ML20236C267

SALP Rept 50-155/89-01 for Sept 1987 - Dec 1988

ML20236C267
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/31/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236C258	List: ML20236C254 ML20236C267
References
50-155-89-01, 50-155-89-1, NUDOCS 8903220049
Download: ML20236C267 (26)

See also: IR 05000155/1989001

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SALP'8'

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SALP BOARD REPORT

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U.S. NUCLEAR REGULATORY' COMMISSION 1

REGION III

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SYSTEMATIC ASSESSMENT OF LICENSEE ~ PERFORMANCE.

50-155/89001

Inspection Report:No. I

Consumers Power Company

Name of Licensee.

Big Rock Point

Name of Facility

September 1, 1987, through December 31, 1988 I

Assessment Period. l

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TABLE OF CONTENTS-  !

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I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . .1 i

II. S UMMARY O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . 2

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A. Overview . . . . . . . . . . ............. 2 l

B. Other Areas of Interest . .............. 2

III. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . 3  !

'IV. PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . .- 5

A. Plant' Operations . . . . . . . . . . . . . . . . . . . . 5-

B. Radiological Controls . . . . . . . . . . ..-. . . . . . 7

C. Maintenance / Surveillance . . . . . . . . . . . . . . . . 9

D. Emergency Preparedness . . . . . . . . . . . . . . . . . 12

E. Security . . . . . . . . . . .............. 13-  !

F. Engineering / Technical Support . ............ 15'

G. Safety Assessment / Quality Verification . . . . . . . . . - 17 -

V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . . 20

A. Licensee Activities . . . . . . . . . . ......... 20

B. Inspection Activities . . . ................ 21 ,

C. Escalated Enforcement Actions . . . . . ......... 22

0. Co'nfirmatory Action Letters (CALs) . . . . . . . . . . . 23

E. License Amendments Issued . . . ............ 23 -)

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F. Review of Licensee Event Reports. Submitted l

by the Li cen see . . . . . . . . . . . . . . . ..... 23

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I. INTRODUCTION l

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The Systematic Assessment of Licensee Performance (SALP) program is an  :

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integrated NRC. staff effort to collect available observations land data l

on a periodic basis and to evaluate licensee performance on the~ basis- a;

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of this-information. The program is supplemental, to normal regulatory j

processes used to ensure compliance with NRC rufes and regulations. SALP

is intended to be sufficiently diagnostic to provide a rational basis for ' ,

allocating NRC resources and to provide meaningful feedback to the licensee's j

management regarding the NRC's assessment of.their facility's-performan'ce q

in each functional area.

An NRC SALP Board, composed 'of the staff members listed below, met on  ;

~ February 24, 1989, to review'the observations and data on performance, and  !

to assess licensee performance in accordance with the guidance in NRC .. 1

Manual Chapter 0516, " Systematic Asser,sment of Licensee Performance." .The

guidance an,d' evaluation criteria are summarized in Section III of this + 3

report. The Board's findings and: recommendations were forwarded to the l

NRC Regional / Administrator for approval and issuance. , ,

This report is the NRC's assessment of the licensee's safety performance 1

at Big Rock Point for the period September 1,'1987, through December 31, 1988. '

SALP Board for Big Rock Point was composed of; [ i

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• C. E. Norelius SALP Board Chairman, Director, Division of Radiation - l

Safety and Safeguards (DRSS)  !

• H. J. Miller Director, Division of Reactor Safety (DRS) l

• W. L. Forney Deputy Director, Division.of Reactor Projects j

• T. R. Quay Acting Project' Director, Office of Nuclear Reactor

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Regulation (NRR)- j

• W. L. Axelson Chief, Reactor Branch 2, DRP l'

I. N. Jackiw Chief, Reactor Projects Section 2B, DRP

W. G. Snell Chief, Emergency Preparedness and Effluents Section  !

• W. E. Scott Project Manager, NRR 1

• E. A. Plettner Senior Resident Inspector

J. P. Patterson Emergency Preparedness Specialist, DRSS

J. R. Kniceley Security Specialist, DRSS

D. E. Miller Senior Radiation Specialist, DRSS ;I

M. A. Kunowski Radiation Specialist, DRSS j

A. Dunlop Reactor Engineer, Technical Support Staff '

M. P. Huber Reactor Inspector, DRS i

N. R. Williamsen Resident Inspector  ;

D. L. Schrum Project Engineer, Section 2B, DRP  !

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• Denotes voting members

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II. SUMMARY OF RESULTS

,. A. Overview

Management continued to demonstrate a high degree of personal

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involvement in overall plant operation and quality programs; it has

been aggressive and proactive in response to NRC safety concerns and

in the support of quality improvement-initiatives. The effectiveness

of improvement initiatives was demonstrated during the last half of

the assessment period, especially in improved plant operations and 1

in a reduction of reportable events. However, the number-of reactor

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trips attributed to equipment and personnel errors remained high.

