ML20211F212

Amends Relevant Commitments That Were Made to Commission & Informs That Actions Previously Committed to Will Not Be Completed Due to Permanent Cessation of Plant Operation

ML20211F212
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/22/1997
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9709300378
Download: ML20211F212 (17)

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• A CMS tnerg;Compay B<g Rxk Point Nuclear PL,nt Eeanne R teners 10269 US-31 Nurth Ste Manager Charlevoa. MI 49720 September 22, 1997 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKET 50-155 - LICENSE DPR BIG ROCK PolNT PLANT - CHANGE IN CURRENT COMNITNENTS DUE TO PERNAMENT CESSATION OF PLANT OPERATION The purpose of this letter is to amend relevant commitments that were made to the Commission by Consumers Energy Company. At the time, these commitments presumed that Big Rock Point Plant would be operated until the end of its operating license, May 31, 2000.

Consumers Energy Company notified the Nuclear Regulatory Commission (NRC) by letter dated June 18, 1997, of its intentions to permanently cease operations of the Big Rock Point Nuclear Plant by August 30, 1997. On September 20, 1997, the last fuel bundle was removed from the reactor vessel and placed in the spent fuel pool.

Since Consumers Energy Company has permanently ceased operation of the Big Rock Point Nuclear Power Plant, pursuing the completion of most these commitments is not expected to provide any future safety benefit for a facility that has transitioned from operating into decommissioning. Subsequent to the docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, the 10 CFR Part 50 license no longer authorizes operation of the reactor or retention of fuel in the reactor vessel. Furthermore, the UFHSR, which is a licensing basis document for performing activities under 50.59, Changes, Tests and A Experiments, will be revised to address decommissioning activities. A design basis summary is also being developed for structures, systems, or components k-associated with the storage, control _and maintenance of spent fuel in a safe condition, in a manner sufficient to provide reasonable assurance that such hL structures, systems, or components are capable of fulfilling their intended safety functions. -

Ther: fore, based on the foregoing discussion, Consumers Energy C'mpany will /

not complete the actions previously committed to as described in the attachments o this r. ,[ j K nneth P Powers Site Director and Decommissioning General Manager ((h CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point NRR Project Manager - OWFN hkfhflllllll]g ATTACHMENTS .

9709300378 970922 ADOCK 0500 5

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t ATTACHNENT I CONSUNERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 CONNITNENTS ASSOCIATED WITH " REQUEST FOR INFORNATION PURSUANT TO 10 CFR 50.54(f) REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORNATION.

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.. NTTACHNENT 1 - CONNITNENTS ASSOCIATED WITH ' REQUEST FOR INFORNATION TO 10 CFR 50.54(f) REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASEb INFORNATION.

1. The Quality Assurance Review Matrix (QARM) is used by Big Rock Point personnel with the understanding that required regulatory commitments are reflected in plant administrative procedures. Some minor clarifications

, will be made in administrative procedures as well as incor;, oration of one additional administrative procedure into the QARM, Action taken to date: The entire QARM was reviewed and a number of editorial changes were made. The QARM was revised on April 23, 1997.

2. The Q-List is used in several processes to identify the significance of Structures, Systems, and Components (SSCs) and what procedural requirements apply. Chapter 4 of the Q-List is a component listing that is currently able te be revised with a minimal re/iew process. All other portions of the Q-List require full PRC review with attendant 50.59 reviews as needed. The revision process for Chapter 4 of the Q-List will be revised to strengthen 4

the review process.

4 Action taken to date: This action will be completed.

3. A process which allows the use of Temporary Operating Instructions (TOIs) and Procedure Deviations (PDs) for Operating procedures has allowed these processes to be used on safety-related equipment. Big Rock Point will require the use of a 50.59 review process to determine if safety-related

SSCs are affected for all TOIs and PDs. The procedure revision process will be required when safety-related SSCs are affected.

Action taken to datei This commitment is being evaluated to determine if it is applicable to decommissioning activities. ,

4. Perform an in-depth evaluation for the six most risk-significant systems described in the Updated Final Hazards Summary Report (UFHSR) against plant

procedures for compliance by December 31, 1997. Then the rest of the plant systems would undergo the same evaluation with completion scheduled for December 31, 1998.

Action taken to date: To date, only one system, the Reactor Protection System, has been evaluated. The evaluation concluded that the i operation of the Reactor Protection System, when conducted in conformance with the body of applicable procedures, complies fully with the commitments made by Consumers Energy Company for the operation of the Reactor Protection System. No additional action will be taken. However, it should be noted as stated in the cover letter that a design basis summary is being developed for the Spent Fuel Pool.

