IR 05000155/1990022

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Insp Rept 50-155/90-22 on 901016-1126.Violation Noted.Major Areas Inspected:Refueling Activities,Surveillance,Maint, Operational Safety Verification Including Fuel Pool Sys,Cold Weather Preparations & Check Valve Activities
ML20024F902
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/17/1990
From: Defayette R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20024F891 List:
References
50-155-90-22, NUDOCS 9012270123
Download: ML20024F902 (9)


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U.S. flVCLEAR REGULATORY COMf11SS10N REGION 111 Report No. 50-155/90022(DRP)

Docket No. 50-155 License No. DPR-6 Licensee:

Consumers Power Co puny 212 West Mich.gan Avenue Jacks,on, MI 49201 Facility Name:

Big Rock Point Nuclear Plant inspection At:

Charlevoix, Michigan Inspection Conducted: October 16 through November 26, 1990 Inspectors:

E. Plettner D. Jones K. Piemer P. Rodrik Approved By:@R. [% % 6 [ b DEC1? E90 DeFayette, Chief, Reactor Projects Section 2B Date Inspection Summary inspection on October 16 through November 26, 1990 (Report No. 50-15F/90022(DRP))

Areas Inspected:

The inspection was routine, unannounced, and conducted by the Senior Resident Inspector and three regional inspectors. The functional areas inspected consisted of the following: refueling activities; surveillance activities including those required for re#ueling; maintenance activities on various components; operational safety verification including the fuel pool system; cold weather preparations; and a regional request dealing with check valve activities.

Results:

The refueling and surveillence pronrams were implemented in a manner to ensure public health and safety. One violation concerning failure to follow procedures was identified in the maintenance program.

Inattention to detail problems were noted in both the maintenance and operational safety verification programs.

Plant Operations The plant was in an outage during the inspection period.

Inattention to detail problems were observed when a daily reading for the storage battery was omitted.

Refueling operations were conducted without problems.

9012270123 901217 ADOCK 0500

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Radioloaical Controls

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Activities were conducted as required with adequate health physics coverage at various job sites involving radiological concerns. Two failures to initial radiation work permits (RWPs) were observed during

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the inspection period. This is a continuation of the same problem

. documented in prior inspection reports.

t Maintenance / Surveillance Maintenance Department personnel had two rework items during the

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inspection period.

One violation for failure to follow procedures was identified when a circuit breaker was replaced in a wrong location.

In adoition, several inattention to detail problems while performing maintunance activities were also observed.

Surveillance activities were performed correctly and on schedule.

Emeg ency Preparedness m

No events occurred during toe period for assessment of this area.

Security-All security activities observed were performed in a proper and timely manner.

Engineering / Technical Support Daily involvement of the engineering / technical staff in plant activities-was observed.

Safety Assessment / Quality Verification Daily involvement in plant activities was observed and continuous job site coverage was provided by Quality Assurance / Quality Control m

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personnel during the outage, o

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DETAILS 1.

Persons Contacted Consumers Iower Company

+*W. Beckmat, Plant Manager

  • L. Monshor, Quality Assurance Superintendent
  • H. Hoffman, Maintenance Superintendent R. Garrett, Chemistry / Health Physics Supervisor

+*W. Trubiloxicz, Operations Superintendent

  • G. Withrow, Plant _ Engineering Superintendent

.+*R. Alexander, Technical Engineer

  • E. Zienert, Director Human Resources

-*P. Donnelly,-Nuclear Assurance Administrator

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+*J. Beer, Chemistry / Health Physics Superintendent D. Lacroix, Nuclear Training Administrator Nuclear Regulatory Commission

+ B. Clayton, Branch Chief, Division of Reactor Projects

+ R. DeFayette, Section Chief, Division of Reactor Projects

+ B. Drouin, Project Engineer, Division of Reactor Projects

+.M. Kunowski, Inspector, Division of Radiation Safety and Safeguards

+ K. Riemer,. Reactor Er.gineer, Division of Reactor Projects

+ P. Rodrik, Reactor Engineer, Division of Reactor Projects

+ D. Schrum, Reactor Engineer, Division of Reactor Projects The inspector also 'ontacted other licensee personnel in the Operations, Maintenance, Engineering, Radiation Protection, and Technical Departments.

