ML20010B208
| ML20010B208 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/24/1981 |
| From: | Phyllis Clark JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20010B206 | List: |
| References | |
| NUDOCS 8108140216 | |
| Download: ML20010B208 (17) | |
Text
. .
r g GPU Nuclear 4, , QQgg[ 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:
June 24, 1981 Mr. 'Itunas T. Martin, Acting Director Division of Engineering and Technical Inspection U.b. Nuclear Regulatory 02mtission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 50-219/81-05 This letter is subnitted in response to your letter of May 29, 1981 regarding the 'indings of the inspection by Mr. Blumberg on March 9-13, 1981.
Enclosed as Attachrent A, are our responses to the violations.
Attachment B discusses the irrplementation of our management control systens in the areas concerned with the violations.
If there are any questions regarding the enclosed infonnation, please contact me or Mr. Michael Laggart of my staff at (609) 693-6932.
Very truly yours, 4 d Philip R.jClark Executive Vice President Sworn to and subscribed to before ne this .)V day of b d 1981.
/
. m Ybe MS& S Notary Public #d IRF:ML:lse MICHAEL (AGGART NOTARY PU%IC OF flDY l(Uy attachnents W b = Emres m ern.nu 8108140216 810508' gDRADOCK 05000219 PDR GPU Nuclear is a part of the General Public Utilities System
t cc: Directcr
' Office of Inspection and Enforement Region I U.S. Nuclear Regulatory Otanission 631 Park Avenue King of Prussia, PA 19406 NBC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 i
I 5
k f
_,~.
..7. .. , , .m..,..-., .m ,, _,p,.,,,.,, , , ., , , , , - --.,y,-,_w,,
,,s,....r., _ ,,_, , ,, y., , - 7 s y.- , .. , , .. _ _ , , . --y., . ,. ,.._,. ,
Mr. T. T. Martin Page 1 June 24, 1981 ATIACHMENT A Response to Inspection No. 50-219/81-05
'Ihe following information provides a response to the "Ibtice of Violation" contained in the US NBC letter dated May 29, 1981.
Violation A:
10 CFR 50, Appendix B, Criterion XII, states, in part, " Measures shall be established to assure that . . . gages . . . used in activities affecting quality are properly controlled, < alibrated, and adjusted . . . to traintain accuracy within necessary limits."
Jersey Central Power and Light Otznpany Generation Division Operational Quality Assurance Plan,Section III, Operational Quality Assurance Program, Paragraph 3.A states, in part, " ANSI N45.2.4 Guidance will be utilized in conjunction with the JCP&L Operational Quality Assurance Plan..."
ANSI N45.2.41971, " Installation, Inspection and Testing Requirments for Instrunentation and Electric Equipent During the Construction of Nuclear Power Generating Stations," paragraph 2.5.1 statas, in part, "Irspection and testing equipnent with acceptable accuracy for performing the required function shall be selected..."
Contrary to the above, surveillance tests are being performed using test gages with less than acceptable accuracy and roariabilit1 in that 0-1500 psi test gages having 5 psi scale increnents were calibratal to accuracies of
+0.5 percent (+7.5 psig) of full scale and were then used in the performance of the following tests:
- 619.3.008, Turbine Ioad Rejection Scram Test (< 40% Ioad), performed February 13, 1981, with test setpoints established at 180 15/0 and 165 10/5 psig.
- 602.3.004, Electrmatic Relief Valve Pressure Sensor Test and ralibration, performed Decenber 1,1980, with test setpoints established at 1059
+0/5 psig, 1084 +0/5 psig, 1076 10/5 psig, 1062 10/5 psig, and 1082
[+0/5psig.
- 609.3.003, Isolation Condenser Autanatic Actuation Sensor Calibration and Test, perfonmd February 5,1981, with test setpoints established at <106810/2 psig and <1066 12 psig.
- 619.3.007, Iow Pressure Main Steam Line Functional Calibration Test While Shutdown, performed July 4,1980, with test setpoint established at 850 15/0.
G w - - - - - - - -
' Mr. 'i'. T. Martin Page 2 June 24, 1981 Violation A: (Continued)
- 619.3.017, Reactor High Pressure Scram Test and ralibration, performed February 10, 1981, with test setpoints established at 1068 10/2 psig and 1066 10/2 psig.
