ML20151A915
| ML20151A915 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/30/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20150F844 | List: |
| References | |
| 50-155-87-01, 50-155-87-1, NUDOCS 8804070307 | |
| Download: ML20151A915 (7) | |
See also: IR 05000155/1987001
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Enclosure 3
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ERRATA SHEET
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PAGE LINE NOW READS SHOULO READ
8 48 gaseous releases during gaseous releases
this assessment oeriod until March, 1987,
continued to be.... when the fuel problem
was corrected, continued
to be .......
12 8,9,10 One surveillance on the Deleted
the station battery was not
performed while the
requirement for its performance
was under review by NRR.
22 33,34,35,36 Skill training that was Skills training was
scheduled during the generally conducted on
assessment period was on schedule with
frequently cancelled only minimal impact
because of plant activities, from plant operations.
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and much of the training Significant increase
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provided during the in training man days
assessment emphasized were in evidence
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worker safety rather than when compared to the
l skill, training effort du.'ing
i the previous assessment
l period.
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(Basis for changes explained in Enclosure 1)
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, The enforcement history showed little change; there was one
Severity IV level violation during this assessment period
compared with one Severity Level V violation and one deviat n
during the previous assessment period. The violation, whi
involved a failure to comply with a tech spec action stat ment
during a liquid radwaste release, did not represent a pr grammatic
breakdown.
Staffing in chemistry and radiation protection is ad quate.
The chenistry/ health physics technical staff has st ilized
since the last assessment period. Twelve chemistr / health
physics technicians (a full complement) remain o the staff,
th&y all meet the criteria for qualification in adiation
protection procedures (unsupervised back-shif t coverage).
However, about 25% of the technician staff do not meet the
experience requirements given in ANSI N18.1- 971. Staffing
for the ALARA program appears strained, par icularly during
refueling / maintenance outages.
Management involvement in this function r.rea was evident and
was generally adequate. The formal su vet 11ance program required
by the licensee's Radiation Safety P1 n was implemented, and
actions to strengthen Radiation W Permit (RWP) and ALARA
program weaknesses identified in it and surveillance findings
were progressing during this as ment period. However, more
management attention appears ed for the contamination control
program. Several instances ow-level contamination detected
outside radiologically contr ed areas were noted; these may
have stemmed from continued r liance on conventional hand-held
friskers and consequently i daquate personnel frisking.
Increased staff resource re assigned to contamination control
during this assessment. iod.
The licensee's resporQ4 eness to NRC initiatives was mixed. The
licensee cooperate h the Commission's request to monitor
and report on rad tvity levels to assess the impact of the
Charnobyl ir.cidert. On the other hand, the licensee performed
ti inspection of f el only with NRC prompting and was reluctant
to replace perp' n el contamination detectors (friskers) in
containment a
1
The license approach to the resolution of radiological
technical is 'es has generally been technically sound; however,
the license hAs been slow to resolve questions concerning a
small prim ry-to-seccndary leak in the emergency condenser.
As a re it of continuing fuel cladding problems, radioactive
g r.seou releases during this assessment period continued to be
about a f actor of 6 higher then normal, but well below regula*.ory
limi s. The activity in liquid releases has remained stable;
one unmonitored batch liquid radwaste relea:e and one ina:Nertent
di charge of low-level contaminated water to the sanitary sewer
stem occurred late in the assessment period. Solid radwaste
8
. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
7,
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The enforcement history showed little change; there was one
Severity IV level violation during this assessment pariod
compared with one Severity Level V violation and one deviation
during the previous astessment period. The violation, which
involved a failure to comply with a tcch spec action statement
during a liquid radwaste release, did not represent a programmatic
breakdown.
Staffing in chemistry and radiation protection is adequate.
The chemistry / health physics technical staff has stabilized
since the last assessment period. Twelve chemistry / health
physics technicians (a full complement) remain on the staff,
they all meet the criteria for qualification in radiation
protection procedures (unsupervised back-shift coverage).
However, about 25% of the technician staff do not mces the
experience requirements given in ANSI N18.1-1971. Staffing
for the ALARA program appears strained, particularly during
refueling / maintenance outages.
Management involvement in this functional area was evident and
was generally adequate. The formal surveillance program required
by the licensee's Radiation Safety Plan was implemented, and
actions to strengthen Radiation Work Permit (RWP) and ALARA
program weaknesses identified in audit and surveillance findings
were progressing during this assessment period. However, more
l management attention appears needed for the contamination control
program. Several instances of low-level contamination detected
outside radiologically controlled areas were noted; these may
have stemmed from continued reliance on conventional hand-held
friskers and consequently inadequate personnel frisking.
Increased staff resources were assigned to contamination control
during this assessment period.
