ML20040A133
| ML20040A133 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/31/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| References | |
| NUDOCS 8201200390 | |
| Download: ML20040A133 (36) | |
Text
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NRR Evaluation Report
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October 1981
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PRAIRIE 1SLAND NUCLEAR GENERATING PLANT Northern States Power Company October 1981 JAN B E
PRAIRIE ISLAND (1981)
Paga1
SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Northern States Power Company's (NSP) Prairie Island Nuclear Generating Plant during the weeks of June 1 and June 8,1981. The Prairie Island Station consists of two 507 megawatt (net electrical) Westinghouse pressurized water reactor plants. The station is located on the Mississippi River in southeast Minnesota. Unit I was placed in commercial operation in December 1973 and Unit 2 in December 1974.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant operating safety, evaluate management systems and controls and identify areas where improvements can be made. Determinations are based on observations of activities, discussions, interviews and reviews of station docu-ments.
Station administrative functions, training, operations, maintenance, on-site tech-nical support, and radiological and chemistry activities were evaluated. Cor-l porate activities were not included in the scope of the evaluation, except as an incidental part of the station evaluation. As a basis for the evaluation, INPO used its own experience on best practices in the industry and written evaluation j
criteria, copies of which were furnished to tLe station in advance.
The
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evaluation standards are high, and the findings and recommendations are not limited to minimum safety concerns.
l DETERMINATION l
Within the scope of this evaluation, the team concluded the station is in superior material condition and is being operated in a safe manner by competent personnel who exhibit high morale.
The fdlewing beneficial practices and accomplishments were noted:
Superior operating and maintenance practices have resulted in high o
reliability.
An effective outage planning and performance program has minimized o
scheduled and unscheduled downtime.
o Maintaining a high percentage of engineers with current senior reactor operator licenses provides the station with a stable, experienced engi-neering support group.
Effective radiological exposure control practices exist, as evidenced by o
low total man-rem exposure.
PR AIRIE ISLAND (1981)
Page 2 o The quality and applicability of the station's integrated prccedures contribute to the effective operation of the station.
Opportunities for improvement were identified as follows:
o A need exists for formalization of good practices currently in use with written pclicies and guidelines.
o Communications between the corporate training group and station man-agement need improvement to ensure station training needs are met.
Recommendations associated with the findings are intended to augment NSP's effort to achieve high standards in its nuclear operations. In taking corrective
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action, findings should be analyzed for applicability to broad areas. Such action should address the underlying issues or causes. NSP's responses to the report are considered appropriate to the findings and recommendations presented.
Specific evaluation findings are in the accompanying DETAILS, and information J
of an administrative nature is in the ADMINISTRATIVE APPENDIX. These findings were presmted at an exit interview at the Prairie Island Station on I
June 12, 1981, and were further discussed along with NSP's responses on l
August 28 and 31,1981, in a telephone conference with station management.
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To follow the timely completion of the improvements included in your responses, j
INPO requests written notification of status six months from the date of this a
report.
The evaluation staff appreciates the excellent cooperation received from all j
levels of the Northern States Power Company.
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E. P. Wilkinson President l
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PR AIRIE ISLAND (1981)
Page 3 NORTIIERN STATES POWER COMPANY Response Summary NSP concurs with INPO's conclusion that the Prairie Island Station "is in superior material condition and is being operated in a safe manner by competent personnel who exhibit high morale."
The company also recognizes that there are weas for improvement and is pleased to provide a positive response to all of the !APO recommendations.
Specific implementation dates have been set for many INPO recommendations.
l The company welcomes follow-up INPO evaluations to assess program implemen-tation.
PR AIRIE ISLAND (1981)
Paga 4 l
DETAILS This section of the report includes the detailed findings. Findings referenced to a specific criterion within an INPO evaluation procedure are Category I, i.e.,
established standards of excellence. Findings referenced to General Criterion are Category II, i.e., accepted industry practices or a not-yet-approved INPO l
criterion.
l There are six segments to this section, one for each major evaluation area. Each segment is headed by a summary describing the scope of the evaluation and statements of pertinent observations made in that area.
The summary is followed by specific findings, eecommendations and utility responses related to each performance area. An Administrative Appendix lists the applicable INPO evaluation procedures used at the Prairie Island Station.
ORGANIZATION AND ADMINISTRATION l
1 Station objectives, organizational structures, administrative controls and pro-grams for industrial safety, quality assurance, and surveillance inspections and tests were reviewed.
Several areas were evaluated that indicated commendable performance by the Prairie Island organization. These would includc station programs for quality control, industrial safety, outage planning and surveillance scheduling.
Areas where improvement should be made are position descriptions and personnel performance evaluations.
OBJECTIVES (INPO Procedure OA-101, Revision 2)
An evaluation was performed to determine the establishment of goals and objectives throughout the station and how effectively they convey intended operational and maintenance directives. Areas reviewed included the station mission statement, availability of station mission documents, supervisor account-ability, assessment programs and measurement of goals and objectives attain-ment.
Finding All criteria in this procedure were met.
ORG AN!ZATION STRUCTURE (INPO Procedure OA-102, Revision 2)
An evaluation was performed to determine if the organizational structure provides the capability of managing Prairie Island on a day-to-day basis in a safe and efficient manner. Areas reviewed included the organizational structure and
PR AIRIE ISLAND (1981)
Paga 5 reporting requirements, the establishment of written position descriptions based on job analysis, the use of position descriptions to periodically evaluate each individual's performance, the span of control for management positions, the back-up capability for management positans and the staff size.
