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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217G4111999-10-12012 October 1999 Informs of Changes to Big Rock Point Defueled Emergency Plan, That Meet Requirements of 10CFR50.54(q) & Can Be Made Without NRC Approval.Changes to Plan Are Listed ML20212L9051999-10-0404 October 1999 Forwards Environ Assessment & Finding of No Significant Impact Re 990511 Application for Amend,As Supplemented on 990603 & 0728.Proposed Amend Would Make Changes to TSs by Deleting Definition,Site Boundary & Use ML20217C5111999-09-30030 September 1999 Forwards Info Re Management & Funding of Irradiated Fuel Notification,Per 10CFR50.54(bb),in Response to NRC Telcon Rai.Revs to Original 990811 Submittal Are Indicated by Redline/Strikeout Method ML20217C2761999-09-30030 September 1999 Forwards Big Rock Point Plant Annual Rept of Facility Changes,Tests & Experiments,Iaw 10CFR50.59(b)(2).Rept Provides Summary of Changes to Facility Performed Since 981001.No Activities Classified as Tests or Experiments ML20212K7561999-09-30030 September 1999 Forwards Insp Rept 50-155/99-05 on 990731-0921,site Insp & 990929 Public Meeting.No Violations Noted ML20211G1011999-08-25025 August 1999 Confirms Discussions & Agreement to Have Mgt Meeting in Region III Office on 990929.Purpose of Meeting to Discuss Decommissioning Activities,Priorities,Challenges & Successes & to Preview Plans & Schedules for Next Year ML20210V0561999-08-17017 August 1999 Advises of Plan to Stop Using Ofc Complex at Plant,Which Consumers Energy Co Had Provided for NRC Resident Inspectors Under 10CFR50.70(b)(1) ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML20210S6961999-08-12012 August 1999 Forwards Insp Rept 50-155/99-04 on 990609-0730.No Violations Noted.No Safety Issues or Enforcement Items Were Identified During Insp ML20210S6291999-08-11011 August 1999 Forwards Notification to NRC for Review & Approval of Program Intending to Manage & Provide Funding for Mgt of All Irradiated Fuel at Big Rock Point Until Title of Fuel Is Transferred to Secretary of Energy for Disposal ML20210L0321999-08-0303 August 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety & Documents Listed in App B Being Released in Part (Ref FOIA Exemption 6) ML20210H2701999-07-28028 July 1999 Informs That Big Rock Point Commits to Listed Actions with Regard to 990511 Amend Request to Delete Definition of Site Boundary & Remove Site Map,Based on Discussion with NRC on 990728 ML20209D6951999-07-0707 July 1999 Ack Receipt of Which Requested That NRC Reconsider Decision to Move NRC Resident Inspector from Big Rock Point Plant.Determined Decision to Be Correct One ML20210L0491999-06-30030 June 1999 Partially Deleted Request for FOIA Documents Re Source of High Alarms Generated by Radiation Effluent Detector or Detectors in Discharge Canal at Big Rock Point on 980314,15 & 25.Partially Deleted Info Encl ML20209D7011999-06-21021 June 1999 Requests That NRC Reconsider Decision to Move Resident Inspector from Big Rock Point NPP ML20196E1601999-06-21021 June 1999 Forwards Insp Rept 50-155/99-03 on 990416-0608.No Violations Noted.Overall,Reactor Decommissioning Activities Performed Satisfactorily ML20195D0371999-06-0303 June 1999 Forwards Revised Defueled Ts,Per 990511 Util Request.Page Format in Attachments 1 & 2 of Submittal Do Not Agree with Current Facility Defueled TS Format.Replacement of Encl Pages Requested ML20207F6631999-06-0303 June 1999 Forwards Rev 33 of Big Rock Point Plant Security Plan,Which Incorporates Exemption from Certain Requirements of 10CFR73 That Reflect Permanent Shutdown & Defueled Condition of Facility.Encl Withheld IAW 10CFR73.21(c) ML20207D1151999-05-27027 May 1999 Informs That Effective 990328,NRC Ofc of NRR Underwent Reorganization.Within Reorganization,Division of Licensing Project Management Created ML20206P4501999-05-11011 May 1999 Requests Transcript of 990413 Public Meeting in Rockville,Md Re Decommissioning of