+ Denotes those present at the NRC/ licensee meeting an December 11, 1990._

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'2.

Refueling Activities (60710) (60705)

Preparations for refueling were observed / reviewed to ascertain that the 6ctivities were meeting approved procedures and were in conformance with Technical Specifications.

The Senior Resident Inspector observ(d the fuel reloading conducted during the period of November 13 through November 1/, 1990.

The fuel reloading was performed in a proper and professional manner, using correct and current procedures. Status boards and records of fuel bundle locations were verified to be..in accordance with Procedure TR-46, Attachment 1.

Shutdown margin measurements and physics tests were conducted satisfactorily following fuel reloading using the proper procedures.

No violatiens or deviations were identified in this area.

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3.

Monthly Surveillance Observation (61726)

Station surveillance activities listed below were observed to verify that the activities were conducted in accordance with the Technical Specifications and surveillance procedures.

The applicable pracedures were reviewed for adequacy, test and process instrumentation were verified to be in their current cycle of calibration, personnel performing the tests were qualified, and test data was reviewed for accuracy and completeness.

The NRC inspector ascertained that any deficiencies identified were reviewed and esolved.

The NRC inspector observed the licensee's performance of the following surveillance tests on the indicated dates:

October 16:

T7-24, " Battery Pilot Cell Reading," Revision 12, June 6, 1990.

October 24:

TR-70, " Fire Suppression Water System Functional Test and Pump Capacity Test," Revision 10, May 26, 1989, with Procedure Change Form to use the newly installed flow-meter from Field Change (FC) 663.

The test was conducted by normal plant operations personnel to test the newly installed flow meter.

Additional oversight was provided by the fire safety officer and the engineers involved with the FC-663.

The test was performed satisfactorily and all system parameters met acceptance criteria.

The engineers will perform a review of the data collected to verify the operability of the new flow meter and to make any necessary changes that may he identified during the review process.

No violations or deviations were identified in this area.

4.

Monthiy Maintenance Observation (62703)

Station maintenance activities of safety related systems and components listed below were observed / reviewed ';o ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards and in conformance with Technical Specifications.

The f ollowing items were et nsidered during this review:

the L'onit ing Conditions for Operation were met while components or systems were removed from service; approvals were obtained pr;cr to nitiating the work; activities were accomplished using approved proceduces and were inspected as applicable; functional testing and/or calibraMons were performed prior to returning components or systems to service; quality control records were naintained; activities were accomplished by qualified personnel; parts and materials used were certified; and radiological and fire irevention controls were implemented.

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

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The NRC inspector observed the licensee's performance of the following maintenance work orders on the indicated dates:

October 26:

No. 90-005-0071, dated October 22, 1990, Inspect Check Valve.C~~The check valve was located in the condensate system and had no record of having been inspected in the 30 year history of the plant.

Although the valve was not causing any problems and was in a balance of plant system, for which there are no inspection requirements, the licensee decided to inspect it as a preventative measure.

No excessive wear was noted during the inspection and the valve was reassembled and returned to service. This effort indicated a proactive approach to plant upkeep by the licensee.

November 1:

No. 90-CWS-0009, dated June 28, 1990, " Overhaul Valve Operator," in conjunction with Procedure MGP-27, " Inspection and Repair of SMA-00 Double Torque Limitorque Valve Operators," Revision 1, dated September 18, 1990, and Procedure MGP-2, " Inspection and Setting of Limit Switches on Limitorque Valves," Revision 19, dated December 13, 1989.

The work was con (teted by two contractor. maintenance personnel who specialized in valve operator repairs.

Quality Assurance oversight was provided throughout.the repair process.

November 2: 'No. 89-SPS-0039, " Circuit Breaker Replacement." The job entailed the replacement of a circuit breaker in 52-1A14, screen structure MCC, bus 10, but the breaker actually being replaced was in 52-2A14,-

reactor building power panel No. 2P.

The mistake was discovered by the

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Senior Resident Inspector while reviewing the work order at the job site.

Installation work had essentially been completed when the Senior Resident Inspector discovered the error and made the job site supervisor aware of the discrepancy between the actual breaker installation and the requirements on the maintenance order.

The su)ervisor and Senior. Resident Inspector left the job site area to confer wit 1 the responsible engineer to resolve the issue.

