IR 05000250/1987009
| ML17347A474 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/30/1987 |
| From: | Shymlock M, Stadler S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17347A473 | List: |
| References | |
| TASK-1.A.2.1, TASK-1.A.2.3, TASK-TM 50-250-87-09, 50-250-87-9, 50-251-87-09, 50-251-87-9, NUDOCS 8705190173 | |
| Download: ML17347A474 (57) | |
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UNITED STATES NUCLEAR REGIJLATORY COMMISSION
REGION II
101 MARI ETTA ST R E ET, N.IN.
ATLANTA,GEORGIA 30323 Report Nos.:
50-250/87-09 and 50-251/87-09 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-250 and 50-251 Facility Name:
Turkey Point 3 and
License Nos.:
DPR-31 and DPR-41 Inspect'ion Conducted:
February 16-21, 1987
./
I Inspector:
S.
D Stadler, Team Leader Da e
S gned Accompanying Personnel:
W. Bradford C. Casto H. 0. Christensen L. Lawyer P.
B. Moore P. Skinner T. Stetka C.
L. Vanderniet Approved by: ~~~~~ ~24Ci M. B. Shymlock, Chief Operational Programs Section Division of Reactor Safety
.3d jZ7 Date Signed SUMMARY Scope:
This special, announced inspection was performed to assess plant operations.
The licensee has received a
Category
SALP rating in plant operations for the last three consecutive Systematic Assessment of Licensee Performance (SALP) periods despite an extensive upgrade program.
The inspec-tion team was divided into four major assessment areas including maintenance, operations, plant management controls, and training.
The objective in each area was to access through observation, interviews, reviews of documentation, event followups, in-plant walk-throughs, evaluation of corrective actions taken to resolve long-standing deficiencies, the specific improvements made in the last 12 months, and to access that adequate support was being provided to plant operations by various plant groups.
Results:
No violations/deviations were identified.
8705190173 870430 PDR ADOCN 05000250 PDR
REPORT DETAILS Persons Contacted Licensee Employees
- C.
M. Wethy, Vice President
- C. J.
Baker, Plant Manager - Nuclear
"F. H. Southworth, Senior Technical Advisor
"T. A. Finn, Operations Supervisor
- J. Webb, Operations - Maintenance Coordinator
- R. A. Longtemps, Mechanical Maintenance Department Supervisor
"D. Tomasewski, Instrument and Control (IC) Department Supervisor
- J.
C. Strond, Electrical Department Supervisor
- W. Bladow, Quality Assurance (QA) Superintendent
- M. J. Crisler, Quality Control (QC) Supervisor
- R. G. Mende, Reactor Engineering Supervisor
- J. Arias, Regulation and Compliance Supervisor
- R. Hart, Regulation and Compliance Engineer
"W. C. Miller, Training Supervisor
- G. 0. Gonzalez, Information and Planning Supervisor
"W. G. Haley, Plant Supervisor Nuclear
- H. T. Young, Project Site Manager
"L. L, Thomas, Outage Manager
- J.
P. Mendieta, Services Manager Nuclear
- H. Arredondo, Purchasing Supervisor
"C.
D. Kelly, Maintenance Training Supervisor
- J. C. Balaguero, Operations Support Supervisor
- W. R. Williams Jr., Assistant Superintendent Planned Maintenance
- D. L. Osborn, Site Engineering
"K. H. Nordmeyer, Shift Technical Advisor
- D. Tseng, Senior Plant Engineer Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force members, and office personnel'RC Resident Inspectors
- K. W.
VanDyne
- J. B. MacDonald
- Attended exit interview Exit Interview The inspection scope and findings were summarized on February 21, 1987, with those persons indicated in paragraph 1 above.'he inspector described the areas inspected and discussed in detail the inspection
findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved Items are matters about which more information is required to determine whether it is acceptable or may involve a violation or deviation.
Two unresolved items were identified during this inspection which are discussed in paragraphs 6 and 8.
5.
Maintenance The major maintenance deficiencies noted during the last SALP evaluation included inadequate training, failure to follow procedures, high work order backlog, and a tendency to postpone necessary maintenance forcing operations to "operate around" problems.
A review of the licensee's maintenance program was conducted.
The following areas were inspected:
selected open plant work orders (PWOs);
the PWO backlog; the preventative maintenance program; selected plant events to determine adequate maintenance activities; the licensees performance based training program; the Nuclear Job Planning System (NJPS);
interviews with mechanics, electricians, and instrumentation and control (IKC) technicians; overtime records and plant staffing; equipment lubricant program; and the status of the maintenance improvement program.
a.
Open Plant Work Orders (PWOs)
The inspectors reviewed several work activities in progress to determine the adequacy of work procedures, procedure compliance, content of work packages, maintenance/operations interface, post maintenance testing, identification and documentation of root cause, and direct supervision of work.
The following work activities were observed and/or their PWO packages reviewed.
PWO ¹ Name Safet Classification 0838/63 Amertap Inducer Pump, Condenser Non-Nuclear Safety (NNS)
South
I-
0044/64 0843/63 5655/64 Drain Valve Intercondenser to Loop Seal Relief Valve for Auxiliary Steam Supply Line Feed Water Pump "A" Discharge Motor Operated Isolation Valve NNS Safety Related (SR)
2696/63 Coolant Charging Pump "A" SR 7497/63 7498/63 0766/63 East Overspeed Protection Controller West Overspeed Protection Controller Turbine Thrust Bearing Trip Mechanism NNS NNS NNS 2486/63 Power Operated Relief Valve SR 0762/63 5550/64 5554/64 4305/63 5646/64 5610/64 Main Turbine Governor Impeller Oil Pressure Boric Acid to Blender Heat Tracing Circuit Low Tempera-ture Reading Boric Acid Transfer Pump Heat Tracing Circuit Out of Specification Weekly Inspection and Cell Readings on Station Battery 3B Weekly Inspection and Cell Readings on Station Battery'A Turbine Control Valve Test (assist Operations and Maintenance)
NNS SR SR 5632/64 Spare Battery Discharge Test SR 4105/63 Spare Auxiliary Feedwater (AFW)
MOV Motor-Megger Motor and Lug Motor Leads SR 5482/69 Fire Protection System Alarm Points
5484/69 Troubleshoot and Adjust Trip 5 Throttle Valve on "C" AFW Pump SR 0406/63
¹3 Turbine Governor NNS These work packages were complete and the work instructions adequate, When maintenance procedures were required at the work location, they were being used and were appropriate for the work activity.
The safety-related PWOs required post maintenance testing and this testing was performed as required.
All work activities inspected were receiving direct supervision by the foreman and/or various line supervisors.
All workers were documenting root cause failures on the PWOs which is an improvement over past performance.
In the mechanical maintenance area, the post maintenance testing on balance of plant (BOP) equipment was not being conducted.
This item was brought to the attention of plant management.
The licensee subsequently informed the inspector that all maintenance crafts were instructed to commence post-maintenance testing on all equipment in November 1986.
The electrical and instrument and control sections implemented the testing at that time, however, the mechanical maintenance section did not.
In response to the NRC's concerns, the Mechanical Maintenance Department has commenced post-maintenance testing of all plant equipment, including safety-related and non-safety-related.
The following procedures were reviewed to determine if the mainte-nance program was being implemented as defined:
AP0103. 14, Computerized PWO Tracking System, revision dated January 1,
1987.
AP0190. 19, Control of Maintenance of Safety Related and guality Related Systems, revision dated January 29, 1987.
AP0190. 28, Post Maintenance Testing, revision dated December 23, 1986.
AP0190. 82, Request for Technical Assistance (RTA) - Preparation, Review, and Approval, revision dated 'November 25, 1986.
O-ADM-010, Activity Planning and Coordination Program, revision dated April 24, -1986.
O-ADM-701, Plant Work Order Preparation, revision dated July 17, 1986.
0"ADM-705, Guideline for the Analytical Based Preventive Maintenance Program, revision dated June 13, 198 b.
Nuclear Job Planning System (NJPS)
The Nuclear Job Planning System (NJPS) is a pilot program for compu-terizing and tracking PWOs from origination to closeout.
In the Mechanical Maintenance Department this system has been implemented for the generation of PWO's from origination to the job planning and PWO approval stage.
After the PWO is approved by the appropriate departments, it is printed out on a hard copy and assigned to the responsible foreman.
The foreman maintains a file and manual log for tracking the ready to work PWOs.
The NJPS-will have the capability to track PWO status and provide backlog information when the system is fully implemented.
The present computerized PWO tracking system is based on the licensee's Generating Equipment Management System (GEMS) computer.
This interim system provides a
PWO status printout and backlog information printouts.
c..
Plant Work Order Backlog The inspector reviewed the PWO status printout and selected a number of backlog PWOs to verify this current status.
These PWOs were:
PWO ¹ Name Date Issued
~Pri or it 850/69 Emergency Diesel Generator March 18, 1986 Al (EDG) ir Star t Vessel Iso 1 ati on ED-213 852/69 EDG 'B'ir Start Isolation March 18, 1986 Valve ED-204 Al 854/69 EDG 'B'ir Start Isolation March 18, 1986 Valve ED-208 Al 2263/69 Valve 1107 'A'hemical October 23, 1986 and Volume Control s System CVCS Tank B
2264/69 Valve 1108 'B'VCS Tank October 23, 1986 B
2265/69 Valve 1109 'C'VCS Tank October 23, 1986 B
2130/63 Reactor Head Vent System July ll, 1985 A1 2523/63
'A'IS Pump Casing Leak December 6,
1985 A2 These PWOs were on hold for a number of reasons, the PWOs for the EDG air start isolation valves-were awaiting parts, as was the reactor head vent system PWO.
The 'A'afety injection system (SIS)
pump casing leak PWO was awaiting technical assistance, and the chemical and volume control (CVCS) tank valves PWOs were awaiting engineering assistance.
The CVCS PWOs were progressing adequately, and were
I
awaiting the review and approval of a Controlled Plant Work Order (CPWO).
The other PWOs appeared to be in a
hold status for an inordinate amount of time The reactor head vent system PWO requested the repair or replacement of six vent valves.
The hold status indicated that four valves were in the warehouse as of February ll, 1987, and the PWO was awaiting two additional valves.
Further review by the inspector, however, indicated that at least six valves were in the warehouse and others were sent by the licensee to another utility.
The PWO was originated July ll, 1985, and 12 valves were received February 3,
1986, under a different requisition order that originated on January 16, 1985.
The required number of valves were on site for approximately one year, and the PWOs'tatus was not changed to reflect the availability of the parts.
The EDG air start isolation valve PWOs requested a Requisition and Purchasing Authorization (RPA) for 1.5-inch bronze gate valves.
