ML20010H376
| ML20010H376 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/31/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| References | |
| NUDOCS 8109240399 | |
| Download: ML20010H376 (37) | |
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EVALUATION of BIG ROCK POINT NUCLEAR POWER PLANT Consumers Power Company August 1981 l
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BIG ROCK POINT (1981)
Page1
SUMMARY
INTRODUCTION j
The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Consumers Power Company's Big Rock Point Nuclear Plant during the weeks of April 20 and May 4,1981. Big Rock Point Nuclear Plant consists of one 71 megawatt (net electrical) General Electric boiling water reactor plant. The site is located on the eastern shore of Lake Michigan, five miles northeast of Charlevoix, Michigan.
The plant was placed in commercial operation in November 1965.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant operatir.g safety, evaluate management systems and controls and identify areas needing improvement. Information was assembled from discus-sions, interviews, observations and review of plant documents.
The team examined station organization, training, operations, maintenance, radiological and chemistry activities and on-site technical support. Emergency preparedness was not included in the scope of the evaluation, nor were corporate activities, except as an incidental part of the evaluation. On-sitc training, which is a corporate function, was evaluated. As a base for the evaluation, INPO used its own experience on best practices within the industry and written evaluation criteria which were furnished to the plant in advance. The evaluation standards are higt, and the findings and recommendations are not limited to minimum safety concerns.
DETERMINATI3N Within the scope of this evaluation, the team determined the plant is being safely operated. The following beneficial practices and aceemplishments were noted:
o Tt e plant staff has a great deal of envience. Communication and cooperation among staff members at alllevels are excellent.
o An effective maintenance program is in effect. The plant is in excellent material condition, and cleanliness is good overall.
o None of the control room alarm annunciators were normally activated while operating at power. Few annunciators in the remainder of the plant were normally activated.
o The control room environment was quiet and businesslike. Access con-trols were effective.
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BIG ROCK POINT (1981)
PIge 2 o Radiation and contamination levels are low throughout the plant.
o The Technical Department is wel'. organized and provides excellent engineering support for plant operations.
Improvements were recommended for the following gcneral conditions:
o Training is weak. A concerted effort is needed to ensure that training programs are developed to provide the skills and qualifications needed.
c The plant operator qualification program should be improved to ensure that each operator achieves the necessary knowledge and skills before operating equipment without supervision.
o Efforts to minimize personnel radiation exposure and the spread of low level radioactive contamination are not as effective as they should be, o Communication and ecoperation between the plant staff and supporting corporate groups are weak, causing a lack of effective support in several areas.
Specific evaluation findings and recommendations are contained in the accompa-nying DETAILS, and informatior r. an administrative nature is included in the ADMINISTRATIVE APPENDIX.
These findings were presented at an exit meeting at the plant on May 7,1981.
Recommendations are intended to augment Consumers Power Company (CPCo) efforts to achieve the highest standards in its nuclear operations.
Certain findings may reflect multiple deficiencies within a particular area. Therefore,in addressing these findings and recommendations, the company should look beyond correction of the specific deficiencies and address corrective actions toward the underlying causes and issues.
The findings and CPCo's responses were reviewed with CPCo's management on June 29,1981. CPCo's responses are considered satisfactory. To follow the completion of the improvements included in your responses, INPO requests written notification of status six months after the date of this report.
The evaluation team appreciates the cooperation received from all levels of the Consumers Power Company.
E. P. Wilkinson President
BIG ROCK POINT (1981)
Page 3 CONSUMERS POWER COMPANY Response Summary Consumers Power Company concurs with INPO's conclusion that the Big Rock Point Plant "... is being safely operated." Consumers also recognize 3 there are areas for improvement, and the Company is committed to meeting or exceeding INPO's recommendations to ensure excellence of plant operations. There are three broad areas of improvement that will have the greatest impact on addressing most of the findings.
Staffing - Tne Nuclear Operations Department is being substantially increased in 1981. Emphasis in General Office Support has been placed in the training, health physics, quality assurance and project engineering support areas.
Specific increases to the Big Rock Point Plant staff are under review.
Training - The Nuclear Operations Training Department was formed in 1980 to develop and implement the training necessary for all Nuclear Operations Department personnel. Training needs are being developed with emphasis on licensed and non-licensed ooerators, and plant support personnel. A new Nuclear Trainin;; Center is under construction in Midland, Michigan.
Management Systems - A major effort is being made to standardize many activities throughout the Nuclear Operations Department through the establish-ment of a "Stano~ards Manual." This contractor-supported program will expand many of the safety-related practices presently in use to include critical non-safety-related practices.
Specific implementation dates have been established wherever possible. Con-sumers Power Company will continue to welcome follow-up INPO evaluations to assess program implementation and effectiveness.
BIG ROC K POINT (1981)
Prge 4 DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each section is headed by a summary describing the scope of the evaluation and the overall finding in that area. The summary is followed by the specific findings, recommendations and utility responses related to each of INPO's evaluation procedures. Items relating to criteria that have not been included in INPO procedures but that are generally recognized as desirable, accepted techniques of industry and management are listed as General Criteria. The evaluation procedures that were used are listed in the ADMINISTRATIVE APPENDIX.
ORGANIZATION AND ADMINIS7 RATION in this area, the team evaluated the overall management of the plant from an administrative viewpoint.
This included an assessment of the management procedures in use at the plant and their effectiveness in achieving the desired results.
Overall, the plant was found to be managed effectively.
The administrative system is comprehensive and supports safe plant operation -
without unnecessary complications.
Plant personnel have a great deal of experience with the plant and are very knowledgeable regarding plant charac-teristics and administrative controls, in part because of the small size of the plant and the stability of the staff. Communication and cooperation among the various groups on the staff are excellent. The detailed findings in this area are described below.
OBJECTIVES (INPO Procedure OA-101, Revision 2)
The method of promulgating management objectives within the plant was examined, along with methods of promoting progress toward objectives and periodic assessment of progress.
The objectives in use were examined to determine if they provide substantive guidance to plant personnel and support
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higher level objectives.
l Finding All criteria in this n'ea were met.
ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)
The administrative organization was examir.ed to dete rmine if it supports safe and efficient operation of the plant. Key areas examined included the reporting relationships for plant and on-site support personnel, position descriptions, performance eteluations ant' workload distribution.
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BIG ROCK POINT (1951)
Page 5 Finding All criteria in this area were met.
ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Revision 2)
The station administrative procedures and controls were examined to determine if clearly defined controls are in effect and if adherence to these controls is maintained.
Finding All criteria in this area were met.
QUALITY PROGRAMS (INPO Procedure O A-104, Revision 5)
On-site quality programs were evaluated to determine if sufficient monitoring and auditing capabilities exist to ensure safe and efficient accomplishment of the plant mission.
