ML20010H179

Evaluation of Trojan Nuclear Plant

ML20010H179
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/31/1981
From:	Wilkinson E PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20010H178	List: ML20010H177 ML20010H179
References
NUDOCS 8109240060
Download: ML20010H179 (39)

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1 EVALUATION OF TROJAN NUCLEAR PLANT i

Portland General Electric Company 1

i July 1981 i

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I TROJAN (1980)

Page 1 4

SUMMARY

PURPOSE AND SCOPE An evaluation of site activities was performed at Portland Genraal Electric Company's (PCE) Trojan Nuclear Plant. The evaluation team was at the station.

during the wuks of December 1 and 8,1980.

The evaluation was based on preliminary INFO criteria.

Information was assembled from discussions, interviews, observations and reviews of policies and instructions.

Corporate activities were not included in the scope of this -

evaluation.

The team performed evaluations of station organization and administration, training, operations, maintenance, radiation protection and chemistry, 9nd en-site technical support.

Each area review was based on objectives of overall excellence and not minimum acceptable standards. Recommendations in this report, therefore, are not limited to minimum safety or reliability guidelines.

DETERMINATION Within the scope of this evaluation, the team determined that the plent is being operated safely. The following accomplishments and excellent practices were identified:

o A firm management commitment to ALARA principles exists.

o An industrial psychologist is employed on a long-term basis to assist in development of management and supervisory courses, facilitate periodic meetings between operators and management, and conduct studies-regarding motiJational factors 'in plant activities.

Station personnel express a respect and enthusiasm for this effort.

o Communications within and between divisions and departments is very good.

Opportunities for improvement were identified in the following areas:

o Formal written programs to provide guidance and management review for effectiveness need to be developed in certain areas, f

o t'. program is needed to ensure mechanical and electrical drawings and systems descriptions are kept current and available for all departments.

o A lack of adequate written direction exists. Many good practices and activities are being sustained by excessive reliance on experienced, highly i

qualified persons. ' Policies, programs and procedures have not ben developed to ensure that the quality of such practices would continue in the event of a decrease in the experience level of station personnel.

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Page 2 In order to ensure the management system that permitted a finding to exist has been corrected, it is recommended that PGE's management review of this report should consider possible generic significance of the findings and recom-mendations.

Programs or policy improv ments instituted should encompass broad functional consioerations as well as specific items for correction.

Specific findings and recommendations are in the accompanying DETAILS, and administrative information is in the ADMINISTRATIVE APPENDIX.

Initial findings were discussed with PGE station personnel during the evaluation. These findings were again reviewed with corporate management and station personnel at an exit meeting at Trojan on December 12,1980. Further discussion of PGE responses was conducted at the Trojan office on May 5,1981.

PGE responses to the report have been reviewed and are considered appropriate.

It is requested that PGE provide us written notification upon achievement of improvements at key target dates.

The evaluation staff appreciates the excellent cooperation received by all corporate and station personnel of the Portland General Electric Company.

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Page 3 PORTLAND GENERAL ELECTRIC COMPANY Response Summary Portland General Electric Company (PGE) agrees with the INPO conclusion that the Trojan Nuclear Plant is being operated safely and acknowledges the positive comments related to our r.;anagement commitment to ALARA principles, the involvement of an industrial psychologist in facility training efforts and the effectiveness of interdepartmental communications.

PGE acknowledges that areas exist where improvements can be made, as identified by INPO during their review of the facility, based on INPO objectives of overall excellence. We are committed to meeting or exceeding these INPO standards.

A number of recommendations were made regarding the need for formal, written programs to provide management review for effectiveness. Changes are being made to incorporate these recommendations as shown in the detailed response.

As INPO noted, PGE has recognized problems concerning updating of drawings and has established a program of control.

Complete implementation of this progra.n has been effected.

Additional detail and content covering normal operating practices are being added to plant procedures to provide the guidance which would be required for a less experienced staff.

Each INPO recommendation has been responded to ar.d, in general, PGE concurs with these recommendations. Although these responses tend to indicate a direct response, these findings have been and will continue to be evaluated from a generic standpoint.

PGE appreciated INPO's efforts in evaluating the manner in which our Trojan Nuclear Power Plant is being operated.

INPO involvement in assessing the effectiveness of planned and completed actions to improve this operation is aise l

invited. PGE will keep !N'rD ad. bed of actions related to key target dates.

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TROJAN (1980)

Page 4 DETAILS Findings referenced to a rpecific criterion within an INPO Evaluation Procedure are Category I, i.e., established standards of e.tcellence. Findings referenced to General Criterion are Category II; i.e., accepted industry practice or a not-yet-approved INPO criterion.

All findings listed are Category I except where designated as Category II.

ORGANIZATION AND ADMINISTRATION Station objectives, organizational structure, administrative controls, industrial safety and programs for quality assurance, information dissemination, sur-veillance tests and personnel qualifications were reviewed using current INPO criteria.

Plant organization and administration are effective and receive suitable management attention. It was noted that improvements cculd be made regarding station objectives, organizational structure, information programs and personnel qualifications.

OBJECTIVES (INPO Procedure OA-101, Rev.1)

An evaluation was performed to determine how effectively goals and objectives are disseminated throughout alllevels of the station and how effective they are in conveying intended operational and maintenance directions. Areas reviewed included the statim. mission statement, supervisory accountability, availability of station mission documents, assessment programs and measurement of gonk and objectives attainment. Station management has developed an effective method for deveicping department goals in addition to establishing station goals.

Determinations were made as follows:

1.

Finding (Ref. Criterion A)

A station mission statement is not y iblished. Review of the published station goals and objectives does not ceveal such a statement. Inter-views with station personnel evidenced a lack of understanding in regard to the station mission.

Recommendation A station mission statement should be developed in conjunction with the station goals and objectives. Further, this combined set of objectives should be promulgated to all levels at the station.

Response

A plant mission statement has been iraluded in the plant's annual objectives, which were issued in January 1981.

A copy of these objectives has been distributed to all plant supervisors, and will be covered in staff and group meetings so all levels of the staff are informed.

2.

Finding (Ref. Citerion B)

Some of the station supervisors were not aware of cr knowledgeable in their department goals and objectives.

TROJAN (1980)

Page5 Recommendation See recommendation for Finding 1, Criterion A.

Response

A copy of the plant's annual and monthly objectives, which are submitted to the Vice President, Nuclear, are now distributed to all plant supervi-sors. The plant's monthly objectives include goals and objectives of each department.

3. Finding (Ref. Criterion C)

Management goals and objectives toward achieving the company mission are not readily available.

Recommendation See recommendation for Finding 1, Criterion A.

Response

See responses to Findings 1 and 2 above. The monthly objectives are reviewed in group meetings and/or routed through each department.

ORGANIZATION STRUCTURE (INPO Procedure OA-102, Rev. 2.1 An evaluation was performed to determine how effectively the station is structured and managed to ensure safe, efficient operation.

Areas reviewed included applicability of the organization structure diagram, position descrip-tions for all station personnel, personnel performance evaluations, supervisors' span of authority, assignment of backup personnel for each plant management position and individual workload a signments.

The station appears to be adequately staffed, and overtime is well controlled. Determinations were made as follows:

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Finding (Ref. Criterion B)

Position descriptions for hvirly employees do not define authority, responsibility or accountability.

Recommendation Position descriptions should be developed fc.c hourly personnel based on job analysis. These position descriptions should define authority, respon,

sibility and accountability of individuals assigned to the job position.

Response

1 Position descriptions for hourly employees have been developed with accountability, authority and responsibility clearly defined.

