ML18025B643
| ML18025B643 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/30/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| References | |
| NUDOCS 8109240319 | |
| Download: ML18025B643 (52) | |
Text
EVALUATION BROWNS PERRY'NUCLEAR POWER'STATION'ennessee Valley Authority July 1981 KMMM7RL'le ALLMPlf Bf09'2403i9 Bf093f
'DR ADQCK 05000259 P
~, PDR
SUMMARY
BROWNS FERRY (1981)
Page 1
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Tennessee Valley Authority's.(TVA) Browns Ferry Nuclear Generating Station during the weeks of March 2 and 9, 1981.
Browns Ferry consists of three 1152 megawatt (electrical) General Electric boiling water reactor plants. It is located on the Tennessee River near Huntsville, Alabama.
Unit I was placed in commercial operation in 19V4, Unit 11 in 19V5 and Unit IIIin 19VV.
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.
The evaluation was based on INPO experience of best practices within the industry and written evaluation criteria furnished to the plant in advance.
Information was assembled from discussions, interviews, observations and reviews of plant: documents.
Emergency preparedness was, not included in the scope of'he evaluation, nor were corporate activities, except as an. incidental part of, the station evaluation..
The evaluation team examined station organization, training*and qualifications, operations,, maintenance, radiological and chemical activities and site technical support;.
Performance evaluations were based on best practices.
Report recommendations,, therefore, are not limited to. minimum safety requirements.
DETERMINATION'ithin.
the scope of'his. evaluation, the team 'determined the plant is being.
safely operated by qualified personneL, The following, beneficial practices and.
accomplishments'were noted o
The station-has,superior outage planning; o
An excellent system for identification and labeling. of plant systems and components was, in use.
o An excellent equipment performance monitoring= and diagnostic testing'rogram was being carried out.
o The station has an'xcellent preventive maintenance scheduling;system;.
o An effective program exists to maintain plant cleanliness.
o An effective technical support organization was observed.
BROWNS FERRY (1981)
Page 2
o An effective program is in use for management of items that require action.
Improvements were recommended for the following conditions:
o Verification of tagout boundaries by individuals performing work is not consistently done.
o The station staff has a tendency to use'informal or ineffective adminis-trative controls rather than incorporate them into procedures and require adherence.
o Some supervisors are reluctant to accept their responsibility to enforce and implement programs and policies.
Recommendations are intended to augment TVA efforts to achieve the highest possible standards in its nuclear. operations.
Cer'tain findings may reflect multiple deficiencies within a particular area.
Therefore, in addressing these findings and recommendations, TVA should look beyond the correction of the.
specific deficiencies and address its corrective actions toward underlying issues.
To follow the timely completion of these responses, INPO requests written notification when improvements are achieved on or before key target dates.
Specific evaluation findings are in the accompanying DETAILS, and information of an administrative nature is in the ADMINISTRATOR; APPENDIX.
These findings. were presented at an exit meeting at'he plant on March 13, 1981, and were further discussed, along with TVA responses, on Nay 22, 1981 in a meeting with TVA management.,
The evaluation staff'ppreciates the exceQent cooperation received from all levels of the Tennessee VaDey Authority.
E. P. Wilkinson President
BROWNS FERRY (1981)
Page 3
RESPONSE
SUMMARY
r TVAappreciates the evaluation of Browns Ferry Nuclear Plant conducted by the Institute of Nuclear Power Operations (INPO).
The evaluation afforded us a perspective of our plant's activities comparative to the INPO criteria and, consequently, the rest of the industry.
We consider the recommendations for improvements INPO has made as objective and with basis, and will take the appropriate actions to implement these recommendations in a timely manner.
It has become apparent to TVA that, in an effort to achieve a high standard in plant operation, plant procedures have been promulgated which are excessive both in number and in detail.
Such an attempt has undoubtedly resulted in more requirements and programs than can be reasonably managed.
TVA recognizes that this approach has created many of its own problems, including a tendency by plant management to use informal and less burdensome controls and a reluctance to enforce adherence to all procedural requirements because of the near impossibility of doing so.
This type of overcommitment and its associated pr oblems wer e confirmed. by INPO's evaluation.
TVA appreciates:
the knowledgeable and practical recommendations made by INPO.
These recommendations have been evaluated and will be implemented as reflected in the foQowing detailed response to specific items.
Recommendations with generic significance will be implemented at'ther plants as aopropriate.
Full implementation, when
- achieved, will further enhance TVA's ability to operate its nuclear power. plants in a safe and efficient manner.
DETAILS BRONNS FERRY (1981)
Page 4 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.
The evalua-tion procedures that were used are listed in the ADMINISTRATIVEAPPENDIX.
ORGANIZATIONAND ADMINISTRATION Seven. performance areas were evaluated using current INPO criteria.
The areas included objectives, organization structur e, administrative
- controls, quality assurance, industrial safety, equipment surveillance and personnel qualifications.
The Browns Ferry organization has many well qualified people and an effective quality assurance program.
In addition, the plant has a good action tracki~
system in operation to keep abreast of its many programs.
Areas where improvements were recommended include performance objectives, organization structure, administrative controls and industrial safety.
OBJECTIVES (INPO Procedure OA-101,, Revision 1)
An evaluation was performed, to determine, how effectively goals and objectives are disseminated throughout all levels of the station and how'ffective they are in, conveying intended operational and maintenance directions.
Areas reviewed'.
include specific goals in use, management goals issued to. all personnel and measurement of goals and, objectives attainment.
Finding (Criteria B and D)
Although a comprehensive, goals, and objectives system that relates.
directly to an'ndividual!s performance appraisal has been established, this program is not effectively implemented.
Specifically, the goals and
'bjectives of'upper and'iddl'e management are not consistently com-municated to lower levels of'the organization.,
R'ecommendation Continue the development of the. goals, and objectives'ystem now in'ffect.
Establish and, implement. a plant'. policy to ensure that goals'nd objectives are communicated to lower levels of. the organization.,
R'esponse The present management appraisal'ystem will be continued
- and, will'nclude plant performance and adherence to requirements-as-part of.'ersonnel evaluation.. This system provides an effective means to ensure managers are aware of their goals and objectives.
A plant policy was-placed in effect July 1',, 1981.
Implementation of this policy will ensure goals and, objectives. of: the plant are. communicated to all levels of the plant organization'..
BROWNS PERRY (1981)
Page 5
ORGANIZATIONSTRUCTURE (INPO Procedure OA-102, Revision 2)
An evaluation was performed to determine if the organizational structure provides the capability of managing Browns. Ferry on a day-tray basis in a safe and efficient manner.
Areas reviewed include the organizational structure and reporting requirements, the establishment of written position descriptions based on job analysis, the use of position descriptions to periodically evaluate each individual's performance, the span of control for plant management positions, the backup capability for plant management positions and the staff size.
Pinding (Criteria B and C)
These criteria were not fully met in that a number of job descriptions provided for station positions were not current or based upon job analysis.
Specifically, qualifications; responsibility, authority and ac-countability in these cases were not site~ecific. It was recognized that a program was in progress to resolve this deficiency.
Note: Similar position description, deficiencies exist in relation to INPO procedures OA-108-and OP-303 and will not be addressed as separate findings.
Recommendation Continue present efforts to upgrade job descriptions for station positions and ensure they are site~ecific..
Response
A position task analysis is currently being performed on selected positions at the plant.
One purpose of this analysis is to determine the correctness. of'ob descriptions..
Based on results of the
- analyses, applicable; job descriptions will be revised..