The Plant Document Review Team (PDRT) sent the RPA to Site Engineering for review and approval on March 22, 1986.
The PDRT document tracking form indicated that Site Engineering still had action on the RPA.
A review by Site Engineering indicated that the RPA was missing and the status could not be determined.
The last PWO reviewed, the 3A SIS pump, required a
request for technical assistance (RTA) to solve a
pump case leakage problem.
The request was made on December 6,
1985, with a
requested completion date of February 1986.
A review of the RTA status indicated that the Technical Department was still evaluating the request at the time of this inspection, with no proposed solution to the problem.
The licensee indicated that the pump vendor was going to be called in during the upcoming outage to recommend a resolution.
The RTA, however, already contained a
recommended temporary repair that could have been implemented for the interim one-year period while a permanent solution was being pursued, thus reducing the spread of contamination around the pumps and the floor areas.
After completing the review of the selected PWO backlog status the following concerns were noted:
Administrative procedure AP0103. 14, 'omputerized PWO Tracking System, step 8.6.4, requires that a periodic review of the computerized PWO tracking system should be conducted in order to provide accurate information, and that this review should be performed by the Maintenance Planner/Coordinator on a weekly basis.
It appeared that these reviews were not thorough, and were not performed on a timely basis.
The requested assistance, (i.e.
RTAs REAs, RPAs and parts request)
did not receive the same priority as the requesting PWO.
An example, PWO 2130/63, reactor head vent system, was classified as an Al priority, equipment vital to plant safety for which work is to start within two days.
The parts were available on site for approximately one year, but no work was
begun.
Another example, PWO 2523/63, 'A'IS Pump casing leak was an A2 priority, equipment vital to plant safety for which work is to start within seven days.
The RTA was still under process by the Technical Department, even though the PWO was over one year old.
The PWOs and the requested assistance should be processed with the same urgency, or the PWO priority should be downgraded to reflect the true requirements, and extenuating circumstances documented.
In addition, requests for assistance which are on hold should be reviewed on a regular periodic schedule to determine the status.
Administrative Procedure AP0103. 14 step 5.4.3 requires that Maintenance Department GEMS Planners/Coordinator s
shall be responsible for coordinating with the Operations/Maintenance Coordinators for the purpose of planning, scheduling, and priority changes of approved PWOs.
Although the above procedure allows the maintenance planners to change PWO prioriti,es, the coordination effort is not being documented.
The Site Engineering Department appeared to have lost account-abilityy on one request, an RPA for EDG air start isolation valves.
The RPA was generated on March 22, 1986, but could not be located at the time of this inspection.
A new engineering work request system that was implemented in September 1986, should prevent such a
loss of requests and should aid in assuring more timely responses.
The requests for assistance that were in the engineering review process prior to the imple-mentation of the new system did not appear subject to these improved controls.
The licensee needs to review the status of all RPAs and REAs in process prior to September, 1986, to ensure adequate and timely response or possibly for implementation into the new program.
The inspectors reviewed the licensee's PWO backlog status, which is used as a Maintenance Department performance indicator.
The backlog target criterion is to have no more than 50 percent of these correc-tive maintenance PWOs older than three months which is based on an INPO guideline.
As of the week of February 16, 1987, the backlog for the Electrical Department was 362 PWOs, the Mechanical Department was 516 PWOs, and the ILC Department was 768 PWOs.
The Mechanical and Electrical Departments were very close to the target indicator.
The IKC Department appeared to be about 10 percent above the target.
In the past, the ILC PWO backlog was fairly large, with approximately 900 PWOs.
In response to an NRC expressed concern with this backlog, the licensee hired eighteen temporary IKC technicians to aid the permanent IKC staff in reducing the PWO backlog.
With their help the licensee reduced the backlog to approximately 400 PWOs, at which
I
time the temporary I8C technicians were terminated.
A review of the backlog trend curves for all three maintenance departments indicated that the PWO backlog had been increasing.
The licensee gave the following reasons for this increasing trend:
The number of PWOs has increased because the plant operating staff has experienced improved response from the Maintenance Department on correcting identified problems.
As a result more PWOs were being generated.
The Maintenance Department was using improved maintenance procedures, which require mo'e time to perform.
The licensee has committed to stay within the INPO guidelines in the number of outstanding maintenance work orders.
However, it is apparent that, based on past performance, more qualified maintenance personnel are required, especially in the I&C area.
This would also require more field supervisors to maintain a suitable ratio between craftsmen and supervisors.
The licensee indicated that additional personnel wi 11 be added in the near future.
d.
Plant Work Order Prioritization The licensee's PWO prioritization method was reviewed.
Procedure O-ADM-701, Plant Work Order Preparation, step 3.2.4, requires that the Nuclear Watch Engineer/Plant Supervisor Nuclear, assigns priority codes to PWOs affecting plant operations.
Step 3.3 of this procedure requires that the Maintenance Coordinator/Planners, coordinate with the Operations/Maintenance Coordinator for planning, scheduling, and priority changes of approved PWOs.
The originator's supervisor, the Nuclear Watch Engineer, or the Plant Supervisor-Nuclear assigns one of the following priority codes to PWOs:
AA-Emergency Work (an action statement has been entered)
A-Equipment Vital to Plant Safety (T.S.,
Nuclear Safety-Related, Fire Protection, Security)
and Personnel Safety.
B-Equipment Vital to Unit Availability C-Equipment Important to Unit Availability 0-Miscellaneous Plant Equipment E-Housekeeping, Material Handling, Support
The Maintenance Planner/Coordinator assigns the second digit of the priority code, which is a
number that represents the time period, within the normal planning cycle, in which work is to start.
These numbers represent:
1 - 2 days
7 days 3 14 days 4 - 30 days 0 - outside the planning cycle Additionally, the licensee has implemented an Activity Planning and Coordination Program to delineate responsibilities for the daily, weekly and long term planning and coordination of plant activities.
In this program the Operations/Maintenance Coordinator has the responsible for establishing priorities on the
"hot item list".
The "hot item list" is a daily list of tasks determined to be important to the safe and efficient operation of the unit, or of immediate regulatory concern.
The Operations/Maintenance Coordinator established the following priorities for the hot item list:
Immediate Items -
These items require resolution in less than
hours.
Short-Term Items These items require resolution in 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Long-Term Items
These are items whose significance permit more that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before resolution is required.
A review of a
hot items list and the associated computerized PWO tracking printout, noted that a specific maintenance item on the hot list may have a lower priority than some of the ready to work PWOs on the tracking printout.
The inspector expressed concern that, even though the hot items list may address some maintenance activities the Operations Department consider s high priority, the PWO priority system does not necessarily reflect the same type of prioritization.
Priority A-1 PWOs in the ready to work status, appeared, in some cases, to be bumped by lower priority PWOs on the "hot item list."
The total PWO prioritization system as currently imolemented did not appear to adequately define appropriate work prioritization.
There appeared to be a conflict between the original priorities as assigned by the author, the priority as revised by the work planners, the priority as revised by the Operations/Maintenance Coordinator and the
"hot items list."
The licensee should evaluate the current system to consider the following:
Define the actual method of work prioritization; revise existing procedures to reflect that process; evaluate all outstanding PWO's to reflect their proper priorit ~
e.
Maintenance Interviews The inspector interviewed six employees from the Electrical Maintenance Department.
Their experience ranged from six months to over six years.
The interviewees were asked questions pertaining to their opinions and their perceptions of the major changes and improvements in plant operations, particularly within the Maintenance Department.
The consensus comments were that the work packages were greatly improved; questions pertaining to work being performed were now being answered; and if a technician requested assistance or additional supervision in the field, it would be provided.
The inter-viewees all felt that the continuing training program,. which for a
time had been nonexistent, was a definite improvement.
They receive training for one week every two months.
The instructors were judged to be competent and willing to take the extra time needed to explain difficult subjects.
Direct supervision of maintenance personnel was also noted to be increased, when compared with the past.
Super-visors were now available to aid in the completion of the work activity, to approve on-the-spot procedure changes, or to interface with the Operations staff regarding work in progress.
None of those interviewed indicated that overtime had a negative impact on their level of performance.
Since there were more maintenance personnel than in the past, all overtime was now usually done on a voluntary basis.
Excessive overtime had appeared to have contributed to maintenance errors and plant events in the past.
In general, the philosophy of the Maintenance Department appears to have changed greatly over the past two years.
There is more attention paid to the assembly of adequate work packages, the specific needs of mechanics and technicians, and to maintenance training.
f.
Maintenance Training The inspector reviewed maintenance training.
Maintenance training had been discontinued for over a year to add staff support to accomplishing the. INPO accreditation effort.
Early in 1986, the maintenance training was reinstated with a
new performance-based Continuing Maintenance Training Program.
This program requires all mechanics, I8C technicians, and electricians to attend continuing training on a
regular periodic basis.
Turkey Point Training Administrative Guideline AG-008, Nuclear Maintenance Trainino and Qualification Program is the administrative guide for this training program.
Appendix "H" of this procedure delineates the curriculum for electrical maintenance personnel.
The inspector observed an introductory class for electricians, covering the plant electrical distribution system.
The instruction and related class participation appeared to be adequate.
Providing on-going performance-based training to maintenance personnel is a definite improvement, and should result in a noticeable performance improvement.
The new maintenance building, which's under construction, should further improve the training program by providing mechanical, IEC, and electrical laboratories for hands-on trainin ~
Plant Event Review A review of selected plant events was conducted to determine the adequacy of plant maintenance.
On December 27, 1986, the Unit 3 reactor was manually tripped due to a loss of plant electrical load caused by a failure in the turbine governor.
The licensee's review of the event indicated that only two things could have caused a
sudden loss of control oil pressure; either the overspeed protection controller (OPC)
solenoid valves had opened, or the auxiliary governor had operated.
The event review was conducted, by the licensee's Emergency Response Team (ERT).
The team concluded that since there was no indication that the OPC solenoid valves had operated before the event, that a blockage in the impeller orifice of the control oil pump had broken loose causing a control oil pressure increase of greater than 3 percent per second.
This rapid control oil pressure increase resulted in the auxiliary governor dumping the control oil, and the closing of the turbine governor and intercept valves and the unloading of the turbine-generator.
The licensee initiated a
PWO to inspect the control oil system, but could not locate the suspected blockage or trash or any other problems.
A plant startup was commenced on the hypothesis that the sudden clearing of the orifice was the cause of the event.
The licensee indicated that they plan to clean the control oil system by hydro-lasing all pipes during the impending refueling outage.
The licensee indicated that the hydrolasing of the control oil system piping should adequately clean the system and prevent future blockage problems.
