ML19347E607

Evaluation of Crystal River Nuclear Power Station.

ML19347E607
Person / Time
Site:	Crystal River
Issue date:	04/30/1981
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
To:
References
TAC-12961, NUDOCS 8105130119
Download: ML19347E607 (85)

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EVALUATION of CRYSTAL RIVER NUCLEAR POWER STATION Florida Power Corporation April,1981 N

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SUMMARY

INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted an evaluation of Florida Power Corporation's (FPC) Crystal River Unit 3 Nuclear Generating Station during the weeks of January 18 and 25,1981. Crystal River Unit 3 consists of an 855 megawatt (electrical) Babcock and Wilcox pressurized water reactor plant. It is located on the Gulf of Mexico near Crystal River, Florida.

The plant was placed in commercial operation in March,1977.

PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall evaluation of plant operating safety, to review management systems and controls and to identify areas needing improvement.

The evaluation was based on preliminary INPO criteria and practices generally recognized as desirable and accepted techniques of industry and management.

Information was assembled from discussions, interviews, obsevations and reviews of plant documents. Emergency preparedness and security activities were not included in the scope of the evaluation, nor w&re corporate activities, except as an incidental part of the station evaluation.

The evaluation team examined station organization, training and qualifications, operations, maintenance, radiological and chemistry activities and site technical support. Performance evaluations were based on best practices. Report recommendations, therefore, are not limited to minimum safety requirements.

DETERMINATION Within the scope of this evaluation the team determined that the plant is being safely operated. We noted a positive attitude among station and corporate management personnel toward improvements in station operation and management.

Improvements were recommended for the following conditions:

o The non-licensed operator training program does not provide consistent, high quality training to individuals in this program.

o The actual staffing of C ystal River 3 is significantly below the autho-rized staffing level.

, o The outgn modification program does not provide timely, accurate l

changes to plant related documentation and support systems affected by j plant modifications.

Recommendations are intended to augment FPC's efforts to achieve the highest possible standards in its nuclear operations. In taking corrective e.ction, FPC

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Page 2 should consider possible generic significance of findings and recommendations.

FPC responses to the report are consideced appropriate to the findings presented. To follow the timely completion of these responses, INPO requests written notification upon completion of improvements.

Specific evaluation findings are in the accompanying DETAILS, and information of an administrative nature is in the ADMINISTRATIVE APPENDIX. These findings were presented at an exit meeting at the plant on January 30,1981. In addition, the findings, recommendations and responses have been discussed with FPC management.

The evaluation staff appreciates the excellent cooperation received from all levels of the Florida Power Corporation.

E. P. WILKINSON President 1

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Page 3 FLORIDA POWER CORPORATION l

Response Summary i I

The following is in response to the findings and recommendations expressed in the Determination Section of the INPO report on the Management Evaluation of the Crystal River Nuclear Plant.

We are pleased, yet not surprised, that INPO found a positive attitude toward safe operation and overallimprovements in our station operation. In the spirit of this attitude, we are committed to improvement in those areas which INPO identified as needing improvement.

In response to the three specific areas covered in the Determination Section, we

' feel that it is pertinent to point out that all of these items had been identified prior to INPO inquiry by both our plant staff and management team as items that must be strengthened if we are to achieve the highest possible standards in our plant operation. The first of these areas relates to the non-licensed operator training program, and more specifically, the INPO conclusion of inability of the program to consistently provide sufficient high-quality in-plant training for individuals in this program. We had observed the inadequacies in this program earlier and initiated actions to strengthen our training program. Our intent is to upgrade the non-licensed operator training program to fully meet the intent of the INPO Guidelines for non-licensed operator training. As an interim measure, Florida Power Corporation willimplement a formalized program to improve both the quality ar.d consistency of in-plant training provided for personnel within this classification. .

The second INPO recommendation was to reduce the disparity between autho- -

rized staffing level and actual staffing level. Several menagement actions have been implemented to date, and others are in p ogress to improve our recruiting success and to increase our retention of personnel. Our goal is to reach and maintain a level of 95% or greater for authorized staff on board in 1981.

The third recommendation is to improve our design modification program to provide timely, accurate plant-related documentation and support systems affected by plant modifications. Again, we are in agreement with the recom-mendation and have Initiated actions which, we believe, will achieve results compatible with INPO's recommendations.

The specific responses will address target dates or milestone dates for the planned corrective actions. Florida Power Corporation will submit reports to INPO on a semi-annual basis regarding our progress toward target or milestone dates. The first report will be submitted by September 1,1981.

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Page 4 DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each section is headed by a summary describing the scope of the evaluation and the overall finding in that .

area. The summary is followed by the specific findings, recommendations and )

utility responses related to each of INPO'S evaluation procedures. The evalua-tion procedures used are listed in the ADMINISTRATIVE APPENDIX.  ;

I ORGANIZATION AND ADMINISTRATION In this area, station objectives, organization structure, administrative controls, industrial safety, quality assurance programs, information dissemination and surveillance inspections and tests were evaluated.

Plant organization and administration are effective and receive suitable manage-ment attention. All management personnel contacted demonstrated a positive attitude and were very cooperative. It was noted that improvements could be made regarding the accuracy of station organization diagrams and timeliness of corrections to administrative instructions. The improvements are discussed in detall below.

OBJECTIVES i (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 effective they are in conveying intended operational and maintenance directions. Areas reviewed included the station mission statement, supervisor accountability, availability of station mission documents, assessment programs and measurement of goals and objectives attainment.

A comprehensive list of 1981 goals and objectives encompassing both corporate and plant personnel was recently distributed to all employees. Determinations were made as follows:

Findintr The criteria of OA-101 were met.

ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)

An evaluation was performed to determine how effectively the organization, as structured, manages the station to ensure safe, efficient operation. Areas reviewed included applicability of the organization structure diagram, position descriptions for all station personnel, personnel performance evaluation,

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management position and individual workload assignments.

Thirty-five staff positions are currently vacant. A strong effort to flu these positions and achieve the authorized staffing level should be continued. Deter-minations were made as follows:

1. Finding (Reference Criterion A)

The most current plant organization diagram, issued November 17,1980, does not show all reporting lines correctly and does not agree with organization diagrams contained in Administrative Instruction (AI-600, AI-700). No organizational structure diagrams exist for operations shift personnel below the Assistant Nuclear Shift Supervisor level. In addi-tion, written descriptions of the reporting lines of several supervisory positions in AI-200, AI-600, and AI-700 are not correct.

