IR 05000155/1992017

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-155/92-17

ML20127C855
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/04/1992
From:	Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Beckman W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
EA-92-122, NUDOCS 9209100243
Download: ML20127C855 (3)

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SEP 0 692 Docket No. 50-155 EA 92-122 Consumers Power Company ATTN: William L. Beckman Plant Manager Big Rock Point Nuclear Plant 10269 US 31 North Charlevoix, MI 49720

Dear Mr. Backman:

SUBJECT: NOTICE OF V10l.ATION (NRC INSPECTION REPORT NO. 50-155/92017(DRP))

This will acknowledge receipt of your letter dated- August 20, 1992, in response to our letter dated July 22, 1992, transm-itting a Notice of Violation

] associated with Inspection Report No. 50-155/92017(DRP). We have reviewed j

your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely,

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Edward G. Greenman, Director Division of P.eactor Projects

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Enclosure: Letter dated August 20, 1992 010043 See Attacheci Distribution RIII RIlly R R RIII

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uh3ttED STATES

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SEP C _ 2 Locket No. 50-155 EA 92-122 Consumers Power Company i

ATTil: William t.. Beckman Plant Manager Big Rock Point Nuclear Plar.t 10269 US 31 North Charlevoix, MI 49720

Dear Mr. Beckman:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-155/92017(DRP))

This will acknowledge receipt of your letter dated August 20, 1992, in response to our letter dated July 22, 1992, transmitting a Notice of Violation j associated with Inspection Report No. 50-155/92017(DRP). We have reviewed your corrective actions and have no further questions at this time. These

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corrective actions will be examined during future inspections.

Sincerely,

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Edward G. Greenman, Director Division of Reactor Projects Enclosurn Letter dated August 20, 1992 See Attached Distribution I _ _ _ _ _ _ _ _ - - _ _ _ _ _ _

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SEP u., n.c, C'onsumers Power Company 2

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Distribution:

cc w/ enclosure:

l David P. Hoffman, Vice President -

! Nuclear Operations i DCD/DCB (RIDS)

{ OC/LFDCB Resident inspector, Rill

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James R. Padgett, Michigan Public

Service Commission

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Michigan Department of Public Health

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R. J. Stransky, LPM, NRR

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! C. J. Paperiello, RIII i

J. Lieberman, Director, OE-J. R. Goldberg, OGC J. G. Partlow, NRR i

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MICHIGAN 5 PROGRESS Big Rock Pcunt Nucloat Plant.10269 US 31 North, Charlevoix., MI 49720

August 20, 1992

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Nuclear Regulatory Cocznission Docuwent Control Desk Washington, DC 20555

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DOCKET 50-155 - LICENSE DPR-6 - BIC ROCK P0j NT PIANT - REPLY TO A NOTICE OF

VIOLATION (Nr J INSPECTION REPORT 50-155/92-017)

Enclosed is the reply to the Notice of Violation described in the Nut. lear Regulatory Consnission Inspection Report 50-155/92-017 dated July 22, 1992.

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Gregory C Withrow For William L Beckman (Signed)

, William L Beckman Plant Manager

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l CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Attachment

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ATTACllMENT Consumers Power Company Big Rock Point Plant Docket 50-155

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REPLY TO A NOTICE OF VIOLATION hRC INSPECTION REPORT 92017 August 20, 1992

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l V I Ol.AT I ON 92017-01

, Section 6.8.1 of the Technical Specifications states in part, " Written

* procedures shall be established, implemented, and maintained for all structures, oystems, components, and safety actions defined in the Big Rock ;

Point Quality List." Section 5.2 of Chapter 13 of Volume 17 of the quality l j list requires procedures for maintenance and operations activities. Section ;

l $.6.1 of Administ rative Procedure 2.1.4, " Plant Status and Equipment l

} Control," which provides operational requirements for removing equipment from i service, states, in part, that prior to giving his permission, the shift i

supervisor shall verify that the equipment or system to be removed from service can be removed and that the method used to remove it from service is proper, i

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Cont rary to the above, on January 10, 1992, maintenance order periodic inst ructions EPS-0003 and SPS-0001 were released to allow work on the K-59-X and K-27-X emergency diesel generator overvoltage and undervoltage relays

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respectively without verifying that both relays could be removed from service

at the same time.

