ML20041D375

Evaluation of Davis-Besse Nuclear Power Station.

ML20041D375
Person / Time
Site:	Davis Besse
Issue date:	01/31/1982
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
To:
Shared Package
ML20041D368	List: ML20041D364 ML20041D375
References
NUDOCS 8203050270
Download: ML20041D375 (32)

Text

_ _ _ ___ _ . _. - .. _ _ _ _ . . .. _

Evaluation Report January 1982 Davis-Besse Nuc ear PowerStation oeco scison

,e Comaany INPO l

l

!!R 2888K 4 8888!6

EVALUATION of DAVIS-BESSE NUCLEAR POWER STATION The Toledo Edison Company e

r

! e i

D AVIS-BESSE (1981) j , Page1

SUMMARY

4 INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of The Toledo Edison Company's Davis-Besse Nuclear Power Station during the weeks of September 14 and 21,1981. Davis-Besse is a single unit, 906 Mw net Babcock and Wilcox pressurized water reactor. The station is located on the southwest shore of Lake Erie about 21' miles east of Toledo, Ohio. The unit began commercial operation in November 1977.

PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of i plant safety, to evaluate management systems and controls, and to identify areas l

! needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of documentation.

The INPO evaluation team examined station training, operations, maintenance, radio-logical and chemistry activities, on-site technical support, and organization and 1

i administration. The team also observed the actual performance of selected evolutions and surveillance testing. Corporate activities were not included in the scope of the evaluation, except as an incidental part of the station evaluation. As a basis for the evaluation, INPO used performance objectives and criteria relevant to each of the six areas examined; these were applied and evaluated in light of both the experience of team members and INPO's observations of good practices within the industry.

INPO's goal is to assist member utilities in achieving the highest standards of excellence in all phases of nuclear plant operation. Accordingly, the conditions found in each area were compared to best practices, rather than to minimum acceptable conditions or requirements.

DETERMINATION Within the scope of this evaluation, the team determined that the plant is in i satisfactory material condition and is being operated in a safe manner by qualified

personnel. Certain beneficial practices and accomplishments were noted. .

l Corporate headquarters has a strong commitment to establish an organization and  ;

develop supporting programs to achieve improved support of nuclear operations.

Radiation protection personnel are achieving excellent results in minimizing total j exposure.

The training organization is making effective use of local college programs and  !

facilities to provide education for plant personnel.  !

i I

i

DAVIS-BESSE (1981)

Page 2 Improvements were recommended in a number of areas. The following are considered to be among the most important: -

The work order system needs to be purged and the backlog of work requests reduced.

Control of the jumper and lifted wire system needs improvement.

The information tagging system is in need of improved controls.

Cleaning of rotating equipment needs improvement.

Control of the plant design change program needs improvement.

Personnel monitoring for radioactive contamination needs to be strengthened.

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

Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to which they pertain. Particularly noteworthy conditions that contribute to meeting  ;

PERFORMANCE OBJECTIVES are identified as Good Practices. Other findings describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It would not be productive to list as Good Practices those things that are commonly done in the industry since this would be of no benefit to Toledo Edison or to INPO's other member utilities. As a result, most of the findings highlight conditions that need improvement.

The recommendations following each finding are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.

The findings listed herein were presented to Toledo Edison management at an exit meeting at the plant on September 25,1981. Findings, recommendations, and responses were reviewed with Toledo Edison management on November 19, 1981. Toledo Edison responses are considered satisfactory.

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

The evaluation staff appreciates the cooperation received from alllevels of The Toledo Edison Company.

E. P. Wilkinson President t _ -. - _-

DAVIS-BESSE (1981)

. Page 3 TIIE TOLEDO EDISON COMPANY Response Summary

. The Toledo Edison Company (TED)is pleased that INPO found the Davis-Besse Nuclear Power Station being operated in a safe manner. As recognized by INPO, Toledo Edison's Corporate Management is committed to the continued safe operation of Davis-Besse.

