ML20033A746
| ML20033A746 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/31/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| Shared Package | |
| ML20033A744 | List: |
| References | |
| NUDOCS 8111270212 | |
| Download: ML20033A746 (39) | |
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Evaluation Report October 1981 Quac Cities Nuc ear Power S:a: ion Commonwea :1 Ecison Comoany 1
I EVALUATION of QUAD CITIES NUCLEAR POWER STATION Commonwealth Edison Company October 1981
QUAD CITIES (1981)
Page1 SUM M ARY INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Commonwealth Edison' Company's (CECO) Quad Cities Nuclear Power Station during -
the weeks of June 15 and 22,1981. Quad Cities consists of two 789 MW net General Electric boiling water reactors.
The station is located on the Mississippi River, approximately 20 - miles northeast of Moline, Illinois.
Unit 1 began commercial operation in February 1973, and Unit 2 began commercial operation in March 1973.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of '
plant operating safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, observations, and reviews of plant documents.
The INPO evaluation team examined station organization and administration, training, operati<.ns, maintenance, radiological and chemistry activities,. and site technical suppo:t. Corporate activities were not included in the scope of the evaluation, except as an incidental part of the station evaluation. As a basis for the evaluation,INPO used performance objectives and criteria relevant to each of the six areas examined; these
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w2re applied and evaluated in light of both the experience of team members and INPO's observations of good practices within the industry.
INPO's goal is to assist member utilities in achieving the highest standards of excellence in all phases of nuclear plant operation. Accordingly, the conditions found in each area were compared to best practices, rather than to minimum acceptable conditions or requirements.
DETERMINATION Within the scope of this evaluation the team determined that the plant is in satisfactory material condition and is being operated in a safe mr.nner by qualified personnel.
Certain beneficial practices and accomplishments were r.oted by the evaluation team:
Plant availability has been consistently high as evidenced by capacity factor history.
The site training staff is highly qualified. Eight of nine instructors hold senior reactor operator licenses and are assigned to shift foreman positions on a r'. gular basis to maintain their operational proficiency.
Plant management actively supports professional development of mid-level managers. Supervisors are rotated through key plant positions as opportunities are ' identified.
Managers are encouraged to study for, acquire, and maintain reactor
QUAD CITIES (1981)
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operator licenses. Several management personnel cerrently hald senior reactor operator licenses.
The plant has experienced low personnel turnover. As a result, staff experience level is high in many areas.
Improvements were recommended in a number of areas. The following are considered-to be among the most important:
Control room activities need to be upgraded, both in terms of operating practices and formality.
Use of procedures needs improvement in the control room as well as in other areas of the plant.
Plant housekeeping needs improvement.
The plant is not fully benefitting from the information contained in Significant Operating Experience Reports (SOERs) issued jointly by INPO and the Nuclear Safety Analysis Center (NSAC).
The radiation protection program requires greater management attent!on in four major areas:
a.
generation of solid radioactive waste b.
personnel erposure control c.
surface contamination in certain areas of the plant d.
the occasional spread of contamination to clean areas within the plant and the potential for the spread of contamination off-site.
In each of the six creas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of this evaluation are listed in APPENDIX A.
Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to which they pertain.
Particularly noteworthy conditions that contribute to meetilig PERFORMANCE OBJECTIVES are identified as Good Practices.
Other find;rts describe conditions that detract from meeting the PERFORMANCE OBJECMES. It would not be productive to list as Good Practices those things that are commonly done in the industry since this would be of no benefit to CECO or to INPO's other member utilities. As a result, most of the findings highlight conditions which need improve-ment.
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 recom nendations the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.
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Page 3 The findings listed herein were presented to CECO management at an exit meeting at the plant on June 25,1981. Findings, recommendations, and responses were reviewed with CECO management on September 10, 1981.
CECO responses are considered satisfactory.
To follow the timely completion of the improvements included in the responses, INPO requests wr.tten notification of status six months from the date of this report.
The evaluation staff e,preciates the cooperation received from all levels of Common-wealth Edison Company.
E. P. Wilkinson President
QUAD CITIES (1981)
Page 4 COMMONWEALTH EDISON COMPANY Response Summary The following is CECO's response to INPO's recommendations as found in the Quad Cities evaluation. We have set specific cates, where applicable, for the implementation of these recommendations. We will report our progress on individual recommendations within six months of the date of this report.
We believe thet the recommendations offered in ti!s management evaluation report are beneficial and will improve the mhnagement and operation of Quad Cities Station; therefore, we are committed to their imphmentation.
Commonwealth "dison is pleased that INPO agrees that the Quad Cities Station is being operated in a safe manner by qualified personnel. We also appreciate the " beneficial practices and accomplishments" noted by the evaluation team, in particular those relating to high plant availability, highly qualified site training staff, low personnel tarnover, and opc support for professional development.
However, in addition, we re:ognize that there are areas needing improvement, and we will address those in a prompt manner. Our commitments to address areas needing improvement are shown in the responses to individual findings.
We appreciate the cooperation and dedication of your organization and are committed to the prompt completion of our corrective actions.
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Page5 TRAINING AND QUALIFICATION TRAINING ORGANIZATION PERFORMANCE OBJECTIVE: Provide a clearly defined training organization staffed with qualified personnel capable of accomplishing a" assigned training tasks.
Finding A Good Practice in maintaining instructor currency and proficiency (TQ.1-1) was noted. Instructors for licensed operator training and retraining programs enhance their qualification by periodic involvement in shift operations.
These instructors are assigned to the Shift Foremar. position on a rotating schedule. This practice assists licensed instructors in maintaining familiarity with plant opera-tions.
NON-LICENSED OPERATOR TRAINING PERFORMANCE OBJECTIVE: Develop and maintain the skills and knowledge neces-sary for non-licensed operators to perform their assigned job functions.
Finding The Equipment Attendant (EA) cualification program is not (TQ.4-1) sufficiently comprehensive.
