ML20028F011
| ML20028F011 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 01/20/1983 |
| From: | DAIRYLAND POWER COOPERATIVE |
| To: | |
| Shared Package | |
| ML20028F005 | List: |
| References | |
| PROC-830120, NUDOCS 8301280342 | |
| Download: ML20028F011 (12) | |
Text
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DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR REGULATORY IMPROVEMENT PROGRAM STATION ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE:
Stat, ion organization and administrative systems should ensure effective implementation and control of station activities.
Task:
Perform an evaluation of the current organizational respon_
sibilities, management controls and staffing levels. Establish an appropriate plan of action after reviewing the results of this evaluation.
Action:
LACBWR will conduct an overall review of the organizational structure and will specifically address the following by the date indicated:
a.
the span of control of the plant superintendent (February 1982) b.
the difficulty of the radiation protection engineer to concentrate his time on matters related to health physics (February 1983).
c.
the ability of the Health and Safety Department to effectively implement the radiation protection and chemistry programs and to evaluate and improve the standards of the program (February 1983).
The following items have been addressed:
a.
Tre workload of the mechanical engineer has been reviewed; ar, additional person of this discipline has been employed and began work at LACBWR on Dec. 6,1982.
b.
Additional support is being provided to the Radiation Protection and Health Physics department by the Dept. of Environmental Affairs.
Administrative tasks of emergency preparedness will be shared with Information Services.
The involvement of Radiation Protection in Emergency Preparedness is essential.
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CONDUCT OF OPERATIONS PERFORMnNCE OBJECTIVE:
Operational activities should be conducted in a runner that achieves safe and reliable plant operation.
lask:
Formalize guidance regarding personnel authorized to operate controls and acknowledge annunciators.
Supervisors should routinely monitor control room activities to ensure that only authorized personnel operate the controls.
Action:
A tormal policy that directs that no one is permitted to operate controls without the express permission of the operations person assigned that watch was prepared and implemented in December 1982.
(ALP. 2.1) lhe establishment of periodic supervisor's meetings with the superintendent provide an informal basis for coordination of plant activities and improved conmunications between departnents.
Progress of improvements will be monitored.
Control room access is available to those whose duties require access.
Existing policies provide authority to remove people from the control room when conditions warrant this action.
PLANT STATUS CONTROLS PERFORhANLE OBJECTIVE:
Operational personnel should be cognizant of the status of the plant systems and equipment under their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.
Task:
Review outstanding Special Information Tags (SITS) on a periodic basis for applicability, readability and proper placement.
Action:
An administrative control procedure covering SITS that requires logging every tag in the book and a review for applicability, readability and proper placement at least quarterly will be issued April 1,1983.
All tags will identify the individual placing them and the original date placed.
'lask :
Provide for additional training of operations personnel on the understanding of ' operability' and how to recognize when a system should be declared inoperable.
Action:
A special training syllabus will be prepared which will include parameters affecting operability and especially those introduced by TMI requirements.
MAINTENANCE ORGAlilZATION AND ADMINISTRATION PERFORMANCE 06JECTIVt:
The maintenance organization and administrative systems should ensure effective control and implementation of department activities.
Task:
Evaluate and adjust the adoinistrative workload of the uechanical naintenance section. Particular attention should be given to
.epetitive reports and delegation of administrative tasks to appropriote personnel.
Action:
An assistant mechanical maintenance supervisor position has been created and has been filled effective September 13, 1982. This new position will oversee record naintenance and assist in documentation update and administration tasks, thus relieving the maintenance supervisor for closer job supervision.
The assistant mechanical naintenance supervisor will also assist on job supervision and by means of improved record keeping be able to trend equipment maintenance activities which may indicate impending failure and allow prior repair or replacement.
lask:
Improve the attitude of and adherence to health and safety and security requirements by maintenance personnel.
Through periodic supervisor and staff meetings, emphasis will be placed upon the need for adherence to all rules regarding safety, security and radiological protection by all maintenance operating and staff personnel.
This action will begin immediately.
WORK CONTHOL SYS1EM PERT 0RilANCE OBJECTIVE:
The control of work should ensure that identified maintenance actions are properly completed in a safe, timely and efficient udnner.
