IR 05000155/1993001
| ML20059C091 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/08/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035D921 | List: |
| References | |
| 50-155-93-01-01, 50-155-93-1-1, NUDOCS 9311010007 | |
| Download: ML20059C091 (12) | |
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Enclosure 1 SALP 11 FINAL SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report No. 50-155/93001 Consumers Power Company Bia Rock Point Nuclear Plant October 1.1991. throuah December 31. 1992 9311010007 93040s
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PDR ADDCK 05000155 O
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i Enclosure 1
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Bia Rock Point Nuclear Plant A.
Summary of Meetino with Consumers Power Company on March 18. 1993 The findings and conclusions of the SALP Board are documented in Report No. 50-155/93001 and were discussed with the licensee on March 18, 1993, at the Points North Inn, Charlevoix, Michigan.
While the meeting was primarily a discussion between the licensee and
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the NRC, it was open to members of the public as observers.
The following licensee and NRC personnel were in attendance, as well as the noted observers.
Consumers Power Company M. Morris, Chief Operating Officer D. Hoffman, Vice President, Nuclear Operations W. Beckman, Plant Manager P. Donnelly, Plant Manager D. Hughs, Executive Engineer G. Withrow, Engineering Superintendent W. Trubilowicz, Operations Superintendent, CPCo E. Bogue, Chemistry / Health Physics Superintendent
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T. Petrosky, Public Affairs Director R. Rice, Director Nuclear Performance Assessment M. Van Alst, Property Protection Supervisor L. Darrah, Operations Supervisor E. Evans, Electrical / Instrumentation and Control Engineering Supervisor
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D. Moeggenberg, Mechanical Engineering Supervisor D. Lacroix, Nuclear Training Administrator A. Katarsky, Big Rock Point Emergency Preparedness Coordinator T. Hagan, Director Nuclear Training C. Barsy, Chemistry Supervisor R. Alexander, Technical Engineer D. Turner, Maintenance Superintendent R. Sinderman, Rate Case Technical Analyst W. Merwin, Operating Experience Analyst T. Mosley, Sr. Engineer, Chemistry / Health Physics J
K. Wooster, Emergency Preparedness Coordinator J. Fremeau, Director, Nuclear Services T. Popa, Chemistry / Health Physics-ALARA Coordinator E. Zienert, Director, Human Resources W. Beckus, NPAD Performance Specialist
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D. Gaiser, Senior Engineer, Maintenance
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R. Sarki, Supervisor, Maintenance R. Joba, Supervisor, Performance Engineering i
S. LaJoice, Site Manager, Curns Security
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r fqclosure 1 R. McCalik, NPAD' Specialist
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R. Hill, NPAD Specialist.
J. Tilton, Senior Engineer Electrical L. Potter, I and C Supervisor S. Beachum, Special Projects Supervisor P-. Loomis,_NPAD Specialist
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J. Horon, Shift Supervisor G. Hausler, Shift Supervisor
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M. Bourassa, Senior Licensing Technician J. Lampman, Licensing Specialist S. Amstut2.. Staff Secretary to Plant Manager Nuclear Reaulatory Commission H. Miller, Deputy Regional Administrator, R3gion III
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E. Greenman, Director, Division of Reactci Projects (DRP)
L. Marsh, Project Director, PD 3-1, NRR M. Phillips, Section Chief, DRP E. Plettner, Senior Resident Inspector L. Olshan, Project Manager, NRR R. Leen.on, Seniur Resident Inspector
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Other E. Huma, Emergency Services Director Charlevoix County D. Hahn, Michigan Department of Public Health R. Whale, Michigan Public Service Commission J. Padgett, Michigan Public Service Commission B.
Comments Received from Licensee-
Consumer's Power's response to the Big Rock Point Initial SALP 11 Report-dated March 3,1993, included several comments that have resulted in a minor revision to the Initial SALP Report. These changes are listed in -
Enclosure 2 and the revised pages are included as Enclosure 3.
The affected pages of the Initial SALP Report should be replaced with the corrected pages included in Enclosure 3.
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Regional Administrator's Comments Based on Consideration of the Licensee Comments I have considered your written response to the SALP 11 initial report and the comments during the public meeting held on March 18,-1993.
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Enclosure 1 We acknowledge your plans to implement E0Ps for plant operations and to improve the MOV program in ETS prior to the startup following the 1993 refueling outage. We will review these during future inspections.
