ML20032E905
| ML20032E905 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/31/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| References | |
| NUDOCS 8111230483 | |
| Download: ML20032E905 (42) | |
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Evaluation Repod October 1981 i
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i EVALUATION of
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FORT CALIIOUN STATION Omaha Public Power District 41 J
October 1981 M
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I FORT CALHOUN (1981)
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SUMMARY
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INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Omaha Public Power District's (OPPD) Fort Calhoun Station during the weeks of May 4 and May 11, 1981.
Fort Calhoun consists of one 490 megawatt (electrical) Combustion Engineering pressurized water rector plant.
It is located near Fort Calhoun, Nebraska on the Missouri River. The station was placed in commercial cperation in September 1973.
PJRPOSE AND SCOPE INPO conducted an evaluation of site activities to make en overall determination of plant operating 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 orga9zat.en, training, operations, maintenance, radiological and chemistry activities, and on-site technical support. Corporate activities were not included in the scope of the evaluation except as an incidental part of the evaluation. As a basis for the evaluation, INPO used its own experience on best practices within the industry and written evaluation criteria furnished to the plant in advance. The evaluation standards are high, and the findings and recommendations are not limited to minimum safety concerns.
DETERMINATION Within the scope of this evaluation the team determined the plant is being safely operated. The following beneficial practices and accomplishments were noted:
o The written procedures used throughout the plant are excellent.
F;rveillance procedures are especially well written and well imple-o mented.
The experience and competence of the staff is clearly evident.
o o The effectiveness of the chemistry program is excellent.
o The rotatior' of licensed operators throughout the plant watch stations is innovative and appears to pay operational dividends.
o Some of the training programs in effect are particularly well imple-mented, such as togout system training for new employees and the systems qualification program.
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Page 2 Opportunities for improvement were identified as follows:
Additional staffing is needed to handle all of the station's routine work o
requirements, The document control program needs management attention.
o The structure and content of the modification program are excellent.
o However, in practice, parts of the program are ineffective, The generation of solid waste is a problem now, and one that could o
become more severe in the future. Near-term action, such as waste segregation, should be employed to reduce volume.
Other longer term i
actions for volume reduction, such as boron recycling and auxiliary building decontamination, need to be considered.
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The monitoring of personnel for contamination needs to be strengthened.
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The recommendations following each finding are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs.
In addressing these findings and recommendations the utility should, in addition to correcting or iinproving specific conditions, pursue underlyi'g causes and issues.
The findings listed herein were presented to OPPD management at an exit meeting at the plant on May 22,1981. Findings, recommendations, and responses were reviewed with OPPD management on September 2,1981. OPPD responses are considered satisfactory.
1 To follow the timely completion of the improvements included in tne responses, INPO requests written notification of status six months from the date of this report.
The evaluation staff appreciates the cooperation received from all levels of Omaha Public Power District.
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E. P. Wilkinson I
President j
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O FORT CALHOUN (1981)
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_ OMAHA PUBLIC POWER DISTRICT Response Summary I
the Fort Calhoun Station.The Omaha Public Power District (OPPD i
Station since initial operation in 1973 attests to this coThe excel procedures, equipment and manpower. The INPO e mmitment. Maintaining and evaluation of Station's operations an,d support groups provided a valuablon of the F tion of these areas.
e, independent evalua-OPPD concurs with the INPO recommendations which Clearly defined plant goals and objectives, increa are based on the INPO a oun Station.
upgraded and enl training programs,arged training and office space, more specifically tailo and an improved document control program for P&ID's an other drawings are areas the District is committed to im r numerous plant procedures and standing orders p ove. Additionally, erations, training, objective is to provide the additional detail required to c updated. The recommendations.
onform to the INPO OPPD appreciates INPO's time and effort in evaluating th Fort Calhoun Station. The District has thoroughly evalu t d IN e operations at the recommendations and, based ae PO's findings and responses which conform to INPO's objective of excellenceon plant-spec INPO involvement in assessing the effectiveness and tim li. The District the INPO recommendations.
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FORT CALHOUN (1981)
Page 4 DETAILS 1
An item that relates to criteria not yet included in INPO procedures, but generally recognized as a desirable technique or practice is listed as " Category II."
ORGANIZATION AND ADMINISTRATION Seven performance areas were evaluated using current INPO criteria. The areas included objectives, organization structure, administrative controls, quality assurance, industrial
- safety, equipment surveillance, and personnel qualifications.
The Fort Calhoun organization has an effective surveillance program.
In addition, the station has comprehensive administrative procedures that give clear guidance for station performance.
Areas where improvements were recommended included objectives, organization structure, and quality programs.
OBJECTIVES (INPO Procedure OA-101, Revision 2)
An evaluation was performed to determine how effectively goals and objectives are disseminated throughout all levels of the station and how effective they are
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in conveying intended operational and maintenance directives. Areas reviewed included specific goals in use, management goals issued to all personnel, and measurement of goals and objectives attainment.
Finding (Criteria A, B, C, D and E)
A formal, coordinated program is needed to establish plant goals, objectives, and performance monitoring that is clearly understood at all l
levels within the plant organization.
RecommeMation Develop a coordinated program of goals and objectives that can be i
disseminated and understood by all personnel in the plant organization.
Utilize trends and other periodic checks to determine levels of perform-ance and attainment of these goals and objectives.
Response
A consolidated plant mission statement with goals and objectives will be issued to all plant supervisory personnel by April 1,1982. Subsequent to issuance of this plent mission statement by the Manager - Fort Calhoun Station, plant supervisory personnel will review the mission statement with station personnel under their supervision. Corporate strategic goals and objectives will be included in this mission statement as appropriate.
The mission statement will be updated and reviewed with station personnel on an annual basis. It will also consolidate and make " plant-specific" critical elements of individual programs already in use and administered by both on-and off-site District personnel.
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FORT CALHOUN (1981)
Page5 ORGANIZATION STRUCTURE (INPO Procedure OA-102, Revision 2)
The evhication team examined the station organization to determine if i
supports safe and efficient cperation of the station.
if the3 are clearly defined, well understood, and com if excessive burdens were placed on any individuals.
,and available to provide backups for management pers overtime.
station were also examined. Methods used to evaluate the performance of individu Finding (Criterion F) in the Technical Support, Operations, Maintena Control and Quality Assurance (QC/QA) areas.
Recommendation Determine the number and classification of personnel required in each area to manage effectively the existing programs and determine the necessary actions to augment the staff as indicated by these determinations.
Response
In keeping with the District's objectives to construct and operate power supply facilities "...in compliance with all governing regulations and with best interests of the customersconsideration to the env evaluated manpower resources. and the public," the District has annually The five-year staffing study for the Production Operations Division has been reviewed by the senior management group.Additional personnel have been approved for employment by the end of 1982 in positions related to Fort Calhoun. The newly approved manpower plan will add 35 persons to the areas noted above.