The pr ogram does not identify job functions to be covered during the on-tho ;0b training phase and does not provide adequate equipment attendant experience in selected tasks. In addition, the Equipment Attendant qualification program does not cover several routine duties such as shift turnover and responsibilities for regular monitoring of plant equipment and paces.
Recommendation A structured on-the-job training phase should be developed and implemented as part of the qualification program for equipment attendants.
The program should identify job functions to be performed, observed, or discussed during this training phase.
Response
A structured on-the-job training phase will be developed and implemented as part of the qualification program for equipment attendants by December 1,1981. A job task analysis for the EA position is currently in progress on a corporate level. The results of the task analysis will be incorporated into the on-the-job training and requalification program upon completion of the task analysis.
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Paga 6 Finding Retraining is not being conducted for all equipment attendants.
(TQ.4-2)
Retraining sessions are regularly scheduled, but several equipment attendants have not attended.
Alternate or make-up training sessions have not been conducted.
Refresher training in plant systems and additional jotrrelated technical training are missed as a result of this practice.
Recommendation Equipment attendant participation in the retraining program should be closely monitored.
Job assignments which interfere with retraining should be minimized, and essential information missed by equipment atter4 ants should be covered by other means.
Response
Participation by equipment attendarts in the retraining program will be closely monitored. it is CECO's intent to approach 100 percent coverage of personnel in the Equipment Attendant Group in the retraining program.
Makeup training will be utilized as necessary to meet this intent.
LICENSED OPERATOR TRAINING PERFORMANCE OBJECTIVE: Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.
Finding The Licensed Operator qualification por, gram is not sufficiently (TQ.5-1) comprehensive. The program does not identify job functions and technical information to be covered during the on-the-job training phase.
Trainee participation in selected plant evolutions and review of sdected procedures is not required.
Recommendation A structured on-the-job training phase should be developed and implemented as part of the qualif. cation program for licensed op-erators.
Thc program should identify job functions to be per-formed, observed, or discussed during this training phase.
Response
A list of job functions to be performed, observed, or discussed during the on-the-job training phase of the Licensed Operator qualification program has been written and implemented. These functions will be reviewed against the results of job task analyses currently in progress at the corporate level, and necessary changes will be made upon completion of the review.
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Page 7 Finding Good Practices were noted in the simulator training program for (TQ.5-2) initiallicensed operator training. Simulator instructors are select-ed from the plant training staff to implement and evaluate the simulator training sessions. In addition, the simulator training is conducted using Quad Cities plant procedures and technical speci-fications.
These practices significantly enhance the training benefit derived from the non-plant-specific simulator used for operator training.
MAINTEN/.NCE PERSONNEL TRAINING PERFORMANCE OBJECTIVE: Develop and maintain the skills and knowledge neces-sary for maintenance personnel to perform their assigned job functions.
Finding The Instrument Mechanic qualification program is not fully imple-(TQ.8-1) mented. Plant instrument systems training has been conducted in the past for instrument mechanics.
However, systems trainin7 currently is not being conducted and has buen limited during the last two years.
Recommendation The instrument systems training program should be conducted on a regularly scheduled br sis. Instrument mechanics should complete the instrument training program as part of their qualification.
Response
Systems training has been conducted in the Instrument Mainte-nance Department, but not on a regular basis. Systera train'ig will return to a regularly scheduled basis following the fall 1981 refueling outage, and every effort will be made by CECO to keep it on a regular basis. System training will be given initially to qualify a new instrument mechanic once assigned to the department, e.nd retraining will be provided to keep the mechanics up-to-date.
Finding The Electrical Mechanic qualification program is not fully imple-(TQ.8-2) mented. Plant electrical control systems training materials are needed, and systems training is conducted only through informal on-the-job trai' ling.
Recommendation An electrical systems training program should be established and systems training materials developed. Electrical mechanics should complete systems training as a part of their qualification program.
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Response
The Electrical Maintenance Department systems training program is being developed and will be implemented by June 1,1982.
Systems training will be given intially to qualify a new electrical mechanic once assigned to the department, and retraining will be provided to keen the mechanics up-to-date.
QUAD CITIES (1981)
Paga 9 OPERATIONS OPERATIONS FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Provide plant facilities and equipment that are operated and maintained at a level to support safe and efficient operation.
Finding Cleanliness and material condition need improvement in certain (OP.2-1) areas of the plant. Specific areas observed to be in need of general improvement were the turbine building basement, emergency core cooling system (ECCS) equipment rooms, radwaste areas, residual heat removal (RHR) service water pump areas, and control room pane surfaces.
Material condition was somewhat degraded as evidenced by minor leaks, some instruments reading offscale, local valve indicators with burned out bulbs or missing lens caps, and excessive seal water leakage on RHR service water pumps, Recommendation Assign departmental and individual responsibilities for house-keeping and material problems. Increase management attention in these areas as necessary to ensure improvement is achieved.
Response
A procedure revision to QAP 200-13, Station Housekeeping Organi-zation, will be written and implemented by December 1,1981 to address departmental and individual responsibilities in y ving housekeeping and plant cleanliness. Inspe;. ions, surveys, corree-tive actions, material storage, and fire protection will be included in this revisior.
It is CECO's intent to improve housekeeping through the implementation of the above program.
CONDUCT OF SHII'T OPERATIONS PERFORM ANCE OBJECTIVE: Ensure that shift operations are conducted in a safe and reliable manner.
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Finding Instances were noted where nuclear station operators were not (OP.3-1) conscientious in monitoring changes in plant parameters. Com-munications between the Center Desk Operator and the Unit Nuclear Station Operator during periods when the Unit Nuclear Station Operator must leave the front panel area needs improve-ment.
Recommendation Provide guidance and instruction to the control room operators on improved monitoring of and attentiveness to control room panels.
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Response
Guidance and instructions have been provided to the control room operators to improve compliance with existing regulations and company policy. These requirements will be reviewed and rein-forced with the Operations personnel. This actions will be com-pleted by November 1,1981.
Finding The number of control room annunciators normally in an alarmed (OP.3-2) condition was considered to be excessive.
Recommendation More aggressive action to eliminate the cause of continuously activated annunciators is needed.