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TROJAN (1980)

Page 6 ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Rev.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, lavel of administra-tive actions and program dissemination. Existing administrative orders cover all of the areas required by this INPO procedure. Determinations were made as follows:

Finding The criteria of OA-103, Rev.1, were met.

QUALITY PROGRAMS (INPO Procedure OA-104, Rev. 4)

An evaluation was performed to determine how effectively quality programs monitor and audit plant activities to ensure proper levels of quality. Areas reviewed included management controls, accountability program, program l

cross-checks, program effectiveness, program for corrective action and staffing.

Determinations were made as follows:

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Finding l

The criteria of OA-104, Rev. 4, were met.

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1 INFORMATION PROGRAMS (INPO Procedure OA-105, Rev.1)

An evaluation was performed to determine how effectively information perti-nent to operational safety and plant reliability is disseminated for review and l

l appropriate action.

A Nas reviewed addres:,cd the system for informa-tion dissemination, incluiing time factors, loop closure features and follcw-up J

verification. A program is in effect for controlled dissemination of pertbent I

information to appropriate departments at the station.

Determinations were 1

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made as fonows:

l Finding (Ref. Criterion C)

The existing program does not include a loop closure feature; therefore, the possibility exists for failure to perform a required action o" to recognize a potential station problem based on an off-site experience.

A station program is being developed that should satisfy the INPO criteria. Implementation was scheduled for Jaruary 1981.

Recommendation Complete those steps necessary to ensure the proposed review program addresses the INPO criteria of OA-105, Rev.1.

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Response

The Operating Experience Review Program, as defined in Administrative Order A0-9-4, was implemented in January 1981, and meets the INPO criteria.

INDUSTRIAL SAFETY (INPO Procedure OA-106, Rev.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 policies, manage-ment support for the safety program and employee and management inter-face in safety matters. Determinations were made as follows:

Findi.ig The criteria of OA-106, Rev.1, were met.

SURVELLANCE PROGRAM (INPO Procedure OA 207, Rev.1)

An evaluation was performed to determine that an effective program exists to accomplish required surveillance, inspection and testing. The surveil-lance program was reviewed for completeness, depth, acceptance cri-teria, results review, notification and control of off-standard conditions, and suitable scheduling and training in proper use of surveillance proce-dures.

The station's surveillance program is well defined and suitably managed. Determinations were made as follows:

Finding The criteria of OA-107, Rev.1, were met.

PERSONNFL QUALIFICATIONS (INPO Procedure OA-108, Rev.1)

An evaluation was performed to determine if a program exists that defines qualification levels in order to provide appropriately qualified personnel to operate and maintain the plant. Areas reviewed included the application of job and task analysis for each station position, the program for personnel selection and promotion and the program for periodic review of all job and task analysis.

It was noted the position descriptions for managers and supervisors are in the process of being revised.

Determinations were made as follows:

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TROJAN (1980)

Page 8 Finding (Ref. Criterion C)

There presently is no program to periodically review and revise personnel qualification requirements.

Recommendation Establish a program or policy to periodically review qualification requirements for all station positions.

Response

A new administrative order, which establishes a program to periodically review all plant position and job descriptions every 2 years, for adequate personnel qualification requirements, has been issued.

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Page 9 O-ty TRAINING AND QUALIFICATION i;

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Training organization, management, resources, and effectiveness were evaluated in 2ccordance with current INPO criteria.

The station training group is affcetive, well-organized and receives suitable management attention and sup-

cet.

It was noted that improvements could be made regarding training

sources and licensed operator retraining.

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E T'.AINING ORGANIZATION AND ADMINISTRATION dNPO Procedure TQ-211, Rev. 2)

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

rnnization that assigns responsibilities and delegates authority to accomphsh E

rainmg tasks.

Areas reviewed included the organizational struciare and metices, training staff size, ability and authority to schedule and provide k

required training and a review to see that training is performed in accordance zi:h written training plans.

The station has developed a well organized, g

y Mfective and responsible training group. Sufficient authority is vested in the

• ning group to successfully meet the training goals.

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t Finding The criteria of TQ-211, Rev 2, were met.

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(INPO Procedure TQ-221, Rev.1) x M'

in evaluation was performed to determine that adequate facilities, equipment f[

md materials are provided to support quality training programs.

Areas of

,nterest included review of facilities for suitable classrooms, laboratories,

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workshops, office space, training materials, aids and equipment, lesson develop-T ment and accommodations to support the trainers and trainees. The training 4

Ocup has succeeded in providing a very good training program with the facilities 7

ad materials provided. Determinations were made as follows:

W it Finding (Ref. Criterion F)

Q Training materials (system descriptions) and lessoa plans have not, for the most part, been updated since they were developed during the cold E

license training program. Review of the system descriptions and lesson L

plan files showed outdated system descriptions and lesson plans. As a 0;

result of using outdated material, instructor preparation time is signi-g ficantly increased; lectures providing consistent, cohesive information p

are more difficult to achieve; and trainee confidence in self-study material accurucy is reduced, as is the incentive for self-study.

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inputs provided by the station's " Request for Plant Change" procedure.

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Page 10 Plant change information is routinely made available to the training group.

Recommendation It is recommended that a program be developed and implemented to review and upgrade the existing station systems descriptions.

The priority for upgrading the existing lesson plans should be raised to a level that will ensure all lectures are supported with site-specific materials.

A long-range program should be developed for periodic review of system descriptions and lesson plans.

Response

The program of upgrading our lesson plans, which include system descriptions, will start in March 1981 and is expected to be complete by June 1982. A program for continued updating will be implemented as the lesson plans are upgraded.

i TRAINING EFFECTIVENESS (INPO Proced'tre TQ-231 Rev.1)

An evaluation was performed to determine whether the training provided to plant personnel is effective in meeting training objectives and improving operational performance. In the area of training effectiveness, the evaluation included measurement of trainee performance and instructor performance as well as auditing of training activities and correlation of training programs with job requirements. It was noted that reactor operators are trained at the senior reactor operator level. Determinations were made as follows:

Finding The criteria of TQ-231, Rev.1, were met.

L NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Rev.1)

An evaluation was performed to determine that an initial and continuing training program is established for non-licensed operators. Areas reviewed included the procedures for initial and continuing training of non-licensed operators, selection und promotion screening of non-licensed operators, utilization of classroom and on-the-job training and evaluation of trainees' fundamental knowledge level.

Finding

'lhe critcria of TQ-242, Rev.1, were met.

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i TROJAN (1980)

Page 11 LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Rev.1)

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 the licensed operator training program for content, base level of knowledge, training materials, source input, systems and fundamentals, operating practices, SRO training and candidate and program evaluation. Determinations were made as follows:

Finding The criteria of TQ-243, Rev.1, were met.

LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-244, Rev.1)

An evaluation was performed to determine the effectiveness of the requalifica-tion program to maintain a level of skill and knowledge for each reactor operator and senior r^ actor operator. Areas reviewed included development and use of training materials to inform licensed operators of procedure changes, licensee event reports, plant modifications, changes in station licensing requirements and vendor information affecting operation. In addition, station policy on use of a training simulator, periodic program evaluation and provisions for delinquent operator identification and requalification were reviewed. A good practice was noted in the development by the training group of Training Information Bulletins (TIBs). TIBs are used to make operators aware of a wide spectrum of events, plant changes and operating information in a timely manmr, utilizing a self-study technique. Determinations were made as follows:

1 Finding (Ref. Criterion D)

The criterion is not fully met in that off-site operating experiences are

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not given adequate, in-depth review. Interviews with ROs and SROs indicated a lack of awareness of the full ramifications of a number of off-site experiences. The TIBs do provide a general understanding of these events, but do not provide enough depth.

