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{{Adams | |||
| number = ML20141E420 | |||
| issue date = 06/20/1997 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-219/96-09 & 50-219/96-11 | |||
| author name = Eselgroth P | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = Roche M | |||
| addressee affiliation = GENERAL PUBLIC UTILITIES CORP. | |||
| docket = 05000219 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-219-96-09, 50-219-96-11, 50-219-96-9, NUDOCS 9707010056 | |||
| title reference date = 01-24-1997 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 2 | |||
}} | |||
See also: [[see also::IR 05000219/1996009]] | |||
=Text= | |||
{{#Wiki_filter:-. . . | |||
,- | |||
I | |||
. | |||
June 20, 1997 , | |||
Mr. Michael B. Roche | |||
Vice President and Director | |||
GPU Nuclear Corporation | |||
Oyster Creek Nuclear Generating Station | |||
P.O. Box 388 | |||
Forked River, New Jersey 08731 | |||
SUBJECT: NRC INTEGRATED INSPECTION REPORTS 50-219/96-09 and 50-219/96-11 | |||
AND NOTICE OF VIOLATION | |||
Dear Mr. Roche: | |||
This letter refers to your January 24,1997 correspondence, in response to our | |||
December 6,1996 and January 2,1997 letters. | |||
Thank you for informing us of the corrective and preventive actions documented in your | |||
letter. These actions will be examined during a future inspection of your licensed program. | |||
Your cooperation with us is appreciated. | |||
Sincerely, | |||
Original Signed By: | |||
Peter W. Eselgroth, Chief | |||
Projects Branch 7 | |||
Division of Reactor Projects | |||
Docket No.: 50-219 | |||
cc: w/o cy of Licensee's Response Letter | |||
G. Busch, Manager, Site Licensing, Oyster Creek | |||
M. Laggart, Manager, Corporate Licensing | |||
cc: w/cy of Licensee's Response Letter | |||
State of New Jersey | |||
910003 | |||
i | |||
a a < u | |||
b,o I | |||
9707010056 970620 / | |||
PDR ADOCK 05000219 | |||
G PDR | |||
E | |||
._ _ . _ _ . . ___. . . . _ . . - _ _. _ . _ . ~ . . _ _ . _ . _. _ __ -_ _._ . | |||
4 | |||
, | |||
I | |||
, | |||
i | |||
2 1 | |||
' | |||
* | |||
Distribution w/cv of Licensee Response Letter | |||
Region I Docket Room (with concurrences) | |||
,~ | |||
Nuclear Safety Information Center (NSIC) | |||
PUBLIC | |||
, | |||
NRC Resident inspector | |||
D. Screnci, PAO | |||
4 | |||
P. Eselgroth, DRP | |||
I D. Haverkamp, DRP | |||
4 | |||
J. Nick, DRP | |||
. | |||
C. O'Daniell, DRP | |||
l W. Dean, OEDO l | |||
i P. Milano, NRR/PD l-3 . | |||
! R. Eaton, NRR/PD 1-3 | |||
i R. Correia, NRR | |||
l D. Taylor, NRR | |||
! Inspection Program Branch, NRR (IPAS) | |||
i | |||
; | |||
i | |||
i | |||
i | |||
l | |||
! | |||
i | |||
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. | |||
4 | |||
! DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\OC960911 rpy | |||
To recdve e copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy | |||
OFFICE ~31/DRP W Rl/DRP / | |||
NAME JNick fJ PEselgroth | |||
DATE fA7/97 6 //f/97 | |||
OFFICIAL RECORD COPY | |||
. | |||
. .. . | |||
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, , .. .. | |||
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NUCLEAR 'ornes River. L 0473: 231 | |||
73 . 6;i 37i-C. | |||
January 24, 1997 | |||
6730-97-2030 | |||
U. S. Nuclear Regulatory Commission | |||
Attention: Document Control Desk | |||
Washington, DC 20555 | |||
Dear Sir. | |||
Subject: Oyster Creek Nuclear Generating Station | |||
Docket No. 50 219 | |||
Reply to a Notice of Violation | |||
inspection Reports: 96-09 and 96-11 | |||
in accordance with 10 CFR 2.201. Attachment I provides GPU Nuclear's response to the | |||
violations identified in the subject inspection reports. During discussions held with Region 1 NRC | |||
staff on January 6.1997, it was agreed that the due date for this response would be extended to | |||
January 24,1997, | |||
if you should have any questions or require further information, please contact Brenda | |||
DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642. | |||
Very truly yours, | |||
.. - | |||
, , - | |||
l. u .. J P W " --L | |||
.. | |||
Michael B. Roche | |||
Vice President and Director | |||
Oyster Creek | |||
MBR/BDE/gl | |||
, | |||
