ML17258A375

Evaluation of Robert E Ginna Nuclear Power Plant.

ML17258A375
Person / Time
Site:	Haddam Neck, Ginna  File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/31/1981
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
To:
Shared Package
ML093430786	List: ML093430793 ML093430794 ML100321543 ML100321545 ML17258A375
References
NUDOCS 8112170008
Download: ML17258A375 (79)

Text

Evaluation Report August, 1981 Robert E. Ginna Nuclear Power Plant Rochester Gas 8 Electric Corporation

EVALUATION of ROBERT E. GINNA NUCLEAR POWER PLANT Rochester Gas and Electric Corporation August 1981

GINNA (1980)

Page 1

SUMMARY

PURPOSE AND SCOPE During the weeks of September 8 and 15, 1980, an Institute of Nuclear Power Operations (INPO) evaluation team visited Rochester Gas and Electric Corporation's (RGRE) Robert E. Ginna Nuclear Power Plant at Ontario, New York, to conduct an overall evaluation of site activities.

The evaluation was based on preliminary INPO criteria, and information was assembled from discussions, interviews, observations, and reviews of policies and instructions. Corporate activities were not included in the scope of this evaluation.

The team examined station organization and administration, training, operations, maintenance and on-site technical support. Performance evaluation was based on objectives of overall excellence and not minimum acceptable standards; in this regard, report recommendations are based upon evaluation of optimum performance standards addressed in the scope of the evaluation, and are not necessarily limited to safety concerns.

GINNA (1980)

Page 2 ',

DETERMINATION Within the scope of this evaluation, the team determined that the plant is being operated safely. Evaluations were performed in thirty-nine areas.

The Robert E. Ginna Nuclear Power Plant met most of the criteria in these areas; the foQowing were identified as excellent practices that reflect favorably on station management.

A partial full-size steam generator mock-up with considerable detail and a full-scale mock-up of a reactor coolant pump are utilized in training of maintenance personnel.

A formalized method has been developed to provide a weekly identification and Plant Operating Review Committee review to resolve continual unwarranted Control Room alarms.

A procedural structure and format are used for instrument c'alibrations that provide flexibility while maintaining a high level of quality.

A significant active management support exists for the ALARA program.

The team noted that the station has had an excellent industrial safety record for the past five years, and has experienced a very low employee turnover rate.

Opportunities for improvement were identified in the following areas:

1. The existing overall training program tends to be minimal regard-ing scope, resources and facilities.

2. The on-site technical support group is not provided significant functional responsibility and resources to perform a more mean-ingful role in engineering items affecting the station.

OGINNA (1980)

Page 3

3. Some drawings on the non-nuclear portion of the plant do not provide current accurate information.

4. There is a tendency in some cases to weaken the effectiveness of management control systems by avoiding formalizing such sys-tems.

RGdrE management review of this report should consider possible generic significance of findings and recommendations. Improvements instituted should address broad functional application as well as specific item correction. Recommendations are intended to assist RGRE management's efforts to achieve the highest standards possible in its nuclear operations.

Specific findings are in the accompanying DETAILS, and administrative information is in the ADMINISTRATIVEAPPENDIX. Initial findings were discussed with RGRE personnel during the evaluation, and again in summary form at an exit meeting at the station on September 18, 1980.

Further discussion of RGRE responses was conducted at the RGRE corporate office on March 4, 1981.

RGdcE responses to our Findings and Recommendations have been care-fully reviewed and are considered appropriate.

To follow the timely completion of these responses INPO requests written notification from corporate management upon achievement of improve-ments at key target dates RGdcE has established.

The evaluation staff appreciates the excellent cooperation received from all levels of the Rochester Gas and Electric Corporation.

E. P. WILKINSON President

GINNA (1980)

Page 4 ROCHESTER GAS AND ELECTRIC CORPORATION Response Summary RGdcE agrees with INPO's evaluation that the Robert E. Ginna Nuclear Power Plant is being operated safely. The company is committed to improving its operating record and will strive to meet INPO recommendations toward excellence of operations.

The general areas of improvement are as follows:

1) The existing training programs will be expanded and formalized in terms of scope, resources and facilities.

2) The technical support group functional responsibilities have been expanded; therefore, they should perform a more meaningful role in engineering items affecting the station.

3) A drawing update program is being evaluated to bring all plant drawings up-to-date.

4) Where it is necessary, formal procedures are being written to improve the effectiveness of the management control system.

RGRE will review the INPO findings for possible generic significance.

Specific implementation dates have been set for most INPO recommenda-tions. RGRE will submit reports to INPO on a semi-annual basis regarding our'progress relative to those specific implementation dates. The first report will be submitted by September 1, 1981. The RG*E will look forward to INFO follow-up evaluations to assess the recommended imple-mentations.

GINNA (1980)

Page 5 DETAILS Category I items relate to criteria in INPO evaluation procedures.

Category II items, which are included in a few specific cases, relate to criteria that have not yet been included in INPO procedures but that are generally recognized as desirable and accepted techniques of industry and management. All findings listed are category I, except findings M2, 01, 02, P and AA2, which are category II.

ORGANIZATION AND ADMINISTRATION A. ~Ob'ectives Criteria A of INPO procedure OA-101, Rev. 1 states that a plant mission statement with goals and objectives should be published by the Plant Superintendent.

Finding Plant management has not prepared or published a mission statement for the plant nor have any formal goals and objec-tives been established for the plant. Due to the fact that the mission statement has not been published, Criteria A, B, C, D and E have not been met.

Recommendation Plant management should prepare and publish a mission state-ment that includes short term as well as long term goals and objectives for the plant. This should have widespread distri-bution through the station staff so that all individuals under-stand the station goals and objectives.

GINNA (1980)

Page 6 RGRE Res onse Station long-term goals and objectives have been distributed to the Station Supervisory Staff.

Station shoft-term goals will be developed and distributed by September 15, 1981.

GINNA (1F80)

Page 7 B. ORGANIZATIONSTRUCTURE

1. Criterion A of INPO procedure OA-102, Rev. 2 states that the organization structure should be defined by a diagram or comparable means which accurately reflects actual reporting lines.

~Find in The organization chart contained in administrative procedure A-201 does not accurately reflect actual plant organization for the Operations and Chemistry and Health Physics depart-ments. In addition, the position of Project Liaison Engineer and secretarial/clerical positions are not included on the organization chart.

Note: This finding also applies to INPO procedure TQ-211 Criterion A, OP-303 Criterion A and RC-501 Criterion A.

Recommendation The plant organization chart should be revised to reflect the actual plant organization. The use of an accurate organization chart will assure a clearer understanding of reporting arrange-ments and functional relationship of positions in the plant.

RGhE Res onse The "as is" plant organization chart will be completed and distributed by September 15, 1981.

0 GINNA (1980)

Page 8

2. Criterion B of INPO procedure OA-102, Rev. 2 states that written position descriptions, based upon job analysis, should be established for each position in the plant staff. These position descriptions should define authority, responsibility and accountability.

~Findin Position descriptions for plant positions are provided in Ginna Plant administrative procedure A-201; however, the procedure is not complete in that it does not cover all supervisory and technical positions or hourly employees. In addition, authori-ties for each position are not addressed.

Note: This finding also applies to INFO procedure TQ-211 Criterion C, OP-303 Criterion B, MA-401 Criterion C and RC-501 Criterion E.

Recommendation Position descriptions should be expanded to cover all positions at the plant to include job responsibilities, authority and accountability. Existing position descriptions should be re-vised to include position authority and accountability.

RGRE Res onse We totally concur with the audit finding and recommendation.

We understand that INPO is currently preparing generic posi-tion descriptions. A Corporate Employee Relations staff person has been assigned to organize and coordinate this effort. Due to the magnitude of this project, we expect to complete this task within one year of receipt of the INPO position descr iptions.

GINNA (1888)

Page 9

3. Criterion F of INFO procedure OA-102, Rev. 2 states that the plant organization should provide adequate staff to prevent excessive overtime and administrative burden at all levels.

~Pindin Adequate staffing is presently provided for the departments in the plant to handle the administrative workload at those levels; however, the plant superintendent is responsible for an excessive number of administrative and routine work require-ments.

Recommendation The plant superintendent's administrative workload should be evaluated to maximize his availability for management of plant activities.

