IR 05000155/1977001

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IE Insp Rept 50-155/77-01 on 770111-14.Noncompliance Noted: Liquid Poison Sys Bimonthly Circuit Test Not Performed to Assure Proper Operation
ML20002E486
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 02/04/1977
From: Fiorelli G, Hunter D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20002E484 List:
References
50-155-77-01, 50-155-77-1, NUDOCS 8101280146
Download: ML20002E486 (13)


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UNITED STATES NUCLEAR REGULATORY CO211SSION l

0FFICE OF INSPECTION C D ENFORCEMENT

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REGION III

Repo-t of Operations Inspection IE Inspection Report No. 050-155/77-01

. Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49210

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Big Rock Point Nuclear Plant License No. DPR-6 Charlevoix, Michigan Category:

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Type of Licensee:

BWR GE 240 MWt Type of Inspection:

Routine, Unannounced Dates of Inspection:

January 11-14, 1977

$20 $bl4shvfyv I

l D. R. Hunter M/3/77 Principal Inspector:

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Accompanying Inspectors: None

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other Accompanying Personnel: None

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Reviewed By:/. Fiorelli, Chief Reactor Operations and

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Nuc1 car Support Branch

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SUMMARY OF FINDINGS

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Inspection Summary

Inspection on January 11-14, 1977, (77-01): Review of operations, reportabic occurrences, plant cleanliness, procedures, outstanding inspection items, and corrective action associated with an item of noncompliance. One item of noncompliance was identified concern-ing failure to perform surveillance testing in accordance with Technical Specifications.

Enforcement Items Infraction Contrary to Technical Specification 5.2.3, the liquid poison system bi-

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monthly circuit test was not performed to assure proper operation.

(Paragraph 3.a, Report Details)

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Licens?e Action on Previously Identiff,1 Enforcement Items A review of the licensee's corrective actions associated with plant modification controls and plant training activities indicates that the activities are not complete.

(Paragraph 4, Report Details)

Other Significant Items A.

Systems and Components i

None.

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B.

Facility Items (Plans and Procedures)

The licensee has submitted a schedule to NRR for the complete implementation of the Quality Assurance Program Manual (CPC-1A).

The licensee's plans for a short maintenance outage during the

week of February 12, 1977, and will include testing of the reac-tor depressurization valves at the cold shutdown condition.

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C.

-Managerialkeers

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t Unresolved Item: Certain licensee retraining records were not adequate to verify accurate status'of the operator licensed retraining program.

(Paragraph 5.a. Report Details)

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Deviations i

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None.

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Status of Previously Reported Unresolved Items

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The item concerning the visual inspection of containment elec-

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l trical~ penetrations potting caterial continues under review by the licensee.

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Management Interview

- The management interview was conducted on January 14, 1977, by Mr. Hunter with the following persons present:

C. J. Hartman, Plant Superintetident C. R. Abel, Operations Superintendent D. E. DeMoor, Technical Engineer

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T. W. Elward, Technical Superintendent

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G. B. Szczotka, Quality Assurance Superintendent R. W. Doan, Training Supervisor K. M. Brun, Secretary A.

The inspector stated that a review of operations and selected deviation reports revealed no discrepancies.

The licensee acknowledged the inspector's statement.

(Paragraph 2, Repert Details)

B.

The inspector stated that a review of the reportable occurrence I

concerning the failure to test the liquid poison circuit for operability constituted an-item of noncompliance and the correc-tive actions taken by the licensee appeared adequate. No respor.se to this item is required.

The licensee acknowledged the inspector's statement.

(Para-Braph 3.a, Report Details)

C.

The inspector stated that a review of the reportable occurrence concerning the failure of the emergency diesel generator to start within the required times indicated a continuing problem with the diesel engine and the licensee must continue to pursue the starting problems; and also insure the emergincy diesel generator operability as required by the facility lic,dnse.

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t The licensee acknowledged the inspectors statement and stated

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that the wecent testing of the emergency diesel following

governor replacement and a minor modification to the govenor

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lube oil system appears to have improved the starting times of the diesci engine.

