IR 05000155/1987001
| ML20154B609 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/31/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20154B606 | List: |
| References | |
| 50-155-87-01, 50-155-87-1, NUDOCS 8809140063 | |
| Download: ML20154B609 (33) | |
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SALP 7 l
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t SALP BOARD REPORT
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NUCLEAR REGULATORY COMI5510N i i
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j i SYSTEMATIC A$$E55 MENT OF LICENSEE PERFORMANCE 50-:.55/47001 l Inspect'on Report N l j i i !
Consumers Power Company ;
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Bis Rock Point ,
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i l l Aset) 1, 1986 through Aunust 31. 1987 !
Assessment Per'.od j
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SUMMARY OF RESULTS Overall, the licensee's performance was found to be acceptable and appears generally the same as during the last assessment period. However, during its evaluation, the board identified a lack of aggressiveness in licensee performance over the last several assessment periods which appears in several functional areas. This relates to an apparent tendency on the part of licensee management to expend resources at a level which is not consistent with a finn comitment to excellence. Of the eleven functional
- areas rated during this assessment period, ratings in three areas improved
- and the ratings in three areas declined. Perfonnance in the Plant Operations area improved from a Category 2 rating during the last assessment period to a Category 1 rating this period as a result of improvement in the licensee's administrative control over operations activities, particularly during outages. The Surveillance area was rated a Category 1 based on the timely and effective performance of routine surveillances and the quality of the ISI program. Improvement in the Outages area from a Category 3 rating during the last assessment period to a Category 2 rating during this period was mainly the result of increased management involvement. The Emergency Preparedness area declined in performance from a Category 1 rating during the last assessment period to a Category 2 rating durir.g this period due to a decrease in the licensee's responsiveness to NRC concern Because of sn increase in personnel error-related violations, a decrease in effectiveness in same security equipment, and a lack of adequate planning and investigation of an equipment-tampering event, the Security area was downgraded to a Category 2 from a Category 1 rating during the previous assessment period. No decline in Training and Qualification Effectiveness performance was evident; however, a review of the last assessment period performance revealed a Category 2 rating is a more accurate assessment than the Category 1 rating received during the last assessment perio Four areas sustained Category 2 ratings and one area sustained a Category I rating with continued good performanc Rating Last Rating This Functional Area Period _ Period Plant Operations 2 1 Radiological Controls 2 2 Mainterrste 2 2 Surveil.ance 2 1 Fire Protection 2 2 Emergency Preparedness 1 2 Security 1 2 Outages 3 2 Quality Programs and Administrative Controls Affecting Quality 2 2 Trainir:g and Qualificatio Effectiveness 1 2 Licensing Activities 1 1
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IV. PERFORMANCE ANALYSIS Plant Operations Analysis The evaluation of this functional area was based on the results of routine inspections conducted by resident inspectors based at the plant.
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The licensee's enforcement history indicates little change from the previous assessment period. Two violations were issued (Severity Level IVs); one was issued for mispositioned control rods and one for an improper mode switch positio During the previous assessment period, two violations (one Severity Level IV and ine Severity Level V) were issue '
Management involvement in this area was good. The licensee benefits from Shift Supersisors and line managers who are knowledgeable in the history and operating characteristics of the facility, and these managers generally are deeply involved in both routine and off-normal operational activitie Site management personnel are often present in the control room, comunicate regularly with the Shift Supervisor during all shifts, and tour the plant regularly. Management presence and involvement appear to directly contribute to the generally high levels of housekeeping throughout the facility. However, corporate managers are rarely seen on the site. Throughout the assessment period management became more involved in clearly conveying information, knowledge, and performance expectations to the operations staff and, when directing operator activities, increasingly left less to assumptio The licensee participated in two management meetings at the Region !!! office. The meetings dealt with multiple instances of mispositioned control rods (only one of which occurred during this assessment period) and other personnel errors. Management involvement in addressing operator error problems increased over the assessment period and has generally been effective in preventing operator errors that are rooted in inattentiveness and failure to follow orocedure The licensee made effcetive use of its staff's broad base of experience with the operation of the facility to resolve technical issues with an appropriate emphasis on safety. The licensee was consistently conservative in interpreting Technical Specifications and addressing operational concerns. Examples of this conservatism include developing procedures for on-line testing of the main steam isolation valve, developing a good understanding of the effect of high reactivity rod notches near the calculated critical position for the core reload, and procedures for spent fuel ;)ool operations and fuel bundle remova .~ . .
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Due to the relatively high unidentified leak rates throughout the assessment period, the licensee made several power reductions to investigate and repair leaking components before the leak rateapproachedadministrativeorregulatorylimits. The responsible attitude of the licensee s Production / Performance Superintendent was a significant contributor to the licensee's safety-oriented approach to plant operation durin0 the assessment perio .