RGBcE Res onse The Superintendent's availability to manage plant activities must be maximized. A review of the present administrative burden will be performed, and those duties that can be will be delegated to other offices. This will be accomplished by December 15, 1981.

GINNA (1980)

Page 10 C. Administrative Controls Criterion E of INPO procedure OA-103, Rev. 1 states that administrative controls should be disseminated to appropriate personnel and adherence should be required.

~Findin An observation of a maintenance activity revealed an action not authorized by the protective tagout procedure in that a breaker in a hold tag condition was operated for test purposes.

Recommendation Plant management should review maintenance procedures and practices to ensure they accommodate the requirements of the hold tag procedure. If there are unique conditions that do not permit checkout or testing in accordance with the hold tag procedure, these exceptions should be reviewed for safety concerns, and allowed exceptions should be identified in the hold tag procedure. Alternatively, the scope of the present hold tag procedure should be reviewed to determine its suita-bility to the full range of existing needs.

RGRE Res onse Plant procedures on hold rules have been modified to allow exceptions when special conditions required this action. These changes require informing all personnel marked up on the hold and is performed under the direction of the Holding Authority.

INNA (1980)

Page 11

~dW f Criterion D of INPO procedure OA-106, Rev. 1 states that work practices and safety considerations peculiar to the plant that affect employee safety should be published and given to every employee.

~Pindin A plant safety manual has not been published and distributed to the plant employees.

Recommendation Management should ensure the timely publication and distri-bution of the plant safety manual.

~G*E The division safety manual is in the process of being revised and updated to include reference to Ginna Station administra-tive and training programs. This manual will be completed and distributed by January 1, 1982.

GINNA (1980)

Page 12 TRAINING E. Trainin Or anization and Administration

1. Criterion B of INPO procedure TQ-211, Rev. 2 states that an adequate number of qualified personnel should be available to conduct the required training activities.

~Findin Adequate resources are not available to perform all normally assigned responsibilities including instructor preparation, ma-terial development, program improvement, trainee counseling, and instructor professional development in addition to actual instruction. The existing organization structure provides lim-ited resources for the accomplishment of these tasks.

Recommendation Management should review training manpower resources to determine additional needs. The Training Department man-ning levels should subsequently be increased to provide for a quality training pr ogram.

RGRE Res onse We accept your recommendations for more highly credentialed trainers in our nuclear section. We are actively pursuing personnel to increase the complement.

OIINNA (1980)

Page 13

2. Criterion F of INPO procedure TQ-211, Rev. 2 states that training program and curriculum development should be based on an evaluation of training needs or job analysis.

~Findin Curriculum development and modification is not based on evaluation of training needs or job analysis. New programs are developed as mandated by regulatory agencies and, as such, the need for training programs other than licensed operator training is not evaluated or developed.

Recommendation A job analysis, along with an evaluation of training needs, should be conducted to provide assurance that the training programs and program development provide plant personnel with suitable training to carry out their job responsibilities.

We accept your recommendation for more structured pro-grams. We plan to achieve these goals by December, 1982.

GINNA (1980)

Page 14 ', ~ ~

F. Trainin Resources

1. Criterion A of INPO procedure- TQ-221, Rev. 2 states that classroom facilities should be adequate for all group instruc-tions provided at the site.

~Findin Classroom training facilities are not adequate for the conduct of all formal group instruction provided at the site. Three classrooms are available to the Training Department and at times there are up to five classes scheduled. Some classrooms are excessively noisy from room air-conditioners. A vending machine break area located outside of one classroom causes excessive noise in adjacent classrooms.

Recommendation Management should evaluate training needs and requirements and provide suitable classroom facilities for all formal group instruction conducted at the site.

RGhE Res onse Management is evaluating the training needs and requirements and, after reviewing the recommendations of our consultant, positive steps will be taken in terms of adequate training facilities. This will be accomplished by April 1, 1982.

GINNA (1980)

Page 15

2. Criterion D of INPO procedure TQ-221, Rev. 2 states that training facilities should include sufficient offices, reference and study areas and break-out areas to accommodate the activities of the trainees and the training staff.

~Findin The training facilities do not adequately accommodate all of the activities of the trainees and the training staff.

Recommendation Management should evaluate their training needs and require-ments and provide training facilities that are sufficient to accommodate the activities of the trainees and the training staff.

~R This will be implemented in accordance with recommendation F-l, Training Resources. The Brookwood Science Information Center is under consideration to fulfillthis need. This will be accomplished by April 1, 1982.

GINNA (1980)

Page 16

3. Criterion F of INPO procedure TQ-221, Rev. 2 states that instructor lesson plans should be developed for all training programs.

~Findin Lesson plans have not been developed for all training pro-grams. Some programs are lacking lesson plans, and in other cases the content of lesson plans is minimal. Some programs are pr esented using only a one-line diagram.

Recommendation Complete lesson plans should be developed for all training programs to provide a greater assurance that consistent accu-rate information is presented to trainees.

RGhE Res onse We accept your recommendation. Preparation of lesson plans for all training programs will be accomplished by June, 1982.

~ PINNA (1980)17 Page G. Trainin Effectiveness

1. Criterion A of INPO procedure TQ-231, Rev. 2 states that the effectiveness of all training programs should be evaluated regularly by plant management and these evaluations should be conducted in accordance with written procedures.

~Findin Station procedures do not adequately address management's evaluation of the effectiveness of training programs. A definitive evaluation plan is not in existence, nor are there written implementing procedur es.

Recommendation Plant management should develop and implement written procedures for timely and pertinent evaluation of training program effectiveness.

RG*E Res onse We accept your recommendation.

Currently, through review of such documents as QC Surveil-lance Reports, QA Audit Reports, NRC Inspection Reports and Ginna Station Event Reports, the need for additional training is constantly reviewed and evaluated. This is not formally specified or documented. A procedure for this process, as well as a procedure for determining training effectiveness will be developed and implemented by December 5, 1981.

GINNA (1980) .

Page 18

2. Criterion B of INPO procedure TQ-231, Rev. 2 states that for each training program, trainee performance should be periodi-cally measured against job-related standards.

~Findin Trainee performance is not being per iodically measur ed against job-related standards.

Recommendation Management should develop and implement a program includ-ing procedures which will measur e trainee performance against job-related standards.

RGhE Res onse Rochester Gas and Electric Corporation has a job performance review system for every employee. It is performed on at least a yearly basis. The application of recommendation B-1 and B-2 should result in a method of obtaining training perfor-mance measured against job-related standards.

O GINNA (1980)

Page 19

3. Criterion C of INPO procedure TQ-231, Rev. 2 states that for each training program, instructor performance should be measured with respect to accomplishment of the program's objectives and effectiveness of instruction.

~Findin Instructor performance is not being measured with respect to accomplishment of program objective and effectiveness of instruction.

Recommendation An evaluation program should be developed and implemented to provide for effective instructor performance evaluation for each training program.

RGRE Res onse The Instructor Effectiveness Program will be formalized by March 1, 1982.

GINNA (1980)

Page 20 H. Non-Licensed 0 erator Trainin

1. Criterion A of INPO procedure TQ-242, Rev. 2 states that the initial training program and the continuing training for non-licensed operators should be described in a written proce-dure.

~Findin The initial training program for newly hired non-licensed operators and the continuing program are not described in a written procedure. This results in the non-licensed operators being included in the licensed operator retraining class, which does not address maintaining the job-related knowledge of non-licensed operators. The licensed operator retraining is designed for operators already licensed and trained and is of questionable value to the non-licensed operators.

Recommendation Formal procedures should be developed and implemented for initial and continuing training of non-licensed operators to ensure an appropriate progression from basic to more ad-vanced job knowledge.

RGdcE Res onse We agree with the recommendation.

Additions to the Ginna Station Training staff will afford the opportunity to provide on-going training for newly hired non-licensed operators. This type of job-related training for non-licensed operators, as well as re-training, will be in place by December, 1982.

GiNNA (1980)

Page 21

2. Criterion D of INPO procedure TQ-242, Rev. 2 states that in addition to training which is provided to qualify individuals for promotion, continuing training should be provided to qualified non-licensed operators to maintain and improve their capabil-ities to perform their current jobs.

~Pindin Continuing training of non-licensed operators is not designed to maintain and improve their capabilities to perform their current jobs.

Recommendation The continuing training program for non-licensed operators should be restructured to ensure that the training is designed to maintain and improve their capabilities to perform their cur rent jobs.