Recommendation

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A qualified person or group should have the responsibility to provide an in-depth review of off-site experiences to ensure all station operating practices and procedures are considered.

Develop the reviews program discussed in the finding of OA-105, Rev.1, Criterion C, to achieve an adequate depth of review.

Response

The Operating Experience Review Program implemented in January 1981 by Administtative Order A0-9-4, addresses the INPO criteria. The plant currently has six engineers qualified and assigned as shift technical advisors. Duties assigned to those personnel when not on shift include the detailed review of operating experience reports from other facilities and warking with appropriate plant staff, including training, for follow-up actions. In addition, two positions authorized for the Systems &

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TROJAN (1980)

Page 12 of which is still to be filled, will review platit operations against the Significant Event Reporta identified by the plant, INPO or NSAC.

SHIFT TECIINICAL ADVISOR TRAINING (INPO Procedure TQ-245, Rev.1)

An evaluation was performed to determine that a suitable training policy has i

been developed and implemented for shift technical advisor (STA) training and retraining. Areas of interest included a review of the STA training program for site-specific requirements, retraining program including on-site and off-site l

event analysis, simulator time and suitable documentation of all training. The j

long-term STAS were in the final stage of a good initial training program based j

on their educational background. A senior licensed operator was assigned the responsibility of overseeing current STA training and developing the retraining program. Determinations were made as follows:

Finding The criteria of TQ-245, Rev.1, were met.

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I OPERATIONS Coerations vas evaluated using current INPO criteria for performance in shift i

ecaduct organization and administration, and use of procedures for tagout, coerating, plant status controls aad shift turnover. The plant is clean and in

ood material condition. It was noted that improvements cculd be made in each

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of the seven performance areas evaluated.

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f CONDUCT OF SIIIFT OPERATIONS (INPO Procedure OP-301, Rev.1)

.in evaluation was performed to determine how effectively the conduct of shift

perations maintains quality shift performance. Areas reviewed included opera-

or activities, station cleanliness and order, response to abnormal conditior.s,

.:gxceping practices, reliability of control room instrumentation and operator ti

> vareness of plant conditions. The control room atmosphere is calm, orderly and f

ausinesslike. Determinations were made as follows:

k Pinding (General Criterion) (Category II) t Administrative procedures do not address the contents and requirements 4

of the following logs: Shift Supervisor, Auxiliary Building and Water E

Rover.

Proper logkeeping standards are necessary to ensure that meaningful, consistent operating histories are maintained for equipment condition and performance.

Recommendation i

Incorporate appropriate guides and controls in the applicable administra-tive orders for each station log maintained.

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Response

y Administrative Order A0-3-6, Conduct of Operations / Shift Record, has F

been revised to address contents and requirements for logs.

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(INPO Procedure OA-302, Rev.1) 7 in evaluation was performed to determine if established tagout practices ensure p

protection for personnel and station equipment. Areas reviewed included SRO 4

approval of safety-related tagouts, double verification of tagged equipment for E

personnel safety, double verification of important manual valves that are h

repositioned, tag coloring and numbering and review of clearance logs. The plant

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has developed tags that fit various switch types and do not obscure name plates

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cc instrumentation. Also, the safety-related equipment outage checksheet is a

ood system. Determinations were made as follows

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Finding (Ref. Criterion C)

Double verification of important manual valves following maintenance or testing is not performed or required by existing procedures.

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Page 14 Recommendation Establish administrative controls requ'a.ig double verification for all safety-related manual valves affected oy maintenance or testing.

Response

Important manual valves have been defined as being all safety-related locked valves Wat do not have control room indication. We will change Plant Safety Trocedure PS-3-30, Trojan Holdout and Tagging Procedures, to double verify these locked valves after maintenance.

Applicable Periodie Operating Tests (POTS) will also be revised to require double verification of locked valves whose positions are changed during the test.

This has been done. Administrative Order A0-3-13, Control of Locked Valves, has been revised to require double verification of those valves.

2.

Finding (Ref. Criterion D)

A second verification of equipment tagged for personnel safety and equipment protection is not performed consistently. Station Procedure PS-3-30 requires verification by the individual accepting a c!earance.

Interviews of station personnel indicate second verification occurs only if the clearance accepter deems it necessary.

Recommendation Station management should make clear the intent of the existing tagout procedure in regard to "second verification."

Response

Plant Safety Procedure PS-3-30 will be written to specify when double verification of tagged equipment for personnel safety is required. This has been done.

3.

Finding (Ref. Criterion F)

A periodic review of the tagout system for accuracy and consistency between the clearance log, hold-out card and danger tags is not performed. A review of these documents indicates discrepancies in the systcm as used.

Recommendation Develop and implement a policy to perform periodic reviews of the tagout system to ensure proper and timely restoration of equipment operability.

Response

Administrative Order A0-2-2, Review Responsibilities, has been revised to require operators to check the Hold-Out Tag and the Caution Tag Logs once per month during operation against the actua! tags in the plant. This review will also evaluate whether the tagout is still needed.

This will also be done for the Caution Tag Log.

l 0RGANIZATION AND ADMINISTRATION (INPO Procedure OP-303, Rev.1) l An evaluation was performed to determine the existence of a clearly defined l

operations organizatbn that assigns responsibilities and delegates adequate l

a TROJAN (1980)

Page 15 authority for accomplishment of required tasks.

Areas reviewed included organizational structure, job descriptions, shift administrative assignments, written and oral instructions and miscellaneous administrative programs. The recently established position of Assistant Operations Supervisor, when manned, should reduce the shift administrative work load. Determinations were n ide as follows:

Finding (Ref. Criterion D)

The shift supervisors' (SS) administrative work load is excessive. Present requirements for SS collateral duties included scheduling shift and Periodic Operating Tests (POTS), filing records and Design Change Procedures (DCPs), writing monthly reports, review of procedures and their changes and additional delegated reviews as assigned by the Operatiors Supervisor.

Recommendation Review SS administrative assignments.

Reassign tasks that do not require the particular talents of the SS group.

Response

I The assistant operations supervisor position has been established to assist the operations supervisor with many of the administrative duties formerly assigned to the shift supervisor, which are not required to be done on shift. This new position was filled February 16,1981.

USE OF PROCEDURES (INPO Procedure OP-304, Rev.1)

An evaluation was performed to determine proper use of procedures to conduct plant operations safely and reliably.

Areas reviewed included management policy for use of procedures anr1 change of pr >cedures (short-term and long-term). In addition, procedurns were reviewed for clarity, continuity, identifica-tion of " sequence-required" ut:tions and suitable advisory information. Use of a movable cart for control room procedures is a very good practice. Determi-nations were made as follows:

Pinding (Ref. Criterion A)

Administrative orders for use of procedures do not define those portions of emergency response procedures (ERPs) required to be performed from memory. Additionally, there is no defined requirement for performing specific activities with procedures "in hand."

Recommendation Establish and implement administrative controls to define those portions of ERPs that are to be memorized. Establish and implement a policy concerning "in-hand" use of procedures.

Response

Administrative Order A0-4-2, Use of Procedures, has been revised to specify that only procedure check-off sheets are required to be "in hand" during performance of the specified activities. A0-4-2 has also been revised to define which symptoms and immediate operator actions of the Emergency Instructions and Off-NormalInstructions must be mamorized.

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Page 16 PLANT STATUS CONTROL (INPO Procedure OP-305, Rev.1) 1 j

An evaluation was performed to determine that 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 the senior licensed j

operator assigned to monitor and review status control; and provisions for status control under special conditions such as outages, accident recovery or rt. fueling, j

A number of good practices were obscrved at the station that are not set forth in i

procedures. Determinations were made as follovn::

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Finding (Ref. Criterion A)

Administrative procedures do not provide guidance for the use of control room status boards.

