ML20212A828

Responds to NRC Re Violations Noted in Insp Rept 50-219/97-06.Corrective Actions:Updated Job Order Re Work Performed,Counseled Supervisor of Requirements of Procedure 105, Conduct of Maint & Reviewed Violation W/Personnel

ML20212A828
Person / Time
Site:	Oyster Creek
Issue date:	10/17/1997
From:	Roche M GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-219-97-06, 50-219-97-6, 6730-97-2251, NUDOCS 9710270016
Download: ML20212A828 (13)

Text

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{ GPU Nuclest. Inc.

( U s Route #9 south NUCLEAR [,*,7,0"f,8%

, *7mma Tel 609 9714E October 17. 1997 6730-97 2251 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50 219 Inspection Report 97-06 I

Reply to a Notice of Violation Byletter da:ed September 17,1997, the NRC docketed Inspection Report 50-219/97-06.

Enclosure I to that Report contained two Notices of Violation. Attachment I to this letter provides the requisite replies to the two violations.

If any additional information or assistance is required, please contact Ms. Brenda S. DeMerchant of my staff at 609 971-4642.

Very truly yours, Michael B. Roche

( ' N710270016 ADOCK97101f 050002 9 Vice President and Director

$DR Oyster Creek MBR/BDE

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Attachment i o u, ,i

[ LJ,I cc: Administrator, Region 1 NRC Project Manager Senior Resident inspector

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Attachment I NRC Notice of Violation 1 Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained that meet or exceed the requirements of NRC Regulatory Guide 1.33.

Contrary to the above, procedure requirements were not established, implemented and maintained I as indicated by the following examples.

A. NRC Regulatory Guide 1.33, Appendix A recommends procedures for the control of l maintenance, repair, replacement, and modification work. 1 Procedure 105, Revision 37, Conduct ofMaintenance, step 4.3.2.24 requires the worker to maintain the work document up-to-date with suflicient information of the work performed, results achieved, and data obtained to provide for future reference and, if necessary, for reconstruction of the work activities.

Contrary to the above, prior to July 24,1997, an electrical worker did not maintain job order 00515622 work package up-to-date with suflicient information concerning work performed on July 15,1997, and post maintenance test results achieved on July 17,1997.

In particular, the worker did not document corrective action taken, cause of failure, work order completion, and post maintenance test results.

B. NRC Regulatory Guide 1.33, Appendix A recommends Administrative Procedures for the scheduling of suneillance tests and calibration.

Procedure 116, Revision 59, Surveillance 7i'st Program, step 4.3.4 requires that a Temporary Interruption of Surveillance Test Form shall be used to control and record interruptions of a surveillance test. Step 4.3.4.6 requires permission to recommence sun eillance tests.

Contrary to the above, on Jt N . 2,1997, electrical technicians did not use a Temporary Interruption of Surveillance 'i est Form to control and record interruption of procedure 636.2.012, Diesel Generator Battery Service Test, when the Group Operating Supervisor interrupted the surveillance, in addition, on July 24,1997, electrical technicians recommenced procedure 636.2.012, Diesel Generator Battery Service 7irst, and did not obtain permission.

C. NRC Regulatory Guide 1.33, Appendix A recom. mends procedures for the plant fire protection program. Procedure 101.2, revision 23, Fire Protection Program, section 5.1.2 requires, in part, that station operations be carried out in accordance with the

operating license (including Technical Requirements, Attachment 101.2 3) and NRC

' commitments. Technical Requirement 5.A.1 requires, in part, that all sealing devices in fire rated assembly penetrations (fire doors listed in Table 6, tire dampers, cable, piping, and ventilation duct penetration seals) shall be intact except for periods of planned rnaintenance.

Contrary to the above, on August 5,1997, the licensee did not maintain a 4160 vault roll-up fire door (listed in Table 6 of the Technical Requirements) intact and the operating shill did not authorize any planned maintenance.

D. NRC Regulatory Guide 1.33, Appendix A recommends procedures for the plant Fire Protection Program. Procedure 120.5, revision 8, Control of Combu3tibks, section 4.5.3.1 requires, in part, that where replenishment activities require handling of combustible liquids within safety related areas, the combustible liquid may be transported only in its original container or in an approved closed metal container, Any unused l portions will be removed from the area.

l l Contrary to the above, prior to approximately 3:30 a.m. on August 6,1997, the licensee handled combustible liquids in the upper cable spreading room, a safety related area, and did not remove unused portions, two gallons of refrigeration oil and one gallon of vacuum pnmp oil, from the area.

f Reason for Violation GPUN concurs with this violation.