1.
Finding (Reference Criterion B)
Written position descriptions based on job analysis have not been 4
developed for union and non-union, non-exempt job positions. A clear definition of job responsibility, accountability, authority and qualifica-tions does not exist.
Position descriptions for senior management positions do define these areas.
j Recommendation Position descriptions based on job analyses and including the details listed above should be developed for all station personnel. These position descriptions should be utilized as a management tool for hiring, training, performance appraisal and promotions.
Response
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A job analysis of all positions in the plant is now underway. As these are 1
completed, position descriptions will be written and reviewed with the incumbents. Expected completion date is February 1982.
j 2.
Finding (Reference Criterion C)
Periodic performance evaluations of individual station personnel are not conducted.
4 Recommendation Establish and implement a policy and suitable guidelines to periodically conduct performance evaluations for each station employee.
Response
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Beginning approximately three months after employees have had an opportunity to review their position descriptions, performance evalua-l tions will be held. By May 1982 all employees on site will have had a formal performance evaluation. Thereafter, performance evaluctions of I
all jobs will be conducted at least annually.
ADMINISTR ATIVE CONTROLS
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(INPO Procedure OA-103, Revision 2) j An evaluation was performed to determine the effectiveness of the controls for administrative functions. Areas reviewed addressed the program of administra-tive controls for purpose, scope, responsibilities, flexibilities, level of adminis-trative actions and program dissemination.
Finding l
All criteria in this procedure were met.
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PR AIRIE ISLAND (1981)
Paga 6 4
QUALITY PEOGRAMS (INPO Procedure OA-104, Revision 5)
An evaluation was performed to determine how effectively quality programs monitor and audit plant activities to ensure proper levels of quality. Areas
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reviewed included management controls, accountability programs, pr.ogram cross-checks, program effectivenesss, programs for corrective actions, and staffing.
8 Finding All criteria in this procedure were met.
i INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 3)
An evaluation was performed to det em.ine the effectiveness of the station's safety program in providing a safe, orderly working environment.
Areas j
reviewed included the station's general and site-specific policy, management l
support for the safety program and employee and management interface in safety matters.
Finding l
All criteria in this procedure were met.
SURVEILLANCE PROGRAM UNPO Procedure OA-107, Revision 3)
An evaluation was performed to determine if an effective program exists to accomplish surveillance inspections and testing.
Areas reviewed included completeness, depth, acceptance criteria, results review, notification and con-trol of off-standard conditions, suitable scheduling and training in proper use of surveillance procedures.
Finding All criteria in this procedure were met.
PERSONNEL QUALIFICATIONS ONPO Procedure OA-108, Revision 2)
An evaluation was performed to determine if a program exists for providing qualified personnel to operate and maintain the station. Areas reviewed included the applicability of %5 descriptions for station positions, the programs for i
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j PR AIRIE ISLAND (1981) l Page 7 l
personnel promotion and selection and the program for periodic review of all job descriptions.
l Finding a
The criteria of this performance area were met except as noted previously in OA-102, Criterion B, regarding a clear definition of l
qualifications for union and non-union, non-exempt job positions. -
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PR AIRIE ISLAND (1981)
PagG 8 TRAINING AND QUALIFICATION The following areas were evaluated: training organization and administration; training programs for licensed and non-licensed operators, shift technical advi-sors and other station personnel; and training resources. Positive features were noted in most areas. Of special note are management's commitment to training as demonstrated by the new training facility under construction, and manage-ment and union cooperation in the joint training committees for overseeing the on-the-job training programs.
Areas for improvement are as noted in the following details.
TRAINING ORGANIZATION (INPO Procedure TQ-201, Revision 0)
An evaluation was performed to determine if a clearly defined training organiza-tion staffed with qualified personnel exists that is capable of accomplishing all assigned training tasks.
1.
Finding (Reference Criterion B)
The existing training organization cannot provide all of the required and projected 1981 training activities as currently planned.
Recommendation Complete tl.e ongoing, in-house review of manpower needs for the training staff.
Develop and implement a prioritized training plan considering projected training schedules and availability of qualified instructors.
Response
The in-house review of training staff manpower needs associated with the 1981 work objectives has been completed. A prioritized training plan is in effect. We exrcet to use cdditional contract instructors in the interim until the plant instructional staff is appropriately qualified.
2.
Finding (Reference Criterion D)
Some instructors on the training staff need to improve their site-specific knowledge.
Additionally, some instructors need further instructor training.
Recommendation Develop and implement a program for training instructors covering plant-specific knowledge. Establish a program for improving instruc-tional qualifications of the instructors.
Response
A program exists and is being implemented for training instructors without sufficient plant-specific knowledge (reactor operator and senior reactor operator classes).
All instructors have or will receive training in instructional techniques.
In addition, each instructor will be evaluated at least semi-annually on his instructional techniques and classroom lectures.
This is considered to be an ongoing program.
PR AIRIE ISLAND (1921)
Pags 9 f
TRAlNING ADMINISTRATION (INPO Procedure TQ-202, Revision 0)
An evaluation was performed to determine if organization functions necessary to initiate and control personnel qualification programs are accomplished in a well-defined, coordinated and effective manner.
1.