Task analyses will be completed by January 1, 1982.
ADMINISTRATIVECONTROLS (INPO Procedure OA-103, Revision 1')
An evaluation was performed, to determine the. effectiveness of-the controls for.
administrative functions., Areas reviewed include. completeness, flexibility,level of administrative actions. and effectiveness of the administrative controls program.
Management:
has: implemented; a large-and complex administrative system at.
Browns Ferry; This program. is effective in establishing rules for contro1s to be in place; but it's, difficult for supervisors: to understand-and support.
To help with this problem management'as established additional methods to identify responsibilities by, job or function,. greatly. increasing, the effectiveness of the administrative controls program.
Pinding (Criterion E)
Administrative controls are issued by various means such as section instruction letters, signs requiring actions to ensure industrial, safety and signs requiring use of health physics monitoring equipment.
However; adherence to these instructions is not effectively or consistently re-quired. Additionally, administrative controls sometimes conflict.
BROWNS FERRY (1981)
Page 6
Recommendation Evaluate the issuance of section instruction letters, and the use of signs and re-indoctrinate the staff that adherence to such instructions is required.
An effective mechanism should be established to allow communication from the onwite implementing groups to the offwite-policy-setting groups so that consistency and, efficiency in establishing management policy can be maintained.
Response
We have evaluated the use.of section instruction letters, instructions and use of signs.
These. methods are essential to ensure requirements are implemented at the lowest level of the plant organization.
We will require that each section complete a review of their section instruction letters by July 1, 1981, to ensure they are up-to-date and reflect present requirements.
The requirements for adherence will be covered in safety meetings or special meetings as required and will be completed by Au~st 1, 1981".
The present concept for development of central office procedures is under review.
These procedures willbe revised to eliminate duplication and conQicts and to contain only essential requirements.
We have been using procedure revision forms to communicate between the plant and central office, but'have found them not to be as effective as desired.
A cognizant,'nowledgeable person will be assigned responsibility for each procedure within the division.
This individual will prepare the.
procedure, assist.
the, plant in implementation, provide central office expertise in'the area of the procedure. content and periodically monitor, the effectiveness of'he procedure content if applicable.
This approach should maintain central. office expertise and provide. the plant with a central office contact who is responsible. for the procedure,,
thereby improving communications..
Review and reissuance of central office procedures will be*an-ongoing process and is expected to be completed by June 1982.
- QUALITY, PROGRAMS'NPO Procedure OA-104, Revision.4)
An evaluation was performed.to determine that sufficient monitoring and audit programs were in effect to promote safe, efficient accomplishment. of plant.and organization: missions.
Areas reviewed: included: management controls, approved, quality assurance program, quality assurance organization, selfmuditing capa--
bility, effectiveness-of the program and'corrective actions.
Finding The criteria of OA-104 were'et.
BRONNS FERRY (1981)
Page 7 INDUSTRIALSAFETY
{INPO Procedure OA-106, Revision 1)
An evaluation was performed to determine ifa safe and orderly working environ-ment was provided for station personnel. Areas reviewed included plant commit-ment to safety, attitude toward safety, employees'nvolvement and cooperation in accident prevention, and work practices and safety considerations peculiar to the plant. Determinations were made as foQows:
Finding {Criterion B)
Although a comprehensive standard practice had been published and distributed to department heads concerning safety, hazard control and fire protection, the industrial safety program had not been fuQy imple-mented.
Specifically, the operations department had not conducted weekly safety meetings as required.
In some cases, supervisors had not actively enforced standard practices, and workers had not. followed instructions given in the standard practices document or posted instruc-tions.
Recommendation Management should communicate its commitment to an effective indus-trial safety program throughout the organization. It should emphasize to supervisors that although it is the duty of each employee to work safely and protect himself and equipment, it is the supervisors'esponsibility to ensure that employees obey applicable rules.
This philosophy should be reiterated to employees during weekly safety meetings and suoervisors should'ctively enforce safety rules.
In addition, obsolete signs and conflicting'or inappropriate safety instructions that now-exist should, be removed or revised.
Response
Management willcommunicate its commitment to an effective industrial safety program through safety meetings or special. meetings as required.
This'communication will.emphasize the individual's role in-safety. as well as the supervisor's.
This action willbe completed, by August 1, 1981..
Ne will ensure, each supervisor fully understands that it is his responsi-bility that employees under his supervision obey applicable rules and that his, section has a: system of reporting unsafe acts: or conditions.,
A standard practice stating, this policy has been approved and will be communicated to each employee..
Obsolete signs and conflicting, or inappropriate safety instructions that:
exist wiQ.be r emoved, by July 1, 1981.
SURVEILLANCE; PROGR'A'M'NPO Procedure OA-.10V, Revision 2)
An evaluation'as performed'to determine= that a'urveillance program existed and accomplished the required surveillance inspection and testing.
Areas reviewed included procedures that addressed aQ areas of surveillance, accept-ance criteria, out of range reporting. requirements, timely completion require-ments, management control systems'and actions to correct deficiencies.
BROWNS FERRY (1981)
Page 8
Finding The criteria of OA-107 were met.
PERSONNEL QUALIFICATIONS gNPO Procedure OA-108, Revision 1)
An evaluation was performed to determine if appropriately qualified individuals were available to safely and efficiently operate and maintain the plant.
Areas reviewed included written qualification requirements for each plant staff posi-
- tion, policies for ensuring every position is filled by individuals meeting qualification requirements, and periodic reviews and revisions of these qualifica-tion requirements.
Finding The criteria of OA-108 were met with the exception of Criterion A which was previously identified under Criteria B and C of OA-102.
BROWNS FERRY (1981)
Page 9
TRAININGAND UALIFICATIONS The following areas were evaluated:
training organization and administration,
'raining resources, training effectiveness, licensed operator training and requali-fication, non-licensed operator training and shift technical advisor traininq.
In these
- areas, positive features were noted; specifically, plant training programs are thoroughly developed and well documented.
However, some areas require improvements as identified in the findings below.
TRAININGORGANIZATIONAND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)
\\
An evaluation was performed to determine if the plant has a clearly defined training organization that provides for assignment of responsibility and delega-'ion of adequate authority for accomplishment of all training tasks.
Finding (Criterion B)
No method exists to ensure instructional expertise of the plant instruc-tors.
Recommendation Develop and implement an instructor qualification program for plant instructors.
Response
Division instructions willbe developed and implemented by July 1, 1981, which willestablish requirements for plant instructors and document the qualifications and minimum training requirements for instructors.
TRAININGRESOURCES (INPO Procedure TQ-221, Revision 2)
An evaluation was performed to determine if the plant has sufficient resources, to support'he delivery of'high quality training. to Browns. Ferry personneL Finding:(Reference, Criterion A)
Insufficient classrooms'xist to'acilitate all. training; activities;.
The location of rest rooms with respect to the classrooms is inconvenient;.
Additionally, the licensed operator classroom is subject; to-frequent:
interruptions.,
Recommendation Management should evaluate training facility. needs and, requirements, including classroom facilities, and provide improvements'as necessary.
Response
The need for-additional space for training has been recognized and a
longer ge plan and schedule for new facilities has been developed.
The
BROWNS FERRY (1981)
Page 10 first phase of this program was to begin this year, but it was postponed due to budgetary considerations.
This program will be implemented as soon as budgeting considerations allow, which is currently anticipated to be in October 1982.
We will, by August 1, 1981, improve the present facilities to enhance their usefulness by rerouting traffic to avoid class interruptions, relocat-ing instructor offices and providing more storage space for training materials.
