ML20202F264
| ML20202F264 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/10/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20202F249 | List: |
| References | |
| 50-155-86-01, 50-155-86-1, NUDOCS 8607150126 | |
| Download: ML20202F264 (39) | |
See also: IR 05000155/1986001
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SALP 6
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY COMMISSION
d'
REGION III
1
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-155/86001
Inspection Report
Consumers Power Company
Name of Licensee
Big Rock Point Plant
Name of Facility
November 1, 1984 through March 31, 1986
Assessment Period
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8607150126 860710
PDR ADOCK 05000155
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
A NRC SALP Board, composed of staff members listed below, met on May 23,
1986, to review the collection of performance observations and data to
assess the licensee's performance in accordance with the guidance in NRC
Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II
of this report.
SALP Board, for Big Rock Point:
Name Title
J. A. Hind Director, Division of Radiological
Safety and Safeguards
E. G. Greenman Deputy Director, Division of Reactor
Projects
W. G. Guldemond Chief, Reactor Projects Branch 2
L. R. Greger Chief, Facilities Radiation Protection
Section
E. R. Schweibinz Chief, Technical Support Staff
M. Schumacher Chief, Radiological Effluents and
Chemistry Section
B. Snell Chief, Emergency Preparedness Section
D. H. Danielson Chief, Material and Process Section
R. B. Landsman ProjectManager,ReactorProjects
Section 2D
T. Rotella Big Rock Point Project Manager, NRR
S. Guthrie Senior Resident Inspector
D. A. Kers Plant Protection Analyst
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II. CRITERIA
Licensee nerformance is assessed in selected functional areas, depending
upon whetner the facility is in a construction, preoperational, or
operating phase. 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
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observations. Special areas may be added to highlight significant j
observations.
One or more of the following evaluation criteria were used to assess each
functional area.
1. Management involvement and control in assuring quality
2. Approach to the resolution of technical issues from a safety
standpoint
3. Responsiveness to WRC initiatives
4. Enforcement history
5. Operational and Construction events (including response to, analyses
of, and corrective actions for)
6. Staffing (including management)
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1: Reduced NRC attention inay be appropriate. Licensee management
attention and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high level of
performance with respect to operaticnal safety and construction quality is
being achieved.
Category 2: NRC attention should be maintained at normal levels. Licensee
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management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably
effective so that satisfactory performance with respect to operational
safety and construction quality is being achieved.
Category 3: Both NRC and licensee attention should be increased. Licensee
management attention and involvement is acceptable and considers nuclear
safety, but weaknesses are evident; licensee resources appear to be strained
or not effectively used so that minimally satisfactory performance with
respect to operational safety or construction quality is being achieved.
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III. SUMMARY OF RESULTS
The overall regulatory performance of the Big Rock Point Plant has
continued at a satisfactory level during the assessment period.
Improved performance in the area of Licensing Activities is noted.
However, performance in the areas of Plant Operations and Surveillance and
Inservice Testing declined from a Category 1 to a Category 2. Performance
in the area of Outages is rated a Category 3 this period. This rating is
a reflection of the breakdown of administrative controls over the outage
process and resulted in a Severity Level III violation during the middle
of the SALP period.
July 1, 1983- November 1, 1984-
Functional Area October 30, 1984 March 31, 1986
A. Plant Operations 1 2
B. Radiological Controls 2 2
C. Maintenance / Modifications 2 2
D. Surveillance and
Inservice Testing 1 2
E. Fire Protection 2 2
F. Emergency Preparedness 1 1
G. Security 1 1
H. Outages *
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I. Quality Programs and
Administrative Controls
Affecting Quality 2 2
J. Licensing Activities 2 1
K. Training and Qualification
Effectiveness *
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- Not Rated (new functional areas for SALP 6)
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
Portions of eight routine inspections by the resident inspector
reviewed plant operations. The inspections included observations
of control room operations, reviews of logs, discussions of
operability of emergency systems, and reviews of reactor building <
and turbine building equipment status. During the evaluation
period the following violations were identified:
a. Severity Level IV - Failure to perform required surveillance
on the Reactor Depressurization System (RDS) (155/84017).
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b. Severity Level V - Delay in notification to NRC of a plant
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shutdown required by Technical Specifications (155/84017).
By not performing the surveillance when required, the unit
entered a Limiting Condition for Operation statement and a unit
shutdown was necessary. The licensee also failed to recognize
the reporting requirements of 10 CFR 50.72 associated with a
forced shutdown and was late in making the required notification.
The Big Rock Operations Department is adequately staffed with
licensed and non-licensed individuals who are dedicated to
safe and efficient operation of the reactor. Observation of
operators in the control room and on tour in the plant indicates
they are generally conscientious in both routine and off-normal
activities. They make regular use of drawings and procedures to
plan and perform evolutions. Control room decorum is adequate,
and a cooperative, results-oriented attitude is apparent among
the operators and in the operator's dealings with maintenance
men, radiation protection technicians, and the engineering staff.
Operators are well trained. Shift-manning is accomplished
without excessive use of overtime and the number of individuals
in training and requalification programs appears adequate to meet
future needs.
The operations staff performs well during startups and
shutdowns of the reactor, refueling operations, and performance
of surveillances. During surveillances, operators appear to
understand the objective of the test and the impact of their
actions on plant equipment. Operators appear capable of
dealing with abnormal and emergency situations,' indicating
adequate training and a functional understanding of plant
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equipment and systems interrelationships. Examples include
operator action that prevented reactor scrams on two occasions,
including a potential scram on high pressure when the Initial
Pressure Regulator (IPR) cover was lowered onto the IPR linkage,
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and two near scrams on low vacuum during installation of a pipe
patch on bypass line piping. In another instance, operators took
conservative action by scramming the unit manually on indications
of a major steam leak. Additionally, during the period of
reactor vessel inventory loss following the incorrect disassembly
of VRD305, operators on the refueling deck were quick to identify
the cause of the decreasing level and took proper corrective
action.
Of the six Reactor Protection Systems actuations resulting in a
scram signal during the evaluation period, two were attributable
in part to operator error. On January 7, 1985, the scram was
caused by failure to reset the FRV and on December 7, 1985, the
scram was precipitated by operators who earlier had left a valve
mispositioned prior to startup. The other four scrams resulted
from spurious actuations of the RPS system because of electrical
noise affecting the circuitry at low power, a known operating
characteristic of little safety significance.
In spite of the ability of the operations staff to operate the
plant reasonably well the department experienced a series of
human errors throughout the assessment period which detracted
3' from the safe operation of the facility. Most were attributable
to inattentiveness or lack of thorough attention to detail.
Operator inattentiveness on two occasions resulted in misposi-
tioned control rods, though one instance was influenced by
inadequate management direction and cumbersome administrative
controls over several available rod withdrawal sequences.
Inattention to detail and an assumption that other plant
personnel or administrative systems would compensate for
failure to assume personal responsibility for plant safety were
at the root of errors associated with tagging and isolation of
components involving work on the recirculation pump, and in a
separate incident, the incorrect disassembly of a control rod
drive system check valve. Inattention to detail and a
willingness to circumvent administrative controls (see
Section IV.H) resulted in an incorrect pipe being severed during
construction of Alternate Shutdown systems. Additionally, errors
resulted in the incorrect tagging of an electrical breaker, and
in missed surveillances detailed in Section IV.D of this report.
Finally, failure to follow local tagging procedures resulted in
the repair of Valve VNS143 without tagging or isolation and is
believed to be a factor in a major steam leak and subsequent
. scram on December 7, 1985. Licensee management, in response to
increased frequency of errors, has emphasized attention to
detail, counseled individuals, retrained personnel, and
implemented revised administrative controls on control rod
manipulations.
Management demonstrates a thorough understanding of the plant's ,
operation, reflecting extensive experience with this facility. '
Management personnel are often present in the control room area
and tour the plant regularly. Management direction and control,
however, was considered to be deficient in several instances.
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While the composition of the operations department staff
continued in transition from a group of older operators with
many years of plant specific experience to a mixed group with
many operators who are relatively new to the plant, management
showed a reluctance to compensate by incorporating lessons
learned into plant operating procedures. For example, the
bypass valve has a history of erratic behavior in automatic
operation at low steam flows, resulting in two plant scrams in
1984. Management had not provided specific guidance to operators
on when to remove the valve from automatic control, leaving it up
to the individual operator's discretion, even though a disparity
in theories and practices existed among operators because of
differences in experience levels. The Reactor Scram on
January 7, 1985 was caused by failure to reset instrument air
to the Feedwater Regulating Vaive (FRV) following air system
maintenance. Older operators surveyed were aware of the valve's
characteristic of failing on loss of air, but the less experienced
operators performing the startup were not. Newer operators could
have benefited from an expanded component identification program
throughout the plant. Finally, the licensee's revised admini-
strative controls over control rod movement, "hich employed
laminated cards and was implemented as corrective action
following two instances of mispositioned control rods, went
into effect with insufficient management direction. As such,
the card system went unused until repeated requests from the
resident inspector prompted management to publish guidance
requiring consistent and regular use by operators for all rod
motion.
