IR 05000155/1978006

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IE Insp Rept 50-155/78-06 on 780522-26.Noncompliance Noted: Reactor Depressurization Sys Placed in Degraded Condition When Fire Pump Control Switches Were in Inhibit Position During Maint Activities
ML20002E472
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 07/19/1978
From: Hunter D, Jorgensen B, Warnick R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20002E473 List:
References
50-155-78-06, 50-155-78-6, NUDOCS 8101280115
Download: ML20002E472 (14)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

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REGION III

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Report No.

50-155/78-06 Docket No.

50-155 License No.

DPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue

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Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant Inspection At: Big Rock Point Site, Charlevoix, MI Inspection Conducted:

$2-26, 1978

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l lawycetors:

D. R. Hunter

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a-m ved By:

R. F. Warnick, Chief 7-/ f-7A Reactor Projects Section 2 Inspection Summary Inspection on May 22-26, 1978 (Report No.

50-155/78-06)

Areas Inspected: Routine, unannounced inspection of operations, reportable events, modifications, procedu_es, maintenance, review and audit, headquarters requested item, IE Bulletin and Circulars, item of noncompliance, and outstanding inspection items. The inspec-tion involved 54 inspection-hours onsite by two NRC inspectors.

Recults: Of the ten areas inspected, no items of noncompliance or deviations were identified in nine areas; one item of noncompliance (infraction - operation with a safety-related system in the degraded condition - Paragraph 4.c) was identified in one area.

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DETAILS

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1.

Persons Contacted

  • C. J. Hartman, Plant Superintendent
  • D. E. DeMoor, Technical Engineer
  • J. Rang, Maintenance Superintendent
  • T. C. Bordine, QA Superintendent R. E. Schrader. Technical Superintendent
  • D. P. Blanchard, Reactor Engineer
  • A. C. Sevener, Operations Supervisor

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  • G. D. Gilbody, QA Engineer

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R. M. Brzezinski I&E Engineer J. J. Popa, Maintenance Engineer H. E. Black, Maintenance Supervisor C. F. Sonenberg, Shift Supervisor W. F.-Blissett, Shift Supervisor

  • K. M. Brun, Technical Clerk The inspector contacted other plant personnel including members of the operations, technical, and administrative staf f.
  • Denotes those attending the management exit on May 26, 1978.

f 2.

License Action on Previously Identified Items (Closed) IE Inspection Report No. 50-155/77-08, Deficiency:

a.

The licensee has taken corrective actions and has subsequently rewritten the procedure for the shutdown margin check (TR-43).

b.

(Closed) IE Inspection Report No. 50-155/75-05, Unresolved:

the licensee has completed the fabrication of test flanges for the containment ventilation supply and exhaust lines and tested the ventilation valves and flanges in the direc-tion of the LOCA at PA(27 Psig).

3.

Plant Operations The inspector observed plant operating conditions and controls, a.

control room manning, and equipment tagout status in the plant In addition, selected operating records and procedures tour.

were reviewed as follows:

(1) Shift Supervisor Log (May 1978)

(2)

Control Room Log (April and May 1978)

(3) Control Room Sheets (April and May 1978)

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(4) Reactor Log (April 1978)

(5) Daily Order Book (through May 18, 1978)

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(6) Switching Orders in Effect (7) Lockout and Jumper Controls

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(8) Deviation Reports (9) Event Reports Compliance with technical specification and plant Administrative Procedures, including management review, was verified where applicable.

No items of noncompliance or deviations were identified.

4.

Reportable Events The inspector reviewed the licensee actions concerning the following nonroutine event reports to verify the licensee evaluation, review, and corrective actions were performed, and that the plant limits were not exceeded. The review included personnel interviews, plant records, and PRC minutes.

LER 78-06, 78-09, 78-13, and 78-14 - Reactor Depressurization a.

System Channels Removed From Service for Maintenance.

b.