The licensee exhibited excellent responsivaness to NRC initiatives during the assessment period and communicated with the resident inspector frequently and offactively on matters related to plant operations. The licensee has an effective program of evaluating and responding te industry and NRC notices and bulletins warning of operational concerns. During the assessment period, tie licensee implemented changes to administrative controls in response to INPO recommendation Staffing in the plant operations area is adequate. A sufficient number of qualified licensed and non-licensed individuals are available to allow for routine shift coverage, training, and outage work without excessive use of overtime. During the assessment period, the operations staff stabilized after the loss of experienced key personnel during the previous assessment, and new persons were added to the staff to ensure adequate future
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i staffin Operator confidence improved during the assessment period as newer staff members gained experience; this was evidenced by the operators' performance during the startups, <
shutdowns, and power reductions that occurred durirg the perio e The staff regularly undertakes projeccs that go beyond routine plant operating duties, which enha%ces plant safety and operator efficiency and effectiveness. P.amples of these projects include a comprehensive rewrite of Off dormal Procedures to ensure consistency among operating thifts, completion of a comprehensive l
' program of plant equipment *,abeling, and steps that were taken to improve interdepartmental communications to streamline '
l coordination of operations and maintenance activities. The plant l
' operations staff participated with health physics personnel to improve radiation work permits and reduce radiation exposur Operational events that occurred during this assessment period indicate a mixture of strengths and weaknesses. Operators in many instances demonstrated their knowledge and expertise in i
responding to off-normal conditions and emergencies. Examples nf this expertise include prompt diagnosis of problems with
i declining instrument air pressure that prevented a plant scram, j
prompt and conservative response to abnormal steam drum levels i
during a surveillance, implementation of compensatory measures I to cool plant equipment that allowed continued operation during a period of unseasonably warm record temperatures, and appropriate response to erratic feed flow and resultant fluctuations in steam drum level during power reduction. The innovative solutions to simulated problems during the Annual Emergency Preparedness
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Exercise and other drills indicated a detailed understanding of plant systems and their integrated operation. Control room
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decorum reflects a high degree of professionalism. Operators routinely make use of procedures and drawings to conduct plant operations and are familiar with the Technical Specifications and supporting administrative requirements associated with plant operation. Operators demonstrated skills in fuel handling and administrative controls during refuelin Detracting somewhat from the staff's otherwise good performance,
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inattention to detail, failure to follow procedure, and failute to recognize and address abnormal indications and condition Three of these errors resulted in the submittal of Licensee Event Reports. Examples include one incident of mispositioned control rods, a failure to perform liquid sampling required by the Technical Specifications, an overflow of radioactive water from the treated waste hold tank, removal of a control rod drive with the mode switch in an unauthorized position, exceeding power escalation administrative limit as a result of Xenon burnout, and performing a batch discharge without using the required process monito Errors declined during the assessment period, indicating management's efforts to reduce the error rate, met with some success. Throughout the period management increased the level of involvement with plant evolutions and '
clearly conveyed performance expectations to the operations staf Through meetings, increased involvement and direction, and heightened emphasis on disciplinary actions licensee demonstrated appropricte concern for the types of human errors occurring. During the assessment period significant progress was made in improving administrative controls, particularly in outage management, a deficiency noted in the previous assessmen . Conclusion The licensee's performance is rated Category 1 in this are The licensee was rated Category 2 during the last assessment -
period. Ir.provement was noted in the licensee's administrative control over operations activities, particularly during outage . Board Recommendations Non B. Radiological Controls Analysis The evaluation of this functional area was b:ted on the results of five inspections performed during whis assessn.:nt period by inspectors based in the region and on routine observeF ons by the resident inspector at the sit *
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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 deviation during the previous assessment period. The violation, which involved a failure to comply with a tech spec action statement during a liquid radwasta release, did not represent a programmatic breakdow Staffing in chemistry and radiation protection is adequat The chemistry / health physics technical staff has stabilized
- since the last assessnent 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 ceterage).
- However, about 25% of the technician staff do not meet the experience requirements given in ANSI N18.1-1971. Staffing for the ALARA program appears strained .particularly during
refueling / maintenance outage 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 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 friskin Increased staff resources were assigned to contamination control during this assessment perio 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 Chernobyl incident. On the other hand, the licensee performed UT inspection of fuel only with NRC prornting and was reluctant to replace personnel contamination detectors (friskers) in containment area 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 small prirary-to-secondary leak in the emergency condense As a result of continuing fuel cladding problems, radioactive gaseous releases during this assessment period continued to be about a factor of 6 higher then normal, but well below regulatory limits. The activity in liquid releases has remained stable; one unmonitored batch liquid radwaste release and one inadvertent discharge of low-level contaminated water to the sanitary sewer system occurred late in the assessment period. Solid radwaste
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volumes generated have steadily declined in recent yecrs as a result of the continued implementation of a volume reduction and segregation program for dry active waste (DAW).
Personal exposures for 1986 and 190'; will apparently average about 150 person-rems per year. 7his is less than the licensee's historical annual average of abot. 250 person-rems. Personal contaminations have not been excessive, averaging about 3 to 6 per month; however, this may be an underestimate resulting from the lack of technologically current contamination detection
. equipment at the plant. The licensee has ordered state-of-the-art whole body frisking units to replace the conventional hand-held friskers. The licensee is now addressing some needed ALARA program improvements (staffing, training, documentation, and RWP usage).