On February 13, 1987, Unit 3 was again removed from service due to turbine governor low control oil pressure problems.
The control oil system was inspected and the governor control oil pump impeller was found worn.
The impeller was replaced.
When the turbine was being returned to service, maintenance personnel adjusting the impeller orifice backed the adjustment handle too far out, causing a
reactor trip from 10 percent power, and the loss of a large quantity of control oil.
The control oil impeller orifice was readjusted, and the unit was returned to service.
The control oil pressure was still low, approximately 24,5 psi as opposed to the normal operating pressure of 28 psi.
The turbine generator controls can become unstable when control oil pressure is significantly lower than normal.
The licensee planned to continue plant operation with this noted problem until the scheduled plant outage on January 28, 1987.
The inspectors expressed concerns that the investigation of the initial control oil failure and turbine trip by the ERT was not thorough, and may have been impeded by load generation requirements.
The licensee indicated that the ten previous events investigated by the ERT since its inception had resulted in accurate root cause identification and no repetitive failures.
To ensure the continued effectiveness of this investigative team, the licensee needs to ensure adequate management support including allowing adequate time for proper root cause analysis and corrective action Maintenance of Process and Area Radiation Monitors The inspector reviewed the licensees installed radiation monitor systems, both area and process, to determine if the calibration and maintenance program had improved.
The licensee's area radiation monitoring system (ARMS)
and process radiation monitoring system (PRMS)
were reviewed to determine the present level of attention being given them, and the condition of the equipment itself.
Problems experienced in the past in this area had included sources that were not strong enough to test the full range of responses including high level alarms, which resulted in monitors being declared inoperable.
Also, maintenance and calibration of the instrument cabinets had caused spurious alarms, trips, and isolations due to electrical spikes in the system.
The licensee has a history of excessive amounts of monitoring equipment being out of service for long periods of time, particularly ARMS.
The licensee indicated that many years of poor maintenance practices associated with the monitoring equipment, coupled with a configuration that creates too much interdependence between monitors, have rendered the system crippled, but not inoperable.
The licensee also indicated that the present level of attention being required by the PRMS and ARMS is much more than desirable, and prevents the Maintenance and Health Physics Departments from dedicating themselves toward more productive activities.
The licensee has upgraded their calibration sources, and at the time of the inspection did not have any problems with calibration of monitors except for the process monitor on the CVCS letdown line.
This monitor is located in the vicinity of a crud trap, and the background levels for this monitor are excessively high.
The licensee plans to relocate this crud trap during the next outage which should resolve this problem.
Maintenance activities on the monitors have been causing spurious alarms which have resulted in several containment and control room isolations.
The licensee explained to the -inspector that the configuration of the PRNS is such that the power supply to these monitor cabinets are connected in a series, and thus when maintenance activities are'performed in one cabinet, they are seen as electrical spike on other cabinets.
This will cause other monitors to react to the electrical spikes.
This configuration has been responsible for several alarms and isolations in the past.
In addition, past maintenance has been inadequate and the general condition of the radiation monitoring cabinets was poor.
There were numerous cases of cold solder joints and solder splatter as well as deteriorated components that have lead to a greater number of equipment failures than normally expected.
In response to these problems, the licensee is replacing all of the PRNS cabinets with a
new system.
The inspector reviewed the purchase order for the new equipment, which when coupled with improved levels of maintenance, should adequately address the past problems with the PRNS.
The licensee has committed
to Regulatory Guide 1.97, Instrumentation for Light Water Cooled Reactors to Assess Conditions During and Following an Accident, to upgrade their ARMS system in the future.
The licensees target date for this action is 1990, but considering the high numbers of ARMS continuing to be listed as inoperable, consideration should be given to expediting this schedule.
Preventive and Predictive Maintenance Programs The inspector performed a review of the licensee's recently imple-mented preventive and predictive maintenance program.
In order to implement the PM program, each department has adopted a
system wherein their procedures are classified in accordance with their purpose.
There are three different types of procedures in each of the three maintenance disciplines.
The procedures are divided into preventive maintenance (PME),
corrective maintenance (CME),
and surveillance maintenance (SME).
The
"E" suffix denotes the department, which in this example denotes electrical maintenance.
There are approximately 40 percent more maintenance procedures than there were 18 months ago.
This is primarily due to the licensee'
effort to provide an approved procedure for every task, and their implementation of an upgraded preventive maintenance program.
Past inspections noted the lack of a
PM program.
The Safety System Functional Inspection (SSFI)
on the auxiliary feedwater (AFW) system detailed the lack of preventive maintenance on the AFW system.
The inspector reviewed procedure 0-PME-075. 1, Auxiliary Feed Pump 18-Month Electrical Preventive Maintenance, approved on May 15, 1986.
The procedure appeared adequate in scope, and provided the proper references to related drawings, administrative procedures, Technical Specifications, gA records, PWO generation, independent verification, post-maintenance testing, operability verification, and vendor manuals.
Implementation of this procedure represents a significant improvement in the potential effectiveness of the licensee's PM Program.
The licensee has recently began implementing an Analytical Based Preventive Maintenance (ABPM) Program to augment their PM program.
O-ADM-705, Guideline for the Analytical Based Preventive Maintenance Program, is the procedure that establishes the guidelines for this program.
The inspector reviewed the ABPM program currently as implemented.
The program included oil analysis for pump motors and vibration analysis for pumps.
Oil samples are taken via quarterly PMs for all safety-related pumps outside containment, and for many pumps on the secondary plant. 'hese oil samples are sent to an independent laboratory for analysis of abnormal contamination that could indicate a degrading condition.
Any analysis that indicates an abnormal condition is noted on oil sample program status sheets that are provided monthly to maintenance planners.
This status sheet details the date of the sample, laboratory findings, recommendations, and actions taken or proposed.
Typical recommendations included
suggestions to examine a
pump for the adequacy of recent repairs, sampling oil at reduced intervals, closer monitoring of the pump conditions, and resample of oil immediately.
One laboratory finding indicated the following:
(per telephone January 20, 1987):
"Critical lubricant condition indicated.
Sample contains sand, pipe scale, and high water content.
have increased.
Could have reservoir corrosion and/or bearing wear."
This comment came with the recommendation to resample as soon as possible.
The oil analysis program has already shown positive results in that a
pump was replaced as a result of a negative oil analysis.
Subsequent examination by the vendor revealed that the pump had been very close to failure.
Vibration analysis was the only other part of the ABPM program to be currently implemented'he licensee utilizes a portable data input terminal to gather vibration data.
The terminal directs the user to different pumps, and then to different areas and components of a
given pump.
The terminal is programmed for different walkdowns of various areas, so that all pumps presently included under the program are tested with regularity.
In addition to the vibration data, the technician also.inputs other data from process instrumentation such as flow rate and temperature.
This additional data provides the necessary control for the data collection to reflect whether the vibration data was gathered under similar conditions to ensure that the resultant trending analysis will be accurate.
The technician returns the terminal to the ABPM office where the raw data is dumped to the ABPM computer.
ABPM personnel then perform data analysis in the form of graph generation that represents the physical data taken from each pump.
This system was expedient and economical in its use of manhours, very accurate, and should ensure regular vibration monitoring of designated equipment.
ABPM personnel provided the inspectors with several memorandums wherein maintenance supervisors were provided with a summary of vibration problems indicated by their data acquisition and subsequent processing.
This report was being generated twice a month, The licensee intends to expand the scope of their ABPM program in the near future to include pipe wall thickness monitoring, infrared scanning of breakers and electrical connections, battery voltage monitoring, and generator/exciter load and voltage testing.
The program represents a definite improvement, and should help.the licensee in identifying equipment problems prior to fai lure as well as reduce unscheduled outages.
Lubricant Control The inspector reviewed the control of lubricants utilized in safety-related equipment.
The lack of control of lubricants had been a
problem in the past with the mixing of environmentally qualified (EQ)
and non-EQ grease in safety-related valve operators, inadequate storage segregation of lubricants, and inadequate identification and control of grease guns.
Safety-related lubricants are now being controlled by an upgraded administrative procedure, O-ADM-709,
Equipment Lubrication Guide.
Unit 4 Limitorque valve operators, both safety-related and balance of plant (BOP),
had been upgraded to utilize only E(} Nebula EP-1.
This precludes the use of non-Eg grease in safety-related applications by using one grease for all valve operator applications.
The Unit 3 safety-related Limitorque valve operators have all been changed to Nebula EP-1 and the remainder of the valve operators are scheduled to be corrected during the March, 1987 refueling outage.
Storage of lubricants had
. been improved by segregating Eg and non-EQ greases and providing adequate lubricant labeling.
The control of grease guns utilized for safety-related applications had also been upgraded.
Procedure ADM-709 requires that any grease gun returned to the tool shop be clean and empty to help prevent inadvertent mixing of lubricants.
There is one grease gun in each tool room, including inside the radiation controlled area (RCA),
that is dedicated to be used for Nebula EP-1 only.
Although these controls represent a definite improvement, the inspector expressed additional concern over the control of the grease guns.
The only cleaning required for returned guns is a wipe-off of exposed surfaces, as opposed to flushing the gun and connections with a
solvent.
Also, the guns utilized with Nebula EP-1 (E(}) are not adequately labeled.
Instead of labeling the grease guns for use with EP-1 only, the labeling simply indicates
"do not use with all purpose (AP) or EP-2 grease.
Overall, however, the licensee's control of lubricants utilized for safety-related applications has improved substantially over the past year, and with the resolution of the above concerns, should be adequate.
k.
Inverters The licensee had experienced numerous and repetitive inverter trips in 1984 and 1985.
These inverter trips had resulted in several plant trips and transients.
In response to NRC concerns with this worsen-ing problem, the licensee significantly expedited the installation schedule of 12 newly designed inverter s that were in storage on site.
Installation of the new inverters was completed in September 1985, and the licensee has experienced no inverter trips since that time.
l.'ummary The licensee has made the following major improvements in the area of maintenance:
The Nuclear Job Planning System (NJPS)
improved the writing and tracking of PWOs and provided comprehensive PWO work packages.
The preventive maintenance program was upgraded and the preven-tive maintenance program, including ABPM, was implemente Maintenance personnel are documenting work in more detail utilizing procedures, and appear to be identifying the root cause of failures on a regular basis.
Post-maintenance test procedures were significantly improved over one year ago.
All Maintenance Sections were performing safety-related post-maintenance testing and the electrical and 18C sections implemented balance of plant post maintenance testing in the fall of 1986.
The number and quality of maintenance procedures have been greatly improved through the efforts of the Procedures Upgrade Group.
Establishment of the Operations/Maintenance Coordinator position has improved the communications and interface between Operations and Maintenance.