Response
Programs have been implemented in the past to review, modify, or eliminate alarmed annunciators so this system can be more mean-ingful. Further evaluations will be initiated by October 1,1981.
Station Nuclear Engineering will be consulted as necessary, for modifications to the annunciators.
Finding
- h. stances were noted where the conduct of control room operations (OP.3-3) was not in accord nce with good operating practices.
Nuclear station operators and center desk operators are sometimes too casual in their approach to routine shift evolutions. Com munica-tions between nuclear station operators and equipment attendants while coordinating activities were sometimes informal.
For example. on one occasion a caution was ignored in an approved surveillence procedure. In a separate instance, surveillance testing was conunued after unexpected results occurred.
Recommendation Provide instruction to nuclear station operators on good operating practices, which includes proper communication of tasks to be performed, proper performance of tasks, and adherence to ap-proved procedures.
Improve management supervision and spot checking of control room activities.
Response
Good operating practices covering procedure adherence and com-munications will be reinforced and will be reviewed with licensed operating personnel. Supervision of control room activities, utiliz-ing primarily the Station Control Room Engineer (SCRE), will be reinforced by discussions and spot checks by management.
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QUAD CITIES (1981)
Page 11 PLANT OPERATIONS PROCEDURES PERFORMANCE OBJECTIVE: Provide timely, effective guidance to operators in the form of written procedures.
Finding Uncontrolled notes, graphs, portions of procedures, labels, and (OP.4-1) drawings of a temporary nature that are used as operator aids are attached to control panels at various plant locations.
Recommendation Implement administrative controls for all written instructions or aids used by operations personnel. The use of posted instructions should be minimized.
Response
A program has been initiated to reduce or eliminate where possible the graphs, labels, and drawings that are in place and used as additional operator aids. Labels that appear to be temporary will be reviewed and will be made permanent where the label provides useful information that would be difficult to convey in any other manner. These actions will be completed by December 1,1981.
Finding Guidance to operating personnel on the use of procedures is not (OP.4-2) considered adequate in some areas, as follows:
a.
action to be taken when procedures are found to be in-adequate for the intended tasks or when unexpected results occur b.
directions for when procedures are to be used as general guidance, followed step-by-step, sign-off required, etc.
c.
identification of procedures required to be in hand when performing the operation to which they pertain d.
action to be taken if procedures conflict.
Recommendation Implement instructions covering t!,e use of procedures. Provide guidance in the areas noted above as a minimum.
Response
A procedure will be written by October 1,1981 as guidance to operators to better define actions they should take for the areas listed.
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Page 12 PLANT STATUS CONTROLS PERFORMANCE OBJECTIVE: Maintain plant status in a condition that ensures equip-ment and system availability as necessary for safe and reliable plant operations at all times.
Finding Drawings provided for operators in the control room are marked (OP.5-1)
"for reference only" snd are infrequently updated. They were used by personnel it: lhe control room for tagouts and other operational activities.
Recommendation A controlled and r:urrent set of drawings should be maintained in the control room.
Response
A current set of drawings has been provided in the control room. A mechanism for updating these reference drawings is presently being developed and will be formulated by January 1,1982.
SHIFT TURNOVER PERFORMANCE OBJECTIVE: Ensure a continuous and correct understanding of plant conditions at all shif t operating positions through proper shift turnover.
Finding Turnover procedures and checklists are not used for some shift (OP.6-1) positions.
Observations of shift turnovers for other positions indicate that they are not always conducted in accordance with existing procedures.
l Recommendation Implement turnover procedures and checklists for all Operations
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Department positions. Require their rigorous use at each turnover.
Response
Turnover procedures and checklists will be reviewed, revised where necessary, and implemented for all shif t positions. A program will be implemented to ensure a more rigorous use of all procedures and checklists associated with shift turnover. These actions will be completed by January 1,1982.
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Page 13 TAGOUT PRACTICES PERFORMANC uBJECTIVE: Protect personnel and plant equipment by implementing effective tagout prar. ices.
Finding Tagout lineups are performed in some cases by (cerators who may (OP.7-1) not me sufficient knowledge of the systems t.N y are tagging.
e Interviews with various nuclear station operators indicated that several lacked confidence in the " systems" knowl'dge of their equipment attendants.
Recommendation Implement policies and procedures to ensure that tagging of equipment is performed by operators who have adequate knowledge of systems and component locations.
Response
Equipment attendants are given initial training covering plant systems, and re-training is given to reinforce their basic systems knowledge. Any initial training inadequacies will be addressed by the program outlined in the response to TQ.4-1.
The retraining program will be evaluated to determine if it is sufficient to provide adequate reinforcement.
Finding Tagout precedures do not provide for pericdic review and audit of (OP.7-2) the status of tagouts. Audits are occasivially performed by the Shif t Engineer; however, this effort is informal and the results are not documented.
Recommendation A procedure requiring periodic audit of all active tagouts should be implemented. The scope, depth, and frequency of the audit should be specified. A requirement to document the results and to report unexpected findings to the appropriatc level of authority should be included.
Response
A tagout procedure will be written that will require periodic review of all active out-of-service cards. The scope, depth, and frequency will be specified, along with corrective action require-ments. This action will be completed by November 1,1981.
QUAD CITIES (1981)
Page 14 MAINTENANCE MAINTENANCE ORGANIZATION AND ADMINISTRATION PERFORM ANCE OBJECTIVE: Provide a clearly defined maintenance organization tho' is adequately staffed, assigns responsibilities, and delegates adequate authority for thu accomplishment of assigned tasks.
Finding Procedures governing the Preventive Maintenance Program havo (M A.1-1) not been provided. The result is periodic maintenance which may not be well controlled, reviewed, or evaluated for completeness and accuracy. Better assurance that all important plant equipment is undergoing adequate routine maintenance on a periodic basis is needed.
RecommLndation Develop and implement a more comprehensive program for pre-ventive maintenance.
Response
The station has been provided a " Preventive Maintenance Adminis-trative Guideline" from the Commonwealth Edison Company cor-porate office. The station is pursuing the development of a more formal preventive maintenance program based upon this guideline.
MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Support the performance of maintenance activities by providing adequate facilities and equipment.
Findi g Office facilities for staff personnel of the mechanical and elec-(M A.2-1) trical sections of the Maintenance Department are generally in-adequate from the standpoint of available space and freedom from distraction and interference.
It is recognized that efforts to correct the situation are in progress.
Recommendation Provide adequate office space.
Response
Construction of an addition to the service building is expected to be completed by the end of October 1981. -This will alleviate the problems with the present office space.
QUAD CITIES (1981)
Pags 15 WORK CONTROL SYSTEM PERFORMANCE OBJECTIVE: Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently disposi-tioned and documented.
Finding Radiation protection and low radiation exposure (ALARA) consid-(M A.3-1) erations are not included as part of the work control system planning and review process.
Recommendation Undertake measures that will ensure qualified supervisory review of radiation protection and ALARA considerations for appropriate jobs.
Response
Commonwealth Edison is pursuing implementation of its ALARA Program. The preplanning of specific wcrk, in addition to the review of and response to exposure trends, is part of the program.
The use of task-based goals is viewed by the company to be an effective tool in reducing radiation exposure. Once full staffing of the ALARA pronam is achieved, its operations will fulfill the INPO recommendations and make the CECO 5 rem annual individ-ual exposure goal more achievable. This item is an ongoing CECO program and will be implemented in accordance with the goals of the CECO corporate office. The Station ALARA Coordinator has attended, and will continue to attend, the daily morning work planning meetings in order that he review new work requests pursuant to radiation protection planning.
He will provide the necessary radiation protection management input to determine protective measures and to minimize the spread of contamination for appropriate jobs.
This item will be incorporated into the position description document for the ALARA Coordinator by November 1,1981.
Finding Outstanding routine work is not always effectively controlled, (M A.3-2) reviewed, and closed out in a timely manner. While priority A and B-1 jobs appear to be given sufficient management and supervisory attention, work of lower priority is not effectively reviewed for status or timeliness of completion. Deferral of such work is not always authorized by a senior individual in the maintenance organi-zation.
Approximately 850 non-outage work requests are out-standing, some over two years old.
A random sampling of mechanical and electrical work requests indicated that a signifi-cant number had been either completed previously or were actually outage work.
Recommendation Institute a periodic review of outstanding work requests to effect their completion in a timely manner, to ensure prompt close-out of
QUAD CITIES (1981)
Page 16 completed work, and to keep maintenance history current. Assign work det'erral review responsibility to a senior individual in the maintenance organization to ensure that established work priorities are beirg observed.
Response
Outstanding work requests will be reviewed semi-annually by senior individuals in the Maintenance Department. This review task will be stated in the position description for the appropriate individuals and placed on the Maintenance Recall File. The position descrip-tion will be revised, ad the review will be initiated by January 1, 1982.
MAINTENANCE PROCEDURES PERFORMANCS OBJECTIVE: Ensure that adequate plant maintenance procedures exist and are t. n.:ed to achieve quality by the safe and reliable conduct of maintenance activn. s.
Finding Vendor manuals used for maintenance are not always current.
4 (M A.4-1)
Recommendation Establish a system that ensures vendor manuals used for reference in conducting maintenance of selected plant systems and compo-nents are current, or are given appropriate engineering review and are certified adequate for the work to be performed.
Response
Maintenance work is conducted in accordance with approved work procedures, which may reference vendor manuals or portions thereof. In the course of review and approval of these procedures, the certification of the undor manual accuracy and adequacy is accomplished. These procedures are examined and approved by the Maintenance Assistant Superintendent, Quality Control, Quality Assurance, and the Tech Staff Supervisor.
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Finding Guidance to maintenance personnel on the use of procedures is not (M A.4-2) considered adequate in some areas. Observations and interviews inc. ate that use of procedures by maintenance personnel is irc ansistent and sometimes improper. The decision as to how a pr ocedure is to be used is often left to the craftsman.
Recommendation See the recommendation for Finding OP.4-2.
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Response
A procedure will be written by November 1,1981 as guidance to maintenance personnel to better define actions they should take in the use of procedures. (See also response to Finding OP.4-2)
M AINTENANCE HISTORY PERFORMANCE OBJECTIVE: Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvements in equipment performance.
Finding The following Good Practice was noted: Copies of the current (M A.5-1) maintenance history card are attached to each applicable work request. This practice facilitates and enhances the work request review process.
Finding Maintenance history does not, in all cases, contain sufficient detail (MA.5-2) to fully describe the circumstances, conditions, and significance of the maintenance activity, or to allow for meaningful evaluation of equipment performance and identification of persistent or recur-ring maintenance problems. Additionally, the cause of failure (or other need for repair) is usually not indicated. The maintenance history program is not governed by an approved administrative procedure.
Recommendation Provide a maintenance history that better facilitates analysis of equipment performance. Formalize the current program, including documentation of the methods in use.
Response
This area will be addressed in the station's Preventive Maintenance Prcegram. Sec response to Finding MA.1-1.
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QUAD CITIES (1981)
Page 18 R_ADIATION AND CIIEMISTRY RADIOLOGICAL PROTECTION TRAINING PERFORMANCE OBJECTIVE: Ensure that personnel on the site have the knowledge and practi al abilities necessary to effectively implement radiological protection practices aasociated with their work.
Finding The general employee radiological protection training program (RC.2-1) needs improvement in the following areas:
a.
Plant employees were not required to demonstrate practi-cal abilities during general employee radiological protec-tion training.
b.
Some general employee training instructions contain con-flicting information.
c.
Written examinations for general employee training need improvement.
Recommendation Include practical abilities in the general employee radiological protection training program and eliminate conflicting information in the program. Improve written tests so that they will better determine employee knowledge of the radiological protection pro-gram.
Response
The Nuclear General Employee Training (NGET) program now incorporates a practical demonstration of techniques to be em-ployed in the proper donning and removal of protective clothing and in personnel contamination survey methods using GM-type instruments. The practical demonstration will involve participa-tion by those personnel in the class who have not previcusly worked at a nuclear power facility in radiation areas.