1.
Finding (Ref. Criterion B)
Most non-safety-related aspects of plant operation are not covered by a formal quality assurance (QA) program.
Recommendation Expand the quality assurance program to include non-safety-related plant equipment and activities that can irrpact significantly on plant reliability and perforinance.
Response
A study will be completed by June 1982 to identify non-safety-desig-nated plant equipment that is important to safety, and this equipn.....
will be incorporsted into the QA program. Remaining equipment will also be evaluated for inclusion in this program.
2.
Finding (General Criterion)
Non-conforming replacement parts and materials were stored with conforming parts and materials in the quality control storage area of the storeroom.
Recommendation Conforming parts and materials should be removed from the quality controi hold area and stored in other areas of the plant. The quality control hold area should be used exclusively for non-conforming material such as Hold, Reject and Repair / Rework Repro l
This occurrence was due to the size and amount of material that was l
purchased for a specific task.
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BIG ROCK POINT (1981)
Page 6 A wire reel rack has been fabricated and installed in the QA warehouse, and all quality-related wire has been placed there. The remaining items were placed in the normal " Accept" area. The hold area is now used exclusively for non-conforming material.
INDUSTRIAL SAFETY tiNPO Procedure OA-106, Revision 3)
The on-site industrial safety program was evaluated to determine if plant poFeies and practices provide a safe working environment for all personnel at the pMnt.
Finding Considerable effort has been expended by management to promote an effective industrial safety program. The program is comprehensive and appears to be actively supported at all levels. All criteria in this area were met.
SURVEILLANCE PROGRAM (INPO Procedure OA-107, Revision 3)
The surveillance program was evaluated to determine if appropriate surveillance inspection and testing are accomplished to ensure reliable system and equipment performance.
Finding All criteria in this L.ea were met.
PERSONNEL QUALil'rCATIOM3 l
(INPO Procedure OA-108 Revision 2) 1 The team evaluated the qualification requirerr: ants for job positions at the plant and the methods used to ensure that all positions are filled with qualified j
personnel.
Finding (Ref. Criterion A)
Qualification requirements for a number of the positions at the plant are based on minimum regulatory requirements rather than on aa analysis of i
l the responsibilities and authorities of the position.
As a result, l
employees are not being selected, promoted or trained b<ised on com-l plete, clearly defined qualification requirements.
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BIG ROCK POINT (1081)
Page 7 Recommendation Position descriptions should be reviseu to identify all appropriate qualifi-cation requirements for incumbents. Specific attributes that should be delineated, where appropriate, include educationhl level; technical skills; hands-on, supervisory, or management experience; licenses; and skill certifications. The revised qualification requirements should then be used for selection and promotion of candidates and to guide training of individuals desiring promot%n.
Response
The plant will develop precedures that describe current individual job functions, responsibilities, authorities and accountabilities for the plant staff. Within the context of current company job evaluation, perform-ance appraisal and promotion relection systems, these procedures will be used for defining job qualifications, selection and performance ap-praisals, and for determining training requirements of each position. The Nuclear Operations Trainmg Department will establish similar proce-dures for the training staff.
These efforts will be cumpleted by March 31, 1982, for plant staff and January 1,1982, for corporate nuclear training staff.
In addition, the Nuclear Operations Training Department will develop training programs to meet job requirements on an ongoing basis.
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BIG ROCK POINT (1981)
Page 8 TRAINING AND QUALIFICATION The team evaluated the organization and administration of the training program, training resources and effectiveness, and programs for training licensed and non-licensed operators, shift technical advisors and other station perscnnel.
Significant improvements needed in the training program are identified below.
TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)
The team examined the on-site traimng organization and the administrative system used to develop, implement and evaluate training for licensed and non-licensed operators, maintenance repairmen, instrument and control technicians, health physics technicians, chemistry technicians, instructors and staff engi-neers.
1.
Finding (Ref. Criterion B)
The present on-site training staff is not of su.*ficient site to develop or implement the training programs assigned. As a result, deveral programs are not being carried out. This condition has been recognized, and some additional training staff positions have been authorized.
Recommendation A thorough review of the staffing level and duties of the training department should be performed. Based on the review findings, the staffing level or responsibilities should be changed to ensure sufficient manpower is available to complete all the necessary training functions.
Response
A review of staffing levels and duties is now complete. Four additional instructors for the Big Rock Point training section have been authorized.
Candidates are being recruited at the present time and all positions are expected to be filled by January 1,1982. Additional contract personnel will be utilized to supplement the staff in the interim.
1 2.
Finding (Ref. Criteria D and F)
The plant is not conducting effective initial and continuing training of the following personnel:
o instrument and control techn cians o maintenance repairman o chemistry and health physics technicians o technical support department personnel Programs and curricula in these areas are not developeo in any system-atic manner based on training needs or jot, analysis.
Recommendation Review the responsibilities and knowledge requirements of these tech-nical positions. Determine from the review the training necessary to initially qualify persons to perform their work safely and the training appropriate to improve the effectiveness of persons already in those positions. Develop and implement coordinated programs to ensure that the necessary training is performed effectively.
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BIG ROCR POINT (1981)
Page 9
Response
Training requirements for instrumant and control technicians and main-tenance repairmen will be developed by '.he maintenance department and fer Qe chemistry and healtn physics technicians by the chemistry /hcalth physics department by January 1,1982.
Two members of the plant training staff will be dedicated to developing training programs for instrument and control technicians, maintenance repairmen, and chemistry and health physics technicians.
Training needs for technical support department personnel will be developed by the tachnical department by June 1982. Training of these personnel will be done by the Big Rock Point Training Department, in-house company programs and outside contractors as necessary.
TRAINING RESOURCES (INPO Procedure TQ-221, Revision 2)
The team examined the training facilities, equipment and materials available to support the delivery of training programs.
Finding (Ref. Criterion F)
Few written instructor lesson plans are available for any training programs. No up-to-date description of P ant systems is available for L
study by trainees.
NOTE: This finding also applies to INPO Procedure TQ-243 (Criterion C);
it is not repeated in that section.
Recommendation Develop formal lesson plans for each subject to be taught and ensure that they are used by course instructors. Up-to-date copies of system descriptions and other appropriate training materials should be made readily available to trainees.
Response
Lesson plans will be developed by outside contractors and Big Rock Point training instructors as the lessons progress and will be completed by January 1,1982. The existing system descriptions will be corrected by instructors as they are used and supplemented as necessary.
TRAINING EFFECTIVENESS (INPO Procedure TQ-231, Revision 2)
The team examined plant and training management practices relating to evaluation of training program effectiveness, auditing of training activities, and evaluation of instructor and trainee performance in training programs.