Note: This finding also applies to INPO Procedures OP-303 and MA-401 and is not repeated in those sections.

Recommendation i Establish and maintain a plant organization diagram which clearly reflects actual reporting lines. Establish a system to ensure that doeurr.ents whien are affected by changes to the organization diagram are corrected in a timely manner.

Response

Florida Power Corporatic,n Management concurs with INPO's recommen-dation. Administrative Procedures will be revised to include accurate

. organization charts anc! clear definition of reporting relationships and responsibility. In addition, Administrative Procedure AI-200 will be revised to' require that affected documents have the appropriate changes made no later than thirty days after effecting permanent organizational changes. The revised Administrative Procedures will define the relationships for an plant staff members. These changes will be completed by August 1,1981.

2. Finding (Reference Criterion B)

Position descriptions are available for most plant staff positions; how-ever, these have not been developed based on job analysis. Crystal River plant personnel are participating in an industry-wide job analysis project, coordinated by INPO, which will assist utilities in developing their position descriptions.

Note: Similar job analysis requirements appear in INPO Procedures OA-108, MA-401 OP-303, TQ-211 and RC-501 criteria A, C, B, C, and E respectively and will not be listed as separate findings.

Recommendation A job analysis should be performed for each authorized position at Crystal River Unit 3. Position descriptions describing the authority, responsibility and accountability of assigned individuals should then be prepared based on the completed job analyses.

Response

l In general, Florida Power Corporation Management concurs with the INPO recommendation. At the present time, all exempt positions have l

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1 position descriptions based on job analysis. However, many of these i position descriptions are outdated due principally to organizational l changes in the past year. Position descriptions for office and technical personnel and employees covered by the Memorandum of Agreement with the IBEW do not have adequate position descriptions based on job analysis.

. Crystal River Plant staff is participating in the industry-wide job analysis project which INPO is coordinating. It is understood that this project is initially constrained to journeyman-level jobs. To that end, Florida Power Corporation plans to continue with.the effort to upgrade -

the exempt position descriptions and initiate upgrading of the office and technical position descriptions based on job analysis. This effort should be completed by June 1,1982. A schedule cannot be established at this time for those positions to be included in the industry-wide job analysis program due to uncertainty in the scheduled completion of this program.

ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Revision 1)

An evaluation was performed to determine the effectiveness of the controls for administrative. functions. Areas reviewed addressed the program of administra-tive controls for purpose, scope, responsibilities, flexibility, level of administra-tive actions and program dissemination. Determinations were made as follows:

Finding The criteria of OA-103 wee met.

QUALITY PROGRAMS (On Site)

(INPO Procedure OA-104, Revision 4)

An evaluation was performed to determine how effectively quality programs monitor and audit plant activities to promote accomplishment of the station mission. Areas reviewed included management controls, accountability programs, program crosschecks, program effectiveness, program for corrective actions and staffing. The QA/QC Compliance Department, staffed with an allowanm of 12 people and using a computer printout system to track all action i

items, uaintains good control of quality programs. Determinations were made _

as follows:

Phuling The criteria of OA-104 were met.

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Page 7 INFORMATION PROGRAMS (On-Site) ,

(INPO Procedure OA-105, Revision 1)

An evaluation was performed to determine how effectively information germane to operational safety and plant reliability is disseminated for review and appropriate action. Areas reviewed addressed the system for information dissemination, including time factors, loop closure features and follow-up verification. Determinations were made as follows:

Finding A program is in effect for controlled dissemination of pertinent informa-tion to appropriate departments at the station. The criteria of OA-105 were met.

INDUSTRIAL SAFETY (On Site)

(INPO Procedure OA-106, Revision 1)

An evaluation was performed to determine the effectiveness of the station safety program in providing a safe, orderly working environment. Areas reviewed included the station's general and site-specific policy, management support for the safety program and employee interface with management in safety matters. Determinations were made as follows:

Finding .

The criteria of OA-106 were met.

SURVRTLLANCE PROGRAM (INPO Procedure OA-107, Revision 2)

An evaluation was performed to ensure that an effective program exists to accomplish required surveillance, inspection and testing. Areas reviewed l

included completeness, depth, acceptance criteria, results review, notification, control of off-standard conditions, suitable scheduling and training in proper use of surveillance procedures. Determinations were made as follows:

Finding

' The surveillance program is well defined and suitably managed. The criteria of OA-107 were met.

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Page 8 PERSONNEL QUAIJFICATIONS (INPO Procedure OA-108, Revision 1)

Evaluation was performed to ensure a program exists for providing appropriately qualified personnel to operate and maintain the plant. Areas reviewed included the application of job and task analysis to each station position, tne program for personnel selection and promotion and the program for periodic review of job and task analysis. Determinations were made as follows:

Finding (Reference Criterion A)

The criteria of OA-108 were met with the exception of Criterion A, which was previously identified under Criterion B of OA-102.

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Page 9 TRAINING AND QUALIFICATIONS In this area, training organization, management, resources and effectiveness were evaluated. Effectiveness in training and retraining of licensed operators, non-licensed operators and shift technical advisors was also evaluated. The station training organization is well organized and receives suitable management attention and support. Improvements could be made regarding training adminis-tration and resources, evaluation of training effectiveness and qualification standards. These improvements are discussed in detail below.

TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)

An evaluation was performed to ensure the station has a clearly defined training -

organization that assigns responsibilities and delegates authority to accomplish those training tasks assigned to the training group. Areas reviewed included the organizational structure and practices, training staff size, ability and authority to schedule and provide required training and existence of and adherence to Pitten training plans.

Florida Power Corporation has developed a well organized and responsible trt.ining group. Sufficient authority is vested in the training group to success-fully meet the training goals. Determinations were made as follows:

1. Finding (Reference Criterion C)

This criterion was previously addressed under Criterion B of OA-102.

L Finding (Reference Criterion D)

A formal program for in-plant training of non-licensed operators and 4 license candidates has not been provided. Informal guidelines were outlined in a December 1980 memorandum of understanding between the -

training and operations groups. However, this memorandum does not provide guidance to trainees or responsible on-shift personnel fot structured, prioritized completion of the existing systems check lists.