The effects of these additions and any new requirements identified will be evaluated on an annual basis to be sure Fort Calhoun plant and support staffs are adequate.
ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Revision 2)
An evaluation was performed to Jetermine the effectiveness of the controls for administ'ative functions.
Areas reviewed included completeness, flexibility, level of administrative actions, and effectiveness of the administrative controls programs.
Finding All criteria in this area were met.
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I FORT CALHOUN (1981)
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QUALITY PROGRAMS (INPO Procedure OA-104, Revision 5)
An evaluation was performed to determine if quality programs were in effect to provide sufficient accomplishment of station and company missions.
Areas reviewed included management controls, approved QC/QA programs and organ'-
zations, self-auditing-capability, and effectiveness of programs and corrective actions.
Finding (Criteria B and C)
The scope of the QA program needs to be expanded to cover additional aspects of plant operations, in a graduated manner appropriate to the importance of the operation. Important balance-of-plant equipment is not included in the QA program.
Recommendation Extend the QA program to cover selected balance-of-plant equipment.
Also, determine additional personnel required to covcr this extension.
Response
An evaluation has been made of the personnel requirements to effec-tively manage the current QA program. This includes the addition of one full-time clerical person and one additional Operations QA inspector.
These additions will support the control of quality in critical balance-of-plant equipment maintenance and operation.
QA positions are being evaluated annually to ensure an adequate number of qualified personnel are available to effectively manage the QA program.
INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 3)
The team examined the industrial safety program to determine if management is clearly committed to industrial safety, if the program is supported at all levels of the station staff, and if the program is effective in minimizing safety hazards and accidents.
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All criteria in this area were met.
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Page 7 SURVEILLANCE PROGRAM (INPO Procedure OA-107, Revision 3)
An evaluation was performed to determine if a surveillance program exists and accomplishes the required surveillance inspection and testing. Areas reviewed included procevures that addressed all areas of surveillance, acceptance criteria, out-of-range reporting requirements, timely completion requirements, manage-ment control systems, and actions to correct deficiencies.
Finding All criteria in this area were met.
PERSONNEL QUALIFICATIONS UNPO Procedure OA-108, Revision 2)
The team examined the methods used to establish qualification requirements for each job position and to ensure that positions are filled with qualified personnel.
Finding All criteria in this area were met.
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Page 8 TRAINING AND QUALIFICATION Evaluations were conducted to determine the effectiveness of the training organization and administration, the sufficiency of training resources, and the appropriateness and effectiveness of non-licensed operator, licensed operator, and shif t technical advisor (STA) training.
Areas of strength were found in-the STA initial qualification program, the effectiveness of the sixth operations shift dedicated to training, and the continuing progress in construction of the new Technical Support facility, part of which will be used for training.
TRAINING ORGANIZATION (INPO Procedure TQ-201, Revision 1)
An evaluation was performed to determine if a clearly defined training organi-zation exists that is staffed with qualified personnel and is capable of accom-plishing all assigned training tasks.
Finding (Criterion D)
A program is needed to develop and maintain instructional competence.
Recommendation Develop and implement a comprehensive instructional technique program to ensure instructional competence.
Response
The training organization will investigate the area of instructor qualifi-cation to determine program requirements, the content of such a program to best meet the needs of the Fort Calhoun Station, and the resources available (both within and outside OPPD) to implement and maintain such a program.
Once an instructional technique program content has been determined, it will be included in the Fort Calhoun Station Training Manual. A program will be established by March 1982.
TRAINING ADMINISTRATION (INPO Procedure TQ-202, Revision 0)
An evaluation was performed to determine if organizational functions necessary to initiate and control personnel qualification programs are accomplished in a well-defined, coordinated, and effective manner.
Finding (Criterion A)
The comprehensive management development program is not uniformly implemented or fully understood by all supervisory personnel.
Recommendation Schedule and implement management development training based on job analysis for all supervisory personnel.
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Response
Management development seminars for all supervisory personnel will be eonducted in the near future. All Production Operations managers will be apprised of the development program and participation will be monitored by senior division management.
TRAINING RESOURCES (INPO Procedure TQ-205, Revision 0)
An evaluation was performed to determine the quality and quantity of facilities, equipment, and materials necessary for the delivery of effective training for nuclear plant personnel.
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Finding (Criterion A)
More and better equipped classrooms are needed.
Recommendation Designate and equip additional classrooms to meet training needs. The existing classroom should be upgraded to reduce noise and improve lighting and seating conditions.
Response
A modification request (MR) has been submitted to upgrade the sound, lighting, and seating conditions of the existing classroom.
t An area of the new Technical Support Center (TSC) has also been designated and dedicated for use as a classroom.
Utilization of this classroom will be effected upon completion of the TSC. In addition, a third on-site training area has been identified for possible utilization.
In order to provide for more adequate coincidental training at the Fort Calhoun Station, additional medie equipment will be provided.
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Finding (Criterion D)
Reference library and study areas are needed.
Recommendation Dedicate a space that will provide a suitable study area with sufficient reference material to support program curricula.
Resporse An area of the Technical Support Center (TSC) will be utilized to provide a quiet, well-lit, interruption-free study and library area. This area will be available af ter completion of the TSC.
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LICENSED OPERATOR REQUALIFICATION (INPO Procedure TQ-223, Revision 0)
An evaluation was performed to determine if an effective program exists to maintain a high level of knowledge and skill in individuals licensed as reactor operators (RO) or senior reactor operators (SRO).
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Finding (Criterion B)
Operator requalification training content is identical (not specific) for the differing positional tasks.
Recommendation Requalification training should be tailored to the needs of the senior' reactor operator, reactor operator, and non-licensed operator positions.
Response
Senior reactor operator and reactor operator requalification training will be adjusted to meet the requirements of the NRC's requalification program. A training program specifically tailored to the non-licensed operators will be in effect by July 1,1982.
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Finding (Criterion F)
More oral examinations are needed in the requalification program.
Recommendation Develop, schedule, and implement additional oral examinations for li-censed operator requalification programs.
Response
Licensed personnel administer oral walk-through examinations on a continuous basis to non-licensed personnel seeking an NRC license. The Training Department will continue to administer oral examinations in lectures to ascertain weak areas that need to be stressed in future lectures. Oral examinations will also be accomplished as part of the annual simulator requalification sessions.
SIIIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-224, Revision 0)
An evaluation was performed to determine if STAS have the qualifications necessary to enhance operational safety by providing effective technical assis-tance to the operating shift personnel during normal, abnormal, and emergency operating conditions.
Finding (Criterion F)
Simulator training should be provided in the STA requalification pro-gram.
Recommendation Provide simulator training for STAS during requalification periods to better prepare them for nbnormni und emergency conditions.