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F BIG ROCK POINT (1981)
Page 10 1.
Finding (Ref. Criterion A)
Neither plant nor training department management conducts any strue-tured evaluation; of training effectiveness. A systematic appraisal of effectiveness is not required by the company.
NOTE: This finding also applies to INPO Procedures TQ 245 (Criterion I) and TQ-244 (Criterion I); it is not repeated in those sections.
Recommendation All training programs should be formally evaluated annually by an independent, knowledgeable person or group-The evaluation should include a formal, written report with recommendations for improving training effectiveness in producing persons who are properly qualified for their assigned responsibilities.
Response
A program of formal, periodic evaluations of plant training effectiveness will be established and implemen'ad by December 31, 1981.
2.
Finding (Ref. Criterion B)
The plant does not initially or periodically measure trainee performance against job-related standards.
Licensed and non-licensed operators are assigned operational duties without a complete program for evaluation of their qualifications.
Recommendation Formal prceedures should be established to periodically deterniine if persons completing training have attained the skills and knowledge intended and s/ training curricula adequately support all job requirc-ments. Where deficiencies are noted in trainee knowledge or perform-ance as a result of these reviews, corrections to the training program should be required.
Formal qualification guides should be established for licensed and on-licensed operator positions up to and including shift supervisor.. >ch guide should include provisions to certify achievement of the individual skill and knowledge requirements appropriate to the particular position.
Plant and system knot dge; license, regulatoe., and administrative requirements; and, where possible, demonstration of practical skills by actual equipment operation should be included. Satisfactory completion of the qualification program for each position should be certified by responsible operations supervisors.
Response
Procedures will be developed oy plant management for assessing the adequacy of training to support operational job requirements. Qualifi-cation guides will be developed by plant management and, with the aid of the training depetment, will be used to certify the sk0ls and knowledge of personnel filling various operating positions thro"3a the chif t supervi-sor level. This effort will be completed tvy Iantary 1,1982.
3.
Fincibg (Ref. Ceterion C)
Instructor performance is not being evaluated to determine instructor effectiveness in achieving objectives of the training programs.
BIG ROCK POINT (1981)
P;ge 11 Recommendation The training supervisor or other qualified plant managers should evaluate instructor classroom performance by observation in the areas of techni-cal competence, communication skills, trainee interest, class discipline, use of materials and accomplishment of objectives. The results of the evaluation should be used to imp.ove instructor effectiveness.
Response
The Nuclear Training Center at Midland will be staffed with personnel having a background in education and qualified to train instructors. The instructor training program will include periodic instructor evaluations by personnel itom the Training Center and the Nuclear Operations Training Department (NOTD) staff. In addition, the on-site it.structors will be evaluated by the Training Supervisor.
NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)
The team examined the training program and training practices used to initially qualify non-licensed operator candidates and to maintain and improve the qualifications of existing non-licensed operators.
1.
Finding (Criteria A, C and D)
The initial training program for non-licensed operators is not adequate.
No written procedure is used to guide this training. Auxiliary operators are not required to participate in classroom or on-the-job training in plant systems prior to being ass,igned to operate equipment without supervision.
Recommendation Formal procedures for initial training of non-licensed operators should be developwi and implemented so they can attain sufficient understanding of plant equipment and admin!s'.cative controls to perform their jeb safely.
Response
The NOTD staff is presently developing procedures and programs to improve the existing auxiliary operator (AO) training program.
The recommended changes in the AO training program will be completed by Jaruary 1,1982.
2.
Finding (Ref. Criteria A, C and D' No continuing training is provided for auxiliary operators to improve
$hir capability. Unofficial check-offs are used in varying degrees by different persons, but no formal guidance for their use exists. The auxiliary operatoc:, are frequently assigned to work in the plant during the four days every fifth week allotted for training.
Recommendation Provide a requalificatico program for non-licensed operators.
The program should include coverage of changes to plarat systems, operating procedures and administrative controls that affect the non-licensed operator's duties. Appropriate industry operating experiences should also be integrated into the program. A periodic assessment of non-licensed
BIG ROCK POINT (1981)
P:ge 12 operator's job knowledge and skills should be included to evaluate current job proficiency.
Retraining should be directed toward correction of identified deficiencies.
Response
The NOTD staff is presently developing an AO requalification program with implementing procedures. This program will involve each non-licensed operator once every five weeks and includes studies on funda-mentals, theory and pbnt systems. Time is also spent with the licensed operators in jaint training.
These changes will be completed by January 1,1982.
IJCENSED OPERATOR TRAINING (INPO Procedwe TQ-243, Revision 2)
The team examined the training program and practices used to initially qualify licensed operator candidates to operate the nuclear plant reliably and safely.
The findings in this area applied to criteria C and I.
They have been stated above under Criterion F of TQ-221 and Criterion A of TQ-231.
LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-244 Revision 2)
The team examined the qualification program and training practices used to maintain and improve the qualification of licensed personnel.
1.
Finding (Ref. Criteria A, B and C)
The l'oensed operator requalification program is different than that prescribed by plant instructions.
Most of the material presented is review. Two of the four Oays set aside for formal requalification are used by the operations department to review plant systems. During the remaining two days, time is spent re-reading facility and prez.edure changes that have been previously read by the same operators while on shift.
Recommendation Develop an effective licensed operator requalificatioa plan that defines program goals, content, implementation practices and responsibility assignments.
In part, the program content should be based upon retraining needs derived from the results of job analysis and recent jor performance. Training materials should include descriptions of systems and instructor lesson plans. Effectiveness should be evaluated annually with respect to achieving the program goal of improving job perform-ance.
Response
The existing requalification program will be reviewed and revised in 1981 to ensure that program content is based upon operator needs and program administration is improved, consistent with tha recommenda-tion.
BIG ROCK POINT (1981)
Pag 213 A program of formal, periodic evaluations of plant training effectiveness will be established and implemented by December 31, 1981, by the Nuclear Operations Training Department.
2.
Finding (Ref. Criterion G)
The licensed operator requalification program does not include annual oral examinations to monitor licensed operators' retention of the knowl-edge and skills required for job proficiency.
Recommendation Administer comprehensive oral examinations to all licensed operators at least annually. Failure of this examination should result in an accel-ersted requalification program followed by re-examination.
Response
Oral examinations will be conducted on an annual basis commencing during the general time frame of the annual, written requalification examinations for 1981. Oral examinations will be conducted by plant staff members knowledgeable in plant operations and will be graded on a satisfactory-unsatisfactory basis. If a licensed persoa is judged unsatis-factory on the overall examination, he shall be removed from his licensed activities and placed in an accelerated training program for the deficient areas until he can be satisfactorily retested.
