ML20150F858

App to SALP 7 Board Rept 50-155/87-01 for Apr 1986 - Aug 1987

ML20150F858
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	03/30/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20150F844	List: ML20150F841 ML20150F858 ML20151A915
References
50-155-87-01, 50-155-87-1, NUDOCS 8804060028
Download: ML20150F858 (4)

See also: IR 05000155/1987001

Text

_ _ _ _

.-___ -___ _ _ -

c.

Enclosure 1

,

,

..

.

APPENDIX

SALP 7

SALP BOARD REPORT

NUCLEAR REGULATORY COMMISSION

.

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE'

50-155/87001

Inspection Report No.

Consumers Power Company

Name of 1.icensee

!

!

Big Rock Point Plant

Name of Facility

i

l

April 1, 1986 through August 31, 1987

!

Assessment Period

(

i

l

l

8804060028 880330

i

PDR

ADOCK 05000155'

L

@

renc.co

-

. .

,.

"

Enclosure 1

.

.

A.

Summary of Meeting with Consumers Power Company on December 21, 1987

The findings and conclusions of the SALP board documented in Inspection

Report No. 50-155/87001 were discussed with the licensee on December 21,

1987, in Charlevoix, Michigan.

The 11censee's regulatory performance

was presented and found acceptable in each fJnctional area.

The following licensee and NRC personnel attended the meeting.

Consumers Power Company

F. Buckman, Vice President Nuclear Operations

G. Slade, Executive Director for Nuclear Assurance

R. Abel, Production and Plant Performance Superintendent

R. Alexander, Technical Engineer

J. Beer, Chemistry / Health Physics Superintendent

M. Sralinski, Senior Engineer

W. Blosh, Maintenance Engineer

G. Boss, A0

T. Hagan, Human Resources Director

C. Macinski, Plant Public Affairs Director

0. Moeggenberg, Engineering Supervisor

G. Petitjean, Planning / Administrative Services Superintendent

E. Reciborski, Scheduling Administrator

R. Schrader, Electrical I&C Engineering Supervisor

W. Trubilowicz, Operations Superintendent

M. Vankist, Property Protection Supervisor

G. Withrow, Engineering Maintenance Superintendent

R. Suchmar, Nuclear Plant Training Administrator

A. 'lrickenberger, Quality Control Supervisor

P. Donnelly, Nuclear Assurance Administrator

L. Monshor, Quality Assurance Superintendent

Ny: lear Regulatory Commission

W. Guldemond, Chief, Reactor Projects Branch 2

I. d. Jackiw, Chief, Reactor Projects Branch 28

S. Guthrie, Senior Resident Inspector

C. Papriello, Deputy Regional Administrator

B.

Comments Rece*ved from Licensee

By let'.er dated January 20, 1988, the licensee provided written comments

on the SALP report in accordance with the forwarding letter.

In regards to the comments relative to Section IV.B., "Radiological

Controls," the staff reviewed the issue of failed fuel and cancelled

inspection on fuel bundles scheduled for return to the reactor core.

Resolution of this concern involved several conference cells to address

2

-

'

'

.

,

Enclosure 1

.

v

the testing necessary to determine that no leaking fuel bundles were

returned to service.

Your eventual ultrasonic testing of fuel bundles

being returned to the core satisfied our concerns in this area. Based

on cur review of the information on gaseous releases, the report will

be corrected to reflect the following:

As a result of continuing fuel cladding problems, radioactive

gaseous releases until March 1987, when the fuel problem was

corrected, continued to be about a factor of 6 higher .

...

In regards to the comments relative to Section IV.C., "Maintenance,"

we accept your comments as they relate to EEQ and Appendix R.

Concerning

the effectiveness of mainte,ance programs at Big Rock Point, the staff

remains concerned that the current level of preventive, predictive, and

corrective maintenance at the facility may be only marginally adequate to

counter the effects of equipment aging and normal plant wear. The staff

encourages you to continue to emphasize your preventive and predictive

maintenance effort toward the goal of enhanced plant safety through such

activities as pump overhauls.

In regards to the comments relative to Section IV.D., "Surveillance,"

the staff scknowledges your clarification of the status of the battery

service test. The inaccuracy in Paragraph 3 has been deleted from the

SALP report. The following statement has been deleted:

One surveillance on the station battery was not performed while

the requirement for its performance was under review by NRR.

In regards to the comments relative to Section IV.K., "Training and

Qualificatior. Effectiveness," the staff appreciates the additional data

you provided to describe the improvements made in upgrading the skills of

the mechanical / electrical maintenance staff.

Based on our review of that

information the report will be amended to reflect the following:

Skills training was generally conducted on schedule with only minimal

impact from plant operations.

Significant increase in training man-days were in evidence when

compared to the training effort during the previous assessment period.