As a result, status boards are not current cz 1

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informative and do not aid in station operation.

h Recommendation 3-Establish and place in effect guidance for the use of station status r

t,oards. This should include types of information required, frequency of i

update, frequency of review, individuals responsible for reviewing and who is responsible for maintaining these boards.

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%sponse j

Administrative Order A0-3-6, Conduct of Operations / Shift Records, has been revised to include the control room status board and delete

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information from the status board that is provided in other places.

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2. Finding (General Criterion) (Category II) l Policies or procedures are not established to control the use of labels, graphs, notes, iratructions, markings and drawings of a temporary j

nature. Examples of the:>e are found throughout the station; they are j

unsigned, undated and unclear in many cases.

n Recommendation 4

Develop and place in effect a policy to control the temporary use of g

labels, notes, instructions, etc., used at various locations in the plant.

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Response

y Notes on panels outside the control room have been removed. Notes that i

contained useful info: mation were replaced with caution tags, permanent 3-labels or placed in plant procedures.

)j An index of piping and instrument diagrams (P& ids) and procedures used 3

outade of the control room has been provided and is used to control h

these items. These controlled P& ids and procedures have permanent storage containers to protect them from loss or damage.

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l OPERATIONS FACILITIES AND EQUlf MENT (INPO Procedure OP-306, Rev.1) g i

f An evaluation was performed to determine if plant facilities and equipment are 9

operable and maintained in a manner that ensures safe and efficient operation.

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Page 17

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Areas reviewed included equipment operability, equipment availability programs, effect of the working environment on safe and efficient station operation, acequacy of communication equipment and watch station assignments.

The steam plant end auxiliary spaces are clean, few equipment or system leaks exist, and general mtterial condition of the station is very good. Determinations were made as follows:

1.

Finding (Ref. Criterion B)

The " Routines" program in use at the station does not previde adequate guidance for the operator making his rounds and is therefore less effective than it could be. This program does not contain sufficient de-tail to monitor equipment service needs or trends and does rot require all equipment to be checked.

Recommendation Estat,lish a program to provide specific guidance to operating personnel making rounds and checking equipment.

Response

Administrative Order A0-3-6, Conduct of Operations / Shift Records, will be revised to include guidance on what equipment to check by June 1,1981.

Important set points, alarms or items to check will be noted locally on panels or equipment. These notations will be permanent labels or controlled documents.

This will be completed by January 1,1982.

k WATCil TURNOVER (INPO Procedure OP-309, Rev.1) r An evaluation was performed to ensure that continuous, correct understanding of station conditions is maintained at all shift positions. Areas reviewed included

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programs and policies controlling turnover practices for watch stations, checklists, operating panel reviews and station activities in progress or planned.

~m Observation of control room practice indicates sufficient information is con-

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veyed during shift turnover to avoid unsafe operation.

Determinations were j

made as follows:

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Finding (Ref. Criterion A)

I An approved procedure detailing turnover requirements has not been developed for the positions of shift supervisor ar assistant control operator.

Recommendation Develop additional procedures or expand existing procedures to detail turnover requirements for shift supervisors and assistant control opera-tors. This procedure should include the guidelines for use of the watch turnover checksheets described in Finding #2 below.

Response

Administrative Order A0-3-6, Conduct of Operations Shift Records, has been revised to include turnover requirements for shift supervisors and assistant control operators.

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Page 18

2. Finding (Ref. Criterion B)

Turnover checksheets have not been developed for shift supervisors or assistant control operators.

In addition, cheebheets for the control operator do not include reviews of pcrtinent watch information mate-rials, i.e., elecrance log, jumper log, nignt orders and standing orders to achieve adequate continuity between shif ts.

Recommendation i.,evelop and implement turnover checksheets for shift supervisor and assistant control operator.

Modify the control operator turnover checksheets as necessary to include reviews of pertinent information materiais such as status boards, clearance log, standing orders, night orders, etc.

Response

Checksheets have been changed to make them more useful. They include i

clearance log, jumper and lifted lead notebook, Operations Supervisor's notebook (night orders) and control room log. These items are broken down into things that are checked during the turnover. Checksheets will be utilized by the shif t supervisor, and the assistant control operator will sign off on the control operator's checksheet.

3. Finding (Ref. Criterion C)

Procedures have not been developed to walk down all control room consoles for adequate status review to ensure all on-shift licensed personnel are aware of system conditions.

Recommendation Develop additional procedures or expand existing proceduces to require review of control room panels by all licensed personnel on shift

Response

A general walkdown of the control board is now required as part of the turnover sheets.

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F Page 19 p

f MAINTENANCE

[

Seven performance areas were examined using current INPO criteria. The areas reviewed included maintenance organization, corrective and preventive maintenance (PM), administrative programs, procedures, equipment history and maintenance facilities.

Tne Trojan maintenance staff and organization were noted to be a strength. The staff was found to be well organized and comprised of capable and motivated persons. There was good evidence of effective cooperation and communication between supervisors and workers. Maintenance planning and scheduling is also a favorable feature. The assignment of a supervisor and foreman full-time to implement the planning function can be considered an example of an excellent maintenance practice.

Areas where improvements are recommended include maintenance procedures, work control systems, maintenance history, control and calibration of test equipment and instrumentation, and maintenance facilities and equipment.

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

An evaluation was performed to determine how effectively the maintenance organization and administrative programs contribute to the performance of maintenance tasks. Areas reviewed included the organizational structure and reporting requirements, staff size, training and retraining, position descriptions for maintenance personnel, span of control for superiisors and certain adminis-trative programs.

An effective method for accomplishing the planning and scheduling of mainte-nance work is provided by the assignment of a full-time maintenance planner.

The plant policy of assigning a foreman to support the planning function contributes to the effectiveness of this activity. Determinations were made for the area of maintenance organization and administration as follows:

Finding The performance criteria of MA-401, Rev. 2, were met.

l PREVENTIVE MAINTENANCE PROGRAM l

(INPO Procedure MA-402, Rev.1)

An evaluation was performed to determine the effectiveness of the maintenance of fort to optimize equipment reliability and performance.

Areas of review included an assessment of formalized preventive maintenance (PM) programs, equipment included in the program, type and frequency of PM, effectiveness of program control and coordination.

In addition, implementation of the PM program was reviewed for completeness.

Determinations for the area of preventive maintenance are as follows:

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Page 20 i

Finding The performance criteria of MA-402 were met. A concern does exist for Criterion D of this area and is considered in the finUng determined for M A-403, Rev. 2.

MAINTENANCE PROCEDURES (INPO Procedure MA-403, Rev. 2)

An evaluation was performed to determine the quality and effectivenass of maintenance procedures. Areas reviewed included an assessment of activities governed by procedures, methods for procedure development and revision and content of procedures. The extent that maintenance procedures are actually utilized for accomplisi? ment of work was also within '.he scope of the evaluation.

Opportunity for improvement was noted in the following area:

Finding (Ref. Criterion A)

Approved instructions in the form of individual or specific procedures are not provided for certain safety-related equipment and critical br. lance-of-plant items. The existing use of generic procedures (such as MP-1-16, Motor Maintenance) does not fully satisfy the intent of this criterion in that management controls are not sufficiently detailed or specific to provide the best assurance of reduced human errors and quality maintenance. The equipment vendor manuals that are being used also do not satisfy the intent of the criterion in that they are not approved as part of the procedure review process.

This finding also addresses the concerns of Criterion D of INPO Proce-dure MA-402, Preventive Maintenance.

