ML20128N579

Submits follow-up Response to NRC Re Open Items Noted in EOP Insp Rept 50-155/92-13 on 920615-19.Corrective Actions:Associated Plant Specific Technical Guidelines & Design Basis Will Be Revised

ML20128N579
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	02/17/1993
From:	Beckman W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9302230302
Download: ML20128N579 (3)

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Williant L Beckman 11 ant Afanager MENNEAN5 PROGRLES Big Rock Point Nuclear Plant,10269 US-31 North, Charlevoit MI 49720 February 17, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

FOLLOW-UP RESPONSE.TO INSPECTION REPORT 92-013 EMERGENCY OPERATING PROCEDURES NRC letter dated July 17, 1992, transmitted the subject-Inspection Report-covering the E0P Inspection conducted on June-15_-19, 1992-at Big Rock Point.

CPCo submittal dated September 16,1992 provided an initial Lresponse to- the - ,

the Inspection Report and a' meeting was held in the Region'III office on-

, October 22, 1992. NRC Inspection Report 92-024 dated November:25, 1992 provided a summary of this meeting. This letter provides an update to our earlier response and a status of our corrective-action efforts. .

Open Item 155/92013 Resolution of Plant Specific Technical Guidelines l (PSIG) Concerns -

Three (3) specific issues were identified during the inspection with respect to the E0P's and PSTG's.

1). RC/L entry level at -17 below C/L vs . scram setpoint

2) RC/P entry level at 1435 psig vs scram setpoint (1385 psig)

3) Setpoint for RDS activation at 1800 psig in RC/P guideline.

a Consumers Power Company personnel presented the basis for the entry levels in' RC/L and PC/P during the meeting on October 22,1992. ~ Although details of this discussion are included-with Inspection Report, in summary, sufficient conservatism exist.s in entry condition value when compared to other BWR's.and that reducing the entry level (regt. iring E0P changes) would provide minimal benefit. Consumers Power did agree that the PSTG's bases for these two.(2) entry conditions needed improvement and is currently updating the basis document to include the justifications presented at the meeting.

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- s :- NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT

. FOLLOW-UP RESPONSE TO-IR 92-013 (E0P's)

February 17, 1993 With respect to the third item regarding manual RDS. actuation, the BRP E0P sponsor has conducted a review of the PCS overpressure scenarios and has concluded it prudent to change the E0P's. This review has concluded that although current guideline.of 1800 psig did not present a safety issue, a reduction to 1600 psig would provide additional conservatism without affecting the mitigation strategy in this area of the E0P's. The associated PSTG and design basis will also be revised to reflect this change.

With the completion of the above, and associated operator training, Consumers-Power considers our actions in response to this Open item complete.

Open Item 155/92013 E0P Writers Guide As discussed in our letter dated September 16, 1992 and at the. Region llI meeting, the Writers Guide for the BRP E0P's is currently being revised to provide sufficient guidance to maintain consistency when revising the EOP's.

This effort is approximately 80% complete at this time and will also address some of the " human factors" concerns raised during the Inspection (e.g.,

larger print size, consistency in symbol usage, etc..). For-the items identified in the Inspection Report not being addressed by Writers Guide changes, written justification will be provided. The E0P sponsor is utilizing industry references as well as NUREG/CR-5228 and NUREG-0899 in this effort.

Following review and approval of the Writers Guide, a copy along with the justifications discussed above will be provided to Region III.

Open Item 155/92013 E0P Verification and Validation Our actions to address this item remain essentially unchanged from those described in our September 16, 1992 letter.

Schedule for Corrective Actions As we discussed at the October 22, 1992 meeting, since the above efforts will conclude in revisions to the E0P's and Technical Bases, the ideal time to implement a transition is during a Refueling Outage. Currently our Refueling Outage is scheduled to begin in mid-July and all corrective actions including operator training on the changes will be completed prior to startup from the-outage. To meet this schedule, the following target dates have been established:

• Completion of the Writers Guide April 1, 1993' (excluding V & V)

• Completion of Validation & June 1, 1993 Verification Guidelines

• Issuance of revised E0P's and August 1, 1993 Technical Bases

• Completion of R0/SR0 Training 1993 Refueling Outage

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. . s NUCLEAR ~REGULATORi COMMISSION BIG ROCK POINT' PLANT JOLLOW-UP RESPONSE TO IR 92-013 (E0P's)

February 17, 1993-We will continue to keep Region III informed on.the progress of'our efforts and the completion of the milestones and should any additional questions or concerns arise, please contact us.

)uM 0 $l YWrf1 William L Beckman (Signed) e William L Beckman Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point l

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