Management's continued support of an open communication environment )

and' staff training was evident. Staffing was viewed as.a utility

strength; licensee personnel are responsible and forthright in

identifying and resolving problems and display a positive safety

attitude. Weaknesses were noted in the areas of maintenance,

engineering / technical support and safety assessment / quality.

verification. Maintenance related weakne'sses include the performance

of the traveling maintenance crews, and the large number of equipment l

failures causing forced outages. These. problems may be the result

of plant aging and the lack of an aggressive prevention maintenance

program. The engineering / technical support weakness is the lack' of ,

critical performance requirements in the original design basis j

information particularly as this is needed in replacement of i

outmoded parts. The safety assessment / quality verification I

weaknesses are the timeliness'of completion of certain significant. I

technical issues, resource allocations, and some non-conservative

decisions. The licensee performance was generally good and

continued to show overall improvement, and was a good performer. l

As an example, emergency preparedness improved to a Category 1 as I

a result of improved training, an independent audit program, and

excellent interface with offsite emergency response officials, )

The performance ratings during the previous assessment period and

this assessment period according to functional area are given

below:

Rating Last Rating This

Functional Area Period period Trend  !

Plant Operations 1 1

Radiological Controls 2 2

Maintenance / Surveillance 2/1 2 3

Emergency Preparedness 2 1 1

Security 2 2

Engineering / Technical Support

Safety Assessment / Quality

NR 2  !

Verification NR 2 ,

NR - Not Rated

B. Other Areas of Interest

None

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III. CRITERIA

Licensee performance is assessed in selected functional areas. Functional

areas normally represent areas significant to nuclear safety and the

environment. Some functional areas may not be assessed because of little

or no licensee activities or lack of meaningful observations. Special

areas may be addcd to highlight significant observations.

The following evaluation criteria were used to assess each functional

area:

1. Assurance of quality, including management involvement and control;

2. Approach to the resolution of technical issues from a safety

standpoint;

3. Responsiveness to NRC initiatives;

4. Enforcement history;

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5. Operational events (including response to, analyses of, reporting

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of, and corrective actions for);

6. Staffing (including management); and

7. Effectiveness of training and qualification program.

However, the NRC is not limited to these criteria and others may have

been used where appropriate.

On the basis of the NRC assessment, each functional area evaluated is

rated according to three performance categories. The definitions of

these performance categories are as follows:

Category 1: Licensee management attention and involvement are readily

evident and place emphasis on superior performance of nuclear safety or

safeguards activities, with the resulting performance substantially

exceeding regulatory requirements. Licensee resources are ample and

effectively used so that a high level of plant and personnel performance

is being achieved. Reduced NRC attention may be appropriate.

Category 2: Licensee management attention to and involvement in the

performance of nuclear safety or safeguards activities are good. The

licensee has attained a level of performance above that needed to meet

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regulatory requirements. Licensee resources are adequate and reasonably

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allocated so that good plant and personnel performance is being

achieved. NRC attention may be maintained at normal levels.

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Category 3: Licensee management attention to and involvement in the

performance of nuclear safety or safeguards activities are not

sufficient. The licensee's performance does not significantly exceed

that needed to meet minimal regulatory requirements. Licensee resources

appear to be strained or not effectively used. NRC attention should be

increased above normal levels.

The SALP report may include an appraisal of the performance trend in a

functional area for use as a predictive indicator if near-term performance

is of interest. Licensee performance during the last quarter of the

assessment period should be examined to determine whether a trend exists.

Normally, this performance trend should only be used if both a definite

trend is discernable and continuation of the trend may result in a change

in performance rating.

The trend, if used, is defined as: l

Improving: Licensee performance was determined to be improving near the

close of the assessment period.

Declining: Licensee performance was determined to be declining near the

close of the assessment period, and the licensee had'not taken meaningful

steps to address this pattern.

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'IV. PERFORMANCE ANALYSIS '

A. Plant Operations-

1. Analysis

Evaluation of this functional. area was based on the results of

ten. routine inspections by the resident inspectors.

The enforcement history in this area identifie.1 no violations.

This was an improvement over. the previous assessment period 1

in which two Severity Level IV violations were identified. I

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Management invcivement in this area was excellent. The licensee j

benefits from shift supervisors and line manag'ars who are

knowledgeable in the history ;and operating c,heracteristics of j

the facility. These managers.are generally involved in  !

both routine and off-normal operational activities. There was' ]

constant evidence of prior planning and assignment'of priorities, i

Procedures for control of activities were well-stated, j

controlled, and explicit. Senior sito management personnel were. q

often present in the control room, communicated regularly with j

the shift supervisor during 'all shif ts, ano toured the. plant on i

a regular basis. Management's presence and involvement

contributed to the generally high level of housekeeping ..

throughout the facility. Corporate n.anagement'has frequently j

and effectively been involved in site activities and'has been

onsite at least once a quarter. The safety review committees

were adequately involved in reviewing and approving charges to

operational procedures on a regular and emergency basis, q

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The licensee's response to the resolution of technical issues {

from a safety standpoint demonstrated a clear understanding 1

of the issues. Examples were the reducticn in power to fix the ]

unidentified leak rate before it reached Technical Spec,1fication

(TS) limits and the installation of a ,iumper in the source range

monitor to maintain a required interlock in the rod block

system. Additionally, the licensee exhibited their conservative

operating philosophy when the plant was placed in a safe condition

after steam was detected in the steam tunnel, which turned out to I

be a leak in the feed water heat exchanger. '

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l The licensee's responsivcnass to the resident inspectors initiatives

and policies were timely and effective as demonstrated in the

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evaluation of using a control copy to repair a flange steam.

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leak, the placement of controlled procedures at applicable work

stations in lieu of operators carrying procedures stamped

working only copy, and evaluating potential generic concerns.

identified at other sites. The licensee consistently met

expectations with regard to schedule'and content.

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Operational events increased.during this assessment period over

the previous period indicating a decline in~ performance. .There

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were eight licensee event reports (t.ERs) issued that related to

plant operations. Six automatic, reactor trips and one manual

reactor- trip, resulting in two. engineered safety system .