l | |||
' | |||
cc- . Administrator, Region i | |||
' | |||
NRC Project Manager | |||
NRC Sr. Resident inspector | |||
! | |||
$702DQ M / hff | |||
- _ __ _ _ _. _ _._ _ _ _ _ __ . . _ . _ _ _ .. _ _ . _ _ __ | |||
, , . . | |||
, | |||
,_ , | |||
. | |||
. | |||
Response to IR 96-009 Notice of Violations | |||
Violation i | |||
Technical Specification 6.81 states, written procedures shall be established. implemented, and | |||
maintained that meet or exceed the requirements of NRC Regulatory Guide 1.33 - | |||
NRC Regulatory Guide 1.33, Appendix A, Paragraphs 4 and I, state, in part, that procedures | |||
should be prepared as appropriate, for Startup, Operation, and Shutdown of Safety-Related BWR ! | |||
Systems, including the Control Rod Drive System, and Administrative Procedures including | |||
Equipment Control (e.g., Locking and Tagging). | |||
1 | |||
Procedure 302.1, Control Rod Drive Hydraulic System, Revision 57, Section 10.0, Alternate | |||
* | |||
CRD Cooling and Drive Water Supply, Paragraph 10.3.5, Steps 10.3.5.1, and 10.3.5.2, directed | |||
the operator to Open valves V-11-49 and V-ll-63 (to provide a water source for the Jockey _; | |||
pump). | |||
Contrary to the above, on September 17,1996, the operator f6?ed to follow the procedure and | |||
opened valves V-ll-44 and V-Il-63. V-II-63 was subsequently closed to isolate a hose leak and | |||
V-11-44 was left open. This valving error caused the cross connection of the fire water system | |||
and the condensate transfer system and resulted in an unplanned and unmonitored release of | |||
133,000 gallons of slightly radioactive water when the correct valve, V-l l-49, was opened to | |||
place the alternate CRD system in service. | |||
Procedure 108 5. Control of Locked Valves and Breakers, Revision 1, Section 4.1 1. the criteria | |||
for locking valves shall be: Step 4.1.1.7 states, " Valves that are required to be positioned to | |||
prevent contamination of other systems or areas (radiological, chemical, liquid waste, etc.) " | |||
Contrary to the above, valve V-11-44, a valve that prevents cross contamination of the fire system | |||
from the condensate transfer system, was not locked. This is a second example of failure to | |||
follow procedure which contributed to the unplanned and unmonitored release of 133,000 gallons | |||
of slightly radioactive water. | |||
This is a severity Level IV violation. (Supplement I) | |||
Response: | |||
GPUN concurs with the violation as written. | |||
Reason for the Violation: | |||
l The root cause of the Procedure 302.1 violation was personnel error. The operator did not have | |||
the procedure in hand when placing the jockey pump in service and did not properly self check his | |||
; actions to ensure that the correct valve was manipulated. | |||
--. - . . ,. - - - _. | |||
.. . . - - . - _ - . - . . . - . - . - _ . - . = . . _ - - - | |||
;, .. . . . | |||
4 | |||
a | |||
2 | |||
. | |||
. The root cause of the Procedure 108.5 violation was proceduralinadequacy in that relevant | |||
i | |||
information regarding the increased potential for cross contamination occurring while in the | |||
temporary modification configuration was not addressed in the safety review for Procedure 3011 | |||
l | |||
. | |||
l | |||
l The Corrective Steos Taken and the Results Achieved. ; | |||
1 | |||
{ On September 18, at 0830. following the discoverv that an overboard discharge had occurred. | |||
V-11-44 was locked closed and the jockey pump was relocated o a connection where there was | |||
j no potential for an overboard discharge or cross-contamination to occur. Subsequent to this | |||
! incident, operations personnel conducted an extensive investigation documented in a detailed | |||
j critique. | |||
l | |||
Among the completed corrective actions as a result of this incident are the following: | |||
, | |||
A walkdown was performed to ensure that p. >per controls are in place at other system interfaces | |||
l where the potential for discharge or cross-contamination exists As a result, one other valve was | |||
locked and warning signs were posted to indicate that a potential for cross-contamination exists | |||
J | |||