A finding applicable to Criterion I was stated above under Criterion A of TQ-231.
SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ 245, Revision 1)
An evaluation was performed to determine if a suitable program has been i
developed and.mplemented for shift technical advisor training and educat an.
Finding All criteria in this area were met.
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BIG ROCK POINT (1981)
P ga 14 OPERA'I1ONS Operations activities were evaluated in the areas of erganization and administra-tion, tagout practices, conduct of shift operations, procedures, plant status controls, facilities and equipment and shift turnover.
It was noted that Operations Department personnel are expedenced, dedicated toward safety and productivity, and exhibit a professional attitude toward their duties.
Several good rpsetices, such as minimizing excessive contrcl room traffic and operating wl:n a minimum number of control room annunciators on ala:m, were also observed throughout the period of the evaluation. Overall facility operation is considered good in th; areas evaluated; however, several areas in need of improvement were identified.
OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-301, Revision 3)
An evaluation was performed to determine if a clenny defined operations organization exists and if assignment of responsibilitia and authority are adequate 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.
Finding All cr:teria in this area 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. The tagout procedure appears to be highly respected throughout the plant.
It was used conscientiously to establish and maintain safe working conditions. The use of written step-by-step switching orders ooth to install and to remove tagouts is a good practice that can be helpful in ensuring that tagging operations are performed completely and in the desired segence. However, improvements are needed in some areas.
1.
Finding (Ref. Criterion F)
The Workmen's Protective Tags and the yellow caution tags are large enough to obscure important indications on control panels.
Recommendation Develop and use smaller console tags, stickers and/or other devices that will not obscure indicators, labels, and legends or prevent control actuation.
Response
A small tag will be developed by January 1,1982, for use in the Control Room only. It will be used on a trial basis to evaluate effectiveness.
BIG ROCK POINT (1981)
Page 15 2.
Finding (Ref. Criterion G)
A periodic review and audit of outstanding Workmen's Protective Tags and switching orders is not being performed.
Recommendation Develop and initiate a periodic review program for outstanding switching orders. This program should include checks for proper tag attachment, proper positioning of equipment, presence of unauthorized tags and adequacy of current tagouts.
Response
Procedures will be changed to require periodic physical audits of Workmen's Protective Tags, and monthly audits of these tags will be initiated In addition, QA audits, or surveillances, will be conductec 2n a periodic basis to determine departmental adherence to these require-ments. These changes will be completed by October 1,1981.
3.
Finding tGeneral Criterion)
The use of yellow caution tags should be limited to temporary situations so the formal reviews appropriate for permanent plant changes are not inadvertently bypassed. Even though a periodic review of outstanding caution tags is performed, some of these tags were found to be four to five years old, and no action was planned to permit their removal.
Recommendation Revise the current caution tag review program to resolve, with minimum delay, deficiencies that require the use of these tags.
Long-term conditions should be resolved by plant modifications and procedure revisions rather than use of a caution tag.
Response
The caution tag procedure and review in the Administrative Procedures appear adequate to control the use of caution tags for short-term application.
However, existing Administrative Procedures will be changed by *eptember 1,1981. to address long-term conditions.
CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-303, Revision 3)
The conduct of shift operations was evaluated to determine if operator activ-ities, the operating environment and operator aids support safe and efficient l
operation of the plant.
Areas reviewed included operator activities, station l
cleanliness and order, response to abnormal conditions, logkeeping practices, reliability of control room instrumentation and operator awareness of plant i
conditions. Determinations were made as follows:
l 1.
Finding (Ref. Criterion A) l Miscellaneous non-technical reading material was observed in Operations l
work areas.
(
Recommendation Implement a policy that prohibits on-duty plent operators from reading material not associated with their employment ur shift responsibilities.
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BIG ROCK POINT (1981)
P;ge 16
Response
By October 1, 1981, Consumers Power Company will implement a corporate policy which will prohibit reading material not assor:iated with employment matters or shift responsibilities in our nuclear power plant Control Rooms and operations work stations.
2.
Finding (Ref. Criterion B)
The plant spaces are generally clean. However, considerable dirt, debris and loose items were abserved in limited access areas and out-of-the-way places.
Recommendation Increased effort should be applied to maintaining cleanliness of the less accessible areas.
Those that are not open to normal access during operation should be cleaned before startup.
Increased management attention should be develed to identifying and correcting housekeeping deficiencies.
Response
Increased management atter. tion is being devoted to identify and correct housekseoing deficiencies on a antinuing basis.
Areas requiring special housekeeping attention will be identified prior to each refueling outage and placed in the outage schedules as generic items. Manpower requirements will be scheduled and programmed into the computerized outage schedule. In addition, maintenance orders will be written and approved by management in advance, so that they will be ready during the refuel!ng outage.
USE OF PROCEDURES (INPO Procedure OP-304, Revision 2)
The evaluation in this area was performed to determine if appropriate manage-ment policies exist for use of procedures, if procedures are being properiy utilized, if procedures are written clearly, if emergency procedures allow quick and appropriate responses to plant conditions and if a system for revising and controlling procedures is in effect.
Finding (Ref. Criterion A)
Present controls do not ensure t!;at procedures are consistently used as intended by management. Some steps of the shift turnover procedure were omitted during the observed turnovers, and switching order steps were not consistently marked off, as required, when they were per-formed.
Recommendation The approved management policy requiring adherence to all procedures should be enforced. The proper use of procedures should be emphasized in training programs.
Management should initiate formal, periodic review to determine if procedures are being properly used and to identify any corrective actions appropriate.
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BIG ROCK POINT (1981)
P;ge 17 Repme The management policy requiring adherence to all procedures will be more actively enforced. A review of the use of procedures will be donc routinely by plant management, and corrective actions will be identified if necessary.
The shift turnover procedure will be clarified by January 1,1982, to prevent possible omission of steps. Teining does emphasize the proper use of procedures.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 2)
The team reviewed plant status controir to determine if controls are in effect to ensure that eqdpinent and system availability is adequate for safe operation and that operating shift personnel are aware of the status of all equipment under their control. One finding was noted in this area:
Finding (General Criterion)
Approved procedures or policies are not in effect to prevent the use of uncontrolled instructions, notes, graphs or drawings that were observed to be attached to plant components and panels.
Recommendation There should be an established policy that all operating aids which are posted on control panels or equipment are administratively controlled to ensure that they remain current and reflect approved operating informa-tion.
Response
All operating eids will be controlleu or removed by Janui i f,1982.
OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-306, Revision 2) l Ar. evaluation was performed to determine if plant facilities and equipment ere operable and maintained in a manner that ensures safe and efficient operation.
Areas reviewed included equipment operability, equipment availability programs, l
effect of the working environment on safe and efficient station operation, adequacy of communication equipment and watG station assignments.
