IR 05000155/1985011

Insp Rept 50-155/85-11 on 850611-0729.No Violation or Deviation Noted.Major Areas Inspected:Action on Previous Insp Findings,Operational Safety,Maint Operation,Ie Bulletins & Generic Ltrs,Ler Followup & Licensing Actions

ML20133M882
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/08/1985
From:	Boyd D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133M869	List: IR 05000155/1985011 ML20133M867
References
50-155-85-11, GL-84-11, IEB-83-02, IEB-83-2, NUDOCS 8508130300
Download: ML20133M882 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

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  . REGION III Report'No. 50-155/85011(DRP)

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 Plant

' Inspection At: Charlevoix, MI 49720 Inspection Conducted: June 11, 1985 through July 29, 1985 Inspector: S. Guthri l Approved B : D. C. Boyd, Chiev  [/[ [[

Projects Section 18 Date ' Inspection Summary Inspection on June 11, 1985 - July 29, 1985 (Report No. 50-155/85011(DRP)) Areas Inspected: Routine, unannounced inspection of licensee actions on previous inspection findings, operational ~ safety, maintenance operation, IE ' Bulletins and Generic Letters, licensee event report followup, licensing actions, and spent fuel pool activities. The inspection involved a total of 169 inspector-hours by one NRC inspecto Results: Of the ten areas inspected, no violations or deviations were identifie No significant safety items were identifie PDR ADOCK 05000155 G PDR

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i-DETAILS ! 1. Persons Contacted D. Hoffman, Plant Superintendent

* Pettijean, Technical Superintendent G. Withrow, Maintenance Superintendent
*R. Alexander, Technical Engineer A. Sevener, Operations Superintendent R. Abel, Operations and Maintenance Superintendent
*L. Monshor, Quality Assurance Superintendent R. Barnhart, Senior Quality Assurance Administrator P. Donnelly, Senior Review Supervisor, Nuclear Activities Department J. Lovell, Quality Control Supervisor E. McNamara, Shift Supervisor W. Blissett, Shift Supervisor D. Swem, General Engineer G. Sonnenberg, Shift Supervisor D. Staton, Shift Supervisor
*R. DeWitt, Vice President, CPC0
*J. Beer, Chem / Health Physics Superintendent
*W. Blosh, Acting Maintenance Superintendent
*W. Trubilowicz, Acting Operations Superintendent The inspector also contacted other licensee personnel in the Operations, Maintenance, Radiation Protection and Technical Department * Denotes those present at exit intervie . Licensee Action on Previous Inspection Findings (Closed) Open Item (155/82017-01), Evaluation of use of silicon oil in Barton water level transmitter reference leg. The licensee completed the modification to use silicon oil in the reference leg in the installed transmitter and in the spare transmitte (Closed) Open Item (155/84011-01), Conversion to Scott Air Pak The licensee has completed the conversion to portable Scott Air Pak The cascade system for the control room, at the close of the inspection period, was being modified to adapt the Scott system. Training of all site personnel has been complete Newly hired personnel will receive training as part of regular fire trainin (Closed) Open Item (84013-01), Acoustic Monitor procedural changes. The licensee modified 0TGS-1, Master Check-Off Sheet, to include a verification that all six channels are operable prior to startup, and modified Standard Operating Procedure (SOP) 29 to require monitor operability at all power level (Closed) Violation, Severity Level 4,(155/84017-01), Failure to perform RDS valve surveillance. The licensee has completed their review of the occurrence. No specific corrective action is require '
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(Closed) Violation, Severity Level 4,(155/84017-02), Failure to notify NRC of required shutdow No specific corrective action is require . Operational Safety Verification
'The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the inspection period. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the containment sphere and turbine building 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 ebservation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the inspection period, the inspector walked down the accessible portions of the Liquid Poison, Emergency Condenser, Reactor Depressurization, Post Incident, Core Spray and Containment Spray systems to verify operabilit On May 24 routine sampling of the secondary water in the Emergency Condenser's shell side indicated a small primary to secondary lea Loop No. 2 was removed from service and secondary water sampling was conducted every two days until, on June 11, the declining level of the Xenon 133 isotope confirmed the leak in Loop No. 2 was isolate Normal monthly samples of shell side water show no detectable level of Xenon, while the May 24 sample indicated a level of 1.1 x 10 4 pCi/m After isolation of Loop No. 2, Xenon level was 2.3 x 10 6 pCi/ml. This low level is not detectable at the emergency condenser vent monitor installed at the containment penetration, and is well below the limits of 10 CFR 20, Appendix B. Technical Specifications require both emergency condenser tube bundles to be operable prior to heating the plant for power operation, but permit operation with one leaking tube bundle isolated until the next outag Each tube bundle provides 100%

design heat removal capacity. The licensee, by an Operations Memorandum issued to operators on June 13, directed that the control switch for the isolated loop be placed in the " pull to stop" position and that this loop should only be used if Loop No. 1 failed to operate in an emergency. The inspector verified that removing the switch from the " pull to lock" position is the only operator action necessary to return Loop No. 1 to full operability, and that this action can be accomplished promptly from the control room. The licensee verified the operability of Loop No. 1 isolation valves prior to isolation of Loop No. On June 25 the inspector, after gaining concurrence of Region III and NRR, informed the licensee that if the unit tripped or experienced an l unscheduled forced outage they had the option of returning to power by unisolating Loop No. 2 for the estimated six hour period required by l l Technical Specifications. The leaking loop would then be reisolated ,