NOTE: This finding also applies to INPO Procedures TQ-242 (Criterion A) and TQ-243 (Criterion E), which pertain to written procedures for conducting in-plant training. This finding is not repeated in those sections.

Recommendation Develop and implement formal, structured training programs for in-plant training of non-licensed operators and license candidates. These pro-grams should include detailed instructions and guidance for systems checkouts by the operations group and prioritized guidelines for operations personnel to conduct system checkouts which establish levels i

of acceptable systems knowledge and set standards for trainee progress.

Response

Florida Power Corporation Management agrees with this finding and the recommendation. Work is currently in progress toward implementation of a formal program for the in-plant training of both licensed and non-licensed operations personnel. This program will provide detailed instructions and guidelines for operations personnel to conduct system l

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checkouts which establish levels of acceptable system knowledge,  ;

prioritize those system checkout et luirements for the trainee and establish standards of progress for the .rainee. It is anticipated that this program will be developed and initiated by September 1,1981.

3. Finding (Reference Criterion E)

An effective program has not been implemented for monitoring the progress and performance of non-licensed operators and license candi-dates during the in-plant portion of their training. The student advisor concept described in the memorandum of understanding between the training and operations groups was designed to be a mechanism for conducting such monitoring. However, this student advisor concept has not been effectively implemented.

Recommendation Develop and implement a program to monitor the progress and perfor- --

mance of non-licensed operators and license candidates during the in-plant portion of their training. This program should establish the responsibilities of the training and operations groups for periodically evaluating trainee progress, performance and retention of plant know-ledge.

Response

Florida Power Corporation Management concurs with this recommendation. A formal program will be developed, concurrent with the program and schedule referenced in the response to the recommendation for Criterion D of TQ-211, to monitor the performance of both non-licensed operator and license candidate trainees. This program will provide for periodic monitoring and evaluation of trainee performance. Appropriate responsibilities will be specified in the program.

TRAINING RESOURCES (INPO Procedure TQ-221, Revision 1)

An evaluation was performed to determine whether sufficient facilities, equipment and materials are provided to support the trair.ing programs. Areas reviewed included facilities, laboratories, workshops, office space, training materials, aids and equipment, lesson development and accommodations to support the trainers and trainees. Determinations were made as follows:

Finding (Reference Criterion F)

The training facility does not have an actively maintained library.

Recommendation Establish and maintain a library readily accessible to the trainlag group.

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Response

Florida Power Corporation concurs with the Intent of this reccmmendation. Such a facility is in the conceptual planning phase and should be functional within two years (by April 1,1983). In the interim, the instructional staff and trainees have access to required material in the plant document control center.

TRAINING EFFECTIVENESS (INPO Procedure TQ-231, Revision 1)

An evaluation was per formed to determine what measurements are made of the effectiveness of trait ing programs with regard to meeting training objectives and improving operational performance. Areas evaluated included programs for management evaluation of training effectiveness, measurement of trainee and instructor performance and audits of training activities. Determinations were made as follows:

Finding (Reference Criterion A)

Written procedures have not been developed to provide for structured, regular evaluations of all training programs. As a result, formal, systematic appraisals of the effectiveness of training programs have not been periodically conducted.

NOTE: This Finding also applies to INPO. Procedures TQ-243 (Criterion I) and TQ-244 (Criterion D, which pertain to evaluations of training .

programs. This finding is not repeated in those sections.

Recommendation Develop and implement procedures to periodically review all formal training programs for effectiveness. These procedures should utilize written examinations, oral examinations, reviews of trainee per-formance, eriodic spot checks for lesson retention and reviews and evaluations by knowledgeable persons independent from the group being reviewed. An effective procedure would use a combination of these techniques.

Response

Florida Power Corporation Management concurs with INPO's recommen-dation. Informal evaluations of formal training programs have been implemented. The evaluation process will be formalized by procedure development and implementation. The development of these procedures will be completed to provide for periodic formal evaluation for the full scope of formal programs conducted after January 1,1982.

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Page 12 NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)

An evaluation was performed to determine whether a training program has been established for non-licensed operators. Areas reviewed included the programs for initial and continuing training, selection, screening, promotion and utilization of classrooms and inylant training methods. Determinations were made as follows:

1. Finding (Reference Criterion A)

This criterion was previously addressed under Criterion B of OA-102.

2. Finding (Reference Criterion B)

Non-licensed operators are assigned the responsibilities of a watch station without meeting formal qualification standards. Qualification standards have not been developed for the various levels of non-licensed operator positions described in the station's Administrative Instructions.

Recommendation Develop qualification standards for each non-licensed operator position ,

as described in AI-200, section .7.4 and/or for each plant watch station.

In addition, implement a program or policy that will ensure that individuals assigned to a given position or watch station have met the applicable qualification standards.

Response

Florida Power Corporation Management concurs with the INPO recom-mendation. Qualification standards will be developed for each plant watch station and policy statements will be promulgated to ensure that individuals meet the appropriate qualification standard (s) prior to independent shift assignment. These standards will be develcped by September 1,1981. At the time of issuance of the standards, all personnel assigned to the position will be evaluated for compliance with the applicable standard. Those not in compliance will be given a specified time period to correct deficiencies or be removed from -

independent shift assignment, depending on the degree of disparity between the standard (s) and the individual's qualifications.

LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)

An evaluation was performed to determine the effectiveness of the training program that prepares candidates for Reactor Operator (RO) and Senior Reactor Operator (SRO) licenses. Areas reviewed included program content; base level of knowledge; training materials and source inputs; training in systems, plar.t

'undamentals and operating practices; SRO training; and evaluation of trainees and the training programs. Determinations were made as follows:

Finding The criteria of TQ-243 were met with the exceptions of Criterion E, I which was previously identified under Criterion D of TQ-211 and i Criterion I, which was previously identified under Criterion A of TQ-231.

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Page 13 LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-244, Revision 2) l An evaluation was performed to determine the effectiveness of the qualificatfort program in maintaining a high level of skill and knowledge for each Reactor Operator (RO) and Senior Reactor Operator (SRO). Areas reviewed included development and use of training materials to upgrade licensed operators in fundamentals and to inform them of procedure changes, licensee event reports, plant modifications, changes in station license requirements and changes in -

vendor information affecting operations. In addition, the policy on use of a training simulator, periodic program evaluation and provisions for inactive operator identification and requalification were reviewed. Determinations were made as follows:

Finding The criteria of TQ-244 were met with the exception of Criterion I which was previously. identified under Criterion A of TQ-231.

SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-245, Revision 1)

An evaluation was performed to ensure that a suitable training policy has been

. developed and implemented for Shift Technical Advisor (STA) training and educa.tlon. Areas of interest included a review of the STA program for college-level and site-specific instruction, simulator training, retraining provisions and

documentation of all training. Determinations were made as follows

Pinding The criteria of TQ-245 were met.

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Page 14 OPERATIONS l Operations was evaluated in light of current INPO criteria to assess performance in shift conduct, organization and administration, use of procedures, tagout practices, plant status controls and watch turnover.

The plant is generally clean and in good material condition.

It was noted that improvements could be made in the watch turnover mechanism for lower tier operators. These improvements are discussed in detail below.

l 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 cleenliness and order, response to abnormal conditions, logkeeping practices, reliability of control room instrumentation and operator awareness of plant conditions. Determinations were made as follows:

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 which are repositioned, tag coloring and nt mbering and review of clearance logs. Determinations were made as follows:

Pinding The criteria of OP-302 were met.

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Page 15 ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-303, Revision 2) l An evaluation was performed to determine the existence of a clearly defined operations organization that assigns responsibilities and delegates adequate authority for accomplishment of required tasks. Areas reviewed included organizational structure, job descriptions, shift administrative assignments, written and oral instructions and orders and miscellaneous administrative programs. Determinations were made as follows:

Finding The criteria of OP-303 were met with the exception of Criterion B which was previously identified under Criterion B of O A-102.

USE OF PROCEDURES (INPO Procedure OP-304, Revision 2) _

An evaluation was performed to determine if proper use is made of procedures to conduct operations safely and reliably. Areas reviewed included management policy for use of pocedures and changes to procedures (short term and long term). In addition, procedures were reviewed for clarity, continuity, identifi-cation of " sequence required" actions and suitable advisory information. Deter-minations were made as follows: ,

Finding The criteria of OF-304 were met.

PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 1) _

An evaluation was performed to determine if plant status controls are provided to ensure adequate equipment and system availability. Areas reviewed included management programs and policies that provide guidance for status control, actual practices in status control, responsibilities of Senior Licensed Operators assigned to monitor and review status control and provisions for status control i under special conditions such as outages, accident recovery, or refueling. ,

Determinations were made as follows. ,

Finding It was noted that the coordination between the outage group and the Operations Department during refueling outages is very good. The criteria of OP-305 were met.

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Page 16 OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-306, Revision 2)

An evaluation was performed to determine if plant facilities and equipment are operable aM are maintained in a manner that ensures safe and efficient i operation. Areas reviewed included equipment operability, equipment avail-  !

ability programs, effect of the working environment on safe and efficient station operation, adequacy of communications equipment and watch station assign-ments. Determinations were made as follows:

Findirg The criteria of OP-306 were met.

SHIFT TURNOVER (INPO Procedure OP-309, Revision 2)

An evaluation was performed to determine if continuour correct understanding of statfor. conditions is maintained at all shift positions. Areas reviewed' included programs and policies controlling shift turnover practices for watch stations, checklists, operating panel reviews and station activities in progress or planned. Observation of control room practice indicates sufficient information is conveyed during shift turnover to avoid unsafe optration. Determinations -

were made as follows: ,

Finding (Reference Criterion B) -

SRO and RO licensed operators tave efficient turnover mechanisms.

The operators below this level to not have a formal check sheet or other mechanism for efficient turnover of information.

Recommendation A shift turnover mechanism should be developed for non-licensed auxi-11ary operators to complement the excellent turnover mechanisms curreraly used by the licensed operators.

Response

Florida Power Corporation Management concurs with the INPO rec-ommendation. Appropriate shift relief checklist (s) will be developed and implemented for ell shift positions. The developed checklist (s) will be in effect no later than September 1,1981.

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Page 17 MAINTENANCE ,

i Maintenance was examined in light of current INPO criteria. The areas reviewed include maintenance organization, corrective and preventive maintenance, administrative programs, procedures, equipment history and maintenance

facilities. The existing maintenance administrative programs add strength to the organization. Additionally, there is a progressive approach to management which appears to be improving the overall performance of maintenance.

l Areas where improvements are recommended include organization, maintenance history, preventive maintenance, facilities and spare parts availability.

MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 2)

An evaluation was performed ta determine how effectively the msintenance organization and administrative programs contribute to the performance of maintenance task' Arcas reviewed included organizational structure, reporting requirements an. practices, staff size, training and retraining, position descrip-tions for maintenance personnel, span of control for supervisors and certain administrative programs. Determinations were made as follows:

1. Finding (Reference Criterion A and B)

The maintenance organization is not of sufficient size or appropriate structure to perform all normally assigned responsibilities. The span of control for the Maintenance Superintendent appears too large for him to I effectively perform all assigned duties. The excessive overtime worked in some areas and the backlog of work requests indicate an inadequate staff size.

Reco nmendation Actions should be taken to evaluate and adjust staffing requirements and job responsibilities in areas where there is excessive ovntime and a -

growing or stable backlog of work. In addition, the Main *e m " Super-intendent should have individuals within his organization. . A lead responsibility for supervision and technical direction of the behanical, Electrical and Instrumentation and Control areas.

Response

Florida Power Corporation Management acknowledges the concern expressed in INPO's finding and recommendation. As an ongoing effort as well as part of the 1981 goals and objectives for Nuclear Operations, excessive overtime across the entire organization w21 be monitored to determine causes and appropriate corrective action to be taken.

Reorganization and work efficiency assessments are actively underway.

The Maintenance Superintendent has been directed to provide findings and recommendations to Management by September 1,1981.

2. Finding (Reference Criterion C)

This criterion was previously addressed under Criterion B of OA-102.