The licensee performed well in confirmatory measurements for
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both radiological and nonradiological analyses. Plant water chemistry appears to be generally well maintained, largely through the exercise of tight controls on conductivity. This, in turn, limits concentrations of critical ionic species such as chloride and sulfate. The lack of a formal water chemistry control program based on the BWR Owners Group Guidelines is a weaknes . Conclusion The licensee is rated Category 2 in this area. This licensee was rated Category 2 in this area during the last SAlp perio . Board Recommendations Non C. Maintenance
. Analysis The evaluation of this functional area was based on the results of routine inspections by the resident inspector and one special inspection by a team of region based inspectors and consultants to verify compliance with the electrical equipment environmental qualification (EEQ) requirements of 10 CFR 50.4 The enforcement history in this area indicated the same level of performance during this assessment period compared with the previous assessment. During this period no violations were issued. One unresolved item associated with failure to maintain a Limitorque actuator and qualified Butyl rubber cables was identified during the special inspectio . _ . ._ - . -
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Staffing in this area appears adequate to accomplish routine maintenance activities without a significant backlog of maintenance orders. The site staff was supplemented during major outages by travel crew personnel. The impact resulting from loss of experienced key personnel, noted during the previous assessment period, was of little significance during this assessment period as the mechanical maintenance group l stabilized and individuals gained experience. Transfer of l several repairmen from travel crews resulted in a slight increase in the staff size, and there was some movement of
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/ groups. Instrument and control technician staffing remained constant and the number of experienced personnel was sufficient to meet routine surveillance and maintenance needs and outage 1 requirement Mechanical maintenance training was inadequate as discussed in Section J (Training and Qualification Effectiveness) of this
- SAl Management involvement was adequate to ensure quality. Vendor expertise was used, where appropriate, such as in the resolution of problems with control rod drives and reactor depressurization system (RDS) auto test clock circuitry. Management gen 6ra11y was proactive in the and maintenance identification problems and resolution that threatened of eng(ineering plant operation such as the rising levels on Lake Michigan and the erosion of steam piping). Management involvement, however, was not sufficient to ensure compliance in the EEQ progra In addition, engineering involvement in the preparation and review of the EEQ files, which establish the qualification of components to 10 CFR 50.49 requirements, failed to demonstrate the qualification of Limitorque valve actuator MO-7068 and Polyethylene and Butyl rubber cables. Enforcement action regarding these failures is currently being reviewed. Management was not aggressive in providing appropriate skills training for newer employees with limited nuclear or plant specific experience. While employees -
received some general worker training and on the job instruction, management made little progress in upgrading the mechanical /
electrical staff's skill levels, a condition noted in the previous assessment perio Management often showed evidence of an acceptable approach to resolution of technical issues from a safety standpoint, such as through corrective action for loose torque brackets on motor-operated valves and a voluntary testing program of high-flow piping following an incident at another facility. However, the
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safety perspective was minimal in several instancis, including (1) the practices to determine the as-found set points on steam drum relief valves, (2) the decision not to rewire the N control rod drive (CRD) pump for Appendix R use, and (3) the failure to aggressively diagnose and correct emergency condenser primary-to-secondary leakag ' *
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The licensee's responsiveness to NRC initiatives was generally '
I acceptable, as evidenced by the replacement of the diesel fire pump engine, the placement of dust covers on core spray motor-operated valve actuators' stems, and the resolution of the EEQ splice deficiencie The licensee was generally effective in responding'to operational events requiring maintenance action. The licensee s staff was ,
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particularly effective in implementing the source range nuclear instrumentation modification, in resolving problems with a
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defective shipping cask, and in overhauling motor-operated valves.
Facility changes and engineering packages were generally well documented and technically sound, although they often reflected the staff's need for additional knowledge of quality assurance requirements. The licensee has an effective program for responding to NRC and industry bulletins and notices that warn
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of engineering or operational problem .
Improvement in Preventive Maintenance practices, an issue addressed in two previous assessments, has been limited to the start of a predictive analysis program (using vibration monitoring of rotating components) and the licensee's voluntary program of pipe thickness inspections which were implemented during the assessment period and resulted in repairs to degraded components and piping. Although the licensee devotes resources to aging plant equipment on an as-needed basis when operating characteristics warrant attention (as in the case of the control rod drive system components), the licensee continues to operate without a fully proactive maintenance progra . Conclusion The licensee's performance in this functional area is rated Category 2. In the last SALP period, the licensee was rated category 2 with a declining trend. The elimination of the downward trend results from observing the effectiveness of the maintenance, I&C, and Engineering staffs in maintaining the material condition of the facility. The board noted the licensee's marginal performance in addressing EEQ requirements during this and previous assessment period . Board Recommendations Non Surveillance Analysis The evaluation of this functional area was based on the results of routine inspections conducted by the resident inspector and two inspections by region based inspectors who reviewed the inservice inspection (ISI) of piping and system component welds and snubbers surveillance and functional testin ~
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Enforcement history in this area continues to indicate good performance. No violations were identified during the current and previous assessment period Management involvement in ensuring that the quality of routine plant surveillances is acceptable as indicated by the timeliness and effectiveness of surveillances performed during the assessment period. One surveillance on the station battery was not performed while the requirement for its performance was under review by NRR. One surveillance in the area of emergency
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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. Examples include reactor depressurization system battery low 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 define procedural inadequacies, as in the case of the development of a clamping device for scram inlet valves used during control rod drive -
accumulator testing. Management was regularly involved in the performance of routine surveillances as evidenced by the periodic review of procedures and assignment of a knowledgeable procedure sponso 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 defingd procedures. Records and current equipment calibrations and material certifications were well maintained indicating further evidence of a properly managed progra The licensee's responsiveness to NRC recommendations relating to ultrasonic examinations performed to meet the guidelines of NRC Generic Letter 84-11, "Inspections of BWR Stainless Steel Piping," -
was timely, viable, and generally soun On the basis of a review of deficiencies identified by the
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surveillance process and resolution of the surveillance procedural I
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 depressurization system isolation valve testing were examples of this safety perspectiv 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 operation Records indicated that personnel performing nondestructive examinations and snubbers surveillance testing were trained and certifie i
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. Conclusion The licensee is rated Category 1 in this area on the basis of the timely and effective performance of routine surveillances and the quality of the ISI program. The licensee was rated Category 2 du ing the previous assessment period. Improvement was noted in the timely performance and administrative control of the surveillance progra . Board Recommendations
