ML20055F168
| ML20055F168 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/06/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20055F167 | List: |
| References | |
| 50-155-90-01, 50-155-90-1, NUDOCS 9007160019 | |
| Download: ML20055F168 (28) | |
See also: IR 05000155/1990001
Text
-
-+
.
.-
p
p
,.; ' .
.;
-
.
I
.p
,
~h
t
SALP 9
'
INITIAL SALP REPORT.
.
>-.
.
U.S. NUCLEAR REGULATORY COMMISSION
p
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
I
'
'
50-155/90001
t
Consumers Power Company
,
Big Rock Point Nuclear Plant
,
January 1, 1989 through April 30, 1990
- (
,
b
o
~;
l
9007160019~900706
ADOCK 05000153
-Q
.
'
,
l
.
.
.
.
-
,
. . . -
.s
,,
1
.
i
TABLE 0F CONTENTS
'\\ :
Page No.
' LIST OF ACRONYMS ............................................
11
'I.
INTRODUCTION ............................................
1
-II.
SUMMARY'0F RESULTS .....................................
3
A.
Overview ..........................................
3
B.
Other Areas of Interest ...........................
3-
III. CRITERIA ................................................
4
IV.
PERFORMANCE ANALYSIS .........-...........................
6
A.
Plant Operations ..................................
6
B.-
Radiological Controls .............................
8
.)
,
C.
Maintenance / Surveillance ...... ...................
10
- '
O.
. Emergency Preparedness ............................
13
-E.
Security ..........................................
14
F.
Engineering / Technical Support .....................
16
G.
Safety Assessment / Quality Verification ............
18
EV .
' SUPPORTING DATA AND SUMMARIES...........................
22
!
sA . - - Li cen s e e Acti vi ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22
9
,
.B.
Inspection Activities..............................
23
E
C.
Escalated Enforcement Actions......................
24
D.
Con fi rma to ry Acti on Letters . . . . . . . . . . . . . . . . . . . . . . . .
24
'
'
E.
Review of - Licensee Event Reports (LERs). . . . . . . . . . . .
24'
!
>
.t.!
-
.!
.
.
i
,
_
$4
s .' . .
y
.
-.
-ALARA
as-low-as-reasonably-achievable
closed circuit television
Ci
curies
DR
deviation reports
Division of Reactor Projects
Division of Reactor Safety
'
DRSS
Division of Radiation Safety and Safeguards
emergency action level
emergency operating procedures
,
ER
event reports
i
ILS
integrated living schedule
,
LER
licensee ~ event report
!
NRC
Nuclear Regulatory Commission
Office of~ Nuclear Reactor Regulation
I
NSB
Nuclear Safety Board
NSSD
Nuclear Safety Service Department
l
personal contamination events
Project Directorate
preventive, maintenance
Plant Review Committee
QA-
quality assurance
j
QC-
quality control
RDS
reactor depressurization system
REMP. -
Radiological Environmental Monitoring Program
Systematic Assessment of Licensee Performance
q
TS
Technical Specifications
l
Unusual Event
!
Verification and Validation
WR~
work request
-
,
\\
!
o
t
q
p
!
!
!
!
1'
l
l
i
{
l
1
l
.:
l
,
, :,.
.,
t
>
,
1
b
'I.
'INTRODUCTIONL
The Systematic Assessment'of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available ob:ervations and data on
a periodic basis and to evaluate licensee performance' on the basis of this
information.
The program is supplemental to normal regulatory processes
used to ensure compliance with NRC rules and regulations.
It,is intended
to be sufficiently diagnostic to provide a rational basis for allocating
!
NRC resources and to provide meaningful feedback to the licensee's.
!
management regarding the NRC's assessment of their facility's performance
1
in each functional area.
E
An NRC SALP Board, compo ad of the staff members listed below, met on
June 20, 1990, to review the observations and data on performance, and to
-
assess licensee performance in accordance with the' guidance in NRC Manual
Chapter 0516, " Systematic Assessment of Licensee Performance." The
'
guidance and evaluation criteria are summarized in Section III of this-
,
report. The Board's findings and recommendations were forwarded to the
i
NRC Regional Administrator for approval and issuance.
,
This report is the NRC's-assessment of the licensee's safety performance
at Big Rock Point Nuclear Plant for the period January 1, 1989 through
April 30, 1990.
The SALP Board for Big Rock Point was composed of the following
individuals:
Board' Chairman
H. J. Miller, Director, Division of Reactor Safety (DRS)
Board Members
i
W. L. Forney, Deputy Director, Division of Reactor Projects (DRP)
W.- L. Axelson, Deputy Director, Division of Radiological Safety and
Safeguards (DRSS)
.
,
R.
C', Pierson, Project Director, Office of Nuclear Reactor
,'
. Regulation / Project Directorate (NRR/PD) III-1
,
B. Clayton,-Chief, Reactor Projects Branch 1, DRP
B. Holian, Project Manager, NRR/PD III-1
-
E.
A'. Plettner, Jr. , Senior Resident Inspector, DRP
'
.
Other Attendees at the SALP Board Meeting
.
.G.-C. Wright, Chief, Operations Branch, DRS
R. DeFayette, Chief, Reactor Projects Section 2B, DRP
M.' Schtnacher, Chief, Radiological Effluents and Chemistry Section, DRSS
s
-
W. Snell,- Chief, Radiological Controls and Emergency Planning Section, DRSS
I
J. R. Creed, Chief, Safeguards Section, DRSS
B. Drouin, Project Engineer, DRP
C. F. Gill, Senior Reactor Programs Specialist, DRSS
F. A. Maura, Reactor Inspector, DRS
L
b
!
..
,
. . . . .
. , - - ;w
[
.1
t
t
.'A'.
.d.
-
V. P. Lougheed Reactor Inspector, DRS-
D. L Schrum, Reactor Engineer, DRP
b-
T. Rowell, Summer Intern, NRR/PD 111-1
>
'
i[,1
,~
r
-!
