ML20038B725

Evaluation Rept,Oct,1981.

ML20038B725
Person / Time
Site:	Cooper
Issue date:	10/31/1981
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
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ML20038B705	List: ML20038B704 ML20038B725
References
NUDOCS 8112090049
Download: ML20038B725 (32)

Text

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COOPER (1981)

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SUMMARY

INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of the Nebraska Public Power District's (NPPD) Cooper Nuclear Power Station (CNS) during the weeks of August 10 and 17,1981. Cooper uses a 778 MW Net General Electric boiling water reactor. The site is located on the Missouri River, approximately 23 miles south of Nebraska City, Nebraska. The unit began commercial operation in July 1974.

PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of station documents.

The INPO evaluation team examined station organization and administration, 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 station evaluation. As a basis for the evaluation, INPO used performance objectives and criteria relevant to each of the six areas examined; these were applied and evaluated in light of both the experience of team members and INPO's observations of good practices within the industry.

.I 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 I 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 excellent physical condition and is being operated in a safe manner by qualified personnel.

Certain beneficial practices and accomplishments were noted:

1 Cooper has becn an industry leader in miniriizing accumulated personnel radiation

exposure.

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! The physical condition and cleanliness of the station are excellent.

Very few control room control panel alarms were activated.

l The station has an impressive safety record, with no lost time accidents in over two years.

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g COOPER (1981) g Page 2 Station management exercises positive management controls throughent all levels.

A positive commitment to maintaining fuel clad integrity combined with fixing system leaks i.nmediately has resulted in minimidng contamination and radiation levels throughout the station.

Improvements were recommended in a number of areas. The following are considered I to be among the most important:

The need to fill the seven technical vacancies in the 22-man Engineering Department.

The need to thoroughly implement station training programs in order to improve the overall effectiveness of the training effort.

In each of the six areas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of this evaluation are listed in APPENDIX A.

Fmdings and recommendations are listed under the PERFORMANCE OBJECTIVES to which they pertain. Particularly noteworthy conditions which contribute to meeting PERFORMANCE OBJECTIVES are identified as Good Practices. Other findings describe conditions which detract from meeting the PERFORMANCE OBJECTIVES. 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 NPPD or to INPO's other member utilities. As a result, most of the findings highlight condi.i ns o that need improvement.

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 I recommendations the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.

The findings listed herein were presented to Nebraska Public Power District manage-I ment at an exit meeting at the plant on August 20,1981. Findings, recommendations, and responses were reviewed with Nebraska Public Power District management on October 1,1981. Nebraska Public Power District responses are considered satisfactory.

To follow the time'y completion of the improvements included in the responses, INPO requests written notification of status six months from the date of this report.

The evaluation staff appreciates the excellent cooperation received from the personnel of the Nebraska Public Power District.

E. P. Wilkinson President l

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COOPER (1981)

Page 3 NEBRASKA PUBLIC POWER DISTRICT Response Summary Nebraska Public Power District is pleased to have had INPO perform an evaluation of our Cooper Nuclear Station. We agree that the findings will serve to improve the management of operation of the station, and the District will strive toward timely implementation of the improvements recommended. Each of the findings has been responded to in as much detail as possible at this time.

I The District was aware of many of the recommendations which were identified, but INPO's focus confirms and stimulates efforts toward improvement. The District has benefited from all of the INPO discussions leading up to these findings, and is especially l

I pleased by the INPO recognition of a number of " Good Practices" at Cooper Nuclear Station.

We are concerned about the technical manpower shortage that exists in the industry and the challenge facing the District to recruit and maintain an adequate technical staff.

To this end we are actively evaluating all of the different approaches to this problem which may be available to the District. INPO is urged to continue its efforts to assist the industry in achieving a practical and reasonable solution to this problem.

Targeted completion dates for specific items have been noted in the details section where possible. A written status report will be provided to INPO six months from the I date of this report. INPO is invited to assess the effectiveness of our actions as they are implemented.

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'I COOPER (1981)

Page 4 TRAINING AND QUALIFICATION TRAINING ORGANIZATION PERFORMANCE OBJECTIVE: Provide a clearly defined training organization staffed with qualified personnel capable of accomplishing all assigned training tasks.

Fir. ding "% training staff is not of sufficient size to fully meet ali usigned (TQ.1-1) . ynsibilities.

Recommendation Examine the training programs which station personnel are respon-sible for conducting to determine the total manpower necessary to perform all required training activities (including program and I material development and upgrading, instructor preparation, and instructor professional development). Establish full-time, perma-nent positions to accomplish these activities and fill these positions with appropriately qualified it dividuals.

