ML20004F091
| ML20004F091 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/27/1981 |
| From: | Boyd D, Parker M, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20004F086 | List: |
| References | |
| 50-155-81-05, 50-155-81-5, NUDOCS 8106160492 | |
| Download: ML20004F091 (7) | |
See also: IR 05000155/1981005
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-155/81-05
Docket No. 50-155
License No. DPR-06
Licensee: Consumers Power Company
212 West Michigan Avenue
Jackson, MI 49201
Facility Name: Big Rock Point Nuclear Plant
Inspection At: Charlevoix, MI
Inspection Conducted: April 10 through May 8, 1981
Inspectors:
G. C. Wrig
.52'I' 8 /
M. E. Parker
8- 2'7- 8/
5- 2 r-s /
Approved By:
D. C. Boyd, hief
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Projects Section IA
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Inspection Summary
Inspection on Apri'.10 through May 8; 1981 (Report No. 50-155/81-05)
Areas Inspected: Routine safety, re.j: dent inspector inspection involving:
Operational Safety Verification, Su'.veillance Observation, General Employee
Training, Requalification Training, Maintenance, and Independent Inspection.
The inspection involved a total cf 192 inspector-hours onsite by two NRC
inspectors including 10 inspect w hours onsite during offshifi.s.
Results: Of the areas inspectet., one ites of noncompliance was identified,
Inadequate Requalification Progrs's (paragraph 5).
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DETAILS
1.
Persons Contacted
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- C. J. Hartman, ?lant Superintendent
- C. E. Axtell, Health Physicist
D. D. Herboldsheimer, Outage Coordinator
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- A. C. Sevener, Operations Supervisor
J. J. Popa, Maintenance Engineer
E. McNamara, Training Coordinator
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V. A. Avery, Training Instructor
- D. E. DeMoor, Technical Engineer
- C. R. Abel, Operations and Maint'enance Superintendent
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- T. Fisher, Quality Assurance
- E. Raciborske, Quality Assurance Supervisor
The inspectors also contacted other licensee personnel, including shift,
supervisors, control room operators and document control, radiation
protection and training personnel.
- Denotes those present at the ex'it interview.
2.
Operational Safety Verification
The inspector observed control room operations, reviewed applicable
logs and conducted discussions with control room operators during the
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month of April, 1981. The inspector verified the operability of selected
emergency systems, reviewed tagout records and verified proper return
to service of affected components. Tours of the reactor building and
turbine building were conducted to observe plant equipment conditions,
including potential fire hazards, fluid leaks, and excessive vibrations
and to verify that maintenance requests had been initiated for equipment
in need of maintenance. The inspector, by observation, verified that
the physical security plan was being implemented in accordance with the
station security plan.
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The inspector observed plant housekeeping / cleanliness conditions and
verified implementation of radiation protection controls. During the
month of April,1981, the inspector walked down the accessible portions
of the Core and Containment Spray systems to verify operability.
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These reviews and observations were conducted to verify that facility
operations were in conformance with the requirements established under
technical specifications, 10 CFR, and administrative procedures.
No apparent items of noncompliance were identified.
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3.
Monthly Surveillance Observation
The inspector observed technical specificaticas required surveillance
testing on the Reactor Protection System and the Core Spray System and
verified that testing was performed in accordance with written procedures,
that limiting conditions for operation were met, that removal and restora-
tion of the affected components were accomplished, that test results con-
formed with. technical specifications and procedure requirements and were
reviewed by personnel other than the individual directing the test, and
that any deficiencies identified during the testing were properly reviewed
and resolved by appropriate management personnel.
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No apparent items of noncompliance were identified.
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4.
Training
The inspector reviewed Administrative Procedure, Personnal Training,
Volume IB, Chapter 13, the Master Training Plan, Volume 18, and corre-
sponding training recor(s.
The training program was reviewed to ascertain whether the overall train-
ing activities for new employees and the retraining of non-licensed per-
sonnel are in confetmance with Technical Specification (T.S.) requirements.
The inspectors verified that for' sal training and retraining programs have
been established for new employees, temporary or service personnel, non-
licensed / licensed personnel, technicians and craft personnel; that the
formal training program for therpersoanel listed above covers General
Plant Description, Job Related Procedures and Instructions, Radiological
Health and Safety, Station Emergency Plans, Industrial Safety Program,
Fire Protection Program, Security Program, On-the-Job Training and Quality
Assurance Training; that the retraining program for technicians and craft
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personnel includes on-the-job training, formal technical training, and
fire fighting training; that responsibilities have been assigned to assure
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that training program requirements have been met; and that all female
employees are provided instructicas concerning prenatal radiation exposure.