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actuations (diesel generator starts), occurred during this

assessment period compared with three automatic trips with no . '!

engineered safety. system actuations in the previous assessment

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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 the-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 outage.

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 fault. In response to the two trips, the

licensed operators expeditiously took the correct emergency

operating procedure (EOP) actions needed to maintain the plant

in a safe condition. All events were promptly- and completely 4

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 problem.

Fire watch personnel carried out their assigned duties in a

professional manner.

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 and responsibilities were well-defined. .

During this assessment period, the licensee developed programs: 'l

for task analysis of operators, operator goals toward continuing-

professionalism, and'new E0Ps. The fire protection. organization

was adequately staffed with well qualified personnel. There is

a full-time safety supervisor, who is a dagreed fire protection

specialist and is the safety coordinator and. fire brigade-

instructor.

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Training and qualification programs made a positive contribution

to the understanding of work and adherence to procedures as

indicsted by the' low number of personnel errors, lhe licensee'

adequately satisfied the requirement of training operators on a

simulator by the use of another f acility's simulator. Three

replacement exams were administered during the assessment period

with a one passing. This was a decrease from the previous ..

period. Additional discussions are in:the- Engineering / Technical

Support area of this report. Two training ~ positions were

created and filled during the assessment period. One of the

positions is filled by rotating shift supervisors through the

position on an annual basis. The second position was created to

assiht operations in the job task analysis program. The additional

dedicated resources provided a means of feedback to the operator-

licensing training program from experienced personnel. Two

operations personnel with licenses were. attending college on a

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part-time basis during this assessment period. However, the~

licensee has no formal degree program for licensed operators.

2. performance Rating

The licensee's performance is rated Category 1 in this area.

The licensee's performance was rated Category 1 in the previous

assessment period.

3 .. Recommendations

None.

B. Radiological Controls

1. Analysis

Evaluation of this functional area was based on the results

of four routine inspections by regional inspectors and

ten inspections by resident inspectors.

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The enforcement history in this area during this period

showed improvement with no violations when compared with

one Severity Level IV violation in the previous period.

Management involvement in ensuring quality was good and had

improved since the previous assessment period. -The radiation

work permit (RWP) and as low as reasonably achievable (ALARA)

programs were strengthened and included the' formation of an

ALARA Committee. With NRC prompting, an extensive decontamination

program was performed in the plant after. many cases of personnel

contamination werc detected by the new whole body contamination

monitors. Self-assessment of the radiation protection program

resulted in increaseo oversight of reactor deck refueling

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activities, installation of new whole body contamination

monitors, and identified th'e lack of a formal hot. particle ]

program. .These efforts were necessary to improve contamination )

controls and radiation worker' practices.

Responsiveness to NRC. initiatives was generally good.with some .

exceptions. In response.to NRC.Information Notice 88-34,;the I

licensee identified and corrected non-fuel special nuclear I

material accountability proolems. Several-previously identified . j

NRC concerns relating to whole body. contamination monitors,. 1

administrative controls'over high radiation area. keys, inservice l

inspection (ISI) planningiand-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 l

maintaining shoe covers and gloves at frisker stations. 1

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

, hipping casks. A weakness was identified concerning the- ,

determination of radiological protective measures based

primarily on previous similar jobs.

The licensee continues.to perform'well in the radiological

confirmatory measurements area with 56 agreements in 59

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 dcwnward over the last several assessment periods and

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reflects an improved ALARA performance. Due to an NRC initiative,

the licensee sipped fuel and removed bad fuel. LThis resulted in

radioactive gaseous effluent releases being' considerably reduced -

during the assessment period, reflecting the absence of.significant

fuel cladding problems with the current fuel. The amount and

l activity cf liquid radwaste releases remained at an acceptable

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level, Solid radwaste volumes-shipped to-licensed burial sites

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continue to decline as a result of implementing volume reduction

techniques.

The staffing levtis and qualifications of radiation protection

personnel were generally adequate to implement the routine

radiation protection and ALARA programs; experienced contract

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technicians supplemented the chemistry / health ' physics (C/HP)

staff during refueling. Three C/HP technicians were

expeditiously replaced during the early and middle stages of the

assessment period. Contract personnel were hired as needed to

supplement the-work force. The staffing was increased and

stabilized later in the period with no identified adverse

effects.

The training' program was good with some exceptions. The C/HP

, technician training program was accredited by the Institute of

Nuclear Power Operations (INPO) in February 1988. The licensee

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conducted an ALARA engineering course and observation training

for plant supervision with emphasis on radiation protection

practices. Weaknesses-were noted that related to tracking and

scheduling of advanced radiation worker's training and

documentation of respiratory prote'ction qualification.

2. Performance Rating

The licensee's performance is rated Category 2 in this area. q

l The licensee's performance was rated Category 2 in the previous

assessment period.

3. Recommendations

None.

C. Maintenance / Surveillance

1. Analysi s

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Evaluation of this functional area was based on the results'of

i ten routine inspections performed by the. resident inspectors and

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six routine inspections by regional inspectors. Maintenance and

surveillance were separate functional areas in the previous

assessment period but have been combined as one functional area

for this assessment period.

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The enforcement history in this area has declined from the i

previous assessment period when there were no violations in

either the maintenance or surveillance area. Three F.i " J ty

Level IV violations were identified during this. assess.....c

period. The major causes of the violations were inadaquate or

lack of procedures for performing maintenance activities.