The licensee's responsiveness to NRC initiatives was mixed. The
-
licensee cooperated with the Commission's request to monitor
! and report on radioactivity levels to assess the impact of the l
l Chernobyl incident. On the other hand, the licensee performed l
l UT inspection of fuel only with NRC prompting and was reluctant
to replace personnel contamination detectors (friskers) in
containment areas.
The licensee's approach to the resolution of radiological
technical issues has generally been technically sound; however,
the licensee has been slow to resolve questions concerning a
l small primary-to-secondary leak in the emergency condenser.
As a result of continu %g fuel cladding problens, radioactive
gaseous releases until Kirch 1987, when the fuel problem was
corrected, continued to be about a factor of 6 hig M than nctual,
but weil celow regulatory limit *:. The activity in liquid releases
has remained stable; one ununitored batch liquid racWste
release and one inadvertent discharge of low-level contaminated
water to the sanitary sewer system occurred late in the
assessment period. Solid radwaste volumes e nereted have
l
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.. 5"
,
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.
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Enforcement history in this area continues to indicate goo
performance. No violations were identified during the eu rent
and previous assessment periods.
Management involvement in ensuring that the quality of routine
plant surveillances is acceptable as indicated b.v th
timelinuss and effectiveness of surveillances perfo ed during
the assessment period. One surveillance on the st ion battery
was not performed while the requirement for its p forrance was
under review by 3RR. One surveillance in the ar of emergency
preparedntss was inadequate and outdated. Surv
appearedeffectiveinidentifyingdeficiencies.yllances in the component *
or function being tested, indicating technica y sound procedures
and conscientious performance by the picnt s aff. Examples
include reactor depressurization system bat ery low specific
gravity, and low voltage from the reactor rotection system
motor generator set, both of which were d scovered through
surveillances. Management was visibly i volved in the
performance of upgrading surveillar.ces o define procedural
inadequacies, as in the case of the de olopment of a clamping
device for scram inlet valves used d ing control rod drive
accumulator testing. Management wa regularly involved in
the performance of routine surve 11 nces as evidenced by the
periodic review of procedures a d ssignment of a knowledgeable
procedure sponsor.
Special inspections determineh hat ISI and snubbers surveillance
activities had received ade e prior planning and assignment of
priorities and thtt the ac. ties were controlled through the
use of well-stated and defi gd procedures. Records and current
equipment calibrations a aterial certifications were well
maintained indicating f r er evidence of a properly managed
program.
Dveness to NRC recommendations relatirg to
The licensee's resp
ultrasonic examina. s performed to meet the guidelines of NRC
Generic Letter 84 1 "Inspections of BWR Stainless Steel Piping,"
was timely, viable and generally sound.
On the basis of review of deficiencies identified by the
surveillance ess and resolution of the surveillance procedural
inadequacies e licensee is considered to have a conservative
approach to , olution of technical issues from a safety
stendpoint. n-line testing of the main steam isolation valve at
pewer and i roved methods of conducting reactor depressurization
system iso ation valve testing were examples of tais safety
perspetti e.
The lic nsee's staff, who are assigned responsibility for the
survei lance performance and for the accuracy and effectiveness
of su veillance procedures, is of adequate size and is generally
know.edgeable in testing requirements and plant operations.
Rec rds indicated that personnel performing nondestructive
ex minations and snubbers surveillance testing were trained and
rtified.
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Enforcement history in this area continues to indicate good
performance. No violations were identified during the current ,
and previous assessment periods.
Management involvement in ensuring that the quality of routine
plant surveillances is acceptable as indicated by the timeliness
and effectiveness of surveillances performed duri.1g the assessment
period. One surveillance in the area of emergency preparedness
was inadequate and outdated. Surveillances appeared effective
in identifying deficiencies in the component or function being
tested, indicating technically sound procedures and conscientious
performance by the plant staff. Examoles include recctor
depressurization system battery ior specific gravity, and low
voltage from the reactor protection system motor generator set,
both of which were discovered through surveillances. Management
was visibly involved in the performance of upgrading surveillances
to defir.'. procedural inadequacies, as in the case of the development
of a clamping device for scram inlet valves used during control
rod drive accumulator certing. Management was regularly involved in
the performance of routine surveillances as evidenced by the
periodic review of procedures and assignment of a knowledgeable
procedure sponsor.
Special inspections determined that ISI and snubbers surveillance
'
activities had received adequate prior planning and assignment of
priorities and that the activities were controlled through the
use of well-stated and defined procedures. Records and current
equipment calibrations and material certifications were well
maintained indicating further evidence of a properly managed
program.
The licensee's responsiveness to NRC recommendations relating to
ultrasonic examinctions performed to meet the guidelines of NRC
Generic Letter 84-11, "Inspections of BWR Stainless Steel Piping,"
was timely, viable, and generally sound.
