IR 05000155/1993019

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Insp Rept 50-155/93-19 on 931020-1214.Violations Noted.Major Areas Inspected:Operational Safety Verification,Engineered Safety Feature Sys Walkdowns & Maint & Surveillance Activities
ML20059C108
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 12/21/1993
From: Phillips M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059C095 List:
References
50-155-93-19, NUDOCS 9401040373
Download: ML20059C108 (10)


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U.S. NUCLEAR REGULATORY COMMISSION i

REGION Ill

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Report No.

50-155/93019(DRP)

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Docket No.

50-155 License'No. UPR-6'

Licensee:

Consumers Power Company

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212 West Michigan Avenue

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Jackson, MI 49201 l

Facility Name:

Big Rock Point Nuclear Plant I

Inspection At:

Charlevoix, Michigan i

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Inspection Conducted: October 20 through December 14, 1993 I

Inspectors: R. J. Leemon i

C. E. Brown C. Gainty i

Approved By: @ Y M 4v e

@/9//4 7

506',M. PE'Phjliips, Chief Dats "

Reactor Projects Section 2B Inspection Summary

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Inspection on October 20 - December 14. 1993 (Report No. 50-155/93019(DRP))

Areas Inspected:

Routine, unannounced inspection by the resident inspectors i

of operational safety verification, engineered safety feature system-walkdowns, maintenance and surveillance activities, engineering and technical l

support activities, quality verification effectiveness, and plant support j

activities.

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Results: Within the-areas inspected, one violation was identified (paragraph I

3.b).

The following is a summary of the licensee's performance during this l

inspection period:

Plant Operations: Although overall performance in this area was good;_the

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licensee again removed a component from service at a time when its operability-was required due to continued problems with the' configuration controls as l

implemented through the switching and tagging process.

A verbal

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miscommunication resulted-in a backup _ core-spray valve being inadvertently

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removed from service, rather than an alarm being cleared in the control room.

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This is another example of the violation cited'in Inspection Report No. 50-

155/93015.for which escalated enforcement-was issued.

In addition, a weakness j

was noted in total-activity planning, resulting in an un-interruptable power

source (UPS) battery being initially called out-of-service.when it was not.

This was caused by two different groups taking specific gravity readings under two different procedures.

The second reading was inaccurate due to the water'

that had been added to the battery cells during the performance of the first j

procedure.

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9401040373 931222 PDR ADOCK 05000155--

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Maintenance:

Performance in this area was mixed. Strengths were noted in the improvement to critical job performance when a final job-scoping and readiness

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walk through was performed after the final pre-job briefing (before placing the bypass steam valve hydraulic power unit out of service) and in the repair efforts following the inadvertent loss of the diesel fire pump -(DFP).

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Weaknesses noted included the failure to have a contingency plan in place in

case the fuel supply line to the DFP was cut and in the failure to review-the

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"as-left" torque switch setting on a safety related valve, resulting in its

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subsequent inoperability when stroked.

Engineering:

Performance in this area was adequate. The continued strong

proactive Zebra Mussel control efforts were viewed as a strength. A weakness j

vas nnted in engineering efforts to support maintenance as noted in the t

previou3 paragraph.

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Plant Support Performance in this area was good.

Strengths' included dose

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control efforts and improvements in self assessment performance and document control activities.

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DETAILS

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1.

Persons Contacted Consumers Power Company

P. Donnelly, P1 ant Manager l

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  • E. Bogue, Chemistry / Health Physics Manager G. Boss, Systems and Project Engineering Manager
  • M. Bourassa, Senior Licensing Technologist

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D. Hughes, Executive Engineer

  • R. Scheels, Planning and Scheduling Administrator
  • W. Trubilowicz, Operations Manager
  • D. Turner, Maintenance Manager

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  • G. Withrow, Plant Safety and Licensing Director
  • L. Darrah, Operations Supervisor
  • E. Evans, Engineering Supervisor
  • T. Petrosky, Public Affairs Director
  • G. Cheeseman, NPAD Assessor i

The inspectors also contacted other licensee employees including members

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of the technical and engineering staffs, and the reactor and auxiliary i

operators.

2.

Plant Operations

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The licensee operated the plant routinely at the full released power

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level for the entire inspection period. Maximum released power was i

controlled by fuel conditioning and burnout. The plant has maintained a 100 percent availability following startup after the-recent refueling outage. The inspectors noted that turbine repairs performed during the

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last refueling outage have contributed greatly to weekly water usage

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remaining at a very low level.

a.

Operational Safety Verification (71707)

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The inspectors verified that the facility was being operated in conformance with the license and regulatory requirements and that

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the licensee's management was effectively carrying out its

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responsibilities'for safe operation ~of the facility.