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Response
Commensurate with the availability of the simulator, Omaha Public Power District will provide simulator training for the STAS, including i,
accident analysis, mitigation of core damage, and Fort Calhoun Station plant transients and accidents, during annual training sessions.
y NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)
An evaluation was performed to determine if initial and continuing training for i
non-licensed operators is sufficient to ensure they are capable of performmg their jobs safely and efficiently.
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Finding (Criterion C)
The training program content should include power plant fundamentals such as types and applications of pumps, valves, heat exchangers,and other plant equipment, as well as basic plant operations.
Recommendation Develop and implement power plant fundamentals and basic plant operations training programs based on needs analysis. INPO GPG-04,
" Nuclear Power Plant Non-Licensed Operator-Guidelines for Qualifi-cation Program," provides guidelines for program content and methodo-logies.
Response
A District program of power plant fundamentals has been planned and will be included at the Fort Calhoun Station. Individuals will be required to complete all or part of the program on a case-by-case basis, depending on background and experience.
' j A program of power plant fundamentals, administered by the District's off-site training group, will be in effect for all new non-licensed operator employees by December 1,1981.
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LICENSED OPERATOR TR AINING (INPO Procedure TQ-243, Revision 2)
An evaluation was performed to determine if the training for licensed operator candidates is adequate to permit them to operate the plant reliably and safely.
Finding All criteria in this area were met.
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I-FORT CALIIOUN (1981)
Page 12 OPERATIONS Areas evaluated in the Operations Department consisted of the following: the organization and administration, tagout practices, conduct of shift operations, the use of procedures, plant status controls, facilities and equipment, and shift turnover. It was concluded that the department is staffed with well-qualified, experienced, professional persons who operate the plant in a safe and efficient manner. Several programs are worthy of special mention: the On-Site Training Program used to qualify operators on plant systems, the program that indoctrinates all on-site personnel on the equipment isgging procedure, and a shift schedule that rotates control room operators through in-plant shift stations.
OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-301, Revision 3)
The team examined the Operations Department organization and administration to determine if a well-defined and well-understood organization structure exists; if department management has adequate authority to accomplish assigned tasks; if adequate administrative support is provided to maximize productive time for personnel operating the plant; if all instructions are issued in a businesslike manner; if administrative programs are established for activities affecting em-ployees; and if position descriptions are available and utilized for all personnel.
Finding (Criteria A and D)
Two findings in this area are detailed in the Organization and Adminis-tration sections OA-101 and OA-102.
TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)
The team examined the formal tagout procedure to verify if this procedure is highly respected and understood by the station staff; if SRO approval is required for removal of safety-related equipment from service; if double verification is required for safety-related manual valves that do not have control room indication; if a second verification of tagged equipment takes place; if tag coloring and numbering is not confusing; and if the clearance log is audited periodically.
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Finding (Criterion C)
A second independent verification of important safety-related compo-l nents (without control room indication) repositioried during maintenance or testing is not currently required. Standing Order-37 does require a second verification of some safety-related systems after a refueling
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outage.
Recommendation Revise existing procedures to require a second independent verification of important safety-related components that have been repositioned during maintenance or testing.
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Response
j Periodic valve alignment checks on accessible safety-related components will be performed by qualified persons knowledgeable in operation of the affected components. Thesr, additional periodic checks will be imple-mented after the 1981 refueling outage.
These periodic checks will be in addition to the following practices currently utilized:
c Maintenance and testing procedures detail and require specific sign-off by a knowledgeable individual acknowledging that an affected system has been returned to normal and, in many cases, the procedures specify a detailed step-by-step return to normal valve line-up.
o All safety-related equipment is required to be tested for opera-bility as a further verification that the equipment is capable of performing as required.
I o Second independent component alignment verifications of safety-
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related systems, as specified by the Supervisor-Operations, are performed af ter any major outage at the station.
i CONDUCT OF SIIIFT OPERATIONS (INPO Procedure OP-303, Revision 3)
The team examined the conduct of shift operations to determine if operator activities are related to plant operation, if cleanliness and order exist, if log keeping is timely and accurate, and if out-of-tolerance instrumentation is identified to tne operators.
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Finding (Criterion C)
An improved program is needed to reduce the number of annunciators in an alarmed condition during normal operation.
Recommendation Initiate a program to identify and mmimize the number of annunciators in an alarmed condition during normal plant operations.
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Response
I OP-305, Revision 2, Finding 3 also relates to control room annunciators.
in the response to OP-305, Revision 2, Finding 3, the District commits to i
requiring the Supervisor-Operations to periodically review the annun-ciator log. At the time of review, he will ensure that a Maintenance Order has been issued to repair and/or investigate the reason for an annunciator being in an alarmed or inoperable condition. This action will j
result in a formalized program that will reduce the number of annunciators in an alarmed condition.
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Finding (Criterion J)
Improvements are needed in the control of general access to the control room.
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Recommendation Evaluate access to the control room, and then limit access to tho'se persons having a need to enter. Provide a means of further limiting access to the control room during unit trips or other off-normal conditions. Limit personnel access to control room panels by estab-lishing a " permission to enter" the operating area policy.
Reporse Standing Order 0-11, Control Room Access, Section 4.0, Boundaries, will be changed to specify the areas where permission must be gained to enter. People entering will be limited during off-normal conditions in two ways.
First, standing Order 0-11 will be modified to include personnel who report to the control room for a unit trip.
A new emergency plan designates the personnel required in the control room during an emergency condition. Second, a mooification that will reduce the number of personnel who can enter the cont.ol room will be completed by the end of 1981.
UEE OF PROCEDURFS (INPO Procedure OP-304, Revision 2)
The evaluation team examined the use of procedures to determine if manage-ment policies exist for use of procedures, if procedures are being utilized, if procedures are written clearly, if instructions in emergency procedures allow quick aad appropriate responses to situations, and if a system for revising and controlling procedures is in effect.
Finding All criteria in this area were nmt.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 2)
The team examined the plant status controls to determine if management-approved policies exist giving guidance in the area of plant status controls, if operability status of equipment is properly c ntrolled, if a senior licensed indi-vidual is assigned responsibility for plant status controls, and if special situations such as outages and post accident recovery have provisions for adequate plant status controls.
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Finding (Criterion H)
The Emergency Plan Implementing Procedures (EPIP) should contain guidelines to be used during a post-accident environment to more closely control plant status.
Recommendation Revise the EPIP to include a means to suspend routine operations imless or until they are approved by the shif t supervisor.
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FORT CALHOUN (1981) l Page 15
Response
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Guidelines for use during post-accident environment to more closely 3:
control plant status will be developed.
A means to suspend routine l:
operations, unless or until approved by the shif t supervisor, will either be incorporated into existing EPIP-OSC-3, 4, 5, and 6 series or a new, specific EPIP will be prepared.
The procedure will be available by November 1,1981.
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Finding (Category II)
Improved administrative controls are needed for temporary labels, curves, notes, and instructions attached to plarit components and control consoles.
Recommendation Determine where actual needs exist for pping prints, diagrams, mimicking of valve operating stations, etc. Ensure that such operator aids are management-approved, formally promulgated, and periodically reviewed for currency.