On the basis of a review of deficiencies identified by the
"
surveillance process and resolution of the surveillance procedural
inadequacies, the licensee is considered to have a conservative
.
approach to resolution of technical issues from a safety
'
standpoint. On-line testing of the main steam isolation valve at
power and improved methods of conducting reactor depresrurization
system isolation valve testing were examples of this safety
perspective.
-
The licensee's staff, who are assigned responsibility for the
surveillance performance and for the accuracy and effectiveness
of surveillance procedures, is of adequate size and is generally
knowledgeable in testing requirements and plant operations.
Records indicated that personnel performing nondertructive
examinations and snubbers surveillance testing were trained and
certified.
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J. Training and Qualification Effectiveness
1. Analysis
Theevaleationofthisfunctionalareawasbasedontheresult/
of initial licensed operator examinations and related obsery (ions,
resident inspector evaluations, and an inspection conducted o
evaluate the effectiveness of the licensee's licensed and
non-licensed personnel training programs.
Enforcement history in this area represented performan e that
conformed to NRC regulations. No violations or devia ions were
identified during this assesuent period.
Management involvement to ensure quality in this unctional area
has been extensive. Personnel were generally k wiedgeable
and effective in implementing their duties. Tr ining appeared
to be well planned and adequately presented. n cases where -
abnormal incidents had occurred at the plant the licensee had
developed a system to review the event to aluate whether
there was a potentia'i training impact. T training department
activities were guided by procedures tha_1::plemented a well-
In equate training was
definedlicensedoperatorprogram./se
seldom identified as a probable ca f events occurring during
this rating period.
Little progress was made during . assessment period in
providing training to newer m ical maintenance staff
members--a condition also no during the previous assessment
period. The procedural requ ments for both required and
on-the-job training were not et and the Maintenance Department
Training Program has not n evaluated and accredited by INPO.
Skill training that was/; eduled during the assessment period
was frequently cancell ecause of plant activities, and much
of the training provi during the assessment emphasized
worker safet.v rathe an skill. Skill training and worker
protection trainin / s too general, not nuclear plant
specific, and did 1 tie to enhance the effectiveness of the
maintenance staff. However, the on-the-job training conducted -
by an individua creman in electrical maintenance was
effective in vp ading the staff's knowledge in that area.
The license responsiveness to NRC initiatives has also been
extensive. he success rate for initial licensing examinations
in the pas has been good. During this period, all initial
license e ndidates passed the NRC-administered examinations.
In cases where the NRC recommended improvemtnts to the training
progra., such as lessons learned from the IA-2B breaker event,
the 1 ensee was very responsive and the recommendations were '
impi mented in a timely manner.
T licensee maintained a qualified staff and associated
training materials for the conduct of all training activities
22
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,
'
, t
.
' J. Training and Qualification Effectiveness
1. !,nalysis
The evaluation of this functional area was based on the results
of initial licensed operatcr examinations and related cbservations,
resident inspector evaluations, and an inspection conducted to
evaluate the effectiveness of the licensee's licensed and
non-licensed personnel training programs.
Enforcement history in this area represented performance that
conformed to NRC regulations. No violations or deviations were
identified during this assessment period.
Management involvement to ensure quality in this functional area
has been extensive. Personnel were generally knowledgeable
and effective in implementing their duties. Training appeared
to be well planned and adequately presented. In cases where
abnormal incidents had occurred at the plant, the licensee had
developed a system to review the event to evaluate. whether
there was a potential training impact. The training department
activities were guided by procedures that implemented a well-
defined licensed operator program. Inadequate training was
seldom identified as a probable cause of events occurring during
this rating period.
Little progress was made during the assessment period in providing
training to newer mechanical maintenance staff members--a
condition also noted during the previous assessment period. The
procedural requirements for both required and on-the-job training
were not met and the Maintenance Department Training Program has
not been evaluated and accredited by INPO. Skills training was
generally conducted on schedule with only minimal impact from
, plant operations. Significant increase in training mandays were
- in evidence when compared to the training effort during the
previous assessment period. Skill training and worker protection
training was too general, not nuclear plant specific, and did
little to enhance the effectiveness of the maintenance staff.
However, the on-the-job training conducted by an individual
'
.
foreman in electrical maintenance was effective in upgrading the
!
staff's knowledge in that area.
The licensee's responsiveness to NRC initiatives has also been
extensive. The success rate for initial licensing examinations
i in the past has been good. During this period, all initial
!
license candidates passed the NRC-administered eu minations.
[ In cases where the NRC recoamended improvements to the training
i program, such as lessons learned from the IA-2B breaker event,
the licensee was very responsive and the recommendations were
'mplemented in a timely manner.
The licensee maintained a qualified staff and associated
training materials for the conduct of all training activities.
22
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