Big Rock ML20206P0921999-05-0707 May 1999 Responds to Discussing Impact That Delays to Wesflex Sys Approval Would Have on Big Rock Point Decommissioning Cost & Schedule ML20206H1011999-05-0404 May 1999 Forwards Safety Evaluation for Exemption from Certain Physical Protection Requirements.Enclosure Contains Safeguards Info & Being Withheld ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20206E7821999-04-29029 April 1999 Forwards Annual Radioactive Environ Rept for 1998 for Big Rock Point Plant. Rept Includes Summaries,Interpretations & Statistical Evaluation of Results of Radiological Environ Monitoring Program ML20206E3721999-04-29029 April 1999 Informs That Based on Licensee Determinations That Changes in Rev 1 Do Not Decrease Effectiveness of Defueled EP & That Plan Continues to Meet Applicable Stds of 10CFR50.47(b) & Requirements of App E to Part 50,NRC Approval Not Required ML20206B7381999-04-26026 April 1999 Forwards Insp Rept 50-155/99-02 on 990226-0415.No Violations Noted.Activities in Areas of Facility Mgt & Control,Decommissioning Support,Spent Fuel Safety & Radiological Safety Were Examined 05000155/LER-1992-008, Advises That Util Terminated Corrective Actions Re LER 92-008 of Loss of Station Power 125 Volt Dc sys.SOP-28 Has Been Deleted in Entirety.Commitments No Longer Applicable1999-04-26026 April 1999 Advises That Util Terminated Corrective Actions Re LER 92-008 of Loss of Station Power 125 Volt Dc sys.SOP-28 Has Been Deleted in Entirety.Commitments No Longer Applicable ML20196K7881999-03-29029 March 1999 Forwards Rept on Certification of Financial Assurance for Decommissioning for Big Rock Plant,Per 10CFR50.75(f)(1).Copy of Trust Agreement Between Consumers Energy & State Bank & Trust Co,Included in Rept ML20205E3471999-03-29029 March 1999 Informs That USNRC Granted Encl Exemption from Certain Requirements of 10CFR73,to Allow Implementation of Safeguards Contingency Plan Reflecting Permanent Shutdown & Defueled Condition of Brpnp in Response to ML20204F4611999-03-19019 March 1999 Forwards Insp Rept 50-155/99-01 on 990113-0225.One Violation of NRC Requirements Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML20203F8041999-02-11011 February 1999 Forwards Temporary Addendum to Security Plan Re Central Alarm Station,Per 10CFR50.54(p).Encl Withheld,Per 10CFR73.21(c) ML20203C8971999-02-0808 February 1999 Informs That NRR Contracted with PNNL to Evaluate Storage of Spent Fuel at Number of Decomissioning Nuclear Power Facilities.Forwards Request for Info Re Spent Fuel Storage at Big Rock NPP ML20202H4891999-01-26026 January 1999 Informs That Exemption Request from Various 10CFR73 Physical Protection Requirements, ,was Improperly Based on Requirements of 10CFR50.12.Request Was Resubmitted by Ltr ML20199H2431999-01-15015 January 1999 Forwards Insp Rept 50-155/98-09 on 981201-990112 & Nov.One Weakness Identified Re Event Involving Ungrappling Fuel Bundle Without Being Fully Seated in Rack & Without Independent Verification That Ungrappling Bundle Was Proper ML20199E1841999-01-13013 January 1999 Forwards Environ Assessment & Finding of No Significant Impact Re Proposed Exemption from Certain Physical Protection Requirements of 10CFR73.Assessment Forwarded for Fr Publication ML20199E0781999-01-13013 January 1999 Informs That Staff Has Received Request for Exemption from Various 10CFR73 Pyhsical Protection Requirements Dated 981112.Exemption Request Improperly Based on Requirements of 10CFR50.12 Instead of Applicable Requirements of 10CFR73.5 ML20199D9711999-01-13013 January 1999 Forwards Plant Defueled TS Administrative Replacement Pp.On 990104 Staff Informed NRC That Pp Numbering for Table of Contents Was Incorrect.Subj Pp Requested to Be Replaced with Encl ML20199E9051999-01-12012 January 1999 Submits Revised Request for Exemption from Certain Requirements of 10CFR73 Re Physical Protection of Plants & Matls ML20199E7671999-01-12012 January 1999 Informs That Licensee Has Elected to Comply with