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as a conservative measur This interpretation of Technical Specific-l ations:was based on the anticipated difficulty of locating the very ' J small leak,-estimated to be'less than 0.1 gpm. A leak rate of this magnitude is too~small~to accurately calculate and offers little l

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  . likelihood of approaching the total leakage. limit of Technical Specific-
  'ations or the limits for Xenon 133 concentration in air above natural '

background levels as specified in 10 CFR 20, Appendix 8. The licensee is. preparing for use special. leak detection equipment. Repair will involve partial disassembly of the condenser, and is being scheduled for the upcoming refueling outag .b .- On June 20'the public. warning system serving the area surrounding the Big Rock site was removed from service while system controls were

relocated within the Charlevoix County Sheriff's office. The inspector verified that the licensee made the appropriate notifications. The system was returned to service in approximately three hour ~0n July 2 the inspector discussed with the licensee his concerns over '

access to and radiological posting of the Radwaste Storage Building, located adjacent to the protected area and surrounded by a separate E fenc The inspector, during a routine tour of the building while l licensee personnel had the gate and building open for maintenance activities, was able to enter the building and move about without being observed.by workers engaged in work activities in one corne The inspector pointed out that it was possible to enter the licensee's

  ; property by following shoreline routes not constantly monitored by security personnel and that the gate being normally open while work was being performed within presented a situation where a member of the ,

public could gain unobserved access to the building. Dose rates within the building vary from zero to 800 Mr/hr contact, and normal

  . contamination levels vary from zero to 1000-5000 dpm in the packaging area. The licensee agreed to shut the gate and leave it unlocked when the building was occupied.

!~ The licensee has one posting for the radwaste building, located at the

  . personne1' access-door. The building is not partitioned except for

, walls separating the packaging area. The building has three general ! areas: the shielded vault where high level radioactive waste is stored awaiting transportation; the packaging area where low level radioactive ! waste -is packed into barrels for shipment; and, a general area where ! radioactive material is stored for the packaging operation or shipmen When the stored contents necessitate, a high radiation area with roped I boundaries is established. Otherwise, a person is free to move about the building. The posting notice describes the range of general fields t and typically notes contamination levels and areas of high exposure rates. The inspector expressed his concern to the licensee that the , section of the posting notice that specifies protective and anticontamin-ation. dress requirements is highly generalized and does not provide a j- worker with specific requirements for the area or activity in which L he/she is enp ge For example, the posted requirements on July 15 , called for workers to wear cloth gloves and coveralls. As posted, this requiremer t would be in effect for all activities in the building.

! In practice, coveralls are only required in certain portions of the I r i

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building; thus, posted requirements are subject to interpretation by each worker. The licensee elected to require a rad-chem technician be present in the radwaste building when any employee is engaged in work in the building. The licensee normally issues a key to an employee who has received radiation worker training. The conservative decision to require rad-chem technician presence is in part in response to an unusually high level of radwaste building work activity associated with the fuel pool cleaning effort and the relatively high dose rates present from some of the waste now stored there. The new requirement was communicated to rad-chem technicians verbally on July 22 and is subject to review when use of the radwaste building returns to former level d. During the inspection period the inspector monitored the progress of construction on the remote shutdown building. At the close of the inspection period foundation work was being complete Conduit installation continued, including the penetrations to the control roo When the penetrations in the control room wall were open the licensee conducted hourly fire watche Vendor delays have caused the project some minor schedular setback Cable penetrations previously installed in the equipment lock are having their flange faces replaced to correct a design error, an action not expected to delay the projec e. During the previous inspection period the inspector registered concerns over the addition of several functions to the responsibilities of the site Quality Assurance (QA) group without a corresponding increase in QA manpower availability. During the inspection period the licensee transferred from site QA to an offsite group the lead for fuels procurement and inspection. The site QA staff will continue to be involved as a team member on fuels inspections. The entire issue of QA workload vs. manpower is addressed in a special report by a Regional QA specialist, Report No. 50-155/8501 f. On July 13 at 11:50 a.m. the licensee discovered that all emergency notification system (ENS) telephones were not operable and that all normal commercial lines were inoperable outside the local exchang The licensee later determined that the phone outage was caused by cables accidentally severed by Michigan Bell workmen. The licensee used radio communications with Grand Rapids, and dispatched an auxiliary operator by truck to inform licensee management at hom At 12:56 p.m. the Shift Supervisor declared an unusual event because of loss of ENS phones. An unusual event is the least serious of the four emergency classifications specified by the Site Emergency Pla The inspector noted that while notification of NRC headquarters (via radio to Grand Rapids) of the loss of phones is appropriate, the guidance provided by the Site Emergency Plan does not call for the unusual event declaration. The inspector discussed with the licensee previous examples of difficulty in determining emergency classification The licensee is reviewing the adequacy of guidance provided to the Shift Supervisors and evaluating the need to provide additional training in event classification and interpretation of requirements of 10 CFR 50.7 l