'Ihis is a Severity level V Violation (Supplanent I) .
Response
Admission or denial of the alleged violation:
We concur with the violation.
Corrective steps which have been taken and the result.s whieved:
Previous to this inspection and currently, Instrument Department Technicians perform checks on gages both above and below the expected test pressure set point (approximately +10 psi) prior to performing the surveillance test. 'inis is done against a primary standard with a certified accuracy of 0.05%. It would be reasonable to assume that the test gage has an accuracy approaching the accuracy of the stand 1rd for this narrow band. Test gages checked and used in this manner exceed the manufacturer's full scale accuracy. 'Ihese checks are now recorded on surveillance procedure data sheets.
Our deficiency in this area was a lack of proper arvmwntation that the checks were being performed; therefore, Procedure No. 112, " Oyster Creek Calibration of Maintenan Test and Inspection 'Ibols, Gauges, and Instruments", was revised to incorporate the above actions.
Cbrrective steps which will be taken to avoid further violations:
Our Engineering Department has initiated procuranent of more accurate (0.1%) gages and is pursuing availability of nore accuz.cte reference standards for in-house calibration. Engineering will also perform a procedure review to include, among other things, a determination as to whether or not sane tolerances are too stringent.
'Ihe date when full cmpliance will be achieved:
Full cmpliance was achieved immaiately following the inspection by requiring the checks on existing gages both above and below the expected test pressure set point as 6escribed above in our corrective action. Procurement and procedure generation of the more accurate test gages is scheduled for empletion by the end of our upcaning refueling outage.
Violation B:
Technical Specifications 6.8.1 and 6.8.2, stated, in part, " Written procedures shall be established, implanented and maintained that meet or exceed-the requirements of Section 5.1 and 5.3 of American National Standard N18.7-1972...
Each procedure... shall be reviewed by the Plant Operations Review Otmnittee and approved by the Director Oyster Creek Operation prior to inplementation..."
Mr. T. T. Martin Page 3 June 24, 1981 Violation B: (Continued)
ANSI N18.7-1972, paragraph 5.3.6, states, in part, " Procedures shall be provided for periodic calibration and testing of safety-related plant instrunentation... The procedures shall have provisions for... assuring measurunent accuracies adequate to keep safety parameters within operational and safety limits."
Contrary to the above, calibrations were being performed on safety-related instrunents without using established and approved procedures. %e following are typical exanples of safety-related calibrations perforned without procedures. Other cases were also noted:
- IID4, Standby Liquid Control Systm Invel Transmitter;
-- IIDS, Standby Liquid Control Systems Invel Indicator;
- RD04, Control Rod Drive Water Pressure Indicator;
- RDl8, Control Rod Drive Water Pressure Transmitter; IG07B, Dnergency Condenser IcVel Indicator; EDST, Dnergency Diesel Fuel Storage Tank level Meter; and FP07, Fire Panp Discharge Pressure.
Further, in addition to procedures not being established, mlibrations have not been accmplisned for the following safety-related instrunents:
- Diesel Generator Kilowatt meters used to verify Diesel Generator operability;
- Diesel Generator Kilovar meters used to verify Diesel Generator operability; and
- Fire Ptmp revolutions per minute (RPM) meter used to verify fire ptmp operability.
'Ihis is a Severity IcVel V Violation (Supplement I) .
Resp.onse:
Mmission or denial of the allegal violation:
We control of calibration practices is described in Procedtue #112.1 which does refer to vendors manuals as well as approved procedures, where applicable. However, operational setpoints and tolerances are not cpproved in all cases and we, therefore, concur with the findings.
Mr. k'. T. Martin Page 4-- June 24, 1981 4 Response: (Cbntinued)
. Corrective steps which have been taken and the results achieved:
1 A thorengh revision of Procedure #112.1 is underway to ensure that all safety-related instrunents are <mlibrated to approved setpoints and l
tolerances. 'Ihose itms listed in the finding and others found . ,
- during our review which have not been <wlibrated recently will be done j at the next target of vesertunity and arWel to the routine calibration schedule.
