ML20217G494
| ML20217G494 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/23/1998 |
| From: | Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9804290146 | |
| Download: ML20217G494 (39) | |
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^ *0A***Y Big Rock Pmnt Naclear Plant M !. Peeners
' 10269 L&31 Nortn Site General Manager Charlevcu, MI 49720 April 23, 1998 Nuclear Regulatory Commission Document Control Desk Washington DC 20555-0001 l
DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - CHANGE IN CURRENT COMMITMENTS DUE TO PERMANENT CESSATION OF PLANT OPERATION i l
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 Hock Point Plant would be operated until the end of its j 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 i 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 l Rock Point Nuclear Power Plant, pursuing the completion of these commitments l will not 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 Updated Final Hazards Summary Report (UFHSR). which is a licensing basis document for performing activities under 10 CFR 50.59.
" Changes. Tests and Experiments." was revised February 12. 1998, to address gg' decommissioning activities.
9904290146 980423 ~
PDR ADOCK 05000155 hk W PDR, j
l Nuclear Regulatory Commission 2 Big Rock Point Plant Change In Current Commitments Due To Permanent Cessation of Plant Operation April 23, 1998 Therefore based on the foregoing discussion. Consumers Energy Company will not maintain the actions previously committed to as described in the attachments to this letter, and these commitments will not be retained.
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Kenneth P. Powers Site General Manager CC: Administrator. Region III. USNRC NRC Resident Inspector - Big Rock Point NRR Project Manager - OWFN ATTACHMENTS i
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' ATTACHMENT 1 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT 00CKET.50 155 COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS f
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. Page 1 of 10 l ATTACHMENT 1 COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS 4 h.NRCInspectionReport87-022. November 25. 1987 Commitment:
l l In a letter to the NRC dated May 16, 1989. pertaining to activities responsive to concerns identified in IR 87-022. Consumers Energy Company committed to revise eighteen maintenance procedures. The revisions were to require recording of motor operated valve (MOVs) and control valve (CVs) stroke times and routing of this information through the ISI Coordinator.
All procedure revisions were to be completed and approved prior to use during the 1989 Refueling Outage.
Action taken to date:
The maintenance procedures were appropriately revised prior to use during the 1989 Refueling Outage.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant ]
operation, motor operators for MOVs and CVs will no longer be required.
since they are not important to the safe storage of spent fuel.
i Consequently, the recording of MOVs and CVs stroke times and routing of this information through the ISI Coordinator will no longer be applicable.
Therefore, the MOV/CV maintenance procedures will either be deleted (for obsolete valves) or revised (for operational valves which may be hand l
operated) to reflect that the valves will no longer be motor operated.
Based upon the above information, the associated commitment will no longer be retained.
B. NRC Inspection Report 89-015. dated September 19. 1989 i
Commitment:
In a letter to the NRC dated November 1. 1989, pertaining to activities 4 i responsive to concerns identified in IR 89-015. Consumers Energy Company )
l committed to make revisions to the Containment Integrated Leak Rate Test (CILRT) procedure to accommodate water level and pressurized container !
corrections prior to the next performance of the ILRT.
Action taken to date: l The CILRT procedure was appropriately revised November 8,1991.
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. Page 2 of 10 i ATTACHMENT 1 COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS Commitment Discosition:
It has been determined that, due to the permanent cessation of plant operation. the CILRT will no longer be required. since it is not important to the safe storage of spent fuel. Therefore, since this procedure is no longer required it will be deleted. Based upon the above information, the associated commitment will no longer be retained.
C. NRC Inspection Report 90-08 dated May 24. 1990 Commitment:
In a letter to the NRC dated May 23 1991. pertaining to activities responsive to concerns identified in IR 90-008. Consumers Energy Company committed to move the Emergency Operat Ag Procedure (EOP) procedural step directing the operator to implement the alternate boron injection procedure, with completion scheduled for October, 1991.
Action taken to date:
The E0P was appropriately revised and issued on October 31, 1991.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, this E0P will no longer be required since it is not important to the safe storage of spent fuel. Therefore, since this procedure is no longer required, it will be deleted. Based upon the above information, the associated commitment will no longer be retained.
D. NRC Inspection Report.91-005. dated May 24. 1991 Commitment:
In a letter to the NRC dated July 9. 1991 in response to Notice of
, Violation 91005-01C. Consumers Energy Company committed to revise Standard Operating Procedure (SOP) 30, " Control Rod Drive System.~ to: 1) clarify conditions under which the Plant Manager must be notified before l troubleshooting a CRD. 2) clarify the level of corrective action required for various CRD problems and 3) to tie the notification requirement and the troubleshooting procedure together. This was scheduled for completion by August 1. 1991.
Action taken to date:
SOP-30 was appropriately revised and issued August 1.1991.
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. Page 3 of 10 ATTACHMENT 1 - COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation. this 50P will no longer be required since the CRD system is obsolete and is not important to the safe storage of spent fuel.
Therefore, since this procedure is no longer required it will be deleted. i Based upon the above information, the associated commitment will no longer be retained. j E. NRC Inspection Report 92-10. dated June 5, 1992 Commitment 1:
In a letter dated December 13. 1993. Consumers Energy Company informed the NRC that, in response to NRC recommendations in IR 92-010 pertaining to the !
l operation of the Main Steam Isolation Valve (MSIV) M0-7050, and as a follow l
- up to a commitment made to the NRC in a letter dated September 21. 1993.
j the following statement was added to the Precautions and Limitations section of SOP-10:
l "The MSIV operator thrust output at torque switch trip is sufficient to l close the valve under design basis conditions. However, any attempts to l
close the valve at differential pressures greater that 500 lbs. may not be within the capability of the MOV. If the MOV fails to close, it may be due to premature tripping of the torque switch. It may be necessary to give a l momentary open signal to reset the torque switch; then resignal the valve j in the closed direction."
l During a telecon with the NRC on March 24. 1994, as documented in an NRC letter dated July 12. 1994 Consumers Energy Company stated that it would revise this Precautions and Limitations statement to specify that the momentary open signal must be " pull-to-stop." Consumers Energy also committed to verify the locking gear train in the actuator from the overall gear ratio and diagnostic trace analysis.
Action taken to date:
SOP-10 was appropriately revised and issued September 14. 1994.
Verification results were verbally communicated to the Staff.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, this statement in SOP-10 will no longer be required. since the Main Steam system is obsolete and is not important to the safe storage of spent fuel. Therefore, since this statement in the procedure is no longer
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' . Page 4 of 10 ATTACHMENT 1 COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS required, it will be deleted. Based upon the above information, the associated commitment will no longer be retained.