Finding (Reference Criterion A)
A policy or guideline is needed to ensure the interface between the corporate training organization and the plant organization satisfies the plant's training needs.
Recommendation Develop and implement a policy that defines corporate training and plant interfaces such as scheduling, information exchange, responsibilities of one department to the other, training needs and training goals, devel-opment and modification program curricula; and development and modi-fication of training materiau.
Response
The Power Division Administrative Control Directive on training has been revised to reflect this interface and has been routed for comment.
It is anticipated this revised directive will be effective by December 1,1981.
2.
Finding (General Criterion)
Production Training Department technical procedures were developed and approved without input or review by other organizations. Plant input is needed to ensure the procedures meet the specific training require-ments of Prairie Island.
Recommendation To ensure plant training needs are met, have Production Training Department technical procedures reviewed by other organizations such as on-site training and/or station personnel.
Response
The INPO recommendation is now being implemented, Production Training Department technical procedures have been revised and were re-issued as draft Power Production Administrative Work Instructions on June 15,1981. These were sent to the appropriate organizations for comment.
It is anticipated these instructions will be effective by December 1,1981.
TRAINING RESOURCES (INPO Procedure TQ-205, Revision 0)
An evaluation was performed to determine the suitability of facilities, equip-ment and materials available for the delivery of effective training for station personnel.
PRAIRIE ISLAND (1981)
Page 10 1.
Finding (Reference Criteria A and B)
An increase is needed in the number of classrooms and amount of office space for training activities. The new training facilities under construe-tion should provide a long-term solution to this problem.
Recommendation Conduct a review of current training facility needs. This review should include, but not be limited to, regularly scheduled training, irregularly scheduled training, instructor preparation requirements, administrative function requirements and study areas.
Take corrective action as necessary.
Response
As indicated, the new training facilities should provide a long-term solution to the problem by apprcximately February 1,1982.
In the short term, a new trailor was added on July 18,1981, which provides additional office and classroom space.
An evaluation of classroom, office and study area needs is continuing, but it is anticipated that the current facility will be adequate until the new facility is ready.
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Findmg (Reference Criterion F)
Some plant reference material, such as the systems descriptions section of ths operations manual and technical manuals used in the training program, do not reflect current as-built plant conditions.
Recommendation Update plant reference material used in training and establish a control system to ensure a routine updating of this material.
Response
Plant system descriptions will be updated. The anticipated date for completion is December 1982. Technical manuals are being incorporated into a control system. Administrative controls are in place that will ensure routine updating.
LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-223, Revision 0)
An evaluation was performed to determine if an effective program exists to maintain a high level of knowledge and skill in individuals licensed as reactor or senior reactor operators.
Finding (Reference Criterion C)
A comprehensive program is needed to ensure that pertinent industry-related material is provided to the training department and included in the training program.
Recommendation Develop and implement a policy and guidelines to ensure timely inclusion of materials such as the following in retraining activities:
o Licensee Event Reports o Significant Event Reports
PR AIRIE ISLAND (1981)
Paga 11 Significant Operating Event Reports o
l o vendor information reports o Nuclear Regulatory Commission bulletins, notices and circulars o plant modifications o procedure changes Technical Specification changes.
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Response
A comprehensive program will be in place by October 15,1981.
SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedures TQ-224, Revision 0)
An evaluation was performed to determine if the shift technical advisor qualification program prevides individuals with the qualifications necessary to provide effective technical assistance to the operating shift personnel during normal, abnormal and emergency operating conditions.
Finding All criteria in this procedure were met.
l NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)
An evaluation was performed to determine if initial and continuing training for non-licensed operators is sufficient to ensure the individuals are capable of performing their jobs safely and efficiently.
1.
Finding (Reference Criterion C)
Plant-specific classroom instruction is needed for initial training of non-licensed operators.
Recommendation Implement a structured training program for initial training of non-licensed operators. The training program described in the Production Department procedures could provide this training.
Response
Effective October 1,1981, a sixth shift should be implemented. The plant-specific classroom instruction described in the Production Training Department procedures will be implemented.
2.
Finding (Reference Criterion D)
Continuing training of non-licensed operators is needed to maintain and improve their capabilities to perform their current jobs.
Recommendation Develop and implement a program to maintain and improve the capabili-ties of qualified non-licensed operators to perform their current jobs.
PR AIRIE ISLAND (1981) pig 212 This program should include periodic lectures to review plant systems, facility and procedure changes; emergency actions required by the job position; and plant and industry operating experiences.
Response
Effective October 1,1981, a sixth operating shift should be added. The continuing training program described in the administrative work in-struction will be implemented.
LICENSED OPER ATOR TRAINING (INPO Procedure TQ-243, Revision 2)
An evaluation was performed to determine the effectiveness of the training program that prepares candidates for reactor and senior reactor operator licenses.
Findmg All criteria in this procedure were met.
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PR AIRIE ISLAND (1981)
Page 13 OPERATIONS l
I The Operations Department was evaluated in the areas of shift operations, tagout practices, organization and administration, use of procedures, plant status I
controls, shift turnover and facilities and equipment.
Within the scope of this evaluation, it is evident the Operations Department is an experienced, dedicated group of operators.
'Ihe professionalism of these operators, enhanced by excellent control room facilities, has made a significant contribution to the high level of performance achieved at Prairie Island.
Areas where improvement should be made include tagout pactices, use of procedures and shift turnover.
