IR 05000155/1985010

Insp Rept 50-155/85-10 on 850603-0726.No Violation or Deviation Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Maint Activities & Qa/Qc Administration

ML20133D228
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/01/1985
From:	Hasse R, Hawkins F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133D214	List: IR 05000155/1985010 ML20133D210
References
50-155-85-10, NUDOCS 8508070265
Download: ML20133D228 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/85010(DRS)

Docket No. 50-155 License No. DPR-06 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Facility Name: Big Rock Point Nuclear Plant Inspection At: Charlevoix, Michigan Glen Ellyn, Illinois Inspection Ccnducted: June 3-7, June 10, June 17-21, July 9-12, July 17, 22, 24, and 26, 1985 Inspector: %M asse R- \- %$

Date Approved By:

SDMk F. Hawkins, Chief  %- \d 5 Quality Assurance Programs Section Date Inspection Summary Inspection on June 3-7, June 10, June 17-21, July 9-12, July 17, 22, 24, and 26, 1985 (Report No. 50-155/85010(DRS))

Areas Inspected: Routine inspection by one regional inspector of licensee action on previous inspection findings, maintenance activities, and QA/QC administration. The inspection involved 80 inspector-hours onsite and 15 inspector-hours in the Region III offic Results: No violations or deviations were identifie h

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8500070A $500055 PDR PDR G

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DETAILS Persons Contacted Consumers Power Company D. Hoffman, Plant Superintendent

• C. Abel, Operations and Maintenance Superintendent

• • G. Withrow, Maintenance Superintendent

• D. Wilks, Maintenance Supervisor

• J. Johnson, Instrumentation and Controls Supervisor

• L. Monshor, Quality Assurance Superintendent G. Petitjean, Technical Superintendent D. Herboldsheimer, Outage Coordinator Supervisor W. Blosh, Senior Plant Technical Analyst D. Staton, Shift Supervisor

• • G. Slade, Executive Director, Quality Assurance (by telecon)

1. **R. Alexander, Technical Engineer -

• • T. Fisher, Senior QA Administrator

• • R. Barnhart, Senior QA Administrator USNRC

• S. Guthrie, Senior Resident Inspector Other personnel were contacted as a matter of routine during the inspectio * Denotes those attending the exit interview on June 21, 198 ** Denotes those attending the exit interview on July 12, 198 # Denotes participation in telecon exit interview on July 26, 198 . Action on Previous Inspection Findings (Closed) Unresolved Item (155/84-15-01): Administrative procedures did not require a documenteo 10 CFR 50.59 review for temporary modifications (liftedleadsandjumpers). The inspector verified that the applicable administrative procedures had been revised to require this review for all temporary modifications not previously addresse . Program Areas Inspected Maintenance Program During the most recent SALP period (SALP 5), the licensee was rated as a Category 2 in the maintenance area. This represented a decline in performance from the SALP 4 period in which the licensee was rated a Category 1. In addition, SALP 5 noted that performance continued to decline during the rating period. The primary reason for the decline in the SALP rating was the increase in the number of problems requiring maintenance attention. A particular concern was expressed about those that could have been prevented by a mnre aggressive PM program (i.e.,

emergency diesel generator problems). Other concerns were the lack of

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increased management attention to reverse the trend toward more main-tenance problems and the occasional lack of aggressive action in solvin maintenance problems. This inspection was augmented to assess the reasons for the declining performance and any remedial actions being taken by the licensee to reverse i (1) Inspection Results The inspector reviewed the procedures controlling maintenance activities, maintenance history files for selected pieces of equipment, completed maintenance order packages, recent licensee audits of the maintenance program, the SALP 5 Report, Licensee Event Reports for 1983-85, and Deviation Reports. The inspector also interviewed licensee personnel responsible for the mainten-ance program. Specific observations were as follows:

a_ During the review of completed maintenance orders (M0's),

the inspector noted that the equipment outage requests (EOR's) were not always completed. Further investigation indicated that this problem had been identified in the 4 licensee's 1984 audit of maintenance activities and was incorporated in that report as an observation. During the licensee's 1985 audit of this area, the problem was found to be worse and the matter was upgraded to a finding. This is considered an unresolved item pending NRC review of the licensee's prompt corrective action (155/85010-01).

b The inspector reviewed the licensee's program for independent verification of system alignment for removal from and return

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to service. When protective tagging (for personnel protection)

is required, independent verification of system alignment is

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performed for removal from service; however, the tagging system does not provide for independent verification of l system alignment for return to service. In addition, instru-mentation and control procedures for calibrations do not require independent verification of system alignment during i either removal from or return to service.