1 Commitment 2:
l l In the letter to the NRC discussed above, dated September 21, 1993.
l Consumers Energy Company informed the Staff that, in response to NRC i recommendations in IR 92-010 pertaining to the operation of the Main Steam Isolation Valve (MSIV) M0-7050, a revision would be made to SOP-6.
~ Emergency Condenser System.~ cautioning that "should the torque switch prematurely trip, the MOVs may need to be resignaled by the operator to close."
l Action taken to date:
i SOP-6 was appropriately revised and issued by November 15, 1993. I Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant l operation, this statement in SOP-6 will no longer be required, since the Emergency Condenser system is obsolete and is not important to the safe l storage of spent fuel. Therefore, since this statement in the procedure is
! no longer required. it will be deleted. Based upon the above information, the associated commitment will no longer be retained. l F. NRC Inspection Report 92-013. dated July 17. 1992.
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Commitment:
4 NRC IR 92-013. Open Item 155/92013-04. was initiated to track Staff E0P Verification and Validation (V&V) concerns. In a letter to NRC dated February 22. 1994. Consumers Energy submitted a copy of the Validation and l Verification Guidelines (Administrative Procedure 1.1.3. "EOP Verification ;
and Validation").
! NRC IR 94-011. dated September 23, 1994 Inspector Follow-up Item (IFI) 155/92013-04 identified that the revised Administrative Procedure 1.1.3 met the intent of the six objectives of V&V listed in Section 3.3.5.1 of NUREG-0899, and resolved the deficiencies in walkdowns. validation of support procedures, selection of review staff, and involvement with human factors.
However, the IFI stated that the procedure did not give objective criteria to determine the type of validation required rather it had the E0P procedure sponsor determine if V&V would be performed. Also, the IFI stated that the procedure did not require V&V for typographical errors.
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changes which did not alter the intents. clarifications and incorporation i of previous V&V comments. i NRC IR 94-018. dated February 15. 1995, closed IFI 155/92013-04 but stated that remaining issues left to be completed that relate to E0P V&V would be l followed up as part of IFI 155/94011-03 l
NRC IR 96-003. dated May 24. 1996, closed IFI 155/94-011-03 in response to the latest revision of Administrative Procedure 1.1.3 which requires full V&V for all E0P revisions.
l Action taken to date:
l Administrative Procedure 1.1.3 was appropriately revised as discussed above to address the NRC's concerns.
Commitment Disoosition:
l It has been determined that, due to the permanent cessation of plant operation, the E0P Verification and Validation procedure will no longer be required, and will therefore be deleted. Based upon the above information, the associated commitment will no longer be retained.
G. NRC Inspection Report 92-019. dated October 30. 1992 l
Commitment:
In a letter to the NRC dated December 23. 1992, in a follow-up response to NRC Open Item 155/92019-01. Consumers Energy Company committed to perform a formal load flow calculation to demonstrate that the 46 kV line could l maintain adequate voltage levels during a design basis accident (DBA) with the 2.4 kV voltage regulator out of servic3. This effort was scheduled for completion by May 1. 1993. Consumers Energy Company also committed to l
update operating procedures to advise operators that this mode of operation was acceptable within 60 days following completion of the analysis.
Action taken to date:
As documented in NRC IR 93-020. dated November 10. 1993, a BRP engineering analysis was completed to address this open item. The inspectors verified that the calculation adequately modeled the 46 kV system with the 2.4 kV i sys;am in bypass and closed this item. The applicable Standard Operating Procedure (50P-14) was appropriately revised and issued June 18. 1993.
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- Page 6 of 10 ATTACHMENT 1 - COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, the impacted section of SOP-14 will no longer be required since the DBA for which this mode of operation was required is no longer applicable and is not relevant to the safe storage of spent fuel.
Therefore, since this section of the procedure is no longer required, it will be deleted. Based upon the above information, the associated commitment will no longer be retained.
H. NRC Inspection Report 93-015. dated November 9. 1993 <
Commitment 1:
In a letter to the NRC dated December 8, 1993, in response to Notice of V1olation 93015-A.1. Consumers Energy Company committed to revise TR-39I.
"Feedwater Check Valve Leak Rate Test." Attachment 1. " Test Setup." The drawing needed to be updated to include the symbol for the containment i boundary. Consumers Energy Company also committed to review all applicable drawings used in procedures to assure that containment boundaries are included where appropriate.
Action taken to date:
Procedure TR-391 was updated and issued April 19, 1994 to include the symbol for containment boundary. Applicable drawings used in procedures were reviewed to assure that containment boundaries were included.
Required revisions were identified and made to procedures TR-39B. 39H. 39M and 390. April 4. 1994.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, local leak rate test procedures will no longer be required, since the systems are obsolete and are not important to the safe storage of spent fuel. Therefore, since these procedures are no longer required, they will be deleted. Based upon the above information, the associated commitment will no longer be retained.
Commitment 2:
In a letter to the NRC dated December 8, 1993, in response to Notice of Violation 93015-A.2. Consumers Energy Company committed to revise TV-10.
" Pressure Test of the Nuclear Steam Supply System." Revisions were to I
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Page 7 of 10 ATTACHMENT 1 COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS include the following requirements: 1) positioning of the operator at the hydro pump at all times with communications available at the Control Room:
- 2) communication of leakage corrections between the Control Room and hydro pump operators: 3) addressing the use of a formal meeting to discuss the procedure before use and 4) investigation if leakage inspections can be made earlier in the test to facilitate the procedure.
Action taken to date:
Procedure TV-10 was appropriately revised February 23. 1994.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation procedure TV-10 will no longer be required, since the Nuclear i Steam Supply system is obsolete and is not important to the safe storage of I l spent fuel. Therefore, since this procedure is no longer required, it will be deleted. Based upon the above information. the associated commitment will no longer be retained.
l I. NRC Inspection Report 93-019. dated November 9. 1993 Commitment:
l In a letter to the NRC dated January 17. 1994, in response to Notice of l Violation 93019-01. Consumers Energy Company committed to revise MGP-39 to verify that the "as-left" data is from the last VOTES test performed.
