IR 05000155/1989001: Difference between revisions

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{{Adams
{{Adams
| number = ML20236C267
| number = ML20247K887
| issue date = 12/31/1988
| issue date = 05/24/1989
| title = SALP Rept 50-155/89-01 for Sept 1987 - Dec 1988
| title = App to SALP Rept 50-155/89-01 for Sept 1987 - Dec 1988 Covering Diesel Generator as ESF Sys & Sipping of Fuel & Removal of Bad Fuel
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-155-89-01, 50-155-89-1, NUDOCS 8903220049
| document report number = 50-155-89-01, 50-155-89-1, NUDOCS 8906020045
| package number = ML20236C258
| package number = ML20247K883
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 26
| page count = 10
}}
}}


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Enclosure 1 SALP 8 APPENDIX SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
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SALP'8'
l SALP BOARD REPORT I
U.S. NUCLEAR REGULATORY' COMMISSION   1


==REGION III==
==REGION III==
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I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORi4ANCE 50-155/89001 4 Inspection Report N l Consumers Power Company Name of Licensee l
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SYSTEMATIC ASSESSMENT OF LICENSEE ~ PERFORMANC /89001 Inspection Report:N I Consumers Power Company Name of License Big Rock Point Name of Facility September 1, 1987, through December 31, 1988   I Assessment Perio l l
Big Rock Point Nuclear Pla.nt Name of Facility September 1, 1987, through December 31, 1988 Assessment Period
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l 890602004D 890524 PDR ADOCK 05000155 Q  PDC
Dk kOhjK9 890313
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Enclosure 1 Big Rock Point Nuclear Plant A. Summary of Meeting with Consumers Power Company on March 28, 1989 The findings and conclu:, ions of the SALP Board are documented in Report No. 50-155/89001 and were discussed with the licensee on March 28, 1989, at the Edgewater Inn, Charlevoix, Michiga While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observer The following licensee and NRC personnel were in attendanc Consumers Power Company G. Heins, Senior Vice President R. Nicholeson, Vice President of Energy Supply Services K. Berry, Director of Nuclear Licensing T. Elward, Plant Manager, Big Rock Point Various members of the plant staff Nuclear Regulatory Commission C. Norelius, Deputy Regional Administrator W. Forney, Deputy Director. Division of Reactor Projects (DRP)
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I. Jackiw, Chief, Reactor Projects Section 28, DRP W. Scott, Licensing Project Manager, NRR E. Plettner, Senior Resident Inspector  i l
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B. Comments Received from Licensee Consumers Power s response to the Big Rock Point SALP 8 Board Report dated
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F TABLE OF CONTENTS-      !
April 27, 1989, included several comments that after further evaluation l
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have resulted in revising the SALP Report. These changes are listed in Enclosure (2), Errata Sheet, and corrected pages are included as Enclosure (3).
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i INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . .    .1 i II. S UMMARY O F R E S U LT S . . . . . . . . . . . . . . . . . . . . . 2 l
Replace the pages in arror listed in Enclosure (2) with the corrected pages attached in Enclosure (3) into your copy of the SALP Repor C. Regional Administrator's Conclusions Based on Consideration of Licensee Comments We noted your comments on pages 3 and 4 of your response regarding security. The information contained in your response regarding the ;
i Overview . . . . . . . . . . ............. 2 l Other Areas of Interest . .............. 2 III. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . 3 !
elimination of the Corporate Property Protection group was known at the time of our evaluation and expression of concern. Also, we agree that prompt correction of identified problems should not necessarily be L__-________ _ _ - _ _ _ _ _ _ _ .
'I PERFORMANCE ANALYSIS . . . . . . . . . . . . . . . . . . . .-    5 Plant' Operations . . . . . . . . . . . . . . . . . . . . 5- Radiological Controls . . . . . . . . . . ..-. . . . . . 7 Maintenance / Surveillance . . . . . . . . . . . . . . . . 9 Emergency Preparedness . . . . . . . . . . . . . . . . . 12 Security . . . . . . . . . . .............. 13- ! Engineering / Technical Support . ............ 15' Safety Assessment / Quality Verification . . . . . . . . .    - 17 - SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . . 20 Licensee Activities . . . . . . . . . . ......... 20 Inspection Activities . . . ................ 21 , Escalated Enforcement Actions . . . . . ......... 22 Co'nfirmatory Action Letters (CALs) . . . . . . . . . . . 23 License Amendments Issued . . . ............ 23 -)
' Review of Licensee Event Reports. Submitted      l by the Li cen see . . . . . . . . . . . . . . .  ..... 23 l
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interpreted as a negative trend. Your correction of the problems was l'
adequate; however, they should have been identified soone With regard to Consumers Power disagreement of how the NRC tabulates !
engineered safety features actuations, we have noted your comments and J have requested that NRR review this matter. We will inform you of the i results of our revie j


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l   We concur with your actions to enhance performance based audits and look l
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' INTRODUCTION      l
forward to discussing this matter with your staf l
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The Systematic Assessment of Licensee Performance (SALP) program is an :
The changes in response to licensee comments for paragraphs A, B, E, I and G appear on the Errata Sheet of this Appendix to the SALP Repor !
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I have concluded that the overall ratings in the aff ected areas have not l'
integrated NRC. staff effort to collect available observations land data  l on a periodic basis and to evaluate licensee performance on the~ basis- a;
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of this-information. The program is supplemental, to normal regulatory  j processes used to ensure compliance with NRC rufes and regulation SALP is intended to be sufficiently diagnostic to provide a rational basis for ' ,
allocating NRC resources and to provide meaningful feedback to the licensee's j management regarding the NRC's assessment of.their facility's-performan'ce q in each functional are An NRC SALP Board, composed 'of the staff members listed below, met on  ;
~ February 24, 1989, to review'the observations and data on performance, and !
to assess licensee performance in accordance with the guidance in NRC .. 1 Manual Chapter 0516, " Systematic Asser,sment of Licensee Performance." .The guidance an,d' evaluation criteria are summarized in Section III of this + 3 report. The Board's findings and: recommendations were forwarded to the l NRC Regional / Administrator for approval and issuanc , ,
This report is the NRC's assessment of the licensee's safety performance  1 at Big Rock Point for the period September 1,'1987, through December 31, 198 '
SALP Board for Big Rock Point was composed of;  [  i
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    .T. --i t l * E. Norelius SALP Board Chairman, Director, Division of Radiation - l Safety and Safeguards (DRSS)  !
*H. J. Miller  Director, Division of Reactor Safety (DRS)  l
* L. Forney Deputy Director, Division.of Reactor Projects  j
*T. R. Quay  Acting Project' Director, Office of Nuclear Reactor
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Regulation (NRR)-    j
* L. Axelson Chief, Reactor Branch 2, DRP  l'
I. N. Jackiw Chief, Reactor Projects Section 2B, DRP W. G. Snell  Chief, Emergency Preparedness and Effluents Section  !
* E. Scott Project Manager, NRR    1
* A. Plettner Senior Resident Inspector J. P. Patterson Emergency Preparedness Specialist, DRSS J. R. Kniceley Security Specialist, DRSS D. E. Miller Senior Radiation Specialist, DRSS  ;I M. A. Kunowski Radiation Specialist, DRSS  j A. Dunlop  Reactor Engineer, Technical Support Staff  '
M. P. Huber  Reactor Inspector, DRS  i N. R. Williamsen Resident Inspector    ;
D. L. Schrum Project Engineer, Section 2B, DRP  !
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* Denotes voting members
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II. SUMMARY OF RESULTS
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,. Overview Management continued to demonstrate a high degree of personal
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involvement in overall plant operation and quality programs; it has been aggressive and proactive in response to NRC safety concerns and in the support of quality improvement-initiatives. The effectiveness of improvement initiatives was demonstrated during the last half of the assessment period, especially in improved plant operations and  1 in a reduction of reportable events. However, the number-of reactor
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trips attributed to equipment and personnel errors remained hig Management's continued support of an open communication environment )
and' staff training was eviden Staffing was viewed as.a utility strength; licensee personnel are responsible and forthright in identifying and resolving problems and display a positive safety attitude. Weaknesses were noted in the areas of maintenance, engineering / technical support and safety assessment / qualit verification. Maintenance related weakne'sses include the performance of the traveling maintenance crews, and the large number of equipment l failures causing forced outages. These. problems may be the result of plant aging and the lack of an aggressive prevention maintenance program. The engineering / technical support weakness is the lack' of ,
critical performance requirements in the original design basis  j information particularly as this is needed in replacement of  i outmoded parts. The safety assessment / quality verification  I weaknesses are the timeliness'of completion of certain significan I technical issues, resource allocations, and some non-conservative decisions. The licensee performance was generally good and continued to show overall improvement, and was a good performe l As an example, emergency preparedness improved to a Category 1 as  I a result of improved training, an independent audit program, and excellent interface with offsite emergency response officials,  )
The performance ratings during the previous assessment period and this assessment period according to functional area are given below:
Rating Last Rating This Functional Area  Period  period Trend !
Plant Operations  1  1 Radiological Controls  2  2 Maintenance / Surveillance 2/1  2 3 Emergency Preparedness  2  1 1 Security  2  2 Engineering / Technical Support Safety Assessment / Quality NR  2 !
Verification  NR  2 ,
NR - Not Rated Other Areas of Interest None
 