Task:
Implement scheduling and coordination techniques for maintenance activities that will improve the coordination of radiation protection, operations and other functions required to support maintenance.
Periodic management information meetings, improvded schedules and more effective use of back-shift personnel should be considered.
Action:
A computer program for planning needs is being developed to coordinate outages well in advance of scheduled start dates.
Routine staf f meetings will be held to provide more coordination outside of outage periods. This effort was started in November 1982.
The computer program is in trial run--data for the 1983 refueling outoge is being collected.
5taff meetings are held on as frequent a basis as needed, and f requency will increase as pre-planning activities increase.
C0fiDUCT OF MAINTENANCE PERFORMANCE OBJECTIVE:
Maintenance should be conducted in a manner that ensures efficient and effective plant operation.
Task:
Ensure through periodic observation by supervisory personnel that procedures are used properly.
Emphasize to mechanical, instrument and electrical personnel the importance of adhering to procedures, s.ction:
The concern of not utilizing procedures on the job is under review and, if deemed necessary, will be resolved by additional personnel training.
The quality assurance department will perform an audit to determine the degree of procedure utilization by January 1983.
the need for supervisory control on a day-to-day basis is reemphasized by the superintendent in meetings with key supervisors.
Increased involvement of quality assurance in all areas of operation and maintenance should assure better conformance to procedures.
Superintendent memo of January 4,1983 states requirement for complete documentation of work prior to returning equipuent to service.
PLANT MODIFICATIONS PERF0KMANCE OBJECTIVE:
Plant modification programs should ensure proper review, control, implementation and completion of plant design changes in a sate and timely manner.
Task:
Improve the drawing control program to ensure operators have access to current drawings of acceptable quality to perform plant evolutions anc that uncontrolled drawings are removed from use or upgraded to controlled status.
Action:
A program of purging and establishing new and controlled drawing files is underway.
Eventually all drawings will indicate either controlled or non-controlled. This task is estimated for completion by February 1,1983.
lask:
Follow the established facility change procedure to ensure that all design changes to the plant receive an appropriate technical review.
Action:
All future applicable design changes will be governed by the Facility Change Procedure and receive a technical review and appropriate document update.
OUTAGE AfiD MAlf4TEhANCE ACTIVITIES C00RDINATI0li Task:
There is a lack of long range planning on outages and this leads to a lack of coordination between the different groups in the plant.
Action:
Plan and develop an outage coordinating program which will list the many activities to be carried out during an outage, how many persons are required at a given time, ' milestones' for completion of specific tasks and what restrictions within our technical specifications prohibit simultaneous activities. This will be updated regularly and all departments will have an input into it.
The printout will be posted before the outage.
Outage planning discussions will be scheduled as frequently as necessary to ensure timely development of procedures well before they are needed in an outage and to make sure that everyone from operations and maintenance personnel to radiological protection personnel are aware of the goals and missions of a particular outoge.
Health Physics activities will be coordinated with outage activities to insure ALARA in all phases of the maintenance outage work.
MAINTENANCE PERSONNEL TRAINING AND QUALIFICATION PERFORMANCE OBJECTIVE:
The maintenance personnel training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job functions.
Task:
Develop and implement structured training in plant systems and administrative requirements for mechanical maintenance personnel.
Action:
LACBWR will develop and implement a training program covering plant-specific systems and administration requirements for all mechanical maintenance personnel, all instrument and electrical personnel and all quality assurance personnel.
This program will be started in February 1983 and will be completed in 1983. This program will expand to include new employees and be made a part of uJT and apprenticeship programs.
Step-up in grade will be contingent upon completion of the training requirements.
I RADIOLOGICAL PROTECTION ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE:
The organization and administrative systems should ensure effective control and implementation of the radiological protection
~ program.
Task:
Ensure that all supervisory personnel are made aware of their responsibility to enforce radiological protection procedures and l
practices.
Stress the need to adhere to radiological protection l
procedures and practices in the training and retraining of plant personnel.
Action:
Plant personnel are being reinstructed to comply with radiological protection procedures and requirements. A continuing policy of I
ensuring adherence to radiological requirements by all personnel will be expanded in year 1983.
