ML20211G421

Forwards Errata to SALP 6 Board Rept 50-155/86-01 for Nov 1984 - Mar 1986,including Corrected Pages,Per 860721 Meeting & Comments in .Rept Revised to Eliminate Any Negative Connotation Re Recirculating Pump Seals

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: IR 05000155/1986001 ML20211G421 ML20211G516
References
NUDOCS 8702250380
Download: ML20211G421 (4)

See also: IR 05000155/1986001

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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.

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FEB 171987

Consumers Power Company 2

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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

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Consumers Power Company 3 FEB 171987

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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

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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.

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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.

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Consumers Power Company 4

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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

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