The staff continues to regard skill training and worker protection training

to be of a general nature and not sufficiently nuclear plant specific to

be of immediate benefit in upgrading the effectiveness of the newest

members of the mechanical / electrical maintenance staff. A review of the

CPC0 Training Records System Employee Training Report updated through

January 4, 1988, for the five mcst recent additions to the maintenance

staff indicate that the training provided these individuals during the

assessment period heavily emphasized worker safety.

Examples include the

3

_ _ _ _ _

_

_ _______________________ _ _ _

- _ _ -

• *

'

Enclosure 1

-

.

,

.

.

l

confined spaces and fire brigade training, protective tagging procedures,

asbestos control, and respirator use.

During the last month of the

assessment period, the individual's course work began to emphasize general

skills through training courses emphasizing introduction to valves,

introduction to blue prints, hand tools, power tools, electrical math, and

basic DC electricity.

Big Rock Point System training for these and other

individuals commenced August 17, 1987, two weeks prior to the close of

the assessment period.

In regards to the comments relative to Section IV.E., "Fire Protection,"

Section IV.G., Security,Section IV.K., Licensing Activities, we

acknowledge your comments and these facts will be factored into the

SALP 8 assessment period.

C.

Regional Administrator's Conclusions Based on Consideration of

Licensee Comments

Based on my review of the comments provided by the licensee, I have

concluded that the overall ratings in the affected areas have not

changed. Actions identified in the letter of response to SALP 7 dated

January 20, 1988 will be factored into future Region III inspections.

>

l

r

'

4

-

.

.

_

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

_ _ _ , _ _ _ _ _ _

_ _ . . _ .

- _ _ - _ _

l

3

e

a

Ehc\\aSocc, 8

,.

.

l

l

l

.

Consum8Is

POW 8r

Fr.a. rick w sockm.n

Srmor Vue Pressdent

POWERING

Ewty Supply

MICNIGAN'S PROGRE55

Generst Omces 1945 West Parnell Road. Jackson. MI 49201 e (517) 7881217

January 20, 1988

Nuclear Regulatory Commission

Document Control Desk

Washington, DC 20555

DOCKET 50-155 - LICENSE DPR-6 - BIG ROCK POINT PLANT -

SALP 7 REPORT C0KKENTS

Consumers Power Company appreciates NRC effort in assessing the nerformance of

Big Rock Point during the SALP 7 period. Of special note was Mr. Paperiello

and the SALP Board holding the presentation in Charlevoix, Michigan, which

permitted an increased attendance of Consumers Power Company personnel responsi-

ble for the operation of Big Rock Point. The direct communication was a

valuable part of the overall SALP process, and it will assist us in planning

future strategies and activities to achieve excellence in performance.

Following the presentation and review of the SALP 7 Report, Consumers Power

Company provides the following com=cr.ts.

A. Plant Operations

No Co= cents.

B. Radiological Controls

4

Unresponsiveness to NRC initiatives and concerns for fuel inspections was

never our intent. Only after carefully examining previous cycles' fuel

failures, current indicators, and personnel doses was the decision made not

to inspect fuel. We were confident that the fuel causing the failures was

being discharged and not used in Cycle 22.

In the spirit of ALARA, the

possibility was great for receiving more dose from fuel inspections than

the fuel failures we had been experiencing. Results of ultrasonic inspections

and next cycle performance substantiated our original evaluation that all

leaker bundles were discharged. Paragraph six (6) of this section incorrectly

4

refers to "... gaseous releases... continued to be about a factor of 6 higher

than normal." After the Cycle 22 Refueling Outage (March, 1987) gaseous

release rate was restored to normal and currently no leaking fuel is

evident.

It is true that a water chemistry control program based on BWR Ovners Group

Guidelines was not formalized, however, virtually every chemistry parameter

is within these guidelines and we feel confident that plant management

would take the appropriate measures if these parameters were above the

OC0188-0016-NLO2

[ p/

UAN22 088

9@t v

/ +' '

1(

"

mglhenarwuwn

<'

- --

_ _ _ _ _ _ _ _ .

-

. .

,.

.

Nuclear Regulatory Commission

2

Big Rock Point Plant

? ALP 7 Report Comments

,

January 20, 1988

"action levels" of the guidelines even though they were not procedura11 zed.

The applicable guidelines will be incorporated into plant procedures over

the next procedure review cycle.

We note NRC concerns and have implemented improvements in the ALARA and

Radiation Work Permit programs and frisking equipment / practices since the

assessment, and will continue efforts to further reduce dose and contamin-

ation incidents.

C. Maintenance

Consumers Power Company utilized extensive resources in establishing a

"good f aith" ef fort in complying with the EEQ and Appendix R regulations.