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Page 18 PREVENTIVE MAINTENANCE 1 (INPO Procedure MA-402, Revision 1)

An evaluation was performed to determine the effectiveness of the maintenance effort to optimize equipment reliability and performance. Areas of review included assessment of formal preventive maintenance programs, equipment included in the program, type and frequency of preventive maintenance and effectiveness of program control and coordination. Determinat!ons were made as follows:

Finding (Reference Criterion A)

Although there is a preventive maintenance system in use, there is no management-approved preventive maintenance program. There are no provisions for evaluation of the effectiveness of the effort or for modification to the system. __

Recommendation The existing preventive maintenance and lubrication program should be approved by plant management. Features that should be in the program descriptions include definition of equipment included, scope and frequency of preventive maintenance. The program should also include a loop clowre feature to ensure reviews of preventive maintenance activities are conducted to modify the program as needed.

Response

Florida Power Corporation Management concurs in general with INPO's finding and recommendation. A preventive maintenance program upgrade should be implemented by September 1,1981.

MAINTENANCE PROCEDURES (INPO Procedure MA-403, Revision 2)

An evaluation was performed to determine the ability of .uaintenance procedures to enhance the quality and effectiveness of maintentace activities. Areas reviewed included an assessment of activities governed by procedures, methods of procedure development and revision and content of procedures. The extent that maintenance procedures are actually utilized for accomplishment of work is also within the scope of the evaluation. Determinations were made as follows:

Finding The criteria of MA-403 were met.

WORK CONTROL SYSTEM (INPO Procedure MA-404, Revision 1)

An evaluation was performed to determine the effectiveness of the work control system in use at the plant. The system functions were checked to see if they define and authorize work to be performed by the maintenance groups; provide l

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Page 19 for planning, scheduling and control of actual work; and have a mechanism to.

input the maintenance results into an equipment history file for future evalue. tion. Determinations were made as follows:

Finding The criteria of MA-404 were met.

i MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 2)

An evaluation was performed to determine if a maintenance history file is in use that will support an evaluation program and contribute to improved equipment performance. Areas reviewed included assessment of equipment items included '

in maintenance history, content and accessibility of records, history review and evaluation methods and procedures for program implementation. Determinations were made as follows:

4 Finding (Reference Criteria C, D and E)

Responsibility is not assigned for development of a maintenance history program. As a result, there is no periodic review of maintenance history. Additionally the records filing system has evolved into a system which does not lend itself to performing a review of maintenance history.

Recommendation .

A formal method (program) for periodic review of the history files should be established to determine trends and to perform engineering evaluations. The program should identify responsibility for frequency and nature of the reviews necessary to provide input for evaluations of equipment performance and maintenance effectiveness. Review require-ments should be reconciled with the type of data being recorded with

! equipment history to ensure records are sufficient to identify such items as plant conditions at the time of equipment Nilure, cause of failure and corrective action necessary to prevent recurrence. The filing. system which is currently under study should be revised to facilitate reviews of maintenance history. The history review program should provide a Iccp closure feature to ensure necessary changes in operating or maintenance practices are made.

Response

Florida Power Corporation Management concurs with the INPO re-commendation. Efforts are currently underway to establish a formal maintenance history program. This effort is being pursued in parallel with the upgrading of the Nuclear Operations overall records manage-j ment system. The base computer program will be completed by August 1,1981, and the actual program will be initiated by September 1,1981. ,

The procedure revisions rem' red to formally implement the review and  ;

4 trend analysis should also tas completed by September 1,1981. )

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Page 20 CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTA-TION (INPO Procedure MA-406, Revision 1) i An evaluation was performed to ensure that available facilities and procedures in effect support the need for accurate test equipment and instrumentation. Areas reviewed included identification, calibration, storage, issuance, use, shipment and documentation. Determinations were made as follows:

Finding The criteria of MA-406 were met.

MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Revision 1)

An evaluation was performed to determine if facilities and equipment provided for the maintenance staff effectively contribute to the performance of required activities. Areas reviewed included criteria that address the need for sufficient tools and equipment, adequate maintenance of tools and equipment, ample tool storage space in suitable plant locations, adequate office end work areas and clean, orderly, and well-maintained facilities. In addition, an assessment was made of the storage and availability of parts and materials required to support maintenance work. Dete'eminations were made as follows:

1. Finding (Reference Criterion C)

There is generally inadequate work space to perform maintenance efficiently. There are no locker or shower facilities for female maintenance employees.

Recommendation An evaluation of work spaces for maintenance personnel should be conducted and adequate working spaces provided. This evaluation should sonsider work area available to workers, welding equipment location and power supplies, shower and locker facilities and location of test equip-ment.

Re.sponse Florida Power Corporation Management concurs with the finding and recommendation made by INPO, and expects that such improvements should be made by April 1,1983.

2. Finding (Reference General Criterion)

The inventory of spare parts is not adequate to effectively and efficient-ly perform all maintenance activities. Because of the storeroom location, accessibility to spare sarts is very inefficient. Additionally there is not an effective system to ensure that the spare parts inventory is maintained current as changes to piant equipment take place.

Recommendation An evaluation of the procedures and practices which govern procure-ment, stccage and issuance of spare parts should be conducted and effective procedures and issuing locations should be provided. This evaluation

CRYSTAL RIVER (1981) f Page 21 should consider locating the storeroom in an area which provides an efficient interface with maintenance, developing procedures to ensure the spare parts inventory is maintained current with plant and equipment changes and providing personnel whose job descriptions accurately reflect their responsibilities for spare parts interfaces.

Response

Florida Power Corporation Management concurs with the finding and recommendation. Efforts have been in progress for some time to improve all aspects of material support for Crystal River Unit 3. There --

is currently no Intent to relocate the warehouse facilities, but a staging warehouse, contiguous to the in-plant maintenance area, for in-service operation within two years (by April 1,1983), is being considered. A review of procurement methodology, spare parts inventory and the applicable procedures should be completely overhauled by July 1982.-

However, a new concept in spare parts purchasing has been developed and is now in the early stages of implementation. In addition, the first phase of an in-depth, systematic re-evaluation of spare parts needs involving the full scope of the Nuclear Steam Supply System is to be initiated by May 1,1981. Of an even shorter term nature, formalization of spare parts justification criteria and high-level assessment of most significant spare part needs is to be completed by September 30,1981.

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Page 22 RADIATION PROTECTION & CHEMISTRY Organization, administration, radiological protection, liquid waste control and process water chemistry were evaluated in light of current INPO criteria.

It was concluded that the plant's radiation protection and chemistry prog.ams were being conducted in an efficient and professional manner which provided for sufficient controls to protect the public, plant workers and the environment.