The inspector discussed this issue with licensee personnel, l

and they stated that the E0R system does require action to i determine equipment operability prior to returning it to

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service. In some cases, this would represent independent i

verification of system alignment. In other cases, only the item worked on may be tested and overall system alignment may not be verified. The Nuclear Operations Department

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Standard governing this area was revised during this inspection to reflect this fact permitting operability testing to be used for independent verification only when l

personnel hazards precluded visual verification by a second

qualified individual. This is considered an unresolved

! item pending NRC review of the revised operating procedures (155/85010-02).

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c- The maintenance staff is experienced and well qualifie The licensee is generally able to replace experienced personnel that leave with personnel experienced in their particular craf Systems training is provided to the new personne Some skill training is also provided. While no formal on-the-job training program is used, an apprentice type program is employed. This provides " hands-on" experience with plant equipment to new staff members under the supervision of experienced personnel. An INP0 accredited maintenance training program is being pursue d_ Approximately 4000 maintenance orders (M0s) are processed each year. At the time of this inspection there were 2 M0s open from 1982 (under review for necessity), 8 from 1983 and approximately 115 from 1984. The backlog appeared to be reasonable. Preventive maintenance (PM) tasks were being completed in reasonable agreement with the PM schedul ~

e To assess the reasons for the declining SALP performance, the inspector reviewed the examples listed in SALP 5. The inspector also reviewed LER's for 1983-1985 for other main-tenance problems which led to reportable condition Specific observations are as follows:

. The problems with the emergency diesel generator involved a fuel pump shaft failure, loose and pitted contacts, and failure of a drive coupling to the engine cooling water pump due to long term wea While the diesel engine had recently been overhauled, the remainder of the system had not been examined or refurbished. It does appear that a more complete PM program for this sytem would have prevented these problem . An example of a corrective maintenance situation that might have been prevented by more aggressive corrective action involved the recirculating pump seal leakoff valves (IA60A and IA608). These valves are no longer used to control seal leakage but remain in a full open positio In February 1984, the packing in IA60A failed leading to a high containment radiation level and a forced outage to repack the valve. During April 1985, IA60B packing failed leading to another forced outage to repack that valve. The inspector reviewed the deviation report associated with IA60A to determine why IA60B was not repacked after IAG0A failed. The licensee evaluation of the IA60A failure "

appeared to conclude that the reason for the failure was that the valve was not backseated. It also noted that there was some packing left and that the packing was still pliable. Corrective action included repacking IA60A, adjusting IA60B packing, and backseating the valve. A change was also initiated to an operations valve checklist to routinely ensure these valves were

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backseated. One item not addressed was anticipated packing life and establishing a repacking schedule for these valves. Considering the consequences of packing failure it would appear prudent to have repacked IA60B at the same time as IA60A or at least scheduled it for the next outage. The valves had not been repacked within the period covered by their machinery history records (1977 was earliest entry).

(2) Conclusions and Recommendations There is evidence of weaknesses in the PM program and a lack of management aggressiveness in upgrading that program based on plant experience to prevent equipment failures. This is particularly important considering the age of the plant resulting in the increased potential for end-of-service-life failures. The licensee has taken some actions to reduce equipment failures and increase reliability. Among these are budgeting for replacement of recorders and transmitters, assessing the replacement of neutron instrumentation, and the establishment of a PM program for limitorque operators. However, the following additional actions should be-considered:

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a Treat corrective maintenance M0s more like corrective action documents. Specifically, a review should be performed to ensure the root cause has been properly identified and an assessment made to determine if better PM (or other action)

could prevent recurrence. The assessment should include generic implications and be completed prior to closing the M b A formal evaluation should be made for important plant equipment to assess the potential for end-of-service life failures and determine actions necessary to prevent these failure ~

c The infonnal assessments of equipment problems currently performed by the maintenance staff should be documented in the maintenance history files to ensure their availability for future assessments.