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Management involvement'and program effectiveness have been

evident during plant outages and refueling. activities. Major

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tasks have been well planned and implemented, as have

l continuing plant improvement programs. Three major tasks

completed during the 1988 refueling outage were the replacement /

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upgrade of.the WRNM instrumentation system; the testing,

l refurbishing, and modification of the RDS valves; and the

replacement of 64 control rod drive scram (CRDS) valve

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diaphragms. Problems were encountered in all three tasks that

required additional management attention. The problems with

the WRNM will be discussed in the Engineering / Technical Support

section of this report. The problems with the RDS valves were

identified during full stroke testing. After, substantial

questioning by the NRC staff, the remaining valves were

tested. Subsequently, all four valves were refurbished,

modifications were initiated to improve the design, the valves

were retested, and a TS amendment was initiated to full

stroke test the valve every refueling outage. The CRDS valve

diaphragm problem was identified during post-maintenance testing

and resulted in complete rework of the project. The field

maintenance teams used mostly during outages did not perform

maintenance up to the standards of the regular plant maintenance

personnel. In the case of CRDS valve diaphragm, the initial

work practices used were inadequate. Site quality control did

not detect the errors during maintenance. Field maintenance

team performance continues to be an area of concern to the NRC.

Resolution of technical issu'es was viable, generally sound,

and thorough during this assessment period. Occasionally,

problems recur before they are effectively resolved, as

demonstrated in the CRDS valve problems and neutron monitoring

system. .

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l The licensee was responsive to NRC concerns with the

maintenance program and identified and corrected programmatic

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and procedural deficiencies in the maintenance area. During

this assessment period, the licensee made a management change l

in the Engineering / Maintenance Department to create separate

Engineering and Maintenance Departments. The change enabled

the new superintendent of maintenance to devote his full time

to maintenance activities. The licensee created a six-member

team to write new procedures for maintenance personnel and to

upgrade the format of existing procedures. Due to an NRC

initiative, a root-cause analysis program was developed and is

undergoing a trial implementation period before its final

formatting and approval. These changes occurred late in the

assessment period, making it difficult to assess the impact. A

self-assessment in the maintenance area was performed during

the assessment period. The licensee has committed its limited

resources to resolving the issues of planning and scheduling,

writing additional procedures, and improving maintenance tool

and equipment control in an expeditious manner.

Maintenance and surveillance events accounted for three LERs

during this assessment period. Maintenance and surveillance

work on safety and safety-related systems and components were

in most cases well planned and professionally performed with

detailed instructions, drawings, and procedures being used at

the job site. The work and post-maintenance testing performed

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were well-documented.' 'Except for the CRDS diaphragm problem a

small amount of rework was indicative of an effective maintenance

program. Corrective action may not be effective in correcting g

the root-cause of the problem as. indicated by: occasional j

repetition of events, such as problems with the steam admission 4

valves and the source range neutron monitor. ~I

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There has been a significant reduction in.the: plant equipment

work request (WR) backlog. The WR backlog had-averaged

approximately 180 items at the~ start of the assessment period l

and had decreased to'approximately 90 at.the end of the assessment- )

period. A minimal number of preventive maintenance (PM). items- I'

required deferral during the assessment period. Improvements

continue.in the PM program from.the: previous' assessment periods

with the increased use of predictive analysis (using vibration

and temperature monitoring)_on a variety of equipment. However,.

the large number of forced outages due to equipment failures may

indicate that a more aggressive PM program is needed. Plant

aging is an area of concern to the'NRC and may require more of

the licensee's resources particularly as the' plant ages.

The water chemistry appeared to be under good control as

demonstrated by the licensee's trend charts of the various

parameters. Although the laboratory had a technician

performance testing program and used performance checks on the 4

analyses, the Quality Assurance / Quality Control (QA/QC) program

for analytical measurements was weak. The-licensee's staff made

only limited use of.QC charts and these were without t

statistically-derived control parameters. The licensee is 1

correcting these weaknesses. The -laboratory facilities, including '

space and instrumentation, were adequate for monitoring the

chemistry parameters. The results of the nor radiological

confirmatory measurements program were good. The licensee had

11 of 13 initial comparisons in agreement (85%). The disagreements

appeared to be due mainly to problems in reading a calibration

curve accurately on a graph. The licensee is extensively

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modifying the chemistry procedures to bring the water ~ chemistry

program into conformance.with the Electric Power Research i

Institute Boiling Water Reactor Owners Guidelines. Further,

licensee representatives agreed to document-the variance between ,

their practices and these guidelines, j

The licensee maintains a well-trained and qualified maintenance,

surveillance, and chemistry staff. During outages,~ additional'

company maintenance crews are utilized to assist. plant personnel.

The maintenance training program received accreditation by

INPO in February 1988. To enhance the training' effort, the

maintenance trainer position was changed.to report to'the Big

Rock Point training supervisor rather than the Bay City

supervinor. Increased attention to career. plans was implemented

for all maintenance personnel, including repairme'n and

technicians. Additional schools were provided to increase

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individuals' skills and knowledge levels. This was a weakness

identified in previous assessment periods.

2. Performance Rating

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The licensee's performance is rated Catego y 2 in this area.

The licensee's performance was rated Category 2 in Maintenance

and was rated Category 1 in Surveillance in the previous

assessment' period.

3. Recomme.idations  :

None.

