ML20150F858
| ML20150F858 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/30/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20150F844 | List: |
| References | |
| 50-155-87-01, 50-155-87-1, NUDOCS 8804060028 | |
| Download: ML20150F858 (4) | |
See also: IR 05000155/1987001
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Enclosure 1
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APPENDIX SALP 7
SALP BOARD REPORT
NUCLEAR REGULATORY COMMISSION .
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE'
50-155/87001
Inspection Report No.
Consumers Power Company
Name of 1.icensee
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! Big Rock Point Plant
Name of Facility
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l April 1, 1986 through August 31, 1987
! Assessment Period
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Enclosure 1
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A. Summary of Meeting with Consumers Power Company on December 21, 1987
The findings and conclusions of the SALP board documented in Inspection
Report No. 50-155/87001 were discussed with the licensee on December 21,
1987, in Charlevoix, Michigan. The 11censee's regulatory performance
was presented and found acceptable in each fJnctional area.
The following licensee and NRC personnel attended the meeting.
Consumers Power Company
F. Buckman, Vice President Nuclear Operations
G. Slade, Executive Director for Nuclear Assurance
R. Abel, Production and Plant Performance Superintendent
R. Alexander, Technical Engineer
J. Beer, Chemistry / Health Physics Superintendent
M. Sralinski, Senior Engineer
W. Blosh, Maintenance Engineer
G. Boss, A0
T. Hagan, Human Resources Director
C. Macinski, Plant Public Affairs Director
0. Moeggenberg, Engineering Supervisor
G. Petitjean, Planning / Administrative Services Superintendent
E. Reciborski, Scheduling Administrator
R. Schrader, Electrical I&C Engineering Supervisor
W. Trubilowicz, Operations Superintendent
M. Vankist, Property Protection Supervisor
G. Withrow, Engineering Maintenance Superintendent
R. Suchmar, Nuclear Plant Training Administrator
A. 'lrickenberger, Quality Control Supervisor
P. Donnelly, Nuclear Assurance Administrator
L. Monshor, Quality Assurance Superintendent
Ny: lear Regulatory Commission
W. Guldemond, Chief, Reactor Projects Branch 2
I. d. Jackiw, Chief, Reactor Projects Branch 28
S. Guthrie, Senior Resident Inspector
C. Papriello, Deputy Regional Administrator
B. Comments Rece*ved from Licensee
By let'.er dated January 20, 1988, the licensee provided written comments
on the SALP report in accordance with the forwarding letter.
In regards to the comments relative to Section IV.B., "Radiological
Controls," the staff reviewed the issue of failed fuel and cancelled
inspection on fuel bundles scheduled for return to the reactor core.
Resolution of this concern involved several conference cells to address
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Enclosure 1
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the testing necessary to determine that no leaking fuel bundles were
returned to service. Your eventual ultrasonic testing of fuel bundles
being returned to the core satisfied our concerns in this area. Based
on cur review of the information on gaseous releases, the report will
be corrected to reflect the following:
As a result of continuing fuel cladding problems, radioactive
gaseous releases until March 1987, when the fuel problem was
corrected, continued to be about a factor of 6 higher . ...
In regards to the comments relative to Section IV.C., "Maintenance,"
we accept your comments as they relate to EEQ and Appendix R. Concerning
the effectiveness of mainte,ance programs at Big Rock Point, the staff
remains concerned that the current level of preventive, predictive, and
corrective maintenance at the facility may be only marginally adequate to
counter the effects of equipment aging and normal plant wear. The staff
encourages you to continue to emphasize your preventive and predictive
maintenance effort toward the goal of enhanced plant safety through such
activities as pump overhauls.
In regards to the comments relative to Section IV.D., "Surveillance,"
the staff scknowledges your clarification of the status of the battery
service test. The inaccuracy in Paragraph 3 has been deleted from the
SALP report. The following statement has been deleted:
One surveillance on the station battery was not performed while
the requirement for its performance was under review by NRR.
In regards to the comments relative to Section IV.K., "Training and
Qualificatior. Effectiveness," the staff appreciates the additional data
you provided to describe the improvements made in upgrading the skills of
the mechanical / electrical maintenance staff. Based on our review of that
information the report will be amended to reflect the following:
Skills training was generally conducted on schedule with only minimal
impact from plant operations.
Significant increase in training man-days were in evidence when
compared to the training effort during the previous assessment period.
