IR 05000155/1998004
| ML20236M079 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/08/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| 50-155-98-04, 50-155-98-4, NUDOCS 9807130288 | |
| Download: ML20236M079 (2) | |
Text
July 8, 1998
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-155/98004(DRS))
Dear Mr. Powers:
This will acknowledge receipt of your letter dated June 30,1998, in response to our letter dated June 4,1998, transmitting a Notice of Violation associated with the use of inappropriate performance measures for structures, systems, and components in the maintenance rule
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I program at the Big Rock Point Nuclear Plant. We have reviewed your corrective actions and j
have no further questions at this time. These corrective actions will be examined during future
inspections.
Sincerely, Original /s/ R. N. Gardner for j8j71}$$ goo
John A. Grobe, Director G
PDR Division of Reactor Safety l
Docket No. 50-155
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License No. DPR-6 Enclosure: Ltr did 6/30/98 from K. Powers, Consumers Energy to USNRC cc w/o encl:
R. A. Fenech, Senior Vice President, Nuclear, Fossil, and Hydro Operations cc w/ encl:
Richard Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Department of Attorney General (MI)
Emergency Management Division, Michigan Department of State Police See Attached Distribution DOCUMENT NAME: G:DRS\\ BIG 98004.TY re r.e.w..m.t ein e.c oe== m e w=: c cam. m v.w.r. cme.uc - w.r-mem OFFICE Rlli f Rlli A/ Rlli M ]C Rlli ld
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Grobe ML DATE 07/f /98 07/5'/9d, "
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bmsumersEnergy
?lPlP A CMS Energy Company Big Rock Point Nuclear Plant KM R Nm r
10269 L6-31 North Site General Manager Charlevoix. MI 49720 June 30, 1998 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKET 50-155 LICENSE DPR 6 BIG ROCK POINT PLANT - REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004.
On May 8th, the NRC completed an inspection of the implementation of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Mainter ance at Nuclear Power Plants" at the Big Rock Point Plant.
The NRC inspectors identified two violations of NRC requirements. Both violations were contrary to 10 CFR 50.65(a)(1) and (a)(2). As of July 10, 1996, the Big Rock Point staff elected not to monitor the performance or condition of certain Systems Structures, and Components (SSCs) against established goals pursuant to the requirements of Sectiori (a)(1),
and failed to demonstrate that_.the performance or condition of SSCs within the scope of 10 CFR 50.65 had been effectively controlled by performing appropriate preventative maintenance.
Consumers Energy Company agrees with the violations as stated. The facility is currently in full compliance.
Pursuant to the direction provided in the report find attached a Reply to the Notice of Violation. The corrective actions taken and proposed are intended to address the concerns expressed by the NRC Inspectors, and to prevent recurrence of similar i cidents.
enneth P Powers Site General Manager CC: Administrator. Region III. USNRC NRC Resident inspector - Big Rock Point NRR Project Manager - OWFN, USNRC ATTACHMENT
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ATTACHMENT CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT
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DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 98004 Submitted June 30, 1998
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i REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004 NOTICE OF VIOLATION Consumers Energy Company Docket No. 50-155 Big Rock Point Nuclear Plant License No. DPR-6
EA 98-282 i
During an NRC inspection completed on May 8.1998. violations -of NRC
requirements were identifled.
In accordance with NUREG-1600. " General Statement of Policy and Procedure for NRC Enforcement Actions. " the violations
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are listed below:
10 CFR 50.65(a)(1) requires, in part. the holders of an operating license i
shall monitor the performance or condition of SSCs within the scope of the i
monitoring program, as defined in 10 CFR 50.65(b). against licensee-established goals in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety.
When the performance or condition of an SSC does not neet established goals, appropriate corrective action shall be taken.
10 CFR 50.65(a)(2) requires, in part. that monitoring c specified in 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function.
Contrary to 10 CFR 50.65(a)(2). as of July 10. 1996, the time that the licensee elected not to monitor the performance or condition of certain SSCs against established goals' pursuant to the requirements of Section (a)(1) the licensee failed to demonstrate that the performance or condition of SSCs within the scope of 10 CFR 50.65 had been effectively controlled by performing i
appropriate preventive maintenance, as evidenced by the following examples.
each of which constitutes a separate violation:
1.
The licensee failed to adequately demonstrate that the performance or condition of functions of the reactor cooling water, station power.
l spent fuel storage rack, and fuel bundic configuration systems had been l
effectively controlled by performing appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2).