Recommendation Provide individual or specific maintenance procedures for work on safety-related equipment and critical balance-of-plant equipment. The contents of these procedures should be subjected to reviews and ap-proval by appropriate plant personnel. Procedure content should provide specific details for precautions, prerequisites, quality control hold points and other details unique to the equipment being serviced.

Plant maintenar.ce procedures which rely on references to vendor manuals for work instructions should be revised to incorporate the instructions into the procedures. Alternately, those manuals which are referenced by procedures should be subjected to a review which is equivalent to that provided for plant procedures, and the manuals should be specifically approved for use with the applicable plant procedure.

Response

We feel that in many cases it is reasonable and proper to reference a specific section(s) of a vendor m9nual.

Maintenance ProcedurS and lower tier maintenance procedures will be reviewed to ensure references are specific and that the sections referenced are adequate. This review, which was made by the Maintenance Department engineering staff, has been completed for electrical and instrument and control work and will i

be completed by November 1,1981, for mechanical work.

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Pege 21 1

?

A problem is recognized in that vendor manuals are not currently controlled dccuments. Selected vendor manuals will be made controlled documents, and a mechanism for making changes to all official copics will be established. Although vendor prints have been updated, these changes have riot been inserted in the vendor manuals. Selected vendor manuals will be controlled and vender prints inserted by June 1982.

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WORK CONTROI, SYSTEM (INPO Procedure MA-404, Rev.1)

An evaluation of this area was performed to determine the effectiveness of the work control system in u e at the plant. The system functions were checked to see if they define and,uthorize work to be performed by the maintenance groups; provide for the planning, scheduling, and control of actual work; and have a mechanism for inputting the maintenance results into an equipment history file for future evaluation. The plant has an effective work control system.

In particular, the planning and scheduling of work is well done, and the history files are well maintained and readily available to maintenance personnel.

Determinations were made as follows:

Finding (Ref. Critefion B.3.h)

There is no clearly stated requirement that a determination be made if proposed worm (Maintenance Request) will modify equipment from its original design. The Maintenance Request (MR) form does not include a provision to oocument the maintenance item covered by the MR has been evaluated as a potential design change. Trojan Plant Administra-tive Order AO-3-9, Rev. 6 Maintenance Requests, does not require that 5

this determination be made prior to work authorization. As a result, it would be possible to !nadvetently cause a design change in the process of accomplishing a repair (e.g. substitution of parts with different characteristics due to non-availability of precise replacement part needed).

Recommendation Revise administrative controls governing reviews of proposed MRs (such as Procedure AO-3-9) to determine the need for a design change review prior to commencing the MR work. The format of the Maintenance Request Form should be revised to include some type of reminder and checkoff to document this review.

Response

A revision to Administrative Order A0-3-9, Maintenance Requests, has been made to require a determination be made as to whether a design change is involved and to specify the review and action required if a design change is involved. A block has been added to the MR form to document the results of this review.

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TROJAN (1980)

Page 22 MAINTENANCE HISTORY (INPO Procedure MA-405, Rev. 2)

An evaluation of this area was performed to ensure a maintenance history file is in use that will support an evaluation program and contribute to improved equip-ment 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. The maintenance history program in use at the plant is well maintained and is used to assist in follow-up maintenance. Determinations were made as follows:

Finding (Ref. Criterion D)

A structured method for periodic review and evaluation of maintenance history is not established. Present reviews are limited to items that are the subject of specific inquiries or which have been noticeable problem areas. The revicws described by Plant Administrative Order AO-2-2, Rev. 5, " Review Responsibilities," do not satisfy the criterion in that they are limited to checks of adequacy and completeness.

Recommendation Establish a formal method for periodic review of the history files to determine trends and to perform engineering evaluations. This program should identify the frequency and nature of reviews necessary to provide input for evaluations of equipment performance ano maintenance effee-

• iveness. Review program requirements 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 failure, cause of failure and corrective action necessary to prevent recurrence. The history review program should provide a loop closure feature to ensure necessary changes in operating or maintenance practices are made.

Response

Periodic reviews and evaluations are being performed but have not always been formally documented.

A Maintenance Department procedure has been prepared that describes the preventive maintenance program, details the methods used to determine equipment conditions, requires identification of problems, and i

defines corrective actions.

Future annual reviews will be fermally documented in accordance with this procedure.

In addition, all completed MRs are now being reviewed on an on-going basis as they are placed in the equipment history files in accordance with the requirements of MP-4-1.

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l CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION i

(INPO Procedure MA-406, Rev.1)

An evaluation was performed to ensure that available facilities and procedures in l

cffect support the need for accurate test equipment and instrumentation. Areas l

reviewed included identification, calibration, storage, issuance, use, shipment l

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TROJAN (1980)

Page 23 and documentation. A program for control and calibration of test equipment and instruments is essential to maintain accurate plant instrumentation and resultant l

safe plant operation. Determinations were made as follows:

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Finding (Ref. Criterion F)

}

The storage of Instrument and Control (I&C) test equipment is crowded and does not meet the intent of this criterion in that conditions are not appropriate to maintaining instrument quality. Instruments kept in the shop were found stacked and non-segregated. insufficient shelf space requires storage of some instrumunts on work benches and shop furni-ture. Instrument storage located behind the control room consoles was also identified as an are.a warranting improved storage arrangement.

The intent of this criterion also was not satisfied in that test devices which are identified as out-of-specification are not provided a separate storage location to preclude their int.dvertent use.

1 Action to improve the crowded shop facilities has been indicated by plans to include an expanded shop area in the new building addition now under construction.

Recommendation i

Provide expanded storage space for I&C test equipment to accommodate all of the controlled items. A separate storage area should be estab-lished for rejected test devices to preclude thei' inadvertent use.

Response

Expanded storage space will be provided by expanding the I&C shop area.

This project will be completed by January 1983. The expanded shop will also allow the use of separate storage areas for rejectad test devices.

The storage of I&C equipment outside the shop area has been improved, on an interim basis, by using locked storage cabinets.

2.

Finding (Ref, Criterion G)

The intent of the criterion is not met in that the lack of positive controls for the issuance of test equipment does not provide the best assurance that devices are used by persons qualified to determine the correct applications. I&C test equipment is stored on open shelves accessible to anyone.

Recommendation Establish a control system that will effectively prevent unauthorized use of the I&C test equipment. This system should be sufficiently flexible so as not to inhibit access to test equipmt.nt by approved personnel.

Response

The I&C shop is normally staffed or locked to preclude the indiscrim-inate use of test equipment by unqualified personnel. The location of the I&C shop adjacent to the control room further discourages entry by unauthorized personnel. In addition, locked storage cabinets are now in use for storage of I&C equipment outside the shop area.

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TROJAN (1980)

Page 24 MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Rev.1)

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

Finding (General Criterion) (Category II)

A stock of repair parts and materials should be readily available to the maintenance organization. The materials indexing system in place at the plant _ warehouse is not adequately organized to permit timely location of -

items required in support of maintenance. The generic type indexing system being used does not effectively interface with the maintenance 4

staff's capability to identify needed materials.

Trojan warehouse personnel have previously recognized this concern. A corporate representative from the computer management group has been brought on site for the purpose of preparing a proposal for an upgraded inventory indexing system.

Additionally, the plaat is reviewing a i

proposal for a computer-based maintenance management system that j

may address this area.

Recommendation Institute an improved system for locating parts and materials. The p

indexing of stock items should be made sufficiently flexible to promote j

efficient receipt and storage of materials as well as to provide a -

Ll capability *

~ ily identify stock items from specifications or descrip-

'3 tions nor-

,ailable to the maintenance organization. The ware-I housing revmws currently being performed by the plant should be pursued as necessary to provide a timely resolution of this concern.

