ML20236H070

Responds to Violations Noted in Insp Rept 50-155/98-04. Corrective Actions:Rcw Sys Function Plant Performance Criteria Was Revised to One MPFF for Sys Function in Expert Panel Meeting 98-02,980506

ML20236H070
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/30/1998
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-155-98-04, 50-155-98-4, NUDOCS 9807070075
Download: ML20236H070 (7)

Text

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00nsumersEnergy A CMS Erergy Company Big Rock Point & clear Plant M RPnents 10269 L&31 Norm Site General Manager Charlevoix. MI 49720 June 30, 1998 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKET 50-155 - LICENSE DPR 6 - BIG ROCK POINT PLANT - REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004, On May 8th, the NRC completed an inspection of the implementation of 10 CFR 50.65. " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" at the Big Rock Point Plant.

The NRC inspectors identified two violations of NRC requirements. Both violations were contrary to 10 CFR 50.65(a)(1) and (a)(2). As of July 10, 1996, the Big Rock Point staff elected not to monitor the performance or condition of certain Systems Structures, and Components (SSCs) against established goals pursuant to the requirements of Section (a)(1), and failed to demonstrate that the performance or condition of SSCs within the scope of 10 CFR 50.65 had been effectively controlled by performing appropriate preventative maintenance.

Consumers Energy Company agrees with the violations as stated. The facility is '

currently in full compliance. ]

Pursuant to the direction provided in the report, find attached a Reply to the Notice of Violation. The corrective actions taken and proposed are intended to address the concerns expressed by the NRC Inspectors, and to prevent recurrence of similar i cidents.

f/ ODl enneth P Powers  ;

Site General Manager CC: Administrator, Region III. USNRC NRC Resident Inspector - Big Rock Point NRR Project Manager - OWFN. USNRC ATTACHMENT 9807070075 990630

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INSPECTION REPORT.-98004 Submitted June 30,:1998 E

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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004 NOTICE OF VIOLATION 4

Consumers Energy Company Docket No. 50-155 Big Rock Point Nuclear Plant' License No. DPR-6 EA 98-282

.During an NRC inspection completed'on May 8.1998. violations of NRC requirements were identified. In accordance with NUREG-1600; " General

Statement of Policy and Procedure-for NRC Enforcement Actions. " the violations are listed below

. 10 CFR 50.65(a)(1) requires, in part. the holders of an operating license shall monitor the performance or condition of SSCs within the scope of the monitoring program, as defined in 10 CFR 50.65(b). against licensee-

-' established goals in a manner sufficient to provide reasonable assurance that

' such SSCs are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety. When the performance or i

. condition of an SSC does not meet established goals, appropriate corrective i

. action shall be taken. l

' 10 CFR 50.65(a)(2) requires. in art that monitoring as specified in i 10 CFR 50.65(a)(1) is not required where it has been demonstrated that the {

performance or condition of an SSC is being effectively controlled through the 1 per formance of appropilate preventive maintenance, such that the SSC remains l capat:1e of performing its intended function.

Contrary to 10 CFR '50.65(a)(2), as of July 10.' 1996, the time that the licensee elected not to monitor the performance or condition of certain SSCs 1 against established goals pursuant to the requirements of Section (a)(1). the l licensee failed to demonstrate that the performance or condition of SSCs l

, . within the' scope of 10 CFR 50.65 had been effectively controlled by performing  !

appropriate preventive maintenance. as evidenced by the following examples, i each of which constitutes a separate violation: j

, ' 1. The licensee failed to adequately demonstrate that the performance or condition of functions of the reactor cooling water station power.

spent fuel storage rack, and fuel bundle ~ configuration systems had been effectively controlled by performing appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2).  !

Specifically. the licensee's basis for placing these SSC functions under the requirements of 10 CFR 50.65 (a)(2) was inadequate because plant level measures were used in assessing preventive maintenance. Failures of these SSCs would not necessarily result in unplanned scrams. safety system actuations, or an unplanned capability loss factor. Further, none ,

l of these parameters were appropriate for a permanently shutdown plant. i As a result, it was not demonstrated that effective preventive maintenance ensured that the functions of these systems remained capable of; performing as required. (04011) i 8

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REPLY TO A NOTICE OF VIOLATION - NRC INSPECTION REPORT 98004

2. ' The licensee failed to adequately demonstrate that the performance or condition of functions of the demineralized water emergency power. fuel handling. and radiation monitoring systems had been effectively controlled by performing appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically.

the measures used in the demonstration for these system functions consisted only of an inappropriate reliability measure that allowed repetitive maintenance preventable functional failures that are a 1;.easure of corrective action rather than reliability. As a result, it was not demonstrated that effective preventive maintenance ensured that the functions of these systems remained capable of performing as required. (04012)

This is a Severity Leve! IV violation (Supplement IV).

