ML19341B360

IE Insp Rept 50-155/80-14 on 801020-24.Noncompliance Noted: Spec/Field Change Package 80-015 Closed Out W/O Required Testing

ML19341B360
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/17/1980
From:	Shepley S, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19341B356	List: ML19341B355 ML19341B358 ML19341B360
References
50-155-80-14, NUDOCS 8101300796
Download: ML19341B360 (6)

See also: IR 05000155/1980014

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U. S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-155/80-14

Docket No. 50-155

License No. DPR-6

' Licensee: Consumers Power Company

212 West Michigan Avenue

Jackson, MI

49201

Facility Name: Big Rock Point Nuclear Power Plant

Inspection At:

Big Rock Site, Charlevoix, MI

Inspection Conducted: October. 20-24, 1980

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Inspector:

S. E. Shepley, Resident Inspector

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Approved By:

R. L. Sphssard, Chief,

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Reactor Projects Section No. 1

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Inspection Summary

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Inspection on October'20-24, 1980 (Report No.~ 50-155/80-14)

Areas Inspected: Routine, operational inspection consisting of verification thati

design changes were made in accordance with Technical: Specifications 'and. the .

established Quality Assurance Program. The inspection involved a total of 24'

inspector-hours onsite by one NRC inspector.

Results: One item of noncompliance (Severity VI - failure to follow plant modi-

fication procedures - paragraph 2.b. (2). (b)) was identified.

8101800y@b

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DETAILS

1.

Persons Contacted

• C.

R. Abel, Acting Operations & Maintenance Superintendent

• R.

E. Schrader, Technical Superintendent

• D.

E. DeMoor, Technical Engineer

• J.

J. Popa, Maintenance Engineer

• K.

E. Marbaugh, Q. A. Administrator

F. J. Valade, Shift Supervisor

L. F. Monshor, General Engineer

• Denotes persons present at management interview.

2.

Review of Design, Design Changes and Modifications

a.

The inspector reviewed the licensee's design, design changes and modi-

fications documentation to ascertain whether. design changes and modifi-

cations, which are not approved by NRR, are in conformance with the

requirements of the Technical Specifications and 10 CFR 50.59.

As

part .of this review, the inspector:

(1)

Selected a total of six changes which included changes in the

reactivity control system, reactor coolant system, emergency

core cooling system, ' containment system, and radwaste system.

(2)

Checked whether the changes chosen were reviewed and approved

in accordance with Technical Specifications and established

QA/QC controls.

(3)

Checked whether the design changes selected were controlled'

by established procedures.

(4)

Checked by review of completed test records whether the licensee

conducted a review and evaluation of test results and:

(a)

Test results were within previously~ established acceptance

criteria.

(b)

Test deviations were resolved and retesting' accomplished

as appropriate.

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(5)

Checked whether operating' procedure modifications were' made and :

approved' in accordance with Technical Specifications :for those:

design changes selected.

-(6)

Checked whether as-built drawings'were changed to reflect the

modifications.

(7)- For four of the changes selected lin previous a., checked:

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(a)

That change activities were being conducted in accordance

with the appropriate specifications, drawings, and other

requirements.

(b)

That acceptance and startup testing of modifications were

conducted in accordance with technically adequate and

approved procedures.

(c)

The implementation of appropriate controls (e.g., firewatch,

portable fire fighting equipment, welding and cutting

permit, etc.).

b.

As a result of this review, the inspector has determined the following:

(1)

The " Facility Change" documentation was found adequate and

acceptable.

Only minor problems were noted with design changes

and modifications where a " Facility Change" type of documentation

package was used, and the inspector has no concerno on these

matters.

(2)

The " Specification / Field. Change" (SFC) documentation method was

found less than adequate because it si:s too weak to provide satis-

f actory guidance. and checks against error; controls to prevent

questionable use, and documentation requirements to provide

record continuity.

Significant problems were noted with design

changes and modifications where a " Specifications / Field Change"

type of documentation package was used.

Two examples of the

problems, as discussed with the licensee, are:

(a)

SFC 79-023, Modification to Reactor Vessel Bottom Head

Insulation, with which the licensee made a cut through

the insulation on the bottom of the Reactor Vessel so it

would be permanently attached only at the ends. This

was done to facilitate removal for leak inspection, in

the area of F-2 CRD Penetration, under and adjacent to the

insulation. When-closed up, the insulation would be

stapled together wJth two splicing bars.

The safety evaluation for the modification stated that the

FSAR requires the insulation to be present, but that the

modification would not violate this because "the insulation

will be held in place during operation. . .and will only be

removed during periods when the reactor is shut down."

The cut was made, the splicing bars were fabricated, and the

SFC package was closed out and the system was returned'to

operation.

The FSAR requires the insulation to be in place, pre-

sumably, in order-to' insulate. The safety _ evaluation did '

not eddress any possible degradation to insulating quality.

One of the reviewers _ questioned the eff ect of _ the modifi-

cation on the insulation, but no documentation exists that

any resolution of this question was made. No testing was

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mentioned, or done. Even if the issue were unimportant,

a statement should exist that it was looked at and the

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effect would be negligible and no test was necessary.

The safety evaluation required that the insulation be in

place during operation and only removed during periods

when the plant was shut down.