The staff continues to regard skill training and worker protection training
to be of a general nature and not sufficiently nuclear plant specific to
be of immediate benefit in upgrading the effectiveness of the newest
members of the mechanical / electrical maintenance staff. A review of the
CPC0 Training Records System Employee Training Report updated through
January 4, 1988, for the five mcst recent additions to the maintenance
staff indicate that the training provided these individuals during the
assessment period heavily emphasized worker safety. Examples include the
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Enclosure 1
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l confined spaces and fire brigade training, protective tagging procedures,
asbestos control, and respirator use. During the last month of the
assessment period, the individual's course work began to emphasize general
skills through training courses emphasizing introduction to valves,
introduction to blue prints, hand tools, power tools, electrical math, and
basic DC electricity. Big Rock Point System training for these and other
individuals commenced August 17, 1987, two weeks prior to the close of
the assessment period.
In regards to the comments relative to Section IV.E., "Fire Protection,"
Section IV.G., Security,Section IV.K., Licensing Activities, we
acknowledge your comments and these facts will be factored into the
SALP 8 assessment period.
C. Regional Administrator's Conclusions Based on Consideration of
Licensee Comments
Based on my review of the comments provided by the licensee, I have
concluded that the overall ratings in the affected areas have not
changed. Actions identified in the letter of response to SALP 7 dated
January 20, 1988 will be factored into future Region III inspections.
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Consum8Is
POW 8r Fr.a. rick w sockm.n
Srmor Vue Pressdent
POWERING Ewty Supply
MICNIGAN'S PROGRE55
Generst Omces 1945 West Parnell Road. Jackson. MI 49201 e (517) 7881217
January 20, 1988
Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
DOCKET 50-155 - LICENSE DPR-6 - BIG ROCK POINT PLANT -
SALP 7 REPORT C0KKENTS
Consumers Power Company appreciates NRC effort in assessing the nerformance of
Big Rock Point during the SALP 7 period. Of special note was Mr. Paperiello
and the SALP Board holding the presentation in Charlevoix, Michigan, which
permitted an increased attendance of Consumers Power Company personnel responsi-
ble for the operation of Big Rock Point. The direct communication was a
valuable part of the overall SALP process, and it will assist us in planning
future strategies and activities to achieve excellence in performance.
Following the presentation and review of the SALP 7 Report, Consumers Power
Company provides the following com=cr.ts.
A. Plant Operations
No Co= cents.
4 B. Radiological Controls
Unresponsiveness to NRC initiatives and concerns for fuel inspections was
never our intent. Only after carefully examining previous cycles' fuel
failures, current indicators, and personnel doses was the decision made not
to inspect fuel. We were confident that the fuel causing the failures was
being discharged and not used in Cycle 22. In the spirit of ALARA, the
possibility was great for receiving more dose from fuel inspections than
the fuel failures we had been experiencing. Results of ultrasonic inspections
and next cycle performance substantiated our original evaluation that all
4 leaker bundles were discharged. Paragraph six (6) of this section incorrectly
refers to "... gaseous releases... continued to be about a factor of 6 higher
than normal." After the Cycle 22 Refueling Outage (March, 1987) gaseous
release rate was restored to normal and currently no leaking fuel is
evident.
It is true that a water chemistry control program based on BWR Ovners Group
Guidelines was not formalized, however, virtually every chemistry parameter
is within these guidelines and we feel confident that plant management
would take the appropriate measures if these parameters were above the
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Nuclear Regulatory Commission 2
Big Rock Point Plant
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? ALP 7 Report Comments
January 20, 1988
"action levels" of the guidelines even though they were not procedura11 zed.
The applicable guidelines will be incorporated into plant procedures over
the next procedure review cycle.
We note NRC concerns and have implemented improvements in the ALARA and
Radiation Work Permit programs and frisking equipment / practices since the
assessment, and will continue efforts to further reduce dose and contamin-
ation incidents.
C. Maintenance
Consumers Power Company utilized extensive resources in establishing a
"good f aith" ef fort in complying with the EEQ and Appendix R regulations.
However, both the EEQ and Appendix R efforts evolved over a very long time
period allowing program managers, both Consumers Power Company and NRC, to
change during program development and compliance rTriew. Decisions or
compliance interpretations agreed upon at one stage have been changed or
modified by individuals involved at later time periods. Consumers Povet
Company originally was involved in EEQ since 1975, with a LOCA task force,
followed with the RDS Modifications, and with the Systematic Evaluation ,
Program in the late seventies. Implementation Inspections did not commence
until 1986. We believe this contributed to the EEQ issues dealing with
MO-7068 and Polyethylene and Butyl rubber cables. Consumers Power Company
still believes that M0-7068 and the cables were capable of performing their
safety function, however, we agreed to replace the components rather than
continuing to debate the issues.