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D Emergency Preparedness j

1. Analysis

Evaluation of this functional area was based on the results of

two routine inspections and one annual emergency preparedness

(EP) exercise.

The enforcement history in this area did not identify any

violations in either of the two routine inspections.

Two Severity Level IV violations in this area were identified

during the previous assessment. No weaknesses were identified

in the annual exercise. Although the Emergency Response Facility

(ERF) appraisal was postponed because the control room design

review had not been completed, the meteorology and dose

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assessment portions of the ERF appraisal were reviewed and

reported as part of the exercise report. Both of these areas

of the ERF appraisal were considered satisf actory.

Corporate and site management have been involved in site ]

activities in an effective manner. Independent audits of the

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licensee's EP program were complete, timely, and thorough.

A weakness identified in this area in the previous assessment

period had been corrected. Manageme.nt attention to the EP

program and cooperation with EP personnel has resulted in a

better, more professional approach that includes surveillance

and reviewing the interfaces between the licensee and state and

local governments. A good working relationship is being

maintained with Charlevoix County, Emmet County, and the

Emergency Management Division of the State of Michigan,

Management responsiveness to NRC initiatives has resulted in

acceptable resolutions of concerns arising from the licensee's

initial submissions. Through management and technical staff-

cooperation, several Emergency Action Levels were revised

according to NRC recommendations. These changes were documented

and responses made to the NRC in less than 2 months in all

instances.

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Two events occurred during the assessment period that activated ,

the emergency plan.. Each activation resulted in a Notification l

of Unusual Event and was correctly classified with notifications I

being made on a timely basis to offsite agencies and the NRC. l

The EP coordinator maintained a file on each event, and j

corrective. actions were taken on any items of concern.

'

Shift augmentation for emergency response positions has

been adequately demonstrated through several call-in drills. I

When one drill indicated a shortage.of individuals for ce'rtain j

security positions, the EP coordinator took prompt action-to I

correct this shortage. Through drills and training, adequate- )

corrective actions have been taken to maintain a viable shift

l

augmentation program.

The tecining' program has improved since the prior assessment l

period. For example, pertinent training records are being )

documented and maintained better, and record retrieval capability

is good. Effective in January 1988, the EP training modules were

reduced.by combining certain'ones which, in turn, reduced

certain redundant emergency. response positions. As an example,

a person training for a certain Technical Support. Center support

position need not be completely retrained for a similar position

in the Emergency Offsite Facility. Records indicate that 145

out of 156 people onsite are trained in emergency preparedness

responsibility (93% coverage). Of these 145 persons, 65% have

.

1

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participated in two or more drillsLin the past 2 years. .This

clearly indicates the extensive scope of current emergency

'

preparedness training.

l 2. Performance Rating 1

'

l

The licensee's performance is rated Category 1 in this area.

The licensee's performance was' rated Category 2 in the previous

assessment period. This improvement was.the result of improved

training, an independent audit program, management

responsiveness to-concerns, and excellent interface with

offsite emergency response officials.

I

3. Recommendations-

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None.

E. Securi,ty

l

1. Analysis

Evaluation of this functional area was' based on the results of

four inspections (three special and one routine) by regional

inspectors and on routine observations of security force

activities by the resident inspectors,

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The enforcement history represented a reduction in the i

licensee's performance from the previous period. Two violations j

were identified, one Severity Level III violation and

one Severity Level IV violation. During the previous

assessment period, no violations were issued. The Severity i

Level III violation occurred at the beginning of the assessment 1

period, and a civil penalty was assessed. The vio'lation was

for an inadequate vital area barrier that had existed since the

plant was constructed, and because of the barrier's location,

it was not identified previously by the licensee nor the NRC.

The violations did not represent a significant program breakdown

and neither of the violations resulted in direct safety problems.

Management involvement in assuring quality in this area was

adequate. Management support for upgrading security equipment

necessitated by aging equipment and NRC concerns was evident as

demonstrated by the acquisition of new access control search

equipment, completion of the closed circuit television upgrade

project, and completion of the fence tightening and soil

stabilization projects. Concerns identified in the previous

assessment period were effectively addressed by the licensee.

The property protection supervisor (PPS) was very responsive

to regional and resident inspector concerns. The PPS and his

staff developed a program to analyze security data to determine

program performance trends that have resulted in identifying

l potential problems and have helped create a proactive security

program. A higher level of security awareness among the general

plant work force has reduced the high number of security violations

caused by non-security personnel and has strengthened the

security program.

The licensee's responsiveness to NRC initiatives was adequate -

!

when violations and weaknesses were identified. Commitments i

and requirements within the scope of the security plan were i

generally met. When violations and weaknesses were identified, j

the licensee took corrective action in a timely and effective

manner.

Security events reported under 10 CFR 73.71 were properly

id.'ntified, analyzed, and reported to the NRC as required.

There were three events reported during this assessment period,

which wa= the same number as that reported during the previous

assessment period. This low number of events over the

two assessment periods was considered excellent. Generally,

the licensee ls procedural guidance for the security force was

sufficiently detailed to ensure that personnel were knowledgeable

of their responsibilities. The licensee's security force has

been very stable, which is one of the licensee's strongest

security assets. The security force morale was good. The

, increase in morale was attributed to better management

interaction and communication with the security force.

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Staffing levels in the security area were ample. A new PPS was

assigned at the beginning of this assessment period because of

the resignation of the previous supervisor. The security

department's staff was. increased by one at the end of the

i

assessment period because of the elimination of the corporate

Property Protection Department (PPD) and the reassignment of

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the responsibility to the site. The corporate PPD has been

eliminated because of a corporate reorganization. The

PPD personnel were knowledgeable of program requirements and

problem areas and effectively supported the security program.