The following are areas of continuing concern in the area of maintenance:
The licensee's PWO prioritization was less than adequate with multiple priority systems that appeared to conflict.
The priority assigned to PWOs should be reflected in the procurement of parts, and in requests to the Technical Oepartment and Site Engineering for assistance.
The increasing trend in PWO backlog which had previously been reduced.
The communications and interface between Maintenance and other supporting organizations were weak.
The backlogged PWO program is not being updated to the new NJPS system, in that, the indicated PWO status is not always correct.
As a result, some PWOs are on hold for inordinate amounts of time.
Post-maintenance testing of balance of plant systems had not been implemented in the fall of 1986 by Maintenance as it was by IKC and Electrical.
The licensee committed to correct this immediately.
In conclusion, the initial implementation of the various maintenance upgrade programs and the resultant improvements in training, procedural compliance, work planning, root cause identification, Maintenance-Operations interface, and individual emphasis on quality, appears to have improved the Maintenance contribution to plant operations.
Permanent and timely corrective maintenance appears to be decreasing the tendency to
'I
perform temporary repairs, and to "operate around" problems.
Additional
, management effort needs to be applied to reducing the excessive PWO backlog, and to ensuring the proper priorities are assigned to maintenance work activities.
6.
Operations a 0 Control Room and Plant Operations Observation Operations has been identified in the past as having programmatic deficiencies in a number of areas.
Among these have been inadequate system configuration control, failure to follow procedures, excessive on-the-spot changes to procedures, inadequate control room and plant labeling, and missed surveillance testing.
The inspectors reviewed the control room status and observed shift operations for an extended period.
The control boards are in better physical condition than they were a year ago.
The boards have been relabeled with clearly readable labels and a color-coding system has been utilized to identify power supplies.
The control boards have also been re-aligned to better group similar system components.
The use of brightly colored information, clearance, and plant work order tags have improved the observability of the components effected by the tags.
There did however, appear to be a large number of PWO tags attached to the control boards and associated equipment, initially indicating the potential that excessive instrumentation was not functioning correctly.
Tags reviewed by the inspectors, however, indicated that most were related to minor deficiencies and did not appear to significantly detract from the proper discharge of operator responsibilities.
Shift turnover checklists had been recently implemented for the reactor operator (RO), senior reactor operator (SRO), shift technical advisor (STA), and non-licensed operators.
These check lists appear to have greatly improved the quality of the shift turnover.
Shift briefings had also been implemented after the shift has turned over to discuss changes that have occurred since the last shift and to discuss up-coming work for the shift.
These changes have upgraded the transfer of knowledge between the shifts and have made a definite improvement in the overall operations at the facility.
The inspectors observed the acknowledgement of alarms by operators and noted that once a flashing alarm was observed, the rest of the board was not always scanned.
This could result in the operator failing to observe simultaneous alarms.
The swing RO often acknowledged alarms for the "at the controls" operator, and on occasion failed to notify the "at the controls" operator of the alarm.
These concerns were brought to the attention of the facility management, and during the course of the inspection this concern appeared to have been adequately corrected.
The inspectors noted
that in all observed cases the operators followed procedures in an adequate manner, often double-checking steps prior to the operation of switches to insure the cor'rect action was taken.
This adherence to procedures is essential to the proper operation for the facility, and a definite improvement over previous practice.
Control room logs were found to be legible and errors properly documented.
These logs are procedurally required to be reviewed by supervisors and members of the operations staff on a regular basis, but these reviews are not documented by initialing and dating or by some other means.
This documentation would help ensure that these control room logs are reviewed regularly as required.
The RO parameter logs (rounds sheets)
appeared to be lacking in detail, and new and more detailed RO logs were in the process of being developed and scheduled to be issued soon.
The inspectors observed the control room housekeeping and determined it to be much improved considering the relatively small size of the two-unit control room.
Plant Housekeeping Primary plant housekeeping appears to have significantly improved with regular plant tours conducted by Operations Management and gA.
The secondary plant housekeeping had improved slightly, but it was still substandard.
Severe pump and valve leaks, unused hoses, standing water, and burned out lights were typical of housekeeping deficiencies noted in the secondary plant.
Past inspections conducted, including the Safety System Functional Inspection (SSFI)
on the AFW system, noted poor configuration control and material condition throughout the plant.
During this inspection, the inspectors observed increased attention to configuration control, increased independent verification of safety-related systems, an upgrade of system and instrumentation alignment sheets in the PUP procedures, upgraded labelling and color coding, and a reconstitution of design bases and system walkdowns by Operations, Engineering, and gA personnel.
The inspectors were still concerned with the continuing poor material condition of the secondary, balance of plant systems and equipment including major pump and valve leaks, and a lack of independent verification on quality related systems.
"guality related" is a
new licensee equipment classification, and
'quates to the previous designation of "important to safety."
This equipment is essential in supporting safety-related equipment, and should be.subject to the same level of attention as safety-related equipment, including configuration control and independent verifica-tion.
In overview, the configuration control and material condition of the safety-related systems has definitely improved in the past
months.
Additional emphasis is needed on the secondary plant system I
Surveillance Testing In the area of surveillances, the inspectors noted that the licensee had incorporated all surveillance, schedules'nd responsible depart-ments into a single procedure.
This comprehensive procedure details each surveillance test requirement, its schedule for completion, and the responsible plant group to perform the activity.
Indications were that no surveillance tests have been missed since the inception of the new procedure in 1986.
In addition, the Procedures Upgrade Group is performing an upgrade of all other surveillance procedures.
The inspectors were concerned that the implementation of the licensee's Standardized Technical Specifications will required addi-tional survei llances to be performed, and caution should be taken to incorporate these into applicable procedures.
Overall, the conduct of operations surveillance testing appeared to have improved substan-tially with improved procedures, scheduling, and documentation.
Shift Management The inspectors made the following observations of shift supervision.
A third SRO had been added to each shift which allows plant rounds by the shift supervisor.
The addition of a shift technician has alleviated some of the administrative burdens on the licensed staff.
Interviews indicated that the SRO's and RO's feel that excessive management emphasis is placed on continued generation versus removing the units from service for needed repairs.
Indications were that this problem may have contributed to unplanned plant transients.
The inspectors noted that during their time in the control room several individuals appeared to be putting in an excessive amount of overtime hours.
While conducting interviews with several operators the inspectors were told that there was an excessive amount of overtime being performed by operations personnel.
Inspectors reviewed the amount of hours individuals worked from time cards and noted that the operators were, in fact, working overtime in excess of the guidelines given in Administrative Procedure AP-0103.2.
One operator was observed, during the course of the inspection, working multiple shifts on the control panel that was an example of overtime above that prescribed in AP-0103.2:
The inspectors noted that AP-0103.2 allows exceeding the guidelines providing the deviation is authorized by senior facility management.
The documentation of the authorization was difficult to determine and appears to be done after the overtime has been completed.
The inspectors consider the use of the term authorization to imply authorization prior to the actual performance of the overtime not post-overtime approval.
The inspectors also reviewed Generic Letter No. 82-12 which provides licensees with clarification on the use of overtime as stated in NUREG-0737.
An attachment to that letter was the table of licensee's commitments on NUREG-0737 requirements in which the licensee is noted as being in compliance with Item I.A.1.3. 1, Limit Overtime.
This compliance included revisions to administrative procedures and changes to facility Technical Specifications.
It was not clear to the inspectors from their review that the licensee is
in full compliance in regards to NUREG-0737 requirements concerning overtime, nor that the administration of overtime is in full accordance with AP-0103.2.
Therefore, the issue of excessive overtime is identified as an unresolved item (50-250, 251/87-09-01)
pending further review by the NRC.
Communications The inspectors noted that operating communications were casual and often on a first name basis, with operators rarely using any form of a
repeat back.
Direction was often given in non-measurable terms (up a little bit) or announced over the public address system.
Informality in plant communications can result in personnel errors and plant trips and transients.
During interviews with operators, communications were noted as a primary concern of most operators.
It was indicated that radios and the page system were not capable of proper operation between all areas of the plant.
The licensee plans improvements to the radio communication system during the impending refueling outage.
A new radio system will be installed with a
repeater system to allow adequate communications throughout the plant.
The control room demeanor varied greatly between operators and shifts.
On day shift, the control room was quite busy and noisy with individuals continually entering and exiting the "at the controls" area of the control room.
Utilizing the control room as the PWO tagging center added to the apparent congestion.
A sign is posted at the entrance to the control room requiring that individuals are to request permission prior to entering the control room but did not appear to be strictly adhered to.
In several instances the inspectors observed test and engineering personnel entering the control room without requesting permission.
Also,individuals passing through the the control room often walked in front of the main control boards instead of taking one of the other available routes.
This blocks the view of the operators and allows the potential for inadvertent switch operation due to physical contact.
Due to the small physical size of this control room, the licensee should consider moving the PWO tagging center to a
remote location outside the control room.
This would reduce congestion, noise, and distrac-tions to the RO "at the controls."
In addition, control room access should be more strictly enforced and proceduralized.
On The Spot Changes to Procedures On the spot changes (OTSCs)
are utilized by the licensee to effect temporary changes to approved procedures.
In the past, the licensee has generated a large volume of OTSCs, including those necessary to
"operate around" equipment problems due to inadequate maintenance support.
The inspector reviewed the current files and found one OTSC in Volume 1 of the file and 42 OSTCs in Volume 2.
This is a signifi-cant reduction, and indicates that the licensee has adequately corrected the past overuse of the OTSC In reviewing the active OTSCs, the inspector found several OTSCs that were indicated as cleared in the index, but were still contained in the active file.
The licensee indicated that the discrepancy was a clerical problem which was subsequently corrected during the course of the inspection.
A full set of surveillance and maintenance procedures for each unit are maintained within the "at the controls" areas for the respective units.
The procedures are used as refer-ences for the operators in reviewing pending testing and the prepara-tion of clearances, as well as following in-progress testing.
If a copy of the procedure is required for the performance of a test or evolution, the operator obtains a working copy from shift clerical support.
Current working copies, including active OTSCs, are main-tained in file cabinets in an office adjacent to the control room.
When an OTSC is issued, a round orange sticker is attached to the effected procedure, and the OTSC number is written on the sticker.
The inspector reviewed several of the active OTSCs and all appeared to be in compliance with the administrative controls of the facility.
The inspector.noted however, that Operational Surveillance Procedure 3-0SP-059.4, Power Range Nuclear Instrumentation Analog Channel Operational Test, had three OTSCs effecting it, and the corresponding procedure for Unit 4 had none.
The inspector reviewed working copies of the two procedures and found that all three OTSCs were applicable to both units.