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The inspectors verified proper control room staffing and coordination of. plant. activities, verified operator adherence to

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procedures and technical specifications (TS), monitored the

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control room for abnormalities, verified that electrical power was j

available, observed shift turnovers, and monitored the frequency

of plant and control room visits by station management.

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The inspectors reviewed various records, such as Caution-Tag

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books, switching-and tagging-order files, shift logs and

surveillances, daily orders, and maintenance work orders.

Except as noted below, the inspectors determined that all observed activities were acceptable.

- Weak Configuration Control - The licensee demonstrated weak i

cor*Su*ation control when backup core spray valve.(M0-7071) was

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inadvertently removed from service. A switching and tagging order

was generated to replace a defective low-pressure alarm

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transmitter. Due to a verbal miscommunication, the wrong-electrical terminal block sliding links were specified on the switching and tagging order. When the operator opened the designated slide links, M0-7071 was taken out-of-service.

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operator immediately noted the error as the low-pressure alarm did not clear. After investigation, MO-7071 was quickly restored to service. A 4-hour 10 CFR 50.72 report was made to the NRC.

i A recent escalated enforcement action described in Inspection Report No. 50-155/93015(DRP) concerned ineffective configuration

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controls through the use of switching and tagging orders and

inadequate corrective actions to address them. This event is another example of the type that led to that escalated enforcement r

action in that it' also resulted in rendering a system inoperable at a time when operability was required. After this event, the licensee took additional immediate corrective actions to address i

problems with the switching and tagging process and addressed the long term corrective actions.

These were documented both in the response to the Notice of Violation for inspection report 50-155/93015(DRP), which the licensee issued on December 8, 1993, and also in the Licensee Event Report 93011, which was issued on

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November 29, 1993. The inspectors will continue to monitor the effectiveness of the these corrective actions as part of the close

out for the escalated enforcement.

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b.

Engineered Safety Feature System Walkdown (71710)

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The inspectors performed walkdowns of various safety systems using procedures and piping and instrumentation drawings (P& ids) to

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verify system line-ups and to ascertain that the systems were

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operable.

During the inspections, housekeeping and the material condition of valves, pumps, supports, labeling, and major system components were assessed and items needing attention were

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communicated to the licensee.

c.

Cold Weather Preparations (71714)

The inspectors determined that the licensee had performed good

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cold weather preparations. - The inspectors reviewed the license's Procedure 0-VAS-1, Cold / Warm Weather Checklists, Revision 10, and found it to be complete and to meet requirements. All actions had been completed before the onset of freezing temperatures and a

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walk through proved necessary physical barriers to be in place.

All records were complete and properly filed for good

accountability.

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No violations or deviations were identified in this area.

3.

Maintenance

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Activities Observed (61726 & 62703)

The inspectors observed station maintenance and surveillance

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activities and determined that they were conducted in accordance

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with approved procedures, regulatory-guides, industry codes and

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standards, and in conformance with TS.

i During this review, the inspectors considered the following: (1)-

were approvals obtained before initiating work; (2).were

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instruments calibrated; (3) were functional tests and/or calibrations performed; (4) were quality control records properly

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maintained; (5) were activities accomplished by qualified personnel; and (6) were results within specifications and properly

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reviewed with any identified deficiencies properly resolved before returning components or systems to service. The following

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maintenance and surveillance activities were observed:

T30 - 27 Shift Fire Drill Procedure T30 - 44 Containment Gamma Monitor 190 - 22 Plant Housekeeping Inspection T90 - 23 Portable Pump Function & Capacity Test T7 - 28 Emergency Diesel Generator Start Test T7 - 20 Diesel Fire Pump Test Start ~

WO 12301949 Control Rod Pump Power End Maintenance

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With the exception of those areas discussed below, the inspectors

noted good communications and safe work practices for those

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activities observed.

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b.

Comments on Work Observed i

Inadvertent Loss of the Diesel Fire Pump (DFP) - The inspectors j

concluded that the licensee's recovery efforts to repair

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inadvertently cut fuel lines and to return the DFP to service were

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excellent.

However, the preparations for drilling the holes next i

to the DFP_ were weak in that no contingency plan for a possible

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fuel line cut had been developed before commencing to drill. The-l fuel lines were cut while drilling a 6-inch hole in the screen i

house floor to accommodate a TV camera inspection for Zebra Mussel j

infestation. The location of the hole needed to be in close proximity to the DFP suction _ screen for.the TV camera to be effective. The presence of a conduit containing the fuel oil supply and return lines was known to the licensee from examining

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original-construction photographs. Neither examination of plant

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t drawings nor radar mapping of the floor had determined the exact location of the conduit.

