ML20057E994

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Responds to Violation Noted in Insp Rept 50-155/93-10. Corrective Actions:Sor Representative Recommended That Housing Vent Plug Be Removed & Switches Recalibr.Action Accomplished on 930723
ML20057E994
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 10/04/1993
From: Donnelly P
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9310130465
Download: ML20057E994 (4)


Text

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POW 8r Patrick M Donnelly 1

Plant Manager POWERING MICHIGAN'S PROGRESS Beg Rocs Pomt Nuclear Plant.10269 US.31 North, Charlevoix W 49720 October 4, 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 - (NRC INSPECTION REPORT NO. 50-155/93010)

On September 9,1993, Consumers Power Company - Big Rock Point Plant, received a Notice of Violation with regards to the setpoints for two of the containment high pressures sensors being greater that Technical Specification requirements.

Pursuant to the action required by the notice, find attached a written response to the violation.

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Patrick M Donnelly Plant Manager O

CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point ATTACHMENT 10 1co 9310130465 931004

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i ATTACHMENT CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 50-155/93010 October 4, 1993 9

ATTACHMENT REPLY TO VIOLATION 93010 o

VIOLATION 93010 Technical Specification (TS) 3.5.1.e requires, in part, that the signal trip

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setting for the post-incident spray system be less than or equal to 2.2 pounds 1

per square inch gage (psig). TS ll.3.3.4.b states, in part, that if during power operation, one of the two containment spray systems is inoperable, a normal orderly shutdown shall be initiated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the reactor shall be shutdown as described in Section 1.2.5(a) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and shut down as described in Section 1.2.5(a) and (b) within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Contrary to the above, since installation of two new pressure sensors in i

October 1990 to July 1993, the reactor enclosure high pressure trip setpoint periodically, based on atmospheric temperatures, exceeded the limit of less than or equal to 2.2 psig with no resulting orderly shut down being performed.

REASON FOR THE VIOLATION Causal factors and apparent root causes contributing to containment high-pressure sensor setpoint drift are well documented in LER 93-003; Reactor Enclosure High Pressure Sensors Found Out of Technical Specification Tolerance, (dated August 4,1993) and Nuclear Regulatory Commission Inspection Report 50-155/93010 (dated September 8, 1993).

The LER concludes that the Technical Specification limit of 2.2 psig was found out-of-tolerance high because of an improper installation (vent plugs installed). The NRC Inspection report went further by concluding that a) the licensee did not communicate the unique characteristics of installation with the vendor to determine whether the vendor's recommendation concerning venting the reference leg was no longer valid, and b) failure of engineering personnel associated with the installation of these pressure sensors to recognize the affect of temperature changes on the setpoint.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Following identification of the setpoint increase, a Static 0-Ring (S.0.R.)

representative was contacted on July 9, 1993 for assistance. After reviewing the Big Rock Point calibration and design data, S.O.R. recommended that the 1

housing vent plug be removed and the switches recalibrated. This action has was accomplished on July 23, 1993.

In addition, a review of Big Rock Point documentation concluded this was the only application using S.0.R. sealed pressure sensors susceptible to temperature changes.

[0RRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATIONS As noted in the NRC Inspection Report, the Big Rock Point staff did not initiate corrective action to address the engineering efforts or vendor communication needs associated with the installation of these sensors. Because of the unique nature of this event, action to prevent recurrence was not addressed. However, the following actions should address the NRC concern to improve engineering efforts and information flow between Consumers Power i

Company and vendors.

ATTACHMENT REPLY TO VIOLATION 93010

1) Revise the EEQ file for pressure switches PS-7064 A and B (2.146) to address the need to remove the vent plugs. This should identify the concern 1

for future installations. This action is expected to be completed by December J

1, 1993.

2) Write a letter to S.0.R. informing them of our concern regarding inadequacy of vendor information regarding housing pressurization under ambient temperature swings. The letter will request S.O.R. to consider revising their manuals to highlight this potential problem. This letter is expected to be written by November 1, 1993.
3) Since the ultimate responsibility for understanding and controlling the application of equipment at Big Rock Point lies with plant personnel, communicating with the vendors is a necessity. A review of plant modifications / procurement procedures will be performed to determine if improvement can be made to " stress the need for communication with the vendor to understand equipment characteristics / specifications and their affect on the application being proposed at Big Rock Point. Procedures will be modified if necessary. This action is expected to be completed by January 15, 1994.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The facility is currently in full compliance with regards to immediate corrective action. Actions to prevent recurrence will be completed by January j

15, 1994.

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