IR 05000155/1987022

Insp Rept 50-155/87-22 on 870831-1117.One Violation Noted. Major Areas Inspected:Ie Bulletin 85-003, Motor-Operated Valve Failures During Plant Transient Due to Improper Switch Settings, & Inservice Testing Program for Pump & Valves

ML20236U058
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/25/1987
From:	Eick S, Huber M, Phillips M, Wohld P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236U041	List: IR 05000155/1987022 ML20236U039 ML20236U054
References
50-155-87-22, IEB-85-003, IEB-85-3, NUDOCS 8712020253
Download: ML20236U058 (5)

Text

{{#Wiki_filter:..

.
       '

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

I Report No. 50-155/87022(DRS)

       '

Docket No. 50-155 License No. DPR-06 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant Inspection At: Charlevoix, Michigan Inspection Conducted: August 31 through November 17, 1987 Inspectors: P. R. Wohld YW M'2 5" Date M. P. Huber j ', [[ [2 I

     %7 Dath S. D. Eick -
   "' --

a /zs-/s7 Dats  ! Approved By: hief Operational Programs Section

     //[2 r[7  i Date Inspection Summary Inspection on August 31 through November 17, 1987 (Report No. 50-155/87022(DRS))

Areas Inspected: Special safety inspection of the licensee's activities with respect to Inspection and Enforcement Bulletin No. 85-03 " Motor-0perated Valve Failures During Plant Transient Due to Improper Switch Settings," and their

inservice testing program for pump and valves and its implementation (73756).

l ' Results: One violation was identified, Paragraph 3, for failure to take appropriate corrective action in response to deficiencies identified in the l pump and valve inservice test program.

, 8712020253 871125 PDR ADOCK 05000155 G PDR

      - _ - _ _ _ _ -

       ,1
-
,.       j l

DETAILS 'I

-1. Persons Contacted Consumers Power Company (CPCo)
*T. Elward, Plant Manager
+* Acker, ISI Coordinator
+* Alexander, Technical Engineer
*E. Evans, Senior Engineer
*T. Fisher, Senior QA Consultant
*G. Withrow, Engineering and Maintenance Superintendent
+D. Moeggenberg, Mechanical Engineering Supervisor Nuclear Regulatory Commission

, !

       -]

+*S. Guthrie, Senior Resident Inspector
*T. McLellan,'NRR, Mechanical Engineer * Denotes those attending the meeting held on September 4, 198 J
+ Denotes those participating in the exit telephone conference held on
    '

i November 17, 198 'i Additional plant technical and administrative personnel were contacted-during the course of the inspectio .1 2. IE Bulletin Followup l (0 pen) IE Bulletin 85-03: Motor-0perated Valve (MOV) Common Mode Failures During Plant Transients Due to Improper Switch Settings: The bulletin requested licensees to develop and~ implement a program to ensure that switch settings on certain safety-related motor-operated. valves are i selected, set, and maintained correctly to accommodate the maximum ' differential pressures expected on these valves during both normal and abnormal events within the design basis. In their bulletin response .

    ~

dated May 6, 1986, the licensee indicated that the concerns addressed in

       .

, j l the bulletin-did not apply to Big Rock Point because high differential  !

       '

pressures would not occur across motor-operated valves as discussed in the bulletin and because the plant did not utilize high pressure safety systems addressed by the bulletin. However, a review of the plant's safety-related core cooling system (Core Spray) indicated that two MOVs (M0-7061 and MO-7071) may be required to open against full. reactor pressure because of pressure trapped between these and two upstream check valves when the reactor coolant' system is depressurized after an acciden ~f Because of this and other items addremsed in IE Bulletin 85-03, the .

       >

inspector disagrees with the licensee's position that concerns addressed by the bulletin were' not applicable to Big Rock Point. However, the-licensee does appear to be correct in stating that because the Core Spray , system (their only safety-related, safety injection pumping system (with I fire pump backup)) is a low pressure' system, it is technically not subject' to the bulletin as issue j

       ,
       .
       '

t l ! l' ' _ - - - _ _ _ _ _ _ _ _ _ _ _ _

t j

-
,.      4 j

Regardless of the applicability of the bulletin, the licensee indicated .l in their response to NRC.that conservative testing of.the. core spra l injection valves would be performed monthly to assure their operabilit .1 i 'A review of test procedure T30-22, Revision 29, for testing of, motor-operated injection valves M0-7051 and M0-7061'in one line, and M0-7070 and.M0-7071 in the redundant line indicated that the.. test procedure did ! not assure that maximum differential existed.across the valves during testing. . Test changes were discussed that would assure'an adequate test , and the licensee agreed to submit a revised' test procedure to the ;

      '

l- Region III office within the next sixty days and/or to revise the bulletin response to reflect actual testin Testing using the injection valve test procedure was observed'and was noted.to be performed competently and efficiently by plant personnel. By i coincidence, the sequence of back leakages noted through a " telltale" l during testing and the data indicated'by pressure transmitter PT-186' showed that MO-7061 and M0-7071 were actually being tested against full reactor pressure.because of'the relative leakages between the system valves. Hence, the operability of these valves was not a present concer .The other two valves must operate against a much lower pressure but higher than currently existing during testing. The test changes discussed should address this concer The bulletin will remain open until the valve testing issues noted above are resolve _

