ML20039A295
| ML20039A295 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Point Beach File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 11/30/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| Shared Package | |
| ML093430786 | List: |
| References | |
| NUDOCS 8112170026 | |
| Download: ML20039A295 (32) | |
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Evaluation Report November 1981 Point Beach Nuclear Plant wisconsin Eec:ric Jower Comoany l
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EVALUATION of POINT BEACH NUCLEAR PLANT Wisconsin Electric Power Company November 1981
POINT BEACH (1981)
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SUMMARY
l INTRODUCTION k
The Institute of Nuclear-Power Operations (INPO) conducted its first evaluation of Wisconsin Electric Power Company's Point Beach Nuclear Plant (PBNP) during the weeks of August 10 and August 17, 1981. PBNP is a twin, Westinghouse pressurized water reactor station, each unit rated at 497 megawatts electrical. The site is located 15 miles north of Manitowoc, Wisconsin on Lake Michigan. Unit 1 began commercial operation in December 1970 and Unit 2 in October 1972.
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 plant 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 related to areas evaluated at the plant. 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 af 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 very good material condition and is being operated in a safe manner by well qualified personnel.
Certain beneficial practices and accomplishments were noted:
l The high plant availability factor.
e The record of good operator performance.
The frequent presence of plant management out in the plant and the beneficial results of this practice.
A high sense of responsibility on the part of both supervision and station workers.
High productivity of station personnel and excellent morale.
POINT BEACH (1981)
Page 2 The absence of activated annunciators.
Drawings, procedures, and training updated in conjunction with completion of plant modifications.
The low personnel radiological exposure record.
Effective housekeeping practices.
Improvements were recommended for a number of conditions.
The following are considered to be among the most important:
The absence of written procedures in several arcas and a reluctance to provide them.
The station action tracking program.
Management efforts to derive maximum benefit from the evaluation of problems at other plants.
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.
Findings 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 Wisconsin Electric Power Company or to INPO's other member utilities.
As a result, most of the findings highlight conditions 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 recommendations the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.
The findings listed herein were presented to Wisconsin Electric Power Company management at an exit meeting at the plant on August 21,1981. Findings, recommen-dations, and responses were reviewed with Wisconsin Electric Power Company manage-ment on October 19,1981. The responses are considered satisfactorv-To follow the timely completion of the improvements included in !Se responses, INPO requests written notification of status six months from the date of this report.
The evaluation staff appreciates the excellent cooperation received from all levels of Wisconsin Electric Power Company.
E. P. Wilkinson President
POINT BEACH (1981) l' Page 3 WISCONSIN ELECTRIC POWER COMPANY l
Response Summary Wisconsin Electric Power Company is pleased to have had INPO conduct a management evaluation.of the Point Beach Nuclear Plant. We appreciate the time and effort put forward by the evaluating team and wish to again thank them for their courtesy and for minimizing the impact of the evaluation upon plant operations.
The evaluation reidentified items about which we were already aware, and identified items where we can improve on the path to the goal of excellence.
We appreciate the comments given as " beneficial practices and accomplishments" and acknowledge the improvements recommended. We recognize that those recommenda-tions are summaries of specific findings which we address later in the report, but offer the following general respor.ses:
1.
Regarding the lack of certain procedures, we concede that some practices are carried out with minimal documentation or without a written procedural require-ment.
Because of our historically low turnover rate and relatively small organization, we believed in many cases that common understanding among operating personnel precluded the need for a written procedure. We are, however, evaluating the need for creating more written procedures, including those specified in this INPO report. Once evaluated, that need will dictate the schedule for creating or revising procedures.
We are, however, still dedicated to the philosophy of minimum paper and maximum quality in our operating personnel, and we believe that this approach has distinct advantages in the overall safe and best operation of a nuclear plant.
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The action tracking program for SOERs does need improvement. Again, it is a matter that we had recognized, and INPO's notation gives emphasis to acceler-ating resolution of deficiencies.
The system will be reviewed in detail and improved as needed.
3.
We agree completely that operating experience from other plants can be highly beneficial to us, and believe that our reviews have been good. We are, however, increasing the effort applied to these reviews, and requiring formal documenta-tion of their completion.
4.
The Point Beach training situation can be characterized as being in a transition period of upgrading and expansion.