(Paragraph 3.b, Report Details)~

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D.

The inspector stated that the review of the licensee evaluation concerning the reactor depressurization battery cell lou speci~

fic' gravities revealed no apperent discrepancies.

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The licensee acknowledged the inspector's statement and' stated that additional information was forthcoming from the vendor

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concerning battery capacity.

(Paragraph 3.c, Report Details)

E.

The inspector stated that a review of the reportable event con-

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cerning the reactor depressurization system testing which violated the single failure criteria as applied to initiation

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.of the system during testing revealed no discrepancies. The

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procedure changes implemented by the licensee have eliminated the possibility of total system initiation during testing and apparently satisfies the design criteria.

(Paragraph 3.d, Report Details)

F.

The inspector stated that a review of the corrective action for the reportable occurrence concerning the failure to adequately test the reactor depressurization system appeared to be adequate.

The licensee acknowledged the inspector's statement.

(Para-

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graph 3.e, Report Details)

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G.

The inspectcr stated that the review of the corrective actions associated with the c'ompletion of accelerated tcaining for four licensed operators, following inadequate grades en topical requalification examinations, appeared adequate and no further questions were required of this matter at this time. The implementation of the plant maintenance training program had not been completed, but it was included in the implementation schedule for the Consumers Quality Assurance Program and would

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be reviewed at a subsequent inspection.

The licensee acknowledged the inspector's statement.

(Para-graph 4, Report Details)

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, The inspector stated that the review of thd records maintained by the training department concerning the continuing training

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program (1 day /5 we:ks) 1 secure caries ravasicd cpptrcnt inadequacies concerning the attendance of certain licensed personnel and the review of procedure changes and facility

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changes by certain licensed personnel. The inspector stated

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that this item would be continued as unresolved pending review, (

evaluation, and assembling of the appropriate records by the

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licensee.

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The licensee acknowledged the inspector's statements.

(Para-graph 5.a. Report Details)

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REPORT DETAILS

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Persons Contacted C. J. Hartman, Plant Superintendent D

E. DeMoor, Technical Engineer C. R. Abel, Operations Superintendent

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T. W. Elward, Technical Superintendent J. P. Flynn, Maintenance Superintendent G. B. Szczotka, Quality Assurance Superintendent C. E. Axtell, Health Physicist R. E. Schrader, Senior Technologist A. C. Sevener, Operations Supervisor R. W. Doan, Training Supervisor T. M. Brun, Chemical and Radiation Protection Supervisor

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J. J. Popa, Maintenance Engineer E. M. Evans, Plant Engineer T. K. Pence, Shift Supervisor E. F. Peltier, Shift Supervisor E. McNamara, Shift Supervisor C. F. Sonnenberg, Shift Supervisor D. D. Herboldsheimer, Maintenance Scheduling Coordinator 2.

Review of Operations The inspector reviewed selected records and activities, observed certain operations activities, and interview 2d selected personnel to assure facility operations to be within the Technical Speci-(

fications and Administrative controls. The review included:

a.

Shift Supervisor Log, November 17, 1976, through January 11, 1977.

b.

Control Room Log, December 8, 1976, through January 1, 1977.

c.

Control Room and Auxiliary Log Sheets for December 1976.

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d.

Master Check List, performed on August 8-11, 1976, and System Checklists performed during 1976 plant startup.

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Plant Operating Memos and Administrative Memos.

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Daily Order Book, November 1976 throug'h January 7, 1977.

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Plant Chemistry.

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Control Room Materials.

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(1) Operating Procedures (2) Technical Specifications

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(3) Site Emergency Plan

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(4) Operations Memos and Administrative Memos

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(5) Technical Data Book I

(6) Outstanding Switching Orders

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System Status Board.

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Electrical System.