>
,
s
t i
1
6ib
>
l
.,4
h
%
1 -
If
'
!
l
l
l.
[,1
l :
I
A
2
>
.
c
p ; .;
- . ,
.c
a
'
.II.
SUMMARY'0F RESULTS.
'A.
Overview
l
Licensee management' continues to be highly involved with site. activities _
'!
'
and maintains a conservative philosophy regarding the safe operation
of the plant. The plant sustained its Category I rating in the area
of Operations and improved its- rating from a Category 2 to a Category 1
- -
in Maintenance / Surveillance.
The Operations rating was based in part
on the reduction of reactor trips from four during the previous
<
assessment period to 1 during this assessment period and operator
,
response to events. _The improvement in the Maintenance / Surveillance
.
<
area was attributable to aggressive management involvement, a well
!
trained and experienced staff, effective preventive maintenance
and equipment refurbishment prograns, a good balance of plant maintenance
i'
program, a_. low corrective maintenance backlog, and the development of
1
'
improved maintenance procedures. The Category 2 Improving rating in
'!
+
the Safety Assessment / Quality Verification functional area reflects
Consumers Power Company's management's continued efforts to establish
priorities and schedules for actions regarding resource allocations
to improve plant safety and performance. The licensee also made more.
effective use of resources to address previous NRC concerns with the
Integrated Living Schedule (ILS). All other SALP functional areas
demonstrated commitment to' safe operation of the plant.
The only
SALP functional area identified as needing increased management
'
attention was Radiological. Controls in which a slight decline in
overall performance was noted.
The area declined from the previous
assessment period in enforcement. history, responsiveness to NRC
' initiatives, identification and resolution of technical issues, and
training.
The performance ratings during the previous assessment period.'and
this assessment period according to functional areas are given_ below:
Rating Last
Rating This
_3
Functional Area
Period
period
'Tiend.
!
Plant Operations
1
1
Radiological Controls
2
2
Maintenance / Surveillance
2
1
g
1
1
!
!
Security
2
2
-Engineering / Technical Support
2
2
Safety Assessment / Quality
r
Verification
2
'2
Improving-
,
B.
Other Areas of Interest
,
None,
l
3
L
,
r
m
m
,
,
c.."
- _. w
y
.
.
I
III.~ CRITERIA
,
Licensee performance is assessed in selected functional' areas.
Functional
t
_ 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 added 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 identification and resolution of technical issues
from a safety standpoint;
.
"'
' 3.
Responsiveness to NRC initiatives;
4~
' Enforcement history;
.
5.
Operational events (including response to, analyses of, reporting of,
and corrective actions for);
,
- 6.-
Staffing (including management); and
4
7.
' Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may'have been
used where appropriate.
1
i
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:
1
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
t
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
regulatory requirements.
Licensee resources are adequate and reasonably
allocated so that good plant and personnel performance is being achieved.
!
NRC attention may be maintained at normal levels.
i
p
Category 3:
Licensee management attention to and involvement in the
'
performance of nuclear safety or safeguards activities are not sufficient.
"
l
l-
4
,
lL
l
l'
-
.,
d
. ..
.. :.
.
!
The_ licensee's performance does not significantly exceed that needed to
I
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.
Licensee performance
during the assessment period should be examined to determine whether a
,
trend exists.
Normally, this performance trend should only be used if a
definite trend is discernable.
i
The _ trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving during the
assessment period.
Declining:
Licensee performance was determined to be declining Juring the
assessment-period, and the licensee had not taken meaningful steps to
address this pattern.
,
e
.
1
5
r
1 ,.
. . .
.
IV.
Performance-Analysis
A.
Plant' Operations
'1.
Analysis
Evaluation of this functional area was based on the results of
twelve routine inspections by the resident inspectors.
Enforcement history in this area was excellent.
Only one
Severity Level V violation was identified, which was of minor
significancet
Management involvement to ensure quality in this' area was
excellent.
.A' new plant manager was assigned during the last
three months of the assessment period. He continued to
,
uphold the high standards of his predecessor. The plant
j
production / performance superintendent retired in December 1990,
i
in response to the early retirement program implemented by
Consumers Power Company. The program affected other areas of
,.
l
site management.
Despite these changes, the licensee continued
'l
E
to maintain highly skilled shift supervisors and line managers
1
l-
who are knowledgeable of the history and operating
i
characteristics of the facility. These managers were generally-
.
L
involved in both routine and off-normal operational activities.
'
There-was continual evidence of prior planning and well assigned
priorities.
Procedures for control of activities were well
stated, controlled, and explicit.
!
'
l_
At the beginning of the assessment period the licensee initiated
L
a program.for upgrading operations procedures to improve efficiency
l
in performance and documentation. The program identified 295
l
procedures requiring upgrading; it is scheduled to be completed
1
"
in December-1990. .At the end of the assessment period 203
l
procedure improvements had been completed and approved, making
j
the program slightly ahead of schedule,
j
-t
Senior site management personnel were of ten present in the
l
control room, communicated regularly with the shift supervisor
y
during all shifts, and toured the~ plant on a regular basis.
l
Management's presence and involvement: contributed to the
'
generally high level of housekeeping throughout,the facility.
L
Corporate management'was frequently and effectively involved in
onsite acti'vities and was onsite at least once a quarter.
H'
The licensee's response to resolving technical issues from a
!
safety standpoint demonstrated a conservative operational
3
approach to unusual events. The plant was reduced in power or
shut down until problems were investigated.
Examples were the
,
6
i
.
I
i;f
- ,
{
~
.
}
repair of. steam leaks on the~high-pressure turbine and a turbine
expansion joint, and the Garlock No. 938 packing problem.-
,
-The licensee's responsiveness to NRC inspection findings was
timely and effective, as demonstrated by correcting housekeeping:
problems; responding to equipment problems involving an electrical
<
splice, liquid-tight flexible conduits, and oil in a nitrogen
line; and evaluating potential generic concerns identified at
,
other sites. The_0perations Department assisted in the development.
of symptom-based emergency operating procedures (EOPs) which were
completed in a reascaable time considering that the generic
guidelines developed by the Owners Group were, in general, not
applicable to this plant.
