ML20133D228

Insp Rept 50-155/85-10 on 850603-0726.No Violation or Deviation Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Maint Activities & Qa/Qc Administration

ML20133D228
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/01/1985
From:	Hasse R, Hawkins F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133D214	List: IR 05000155/1985010 ML20133D210
References
50-155-85-10, NUDOCS 8508070265
Download: ML20133D228 (10)

See also: IR 05000603/2007026

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/85010(DRS)

Docket No. 50-155 License No. DPR-06

Licensee: Consumers Power Company

212 West Michigan Avenue

Jackson, Michigan 49201

Facility Name: Big Rock Point Nuclear Plant

Inspection At: Charlevoix, Michigan

Glen Ellyn, Illinois

Inspection Ccnducted: June 3-7, June 10, June 17-21, July 9-12, July 17, 22,

24, and 26, 1985

Inspector: R.

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asse R- \- %$

Date

Approved By:

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F. Hawkins, Chief  %- \d 5

Quality Assurance Programs Section Date

Inspection Summary

Inspection on June 3-7, June 10, June 17-21, July 9-12, July 17, 22, 24, and 26,

1985 (Report No. 50-155/85010(DRS))

Areas Inspected: Routine inspection by one regional inspector of licensee

action on previous inspection findings, maintenance activities, and QA/QC

administration. The inspection involved 80 inspector-hours onsite and 15

inspector-hours in the Region III office.

Results: No violations or deviations were identified.

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DETAILS

1. Persons Contacted

Consumers Power Company

D. Hoffman, Plant Superintendent

• C. Abel, Operations and Maintenance Superintendent

• • G. Withrow, Maintenance Superintendent

• D. Wilks, Maintenance Supervisor

• J. Johnson, Instrumentation and Controls Supervisor

• L. Monshor, Quality Assurance Superintendent

G. Petitjean, Technical Superintendent

D. Herboldsheimer, Outage Coordinator Supervisor

W. Blosh, Senior Plant Technical Analyst

D. Staton, Shift Supervisor

• • G. Slade, Executive Director, Quality Assurance (by telecon)

1. **R. Alexander, Technical Engineer -

• • T. Fisher, Senior QA Administrator

• • R. Barnhart, Senior QA Administrator

USNRC

• S. Guthrie, Senior Resident Inspector

Other personnel were contacted as a matter of routine during the

inspection.

• Denotes those attending the exit interview on June 21, 1985.

• • Denotes those attending the exit interview on July 12, 1985.

1. Denotes participation in telecon exit interview on July 26, 1985.

2. Action on Previous Inspection Findings

(Closed) Unresolved Item (155/84-15-01): Administrative procedures did

not require a documenteo 10 CFR 50.59 review for temporary modifications

(liftedleadsandjumpers). The inspector verified that the applicable

administrative procedures had been revised to require this review for all

temporary modifications not previously addressed.

3. Program Areas Inspected

a. Maintenance Program

During the most recent SALP period (SALP 5), the licensee was rated

as a Category 2 in the maintenance area. This represented a decline

in performance from the SALP 4 period in which the licensee was rated

a Category 1. In addition, SALP 5 noted that performance continued to

decline during the rating period. The primary reason for the decline

in the SALP rating was the increase in the number of problems requiring

maintenance attention. A particular concern was expressed about those

that could have been prevented by a mnre aggressive PM program (i.e.,

emergency diesel generator problems). Other concerns were the lack of

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increased management attention to reverse the trend toward more main-

tenance problems and the occasional lack of aggressive action in solving.

maintenance problems. This inspection was augmented to assess the

reasons for the declining performance and any remedial actions being

taken by the licensee to reverse it.

(1) Inspection Results

The inspector reviewed the procedures controlling maintenance

activities, maintenance history files for selected pieces of

equipment, completed maintenance order packages, recent licensee

audits of the maintenance program, the SALP 5 Report, Licensee

Event Reports for 1983-85, and Deviation Reports. The inspector

also interviewed licensee personnel responsible for the mainten-

ance program. Specific observations were as follows:

a_ During the review of completed maintenance orders (M0's),

the inspector noted that the equipment outage requests

(EOR's) were not always completed. Further investigation

indicated that this problem had been identified in the

4 licensee's 1984 audit of maintenance activities and was

incorporated in that report as an observation. During the

licensee's 1985 audit of this area, the problem was found

to be worse and the matter was upgraded to a finding. This

is considered an unresolved item pending NRC review of the

licensee's prompt corrective action (155/85010-01).

b The inspector reviewed the licensee's program for independent

verification of system alignment for removal from and return

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to service. When protective tagging (for personnel protection)

is required, independent verification of system alignment is

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performed for removal from service; however, the tagging

system does not provide for independent verification of

l system alignment for return to service. In addition, instru-

mentation and control procedures for calibrations do not

require independent verification of system alignment during

i either removal from or return to service.