LER 78-07, Emergency Diesel Generator Trip on High Water Temperature. The failure of the cooling water system was

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a result of a leaking packing which caused the pump to become airbound. The corrective action included the instal-lation of a mechanical seal to upgrade the pump. Subsequent operation of the diesel has revealed no additional problems.

The licensee is continuing to observe the diesel generator testing activities closely to identify and evaluate any further problems encountered during routine testing.

LER 78-08, Reactor Depressurization System Placed in a c.

The Degraded Condition During Maintenance Activities.

licensee reviewed the event with the plant operations personnel, reviewed the key controls, and placed a caution tag on the control panel to remind the operations personnel of the operability requirements for the " INHIBIT" switchas for the fire pumps. The licensee has an established requirement for the removal and return to service of safety-related equipment. Plant power operation with the reactor

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depressurization system in the degraded condition is an item of noncompliance pursuant to Technical Specification 11/3.1.5.A and is an infraction. The licensee corrective (

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actions appear acceptable and no further questions are required of this matter at this time (This item was discussed at the management exit).

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a d.

LER 78-10, Steam Drum Level Switches Inadequate Environmen-tal Qualification. The licensee replaced the yarway plastic parts, cover, diffuser, and dial with qualified components.

LER 78-11 and 12,~ Unqualified Pilot Solenoid Valves.1 The e.

licensee modified the two unqualified solenoid valves using qualified high temperature components.

f.

LER 78-15, Potentially Unqualified Submerged Electrical Circuitry.

LER 78-16 Daily Primary System Unidentified Leakage in g.

Excess of Allowable.

h.

LER 78-17, Scram Pilot Valve Control Switch Placed in the Reset Position.

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LER 78-18, Steam Drum Level Switches Failed to Operate.

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LER 78-19, Condenser Vacuum Switch Set Point Drift.

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LER 78-20, Off-gas System Inoperable.

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LER78-21,DegradgpOff-sitePowerSourceDuringReactor 1.

Power Operations.-

one Off-site Power Source During Reactor m.

LER 78-22, Loss j

Power Operations No other items of noncompliance or deviations were identified.

5.

Design, Design Changes, and Modifications The inspector reviewed the following modifications to assure that the changes were performed in accordance with the requirements:

FC-223, Fuel Pit Surge Tank Leval Indication.

a.

b.

FC-242, Reactor Protection System key lock switch.

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IE Inspection Report No. 50-155/78-02.

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Ltr, CP to NRR, dtd 5/11/78.

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A FC-266, Emergency Lighting Transformer supply breaker tripped c.

annunciator.

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FC-355, Emergency Condenser sample line check valve.

FC-384, Containment Vent Valves nitrogen bottle isolation c.

valves.

f.

FC-405, Reactor Depressurization Valves test piping.

FC-420, Emergency Diesel Generator Trouble Annunciator.

g.

h.

FC-421, Cont ment Ventilation Supply and Exhaust Line Test Flanges No items of noncompliance or deviations were identified.

6.

Maintenance The inspector reviewed the following activities to assure thac the maintenance items were performed in accordance with the requirements, 76 RWS 28211, Installation of air chamber and level s.

instruments on the fuel pool surge tank.

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b.

76 SPS 24702, Installation of emergency lighting annunci-ation alarm.

77 CLS 08915, Installation of nitrogen bottles fittings c.

and accessories.

d.

77 RDS 01012, Installation of threadolets on discharge piping.

77 EPS 00603, Installation of an oil line on the Emergency e.

Diesel Generator governor valve.

f.

77 PIS 17902, Installation of new relief valves on the core spray lines.

77 PCS 08102, Calibration of the pressure indications on g.

the reactor recirculation pump seals.

h.

77 RDS 30102, Repair of trip lights on the AC 1, L2 module.

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IE Inspection Report No. 50-155/75-05.

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77 RPS 03802, Installation of the ECCS on line test fittings.

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77 RSD 11208,. Remove and replace the No. 2 safety valve with

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the spare.

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No items of noncompliance or deviations were identified.

7.