! l | |||
' | |||
: Valve V-l l-44 was renumbered V-9-2099, a Fire Protection System valve number. | |||
$ Shortly after the incident, briefings were conducted with all licensed and non-licensed operators ) | |||
which included the following topics: i | |||
4 | |||
; e The need to maintain awareness of plant status above all other priorities was re- | |||
i emphasized, | |||
1 | |||
I | |||
! . Shift briefings to review plant status at the beginning of each shift were instituted; | |||
:! | |||
' | |||
. The need to employ self-checking was re-emphasized, | |||
, | |||
1 | |||
; e " Procedure in-hand" requirements were re-emphasized, j | |||
' \ | |||
e The need to understand changing plant conditions and aggressively identify | |||
unknown conditions was re-emphasized. 1 | |||
1 1 | |||
3 | |||
A safety evaluation to address continued operation of the Fire Protection System as a | |||
contaminated system was completed | |||
The Corrective Steos that will be Taken to Avoid Further Violations: | |||
Procedural guidance will be developed and training provided to assist operations personnel in | |||
identifying tank inventories and expected changes during refueling outages when tank inventories | |||
are subject to wide fluctuations; | |||
. . _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ ._._ _ _ _ _ _ _ _ _ _ _ _ _ | |||
L, c . . . | |||
1 | |||
; ' | |||
; | |||
, _ | |||
!* | |||
j The practice of allowing temporary modifications to be added to procedures without the | |||
j Technical Evaluation form from Procedure 108 8 will be re-evaluated to ensure that controls are | |||
, | |||
adequate | |||
: | |||
l | |||
, A standing order or procedural controls will be developed to include a listing of potential cross- ) | |||
[ contamination and overboard discharge points, instructions and restrictions, as needed, to ensure | |||
l proper operation of the effected components, and instructions for response to a spill or discharge. | |||
! | |||
? | |||
These actions will be co.Nieted by the end of the first quarter,1997. 1 | |||
1 | |||
-l | |||
l', Full compliance was achieved on September 18,1996, at 0830 when valve V-11-44 was closed | |||
l' | |||
l and locked. | |||
; ! | |||
: | |||
. | |||
! Violation 2 ] | |||
j 1 | |||
i Code of Federal Regulations Title 10, Energy, Part 50.59, Changes, Tests and Experiments, l | |||
l Section (a)(1), states that the holder of a license (i) may make changes to the facility as described ! | |||
j in the safety analysis report, and (ii) make changes in procedures as described in the safety | |||
j analysis report without prior Commission approval, unless the proposed change involves a change | |||
f - | |||
in the Technical Specifications or involves an unreviewed safety question. Section (b)(1) states ! | |||
that the licensee shall maintain records of changes ... made pursuant to this section. Those | |||
records must include a written safety evaluation which provides the basis for the determination . | |||
that the change does not involve an unreviewed safety question l | |||
Contrary to the above. a permanent change (September,1994) was made to Procedure 3021, | |||
Control Rod Drive Hydraulic System and to the facility, as described in the safety analysis report | |||
(SAR) involving use of a CRD " jockey pump" to provide a different means of providing a CRD | |||
cooling and drive water supply than was described in the SAR without a written safety evaluation | |||
to determine if an unreviewed safety question existed. A second minor example of failure to | |||
perform a written safety evaluation as required by 10 CFR 50.59 occurred in July,1995, when an | |||
annunciator alarm function described in the SAR was disabled. | |||
This is a severity Level IV violation (Supplement 1) | |||
Subsequent to receiving the above violation, the following similar violation was received in | |||
Inspection Report 96-11: | |||
Title 10. Code of Federal Regulations, Part 50 59, " Changes, Tests, and Experiments." (10 CFR ) | |||
50.59), Section (a)(1) requires, in part, that licensees may make changes in procedures as | |||
described in the safety analysis report without prior NRC approval, unless the proposed change | |||