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Non E. Fire Protection Analysis The evaluation of this functional area was based on routine inspections by the resident inspector and on the results of one special inspection (including four site visits) conducted by region based inspectors and their consultants. This special inspection began before this evaluation period, but it was completed during this assessment period; therefore, the inspection was not rev'.ewed during the previous assessment period. The special inspection was conducted to determine the adequacy of the facility's post-fire safe shutdown methods, and included a partial review of the routine fire protection program. A meeting
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to further clarify and discuss the licensee's post-fire safe shutdown methodology was held at NRC Headquarters on March 31, 198 The enforcement history in this area indicated a decline in performance as a result of the above-mentioned special inspectio During the assessment period, three violations (two Severity Level IV and one Severity Level V) were identified, compared with no violations during the previous assessment perio These violations concerned (1) the lack of a fixed fire suppression system or exemption for the screenwell and pump house; and no alternate shutdown capability provided for that area; (2) inadequate corrective actions in resolving emergency li9 hting system deficiencies; and (3) failure to adhere to fire protection combustible control implementing procedures. Of additional importance during the initial inspection visit (December 1985) was the licensee's lack of documentation preparation showing the necessary equipment and systems needed to safely shut down the plant during a postulated worst-case Appendix R fire. Control of combustibles was not consistently safe. In addition to the violation noted above combustibles were found mixed with non-cor5ustibles in several storage areas on several occasions. Combustible control inside containment was in evidenc *
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Management involvement in meeting the requirements of 10 CFR Part 50, Appendix R was lacking, as evidenced by insufficient documentation to demonstrate compliance with the requirement Management involvement in ensuring the quality of fire brigade performance was evidenced during drills, during three actual fires that occurred during the assessment period, and by compensatory measures taken when maintenance required interruption of fire -
water to containment. Management supports fire prevention activities and fire-fighter training. Management also takes an active role in ensuring a generally high level of cleanliness
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throughout the plan The licensee's approach to resolution of technical matters from a safety standpoint lacked supporting documentation and technical thoroughness as evidenced by the findings of the special inspection. It was necessary for the inspection team to make several return visits to the site and to conduct
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technical-level meetings at the site and at headquarters, indicating that the licensee's technical staff lacked a clear understanding of the overall safe shutdown aspects of Appendix While the staff responsible for routine fire protection appears qualified and sufficient in size, sufficient consultant resources were not available to the licensee to assist in resolution of Appendix R issue The licensee in several instances demonstrated an initial unresponsiveness to NRC initiatives, but eventually complied with regulatory requirements. Examples of the requirements included replacing the diesel fire pump during the 1987 outage, addressing Appendix R requirements, and upgrading welding area . Conclusion The licensee is rated Category 2 in this area. The Itcensee's rating is based on a combination of the apparent violations identified above and its lack of documentation of equipment and systems needed to safely shut down the plant. Routine fire
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detection, prevention and response throughout the assessment was considered by the board to be adequate. The licensee was rated Category 2 during the previous assessmen . Board Recommendations Non F. Emergency Preparedness Analysis lwo annual emergency exercises and one routine inspection were performed during the assessment period. One weakness requiring corrective action was identified in the 1986 exercise, compared l with none in the 1985 exercise. No weaknesses were identified I in the unannounced, off-hours exercise conducted this yea . .--
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One Severity Level IV violation was identified in the routine inspection, which was similar to one of two Severity Level V violations identified during the previous SALP period. This latest violation involved inadequacies relating to the annual independent audit of the emergency preparedness (EP) progra The fact that similar violations were identified in the same area for successive SALP periods indicates a less than satisfactory response to NRC concerns. In addition, the Senior Resident Inspector issued a Severity Level IV violation for a delayed repair of a primary emergency telephone line to
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periodic communications test The EP program has benefitted from the appointment of a new Emergency Planning Coordinator (EPC) in September 1986. The new EPC conducts all EP training at the site, rather than at
- the Midland site, as was done in the past. This relocation of training is considered an improvement over previous arrangement Dose assessment training has been improved and revised to include periodic hands-on problems, reducing a reliance on just classroom training. However, examination of the training program revealed the need for improving the documentation and maintenance of pertinent training records and the need for improving record retrieval capabilit Staffing for key emergency response positions has been adequate with authorities and responsibilities well define Performance of the emergency response personnel, as demonstrated in the two exercises, is adequat Two events occurred in the assessment period that activated the Emergency Plan. Each event was correctly classified as an Alert, and notifications were made in a timely manner to offsite agencies, including the NR . Conclusion Licensee performance is rated Category 2 in this area. The licensee was rated Category 1 in this area during the previous assessment period. The rating was downgraded to a 2 based on a decrease in the licensee's responsiveness to NRC concern . Board Recommendations Non G. Security l
l Analysis The evaluation of this functional area was based on the results of one routine and two allegation-related inspections conducted by physical security inspectors from the region and inspections l
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l conducted by the resident inspector during routine observation of security activitie The enforcement history represented a decline in licensee performance during the assessment period. Although no violations were formally cited during the inspections, four licensee identified violations were noted as a result of followup on Security Event Reports, allegations, or resident inspector input No violations were identified during the last assessment perio Three of the licensee-identified violations were caused by
- personnel error. In addition to the errors involving violations, another personnel error pertaining to the inadequate search of
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items being taken into the protected area resulted in a Confirmatory Action Letter being issued on July 2,1987 to '
confirm corrective actions implemented to resolve the issu Additionally, a personnel error in programming cardreaders resulted in a Security Event Report being submitted in April 198 Because no cited or licensee-identified violations were noted
. during the previous assessment period, and good performance by the uniformed security force was identified as a program strength, the performance during this period is considered reduced. The personnel error trend noted during this assessment period warrants increased management attentio Management support in ensuring quality for the security program is generally adequate. However, an inspection of an equipment-tampering event, conducted between April 9 and August 6, 1987, concluded that planning for such events was not sufficient and that plant management failed to conduct an adequate l
investigation of the event. The previous SAlp report identified j
aging security equipment as a factor in the declining performance of the security organization. An inspection conducted in
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l January 1987 noted a deteriorating security assessment capability and necessitated NRC's request for a written response addressing management actions and timeframes for resolving the concer The deteriorating quality of the assessment system had also been identified by licensee security audits and by the Regulatory -
Effectiveness Review inspection conducted during this assessment perio Senior management support for upgrading security equipment was evident during the last quarter of the assessment period. The ongoing closed-circuit television system upgrade program is thorough and extensive, but the program will not be completed ( until the next assessment period. Ir. addition, the new x-ray and metal-detector equipment that has been ordered will not be available until the next assessment period. Although management action has been taken to improve equipm:nt performance and reliability, the actions were not implemented in sufficient time to improve equipment performance for this assessment perio \ - - _ _ _ _ _ _ _ _ _ ___ __ _ _ _
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l The previous SALP report noted low morale in the security !