OPERA 110NS ORGANIZATION AND ADMINISTRATION UNPO Procedure OP-301, Revision 3)
An evaluation was performed to determine the existence of a clearly defined operations organization that provides for the assignment of responsibilities and the delegation of adequate authority for acccmplishment of required tasks.
Areas reviewed included organizational structure, job descriptions, shift admin-istrative assignments, and written and cral instructicus and orders.
Finding All criteria in this procedure were met.
TAGOUT PRACTICES UNPO Procedure OP-302, Revision 2)
An evaluation was performed to determine if established tagout practices ensure protection of personnel and equipment. Areas reviewed included senior reactor operator approval of safety-related tagouts, independent verification of tagged equipment for personnel safety, independent verification of safety-related components, tag coloring, tag numbering and clearance log review.
Finding (Reference Criterion G)
Periodic reviews and audits of the status of all tagouts are not required by policy or procedure and are not being routinely conducted.
Recommendation Revise existing procedures to include instructions requiring periodic reviews and audits of systems or equipment currently controlled by tagouts.
These instructions should include a determinetbn of the continued need for the tagout and, if the tagout is needed, $_ v rification that equipment is aligned correctly.
Response
The recommendation will be incorporated fully. The periodic review will be quarterly. Revised instructions will be in place in October 1981.
PR AIRIE ISLAND (1981)
Pega 14 CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP-303, Revision 3)
An evaluation was performed to determine how effectively the conduct of shift operations maintains quality shift performance.
Areas reviewed included operator activities, station cleanliness and order, response to abnormal conditions, logkeeping practices, reliability of control room instrumentation and operator awareness of plant conditions.
Finding All criteria in this procedure were met.
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i USE OF PROCEDURES (INPO Procedure OP-304, Revision 2)
An evaluation was performed to determine if procedure content and use are appropriate for conducting operations safely and reliably.
Areas reviewed included management policy for use of procedures, procedure changes, procedure clarity and continuity, suitable advisory information and identification of "se-quence required" actions.
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Finding (Reference Criterion A)
A comprehensive policy for use of integrated operating and emergency i
procedures is needed.
Recommendation 1
Develop and implement a policy and suitable guidelines for use of approved procedures. The policy should include the following:
o guidance for use of procedures o guidance for "in-hand" use of procedures o directions if conflict exists between procedures and standing instructions directions for memorizing immediate action steps o
o directions if a procedure does not produce the intended results o methods by which management will audit or assess the use of procedures.
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Response
The recommendation will be incorporated fully. Revised guidelines will be in place in January 1982.
1 2.
Finding (Reference Criterion D)
Some emergency procedures contain a large number of immediate action steps. It is recognized there is an ongoing program to reduce the number of emergency procedures and the number of immediate action steps.
i Recommendation Follow through to completion the program for reducing the number of emergency procedures and the number of immediate action steps in the emergency procedures.
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PR AIRIE ISLAND (1981)
Paga 15
Response
The program will be followed through to completion by January 1982.
3.
Finding (General Criterion)
A number of uncontrolled procedures, hand-drawn system sketches and handwritten operational notes are in use in the plant.
Recommendation Develop and implement a policy to prevent the use of uncontrolled procedures, instructions, drawings and notes. The policy should include a periodic review for updating or removal of authorized temporary instruc-tions.
Response
The recommendation will be incorporated fully. Instructions will be in place in October 1981.
PLANT STATUS CONTROLS (INPO Procedure OP-305, Revision 2)
An evaluation was performed to determine if plant status controls are provided to ensure adequate equipment and system availability. Areas reviewed included management programs and policies that provide guidance for status control, actual practices in status control, responsibility of senior licensed operators assigned to monitor and review status control, and provisions for status control under special conditions.
Finding All criteria in this procedure were met.
OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-306, Revision 2)
An evaluation of the operations facilities and equipment was performed to determine if there is adequate accessibility for operation, programs are in place to maximize equipment availability, the working environment contributes to overall efficiency and safety of plant operations and communication equipment is adequate.
Find:ng All criteria in this procedure were met.
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PR AIRIE ISLAND (1981)
Paga 16 8HIFT TURNOVER (INPO Procedure OP-307, Revision 1)
An evaluation was performed to determine if procedures specify shift turnover requirements for all operating shift positions; if shift turnover includes mecha-nisms to communicate pertinent information regarding equipment status,, opera-tions, or testing in progress; and if pertinent logs are reviewed.
Finding (Reference Criterion C)
The shift turnover policy does not ensure a general review of the control boards during turnover nor is a review being consistently performed.
Recommendation Modify present turnover policy to specifically require a general review of control boards as part of the turnover process.
Response
The procedure now requires a general review of control boards im-mediately after turnover. This review is documented.
l PR AIRIE ISLAND (1981) l Paga 17 MAINTENANCE Organization, corrective and preventive maintenance, administrative programs, procedures, maintenance history, special processes, and maintenance facilities were reviewed.
The material condition of the plant attests to the effectiveness of the preventive and corrective maintenance programs. Areas where improvements are recom-mended include maintenance organization and administration, maintenance his-tory, control of test equipment, control of special processes and maintenance facilities.
MAINTENANCE ORGANIZATION AND ADMINISTRATION ONPO Procedure MA-401, Revision 3)
An evaluation was performed to determine how effectively the Maintenance and Instrument and Control (I&C) organizations and cdministrative programs function to enhance performance of maintenance tasks.