involves an unreviewed safety question. Section (b)(2) of 10 CFR 50.59 requires, in part, that i | |||
licensee's records of changes in procedures must include a written safety evaluation which | |||
provides the bases for the determination that the change does not involve an unreviewed safety | |||
question. | |||
- .- - | |||
- - - - - . .. . . - - -. . .. . . - - | |||
, . _ . . . | |||
. | |||
l | |||
. l | |||
l | |||
< | |||
l | |||
Contrary to the above a written safety evaluation was not performed to provide the bases for the l | |||
determination that a change to station procedure 336.3. " Generator Hydrogen Gas System," did l | |||
not involve an unreviewed safety question. Specifically, on Febmary 23,1994, procedure 336.3 l | |||
was changed to add instruction to manually adjust cooling How for the generator hydrogen I | |||
coolers rather than using the automatic temperature control valve as described in the safety | |||
l | |||
analysis repon, however, a written safety evaluation was not completed. ' | |||
1 | |||
This is a severity level IV violation. I | |||
Resnonse: | |||
l | |||
GPU Nuclear concurs with the violations with regard to incomplete safety evaluations. The | |||
practice of using a jockey pump is controlled as a temporary modification and, therefore, does | |||
not constitute a permanent change to the facility. | |||
l | |||
Eggon for the Violations: | |||
The violations occurred due to personnel error in not accurately addressing the questions of the | |||
GPU Nuclear 10 CFR 50.59 Safety Determination form used at that time. | |||
The Corrective Steos Taken and Results Achieved | |||
In all instances where inaccurate safety determinations have been performed the appropriate | |||
system engineers have been assigneo action to review and revise or prepare, if necessary, a safety | |||
evaluation which accurately re6ects the Safety Analysis Report (SAR) or propose a change to the , | |||
FS AR, if required l | |||
I | |||
The Corrective Steps that will be taken to Avoid Further Violations: | |||
1 | |||
l | |||
The Safety Review training program will be enhanced emphasizing the need to accurately answer | |||
the safety determination questions and will include discussions of the tools available to assist in | |||
these reviews (e g., computer databases, etc.). These violations will be used as examples to | |||
emphasize the importance of performing thorough reviews and preparing complete | |||
documentation, as well as examples of where SAR revisions are warranted. | |||
A " Safety Review Newsletter" will be prepared and issued to all qualified safety reviewers | |||
clarifying and reinforcing expectations as well as citing these examples ofimproper safety . | |||
evaluations. l | |||
Full compliance will be achieved when the appropriate system engineer has reviewed the incorrect | |||
safety determination and revises or updates / corrects it. Cited safety evaluations involving | |||
recurring outage related modifications (jockey pump) will be completed six months prior to the | |||
next outage which is currently scheduled for October,1998. Safety evaluations involving the | |||
remaining inaccuracies will be reviewed and revised by the end of the first quarter,1997. | |||
Regarding Station Procedure 336.3, " Generator Hydrogen Gas System," the continued operation | |||
l | |||
. __ | |||
, . - ..- . , ' . | |||
. | |||
. | |||
4 | |||
of the plant while the safety evaluation is being written has been determined to be acceptable as | |||
the Turbine Building Closed Cooling Water System is not Nuclear Safety Related and cools no | |||
safety related components.- | |||
I | |||
l | |||
l | |||
1 | |||
.: | |||
! | |||
) | |||
- , - _ . . .- .. . - . . - . . - , . . - . - - | |||
. , | |||
}} |
Latest revision as of 11:54, 8 August 2022
ML20141E420 | |
Person / Time | |
---|---|
Site: | Oyster Creek |
Issue date: | 06/20/1997 |
From: | Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
To: | Roche M GENERAL PUBLIC UTILITIES CORP. |
References | |
50-219-96-09, 50-219-96-11, 50-219-96-9, NUDOCS 9707010056 | |
Download: ML20141E420 (2) | |
See also: IR 05000219/1996009
Text
-. . .
