ML19341C412
| ML19341C412 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/13/1981 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19341C411 | List: |
| References | |
| 800113, NUDOCS 8103030374 | |
| Download: ML19341C412 (4) | |
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i CORSumBTS QrPOW8f Company Generet offkes: 212 West Michigan Avenue, Jeckson, Michlgen 49201 * (517) 798 4650 January 13, 1981 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - RESPONSE TO IE INSPECTION REPORT NO 80-14 IE Inspection Report No 50-155/80-14, dated December 17, 1980, transmitted one apparent item of noncompliance found at the Big Rock Point Plant.
Our response to this Severity Level VI violation is as follows:
Violation Big Rock Point Technical Specifications, Section 6.8.1, 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. These procedures shall meet or exceed the requirements of ANS1 18.7."
ANSI N18.7-1976, Section 5.2.7 (see ANSI N18.7-1972, Sections 5.1.6.1 and 5.1.6.4 for similar requirements), states, in part, "... maintenance or modifications which may affect functioning of safety related... components shall be performed in a manner to ensure quality....
A suitable level of confidence in... components on which... modifications have been performed shall be attained by appropriate inspection and performance testing... modification of equipment shall be preplanned and performed in accordance with written procedures...means for assuring quality of... modification activities and measures to document the performance thereof shall be established."
l Big Rock Point Administrative Procedures Valume 1, 1.9 Plant Modifications, Section 1.9.D.1.2.1, dated February 12, 1980, states, in part,
...an SFC will be completed and approved prior to issue of the Maintenance Order and will be attached or referenced thereto," Section 1.9.D.2.2.3(a), dated January 11, 1978, states, "When the Maintenance Order is complete, the Requisition Engineer then closes out the SFC," and Section 1.9.D.2.2.3(b), dated oc0181-0131a-43 g
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Mr Jam s G Kappler 2
Big Rock Point Plant January 13, 1981
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January 11, 1978, states, "When the MO is completed, it is forwarded to the Requisition Engineer and the SFC is closed out."
Contrary to the above, on June 3, 1980, SFC Package 80-015, wnich had been used to modify the valve operator of a Q-listed valve in a way that adversely affected its closing time (the closing time has a Technical Specification limit) was closed out without any testing being performed.
Subsequently, on June 18, 1980, the testing was done and was documented in a Maintenance Order which was not attached to or referenced in the SFC packege. Thus, the Maintenance Order was completed after the SFC was closed out.
Response to Violation As noted in violation description, the Specification Field Change (SFC)
Package 80-015 was closed out prior to completion of the associated Maintenance Order (MO) and did not reference the MO.
These two actions constitute violations of existing Plant Administrative Procedures. However, contrary to the statements made in the Notice of Violation, no modification work had been performed on the subject valve at the time of completion of the SFC and no untested equipment was placed in service. The modification work was performed under the cor. trol of the associated M0 with authorized Procedure i
No SFC-80-15 and No SFC-80-16.
The work commenced and ended on the same day, June 18, 1980 (working clearance was issued at 0738 hours0.00854 days <br />0.205 hours <br />0.00122 weeks <br />2.80809e-4 months <br /> and the system was returned to operable status after completion of the modification and testing at 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br />).
The irregularities (ie, violations of Plant Administrative Procedures) that i
existed in the control of the documents associated with this modification were explained in detail to the inspector. These irregularities did not create an unsafe condition, as noted above. The SFC package is basically a design package used to make specific and generic changes to plant design documents.
The SFC, by itself, is not capable of initiating physical changes to plant equipment or structures. Either an MO or Notice of Outside Construction (NOC) must be initiated to allow changes to plant equipment or structures to commence. The M0 and NOC may use the SFC as a design basis justification to perform modification work but each incorporates testing requirements independent of the SFC.
Contrary to what is stated in the subject I,spection Report, M0s are required by Administrative Procedures to be retained for the life of the plant.
Corrective Action Taken and Results Achieved The appropriate Maintenance Order number (MO 80-CIS-155-06) for the modification has been recorded on SFC Package 80-015 so that traceability can be assured.
Corrective Action To Prevent Recurrence Plant Administrative Procedures will be revised to prevent recurrence of the noted violation and to provide stronger overall administrative controls for oc0181-0131a-43
Mr Jcain 'e Kappler 3
Big Rock Point Plent January 13, 1981
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the use of the SFC. Some of the modifications to the SFC program are anticipated to be:
1.
Inclusion of an SFC checklist to assure proper documentation requirements are fulfilled.
t 2.
Administrative review by the Technical Superintendent for closeout of the SFC in the same manner as is currently done for facility changes.
I In addition, changes to the SFC program will address the following issues of concern to your staff:
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1.
The need for controls over what modification should use the SFC method.
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The need for a single document that tracks all steps of the modification.
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3.
The need for strengthened control over the modification steps themselves.
D, ate When Full Compliance Vill Be Achieved f
Modifications to the Plant Administrative Procedures, as discussed above, to provide stronger controls for the SFC and achieve full compliance, will be implemented by June 1, 1981.
As requested by your letter dated December 17, 1980 which transmitted the subject Inspection Report and associated Notice of Violation, we commit to address the concerns identified in Paragraph 2.b(2) of the Inspection Report, as noted above. However, we are unab?e at this time to provide specific responses to these concerns due to the complexity involved in rectifying the problems associated with the entire SFC program.
David P Hoffman Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector-Big Rock Point l
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oc0181-0131a-43
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l CONSUMERS POWER COMPANY Big Rock Point Plant IE Inspection Report No 50-155/80-14 Response to NRC Letter Dated December 17, 1980 TLcket No 50-155 License DPR-6 i
At the request of the Commission and pursuant to the Atomic Energy Act of j
1954, and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and Regulations thereunder, Consumers Power Company submits our response to NRC letter dated December 17, 1980 which provides IE Inspection Report No 50-155/80-14 and a Notice of Violation dated December 17, 1980. Consuscrs Power Company's response is dated January 13, 1981.
CONSUMERS POWER COMPANY b
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R B DeWitt, Vice President' Nuclear Operations Sworn and subscribed to before me this 13th day of January 1981.
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{ 0+ct/M, Linda K Carstens, Notary Public Jackson County, Michigan My commission expires June 10, 1981.
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