ML20211G516

Comments on SALP 6 Board Rept 50-155/86-01.Evaluation Is Realistic & Correct Assessment of Facility Performance.Areas Where Conclusions May Have Been Reached Based on Incomplete Info Discussed

ML20211G516
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/22/1986
From:	Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20211G425	List: IR 05000155/1986001 ML20211G421 ML20211G516
References
NUDOCS 8702250413
Download: ML20211G516 (3)

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Vice President l Nuclear Operations General othces: 1945 West Parnali Road. Jackson, MI 49201 . (517) 788-1217 August 22, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

SALP 6 BOARD REPORT COMMENTS Following review of the Big Rock Point SALP 6 Board Report and the NRC's presentation of their views of the results,. Consumers Power Company acknowledges that performance improvements can be made to reduce the occurrence of problems like those discussed in the report. As was true in the case of the Level III violation received during the 1985 Refueling Outage, these types of concerns are normally internally identified and corrective actions promptly initiated. Corrective actions taken with respect to the violation involving the Field Maintenance Service crew resultsd in good performance by this group during two forced outages following the initial occurrence. Although Consumers Power Company would have preferred that consideration be given to include these successful demonstrations of our corrective actions in this SALP Report, we generally agree with the 1

conclusions of this SALP Report and find that the evaluation is a realistic and correct assessment of Big Rock Point performance. We continue to stress

our commitment to being an outstanding performer.

With respect to this report, we have identified a few instances where conclusions may have been reached on the basis of incomplete information. To prevent the potential of the next SALP Board concluding something as a repeat concern based on misinformation, we are bringing these items to your attention.

The " Maintenance / Modifications" section states that " licensee did not overhaul the spare recirculation pump seal in advance of the outage and was still rebuilding the seal as the plant was being shutdown to perform the replacement, even though the punnp had been idle for two weeks prior to shutdown". The reason this was not done is because the manufacturer D702250413 870217 PDR ADOCK 05000155 G PDR OC0886-0134-NLO4 AUG 25 W

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! J G Keppler, Administrator 2

, Big Rock Point Plant SALP 6 Report Comments August 22, 1986 recommends that seals not be rebuilt ahead of use as they tend to distort during storage which can lead to increased failures. (SALP Report page 11)

The " Maintenance / Modifications" section states that "although the licensee has long recognized the need for maintenance staff training, no training was provided until February 1986, when a regular program of skills training offsite was initiated. The skills training is general in nature and is not nuclear plant specific. No nuclear plant system or concepts training is provided." A special course in plant systems including reactor theory was provided to maintenance and I&C sunervisory personnel within the last two years and has been provided to half of the I&C technicians since then. Skills training has been provided to plant maintenance personnel at the Consumers Power Company Skills Training Centers for over five years. (SALP Report page 12)

The " Maintenance / Modifications" section states that "the licensee made a commitment to verify, prior to startup from the 1985 outage, Limitorque Switch settings on 18 Limitorque Valves ... (and) as of this date only 15 have been checked". Our records document that all 18 were completed prior to startup following the 1985 outage. (SALP Report page 13)

The " Outages" section states that " forced retirement of several older key members of the licensee staff ... contributed to the breakdown in the management process". The retirements were not forced retirements. With the Consumers Power Company reorganization following the termination of Midland Plant construction, an incentive retirement program was implemented to reduce overall personnel numbers. The individuals at Big Rock Point, initially not offered the program because of the importance of their contribution, demanded that they be given the option since they were eligible. Management chose to honor their requests. (SALP Report page 22)

The " Quality Programs" section states that " Licensee corporate management detracted from the effectiveness of programs and administrative controls affecting quality."

1. Example "a" states that " reluctance of corporate management to respond to the concerns of the Site QA Superintendent ... detracted from the effectiveness of Programs and Administrative controls affect $r.g quality". Management reassigned certain duties to free key people at the site, and hired contract QC personnel to help supplement the available hours to do site QA work. The Company chose not to hire additional permanent staff for a temporary workload increase. (SALP Report page 25)

2. Example "b" states that "two examples of cancelled NODS were referenced in other procedures". Each reference to the cancelled NODS was used to identify the source of a requirement which was implemented by that procedure. Neither reference directed the procedure user to OC0886-0134-NLO4

J G Keppler, Administrator 3 Big Rock Point Plant SALP 6 Report Comments August 22, 1986 s

refer to the NODS for direction or input. The NODS reference, therefore, did not impact the execution of the procedure. All Administrative Procedures at Big Rock were reviewed and none were found that referred the user to a deleted NOD Standard for direction or input. (SALP Report page 25)

In conclusion, we acknowledge the areas of concern identified by the NRC that need improvement at Big Rock Point and will pursue resolution of them. We continue to look forward to working with the NRC to resolve future concerns which will keep Big Rock Point a safe, reliable and efficient operating plant throughout the remainder of its operating lifetime.

Frederick W Buckman Vice President Noclear Operations CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Big Rock Point OC0886-0134-NLO4

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