Response

Development of a computer-based Maintenance Management System is planned which will meet the above criteria. The portion of this system l:

for identifying and locating parts.and materials will be completed by

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January 1983.

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TROJAN (1980)

Page 25 RADIATION PROTECTION AND CHEMISTRY Organization, admir8stration, radiological protectio 1, liquid waste control and process water chemistry were examined in light of IllPO criteria. This portion of the evaluation was primarily an examination of plart programs and facilities as they function under normal operating (non-outage) etnditians. With this in mind, it was concluded that the plant's radiation protection and chemistry programs were being conducted in an efficient and professional manner which provided sufficient controts to protect the public, plant workers and the environment. It was noted, however, that improvements could be made in some programs, procedures and facilities. These areas for improvement are discussed in each individual evaluation topic below.

RADIATION PROTECTION AND CHE!WISTRY ORGANI2,ATION AND ADMINISTRATION (INPO Procedure RC-501, Rev.1)

An evaluation was performed to determine the effectiveness of the radiation protection and chemistry organizations and their associated admin!strative control mechanisms in providing the level of services currently required at the plar.t under normal operatVC ccnditions. The organizational structure employed during the most recent refueling outage was reviewed, and projected plans for staff increases were also considered when evaluating the staff nructure end size. Areas reviewed included the formal organizational structure, procedures for conduct of operations, staffing levels, training and retreining programs, position descriptions and management authority.

Both the radiation protection and chemistry groups were organized and adminis-tertid in an effective manner. Several good n:anagement practices were evident.

Adequate advance planning was underway for handling future reeds of the organizations. Communications between these groups and other plant organiza-tions were observed to be excellent a spite of the separated nature of the physical facilitier. The level of staffing appears to be adequate, provided that additional personncl are hired into the radiation protection organization as planned. Determinations were ma# as follows:

Finding (Ref. Criterion B)

The plant and corporate procedures that address the conduct of operations for radiation protection have not been revised to reflect the organizational changes that have occurred since the procedures were first prepared about two to three years ago, Neither tne corporate radiation protection program procedure (PGE 8005) nce the on-site Radiation Protection Manual agree with the current on-site organizatica.

Plant Administrative Orders A O-1-5 and AO-1-8 do not include responsibility statements for the positicns of radiation protection engineer, radiation protection specialist, radiation protection records coordinator and rad:ation protection utility man.

It was noted that the radiation protection supervisor has made plans to revise the plant's Radiation Protection Manualin 1981.

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TROJAN (1980)

Pago 26 Recommendation The Radiation Protection Manual, AO-1-5, AO-14 and PGE 8005 should be revised to reflect the actual plant omaniwion and new corporate org9nization, where appropriate.

Respoase Changes Pave been made to administr:tive orders and to the Chemistry and Radiation Protection Manuals to reflect the current organization and current responsibilities. PGE-8005 will be revised by September 1,1981.

ALARA PROGRAM (INPO Procedure RC-502, Rev.1)

An evaluation was performed to determine the effectiveness of efforts toward maintaining personnel occupational radiation exposure as low as is reasonably achievable (AL.UtA) at the plant. Areas of !nterest included the company's ALARA policy, responsibilities for ALARA, level of review for the ALARA program, systems for setting goals and measurinr* progress and overall scope of ALARA activities. Plans for the development of e pinnt-level, formal ALARA program were also reviewed and were consideree m the evaluation process.

The plant did not have a separate, formal ALAR' programs however, the radiological protection activities reviewed included sufficient ALARA aspects to indicate that an informal program existed. E.<amplea of gor,d ALARA practices included, but were not limited to, the use of a portable shielding rig for reactor vessel head stud detensioning and tensioning, the use of a shielded, remotely-operated filter handling mechanism and tb9 provision for job pre-briefings in the radiological work permit system. The key elements of an excellent ALARA program were observed to be readily availcole for incorporation into the planned, formal program. Determinations were mede as follows:

Finding (Ref. Criterion D)

Exposure accumulation (man-rem) goals are not routinely set for all major types of radiological work. In practice, job-specific goals have been set and monitored f6c some types of radiological work. The formal ALARA program under development includes a system for establishing job specific goals; however, the computerized exposure records system's programs and outputs have not been improved to provide the best management tools possib!e to svaluate perfermance against these goals.

Recommendation The plant should cortinuo development of the formal ALARA program as planned. Concurrently, steps should be taken to expand the screening processes and output reports available from the computerh;ed exposure records system so that progress toward job-specifie goals cnd overall exposure trends can be readily reviewed and evaluated.

Respome The Trojan plant ALARA program has been fully implemente-t Radia-tion Protection forms RP-121 and 122 estimate the exposure by job and task. Daily computer printouts of exposures are prepared for all plant personnel and for each ALARA budgeted job. The program uns the L

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TROJAN (1980)

Page 27 headings of 1) job, 2) RWP number, 3) estimated exposure and 4) actual exposure to date. These programs ere reviewed daily for trends and to detect exposure potential problems.

PERSONNEL DOSIMETRY (INPO Procedure RC-503, Rev.1)

An evaluation was performed to determine the effectiveness of the plant's dosimetry program in :neasuring, 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.

Plans for the implementation of a new external dosimetry system involving the on-site processing of thermolummescent dosimeter (TLDs) were also reviewed. The dosimetry prograta was judged to be adequate for current needs; however, improvaments were possible.

Determinations were made as follows:

1.

Finding (Ref. Criterion C)

The plant's radiation protection procedures that cover the conduct of the personnel dosimetry program do not address the methods that are currently used for comparison of pocket ion enamber (PIC) results and TLD results or the corrective actions that are taken for out-of-lolerance camparisons.

Comparisons are performed and approp.iate action is taken when warranted; however, this process depends to a large degree on the knowledge and conscientiousness of one or two I:cy individuals. In view of the upcoming changeover to a new TLD system, the lack of procedural guidance in this critical area could result in confusion for both plant personnel and the system vendor.

The plant radiation p otection procedure that addresses personnel skin contamination under non-emergency conditions (RP-112) does not cover the evaluation of skin dose which might result from significant levels of contamination.

Recommendation The plant should revise the existing dosimetry procedure (s) to inco m -

rate the methodology for performing TLD/PIC compari. ions and N reccedkeeping requirements for TLD results correctio% in addition, d improvements in the computerized expcsure records system are undar-taken as a result of this evaluation or implementation of the new TLD system, then development of a routine fo' automatic comparisons and error identification should be considered.

Peceedure RP-112 shoold be revised to incNde a recommendation for evaluation of the poten!!al skin dose above a predetermined contamina-tion level. The procedure should also recommend that the evaluation method used in such cases be fully documented.

Response

A computer program to comparc PIC and TLD values has been developed. The program compares indivioual PIC and TLJ values and develops statistical summaries of the data.

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I TROJAN (1980)

Page 28 A procedure for PIC and TLD value comparisons will be developed along i

l with other dosimetry computer procedures by October 1,1981.

A procedure has been prepared to require skin dose calculations when i

applicable. The procedure also requires an exposure investigation to be made and documented if persorel skin contamination is greater than 5 mracine.

2.

Finding (Ref. Criterion D)

Quality control checks are not routinely performed on the current vendci's dosimetry processing and records systems. Spiked TLDs (TLDs exposed to a dose unknown to the vendor but known to plant personnel) are not submitted to the current vendor for purposes of checking the accuracy of the vendor's TLD processing and reports generation systems.

