ML093430794
| ML093430794 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/31/1981 |
| From: | Institute of Nuclear Power Operations (INPO) |
| To: | |
| Shared Package | |
| ML093430786 | List: |
| References | |
| NUDOCS 8112170090 | |
| Download: ML093430794 (32) | |
Text
Evaluation Report October 1981 Indian Point:
Nuclear Power Plant Power Authority of the State of New York I!iPK C78 1121-7O0 0oAO
i I
October 1981 EVALUATION OF INDIAN POINT 3 NUCLEAR POWER PLANT Power Authority of the State of New York
ODIAN POINT 3 (1981)
Page 1
SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of the Power Authority of the State of New York's (PASNY) Indian Point 3 Nuclear Power Plant during the weeks of May 4 and 11, 1981.
Indian Point 3 Nuclear Power Plant consists of one 965 megawatt (electrical) Westinghouse pressurized water reactor.
It is located on the Hudson River near
- Buchanan, New York. The unit was placed in commercial operation in August 1976.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant operating safety, to evaluate management systems and controls, and to identify areas needing improvement.
Information was assembled from discus sions, interviews, observations, and reviews of plant documents.
The team examined station organization and administration, training, operations, maintenance, radiological and chemistry activities, and on-site technical sup port. Corporate activities were not included in the scope of the evaluation.
As a basis for the evaluation, INPO used its own experience on best practices within the industry and written evaluation criteria that were furnished to the plant in advance.
The evaluation standards are high, and the findings. and recoinmen dations are not limited to minimum safety concerns.
DETERMINATION Within the scope of this evaluation, the team determined the plant is being operated safely.
The following-beneficial practices and accomplishments were noted:
o An effective radiation control program is evidenced by the low total man-rem exposure for 1980.
o Resources have been committed to effectively monitoring and controlling primary and secondary chemistry.
o The overall material condition of the plant is good.
Improvements were recommended for the following conditions:
o Overtime for pe rsonnel in a number of plant departments is high.
Additional management attention is needed this area.
o Personnel shortages exist in a number of areas.
0 INIA ININPOINT 3 (1981)
Page 2
" Management policy and procedures in, and enforce ment of, industrial safety practices need to be improved.
Instrumentation and control (I&C) facilities need improvement to better support work activities.
Specific evaluation findings and recommendations are contained in the accom panying DETAILS, and information of an administrative nature is included in the ADMINISTRATIVE APPENDIX.
These findings were presented at an exit meeting at the station on May 15, 1981.
Recommendations are intended to augment PASNY efforts to achieve the highest possible standards in its nuclear operations.
Certain findings may reflect multiple deficiencies within a parti cular area.
Therefore, in addressing these findings and recommendations, the utility should look beyond correction of the specific deficiencies and address corrective actions toward. the underlying issues.
The findings and PASNY's responses were reviewed with PASNY management on August 4, 1981.
PASNY's responses are considered to be satisfactory. To follow the timely completion of the improvements included in the responses, INPO requests written notification of status six months from the date of this report.
The evaluation team appreciates the excellent cooperation received from all levels of the PASNY organization.
E. P. Wilkinson President
W
~
DIAN POINT 3 (1981)
Page 3 POWER AUTHORITY OF THE STATE OF NEW YORK Response Summary The Power Authority of the State of New York is firmly committed to the safe, reliable operation of its nuclear power plants.
We are pleased to note that INPO's review of our operation found that that goal was being met.
INPO's recommendations form a valuable contribution to PASNY's long-term effort to achieve a higher standard of excellence in operation. As is noted in the detailed report, many of the recommended actions were recognized before the evaluation and were already receiving attention.
Nevertheless the evaluation was most helpful to focus attention and priorities.
The Power Authority agrees with INPO's determination that increased attention must be paid to the issues of the use of overtime and the filling of vacant positions in the plant organization. INPO has noted that a beneficial accomplish ment of the Authority is the construction of new facilities to accommodate work activities.
Resolution of inadequacies relative to the instrumentation and control group will be achieved when this construction is complete.
The body of the report contains detailed responses to all recommendations made by INPO. The Authority intends in its response to provide remedial action which takes the underlying issues behind the recommendation into account.
INPO will be provided with reports which document completion of the recommendation by the dates specified in our response.
INDIAN POINT 3 (1981)
Page 4 DETAILS This portion of the report includes the detailed findings. It. is composed of six sections, one for each of the major evaluation areas. Each section is headed by a summary describing the scope of the evaluation and the overall finding in that area. The summary is followed by the specific findings, recommendations, and utility responses related to each of INPO's evaluation procedures. Items relating to criteria that have not been included in INPO procedures but that are generally recognized as desirable, accepted techniques of industry and management are listed as Category II. The evaluation procedures that were used are listed in the ADMINISTRATIVE APPENDIX.
ORGANIZATION AND ADMINISTRATION The organization structure, personnel qualifications, administrative controls, programs for management objectives, quality assurance, industrial safety, and equipment surveillance were evaluated.