Response The training programs that must be carried out will be examined to determine necessary training staff requirements. Appropriately qualified personnel will then be assigned from each department to conduct these training programs. This objective will be accom-plished prior to September 1,1982. The need for adding personnel to the training staff for activities such as instructor preparation and instructor professional development will be considered.

I 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.

I Finding (TQ.4-1)

The station operator (non-licensed) initial qualification program nee & improvement. The on-the-job training station operators now receive is unstructured and not fully implemented.

Recommendation Develop a structured on-the-job training phase as part of the I qualification program for station operators. The program should identify job functions to be performed, observed, or discussed during this training phase. Classroom training in power plant I fundamentals should also be included in the initial training program for station operators.

I COOPER (1981)

Page 5 Response The station operator initial qualification program will be fully established by July 1,1982. The on-the-job training will be structured as recommended.

LICENSED OPERATOR TRAINING PERFORMANCE OBJECTIVE: Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.

Finding The licensed operator training program should include a structured (TQ.5-1) program for training senior reactor operator (SRO) trainees. The program does not identify job functions and technical information I to be covered during on-the-job or classroom training. Trainee participation in selected plant evolutions and review of selected procedures is not required.

Recommendation Develop structured en-the-job and classroom training phases as part of the qualificction program for SROs. The program should identify job functions to be puformed, observed, or discussed, and I should include coverage of technical, administrative, and super-visory skills and knowledge required of the SRO. An INPO doau-ment titled " Guidelines for Qualification Programs at Operational Un:ts" (INPO #GPG-03) provides guidance in this area.

Response INPO document # G PG-03 will be reviewed to determine the modifications required in the training program for senior reactor operators by March 1, 1982. Identified modifications will be completed by July 1,1982.

i LICENSED OPERATOR REQUALIFICATION TRAINING j PERFORMANCE OBJECTIVE: Maintain the skills and knowledge necessary for licensed

! operators to perform their assigned job functions.

lI Finding (TQ.6-1)

The recommendations of the training staff's evaluation of the licensed operator requalification program are not always imple-mented.

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I I COOPER (1981)

Page 6 Recommendation Implemeat the recommendations of the training staff's evaluation of the licensed operator requalification program. Also develop a management review system to ensure that future recommendations are reviewed by station personnel.

Response Increased emphasis will be placed on the requalification program to ensure that necessary training is conducted. A management review

,. system will be established such that the Operations Supervisor and the Station Superintendent are aware of the status of the requalifi-cuion program, the training staff's recommendations, and any deficiencies, so that corrective action can be taken.

I SilIFT TECIINICAL ADVISOR TRAINING I PERFORMANCE OBJECTIVE: Develop and maintain the skills and knowledge neces-sary for Shift Technical Advisors (STA) to perform their assigned job functions.

Finding The STA training program should be expended tc include training in (TQ.7-1) several technical areas not currently covered.

Recommendation Expand the scope of the STA training program. The INPO

, document #GPG-01, " Recommendations for Position Description, Qualifications, Education and Training," provides guidance in this area.

Response The current STA program and INPO document #GPG-01 will be reviewed and the program expanded to include identified areas by July 1,1982.

Finding STA retraining requirements are needed.

(TQ.7-2)

Recommendation Establish an STA retraining program. The INPO document titled

" Recommendations for Position Description, Qualifications, Educa-I tion and Training" (INPO #GPG-01) provides guidance in this area.

Response An STA retraining program will be established prior to March 1, 1982.

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I COOPER (1981)

Page 7 MAINTENANCE PERSONNEL TRAINING J

PERFORMANCE OBJECTIVE: Develcp and maintain the skills and knowledge neces-l sary for maintenance personnel to perform their assigned job functions. l l

Finding The instrumentation and control, electrical, and mechanical main-(TQ.8-1) tenance personnel initial training programs should include plant I systems training. The training section has not developed plant systems training material for the maintenance personnel trainees.

I Recommendation Develop systems training material and establish a systems training program to familiarize maintenance personnel with plant systems as a part of their qualification program.

Response Systems training will be incorporat ed as a part of the maintenance personnel training program. It is planned to have this completed by September 1,1982.

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il COOPER (1981)

Page 8 OPERATIONS CONDUCT OF SIIIFT OPERATIONS PERFORMANCE OBJECTIVE: Ensure that shift operations are conducted in a safe and reliable manner.