Our commitment to excellence has extended beyond our own resources. We have solicited recommendations and assistance from many nationally known experts and consultants in nearly all areas of facility operation. Their recommendations have covered widely varying subjects related to safe, reliable plant performance. Toledo Edison appreciates INPO's constructive findings and recommendations, and supports INPO's goal of utilizing these remarks to achieve the highest possible standards of operation.

Toledo Edison acknowledges INPO's recognition of our achievements in the areas of corporate management support, radiation protection, and personnel training as deline-ated in their " beneficial practices and accomplishments" remarks. Toledo Edison views this as a positive indication that its continuing efforts toward overall excellence of operation are paying off. This recognition is especially gratifying to those Davis-Besse personnel who have contributed to this station having the lowest total collective

radiation exposures (man-rem) of all operating light-water nuclear plants in the United States for the past three years.

INPO also pointed out several areas in which improvements could be made. Toledo Edison readily acknowledges these recommendations and is pleased to note that in the areas of the work order system, cleaning of equipment, and the control of plant design changes, problems had been previously recognized and the Company had already instituted changes to correct them. In the areas of the jumper and lifted wire system, the information tagging system, and personnel monitoring, it is agreed that beneficial changes can be made. In all of the areas commented on, Toledo Edison views the recommendations as a fresh source of ideas to be utilized in evaluating existing programs for continued improvement.

As a result of the INPO evaluation and finding recommendations, Toledo Edison has already taken action to implement changes in several areas. In the several areas of the report where INPO noted Toledo Edison had already identified a deficiency and was taking corrective action, the actions will be reevaluated in light of an outside perspective.

A specif!c response for each finding is contained in the body of the report. Where appropriate, Toledo Edison has identified target dates for completion of corrective actions. Toledo Edison will keep INPO advised of progress toward implementing its responses and welcomes INPO's review and assistance.

I r I

! l l

I l

DAVIS-BESSE (1981)

, Page 4 TRAINING AND QUALIFICATION I l

TRAINING ADMINISTRATION PERFORMANCE OBJECTIVE: Ensure that activities necessary to initiate and control personnel qualification programs are accomplished in a well-defined, coordinated, and effective manner.

Finding A Good Practice was noted in that the training organization is (TQ.2-1) effectively utilizing college and university programs and facilities to provide education for plant personnel. Using guidance from plant management, a local technical college has implemented a nuclear power associate degree program to prepare personnel for entry-level plant positions. Additionally, several university courses are being conducted on site in Bachelor of Science degree programs to provide continuing education for plant personnel.

NON-LICENSED 'ERATOR TRAINING PERFORMANCE OBJECTIVE: Develop and maintain the skills and knowledge neces-sary for non-licensed operators to perform their assigned job functions.

Finding The auxiliary and equipment operator on-the-job training programs (TQ.4-1) should more clearly identify the knowledge and skills necessary for qualification. These programs are primarily administered through self-study and oral checkouts. However, the program guidelines do not provide sufficient detail in plant systems and procedures knowledge requirements. . Additionally, equipment monitoring and system operating job skills thould be covered in the qualification manual.

Recommendation The auxiliary and equipment operator qualification manual should be revised to identify the essential knowledge and skills necessary to monitor equipment and perform normal and abnormal system i operations. The trainee on-the-job qualification checkouts should be structured to ensure consistent verification of required knowl-edge and skills. l Response The auxiliary and equipment operator qualification manuals have been amended to include instructions to the operator and the j examiner that identify the minimum knowledge and skills necessary ,

l to complete the checkoff. Also included are sources of informa- I tion available to the operator to better prepare for examination. l The licensed operators will be able to give better structured  !

checkoffs to ensure the trainee can operate and monitor the plant j l l L___ - -

DAVIS-BESSE (1981)

Page5 systems. The job skills required to complete the various operator tasks are verified by successfully completing the checkoff, a written examination, and finally a thorough in-plant walk-through by a senior licensed operator.

