ML20210J038

Ack Receipt of in Response to Transmitting NOV Re Insp Rept 50-155/97-02

ML20210J038
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/05/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
50-155-97-02, 50-155-97-2, NUDOCS 9708140312
Download: ML20210J038 (3)

See also: IR 05000155/1997002

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August b. 1%/

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K. P. Powers, Plant General Manager

Big Rock Point Nuclear Plant

Consumers Energy Company

10209 US 31 North

Charlevoix, MI 49720

SUDJECT: .

NOTICE OF VIOLATION

(NRC INSPECTION REPORT NO. 50155/97002(DRPI)

Dear Mr. Powers:

This will acknowledge recoint of your Juno 5,1997, letter in responso to ou

1997,latter transmitting a Notico of Violation (Notico) associated .

with the s

-.

inspection report. The report identified four violations. In your responso, yo

the NRC to considor additionalinformation in connection . This with tw

This re review is identical to the review performed for ,

.

reason, the two violations are being treated es contested violations. For the other

violations, we have reviewed your correctivo actions and have no further q

timo. The correctivo octions will be examined durin9 futuro inspections .

The NRC has reviewed tho additionalinformation you provided regarding the tw

violations,

below. and has concluded that the violations occurred, as cited, for the

The first violation dealt with the failure to perform

Report (SAR). The inspection Report (IR) stated that in 1985 the Big Rock Point ,

identified that the alarm for high containment temperature was set at 120*F,

calculations used to datormine temperatures in containment following a postulated

accident were based on a maximum initial containment temperature of 100*F. T

and datorminod that post accident temperaturoc wou

anticipated. The IR further documented that you performed a review of installed

equipment to ensure that operability would not be affected by the now, higher, p

accident temperatures, but your staff did not document the basis for determinin

unroviewod safety question (USO) did not exist. Additionally, the issue of post ac

containment temperatures was reviewod by your staff in October, November, and

December 1996, yet your staff again did not recognize the nood to perform a 10 C

50.59 safety evaluation for the higher post-accident containment temperatures wh

tesulted from operating the plant with containment temperatures of up to 120*F .

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K. P Powers

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in your response to the hrst violation, you character red the evaluation a

of the 120*F in

containmeru temperatuto during a postulated accident a is

ar0ument because the change in plant opeta6cn O.e.. containment temperatutes higher

than 100*F and resultant calculated post accident temperatures ously higher than previ

exist at the facility. Upon identification of the nonconfor

,

I CFR 50, Appendix B, Critorion XVI, "Correctivo Action," to disposition the

,

nonconformance. Your stafI porformed an analysis to determino the impact of higher

initial containment tbmporatures and determined that you woro with

in non coriformance

,

!

could have returned plant operation to its design basis (i.e., e

containment temperature at not greator than 100'F), or you could have changed l

'

you

program limits and completed a safety evaluation under 10 CFR 50.50. You did not ret

' plant operation to its design basis. You did, in part, chango your EEO program

verifying that affected equipment could withstand the now peak temperatures, bu

f ailed to perform the required 10 CFR 50.69 safety evaluation. ,

The second violation dealt with the failure to update the SAR in 1989, as require

CFR 50.71(e), to reflect the reanalyrod post accident temperatures in containment

noted that 10 CFR 50.49(e)(1) requires that time-dependent. The(R temperatures and press

be established for the most severo design basis accident. As described above,

perIormed new EEQ calculations in 1985 when it was identified that the original EEO

calculations prepared pursuant to 10 CFR 50.49(e)(1) contained a non-conservative

assumption (initial containment temperature of less than 120*F) which was inconsiste

withSAR

next operation

update. of the facility, but failed to include the results of these calculations

The failuro to update the SAR meant that subsequent equipment

and that maintenance activities did not take the correcte

required by your EEO program.

,

n

required of Big Rock Point, and again assert that the revis

dispositioned the potential 20'F difference between initial accident conditions in

containment and those assumed during earlier studies, was only a " sensitivity a

.

The Notice cites the 1989 SAR update, and so your let

the " sensitivity analysis" MJ in fact a calculation required by 10 CFR 50 49(e)(1)

.

and

10 CFRas50.71(e).

such was required to be reflected in the 1989 SAR update in accordance with

,

In preparing this letter, the NRC noted an error in the Notico for the second violation

Specifically, the word "not" was inadvertently inserted in the last .

. As line of the violation

discussed above, the time-dopendent containment temperatures had boon prepare

in the

that our errornext

may haveSAR

caused. updato as required by 10 CFR 50.71(c). W

- _ . =

. _ _ _ _ _ _ _ - _-__-_-_ _ _

.i

'i

K. P. Powers

3-

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'

Because your June 5,1997 lotter primarily discussed your reasons for contostin0 the

violations, wo r,oquest you respond to this lotter end follow the instructions previously

specified in the Notice when preparing your responso.

,

in accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter

will be placed in the NRC Public Document Room.

[

Should at

Burgess you have

(630) 829any further questions, please do not hositato to contact Mr. Bruce

9029.

.

.

Sincerely,

/s/ A. Bill Beach '

4

A. Elli Beach

Regl>nal Administrator

Docket No. 50155

cc: Robert A. Fenech, Senior Vice

President, Nuclear, Fossil

and Hydro Operations

James R. Padgett, Michigan

Public Service Commission

Michigan Department of

,

Environmental Quality

Department of Attorney General (MI)

Docket Hle OC/LFDCB

BRP PM, NRR

DRP

SRI BRP, Palisades

' PUBLIC IE-01

A. B. Beach Deputy RA

Rlli PRR

DRS

Rill Enf. Coordinator

Document: G:\BIGR\Nov.RES

To

"E" =reconve Copy witha attach

copy /enci

of this document, indicate in the box "C" = Copy without attachtenci

"N" = No copy

OFFICE Rill

_ f Rill' / Ritt / id t,

NAME Burgess:dpkp[ Clayton [L

Grant @/7 _8pdh

DATE 07/jl/97

~ 07B//97 [T6/9[ 01/ $/97

OFFICIAL RECORD COPY