ML20078K786

Forwards Response to Violations Noted in Insp Rept 50-219/94-18.Corrective Actions:Maint Activity Stopped & Isolation Valve That Allows Draining of Containment Spray/ Emergency Svc Water Heat Exchangers Overboard Line Closed

ML20078K786
Person / Time
Site:	Oyster Creek
Issue date:	11/17/1994
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-94-2177, NUDOCS 9411250206
Download: ML20078K786 (3)

Text

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GPU Nuclear Corporation

- Nuclear  :::e " e 88 Forked River. New Jersey 08731-0388 609 971-4000 Wnter's Direct Dial Number:

C321-94-2177 November 17, 1994 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 50-219/94-18 Reply to a Notice of Violation Enclosure 1 to NRC Inspection Repon 50-219/94-18 contained a Notice of Violation.

Attachment I to this letter contains the reply to that Notice of Violation, as required by 10 CFR 2.201.

I We agree there was a lack of control of the maintenance activity as a result of not complying l with our equipment control procedures. In addition, a more timely implementation of the '

turnover process would have brought the need for operating instructions in question.

The GPUN critique of this event did not indicate that the project controls used during this modification wem a contributing factor to this event. It is noted, however, that a revised project management process is in the final stages of implementation which will provide  ;

greater continuity through the project life cycle.

If you should have any questions or require funher information, please contact Mr. Terry Sensue, Oyster Creek Licensing Engineer at 609-971-4680. >

Sincj e 'our i

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Y JUhn J. a1on ice Pre - ent and Director j Oyster Creek JJB/TS/je ec: Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Engineer I

9411250206 941117 /)

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I PDR ADOCK 05000219 2* 30 0 u t, O PDR 1 GPU Nuclear CorporaDon is a sut;s!c.ay of Genera: Puboc UN&es Corpo ahon 1 i

Page 1 of 2

' C321-94-2177 Attachment I Violation:

10 CFR Pan 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

requires that activities affecting quality must be prescribed by documented instmetions, procedures, or dmwings, of a type appropriate to the circumstances and activities must be accomplished in accordance with these instmetions, procedures, or drawings.

Contrany to the above, on August 9,1994, documented instmctions, procedures, or drawings did not adequately prescribe Containment Spray / Emergency Service Water System I maintenance. As a result, secondary containment integrity was unknowingly compromised.

GPUN Reply:

GPUN concurs with the violation as written.

Reason for the Violation The cause of the violation was a failure to follow established procedures for the control of plant equipment config imtion as a result of a misundarstanding by personnel of the need for documented instmetions for the draining evolution.

A contributing cause to the violation is that Mechanical Maintenance permnnel are unfamiliar with the implementation and turn-over of configuration changes. This unfamiliarity with the plant configuration change control process allowed a missed opportunity to identify the need for adequate operating instructions to tw provided for the modification.

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Corrective Actions Taken and the Results Achieved The maintenance activity was stopped. The isolation valve that allows dmining of the containment spray / emergency service water heat exchangers contents to the overboard discharge line was closed. This re-established secondary containment integrity. Also, the hoses associated with the modification were disconnected.

A switching and tagging order was implemented to tag closed both System I and System 2 overboard discharge line drain isolation valves. This prevents the use of the modification without proper operating instmetions.

1 C32f-94-2177

'Page 2 of 2 )

Attachment I ,

Corrective Actions Taken and the Results Achieved - (Continued)

The Plant Configuration Change Control process was implemented for the modification performed to both systems. The process identified the lack of operating instructions for the modification as a discrepancy. Station operating procedure 310, Containment Spray System Operation, is being revised to include specific directions for using the modification.

_ Corrective Steps Taken to Avoid Further Violations Maintenance personnel will be given additional training on following established procedures for the control of plant equipment. This training will emphasize that installed plant equipment is not to be operated by Maintenance personnel without appropriate approved operating instnictions. Also, Maintenance supervision will be given training on the Plant Configuration Change Control process. This training will increase personnel familiarity with the pmcess and reinforce using a questioning attitude while perfonning maintenance activities.

The Control Room operating crew will be provided the critique of this event in Le required reading program. This required reading will emphasize the importance of the turnover process and the need to have appropriate instructions to cerixl these types of activities.

Ilate When Full Compliancepas Achieved Full compliance was achieved on August 10, 1994 when the maintenance activity was stopped and secondary containment integrity was established.

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