Personnel not expected to work in radiation areas would be exempt from this demonstration.
NGET training will be reviewed for conflicting information and in addition, the written examinations will be reviewed and revised as necessary.
Finding The radiation and chemistry technician training program needs (RC.2-2) improvement in the following areas:
i a.
Oral examinations are not used for initial qualifications of radiological protection and chemistry technicians.
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Page 19 b.
Radiological protection and chemistry.echnicians do not receive plant systems training. It is understood that the plant trainin; department plans to offer systems training to these personnel by August 1981.
Recommendation Include oral examinations in the technician training and qualifi-cation program to explore areas of weakness demonstrated on written tests. Oral examinations may also be used to determine the technician's ability to use his knowledge in unusual or complex situations.
Provide plant system training for technicians to aid them in applying radiological protection requirements to work on or around these systems.
Response
Oral examinations designed to assess areas of weakness demon-strated on written examinations will be incorporated in future Rad-Chem Technician training. Plant system training will be provided to all future Rad-Chem Technician classes. This training will be delivered to the current Rad-Chem Technician staff as part of an-expanded 1982 technician retraining program. This item will be implemented by March 1,1982.
EXTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: Minimize personnel external radiation exposure.
Finding Planning to reduce personnel radiation exposure appeared insuffi-(RC.4-1) cient. It is recognized that a number of exposure reduction efforts have been undertaken during some major plant modifications.
liowever, more effort is needed for normal operations and routine outage work.
The plant's ALARA committee has had a few meetings, and, until the last few weeks prior to the evaluation, the ALARA coordinator had spent only a small fraction of his time on ALAR A work. Although the station does have an administrative goal of 5 rem per year for individuals, this goal frequently has not been achieved.
Recommendation Expand the ALARA program to include preplanning for specific jobs, following exposure trends, and initiating corrective action if exposure trends or accumulation are excessive. Stricter adherence to the individual annual exposure goal of 5 rem is recommended.
Goals are recommended for sp! ific jobs when significant exposures are anticipated. Overall annual goals are recommended.
Response
Commonwealth Edison is pursuing implementation of its ALARA Program. The preplanning of specific work, in addition to the y,-
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Page 20 review of, and response to, exposure trends is part of CECO's program. The use of task-based goals is viewed by CECO to be an effective tool in reducing radiation exposure. Additionally, CECO is planning a new radwaste system and is evaluating decontamina-tion of the primary system.
Once these efforts are complete, INPO's recommendation of a 5 rem annual individual exposure goal will be achievable. This item is an ongoing CECO program and will be implemented at Quad Cities in accordance with the goals of CECO's corporate office.
Finding The general employee training program contained insufficient (RC.4-2)
Information on radiation exposure reduction techniques.
Addi-tionally, the training program for radioactive waste operators includes little ALARA information.
Recommendation Include specific techniques for reducing radiation exposure in the general employee training program.
Include specific radiation exposure precautions and reduction methods associated with radio-active waste operations and handling in the radioactive waste operator training program.
Response
The Station ALARA Coordinator will review the NGET program and radwaste operations. Based upon these reviews, the ALARA Coordinator will generate changes to the NGET and operations training programs to address specific techniques, precautions, and exposure reduction methods. These actions will be completed by January 1,1982.
Finding The plant's use of film badge measurements for legal exposure (R C.4-3) records complicates control of personnel exposures during outages because of the delay involved in obtaining results. During outages when personnel receive exposures approaching limits, a more timely method for accurately determining exposures is needed.
The plant is using pocket dosimeters to obtain a second check against film badges. Records show this information is inconsistent and cannot be relied upon for adequate control during the period necessary for badge processing.
Recommendation Replace the film badge system with a thermoluminescent dosi-metry system to provide a more timely method of determining exposures.
l QUAD CITIES (1981)
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Response
Commonwealth Edison Company is evaluating the replacement of the film badge system with a thermoluminescent dosimetry system in response to recommendations by the NRC and by American Nuclear Insurers, as well as by INPC.
SOLID RADIOACTIVE WASTE PERFORM ANCE OBJECTIVE: Minimize solid radioactive waste volumu Finding The amount of solid radioactive waste generated needs to be (RC.7-1) reduced.
Recommendation Establish methods to segregate radioactive from nonradioactive material in controlled areas and to minimize the amount of material taken into contaminated control areas. Emphasize waste reduction methods in training programs.
Response
Commonwealth Edison concurs with the INPO recommendation.
The Quad Cities Station volume reduction program will be revised to include segregation of waste material in controlled areas, minimizing material brought into controlled areas, and investiga-tions of solid waste sources. Maximum employment of reuscable containers and materials will be emphasized. The NGET program will be updated to include volume reduction techniques employed by Quad Cities. The station anticipates having these changes in effective operation by April 1,1982.
TRANSPORTATION OF RADIOACTIVE MATERIAL PERFORMANCE OBJECTIVE: Meet the requirements for transportation of radioactive material.
Finding Radioactive contamination measurements for radioactive mcterial (RC.8-1) shipments need to be improved. Techniques used did not determine specific contamination levels.
Recommendation Provide instructions to technicians performing smear surveys for all shipments. Measurements should be taken in crevices that are difficult to decontaminate. Provide instructions to technicians to assist them in determining the minimum detectable activity of instruments. This will enable technicians to ensure that instru-ments of adequate sensitivity are used for surveys.
QUAD CITIES (1981)
Page 22
Response
Significant changc= to station radioactive contamination measure-nent techniques nave been made.
A planchet-source holder arrange.nent will be employed to ensure a standard counting geometry. The analysis will be conducted using shielded, thi.4-window GM tuoes. Predesignated smear survey locations will be specified and required for all departure surveys to ensure that areas difficult to decontaminate are investigated. All necessary equipment has been purchased. The training of all technicians and the implementation of the revised techniques is expected by April 1,1982.
RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Minimize contaminated equipment and areas in the plant and minimize personnel contamination.
Finding Personnel monitoring for in-plant radioactive contamination is not (RC.9-1) always adequate to ensure detection of low levels of contamina-tion. Sensitive portable beta detectors are needed for monitoring personnel exiting contaminated areas. In the areas where sensitive detectors are currently used, only hand and foot monitoring is performed.
Recommendation Initiate the use of more sensitive instruments for monitoring personnel for radioactive contamination at controlled area exits.
Where practicable, establish monitoring stations at the exits from contaminated areas within controlled areas to minimize spread of contamination.
Response
All aluminum-walled GM probes employed in personnel contamina-tion surveys have been replaced with thin-window beta sensitive probes. The sensitivity of the liquid scintillator portal monitors in use at primary control points is significantly better than the GM l
tube portal monitors previously employed at the station. Liquid i
scintillator foot monitors have been purchased and upon delivery, l
will be employed on these units. A thin-window GM tube hand and l
foot monitor and two additional liquid scintillator portal monitors will be added to CECO's surveillance program this year. Where practicable, thin-window beta sensitive GM tube survey instru-ments will be used at work area access points within the controlled j
area. These items should be completed by January 1,1982.
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Page 23 Finding The number of areas in the plant requiring protective clothing (RC.9-2) needs to be reduced. Several areas require resi;iratory equipment because of high levels of loose surface contamination. Areas such as the reactor building equipment rooms, turbine building pump vaults, and radioactive waste processing facilities require respi-rators for entry. The requirement for respiratory equipment in-creases the difficulty of performing operational duties in these areas.
Recommendation Establish a program to eliminate or minimize the source of radioactive contamination in these areas and decontaminate the areas to levels where respiratory requirements are minimized.
Response
The Rad-Chem Department will compile a quarterly summary of the status of plant radioactive contamination. This item will be tracked by the Rad-Chem / Technical Support surveillance program schedule. Process changes, engineering controls, and decontamina-tion efforts will be reviewed in the report, with subsequent actions based upon past progress. Copies of the report will be supplied to the Station Superintendent and Assistant Superintendents for re-view, comment, and action. Procedures will be revised to provide action levels recommending decontamination, based upon contami-nation levels, radiation exposure rates, and occupancy.
These actions will be implemented by April 1,1982.
Finding Several situatiorts were observed where radiological protpction (RC.9-3) practices invo;ving the prohibition of chewing, eating, and smoking were not being observed.
Recommendation Emphasize adherence to good radiological protection practices by existing methods such as department meetings, training programs, and posted instructions.
Response
The station agrees that adherence to the Radiation Control Stan-dards is essential in providing effective radiation protection. This policy will be stressed through normal station communication channels. The posting of instructions and requirements will be upgraded. These actions will be completed by January 1,1982.
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QlfAD CITIES (1981)
Page 24 Finding Workers are not always provided adequate precautionary gaidance (RC.9-4) at the entrances to contaminated areas.
Recommendation Evaluate various methods of providing guidance for entry into contaminated areas, and implement a method which -vill provide consistent information for all radiation workers.
Response
CECO believes personnel should be required to obtain protective clothing requirements from Rad Protection prior to entry into contaminated areas. Through station department meetings, it will be stressed to all plant personnel that consultation with radiation protection supervisors prior to entry into contaminated areas is a valuable and essential part of proper job planning. These actions will be implemented by January 1,1982.
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QUAD CITIES (1981)
Page 35 TECHNICAL SUPPORT PLANT EFFICIENCY AND RELIABILITY PERFORMANCE OBJECTIVE: Optimize plant thermal efficiency and reliability.
Finding The thermal efficiency and reliability of the plant has not been (TS.2-1) optimized.
Recommendation Remote monitoring and/or calculation of such items as feedwater heater terminal difference, turbine shaft seal leakoffs, turbine extraction line pressure drops, turbine stage pressure drops, and valve leakage to low pressure portions of systems should be routinely evaluated to determine the effect of each on unit efficiency and reliability.
Evaluation results could be used for ALARA and predictive / preventive maintenance considerations. An engineering analysis should be made to determine those items that are cost effective or worthy of being done for other reasons. This engineering analysis should be the basis for determining additional items that should be part of a program to optimize plant thermal efficiency and reliability.
Response
An engineering analysis will be performed by the station to determine what additional process parameters are cost effective to augment the existing thermal efficiency monitoring program.
These parameters will be fed to the station's new process compu-ter, when installed, because the existing process computer does not have sufficient spare inputs.
The new process computers are scheduled for installation by September 1982. The engineering analysis will be completed by that time.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM PERFORM ANCE OBJECTIVE: Ensure industry-wide and in-house operating experiences i
are evaluated and appropriate actions are taken to improve personnel awareness and equipment reliability.
(
Finding Some recommendations included in INPO Significant Operating l
(TS.3-1)
Experience Reports (SOERs) have not been completed.
SOER recommendation status for 80-1 through 80-6 and 81-1 through 81-11 is as follows:
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QUAD CITIES (1981)
Page 26 Recommendations Action Taken 21 Satisfactory 1
Not applicable 33 Pending The recommendations pending action are as follows:
SOER No.
Recommendation No.
81-1 1, 2 81-2 1 through 6 81-3 1,2,3 81-4 1,2,3,4 81-5 1-1, 1-2, 1-3, 1-4 81-6 1, l a, 2 81-7 1, 2 81-8 1,2,3,4 81-9 1,2a,2b,2c 81-10 1
Recommendation Establish a method to ensure that SOERs are processed in a timely manner. Describe the action taken or planned with regard to each pending recommendation in response to this report.
Response
SOERs received at corporate headquarters will be reviewed by the Office of Nuclear Safety for applicability to company stations.
The Operating Experience Assessment Report (OEAR) form I has been revised to ensure a timely documented review of the SOERs and action will be taken. The 1981 SOER review will be completed by January 1,1982. The status of the recommendations listed above will be provided in our follow on respomes six months from the date of this report.