Unit availability improved during this assessment period and
L'
was indicative of excellent plant operations and maintenance.
,
For most of the assessment period, the plant operated with no-
control room instruments out of service, and the plant had-a
<
" black board" most of the time. There were significantly fewer
operational events this assessment period compared with the
previous period; there was one automatic reactor trip from power
with no engineered safety system actuations during this assessment
period, compared with six automatic trips with two engineered
,
safety system actuations in the previous assessment period.
The
'
reduction can be attributed to aggressive management review in
.
determining the root causes of problems, and in instituting
!
corrective actions to prevent recurrence. The trip was caused
by the failure of turbine-equipment.
In response to the-trip,
the licensed operators expeditiously took the correct EOP
~
,
. actions needed to maintain the plant in a safe condition. On
'
<
another occasion, the operators prevented a reactor trip by
y
their quick response to a feedwater pump trip.
The forced
outages that occurred during.the assessment period were not
indicative of major plant problems.
'
L
Operators routinely consulted procedures and drawings to conduct
'
plant operations and were familiar with Yechnical Specifications
,
!-
(TS) and supporting administrative requirements associated with
!
l
plant operations.
Shift personnel performed their duties in a
L
professional manner and control room decorum was maintained'at a
high level.
The plant operations area continues to be well staffed. A
sufficient number of qualified licensed and non-licensed individuals
u
L
were available to allow for routine shift coverage, training,
1
and outage work without excessive use of overtime.
Positions
p
were clearly identified, and authorities and responsibilities
were well defined. The fire protection organization was adequately
staffed with well qualified personnel. This included a full-time
safety supervisor who holds a college degree as a fire protection
specialist and who performed the duties of safety coordinator
and fire brigade instructor.
.;
i
1
7
f
- - - - - - -
- - -
- - -
-
- - - - - - -
- - - - - -
- -
m
,c /* ':2 ,
s
' Training-and qualification' programs contributed to the
.
understanding of work and adherence to procedures; indicative
of this is_that only one personnel error involving procedures
occurred during the assessment: period. Although the licensee
does' not yet have a site- specific simulator, it adequately
satisfied the requirement of training operators on a. simulator
i
by conducting training on Dresden's simulator.
Replacement-
examinations .were administered.to- four individuals during the '
assessment period; the pass rate was 100%. Of the twelve
operator requalification examinations that the NRC administered
during the assessment period,11 (92%) had passing grades.
No
problems were identified in the ability of the staff. to execute
the E0Ps.
2.
Performance Rtt_in,g
The , licensee's performance is rated Category 1 in this area,
i
The licensee's performance wa.c rated Category 1 in the previous
assessment period.
3.
Recommendations
i
None.
B.
Radiological Controls
- f
e
1.
Analysis
,
1
Evaluation of this functional area was based on the results
i
of three inspections conducted by regional . inspectors and
observations made by.the resident inspectors.
j
Enforcement hittory in this area declined slightly from the
i-
previous assessment period, but did not represent a significant
program degradation.
Three violations, one Severity Level IV
and.two Severity' Level Vs, were identified during.the
' ,
assessment period compared.with no violations identified in
the previous period',
'
Training and qualifications of the staff were adequate to
implement the routine radiation protection programs.
Staff
turnover.was low during the assessment period. An experienced
and well qualified technician was quickly appointed to fill the
vacancy in the position of As-Low-as-Reasonably-Achievable
(ALARA) coordinator. This technician's position was not filled
so the plant established a special program to ensure adequate
quality of backshift coverage as a result of the reduced
complement of chemistry and radiation protection technicians.
The licensee responded adequately tc identified concerns. The
licensee was receptive to the NRC confirmatory measurements
programs, and improved the procedures for whole-body counting
and for internal dosimetry procedures.
,
,
8
>
4
-
- . - -
- - - - - - - - -
- - . .
-
- -
"
,
i
..
- ;
,
I
s-
L
Management involiement to entsure quality in this area wa;
improved. The station requested and received a followup review
by an industry group of its efforts to improve its radiation
protection prrgram and the radiation protection manager visited
several other nuclear plants to acquaint himself with their
programs. Management initiatives in improving plant
cleanliness, worker training, and establishment of goals have
been e factor in reducing the number of personal contamination
events (PCEs) during this period. Management involvement was
also evident in station adoption of current industry water
quality gu'delines and in improvements to the chemistry cuality
assurance / quality control (QA/QC) program. However, the
observation that several of the PCEs involved failure to
follow conysntional radiation protection practices indicates
o
that more ef fort is warranted in this area. Similarly,
management ovarsight was weak when work associated with a
condenser in-13akage test resulted in spread of contamination
s
in the turbine building.
The licensee's appcoach to identifying and resolving technical
issues was adequate with generally good efforts made with regard
to ALARA and contaminat on control. Total station dose in 1989
i
was 160 person-rem, similar to 1988.
An improved ALARA program
was a factor in achieving this because work performed during
the 1989 outage had a greater dose potential than the 1988
outage. The t9mber of PCEs in 1989 was 178, down from 293 in
1988. Weaknesses observed included several instances of
improperly label ed contaminated equipment stored in clean
areas and of workers not properly completing the sign-offs on
radiation work permits. These were the result of inattention
to detail and were of minor safety significance.
There were 7080 Curies (Ci) of airborne radioactivity released
in 1989 which was somewhat lower than the 7760 Ci released in
1988. This continues to reflect the benefits achieved since
1987 when fuel with cladding problems was replaced. Water
chemistry appeared to be under satisfectory conts01.
Improvements were made to the laboratory QA/QC program, which
was identified as a weakness during the last assessment period,
and the licensee is pursuing improvements in analytical
capabilities.
Current methods used by the licensee for
chloride c.aiysis have limited sensitivity. The laboratory
fac111tles and equipment are adequate altho 6h space is
limited.