1 Finding The following Goed Practice was noted: The number of annun-g (OP.3-1) ciators in the alarmed condition on the control room front panels l3 has been significantly reduced through a joint effort of operators and plant engineering personnel to determine and correct the cause lg of the alarmed condition.

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l Finding The following Good Practice was noted: An effective method is (OP.3-3) med to identify aNormal conditions or parameters requiring spe-cial attention. Red arrows affixed to magnetic white plastic plates are med on the control boards to alert operators to ongoing activities or conditions that are not normal during routine oper-ations.

PLANT OPERATIONS PROCEDURES PERFORMANCE OBJECTIVE: Provide timely, effective guidance to operators in the form of written procedures.

Finding Emergency and abnormal procedures are not uniquely identified.

(OP.4-1) The color of the binders for emergency and abnormal procedures is I identical to other binders. The first volume of procedures contains the only index for the procedures. In addition, insufficient tabbing is used to separate individual procedures.

I Recommendation Provide a more effective means for assisting operators in the timely identification of emergency and abnormal procedures.

Response The control room emergency and abnormal procedures have now been placed in red binders. An index is also now placed in the front of each book.

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COOPER (1981)

Page 9 Finding The emergency procedure that provides for shutdown from outside (O P.4-2) the control room omits some important steps that should be taken l'

before the operator is directed to leave the control room.

Recommendation Review the current procedure and include, as a minimum, steps that direct the operator to scram the reactor, chen all rods in, and ensure that the turbine is tripped before exiting the control room.

.I j Response The Emergency Procedure 5.2.1 is being revised to include steps i directing the operators to, if possible, scram the reactor, check all rods in, and ensure the turbine is tripped before exiting the control room.

I 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 Formal controls for the use of caution tags are needed. Caution (O P.5- 1) tags are considered as an "information only" card and are placed on equipment by operations and maintenance personnel on an informal basis to identify unique conditions or abnormal situations. Caution tngs bear no identification number for documer.tation, and no I formal audit is required or periodic assessment made of their continued need.

Recommens ation Provide necessary instructions for the use and control of caution I t a gs. Include requirements for periodic review of tags in tne to ensure their validity.

I Response The use nnd control of caution tags will be reviewed. Necessary instructions for the use and control of these tags will be provided and will include periodic review of tags in use for validity. This action will be completed by January 1,1982.

Finding Controlled drawings and drawings listed "for information only" are (O P.5-2) mixed on the same print holder. These drawings are used for clearance tagging and other control room information as required.

Placing both types of drawings on the same print holder could result in the use of prints which differ from the as-built system.

I COOPER (1981)

Page 10 Recommendation .r:termine why "for information only" and controlled drawings are I catained on the same print holder in the coritrol room and take

& ~ ctive measures to prevent recurrence.

I Response The Records Administration Department (RAD) personnel had incorrectly stamped these drawings marked "For Information Only" and sent them directly to the control room in response to a request. The methods of handling drawings have been revised so I that R AD sends requested drawings to the CNS Engineering De-partment and that department checks and distributes them.

I Finding Uncontrolled notts, graphs, portions of procedures, labels, and (O P.5-3) drawings of a temporary nature used as operator aids are attached to the unit control board panels. A method is needed for approving, updating, or verifying these temporary messages.

Recommendation Evaluate the need for tnis material and remove material net considered necessary. Develop a system to control the use of approved and dated notes, graphs, and drawings and periodically review these documents for removal or retention.

Response The control room panels have been examined to ensure that materitil attached to the panels is necessary, valid, and current.

An adrainistrative procedure will t e preoared to control such material including periodic review of the material on the panels.

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PERFORMANCE OBJECTIVE: Ensure a continuous and correct understanding of plant conditions at all shif t operating positions through proper shift turnover.

Finding Shift turnover procedures are needed for control room and station (OP.6-1) operators. Operators use a variety of informal methods to discuss equipment status during shif t change including logs, rounds sheets, random notes, and memory. The informality of shift turnover could result in inadequate irlormation exchange on equipment status.

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I I COOPER (1981)

Page 11 Recommendation Develop shif t turnover procedures for each watch station. Instruct all operators in the proper use of turnover procedures and period-ically assess the effectiveness of the turnover procedures. The turnover procedures should include a checklist for each operating shif t station to guide the turnover process.

Response The shift turnover procedures for each watch station will be reviewed and modifications made to incorporate the above recom-mendation as necessary. This action will be completed by January 1,1982.

I I TAGOUT PRACTICES PERFORMANCE OBJECTIVE: Protect personnel and equipment by implementing ef-fcctive tagout practices.

