ML20083R873

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Responds to NRC Re Violations Noted in IE Insp Rept 50-219/83-26.Corrective Actions:Fire Pump 1-1 Returned to Operable Status After Successful Functional Test.All Surveillance Procedures Reviewed to Ensure Tech Specs Met
ML20083R873
Person / Time
Site: Oyster Creek
Issue date: 03/28/1984
From: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
To: Starostecki R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20083R842 List:
References
NUDOCS 8404240341
Download: ML20083R873 (3)


Text

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GPU Nuclear Corporation 1-Nuclear 388 Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Nurnber:

March 28, 1984 Mr. Richard W. Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Starostecki:

Suoject: Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 83-26 This letter is submitted in response to your letter of February 27, 1984, regarding the Notice of Violation (NOV) contained in Appendix A.

In accordance with 10 CFR 2.201, the attachment to this letter represents our reply to the NOV. If there are any questions regarding the information therein, please contact me or the Oyster Creek Licensing Manager at (609) 971-4643.

Very truly yours, A

ete dfer ~' )

Vice President and Director Oyster Creek PBF:RPJ: dam Attachment cc: Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, FU 08731 8404240341 840418 I

PDR ADOCK 05000219 G

PM GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

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O A'ITACHMENT Violation:

As a result of the inspection conducted on Novemoer 7 - December 31, 1983, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C) the following violation was identified:

Tecnnical Specification 6.8.1 requires that written procedures be establisned, implemented, and maintained that meet or exceed tne requirements of-Appendix A of Regulatory Guide 1.33-1972, Appendix A of Regulatory Guide 1.33-1972 specifies tnat specific procedures for eacn surveillance test listed in the Tecnnical Specifications be written.

Contrary to the above, Surveillance Procedure 645.6.012, Fire Pump 3

Functional Test, failed to incorporate a Technical Specification change relating to fire pump acceptance criteria. As a result, testing performed on Septemoer 14, 1982 failed to ioentify tne development of an inadequate pump head pressure.

Reply:

We concur with the violation as stated.

The discrepancy was first identified by GPU Nuclear on November 3, 1983 and reported to the NRC via Special Report 83-01P on Novemoer 4, 1983. A follow-up report, Special Report 83-OlT, was suomitted on November 18, 1983.

The Apparent Cause of Occurrence section of Special Report 83-OlT states:

"... the acceptance criteria in surveillance procedure 645.6.012, ' Fire Pump 4 -

Functional Test' was not properly revised to reflect the Tecnnical Specification surveillance requirements which were issued via Amendment 58 on December 21, 1981." The Corrective Action section of the same Special Report states:

"Tne acceptance criteria in procedure 645.6.012 has been revised to incorporate the requirements in Section 4.12.B of the Oyster Creek Technical Specifications." This was done with a Temporary Change and the permanent change was approved on December 23, 1983. The fire pump in question, pump 1-1, was returned to operable status on November 24, 1983 after a successful functional test. Another corrective action that was undertaken because of Special Report 83-01T was a complete review of all Surveillance procedures to i

ensure that the procedures reflect Technical Specification requirements.- This item was the only item not incorporated into facility procedures from Technical Specifications Amendment 58.

GPU Nuclear now incorporates changes.to the Technical Specifications into facility procedures by a more formalized process than used in December 1981.

Technical Functions procedure LP-006 now controls the distribution of

-Technical Specification changes through the Licensing Aetion Item. system.~' By-this system, Licensing generates an Action Item (AI) to Plant Engineering to.

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- see that all procedures affected by the Amendment are reviewed and changed as necessary. Within Plant Engineering there is a Plant Task Action tracking system by which the AI from Licensing.is assigned to an engineer and tracked until completion. After completion, the engineer's task is reviewed by his supervisor and if deemed to be complete, the AI is returned to Licensing to be closed out, i

Because this violation deals with wnat is considered an isolated incident and tne metnods now used by GPU Nuclear to control Technical Specification changes were instituted after Decemoer 1981, GPUN feels tnat the necessary corrective actions have been taken tnat will avoid further violations. The i

date of full compliance can be given as December 23, 1983, when the procedure in question, 645.6.012, was approved as revised.

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