The results of the nonradiological confirmatory measurements
program were good. The licensee had 3 of 12 initial comparisons
in agreement (75*4).
The disagreements appeared to be due mainly
to problems in reading a calibration curve and the calibration
standards. This is a continued weakness from the last
assessment period.
9
. . . . _ . .
.
. -
_ -
_ _ _ _ _ _ - _ _
..
_---
.1
,
'
.-
The results of the radiological confirmatory measurements
1
programs also were good; 81 agreements were achieved in
88 initial comparisons. The discrepancies were minor and were
satisfactorily resolved. The Radiological Environmental
i
Monitoring Program (REMP) was adequate. The annual REMP report
]
included statistical analyses of the results to assess the
effect of the plant on the environment. The air-sampling and
,
milk-collecting systems appeared to operate satisfactorily.
2.
performance Rating
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous
,
assessment period.
3.
Recommendations
None.
C.
Maintenance / Surveillance
1.
Analysis
Evaluation of this functional area was based on the results of
i
12 routine inspections conducted by the resident inspectors and
2 routine inspections conducted by regional inspectors.
Enforcement history in this area was excellent and had improved
from the previous assessment period when there were three
Severity Level IV violations.
There were no violations during
l
this assessment period.
Management's involvement and program effectiveness to ensure
quality in this area were evident during plant outages and
refueling activities. Major tasks were wall planned and
implemented, and plant improvement progra u were continued.
7
All major tasks completed during the outage demonstrated close
i
management control of work. Major tasks completed during
the 1989 refueling outage were the main turbine overhaul,
replacement of wiring to the control rod drive accumulator
pressure switches, onsite testing of the four reactor
,
depressurization system (RDS) valves, the first part of the
recirculation pump room wire replacement, change out of the
final-two sets of uninterruptible power supply batteries, part
,
two of the three year project to refurbish all major plant
components, and performing the integrated leak rate test.
The routine refueling outage was completed correctly and on
time, partly because of aggressive management oversight.
The
company field maintenance service team performed well; no rework
issues were identified.
This was an improvement from the last
assessment period when a major rework item occurred regarding
,
10
L
3
,
-
--,w.-
,r
r--
.
r
!
..
,
i
i
the control rod drive system diaphragms. The inservice inspection
program and the pump and valve inservice testing program were
adequate and met the requirements of Section XI of the American
Society of Mechanical Engineers (ASME) Boiler and Pressure
Vessel Code and the licensee's program. All activities were
controlled with well-stated and well-defined procedures.
Records were complete, well maintained, and accessible. All
four RDS valves successfully passed their full-stroke test and
no excessive wear or corrosion was noted in the valve that was
disassembled for inspection.
This was an improvement from the
last assessment period when one of the four RDS valves had
failed the full-stroke test because of excessive corrosion.
With one exception, technical issues were resolved soundly and
thoroughly during this assessment period.
Examples were the
valve seat degradation problem, the Kerotest isolation valve
problem, and the Garlock No. 938 packing problem. The licensee
submitted all three examples as informational licensee event
reports (LERs). The one exception involved the integrated leak
rate test.
The licensee did not provide a sound technical
basis or information for terminating the Type A test; the test
was supped as soon as one set of data reached the acceptable
range. Only when the validity of the test was questioned did
the licensee provide additional information; however, this
information was not always technically justified.
The NRC previously had identifiea a regulatory deficiency in the
maintenance program with respect to procedures. The licensee
therefore established a six-member team to write new procedures
.
for maintenance personnel and to upgrade the format of existing
i
procedures.
The rewriting effort was started at the beginning
of the assessment period and is scheduled to be completed in
December 1990. At the end of the assessment period 105 of 160
,
identified procedures were completed and approved, thus meeting-
the goals and the schedule of the program to improve procedures.
Early in the assessment period, the licensee implemented a
root-cause analysis program which was formally approved late in
the assessment period.
Benefits of the program were seen in the
licensee's approach to resolving such issues as a coupling
problem on the emergency diesel generator and a packing problem
on several valves.
No significant operational events in the Maintenance / Surveillance
area occurred during this assessment period.
Maintenance and surveillance work on safety and safety-related
systems and components was in most cases, well planned and
professionally performed with detailed instructions, drawings,
and procedures used at the job site.
The work and the
postmaintenance testing were well documented.
Corrective
l
l
l-
11
-
,
d
'
y
..
..
..
'
.
actions appeared to be effective in correcting the root causes
,
of problems as indicated by the fact that no rework was
required.
The plant equipment work request (WR) backlog has been reduced
since the previous assessment period. The WR backlog averaged
approximately 90 items at the start of the assessment period and
decreased to approximately 60 items at the end of the assessment
period and met the plant goals. Sixty items represent about one
month's worth of work.
Furthermore, only a minimal number of
preventive maintenance (Pri) items required deferral during the
assessment period.
It is also commendable that the licensee
gives high priority to balance-of plant problems when they are
related to safety systems.
The licensee continued to improve the PM program by reassessing
vendor preventive maintenance recommendations and expan'" 3 the
use of predictive analysis (using vibration and temperature
monitoring) on a variety of equipment.
Forced outages decreased
during this assessment period. The largest contributor to this
decrease was the equipment replacement / refurbishment projects
conducted over the last two refueling / maintenance outages. The
licensee continued to aggressively address issues of-plant
aging, as evidenced by the recirculation pump room wire replacement
and control rod drive accumulator pressure switch wire replacement.
With one exception, all surveillances were performed within the
required time interval.
The missed surveillance was not significant.
The licensee maintains a well-trained and qualified maintenance
and surveillance staff.
Three supervisors retired as the result
of the early retirement program implemented by Consumers Power
Company.
All three positions were filled by promoting plant
personnel.
Despite the loss of key personnel, the licensee
continues to maintain a high level of expertise. New individuals
were hired to fill vacancies created by the promotions.
Training
was provided to increase individual skills and knowledge levels.