Consumers Energy also committed to revise procedure MGP-39. " Motor Operated
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l Valves Post Maintenance / Acceptance Testing." minimum closing thrust value j for M0-7053 to its required value as determined by Engineering Analysis EA-
! AIR-A-NL-89-41-0. " Thrust and Torque Calculation for M0-7053." i Action taken to date:
MGP-39 was revised February 28. 1994, to require verification that the "as- j left" data is from the last VOTES test performed. In a letter to NRC dated i f June 15. 1994 Consumers Energy Company identified that the EA revision was not required and therefore, revision of minimum closing thrust value for i MO-7053 in MGP-39 was also not required.
Commitment Disoosition:
Since. as discussed above, it was determined that a revision of minimum closing thrust value for MO-7053 in MGP-39 was not required, this I commitment was canceled. l
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- d. NRC Inspection Report 94-010 dated August 16, 1994 i Commitment:
NRC Inspection Follow-up Item IFI 155/94010-02 identified several weaknesses in the receipt and storage of new fuel. Consumers Energy .
responded to these NRC concerns, in part. by indicating that procedures )
would be revised to ensure better inspection of fuel storage locations prior to receipt of the next fuel shipment.
Action taken to date:
Procedure MFHS-8. " Nuclear New Fuel Shipment Procedure." was appropriately revised (Revision 2).
Commitment Disoosition:
l It has been determined that, due to the permanent cessation of plant operation. MFHS-8 will no longer be required since new fuel receipt and storage will no longer be performed Therefore, since this procedure is no longer required, it will be deleted. Based upon the above information, the associated commitment will no longer be retained.
K. NRC Inspection Report 94-018 dated February 15. 1995 l Commitment.
4 NRC IR 94-018. IFI 155/94018-02 identified Staff concerns with long standing problems involving Accumulator Charging Header Control Valve CV- ,
i NCI8. which operators had to operate in manual vs automatic, a condition !
not in accordance with plant design. In addition. this IFI identified !
concerns with the non-running Control Rod Drive (CRD) pump control switch !
, being placed in 'Off" vs " Standby" such that the pump would not start automatically on a reactor scram signal. i Action taken to date:
Procedures Off Normal DNP-2.31. " Reactor Scrams" and Alarm ALP-1.3-32 " Rod Drive Hi Temp." were appropriately revised to address the NRC's concerns.
ONP-2.31. Revision 112. has a step 1.2.g to verify that a second CRD Pump starts, if in " Standby." ALP-1.3-32. Revision 156. has a step 3.a to verify running or start a second CRD pump, if available. NRC closed IFI 155/94018-02 in IR 97-010. dated November 26, 1997.
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l ATTACHMENT 1 - COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS l Commitment Disoosition:
l It has been determined that, due to the permanent cessation of plant operation, procedures ONP-2.31 and ALP-1.3-32 will no longer be required.
- since the CRD system is obsolete and is not important to the safe storage l of spent fuel. Therefore, since these procedures are no longer required, they will be deleted. Based upon the above information, the associated commitment will no longer be retained.
! L. NRC Inspection Report 95-006, dated May 24. 1995 Commitment:
In a letter to the NRC dated June 22, 1995, in response to Notice of Violation 95006-I. which identified NRC concerns pertaining to the inoperability of fire system dual-basket strainer BS-5761. Consumers Energy Company committed. in part, to revise Standard Operating Procedure 50P-8.
" Post Incident System." SOP-11. " Radioactive Waste System - Liquid." arid SOP-26. Fire Protection System." to address the proper operation of the duplex basket strainers.
l Action taken to date:
Each of the three procedures was appropriately revised by October 1. 1995.
to address proper operation of the duplex strainers - SOP-8. Revision 144:
SOP-11. Revision 128: and SOP-26. Revision 99.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedure SOP-8 will no longer be required, since the Post l Incident System is obsolete and is not important to the safe storage of spent fuel. Therefore. SOP-8 will be deleted. Although, the proper operation of the duplex strainers is still addressed in SOP-11 and SOP-26.
the inoperability of the strainers is no longer a nuclear safety concern.
Based upon the above information, the associated commitment will no longer be retained.
M. NRC Inspection Report 95-012. dated January 9. 1996 l
Commitment: i NRC IR 95-012. identified that the failure to incorporate a Temporary
, Charige (TC) into procedure EIP 2. Appendix 2. " Alternate Boron Injection."
Revision 3. constituted a violation of minor significance and that it was l
i Page 10 of 10 l ATTACHMENT 1 - COMMITMENTS ASSOCIATED WITH NRC INSPECTION REPORTS 1 .
l being treated as a Non-Cited Violation, consistent with Section IV of the l NRC Enforcement Policy.
I Action taken to date:
EIP-2 was appropriately revised in Revision 4. December 2. 1996 Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedure EIP-2 will no longer be required, since the Alternate Boron Injection System is obsolete and is not important to the safe storage of spent fuel. Therefore. EIP-2 will be deleted. Based upon the above information, the associated commitment will no longer be retained.
N. NRC Inspection Report 96-012. dated March 20. 1997 Commitment:
In a letter to the NRC dated March 20. 1997. Consumers Energy Company responded to Notice of Violation 96012-A.1. which identified NRC concerns pertaining to the uncontrolled leakage of about 400 gallons of reactor '
coolant through the open CRD accumulator water-side-drains. Consumers Energy Company committed. in part, to revise procedures identified in Administrative Procedure 1.15. " Conduct of Infrequently Performed Tests and Evolutions (IPTE)~ as (IPTE) procedures requiring an IPTE briefing prior to the point of manipulation of plant equipment affecting configuration control, i
Action taken to date:
Procedures identified in Administrative Procedure 1.15: TV-02. " Containment Integrated Leak Rate." SOP-29. " Nuclear Steam Supply System." and TV-10.
" Pressure Test of Nuclear Steam Supply System." were appropriately revised by June 1. 1997.
l Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant i l '
operation. procedures TV-02. SOP-29. and TV-10 will no longer be required.
since their associated systems are obsolete and they are not important to the safe storage of spent fuel. Therefore, these procedures will be deleted. Based upon the above information, the associated commitment will I no longer be retained. l 1
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ATTACHMENT 2 l CONSUMERS ENERGY COMPANY BIG. ROCK POINT PLANT-DOCKET 50 155 l
I f COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS) q i
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-ATTACHMENT 2 COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)
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A. Licensee Event Report (LER)89-004. Technical Specification Violation -
l Failure to Follow Procedure, dated May 11, 1989 L
Commitment:
- In LER 89-004. Consumers Energy Company committed, in part, to provide-guidance in the operating procedures to consider follow-up actions where multiple strokes of the DC operated valves have occurred to ensure battery operability, by September 1. 1989.
l Action taken to date:
Twelve procedures were identified and appropriately revised to provide l guidance on battery operability by July 31, 1989.