In Emergency Preparedness, we acknowledge the corrective actions on the exercise performance weakness were well underway late in the SALP 11 period.
However, completion of a second training session and demonstration of the corrective actions' effectiveness, based on March 1993 exercise performance, were essential to resolving our concerns.
In ETS you commented that the EDSFI results were positive. We believe the SALP report accurately portrays the results of the EDSFI. Selected
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important strengths and weaknesses were discussed in appropriate functional areas.
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In Safety Assessment and Quality Verification, we acknowledge your clarification of the reasons why the 1992 exercise performance weakness was categorized as only a recommendation for improvement rather than a traceable finding by the NPAD staff.
In addition, ve ecknowledge that only one of our four exercise concerns was categorized as a performance weakness.
It is my conclusion that the SALP 11 initial report ratings have not changed.
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Enclosure 2 REVISION SHEET pAGE LINE READS NOW SHOULD READ
31-35 Examples include the Examples include the
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improper installation of improper installation of compression fittings on compression fittings on a a primary pressure primary pressure i
boundary, improper boundary, improper coupling of the seventh coupling of the seventh turbine admission valve, turbine admission valve,
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improper repair of the and, most recently, i
turbine handtrip inadequate repair of the solenoid, and most
"B" reactor
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recently, inadequate depressurization valve repair of the "B" flange leaks.
reactor depressurization valve flange leaks.
Basis:
Repair of the main turbine handtrip solenoid was unsuccessful vice inadequate, therefore, it does not constitute an example of a lack of quality.
PAGE LINE READS NOW SHOULD READ
13-15 Following the discovery Following the discovery of a failed core flow of a failed core flow baffle plate hold-down baffle plate hold-down bolt, the initial bolt, the initial engineering analysis and engineering analysis was proposed acoustic inadequate and.the monitoring system were proposed acoustic inadequate.
monitoring system could not be calibrated at that time.
Basis: Subsequent information provided by the licensee identified a previously unknown loose part in the reactor vessel where upon correction, the acoustic monitoring system could have been calibrated.
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cause management was not effective in resolving procedural adherence i
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Trai ing, qualifications and the number of staff in chemistry and radiation protec ion (RP) remained good.
The chemistry and RP technician staffs
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experie ed low turnover. Contract RP technicians hired to support outage
activitic were effective in their assignments. The RP and chemistry superinten ent and RP supervisor were replaced after the previous individuals
transferred ithin the company. The ALARA program was improved by the addition of a enior RP technician to assist the ALARA coordinator in
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identifying ra ological concerns during maintenance job planning.
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addition the pre ious RP supervisor transferred to the outage management section, thus pro ding a stronger RP presence in the outage management section.
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Performance Rat
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Performance is rated Cat ory 2.
Performance was rated Category 2 during.the previous assessment perio
[P 3.
Recommendations None.
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Maintenance / Surveillance 1.
Analysis
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' Management effectiveness in ensuring qua Ty % mixed.
Weaknesses in post-maintenance testing and procedural complia (e werb noted. A lack of quality was observed resulting in several rework is Examples included the improper installation of compression fittings (q improper coupling of the seventh turbine admis ye primary pressure boundary, F
qnNalve, improper repair of the turbine hand trip solenoid, and, most recent Jadequate repair of the
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"B" reactor depressurization valve flange leaks.
ecluse root-cause analy' sis and failure modes were occasionally not documented, equipment problems could not be adequately addressed; this was also a concern 'n the previous assessment period.
At the end of the assessment perio, a root-c:tuse analysis training program was instituted.
On the positive side, maintenance-related turnovers anc br~efings ensured minimal delay of the work activities, and supervisors provi -d oversight to maintenance workers at job sites.
The plant staff continued o manage the number of control room equipment deficiencies with a " black bo d" condition
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being maintained throughout most of the period when the plant wa operating.
In addition, plant management instituted a preventive maintenance PM) self-assessment that identified several concerns. Midway through the as essment period, a number of specific programs were developed to address thes concerns.
These included upgrading and computerizing the maintenance ork request process, which allowed managers to track the status of maintena e
activities and to improve scheduling. Maintenance planning was improved 'ith the assignment of three dedicated planners and the development of a " job
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Enclosure 3
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because management was not effective in resolving procedural adherence problems.
Training, qualifications and the number of staff in chemistry and radiation protection (RP) remained good.