Big Rock Point continues to have an effective maintenance performance
history as evidenced by historical plant availability and number of forced
outages. Reactor trips from power have been minimal and the plant material
condition has been noted as very good by the NRC, INPO, and Insurance
Inspectors. During this SALP period Big Rock Point initiated and recently
completed a Maintenance Self-Assessment utilizing INPO guidelines.
Throughout the next SALP period we will be implementing changes in our
Maintenance Programs to improve the high priority areas identified in the
self-assessment. These will further strengthen our maintenance performance.
In addition, several major pump and motor overhauls are planned for the
upcoming refueling outage. The main feedvater pumps, turbine / generator,
and a service water pump have been completed in the recent past. Over the
next few years, two to three major pump overhauls per year are planned.
Big Rock Point will continue to monitor equipment performance and industry
maintenance practices toward enhancing existing Maintenance programs.
D. Surveillance
One inaccuracy existed in paragraph 3 of this section with regard to not
performing a surveillance test (Service Test) on the station battery. A
Technical Specification Change Request submittal dated December 22, 1986,
which is still under NRR review, modified the Service Test design time
interval to resolve errors as described in LER 86-004. Consumers Power
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Nucicar Rsgulatory Ccmmission 3
Big Rock Point Plant
SALP 7 Report Comments
January 20, 1988
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Company agreed to impleaent this proposal into testing scheduled for the
1987 Refueling Outage. The modified surveillance test was completed
satisfactorily during the outage.
E. Fire Protection
The NRC concern on lack of plant staff Appendix R understanding is related
to the duration of the review and implementation. As discussed above in
Section C, the effort extended over a long time period (approximately
1978-1986). Because of the long time interval the need existed for several
technical-level meetings with staff and consultant personnel to revice
extensive submittals to understand the safe shutdown paths for Big Rock
Point in complying with the Appendix R requirements. Although further NRR
review was needed and one additional exemption was required, overall the
post-fire safe shutdown methods met the requirements for Appendix R. Since
the inspection, documentation has been improved and fire plans strengthened
to enhance the capability of Big Rock Point to mitigate the effects of a
plant fire.
No coc=ents.
G. Security
In response to NRC concerns regarding equipment aging, the 1987 CCTV
Upgrade Project was completed by year-end. Existing equipment was repaired,
cleaned or replaced. Two additional CCTV cameras and new lights were
installed and some existing lights were repositioned. A new metal detector
and X-ray machine were purchased for installation in the Lobby of the
Security Building.
In response to NRC concerns regarding an increase in personnel errors,
several methods of monitoring personnel performance have been initiated in
an effort to identify exceptional as well as weak performance. These
methods allow trending errors and pinpointing the causes. Each First
Lieutenant on shift is now committed to evaluating his shift personnel on a
weekly basis and documenting the results on a "Personnel Evaluation Form."
They are committed to one planned and one unplanned evaluation each week.
Drills are conducted twice per month on each shift using adopted scenarios
for contingencies. Individuals with recurring performance problems are
retrained when needed and counseled or disciplined when applicable.
A new method of reviewing Logs has been established to track documentation
errors. This will ensure that proper logging is being accomplished.
A full review of all site security manuals and routine job information
sheets is being implemented to improve performance in the Security area.
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Nuc1 Gar Regulatcry Commission 4
Big Rock Point Plant
SALP 7 Report Comments
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January 20, 1988
H. Outages
No comments.
I, Quality Programs and Administrative Controls Affecting Quality
No comments.
J. Training and Qualification Effectiveness
Training and Qualification Effectiveness was evaluated as a category 2 - a
rating judged equivalent in performance to the previous assessment period
which at that time had received a category 1 rating. While we do not take
issue with the lowering of a previously assessed category, a review of the
training results completed during this SALP period leads us to conclude
training warrants a category 1 assessment.
