IR 05000155/1989001

App to SALP Rept 50-155/89-01 for Sept 1987 - Dec 1988 Covering Diesel Generator as ESF Sys & Sipping of Fuel & Removal of Bad Fuel

ML20247K887
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/24/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247K883	List: IR 05000155/1989001 ML20247K874
References
50-155-89-01, 50-155-89-1, NUDOCS 8906020045
Download: ML20247K887 (10)

Text

7. .

. <

'-

,

, ,

.

.

Enclosure 1 SALP 8 APPENDIX SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION III

I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORi4ANCE 50-155/89001 4 Inspection Report N l Consumers Power Company Name of Licensee l

(

Big Rock Point Nuclear Pla.nt Name of Facility September 1, 1987, through December 31, 1988 Assessment Period

I l

l 890602004D 890524 PDR ADOCK 05000155 Q PDC

\ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _

_ . _ _ _ _ _ _ _ _ _ _ _

i

-

,.

.

.

Enclosure 1 Big Rock Point Nuclear Plant A. Summary of Meeting with Consumers Power Company on March 28, 1989 The findings and conclu:, ions of the SALP Board are documented in Report No. 50-155/89001 and were discussed with the licensee on March 28, 1989, at the Edgewater Inn, Charlevoix, Michiga While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observer The following licensee and NRC personnel were in attendanc Consumers Power Company G. Heins, Senior Vice President R. Nicholeson, Vice President of Energy Supply Services K. Berry, Director of Nuclear Licensing T. Elward, Plant Manager, Big Rock Point Various members of the plant staff Nuclear Regulatory Commission C. Norelius, Deputy Regional Administrator W. Forney, Deputy Director. Division of Reactor Projects (DRP)

I. Jackiw, Chief, Reactor Projects Section 28, DRP W. Scott, Licensing Project Manager, NRR E. Plettner, Senior Resident Inspector i l

B. Comments Received from Licensee Consumers Power s response to the Big Rock Point SALP 8 Board Report dated

April 27, 1989, included several comments that after further evaluation l

have resulted in revising the SALP Report. These changes are listed in Enclosure (2), Errata Sheet, and corrected pages are included as Enclosure (3).

Replace the pages in arror listed in Enclosure (2) with the corrected pages attached in Enclosure (3) into your copy of the SALP Repor C. Regional Administrator's Conclusions Based on Consideration of Licensee Comments We noted your comments on pages 3 and 4 of your response regarding security. The information contained in your response regarding the ;

elimination of the Corporate Property Protection group was known at the time of our evaluation and expression of concern. Also, we agree that prompt correction of identified problems should not necessarily be L__-________ _ _ - _ _ _ _ _ _ _ .

, ~

1 .

,

.

f

.

interpreted as a negative trend. Your correction of the problems was l'

adequate; however, they should have been identified soone With regard to Consumers Power disagreement of how the NRC tabulates !

engineered safety features actuations, we have noted your comments and J have requested that NRR review this matter. We will inform you of the i results of our revie j

l We concur with your actions to enhance performance based audits and look l

'

forward to discussing this matter with your staf l

)

The changes in response to licensee comments for paragraphs A, B, E, I and G appear on the Errata Sheet of this Appendix to the SALP Repor !

I have concluded that the overall ratings in the aff ected areas have not l'

change i l

!

\

- _ - _ _ _ _ _ _

_ _ _ _ _ _ _ _ - . _ _ _ _ _ . -

,

-

. .

3 ,

.

'

Enclosure ERPATA SHEET-PAGE LINE NOW READS SHOULD READ

L ~6 5, 6- ...two engineered ...two diesel li safety system generator actuations (diesel actuation i generatorstarts),

Basis: The Big Rock Point Updated Final Hazards Summary Report does not include the diesel generator as an ESF system. Therefore, the words engineered safety system were remo've , 33, 34 Due to an NRC initiativft, Radioactive the licensee sipped fuel gaseous effluent and removed bad fue releases were This resulted in radio- considerably...

active gaseous effluent releases being consider-ably. . .