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The inspector discussed this issue with licensee personnel,

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and they stated that the E0R system does require action to

i determine equipment operability prior to returning it to

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service. In some cases, this would represent independent

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verification of system alignment. In other cases, only the

item worked on may be tested and overall system alignment

may not be verified. The Nuclear Operations Department

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Standard governing this area was revised during this

inspection to reflect this fact permitting operability

testing to be used for independent verification only when

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personnel hazards precluded visual verification by a second

qualified individual. This is considered an unresolved

! item pending NRC review of the revised operating procedures

(155/85010-02).

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c- The maintenance staff is experienced and well qualified.

The licensee is generally able to replace experienced

personnel that leave with personnel experienced in their

particular craft. Systems training is provided to the new

personnel. Some skill training is also provided. While no

formal on-the-job training program is used, an apprentice

type program is employed. This provides " hands-on"

experience with plant equipment to new staff members under

the supervision of experienced personnel. An INP0 accredited

maintenance training program is being pursued.

d_ Approximately 4000 maintenance orders (M0s) are processed

each year. At the time of this inspection there were 2

M0s open from 1982 (under review for necessity), 8 from

1983 and approximately 115 from 1984. The backlog appeared

to be reasonable. Preventive maintenance (PM) tasks were

being completed in reasonable agreement with the PM schedule.

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e To assess the reasons for the declining SALP performance,

the inspector reviewed the examples listed in SALP 5. The

inspector also reviewed LER's for 1983-1985 for other main-

tenance problems which led to reportable conditions.

Specific observations are as follows:

. The problems with the emergency diesel generator

involved a fuel pump shaft failure, loose and pitted

contacts, and failure of a drive coupling to the

engine cooling water pump due to long term wear.

While the diesel engine had recently been overhauled,

the remainder of the system had not been examined or

refurbished. It does appear that a more complete PM

program for this sytem would have prevented these

problems.

. An example of a corrective maintenance situation

that might have been prevented by more aggressive

corrective action involved the recirculating pump seal

leakoff valves (IA60A and IA608). These valves are no

longer used to control seal leakage but remain in a

full open position. In February 1984, the packing in

IA60A failed leading to a high containment radiation

level and a forced outage to repack the valve. During

April 1985, IA60B packing failed leading to another

forced outage to repack that valve. The inspector

reviewed the deviation report associated with IA60A to

determine why IA60B was not repacked after IAG0A

failed. The licensee evaluation of the IA60A failure "

appeared to conclude that the reason for the failure

was that the valve was not backseated. It also noted

that there was some packing left and that the packing

was still pliable. Corrective action included repacking

IA60A, adjusting IA60B packing, and backseating the

valve. A change was also initiated to an operations

valve checklist to routinely ensure these valves were

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backseated. One item not addressed was anticipated

packing life and establishing a repacking schedule for

these valves. Considering the consequences of packing

failure it would appear prudent to have repacked

IA60B at the same time as IA60A or at least scheduled

it for the next outage. The valves had not been

repacked within the period covered by their machinery

history records (1977 was earliest entry).

(2) Conclusions and Recommendations

There is evidence of weaknesses in the PM program and a lack of

management aggressiveness in upgrading that program based on plant

experience to prevent equipment failures. This is particularly

important considering the age of the plant resulting in the

increased potential for end-of-service-life failures. The

licensee has taken some actions to reduce equipment failures and

increase reliability. Among these are budgeting for replacement

of recorders and transmitters, assessing the replacement of

neutron instrumentation, and the establishment of a PM program

for limitorque operators. However, the following additional

actions should be-considered:

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a Treat corrective maintenance M0s more like corrective action

documents. Specifically, a review should be performed to

ensure the root cause has been properly identified and an

assessment made to determine if better PM (or other action)

could prevent recurrence. The assessment should include

generic implications and be completed prior to closing the

M0.

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b A formal evaluation should be made for important plant

equipment to assess the potential for end-of-service life

failures and determine actions necessary to prevent these

failures.

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c The infonnal assessments of equipment problems currently

performed by the maintenance staff should be documented in

the maintenance history files to ensure their availability

for future assessments.