Finding A more comprehensive auxiliary and equipment operator retraining (TQ.4-2) program is needed. Areas that are not fully covered include the following:

a. job-related plant equipment

b. applicable plant and industry operating experiences

c. review of job-related 'echnical information, including procedure changes Recommendation A formal auxiliary and equipment operator retraining program should be established and implemented. The INPO " Nuclear Power Plant Non-Licensed Operators - Guidelines for Qualification Pro-grams(GPG-04) could provide a basis for determining the program requirements.

Response A more formal non-licensed operator retraining program will be developed by the nuclear training department. Program develop-ment should be completed by March 1,1982, and the program will be implemented by September 1,1982.

DAVIS-BESSE (1981)

Page 6 OPERATIONS CONDUCT OF SillFT OPERATIONS PERFORMANCE OBJECTIVE: Ensure that shift operations are conducted in a safe and reliable manner.

Finding Equipment operators (EO) should be assigned to specific shift (OP.3-1) positions. Equipment operators for each shift are grouped on the schedule without specific plant area assignments. This can result in EOs not obtaining information at shift turnover that is necessary for performance of shift assignments.

Recommendation Review current shift assignment methods and implement controls to improve continuity of shift assignments and turnover.

Response Present shift assignment of auxiliary operators / equipment opera-tors is made by the shift supervisor. Policies will be developed to ensure all shift supervisors assign operators in a similar manner, that the assignment is clear to each operator, and known to the reactor operators. The duration of the assignment will be consis-tent. The shift supervisors will rotate assignments to ensure requalification (TQ.4-2). Turnover will be strengthened per Finding OP.6-1 recommendation. These policies will be established by January 31,1982.

Finding Access and traffic control within the control room should be (OP.3-2) improved. The number of people entering and present in the control room is sometimes excessive. Non-licensed operator shift turnover usually occurs in the control room, which adds unneces-sary personnel at shif t turnover time.

Recommendation Review existing policies and procedures for adequacy and revise as needed. Increase supervisory attention in this area to ensure compliance with these policies and procedures.

Response Improvement in control of access and traffic within the control i

room will be made. Standing Order 27 (control room access) will be strengthened. A restricted access zone will be marked off on the floor requiring the reactor operator's permission to enter. This will be done by December 31, 1981. Turnover for auxiliary I operators and equipment operators will be at their local work station. AD 1839.00 will be modified to require this by January 31,1982.

l

DAVIS-BESSE (1981)

Page 7 Also, a new terminal for access for the computer has been installed in the computer programmer's office, and Instrumentation and Control (I&C) will be requested to use that terminal instead of the control room terminal when they can. Also, when FCR 79-113, 855 i replacement, is complete about March 1982, two terminals will be i added outside the control room. I&C engineers and training / testing l shift can use these terminals and cut down on control room traffic. l l

Finding Housekeeping and equipment cleanliness need improvement. Gen-(OP.3-3) eral cleanliness should be upgraged in the turbine building and rad- i waste processing area. Oil accumulations were present around  ;

some tanks and pumps, and some pumps and rotating equipment  !

were not routinely cleaned.

Recommendation Expand existing procedures to include individual and departmental  !

responsibilities and accountabilities for housekeeping, and to in- l clude periodic monitoring of these accountabilities by managers and supervisors.

Response Existing procedures will be expanded to include individual and departmental responsibilities and accountabilities for housekeep-ing, and to include periodic monitoring of these accountabilities by managers and supervisors. Control room panels have been assigned ,

to each shift for cleaning. Operators are responsible to clean l rotating equipment in the area they are assigned to work. The Monthly Equipment Log will be changed to add cleaning of specific troublesome areas on a routine basis (e.g., seal oil room, oil sump baseplates, etc.). Implementation of this will start by January 31, 1982 and will continue as additional areas are identified.

i Finding The number of control room annunciators normally in an alarmed (OP.3-4) condition should be reduced. There is a program to decrease the ,

number of annunciators in the alarmed condition; however, the l program is limited in scope.

