ML20127N675

Responds to NRC Re Violations Noted in Insp Rept 50-155/92-17.Corrective Actions:Quality Verification Program Will Be Developed to Address Q & Non Q Equipment & Should Help Prevent Occurrences in Future

ML20127N675
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/24/1992
From:	Beckman W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9212010368
Download: ML20127N675 (6)

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f ti CORStimEIS William L Beckman

&gs$h 11 ant Man.txer POWERING MICHIGAN'S FROGRESS Big Rock Point Nuclear Plant,10269 US-31 North, Charlevoix, MI 49720 November 24, 1992 Nuclear Regulatory Commission Doc ment Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

REPLY TO A NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-155/92017) -

REVISION 1 Enclead is the reply to the Notice of Violation described in the Nuclear Regulatory Commission Inspection Repor' 50-155/92-017 dated July 22, 1992.

This revision is being submitted to update the progress of corrective steps taken in regards to Violation 92-017-03, and to adjust the date when the

'acility is expected to be in full compliance.

The onerations department has spanded the scope of the required actions, warranting the modification to the i

completion date.

This extension was discussed with Region III personnel during a public i..eeting at Big Rock Point on October 27, 1992.

i Wil afn L Beckman Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point ATTACHNENT I

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ATTACHMENT Consumers Power Company Big Rock Point Plant Docket 50-155 REVISION 1 REPLY T6 VI0lATION 92-017 4

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V10LATavN 92-017-01 1 of the Technical Specifications states in part, " Written Section 6.8: hall be established, implemented, and maintained for all procedures s structures, systems, components, and safety actions defined in the Big Rock Point Quality List." Section 5.2 of Chapter 13 of Volume 17 of the quality list requires procedures for maintenance and operations activities.

Section 5.6.] of Administrative Procedure 2.1.4, " Plant Status and Equipment Control,"

which provides operational requirements for removing equipment from service, states, in part, that prior to giving his permission, the shift supervisor shall verify that the equipment or system to be removed from service can be removed and that the method used to remove it from service is proper.

Contrary to the above, on January 10, 1992, maintenance order period w instructions EPS-0003 and SPS-0001 were released to allow work on tk LE-X and K-27-X emergency diesel generator overvoltage and undervoltage ;.:ays respectively without verifying that both relays could be removed from service 1

at the same time.

l Reason For The Violation 4

The Shift Supervisor released two maintenance orders which permitted concurrent testing of the Emergancy Die <,el undervoltage (K-27-X) and over-voltage (K-59-X) relays. This action was determined to be personnel error.

Neither the Shift Supervisor nor the Technician performing the work were aware of the consecuences that might occur because of inadequate job planning.

This is considered to be an isolated incident.

Corrective Action Taken and Results Achieved l

1.

The appropriate activities in the Periodic Activities Controls Program were updated to include a reference to the fact that only one relay (K-27-X or K-59-X) be released at any one time for prevent'le maintenance.

This action was comoleted by May 4,1992, i

2.

A memorandum was addressed to the operations department describing that C-43, the auto transfer to the emergency generator the C01 console, may not work to defeat ACB (air circuit breaker) closure if both K-27-X and K-59-X are " picked up" at the same time. This memorandum was inued by May 9, 1992.

~orrective Steps To Be Taken To Avoid Further Violations Several ongning actions / programs will contribute to avoiding occurrences such as the concurrent testing of the EDG under and overvoltage relays:

1.

Quality Verification Program This program is expected to offer an inspection planning process.

Both "Q" AND Non "Q" equipment will fall under the requirements of the program.

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2.

Planning / Scheduling is being improved by:

- developing a planning guide

- assigning a maintenance supervisor as a full-time planner

- hiring an additional planner.

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Converting the current Preventive Maintenance Program to a computerized Advanced Maintenance Management System (AMMS).

Date When Full Comoliance Will Be Achieved The facility will be in full-compliance by the end of 1992.

VIOLATION 92-017-02 Section 6.8.1 nf the Technical Specifications states in part, " Written procedures shall be established, implemented, and maintained for all structures, systems, components and safety actions defined in the Big Rock Point Quality List." Section 5.2 of Chapter 13 of Volume 17 of the quality list requires orocedures for maintenaace and operations activities.

Section 5.3.2.b of Administrative Procedure 3.2.1, " Maintenance Order Processing,"

states in part that maintenance of equipment shall be planned and performed in accordance with written-procedures, documented instructions, or drawings that l

are appropriate to the circumstances.

Contrary to the above, on March 10, 1992, a one-inch compression fitting on the number one recirculation pump (RCP) seal-water heat exchanger was installod with maintenance order #91-PCS-0033. This maintenance order failed to contain adequate instructions for the proper installation of the compression fitting.