,-
I
.
June 20, 1997 ,
Mr. Michael B. Roche
Vice President and Director
GPU Nuclear Corporation
Oyster Creek Nuclear Generating Station
P.O. Box 388
Forked River, New Jersey 08731
SUBJECT: NRC INTEGRATED INSPECTION REPORTS 50-219/96-09 and 50-219/96-11
AND NOTICE OF VIOLATION
Dear Mr. Roche:
This letter refers to your January 24,1997 correspondence, in response to our
December 6,1996 and January 2,1997 letters.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
Original Signed By:
Peter W. Eselgroth, Chief
Projects Branch 7
Division of Reactor Projects
Docket No.: 50-219
cc: w/o cy of Licensee's Response Letter
G. Busch, Manager, Site Licensing, Oyster Creek
M. Laggart, Manager, Corporate Licensing
cc: w/cy of Licensee's Response Letter
State of New Jersey
910003
i
a a < u
b,o I
9707010056 970620 /
PDR ADOCK 05000219
G PDR
E
._ _ . _ _ . . ___. . . . _ . . - _ _. _ . _ . ~ . . _ _ . _ . _. _ __ -_ _._ .
4
,
I
,
i
2 1
'
Distribution w/cv of Licensee Response Letter
Region I Docket Room (with concurrences)
,~
Nuclear Safety Information Center (NSIC)
PUBLIC
,
NRC Resident inspector
D. Screnci, PAO
4
P. Eselgroth, DRP
I D. Haverkamp, DRP
4
J. Nick, DRP
.
C. O'Daniell, DRP
l W. Dean, OEDO l
i P. Milano, NRR/PD l-3 .
! R. Eaton, NRR/PD 1-3
i R. Correia, NRR
l D. Taylor, NRR
! Inspection Program Branch, NRR (IPAS)
i
i
i
i
l
!
i
'
,
t
J
!
i
.
4
! DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\OC960911 rpy
To recdve e copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy
OFFICE ~31/DRP W Rl/DRP /
NAME JNick fJ PEselgroth
DATE fA7/97 6 //f/97
OFFICIAL RECORD COPY
.
. .. .
.. --_ _ . - . - -_ -- . . . -.
, , .. ..
l
i '
!.
t .
l
.
GPU ?id::;s .-
' * C"'" b " "
NUCLEAR 'ornes River. L 0473: 231
73 . 6;i 37i-C.
January 24, 1997
6730-97-2030
U. S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20555
Dear Sir.
Subject: Oyster Creek Nuclear Generating Station
Docket No. 50 219
Reply to a Notice of Violation
inspection Reports: 96-09 and 96-11
in accordance with 10 CFR 2.201. Attachment I provides GPU Nuclear's response to the
violations identified in the subject inspection reports. During discussions held with Region 1 NRC
staff on January 6.1997, it was agreed that the due date for this response would be extended to
January 24,1997,
if you should have any questions or require further information, please contact Brenda
DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
Very truly yours,
.. -
, , -
l. u .. J P W " --L
..
Michael B. Roche
Vice President and Director
Oyster Creek
MBR/BDE/gl
,
l
'
cc- . Administrator, Region i
'
NRC Project Manager
NRC Sr. Resident inspector
!
$702DQ M / hff
- _ __ _ _ _. _ _._ _ _ _ _ __ . . _ . _ _ _ .. _ _ . _ _ __
, , . .
,
,_ ,
.
.
Response to IR 96-009 Notice of Violations
Violation i
Technical Specification 6.81 states, written procedures shall be established. implemented, and
maintained that meet or exceed the requirements of NRC Regulatory Guide 1.33 -
NRC Regulatory Guide 1.33, Appendix A, Paragraphs 4 and I, state, in part, that procedures
should be prepared as appropriate, for Startup, Operation, and Shutdown of Safety-Related BWR !
Systems, including the Control Rod Drive System, and Administrative Procedures including
Equipment Control (e.g., Locking and Tagging).
