ML20035G925

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Insp Rept 50-155/93-03 on 930217-0406.Violation Noted.Major Areas Inspected:Operational Safety Verification,Engineered Safety Feature Sys Walkdown,Maint & Surveillance Activities & Engineering & Technical Support Activities
ML20035G925
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 04/23/1993
From: Phillips M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20035G916 List:
References
50-155-93-03, 50-155-93-3, NUDOCS 9304300187
Download: ML20035G925 (9)


See also: IR 05000155/1993003

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 111

Report No.

50-155/93003(DRP)

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 Plant

inspection At: Charlevoix, Michigan

Inspection Conducted:

February 17 through April 6, 1993

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Inspector:

E. A. Plettner

R. J. Leemon

Approved By:

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Reactor Projects Section 2B

Date

Inspection Summary

inspection on February 17 throuch April 6.1993

(Report No. 50-155/93003(DRP))

Areas inspected:

A routine, unannounced, inspection by the resident

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inspectors of operational safety verification; engineered safety feature

system walkdown; maintenance and surveillance activities; engineering and

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technical support activities; and other safety assessment and quality

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verification activities.

Results: Of the five areas inspected, one violation was identified.

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violation was for failure to provide complete and accurate information in a

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timely manner to the NRC (paragraph 6).

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Operations:

The activities were carried out in an acceptable manner.

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strength was noted in the manner that departmental personnel exchanged

detailed information. A casual attitude toward caution tags was identified.

Maintenance / surveillance: Activities were mixed. Surveillances were still

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considered to be strong.

A weakness was identified in lack of an independent

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verification with peer evaluation on the main turbine hand trip solenoid work.

Radiation Protection: A good ALARA practice was recognized with two power

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reductions to repair a steam leak on the moisture separator.

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9304300187 930423

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Emergency Preparedness: The licensee conducted a challenging drill and

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critique that resulted in noteworthy improvements for the subsequent NRC

evaluated emergency preparedness exercise.

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Engineering: As noted above, a problem with independent verification resulted

in an incorrect wiring modification to the main turbine hand trip solenoid.

Safety Assessment and Quality Verification: A violation was issued for

failure to respond in a timely manner to an NRC violation.

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DETAILS

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1.

Persons Contacted

Consumers Power Company

  • P. Donnelly, Plant Manager
  • D. Hughes, Executive Engineer

D. Turner, Maintenance Superintendent

  • W. Trubilowicz, Operations Superintendent
  • G. Withrow, Plant Engineering Superintendent

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  • R. Alexander, Technical Engineer
  • E. Bogue, Chemistry / Health Physics Superintendent

D. Lacroix, Nuclear Training Administrator

  • M. Bourassa, Senior Licensing Technologist
  • R. Scheels, Planning and Scheduling Administrator
  • T. Petrosky, Public Affairs Director

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  • D. Gaiser, Maintenance Engineer
  • G. Boss, Reactor Engineer

The inspectors also contacted other licensee employees including members

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

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operators.

  • Denotes those attending the resident inspectors' exit meeting on

April 6, 1993.

2.

Manaaement Meetina (30702)

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The Deputy Regional Administrator and members of the headquarters and

regional staffs' met on March 18 in Charlevoix, Michigan, with

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representatives of Consumers Power Company to review the Systematic

Assessment of Licensee Performance Report (SALP 11) for the Big Rock

Point Nuclear Power Plant.

On March 15 Mr. Patrick Donnelly assumed the duties of plant manager.

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Mr. William Beckman, the departing plant manager, has taken a position

in the corporate office to assist Consumers Power Company with future

projects.

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3.

Plant Operations

a.

Operational Safety Verification (71707)

The inspectors verified that the facility was being operated in

conformance with the license and regulatory requirements and that

the licensee's management was effectively implementing its

responsibilities for safe operation of the facility.

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The inspectors verified proper control room staffing and-

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coordination of plant activities; verified operator adherence with

procedures and Technical Specifications; monitored the control

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room for abnormalities; verified that electrical power was

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available; observed that management personnel, including the plant

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manager, frequently toured the control room; and observed shift

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turnover.

The operations staff performed well in exchanging

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detailed information.

The inspectors also monitored various records, such as hold and

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secure card records, jumpers and bypasses, shift logs and

surveillances, daily orders, and maintenance items.

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All operations were considered acceptable except as noted

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elsewhere in this report.

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On February 28 the reactor was shut down to repair a leaking shaft

seal on the number two recirculation pump. During the shutdown,

the main turbine hand trip solenoid valve failed to function and-

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resulted in the operators manually tripping the turbine. No other

abnormalities occurred during the shutdown. The shutdown was

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performed correctly and in.a professional manner. Additional work _

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completed during the outage included the replacement of a steam

drum relief valve, change out of the gaskets on the "B"

and "D"

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trains of the reactor depressurization system, repair.of a main

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condenser tube leak, and change out of four solenoid valves that

actuate containment isolation valves. . Repairs were completed and

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reactor startup was accomplished on March 5.