"

Basis: .The sipping of fuel and removal of bad fuel was perfortned during the previous SALP assessment period and thus is not applin.ble to this SALP assessment perio , 27, 28 The NRC has concerns that The NRC has concerns the quality assurance that the quality surveillance and audits assurance department are not performance... is conducting a minimum number of surveillance and audits that are performance...

Basis: The original statement regarding performance based inspections was in error. The changed wording recognizes that the QA department does use performance based techniques in their audits and surveillanc l l

!

- _ _ _ _ - _ _ _ .

EtCDSURE 2

,' '

Q & h b r o f-~

-

.;

Operational events increased during this assessment period over l the previour period indicating a decline in performance. There were eight licensee event: reports (LERs) issued that related to plant operations. Six automatic reactor. trips and one manual reactor trip, resulting in two' engineered safety system actuations (diesel generator starts),1 occurred during this assessment period compared with three automatic trips with no engineered afety system actuations in the previous assessment period. Four of the automatic trips occurred early in the

%(% ssment period with the reactor at 0% power. One trip was Nnglerodmotionduringmaintenancetesting,and it e sulted from spurious trips from the 26 year-old WRNM 19514 ,

ation system. Personnel error during switch down- .

rang ng was a contributing factor in one of the three WRNM spurto The WRNM system was replaced with state-o ; e art equipment during the 1988 refueling outage, j The manua I trip was caused by personnel error during grid i synchronization. Two trips occurred late in the assessment period with _ actor at approximately 90% power. One was caused by tur e uipment failure and the. other by an offsite electrical line . In response to the two trips, the licensed operato1 editiously took the correct emergency operating procedu ) actions needed to maintain the plant in a safe condition 4 events were promptly and completel reported. Operato'r4 ~ u' ly made use of procedures and drawings to conduct Vi d rations and were familiar with TS and supporting admifi r ve requirements associated with plant operations. Unit,a ility decreased during this !

assessr..ent period to 75'.4% 9.7% during the previnus assessment period. The dec was not_ indicative of a proble t their assigned duties in a Fire watenmanne professional personnel carrie'('g

%

Staffing for the plant operations ontinues to be excellent. A sufficient number ied licensed and non-licensed individuals were ava y allow for routine shift coverage, training, and outagg 'without excessive use of overtime. Total overtime averaged,.1 M L all operations personnel ouring the assessment period.; Ws tions were clearly identified and authorities and respons1h 11 were well-define Duringthisassessmentperiod,thelicen(ge s ped programs for task analysts of operators, operator goa s t rd continuing l professionalism, and new E0Ps. The fire prove organization was adequately staffed with well qualified personne . There is a full-time safety supervisor, who is a degreed gfire protection specialist and is the safety coordinator and firgbrigade instructo _ _ _ _ _ .

i

.

)

Qym Ercar i activitics, installation of new whole body contamination monitors, and identified the lack of a formal hot particle i program. These efforts were necessery to improve contamination controls and radiation worker practices, j

)

, sponsiveness to NRC initiatives was generally good with some ceptions. In response to NRC Information Notice 88-34, the

>

q'11 see identified and corrected sen-fuel special nuclear asal accountability problems. 'averal previously identified erns relating to whole body contamination monitors, a tgative controls over high radiation area keys, inservice ins 6 tion (ISI) planning and coordination, skin dose calculation met ology, and gamma spectroscopy were adequately addressed durin t the ssment period. However, followup evaluation of a i

persona gination event was relatively weak; the licensee :

was slo mprove control of used protective clotning at  !

contaminatten g ries; and the licensee was lax in maintaining 09j v rs and gloves at frisker station The licensee'sh gpfFpk h to the identification and resolution of radiological 'ttchni issues was generally sound as exhibited by majorg ' s to the RWP system, continued improvements in persp tracking, good hot particle skin i dose assessments, andgre ion of problems with vendor owned shipping casks. A wes1gess 4 v.3 identified concerning the determination of radiol J rotective measures based primarily on previous si i a g job +

The licensee continues to perform 1 in the radiological confirmatory measurements arei w 3 agreements in 59 comparisons. Licensee performance , f e Radiological Environment Monitoring ?rogram was satisfactory - total station dose (about 210 person-rem in 1987 and $60 erson-rem in 1988) has trended downward over the last sever 41 ment periods and l reflects an improved ALARA performanc4b to an NRC initiative, I thelicenseesippedfuelandremovedbaq ~ % This resulted in l radioactive gaseous effluent releases be onkiderably reduced