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(1) System Status (2) SOP 28, Station Power (3) ALP 1.5, Turbine and Generator System Annunciator Tabulation (4) ALP 1.12. Emergency Diesel Generator Annunciator Tabulation

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(5) ALP 1.15, Reactor Depressurization System Annunciator Tabulation

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(6) ONP 2.14, Loss of Emergency Diesel Generator (7) ONP 2.18, Loss of Transmission System

(8) ONP 2.36, Loss of Station Power (9) EMP 3.1, Loss of DC Power System (10) Battery Preventive Maintenance Checks (11) T7-01, Emergency Diesel Generator Auto Test (12) T30-05, Control Rod Position M.G. Set (13) T30-19, Emergency DG Test Run - Loaded (Performed with T7-01)

(14) T30-20, Battery Voltage and Specific Gravity Data (Performed with the preventive maintenance program)

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Operations Surveillance Master Status Board.

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Selected Plant Deviation Reports.

No discrepancies were noted.

3.

Reportable Occurrences

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The inspector reviewed the following reportable occurrences to assure adequate licensee review, evaluation, corrective actions, and reporting.

LERRO37-76,Failuretoperformthebf'monthlyligyid a.

poison system circuit test. The licer. hee reported-that the bi-monthly test of the liquid poison system circuit during Jure, August, and October of 1976 was not performed.

The inspector reviewed the event with the licensee representa-tives and verified the completion of the test on November 30, 1975.

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1/ Ltr, CP to IE:III, dtd 12/30/76.

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i The surveillance test has been rescheduled on a 60-day basis by operations.

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The licensee has completed a review of surveillance procedures g

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to assure no others had been erroneously scheduled. No apparent discrepancies were noted by the licensee.

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The failure to check the liquid poison system circuit bi-monthly in accordance with Technical Specification 5.2.3 is an item of noncompliance. The licensee corrective actions appear ade-quate and no further questions are required of this matter at this time, b.

LER R0 38-76, Failure of the Emergency Diesel Generator to start within the specified time.

The licensee reported that the emergency diesel generator

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failed to start within the specified time during routine testing on December 2, 1976. The inspector reviewed the event with the licensee representativea. The failure to meet the starting time requirements is a repetitive occur-rence.

The licensee has replaced the diesel generator governor valve on December 19, 1976, after review and evaluation of the

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sluggish operation of the diesel engine with the vendor representative.

Following subsequent failures in December and January, the lube oil supply line to the governor was modified to provide

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a lube oil supply to the governor valve from the oil header via a ball check valve to prevent draining of the governor oil supply during extended shutdown periods. The licensee indicates tLat the oil drainage may be causing the governor valve opening during diesel starting to be sluggish. Also the governor valve is normally closed during diesel shutdown conditions and the licensee indicated that a modification to pre-position the governor partially open is being evaluated to further decrease the starting times on the diesel engine.

The inspector observed the performance of the emergency diesel generator weekly surveillance test (T7-01) on January 11, 1977, and noted with the licensee representa-tive smooth governor operation during/ starting and a start time of 10.5 seconds. Previous testing on January 7, 8, 10, and subsequent testing performed during tha inspection indicated satisfactory diesel start times.

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Tha lic:ncan 10 continuing to parform additional testing

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of the emergency diesel to provide assurance of starting

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and is continuing to evaluate the diesel and diesel gover-nor valve.

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No further questions are required of this item at this time.

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LER RO 39-76, Reactor Depressurization System "B" Battery Pilot Cell Specific Gravity of 1.198. -

The licensee reported 3/ that the specific gravity of pilot

cell 29 in the reactor depressurization system "B" battery was found as 1.198 during routine battery testing. The pilot cell subsequently indicated a specific gravity of 1.203 and all extra cells indicated specific gravity was above 1.200.

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The low specific gravity readings on individual random cells

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in the reactor depressurization system batteries is a

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repetitive problem.

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l The licensee is continuing an investigative program with the vendor to determine the final corrective actions required.

The review of the operations safety analysis performed by the licensee to assure adequate battery capacity to meet the

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system design requirements revealed no apparent discrepancies.