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It has been determined that, due to the permanent cessation of plant operation ten of the twelve procedures will no longer be required, since I their associated systems are obsolete and they are not important to the safe storage of spent fuel. Therefore, these procedures will be deleted.
Although the remaining two procedures currently retain guidance on battery operability they.are not important.to the safe storage of spent fuel.
Based upon the above information, the associated commitment will no longer be retained.
! B. Licensee Event Report (LER)90-006. Inoperable Primary System Safety Valves, dated November 20. 1990~
l Commitment 1:
In LER 90-006. Consumers Energy Company committed, in part, to revise the 4
- steam drum relief valve maintenance procedure to require verification of the serial number from the valve body and position tags on the steam drum flanges to assure proper valve identification, prior to the next refueling outage.
Act' ion taken to date: l l
Procedure MRSD-3 " Steam Drum Relief Valve - Removal and Installation." was !
appropriately revised by March 4.1991. The NRC closed LER 90-006 in IR 92-009 dated June 11. 1992.
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Commitment Disoosition:
- It has been determined that, due to the permanent cessation of plant operation. MRSD-3 will no longer be required, since the Reactor Steam Drum )
(RSD) system is obsolete and is not important to the safe storage of spent fuel. Therefore. MRSD-3 will be deleted. Based upon the above information, the associated commitment will no longer be retained.
Commitment 2:
In LER 90-006. Consumers Energy Company committed, in part, to revise test procedures to require the use of controlled, oil free hose when assembling the test apparatus for setting the safety relief valves.
Action taken to date:
Procedures MRSD-4 " Maintenance and/or Adjustment of Crosby Style HC Safety Valves." MRSD-5. " Maintenance and/or Adjustment of Crosby Style HC-75 Safety Valves Using a Hydraulic Jacking Device." and TR-28. " Steam Drum Relief Valve Testing." were appropriately revised by March 28. 1991. LER j 90-006 was closed by the NRC in IR 92-009. dated June 11. 1992. l Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedures MRSD-4. MRSD-5 and TR-28 will no longer be required, since the RSD system is obsolete and is not important to the safe storage of spent fuel. Therefore, these procedures will be deleted. Based upon the above information, the associated commitment will no longer be retained.
C. Licensee Event Report (LER)90-007. Technical Specification Violation - I Reactor Recirculation Pump / Valve Interlocks Failure, dated December 26. !
1990 Commitment: !
In LER 90-007. Consumers Energy Company committed to revise surveillance i procedure TR-35. " Reactor Recirculation Pump Interlock Test." to include provisions for testing the recirculation pump motor trip circuitry on l associated valve closure as defined in the Plant Technical Specifications.
This was to be completed by the 1991/1992 refuelirig outage which was to be the next scheduled performance of TR-35.
. Page 3 of 12 ATTACHMENT 2 COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)
Action taken to date:
Procedure TR-35 was appropriately, revised and issued September 26, 1991.
LER 90-007 was closed by the NRC in IR 92-009, dated June 11. 1992.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation. procedure TR-35 will no longer be required. since the Reactor Recirculation pumps are obsolete and not important to the safe storage of l spent fuel. Therefore, this procedure will be deleted. Based upon the above information the associated commitment will no longer be retained.
D. Licensee Event Report (LER)91-004. Plant Shutdown Due to Inoperable Core Spray Valve, dated June 26, 1991 l Commitment:
In LER 91-004. Consumers Energy Company committed to revise maintenance procedure MRVG-2. " Installation of Reactor Vessel Head." to include hanger positions and rod lengths to ensure the slope of the redundant core spray line is properly oriented. Consumers Energy Company also committed to review surveillance test T30-22. " Emergency Core Cooling System Valve Tests." for possible inclusion of a pre-test verification. :
Action taken to date:
Procedures MRVG-2 and T30-22 were appropriately revised by October 15.
1991.
Commitment Disoosition:
It has been determined that. due to the permanent cessation of plant operation, procedures MRVG-2 and T30-22 will no longer be required since the Core Spray and Emergency Core Cooling Systems are obsolete and not important to the safe storage of spent fuel. Therefore, these procedures i will be deleted. Based upon the above information the associated I commitment will no longer be retained.
E. Licensee Event Report (LER)92-007. RPS Actuation with Control Rod Motion During Drive Testing dated May 26, 1992 Commitment 1:
In LER 92-007. Consur.iers Energy Company comm.tted to revise maintenance procedures MRVG-1. " Removal of the Reactor Veisel Head." cnd MRVG-2.
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" Installation of Reactor Vessel Head." to ensure the closure of pipeway dampers when these procedures are being performed and reopening of these l dampers upon completion of these procedures.
Action taken to date: !
l Procedures MRVG-1 and MRVG-2 were appropriately revised by December 21. !
! 1992. NRC closed LER 92-007 in IR 93-002. dated February 19. 1993.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant i operation. procedure MRVG-2 will no longer be required, since it is not
- important to the safe storage of spent fuel. Therefore, this procedure will be deleted. The reactor head removal procedure (MVRG-1) will remain in effect until no longer needed, however, it is not required to address the original commitment which was related to the prevention of inadvertent RPS actuation with Control Rod motion during drive testing. Based upon the above information. the associated commitment will no longer be retained.
Commitment 2:
In LER 92-007. Consumers Energy Company committed to revise Standard i Operating Procedure. SOP-25 ~ Heating and Ventilation System." to ensure that air flow dampers are left open during refueling outages, and that the pipeway cooler fans are operating to maintain air flow over the ion tubes.
, Action taken to date:
Procedure SOP-25 was appropriately revised by December 8.1992. NRC closed LER 92-007 in IR 93-002, dated February 19. 1993.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, the revised steps to procedure SOP-25 to maintain air flow over the ion tubes will no longer be required and hence will be deleted, since the RPS Neutron Monitoring System is obsolete and is not important to the safe storage of spent fuel. Based upon the above information. the associated commitment will no longer be retained.
F. Licensee Event Report (LER)92-009. Reactor Scram During Plant Startup for Cycle 26. dated June 3. 1992 l
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Commitment:
In LER 92-009. Consumers Energy Company committed. in part. to revise procedure 0-TGS-1. " Master System Checklist." by September 1. 1992, to
- incorporate lessons learned from the May 13. 1992 reactor trip.
