ML20202B109

Forwards Evaluation of 13 Specific Recommendations Contained in BNL Rept of Review of Surveillance & Maint Program,In Response to CE Norelius 860506 Request

ML20202B109
Person / Time
Site:	Midland
Issue date:	07/01/1986
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler, Kkeppler J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
32736, IEIN-85-056, IEIN-85-56, NUDOCS 8607100205
Download: ML20202B109 (7)

Text

'

^

O * *

e. +

y, '

power #

@' Constimers -

Company """

,Vice President - Projects, Engineering .

y and Construction General offices: 1945 West Pernall Road, Jackson, MI 49201 * (517) 78& O453 FRICRITY E0'JTING .

dk *. M

~

' e '

. July 1, 1986 *

• 6El_gfC "h# h j

. ass c 1 -

.. D*As sM Mr.J G Keppler, Regional Administrator - ^ 1 N

~

US Nuclear Regulatory Commission- -

Region III - .

, 739 Roos.evelt! Road .

Glen Ellyn, IL 60137 -

JilDLAND ENERGY CENTER GWO 7020' ,

' 4

. DOCKET NOS.50-329 AND 50-330 MIDLAND RESPONSE"TO NRC REGION III LETTER OF MAY 6, 1986 *

. FILE: o0.4'.2, 1.300 SERIAL: 32736

Reference:

Letter C E Norelius, NRC Region III,.to J W Cook, CPCo, e dated Iky 6, 1986

' ~

The. referenced letter,transmftted~Brookhaven Na,tional Laboratory's report of its review of the Midland Surveillance and Maintenance Program and requested "our written avaluation o( the observations and recommendations in the report.

Preliminary comments wer.e provided to CPCo by the Brookhaven reviewers during the exit discussions at the conclusion of the October review. Furt.her, we discussed the specific recommendations with. Region III by phone in January 1R86 noting the relevant activities already underway at Midland and seeking l

clarification of other issues. We believe that we have been responsive to l both the intent and specifica of the recommendations and that our corporate philosophy 1.3 consistent wit'h the overall coutments. In those~ areas where the

! surveillance and inaintenance program vary from the Brookhaven recommendations we believe the, approach we have taken is appropriate given the Midland Energy Center cigcumstances. The program accommodates both our option to finish

- Midland as a nuclear facility and our ability to preserve the value of' sa(ety-related components for possible sal,e. , ,

l .

. n.

l The enclosure to the letter provides our evaluation of the 13 specific recommendations. -

i JWC/WkB/lr .

CC: RBlandsman, USNRC Region III ,

TSMichae1s, USNRC.NRR (C l \~

~

8607100205 860701 PDR ADOCK 05000329 '

G PDR . rj 1986 OC0686-0054A-MP02

- -. ]

.e

'l ' " ,

J-Enclosu're to JWCook, Letter dated Jufy' 1,1986 -

Sgrial 32736 .-

) .

The following paragraphs provide Consumers Power's evalization of the observa - '

tions gud recommendations containesi in .the Brookhaven National . Laboratory

• (BNL) Technical, Review Report (the " Report"), dated January 6, 1986, and which' -

documents the BNL October 14-18, 19 &5 Midland Energy Center. Review. The Report wastransmittedtodonsumersPowerCompanionMay6,1986. -

The evaluatioc addresses the# recommendations.in t.he order given on Page 19 of .

the Report. Commentsemade in other sections of the Report are addressed in the evaluation responses to the recommendation mo'st closely associated with' those comments. -2 Recommendation 1 ,

" Conduct a QA audit of the Prdventative' Maintenance (PM) Program iniplementa- '

, tioninearlyg986(1.15)." , ..

Response .