No documentation existed

in the SFC package to indicate followup action to insure

this.

When the inspector asked some licensee operations

personnel if there were some procedures to preclude start-

up without the insulation in place, they said there were

not, but they thought that the procedure which controls

the leak investigations for the CRD system should have

a part which controls the removal and replacement of the

insulation. When we looked at the Icak investigation

procedure, there was nothing there concerning the insula-

tion replacement.

There did not appear to be any formal

control to ensure the requirements of the safety evalua-

tion would be enforced.

The licensee assured the inspector that the insulation

was in place even though there was no documentation

availabic. This ma tter will be reviewed during a subse-

quent inspection (155/80-14-01) .

(b)

Specification / Field Change 80-015, CV4096 Air Cylinder

Extension, with which the licensee extended the air

cylinder of the valve operator for the containment supply

ventilation check valve to eliminate overstresses in

the valve operator during a LOCA from the full open

position.

The valve was a Q list item.

The analysis appendant to the safety evaluation stated

that the modification would increase the closing time of

the valve, but that calculations indicated the valve

closure would not be extended past the 6 second Technical

Specification limit.

The modification was donc and the SFC was closed out on

June 3, 1980, but there was no documentation in the SFC

package that any post modification testing had been done

to verify Technical Specification conformance.

The licensee explained that for this type of SFC there is

always a maintenance order attached to or referenced in the

SFC package and that testing documentation could be

contained in that.

The place in SFC 80-015 that was

suppossed to contain the reference to the maintenance

order was blank. There was no way to know, just from the

SFC, that there was further paperwork involved.

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The test was indeed found in the maintenance order that

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was supposed to be referenced by the SFC. This was

improper because the test has a requirement to be stored

for the life of the license while the maintenance order

has no requirement to be stored any longer than 5 years

(ANSI N18.7-1976, Section 5.2.12 and ANSI N45.2.9-1974,

Section 2.2.1 and Appendix A), and the licensee has not

shown the inspector specific administrative controls

that would guarantee lifetime storage for the maintenance

order. The test would be better stored in the SFC which

also has a life of license storage requirement.

The test was completed on June 18, 1980, fifteen days

after the SFC was closed out.

The maintenance order was

closed out af ter the SFC also, which constituted a pro-

cedure violation. The procedure violation may have been

caused in part because there was no way to tell, internal

to the SFC, that there was an associated maintenance

order. The inspector determined that the operating status

of the valve was properly controlled and that the valve

was not returned to service until the maintenance order

was closed out.

The inspector picked 10 SFC's out of the licensee's files

to see how many would reference a maintenance order. Out

of the 10 checked, 7 had the place, where the maintenance

order reference should be, blank. While some types of

SFC's can stand alone without an associated maintenance order,

the following SFC's should have maintenance orders and

do not reference one: 80-17; 80-16; 80-15; 80-13; 80-12;

79-19; and the inspector is not sure about 79-21.

As can be seen ~ from the examples, the problems resulted from

lack of control over _various steps in the SFC modification

process. There are no sign-of f check lists (similar to 'those

in the successful " Facility Change" package) to require responses -

to such questions as: will the modification adversely affect

perf ormance;- is an analysis necessary; is a test'necessary;

has the test been successfully completed; is a procedure change

necessary; is followup surveillance necessary; is there a main-

tenance order associated with the modification (with a response

required even when there is not) . There is no single document

that tracks all aspects of an SFC modification-and ties SFC and

maintenance order activities together.

In discussing these and other problems with the licensee, the

licensee mentioned several past problems of a similar nature which

had been experienced. The possibility of the SFC having been

abused because of looser restrictions for modifications that

should have been done under " Facility Change" was mentioned,

along with the need for administrative controls to prevent it.

The licensee acknowledged that'the SFC was weak and should be

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strengthened stating that a draf t of a new SFC procedural

package was being developed, but there was no commitment that

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any specific changes would be made.

The failure to follow procedures as described in 2.b. (2) . (b) .

above is _ contrary to Big Rock Point Technical Specifications,

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Section 6.8.1; ANSI N18.7; and Big Rock Point Administrative

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Procedures Volume 1, Sections 1.9.D.1.2.1, 1.9.D.2.2.3(a) ,

and 1.9.D.2.2.3(b), as well as 10 CFR 50.59b; 10 CFR 50,

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Appendix B, Criterion II; ANSI N45.2.9; and Big Rock Point

Quality Assurance Program Policy #3 and is considered to be

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an' item of noncompliance (155/80-14-02).

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The inspector is particularly interested in corrective action

that will preclude recurrence, and since the overall weak

administrative controls associated with the SFC package is

considered a contributing factor and ' therefore, a part of

the failure, any corrective action should address the following

issues:

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a.

The need for controls over what modification should use

the SFC method (abuses-155/80-14-03) .

b.

The need for' a single document that tracks all steps

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of- the modification (record continuity including storage-

155/80-14-04).

c.

The need for strengthened control over the modification

steps themselves- (guidance and checks-155/80-14-05).

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3.

Management Interview

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The inspector met with . licensee representatives (denoted in Paragraph 11)

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at the conclusion of the inspection period. The inspector: summarized

the scope and findings of the inspection.

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