Some reluctance to respond to NRC initiatives was in evidence
throughout the assessment period. Examples include responses to
inspector inquiries about operability of the acoustic monitor
during plant startup and operation, the need for a second Control
Rod Drive Pump to meet the requirements of Appendix R, the need
to test the availability of one electrical power source prior to
removal of another, and the recommendation to label the contain-
ment escape lock operating handles. However, the quality and
quantity of communication and cooperation with regulators
steadily improved over the 17 months. In the closing months of
the evaluation period the licensee demonstrated a willingness
to respond positively to NRC initiatives and a concern for safety
by operating the Diesel Fire Pump continuously when its starting
reliability was in question.
The licensee also exhibited several instances where a conservative
approach to resolution of a technical issue was chosen. Examples
include conservative declarations of inoperability on the RDS
system because of a detensioned hanger and on one tube bundle of
the emergency condenser based on a barely detectable indication
of a primary to secondary leak. The circumstances surrounding
the event discussed earlier in this section point to a licensee
decision to emphasize production over safety, but is an isolated
example not representative of the licensee's approach to
technical issues throughout the remainder of the period.
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2. Conclusions
The licensee is rated category 2 in this area with a declining
trend based on increasing frequency of human errors and difficulty
in implementing administrative controls over practices and
procedures important to plant safety.
3. Board Recommendations
To avoid future declines in this functional area licensee
management should address problems with administrative controls,
particularly as they relate to nutage management, and reduce the
frequency of human error in plant operations.
B. Radiological Controls
1. Analysis
Evaluation of this functional area is based on routine
assessments by the resident inspector during implementation of
the resident inspection program and six inspections by Region III
specialists. These inspections covered radiation protection,
radwaste management, disposal of low-level radioactive waste,
chemistry and radiochemistry, and confirmatory measurements.
One violation and one deviation were identified as follows:
a. Severity Level V - Failure to conduct a quality control
program to assure compliance with waste classification and
waste characteristic requirements (155/85006).
b. Deviation - Failure to implement the Radiation Safety Plan
by the date specified in the licensee's August 19, 1982
supplemental response to the Health Physics Appraisal
(155/85003).
The violation and the deviation were the results of inadequate
procedures; the licensee's corrective actions were timely.
Responsiveness to NRC initiatives has been generally adequate.
In response to inspector concerns regarding mask-fit testing of
BioPak 60-P respirators, the licensee replaced these respirators
with open circuit Self Contained Breathing Apparatuses (SCBAs).
Also, inspector concerns identified related to laboratory
performance are often acted upon by the end of the inspection.
However, the licensee was somewhat slow in correcting an error
in a 1984 semiannual effluent report brought to their attention
by the inspector, and was also slow to complete an evaluation and
request for approval concerning retention of contaminated soil
onsite following a break in an underground line to the condensate j
storage tank. The contaminated soil issue was closed by an -
Environmental Assessment and Findings of No Significant Impact
published in the Federal Register (May 5, 1986 - 51FR16596). New i
RETS technical specifications and the ODCM were implemented 1
during this assessment period. I
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Staffing in chemistry and radiation protection appears adequate,
with no changes in key supervisory personnel. The relatively
small technician staff has recently experienced a high turnover,
with six of 12 technicians replaced during this assessment
period; however, the inspectors have not observed a significant
effect on licensee performance. All of the replacement
technicians have completed the specified basic training course,
and assigned responsibilities appeared to have been commensurate
with the level of training. Supervisory personnel appear to have
a good understanding of their areas of responsibility.
Management involvement has been adequate to assure acceptable
quality in the functional area. There is adequate ALARA program
support and involvement by all levels of management. Records
are generally complete and well maintained. Procedure adherence
has been generally adequate, and management policy encourages
worker identification of problems to help with timely corrections.
However, inspectors have noted a significant number of instances
which indicate the need for more management attention, including
persons not frisking at exit points, radioactive materials stored
outside posted areas, contaminated area postings with inadequate
or confusing instructions to workers, and area monitor calibra- i
tion sources carried through office areas without appropriate
restrictions to personnel access to the area. Quality Assurance
(QA) involvement in the health physics activities during 1984 was
marginal. This shortcoming was exacerbated by the fact that
the formal plant surveillance program required by the licensee's
Radiation Safety Plan (RSP) had not yet been implemented. In
February 1985, NRC inspectors noted that the formal reporting
system for minor radiological occurrences required by the RSP
had also not been implemented. The recent implementation of
these RSP programs should improve overall management involvement
in this functional area.
Although the licensee's approach to the resolution of radiological
technical issues has generally been technically sound, thorough,
and timely during this assessment period, instances of poor
performance have occurred. In late 1984, a policy was
implemented which established a routine decontamination program;
however, no dedicated decontamination workers were assigned.
Despite this decontamination program, the licensee has
experienced problems in contamination control, especially during
outages. The addition of two contractor decontamination workers
following the 1985 outage resulted in a major improvement in
j plant cleanliness. Formerly inaccessible areas are now
accessible. The ALARA program has shown improvement during
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, and since the 1985 outage. The licensee has committed to an
, ambitious program of person-rem reduction that will stress job
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preplanning and new fuel pool cleaning equipment. With regular
- use of decontamination personnel the licensee intends to reduce
annual exposure by approximately one-third. The licensee is
generally conservative in resolution of potential safety and
environmental concerns. Relocation of a storm drain release
path to the lake, necessitated by high lake level, was
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accomplished by routing it in a manner to ensure that releases
would be monitored by the discharge canal monitor. The licensee
has also performed extensive testing during shutdown to locate
the source of a minor primary to secondary leak that developed
in the emergency condenser during operation. When the leak
source could not be identified, an augmented sampling program
was instituted upon restart to ensure that regulatory limits
are met. Corporate management is involved in the station's
effort to develop a method of measuring minor airborne releases
via this pathway.
Due to continuing fuel cladding problems, radioactive gaseous
releases during this assessment period were about a factor of
six higher than normal but have remained well below regulatory
limits even when operating at full power. Licensee efforts to
minimize releases and to eventually eliminate the problem
included removal of identified fuel leakers and use of a new
design replacement fuel. Release rates since the November
restart have been running at about three to four times the
normal rate. Liquid radioactive releases were below average
for U.S. boiling water reactors. The activity in liquid releases
has apparently stabilized during this assessment period following
several years of gradual decline. The solid radioactive waste
volumes in 1984 and 1985 were significantly less than in recent
years due, in part, to the implementation of a segregation
program for dry active waste (DAW). No transportation problems
were identified during this assessment period.
Personal exposures were about 120 and 270 person-rem in 1984
and 1985, respectively. These exposures are below the station
average over the previous five years (approximately
300 person-rem).
The licensee performed generally well in confirmatory measurements
with 34 agreements in 36 comparisons with Region III during the
assessment period. The disagreements were both for iodine
collected on a charcoal cartridge, with the licensee's values
about 20% lower than the NRC's. Recalibration following a
similar disagreement during the previous SALP period did not
resolve the difficulty owing, apparently, to differences of
activity distribution between the licensee's standard and
plant samples. The licensee readily agreed to use a correction
factor until another recalibration could be accomplished.
2. Conclusions
The licensee is rated Category 2 in this functional area. This
is the same rating given the previous SALP period.
3. Board Recommendations
None.
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C. Maintenance / Modifications
1. Analysis
Portions of eight routine inspections by the Resident Inspector
reviewed maintenance activities. One violation discussed in
Section IV.H, Outages, reflects on the licensee's ability to
conduct maintenance work during outages. In addition, two
Regionally based inspections'were performed. The inspections
included reviews of normal maintenance and modification activities
to ensure that approvals were obtained prior to initiating work,
activities were accomplished using approved procedures, post
maintenance testing was completed prior to returning components
or systems to service, and parts and materials were properly
certified. In addition, work planning and scheduling was
reviewed as well as the effectiveness of administrative controls
to ensure proper priority is assigned. No violations or
deviations noted.
During the evaluation period the licensee interrupted plant
operations for nine unscheduled maintenance outage periods
ranging from one to 11 days. Three outages were required to
repair Reactor Depressurization System (RDS) valves due to the
degraded condition of the system preventing successful performance
of quarterly surveillances. These included one forced shutdown
required by Technical Specifications unidentified leak rate
limitations. Two outage periods of one day each were required
to successfully repair IA-60B, seal leakage to heat exchanger
for Reactor Recirculation Pump No. 2. Also, two outages of three
and four days each were required to diagnose and correct steam
leakage from the reactor vessel head o-rings. One outage period
of four days was used to replace a recirculation pump seal, and
a one day outage was required to correct steam leaks associated
with the plant scram on December 7, 1985.