This includes a method policy of documenting deviations..-_
7 Radiological Protection suptrvisory personnel are charged with the
. responsibility of reviewing the activities through plant tour, inspection and review of documentation.
)
A Safety responsibility policy now prepared for managenent approval provides disciplinary action for violation of DPC safety rules and/or Federal rules and regulations concerning safety and health of employees.
a GENERAL EMPLOYEE TRAINING IN RADIOLOGICAL PROTECTION i
PERT 0RMANCE 06JECTIVE:
General employee training should ensure that plant
..ersonnel, contractors and visitors have the knowledge and practical abilities necessary to effectively implement radiological protection practices dssoCidted with their work.
Task:
Require each employee to perform a satisfactory demonstration of practical radiological protection skills such as donning and removing protective clothing, frisking, using step-off pads and reading pocket ion chambers. Expand the scope of written tests to provide a more accurate evaluation of employed knowledge of the i
radiological protection program.
Action:
LACBWR is revising the general employee radiological training, which will include these recommendations. This revision will include emphasis on individual responsibilities and will be implemented early in 1983.
4 INTERNAL RADIATION EXPOSURE i
1 PERFORMANCE OBJECTIVE:
Internal radiation exposure controls should minimize j
internal exposures.
Task:
luplement a program to verity the Whole-Body Counter (WBC) calibration on an annual or more frequent basis.
Action:
The whole-body counter will be calibrated by March,1983. An l
annual recalibration requirement will be established in March 1983.
l i
I PERSONNEL DOSIMETRY PERF0kMANCE OBJECTIVE:
The personnel dosimetry program should ensure that radiation exposures are accurately determined and recorded.
Task:
Establish criteria and conduct appropriate individual evaluations 4
Lo detect dosimeter problems or errors in recorded dose. Continue with periodic, overall evaluations of TLD film, and PIC readings to identify basis problems.
i Action:
LACbWR will perform a monthly comparison of individual TLD results, film results, and pocket dosimeter results.
Differences between these results that exceed a predetermired level will be reviewed by the radiation protection engineer, and an evaluation will be _
performed and documented.
This program will be implemented by j
tebrua ry, 1983. :
W Task:
Establish guidance for the use arf placement of dosimeters when detailed radiation surveys indicate that extremity, skin or multiple whole-body monitoring may be appropriate.
Ensure that the point of highest exposure is munitored.
LACBWR will modify the proce' ure for the use and placement of d
Action:
extremity and whole body dosimeters and will ensure that the procedure is followed Ly March,1983.
RADI0 ACTIVE CONTAi4] NATION CONTROL PERFORMANCL OBJECTIVE: Radioactive contamination controls should minimize the contamination of areas, equipment and personnel.
Task:
Contamination control practices.need to be reviewed and upgraded.
Changes should address the points discussed above.
..ction:
The problems in contamination control are still under review.
dpecial attention will be given' tr' minimizing the spread of avoidable contamination and confirming the -area for decontamination of affected equipment tools or components.
Task:
Establish methods to improve personnel monitoring when exiting contaminated work areas and the radiological controlled area.
Require whole-body frisking when leaving contaminated or potentially contaminated areas.
Action:
LACBWR will institute a policy of increased ffisking of personnel when leaving contaninated or potentially contaminated areas during 1983.
Consideration for localing friskers closer to source of potential contanination in order to limit areas of contamination spread will become part of routine H. P. Job planning.
CHLiilSTRY CONTROL PERFORMANCE OBJECTIVE:
Chemistry controls should ensure optimum chemistry conditions during all phases of plant operation.
Task:
Establish a plant program to provide effettive controls for storage, use, transfer and disposal r'
'goicals.
This includes chemicals used both in the laborat9t'es nd in the plant by the maintenance group and by the optr; J 76 roup.
Consider assigning responsibility for oversight of <+. cia:.
itorage, use and disposal to the health and safety group.
Action:
LACBWR will develop a plant program for the control, storage, transfer and disposal of corrosive and hazardous chemicals.
LACBWR will assign responsibility fer oversight and management of' this program, which will be implemented by April 1983. _ _ _ _ _ _ _ _ _ _ _
Task:
Modify chemistry log sheets to include limits for all applicable parameters.