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b. QA/QC Administration

The licensee had recently reorganized resulting in the transfer of

some functions previously performed at the General Offices (GO) to

the Big Rock Point (BRP) site organization. The transfer of these

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functions necessitated changes to the QA program implementing

l procedures and increased the the BRP QA staff workload. Because of

l NRC concerns relative to the safety impact, the inspector assessed

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these changes to determine the adequacy of the procedure changes, if

BRP QA personnel were qualified to perform their new responsibilities,

and the impact of the added workload on the ability of the BRP QA

staff to adequately perform their assigned tasks.

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(1) Procedure Changes

The top tier implementing documents for the QA program are the

Nuclear Operations Department Standards (N0DS). These standards

specify the organizational responsibilities and requirements

for various subject areas (such as fire protection and plant

security. Due in part to the reorganization, 16 N0DS had been

revised and 15 cancelled. Changes to Administrative Procedures

(APs) (second tier implementing procedures) had not been

completed at the time of this inspection.

a_ Inspection Results

The inspector reviewed the revised and cancelled N0DS and

identified the following concerns:

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1 The inspector noted that in some cases a revised NODS

referenced a cancelled NODS. In one case the reference

was a "use" reference: N0DS-Q01, (" Corrective Action

and Nonconforming Items") was revised to require QA

Support to trend certain items in accordance with

h0DS-M05 (" Supplier Evaluation and Selection") which

had been cancelled. The inspector asked whether the

requirements of the cancelled N0DS were included in

either the remaining N0DS or the Administrative Proce-

dures (APs). Licensee personnel stated that the

situation had been reviewed and they were satisfied

that all requirements of the cancelled N0DS were

addressed; however, they recognized that cancelled N0DS

were still referenced in both the APs and active N0DS

and could not ensure that there were no other cases in

which the reference was a "use" reference. The

licensee's current plan was to delete references to

the cancelled N0DS in the APs or N0DS when they were

revised for other reasons or at the time of their

biennial review. The inspector was concerned that in

the case where the reference was a "use" reference, as

in the case noted above, this schedule could lead to

the use of uncontrolled documents (cancelled N0Ds) or

the lack of specific direction for performing safety

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related activities. This is considered an unresolved

item pending further NRC review (155/85010-03).

2_ The NODS provide a convenient reference to applicable

requirements for a specific subject area and provide

a vehicle for G0 level interpretation of these require-

ments. The inspector was concerned that the APs

become more vulnerable to missing requirements in

those areas where a NODS had been cancelled since the

gap between the baseline requirements (Facility

License, NRC approved QA program, etc.) and the APs

had been widened. The preparation of APs becomes more

difficult since the baseline documents must be searched

to identify applicable requirements. The workload

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and potential for error are thus increased. The

licensee is planning to mitigate this problem to some

extent b

Matrix (yQARM).

revising

TheitsQARM

Quality Assurance

is currently a twoRequirements

dimensional

matrix relating requirements to implementing procedures.

The revision will add a third dimension relating

subject to requirements. This is considered an open

item pending further NRC review of the adequacy of the

revised QARM for identifying regulatory requirements

relating to subject areas (155/85010-04).

_3_ The N0DS also provide a vehicle for establishing

corporate level policy related to regulatory

requirements in a subject area. The inspector was

concerned that for those subjects covered by the

cancelled N005, this policy making authority had been

effectively transferred to the plant and department

level managers thereby reducing corporate level control.

The licensee stated that this had been discussed

extensively and that corporate level management felt

they had adequate control through the performance

appraisal (MB0) system. .The inspector had no further

questions concerning this subject.

4 Some changes in the revised N0DS, taken collectively,

appeared indicative of weakened controls. Specifically:

. The Corrective Action Review Board (CARB) will

no longer review completed Event Reports (ERs)

or Deviation Reports (DRs). They will review

only the initial reports.

. ERs and DRs will no longer be prioritized.

. Applicability of many N0DS is for safety-related

items only. The issues of "important to safety"

and " reliability" are not addressed.

.

Overdue corrective actions will no longer be

explicitly escalated to higher levels of

management.

.

The Plant Review Committee (PRC) will no longer

review Q-list changes.

. The PRC will no longer review all violations of

procedures required by the Technical

Specifications, only those considered to have

significant safety impact.

Individually, these items may be justified on the basis

of efficiency or line management responsibility or both.

However, as noted above, they do appear indicative of

weakened controls.

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b_ Conclusions and Recommendations

Based on the observation noted above, the inspector

concluded that the cancellation of some of the NODS

was premature in that the licensee did not adequately

ensure that they were no longer required as a "use"

reference nor provide a fully operational alternative

for efficient identification of requirements for

specific subject areas (eg, QARM). Further, overall

operational controls may have been weakened. Based

on these conclusions, the following actions appear

warranted:

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1 The licensee should perform an immediate and in

depth review to identify any case where a

cancelled NODS is required as a "use" reference.

