ML20137D424
| ML20137D424 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/20/1997 |
| From: | Addy R CMS ENERGY CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9703260159 | |
| Download: ML20137D424 (8) | |
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i A CMS Et;ergy Company
&gRxkPcintMcker Plant Kenneth P.Poeners 10269 &31 Myth Pint GeneralManager o%rlevoix, MI49720 March 20, 1997 1
Nuclear Regulatory Commission Document Control Desk i
Washington, DC 20555 DOCKET 50-155 - LICENSE DPR,A ROCK POINT PLANT - REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96012.
During a routine NRC inspection conducted from November 30, 1996, through
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January 17, 1997, two examples of a violation of NRC requirements were identified and forwarded by letter dated February 2.4, 1997.
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The violation concerns an uncontrolled leak of about 400 gallons of reactor coolant through the open control rod drive accumulator water-side-drain l
valves, an inline relief valve lifting due to the failure to remove an installed blank flange, and work control documents used to inspect and repair j
the main steam isolation valve did not contain specifications to ensure a j
proper fit between the T-slot in the valves wedge and tee on the valve stem.
Consumers Energy Company agrees with the violation as stated.
Pursuant to the direction provided in the report, find attached a Reply to tne Notice of Violation. The proposed corrective actions are intended to address the concerns identified by the violation, and to prevent recurrence of the violations.
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dy Plant Manager CC: Administrator,RegjonIII,USNRC NRC Resident Inspector - Big Rock Point ATTACHMENT gj i
i 9703260159 970320 PDR ADOCK 05000155 G
PDR CG0013 121.4K5518.B#H
ATTACHNENT CONSUNERS ENERGY CONPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 96012
'i SUBMITTED MARCH 20, 1997
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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96010 l
NOTICE OF VIOLATION Consumers Energy Company-Docket No. 50-155 a
Big Rock Point Nuclear Plant License No. DPR-6 During an NRC inspection conducted from November 30, 1996, through January 17, 1997, two examples of violations of NRC requirements were identified.
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accordance.with the " General Statement of Policy.and Procedure for NRC
' Enforcement Actions," NUREG-1600, the' violation is listed below:
1.
10 CFR 50,' Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality shall be prescribed by documented instructions,' procedures, or drawings,.of a l
type appropriate to the circumstances.
J Contrary to the above:
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On January 2,1997, surveillance procedure TV-02, " Containment Integrated Leak Rate Test," Rev 28., an activity affecting quality, was inappropriate to the circumstances in that 2
performance of the procedure resulted in 1) an uncontrolled leak i
of about 400 gallons of reactor coolant through the open CRD accumulator water-side-drain valves and 2) an inline relief valve lifting due to the failure _to remove a installed blank flange.
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In November 1994, the work control documents used to inspect and repair the main steam isolation valve, M0-7050, an activity 3
affecting quality, were inappropriate to the circumstances in that l
they did not contain specifications to. ensure a proper fit between the T-slot in the valve wedge and' tee on the valve stem.
k This is a Severity Level IV violation (Supplement I).
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Consumers Energy Company's response is provided by below.
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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96010 Violation 96012-A.1 On January 2, 1997, surveillance procedure TV-02, " Containment Integrated Leak Rate Test," Rev 28., an activity affecting quality, was inappropriate to the circumstances in that performance of the procedure resulted in an uncontrolled leak of about 400 gallons of reactor coolant through the open CRD accumulator water-side-drain valves.
Consumers Energy Company agrees with the violation as stated.
I. Reason for the violation The root cause of this event has been determined to be inadequacy of TV-02 to provide adequate detail to ensure safe depressurization of the nitrogen side of the accumulators.
II. The corrective steos that have been taken and the results achieved.
A memorandum was sent to each member of the Operations Department to clarify the expectations of operator use of Section 7, Equipment Tagging, of the System:; Operating Protecures. The operators have been reminded that if a procedure does not exist for a safety-related activity, the choices are to write a new procedure, or revise an existing procedure. Section 7 is expected to be used as a guideline for writing switching and tagging orders. The contents of Section 7 are not to be used as a "pocedure" in an application where a procedure does not exist.
III. The corrective steps that will be taken to avoid recurrence.
1.
By memo, and review of the memo with the operations staff, revisit managements expectations for configuration control by use of switching and tagging, control room status board, log entries and l
shift turn over procedure.
THIS ACTION WILL BE COMPLETED MAY 1, 1997.
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Revise procedures identified in Administrative Procedure 1.15, l
Conduct of Infrequently Performed Tests and Evolutions (IPTE), as (IPTE) procedures requiring an IPTE briefing prior to the point of 1
manipulation of plant equipment affecting configuration control.
THIS ACTION WILL BE COMPLETED JUNE 1, 1997.
3.