Proper planning and outage control was generally evident for the !
nine unscheduled outages. Although unplanned, the licensee in
the case of the RDS and recirculation pump outages had sufficient
warning to plan activities, prepare parts and procedures, and
perform other maintenance work that fell within the scope and
time limitations of the forced outage. Repair to RDS valve top
assemblies have become commonplace to the point that the licensee
routinely overhauls spare top assemblies. The licensee did not
, overhaul the spare recirculation pump seal in advance of the
outage and was still rebuilding the seal as the plant was being
shutdown to perform the replacement, even though the pump had been
idled for two weeks prior to shutdown. The licensee made
extensive use of vendor consultants and pump experts from the
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General Office for the seal replacement, resulting in a refined
and useful procedure for rebuilding and installation. Outages
for RDS and recirculation pump repairs were well planned and
executed. Outages to repair IA-60B represented an operational
situation that offered little warning and first attempts at
repairs were unsuccessful. The reactor vessel o-ring offered
no warning prior to failure, but successful repairs were delayed
when the problem was misdiagnosed. Once the decision was made
to perform the vessel head removal and ring replacement the
physically demanding job was successfully completed with
conservative consideration to ALARA and personnel safety.
Maintenance work (including mechanical, electrical, and
instrument / control) at Big Rock Point is performed by generally
competent repairmen who exhibit craftsmanship and a general
familiarity with the facility and the equipment. The amount
of unsuccessful repair attempts resulting in rework is generally
small. Repairmen generally are cognizant of procedural require-
ments associated with their assigned task, communicate effec-
tively with operators and health physics technicians, a'd reflect
concern for ALARA considerations. While the input repairmen
provide to machinery history is often marginal, communication
with co-workers and supervisors indicates genuine interest in
continued safe and successful operation of the reactor. The
mechanic who performs the work, for example, often participates
in post maintenance testing. While the retirement of older,
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experienced maintenance department personnel during the period
- had a negative impact on performance as documented further
! in Section IV.H, Outages, the maintenance staff demonstrated
flexibility and dedication throughout the evaluation period.
l The size of the maintenance staff is generally adequate for all
periods other than major refueling outages. A gradually
increasing backlog of maintenance orders over the period is
explained in part by increased emphasis on skills training which
over the short term reduces staff size availability.
Like the Operations Department the loss of older experienced
personnel due to retirement or other duties has altered composi-
tion of the maintenance staff. While the I & C group remained
unchanged, in the mechanical maintenance group of 12 men, five
were added during the assessment period. Because hiring and
promotion is heavily influenced by Labor Relations agreements
that emphasize seniority, newly added staff members generally
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have little or no experience with nuclear powered generating
plants in general or Big Rock Point specifically. Altbough the
licensee has long recognized the need for maintenance staff
training, no training was provided until February 1986, when a
regular program of skills training offsite was initiated. The
skills training is general in nature and is not nuclear plant
specific. No nuclear plant system or concepts training is
provided.
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First line supervision in the maintenance department reflects
adequate technical skills and managerial competence. During the
1985 outage, the maintenance department overcame the loss of
staff experience, inadequate outage planning, and parts procure-
ment to accomplish a relatively large number of modifications,
repairs, and preventive maintenance tasks.
Throughout the evaluation period several recurring problems were
not successfully repaired or adequately addressed. Valve M0-7067,
Turbine Bypass Isolation Valve, was not declared operable for
much of the evaluation period, based on difficulties with the
valve operator. Reactor Depressurization System (RDS) valves
exhibit inherent design deficiencies that have resulted in three
forced shutdowns during the assessment period and a long history
of problems dating back to their installation. Management,
however, has not placed a high priority on a comprehensive
solution and as a result the RDS system was not improved over
the period. Problems with the Emergency Diesel Generator (EDG)
fuel pump were allowed to continue and a design change to the
pump mounting bracket scheduled for completion during the 1985
refueling outage was deleted in an effort to return the plant to
an operable status. Shortly thereafter the pump failed again,
placing the EDG in an action statement for the generator's
Limiting Condition for Operation. Finally, the licensee made a
commitment to verify, prior to startup from the 1985 outage,
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Limitorque Switch settings on 18 Limitorque Valves the licensee
considered important to safety. As of this date only 15 have
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been checked. The torque settings for valve M0-7067 have been
reset on three different occasions, indicating a lack of decisive
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direction on problems with Limitorques Operators that goes back
to September, 1984, as was addressed in SALP 5.
SALP 5 expressed concern that the Prevention Maintenance (PM)
program may be inadequate to address aging equipment. At the end
of this assessment period the PM program continues to be reactive
in nature, relying heavily on visual inspections that do not
involve disassembly or physical measurements, and on the obser-
vations of operators monitoring noticeable changes in component
l operating characteristics. There continues to be no program to
analyze for trends in failures or any other measurable parameter
other than pump capacity on certain pumps. The licensee has not
responded to NRC initiatives to upgrade the PM program to incor-
porate vendor recommendations and industry experience. The plant
continues to rely on surveillance tests to identify problems that
may be in some advanced stage of development due to aging
equipment. At the close of the assessment period the licensee
assigned an engineer to develop a program of predictive analysis
focusing on vibration and lubricating oil analysis. Evidence of
problems associated with aging of plant equipment during the
assessment period included:
a. Several examples of end of service life for solenoid valves
on the turbine stop valve, diesel fire pump (DFP), and the
exhaust ventilation downstream isolation valve.
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b. Deterioration of fuel delivery system on the DFP.
c. Failure of several motor operated valves to operate on
demand, including the turbine bypass isolation valve, the
recirculation pump suction valve, turbine stop valve, and
the shutdown system reactor isolation valve.
A regionally based inspection performed in response to a
, declining performance trend identified in SALP 5, pointed out
! weaknesses in the PM program including failure to update the
progri.a based on plant experience, inadequate root cause analysis,
and inadequate consideration of the generic implications of
maintenance action. The report recommended a more comprehensive
method of evaluating potential end-of-service-life failures.
Another regionally based inspection assessed the adequacy of the
licensee's response to Generic Letter 83-28 and determined the
licensee was generally meeting the requirements in the areas of
vendor interface and post maintenance testing. The report noted
the lengthy delays in implementation of the vendor interface
program and inadequacy of post maintenance testing instructions
and documentation.
For the last half of the assessment period the site engineering
group has functioned under the Maintenance Department, an
organizational move intended to improve coordination between the
engineering and maintenance functions. The engineering group
seems slightly overburdened, a situation compounded by lack of
consistent prioritization of project assignments. Engineers were
regularly redirected from one project to another based on manage-
ment's sense of urgency over a given engineering project. The
licensee, at the end of the assessment period, performed an
inventory of all engineering projects and has devised a system
of consistent prioritization which should alleviate this problem.
The quality of modification packages prepared by the site
, engineering group is consistently high, reflecting the group's
extensive familiarity with the facility and a genuine interest in
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the safe and successful operation of the plant. Sound engineering
judgement that stresses safety and reliability is evident. Some
members of the staff do not consistently identify and incorporate
into their proposals and designs the quality requirements derived
from the various codes and regulations, relying instead on review
, by the Quality Assurance group to identify all the requirements.
! The deficiencies in the Nuclear Operations Department Standards
(N0DS) discussed in Section IV.I contribute to this problem.
A communication barrier exists between members of the engineering
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and mechanical maintenance staffs, and the knowledge of mechanics
- is not routinely conveyed to engineers or factored into design
decisions. A notable example is information gathered by mechanics
during disassembly and cleaning of RDS valve top assemblies which
never made its way to the engineer in charge of the project.
This resulted in the repeated failure of the RDS valves.
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.
While licensee management is generally informative and cooperative
with NRC inspectors, there is only a marginal level of respon-
siveness to NRC initiatives displayed. Compliance with regulatory
requirements is generally adequate, but mediocrity or deficiencies
in performance or programs is tolerated and often justified by
citing budgetary and manpower constraints. Management action in
the areas of preventive maintenance, mechanical training
upgrading, and resolution of long standing engineering projects
is marginal. Management's lack of effective control of the
outage process was a major factor in the events during the 1985
outage discussed in Section IV.H. The reorganization of both the
maintenance and engineering functions under one Superintendent
appears to be too much activity for any one individual to
effectively manage, contributing in part to the licensee's
commencement of the 1985 outage with incomplete engineering
projects, inadequate scheduling of maintenance activities, and
deficient material procurement to support planned work.
2. Conclusions
The board rates the licensee Category 2 with a declining trend
based primarily on insufficient management control over the
maintenance process.
3. Board Recommendations
The board notes that this is the second consecutive assessment
period of declining performance and special management attention
is needed to offset the effects of aging equipment.