Listed 10CFR50.68(b) Requirements in Lieu of Maintaining Monitoring Sys Capable of Detecting Criticality as Described in 10CFR70.24 ML20199A4151999-01-0404 January 1999 Informs That Individuals Listed on Attachment 1 Will No Longer Maintain Operating License for Plant.Senior Licensed Operators & Licensed Operators No Longer Required at Facility ML20198K6551998-12-24024 December 1998 Forwards Amend 120 to License DPR-6 & Safety Evaluation. Amend Changes License DPR-6 & App A,Ts to Reflect Permanently Shutdown & Defueled Status of Plant ML20198J4001998-12-21021 December 1998 Requests That Words Decommissioning of in First Sentence of Paragraph a of Fol,License DPR-6 Be Removed from CPC 970919 Request ML20196H3171998-12-0303 December 1998 Forwards Insp Rept 50-155/98-08 on 980827-1130.No Violations Noted.Inspection Covered Activities in Areas of Radiological Safety ML20196G7541998-11-25025 November 1998 Requests Withdrawal of Listed Sections of 970919 Amend Request,As Supplemented by Ltrs ,0721 & 1014, Respectively.Util Proposed to Retain Certain Sections of Current Tech Specs (CTS) to Support Withdrawal Request ML20195G9851998-11-17017 November 1998 Forwards Rev 0 to Vol 9 of Defueled Emergency Plan & Rev 0 to Vol 9A of Defueled Epips ML20195H5321998-11-13013 November 1998 Provides Confirmation That Revs Required by NRC to Defueled Emergency Plan Prior to Implementation Have Been Completed by Licensee.Items Incorporated Into Plan,Listed ML20195F2271998-11-12012 November 1998 Forwards Request for Exemption from Certain Requirements of 10CFR73 Re Physical Protection of Plants & Matls.Request Withheld,Per 10CFR73.21 ML20154M5381998-10-14014 October 1998 Forwards Supplement to Plant Defueled TS & Bases, Incorporating Licensee Response to NRC 980416 RAI & Clarifying Listed Items ML20154M2211998-10-14014 October 1998 Forwards Insp Rept 50-155/98-07 on 980827-1007.No Violations Noted.Insp Consisted of Examination of Activities in Areas of Facility Mgt & Control,Decommissioning Support (Including Physical Security),Sf Safety & Radiological Safety 1999-09-30
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20212L9051999-10-0404 October 1999 Forwards Environ Assessment & Finding of No Significant Impact Re 990511 Application for Amend,As Supplemented on 990603 & 0728.Proposed Amend Would Make Changes to TSs by Deleting Definition,Site Boundary & Use ML20212K7561999-09-30030 September 1999 Forwards Insp Rept 50-155/99-05 on 990731-0921,site Insp & 990929 Public Meeting.No Violations Noted ML20211G1011999-08-25025 August 1999 Confirms Discussions & Agreement to Have Mgt Meeting in Region III Office on 990929.Purpose of Meeting to Discuss Decommissioning Activities,Priorities,Challenges & Successes & to Preview Plans & Schedules for Next Year ML20210V0561999-08-17017 August 1999 Advises of Plan to Stop Using Ofc Complex at Plant,Which Consumers Energy Co Had Provided for NRC Resident Inspectors Under 10CFR50.70(b)(1) ML20210S6961999-08-12012 August 1999 Forwards Insp Rept 50-155/99-04 on 990609-0730.No Violations Noted.No Safety Issues or Enforcement Items Were Identified During Insp ML20210L0321999-08-0303 August 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety & Documents Listed in App B Being Released in Part (Ref FOIA Exemption 6) ML20209D6951999-07-0707 July 1999 Ack Receipt of Which Requested That NRC Reconsider Decision to Move NRC Resident Inspector from Big Rock Point Plant.Determined Decision to Be Correct One ML20196E1601999-06-21021 June 1999 Forwards Insp Rept 50-155/99-03 on 990416-0608.No Violations Noted.Overall,Reactor Decommissioning Activities Performed Satisfactorily ML20207D1151999-05-27027 May 1999 Informs That Effective 990328,NRC Ofc of NRR Underwent Reorganization.Within Reorganization,Division of Licensing Project Management Created ML20206P0921999-05-0707 May 1999 Responds to Discussing Impact That Delays to Wesflex Sys Approval Would Have on Big Rock Point Decommissioning Cost & Schedule ML20206H1011999-05-0404 May 1999 Forwards Safety Evaluation for Exemption from Certain Physical Protection Requirements.Enclosure Contains Safeguards Info & Being Withheld ML20206E3721999-04-29029 April 1999 Informs That Based on Licensee Determinations That Changes in Rev 1 Do Not Decrease Effectiveness of Defueled EP & That Plan Continues to Meet Applicable Stds of 10CFR50.47(b) & Requirements of App E to Part 50,NRC Approval Not Required ML20206B7381999-04-26026 April 1999 Forwards Insp Rept 50-155/99-02 on 990226-0415.No Violations Noted.Activities in Areas of Facility Mgt & Control,Decommissioning Support,Spent Fuel Safety & Radiological Safety Were Examined ML20205E3471999-03-29029 March 1999 Informs That USNRC Granted Encl Exemption from Certain Requirements of 10CFR73,to Allow Implementation of Safeguards Contingency Plan Reflecting Permanent Shutdown & Defueled Condition of Brpnp in Response to ML20204F4611999-03-19019 March 1999 Forwards Insp Rept 50-155/99-01 on 990113-0225.One Violation of NRC Requirements Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20203C8971999-02-0808 February 1999 Informs That NRR Contracted with PNNL to Evaluate Storage of Spent Fuel at Number of Decomissioning Nuclear Power Facilities.Forwards Request for Info Re Spent Fuel Storage at Big Rock NPP ML20199H2431999-01-15015 January 1999 Forwards Insp Rept 50-155/98-09 on 981201-990112 & Nov.One Weakness Identified Re Event Involving Ungrappling Fuel Bundle Without Being Fully Seated in Rack & Without Independent Verification That Ungrappling Bundle Was Proper ML20199D9711999-01-13013 January 1999 Forwards Plant Defueled TS Administrative Replacement Pp.On 990104 Staff Informed NRC That Pp Numbering for Table of Contents Was Incorrect.Subj Pp Requested to Be Replaced with Encl ML20199E0781999-01-13013 January 1999 Informs That Staff Has Received Request for Exemption from Various 10CFR73 Pyhsical Protection Requirements Dated 981112.Exemption Request Improperly Based on Requirements of 10CFR50.12 Instead of Applicable Requirements of 10CFR73.5 ML20199E1841999-01-13013 January 1999 Forwards Environ Assessment & Finding of No Significant Impact Re Proposed Exemption from Certain Physical Protection Requirements of 10CFR73.Assessment Forwarded for Fr Publication ML20198K6551998-12-24024 December 1998 Forwards Amend 120 to License DPR-6 & Safety Evaluation. Amend Changes License DPR-6 & App A,Ts to Reflect Permanently Shutdown & Defueled Status of Plant ML20196H3171998-12-0303 December 1998 Forwards Insp Rept 50-155/98-08 on 980827-1130.No Violations Noted.Inspection Covered Activities in Areas of Radiological Safety ML20154M2211998-10-14014 October 1998 Forwards Insp Rept 50-155/98-07 on 980827-1007.No Violations Noted.Insp Consisted of Examination of Activities in Areas of Facility Mgt & Control,Decommissioning Support (Including Physical Security),Sf Safety & Radiological Safety ML20154E0121998-09-30030 September 1998 Forwards Exemption from 10CFR50.54(q) Re Plant & Suppls ,1120& 980302,0429 & 0828 Which Requested Exemption from Certain Protions of 10CFR50.47(b) & App E to 10CFR50 to Allow Brpnp to Discontinue Offsite EP Activities ML20239A2491998-09-0303 September 1998 Forwards Insp Rept 50-155/98-06 on 980716-0826.No Violations Noted.Overall,Reactor Decommissioning Activities Were Generally Performed Satisfactorily & as Planned.Potential Weaknesses Were Identified in Review of SE Procedure ML20237E2731998-08-25025 August 1998 Discusses NRC Insp Rept 50-155/98-03 on 980527.Violations Noted.Insp Findings Documented in NRC Insp Rept Sent to Util by Ltr ML20237C5461998-08-19019 August 1998 Refers to Revs 133,134 & 135 to Portions of Big Rock Point Plant Emergency Plan.Based on Determinations That Changes in Revs 133-135 Do Not Decrease Effectiveness of Emergency Plan,Nrc Approval Not Required ML20236Y0441998-08-0505 August 1998 Forwards Summary of Decommissioning Insp Plan Through March 1999.Plan Will Be Updated Approx Twice Each Yr & May Be Revised at Any Time Based on Future Insp Findings,Events & Resource Availability ML20236V0651998-07-28028 July 1998 Ack Receipt of 980605 Request for Withdrawal of 980325 Request for License Amend for DPR-6,paragraph 2.C.