The plant appears to be organized and administered effectively to support continuing safe operation. However, improvements are needed in the manage ment objectives program and in industrial safety. The detailed findings in this area are described below.
OBJECTIVES (INPO Procedure QA-l0l, Revision 2)
The methods used to establish and disseminate management objectives within the plant and to track programs toward completion were examined.
Finding (Criteria A, B, C, D and E)
A plant mission statement, goals, and objectives need to be prepared and published by plant management.
Recommendation Plant management should periodically prepare and publish a mission statement that includes short-term as well as long -term goals and objectives for the plant.
Response
A plant mission statement will be distributed to all station employees by December 1981.
ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)
The administrative organization of the plant was evaluated with emphasis on organizational structure, position description utilization, performance evalua tions, and workload distribution.
- DIAN POINT 3 (1981)
Page 5 Finding (Criterion C)
Performance appraisals are not made on hourly employees.
Recommendation The performance appraisal programs should cover all personnel at the plant.
ftesponse At the present time, current bargaining unit arrangements preclude the use of annual evaluations for bargaining unit personnel.
INPO Comment 11NPO believes periodic performance appraisals are an important manage ment tool.
INPO recommends that PASNY undertake to achieve bargaining unit arrangements that permit the use of periodic perform ance appraisals.
ADMINIS3TRATIVE CONTROLS (INPO Procedure OA-103, Revision 2)
Administrative controls were evaluated to determine if there is a well-defined, organized, and effective system to accomplish administrative functions.
Finding No findings were made in this area.
QUALITY PROGRAMS (INPO Procedure OA-104, Revision 5)
Quality programs were evaluated to determine if monitoring and audit capa bilities are in place to promote efficient and safe operation of the plant.
Finding No findings were made in this area.
INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 3)
The on-site industrial safety program was evaluated to determine if it provides a safe and orderly working environment for station personnel.
0INDIAN POINT 13 (191)
Page 6
- 1.
Finding (Criterion A)
A formal management policy statement that outlines the utility's com mitment to an effective industrial safety program is needed.
Recommendation A policy statement reflecting management's commitment. to an effective industrial safety program should be prepared and distributed.
Response
A formal management policy statement for the Authority safety pro-,
gram has been finalized by the president and chief operating officer and was issued on May 19, 1981.
- 2.
Finding (Criterion D)
Safety work rules and practices have not been distributed to all plant.
em ployees.
Recommendation Industrial safety work rules and practices should be disseminated to all plant employees.
Response
The Authority's safety manual will be distributed to Indian Point 3 personnel.
- 3.
Finding (Category II)
Observation of work activities in the plant indicates that adherence to safe work practices needs more attention.
Recommendation Management action should be taken to improve enforcement of industrial safety rules and practices.
Response
The Indian Point 3 industrial accident incident rate indicates that management has a strong commitment to providing a safe work environ ment and the development of safe work practices among its employees.
Additional emphasis will be provided in these areas.
SURVEILLANCE PROGRAM (INPO Procedure OA-107, Revision 3)
The surveillance program was evaluated to determine if it accomplishes the required surveillance, inspections, and testing.
Finding No findings were made in this area.
- DIAN POINT 3 (1981)
Page7 PERSONNEL QUALIFICATIONS (INPO Procedure OA-108, Revision 2)
Personnel qualifications were evaluated with emphasis on written qualification requirements based upon job analysis for each job position, on procedures estab lished for filling jobs with qualified personnel, and on periodic review of qualification requirements.
- 1.
Finding (Criterion A)
Written qualification requirements based upon job analysis are needed for each plant staff position which can affect plant safety and relia bility.
Recommendation Qualification requirements should be developed for each such position at the plant based on authorities, responsibilities, and accountabilities assigned to the position.
Response
Written qualification requirements exist for management positions at Indian Point 3. Written qualification requirements do not exist for most bargaining unit positions; however, all persons assigned work on Category I systems meet standards developed by NRC or INPO. Written qualifi cation requirements will be developed by June 1982 for plant personnel whose work activities could affect plant safety or reliability.
- 2.
Finding (Criterion C)
Qualification requirements are not periodically reviewed and revised.
Recommendation Management should periodically review qualification requirements and keep them current.
Response
A program to periodically review qualification requirements for staff positions will be developed by January 1982.
V INDIAN POINT 3 (1981)
Page 8 TRAINING AND QUALIFICATION The team evaluated the training organization, the administration of training programs, and training resources.
Training programs for the following job classifications were also evaluated: licensed operators, non-licensed operators, shift technical advisors, mechanical and electrical maintenance personnel, and instrumentation and control technicians.
In these areas some positive features were noted, including a plant systems training course that is made available to all individuals who work at Indian Point 3, and the training department's extensive video production capability used to produce various site-specific training programs. The overall training program at Indian Point 3 shows a management commitment to training.
