IR 05000730/2010031
| ML20205K077 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point, 05000730 File:Consumers Energy icon.png |
| Issue date: | 02/24/1986 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205K066 | List: |
| References | |
| 50-155-85-14, EA-86-013, EA-86-13, NUDOCS 8602270101 | |
| Download: ML20205K077 (3) | |
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Consumers Power Company Docket No. 50-155 Big Rock Point Nuclear Plant License No. DPR-6 EA 86-13
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During an NRC inspection conducted during the period July 30 through October 31, 1985, a number of violations of NRC requirements were identified.
The violations involved personnel errors, inattentiveness, and failure to follow procedures.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are listed below:
A.
Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained for all structures, systems and safety actions defined in the Big Rock Point Quality List.
Local Control Procedures - Part I, RESPONSIBILITIES, Repairman, which implements Technical Specification 6.8.1, requires that "after" working clearance has been received and "before" the work is started, it is the responsibility of the repairman doing the work to ensure that the equipment
is depressurized and de-energized as is necessary to perform the work.
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Contrary to the above, on September 11, 1985, even though a repairman had received working clearance on the steam isolation valve for the steam seal regulator CV-4104 and it had been determined that the associated system was depressurized and de-energized, work was incorrectly performed on turbine bypass warming valve CV-4106 for which working clearance had not been received and for which its associated system had not been determined to be depressurized and de-energized.
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B.
Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained for all structures, systems, and
safety actions defined in the Big Rock Point Quality List.
Local Control Procedures - Part I, RESPONSIBILITIES, Operator, which implements Technical Specification 6.8.1, requires the operator [suxiliary operator] to accept, write and carry out all switching orders to the best
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of his ability and with strict adherence to Local Control Procedures.
If
at any time there is not complete understanding and agreement of what is to be done, the operator shall stop and resolve the misunderstanding or disagreement before continuing.
Local Control Procedures - Part I, RESPONSIBILITIES, Issuing and Receiving Working Clearance, which implements Technical Specification 6.8.1, requires that the person in charge have a complete understanding of the condition of equipment involved and that the electrically de-energized and/or B602270101 860224
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February 24, 1986 mechanically isolated and protective tagged equipment encompass the work area needed, thereby making the equipment safe to work on.
It also requires that tagging be double checked by the Operations Supervisor after equipment is removed from service.
Local Control Procedures - Part I, EXPANDING WORKING CLEARANCE, which implements Technical Specification 6.8.1, states that if at any time working clearance does not encompass the work area needed, a new switching and tagging order shall be completed.
Modification of or adding to an existing switching order is prohibited.
Local Control Procedures - Part I, RESPONSIBILITIES, Repairman, which Implements Technical Specification 6.8.1 requires tha.t "after" working clearance has been received and "before" the work is started, it is the responsibility of the repairman doing the work to ensure that the equipment is depressurized and de-energized as is necessary to perform the work.
Administrative Procedures, Volume I, Chapter 5, Section 1.5.6.4.2.E.8, which implements Technical Specification 6.8.1, requires that th:: maintenance procedure shall contain a step-by-step description of the work to be performed and shall be sufficiently detailed to allow correct and safe performance by a qualified individual without direct supervision.
Maintenance Procedure TR-74, Sections 5 and 6, Inspection of Liquid Poison Supply Check Valves VP-301 and VP-302, describes the procedures for isolation from the reactor vessel, proper tagging, disassembly, inspection repair, and testing prior to returning these valves to service.
Contrary to the above, written procedures for systems defined in the Big Rock Quality List were not properly implemented which resulted in the wrong valve, control rod drive system check valve VRD-305, being disassembled on September 25, 1985 instead of VP-301 and a loss of approximately 1400 gallons of water from the associated system.
The following examples of the violation occurred:
1.
Notwithstanding the Local Control Procedures on Operator Responsibilitie'.
on September 23, 1935, the auxiliary operator issued a work clearance to the maintenance supervisor on liquid poison supply check valve VP-301 even though a misunderstanding on the location of the valve VP-301 had not been resolved.
2.
Notwithstanding the Local Control Procedures on Issuing and Receiving Working Clearance, prior to commencing work on September 25, 1985, the maintenance supervisor did not require that the operations supervisor double check the tagging but instead requested a radiation protection technician to identify valve VP-301 for the repairma.
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February 24, 1986 3.
Notwithstanding the Local Control Procedures on Expanding Working Clearance and Repairman Responsibilities, on September 25, 1985, after working clearance had been received for valve VP-301 and before work was started, a maintenance supervisor improperly modified the existing
switching and tagging order for VP-301 by adding liquid poison supply check valve VP-302 to the order.
Maintenance was performed on VP-302
without the repairmen who did the work ensuring that the added equipment was depressurized and de-energized as necessary.
4.
Notwithstanding the referenced Administrative Procedure and Maintenance Procedure TR-74, when VP-302 was improperly added to the existing switching and tagging order for VP-301, the step-by-step description of work contained in Maintenance Procedure TR-74, Section 5 and 6 was not included in the tagging Order for VP-302 and was not followed before returning VP-302 back to service.
These violations are categori::ed in the aggregate as a Severity Level III problem (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Consumers Power Company is hereby required to submit to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, IL 60137, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply including for each violation:
(1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the
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results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
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FOR THE NUCLEAR REGULATORY COMilSSION
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E~D James G. Keppler Regional Administrator Dated a Glen Ellyn, Illinois this 1 -day of February 1986
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