ML20198R535

Responds to NRC Re Violations Noted in Insp Rept 50-155/97-13.Corrective Actions:Removed Two Items from Span 19 to Reduce Weight to 342 Pounds & Performed Evaluation of Effect of Overloading of Spans 18,19 & 20

ML20198R535
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/15/1998
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-155-97-13, NUDOCS 9801230338
Download: ML20198R535 (5)

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A CMS Ewn COntmy By Roch Pornt Nuckar funt Enneneh P. M K39 l641 Nxm Site Gewal Manager Chanescu, M 49720 January 15, 1998 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKET 50-155 - LICENSE DPR-6 BIG ROCK POINT PLANT - REPLY TO NOTICE OF VIOLATION - NRC INSPECTION REPORT 97013 During an NRC inspection of decommissioning activities at Big Rock Point, completed December 4, 1997, a violation of NRC requirements was identified and forwarded by letter dated December 17, 1997.

The violation involved exceeding the weight limit on Spent Fuel Pool rail span No. 19. Consumers Energy Company concurs with the NRC in that the violation is of concern, because it may reflect inadequate attention to detail and a lack of a questioning attitude about fuel pool safety controls, at a time when fuel safety should be an issue of particular focus, t c

Consumers Energy Company agrees with the violation as stated.

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 similai events.

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Kenneth P. Powers \

Site Director and Decommissioning General Manager 5 cc: A :inistrator, Region III, USNRC NRC Resident Inspector - Big Rock Point NRR Project Manager - OWFN, USNRC ATTACHMENT , , , , ,

9001230338 990115 "fiiiOb 4 ,n D h 1

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ATTACHMENT CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 97013 Submitted January 15, 1998

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REPLY TO A NOTICE OF_ VIOLATION - NRC INSPECTION REPORT 97013 During an NRC Inspection conducted from fictober 8,1997, through December 4,1997, one vfolation of NRC requirements was identifled.

in accordance with the " General State,nent of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

Violation 97013-01 Big Rock Point Tecnnical Specification 6.8.1 includes a requirement that written procedures be implemented for all structures, systems, components, and safety actions defined in <

the Big Rock Point Quality List, and these procedures must  ;

meet or exceed ti.e requirements of ANSI N18.7. as endorsed by CPC-2A, " Quality Program Description for Operational Nuclear  ?

Power Plants."

Section S.2 of CPC-2A includes a stipulation that system operating procedures are used to control activities affecting

. refueling. System Operating Procedure SOP-44, " Spent Fuel Pool Operations and New Fuel Handiing," Revision 135, Step

-3.0..i restricts the total load on any span of the spent fuel x pool rai1 to 350 pounds.

Contrary to the above, on October 29, 1997, the items that were hanging from the spent fuel pool rail span No.19 had a combined weight of 497 pounds. The length of time that the eight on the rail exceeded the weight restriction could not ce determined by review of records.

This is a Severity Level IV violation (Supplement I).

Consumers Energy Company agrees with the violation as stated.

I. Reason for the violation.

Load limitations were established on the Spent Fuel Pool rails in 1986. When these pipe rail limits were incorporated into operational procedures, no method was provided, other than operator judgement, to measure compliance with the prescribed limits. The reason for this was inappropriate management standards which existed about this topic until the time of violation.

Discussion In 1974, the Spent Fuel Pool was modified by installing a liner plate and a leak chase system. This included a pipe rail around sides of the Spent Fuel Pool, which was used for storage of tools '

and fuel handling equipment. No guidance or limitations for use were prescribed for this particular aspect of the Spent Fuel Pool Liner until 1986.

In 1987, Standard Operational Procedures (50P) were revised to include the load limits on the Spent Fuel Pool pipe rail. However, no method (other than operator judgement), was given in determining the weight of loads on the rail, or specifying how to perform surveillances to determine compliance with the limits. A reliance on personnel knowledge and communicatio'is was assumed, with no written documentation requirement.

In 1991, the need to develop a Spent Fuel Pool Cable Log was identified and implemented. However, the cable log iid not provide the ability to document the weight of items hung on the pipe rail. ,

During planned decommissioning tasks to weigh, inventory, and

.laracterize all fuel pool items, 60 of 61 items hanging from the 21 rail spans were weighed. Twenty of'the twenty-one rail spans were within the specified limit. Only Span No. 19 was determined to be over the limit (by 147 pounds), with six items contributing a total weight of 497 pounds. j II. The corrective steos that have been taken and results achieved

1. Upon discovery on October 29, 1997, that Spent Fuel Pool span No. 19 exceeded the 350 pounds allowed by procedure, two items were removed from the span to reduce the weight to 342 pounds.

This condition was documented via the plant Corrective Action Program and also communicated to Operations via the Daily Orders. Span No. 19 and adjacent spans, Nos. 18 and 20, were restricted from having any items added to these spans until the condition was evaluated.

2. An evaluation of the effect of overloading Span No. 19, ,

including the impact on adjacent Span Nos. 18 and 20 and $

6ssociated supports, was performed. This evaluation included the weights on each of these three spans. The evaluation concluded that the 147 pound overload on Span No. 19 consituted a one time " alternate loading condition" that exceeded AISC allowable stresses, which is a Big Rock Point committed code, but did not cause any of the load bearing

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members to reach yield stress. Based upon this evaluation, it was determined that this loading condition had not impacted the safety of the plant.

3. A weighing method was developed, using the Spent Fuel Pool winch, a scale and cables.

A " move" sheet, approved by the Shift Supervisor and a Nuclear Fuel Projects Supervisor, is now required prior to moving any item in the Spent Fuel Pool. Any changes to the move sheet will be approved by a Shift Supervisor and Nuclear Fuel Projects. Both of these items have been added into procedure SOP-44 III. The corrective steos that will be taken to avoid recurrence.

The Spent Fuel Pool Cable Log has been revised to include the weights of the items on the cables. Weights have been obtained for the loaded spans, except for Span No. 9. This load is difficult to weigh, but is easily moved by hand, lending reasonable assurance that the load is less than 350 pounds. This load will be weighed and dispositioned by the end of the second quarter, 1998, as a part of a planned project to remove irradiated compcnents/ material from the spent fuel pool.

IV. The date wht- the facility will be_13 full comoliance.

The facility is currently in full compliance.

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