- However, improvements should -be made in the following-areas:
TRAINING ORGANIZATION (INPO Procedure TQ-201, Revision 0)
The team examined the on-site training organization used to develop, implement, and evaluate training activities.
Finding (Criterion B)
The training instructors need additional support to assist with the formal printing and maintenance of lesson plans and other training materials.
Recommendation A review of training staff manpower needs should be performed.
Staffing levels should be adjusted, based on the review, to provide better support for training activities.
Response
A training staff reorganization plan has been submitted as part of the 1982 budget. Staffing action will be completed by December 1982.
TRAINING AD MINISTRATION (INPO Procedure TQ-202, Revision 0)
The team examined training administrative guidance for the qualification of plant personnel.
Finding (Category II)
Instrument and -control technicians need formal initial training and retraining. Also, formal instrument and control and maintenance train ing is needed on plant modifications and on related licensee event reports (LERs) from other plants.
Recommendation Formal initial training and retraining programs should be provided for all maintenance technicians.
Also, information on maintenance-related plant modifications and lessons learned from LERs should be provided to the maintenance supervisors and technicians in a timely manner.
0ON DIAN POINT 3 (1981)
Page 9
Response
Formalized training and retraining for I&C technicians has commenced.
TRAINING RESOURCES (INPO Procedures TQ-205, Revision 0)
The team examined the training facilities, equipment, and materials available to support the presentation of quality training for nuclear plant personnel.
1'.
Finding (Criterion A)
The classroom environment is not conducive to effective instruction and learning processes.
Some classrooms are noisy, and improvements are needed in air conditioning and heating.
Recommendation Management should evaluate training needs and requirements, including classroom facilities, and provide necessary improvements.
Response
Training facilities have been significantly upgraded to provide a satisfac tory training environment.
- 2.
Finding (Criterion F)
The training facility library needs upgrading.
Recommendation A library that is readily accessible to the training group should be established and maintained. This library should include controlled copies of plant drawings, training materials, and vendor manuals used in the training effort.
Response
Work is currently underway to enlarge the scope of the training library.
LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-223, Revision 0)
The team examined the licensed operator requalification program and training practices used to maintain and improve the qualification of licensed personnel.
Finding No findings were made in this area.
W W
INDIAN POINT 3 (1981)
Page 10 SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-224, Revision 0)
The team. examined the qualification program and training practices used to qualify shift technical advisor (STA) candidates initially and to maintain and improve the qualifications of the STAs.
Finding No findings were made in this area.
NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 1)
The team examined the training program and training practices used to qualify non-licensed operator candidates initially and to maintain and improve the quali fications of existing non-licensed operators.
Finding No findings were made in this area.
LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 1)
The team examined the training program and training practices used to qualify operator and senior operator license candidates to operate the plant reliably and saf ely.
Finding.
No findings were made in this area.
- TDIAN POINT 3 (1981)
Page 11 OPERATIONS The team evaluated operations activities in the areas of organization and administration, tagout practices, conduct of shift operations, procedures, plant status controls, facilities and equipment, and shift turnover.
Team observations made throughout the evaluation period found the plant to be generally clean. It was observed that the control room is run in an efficient and businesslike manner; it was also observed that the nuclear plant operator log sheets were complete and comprehensive.
However, improvements should be made in the following areas:
OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-301, Revision 3)
The team examined the Operations Department organization and administration to determine if a well-defined and easily understood organizational structure exists, if department management has adequate authority to accomplish assigned tasks, if position descriptions are available and used for all personnel, if all instructions are issued in an effective manner, and if operating personnel are provided adequate administrative support.
Finding (Criterion B)
A finding in this area concerning position descriptions is addressed under Organization Structure, OA 102, Criterion B.
TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)
Procedures were examined to determine if they are understood and followed to provide protection to personnel and plant equipment.
Areas reviewed included senior reactor operator (SRO) approval of safety-related tagouts, double verifi cation of tagged equipment for personnel safety, double verification of impor tant manual valves that are repositioned, tag coloring and numbering.
Also, an evaluation was done to determine if a review and audit of clearance logs are periodically made.
- 1.
Finding (Criterion C)
Double verification of important safety-related manual valves, which are repositioned for maintenance or testing, is needed (with the exception of the Auxiliary Feedwater System and valves which have control room indications.)
Recommendation Administrative controls should be established that ensure independent verification of the position of important safety-related valves each time such valves are repositioned for maintenance or testing.
w INDIAN POINT 3 (1981)
Page 12
Response
A program will be implemented by April 1982 to require independent verification of safety-related valves that have been repositioned for maintenance or testing and that do not have control room indication.
- 2.
Finding (Criterion B)
Il The tagout program should provide guidance for the use of "Do Not Operate" caution tags.
Recommendation Administrative procedures should be revised to incorporate the use *of "Do Not Operate" caution tags and to provide for a periodic review and audit of these tags.