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On April 3 the number seven main turbine admission valve failed in

the closed position. Operators took the appropriate actions-to

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maintain the plant in a safe condition.

Repairs will be completed

during the scheduled 1993 refueling and maintenance outage to

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commence in June 1993.

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Caution Taas

During tours of the control room, the inspectors noted a number of.

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large size caution tags on control panels, as well as a number of

smaller caution tags in use. As a result of the Three Mile Island

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accident, most licensees have gone to exclusive use of the smaller

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tags on control panels in order to prevent blocking the view of

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equipment indicators and controls. A review of the Big Rock Point

procedure for caution tags revealed that either size tag is -

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authorized in the control room. Although several'of the larger

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tags were rolled or folded in order to prevent obscuring the view,

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this is considered to be a weakness.

In response, the licensee

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submitted a procedure change request to strengthen the caution tag--

procedure.

In a previous self. identified. finding discussed in

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Deviation Report D-BRP-92-040,. the recirculation systems were

declared operable with caution tags left on the pump suction valve

handwheels in the recirculation system pump rooms. No apparent

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reason was listed for the error. These findings indicate a casual

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attitude toward the caution tag system.

Emeroency Preparedness Drill

On February 23 th' licensee staff participated in an emergency

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preparedness training drill to identify areas where improvements

should be made in preparation for the graded exercise to take

place on March 23, 1993.

The inspectors observed the drill in the

control room and Technical Support Center (TSC). The licensee

conducted a challenging drill followed by good critiques.

Items

identified for improvement were: more attention by reactor

operators to the control board indications, more timely

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communication to the staff when upgrading the emergency

classification level, and tracking of the protective action

recommendations on the TSC status board. Other issues for

consideration included more formal feedback communications during

changes of command and control and the relaying of information

between the operations support center and the control room as

related to work activities. Orderly, formal, and structured

status update briefings were needed to improve overall

communications and focus the staff's actions on priority items.

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The NRC evaluated the emergency preparedness exercise held on

March 23. The results of that evaluation are documented in

Inspection Report 50-155/93005(DRSS), and indicated that the above

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areas for improvement had been corrected.

Procedure Adeauacy

During the inspection period the licensee completed its

investigation into the reactor depressurization system valve,

VRDS-101-A, being closed when it should have been open. The

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investigation identified that the operators involved had little or

no experience in operating such unique valves.

Further

investigation revealed that the same problem occurred some time in

1982 for which the licensee issued a memo to correct the problem.

These instructions, however, were not included in plant operating

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procedures or training lesson plans resulting in the incident

occurring again on January 4, 1993.

This incident is not being

cited as a violation in that it is similar to another violation

for procedure adequacy where the corrective actions are still

being implemented by the licensee. This is discussed in

Inspection Report 50-155/91005(DRP).

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Radiation Protection /ALARA

A good ALARA practice was noted on March 9 when reactor power was

decreased to reduce radiation exposure to the workers from 0.30

REM per hour to 0.08 REM per hour while repairing the moisture

separator. This practice was again employed when power was

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decreased a second time on March 11 to complete the repair.

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b.

Enoineered Safety Feature System Walkdown (71710)

The inspectors performed a walkdown of the batteries, diesels,

service water, core spray, and fire system. During the

inspection, the material condition of the valves, pumps, hangers,

supports, labeling, housekeeping, and major system components were

assessed. The housekeeping throughout the station was adequate in

the major traffic areas.

Some minor fretting was noted on some

copper lines on the emergency diesel generator. The licensee

issued a maintenance order to correct the problem.

No violations or deviations were identified.

4.

Maintenance / Surveillance (61726 & 62703)

a.

Work Observations

Station maintenance and surveillance activities were observed

and/or reviewed to ascertain that they were conducted in

accordance with approved procedures, regulatory guides, industry

codes and standards, and in conformance with Technical

Specifications.

The following items were considered during this review: Approvals

were obtained prior to initiating work; test instrumentation was

calibrated; functional testing and/or calibrations were performed

prior to returning components or systems to service; quality

control records were maintained; activities were accomplished by

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qualified personnel; results were within specification and

properly reviewed; and any deficiencies identified were properly

resolved.

The following maintenance and surveillance activities

were observed.

Maintenance

M/0 92-RDS-0054 Reactor Depressurization Valve "D" for Removal

and Reinstallation cf Gasket.

M/0 93-TGS-0037 and 0038 Turbine Hand Trip Solenoid Replacement.