Areas reviewed included I
organizational structure, reporting requirements and practices, staff size, train-ing and retraining, use of position descriptions and span of control for supervi-sors.
Finding (Reference Criterion F)
Maintenance management and supervisors spend a significant amount of time in general administrative and clerical activities. More time needs to be made available for in-plant observations of department work activities and equipment conditions.
j Recommendation Review maintenance management's and supervisors' work activities and priorities for optimum use of their time. Take corrective action as necessary.
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Response
The recommended review has been done. Additional clerical support will be provided for maintenance supervision. Further corrective action will be taken as necessary.
l PREVENTIVE M AINTEN ANCE (INPO Procedure M A-402, Revision 2)
An evaluation was performed to determine the effectiveness of the maintenance effort in optimizing equipment reliability and performance. Areas of review included governing procedures, equipment included in the program, type and frequency of preventive maintenance (PM), and effectiveness of program coor-dination and control.
PR AIRIE ISLAND (1981)
Paga 18 Finding All criteria in this procedure were met.
M AINTEN ANCE PROCEDURES (INPO Procedure M A-403, Revision 3)
An evnluation was performed to determine if existing maintenance procedures i
provide quality and effectiveness of maintenance activities. Areas of review included an assessment of activities governed by procedures, methods of procedure development and revision, and content of procedures.
Finding All criteria in this procedure were met.
WORK CONTROL SYSTEM (INPO Procedure M A-404, Revision 3)
An evaluation was performed to determine the effectiveness of the work control system in use at the plant. The system functions were reviewed to ensure they define and authorize work to be performed by maintenance groups; provide for planning, scheduling and control of actual work; and provide a suitable record of work performed for future reference.
Finding All criteria in this procedure were met.
M AINTEN ANCE lilSTORY (INPO Procedure Mir105, Revision 3)
An evaluation was performed to determine if maintenance history records are retained and used to improve equipment reliability and performance. Areas of review included assessment of equipment included in the program, content and accessib!!ity of recordr, history review and evaluation methods and procedures for program implementation.
Finding (Reference Criterion A)
Comprehensive guidelines or procedures are not available to describe the methods and responsibilities for implementing the Maintenance Depart-ment maintenance history program.
PR AIRIE ISLAND (1981)
Pago 19 Recommendation A written policy and suitable guidelines should be developed to describe the maintenance history program. The guidelines should be sufficiently comprehensive to describe history record format, responsibilities, ac-cess, and methods to evaluate and trend equipment performance.
Response
The machine history program description will be rewritten to better reflect present activities and the responsibilities for accomplishing program objectives by January 1,1982.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTR 1?MENTAT ON (INPO Procedure M A-406, Revision 2)
An evaluation was performed to determine if available facilities and procedures provide for accurate test equipment and instrumentation.
Areas reviewed included identification, calibration, storage, issuance, usage, shipment and documentation.
Finding (Reference Criteria A, D and E)
Maintenance Department and I&C Section Work Instructions do not provide instructions for tagging out-of-calibration or damaged equipment with a distinct " reject" tag. Additionally, instructions to ensure segre-gated storage of these items are needed.
Recommendation Maintenance Department and I&C Section Work Instructions should be revised to provide instructions for use of " rejected" tags and segregated storage.
Response
Appropriate Section Work Instructions will be revised in accordance with the recommendation by January 1,1982.
CONTROL OF SPECI AL PROCESSES (INPO Procedure M A-407, Revision 1)
An evaluation was performed to determine if adequate controls exist for performance of special processes.
Areas of review included training and qualification of personnel, administrative controls and control of equipment and materials for weldir,g processes.
Finding (Reference Criterion D)
Welding machines are not included in the preventive maintenance program.
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Paga 20 l
l Recommendation A review of special process equipment preventive maintenance require-l l
ments should be performed and action taken to include these machines in the plant preventive maintenance program.
Response
A preventive maintenance program for welding machines will be devel-oped by January 1,1982.
MAINTENANCE PACllri1ES AND EQUIPMENT (INPO Procedure MA-408, Revision 2)
An evaluation was performed to determine if available facilities and equipment contribute to the performance of maintenance activities.
Areas reviewed included number, type and condition of tools and equipment; size and location of
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l tool storage areas; adequacy of office and work areas; and the cleanliness and orderliness of maintenance facilities.
Finding (Reference Criterion A)
Office space for the I&C Supervisor is inadequate and detracts from the effective performance of the position's responsibilities.
Recommendation Review the I&C office space and initiate the necessary action to provide the I&C Supervisor witn an area suitable to the conduct of his responsi-bilities.
Response
Partitioned office space will be provided as part of the Instrument Shop remodeling. This is planned as soon as space is made available, by the plant office remodeling project, for I&C parts storage. The anticipated date for completion is January 1982.
PR AIRIE ISLAND (1981)
PJga 21 R ADIATION AND CHEMISTRY Radiation protection and chemistry were evaluated by reviewing plant perform-ance in the areas of training, personnel dosimetry, external and internal radiation exposure control, radioactive contamination control, waste manage-i ment and plant chemistry.
A number of good practices were observed in radiological protection and chemistry. They included management participation in carefully considering radiation exposure when planning and conducting high exposure jobs, successfully maintaining a staff of qualified technicians and technical support personnel and reducing radiation sources by decontamination and chemistry control.