Response
A formal procedure will be developed by November 1981 for the use of caution tags.
The procedure will include appropriate requirements for audit and review of the system.
CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-303, Revision 3)
The team evaluated the conduct of shift operations to determine if operator activities-are related solely to plant operations, if control room and plant opera tions are orderly and efficient, if logkeeping is timely and accurate, if instrumentation is considered reliable, and if operators are confident of the instrument indications.
- 1.
Finding (Criterion B)
A significant amount of inappropriate material is located in the contain ment building, such as Herculite and containers of plastic booties.
Recommendation Nonessential material should be properly stored or removed from the containment building, and procedures should be established to ensure the containment building is free of such material, or the material is properly stored, prior to plant operation.
Response
Evaluation of the use of -Herculite in the containment building will be completed by March 1982. Possible remedies include better methods of securing Herculite used in the containment building and substitution of materials that would not require Herculite shielding to prevent waste generation as a result of contamination. That material determined to be nonessential will be removed.
- 2.
Finding Unique labeling or identification is needed for "out-of-tolerance" instru mentation. Instruments and annunciators that are in a degraded condi tion cannot be readily recognized by the operating personnel.
Recommendation A program should be established to identify degraded instruments and annunciators in the control room and on local panels in the plant.
- DIAN POINT 3 (1981)
Page 13
Response
A procedure will be developed and implemented by March 1982 to label or identify out-of-tolerance instruments.
USE OF PROCEDURES (INPO Procedure OP-304, Revision 2)
The team evaluated the use of procedures to determine if management policies exist for their use, if procedures are being used adequately and are clear and concise, if emergency procedures are conducive to quick and appropriate response by the operators, and if a system for revising and controlling procedures is in effect.
- 1.
Finding (Criterion D)
The immediate action steps in the Plant Emergency Procedures (PEP) contain nonessential actions to be performed by the operators, and some steps are too wordy.
In addition, a number of PEPs are unnecessarily classified as Emergency Procedures.
Recommendation Reduce the number of immediate action steps that must be memorized to those necessary to adequately control the emergency situation.
In addition, consideration should be given to a new category of procedures for those that do not need to be classified as emergency procedures.
Response
The recommended action will be completed by January 1982.
- 2.
Finding (Criterion E)
A better method for updating procedures affected by modifications is needed.
Recommendation Administrative controls should be established that ensure procedure update prior to placing a modified system in service.
Response
The recommended action will be completed by November 1981.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 2)
The plant status controls area was evaluated to determine if management approved procedures and policies exist for status controls, if equipment opera:
bility is effectively controlled, if a senior licensed individual is assigned responsibility for plant status controls, if provisions are made for special situations such as outages and post-accident recovery, and if management frequently monitors and evaluates plant status to ensure that safe and reliable conditions exist.
INDIAN POINT 3 (1981)
Page 14 Finding No findings were made in this area.
OPERATIONS FACILITIES AND EQUIPMENT (INPO-Procedure OP-3 06, Revision 2)
The team evaluated operations facilities and equipment to determine if equip-ment is accessible, if equipment availability is maximized, if plant environment contributes to efficient and safe plant operations, and if communications equip ment is adequate.
Finding (Criterion C)
A recent test of the CO2 fire extinguishing system determined that the control room atmosphere was degraded by the inleakage Of CO2 into the control room.
Recommendation A detailed study should be made to determine inleakage Of CO 2. gas.
Appropriate corrective action should then be taken.
Response
Plans are under way to install an alarm in the control room that will monitor carbon dioxide levels. In addition, an attempt will be made to locate and repair the inleakage path for the CO 2 gas.
SHIFT TURNOVER (INPO Procedure OP-307, Revision 1)
The team observed shift turnovers to determine if a continuous and correct understanding of plant conditions is maintained at all operating positions, if procedures specify the requirements for each shift position, if checklists are used in the turnover, and if associated logs and records are reviewed.
Finding No findings were made in this area.
9DIAN POINT 3 (1981)
Page 15 MAINTENANCE In this area the team evaluated the Maintenance and Instrument and Control (I&C) organizations, preventive maintenance programs,. work control systems, maintenance histories, control and calibration of test equipment, and instrumen tation and maintenance equipment and facilities. In addition, control of special processes was evaluated in the maintenance area.
The evaluation team noted that the maintenance machine shop/hot shop is one of the best shop facilities INPO has observed to date. Plant management's forward planning to facilitate plant maintenance is commendable.
MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 3)
The evaluation of this area was performed to assess how effectively the maintenance administrative programs and organization contribute to the per formance of maintenance tasks. Areas reviewed included organizational struc ture, reporting requirements and practices, staff size, training, and certain administrative programs.
Finding (Criterion B)
A finding in this area concerning position descriptions is addressed under Organization Structure, OA 102, Criterion B.