RGRE Res onse Additions to the Ginna Station training staff will afford the opportunity to provide on-going training for newly hired non-licensed operators. This type of job-related training for non-licensed operators, as well as retraining, will be in place by December, 1982.

GINNA (1980)

Page 22 I. Licensed 0 erator Trainin

1. Criterion F of INPO procedure TQ-243, Rev. 2 states that the licensed operator training program should specify required

- operating practices training.

~Findin Training requirements in operating practices for license candi=

dates are not identified beyond a listing of program examina-tion categories and a listing of normal plant operating evolu-tions.

Recommendation Proficiencies required of license candidates in performing normal plant evolutions, completing licensed operator adminis-trative and operational duties, and coping with abnor-mal/emergency plant conditions should be identified in the licensed operator training program. A combination of planned technical training, on-the-job training and nuclear plant simu-lator training should be used in developing these proficiencies.

~*

We agree with your recommendation.

The Licensed Operator Training Program is presently being revised to address the concerns of the INPO group. The program should be completed and approved by December, 1982.

GINNA (1980)

Page 23

2. Criterion D of INPO procedure TQ-243, Rev. 2 states that the licensed operator training program should specify required plant systems training and training methods used in accom-plishing this tr aining.

~Findin Nuclear power plant fundamentals training and plant systems training requirements for license candidates are not identified beyond a listing of program examination categories, and training methods to be used in the program are not specified.

Recommendation Knowledge and proficiencies required of license candidates in nuclear power plant fundamentals and plant systems should be identified in the licensed operator training program. Training methods to be utilized in the program should also be identi-fied.

A method of demonstrating proficiency in a program area should also be identified so that credit can be given for a license candidate's previous training and experience.

RGdcE Res onse We do concur that complete documentation of these training requirements is not in place. This will be accomplished by June 30, 1982.

GINNA (1980)

Page 24 J. Licensed 0 erator Re ualification Trainin Criterion B of INFO procedure TQ-244, Rev. 2 states that the requalification program should address how training material is developed.

~Findin The factors considered in determining the preplanned lecture series content and the process of developing training materials for the lecture series are not specified for the requalification program.

Recommendation The Training Department should consider licensed personnel performance during previous requalification program training and on-the-job performance and determine performance defi-ciencies which will be addressed in the requalification pro-gram. Plant operating experience and related nuclear industry oper ating experience related to licensed personnel operational proficiency should also be identified and addressed in the requalification program.

RGdcE Res onse Training material for use in licensed operator requalification training addresses itself to evaluations of the annual examina-tion and on-the-job performance deficiencies. Our program requires all topic areas to be covered every two years in-cluding those areas where high levels of proficiency are displayed.

Plant operating and related nuclear industry experiences are used during open classroom discussions to determine the background of the events, proper Ginna Station personnel actions, and future appropriate procedures.

GINNA (1980)

Page 25 K. Shif t Technical Advisor Trainin Criterion A of INPO procedure TQ-245, Rev. 1 states that training requirements for shift technical advisors should be established.

Criteria B, C and D of INPO procedure TQ-245, Rev. 1 state shift technical advisor training guidelines for general educa-tion, plant-specific training and annual refresher training.

~Findin Training requirements for the shift technical advisor position have not been fully established'. An outline of training to be accomplished by January 1, 1981 is established, but a complete program defining overall qualifications and training has not been identif ied.

The outline of training to be accomplished by January 1, 1981 does not include adequate general education and plant-specific training due to the short time frame available. Retraining requirements have not been identified.

Recommendation Plant management should establish a comprehensive training and retraining program for shift technical advisors. The INPO "Nuclear Power Plant Shift Technical Advisor-Recommenda-tions for Position Description, Qualifications, Education and Training" should be utilized in developing this program.

RGdcE Res onse We concur with this recommendation and are now in compli-ance.

GINNA (1980)

Page 26 OPERATIONS L. ~

Conduct of Shift 0 erations Criterion A of INPO procedure OP-301, Rev. 1 states that operator activities should be limited to operational duties.

~Findin Reading of non-technical material by the operators is permit-ted while on shift. Newspapers and novels were observed in the control room; Magazines were observed at the auxiliary operator's watch station.

Recommendation Management should develop policies for the control of reading material on shift and should implement effective management and supervisory effort to assure policies are adhered to.

Responsibility and authority for enforcement of the policies should be assigned.

RGRE Res onse A formal plant policy on reading materials has been estab-lished.

GIN NA (1980)

Page 27

1. Criterion C of INPO procedure OP-302, Rev. 1 states that double verification should be required for operation of impor-tant manual valves which are repositioned during maintenance or test and are safety related and have no control room indication.

~Findin Redundant verification of important manual safety-related valves is done after system test. However, this redundant verification is done only for the valves that were repositioned during the test and may not necessarily cover aQ valves that were repositioned during maintenance.

Recommendation Station procedures should be written to require double verifi-cation of the position of important manual valves that are repositioned for maintenance or test.

RGAE Res onse When maintenance is performed on safety-related equipment, the equipment is classified as inoperable and is tested prior to returning to service. The testing procedure (PT series) re-quires verification that aQ valves required for performance are in their proper operating position. AdditionaQy, Procedure A-1401, Station Holding Rules, has been modified to require double verification of proper alignment of valves tagged out.

This provides the redundant verification.

GINNA ('1980)

Page 28

2. Criterion F of INPO procedure OP-302, Rev. 1 states that a periodic review should be required of the clearance log.

~Findin Reviews of the hold tag log are required at shift change by the shift supervisors and by the duty engineer during his tours on back shift and weekends. These reviews are for watch relief and spot check, respectively, and are not a complete periodic check of log contents and tag attachment verification.

Recommendations A periodic review of the hold log should be required to verify that the Hold Record sheets are filled out in a consistent manner, and to verify each effective tag is appropriately attached, and tagged devices are in the proper position.

RGitt;E Res onse Rochester Gas and Electric currently performs the following with respect to their hold tagout practices:

1. Completed hold records are reviewed by the Operations Supervisor for discrepancies before submittal to central records.

2. The Duty Engineer randomly selects a tag from the field and verifies proper documentation in the Hold Book and vice versa for another tag, depending upon the availa-bility.

3. The Operations Supervisor reviews the Hold Record each week, after each shutdown and at the beginning of the year.

GINNA (1980)

Page 29 In addition to this, appropriate procedures have been modified to include the requirement for a periodic review of this Hold Book status in accordance with INPO's recommendation.

GINNA (1980) ', ~

Page 30 N. Use of Procedures

1. Criterion D of INPO procedure OP-304, Rev. 1 states that the content of emergency response procedures should aQow the operator to quickly and accurately review instructions for safety response to abnormal conditions.

~Findin The present format and content of emergency procedures do not provide the operator rapid access to needed instructions.

Some emergency procedures have many symptoms and im-mediate operator actions. Many of these immediate operator actions and symptoms are redundant or could be considered subsequent actions. Various emergency procedures include explanatory notes and general information in the immediate operator action section that make memorization by the opera-i-)

~ ~

tor difficult, and inconsistencies exist in some emergency procedures..

The practice of having no indentation of procedural steps and no capitalization or other highlighting methods except for major section headings, notes and cautions makes rapid loca-tion of procedural steps more difficult for users.

Recommendation Emergency procedures should be rewritten to eliminate: in-consistencies, redundancy, unnecessary notes, and general information from the immediate operator actions. Improve-ments can also be made in procedural format such as indenta-tion of procedural steps and more extensive use of capitaliza-tion or other highlighting methods.

GIN NA (1980)

Page 31 We recognize that some of the emergency procedures have recently been mandated by the NRC as a result of Westinghouse Owners'roup actions.

RGdcE Res onse The existing Ginna Emergency Procedures are based on guide-lines developed by the Westinghouse Owners Group to improve the format of the guidelines.

Revised procedural guidelines and a training seminar for utility personnel who are responsible for procedural prepara-tion and for operator training is scheduled for late September, 1981.

Following the seminar, we will revise our pr ocedures in accordance with the Owners Group guidelines, taking into account the INPO comments. We expect to complete the necessary procedural revisions and training by the end of the spring 1982 outage.

GINNA (1980)

Page 32

2. Criterion E of INFO procedure OP-304, Rev. 1 states that a system for development or revision of operating procedures should be established that provides prompt action to maintain procedures up-to-date.