The QA Department estab'lished in late 1985 an objective to " Verify by July 30,

-1986 that all elements.of the Q-PM Program are in place and each PM activity has been conducted satisfa.ctorily at le,ast once." The accompli'shment of th,is objectivp.will result in a compre,hensive review of preventive mainte' nance for ,

a'll Midland Energy,Centet Q equipment and a determinati'on of its adequacy to date. This analysis began in January 1986 and will be completed as scheduled ,

in July 1986. . A report 'is to be issued on July 30, 1986 and will address the following questions: , ,

e . .

a. Whether a review has been made by Engineering of all Q equipment for

. appropriate inclusion in the preventive maintenance program? -

b. Where . preventive mai,nt'enance activities are required, are' they documented by work orders and maintenance instructions?

c. Has the required preventive maintenance been performed and were the criteria and execution adequate?

Our' review of the results to date indicate that the preventive maintenance program is being successfully implemented and equ,ipment is being appropriately l preserved in a serviceable condition, .

Recommendation 2 l

i

, " Modify the 'means of- QA nonconformance reporting and dispositioning to pre- .

clude repo,rts remai'ning open for extended periods of time (1.6)." ,

Response -

As stated wi' thin the -Brookhaven Report and ,in the MI'dlan'd Energy Center Quality Assurance Program Plan, 1,t is Consumers Power Company-s intent to e

, . process further only th'ose NCRs that are req'uired to support shutdown activi-l gies and equipment salvage. To preclude NCRs remaining open for extended ,

pdriods of time, the Midland Project established an objective to cause disposition of all nonconformance and audit findings related to S&M activities ,

within 10 working dsys. The, tracking mechagism used for this objective is the l

- -s l

MIO686-0029A-MP03, ,

( _

e -g n-es . (b - ,

2 e .

. Enclosura to JWCook Letter s dated July 1, 1986 .

. ~ Serial 32736

- - a.  %

, 9 J.

- t

. NCR Status Report, which is required by Midland Project Shutdown Organizat' ion .

Procedure QA-006, section $ 10. ,The monthly NCR Status Report incitf. des the-forecast dates for disposi? ion imp'1ementation.by the. action organization.

Since the NCR sta,tus report was initiated in February 1986,-dispositions of all except.1 of the S&M related NCRs have been made within 10 working' days .* '

e with'an average closure time of 4 days. Disposition of the one NCR not.

meeting the closure time objective was made .in 14 days. .

e Recommendation 3 -

' ~

Deviations from Vendor and/or Architect / Engineer layup or PM requirements .-

should be technidally justified, formally approve.d .and documented (2.3)."- -

Response ,

% e preventive maintenance criteria'were generated by Engineering . based on . .

balancing the cost of the program against the projected future benefits. The factors considered duri,ng the generation of the criterda~were- .

a) Manpower Requireinents * '

b) Anticipat.ed. Costs ,

+-

c) Vendor and Ar'chitect/ Engineer Maintenance Recominendations d) ' Technical Expertise and Expe'rience of Company Personn'el e) Existing Pr6 grams at,.0ther Laid Up Nuclear Plants .

. f) AssumedpurationoftheShutdown

• Some deviations from Vendor rec'ommendations were' expected based on the above factors and the.overall program objectivese ,

Prior to the shutdown, t.he Architec.t/ Engineer program was consistent with the Vendor recommend,ations to protect equipment and retain warranties. Following .

shutdowg, Corfsumers* w'hs willing to accept

• some refurbishment or geplacement or equipment prior to,a nuclear res, tart if,any unacceptable degradation occurred. f' ,

s The Quality Assurance Program Plan states "Therefore an essential element of -

controlling surveillance and niaintenance work is not the ability to measure

. agAnst a pre-established design basis, but rather the ability to assure .

. identification. of the nattge and scope of any chariges such that surveillance .'

and maintenance work can later be evaluated and dispositioned in accordance -

with the desigh basis applicab'le to the Project'at the time of Proj,ect re-

• start." (Page 8 of 44.)

The philosophy reflected,the obje'etive to protect

> the MEC equipment for'a possible nuclear restart. Experience to date shows-that equipment preservation is consistent with the Company philosophy, le maintaining it for the intended service. ,

Recommendation 4 .