TRAININGEFFECTIVENESS (INPO Procedure TQ-231, Revision 2)
An evaluation was performed to determine if the training provided to plant personnel is effective in meeting training goals and improving operational performance.
1.
Finding (Criterion A)
Systematic evaluations of training programs, using written procedures and conducted by knowledgeable personnel, are not performed.
Recommendation Knowledgeable personnel should periodically evaluate training programs to assess their effectiveness and recommend appropriate-modifications:
to content and format.
Response
By June 1981, division instructions will be implemented that establish a formal review and define required audits of training.
Plant instructions will implement requirements applicable to the training activities con-ducted at the plant.
2.
Finding (General Criterion)
Newly hired maintenance journeymen have no method to develop plant specific knowledge and skills..
Recommendation Develop and implement plant specific training programs for newly-hired'aintenance journeymen..
Response.
A position task analysis is currently being performed on all key mainte-nance positions..
Based on results of this analysis, applicable-training programs willbe implemented.
Task analysis will be completed by January 1982..
At that time a schedule willbe developed to implement training programs.
BROWNS FERRY (1981)
Page 11 NON-LICENSED OPERATOR TRAQGNG (INPO Procedure TQ-242, Revision 2)
An evaluation was performed to determine if an effective program exists to provide initial and continuing training for non-licensed operators to ensure they ar e capable of performing their jobs safely and effectively.
Finding The criteria of TQ-242 were met.
LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)
An evaluation was performed to determine if an effective program exists to provide adequate training to candidates for operator and senior operator licenses to permit them to operate the plant reliably and safely.
Determinations were made as follows:
Finding The criteria of TQ-243 were met.
LICENSED OPERATOR REQUALIFICATIONTRAINING (INPO Procedure TQ-244, Revision 2)
An evaluation was performed to determine if adequate training exists to maintain a high level of knowledge and skill in reactor and senior reactor operators.
Finding (Criterion G)
Oral examinations are not administered as part of the annual requalifica-tion program.
In some
- cases, over sixty percent of the written exam questions are taken from the previous year's test,.
which is made available to the trainees.
Additionally, the same exam is given to, personnel from all, five shifts, thereby increasing the potential for:
compromising the test..
Recommendation Annual requalification examinations should include an oral examination;,
AdditionaQy, written examinations should be conducted in a manner to ensure comprehensive'measurement of each student's knowledge.
Response
We agree with the substance of this finding. Modifications willbe made to the operator requalification program, which will include meaningful oral and visual evaluation of operator knowledge during simulator.
activities.
Additionally, administrative controls wiQ be placed in effect that will better ensure that examinations are not compromised.
These~
actions willbe completed by January 1982.
BROWNS FEKKY (1881)
Page 12 SHIFT TECHNICALADVISOR TRABGNG (INPO Procedure TQ-245, Revision 1)
An evaluation was performed to determine if an adequate program exists to provide the shift technical advisors with initialand continuing training necessary to ensure safe and effective performance of assigned duties.
Finding The criteria of TQ-245-were met.
OPERATIONS BROWNS PERRY (1981)
Page 13 The area of Operations was evaluated using current INPO criteria for performa-ncee in shift conduct, organization and administration, use of procedures, takeout practices, plant status controls, facilities and equipment and shift turnover.
The plant is generaQy clean'a'nd in good material condition.
Also the knowledge level of the shift engineers was impressive.
Improvements should be made in the areas of tagout practices, organization and administration, use of procedures and plant status controls.
These improvements are discussed in detail below.
CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-301,,Revision 2)
An evaluation was performed to determine how effectively the conduct of shift operations maintains quality shift performance.
Areas reviewed included opera-tor activities, station cleanliness and order, response to abnormal conditions, logkeeping practices, reliability of control room instrumentation and operator awareness of plant conditions.
Finding The criteria of OP-301 were met.
TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)
An evaluation was performed to determine if established tagout practices ensure protection for-personnel and station equipment;.
Areas reviewed included senior reactor operator (SRO) approval of safety-related tagouts, double verification of tagged equipment for personnel safety, double verification of important manual valves that are repositioned, tag coloring and numbering and clearance lo s.
Determinations were, made as follows:
1'..
Finding (Criterion E)
Tagout status is not verifi'ed by persons responsible for work on, the tagged out equipment before beginning work.
Recommendation Revise-instructions to require persons responsible for performing the work to separately verify all or part of the. lineup as necessary to ensure that adequate steps have been taken to provide for the safety of their workers., Train and enforce as necessary to ensure that instructions are understood and followed by maintenance personneL
Response
We will r~mphasize, during routine safety
- meetings, the safety re-quirements for personnel'erforming work on equipment involved in a.
clearance.
This, training willbe-completed by August 1, 1981.
20 BROWNS FERRY (1981)
Page 14 Finding (Reference Criterion F)
Tags on control room consoles were observed to obscure labels, valve position indicators and switch positions.
Plant management had recog nized this situation and was investigating the use of smaller sized tags for control room consoles..
Recommendation Proceed with the current investigation and implement the use of a smaller tag for the control room consoles to prevent obscuring labels, valve position indicators and switch positions.
Response
Evaluation of the use of smaller tags will continue.
A practical alternative willbe implemented by August 1, 1981.
3.
Finding (Reference Criterion G)
Tagout audits or an assessment of the status of tagouts was neither requu ed nor conducted..
This situation has been r ecognized by manage-ment and a revised clearance procedure requiring tagout audits has recent1y been completed.
Recommendation Implement the revised clearance procedure that requires periodic audits of the status of tagouts, including tag attachment and lineup status.
Operations supervisors should review the tagout status..
Response
Plant instructions have been revised and issued to require periodic audits of the status of outstanding clearances.
ORGANIZATIONAND ADMINISTRATION (INPO Procedure. OP-303, Revision 2)
An evaluation was performed to determine the existence of a clearly defined operations organization that provides for the assignment of responsibilities and'he delegation of adequate authority for accomplishment of required tasks.
Areas reviewed include organizational'tructure, job descriptions, shift admin-istrative assignments,. written and,oral instructions and orders; and miscellaneous:
administrative programs.
Finding (Criterion-F)
Based on the data provided,. the amount of overtime worked by unit.
operators and assistant unit operators appears excessive.
This data was in the form of'vertime hours-paid and not actual overtime hours worked.
Actual hours of overtime. worked,was monitored by sections on a weekly basis, but no actions indicating attempts to reduce overtime were evident.
Recommendation Determine'and correct the cause of excessive overtime incurred by unit'perators and assistant unit operators.
Implement a program to monitor actual overtime worked and prevent excessive overtime on a long-term basis.
BROWNS FERRY (1981)
Page 15
Response
The requirements placed on operators will be reviewed, and an assess-ment will be made of the present staff's ability to satisfy these requirements by August 1981.
As a result, necessary changes will be made to reduce overtime.
USE OF PROCEDURES (INPO Procedure OP-304, Revision 2)
An evaluation was performed to determine proper use of procedures to conduct plant operations safely and reliably.
Areas reviewed included management f
d h
e of procedures (short-term and long-term).
in addition, of "se uence procedures were reviewed, for clarity, continuity, rdentif<cation o
seq required" actions and suitable advisory information.
Finding (Criter ion A)
The excessive number of emergency operating instrucbons prec u es e
practicality of memorization of emergency immediate operator actions.
r tin-Take action to reduce the excessive number of emergency opera ing-instructions which require. memorization.