Response
An administrative standing order will be written to formally develop a program for control of operating aids.
The procedure will include provisions to ensure that the operating aids are management-approved, kept current, and periadically reviewed. This procedure will be imple-mented by January 1,1982. In the long term, the human factors study to be performed in response to NUREG-0737 will resolve these concerns.
3.
Finding (Cutegory !!)
The annunciator status log instructions allow control room operators to disable alarming annunciators without first obtaining the concurrence of supervisory personnel.
Recommendation Modify the instruction for the annunciator status log to require the I
approval of the shift supervisor prior to disabling an annunciator.
Require that the log be reviewed during shift turnover and periodically reviewed by the Supervisor-Operations.
Response
The instructions for the annunciator status log will be formalized into a standing order at the Fort Calhoun Station. The standing order will include a requirement for approval by the shift supervisor prior to disabling an annunciator.
The standing order will also include a requirement for review curing shift turnover and a periodic review by the Supervisor-Operations. This standing o? der will be implemented by November 1,1981.
4.
Finding (Category II)
Plant valves, components, and systems are not clearly identified by permanent, distinguishable, and consistent labeling.
Recommendation Initiate a program to identify and permanently mark all valves and equipm ent.
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Response
An evaluation is being conducted to identify and permanently mark all valves and equipment. This evaluation will ba comp'.eted by January 1, 1982, and necessary action will begin at that time.
OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-506, Revision 2)
The evaluation team examined the Operations Department facilities and equip-ment to determine if equipment is accessible for operation, if programs are effected to maximize equipment availability, if the working environment i
contributes to overall efficiency and safety of plant operations, if communication equipment is adequate, and if watch stations are adequate.
Finding All criteria in this area were met.
SilIFT TURNOVER (INPO Procedure OP-307, Revision 3)
The team examined shift turnover to determine if procedures specify shift turnover requirements for all operating shif t oositions, if shif t turnovers include mechanisms to communicate pertinent information regarding equipment status, i
operations, or testing in progress, and if pertinent logs are reviewed.
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Finding (Criterion B)
Improvements are needed in the current administrative controls used for conducting and documenting shift turnover.
l Recommendation Evaluate the shif t turnover process and upgrade the shift turnover log to include inoperative equipment, in-progress and planned testing and l
l operations, and review of pertinent operating logs and records. Establish j
separate shift turnover checksheets for the shift supervisor and the i
auxiliary building, turbine building, and water treatment operators.
Response
The existing turnover log will be revised to include major inoperable equipment and tests in progress. The current standing order for shift turnover will be modified to include review of pertinent operating logs.
Shift turnover sheets will be developed for the auxiliary building, turbine building, and water plant operators. These items will be completed by January 1,1982.
2.
Finding (Criterion C)
The procedure for conducting shift turnover should require a general review of the control boards.
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Recommendation Revise existing procedures to require a general review of the control room panels by control room shift personns. This review should be performed jointly between the oncoming and outgoing shifts during the turnover process.
Response
Existing procedures will be revised (Standing Order 0-29) to include a general review of the control room panels during turnover by the oncoming shift. This revision will be completed by November 1,1981.
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T" N FORT C ALHOUN (1981)
Paga 18 M AINTEN ANCE Areas evaluated in the Maintenance Department consisted of the following:
maintenance pro-organization and administration, preventive maintenance, cedures, the work control system, maintenance history, control and calibration of test equipment and instrumentation, control of special processes nance facilities and equipment.
e experienced and knowledgeable supervisors and foremen. The preventive tenance program is comprehensive in scope and detail, lending that it is not of sufficient size to effectively accomplish all managing and tracking.
maintenance items with the attendant administrative b tasks.
administrative delays in closing out work packages.
MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure M A-401, Revision 3)
An evaluation was performed to determine how effectively the maintenanceItems re organization and administrative program functioned.
organization structure, reporting requirements and pra visors, and various personnel-related programs.
Finding (Criterion B)The maintercince organization workload appears to be e 1.
Overtime is routinely employed to meet personnel currently assigned.
A the requirements of the preventive maintenance (PM) p Review the present and projected requirements and responsibilities of Recommendation the Maintenance Department and augment personnel resources as neces-sary to ensure assigned work is ecmpleted on schedule.
The need for additional manpower in the Maintenance
Response
The plant staff will carefully monitor the PM be made during 1982.
program and will acquire additional support from central maintenance as I
needed. The backlog noted above has been climinated by this means.
PREVENTIVE M AINTEN ANCE (INPO Procecute M A-402, Revision 2)
An evaluation was performed to determine the effectiveness of the maintenance Areas reviewed effort in enhancing equipment reliability and performance.
included governing procedures, equipment include and control.
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Page 19 Finding (Criterion 1)
The PM program should include an ongoing review of program effective-i ness.
Recommendation Modify Standing Order M-2 to describe responsibility for, and details of, an ongoing review and evaluation of the PM program.
Response
A " review of program effectiveness" will be defined, incorporated in Standing Order M-2, and implemented by June 1,1982.
MAINTEMANCE PROCEDURES (INPO Procedure M A-403, Revision 3)
An evaluation was performed to determine the existence and adequacy of maintenance procedures and vendors' manuals for safety-related and critical balance-of-plant work activities.
Items reviewed included an assessment of activities governed by procedures, methods of procedure development and revision, and control of procedures.
Finding (Criterion A)
Specific procedures for preventive and corrective maintenance of impor-tant balance-of-plant equipment are needed in many cases.
Vendor instruction manuals used to perform maintenance on such equipment are not currently receiving technical review and approval prior to their use.
Recommendation Expand the requirements of Standing Order M-1 to include important balance-of-plant equipment. Develop a method whereby vendors' man-uals used to perform maintenance are appropriately reviewed.
Response
Importent balance-of-plant equipment requiring detailed maintenance procedures will be identified by February 1,1982. The adequacy of the technical manual information available will be reviewed by September 1, 1982. Technical manuals will be supplemented as needed, and procedures will be developed when required for the maintenance of this equipment.
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WORK CONTROL SYSTEM l
(INPO Procedure M A-404, Revision 3) i An evaluation was performed to determine the effectiveness of the work control I
system. The system functions were checked to determine if they identified, defined, and authorized work to be performed by maintenance groups; pre vided for planning, scheduling, and control of the wort ; and provided a suitable record of work performed for future reference.
l FORT CALHOUN (1981)
Page 20 Finding (Criterion F)
Responsibility to determine whether proposed work constitutes a design change or modification should be specifically assigned.
Recommendation Modify Standing Order G-17 to assign specific responsibility for deter-mining if proposed work constitutes a design change or modification.
Response
Standing Order G-17 will be changed to require the Technical Supervisor to include in his review of maintenance orders a determination if proposed work constitutes a design change or modification.