.
D. Surveillance and Inservice Testing
1. Analysis
During this evaluation period the resident inspector regularly
observed licensee performance in this area. These inspections
included observations of technical specifications required
surveillance testing to verify adequate procedures were used,
that instruments were calibrated, and that test results conformed
with technical specifications and procedure requirements. In
addition, all or part of four regional inspections were conducted
in this area. These inspections reviewed startup core perfor-
mance, Containment Integrated Leak Rate Tests, intergranular
stress corrosion cracking, and inservice testing.
Big Rock Point uses a manual tracking system to schedule
performance of operational surveillance of mechanical, electrical,
and Instrumentation and Control (I & C) components and systems.
Each surveillance procedure is sponsored by a knowledgeable
individual, and the mechanism exists for revision to the
procedure based on performance experience. Surveillances are
generally taken seriously by those performing the test and not
run to simply satisfy a requirement. Two surveillance tests
were overlooked during the evaluation period, including daily
15
_ _ _ _ - - _ _ _ .
._ __ _ . - __ .
.
.
control rod drive exercises and test of fire detectors in the
recirculating pump room. Cumbersome administrative controls
over fire detector tests contributed to the pump room detector
,
-
omission.
1'
During the evaluation period, one unresolved item resulted from
a concern over the frequent lack of detail in instructions and
documentation of post maintenance testing when work orders and
equipment outage requests are used to meet the post maintenance
testing requirements of Generic Letter 83-28, Sections 3.1 and
3.2.
An inspection reviewed the licensee's Inservice Inspection (ISI)
program after the corporate ISI group was disbanded in favor of
inder endent program administration at each plant. The inspection )
'
reviewed the Big Rock 1985 ISI Examination Program Plan and the
licensee's outage plan and found them to be acceptable.
Observations of ISI activities shows plant personnel have an
adequate understanding of work practices and adhere to procedures
that are generally well defined. Records are generally complete,
and indicate that equipment and material certifications are kept
current.
This inspection also reviewed the licensee's inspection program
to detect intergranular stress corrosion cracking (IGSCC) in
i
large diameter recirculation system piping to verify that the
actions set forth in Generic Letter 84-11 were performed. The
inspection determined the acceptability of inspection procedures
and techniques, documentation, and examiner qualifications.
4
In reviewing the licensee's containment integrated leak rate test
(CILRT), the inspector noted that the activity was adequately
staffed with knowledgeable individuals experienced in the Big
Rock unit. No specific training of the participants had preceded
the event and the licensee's familiarity with Type A testing
requirements was weak. Licensee management involvement in
supplemental verification testing was considered marginally
acceptable as evidenced by efforts to complete the Type A test ,
,
before acceptable supplemental verification test data was '
1
obtained.
In the area of startup and surveillance testing programs
subsequent to the refueling outage, the inspector concluded that
licensee personnel appeared to understand technical issues and
had a genuine interest in plant operations, providing timely and
thorough responses to inspector identified concerns. Procedures
appeared to be well written and employed a technically sound
methodology.
l
2. Conclusions
The licensee is rated Category 2 in this area. This is a decline
in performance from the last assessment period based primarily on
the missed surveillances.
- 16
,
. _ . . _ . , . . .- . _ . . . _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ . , _ _ _ _ _ _ _ _ _ _ . _ , _ . _ . _ _ _ _ _ _ . . _ _ _ . . . . . _ . . _
-- _ -.- -_ __. .- .. - ..
.
i .
3. Board Recommendations
None.
- E. Fire Protection
1. Analysis
I
i During this assessment period the resident inspector routinely
observed licensee activities in the fire protection functional
area, including routine housekeeping. One special inspection was
- conducted by Region III personnel to assess the licensee's
compliance with 10 CFR 50, Appendix R, close out previously
identified open items, and verify compliance with routine fire
2
protection program requirements. The report has been delayed
while the staff completes the review of Big Rock Point's '
compliance with Appendix R, and will be addressed in SALP 7.
'
The licensee's ability to respond to fire alarms both in
preplanned drills and actual alarms was observed on several
occasions with satisfactory results that indicated the effective-
ness of fire brigade member training and fire response procedures.
Licensee personnel received hands-on fire training and training
in use of the self contained breathing apparatus. Licensee
- personnel are generally knowledgeable about fire prevention.
'
Housekeeping has improved from the previous assessment period.
Housekeeping during plant operation is generally of high quality
and accessible plant areas of the facility are routinely policed.
Maintenance workers generally clean up after their job is
i complete. Cleaning lockers and assigned areas are part of a
'
housekeeping system that is incorporated into the daily routine.
Supervisors are regularly in the plant and monitor cleanliness
levels, taking action as appropriate. Housekeeping during
!
extended outage periods, as it relates to both fire protection
and contamination control, declines noticeably from periods of
normal operation. While plant appearance deteriorates during
extended outages, post-outage cleanup is generally prompt and
thorough and reflects management involvement.
During NRR visits to the plant, the staff was impressed with
the clean, well ordered appearance of the plant. Even during
construction of the Alternate Shutdown Building, cc struction
materials and supplies were well controlled. The Control Room
appeared very well run and well organized in terms of reference
materials and drawings. '
Throughout the evaluation period the licensee experienced
difficulties with the dependability of the diesel fire pump
(DFP), including end of service life for a solenoid coil on the
fuel supply shutoff valve, sluggish behavior and slow start
times that required cleaning in the fuel delivery system, and
a leaking fuel filter. The greatest cause for concern about the
3
DFP reliability arose during February, 1986, when excessively
,
17
.
.
long start times and erratic starting behavior were corrected by
further cleanings, tightening, and adjusting. Efforts to
diagnose and correct problems were hampered by the age of the
engine and the unavailability of parts and diagnostic instruments.
These facts combined with a shortage of vendor representatives
experienced on older engines make future repairs unlikely. These
factors, combined with the DFP's Core Spray function, make
replacement of the DFP a high priority for the 1986 outage.
The licensee has committed to replace the engine at that time.
2. Conclusions
The licensee is rated Category 2 in this area. There is
improvement noted in housekeeping.
3. Board Recommendations
None.
1. Analysis i
Three inspections were conducted during the assessment period to
evaluate the licensee's performance with regard to emergency
preparedness. These included two routine inspections of the
emergency preparedness program and observation of the licensee's
annual emergency preparedness exercise. Two violations were
identified as follows:
a. Severity Level V - Failure to evaluate the adequacy of
interfaces with State and local governments as part of the
annual audit as required by 10 CFR 50.54(t) (155/84014).
b. Severity Level V - Failure to conduct Health Physics drills
in 1983 as required by the Site Emergency Plan (155/84014).
The above violations were the result of isolated administrative
breakdowns in the emergency preparedness program and not indica-
tive of any major programmatic problem. In both cases the ;
licensee took prompt corrective actions to resolve the violations
and ensure that they would not reoccur.
Management involvement in assuring quality is evidenced by the
fact that corrective actions are effective as indicated by the
lack of repetition of identified weaknesses. Management support
is also shown through the significant corporate assistance in the
training program and in the planning and conducting of exercises.
During the emergency preparedness exercise, licensee management
demonstrated an above average command and control capability
and were effective in carrying out their assigned emergency
responsibilities.
18
l
)
.
.
The licensee continues to be responsive to NRC concerns.
Violations and weaknesses that are identified are almost always
resolved in a timely manner and demonstrate technically sound and
thorough approaches. This is evidenced by the fact that few
issues of concern are identified by the NRC, and those that are
have generally been resolved by the next inspection.
Staffing of key emergency response positions has been adequate
with the authorities and responsibilities of personnel identified.
The licensee has a Senior Nuclear Emergency Planning Coordinator
position at the site, which has been generally adequate to main-
tain the daily emergency program activities at an acceptable
level of performance. Knowledge and capability of personnel to
carry out their assigned emergency response duties and responsi-
bilities was demonstrated during both the annual emergency
preparedness exercise and through walkthroughs of personnel
during the routine inspections. The licensee's performance in
these areas is indicative of an effective training program that
has adequately prepared personnel to carry out their emergency
response assignments. Examination of the training program and
observation of several training sessions during the last routine
inspection determined that the program was sufficiently thorough
and well conducted.
However, several events during the assessment period indicated
awkwardness with interpretation of reporting requirements and
emergency event classification. An example of this was the
notification to NRC Headquarters on May 25, 1985 of Unit
shutdown, which did not advise of the declaration of the
Unusual Event. During these events the licensee's capability
to interpret reporting requirements and classify the events was
less than the level of performance demonstrated during drills,
exercises, and inspection walkthroughs.
2. Conclusions
The licensee is rated Category 1 in this area. The licensee was
rated a Category 1 in this area in the last two SALP periods
which reflects the continued effectiveness of the emergency
preparedness program.