The reactor depressurization batteries (Type 3CA-3) are oversized substantially (5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> rating of 8 amperes and I hour rating of 26 amps.).

The system requirements are approxi-mately 8 amps for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The licensee prestartup testing

of the reactor depressurization system batteries on May 20,

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1976, revealed an acceptable performance even though certain cells were below a specific gravity of 1.200.

Two cells in the "D" batt yjwere subsequently replaced due to low speci-fic gravity The licensee is continuing to evaluate the problem and is obtaining additional battery capacity curves from the vendor which are based on cell specific gravity.

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No further questions are required of this matter at this time.

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LER R0 41-76, Monthly on-line test method for the reactor

depressurization system subjected the, system to violation of the single failure design criteria for inadvertant operation.

3/ Ibid.

[/ IE Inspection Report No. 050-155/76-12.

5/ 1E Inspection Report No. 050-155/76-13.

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S! that during the etcff rsvisw of a The licensee reported mie.or test malfunction, which had occurred on October 27,

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1936, it was realized that the routine monthly testing per-formed on the reactor depressarization system was subjecting (

the system to a violation of the single failure design

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criteria for inadvertant system initiation.

The inspector reviewed the newly written and approved test-ing procedures with the licensee representative.

It was noted that at no time was the system initiation prevented by testing; therefore, the system would have functioned prop-erly upon initiation of a depressurization signal automatically or by manual initiation by operations.

The review of the system design basis ! ndicated that

i the system should meet the single failure criterion in both directions, i.e., a single failure shall not prevent blow-

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down wher the need does not exist.

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The modifications of the methodology of testing removed the possibility of a single failure initiating the system partis 1 or full blowdow.) by not inputting a single sensor cabinet trip signal output into all of the actuation cabinets simul-taneously.

The licensee evaluation of the reactor depressurization system testing is continuing. The evaluation includes the feasibility of complete manual testing of tha system logic and the required testing during outages to provide additional assurance that the initiation logic is operable. This area will be

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contined as an open item and reviewed during a subsequent

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inspection.

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LER RO 42-76, Monthly on-line tests of the reactor depres-surization system logic was not adequate to cover the technical specifications requirements.

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The licensee reported that during the plant staff review of a minor test malfunction which had occurred on October 27,

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1976, it was realized that the monthly testing performed on the reactor depressurization system logic was not adequate to cover the Technical Specification requirements.

Specifi-cation 11/4.1.5 D requires that the system logic shall be i

6/ Ltr, CP to IE:III, dtd 12/22/76.

  • 7/ Ltr, CP to DL, dtd 8/15/74.

8/ Ltr, CP to IE:III, dtd 9/22/76.

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functionally tested as indicated in Table 4.5.2.h., which

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requires monthly output channel logic tests.

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The inspector reviewed the occurrence with the licent.ee i

representatives. The licensee is taking credit for the auto

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l test clock feature of the sensor and actuation cabinets to assure system operability.

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The review of the revised test procedures (T30-28 through 31)

revealed no apparent discrepancies. The auto test clock is tested weekly and each sensor and actuation cabinet tested monthly. The actuation cabinet logic (2 of 4) is verified by the auto test clock feature and the sensor cabinet input channel and cabinet logic is verified by manual testing.

The licensee evaluation of the system testing is continuing and includes the feasibility of providing complete manual testing of the system to provide increased assurance that

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l the initiation logic is operable.

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Licensee corrective acticns appear adequate regarding this

occurrence.

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Item of Noncompliance

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The inspector reviewed the completed corrective actions a.

associatedy{gptheacceleratedtrainingforfourlicensed personnel.9 -

Each of the individuals had completed 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of specialized training on August 18-26, 1976, and obtained a satisfactory grade on the reexamination fol-j lowing the completion of the retraining activity.

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No discrepancies were noted and this item is considered closed.

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Theinspect77;f2773fev f the status of the maintenance train-ing progran-- -- -- revealed that the licensee is continuing to prepare the training program c,oncurrently with the overall

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9/ IE Inspection Report No. 050-155/76-16.