MAINTENANCE HISTORY (INPO Procedure M A-405, Revision 3)
An evaluation was performed to ensure that maintenance history records are retained and used to improve equipment reliability and performance; Items reviewed included assessment of equipment included in the program, content and accessibility of records, history review, and evaluation methods and procedures for program implementation.
Finding (Criteria B and D)
Overall improvements are needed in the maintenance history program.
Recommendation Develop and implement a more effective maintenance history program.
The program should include more than completed maintenance orders as
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the basis for the history. A method of periodic review should be included to permit a means of identifying and correcting persistent maintenance problems.
Response
The District will review availsble samples of maintenance history programs by March 1,1982. The program to be used by OPPD will be devised by June 1,1982 and will include a schedule for implementation based on equipment priorities cnd available staffing.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND l
INSTRUMENTATION (INPO Procedure M A-406, Revision 2) l l
An evaluation was performed to ensure that available facilities and proceduces i
support the requirement for accurate test equipment and instrumentation. Areas reviewed included identification, calibration, storage, issue, use, shipment, and documentation.
Finding No findings were made in this area.
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Page 21 CONTROL OF SPECIAL PROCESSES (INPO Procedure M A-407, Revision 1)
An evaluation was performed to determine if adequate controls exist for the performance of special processes, namely welding and nondestructive exami-nation.
Areas of review included training, qualification and certification of 4
personnel, administrative controls, and control of equipment and materials.
L Finding (Criterion A)
A structured training, qualification, and requalification program is needed for personnel who perform special processes.
Recommendation Establish an appropriate welder and QC inspector training qualification and requalification program to ensure appropriate on-sita welding and QC capabilities exist.
Response
A structured program will be established by March 1,1982.
2.
Finding (Criterion D)
A program for periodic maintenance of welding equipment is needed.
Recommendation Include welding equipment in the PM program.
Response
Welding equipment will be included in the PM program by January 1,1982.
MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure M A-408, Revision 2)
An evaluation was performed to determine if available facilities and equipment contribute to the effective performance of maintenance activities.
Areas reviewed included quantity, type, and condition of tools and equipment; size and location of tool storage areas; adequacy of office and work areas; and the cleanliness and orderlir. css of maintenance facilities.
1.
Finding (Criterion F)
Ventilation in the area of the welding shop needs improvement.
Recommendation Upgrade ventilation of the welding shop.
Response
Improved ventilation will be provided for this area during 1982.
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FORT CALHOUN (1981) l '!'
Page 22 2.
Finding (Criterion F)
The combined Electrical Foreman Office and Electrical Print Shop appears too small.
Recommendation Provide additional sgace for t.ese functions.
Response
Space has been allocated in the new Technical Support Center to alleviate this problem. Upon completion of the TSC, this problem will be resolved.
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Page 23
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RADIOLOGICAL PROTECTION AND CHEMISTRY Radiological protection and chemistry were evaluated by reviewing the perform-ance of radiological protection training, personnel dosimetry, external and internal radiation exposure, radioactive contamination control, and chemistry.
This portion of the evaluation was primarily an examination of plant programs as i
they function under normal (non-outage) conditions.
l A number of good practices were observed in radiological protection and chemistry. These included interest and involvement of operations management in improving radiological protection, and rigorous compliance with chemistry procedures.
4 The most significant problem areas were the generation of solid radioactive waste, inadequate personnel monitoring for radioactive contamination, and re-training of radiological protection technicians. These specific problems and the lack of programs, in general, to improve radiological protection appear to result from two tusic problems: (1) the lack of sufficient numbers of experienced technical personnel for program development, and (2) the absence of the Super-visor, Chemistry and Radiological Protectior. who is assigned work at corporate headquarters a majority of his time.
RADIATION PROTECTION AND CIIEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)
An evaluation was performed to determine the effectiveness of the management of the radiological protection program and to ensure that plant staff members have the knowledge and practical abilitics necessary to effectively implement radiological protection practices associated with their work.
1.
Finding (Criterion D)
A retraining program is needed for radiological protection and chemistry technicians.
j Recommendation Implement a radiological protection and chemistry technician retraining
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program to utilize the curriculum that has recently been developed.
Response
The Fort Calhoun Station computerized training record keeping system has been revised to include provisions for retraining of chemistry /radia-tion protection technicians. In addition, the station's training manual and the technician's qualification manual will be revised and the retrain-ing program implemented by April 1,1982.
2.
Finding (Category II)
Improvement is needed in the utilization of written examinations to i
i verify radiological protection training for radiological protection techni-cians.
Recommendation Establish a numerical passing score, and record the numerical exami-nation score achieved in training documents.
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Response
Numerical passing scores have been established for the examination, and the scores are entered into the training records.
PERSONNEL DOSl!AETRY (INPO Procedure RC-503, Revision 2)
An evaluation was performed to verify personnel radiation. Exposures were accurately determined and recorded.
1.
Finding (Criterion E)
Personnel skin contaminations are not documented.
Recommendation Prepare and implement procedures for recording personnel skin contami-nntion.
Response
The radiation protection manual has been revised to require documen-tation of personnel skin contamination. The revised prceedures have now been implemented.
2.
Finding (Criterion D)
The station should be evclunting differences in dosimetry measurements made by thermoluminescent. dosimeters (TLDsi and pocket dosimeters.
The plant has procedures requiring such evaluations; however, no record was found showing such evaluations have been made.
Recommendation Implement existing procedures f r evaluation of differences between dosimetry measurements made by TLDs and pocket dosimeters.
Response
Section 4.0 of Standing Order T-10 has been revised and evaluatior.s of all comparisons between TLDs and pocket dosimeters that do not meet a comperison criteria are now being documented.
3.
Finding (Criterion D)
Improved consistency is needed in the results of calibration tests of the station's neutron dosimetry system.
Recommendation Evaluate the neutron monitoring system to determine modifications necessary to imprc ve calibration consistency, or if the system should be replaced with an industry standard system to measure neutron cxposures with greater accuracy.
Response
The District is currently reviewing the calibration for the neutron TLD system, with particular attention to the thermal neutron calibration.
The District is also, with the aid of the new A-B rem-meter, re-evaluating the fast and thermal calibration factors for the Fort Calhoun Station. The results of this review and testing will determine whether M
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FORT CALHOUN (1981) l$
Page 25 I(
,e the present system can continue in service or if a replacement system 4
will be required.
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2 RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 2)
An evaluation was performed to determine if the plant was minimizing contami-nation of equipment and areas of the plant and to determine if personnel contaminations were minimized.
1.
Finding (Category II)
Station personnel monitoring practices are not always adequate to ensure detection of low levels of radioactive contamination. Current proce-durrs require use of only hand and foot monitors and a relatively insensitive portal monitor. Monitoring of the whole body is not per-formed.
These practices are not consistent with standard industry practice.
Recommendation Develop and implement monitoring procedures utilizing a sensitive beta detector to determine personnel contamination when exiting contami-nated areas.