The external audit function of the PPD was instrumental in

identifying and correcting program deficiencies and was

identified as a program strength. The NRC has a concern about

the loss of the corporate PPD organization in that the function

may not be adequately performed by site personnel in the future.

The training and qualification program utilized by the licensee

was considered acceptable and meets security plan requirements.

None of the security violations were as a result of deficiencies

in the security force training. Communications between site

security personnel and Region III Safeguards personnel have been

excellent.

2. Performance Rating

The licensee's performance is rated a Category 2 in this area.

The licensee's performance was rated a Category 2 in the previous

assessment period.

3. Recommendations

None.

F. Engineering / Technical Support

1. Analysis

This is a new functional area and consequently was not rated in

the previous assessment period. Evaluation of this functional

area was based on the results of four inspections conducted by

regional inspectors and the routine inspections conducted by

the resident inspectors.

The enforcement history in this area identified one Severity

Level III violation with civil penalty and one Severity

Level IV violation involving the newly-installed WRNM

instrumentation system. The Severity Level III' violation was

based on equipment qualification (EQ) requirements of

10 CFR 50.49, which was identified in the previous assessment

15

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period. The licensee's identification and corrective' actions

for the WRNM violation were prompt. No prior enforcement history

is available for comparison because this is a new functional

area.

Management's level of involvement in this area.has been

evident in several ways. The Engineering / Maintenance Department

was changed to create. separate Engineering and Maintenance

Departments. The change enabled the superintendent of

engineering to devote his full time to engineering activities.

The. superintendent of engineering was appointed to chair the  !

Technical Review Group, ensuring that planning and assignment .

of priorities were given additional management review. l'

Corrective actions taken by the Engineering Department were

usually effective except for the neutron instruments. A system

engineering concept is not used at Big Rock Point. Project- ,

groups were formed to resolve major system problems like the  !

RDS and WRNM. The site maintains-the authority for design

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changes and receives support from the-corporate office as

circumstances require.

The identification and resolution of technical issues from a l

safety standpoint were adequate. Engineering evaluations in the  !

form of 10 CFR 50.59 reviews were usually well-documented and

demonstrated a technical rationale. Improvements were noted

,

since the previous assessment period in 10 CFR 50, Appendix R  ;

I compliance. The licensee submitted information to demonstrate

1. a more conservative approach for protecting against fire-induced

I spurious operations of high/ low pressure interfaces than was

required by the NRC. Modification packages showed strength in

the area of documentation and general technica1' adequacy. A-

weakness exist.s when the licensee is replacing existing plant

I equipment on other than a "like-for-like" basis because of

i failure to identify critical performance requirements. This is

due in part to the lack of original design basis information.  !

,

The WRNM upgrade was an example of the problems involved in

'

engineering, The WRNM were installed without proper adjustments

due to deficiencies in~the drawing specifications and the

testing package. Specifically, the receipt and post installation

testing of the WRNM system did not. detect vendor misadjustment

of the internal gain factor.

'

Responsiveness to NRC initiatives was generally timely and.

viable except for the operator licensing examination conducted _

in 1988. The exam had to be cancelled after the examiners

arrived at the site, due to the failure of the licensee to

provide up to date, accurate reference material. While the i

examination was successfully completed in October-1988,

considerable NRC time and effort were expended in resolving the

problems caused by the inappropriate reference. material.

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.Two LERs, one of which was informational, were issued during

this assessment period. The informational LER concerned

lubricants in Limitorque valve operators. Both events were-

properly identified, analyzed, and corrected.

Engineering and technical _ support staffing was adequate, with

key positions identified and defined. Turnover involved two

vacant positions that were filled within a reasonable time.

The staff has varied backgrounds, including mechanical,

electrical, civil, and metallurgical engineers. I

A training program for the engineering and support staff

consisted of in-house training and appropriate vendor / industrial

l seminars. The training and qualification program contributed to l

an adequate understanding of work and adherence to procedures. -l

The licensee received accreditation for its training and- i

qualification program from INP0 ir February 1988. l

l

2. Performance Rating

l

The licensee's performance is rated Category 2 in this area. I

Because this is a new area, no rating is available for the  !

previous assessment period. l

3. Recommendations

None. i

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l G. Safety Assessment / Quality Verification

1. Analysis I

J

This is a new functional area and consequently was not rated in

the previous assessment period. Evaluation of this area was

based on the results from ten routine inspections conducted

by the resident inspectors, assistance from regiona' inspectors, 1

meetings with corporate and/or site technical and licensing

representatives, and interaction with NRR project managers of

the licensee's submittals for amendments to the Operating

Licence, etc.

The enforcement history in this area indicated that major

[ violations were rare and.were not indicative of a' programmatic ,

breakdown. One Severity Level V violation was identified l

involving the failure to adequately control a procedure. No  ;

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prior enforcement history was available for comparison because

L

this is a new functional area.