3. Board Recommendations
None.
G. Security
1. Analysis
Two inspections were conducted by region based inspectors during
this assessment period. The resident inspector also conducted
periodic observations of security activities. No violations were
noted during the inspection efforts. l
19
. ___ _ _ _ - _ _
.
.
Several allegations pertaining to alleged deficiencies with the
licensee's security program were received from a member of the
public during this evaluation period. The investigation and
resolution of the allegations have extended beyond the close of
this evaluation period and will be addressed in a future
inspection report.
The licensee has been generally responsive to resolving NRC
concerns. An inspection conducted early in the assessment period
(November 1984) identified the need for revision of the security
plan and some supporting implementing procedures. The most
significant concern pertained to training methods for newly hired
security force officers. These concerns did not constitute
violations or enforcement issues and were generally administrative
in nature. However, they were indicative of security management's
need to more closely monitor the administrative aspects of the
security program. All of the concerns were reviewed during a
February 1986 inspection, and the licensee's actions were
considered adequate to resolve the concerns. The site and
corporate security staff have provided timely and sound technical
solutions to inspection findings.
The February 1986 inspection noted that the morale of the security
force was low but had not deteriorated to the point where job
performance was affected. The primary cause for the morale
,
concern was attributed to long-term labor relation concerns
- beyond the immediate control of the licensee. Licensee management
- was aware of the concern and was addressing the issue, within
existing labor relation constraints. Deterioration of certain
security equipment was also noted and the licensee committed to
resolve the issue in a timely manner. The licensee needs to
, continue to be sensitive to required maintenance for aging
security equipment.
Only one security event was reported during the assessment period.
The event pertained to degradation of a vital area barrier and
did not constitute an enforcement issue.
Training and performance of the security force continued to be
maintained at a high and consistent level during this assessment
period as evident by the excellent enforcement history and lack
of reportable events caused by personnel error. Supervision of
day-to-day operations appears strong.
Corporate security support appears adequate. Licensing issues
are responded to in a timely manner and analysis of such issues
are generally thorough and technically sound. Inspection results
are closely monitored by the corporate security office and the
corporate office responds in a timely manner to help resolve
1 inspection findings and concerns. Audit functions by the
corporate security office appear adequate.
'
,
20
_ _ __ __ .- -- _ _. __ _ _ . _. . _ .
-
_ - - _ . - - _ - - - - - ~
- .. . _. - - - -- .- -. .. . . - _ .
.
.
2. Conclusions
The licensee is rated Category 1 in this area based on
j demonstrated good performance by the uniformed security force
'
members and no violations being cited during this assessment
period. In spite of that the trend is declining based on the
,
aging security equipmen and continued low morale of the guard
~
force.
3. Board Recommendations
None.
1
H. Outages
,
1. Analysis
The Resident Inspector performed routine inspections during
outage periods and one inspection by a Regional Inspector
reviewed refueling activities. These inspections included
observation of maintenance activities including administrative
requirements, review of planning activities, refueling activities,
plant modifications, and post outage testing. One violation was
issued as follows:
Severity Level III - this violation combined in the aggregate
seven identified violations stemming from three separate examples
during the 1985 outage of supervisory personnel, repairmen, and
operators circumventing or ignoring administrative requirements
and not exercising sufficient care and attention to detail to
ensure plant safety. Contributing to the situation was the lack
) of component identification throughout the facility, the absence
1 of a single point supervisory contact to direct the activities of
i travel repair crews, inadequate management involvement in
i directing maintenance activities during the outage, and evidence
of a lackadaisical attitude on the part of certain operators
,
toward adherence to procedural requirements.
During the assessment period the licensee conducted one refueling
'
outage. Originally scheduled for 53 days, the outage was extended
10 days due to delays associated with repairs to feedwater and
poison system valves, turbine alignment troubles, and the dis-
assembly of incorrect valves which was the subject of the
violation noted above. Despite the delays, a significant
number of major outage activities were successfully completed,
including ISI/IGSCC inspections, electrical equipment environ-
mental qualifications modifications, and installation of the
alternate shutdown panel. The licensee completed 1100 main-
tenance orders, eight facility changes and 18 specification
field changes.
!
21
4
-
- . - . _ __ . _ _ ___
.. - _ _ _ _ _ __ _ _ . - _ . _ _ _ . . _ , _ _ _ _ _ _ _ _ _ . _ _ _ _
- . ._ _ . _. -._ _ ___
.
.
Operations Department personnel performed fuel handling
operations for the 1985 refueling outage. Fuel handling was
safely conducted by adequately trained individuals in accordance
with approved procedural requirements. Staffing on both the
reactor deck and in the control room was adequate, and communi-
cation between the two areas was effective. Management involve-
ment in refueling activities was evident. Tool control and
status board maintenance was adequate. Licensee responsiveness
to NRC initiative was evident by their prompt action to correct
procedural deficiencies in data recording and in relocation of
bagged equipment that had obstructed access to the. refueling
deck status board.
During the 1985 refueling outage several incidents occurred
which demonstrated inadequate management control over the outage
process. The incidents involved:
- Repeated examples of contractors and licensee travel crew
j personnel, not normally assigned to Big Rock Point,
performing work on the wrong component or system, pointing
i to inadequate control over the activities of travel crews
and contractors.
- Repeated examples of supervisors, maintenance, operations,
and engineering personnel, and travel crew personnel,
circumventing or failing to adhere to administrative
requirements, particularly those related to component
tagging and isolation.
- Repeated examples by individuals, throughout the
organization, of inattention to detail and failure to
exercise sufficient care in performance of outage related
work to ensure plant safety.
Several factors contributed to the breakdown in the outage
'
management process:
- Throughout the facility, components, valves, and syste;ns
identification was generally inadequate, with many compo-
nents unlabeled. The licensee had not acted upon earlier
requests from the Resident Inspector to improve component
identification and discounted warnings on the potential for
mishaps.
- Forced retirement of several older key members of the
licensee staff, including the Operations Superintendent,
the coordinator of the ISI program, an experienced Shift
Supervisor, and a Maintenance Supervisor who in the past
had acted as a coordinator and single contact point for
control of travel crew personnel. The impact of the loss
3
of these individuals two months prior to commencement of
22
-. ._ __ _ _ - - - .
.-
-
_ _ _ _ _ - - .- _ _ . _ __ . _ _
-. - - = . .. . .- - - - - . . - _ _ . .
.
.
the outage was exacerbated by a major reorganization of
the plant staff with reassignments of functional depart-
ments, creation of new departments, and redistribution of
duties within the Maintenance and Operations Departments
immediately prior to the outage.
,
- In the absence of a single point contact to direct and
- coordinate the activities of travel crew personnel, manage-
l ment involvement in directing maintenance work was
j inadequate.
'
- Training provided for travel crew and local licer.see
'
personnel on tagging and isolation was inadequate.
l * Outage planning, including parts procurement and job
sequencing of specific work activities was inadequate.
Design work on many facility changes was incomplete at
- outage commencement.
- Licensee travel crews were inadequately supervised and did
not display the same level of concern for reactor safety
4
normally in evidence among Big Rock personnel.
- Work crews assigned a particular task often were comprised
entirely of travel crew members without the guidance and
experience of Big Rock employees.
! * Travel crew supervisors invested too little time and effort
- in inspecting and planning a specific job activity and in
- instructing their workmen on the job's performance.
'
.
l * A lackadaisical attitude on the part of certain personnel
i toward attention to detail was a major contributing factor
l in the events.
1
I' The licensee has enjoyed decades of safe and successful reactor
operation resulting primarily from the professional attitude
i
displayed by talented and experienced individuals. The plant's ,
,
limited staff and small physical size makes the outage process a
J manageable activity. The events of the 1985 outage appear to
4
have impressed upon the licensee the need to aggressively manage
outages. The corrective actions in response to the 1985 events
have been comprehensive and include:
l * An expanded component identification program.
!
- A photograph book of the plant to aid in job planning.
j
- Counseling and disciplinary action for personnel involved in
the problems.
l * Expanded training for Big Rock and travel crew personnel.
!
23
r
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-- _ _ _ _
.
.
- Procedure upgrading for valve preventive maintenance.
- Controls on future outage activities of travel crews,
including single point contact and prejob planning.
In addition, the licensee has created new groups to handle
material procurement and control and outage planning and
scheduling.
The licensee's responses to NRC concerns in response to the
incidents showed a desire to communicate and cooperate. The
Plant Superintendent made separate visits to regional and NRR
management to present licensee programs to correct programmatic
and management deficiencies. Prior to the close of the
evaluation period no outage activities were conducted that
would permit evaluation of the licensee's corrective action.
2. Conclusions
The licensee is rated Category 3 in this area.
3. Board Recommendations
The licensee should aggressively implement the corrective
actions noted previously.