Operators indicated that OTSCs for one unit are generally reviewed by shift supe'rvi sion as to applicability to the other unit prior to the approval of the OTSC.
The current procedure governing the use of OTSCs however, does not require a review of this nature and, as in the case of 3-0SP-059.4, a procedure is not always adequately reviewed for application to the other unit prior to implementation.
The licensee should establish a
formal review process to ensure that the applicability of a specific OTSC to the other unit is reviewed, prior to implementation of that OTSC.
g.
Summary The licensee has made the following major improvements in the area of Operations:
Control board labeling, tagging, and color-coding has been upgraded.
Shift turnover practices have improved, including the implemen-tation of turnover checklists and shift briefings.
Attention to control room indications and alarms by operators has improved.
Procedural quality and adherence by operators have improved.
Control room and primary plant material condition, configuration control, and housekeeping have improve Survei 1 1 ance testing has improved, including the related procedures and the coordination between various plant groups.
The following continue to be major concerns in the area of Operations:
Inadequate configuration control, material conditions, and housekeeping in the secondary plant; shortage of personnel and excessive overtime; control room congestion and lack of consistent access control; and inadequate communications systems and informal operating communications.
In conclusion, the contribution of the Operations group to overall plant operations has improved considerably within the past year.
Initial implementation of the various upgrade programs has made noticeable improvements to control room and plant operations and the interface with other plant groups, including Maintenance, Training, and Engineering.
The tendency to generate excessive on-the-spot procedure changes to
"operate around" maintenance problems has been significantly reduced through upgrades in corrective maintenance, procedures, and management controls and support.
Additional plant management effort needs to be applied to the areas of inadequate staffing and excessive overtime, secondary plant physical condition, control room congestion, and plant communications.
7.
Plant Management Controls Previous problem areas identified in past inspection reports in the area of plant management controls were:
inadequate responses to technical issues; untimely response to QA non-conformance reports (NCRs),
inadequate QA/QC audits, lack of management controls over plant change modifications (PC/Ms) and temporary system alterations (TSAs), failure to identify the root causes of events and subsequent failure to take prompt corrective action, and overall inadequate management involvement in plant operations.
a ~
Onsite Engineering Group The licensee had inadequate corporate engineering support for site activities in the past, but the Engineering organization has been recently reorganized and a Site Engineering organization established.
The Site Engineering Manager reports to the Site Vice President.
The Site Engineering Organization presently has approximately
engineers onsite and the licensee plans to add about
more to the staff.
This organization also had approximately 96 contract
engineers onsite, however, this number should decrease as the permanent site engineering staff is increased.
To improve the Site Engineering Organization, the Site Engineering Manager has established the following goals:
Increase project accountability at the site level; Reduce the number of contractors onsite; Reduce the number of revisions of plant modification packages; Reduce the drawing update backlog; Reduce the number of non-conforming reports (NCRs)
and the number of responses outstanding against these NCRs; and, Improve the plant change and modifications (PCM) packages.
Review of the engineering report for January 1987, indicated that many requests for engineering assistance (REAs)
remained open, and that these numbers were still increasing.
There were approximately 525 REAs open, but this relatively large number appeared to be somewhat attributable to the increased confidence in Site Engineering support response by various plant groups, and to the extensive plant modifications taking place.
Indications were that safety-related
, REAs receive priority over non-safety-related REAs
~
An area of concern was that a number of REAs which were a year old or more, had not been the object of any action or review and in at least one case, the REA had been lost by Site Engineering.
The licensee has recently implemented a
program which generates a
formal package for newly received REAs.
This should prevent the loss of an REA in the future.
This program, however, did not require a review of the status of REAs generated prior to its implementation.
The licensee should review the status of all REAs written prior to the new program and prepare a similar package for each REA.
In addition, the status of all REAs should be reviewed on a regular basis to ensure adequate and timely response.
The establishment of Site Engineering and the Site Engineering Manager position appear to have significantly upgraded the engineering support of Turkey Point plant operations.
b.
Safety Engineering Group The Safety Engineering Group (SEG) is comprised of five full-time members and a Chairman.
The SEG was formed in April 1984 but did not appear to perform. an active plant function until October 1985 when they were assigned to perform system reviews as part of the licensee's Phase 1 Systems Review Program.
Following completion of this program, the SEG was assigned responsibility for the Phase
Systems Review Program.
SEG activity at the time of this inspection appeared totally involved with the followup of the findings identi-fied by this Phase 2 review.
The Phase 2 report, issued in December 1986, indicated that a
very comprehensive review of the selected plant systems was conducted by the SEG.
The ten systems identified in the NRC Confirmation of Action (COA) letter for this phase of review was expanded to 14 systems to assure coverage of all necessary support system The inspector selected one of the
systems (instrument air) to determine if the findings of the SEG were receiving adequate response from interfacing organizations.
As a
result of this review it appeared that the SEG findings were receiving good response from the interfacing organizations, and that followup action items were being resolved on a timely basis.
The present goals for the SEG include issuance of Procedure PTN-EP 5. 1 which will specify how normal SEG business is to be conducted (business is presently conducted under procedure PTN-EP 5.2 which relates to the Phase
Program only),
and to establish trending of plant errors.
Addition-ally the SEG is expediting completion of the Phase 2 program so that their normally chartered activities can be pursued.
The Phase
program is 100 percent completed except for system walkdowns which are about 70 percent complete and some necessary system modifications.
The walkdowns and modifications are scheduled to be completed by the end of the refueling of Unit 4.
The inspec-tors noted that in support of the Phase 2 review, the licensee had transferred the accountability of the SEG from the Site Vice President to the Site Engineering Manager.
While this change in the reporting chain may have been effective under Phase 2 activities, it appeared that the normal SEG activities could be more effectively accomplished if the SEG were to be transferred back to the Site Vice President.
In response to this concern, the licensee indicated that this action was being considered for implementation following completion of the Phase 2 review.
The SEG appears to have been very effective in support of Phase 2 of the systems review, and should be a definite contributor to effective plant operations once their efforts are redirected toward their normal charter of providing oversite of all plant operations and major activities.
Emergency Response Team Past NRC inspections have detailed numerous instances where the licensee failed to adequately determine root causes of events and trends, and to take adequate and timely corrective actions.
In 1984, the licensee established the Emergency Response Team (ERT)
to investigate plant events, determine root causes, and to recommend corrective actions.
To review this area the inspector interviewed ERT personnel, reviewed Procedure O-ADM-011, "Short Notice Outage Work (SNOW)
Response Organization,"
which is the controlling procedure for the ERT, and reviewed the ERT response to four recent plant events.
The ERT does not have a
permanent membership.
Individuals are selected for each team based on the type of event.
For instance, members for a specific team, might include a senior reactor operator (SRO),
an engineer, an 18C supervisor and.
one additional member of the plant staff.
The ERT has investigated a
number of events since~ being established, and has the potential to significantly improve the licensee's response to events, including
the identification of root causes and the recommendation of correc-tive actions.
Several areas of concern with the performance of the ERT were identified during the review of the ERT reports for the four selected events:
There were indications of a lack of depth in identifying the specific root causes of events possibly due to time and restart constraints.
Furthermore, the ERT has no tracking system which would allow a review of past events to identify trends.
While the ERT personnel conduct a followup on the items that are identified during their review and that require subsequent actions, there is no formal tracking system to assist in this followup.
Since there is no logging or formal record keeping process for ERT reports, tracking of followup items did not appear to be effective.
Procedure O-ADM-011, Short Notice Outage Work (SNOW)
Response
.
Organization, requires the ERT to respond within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the onset of an event.
Review of the 4 events indicates that this time period is not being met in that it took the ERT approxi-mately 2 to 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to respond to most of the events.
The procedure requirements should be met, or if not realistic, be revised to reflect the actual, response time desired.
The procedure could be upgraded to require the Plant Nuclear Safety Committee (PSNC)
review of plant trips prior to unit restart.
Indications were, however, that in most cases this PNSC review was occurring even though not required by O-ADM-011.
The licensee had established goals to improve the ERT as follows:
Change the ERT controlling procedure (0-ADM-Oll) to establish a
computerized tracking system that will track long term items, lower the threshold for the type of events to which the ERT wi 11 respond (i.e.,
respond to more events),
and involve plant upper management in plant restart decisions.
Standardize the format of the ERT reports.
While these goals will help improve the effectiveness of the ERT, there are other improvements which could also contribute:
Trending of past events so that recurring events can be identified; Logging and recording of ERT rep'orts; Ensuring that significant short-term corrective actions are completed prior to plant restar The ERT responded to 14 events within the last 12 months.
Of the long-term action items identified from these responses, eight were still open, indicating that about 70 percent of these items had already been completed.
Plant Status Meetings In the past, the interface between the licensee's Operations and Maintenance groups had been poor, resulting in problems with the prioritization of work and a lack of timely maintenance necessary for continued plant operations.
To improve this area, the licensee recently implemented a regular morning status meeting.and afternoon priority meeting.
The morning meetings are chaired by the Operations Section and are attended by every plant group except Security and the work planners.
These meetings are brief, but appeared to be a very effective method of providing daily plant status to all personnel, and allowing an interface and exchange of information and plans between plant groups.
Requiring Security and the work planners to attend might further enhance the effectiveness of those meetings.
The afternoon planning meetings are smaller than the morning status meetings, and are designed to ensure that plant personnel are aware of ongoing and planned work and the applicable priorities.
This planning meeting also appeared to be an effective method of improving the interface between plant groups and in coordinating plant work and surveillance testing.
A published
"plan of the day" would further enhance this effort by ensuring that all plant personnel are aware of planned and ongoing activities.
The licensee had also implemented refuel planning meetings in preparation for the upcoming Unit 4 refueling outage.
As the refuel period approaches, it is expected that these meetings wi 11 inci ease in frequency.
These status, planning, and outage meetings appear to be a definite improvement in work planning and the related communications, inter-face, and cooperation between various plant groups, particularly between Operations and Maintenance.
Temporary System Alterations and Plant/Change Modifications The licensee, in the past, had exhibited a lack of adequate manage-ment control over temporary systems alterations (TSAs)
and plant change/modifications (PC/Ms).
A significant number of deficiencies in this area were identified during the AFM SSFI in 1985.
The inspector interviewed personnel that have TSA responsibility, reviewed procedure O-ADM-503, Control and Use of Temporary System Alterations, and reviewed 3 completed TSA The TSAs are now controlled by a single group, the Shift Technical Advisors (STAs), resulting in an improvement in this area.
The STAs initiate, issue, and track the TSAs, thus assuring that they receive proper review and approval and that their continued use is justified.
While this control is an improvement in this area, it appears that further improvements are needed, in that Procedure 0-ADM-503 does not specify a time limit for a TSA to remain active, and as a result there are some TSAs dating back to 1984 that were still in effect.