Management's involvement to ensure quality was adequate

throughout the assessment period. The licensee has increased j

its involvement in self-improvement and self-assessment '

activities. The Nuclear Safety Board was effective in

perfonning independent reviews of plant activities, including

maintenance, modifications, operational problems, and

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operational analyses. The Board was also effective in reviewing

'LERs for completeness and determining areas that required

additional investigation. The Plant Review Committee (PRC) had

performed adequately in initiating investigations and ensuring

followup of corrective actions for previously. identified violations,

reportable events, and areas of weakness. The NRC was concerned

with the PRC's non-conservative decision to continue up in power

following the' discrepancy in WRNM indications and heat balance

calculations during initial testing of the WRNMs. Also of.

concern was the licensee's inquiry for a possible TS change to

pull rods to go critical without proper source range indication.

The open items for both the PRC and Nuclear Safety Board were

tracked on the licensee's tracking system, and the licensee was

active in ensuring that scheduled dates for closures were met. 1

The licensee maintained an open environment for the discussion l

of problems and improvement opportunities. Also, at the urging

of the NRC, a trial root-cause analysis program was implemented. J

at the end of the assessment period.

A number of technical issues, some of thera unique to the Big l

Rock Point plant design, were resolved, including a major  ;

effort on RDS valve testing requirements. 0ther issues remain I

open, including the validation and verification (V&V) of software

for the new power range monitoring instrumentation, an exemption i

from fire protection requirements relating to the screenhouse, ,

revision of the Offsite Dose Calculation Manual (00CM), E0Ps, I

plans for cont-ol room ~ simulation, and station battery service

test requirements. The licensee displayed a good understanding l

of the safety issues and was generally responsive to the staff, i

l

The licensee's Integrated Living Schedule (ILS) was used to

provide visibility to and status of NRC-and licensee-initiated

safety. issues and to prioritize the application of resources

to resolve the issues. ILS updates were the subject of two

licensee-requested semiannus.1 meetings among corporate, plant,

and NRC management. The ILS clearly provides a mechanism to

justify focusing limited resources on a few high priority

issues. However, the RDS and turbine load rejection problems-

have for years been both high priority and unresolved issues.

~

.Further examples of repeated schedule extensions were for-the

sof tware V&V, ODCM revisions, and Final Hazards Safety Report

updates. These frequent extensions raise questions about

adequacy of resources being allocated to ILS items. Shile it

is acknowledged that improvements in resource commitments have

been made, additional emphasis is needed.

Licensee responsiveness to generic communications were timely

and thorough, as evidenced by-their acceptable responses to

NRC bulletins on fastener testing (Bulletin 87-02) and

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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 the licensee for corrective

actions.

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 l

introduced the probabilistic risk concept in the surveillance  ;

and inspection program during this assessment period. The

concept is based on core damage / release of fission products. l

Two surveillance performed using this concept were the ISI and l

RDS valve testing. The enhanced performance incentive program I

was a positive licensee initiative to control the use of QA l

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

l of past outstanding performance. The program has the approval

of NRC regional staff. Safety review committees and feedback

from QA/QC activities were used to provide critical

I self-assessments to the corporate management and to improve work

activities associated with plant operations. The NRC has

concerns that the quality assurance surveillance and audits are

not performance based inspections and may have an inadequate

number of hours budgeted to do observations of actual work in

progress.

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i Staffing of the licensee's onsite QA/QC department remained

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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 i

CROS valve diaphragms.

i The training and qualification program contributes to an j

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l adequate-understanding of work and adherenc.e to procedures

'

as indicated by few personnel errors. QA/QC staff members

! participated in audits at other company locations and attended

I

meetings to increase their knowledge and understanding .

of the QA/QC process. l

2. Performance Rating

The licensee's performance is rated Category 2 in this area.

Because this is a new area, no rating is available from the

previous assessment period.

I 3. Recommendations

None.

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V. SUPp0RTING'OATA AND SUMMARIES

A. Licensee Activities

i

Big Rock Point began the assessment period in routine power operation. l

Throughout the assessment period _ the plant operated at power levels j

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up to the fuel-conditioning / thermal-hydraulic limits. During the I

l period, the plant encountered several power reductions and outages

l

for maintenance, repairs, and surveillance testing. Refueling~

! activities occurred from April through June 1988. Big Rock Point 1

ended the assessment period operating at power levels up to the l

fuel-conditioning / thermal-hydraulic limits. j

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The plant exper;lenced two engineered safety feature (ESF) actuations i

and seven reactor trips. Two trips occurred while operating above )

15%. power and five while below 15% power (three at 0% and one with

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single rod motion). Two trips were the result of personnel errors,

four trips were the result of component. failures, and one was related

to external factors.

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Significant outages and events that occurred during the assessment

period are summarized below:

1. September 6-10, 1987, the plant was shutdown to investigate a

higher than normal unidentified leak rate, and repairs were ,

performed on the 'B' RDS depressurizing valve.

2. November 9-14, 1987, the plant scrammed at 0% and remained

shutdown to perform repairs to leaking RDS valves. l

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3. November 20-23, 1987, the plant was shutdown to perform top  !

assembly replacement on RDS depressurizing valves. Pilot

valves in those assemblies had exhibited excessive leakage ,

since November 14, 198'. I

4. December 2-7, 1987, the plant was shutdown to investigate and

repair a steam leak in the condenser area of the turbine high

pressure heater.

5. January 19-20, 1988, the plant was shutdown to repair a high

pressure heat exchanger steam leak.

6. February 2-4, 1988, the plant was shutdown to make repairs to

the No. 1 reactor recirculation pump seal.

7. February 5-6, 1988, the plant was manually scrammed, as

administratively required, from 10* 4power when the

, recirculation pumps tripped due to a momentary loss of power

l caused by personnel error during generator synchronization.

