ML20245J287

Comments on SALP 8 Board Rept for Sept 1987 - Dec 1988. Correction of Reactor Depressurization Sys Valve Problems, Neutron Monitoring Sys Upgrades & Resolution of Steam Drum Relief Valve Concerns Completed in 1988

ML20245J287
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/27/1989
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8905040083
Download: ML20245J287 (4)

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Colisumers POWBr David P Hoffman Vice President Nuclear Operations SQWERlM MIENSGAnr5 PROGRESS General Offx:es: 1945 West Pernall Road, Jackson, MI 49201 (517) 788-0453 l

April 27, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i

I DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

SALP 8 RESPONSE NRC letter dated March 13, 1989 contained the Systematic Assessment of '

Licensee Performance (SALP) No. 8 Board Report for our Big Rock Point Nuclear Plant. This letter provides Consumers Power Company's written comments regarding that report.

Consumers Power Company thanks the NRC for the feedback on activities at Big Rock Point from the period of September 1, 1987 through December 31, 1988.

We believe that all of the concerns identified will be addressed very effectively.

With regard to concerns associated with the Living Schedule, in 1988 we completed three high priority items, specifically: correction of Reactor Depressurization System valve problems; Neutron Monitoring System upgrades;  ;

and resolution of steam drum relief valve concerns. We believe that these i

. actions have made and will make a continued positive contribution toward l improved plant safety and availability. Our two highest priority items are now receiving accelerated attention and resources. We fully expect actions in 1989 and in the 1990 refueling outage to address these issues. Also, in  !

September 1988, we changed the plant organization to increase management attention and the total engineering resources applied to our Living Schedule.

With regard to the concerns associated with plant age and plant maintenance, we are taking actions which we believe will result in significant improvements. In September 1988, the organization was revised to re-establish a full time maintenance superintendent whose responsibilities are solely  !

maintenance. In early 1988, we continued to enhance our Predictive Maintenance l Program in the area of vibration analysis of rotating equipment. In late a rep OC0489-0125-NLO4 . i g A CAiS ENERGYCOMPANY

Nuclear Regulatory Commission 2 l , Big Rock Point Plant

. Salp 8 Response April 27, 1989 1988, we began to add thermography readings. This information was critical in l helping us decide to perform preventive maintenance on bus bar connections in our switchyard in a recent four day scheduled maintenance outage in March.

This very likely avoided possible future equipment failures. We have plans to enhance this program into 1989 and 1990. Part of our predictive efforts have been aimed at pipe wall thinning in secondary systems and our program there is well established.

In 1988, we overhauled one main feedwater pump and mort.r, one service water pump and motor, and one circulating water pump and neto . In 1989, we plan to overhaul the remaining service water pump and motor. V are adding vibration monitoring equipment to our recirculation pumps and perf rming presentive maintenance on critical recirculation pump heat exchangers. We will also be monitoring key motor parameters. A major $1.5 million turbine overhaul is planned for this summer; it will refurbish turbine seals, blade tips and items critical to turbine performance. In January, we sent three key maintenance staff members to Humboldt Bay to obtain maintenance information and history data as well as critical parts for future planned maintenance activities.

In 1989, we are planning to rewire all of our control rod drive accumulators prior to aging becoming a concern. In 1990, we will overhaul both our condensate pumps and our main generator. This will result in the completion of all major rotating equipment overhauls at Big Rock Point in the period from 1988 through 1990.

To accomplish all of the maintenance identified, we have relird primarily upon our plant maintenance staff. We will also supplement these resources first with our Company's travel repair crews, and occasioanlly with outside contractors. Our efforts to manage these support groups will be intensified in 1989. Many of the items are delineated in our Maintenance Improvement Plan which stemmed from our Maintenance Self Assessment.

Concerning the operator licensing examination conducted in 1988, Consumers Power recognizes that extensive efforts are expelled by the NRC in developing and administering these exams, and our failure to provide up to date reference material is unacceptable. Actions have taken place to avoid recurrence.

Recently, Big Rock Point Training personnel held a meeting with NRC Region  !

III personnel to discuss plans for the 1989 examination. Plant participation in the development of these exams is recognized and with continued communica-tion, problems should be avoided. Additional interaction with NRC staff, both in Region III and NRR, is forthcoming to discuss implementation plans associated with the recent 10 CFR 55 rule changes dealing with operator training and examination.

Additional comments are provided as follows:

A. Plant Operations The section discussed the reactor trips and ESF actuations during the SALP period which raised some overall concern in comments contained in the cover letter. Four of the trips did occur at low power due to electrical OC0489-0125-NLO4

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. Salp 8 Response

' April 27, 1989 noise in the original plant neutron monitoring system. This system has been replaced with new state-of-the-art equipment and the one out of two y logic trips has been eliminated. Consumers Power Company expects this 1 change will sigt"ficantly reduce the trip ratu, i With respect to ESF actuations, Consumers Power disagrees with staff assessment of diesel generator starts. The guidance contained in NUREG-1022, Supplement #1, question 6.1, is "no standard list of ESFs exist i and one should consult the FSAR in determining deportability". Using this guidance, the BRP Updated Final Hazards Summary Report, developed from NRC Safety Evaluation dated February 1, 1982, states the ESF systems for Big Rock Point are as follows:

Containment Isolation Post Incident System Core Spray System Emergency Condenser System Reactor Depressurization System B. Radiological Controls An issue discussed in this area dealt with fuel sipping and removal of bad fuel. Consumers Power Company agrees with the NRC comments during the SALP presentation that reference to this issue did not belong in this report and acknowledges that the staff intends to have this portion amended.

C. Maintenance / Surveillance No additional comments.

D. Emergency Preparedness No comments.

E. Security In security, the elimination of the Corporate Property Protection group has been identified as a potential concern. The Company retained the two most experienced Property Protection Departner.t personnel, one of whom performs audits every six months in the security area. The other individual recently performed a comprehensive in-house fitness for duty audit and participates in licensing activities related to security. We believe this will retain the independence and expertise of the previous Property Protection Department while making plant line management accountable.

F. Engineering / Technical Support No additional comments.

OC0489-0125-NLO4

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• Salp 8 Response April 27, 1989 G. Safety Assessment / Quality Verification With respect to lack of performance based audits and surveillance, Consumers Power QA Audit section has used various " Performance Based Techniques" for several years. The use of technical specialists in support of audits along with the " vertical slice" approach have all been aimed at performance based inspections. To build upon this, training classes in performance based audits and inspections were conducted by BarTech, Inc in January and March of this year. This training will continue our advancement in the direction of performance based audits and inspections.

While we believe progress has been made by Quality Assurance Department in conducting performance based audits Consumers Power will continue to work at improving this area.

Overall, we believe that the Nuclear Regulatory Commission may wish to rothink how it uses and interprets trend data. For example, two items of noncompli-ance were identified in the security area in this SALP period and stated to be a negative trend. Both of these involved physical plant deficiencies that were present since the Security Plans took full effect in 1975. What occurred in this SALP period was the identification of these weaknesses and the immediate corrective action. We would (onclude that the trend is very positive as our security system is physically (hardware wise) superior to what it was at anytime in the past. The identification of a problem that has existed in the past and that is promptly corrected should not necessarily be viewed as a negative trend.

Consumers Power Company thanks you for your attention. We sincerely intend to communicate openly and frequently with NRC and we appreciate your recognition of our management style at Big Rock Point. We are committed, as are you, to continue to make Big Rock Point a very safe operation.

David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Plant OC0489-0125-Ni04

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