In doing so, consider consoli-dat' to one administrative procedure the requirements for use of procedures currently found in sections of several administrative proce-dures and operating instructions.
Response
We will review our emergency operating instructsons and the requir
~
~
~
~
ments for immediate action by August 1, 1981.
From this review, and from efforts we are currently engaged in with the GE Owners'roup, we
'll tak ti to reduce to a manageable number the items that 982.
require memorization.
These actions wiQ be completed by January 1
PLANTSTATUS'ONTROL (INPO Procedure OP-305, Revision 1)
An evaluation was performed to determine if plant status controls are provided to ensure adequate equipment and system avaQability; Areas. reviewed include management programs and policies that provide guidance for status control; tus t
1 al t',
status control responsibilities of senior licensed operators assigned to monitor and review status control; and provisions for sta con ro under special conditions such as outages, accident recovery or refueling.
Finding (General Cr iterion)
A roved rocedures and policies were not in effect to prevent the use of uncontrolled instructions; notes or drawings attache p
pp rove proc d to lant com-ponents or consoles.
BROWNS FERRY (1981)
Page 16 Recommendation Develop and implement a policy to prevent the use of uncontrolled instructions, notes or drawings attached to plant components or consoles.
Response
Adequate controls have been placed on the use of temporary notes and drawings attached to plant components and control boards.
OPERATIONS FACILITIESAND EQUIPMENT (INPO Procedure OP-306, Revision 2)
An evaluation was performed to determine if plant facilities and equipment are operable and if they are maintained in a manner that ensures safe and efficient operation.
Areas reviewed included equipment operability, equipment availabil-ity program(s), effect of the working environment on safe and efficient station operation, adequacy of communication equipment and shift station assignments.
Firiding The criteria of OP-306 were met.
SHIFT'TURNOVER.
(INPO Procedure OP-309, Revision 2)
An evaluation was performed to determine if continuous, correct understanding of station conditions are maintained at all shift positions.
Areas reviewed included programs and policies controlling turnover practices for shift stations, checklists, operating panel reviews and station activities in progress or planned.
Finding The criteria of OP-309 were met.
BROWNS FERRY (1981)
Page 17 MAIN'rENANCE The maintenance organization, preventive maintenance
- programs, mamtenance ures and administrative systems for controlling and documenting mainte-m thods used to control and calibrate t
d the overall adequacy of maintenance facQities e activities were examine e me
~
~
measuring and test equipmen an e
and equipment were also evaluated.
Within the scope o
is ev f th'luation it was determined'hat an effective e
maintenance program exis s.
xc Excellent programs weie noted for performanc
~
~
monitoring, diagnostic testing and scheduling of preventive maintenance.
Speci ic areas w
'f as where improvements could be achieved are noted in the following discussions.
MAINTENANCEORGANIZATIONAND ADMINISTRATION
{INPO Procedure MA-401, Revision 2)
A aluation was performed to determine if the Mechanical, Electrical and Instrument Sections were organized to accomplish r q
'n ev ua ion e uired maintenance tasks.
f b tween these groups and other organizations was also examine The inter ace e
een e
Other areas reviewed included organizational documenta, p
tion (charts osition descriptions, assign
'i assignment of responsibQities),
administrative programs an'd ad-ministrative clerical work load.
Pin+< c (Criterion B)
~
~
~
Responsibilities assigne o
'lit'dto the Mechanical and Electrical. Maintenance su orted b
the Sections'ngineering staffs cannot be adequately suppor e
y
'd d M
- y. tasks assigned to these staffs weie deferred manpower provi e.
any.
authorized or delayed.
It is noted that the mechanical staff'has the au number of personnel, while the electrical staff is short two of six engineers authorized.
Recoinmendation Evaluate responsibilities assigned versus staff provided and make pp e a ro-priate adjustments to achieve a balance.
Response
~
An evaluation of requirements versus resources is n p gr is i ro ess and willbe compe e
y 1 t d b October 1981'.
As stated in the response to OA-,103, central office procedures wQl be revised to contain y.
nts.
Also as part of this effort, the impact on plant personnel of implementing new requirements will. be. evalu resources.
are available or are provided prior to promulgation of the requirements.
VKIJWL'IDL'all,a,x gxvoxg Page 18 PREVENTIVE MAINTENANCEPROGRAM (INFO Procedure MA-402, Revision 1)
An evaluation was performed to determine if preventive maintenance (PM) activities are being performed and whether a weH&efined and effective program is in place.
The administrative procedures governing the program and the plant organization established, for implementation were also examined.
Other areas included criteria used to define the equipment included in the program, the use of equipment history files in conjunction with the program, the adequacy of individual PM procedures and inspection frequencies.
Pinding The criteria of MA-402 were met.
MAINTENANCEPROCEDURES (INPO Procedure MA-403, Revision 2)
An evaluation was performed to determine the existence and adequacy of maintenance procedures and vendor manuals for safetyweiated and critical balancemf~lant work activities.
Procedures and manuals were examined to determine the type of activities covered,
- scope, level of detaQ, review and approval cycle, document control requirements and methods of revision.
An evaluation was also made of the effectiveness of procedures in controlling and documenting work and inspection activities.
Pinding The criteria of MA-403 were met.
WORK CONTROL SYSTEM (INFO Procedure MA-404, Revision 1)
An evaluation was=performed of the administrative mechanism used for identi-fying and. reporting equipment problems.
The evaluation was also performed to determine if the work control system was effective for planning and document-ing the completion of maintenance work. Specific areas included the administra-tive procedure for requesting corrective maintenance and those provisions in the system relating to planning, authorizing and documenting the work. In addition, observations were made of actual work in progress.
Pinding (Criterion 8)
Several.key elements in the review and planning process and in the documentation of completed work were not fullyeffective; they are:
o Opportunity for Quality Group review was not ensured prior to the start of safety-related jobs.
BRONNS FERRY (1981)
Page 19 o Responsibility to determine whether the proposed work constituted a
design change or modification was not specifically assigned to anyone in the review cycle.
o Planning for non~utage corrective maintenance was limited and did not include estimation of. man-hours required.
o Completed work records did not include man-hours expended.
Recommendation Modify the review process for trouble reports to provide a positive measure to ensure QA is afforded an opportunity to review each safety-related job prior to commencement.
Assign specific responsibility to an appropriate individual in the review process to determine whether or not the proposed work constitutes a design change or modification.
Modify planning efforts and documentation of non-outage work to include job-specific estimated and actual man-hours.
Response
The maintenance work request program is being revised to include a determination of need for quality review.
This program will be imple-mented by January 1982.
Implementation of the revised work request program will fix responsi-bility for determination that a work activity may constitute a design change.
A system of cost control based on activities-is being developed to provide time spent'or each activity associated with a job.
Once implemented, the actual versus estimated man%ours can be factored into the planning process.
This program is. expected to be in place by January 1983.
MAINTENANCEHISTORY QNPO Procedure MA-405', Revision 2)
An. evaluation was performed to determine if complete, functional maintenance.
history records were being retained and used in the evaluation of equipment performance.
Specific areas of interest include the amount and types of equipment included in the program; type, level of detail, traceability and:
retrievability of records; methods used for review and evaluation of maintenance histories;. and assignment of responsibility for. implementing'the program.,
Pindhg (Criteria D and E)
Although functional maintenance histories were being maintained,
- the,
'aintenance History Programs for the Mechanical and Instrument Sec-tions were not defined.. Periodic reviews of these sections'aintenance histories were not required or'conducted..
Recommendation Describe the Maintenance History Programs that are in effect or willbe implemented in the near future by an appropriate procedure.