Finding All criteria in this area were met.
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BIG ROCK POINT (1981)
Page 18 SHIFT TURNOVER (INPO Procedure OP-307, Revision 1)
An evaluation was performed to determine if continuous, correct understanding of station conditions is maintained at all shift positions.
Areas reviewed included programs and policies controlling shift turnover, turnover checklists, operating panel reviews and review of station activities in progress or planned.
Finding All criteria in this area were met, i
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BIG ROCK POINT (1981)
Page 19 MAINTENANCE The team examin~1 the maintenance organization, preventive maintenance, maintenance pv-ures, maintenance history and t.dministrdve systems for controlling and i samenting work. The methods useu to co". trol test equipmer:t were reviewed, and *5e overall adequacy of maintenance facilities and equip-ment was assessed.
Within t'
- t. ope of this evaluation, it was determined that the ma!ntenance program is comprehensive and effective.
The Maintenance Department is staffed by experienced, qualified personnel who are well-motivated.
Plant equipment condition is good, hnd an effective preventive maintenance system is in use.
Improvements recommended include refinement of certain administrative pro-grams and storage and control of certain equipment.
MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure M A-401, lievision 3)
An evaluation was performed to determine how effectively the maintenan. <
organization and administrative programs contribute to the perf.mance of maintenance tasks. Areas reviewed included organizational structure, reporting equirements and practices, staff size, training and retraining, position descrip-tLns for maintenance personnel, span of control for supervisors and certain administrative programs.
Finding All criteria in this area were met.
PREVENTIVE M AINTENANCE (INPO Procedure MA-402, Revision 2)
A review was made to determine if preventive maintenance (PM) activities are l
being performed and whether or not a well-defined and effective program is in place. The administrative procedure governing the program and the station organization established to implement it were also exaniined. Other areas of interest included criteria used to define the equ;p.nent included in the program, the use of equipment history files in conjunction with the program, the adequacy l
of individual PM procedures for safety-related equipment and inspection fre-quencies.
I Finding All criteria in this area were met.
I 1
BIG ROCK POINT (1981)
P;ge 20 M AINTEN ANCE PROCEDURES (INPO Procedure M A-403, Revision 3)
A review was made to determine the adequacy of maintenance procedures and vendor manuals for safety-related and critical balance-of-plant work. Proce-dures and manuals were examined to determine the types of activities covered, scope, level of detail, review and approval cycle, document control requirements and methods of revision.
An evaluation was also made to determine the effectiveness of procedures in controlling and documenting work and inspection activities. A determination was made as follows:
Finding (Ref. Criterion C)
Maintenance procedures are reviewed and approved for use by the plant staff, with no quality control or inspectiori hold points established.
Although So4d points are usually added by QA personnel prior to procedure use, no method exists to ensure that hold points are consis-tently provided where appropriate to determine the quality of work.
Recommendation Perm " ent hold points should be established in maintenance procedures to consistently ensure that steps critical to quality are verified by a second person. These verification inspections could be performed by qualified quality control or maintenance personnel.
Response
All safety-related maintenance orders and procedures are reviewed by QC prior M use, and hold points are stamped on the maintenance order or procedure. In addition, all maintenance procedures will be reviewed and modified prior to their next us; s o add permanent hold po!nts so that steps tnat are important to work quality will be consistently verified by a second person.
WORK CONTROL SYSTEM (INPO Procedure MA-404, Revision 3)
The administrative mechanism used for identifying anu re r
..e, equipment problems was revie":ed. An evaluation was performed to cat'.rmine if the work control system wis effective for planning, controlling and documenting the completion of.".aintenance work.
Specific areas of interest included the administrative procedure for requesting corrective maintenance and those provi-sions in the system relahd to planning, authorizing and documenting the work.
Finding All criteria in this area were met.
BIG ROCK POINT (1981)
Page 21 MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 3)
A review was made to determine if complete, functional maintenance history records are being retained and used in evaluation of equipment performance.
Areas examined included the amount and types of equipment included in the program; type, level of detail, traceability and retrievability of records; methods used for review and evaluation of maintenance histories; and assignment of responsibility for implementing the program.
A very goad maintenance history program was implemented through the corpo-rate Maintenance Management Improvement Program (MMIP). The history has been updated at regular intervals and p cvides a ready index of maintenance orders in an easy-to-use format.
Fir. ding All criteria in this area were met.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION (INPO Procedure MA-406, Revision 2)
A review was made t<> detersnine the effectiveness of methods used for calibration and control of test equipment and instrumentation. Areas examined included methods used for identifying, calibrating, storing, issuing, transporting and using measuring and test equipment. Procedures governing the calibration programs and existing calibration records were also reviewed.
The measuring and test equipment (M&TE) progiam was administered by an off-site corporate calibration facility. No, evaluation of this off-site facility was perforrned. A recall program was instituted by the corporate facility to identify M&TE coming due for recalibration and to establish a regular schedule of pickups and deliveries. This recall program was well undcutood and fully implemented at the plant. The plant has a good inventory of M&TE in excellent condition.
However, some areas of the program need improvement.
1.
Finding (Ref. Criterion A)
The interface between the corporate calibration facility and the plant is pcor. No documentation is provided to the plant concerning details of i
the program that may affect plant work. Changes that affected work at the plant were made to the pregram without tne knowledge of plant p+tsonnel. These changes were not recognized by plant personnel for a considerable period after they hcJ been implemented by the corporate facility.
Recommendation The plant should be provided with formal documentation of all aspects of the corporate calibration program affecting its work. This documenta-tion should be updated when changes occur in the corporate system. It is
BIG ROCK POINT (1981)
Page 22 suggested that the plant either le provided controlled copies of appli-cable procedures describing the details of the program or that the calibration facility develop " Users Guides" providing the same informc-tion.
Response
Big Rock Point Plant hns been added to the distribution list for System Protection and Latnratory Services measuring and test equipment proce-dures. Current revisions of these procedures are on site.
2.
Finding (Ref. Criterion E)
Controlled and non-controlled test equipment are not segregated in storage.
Recommendation The plant is taking steps to upgrade all non-controlled (Q code N) test equipment to controlled status (Q code Y).
However, until all non-controlled test equipment has been eliminated, separate storage of controlled and non-controlled M&TE should be provided.
Response
Q code N test equipment is now stored in a cabinet segregated from Q code Y test equipment.
CONTROL OF SPECIAL PROCESSES (INPO Procedure M A-407, Revision 1)
A review v as made of the adequacy and effectiven':ss of the controls over welding.
Areas examined included welder qualification, reqvalification and certificetion, welding procedures, equipment and material.