~Findin Procedure A-503 requires users of procedures to check for the existence of any applicable procedure change notice (PCN's).

This practice is not being done. Discussions with several operating personnel revealed that they were not aware of the procedural requirement.

The results of procedure review by the Plant Operating Review Committee are not being provided to the shift in a timely manner that ensures approval or disapproval of PCN's prior to expiration date.

Recommendation Management should establish controls to ensure that users consult PCN's and that PORC approvals of changes are com-pleted and disseminated within the required time period.

RGdcE Res onse The additional controls are in operation.

GINNA (1980)

Page 33 0 erations Facilities and E ui ment A general criterion applicable to INPO procedure OP-306, Rev. 1 is that protective clothing should be properly main-tained.

~Findin Protective clothing lockers in the volatile treatment room, Primary Demineralizer room and the Hypochlorite room con-tained soiled protective clothing. Crystals and dirt on face shields located in these lockers would obscure the user's vision.

Recommendation A formal method to control protective clothing should be established to assure proper cleanliness.

~*

Procedures and controls to assure proper cleanliness of protec-tive clothing will be established by September 1, 1981.

GINNA (1980)

Page 34 P. Watch Turnover

1. Criterion B.S of INPO procedure OP-309, Rev. 1 requires documentation of the review of pertinent operating records/logs by the oncoming watch prior to assuming the watch and additional review of non-essential records/logs subsequent to assuming the watch.

~Findin Observations of the control room turnover revealed that review of the head control room operators log is not done or required by turnover procedures. Procedure 0-9, Shift Relief Turnover Control Room, requires operator review of other pertinent operating records/logs by the offgoing and the oncoming shift prior to turnover. In practice, the required review of pertinent operating records/logs was not done as required by procedure prior to turnover.

Recommendation Turnover procedures should be revised to include the review of the head control operator's log by all control room watch positions prior to turnover. There should be increased man-agement attention to ensure the turnover procedure is being adhered to.

The existing procedure only required turnover review of opera-ting records/logs by the Head Control Operator and has been complied with. However, we agree with the recommendation.

This will be implemented by September 30, 1981.

GINNA (1980)

Page 35

2. Criterion C of INFO procedure OP-309, Rev. 1 states that control room watch turnovers should include a general review of the control board to verify plant status.

~Findin A general console review is not being per formed during turnover nor is it required by procedure. The oncoming Shift Supervisor, after accepting the shift, is required to review 0-6.13, Daily Surveillance Log, which requires a detailed alignment check of critical valves, pumps, breakers, etc.,

sometime during his shift. This check is not being done at turnover for determination of plant status.

Recommendation Watch turnover procedures should be revised to include a general review of the control board at the time of watch turnover to verify plant status.

RGAE Res onse We agree with the recommendations. This will be imple-mented by September 30, 1981.

GINNA (1.980)

Page 36 ~

'AINTENANCE Q. Maintenance Or anization and Administration

1. Criterion E of INPO procedure MA-401, Rev. 2, states that administrative programs should be established by the Mainte-nance Department that address activities such as safety, employee development and communications.

~Findin Aside from participation on the plant safety committee, no department-level program for safety is established, Addi-tionaQy, training of department supervisors was found inade-quate in such areas as job-specific supervisory training, recog-nition of aberrant behavior, interpersonal relationships and technical training for foremen.

H

~ +~

Recommendation There should be increased department-level support and atten-tion to implementing industrial personnel safety rules and practices.

Formal supervisory training programs should be expanded and implemented to ensure optimum effectiveness of foremen and supervisors.

RGRE Res onse A corporate program is being improved upon and will be in effect by September 1, 1981.

GINNA (1980)

Page 37 R. Maintenance Procedures Criterion A of INPO procedure MA-403, Rev. 2, identifies the need for approved vendor instruction manuals when they are referenced by plant maintenance procedures for details of work instructions.

~Findin Many maintenance procedures reference unapproved and un-controlled vendor manuals for details of work instructions.

Recommendation Plant maintenance procedures which rely on references to vendor manuals for work instructions should be revised to incorporate the instructions into the procedures to the extent that the vendor manuals are utilized. Alternately, those manuals which are referenced by procedures should be subject-ed to a review which is equivalent to that given to plant procedures and should be specifically approved for use with the applicable procedure. The approved manual should be placed under document controls equivalent to that provided for plant procedures.

RGRE Res onse All vendor manuals required to perform safety related proce-dures will be under the control of Central Records. The maintenance procedures are being reviewed to minimize the number of vendor manuals necessary specifically for mainte-nance. This work will be completed by June 30, 1982.

GINNA (1980)

Page 38 S. Maintenance Histor

1. Criterion D of INPO procedure MA-405, Rev. 2, states that a method of periodic review and evaluation of equipment his-tories should be established.

~Findin A method of perodic review and evaluation of maintenance history is not established. Present reviews are limited to items that are the subject of specific inquiries or which have been noticeable problem areas. Adequate source information exists and is retrievable.

Recommendation A formal method of review and evaluation of equipment history should be established to detect abnormal equipment trends; to use in evaluation of equipment performance; and to detect additional needs for equipment maintenance, design, or replacement.

RGhE Res onse An informal review of maintenance histories has been in progress since the plant was started up and will be continued.

A formalized program will be in place by June 1, 1982.

GINNA (1989)

Page 39

2. Criterion E of INPO procedure MA-405, Rev. 2 states that an administrative procedure should exist which describes and defines the purpose, method and responsibility for implement-ing a maintenance history program.

~Findin An administrative procedure such as described by this INPO criterion does not exist. Maintenance history is up-to-date and consistent in format, but assurance of an ongoing consis-tency of program implementation is not provided.

Recommendation An approved administrative procedure should be developed to govern implementation of the maintenance history program.

RGRE Res onse An informal review of maintenance histories has been in progress since the plant was started up and will be continued.

A procedure will be in place by June 1, 1982.

GINNA (1980)

Page 40 T. Control/Calibration of Test E ui ment and Instrumentation

1. Criterion A of INPO procedure MA-406, Rev. 1, states that permanent, identifying designations should be assigned to test devices. This criterion further states that the designations should indicate the facility and particular group to which the devices are assigned.

~Findin Maintenance Department calibration and test devices are identified by the applicable manufacturer's serial number. No provision is made to identify the facility and group to which the device is assigned. Controlled devices are not identified so as to be clearly distinguishable from uncontrolled devices.

Recommendation Test and calibration devices designated by the Maintenance Department as "category 1" or "category 2" should be clearly identified as controlled devices. Identification information should include the responsible group or department and the name of the facility to which the device is assigned.

RGAE Res onse Rochester Gas and Electric will implement the recommenda-tions presented by INPO.

Currently the identification of test devices by name and serial number is being employed. Additionally, a unique system will be established to readily distinguish between controlled and uncontrolled devices, including the responsible group or department and the name of the facility to which the device is assigned. This will be completed by January 30, 1982.

NNA (1980)

Page 41

2. Criterion E of INPO procedure MA-406, Rev. 1 states that outmf-specification test devices should be identified with a special tag. The criterion further states that the tag should show information such as the date of rejection, the reason for rejection and the identification of the individual rejecting the device.

~Findin Although rejected test devices are identified with a unique "Do Not Use"-label, the information posted does not meet the intent of the INPO criterion. No additional information is posted as described by the criterion.

The omission of this information reduces the assurance against loss of information necessary for timely repair or replacement of rejected devices.

Recommendation Revise the format of rejected device labels to include infor-mation regarding the date of rejection, the reason for rejec-tion and the identification of the individual rejecting the device.

RGRE Res onse An improved tag is now used to identify rejected test devices, identifying date, reason for rejection and individual identifying the problem.

~ GINNA (1980)

Page 42

3. Criterion F of INPO procedure MA-406, Rev. 1 states that controlled test devices should be provided segregated storage locations.

~Findin Test devices which are identified as out of specification are not provided a storage location so as to preclude their inadvertent use. Accepted test devices are provided with segregated storage locations; however, some of these were found to be routinely stored in uncontrolled and non-segre-gated locations.

Although a relocation of the IAC facility was in progress at the conclusion of the evaluation visit, the move was in-C complete and the new storage locations were not evaluated.

Recommendation A segregated storage area should be established for rejected test devices so as to preclude their inadvertent use. Storage locations of accepted devices should be expanded as needed to accommodate all of the controlled items.