Since March 1979, the number of plant personnel in the training group has increased by a factor of five. New classroom and study facilities have just been completed. The loss of two superintendents of training and difficulties in finding a replacement until recently has delayed some of our training activities. A Basic Nuclear Power School for new inexperienced operations employees is expected to be implemented by the Corporate Training Department by early 1982. While updating our documentation is, in our opinion, of lesser priority than the program effectiveness itself, we expect to be able to improve our recordkeeping fairly quickly.
e POINT BEACH (1981)
Page 4 In general, we concur with the findings and recommendations provided by the evaluation team. A direct response to each identified concern has been provided, and evaluation I
of findings will continue in order to determine additional underlying causes, if any.
l Several of our responses indicate that actions have not been completed but are planned or in progress. We will report the status of all items by letter to INPO before March 1, 1982. This report will include projected completion dates for all open items.
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POINT BEACH (1981)
Page 5 TRAINING AND QUALIFICATION 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 Completion of auxiliary operator skills training is not required l
(TQ.4-1) prior to initial qualification.
Established qualification checklists identify auxiliary operator training guidelines; however, the check-lists are not always completed prior to the trainee assuming associated job responsibilities. Additionally, turbine building job skills are not adequately covered in the qualification checklists.
Recommendation The auxiliary operator qualification system should be expanded to encompass turbine building operator job skills.
The auxiliary operator should demonstrate competency by completing the quali-fication checklist training guidelines prior to assuming job respon-sibilities.
Response
The auxiliary operator qualification guidelines and checklist will be revised to provide more specific and uniform training require-ments, including the addition of turbine hall job skills. Certain items in the checklist will be designated as minimum requirements for qualification but the long checklist will be retained as a means of recording the accomplishment of a variety of job skills.
Finding
'Ihe auxiliary operator on-the-job training system does not clearly (TQ.4-2) identify the knowledge and skills necessary for qualification. The existing training guidelines do not provide sufficient guidance in plant systems and procedure qualification standards. This allows significant variation in the auxiliary operator's qualification.
Recommendation The auxiliary operator training guidelines should be revised to identify the essential knowledge and skills necessary to perform normal and abnormal system operations.
Appropriate system descriptions, operating instructions, and technical manuals should be referenced in these guidelines. The trainee on-the-job qualifi-cation checkouts should be structured to enable consistent verifi-cation of required competency. The qualification checklists should include essential equipment surveillance checks, normal system operations, and abnormal system operations performed by the auxiliary operator.
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POINT BEACH (1981)
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Response
These items will be incorporated in the revisions described in the response to finding TQ. 4-1.
Finding A more comprehensive auxiliary operator retraining program is (TQ.4-3) needed. Areas which are not being covered for some auxiliary operators include the following:
a.
review of plant systems b.
review of applicable industry operating experiences c.
review of job-related technicalinformation.
Auxiliary operators are being kept aware of plant equipment and procedure changes.
Recommendation A formal auxiliary operator retraining program should be estab-lished and implemented. The INPO " Nuclear Power Plant Non-Licensed Operator-Guidelines for Qualification Programs" should be considered in determining these requirements.
Response
Qualification is not the end of our Auxiliary Operator training. As currently structured, once qualified, the Auxiliary Operator con-tinues to complete the job skills shown on the checklist. He also begins to work toward Control Operator qualification and is rou-tinely scheduled to attend appropriate sessions in the Licensed Operator retraining program. Development of an Auxiliary Opera-tor requalification program will be coordinated with the review and revision of the Auxiliary Operator training program. The fully developed formal requalification prograra will include requirements to review each of the areas in this finding.
Finding A Good Practice was noted in that auxiliary operator indoctrina-(TQ.4-4) tion in radiation control policies and practices is conducted in an effective manner.
The auxiliary operator trainees are initially assigned to the Health Physics Group to learn and practice radi-ation control functions. This provides auxiliary operator candi-dates with a good understanding of radiation control practices, i
which enhances auxiliary operator performance.
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POINT BEACH (1981)
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1 IJCENSED OPERATOR TRAINING PERFORMANCE OBJECTIVE: Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.
Finding A structured operating supervisor (senior control room operating (TQ.5-1) position) qualification program is needed. The training program technical content is not identified. end the job functions to be covered during the on-the-job training phase are not specified.
Recommendation A formal operations supervisor training program should be estab-lished and implemented. The INPO " Nuclear Power Plant Licened Operator-Guidelines for Quallilcation Programs at Operational Units (GPG-03)" should be considered in determining these require-ments.
Response
In the past, prior to being appointed to the Operating Supervisor position, a Control Operator underwent a careful selection and screening process to evaluate his technical and supervisory capa-bilities. After promotion, he began an individual study program guided by the training supervisor to prepare himself for NRC Senior Reactor Operator licensing.
This unstructured training method has been successful in the past based upon the large amount of experience our trainees had and the small number of trainees at any one time. With the increased pace and changes in the operator licensing procedures and exams, we find it necessary to change this approach. We will continue to carefully select our operating supervisors as we have in the past. In addition, we have recently added an Operating Supervisor Trainee position to provide time for education and development prior to assuming the Oper-ating Supervisor responsibilities. This person will participate in the Senior Reactor Operator training program which we are presently developing. This program will be formalized and designed to aid the operator in self-study by providing references, guidelines and general areas of study. The INPO " Nuclear Power Plant Licensed Operator - Gudielines for Qualification Programs at Operational Units (GPG-03)" will be used in determining these requirements.
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POINT BEACH (1981)
Page 8 MAINTENANCE PERSONNEL TRAINING PERFORMANCE OBJECTIVE: Develop and maintain the skills and knowledge neces-sary for maintenance personnel to perform their assigned job functions.
Finding Coordination of the Mechanie-Electrician qualification program (TQ.8-1) with the employee's normal job progression is needed. Mechanic-Electrician Repairers do not always complete necessary training prior to assuming associated job responsibilities.
Recommendation The Mechanic-Electrician Trainees should be qualified by imple-menting the maintenance employee progression training program described in administrative instruction PBNP 5.6.
The program should ensure that on-the-job training requirements are accom-plished in conjunction with training sessions covering associated technical information.
Response
The PBNP maintenance personnel progression and training program has been functioning for many years; the increased quantity of backfitting and surveillance at nuclear plants has caused training and progression to fall out of step, as INPO identifies. PBNP 5.6 is being revised to identify the essential qualification requirements which will be completed in correlation with normal employee progression.
9 POINT BEACH (1981)
Page 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.
FinJing A Good Practice was noted in the station's ongoing policy of (OP.2-1) initiating prompt corrective action to minimize continuois alarms.
It was observed during a number of tours through the control room that there were no activated alarms.
CONDUCT OF SHIFT OPERATIONS PERFORMANCE OBJECTIVE: Ensure that shift operations are conducted in a safe and reliable mar.ner.
Finding Inappropriate material is located in the containment building.
(OP.3-1)
Other material may be improperly stored.
Recommendation This material should be removed from the containment or properly stored. Securing items with polypropylene rope should be assessed with regard to the potentially hostile containment environment (radiation or chemical).
Response
This material will be removed or otherwise secured pending receipt of the evaluation of polypropylene rope currently in progress. The post-refueling containment closeout procedure will be reviewed to determine whether additional precautions or guidelines are neces-sary.
POINT BEACH (1981)
Page 10 PLANT STATUS CONTROLS PERFORMANCE OBJECTIVE:
Maintain plant status in a condition that ensures equipment and system availability as necessary for safe and reliable plant operations at all times.
Finding A Good Practice was noted in that frequent, routine tours of the (OP.5-1) plant by management has resulted in a positive effect on the material condition of the plant.
TAGOUT PRACTICES PERFORMANCE OBJECTIVE: Protect personnel and plant equipment by implementing effective tagout practices.
Finding A periodic review of the status of outstanding red danger tags is (OP.7-1) not being conducted. There are presently 15 red tag clearances which have been outstanding in excess of 60 days.
Recommendation A periodic review of long-standing red tags should be conducted.
One method of including this task could be to revise PBNP 4.13 (Equipment Isolation Procedure) to incorporate the periodic review, and add this task to the program "Callup."
Response
The benefit of the review of danger tags was previously identified and a new quality assurance audit procedure (PBNP 3.25.1) ensures that an audit and inventory will be conducted periodically.
Finding An independent verification of safety-related equipment, having no (OP.7-2) control room indication, that is repositioned during maintenance or testing is not performed, with the exception of the auf 'ary feedwater system. It is noted that independent verification is being performed when the equipment is removed from service.
Recommendation PBNP procedures should be revised to incorporate independent verification of safety-related equipment having no control room indication. This action should be required each time equipment is returned to service following maintenance or testing.
POINT BEACH (1981)
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Response
Wisconsin Electric concurs with the recommendation and has implemented this practice fully in the plant equipment red tag procedure and partially within other procedures. Implementation is continuing and will soon include all safety-related equipment.
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POINT BEACH (1981)
Page 12 MAINTENANCE CONTROL OF SPECIAL PROCESSES PERFORMANCE OBJECTIVE: Ensure that the control and performance of special processes yiels quality results.
Finding The Welder or Welding Operator qualifications are not adequately (M A.8-1) documented.
Reviews of available documents and test coupons verify that welder performance qualification tests are conducted annually. Station welding procedures require more frequent quali-fication renewal. Consistent documentation of the annual qualifi-cation and periodic qualification renewal is not maintained.
Recommendation Accurately and consistently document the welder performance qualification. This should include a method for annotating the renewal of qualification between welder coupons and the proce-dure (s) for which the renewal of qualification is applicable.
Response
PBNP welding procedures and welder qualification procedures are patterned after and meet the requirements of applicable editions and addenda of ASME Section IX. Documentation of qualifications will be improved to ensure renewal of individual qualifications in accordance with station procedures.
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Page 13 g
RADIATION PROTECTION AND CHEMISTRY
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RADIOLOGICAL PROTECTION TRAININd
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,j PERFORMANCE OBJECTIVE: Ensure that personnel on the site have the knowledge.
and practical abilities necessary to effectively implement radiological protect _ ion practices associated with their work.
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,7 Finding The Radiation Control Operator (RCO) training program is hot f
(RC.2-1) fully developed or implemented. RCO trainees are~not required to
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complete the program before assuming the responsibilities of an ? ^
RCO.
Written examirations and practical demonstrationi; are im utilized; however, oral examinations'are not used to evaluate the
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trainees' ability to respond to both routine _and abnormal eon-p ditions.
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Recommendation Develop a schedule for completion and implementation of the RCO training program. Develop guidelines to ensure trainees complete.
J-E the program in a timely manner and prior to their attaining qualified RCO status. In addition, oral examinations : bould be used to evaluate the trainees' ability to respond to routine and abnormal 11 conditions.
Response
As noted in the finding, a program to supplement on-the-job training is being developed. Development and full implementation of this program will continue as training and operating conditions permit. Appropriate oral examinations will be devised to ensure program adequacy.
It should be noted that Radiation Control Operator Trainees may assume some of the duties of a Radiation Control Operator prior to completion of qualification, provided they have completed that portion of the qualification related to the duties being performed.
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- -i Finding Impr6vement in general employee training is needed in the fol- _
(RC.2-2) ~
lowing areas:
a.
More information should be provided concerning work practices an individual should use to reduce their radi-ation exposure.
b.
Trainees should be required to demonstrate personnel monitoring techniques, removal of protective clothing, and use of step-off pads.
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POINT BEACH (1981)
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Page 14 m
i Tests and test practices at the completion of general c.
employee training do not adequately evaluate trainee
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understanding of the training material.
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i Recommendation
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- Revise the general employee training program to improve the areas listed above.
Rea' pome General employee orientation undergoes frequent review and revi-
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sion based upon changing plant needs and conditions.
More emphasis has been included in the orientation program on means to reduce exposure. This emphasis was being planned prior to the INPO evaluation and includes discussions on ALARA, time, y
distance and shielding, and other means of reducing personnel 7
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y exposure. We have also added demonstrations of step-off pad and
,f frisking techniques.
The procedures of donning and removing a
protective clothing will be demonstrated by plant employees and i_
supervisors of contractor groups, who, along with plant and 1
contracted radiation protection personnel, will monitor and assist those working in controlled areas. The testing procedure has been revised to include individual review of important concepts for j
those individuals failing the examination. Tests will be changed
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PERSONNEL DOSIMETRY y
. PERFORMANCE OBJECTIVE: Accurately determine and record radiation exposures.
Finding Improvement in the program for evaluating personnel radiation (RC.3-1) exposure is needed in the following areas:
t Results for thermoluminescent dosimeters (TLDs) that a.
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have been exposed to known amounts of radiation are significantly different from the known exposure.
The utility had initiated action to resolve the TLD evaluation discrepancy prior to the INPO evaluation.
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b.
The program for comparing the pocket ionization cham-bers (PICS) to TLDs does not ensure that discrepancies
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will be reviewed and evaluated. A review of TLD versus PIC results revealed discrepancies between the two dosi-meters, some as high as a few hundred millirem in a month. A revision to the TLD to PIC comparison program was initiated during the INPO evaluation.
Recommendation Management should continue the ongoing effort to resolve the TLD evaluation discrepancy in a timely manner. Quality assurance type evaluations should be initiated to ensure that TLD to PIC discrep-ancies are promptly resolved. An aid to this comparison program
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POINT BEACH (1981)
Page 15 could be the switching from O-500 mr to 0-200 mr PICS, as they are easier to interpret.
Response
The accurate determination of personnel radiation exposure is of major importance to plant health physics personnel.
Because of this, significant attention has and will continue to be given to this The following actions are in progress or have been com-area.
pleted:
The program which compares thermoluminescent dosi-a.
meters (TLD) to pocket ionization chambers (PIC) read-ings was modified to require closer scrutiny of dis-crepancies.
b.
Current practice is to read and rezero PICS daily. We are n
changing the practice to daily recording and rezeroing only when the dose exceeds a specified level.
This practice should eliminate some errors due to data scatter and low level drift and will be evaluated prior to pursuing use of 0-200 PICS in place of 0-500 PICS.
Action is continuing to improve TLD results. Conversion c.
to a new system is expected to be accomplished by January 1982.
s SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Minimize solid radioactive waste volumes.
Finding low, could be further reduced.'Ihe volume of solid radioactive (RC.7-1)
Improvement is needed in the control of material taken into radiologically controlled areas.
Maximum compaction of wastes is not being achieved.
The company has recently purchased a new compactor and is in the process of developing operating procedures.
Recommendation The plant staff should consider the following techniques in their ongoing efforts to reduce solid waste generation:
a.
segregating non-compactable materials from compactable materials b.
use of drum inserts to reduce " spring-back" during com-t paction
r POINT BEACH (1981)
Page 16 c.
a program to reduce the amount of unnecessary materials taken into radiologically controlled areas (shipping ma-terials, protective coverings, wrappings, etc.).
d.
general employee training should highlight solid radioae-tive waste control.
Response
The compactor operating procedures under development, existing radwaste handling procedures, and some aspects of the General Employee Orientation will be reviewed and revised as necessary to include these and other solid waste considerations. Drum inserts were previously identified as a possible aid to compaction and will be ordered to test their capability. We have relocated the main maintenance shop from the controlled side of the plant to the clean side of the plant. This will provide an additional aid to minimize solid waste generation.
CHEMISTRY PERFORMANCE OBJECTIVE: Ensure accurate measurement and effective control of chemistry parameters.
Finding
'Ihe Radiochemical Technician training program is not developed or (RC.10-1) implemented except for on-the-job training. These technicians are not required to complete the available portions of the existing program before assuming their job responsibilities.
Recommendation Develop a schedule for completion and implementation of the Radiochemical Technician training program. Develop guidelines to ensure trainees complete the program in a timely manner and prior to their attaining qualified technician status.
Response
Becach. of the low turnover and high experience level of Radio-chemical Technicians in the past, we had not until recently experienced the need for a significant amount of formal training other than that given on the job. However, with new hiring, we agree that a separate, formal program incorporating additional job-related topics is justified. The program is under development and, when completed, will implement the INPO Performance Objective.
POINT BEACH (1981)
Page 17 TECHNICAL SUPPORT ON-SITE TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: Have a clearly-defined on-site technical support organi-zation that is adequately staffed, assigns resporsibility, and delegates adequate authority for the accomplishment of required tasks.
Finding A more firm management commitment to an ongoing training (TS.1-1) program for on-site technical support engineers is needed. Train-ing of engineers at Point Beach is recognized as important; however, the current staff does not receive needed training.
Recommendation Develop and implement a policy that will firmly commit manage-ment to an ongoing training program for on-site techneial support engineers. This commitment should include plant-specific training, discipline upgrading, and setting aside the man-hours necessary to accomplish training.
Response
Training and development of engineers (engineer level and group head level) has in the past not been well-formalized, except for the recent Duty and Call Technical Advisor (DCTA) program. Other technical support (professional) development has included:
1.
sophisticated selection techniques for the new hire 2.
group assignment for the new hire related to the indivi-dual's previous education and qualifications 3.
subsequent rotation of new engineers to other groups for discipline development as an on-the-job work training activity as appropriate 4.
overall Company " management development training" which includes standardized leadership training and is required for all first-line supervisors and engineers with such assignments.
In the future the Duty and Call Technical Advisor training program will become the base program for training of new technical support personnel. In addition, each engineer / technical support person will be evaluated annually for his/her needed technical expertise com-bined with his/her and Company needs for professional develop-ment. The employee's supervisor will then have the individual scheduled for sections of the Duty and Call Technical Advisor or other programs to ensure the person's technical support qualifica-l tion.
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POINT BEACH (1981)
Page 18 The setting aside of the man-hours necessary and the providing of personnel or contractors for technical support training will be a management objective.
PLANT EFFICIENCY AND RELIABILITY PERFORMANCE OBJECTIVE: Optimize plant thermal efficiency and reliability.
Finding
'lhe current program for optimizing plant thermal efficiency is (TS.2-1) incomplete. The "BALAN PROGRAM DATA SHEET" is used for logging plant secondary side performance information. This and other data are currently being graphed to determine relevant trends in important plant parameters. However, it has not been determined how the graphs and data will be utilized. The fre-quency of data collection, graphing, and analysis has not been established nor has a model of the plant been developed for long-term reference.
Recommendation Develop and implement a comprehensive program for plant per-formance monitoring with an objective of improving the plant operating efficiency and reliability.
Response
Wisconsin Electric has recently hired an engineer whose primary responsibility will be the ongoing evaluation of unit efficiency as it relates to system performance. His job will include the develop-ment of a program to aid in this effort, which will include the baseline data and required performance criteria. In addition, to compensate for operational problems with some instrumentation, Point Beach is installing leading edge flow meters to more accu-rately determine power level which will enhance unit efficiency.
Reliability (unit availability) on Point Beach Nuclear Plant Unit 2 has been the highest in the United States for several years, with Unit 1 also being above average. This has been due to careful attention to the components and the systems and subsystems of the units.
However, in the next few years PBNP's high availability factors will probably fall because of equipment aging and longer planned outages.
We are committed to long-term performance improvements such as steam generator sleeving and/or replacement and are studying other components which can impact availability. Further, manage-ment has recently committed to a substantially larger inventory of I
spare parts, including such components as spare LP turbine rotors and one spare reactor coolant pump motor.
POINT BEACH (1981)
Page 19 NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM PERFORMANCE OBJECTIVE: Ensure industrywide and in-house operating experiences are evaluated and appropriate actions are taken to improve personnel awareness and equipment reliability.
Finding Appropriate management emphasis is not being foetmed on the (TS.3-1) review of industrywide operating experiences. A written program for these reviews is in effect; however, the relevant aspects of these experiences are not always identified and appropriately addressed. Completed evaluations generally address only the more obvious aspects of industry events.
In addition, no periodic, independent review is performed to ensure the adequacy of these evaluations.
Recommendation Apply appropriate management direction to ensure full implemen-tation of the industry experience review process.
Particular emphasis should be placed on conducting these reviews in a rigorous manner to ensure the important and sometimes subtle lessons to be learned from industry events are not overlooked.
Criteria under INPO Performance Objective TS.3 provides guidance in this area.
P.esponse Our review procedure has been revised to require in-depth consid-eration of generic applications of each of the recommendations listed in INPO SOERs.
Review of other operating experience information will receive similar consideration.
An independent review of operating events and of program effectiveness will be formally conducted as part of the station quality assurance audit procedure. The Off-Site Review Committee will also periodically review the status of this program.
Finding The tracking of corrective actions resulting from Significant (TS.3-2)
Operating Experience Reports (SOERs) does not ensure timely follow-up and completion of open items.
Items identified for corrective action are logged on the Administrative Punch List.
However, this list is only informally and infrequently updated.
Consequently, the status of open items is addressed irregularly, without necessarily conveying the proper priority.
Recommendation Improve the tracking mechanism used to follow identified items requiring corrective action to ensure that regular status and prior-ity determinations are made and that corrective actions are completed in a timely manner.
POINT BEACH (1981)
Page 20
Response
The Administrative Punchlist, since its inception, has been an informal, ' ut fairly effective, means of tracking many kinds of open items. We have felt the need and will proceed to revise and formalize our current practice with a procedure that will require more frequent periodic review and updating of open items.
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Finding Review is pendirg for a significant number of SOER recommen-(TS.3-3) dations. Additionally, the recommendations of SOERs 81-1, 81-2, and 81-3 did not receive adequate review.
The utility has undertaken a second review of these items. Recommendations for which review is pending are:
SOER NUMBER PENDING RECOMMENDATION NUMBER 81-4 1,2a,2b,3,4 81-5 1,2,3,4 81-6 1, la, 2 81-7 1, 2 81-8 4
81-9 1,2a,20,2e 81-10 1
81-13 1,2,3,7,8,10,11,12,13,15 4
Recommendation Complete the review of the recommendations identified above.
Advise INPO of the status of these reviews in the response to this finding.
Response
The status of reviews is as follows: SOERs 81-1, 81-2, and 81-3 are being reviewed by the plant engineering staff. Recommendations of SOERs 81-4, 81-5, 81-6, and 81-7 have been reviewed in detail, but are being held for further review based upon the anticipated Westinghouse analysis of the event.
The recommendation of SOERs 81-8 and 81-13 have been reviewed and action is completed.
SOERs 81-9 and 81-10 have been referred by the plant staff to our Nuclear Engineering Section for analysis.
POINT BEACH (1981)
Page 21 PL ANT MODIFICATIONS PERFORMANCE OBJECTIVE: Provide a program to implement plant modifications in a timely manner while maintaining the quality of plant systems and components.
Finding Plant administrative procedure PBNP 4.17 for lifted wires, jump-(TS.4-1) ers, and bypasses needs improvement in a number of aspects. This procedure should include:
a.
an interdisciplinary review for all applications of jumpers and bypasses b.
a provision to review and clear out long-standing entries c.
provisions that long-standing entries be reviewed for inclusion in the permanent plant modification process.
Recommendation Revise PBNP 4.17 as appropriate to include the above provisions.
Response
As INPO points out, PBNP 4.17, " Lifted Wires, Jumpers and Bypasses," needs improvem ent. We will in the next revision of the procedure:
Clarify that review and approval involves written ap-a.
proval of the Duty Shift Supervisor and an authorized supervisor of the cognizant plant group. (Plant groups involved in lifted wires and bypasses are Operations, Maintenance (Electrical and Mechanical) and I&C.)
b.
Ensure that log entries will be reviewed frequently by the Operations Group and evaluated in accordance with the auditing program by the Engineering, Quality & Regula-tory Group. These reviews and audits will ensure full compliance with procedural requirements. The audits will also serve to identify changes which should be appro--
priately entered into the permanent plant modification system.
Finding t
(TS.4-2)
A Good Practice was noted in that the training of plant operators and the updating of drawings and operating procedures as a result of plant modifications are effective and facilitate timely com-pletion of the modification process.
Responsibility for these important aspects of the plant modification process is firmly established with the operating crews. A conscientious effort is
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l POINT BEACH (1981)
Page 22 made to accomplish the required paperwork, testing, and verifi-cation of as-built status necessary to maintain operational aware-ness of the plant.
ON-SITE REACTOR ENGINEERING Optimize nuclear reactor operations without compro-PERFORMANCE OBJECTIVE:
mising design or safety limits and control nuclear fuel handling activities to ensure safety of personnel and equipment.
Improvements are needed in the review and approval process for Finding changes to plant computer programs and parameters. Currently a (TS.5-1) conscientious effort is made by the reactor engi",ers to avoid computer-related problems when changes are made. However, the process for review and approval is not completely formalized, is not applied to all changes, and is not adequately documented.
Recommendation Formalize the process for review and approval of all changes to the computers. Include appropriate documentation for each change.
The software change procedure will be revised to increase its
Response
A cover sheet summarizing the change and showing usefulness.
appropriate approvals will be retained for reference.
l
,a
r POINT BEACH (1981) l Page 23 ORGANIZA'I10N AND ADMINISTRATION ADMINISTRATIVE CONTROLS PERFORMANCE OBJECTIVE: Provide well-defined, organized, and effective adminis-trative controls to direct the tasks, responsibilities, and practices within the organi-zation to meet the specified mission, goals, and objectives.
Finding Administrative guidelines or procedures to provide guidance for (OA.4-1) implementation of a number of programs are not provided. Ex-amples of areas where such guidelines or procedures are needed or need improvement include:
a.
preventive maintenance b.
maintenance history c.
control of measurement and test equipment d.
sampling of systems for chemical and radiological analysis e.
operation, calibration, and standardization of some lab-oratory equipment f.
analytical techniques for chemistry and radiological eval-uation, including periodic use of spiked samples for verifi-cation of techniques g.
determination and control of chemical shelf-life h.
quality assurance reviews of chemistry and radiological laboratory techniques and practices.
Recommendation Develop and implement written guidelines or procedures for areas where needed, including those listed above.
Response
Wisconsin Electric concurs with the recommendation and will effect revision or development of procedures in the above-listed Some of the areas had been identified and placed on work areas.
lists prior to the evaluation. Progress will continue on these and others.
i i
POINT BEACH (1981)
Page 24 Finding Procedwes frequently used for station operation and training are (OA.4-2) routinely reviewed by use. However, there are a large number of procedures and administrative controls that receive irregular use and are not periodically reviewed to ensure they remain current and applicable.
Recommendation Develop and implement a policy or program to identify procedures and administrative controls that do not receive review by use and perform periodic review of those procedures and administrative controls identified.
Response
Periodic review of all procedures will be instigated and required by the quality assurance audit procedure.
l i
POINT BEACH (1981)
APPENDIX Page1 APPENDIX A I.
Performance Objectives Reviewed 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 well-defined, 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.F Shift 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.
I
POINT BEACH (1981)
APPENDIX i
Page 2 OPERATIONS OP.1 Operations Organization and Administration Provide a clearly defined operations organizatio1 that is.ade-quately staffed, assigns responsibilities, and deltgates adequate authority for the accomplishment of required tasks.
O P.2 Operations Facilities and Equipment Provide plant facilities and equipment that are operated and main-l l
tained at a level to support safe and efficient operation.
OP.3 Conduct of Shift Operations Ensure that shift operations are conducted in a safe and reliable manner.
O P.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of written procedures.
O P.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.
OP.6 Shif t 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.
MAINTENANCE MA.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.
?
5 7*
POINT BEACH (1981) s APPENDIX S
Page 3 j
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 f
Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently dispositioned and documented.
MA4 Maintenance Procedures Ensure that adequate plant maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of maintenance activities.
M A.5 Maintenance History Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvemt. ts 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.
M A.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.
R C.2 Radiological Protection Training Ensure that personnel on the site have the knowledge and practical abilities necessary to effectively implement radiological protection i
practices associated with their work.
I POINT BEACH (1981) f*.
APPENDIX Page 4 O
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 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 requirements for transportation of radioactive material.
RC.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-l quate authority for the accomplishment of required tasks.
TS.2 Plant Efficiency and Reliability Optimize plant thermal efficiency and reliability.
m
POINT BEACH (1981) a.
APPENDIX Page 5 e
TS.3 Nuclear Operating Experience Evaluation Program Ensure industrywide and in-house operating experiences are eval-uated 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.
i ORGANIZATION AND ADMINISTRATION O A.1 Organizational Objectives Establish mission, goals, and objectives for the organizational units that improve plant activities or maintain them at high levels of safety and reliability, and establish the process to achieve the 2
mission, goals, and objectives.
OA.2 Organizational Structure Provide an organizational structure that supports the effective management of nuclear power plant operation.
O A.3 Manpower Resources Ensure that qualified individuals are available to fill all job positions supporting plant safety and reliability.
OA.4 Administrativ.e 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 plant mission, goals, and objectives.
i
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m POINT BEACH (1981)
APPENDIX o
Page 6 OA.6 Surveillance Program Provide surveillance programs to accomplish coordinated meni-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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