Corrective steps which will be taken to avoid fuh vio.'.ations:
j Our Engineering Department's review of the surveillance prws .
cmbined with the Preventative Maintenance Depart 2nent's review of the calibration program will identify and correct discrapeccies and, thus, preclude further violations.
i
'Ihe date when full emp' Nx:e will be achieved:
i f'
Full ampliance will be achieved by the end of our nprvn%g refueling a
outage.
i
! violation C f 10 CFR 50, Appendix B, Criterion V, states, in parc, " Activities affectirig .
quality shall be prescrihM by h_= anted... procedures ... of a type
- appropriate to the ciretznstances and shall be acomplished in accordance with these procedures..."
Jersey Central Power and Light cmpany Generation' Division Operational
- Quality Assurance Plan, Revision 3,Section III, Operational Quality Assurance Program states, in part, "For activities falling within the scope of Part I
- of the Quality Assurance Systens List,. Jersey C?ntral Power and Light Cortpany shall' utilize the guidance of .. 13. ANSI N18.7-1972, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants . . ." AtEI N18.7-1972, paragraph 6.2, states, "'I4 sting of safety-l related plant parameters, structures,_ systens, and ww. ants shall be L . performed in accordance with approved written test proceiures, which set i forth the requirenents and acceptance liraits."
- j. 10 CFR 50, Appendix B, Criterion XVI, states, in part, " Measures shall be
! established to assure that conditions adverse to quality, such as'...
deficiencies ... are praptly ... corrected. In the case of significant t conditions adverse to quality, the measures shall assure that the cause of
-the condition is determined and corrective action taken to preclude repetition.-
'Ihe identification of the significant condition-adverse v quality, the cause of the condition, and the vuitective action taken siall be h= anted i and taported to appropriate levels -f management."
s 6
7-4
.,-.y,_.,-.,,. , p., ..i,.,.,pw,-ym, w,,,._,,,, ,, 't-'W* * "WW'mv'*--TP"~~-w'*-F-+*-W7*%N F-.
Mr. T. T. Martin Page 5 June 24, 1981 Violation C: (Continued)
Contrary to the above, test procettures have not been prepared, issued, or inplemented for Inservice Testing of numerous valves identified for testing in your Inservice Inspection Program, Section 2, "Punp and Valve Test Program". 'Ihe following are scxna examples of valves listed in the ISI Program, Section 2, whose testing is not documented in an approved procedure:
- a. Core Spray Sycts Valves V20-60, V20-61 and V20-10.
- b. Containment Spray System Valve V21-10.
- c. Closed Cooling Water Valve V5-154.
- d. Fire Protection Systm Valve V9-13. l Many additional valves were also identified during the inspection. !
Further, this is a recurrent itm, in that a similar its of noncmpliance was cited in our letter to you dated May 9,1980 (NIC Inspection 219/80-10) which noted that pump and valve operability tests required by Section XI, i Subsection IWP and IWV, of the ASME Code had not been cmpleted nor had procedures been approved to implment the required tests for cmponents contained in various systms within the scope of Inservice Test Program (IST).
Your letter dated June 3,1980, in response to our letter stated that proccxlures would be written and inpleented by July 31, 1980.
As evidenced by the deficiencies cited above, your corrective actions and managment action to assure proper corrective actions were incc*tplate and inadequate.
'Ihis is a Severity Invel V Violation (Supplment I) .
Response
Mmission or denial of the alleged violation:
We concur with the violation. Following Inspection tb. 219/80-10, the task of procedure generation was subcontracted to an outside organization.
! Our deficiency was not performing an adeqtuto review of their efforts.
Cbrrec'ive steps which have been taken and the results achieved:
Test procedures have been written for the majority of the valves in the Inservice Testing Program. Presently, there exists a lack of proper documentation related to tests that are already being perforu
'Ihree of the six valves listed in the violation have had their respecLve procedures revisai to provide proper documentation.
I
i Mr. T. T. Martin Pi@ 6 June 24, 1981-2 l Response: ((bntinued)
Cbrrective ceps which will be'taken to avoid further violations:
Our subnit'al of May 22, 1981 to Mr. Boyce H. Griet delineated the actions we consider necessary to resolve the concerns related to thc valve testing program.. Specifically, we cannitted to the following:
- 1. Review and revise existing valve _ test procedures and, where needed, generate new testing procedures for valves not yet
- incorporated by S @ mixr 30, 1981.
i 2. Schedule the valve inservice tests in accordanc? with the progran
- by Oc
- r 15, 1981.