The licensee used its limited resources effectively in resolving
issues of planning and scheduling, writing additional procedures,
and improving maintenance tool and equipment control. Additional
company maintenance crews were used to assist plant personnel
i
during outages. Total overtime was not excessive and was
consistent with NRC and licensee guidelines. Career planning
was implemented last assessment period and continued this
assessment period for all maintenance personnel, including
repairmen and technicians.
2.
Performance Rating
,
e
'
The licensee's performance is rated Category 1 in this area.
The licensee's performance was rated Category 2 in the previous
I
assessment period.
l
l
12
l
)
f#*
',,
y
.
,
t
3.
Recommendations
None.
,
D.
1.
Analysis
Evaluation of this functional area was based on the results of
'
two inspections conducted by regional inspectors and
observations made by the resident inspectors.
Enforcement history has remained excellent.
No violations were
identified, nor were any exercise weaknesses identified during
this assessment period.
Management involvement to ensure quality in this area continues
to be good. One QA audit and two QA surveillances were
'
conducted on the site's emergency preparedness (EP) program as
well as an audit on the Corporate General Office EP program;
there were no negative findings o observations of the EP
program at the plant.
Responsiveness to identified concerns was good for most EP
issues, particularly for training and audit-related findings.
.However, in response to an NRC inspection finding relating to
changes in the emergency action level (EAL) tables, it took
twelve months to resolve the issue.
!
Shift staffing and response capability has been well
maintained as was demonstrated by shift augmentation drills
conducted throughout this assessment period. A new emergency
position, Emergency Operations Facility (EOF) Governmental
Liaison was established and proceduralized.
This position,
which serves as the State of Michigan and county liaison, was
active in the May 1989 exercise and will be used for both
full-scale and utility-only exercises in the future.
The training program has continued to be well directed and to
have strong plant management support. The EP Coordinator
'
initiated " mini-drills" for the Shift Supervisors and other key
operating personnel to keep them current on key emergency plan
implementing procedures, including emergency notification and
s
the EAL tables.
P
The licensee's ability to identify and resolve technical issues
was demonstrated to be excellent during the annual exercise.
The exercise comprised several challenging scenarios, including
a plume that changed direction after the release path was
identified. These scenarios provided realistic challenges to
continually evaluate and upgrade the protective action
recommendations. The assembly and accountability drill, which
!
13
r
7-
c* .-
,
,
.
,
!
included onsite contractor personnel present for an upcoming
outage, was conducted successfully without error.
Good reentry
and recovery were demonstrated by meaningful and realistic input
from a joint meeting of the Technical Support Center and EOF
staffs.
In addition, the licensee's response to operational
events was good.
The emergency plan was activated three times
during this assessment period.
Each event was correctly
classified as a Notification of an unusual Event (UE), and the
State of Michigan, the counties, and the NRC were notified
within the required time limits for each event.
The third
event was conservatively classified an UE in as much as the
situation involved a proposed TS change that had not been
formally approved. Subsequent licensee review of the
clas;ification of these three events concluded that the
applicable EAL for one of the events should have been recognized
sooner. As a result, subsequent training sessions emphasized
the importance of recognition of conditions so as not to delay
proper use of the EAL tables and resulting classification.
2.
Performance Rating
,
The licensee's performance is rated Category 1 in this area.
The licensee's performance was rated Category 1 during the
previous assessment period.
3.
Recommendations
None.
E.
Security
1.
Analysis
Evaluation of this functional area was based on the results of
three routine security inspections conducted by a regional
security inspector and on observations made by the resident
inspectors.
Enforcement-related performance was excellent.
No violations
s
were identified during this period.
Management's role in ensuring quality was adequate. Management's
.
support for improvements to the security system, necessitated
!
by aging equipment, was good as evidenced by support for the
proposed replacement of closed circuit television (CCTV) cameras
and the proposed addition of electromagnetic locks for some
security-related doors.
In addition, management's efforts to
reduce personnel errors involving the implementation of the
security program were noteworthy.
p
l,
!
14
bi
t.,
j
r
'
,
,
I-
s
!
i
The licensee developed and implemented its Fitness-For-Duty
program during this assessment period.
Site management
<
involvement and support were evident in the planning and
'
execution of the program.
,
An upgrade for the access control computer was approved and a
new system is being evaluated for proposed installation during
'
1990. The initial evaluation of the proposal shows that the
,
system is technically advanced and, if implemented adequately,
the new system should provide a significant program upgrade.
.
The licensee's responsiveness to correcting NRC inspection
findings was mixed. On the positive side, security management
is generally responsive to inspection findings. On the other
hand, it was noted that although management was aware of
reliability problems with its CCTV assessment system early in
!
the assessment period, corrective actions were slow in being
.
implemented. As a result, the CCTV camera replacement project
may not be completed until the end of the next assessment
period.
During this assessment period, security management
personnel kept the NRC regional personnel fully informed of
<
security issues involving the site.
The licen.,ee's approach to the identification and resolution
l
of techrteal issues was also mixed.
Some problems related to
t
equipmr.nt and personnel continued from the previous assessment
pe ri or..
Among these problems were vital area doors not being
'
closed af ter use and CCTV cameras failed-to function.
Those two
issuss accounted for approximately 75% of the loggable events
during this assessment period.
Improvement was noted toward the
end of the assessment period.
.
The licensee's security organization was adequately staffed.
Positions and responsibilities within the security organization
were well defined, and overtime was adequately monitored and
~,
controlled.
The licensee's security staff had a very low
turnover. The experience level of the guard force was
!
considered a program strength because the average contract
'
security staff had about ten years of onsite experience. The
turnover rate for this assessment period was about 2%, which is
considered excellent.
,.
The licensee's program for reporting required security events
and keeping the NRC informed of security-related matters was
good.
Required -reports were accurate and timely.
The
licensee's program for logging security events generally
utilized NRC guidance.
In general, security-related records
were complete, well maintained, and readily available.
15
. .
.
7
3
'
'e
e,
i
.
?
e
!