Recommendation Due to the short time before the changeover to the new TLD system, incorporation of quality control checks into the old (existing) system is probably not practical. The new system under development includes so;ne vendor-initiated quality control checks which should be adequate for checking hardwcre securacy. The plant should develop additional methods for performing total system quality control checks on the new system, including aof tware accuracy checks.

Response

The plant will. <.s it does now with Eberline, review all exposure reports received. Curectly this is done manually by the Radiation Protection staff by comparing TLD readings against the PIC exposure reported on radiation work permits (RWPs).

A computer program has been developed, and the overall pmcedures to compare PlO and TLD readings will be developed by October 1981. 'See response to RC-503, Criterion C.) Software checks are not performed by plant personnel, but are a part of the overall QC provided by a third party review. We do not believe that the plant's involvement in reviewing the software serves any benefit when added to our program of exposure comparison of PIC to TLD.

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l RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Rev.1)

An evaluation was performed to determine the effectiveness of the plant's radiological surveillance program and radiological work controi mechanisms in l

identifying radiological hazards to workers and management e.d in minimizing i

the magnitude of thm hazards. Areas of interest inclufd surveilhnee program procedures, surveinance p ogram seobe, radiological conditions in the plant, surveillance methodo% and the level of management review of serveillance d:ta. The radiological surveillance program and work control methods were effective in identifying radiological hazards and minimizing personnel radiation exposure. Determinations were made as follows:

Finding The criteria of procedure RC-504, Rev. I were met.

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htOJAN (1980)

Page 29 WASTE AJD DISCHARGE CONTROL (LIQUID)

(INPO Procedure RC-505, Rev. 2)

An evaluation was performed to determine the effectiveness of the plant's liquid weste control programs in minimizing the generation of liquid radioactive waste (radwaste) and limiting releases to levels as low as is reasonably achievable KLARA). 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; however, opportunities for improvement were nc+cd. Determinations were made as follows:

1.

Finding (Ref. Criterion D)

There is no comprehensive program for routine sampling emi radioactiv-ity analyses of systems which are normally not contaminated. Service water is sampled routinely and the service air system is sampled when used to supp!y breathing air stations; however, systems such as deminer-alized water and notable water are not sampled for radiosctivity.

Recommendation The plant should develop and implement a routine sampling program (for radioactivity) for those normally clean systems which, through system leakage, improper valve lint ~ups, valve failures or improper jumper hose connections, could become radiologically contaminatad. Gross activity analyses are acceptable unless activity is detected, in which case, specif!c nuclide identification (spectroscopy) would aid in determining the source of the contamination.

Response

A program has been implemented for monthly sampling of systems normally not contaminated.

RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure 2C-506, Rev. 2)

An evaluation was performed to determine the effectiveness of the plant's radiological survey equipment entrol and calibration program in mahttaining a su'*:cient inventery of instreraents 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, equipment identifilat'on and evaluations for out-of-tolerance equipment. Adequate numnm and types of operable instruments were observed in the plant to support normal operations. The instrument control (md calibra-tion program was effective in accomplishing its intended purpose.

Deter-

)

minations were made as follows:

Pinding The criteria of procedure RC-506, Rev. I were met.

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TROJAN (1980)

Page 30 PERSONNEL IIEALTll PIIYSICS INDOCTRINATION (INPO Proacdure RC-507. Rev. 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 the available methods for minimizing exposure.

Areas reviewed included management policy, scope and depth of the indoctrie-tion, the training environment and training documentation.

The health physics indoctrination is presented as a part of general employee training and consists of videotar*e presentations r.1pported by live instructors. In addition, personnel who will work in radiological controlled areas are given the opportunity to practice and demonstrate proficiency at donning and removing anti-contamination clothing, reading pocket ion chamber dosimeters and frisking under the supervision of an instru2 tor or a member of the radiation protection group.

Taken as a r: hole, the indoe trination program was structured and conducted in a manner that achieved the objective of preparing personnel to work in radiological controlled areas of the plant. Determinations were made as follows:

Firding (Ref. Criterion B)

The videotape that is used to instruct workers in radiation protection fundamentals needs improvement in content and quality. The material presented in this tape directly affects workers' understanding of radio-logical hazards and their abilities to maintain their exposures ALARA.

In eddition, the tape can influence the workers' perceptions of the m tion in their jobs and mangement's signi'!:ance of radiation pro e

commitment to maintaining tiieir exposures ALARA.

Recommendation The radiation protection fundamentals videotape should be revised to ensure it is aimed at the level of understanding and interest of the avert.ge worker. The understandability of the tape may be evaluated by reviewing the number and ines of questions asked by viewers and by written or orcl examination of viewers. As a minimum, the revised tape should be reviewed and approved by the radiation protection supervisor.

In addition, it may be desirable to test the tape on selected audiences of non-plant personnel (e.g., a group of utility workers from a company fossil plant) to evaluate its effectiveness in delivering the desired in-formation.

Improvements needed in the videotape include the following:

The plant's adniinistrative weekiy exposure guidelines should be o

discussed along with guidance on what the worker should expect for

" reasonable" levels of exposure in his/her job.

The timing of exposure (outage vs. non-outage) should also be discussed.

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TROJAN (1980)

Pags 31

!i o Workers should be clearly instructed in their responsibility to report immediately to management any observed conditions which might l

cause violations of regulations or unnecessary exposure. The option for reporting to the NRC should also be covered, but the worker's i

responsibility to plant management should be stressed.

Response

The general employee radiation protection videotape has been revised with input from the Generation Licensing & Analysis, Human Resources and Trojan's Radiation Protection and Training Departments.

PROCESS WATER CONTROLS (INPC Procedure RC-508, Rev. 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 corrosiot and, in addition, the chemistry group was performing routine photographic surveiLance e i open systems (during outages) to assess the type and degree of corrosion. Determinetions were trade as follows:

Finding (Ref. Criterion B)

Comprehensive, formal cor.:rols are not in place for the issuance or use of decontamination agents, sealants and solvents which may be corrosive to process system materiab Some cleaning agents are prohibited fcr use on site due to effluent regulations. In addition, there are quality eaurance controls on items that are ta' m into containment.

The evaluation did not reveal any Ireidnts whew corrasive agents had been inadvertently introduced into plent systems.

Recommendation The plant should develop an administrative procedure or procedures for the control of chemicals whicl. may be harmful to syr. n materials or personnel. Training should be conducted upon implementation of tne procadure(s) to ensure that affected personnel understand the control methads to be employed.

Response

A procedure for controbing chemiccb has been implemented.

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IIEALTH PHYSICS FACILITIES AND EQUIPMENT l

(INPO Procedure RC-509, Rev. 2)

An evaluation v.as performed to determine the effectiveness of the plant's health l

physics facilities and equipment in satisfying plant needs and in contributing to

TROJAN (1330)

Page 32 i

safe and efficient plani operation. Areas of interest included the number and types of instruments and equipment, the protective clothing inventory, the design and working environment of facilities and the ease of access to and physical conditions of radiological controlled areas.

The original plant design pr6vided only limited space for health physics facilities, and the majority of this space was centered around the main access control area.

Plant gersonnel have attempted to utilize the available space in the best possible manner.

Radiological conditions and cleanlinese of controlled areas were observed to be excellent, and it was evident that an intensive, ongoing program c' decontamination and cleani#g was in place and was effective in ensuring easy acem,s to the plant. Determinations were made as follows:

Finding (Ref. Criterion C)

Existing health physics facilities are overcrowded and in some cases inadequate to support certain activities such as respirator decontemina-tion, instrument maintenance and calibration, counting instrument oper-ation and radioactive materials storage. The plant has initiated plans to mod!fy the main access control area to improve the facilities there and

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obtain the most efficient arrangement of health physics functions

l possible within the limited space available.