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III. CRITERIA Licensee performance is assessed in selected functional areas. Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be addcd to highlight significant observation The following evaluation criteria were used to assess each functional area: Assurance of quality, including management involvement and control; Approach to the resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history;
. Operational events (including response to, analyses of, reporting l
of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra However, the NRC is not limited to these criteria and others may have been used where appropriat On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:
Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat Category 2: Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet
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regulatory requirements. Licensee resources are adequate and reasonably I
allocated so that good plant and personnel performance is being achieved. NRC attention may be maintained at normal level .
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Category 3: Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively use NRC attention should be increased above normal level The SALP report may include an appraisal of the performance trend in a functional area for use as a predictive indicator if near-term performance is of interes Licensee performance during the last quarter of the assessment period should be examined to determine whether a trend exist Normally, this performance trend should only be used if both a definite trend is discernable and continuation of the trend may result in a change in performance ratin The trend, if used, is defined as:    l Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Licensee performance was determined to be declining near the close of the assessment period, and the licensee had'not taken meaningful steps to address this pattern.
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    'I PERFORMANCE ANALYSIS          ' Plant Operations- Analysis Evaluation of this functional. area was based on the results of ten. routine inspections by the resident inspector The enforcement history in this area identifie.1 no violation This was an improvement over. the previous assessment period    1 in which two Severity Level IV violations were identifie I i
Management invcivement in this area was excellent. The licensee    j benefits from shift supervisors and line manag'ars who are knowledgeable in the history ;and operating c,heracteristics of    j the facility. These managers.are generally involved in      !
both routine and off-normal operational activities. There was'    ]
constant evidence of prior planning and assignment'of priorities,    i Procedures for control of activities were well-stated,      j controlled, and explici Senior sito management personnel wer q often present in the control room, communicated regularly with    j the shift supervisor during 'all shif ts, ano toured the. plant on    i a regular basis. Management's presence and involvement contributed to the generally high level of housekeeping    ..
throughout the facilit Corporate n.anagement'has frequently  j and effectively been involved in site activities and'has been onsite at least once a quarter. The safety review committees were adequately involved in reviewing and approving charges to operational procedures on a regular and emergency basis,    q t
The licensee's response to the resolution of technical issues    {
from a safety standpoint demonstrated a clear understanding    1 of the issues. Examples were the reducticn in power to fix the    ]
unidentified leak rate before it reached Technical Spec,1fication (TS) limits and the installation of a ,iumper in the source range monitor to maintain a required interlock in the rod block system. Additionally, the licensee exhibited their conservative operating philosophy when the plant was placed in a safe condition after steam was detected in the steam tunnel, which turned out to    I be a leak in the feed water heat exchange '
l l        The licensee's responsivcnass to the resident inspectors initiatives and policies were timely and effective as demonstrated in the
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Enclosure ERPATA SHEET-PAGE  LINE NOW READS SHOULD READ
evaluation of using a control copy to repair a flange stea '
l leak, the placement of controlled procedures at applicable work stations in lieu of operators carrying procedures stamped working only copy, and evaluating potential generic concern identified at other sites. The licensee consistently met expectations with regard to schedule'and conten :
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L ~6 5, 6- ...two engineered ...two diesel li    safety system generator actuations (diesel actuation i generatorstarts),
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Basis: The Big Rock Point Updated Final Hazards Summary Report does not include the diesel generator as an ESF system. Therefore, the words engineered safety system were remo've , 33, 34 Due to an NRC initiativft, Radioactive the licensee sipped fuel gaseous effluent and removed bad fue releases were This resulted in radio- considerably...
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active gaseous effluent releases being consider-ably. . .
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Basis: .The sipping of fuel and removal of bad fuel was perfortned during the previous SALP assessment period and thus is not applin.ble to this SALP assessment perio , 27, 28 The NRC has concerns that The NRC has concerns the quality assurance that the quality surveillance and audits assurance department are not performance... is conducting a minimum number of surveillance and audits that are performance...
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Basis: The original statement regarding performance based inspections was in error. The changed wording recognizes that the QA department does use performance based techniques in their audits and surveillanc l l
Operational events increased.during this assessment period over the previous period indicating a decline in~ performance. .There
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were eight licensee event reports (t.ERs) issued that related to plant operations. Six automatic, reactor trips and one manual reactor- trip, resulting in two. engineered safety system .
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actuations (diesel generator starts), occurred during this assessment period compared with three automatic trips with no . '!
engineered safety. system actuations in the previous assessment
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period. Four of the automatic trips occurred early in the assessment" period with the reactor at 0% power. . One trip was with single rod motion during maintenance testing, and three resulted from spurious trips from the-26 year-old WRNM instrumentation system. Personnel error during switch down- ..
ranging was a contributing factor in one of the three WRNM; spurious trips. The WRNM system was replaced wit state-of-the-art equipment during the 1988 refueling outag The manual trip was caused by personnel error ~during grid synchronization. Two trips occurred. late in the assessment period'with the reactor at approximately 90% power. One wa caused by turbine equipment failure and the other by an offsite electrical line faul In response to the two trips, the licensed operators expeditiously took the correct emergency operating procedure (EOP) actions needed to maintain the plant in a safe condition. All events were promptly- and completely 4 reported. Operators routinely made use of procedures and drawings to conduct plant. operations and were familiar with TS and supporting administrative requirements associated with plant operations. Unit availability decreased during this assessment period to 75.5% from 79.7% during the previous assessment period. The decrease was not indicative of a proble Fire watch personnel carried out their assigned duties in a professional manne Staffing for the plant operations area continues to be excellent. A sufficient number of qualified licensed and non-licensed individuals were available to allow for routine shift coverage, training, and outage work without excessive use of overtime. Total overtime averaged 12% for all operations personnel during the assessment period. Positions were clearly identified and authorities and responsibilities were well-define .
During this assessment period, the licensee developed programs: 'l for task analysis of operators, operator goals toward continuing-professionalism, and'new E0P The fire protection. organization was adequately staffed with well qualified personnel. There is a full-time safety supervisor, who is a dagreed fire protection specialist and is the safety coordinator and. fire brigade-instructo I J
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: Operational events increased during this assessment period over  l the previour period indicating a decline in performance. There were eight licensee event: reports (LERs) issued that related to plant operations. Six automatic reactor. trips and one manual reactor trip, resulting in two' engineered safety system actuations (diesel generator starts),1 occurred during this assessment period compared with three automatic trips with no engineered afety system actuations in the previous assessment period. Four of the automatic trips occurred early in the
%(% ssment period with the reactor at 0% power. One trip was Nnglerodmotionduringmaintenancetesting,and it e sulted from spurious trips from the 26 year-old WRNM 19514 ,
ation system. Personnel error during switch down-  .
rang ng was a contributing factor in one of the three WRNM spurto The WRNM system was replaced with state-o ; e art equipment during the 1988 refueling outage,  j The manua I trip was caused by personnel error during grid  i synchronization. Two trips occurred late in the assessment period with _ actor at approximately 90% power. One was caused by tur e uipment failure and the. other by an offsite electrical line'' . In response to the two trips, the licensed operato1 editiously took the correct emergency operating procedu ) actions needed to maintain the plant in a safe condition 4 events were promptly and completel reported. Operato'r4 ~ u' ly made use of procedures and drawings to conduct Vi d rations and were familiar with TS and supporting admifi r ve requirements associated with plant operations. Unit,a ility decreased during this !
assessr..ent period to 75'.4% 9.7% during the previnus assessment period. The dec  was not_ indicative of a proble t their assigned duties in a Fire watenmanne professional personnel carrie'('g
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Staffing for the plant operations  ontinues to be excellent. A sufficient number  ied licensed and non-licensed individuals were ava y  allow for routine shift coverage, training, and outagg 'without excessive use of overtime. Total overtime averaged,.1 M L all operations personnel ouring the assessment period.; Ws tions were clearly identified and authorities and respons1h 11  were well-define Duringthisassessmentperiod,thelicen(ge s ped programs for task analysts of operators, operator goa s t rd continuing l professionalism, and new E0Ps. The fire prove  organization was adequately staffed with well qualified personne . There is a full-time safety supervisor, who is a degreed gfire protection specialist and is the safety coordinator and firgbrigade instructo _ _ _ _ _ .
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Qym Ercar   i activitics, installation of new whole body contamination monitors, and identified the lack of a formal hot particle i program. These efforts were necessery to improve contamination controls and radiation worker practices,  j
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  , sponsiveness to NRC initiatives was generally good with some ceptions. In response to NRC Information Notice 88-34, the
Training and qualification programs made a positive contribution to the understanding of work and adherence to procedures as indicsted by the' low number of personnel errors, lhe licensee'
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adequately satisfied the requirement of training operators on a simulator by the use of another f acility's simulator. Three replacement exams were administered during the assessment period with a one passing. This was a decrease from the previous ..
q'11 see identified and corrected sen-fuel special nuclear asal accountability problems. 'averal previously identified erns relating to whole body contamination monitors, a tgative controls over high radiation area keys, inservice ins 6 tion (ISI) planning and coordination, skin dose calculation met ology, and gamma spectroscopy were adequately addressed durin t the ssment period. However, followup evaluation of a i
period. Additional discussions are in:the- Engineering / Technical Support area of this report. Two training ~ positions were created and filled during the assessment period. One of the positions is filled by rotating shift supervisors through the position on an annual basis. The second position was created to assiht operations in the job task analysis program. The additional dedicated resources provided a means of feedback to the operator-licensing training program from experienced personnel. Two operations personnel with licenses were. attending college on a
persona gination event was relatively weak; the licensee :
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was slo mprove control of used protective clotning at !
part-time basis during this assessment period. However, the~
contaminatten g ries; and the licensee was lax in maintaining 09j v rs and gloves at frisker station The licensee'sh gpfFpk h to the identification and resolution of radiological 'ttchni issues was generally sound as exhibited by majorg ' s to the RWP system, continued improvements in persp tracking, good hot particle skin i dose assessments, andgre ion of problems with vendor owned shipping casks. A wes1gess 4 v.3 identified concerning the determination of radiol J rotective measures based primarily on previous si i a g job +
licensee has no formal degree program for licensed operator . performance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 1 in the previous assessment perio .. Recommendations Non B. Radiological Controls Analysis Evaluation of this functional area was based on the results of four routine inspections by regional inspectors and ten inspections by resident inspector .
The licensee continues to perform 1 in the radiological confirmatory measurements arei w 3 agreements in 59 comparisons. Licensee performance , f e Radiological Environment Monitoring ?rogram was satisfactory - total station dose (about 210 person-rem in 1987 and $60 erson-rem in 1988) has trended downward over the last sever 41  ment periods and l reflects an improved ALARA performanc4b  to an NRC initiative, I thelicenseesippedfuelandremovedbaq ~ % This resulted in l radioactive gaseous effluent releases be onkiderably reduced
The enforcement history in this area during this period showed improvement with no violations when compared with one Severity Level IV violation in the previous perio Management involvement in ensuring quality was good and had improved since the previous assessment period. -The radiation work permit (RWP) and as low as reasonably achievable (ALARA)
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programs were strengthened and included the' formation of an ALARA Committee. With NRC prompting, an extensive decontamination program was performed in the plant after. many cases of personnel contamination werc detected by the new whole body contamination monitors. Self-assessment of the radiation protection program resulted in increaseo oversight of reactor deck refueling l
during the assessment period, ref.lecting abs of significant i fuelcladdingproblemswiththecurrentfue qamount and !
 
activity of liquid radwaste releases remaine( t an'" acceptable j level. Solid radwaste volumes shipped to licensed burial sites l continue to decline as a result of implementingholume reduction l technique %
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The staffing levels and qualifications of radiation \ protection personnel were generally adeauate to implement the ro4 tine radiation protection and ALARA programs; experienced coetract  l
 