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.. On July 26 the inspector observed the licensee's hands on fire training, involving the use of hoses and extinguishers to control actual flame During the inspection period the inspector reviewed the licensee's deletion of fifteen Nuclear Operations Department Standards (N0DS).

The licensee stated their intention to incorporate the contents of each deleted N0DS into the appropriate Big Rock administrative procedure or other document. The N0DS are the vehicle by which Topical Report CPC-2A, Quality Assurance Program Description for Operational Nuclear Power Plants, is implemented and provide a means by which the licensee staff can be assured that the requirements of the various codes and regulations are compiled in one location. The inspector identified the following concerns with the deletion of the fifteen N0D Deleting the N0DS before the requirements contained therein are incorporated into other. appropriate procedures or documents creates the likelihood that those requirements may be los Transferring all the requirements to other procedures prior to N0DS deletion would likely insure all requirements remain in forc During the interval between N0DS deletion and incorporation of the N0DS's requirements into other procedures those requirements are not available to the licensee staff except by returning to and thoroughly researching code and regulatory source document The licensee has not identified a deadline by which all the requirements of each deleted N0D will be addressed by other procedures. The licensee intends to incorporate the requirements whenever a procedure is reviewed for other reasons, or during the biennial review of each procedure. This means that the require-ments-formerly contained in the N0DS could go unaddressed for up to two years. This enhances the opportunity for engineers, who formerly could use the N0DS as a resource document to ensure all applicable QA requirements had been included in their project, to overlook QA requirement Through discussions with licensee management and staff the inspector recognizes the difficulty the licensee has experienced in getting the engineer who generates a document to identify and to include all the applicable codes and regulatory requirements. The licensee has identified as a goal the reduction of on-site QA time spent in procedure review by upgrading the QA knowledge of the procedure's author. Presently the QA staff often departs from its official review function and is relied upon to identify for the author all applicable QA requirement Although the procedural and biennial reviews that are to be relied upon for verifying that all the requirements of the deleted N0DS are incorporated into administrative procedures are conducted by the site engineering staff, that review is in turn reviewed by the site QA staff. Thus, the QA review will be the safety net to insure all the requirements are identified and included. By expecting the QA department, in practice, to be responsible for

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. ensuring all the requirements of a deleted N0DS get included in procedures during the QA review, the QA staff departs from their stated function of review of and concurrence in administrative procedures for compliance with QA program requirement Section 2.2.5 of CPC-2A states that NODS are used for " implementing the provisions" of the Quality Assurance Program Description (CPC-2A).

It further states that the methods for implementing QA program controls are integrated into the N0D While CPC-2A is not affected directly, the ability to implement CPC-2A is likely affected by the N0DS deletio These and other concerns are the subject of a special inspection by a Region III QA Specialist. (50-155/85010) , No violations or deviations were identified in this are . Monthly Maintenance Observation Station maintenance activities of safety related systems and component listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc On June 27, the unit was lowered in power to approximately 15 MWe to repair a packing leak on VHS-265, Steam Drum Level Element Drain isolation valve. The packing leak had caused an indicated difference , between cast and west steam drum level of 5 - 7 in. While power was reduced maintenance personnel verified zero leakage on No. 2 ' recirculation pump seal replaced in May 198 On July 11 the licensee again reduced power to approximately 7 MWe to repair VNS-265 after the packing leak resumed. The packing gland was sealed with a chemical solution intended to prevent leakage until the valve can be replaced during the upcoming outag The unit returned to full power operatio .