- 3. Perform inservice tests for valves required during plant operation by Oc
- r 15, 1981.
- 4. Perform inservice tests for valves required during cold shutdown
- b. in our first cold shutdown after Gub-A=1: 15, 1981.
J 5. Perform inservice tests for 'ralves required during refueling
- outages in our wing refseling cutage.
! 6. Develop a records systca for valve testing and file the necessary 1 th,mmtation for each valve by January 1,1982.
l In addition to the above specific actions, our Engineering Departments will be advised of their responsibility to adequately _ review all .
contracted work for technical accuracy before acceptance and inplementation.
j 4
'Ihe above corrective actions shotild ensure that further violations of this nature will not cccur.
Date when full ocepliance will ba schieved_: .
l Full cmpliance will be achieved upon ampletion of the above described program by January 1, 1982.
I In order to insure that comnitments are followed through to conpletion, the on-site Licensing Department has been tasked through the reorganization of the GPU Nuclear Group to maintain a tracking systan of all NRC cannitments. 'Ihis systen ensures that each responsible department manager is made aware o' ommitments made arxi alerts then to ypmuning ommitted to dates.
, Violation D:
10 CFR 50, Appendix B, Criterion XVIII, states, in part, "... aJdit results shall be doctanented and reviewed by managenent having responsibility in the area audited. Follow-up action .. .. shall be taken where indicated."
~ .. . - ._
4 Mr. T. T. Martin Page 7 June 24, 1981 1
i Violation D: (Continued)
Technical Specification 6.5.2.8 states, "'1he POIC shall maintain written i minutes of each meeting and copies of minutes and detenninatione " hall be
, provided to the Director Oyster Creek Operations; Vice President, JCP&L; Director, Oyster Creek; ISRG Coordinator and the Chairman of the GORB."
i.
l Contrary to the above, minutca of the POIC meetings have not been provided
! to applicable managers in that, as of March 13,' 1951, the last meeting 3
minutes which have been issaed and provided to the Director Oyster Creek Operations; Vice President, JCP&L; Director Oyster Creek; ISIE Coordinator i and the Chairman of the GORB were those of PORC Meeting 104-80 conducted July 1, 1980.
j Additionally, .managenent action to correct this deficient,y was inadequate, in that the alove deficiency was identified by your C apany Audit No. 79-37,.
i dated April 9, 1980 and was further identified for corrective action as an
- unresolved item during NRC Inspection 219/805-16 conducted May 5-9, 1980, j and, as of March 13, 1981, adequate corrective actions have not been taken.
i '1his is a Severity Ievel V Violation (Supplement I) .
1
Response
Admission or denial of the alleged violation:
We concur with the violation as stated.
l .
Corrective steps which have been taken and tre results achieved:
During the year of 1980, the Plant Operations Review Ommittee (PORC)
! conducted 174 meetings. Minutes of all 174 meetings have been approved and issu^t for distribution.
As of June 15, 1981, the POBC has conducted 77 meetings during 1981.
Minutes have been drafted and are in the final approval stages for 66 of the meetings.
l '1he current schedule is to have all meeting minutes up to date by July 15, 1981. After July 15, 1981, PORC minutes will be approved and
!~ submitted for c'istribution within six (6) weeks of the meeting.
) Corrective steps which will be'taken to avoid further violations:
In order to correct the deficiencies which caused the backlog of POBC minutes, an engineer has been assigned to the position of PORC Secretal.y on a full time basis. Previously, the PORC Secretary had concurrent' responsibilities concerning plant oparations.
l
_ . . . - - . - _ _ . - , . - _ . . . - . , . - . . _ - , - _ , _ . . . - , - - , - , _ , . . _ _ . . , , . ~ , , _ _ . . - . . _ . - . - - - , m._,-
Mr. T. T. Martin Page 8 June 24, 1981 Response: (Continued)
In aMition, a secretarial position its been authorized for the PORC Chairman. 'Ihis position will ensure the prmpt typing of meeting minutes and relieve the PORC Secretary of a large portion of his administrative duties. 'Ihis position is scheduled to be filled in the near future.
'Ihe actions described above should ensure that future violations in this area will not occur.
Date when full canpliance will be achieved:
Full cmpliance will be achieved by July 15, 1981.