(5), Physical Protection & Closes TAC MA0756 ML20236U4311998-07-24024 July 1998 Forwards Insp Rept 50-155/98-05 on 980528-0715.No Violations Noted.Nrc Concern That Programmatic Assessments of RPP Were Not Initiated Following Identification of Multiple Deficiencies in RP Program During First Half of 1998 IR 05000155/19980041998-07-0808 July 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-155/98-04 ML20236M4131998-07-0707 July 1998 Ack Receipt of Ltr Dtd 980512,transmitting Changes Identified as Rev 14 to Big Rock Point Security Suitability, Training & Qualification Plan.No NRC Approval Required ML20249C4391998-06-25025 June 1998 Ack Receipt of ,Which Transmitted Changes to Rev 14 to Suitability,Training & Qualification Plan,Submitted Under Provisions 10CFR50.54(p) ML20249B3041998-06-16016 June 1998 Forwards Insp Rept 50-155/98-03 on 980407-0527.Violation Noted & Being Considered for Escalated Enforcement Action. Notice of Violation Not Presently Being Issued for Insp Finding ML20248F3541998-05-28028 May 1998 Responds to to P Harris Which Requested That NRC Retain Resident Inspector at Big Rock Site to Monitor Project for Period of Five Years.Informs That NRC Intends to Assign Inspector to Site for One Year ML20247M9481998-05-15015 May 1998 Ack Receipt of Ltr Dtd 980312,which Transmitted Changes Identified as Rev 7 to Safeguards Contingency Plan,Submitted Under Provisions of 10CFR50.54(p) ML20217D1221998-04-21021 April 1998 Forwards Insp Rept 50-155/98-02 on 980203-0406.No Violations Noted.Emergency Preparedness Exercise Was Completed Satisfactorily,However,Unusual Event Was Declared When Algae Containing Co-60 Alarmed Discharge Canal Radiation Monitor ML20217A5991998-04-16016 April 1998 Forwards Request for Addl Info Re Proposed Changes to Proposed Defueled TS as Detailed in .Questions Were Discussed W/Licensee Staff on 980121-22 & 980311.RAI Summarizes Questions That Remain ML20216J4411998-04-16016 April 1998 Informs That Consumer Request for Exemption from Certain Requirements of 10CFR50.54, Condition of Licenses, Based On,In Part,Determination That Plant Permanantly Shut Down & Defueled Not Required ML20216J9861998-04-16016 April 1998 Forwards SE Approving Licensee 970919 Submittal of Training Program for Certified Fuel Handlers.Comments Also Encl ML20247L4021998-04-14014 April 1998 Discusses Rev 131 to Chapter 5 & Rev 132 to Chapters 2,3 & Appendix H of Big Rock Point Plant Emergency Plan Submitted Under Provisions of 10CFR50.54(q).No NRC Approval Required ML20216G9071998-04-0808 April 1998 Responds to Asking Number of Questions Re Activities at Big Rock Point Nuclear Plant.Particularly on 980203 NRC Requested Addl Info from Utility Re Proposed Changes to Emergency Preparedness Plan ML20217J2131998-04-0202 April 1998 Forwards Copy of Each Revised Forms 398,personal Qualifications Statement & 396,certification of Medical Exam by Facility Licensee.Due to Error on Instructions for Form 398,addendum for Completing Form Are Provided IR 05000155/19970151998-03-20020 March 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-155/97-15 ML20246H0091998-03-19019 March 1998 Discusses Rev 130 to App a of Big Rock Point Nuclear Plants Emergency Plan,Received in Sept 1997.NRC Approval Not Required Based on Determination That Changes Do Not Decrease Effectiveness of Emergency Plan ML20203K7501998-02-26026 February 1998 Forwards Summary of Decommissioning Insp Plan for Remainder of Fy 1998.Plan Will Be Updated Approx Twice Each Yr & May Be Revised at Any Time Based on Future Insp Findings,Events, Resource Availability ML20203H8511998-02-23023 February 1998 Forwards Request for Addl Info Re Exemption from Offsite Emergency Planning Requirements.In Accordance with 