A review of the identified examples indicates that the procedural requirements were not adequately implemented and that in each car,e, the procedures involved were of an administrative nature These kinds of documents are not included in the work package. Personnel receive instruction in these administrative procedures during initial qualification and are updated on any changes to these procedures as they occur, Periodic refresher training on the entire document has typically not been conducted in the past.

Additional information associated with each example identified in the violation is provided below.

Caricctive Actions Taken andlhe.RendttAchiered Immediate corrective actions taken are as detailed under each example as listed below.

Corrective Steps that will be taken to Avoid Further Violaiion The Plant Maintenance Department will include, within its cyclic training program; designated periods for review of those selected administrative procedures that govern the performance of work. This refresher training should serve to reinforce those aspects ofour work controlling documents needed to prevent recurrence. Additional actions taken to reinforce management's' expectations of procedure compliance are as identified under each example as listed below.

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Date When Full Comollance Will Be Achieved

. Full compliance was achieved as identified under each example listed below. The Maintenance Department cyclic training program beginning in 1998 will be modified to include Administrative Procedure Refresher Training.

AdditionalInformation Examnie 1 At NRC Regulatory Guide 1.33, Appendix A recommends procedures for the control of maintenance, repair, replacement, and modification work.

Procedure 105, Revision 37, Conduct o/ Maintenance, step 4.3.2.24 requires the worker to maintain the work document up to-date with suflicient information of the work performed, results achieved, and data obtained to provide for future reference and, if necessary, for reconstruction of -

the work activities.

Contrary to the above, prior to July 24,1997, an electrical worker did not maintain job order 00515622 work package up to date with sullicient information concerning aork performed on l July 15,1997, and post maintenance test results achieved on July 17,1997. In particular, the worker did not document corrective action taken, cause of failure, work o der completion, and post maintenance test results.

Additional Information for Examnie 1 A Reason for the Violation The Job Order (Work Controlling Doctnent) was not updated or completed in a timely manner as required by procedure 105, due to inadequate communications between the Job Supervisor and the Operations Department concerning the status of the testing performed by Operations to address the deficiency identified in a Reactor Building exhaust fan breaker control circuit.

Corrective Actions Taken and The_Briults Achieved The Job Order was updated concerning the work perfonned and a status of closed was entered into the GPUN Work Control System. Immediately upon being informed of this deficiency, the supervisor was coached on the requirements of Procedure 105, " Conduct of Maintenance" and the requirement to maintain the work document up to date. The need to inform Operations of the work progress and testing status was specifically addressed. Subsequent to this coaching session the Plant Maintenance Director reviewed this violation with all electrical department personnel at a weekly shop meeting and discussed the nature of the deficiency, the importance of accurate and timely statusing of work, and management's expectations for procedural compliance.

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Eutute Actions to De Taken To Precluddecutience The Plant Maintenance Director is discussing this violation in weekly Msnagement Interface sessions with the Maintenance crews in training.

Dale _WhettEull Complitn.tcJill De Achitml Full compliance was achieved on 08/29/97 when the Job Order was fully documented and closed.

The shop meeting with all electrical department personnel wa: conducted on 10/01/97. The Management Interface discussions will be completed by the end of the current training cycle November 30,1997.

Fxamnic 1 B NRC Regulatory Guide 1.33, Appendix A recommends Administiative Procedures for the scheduling of surveillance tests and calibration.

l Procedure 116. Revision 59, Surw//kmcc net Program, step 4.3.4 requires that a Temporary l

Interruption of Surveillance Test Form shall be used to control and record interruptions of a surveillance test. Step 4.3.4.6 requires permission to recommence surveillance tests.

Contrary to the above, on July 22,1997, electrical technicians did not use a Temporary Interruption of Surveillance Test Form to control and record intermption of procedure 636.2.012, D/esel Generator Battery Service Test, when the Group Operating Supenisor interrupted the surveillance. In addition, on July 24,1997, electrical technicians recommenced procr+ne 636.2.012, D/esel Generator hattery Service Test, and did not obtain permission.

