ML20154B723

Responds to NRC Re Violations Noted in Insp Rept 50-155/88-13.Corrective Actions:Unmarked Procedures Removed from Work Spaces & Instruction on Correct Practices for Using Procedures Provided to Personnel

ML20154B723
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/06/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8809140093
Download: ML20154B723 (6)

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Consumers Power Kenneth W Berry Dvector MM Mciter Lkentmg gyg General Omces 1:45 West Pomell Roed. Jeckson. MI 49201 e (51h 7s81836 September 6, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 s

DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO INSPECTION REPORT 88013 Nuclear Regulatory Inspection Report 88013, dated August 5, 1988 transmitted two violations requiring a written response within 30 days. Consumers Power Company's response is provided herein.

Violation (155/88013-01) P

! 10 CTR 50, Appendix B, Criterion X, "Inspection," as implemented by Big Rock Point's "Quality Assurance Description for Operational Nuclear Pover Plants" and described in Section 10, requires that inspections shall be performed by

< individuals other than those who performed r.he activity being inspected and examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality. ,

Contrary to the above, during the initial diaphragm replacement performed April and May 1988, on the Control Rod Drive Scram Valves, a safety related system, the licensee failed to inspect a complete disassembly, repair, and reassembly process of any single valve and failed to perform any dimensional check of the diaphrages or a comparison between the diaphragus for consistency prior to installation.

Response ,

Consueers Power Company received a General Electric Service Information Letter

! 'SIL), Number 457, which stated in part: "Failures of scram valve diaphrages l tre discovered recently at a BWR located in the L'nited States. Four failures securred while the plant was at power. Two of these failures caused control rod insertions. There were no indications that the failures were about to occur.... Examinations of the nylon-reinforced Buna N material shoved that the failed diaphrages had long, diametrically oriented tears. Scram valve OC0988-0115-NLO4 0  :

0809140093 000906 / I POR ADOCK 05000155 O G PPAJ g

• Huelcar R:gulatory Commission 2 Big Rock Point Plant Response to IR 88013 September 6, 1988 diaphragms are non-safety related, commercial grade components. ... No adverse safety consequences result from scram valve diaphragm failures."

SIL 457 recommended a maximum service life of fifteen years. The installed scram valve diaphragus at Big Rock Point had been in service for approximately 25 years. As a result of SIL 457, a decision was made to remove two of the sixty-four scram valve diaphrages for testing. Maintenance instructions taken from the valve manufacturer's service information were developed for the removal and installation of scram valve diaphragas. t During the 1987 refueling outage, two scram valve diaphrages (one inlet and one outlet scram valve diaphragm) were changed out. The two removed ,

diaphrages were sent to Consumers Power Company's test laboratory for testing.

1 The tests confirmed that the diaphrages removed from service were still j serviceable. Consurers Power Company's Test Laboratory Project 138719-060-006

Report stated that, "based on the cracking, wear and decrease in tensile l

] strength of the diaphragus tested, the Laboratory concludes that there is no l i reason to expect immediate failure on the diaphrages. However, a schedule for ,

replacement of the diaphrages should be established." To enhance reliability,  ;

j a decision was made to replace the remaining sixty-two scram valve diaphragms  !

! during the 1988 refueling outage.

Following the scram valve diaphragm replacement activities, post-maintenance testing identified leakage on several inlet and outlet scram valve actuators.

Leakage investigations determined that all diaphragas were installed in the 2 frverted configuration, including the two diaphrages installed during the 1987 refueling outage. Because of these problems, a decision was made to replace [

, all si ey-four scram valve diaphragms a second time. The cause for installing

! the diaphrages in the inverted position was determined to bei 1) When the scram valve actuators were disassembled, it was observed that the diaphragms had taken on a permanent set-form from being in service for approximately

] twenty-five years. This diaphragm set-form caused the repair persennel to l conclude thac the diaphrages should be installed in a similar configuration '

l which af terwards was determined to be the inverted position. And, 2) The '

manufacturer's drawing showing the internals of the scram valve actuator was  :

ambiguous as to how the diaphrages should be installed. The valve  ;

manufacturer was contacted. The manufacturer stated that a diaphragn installed in the inverted configuration should have no adverse effect on valve i nerformance or diaphragm leakage. In fact, the two diaphrages installed l during the 1987 refueling outage support this determination since they had l been in service for approximately one year providing acceptable performance. j