I b. QA/QC Administration The licensee had recently reorganized resulting in the transfer of some functions previously performed at the General Offices (GO) to the Big Rock Point (BRP) site organization. The transfer of these

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functions necessitated changes to the QA program implementing l procedures and increased the the BRP QA staff workload. Because of l NRC concerns relative to the safety impact, the inspector assessed

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these changes to determine the adequacy of the procedure changes, if BRP QA personnel were qualified to perform their new responsibilities, and the impact of the added workload on the ability of the BRP QA staff to adequately perform their assigned tasks.

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(1) Procedure Changes The top tier implementing documents for the QA program are the Nuclear Operations Department Standards (N0DS). These standards specify the organizational responsibilities and requirements for various subject areas (such as fire protection and plant security. Due in part to the reorganization, 16 N0DS had been revised and 15 cancelled. Changes to Administrative Procedures (APs) (second tier implementing procedures) had not been completed at the time of this inspectio a_ Inspection Results The inspector reviewed the revised and cancelled N0DS and identified the following concerns:

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1 The inspector noted that in some cases a revised NODS referenced a cancelled NODS. In one case the reference was a "use" reference: N0DS-Q01, (" Corrective Action and Nonconforming Items") was revised to require QA Support to trend certain items in accordance with h0DS-M05 (" Supplier Evaluation and Selection") which had been cancelled. The inspector asked whether the requirements of the cancelled N0DS were included in either the remaining N0DS or the Administrative Proce-dures (APs). Licensee personnel stated that the situation had been reviewed and they were satisfied that all requirements of the cancelled N0DS were addressed; however, they recognized that cancelled N0DS were still referenced in both the APs and active N0DS and could not ensure that there were no other cases in which the reference was a "use" reference. The licensee's current plan was to delete references to the cancelled N0DS in the APs or N0DS when they were revised for other reasons or at the time of their biennial review. The inspector was concerned that in the case where the reference was a "use" reference, as in the case noted above, this schedule could lead to the use of uncontrolled documents (cancelled N0Ds) or the lack of specific direction for performing safety

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related activities. This is considered an unresolved item pending further NRC review (155/85010-03).

2_ The NODS provide a convenient reference to applicable requirements for a specific subject area and provide a vehicle for G0 level interpretation of these require-ments. The inspector was concerned that the APs become more vulnerable to missing requirements in those areas where a NODS had been cancelled since the gap between the baseline requirements (Facility License, NRC approved QA program, etc.) and the APs had been widened. The preparation of APs becomes more difficult since the baseline documents must be searched to identify applicable requirements. The workload

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and potential for error are thus increased. The licensee is planning to mitigate this problem to some extent b Matrix (yQARM).

revising TheitsQARM Quality Assurance is currently a twoRequirements dimensional matrix relating requirements to implementing procedure The revision will add a third dimension relating subject to requirements. This is considered an open item pending further NRC review of the adequacy of the revised QARM for identifying regulatory requirements relating to subject areas (155/85010-04).

_3_ The N0DS also provide a vehicle for establishing corporate level policy related to regulatory requirements in a subject area. The inspector was concerned that for those subjects covered by the cancelled N005, this policy making authority had been effectively transferred to the plant and department level managers thereby reducing corporate level contro The licensee stated that this had been discussed extensively and that corporate level management felt they had adequate control through the performance appraisal (MB0) system. .The inspector had no further questions concerning this subjec Some changes in the revised N0DS, taken collectively, appeared indicative of weakened controls. Specifically:

. The Corrective Action Review Board (CARB) will no longer review completed Event Reports (ERs)

or Deviation Reports (DRs). They will review only the initial report . ERs and DRs will no longer be prioritize . Applicability of many N0DS is for safety-related items only. The issues of "important to safety" and " reliability" are not addresse .

Overdue corrective actions will no longer be explicitly escalated to higher levels of managemen .

The Plant Review Committee (PRC) will no longer review Q-list change . The PRC will no longer review all violations of procedures required by the Technical Specifications, only those considered to have significant safety impac Individually, these items may be justified on the basis of efficiency or line management responsibility or bot However, as noted above, they do appear indicative of weakened control .