Develop guidance requiring periodic reviews of maintenance and specifying. the scope and methods to be used.
BROWNS FERRY (1981)
Page 20
Response
Plant instructions will be issued by October 1,
- 1981, describing the implementation of a maintenance history records program for all plant maintenance sections.
CONTROL AND CALIBRATIONOF TEST EQUIPMENT AND INSTRUMENTATION (INPO Procedure MA-406, Revision 1)
An evaluation was performed 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.
It was noted that almost all calibration activities were performed offwite. No offwite evaluation was conducted.
Finding (Criterion F)
Uncontrolled and controlled test and measuring equipment were not segregated in the Mechanical Maintenance Section tool room.
Similarly no~ontrolled equipment was stored on the same shelf in a locker designated for controlled tools only.
Recommendation Segregate controlled,and uncontrolled test equipment.
Response
This condition has been corrected, and section supervisors will review applicable requirements with their employees.
Segregation of measuring and test equipment located-in the Mechanical Maintenance Section tool room willbe checked on a periodic basis.
MAINTENANCEFACILITHBAND EQUIPMENT (INPO Procedure MA-408, Revision 1)
An evaluation:
was-performed to determine the adequacy and condition of maintenance facilities and equipment;. the location, size, and condition of office, work and storage areas were examined,, along with the, quantity, type,, condition and location of maintenance tools and equipmept.
Finding (Criteria B and C)
Adequate maintenance tool storage was'not available for the Mechanical and Electrical Maintenance Sections.
Both tool rooms are too small to effectively accommodate the. quantity of tools and supplies currently stored, in them.
Additionally, adequate maintenance workshop areas were not available for the Mechanical or Electrical Sections.
The mechanical workshop
BROWNS FERRY (1981)
Page 21 area is congested and many instances of job interference were observed.
The electric workshop area is too small and its use is primarily limited to serving as a staging area.
I It was noted that a new facility is in the preliminary planning phase.
Recommendation Continue with plans for the new facBity.
Based on the time frame for completion of the new-facility, consider the need for additional interim workshop and tool space.
Response
Development of new plant facilities is essentially complete and money has been funded for a preliminary design.
We have previously reviewed interim workshops and tool spaces for maintenance personnel and found that no other area is satisfactory due to various reasons.
We willlook at other means such as shift work to help reduce the congestion in the shops.
We willcomplete this review by August 1, 1981.
BROWNS FERRY (1981)
Page 22 RADIATIONPROTECTION AND CHEMISTRY Organization, administration, radiological protection, liquid waste control and process water chemistry were evaluated usihg current INPO criteria.
This portion of the evaluation was primarily an examination of plant programs and facQities as they function under normal operating {nonmutage) conditions.
It was concluded that the plant's radiation protection and chemistry programs were being conducted in a manner which provided for sufficient controls to protect the public, plant workers and the erivironment.
RADIATIONPROTECTION AND CHEMlSTRY ORGANIZATIONAND ADMWLSTRATION (INPO Procedure RC-501, Revision 1)
An. evaluation was performed to determine the effectiveness of the radiation protection and chemistry organizations and their associated administrative control mechanisms in providing the level of services currently required at the plant under normal operating conditions.
Areas reviewed include the formal organization structure, procedures for conduct of operations, staffing-levels, training and retraining programs, position descriptions and management author-ity.
1.
Finding (Criterion D-Training and Retraining)
The health physics technician training program was not effectively-implemented.
Interviews with health physics, personnel indicated train-ees were not receiving direction while completing the in~lant, section of the formal program.
In addition, no formal retraining program for the health physics staff was available. It was noted that the plant had made
~ plans to implement a retraining program during the first.quarter of 1981.
Recommendation It is recognized that TVA has committed significant resources to the training.of health physics technicians; however, particular emphasis must be placed on the in-plant section of the formal training, program.
Trainees.should be given. direction by the appropriate level of supervision to ensure that the ~lant, section of the training program is, effectively'mplemented.
The retraining program, if implemented's planned; appears= adequate to maintain the technical capabilities of the health physics staff.
Response.
A revision of the health physics technician training and'etraining program has been under development for the past six months.,
The revision will include emphasis on supervisors'esponsibQities-for in~lant training and willbe implemented by June 30,':1981.
2.
Finding (General Criterion-Radiation Protection-Procedures)
Radiation protection procedures should be kept current, reflect actual.
practices, be used effectively to implement policies and programs and be readily available to health physics personneL
DllV'Ilgwu~ ~
Page 23 It was observed that the various administrative and working-level procedures and instructions that describe and/or implement the utility and plant radiation protection programs were not being effectively maintained or used.
Recommendation It is recognized that the plant has initiated a comprehensive review and rewrite of the existing plant-level radiation protection procedures.
Although this should result in considerable improvement in the technical content of these procedures, it willnot correct some of the underlying deficiencies in procedure maintenance and use.
The foQowing additional action is recommended:
o Wherever
- possible, the number of intermediate administrative procedures should be reduced.
o Controlled copies of procedures should be maintained in appropri-ate offices and work spaces.
Supervisors and technicians shou)d be encouraged to use these procedures.
o Adherence to procedures and instructions should be strictly en-forced.
If adherence to a particular procedure proves to be impractical, then the procedure should be revised.
o Responsibility'for the long term review and maintenance of each radiation protection procedure should be assigned to appropriate staff members, based upon subject matter.
Response
We will review and revise all of the health physics procedures to mak~
them consistent and more usable.
Also,. controlled copies will b maintained properly.
We are also r~mphasizing strict adherence t
these procedures.
We plan to finish this effort by June 1981.
Responsi bility for long-term review and maintenance of these procedures he been assigned.
ALARA PROGRAM'NFO Procedure RC-602, Revision 1)
An evaluation was performed to determine the effectiveness of efforts towar maintaining personnel occupational radiation exposure as low as is reasonat achievable {ALARA)at the plant.
Areas of interest included the ALARApoli~
responsibilities for. ALARA,,levelof review for the ALARAprogram, systems
'etting goals and measuring-progress and overall scope of ALARAactivities.
A formal ALARA.program had been established, but. it, was not fully imp mented.
The-program contained the key elements for. an excellent ALA program.,
BROGANS FERRY (1981)
Page 24 1.
Finding (Criterion D-ALARAGoals)
ALARA goals are established for outage periods in most cases, but not for routine operation and maintenance.
In addition, the plant is unable to monitor real-time exposure of jobs in progress or to retrieve, in a reasonable time, quantitative exposure data by specific job.
Recommendation Expand the existing ALARAprogram to include a system for retrieving exposure data in a timely. manner in order to measure the success in achieving ALARA goals.
(See the recommendation for the personnel dosimetry finding in this evaluation report.)
In addition, a system for initiating corrective measures when goals are not met should be imple-mented.
Response
A review of causes of and possible solutions to this problem wiQ be conducted and completed by January 1982.
As a result, an action plan to implement a system for retrieving exposure data in a timely manner wiQ be developed.
Additionally, a system for initiating corrective measures when goals are not met wiQ be implemented.
2.
Finding (Criterion E-Scope of ALARAProgram)
The ALARAprogram had not been effectively implemented with regard to routine plant operations and maintenance.
Recommendation Revise existing procedures to include routine operation and maintenance activities in the ALARAprogram.
Expanding the ALARAprogram will assure plant management that workers are using the best avaDable work practices. and that aQ work-is supervised to the, extent necessary to achieve ALARAgoals.