! The cause of the leakage was attributed tot 1) The valve stem center hole in

some of the diaphragns was found to be factory punched off-center by as much ,

as 3/16 of an inch. Because of this fact, the diaphrages were stretched to I 3

! allow bolt hole aligneent. This caused the diaphragm bolt holes to be j elongated and pinched by the bolts when they were installed, and 2) other i I contributing factors may have included inadequate cleaning of surfaces prior i

! to assembly, and not following a specified torque sequence. As a result of l l

these considerations, procedures were reviced to clarify diaphragn  ;

or *atation, specify torquing sequence and cleaning requirements were  ;

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. Nuclear Reguletory Commission 3 Pig Rock Point Plant lmsponse to IR 88013 September 6, 1988 i

established. In addition, the valve stem center hole location was checked and the diaphrsges were rotated to the best fit position prior to reassembly.

l Theci sctions were completed before the second replacement activities were started. Four diaphrages were rejected on the basis of eccentricity and 1 replaced with diaphrages drawn from stock. All sixty-four scram valves t successfully passed post-maintenance testing.

l Consumers Power Company's QA program is a graded approach program. This allows catablishment of necessary controls based on the item, system or component's importance to safety. As stated in 10 CFR 50 Appendix B, Criterion X:

"Examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality".

Consumers Power Company's QA program also allows Consumers Power Company to 1 apply t'aa,ae controle to enhance the reliability of items that are not i safety related. The scram valves are safety-related; however, the diaphragms

are not considered safety-related c'mponents. They are not required to shut

' down the reactor, maintain it in a hut down condition, or mitigate the consequences of an accident. The s_ ram valve operates in a conservative mode ao that if air pressure is lost, or if a diaphragm fails, the control rod

< drive will be inserted ir..o the core. Big Rock Point has applied elements of

! the QA program to the diaphragms because of their relationship to the scram valves. However, the diaphrages do not require, nor are they given, full 10 CFA 50 Appendix B controls. The scram valves were in the process of post-maintenance testing when the diaphragm failures were identified. During diaphragm replacement activities, the scram valves were never declared operable or placed in service.

4 I CPC-2A is the Quality Assurance Program for Consumers Power Company's Nuclear

Operations Department. CPC-24 and its revisions have been reviewed and approved by the Nuclear Regulatory Commission. Nuclear Operations Departmont i Standards (NODS) delineate the requirements established in CPC-2A. NODS-QO3 delineates the requirements for inspection. NODS-QO3 includes a listing of I activities that require mandatory Hold Points as well as activities that recommend Notification Points.

Quality control reviews of the diaphragm replacement activity were completed

! prior to the actisity commencing. The mainteriance order and the procedure to l perform the work activity v9re reviewed and the scope of the activity was considered. The diaphragm taplacement was not considered to be a complex

! activity and did n)t fall within those requirements in NODS-QO3 for either a Hold or Netification Point. In addition, the installation procedure was shown to be adequate for the skills of the mainterance personnel performing the i task, based on the fact that the scram valve diaphragn ren, val and installation maintenance activities were successfully accowylished in 1987 and j the scram valve diaphrages had parformed satisfactorily for approximately one j year after installation. Also, post-maintenance test.1g vas required on each valve prior to that valve being returned to service and being relied on for its intendid function. Based on these facts, and other activities requiring quality control inv;1vecent ongoing at the same tire, a conclusion was reached to perform spot check inspections of the scram valve diaphragm replacement activity. The inspections involved visiting the work location to assure the I

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• Nucicar Reguletory Commicsion 4 Big Rock Point Plant Response to IR 88013 September 6, 1988 maintenance order was approi

• and correct, that the material being used was r correct and accepted, and the, the procedure was current and being completed as the job progressed.

ANSI N 45.2.13 - 1976 is committed to by CPC-2A. Section 10.3, Methods of Acceptance Selection and Implementation, states: "Purchaser methods used to accept an item or service from a Supplier are source verification, receiving inspection, Supplier certificate of conformance, post installation test at the j nuclear power plant site, or a combination thereof."

The scram velve diaphrages were ordered commercial grade to invoke portions of the QA program to a non-safety-related component for the inclusion of administrative controls for procurement, receipt and control of the items.

