ML20236C267
| 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: |
| 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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Name ,
.T. --i t l e.
- 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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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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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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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
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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. !
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The WRNM upgrade was an example of the problems involved in
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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
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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.
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.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
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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
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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
'
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,
t
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
E. Security ' 'I 1
F. Engineering / Technical
Support 1* 1
G. Safety, Assessment / ,
Quality Verification 1
TOTALS III IV V
2 5 1
(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)
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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