During the post modification testing, a wiring error was

discovered which had occurred during the installation process. An

indepth root cause analysis was conducted to determine where the

breakdown occurred as it could have an impact in future

applications on safety related systems. The problems identified

were as follows:

no pre-job walkdown of the system to verify that

terminal configuration matched the plant drawings (this was a

concern identified with configuration control during the

Electrical Distribution Safety Function Inspection conducted in

the Fall of 1992), lack of detail in the written work

instructions, and lack of an independent peer inspection

verification. This was a non-safety related system and the

requirements of 10 CFR Part 50 Appendix B did not apply. However,

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the licensee agreed to provide guidance for quality verifiers on

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the importance of independent verification and to improve the

modification process with additional procedural guidance to assure

that similar problems do not occur in the future.

Moisture Separator Steam Leak Repair

On March 9 reactor power was reduced to 35 percent to repair the

steam leak located on the top portion of the moisture separator

(MS). The contractor, in preparing to perform the sealant

injection operation, noted that the bolts on top of the MS were a

different size than expected. Because of delays in determining

and obtaining the proper sized bolts, the reactor was returned to

full power without making any repairs. _ The correct size bolts

were determined and procured, and on March 11 reactor power was

reduced to 70 percent to perform the sealant injection operation.

The operation was successfully completed and the reactor returned

to full power later in the day.

Because the licensee lacked

detailed engineering prints on non-safety related equipment,

additional time and radiation exposure to workers was necessary in

order to complete the repairs.

Surveillance

T7-28 The Emergency Diesel Generator Surveillance. This was

performed by an engineer and an operator using state-of-the-art

vibration computer data logging equipment.

The inspector observed

that the operator was knowledgeable of the equipment and

electrical system and operated and took readings on the emergency

diesel generator and electric fire pump. The engineer ensured

that the vibration probe was properly attached to the equipment

and that the reading had stabilized before logging the readings.

No problems were identified.

b.

Outaae Plannina and Control

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The Operations Department formed a new committee which had one

working meeting during the inspection period to discuss the scope

and establish better ways to schedule and prioritize work

activities during outages. This was the first step in a process

to improve interdepartmental communications and planning.

No violations or deviations were identified.

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5.

Enoineerina and Technical Support (38280)

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The inspectors evaluated the extent to which engineering principles and

evaluations were integrated into daily plant activities. This was

accomplished by assessing the technical staff involvement in non-routine

events, outage related activities, and assigned TS surveillances;

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observing on-going maintenance work and troubleshooting; and reviewing

deviation investigations and root cause determinations.

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Problems were noted in the main turbine hand trip solenoid modification

process. This is discussed in detail in section 4.a of this report.

The licensee is taking actions to address the findings.

No violations or deviations were identified.

6.

Safety Assessment /0uality Verification (40500)

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 the coordination between departments.

Additionally, the inspectors routinely monitored the results of the

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licensee corrective action programs by attending routine meetings,

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through discussions with the plant staff, and review of deviation and

root cause evaluation reports.

The licensee held two Corrective Action Review Board (CARB) meetings on

a wiring error on a battery charger. This was for a root cause

investigation which was still in progress at the end of the inspection.

However, it was determined that the battery charger was operable during

the time in question. The CARB was considered pro-active since the

battery charger is not classified as safety related equipment. The

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resident inspectors will evaluate and document the results of the root

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cause analysis and lessons learned in a future inspection report.

Inspection Report 50-155/93002(DRP) contained an unresolved item, 93002-

01, involving the licensee's failure to inform the appropriate groups

within the organization and the NRC of commitment date extensions. 0n

February 17, 1993, the licensee informed the NRC that Notice of

Violation 50-155/92017-03(DRP) had exceeded the response date of

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December 31, 1992 (a period of over six weeks).

10 CFR 2.201(a)

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requires licensees to respond in writing within twenty days or other

specified time of the date of a Notice of Violation, describing the

corrective actions that have been taken, corrective actions to be taken,

and the date when full compliance will be achieved. The licensee failed

to provide the required information to the Commission prior to exceeding

the response date and failed to request an extension for Violation 50-

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155/92017-03(DRP).

This is considered to be a violation of 10 CFR 2.201(a) (50-155/93003-01(DRP)).

One violation and no deviations were identified.

7.

Followup of Previous Identified Items (92701)

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(Closed) Unresolved item 93002-Ol(DRP): " Failure to Update Missed LER

Commitment Dates." This unresolved item dealt with failure to update

the NRC prior to exceeding corrective action completion dates for

licensee event reports.

Violation 50-155/93003-01(DRP) dealing with the

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same subject matter is being issued; therefore, this item is closed.

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Exit Interview

The inspectors met with licensee representatives (denoted in paragraph

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1) at the conclusion of the inspection on April 6.

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

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such documents or processes as proprietary.

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