PREVENTIVE MAINTENANCE (INPO Procedure MA-402, Revision 2)
The evaluation of this area was performed to determine the effectiveness of the maintenance effort to optimize equipment reliability and performance. Preven tive maintenance (PM) programs and activities were assessed to determine if they are well defined and effectively implemented.
Areas of review were equipment included in the program, frequency of preventive maintenance, and effectiveness of program control.
- 1.
Finding (Criterion A)
The Maintenance Department needs an approved preventive maintenance procedure. A procedure has been written and is in the review cycle.
Recommendation Complete the review, approval, and implementation of the preventive maintenance procedure.
Response
The procedure will be reviewed and implemented by January 1982.
- 2.
Finding (Criterion B)
In the I&C Department, the preventive maintenance program is not clearly defined in that responsibility is not assigned by departmental procedure.
W INDIAN POINT 3 (1981)
Page 16 Recommendation Management should review present administrative and departmental procedures to ensure responsibility for the preventive maintenance program is defined and assigned.
Response
The departmental procedures will be revised to appropriately def ine assignment of responsibility for the PM program.
- 3.
Finding (Criterion E)
PASNY Procedure AP-19 requires a trend analysis and identification of equipment failures to be performed.
These activities are not always being carried out, and feedback to the department responsible for the equipment needs to be improved.
Recommendation Perform the required trend analysis and identification of failures as provided for by Procedure AP-19. Also, the procedure should be revised to provide feedback to the responsible department.
Response
The Authority is reviewing methods to mechanize trend analysis in order to improve the ability to recognize trends that would require adjustment or accelerated component replacement.
The program should be func tional by December 1982.
MAINTENANCE PROCEDURES (INPO Procedure MA-403, Revision 3)
This performance area was evaluated to assess the contribution of maintenance procedures toward the enhancement of quality and effectiveness of maintenance activities.
Procedures and manuals were examined to determine the types of activities covered, scope, level of detail, review and approval process, document control requirements, and methods of revision.
An evaluation was also made to determine the extent to which procedures are used.
Finding No findings were mnade in this area.
WORK CONTROL SYSTEM (INPO Procedure MA-404, Revision 1)
An evaluation of this area was performed to determine the effectiveness of the work control system. The system functions were checked to see if they defined and authorized work to be performed by the maintenance groups; if they provided for planning, scheduling, and control of actual work; and if they had a mechanism to put the maintenance results into an equipment history file for f uture evaluation.
1DIAN POINT 3 (1981)
Page 17 Finding No findings were made in this area.
MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 2)
The evaluation of this area was performed to assess the capability of mainte nance history records to support evaluation of equipment performance.
The review also included a check for implementation of an evaluation program contributing to improved equipment performance.
Areas reviewed included an assessment of equipment items included in maintenance history, content and accessibility of records, history review and evaluation methods, and procedures for program implementation.
Finding (Criterion A)
The Maintenance and I&C departments need written procedures or guidelines that describe the methods and responsibilities for imple menting the maintenance history programs.
Recommendation Formal maintenance history programs should be developed and imple mented for each department. The programs should specify responsibili ties, methods of administration, and provisions for review and evaluation of history information.
Response
A written procedure that describes the methods and responsibilities for implementing maintenance history programs will be developed by January 1982.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION (INPO Procedure MA-406, Revision 1)
In this area, a review was made to determine the adequacy and effectiveness of methods used for calibration and control of test equipment and instrumentation.
Specifically, methods used for identifying, calibrating, storing, issuing, trans porting, and using measuring and test equipment were examined.
Procedures establishing and governing the calibration program and existing calibration records were also reviewed.
Finding (Criterion E)
In the I&C and Maintenance departments, measuring and test equipment should be stored in a manner that precludes inadvertent use of rejected equipment.
Also, no method is currently provided for segregation of controlled and noncontrolled equipment.
w INDIAN POINT 3 (1981)
Page 18 Recommendation The I&C Department should provide for segregated storage of controlled, noncontrolled, and rejected measuring and test equipment.
Response
Maintenance and I&C departments will develop procedures by March 1982 that will delineate the requirements for segregated storage.
CONTROL OF SPECIAL PROCESSES (INPO Procedure MA-407, Revision 1)
An evaluation was performed to ensure that personnel are qualified, and procedures, equipment, and material are controlled for the performance of welding processes.
Finding No findings were made in this area.
MAINTENANCE FACILITIES AND EQUIEPMENT (INPO Procedure MA-408, Revision 1)
The evaluation of this area was performed to determine if facilities and equipment provided for the Maintenance and I&C organizations effectively contribute to the performance of required tasks.
The location, size, and condition of offices, work, and storage spaces were examined. In addition, the number, type, condition, and location of maintenance tools and equipment were reviewed.
- 1.
Finding (Criterion A)
Improvements are needed in the size and arrangement of I&C work areas and shops.
Recommendation It is recognized that management has plans for providing new facilities for the I&C Department.
An effort should be made to complete this project in a timely manner.