Action taken to date:
Procedure 0-TGS-1 was appropriately revised by October 20, 1992. NRC closed LER 92-009 in IR 93-006, dated February 19. 1993.
Commitment Disoosition:
It has been determined that. due to the permanent cessation of plant operation, procedure 0-TGS-1 will no longer be required, since the CRD {
System is obsolete and is not important to the safe storage of spent fuel, j Therefore, this procedare will be deleted. Based upon the above i information. the associated commitment will no longer be retained.
G. Licensee Event Report (LER)93-007, Unplanned Engineered Safety Feature (ESF) Actuation: Electric Fire Pump Start During Surveillance Test, dated August 12, 1993 Commitment:
l In LER 93-007. Consumers Energy Company committed to add a precaution !
statement to surveillance procedure TR-48. " Reactor Depressurization System (RDS) Function Test." by the next refueling outage that cautions against ;
board movement causing unwanted spikes, imposing spurious signals in the l RDS. The caution statement was als~o to require the affected RDS channel to be placed in " bypass" should any board movement occur.
Action taken to date:
Procedure TR-48 was appropriately revised by September 28. 1993. NRC closed LER 93-007 in IR 93-019 dated December 22, 1993.
- Commitment Disoosition
It has been determined that, due to the permanent cessation of plant operation. procedure TR-48 will no longer be required, since the Reactor Depressurization System is obsolete and is not important to the safe storage of spent fuel. Therefore, this procedure will be deleted. Based upon the above information, the associated commitment will no longer be retained.
Page 6 of 12 ATTACHMENT 2 COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)
, H. Licensee Event Report (LER)94-003. Unplanned Engineered Safety Feature (ESF) Actuation: Electric Fire Pump, dated March 28. 1994 Commitment 1:
In LER 94-003. Consumers Energy Company committed to review all Standard Operating Procedures (SOPS) that contain equipment that is defined as Engineered Safety Features to insure that the proper guidance is given to the care that must be exercised to avoid inadvertent actuation by December
- 1. 1994.
Action taken to date:
SOPS that contain equipment that is defined as Engineered Safety Features were reviewed as required and procedure SOP-6 " Emergency Condenser System."
was appropriately revised by December 1. 1994. NRC closed LER 94-003 in IR 94-018. dated February 15, 1995. )
1 Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedure SOP-6 will no longer be required, since the Emergency l
Condenser System is obsolete and is not important to the safe storage of spent fuel. Therefore, this procedure will be deleted. Based upon the above information. the associated commitment will no longer be retained.
Commitment 2:
In LER 94-003. Consumers Energy Company committed to review SOP-18.
" Reactor Depressurization System." to ensure proper guidance is given to operate an Engineered Safety Feature and the corrective action to take I given an actuation by September 1. 1994.
l Action taken to date:
l SOP-18 was appropriately revised by August 31, 1994. NRC closed LER 94-003 l in IR 94-018. dated February 15, 1995.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation procedure 50P-18 will no longer be required. since the Reactor Depressurization System is obsolete and is not important to the safe storage of spent fuel. Therefore this procedure will be deleted. Based l upon the above information, the associated commitment will no longer be i retained.
Page 7 of 12 ATTACHMENT 2 - COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS) l Commitment 3:
In LER 94-003. Consumers Energy Company committed to evaluate changing l steps in SOP-18 section 6.5.4 so that the steam drum low sensor cabinet l bistables are all reset prior to resetting the actuation cabinet L2 module.
l Action taken to date:
! SOP-18 was appropriately revised by August 31. 1994. NRC closed LER 94-003 l in IR 94-018. dated February 15. 1995.
Commitment Discosition:
It has been determined that, due to the permanent cessation of plant operation, procedure SOP-18 will no longer be required since the Reactor l Depressurization System is obsolete and is not important to the safe storage of spent fuel. Therefore, as discussed above, this procedure will be deleted. Based upon the above information, the associated commitment .
will no longer be retained.
l Commitment 4:
In LER 94-003. Consumers Energy Company committed to consider changing section 6.5.4 in SOP-18 to a " continuous use procedure.'
Action taken to date:
l SOP-18 was appropriately revised by August 31, 1994. NRC closed LER 94-003 in IR 94-018. dated February 15. 1995. )
l Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant '
operation procedure 50P-18 will no longer be required, since the Reactor Depressurization System is obsolete and is not important to the safe !
storage of spent fuel. Therefore, as discussed above, this procedure will j be deleted. Based upon the above information, the associated commitment j will no longer be retained.
Commitment 5:
In LER 94-003. Consumers Energy Company committed to add a statement to SOP-29, " Nuclear Steam Supply System.' section 6.5 that refers operators to ;
SOP-18 section 6.5.4 if the RDS requires resetting.
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Action taken to date:
l SOP-29 was appropriately revised by August 31, 1994. NRC closed LER 94-003
! in IR 94-018, dated February 15. 1995.
1 Commitment Disoosition:
l It has been determined that. due to the permanent cessation of plant operation. procedure 50P-29 will no longer be required. since the Nuclear Steam Supply System is obsolete and is not important to the safe storage of spent fuel. Therefore, this procedure will be deleted. Based upon the above information, the associated commitment will no longer be retained. !
- I. Licensee Event Repcrt (LER)94-005. Unplanned Actuation of Reactor l Protection System - No Rod Motion, dated April 8,1994 j
- Commitment
I In LER 94-005. Consumers Energy Company committed to revise procedure TR-43
! " Shutdown Margin Check." to incorporate specific interlocks and specific l
trips which must be cleared for the test to be run in the two mode switch l positions.
Action taken to date: i l
l TR-43 was appropriately revised August 15, 1994. NRC closed LER 94-003 in l IR 94-018. dated February 15. 1995. !
l Commitment Discosition:
It has been determined that, due to the permanent cessation of plant l operation. procedure TR-43 will no longer be required. since the Reactor {
Protection System is obsolete and is not important to the safe storage of l spent fuel. Therefore, this procedure will be deleted. Based upon the l above information, the associated commitment will no longer be retained.
i J. Licensee Event Report (LER)94-010. Manual Scram Dee to Loss of Feedwater, i dated December 23, 1994 l Commitment:
In LER 94-010. Consumers Energy Company committed to revise procedure SOP-15 ~ Condensate System Hotwell to Reactor Feedwater Pumps." Return the Condensate Pumos to Service section by January 15, 199_4 (a typographical error). The revision was then to be validated by scheduling a test during plant startup/ shutdown.