In response to the statement "While employees received some general worker
training and on-the-job instruction, management made little progress in
upgrading the mechanical / electrical staff's skill levels, a condition noted ,
in the previous assessment period" on page 10 under maintenance summary; we
believe that maintenance training has been aggressively pursued. We have
doubled the training time per repairworker from SALP 6 to SALP 7. During
the SALP 7 period, we provided 443 student days of Mechanical / Electrical
skills training and 108 student days of Safety training. This is a signif-
icant investment of time dedicated for upgrading the skills of a maintenance
staff of 14 repairmen. All of this instruction time was dedicated to
strengthening the skills of our maintenance staff. This represents an
investment of 13% of the repairmen's time for training.
We do not concur with the statement "Skill training that was scheduled
during the assessment period was frequently cancelled because of plant
activities..." on page 22 under the training summary. Our records indicate
that there were no cancellations. There vae some rescheduling of courses,
but all courses originally scheduled were eventually completed. The
percentage of courses required to be rescheduled was relatively low at 7.6%
for the entire SALP 7 period, and was due to unforeseen plant outages.
Also, on page 22 of the training suc=ary, further clarification is in order
in response to the statement "Skill training and worker protection training
was too general, not nuclear plant specific, and did little to enhance the
effectiveness of the maintenance stafi". Skills training is not always
required to be nuclear plant specific, however during the period, 121
student days of Big Rock Point specific training was provided to the
maintenance staff. It should also be noted that all of the tasks required
of the Maintenance repairmen were addressed via classroom training,
on-the-job training, and shop practices during the SALP 7 period. During
the SALP 7 peried, a major effort was made to modify training materials to
assure that all tasks were addressed as identified on the Big Rock Point
Plant Specific Task List. It is recognized that additional systems training
is necessary for improved worker understanding and performance. At the end
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Nuclear Regulatory Commission 5
Big Rock Point Plant
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SALP 7 Report Comments
January 20, 1988
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of the SALP period the second round of systems training was started for the
least senior repairworkers at the plant.
Finally, on page 22, the statement "The Procedural requirements for both
required and on-the-job training were not met and the Maintenance Depart-
ment Training Program has not been evaluated and accredited by INP0" is
somewhat misleading. INP0 evaluation and accreditation was not planned to
occur during this SALP period. The INPO evaluation was conducted in
October 1987 and after the fourteen man team completed their evaluation
they. proposed zero recom=endations in maintenance training. INFO considered
the program to be very good and stated our program demonstrated a strong
commitment by the plant. Essentially all of the procedural requirements
for classroom and OJT were complete and in place prior to the end of the
SALP 7 period. Formal INPO Board approval is tentatively scheduled to
occur in the first quarter 1988.
We also reiterate the fact that initial or replacement license candidate ,
and requalification license candidate classes both achieved a 100% pass
rate during the SALP period. This is the sixth license class to achieve a
100% pass rate. It is a ree-r' we are very proud of and speaks for itself
s to the caliber of Big Roo 'oint training.
We believe the above results demonstrate that management commitment to
training is evident to assure that our training provides the skills and
knowledge necessary to continue to operate Big Rock Point as a safe and
reliable plant. We also believe : hat the training results completed during
the SALP 7 period supports a Category 1 assessment.
K. Licensing Activities
Consumers Power Company Management and staff will continue to support and
utilize the Integrated Living Schedule (ILS) in accordance with License
requirements to evaluate and prioritize workload. We also plan on working
with Region III personnel in the near term, on exploring ways to use the
ILS process in prioritizing inspection based plant betterments.
Consumers Power Company understands that high quality and timely licensing
documents are essential in maintaining a sound licensing basis for Big Rock
Point and continue to support this objective. Corporate and plant licensing ,
personnel will continue to advocate frequent meetings with NRR and Region
personnel to understand and prioritize issues from both a NRC and Consumers
Power Company perspective. Our goal will be to recognize unique or complex
technical issues and ensure that related submittals are timely with suf-
ficient detail to minimize interaction.
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Nuclear Regulctory Commissien 6
Big Rock Point Plant
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SALP 7 Report Comments
January 20, 1988
Consumers Power Company believes the overs 11 SALP evaluation presented a
balanced assessment of plant performance during the appraisal period. The
issue concerning resource allocation that was raised in the SALP report is one
to which we vill remain sensitive, but Consumers Power Company strongly
believes that management commitment to excellence cannot be measured by the
amount of money spent on a plant. We will continue to work closely with the
NRC staff in communicating the establishment of priorities and schedults for
action to improve plant safety and performance.
Frederick W Buckman (Signed)
Frede' tick W Buckman
Senior Vice President
Energy Supply
CC At-inistrator, Region III, NRC ,
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NRC Resident Inspector - Big Rock Point
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