      ! Pump and Valve Inservice Testing Program Implementation-  l l The licensee's pump and valve inservice teso program implementation was inspected to verify compliance with Appendix B of 10 CFR Part 50; 10 CFR 50.55a(g); and Subsections IWP and IWV.of Section XI of-the American Society of Mechanical Engineers (ASME). Boiler and Pressure Vessel Code (1977 edition with addenda through Summer 1978). The inspection included a review of administrative controls, selected surveillance procedures, test results'and documentation, and observation of the performance of testing under Procedure No. T3-22 (Emergency Core s Cooling System Valve Tests).    !

The licensee had not received approval from the Nuclear Regulatory l Commission for Code testing relief requests as required by 10 CFR 50.55a(g).

However, the requests have not been denied and'the licensee was proceeding with its program, with relief as requested, according to its submittals to i NRC. The inspection was based on Consumers Power Company program submittal dated January 21, 1983, with additional information dated December 22,.198 The inspection determined that administrative controls over the IST program, either proceduralized or by other means, were inadequat The lack of administrative controls resulted in deficiencies in the program's implementation. Specific deficiencies were identified indicating an inadequate IST program:  ;

f

i o

'      i
.

n

(a) Relief requests were not always accompanied by adequate technical d suppor 'i i
(b) Although the licensee was not implementing and did not intend to  j implement Code requirements for pump flow measurement and' bearing :

temperature, no relief had been requested. It is noted'that the- ! licensee'had informed the NRC of their positio (c) While current testing appears to show that two pressure isolation: i boundaries protect low pressure piping'from reactor pressure, the l subject has_not been adequately addressed within the IST progra ~

(d) Post maintenance stroke times, required by the Code, were not entered into the trend books to set new stroke time reference values or to '

evaluate stroke time changes (such as after packing tightening or major rework).

(e) Upper stroke time limits were not specified for a number of valves-as required by the Cod (f) Remote position' indication verification required by the Code had not been adequately addressed in the progra (g) The licensee had indicated in the past that some means would be considered for more comprehensive testing of the reactor coolant system depressurization valves; however, these valves still had never been full-stroke exercise ']

(h) The alert and action ranges for the diesel fire pump test data had  J not been in accord with Code requirement ]

The licensee had identified problems with the IST program during a QA j surveillance reported in March 1987, and while corrective actions planned .j in response to the QA findings would likely have identified and corrected the Code testing deficiencies noted during the inspection, a number of test program deficiencies were not identified and corrective action timeliness was not adequate to identify and resolve these additional- .'l items noted during the inspectio ! Items (d), (e) and (f) are examples of failures to meet testing specified j in Subsections IWP and IWV of Section XI of the ASME' Boiler and Pressure

      '

Vessel Code, 1977 edition with addenda through' Summer 1978. The failure to identify and correct these deficiencies is considered a violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action (155/87022-01(DRS).

l The licensee was cautioned that the inspection was an audit of selected 4 ! activities required by the ASME Code and not a 100% evaluation. Corrective ' actions by the licensee will need to encompass an assessment of all Code 4

' requirements and implementation adequac ,

_-___--_- = _ m

_

        ,
        .s
 '
 ..-       ;

1 Pump Vibration Testing The inspector noted that the' vibration testing; adopted at Big Rock Point- -l generally met minimum Code requirements. However, except for the  ! motor-driven fire pump, comprehensive data collection'and multifrequency .; analysis techniques were.not being performed. The inspector recommended- -i that the licensee consider-improving their program in this area to be more-

 -in line with current vibration monitoring practic No violations or deviations were identifie . Valve Inspection
        !

Because of the plant operating status,.only one valve could practically-be removed from service for inspection. This was a fairly recently , installed valve, M0-7080. Handwheel operation and observation of the l geared limit switch rotors did not indicate;any problems with the' settin I of these switches. One mechanical deficiency was noted in that the limit switch mounting to the main gear case was somewhat 1oose. Otherwise, the

     ~
        'j valve appeared to be in good. condition. The looseness was corrected  ,

immediately by the license ) J No violations or deviations were identifie l Exit Interview i The inspectors met with licensee representatives (denoted in Paragraph 1) i on September 4, 1987, to discuss the scope and interim findings of the 1 inspection. The licensee acknowledged the statements made by the inspectors with respect to items discussed in.the report. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed'by the inspectors during this inspection. The licensee did not identify any such documents / processes as proprietary. Further information was also requested to be evaluated in the Region III office. On November 17,'1987, the inspectors held a conference telephone exit with the licensee representatives denoted in Paragraph 1. The findings of the inspection were presented. . Licensee 1 representatives acknowlec'ged the statements made by the inspectors concerning the violation.

l l

        :

l

_ _ - - _ _ _ _ _ _ _ _ _ - _ - - _ _ - _ - _ _ _ _ _ - _ . _ __ - - _ _ ___ _ _ , }}