Utilize this information when plotting data to facilitate trend analysis.
Action:
LACBWR will review all chemistry and log sheets by December 1982 and make modifications where needed to help ensure timely identification, notification and corrective action for plant chemistry parameters that have exceeded specified limits.
LONDITION OF THE FUEL AND PRIMARY RADIOACTIVE CHEHISTRY PARAMETERS PERFORnANCE OBJECTIVE:
Tighter surveillance of reactor primary water chemistry and radio chemistry is needed especially during warm-up and start-up conditions; trending of the parameters is needed to avoid exceeding limits ouring transition.
Task:
Plant primary fuel condition chemistry will be monitored by
..erforming necessary surveillance tests and alerting operations
, ersonnel when problems are evident.
Action:
A plot of all technical specifications require primary system radiochemistry parameters will be established in the control room.
The limits will be visually indicated on them so that any person walking into the control room can readily recognize a deviation f rom the regulatory requirements.
This program will be in place by April 1,1983 by means of a visible graph of radio chemistry parameters related to fuel condition and located in the control room.
LABORATORY ACTIVITIES PLRFORMAhtt OBJECTIVE:
Laboratory and counting room dctivities should ensure accurate measuring and reporting of chemistry parameters.
lask:
Expand the quality control program to provide appropriate checks 09 the quality of analyses.
Known standards should be analyzed in conjunction with routine plant samples.
Periodically, unknown sanples should be substituted for known samples to provide a check of technician perforuance, laboratory procedures, reagents and instrumentation. All reagents used in the laboratory should be labeled with expiration dates.
Reagents with expired shelf lives should not be used.
Action:
LACBWR will establish a progran for quality control in the chemistry lab including, bu'. not limited to, routine analysis of unknown spike samples and use of standards in conjunction with samples in March 1983.
LACBWR will be assisted by the DPC central chemistry lab and chief chemist in this effort.
ACBWK will assign a health physics technician to be responsible to ensure that the prepared chemicals having limited shelf life are so marked and replaced as needed.
A list of chemicals with limited shelf lite will be prepared and the chemicals will be periodically inventoried and replaced as needed beginning in February 1983. ________
LACBWR will identify an individual to be responsible for the radio chemistry lab.
Administrative controls and lab results will be placed in this responsibility (April 1983).
ADMINISTRATIVE CONTROL PERFORMANCE OBJECTIVE:
Provide a means of tracking commitments to ensure that responses to agency requests are submitted on time.
Task:
Establish an improved records management system, document control and commitment-response system.
Action:
Computerized systems for records management are planned for implementation in 1983. Document control and commitment-response tracking are the duties of newly appointed LACBWR administrative assistant.
Responsibility for timely response, however, lies with the plant technical staff. The effectiveness of the commitment tracking and general regulatory response is under the ultimate review of the Assistant General Manager for Power.
TECHNICAL SUPPORT 4
PERFORMANCE OBJEClIVE.
Provide sufficient resources to carry out the technical programs imposed by Systematic Evaluation Program (SEP), licensing activities, plant improvements and operational problems.
lask:
Improve and expand the technical support to the LACBWR operations and engineering activity.
Action:
Technical support from the DPC central office staff has, heretofore, been only lightly utilized.
Personnel are available and trained to perform in several areas such as:
l d.
materials procurement b.
chemistry and analytical services, non-radiological i
c.
health physics d.
turbine generator operations, maintenance and i
performance improvement e.
electrical engineering projects f.
drafting services g.
meteorological monitoring h.
data processing 1.
maintenance support 9
Greater utilization of these supportive resources has begun and will be expanded until fully utilized. Dependence on outside consulting firms will be reduced proportionately as in-house resources are more fully utilized.
A free communication between plant staff and headquarters keeps dvailable headquarters staff people involved in ongoing work.
Special engineering or other project assistance requests are handled on assignment basis.
All nuclear plant project work is ieviewed by Quality Assurance, and outside support works under the direction of a plant ' nuclear-oriented' individual.
The primary technical support staff is plant-based and can be supported by in-house staff services and outside contract consultants as needed.
EMERGENCY PREPAREDNESS PERFORMANCE OBJEClIVE:
Improvements rre needed in emergency response activities, Ivocedures, communications and support.