Response
The I&C Department will be moving into new work areas and shops that are better suited to the performance of its work.
These facilities are being built and should be completed by October 1982.
- 2.
Finding (Criterion B)
The storage areas for the I&C Department do not appear adequate for the work activities of the department. Also, an inventory control system is needed.
9DIAN POINT 3 (1981)
Page 19 Recommendation It is recognized that management has plans for providing new storage facilities for the I&C Department.
An effort should be made to complete this project in a timely manner.
An inventory control system should be developed and implemented.
Response
Storage areas will be improved and an inventory control system imple mented when the planned work facilities become available.
In the interim, new and improved temporary facilities have been provided.
1W INDIAN POINT 3 (198b)
Page 20 RADIATION PROTECTION AND CHEMISTRY Radiological protection and chemistry activities were evaluated by reviewing radiological protection training, dosimetry, internal and external radiation exposure control, radioactive waste activities, radioactive contamination control, and water chemistry control.
This evaluation was primarily an examination of plant programs and facilities as they function under normal (non outage) conditions.
A number of good practices were observed in radiological protection and chemistry. These included the effective control of personnel radiation exposures during calendar year 1980, strict standards for access to high radiation areas, and a commitment to improving cleanliness and reducing contamination levels in the radiologically controlled areas of the plant.
In addition, a great deal of emphasis on controlling air inleakage and chemistry parameters in the secondary system was noted.
The most significant area of weakness was the need for a comprehensive training program for chemistry and health physics technicians.
RADIATION PROTECTION AND-CHEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)
In this area an evaluation was performed to determine the effectiveness of the management of radiological protection and the ability of the training program to instill the knowledge and practical. abilities necessary for a high level of performance in radiological protection.
Finding (Criterion D)
The health physics technician training and retraining program needs to be expanded to include classroom instruction in plant health physics procedures.
It is understood the plant plans to implement such a program.
Recommendation Implement the planned health physics technician training program that includes specific training in plant health physics procedures.
Response
A health physics technician training and retraining plan has been prepared. -Training was completed August 21, 1981.
Retraining is an ongoing thing.
An aggressive effort is underway to hire health physics personnel.
PERSONNEL DOSIMETRY (INPO Procedure RC-503, Revision 2)
An evaluation was performed to determine the effectiveness. of the plant's dosimetry program in measuring, evaluating, and recording occupational radiation exposures.
WDIAN POINT 3 (1981)
Page 21 Finding No findings were made in this area.
RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 2)
This evaluation was performed to determine if the plant was minimizing contamination of equipment and areas in the plant.
Also reviewed was the adequacy of work practices to keep workers informed of radiological conditions in work areas.
During the evaluation it was noted the plant had an effective monitoring program for internally deposited radioactivity.
Finding No findings were made in this area.
WASTE AND DISCHARGE CONTROL (INPO Procedure RC-505, Revision 2)
An evaluation was performed to determine if an ongoing program exists to minimize the generation of radioactive waste, to reduce the likelihood of having an inadvertent release, and to detect the presence of contamination in clean systems.
1..
Finding (Category II)
Personnel involved in the packaging and shipping of radioactive waste need training in all aspects of their job. Specifically, training regarding burial site criteria, applicable regulations, and plant radioactive waste procedures is needed.
Recommendation Develop a training program that provides classroom and practical training for personnel involved in the packaging and shipping of radioac tive waste at the plant.
Response
Present practice of the Authority is to involve large numbers of people in the process of packaging and shipping radioactive waste. The practice of using a rotating pool of people will be modified with an increase of staff budgeted for 1982 to permit all required training.
Supervisory personnel involved with these practices are trained in the specific details of radioactive waste shipment, and appropriate training will be provided for other personnel involved in this process.
- 2.
Finding (Category II)
Radioactive waste storage facilities at the plant need improvement.
Specifically, 55-gallon drums and metal boxes containing low specific activity radioactive waste were stored outside on the ground in the controlled area.
INDIAN POINT 3 (1981)
Page 22 Recommendation Management action should be taken to ensure that. radioactive waste packaged for shipment is stored with proper environmental controls.
Response
PASNY concurs with the recommendation. Plans for an interim storage facility for radioactive wastes are under consideration.
RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2),
An evaluation was performed to determine if the control and calibration of radiological survey equipment were sufficient to maintain a high degree of accuracy for radiation measurements.
Finding (Category II)
The portable gamma survey instrument should be response-checked with a known radiation source daily, when in use. It is understood the plant plans to implement such a program.
Recommendation Implement the program, as presently planned, to source-check the gamma survey instrument daily, when in use.
Response
A program is planned to provide an appropriate source for checking. The source is now in place.
Administrative procedures were developed before the source was placed in service.
Procedures will be revised to include neutron instrumentation as well.
PERSONNEL HEALTH PHYSICS INDOCTRINATION, (INPO Procedure RC-507, Revision 2)
An evaluation was performed to determine if personnel entering the restricted area are informed of the risks resulting from exposure to radiation and of the means to minimize exposure. During the evaluation it was noted that visual aids are used effectively in the training process.