During the procedure review, the inspector noted a discrepancy in the
Master Training Plan Volume 18.
Administrative Procedure 1.13, Section
1.13-A.2.2 states that Radiation Protection retraining will be conducted
annually, whereas Volume 18 makes reference to both annual and bi-annual
retraining depending on which functional group the employee belongs to.
This item was pointed out in Inspectica Report 80-03.
In addition,
Regulatory Guide 8.27, dated March,1981, states that radiation protec-
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tion refresher training should occur annually, as a minimum.
(81-05-01)
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Regulatory Guide 8.13 states that female employees should be asked to
sign a statement indicating they have received the information contained
in Regulatory Guide 8.13 on prenatal radiation exposure, the licensee's
procedure in this area does require this signature, but the licensee
has not been adhering to this procedure for all fanale employees.
(81-05-02)
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Volume 18, Chapter 1, Section 5.2.1. states that, " Initial training
shall consist of a program covering those general headings cad
subtopics listed below." Included in the general heading is " Quality
Assurance Indoctrination." In reviewing records of selected employee
two individual folders were identified where QA indoctrination was not
indicated as beicg received. The licensee pointed out that QA indoc-
trination is performed once a year for all new employees, for the
previous one year period. This practice allows licensee personnel to
work on and around plant safety related equipment for up to one year
without a formal introduction to the Quality Assurance Program. This
does not appear to an acceptable practice.
(81-05-03)
Volume 18, Introduction, Section 4.0 states, "The entire manual shall
be reviewed by the Plant Training Coordinator on a two-year basis as a
minimum to assure its applicability to existing codes and changing needs."
The inspector was unable to determine that the entire Master Training
Manual had been reviewed by the training coordinator.
(81-05-04)
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The above examples, along with other isolated examples, which were
brought to the licensee's attention, indicate that the general employee
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training requirements of Volume 18 are not being adhered to by the licensee.
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No apparent items of noncompliance were identified.
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S.
_L_icensed Operator Requalification
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The requalification program was reviewed to ascertain whether the
licensed operator requalification training program is is effective and
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in conformance with regulatory requirements. The inspector reviewed
records to verify that an operator requalification training program is
established and include preplanned lectures, attendance documentation
and identification of specific training aids to be used in lieu of an
instructor: the on-the-job training requirements have been specified
to include control manipulations, discussion / review of changes in
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facility design, procedures, and license, and that records of licensed
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individuals are maintained to include completed course and yearly
examinations, documentation of manipulations, documentation of required
simulations of emergency and abnormal conditions, results of supervisory
evaluations and observation of manipulations and simulations identified
above, documentation of individual study, and documentation of accelerated
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requalification training.
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The inspectors reviewed the records of licensed Senior Reactor Operators
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and licensed Reactor Operators to verify that the licensee's approved
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requalification training program was being properly implemented.
During the review of the requalification program, the inspector noted
that the licensee, in a letter from Consumers Power Company to NRR,
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dated August 6, 1980, stated.that:
"An overall grade of 80% on the
annual requalification exam, with a minimum of 70% in any one category
shall be required of all persons performing licensed duties. Persons
receiving exam scores less than those stated -above shall be enrolled in
an accr'.erated training program within five days of their grade deter-
mination to upgrade their knowledge to an acceptable level (
80% upon
reenmination) ." Volume 18, Chapter IV,. Master Training Manual, Operations
Department Section 5.6.25, states: "Each licensed individual shall be
required to achieve an 80% overall passing grade sud no less that 70% in
any one category. A grade of less than 80% will require entry into an
accelerated train u g program within five days of the grade determinati.on.
The individual shall be removed from his/her licensad activities until
he/she satisfactorily passes a reexamination with 80% or greater." No
mention of what action is to be taken if an individuel achieves less
than 70% in any categori, as was committed to in the August 6, 1980,
letter.
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Further review of individual's scores on the September, 1980, Annual
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Requalification Exams identified two individuals, one reactor operator
and and one senior reactor operator who achieved an overall score of
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80% but fell below 70% on individual categories. Neither individual
was enrolled in an accelerated training program nor was either individual
reexamined as per prior commitment. Discussion with onsite training
personnel revealed that they were unaware of the August 6,1980 commitments.