1
Procedure 302.1, Control Rod Drive Hydraulic System, Revision 57, Section 10.0, Alternate
CRD Cooling and Drive Water Supply, Paragraph 10.3.5, Steps 10.3.5.1, and 10.3.5.2, directed
the operator to Open valves V-11-49 and V-ll-63 (to provide a water source for the Jockey _;
pump).
Contrary to the above, on September 17,1996, the operator f6?ed to follow the procedure and
opened valves V-ll-44 and V-Il-63. V-II-63 was subsequently closed to isolate a hose leak and
V-11-44 was left open. This valving error caused the cross connection of the fire water system
and the condensate transfer system and resulted in an unplanned and unmonitored release of
133,000 gallons of slightly radioactive water when the correct valve, V-l l-49, was opened to
place the alternate CRD system in service.
Procedure 108 5. Control of Locked Valves and Breakers, Revision 1, Section 4.1 1. the criteria
for locking valves shall be: Step 4.1.1.7 states, " Valves that are required to be positioned to
prevent contamination of other systems or areas (radiological, chemical, liquid waste, etc.) "
Contrary to the above, valve V-11-44, a valve that prevents cross contamination of the fire system
from the condensate transfer system, was not locked. This is a second example of failure to
follow procedure which contributed to the unplanned and unmonitored release of 133,000 gallons
of slightly radioactive water.
This is a severity Level IV violation. (Supplement I)
Response:
GPUN concurs with the violation as written.
Reason for the Violation:
l The root cause of the Procedure 302.1 violation was personnel error. The operator did not have
the procedure in hand when placing the jockey pump in service and did not properly self check his
- actions to ensure that the correct valve was manipulated.
--. - . . ,. - - - _.
.. . . - - . - _ - . - . . . - . - . - _ . - . = . . _ - - -
- , .. . . .
4
a
2
.
. The root cause of the Procedure 108.5 violation was proceduralinadequacy in that relevant
i
information regarding the increased potential for cross contamination occurring while in the
temporary modification configuration was not addressed in the safety review for Procedure 3011
l
.
l
l The Corrective Steos Taken and the Results Achieved. ;
1
{ On September 18, at 0830. following the discoverv that an overboard discharge had occurred.
V-11-44 was locked closed and the jockey pump was relocated o a connection where there was
j no potential for an overboard discharge or cross-contamination to occur. Subsequent to this
! incident, operations personnel conducted an extensive investigation documented in a detailed
j critique.
l
Among the completed corrective actions as a result of this incident are the following:
,
A walkdown was performed to ensure that p. >per controls are in place at other system interfaces
l where the potential for discharge or cross-contamination exists As a result, one other valve was
locked and warning signs were posted to indicate that a potential for cross-contamination exists
J
! l
'
- Valve V-l l-44 was renumbered V-9-2099, a Fire Protection System valve number.
$ Shortly after the incident, briefings were conducted with all licensed and non-licensed operators )
which included the following topics: i
4
- e The need to maintain awareness of plant status above all other priorities was re-
i emphasized,
1
I
! . Shift briefings to review plant status at the beginning of each shift were instituted;
- !
'
. The need to employ self-checking was re-emphasized,
,
1
- e " Procedure in-hand" requirements were re-emphasized, j
' \
e The need to understand changing plant conditions and aggressively identify
unknown conditions was re-emphasized. 1
1 1
3
A safety evaluation to address continued operation of the Fire Protection System as a
contaminated system was completed
The Corrective Steos that will be Taken to Avoid Further Violations:
Procedural guidance will be developed and training provided to assist operations personnel in
identifying tank inventories and expected changes during refueling outages when tank inventories
are subject to wide fluctuations;
. . _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ ._._ _ _ _ _ _ _ _ _ _ _ _ _
L, c . . .
1
- '
, _
!*
j The practice of allowing temporary modifications to be added to procedures without the
j Technical Evaluation form from Procedure 108 8 will be re-evaluated to ensure that controls are
,
adequate
l
, A standing order or procedural controls will be developed to include a listing of potential cross- )
[ contamination and overboard discharge points, instructions and restrictions, as needed, to ensure
l proper operation of the effected components, and instructions for response to a spill or discharge.