5. Enhance the maintenance work planning process by performing a more detailed review of completed work orders. This work process requires that vork on all safety-related Structures, Systems, and Components be planned to the highest /most detailed level of planning unless a Plant Review Committee '

approved procedure is used.

Action taken to date: None. No action will be taken.

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ATTACHNENT 1 - CONNITNENTS ASSGCIATED WITH ' REQUEST FOR INFORN% TION PURSUANT TO 10 CFR 50.54(f) REGARDING ADEQUACY AND AVAILABILITY OF DESIGN BASES INFORMATION.

Q. In the review of the Emergency Condenser System a weakness was identified.

The Emergency Condenser System Surveillance tests, T90-26, " Emergency Valve Operability Test" and _TR-34 " Emergency Condenser Outlet Valve Tests",

include an acceptance criteria for valve timing which is different than the valve timing ststed in the UFHSR. The valves currently meet all criteria; however, a revision will be made to the plant procedures such that they are consistent with the UFHSR.

Action taken to date: None. No action will be taken.

7. In review of the Shutdown Cooling System operation, a weakness was identified with S0P 5, Reactor Shutdown Cooling System and the description provided in the UFHSR. A revision will be made to reflect the correct operation of the Shutdown Cooling System.

Action taken to date: None. No action will be taken.

, 8. The results of the Control Rod Drive investigation showed that an adequate correlation exists between the reouirements imposed by the Plant Technical Specifications and UFHSR; however, several weaknesses were discovered and the appropriate corrective actions are being taken with regards to revising l plant procedures and the UFHSR.

Action taken to date: None. No action will be taken.

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ATTACHNENT 2 CONSUMERS ENERGY COMPANY-2 BIG ROCK POINT PLANT DOCKET 50-155 i

f CONNITNENTS ASSOCIATED WITH GENERIC LETTER 96-01. TESTING OF SAFETY-RELATED LOGIC CIRCUITS J

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. ATTACHMENT 2 - COMMITMENTS ASSOCIATED WITH GENERIC LETTER 96-01. TESTING OF SAFETY-RELATED LOGIC CIRCUITS.

't The NRC documented a significant number of instances involving problems with logic testing of safety-related circuits in information notices which have described events at various pressurized water and boiling water reactors.

Action taken to date:

4 A review of the logic circuitry and associated surveillance procedures for the Rca: tor Protection System, Emergency Diesel Generator, Reactor hepr;ssurization System, and actuation logic for the engineered safety

192tures system has been completed. The review identified that additional testing to meet the generic letter requirements would be required. A method to verify the proper operation of the individual RPS contacts was to be developed and implemented during the 1997 refueling outage. Furthermore, a more detailed l_ review of the Reactor Depressurization System logic was to be developed and u.plemented during the 1997 refueling outage.

Connitment disposition:

Big Rock Point committed to provide a response confirming completion of the actions taken within 30 days of completion to the NRC as requested by the generic letter. The actions committed to have been terminated due to the permanent cessation of plant operation. These commitments were made with the

, understanding that the plant would continue to be operated until the end of j the operating license, May 31, 2000.

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i ATTACHNENT 3 CONSUNERS ENERGY COMPANY

BIG ROCK POINT PLANT DOCKET 50-155 l

CONNITNENT ASSOCIATED WITH GENERIC LETTER 87-02, " VERIFICATION OF SEISNIC t

ADEQUACY FOR NECHANICAL AND ELECTRICAL EQUIPNENT IN OPERATING REACTORS, UNRESOLVED SAFETY ISSUE (USI) A-46 e

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ATTACHMENT 3 - COMMITMENT ASSOCIATED WITH GENERIC LETTER 87-02, ' VERIFICATION OF SEISMIC ADEQUACY FOR MECHANICAL AND ELECTRICAL EQUIPNENT IN OPERATING REACTOR $, UNRESOLVED SAFETY ISSUE (USI) A-46 Qonsumers Energy Company committed to conduct a walkdown of all the safe shutdown equipment listed in the Reference below, Table B-1, to assess its seismic adequacy. This walkdown was to be conducted and documented according to the provision of the GIP 2. The Big Rock staff was to report the results of the completed walkdown to the staff by December 1,1997.

Action taken to date:

l Some preliminary engineering has been performed.

, Commitment dispositioni l

This walkdown will not be performed due to the permanent cessation of plant  !

operation. These commitments were made with the unuerstanding that the plant i would continue to be operated until the end of the operating license, May 31,  !

2000.

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Reference:

Letter to (NRC) from PMDonnelly, " Response to a Request for

Additional Information (RAI) on Severe Accident Management, Generic Letter

. (GL) 87-02, and Generic Letter 88-20, Supplement 4".

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ATTACHNENT 4 CONSUNERS ENERGY CONPANY BIG ROCK POINT PLANT DOCKET 50-155 CONNITNENT ASSOCIATED WITH 120 DAY RESPONSE TO GENERIC LETTER 96-06: ASSURANCE OF EQUIPNENT OPERABILITY AND CONTAINNENT INTEGRITY DURING DESIGN-BASIS ACCIDENT CONDITIONS 1 page

.kTTACHMENT4-COMMITMENTASSOCIATEDWITH120DAYRESPONSETOGENERICLETTER 96-06: ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DES!EM-! ASIS ACCIDENT COM9!TIOMS-Qonsumers Electric Company committed to install a surge chamber on the demineralized water line during the 1997 Refueling Outage to provide overpressurization protection, and ultimately containment integrity, during a main-steam-line break during power operation.

Action taken to date:

Some preliminary engineering has been completed.

Commitment disposition:

The surge chamber installation will no longer be required due to the permanent l cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000.

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ATTACHNENT 5 CONSUNERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 CONNITNENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS) 3 pages

. ATTACHMENT 5 - COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)--

A. LER 96-001, STEAM LEAKAGE FROM REACTOR CLEANUP SYSTEM PIPING DISCOVERED DURING A PLANNED REACTOR SHUTDOWN - Revision 1.

Comitment(s):

1. Perform IGSCC ISI examination on all five weld overlay repairs in the reactor water cleanup system during the 1997 refueling outage.

2. Perform IGSCC ISI examination on at least 50% of the repair welds (non-overlay repairs) in the reactor water cleanup system during the next refueling outage (1997). Examine the remaining repair welds (non-overlay repairs) during the subsequent refueling outage (1998).

3. Perform an expanded scope IGSCC ISI examination on the order of 15 to 30%

in the reactor water cleanup system during next refueling outage (1997).

The ISI engineer will determine the inspection scope.

Commitment disposition:

These examinations will not be performed due to the permanent cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000.

B. LER 96-003; REACTOR DEPRESSURIZATION SYSTEM "B" TRAIN F00ND IN0PERABLE DURING REFUELING OUTAGE SURVEILLANCE TESTING - REVISION 1 Commitment:

Replace slenes in-all 86R style pilot valves as they become available for rebuild.

Commitment disposition:

The sleeves for pilot valves 86R-1 and 86R-5 have been changed. Pilot valve 86R-4 had significant internal damage that it will no longer be used. Valve s/n 86R-6 is still installed in the RDS System. Further sleeve rep'acements will-not be performed due to the permanent cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000.

C. LER 96-007; Interpretation of Technical Specification Heatup/Cooldown Limits for Reactor Scrams.

(qmmitment:

1. Improve feedwater regulation valve performance at low flow conditions during the 1997 Refueling Outage.

NOTE: Improvements in the feedwater regulation valve performance were made due to valve maintenance conducted during the 1996 refueling outage. Design changes are required for further improvement.

. ATTACHMENT 5 - COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)

Comitment disposition:

The project to improve feedwater regulation valve performance at low flow conditions will not be performed due to the permanent cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000.

D. LER 97-001; Test Not Performed in Accordance With Appendix J to 10 CFR Part 50.

Commitment:

Station procedure TV-02, Containment Integrated Leak Rate Test (ILRT), will be revised to provide direction with respect to the outboard blind flange on containment penetration H-80.

Commitment disposition:

These procedure changes will not be made due to the permanent cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000.

E. LER 97-003; Deminerali:.ed Water Piping Susceptible to Overpressurization During a Design-Basis Accident Commitment:

Consumers Electric Company committed to install a surge chamber on the demineralized water line during the 1997 Refueling Outage to provide overpressurization protection, and ultimately containment integrity, during a main-steam-line-break during power operatLon.

Action taken to date:

Some preliminary engineering has been completed.

• Commitment disposition:

The surge chamber installation will not be performed due to the permanent cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000.