Review and Audit The inspector reviewed the Plant Review Committee minutes to ascertain that the review activities were performed in accordance with the requirements:

On-site PRC meetings were conducted at the required frequency a.

and consisted of a quorum.

Proposed tests and experiments were reviewed as required.

b.

(1) SST-01, Instorage Test of 24" butterfly valve seat.

(2) SST-02, Reactor Depressurization Valves Test (TV-12)

(3)

SST-07, Emergency Condenser Sample Line Leak Test (4) SST-08, Supply Vent Valve Leak Rate Test.

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(5) SST-09, Special Installation Vei.ve Test.

(6) SST-10, Feedwater Check Valve Leak Test (7) SST-11, Reactor Depressurization System Channel D Leak Rate Test.

(8) SST-12, CRD C1 and E3 Scram

.(9) SST-14, Irradiated Fuel Examination, Proposed Changes to Technical Specification, c.

d.

Violations of the Technical Specifications.

Certain deviation reports (corrective action system) concerning the violation of the specifications were not apparently reviewed by the plant review committee as required by the Technical Specifications 6.5.1.5.E.

The licensee is reviewing the specific area and developing formal procedures to upgrade the management controls.

This item will remain unresolved pending completion of the (

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. review by the licensee and review by the inspector at a sub-t-'

sequent inspection (This item was discussed at the management exit and by telephone on June 1, 1978).

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No items of noncompliance or deviations were identified.

8.

Reactor System Decontamination The inspector reviewed the use of chemical decontamination

--solutions at the facility on reactor system pressure boundary components.

No decontamination performed or planned, a.

b.

No decontamination chemicals introduced into the primary system (This item was discussed at the management exit).

No items of noncompliance or deviations were identified.

9.

IE Bulletin and Circulars The inspector reviewed the following IE Bulletins and Circulars to assure the licensee reviewed and evaluated the items as appropriate, IEB 78-03, Potential Explosive Gas Mixture Accumulation s.

Associated with BWR Off Gas Systems.

h.

IEB 78-04, Environmental Qualification of Certain Stem Mounted Limit Switches Inside Reactor Containment.

IEC 78-02, Proper Lubricating Oil for Terry Turbines.

c.

d.

IEC 77-15. Degradation of Fuel Oil Flow to the Emergency Diesel Generator.

IEC 77-16, Emergency Diesel Generator Electrical Trip Lock-e.

out features.

No items of noncompliance or deviations were identified.

10.

Item of Noncompliance Theinsepctorreviewedthecorrectiveactionstakgijbythelicensee concerning an item of noncompliance (deficiency).--

The licensee 5/

IE Inspection Report No. 50-155/77-08.

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had coepleted the corrective action indicated in the response and had subsequently rewritten the procedure for the shutdown margin test (RE-08, now TR-43).

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No further questions are required of this matter at this time

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and this matter is considered closed.

11.

Procedures

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The inspector reviewed the following procedures to insure the procedures were issued, reviewed, and approved in accordance with the requirements; also that the procedure changes were reviewed and approved and did not conflict with the Technical Specifications.

General Operating Procedures a.

The licensee (1) GOP 1, Rev. 2, Startup from Cold Shutdown.

master checklist / system checklists does not include a line up of the station electrical systems (2.4 KV, 480V, station lighting, protection, and 125V DC) specifically to assure alignment of all breakers and equipment prior to plant startup. The breaker and equipment positions are maintained through routine operations and maintenance controls. During the inspection no equipment was noted

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to be out of position. The licensee is reviewing the need for an electrical line-up checklist. This item will remain open and will be reviewed at a future inspection.

(2) GOP 2, Rev. 2, Hot Startup.

(3) GOP 4, Rev. 3, Reactor Trip Recovery (4) GOP 5, Rev. 2, Power Operations The licensee performs a heat balance weekly (T7-06) or as required and adjusts the power range instrumentation as necessary to maintain the reactor thermal power below the administrative limits set by management.