Facility Technical Specifiaction 6.4.1 states:
"A retraining and replacement training program for the plant staff shall
be maintained under the direction of the Plant Superintendent and shall
meet or exceed the requirements and recommendations of Section 5.5 of
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ANSI N18.1-1971 and Appendix "A" of 10 CFR, Part 55."
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10 CFR 55, Appendix A, Section 4.e states that a requalification program
shall have " provisions for each licensed operator and senior operator to
participate in an accelerated requalification program where performance
evaluation conducted pursuant to paragraphs 4a through 4d clearly indicate
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the need."
Contrary to the above, the licensee's existing requalification program
appears to be deficient in identifying accelerated training for licensed
personnel achieving less than 70% on a given section. Further, changes
to the requalification program as outlined in Consumers Power Company's
letter of August 6,1980, which if implemented, would have brought the
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program into compliance with 10 CFR 55, were not made in a timely manner.
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(81-05-05)
It is to be coted that when the above situation was brought to the
licensee's attention the two individuals were immediately enrolled in
an accelerated training program on the sections in question.
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The inspector's concern, pertaining to this item of noncompliance, is
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the reason for the information contained in the licencee's August 6,
1980, letter not reaching the appropriate licensee personnel to effect
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implementation. It is to this end that the licensee should direct their
reply.
6.
Maintenance
The inspector revitwed selected maintenance activities to ascertain that
activities on safety related systems and components were conducted in
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accordance with approved procedures, regulatory guides and industry codes
or standards and in conformance with Technical Specification requirements.
Altisough no apparent items of noncompliance were identified, the inspector
has questions in the following areas and discussed the same with the
licensee:
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a.
The " Testing Requirement" section of the maintenance order is filled
out only when testing is required. The inspector commented that if
no testing is required, then this fact should be noted on the main-
tenance order, thus indicating that testing had been considered.
b.
Worker and management attention to detail. This is a general
comment on recording data, placing calibration stichers and review
of completed documentation by supervisors.
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The inspector questioned the advisability of writing maintenance
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orders to " inspect, trouble shoot and repair" equipment. The
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potential equipment control problems and Quality Control problems
were discussed.
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d.
T'2e inspector could not identify any mechanism for controlling
changes to maintenance orders af ter a portion of the review chain
had been completed.
7.
Independent Inspection
The ir .pectors discussed with the licensee the definitions of " Restricted"
and " Unrestricted" areas and th; practice of designating areas, outside
the protected area fence,'as " Restricted Areas."
The inspectors indicated that due to the training requirements of 10 CFR 19.12, pertaining to restricted areas, the licensee's definition of a
"Reatricted Area" in Volume 11, " Radiation Protection Manual - General"
is not a viable definition.
The inspectors also stated that the practice of using an approximately
three and a half foot high strand wire fence around the radioactive vaste
storage facility (located outside the protected area fence) and around a
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section of the protected area fence adjacent to the contaminated tool
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storage warehouse, in the southwest corner of the protected area, to
define a " restricted" area was unacceptable.
The licensee, in response to the above positions, has committed to the
following actions:
Redefine, in Volume 11, the term " Restricted Area".
On an interim
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basis, the '5 Restricted Area" will be defined as all areas inside
the protected area fence and the area around the radioactive waste
storage facility defined by stranded wire the existing stranded
wire fencing and adequate posting.
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The above definition is temporary, for further details refer to
item c. below.
(81-05-06)
b.
The licensee will reduce the radiation levels at the exterior of
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the contaminated tool storage warehouse, located in the southwest
corner of the protected area, such that the area outside the pro-
tected area fence will meet the definitions of an unrestricted
area.
(81-0507)
Pertaining to the wire fence around the radioactive waste. storage
c.
area, the licensee has stated that plans are underway to enclose
the facility with a permanent building. A completion date of
October 1, 1981, has been set for the building.
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The licensee and the inspectors have agreed that the wire fence,
along with appropriate' posting, will be acceptable to define the
restricted area, pendin*g completion of the permanent building,
based on a completion date of October 1,1981.
(81-05-08)
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The ?'censee has been informed that if the proposed building is not
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ed, or if delays are encountered, other measures will have
to be implemented to insure compliance with 10 CFR 20 requirements
on radiation levels and access controls in regard to restricted and
unrestricted areas.
8.
Exit Interview
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The inspectors met with the individuals denoted in paragraph I at the
conclusion of the inspection and summarized the scope and findings
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of the inspection. The licensee acknowledged the inspector's comments.
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