. Violation E:
10 CFR 50, Appendix B, Criterion XVI, states, in part, " Measures shall be established to assure that conditions adverse to quality, such as ...
deficiencies . . . are prmptly . . . corrected. . ."
Technical Specification 6.8.2 states, in part, "Each procedure and administrative policy ... shall be reviewed ... periodically as specified in the 7dninistrative Procedures."
Idministrative Procedure 107, " Procedure Cbntrol," requires that operating procedures be reviewed annually and doctznented in the PORC neeting minutes.
Contrary to the above, the following operating procedures were not reviewed on an annual basis.
- 202.1, Power Operation;
- 302.2, CRD Manual Control Systan;
- 315.2, Turbine Inbe Oil; and
-- 340.2, 24 VDC Distribution Systen.
Further, action taken to correct this discrepancy was inadequate, in that it was identified to you for wrrective action as an unresolved itan by tac inspectica 219/80-16 conducted May 5-9, 1980 and, as of March 13, 1981, corrective action has not been taken.
'Ihis is a Severity Invel VI Violation (Supplanent I) .
i
Response
Idmission or denial of the alleged violation:
We concur with the violation as ste.ted.
i
. . y I Mr. T." T. Martin Page 9 June 24, 1981
- o I'
Response: (Continued)
! Corrective steps which have been taken and the results achieved: ;
) The listed operating procedures, 202.1, ' 302.2, 315.2, and 340.2, - have ,
! been reviewed and docunented as such in the PORC minutes. t 1
corrective steps which have been taken to avoid further violations: ,
1, i
Procedure 107, " Procedure Control", assigns each department nanager !
j the responsibility to ensure periodic pwc= dure reviews,-specifies the
! frequency of review, and requires the review to be docunented in the
- i. PORC minutes. _In order to unintain centralized, auditable roccirds of
- coupleted reviews, Procedure No.107 will be revised to require a nore
! effective means of hmtation than the presently used system of PORC minutes. ,
All procedure reviews will be hmted as per the revised system by
.!- December 31, 1981.
i 4
Date when full empliance will be achieved:
Full empliance will be achieved by r+:-4r 31,1981.
1 i
t Violation F:
[ .
I Technical Specification 6.8 states, in part, " Written procedures shall be established, implenented and maintained..."
Plant Procedure 112.1, "Calibraticm of Technical Specification Supporting i Installed Instrunentation," parragattus 5.4 and 5.7 state, in part, "5.4 i men the calibration (s) are ocuplete, the "As Found" and "As Isft" data-shall be entered on the appropriate history card." "5.7 The Group I&C&E Supervisor shall review the ... appropriate instrument history cards for
- coupleteness, and for instrtment problems and trends..."
t '(bntrary to the above, calibration data was not recorded on the instrunent -
history cards for the following instrunents:
- IIeOS, . Standby Liquid Control System Discharge Pressure, for mlihration
' performed June 20, 1980; ,
- RD-04, Control Rod Drive Hydraulic Ptap Discharge Pressure, for calibrations performed May 9,1980 and January 9, ~1981; and
- RD-15, Control Rod Drive Hydraulic'Ptup' Flow, for mlibration performed -
1 January 7, 1981.
f Further, as evidenced by the missing m1ibration' data, supervisory review 1
of the 'instrunent history. cards,' which contain the actual miihration data, i .is not being performed.
1 I This is a Severity Ievel VI Violation (Supplement I) .-
1 i
- , _ , _ _: _ , _. _ .. _ ___ _ ...._, _ . _ _. _ _ _ _ _ a _ ._ _ . _ ._.., _ ... , _ ._ ,,.. _ ,_
I i
)
Mr. T. T. Martin Page 10 June 24,, 1931 l Besponse:
Admission or denial of the alleged violations:
We concte with the violation.
Corrective steps which have been taken and the results achieved:
Inmediately following the inspection, the equignent history cards were reviewed and updated to reflect current conditions.
Corrective steps which will be taken to avoid further violations:
The engineering review within the Preventative Maintenance Department, as directed by Procedure No.118, " Preventative Maintenance Administrative Procedure", will identify any discrepancies on equipnent history cards. In wlaition, this review will be defined and scheduled as a preventative maintenance task.
Date when full cmpliance will be achieved:
By our inmvliate review and correction of the equignent history cards, we are currently in full empliance.