In those cases, immediate corrective action

should be taken.

2 The revision to the QARM should be given a high

priority.

3_ The licensee's audit and trending programs

should be augmented on a temporary basis to

focus on these changes to determine if they have

impacted the safety of facility operation.

(2) Site QA Workload and Staff Qualifications

The site QA staff had been assigned new functions previously

performed by the GO QA staff. These functions were:

. Fuel vendor inspections

. Inservice inspection program

. In-line QA reviews for the G0 projects

organization (BRP projects)

. Equipment environmental qualification (EEQ)

program for BRP

. Appendix R (safe shutdown) building for BRP

. Core physics packages for BRP

The lead responsibility for the fuel vendor inspections haa

originally been reassigned to BRP. However, the lead was later

transferred to the Palisades QA staff with BRP providing auditor

support. The EEQ program and Appendix R building were primarily

one time efforts.

The inspector interviewed site QA personnel and reviewed formal

workload projections to determine if the site QA organization

was qualified and adequately staffed to perform these newly

assigned tasks.

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a Inspection Results

The inspector made the following specific observations:

1 The workload projection did not include all categories

of work performed by the QA organization. Non-projected

categories included surveillance (approximately 9% of

1983 effort), training, corrective action closecut

reviews, independent assessments, consulting, and

other miscellaneous activities. For those categories

that were projected, the projection for 1985 was based

- on actual manpower expended during the first 6 months

of the year. It included neither the additional effort

required to support the refueling outage scheduled for

late 1985 nor any increase in workload due to the

reorganization which was not fully reflected in the

effort expended during the first six months of 1985.

Site QA personnel felt that the 1985 workload for the

projected categories would be approximately 10% higher

than projected. No projections were available beyond

1985.

The projected categories required an increase of 10%

of the total QA manpower available over that expended

in 1984 in the same categories (adjusted for the

anticipated 10% increase in the 1985 projection for

these categories). An increase in the manpower require-

ments for the non-projected categories of training and

consulting was also experienced during the first 6

months of 1985. The manpower to support the increase

in the projected and non-projected categories was to

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come from a decrease in the number of surveillances to

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be performed during 1985. The site QA staff felt that

' those surveillances performed would also contain less

depth than those performed during 1984. Thus, it

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appeared that an increase of 10% of available manpower

j for projected categories plus an increase in non-pro-

! jected categories plus added refueling outage effort

I was to be recovered by reducing (not eliminating)

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effort in a category utilizing only 9% of available

manpcwer during 1984. This did not appear feasible

to the inspector.

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2 The inspector was satisfied that the QA staff was

qualified to perform the newly assigned functions.

However, extra time was required by the staff to

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familiarize themselves with the specific requirements

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in certain areas such as inservice inspection and fuel

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vendor audits. Also, one QA staff member (representing

25% of available staff hours) was still in training and

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currently qualified to perform only certain categories

of work. This impacted the flexibility in assigning

staff work and increased staff training time.

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b Conclusions and Recommendations

Based on the observations noted above, the inspector con-

cluded that workload projection for the site QA staff was

inadequate in that historical data was used to project

workloads in a changed situation and only a portion of the

total workload was projected. Further, the uncertainties

noted above not withstanding, the site QA organization did

appear to be understaffed, at least for the short term.

Based on these conclusions, the following recommendations

are made:

1 A more meaningful workload projection for the site QA

staff should be made. The projection should include

all categories of effort and reflect the full impact

of newly assigned functions. The projection should

also extend beyond 1985.

2_ The site QA staff should be temporarily supplemented

at least until all current staff members are fully

qualified, the 1985 refueling outage is complete, and

the above projection is completed. Any permanent

change in staff level should be based on the

completed projection.

4. Unresolved Items

Unresolved items are matters about which more infonnation is required in

order to ascertain whether they are acceptable items, violations, or

deviations. Unresolved items disclosed during this inspection are

presented in Paragraphs 3.a.(1).a_, 3.a.(1).b_, and 3.b.(1).a.1.

5. Open Items

Open items are matters which have been discussed with the licensee, which

will be reviewed further by the inspector, and which involve some action

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on the part of the NRC or licensee or both. An open item disclosed

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during this inspection is presented in Paragraph 3.b.(1).a.2.

6. Exit Interviews

The inspector met with licensee representatives (denoted in Paragraph 1)

on June 21, 1985 and July 12, 1985, and summarized the purpose, scope, and

findings of the inspection. A final summary of the inspection findings was

presented to the licensee via telecon on July 26, 1985. The licensee

indicated that the inspector had no access to proprietary information

during the inspection.

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