RADIATION PROTECTION & CHEMISTRY ORGANIZATION & ADMINISTRA-TION (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. Areas reviewed included the organization structure, procedures for conduct of operations, staffing levels, training and retraining programs, position descriptions and management authority.

The Chem / Rad section had recently been reorganized under a single Chem / Rad Manager who reports directly to the Plant Manager. The reorganization involved the designation of functional area supervisors and specialists along with a significant increase in overall staff size. This new organizational approach and the increased management support in the area of radiation protection and chemistry appear to have had very positive effects on the quality of the services provided by the Chem / Rad secHon. Without exception, the radiation protection and chemistry personnel contacted during the evaluation exhibited an overall -

high degree of professionalism and a positive attitude toward self improvement.

Finding The criteria of RC-501 were met with the exception of criterion E which was previously identified under OA-102.

ALARA PROGRAM (INPO Procedure RC-502, Revision 1)

An evaluation was performed to determine the effectiveness of efforts toward maintaining personnel occupational radiation exposure as low as is reasonably achievable (ALARA). Areas evaluated included the company's ALARA policy, responsibilities for ALARA, level of review for the ALARA program, systems for setting goals and measuring progress and overall scope of ALARA activities.

The plant did not have a separate, formal ALARA program; however, the 1 radiological protection activities reviewed included some elements of an infor-mal ALARA program. Examples of good ALARA practices included, but were not limited to, the redesign of facilities and equipment for letdown pre-filter changeout, shielding of letdown lines in occupied areas and the establishment of general exposure goals for 1981. The utility had recognized the need for (

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CRYSTAL RIVER (1981)

Page 23 development of a formal ALARA program and at the time of the evaluation had established a project team to study available options and make recommendations for a corporate and plant ALARA program. Determinations were made as follows:

Finding (Reference Criteria B, C, D and E)

Although the company had a written ALARA polley, no formal ALARA program existed which addressed Criteria B, C, D or E. There was no clear assignment of responsibility for the ALARA program other than i that encompassed by the recent project team formation. ALARA activities were not being coordinated, reviewed or approved at any level within the company. There was no system to establish or monitor progress towards specific exposure goals. The elements of the informal ALARA program which did exist did not address all areas of facility design, operations, maintenance and training.

Recommendation Develop and implement a formal ALARA program which addresses all of the criteria of INPO Procedure RC-502. It should be recognized that improvements will probably be necessary in some related areas in order to implement an effective program. These areas include:

a. computerized exposure records system screening processes and output reports.

< b. radiological surveillance records cataloging and retrieval capa-

ilities.

c. radiological work permit system interface with maintenance work request system and cross-reference to equipment data bases.

Response "

Florida Power Corporation concurs with the INPO recommendation. The specific points identified in INPO's recommendation as needing remedial action to faellitate an ALARA program implementation have been previously identified by Florida Power Corporation and action is in progress to address these concerns. By way of clarification, the Nuclear Support Services group is assigned overall ALARA program responsibility with a corporate-wide commitment for adherence and plant staff responsibility for implementation. This role is currently vacant, but should be filled before the implementation date of the program. The current plan is to have the program defined by July 1,1981, and the program fully implemented by January 1,1982.

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! PERSONNEL DOSIMETRY (INPO Procedure RC-503, Revision 1)

An evaluation was performed to determine the effectiveness of the plant's dosimetry program in measuring, evalusting and recording occupational radiation exposures. Areas examined included the scope of the dosimetry program, pro mdural controls, dosimetry selection and use, system operation and exposure records.

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! Page 24

[ l l The dosimetry program was judged to be effective however, some improvements _ _ . . _ _

were needed. Determinations were made as follows:

1. Finding (Reference Criterion C)

Improvements in the plant's radiation protection procedures are desirable I in each of the following areas in order to ensure thoroughness and consistency in the conduct of the dosimetry program:

a. neutron dosimetry method and documentation of results.

b. extremity dosimetry criteria and methodology. l I

c. evaluation of skin dose for significant levels of personnel skin contamination. l t

d. exposure records retention.

Recommendation The existing radiation protection procedures should be revised to in- l corporate appropriate instructions for the items mentioned above. l Rampnnes Florida Power Corporation Management concurs with the INPO recom-mendation. These improvements should be implemented prior to the next refueling outage, which is currently planned for September,1981.

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2. Finding (Reference Criterion D)

The primary personnel exposure records files were maintained in stan-

.dard, non-fireproof filing cabinets in the dosimetry work area. Duplicate copies of these records were not being maintained in a separate location, i and the computerized exposure records system data base was not

designed to maintain comprehensive historical records of the nature

contained in the hard copy files. The records system was therefore r inadequately protected against the loss of information which would

! result in the event of a fire in the dosimetry work area. l Recommendation At the time of the evaluation, the plant had taken initial action toward the development of a plant-wide centralized document control and _

records retention system. The maintenance of duplicate exposure records should be incorporated in this central system. In addition, fireproof file cabinets should be considered for those hard copy records maintained in the dosimetry work area which are routinely used and which are not readily available from the computerized system. (This is in addition to duplicate storage in the control records system.) l

' Response

. Florida Power Corporation Management has previously recognized the problem with records retention in the Chem / Rad area. This problem is more broadly present within Nuclear Operations, and actions have been taken previously to address this issue as stated in the INPO recom-mendation. Items presently under consideration in addition to upgrading the centralized records management system are improved computerized dosimetry records and/or improved hard copy storage facilities. It is currently anticipated that the implementation of the solution to this i problem will take approximately one year (by April 1,1982).

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Page 25 l RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 1)

An evaluation was performed to determine the effectiveness of the radiological surveillance program and radiological work control mechanisms in identifying radiological hazards to workers and management and in minimizing the magni-tude of these hazards. Areas evaluated included surveillance program proce-dures, surveillance program scope, radiological conditions in the plant, surveil-  !

lance methodology and the level of management review of surveillance data.

The radiological surveillance program and work control methods were effective in identifying radiological hazards and minimizing personnel radiation expo.-ure.

Determinations were made as follows:

Finding The criteria of RC-504 were met.

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 genacation of liquid radioactive waste (radwaste) and limiting releases to levels as low as reasonably achievable (ALARA). The program elements reviewed included procedures, effluent moni-toring system design and function, clean system sampling, training and radwaste management methods.