Other special proces es, such as nondestructive examination, are performed by off-site organi-zations. These were not evaluated.
A good welding prograia is implemented.
Welder certification is current; welding equipment is in good condition; and welding material is adequately controlled.
Finding l
All criteria in this area were met.
l l
MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Revision 2)
A review was made of the maintenance facilities and equipment to determine adequacy and condition. The location, size and condition of office, work and storage space were examined, along with the number, type, condition and location of maintenance tools and equipment.
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BIG ROCK POINT (1981) i Page 23 e
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W BIG ROCK POINT (1981)
Page 24 RADIA'110N PROTECTION AND CHEMISTRY Radiation protection and chemistry activities were evaluated against current INPO cri;eria and other good practices commonly found at nuclear power plants.
The evaluation dealt mainly with the management of radiological controls as applied to plant operations and maintenance. Specific areas evaluated included ALARA activities, training,, dosimetry, contamination control, survey equipment calibration, respiratory protection and chemistry. The evaluation was performed during routine power operetions and was limited to what could be observed under those conditions, plus a review of records generated during the last outage.
Many radiological protection and chemistry personnel inve several years of experience and have extensive knowledge of plant characteristics.
Survey equipment was in extremely good condition, and radiation levels throughout the plant were low.
There were several areas in which improvements are needed.
The most significent weaknesses involved training and radiation exposure reduction.
RADIA'I10N PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)
Manpower, organizational structure, authority and training were evaluated to determine if they are supportive of good health physics and chemistry practices.
Some procedures were reviewed to determine if they provided sufficient guidance to ensure continuity in the conduct of day-to-day operations.
The Chemistry and Radiation Protection Department was found to be weli organized and functioning smoothly.
There were several very experienced personnel in this department, and cbservations indicated that chemistry and radiation protection personnel are well respected and have adequate authority.
One finding was noted in this area.
Finding (Ref. Criterion D)
No structured, comprehensive initial training program is available for chemistry and radiation protection technicians.
Also, no continuing training program is in use by which senior chemistry aid radiation protection technicians can maintain and improve their job performance.
Some technicians have received little training other than on-the-job training. Observations of work activities and discussions with personnel indicate that basic training is needed.
At the time of the evaluation, contractors had been hired to provide some chemistry training and to develop a radiation protection training program for technicians.
A chemistry cour e was in progress. The initial phase of a radiation protection technician training program is scheduled to be implemented in June.
Recommendation The activities in progress and those planned for the near future should be incorporated into a systematic training program that will ensure the timely training of new personnel and the continuing training of more
BIG ROCK POINT (1981)
Page 25 senior employees. It is also recommended that senior chemistry and radiaticn protection technicians attend the new technician training course.
Respome The Nuclear Operations Training Department was established in 1980 to develop and implement the training program for all Nuclear Operations Department personnel.
A systematic training program for radiation protection and chemistry will be developed in 1981. It will ensure the timely trafring of new personnel and continued training of senior employees. The first cycle of this program will be completed by January 31,1983.
ALARA PROGRAM (INPO Procedure RC-502, Revision 1)
An evaluation was performed to determine the extent of efforts to maintain personnel occupational radiation exposure as low as reasonably achievable (ALARA). Several good practices were noted that indicated an awareness of the ALAR A principle; however, there was a need for improvement in this area.
Finding (Ref. Criteria C, D and C)
No comprehensive ALARA program exists. In one example, the obserta-tion of a radwaste shipping operation involving significant exposure rates (3-4 R/hr) revealed that although more than usual planning was con-ducted, personnel exposures could have been further reduced by some relatively simple changes in the way the work was performeo.
It is recognized that the corporate staff is working on guidelines for a companywide program and that a plant staff health physicist has be~
designateo'ss the plant ALARA coordinator. A contractor has also been hired to devt. lop a radiation protection plan that will have some integral ALARA features. However, these activities have not yet produced an effective ALARA program at the plant.
Recommendation In the short term, the plant staff should emphasize exposure reduction through more aggressive work planning and by more critically observing work in progress. Reduced exposure goals should be established as a basis for planning and tracking the effectiveness of exposure reduction efforts.
The radiatior protection staff should play the lead role in ccordinating this effort; however, the other departments should share the responsibility for effective planning and adherence to exposure reduction procedures.
For the long term, the company should continue with the pre; ram development activities identified in the finding.
Response
The corporate Radiation Safety Standard details the ALARA program with assignments of authority, duties and responsibilities. An ALARA coordinator has been assigned at the Big Rock Plant, and annual ALARA
BIG ROCK POINT (1981)
Page 26 goals and obja etives have beer established to promote reduced exposure.
Implementation of the formal plant ALARA program will be completed by July 1982.
In the interim, plant manerement and the ALARA Coordinator will emphasize improved plannirg and performance of activitics involving radiatior. exposure to ensure reduced exposure goals are achieved.
PERSONNEL DOSIMETRY (INPO Procedure RC-503, Revision 1)
An evaluation was performed to determine the effectiveness of the plant's dosimetry program in measuring, evcluating and recording occupational radiation exposures.
Finding All criteria in this area were met.
RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 2)
An evaluation was performed to determine if practices used to keep workers informed of radiological conditions in the work area are adequate. In addition, the policies and practices regarding the control of contamination were reviewed.
A few areas with loose surface contamination were observed and, in general, they wcre adequately posted and controlled. However, some areas exist where improvements can be made.
l Finding (General Criterion)
A number of examples were noted where workers are not rigorously complying with procedures and generally accepted good practices re-l garding contamination control.
The poor practices observed have resulted in the spread of contamination to clean areas and in personnel contamination.
Examples of the poor practices observed included friskir.g too fast for the frisker to respond to low levels of contamination ano failure to observe proper procedures for entering and leaving a con-taminated area. In addition, three key friskers were located in relatively high background areas and were not shielded. This caused a significant reduction in their sensitivity.
Recommendation Gene %1 Employee Training should emphasize proper frisking techniques.
Derw;strations, if necessary, should be used to show workers how slo,ay they must frisk to detect the levels of rt.diation represented by the clean area limits. Frisking staticns should be shielded if it is not practical to move them to a lower background area. Contamination control proce-dures should be more vigorously enforced.
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BIG ROCK POINT (li3D Page 27 Repme The Corporate Radiation Safety Standard deta'.i.< proper frisking tech-ciques ar.d re-emphasizes procedures for entering and leav:ng a contami-nated area. Implementing procedures will be in place by approximately July 1982. The Training Department will review the general employee tra:ning and revise or update it appropriately by December 31,1981.
Special training on the proper use of friskers will be prouded by October 1,1981.
Three frisker stations are located in relatively high background areas.
These areas will be investigattd and the frisker stations will be shielded or moved to a lower background area by December 31,1981.