10CFR50.30(b),response Must Be Executed in Signed Original Under Oath or Affirmation ML20202J8111998-02-14014 February 1998 Forwards Insp Rept 50-155/97-15 on 971205-980202 & Notice of Violation.Activities in Areas of Facility Mgt & Control, Decommissioning Support & Spent Fuel Safety ML20203E0811998-02-13013 February 1998 Informs That on 980331 & 0401,NRR Will Be Holding 1998 Decommissioning Power Reactor Counterparts Meeting in Arlington,Tx.Recipient Requested to Make Presentation at Subj Meeting.Meeting Agenda Encl ML20202D7751998-02-0808 February 1998 Ack Receipt of Ltr Dtd 980116,which Transmitted Changes Identified as Rev 32 to Big Rock Point Security Plan, Submitted Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Plan 1999-09-30
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SEP 0 692 Docket No. 50-155 EA 92-122 Consumers Power Company ATTN: William L. Beckman Plant Manager Big Rock Point Nuclear Plant 10269 US 31 North Charlevoix, MI 49720
Dear Mr. Backman:
SUBJECT: NOTICE OF V10l.ATION (NRC INSPECTION REPORT NO. 50-155/92017(DRP))
This will acknowledge receipt of your letter dated- August 20, 1992, in response to our letter dated July 22, 1992, transm-itting a Notice of Violation
] associated with Inspection Report No. 50-155/92017(DRP). We have reviewed j
- your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
Sincerely,
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- Edward G. Greenman, Director Division of P.eactor Projects
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Enclosure: Letter dated August 20, 1992 010043 See Attacheci Distribution RIII RIlly R R RIII
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uh3ttED STATES
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SEP C _ 2 Locket No. 50-155 EA 92-122 Consumers Power Company i
ATTil: William t.. Beckman Plant Manager Big Rock Point Nuclear Plar.t 10269 US 31 North Charlevoix, MI 49720
Dear Mr. Beckman:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-155/92017(DRP))
This will acknowledge receipt of your letter dated August 20, 1992, in response to our letter dated July 22, 1992, transmitting a Notice of Violation j associated with Inspection Report No. 50-155/92017(DRP). We have reviewed your corrective actions and have no further questions at this time. These
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corrective actions will be examined during future inspections.
Sincerely,
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Edward G. Greenman, Director Division of Reactor Projects Enclosurn Letter dated August 20, 1992 See Attached Distribution I _ _ _ _ _ _ _ _ - - _ _ _ _ _ _
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SEP u., n.c, C'onsumers Power Company 2
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Distribution:
cc w/ enclosure:
l David P. Hoffman, Vice President -
! Nuclear Operations i DCD/DCB (RIDS)
{ OC/LFDCB Resident inspector, Rill
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James R. Padgett, Michigan Public
- Service Commission
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Michigan Department of Public Health
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R. J. Stransky, LPM, NRR
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! C. J. Paperiello, RIII i
J. Lieberman, Director, OE-J. R. Goldberg, OGC J. G. Partlow, NRR i
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MICHIGAN 5 PROGRESS Big Rock Pcunt Nucloat Plant.10269 US 31 North, Charlevoix., MI 49720
August 20, 1992
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Nuclear Regulatory Cocznission Docuwent Control Desk Washington, DC 20555
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DOCKET 50-155 - LICENSE DPR-6 - BIC ROCK P0j NT PIANT - REPLY TO A NOTICE OF
VIOLATION (Nr J INSPECTION REPORT 50-155/92-017)
Enclosed is the reply to the Notice of Violation described in the Nut. lear Regulatory Consnission Inspection Report 50-155/92-017 dated July 22, 1992.