Response
A review of causes of and possible solutions to this problem will be conducted and completed by January 1982.
As a result, an action plan to implement a system for retrieving exposure data in a timely manner will be developed.
Additionally, a system for initiating corrective measures when goals are not met wiQ be implemented.
PERSONNEL DOSIMETRY
'INPO Procedure RC-503,,Revision 1)
An evaluation was performed to determine the effectiveness of the plant's dosimetry program in measuring; evaluating and recording occupational radiation exposures.
Areas. examined included. the scope of. the dosimetry program, procedural controls, dosimetry selection and use, system operation and exposure records.
Finding (Criterion. D-Dosimetry Quality Controls)
Deficiencies were present in the quality controls for the dosimetry program.
Systems were being, operated in a manner which unnecessarily increased the potential for loss of data and/or misinterpretation of dosimetry results.
BROWNS FERRY (1981)
Page 25 Recommendation Actions should be taken to coordinate Thermoluminescent Dosimeter (TLD)/Direct Reading Dosimiter (DRD) comparison methodologies so that meaningful conclusions regarding the accuracy can be reached from the comparison.
~
As a part of this effort, mechanisms should be established to,investigate and resolve abnormal TLD/DRD variances.
Additionally, the whole body counting systems should be formalized so that counting data is reliably screened and the data base is consistent and accurate.
Response
An evaluation of the effectiveness of the current personnel dosimetry program will be conducted and a
course of action determined, by October 1, 1981.
This evaluation wQl encompass TLD/DRD comparison methodologies and variances, DRD calibration and calibration check policies and whole body counting data.
RADIATIONSURVEILLANCEAND CONTROL (INPO Procedure RC-504, Revision 1)
An evaluation was" performed to determine the effectiveness of the plant's radiological surveillance program and radiological work control-mechanisms in identifying radiological hazards to workers and management and in minimizing the magnitude of these hazards.
Areas of interest included surveillance program procedures, surveillance program
- scope, radiological conditions in the plant, surveQlance methodology; the level of management review of surveillance data and the controls placed upon access to and work in areas with known or potential radiological hazards'inding (General Criterion-Personnel Controls)
Reasonable controls. should be established and enforced to prevent unnecessary exposure of personnel to radioactive materials through ingestion, or inhalation.
Contrary to this generally accepted
- practice, eating, drinking; smoking and chewing were-permitted in radiologically controlled, areas of; the phnt (exclusive of posted contamination areas).
Butt&its (ash trays) and spittoons were provided throughout the:reactor building and. turbine; building..
Water cans were also provided on each level of these buildings.
Personnel were observed to be smoking and eating in the heal'th physics lab immediately adjacent to radioactive sample counting. stations.
Recommendation:
Eating; drinking, smoking and chewing should be prohibited in radiologi-cally controlled areas.
This includes the turbine building,. the reactor building, radwaste and. laundry handling areas, labs containing radio-active material and off~as treatment ar'eas.
As a, convenience
- feature, smoking and drinking may be permitted in selected break areas within the major buildings provided that these-areas are strictly controlled and closeIy monitored.,
BROWNS FERRY. (1981)
Page 26
Response
Eating and drinking (from other than specially provided and monitored water dispensers) in the radiologically controlled areas are prohibited.
Smoking and chewing have been aDowed in the regulated areas but not the contaminated areas.
Additional administrative controls which will alleviate potential contamination problems will be evaluated and imple-mented by September 30,.1981.
WASTE AND DISCHARGE CONTROL (LIQUID)
(INPO Procedure RC-505, Revision 2)
An evaluation was performed to determine the effectiveness of the plant's liquid waste control programs in minimizing the generation of liquid radioactive waste (radwaste) and limiting releases to levels as low as is reasonably achievable (ALARA). The program elements reviewed included procedures, effluent moni-toring system design and function, clean systems sampling, training and radwaste management methods.
The plant was effectively controlling the generation, processing and release of liquid and solidified radwaste.
Findhg The criteria of RC-505 were met.
RADIOLOGICALSURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2) 4, An evaluation was performed to determine the effectiveness of the'lant's.
radiological survey equipment control and calibration prograni in maintaining a.
sufficient inventory of instruments and a-high degree of accuracy for. the.
radiological measurements made with these instruments.
The evaluation covered procedures; storage,,
reference standard
~ traceability, operational response checks, equipment identification and evaluations for out-,of-tolerance equipment.
The evaluation'as performed. at the: plant site and at an offwite,.
central'nstrument calibration and repair facility operated by the utility.
Finding (General Criterion-Calibration and Check Methods)
The techniques employed for calibration and operational response check-ing of radiation protection instrumentation should ensure that the.
instruments will perform with the best possible accuracy and precision under normal use conditions. It'as found,however, that the-methods.
employed for calibration and performance testing of radiation protection, instruments were not appropriate for the applications of the-instruments.,
o Source Check Reference Values The nominal (reference) values selected as the control limits for.
radiation survey instrument source checks were. not based upon either reference standard assay results or upon initial checks
BROWNS FERRY (1981)
Page 27 performed for each calibrated instrument.
The bases for the nominal values were not documented.
The preselected nominal values. were not required to be recalculated or reverified periodi-cally to account for source decay.
Beta Standardization'on chamber instruments used for beta radiation surveys were not standardized against a
beta radiation source.
- Generic, non-instrument specific correction factors were specified in proce-dures, but were not supported by test results.
o Pancake Probe Efficiency Checks and Source Checks Pancake GM probes used on friskers were not cheeked at any time with a known radioactive standard to verify that the probes exhibited the minimum efficiency required for contamination monitoring.
In addition, the sources used to perform qualitative response checks on friskers were representative of activity levels exceeding the plant contamination limit by a factor of 16,000.
These source checks were, therefore, not appropriate for verifica-tion of minimum required frisker sensitivity.
o Inadequate Radiation Standard The Cs-137 well source used for calibrating radiation survey instruments has a maximum output of 80 R/hr. and therefore is not capable of delivering the exposure rates necessary for calibration of high range portable instruments.
Eberline Model 6112'Teletec-tors. were being calibrated on this well source, but no use limita-tions were imposed on the instruments for surveys on the 1,000 R/hr scale.
Recommendation The, following action should be'aken with respect'o the specified deficiencies:
o Source Check Reference Values Obtain nominal (reference) values-for each individual instrument foll'owing each calibration,", in accordance: with Section 4.6 of ANSI:
N323-1978, "Radiation Protection Instrumentation Test and Cali-bration."
or Obtain reference values for each instrument model by averaging the responses of several newly calibrated'nstruments.
Repeat this'etermination for each instrument model at a frequency such that check source activity changes by less than 2 percent between determinations.
o Beta: Standardization As a minimum, beta correction factors should be determined for each instrument model using appropriate beta radiation standards.
The beta correction factors should be verified or redetermined.
each time an individual, instrument is recalibrated.
BROWNS FERRY (1981)
Page 28 o
Pancake Probe Efficiency Checks and Source Checks As a part of calibration, each frisker's pancake GM probe should be efficiency checked. with an appropriate radioactive standard (pre-ferably low activity, at or below mid-rana,e of frisker readout).
In addition, all replacement probes should be simQarly checked prior to or immediately after installation on a calibrated frisker. Source checks performed on friskers should utilize a planchet source with activity levels at or near the plant's surface contamination limit.
o Inadequate Radiation Standard Upgrade the well source to produce exposure rates of at least 750 R/hr ahd preferably above 1,000 R/hr (to check instrumentation for saturation conditions at on~cale exposure rates).