RGRE Res onse Out-of-specification items are now being stored in specific cabinets in a special area.

PINNA (1980)

Page 43

4. Criterion G of INPO procedure MA-406, Rev. 1 calls for positive control over the checkout of test equipment.

~Findin The use of IRC Department test devices is not controlled except on an informal basis. The present arrangement does not provide the best assurance that test devices are used by persons qualified to determine the correct applications.

Recommendation The IRC Department should develop a program for positive controls over the issuance of test equipment. This program should be sufficiently flexible so as not to inhibit issue of the test devices and should provide a central record of use of these items.

RGhE Res onse Past history has shown no problems with the informal controls over use of test equipment. All IAC personnel are qualified to use the test equipment and are knowledgeable of the applica-ble uses of each. Other personnel can only obtain these devices with permission from the IAC Shop supervisors.

Records are now being kept for use of these devices by the INC personnel for QA or Technical Specification surveillance.

This will aid in the review of calibration in the event of an out-ofwpecification device.

GINNA (1980)

Page 44 U. Maintenance Pacilities and E ui ment

1. Criterion B of INPO procedure MA-408, Rev. 1 states that ample maintenance tool storage space should be available in a suitable plant location.

Finding An IRC equipment and parts storage crib is situated in an unsuitable location. The location of this crib in the Makeup Demineralizer area subjects equipment to exposure to flood-ing, corrosive chemicals, and dust contamination.

Recommendation Action should be taken to relocate the IRC storage crib to an area with a more suitable environment. Consideration should be given to providing a location with good access from the new instrument shop.

RGRE Res onse We agree with the INPO finding. All shops shall review maintenance tool storage and equipment storage areas not located within their shop or stockroom. Such materials have either been discarded or turned over to the stockroom.

IlINNA (1990)

Page 45

2. Criterion C of INPO procedure MA-408, Rev. 1 states that office and work areas should adequately conform to the needs of the organization.

~Findin Office arrangements for the Maintenance Supervisor and the IRC Supervisor are established in a manner that detracts from the most effective performance of their job responsibilities.

Recommendation Action should be taken to provide the necessary features at the work locations of these two key supervisors that will work to reduce the visual and aural distractions currently expe-rienced in the existing arrangement. Some provision should be made to improve the capability to conduct confidential inter-views or conferences by these supervisors.

RGRE Res onse We agree with this finding. Free-standing moveable partitions will be ordered and installed by March, 1982. This will be installed in all areas of the Office Service Building as deter-mined by the Station Superintendent.

GINNA (1880)

Page 46

3. Criterion E of INPO procedure MA-408, Rev. 1 states that maintenance tools, equipment and facilities should be kept clean, orderly, and well maintained.

~Findin The arrangement of equipment in certain areas indicates an inappropriate level of attention to maintenance of these items. Some areas are not maintained in a manner that would contribute to quick location of materials or provide convenient access.

Preparations for relocation of the IRC facility may have affected some of the areas evaluated.

Recommendation Maintenance supervision should review existing procedures and practices for adequacy in this regard, making pertinent changes where needed, and should implement effective supervisory effort to provide orderly and proper arrangement of equipment. The proposed expansion of the Mechanic Shop and the relocation of the Electrician Shop and IRC Shop should provide a good opportunity to address this finding.

RGRE Res onse The relocation of the Mechanic, INC, and Electric Shops since the INPO audit has greatly improved conditions in these areas.

All shop personnel will be reminded during shop meetings of the importance of maintaining good working areas and equip-ment.

The work areas in this plant will be maintained as clean as possible. All personnel will be advised of the necessity of keeping a clean work space.

INNA (1980)

Page 47 RADIATION PROTECTION AND CHEMISTRY V. Radiation Protection and Chemistr Or anization and Admin-istration Criterion D of INPO procedure RC-501, Rev. 1 states that a formal training/retraining program should be in effect to maintain the technical qualifications of the staff. Formal management training should be included for supervisory and management employees.

~Findin The technician indoctrination and training program has not been formalized. This program includes procedure review checklists, on-the-job training under the supervision of ex-perienced technicians and systems training when available.

Supervisors do not formally approve an individual's completion of the program, and training records are not required to be kept. Systems training is provided to technicians as part of the operator training program, but technicians attend only if it is convenient and completion of systems training is not re-quired. No program exists for the periodic retraining of personnel, and no formal management training is provided on a systematic basis for management and supervisory personnel.

Recommendation A training program, based on job evaluations, should be developed for the Radiation Protection and Chemistry Depart-ment. The program should provide for refresher training at specified fr equencies. Refresher training should include new techniques and new knowledge available to the industry as well as a review of current plant practices and plant systems.

Present training activities such as the six weeks health physics course presented by Memphis State University should be

GINNA (1980)

Page 48 incorporated into a comprehensive training program. Supervi-sory review of completed training and the maintenance of training records should be included as administrative require-ments of the program. A systematic, progressive management training program should be instituted for managers and super-visors.

RGRE Res onse We agree with the recommendation. A formal program will be established by January 1, 1982.

Radiation Protection Trainin involves procedural review and on-the-job training under a qualified individual and formal training provided to increase their knowledge level as outlined in the formal program.

The Training Section has been enlarged to accomplish addi-tional training. One new instructor will coordinate and expand the training program for Health Physics section personnel as time is available. The expanded training program will be based on job evaluations/descriptions that will be prepared by the Employee Relations Department and completed by December, 1982.

Mana ement Trainin will be provided by the Employee Rela-tion Department by a formal management training program to involve supervisors and managers in training. This program will be provided company-wide on a regular basis, and records of such tr aining may be obtained through the Employee Relations Department.

~ PINNA (1980)

Page 49 W. Waste and Dischar e Control {Li uid)

1. Criterion D of INPO procedure RC-505, Rev. 2 recommends a program for sampling systems that are normally clean.

~Findin The auxiliary boiler, the service air system and the demin-eralized water system are examples of normally clean systems which are not being sampled routinely to detect radioactive contamination.

Recommendation Evaluate the various plant systems that are normally clean to determine if the potential for contamination exists. For those systems where contamination is possible, establish a sampling schedule or a means of monitoring the system to detect contamination before it becomes a personnel hazard or is inadvertently released.

RGhE Res onse A review has been made for those systems where contamina-tion is possible. The service air system is sampled prior to use for breathing. The auxiliary boiler and the demineralized water systems are currently being periodically sampled. There are no other systems where contamination is possible.

GINNA (1980)

Page 50

2. Criterion E of INPO procedure RC-505, Rev. 2 requires a training/requalification program for radwaste system opera-tors, maintenance personnel and radchem personnel.

~Findin See V Finding in this report.

Recommendation See V Finding in this report.

RGRE Res onse We agree with the recommendation. A formal program will be established by January 1, 1982.

Rad Waste Trainin involves procedural review and on-the-job training under a qualified individual and formal training pro-vided to increase their knowledge level as outlined in the formal program.

The Training Section has been enlarged to accomplish addi-tional training. One new instructor will coordinate and expand the training program for Health Physics section personnel as time is available. The expanded training program will be based on job evaluation/description which will be prepared by the Employee Relations Department and completed by December, 1982.

Mana ement Trainin will be provided by the Employee Rela-tion Department by a formal Management Training Program to involve supervisors and managers in training. This program will be provided company-wide on a regular basis, and records of such training may be obtained through the Employee Relations Department.

4 INNA (1980)

Page 51 X. Radiolo ical Surve E ui ment Control and Calibration

1. Criterion A of procedure RC-506, Rev. 2 states that manage-ment approved procedures should be provided to prescribe the policies, practices and requirements for the control and cali-bration of monitoring equipment.

~Findin Procedures do not specify controls for instruments nor are informal controls being practiced, except during outages.

There is no accountability for an instrument until the calibra-tion is due, at which. time there is a search made for the instrument. Several instruments were considered lost.

Recommendation Develop and implement procedural controls for the accounta-bility of instruments during all stages of operation. A certain number of instruments at access control should be set aside for health physics use only. All "in service" instruments except those assigned to specific work stations should be returned to access control on at least a daily basis to facilitate battery and operability checks. Control of instru-ments in storage or awaiting calibration should also be ad-dressed. ANSI N323-1978 outlines an acceptable program for control and calibration of instruments.

RGdcE Res onse We agree with this INPO finding. To meet this Criterion, procedures will be developed to control instrument issuance.