They were procured as a commercial grade item on the basis of a manufacturer's published description (catalog no. A99A1007 and part number). The description, as well as other manufacturer's information, does not provide the diaphragm dimensions or tolerances. The procurement document specified no ,

substitutions and a Certificate of Conformance was received stating that the diaphragms were exact replacements. Quality Control verified through receipt inspection that the diaphragms were, in fact, those requested by the purchase order and that they met the stated purchase order requirements. In addition,  :

a comparison check of the diaphrages against each other, as suggested by the inspection report, would not have been an accurate verification of their '

correctness since there vas no template or dimensions of the actual valve diaphragm available. Post-maintenance testing was also specified and performed for the diaphragu replacement activity. As a result, three out of four method 4 (of which any one method may be adequate) specified in ANSI N 45.2.13 were employed. <

] The quality control activities involved with the scram valve diaphragm  !

replacement were in full compliance with Consumers Power Company's Quality i Assurance Program. At no time was there a threat to the health and safety of the public. Based on the facts presented, and that 10 CFR 50 Appendix B requirements do not apply to non-safety-related component maintenance, no violation of Quality Assurance requirements was committed and full compliance has been achieved with regard to the scram valves.

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i From the perspective of overall quality improvement, Consumers Power Company l recognizes and is concerned that a relatively simple repair activity was not '

successfully accomplished and resulted in considerable rework. Therefore, we

have evaluated inspection guidanco given in NODS-QO3 and have determined that i additional direction should be provided with respect to inspection of l activities done infrequently, for the first time, or in the first of a series.

Revision of N0DS-QO3 to include additional guidance will be completed by l December 15, 1988. i t  ;

b OC0988-0115-NLO4  !

• Nucloar Regulatory Conuniscion 5 Big Rock Point Plant l Response to IR 88013 ,

September 6, 1988 l ViolationJ155/88013-02) 10 CFR 50 Appendix B, Criterion V. "Instructions, Procedures, and Drawings," i as-implemented by big Rock Point's "Quality Assurance Program Description for Operational Nuclear Power Plants," and described in Section 5.0, requires that activities affecting quality shall be prescribed by documented procedures.

Administrative Procedure 4.1.8, Revision 1 dated February 12, 1988, Section ,

12.0 requires that controlled documents needed as working level procedures l shell be clearly marked "Working Copy" or "Working Controlled Copy." r Contrary to the above, copies of the controlled documents listed below were -

found at their associated work site without being marked "Working Copy" or "Working Controlled Copy " on the date shown:  !

• June 18, 1988: System Operating Precedures (SOP) 19. "Make up System,"

Revision 140.

• June 21, 1988: S0P 15, "Conderisate System " Revision 94.

June 21, 1988: S0P 11 "Radioactive Waste System," Revision 117.

July 6, 1988: Administrative Procedure 4.2.1, "Material Control." Revision 4

Response

Consumers Power Company recognizes the need and encourages all personnel to utilize procedures when performing safety-related activities. Administrative controls are in place to ensure copies of procedures used in the field are, in fact, the most current available. We acknowledge that we have been delinquent in implementation of the controls as identified and this is a practice that needs improvement. However, it is not our intent to have overly rigorous controls or implementation so that a barrier to utilization of approved procedures is created. This could create a situation which is detrisiental to safety in that procedures may not be used during the performance of safety-related activities. It should be recognized that effort was expended by individuals at the time to obtain a copy of a procedure to perform an activity.

Corrective Action Taken The unmarked copies of the procedures were removed from the work spaces. In addition, personnel were provided instruction on the correct practices for using procedures in the field and plant areas were checked for other unmarked copies of procedures. In the four cited cases, all of the procedures were the most current revision in effect even thuugh they were not marked correctly.

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• Nuclocr R:gulotcry Commicsion 7 Big Rock Point Plant Response to IR 88013 September 6, 1988 Corrective Action Taken To Avoid Further Noncompliance An item han been added to the routine surveillances conducted by our Quality Assurance organization to check for use of unmarked copies of procedures at more frequent intervals.

Date When Full Compliance Will Be Achieved Full compliance has been achieved.

$ e Kenneth W Berry Director. Nuclear Licensing CC Administrator. Region III. NRC NRC Resident Inspector - Big Rock Point i

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