WASTE AND DISCHARGE OGTROL (LlQUID)
(INPO Procedure R ;-505. Revision 2)
This area was evaluated to determine if a system of controls exists that will minimize the generation of radwaste, reduce the likelihood of having an inadvertent release, detect the presece of contamination in systems where it should not be and ensure that all activities related to this area are effectively coordinated between the different departments.
Finding All criteria in this area v'ere met.
1 RADIOLOGICAL 30RVEY EQUIPMENT CONTROL AND CALIBRATION l
(INPO Procedure RC-506, Revision 2)
An evaluation was performed to determine the effectiveness of the plant's radiological survey equipment calibration and control program.
Instruments were found to be in very good physical condition, and calibrations were generally adequate. One area was apparent where assurances of instrument reliability could be improved.
Finding (Ref. Criterion C)
The higher range instruments cannot be calibrated at greater than 15 R/hr because of the low strength of the calibration source. In addition, instruments are not source-checked prior to use to determine if they are operating properly.
The plant staff is planning to use the Midland Plant calibration facility for high-range calibration when this iscility is completed.
Although some high-rarp calibrations have been performed at the University of Michigan, they were not part of an ongoing program.
BIG ROCK POINT (1981)
Page 28 Recommendation Establish a program of periodic calibrations for high-tange instruments and a program for source-checking instruments prior to first use each day the instrument is usei Guidance in ANSI 323-1980 should be used as a basis for incorporating these changes into the instrument calibration and control program.
Response
A temporary program of periodic calibrations for hand-held high range radiological inst uments will be established by August 31,1981, and will continue until the Midland Plant calibration facility is com,olrded.
Hand-held instruments will be response-checked with a source or known field tc ensure accuracy befcre use each day and will be calibrated per Technical Specifications.
PERSONNEL HEALTH PHYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2)
An evaluation was performed to determ8ne the effectiveness of the plant's health physics indoctrination program.
Finding All criteria in this area were met.
PROCESb WATER CONTROLS (INPO Procedure RC-508, Revision 2)
An evaluation was made to determine if chemistry parameters are being controlled within established specificativns and to determine if a program is in effect to prevent corrosive materials from being put into or placed in contact with systems material.
One area needs to be strengthened.
l Finding (Ref. Criterion B) l Controls do not exist for the use of decontamination agents, degreasing agents, sealants, solvents, etc. Chlorinated solvents and cleansers were observed at several locations in tr.c plant.
Recommendation Develop a program to control the use of solvents, sealants and other chemicals that could cause corrosion if placed in contact with plant systems. Unapproved substances should not be allowed in the plant. The plant should also consider including within this program appropriate limitations on substances that are known or suspected health or safety hazards (e.g. benzene and acetone).
Bl( ROCh POINT (1981)
Page 29
Response
A program to control the use of solvents, sealants and other chemicals that could cause corrosion if placed in contact with plant systems will be developed and in use by October 1,1981.
Consideration will also be given to enlarging the program to include limitations on substances that are suspected heslth or safety hazards (e.g., benzene and acetone).
HEALTH PHYSICS FACILITIES AND EQUIPMENT (INPO Procedure RC-509, Revision 2)
The chemistry and health physics facil' ties were evaluated to determine if they are adequate to support safe and efficient plant operation, Finding All criteria in this area were met.
RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
This area was evaluated to determine if the respiratory protection program is protecting workers from significant internal hazards. One area was noted where improvements should be made.
Finding (General Criterion)
The plant's records show an unusually high number of whole body counts with positive indications of radioactive corrosion products. The positive counts (typically less than three percent maximum permissible body burden) are attributed in most cases to external contamination. How-ever, separating internal contamination from external contamination is often difficult. This makes evaluating the adequacy of the respiratory protection program more difficult.
Recommendation The plant should determine if the positive whole body counts are primarily internal or external.
Emphasis should then be put on the contamination control program or the respiratory protection program as necessary to reduce the number of positive whole body counts.
Response
Consumers Power Company will perform an investigation to determine if the radioactive material observed in the whole body count program is external contamination.
This investigation has begun and will be completed by January 1,1982. Results from the investigation will be applied to the program to reduce the incidence of personnel contami-nation.
BIG ROCK POINT (1981)
Page 30 TECHNIC AL SUPPORT - ON-SITE On-site engineering support was evaluated in the areas of organization and administration, engineering support, operating experience evaluation, plaid cod ifications and reactor engineering. The Big Rock Point Technical Departmera was found to be well organized and to be efficiently managing engineering support for the plant. In addition, the Technical Department is effectively controlling and mnaging the numerous additions and modi!mations to the plant that sre currenby in progress.
TECHNIC AL SUPPORT ORGANIZA'I10N AND ADMINISTRATION (INPO Procedure TS-701, Revision 1)
The staffing and organization of on-site engineering support was evaluated with respect to the capability to perform all assigned duties and responsibilities.
Knowledge of job functions and the training performed to maintain and enhance engintering skills were examined. Findings were made in the area of personnel qualification as follows:
1.
Finding (Ref. Criterion C)
Off-site project engineers assigned responsibility for plant modif;c/tions are not familiar with site-specific systems, procedures and admiustra-tive directives. Consequently, their project responsibilities with ugard to plant modifications are not being carried out in the most proficient and timely manner. Considerable re-work has been required by the on-site staff.
Recommendation The off-site project engineers should receive site-specific as well as generic system training.
Response
Consumers Power agrees that site-specific training for off-site engineers should be provided. The appropriate content of a training program for various engineering staff members will be determined by anuary 1982, based on review with off-site and on-site engineering groups.
The Nuclear Operations Training Department will provide the necessary training beginning in the first quarter of 1982.
2.
Finding (Ref. Criterion D)
The Technical Department does not have a technical training program in effect to aid in the professional development of its personnel.
Recommendation Develop and implement a training program to provide Technical Depart-ment personnel with appropriate design and operating information about the plant and to upgrade their professional capabilities. The program should include systems training similar to that given to shift technical advisors.
Participation in industry seminars, workshops snd other technical exchanges shoult' also be encouraged.
Response
Consumers Power agrees that technical and professional training should be provided for Technical Department engineers and other professional
BIG ROCK POINT (1981)
Page 31 employees. The Nuclear Operations Training Department was estab-lished in 1980 to develop and implement the training programs necessary for all Nuclear Operations Department personnnel. Training needs are now being developed with emphasis on plant support personnel (techni-clans and maintenance) and those areas affected by NRC requirements (ie., licensed operators, STAS, etc). Specific needs for professional em-ployees (ie., engineers, supervisors, et c.) will be evaluated by January 1,1982.