The inspector noted that the power range instruments were administratively set between 97 percent and 100 A discussion of the setpoints on the power percent.

range instruments and the allowable increase in power from 97 percent indicated to 100 percent indicated power, in addition to the assumed 2 percent inaccuracy assumed in the manual heat balance, a total of 5 percent thermal power error could result in the approach

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Ltr, CP to RIII, dtd 8/10/77.

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i and/or exceeding of certain core power limits. A review of the deviations issued previously when the indicated thermal power administrative' limit was exceeded' revealed that the core limits had not been exceeded. 'The licensee

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is reviewing the administrative power limits and the use of the computer heat balance (corrected to the last hand heat balance calculation) in addition to the feedwater and steam flows as a trending method to assue the core limits are not approached or exceeded.

This item will remain open and be reviewed at a future inspection (This item was discussed at the management exit).

(5) C0P 6. Rev. 2, Hot Shutdown.

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(6) GOP 7, Rev. 2, Cold Shutdown.

b.

Standard Operating Procedures (1) S0P 1. Rev. 9, Reactor Operations.

(2) SOP 3, Rev. 6, Reactor Cleanup System.

(3) SOP 5, Rev. 5, Renctor Shutdown Cooling System.

(4) SOP 6, Rev. 2, Emergency Condenser System.

(5) SOP 8, Rev. 4, Post Incident System.

(6) S0P 9, Rev. 2, Fuel Fool System.

(7) SOP 14 Rev. 2, Station Substation.

(8) SOP 18, Rev. 7. Reactor Depressurization System.

(9) S0P 22, Rev. 1, Air Ejector Offgas System.

(10) S0P 26, Rev. 11, Fire Protection System.

(11) S0P 28, Rev. 6, Station Power System.

(12) SOP 29, Rev. 4, Nuclear Steam Supply System.

(13) S0P 30, Rev. 7, Control Rod Drive System.

(14) SOP 32, Rev. 2, Incore Instrumentation System.

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(15) SOP 33, Rev. 2, Air Ejection Of fgas System.

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(16) SOP 36, Rev. 1, Emergency Condenser Vent Monitor.

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(17) SOP 42, Rev. 1, Annunciators.

.0ffnormal Procedures c.

(1) ONP 2.2, Rev. 3, Loss of Instrument Air System.

(2) ONP 2.3, Rev. 2, Loss of Condensate System.

The review revealed that the procedures inadequately addressed the loss of the " fill valve" from the con-

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densate storage tank to the condenser.

The fill valve operability is required for continued plant operation.

The licensee issued a daily order and temporary pro-cedure and a permanent procedure change will be issued presently. This item will remain open pending the review of the procedure change at a subsequent inspection (This item was discussed at the management exit).

(2) ONP 2.5, Rev. 2, Abnormal Radioactive Releases in Containment Building and Emergency Entry.

(4) ONP 2.14, Rev. 3. Loss of Emergency Diesel Generator.

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(5) ONP 2.16, Rev. 5, Loss of Fire Protection System.

(6) ONP 2.17, Rev. 3, Abnormal Off-Gas or Stack-Gas Release.

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(7) ONP 2.32, Rev. 3, Low and High Steam Drum Level.

(8) ONP 2.36, Rev. 2, Loss of Station Power.

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(9) ONP 2.37, Rev. 2, Trouble in Reactor Depressurization System.

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Emergency Procedures (1) EMP 3.1, Rev. 3, Loss of DC Power System.

(2) EMP 3.2, Rev. 2, Loss of Neutron Flux Indication.

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(3) EMP 3.3, Rev. 6. Loss of Reactor Coolant.

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The inspector noted that the loss of coolant accident being an emergency condenser tube rupture did not appear to be adequately addressed (This item was

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discussed at the management exit).

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(4) EMP 3.4, Rev. 3, Fuel Handling Accidents.

(5) EMP 3.6, Rev. 4, Fires in Plant.

Administrative Procedures e.

(1)

1.2, Organization and Responsibility.

(2)

1.4, Operations Department Administrative.

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(a) Shift Relief and Turnover (b) On-duty Superintendent (c) Shift Logs (d) System Status (e) System Tagging

(f) Adherence to Procedure and Temporary Procedure changes.

(g) Surveillance (3) Maintenance Administrative (a) Adherence to Procedures and Temporary Procedure Changes.

(b) Surveillance (c) Fire Hazzards (d) Cleanliness (e) Control of Test and Measurement Equipment (4) Cortrolled Materials Procedures Manual (5) Master Training Manual

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Maintenance Procedures 76-EPS-073, Rev. O, 3/14/77, Emergency Diese'l Generator (1)

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Trouble Annunciation.

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(2) 76-SPS-247, Rev. O, 12/7/76, Emergency Lighting Annunci-ation Installations.

(3) 77-RPS-C413-A Rev. O, 2/10/77, ECCS On-line Test Fittings

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Installation.

(4) MRSD-3, Rev. 3,10/28/77, Steam Drum Safety Valves.

(5) IEPS-2, Rev. O, 4/17/78. Emergency Diesel Generator Battery Undervoltage Monitor Calibration and Test.

(6) INUMS-8, Rev. 2, 3/16/78, Bench Calibration of Log-N Amplifier.

(7) IRPS-10, Rev. 1, 5/2/78, component Inspection and Circuits Resistance Check on Channel 1 and 2 Logic Units.

(8) MEPS-1, Rev. 4, 4/25/78, Emergency Diesel Generator Inspection and Repair.

l Uutstanding Inspection

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The inspector reviewed selected outstanding items to assure licensee actions as required.

Fire Protection System 1 a.

Items of review included the new and upgraded surveillance procedures, completed testing, and the revised operating procedures.

(1) T30-34, Rev.1, Monthly Fire Protection System Testing.

(2) TR 69, Rev. 1, Fire Protection System Flush and Inspection.

(3) TR 70, Rev. O, Fire Suppression Water System Functional Test and Pump Test.

(4) TR 71, Rev. O, Fire Protection System Deluge Test.

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Ltr, NRR to CP, dtd 3/6/78.

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(5) TV 22, Rev. 2, Three-Year Fire Protection System Check and Test.

No iteins of noncompliance or deviations were identified,

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b.

Milestone Event The licensee study of the facility electrical system has been essentially completed and is being reviewed by the plant personnel prior to submitted to NRR (This item was discussed at the management exit and by telephone on June 2, 1978, with Nuclear Licensing Department).

13. Management Exit Interview The inspector conducted a management exit interview with the licensee representatives denoted in Paragraph 1 at the con-clusion of the inspection on May 26, 1978.

The inspector summarized the scope and findings of the inspection and the licensee made the following comments and statements concerning the items discussed by the inspector:

The licensee stated that the study being performed as a result of '.he undervoltage event at the Milestone Station was continuing.

The completion was projected to be in early June 1978 (Paragraph j

12b).

The licensee stated that no decontamination of the primary system had been performed nor was planned and routine decontamination of components for maintenance was performed utilizing water and standard practices (Paragraph 8).

The licensee acknowledged the inspector's statement that the operation of the plant with the reactor depressurization system in the degraded condition was an item of noncompliance (infraction)

and that corrective actions taken appeared adequate to prevent recurrence; therefore, no response was required for this item (Paragraph 4c).

The licensee stated that the administrative limits on power and the gain settings on the "picos" following a heat balance perfor-mance would be reviewed (Paragraph lla).

The licensee stated that the off-normal procedures concerning the loss of the condenser fill valve would be reviewed and updated (Paragraph lic),

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Ltr, CP to NRR, dtd 12/9/76.

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The licensee. stated that loss of coolant accident as a result of an emergency condenser tube leak was being reviewed (Para-

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graph lidh The licensee stated that the deviation reports concerning violation of procedures when _ dealing with operability requirements of The licensee also safety-related activities would.tne reviewed.

stated that the administrative guidelines would be developed and implemented to review the outstanding deviation reports during 1978 in order to comply with the requirements (Paragraph 7d).

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