Additional Information for Example IB Reason for the Violatian The Job Supenisor failed to follow the requirements of Procedure 116, which clearly required the use of the Temporary Interruption of Surveillance Test Form. The supenisor relied inappropriately on verbal discussions with Operations personnel in controlling the stopping and restart of the surveillance activity.

Corrective Actions Taken and TJ1e Results Achieved As stated in the Inspection Report, the suneillance was corr.pleted with satisfactory results.

Upon being informed of this deficiency, the supenisor was coached on the requirements of Procedure 116. " Surveillance Test Program" concerning the procedure requirements and management's expectations regarding the control of surveillance activities and procedural compliance.

Subuquent to the coaching session the Plant Maintenance Director reviewed this violation with all electrical department personnel at a weekly shop meeting and discussed the nature of the deficiency and the importance of complying with administrative procedural requirements and exercising control over work activities Euture Actions to be taken to Precludsleguttggqc The Plant Maintenance Director is discussing this violation in weekly Management Interface sessions with the Maintenance crews in training.

Date when Full Compliance will be Achieved Full compliance was achieved with the ampletion of surveillance 636.02.012 on 07/24/97. The shop meeting with all electrical depanment personnel was conducted on 10/01/97. The Management Interface discussions will be completed by the end of the current training cycle November 30,1997.

Example IC NRC Regulatory Guide 1.33, Appendix .A recommends procedures for the plant fire protection program. Procedure 101.2, revision 23, Fire Protection Program, section 5.1.2 requires, in part, that station operations be carried out in accordance with the operating license (including Technical Requirements, Attachment 101.2-3) and NRC commitments. Technical Requirement

5. A.1 requires, in part, that all spling devices in fire rated assembly penetrations (fire doors listed in Table 6, fire dampers, cah. pe g,n and ventilation duct penetration seals) shall be intact except for periods of planned maintenance.

Contrary to the above, on August 5,1997, the licensee did not maintain a 4160 vault roll-up fire door (listed in Tablu 6 of the Technical Requirements) intact and the operating shill did not authorize any planned maintenance.

. Additional Information for Examnic IC Reason for the Violation While performing testing in the "D" 4160 Switchgear Room the technicians failed to comply with the station's procedure 101.2 regarding fire barriers and inappropriately raised the fire barrier to run an extension cord.

Corrective Actions Taken and Rg3ults Achieved Upon identification of the breached fire barrier, the GOS dispatched an eqi ment operator who removed the extension cord and secured the fire door. A deviation report was issued and entered into the corrective action system. A modification to install permanent 120V receptacles was accelerated on the schedule and installation was subsequently completed September 5,1997

The Plant hiaintenance Director reviewed the violation with all electrical department personnel at a weekly shop meeting and discussed the nature of the deliciency and the imponance of complying with the provisions of the fire protection program and obsening and complying with posted requirements regarding operation of the fire doors, the necessity to notify the GSS in advance and to ensure that appropriate compensatory measures are taken.

Future Acticns to be taken to Precludelecurrenes in addition, the Plant hiaintenance Director is discussing this violation in weekly hianagement I

interface sessions with the hiaintenance crews in training. The deviation report corrective action of presenting a briefing on fire protection barrier requirements to all hiaintenance personnel is scheduled to be completed by November 30,1997.

! Daic_When Full Compliance Will Be Achieved Full compliance was achieved when the extension cord was removed and the fire door secured on 08/05/97.

EaamnieID NRC Regulatory Guide 1.33, Appendix A recommends procedures for the plant Fire Protection Program. Procedure 120.5, revision 8, ContmlofCombust/b/cs, section 4.5.3.1 requires, in part, that where replenishment activities require handling of combustible liquids within safety related ares.s, the combustible liquid may be transponed only in its original container or in an approved closed metal container. Any unused portions will be removed from the area.

Contrary to the above, prior to approximately 3:30 a.m. on August 6,1997, the licensee handled combustible liquids in the upper cable spreading room, a safety related area, and did not remove unused portions, two gallons of refrigeration oil and one gallon of vacuum pump oil, from the area.

Additional Information for Examnie I D The combustible material left in the upper cable spreading room was utilized in work associated with the 'A' Control Room llVAC system which is located in the rocm. The system had been charged once, but it was believed that aller running the syrtem it would require an additional charge, in the interim, the provisions of Procedure 120.5, " Control of Combustibles" were not followed.