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r O On July 19 a gradually increasing temperature in piping downstream of the "C" Target Rock RDS depressurization valve (SV-4986) caused the licensee to close the "C" bypass valve, RDS-1010. Normally, the piping between the Target Rock Valve and the isolation valve (CV-4182) upstream is pressurized via RDS-101C, and closing RDS-101C reduces that pressure to minimize leakage. Regularly recurring problems with Target Rock leakage have resulted from pilot valve erosion, but the licensee's evaluation indicates that this leakage is through the valve's main seat, which is known to be cracked. The valve is due to be removed from the system during the upcoming outage and shipped to a vendor laboratory for overhaul and testin No violations or deviations were identified in this this are . Generic Letters and Bulletins (Closed) IE Bulletin 83002, " Stress Corrosion Cracking in large Drameter Stainless Steel Recirculation System Piping at BWR Plants." During the inspection period the inspector confirmed that the action requirements of the Bulletin had been met. The inspector reviewed the licensee's plans to perform IGSCC inspections on 18 welds during the 1985 refueling outag The inspections are to be performed by a vendor using qualified inspector During the inspection period the licensee was informed by NRR that their proposal to perform IGSCC inspections on 18 welds satisfied the requirements of Generic Letter 84-1 No violations or deviations were identified in this are . Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (Closed) LER 85-005, " Reaction Depressurization System Constant Support Hanger Found Improperly Tensioned". This event is described in detail in Report No. 50-155/85007(DRP), Section . Licensing Activities During the week of July 8 the inspector participated in a series of training sessions and meetings designed to familiarize the new NRR Licensing Project Manager (LPM), Mr. T. Rotella, with the Big Rock facilit During the sessions the parties reviewed currently outstanding Technical Specifications Changes and Exemption Requests, and reviewed the details of the highest ranked Living Schedule issue On July 11 the LPM was joined by Mr. J. Zwolinski, Chief, Operating Reactors Branch No. 5, Division of Licensing. The visitors toured the facility and discussed the progress of regulatory issues of interest to the licensee. Both of the visitors stressed to the licensee the

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L nead for comprehensiva and thoroughly documented submittals to NRR to O ensure prompt resolutio On July 12 the inspector accompanied Messrs. Rotella and Zwolinski to f Region III offices in Glen Ellyn for a series of meetings dealing with - licensing issues and program definition, s On July 1 the NRC issued Amendment 76 to Operating Licensee DPR- This amendment modifies Technical Specifications (TS) to reflect the - licensee's corporate reorganizatio E On July 17 the NRC exempted the licensee from the requirements of : 10 CFR 50.44 (c)(3)(iii) that require the installation of high point vents on the reactor coolant system if the accumulation of = noncondensible gases would cause the loss of function of any system L required to maintain adequate core cooling. The Reactor  :- Depressurization System (RDS) is the path by which all noncondensibles - would be vented from the reactor vessel and reactor coolant syste . The high point vent requirements of NUREG 0737, Item II.B.1, were addressed by this actio By letter dated June 10, the NRC issued Amendment 75 to Operating Licensee DPR-6. This amendment incorporates new Technical Specifications (TS) that address the stack gas monitoring syste r

       By letter dated June 13, NRR accepted the licensee's evaluation of coatings used within containment that qualified those coatings for j accident conditions. The licensee committed to a coating inspection ?

program. These actions resolved Section 4.19.1 of the facility's j integrated assessment (NUREG-0828).

n By letter dated June 7 the NRC issued Amendment 74 to Operating Licensee e DPR-6. This amenament modifies Technical Specifications to include

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the recently modified Reactor Enclosure Treated Waste Line Isolation 2 Valve, CV-4049, in the list of automatic containment isolation valves 3 to be leak rate teste , Spent Fuel Pool Activities N d - On June 18-19 the inspector observed maintenance activities in the spent - fuel pool in preparation for a pool cleaning project. Preparation included =

relocation of spent fuel bundles and control rods, movement of racks, and 7 replacement of the metal pad placed beneath newly installed racks to prevent galvanic corrosio j During the remainder of the inspection period the inspector monitored the k activities of contractor personnel working in the spent fuel pool area to -

package for disposal 79 old channels, source cans, orifices, incores, and i miscellaneous hardware accumulated over the life of the facility. The .f project has been hampered by crusher equipment malfunctions and packaging  ; difficulties. At the close of the inspection period the licensee terminated = work activities and will resume the project following the 1985 refueling i outag i

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il d During the inspection period the inspector completed the requirements of Temporary Instruction 2515/67, Survey of Licensee's Response to Selected Safety Issues. The inspector reviewed procedures and training intended to reduce incidents of mispositioned control rods. The inspector noted in his response that Big Rock does not have a Rod Worth Minimizer, Rod Sequence Control System, or any electronic or mechanical means of preventing control rod mispositioning. Accuracy of rod position at Big Rock relies on administrative controls and operator attentiveness. The inspector noted that there have been two recent incidents when inadequate administrative control and/or operator inattentiveness have resulted in rods being mispositione These two occurrences are detailed in Reports No. 50-155/85002(DRP) and No. 50-155/85007(DRP).

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. No new open items were

/ disclosed during the inspectio . Exit Interview The' inspector met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection period and

~ summarized the scope and findings of the inspection activities. The licensee acknowledged these findings. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents or processes as proprietar .

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