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Gregory C Withrow For William L Beckman (Signed)
, William L Beckman Plant Manager
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l CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Attachment
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ATTACllMENT Consumers Power Company Big Rock Point Plant Docket 50-155
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REPLY TO A NOTICE OF VIOLATION hRC INSPECTION REPORT 92017 August 20, 1992
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l V I Ol.AT I ON 92017-01
, Section 6.8.1 of the Technical Specifications states in part, " Written
- * procedures shall be established, implemented, and maintained for all structures, oystems, components, and safety actions defined in the Big Rock ;
Point Quality List." Section 5.2 of Chapter 13 of Volume 17 of the quality l j list requires procedures for maintenance and operations activities. Section ;
l $.6.1 of Administ rative Procedure 2.1.4, " Plant Status and Equipment l
} Control," which provides operational requirements for removing equipment from i service, states, in part, that prior to giving his permission, the shift i
supervisor shall verify that the equipment or system to be removed from service can be removed and that the method used to remove it from service is proper, i
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Cont rary to the above, on January 10, 1992, maintenance order periodic inst ructions EPS-0003 and SPS-0001 were released to allow work on the K-59-X and K-27-X emergency diesel generator overvoltage and undervoltage relays
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respectively without verifying that both relays could be removed from service
at the same time.
REASON FOR THE VIOLATION
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The Shift Supervisor released two maintenance oruers which permitted concurrent i testing of the Emergency Diesel undervoltage (K-27-X) and overvoltage (K-59-X)
relays. This action was determined to be personnel error. Neither the Shift
Supervisor nor the Technician performing the work were aware of the consequences that might occur because of inadequate job planning. This is considered to be an isolated incident.
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CORRECTIVE ACTION TAKEH AND RESULTS ACHIEVED
1. The appropriate activities in the Periodic Activities Controls Program
) were updated to include a reference to the fact that only one relay (K-27-X or K-59-X) be released at any one time for preventive maintenance. This action was completed by Hay 4, 1992.
I 2. A memorandum was addressed to the operations department describing that C-43, the auto transfer to the emergency generator switch on the C01 i
console, may not work to defeat ACB (air circuit breaker) closure if both K-27-X and K-59-X are " picked up" at the same time. This memorandum was issued by May 9, 1992.
CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS Several ongoing actions / programs will contribute to avoiding occurrences such
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as the concurrent testing of the EDC under and overvoltage relayat 1. Quality Verification Program This program is expected to of fer an inspection planning process. Both
"Q" and Non "Q" equipment will f all under the requirements of the program.
2. Planning / Scheduling is being improved by:
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developing a planning guide
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assigning a maintenance supervisor as a full time planner
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hiring an additional planner.
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Nuclear Regulatory Commission 2
!!ig Rock Point Plant REPLY ,TO VIOLATION 92-017-01 August 20, 1992 ATTACHMENT I
3. Converting the current Preventive Haintenance Program to a computerized Advanced Maintenance Management System ( AHMS). This action will consolidate PMs, data, history and schedule on a " user f riendly",
Company proven system.
DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED The f acil!Ly will be in full compliance by the end of 1992.
VIOLATION 92-017-02
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Section 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." Section 5.2 of Chapter 13 of Volume 17 of the quality list requires procedures for maintenance and operations activities. Section 5.3.2.b of Administrative Procedure 3.2.1, "Haintenance Order Processing,"
states in part that maintenance of equipment shall be planned and performed in accordance with written procedures, documented instructions, or drawings tha; at appropriate to the circumstances.
Contrary to the above, on Harch 10, 1992, a one inch compression fitting on the number one recirculation pump (RCP) seal water heat exchanger was
installed with naintenance order $91-PCS-0033. This maintenance order failed to contain adequate instructions for the proper installation of the
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compression fitting.
REASON FOR THE VIOLATION The maintenance order failed to contain adequate instructions for the installation of the compression fitting for the following reasons:
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Plant and Field Maintenance Service repairmen have received training on compression fitting installatior.. The skill of the craf t was assumed to be adequate to perform this task without special instruction. Matching the level of the experience of the crew commensurete is the level of detail in procedures will always provide a challenge for msnagers.