Alternatively contract calibration services from a vendor or university capable of providing the proper exposure rates.
In the interim, Teletectors should be labeled with use limitation precautions that state that the 1,000 R/hr range has not been calibrated.
Response
o A procedure to cover checking and documenting the information for the plant response check sources willbe issued by July 1, 1981.
Copies of documentation willbe provided to the plants.
o The Laboratory Services Branch (LSB) does not currently calibrate or provide correction factors for instruments which have both beta.
and gamma capabilities.
As soon as LSB can obtain the proper sources for this work, it will provide this information with each instrument.- Estimated completion is January 1982.
I o
We wQl procure and use the recommended, source by September 1,
1981.
o An evaluation of present calibration reliability will be. conducted by September 1, 1981. If calibration of these instruments at the upper end of'he= 1,000 R scale is determined to be necessary, calibration to fullscale wi11 be per formed.
PERSONNEL HEALTHPHYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2)
An evaluation was'performed'to determine the effectiveness of the plant's health physics-indoctrination program in informing personnel, of the risks associated with radiation exposure and methods for minimizing exposure.
Areas reviewed include management policy, scope and depth of the indoctrination, the training, environment and training documentation..
BROWNS FERRY (1981)
Page 29 The health physics indoctrination is presented as a part of general employee training and consists of videotape presentations supported by instructors.
In
- addition, personnel who will work in radiologically controlled, areas during outages are given the opportunity to practice and demonstrate proficiency at donning and removing antimontamination clothing, reading pocket ion chamber dosjmeters and frisking under the supervision of an instructor or a member of the radiation protection group.
Taken as a whole, the indoctrination program was structured and conducted in a manner that achieved the objective of preparing personnel to work in radiologically controlled areas of the plant.
Finding The criteria of RC-507 were met.
PROCESS MATER CONTROLS (INFO Procedure RC-508, Revision 2)
An evaluation was performed to determine the effectiveness of plant process water controls in maintaining the integrity of plant systems.
Areas reviewed included procedures, laboratory quality control, bulk chemical,, cleaning agent and reagent control, training and systems chemistry.
Process water controls appeared to be effective in minimizing corrosion.
The chemistry group was well organized and functioned smoothl.
Finding
~
The criteria of RC-508 were met.
HEALTH.PHYSICS FACILITIESAND EQUIPMENT (INPO Procedure RC-509, Revision 2)
An evaluation was performed to determine the effectiveness of the plant's health physics facilities and equipment in satisfying plant needs and in contributing; to-.
safe and efficient plant operation..
Areas evaluated included. the number.'and'ypes of instruments and. equipment,,
the protective cl'othing inventory,, the.
design and working, environment of facilities and the ease of access to and physical conditions of radiologically controlled areas.
, Radiological conditions and cleanliness of controlled areas were observed to be very good; it-was evident. that an effective program for, decontamination and cleaning was in place.
1.
Finding, (Criterion A-Instrument Inventory)
The inventory of portable radiation survey instruments was not appropri-.
ate for the type radiation surveys performed at the plant.
iVIanage'ment controls over instrument'selection, repair and replacement were inade-quate.
o Improper Mix of Instrument Types BROWNS FERRY (1981)
Page 30 Too much reliance Was placed upon ion chamber type instruments.
Statemf-thwart GM type survey instruments were not included in the inventory.
There was an insufficient number of operable high-
- range, extendabl~robe type GM survey instruments available.
The improper mix in types of instruments resulted in the use of ion chamber instruments for surveys for which they were not suited by design (e.g., hot spot surveys and outdoor radwaste vehicle sur-veys).
When operations or maintenance personnel required a survey instrument, they were routinely issued the least reliable type of ion chamber instrument in the inventory.
o Excessive Number and Age of Instruments The instrument inventory of certain types was excessively large and contained an abnormally high percentage of inoperable instru-ments.
The average age of instruments was such that excessive costs may have been incurred in instrument repairs and repair parts stocking.
Recommendation It is recognized that the utility has recently organized an instrument committee to review instrument types and recommend instrument pur-chases.
This committee or other management should take action, as follows, with respect to the specific items in the finding.
o Improper Mix of'Instrument Types Staff-.thwart GM type survey instruments should be. purchased and incorporated in the survey programs.
The. number of operable, extendable~robe type instruments should be increased by improved maintenance, extension of the calibration period (currently these instruments are calibrated monthly), and/or purchase of new in-struments.
o Excessive Number and Age of'Instruments Criteria should be established fbr deciding whether to repair or scrap inoperable instruments.
Instruments that are not cost effective should be retired from the inventory.
Response
o New. instruments: have been ordered that, are more appropriate for.
the surveys:conducted'by the'perators. to whom the instruments are-assigned.
The instruments will.be placed in service as soon as they'r,e received.
o We are working to establish better controls for instrument selec-tion,, repair and procurement.
An instrument oversight committee has been established to review this effort.
The initial review should be completed by July 1, 1981, and an ongoing program of periodic reviews will,be established.
BROWNS PERRY (1981)
Page 31 Finding (Reference Criterion C-Inefficient Facilities)
Inefficiencies existed in the design and working environment of respira-tor cleaning and maintenance facilities and the chemistry counting room.
o
'Respiratory Protection FacQities The respirator monitoring, testing and maintenance station was too small to adequately serve its intended purpose.
In addition, it was isolated from other related respirator work stations (storage, issue and cleaning locations) resulting in inefficiencies in conduct of the respiratory protection program.
o Chemistry Counting Room The chemistry counting room was not equipped with the appropri-ate environmental control systems, electrical supply systems and instrument cabinets/racks to support the compute~ased counting equipment which was in use in the room.
Recommendation.
o Respiratory Protection Facilities The area devoted to respirator monitoring, testing and mainte-nance should be enlarged.
New cleaning equipment should be installed in close proximity to the monitoring station or the monitoring station should be moved closer to the existing cleaning facilities. The utility should evaluate the installation of a respira-tor cleaning and maintenance package that would combine all of the necessary functions into a single, efficient facility.
o Chemistry Counting Room
~ Increase capacity of existing air conditioning units or install separate instrument environmental enclosures.
Upgrade the elec-trical supply system to protect counting instruments from voltage surges.
Provide battery backup for the disc drive units.
Organize the NIM-bin based instruments and other computer equipment in standard instrument racks to save space and protect the equipment from damage.
Response
. o We agree that the. area should be enlarged..
Correction of'his problem willbe part of'he actions referred. to in response to. TQ-
, 221.
0'hemistry counting room air conditioning,, electrical supplies; and equipment organization. will be evaluated and action to correct deficiencies noted willbe initiated by July 1, 1981..
RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
BROWNS FERRY (1S81)
Page 32 An evaluation was performed to determine the effectiveness of the plant's respiratory protection program in protecting personnel from airborne hazards.
Areas reviewed include policy and pracedures,.identification and control of airborne hazards, selection and use of respirators, respirator maintenance and emergency capabilities.
The plant program was judged to be adequate for the protection.of personnel from known hazards.
Finding The criteria of RC-511 were met.
4
TECHNICALSUPPORT BROWNS FERRY (1981)
Page 33 On-site engineering support was evaluated in accordance with current INPO criteria.
The Results Section was found to be well organized'and effective in providing engineering support for the plant.
In addition, the Outage Group is effectively managing the numerous additions and modifications to the plant which are currently in progress.
It was found that improvement should be made jn the area of temporary alterations.