"Incorpora& Limitorque Motor Operators into the. Surveillance'a'nd Maintenance Prog' ram .(2.3) ." , ,

o e

• e Y

s .

.M10686-0029A-MP03'

~

'. 3 Enclosure to JWCock Letter dated July 1, 1986 Serial .32736 .

Response .

The Limitorque motor operators were included in the S&M program. The BNL comments caused the maintenance criteria for the valve operators to be reviewed, and it was tentatively decided to add a requirement to preserve the electrical contacts. We later reviewed the cost of maintaining the valve operators versus future replacement of the electrical contacts. We concluded that it would be more cost effective to inspect contacts and replace them before startup rather than to spray the contacts periodically with a preservative. The Bechtel trend records show that less than 2% of the motor operated valves required contact replacement after the valves were in storage for 45 months. This information was provided to Brookhaven's Mr W Gunther during a telephone conversation of March 17, 1986, during which he agreed with this recommendation. The commitment to inspect the valve operators and repair them if necessary was added to our Commitment Management System as a required action for a nuclear construction r'estart.

m Recomme'ndation 5 .-

" Contact valve manufacture'rs to verify that.present storage and layup practic-es are acceptable (2.3)."

Response ~

CPCo had discussions with other shut down nuclea,r projects regarding their

. g; practices on long term layup of valves, including the, recommendations of various Vendors. The conclusion.was that to properly layup the valves for a g>

long term shutdown,- the valve packing should. be removed and the valve lef t partially open. This would require a significant, effort to complete as part of the surveillance and maintenance program. During the initial stages of the layup program, it was believed more important ce drain .and dry the systems for layup. The damage that could occur from not r6 caving.the packing and opening.

the . valve may be corrosion of the valve ett er .orrosion between the valve plug' and seat. There has been some corre Lcn valve stems at Washington Public Power Supply System on specific t.em E.t</ial when in contact with packing. It was therefore CPCo's expectation.to see some pitting when the valve stems are inspected but as with WPPSS, we expect the pittin,g to be limited.

On a project restart, it was planned that the valve packing would have to be removed and new packing installed prior to placing the systems into service.

CPCo had planned to inspect valve stems and seating surfaces at that time.

~

~

Recommendation 6 '

" Engineering activity to. preserve and protect the vessel needs to be acceler-ated rapidly to address the manufacturer's recommendations (2.3)." +

Response

Layup actions for the reactor vessel had been started at the time of the Brookhaven review and were completed on November 23, 1985.

~

MIO686-0029A-MP03 9 --

4 -

Enclorure to JWCook e

~

Letter dated July 1, 1986 -

, Serial 32736 The Report discusses a concern that the frequency of humidity checks was not specified in the layup procedure. The frequency of inspection is controlled by preventive layup criteria document CP-F10-5024. The first inspection was conducted on March 4, 1986 and the humidity was less than 60% at the reactor vessel and upper and lower channel heads of the steam generator. The inspec-

~

tion interval for the reactor vessel in its laid up. condition is consistent with the interval for other tanks and vessels within the plant. Based on our experience with other equipment, we believe the six month inspection interval is adequate. Since the reactor coolant system is sealed, contains desiccant, and has an internal closed system to circulate air, humidity changes are .

unlikely.

Another item mentioned ,in the report is the proximity of the humidity indica-tor to the desiccant. However, since air circulation is part of the layup

• criteria, proximity is not a concern.- The' humidity indicator on the upper and "

lower channel heads provide a rep.r,esentative reading of the reactor coolant ,,

~ ,

loop humidity. These readings must also be below 60%. Based on the readings obtained to date and the continued air circulation, ewe expect the indicators to be representative of the air within the entire loop.

A concern was expressed by Brookhaven regarding desiccant placement. The ideal method for placing desiccant is to disperse it uniforml throughout the volume to be protected. However, to' prevent contact of the desiccant with the stainless steel, we placed the desiccant in one basket as provided by B&W.