Instruments which are set aside for daily use by technicians and plant personnel would be signed out and returned daily.

This could be checked each day by the technicians on after-noon and midnight shifts to ensure the instruments have been returned. This will be implemented by December 1, 1981.

GINNA (1980)

Page 52

2. Criterion B of INPO procedure RC-506, Rev. 2, states that equipment should be stored in areas that provide environ-mental and physical protection while separating operable and inoperable equipment.

~Findin A large number of instruments were being stored in the air handling equipment room in the administrative building. This room contains the gamma calibrator and serves as a calibra-tion facility. Instruments were sitting on ledges on the gamma calibrator and on one desk-near the calibrator. No physical protection was provided and no storage cabinets were available for organizing the storage location. Moisture in the area is a potential problem because of the large amounts of water standing in the drip basins beneath the air handling units. Lighting was also poor in the area.

Recommendation The long-term recommendation is to provide a calibration facility that provides adequate lighting, environmental con-trols and instrument storage facilities. A short-term solution would be to provide storage cabinets in the present facility for the purpose of organizing and protecting instruments awaiting calibration. Instruments should be calibrated promptly and moved to a storage area where environmental conditions will not jeopardize instrument reliability.

~*

Cabinets have been ordered for the instruments. These will be set up in an area that has environmental controls such as the lab or office area.

A permanent calibration facility is now in place.

GINNA (1980)

Page 53

3. Criterion C of INPO procedure RC-506, Rev. 2, requires that instruments be source checked at least daily (if used) prior to the first use.

~Findin Instruments are not being source checked in the interval between calibrations. Calibrations are normally performed each quarter.

Recommendation Establish a procedural requirement for routine source checks of instruments between calibrations.. ANSI N323-1978, Radia-tion Protection Instrumentation Test and Calibration, provides acceptable guidance in this area.

RGhE Res onse RGRE wiQ implement a procedure to source check instruments set aside for daily use. The most probable method to accomplish this will be to have one cabinet set aside with instruments available for use by technicians and plant person-nel. These instruments would be source checked each morning by the technician on the midnight shift so that they would be available for use during the day shift. The remaining instru-ments would be kept in separate, locked cabinets and source checked prior to use.

This will be implemented by December 1, 1981.

~ GINNA (1989)

Page 54 Y. Personnel HP Indoctrination Criterion F of INPO procedure RC-507, Rev. 2, recommends that the HP Indoctrination Program be evaluated annually by an independent, knowledgeable person or group.

~Findin Plant procedures do not provide for an annual, independent evaluation of the Health Physics Indoctrination program. It is recognized that such evaluations have been performed in the past by the Chemistry and Health Physics Training Depart-ment and other groups outside the plant organization.

Recommendation The HP Indoctrination Program should be revised to include an annual independent evaluation of the program.

RG*E Res onse We continue to recognize the need for evaluation and improve-ment of the Health Physics Orientation Program. In the future, we wiQ evaluate the program annually using corporate training resources, health physics personnel, or contracted consultants. We will, however, add a statement to that effect in the orientation procedures. This will be implemented by December 15, 1981.

O GINNA (1980)

Page 55 Z. Process Water Controls

1. Criterion B of INPO Procedure RC-508, Rev. 2, requires a program to control the use of chemicals that might cause corrosion if put into or in contact with plant components.

~Findin There is no program to control the use of chemicals that might cause corrosion if put into or in contact with plant compo-nents.

Recommendation Establish a program that delineates what chemicals, solvents, sealants and decontamination agents are authorized for plant use, the systems on which they may be used, the conditions of use and the method of disposal. Such a program might be part of an overall industrial hazard control program to control chemicals because of their toxicity, fire hazard, etc.

~*

We agree with the recommendation and will establish such a program by December 15, 1981.

GINNA (1980)

Page 56

2. In INPO procedure RC-508, Rev. 2, there is an inherent general criterion that requires that chemistry laboratories be clean, organized and free of unnecessary hazards.

~Findin The work surfaces in the secondary chemistry lab were clut-tered and dirty. Infrequently used equipment is being stored in laboratory cabinets and in work spaces that should be kept clear for routine high frequency work. Large amounts of flammable liquids (several gallons of acetone, benzene and methylethylketone) are stored in the lab but are not kept in fireproof cabinets. Chemical hazards were not all clearly identified.

Recommendation Find alternate storage locations for some of the equipment and bulk chemicals being stored in the lab. Fire codes and OSHA regulations should be consulted to determine the types, amounts and storage requirements for flammable and toxic chemicals. Laboratory work areas such as benchtops and fume hoods should be kept clean on a continual basis. The use of drip pans and absorbent paper covers for work spaces might be considered to assist in keeping the work spaces clean and neat.

RGdcE Res onse We agree with the recommendation.

As a means for reclaiming workspace, infrequently used equip-ment has been stored at an alternate location outside the laboratory. Storage c'abinets have been ordered for this purpose and have been located in the "Air Handling Room."

The storage of flammable liquids in the laboratory has been minimized. Those liquids routinely utilized in the lab have

ANNA(1980)

Page 57 been stored in OSHA-approved safety containers. Infrequently used and bulk flammable liquids have been stored in a safety cabinet located elsewhere in the plant.

GINNA (1980) ~

Page 58 AA. Health Ph sics Facilities and E ui ment Criterion C of INPO procedure RC-509, Rev. 2, states that the design and working environment of health physics facilities should be optimized to contribute to efficiency and safe operation of the plant.

~Findin All of the facilities observed were judged to be safe; however, the efficiency at several of the facilities needs improvement.

The office provided for the CRHP Foreman is in fact the entrance hallway into the HP work area at Access Control.

Traffic and noise levels were observed to be high.

Recommendation The CdcHP Foreman's office could be made much quieter and traffic substantiaQy reduced by blocking off the rear (or west end) of the office and rerouting traffic.

RGAE Res onse The Health Physics Office has been relocated across the hall.

As a result, the C 8 HP Foreman area is now considered satisfactory.

~ PINNA (1990)

Page 59 Technical Su ort On-Site AB. On-Site En ineerin Su ort (TS-702)

1. Criterion A of INPO procedure TS-702 Rev. 1 states that on-site engineering support should be defined and organized to support plant management goals and objectives.

~Findin The on-site engineering group is not adequately staffed and organized to support plant management in the areas of design modifications and reactor engineering. While the off-site engineering group does provide support in these areas, the on-site group does not have sufficient depth and resources to provide a prompt input to plant management on problems of a technical nature. Only one nuclear engineer is assigned to the station.

His duties include the handling of design modifications and other assigned activities which divert him from his primary responsibility of monitoring core performance. Deficiencies in the coordination of design modifications are addressed in the findings for Criterion C of procedure TS-702 Rev. l.

Recommendation The nuclear engineering component of the on-site engineering organization should be strengthened. Organizational changes should also be implemented as identified in the recommenda-tions for Criterion C of INPO procedure TS-702 Rev. 1.

RGhE Res onse Several changes have been made within the Technical Engi-neering Group. The Nuclear Engineer has assumed additional responsibilities for monitoring and assessing fuel and reactor performances.

GINNA (1980)

Page 60 His reponsibility for providing plant input at the fuel and cycle design stage has been reemphasized. Responsibility for modi-fications has been reassigned from the Nuclear Engineer to another engineer in the Technical Engineering Group. The Nuclear Engineer retains responsibility for review of safety analysis for minor modifications.

It is necessary to respond, however, to the general nature of the finding. Engineering support of Ginna Station is provided by knowledgeable people throughout the company. This in-cludes engineers on the Ginna staff, Ginna Station engineers assigned to the Modification Project, Modification Engineers who are not members of the Ginna staff, and engineers reporting to off-site organizations such as the Engineering Department. In each group there are engineers with actual plant engineering and operations experience. In fact, a number of engineers in the Engineering Department have worked for extended periods of time at Ginna. We believe it proper to view engineering support from the broad perspective including aQ experience and resources available offwite as well as on-site.

Reliance on off-site groups to support on-site engineering will continue.

PINNA (1980)

Page 61

2. Criterion B of INPO procedure TS-702 Rev. 1 states that the

,interface of off-site support groups with on-site engineering should be coordinated effectively and prompt action should be received on requests for assistance.

~Findin The interface between the on-site engineering group and the off site engineering group is not being effectively coordinated.

