IR 05000155/1981003

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IE Insp Rept 50-155/81-03 on 810310-0409.Noncompliance Noted:Failure to Adhere to Written Operating Procedures & to Post Area as Radiation Area
ML20004E326
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 04/29/1981
From: Boyd D, Parker M, Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20004E321 List:
References
50-155-81-03, 50-155-81-3, NUDOCS 8106110545
Download: ML20004E326 (8)


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

REGION III

Report No. 50-155/81-03 Docket No. 50-155 License No. DPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Power Plant Inspection At: Charlevoix, MI Inspection Conducted: March 10 through April 9, 1981

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Projects Section 1A Inspection Summary Inspection on March 10 through April 9, 1981 (Report No. 50-155/S1-03)

Areas Inspected: Routine resident inspector inspection involving: operational safety verification, Bulletin followup, Circular followup, startup physics test-ing, shutdown margin verification, core power distribution limits, control rod scram time testing, control rod sequence and reactivity checks, core thermal power evaluation, and maintenance activities. The inspection involved a total of 234 inspector-hours onsite by two NRC inspectors including 0 inspector-hours onsite during off-shifts.

Results: Of the ten areas inspected, two items of noncompliance were identified in one area (Failure to follow procedures, Paragraph 2a and b; failure to post a radiation area, Paragraph 2c.).

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h DETAILS 1.

Persons Contacted

  • C. J. Hartman, Plant Superintendent
  • A. C. Sevener, Operations Supervisor
  • D. E. De!!oor, Technical Engineer R. L. Burdette, Senior C&RP Technician
  • L. F. Monshor, General Engineer
  • T. R. Fisher, QA Analyst
  • C. R. Abel, Operations and Maintenance Superintendent
  • J. J. Popa, Maintenance Engineer The inspectors also contacted other licensee personnel, including shift supervisors, control operators, radiation protection personnel.
  • Denotes those present at the exit interview.

2.

Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the month of March. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the reactor buildings and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector by observation verified that the Physical Security Plan was being implemented in accordance with the Station Security Plan.

The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the

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month of March, the inspector walked down the accessible portions of

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the Post Incident System to verify operability. These reviews and l

observations were conducted to verify that facility operations were in conformance with the requirements established under Technical l

l Specifications, 10 CFR, and administrative procedures.

Durink control room tours during March the following items were observed by the inspectors:

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The Post Incident System portion of the Master Checkoff List re-a.

quires that valve M0-7068, backup containment spray isolation valve, te verified closed and " insure Remote Manual Control (RMC)

is not pull-to-stop" position. Review of records and discussions j

l with operations personnel did not reveal any reason for, or any l

procedure which changed the position of the RMC from the closed position to the closed " pull-to-stop" position.

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s The licensee's immediate corrective action was to remove the RMC from the " pull-to-stop" position.

It is to be noted the valve M0-7068 is a remote-manual valve with no automatic function. To place the backup cuatainment spray system into service required manual action by the operator.

As such, whether the handswitch is in the closed or closed

' pull-to-step" position has little impact on the operability of the system, b.

During review of the shift supervisor's and control room log book the inspector noted that on March 27, 1981 point four on the con-tainment temperature recorder alarmed high on two separate occasions with a period of normal operation separating the two ala rms.

The inspector noted that each alarm was entered in the shift supervisor's log, however, only the initial alarm was entered in the control room log.

The inspector reviewed Alarm Procedure 1.4 for annunciator 9A, Containment High Temperature, and verified that the stated operator action is to close the containment ventilation isola-tion valves.

Further review of the log books and discussion with operations personnel indicated that in neither alarm situation were the containment ventilation isolation valves closed.

The need to close the containment ventilation isolrtion valve upon receipt of a high containment temperature alarm was brought to light during the licensee's small break loss of coolant acci-dent analysis. Both the analysis and the SER for Licensee Amendment No. 37 indicate that operator action is the primary means to isolate the containr ent.

Technical Specification Section 6.8.1 states in part:

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procedures shall be established, implemented and maintained for all structures, systems, components and safety actions....."

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As noted in Paragraphs a. and b. above, the licensee failed to l

adhere to procedures governing the-backup containment spray and

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containment isolation systems. This is considered to be an item of noncompliance (155/81-03-01).

During a routine tour of plant accessible areas conducted on c.