8. February 8-11, 1988, the plant was shutdown to repair a pinhole

leak on the No. 2 reactor recirculation pump seal cooling water

heat exchanger.

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9. April 8-June 27,1988, .the plant was shutdown- for its 22nd

scheduled refueling outage. .Ma'or activities included RDS

valves modification and testing, WRNM replacement, and

l_ CRDS valve diaphragm replacement,

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10. June.29-July 1,1988, a manuai reactor shutdown was performed

to repair the newly installed WRNM system and calibrate the

.

-source range instrumentation.

11. July 2-7,;1988,-the plant was shutdown to perform repairs on'the

hydrogen. seal oil ~ system.

1

12. July 7.-10, 1988, the plant was shutdown to perform additional

repairs on'the WRNM system.

13 . - October 28-30,-1988, the plant scrammed at 98% power and

remained shutdown to perform repairs on a transformer, which

was damaged during a windstorm when a lightning rod. fell

across its-lines.

14. November 21-24, 1988, the plant scrammed at 90% and remained

shutdown to perform _ diagnostic work and repairs on a high

pressure turbine steam admission valve.

15. November 26-28, 1988,'the plant was shutdown to perform repairs-

on an '! mission valve that had broken and was restr.icting . steam

flow to the turbine, thus causing anomalous' behavior in the

initial pressure regulator.

B. Inspection Activities

Thirty-two inspection reports are discussed in this report

(September 1,-1987, through December 31,1988) and are listed in

Peragraph 1 of this section, Inspection Data. Table 1 lists the

violations per functional area and severity level. Significant

inspection activities are listed in Paragraph 2 of this section,

Special Inspection Summary.

1. Inspection Data

Facility Name:-Big Rock Point'

Docket No.:-50-155

Inspection Report Nos.: 87022 through 87029, 88002-through 88006,

'88008 through-88014, and 88016-through 88027.

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TABLE 1

NUMBER OF VIOLATIONS IN EACH SEVERITY LEVEL

Functional Areas III IV V

A. Plant Operations

B. Radiological Controls

~~C. Maintenance / Surveillance 3

D. Emergency Preparedness

E. Security ' 'I 1

F. Engineering / Technical

Support 1* 1

G. Safety, Assessment / ,

Quality Verification 1

TOTALS III IV V

2 5 1

• This violation was identified during SALP 7, but was not issued until SALP.8

(Enforcement Case No. EA 87-030). It is included in the totals for this SALP

period.

2. Special Inspection Summary

a. During September 28-October 2,1987, a special security

inspection was conducted regarding'the lack of program

management relating to the safeguards program (Inspection

Report No. 155/87025).

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b. During July 18-21, 1988, the annual emergency preparedness

exercise was conducted (Inspection Report No. 155/88016).

c. On July 21, 1988, a special enforcement conference was

held to discuss an apparent violation identified in

Inspectior Report No. 155/88011, regarding full' stroke.

valve testing of the RDS_ valves (Inspection Report

No. 155/88019).

C. Escalated Enforcement Actions

1. A Severity Level III violation-and the imposition of a civil

penalty in the amount of $25,000 was issued to the licensee on

December 2, 1987. This action was based on a violation

involving failure to maintain access control to a vital area of

the plant The licensee paid the civil penalty on January 11, .

1988 (Enforcement Case No.87-202, Inspection Report

No. 155/S7025, Enforcement Notice No. EN-87-101).

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2. A proposed imposition of civil penalty.in the amount of $187,500 l

was issued to the-licensee on September 22, 1988. This action

was based on a violation involving EQ requirements of ,

10 CFR 50.49. .The escalated and mitigation factors of the- l

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- modified enforcement policy'were considered, and 25% escalation.

of the base civil penalty was deemed appropriate because of the

licensee's poor corrective actions. This. case is.under licensee

review (Enforcement Case No. EA-87-080, Inspection Report

&c. 155/86013, Enforcement Notice No. EN-88-079).

L

. D. Confirmatory Action Letters

None.

E. License Amendments Issued

Amendment No. Description Date

90 Allows all reloads of the "I" 05/17/88

fuel design.

91 Revised TS to reflect the features 05/17/88

and terminology used with the

new out-of-core power range )

instrumentation- '

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92 Modified the license to require -

09/14/88

compliance with the Physical Security

Plan, which was amended in response

to 10 CFR 73,55 requirements.

( 93 Requires full stroke tests of all 11/04/88

four RDS valves each refueling outage.

F ,. Review of Licensee Event Reports Submitted by the Licensee

l

Thirteen LERs were issued during this assessment period'. Table 2-

shows cause coce comparisons of SALP 7 versus sal.P 8 LERs.

LER Nos.: 87010 thN 87013 and 88001 thru 88009

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TABLE 2

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(17-MO)- .(16-M0)

Cause Areas SALP 7 SALP 8

No. - (Percent) ~ No. (Percent)

Personnel Errors' 3 (23.1%) 2(15.4%)-

l. Design Problems 3 (23.1%) 2 (15.4%)

External Causes l0 ( 0.0%)- 1 ( 7.7%)

Procedure Inadequacies L4 (30.7%) 1 (.7.7%)

Component / Equipment 1 ( 7.7%). 7 (53.8%)

Other/ Unknown 2 (15.4%)- 0 ( 0.0%)

TOTALS 13 13

FREQUENCY (LERs/MO) .79 ,83

NOTE: The above information was derived 'from review of LERs performed by NRC-

staff and may not completely. coincide with the licensee's cause assignments.

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