In their absence, the shift supervisor, who had been indirectly made aware of the problem when he received a call that norma _1-lighting had been lost in the sphere, instructed the auxiliary operator to energize the circuit breaker because of personnel safety concerns he had for peo)1e working in the sphere.(normal lighting controlled by that'brea<er had been deenergized). The shift supervisor was especially concerned with the safety of-personnel working on scaffolding in the sphere where the only lighting available was provided

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by emergency lighting.. The rating on the incorrectly installed breaker was higher than the load requirements and no damage to the breaker occurred. Although this information was not known at the time'of reenergization, due to plant conditions -at that particular time in the outage (all fuel off loaded from the core), the shift supervisor knew that there were no major loads on the affected: bus-and that equipment damage was unlikely. After personnel were cleared from danger in the sphere, the

. breaker was removed, the old 52-2A14 breaker reinstalled, and the new breaker installed in 52-1A14.

The cause of the incorrect breaker installation was personnel error and failure to follow procedures.

The auxiliary operator in charge of the work had the proper written instructions; had a piece of paper in his pocket with the breaker number

. clearly marked: and the circuit breakers were clearly and correctly l_

labeled. The licensee's corrective action for the problem included i-

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discipline and time off without pay for the involved individual.

Administrative Procedure 3.2.1, " Maintenance Work Order Processing,"

established the formal requirements for use of Maintenance Orders to l

control work activities.

Procedure 89-SPS-0039 was the formal requirement

for this work.

Failure to follow this procedure is a violation (155/90022-01(DRP)).

l During the inspection aeriod, the inspector observed several cases of

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inattention to detail )y plant personnel. For example, tools were left at a job site and a maintenance tag was found laying on equipment following completion of work. Although there was no safety significance associated with those incidents, they are indicative of a continuing concern with l

inattentiveness. Also, two. rework items occurred during this refueling / maintenance outage; whereas none were observed during the last refueling / maintenance outage.

In one case, the licensee had to reperform a check valve repair to rebend check valve hinge pins.

In another case the licensee had to work control rod drive CG three times before it successfully passed its friction testing.

There also was a poor installation of some instruments in the control room when screws were left out'of covers and electrical compression fittings were not tightened when installation work was performed on recorders.

(It should be noted that the final walkdowns and acceptance signoffs had not been completed iy the responsible licensee engineer for this last example when the inspector brought the findings to the licensee's attentien, and the problem was corrected before it could have any safety impact.) Nevertheless, the actual installation had been completed and should not have been left in the as-found condition.

These examples serve to reinforce the inspector's concern that an attention to detail problem exists at Big Rock Point.

During the outage, the inspector observed that the licensee encountered several problems with its recirculation pump rewire project.

One problem involved several relays in the system that were not physically located in accordance with the electrical-prints. The licensee was evaluating the cause at the end of the inspection period. Anothc' aroblem involved equipment failure when a position switch was discovered to have broken-gears. The third problem was a wire lead that was found to be loose and had to be relanded.

These problems were all discovered and corrected by the-licensee during post-maintenance testing and indicated a successful post-maintenance testing program.

One violation and no deviations were identified in this area.

5.

Operational Safety Verification (71707)

The NRC inspector observed control room operations, reviewed applicable-logs, and cor. ducted discussions with--control room operators during the inspection perlod.

Instrumentation and recorder traces were examined for abnormalities and discussed with the control room operators, as was the status of control room annunciators.

The inspector conducted reviews to confirm that the required leak rate calculations were performed and were

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within Technical Specification limits.

The inspectors observed the Plant Manager and the Operations Superintendent performing plant tours. They also made frequent visits to the control room. The Senior Resident

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Inspector performed a walkdown of the fuel pool system and noted no abnormalities.

The Senior Resident Inspector toured the containment sphere and turbine building 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.

Radiation protection controls were inspected, including Radiation Work 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 site compensatory measures when security equipment had a failure or impairment.

During the inspection period the Senior Resident Inspector noted that two individuals had failed to initial a Radiation Work Permit (RWP) procedure and several individuals had not filled in non-regulatory information blocks. A violation notice on the RWP procedure was documented in the previous inspection report (155/90017-01 (DRP)) issued on November 2, 1990. A second violation will not be issued because there is no significant safety issue and the licensee has not had sufficient time to respond to the previous violation.