Develop a case study to address the lessons learned from this event, with emphasis on the following:
Lack of protecting plant design boundaries; Configuration control by use of procedures, switching and tagging, status board, log entries, team communications, and shift turnover;
REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96010 Recognizing when to use and use of, a good questioning attitude; Adequate pre-job briefings by shifts based on task involved and relative complexity of task.
THIS ACTION WILL BE COMPLETED JULY 1, 1997.
4.
Conduct a process of review as necessary to determine compliance with Administrative Procedure 1.1.1 for TV and TR tests prior to use during the next REF0VT, with particular emphasis on the requirements of Section 5.6.11, " Level of Instructional Detail."
A Utilize a process which incorporates procedure step review by a qualified operator (A0, RO) to determine the adequacy of the steps to be performed based on complexity of the task and skill of the operator.
THIS ACTION WILL BE COMPLETED JULY 1, 1997.
Revise lesson plan BAE-01 " Effective Communication," include condition report C-BRP-97-001 and incorporate into simulator training.
THIS ACTION WILL BE COMPLETED BY JANUARY 15, 1998.
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Revise TV-02, " Containment Integrated Leak Rate Test," and enhance as follows:
Ensure compliance with Administrative Procedure 1.1.1, (with emphasis on Section 5.6.11, Level of Instructional Detail).
Identify Precautions and Limitations applicable to each major section (ie, Operations Test Preparations, Maintenance Test Preparations, 18C Test Preparations, etc) such that revisions of the procedure can more easily identify statements applicable to their tasks.
Identify sections of TV-02 requiring coverage in a pre-job-briefing prior to allowing preliminary work assignments, on and for each department affected, add a sign-off for the completion of this briefing.
Utilize a process which incorporates procedure step review by a qualified operator (A0, R0) to determine adequacy of the steps to be parformed based on complexity of the task and skill of the operator.
THIS ACTION WILL BE COMPLETED MARCH 31, 1998. THIS DAiE IS BASED ON PREPARING l
TOR THE NEXT ILRT.
REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96010 IV. The date when the facility will be in' full comoliance.
.The facility is currently in full compliance.
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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96010 Violation 96012-A.2 On January 2, 1997, surveillance procedure TV-02, " Containment Integrated Leak Rate Test," Rev 28., an activity affecting quality, was inappropriate to the circumstances in that performance of the procedure resulted in an inline relief valve lifting due to the failure to remove a installed blank flange.
Consumers Energy Company agrees with the violation as stated. This activity is also discussed in Licensee Event Report 97-001, Test Not performed in Accordance With Appendix J to part 50 dated January 31, 1997.
I. Reason for the violation.
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An inadequate procedure precipitated the event. The procedure does not provide the appropriate amount of detail for the outboard blind flange installation, which can lead to a nonconforming test.
II. The corrective steos that have been taken and the results achieved.
The blind flange was removed, a new gasket was inserted, a successful LLRT was performed on H-80, and containment sphere pressurization resumed.
III. The corrective steos that will be taken to avoid recurrence.
Station procedure TV-02, Containment Integrated Leak Rate Test (ILRT), will be revised to provide direction with respect to the outboard blind flange on containment penetration H-80.
THIS ACTION WILL BE COMPLETED BY MAY 1, 1997.
IV. The date when the facility will be in full compliance.
The facility is currently in full compliance.
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i REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 96010 Violation 96012-B In Noverber 1994, the work control documents used to inspect and repair the main steam isolation valve, M0-7050, an activity affecting quality, were inappropriate to the circumstances in that they did not contain specifications to ensure a proper fit between the T-slot in the valve wedge and tee on the valve stem.
Consumers Energy Company agrees with the violation as stated.
I. Reason for the Violation 1
The maintenance order that directed the replacement of the stem and disc had no stem-to-disk clearance details specified, and therefore, the parts used in these valves were not properly " field fit" as required by the original valve manufacturer. The parts were made to the original valve specifications which had very tight stem-to-disk clearances requiring field fitting of the disk to the stem. The stem clearance on Powell valves made after the mid 1960's were increased to improve disc seating, eliminating the need to field fit a new disk. Over reliance on disk flex and inadequate fit up techniques resulted in the poor disk fit up. The procedure to repair the MSIV did not have adequate guidance for the fit up of a new disk.
II. The corrective steps that have been taken and the results achieved.
M0-7050 was reassembled. Leak rate and V0TES tests were performed and determined to be acceptable.
III. The corrective steps that will be taken to avoid recurrence.
Maintenance procedures for Powell gate valves similar to M0-7050 will be revised to incorporate specifications to ensure a proper fit between the T-slot in the valve wedge and tee on the valve stem.
THIS ACTION WILL BE COMPLETED JULY 1, 1997.
IV. The date when the facility will be in full comoliance.
The facility is currently in full compliance.
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