This practice will be revised if the allowable humidity exceeds the criteria ~ ,

limits. We have also installed a humidity indicator on the reactor vessel internals.

We believe that the overall preservation measures adequately protect the int,egrity of the primary (RCS) system and provide comparable or superior

• conditions to those experienced *during the prior plan't construction period. 4 Recommendation 7

" Incorporate instrument tubing layup criteria into the system layup procedures where this was omitted (2.3)."

Response

l Layup requirements for all instrument tubing have been incorporated into the l appropriape procedures which previously did not address the tubing. .

RecoEmendation 8 * *

" Follow-up on the implementation of the layup of re'ma,ining systems including the Reactor Vessel, Steam Generator", Service Water and Component Cooling Water (2.3)."-

Response

^

The implementation of layup requirements for the above systems had been

, complete'd for both units by the following dates:

~

1 MIO686-0029A-MP03 L _ J

~ '

5

'nclo'rure E to JWC'ock

.Lett'dr dated July 1, 1986 '

Serial 32736 -

a Reactor Vessel - 11/23/85 . Steam Generator - 11/12/85 Service Water '- 01/10/86 Component Cooling Water - 01/03/86

e. .

Recommendation 9 . -

" Modify corrosion monitoring program to. include ponitoring/in,spection of p'iping and equipment internals (2.4)." .

- Response

• 4

~

,As U,1scussed during the site _ review, the coupon monitoring pfogram was being supplemented by a component evaluation program., This program covers the 1

inspection of component internals of both Q and Non-Q equipment. To date the .

~ evaluations have resulted in some additional.layup measures but no unaccept-able equipment degradation has been found. Continuation of component evalua-tion, in conjunction.gith the coupon program, will provide information to ~

protect the equipmegt for sale or' service. .,

Recommendation 10 ,

. e s

" Responded to IEInformation Notice 85-56 scheduled to be completed on October 28, 1985'(2.5)."

Response .

Information NoEice 85-56-was dispositioned on October 25, 1985 in accordance with our commitpent management system.

~

Recommendation 11

" Expedite c,ompletion of layups for outst'anding systems and equipment (3.2)".

. Response .

Layup implementation was approximately 75% complete at the time ~of the October review. 'A thorough review of all outstanding work. orders was initiated and a priority placed on' implementation. Layup was 9'5%' complete in December 1985

~

and was 100% complete by February 1986. .

Recommendation 12

4. > .

"' Review adequacy'of Operating Section Manpower (3.3)."

.w .

l

. Response * -

$The Operating Section consists of 13 people. At the enrrent time, layup implementatifon is complete and continuing reviews of operating section work indicated that the project'is carrying out its scheduled work within the p' ocedural ' window and .t'he backlog remains essentiallk at zero. It has been ,,.,

concluded that curren't manpower to operate and monitor systems is adequate.

[ .

l MIO686-0029A-MP03 .

- - - ~ __

.. , 6 Enclorure to JWCook Letter dated July 1, 1986 -

Serial 32736 Recommendation 13

. " Modify work order processing procedure to insure that bypass of QA responsi-bilities it prohibited (2.3) ." ,

. Response Midland Project Shutdo'wn Organization Procedure OM-001,eRevision 4, Control '

of Work Performed on Permanent Plant Equipment, details the requirements and ,

methods for processing work orders. A Quality Assurance Department review and approval is. required for all corrective and preventive maintenance work orders which' control Q' work activities. This review is required for the initial '

issue of.a work order, and any subsequ'ent revisions. These requirements alleviate any further concerns of possibly by-passing QC. Procedure OM-001, '

Rev 4, Section 5.3.2 re' quires the supervisor or designee to notify QAD-Verification of any hold points and/or the start of work per work order instructions.

G 9

4 .

~

O 9

F s

s S

o

%% a M10686-0029A-MP03