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Recommendation The planned reconfiguration of the access control area should considera-bly improve the efficiency of the health physics facilities in that area; however, since very little new space will be created, problems will still remain for some of the areas mentioned. The plant should mvestigate the possibility of converting more space within the auxiliary building to health physics use and of constructing additional storage space for radioactive materials.

I

Response

Additional space will be made available as a result of the Control j

Building modification. This will be complete by July 1,1982.

The process steam boiler area will be converted to a respirator mainte-nance area by July 1,1982.

A roof will be constructed ovu the outside radwaste storage area by July 1,1982.

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TROJAN (1980)

Page 33 RESPIRATORY PROTECTION PROGRAM (INI'O Procedure RC-511, Rev. 2)

An evaluation was performed to determine the effectiveness of the plant's respiratory protection pecgram !n proteethg personnel from airborne hazards, areas reviewed included policy and procedures, Identification and control of airborne hai.aris, selection and use of respirators, resolrator maintenance and emergency cape.bilities. The plant program was judged to be adequate for the protection of personnel ftom known haza-ds.

Determinations were made as follows:

Finding The criteria of procedure RC-511, Rev. 2 were met.

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e TROJAN (1980)

Page 34 TECIINICAT, SUPPORT On-site engineering support was evaluated against current INPO criteria. The interface with corporate engineering and the on-site group is effective. It was noted that improvements could be made regarding control of plant drawings and control of potential plant changes.

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

An evaluation was performed to determine the effectiveness of the on-site engineering support group in resolving problems and concerns of a technical 9

4 nature. Arcas reviewed included the engineering support group organizational structure and responsibilities for interface with other engineering groups.

Additionally, programs were reviewed for control of design chv.ges, review of plant incidents, other industry operating experience, plant performance moni-toring, in-service inspections and evaluation of engineering activities.

The assignment of a corporate engineering branch manager to the site has resulted in improvements in processing design change reqWsts and drawing revisions.

Determinations were made as follows:

1.

Finding (Ref. Criterion 3)

Although PGE has recognized problems concerning updating of drawings and has established a program of control, a number of plant drawings do not reflect as-built conditions that exist after plant modifications are completed and released for plant use. Additionally, plant administrative controls do not require tnat affected drawings and procedure changes be completed prior to release of the modified item for use.

Recommendation It is recommended that the existing program to update electrical schematic drawings affected by construction as-builts be continued to completion. Addhionally, the plant should review the need to expand the scope of this program to include ~ similar updating of other classifications of drawings (such as wiring diagrams).

Administrative controls for Requests for Design Change should be revised as necessary to require that updated &awings and revised procedures be in place prior to releasing the equipment for u::e.

Response

The current program of Nuclear Projects Engineering to update electri-cal schematic drawings has been completed. An engineering review has been made of those drawings required for safe plant and system

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operation. A list of " top drawings" has been established that identifies l

those drawings which will be updated within a few days of modification j

completion. Any necessary procedure revisions will also be prepared in a j

timely manner following modification completion.

Most importantly, prior to placing the equipment which has been modified into operation, any new information required for safe operation will be provided in -

Operation's Night Orders until new procedures are finalized.

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TROJAN (1980)

Page 35 S

Finding (General Criterion) (Category II)

It is a general criterion and an accepted industry practice to require that temporary design modifications receive engineering reviews prior to implementation. The intent of this general criterion is not met in that the modifications documented in the Log of Lifted Leads, Jumpered Leads and Removed Circuit Boards do not receive an adequate engineer-ing aview. The Trojan plant Log of Lifted Leads, Jumpered Leads and Removed Circuit Boards was found to have 59 open entries made prior to the year 1980, and 20 open entries for 1980. The long-term nature of many of these entries in effect establishes the Nork as permanent desk,n modifications. There is some evidence that the plant maintenance staff has rengnized this concern and has been considering action to close out open log items or to initiate Requests for Design Change. Additionally, it was noted that a proposed revision of Administrative Order AO-6-2, Bypass of Safety Functions, has been initiated by the plant.

This proceduct change is proposed to upgrade the review of temporary modification'. of this type.

Recomn endatiw It is recommended that action be taken to prmide an engineering review of all open items currently in the Log of Lifted Leads, Jumpered Leads and Removed Circuit Boards. The maintenance staff should continue with their pesent plans to close out all possible log entries with restoration tc original conditions or with Requests for Design Change (RDC). The proposed changes to the administrative controls should be resobad and should require an engineering review, including a safety analysis, for any temporary modifications prior to implementation.

Response

An engineering review of the opm items in the Le of Lifted Leads, u

.Jompered Leads and Remotes Circuit Boards was completed in January 1981. Administrative Order A0-6-2, Bypass of Safety Functions, will be revised to include a semi-annual review of the " Lifted Lead" Log by the operations supervisor and engineering supervisor. For any log entries in effect Iw more that 1 year, action will be taken to 1) remove the jumper, lay the lead back down, etc.; 2) justify maintaining the current condition; or 3) process an RDC to eliminate the need for the existing condition.

This review will be implemented during the forthcoming refueling outage.

Administrative Order A0-6-1 also requires the review and approval by the cognizant supervisor end by Operations prior to making temporary modifications.

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Appendix TROJAN (1980)

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ADMINISTRA'QVE APPENDIX l

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LISTING OF AREAS EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectiver OA-102 Crganization Structure OA-103 Administrative Controls O A-104 Quality Programs O A-105 Information Programs OA-106 Industrial Safety OA-107 Surveillance Program OA-103 Perronnel Qualif.:aticns TRAINING AND QUALIFICATION TQ-211 Training Organization and Administration TQ-221 Training Resources TQ-231 Training Effectiveness TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training TQ-244 Licensed Operator Requalification Training TQ-245 Shift Technical Advisor Training j

OPERATIONS OP-301 Conduct of Shif t Operations OP-302 Tagout Practices OP-303 Organization and Administration OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-309 Viatch Turnover MAINTENANCE M A-401 Maintenance Organization and Administration M A-402 Preventive Maintenance Program MA-403 Maintenance Procedures MA-404 Work Control System M A-405 Maintenance History M A-406 Control and Calibration of Test Equipment and Instrumentation MA-408 Maintenance Facilities and Equipment

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Appendix TROJAN (1980)

Page 2 ReDIATION PROTECTION AND CHEMBTP.Y RC-501 Radiation Protection and Chemistry Organization au Administration RC-502 ALARA Program RC-503

?ersonnel Dosimetry RC-504

tadiation Surveillance and Control RC-505 Naste and Discharge Control (Liquid)

RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel Health. Physics Indoctrination RC-bo8 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program TECHNICAL SUPPORT 4

TS-702 On-Site Engineering Support a

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Appendix TROJAN (1980)

Page 3 II.

PGRTI.AND GENERAL ELECTRIC COMPANY PERSONNEL CONTACTED Gene 2 3fmager Manager, Operations and Maintenance Maneger, Technical Services Quality Assurance Supervisor QA/QC Inspeator Safety Coordinatar Industrial Psychologist Operations Supervisor Training Supervisor Traiaing Assistants Shif t Supervisors Control Operators Assistant Control Operators Auxiliary Operators Instrument and Control Technicians Servicemen AA (Mechanical Maintenance)

Control and Electric Supervisor Electrical Foretnan Instrument and Control Supervisor Maintenance Planner / Scheduler Mechanical Foremen Me.iis lical Supervisor j

Manitenance Supervisor Engineering Supervisor, Acting Reactor Engineer Manager, On-site Engineering Branch Engineer, On-site Engineering Branch I

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