Page 9 of 12 ATTACHMENT 2 - COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)
Revision 1 to LER 94-010. dated July 3. 1995, corrected the due date for this commitment to January 15, 1996 Action taken to date:
SOP-15 was appropriately revised in Revision 107. NRC closed LER 94-010 in IR 95-010. dated October 27. 1995.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedure SOP-15 will no longer be required, since the Condensate System is obsolete and is not important to the safe storage of spent fuel. Therefore, this procedure will be deleted. Based upon the above information, the associated commitment will no longer be retained.
l K. Licensee Event Report (LER)95-001. Unanalyzed Emergency Core Cooling l System Condition Results in Technical Specification Required Shutdown.
l dated March 17. 1995 Commitment:
l In LER 95-001. Consumers Energy Company committed to in part, to revise i Standard Operating Procedure SOP-8. " Post Incident System." SOP-11.
l " Radioactive Waste System - Liquid." and SOP-26. Fire Protection System."
to address the proper operation of the duplex basket strainer.
l Action taken to date:
I As previously discussed under NRC IR 95-006, dated May 24. 1995. each of l the three procedures was appropriately revised by October 1.1995, to address proper operation of the duplex strainer - SOP-8. Revision 144: SOP- 4 I
- 11. Revision 128: and SOP-26. Revision 99. NRC closed LER 95-001 in IR 95-010. dated October 27. 1995.
Commitment Discosition:
It has been determined that, due to the permanent cessation of plant operation, procedure SOP-8 will no longer be required since the Post Incident System is obsolete and is not important to the safe storage of '
spent fuel. Therefore. SOP-8 will be deleted. Although the proper operation of the strainer is still addressed in 50P-11 and SOP-26, it is not important to the safe storage of spent fuel. Based upon the above ,
information, the associated commitment will no longer be retained.
Page 10 of 12 i ATTACHMENT 2 COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)
L. Licensee Event Report (LER)95-007. Automatic Reactor Scram, dated December
- 14. 1995 Commitment:
In LER 95-007. Consumers Energy Company committed to. in part, to revise Standard Operating Procedure SOP-16. "Feedwater System.~ and procedure 0-l TGS-1. " Master System Checklist." by January 12. 1996, to incorporate lessons learned from the November 16. 1995. reactor trip.
Actio, taken to date:
l l Procedures SOP-16 and 0-TGS-1 were appropriately revised by January 12.
l 1996. NRC closed LER 95-007 in IR 97-010 dated November 26, 1997.
I Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedures SOP-16 and 0-TGS-1 will no longer be required. since the Feedwater System is obsolete and is not important to the safe storage of spent fuel. Therefore, these procedures will be deleted. Based upon the above information. the associated commitment will no longer be retained.
i M. Licensee Event Report (LER)96-003. Reactor Depressurization System "B" Train Found Inoperable During Refueling Outage Surveillance, dated February
- 16. 1996 Commitment 1:
l In LER 96-003. Consumers Energy Company committed, in part, to revise l procedures Periodic and Predetermined Activity Control PPAC XTR-101. "RDS Depressurizing Valve Test." and MRDS-13. " Remove and/or Install RDS Target Rock Valves.~ to include an expanded as-found examination of the pilot isolation valves (preserve "as-found"/"as-left' condition) by June 12.
1996. In a letter to NRC dated June 14. 1996. Consumers Energy informed the Commission that this commitment due date was not met.
,. Action taken to date:
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Procedures PPAC XTR-101 and MRDS-13 were appropriately revised by June 14 1996.
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Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation. procedures PPAC XTR-101 and MRDS-13 will no longer be required, since the RDS is obsolete and is not important to the safe storage of spent i fuel. Therefore, these procedures will be deleted. Based upon the above information. the associated commitment will no longer be retained.
Commitment 2:
In LER 96-003. Consumers Energy Company committed, in part, to revise procedure TR-101. ~RDS Depressurizing Valve Test.~ to: 1) ensure SV-4984/5/6/7 are tested in the truly "as-found" condition and after a successful " lift." the pilot valves are to remain in the open position:
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- 2) have all the lower pilot isolation valves disassembled. inspected, and cleaned prior to returning the valves to service: 3) improve the reliability of existing locking mechanism or provide an alternative locking device as appropriate.
Action taken to date:
Procedure TR-101 was appropriately revised by March 22, 1996.
l Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedure TR-101 will no longer be required, since the RDS is obsolete and is not important to the safe storage of spent fuel.
Therefore, this procedure will be deleted. Based upon the above information, the associated commitment will no longer be retained.
N. Licensee Event Report (LER)97-001. Test Not Performed in Accordance with Appendix J to 10CFR Part 50. dated January 31, 1997 Commitment .
I In LER 97-001. Consumers Energy Company committed to revise procedure TV-i 02. " Containment Integrated Leak Rate Test (ILRT) to provide direction with ,
l respect to the outboard flange on containment penetration H-80. !
Action taken to date:
i As previously discussed under NRC Inspection Report 96-012. dated March 20.
1997 procedure TV-02 was appropriately revised (Revision 29). NRC closed LER 97-001 in IR 97-002, dated April 23. 1997.
Page 12 of 12 ATTACHMENT 2 COMMITMENTS ASSOCIATED WITH LICENSEE EVENT REPORTS (LERS)
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation, procedure TV-02 will no longer be required, since the ILRT is obsolete and is not important to the safe storage of spent fuel.
Therefore, this procedure will be deleted. Based upon the above information, the associated commitment will no longer be retained.
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1 ATTACHMENT 3 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT-DOCKET 50 155
-COMMITMENTS ASSOCIATED WITH 10CFR50.63 STATION BLACK 0UT RULE
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Page 1 of 1 ATTACHMENT 3 - COMMITHENT ASSOCIATED WITH 10CFR50.63 STATION BLACK 0UT RULE
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'A. Station Blackout Rule'10CFR50.36 Commitment 1:
In a letter to NRC dated July 3.1992, which provided a revised response to the Station Blackout (SBC) Rule, Consumers Energy Company committed to revise procedure ONP 2.36. " Loss of Station Power."to assure that a revised battery load profile is preserved.
Action taken to date:
ONP 2.36 was appropriately revised February 12. 1993.
Commitment disoosition:
Pursuant to the guidance of NUREG/CR-6451. Appendix B. " Detailed Regulatory Assessment." the purpose of the Station Blackout Rule is to explicitly require that nuclear plants be designed to insure that core cooling can be maintained for a specific duration (coping period) without onsite or offsite AC power.