The training and qualification program meets regulatory
requirements. The licensee's security organization identified
the need for additional and more effective tactical response
',
. training. .However, because of the lack of resources, very
)
little of this training was performed this assessment period.
i
2.
Performance Rating
The licensee's performance was rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous
assessment period.
3.
_ Recommendations
I
,
None.
'F.
Engineering / Technical Support
1.
Analysis
Evaluation of this functional area was based on the results
of one routine inspection by regional inspectors, several
inspections by the resident inspectors, and interactions
between the licensee and NRR, and NRR's reviews of licensee
submittals.
,
t
Enforcement history was excellent and had improved with no
violations identified during this assessment period.
Only one operational event led to the issuance of an LER and
this was not significant; it did not indicate any present
programmatic weaknesses.
Management involvement to ensure quality in this area was
adequate. Technical support for operations, outages,
!
maintenance, and surveillances was well defined and effective.
'
Examples of support included the preparation of plant specific
technical guidelines which integrated the Probabilistic Risk
Assessment results into the development of the plant E0Ps; the
completion of projects on schedule with no items needing
i
rework; and the performance of the Corrective Action Review
Boaras, the Technical Review Groups, and the Operating
Experience Review Groups in the review, evaluation, and
scheduling of corrective actions to issues identified by the
licensee, industry, or the NRC. A weakness was noted in the
"
documentation of items discussed by the above listed groups in
that it was difficult to perform a historical review of
recurrent problems. The information is retrievable, but the
existing system is not state-of-the-art.
16
F
[
q
t
,
i
f
.
,
The material for the licensed operator requalification examination,
required additional work after NRC review.
Examples of these
!
L
deficiencies included:
dynamic simulator scenarios were not
!
always detailed enough to track expected operator responses; job
performance measures were not always consistent with procedures;
3
and written exam questions did not always require synthesis of
'
information, rather they often were strictly recall.
l
The licensee's approach to the identification and resolution of
I
technical issues from a safety standpoint was adequate. The
>
preparation of Plant Specific Technical Guidelines for the
!
development of plant E0Ps showed a good engineering resolution
i
to the issue from the perspective of the plant's unique design,
'
!
size, and age.
From these the licensee has implemented a good-
i
set of symptom-based E0Ps, although two minor programmatic
weaknesses were identified:
the lack of a verification and
<
'
validation (V&V) program for E0P revisions and the failure to
include procedures in the referenced E0Ps in the V&V program.
The licensee applied the same plant specific, thorough approach
in rtsponse to the requirements in 10 CFR 55.45 for a plant
,
spr;cific simulator, and in their proposal, accepted by the NRC, to
impeo.e the plant's load rejection capability and secondary
side stability in lieu of implementation of the generic
,
requirements (alternate rod insertion anticipated transient
without scram). Weaknesses were noted in the documentation of
engineering evaluations in the justifications used to declare
i
the containment integrated leak rate test acceptable.
[
The licensee's response to NRC initiatives was adequate. An NRC
audit determined that the response to the Detailed Control Room
'
Design Review met the requirements, and that the response
addressing the Safety Parameter Display System partially met the
requirements.
The licensee was actively pursuing an alternative
i
to a plant-referenced simulator required by 10 CFR 55.45(b)(1)(ii),
and has kept Region III and Headquarters personnel informed of
its progress on this alternative.
Staffing, training, and qualification effectiveness was good.
Turnover was low, and as a result, the plant staff's knowledge
of plant systems remained high.
.
2.
Performance Rating
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 during the
.*
previous assessment period.
3.
Recommendations
None.
17
,
0
c
- e
_
,
G.
Safety Assessment / Quality Verification
'
P
1.
Analysis
Evaluation of this area was based on 12 routine inspections
!
conducted by the resident inspectors and regional inspectors,
meetings with corporate and/or site technical and licensing
representatives, and evaluations by NRR of the licensee
'
submittals for amendments.
The enforcement history in this area was excellent; only one
'
Severity Level V violation was identified, which was of minimal
j
t
safety significance.
Management's involvement to ensure quality was offective
throughout the assessment period.
The licensee increased its
involvement in self-improvement and self-assessment activities.
Late in the assessment period, the licensee conducted a Safety
Systems Functional Assessment of the electrical power
distribution system.
Eleven total observations, none having
high safety significance, were identified.
Corrective actions
will be completed durint .he next assessment period.
,
.
The Nuclear Safety Service Department (NSSD) replaced the
'
Nuclear Safety Board (NSB) in the second half of the assessment
period. This represented a significant charge from a committee
that met in regular semiannual meetings, to one that met every
.
day to review safety concerns at the licensee's two nuclear
facilities.
The previous NSB and new NSSD were-effective; both
performed independent review of plant activities (including
maintenance, modifications, operational problems, and operational
i
analyses); reviewed LERs for completeness; and determined areas
'
that required additional investigation.
The Plant Review Committee (PRC) performed adequately in
initiating investigations and ensuring followup of corrective
actions for previously identified violations, reportable events,
i
and areas of weakness.
The open items for both the PRC and NSSD
were tracked on the licensee's tracking system until completion,
and the licensee actively ensured that scheduled dates for
closures were met. The licensee maintained an environment
that was open to the discussion of problems and provided
opportunities for suggesting improvements. The licensee
formally approved a root-cause analysis program at the end of
the assessment period.
The licensee had performed a 10 CFR 50.59 evaluation of its
plant-specific technical guidelines to ensure that the E0Ps were
>
cnnsistent with the plant design basis, and/or that any actions
outside the design basis had been approved by the NRC in an
appropriate Safety Evaluation Report.
This was viewed as a good
effort.
18
,
G S
,
..
F
L
,
L
The licensee's ability to identify and correct problems was
i
amply demonstrated during a surveillance on the E0Ps.
However,
the licensee conducted only one such audit and the audit was
!
limited to one procedure. The narrow scope of the licensee's
surveillance program in the area of E0Ps prevented the
identification and correction of numerous othec deficiencies
with the E0Ps which were subsequently identified by the NRC.
