IR 05000155/1990002

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Insp Rept 50-155/90-02 on 900101-0205.Violation Noted.Major Areas Inspected:Mgt Meetings,Qa Program Implementation, Surveillance Activities & Maint Activities on Various Components & Operational Safety Verification
ML20034C447
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 03/07/1990
From: Defayette R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20034C444 List:
References
50-155-90-02, IEB-87-002, NUDOCS 9005030282
Download: ML20034C447 (10)


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U.S. NUCLEAR EGULATORY COMMISSION

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REGION 111

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Report No. 50-155/90002(DRP)

Docket No. 50-155 License No. OPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:

Big Rock Point Nuclear Plant Inspection At:

Charlevoix, Michigan Insuection Conducted: January 1 through February 5,1990 Inspectors:

E.A. Plettner N.R. Williamsen

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Approved By:

R. W. DeFayette, hief,

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Reactor Projects Section 28 Date Inspection Sumnary

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Inspection on January 1 through February 5,1990 (Report No.

50-155/90002(DRP))

Areas Inspected:

the senior resident inspector and the resident inspector.The inspection was rout j

inspected consisted of the following:

The functional areas t

management nmetings; quality assurance-j program implementation; surveillance activities; maintenance activities on.

i various components; operational safety verification which included the control-rod drive system; follow-up en Licensee Event Reports dealing with source range monitor problems, inservice inspection program problems, and an informational Licensee Event Report dealing with Kerotest valves; and temporary instructions dealing with fastener problems identified in NRC Bulletin 87 02 and with i

Fi tness-for-Duty training.

Results:

The licensee has responded in a timely manner to issues and concerns presented to it by the NRC.

The quality assurance, surveillance, and maintenance programs appeared to be performed in a manner to ensure public health and safety.

'Oris41olation concerningragadiologicahworkepermit'and one a

unresolved item in regards to the timeliness in-conducting the Fitness-for-Duty.

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training were identified in the operational safety program.

.i Licensee Event Reports were reviewed and corrective actions were found to ensure safety.

informational Licensee Event Report required no corrective actions.

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The temporary instructions inspection verified that corrective actions had been j

taken by the licensee.

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900503028-2 900307 ADOCK0500g5 PDR j

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DETAILS 1,

Persons Contacted

  • T. Elward, Plant Manager L. Monshor,. Quality Assurance Superintendent

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  • H. Hoffman, Maintenance Superintendent R. Garrett, Chemistry / Health Physics Supervisor
  • W. Trubilowicz, Operations Supervisor
  • G. Withrow, Plant Engineering Superintendent'
  • R. Alexander, Technical Engineer
  • E. Zienert,' Director Human Resources
  • P. Donnelly, Nuclear Assurance Administrator

"R. Krchmar,' Acting Quality Assurance Superintendent-J. Beer, Chemistry / Health-Physics Superintendent

  • R. Burdette. Senior Health physicist

"T. Pence, Senior Nuclear Instructor W. Beckman, Plant Manager effective 2/1/90 The inspectors also contacted other licensee personnel in the Operations, Maintenance, Engineering, Radiation Protection, and Technical l

Departments.

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  • Denotes those present at tne exit interview on February 5,1990.

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Management (30703)

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-f On January 3, Bir, Rock Point announced management changes that resulted from the early retirement program implemented by Consumers Power Company, lhe following changes were made effective 1/4/90:.(1) The

. production / performance superintendent position-was eliminated and the-j

tasks of that position were divided between two other positions:

the operations tasks were assigned to the operations department (formerly f

headed by the operations supervisor, but now upgraded to the operations j

superintendent), and the performance engineering tasks were assigned to

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the engineering department, (2) The electrical / instrument and controls engineering supervisor and two maintenance supervisors retired and tne

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i positions were filled by promotions within the company. Appropriate-changes to the technical specifications are being addressed by the

licensee.

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On January 5, the senior resident inspector met wi th D. W. Joos, Vice-President, Energy Supply replacing R. J. Nicholson; G. L. Heins,.