organization because the security force did not have a contrac A contract has now been rr.tified by the security force. The morale issue will be ovaluated during inspections for the next assessment perio Staffing levels appear adequate. A new Security Director was assigned during this assessment period and has been instrumental in efforts to upgrade security equipment efforts. The new Plant Superintendent assigned during this assessment period
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has shown a keen interest in the security organization and has supported program upgrade efforts. Supervisory personnel
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assigned to shifts provide strong day-to-day supervisio Attention to detail by security officers and some supervisors is required to reduce personnel error and warrants added emphasis by supervisor * The licensee has been generally responsive to resolving NRC specific concerns. Several corrective actions in response to a Reguistory Effectiveness Review inspection were initiated before rece pt of the inspection report. The corporate security staff closely monitors inspection results and provides timely and sound technical solutions to inspection and licensing issue Security audits are performed by the corporate staff and meet security plan requirement Training for the security force continues to be adequate and procedures are adequate to implement security plan requirements and to define appropriate responsibilities. Two administrative weaknesses were noted during a January 1987 inspection that have subsequently been resolve Three Security Event Reports (SERs) were issued by the licensee during this assessment period, compared to one event reported during the SALP 6 period. One SER resulted from personnel error, one event was equipment related, and the third report was informational in natur . Conclusion
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The licensee's performance is rated Category 2 in this are The licensee was rated Category 1 but declining, during f.
i the previous assessment period. The increase in personnel error-related licensee-identified violations and SERs, decreased effectiveness in some security equipment and the lack of adequate planning and investigation of an l
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equipment-tampering m r.t. were the basis for the reduced i ratin . Board Recommendations Non . _ - _ _ _ _ _
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H. Outages Analysis The evaluation of this functional area was based on inspections performed by the resident inspector during the 1987 scheduled refueling outage and the May 1987 outage to correct deficiencies in the Electrical Equipment Qualification (EEQ) program. In addition, one inspection was performed by an inspector from the region in the area of startup core performance testing.
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Enforcement history in this area indicates significant improvement. No violations associated with outage management and control were identified during the assessment period, compared to one Severity Level III violation during the last assessment. Several incidents of personnel error occurred during the outage, including one violation for incorrect mode switch position, pointing out the need for heightened operator awareness during the periods of abnormal equipment and system configurations typically found during outage activitie Operator errors are addressed in the Operations Functional Are Management involvement in the outage process was extensive throughout the assessment period and was generally effective in implementing the licensee's comprehensive plan for improving outage performance. Aggressive management of the outage process was evident in outage preplanning and coordination of activities, and also in supervisor orientation programs for maintenance travel crew Examples of prior planning include (1) the prefabrication of the diesel fire pump foundation and cleanup demineralizer bypass piping, (2) the advance preparation of maintenance orders and protective tagging orders and coordination of that work with Health Physics, and (3) the extensive cleanup activities in the spent fuel poo The licensee's generally acceptable approach to the resolution of technical issues from a safety perspective was evidenced by the quality of the core reload analysis. Detracting from the generally acceptable performance level was the licensee's reluctance to test fuel bundles suspected of leakage and scheduled for return to the reactor for service during the next cycle. At the NRC's insistence the licensee eventually agreed to ultrasonically test suspect bundles. Management's significant involvement in the development and implementation of new approaches to outage management is evidence of appropriate responsiveness to NRC concerns identified during the previous assessment perio Staffing in this area is adequate. The Outage Planning and Material Services groups were staffed with a sufficient number of experienced personnel. The relatively small plant maintenance staff was supplemented by travel crew personnel. Postponement of the requalification cycle training resulted in additional
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qualified operators and a Shift Supervisor available to supplement on-shift personnel during periods of high work activity. The licensee's staffing efforts resulted in significant improvement in outage performanc .
Although the concept of outage management by a dedicated group was not fully embraced by the plant staff, the Outage Planning group was generally effective in the identification and scheduling of maintenance items and coordination among departments. The Material Services Group was often ineffective in pre-staging parts and supporting maintenance activities,
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primarily because of procurement delays associated with facility changes, last minute ordering, inadequate storage facilities, and unanticipated emergent work. Operators were generally effective in preventing duplication of testing, advance tagging order preparation, and efficient fuel handling during refueling. The core reload package prepared by Reactor Engineering was well detailed and resulted in a core with no hot notches and an accurate critical positio The licensee is aware of areas still needing improvement and is taking appropriate action, with some improvement noted during the EEQ outag . Conclusion The licensee performance is rated Category 2 in this functional area. The licensee was rated Category 3 during the previous assessment period. The increased performance level is the result of increased management involvement and investment of significant resources in outage process improvement activitie . Board Recommendations Non I, Quality Programs ind Administrative Controls Affectina Quality Analysis The evaluation of this area addresses two related but separate functions. First, it assesses the licensee's management activities aimed at achieving quality in overall plant operation This assessment in great measure is a reflection of the quality of licensee activities in individual functional areas addressed in other sections of this report. Secondly, this section assesses the licensee's internal, independent quality oversight activities such as those performed by the quality control / quality assurance organization .'