When fuel started to flow from around the drill bit, the licensee immediately stopped. drilling, stopped I

the fuel oil leak, notified State and local authorities, and took precautionary oil spill control measures. One or two drops of oil seeped back through the conduit and into the cooling water out i

fl ow. This small amount of oil was contained by a licensee oil-i control boom. The licensee repaired the fuel lines and returned the DFP to service in about 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, well within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LC0

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requirement.

During the repair efforts, the inspectors noted strong peer inspection efforts in quality assurance. The licensee inspector questioned the procedure and then stopped further work

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until the attendant engineer could add the necessary record pages for each new joint that was being made. Subsequent investigation and further radar mapping revealed that the majority of the conduit had been fastened directly under a re-enforcing bar

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(rebar) before the concrete floor was poured. The rebar had.

masked the presence of the conduit leading to the inaccuracy of

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the location of the hole.

l Enhancement to Work Control Process for Critical Jobs -- The inspectors observed a notable enhancement to the licensee's l

work-control process for critical jobs. The licensee had

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scheduled filter replacement and minor oil leak repairs on the steam-bypass valve hydraulic-power unit. The work was placed on the 3-day schedule, then onto the 1-day schedule, then onto the

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plan of the day (P0D) and was discussed at the daily 8:00 a.m.

meeting. The job had been reviewed at the daily 1:00 p.m.

planning meeting and had been scheduled for an infrequently performed test or evolution (IFPTE) briefing.

At the morning meeting, licensee management stressed the importance of the IFPTE briefing and stated that an additional step would be taken to ensure readiness before starting this critical job. At the conclusion of the IFPTE briefing, a final.

job scoping would be performed by the personnel actually assigned

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to perform the work. All persons involved were to do a final check of the material, procedures, switching and tagging orders, and tools to ensure that everything was ready to complete the work-

before the unit was taken out-of-service. The IFPTE briefing was very good and covered all contingencies. After the briefing, the experienced maintenance man assigned to the job, noted that new

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gaskets had not been supplied for the canisters that hold two of

the filters. These gaskets are required in addition to the ones supplied on the filter cartridges.

He immediately informed his supervisor and the shift supervisor (SS). The SS then set a

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deadline time for the engineers and planners to have the parts in

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hand or the job would be cancelled. The parts were not in stock and the job was cancelled before the equipment was taken out-of-

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service. The addition of the final job scoping by an experienced maintenance man and his questioning attitude was an excellent

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enhancement to the work control process for critical jobs.

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p Improperly Adjusted Motor-Operator Torque Switch - The inspectors determined that the licensee failed to evaluate the final "as left" torque switch setting for closing M0-7053. On November 5, 1993, during performance of quarterly M0V stroke testing, normally-t.losed M0-7053 (emergency condenser outlet isolation valve) was opened, but did not close when signalled.

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attempts to close the valve were unsuccessful.

The licensee determined that the torque switch had been set at too low a value

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during previous testing on August 4, 1993. The low setting caused l

the motor operator to de-energize before closing the valve against the system pressure present during the surveillance test.

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Further, it was determined that the VOTES test results following

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the final adjustment of the torque switch were not evaluated as part of the test package.

Instead, the licensee inadvertently

evaluated the results of an earlier V0TES test, which was conducted at a higher torque switch setting. According to the licensee, the results of the final V0TES test at the as-left torque switch setting would not have met the established acceptance criteria. The safety significance of this condition is relatively minor in that MO-7053 is normally closed and its safety function -- to open and establish emergency cooling -- was not impeded by the low torque switch setting. However, because MO-7053 would not close, the licensee was required to leave an emergency condenser inlet valve (M0-7052) closed, thus removing

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one emergency condenser loop from service.

The licensee has put a contingency plan in place to make the loop available for use, but only through overt operator action. Repairs are scheduled for the first available outage. TS 4.1.2(b) permits isolation of one loop of the emergency condenser until the next outage. The failure to evaluate the test results at the final torque switch setting is

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considered a violation of 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," which requires, in part, that test results be documented and evaluated to ensure that test requirements have

been satisfied (50-155/93019-01(DRP)).

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One violation was identified in this area.

4.

Engineering (37700)

The inspectors evaluated the extent to which engir,eering principles and evaluations were integrated into daily plant activities.

This was accomplished by assessing the technical staff's involvement in non-routine events, outage related activities, and assigned TS surveillances; by observing on-going maintenance work and troubleshooting; and by reviewing deviation investigations and root

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cause determinations.