Senior Vice-President Energy Supply; and F. W. Buckman, President-Consumers Power Company, to discuss the impact of the early retirement program on plant operations. Material presented by the licensee at the j

senior management meeting held on the site on December 5, 1989, was

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discussed, in particular the performance of the Field Maintenance i

Services Division. The recent implementation of the Fitness-for-Duty rule was discussed.

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K On January' 29, D.' P. Hof fman, Vice President Nuclear Operations Department,

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announced a new plant manager for Big Rock Point.

Effective on February 1,

Mr. William Beckman, formerly the Radiological Services Manager'of y

Palisades Nuclear Plant, replaced the current Plant Manager, Mr. T. Elward,

.who was promoted to Vice-President of CMS Generation.

On February 2, the resident inspectors met with Mr. Beckman to discuss plant issues.

3.

Evaluation of Licensee Quality Assurance Program-Implementation (35502)

The inspection was performed to evaluate the effectiveness of the licensee's implementation of its quality assurance program and to determine, based on this evaluation,. whether a follow-up regional inspection is warranted.

The onsite QA/QC Group, ~ the Offsite Nuclear Assurance Group, and the Corrective. Action Review Board evaluation was performed and documented in a previous Inspection Report No. (155/89019(DRP)),

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Licensee Trending System The licensee has a trending system which provides licensee management with su'mmary data that indicates the performance of the plant and plant organization in key safety and reliability areas.

Additional inquiry and management involvement was taken when the-report data indicated potential problems or adverse trends.

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licensee instituted a program called "BRP Operations Closecut" to

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resolve all open Event Reports (ER) and Deviation Reports (OR) older than January 1,1989, by December 31, 1989, Special approval from the Vice-President of Nuclear Operations would be required to leave an item open. Three out of 57. items-were approved to remain open at

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the end of 1989. The Senior Resident Inspector reviewed the closea EP/ ors and did not notice any decrease in the quality of work performed by the licensee. -This improvement by management has j

decreased the average duration of ER/0Ps to six months for 1989, from eight months in 1988, thus resulting-in more -timely resolution

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b.

Enhanced Performance Incentive Program-

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The enhanced performance incentive program is a program to reduce

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l the number of QA inspection hours where high performance has been Its purpose is to assist _in allocating resources of QA

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personnel in problem areas.

It was implemented in 1988 on a trial basis and the 1 & C department was the only plant group placed in the r

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program because of its prior outstanding performance.

The I & C'was removed f rom the program in 1989 because of a violation involving I & C procedures,

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Inspection planning!

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The licensee madel two significant changes'inLits:'1989

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t inspection efforts.

The: first change was to:increaseithe.

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A number of hours spent,on! performance-based inspections. -In -

1989; 1718 more hours were spent. on: the activi_tyy than' in -1988.

j The second change was to decrease the totalEnumber of. hours-

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spent :on:all.QA/QC activities,' ;In-1989; 1256: fewer. total hours-

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were _ spent; than-in-1988.

The senior residenteinspector :

conducted a review of QA/QC activities /and ~ verified that.

requirements 1for;QA/QC activities were met..Therefore,'the'

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increase in performance-based ins'pectionslappears to allow?

QA/QC to accomplish itsifunctions,with less totalLinspection.

s hours per year.

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Licensee-Actions on SAlp' Reports and-Inspection Findings

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p The licensee has continued 'to taggressively pursue. resolutions to--

issues. The -licensee:made _two: presentations to Region' III; senior.

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management on-SALP issues in 1989.. It has responded in a timely-manner to address notices'of violations and unresolved issues.

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l ei Members of the engineering ; department made' a _ special: trip.to l

Region-III to discuss Integrated Leak Rate! issues. in:1989.

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Based on the: evaluations. documented in Inspection Repor.t:(155/89019(ORp))'

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and on those items discussed above, no follow-up regional? inspection is.

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warranted.

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v No violations or deviations were' identified in this. area.

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4.

Monthly Surveillance Observation'(61726)

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Station surveillance activities listed below were observed to verify;that

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the activities were-conducted in accordance with?the Technical.