{

during the assessment period, ref.lecting abs of significant i fuelcladdingproblemswiththecurrentfue qamount and !

activity of liquid radwaste releases remaine( t an'" acceptable j level. Solid radwaste volumes shipped to licensed burial sites l continue to decline as a result of implementingholume reduction l technique %

The staffing levels and qualifications of radiation \ protection personnel were generally adeauate to implement the ro4 tine radiation protection and ALARA programs; experienced coetract l

\ I 3 i

% !

l

I k._______-._ _ _

i

kce, W hkkOk u

-

.

non-conforming materials (Bulletin 88-05). The licensee was l j

very responsive in taking actions to resolve allegations that  !

were turned over by the NRC to the licensee for corrective action .

s konsiteQAgroupplacedemphasisforitssurveillance

!

'

'

tions on those systems with the. highest safety s cance, such as the reactor protection system, post ac e system, RDS, and core spray system. The licensee

'ntr the probabilistic risk concept in the surveillance and i est. ion program during this assessment. period. The concept is based on core damage / release of fission product '

Twoiprveillances performed using this concept were the ISI and RDSvalyete 9. The enhanced performance incentive program was a pesi icensee initiative to control the use of QA resource's,f involving in-line reviews of procedures and maintenanc rs. The first plant group selected for the programwas) ent and control department, because of past outst formar.ce. The program has the approval of NRC regiona ,st . Safety review committees and feedback from.QA/QC acti ntie used to provide critical self-assessments to th o rate management and to improve work activities associated t nt operations. The NRC has concerns that the qualit rance surveillance and audits are not performance based inspg;4@ and may have an inadequate number of hours budgeted to c ' observations of actual work in progres ' d

s Staffing of the licensee's cinsite QA/QC department remair.ed generally stable over the assessmen iod. The staff is composed of technically oriented in is with extensive plant experience who exhibit a good snding of programmatic requirements and exhibit }Agh degree of professionalism. During the asses'een s r d, the site staff was supplemented by corporate person'np C group was deficient in detecting one work error' to rework of the CR05 valve diaphragm '

'

The training and qualification program contri es an adequate understanding of work and adherencetto p ures as indicated by few personnel errors. QA/QC sta rs participated in audits at other company locations and attended ,

meetings to increase their knowledge and understanding '

of the QA/QC proces . Performance Rating f

\.3 The licensee's performance is rated Category 2 in this 3re Because this is a new area, no rating is available from tie l (

previous assessment perio ' Recommendations -

Y

Non Y j

l 19 I

_ _ _ - - - - - - - - - I

u ,

- _. _ _ _ _ _ . -

' '

acwSURE 3

- '

.

,

O /

Operational events increased during this assessment period over i the previous period indicating a decline in performance. There '

were eight. licensee event reports (LERs) issued that related to plant operations.. Six automatic reactor trips and one mar.ual reactor trip, resulting in two diesel generator actuations, occurred during this assessment period compared with three automatic trips with no engineered safety system actuations in the previous assessment period. Four of the automatic trips occurred early in the assessment period with the reactor at 0%

power. One trip was with single rod motion during maintenance testing, and three resulted from spurious trips from tne 26-year-old WRNM instrumentation system. Personnel error during switch down-ranging was a contributing factor in one of the three WRNM spurious trips. The WRNM system was replaced with state-of-the-art equipment during the 1988 refueling outag The manual trip was caused by personnel error during grid synchronization. Two trips occurred late in the assessment-period with the reactor at approximately 90% power. One was caused by turbine equipment failure and the other by an offsite electrical line faul In response to the two trips, the licensed operators ex operating procedureE0P) (peditiously took the actions needed to correct maintainemergency the plant in a safe condition. All events were promptly and completely reported. Operators routinely made use of procedures and drawings to conduct plant operations and were familiar with TS and supporting administrative requirements associated with plant operations. Unit availability decreased during this assessment period to 75.5% from 79.7% during the previous -

assessment period. The decrease was not indicative of a proble Fire watch personnel carried ou, their assigned duties in a professional manne Staffing for the plant operations area continues to be excellent. A sufficient number of qualified licensed and non-licensed individuals were available to allow for routine shift coverage, training, and outage work without excessive use

