ML20246L911

Responds to NRC Re Violations Noted in Insp Rept 50-155/89-13.Corrective Actions:Plant Procedures Being Rewritten to Address Human Factors Concerns & Complete Insp & Clean Up of Reactor Bldg Area Conducted

ML20246L911
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/30/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8909070060
Download: ML20246L911 (3)

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r 13 Const!mers Power Kenneth W Berry M Director gqq Nuclear Dcensing

. General Officos: 1945 West Parnell flood. .lockson, WH 49201 e (617) 788-1636 t

August 30,-1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - L7 CENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO VIOLATIONS ISSUED IN INSPECTION REPORT 89-013.

Nuclear Regulatory Commission Inspection Report 89-013, dated August 2, 1989 transmitted three violations requiring written response within 30 days.

Consumers Power Company's response to the violations is provided herein.

VIOLATION 01 (155/89013-01 AND 155/89013-02)

'Sectica 6.8.1 of-the Technical Specifications states in part, " Written procedures shall be established, implemented and maintained for all structures, systems, components and safety actions defined.in-the Big Rock Point-Quality List."

Administrative Procedure Volume 1, No. 1.8 '" Plant Housekeeping and Cleanliness,"

Rev.1, . dated April 5,1988, Section 4.1.3, states: " Tools, equipment,

,. materials and supplies shall be controlled, through utilization of-such items L as log sheets and tethered tools in areas requiring special considerations, to prevent.the inadvertent inclusion in critical syetems."

Contrary to the above, tools and' materials found on the reactor building crane (a tool control area) were not listed on the required log sheet or connected to a tether.

Section;5.0.c of Administrative Procedure Volume 1,. Procedure 5.5 " Radiation Work Permit" Rev 2, dated July 21, 1988 states in part, "All attachments to the radiation work permit are considered a part of the radiation work permit and require compliance."

Contrary to the above, several individuals on numerous occasions failed to complete all required entries on the kadiation Work Permit Entry Log Sheet (Form ERP051), a part of the Radiation Work Permit.

g This is a Severity Level V violation (Suppleme.nt I).  ;

8909070060 890330 PDR ADOCK 05000155 po/

g FDC I t OC0889-0008-NLO2

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• l Nuclear Regulatory Commission 2

[ Big Rock Point Plant i Response to IR Report 89-013 August 30, 1989 Correctiva Actions Taken and the Results Achieved Upon notification of the housekeeping concern on the Reactor Fdk ding crane on June 30, 1989, all items were immediately removed from the locatica. A complete inspection / clean-up of the area was conducted at that time which r.estored compliance with the Administrative Procedure requirements.

With respect to the incomplete Radiation Work Permits, department supervisors were notified that closer attention was needed by all plant workers in documenting the requested information. Individual entries which at times did not include Social Security numbers or Work Croup classifications used for dose tracking and trending were completed by Health Physics Technicians and/or the ALARA Coordinator prior to processing and filing.

Action to Avoid Purther Violations The housekeeping problem was principally the result of a failure of management expectations to be clearly understood by personnel handling tools and working on the Reactor Crane. It is likely that several items may have been present for several years, however, recent initiatives in tool control by Maintenance and decontamination / clean-up efforts by Health Physics, specifically in this area were expected to have eliminated any problems in this area.

To prevent recurrence a Plant Material Control Policy was issued by the Plant Manager on July 29, 1989 outlining expectations of all workers in dealing with material and plant status control.

Failure of individuals to complete the requested information on radiation work periods is primarily due to poor performance. To improve performance in this area, the Health Physics Department will be revising the Radiation Work Permit System to ensure a more positive control of ingress and egress to the Radiological Controlled areas. This will enhance RWP form completion.

This effort is expected to be completed by December 31, 1989.

VIOLATION 02 (155/89013-03) 4 Section 6.8.1 of Technical Specifications states in part that procedures defined in the Big Rock Point Quality List shall meet or exceed the requirements of ANSI N18.7 hs endorsed by CPC-2A, Consumers Power Company's Quality Assurance program implementing Appendix B of 10 CFR Part 50. Appendix B section VI,

" Document Ct.atrol," states in part that measures shall assure that documents, including citanges, are reviewed for adequacy and approved for release by authorized personnel.

Contrary to the above, an inadequate review was performed or. Procedures IRPS-1 Rev. 10, IRPS-4 Rev. 12, IRPS-5 Rev. 9. IRPS-6 Rev. 9, IRPS-9 Rev. 8 and TR-32 OC0889-0008-NLO2

, , , , - e l 4 Nuclear Regulatory Commission 3 l Big Rock Point Plant Response to IR Report 89-013 August 30. 1989 Rev. 19 because, each contained typographical errors and in several procedures steps were absent or missing information.

This is a Severity Level V violatic, (Supplement I).

Corrective Actions Taken and the Results Achieved At the present time, Big Rock Point procedures are being rewritten to address human factors concerns. By correcting human factors deficiencies, it is believed . Plant procedures vill be easier to f ollow, thereby reducing potential for human error during their performance. The procedures in which the errors were identified had just completed this revision process, and had not yet been used. Identified errors were corrected prior to the procedures being used.

Action To Avoid Further Violation i The effort to improve the format and other human factors aspects of a procedure often results in its being completely retyped. Even though two levels of review occur after typing, some deficiencies may not be identified prior to issuance of the procedure. Plant personnel are instructed to review procedure steps prior to performing them, and if errors or other problems are noted, to contact their supervisor in order to have necessary corrections made prior to continuing the procedure. Typographical errors or inadvertent omissions missed during clerical review are normally identified during review by the user of the procedure. None of the procedures identified in the notica of violation were used prior to correction of the errors.

To improve performance, a letter has been written to all procedure sponsors and department heads to discuss the problems identified in the notice of violatfon.- The letter provides additional guidance related to review techniques in order to enhance identification of omissions and typographical errors. i To determine the extent of similar errors in other procedures, a sample of  ;

plant working level procedures will be reviewed by Quality Assurance personnel. The results of this review will be used to determine if l additional reviews or changes in the revin r ocess are necessary. This i review will be completed by December 31, 2 W .

dor i Kenneth W Berry l Uirectoi, Nuclear Licensing l CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point DC08894008-NLO2

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