2. The Q-list does not classify RCP seal water heat exchangers as being safety related, therefore they are not subject to the requirements of the Quality Program. This would account for an inspection of the compression' fitting installation not being performed.
l CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED l 1. New instruc* ions / inspection checklist for compression fit tings (high
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pressure, greater than or equal to 3/4 inch) were written and l distributed to maintenance supervisors, planners, training and
! engineering departments. The maintenance planners will use these when
- - processing future applicabic maintenance orders.
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Thi s act ion was complet ed by May 28, 1992.
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OcciW ? - n 004 -B L01 i
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Nuclear Regulatory Consnission
- Big Rock Point Plant 3 REPLY TO VIOLATION 92-017-01 Augu'st 20, 1992 ATTACitHENT 2. Ey July 3,1992, upgraded compression type fitting training had been administered to Big Rock Point mechanical / electrical repairmen. The training included hands-on fitting assembly and use of the newly developed instruction / inspection c!.ecklist. The lesson plans for skills center training have also been upgraded to include the revisions described above.
CORRECTIVE ACTION 70 flE TAKEN TO PREVENT RECURRENCE 1.
The "Q" List classification of both one inch and 3/4 inch recirculation pump seal water heat exchanger will be reevaluated to determine if the heat exchangers should be classified as "Q". This action will be completed by November 1,1092.
2.
The Quality Verification Program is being developed to address "Q" and Won "Q" equipment,- and should help prevent these types of occurrences in -
thc future.
DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED The f ar.ility will be in full compilance by the end of 1992.
! VIOLATION 92-017-03 i
10 CFR part 50, Appendix B, Criterion V, states, in part, that activities af fecting quality shall be prescribed in documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above, on May 6,1992, tagging order f 92-0491 to remove the station battery charger f rom service did not contain instructions appropriate to the circumstances in that the instruction incorrectly specified the removal of the battery leads and not the battery charger leads.
REASON FOR Tile VIOLATION The reason for the violation has been identified as personnel error and procedural shift inadequacy. During the development of the tagging order, the supervisor and control room operator inadvertently substituted the word
" bat tery" for " battery charger" during their thought process. Within the equipment tagging section of the System Operating Procedure SOP-28,- Station Power,_it is not clear that the cables to be lifted during this sequence are
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between the charger end the battery. In addition, SOP-28 had yet tc be reviewed in accordance with a procedure improvement program established in 1991 per commitments made in Response to a Notice of Violation (NRC IR 50-155/
91005) Failure to Follow Procedures, dated July 9,1991.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED A.
Sect ion 7.5 of SOP-2B, Stat ion Power, was revised to clarif y the task of removing the station battery charger from service. The revision was issuad on July 14, 1992.
OC08'm 0004-it1.01
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Nuclear Regulatory Conmission 4
. Big Rock Point Plant
REPLY TO VIOLATION 92-011-01 August 20, 1992 i ATTACHHINT
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8. A memorandum suecarizing this event and emphasizing the need for obtaining outside assistance when the shif t personnel.cannot readily
identify the proper method or impact of removing equipment from service was issued and reviewed by Operations personnel. This action was
, completed May 30, 1992.
l CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS '
, 1. Review the equipment tagging section of the System Operating Procedures (Section 7.0) and the Haster Switching and Tagging Orders. Hake revisions, as required, to include the limiting conditions and necessary cautions
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for operation when equipment is removed from service. This action will
- be completed by October 15, 1992.
2. A "Self Checking Program" is expected to be implemented by the end of the third quarter of 1992 in the operations department. The purpose of this program is to address " blind compliance issues" as procedures improve and become more relied upon by the operating shifts.
3. An Administrative procedure is being authored to address SOER 91-01:
Infrequently Performed Task / Evaluations. The new procedure will consider training, management expectations, special controls and the need for increased controls to control these types of tasks. This procedure will be in place by the end of the third quarter of 1992.
l 4. a Procedure Implementation Task Force is currently being organized and is expected to be in place by the end of 1992. The- goal of this task i
force is to formulate guidelines to help the operator answer procedure need question.
5.
A " Morning Heeting" has recently been established as a forum for daily planning. The meeting is attendeu by department heads and representatives f rom major departments.
The meetings ~ are designed to be of short duration, and encourage a team approach to problem solving.
DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED l
The f acility is expected to be in full compliance by the end of 1992.
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OC0 89 ? -0004 A- Hl.01
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