Resporse A new procedure was written requiring whole body frisking when exiting the radiation controlled area, using a hand-held pancake GM counter.
Whole body frisking stations have been established at all normally used exits from the radiation controlled area.
2.
Finding (Criterion C)
Improved accessibility to the auxiliary building is needed. Protective clothing was required for access to all areas of the auxiliary building, i
even though many areas had contamination levels below surface con-tamination limits. Decontamination of a number of contaminated areas appeared practicable, j
Recommendation I
Establish a decontamination program that will maintain a major portion of the auxiliary building free of radioactive contamination.
Response
A formal decontamination program has been established with the objec-tive of maintaining a major portion of the auxiliary building free of radioactive contamination. This program consists of regularly scheduled decontamination of preselected areas of the auxiliary building every normal working day, Monday through Friday. This program has been effective in maintaining many areas of the auxiliary building below station contamination limits.
The District will continue to require protective clothing commensurate with the contamination levels identified in the auxiliary building as specified in the radiation protection manual.
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FORT CALilOUN (1981)
P;ge 26 WASTE AND DISCHARGE CONTROL (INPO Procedure RC-505, Revision 2)
An evaluation was performed to determine if releases of radioactive effluent to the environment were being minimized. An evaluation was also performed to determine if solid radioactive waste volumes were minimized Finding (Category 11)
Radioactive solid waste volume can be further reo ced.
Disposable clothing is often used even when reusable clothing is specified by the radiation work permit. More effort is needed to minimize materials and tools taken into controlled areas and to segregate non-radioactive and radioactive trash.
Recommendation Reduce solid radioactive waste generation by minimizing the use of disposable protective clothing, restricting the number of tools used in contaminated areas, and segregating non-radioactive from radioactive waste.
Response
An effort will be made to increase the use of reusable protective clothing in order to reduce solid radioactive waste volumes.
The station's existing policy to minimize materials and tools taken into controlled areas will be re-emphasized. More effort will be directed toward segregating non-radioactive from radioactive waste.
i RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)
An evaluation was performed to determine if the control and calibration of l
radiological survey equip nent is adequate.
Finding All criteria in this area were met.
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t PERSONNEL llEALTil PilYSICS INDOCTRIN ATION (INPO Procedure RC-507, Revision 2)
An evaluation was performed to de' ermine if leneral plant employees have the t
knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.
1.
Finding (Criterion B)
The general employee radiological protection retraining videotapes are not fully consistent with current station practices.
The tapes also appear to contain errors.
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l FORT CALilOUN (1981)
Page 27 Recommendation Update the videotapes to reflect current station practices and to correct errors.
Response
The general employee radiological protection retraining videotapes will be updated to identify current station practices and to correct errors and inconsistencies. The updating will be cote.pleted by April 1,1982 and will be periodically reviewed thereafter.
2.
Finding (Category II)
The same examination has been used for three successive years to verify general employee retraining in radiological protection.
Recommendation Change examinations on a more frequent basis or use a bank of questions.
Response
The examination for general employee retraining has been revised. A bank of pertinent examination questions has been established to ensure that tests are varied periodically.
PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2)
An evaluation was performed to determine if accurate measurements are taken and aggressive control of chemistry parameters is in use.
Finding (Criterion A)
The procedures for corrective action when out-of-specification chem-istry conditions occur are not sufficiently detailed to ensure proper corrective actions.
Recommendation Develop and implement detailed procedures for corrective action when out-of-specification conditions are recognized.
j
Response
Procedures for the correction of out-of-specification chemistry condi-tions for primary and secondary plant systems will be developed by April 1,1982.
l RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2) i l
l An evaluation was performed to determine if internal radiation exposure was being minimized.
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FORT CALHOUN (1981)
Page 28 Finding (Category II)
The station's records of monitoring for internally deposited radioactivity show a number of personnel with low levels of the fission products Cesium 134 and 137. The highest levels were recorded during the last refueling, in the first half of 1980. Although the levels are a small fraction of the established limits, the number of workers involved indicates the need for either improving cont 9mination control or respi-ratory protection.
Recommendation Identify the reasons for indicatian of low levels of internally deposited fission product activity. Both external radioactiu contamination and actual internal deposition of radioactivity should be checked.
Take appropriate corrective action to reduce indicatfor:s of internally de-posited radioactivity.
Response
The Distric*'s respiratory pogram is conducted in strict compliance with NRC Regulatory Guide 8.15 and NUREG-0041 recommendations.
As such, it is believed that the counting resuita are not indicative of abnormal amounts of internally deposited radionuclides caused by the Fort Calhoun Station operations, but the source of the activity will br.
identified and controlled.
The following additional measures have been taken:
o Calibration of the counter using a masonite phan*om has been performed in order to ensure that the counter :emains in good calibration.
o The station has implemented a new personnel external contamina-tion control program as described in our response to RC-504, Revision 2 of this INPO evaluation report.
o To ensure the Cesium 134 and 137 involved is not the result of external skin contamination, more care is being taken to reduce t
any chance of external skin contamination affecting the whole body counting results.
I RADIATION EXPOSURE REDUCTION GOALS (INPO Procedure RC-538, Revision 0)
An evaluation was performed to determine if the plant was minimizing personnel external radiation exposure.
Finding (Crif eria B and C)
The station personnel radiation exposure reduction program (ALARA) needs to be more aggressive in reducing personnel radiation exposure.
Exposure reduction goals should be established for specific jobs, outages, or total collective annual exposure.
Recommendation Expand the existing ALARA program to incorporate a system for l
establishing goals, following exposure trends, evaluating effectiveness of i
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FORT CALIIOUN (1981) h Pege 29 j
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the program, and initiating corrective action if exposure accumulatfori is increasing. This system should be used to reduce exposure during routme work as well as during outages.
Response
The District agrees that ALARA goals should be set and commits to establishing goals for the year, refueling outages, and major tasks beginning with 1982.
With regard to evaluating exposures during outages, doses during the outage are categorized according to task and evaluated from outage to outage to identify trends and identify needed improvements.
Fort Calhoun's ALARA program could be more aggressive. To this end, improved formal ALARA program requirements will be documented and followed.
Provisions will include (1) more frequent meetings of the ALARA committee, (2) an increased effort in identifying exposure reduction goals, (3) increased evaluation in routine work assignments as well as outage work, and (4) continuation and expansion of dose trending.
Need for ade.tional off-site District support to enhance this effort is under study.
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TECHNICAL SUPPORT l
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a An evaluation was performed to determine the effecti/eness of the on-site j
engineering support group in resolving problems and concerns of a technical nature.
The station engineering organization and most station engineering programs are functioning in an effective manner. The station engineering group has a number of very good procedures. Areas where improvements are needed are noted as follows.
TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS-701, Revision 1)
An evaluation of the Technical Department was made to determine if it is capable of performing all assigned responsibilities, if personnel are knowledgeable of their duties, if a training program exists to enhance and develop the skills and knowledge of personnel, and if non-technical personnel are utilized for non-technical tasks.
Finding (Criteria A and D)
Two findings in this area are detailed in Organization and Administration sections OA-101 and OA-102.
ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)
An evaluation was made in the area of plant performance monitoring, communi-cation with other groups, document control systems, and the on-site engineering support facilities.
1.
Finding (Criterion A)
The station needs a program for routinely assessing and improving plant thermal efficiency.
Recommendation A comprehensive program should be developed and implemented for routinely monitoring plant performance with an objective of improving i
plant operating efficiency and reliability.
Response
The District will develop and implement a program for routinely I
monitoring plant performance. This program is defined, and certain aspects of the program currently being implemented in the core follow program will be a part of the monthly Core Follow Reports. Operctional parameters that will be used for trending are currently being recorded, and the analysis to determine any needed corrective action will com-mence following the 1981 refueling outage.
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Page 31 2.
Finding (Criterion C) i
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The document control system is not totally effective.
Uncontrolled I
Piping and Instrumentation Diagranis (P& ids) and other uncontrolled documents can be used to operate and maintain the plant.
Recommendation o P& ids and other drawings used for reference to operate the plant should be controlled.
A major effort should be undertaken to ensure plant drawings agree o
with as-built conditions of the plant. P& ids should be completed first.
A drawing index should be maintained to provide the status of o
drawing revisions.
A periodic audit should be made to ensure that only latest drawing o
revisions are used by plant personnel.
Response
The District agrees P& ids and other drayings used for reference to operate should be controlled. By January 1,1982 a program will be developed and implemented for the control of P& ids and other drawings 6
used by plant operadng personnel.
'I The District enlisted an Architectural Engineering firm to perform a "walkdown" and field verification of all the Fort Calhoun P& ids. This i
task was cor.1pleted in late 1980, and the District is currently trying to identify and correct any deficiencies that still exist. These deficiencies are being corrected and "as-built" P& ids issued by January 1,1982. A major effort is being planned to update other Fort Calhoun drawings to as-built conditions.
A computerized index has been developed for Gibbs & Ilill engineering drawings and those of major vendors such as General Electric. This index will be maintained to reflect the current revision of these drawings.
The quality assurance organization will periodically audit the drawing control program af ter it is established.
3.
Finding (Criterion D)
The Technical Department workspace is marginal with the present number of people.
I Recommendation A review of the personnel and workspace for the Technical Department should be made. This review should be used to determine the workspace needed for each individual and the possible reassignment of some personnel to the new technical support facility or other facilities as appropriate.
Response
Additional office space will be provided for Training Department person-nel and shif t technical advisors upon completion of the TSC. Providing I
additional office space in the old maintenance shop and lobby of the plant is also being considered.
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Page 32 I
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM j
i (INPO Procedure TS-703, Revision 1)
An evaluation was made of the program for handling in-house and nuclear industry operating experiences, utilization of experienced technical personnel, periodic review of program effectiveness, and periodic independent evaluation of industry experiences to verify, proper disposition.
1.
Finding (Criterion B)
Improvements in the existing program are needed to ensure that Signifi-cant Operating Experience Reports (SOERs) and the attendant recom-mendations are reviewed for applicability by experienced technical personnel and appropriate action taken. Review and follow-up action has been completed on only two SOERs to date.
Recommendation The existing program should be revised to include a timely review and evaluation of each SOER by experienced personnel to detcrmine appli-cability to Fort Calhoun and the appropriate corrective action.
The program should also assign responsibility for any follow-up cetion to be taken.
Response
Emphasis is being placed on reducing the backlog of unreviewed SOERs.
The review of the existing SOERs will be completed by January 1,1982.
Corrective action will be taken as appropriate. The status of SOER recommendations will be reported to INPO in the District's follow on responses six months from the date of this report.
2.
Finding (Criteria D and E)
The existing program should ensure that tne information disseminated to station personnel is timely, applicable, and not contradictory.
Recommendation The existing program should be fully implemented.
The Reactor Engineer, as stated in the existing procedure. should receive all the operating experience information from off-site. Ile should screen and disseminate information to station personnel. A single screening point will help avoid non-assigned actions or contradictory instructions.
Response
The reactor engineering group now reviews incoming information (e.g.,
NOTEPAD and SOERs) for applicability to the Fort Calhoun Station. If the information is felt to be applicable, it is then forwarded to l
l appropriate station staff members. For example, information on im-proved methods for chemical sampling would be forwarded to the Chemistry and Radiation Protection Supervisor.
The Reactor Engineer receives INPO/NSAC correspondence directly l
from Administrative Services.
This cyy is used for review and i
dissemination to the station staff.
In addition, the Manager-Fort Calhoun Station receives a copy for his information directly from Administrative Services. Since the manager is directly responsible for safe plant operation, it is important that he receive these information copics.
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l FORT CALIIOUN (1981) l Page 33 l
l Operations incidents from the Fort Calhoun Station are not included in the Reactor Engineer's responsibilities sicce operation incident review and disposition is administered by the Pla~ ' Review Committee.
l 3.
Finding (Criteria G.2 and G.4)
The disposition of some operating experience information received is not documented. The log maintained by the Reactor Engineer addresses only those items he judges to be pertinent; other information is disposed of.
A periodic, independent review to verify that all information is properly addressed is not made.
Recommendation The disposition of all operating experience information received should be logged. Information judged to be pertinent should be passed on to appropriate personnel and the remaining information filed. An indepen-dent review should be made periodically to ensure all material is properly classified.
Resporse l
All operating experience information is now documented, logged, and j
filed in the Reactor Engineer's office. A periodic review will be made by i
an experienced engineer to ensure that all operating experience infor-mation has been properly classified.
Quality Assurance has been requested to perform periodic audits of the operations review assessment program.
4.
Finding (Criterion F.2)
The program does not include provisions to promptly notify other utilities concerning significant events having generic implications. The Administrative Orders address the requirements for reporting events to the NRC but not to other utilitics.
Recommendation The existing station policy regarding dissemination of information con-cerning significant in-house events should be reviewed.
This review should be the basis for revising station procedures to include placing information into the NOTEPAD system.
Response
Operations incidents are now being areened for possible generic impli-cations. Operations incidents that are determined to fall within this category are reported by the plant staff via the NOTEPAD system.
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PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 1) l An evaluation was made of the program for control and processing of plant l
modifications to determine if modifientions are implemented in a timely manner and if they maintain the proper quality of plant systems, components, procedures, and training. The modification control procedure (Standing Order G-
- 21) is an excellent procedure; however, the modification program is not effective, and some specific areas of the program should be improved.
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Page 34 1.
Finding (Criterion C)
Station personnel should follow the status of each outstanding modifica-tion request.