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With respect to the evaluation of management's effectiveness in achieving high quality in operation of the facility, a wide range of subjective and objective performance measures and compliance history in all the functional areas were assesse This evaluation revealed that over the last several assessment periods, licensee management's approach to plant operations, while acceptable in considering nuclear safety, emphasized minimal expenditure of resources necessary to satisfy regulatory requirements or initiative *
Specifically, it was noted that in the case of EEQ and Appendix R,
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t'.4 licensee relied heavily on requests for exemptions and extensions. It was also noted that in the matters of preventiv maintenance, engineering project backlog, control room design review, emergency operating procedures, updating of the Final Hazards Summary Report, construction of adequate and approved material storage facilities, sipping of leaking fuel bundles to
prevent return of leaking bundles to the core, replacement of the diesel fire pump, and development of the quality assurance requirements matrix, licensee resources were not effectively used to achieve a high level of performance in these area Many of these issues spanned several assessment periods, and several issues such as the construction of storage facilities and the Final Hazards Summary Report, will require additional time to resolve. It is noted, however, that with continued persistence by the NRC staff, some of these issues have been resolved satisfactorily. Unresolved issues, such as the engineering project backlog and development of a comprehensive preventive maintenance program will receive additional regulatory i
attention during further assessment With respect to evaluation of the licensee's internal and independent quality oversight activities, results of routine inspections conducted by the resident inspector and two inspections performed by regional inspectors were considere The enforcement history in the Quality Assurance program indicates performance that conforms to regulatory requirements. No violations were identified during this or the previous assessment perio Staffing in the Site Quality Assurance (QA) and Quality Control (QC) departments was generally adequate to function effectively, although one long-standing vacancy occasionally created an added burden for the staff. The site staff is compose'J of knowledgeable individuals with extensive plant experience who exhibit a good understanding of programmatic requirements and a high degree of professionalism. During tne assessment period, the site staff was supplemented by general office personnel during an extensive review and upgrade
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e e of local administrative procedures and the Quality Assurance Requirements Matrix (QARM). Cross-training of site QC personnel to perform QA activities contributes to flexibility in meeting program commitment At the site level, QA/QC staff involvement in plant activities was exemplary throughout the assessment period. Involvement of corporat2 management steadily improved throughout the assessment period as the licensee responded to NRC initiatives to improve Nuclear Operations Department Standards and Administrative
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Procedure Plant management was not always responsive to QA/QC findings and recomendations. One example of the plant staff's reluctance to act on QA/QC findings include documented deficiencies in material control and warehousing practice An additional example was the use of the primary relief valves'
acceptance test data. That data igno-ed the as-found lift pressure and declared the valves ace w table on the basis of subsequent test lif t Site QA/QC staff consistently demonstrated their concern for resolution of technical issues from a safety perspective, indicated by extensive involvement in all areas of plant operatio During the assessment period the licensee successfully initiated a program of reduced involvement of QA in procedure review for selected departments with an exemplary history of compliance with quality requirements. The trial program will eventually result in greater auditor availability for poorer performers. However, site QA/QC reviewers are still heavily relied on by other departments to ensure that quality requirements are incorporated into design changes, projects, or procedures, thus placing an added burden on the staf Licensee performance effectiveness could be improved by -
upgrading the general knowledge level of the plant staff in the quality requirements associated with each department, thus permitting site QA/QC staff to perform only a review functio . Conclusion The licensee performance is rated Category 2 in this are The licensee was rated Category 2 during the previous assessment period. While the performance of the site QA/QC function was considered exemplary, the overall approach to assuring'high quality in all areas detracted from the licensee s effectiveness in this functional area.
. Board Recommendations Non *
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J. Training and Qualification Effectiveness Analysis The evaluation of this functional area was based on the results of initial licensed operator examinations and related observations, resident inspector evaluations, and an inspection conducted to evaluate the effectiveness of the licensee's licensed and non-licensed personnel training program Enforcement history in this area represented performance that conformed to NRC regulations. No violations or deviations were
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identified during this assessment perio Management involvement to ensure quality in this functional area hos been extensive. Personnel were generally knowledgeable and effective in implementing their duties. Training appeared to be well planned and adequately presented. In cases where
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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 progra Inadequate training was seldom identified as a probable cause of events occurring during this rating perio 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 INP '
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Skill training that was scheduled during the assessment period was frequently cancelled because of plant activities, and much of the training provided during the assessment emphasized worker safety rather than skill. 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 are I The licensee's responsiveness to NRC initiatives has also been extensive. The success rate for initial licensing examinations in the past has been good. During this period, all initial license candidates passed the NRC-administered examination In cases where the NRC recommended improvements to the training program, such as lessons learned from the IA-2B breaker event, '
the licensee was very responsive and the recommendations were implemented in a timely manne The licensee maintained a qualified staff and associated training materials for the conduct of all training activitie __ _ _ _ _ _ _ -- -_ _ _- _ _- _ _ .
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Five training programs (electsical maintenance, mechanical maintenance, chemistry, health physics, and technical support and management) had not received INPO accreditation as of the end of this rating period. The licensee had submitted the formal self-evaluation reports to INPO, however, and was awaiting the scheduling of the next INPO visit for evaluatio . Conclusion The licensee is rated Category 2 in this functional area.
