ML20056F847
| ML20056F847 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/25/1993 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308310204 | |
| Download: ML20056F847 (5) | |
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Consumers POWBr Patrick M Donnelly Plant Manager s
POWERING MICHIGAN'S PROGRESS 8 80 Rock Pom: Nucleet Plant.10269 US 31 Nonh, Charlevom. MI 49720 August 25, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - REPLY TO A NOTICE OF 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 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 violation involved failure to follow procedures for control of combustibles and for reactor deck tool control and housekeeping. An additional violation involving the use of caution tags was also identified; however, since the requirements of 10 CFR Part 2, Appendix C, Section VII.B were met, this violation is non-cited.
Unfortunately on August 20, 1993 the incorrect Reply to the Violation was submitted by the Big Rock Point Staff. The draft file was inadvertently retrived from the computer data base and issued without an adequate review.
Pursuant to the direction required by the report, find attached a response that supersedes the August 20, 1993 submittal to the Notice of Violation dated July 23, 1993.
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,7 8 7 Patrick M Donnelly Plant Manager CC: Administrator, Region III, USNRC g
NRC Resident inspector - Big Rock Point h
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4 ATTACHMENT CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT 93007 l
August 25, 1993
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3 Pages
ATTACHMENT RESPONSE TO VIOLATION 93007 VIOLATION 93007 Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained for all structures, systems, components, and safety actions defined in the Big Rock Point Quality List. Theses procedures i
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,
-l' systems, and components.
A. Administrative Procedure 1.8, " Plant Housekeeping and Cleanliness," Rev.5, Section 5.3.2, states, in part, th;t,ith the reactor head off special care shall be taken to keep the area ar uno he cavity free of unnecessary tools and supplies to prevent loose objec..
.om falling into the cavity. Section 5.3.3 of the same procedure states, tnat, in part, that the immediate area around the fuel pool shall be kept free of unnecessary of loose objects.
Contrary to the above, on June 29, 1993, the Licensee failed to remove i
unnecessary tools or loose objects from around the reactor cavity and the fuel pool area with the reactor head off and refueling operations in progress REASON FOR THE VIOLATION Procedures currently exist which provide for a tool control area and are written to prevent debris from entering these areas. While the operations department is cognizant of the procedure (s) which provides these controls, there is a general lack of awareness of these controls by other working 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.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED 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.
The debris has subsequently been removed from the reactor deck and from the working platform above the reactor vessel. A requirement was 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 the reactor and the spent fuel pool. This area is clearly delineated with a yellow herculite boundary.
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ATTACHMENT 2
REPLY TO VIOLATION 93007 i
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS Prior to operating the plant at power:
All tools will be removed from the entire reactor deck except for those controlled by the operations department in accordance with System Operating 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 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.
Prior to the next refueling outage:
i 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.
j 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 specifying 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.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1
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 I
taken, so that full compliance can be maintained during the next and future refueling outages.
VIOLATION 93007 i
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.
REASON FOR THE VIOLATION Several cans of combustible paint were found by the NRC 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 compromised.
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a ATTACNMENT 3
REPLY TO VIOLATION 93007
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REASON FOR THE VIOLATION (Continued)
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). (This assignment was secondary to the routine duties of the A0s). During the shift, the A0s left to radwaste, at the request of the Shift Supervisor (55). They had planned to return to finish the painting task, therefore the paint was left in the area. However, i
they were delayed till the end of their shift and did not return to the vent shed. Contrary to their previous shifts, the A0s did not turn over to the SS l
or the oncoming shift that the paint had been left in the vent shed (prior to this, the A0s had been removing the paint at the end of each day - a good housekeeping practice).
1 Therefore, the root cause of this event was a lack of communication because the A0s did not advise the Shift Supervisor or the on-coming shift that the paint had been left in the vent shed that day.
The BRP staff recognizes that housekeeping during this refueling outage is not at the level where it needs to be, and can be improved. Management attention is being directed to alleviate the problem in all work groups. Major l
clean-up campaigns, management expectations, training and procedure revisions are expected to bring the levels of housekeeping back to an acceptable level.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED I
l The paint was immediately removed from the vent shed.
CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS Reply to Notices of Violation are routinely reviewed by the Operations department during the scheduled training shift. The shifts will be made aware of the violation in this manner.
DATE WHEN FVll COMPLIANCE WILL BE ACHIEVED With regards to the corrective actions taken above, the facility concludes that full compliance has been achieved.
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