[

'

of overtime. Total overtime averaged 12% for all operations personnel during the assessment period. Positions were clearly identified and authorities Lad responsibilities were well-define DurIng this assessment period, the licensee developed programs for task analysis of operatcrs, operator goals toward continuing professionalism, and new E0Ps. The fire protection organization war adequately staffed with well-qualiff eo personnel. There is a full-time safety supervisor, uho is a degreed fire protection specialist and is the safety coordinator and fire brigade ( instructor.

i 6 )

_ _ _ _ _ - - .

l

-

, .

,

.

.

activities, installation of new whole body contamination i monitors, and identified the lack of a formal hot particle ;

program. These efforts were necessary to improve contamination !

controls and radiation worker practice Responsiveness to NRC initiatives was generally good with some exceptions. In response to NRC Information Notice 88-34, the licencee identified and corrected non-fuel special nuclear ,

materia'l accountability problems. Several previously identified l NRC concerns relating to whole body contamination monitors, !

administratitre controls over high radiation area keys, inservice l inspection (ISI) planning and coordination, skin dose calculation methodology, and gamma spectroscopy were adequately addressed during the assessment period. However, followup evaluation of a personal contamination event was relatively weak; the licensee was slow to improve control of used protective clothing at contamination boundaries; and the licensee was lax in maintaining shoe covers and gloves at frisker station ,

i The licensee's approach to the identification and resolution of radiological technical issues was generally sound as exhibited by major revisions to the RWP system, continued improvements in personal dose tracking, good hot particle skin dose assessments, and resolution of problems with vendor owned l

shipping casks. A weakness was identified concerning the j determination of radiological protective measures based primarily on previous similar job The licensee continues to perform well in the radiological confirmatory measurements area with 56 agreements in 59 l

comparisons. Licensee performance of the Radiological Environment Monitoring Program was satisfactory. The total station dose (about 210 person-rem in 1987 and 160 person-rem in 1988) has trended downward over the last several assessment periods and reflects an improved ALARA performance. Radioactive gaseous effluent releases were considerably reduced during the assessment period, reflecting the absence of significant fuel cladding problems with the current fuel. The amount and activity of liquid radwaste releases remained at an acceptable level.

,

(

Solid radwaste volumes shipped to licensed burial sites continue to decline as a result of implementing volume reduction technique The staffing levels and qualifications of radiation protection personnel were generally adequate to implement the routine radiation protection and ALARA programs; experienced contract l

l

- _ _ _ _ _ - _ - _ _ _ _ .

- .-

,.

L .

.

non-conforming materials (Bulletin 88-05). The licensee was very responsive in taking actions to resolve allegations that were turned over by the NRC to tne licensee for corrective action The onsite QA group placed emphasis for its surveillance inspections on those systems with the highest safety significance, such as the reactor protection system, post accident system, RDS, and core spray system. The licensee introduced the probabilistic risk concept in the surveillance and inspection program during this assessment period. The concept is based on core damage / release of fissior, product Two surveillance performed using this concept were the ISI and RDS valve testing. The enhanced performance incentive program was a positive licensee initeative to control the use of QA resources for work involving in-line reviews of procedures and maintenance orders. The first plant group selected for the program was the instrument and control department, because of past outstanding performance. The program hcs the approval of NRC regional staff. Safety review committees ard feedback from QA/QC activities were used to provide critical self-assessments i to the corporate management and to improve work act vities associated with plant operations. The NRC has concerns that the quality assurance department is conducting a minimum number of surveillance and audits that are performance based inspections ,

and may have an inadequate number of hours budgeted to do !

observations of actual work in progres '

Staffing of the licensee's onsite QA/QC department remained generally stable over the assessment period. The staff is composed of technically oriented individuals with extensive ;

plant experience who exhibit a good understanding of programmatic requirements and exhibited a high degree of professionalism. During the assessment period, the site staff was supplemented by corporate personnel. The QC group was deficient in detecting one work error that led to rework of the CRDS valve diaphragm The training and qualification program contributes to an adequate understanding of work and adherence to procedures as ir.dicated by few personnel errors. QA/QC staff members participated in audits at other company locations and attended meetings to increase their knowledge and understanding of the QA/QC proces l 2. Performance Rating l The licensee's performance is rated Category 2 in this are l Because this is a new area, no rating is available from the l previous assessment perio ' Recommendations l

Non j

!