Specifications andl surveillance procedures. ' Thet applicable procedures

were reviewed for adequacy, test and. process instrumentation was.~ verified,

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to be in their current cycle of calibration,' personnel performing the

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tests appeared to be qualified, and test data wascreviewed for? accuracy-and completeness, The-'NRC inspectors ascertained that any deficiencies identified were reviewsd and resolved.

The NRC-inspectors observed the

licensee's performance of the-following surveillance tests :on the -

indicated dates:

January 2:

T7-21,." Standby Diesel Generator Start and Run Thst ? -

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Revision 16, March 16, 1988,

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with Procedure Change Form,: dated l January 2; i

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January 2:

T7-18, " Bypass Valve Test," Revision 12, December 8. 1989.

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January 2:

T30-01, " Monthly Reactor protection System Test at Power,"

Revision 13, February 17, 1989.

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January 5, 7:

T180-018, " personnel and Equipment Lock Leak Rate Test,"

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Revision 38, May 24, 1989.

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h January 7: T7-03, " Control Rod Coupling Integrity Test at Power,"

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Revision 16, October 20, 1989.

No violations or deviations were identified in this area.

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Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components 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 Specifications.

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 certified;.and radiological and fire prevention controls were implemented.

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Work requests were' reviewed to determine status.of outstanding jobs and to assure that priority was assigned to safety related equipment maintenance which may affect system performance.

The NRC inspectors observed the licensee's performance _of the following maintenance work orders on the indicated areas.

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January 2:

No. 90-CRD-0001, dated January 2,1990, to repair Control Rod Drive Pump No. 2.

January 4:

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No. 90-CRD-0002, dated January 4,1990, for rebuilding the Control Rod Drive Selector Valve for Drive F-4, in conjunction with Procedure MCRD-10, " Control Rod Drive Selector Valve Repair," Revision 3, June 14, 1989. After the repair Surveillance T30-03, " Monthly Drive Selector Valve Reduced Pressure Test," Revision 11, October 20, 1989, was successfully performed.

I January 5:

No. 90-NMS-0003, dated January 5, 1990, to-repair Channel Number 3 wide range neutron monitor recorder.

January 10:

No. 90-FWS-0003, dated January 9, 1990, to clean the air-nozzles in the pneumatic instruments that regulate feedwater flow.

January 12:

No. 90-PIS-0003, dated January 11, 1990, to replace a containment water level transmitter.

January 16:

No. 90-RWS-0005, dated January 15, 1990, for emptying the fuel pool sock cask.

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No violations or deviations were identified in this area.

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6.

Operation Safety Verification (71707)

The NRC inspectors observa control room operations, reviewed applicable logs, and conducted discussions with control room operators during the inspection period.

Instrumentation and recorder traces were examined for t

abnormalities and discussed with the control room operators, as was the status of control room annunciators.

Reviews were conducteo to confirm that the required leak rate calculations were performed and were withiri Technical Specification limits.

It was observed that the Plant Manager, the Production and Performance Superintendent, and the Operations Supervisor were well informed on the overall status of the plant, making visits to the control room and touring the plant.

Supervisors were well informed on the overall status of the plant, and they made frequent visits to the control room and regularly toured the plant. A system walkdown was performed to verify the operability of the Control Rod Drive system.

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 maintenanca requests had been initiated for equipment in need of maintenance.

Radiation protection controls were inspected, including Radiation Work y

Permits, calibration of radiation detectors, and proper posting and

observance of radiation and/or contaminated areas.

The inspectors observed site security measures including access control of personnel and vehicles, proper display of identification badges for personnel within the protected area, and compensatory measures when security eqtipment had a failure or impairment.

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The NRC inspector accompanied two separate Auxiliary Operators on their tours to observe them in the performance of their duties. The operators

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appeared to be knowledgeable and competent.

On January 4, the senior resident inspector noted that two individuals failed to complete all required entries on the Radiation Work Permit Entry log Sheet (Form BRP051).

Section 5.0.c of Administrative procedure Volume 1, Procedure 5.5, " Radiation Work Permit" Rev. 2, dated July 21, 1988, states in part, "All attachments to the radiation work. permit are considered a part of the radiation work permit and require compliance."