RADIATION PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)
An evaluation was performed to determine the effectiveness of the radiological protection and chemistry organizations.
/.reas reviewed included the formal organization structure, procedures for condact of operations, staffing levels, training and retraining programs, position descriptions and management author-ity.
Finding All criteria in this procedure were met.
PERSONNEL DOSIMEi'RY (INPO Procedure RC-503, Revision 1)
An evaluation was performed to determine the effectiveness of the station's dosimetry program in measuring, evaluating and recording occupational radiation exposures.
Areas examined included the scope of the dosimetry program, procedural controls, dosimetry selection and use, system operation and exposure records.
Finding All criteria in this procedure were met.
RADIATION SURVIflLLANCE AND CONTROL (INPO Procedure RC-504, Revision 2)
An evaluation was performed to determine the effectiveness of the station's radiological surveillance program in minimizing personnel exposure and contami-nation by detecting and controlling direct radiation, airborne activity and 1
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PR AIRIE ISLAND (1981)
P:ga 22 contamination of equipment and work spaces. Areas of interest included the scope of the surveillance program, radiological conditions in the plant, manage-l ment reviews, and work and access controls.
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Finding (General Criterion) l The portal monitor in use at the auxiliary building " access control point" does not have state-of-the-art sensitivity to detect low leve.ls of contamination. It is noted that the atation has already initiated steps to l
procure a more sensitive portal monitor.
Several frisking stations within the radiological control zone are located where background radiation levels were too high to permit detection of i
low levels of contamination.
i Recommendation Continue with the procurement and adoption of more sensitive portal monitors at the station.
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Lower the background radiation levels at those frisking stations where the background is excessive or relocate the frisking stations to low background areas.
Response
More sensitive portal monitors are being procured and will be installed.
Frisker stations will be evaluated. Frisker areas will be at a background consistent with the sensitivity required of the frisker.
WASTE AND DISCIIARGE CONTROL (INPO Procedure RC-505, Revision 2)
An evaluation was performed to determine the effectiveness of the station's waste control programs in minimizing the generation of liquid and solid radio-active waste and limiting releases to levels as low as is reasonably achievable.
Areas reviewed included procedures, effluent monitoring, clean system sampling and waste generation.
Finding All criteria in this procedure were met.
RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)
An evaluation was performed to determine if the station is maintaining a sufficient inventory of survey instruments with a high degree of accuracy. The review included procedures, storage conditions, National Bureau of Standards traceability and calibration methods.
PR AIRIE ISLAND (1981)
Pago 23 Finding (General Criterion)
The following problems were noted in the calibration of radiation survey equipment:
o The calibration sources in current use are not of sufficient strength to calibrate the highest range of the Teletector survey 'instru-ments.
o The calibration range should be restandardized at sufficient, fre-quent intervals to ensure compensation for radioactive source decay.
o The high-range source needs an interlock or warning device to prevent Inadvertent exposure to the radiation beam.
Recommendation o Action should be initiated to periodically calibrate the highest range of the station's Teletector survey instruments.
o Station procedures and practices should be reviewed to restendard-Ize the calibration range to ensure accuracy of radiation detection equipment remains high.
o Personnel protection device (s) should be provided to ward against inadvertent exposure to a high-level calibration source.
Response
A new radiation survey meter calibrator source is being procured. This calibrator will be of sufficient strength to calibrate the Teletector at higher radiation levels. The source will havre a long half-life such that the present restandardization frequency will be adequate to compensate for source decay. The new source will be adequately safeguarded to prevent inadvertent exposure.
PERSONNEL HEALTil PilYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2)
An evaluation was performed to determine the effectiveness of the station's health physics indoctrination program in informing personnel of the risks associated with radiation exposure and the available methods for minimizing exposure. Areas reviewed included management policy, scope and depth of the inoactrination, the training environment and training documentation.
Finding All criteria in this procedure were met.
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PR AIRIE ISLAND (1981)
Paga 24 PROCESS WATER CONTROLS (INPO Procedure RC-508, Revision 2)
An evaluation was performed to determine the effectiveness of process water controls in maintaining the integrity of plant systems. Areas reviewed included i
procedures, laboratory quality control, bulk chemical control, cleaning agent control, reagent control, training and systems chemistry.
Finding (Reference Criterion B)
The plant does not routinely use samples with known chemical concen-tration to verify the accuracy of process water measurements.
Recommendation Develop and implement procedures to periodically use " spiked" samples with known chemical concentrations as a quality check on laboratory reagents, instrumentation and laboratory technician performance.
I
Response
The quality control program will be revised to verify more thoroughly the accuracy of process water measurements by January 1,1982. This program will include use of " spiked" samples with known chemical con-centrations as a quality check on laboratory reagents, instrumentation, and laboratory technician performance.
HEALTH PilYSICS FACILTITES AND EQUIPMENT (INPO Procedure RC-509, Revision 2)
An evaluation was performed to determine the effectiveness of the station's health physics and chemistry facilities and equipment in satisfying station needs and in contributing to safe and efficient plant operation. Areas of interest included the number and type of instruments and equipment and the design and working environment of facilities.
Finding All criteria in thir. procedure were met.
RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
An evaluation was performed to determine the effectiveness of the station's respiratory protection program in protecting personnel from airborne hazards.
Areas reviewed included policy and procedures, identification and control of airborne radioactivity, selection and use of respirators and emergency capabili-ties.