Finding A periodic review and audit of tagouts should be conducted.

(OP.7-1) Although shift supervisors are required by their shift turnover checklist to review the clearance log, this review does not suffice I as an audit of tagouts.

Recommendation Develop and implement a program for periodic review of the status of tagouts. Instruct supervisory personnel in its implementation.

The program should include performance checks, as follows, on a periodic basis:

o Conduct review of the tag index.

o Verify the adequacy of tagouts.

o Check the condition of posted tags, o Verify proper attachment of tags and position of tagged equipm ent.

o Check for presence of unauthorized tags, o Check for tagouts remaining in effect beyond their need.

Response The Quality Assurance Department currently performs a " systems operational status" audit as a part of QAP-200. A section of this audit is dedicated to clearance orders (tagouts). This audit procedure will be reviewed and modified as required to include the above performance checks.

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COOPER (1981)

Page 12 Finding The size of clearance tags is too large for control board use. Tags

(O P.7-2) are of a size that can obscure labels, indicating lights, and control switch positions. As an example, a hold tag on a battery room exhaust fan obscures two sets of indicating lights and one switch handle.

Recommendation Correct current conditics where tags are obscuring lights and

switches. Investigate the use of smaller tags which will not obscure control board lights or switches.

Response An investigation of small tag use on control boards is being lE conducted. until these smalier tags are available, tags wiii be E rolled to prevent obscuring other pertinent components on control boards.

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Page 13 MAINTENANCE WORK CONTROL. SYSTEM PERFORMANCE OBJECTIVE: Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently dispo-sitioned and documented.

Finding The following Good Practice was noted: Computer terminals with (M A.3-1) CRT displays, located in the instrument and control, electrical and mechanical shops, provide local access to component data, parts l information, maintenance history, and preventive and corrective maintenance. This practice makes valuable information readily available to key people and climinates time-consuming drawing and l file searches.

.I Finding The following Good Practice was noted: Management's aggressive (M A.3-2) approach to correcting all material problems as soon as practicable has led to a minimum number of outstanding maintenance items and an overall execlient material condition of the station.

i M AINTENANCE PROCEDURES PERFORMANCE OBJECTIVE: Ensure that adequate station maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of maintenance activities.

Finding The test equipment section of Maintenance and Surveillance Proce-I (M A.4-1) dures does not always include the rarge of the test instrument to be used.

Recommendation Review Maintenance and Surveillance Procedures and, where appropriate, provide a more detailed description, including the range of the test equipment to be used.

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COOPER (1981)

Page 14 Response A more detailed description of test equipment will be added to the mairle:iance and surveillance procedures, where appropriate, dur-ing tne next scheduled review of these procedures. This review is now planned for completion by September 1,1982.

Finding Some maintenance procedures specified by the preventive mainte-(M A.4-2) nance printout need more effective management control of the work to be performed. In reviewing these procedures, the follow-ing items were noted:

o Vendor rm.nuals and some procedures prepared by mainte-nance peisonnel for essential equipment preventive main-tenance are not approved b, station management.

o Some of the referenced vendor manuals are not held by the shop assigned to perform the preventive maintent.nce-o Vendor manuals are referenced for the preventive main-tenance procedure when a more comprehensive station procedure exists.

Recommendation Review preventive maintenance procedures to ensure that they are properly approved, are the most appropriate procedures for the prescribed work, and are readily available to the workers.

Response The preventive maintenance procedures will be reviewed to ensure I they are appropriate for the work to be performed. The proper reference to vendor manuals will be checked and those referenced manuals will be made available to the shop performing the work.

Appropriate station management will then review and approve these procedures, it is expected that this activity will be com-pleted by September 1,1982.

M AINTEN ANCE IllSTORY PERFORMANCE OBJECTIVE: Provide a complete and functional maintenance history supportired an evaluation program which contributes to improvements in equipment performance.

Finding The maintenance history program should be described by an (M A.5-1) approved procedure or guideline. The station has recently changed l

COOPER (1981) -

Page 15 j from a handwritten maintenance history to a computerized system. l Key station personnel were not familiar with all aspects of the new system.

I Recommendation Issue an approved procedure that describes all aspects of the existing maintenance history program and provides training to ensure key personnel are familiar with its use.

Response A work item tracking / equipment history procedure will be devel-oped and approved by station management. This procedure will describe the maintenance history program. Appropriate training will then be performed such that necessary personnel are familiar with the system. The procedure is to be completed and approved by %1 arch 1,1982 and personnel trained by July 1,1982.