However, both the EEQ and Appendix R efforts evolved over a very long time

period allowing program managers, both Consumers Power Company and NRC, to

change during program development and compliance rTriew. Decisions or

compliance interpretations agreed upon at one stage have been changed or

modified by individuals involved at later time periods. Consumers Povet

Company originally was involved in EEQ since 1975, with a LOCA task force,

followed with the RDS Modifications, and with the Systematic Evaluation

,

Program in the late seventies. Implementation Inspections did not commence

until 1986. We believe this contributed to the EEQ issues dealing with

MO-7068 and Polyethylene and Butyl rubber cables. Consumers Power Company

still believes that M0-7068 and the cables were capable of performing their

safety function, however, we agreed to replace the components rather than

continuing to debate the issues.

Big Rock Point continues to have an effective maintenance performance

history as evidenced by historical plant availability and number of forced

outages. Reactor trips from power have been minimal and the plant material

condition has been noted as very good by the NRC, INPO, and Insurance

Inspectors. During this SALP period Big Rock Point initiated and recently

completed a Maintenance Self-Assessment utilizing INPO guidelines.

Throughout the next SALP period we will be implementing changes in our

Maintenance Programs to improve the high priority areas identified in the

self-assessment. These will further strengthen our maintenance performance.

In addition, several major pump and motor overhauls are planned for the

upcoming refueling outage. The main feedvater pumps, turbine / generator,

and a service water pump have been completed in the recent past. Over the

next few years, two to three major pump overhauls per year are planned.

Big Rock Point will continue to monitor equipment performance and industry

maintenance practices toward enhancing existing Maintenance programs.

D. Surveillance

One inaccuracy existed in paragraph 3 of this section with regard to not

performing a surveillance test (Service Test) on the station battery. A

Technical Specification Change Request submittal dated December 22, 1986,

which is still under NRR review, modified the Service Test design time

interval to resolve errors as described in LER 86-004. Consumers Power

OC0188-0016-NLO2

__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

,.

Nucicar Rsgulatory Ccmmission

3

Big Rock Point Plant

SALP 7 Report Comments

'

January 20, 1988

Company agreed to impleaent this proposal into testing scheduled for the

1987 Refueling Outage. The modified surveillance test was completed

satisfactorily during the outage.

E. Fire Protection

The NRC concern on lack of plant staff Appendix R understanding is related

to the duration of the review and implementation. As discussed above in

Section C, the effort extended over a long time period (approximately

1978-1986).

Because of the long time interval the need existed for several

technical-level meetings with staff and consultant personnel to revice

extensive submittals to understand the safe shutdown paths for Big Rock

Point in complying with the Appendix R requirements. Although further NRR

review was needed and one additional exemption was required, overall the

post-fire safe shutdown methods met the requirements for Appendix R.

Since

the inspection, documentation has been improved and fire plans strengthened

to enhance the capability of Big Rock Point to mitigate the effects of a

plant fire.

F. Emergency Preparedness

,

No coc=ents.

G. Security

In response to NRC concerns regarding equipment aging, the 1987 CCTV

Upgrade Project was completed by year-end. Existing equipment was repaired,

cleaned or replaced. Two additional CCTV cameras and new lights were

installed and some existing lights were repositioned. A new metal detector

and X-ray machine were purchased for installation in the Lobby of the

Security Building.

In response to NRC concerns regarding an increase in personnel errors,

several methods of monitoring personnel performance have been initiated in

an effort to identify exceptional as well as weak performance. These

methods allow trending errors and pinpointing the causes. Each First

Lieutenant on shift is now committed to evaluating his shift personnel on a

weekly basis and documenting the results on a "Personnel Evaluation Form."

They are committed to one planned and one unplanned evaluation each week.

Drills are conducted twice per month on each shift using adopted scenarios

for contingencies.

Individuals with recurring performance problems are

retrained when needed and counseled or disciplined when applicable.

A new method of reviewing Logs has been established to track documentation

errors. This will ensure that proper logging is being accomplished.

A full review of all site security manuals and routine job information

sheets is being implemented to improve performance in the Security area.

,

OC0188-0016-NLO2

.

.-

'

Nuc1 Gar Regulatcry Commission

4

Big Rock Point Plant

SALP 7 Report Comments

January 20, 1988

.

H. Outages

No comments.

I, Quality Programs and Administrative Controls Affecting Quality

No comments.

J. Training and Qualification Effectiveness

Training and Qualification Effectiveness was evaluated as a category 2 - a

rating judged equivalent in performance to the previous assessment period

which at that time had received a category 1 rating. While we do not take

issue with the lowering of a previously assessed category, a review of the

training results completed during this SALP period leads us to conclude

training warrants a category 1 assessment.

In response to the statement "While employees received some general worker

training and on-the-job instruction, management made little progress in

upgrading the mechanical / electrical staff's skill levels, a condition noted

,

in the previous assessment period" on page 10 under maintenance summary; we

believe that maintenance training has been aggressively pursued. We have

doubled the training time per repairworker from SALP 6 to SALP 7.