PR AIRIE ISLAND (1981)
P:g2 27, Finding (Reference Criterion C)
The breathing air supplied from air manifolds throughout the plant is not sampled to determine its purity.
Recommendation Develop a policy and suitable guidelines for the routine sampling and analysis of the breathing air for potential contaminants.
Response
A program for sampling and analysis of breathing air for potential contaminants will be developed and implemented by January 1,1982.
RADIATION EXPOSURE REDUCTION GOALS (INPO Procedure RC-538, Revision 0)
An evaluation was performed to determine the effectiveness of efforts toward maintaining personnel occupational radiation exposure as low as reasonably achievable (ALAR A).
Finding (General Criterion)
Practices and programs used by the station to minimize radiation exposure have not been fully documented.
A number of effective practices are in use at the station to reduce exposure. Documentation of the more important aspects of these practices and departmental duties for ALAR A could help ensure continued effectiveness.
Recommendation Develop written policies and guidelines to ensure the continued effee-tiveness of current ALARA practices.
Response
Written policies and guidelines on ALARA practices will be expanded.
This will ensure continued effectiveness of present practices. The effort will be completed by June 1,1982.
PR AIRIE ISLAND (1981)
Paga 26 TECHNICAL SUPPORT An evaluation was performed to determine the effectiveness of on-site technical support activities. Areas reviewed included organizational structure and size, assignment of responsibilities and effectiveness of coordination with other groups. In addition, programs for control of design changes, on-site and off-site industry event reviews, plant performance monitoring and reactor engineering activities were reviewed.
It was concluded that the station is receiving effective technical support. The large number of senior reactor operator (SRO) licensed engineering personnel is one indication of a well experienced, knowledgeable technical support staff.
TECliNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS-701, Revision 1)
An evaluation was performed to determine if the technical group is capable of performing assigned responsibilities, personnel are knowledgeable of their duties, a training program exists to enhance and develop the skills and knowledge of personnel and non-technical personnel are utilized for non-technical tasks.
Finding (Criterion D)
A training program is needed for engineers who are neither SRO licensed nor in license training.
Recommendation Develop and implement a program to ensure that all deputment personnel receive training in appropriate areas of station operation.
Response
The training department will provide introductory training in systems, administrative controls and appropriate regulatory requirements to all new engineers. It is anticipated that an introductory course can be offered by January 1,1982, and on an annual basis thereafter.
ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)
An evaluation was performed to determine the staff's effectiveness in resolving problems and concerns of a technical nature. This included plant performance monitoring, communications with on-site and off-site groups, document control systems and engineering support facilities.
1.
Finding (Criterion A)
A comprehensive effort is needed to monitor, assimilate and evaluate plant parameters important to thermal efficiency and reliability. Sev-eral activities are currently being performed as part of plant perform-ance monitoring. 'Ihese activities, however, are not comprehensive. A l
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PR AIRIE ISLAND (1981)
Page 27 further commitment of resources is needed for optimizing plant thermal performance.
Recommendation Develop and implement a comprehensive program for plant performance monitoring with the objective of improving the plant operating effi-ciency and reliability.
Response
Present plant performance monitoring activities will be formalized. In addition, a performance engineer will be named to coordinate these activities, and systems engineers will formalize procedures that monitor plant thermal efficiency and equipment reliability.
Implementation is scheduled by January 1,1982.
2.
Finding (Criterion C)
Improvements are needed in the control and updating of technical manuals. In addition, many uncontrolled drawings are stored in the control room panels.
Recommendation The plant manuals problem has been recognized and is being addressed by the Document Control Group.
The current project of updating and establishing a technical manuals control system should be continued.
The drawings presently located inside the control room electrical panels should be controlled in a manner consistent with other plant drawings. In addition, they should be relocated or a fire loading analysis review performed if they are allowed to remain in place.
Response
The plant technical manual effort is proceeding satisfactorily. Technical manuals will be controlled and updated. The anticipated completion date is December 1982.
Drawings located in control room electrical panels will be controlled in a manner consistent with other drawings. 'Ihe drawings will be removed from the panels or e fire loading analysis review performed justifying their present location. This effort will be complete by the end of 1981.
NUCLEAR OPER ATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision 1)
The effectiveness of operating experience evaluation and follow-up action was examined.
Areas reviewed included the program for handling in-house and i
industry operating experiences, utilization of experienced technical personnel, periodic review of program effectiveness and methods of industry notification of significant plant events.
I PR AIRIE ISLAND (1981)
Paga 28 1.'
Finding (Criterion A)
The program to review and evaluate industry operating experiences has not been fully implemented < The station has written a directive to control the review of operatirg experience information originating outside the plant; however, it has not yet been implemented.
In addition, the responsible corporate group has not yet performed a review and evaluation of 1981 INPO/NSAC Significant Operating Experi-ence Reports (SOERs) and 1980 Significant Event Reports (SERs). The 1981 SOERs include reports 81-1 through 81-11.
t Recommendation The station should expedite approval and implementation of the proposed directive covering this area.
The responsible corporate group should complete its review and evalua-tion of the above-identified SERs and SOERs and ensure appropriate actions are initiated.
Response
The program to review and evaluate industry operating experiences has now been implemented.