It also discussed this issue in a meeting with NRC regional management on December 11, 1990.

At about 8:30 a.m. on November 7, 1990, during routine inspection activities, the Senior Resident Inspector noted that a set of daily readings for the storage battery had not been taken on the midnight shift as was customary. Although the readings were taken daily, the technical specification requirement is that readings be taken monthly.

Because attention to detail continues to be a problem, the issue was taken to the plant manager.

The Senior Resident Inspector returned to the site at 11 p.m. that same day and during his inspection noticed that the readings for November 7 had still not been taken.

The next morning, the Senior Resident Inspector again reviewed the storage battery-chart and discovered that the data for both November 7 and November 8 were filled in and initialed by the same individual.

However, the initials for the November 7 entry were crossed out and another set of initials had been entered.

The-ins 3ector reviewed the security printout sheet and determined that t1e second individual (the one who crossed out the first initials and recorded his own) had been in the building on November 7 at about the time the readings were supposed to have been taken.

The inspector's concerns were with potential falsification of records.

After further discussion with Region III management and licensee management, however, it became apparent that the individual who back-filled the data for November 7 was not sure how he was to treat the missing information when he discovered it and was not familiar with the-licensee's procedure for correcting such errors.

The NRC concluded that no willful wrongdoing was involved. Although no technical specification requirements were missed, it does not negate the fact that operators were inattentive in the performance of their duties.

The licensee discussed i

j this in a meeting with regional NRC management on December 11, 1990.

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6.

Cold Weather Preparations (71714)

This inspection was performed to determine whether the licensee had maintained its ability to effectively implement its program of protective measures for extreme cold weather to which the licensee committed in response to IE Bulletin 79-24.

The Senior Resident Inspector, using Procedure 0-VAS-1, " Cold / Warm Weather Checklists," Revision 5, dated November 15, 1990, performed a walkdown of the iter.s in the cold weather portion of the procedure. The inspector noted no noteworthy items.

The licensee has experienced no problems with freezing in safety related systems for several years.

The program appeared adequate to address cold weather protective measures, l

No violations or deviations were identified in this area.

7.

RegionalRequest(73756]

A regional request dealing with check salve activities was started and documented in Inspection Report 50-155/90012(DRP).

In that report it was

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stated that additional _information would be completed during the 1990

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refueling outage. The following are the additional findings and final conclusions:

During the inspection period the Senior Resident Inspector observed maintenance personnel performing a visual inspection on a 6 inch tilting disk check valve. Maintenance personnel were observed performing-a visual inspection of the internal valve body for degraded conditions.

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Items included in that inspection were the disk and seat, the condition of the hinge pins and other internal parts.

The valve was also checked for appropriate clearances in both the horizontal and vertical directions to ensure no valve degradation had occurred.

The valve was returned to service after appropriate cleaning, installation of new gasht materials

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and satisfactory completion of aost-maintenance testing.

iroblems were noted.

In addition, the Senior Resident Inspector reviewe

've111ance Procedure TR-74 " Inspection of Liquid Poison System Ched s VP-300, VP-301, and VP-302," Revision 12, dated June 6, 1989. The.

<es were tested as required by Big Rock Point Pump and Valve Inspection Program.

The licensee's pump and valve ins)ection program to identify concerns

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associated with check valve opera >ility and reliability in safety related systems appears to be adeqJate.

There are no requirements for such-inspection activities on balance of plant systeu check valves and the licensee is not considering implementing such a program. Also, there are no pla,ns to initiate a specific sampling program for check valves or to implement a trending program to track check valve failures, maintenance, and test results in either safety or balance of plant systems.

8.

Management Meeting Subsequent to the close of the inspection period, on December 11, 1990, a management meeting was held between the licensee and NRC management at Region III offices in Glen Ellyn, Illinois.

The purpose of the meeting was to discuss recent attention to detail problems experienced by the

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The licensee presented a historical perspective of operator l

errors, discussed current operator errors and corrective actions, and

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.e described continuing efforts to alleviate the problem. The licensee also

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presented its proposed actions to enhance attention to detail in the future. NRC management acknowledged the licensee's presentation and corrective actions.

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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 inspection.

The licensee did not identify any such documents or processes as proprietary.

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