,
I. Quvlity Programs and Administrative Control Affecting Quality
1. Analysis
Throughout the rating period the Resident Inspector routinely
reviewed the activities of the Quality Assurance (QA) and Quality
Control (QC) groups. This included administrative controls for
maintenance and operations as well as deviation reports and
quality control department involvement in accordance with the
QA Plan. In addition, this functional area was examined by the
region addressing the adequacy of site QA staffing levels and
qualifications in light of increased work load and the impact of
Nuclear Operation Department of Standards (NODS) deletion at the
facility. The QC activities associated with disposal of low
level radioactive waste under 10 CFR 20 and 10 CFR 61 were
reviewed in Inspection Report 155/85006(DRSS), resulting in one
violation discussed in section IV-B. The violation resulted from
the inadequacy of the licensee's procedure governing the shipment
& of radioactive materials to provide for determination of the
correct waste classification, although worksheets used to
classify the three waste shipments made since the regulation
became effective resulted in the correct waste classification.
The site QA and QC staffs are comprised of a generally adequate
number of qualified individuals with site experience who demon-
strate a high degree of professional conduct and integrity.
24
.- . . _ . - - - . -.- -
.
.
During the evaluation period there was eviJence that the site QA
staff was in danger of becoming overburdened by assignment of
'
several functions formerly performed by the corporate QA group.
Those added duties were subsequently completed or reassigned
elsewhere and the site staff appears adequate for the remaining
workload. The site QA staff communicates effectively with plant
management and is persistent in pressing for management action
to resolve audit findings. The Plant Review Committee (PRC)
considers the quality aspects of technical and safety issues.
In turn, plant management generally demonstrates their regard
for the significance of findings and comments from the QA staff.
Site QC inspectors are generally thorough and conscientious and
draw heavily on their plant experience. Both the QA and QC site
i staff are responsive to NRC initiatives and inquiries.
Licensee corporate management detracted from the effectiveness of
Programs and Administrative controls affecting quality. Examples
include:
a. Licensee corporate management, by transferring to the site
staff several significant Quality Assurance functions with-
- out a corresponding increase in available site resources,
placed a burden on the staff which resulted in QA reviews
that were less comprehensive, withdrawal of commitments to
support audit activities off site, and a virtual elimir.ation
of time available to auditors to review and observe activi-
ties in the plant. Some QA functions were performed by QC
inspectors. The reluctance of corporate management to
respond to the concerns of the site QA Superintendent in
i this regard and their poor response to NRC initiatives to
address the issue was noted.
f b. Licensee Corporate management deleted entirely fifteen N0DS,
i the document in which the licensee staff can theoretically
j be assured of finding all applicable code and regulatory
requirements compiled in one location. The N0DS are the
j means by which the licensee's Quality Assurance Program
! Description for Operational Nuclear Power Plants (Topical
! Report CPC-2A) is implemented, and results from a commitment
j made in the licensee's Regulatory Performance Improvement
Program submitted in response to a March 9, 1981 Confirmatory i
4 Order. Wholesale deletion of the N0DS without a review to
! insure all of the quality requirements contained therein
]
were already addressed in existing administrative procedures
resulted in a period when the quality requirements were not
'
- available to the N0DS user. Inspectors identified at least
two examples of cancelled N0DS being referenced in other
procedures.
I
1
!,
4
25
i
.
.-, , - . - - - - , - - - ,.,r-__ - .
e- - - . - , - _ , , , - , - - - ..,,,,.,v-,-m,w,,-,--,.r--+,, ,v- -_m, v- y-- , 4,-v-,-
_.. --. - . - . . _ - _ _ . . - - - - . _ _ _ - _ _ _ .-
.
.
c. The findings of the licensee's team that N0DS development
was incomplete and that an inadequate review and approval
process allowed the issuance of N0DS with a significant
magnitude of deficiencies relative to CPC-2A basis documents
went unacted upon by management.
'
During the evaluation period the licensee designed and
implemented a program to reduce QA involvement with reviews of
procedures in departments where there was long term evidence of
high levels of quality performance. The program was implemented
late in the period with the licensee's stated goal of redirecting
auditor resources into areas of poorer performance.
2. Conclusions
The licensee is rated a Category 2 in this area. The exemplary
level of performance by the site QA and QC staff is offset by
our concerns with the actions of corporate management.
3. Board Recommendations
None.
J. Licensing Activities
1. Analysis
a. Methodology
,
The basis of this appraisal was the licensee's performance
in support of licensing actions that were either completed
i
or active during the current rating period. These actions,
consisting of license amendment requests, exemption requests,
relief requests, responses to generic letters, TMI items,
LER's, and other actions, are summarized below:
(1) Amendment Requests
Technical Specifications (TS) Defining Operability
for Safety Systems
Containment Pressure and Water Level Monitor TS
Reporting Requirements TS
- TS Change Section 6 - Plant Staff Reorganization
TS Change for Surveillance Frequencies
- Control Rod Testing Frequency
Incorporation of Byproduct License
^
Cycle 21 Reload Il Fuel TS Change Package
Administrative TS
Gamma Monitor Calibration Frequency
Control Rod Withdrawal Rate Limit TS
26
. . - . . - . - -- _- -. . - -- . - . _ - _ . - _ - -
.
.
Post Maintenance Testing TS Change - Item 3.2.3
PRC Approval Method TS
CRD Performance Testing Frequency TS
Auto-Isolation (CV-4049) TS
Stack Gas Monitoring System TS
Organizational TS
Appendix I TS Implementation Review
Administrative TS Changes Related to RETS
Integrated Program Plan (ILS)
Appendix "R" Alternate Shutdown System TS
ATWS Recirculation Pump Trip
Containment Airlocks
Reporting Requirements - Spurious RPS Actuations
Fire Protection
Equipment Environmental Qualification
High Point Coolant System Vents
(3) Relief Requests
In-Service Testing
In-Service Inspection
(4) TMI Items
I.C.1, Emergency Operating Procedures
I.D.1, Detailed Control Room Design Review
I.D.2, Safety Parameter Display System
II.B.1, Reactor Coolant System Vents
II.D.1, RV and SV Testing
II.F.1, Accident Monitoring
II.F.2.3, Inadequate Core Cooling Instrumentation
III.A.1.2, Emergency Response Facilities
III.A.2.2, Meteorological Data Upgrade
(5) Other Licensing Actions
BWR Pipe Cracking
Salem ATWS Follow-up
Electrical Equipment Qualifiction
Systematic Evaluation Topics
Fire Protection Modifications
Diesel Generator Reliability
Retention of Contaminated Soil Onsite
During the SALP period, 67 licensing actions were completed
which consisted of 45 plant-specific actions, and 22 multi-
plant actions including nine TMI (NUREG-0737) actions.
27
__ -___ _______ . _ _ _
.
.
A very important licensing activity completed during the
review period was the formalization of the Big Rock Point
Integrated Assessment. License Amendment No. 82, " Plan for
the Integrated Assessment," issued February 12, 1986,
incorporates the requirement to adhere to the " Plan," as
documented in License Condition (7) of Big Rock Point
Facility Operating License DPR-6. This achievement is
noteworthy as Big Rock Point is one of the industry
leaders in terms of long-term program implementation.
In addition to these licensing activities the project
manager and other members of NRR participated in an
in progress audit of the licensee's Detailed Control Room
Design Review process as well as 10 CFR Part 50, Appendix R
related modifications,
b. Management Involvement and Control in Assuring Quality
Licensing activities for Big Rock Point show consistent
evidence of prior planning and assignment of priorities and
decision making is almost always done at a level that ensures
adequate management review. The cornerstone of the
licensee's efforts in this area is the Big Rock Point
Integrated Assessment (termed the Plan). The licensee
adopted this integrated approach to licensing issues in
early 1983. Much of the initial assessment was completed
during the last evaluation period; however, the incorpora-
tion of the Plan was completed during this evaluation period.
As part of an on going process, the licensee makes safety
judgements based on the use of the Big Rock Point Proba-
bilistic Risk Assessment as well as standard safety assess-
ment methods to ensure that plant safety is optimized in a
cost-effective manner. The Plan governs the implementation
of significant facility changes.
As presented above, there have been a significant number
- of licensing actions processed, and for the most part, the
majority were completed requiring little or no additional
information or meetings. Adequate management control was
not exercised, however, in the handling of the Reactor
Depressurization System (RDS) Valve Testing Technical
Specification Change Request to reduce surveillance testing
frequency. The request showed a lack of prior planning and
the technical evaluation was not thorough. This RDS issue
has been ranked by the licensee as the most important
current facility project as described in Integrated Plan
Update No. 4. NRR agrees with the licensee's ranking and
believes a continued strong management involvement for
assuring quality on this project is needed.