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The licensee was rated Category 1 in this area during the last assessment period. The reduced rating is a more realistic appraisal of what this functional area should have been scored during the previous SALP assessment perio . Board Recommendations
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Non Licensing Activities Analysis The licensee is evaluated in this functional area on the basis of its performance relating to licensing actions that were completed or active during the rating period. The specific actions considered in this evaluation are listed in Section V on Supporting Dat A high degree of management involvement in ensuring quality continued during the rating period, as evidenced in the licensee's updates to the Integrated Living Schedule (ILS),
license amendment applications, exemption requests, licensee event reports (LERs), and other licensing correspondence. The primary means for licensee management oversight and control of licensing issues is through the ILS, which was incorporated into the facility operating license just prior to the start of the '
current assessment perioc' The ILS, is a central document used to prioritize and coordir. ate proposed resolutions to issues raised by the NRC or initiated by the licensee to make the best use of available resources to enhance plant safet During the rating period, the licensee's Technical Review Group, comp *ised of site and corporate representatives, met six times and submitted three updates of the ILS for NRC revie These updates have. been consistently thorough and timely and they reflect appropriate management attention to the resolution of significant safety issue The licensee's approach to resolution of technical issues was consistently good throughout the period. The periodic updates to the ILS demonstrated the licensee's thorough understanding of the significance of various safety issues, both in terms of
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proposed technical resolutions and scheduling of prioritie i Inclusion in the ILS of licensee-originated operational and '
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safety issues is further evidence of a comprehensive and responsible approach taken by the license The high quality of the licensing documents submitted to the NRC during the period is a further indication of appropriate management involvement in this area. These submittals (see Supporting Data) were generally timely, technically complete, and infrequently required the exchange of additional
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Hazards Determinations submitted in support of the license amendments were also of good quality. However, in the case of
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the Cycle 22 core reload and hybrid control rod amendments and the issue of EQ of certain electrical cable, an inordinate amount of interaction between the NRR staff and the licensee was required for resolution. Licensee management should anticipate some difficulty in resolving unique, complex technical issues and should ensure that related submittals are sufficient in detail and are transmitted promptly to allow sufficient time for revie The licensee's performance in response to NRC initiatives has generally been good. The ILS has served as a useful tool for incorporating new NRC generated issues and integrating their proposed resolution into a comprehensive plan. An example of this is the recently added issue for Generic Letter 87-02,
"Verification of Seismic Adequacy of Active Components."
Several Systematic Evaluation Program topics were closed out during the period through implementation of the ILS. In l addition, formal responses to generic letters, bulletins, and i
l requests for information were always promptly submitted and ( proposed appropriate action.
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l The licensee has been very cooperative in responding to informal NRC requests for information. Daily plant status or outage reports are currently transmitted directly to the NRR project manager. Internal licensing tracking documents were also !
provided by the licensee for use by the project manage ;
Frequent communications between corporate licensing staff and ,
NRR contributed positively to the successful completion of ;
several licensing activities including the recent corporate ;
reorganizatio Licensee management, licensing, and plant personnel have demonstrated a strong willingness to meet with the NRC staff i to facilitate the resolution of issues. Licensing and plant
- staff participated in a licensing counterparts meeting with the NRR staff in October 1986, in which a broad range of topics was addressed. The licensee also participated in industry groups that were formed to address specific NRC requirements, including !
the Seismic Qualification Utility Group and the Utility Siaulation
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Facility Group. These initiatives improve the effectiveness of licensing interactions between the NRC and the license !
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The exemption requests submitted by the licensee during the period provided reasonable technical justifications for relief from various NRC requirements and exhibited a good level of understanding of the bases for the requirements. These requests also required few followup discussions with NR The licensee has a small, but well-qualified licensing staff that has continued to be very capable in handling licensing activities regarding the Big Rock Point Plant. Corporate and site licensing staff have extensive technical expertise and
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of plant status and all ongoing activities. This expertise has contributed greatly to the resolution of technical issues and minimized the need for further exchanges of information. The cooperative attitude displayed by the licensing staff in frequent communications with the NRR project manager has also improved the efficiency of the licensing process. Licensing submittals during the period were consistently timely, of high quality, and evidenced a good understanding of NRC requirement . Conclusion The licensee is rated Category 1 in this functional area. The licensee was rated Category 1 in this area during the previous assessment perio . Board Recommendations Non l
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V. SUPPORTING DATA AND SUMMARIES Licensee Activities Big Rock Point Nuclear Power Station began its SALP 7 assessment period in preparation for the 1987 refueling outage scheduled for January 1, 198 During preplanning for the outage, the licensee took into consideration the backlog of maintenance orders, vendor testing of fuel bundles, equipment qualifications, and testing of safety-related systems and components. The average unit availability during the assessment period was approximately 72%. During this
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time, three reactor scrams were reported: One scram occurred at greater than or equal to 15% power and was the result of a design problem, and two scrams occurred with no rod movement involved during reactor maintenance shutdown activities. No other engineered safety feature actuations were reported during this assessment