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activities, installation of new whole body contamination monitors, and identified th'e lack of a formal hot. particle ]
program. .These efforts were necessary to improve contamination )
controls and radiation worker' practice Responsiveness to NRC. initiatives was generally good.with some .
exceptions. In response.to NRC.Information Notice 88-34,;the I licensee identified and corrected non-fuel special nuclear I material accountability proolems. Several-previously identified . j NRC concerns relating to whole body. contamination monitors,. 1 administrative controls'over high radiation area. keys, inservice l inspection (ISI) planningiand-coordination, skin dose calculation methodology, and gamma spectroscopy were adequately addressed during the_ assessment period. .However, followup evaluation of personal contamination event was relatively weak; the licensee was: slow to improve. control'of used protective clothing at-contamination boundaries; and the licensee was lax in l maintaining shoe covers and gloves at frisker station The licensee's approach to the. identification and resolution of radiological technical issues-was generally sound as exhibited by major revisions to the RWP system, continued improvements in personal dose tracking, good hot particle' skin dose assessments, and resolution of problems with vendor owned
  :, hipping casks. A weakness was identified concerning the- ,
determination of radiological protective measures based primarily on previous similar job The licensee continues.to perform'well in the radiological confirmatory measurements area with 56 agreements in 59 comparisons. Licensee performance of:the Radiological Environment Monitoring Program was satisfactory. The. total station dose (about 210 person-rem in 1987.and 160 person-rem in 1988) has
,. trended dcwnward over the last several assessment periods and l
reflects an improved ALARA performance. Due to an NRC initiative, the licensee sipped fuel and removed bad fuel. LThis resulted in radioactive gaseous effluent releases being' considerably reduced -
during the assessment period, reflecting the absence of.significant fuel cladding problems with the current fue The amount and l  activity cf liquid radwaste releases remained at an acceptable i
level, Solid radwaste volumes-shipped to-licensed burial sites i
continue to decline as a result of implementing volume reduction technique The staffing levtis and qualifications of radiation protection personnel were generally adequate to implement the routine radiation protection and ALARA programs; experienced contract i
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technicians supplemented the chemistry / health ' physics (C/HP)
staff during refuelin Three C/HP technicians were expeditiously replaced during the early and middle stages of the assessment period. Contract personnel were hired as needed to supplement the-work forc The staffing was increased and stabilized later in the period with no identified adverse effect The training' program was good with some exception The C/HP
    , technician training program was accredited by the Institute of Nuclear Power Operations (INPO) in February 1988. The licensee
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conducted an ALARA engineering course and observation training for plant supervision with emphasis on radiation protection practices. Weaknesses-were noted that related to tracking and scheduling of advanced radiation worker's training and documentation of respiratory prote'ction qualificatio . Performance Rating The licensee's performance is rated Category 2 in this are q l    The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations Non Maintenance / Surveillance Analysi s l
Evaluation of this functional area was based on the results'of i    ten routine inspections performed by the. resident inspectors and I
six routine inspections by regional inspectors. Maintenance and surveillance were separate functional areas in the previous assessment period but have been combined as one functional area for this assessment period.
l The enforcement history in this area has declined from the i previous assessment period when there were no violations in either the maintenance or surveillance area. Three F.i " J ty Level IV violations were identified during this. assess.....c perio The major causes of the violations were inadaquate or lack of procedures for performing maintenance activitie >
Management involvement'and program effectiveness have been evident during plant outages and refueling. activities. Major
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tasks have been well planned and implemented, as have l    continuing plant improvement programs. Three major tasks
;    completed during the 1988 refueling outage were the replacement /
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upgrade of.the WRNM instrumentation system; the testing, l    refurbishing, and modification of the RDS valves; and the replacement of 64 control rod drive scram (CRDS) valve
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diaphragm Problems were encountered in all three tasks that required additional management attention. The problems with the WRNM will be discussed in the Engineering / Technical Support section of this repor The problems with the RDS valves were identified during full stroke testing. After, substantial questioning by the NRC staff, the remaining valves were tested. Subsequently, all four valves were refurbished, modifications were initiated to improve the design, the valves were retested, and a TS amendment was initiated to full stroke test the valve every refueling outag The CRDS valve diaphragm problem was identified during post-maintenance testing and resulted in complete rework of the project. The field maintenance teams used mostly during outages did not perform maintenance up to the standards of the regular plant maintenance personnel. In the case of CRDS valve diaphragm, the initial work practices used were inadequate. Site quality control did not detect the errors during maintenance. Field maintenance team performance continues to be an area of concern to the NR Resolution of technical issu'es was viable, generally sound, and thorough during this assessment period. Occasionally, problems recur before they are effectively resolved, as demonstrated in the CRDS valve problems and neutron monitoring syste .
,        i l  The licensee was responsive to NRC concerns with the maintenance program and identified and corrected programmatic
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and procedural deficiencies in the maintenance area. During this assessment period, the licensee made a management change  l in the Engineering / Maintenance Department to create separate Engineering and Maintenance Departments. The change enabled the new superintendent of maintenance to devote his full time to maintenance activities. The licensee created a six-member team to write new procedures for maintenance personnel and to upgrade the format of existing procedures. Due to an NRC initiative, a root-cause analysis program was developed and is undergoing a trial implementation period before its final formatting and approval. These changes occurred late in the assessment period, making it difficult to assess the impact. A self-assessment in the maintenance area was performed during the assessment period. The licensee has committed its limited resources to resolving the issues of planning and scheduling, writing additional procedures, and improving maintenance tool and equipment control in an expeditious manne Maintenance and surveillance events accounted for three LERs during this assessment period. Maintenance and surveillance work on safety and safety-related systems and components were in most cases well planned and professionally performed with detailed instructions, drawings, and procedures being used at the job site. The work and post-maintenance testing performed
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non-conforming materials (Bulletin 88-05). The licensee was l j
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very responsive in taking actions to resolve allegations that  !
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were turned over by the NRC to the licensee for corrective action .
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s konsiteQAgroupplacedemphasisforitssurveillance
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were well-documented.' 'Except for the CRDS diaphragm problem a small amount of rework was indicative of an effective maintenance program. Corrective action may not be effective in correcting  g the root-cause of the problem as. indicated by: occasional  j repetition of events, such as problems with the steam admission  4 valves and the source range neutron monito ~I
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There has been a significant reduction in.the: plant equipment work request (WR) backlog. The WR backlog had-averaged approximately 180 items at the~ start of the assessment period l and had decreased to'approximately 90 at.the end of the assessment- )
period. A minimal number of preventive maintenance (PM). items-  I'
required deferral during the assessment perio Improvements continue.in the PM program from.the: previous' assessment periods with the increased use of predictive analysis (using vibration and temperature monitoring)_on a variety of equipment. However,.
the large number of forced outages due to equipment failures may indicate that a more aggressive PM program is needed. Plant aging is an area of concern to the'NRC and may require more of the licensee's resources particularly as the' plant age The water chemistry appeared to be under good control as demonstrated by the licensee's trend charts of the various parameters. Although the laboratory had a technician performance testing program and used performance checks on the 4 analyses, the Quality Assurance / Quality Control (QA/QC) program for analytical measurements was weak. The-licensee's staff made only limited use of.QC charts and these were without  t statistically-derived control parameters. The licensee is  1 correcting these weaknesses. The -laboratory facilities, including  '
space and instrumentation, were adequate for monitoring the chemistry parameters. The results of the nor radiological confirmatory measurements program were goo The licensee had 11 of 13 initial comparisons in agreement (85%). The disagreements appeared to be due mainly to problems in reading a calibration curve accurately on a graph. The licensee is extensively
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modifying the chemistry procedures to bring the water ~ chemistry program into conformance.with the Electric Power Research  i Institute Boiling Water Reactor Owners Guidelines. Further, licensee representatives agreed to document-the variance between  ,
their practices and these guidelines,  j The licensee maintains a well-trained and qualified maintenance, surveillance, and chemistry staff. During outages,~ additional'
company maintenance crews are utilized to assist. plant personne The maintenance training program received accreditation by INPO in February 1988. To enhance the training' effort, the maintenance trainer position was changed.to report to'the Big Rock Point training supervisor rather than the Bay City supervinor. Increased attention to career. plans was implemented for all maintenance personnel, including repairme'n and technicians. Additional schools were provided to increase
 
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individuals' skills and knowledge levels. This was a weakness identified in previous assessment period . Performance Rating i
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The licensee's performance is rated Catego y 2 in this are The licensee's performance was rated Category 2 in Maintenance and was rated Category 1 in Surveillance in the previous assessment' perio . Recomme.idations    :
None.
 
D Emergency Preparedness    j Analysis Evaluation of this functional area was based on the results of two routine inspections and one annual emergency preparedness (EP) exercis The enforcement history in this area did not identify any violations in either of the two routine inspection Two Severity Level IV violations in this area were identified during the previous assessment. No weaknesses were identified in the annual exercise. Although the Emergency Response Facility (ERF) appraisal was postponed because the control room design review had not been completed, the meteorology and dose l
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assessment portions of the ERF appraisal were reviewed and reported as part of the exercise report. Both of these areas of the ERF appraisal were considered satisf actor Corporate and site management have been involved in site ]
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activities in an effective manner. Independent audits of the
tions on those systems with the. highest safety s cance, such as the reactor protection system, post ac e system, RDS, and core spray system. The licensee
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  'ntr the probabilistic risk concept in the surveillance and i est. ion program during this assessment. period. The concept is based on core damage / release of fission product '
licensee's EP program were complete, timely, and thoroug A weakness identified in this area in the previous assessment period had been corrected. Manageme.nt attention to the EP program and cooperation with EP personnel has resulted in a better, more professional approach that includes surveillance and reviewing the interfaces between the licensee and state and local governments. A good working relationship is being maintained with Charlevoix County, Emmet County, and the Emergency Management Division of the State of Michigan, Management responsiveness to NRC initiatives has resulted in acceptable resolutions of concerns arising from the licensee's initial submissions. Through management and technical staff-cooperation, several Emergency Action Levels were revised according to NRC recommendations. These changes were documented and responses made to the NRC in less than 2 months in all instance L _ ___-
Twoiprveillances performed using this concept were the ISI and RDSvalyete 9. The enhanced performance incentive program was a pesi icensee initiative to control the use of QA resource's,f involving in-line reviews of procedures and maintenanc rs. The first plant group selected for the programwas)  ent and control department, because of past outst formar.ce. The program has the approval of NRC regiona ,st . Safety review committees and feedback from.QA/QC acti ntie  used to provide critical self-assessments to th o rate management and to improve work activities associated t nt operations. The NRC has concerns that the qualit rance surveillance and audits are not performance based inspg;4@ and may have an inadequate number of hours budgeted to c ' observations of actual work in progres ' d''
 