This is due in part to the lack of a focal point in the station for all modifications as discussed in the recommendation for Criterion C. The station's Technical Engineer is not neces-sarily aware of requests for off-site engineering services which may be initiated by other individuals in accordance with procedure A-55 Rev. 3. Participation by plant management in the actual engineering process is also informal and limited; i.e., plant personnel do not have the opportunity to review proposed modifications for operability and maintainability considerations.

Recommendation Responsibility for the interface with the off-site engineering organization should be clearly identified in the station organi-zation. Plant management should be advised of the priority classifications and target completion dates assigned to engi-neering work requests submitted by the station and an effec-tive system for monitoring the status of these requests should be implemented. This system should focus management atten-tion on those requests which are behind schedule and also serve as a means of providing feedback to the depar tment that originated the request.

In addition to monitoring engineering work requests submitted by the station, plant management should also monitor the status of engineering activities initiated by other departments which would affect the station.

GINNA (1980)

Page 62 The interface between the station and off-site support groups should be improved. Plant management should have the opportunity to review the engineering outputs at an appropri-ate stage to ensure that operability and maintainability con-cerns will be addressed in the final design. Prior to installa-tion of a modification, plant management approval of the final design should be required.

RGdcE Res onse Three organizations within the company participate in the design and installation of plant modifications. The Engineering Department has been designated responsibility for design of plant modifications. This includes preparation of the Design Criteria and Safety Analysis, performance of all analy-ses, preparations of procurement documents, and preparation of construction documents. The Modification Project is re-sponsible for construction of modifications. Ginna Station is responsible for performing Safety Evaluations, based on the Design Criteria and Safety Analysis, in accordance with 10 CFR 50.59. Ginna Station is also responsible for approving all installation and operating procedures related to modifications.

Further delineation is clearly established in the Ginna Station Quality Assurance Manual.

Requests from on-site personnel for off-site engineering assis-tance will be processed via the Technical Engineer for concur-rence. Administrative directives will be revised to reflect this requirement.

The Technical Engineer shall at the time the Engineering Work Request is initiated, designate on the work request a compe-tent station person who wiQ provide the responsible engineer station input during the conceptual and final design process.

Prior to installation of the modification, final design packages are submitted to the Modification Project Organization for

INNA (1980)

Page 63 review by the Project Construction Engineer and the Plant Liaison Engineer for constructability and operability. The Plant Liaison Engineer shall also assure that the cognizant station individual has reviewed the final design for maintain-ability and operability and submitted appropriate comments to the responsible engineer. Plant Management and the Techni-cal Engineer will receive the Engineering Work Request status list from Engineering on a monthly basis. This will address all Engineering Work Requests affecting Ginna Station, not only those initiated by Ginna Station, and will provide a mechanism for the station to monitor the status of projects. In addition, all Engineering Work Requests initiated by organizations other than Ginna Station will be approved by the Division Superin-tendent, Nuclear Production, with a copy provided to Ginna Station. Finally, the Ginna Station Plant Operating Review Committee reviews all installation procedures.

0 GINNA (1980)

Page 64

3. Criterion C of INPO procedure TS-702 Rev. 1 states that a program should be defined for control of design changes which ensures safe and timely resolution of plant modifications..

~Findin Station procedure A-301 Rev. 5 thoroughly addresses the plant modification process; however, the system described is cum-bersome and deficient in the following respects.

Responsibility for the modification program is fragmented among several organizational units.

Not all plant design drawings affected by a modification are being revised.

Controlled sets of drawings used for reference by operators on shift are not being marked in all cases to'ensure that the user is made aware of a change as required by station procedure A-603 Rev. 2.

Procedure A-301 Rev. 5 does not require that plant operating procedures affected by a modification be revised before returning a modified system to service.

Procedure A-301, Rev. 5 does not provide adequate assurance that operations personnel will be advised of plant modifica-tions and receive appropriate training in a timely manner.

Minor modifications with relatively minimal engineering re-quirements are not being processed in a timely manner by the on-site and off-site engineering support organizations. In one instance, a modification (no. 79-14) involving the condensate storage tank was requested over one year ago and has not yet been released for installation. This is not a safety-related

Q!NNAPage (1980) 65 component; however, as recognized by the PORC, this design change should prevent the recurrence of tank diaphragm failures which could affect the availability of the Auxiliary Feedwater System.

Recommendation The role of the on-site engineering organization in the modi-fication program should be expanded to provide increased support to the station. The Project Liaison Engineer should continue to coordinate the installation of major modifications; however, the on-site engineering organization should become a focal point for tracking the status of all modifications from the time they are proposed until they are either disapproved or installed and the file closed out. This responsibility should include major and minor modifications whether they are initiated by the station or others. The on-site engineering organization should also provide support services to the station by assisting other departments in the development and proces-sing of installation procedures for the modification. This could also include descriptive material, for training purposes, revisions to plant procedures affected by modifications, and drawing revision requests.

The procedure for control of modifications should ensure that plant design drawings affected by a modification are revised.

In processing the modification, the on-site engineering organi-zation should verify that this is being accomplished. Particu-lar attention should be given to drawings frequently used by station personnel for reference and troubleshooting; these drawings include flow diagrams, schematics, circuit schedules and wiring diagrams.

Management should review procedural and other constraints in'he modification program which are delaying the approval and installation of some minor modifications. Those modifications

GINNA (1980)

Page 66 which involve minimal or no engineering and are within the capability of the station maintenance force to install should be processed in a more timely manner.

Procedure A-301 should be revised to require that revisions to plant procedures affected by a modification be approved and in place before a modified system is returned to service.

As required by section 3.5.5 of procedure A-603 Rev. 2, the Engineering Work Request and marked-up drawings which describe a modification should be attached to (or cross-referenced in) the controlled sets of drawings used by opera-tions personnel on shift for reference. Procedure A-301 should be revised to require this action prior to returning a modified system to service.

Plant management should determine the appropriate operator training requirements for each modification. These may range from formal classroom training for the addition of new sys-tems to a simple written description of the change included in a required reading folder. Modifications which could have a significant impact on operations should be brought to the attention of operators through use of the shift turnover procedure. The depth of training and time frame in which it is accomplished is best determined on a case by case basis by experienced plant management personnel. Procedure A-301 should be strengthened in this respect, however, to address the need for notification and/or training in a timely manner.

RGdcE Res onse The on-site Ginna Technical Organization is the focal point for the plant with regard to the initiation, design criteria, and safety analysis processing of a modification. The Technical Engineer shall at the time the Engineering Work Request is initiated, designate on the work request a competent station individual who will provide the responsible engineer station

~ . ~

GINNA (1990)

~ '$ + g Page 67 input during the conceptual and final design process. Prior to installation of the modification, final design packages are submitted to the Modification Project Organization for review by the Project Construction Engineer and the Plant Liaison Engineer for contructability and operability. The Plant Liaison Engineer shall also assure that the cognizant station individual has reviewed the final design for maintainability and submitted appropriate comments to the responsible engineer.

Procedures will be reviewed and modified to formally describe this responsibility by December 31, 1981.

The Project Liaison Engineer will continue to coordinate the installation of modifications. This also includes descriptive material, for training purposes, and revisions to plant proce-dure requests. Specifically, Training, Operations, Maintenance and Test and Results shall maintain their responsibility for their specific aspects of a modification.

The Project Liaison Engineer, currently by procedure, ensures that drawing change requests are initiated and procedure changes have been implemented to ensure Control Room personnel are aware of system configuration changes prior to the operational need of that system and all related systems.

Systems are under review to ensure existing drawings are maintained current within a reasonable time period. A system will be selected by the Engineering Department by December 31, 1981.

Management has reviewed the minor modifications and agreed that minor modifications will be reviewed and returned to the plant within a four week period after receipt. However, it must be recognized that priority must be placed on safety-related modifications and modifications mandated by the NRC. Thus, these priorities may, at times, result in the four week goal of minor modifications that are not safety-related

GINNA (1980)

Page 68 not being met. 'The on-site review, through the assigned cognizant people, should allow an improvement in the turn-around time of all plant modifications.

Plant procedures have historically been changed prior to operational needs. However, procedure A-301 has been revised to ensure that revisions to plant procedures affected by a modification will be approved and in place consistent with the needs for such procedures. For example, the Containment Leak Rate Test is done on an every three year basis. Proce-dural changes for this test, as a result of modifications, need not be in place until the next test performance, and not when the system is placed in service. Timeliness of procedural changes is recognized and will be accomplished consistent with needs.