An area in which Big Rock needs to focus more attention is
in their safety evaluations generated to support submittals
to NRR involving proposed license amendments. Examples of
safety evaluations which we found to be less than adequate
28
_ __
b
.
.
were the application for the incorporation of the byproduct
license and the application related to the corporate
reorganization. Both applications required extensive NRC
efforts to evaluate the impact of the proposed changes.
Also, the depth of explanation of the no significant hazards
consideration (NSHC) determinations could be improved. It
should be noted that the applications presented above were
evaluated during the first half of the evaluation period;
and we have noted improvement over the past year.
During the last half of the evaluation period, the licensee's
evaluations have been well stated, understandable, and
,
showed consistent evidence of prior planning. Most of the
,
applications received have been timely, thorough, and showed
decision making consistently at a level that ensures
'
adequate management review.
We recognize the strong improving trend; however, Big Rock
i must be keenly aware of their unique plant design and as
such should strive to fully present complete information
to the staff. The key point being that the audience to
which Big Rock is presenting their SEs, in some cases, is
not as familiar with plant-specific design features unique .
i
to Big Rock, and therefore, a conscious effort should be j
made to present more information to better understand a
', given issue.
!
c. Approach to Resolution of Technical Issues from a Safety
3
Standpoint
l
The licensee generally demonstrates understanding of the
technical issues involved in licensing actions and proposes
technically sound, thorough, and timely resolutions.
, However, there have been issues where the licensee's
approach was good, but the licensee did not thoroughly
understand NRR staff guidance. Once the staff guidance :
was fully explained, the licensee proposed timely resolutions l
l which were technically sound and exhibited proper conserva-
- tism. For a few issues, full explanation of the staff
guidance required an above average amount of staff effort. ,
Examples of such issues are Incorporation of Byproduct
'
. License, RDS Valve Testing, and Environmental Equipment
Qualification.
It should be noted, however, that the issues presented above
- were evaluated rarly in the evaluation period. During the
'
last half of the evaluation period, the licensee has
demonstrated a clear understanding of the issues, appropriate
conservatism when the potential for safety significance
existed, and generally sound and thorough approaches. This
reflects positively on Big Rock Point's willingness to work
closely with the staff. l
I
i
29
.
.
d. Responsiveness to NRC Initiatives
The licensee's initial responses to NRC initiatives almost
always contain acceptable resolutions, provide for timely
resolution of issues, always met deadlines and were generally
sound and thorough. Although the assessment for this
attribute was determined to be near average for the first
half of the evaluation period (due to the Incorporation of
the Byproduct License, RDS Valve Testing, and Environmental
Qualification of Electrical Equipment), the performance of
the licensee for this attribute during the second half of
the evaluation period was excellent. We attribute this,
in part, to the willingness of the plant manager to take
control and ensure mutual goals are attained.
e. Enforcement History l
1
This area is addressed in other functional areas of this
report.
f. Reporting and Analysis of Reportable Events
The Big Rock Point plant operated at power during most of
the report period, except for about two months of refueling
outage from September 6, 1985 to November 7, 1985, and short
periods of shutdown for other causes. In a period of about
eight months (from January 1, 1985 to September 6, 1985),
the plant operated with a Reactor Service Factor * of 82%.
In the 17 months covered by this SALP evaluation, the
licensee reported eight** events to the NRC Operations
Center as required by 10 CFR 50.72. Three unusual events I
concerning mechanical and electrical failures were also I
reported. One of the unusual events reported dealt with
the shutting down of the unit from 91% power on December 31,
1984 due to failure of the reactor depressurization system
(RDS) valves to pass as 'urveillance test. Failure of the
RDS valves was noted in the previous SALP report on this
plant. The repetition of the RDS valve failure suggests
that the licensee needs to give more attention to follow-up
analyses and actions. Two of the three unusual events,
including RDS valve failure, resulted in entry into limiting
condition for operation (LCO) action statements. During
this report period, 12 Licensee Event Reports (LERs) per
10 CFR 50.73 were received.
- Reactor Service Factor = (Hours of Critical Reactor
Operatior./Possible Hours) x 100%.
- The number of events reported to the operations center may
not be the same as the number of Licensee Event Reports
because of different reporting criteria and in some cases
an event initially reported to the operations center may be
reassessed as not reportable.
30
.
.
Of the eight 50.72 reports, two reports involved reactor
scrams which occurred in 1985. These scrams were manually
performed at 10% and 15% power. This reactor trip frequency
of two per year compares favorably with the current national
average frequency of 5.9 trips per year.
Of the remaining six 50.72 reports, four reports involved ,
reactor protection system actuations due to a spurious '
signal resulting from electrical noise affecting power level
instrumentation at low power levels. Two of the spurious
RPS actuations involved no rod movement, while a third
occurred during control rod drive testing and resulted in
the insertion of the single withdrawn control rod. The
fourth actuation occurred at 0.1% power while shutting down
for routine maintenance. One report dealt with the loss of
emergency notification sirens. The last of the 50.72
reports pertained to a discovery that a support hanger for
the reactor depressurization system had not been preten-
sioned after a system hydro several years ago (3-6 years)
due to what the licensee called a procedure inadequacy.
Although this incident represented a fourth unusual event,
the licensee failed to inform the NRC that an Unusual Event
had been declared until securing from that classification.
None of the reportable events was considered individually l
significant enough to warrant detailed NRR staff follow-up.
None of the events reported during the period was discussed
,
at the Operating Reactor Events Briefings.
g. Staffing
The licensee has a licensing staff which appears to be
sufficient to provide adequate and timely responses.
Positions are identified and authorities and responsi-
bilities are well defined. The CPC licensing contacts
for the NRR licensing Project Manager at the facility and
in the Corporate Office have or once held an SR0 license.
Because of the Operations experience of these contacts many
technical issues can be' resolved on initial contact with
the licensee.
Management attention and involvement was generally aggressive l
and disciplined. This was evident in both the safe and efficient i
operation of the facility. Staffing levels and quality were '
adequate. Commurication levels between the operating staff and
proper management were established and generally effective. The i
licensee has been, in most cases, effective in dealing with !
significant problems and NRC' initiatives. The licensee's ;
attention to housekeeping appears to have been excellent. The
licensee's efforts in the functional area of Licensing Activities
has significantly improved during this evaluation period. This
is reflected in the quality of work, attention to NRR concerns
and involvement of senior management. Big Rock was an active l
participant at the counterparts meeting of January 30, 1986, and
31 l
1
_ ._. _, ,
.
.
their plant superintendent has visited Headquarters to give an
independent perspective of this concerns, and views regarding
major issues confronting Big Rock and the utility industry.
Thus, we see several trends which have brought this utility
upward in our evaluation scale. We note room for improvement
and all indications reflect a very positive attitude toward
continued improvement.
2. Conclusions
The overall rating for the functional area of licensing activities
is a Category 1. During this period, the licensee's performance
was found to be above average to excellent overall.
3. Board Recommendations
None.
K. Training and Qualification Effectiveness
1. Analysis
The resident and regional based inspectors regularly reviewed
training and qualifications during inspection of other areas and
review of events. No violations were identified in this area.
During the assessment period, NRC examinations were administered
to five Reactor Operator candidates. All candidates passed the
examinations. This passing rate is significantly above the
national passing rate. Based on these results, the operator
licensing training program at Big Rock Point is considered
satisfactory.
", During the evaluation period several instances were identified
where specialized training was conducted prior to non-routine
operations or maintenance activities. Examples include: I
a. Prior to installation of a Control Rod Drive with a unique l
modification the maintenance crew received instructions from
an experienced Superintendent using mock-ups.
b. The licensee's maintenance staff received training in the use
of new Control Rod Drive overhaul equipment by the Vendor,
General Electric.
c. Some training was conducted for Operation Personnel prior to
installation of spent fuel pool racks.
d. Walkthrough by Operation Personnel on Emergency Operating
Procedures under preparation served to familiarize the
operators and identify weaknesses in the procedures.
32
- _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
.
.
e. Extensive training was conducted for Operators, Superinten-
dents, On-call Technical Advisors, and Instrument and
Control Technicians prior to startup of the Alternate
Shutdown System required by Appendix R.
f. Reviews were conducted of procedures prior to installation
of recirculating pump seals.
g. Training was conducted for all personnel in use of Scott
Air Paks.
h. Hands-on Fire Training for all personnel was conducted.
One Example where training was inadequate was in the preparation
l of travel crew workers in the use of local control (equipment
tagging) procedures.
The training department routinely incorporates into system
training and requalification cycle training the information i
contained in all LER's, IE Notices, GE-SILS, Deficiency Reports,
and industry reports. i
Effective April, 1986, the Operations department instituted an On
the Job Training (0JT) program aimed at consolidation of five
former training programs leading to the SR0 license. The program
will use qualification cards. The program's effectiveness will
be evaluated during SALP 7.
