ML20210J038
| 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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K. P. Powers, Plant General Manager
Big Rock Point Nuclear Plant
Consumers Energy Company
10209 US 31 North
Charlevoix, MI 49720
SUDJECT:
.
(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 with tw
This re review is identical to the review performed for
. This
.
reason, the two violations are being treated es contested violations. For the othe
,
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, and has concluded that the violations occurred, as cited, for the
below.
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 postulate
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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9708140312 970805
ADOCK 05000155
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K. P Powers
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in your response to the hrst violation, you character red the evaluation of the 120*F in
containmeru temperatuto during a postulated accident a
a
ar0ument because the change in plant opeta6cn O.e.. containment temperatutes highe
is
than 100*F and resultant calculated post accident temperatures higher than previ
exist at the facility. Upon identification of the nonconfor
ously
,
CFR 50, Appendix B, Critorion XVI, "Correctivo Action," to disposition the
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nonconformance. Your stafI porformed an analysis to determino the impact of higher
initial containment tbmporatures and determined that you woro in non coriformance
,
could have returned plant operation to its design basis (i.e., e
with
containment temperature at not greator than 100'F), or you could have changed you
,
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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 temperatures and pres
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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
with operation of the facility, but failed to include the results of these calculations
next SAR update.
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 as 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 line of the violation
.
discussed above, the time-dopendent containment temperatures had boon prepare
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in the next SAR updato as required by 10 CFR 50.71(c). W
that our error may have caused.
- _ .
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. _ _ _ _ _ _ _ -
_-__-_-_ _ _
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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 you have any further questions, please do not hositato to contact Mr. Bruce
[
Burgess at (630) 829 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
' PUBLIC IE-01
A. B. Beach
Deputy RA
Rlli PRR
Rill Enf. Coordinator
Document: G:\\BIGR\\Nov.RES
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"E" = Copy with attach /enci "N" = No copy
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