Specifica11y. the licensee's basis for placing these SSC functions under l
the requirements of 10 CFR 50.65 (a)(2) was inadequate because plant l
1evel measures were used in assessing preventive maintenance.
Failures of these SSCs would not necessarily result in unplanned scrams, safety
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system actuations or an unplanned capability loss factor. Further, none
.of these parameters were appropriate for a permanently shutdown plant.
As a result, it was not demonstrated that effective preventive maintenance ensured that the functions of these systems remained capable of performing as required.
(04011)
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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004 2.
The licensee failed to adequately demonstrate that the performance or condition of functions of the demineralized water. emergency power. fuel handling, and radiation monitoring systems had been effectively controlled by performing approprute preventive maintenance in accordance with the requirements 0: 10 CFR 50.65(a)(2). Specifically, the measures used in the demonstration for these system functions consisted only of an inappropriate reliability measure that allowed repetitive maintenance preventable functional faifures that are a measure of corrective action rather than reliability. As a result. it was not demonstrated that effective preventive maintenance ensured that the functions of these systems remained capable of performing as required. (04012)
This is a Severity Level IV violation (Supplement IV).
Consumers Energy Company agrees with the violations as stated.
I. Reason for the violations.
Big Rock Point management did not dedicate the appropriate level of ownership and resources to ensure complete compliance with the Rule.
II. The corrective steos that have been taken and the results achieved.
_ Violation 04011 The following corrective actions in the identified areas have been taken:
a.
Reactor' Cooling Water System Function l
The Reactor Cooling Water System function (which is the 3 referred method of heat removal from the spent fuel pool system heat exc1 angers) plant performance criteria was revised to one MPFF for the system function in Expert Panel Meeting 98-02. 5/6/98. Condition reports from 1993 forward were reviewed. A functional failure of a' relief valve on the shell side of one of the fuel pit heat exchangers was found during a three year surveillance. which occurred in July of 1996. At that particular point i
in time, the plant was.in shutdown with return to operation after the j
refueling outage. Expert panel discussed this event at a meeting held June 10. 1998. The maintenance supervisor believed that a goal of successfully completing the post maintenance test was an acceptable basis for (a)(2) categories. The system engineer has initiated the three year surveillance to be performed a year earlier (SFP051. WO #12810700, on RV-5031. #2 heat exchanger). The periodic maintenance to inspect and calibrate RV-5030 (#1 heat exchanger relief valve) will be generated if RV-5031' test is unsatisfactory. The expert panel agreed that the relief valve should remain in maintenance rule category (a)(2) until the results of-the surveillance are obtained.
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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004 b.
Station Power System Function The Station Power System function, which had the plant level performance criteria " Provide power for essential services and equipment required during design basis events, assuming no loss of offsite power", was revised in the plant 0-List to: "The station power system (SPS) provides
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the source of power for services and equipment assuming no loss of offsite power". This system function was found to be in-scope to the Maintenance Rule in expert panel meeting 98-01. Performance criteria for this revised system function was set in Expert Panel Meeting 98-02, to
be one MPFF. Condition reports from 1993 on were reviewed and one potential MPFF was discovered, which occurred 5/30/96. Station battery charger was not functioning and batteries were unable to provide 125 Vdc power. Since the event has not recurred in over two years, the systems performance has been adequate and will remain in category (a)(2).
c.
Spent Fuel Storage Rack System Function The Spent Fuel Storage Rack System function " Spent and new fuel storage rack spacing: provides structural integrity and fuel bundle spacing,"
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was revised in the plant Q-List to: " Spent fuel storage rack spacing which ensures and maintains subcritical configuration among the stored fuel bundles." This system function was found to be in-scope to the Maintenance Rule in expert panel meeting 98-01, 4/98. Plant level performance criteria for this system function was revised in Expert Panel Meeting 98-02, to be one MPFF. Condition reports from 1993 on were reviewed and no functional failures were identified.
d.
Fuel Bundle Configuration System Function The Fuel Bundle Configuration System function, " Fuel bundle configuration, constitution and pressure boundary (UFHSR 4.2)", was revised in the plant 0-List to: " Fuel Bundle configuration, constitution and pressure boundary (cladding)." This system function was found to be in-scope to the Maintenance Rule in expert panel meeting 98-01. Plant level performance criteria for this revised system function was revised in Expert Panel Meeting 98-02, to be condition monitoring with at least
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a two year review or walkdown.