TECHNICALSUPPORT ORGANIZATIONAND ADMINISTRATION
{INFO Procedure TS-701, Revision 1)
An evaluation was performed to determine that onwite technical support is effectively organized and adequately staffed.
The capability to perform all assigned duties and responsibilities, along with a thorough knowledge of them, and training to enhance engineering skills were examined.
Finding The criteria of TS-701 were met.
ENGINEERING SUPPORT QNPO-Procedure TS-702, Revision 1)
An evaluation was performed to determine that onwite engineering, support func--
tions are provided in a clearly defined and effective manner.
The activities of the Engineering and Test Unit were evaluated regarding plant performance monitoring and reporting of data and test results.
Communications of the Results Section with other support groups providing engineering assistance to the plant'were examined.. The control of documents and the adequacy of'engineering support facilities were also evaluated.
Finding The criteria-of'TS-702 were met.
NUCLEAR OPERATING'XPERIENCE EVALUATIONPROGRAM.
QNPO Procedure TS-703, Revision 1)
An evaluation was. performed to determine-that all operating experiences are evaluated and appropriate. actions taken.
It was found that operating experi--
ences. occurring at Browns Ferry are reviewed by experienced technical person-neL Finding The criteria of TS-703 were met.
BROWNS FERRY (1981)
Page 34 PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 1)
An evaluation was performed to determine if plant modifications are imple-mented in a timely manner while maintaining the quality of plant systems, structures and components.
The list of all plant modifications was found to be lengthy and date back to the early years of plant operation.
This is due to the commendable TVA policy of encouraging the proposal of aQ potential plant changes so they may be formally reviewed for possible inclusion in the modification program.
Modification work coordinated and completed by the on-sjte Outage Group was found to be well organized.
1.
Finding (Criterion F)
Although temporary alterations are reviewed by the Plant Operations
'eview Committee, no provision currently exists to require that tempo-rary alterations be included in the permanent plant modification process after a reasonable time interval.
A 70~age typed listing of temporary alteration control items dating back to 1976 is in effect't present.
Even though the list is reviewed periodically, temporary alteration status may not be appropriate after a change has been in effect and in use for several months.
Recommendation Review the Temporary Alteration Control L'ist and delete those items not necessary for normal operation; For all others which may be characterized as permanent in nature, Design Change Requests should be prepared so that they may be reviewed in accordance.
with the. plant.
modification process.
Response
We have had a program of continual review-of temporary alterations in effect over a year and have assurance no alteration compromises safety.
comprehensive list has been developed for Plant Operations Review Committee review and efforts initiated to clear all temporary altera-tions practicaL We will put a greater effort in future reviews on evaluating whether temporary alterations can be made permanent.
ON~E REACTOR ENGINEERING (INPO Procedure TS-'705, Revision 2)
An evaluation was performed to determine that reactor engineering support is provided during-all'odes of reactor operation.
The Reactor Engineering Unit was evaluated to assess the use of'appropriate procedures, computer programs.
and changes to them, and'he communication with other groups who coordinate with the on-site reactor engineers.
The dedication to maintenance of fuel'clad integrity and the involvement of the group in refueling; activities were also examined.
Finding The criteria of-TS-705 were met.
ADMINISTRATIVEAPPENDIX BROWNS FERRY (1981)
Appendix Page 1
LISTING OF AREAS EVALUATED OA-101 OA-102 OA-103 OA-104 OA-106 OA-107 OA-108 ORGANIZATIONAND ADMINISTRATION Objectives Organization Structure Administrative Controls Quality Programs Industrial Safety Surveillance Program
'ersonnel Qualifications TQ-211 TQ-221 TQ-231 TQ-242 TQ-243 TQ-244 TQ"245 TRAININGAND UALIFICATIONS Training Organization and Administration Training Resources Training Effectiveness Non-Licensed Operator Training Licensed Operator Training Licensed Operator Requalification Training Shift Technical Advisor Training; OP-301 OP-302 OP-303 OP"304 OP-305 OP-306 OP-309.
OPERATIONS Conduct of Shift Operations Tagout Practices Organization and Administration Use of Procedures Plant Status Controls Operations FaciTities and, Equipment Shift Turnover M'AINTENANCE MA-401 Maintenance Organization and Administration M'A-402 Preventive Maintenance Program MA-403 Maintenance Procedures.
MA-.404 Work Control System MA-405 Maintenance History MA-406 Control and Calibration of'Test Equipment and Instrumentation MA-408 Maintenance Facilities and Equipment.
RC"501 RC-502 RC"503 RC-504 RC-505 RC-506 RC"507 RC"508 RC-509 RC-511 BROWNS FERRY (1981)
Appendix Page 2
RADIATIONPROTECTION AND CHEMISTRY Radiation Protection and Chemistry Organization and Administration ALARAProgram Personnel Dosimetry Radiation Surveillance and Control Waste and Discharge Control (Liquid)
Radiological Survey Equipment Control and Calibration Personnel Health Physics Indoctrination Process Water Controls
>Health Physics Facilities and Equipment Respiratory Protection Program TECHNICAL.SUPPORT TS-701 Technical Support Organization and Administration TS-V02 Engineering Suppor t TS-703 Nuclear Operating Experience Evaluation Program TS-V04 Plant Modifications TS-V05 Quite Reactor Engineering
BROWNS FERRY (1981).
Appendix Page 3
II.
TENNESSEE VALLEYAUTHORITYPERSONNEL CONTACTED Manager of Power Manager of Power Operations Director of Nuclear Power Plant Manager Assistant Plant Manager - Operations Assistant Plant Manager - Maintenance Power. Plant Results Supervisor Assistant Power Plant Results Supervisor Engineering and Test Unit Supervisor Reactor Engineering Unit Supervisor Outage Director Assistant Outage Director - Modifications Modification Coordinator Document Coordinator Data Systems Technical Coordinator Shift Engineer Shift Engineer - Training Unit Operator Document Control Unit Supervisor File Clerk Compliance-Unit Supervisor Safety Engineer Safety Engineer Aid
'aborer Plant Services Supervisor Engineering Aid Shift Engineer Occupational. Nurse Engineering Supervisor Mechanical Maintenance Supervisor Electrical Maintenance Supervisor Instrument Maintenance Supervisor Assistant Mechanical Maintenance Supervisor Senior Mechanical Engineer, Mechanical Maintenance Journeyman, Mechanical Maintenance Apprentice, Mechanical Maintenance General Foreman,,Electrical Maintenance, Foreman,, Electrical, Maintenance Journeyman, Electrical Maintenance-Apprentice;. Electrical Maintenance Instrument Mechanic Supervisor Computer/Security Supervisor Management Services Supervisor Health Physics Technician Power Stores Supervisor Assistant Electrical Maintenance Supervisor
C
BROWNS FERRY (1981)
Appendix Page 4 TENNESSEE VALLEYAUTHORITYPERSONNEL CONTACTED Cont'd)
Scheduled Maintenance/Trouble Report Coordinator Engineer, Electrical Maintenance Computer Foreman General Foreman, Instrument Maintenanc'e Unit I Foreman, Instrument Maintenance Cler k, Instrument Maintenance Health Physics Supervisor Assistant Health Physics Supervisor Assistant to the Health Physics Supervisor Outage Health Physics Supervisor Plant Chemical Engineer Shift Health Physics Supervisor Chief, Radiological Hygiene Branch Radiation Exposure Management Group Supervisor Chief, Laboratory Services Branch Western Area Laboratory Supervisor Plant Training Officer Training Officer, General Office Instrument and Controls Training Supervisor Electrical Training Supervisor
Ci r