The controls over solidified radwaste and the generation, processing and release of liquid radwaste were acceptable. Determinations were made as follows:

Finding The criteria of RC-505 were met.

RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)

An evaluation was performed to determine the effectiveness of the plant's radio- -

logical survey equipment control and calibration program :n 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 conditions, reference standard traceability, operational response checks and equipment identification.

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CRYSTAL RIVER (1981)

Page 26 Adequate numbers and types of operable instruments were observed in the plant to support normal operations. The instrument control and calibration program was effective in accomplishing its intended purpose; however, improvement was warranted in the calibration techniques employed. Determinations were made as follows:

Finding (Reference General Criterion)

The techniques employed for calibration and operational response check-ing of radiation protection instrumention should ensure that the instru-ments will perform with the best possible accuracy and precision over their full useful ranges.

The methods employed for calibration and performance testing of portable radiation protection instruments were based upon manu-facturers' recommendations. Most instruments were therefore being calibrated at one point within the effective range of each calibration control, but were not being checked for linearity at additional points on each scale or decade of rcadout. Instruments received qualitative radiation response checks prior to use or daily, as applicable.

Quantitative performance tests (reproducible source checks with a specified tolerance on instrument error) were not observed to be part of the instrument response check program.

Recommendation The methods and procedures employed for calibration of portable radia-tion protection instruments should be revised to incorporate the guidance given in Sections 4.1 and 4.2.2 of ANSI N323-1978," Radiation Protection Instrumentation Test and Calibration."

The instrument operational check methods should be changed to quanti-tative performance tests such as those described in Section 4.6 of ANSI N323, with the exception that checking each scale or decade of readout should be done only as practical based upon availability of sources, planned instrument use and consideration of ALARA principles.

Response

A review of the current calibration program and the guidance provided by ANSI-N323 will be conducted. Based on this review and subsequent evaluation, changes will be initiated to ensure compliance with overall current industry standards and practices. The utility does not consider this as a " verbatim" commitment to ANSI-N323. This review, evaluation and implementation of changes will be accomplished by January 1,1982.

l PERSONNEL HEALTH PHYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2) l 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 the available methods for minimizing exposure.

Areas reviewed included management policy, scope, depth of indoctrination, l

training environment and training documentation.

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i CRYSTAL RIVER (1981) I Page 27 The plant had recently revised the contents and method of presentation of the 4

basic health physics indoctrination program. The Indoctrination is presented as a part of general employee training and is given at two levels: 1) simple introduction on posting and controls for personnel who do not routinely enter

' controlled areas and 2) a comprehensive radiation protection indoctrination for personnel requiring unescorted access to radiological controlled areas. Both levels of indoctrination were being presented by live instruction, the quality of which was observed to be excellent. Taken as a whole, the indoctrination program was structured and conducted in a manner that achieved the objective of preparing personnel to work both in and near radiological controlled areas.

Determinations were made as follows:

Finding The criteria of RC-507 were met.

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PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2) i 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 control, cleaning agent and reagent control, training and systems chemistry.

Process water. controls appeared to be effective in minimizing corrosion.

Determinations were made as follows: ,

Finding .

1 The criteria of RC-508 were met.

HEALTH PHYSICS FACILITIES AND EQUIPMENT l (INPO Procedure RC-509, Revision 2)

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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 reviewed included the number and types of instruments and equipment, protective clothing inventory, design and working environment of facilities and the ease of access to and physical conditions of radiological controlled areas.

The original plant design provided limited space for health physics facilities and the majority of this space was centered around the main access control area.

Plant personnel have attempted to utilize the available space in the best possible manner. Radiological conditions and cleanliness of controlled areas appeared to  ;

be well controlled and the segregation, storage and labeling of contaminated j outage support materials were observed to be excellent. Determinations were made as follows:

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CRYSTAL RIVER (1981)

Page 28 Finding (Reference Criterion C)

The health physics facilities were overcrowded, resulting in inefficien-cies in the following operations:

a. respiratory protection equipment cleaning and maintenance.

b. Instrument calibration and maintenance.

c. air sample and contamination survey swipe counting.

d. dosimetry issue, whole body counting (direct bioassay) and exposure records maintenance.

e. radioactive waste compacting.

Recommendation .

Preliminary plans were being developed by the utility for expanding the main access control area in the Auxiliary Building. This expansion of this area appears desirable. The existing health physics facilities should be upgraded to improve the efficiency of the operations mentioned in the finding above (with the exception of waste compacting). Where possible, space should be dedicated for single purposes, such as instrument calibration and maintenance, rather than attempting to combine several operations into a multi-use, multi-purpose area such as was done in the Health Physics Service Room. Additional efficiency may be realized by relocating some of tne more support-oriented functions, such as dosimetry issue, exposure records maintenance and whole body counting to areas outside of access control and possibly even outside the protected area. This last option would'be particularly viable after implementation of a multi-user accessed computerized exposure records data base.

Additionally the radwaste compacting operation should be relocated to a larger more easily controlled area.

Response

As stated in the recommendation, Florida Power Corporation Manage-ment has recognized the inadequacies of existing facilities for health physics and waste drumming operations. The upgrade of these facilities is still in a preliminary design phase, but completion is anticipated within two years (by April 1,1983). The INPO recommendation will be given due consideration in the planned upgrade.

CRYSTAL RIVER (1981)

Page 29 '

RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 1)

An evaluation was performed to determine the effectiveness of the plant's respiratory protection program in protecting personnel from airborne hazards.

Areas reviewed included policy and procedures, identification and control of j airborne hazards, selection and use of respirators, respirator maintenance and l emergency capabilities. )

l The plant pr* gram was judged to be adequate for the protection of personnel  !

)

from known hazards. Determinations were made as follows-Finding l The criteria of RC-511 were met.

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Page 30 i

TECHNICAL SUPPORT On-site engineering support was evaluated in light of current INPO criteria.

l' The plant engineering organization and most plant engineering prograrr.s are functioning in an effective manner. It was noted that improvements could be made regarding control of plant modification 'and performance monitoring programs. These improvements are discussed in detail below.

ON-SITE ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 1)

An evaluation was performed to determine the effectiveness of the on-site engi-neering support group in resolving problems and concerns of a technical nature.