Maintenance personnel during the period received virtually no
l
training. In February the licensee began sending maintenance
personnel to the Bay City Skills Training Department for General
Maintenance Training that is not specific to nuclear applications.
The Training Department has not received a request for Systems
Training for Maintenance Personnel.
The Training Department during the SALP period has added to its
staff several individ'uals with extensive experience in operations,
maintenance, or instrumentation and controls. This in plant,
hands-on experience contributes to the quality of lesson plans
and presentations. Students seem to exhibit a high degree of
respect for the instructors. Management involvement was reduced
because of the frequent temporary offsite assignments of the
Training Administrator.
There were no licensing actions which provided a clear
opportunity to judge this attribute. Based on interface with
CPC's licensing and operations personnel, it appears that the
training and qualification program makes a positive contribution
to the understanding of technical issues and adherence to
procedures with few personnel errors. Based on first-hand
experiences with operations personnel, the NRR licensing
Project Manager believes, however, that some improvement
could still be achieved.
33
__ __. _ _ _ _
.
O
2. Conclusions
The licensee is rated Category 1 in this functional area.
3. Board Recommendations
None.
i
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l
34
__ _ _ _ _ _ _ . _ _ _
.
.
V. SUPPORTING DATA AND 9JMMARIES
A. Licensee Activities
The unit engaged in routine power operation throughout most of SALP 6
except for a scheduled outage for the 20th plant refueling which began
on September 6, 1985 and was completed on November 8, 1985.
The remaining outages throughout the period are summarized below:
December 31, 1984 - January 6,1985 Scheduled outage for
surveillance on RDS
valves l
l
April 5-17, 1985 Scheduled outage to l
repair RDS valves ;
1
May 15-19, 1985 Outage to repair
recirculating pump seal
May 25-20, 1985 Shutdown to repair leak
on heat exchanger on
recirculation pump
May 26-27, 1985 Shutdown to repair leak l
on heat exchanger on
recirculation pump
November 14-18, 1985 Vessel flange
0-ring leakage
November 19-24, 1985 Vessel flange
0 ring leakage
December 7-8, 1985 Steam leak
February 11-17 RDS valves leaking
The plant scrammed six times (four occurred while the plant was less
than 0.1% power). In 1985, the two at power scrams were manually
initiated. One was caused by a failure to manually reset a feedwater
valve prior to plant startup while the other was caused by a minor
steam leak in the recirculation pump room. The four remaining scram
signals were caused by susceptibility of the picoammeters to
electrical noise at low neutron flux levels, a known operating
characteristic of the equipment with little safety significance.
B. Inspection Activities
An emergency preparedness exercise was conducted during the SALP
period by Region III involving observations by nine NRC representatives
of key functions and locations during the exercise.
Violation data for the Big Rock Point Plant is presented in Table 1,
which includes Inspection Reports No. 84013-86006.
35
_ _ _ _ _ _
_ _ _ _ . _ _ - - _ _ _ _
.
.
.
Table 1
ENFORCEMENT ACTIVITY
FUNCTIONAL N0. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA
III IV V
A. Plant Operations 1 1 !
B. Radiological Controls 1
C. Maintenance / Modifications
D. Surveillance and Inservice Testing
E. Fire Protection
G. Security
H. Outages 1
I. Quality Programs and
Administrative Controls
Affecting Quality
J. Licensee Activities
K. Training and Qualification
Effectiveness
TOTALS 1 1 4
C. Investigations and Allegations Review
Several allegations pertaining to alleged deficiencies with the
licensee's security program were received from a member of the public
during this evaluation period. While no immediate safety concerns
were identified the investigation and resolution of the allegations
have extended beyond the close of t,his evaluation period and will be
addressed in a future inspection report.
D. Escalated inforcement Actions
A Severity Level III violation was issued early in 1986 for two
separate incidents which occurred in 1985 resulting from a failure of
supervisory personnel and repairmen to follow procedures. No civil
penalty was issued because of prior good performance and extensive
and comprehensive corrective actions.
E. Licensee Conferences Held During Appraisal Period
1. January 29, 1985 (Glen Ellyn, Illinois) i
{
Licensee presentation on history and operation of Reactor
Depressurization System.
1
36
_ _ _ _
,
,
.
2. March 12, 1985 (Glen Ellyn, Illinois) t
Meeting to review Systematic Assessment of Licensee Performance
(SALP 5).
3. October 1, 1985 (Glen Ellyn, Illinois)
Licensee presentation on new reorganization.
4. December 5, 1985 (Glen Ellyn, Illinois)
l
Meeting to discuss the breakdown in management controls of
'
plant work activities.
l
F. Confirmation of Action Letters (CALs) l
l There were no CALs issued during this SALP assessment.
G. Review of Licensee Event Reports, Construction Deficiency Reports, I
and 10 CFR 21 Reports Submitted by the Licensee
1. Licensee Event Reports (LERs)
LERs issued during the 17 month SALP G period are presented
below:
LERs No.
84-14
85-01 through 85-09
86-01 through 86-02
Proximate Cause Code * Number During SALP 6
Personnel Error (A) 3.
Design Deficiency (8) -#
-0
l External Cause (C) 5
Defective Procedure (D) 1
Management / Quality Assurance
Deficiency (E) 0
Others (X) 1
No Cause Code Marked ** 2
Total 12
- Proximate cause is the cause assigned by the licensee
according to NUREG-1022, " Licensee Event Report System."
- NUREG-1022 only requires a cause code for component failures.
In the SALP 5 period, the licensee issued 27 LERs in 16 months l
for an issue rate of 1.7 per month. In the SALP 6 period the l
licensee issued 12 LERs in 17 months for an issue rate of 0.7
per month. Four of the LERS were submitted for RPS activation
known as " nuisance trips" resulting from electrical noise which j
gives an upscale /downscale trip signal at less than 1% power. ;
37
- - - -- _ - - = - . _ . . . _. =_ _ -. ...._. __
- .,
.
,
.
The licensee submitted a request to be exempt from this reporting
'
. requirement. This request was denied because the requirement
! will be revised to address this problem. The reduction in
!
overall LERs is indicative of an improving trend.
The office for Analysis and Evaluation of Operational Data (AE00)
reviewed the LERs for this period and concluded that, in general
i the LERs are of above average quality based on the requirements
'
contained in 10 CFR 50.73. However, they identified some minor
i deficiencies. A copy of the AE0D report has been provided to the
licensee so that the specific deficiencies noted can be corrected
i in future reports.
l 2. Construction Deficiency Reports i
f
i No construction deficiency reports were submitted during the
,
assessment period.
,
3. 10 CFR 21 Reports
No 10 CFR 21 reports were submitted during the assessment
period.
j H. Licensing Activities
i
) 1. NRR/ Licensee Meetings (at NRC)
!
! SALP 5 Region III 03/12/85
i Licensing Action Prioritizations 08/14/85
- Maintenance Practice Discussions 10/01/85
j Enforcement Conference 12/05/85
. Counterparts Meeting 01/30/86
l Fire Protection 03/31/86
i
!
2. NRR Site Visits / Meetings
- Plant /0rientation 11/07-08/84
! Plant Orientation for PM/PD 07/07-12/85
i Licensing Action Prioritization 10/02/85
{ Fire Protection 12/20/85
i DCRDR In-Progress Audit 1/27/-31/86
i
3. Commission Meetings
l
i
! None
!
i 4. Schedule Extensions Granted
i
{ Equipment Qualification 03/27/85
i !
I l
! l
!
1
! -
i
38
l
_
.
s
e
5. Reliefs Granted
ISI Relief Requests (Revision 3) 11/01/85
ISI Relief Requests 12/12/85
6. Exemptions Granted
Appendix R, III.G.2 03/26/85
RCS High Point Vents 07/17/85
Containment Airlocks Testing 01/08/86
ATWS Recirculation Pump Trip 03/20/86
7. License Amendments Issued
Amendment Title Date
71 Plant Review Committee Review Process 12/10/84
72 Incorporation of Byproduct License 04/18/85
73 Control Rod Drive Performance Testing
Frequency 05/01/85
l
74 Containment Isolation Valve CV-4049 06/07/85
75 Stack Gas Monitoring System 06/10/85
76 Administrative Controls 07/01/85
77 Radiological Effluent Technical
Specifications 08/26/85
78 Definition of Operability & Associated
LC0 10/02/85
79 Surveillance Frequencies 10/22/85
80 Containment Pressure & Water Level
Monitor 10/29/85
81 Reload Il Fuel MAPLHGR Limits 11/01/85
82 Plan for the Integrated Assessment 02/12/86
83 Plant Staff Reorganization and
Administrative Changes 03/10/86
8. Emergency Technical Specifications
None
9. Orders Issued
None
10. NRR/ Licensee Managment Conferences
None
39
L. .
.
.
.. . _ _ . . . . .