Task:
Recent emergency preparedness drills have revealed weaknesses in the Emergency Operations Facilities (EUF) and Technical Support Center (TSC).
Action:
Improved procedures outlined with check points and written in clearer, more precise language will be completed by early 1983.
tmergency Preparedness clearly needs the direct involvement of Health Physics Department personnel. The on-site Emergency Planning Coordinator will be supported by the Directer, Environmental Affairs in the development of improved procedures.
Once accomplished, the maintenance of documentation and execution of energency exercises can be directed by the on-site Emergency Planning Coordinator. There is ample staff to maintain a high level of emergency preparedness once the procedural and connunications aspects are improved.
Several specific improvements are planned, underway or completed:
a Meteorology data communication forms have been designed, printed and are available for use.
b.
A 10 meter on-site meteorological tower now provides ground level data in addition to elevated level data on the LACBWR stack.
c.
Regional scale backup meteorological data system two miles east of LACBWR accessible by telecommunications from the EOF is now available.
d.
A Quality Control Plan (QCP) for meteorological data, collection, reduction and analysis has been acquired and implemented. _
e.
LACBWR TSC to EOF data acquisition and transmission system is being installed now and expected to be available in 1982. The system will transmit plant data to TSC and EOF.
f.
Field survey kits will be improved by March,1983.
g.
In-field radiological sampling system has been upgraded by procedure to:
1.
provide check list of required equipment and actions 2.
provide field calculation forts to simplify.
data reduction 3.
include additional specialized training in emergency procedures h.
Additional practice drills will be scheduled prior to next emergency demonstration drill.
- i. Observers will be included in practice drills in order to sharpen skills of a larger number of potential participants.
j.
In-house critiques are used to improve on deficiencies detected in practice drills.
STAFF MORALE PERFORItANCE OBJECTIVE:
Create an atmosphere of positive 'can-do' spirit among employees faced with difficult tasks and hard decisions.
Task:
The topic of staff morale is a significant factor in regulatory improvement.
It is necessary that the attitude of the staff be as positive as possible towards regulations. The following items will be conducted to ensure this goal is met.
Action:
The staff's uncertainty regarding the future of this facility will be minimized. The superintendent will communicate to the staff through memos, information about the licensing of this facility, information regarding the purchase of fuel and any other major incidents which indicate either in a positive or a negative light precisely what Dairyland's plans are in the operation of the LACBWR facility.
The staff will be involved in budget formulation.
It is particularly important to involve each engineer and the department heads in a manner that can ensure attention to problems.
It is important that they have an ownership in the budget and the facility itself, so that they understand fully LACBWR's operational objectives.
The superintendent will delegate more responsibility and authority to subordinate levels at LACBWR. Responsibility for regulatory compliance must be a personal one.
STAFF COMMUNICATIONS l
PERFORMANCE OBJECTIVE:
Ensure that all facets of the LACBWR organization perform in a harmonious, coordinated manner.
Task:
It is necessary that the staff at LACBWR have a mechanism for communication between department heads and staff engineers which does not require the formal use of the Operations Review Committee or the Safety Review Committee.
Action:
Starting with the month of October, twice monthly meetings of first line supervision and once monthly meetings of engineers will be held. This will give the plant superintendent the opportunity to find out precisely what the problems are before they become problems of concerr to the regulatory agency.
AUDITS PERFORMANCE OBJECTIVE: Audits should be used as an aid in identifying and eliminating weaknesses in all important areas of operation.
Task:
Audit findings of Safety Review Committee audits and our Quality Assurance Program audits should receive follow-through.
Action:
We have established a policy that first responses to findings of internal audits must be resronded to within 30 days.
Once commitments are made to follow a recommendation of an audit and take corrective action, that corrective action will be taken unless the commitment itself is changed by the person who made it.
These audits will be given the weight of a management directive to be followed in the plant.
Audit Response Policy (ACP 19.0) is now implemented.
Quality assurance tracks audit response, and reports deficiencies to the Plant Superintendent and the Assistant General Manager for Powar.
Regulatory review (SALP) and INPO assessments are directed to the Assistant General Manager for Power and necessary responses are generated from that level..