Violation G:
Ibchnical Specification 6.8.1 states, in part, " Written procedures shall be established, ' inplemented, and maintained. . . "
Procedure 610.4.002, "Cbre Spray Pm p Operability Test," states, in part,
" . . 6.2.5.1 Verify Fill Pmp trips (on start of Core Spray Pmp NZ01A) .. .
6.2.13.1 Verify Fill Pmp starts (on stopping of pmp NZ01C) ...
6.4.5.1 Verify Fill Pmp trips (on start of Core Spray Pmp NZ01B) ...
6.4.13.1 Verify Fill Pump starts (on stopping of Pmp NZ0lD) ...
7.0 Acceptance Criteria...
I 7.1.2 Fill pmps . . . operate as specified in the instructions .. ."
l Procedure 107, " Procedure Control", paragraph 5.1.3, states, in part, "Should any written procedure prove to be inadequate, corrective action shall be initiated through established channels as described herein. Any written procedures which are determined to be inadequate shall be revised, tenporarily if necessary. .."
i
Mr. T. T. Martin Page 11 June 24, 1981 Violation G: (Cbntinued)
(bntrary to the above procedure, 610.4.002 has been perfonned at least monthly since Novmber 1980 although the procedure was no longer applicable to the actual system status for fill pmp operation, in that the fill pmps for Cbre Spray Systems I and II have been tmporarily wired in such a manner as to allow the fill pmps to run continuously rather than to autmatically start or stop in conjunction with Core Spray Pmp Operation.
Data sheet verficiations for these steps were marked as "Not Applicable".
Further, although the procedure no longer applied to actual syst s status for fill pmp operation, no revision or tmporary change to the procedure had been made.
'Ihis is' a Severity Level VI Violation (Supplment I) .
Response
Mmission or denial of the alleged violation:
We concur with the violation.
(brrective steps which have been taken and the results achieved:
Procedure 610.4.002, "Cbre Spray Pmp Operability Test", has been revised to reflect the actual system status for fill pmp operation.
Corrective steps which will be taken to avoid further violations:
Managenent has increased their efforts to enphasize to all sployees j that procedures deemed to be inadequate nust be revised accordingly prior to inplementation. Our general sployee and enployee refresher training courses will be revised to include and stress the importance of procedure empliance. 'Ihe course will also include the vehicle to effect changes where needed (Procedure No.107, " Procedure Ocntrol") .
Date when full empliance will be achieved:
l Full cmpliance was achieved on May 13, 1981 with the revision of Procedure No. 610.4.002, "Oore Spray Pmp Operability Test".
l i
l l
l l
Mt. T. T. Martin Page 1 June 24, 1981 ATIACHMENT B
%e subject mtter of the violaticns identified in Inspection No. 81-05 is under the cognizance of three departments within our managment organization at Oyster Creek. A discussion of each department (Preventative Maintenance, Plant Engineering, and Plant Operations Review Ocmnittee) with regard to the inpleentation of our manag nent control systms and our revised ammitment identification and control practices are, therefore, presented.
PREVENEATIVE MAINIDWCE We reorganization of the GPU Nuclear Group, which occurred in Septh, 1980, placed strong enphasis on the establisinent of an independent Preventative Maintenance Depart;rnt. We personnel to support this enphasis were also authorized at this time and efforts were made to fill the vacancies.
W e reorganization provides for a full time staff dedicated to preventative maintenance activities. We organizational chart is as shown on Figure 1 to this attachment. The present status of staffing the authorized positions is as follows:
Position Authorized Filled A. Preventative Maintenance Manager 1 1 B. Engineer 3 1 C. Clerk 1 1 D. Group Instrunent and Electrical Supervisor 2 2 E. Group Mechanical Supervisor 1 1 F. Instrtment Technicians 7 6 G. Mechanical Technicians 9 9 H. Electrical Technicians 7 3 I. Coordinator Scheduling 1 0 h e key position of Preventative Maintenance Manager was filled several weeks previous to the subject inspection. %e majority of deficient areas noted.
in the inspection had been previously identified by this individual and were internally scheduled for correction. We feel that the dimx: tion of the Preventative Maintenance Program under the cognizance of a full time manager, will ensure that future violations in this area will be minimized.
l i
Mr. 'h. T. Martin Page 2 June 24, 1981 PM ENGINEERIM3 he violatiens noted in Inspection 81-05 that fall under the cognizance of the Plant Engmeering Department concern the inplanentation of the Inservice Testing Program for valves.
ne responsibility for inplanentation of the Inservice Testing Program was asstyned by the Plant Engineering Department in Septanber 1980, with the reorganization of the GPU Nuclear Group. With the assunption of responsibilities it was believed that all procedures for the inservice testing of pwps and valves had been empleted. Efforts at this time were then directed toward vibration analysis of equignent.