Actual imp % mentation will begin at ' hat time. In addition, management /supervisci training courses are ptwided by the Company's Personnel Training Department.
ENGINEERING SUPPORT (INPO Procedure TS 102, Revision 2)
The Technical Department was evaluated regarding plant performance men!-
toring and communications with other groups providing engineering assistance to the plant. The control of important documents and the adequacy of engineering support facilities were also exam.'rrd. Big Rock Point is meeting the criteria except for the following:
Finding (Re Criterion A)
The station does not have s formal program for assessing and improving plant thermal performeto.
Recommendat'on A comprehensive program should be developed and implemented for plant performance monitoring, with the objective of enhancing plant operating efficiency and reliability. The program should include data analysis of appropriate monitored variables and provision for corractive action.
Response
The Big Rock Point Plant has an informal program of monitoring plant thermal performance under the responsibility of the Technical Superin-tendent. This progrcm will be formalized by January 1,1982. It will consist of at least three heat balance calculations each week, each of which will be reviewed by the Shift Supervisor and the Reactor Engineer.
If plant efficiency decreases, an investigation will be initiated.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision 1) l An evaluation of the program for in-house and industry operating event reviews was made. It was found that operating experiences and the sttendant corrective actions are reviewed and approved as appropriate by nperienced technical personnel. Big Rock Point is using " NOTEPAD" to assist in becoming aware of events at other facilities. They are meeting all experience evaluation criteria in their program except for the following:
i
BIG ROCK POINT (1981)
Page 32 Finding (Ref. Criterion C)
A program for evaluating effectiveness of the operating experience review program is not in place.
Recommendation Institute a formal system of checks to evaluate if pla it personnel receive and understand infermation applicable to their work that has
%en generated by the operating nperjence review program. Use the results of these checks to make program improvements where needed.
Resporne The existing proceam will bc tipgraded by including the requirements for a nuclear operMing experimee evaluation program within the Nuclear Operations Department Standards manual. This manual will be com-pleted by March 31,1982.
This particular standard will define the documents or information to be evaluated, responsible individuals and methods for providing feedback '.o affected plant and General Office departments. Annual reviews will be performed to Msess the effective-ness of the program in ensuring that appropriate people receive and understand operating e;perience information.
In the interim, Consumers Power Company will rely upon the 6iverse reviews of operating events by General Office and plant personnel to accomplish nuclear operating experience evaluations.
PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 1)
The program to accomplish plant modifications was evaluated to see if modifica-tions are implemented in a timely manner while maintaining the quality of plant systems, structures and components. Evaluation of this area was not complete l
because a significant amount of the plant modification process is conducted at l
the corporate office.
Plant modification work that is done by the on-site Technical Department in conjunction with other plant groups was found to be thorough and well-organized.
An effective modification tracking program exists. However, improvement is needed in one area.
Finding (Ref. Criterion I) i Required as-built drawing revisions for major modifications are not being completed in a timely manner prior to placing modified systemc in service.
Recommendation Develop sad ir plement improved controls over modification drawings so I
operators wil: have information on the as-buBt configuration of any portions of modifications that may affect plant operation before the modified system is placed in service. Develop improved methods to ensure that controlled copies of draw lags affected by major modifica-tions are either (1) marked up to reflect as-built conditions in a manner similar to minor modifications or (2) marked to alert potential users that a modification is in progress or completed.
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BIG ROCK POINT (1981)
Page 33
Response
Drawings for modifications colorolled on-site tre issued in a timely mar.ner. For modifications controlled off-site, a new construction /oper-ations interface policy will require that sufficient copies of applicable
" marked-up" drawings are disiributed to all controlled copy locations at the plant prior to placing a modified system into service. This policy will be implemented by September 1,1982.
j ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
Reactor engineering was evaluated to assess the use of proce6 tres, computer programs and the support functions provided during all modes of reactor operation.
Communications with other groups coordinating with the on-site reactor engineet were also examined. Measures to ensure maintenance of fuel cladding integrity and the involvement of the reactor engineer in refueling activities were also evaluated.
Finding All criteria in this area were met.
BIG NOCK POINT (1981)
APPENDIX Page1 ADMINISTRATIVE APPENDIX I.
LISTING OF AR'# S EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Orga..ization Structure OA-103 Administrative Controls OA-104 Quality Programr G A-106 Industrial Safety OA-107 Surveillance Program OA-108 Personnel Qualifications TRAINING AND QUALIFICATION TQ-211 Training Organization and Administration i
TQ-221 Training Resources TQ-231 Training Effectiveness TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training 1
TQ-244 Licensed Opeator Requdification Training TQ-245 Shift Technical Advisor Training OPERATIONS OP-301 Opetations Organization and Administration OP-302 Tagout Practices I
OP-303 Conduct of Snift Operations OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-307 Shift Turnover M AINTEN ANCE MA-401 Maintenance Organization and Administration M A-402 Preventive Maintenance MA-403 Maintenance Prc;edures MA-404 Work Control System MA-(05 Maintenance History MA-406 Contral and Calibration of Test Equipment and Instrumentation l
MA-407 Control of Special Processes MA-408 Maintenance Facilities and Equipment l
l
h BIG ROCK POINT (1981)
/ PPENDIX Page2 R ADIATION PROTECTION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-502 ALARA Prvgram RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control RC-505 Waste and Discharge Control (Liquid)
RC-506 Radiological Survey Equipment Control and Nibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program TECHNICAL SUPPORT-ON-SITE TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience,valuat'en P;ogram r
TS-704 Plant Modifications TS-705 On-Site Reactor Engineering
BIG ROCK PO!N P(1981)
APPENDIX Page 3 H.
CONSUMERS POWER COMPANY PERSONNEL CONTACTED Executive Vice yJesident - Energy Supply Vice President - huelear Operations Director - Nuclear Operations Training Department Plant Superintendent Operations and Maintenance Superintendent Technical Superintendent Operations Superintendent Maintanance Superintendent Administrative Supervisor Property Protection Supervisor Personnel Dire %
Quality Assurance Superintendent Quality Control Supervisor Acting Chemistry and Health Physics Supervisor Nuclear Safety Technical Engineer Technical Engineer Reactor Engineer Senior Project Engineer Project Engineer Shift Technical Advisors Shift Supervisors Control Operators Auxiliary Operators Outage Control Supervisor Maintenance Supervisor Assistant Maintenance Supervisor Acting Assistant Maintenance Supervisor Instrument and Control Supervisor Assistant Instrument and Control Supervisor Instrument and Control Technicians Maintenance Clerk Maintenance Repairman "A" Machinist General Supervisor - Plant Training GrrJs Training Supervisor Training Instructor Plant Health Physicist General Health Physicist Chemistry and Radiation Protection Technicians i
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