This is identical to the same problem discovered during the 1989 refueling and maintenance outage that resulted in a Severity level V violation documented in Inspection Report (155/89013(DRP)).

Corrective actions for the 1939 violation were to be completed by December 31, 1989.

The corrective actions appear to be inef fective.

The failure to comply with the Radiation Work Permit procedure is an apparent violation (155/9000?-01(DRP)).

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On January 17, at 10:35 a.m. (EST) the licensee declared an Unusual Event as specified in the Emergency Plan Implementing Procedures EPIP-1, for release of flammable gas / liquid.

The event occurred when the relief valve on an unenclosed 250 gallow propane storage tank located within the protected area lifted because of increased pressure.

The tank had been filled in December 1989, when the temperature was.near zero.

On January 17, the temperature had increased to over 40 degrees.

The higher temperature, coupled with the new full tank level, resulted in a pressure

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increase sufficient to lift the relief valve. A representative from the

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propane verdor compa'ny arrived on site and discharged propane from the tank, first liquid and then vapor, until there was a sufficient vapor i

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space at t6e top of the t:nk to safely s.'ppcrt ner.ul operations. A licensee health physics / chemistry technician with appropriate i

i instrume-nts monitored the released of the propane. Areas and buildings downwind from the propane tank were monitored to verify safety and habitability.. The licensee started and ran the equipment which used

propane from the tank to increase the safety margin. No personnel or

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equipment were endangered. All notifications were made in a timely

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manner. At 3 p.m. the licensee terminated the Unusual Event.

The resident inspectors observed the actions of the licensee during the i

event.

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On January 3,1990, while reviewing TI 2515/104, the senior resident I

inspector noted that two supervisors who had occupied the position for

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more than a year had not completed Fitness-for-Duty training for supervisors. One of the individuals was a Shift Supervisor.

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i concern was immediately brought to the attention of the-licensee and Region III. Af ter several discussions, the licensee took action to train

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the two individuals on January 5,1990.

Both-individuals passed the training, item of note. was the Shif t Supervisor had not been on duty between January 3 and his training on January 5,,1990.

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A letter dated December 19, 1989, from the licensee to the NRC certified I

that the Fitness-for-Duty program would be fully implemented by

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January 3,1990, for both Big Rock Point and palisades plants;

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10 CFR Part 26.22c states " Initial tra'ining must be completed prior to i

assignment of duties within the scope of this part and within three months af ter initial supervisory assignment, as applicable."

This apparent violation wi,11 be tracked as an unresolved item pending r

further review by the NRC.

(155/90002-02(ORP)).

One violation and one unresolved item were identified in this area.

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._ Licensee Event Reports Followup (92700)

Through direct observations, discussions with licensee personnel, and

review of records, the following event reports:were reviewed to determine

,t that reportability requirements were fulfilled, timely immediate,

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corrective action was accomplished, and corrective action to prevent i

recurrence had been accomplished in accordance with Technical Specifications.

In addition, the event was evaluated for previous

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similar events, root cause, and potential generic applicability.

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(Closed) LER-155/88006:

Technical Specification Violation".." Source Range Monitor Anomaly,Resulting in

The Big Rock Point Technical.

Specifications (TS) Section 6.2.1 requires that an -interlock should prevent control rod withdrawal when any one of three power range monitors indicates less than 1 x 10 ' percent power when the reactor power is i

above the operating range of the Source Range Monitors (SRMs).

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the 1988 refueling / maintenance outage, a new wide (power) range deuctor-t system was installed and satisfactorily tested.

The instrumentation

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performed as intended during the initial start up from the refueling /eaintenance outage. The lic(nsee raised reactor power to approximately 45 percent to conduct required tests.. During the performance of these tests, the licensee observed that the control rod withdrawal interlock was disabled resulting in the TS violation. Upon discovery, the licensee administrative 1y stopped all rod withdrawals and proceeded to correct the problem.