s Staffing of the licensee's cinsite QA/QC department remair.ed generally stable over the assessmen iod. The staff is composed of technically oriented in is with extensive plant experience who exhibit a good snding of programmatic requirements and exhibit }Agh degree of professionalism. During the asses'een s r d, the site staff was supplemented by corporate person'np  C group was deficient in detecting one work error'  to rework of the CR05 valve diaphragm '
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Two events occurred during the assessment period that activated  ,
the emergency plan.. Each activation resulted in a Notification l of Unusual Event and was correctly classified with notifications  I being made on a timely basis to offsite agencies and the NR l The EP coordinator maintained a file on each event, and  j corrective. actions were taken on any items of concer '
Shift augmentation for emergency response positions has been adequately demonstrated through several call-in drill I When one drill indicated a shortage.of individuals for ce'rtain  j security positions, the EP coordinator took prompt action-to I correct this shortage. Through drills and training, adequate- )
corrective actions have been taken to maintain a viable shift l
augmentation progra The tecining' program has improved since the prior assessment l period. For example, pertinent training records are being )
documented and maintained better, and record retrieval capability is good. Effective in January 1988, the EP training modules were reduced.by combining certain'ones which, in turn, reduced certain redundant emergency. response positions. As an example, a person training for a certain Technical Support. Center support position need not be completely retrained for a similar position in the Emergency Offsite Facility. Records indicate that 145 out of 156 people onsite are trained in emergency preparedness responsibility (93% coverage). Of these 145 persons, 65% have
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participated in two or more drillsLin the past 2 years. .This clearly indicates the extensive scope of current emergency
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preparedness training.
The training and qualification program contri  es an adequate understanding of work and adherencetto p  ures as indicated by few personnel errors. QA/QC sta  rs participated in audits at other company locations and attended  ,
meetings to increase their knowledge and understanding  '
of the QA/QC proces . Performance Rating    f
      \.3 The licensee's performance is rated Category 2 in this 3re Because this is a new area, no rating is available from tie l (
previous assessment perio ' Recommendations    -
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l The licensee's performance is rated Category 1 in this are The licensee's performance was' rated Category 2 in the previous assessment period. This improvement was.the result of improved training, an independent audit program, management responsiveness to-concerns, and excellent interface with offsite emergency response officials.
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Operational events increased during this assessment period over  i the previous period indicating a decline in performance. There  '
Non E. Securi,ty l Analysis Evaluation of this functional area was' based on the results of four inspections (three special and one routine) by regional inspectors and on routine observations of security force activities by the resident inspectors,
were eight. licensee event reports (LERs) issued that related to plant operations.. Six automatic reactor trips and one mar.ual reactor trip, resulting in two diesel generator actuations, occurred during this assessment period compared with three automatic trips with no engineered safety system actuations in the previous assessment period. Four of the automatic trips occurred early in the assessment period with the reactor at 0%
power. One trip was with single rod motion during maintenance testing, and three resulted from spurious trips from tne 26-year-old WRNM instrumentation system. Personnel error during switch down-ranging was a contributing factor in one of the three WRNM spurious trips. The WRNM system was replaced with state-of-the-art equipment during the 1988 refueling outag The manual trip was caused by personnel error during grid synchronization. Two trips occurred late in the assessment-period with the reactor at approximately 90% power. One was caused by turbine equipment failure and the other by an offsite electrical line faul In response to the two trips, the licensed operators ex operating procedureE0P) (peditiously took the actions needed to correct maintainemergency the plant in a safe condition. All events were promptly and completely reported. Operators routinely made use of procedures and drawings to conduct plant operations and were familiar with TS and supporting administrative requirements associated with plant operations. Unit availability decreased during this assessment period to 75.5% from 79.7% during the previous -
assessment period. The decrease was not indicative of a proble Fire watch personnel carried ou, their assigned duties in a professional manne Staffing for the plant operations area continues to be excellent. A sufficient number of qualified licensed and non-licensed individuals were available to allow for routine shift coverage, training, and outage work without excessive use
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of overtime. Total overtime averaged 12% for all operations personnel during the assessment period. Positions were clearly identified and authorities Lad responsibilities were well-define DurIng this assessment period, the licensee developed programs for task analysis of operatcrs, operator goals toward continuing professionalism, and new E0Ps. The fire protection organization war adequately staffed with well-qualiff eo personnel. There is a full-time safety supervisor, uho is a degreed fire protection specialist and is the safety coordinator and fire brigade (  instructor.


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The enforcement history represented a reduction in the  i licensee's performance from the previous period. Two violations j were identified, one Severity Level III violation and one Severity Level IV violation. During the previous assessment period, no violations were issued. The Severity  i Level III violation occurred at the beginning of the assessment 1 period, and a civil penalty was assessed. The vio'lation was for an inadequate vital area barrier that had existed since the plant was constructed, and because of the barrier's location, it was not identified previously by the licensee nor the NR The violations did not represent a significant program breakdown and neither of the violations resulted in direct safety problem Management involvement in assuring quality in this area was adequate. Management support for upgrading security equipment necessitated by aging equipment and NRC concerns was evident as demonstrated by the acquisition of new access control search equipment, completion of the closed circuit television upgrade project, and completion of the fence tightening and soil stabilization project Concerns identified in the previous assessment period were effectively addressed by the license The property protection supervisor (PPS) was very responsive to regional and resident inspector concerns. The PPS and his staff developed a program to analyze security data to determine program performance trends that have resulted in identifying l  potential problems and have helped create a proactive security program. A higher level of security awareness among the general plant work force has reduced the high number of security violations caused by non-security personnel and has strengthened the security progra The licensee's responsiveness to NRC initiatives was adequate -
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when violations and weaknesses were identified. Commitments  i and requirements within the scope of the security plan were  i generally met. When violations and weaknesses were identified, j the licensee took corrective action in a timely and effective manne Security events reported under 10 CFR 73.71 were properly id.'ntified, analyzed, and reported to the NRC as require There were three events reported during this assessment period, which wa= the same number as that reported during the previous assessment period. This low number of events over the two assessment periods was considered excellent. Generally, the licensee ls procedural guidance for the security force was sufficiently detailed to ensure that personnel were knowledgeable of their responsibilities. The licensee's security force has been very stable, which is one of the licensee's strongest security asset The security force morale was good. The
,  increase in morale was attributed to better management interaction and communication with the security forc l
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Staffing levels in the security area were ample. A new PPS was assigned at the beginning of this assessment period because of the resignation of the previous supervisor. The security department's staff was. increased by one at the end of the i
assessment period because of the elimination of the corporate Property Protection Department (PPD) and the reassignment of
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the responsibility to the site. The corporate PPD has been eliminated because of a corporate reorganization. The PPD personnel were knowledgeable of program requirements and problem areas and effectively supported the security progra The external audit function of the PPD was instrumental in identifying and correcting program deficiencies and was identified as a program strength. The NRC has a concern about the loss of the corporate PPD organization in that the function may not be adequately performed by site personnel in the futur The training and qualification program utilized by the licensee was considered acceptable and meets security plan requirement None of the security violations were as a result of deficiencies in the security force training. Communications between site security personnel and Region III Safeguards personnel have been excellen . Performance Rating The licensee's performance is rated a Category 2 in this are The licensee's performance was rated a Category 2 in the previous assessment perio . Recommendations Non F. Engineering / Technical Support Analysis This is a new functional area and consequently was not rated in the previous assessment period. Evaluation of this functional area was based on the results of four inspections conducted by regional inspectors and the routine inspections conducted by the resident inspector The enforcement history in this area identified one Severity Level III violation with civil penalty and one Severity Level IV violation involving the newly-installed WRNM instrumentation system. The Severity Level III' violation was based on equipment qualification (EQ) requirements of 10 CFR 50.49, which was identified in the previous assessment
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activities, installation of new whole body contamination i monitors, and identified the lack of a formal hot particle ;
period. The licensee's identification and corrective' actions for the WRNM violation were prompt. No prior enforcement history is available for comparison because this is a new functional are Management's level of involvement in this area.has been evident in several ways. The Engineering / Maintenance Department was changed to create. separate Engineering and Maintenance Departments. The change enabled the superintendent of engineering to devote his full time to engineering activitie The. superintendent of engineering was appointed to chair the !
program. These efforts were necessary to improve contamination !
Technical Review Group, ensuring that planning and assignment .
controls and radiation worker practice Responsiveness to NRC initiatives was generally good with some exceptions. In response to NRC Information Notice 88-34, the licencee identified and corrected non-fuel special nuclear ,
of priorities were given additional management revie l'
materia'l accountability problems. Several previously identified l NRC concerns relating to whole body contamination monitors, !
Corrective actions taken by the Engineering Department were usually effective except for the neutron instruments. A system engineering concept is not used at Big Rock Point. Project- ,
administratitre controls over high radiation area keys, inservice l inspection (ISI) planning and coordination, skin dose calculation methodology, and gamma spectroscopy were adequately addressed during the assessment period. However, followup evaluation of a personal contamination event was relatively weak; the licensee was slow to improve control of used protective clothing at contamination boundaries; and the licensee was lax in maintaining shoe covers and gloves at frisker station ,
groups were formed to resolve major system problems like the !
i The licensee's approach to the identification and resolution of radiological technical issues was generally sound as exhibited by major revisions to the RWP system, continued improvements in personal dose tracking, good hot particle skin dose assessments, and resolution of problems with vendor owned l
RDS and WRNM. The site maintains-the authority for design
shipping casks. A weakness was identified concerning the j  determination of radiological protective measures based primarily on previous similar job The licensee continues to perform well in the radiological confirmatory measurements area with 56 agreements in 59 l
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comparisons. Licensee performance of the Radiological Environment Monitoring Program was satisfactory. The total station dose (about 210 person-rem in 1987 and 160 person-rem in 1988) has trended downward over the last several assessment periods and reflects an improved ALARA performance. Radioactive gaseous effluent releases were considerably reduced during the assessment period, reflecting the absence of significant fuel cladding problems with the current fuel. The amount and activity of liquid radwaste releases remained at an acceptable level.
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changes and receives support from the-corporate office as circumstances requir The identification and resolution of technical issues from a l safety standpoint were adequate. Engineering evaluations in the !
form of 10 CFR 50.59 reviews were usually well-documented and demonstrated a technical rationale. Improvements were noted
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since the previous assessment period in 10 CFR 50, Appendix R ;
I compliance. The licensee submitted information to demonstrate a more conservative approach for protecting against fire-induced I spurious operations of high/ low pressure interfaces than was required by the NRC. Modification packages showed strength in the area of documentation and general technica1' adequacy. A-weakness exist.s when the licensee is replacing existing plant I equipment on other than a "like-for-like" basis because of i failure to identify critical performance requirements. This is due in part to the lack of original design basis informatio !
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The WRNM upgrade was an example of the problems involved in
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engineering, The WRNM were installed without proper adjustments due to deficiencies in~the drawing specifications and the testing package. Specifically, the receipt and post installation testing of the WRNM system did not. detect vendor misadjustment of the internal gain facto '
Responsiveness to NRC initiatives was generally timely an viable except for the operator licensing examination conducted _
in 1988. The exam had to be cancelled after the examiners arrived at the site, due to the failure of the licensee to provide up to date, accurate reference material. While the i examination was successfully completed in October-1988, considerable NRC time and effort were expended in resolving the problems caused by the inappropriate reference. materia I    _ _ _- __ _O