Wis inspection, plus Inspection No. 81-08 hrought to our attention
'l the fact that our existing procedures were inadequate and inconplete. Upon identifying the deficiencies, i -rainte corrective actions were instituted.
We Nuclear Assurance Division of the GPU Nuclear Group was requested to cmpare our existing procedures against applicable code require: 'nts. Wis was accmplished and deficiencies were noted and scheduled for currection.
Our @-d ttal of May 22, 1981 to Mr. Boyce H. Grier delineates that schedule.
Under the GPU Nuclear Group organization, the technical support provided by the Nuclear Assuran Division will be continued. Wis division is charged with the overall develognent and maintenance of the ISI/IST program. As such, all implementing procedures will be reviewed for technical adequacy prior to approval for use.
Our schedule for corrective action concerning the Inservice Testing Program as described in our May 22, 1981 subnittal and the . continued support of the Nuclear Assurance Division will ensure that future violations in the ISI/IST programs will be minimiud. -
PIANT OPERATIONS REVIEW CONI'ITEE We reorganization of the GPU Nuclear Group in September 1980 did not nodify the duties or responsibilities of the Plant Operations Review Ommittee (POE); however, it has affected the administrative activities of that group.
We position of " Safety Review Manager" was created in the reorganization.
his position has, as its primary responsibility, the chairmanship of the PORC. %e Safety Beview Manager no longer has departmental responsibilities and, therefore, can now devote more attention to POE activities.
Previously, the position of POE Secretary had concurrent operational responsibilities in addition to his PORC duties. %e position is now s
occupied by an engineer on a full time basis. %e increased attention _this position is receiving should ensure that adequate consideration is given to the many administrative and technical details concerning POE activities.
Mr. T T. Martin Page 3 June 24, 1981
.In aMition to the full time attention being given by the Safety Review Manager and the PORC Secretary, a secretarial position has been authorized and is expected to be filled in the near future. mis will ensure the timely preparation of PORC minutes for approval and distribution.
In the past, typing activities were subnitted to a secretarial pool, who were at that time understaffed, and had aMitional priorities.
We increased manpower allocated to POBC related activities as supplied by the reorganization of GPU Nuclear should ensure that future administrative violations will be minimi =1 1
CCFMrIMLNr o m ra0L_
he reorganization of the GPU Nuclear Group has tasked tne on-site Licensing Department to maintain an effective tracking systan for all ocmmitments made to the NBC. % e tracking system, which is currently functional, identifies the responsible manager, the specific nature of the ccanitment, the due date, and the action necessary to fulfill the ammitment.
A cmmitment tracking system report is issued pericainally for corporate management review.
! A review of past docmentation and correspondence is presently being accxmplished in order to identify outstanding emmitmmts. Upon identification, these items will be incorporated into the ommitment tracking system. Se target date for empletion of this aspecb is Septerter 15, 1981.
We establishnent of an. effective comnitment tracking system and the periodic review by corporate managen.unt will ensure that comnitments made are adequately addressed.
r,--- , --,,.-a,--,- .,,, ,, -.,.4,- - , - - . - - - - - - - - , - - , . - , , . . - ~ , , , -.-v
. Mr.'T. T.' Martin Page 1 June 24, 1981 FIGURE 1 PREVMIATIVE MAINID&NCE ORGANIZATIGi PREMNIATIVE MAINIENANCE MANAGER (1)
CDORDINMOR CEEE (1) ();
DEINEERS (3)
GROUP MECHANICAL GROUP EWCTRICAL GROUP INSTIMENT SUPERVISOR (1) SUPERVISOR (1) SUPERVISOR (1) i MEWANICAL EECTRICAL INS'LRENENT TEWNICIANS (9) 'IEmNICIANS (7) 'IEmNICIANS (7) l 1