During this assessment period the licensee has been proactive in
,
'
pursuing resolutions to technical issues.
Licensee management
was proactive in communicating with the region. Most of the
10 CFR 50.59 reviews were detailed and included technical
-
rationale commensurate with their safety significance. The
licensee.made a concerted effort during this assessment period
to ensure that commitments would be met, as evidenced by the
assignment of a full-time plant licensing engineer.
This' action
has resulted in timely action and demonstrated the licensee's
commitment to be responsive to NRC schedules.
During the evaluation period, the licensee adhered closely to
its commitments.
Scheduled submittal dates were met in almost
all cases. Where schedule adjustments were necessary because of
unforeseen events, notification was provided in advance of the
target date and the new submittal date was usually met.
The licensee's Integrated Living Schedule (ILS) provided visibility
and status to NRC-initiated and licensee-initiated safety
issues, and prioritized the application of resources to resolve
the issues.
ILS updates were the subject of meetings among
corporate, plant, and NRC management.
The ILS provides a
mechanism to allocate the use of limited resources on priority
issues. Occasionally, however, the licensee requested time
extensions to complete items.
Furthermore, the updated Final
Hazards Safety Report was not completed on time.
Several
chapters were still in the review process on the commitment
date. The licensee also requested an extension for its simulator
facility.
The licensee responded to generic communications in a timely and
thorough manner as evidenced by acceptable responses to NRC
bulletins and generic letters.
The licensee's submittals in
support of license amendment applications were, in most cases,
complete and demonstrated an adequate understanding of the
safety significance of the proposed changes. When the initial
submittal did not contain enough information for the staff to
complete its review, the licensee promptly and fully responded
to staff requests.
l
19
-.
.
..
.
.
- -
,
O b:
o
9
6'
The onsite QA group continued to perform its functions in a
timely manner.
It.also made three changes in its operation
during the assessment period:
(1) it performed fewer
programmatic-based audits and more performance-based audits;
(2) the improved performance incentive program was temporarily
suspended when the instrument and control department was issued
a Severity Level V violation (under this program, audits were
relaxed for those groups that demonstrated good performance);
(3) a program called " Big Rock Point Operation Closeout" was
implemented to resolve by December 31, 1989, all open event
reports (ERs) and deviation reports (DRs) that predated
L
January 1, 1989. The licensee was aggressive in properly
closing the ERs and DRs throughout the assessment period.
Only three out of the 57 items identified remained open at the
end of 1989, and were still open at the end of the assessment
period. As a result of the program, problems were resolved in
i
a more timely manner.
t
The licensee's site and corporate QA organizations performed
security audits and surveillances on a routine basis. The
extent of these assessments and the qualifications of the
auditors generally appeared adequate to assess technical
i
performance, compliance with requirements, and personnel
)
training / qualifications relating to security.
Licensee responses to audits and surveillance findings were
generally thorough, timely, and technically sound
Safety
review committees and feedback from QA/QC activities were used
to provide critical self-assessments to the corporate management
and to improve work activities associated with plant operations.
Furthermore, the committees were adequately involved in
reviewing and approving changes to operational procedures on
both a regular and emergency basis.
Staffing of the licensee's onsite QA/QC department remained
stable during the assessmnt period.
The staff was composed of
!
l
individuals some of who were former reactor operators who had
extensive plant experience, who exhibited a good understanding
of programmatic requirements, and who demonstrated a high degree
of professionalism.
The site QA/QC staff was supplemented by
corporate personnel during the assessment period, which improved
the resources available to perform audits and inspections.
The training and qualification program contributes to an
,
adequate understanding of work and adherence to procedures as
!
indicated by few personnel errors.
QA/QC staff members
1-
participated in audits at other company locations and attended
l
meetings to. increase their knowledge and understanding of the
QA/QC process.
l
l
l
20
a
,__
_
.
e ,t
_.
- _ - - . - - - -
.- - - - -
- - - - - - - - - - - - - - a
q
gm. ,;
- ,c
e;
e,'
,
,
,
.
,
W.A E4<- .c
. :(
- . .
'/t
>
, ,
4tgy.
.
>-'
-
,
. L. _ 2,.
!.
'\\ .
r
,
'
t
4
, , . ,
<
ta
_
.: j V.!
i v'6
,
2;
Performance Rating
..
. .-
"-
p
. The. licensee's' performance is rated Category 2 improving in:--
this ataa. .The licensee performance was rated Category 2 in
4
h
i
.
id
.t e. prev ous assessment per o ...
.;.
i-
3.
Recommendations
,
1
None,
bn
s
(U
'
[
mi t
.,
f:,
. , --
!
-
-f
,
- i
,
-o
.
i
y.
.ie
m
. $
i
i
'
a,,
'
' *
?
,
ff
' .
r
,
'
>
1
,
,
- .i
j
1
W.
!
. P
is
i i
,
6
i
f
f
1~
<
-t
'. L
r
- i:
i
~
s'}
f
+
'{'$
'
8
3
- e
b
'
T-
~$
e
.[
t
'{
t
r
,-
i
,
' '
.h
3
?
t
'
,
!
,
h
4
- ?
k
k
.#
}
. 9
21
t
,,
y
-i
>
,
,
+
e,f-
t
.p
-
'
x
. ,
.- . .: .. - .
. . , . .
.2,.,--.-.~.-
---. - -
- . - - - ---
- . - -
- ~ = - -
- "
, ,
yC 'b
,
.'
.
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
Big Rock Point began the assessment period in routine power
operation.
Throughout the assessment period, the plant operated at
power levels up to the fuel-conditioning / thermal-hydraulic limits.
During the period, the plant encountered several power reductions and
outages for maintenance, repairs, and surveillance testing.
Refueling activities occurred from June through August 1989. Big
Rock Point ended the assessment period operating in routine
operation.
The plant experienced no engineered safety feature actuations and
one automatic reactor trip. The trip occurred while operating above
15% power and was caused by turbine equipment failure.
Significant outages and events that occurred during the assessment
period are summarized below:
1.