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  .Two LERs, one of which was informational, were issued during this assessment period. The informational LER concerned lubricants in Limitorque valve operators. Both events were-properly identified, analyzed, and correcte Engineering and technical _ support staffing was adequate, with key positions identified and defined. Turnover involved two vacant positions that were filled within a reasonable tim The staff has varied backgrounds, including mechanical, electrical, civil, and metallurgical engineer I A training program for the engineering and support staff consisted of in-house training and appropriate vendor / industrial l  seminars. The training and qualification program contributed to l an adequate understanding of work and adherence to procedure l The licensee received accreditation for its training and- i qualification program from INP0 ir February 198 l l Performance Rating l
The licensee's performance is rated Category 2 in this are I Because this is a new area, no rating is available for the !
previous assessment perio l Recommendations Non i l
l  G. Safety Assessment / Quality Verification Analysis    I J
This is a new functional area and consequently was not rated in the previous assessment period. Evaluation of this area was based on the results from ten routine inspections conducted by the resident inspectors, assistance from regiona' inspectors, 1 meetings with corporate and/or site technical and licensing representatives, and interaction with NRR project managers of the licensee's submittals for amendments to the Operating Licence, et The enforcement history in this area indicated that major
[  violations were rare and.were not indicative of a' programmatic ,
breakdown. One Severity Level V violation was identified l involving the failure to adequately control a procedure. No ;
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prior enforcement history was available for comparison because L
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this is a new functional are Management's involvement to ensure quality was adequate throughout the assessment period. The licensee has increased j its involvement in self-improvement and self-assessment '
Solid radwaste volumes shipped to licensed burial sites continue to decline as a result of implementing volume reduction technique The staffing levels and qualifications of radiation protection personnel were generally adequate to implement the routine radiation protection and ALARA programs; experienced contract l
activitie The Nuclear Safety Board was effective in perfonning independent reviews of plant activities, including maintenance, modifications, operational problems, and
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non-conforming materials (Bulletin 88-05). The licensee was very responsive in taking actions to resolve allegations that were turned over by the NRC to tne licensee for corrective action The onsite QA group placed emphasis for its surveillance inspections on those systems with the highest safety significance, such as the reactor protection system, post accident system, RDS, and core spray system. The licensee introduced the probabilistic risk concept in the surveillance and inspection program during this assessment period. The concept is based on core damage / release of fissior, product Two surveillance performed using this concept were the ISI and RDS valve testing. The enhanced performance incentive program was a positive licensee initeative to control the use of QA resources for work involving in-line reviews of procedures and maintenance orders. The first plant group selected for the program was the instrument and control department, because of past outstanding performance. The program hcs the approval of NRC regional staff. Safety review committees ard feedback from QA/QC activities were used to provide critical self-assessments i to the corporate management and to improve work act vities associated with plant operations. The NRC has concerns that the quality assurance department is conducting a minimum number of surveillance and audits that are performance based inspections ,
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and may have an inadequate number of hours budgeted to do !
operational analyses. The Board was also effective in reviewing
observations of actual work in progres '
'LERs for completeness and determining areas that required additional investigation. The Plant Review Committee (PRC) had performed adequately in initiating investigations and ensuring followup of corrective actions for previously. identified violations, reportable events, and areas of weakness. The NRC was concerned with the PRC's non-conservative decision to continue up in power following the' discrepancy in WRNM indications and heat balance calculations during initial testing of the WRNMs. Also o concern was the licensee's inquiry for a possible TS change to pull rods to go critical without proper source range indicatio The open items for both the PRC and Nuclear Safety Board were tracked on the licensee's tracking system, and the licensee was active in ensuring that scheduled dates for closures were me The licensee maintained an open environment for the discussion  l of problems and improvement opportunities. Also, at the urging of the NRC, a trial root-cause analysis program was implemente J at the end of the assessment perio A number of technical issues, some of thera unique to the Big  l Rock Point plant design, were resolved, including a major    ;
Staffing of the licensee's onsite QA/QC department remained generally stable over the assessment period. The staff is composed of technically oriented individuals with extensive ;
effort on RDS valve testing requirements. 0ther issues remain  I open, including the validation and verification (V&V) of software for the new power range monitoring instrumentation, an exemption  i from fire protection requirements relating to the screenhouse,  ,
plant experience who exhibit a good understanding of programmatic requirements and exhibited a high degree of professionalism. During the assessment period, the site staff was supplemented by corporate personnel. The QC group was deficient in detecting one work error that led to rework of the CRDS valve diaphragm The training and qualification program contributes to an adequate understanding of work and adherence to procedures as ir.dicated by few personnel errors. QA/QC staff members participated in audits at other company locations and attended meetings to increase their knowledge and understanding of the QA/QC proces l 2. Performance Rating    l The licensee's performance is rated Category 2 in this are l Because this is a new area, no rating is available from the l previous assessment perio ' Recommendations    l
revision of the Offsite Dose Calculation Manual (00CM), E0Ps,  I plans for cont-ol room ~ simulation, and station battery service test requirements. The licensee displayed a good understanding   l of the safety issues and was generally responsive to the staff,  i l
The licensee's Integrated Living Schedule (ILS) was used to provide visibility to and status of NRC-and licensee-initiated safety. issues and to prioritize the application of resources to resolve the issues. ILS updates were the subject of two licensee-requested semiannus.1 meetings among corporate, plant, and NRC managemen The ILS clearly provides a mechanism to justify focusing limited resources on a few high priority issues. However, the RDS and turbine load rejection problems-have for years been both high priority and unresolved issue ~
.Further examples of repeated schedule extensions were for-the sof tware V&V, ODCM revisions, and Final Hazards Safety Report updates. These frequent extensions raise questions about adequacy of resources being allocated to ILS items. Shile it is acknowledged that improvements in resource commitments have been made, additional emphasis is neede Licensee responsiveness to generic communications were timely and thorough, as evidenced by-their acceptable responses to NRC bulletins on fastener testing (Bulletin 87-02) and


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  "    om e wo* U power Ykt President Nwlear Operations
  % M ERlNG nlKNIGAN'S PROGREK5 General othces- 1945 West Parnall Roed, Jackson MI 49201 t617) 7884463 April 27, 1989
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46 Nucles.r Regulatory Ccmmission Document Control Desk Washington, DC 20555
non-conforming materials (Bulletin 88-05). The licensee was very responsive in taking actions to resolve allegations that were turned over by the NRC to the licensee for corrective action The onsite QA group placed emphasis for its surveillance inspections on those systems with the highest safety significance, such as the reactor protection system, post accident system, RDS, and core spray system. The licensee  l introduced the probabilistic risk concept in the surveillance  ;
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and inspection program during this assessment period. The concept is based on core damage / release of fission product l Two surveillance performed using this concept were the ISI and  l RDS valve testing. The enhanced performance incentive program  I was a positive licensee initiative to control the use of QA l resources for work involving in-line reviews of procedures  '
DOCKET 50-155 - LICENSE DPR-6 - BIG ROCK POINT PLANT -
and maintenance orders. The first plant group selected for the program was the instrument and control department, because l of past outstanding performance. The program has the approval of NRC regional staff. Safety review committees and feedback from QA/QC activities were used to provide critical I self-assessments to the corporate management and to improve work activities associated with plant operations. The NRC has concerns that the quality assurance surveillance and audits are not performance based inspections and may have an inadequate number of hours budgeted to do observations of actual work in progress.
SALP 8 RESPONSE NRC letter dated March 13, 1989 contained the Systematic Assessment of Licensee Performance (SALP) No. 8 Board Report for our Big Rock Point Nuclear  i I
Plant. This letter provides Consumers Power Company's written ecmments regarding that repor Consumers Power Company thr. uke the NRC for the feed'oack on activities at Big Rock Point from the period of September 1, 1987 through December 31, 198 We believe that all of the concerns identified will be addressed very effectivel With regard to r.oncerns associated with the living Schedule, in 1988 we completed three high priority items, specifically: correction of Reactor Depressurization System valve problems; Neutron Monitoring System upgrades; and resolution of steam drum relief valve concerns. We believe that these actions have made and will make a continued positive contribution toward ,
improved plant safety and availability. Our two highest priority items are now receiving accelerated attention and resources. We fully expect actions in 1989 and in the 1990 refueling outage to address these issues. Also, in September 1988, we changed the plant organization to increase management attention and the total engineering resources applied to our Living Schedul With regard to the concerns associated with plant age and plant maintenance, we are taking actions which we belie.ve will result in significant improvements. In September 1988, the organization was revised to re-establish a full time maintenance superintendent whose responsibilities are solely maintenance. In early 1988, we continued to enhance our Predictive Maintenance Program in the area of vibration analysis of rotating equipment. In late S
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l i Staffing of the licensee's onsite QA/QC department remained
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generally stable over the assessment period. The staff is composed of technically oriented individuals with extensive plant experience who exhibit a good understanding of programmatic requirements and exhibited a high degree of professionalism. During the assessment period, the site staff was supplemented by corporate personne The QC group was deficient in detecting one work error that led to rework of the i CROS valve diaphragm ;
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i The training and qualification program contributes to an  j
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l adequate-understanding of work and adherenc.e to procedures
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as indicated by few personnel error QA/QC staff members
! participated in audits at other company locations and attended I
meetings to increase their knowledge and understanding .
of the QA/QC proces l 2. Performance Rating The licensee's performance is rated Category 2 in this are Because this is a new area, no rating is available from the previous assessment period.


I 3. Recommendations None.
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Nuclear Regulatory Commission Big Rock Point Plant
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V. SUPp0RTING'OATA AND SUMMARIES Licensee Activities i
Salp 8 Response April 27, 1989
Big Rock Point began the assessment period in routine power operatio l Throughout the assessment period _ the plant operated at power levels j
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1988, we began to add thermography readings. This information was critical in  i helping us decide to perform preventive maintenance on bus bar connections in our switchyard in a recent four day scheduled maintenance outage in Marc This very likely avoided possible future equipment failures. We have plans to enhance this program into 1989 and 1990. Part of our predictive efforts have been aimed at pipe vall thinning in secondary systems and our program there is well establishe .
up to the fuel-conditioning / thermal-hydraulic limits. During the I l    period, the plant encountered several power reductions and outages l
l In 1988, we overhauled one main feedwater pump and motor, one service water  i pump and motor, and one circulating water pump and motor, in 1989, we plan to overhaul the remaining service water pump and motor. We are adding vibration monitoring equipment to our recirculation pumps and performing preventive  !
for maintenance, repairs, and surveillance testing. Refueling~
maintenance on critical recirculation pump heat exchangers. We will also be  !
!    activities occurred from April through June 1988. Big Rock Point 1 ended the assessment period operating at power levels up to the l fuel-conditioning / thermal-hydraulic limit j l
monitoring key motor parameters. A major $1.5 million turbine overhaul is  (
The plant exper;lenced two engineered safety feature (ESF) actuations i and seven reactor trips. Two trips occurred while operating above )
planned for this summer; it will refurbish turbine seals, blade tips and items critical to turbine performance. In January, we sent three key maintenance staff members to Humboldt Bay to obtain maintenance information and history data as well as critical parts for future planned maintenance activitie j In 1989, we are planning to rewire all of our control rod drive accumulators prior to aging becoming a concern. In 1990, we will overhaul both our  l
15%. power and five while below 15% power (three at 0% and one with
          '
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condensate pumps and our main generator. This will result in the completion
single rod motion). Two trips were the result of personnel errors, four trips were the result of component. failures, and one was related to external factor l
^    of all major rotating equipment overhauls at Big Rock Pcint in the period from 1988 through 199 To accomplish all of the maintenance identified, we have relied primarily upon our plant maintenance staff. We will algo supplement these resources first with our Company's travel repair crews, and occasionally with outside contractors. Our ef f orts to manage these support groups will be intensified in 1989. Many of the items are delineated in our Maintenance Improvement Plan which stemmed from our Maintenance Self Assessmen Concerning the operator licensing examination conducted in 1988. Consumers Power recognizes that extensive efforts are expelled by the NRC in developing and administering these exams, and our failure to provide up to date reference material is unacceptable. Actions have takgn place to avoid recurrenc !
        '
          !
Significant outages and events that occurred during the assessment period are summarized below: September 6-10, 1987, the plant was shutdown to investigate a higher than normal unidentified leak rate, and repairs were ,
Recently, Big Rock Point Training personnel held a meeting with NRC Region III personnel to discuss plans for the 1989 examination. Plant participation in the development of these exams is recognized and with continued communica-tion, problems should be avoided. Additional interaction with NRC staff, both '
performed on the 'B' RDS depressurizing valv . November 9-14, 1987, the plant scrammed at 0% and remained shutdown to perform repairs to leaking RDS valve l i November 20-23, 1987, the plant was shutdown to perform top !
in Region III and NRR, is forthcoming to discuss implementation plans associated with the recent 30 CFR 55 rule changes dealing with operator training and examinatio Additional comments are provided as follows: Plant Operations The section discussed the reactor trips and ESF actuations during the SALP period which raised some overall concern in comments contained in the cover letter. Four of the trips did occur at low power due to electrical OC0489-0125-NLO4
assembly replacement on RDS depressurizing valves. Pilot valves in those assemblies had exhibited excessive leakage ,
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since November 14, 198'. I December 2-7, 1987, the plant was shutdown to investigate and repair a steam leak in the condenser area of the turbine high pressure heate . January 19-20, 1988, the plant was shutdown to repair a high pressure heat exchanger steam lea . February 2-4, 1988, the plant was shutdown to make repairs to the No. 1 reactor recirculation pump sea . February 5-6, 1988, the plant was manually scrammed, as administratively required, from 10* 4power when the
,    recirculation pumps tripped due to a momentary loss of power l    caused by personnel error during generator synchronizatio . February 8-11, 1988, the plant was shutdown to repair a pinhole leak on the No. 2 reactor recirculation pump seal cooling water heat exchange = _ _ - _ _ _ _


