ML20058L989
| ML20058L989 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/06/1990 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9008090157 | |
| Download: ML20058L989 (4) | |
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Nued.or Operstdosis MMM MFEC General Offices: 1946 Weet Pernell Road Jackson, MI 49201 e (617) 788 0463
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Nuclear Regulatory Commission
. Document Control Desk Washington, DC 20555 np
- DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
SALP 9 RESPONSE
'NRC letter' dated July 9,1990 contained the Systematic Assessment of Licensee Performance (SALP) No. 9 Board Report for our Ef'; Rock Point Nuclear Plant.
This it.tter provides Consumers Power Company's written comments regarding that report.
' Consumers Power Company thanks the NRC for,the feedback on activities at Big
- Rock Point from the period of January 1, 1989 through April 30, 1990. We "l
believe that all of the concerns identified will be addressed very effectively.
-Consumers Power Company appreciates the recognition of continued good performance-in Plant Operations and Emergency Preparedness and the improvement in Plant-
- Maintenance / Surveillance. As the report indicates, a lot of attention.
resources, and effort has gone into Plant Maintenance to support continued 1
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good performance of'BRP through its licensed life..In spite of the recognized ilmprovement, more attention and enhancement are planned for the SALP 10 time
. frame.- We will continue our aggressive 'eff orts in major equipment' overhauls s
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- and preventative maintenance during our next refueling outage. Training and personnel development will continue to ensure a skilled knowledgeable staff-remains as our strongest asset..
Consumers Power Company has concern in that the statement in the cover letter ofLthe SALP report ".....that there has been some overall decline in performance (in radiological' controls) during this SALP assessment period", does not u
W appear to be substantiated by the text of the report, u
,N The.B'ig Rock Point Plant has in recent years focused it's attention on the reduction of collective and individual doses, personnel contaminations, and y,
. radiological effluents. The past five (5) years has shown a steady decline in collective radiation dose. The total dose in 1989 was 160 person-rems, nearly T
the same as 156 person-rems in 1988. However, as noted in the report, 1989 had a much greater dose potential and the potential dose was mitigated by an m",
improved ALARA program. Personnel contaminations were also down from 293 in 1988 to 178 in 1989 as stated in the report. Airborne radioactive effluents 9008090157 900806
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'SALP 9 Response August 6,;1990-L also decreased by-approxh:ately 9% in 1989 from 1988. Consumers Power Company management does not believe these trends are indicetive of declining performance.
We' feel that we have been responsive to NRC initiatives and resolution of radiological issues.
In particular, the report noted that management
-involvement in radiological controls was evident, in ensuring quality.mprovements in confirmatory measurements, improved *proce.aures for.whole-body counting and internal dosimetry, plant-cleanliness, work training and establishment of goals for reducing personal contaminations, and adoption of current industry water quality guidelines and improvements in the chemistry quality control program (which was identified as a weakness in the last SALP period).
The three radiological controle inspection reports during this SALP period listed seventeen (17) open items, violations, or unresolved items. Sixteen F
(16) of the 17 items were listed as closed, which should be a good measure of-responsiveness-to NRC initiatives.
The identified weakness in management oversight associated with the condenser in-leakage test te misleading.
In this incident a small amount of noble gas leaked-from a loose pressure gauge. No surface or personnel contamination occurred as~ implied in the report.
O The SALP report also identified a continued weakness in reading a calibration curve and calibration standards in nonradiological confirmatory measureaants.
These weaknesses are not related. The last assessment period identified a problem in reading a calibration curve for silica analyses on a spectrophoto-meter. The current assessment period identified a disagreement.1n low-level-chloride enalyses using a turbidometric method.
The first problem was corrected. The chloride analyses is a problem with the precision of the turbidometer and variability among technicians. This problem can only be corrected with a different analytical method.
The summary page.also noted a decline in radiological controls training.
However, no mention of training deficiencies is noted in the text of the report or in any of the inspection reports.
Based on the above, we think that the declining trend in radiological controls noted'in the cover letter needs to be reevaluated. However, we note the NRCs concern in this area and will apply added attention to it.
1 OC0890-0256A-NLO4
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LNucisar Regulatory Commission 3-Big Rock Point.. Plant SALP,9 Response
-August 6.-1990-o In the Security area, Consumers Power Company is disappointed'that our increased efforts in the area 'did not result in recognition of at least an
" improving" trend..As we discussed at the SALP meeting, all indicators (ie, loggable events, enforcement history) along with exceptional personnel performance, deserve recognition. System improvements (ie,-CCTV, vital aree doors) did begin during the period and will continue through the next SALP period.
In the Safety Assessment / Quality Verification area, two misunderstandings were identified. The first, which was originally identified.in the E0P Inspection Report dated. May 24, 1990 was an oversight which we failed to identify during review of the E0P Report. This concern reflected from an understanding that only one' audit, limited to one Emergency Operating-Procedure was performed.
This surveillance actually contained a "walkdown" inspection of all the E0Ps-(EOP 1,2,3,4;'and EIP 2,3,4,5,6) along with interviews with Operations and Training personnel. What may have been misunderstood is that following the surveillance, all the concerns existed with only EIP-2 which resulted in corrective actions and further follow-up.
The report stated that the Updated Final Hazards Summary Report (FHSR) was not completed on time. This was. incorrect. The updated FHSR was submitted on
-December 22, 1989 and the commitment date was December 31,-1989.
The following additional' comments are provided to correct errors we identified in'the report.
On page 20, the report states that "the improved performance incentive program was temporarily suspended when the instrument and control department was issued a Severity Level V violation."- This is incorrect, the program was not suspended. Although the I6C Department was-removed from the program, at the same time, the Reactor Engineering.and Emergency Preparedness Departments were added to the program.
s On page 22, items 2 and 4 refer to two reactor shutdowns which did not occur.
In April of 1989 power was reduced to repair the turbine governor valve, but not shut down. The event described on April 23,-1989 did not occur at BRP..Also the start of the Refueling Outage was June 9 not June 6.
On page'25, Table 2, the total number of causes under the SALP 8 category doesn't add up.
The total should be 13 not 10.
Consumers Power Company thanks you for your attention. We sincerely intend to OC0890-0256A-NLO4
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B'ig' Rock Point. Plant '.
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communicate. openly and frequently with the NRC.. We are committed, as are you.
to continue to make Big Rock Point a very safe' operation.
5
' David P Hoffman--
- Vice-President a
- -. Nuclear Operations-CC'. Administrator, Region III, USNRC.
NRC Resident-Inspector
. Big Rock Point Plant
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