10/ Ltr, CP to IE:III, dtd 9/14/76.

]][/ IE Inspection Report No. 050-155/76-16.

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j 12/ Ltr, CP to IE:III, dtd 9/14/76.

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13/ IE Inspection Report No. 050 155/76-21.

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plant training program. The schedule for the completion of

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theprogramwasindicatedintheQualityAssyggnceProgram

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implementation commitnent made by Consumers.---

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This item will remain open pending the scheduled completion of the overall plant training pregram:

(1) Training matrix completed by 'tarch 1, 1976; (2) training of personnel by June 1,1977; and (3) required qualification and certifica-tion of personnel completed by January 1, 1978.

c.

The corrective actions associated with the design control program is continuing. The completion of the Quality Assurance procedurei5pnd associated administrative proce-dures are scheduled-- for June 1, 1977, with complete implementation by August 1, 1977.

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Theperformanceoffacilitychangesiseggt{9yinginaccord-ance with previous licensee commitments

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This item will remain open pending review of the completed design control program procedures.

5.

Outstanding Inspection Items The inspector reviewed selected outstanding items to verify com-pletion and status, a.

The recently completed operator requalification program for 1976, including the annual examinations given at the end of (

1976, was reviewed with the licensee representative.

The record' review revealed that the licensee retraining program for review of procedure changes, review of facility changes, and the attendance to the formal, continuing classroom ses-sions conducted 1 withatleastsix8pmannertoprovideeachlicensedoperator 7-formal sessions each year were not adequate to verify attendance to these sessions by ell licensed per-sonnel. The licensee representative indicated that the

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records would be reviewed and provided to establish the accurate status of the retraining program. This item will be carried as unresolved pending review of the retraining records at a subscquent inspection.

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The review of the completed annual exa61 nations for 1976, indicated adequate knowledge level of the licensed personnel 14/ Ltr, CP to NRR, dtd 12/14/75.

15/ Ibid.

}j/ IE Inspection Report No. 050-155/75-15.

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17/ Ltr, CP to IE:III, dtd 12/19/75.

18/ Ltr, OLB to CP, dtd 9/27/76.

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and the training supervisor was in the process of evaluating

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the examinations, establishing the indicated weak areas, and developing the 1977 formal training classroom program for (

licensed personnel.

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Theinspectorreviewedthygygg}acementoftheemergency diesel generator governor--- --- on December 19, 1976, with the licensee repr'esentative.

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No discrepancies were noted and no further questions are required of this item at this time, l

mentation schedule ypd the Quality Assurance Program imp e-The inspector revig-with the licensee representative. The c.

inspector noted that with exception of certain aspects of document control (Policy 6), identification and control of

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materials (Policy 8) and quality assurance records (Policy 17) the quality assurance program should be completely implemented during 1977. The specific implementation of the program will be reviewed during subsequent inspections.

d.

The inspector reviewed the completed plant quality assurance audit concerning overall plant training completed on November 8, 1976. The audit included sixteen audit find-ings resulting in the issuing of seven deviation reports.

The licensee is ir. the process of correcting the inade-quacies identified. The inadequate areas and the corrective actions will be reviewed during a subsequent inspection.

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I e.

The issuance and audit of the newly revised (updated) Q-list was completed the week of January 12, 1977. The use of the revised Administrative Procedure 1.10 appears adequate to provide control of the safety related Q-list by the licensee.

Thedocumentcontrolprogramprocedures3fepresentlybeing completed by the licensee and scheduled 2-to be completed by February 1, 1977.

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No further questions are required of this matter at this time.

19/ IE Inspection Report No. 050-155/76-21.

20/ LER R0 050,155/R0 38-76.

21/ Ltr, CP to NRR, dtd 12/14/76.

jj[/ IE Inspection Report No. 050-155/76-18.

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23/ Ltr, CP to NRR, dtd 12/14/76.

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