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Nuclear Regulatory Commission    3
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  ,  Salp 8. Response April 27, 1989
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  <        q noise ~in the original plant neutron monitoring system. This system has been replaced with new state-of-the-art equipment and the one out of two  !
l April 8-June 27,1988, .the plant was shutdown- for its 22nd scheduled refueling outage. .Ma'or activities included RDS valves modification and testing, WRNM replacement, and l_ CRDS valve diaphragm replacement, t
logic trips has been elitinated. Consumers Power Company expects this change will significantly reduce the trip rat I With respect to ESF actuations, Consumers Power disagrees with staff !
10. June.29-July 1,1988, a manuai reactor shutdown was performed to repair the newly installed WRNM system and calibrate the
assessment of_ diesel generator starts. The guidance contained in NUREG-1022, Supplement #1, question 6.1, is "no standard list of ESFs exist and one should consult the FSAR in determining deportability". Using this  ;
  .
guidance, the BRP Updated Final Hazards Summary Report, developed from '
  -source range instrumentatio . July 2-7,;1988,-the plant was shutdown to perform repairs on'the
NRC Safety Evaluation dated February 1,1982, states the ESF systems for  .
; hydrogen. seal oil ~ system.
Big Rock Point are as follows:    !
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Containment Isolation
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Post Incident System
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Core Spray System
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Emergency Condscser System
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Reactor Depressurization System Radiological Controls An issue discussed in this area dealt with fuel sipping and removal of bad
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fuel. Consumers Power Company agrees with the NRC comments during the SALP presentation that reference to this issue did not' belong in this-( '
report and acknowledges that the staff intends to have this portion amende Maintenance / Surveillance No additional comment . Emergency Preparedness No comment Security In security, the elimination of the Corporate Property Protection group has been identified as a potential concern. The Company retained the two most experienced Property Protection Department personnel, one of whom performs audits every six months in the security area. The other individual recently performed a comprehensive in-house fitness for duty  q audit and participates in licensing activities related to security. We  '
believe this will retain the independence and expertise of the previous Property Protection Department while making plant line management accountabl Engineering / Technical Support No additional comment OC0489-0125-NLO4
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12. July 7.-10, 1988, the plant was shutdown to perform additional repairs on'the WRNM syste . - October 28-30,-1988, the plant scrammed at 98% power and remained shutdown to perform repairs on a transformer, which was damaged during a windstorm when a lightning rod. fell across its-line . November 21-24, 1988, the plant scrammed at 90% and remained shutdown to perform _ diagnostic work and repairs on a high pressure turbine steam admission valv . November 26-28, 1988,'the plant was shutdown to perform repairs-on an '! mission valve that had broken and was restr.icting . steam flow to the turbine, thus causing anomalous' behavior in the initial pressure regulato B. Inspection Activities Thirty-two inspection reports are discussed in this report (September 1,-1987, through December 31,1988) and are listed in Peragraph 1 of this section, Inspection Data. Table 1 lists the violations per functional area and severity level. Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summar . Inspection Data Facility Name:-Big Rock Point'
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Docket No.:-50-155 Inspection Report Nos.: 87022 through 87029, 88002-through 88006,
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   '88008 through-88014, and 88016-through 8802 ,
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TABLE 1 NUMBER OF VIOLATIONS IN EACH SEVERITY LEVEL Functional Areas  III  IV V Plant Operations Radiological Controls
~~ Maintenance / Surveillance  3 Emergency Preparedness Security '  'I  1 Engineering / Technical Support  1*  1 Safety, Assessment /        ,
Quality Verification  1 TOTALS  III  IV V 2  5 1
  *This violation was identified during SALP 7, but was not issued until SAL (Enforcement Case No. EA 87-030). It is included in the totals for this SALP perio . Special Inspection Summary During September 28-October 2,1987, a special security inspection was conducted regarding'the lack of program management relating to the safeguards program (Inspection Report No. 155/87025).
 
l
' During July 18-21, 1988, the annual emergency preparedness exercise was conducted (Inspection Report No. 155/88016). On July 21, 1988, a special enforcement conference was held to discuss an apparent violation identified in Inspectior Report No. 155/88011, regarding full' strok valve testing of the RDS_ valves (Inspection Report No. 155/88019). Escalated Enforcement Actions A Severity Level III violation-and the imposition of a civil penalty in the amount of $25,000 was issued to the licensee on December 2, 1987. This action was based on a violation involving failure to maintain access control to a vital area of the plant The licensee paid the civil penalty on January 11,  .
1988 (Enforcement Case No. 87-202, Inspection Report No. 155/S7025, Enforcement Notice No. EN-87-101).
 
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l A proposed imposition of civil penalty.in the amount of $187,500 l was issued to the-licensee on September 22, 1988. This action was based on a violation involving EQ requirements of ,
10 CFR 50.49. .The escalated and mitigation factors of the- l
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      - modified enforcement policy'were considered, and 25% escalatio of the base civil penalty was deemed appropriate because of the licensee's poor corrective actions. This. case is.under licensee review (Enforcement Case No. EA-87-080, Inspection Report
      &c. 155/86013, Enforcement Notice No. EN-88-079).
L
. Confirmatory Action Letters Non License Amendments Issued Amendment N Description  Date 90 Allows all reloads of the "I" 05/17/88 fuel desig Revised TS to reflect the features 05/17/88 and terminology used with the new out-of-core power range  )
instrumentation-  '
l 92 Modified the license to require -
09/14/88 compliance with the Physical Security Plan, which was amended in response to 10 CFR 73,55 requirements.
(      93 Requires full stroke tests of all 11/04/88 four RDS valves each refueling outag F ,. Review of Licensee Event Reports Submitted by the Licensee l
Thirteen LERs were issued during this assessment period'. Table 2-shows cause coce comparisons of SALP 7 versus sal.P 8 LER LER Nos.: 87010 thN 87013 and 88001 thru 88009
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!t TABLE 2 i
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    (17-MO)- .(16-M0)
Cause Areas  SALP 7 SALP 8 No. - (Percent) ~ No. (Percent)
Personnel Errors'  3 (23.1%) 2(15.4%)- Design Problems  3 (23.1%) 2 (15.4%)
: External Causes  l0 ( 0.0%)- 1 ( 7.7%)
Procedure Inadequacies L4 (30.7%) 1 (.7.7%)
Component / Equipment 1 ( 7.7%). 7 (53.8%)
Other/ Unknown  2 (15.4%)- 0 ( 0.0%)
TOTALS  13  13 FREQUENCY (LERs/MO) .79  ,83 NOTE: The above information was derived 'from review of LERs performed by NRC-staff and may not completely. coincide with the licensee's cause assignment ,
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Nuclear Regulatory Commission
;p  Big Rock Point Plant Salp 8 Response April 27, 1989 Safety Assessment / Quality Verification With respect to lack of performance based audits and surveillance, Consumers Power QA Audit section has used various " Performance Based Techniques" for several years. The use of technical specialists in support of audits along with the " vertical slic.e" approach have all been aimed at performance based inspections. To build upon this, training classes in performance based audits and inspections were conducted by BarTech, Inc in January and March of this year. This training will i continue our advancement in the direction of performance based audits and inspection While we believe progress has been made by Quality Assurance Department in conducting performance based audits Consumers Power will continue to work at improving this are !
        !
Overall, we believe that the Nuclear Regulatory Commission may wish to rethink how it uses and interprets trend data. For example, two items of noncompli- l
        !
ance were identified in the security area in this SALP period and stated to be a negative trend. Both of these involved physical plant deficiencies that ;
were present since the Security Plans took full effect in 1975. What occurred I
j in this SALP period was the identification of these weaknesses and the
,_
immediate corrective action. We would conclude that the trend is very
[\  positive as our security system is physically (hardware wise) superior to what it was at anytime in the past. The identification of a problem that has existed in the past and that is promptly corrected should not necessarily be ,
viewed as a negative tren l Consumers Power Company thanks you for your attention. We sincerely intend to communicate openly and frequently with NRC and we appreciate your recognition of our management style at Big Rock Point. We are cummitted, as are you, to :
l continue to make Big Rock Point a very safe operatio David P Hoffman (Signed)
David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, USNRC l
NRC Resident Inspector - Big Rock Point Plant k
OC0489-0125-NLO4 i
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Latest revision as of 22:07, 30 January 2022

App to SALP Rept 50-155/89-01 for Sept 1987 - Dec 1988 Covering Diesel Generator as ESF Sys & Sipping of Fuel & Removal of Bad Fuel
ML20247K887
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/24/1989
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247K883 List:
References
50-155-89-01, 50-155-89-1, NUDOCS 8906020045
Download: ML20247K887 (10)
v • d • e


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Enclosure 1 SALP 8 APPENDIX SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION III

I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORi4ANCE 50-155/89001 4 Inspection Report N l Consumers Power Company Name of Licensee l

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Big Rock Point Nuclear Pla.nt Name of Facility September 1, 1987, through December 31, 1988 Assessment Period

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l 890602004D 890524 PDR ADOCK 05000155 Q PDC

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Enclosure 1 Big Rock Point Nuclear Plant A. Summary of Meeting with Consumers Power Company on March 28, 1989 The findings and conclu:, ions of the SALP Board are documented in Report No. 50-155/89001 and were discussed with the licensee on March 28, 1989, at the Edgewater Inn, Charlevoix, Michiga While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observer The following licensee and NRC personnel were in attendanc Consumers Power Company G. Heins, Senior Vice President R. Nicholeson, Vice President of Energy Supply Services K. Berry, Director of Nuclear Licensing T. Elward, Plant Manager, Big Rock Point Various members of the plant staff Nuclear Regulatory Commission C. Norelius, Deputy Regional Administrator W. Forney, Deputy Director. Division of Reactor Projects (DRP)

I. Jackiw, Chief, Reactor Projects Section 28, DRP W. Scott, Licensing Project Manager, NRR E. Plettner, Senior Resident Inspector i l

B. Comments Received from Licensee Consumers Power s response to the Big Rock Point SALP 8 Board Report dated

April 27, 1989, included several comments that after further evaluation l

have resulted in revising the SALP Report. These changes are listed in Enclosure (2), Errata Sheet, and corrected pages are included as Enclosure (3).