As required by Section 3.5.5 of Procedure A-603, Rev. 2, the Engineering Work Request and marked-up drawings that describe a modification should be attached to (or cross referenced in) the controlled sets of drawings used by Opera-tions personnel on shift for reference. Procedure A-301 will be revised by September 30, 1981 to require this action prior to returning a modified system to service.

With respect to training on modifications, the foQowing will be accomplished:

The Engineering Department will ensure that functional descriptions are provided for each modification. When these are transmitted, the Liaison Engineer wBl ensure that the Ginna Station Training Section obtains a copy.

The Ginna Training Section will initiate a "read and initial" sheet to document Operator acknowledgement.

QbINNA (1980)

Page 69 The Operations Engineer will ensure that involved Operations personnel have completed acknowledgement prior to plant start-up or prior to required system use.

Procedures wiQ be in place by December 1, 1981 and will be applicable only to those modifications whose, con-struction starts after that date and to modifications that involve a functional change to a system. Pipe support modifications, for example, do not require operator training since the functions of the system are not changed.

Formal classroom training may be presented at a later date, depending on the complexity of the modification as determined by plant management.

These actions, combined with commitments to timely proce-dural and drawing changes involved in a modification, should ensure continued safe operations at Ginna Station.

GIN NA (1980)

Page 70

4. Criterion D of INPO procedure TS-702 Rev. 1 states that a program should be in effect to identify and rank all plant incidents and to provide an evaluation of cause, corrective action, and generic implications for those considered signifi-cant.

~Findin Plant events, including those which do not require reporting by LER, are being evaluated and a formal corrective action program is in effect. The Technical Assistant for Operations Assessment, however, is not required by procedure A-25.1 Rev. 14 to retain copies of past event reports nor is he required to maintain an index of past events. Copies of past event reports can be obtained from central records, but an adequate index to facilitate retrieval is not available.

Recommendation The Technical Assistant For Operations Assessment should maintain, as a minimum, an index of all events over the life of the plant which were reported by form A-25.1 or the equiva-lent. This index should include a brief description of the event, or the systems or components involved in the events in addition to the event date. An index of this type which includes those events, which did not require reporting by LER, is essential to performance of the Operations Assessment Function.

~*

RGRE agrees with this recommendation.

RGAE now has an effective program for identifying, docu-menting, reviewing, and assessing all plant incidents. This program has not been in effect (in present form) since 1970; therefore, we do not possess "an index of all events over the

GINNA (1980)

Page 71 life of the plantF However, LERs (or their equivalent) have been required since 1971.

Ginna Station Central Records has a complete index of all LERs, dating back to 1971. Since early 1980, RGRE has been indexing and filing A-25.1 event reports, which include many reports that did not require reporting by LER. Contrary to INPO's finding, an adequate index for recent A-25.ls is available.

It would not be practical to review the plant operating history during the 1970's and establish an index of "all events over the life of the plant."

In summary, we have an index and a file in Central Records

'or all LERs dating back to 1971. The Technical Assistant for Operational Assessment will review this index for accuracy for those events occurring after January 1,-1976, and will main-tain an up-to-date (since 1976) copy of this index. We have an index and a file of A-25.1 plant event reports that date back to 1980. The Technical Assistant for Operational Assessment is maintaining a copy of this index up-to-date (since January 1, 1981).

GINNA (1980)-

Page V2

5. Criterion E of INPO procedure TS-702 Rev. 1 states that a program should be in effect to address input of operating I

tw experience from agencies outside of the company.

I~

l ~Findin p A formal program to address operating experiences from II outside the company does not exist. RGRE is in the process of

~ ~

developing a program and is committed to NRC to have one in i

~

t

~

I place by January 1981.

\

Recommendation RGdcE should ensure that sufficient resources are committed to implement a program to evaluate operating experiences from outside the company at an early date.

~*

A program has been established and implemented to evaluate operating experiences from outside RGRE.

n

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GINNA (1880)

I Page 73

6. Criterion F of INPO procedure TS-702 Rev. 1 states that programs should be defined to provide coordination and control of plant performance monitoring, in-service inspection, and integrated leak rate testing.

~Findin In-service inspection and integrated leak rate testing are being adequately coordinated by the on-site engineering and quality control groups. The on-site engineering group does not have a program for plant performance monitoring; however, the cor-porate office engineering does provide some assistance in this respect. The off-site program for monitoring plant perfor-mance was not evaluated.

Recommendation The on-site engineering organization should implement a pro-gram for plant performance monitoring. An on-site program of this nature need not replace or duplicate the off-site program, but rather, it should be structured to complement it.

RGRE Res onse An integrated performance test program involving on-site and off-site organizations will be developed by December, 1982.

The program will be implemented by June, 1983, upon person-nel augmentation of the Ginna Technical Section to maintain such a program.

GINNA (1980)

Page 74 AS-BUILT DRAWINGS Although a criterion has not been developed at the present time as a basis for evaluations, there is a concern regarding the status of the Ginna Station drawings. It appears that the plant design drawings do not in all cases reflect the true as-built status of the plant.

While it is believed that this situation exists primarily in the area of balance-of-plant, it is possible that some safety-related system drawings also may not accurately reflect as-built conditions. It should also be noted, however, that drawings such as schematics and circuit schedules apparently have been maintained in an as-built status and that these drawings in conjunction with periodic functional testing are considered by RGRE management to provide adequate assurance that safety systems will perform their intended functions. The limited depth of this evalua-tion does not permit any conclusions to be drawn regarding the adequacy or inadequacy of the safety-'related drawings.

In absence of an INPO criterion covering as-built drawings, a formal recommendation is not being made at this time. The PORC and the NSARB should, however, review the status of as-built drawings at Ginna Station and address the possibility of adverse affects on the quality of operation and maintenance activities. Particular attention in this review should be given to the effects during abnormal plant conditions not covered by procedures.

SANA (1980)

Appendix Page 1 ADMINISTRATIVEAPPENDIX I. LISTING OF AREAS EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-105 Information Programs OA-106 Industrial Safety OA-107 Surveillance Program TRAINING TQ-211 Training Organization and Administration TQ-221 Training Resources TQ-231 Training Effectiveness TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training TQ-244 Licensed Operator Requalification Training TQ-245 Shift Technical Advisor Training OPERATIONS OP-301 Conduct of Shift Operations OP-302 Tagout Practices OP-303 Operations Organization and Administration OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-309 Watch Turnover

NNA (1980)

Appendix Page 2 MAINTENANCE MA-401 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 Instrumenta-tion MA-408 Maintenance Facilities and Equipment RADIATION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-502 ALARA Program RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control RC-505 Waste and Discharge Control (Liquid)

RC-506 Radiological Survey Equipment Control 2 Calibration RC-50 V Personnel HP Indoctrination RC-508 Process Water Controls RC-509 Health Physical Facilities and Equipment RC-511 Respiratory Protection Program TECHNICAL SUPPORT - ON-SITE TS-702 On-Site Engineering Support

)

'INNA (1980)

Appendix Page 3 ROCHESTER GAS AND ELECTRIC CORPORATION PERSONNEL CONTA of Board, Chief Executive Officer I'hairman President Executive Vice President Vice President - Electric and Steam Production Vice President Employee Relations

'Chief Engineer Assistant Chief Engineer Manager, Mechanical Engineering Manager, Electrical Engineering Superintendent - Nuclear Production Plant Superintendent Assistant Station Superintendent Operations Engineer Maintenance Engineer Supervisor Chemistry and Health Physics Technical Engineer Nuclear Engineer Training Coordinator Quality Control Engineer Technical Assistant for Operational Assessment Fire Protection and Safety Coordinator Results and Test Supervisor Assistant Training Coordinators Shift Supervisors Shift Foremen Licensed Operator Trainees Operations Supervisor Project Engineer Project Liaison Engineer Head Control Room Operators Electrical Foreman Control Room Operators Auxiliary Operators Instrument and Controls Supervisor Maintenance Supervisor Instrument and Controls Foreman Pipe Fitter Foreman Handyman Foreman Mechanic Foreman Maintenance Aide Health Physicists Dosimetry Supervisor Health Physics Foreman Chemistry and Health Physics Technician Instr uctor Secondary Chemist Chemistry Laboratory Technician