. period. Major events, outages, and shutdowns that occurred during this assessment period are summarized belo Significant Outages / Major Events: January 2 - March 10,1987 - Refueling Outage. Big Rock Point conducted its 21st refueling and maintenance outag . March 19-24, 1987 - A power reduction was initiated to allow repacking of the No. 2 feedwater pump and to investigate a turbine thrust-bearing wear indicator alar . April 2-30, 1987 - A power reduction was initiated to recalibrate a turbine thrust bearin . April 9-13, 1987 - A power reduction was initiated to investigate the reasons for the higher-than-normal unidentified leak rat . May 29 through June 21, 1987 - EEQ Outag , July 24-26, 1987 - The licensee shut down the unit for mainte-nance of the automatic depressurization system reactor valve top assembly in an effort to stabilize the increasing unidentified leak rat . August 10, 1987 - Big Rock Point celebrated its 25th anniversary of operatio Inspection Activities There were 30 inspection reports issued during this assessment period (April 1, 1986 through August 31,1987). Major or significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summar _ _ _ _ _ _ _ _ . _ _ _ _ _ _
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Inspection Data Facility Name: Big Rock Point Docket Number: 50-155 Inspection Report Nos.: 85015, 85022, 86001, 86004, 86006 thru 86015, 87002 thru 87009, 87011 thru 87015, 87017, 87019 i and 8702 '
Table 1 Number of Violations in Each Severity Level
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Functional Areas I II III IV V Plant Operations 2
- Radiological Controls 1 Maintenance Surveillance Fire Protection 2 1 Emergency Preparedness 2 Security Outages
, Quality Programs and
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- Affecting Quality Training & Qualification Effectiveness Licensing Activities I II III IV V 7 1 TOTALS
- Special Inspection Summary
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During the assessment period the following special inspections were conducted: an annual emergency preparedness exercise l
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' was conducted on May 19-21,1986(86008). Additional inspections were performed in the areas of: (1) Appendix R
' requirement inspection (2) Environmental Qualification i
inspection and (3) Regulatory Effectiveness Review (RER)
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4 Investigations and Allegations Review Seven allegations pertaining to activities at Big Rock Point consisting of sixteen concerns were received in Region 111 during this assessment period. Four of the seven allegations and eleven of the sixteen concerns remained open at the end of the assessment period,
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. Escalated Enforcement Actions A pending potential Escalated Enforcement case regarding generic environmental qualification (EQ) areas relating to electrical cable is being reviewed by Region III. No enforcement action was initiated during this assessment period for this case (86013). Licensee Conferences Held Ouring Assessment Period July 21,1986, Regional Offices: Management meeting with
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of Licensee Performance (SALP 6) result . Mar.h 31, 1987 Headquarters Office: Management meeting with licensee representatives to discuss environmenta! qualification issue . April 13, 1987, Regional Office: Management meeting with
licensee representatives to discuss the corrective actions to the electrical equipment cable qualification deficiencie . May 26, 1987, Regional Office: Management meeting with licensee representatives to discuss the licensee's performanc . July 7, 1987, Regional Office: Enforcement conference with .
licensee representatives to discuss environmental qualification l issue . August 6, 1987, Regional Office: Management meeting with licensee representatives to review the licensee's actions to a potential equipment-tampering even Confirmatory Action Letters (CAls)
Three CALs were issued during this assessment perio . CAL-RIII-87-008, dated April 15, 1987, regarding Region III Environmental Qualifications Audit Team identified potentially enforceable findings relating to cable deficiencies and other poor quality electrical condition . CAL-RIII-87-008A, dated June 12, 1987 an update to CAL-87-008), (
j concerned the corrective action the licensee had taken to resolve the EQ deficiencie . CAL-87-011, dated July 1,1987, was in regard to safeguard concern ~
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G. A Review of Licensee Events Reports and 10 CFR Part 21 Reports Submitted by the Licenses Licensee Event Reports (LERs)
Facility Name: Big Rock Point Docket Number: 50-155 LER Numbers: 86003 thru 86006 87001 thru 87009
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The following is a breakdown of LERs issued during this assessment period with a comparison of those issued during SALP 6:
Cause Areas SAlp 6 $ Alp 7 Personnel / Unknown Human 3 3 s
Design Problems 0 3
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External Causes 5 0 Procedure Inadequacies 1 4 Component / Equipment 0 1
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Other 1 2 Unknown 2 0 TOTAL 12 13 NOTE: The above information was derived from a review of LERs performed by the NRC staff and may not completely coincide with the licensee's cause assignments. In addition, this table is based on assigning one cause code for each LER. This does not necessarily correspond to the identification of LERs addressed in the Performance Analysis Section (Section IV) where multiple cause codes may be assigned to each even . 10 CFR Part 21 Reports Non , Analysis and Evaluation of Operational Data '
The results of the Office of Analysis and Evaluation of l Operational Data (AE00) assessment of a sample of 13 LERs i for this assessment period indicated an improvement in Big l Rock Point plant's overall quality of issued LERs. AE00 gave
an average score of 8.9 out of a possible 10 points, compared
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with the licensee's previous overall average score of 7.1.
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AE00 stated that improvements were needed in the identification
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of failed componer.ts, but the quality of the LER text dis-cussions has improved since SALP ,
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H. Licensina Actions NRR Site Visits and Meetings Msy 8, 1986 Meeting with Big Rock Point plant staff to discuss Appendix R issue October 16, 1986 Counterparts meeting to discuss licensing issues (at Bethesda, MD)
March 31, 1987 Meetings to resolve identified EEQ April 13, 1987 deficiencies with CPC, NRR, and RIII
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Jane 22-26, 1987 PM site visit for radiation protection training, discussion of licensing issues, and observation of plant operation . Commission Meetinas Non . Schedyle Extensions March 2, 1987 Schedular exemption for submittal of updated Final Hazards Summary Repor . Exemptions Granted January 16, 1987 Appendix R exemption from recirculation pump oil collection system requiremen February 17, 1987 Appendix R exemption from emergency lighting requirement April 15, 1987 Partial exemption to 10 CFR Part 171 (annual
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fee). License Amendments Issued Amendment 84 May 6, 1986 CR0 surveillance test frequency Amendment 85 May 12, 1986 Report.ing requirements Technical Specification change Amendment 86 July 11, 1986 Minimum shift crew composition Amendment 87 January 28, 1987 Sourco range monitoring instrueentation
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Amendment 88 February 17, 1987 Hybrid control rods Amendment 89 February 19, 1987 Cycle 22 core reload 6. Emeraency/Exiaent Technical Specifications One granted. Amendment 89, issued February 19, 1987. NRR's denial of original Cycle 22 core reload amendment request required resubmittal and expedited handling to support restart
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7. Orders None issued.
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