Replace the pages in arror listed in Enclosure (2) with the corrected pages attached in Enclosure (3) into your copy of the SALP Repor C. Regional Administrator's Conclusions Based on Consideration of Licensee Comments We noted your comments on pages 3 and 4 of your response regarding security. The information contained in your response regarding the ;

elimination of the Corporate Property Protection group was known at the time of our evaluation and expression of concern. Also, we agree that prompt correction of identified problems should not necessarily be L__-________ _ _ - _ _ _ _ _ _ _ .

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interpreted as a negative trend. Your correction of the problems was l'

adequate; however, they should have been identified soone With regard to Consumers Power disagreement of how the NRC tabulates !

engineered safety features actuations, we have noted your comments and J have requested that NRR review this matter. We will inform you of the i results of our revie j

l We concur with your actions to enhance performance based audits and look l

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forward to discussing this matter with your staf l

)

The changes in response to licensee comments for paragraphs A, B, E, I and G appear on the Errata Sheet of this Appendix to the SALP Repor !

I have concluded that the overall ratings in the aff ected areas have not l'

change i l

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Enclosure ERPATA SHEET-PAGE LINE NOW READS SHOULD READ

L ~6 5, 6- ...two engineered ...two diesel li safety system generator actuations (diesel actuation i generatorstarts),

Basis: The Big Rock Point Updated Final Hazards Summary Report does not include the diesel generator as an ESF system. Therefore, the words engineered safety system were remo've , 33, 34 Due to an NRC initiativft, Radioactive the licensee sipped fuel gaseous effluent and removed bad fue releases were This resulted in radio- considerably...

active gaseous effluent releases being consider-ably. . .

"

Basis: .The sipping of fuel and removal of bad fuel was perfortned during the previous SALP assessment period and thus is not applin.ble to this SALP assessment perio , 27, 28 The NRC has concerns that The NRC has concerns the quality assurance that the quality surveillance and audits assurance department are not performance... is conducting a minimum number of surveillance and audits that are performance...

Basis: The original statement regarding performance based inspections was in error. The changed wording recognizes that the QA department does use performance based techniques in their audits and surveillanc l l

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EtCDSURE 2

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Operational events increased during this assessment period over l the previour period indicating a decline in performance. There were eight licensee event: reports (LERs) issued that related to plant operations. Six automatic reactor. trips and one manual reactor trip, resulting in two' engineered safety system actuations (diesel generator starts),1 occurred during this assessment period compared with three automatic trips with no engineered afety system actuations in the previous assessment period. Four of the automatic trips occurred early in the

%(% ssment period with the reactor at 0% power. One trip was Nnglerodmotionduringmaintenancetesting,and it e sulted from spurious trips from the 26 year-old WRNM 19514 ,

ation system. Personnel error during switch down- .

rang ng was a contributing factor in one of the three WRNM spurto The WRNM system was replaced with state-o ; e art equipment during the 1988 refueling outage, j The manua I trip was caused by personnel error during grid i synchronization. Two trips occurred late in the assessment period with _ actor at approximately 90% power. One was caused by tur e uipment failure and the. other by an offsite electrical line . In response to the two trips, the licensed operato1 editiously took the correct emergency operating procedu ) actions needed to maintain the plant in a safe condition 4 events were promptly and completel reported. Operato'r4 ~ u' ly made use of procedures and drawings to conduct Vi d rations and were familiar with TS and supporting admifi r ve requirements associated with plant operations. Unit,a ility decreased during this !

assessr..ent period to 75'.4% 9.7% during the previnus assessment period. The dec was not_ indicative of a proble t their assigned duties in a Fire watenmanne professional personnel carrie'('g

%

Staffing for the plant operations ontinues to be excellent. A sufficient number ied licensed and non-licensed individuals were ava y allow for routine shift coverage, training, and outagg 'without excessive use of overtime. Total overtime averaged,.1 M L all operations personnel ouring the assessment period.; Ws tions were clearly identified and authorities and respons1h 11 were well-define Duringthisassessmentperiod,thelicen(ge s ped programs for task analysts of operators, operator goa s t rd continuing l professionalism, and new E0Ps. The fire prove organization was adequately staffed with well qualified personne . There is a full-time safety supervisor, who is a degreed gfire protection specialist and is the safety coordinator and firgbrigade instructo _ _ _ _ _ .

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Qym Ercar i activitics, installation of new whole body contamination monitors, and identified the lack of a formal hot particle i program. These efforts were necessery to improve contamination controls and radiation worker practices, j

)

, sponsiveness to NRC initiatives was generally good with some ceptions. In response to NRC Information Notice 88-34, the

>

q'11 see identified and corrected sen-fuel special nuclear asal accountability problems. 'averal previously identified erns relating to whole body contamination monitors, a tgative controls over high radiation area keys, inservice ins 6 tion (ISI) planning and coordination, skin dose calculation met ology, and gamma spectroscopy were adequately addressed durin t the ssment period. However, followup evaluation of a i

persona gination event was relatively weak; the licensee :

was slo mprove control of used protective clotning at  !

contaminatten g ries; and the licensee was lax in maintaining 09j v rs and gloves at frisker station The licensee'sh gpfFpk h to the identification and resolution of radiological 'ttchni issues was generally sound as exhibited by majorg ' s to the RWP system, continued improvements in persp tracking, good hot particle skin i dose assessments, andgre ion of problems with vendor owned shipping casks. A wes1gess 4 v.3 identified concerning the determination of radiol J rotective measures based primarily on previous si i a g job +

The licensee continues to perform 1 in the radiological confirmatory measurements arei w 3 agreements in 59 comparisons. Licensee performance , f e Radiological Environment Monitoring ?rogram was satisfactory - total station dose (about 210 person-rem in 1987 and $60 erson-rem in 1988) has trended downward over the last sever 41 ment periods and l reflects an improved ALARA performanc4b to an NRC initiative, I thelicenseesippedfuelandremovedbaq ~ % This resulted in l radioactive gaseous effluent releases be onkiderably reduced

{

during the assessment period, ref.lecting abs of significant i fuelcladdingproblemswiththecurrentfue qamount and !

activity of liquid radwaste releases remaine( t an'" acceptable j level. Solid radwaste volumes shipped to licensed burial sites l continue to decline as a result of implementingholume reduction l technique %

The staffing levels and qualifications of radiation \ protection personnel were generally adeauate to implement the ro4 tine radiation protection and ALARA programs; experienced coetract l

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non-conforming materials (Bulletin 88-05). The licensee was l j

very responsive in taking actions to resolve allegations that  !

were turned over by the NRC to the licensee for corrective action .

s konsiteQAgroupplacedemphasisforitssurveillance

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tions on those systems with the. highest safety s cance, such as the reactor protection system, post ac e system, RDS, and core spray system. The licensee

'ntr the probabilistic risk concept in the surveillance and i est. ion program during this assessment. period. The concept is based on core damage / release of fission product '

Twoiprveillances performed using this concept were the ISI and RDSvalyete 9. The enhanced performance incentive program was a pesi icensee initiative to control the use of QA resource's,f involving in-line reviews of procedures and maintenanc rs. The first plant group selected for the programwas) ent and control department, because of past outst formar.ce. The program has the approval of NRC regiona ,st . Safety review committees and feedback from.QA/QC acti ntie used to provide critical self-assessments to th o rate management and to improve work activities associated t nt operations. The NRC has concerns that the qualit rance surveillance and audits are not performance based inspg;4@ and may have an inadequate number of hours budgeted to c ' observations of actual work in progres ' d

s Staffing of the licensee's cinsite QA/QC department remair.ed generally stable over the assessmen iod. The staff is composed of technically oriented in is with extensive plant experience who exhibit a good snding of programmatic requirements and exhibit }Agh degree of professionalism. During the asses'een s r d, the site staff was supplemented by corporate person'np C group was deficient in detecting one work error' to rework of the CR05 valve diaphragm '

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The training and qualification program contri es an adequate understanding of work and adherencetto p ures as indicated by few personnel errors. QA/QC sta rs participated in audits at other company locations and attended ,

meetings to increase their knowledge and understanding '

of the QA/QC proces . Performance Rating f

\.3 The licensee's performance is rated Category 2 in this 3re Because this is a new area, no rating is available from tie l (

previous assessment perio ' Recommendations -

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Operational events increased during this assessment period over i the previous period indicating a decline in performance. There '

were eight. licensee event reports (LERs) issued that related to plant operations.. Six automatic reactor trips and one mar.ual reactor trip, resulting in two diesel generator actuations, occurred during this assessment period compared with three automatic trips with no engineered safety system actuations in the previous assessment period. Four of the automatic trips occurred early in the assessment period with the reactor at 0%

power. One trip was with single rod motion during maintenance testing, and three resulted from spurious trips from tne 26-year-old WRNM instrumentation system. Personnel error during switch down-ranging was a contributing factor in one of the three WRNM spurious trips. The WRNM system was replaced with state-of-the-art equipment during the 1988 refueling outag The manual trip was caused by personnel error during grid synchronization. Two trips occurred late in the assessment-period with the reactor at approximately 90% power. One was caused by turbine equipment failure and the other by an offsite electrical line faul In response to the two trips, the licensed operators ex operating procedureE0P) (peditiously took the actions needed to correct maintainemergency the plant in a safe condition. All events were promptly and completely reported. Operators routinely made use of procedures and drawings to conduct plant operations and were familiar with TS and supporting administrative requirements associated with plant operations. Unit availability decreased during this assessment period to 75.5% from 79.7% during the previous -

assessment period. The decrease was not indicative of a proble Fire watch personnel carried ou, their assigned duties in a professional manne Staffing for the plant operations area continues to be excellent. A sufficient number of qualified licensed and non-licensed individuals were available to allow for routine shift coverage, training, and outage work without excessive use

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of overtime. Total overtime averaged 12% for all operations personnel during the assessment period. Positions were clearly identified and authorities Lad responsibilities were well-define DurIng this assessment period, the licensee developed programs for task analysis of operatcrs, operator goals toward continuing professionalism, and new E0Ps. The fire protection organization war adequately staffed with well-qualiff eo personnel. There is a full-time safety supervisor, uho is a degreed fire protection specialist and is the safety coordinator and fire brigade ( instructor.