Consumers Energy Company agrees with the violations as stated.

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1. Reason for the violations.

Big Rock Point management did not dedicate the appropriate level of ,

ownership and resources _to ensure complete compliance with the Rule. 1 II.'The corrective stens that have been taken and the results achieved.

Violation 04011 The following corrective actions in the identified areas have been taken:

a. Reactor Cooling Water System Function

-The Reactor' Cooling Water System function (which is the 3 referred method of heat removal from the spent fuel pool system heat exc1 angers) plant

>erformance criteria-was revised to one MPFF for the system function in '

Expert Panel Meeting 98-02, 5/6/98. Condition reports from 1993 forward were reviewed. A functional failure of a relief valve on the shell side

.of one of the fuel pit heat exchangers was found during a three year surveillance, which occurred in July of 1996. At that particular point in time, the plant was in shutdown with return to operation after the

. refueling outage. Expert panel discussed this event at a meeting held June'10, 1998. The maintenance supervisor believed that a goal of successfully completing the post maintenance test was an acceptable basis for (a)(2) categories.4The system engineer has initiated the three year surveillance to be performed a year earlier (SFP051. WO #12810700, on RV-5031 #2 heat exchanger). The periodic maintenance to inspect and calibrate RV-5030 (#1 heat exchanger relief valve) will be generated if RV-5031 test.is unsatisfactory. The expert panel agreed that the relief valve should remain.in mainter.ance rule category (a)(2) until the results of the surveillance are obtained.

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. REPLY TO A NOTICE.0F. VIOLATION. '

NRC INSPECTION REPORT 98004 Y  ; . .:

. b. ' Station Power. System Function 4

The Station' Power System function, which had the plant level performance criteria." Provide power :for essential services and equipment required

iduring design basis events, assuming.no loss of-offsite power", was Lrevised:in the. plant Q-List to: "The station power system-(SPS) provides  !

the source.of. 1

offsite power" power for services and equipment assuming no-loss of-; Th  ;

. Maintenance Rule in expert panel meeting 98-01. Performance criteria for L

- this< revised system function was set in Expert Panel Meeting 98-02, to "be one MPFFECondition reports from 1993 on were reviewed and one-

~ potential MPFF was . discovered, which occurred 5/30/96.. Station battery )'

. charger'was not; functioning.and batteries were unable to provide 125 Vdc power.;Since the event has not recurred in over two years, the systems performance has been adequate and will remain in category (a)(2).

c. Spent Fuel Storage Rack S stem Function The Spent Fuel-Storage _ Rack System func' tion " Spent and new fuel storage u

+ rack spacing:.provides structural. integrity and' fuel bundle" spacing." i

was revised in the plant'Q-List.to: " Spent, fuel. storage. rack spacing  !

which ensures and maintains'subtrisical configuration among the stored j fuel bundles." This-system function was found to be in-scope to the .i Maintenance Rule in expert panel meeting'98-01, 4/98. Plant? level  !

3erformance criteria for'this' system function was revised in Expert

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JanelLMeeting 90-02, to be;one MPFF. Condition reports from 1993 on were -l

r.eviewed and no functional' failures were identified.  !

Ld. Fuel Bundle Configuration System Function '

The. FuelBundle Configuration System function..E" Fuel bundle . '

conf _iguration.: constitution and pressure boundary -(UFHSR '4.2)" was <

revised in the plant 0-List' to: ." Fuel Bundle configuration, constitution and pressure boundary-(cladding)." This system function was found to be-n in-scope to the Maintenance Rule in expert panel meeting 98-01. Plant level 1 performance criteria for this revised system function was revised in Expert Panel Meeting 98-02, to be' condition monitoring with at least

< a' two year review or walkdown.

[This condition monitoring criteria was re-reviewed in Expert Panel :I Meeting 98-03.- 6/10/98. since fuel cladding is not inspected on a. l regular-basis due to ALARA (As Low As Reasonably Achievable) conside' rations. When the fuel'was removed from the reactor, a visual

' inspection was done on tne oldest and newest bundles-to inspect cladding

, 11ntegrity. ' Currently, there is:no' inspection for_ system function FFI-

- 1010. Fission products are not monitored in-the spent fuel' pool (based on the assumption that'there were no suspect cladding failures when the i bundles were<in the' reactor; a muta harsher environment). If a bundle.is e

, dropped during fuel moves. a-visual examination is done. Performance-criteria for this system functions was set as a single MPFF as.