From March 9 to 12, 1989, the plant was shut down for a four-day
maintenance outage to repair valve-stem and flange steam leaks
!
and to remove the No. I condenser circulating water pump and
motor for off-site repairs.
The plant ran, with only the No. 2
circulating water pump operating, at about 75% of licensed
power. On April 4, 1989, the No. 1 condenser circulating water
pump was reinstalled and tested.
It failed the test for operability
due to the impeller being installed backwards. The pump was
removed for repairs and reinstalled. After the pump was determined
operable the plant operated at levels consistent with fuel
'
conditioning and/or thermal hydraulic limits.
'
2.
On April 10, 1989, the reactor was shut down due to a defective
No. 4 turbine governor valve. The defective valve was replaced
I
and the unit was returned to service on April 17, 1989.
3.
On April 17, 1989, the number seven main turbine steam admission
valve failed to its closed position resulting in a turbine load
limit of 76% power. The plant operated at reduced power until
the refueling outage.
4.
On April 23, 1989, the reactor shutdown due to an instrument
bus III inverter failure.
The inverter was repaired and the
unit returned to power on April 26.
5.
On June 6, the plant shutdown for a scheduled 65 day refueling
i
and maintenance outage. Major activities conducted during the
+
outage were the main turbine overhaul, on site testing of all
four RDS valves, rewiring of the control rod drive selector
b
L
22
,
,
_
q
gG b
y
0
0
,.
pressure switches, change out of the final two sets of
i
uninterruptible power supply batteries, the first part of the
recirculation pump room wire replacement project, integrated
leak rate testing, and part 2 of the various pumps and motors
designated for refurbishing in the 3 year oroject to refurbish
all major plant major plant components.
6.
On August 13, 1989, the plant started up on time from the
scheduled 65 day refueling and maintenance outage.
,
7.
On August 22, 1989, a reactor scram occurred when all three
'
neutron wide range monitors tripped on high flux due to
equipment failure in the turbine control system. On August 23,
a reactor start-up was completed.
8.
On August 31, 1989, an UE was declared because of low voltage in
one cell of the alternate shutdown battery bank.
9.
On October 27, 1989, the main turbine bypass valve was
determined to be inoperable.
The reactor was shut down to
perform maintenance.
The cause of the failure was binding of
the valve stem from hardening of Garlock Number 938 packing.
Reactor start-up was completed on November 3.
10.
On December 1, 1989, power was reduced to replace the pilot
valve on RDS Train "B."
11. On January 17, 1990, an UE was declared due to a release of
flammable gas / liquid from a propane storage tank located inside
i
the protected area.
12.
On March 20, 1990, reactor power was reduced to facilitate
repairs to No. I reactor feed pump vent valve and sealing gland.
B.
Inspection Activities
Thirty-three inspection reports are discussed in this SALP Report
(January 1,1989 through April 30,1990) and are listed ir
Paragraph 1 of this section, Inspection Data. Table 1 lists the
violations by functional areas and severity levels.
Significant
inspection activities are listed in Paragraph 2 of this section,
Special Inspection Summary.
1.
Inspection Data
Facility:
Big Rock Point Nuclear Plant
1
Docket No:
050-00155
,
l'
Inspection Report No:
89002, 89003, 89006, 89008 through
i
89010, 89012 through 89030, and 9000?
through 90009.
23
E
a
4 :;o .
g
s'
O
TABLE 1
Number of Violations in Each Severity level
FUNCTIONAL AREAS
I
II
III
IV
V
a.
Plant Operations
1
-
-
-
-
b.
Radiological Controls
1.
l'
-
-
-
c.-
Maintenance / Surveillance
-
-
-
-
-
d.
-
-
-
-
-
e.
Security
-
-
-
-
-
f.
Engineering / Technical Support
-
-
-
-
-
g.
Safety Assessment / Quality
1
-
-
-
-
Verification
,;.
-
__ _
_.
_
TOTALS
1
3
-
-
-
.2.
Special Inspection Summary
The: list of.significant inspections conducted during the Big
Rock Point Nuclear Plant SALP 9 assessment period follows:
a.
During April 17-26, 1990, an E0P Team inspection was
conducted (Inspection Report No. 155/90008).
b.
During May 25 - June 9, 1989, the annual EP exercise was
conducted (Inspection Report No. 155/89010)
-C.-
Escalated Enforcement Actions
'
None.
.0.
Confirmatory Action Letters
None.
E. .
Review of Licensee Event Reports (LERs)
Ten LERs were issued in accordance with NUREG-1022 guidelines during
the assessment period. Table 2 shows the cause code comparison of
SALP 8 and SALP 9 periods. Three of the LERS for SALP 9 were issued
'
,
by- the licensee for informational purposes and were' not included in
the cause analysis.
SALP 9 LER Nos: 89001 through 89009, 90001
r
i
24
,
-
,
-..
.
. . , - - -
,
n
, ,
- c .
-
.: f '.
'
'
.,
,
.g:
t ;g -
,
i
e.
TABLE 2
SALP 8
SALP 9
<
('6Mo.)
(16 Mo.)
CAUSE AREAS
NO.
PERCENT
NO.
PERCENT
l.-
Personnel Errors'
2
(15.04%
6
(85.07%)'
(J
Design Problems
2
(15.04%
0
External Causes
1
('7.07%
0
Procedure Inadequacies
l'
( 7.07%
0
[p
Equipment / Component
7:
(53.08%
1
'(14.03%)'
i)
Other/ Unknown
_0
( 0.00%)
_0
'
TOTALS
10
-100%
-7
100%
P
. FREQUENCY LERs/MO
.83
.44
,
NOTE: The above LER information was derived from the review
'
,
'
' of LERs performed by the NRC staff, and may not completely
-coincide with the' licensee's cause-code assignments.
.
.
-
I
( .'
25
-i
!
,
_ _ _ , . . . - . .
.
.-
. - . . , . _ . . . _ . _ . - - , . . _ - . . , _ . , , , -
-
-