Corrective Actions Taken and Results Achieved The material was immediately removed by an equipment operator.

The Plant hiaintenance Director resiewed the violation with all electrical depanment personnel at a weekly shop meeting and discussed the nature of the deficiency and the importance of complying with the provisions of the fire protection program and obsening and complying with posted requirements iegarding control of combustible materials.

EulutsActions to Be Tak n To Picdudelmittrats The Plant Maintenance Director is discussing this violation in weekly Management Interface sessions with the Maintenance crews in training.

DAlf_\YhCRFull Compliange Will De Achiered Full compliance was achieved on August 6,1997. The shop meeting with all electrical department personnel, at which these violations were discussed, was conducted on 10/01/97. The Management interface discussiens with all Maintenance personnel will be completed by the end of the current training cycle November 30,1997.

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NRC Notice of Violation 2 The Code of Federal Regulations,10 CFR, Part 50, Appendix 13, Criterion XVI (Corrective Action), requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malftmetions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.

Contrary to the abeve, the licensee failed to assure that conditions adverse to quality wem promptly identified and corrected in that several long standing deficiencies, known by individuals i

within the licensee's organization for several years, were not promptly corrected es follows: i GPUN Response to Notice of Violation 2 GPUll concurs witt, this violation. '

Reason for Violatin A review of the identified examples indicates that higher priority activities diverted necessary resources and attention from expeditiously implementing necessary corrective actions.

GPUN recognizes that the four examples of untimely corrective actions indici..e the need to revise our ineffective corrective action program. As discussed in the responses below, we believe the new Corrective Action Program (CAP) will address this concern. Additionally, the long standing nature of the examples indicate lack of personal accountability to meet commitment dates.

Correctise Step 1Ihat llave Been Taken and Rewits Achiered A " Work Performance Standard" (OC-10) emphasizing personnel accountability has recently been issued and discussed with all plant personnel. Individuals have been counseled on management's expectations for n.;eting commitments and taking personal responsibility.

Additional immediate corrective actions taken are as described under each example.

Catlective Steps that will be taken to Avoid Funher Violatin:

To preclude recurrence, the system to control corrective actions is being changed. The existing program for tracking licensing work will be modified to use the corrective action system to control the work in the future. Turnover to the new system will include a review of all outstanding licensing work to identify actions to be included in the Corrective Action Program (CAP) system. The CAP is being developed to not only track open items but will also ensure tunely completion by involving senior management in the process of scheduling and exten' ding due dates.

,e The CAP system is scheduled to be implemented by April 1998. / ,

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Example 2A ,

Since March 1994, the plant stalTfailed to correct known inconsistencies among the containment isolation valve technical specifications (Table 3.5.2), the UFSAR (Table 6.2-12), and the primary containment control procedure (procedure 312.9).

Additional information for Examnle 2 A Stason for Violation The violation occurred when higher priority activities diverted attention from expeditiously implementing corrective actions such as a Technical Specification Change Request (TSCR) when this situation was initially recognized.

Conestive Steps That llave Been Taken and Results Ashitysd I

l It was recognized subsequent to the issuance of Generic Letter 91-06 that the list ofcontainment isolation valves noted in the Technical Specifications differed from those in the UFSAR. This concern was also documented as an unresolved item (URl)in IR 94-03. Upon issuance of the UR1, Operations was tasked to revise the " Primary Conta/nment Controt' procedure 312.9 to create a list which includes all automatic containment isolation valves. This procedure was ,

revised (Rev. 51) in December of 1994. Additionally, although delayed due to higher priorities, a TSCR (TSCR 205) was submitted to the NRC in October of 1996 requesting deletion of Technical Specification Table 3.5 2 which litts automatic primary containment isolation valves.

Corrective Steps that will be taken to Avoid Further Violation:

A major revision of UFSAR Table 6.2-12 is currently ongoing and is expected to be included in the next revision of the UFSAR. This item will be tracked in the revised Corrective Action Program System.

Date When Fu1LCompliance Will Be Achieved Full compliance will be achieved when the TSCR which was submitted October 31,1996, is approved by the NRC.