The chemistry and RP technician staffs experienced low turnover. Contract RP technicians hired to support outage activities were effective in their assignments.
The RP and chemistry superintendent and RP supervisor were replaced after the previous individuals transferred within the company. The ALARA program was improved by the addition of a Senior RP technician to assist the'ALARA coordinator in identifying radiological concerns during maintenance job planning.
In addition the previous RP supervisor transferred to the outage management section, thus providing a stronger RP presence in the outage management section.
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Performance Ratina
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Performance is rated Category 2.
Performance was rated Category 2 during the previous assessment period.
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Recommendations None.
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Maintenance / Surveillance 1.
Analysis Management effectiveness in ensuring quality was mixed.
Weaknesses in post-maintenance testing and procedural compliance were noted. A lack of quality
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was observed resulting in several rework issues. Examples included the improper installation of compression fittings on a primary pressure boundary, improper coupling of the seventh turbine admission valve, and, most recently, inadequate repair of the "B" reactor depressurization valve flange leaks.
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Because root-cause analysis and failure modes were occasionally not documented, equipment problems could not be adequately addressed; this was also a conce n in the previous assessment period. At the end of the assessment, iod, a root-cause analysis training program was instituted.
On the positive side, maintenance-related turnovers and briefings ensured minimal delay of the work activities, and supervisors provided oversight to maintenance workers at job sites.
The plant staff continued to manage the number of control room equipment deficiencies with a " black board" condition l
being maintained throughout most of the period when the plant was operating.
In addition, plant management instituted a preventive maintenance (PM) self-i assessment that identified several concerns. Midway through the assessment period, a number of specific programs were developed to address these concerns.
These included upgrading and computerizing the maintenance work request process, which allowed managers to track the status of maintenance activitics and to improve scheduling. Maintenance planning was improved with the assignment of three dedicated planners and the development of a " job i
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f procurement of parts and materials, assisting maintenance in determining w ich vendor recommendations should be followed for the preventive maintenance pr ram, and in resolving issues of component aging.
Technical support was also weak for the core spray system piping replacement modification.
Weaknuses identified included failure to obtain design basis information, inadequ te inservice testing of the core spray pumps, and inadequate post-modifica 'on testing. Also, the uncertainties associated with the results obtained om a computer program, which is used to predict flow to the core spray systen based upon pump performance data, had not been quantified.
Weaknesses in engineering support were also noted in the lack of analysis of adverse trend. ta. As a result, there were unidentified trends regarding repetitive relie valve failures and low EDG cooling water suction pressures that indicated po ti
. gradation.
Following the discovery of a failed core flow baffle te ho d-down bolt, the initial engineering analysis and the proposed acousti
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'toring system were inadequate. The net result of this effort was to ca additional off load of the core to replace the core flow baffle plate od wn bolts.
Engineering actions in implementing the repair were good. A mple of good resolution of technical issues was the special test to resolv station black-out issues.
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Enforcement history was good; owev, it had declined.
None of the violations issued indicated pr r ic problems.
Engineeringresourceswereoften.,rpfbed.
The staff was experienced.
However, many of the weaknesses not di a%ve could be attributed to the level of engineering support provided.
En 'rf# ring and technical support to the operations and maintenance departments wa dequate during normal operations but was strained during outages, when d with reactive work, and when
' making plant improvements. Also, the pla t t ff received insufficient support from corporate engineering organiz.io For example, staffing to support H0V work was insufficient to execute a ffective MOV program. This-was evidenced by poor progress in the MOV pro am, numerous errors in engineering calculations, and inappropriate ass mptions.
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Performance Rating Performance is rated Category 3.
Performance was ra -d ' (egory 2 during the
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previous assessment period.
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Recommendations The licensee should improve engineering capabilities and inv lvement in support of the Big Rock Point plant.
This is particularly im rtant in view of the demands imposed by plant aging.
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Safety Assessment /0uality Verification
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Analysis Management effectiveness in ensuring quality was mixed.
Management invoivement was apparent in attempts to resolve long-standing plant probl s,
such as the steam flow oscillations experienced on the main turbine.
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Enclosure 3 of procurement of parts and materials, assisting maintenance in determining which vendor recommendations should be followed for the preventive maintenance program, and io resolving issues of component aging.
Technical support was
I also weak for the core spray system piping replacement modification.