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These actions will be co.Nieted by the end of the first quarter,1997. 1
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l', Full compliance was achieved on September 18,1996, at 0830 when valve V-11-44 was closed
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! Violation 2 ]
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i Code of Federal Regulations Title 10, Energy, Part 50.59, Changes, Tests and Experiments, l
l Section (a)(1), states that the holder of a license (i) may make changes to the facility as described !
j in the safety analysis report, and (ii) make changes in procedures as described in the safety
j analysis report without prior Commission approval, unless the proposed change involves a change
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in the Technical Specifications or involves an unreviewed safety question. Section (b)(1) states !
that the licensee shall maintain records of changes ... made pursuant to this section. Those
records must include a written safety evaluation which provides the basis for the determination .
that the change does not involve an unreviewed safety question l
Contrary to the above. a permanent change (September,1994) was made to Procedure 3021,
Control Rod Drive Hydraulic System and to the facility, as described in the safety analysis report
(SAR) involving use of a CRD " jockey pump" to provide a different means of providing a CRD
cooling and drive water supply than was described in the SAR without a written safety evaluation
to determine if an unreviewed safety question existed. A second minor example of failure to
perform a written safety evaluation as required by 10 CFR 50.59 occurred in July,1995, when an
annunciator alarm function described in the SAR was disabled.
This is a severity Level IV violation (Supplement 1)
Subsequent to receiving the above violation, the following similar violation was received in
Inspection Report 96-11:
Title 10. Code of Federal Regulations, Part 50 59, " Changes, Tests, and Experiments." (10 CFR )
50.59), Section (a)(1) requires, in part, that licensees may make changes in procedures as
described in the safety analysis report without prior NRC approval, unless the proposed change
involves an unreviewed safety question. Section (b)(2) of 10 CFR 50.59 requires, in part, that i
licensee's records of changes in procedures must include a written safety evaluation which
provides the bases for the determination that the change does not involve an unreviewed safety
question.
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Contrary to the above a written safety evaluation was not performed to provide the bases for the l
determination that a change to station procedure 336.3. " Generator Hydrogen Gas System," did l
not involve an unreviewed safety question. Specifically, on Febmary 23,1994, procedure 336.3 l
was changed to add instruction to manually adjust cooling How for the generator hydrogen I
coolers rather than using the automatic temperature control valve as described in the safety
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analysis repon, however, a written safety evaluation was not completed. '
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This is a severity level IV violation. I
Resnonse:
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GPU Nuclear concurs with the violations with regard to incomplete safety evaluations. The
practice of using a jockey pump is controlled as a temporary modification and, therefore, does
not constitute a permanent change to the facility.
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Eggon for the Violations:
The violations occurred due to personnel error in not accurately addressing the questions of the
GPU Nuclear 10 CFR 50.59 Safety Determination form used at that time.
The Corrective Steos Taken and Results Achieved
In all instances where inaccurate safety determinations have been performed the appropriate
system engineers have been assigneo action to review and revise or prepare, if necessary, a safety
evaluation which accurately re6ects the Safety Analysis Report (SAR) or propose a change to the ,
FS AR, if required l
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The Corrective Steps that will be taken to Avoid Further Violations:
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The Safety Review training program will be enhanced emphasizing the need to accurately answer
the safety determination questions and will include discussions of the tools available to assist in
these reviews (e g., computer databases, etc.). These violations will be used as examples to
emphasize the importance of performing thorough reviews and preparing complete
documentation, as well as examples of where SAR revisions are warranted.
A " Safety Review Newsletter" will be prepared and issued to all qualified safety reviewers
clarifying and reinforcing expectations as well as citing these examples ofimproper safety .
evaluations. l
Full compliance will be achieved when the appropriate system engineer has reviewed the incorrect
safety determination and revises or updates / corrects it. Cited safety evaluations involving
recurring outage related modifications (jockey pump) will be completed six months prior to the
next outage which is currently scheduled for October,1998. Safety evaluations involving the
remaining inaccuracies will be reviewed and revised by the end of the first quarter,1997.
Regarding Station Procedure 336.3, " Generator Hydrogen Gas System," the continued operation
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of the plant while the safety evaluation is being written has been determined to be acceptable as
the Turbine Building Closed Cooling Water System is not Nuclear Safety Related and cools no
safety related components.-
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