As discussed in the UHFSR. Section 8.3.4.6. this issue was adequately resolved for power operation at Big Rock Point. During decommissioning the ability to provide safe shutdown is no longer applicable. since the reactor has been permanently defueled. Additionally, since December 5. 1997 the plant can sustain a loss of spent fuel pool cooling for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without the pool temperature exceeding.the 150 degree F limit specified in the
. Technical Specifications. Therefore, the commitment to assure that a revised battery load profile is preserved is no longer required.and will be deleted.
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Commitment 2:
i In a letter'to NRC dated July '3.1992, which provided a revised response to
! the Station' Blackout (SB0) Rule. Consumers Energy Company committed to
! revise. procedure ONP 2.36. " Loss of Station Power.~to assure that the
! Control Room is manned during a station blackout.
Action taken to date:
ONP 2.36 was appropriately revised February 12. 1993.
Commitment disoosition:
For the reasons discussed above under Commitment 1. this commitment is no longer required and will be deleted.
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O e 3 ATTACHMENT 4 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50 155 COMMITMENTS ASSOCIATED WITH NRC BULLETINS
. Page 1 of 2 ATTACHMENT 4 COMMITMENTS ASSOCIATED WITH NRC BULLETINS
'A. NRC' Bulletin 90-01.." Loss of Fill-0il in Rosemount Transmitters dated March 9. 1990 Commitma.at_:
In a letter to NRC. dated July 11. 1990, in response to Bulletin 90-01.
Consumers Energy Company committed. in part, to revise plant procedures to include static alignment testing for the Post Incident System (PIS)
Rosemount transmitters, beginning with the 1990 refueling outage.
Action taken to date:
Test Procedure TR-50. " Calibration and Testing of Core Spray Flow.
Enclosure Spray Flow and Fire System Strainer Differential Pressure Instrumentation." was revised July 13. 1990.
Commitment Disoosition:
'It has been determined that, due to the permanent cessation of plant operation, procedure TR-50 will no longer be required to_ address
. calibration and testing of the PIS Rosemount Transmitters, since the PIS is '
obsolete and is not important to the safe storage of spent fuel.
Therefore, this procedure will be revised to delete reference to static i alignment testing for the PIS transmitters. Based upon the above i information the associated commitment will no longer be retained.
B. NRC Bulletin 90-02. " Loss of Thermal Margin Caused by. Channel Box Bow."
dated March 20. 1990 Commitment :
In a letter to NRC. dated July 11, 1990, in_ update to the April- 20,1990.
response to Bulletin 90-02. Consumers Energy Company _ committed. in part, to-replace the channels for fuel assemblies in the cycle design package identified as having minimum critical power ratios (MCPRs) of less than or equal to 1.793. To accomplish this, appropriate procedures were required to be modified to. ensure compliance with the Technical Specification limit
.for MCPR of 1.763. j Action taken to date; This procedure revision was completed for TR-46. " Fuel Bundle Core Loadi_ng." by December 20, 1990. This procedural requirement .vas later transferred to procedure 0-RVI-1. " Reactor Internals Shuffling.' in October of 1995.
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Page 2 of 2 ATTACHMENT 4 - COMMITMENTS ASSOCIATED WITH NRC BULLETINS Commitment Discosition:
It has been determined that, due to the permanent cessation of plant operation and defueling of the reactor, procedure 0-RVI-1 will no longer be required and will be deleted. Based upon the above information, the associated commitment will no longer be retained.
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d ATTACHMENT 5 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 1.
COMMITHENTS ASSOCIATED WITH NRC GENERIC LETTERS l-t t
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. Page 1 of 3 ATTACHMENT 5 - COMMITMENTS ASSOCIATED WITH NRC GENERIC LETTERS
'A. NRC Generic Letter 88-01. "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping." dated January 25. 1988 Commitment 1:
In a letter to NRC dated May 24. 1991, which was a revised response to GL 88-01. Consumers Energy Company committed, in part to perform revisions to plant procedures addressing leak detection and inoperability of leakage monitoring equipment described under items A and B of that letter, within 90 days following NRC approval of the Leakage Detection Program.
Action taken to date:
SOP-29. " Nuclear Steam Supply System." was appropriately revised with the issuance of Revision 149.
Commitment Disoosition:
It has been determined that, due to the permanent cessation of plant operation and defueling of the reactor, procedure SOP-29 will no longer be required, since the NSSS is obsolete and is not important to the safe storage of spent fuel. Therefore, this procedure will be deleted. Based upon the above information, the associated commitment will no longer be retained.
B. NRC Generic Letter 89-13. ' Service Water Systems Affecting Safety-Related Equipment." dated July 18. 1989 Commitment 1:
In a letter to NRC dated January 29, 1990. in response to GL 89-13.
Consumers Energy Company committed, in part, to revise affected maintenance procedures to ensure that corrosion and bio-fouling considerations are included during routine maintenance inspections and activities for those systems and components subject to the Generic Letter.
Action taken to date:
Eight of nine maintenance procedures which included corrosion and bio-fouling considerations, were appropriately revised to address this commitment. One procedure (MPIS-2) was a single use procedure and never revised. One procedure (MPIS-18) was identified as obsolete and was deleted during a procedure update review in Octobe; 1995.
Page 2 of 3 ATTACHMENT 5 - COMMITMENTS ASSOCIATED WITH NRC GENERIC LETTERS Commitment Disoosition:
Five of the seven remaining maintenance procedures revised in response to GL 89-13 are applicable to inservice systems and remain in effect.
The alpha-numeric designator of procedure MBLS-2 " Inservice Inspection of Water and Flood Control Structures." was changed to TV-57. which currently remains in effect. It has been determined that, due to the permanent cessation of operation of the plant and defueling of the reactor. IRDS-3.
" Electric Fire Pump Pressure Switches Calibration." and IRDS-4. " Diesel Fire Pump Pressure Switches' Calibration." which relate to the Reactor Depressurization System (RDS) operation, which is obsolete and not important to the safe storage of spent fuel will be deleted.
Commitment 2:
In a letter to NRC dated January 29. 1990. in response to GL 89-13.
Consumers Energy Company committed, in part, to revise operating procedures or employ an equally effective method of communication to alert operations personnel to the threat and consequences of biofouling.
i Action taken to date:
Sixteen operating procedures which included corrosion and bio-fouling consider ' ,ns, were appropriately revised to address this commitment.