Finding An independent review of the SOER program is needed to ensure (TS.3-2) that the proper classification of each SOE11 is minde. The SOERs that are classified as not applicable do not receive a second review.
Recommendation Provide an indepenc'ent check on a random be. sis to verify that industry experiencer are being properly classified as to applicabili-ty. The review sW;uld be done by experienced technical personnel.
Response
An independ'.nt review of SOERs has been established to ensure proper cle',sification of applicability to each plant. In addition, when ttc or.-site Safety Engineering Group is established at each site, 's!i SOERs will be provided to the group for training and for crew,-checking on applicability.
QUAD CITIES (1981)
Page 27 PLANT MODIFICATIONS PERFORMANCE OBJECTIVE: Provide a program to implement plant modifications in a timely manner while maintaining the quality of plant systems and components.
Finding Drawings are not revised and issued in a timely manner following (TS.4-1) completion of modifications. Drawings for a number of modifi-cations have required one year or more for revision. As a result, some drawings have been affected by more than one modification, making it difficult to determine the "as-built" status of the plant.
Recommendation Drawings for implemented modifications should be revised and issued in a more timely manner.
Response
The present drawing change request system adequately reflects the current status of each affected drawing.
However, in order to minimize the number of drawings which have multiple requests submitted, the Station Nuclear Engineering Department has for-mulated a goal for IS81 to close out all requests originated prior to and including 1980. A monthly report is presently being generated by the Station Nuclear Engineering Department and sent to the Station Superintendent indicating the status of outstanding drawing change requests. The station will monitor the progress of reducing the backlog of requests by reviewing this report.
Finding Some modification requests are not adequately tracked to ensure (TS.4-2) timely design, review, and implementation. The status of a number of the modifications cannot be readily determined.
This has resulted in implemented modifications that are not closed out in a timely manner.
Recommendation A method should be developed to ensure that the status of each modification is accurately known and that adequate time is avail-able to accomplish each phase of the modification process. Imple-mented modifications should be closed out in a timely manner.
Response
The method used to determine the status of a modification will be reviewed and revised, as needed, to accurately indicate the proper status of each modification. The weekly modification status report will be revised to provide more detailed information on installed modifications which have not been closed out to assist in their ecmpletion in a timely manner. These actions will be completed by November 1,1981.
QUAD CITIES (1981)
Page 28 Finding Operator training and procedure updating for modified systems is (TS.4-3) not always completed prior to the modified system being returned to service. The modification program does not have a mechanism to ensure that these items are completed prior to returning a modified system to service.
Recommendation The present program should be revised to ensure that appropriate training and procedure revisions have been completed before placing a modified system in service.
Consideration should be given to the preparation of a more detailed operational description or summary for each modification to aid operations personnel.
Response
The station will review each modification and require appropriate licensed operator training and procedures to t'e ecmpleted pri 4 to operation. More detailed operational descriptions and summaries for modifications to aid in training of operations personnel will be arepared. These actions will be implemented by November 1,1981.
Finding Some non-safety-related modifications that are designed on-site do (TS.4-4) not receive a formal, technical, interdisciplinary review and ap-proval prior to the implementation of the design change. This does not ensure the same quality of review and approval that the original plant design received. The station does not have all of the engineering disciplines necessary to ensure that the originsi quality of review and approval is performed for each non-safety-related design change prior to the design change being implemented in the plant.
Recommendation The modification program should be revised to ensure that each design change receives the same quality of review and approval that the original plant design received prior to the implementation of the design change. A method to provide a rapid review and approval for non-safety-related design changes prior to the imple-mentation in the plant could be developed.
Response
The review of non-safety-related modifications that are designed on-site will be expanded to include additional disciplines as deemed appropriate. In most cases, sufficient expertise will exist on-site to conduct this review; however, those modifications which need expertise beyond the on-site capability will be referred to the Station Nuclear Engineering Department for concurrence.
This action will t'e implemented by Novembcr 1,1981.
QUAL CITIES (1981)
Page 29 ON-SITE REACTOR ENGINEERING PERFORMAF7E OBJECTIVE: Optimize nuclear reactor operation without compro-mising design or safety limits and control nuclear fuel handling activities to ensure safety of personnel and equipment.
Finding The following Good Practice was noted: The training and qualifi-(TS.5-1) cation of the station nuclear engineers is considered excellent.
This program contains classroom training, practical on-the-job training, demonstration of knowledge of the procedures used by the nuclear engineers, and written examinations. A final oral exam-ination is given to e asure that each engineer is qualified as a nuclear engineer prior to assuming the duties and responsibilities of that position.
QUAD CITIES (1981)
Pago30 ORG ANIZATION AND ADMINISTRATION ORG ANIZATIONAL. STRUCTURE PERFORMANCE OBJECTIVE: Provide an organizational structure that supports effee-tive management of nuclear power plant operation.
Finding Written position descriptions do not exist for each plant super-(OA.2-1) visory and professiona:' staff position. The following are examples:
Radwas<e Foreman, Senior Operating Engineer, Engineering Assis-tant, A,sistant Storekeeper, and Staff Engineer.
Recommendation Develop written position descriptions for supervisory and profes-sional staff positions not already covered.
Response
Written position descriptions will be developed for those staff positions, supervisory and professional, where no descriptions cur-rently exist. These actions will be completed by November 1, 1981.
MANPOWER RESOURCES PERFORMANCE OBJECTIVE: Ensure that qualified individuals are available to fill all job positions supporting plant safety and reliability.
Finding Written qualification requirements are not defined for many plant (OA.3-1) positions.
Recommendation Prepare qualification requirements for professional staff, super-visory positions, and appropriate positions below first-line supervi-sors. INPO is coordinating an industrywide job analysis project for certain operator, maintenance, and technician positions. In light of this effort. Commonwealth Edisca may wish to utilize the results of INPO's work in defining qualification requirements for applica-ble Quad Cities positions.
Response
Written qualification requirements will be defined for supervisory personnel, professional staff, and appropriate positions below first-line supervisors, for which written qualifications do not currently exist. These actions will be completed by November 1,1981.