REASON FOR THE VIOLATION

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The Shift Supervisor released two maintenance oruers which permitted concurrent i testing of the Emergency Diesel undervoltage (K-27-X) and overvoltage (K-59-X)

relays. This action was determined to be personnel error. Neither the Shift

Supervisor nor the Technician performing the work were aware of the consequences that might occur because of inadequate job planning. This is considered to be an isolated incident.

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CORRECTIVE ACTION TAKEH AND RESULTS ACHIEVED

1. The appropriate activities in the Periodic Activities Controls Program

) were updated to include a reference to the fact that only one relay (K-27-X or K-59-X) be released at any one time for preventive maintenance. This action was completed by Hay 4, 1992.

I 2. A memorandum was addressed to the operations department describing that C-43, the auto transfer to the emergency generator switch on the C01 i

console, may not work to defeat ACB (air circuit breaker) closure if both K-27-X and K-59-X are " picked up" at the same time. This memorandum was issued by May 9, 1992.

CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS Several ongoing actions / programs will contribute to avoiding occurrences such

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as the concurrent testing of the EDC under and overvoltage relayat 1. Quality Verification Program This program is expected to of fer an inspection planning process. Both

"Q" and Non "Q" equipment will f all under the requirements of the program.

2. Planning / Scheduling is being improved by:

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developing a planning guide

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assigning a maintenance supervisor as a full time planner

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hiring an additional planner.

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Nuclear Regulatory Commission 2

!!ig Rock Point Plant REPLY ,TO VIOLATION 92-017-01 August 20, 1992 ATTACHMENT I

3. Converting the current Preventive Haintenance Program to a computerized Advanced Maintenance Management System ( AHMS). This action will consolidate PMs, data, history and schedule on a " user f riendly",

Company proven system.

DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED The f acil!Ly will be in full compliance by the end of 1992.

VIOLATION 92-017-02

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Section 6.8.1 of the Technical Specifications states in part, " Written procedures shall be established, implemented, and maintained for all structures, systems, components and safety actions defined in the Big Rock Point Quality List." Section 5.2 of Chapter 13 of Volume 17 of the quality list requires procedures for maintenance and operations activities. Section 5.3.2.b of Administrative Procedure 3.2.1, "Haintenance Order Processing,"

states in part that maintenance of equipment shall be planned and performed in accordance with written procedures, documented instructions, or drawings tha; at appropriate to the circumstances.

Contrary to the above, on Harch 10, 1992, a one inch compression fitting on the number one recirculation pump (RCP) seal water heat exchanger was

installed with naintenance order $91-PCS-0033. This maintenance order failed to contain adequate instructions for the proper installation of the

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compression fitting.

REASON FOR THE VIOLATION The maintenance order failed to contain adequate instructions for the installation of the compression fitting for the following reasons:

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Plant and Field Maintenance Service repairmen have received training on compression fitting installatior.. The skill of the craf t was assumed to be adequate to perform this task without special instruction. Matching the level of the experience of the crew commensurete is the level of detail in procedures will always provide a challenge for msnagers.

2. The Q-list does not classify RCP seal water heat exchangers as being safety related, therefore they are not subject to the requirements of the Quality Program. This would account for an inspection of the compression' fitting installation not being performed.

l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED l 1. New instruc* ions / inspection checklist for compression fit tings (high

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pressure, greater than or equal to 3/4 inch) were written and l distributed to maintenance supervisors, planners, training and

! engineering departments. The maintenance planners will use these when

- processing future applicabic maintenance orders.