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Page 16 RADIATION PROTECTION AND CIIEMISTRY __

RADIOLOGICAIt PROTECTION TRAINING PERFORMANCE OBJECTIVE: Ensure that persor,al on the site have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

Finding Examinations are needed to verify the knowledge level and practi-(RC.2-1) cal ability of the following:

o radiological protection and chemistry technicians during initial qualification or subsequent retraining o personnel receiving general employee training I o reactor operators who receive radiological protection training for radiological protection coverage on back shifts.

Recommendation Develop written and practical examinations to evaluate the knowledge level and practical ability of radiological protection and chemistry technicians. Develop written examinations and practical exercises for general employee and reactor operator radiological protection training.

, Response The radiological protection training program will include written J

examinations and other techniques to evaluate knowledge level and practical ability and will be factored into the ongoing training program for radiological protection technicians, chemistry tech-

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nicians and reactor operators by April 1, 1982. Written examinations for general employee radiological protection training are now in use.

PERSONNEL DOSIMETRY PERFORMANCE OBJECTIVE: Accurately determine and record radiation exposures.

I Finding The station radiological protection staff has identified discrep-(RC.3-1) ancies in equipment used to monitor beta exposures.

Recommendation Identify the reasons for and the extent of discrepancies in the beta exposures indicated by different thermoluminescent dosimeters U

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COOPER (1981)

Page 17 (TLDs) and reasons for the low beta exposures on TLDs exposed at known radiation levels. Identify and implement a beta dosimetry system that provides consistent results.

Response Discussions are currently being c'onducted with the TLD vendar to resolve identified discrepancies and to develop a satisfactory technique for exposing TLDs to a known beta source. CNS will continue to evaluate the beta monitoring program and review any forthcoming advancements in beta monitoring research and changes in standard practices.

I EXTERNAL RADIATION EXPOSURE PERFORM ANCE OUJECTIVE: Minimize personnel external radiation exposure.

Finding The station has developed and used several good practices to (RC.4-1) maintain personnel exposures among the lowest in the industry.

Continuation of these good practices could be ensured by devel-oping a formal ALARA program for documenting good techniques and establishing, tracking, and evaluating exposure goals for individuals, specific jobs, and total cumulative exposures.

Recommendation Develop a formal AL ARA program to document good techniques; establish exposure goals for individuals, specific jobs, outages, and total yearly cumulative exposures; and track and evaluate actual exposures as compared with the goals.

Response A formal ALAR A program incorporating the above recommen-dation will be implemented by July 1,1982.

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l INTERNAL RADIATION EXPOSURE PERFORMANCE OILIECTIVE: Minimize internal exposure due to radioactivity associ-ated with the plant.

Finding Initial whole body counts to provide a base level should be

( R C.5-1) performed for new personnel who will be working in radiologically controlled areas.

Recommendation Utilize the whole body counting equipment to obtain a base level

! count for all new personnel who will be working in radiologically l controlled areas.

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g COOPER (1981) 5 Page 18 Response As of September 1,1981, the whole body counting equipment has been used to obtain an entry base level for incoming personnel who will be working in radiologically controlled areas.

Finding Whole body count recorch indicate a large number of personnel (RC.5-2) with low levels of Co-60 radioactivity. Although the levels are only a small part of the established limits, the large number of people involved indicates the need to improve contamination control or respiratory protection.

Recommendation Identify the reasons for indications of low levels of radioactivity from whole body counts. Take appropriate actions to reduce the indicated levels of radioactivity.

Response CNS is confident that the low levels, which are w ell below any prescribed action levels, are not a respiratory protection problem and that it may be related to protective clothing and laundry control. This problem is being evaluated and will be pursued to resolution.

RADIOACTIVE EFFLUENTS PERFORMANCE OBJECTIVE: Minimize releases of radioactive effluents to the en-vironment.

Finding The following Good Practice was noted: Radioactive effluent (RC.6-1) discharges have been reduced by processing the effluents to allow recovery and reuse.

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!I SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Minimize solid radioactive waste volumes.

Finding Although radioactive solid waste volumes are low, further redue-(RC.7-1) tion could be achieved by utilizing more effective compacting equipment and segregating clean from radioactive waste coming from radiologically controlled areas.

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I COOPER (1981)

Page 19 Recommendation Determine if the use of compacting discs can significantly increase I barrel weights through increased compaction. Implement proce-dures to segregate radioactive and clean trash.