If a system alteration is needed for an extended period of time, the alteration (or modification)
should be made a
permanent change (PC/M).
This assures that the alteration will receive the same interdisciplinary reviews (e.g.,
an engineering review)
that are required for a
PC/Ms.
The inspectors'eview of the 3 completed TSAs indicate that the instructions for implementation were very general, and appeared inadequate to support the alteration.
This deficiency was confirmed when it was noted that each of the reviewed completed TSAs subsequently required additional instructions for implementation.
These instructions were, in some cases, derived from the plant work order (PWO) that was written to install or perform the applicable TSA.
This approach appears to circumvent the review process delineated in procedure O-AOM-503, in that the full purpose of the alteration may not be adequately understood by involved personnel.
There was evidence of this lack of under standing when the inspector questioned the STA that had signature responsibility for a particular TSA, and determined that the STA could not explain the purpose of the partic-ular alteration.
To assure that an adequate review of each temporary alteration is performed, each TSA should be a complete package that does not require additional instructions to accomplish the installa-tion.
The 'inspector concluded that the control of TSAs had been substantially upgraded by the licensee, and with the addition of a time limit and adequate instructions, could be an effective TSA program.
The inspector reviewed the controlling procedure for PC/Ms, Admin-istrative Procedure AP0190. 15, Plant Changes and Modifications (PC/M), dated December 18, 1986, and two completed PC/M packages.
One of these packages, PC/M 86-005, MSIV Nitrogen Supply Addition, was completed and closed out and the other package, PC/M 83-117, Replacement of 120V Vital AC Plant Inverters, was field completed, tested, and operational, but had not been closed out.
The review of Procedure AP0190. 15, Plant Changes and Modifications, indicated an adequate procedure that contained three notable strong points; the requirement to conduct field walkdowns prior to plant acceptance of a modification, a method to control the installation of replacement parts, and provisions for a
separate Nuclear Startup and Test Department to perform the startup and testing of new or modified system.
This latter strength results because the modification process allows an independent group to test the modificatio,Review of the completed PC/M packages.
however, indicated that the strong points of the latest issue of Procedure AP 0. 190. 15 had not been fully realized due a to lack of implementation.
PC/M package 86-005 had been completed under previous revisions of AP0190. 15 which did not contain all requirements in the latest December 18, 1986, revision.
PC/M package 83-117, which was still open at the time of the inspection, was also started under previous revisions of AP0190.15.
The 83-117 package indicated that the licensee's Backfit Construction Group performs many of these modifications utilizing their own procedures.
While these construction procedures are referenced in the current issue of AP0190. 15, this referencing was apparently not contained in the previous issues of this procedure.
The inspectors determined that the post-modification walkdown discussed in AP0190.15 was not conducted for PCM 83-117.
Subsequent discussions with licensee personnel indicated that it is a
common practice for the Backfit Construction Group to perform modifications using their own procedures.
These construction procedures were not available for the inspector's review and there-fore an evaluation of the interface between procedure AP0190. 15 and the construction procedures could not be made.
Indications were, however, that the construction procedures were less restrictive.
This method of utilizing less definitive and incompatible construc-tion procedures for a plant modification appeared to indicate a lack of management control by the plant staff.
Though these construction procedures apparently receive PNSC review and,approval, the proce-dures should at least meet all minimum requirements included in the plant PC/M controlling procedure, AP0190. 15, including that a
post-modification walkdown be conducted.
In addition, controls should be established to ensure that revisions to the plant or construction PC/M procedures also be included in the corresponding procedures.
While the licensee has established an effective plant procedure to control PC/Ms, emphasis should be placed upon implementation of this procedure for all PC/Ms.
Control of the PC/M program should be consolidated into one
"complete" procedure and procedure AP0190. 15 appeared to be the appropriate vehicle for this consolidation.
The licensee's PC/M controls appeared to have been significantly upgraded in recent months and most of the identified deficiencies resolved.
Additional procedural and management controls over PC/Ms conducted by Backfit Construction could result in a
more effective control program.
Quality Assurance and Quality Control (QA/QC)
The licensee's QA/QC organization has been the subject of a major reorganization in recent months.
The QA/QC organization had previously consisted of the Plant QA/QC Section and the Backfit Construction QA/QC Section, a carry-over from the construction of the
pl ant.
The reor gani zed QA/QC Organi zati on repl aced the Backfit Construction Section with a
Performance Monitoring Section.
~ The Performance Monitoring Section provides for a significant increase in QA/QC involvement in daily plant operations.
This section is being staffed, for the most part, with qualified individuals from various plant groups including Operations and Maintenance.
Their primary charter is to monitor plant activities including operations, mainte-nance, surveillance testing, fire protection, security, etc.,
through observation and walkdowns of various systems and equipment.
If properly staffed and trained, this QA/QC Section could contribute to increased management controls, and further reduce deficiencies such as:
personnel errors; failure to follow procedures; poor configura-tion control; failure to comply with Technical Specifications; inadequate design change control; inadequate maintenance; inadequate security; and unplanned outages.
The inspectors expressed a concern that members of the new QA/QC Section appeared to be walking down systems or observing activities in which they had not received training.
This included specific systems, fire protection, radiation protection, and security.
Applicable training and qualification is paramount for effective performance monitoring.
The inspectors also noted that the QA/QC personnel had not received training on the new Turkey Point Standard Technical Specifications currently being used on a trial bases.
QA/QC personnel should be intimately familiar with these new Technical Specifications in order to monitor implementa-tion, including the adherence to applicable LCOs, action statements, and surveillance testing requirements.
This is especially true during this "trial use" period when general attitudes toward compliance are being established.
The remaining section in the reorganized QA/QC is entitled Regulatory Compliance,'ith responsibility identified for the traditional QA/QC audit function.
The frequency of the corrective action audits performed by this section has been changed from semiannual to quarterly which represents an improvement.
QA/QC has also increased the time restraints associated with NCRs to assist in expediting response and corrective actions.
A maximum of ten days is allowed for initial response to an NCR or request for corrective action.
After ten days with no response, the NCR or request for corrective action is placed on the Computer Tracking (CTRAC) System with an additional ten-day grace period.
Bevond this 20-day period, the NCRs without adequate initial response are upgraded to the attention of the Plant Manager and then to the Site Vice President, if necessary.
The inspectors reviewed the NCRs for the six months prior to this inspection and determined that none had been required to be sent to the Plant Manager during that specific period.
The inspectors noted, however, that QA/QC Compliance was not auditing or tracking several important areas, including requests for engineering assistance (REAs)
and Emergency Response Team (ERT) activities and investigations.
In addition, the QA/QC Organization was not involved in the overview and monitoring of activities and equipment associated with the secondary,
balance of plant area.
Consideration should be given by the licensee to expanding QA/QC responsibilities to cover this area, particularly in view of the poor material condition of the secondary plant at the time of the inspection.
The newly established QA/QC Performance
'onitoring Section would appear to be an excellent vehicle to utilize for this function if properly di rected and trained.
The quality control over the procurement and issuance of replacement parts has also been upgraded by the licensee.
Problems had been encountered in the past with parts and equipment requisitions, when inadequate coordination and communications between site and corporate organizations such as Maintenance, Purchasing, Stores,. and Engineer-ing, caused excessive delays in procurement.
As a result of these problems, at least one purchase order was delayed for over a year without being sent to the supplying vendor.
The licensee recently established an onsite group called the Purchase Document Review Team (PDRT) to address this problem.
Members of this team are from all groups required to process procurement requests including Engineer-ing, QA/QC, Purchasing, and Stores.
In addition, these groups have all been located in close proximity in the new administrative building to improve interface and communications and to avoid paper transfer delays.
The PORT should expedite requests for parts and equipment and eliminate the excessive delays experienced in the past.
The licensee has also improved the control over safety-related spare parts in storage on site.
Personnel responsible for cataloging these parts have been moved from corporate to the site.
In addition, the nuclear stores have been segregated from the fossi 1 stores to help ensure that non-qualified parts and equipment are not utilized in safety-related or important to quality applications.
Plant Management Interviews with plant personnel indicated that the responsiveness of plant management has improved in recent months in many areas including work requests and NCRs.
There were also indications of increased management involvement in daily plant operations, including frequent plant and cont~ol room tours and attendance at the morning plant status meetings.
Managers have also been sent to other operating facilities, including those in Japan.
in order to observe and adopt potential improvements in plant operations, maintenance, and management.
The Plant Manage~
attended extensive managerial training cour ses at a major university and has recently implemented management sensitivity training for all licensee personnel.
This training is designed to "sensitize" employees to the corporate and plant goals, including the Quality in Daily Work (QIDW) Program which establishes a clear understanding by each group of who is their
"customer."
A review of the outlines utilized for this training indicated that it should be very effective.
An important aspect of this training was that senior members of management, including the Plant Manager and Site Vice President, were available at each session to field all questions.
At the time of the inspection, approximately 500 licensee employees had already completed this training with the remainder to be completed in the near future.
In general, it appeared that management attention to plant operations and response to identified problems has definitely improved in recent months.
Two areas which require immediate increased attention, however, are licensed operator requalification training and the material condition of the secondary plant.
These areas are discussed in detail elsewhere in this report.
h.
Summary The licensee has made the following major improvements in the area of plant management controls:
Establishment of the Onsite Engineering Group and the Site Engineering Manager position.
Establishment of the Safety Engineering Group (SEG)" and the conduct of the Phase 2 systems review which included reconsti-tution of systems designs basis.
Establishment of the Emergency Response Team (ERT) to investi-gate events, identify root causes, and to make corrective action recommendations.
Implementation of daily plant status and 'planning meetings for all plant departments.
Increased management control over Temporary System Alterations (TSAs) and Plant Change/Modifications (PC/Ms).
QA/QC reorganization and replacement of Backfit Construction QA with a Performance Monitoring QA/QC Section.
Implementation of the Quality in Daily Work (QIDW) Program.
Increased management involvement in, and support of plant operations.
The following continue to be major areas of concern in the area of plant management controls:
High backlog of Requests for Engineering Assistance (REAs) and the status of REAs older than one year.
The need for the SEG to assume normal plant charter, and to transfer reportability back to the Site Vice Presiden The need to increase management support of the ERT, including assuring adequate time to identify root causes and correct significant deficiencies prior to unit restart.
The need to increase management controls over PC/Ms performed by the Backfit Construction Organization.
The need for increased training for performance monitoring QA/QC inspectors in systems, fire protection, emergency operating procedures, radiation protection, instrumentation, surveillance testing, security, etc.
Need for training QA/QC inspectors on the new standardized Technical Specifications prior to full implementation.