Example 2B From the time following initial plant licensing (circa 1967-1968), until October 10,1996, the plant staff failed to correct a deficiency whereby the automatic depressurization system permis;ive

. interlock description in technical specifications was not reflected in actual plant configuration.

Additional Information for Example 211 litason for Violation This violation occurred as stated due to untimely actions to address the known deficiency ever an extended period of time.

Ihe Corrective Actions Taken.and the RewlliAchicyed Technical Specification Amendment 190 was received on April 14,1997. The amendment modifies the Technical Specifications (TS) by replacing the description of the existing permissive interlock from "AC Voltage" to core spray booster pump diftbrential pressure (d/p) permissive

(>21.2 psid) for initiation of the automatic depressurization system, adds corresponding surveillance requirements, and adds notes clarifying functional requirements.

Date when Full Comoliance Will Be Achityrd Full compliance was achieved on April 14,1997, upon the issuance of Technical Specification 190.

Example 2C Since 1990, when the licensee recognized and documented that they submitted incorrect j information to the NRC in a 197810CFR50, Appendix J, testing exemption request, the plant staff failed to correct the deficiencies.

&lditional Information for Exampic 2C in the 1978 letter, a statement is made that the entire Shutdown Cooling System (SDC) is seismic category one. Additionally, the NRC response to the exemption request takes credit for a water loop seal between the reactor vessel and the SDC. In the late 1980s, a new postulated line break in the dry well removed the basis for assuming the water loop seal. Further review revealed that the scismic category for the portion of the SDC outside of the outboard isolation valves was not clearly understood. This was described in two Preliminary Safety Concern documents. The resolution of the two concerns determined that no safety issue was involved, but 4. hat new information should be supplied to the NRC.

In the time between 1990 and 1997, work was performed on obtaining the correct information to supply to the stalT. Several different approaches were initiated, but not completed. In 1997, a new methodology was implemented which has resulted in the correct information being developed. This information is presently being prepared for submittal.

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llenen for th S_\'iolation The reason for the delay in submitting the corrected information was the case with which extensions to assigned due dates could be obtained A contributing cause wu that a low priority was assigned to a non-safety issue.

CmtcrliYrActioni_TakCILAndAlt.EClull5ACh!CYtd The corrected information has been calculated and is being design verified for submittal to the NRC. The tracking document has been assigned a due date of December 31,1997. The tracking document has been revised to indicate that this date is not to be extended.

Eulute Actions to be taken to Preclude Resunencs This item will be tracked in the revised Corrective Action Program System.

LhicEhen Full Complallec3 Vill Be AchicYed l

Full compliance will be achieved when the corrected Exception Request is docketed to the NRC.

This will occur prior to December 31,1997.

Example 2D l

Since 1984, upon recognizing that they had inappropriately requested and received a technical specification amendment to allow a higher rnain steam isolation valve closure and low condenser vacuum scram bypass setpoim, plant stafTfailed to correct the technical specification deficiency.

Additional Information for Examnic 2D Prior to the Cycle 10 core reload,'he setpoint for the bypass to the main steam isolation valve closure and low condenser was 600 psig. This number was based on two factors: 1) it was the lower bound of the hiinimum Critical Power Ratio (htCPR) safety limit range; and 2) it limited the amount and rate of primary plant cooldown following a scram. The Cycle 10 reload submittal raised the setpoint in the Technical Specifications (but not in the bases) to 800 psia, based on an increase in the lower bound of the h1CPR safety limit. However, the submittal did not account for the cooldown limits.

When the Technical Specification amendment was received, the omission was identified, and administrative limits were put in place to ensure that the higher value would not be used. As the administrative limit ensured the continued safe operation of the plant, the need for a new Technical Specification Change Request was given a low priority.

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~ Reason for the- Violation --

The reason for the delay :n submitting the corrected information was the ease with which extensions to assigned due dates could be obtained. A contributing cause was that a low priority was assigned to an issue with sumcient administrative controls in place to prevent a safety

- problem.

Corrective Steps Taken and Results Achieved The Safety Evaluation to allow for a new TechnicrJ Specification is available and the Technical Specification Change Request is presently being drafted for submittal. This will occur prior to December 31,1997 Date when Full Comoliance Will Be Achieved Full compliance will be achieved when the corrected Technical Specification Change Request is -

docketed to the NRC. This will occur prior to December 31,1997,

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