Finding No findings were made in this area.
PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2)
This evaluation was performed to determine if the plant was performing accurate chemistry measurements and effectively controlling chemistry para meters. During the evaluation it was noted that a comprehensive program for
&DIAN POINT 3 (1981)
Page 23 evaluating the trends of chemistry data was in use. In addition, state-of-the-art in-line instrumentation was used and effectively maintained.
Finding (Criterion C)
The chemistry technician training and retraining programs have been limited by not including classroom instruction and training in plant systems and chemistry procedures.
It is understood the plant plans to implement such a program.
Recommendation Implement the chemistry technician training program and include spe cific training in plant systems and chemistry procedures.
Response
Indian Point 3 is deficient in the number of chemistry technicians on the payroll, and an aggressive effort is underway to hire chemists.
The recommendation will be implemented as soon as this manning deficiency is alleviated.
HEALTH PHYSICS FACILITES AND EQUIPMENT (INPO Procedure, RC-509, Revision 2)
An evaluation was performed to determine if facilities and equipment contrib uted to the safe and efficient operation of the plant.
Finding No findings were made in this area.
RESPIRATORY PROTECTION1 PROGRAM (INPO Procedure RC-511, Revision 2)
An evaluation was performed to determine if a technically and administratively sound program exists for the protection of personnel from exposure to airborne radioactive materials.
Finding No findings were made in this area.
V V
INDIAN POINT 3 (198b)
Page 24 RADIATION EXPOSURE REDUCTION GOALS (INPO Procedure RC-538, Revision 0)
This evaluation was performed to determine if the plant was making a substan tial effort to minimize personnel external radiation exposure.
Finding No findings were made in this area.
£
- DIAN POINT 3 (1981)
Page 25 TECHNICAL SUPPORT An evaluation was conducted to determine the effectiveness of the on-site technical services functions. Specific items of interest included organizational structure and size, performance monitoring, record keeping, facilities, assess ment of operating experiences, coordination of plant modifications, and reactor engineering activities.
The overall performance of activities in the Technical Services Group appears to be good, but improvements can be made in several areas.
TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS-7Ol, Revision 1)
The Technical Services Group was evaluated in the areas of organization, staffing, personnel qualifications, training programs, and availability of adminis trative personnel, to perform non-technical functions.
Finding (Criterion B)
The Technical Service Group has a number of authorized positions vacant.
The undermanning situation, coupled with the workload, has resulted in a backlog of uncompleted modification requests.
Recommendation Management should take appropriate action to fill the existing vacan cies.
With the staffing at the approved level, management should periodically review staffing to determine the need for adjustments.
Response
Efforts are currently underway to fill the vacant positions in the Technical Services Group. Parallel with this effort, uncompleted modifi cation requests are being evaluated to determine which requests can be turned over to the Headquarters Office for completion.
ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)
Engineering facilities in the form of office space, use of office personnel, and availability of reference material were evaluated.
Document control and records management, communications between various on-site and off-site vendor/contractor groups, and plant performance monitoring were also evalu ated.
The efforts of the performance and reliability group in monitoring vibration of rotating equipment and condenser performance are commendable.
Finding (Criterion A)
A more comprehensive performance monitoring program is needed to ensure optimum plant thermal performance.
Recommendation A more comprehensive program should be developed and implemented for plant performance monitoring with the objective of enhancing plant
W INDIAN POINT 3 (1981)
Page 26 operating efficiency and reliability.
The program should include data analysis of appropriate monitored variables and provisions for initiating corrective action.
Response
A performance monitoring program for plant thermal efficiency was implemented in the past and deferred because of known plant, thermal deficiencies such as turbine baffling.
The program will be revised and implemented, incorporating the above recommendation by April 1982.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision 1)
The effectiveness of operating experience evaluation and follow-up was exam ined by the team.
Areas reviewed included the program for handling in-house and industry operating experiences, utilization of experienced technical person nel to review these experiences, review of program effectiveness, classification of industry operating experience, and the method for documenting disposition of operating experiences.
- 1.
Finding (Criterion F-2)
The program for reviewing in-house events does not provide for prompt notification to other utilities concerning significant events that may have generic implications.
Recommendation Administrative procedure AP-8, "Reporting of Significant Ocrees" should be revised to provide a mechanism for notifying other utilities of operating experiences that may have industrywide generic implications.
Response
The site will reevaluate procedures that 'are in effect to ensure that events of significance are reported to other utilities in the industry. The use of the NUCLEAR NOTEPAD is available to the Authority and procedures are being established for its use.
Action on these items should be completed by December 1981.
- 2.
Finding (Criterion G-2)
The disposition of operating experience information important to plant safety is not fully documented. Consequently, no means are available by which management can ensure that information is properly reviewed and classified for applicability.