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Weaknesses identified included failure to obtain design basis information,
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inadequate inservice testing of the core spray pumps, and inadequate post-modification testing. Also, the uncertainties associated with the results obtained from a computer program, which is used to predict flow to the core spray system based upon pump performance data, had not been quantified.
Weaknesses in engineering support were also noted in the lack of analysis of adverse trend data. As a result, there were unidentified trends regarding repetitive relief valve failures and low EDG cooling water suction pressures that indicated potential degradation.
Following the discovery of a failed
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core flow baffle plate hold-down bolt, the initial engineering analysis was inadequate and the proposed acoustic monitoring system could not be calibrated at that time. The net result of this effort was to cause an additional off load of the core to replace the core flow baffle plate hold-down bolts.
Engineering actions in implementing the repair were good. An example of good resolution of technical issues was the special test to resolve station black-out issues.
Enforcement history was good; however, it had declined.
None of the violations issued indicated programmatic problems.
Engineering resources were often strained.
The staff was experienced.
However, many of the weaknesses noted above could be attributed to.the level H
of engineering support provided. Engineering and technical support to the operations and maintenance departments was adequate during normal operations but was strained during outages, when dealing with reactive work, and when making plant improvements. Also, the plant staff received insufficient support from corporate engineering organizations. For example, staffing to support MOV work was insufficient to execute an effective MOV program.
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was evidenced by poor progress in the MOV program, numerous errors in engineering calculations, and inappropriate assumptions. ~
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Performance Ratina Performance is rated Category 3.
Performance was rated Category 2 during the previous assessment period.
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Recommendations The licensee shou improve engineering capabilities and involvement in support of the Big ack Point plant.
This is particularly important in view
of the demands impose' by plant aging.
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Safety Assessment /Ouality Verification 1.
Analysis Management effectiveness in ensuring quality was mixed.
Management involvement was apparent in attempts to resolve long-standing plant problems, such as the steam flow osci'1 1tions experienced on the main turbine.
However.
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ESCLOSURE 4
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O Consumers-
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POWER
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hont Afaarger POWERING MICHIGAN'S PROGRESS sig %ct Po.et m,ct+at Plam, IC269 US 31 Nor:r. Cwie oA MI 487ao April 2, 1993
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Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i
DOCKET 50-155 - LICENSE DPR-6 - BIE ROCK PolNT PLANT -
RESPONSE TO THE INITIAL SALP 11 REFORT (INSPECTION REFORT 50-155/93-001)
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t We have reviewed the ir.itial SALP li report for the Big Rcck Foint Nuclear Plant covering the period from October 1,1991 through December 31, 1992.
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We would like to take this opportur.ity to respond to tie report.
i As we discussed at the SALP c.eeting,1992 was a difficult period for Big Reck j
Point, er.d the SALP Report covering this period was a disappointment to i
Consumers Power Company and especially the Big Rock Pcint Staff. However, as we have already communicated to the Big Rock Point Staff, we intend to lock j
forward and accept our challenges for 1993 and beyond in improving plant i
performance. - The weaknesses and recommendatier.s contained in this SALP Report j
are part of these challenges.
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We agree with the Staff's recc mendatien that cecmunicatien cott..a r -
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departmertal, external, and between regulator / licenses needs continued improve: ent.
The following paragraphs provide our ccaments and active plans to the report arranged by SALP Category.
Flant Operations We recognize that with the dif ficulties of e:rergent work in 1992, resources to I
support E0P improvement were insufficient during the SALP period to close all l
the open issues.
To improve, a meeting was held in the Region (4th quarter 1992) and a follow-up letter was submitted to describe our corrective actions in addressing the remaining issues. The agreed upon charges to the E0P's will be in place by startup from the 1991 Refueling Outage.
Radiolo:4al Controls Dose cont ci and AL ARA planning eff erts have had hicr. :ricrity over the last three to f ue years at Sig Rock poirt and e appreciate the recognition frce the Staff in the SALP Esport. Dose :cntrel will continue *.o remain a high priority as evidenced by our ear 1y impicrentttien of t e revised 10 CfR 20.