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activities, installation of new whole body contamination i monitors, and identified the lack of a formal hot particle ;

program. These efforts were necessary to improve contamination !

controls and radiation worker practice Responsiveness to NRC initiatives was generally good with some exceptions. In response to NRC Information Notice 88-34, the licencee identified and corrected non-fuel special nuclear ,

materia'l accountability problems. Several previously identified l NRC concerns relating to whole body contamination monitors, !

administratitre controls over high radiation area keys, inservice l inspection (ISI) planning and coordination, skin dose calculation methodology, and gamma spectroscopy were adequately addressed during the assessment period. However, followup evaluation of a personal contamination event was relatively weak; the licensee was slow to improve control of used protective clothing at contamination boundaries; and the licensee was lax in maintaining shoe covers and gloves at frisker station ,

i The licensee's approach to the identification and resolution of radiological technical issues was generally sound as exhibited by major revisions to the RWP system, continued improvements in personal dose tracking, good hot particle skin dose assessments, and resolution of problems with vendor owned l

shipping casks. A weakness was identified concerning the j determination of radiological protective measures based primarily on previous similar job The licensee continues to perform well in the radiological confirmatory measurements area with 56 agreements in 59 l

comparisons. Licensee performance of the Radiological Environment Monitoring Program was satisfactory. The total station dose (about 210 person-rem in 1987 and 160 person-rem in 1988) has trended downward over the last several assessment periods and reflects an improved ALARA performance. Radioactive gaseous effluent releases were considerably reduced during the assessment period, reflecting the absence of significant fuel cladding problems with the current fuel. The amount and activity of liquid radwaste releases remained at an acceptable level.

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Solid radwaste volumes shipped to licensed burial sites continue to decline as a result of implementing volume reduction technique The staffing levels and qualifications of radiation protection personnel were generally adequate to implement the routine radiation protection and ALARA programs; experienced contract l

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non-conforming materials (Bulletin 88-05). The licensee was very responsive in taking actions to resolve allegations that were turned over by the NRC to tne licensee for corrective action The onsite QA group placed emphasis for its surveillance inspections on those systems with the highest safety significance, such as the reactor protection system, post accident system, RDS, and core spray system. The licensee introduced the probabilistic risk concept in the surveillance and inspection program during this assessment period. The concept is based on core damage / release of fissior, product Two surveillance performed using this concept were the ISI and RDS valve testing. The enhanced performance incentive program was a positive licensee initeative to control the use of QA resources for work involving in-line reviews of procedures and maintenance orders. The first plant group selected for the program was the instrument and control department, because of past outstanding performance. The program hcs the approval of NRC regional staff. Safety review committees ard feedback from QA/QC activities were used to provide critical self-assessments i to the corporate management and to improve work act vities associated with plant operations. The NRC has concerns that the quality assurance department is conducting a minimum number of surveillance and audits that are performance based inspections ,

and may have an inadequate number of hours budgeted to do !

observations of actual work in progres '

Staffing of the licensee's onsite QA/QC department remained generally stable over the assessment period. The staff is composed of technically oriented individuals with extensive ;

plant experience who exhibit a good understanding of programmatic requirements and exhibited a high degree of professionalism. During the assessment period, the site staff was supplemented by corporate personnel. The QC group was deficient in detecting one work error that led to rework of the CRDS valve diaphragm The training and qualification program contributes to an adequate understanding of work and adherence to procedures as ir.dicated by few personnel errors. QA/QC staff members participated in audits at other company locations and attended meetings to increase their knowledge and understanding of the QA/QC proces l 2. Performance Rating l The licensee's performance is rated Category 2 in this are l Because this is a new area, no rating is available from the l previous assessment perio ' Recommendations l

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Consumers ' )

" om e wo* U power Ykt President Nwlear Operations

% M ERlNG nlKNIGAN'S PROGREK5 General othces- 1945 West Parnall Roed, Jackson MI 49201 t617) 7884463 April 27, 1989

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46 Nucles.r Regulatory Ccmmission Document Control Desk Washington, DC 20555

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DOCKET 50-155 - LICENSE DPR-6 - BIG ROCK POINT PLANT -

SALP 8 RESPONSE NRC letter dated March 13, 1989 contained the Systematic Assessment of Licensee Performance (SALP) No. 8 Board Report for our Big Rock Point Nuclear i I

Plant. This letter provides Consumers Power Company's written ecmments regarding that repor Consumers Power Company thr. uke the NRC for the feed'oack on activities at Big Rock Point from the period of September 1, 1987 through December 31, 198 We believe that all of the concerns identified will be addressed very effectivel With regard to r.oncerns associated with the living Schedule, in 1988 we completed three high priority items, specifically: correction of Reactor Depressurization System valve problems; Neutron Monitoring System upgrades; and resolution of steam drum relief valve concerns. We believe that these actions have made and will make a continued positive contribution toward ,

improved plant safety and availability. Our two highest priority items are now receiving accelerated attention and resources. We fully expect actions in 1989 and in the 1990 refueling outage to address these issues. Also, in September 1988, we changed the plant organization to increase management attention and the total engineering resources applied to our Living Schedul With regard to the concerns associated with plant age and plant maintenance, we are taking actions which we belie.ve will result in significant improvements. In September 1988, the organization was revised to re-establish a full time maintenance superintendent whose responsibilities are solely maintenance. In early 1988, we continued to enhance our Predictive Maintenance Program in the area of vibration analysis of rotating equipment. In late S

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Nuclear Regulatory Commission Big Rock Point Plant

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Salp 8 Response April 27, 1989

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1988, we began to add thermography readings. This information was critical in i helping us decide to perform preventive maintenance on bus bar connections in our switchyard in a recent four day scheduled maintenance outage in Marc This very likely avoided possible future equipment failures. We have plans to enhance this program into 1989 and 1990. Part of our predictive efforts have been aimed at pipe vall thinning in secondary systems and our program there is well establishe .

l In 1988, we overhauled one main feedwater pump and motor, one service water i pump and motor, and one circulating water pump and motor, in 1989, we plan to overhaul the remaining service water pump and motor. We are adding vibration monitoring equipment to our recirculation pumps and performing preventive  !

maintenance on critical recirculation pump heat exchangers. We will also be  !

monitoring key motor parameters. A major $1.5 million turbine overhaul is (

planned for this summer; it will refurbish turbine seals, blade tips and items critical to turbine performance. In January, we sent three key maintenance staff members to Humboldt Bay to obtain maintenance information and history data as well as critical parts for future planned maintenance activitie j In 1989, we are planning to rewire all of our control rod drive accumulators prior to aging becoming a concern. In 1990, we will overhaul both our l

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condensate pumps and our main generator. This will result in the completion

^ of all major rotating equipment overhauls at Big Rock Pcint in the period from 1988 through 199 To accomplish all of the maintenance identified, we have relied primarily upon our plant maintenance staff. We will algo supplement these resources first with our Company's travel repair crews, and occasionally with outside contractors. Our ef f orts to manage these support groups will be intensified in 1989. Many of the items are delineated in our Maintenance Improvement Plan which stemmed from our Maintenance Self Assessmen Concerning the operator licensing examination conducted in 1988. Consumers Power recognizes that extensive efforts are expelled by the NRC in developing and administering these exams, and our failure to provide up to date reference material is unacceptable. Actions have takgn place to avoid recurrenc !

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Recently, Big Rock Point Training personnel held a meeting with NRC Region III personnel to discuss plans for the 1989 examination. Plant participation in the development of these exams is recognized and with continued communica-tion, problems should be avoided. Additional interaction with NRC staff, both '

in Region III and NRR, is forthcoming to discuss implementation plans associated with the recent 30 CFR 55 rule changes dealing with operator training and examinatio Additional comments are provided as follows: Plant Operations The section discussed the reactor trips and ESF actuations during the SALP period which raised some overall concern in comments contained in the cover letter. Four of the trips did occur at low power due to electrical OC0489-0125-NLO4

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Nuclear Regulatory Commission 3

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, Salp 8. Response April 27, 1989

< q noise ~in the original plant neutron monitoring system. This system has been replaced with new state-of-the-art equipment and the one out of two  !

logic trips has been elitinated. Consumers Power Company expects this change will significantly reduce the trip rat I With respect to ESF actuations, Consumers Power disagrees with staff  !

assessment of_ diesel generator starts. The guidance contained in NUREG-1022, Supplement #1, question 6.1, is "no standard list of ESFs exist and one should consult the FSAR in determining deportability". Using this  ;

guidance, the BRP Updated Final Hazards Summary Report, developed from '

NRC Safety Evaluation dated February 1,1982, states the ESF systems for .

Big Rock Point are as follows:  !

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Containment Isolation

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Post Incident System

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Core Spray System

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Emergency Condscser System

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Reactor Depressurization System Radiological Controls An issue discussed in this area dealt with fuel sipping and removal of bad

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fuel. Consumers Power Company agrees with the NRC comments during the SALP presentation that reference to this issue did not' belong in this-( '

report and acknowledges that the staff intends to have this portion amende Maintenance / Surveillance No additional comment . Emergency Preparedness No comment Security In security, the elimination of the Corporate Property Protection group has been identified as a potential concern. The Company retained the two most experienced Property Protection Department personnel, one of whom performs audits every six months in the security area. The other individual recently performed a comprehensive in-house fitness for duty q audit and participates in licensing activities related to security. We '

believe this will retain the independence and expertise of the previous Property Protection Department while making plant line management accountabl Engineering / Technical Support No additional comment OC0489-0125-NLO4

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Nuclear Regulatory Commission

p Big Rock Point Plant Salp 8 Response April 27, 1989 Safety Assessment / Quality Verification With respect to lack of performance based audits and surveillance, Consumers Power QA Audit section has used various " Performance Based Techniques" for several years. The use of technical specialists in support of audits along with the " vertical slic.e" approach have all been aimed at performance based inspections. To build upon this, training classes in performance based audits and inspections were conducted by BarTech, Inc in January and March of this year. This training will i continue our advancement in the direction of performance based audits and inspection While we believe progress has been made by Quality Assurance Department in conducting performance based audits Consumers Power will continue to work at improving this are !

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Overall, we believe that the Nuclear Regulatory Commission may wish to rethink how it uses and interprets trend data. For example, two items of noncompli- l

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ance were identified in the security area in this SALP period and stated to be a negative trend. Both of these involved physical plant deficiencies that ;

were present since the Security Plans took full effect in 1975. What occurred I

j in this SALP period was the identification of these weaknesses and the

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immediate corrective action. We would conclude that the trend is very

[\ positive as our security system is physically (hardware wise) superior to what it was at anytime in the past. The identification of a problem that has existed in the past and that is promptly corrected should not necessarily be ,

viewed as a negative tren l Consumers Power Company thanks you for your attention. We sincerely intend to communicate openly and frequently with NRC and we appreciate your recognition of our management style at Big Rock Point. We are cummitted, as are you, to :

l continue to make Big Rock Point a very safe operatio David P Hoffman (Signed)

David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, USNRC l

NRC Resident Inspector - Big Rock Point Plant k

OC0489-0125-NLO4 i

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