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Thi s act ion was complet ed by May 28, 1992.

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Nuclear Regulatory Consnission

• Big Rock Point Plant 3 REPLY TO VIOLATION 92-017-01 Augu'st 20, 1992 ATTACitHENT 2. Ey July 3,1992, upgraded compression type fitting training had been administered to Big Rock Point mechanical / electrical repairmen. The training included hands-on fitting assembly and use of the newly developed instruction / inspection c!.ecklist. The lesson plans for skills center training have also been upgraded to include the revisions described above.

CORRECTIVE ACTION 70 flE TAKEN TO PREVENT RECURRENCE 1.

The "Q" List classification of both one inch and 3/4 inch recirculation pump seal water heat exchanger will be reevaluated to determine if the heat exchangers should be classified as "Q". This action will be completed by November 1,1092.

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The Quality Verification Program is being developed to address "Q" and Won "Q" equipment,- and should help prevent these types of occurrences in -

thc future.

DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED The f ar.ility will be in full compilance by the end of 1992.

! VIOLATION 92-017-03 i

10 CFR part 50, Appendix B, Criterion V, states, in part, that activities af fecting quality shall be prescribed in documented instructions, procedures, or drawings of a type appropriate to the circumstances.

Contrary to the above, on May 6,1992, tagging order f 92-0491 to remove the station battery charger f rom service did not contain instructions appropriate to the circumstances in that the instruction incorrectly specified the removal of the battery leads and not the battery charger leads.

REASON FOR Tile VIOLATION The reason for the violation has been identified as personnel error and procedural shift inadequacy. During the development of the tagging order, the supervisor and control room operator inadvertently substituted the word

" bat tery" for " battery charger" during their thought process. Within the equipment tagging section of the System Operating Procedure SOP-28,- Station Power,_it is not clear that the cables to be lifted during this sequence are

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between the charger end the battery. In addition, SOP-28 had yet tc be reviewed in accordance with a procedure improvement program established in 1991 per commitments made in Response to a Notice of Violation (NRC IR 50-155/

91005) Failure to Follow Procedures, dated July 9,1991.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A.

Sect ion 7.5 of SOP-2B, Stat ion Power, was revised to clarif y the task of removing the station battery charger from service. The revision was issuad on July 14, 1992.

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Nuclear Regulatory Conmission 4

. Big Rock Point Plant

REPLY TO VIOLATION 92-011-01 August 20, 1992 i ATTACHHINT

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8. A memorandum suecarizing this event and emphasizing the need for obtaining outside assistance when the shif t personnel.cannot readily

identify the proper method or impact of removing equipment from service was issued and reviewed by Operations personnel. This action was

, completed May 30, 1992.

l CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS '

, 1. Review the equipment tagging section of the System Operating Procedures (Section 7.0) and the Haster Switching and Tagging Orders. Hake revisions, as required, to include the limiting conditions and necessary cautions

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for operation when equipment is removed from service. This action will

be completed by October 15, 1992.

2. A "Self Checking Program" is expected to be implemented by the end of the third quarter of 1992 in the operations department. The purpose of this program is to address " blind compliance issues" as procedures improve and become more relied upon by the operating shifts.

3. An Administrative procedure is being authored to address SOER 91-01:

Infrequently Performed Task / Evaluations. The new procedure will consider training, management expectations, special controls and the need for increased controls to control these types of tasks. This procedure will be in place by the end of the third quarter of 1992.

l 4. a Procedure Implementation Task Force is currently being organized and is expected to be in place by the end of 1992. The- goal of this task i

force is to formulate guidelines to help the operator answer procedure need question.

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A " Morning Heeting" has recently been established as a forum for daily planning. The meeting is attendeu by department heads and representatives f rom major departments.

The meetings ~ are designed to be of short duration, and encourage a team approach to problem solving.

DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED l

The f acility is expected to be in full compliance by the end of 1992.

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