QUAD CITIES (1981)
APPENDIX Pcge1 APPENDIX A 1.
Perfermance Objectives 1% viewed TRAINING AND QUALIFICATION TQ.1 Training Organization Provide a clearly defined training organization staffed with quali-fied personnel capable of accomplishing all assigned training tasks.
TQ.2 Training Administration Ensure that activities necessary to initiate and control personnel
' qualification programs are accomplished in a welldefined, coordi-nated, and effective manner.
TQ.3 Training Facilities and Equipment Provide the training facilities, equipment, and materials for devel-opment and evaluation of knowledge and skills needed by nuclear plant personnel.
TQ.4 Non-Licensed Operator Training Develop and maintain the skills and knowledge necessary for non-licensed operators to perform their assigned job functions.
TQ.5 Licensed Operator Training Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.
TQ.6 Licensed Operator Requalification Training Maintain the skills and knowledge necessary for licensed operators to perform their assigned job functions.
TQ.7 Shift Technical Advlsor Training Develop and maintain the skills and knowledge necessary for Shift Technical Advisors (STA) to perform their assigned job functions.
TQ.8 Maintenance Personne' Training Develop and maintain the skills and knowledge necessary for main-tenance personnel to perform their assigned job functions.
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QUAD CITIES (1981)
APPENDIX Page 2 OPERATIONS OP.1 Operations Organization and Administration Provide a clearly defined operations organization that is ade-quately staffed, assigns responsibilities, and delegates adequate authority for the accomplishment of required tasks.
O P.2 Operations Facilities and Equipment Provide plant facilities and equipment that are operated and raain-tained at a level to support safe and efficient operation.
O P.3 Conduct of Shift Operations Ensure that shift operations are conducted in a safe and reliable manner.
OP.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of written procedures.
OP.5 Plant Status Controls Maintain plant status in a condition that ensures equipment and system availability as necessary for safe and reliable plant opera-tions at all times.
O P.6 Shift Turnover Ensure a continuous and correct understanding of plant conditions at all shift operating positions through proper shift turnover.
O P.7 Tagout Practices Protect personnel and plant equipment by implementing effective tagout practices.
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MAINTENANCE I
M A.1 Maintenance Organization and Administration Provide a clearly defined maintenance organization that is ade-quately staffed, assigns responsibilities, and delegates adequate authority for the accomplishment of required tasks.
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APPENDIX Page 3 M A.2 Maintenance Facilities and Equipment Support the performance of maintenance activities by providing adequate facilities and equipment.
M A.3 Work Control System Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently dispositioned and documented.
M A.4 Maintenance Procedures Ensure that adequate plant maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of maintenance activities.
MA.5 Maintenance History Provide a complete and functional maintenance history supporting an evaluation pr.)giam which contributes to improvements in equip-ment performance.
M A.6 Preventive Maintenance (PM)
Optimize equipment reliability and performance to enhance plant safety and availability.
M A.7 Control of Measurement and Test Equipment (M&TE)
Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.
MA.8 Control of Special Processes Ensure that the control and performance of special processes yields quality results.
RADIATION PROTECTION AND CHEMISTRY RC.1 Management of Radiological Protection Provide effective management of the radiological protection pro-gram.
RC.2 Radiological, Protection Training Ensure that personnel on the ite have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.
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QUAD CITIES (1981)
APPENDIX Page 4
- R C.3 Personnel Dosimetry Accurately determine and record radiation exposures.
RC.4 External Radiation Exposure Minimize personnel external radiation exposure.
RC.5 Internal Radiation Exposure Minimize internal exposure due to radioactivity associated with the plant.
R C.6 Radioactive Effluents Minimize releases of radioactive effluents to the environment.
RC.7 Solid Radioactive Waste Minimize solid radioactive waste volumes.
RC.8 Transportation of Radioactive Material Meet the regsirements for transportation of radioactive material.
R C.9 Radioactive Contamination Control Minimize contaminated equipment and areas in the plant and minimize personnel contamination.
RC.10 Chemistry Ensure accurate measurement and effective control of chemistry -
parameters.
TECHNICAL SUPPORT TS.1 On-site Technical Support Organization and Administration Have a clearly defined on-site technical support organization that is adequately staffed, assigns responsibility, and delegates ade-quate authority for the accomplishment of required tasks.
TS.2 Plant Efficiency and Reliability Optimize plant thermal efficiency and reliability.
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's APPENDIX Page 5 TS.3 Nuclear Operating Experience Evaluation Program Ensure industrywide and in-house operating experiences are eval-usted and appropriate actions are taken to improve personnel awareness and equipment reliability.
TS.4 Plant Modifications Provide a program to implement plant modifications in a timely manner while maintaining the quality of plant systems and compo-nents.
TS.5 On-site Reactor Engineering Optimize nuclear reactor operations without compromising design or safety limits and control nuclear fuel handling activities to ensure safety of personnel and equipment.
ORGANIZATION AND ADMINISTRATION OA.1 Organizational Objectives Establish mission, goals, and cbjectives for the organizational units that improve plant activities or maintain the.m at high levels of safety and reliability, and establish the process to achieve the mission, goals, and objectives.
OA.2 Organizational Structure Provide an organizational structure that supports the effective management of nuclear power plant operation.
OA.3 Manpower Resources Ensure that qualified individuals are available to fill all, '
positions supporting plant safety and reliability.
O A.4 Administrative Controls Provide well-defined, organized, and effective administrative con-trol to direct the tasks, responsibilities, and practices within the organization to meet the specified mission, goals, and objectives.
OA.5 Management Quality Programs Provide management with accurate indication of the extent of adherence to policies, administrative controls, codes, regulations, and effectiveness in meeting plant mission, goals, and objectives.
r, QUAD CITIES (1981)
APPENDIX Page 6 OA.6 Surveillance Program Provide surveillance programs to accomplish coordinated moni-toring, inspection, and testing to ensure safe, reliable operation of plant equipment and facilities.
OA.7 Industrial Safety Provide an orderly working environment in which station personnel may carry out their work activities safely.
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