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E!CIDSURE 4
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NUCLEAR REGULATORY COMMISSION
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BIG ROCK POINT PLANT RESPONSE TO SALP 11 REPORT April 2. 1993 hintenance/Surveillence This section refers to our difficulties with the turbine as: "impropcr repair of the turbine hand trip solenoid" (HTS). Although CPCo acknowledges that the handtripsolenoidfailedtooperateonthree(3)occasionsduringthis period, none of the repair efforts were improper, following the failure of the llTS on October 5,1992, Region til sent a special inspector to the plant
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to review our troublesbuoting and repair efforts, and as documented in Inspection Report 92-021, no concerns or additional actions were identified.
One would conclude that our extensive troubleshooting and repair efforts were unsuccessful, but they should not be referred to as 1eproper. Since the sat.P ^
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period, in response to an additional HTS failure, a system design change has been installed (direct acting valve).
Emercency Precaredness CPCo was disappointed in the decline in this functional area. While there were no significant problems identified in the 1991 exercise, we did have one performance weakness in the 1992 exercise. The initial SALP Report discusses this weakness concerning co=.unications with State officials and states that not all corrective actions were completed by the end of the _ assessment period.
In fact, all corrective actions were completed before the end of the assessment period; however, performance in this area was not scheduled to be evaluated until the 1993 exercise.
The corrective actions were effective as evidenced by the recent successful 1993 Exercise in which preliminary results showed no performance weaknesses, follow up items or significant concerns.
Ericurity Consumers Power Company continues to increase security awareness at Big Rock Point and will reinforce our efforts to reduce the number of personnel errors committed by the plant staff.
Enoineerino/Teqhnical Scooort CPCo has reviewed this section and offers additional information in two areas:
Core flow baffle plate failum
HOV Program support a
With respect to the flow baffle plate hold-down bolt activities, our decisicn to terminate our efforts in resolving the NRC's contractor's comments on the engineering analyses to support continued operation, was rooted in our feeling that an impasse had been reached. Professional experts had a different opinion in the correct analytical approach. While it is true that the installed acoustic-monitoring system could not be calibrated because of a large background signature, it was later noted upon disassembly of the reactor internals. that a loose thermal shield wedge was discovered under the core MY mice acca 91G rp:vt tsege,pa
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fiUCLEAR REGULATORY COMMISSION
BIG ROCK POIKT PLANT RESPONSE TO SALP 11 REPORT April 2, 1992 support plate. This wedge was approximately the same size and weight as the nut which the accustic monitor was designed to detect. Had this part not been in the vessel it is highly likely that background noise would have been acceptable allowing system calibration and operability. We concluded that additional work, with the associated review and comment cycle, would only extend the outage further with no guarantee of a satisfactory resolution.
After discussions between CPCo and NRC management, this concern was mutually supported by both sides that the repair option was the appropriate choice.
Describing the acoustic monitoring syttem as inadequate is not appropriate, in light of the abcVe discussion.
Regarding the POV effort, CPCo does recognize that some errors were identified in cur calculations. To support onsite efforts, CPCo elected to erploy an offsite contractor to support our effort. Since the last outage Consumers Po er has assigned additional individuals to the tiOV effort to develop inplace and dP testin; procedures which are scheduled for the 1993 Refueling Outage.
One additional item rentioned by CPCo at the SALP meeting relates to the Electrical Distribution System Functional Inspection (EDSFI). Consumers Pcwer, especially BRP personnel expended significant engineering resources in
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preparation for, during, and after the EDSF1.
We believe that based upon your Inspection Report and discussions at the Exit tieetings that the results were very positive.
Safety Assessrant/0uality Verification The Initial SALP Report refers to Audits associated with the 1992 Emergency Exercise and concludes that no findings were identified. Our Audit organizaticn (tiPAD) did perform a surveillance on the 1992 exercise.
While the surveillance did not identify any findings, it did make recommendations for improvement, which we believe address weaknesses identified by the NRC.
Also the Eccrgency Planning organization had already identified a cor.cern in this area and corrective actions were in progress, so NPAD classified it as a recommendation only (it was self identified). We also believe that Inspection Reports92-012, 92-013 and 91-019 document positive conclusions on licensee assessment activity and follow-up in the Emergency Pre;aredness area.
Big Rcck Point is committed to continuously improving plant operattens to
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ensure that we are meeting industry standards, NRC expectations and to accomplish our goal of operating to the end of licensed life, May 31, 2000.
Patrick M Donnelly (Signed)
Patrics M Cor elly P1 ant Manager 00: Mmnis ator. Region Ill. UStiRC g
MC M Mn Inspector - Sig Rock Point e
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