The poor material condition of the secondary, balance-of-plant, equipment and the need for substantive QA/QC inspections by trained and qualified personnel in this area.
The unsatisfactory results of the Licensed Operator Requalifica-tion and Requalification Upgrade Programs and the immediate need for increased management attention and controls.
In conclusion, licensee plant management controls have visibly improved over the past 12-month period.
The licensee has constructed a
new administration building allowing centralization of the various plant groups, including Operations, Maintenance, Technical Support, Site Engineering, and Quality Assurance which has fostered improved interfacing between these groups.
The Quality in Daily Work Program appeared to be contributing to the improvement by establishing Operations as the
"customer,"
where appropriate, and shifting the focus of these plant groups to a support function for Operations.
This represents a major management philosophy change and should help eliminate or reduce the past problems with a lack of Operations support from organizations such as Maintenance, Engineering, and the Technical Departments.
The Quality Assurance Group also appeared to have made significant improvements in their involvement with plant operations with increased audits and the establishment of the Performance Monitoring Section.
The licensee needs to ensure adequate training for QA/QC inspectors, and should consider QA/QC involvement in the balance-of-plant areas to help upgrade the secondary plant material condition.
In addition, immediate increased management attention should be applied to the identified deficiencies 'n licensed operator requalification training and instructor qualification.
Training Previous major deficiencies identified in the area of training have included an inadequate training staff, a lack of continuing training for maintenance personnel, an unsatisfactory Licensed Operator Requalification Program, General Employee Training (GET) training deficiencies, program-matic deficiencies in the Required Reading and Operational Experience Feedback Programs, and Emergency Operating Procedure (EOP)
training deficiencies, In addition, an internal audit conducted by the licensee in 1986 identified approximately 165 specific training deficiencies.
'a ~
Training Staff An inadequate number of instructors and training staff have had a
significant negative impact on training, testing, and documentation in the past.
The training programs most affected by this lack of adequate training staff have included Maintenance, Licensed Operator Requalification, and GET.
The continuing maintenance training was discontinued for over a year to allow the small training staff to support the INPO accrediation effort.
Licensed operator requalifica-tion was staffed by a "skeleton" staff responsible for development, instruction, testing, scheduling, and documentation.
Based on their poor performance on an NRC requalification examination in 1986, the licensee's Requalification Program was determined to be unsatisfac-tory.
Numerous deficiencies were also identified in the testing and documentation associated with GET training, and those deficiencies appeared somewhat attributable to inadequate training staff.
The licensee was in the process of increasing the use of the training staff, which had increased from 35 in April 1986, to 58 at the time of this ins'pection.
Three program supervisor positions have been established which report directly to the Training Superintendent.
The program supervisor positions for Operations and Maintenance Training were filled with incumbents from the in-plant organization, thus increasing the experience levels within the Training Department management.
These instructors have been assigned to the Hot License (replacement)
Training Program, but two of the three were non-licensed.
The two non-licensed instructors were expected to be placed in the Group XI License Training Group.
During the interim period, however, this provides only one SRO licensed instructor to conduct hot license training.
A simulator training staff had also been assembled in preparation for site-specific simulator delivery.
This simulator staff consisted of a Simulator Engineer Coordinator, who is a contract individual, four support specialists, and one instructor with another instructor slot left to fill. The only instructor assigned at the time of the inspection was a supervisor who had been unsuccessful on the recent
NRC requal ification examination.
This simulator staff does not appear adequate to support curriculum development for simulator delivery this year, or to provide simulator instruction for hot license and license requalification training.
While the overall numbers of training staff have been increased, the licensee was critically short of qualified instructors for Licensed Operator Requalification Training.
Two of the three instructors assigned to requalification training were SRO licensed, but had recently failed NRC requalification examinations.
Several other instructors who had failed NRC requalification programs were perma-nently reassigned to other duties.
The utilization of instructors who have failed requalification examinations to prepare licensed operators for the same type of examination jeop'ardizes the effec-tiveness of the Upgrade Requalification Program and undermines student confidence.
In addition, the third instructor assigned to Upgrade Requalification Training was non-licensed and ineligible to teach systems or integrated plant response in accordance with NUREG 0737 Items I.A.2. 1 and I.A.2.3.
This instructor was also scheduled to participate in License Group XI.
As an interim solution to the instructor shortage, the licensee was utilizing contract instructors in the Upgrade/
Accelerated Licensed Operator Requalification Program.
While these contract instructors provide added depth in generic instruction areas such as reactor theory and thermodynamics, they were lacking in plant specific knowledge.
Administrative Guideline AG-009, Contractor Supplied Training provides for the certification of contract instructors to teach various individual courses such as reactor theory, thermodynamics, and systems.
Instructors who have been certified to teach only reactor theory and thermodynamics, have been utilized to teach systems.
Utilizing contract instructors to teach systems and integrated plant response without site-specific knowledge or training is a poor practice.
Ouring the audit of an Operations Training class, when a contract instructor was asked by a participant a plant specific question on the nuclear instrumentation system, the instructor was unsure of the plant system response.
He provided only a generic system response for the question and did not offer to provide plant specific feedback to the class at a later time. It is clear, as highlighted above, that contr act personnel need to receive plant specific training prior to conducting a particular system integrated plant response course.
This does not appear to meet the intent of NUREG 0737 Items I.A.2.1 and I.A.2',
and could lead to the providing of misinformation to students and a resultant loss of confidence in instructors and the training program in genera Upgrade Requalification Training The Licensed Operator Requalification Training Program had previously been determined unsatisfactory based upon requalification examina-tions administered by the NRC.
Despite continuing accelerated requalification training, the pass rate on subsequent NRC requalifi-cation examinations continues to decline.
The latest examination, December 15, 1986, resulted in only a
38 percent pass rate.
A high percentage of the fai lures were SRO licensed instructors.
Examination success rates for accelerated requalification programs at several other facilities have generally been much higher, ranging between
and 100 percent.
Contributing factors to this lack of performance appeared to be the shortage of qualified instructors and instructor working excessive overtime, the utilization of upgrade requalification participants for in-plant overtime, and an apparent inadequate evaluation and identification of the specific knowledge ar'eas requiring upgrade training.
While these factors appear to have contributed to the lack of success, it is essential that the licensee perform an in-depth evaluation of the program deficiencies and the licensed operator requalification training requirements to identify the major contributing causes to the lack of success.
The Accelerated Requalification Training Program, as well as the permanent Licensed Operator Requalification Program, should be upgraded promptly to maintain operator proficiency, and to ensure adequate licensed staff to safely support two unit operations without reliance on excessive overtime.
The shortage of qualified SRO licensed or certified instructors, the utilization of non-qualified instructors to teach systems and integrated plant response, and the poor performance results in the Upgrade Accelerated Requalification Training Program is identified as an unresolved item (250, 251/87-09-02)
pending review of the licensee's proposed correc-tive actions.
General Employee Training (GET)
There have been instances in the past of grading deficiencies in the GET program, including delays in remediation and question duplication during retest.
Administrative Guideline AG-12 has been revised to provide a format and basis for implementing a systematic method for administering, controlling and providing remediation and security for examinations.
AG-12 had been implemented as of January 13, 1987.
A method of tracking grading errors was included, and this system indicated a significant reduction in instructor error rate.
In addition, the remediation flowpath provided for by the administra-tive guideline should ensure prompt upgrading of personnel after failure of an administered examination.
A review of selected student records indicated the staff had implemented this flowpath which has improved the timeliness of student remediation.
A process to ensure
the integrity of remedial examination, i.e., limit question duplica-tion, was also in-place.
These changes in grading techniques for GET training should preclude future difficulties in this area.
Operational Experience, Feedback Training and Required Reading Program Operational Experience Feedback and Required Reading Programs had experienced programmatic breakdowns in the past.-
Operator Experience Feedback Training control has been improved due to management attention to documentation and timely disposition of information.
A review of recent applicable LERs and licensee ERT event reports indicated that this information was being provided to operators and other plant personnel as required by NUREG 0737 Item I.C.5.
The large number of procedure revisions being generated by the PUP, including minor administrative changes, had virtually inundated the operators with volume, and seriously impeded the effectiveness of required reading.
In response to NRC concerns, the Requi~ed Reading Program had been recently revised to provide the operators with a
synopsis of significant procedural changes vice a detailed review of all procedure changes.
A review of the first "reduced volume" required reading package indicated that the synopsis effectively highlights important-changes that the operators should be familiar with.
However, a backlog of required reading packages (13 volumes)
was still in the control,room; it is improbable that all of these
'existing packages could be reviewed in a
reasonable amount of time without placing an undue burden on the operating staff.
The integrity of the process is much improved, however, it is imperative that the Training Department assess to what extent this backlog of material should be placed into the improved program and re-presented to Operations personnel.
Requalification Training Attendance and Training Briefs It has been identified in the past that attendance of requalification training courses by licensed staff personnel had been minimal, and had impacted proficiency.
Licensed operator requalification training attendance for cycle IV was reviewed.
Attendance by all licensed personnel has improved over the past requalification cycle, and licensed staff attendance has improved significantly.
A marked improvement in examination results and individual proficiency should
'e experienced as licensed staff personnel continue to.regularly attend scheduled requalification lectures.
The training briefs generated by the Training Department appeared to provide a
good vehicle for providing Operations personnel with an interim measure of training on a variety of subjects such as plant modifications, newly installed equipment, and plant events.
The training briefs are created in a
professional format which is conducive to comprehension by the reader.
A tracking process exists which ensures all Operations personnel read the material, and ensures
instructors subsequently incorporate them into permanent lesson plans.
A review of the tracking records indicates several instruc-tors have continually failed to acknowledge inclusion of the training briefs into permanent lesson material within the procedurally allowed time frame.
Failure to incorporate the information cont'ained in the training brief into permanent lesson material could result in serious deficiencies in operator training and retraining.
Although the tracking system allows the instructor 60 days to provide acknowledge-ment of inclusion into permanent training materials, there was no formal followup method in place to ensure that the requirement was met.
Numerous items reviewed exceeded this 60-day restriction and management attention should be directed to this area.
Instructor Development and Certification The licensee has developed a four phase, performance-based Instructor Development and Certification Project (IDCP).
A job analysis was conducted for the instructor career path, and the data accumulated was used to develop the program from the instructor level through the managerial level.
In addition to the general IDCP program, development has been implemented for a
special performance based program for simulator instructors.
Existing job analysis, conducted and verified by another utility, is being utilized in this development.
