ML20141E420

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-219/96-09 & 50-219/96-11

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

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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

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9707010056 970620 /

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Distribution w/cv of Licensee Response Letter

Region I Docket Room (with concurrences)

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Nuclear Safety Information Center (NSIC)

PUBLIC

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NRC Resident inspector

D. Screnci, PAO

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P. Eselgroth, DRP

I D. Haverkamp, DRP

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J. Nick, DRP

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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)

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! 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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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,

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Michael B. Roche

Vice President and Director

Oyster Creek

MBR/BDE/gl

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cc- . Administrator, Region i

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NRC Project Manager

NRC Sr. Resident inspector

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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).

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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.

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. The root cause of the Procedure 108.5 violation was proceduralinadequacy in that relevant

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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

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l The Corrective Steos Taken and the Results Achieved.  ;

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{ 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

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Among the completed corrective actions as a result of this incident are the following:

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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

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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

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e The need to maintain awareness of plant status above all other priorities was re-

i emphasized,

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! . Shift briefings to review plant status at the beginning of each shift were instituted;

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. The need to employ self-checking was re-emphasized,

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e " Procedure in-hand" requirements were re-emphasized, j

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e The need to understand changing plant conditions and aggressively identify

unknown conditions was re-emphasized. 1

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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;

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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

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, 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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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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