ML20235R776

Responds to NRC Re Violations Noted in Insp Rept 50-155/88-26.Concurs That Potential Weakness Did Exist W/ Respect to Identifying Critical Performance Parameters for Improvement of Equipment Replacement Program

ML20235R776
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	02/27/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8903030420
Download: ML20235R776 (2)

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d W 08 Kenneth W Beny POWERING Director MKNIGAN*S PROGRESS """"'""'"'""

General Offices: 1945 West Pernali Road, Jackson MI 49201 e '517) 7881636 February 27, 1989 Nuclear Regulatory Commission j Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO NRC INSPECTION REPORT 88026 NRC letter dated January 5, 1989 enclosed Inspection Report No. 88026. The inspection identified no violations of NRC requirements, however, the cover letter requested that we evaluate a potential weakness in identifying criti-cal performance parameters for improvement of our equipment replacement program. The report further concluded that "in general, these modifications were well documented, technically adequate, and conducted in accordance with applicable requirements." This letter provides our response to the identified weakness.

Consumers Power Company has reviewed the concern and concurs that a potential weakness did exist with response to identification of " critical performance requirements for replacement equipment not procured on a like-for-like basis". Although, we have determined that the specific referenced example concerning replacement recorders was more a concern related to training, in that the involved individuals did not perform an adequate background specification search, we have concluded that the concern was valid. The potential did exist for not identifying an operating parameter and operating experience during the design phase of a modification or specification change.

In response, we have revised both our Design Input Checklist (DIC) and our Specification Change Checklist (SCC).

The DIC r.ow includes an additional block for the determinations of compatibility requirements. The instructions note that the section "is particularly important when equipment replacement is being performed and specific parameters apply". It includes the determinat;on for applicability of the following parameters: fit up interfaces, tolerances, operating interfaces, pressure, voltage, current, and flow. The SCC was also revised to improve the identification of compatibility requirements for all replacements.

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. . " Nuclear Regulatory Cornission 2 Big Rock Point Plant Response to NRC IR 88026 February 27, 1989 We believe these changes to our design and specification checklists provides the appropriate guidance to not only ensure that the potential weakness has been eliminated but will also serve to strengthen and improve our equipment replacement program at Big Rock Point. The checklist revisions and the training associated with the procedures changes have been completed, i 1& "W Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point i i

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