For Technical Instructors:
Phase I:
Phase II:
Phase III:
Phase IV:
OJT Instructor Training Program Development Skills Training Instructional Skills Training Nanagerial Skills Training On-job-training (OJT)
instructor training has been developed; approximately 50 percent of the targeted licensee OJT instructors have been trained, and the training program is undergoing formal evaluation.
Level I training entai ls
contact hours, and an additional four hours to complete performance evaluation requirements before an incumbent is certified.
The remaining instructors are scheduled to complete Level I training and certification requirements during 1987.
Development of Level III and Level IV training will commence in 1988, with all incumbents scheduled to achieve certifica-tion by mid-1989.
For Technical/Simulator Instructors:
The above, plus:
Phase I - Evaluation Techniques Phase 2 - Instructional Techniques Phase 3 - Training Development
The Simulator Instructor Training Program Phase
has been imple-mented for all currently licensed operations instructors.
Phase
is currently under development with completion date targeted for mid-1989.
Presently, as incumbents complete training courses, credit is used toward the completion of the current initial and requalifica-tion requirements.
It is expected that in 1989 the new Instructor Certification Program will completely replace the current program, with all personnel scheduled to complete the performance-based training programs'equirements.
The current Nuclear Training Manual outlines the requirements for instructors.
Position descriptions specify education,. training and work experience requirements for each position.
Administrative Guideline AG-001, outlines instructor development, including initial and requalification training.
Continued qualification requires that an instructor must participate in several upgrade programs, e.g.,
Instructor Requalification Program, Technical Skills Courses, and in-plant activities.
Classroom presentation skills initial qualification requires participation in an appropriate instructor training course that will emphasize instructional presentation skills and techniques.
Instructor qualifications are maintained by participation in a presentation skills course on a biennial basis.
Instructors also must attend an appropriate systematic approach to training (SAT)/instructional systems design (ISD)
course.
The current Instructor Certification Program, however, allows broad discretion by the Training Superintendent in waiving specific minimum requirements by performing a review of a new or contract instructor's resume'.
As evidenced previously in this report, the use of non-licensed instructors who have not attended a
licensed operator training program or received site specific training, is an example of misuse of this flexibility. Administrative Guideline AG-001 requires that instructors who teach in the Accelerated Requalification Program attend license training.
This requirement may be satisfied in accordance with AG-001 by several alternate methods which do not provide for successful completion of an NRC SRO examination.
These alternate methods of instructor qualification do not meet the requirements of NUREG 0737, Items I.A.2. 1 and I.A.2.3, for'he qualification of instructors who teach systems, integrated response, or simulator training to licensed operators.
An audit of the records for the current instructor Certi-fication Program was attempted, but the existing records were disorganized and incomplete.
Instructors are not documenting, in all cases, the amount of time spent training in-plant, and lesson plans used for instructional skills training are not kept on file. It appears, from review of the records which do exist, that the instructors have completed the majority of the requirements of Administrative Guideline AG 001.
While the licensee has conducted an instructor job task analysis to be used in their new IDCP, the existing program and its documentation lacked adequate management attentio Licensee Training Audit The inspectors reviewed an internal licensee audit that described approximately 165 training deficiencies.
A tracking system was in place for monitoring the close-out of action items associated with identified training deficiencies.
The completion of this activity is instrumental in the success of the Training Department's QIP/QIDW programs.
By November 15, 1986, nine items which were classified regulatory in nature had been closed out, and by January 15, 1987, 35 additional items have been closed.
Of the items contained in the training audit, projected closeout for approximately
items was scheduled for Febru'ary 1,
1987, however, the Training Department has exceeded that goal and has closed out 95 items.
Completion of the training audit action items is progressing ahead of the projected schedule.
Management appeared sensitive to the improvement oppor-tunity offered by the completion of this program.
Emergency Operating Procedures Licensed operator
'
ability to use revi sed attachments contained within the emergency operating procedures (EOPs)
has been an area of concern in the past.
Training in the use of attachments had subsequently been conducted and documented for all licensed operators.
As a
means of evaluation, an in-plant walkthrough of Attachment C of ECA-O.O,
"Loss of AC Power,"
was conducted by the inspector.
with a shift supervisor'.
A simulated operation was performed involving the use of the cranking diesels for a loss of all AC power.
The shift supervisor satisfactorily completed the evolution and no major training deficiencies were observed.
The procedure did not list loading limitations for the cranking diesels and the shift supervisor did not appear familiar with the applicable limits.
An audit of lesson plans for emergency diesel generator procedures indicated that the cranking,diesel loading limits were covered in accelerated requalification as an objective.
These limits should also be contained within the EOP attachment to relieve the operator from the burden of memorization, and to ensure that the cranking diesels are not inadvertently overloaded during loss of all AC conditions.
Information has been provided to utilities through LERs, IKE Information Notices, and INPO SOERs regarding the potential for a partial or complete loss of DC power and the need for procedures and training to support this contingency. 'he licensee has not provided procedures for a loss of DC power which is an unresolved item (250, 251/86-18-13).
The establishment of this procedure is contingent upon the completion of a
request for engineering assistance (REA).
Detailed operator training cannot be conducted for a loss of DC until the REA is completed and the procedure written which is scheduled for September 1987.
As an interim measure, the Training Department developed a job performance measure (JPM).
This JPM simply verifies that the operator can successfully restore a
battery charger to the DC bus.
It does not prepare the operator to respond to the loss of the DC bus or related equipment such as pumps, valves, and instrumentation, During this inspection, not all Operations personnel had been evaluated by the loss of DC JPM.
Operations management committed to complete the JPM evaluations by February 27, 1987.
The licensee also needs to expedite the requested engineering review for the establishment of the loss of DC procedure, and completion of the related operator training.
Additional Training Improvement Areas These additional long-term programs were in the early stages of implementation, but should provide a positive impact on the quality of training for the licensee.
These programs include the following:
(1)
Training Assurance Program (TAPS)
(2)
Training Information Management System (TRIMS)
(3)
INPO Accreditation Effort The TAPS program is charged with moving the Nuclear Training System from a reactive to a proactive mode of operation.
The process involves four distinct phases which are implemented and evaluated to provide for a proactive management system.
The Phases are:
Phase I:
Phase II:
Phase III:
Phase IV:
Training Assessment Training Review Group Training Effectiveness Measurement Communication - Interaction Model Phase I was previously discussed as the 165 item internal training assessment.
Phase II has been implemented and Phase III is in development.
It appears to be somewhat parallel to the QIDW program and its development.
The TRIMS program involves a method to identify tracking needs by the review of change indicators, and to track both internal and external change indicators documenting the use of the systematic approach to training (SAT) process.
As of January 1987, 1,229 items of instructional materials had been entered into the system.
This data base allows efficient use of available data for training courses, e.g.,
Licensee Event Reports (LERs), Significant Operating Event Reports (SOERs),
and Operating Event Reports (OERs)
student feedback.
In the. area of INPO accreditation, the Training Department submitted Self Evaluation Reports (SERs) for three programs, Licensed Operator Training, Non-Licensed Operator Training, and Health Physics Training in June 1986.
The remaining six programs were submitted in November 1986, for accreditation.
Currently, there is one INPO recommendation remaining as an open item, one 'evaluation finding (records of industry events),
and one simulator evaluation finding which were projected to be closed about March 198.
Summary The licensee has made the following major improvements in the area of training; The implementation of a performance-based Maintenance Training Program.
INPO accreditation of four of ten training programs.
Increase in training staff manpower from 32 to 58.
A new training facility.
A site specific simulator is on order.
Improved procedural controls over testing and grading.
Improved GET training and video tape presentation.
Training Assurance Program (TAPS).
Training Material Configuration Control System (TMCCS).
Areas of continued concern in the area of training include:
Unsatisfactory Licensed Operator Requalification Program and apparent lack of success of Upgrade Requalification Program.
High SRO licensed instructor failure rate on NRC-administered requalification examinations'nadequate number of qualified Licensed Operator Requalification Program instructors.
Utilization of instructors who have failed NRC-admini stered examinations.
Use of uncertified contract instructors to teach systems and integrated plant response, and lack of site-specific training for contract instructors.
Less than adequate current instructor development program and related documentation'acklog of required reading.
In-plant overtime for operators attending the requalification program and excessive overtime for instructor staff.
Lack of loss of OC power procedure and related operator trainin In conclusion, The licensee has made limited improvements in the area of training through increases in management controls, implementation of performance based continuing training for maintenance personnel, and preparation for INPO accreditation.
The licensee management has not, however, provided adequate attention to, and control over, the Licensed Operator Requalification Program.
A number of deficiencies including an under sized training staff, less than proficient instructors, and lack of attendance by licensed staff personnel, contributed to the original program being declared unsatisfactory due to poor performance on an NRC requalification examination.
The resultant Accelerated Requalification Program also appears to have received inadequate management attention and control, and the success rate has been very low when compared with similar upgrade programs at other utilities.
Problems which appear to have contributed to this poor performance include an inadequate training staff, the use of non-qualified instructors, and excessive overtime by operators in a training status.
The quality and/or content of the Accelerated Training Program may also be deficient, but this could not be established during this inspection.
Adequate licensed operator requalification training is absolutely essential to ensure continued operator proficiency and safe operation of the facility under all conditions, and this area should be the subject of immediate licensee management attention.
~
'eneral Summary After over two years of program development under the Performance Enhancement Program (PEP),
the licensee appeared to have finally begun to effectively implement a number of these programs within recent months.
Definite improvements were observed in areas such as the control, scheduling, and documentation of maintenance, shift and control room operations, procedure quality and compliance, system configuration and design control, maintenance and GET training, QA/QC, effectiveness of event investigation and root cause identification, and onsite engineering support.
The Quality in Daily Work (QIDW) Program, in particular, appears to have excellent potential as evidenced by an increased level of support for plant Operations by other plant groups including Maintenance, Engineer-ing, QA/QC, Administration, and plant management.
The lack of support for operations by other plant groups, particularly Maintenance, had been a major contributor to past problems and was a key deficiency in the SALP 3 rating. It is important to note that these improvements observed, although substantial in magnitude compared with past Turkey Point perfor-mance, are in many cases just bringing the areas to an "average" level in comparison with other facilities.
Continued resources and management attention need to be devoted to these areas to ensure that the full potential of the various improvement programs is recognized.
In several areas where new programs appeared to be providing adequate controls, such as the processing of PWOs, PC/Ms and REAs, the licensee needs to review the status of activities that were being performed prior to implementation of these programs.
This should assure that controls and changes contained in the new programs are consistently applied to all applicable plant
activities.
Areas still considered to be essentially unimproved and in need of immediate upper level management attention inc'lude the Licensed Operator Requalification Program and inadequate training staff, the shortage of qualified plant personnel and excessive overtime, and the poor material condition of the secondary plan I.r g,l'f