Zebra Mussel Countermeasures The licensee took excellent preventive measures to address Zebra Mussel

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colony establishment in the plant water systems.

The actions included

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heating the fire system with a portable heating unit to kill any

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existing mussels, obtaining agreement with the State to use a new

formulation of "Clamtrol" chemical treatment, and drilling holes in the

screen house floor to allow the use of an underwater TV camera to t

inspect pump suction screens for the presence of Zebra Mussels.

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Additionally, the licensee has started to install a continuous

chlorination system to the incoming circulating water. Once installed, this system should prevent future Zebra Mussel infestation. The

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licensee scheduled a chemical treatment of the circulating water systems

for December 17, 1993, even though the low inlet-water temperature will

limit the effectiveness of the treatment.

The inspectors considered

this proactive.

The inspection did not reveal any safety-significant deficiencies.

No violations or deviations were identified in this area..

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Plant Support j

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The inspectors evaluated the effectiveness of management control, verification, and oversight in the jobs observed during this inspection.

The inspectors also attended management and supervisory meetings involving plant status to observe inter-departmental communications and coordination. Additionally, the inspectors monitored the results.of the licensee's corrective action programs by reviewing deviation, event,' and

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root cause evaluation reports; attending routine meetings; and discussing plant evolutions and events with the plant staff.

a.

Self-Assessment Efforts (40702)

The inspector determined that the licensee's Nuclear Performance Assessment Department (NPAD) had performed a good self assessment

of Big Rock Point's Document Control Center (DCC). The audit was

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assessed by discussing the proposed scope with the licensee, monitoring the performance of the audit, and reviewing the audit i

results.

The audit addressed the effectiveness of DCC's control,

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processing, and storage of documents and records. The results t

showed there was substantial improvement in the procedure change

process and document filming at BRP. Additionally, incorporation of administrative and working level procedures on the licensee's l

local area network (LAN) computer system may improve trending.

Overall, the licensee concluded that the document control programs were being effectively implemented.

The inspectors agreed with

the licensee's results and noted this was an improvement in the

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self-assessment efforts in this area.

b.

Plant Review Committee (PRC) (40500)

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report period. The inspectors assessed the performance of the PRC i

by attending both regularly scheduled and reactive meetings, a

monitoring the composition of the committee, and evaluating the -

qualifications of the committee members. The composition and qualifications of the PRC were found to be in accordance with

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requirements. Discussion during the meetings was both open and effective. The chairman kept the meetings on track and ensured that all business was thoroughly discussed, actions items were assigned, proposed minutes were read, and commitments acknowledged before the meetings were adjourned.

c.

Regional Recuests for Information During this inspection period, the inspectors received a request from regional management to provide information about licensee core shroud inspections and specifications. The inspectors determined that Big Rock Point does not have a core shroud as-defined in the request; however, all similar information about the core thermal shield was obtained and forwarded to the regional office.

d.

Radiation Protection During this inspection period, the inspectors noted continued strong emphasis on dose reduction and contamination control efforts. ALARA principles were routinely emphasized and monitored by the technicians and management alike.

Some concerns about the possible spread of contamination during work on the control rod drive pumps and when performing flux wire runs were quickly followed up on by health physics personnel, who would be working with maintenance to improve maintenance work practices.

e.

Followup of Licensee Event Reports (LERs) (90712 & 92700)

The inspectors reviewed the following Licensee Event Reports (LERs) for compliance to reporting requirements and, as applicable, for implementation of appropriate corrective actions:

(Closed) LER 155/93007:

" Electric Fire Pump Start During Surveillance." Before the next refueling outage (scheduled for 1994), a precautionary statement will be added to Surveillance TR-48, " Reactor Depressurization System (RDS) Functional Test," to alert personnel that circuit board movement can cause unwanted electrical spikes imposing spurious signals in the reactor

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j depressurization system (RDS). Any board movement will require i

the affected RDS channel to be placed in " bypass."

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(Closed) LER 155/93009:

" Check Valves Not Included in Technical Specification Required Test Program." Four containment-spray check valves were omitted from the licensee's in-service testing (IST) program. The corrective action of including these valves in the IST program was acceptable and this LER is closed.

i (Closed) IER 155/93010:

" Licensed Operator Requal Training Not

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Performed in Accordance With Facility Technical Specifications."

The licensee immediately reviewed the licensed operator requal training program and ensured that all of the operators were

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corrective actions were acceptable and this LER is closed.

i No violations or deviations were identified in this area.

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6.

Exit Interview

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The inspectors met with licensee representatives (denoted in

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paragraph 1) on December 15, 1993. The inspectors summarized the purpose and scope of the inspection and the findings.

The inspectors also discussed the 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 proprietary.

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