ML20211G421
| ML20211G421 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/17/1987 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML20211G425 | List: |
| References | |
| NUDOCS 8702250380 | |
| Download: ML20211G421 (4) | |
See also: IR 05000155/1986001
Text
,
P. #lhh
.
FEB 171987
,
Docket No. 50-155
Consumers Power Company
ATTN: Dr. F. W. Buckman
Vice President
Nuclear Operations
212 West Michigan Avenue
Jackson, MI 49201
Gentlemen:
This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) 6
Board Report for the Big Rock Point Plant, our meeting of July 21, 1986, which
discussed in detail the contents of the report, and your written consnents dated
August 22, 1986, relative to the report.
Based on the formal exchange of information between our respective staffs, and
as further reiterated in your letter of response, portions of the SALP Report
have been modified as described in the attached Errata Sheet. Correct pages
are included herein to update your copy of the SALP Board Report. Additionally,
we have reviewed the assigned ratings after revising the report and concluded
that no rating changes are warranted. Our comments and conclusions regarding
your response are discussed below:
Comment No. 1:
Recirculating pump seal
The clarification you provided regarding the potential to distort seals
by rebuilding them ahead of use is a valid rationale. The report has
been revised to eliminate any negative connotation.
Comment No. 2: Maintenance staff training
A re-review of the training conducted for the Maintenance Department
Staff indicated that combined theory / systems training was provided to
2 different groups. One group of 4 Maintenance and I & C Supervisors
participated in a 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> course. We note howeve , that this course
was conducted in October and November of 1983, more than a year prior
to the beginning of this evaluaticn period, and that none of the
participants completed the course due to plant operational requirements.
We acknowledge that the same theory / systems curriculum was to be
presented to I & C technicians in classroom sessions every other week
during the 1985 time period. However, only 12 classes were conducted
during this rating period. A similar course has been designed for
maintenance personnel, but we understand that this course has not yet
been conducted. The SALP report has been appropriately revised to
reflect the correct information you provided.
8702250380 870217
ADOCK 05000155
G
g
r
h
d
-
.
FEB 171987
Consumers Power Company
2
.
As an overview, the Board remains of the opinion that changes in the
composition of the maintenance staff over the rating period has resulted
in a net decrease in the experience level of the staff in terms of both
general nuclear plant technology and systems knowledge specifically
applicable to Big Rock Point. While the general skills training provided
at corporate training centers appear to have a positive impact on specific
craft qualifications among your staff, we believe that training intended to
acquaint your staff, including a large number of newly hired individuals
with no nuclear industry experience, with the theoretical and functional
operation of your facility would contribute to and enforce the continued
safe operation of Big Rock Point. We enceurage your initiative in this
important area.
Comment No. 3:
Limitorque Settings
Our verification review indicates that confusing data and records
available at the time of SALP preparation apparently contributed to
incorrect numbers being published in SALP 6.
Internal memorandum
JRT 86-06 dated March 24, 1986, from the project engineer who was
assigned the task of verification of Limitorque switch settings,
reported to the Plant Review Committee (PRC) Chairman that 9 priority
1 valves and 1 priority 2 valve (10 of the 18 at issue) had been verified
to have correct torque switch settings when reference settings provided by
the vendor were compared to actual observed settings on each valve. The
memorandum stated that "the balance of the units, with a Priority of 2
and 3, are to be scheduled for completion in future outages". We were
advised that 15 of 18 had actually been completed, with the remaining
3 not verified because of their non-operable status. During a review
on September 25, 1986, our inspector and several members of your site
engineering staff and management concurred that both of the above
tabulations were in error. A review of dated maintenance orders, used
to verify torque switch settings of all 18 valves, indicates that all
torque switch settings in question had been physically checked prior
to startup from the 1985 refueling outage. With the exception of 1 valve,
M0-7061, the observed switch settings closely approximate the vendor's
recommended values. Valve M0-7061, we understand, is considered by you to
be fully operable based on its performance history. The SALP report has
been appropriately revised to reflect the correct information.
