ML20057E753

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Forwards Insp Rept 50-155/93-15 on 930824-0914.Seven Apparent Violations Noted & Being Considered for Escalated Enforcement Action
ML20057E753
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 10/05/1993
From: Greenman E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Donnelly P
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
Shared Package
ML20057E754 List:
References
EA-93-233, NUDOCS 9310130116
Download: ML20057E753 (5)


See also: IR 05000155/1993015

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007 0 5 1993

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Docket No. 50-155

License No. DPR-6

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EA No.93-233

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Consumers Power Company-

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ATTN:

P. M. Donnelly

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Plant Manager

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Big Rock Point Nuclear Plant

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10269 US 31 North

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Charlevoix, MI 49720

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Dear Mr. Donnelly:

SUBJECT: NRC INSPECTION. REPORT NO. 50-155/93015

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This refers to the special inspection conducted by Messrs. R. Leemon and.

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C. Brown of this office, Mr. D. Desaulniers from the Office of Nuclear Reactor

Regulation's Human Factors Branch, and Mr. G. Bryan, an NRC contractor. The

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inspection was conducted from August 24'through September 14,.1993, and

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focused on the conditions surrounding the hydrostatic primary system test and

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a breach of containment integrity with a concurrent mode change that occurred-

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at your Big Rock facility. At the conclusion of the inspection, the findings

were discussed with those members of your staff identified in the enclosed

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report.

Within the above areas the inspection consisted of selective examinations of

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procedures and representative records, and interviews with personnel. The-

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purpose of the inspection was to determine whether activities authorized by

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the license were conducted safely and in accordance with NRC requirements.

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Based on the results of this inspection, seven examples of apparent violations

were identified and are being considered for escalated enforcement action in

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accordance with the " General Statement of Policy and Procedure for NRC

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Enforcement Actions" (Enforcement Policy),10 CFR Part 2, Appendix C (1993).

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The. examples of apparent violations concern two events where inadequate

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control over plant evolutions was exercised. The first involved five examples

of apparent violations associated with containment integrity. The examples'

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related to two examples of inadequate procedures, two examples of failure to

follow procedures, and one example of inadequate coirective actions. The

second event involved two apparent violations associated with the performance

of a system pressure test that ultimately resulted in the-lifting of a safety

relief valve and rupture of four rupture disks on the overpressurization of

the primary system.

The examples related to failure to follow procedures and

insufficient proficiency on the part of personnel performing the test.

Accordingly, no Notice of Violation is presently'being issued for these

' inspection findings.

In addition, please be advised that' the number and

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9310130116 931005

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Consumers Power Company

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characterization of apparent violations described in the enclosed inspection

report may change as a result of further NRC review.

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We are particularly concerned about both of these recent examples of loss of

control of licensed activities at the Big Rock Point facility because the

underlying causes are essentially identical to those for which we held

previous enforcement conferences with Consumers Power on July 9, 1992,

regarding Big Rock Point and August'10, 1993, regarding Palisades, another

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Consumers Power facility. All of these events involve a failure on the part

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of shift management te maintain an awareness of overall plant conditions.

This recent case of an inadequate switching and tagging order, resulting in a

loss of containment integrity, was similar to a switching cnd tagging order

violation in 1992 regarding the removal of the battery charger from service.

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The hydro overpressure event was almost identical in its causes to the recent

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Palisades control rod withdrawal event. Common causes that led to both events

involved inadequate job briefings, the tendency of shift supervision to get

involved in troubleshooting and lose focus on the overall status of the plant,

inadequate communications between the job site and control room, and

inadequate work practices in the performance of the respective tasks. After

the Palisades control rod withdrawal event, the lessons to be learned were

published at Big Rock Point. Given that the Palisades event occurred in June

1993, corrective actions for Consumers Power should have been developed and

implemented regarding the above commonalities to preclude similar events at

Bic Rock Point.

In addition to line management, we are concerned that your

Nuclear Performance Assessment Department (NPAD) has not contributed

significantly in helping ensure that these types of events would not occur.

An enforcement conference to discuss-this apparent violation has been

scheduled for October 12, 1993. The decision to hold an enforcement

conference does not mean that the NRC has determined that a violation has

occurred or that enforcement action will be taken. The purposes of this

conference are to discuss the apparent violations, their causes and safety

significance; to provide you the opportunity to point out any errors in our

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inspection report, and to provide an opportunity for you to present your

proposed corrective actions.

In addition, this is an opportunity for you to

provide any information concerning your perspectives on 1) the severity of the

violation, 2) the application of the factors that the NRC considers when it

determines the amount of a civil penalty that may be assessed in accordance

with Section VI.B.2 of the Enforcement Policy, and 3) any other application of

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the Enforcement Policy to this case, including the exercise of discretion in

accordance with Section VII.

You will be advised by separate correspondence

of the results of our deliberations on this matter. No response regarding the

apparent violation is required at this time.

Given the conditions surrounding these events, in addition to addressing the

specific examples of violations, we expect you to address the actions you have

taken to assure yourselves that the breakdowns in control of licensed

activities represented by these events will not be continued and that the

proposed corrective actions are of sufficient breadth to preclude repetition

of similar events.

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OCT 0 51993

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Consumers Power Company

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and the enclosures will be placed in the NRC Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

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Sincerely,

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Edward G. Greenman, Director

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Division of Reactor Projects

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Enclosure:

Inspection Report

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No. 50-155/93015(DRP)

cc w/ enclosure:

David P. Hoffman, Vice President

Nut.Lar Operations

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Resident Inspector, RIII

James R.Padgett, Michigan Public

Service Commission

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Michigan Department of

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Public Health

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Big Rock Point,

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SRI, Palisades

J. G. Partlow, NRR

J. Lieberman, OE

J. R. Goldberg, OGC

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the proposed corrective actions are of sufficient breadth to preclude

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repetition of.similar events.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and the enclosures will be placed in the NRC Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

Edward G. Greenman, Director

Division of Reactor Projects

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Enclosure:

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Inspection Report

No. 50-155/93015(DRP)

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cc w/ enclosure:

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David P. Hoffman, Vice President

Nuclear Operations

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Resident Inspector, RIII

James R.Padgett, Michigan Public

Service Commission

Michigan Department of

Public Health

Big Rock Point, LPM, NRR

SRI, Palisades

J. G. Partlow, NRR

J. Lieberman, OE

J. R. Goldberg, OGC

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Consumers Power Company

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter and the enclosures will be placed in the NRC Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

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Sincerely,

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Edward G. Greenman, Director

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Division of Reactor Projects

Enclosure:

Inspection Report

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No. 50-155/93015(DRP)

cc w/ enclosure:

David P. Hoffman, Vice President

Nuclear Operations

OC/LFDCB

Resident Inspector, Rill

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James R.Padgett, Michigan Public

Service Commission

Michigan Department of

Public Health

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Big Rock Point, LPM, NRR

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SRI, Palisades

J. G. Partlow, NRR

J. Lieberman, OE

J. R. Goldberg, 0GC

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