ML20056F392
| ML20056F392 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/20/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308270116 | |
| Download: ML20056F392 (5) | |
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Consumers
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Petrick M Donnetty -
Plant Manager mmunaws rueeness i
Beg Rock Pomt Nuclear Plant.10269 US-31 North. Chartevom. MI 49720 l
August 20, 1993 i
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i Nuclear Regulatory Commission i
Document Control Desk l
Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - REPLY TO A NOTICE OF-l VIOLATION - INSPECTION REPORT NO. 50-155/93007(DRP).
On July 23, 1993, Consumers Power Company - Big Rock Point Plant, received the routine NRC Inspection Report 50-155/93007(DRP) covering the period from May
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26 through July 15, 1993. The report concluded that certain of Big Rock Point's activities appeared to be in violation of NRC requirements. The q
violation involved failure to follow procedures for control of combustibles and for reactor deck tool control and housekeeping. An additional' violation i
involving the use of caution tags was also -identified; however, since the requirements of 10 CFR Part 2, Appandix C,Section VII.B were met, this violation is non-cited.
t Pursuant to the direction required by the report, find attached a response to l
the Notice of Violation dated July 23, 1993.
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Patrick M Donnelly Plant Manager CC: Administrator, Region III, U.SNRC NRC Resident Inspector - Big Rock Point ATTACHMENT n o n n F, j
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ATTACHMENT CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 93007 Dated August 20, 1993 l
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ATTACHMENT RESPONSE TO INSPECTION REPORT 93007 h
VIOLATION 93007 Technical Specification 6.8.1 requires that written procedures be established, f
implemented, and maintained for all structures, systems, components, and safety. actions defined in the Big Rock Point Quality List. Theses procedures shall meet or exceed the requirements of ANSI N18.7, as endorsed by CPC-2A.
CPC-2A, Section 5.2 states, in part, that administrative procedures are used to control activities affecting the quality of safety-related-structures, i
systems, and components.
A. A6ninistrative Procedure 1.8, " Plant Housekeeping and Cleanliness," Rev.5, l
Section 5.3.2, states, in part, that with the reactor head off special care j
shall be taken to keep the area around the cavity free of unnecessary tools and supplies to prevent loose objects from falling into the cavity. Section i
5.3.3 of the same procedure states, that, in part, that the immediate area around the fuel pool shall be kept free of unnecessary of loose objects.
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Contrary to the above, on June 29, 1993, the Licensee failed to remove-unnecessary tools or loose objects from around the reactor cavity and the l
fuel pool area with the reactor head off and refueling operations.in progress j
REASON FOR THE VIOLATION 1
Procedures currently exist which provide for a tool control area and are l
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written to prevent debris from entering these areas. While the operations l
department is cognizant of the procedure (s) which provides these controls, l
there is a general lack of awareness of these controls by other working l
groups. This is probably due to a difference in the level of appreciation for the consequences of failed fuel coupled with a clear understanding of-what level of cleanliness is expected.
1 CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED i
Debris in the form of tape and pieces of wire were found on the reactor deck at the beginning of the refueling outage. A piece of wire was also found on the working platform above the reactor vessel. The working platform covered the opening to the reactor vessel at the time this debris was discovered.
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The debris has subsequently been removed from the reactor deck and from the working platform above the reactor vessel. All members of the Operations department have been briefed by the Reactor Engineer as to the significance of controlling tools and loose materials on the reactor deck. A requirement was i
placed in the Daily Orders Log Book to " visually inspect the reactor deck floor, the refueling platform, and the fuel pool bridge for debris every four hour shift before work commences in the reactor or the spent fuel pool. The tool control area was expanded from the reactor vessel, the spent fuel pool, the reactor crane, and the fuel pool bridge to also include the area between i
the reactor and the spent fuel pool. This area is clearly delineated with a i
yellow herculite boundary. This action was also documented in internal i
correspondence RHS 93-16 (Big Rock Point - Reactor Deck Debris and Tool Control) to all Department heads. RHS 93-16 was also posted around the plant j
for all employees to read.
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2 ATTACHMENT RESPONSE TO INSPECTION REPORT 93007 i
i CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS l
l Prior to operating the plant at power:
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All tools will be removed from the entire reactor deck except for those controlled by the operations department in accordance with System Operating l
i Procedure - 44, Spent _ Fuel Pool Operations and New Fuel Handling. Only items contained in the operations storage box, locked tool box, or tool racks will j
remain on the reactor deck.
A general cleanup will be performed on the reactor deck which will remove all materials from this area except those mentioned above.
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Prior to the next refueling outage:
r Procedural changes will be made to formally expand the tool control area to include the area between the reactor and the spent fuel pool. This area will be clearly marked with paint and/or boundaries.
l Procedural changes which require working groups to account for all materials taken onto the reactor deck will be made.
A letter will be issued to all site personnel specifyir.g acceptable housekeeping practices for the reactor deck-and what consequences will occur if these practices are not adhered to. This letter will also relate the potential consequences of the fuel leak found at the end of cycle 26.
j The Reactor Engineer will expand the briefing done for the Operations department to the Maintenance and Chemistry / Health Physics departments as to the significance of controlling tools and loose materials on the reactor deck.
t DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED With regards to the immediate actions taken above, the facility concludes that full compliance has been achieved. The actions to be taken over the course of the next operating cycle are expected to enhance the immediate actions already taken, so that full compliance can be maintained during the next and future refueling outages.
VIOLATION 93007 B. Administrative Procedure 4.4.7, Revision 4, Section 5.2.1.c, states that, in part, that storage of unnecessary combustible materials shall not be in areas containing safety-related equipment.
Contrary to the above, on June 29, 1993, several cans of combustible paint were found stored underneath the instrument air panel used to operate the safety-related containment isolation valves.
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l RESPONSE TO INSPECTION REPORT 93007 THE BASIS FOR DISPUTING THE VIOLATION Several cans of combustible paint were found by the NPC Senior Resident Inspector on June 29, 1993, stored underneath the instrument air panel in the vent shed. This panel provides backup nitrogen to operate the safety related containment isolation valves in the event that instrument air is comprimised.
Administrative Procedure 4.4.7, Revision 4, Section 5.2.1.c, states in whole, that " Storage of unnecessary combustible materials shall not be in areas containing safety-related equipment. Materials which must be stored for any length of time should be stored in covered metal containers".
The paint had been left in this location by Operations on June 29, 1993. The vent shed had been cleaned, necessary repairs made, and was in the process of being painted by the Auxiliary Operators (A0s). During the shift, the A0s left to radwaste, at the request of the Shift Supervisor (SS). The A0s had planned to return to finish the painting task, so the paint was left in the area; however they were delayed and did not return. The A0s did not turn over to the SS or the oncoming shift that the paint had been left in the vent shed (Prior to this, the A0s had been proactive (in regards to the procedure) by removing the paint at the end of each day. In addition, the Shift Supervisor had authorized the temporary storage of the paint in the vent shed during the cleanup effort). However, the cans of paint were promptly removed by the A0s when the Senior Resident Inspector expressed his concern to the Shift Supervisor.
Since the metal cars of paint were covered with their own lids, the BRP staff concludes that in accordance with Administrative procedure 4.4.7, Revision 4, Section 5.2.1.c described above, the facility is in compliance with the requirements of the procedure.
The BRP staff recognizes that housekeeping during this refueling outage is not at the level where it needs to be. Management attention is being i
directed to alleviate the problem in all work groups. Major clean-up campaigns, Management expectations, training and procedure revisions are expected to bring the levels of housekeeping back to an acceptable level.
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