Response CNS will procure and evaluate the compaction discs in an effort to increase the barrel weight, hence the amount of waste per con-tainer. In addition, procedures in use will be reviewed in an attempt to provide improved segregation of clean and radioactive trash.

RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Minimize contaminated equipment and areas in the station and minimize personnel contamination.

Finding Recorch of personnel skin contaminations should be kept.

(RC.9-1)

Recommendation Maintain records in personnel exposure files to identify skin contamination incidents. The use of such records facilitates the identification, and reduction or elimination, of the cause of re-peated contaminations.

Response Records of skin contamination are now being maintained in person-nel exposure files.

I Finding The following Good Practice was noted: Prompt repair of leaks (RC.9-2) and immediate decontamination have minimized contamination in the reactor building and allowed maximum personnel access without the use of prottetive clothing.

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I COOPER (1981)

Page 20 m TECIINIC AL SUPPORT m

- ON-SITE TECIINICAL SUPPORT ORGANIZATION AND ADMINISTRATION u PERFORMANCE OBJECTIVE: llave a clearly defined on-site technical support organi-zation that is adequately staffed, assigns responsibility, and delegates adequate

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authority for the accomplishment of required tasks.

Finding The on-site technical suppcrt staff is currently manned to 68 (TS.1-1) percent of the authorized m&aning level. This reduced manning prevents the staff from completing assigned work.

Recommendation Improve efforts to fill the vacant engineering staff positions.

Response Two of the vacant engineering positions have becn filled since the INPO evaluation. CNS plans to continue efforts to adequately I staff the on-site technical support organi7ation. CNS is concerned about the technical manpower shortage that exists in the industry and the challenge facing the District to recruit and maintain an I adequate technical staff. To this end the District is actively evaluating all of the different approaches to this problem which may be available.

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i Finding Training to enhance and develop skills and knowledge of the on-site (TS.1-2) technical support personnel needs improvement.

f Recommendation Evaluate the training needs of personnel within the Engineering I

1 Department and provide additional training as required. Consider the need for training in these areas:

I o plant systems and components o areas requiring specialized engineering knowledge or skills o effective management techniques.

Implement the training on a department level to ensure that uniform training is provided to all personnel in the station engi-I neering group.

Response The training needs of personnel in the Engineering Department have been evaluated. Engineers in the Engineering Department will receive plant systems training and will continue to be sent to special schools as required to obtain and maintain proficiency in certain areas.

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[ COOPER (1981)

Page 21 PLANT EFFICIENCY AND RELIABILITY PERFORMANCE OBJECTIVE: Optimize plant thermal efficiency and reliability.

Finding More management attention is needed in efforts to optimize plant

[ (TS.2-1) thermal efficiency. For example:

o Specific responsibilities and assignments for monitoring balance-of-plant thermal efficiency have not been made.

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o Computer programs available to help optimize the balance-of-plant thermal efficiency are not routinely E used.

- o The unit load is frequently cycled to meet system elec-trical demand.

Recommendation Supplement the existing efforts in plant performance monitoring by

[ implementing a more comprehensive program. Provide for the use of available computer programs, systematic evaluation of pertinent plant systems and components, and trending of key plant para-meters. Specify responsibility for implementing each portion of

[ the program.

A study should be made by corporate management to evaluate methods of improving the load factor for Cooper Nuclear Station

{ with the overall objective of improving the plant operating effi-ciene,,,

Response An engineer is currently being trained to fill the Performance Engineer position that has been vacant. Twelve rows of blades have been missing from the turbine low pressure rotors for over a

[ year. New rotors are currently being installed and additional attention will be given to plant thermal efficiency during the upcoming operating cycle. Corporate management and system dispatchers will continue efforts to improve the CNS load factor

{ while meeting the system load requirements.

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NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM PERFORMANCE OBJECTIVE: Ensure industrywide and in-house operating experiences

{ are evaluated and appropriete actions are taken to improve personnel awareness and equipment reliability.

[ Finding The review of in-house events should include a provision for prompt (TS.3-1) notification to other utilities, via NOTEPAD, of significant events h with possible generic implications.

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I I COOPER (1981)

Page 22 Recommendation Review the existing station policy regarding dissemination of information concerning significant events with possible generic implication. Use this review as the basis for revising station procedures to include placing information into the NOTEPAD system.

Response The existing station policy regarding dissemination of information concerning significant events with possible generic implications I will be reviewed and station procedures revised to include proce-dures for placing pertinent information of possible generic signifi-cance ir.to the NOTEPAD system.