Commitment Discosition:
Due to the permanent cessation of operation of the plant and defueling of I the reactor, seven of the operating procedures revised in response to GL 89-13. which relate to obsolete systems not important to the safe storage 1 of spent fuel. will be deleted. The remaining nine procedures retain l guidance addressing biofouling and corrosion concerns.
Commitment 3:
l In a letter to NRC dated January 29. 1990. in response to GL 89-13. l Consumers Energy Company committed. in part. to revise Post Incident System j (PIS). Fire Protection System (FPS) and Emergency Diesel Generator (EDG) '
surveillance tests to establish pre-test inspections and action or response levels, which reduce the potential for bio-fouling.
Action taken to date:
Fourteen surveillance procedures which included corrosion and bio-fouling considerations, were appropriately revised to address this commitment.
Page 3 of 3 ATTACHMENT 5 - COMMITMENTS ASSOCIATED WITH NRC GENERIC LETTERS Commitment Disoosition:
Due to the permanent cessation of operation of the plant and defueling of the reactor, three of the surveillance procedures revised in response to GL 89-13. which relate to obsolete systems not important to the safe storage of spent fuel, will be deleted. The remaining eleven procedures retain guidance addressing biofouling and corrosion concerns.
Commitment 4:
In a letter to NRC dated January 29, 1990, in response to GL 89-13.
Consumers Energy Company committed, in part, to revise existing surveillance procedures with components impacted by GL 89-13. to incorporate trending of parameters indicative of component cooling performance.
Action taken to date:
Seventeen surveillance procedures which included corrosion and bio-fouling considerations, were appropriately revised to address this commitment.
Commitment Disoosition: l l
I Due to the permanent cessation of operation of the plant and defueling of l the reactor. five of the surveillance procedures revised in response to GL l
89-13. which relate to obsolete systems not important to the safe storage )
of spent fuel, will be deleted. The remaining twelve procedures retain l guidance addressing biofouling and corrosion concerns.
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ATTACHMENT 6 CONSUMERS ENERGY' COMPANY BIG ROCK POINT PLANT DOCKET 50-155 MISCELLANEOUS COMMITMENTS I
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Page 1 of 3 ATTACHMENT 6 - MISCELLANEOUS COMMITMENTS j
'A. Let ter to NRC. " Technical Specification 3.7.11.1. Special Report - Fire ,
Suppression Water System." dated June 3. 1988 Commitment: {
Attached to a letter to NRC dated June 3. 1988. a Special Report was provided. This was to satisfy a Technical Specification requirement that a l Special Report be submitted to the NRC if. during a time when a Fire Suppression Water System is inoperable. the inoperable equipment is not returned to service within seven days. In this Special Report. Consumers Energy committed, in part. to revise the UPS Battery Service Test Procedure l to allow returning the Diesel Fire Pump start circuit to service prior to completion of cell recharge.
Action taken to date: )
Procedure TR-65C. "RDS-UPS 'C' Battery Service Test and Discharging Alarm ,
Operability Verification." was appropriately revised to address this commitment.
Commitment Disoosition:
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A plant design change (minor alteration) has eliminated the requirement for this revision and for procedure TR-65C. TR-65C will be deleted. A surveillance test still ensures that the diesel fire pump auto starts on decaying discharge pressure. However, the original commitment is no longer l applicable and will not be retained.
B. Letter to NRC. " Completion of Integrated Plan Issue BN-050A2 (SEP Topic VI- ,
- 4. Containment Isolation), dated May 1.1990 l Commitment:
l NRC letter dated December 9,1982, identified certain weaknesses at Big Rock Point in the area of containment isolation as compared to the l licensing criteria applied to new plants at the time. !
By letter dated February 28. 1983. Consumers Energ/ Company committed to utilize the probabilistic risk assessment (PRA) approach to investigate a number of these areas to determine their contribution to the plant's risk of core damage and/or containment failure. From that evaluation, an instrument air check valve leak testing program was implemented and a recommendation was made to implement a Main Steam Isolation Valve (MSIV) partial stroke test surveillance program, to permit data collection and reliability evaluation.
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~ ATTACHMENT 6 e MISCELLANE0US COMMITMENTS By' letter dated June.l. 1983. Consumers Energy Company committed to perform the partial stroke testing and evaluation of the MSIV as a part of the Integrated Plan.
By letter dated May 1. 1990.. Consumers Energy Company provided the NRC with notification that.SEP Topic VI-4 and BRP Integrated Plan Issue BN-050A2 had been completed. In-this letter Consumers Energy Company committed to continue the MSIV partial stroke testing on a quarterly basis and to perform testing and trending through an administratively controlled test procedure.
Action taken to date:
Procedure T90-25. " Partial Stroke Test of MSIV." was developed and issued
. August 1, 1990, to address this commitment.
Commitment Discosition:
-Due to the permanent cessation of operation of the plant and defueling of the reactor, procedure T90-25 is no longer required since the Main Steam System is obsolete and not important to the safe storage of spent fuel.
Therefore. T90-25 will be deleted-. Based upon the above information, the associated commitment will no longer be retained.
l C. Letter to NRC. '" Modification of Previous Commitment to Replace Feedwater Check Valve Resilient Seal Every.0ther Refueling Outage." dated March 21, 1992:
Commitment:
In a letter dated March 23 1992. Consumers Energy Company revised a commitment made in a May 25, 1983 submittal to replace the feedwater check valve resilient seal every refueling outage and' modified in an April -18, 1988 submittal to replace the seal every other refueling outage. The March 23.-1992 submittal stated that the seat change out would be governed by the
. performance and trending of the inservice leak rate testing of valve VFW-305.
In a le'tter to Consumers' Energy Company from the NRC dated June 29.1992.
" Big Rock Point Plant - Modification of Previous Commitment to Replace Feedwater Check Valve Resilient Seat Every Other Refueling Outage (TAC ;
NO.83072). NRC concluded that seat replacement for the feedwater check l valve that is governed by the performance and trending of inservice leak' rate testing is acceptable.
r e Page 3 of 3 l ATTACHMENT 6 - MISCELLANEOUS COMMITMENTS l
Action taken to date-Procedure TR-391. "Feedwater Check Valve Leak Rate Test." was appropriately revised to address this commitment.
Commitment Disoosition:
Due to the permanent cessation of operation of the plant and defueling of the reactor, procedure TR-391 is no longer required since the Feedwater System is obsolete and not important to the safe storage of spent fuel.
Therefore. TR-39I will be deleted. Based upon the above information, the associated commitment will no longer be retained.
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