The control rod withdrawal interlock was inoperable for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. However, it was not required to perform its intended function during that time frame because reactor power was several decades above the required 1 x 10 * percent power resulting in a minimum impact on safety. -Root cause of the problem was the sensitivity. of the source range monitor channels. Tempora ry corrective action was taken to return the control rod withdrawal interlock to operational mode. The long term corrective actions were completed during the 1989 refueling / maintenance outage as documented in Specification Change, SC-88-038, and testing was completed on July 8, 1989. The instrumentation performed as intended during the initial start up from the 1989 refueling / maintenance outage and during the required tests at approximately 45 percent reactor power.

This-LER is closed.

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(Closed) LER 155/89002:

" Inservice Inspection Program Deficiency -

Technical Specification Violation". On February 3,1989, the licensee reviewed the Inservice Inspection (ISI) ' program in conjunction with a Quality Assurance Audit and discovered that the ASME Section. LWD-2500-1 s

system leak tests required by Technical Specifications had'not been formally completed and documented, nor had specific written relief been

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sent to the NRC.

The root cause of the deficiency was due to an oversight during the development of the 40 Year 151 Plan.

The corrective action plan was to (1) amend the 40 year ISI Plan to include the missing tests, (2) complete the required leak tests during the 1989 refueling / maintenance outage, and (3) perform an independent review of the 40 year 151 plan by December 31, 1989.

Record review verified that (1) the.40 Year.151 plan was properly updated in the " Pressure Testing Examination Scheduling-Table" approved by the Plant Review Lommittee on May 22,1989,(2) the required system leak tests were satisfactorily completed and' documented in the 1989 Inservice Inspection Report dated November 3, 1989, that was sent to the NRC. and (3) the independent review report dated November 14, 1989, found no discrepancies.

This LER is closed.

(Closed) LER 155/89003:

" Informational LER - Damaged Kerotest Valve Purchased from inventory Management Corporation".

The report was written to inform other licensees of a potential problem in purchasing. components from other utilities-or their agents and the need to perform adequate receipt inspection and testing of components.

This.particular case involved a one inch Kerotest Globe-Valve, Model CA-D-%15, which did not pass Big Rock Point receipt inspection.

The valve wat durchased from Inventory Mar.a Power Company.gemer,t Corporation, which was an agent being used by Duke The valve was returned to the manufacturer via Duke Power

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    1. h Interr,al Quality Assurance / Quality Control (,)A/QC) activities would not c.

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have discovered the problem because QA/QC dots not perform-laboratory-analyses on fasteners. which is the only' meals of detection._ Qualified

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QA/QC individuals have performed a. review et the certified material test reports supplied by the vendor. The_ licensee has no plans to change its current mode of internal QA/QC activities.

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The NSR nonconforming fasteners SAE J429 Grade 8 were. removed from stock and sold for scrap.

i (Closed) Temoorary Instruction (TI) 2515/104:: "Fi tness-For-Duty: >

Jnspection of Initial Training Programs." The purpose _of _ the TI was ' for-

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resident inspectors to attend selected licensee Fitness for Outy.(FFD): _ _

i training sessions to determine that required training was being conducted.

3, to implement the program and to provide Reactor Safeguards Branch.-

Division of Reactor Inspection _ and Safeguards, and--the Office of Nuclear,

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Reactor Regulation with information to determine acceptability of general-industry FF0 Program impler.entation.

Part.of_this evaluation was.

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performed and documented in a previous Inspection Report, No. 50-155/S9019(DRP).

i Inspection Findin g i

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The senior resident inspector attended a training session for supervisors conducted by the licensee on January 22, 1989.

The. supervisor training contained the necessary elements to meet the requirements of 10 CFR Part-26.

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Unresolved items

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Unresolved ' items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or

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deviations.

i One unresolved item disclosed during this inspection is-discussed in Paragraph 6.

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10. Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 3)-

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throughout the month and at the conclusion of the inspection period and-summarized the scope and findings of the inspection activities. The

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licensee acknowledged these findings._ The inspectors also discussed the

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likely informational content _ of the inspection report with regard to!

documents or processes reviewed by the inspectors during the inspection ~

The licensee did not identify any such documents or processes'as

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proprieta ry.

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