Areas reviewed included organizational structure, size, assignment of responsi-bilities and effectiveness of coordination with other groups. In addition, programs for control of design changes, on-site and off-site incident review, plant performance monitoring and other such engineerirt activities were reviewed.

There was tvidence that management has attempted to determine the effective-ness of engineering support activities and has initiated beneficial organization and program changes in several areas. Determinations were made as follows:

1. Finding (Reference Criterion 3)

The existing modification program is not effective in providing for timely completion of modifications, revision of affected drawings and removal of temporary jumpers. In addition, the program does not assure that all affected working documents (maintenance procedures, spare

parts liste, etc.) are identified and revised, so that all operators receive information required for safe operation of modified systems prior to returning these systems to service. The need to improve the existing 3

program had been previously identified by plant personnel, and revisions to the controlling. procedure were under study at the time of this evaluation.

Recommendation Efforts to provide more effective control of the modification process through revision of existing procedures should be continued. Through these program changes and a commitment of resources, the number of j outstanding modifications, document revisions and temporary jumpers in i use should be reduced and maintained at a manageable level )

In addition, methods used for training operators and notifying affected personnel of completion of modifications should be reviewed and made more effective. Training requirements should be determined on a i case-by-case basis and may range from formal classroom instruction to

a simple description of the change being placed in the required reading i file. The program should ensure that required training is provided prior to returning a modified system to service. The program should also ensure that operations personnel are notified through the shift turnover process or other effective means when modifications having significant impact on operations are complete.

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CRYSTAL RIVER (1981) l Page 31 Finally, existing methods for identification of documents affected by modifications should be examined and revised as required to assure that affected documents are routinely updated and kept current with changes in pLnt hardware and systems.

Response

Florida Power Corporation Management agrees with the INPO evaluation and recommendation. Beginning in 1979, changes were initiated to the appNpriate procedures to expedite and strengthen the document update following modification completion, to increase the resources available I for the purpose d iraproving the timeliness of each aspect of the design I rnodification process, to initiate an informal industry survey to seek out l the "best practice" for timely and effective training of operations personnel on plant modifications and to factor the current document control problems relative to design modifications into the oveaall records management program upgrading effort. Several Nuclear Operations Goals for 1981 deal with reduction of the backlog of pending modifi- _

cations, as well as closeout of completed modifications.

The procedures referenced above will be implemented by April 1,1981.

The review of the "best practices" and upgrading of existing method of training on modifications should be completed by September 15, 1981.

The document control procedures should be revamped by September of 1981.

2. Finding (Reference General Criterion)

A number of activities have been instituted for plant output and reliability improvement, and these activities form the basis for a performance. monitoring program. Howev'er, mechanis.1s for coordinating and controlling the program are not clearly defined, and maximum benefit is not being gained from the existing activities.

Recommendation An overall plan should be developed for performance monitoring and improvements. The plan should provide for systematic evaluation of pertinent plant systems and components and for trending of important plant parameters. Responsibility for implementing each portion of the plan should also be assigned. While written instructions or procedures may not be required, the overall plan, as well as results of program activities, should be documented and retained to provide consistency and to serve as a reference.

Response

Florida Power Corporation Management concurs with the intent of both the finding and recommendation made by INPO in this aspect of our plant operations. Florida Power Corporation remains committed to optimizing the performance of each generating plant. Improvements in the program for the Crystal River Nuclear Plant can best be made by organizing the several existing activities into a more formal overall effort. Revised program implementation is to begin by January 1,1982.

As an example, Nuclear Support Services is actively involved in definition, integration and implementation of an overall reliability program. This is an extension of the involvement by Florida Power Corporation in development a CR-3 plant specific reliability model, evaluation of the NRC's Integrated Reliability Evaluation Program for CR-3, participation in the Duke /NSAC's Probabilistic Risk Assessment Program and development and implementation of the Generation Equip-ment Availability Reporting System.

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CRYSTAL RIVER (1981) I APPENDIX Page1 ADMINISTRATIVE APPENDIX I. LISTING OF AREAS EVALUATED ORGANIZATION AND ADMINISTRATION - ON SITE 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 Survelliance Program OA-108 Personnel Qualifications TRAINING AND QUALIFICATIONS TQ-211 Training Organization & 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 ?ractices OP-303 Operations Organization and Administration OP-304 Use of Procedures OP-303 Plant Status Controls OP-306 Operations Facilities and Equipment OP-309 Shift Turnover MAINTENANCE MA-401 Maintenance Organization and Administration MA-402 Preventive N aintenance 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

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CRYSTAL RIVER (if,81) '

APPENDIX Page 2 RADIATION PROTECTION AND CHEMISTRY RC-501 Radiation Protection and Chemistry 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 and Calibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection P;agram TECHNICAL SUPPORT-ON SITE TS-702 On Site Engineering Support O

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APPENDIX ~~

Page 3 II. FLORIDA POWER CORPORATION CORPORATE AND STATION PERSONNEL CONTACTED Chief Executive Officer Senior Vice President-Construction and Engineering

'ssistant Vice President for Nuclear Operations lant Manager Management Specialist Director-Quality Programs Operations Superintendent Technical Support Engineer Training Supervisor Assistant to the Plant Manager Radiation Protection Manager Operations Engineer . . _ _ _. _

Maintenance Superintendent Maintenance Clerk Assistant Planning Engineer Building Services Supervisor Administrative Planner building Serviceman Instrumentation and Controls Supervisor Instrumentation and Controls Technician Electrical Supervisor Nuclear Electrician -

Mechanical Supervisor _

Nuclear Mechanic Nuclear Welder Maintenance Staff Pgineer Technical Services Supervisor Performance Engineering Supervisor Modifications Specialist Reactor Specialist Computer and Controls Specialist 1 Nuclear Operations Training Manager Nuclear Operations Instructor Chief Nuclear Operator _

Nuclear Operator i

Nuclear Shift Supervisor Nuclear Auxiliary Operator

• Assistant Nuclear Operator Assistant Nuclear Shift Supervisor Chemistry / Radiation Manager Plant Health Physicist Chemistry / Waste Manager Corporate Health Physicist Health Physics Supervisor

- Radiation Protection Specialist Chemistry / Waste Supervisor Site Manager of Nuclear Administration l

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