ML20002D770
| ML20002D770 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/04/1975 |
| From: | Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20002D769 | List: |
| References | |
| NUDOCS 8101220439 | |
| Download: ML20002D770 (4) | |
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g f C0mpany d W.I cea <a on ces si2 vwes u.cmo a aveawe. Jachsoa. u c~oma se2oi. 4 en coa. si7 ree osso September h, 1975 Mr J. G. Keppler US liuclear Regulatory Cetmission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKEf 50-155, LICEIiSE DFB BIG ROCK POIIiT PLAIIT By letter dated August 7, 1975 Inspection Report 050-155/75-10 vas transmitted.
This inspection report listed several items of apparerat noncompliance. The purpose of this letter is to provide a written statement in reply to these apparent itens of nonco=pliance as requested in the transmittal letter.
Infraction
" Contrary M Tuennical Op cifications 7.1.6 and 7 3.2(a), inec=-
plete entries and unauthorized changes were made to detailed plant start-up p
checklist."
Response - Corrective action is being taken in three areas in an attempt to preclude recurrence of this type of infraction. First, an information memo vill be issued which lists the " infractions" and states that unauthorized changes are not to be made. Second, all check sheets vill te made consistent in that a licensed operator will be required to sign off the check sheet as being conplete and a senior licensed operator vill sign off the review of the check sheet. Third, a notation paragraph vill be added ahead of the review sign-off that specifies that the review must be complete before the check sheet can be treated as completed. All of the above items vill be co=pleted by October 1, 1975 Infraction
" Contrary to Criterion XII of Appendix B of 10 CFR 50, the control of measuring and test equipment has not been implemented."
Eesponse - As noted in the inspection report under Item III.2.c, ve intend to fully inplement a program for control of test equipment by October 1975 This program is presently partially implemented.
Infractions
" Contrary to Criterion V of Appendix B to 10 CFR 50 the following activitics affecting quality were not accomplished in accordance with applicable instructions."
"a.
Eeview of certain operation memos by Operations personnel vere not com-pleted as required by Administrative Procedure 1.h.a.3.7 gyo/M b9%
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"b.
The surveillance testing program master schedule was not completed as required by Adminie',rative Procedure 1.17 "c.
Certain plant devi is were not investigated and corrected as required by Administrative
_edure 1.3."
Response
a.
We have reviewed current administrative procedures regarding Operations memos and have concluded that they are adequate.
In order to insure that thev are fully implemented, we will instruct the relief shift supervisor to include not only licensed control (perators but all operators in the reviews.
In addition, Procedure 1.h.A.3.7.1 regarding Operations memos will be reviewed with all Operations personnel by October 1, 1975 b.
The Instrument and Control Department does not have a mast 0c surreillance schedule to reflect the status of all planned surveillance test and inspec-tions as required by Administrative Procedure 1.17, Section C.3.
As noted in the inspection report, we are in the process of obtaining a status board to keep track of surveillance items. This status board will be obtained and placed in use by October 1975 (Part A) - Apparently no follow-up action was performed with regard to the c.
switch reset problem. The switch performed its trip function within specifi-cations during testing on June 3, 1975 Investigations revealed that the level switch required manual assistance to reset on June 6, 1975 and, though we have no evidence that such reset problems are indicative of failure to trip problems, we intend to inspect and test operate the switch to verify freedom of operation this week. Such reset dif-ficulties usually indicate the trip function is more positive on this type of tilting mercury switch.
In regard to the identification and follow-up of such noted anomalies, we will emphasize such requirements in the administrative procedures and issue a training memorandum the second week of September.
It is noted that the inspection report contains a typographical error in Line 7 of Section II.3. A (Page 17). The reference to our D08-B should be our D08-D.
(Part B) - Predicted critical patterns have been historically considered as only guides for the operator. To add an extra precaution during critical approach, a " hold point" had been administratively established to allow re-assessment of the critical prediction selected for the critical approach.
At least three critical predictions were involved it,the June 1975 start-up.
Two (actually one with two differing rod worth curves) were computer predic-tions (which had to be adjusted for actual conditions). The integral rod wortha varied because of differing assumed withdrawal sequences. The third je=g prediction was a hand calculation of the reacto: engineer. One of assumed
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- withdrawal sequences used in the computer prediction was actually the same as occurred and.the sanc-as that used by the'reactcr: engineer ~in his pre-diction. These two predictions were in close agreement.
The other assumed rod withdrawal sequence (which was not the actual vithdrawal sequence) resulted in an earlier critical _ prediction (less notches withdrawn).
The reactor: engineer established a procedural." hold point" for'further eval-untion based on the earliest' predicted critical = configuration (least notches withdravn). When this' point vas achieved, based on his knowledge of the rod
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. withdrawal sequence and the'resulting differing integral rod vorths, it was his judgment that the start-up was proceeding as was expected and he directed-that the start-up continue utilizing'the other.tvo critical predictions which were in close agreement. These other two critical predictions proved _to be-in acceptable agrcement.with the actual critical' position.
Subsequently, there were some minor errers found in the computer calculation (refer to A0-18-75). These errors did not have-a significant effect on the critical prediction..
We have concluded that the critical approach was conducted in a safe and prv-
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dent manner and that no unexpected deviction occurred which required'further documented review. Proceeding beyond the initial hold point of 70 notches was adequately documented in the reactor logbook and on the critical approach form and procedure. Documented reactor logbook sheet review, which included the prediction discrepancy described above, by members of the PRC did not result in any adverse cc=ments or concerns.
(Part C) - Ay y no follow-up action was taken to explain this apparent deficiency.
ser, the valve operated satisfactorily for the manual ini-tiation test on the same day, January 21, 1975, and again prior to the satisfactory leak rate test on May 29, 1975 l
The valve was visually verified to be closed on August 29, 1975 and the as-sessment was made that the valve is completely operable in the automatic mode.
I With regard to the identification and follow-up of such noted anomalies, we vill require timely review with sign-off of surveillance test prior to de-claring systems operable by appropriate changes to the administrative procedures. These changes will be completed during the second veck in September.
Deficiency
" Contrary to Technical Specification 7.1.2, the observation of the I
critical approach by two licensed' operators on June 5, 1975 was not apparent."
i Response - The intent of the Technical Specifier.tions was met. An interview with the witness along with the signatures on the BRP-RE-8 procedure utilized June 5.
1975 show that two licensed operators were on duty in the control room. Also,
- ,O the reactor engineer was present along with the senior licensed shift supervisor.
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1 A los entry was not made stating that a licensed operator was present since a
" critical approach.on start-up" was not in progress. We have concluded that no follow-up action is warranted.
Deviatien "The start-up package 1 (June 5-8, 1975) was not reviewed in ac--
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cordance with the commitment to the NRC (response dated May 18,-1973)."'
Response - Errors 'which were found by.the _ inspector in the June 1975 start-up'-
checklist were the result of a lesr than detailed review by;the shift super-visors and the Operations engineer. These errors are acknowledged and a more thorough review will be' conducted in the future. Refer the first infraction-for further corrective action.
Ralph B. Sewell (Signed)
Ralph B. Sewell Huclear Licensing Administrator CC: -File
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