I Finding Some recommendations included in INPO Significant Operating I (TS.3-2) Experience Reports (SOERs) have not been completed. SOER recommendation status for 80-1 through 80-6 and 81-1 through 81-13 is as follows:

Recommendations Action Taken I 24 26 27 Satisfactory Not applicable Pending The recommendations pending action are as follows:

SOER No. Recommendation No.

80-1 1, 2 81-2 1 through 6 81-9 1, 2(a), 2(b), & 2(c)

.I 81-13 1 through 15 Recommendation Establish a method to ensure that SOERs are processed in a timely manner. Provide information on the action tsken or planned with

.I regard to each pending SOER in the response to this report.

I Response The method used for review and action for GE SILs is now being used to ensure timely processing of SOERs. The review of SOERs 80-1, 81-2. and 81-9 has been completed and necessary actions completed or scheduled on these SOERs. CNS will complete a I review of SOER 81-13 prior to November 15,1981.

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Finding The following Good Practice was ncted: The method for review l (TS.3-3) and action for General Electric Service Information Letters (GE SILs) is execllent. Consideration should be given to imple-menting the same structured format for the review of Significant Event Reports and SOERs.

I 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 The following Good Practice was noted: Station design changes are I (TS.4-1) normally designed and installed under the responsibility of the same engineer. Station design changes that are designed by off-site engineers are installed by these same engineers under the control of station personnel and procedures.

I ON-SITE REACTOR ENGINEERING PERFORMANCE OBJECTIVE: Optimize nuclear reactor operations without compro-mising design or safety limits and cor. trol nuclear fuel handling activities to ensure safety of personnel and equipment.

Finding The following Good Practice was noted: Cooper Nuclear Station (TS.5-1) personnel have a strong commitment to maintain the highest achievable fuel integrity. This is evident in the on-site reactor engineering program and the outstanding fuel performance reced that has been achieved. The commitment has also paid dividends through lower than noNnal personnel radiation exposure over the years.

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Page 24 ORGANIZATION AND ADMINISTRATION ORGANIZATIONAL OBJECTIVES PERFORMANCE OBJECTIVE: Establish mission, goals, and objectives for the organi-zational units that improve station activities or maintain them M high levels of safety and reliability, and establish the process to achieve the mission, goals, and objectives.

.I Finding Specific goals and objectives should be defined for the station or (O A.1-1) any of its organizational units.

Recommendation Prepare and issue short-term and long-term goals and objectives I for the station. A method of reporting goal achievement should be developed to note program success and to implement personnel accountabilities.

Response Formal goals and objectives will be issued by September 1,1982.

MANAGEMENT QUALITY PROGRAMS PERFORMANCE OBJECTIVE: Provide management with accurate indication of the extent of adherence to policies, administrative corJrols, codes, regulations, and effectiveness in meeting station mission, goals, and obj<etives.

Finding The quality assuranec/ quality control programs (Q?fQC) should (O A.5-1) extend to important non-safety-designated balance-of-plant equip-

-I ment.

Recommendation Expand the QA/QC program to include important non-safety balance-of-plant equipment.

I E Resportse The QA/QC program will be modified to include important balance-of-plant equipment. This effort will be completed by I September 1,1982.

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I COOPER (1981)

Page 25 INDUSTRIAL SAFETY PERFORMANCE OBJECTIVE: Provide an orderly working environment in which station personnel may carry out their work activities safely.

I Finding Work practices and safety considerations peculiar to the station (OA.7-1) that affect industrial safety should be promulgated to 101 site personnel. The " Safety Rule Book" prepared by the Mbraska Public Power District and issued to each staticn employee is not site-specific. Site-specific information contained in "Recom-mended Work Practices" is not disseminated to each new employce.

Recommendation Prepare a sitespecife industrial safety manual and distribute il to I each station employee. Institute methods to ensure that workers on site are familiar with company industrial safety requirements.

a Response The " Safety Rule Book" will be reviewed as related to site specific

!g industrial safety practices. By September 1,1982, a method will be implemented to provide all employees with this information. In addition, CNS will increase efforts to ensure that workers on site are familiar with company industrial safety requirements and that l they follow these requirements.

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APPENDIX Page1 APPENDIX A I. Performance Objectives Reviewed TRAINING AND QUALIFICATION TQ.1 Training Organization Provide a clearly defined training organizction staffed with quali-fied personnel capable of accomplishing all ascigned training tasks.

TQ.2 Training Administration Ensure that activities necessary to initiate and control personnel I qualification programs are accomplished in a well-defined, coordi-nated, and effective manner.