_ _

,

ENCEDSURE 4 l l' .

a

.'

Consumers ' )

" om e wo* U power Ykt President Nwlear Operations

% M ERlNG nlKNIGAN'S PROGREK5 General othces- 1945 West Parnall Roed, Jackson MI 49201 t617) 7884463 April 27, 1989

!

46 Nucles.r Regulatory Ccmmission Document Control Desk Washington, DC 20555

.

DOCKET 50-155 - LICENSE DPR-6 - 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 i I

Plant. This letter provides Consumers Power Company's written ecmments regarding that repor Consumers Power Company thr. uke the NRC for the feed'oack on activities at Big Rock Point from the period of September 1, 1987 through December 31, 198 We believe that all of the concerns identified will be addressed very effectivel With regard to r.oncerns 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 actions have made and will make a continued positive contribution toward ,

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 Schedul With regard to the concerns associated with plant age and plant maintenance, we are taking actions which we belie.ve 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 Program in the area of vibration analysis of rotating equipment. In late S

TDC

-

OC0489-0125-NLO4 APR z 8 g

---

_ - _ - _ _ _ _ _ , - _ . ._ _ _ _ - _ - . _ . - - - _

,

'

Nuclear Regulatory Commission Big Rock Point Plant

'

Salp 8 Response April 27, 1989

,

1988, we began to add thermography readings. This information was critical in i helping us decide to perform preventive maintenance on bus bar connections in our switchyard in a recent four day scheduled maintenance outage in Marc 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 vall thinning in secondary systems and our program there is well establishe .

l In 1988, we overhauled one main feedwater pump and motor, one service water i pump and motor, and one circulating water pump and motor, in 1989, we plan to overhaul the remaining service water pump and motor. We are adding vibration monitoring equipment to our recirculation pumps and performing preventive  !

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 activitie j 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 l

'

condensate pumps and our main generator. This will result in the completion

^ of all major rotating equipment overhauls at Big Rock Pcint in the period from 1988 through 199 To accomplish all of the maintenance identified, we have relied primarily upon our plant maintenance staff. We will algo supplement these resources first with our Company's travel repair crews, and occasionally with outside contractors. Our ef f orts 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 Assessmen 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 takgn place to avoid recurrenc !

!

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 30 CFR 55 rule changes dealing with operator training and examinatio Additional comments are provided as follows: 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

_ - - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

- - - - . - - - _ _ _ _ _ _ _ _ _ _

- - , -

' '

Nuclear Regulatory Commission 3

' Big Rock Point Plant 1

, Salp 8. Response April 27, 1989

< q 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  !

logic trips has been elitinated. Consumers Power Company expects this change will significantly reduce the trip rat 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 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 Condscser System

-

Reactor Depressurization System 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 amende Maintenance / Surveillance No additional comment . Emergency Preparedness No comment 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 Department 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 q 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 accountabl Engineering / Technical Support No additional comment OC0489-0125-NLO4

_ - _ _ - _ - - _ _ - - - - - - - -

i q

O -

. ,

,

,

Nuclear Regulatory Commission

p Big Rock Point Plant Salp 8 Response April 27, 1989 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 slic.e" 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 i continue our advancement in the direction of performance based audits and inspection 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 are !

!

Overall, we believe that the Nuclear Regulatory Commission may wish to rethink how it uses and interprets trend data. For example, two items of noncompli- l

!

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 I

j in this SALP period was the identification of these weaknesses and the

,_

immediate corrective action. We would conclude 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 tren l 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 cummitted, as are you, to :

l continue to make Big Rock Point a very safe operatio David P Hoffman (Signed)

David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, USNRC l

NRC Resident Inspector - Big Rock Point Plant k

OC0489-0125-NLO4 i

- - - - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _