ML20039A300
| ML20039A300 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/31/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| Shared Package | |
| ML093430786 | List: |
| References | |
| NUDOCS 8112170050 | |
| Download: ML20039A300 (39) | |
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i EVALUATION OF
.q CONNECTICUT YANKEE NUCLEAR POWER STATION Connecticut Yankee Atomic Power Company 4
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CONNECTICUT YANKEE (1981)
Paga1
SUMMARY
PURPOSE AND SCOPE The Connecticut Yankee Nuclear Power Station, operated by Connecticut Yankee Atomic Power Company (CY), was evaluated by a team from the Institute of Nuclear Power Operations (INPO). The evaluation was conducted during the period March 23 through April 3,1981.
In conducting the evaluation, the INPO team utilized preliminary criteria that have been established for the nuclear industry. The results of this evaluation were derived from discussions and interviews with CY personnel, observations and a review of CY written directives. Corporate activities were not included in this evaluation.
The INPO evaluation team focused on the major areas of Organization and Administration, Training, Operations, Maintenance, Radiation Protection and Chemistry, and On-site Technical Support. In each area, the conditions found were compared to the criteria for overall excellence, not to minimum acceptable standards. Accordingly, the recommendations in this report are not limited to minimum safety or reliability guidelines.
DETERMINATION Within the scope of this evaluation the team determined the plant is being operated safely. The following favorable practices and accomplishments were noted:
o The program for maintaining secondary plant integrity results in a notable absence of steam leaks. The last planned outage ended August 7, 1980,(234 days ago).
o The plant's capacity factor has been maintained above 77 percent for the past 12 years.
o On!y three continuous alarms were indicated in the control room, and these were not of an operationsl nature.
L o Personnel at the plant exhibited an impressive attitude and an obvious pride in their organization.
o A high level of industrial safety consciousness was exhibited in day-to-day activities, and 276 days had elapsed since the last lost-time accident.
The program for achieving this level of safety has g
l considerable merit.
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o General employee training in health physics is well-organized.
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CONNECTICUT Y ANKEE (1981)
Page 2 Improvements were recommended for the following conditions:
o Some procedures for plant operations need reviewing and upgrading.
o Post-maintenance housekeeping practices require upgrading.
The limited scope in several areas of training and the limited retraining
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could lead to problems in plant operations with future personnel.
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o Analysis of some radiological control practices shows the need for more involvement by maintenance and operations management and offers the possibility for reduction of solid waste and improved productivity.
o A need was evident for more involvement in inspection and evaluation by Ij plant management.
Specific findings and recommendations are contained in the following section of this report entitled DETAILS.
Supplementary administrative information is included as an ADMINISTRATIVE APPENDIX.
The findings were discussed initially with CY personnel during the conduct of the evaluation. They were reviewed with personnel from corporate management and the Connecticut Yankee Nuclear Power Station at an exit meeting on April 3,1981.
The INPO team conducted this evaluation during a limited period and thus, a
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total appraisal of conditions is not presented. Accordingly, in addressing these l
findings it is important to look beyond correction of the specific deficiencies.
Certain findings may reflect multiple deficiencies within an area.
Such a situation would indicate a need to improve management practices that permitted the condition to exist, as well as a need to correct the specific deficiencies.
The findings and CY's responses were reviewed with CY's management at a response meeting on June 3,1981, and are considered satisfactory.
It is requested that CY keep INPO informed, by written notification, of achievement
.of improvements at key target dates.
INPO appreciates the excellent cooperation and assistance extended by CY personnel during this evaluation.
I E. P. WILKINSON President i
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i CONNECTICUT YANKEE (1981)
Page 3 CONNECTICUT YANKEE ATOMIC POWER COMPANY (CY) i Response Summary CY appreciates receiving INPO's constructive findings and recommendations and shares INPO's interest toward improving the overall safety and reliability of the Connecticut Yankee Nuclear Power Station. CY plans on not only implementing the recommendations of this report but also reviewing and, if necessary, implementing any new INPO criteria issued subsequent to this report. C Y is confident that adherence to the INPO " Standards of Excellence" will result in overall benefit to CY, the nuclear industry and the public.
Improvements were recommended in the areas of operational procedures, house-keeping practices, training, solid waste reduction and increased involvement by plant management in inspection and evaluation. CY had recognized the need for improvement in many of these areas prior to the INPO evaluation and therefore efforts to resolve certain deficiencies are already in progress. The INPO report serves the purpose of focusing greater attention on those areas where oppor-tunities for improvement exist.
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CY concurs with the recommendation to review and upgrade procedures for plant J
operations. A program will be established to systematically review and upgrade plant operating procedures.
CY acknowledges the need for additional controls in the area of housekeeping. A formal housekeeping policy will be written and implemented.
As noted in the company's response to training recommendations, the need for increased scope of training has been recognized and is part of an ongoing, comprehensive review program of the station and corporate training needs.
CY acknowledges the need for greater involvement by maintenance and oper-ations personnel in efforts to reduce solid radioactive waste.
A committee comprised of plant and corporate personnel was established earlier this year to address the problems associated with the generation of solid radioactive waste.
J CY acknowledges the n. ed for more involvement in inspection and evaluation by
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plant management and will review and improve or extend, as necessary, existing
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programs.
The specific responses provide target dates for the planned corrective action.
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CY will submit reports to INPO on a semi-annual basis regarding our progress on the planned corrective action.
The first report will be submitted by October 1,1981.
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CONNECTICUT YANKEE (1981)
Pago 4 DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each section is headed by a summary describing the scope of the evaluation in that area. The summary is followed by the specific findings, recommendations and utility responses related to each of INPO's evaluation procedures.
ORGANIZATION AND ADMINISTRATION The overall management of the plant was evaluated from an administrative viewpoint.
This encompassed an assessment of the existing directives and procedures as well as their effectiveness, p
A good system of goals and objectives has been established, and the success is reflected in the plant's impressive capacity factor.
A high level of safety consciousness was apparent during the evaluation, and the plant has operated for 276 days without a lost-time accident. The staff organization is functioning well, and a high level of teamwork is apparent. However, a significant area deserving improvement involves the quality of the plant's procedures and the level of procedural compliance.
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OBJECTIVES (INPO Procedure OA-101, Revision 1)
I The plant's method of promulgating goals and objectives was evaluated. This included the method of implementing actions and of providing a periodic assessment of progress.
Finding (Ref. Criterion E)
A formal monitoring system has not been established to provide periodic checks on the attainment of goals and objectives.
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Recommendation L.
Develop a system to provide a periodic assessment of progress.
Response
A station policy will be written and implemented to provide guidance to station personnel in establishing goals and assessing the progress in
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reaching the goals. The policy will be written and implemented on or J
before August 1981.
ORGANIZATION STRUCTURE (INPO Procedute OA-102, Revision 2) e
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The administrative organization of the plant personnel was evaluated.
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following key areas were reviewed: organization structure, position description utilization, performance evaluations and workloed distribution.
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CONNECTICUT YANKEE (1981)
Paga 5 1.
Finding (Ref. Criterion B)
Although written position descriptions exist for most staff positions, they are not based on job analysis. A plan of action has been formulated to correct this situation.
Recommendation Implement the program now under development.
Response
The first drafts of revised position descriptions for the new corporate program for exempt personnel have been completed and are being
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reviewed. The target dates for completion and approval of the position j
descriptions for exempt and non-exempt personnel are October 1981, and October 1982, respectively.
2.
Finding (Ref. Criterion C)
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The Controlled Routing Log shows many employee development reports
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overdue, some for an excessive period. Further, position descriptions are not used routinely as a basis for the evaluation of an individual's per-formance.
Recommendation Greater emphasis should be placed on ensuring that employee perform-ance is evaluated in a timely manner.
Response
With increased management attention to the importance of timely completion of performance reviews, it is expected that the backlog of j
employee performance reviews will be eliminated on or before July 1981.
A system will be implemented to ensure that a backlog of employee 1
performance reviews does not exist.
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ADMINISTR ATIVE CONTROLS (INFO Procedure OA-103, Revision 1)
An evaluation was made of the administrative system and procedures which are established for the operation and maintenance of the plant. This evaluation included an assessment of the effectiveness of these administrative controls.
1.
Finding (Ref. Criterion C)
The existing system of administrative controls does not result in a clear j
understanding of and compliance with procedures at the worker level. A multitude of diverse procedures exist, and some are difficult to execute as written. In some cases, informal procedures are in use. Additional details in support of this finding are presented in the Operations section under OP-302, OP-303, OP-304, and OP-305.
Recommendation A program should be established to consolidate and upgrade the formal,
procedures for maintaining and operating the plant.
Response
A complete review of the various types of existing plant procedures is in progress to determine if procedures should be consolidated, revised, 5
added and/or eliminated to provide the most effective operational and maintenance results.
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CONNECTICUT Y ANKEE (1981)
Page 6 Included in the program is the review of tagout procedures, night order book, shift to shift memos, and control of labels, curves and instructions.
In addition an overall policy will be written to include the seven guidelines of OP-304, Criterion A.
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A complete review and revision of all procedures will be completed by June 1983. The schedule for revision of the various procedures will be completed by August 1981.
2.
Finding (Ref. Criterion E)
The Controlled Routing System is well-organized; however, it serves primarily as a tracking system.
It does not serve to ensure that administrative actions are completed in a timely manner.
Recommendation Provide a means for clearing the significant backlog and for ensuring that administrative actions are handled in a timely manner.
Response
A staff engineer reporting to the Station Superintendent was recently assigned responsibility for monitoring and assisting in clearing the backlog of controlled routings.
Outstanding assignments will be prioritized by new completion dates. Administrative actions for ensuring timely completion of assignments will be implemented by July 1981.
QUALITY PROGRAMS (INPO Procedure OA-104, Revision 4)
The ability to self-monitor existing conditions and ongoing plant activities was evaluated.
1.
Finding (Ref. Criterion A)
Plant conditions reflect a need for improved management techniques to identify generic problems and to develop effective plans for corrective action.
Recommendation
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Develop the necessary systems to monitor overall status.
Provide a
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means by which generic problems are identified and corrective actions are initia%d.
Response
A stat!-
olicy will be written and implemented to ensure superinten-dents at... elected department heads conduct plant tours on a regular basis.
The policy will emphasize the identification, evaluation and correction of problems and will be implemented by August 1981.
2.
Finding (Ref. Criterion G)
The execution of the Quality Assurance (QA) program does not always ensure expeditious correction of identified deficiencies.
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CONNECTICUT Y ANKEE (1981)
Page 7 Recommendation Provide for the expeditious correction of deficiencies identified by the Quelity Assurance program.
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Response
The Quality Assurance / Quality Control (QA/QC) Department will more closely check the audit response and controlled routings to ensure compliance by the specified completion date. Further, the QA audit procedure will be revised by September 1981, to require the QA/QC Department to perform audits at least annually to verify that deficiencies are corrected in a timely manner.
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INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 1)
The review of industrial safety included interviews with key personnel and extensive tours through the plant areas.
Finding (Category II)
Some areas in the plant evidence a need for improved housekeeping.
Three specific situations were of concern:
o the condition of numerous electrical components; o an absence of procedures and equipment for safe handling of acids and caustics; o storage of flammables.
Recommendation g
A plan should be developed to result in an upgrading in the level of post-J maintenance housekeeping.
Procedures should be formalized for the handling of caustics and acid, and the operators should be provided with appropriate handling equipment.
Consideration should be given to flammable storage requirements.
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Response
The methods of caustic and acid handling will be reviewed by the Station Safety Committee. Procedures will be prepared and implemented as necessary by August 1981. A housekeeping policy will be written and implemented by September 1981, which will include additional control in the areas of flammable materials and post-maintenance housekeeping.
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SURVFJLLANCE PROGRAM l
(INPO Procedure OA-107, Revision 2) t The program to accomplish required surveillance, inspection and testing was reviewed. This included the acceptance criteria, review of results and identifi-cation of off-standard conditions.
CONNECTICUT Y ANKEE (1981)
Prge 8 Finding (Ref. Cr!
lon B)
Surveillance procecures do not always contain acceptance criteria, t
Recommendation Provide for the inclusion of acceptance criteria in surveillance proce-dures so the data taker has the ability to compare results with the acceptance criteria.
Response
All surveillance procedures will be checked for acceptance criteria data and revised, if such data is missing, in accordance with the procedure revision schedule to be completed by August 1981.
1 PERSONNEL QUALIFICATIONS (INPO Procedure OA-108, Revision 1)
Written requirements and individual qualifications were evaluated.
Finding (Ref. Criteria A and C)
The written qualification requirements are not based upon job analysis, nor are they reviewed periodically.
Recommendation
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Upgrade the qualification requirements so they will represent manage-ment's requirements, and provide for a periodic review of qualifications.
Response
A review of requirements will be part of the position description development described in our response to the finding for Criterion B of O A-102.
Also a requirement for a periodic review of qualification requirements will be incorporated into the program.
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CONNECTICUT YANKEE (1981)
P gs 9 TRAINING AND QUALIFICATIONS h
The team evaluated the organization and administration of the training program; training resources and effectiveness; and programs for training licensed and non-licensed operators, shift technical advisors and other station personnel.
CY has established a comprehensive and effective licensed operator replacement training program. In addition, there are plans and proposals under co'uideration to improve the training programs for other station personnel.
The training facility is staffed by conscientious and capable personnel. The facility has an excellent system for utilizing 35mm slides in classroom presen-tations. The Training Department has numerous slides taken during original plant construction and has recently begun photographing outage activities to 3
produce additional slides for use in training.
However, opportunities for improvement exist.
Structured initial training, qualification and retraining programs are not in effect for personnel other than licensed operators.
Auxiliary operators are assigned shift responsibilities without completing formal training and certification. The Training Department
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staff is not large enough to effectively carry out existing programs while developing and implementing the additional programs needed.
No formal,
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periodic, written assessment of training effectiveness is made by plant management.
TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)
The team examined the on-site training organization and the administrative guidance used by the organization to develop, implement and evaluate training
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activities and programs used for the training of plant personnel. Included were
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licensed and non-licensed operators, electricians, mechanics, instrument and control technicians, health physics technicians, chemistry technicians, instruc-tors and staff engineers.
1.
Finding (Ref. Criterion B)
The size of the Training Department staff limits development of
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program materials and professional development of the training staff.
3 Recommendation j
A review of manpower needs for the training staff should be conducted, taking into consideration current and future training staff responsi-bilities. Needed staff members should be added M allow the department r
to fulfill its responsibilities.
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Response
j A review of the training manpower needs has been ongoing. A revised status of present and future training manpower needs at CY was recently submitted to corporate management in May. Final review and approval g
of the station training manpower requirements issue is scheduled to be completed by September 1981.
i CONNECTICUT YANKEE (1981)
Page 10 2.
Finding (Ref. Criterion C)
This criterion is addressed under Criterion B of OA-102.
Response
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Refer to response for Finding 1 under ORGANIZATION STRUCTURE (INPO Procedure OA-102, Rev. 2).
3.
Finding (Ref. Criterion D)
The plant is not conducting a comprehensive formal program for Initial training, qualification and retraining in the following disciplines:
o staff engineers; o Q A/QC inspectors;
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o health physics technicians; j
o instrument and control technicians; o maintenance personnel.
Recommendation Implement programs for initial training and retraining, including qualifi-cation requirements, for all technical disciplines. Existing programs and proposals that have not been fully implemented should be reviewed, appropriately modified and implemented.
Response
s This need for discipline training has been recognized and is part of an ongoing comprehensive review program of the training needs at both the n
station and corporate headquarters. The recent addition to the plant staff of a Technical Training Coordinator for maintenance discipline training is an initial result of the review program.
As stated in our response to the finding in INPO Procedure TQ-211, final J
approval of the training program and manpower requirements is sched-uled to be completed by September 1981.
N TRAINING RESOURCES (INPO Procedure TQ-221, Revision 2)
The team examined the training facilities, equipment and materials available to y
support the delivery of training programs for plant personnel.
Finding All criteria in this procedure were met.
TRAINING EFFECTIVENESS j
(INPO Procedure TQ-231, Revision 2)
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The team examined plant management and training organization practices relating to the evaluation of training program effectiveness, audit of training b
activities and evaluation of instructor and trainee performance in training l
programs.
CONNECTICUT YANKEE (1981)
Pcgm 11 j
Finding (Ref. Criterion A)
Plant management does not conduct structured, regular, written eval-uations of training programs.
A procedural requirement for such systematic appraisals does not exist.
NOTE: This finding also applies to INPO Procedures TQ-243 (Criterion I) and TQ-244 (Criterion I), which pertain to evaluations of effectiveness of licensed operator replacement and requalification training programs.
Recommendation Develop and implement procedures for plant management to periodically review all formal training programs for effectiveness. These procedures should utilize written examinations, oral examinations, reviews of job
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performance, periodic spot checks for lesson retention, and reviews and j
evaluations conducted by knowledgeable persons ir. dependent of the group being reviewed.
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Response
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Although an informal system is in place and functioning, the plant and corporate staffs are scheduled to develop a formal training effectiveness program, as part of the overall training program, by March 1982.
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NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)
The team examined the training program and training practices used to initially qualify non-licensed operator candidates and to maintain and improve the qualifications of existing non-licensed operators.
1.
Finding (Ref. Criteria A and D)
Present procedures do not provide guidance for carrying out the_ auxiliary operator (AO) training, qualification and requalification processes.
Formal retraining is not conducted.
Recom mendation Formalize procedure for AO initial training and qualification that specifies the requirements for obtaining and giving qualification
" checkouts" and the qualification status associated with completing each
" checkout."
In addition, develop a retraining program for AOs that is designed to maintain and improve their capabilities to perform their cur:ent jobs.
This program should meet the intent of Section 7 of INPO document No.
GPG-04, Nuclear Power Plant Non-Licensed Operators - Guidelines for Qualification Programs.
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Response
I The training staff is presently developing a formal auxiliary operator training and retraining program that will meet the CY needs as well as e
j the intent of INPO document GPG-04. The target date for program completion is December 1981.
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CONNECTICUT YANKEE (1981)
Page 12 i
2.
Finding (Ref. Criterion B)
AOs are assigned full shift responsibilities prior to acquiring a thorough understanding of plant systems, procedures and operations and prior to being certified to stand the shift.
Recommendation Formalize an initial training and qualification program for AOs that ensures an individual is competent to perform all normal and emergency duties which may be required prior to assuming full sh!ft responsibilities.
Response
I Refer to response for Finding i under NON-LICENSED OPERATOR I
TR A!NING (INPO Procedure TQ-242, Revision 2).
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3.
Finding (Ref. Criterion C)
The initial training program for AOs does not include training in power plant fundamentals appropriate to their job requirements.
I Recommendation Develop and implement an initial training program for AOs that includes instruction in power plant fundamentals. The program should meet the intent of lNPO document No. GPG-04,
Response
i Refer to response for Finding 1 under NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2).
LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)
The team examined the training program and training practices used to initially qualify licensed operator candidates to operate the nuclear plant reliably and l
safely.
Finding The criteria of TQ-243 were met with the exception of Criterion I, which was identified under Criterion A of TQ-231.
Response
f Refer to response to finding under TRAINING EFFECTIVENESS (INPO Procedure TQ-231, Revision 2).
l LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-244, Revision 2) e The team examined the program and training practices used to maintain and improve the qualifications of licensed personnel.
1.
Finding (Category II)
No program is in effect other than a read-and-sign system to ensure operators are properly trained on changes to facilities and procedures that affect safe operation of the station
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CONNECTICUT Y ANKEE (1981).
Paga 13 Recornmendation Develop a mechanism to inform operators of the bases for changes to procedures, as well as the changes themselves. Implement the program described in CY procedure QA 1.2-3.1 (Revision 12), which calls for placing a " hold" on design modifications until operators are trained as to the nature of the change.
Regonse The new plant design change system, scheduled to be completed by August 1981, will require that pertinent information is transmitted to the training department. The training department will, in accordance with procedure QA 1.2-3.1, provide proper training in the design change and associated procedures prior to placing a modified system in service that impacts the safe and reliable operation of the unit.
2.
Finding (Ref. Criterion 1)
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This finding was identified under Criterion A of TQ-231.
Response
Refer to finding under TRAINING EFFECTIVENESS (INPO Procedure s
TQ-231, Revision 2).
SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-245, Revision 1)
The team examined the qualification program and tra:ning practices wed to initially qualify Shift Technical Advisor (STA) candidates and to main.ala and improve the qualifications of the STA.
Finding All criteria in this procedure were met.
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CONNECTICUT YANKEE (1981)
Page 14 OPERATIONS Areas evaluated in the Operations Department consisted of shift operations, tagout practices, organization and administration, procedures, plant status controls, facilities and equipment and shift turnover. It was concluded that the department is staffed with well-qualified, experienced and professional persons who operate the plant in a safe and professional manner. It is noted that plans have been formulated to increase shift staffing by an additional control operator, auxiliary operator and shift supervisor staff assistant. Additionally, the planned acquisition of an off-shift operations technician should relieve the operating supervisor and his assistant of a significant amount of routine administrative tasks. The lack of permanent or recurring plant alarms and the fact that the plant is relatively free of leaks is noteworthy and attests to the attention that has been invested by managers, supervisors and workers.
3 The department is currently hindered by the necessity to reduce staffing to four shifts for a limited period due to the requirement to support shift technical advisor (STA) training. Problems exist with respect to the fact that guidance in the form of written instructions, procedures and memorandums is excessive, sometimes overlapping and, in general, burdensome, hindering both managers and operators in the conduct of their duties.
CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-301, Revision 2)
The team examined the conduct of shift operations to verify that operator activities are related to plant operation, that cleanliness and order exist, that log keeping is timely and accurate and that out-of-tolerance instrumentation is identified to the operators.
Finding (Ref. Criterion B)
Recognizing that industrial work is in progress, the debris and equipment 1
in the working areas should be better controlled. Several areas of the plant exhibit substandard cleanliness.
Exar;,ies are the state of cleanliness inside containment, the auxiliary feedwater pump room, in the intake structure and the boron storage room.
Recommendation Establish a housekeeping policy that assigns specific responsibilities.
Response
A housekeeping policy will be written and implemented by September 1981.
TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)
The team examined the formal tagout procedure to verify that it is highly respected and understood by the plant staff, senior reactor operator (SRO) approval is required for removal of safety-related equipment from service,
CONNECTICUT Y ANKEE (1981)
Pag:2 15 double verification of safety-related manual valves that do not have control room indication is required, a second verification of tagged equipment takes place, tag coloring and numbering is not confusing and the clearance log is periodically reviewed.
1.
Finding (Ref. Criterion B)
The present practices in equipment and system tagout do not conform to accepted industry standards. The major problems are evidenced by the following:
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o log entries which specify danger tags that do not exist on the equipment; o lack of compliance with the procedure, especially regarding verbal repeating of instructions; o a cumbersome procedure, under the cognizance of Quality Assur-ance, that contains instructions for coal handling and other un-related subjects.
Recommendation It is recognized that a new tagout procedure is being drafted. It should be specifically tailored to the CY power plant.
Response
CY personnel have been involved with the development of the new corporate tagout procedure which is scheduled to be completed by L
July 1981, and implemented by September 1981.
2.
Finding (Ref. Criterion C)
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A second verification is not required, nor is it being conducted,' for j
operation of important components that are repositioned during test or maintenance, are safety related and have no control room indication.
Recommendation Incorporate in the procedure instructions to perform a second verifica-tion of components that have DNn repositioned during maintenance or test and do not have position indication in the control room.
Response
A list of procedures that will require a second verification checklist for important safety-related components having no control room indications has been formulated. These procedures will be revised to contain the added checklists by April 1982.
3.
Finding (Ref. Criterion D)
Some tagouts are being performed by individuals who are not familiar r
with the tagout procedure and who lack knowledge in the operation of affected components. Provisions do not exist for training and qualifying people in tagout procedures.
Recommendation l
e Establish methods to ensure operators responsible for performing tagouts j
are knowledgeable and qualified in the details of the tagout procedure, as well as in the functioning of affected components.
Response
Traiaing in tagout procedures will be incorporated into the current l
auxiliary operator training program by October 1981.
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CONNECTICUT YANKEE (1981)
Pqe 16 4.
Finding (Ref. Criterion E)
The status of a tagout is not routinely verified by workers prior to start of work, even though verification is required by procedure.
Recommendation Enforce the present policy that workers verify the adequacy of clear-ances prior to beginning work. A sign-off on the plant work order could be used to verify the adequacy of clearances by the person accepting the tagout.
Response
Personnel have been instructed to verify status of tagout prior to beginning maintenance work. The work control system will be reviewed and revised as necessary to address the above concerns by February 1982, as part of the new Corporate Planned Maintenance Management System Program. Refer to the response for Finding under WORK CONTROL SYSTEM (INPO Procedure MA-404, Revision 1).
1 5.
Finding (Ref. Criterion G) 1 A formal periodic review and audit of the status of all tagouts is neither required nor being conducted.
Recommendation L -
Modify the tagout procedure to require a periodic audit of the tagout system. This audit should include an assessment as to whether the clearance is still needed, if the equipment is in the correct position and if the tags on equipment and tagout book agree.
Response
The tagout procedure is going through extensive review and update. The new proposed procedure requires a quarterly review of outstanding tags.
This procedure is expected to be completed by July 1981, and imple-mented by September 1981.
OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-303, Revision 2)
The team examined the operations organization and administration to verify that b
a well-defined and understood organization structure exists, department p
management has adequate authority to accomplish assigned tasks, adequate
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administraave support is provided to maximize productive time for personnel operating the plant, all instructions are issued in a businesslike manner, administrative programs are established for activities affecting employees and position descriptions are available and are utilized for all operations personnel.
Finding (Ref. Criterion E) i Written orders relating to plant operations are not always presented in a O
formal, professional manner. The night order book and shift-to-shift memos have not been established by procedure and are informal in e
g nature.
y Recommendation i
Incorporate the present night order book and system of shift-to-shift L
memos into a single, concise, formal method of issuing short-term orders j
relating to plant operations.
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CONNECTICUT YANKEE (1981)
Paga 17
Response
Refer to the response for Finding 2 under ADMINISTRATIVE CONTROLS
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(INPO Procedure OA-103, Revision 1:.
USE OF PROCEDURES (INPO Procedure OP-304, Revision 2) i The evaluation team examined the use of procedures to verify that management policies exist for use of procedures, procedures are being utilized, procedures are written clearly, instructions in emergency procedures allow quick and appropriate responses to situations and a system for revising and controlling procedures is in effect.
1.
Finding (Ref. Criterion A)
A comprehensive policy for use of established procedures has not been implemented.
Recommendation Develop and implement a program that defines a policy for use of approved procedures. The policy should include the following:
o guidance for use of procedures; o guidance for memorization; o guidance for "in hand" use of procedures; o direction if conflicts exist; o direction if a procedure does not work; o direction if unexpected results occur; o methods by which management will audit or assess the use of procedures.
Response
Refer to the response for Finding 2 under ADMINISTRATIVE CONTROLS (INPO Procedure OA-103, Revision 1)
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2.
Finding (Ref. Criterion B)
Instructions provided by some procedures are not sufficiently concise and adequate ~for users to clearly understand and perform their operational activities.
Recommendation -
All instructions relating to plant operations should be reviewed to eliminate ambiguity, overlap and conflict in order to provide operators with concise and clearly understood directives.
Response
A program to update and revise our Emargency Operating Procedures to I
make them both more accurate and useful to the operator is in progress.
The emergency procedures will be reviewed and revised as necessary by e
March 1982.
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CONNECTICUT YANKEE (1981)
Paga 18 3.
Finding (Ref. Criterion E)
A system for revising operating procedures that provides prompt action to maintain procedures up-to-date has not been established.
Recommendation Develop and implement a system for incorporating temporary changes into procedures in a timely manner.
Response
The applicable procedures will be revised by August 1981, to ensure that temporary changes are not outstanding for greater than a specified time period.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 1)
The team examined the plant status controls to verify that management approved policies exist which give guidance in the area of plant status controls, operability status of equipment is properly controlled, a senior licensed individual is assigned responsibility ' for plant status controls and special situations such as outages and post-accident recovery have provisions for adequate plant status controls.
Finding (Category II)
Approved procedures and policies are not in effect to control the use of labels, curves, notes, instructions and markings of a temporary nature attached to or indicated on plant components or control consoles. Many such examples were noted throughout the plant.
Recommendation Establish a policy to control the use of labels, curves, notes, instructions and markings of a temporary nature on plant components and consoles.
This policy should require the review and approvals necessary to post temporary instructions. The policy should include a mechanism to ensure that temporary instructions are updated or removed as required.
Response
Refer to the response for Finding 2 under ADMINISTRATIVE CONTROLS (INPO Procedure O A-103, Revision 1).
J OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-306, Revision 2)
The evaluation team examined the operations facilities and equipment to verify that equipment is accessible for operation, programs are effected to maximize e equipment availability, the working environment contributes to overall j
efficiency and safety of plant operations, communication equipment is adequate i
and watch stations are adequate.
CONNECTICUT YANKEE (1981)
Paga 19 Finding (Category II)
Plant valves, components and systems are not clearly identified by permanent, distinguishable and consistent labelling.
Recommendation Conduct a review of current valve, component and system labelling with a long-range goal of establishing and implementing more permanent, distinguishable and consistent methods of identification.
Response
A program for the review and labelling of system valves, components and systems will be established. The review is scheduled to be completed by December 1981.
SHIFT TURNOVER (INPO Procedure OP-309, Revision 2)
The team examined shift turnover to verify that procedures specify turnover requiremer.ts for all operating shift positions; shift turnovers include mechanisms to communicate pertinent information regarding equipment status, operations or testing in progress; and pertinent logs are reviewed.
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- 1.
- Finding (Ref. Criterion B)
The shift turnover check sheet does not provide a complete summary of important plant information.
Recommendation Establish a check sheet that has watchstation specific requirements and reviews. Check sheets should be used to prepare and guide the turnover process to ensure consistency.
The check sheet should include in-progress, planned and completed testing; procedures; vital safety parameters or equipment needing particular attention; the configuration of watchstation equipment; and review of pertinent operating records logs.
Response
CY plans to review shift turnover procedures in light of the INPO recommendations and make appropriate changes to our operations. This review is scheduled to be completed by August 1981.
2.
Finding (Ref. Criterion C)
Control room shift turnover does not include a general review of the control board to verify plant status either jointly between the oncoming and offgoing shift or by the oncoming shift after turnover. It is being performed by some operators at their discretion.
Recommendation Establish a shift turnover requirement for control operators to perform a general control board review, either jointly during relief or on the part e of the oncoming operator immediately after assuming the shift.
Re@onse This requirement will be addressed as part of the review discussed in OP-309, Criterion B.
CONNECTICUT YANKEE (1981)
Page 20 MAINTENANCE The team evaluated the maintenance organization, preventive maintenance programs, procedures, work control systems, maintenance history, control and calibration of test equipment and instrumentation, and maintenance facilities and equipment.
Although findings were made concerning the need to make certain maintenance practices formal, it was noted that plant equipment and instrumentation are 4
being well maintained, as evidenced by the plant's performance. The Mainte-nance and Instrumentation and Control (I&C) Departments are staffed with experienced, competent personnel who take pride in their work and their plant.
MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure M A-401, Revision 2)
The maintenance group was evaluated to determine if it is staffed and organized to accomplish maintenance tasks. Areas of interest included position descrip-tions, assignment of responsibilities and authorities, administrative controls, safety and communications programs and administrative workload.
Finding This is addressed under Organization Structure (INPO Procedure OA-102).
PREVENTIVE MAINTENANCE (INPO Procedure M A-402, Revision 1)
A review was made to determine if preventive maintenance (PM) activities are being performed and a well-defined and effective program is in effect. Adminis-trative procedures governing the program and the organization responsible for program implementation were also examined. Areas of interest included criteria used to define what equipment is covered by the program, use of equipment history files in conjunction with the program, adequacy of PM procedures for safety-related equipment and frequency of PM inspections.
The findings in this area are related primarily to administrative aspects of the program. It was observed that a considerable number of preventive maintenance activities are being performed, and the overall scope of the program in place appears to be comprehensive.
1.
Finding (Ref. Criterion A)
The Maintenance and I&C Departments Preventive Maintenance program descriptions (PM 9.5-0 and 9.2-0) do not define the program adjustment features in detail. Management's policy regarding revisions to the PM l
tasks and frequencies and the method by which these revisions are to be initiated are not described in the program description documents.
C L
Reco.nmendation 4
The preventive maintenance program description documents should be revised to include appropriate adjustment features.
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CONNECTICUT YANKEE (1981)
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Page 21
Response
PM 9.5-0 and PM 9.2-0 will be revised by September 1981, to include appropriate adjustment features.
2.
Finding (Ref. Criterion G)
Specifically the individual is not identified who is responsible for the
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development of PM procedures and the review of equipment corrective maintenance records for the purpose of revising PM tasks and frequencies.
Recommendation
[
i The preventive maintenance program should be revised to assign respon-sibility for these activities.
Response
PM 9.5-0 and PM 9.2-0 will be revised by September 1981, as applicable to include assignment of responsibilities.
s M AINTENANCE PROCEDURES (INPO Procedure MA-403, Revision 2)
The team performed an evaluation to determine the adequacy of maintenance procedures and vendor manuals for safety-related and key balance-of-plant work activities. Procedures and manuals were examined to determine the types of setivities covered, scope, level of detail, review and approval cycle, document control requirements and methods of revision.
Finding (Ref. Criterion A)
Approved procedures or maintenance instructions do not exist for some critical balance-of-plant equipment such as condensate pumps and heater drain pumps.
Recommendation Procedures should be developed for major preventive maintenance activ-ities on critical balance-of-plant equipment. Procedures should reflect current actual practice, and adherence to procedures should be stressed.
Response
The need for additional procedures in this area will be reviewed by November 1981, and procedures will be developed as necessary.
WORK CONTROL SYSTEM (INPO Procedure M A-404, Revision 1) e f,
The team examined administrative mechanisms used for identifying and report-ing equipment problems. An evaluation was performed to determine if the work control system was effective for planning and for documenting the completion of
)
maintenance work.
Specific areas of interest included the administrative
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procedure for requesting corrective maintenance and those provisions in the system related to planning, authorizing and documenting work.
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CONNECTICUT YANKEE (1981)
Pego 22 Finding (Ref. Criterion B)
The Maintenance / Work Requests and Work Permits procedure (QA-1.5-5.1) does not fully establish controls for identifying, controlling and documenting maintenance activities. Specifically, the procedure _does not address the manner in which the urgency of completing requested i
maintenance is determined and specified. Furthermore, several determi-i nations normally made during the planning phase prior to performing maintenance are not addressed by the work control procedure; examples include the determination of the need for maintenance procedures, radiation control measures, personnel safety requirements and determi-i nation of whether the requested maintenance constitutes a design change.
It was noted that many of these planning activitie.: may be performed on an informal basis even though they are not required by the 4
work control system.
Recommendation The work control system should be reviewed and upgraded to meet the intent of the concerns expressed in the finding.
Response
i The work control system will be reviewed and upgraded, as applicable, to address the above concerns by February 1982, as part of the new Corporate Planned Maintenance Management System Program, i
MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 2) 4 The team reviewed maintenance history records to determine if they were j
complete and functional and they were being used for evaluating equipment performance.
Evaluation areas covered the amount and type of equipment included in the program; type, level of detail, traceability and retrievability of
. records; methods used in reviewing and evaluating maintenance history; and assignment of responsibility for implementing the program.
]
1.
Finding (Ref. Criterion D)
Maintenance history records on major equipment and instrumentation are being maintained; however, there is no written requirement for review and evaluation of these records in either the Maintenance or I&C departments.
Recommendation The method by which maintenance history is reviewed and evaluated by Maintenance and I&C personnel should be specified.
Response
4 Maintenance history records will be reviewed and evaluated annually by Maintenance and I&C personnel. Written requirements will be estab-lished by February 1982, as part of the new Corporate Planned Mainte-l nance Management System Program.
4 2.
Finding (Ref. Criterion E)
In the I&C area there is no department instruction that describes the purpose, method and responsibility for implementing the maintenance history program for primary and secondary instrumentation.
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CONNECTICUT YANKEE (1981)
Paga 23 1
1 Recommendation A formal, written procedure that includes these elements should be developed for the I&C maintenance history program.
Response
A procedure will be issued that will describe the purpose, method and responsibility for implementing the maintenance history program by February 1982, as part of the new Corporate Planned Maintenance Management System.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION (INPO Procedure M A-406, Revision 1)
In this area a review was made to determine the adequacy and effectiveness of methods used for calibration and control of test equipment and instrumentation.
Areas examined included methods used for identifying, calibrating, storing, issuing, transporting and using measuring and test equipment.
Procedures establishing and governing the calibration programs and existing calibration records were also reviewed.
Finding (Ref. Criteria F&G)
In the Maintenance and I&C areas, measuring and test equipment are not being stored in locations that are sufficiently separate from non-controlled devices.
In addition, the issuance of measuring and test equipment in the I&C area is not controlled in a manner that would prevent use for purposes other than those intended.
Recommendation Separate storage areas should be provided for controlled measuring and test equipment.
In addition, the I&C Department should develop a control system that will effectively prevent use for other than the intended purpose. This system should be sufficiently flexible, however, g
so as not to inhibit access to test equipment by approved personnel.
g
Response
The storage facilities for measuring and test equip nent will be changed to provide adequate separation. In addition, the I&C Department will I
establish a system to control such equipment in order to preclude l
unauthorized use. This will be completed by September 1981.
MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure M A-408, Revision 1)
The evaluation team examined maintenance facilities and equipment to deter-mine adequacy and condition. The location, size and condition of office, work and storage space were examined, along with the number, type, condition and location of maintenance tools and equipment.
To a limited extent, the j
warehouse facility was also examined.
i CONNECTICUT Y ANKEE (1981)
Paga 24 1.
Finding (Ref. Criterion C)
Office arrangements for the I&C Supervisor, Foreman and Assistant are 3
established in a manner that detracts from the most effective perform-ance of their job responsibilities.
Facilities for the_ Maintenance Department were in the process of being substantially upgraded at the r
time of this evaluation.
Recommendation Review the work location of the I&C Supervisor for the purpose of reducing distractions.
Response
We are in the process of a multi-phase buildir.g project that will include adequate office space for supervisors and subordinates. This overall project has begun and will require several years to complete.
2.
Finding (Ref. Criterion E)_
Electrical maintenance ' equipment and spare parts are not being stored in an orderly manner in the storage areas assigned to the group.
It was noted that the present condition may be due in part to rearrangement of department facilities.
Recommendation Housekeeping practices in these areas should be improved.
Response
The two storage areas for electrical equipment in the maintenance shop were somewhat disorganized at the time of the INPO visit and the problem has been corrected. A program has been instituted under our response to OA-104 to prevent recurrence of the problem.
3.
Finding (Category II)
Safety-related and non-safety-related parts and materials are stored in the warehouse without segregation. There did not appear to be any procedural requirements for separation, other than tagging.
Recommendation Segregated storage should be provided in the warehouse for safety-related parts and materials.
Response
CY will segregate QA and non-QA material to the extent possible with the limited warehouse space by February 1982, and will subsequently fully segregate QA and non-QA material after the planned warehouse expansion project is completed in July 1983.
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CONNECTICUT YANKEE (1981)
-l Paga 25
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RADIATION PROTECTION AND CHEMISTRY
[,
Radiation Protection and Chemistry were evaluated by reviewing the perform-ance of radiological protection training, dosimetry, internal and external radiation exposure control, radioactive waste, radioactive contamination control, L
audits of radiological protection and water chemistry control. This portion of the evaluation was primarily an examination of plant programs and facilities as
. they function under normal (non-outage conditions. With this in mind, it was
)
concluded that the plant's radiological protection and chemistry programs were adequate to protect the public, plant workers and the environment.
During the last two years the plant has made a number of improvements in radiological protection and chemistry.
Particular strengths were noted in dosimetry and in the well-defined and functioning radiation exposure reduction (ALARA) program.
Specific good practices noted included use of a box compactor to reduce volumes of solid radioactive waste, strict standards for posting of radiation areas, initial training of new employees who perform
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radioactive work, reduction in the gross radioactivity (excluding tritium) of
[
liquid wastes and issuance of dosimetry only to those employees who enter radiological areas.
The most significant areas of weakness were in radiological protection training of health physics technicians and retraining of employees who perform radio-active work. There was a lack of aggressive efforts to reduce contamination levels, to enforce the plant's contamination control procedures and to reduce radioactive wastes.
The findings of this evaluation, which are discussed below, stem primarily from these weaknesses.
RADIOLOGICAL PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)
An evaluation was performed to determine the effectiveness of the radiation
[.
protection and chemistry organizations and their associated administrative L-control mechanisms. This area was evaluated by review of training plans and records for radiological protection and chemistry technicians, interviews of radiological protection technicians, review of records of audits and appraisals performed by other organizations, along with corrective actions taken, and review of the health physics and chemistry organization.
l.
1.
Finding (Ref. Criterion D)
Technicians have not received practical training other than on-the-job experience. Neither do they receive reactor plant systems training, nor
[
training in specific plant procedures. The present two-week training
[
course provided by corporate headquarters is primarily classroom train-ing and does not provide the practical knowledge needed by new n
radiological protection technicians without supplemental plant training.
c Interviews with qualified technicians showed weaknesses in both theo-
[
1 relical and practical knowledge. It is unde
- stood that the corporate o
L headquarters is planning additional training for radiological protection itechnicians.
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T l-CONNECTICUT Y ANKEE (1981)
Pcgs 26 Recommendation It is recommended that programs for both initial training and periodic retraining of radiological protection technicians be instituted to provide r
[
improved theoretical and practical knowledge.
Response
Practical and plant oriented training will be included in radiological
(
protection technician training. Implementation is subject to the final review of training manpower requirements scheduled to be completed by September 1981.
q 2.
Fir. ding (Ref. Criterion C)
The plant has had a large fraction of its radiological protection tech-nician positions vacant for about two years. Currently only half of the positions are filled with permanent employees.
Recommendation Management's Paing efforts should continue to receive special emphasis.
Action should be initiated as hiring obstacles are identified so vacancies can be filled with permanent employees.
Response
A recent recruiting effort was undertaken at a location that should supply us with ANSI qualified technicians.
Additionally a training program is being developed as part of our overall training manpower requirement review program to establish our own source of plant personnel.
ALARA PROGRAM (INPO Procedure RC-502, Revision 1)
An evaluation was performed to determine the effectiveness of efforts toward maintaining personnel occupational radiation exposure as low as reasonable achievable (ALARA) at the plant. This area was evaluated primarily by review of outage radiation exposure reduction reports, individual records of exposure (e.g. no worker exceeded 5 Rem in 1980) and actions taken to reduce exposure.
Finding All the criteria in this procedure were met.
PERSONNEL DOSIMETRY (INPO Procedure RC-503, Revision 1) l l
An evaluation was performed to determine the effectiveness of the plant's c
i-dosimetry program for measuring, evaluating and recording occupational radiation exposures. This area was evaluated primarily by reviewing dosimetry records.
j Finding All the criteria in this procedure were met.
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CONNECTICUT Y ANKEE (1981)
Paga 27 RADIOLOGICAL SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 1)
An evaluation was performed to determine the effectiveness of the plant's j
radiological surveillance program and radiological work control mechanisms in i
identifying radiological conditions to workers and management and in minimizing radiation and contamination levels.
The area was evaluated by touring the primary auxiliary building, turbine building, containment, and radiologically controlled areas; by observing radiological practices of radiological protection technicians and workers; and by reviewing records.
1.
Finding (Ref. Criterion C)
The present contamination control program does not provide for maxi-mum accessibility with minimum protective clothing. Plant procedures require numerous pairs of shoe covers, rubber gloves and full I
anticontamination clothing for many areas of the primary auxiliary I
building (PAB).
It is recognized that the most recent increase in protective clothing requirements started with the modification work in f
the PAB by contractor personnel.
[
Recommendation The plant should reduce radioactive contamination levels in the PAB and implement controls of contamination at its source.
f, Resporme CY will, as previously planned, reduce the radioactive contamination levels in the PAB to the levels existing prior to the block wall modification work. In addition CY will review contamination sources and implement a program for containment of contamination at the source as much as reasonably allowed by December 1981, 2.
Finding (Ref. Criterion D)
Errors were observed in some records of airborne radioactivity surveys.
I Since airburne radioactivity levels in the containment are near the levels I
where respiratory protection is required, such errors may impact wheth-er workers need to wear respirators.
(
Recommendation
[
Radiological protection personnel should be retrained in correct proce-dures for completing records. Survey records should be reviewed on a routine basis to identify errors and inconsistencies.
g g
Response
A retraining program for health physics technicians on completing records will be accomplished by September 1981. The requirement to review survey records on an established frequency will be inco porated into a procedure by September 1981.
i 3.
Finding (Category II)
The plant experienced a number of skin contamination incidents during the 1980 outage; in each case the individual was decontaminated.
A e
I review of these incidents revealed that more than half of the incidents I
resulted from improper removal of anticontamination clothing and i
f 1
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v CONNECTICUT YANKEE (1981)
Page 28 respirators. liowever, a concerted effort to correct the causes of this situation is not evident. For example, signs are not posted to illustrate proper removal of anticontamination clothing, and workers have not been reinstructed on how to don and remove anticontamination clothing.
Recommendation A concerted effort should be initiated to correct the causes of skin contaminations. This effort should not be limited to actions to reduce skin contaminations of personnel as listed in the 1980 otd ge report, but should include additional actions such as retraining and the posting of v
instructions.
Response
A quarterly review of skin contamination incidents will be performed to determine the cause and corrective action to prevent recurrence. This revieve will be in effect by September 1981.
I 4.
Finding (Category 11)
A number of radiological control practices were observed that need improvement. Examples of these practices include improper personnel s
monitoring for radioactive contamination, inconsistencies in methods used to don and remove anticontamination clothing and torn plastic bags used to contain contaminated items.
Recommendation l)
The plant should improve compliance witn radiological control practices by employees.
Response
llealth Physics technicans will be directed by July 1981, to more clearly monitor and correct such deficient practices and, if necessary, report recurrent incidents to plant management for disciplinary action.
5.
Finding (Category II)
The air pressure in the contaminated portion of the PAB is positive relative to the uncontaminated, adjacent area. This situation is contrary to standard industry practice.
Recommendation The plant should determine the cause of the positive pressure in the PAB and should correct the condition.
Response
]
CY intends to rectify the situation by rebalancing the affected j
ventilation systems using the services of an air balancing consultant.
The target date for completion is July 1981.
6.
Finding (Category II)
The plant is not following its health physics surveillance procedure that requires employees to report radiological deficiencies to management.
Recommendation Plant management should require that the health physics surveillance procedure be followed.
Response
This procedure, which is now cancelled, was developed prior to full shift coverage as now provided by health physics. Health physics supervisors a
f review daily radiological areas, conduct tours and take corrective actions upon observance of any unsafe conditions.
i
f CONNECTICUT YANKEE (1981)
Page 29 WASTE AND DISCHARGE CONTROL (LIQUID)
UNPO Procedure RC-505, Revision 2)
This area was evaluated to determine if there is a system of controls that will minimize the generation of radioactive waste, reduce the likelihood of having an inadvertent release and monitor for the presence of contamination in systems where it should not be. This area was evaluated by reviewing records of solid, liquid and gaseous wastes, touring of areas containing waste processing systems p
and waste discharge monitors and touring the radiochemistry laboratory.
i Finding (Category II)
Additional efforts are needed to reduce the volume of radioactive solid g
waste generated.
Whereas about 80 percent of the solid waste generated in 1980 was I
normal trash, several successful methods to reduce trash are not being i
used.
Specifically, radioactive and non-radioactive wastes are not segregated in radiological areas, disposable shoe cover use is not minimized, rubber anticontamination gloves are not being laundered for reuse and strict control is not exercised to minimize the tools and equipment taken into radiologically controlled areas. It is understood that corporate headquarters had scheduled a meeting to discuss methods to reduce solid waste.
Recommendation An aggressive solid waste reduction program should be initiated. Success of such a program will depend primarily on the support of maintenance and operations personnel.
Response
A radwaste committee was formed earlier this year involving corporate, Millstone Nuclear Station and CY personnel to review radioactive waste reduction programs and other related radwaste items. The committee has already made recommendations, which are being implemented, to reduce solid radwaste.
PERSONNEL IIEALTII PHYSICS INDOCTRIN ATION n
(INPO Procedure RC-507, Revision 2)
An evaluation was performed to determine the effectiveness of the plant's health physics indoctrination program.
This area was evaluated by observing the training for personnel who do not enter radiologically controlled areas and by reviewing plans and records for training of personnel who work in radiologically controlled areas.
/
Findir.,< (Ref. Criterion B) l An.ual radiological protection retraining for plant employees has had a e
i narrow scope. For example, in 1980 the retraining was limited to risks I
of low-level radiation exposure. Several of the findings in the radio-l.
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CONNECTICUT YANKEE (1981)
Pag 30 logical protection section reflect the need for improved plant employee retraining in radiological protection.
Recommendation Implement an improved retraining program that encompasses both theo-retical knowledge and practical ability.
Response
The addition of a Health Physics Training Coordinator to the training staff by September 1981, will ensure that annual radiological protection training will receive increased emphasis resulting in the recommended I
improvements.
PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2)
]
An evaluation was performed to determine if the plant staff has established a j
chemistry control program that will protect the integrity of plant systems. The evaluation included a review of procedures, laboratory quality control, primary sample collection, training and chemical parameter control. Findings were as follows:
Finding (Ref. Criterion A)
Several outdated or informal procedures (boron, chromate and chloride analysis) were posted in the chemistry laboratory.
One of these procedures was significantly different from tha present, approved pro-cedure for that analysis.
Recommendation A mechanism needs to be implemented to control use of procedure changes.
Response
This matter will be addressed as part of the overall procedural review discussed in the finding for INPO Procedure OA-103, Criterion C.
t 0
6 RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
I An evaluation was performed to determine the effectiveness of the plant's respiratory protection program in protecting personnel from airborne radio-l-
activity. Areas reviewed included policy and procedures, control of airborne l
radioactivity, respiratory fit testing for personnel and respirator maintenance.
Finding (Category II) e A program has not been developed for determining the amount of tritium that may be absorbed by workers.
Since airborne tritium levels
- containment are at about the maximum permissible concentraf-1 permitted by Federal Regulations, the plant needs a bioassay program to
}
verify workers are not receiving radiation exposare from internally
f CONNECTICUT YANKEE (1081) f-Page 31 deposited tritium.
It is understood the plant plans to start such a program.
Recommendation Implement a bioassay program for tritium.
Response
A contract is scheduled to be awarded to a qualified vendor to perform tritium analyses by July 1981. -
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i CONNECTICUT Y ANKEE (1981)
+
Page 32 TECIINICAL SUPPORT The team examined the on-site engineering organization and administration, t
engineering support functions, reactor engineering and the design change pro-r gram. In addition to on-site engineering, the team also reviewed the corporate i
program that is established to evaluate significant operating experiences at CY and other nuclear stations. The team concluded that the station is receiving adequate technical support. The proportionate number of vacant engineering positions, plant engineer training, plant design change tracking and status control and operating experience review methods were noted as areas where imorovements could be made.
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TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS-701, Revision 1)
The team evaluated on-site engineering support to determine if its organization and administration promotes accomplishment of required technical tasks. Par-
[
ticular attention was given to checking for an adequately staffed department t
with thoroughly knowledgeable individuals. Other areas of interest included the training program for this group and the administrative and cler~ical workload on department personnel.
1.
Finding (Ref. Criterion B)
The on-site technical support staff has a number of authorized positions vacant. This undarstaffing, coupled with an apparent slippage in the performance of some tasks and the current work backlog, indicates an insufficiently staffed department.
(
Recommendation b
Action should be taken to fill existing vacancies.
Response
Recruitment and training are proceeding with full staffing expected to be completed by December 1981, h
2.
Finding (Ref. Criterion D) o No formal training program is in effect for department personnel.
Personnel do occasionally attend seminars or specialized classes given by Q
outside organizations. However, no formal training program is in effect U
to aid personnel in the performance of their duties and responsibilities as plant design engineers, Recommendation c
A formal program should be implemented to ensure that all department personnel receive training in appropriate areas of station operation.
Response
Overall department training is being considered on a formal basis as part of our overall training manpower requirement study which is scheduled to be completed by September 1981.
We are starting a formal on-the-job training program for engineers which centers around selected portions of operator qualification cards. This program is based on the premise that the engineering staff's most useful skill is detailed knowledge of plant operations. The ultimate stage of 3
l CONNECTICUT YANKEE (1981)
Paga 33 this program will be a set of operator qualification prerequisites for entry into the licensed operator course.
ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)
The team evaluated engineering support to determine its effectiveness in resolving problems and concerns of a technical nature. Areas reviewed included plant performance monitoring, communications with on-site and off-site groups, document control system and engineering support facilities.
Finding (1
The department maintains good communications with other groups and has an adequate document control system and support facilities.
All criteria in this procedure were met.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision 1)
The effectiveness of operating experience evaluation and follow-up was ex-amined by the team. Areas reviewed included the program for handling in-house and industry operating experiences, utilization of experienced technical person-nel, periodic review of program effectiveness and periodic independent eval-uation of industry experiences to verify proper classification.
Finding There were no findings in this area.
PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 1)
The evaluation team examined methods and programs for plant modifications to determine if they are implemented in a safe and timely manner and the proper quality of plant systems and components is maintained.
The current program of updating plant drawings to an "as-built" status is noteworthy. It is recognized that this is a major task.
e lt Finding (Ref. Criterion C) l Many outstanding plant design change requests are not being reviewed in a prioritized manner nor tracked on a systematic basis. Prioritizing and
't tracking of modifications was done at an earlier date; however, due to the understaffing situation, this effort has been discontinued.
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CONNECTICUT YANKEE (1981) r Page 34 Recommendation Outstanding plant design change requests should be prioritized and g
tracked on a routine basis.
Response
The new plant design change system, scheduled to be completed by l'
August 1981, will 9ecify a priority system.
6
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ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
The team examined procedures, availability of the plant computer, communi-cations with other groups, fuel integrity commitments and refueling activities.
Finding The reactor engineering group appeared to have satisfactory procedures, maintained good communications with other groups, had a fuel integrity commitment and had preplanned refueling activities. All criteria in this procedure were met.
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CONNECTICUT YANK 2E (1981) a APPENDIX j
Page1 ADMINISTRATIVE APPENDIX I.
LISTING OF AREAS EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Organization Structure OA-103 Administrative Controls O A-104 Quality Programs OA-106 Industrial Safety OA-107 Surveillance Program O A-108 Personnel Qualifications f
TRAINING AND QUALIFICATIONS TQ-211 Training Organization and Administration TQ-221 Training Resources TQ-231 Training Effectiveness TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training TQ-244 Licensed Operator Requalification Training TQ-245 Shift Technical Advisor Training OPERATIONS O P-301 Conduct of Shift Operations
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O P-302 Tagout Practices
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OP-303 Operations Organization and Administration OP-304 Use of Procedures O P-305 Plant Status Controls O P-306 Operations Facilities and Equipment O P-309 Shif t Turnover MAINTENANCE M A-401 Maintenance Organization and Administration M A-402 Preventive Maintenance M A-403 Maintenance Procedures M A-404 Work Contro1 System M A-405 Maintenance History M A-406 Control and Calibration of Test Equipment and Instrumentation MA-408 Maintenance Facilities and Equipment m._
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CONNECTICUT YANKEE (1981)
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APPENDIX Page 2 RADI ATION PROTECTION AND CHEMISTRY I
RC-501 Radiation Protection and Chemistry Organization and Administration RC-502 ALARA Program i
RC-503 Personnel Dosimetry RC-504 Radiological Surveillance and Control RC-505 Waste and Discharge Control (Liquid) r-RC-507 Personnel Health Physics Indoctrination
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RC-508 Process Water Controls RC-511 Respiratory Protection Program TECHNICAL SUPPORT TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience Evaluation Program TS-704 Plant Modifications TS-705 On-Site Reactor Engineering t
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CONNECTICUT YANKEE (1981)
APPENDIX Page 3 II.
CONNECTICUT YANKEE POWER STATION PERSONNEL CONTACTED Station Superintendent Unit Superintendent i
Station Services Superintendent Senior Engineers Engineering Supervisor Instrument and Control Supervisor Maintenance Supervisor j
Operations Supervisor Quality Assurance Superybor Chemistry Supervisor liealth Physics Supervisor Radiological Protection Supervisor Stores Supervisor Training Supervisor Assistant Operations Supervisor Shif t Supervisors
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Supervising Control Operators Control Operators Auxiliary Operators Instrument and Control Specialist Reactor Engineer Station Superintendent's Secretary y)
Health Physics Foreman Radioactive Waste Foreman ALARA Coordinator Records Coordinator
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Assistant Maintenance Supervisor Maintenance Technician Maintenance Foreman Operator Training Coordinator Instrument and Control Supervisor Chemist f
Chemistry Technicians
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IIcalth Physics Technicians Instrument and Control Foreman Maintenance Clerk-Typist Superintendent of Nuclear Operations (Corporate)
Unit Coordinating Engineer (Corporate)
Supervisor Nuclear Safety Engineering (Corporate)
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