TQ.3 Training Facilities and Equipment Provide the trainirg facilities, equipment, and mater'als for devel-opment and evaluation of knowledge and skills needed by nuclear plant personnel.

TQ.4 Non-Licensed Operator Training I Develop and maintain the skills and knowledge necessary for non-licensed operators to perform their assigned job functions.

TQ.5 Licensed Operator Training g Develop the skills and knowledge necessary for licensed operators

'g to perform their assigned job functions.

TQ.6 Licensed Operator Requalification Trainir.g Maintain the skills and knowledge necessary for licensed operators to perform their assigned job functions.

TQ.7 Shif t Technical Advisor Training Develop and maintain the skills and knowledge necessary for Shift Technical Advisors (STA) to perform their assigned job functions.

TQ.8 Maintenance Personnel Training Develop and maintain the skills and knowledge necessary for main-tenance personnel to perform their assigned job functions.

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APPENDIX Page 2 OPERATIONS O P.1 Operations Organization and Administration Provide a clearly defiled operations organization that is adequate-ly staffed, assigns responsibilities, and delegates adequate l authority for the accomplishment of required tasks.

O P.2 Operations Facilities and Equipment Provide plant facilities and equipment that are operated and main-tained at a level to support safe and efficient operation.

! OP.3 Conduct of Shift Operations l

, Ensure that shift operations are conducted in a safe and reliable l manner.

O P.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of wiitten procedures.

O P.5 Plant Status Controls Maintain plant status in a condition that ensures equipment and I '

system availability as necessary for safe and reliable plant opera-tions at all times.

OP.6 Shift Turnover Ensure a continuous and correct understanding of riant conditions at all shift operating positions through proper shift turnover.

I O P.7 Tagout Practices I Pro'ect personnel and equipment by implementing effective tagout practices.

MAINTENANCE M A.1 Maintenance Organization and Administratior.

Provide a clearly defined maintenance organization that is ade-I quately staffed, assigns responsibilities, and dclegates adequate authority for the accomplishment of required tasks.

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APPENDIX Page 3 MA.2 Maintenance Facilities and Equipment

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! Support the performance of maintenance activities by providing adequate facilities and equipment. ]

l l M A.3 Work Control System Provide an administrative control system within which equipment l l problems can be identified and reported, and safely and efficiently l dispositioned and documented.

M A.4 Maintenance Procedures Ensure that adequate station maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of maintenance activities.

MA.5 Maintenance IIistory Provide a complete and functional maintenance history supporting l

an evaluation program which contributes to improvements in equip-ment performance.

M A.6 Preventive Maintenance (PM)

Optimize equipment reliability and performance to enhance plant safcty and availability.

MA.7 Control of Measurement and Test Equipment (M&TE)

I Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.

MA.8 Contro' of Special Processes Ensure that the control and performance of special processes yields quality results.

I R ADIATION PROTECTION AND CIIEMISTRY 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 site have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

COOPER (1981)

I APPENDIX Page 4 RC.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 inte nal exposure due to radioactivity associated with the plant.

RC.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 requirements for transportation of radioactive material.

RC.9 Radioactive Contamination Control ll Minimize contaminated equipment and areas in the station and i5 minimize personnel contamination.

RC.10 Chemistry Ensure accurate measurement and effective control of chemistry parameters.

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I TECIINICAL SUPPORT TS.1 On-site Technical Support Organization and Administration llave a clearly defined on-site technical support organizution 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.

I COOPER (1981)

I APPENDIX Page5 TS.3 Nuclear Operatins ' >erience Evaluation Program Ensure industrywide End in-house operating experiences are eval-uated and appropriate actions are taken to improve personnel awareness anc' quipment 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 AhD ADMINISTRATION O A.1 Orgamzational Objectives Establish mission, goals, and objectives for the organizational units that improve station activities or maintain them at high levels of safety and reliability, and establish the process to achieve the

mission, goals, and objectives.

O A.2 Organizational Structure Provide an organizational structure that supports the effective management of nuclear power plant cperation.

OA.3 Manpower Resources Ensure that qualified individuals are availehle to fill all job positions supporting plant safety and reliability.

O A.4 Administrative Controls Provide well-defined, organized, and effective administrative con-trols 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 station mission, goals, and objectives.

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COOPER (1981)

APPENDIX Page6 OA.6 Surveillance Program Provide surveillance programs to accomplish coordinated moni-toring, inspection, and testing to ensure safe, reliable operation of station 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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