F. LER 97-004; Potential Loss of DC Power for the Primary Containment Spray and Liquid Poison Systems.

Commitment (s):

1. Breakers 72-11 through 72-44 which are associated with the DC Distribution Panel (D02) Feeder will be tested by the end of the 1997 Refueling Outage.

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.' ATTACHMENT 5 - COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)

2. Evaluate and document that all safety-related AC and DC breakers installed in the plant are within the plant design by the end of the 1997 Refueling

, - o! stage.

Commitment disposition:

These actions will not be completed due to the permanent cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operating license, May 31, 2000, d

ATTACHMENT 6 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 COMMITMENTS ASSOCIATED WITH REPLY'S TO NOTICES OF VIOLATION-

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.' ATTACHMENT 6 - COMMITNENTS ASSOCIATED WITH REPLY'S TO NOTICES OF VIOLATIO A. VIOLATION 96008 During an NRC inspection conducted from September 7, 1996, through October 18, 1996, an example of a violation of NRC requirements was identified. In accnrdance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the example is listed below:

i Technical Specification (TS) 6.8.1 requires that written procedures be established, imp 1 m nted, and maintained for all structures, systems,

, components, and s Jety actions defined in the Big Rock Point Quality List.

These procedures shall meet or exceed the requirements of ANSI N18.7, as endorsed by CPC-2A, " Quality Program Description for Operational Nuclear

Power Plants." CPC-2A, Section 5.2 states, in part, that administrative i

procedures are used to control activities affecting the quality of safety related structures, systems, and components.

Administrative Procedure (AP) 3.2.1.1, " Performance of Maintenance,"

Revision 15 of May 6, 1996, Section 5.1, defines the following terms:

1) " DECLARED OPERABLE - A system or component is declared OPERABLE if it is capable of fulfilling its design function and is documented as

' such."

2) " POST MAINTENANCE TESTING - Testing performed following maintenance to verify that the equipment or system performs its intended function, that the original deficiency has been corrected, and that no new deficiency has baen created."

3) " WORK REQUEST / WORK ORDER (WR/WO) - The WR/WO is the fundamental document for requesting and controlling maintenance services or maintenance work on plant equipment. The I!9/WO serves as a permanent record for work involving power plant installed equipment."

WO-RDS-12612016, remove, inspect, and replace SV-4985; Job Plan Step 5, j states, " Perform Post-Maintenance Testing.

i Contrary to the above, on September 7, 1996, solenoid-pilot valve (SV-4985) was declared operable and reactor depressurization system train "B" was returned to service following maintenance activities without performing sufficient post-maintsnance and operability testing to detect a maintenance induced ground on SV-4985.

- As a result of this violation, Consumers Energy Company committed to inspect the lug configuration for the system condulet boxes and repair / replace as necessary. This action was scheduled to be completed during the 1997 Refueling Outage. However, this action will not be completed due to the permanent

, cessation of plant operation. These commitments were made with the understanding that the plant would continue to be operated until the end of the operath.g license, May 31, 2000.

B. Violation 96012-A.1 On January 2,1997, surveillance procedure TV-02, " Containment Integrated Leak Rate Test," Rev 28., an activity affecting quality, was inappropriate to the circumstances in that performance of. the procedure resulted in an 1 controlled leak of about 400 gallons of reactor coolant through the open CRD accumulator water-side-drain valves.

As a result of this violation, Consumers Energy Company committed to Revise TV-02, " Containment Integrated Leak Rate Test," and enhtnce as follows:

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• ATTACHMENT 6 - COMMITMENTS ASSOCIATED WITH REPLY'S TO NOTICES OF VIOLATION

. Ensure compliance with Administrative Procedure 1.1.1, (with emphasis on Section 5.6.11, Level of Instructional Detail).

. Identify Precautions and Limitations applicable to each major section (ie, Operations Test Preparations, Maintenance Test-Preparations, I&C Test Preparations, etc) such that revisions of the procedure can more easily identify statements applicable to their tasks.

. Identify sections of TV-02 requiring coverage in a pre-job--

briefing prior to allowing preliminary work assignments, on and for each department affected, add a sign-off.for the completion of this briefing.

• Utilize a process which incorporates procedure step review by a qualified operator (AO, RO) to determine adequacy of the steps to be performed based on complexity of the task and skill of the operator.

This action was scheduled to be completed March 31, 1998, which was prior to

, the next ILRT. However, this action will not be completed due to the permanent cessation of plant operation. These commitments were made with the

understanding that the plant would continue to be operatr.d until the end of the operating licer.se, May 31, 2000.

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