The 1981 SOERs are in the process of being investigated and evaluated, and the applicable event reports will be transmitted to the station in accordance with procedure 1-NTS-1, NTS Operating Experience Assess-i ment. The Northern States Power Company is committed to evaluate SOERs in accordance with the INPO letter of December 9,1980.
2.
Finding (Criterion C)
The proposed station directive and corporate group procedure for review of in-house events and industry experiences do not include requirements to periodically evaluate the effectiveness of the review programs and to consider improvements.
Recommendation l
Add a provision to the station directive and corporate group procedure to provide periodic reviews for effectiveness at a specified frequency.
Response
Audits required by the Quality Assurance Program of Administrative Control Directives and Safety Audit Committee reviews will provide coverage of program effectiveness. Quality Assurance Group audits of the Administrative Control Directives is an existing requirement. The Safety Audit Committee will include operating experience evaluation in j
their periodic review program.
3.
Finding (Criterion F.2)
A policy has not been established to ensure that other utilities will be notified of possible Prairie Island significant events having generic implications.
Recommendation Develop and implement a policy addressing the review of in-house events to determine if industry notification is appropriate.
PR AIRIE ISLAND (1981)
PIga 29
Response
A procedure will be written to require de review of Significant Operating Event Investigative Reports generated in accordance with 5ACD 3.C, Operating Occurrences and Events. If this review indicates that a plant event could have generic implications, industry notification will be made via the NOTEPAD system. The anticipated date to revise and implement the procedure is December 1981.
PLANT MODIFICATIONS (INPO Procedure TS-704, Revision 1)
Methods and programs for plant modifications were evaluated to determine if they are implemented in a safe and timely manner and if the proper quality of plant systems and components is maintained.
1.
Finding (Criterion C)
A tracking system is needed to assign priority and ensure timely comple-tion of plant design changes.
Recommendation Outstanding plant design changes should be prioritized and tracked on a routine basis.
Response
Outstanding plant design changes will be tracked and prioritized on a routine basis. Quarterly, the status of each outstanding design change will be determined. From this effort, prioritizing, as necessary, will be pursued. This will be implemented by October 1,1981.
2, Finding (Criterion I)
As-built drawings of plant design changes are not routinely provided to the plant operators when placing modified systems in service.
Recommendation The es-built drawing situation had been recognized by the station; however, suitable corrective action has not yet been taken. A system should be developed to provide the control room with interim drawings reflecting as-built conditions prior to placing a modified system in service.
Response
A system is being developed and will be implemented that will provide the control room and other controlled files with interim drawings reficcting as-built conditions prior to placing a modified system in service. This process will be implemented by the end of 1981.
PR AIRIE ISLAND (1981)
Paga 30 ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
The teem examined procedures, controls on the plant computer and associated software, communications with other groups, fuel integrity commitments and refueling activities.
Finding All criteria in this procedure were met.
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PR AIRIE ISLAND (1981)
APPENDIX Page1 ADMINISTR ATIVE APPENDIX LISTING OF AREAL [ VALUATED ORGANIZATION AND ADMINISTRATION OA-101 ObP.ctives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-106 Industrial Safety OA-107 Surveillance Program OA-108 Personnel Quctifications TR AINING AND QUALIFICATION TQ-201 Training Organization TQ-202 Training Administration TQ-205 Training Resources TQ-223 Licensed Operator Requalification Training TQ-224 Shift Technical Advisor Training TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training OPERATIONS OP-301 Operations Organization and Administration OP-302 Tagout Practices OP-303 Conduct of Shift Operations OP-304 Use of Procedures OP-305 Plant Status Controls O P-306 Operations Facilities and Equipment O P-307 Shift Turnover M AINTEN ANCE M A-401 Maintenance Organization and Administration M A-402 Preventive Maintenance MA-403 Maintenance Procedures MA-404 Work Control System MA-405 Maintenance History M A-406 Control and Calibration of Test Equipment and Instrumentation i
M A-407 Control of Special Processes M A-408 Maintenance Facilities and Equipment
PR AIRIE ISLAND (1981) l APPENDIX i
Page 2 R ADIATION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control RC-505 Waste and Discharge Control RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program RC-538 Radiation Exposure Reduction Goals 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 i
PR AIRIE ISLAND (1981)
APPENDIX i
Page 3
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i II. NORTilERN STATES POWER COMPANY PERSONNEL CONTACTED Plant Manager Plant Superintendent, Engineering and Radiation Protection Plant Superintendent, Operations and Maintenance Staff Engineer Senior Scheduling Engineer Superintendent, Quality Engineering Superintendent, Operations Shift Supervisors Lead Plant Equipment and Reactor Operators Plant Equipment and Reactor Operators Assistant Plant Equipment Operators Plant Attendants Plant Services Supervisor Superintendent, Maintenance Maintenance Supervisors Chief Electrician Lead Rigger Quality Control Specialist Superintendent, Radiation Protection Radiation Protection Engineers Radiation Protection Supervisor Radiological Chemistry Supervisor Radiological Protection Coordinator Radiological Protection Specialist Office Manager Plant Administrative Specialist Nuclear Engineer Superintendent, Technical Engineering Instrument and Control Supervisor Instrument and Control Coordinators Superintendent, Operations Engineering Operations Engineers Superintendent, Nuclear Technical Support Administrative Aid, Nuclear Technical Suppor t Manager, Production Training Superintendent, Training Superintendent, Prairie Islan;d Training Simulator Sapervisor Training Engincer Training Instructor i
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