This condition monitoring criteria was re-reviewed in Expert Panel Meeting 98-03, 6/10/98, since fuel cladding is not inspected on a regular basis due to ALARA (As Low As Reasonably Achievable)
considerations. When the fuel was removed from the reactor, a visual inspection was done on the oldest and newest bundles to inspect cladding integrity. Currently, there is no inspection for system function FFI-010. Fission products are not monitored in the spent fuel pool (based on the assumption that there were no suspect cladding failures when the bundles were in the reactor, a much harsher environment). If a bundle is dropped during fuel moves, a visual examination is done. Performance criteria for this system functions was set as a single MPFF as l
documented on a condition report for a cause determination if a bundle j
is dropped and cladding failure is suspected. Condition reports from
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REPLY T0 A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004 l
1993 on were reviewed and no functional failures were identified.
Violation 04012 a.
Demineralized Water System Function
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Demineralized Water System Function is to " Provide makeup water to spent fuel pool. reactor cooling water system, reactor building heating and cooling system, and the heating boiler". The inappropriate performance criteria of repetitive MPFFs was identified in a self assessment in May, i
1997. At the time of the assessment, MPFF's were reviewed to determine L
if revising a repetitive MPFF within a time frame to less than two MPFF's within that time frame would result in exceedance of performance criteria. This system function was required in this review. A single MPFF occurred 2/4/95: the demineralized water pump breaker failed resulting in failure of the motor to run (C-BRP-95-078). In the review after the assessment, this event did not result in exceeded performance criteria. In the May 1998 Expert Panel Meeting. the performance criteria for this system function was revised to a single MPFF. Since the event has not recurred in over two years, its performance has been adequate and will remain in category (a)(2).
b.
Emergency Power System Function Emergency Power System Function is to " Provide backup power sources for essential equipment and services for normal plant system operation during decommissioning upon loss of off-site power". The emergency diesel. generator (EDG). which supports this system function, was in category (a)(1) until August of 1996 when effectiveness of maintenance on a rheostat was demonstrated. In addition, the EDG had several MPFF's, which had dissimilar failure causes in 1996. Since the events have not
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recurred within two years, its will remain in category (a)(2). performance is considered adequate and it i
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Prior to April 1998 Expert Panel Meeting, the standby diesel generator (SDG) was specifically excluded from the scope of the maintenance rule.
At the April 1998 Expert Panel Meeting, the SDG was included in this system function due to planned modifications. Review of corrective l
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action during the Periodic Maintenance Effectiveness Assessment for this system function revealed several failures of the standby diesel
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l generator. The SDG has been recommended for elevation to category (a)(1)
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June 30, 1998.
c.
Fuel Handling System Function Fuel Handling System Function is to provide a " Transfer cask to maintain fuel bundle cooling and cladding integrity during transfer of fuel" This function has inappropriate performance criteria of repetitive MPFF's. This has been revised to one MPFF. Corrective action was reviewed for a three year period, and no MPFFS were identified for this
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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004 L
l system function.
I d.
Radiation Monitoring System Function l
Radiation Monitoring System Function is to " Perform the nonsafety l
related function of monitoring the fuel storage area... indirectly monitoring the spent fuel pool by alarming on high radiation as a result of low pool water level". Review of three year's condition reports revealed an unplanned safety system actuation in March. 1996. The vent valves closed. This was not considered as a functional failure. since
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the actuation was not a result of low fuel pool level or high l
containment pressure.
Although the performance criteria were not revised / reviewed in a timely manner, the Maintenance Rule Administrator was still reviewing MPFF's within the time frame of the inappropriate performance criteria, and no MPFF's for-the system functions identified were-found.
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III. The corrective steos that will be taken to avoid recurrence.
Violation 04011 1.
Timeliness of Technical documents available for the input-to the -
revision of the maintenance rule should be a one-time event. As a result, Decommissioning process priorities have been appropriately set.
2.
Fuel pit heat exchanger relief valve surveillance has been accelerated to determine if its performance is satisfactory. Relief valve will be
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tested to assess maintenance effectiveness. Category determination will be made by September 30, 1998, based upon test results.
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IV. The date when the facility will be in full comoliance.
The facility is currently in full compliance. Full compliance has been achieved with the revision of performance criteria and completion of the review of system functions.
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