ML20215M332

Responds to NRC Re Violations Noted in Insp Rept 50-155/87-05.Corrective Actions:Control Rod Drive change-out Procedure Revised & Meeting Held W/All Maint Supervisors to Discuss Event

ML20215M332
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/22/1987
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8706260355
Download: ML20215M332 (4)

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General Ofhces: 1945 West Parnall Road. Jackson, MI 49201 e (517) 7881636 4

June 22, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 ]

DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - 1 RESPONSE TO INSPECTION REPORT 87-005 l l

NRC Inspection Report 87-005 dated May 22, 1987 transmitted one violation that i required a response by June 22, 1987. This report also requested us to j discuss our actions regarding improvement in communications between operating l crews, and our act on regarding leakage identified in the emergency condenser.

The following is response to the item of violation and the additional items of concern.

Violation #87-005-01 As a result of the inspection conducted on January 28 through April 23, 1987,-

and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violation was identified:

Technical Specification 7.5.7 requires that prior to removal of a control rod drive from the reactor vessel when the reactor is in the shutdown condition the " mode switch is locked in the 'shutdomi' position."

Contrary to the above on February 22 control rod drive B3 was removed from the-reactor vessel with the mode switch in the " Refuel" position.

This is a Severity Level IV violation (Supplement I).

Description of Event As discussed in LER 87-005 Rev 0, the following provides a' description of the event:

On February 22, 1987, a maintenance procedure was released to change out a control rod drive during the Refueling Outage. At 0145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br />, with the mode switch in the " refuel" position, operators uncoupled drive-B-3 in preparation OC0687-0091-NLO2 PDR 8706260355 870622 M G ADOCK 05000155 N - # .

PDR s

., i- I Nuclear Regulatory Commission' 2 Big Rock Point P1nnt Response to IEIR 87-005 June 22, 1987

-for removal. At 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, following uncoupling, the mode switch was placed in the " Bypass Dump Tank" position. At 1310 hours0.0152 days <br />0.364 hours <br />0.00217 weeks <br />4.98455e-4 months <br />, B-3 drive removal activity recommenced and maintenance personnel requested the mode switch be placed in the " refuel" position, in accordance with a procedure step that had inadvertently not been signed off. The control room operator acknowledged the request'and placed the mode switch to the " refuel" position. Maintenance personnel proceeded with drive change out. At 1502 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.71511e-4 months <br />, the Shift Supervisor was notified by the Maintenance Supervisor that a procedural step j requiring the mode switch to be locked in the " shutdown" position was not signed-off. The Shift Supervisor instructed the maintenance crew to stop the activity until the situation was corrected. The control room operator placed and. locked the mode switch in the " shutdown" position. The maintenance crew was then permitted to complete the activity.

Cause ]

Primary cause-for this event is attributed.to a failure of the maintenance personnel to follow their procedure and ensure that each step is signed off when completed. Poor communication between the maintenance crew and the  ;

control room concerning the evolution, coupled with a shift change, ]

complicated matters. Control room personnel should have known when the control rod drive was going to be removed and ensured plant conditions were ~,

appropriate for the activity. j q

Corrective Action And The Results Achieved i As discussed above, immediately upon notification, the Shif t Supervisor stopped the activity, had the mode switch loc.ked in the " shutdown" position, and then permitted completion of the CRD charge-out. These actions' corrected the error and promptly restored compliance-with the Technical Specification requirements.

Corrective Action Taken to Avoid Further Violations

1. Shortly following the event, the following actions were taken to prevent a similar problem with future CRD change-outs during the outage.

j A letter was written to all operating and maintenance personnel describing the event, cause, and stressing the importance of following procedures.

A meeting was held with all maintenance supervisors to discuss the incident prior to the change-out of the next drive.

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2. Following the Refueling Outage, a rewrite of the CRD change-out procedure 1 was completed. The revision now requires the Shift Supervisor versus the Maintenance Supervisor to control " Mode Switch Position" by documenting his verification in the procedure. The procedure also has been restructured to provide improved continuity.of the activity from I uncoupling to replacement.

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Nuclear Regulatory Commission 3 Big Rock Point Plant Response to IEIR 87-005 June 22, 1987 Date When Full Compliance Will Be Activated Compliance was promptly achieved at time of discovery of the event.

Additional corrective actions, as discussed above, have been completed.

Communications Improvement Between Operating Crews As discussed in the Inspection Report and at the Management Conference on May 26, 1987, concerns were raised with regard to the shift turnover process, i and communications between operating crews to ensure continuity of control of l plant activities. Although Consumers Power Company does not support that Shift Turnover / Communications was the root cause of the events discussed, improvements are warranted and the following actions will be pursued. l 5

Improve teamwork diagnostics and problem solving within an operating  !

crew to enhance communication of plant status and off-normal conditions to ensure prompt resolution. This teamwork approach has.

been incorporated and stressed during the 1987 Simulator portion of the Requalification Program and will be completed by all licensed personnel by August 1, 1987.

A review aimed at improving the shift turnover process will be initiated. The INPO Good Practice Document #84-008 (0p-201) " Shift l l

Relief and Turnover" will be looked at item-by-item for applicability to Big Rock Point. Plant administrative procedures will be revised, as deemed necessary, to incorporate the applicable relief and turnover practices. l These actions are expected to be completed by. September, 1987.

All mechanical and electrical maintenance procedures, associated with )

Technical Specification requirements, will be reviewed to ensure l adequate notification and procedural sign-offs by Operations personnel l in order to control plant status and system requirements. )

This effort will be completed by year end. Necessary procedure changes will be issued prior to the 1988 Refueling Outage.

Suspected Emergency Condenser Tube Leakage In the cover letter to the inspection report, the NRC requested information 1 J

regarding the status of our corrective action associated with the emergency condenser leakage. Consumers Power Company letter dated May 19, 1987 j submitted our program to address the leakage in the emergency condenser. This j program is being closely followed by the NRC Resident Inspector. The  !

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.1 Nuclear Regulatory Commission 4 j Big Rock Point Plant i Response to IEIR 87-005 June 22, 1987 commitment made in our May, 19, 1987 letter to perform xenon testing to determine leakage in the tube bundles will be performed approximately one week after startup from our present outage.

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

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OC0687-0091-NLO2