ML20059J307
| ML20059J307 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/17/1994 |
| From: | Donnelly P CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401310436 | |
| Download: ML20059J307 (5) | |
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g Patrick M DonneHy Plant Manager POWERING MICHIGAN'S PROGRESS Big Rod Pmnt Nuclear Plant. 10269 05-31 Nonh. CharHrvoix. MI 49720 4
January 17, 1994 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 93019; ITEM 01: FAILURE TO EVALUATE RESULTS OF VOTES TESTING FOR MOTOR OPERATOR (MO)-7053.
NRC Routine Safety Inspection report conducted for the period October 20, 1993, through December 14, 1993, identified an apparent violation of NRC.
requirements. The violation concerns the failure to evaluate the results of static V0TES (Valve Operation Test and Evaluation Sysiem) testing at the final "as left" torque switch setting for motor operator (MO) 7053, the Emergency Condenser Outlet Valve operator for loop No. 2, conducted August 4,1993.
The NRC review of the safety function of the valve concluded that the violation was of minor safety significance as the opening function of the valve was not impaired. However, the root cause of this event indicates that efforts need to be improved in the review and quality assurance of testing and test results for plant equipment.
l Consumers Power Company does not contest the violation. Pursuant to the
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direction discussed in the report, find attached a Reply to the Notice of Violation.
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c Patrick H Donnelly Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point ATTACHMENT gg13gggkON0055-
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ATTACHMENT CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 93019 ITEM 01 Response dated January 17, 1994 i
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RESPONSE TO NRC INSPECTION REPORT VIOLATION'93019-01 VIOLATION 93019-01 4
10 CFR Part 50, Appendix B, Criterion XI, requires, in part, that measures be established to ensure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Test results shall be documented and evaluated to ensure that test requirements have been satisfied.
Contrary to the above, the results of static VOTT! testing at the final, as-left torque switch setting for MO-7053 conductri t i August 4,1993, were not evaluated prior to the return to service of the yal e on August 28, 1993, and were found to be unacceptable on November 5, 1993, when the valve was stroked open and subsequently would not close.
This is a Severity level IV Violation.
- 1) Reason for the Violation During the performance of VOTES testing on V0P-7053 (Work Order 12300757),the torque switch was set to 1.25, tested and documented on VOTES test number 9.
Neither the results of V0TES test number 9 were entered into procedure MGP-39 (Motor Operated Valves Post Maintenance / Acceptance Testing) nor were they attached to the work order. The previous V0TES test number 8 and its data were used for completion of the work order. The test number 8 data was acceptable, however the as-left settings of test number 9 did not provide the required minimum closing thrust.
Problem Statement (s) and Root Cause(s):
- 1. The repairworker did not include the latest V0TES test report in the work order. Administrative procedure 3.2.1.1, Processing Work Requests / Work Orders, requires that a verification be made to insure that the activity has been completed as intended and documented.
The root cause is lack of attention to detail and communications between the two workers completing the work order.
- 2. The assigned supervisor did not verify that the latest VOTES test was attached to the work order. Administrative procedure 3.2.1.1 states that the assigned supervisor shall ensure that all work specified on the work order has been performed and the data demonstrates that the equipment can be returned to service.
The root cause is a less than adequate understanding of what was expected of the assigned supervisor in his review.
Contributing factors statement and root cause:
The Motor Operated Valve Coordinator verbally provided an inadequately reviewed anticipated minimum required closing thrust, based on verbal field data.
The root cause is less than adequate verification of field data due to time constraints, availability of technical staff, and inappropriate verbal communications.
g RESPONSE TO NRC INSPECTION REPORT VIOLATION 93019-01
- 2) The corrective steos that have been taken and the results achieved a) On November 5,1993, at 0445, Emergency Condenser loop #2 was declared inoperable. A limiting condition of operation per facility technical specifications was entered. Required operability testing of the redundant loop #1 was accomplished by 0538.
b) On November 9,1993, an Operations Memo addressing the off-normal configuration and compensatory actions required was authored by the Operations Manager.
The following conditions of operation are discussed:
- Steady state; no Emergency Condenser tube leaks.
- Steady state; Emergency Condenser tube leak occurs.
- Transient conditions; Emergency Condenser tube leak occurs.
- Placing the Emergency Condenser in operation.
- 3) The corrective stens that will be taken to avoid further violations
- 1. Perform a V0TES test on V0P-7053 and the,ecessary torque switch adjustment to ensure valve closing and opening thr u values meet MGP-39 acceptance criteria.
- 2. Revise EA-AIR-A-NL-89-41-0 (Thrust and Torque Calculation for M0-7053) to take into account the average running load data from the latest VOTES test
(#9).
- 3. Revise MGP-39 minimum closing thrust value to its required value as determined by the Engineering Analysis EA-AIR-A-NL-89-41-0.
- 4. Revise work orders 12300757(V0P-7053) and 12300763(V0P-7070) to account for the latest VOTES test report data.
- 5. Revise MGP-39 to verify that the "as-left" data is from the last V0TES test performed.
- 6. Provide training and expectations for the " assigned supervisor" with regards to work order processing.
- 7. Evaluate the scope of the 1994 refueling outage MOV work. Ensure that adequate trained staff levels (assigned supervisor, MOV coordinator, i
analysis preparer, analysis reviewer and administrative reviewer) and outage schedule days exist to perform the scope of the work.
THESE ACTIONS WILL BE COMPLETED PRIOR TO THE 1994 REFUELING OUTAGE
- 4) The date when full comoliance will be achieved Facility Technical Specifications allow continued operation with one loop of the Emergency Condenser isolated. However, both of the bundles shall be available for service during cold to hot plant heatup for power production.
Therefore,- the facility remains in compliance with the Technical Specifications. If the facility is forced to go to cold shutdown prior the scheduled refueling outage in September, 1994, Corrective Steps to Avoid
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- RESPONSE 10 NRC INSPECTION REPORT VIOLATION 93019-01 Further Violations 1, 2, and 3 will be completed. The remaining corrective steps'will be addressed prior to the 1994 refueling outage.
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