J  ; documented on a condition report for a cause determination if a bundle l

1s dropped'and cladding failure is suspected. Condition reports from g

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a 1 REPLY TO A' NOTICE OF VIOLATION i'NRC INSPECTION REPORT 98004

'1993 on were reviewed and'no functional failures were identified.

iVi01ation'04012- 1 az . Demineralized Water System Function 4

- Demineralized. Water' System Function is to " Provide makeup water to-spent fuel: pool., reactor cooling water system, reactor building' heating and.

cooling _ system, and'the heating boiler". The inappropriate performance

~ criteria 'of repetitive MPFFs was identified in a self assessment in May, 1997.1At the time of-the assessment. MPFF's.were reviewed.to determine Lif- revising.a repetitive MPFF within a time frame to less than twot 2- LMPFF's within that time frame would result in exceedance of performance

, criteria. This system function was- required in this review; A single HPFF occurred-2/4/950 the demineralized water pump breaker. failed

, resulting in failure of the motor to'run (C-BRP-95;078). In the review

'after the assessment.:this event did not result in' exceeded performance .

tcriteria. In the May 1998 Expert Panel Meeting. the performance criteria i for this system' function was revised-to.'a single MPFF. Since the event

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'has not recurred in_ over two years .its performance;has been adequate y 7 andwill1 remain:in' category (a)(2),

o bl Emergency Power System Function

< Emergency.LPowerSystemFunctionisto"Providebackuppowersources~for

. essential equipment and services'for normal plant system operation during decommissioning upon loss of off-site power".. The emergency!

ldiesehgenerator.(EDG), which supports this system function, was .in

.' category (a)(1) uritil August of'1996' when effectiveness of maintenance on a rheostat was demonstrated.--'In addition. the EDG had several MPFF's, '

which had. dissimilar failure causes in 1996.' Since the events: have not:

recurred within two years, its performance is consider-ed adequate and it will remain in category (a)(2);

Prior. to April 1998 Expert' Panel' Meeting. the standby diesel generator

(SDG) was specifically; excluded from the scope of the maintenance rule- .

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L At:the, April 1998 Expert Panel Meeting, the SDG was included in this - i

. system function duetto planned modifications. Review of corrective

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,Eaction during'the' Periodic Maintenance Effectiveness Assessment for this "

system' function revealed several failures of the standby diesel

- Lgenerator. The'SDG has b'een recommended:for elevation to category '(a)(1)

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!as aLresult of the Periodic Effectiveness Assessment.which was completed h June 30,*1998.

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Fuel Handling System Function Fuel 1 Handling System Function is to provide a " Transfer cask to maintain  ;

fuel bundle cooling ~and cladding integrity during transfer of fuel". i This function has. inappropriate. performance criteria of repetitive  !

TMPFF's. This has been revised to one MPFF. Corrective action was

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,reviewedsfor a three year period, and.no MPFFS were identified for this

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' system:, function, fdi Radiation Monitoring System Function

.  : Radiation Monitoring Sys' tem Function is to'~" Perform the nonsafety-related function of monitoring the fuel _ storage area.. indirectly 'l monitoring the spent ' fuel 2001 by_ alarming on:high radiation asi a result -

.of Llow pool. water level"'. . Review of three year's condition reports i

revealed an unplanned safety system actuation in. March, 1996. TheLvent  !

! valves closed. This wastnot considered.as a functional failure. sinceL the' actuation:was-not a , result:of low fuel pool. levellor high containment pressure.-

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- Ithoughi the performance criteria. were- not . revised / reviewed Lin a timely -

manner;.the. Maintenance Rule

Administrator lwas still reviewing MPFF's within i

the time frame of-the inappropriate performance criteria. and no MPFF's for:

i the^ system. functions identified.were found.

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III.iThe correctivesteos that will be taken to avoid recurrence.

! Violation 04011 t l

21. . Timeliness.of Technical documents available- for the11nput to the - 1 revision of the maintenance rule should be a one-time event. As a:

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.  ? result, .Decommi_ssioning process! priorities' have been:appropriatelyiset.)

22 .IFuel pit heat, exchanger: relief valve surveillance has.been accelerated s ;to determine if its performance is satisfactory. Relieflvalve:will be

. tested _to assess maintenance effectiveness.' Category determination will.

'be made by September 30? 1998

based upon. test results.~

[ IV.lThe date when the facility'will be in' full comolianc t

-The facility is currently.in: full compliance. Full compliance has'been 1 fachieved with the revision of performance criteriaLand completion ofsthe m ' review of~ system functions.

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