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b_ Conclusions and Recommendations Based on the observation noted above, the inspector concluded that the cancellation of some of the NODS was premature in that the licensee did not adequately ensure that they were no longer required as a "use" reference nor provide a fully operational alternative for efficient identification of requirements for specific subject areas (eg, QARM). Further, overall operational controls may have been weakened. Based on these conclusions, the following actions appear warranted:

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1 The licensee should perform an immediate and in depth review to identify any case where a cancelled NODS is required as a "use" referenc In those cases, immediate corrective action should be take The revision to the QARM should be given a high priorit _ The licensee's audit and trending programs should be augmented on a temporary basis to focus on these changes to determine if they have impacted the safety of facility operatio (2) Site QA Workload and Staff Qualifications The site QA staff had been assigned new functions previously performed by the GO QA staff. These functions were:

. Fuel vendor inspections

. Inservice inspection program

. In-line QA reviews for the G0 projects organization (BRP projects)

. Equipment environmental qualification (EEQ)

program for BRP

. Appendix R (safe shutdown) building for BRP

. Core physics packages for BRP The lead responsibility for the fuel vendor inspections haa originally been reassigned to BRP. However, the lead was later transferred to the Palisades QA staff with BRP providing auditor support. The EEQ program and Appendix R building were primarily one time effort The inspector interviewed site QA personnel and reviewed formal workload projections to determine if the site QA organization was qualified and adequately staffed to perform these newly assigned task .. o a Inspection Results The inspector made the following specific observations:

1 The workload projection did not include all categories of work performed by the QA organization. Non-projected categories included surveillance (approximately 9% of 1983 effort), training, corrective action closecut reviews, independent assessments, consulting, and other miscellaneous activities. For those categories that were projected, the projection for 1985 was based

- on actual manpower expended during the first 6 months of the year. It included neither the additional effort required to support the refueling outage scheduled for late 1985 nor any increase in workload due to the reorganization which was not fully reflected in the effort expended during the first six months of 198 Site QA personnel felt that the 1985 workload for the projected categories would be approximately 10% higher than projected. No projections were available beyond 198 The projected categories required an increase of 10%

of the total QA manpower available over that expended in 1984 in the same categories (adjusted for the anticipated 10% increase in the 1985 projection for these categories). An increase in the manpower require-ments for the non-projected categories of training and consulting was also experienced during the first 6 months of 1985. The manpower to support the increase in the projected and non-projected categories was to

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come from a decrease in the number of surveillances to

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be performed during 1985. The site QA staff felt that

' those surveillances performed would also contain less depth than those performed during 1984. Thus, it l

appeared that an increase of 10% of available manpower j for projected categories plus an increase in non-pro-

! jected categories plus added refueling outage effort I was to be recovered by reducing (not eliminating)

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effort in a category utilizing only 9% of available manpcwer during 1984. This did not appear feasible to the inspecto The inspector was satisfied that the QA staff was qualified to perform the newly assigned function However, extra time was required by the staff to l

familiarize themselves with the specific requirements l

i in certain areas such as inservice inspection and fuel

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vendor audits. Also, one QA staff member (representing 25% of available staff hours) was still in training and l-currently qualified to perform only certain categories of work. This impacted the flexibility in assigning staff work and increased staff training tim ~

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b Conclusions and Recommendations Based on the observations noted above, the inspector con-cluded that workload projection for the site QA staff was inadequate in that historical data was used to project workloads in a changed situation and only a portion of the total workload was projected. Further, the uncertainties noted above not withstanding, the site QA organization did appear to be understaffed, at least for the short ter Based on these conclusions, the following recommendations are made:

1 A more meaningful workload projection for the site QA staff should be made. The projection should include all categories of effort and reflect the full impact of newly assigned functions. The projection should also extend beyond 198 _ The site QA staff should be temporarily supplemented at least until all current staff members are fully qualified, the 1985 refueling outage is complete, and the above projection is completed. Any permanent change in staff level should be based on the completed projectio . Unresolved Items Unresolved items are matters about which more infonnation is required in order to ascertain whether they are acceptable items, violations, or deviations. Unresolved items disclosed during this inspection are presented in Paragraphs 3.a.(1).a_, 3.a.(1).b_, and 3.b.(1). . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action

on the part of the NRC or licensee or both. An open item disclosed

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during this inspection is presented in Paragraph 3.b.(1). . Exit Interviews The inspector met with licensee representatives (denoted in Paragraph 1)

on June 21, 1985 and July 12, 1985, and summarized the purpose, scope, and findings of the inspection. A final summary of the inspection findings was presented to the licensee via telecon on July 26, 1985. The licensee indicated that the inspector had no access to proprietary information during the inspectio