Recommendation A system for tracking the status of each plant modification should be
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used by station personnel to ensure that the status of each modification is correct and that prompt action is taken when needed. Each modifica-tion request should be tracked until the package has been closed out and the final documents have been issued.
Raponse The Scheduling and Budgets Department provides a computerizedlisting of each modification request, which includes an indication of progress through each critical modification step, including a Modification Com-pletion Report and Drawing Update. Station personnel will monitor and provide update information as required to ensure status is accurate.
2.
Finding (Criterion F)
. Design changes should undergo a formal, technical, interdisciplinary review and approval.
Recommendation Design Procedure B-3 should be revised or a new method created to ensure that each discipline is aware of the modifications the other disciplines are making.
An interdisciplinary review and approval of drawings is one way of ensuring that the other disciplines are aware of each discipline's action. This would reduce the potential for interference problems in implementing design changes in the plant and should help ensure that each design package has been completed by each discipline prior to final review by plant personnel.
Response
Design Procedure B-3 will be revised to require interdisciplinary review as the normal routine. The proccoure will also specify who has authority to waive this requirement for inspection or review by another depart-ment.
3.
Finding (Criterion F)
Temporary electrical jumpers sometimes remain in service for extended periods of time without a technical review and approval.
Long-term jumper installation constitutes a change in the system design and should be treated as a modification.
Recommendation The review process for temporary electrical jumpers should ensure that temporary jumpers are removed after a reasonable period of time or are processed as a modification.
Response
Standing Order A-b-25 requires the Supervisor-Instrument & Control and Electrical Field Maintenance, or his designated alternate, to review monthly the jumper log installed jumpers and blocks. The Standing Order will be changed to require the Supervisor-Instrument & Control and Electrical Field Maintennnce, or his designated alternate, to initiate an Engineering Evaluation Assistance Request if the situation warrants a modification to the system in question. This change will be made by January 1,1982.
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Page 35 i
4.
Finding (Criterion H)
Station personnel should have direct control of off-site personnel imple-menting, inspecting, and testing modifications when on site.
liecommendation Company management should take steps to ensure each off-site person who works at the station understancis the importance of following the procedures established by station management to ensure the Technical Specifications are not violated, and the proper quality of plant design and operation are maintained at all times. Station procedures should be adhered to by all personnel involved in implementing a design change at Fort Calhoun.
Response
The District concurs with the recommendation and will require that all off-site personnel working at Fort Calhoun be retrained annually in the importance of procedure compliance and maintenance of quality design and operations. In addition, procedure reviews and reviews of completed procedures will continue to be utilized to update procedures that control off-site personnel performing modification-related activities.
5.
Finding (Criterion 1)
Improvements are needed to the present program to ensure that station personnel have as-built drawings and that operator training has been completed prior to placing a modified system in service.
Recommendation The present program (Standing Order G-21) should be adhered to by all personnel to ensure that appropriate training and information have been j
provided to the operators prior to placing a modified system in service.
Response
Standing Order G-21, entitled " Station Modification Control," provides a program for ensuring the update of as-built drawings and requires that the Training Department review modifications for training requirements.
The Standing Order specifies that design documents affected by a modification will normally be updated by Generation Station Engineering within six weeks following the receipt of a modification completion report. Every effort will be made by the station staff to ensure that modification completion reports are submitted in a timely fashion so the drawings and other design documents can be appropriately updated.
Operating personnel training that is required as a result of modifying a station system or component will be completed prior to placing that system in service.
I 6.
Finding (Criterion 1)
Final document revisions should be issued in a more timely manner s
following implementation of a modification in the plant.
Recommendation The present program should oc adhered to by all personnel to ensure that all documents affected by plant modifications are revised and issued as I
stated in the modification control procedure (Standing Order G-21).
Response
An intensive effort is being planned to update drawings to reflect as-built conditions in the plant. Additional personnel have been authorized I
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to hcip with this function and for updating of documents following i
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1T FORT CALHOUN (1981)
Page 36 completion of modifications now in progress.
Generation Station Engineering will continue to attempt to update all documents affected l
by a modification within six weeks of receipt of a modification comple-tion report.
ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
An evaluation was made of the program for the on-site reactor engineering including procedure review, computer availability, communication with other groups, fuel integrity commitments, and refueling activities. It was noted that special circumstances existed during the evaluation due to the recent loss of the former Reactor Engineer and that special emphasis to supplement the on-site reactor engineering program with off-site support personnel was in effect.
Finding All criteria in this area were met.
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FORT CALIIOUN (1981)
Appendix Page 1 ADMINISTRATIVE APPENDIX I.
LISTING OF AllEAS EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-106 Industrial Safety OA-107 Surveillance Program OA-108 Personnel Qualifications TRAINING AND QUALIFICATION TQ-201 Training Organization TQ-202 Training Administration TQ-205 Training Resources TQ-223 Licensed Operator Requalification TQ-224 Shif t Technical Advisor Training TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training OPERATIONS OP-301 Operations Organization and Administration OP-302 Tagout Practices OP-303 Conduct of Shift Operations OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-307 Shif t Turnover MAINTENANCE MA-401 Maintenance Organization and Administration M A-402 Preventive Maintenance MA-403 Maintenance Procedures MA-404 Work Control System MA-405 Maintenance Ilistory MA-406 Control and Calibration of Test Equipment and Instrumentation MA-407 Control of Special Processes MA-408 Maintenance Facilities and Equipment
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FORT CALHOUN (1981)
Appendix Page 2 R ADIOLOGICAL PROTECTION AND CllEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control RC-505 Waste and Discharge Control RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel licalth Physics Indoctrination RC-508 Process Water Controls RC-511 Respiratory Protection Program RC-538 Radiation Exposure Reduction Goals TECilNICAL SUPPORT TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience Evaluation Program TS-704 Plant Modifications TS-705 On-Site Reactor Engineering i
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FORT CALilOUN (1981) l Appendix Page 3 11.
OM All A PUBLIC POWER DISTRICT PERSONNEL CONTACTED General Manager Assistant General Manager Division Manager - Production Operations Division Manager - Environmental and Regulatory Affairs Section Manager - Operations Manager - Production Operations Administrative Services Section Manager - Technical Services Manager - Ft. Calhoun Station Supervisor - Operations Supervisor - Maintenance Supervisor - Training Supervisor - Technical Supervisor-Administrative Services Supervisor - Chemistry and Radiation Protection Supervisor - Mechanical Field Maintenance j
Supervisor - Training Coordinator Quality Assurance / Quality ControlInspeetors l
Electrical Engineer Instrumentation and Control Engineer j
Quality Control Clerk l
Fitter - Pressure Equipment Foreman Mechanical Foreman Instrumentation and Control Technician General Maintenance Foreman i
Stores Assistant Shif t Supervisors Reactor Operators Assistant Reactor Operators Equipment Operators Plant Engineer
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Reactor Engineer Shif t Technical Advisors Plant Health Physicist Plant Chemist
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