ML20151J570
| ML20151J570 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/25/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8808030010 | |
| Download: ML20151J570 (3) | |
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Consumers Power Kenneth W Berry MGM Durctor gmg m Nuclear Lkevoeg General Othcu 1946 West Pernett mood. Jeckson. MI 49201 e (51717841636 July 25, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-1*>5 - LICENSE DPR BIG ROCK POINT PLANT -
RESPONSE TO INSPECTION REPORT 88012 Nuclear Regulatory Commission Intipection Report 88012, dated June 27, 1988 transmitted one violation requiring a written response within 30 days.
Consumers Power Company's response is provided herein.
Violation-(50$55/88012-01Aand01B)
As a result of the inspection conducted on May 23-27, 1988, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1987), the following violation was identified:
10 CFR 50, Appendix B, Criterion V, as implemented by Big Rock Point's "Quality Assurance Program Description for Operational Nuclear Power Plants "
- as described in Section 5.0, requires that activities be prescribed by procedures or drawings appropriate to the circumstances and shall be accomplished with these procedures or drawings.
Contrary to the above, maintenance procedure MGP-14. "Disassembly and Assembly of SMA-0 through SMA-4 Limitorques," Revision 3 and prints used for safety-related valves were inappropriate to the circumstances in that:
1.
The procedure and prints were used to perform maintenance on safety-related SMA 000 and 00 model operators; and 2.
Instructions were not provided for safety-related activities involving disassembly of the limit evitch and identification of the limit switch lubricant.
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Blg Rock Point Plant Response to IR 88012 July 25, 1988 Response To Item 1 Discussion:
Maintenance personnel failed to recognize that a different procedure was needed for SHA-000 and -00 model operators. Personnel felt that the existing procedure combined with the applicable vendor manuals were adequate to perform the required maintenance.
Corrective Action Taken:
Prior to completion of the operator overhaul during the 1988 refueling outage, a procedure was written, approved and used for the SHA-000 operators. The procedure also included instructions for limit switch assembly overhaul and lubricant requirements.
Corrective Action Taken to Prevent Recurrence:
A procedure will be written and approved for use for SMA-00 model operators.
Additionally, guidance will be added to all Limitorque operator procedures for overhaul of the limit switch assembly and lubricant requiremente.
Date When Full Compliance Will be Achieved:
Full compliance has been achieved for the SMA-000 operators through the issuance of the procedure.
For the SMA-00 operatore, full compliance will be achieved by issuing the procedure prior to any maintenance requiring disassembly of the operator or prior to the 1989 refueling outage.
Response To Item 2 Discussion:
In 1983, a maintenance procedure, MCP-14, was generated to inspect and overhaul Limitorque Operators based upon recommendations received during an operator rebuild with a Limitorque technician. At that time, Limitorque specified Nebula EP-0 as the only approved lubricant for environmentally qualified safety-related operators. This requirement was included in the procedure. The Limitorque recommendation was intended for the main gear box only. However, the procedure did not limit applicability to the main gear box and was later interpreted incorrectly. As a result, the procedure did not explicitly address change out of the limit switch assembly lubricant.
Subsequent to this time period, the inspections were expanded to include the limit switch assembly and a determination was made that the Nebula EP-0 lubricant was appropriate in light of information received during earlier discussions with Limitorque. During the 1985 Refueling Outage, three Limitorque Operators were overhauled and EP-0 lubricant was used in the limit switch assemblies. Personnel did not realize that a different environmentally qualified lubricant was specified for the limit switch assemblies of these Limitorque Operators.
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Big Rock Point Plant Response to IR 88012 July 25, 1988 An recent evaluation has determined that Nebula EP-0 uaed in tSe limit switch assembly of the three operators was capable of performance undet the Big Rock Point environmental conditions and did not present an operability concern. The three motor operated valves affected were two isolation valves in ti.e primary core spray system and the primary cooling water supply valve to the core spray Weat exchanger. The later valve is not located inside primary containment. A redundant core spray system containing Rotork motor operated valves and a redundant core spray heat exchanget cooling water motor-operated valve were operable and unaffected by this lubricant issue. (See Informational LER 88004 dated June 17, 1988 for additional information.)
Corrective Action Taken:
Upon being made aware of the discrepancy during the inspection, a review of maintenance records for all environmentally qualified operators was performed which identified only three operators are affected. These three operators were immediately inspected and the lubricant in the limit switch assembly changed to Mobil 28.
No other deficiencies ware observed.
Corrective Action Taken to Prevent Recurrence:
Plant maintenance procedure MGP-14 for Limitorque overhauls has been revised to include a section covering limit switch assembly inspection. The procedure specifies that Mobil 28 be used for the limit switch assembly and Nebula EP-0 be used for the main gear box. Non environmentally qualified safety-related operators will be inspected and the lubricant changed, if necessary, through routinelv scheduled preventative maintenance inspections or when corrective maintenance is performed.
Date When Full Compliance Will be Achieved:
Full compliance has been achieved through the issuance of the revised procedure.
j$cr Yu Kenneth W Berry Director Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point OC0788-0071-NLO2
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