Comment No. 4:
Forced Retirement
Your comments regarding the use of the term " forced retirement" are
acknowledged and the report has been revised to reflect the correct
information.
Our concern restated was over the Consumer Power Company's
decision to make early retirement available to key personnel
. .
.
_
FEB 171987
Consumers Power Company
3
.
immediately prior to a major refueling outage coupled with the decision
to implement a major reorganization of the remaining staff which included
the creation and assignment of functional departments, increased the
impact of the loss of those personnel who retired early. We believe
this resulted in a number of errors and problems during the outage.
Comment No. 5:
Quality Programs
Comment No. 5A: Reluctance of QA management to respond to concerns of
site QA Superintendent
The Board continues to feel that corporate management was slow to
respond to an increased workload of the on-site QA/QC staff. A
review of Big Rock Point QA monthly resumes from site QA management
to corporate management for the period February-October 1985,
documented that site QA workload concerns were conveyed to corporate
management.
It is noted however that some relief in the form of
additional QA personnel from the Palisades plant was provided in
September 1985. The SALP report has been revised to reflect this
added support.
Comment No. 58: Nuclear Operation Department Standards (N0DS)
We concur with your view that the N0DS reference did not impact the
execution of the specific procedures involved. Our concern in this
area was the deletion of 15 N0DS without first making a determination
that all of the quality requirements contained were adequately
addressed in other documents. Quality Assurance concerns have been
long standing and merit further management attention.
We appreciate your comments regarding conclusions reached based on incomplete
!
information.
The situation was compounded by a lack of conveniently available
i
and complete records documenting all actions taken regarding maintenance
i
training and limitorque settings.
It is our objective to assure that the SALP
process accurately reflects licensee performance. This can be best accomplished
j
by assuring that information provided during the inspection process is complete.
i
Enclosed, as an Appendix to the SALP Board Report, is a summary of our
meeting which includes names of those persons in attendance.
Issuance
of the Appendix serves as the final step in our SALP assessment process.
In accordance with Section 2.790 of the NRC's " Rule of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter with the
referenced attachments will be placed in the NRC's Public Document Room.
1
,_.
,_.__ .__
_ _ , _ .
_
_ _ . _ _ . _ _ _ _ . , . _ _
_ , - _ . . _ _ _
, . . _ .
_.
_ , _ _ -
_..
_
_.__ _ ._
_. _
-
FEB I 71987
Consumers Power Company
4
.
4
No reply to this letter is required; however, should you have questions on the
conclusions reached by NRC, or on the Appendix to the SALP Report, please let
us know and we will be pleased to discuss them with you.
Sincerely,
ff
James
. K ppler
k Regional Administrator
Enclosures:
1.
Appendix to SALP 6 Board
Report No. 50-155/86001
2.
Errata Sheet
3.
Corrected pages to SALP report
4.
Licensee response ltr dtd 08/22/86
cc w/ enclosures:
Mr. Kenneth W. Berry, Director
Nuclear Licensing
D. P. Hoffman, Plant Superintendent
DCS/RSB (RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
Ronald Callen, Michigan
Public Service Commission
Nuclear Facilities and
Environmental Monitoring
Section
J. M. Taylor, Director, IE
H. R. Denton, Director, NRR
Regional Administrators
RI, RII, RIV, RV
L. W. Zech, Chairman ^
J. K. Asselstine, Commissioner
F. M. Bernthal, Commissioner
T. M. Roberts, Commissioner
K. M. Carr, Commissioner
J. A. Zwolinski, NRR Project Director
T. S. Rotella, NRR Project Manager
J. Axelrad, IE
M. Johnson, IE SALP Coordinator
RIII PRR
RIII S'GA
INP0
6
RIII
RI
RIIL
RIII
RII
RIII
RI
d k
/Ims Gul e}t
R~n
,
Nye
w %i
Pa eriello
nd
1p
er
a
J Cormick-Barger
I-D - 97