Recommendation Administration Procedure AP-37, "Feedback of Operating Experience to Plant Staff," should be revised to ensure that operating experience important to plant safety is identified and logged.
C
- DIAN POINT 3 (1981)
Page 27
Response
Administrative Procedure (AP-37) will be revised by November 1981 to incorporate the above recommendation for SEE-IN products produced by INPO/NSAC and information from the nuclear steam system supplier.
PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 2)
The program for processing plant modifications was evaluated to determine if modifications are implemented in a timely manner, while maintaining the quality of plant systems.
A review o f proposed modifications, prioritization and tracking, testing and verification of installation, and completion of the modifica tion package was conducted.
- 1.
Finding (Criterion C)
The modification program should have a method for tracking-,each change through to completion.
Recommendation Provision should be made for tracking the status of a particular modification, preferably by the cognizant engineer.
Response
A program is in effect to track modifications once they reach the construction stage. This program will be revised by June 1982 to provide a method of tracking modification from initiation to completion.
- 2.
Finding (Criteria 1)
Permanent plant drawings should be updated to an "?as-.built"? status. It is recognized that a project is currently in progress to correct this condition.
Recommendation Continue the current project of updating all drawings to an "?as-.built"i status until completion.
Response
The current project will be pursued until it is completed.
ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
The reactor engineering group evaluation included the procedures for monitoring the nuclear core, computer availability, communications with on-site and off site support groups, fuel integrity, and refueling activities.
Finding No findings were made in this area.
e
',~DIAN POINT 3 (1981)
Appendix Page 1 ADMINISTRATIVE APPENDIX LISTING OF AREAS EVALUATED ORGANIZATION AND ADMINISTRATION OA-iO1 Objectives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-106 Industrial Saf ety OA-107 Surveillance Program OA-108 Personnel Qualif ications TRAINING AND QUALIFICATION TQ-201 Training Organization TQ-202 Training Administration TQ-205 Training Resources TQ-223 Licensed Operator Requalification Training TQ-224 Shift Technical Advisor Training TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training OPERATIONS OP-3 01 Operations Organization and Administration OP-302 Tagout Practices OP-303 Conduct of Shift Operations OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-307 Shift Turnover MAINTENANCE MA-40 1 Maintenance Organization and Administration MA-402 Preventive Maintenance MA-403 Maintenance Procedures MA-404 Work Control System MA-405 Maintenance History MA-406 Control and Calibration of Test Equipment and Instrumentation MA-407 Control of Special Processes MA-408 Maintenance Facilities and Equipment
ODIAN POINT 3 (1981)
Appendix Page 2 RADIATION PROTECTION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control RC-505 Waste and Discharge Control RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program RC-538 Radiation Exposure Reduction Goals TECHNICAL SUPPORT TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience Evaluation Program TS-704 Plant Modifications TS-705 On-Site Reactor Engineering
W INDIAN POINT 3 (1981)
Appendix Page 3 II.-
POWER AUTHORITY OF THE STATE OF NEW YORK PERSONNEL CONTACTED Resident Manager Superintendent of Power Quality Assurance Superintendent Security and Safety Supervisor Assistant to Resident Manager Quality Assurance Supervisor Mechanic A Senior Electrical Technician Performance and Reliability Supervisor Training Coordinator Training Specialist Senior Reactor Operator - Control Room Shift Supervisor Shift Technical Advisor Reactor Operator Operations Superintendent Instrument and Control Superintendent Instrument and Control Supervisor Maintenance Superintendent Shift Technical Advisor Assistant to Operations Superintendent (Acting)
Assistant Maintenance Superintendent Mechanical Engineer Electronic Engineer/Mechanical Supervisor Maintenance Specialist Welding Supervisor Radiation and Environmental Services Superintendent Project Chemistry Coordinator Radiological Engineer Health Physics Supervisor Radioactive Waste Supervisor Dosimetry and Reliability Engineer Contractual Dosimetry Clerk Contractual Health Physics Site Coordinator Health Physics Technician Senior Production Technician Manager, Radiological Health and Safety Shif t Superintendent Chem'.stry Technician Office Supervisor Assistant to Radiation, and Environmental Services Superintendent Reactor Analyst Assistant to Operations Superintendent Technical Services Supervisor Operating Document Coordinator Senior Resident Engineer Electrical Technical Services Engineer Mechanical Technical Services Engineer iNPO is parrraliy supported by assistance tram the Tennessee Valley Authority (TVA), a Federal agency. Under Title VI ot the Civii Rights Act ot 1964 and appicabte TVA regulations no persoln shrat, on the grounds ot race, color or nrationtal origi. be occluded tram participation inbe domied thre benetits of, or be othrerwise Subjected to discrrmination Under mhis program, It you tool you have boon excluded from particpaton in. domed tre benreftis at. or ogherrerse subjected to discrimination under this program on the grounds at race, color or natiorral orrgin. you or your represenltative.
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