During

the SALP 7 period, we provided 443 student days of Mechanical / Electrical

skills training and 108 student days of Safety training. This is a signif-

icant investment of time dedicated for upgrading the skills of a maintenance

staff of 14 repairmen. All of this instruction time was dedicated to

strengthening the skills of our maintenance staff. This represents an

investment of 13% of the repairmen's time for training.

We do not concur with the statement "Skill training that was scheduled

during the assessment period was frequently cancelled because of plant

activities..." on page 22 under the training summary. Our records indicate

that there were no cancellations. There vae some rescheduling of courses,

but all courses originally scheduled were eventually completed.

The

percentage of courses required to be rescheduled was relatively low at 7.6%

for the entire SALP 7 period, and was due to unforeseen plant outages.

Also, on page 22 of the training suc=ary, further clarification is in order

in response to the statement "Skill training and worker protection training

was too general, not nuclear plant specific, and did little to enhance the

effectiveness of the maintenance stafi".

Skills training is not always

required to be nuclear plant specific, however during the period, 121

student days of Big Rock Point specific training was provided to the

maintenance staff.

It should also be noted that all of the tasks required

of the Maintenance repairmen were addressed via classroom training,

on-the-job training, and shop practices during the SALP 7 period. During

the SALP 7 peried, a major effort was made to modify training materials to

assure that all tasks were addressed as identified on the Big Rock Point

Plant Specific Task List.

It is recognized that additional systems training

is necessary for improved worker understanding and performance. At the end

OC0188-0016-NLO2

.

__

.-

,.

,

.

Nuclear Regulatory Commission

5

Big Rock Point Plant

SALP 7 Report Comments

.

January 20, 1988

2

of the SALP period the second round of systems training was started for the

least senior repairworkers at the plant.

Finally, on page 22, the statement "The Procedural requirements for both

required and on-the-job training were not met and the Maintenance Depart-

ment Training Program has not been evaluated and accredited by INP0" is

somewhat misleading.

INP0 evaluation and accreditation was not planned to

occur during this SALP period. The INPO evaluation was conducted in

October 1987 and after the fourteen man team completed their evaluation

they. proposed zero recom=endations in maintenance training.

INFO considered

the program to be very good and stated our program demonstrated a strong

commitment by the plant. Essentially all of the procedural requirements

for classroom and OJT were complete and in place prior to the end of the

SALP 7 period. Formal INPO Board approval is tentatively scheduled to

occur in the first quarter 1988.

We also reiterate the fact that initial or replacement license candidate

,

and requalification license candidate classes both achieved a 100% pass

rate during the SALP period. This is the sixth license class to achieve a

100% pass rate.

It is a ree-r' we are very proud of and speaks for itself

s to the caliber of Big Roo 'oint training.

We believe the above results demonstrate that management commitment to

training is evident to assure that our training provides the skills and

knowledge necessary to continue to operate Big Rock Point as a safe and

reliable plant. We also believe : hat the training results completed during

the SALP 7 period supports a Category 1 assessment.

K. Licensing Activities

Consumers Power Company Management and staff will continue to support and

utilize the Integrated Living Schedule (ILS) in accordance with License

requirements to evaluate and prioritize workload. We also plan on working

with Region III personnel in the near term, on exploring ways to use the

ILS process in prioritizing inspection based plant betterments.

Consumers Power Company understands that high quality and timely licensing

documents are essential in maintaining a sound licensing basis for Big Rock

Point and continue to support this objective. Corporate and plant licensing

,

personnel will continue to advocate frequent meetings with NRR and Region

personnel to understand and prioritize issues from both a NRC and Consumers

Power Company perspective. Our goal will be to recognize unique or complex

technical issues and ensure that related submittals are timely with suf-

ficient detail to minimize interaction.

OC0188-0016-NLO2

__

-- .

.

.

.

-

.

,.

.

Nuclear Regulctory Commissien

6

Big Rock Point Plant

SALP 7 Report Comments

'

January 20, 1988

Consumers Power Company believes the overs 11 SALP evaluation presented a

balanced assessment of plant performance during the appraisal period. The

issue concerning resource allocation that was raised in the SALP report is one

to which we vill remain sensitive, but Consumers Power Company strongly

believes that management commitment to excellence cannot be measured by the

amount of money spent on a plant. We will continue to work closely with the

NRC staff in communicating the establishment of priorities and schedults for

action to improve plant safety and performance.

Frederick W Buckman (Signed)

Frede' tick W Buckman

Senior Vice President

Energy Supply

CC At-inistrator, Region III, NRC

,

,

NRC Resident Inspector - Big Rock Point

l

l

,

l

I

1

!

i

l

l

l

. .0188-0016-NLO2

-

-- -

-

-

.