April 6 and 7, 1981, the. inspector noted an increase in radiation dose rate, outside the protected area fence, as indicated on a survey meter being carried by a licensee health physcis technician.

Subsequent surveys were performed by licensee radiation protection personnel, accompanied by the inspectors. The surveys around the contaminated too.1 storage warehouse and the high 1cvel waste storage vault indicated the following:

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The maximum radi ttion field outside the security fence adjacent to the warehouse was 1.5 mr/hr.

b.

The maximum radiatica field outside the security fence surrounding the hir,n level waste vault was 18 mr/hr at contact and 12 mr/nr at 18".

The 18 mr/hr reading was measured adjacent to a trailer which is used to store drummed waste.

10 CFR 20.203(b) states: "Each radiation rea shall be con-spicuously posted with a sign or signs beacing the radiation caution symbol and words CAUTION RADIATION AREA." A radiation area in this context is defined as "....any area accessible to personnel" in which the radiation levels are such "that a major portion of the body could receive in any one hour a dose in excess of 5 millirem...."

Contrary to the above, the radiation area immediately south of the high level waste storage vault area, and adjacent to a drum storage trailer, was not posted as a radiation area.

The licensee's immediate corrective action was to post the area with signs consistent with the requirements of 10 CFR 20.203(b).

3.

Monthly Surveillance Observation The inspector observed, as required by Techn'

' Specifications, surveillance testing on the Area Monitoring.-

.em and verified that the testing was performed in accordance with adequate pro-cedures, that test instrumentation was calibrated, that limiting conditions for operations were met, that removal and restoration of the affected components were accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing l

were properly reviewed and resolved by appropriate management

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personnel.

No apparent items of noncompliance were identified.

4.

IE Bulletin Followup e

For the IE Bulletins listed below the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported, that the written r.sponse included adequate corrective action commitments based on information-presentation in the bulletin and the licensee's response, that licensee management forwarded copies of the written response to the appropriate onsite management represen-tatives, that information discussed in the licensee's written response-4-

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W was accurate, and that corrective action taken by the licensee was as described in the written response.

a.

IEB 79-03 (Closed) Longitudinal Wald Defects in ASMI SA-312 Type 304 Stainless Steel Pipe Spools Manu-factured by Youngstown Welding and Engineering Company b.

IEB 79-15 (Closed) Deep Draft Pump Deficiencies c.

IEB 80-25 (Closed) Operating Problems with Target Rock Safety / Relief Valves at BWR's No apparent items of noncompliance were identified.

5.

IE Circular Followup For the IE Circulars listed below, the inspector verified that the circular was received by the licensee management, that a review for applicability was performed, and that if the circular applicable was to the facility, appropriate corrective actions were taken or were scheduled to be taken.

a.

IEC 78-15 (Closed) Tilting Disk Check Valves Fail to Close with Gravity in Vertical Position b.

IEC 79-05 (Closed) Moisture Leakage in Stranded Wire Conductors c.

IEC 80-23 (Closed) Potential Defects in Beloit Power Systems Emergency Generators No apparent items of noncompliance were identified.

6.

Verification of Conduct of Startup Physics Testing

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The inspector reviewed the startup physics testing and verified that l

the licensee conducted the following:

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Control Rod Scram Time Tests l

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Control Rod Sequency and Reactivity Checks c.

Core Power Distribution Limits I

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Ccre Thermal Power Evaluation i

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Determination of Shutdown Margin

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No apparent items of noncompliance were identified.

l-7.

S_butdown 21argin Determination l

l Big Rock Point Technical Specifications require that the shutdown margin l

with the most reactive control rod stuck out of the core be greater than 0.3% of reactivity.

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The inspector examined information relating to shutdoan margin determina-tion as described in Procedure No. TR-43, Revision 7, Shutdown Margin Check, dated May 19, 1980.

The inspector noted that, at the start of the test all control rods were fully inserted and two fission chambers were placed in the core in addition to the two fixed excore channels. The measurements of the steady state neutron count rates were recorded for all four channels.

Then a control rod was completely withdrawn, and an adjacent control rod was withdrawn a few notches which were equivalent to an insertion of reactivity greater than 0.3%, as determined by the computer code (GROK). The count rates of the four channels would increase and level off to new steady state values to verify that suberiticality was still maintained. The new steady state count rates of the four channels were recorded. Measurements continued until subcriticality of at least 0.3%

reactivity was verified for every configuration with one rod full out and an adjacent rod partially out.

The inspector concluded that the Technical Specifications requirement on shutdown margin determination was met.

No' apparent items of concompliance were identified.

8.

Core Power Distribution Limits

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The inspector reviewed information relating to surveillance of core power distribution limits which were calculated by the computer code (GR0K). The inspector examined the GR0K printouts obtained for Cycle 17.

The inspector determined that all prerequisites were met, the input to the computer was from actual plant conditions, all thermal margins satisfied Technical Specification requirements, and the calculated values by the computer were within the acceptable criteria established by the licensee.

No apparent items of noncompliance were identified.

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9.

Control Rod Scram Time Tests L

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Big Rock Point Technical Specifications require thet the control rod I

scram time be less than 2.5 seconds for 90% insertion of all control rods.

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The inspector reviewed information relating to control rod scram time tests as described in Procedure No. TR-01, Revision 6, Control Rod Drive Performance Test Procedure, dated October 25, 1978. The inspector examined the results of the test performed on January 11 and 12,1980.

The results indicated that the scram time of each rod was less than 1.5 seconds for full insertion.

l The inspector concluded that control rod scram tests satisfied Technical l

Specification requirements.

l No apparent items of noncompliance were identified.

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10.

Control Rod Sequence and Reactivity Checks The inspector reviewed information relating to control rod sequence and reactivity checks as described in Procedure No. 16.3.2, Revision 1, Critical Configuration Prediction, dated April 24, 1978. The accept-ance criterion stated that the differnece between the predicted and the actual critical configuration be less than 1% of reactivity.

The inspector reviewed information related to " Critical Approach and

Period Report," dated April 24, 1978. The result indicated that actual criticality was achieved using the alternate control rod withdrawal sequence and the reactor was critical on Step 56.

The difference between the predicted and the actual keff due to the difference between the predicted and the actual control rod configuration was less than 1% of reactivity.

The inspector concluded that control rod sequence and reactivity checks were adequate.

No apparent items of noncompliance were identified.

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11.

Core lhermal Power Evaluation The Technical Specifications require that the maximum steady state

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power level shall not exceed 240 MWE.

The inspector reviewed information relating to determination of core thermal poser and calibration of neutron monitoring power channels as described in Surveillance Procedure No. T7-06, Revision 4, Heat Balance Calculation, dated May 19, 1980. The inspector performed a hand heat balance calculation and determined that tl.e steady power level was 214.85 MWE. The calibration of out-of-core neutron monitoring system power channels were found to be within the 3% calibration tolerence as required by plant administrative requirements.

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The inspector concluded that Core Thermal Power Evaluation results f

satisfied Technical Specification requirements.

l No apparent items of noncompliance were identified.

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Maintenance The inspector initiated a review of maintenance activities to ascertain that activities on safety related systems and components were conducted in accordance with approved procedures, regulatory guides and industry l

codes or standards and in conformance with Technical Specification re-l quirements.

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l During the review of Maintenance Order CIS-028-07 dealing with leak rate testing of containment penetrations H89, 90, 91, 95, 96, 98, and 99 the f

inspector noted that the procedure required a test pressure of 2.5 psig.

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o Technical Specification Section 3.7(c) states in part...."After....any disassembly of components that would affect sphere integrity, an indi-vidual component leakage rate or an integrated leakage rate test....

shall be performed, with air at a pressure not less than 10 psig."

The configuration of the penetrations in question has two valve-in series (outside containment) followed by a "T" connection. One side of the "T" goes to the instrument the other side is a capped t,be for calibration purposes, no isolation valve exists between the cap and the instrument.

The test referenced above was performed to verify integrity of the

" capped" tube after the cap had been replaced following calibration.

The test pressure of 2.5 psig was picked to allow for " snoop" checking of the cap but was also a low enough pressure not to disturb the cali-bration of the instrument.

The inspector has asked the licensee to evaluate the above practice in relation to Technical Specification Section 3.7(c). This is an unresolved item pending licensee review.

(155/81-03-03)

13.

Exit Interview The inspectors met with licensee representatives denoted in Paragraph 1 at the conclusion of the inspection and summarized the scope and findings of the inspection.

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