Reason For The Violatio.n The maintenance order failed to conta h adequate instructions for tha installation of the compression fitting for the following reasons:

1.

Plant and Field Maintenance Service repairmen have received training.on compression fitting installation. The skill of the craft was assumed to-be adequate to perform this task without special_-instruction. Matching the level of the experience of the crew commensurate to the level of I

detail in pocedures will always provide a challenge for managers.

2.

The Q-list does not classify RCP seal water exchangers as being safety-related, therefore they are not subject to the requirements of the Quality Program. This,would account _for an inspection of the-compression fitting installation not being performed.

Corrective Action-Taken-and Results Achieved 1.

-New instructions / inspection checklist for compression fittings (high pressure, greater than or equal. to 3/4 inch) were written and distributed to maintenance supervisors, planners, training and engineering-departments. -The maintenance' planners will use these when processing future applicable maintenance orders.

This= action was' completed by May-28, 1992.

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2.

By July 3,1992, upgraded compression type fitting training had been i

administered to Big Rock Point mechanical / electrical repairmen._ The i

training included hands-on fitting assembly and use of the' newly 1

developed instruction / inspection checklist. The lesson plans for skills L

center training have also been upgraded to_ include the revision described below.

l Corrective Action To Be Taken To Prevent Recurrence i

1.

.The "Q" list classification of both one-inch and 3/4 inch recirculation pump seal water heat exchanger will be reevaluated to determine if the heat exchanger should be classified as "0" This action will be completed by November 1,1992.

2.

The Quality Verification Program is being developed to address 'Q" and Non "Q" equipment, and should help prevent these types of occurrences -in I

the future.

Date When Full Compliance Will Be Achieved The facility will be in full compliance by the end of 1992.

I VIOLATION 92-017-03 10 CFR Part 50, Appendix B, Criterion V, states,-in part, that activities affecting quality shall be prescribed in documented instructions, procedures, or drawings of a type appropriate to the circumstances.

l Contrary to the above, on May 6, 1992, tagging order #92-0491 to remove the station battery charger from service did not contain instructions appropriate to the circumstances in that the instruction incorrectly specified the removal i

of the battery leads and not the battery charger leads.

Reason For The Violation 1he reason for the violation has been identified as personnel error. and i

procedural inadequacy. During the development of the tagging-order, the shift-supervisor and control room operator inadvertently substituted the word-l

" battery" for " battery charger"-during their thought process. Within the equipment tagging section of the System Operating Procedure-S0P-28, Station l

Power, it is not clear that the cables to be lifted during this sequences are l

between the charger and the battery.

In. addition, SOP-28 had yet to be reviewed in accordance with a procedure improvement program established in i-1991 per commitments made in Response to Notice of Violation (NRC 50-155/

91-005) Failure to Follow Procedures, dated July 9,1991.

- Corrective Action Taken and Results Achieved A.

Section 7.5 of S0P-28, Station Power, was revised to clarify the. task of L

removing the station battery charger from ~.arvice. The revision was issued on July 14, 1992.

1 B.

A memorandum summarizing this event and emphasizing the need for L

obtaining outside assistance when the shift personnel cannot.readily_

identify the proper method or impact of removing equipment from service was issued and reviewed by operations personnel. This-action was:

completed May 30, 1992.

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Corrective 'Steos To Be Taken To Avoid Further Violations 1.

Reuiew the equipment tagging section of the System Operating Procedures (Section 7.0) and the Master Switching and Tagging Orders.

Make revisions, as required, to include the limiting conditions and necessary cautions for operation when equipment is removed from service. This action will be completed by December 31, 1992.

2.

A "Self Checking Program" was implemented during October,1992 in the operations department. The purpose of this program is to address " blind compliance issues" as procedures improve and become more relied upon by the operating shifts.

The program was developed using the STARR (Stop, Think, Act, Review, Repori; acronym.

Follow up action will include, but is not limited to posters, stamps and shirts. This will be an " ongoing" action.

3.

An Administrative Procedure was authored to address SOER 91-01:

Infrequently Performed Task / Evaluations.

The new procedure considers training, management expectations, special controls and the need for increased controls to control these types of tasks.

This procedure was approved for use September 29, 1992.

4.

A Procedure Implementation Task Force is currently being orghnized and is expected to be in place by the end of the 2nd quarter of 1993.

The coal of this task force is to formulate guidelines to help the operator answer procedurr need question.

5.

A " Morning Meeting" has recently been established as a forum for daily planning.

The meeting is attended by department heads and representative from major departments.

The meetings are designed to be short duration, and encourage a team approach to problem solving.

Qate When Full Comoliance Will Be Achieved The facility is expected to be in full compliance by July of 1993, i

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