Recommendation More aggressive action to eliminate the cause of continously acti-vated annunciators is needed.

I Response A program to decrease the number of annunciators in the alarm l condition does exist, and work is progressing in several TED j organizations to accomplish this task. During the past year, the number of nuisance alarms has been reduced by approximately 50 percent. As part of the changeout of the station process computer

~

DAVIS-BESSE (1981)

Page 8 during the 1982 refueling outage, a large effort will be initiated to properly prioritize all computer alarms. In conjunction with that effort, the control room annunciators will also be receiving very detailed reviews with the intent to provide a more useful alarm system to the operator. This increased effort to evaluate control room annunciators and computer alarms is beginning now and will continue indefinitely until the alarm system meets the operators' needs.

PLANT STATUS CONTROLS PERFORMANCE OBJECTIVE: Maintain plant status in a condition that emures equip-ment and system availability as necessary for safe and reliable plant operations at all times.

Finding Uncontrolled notes, graphs, portions of procedures, labels, and (OP.5-1) drawings of a temporary nature used as operator alck are attached to control panels at varios plant locations. A method is needed for approving, reviewing, updating, or verifying these tempora y messages.

Recommendation Evaluate the need for this material and remove material not considered necessary. Develop a system to control the use of approved and dated notes, graphs, and drawings and periodicaliy review these documents for currency.

Response A Special Order will be written by January 31, 1982 to cover placing of notes, graphs, portions of procedures, etc., used as operator aids on control panels or at local equipment areas. A_ll such information will be approved, initialed, and dated by the Operations Engineer / Operations Supervisor. The Operations De-partment will conduct specific tours of the unit quarterly to audit all local information to ensure it is up to date.

I Finding Improved control of the "Information Only" tagging system is (OP.5-2) needed. "Information Only" tags located throughout the plant are often unreadable, outdated, and left in place following the comple-tion of associated maintenance.

Recommendation Review current controls governing the "Information Only" tagging system and make changes as required to prevent obsolete and unreadable tags from remaining in place. Remove inappropriate

DAVIS-BESSE (1981)

Page 9 tags currently in place and provide for periodic in-plant checks to ensure the system is operating as intended.

Response Minor revisions have been mace to AD 1803.00, Safety Tagging Procedure and AD 1844.00, Maintenance Procedure, to make them

, consistent with each other concerning the information tags, and to clarify when "Information Only" tags are hung, when they are removed, and who can remove them. The station superintendent has also met with the section heads to reiterate the station philosophy concerning these tags and the responsibility of the operators and maintenance people in being cognizant of infor-mation tags. The section heads, in their regular meetings with their people, have reviewed the procedure governing "Information Only" tags. Operations personnel will conduct a supervised walk-down of all major areas of the plant to remove obsolete "Infor-mation Tags" and to replace those in a poor material condition.

This will be completed by January 15, 1982. Periode checks will be made to ensure that the system is being properly usad.

SHIFT TURNOVER PERFORMANCE OBJECTIVE: Ensure a coatinuous and correct understanding of plant conditions at all shift operating posi* ions through proper shift turnover.

Finding Shift turnover procedures should be upgraded. The senior equip-(OP.6-1) ment operator, equipment operator, and auxiliary operator are not provided with a turnover checklist or similar mechanism defining pertinent information to be conveyed at shift turnover. Operators rely on logs, notes, and memory to pass on information. As a result comprehensive turnover of information is not ensured.

Recommendation Establish and implement turnover procedures for all operations department positions to ensure comprehensive and consistent turn-overs for all shift positions.

Response Station Operations AD 1839.00 will be strengthened to improve proper turnover for auxiliary operators / equipment operators / senior equipment operators at local work stations. A turnover checklist will be included. This will be implemented by January 31,1982.

l l

l

DAVIS-BESSE (1981)

Page 10 TAGOUT PRACTICES PERFORMANCE OBJECTIVE: Protect personnel and plant equipment by implementing effective tagout practices.

Finding A periodic review and audit of the status of tagouts should be (OP.7-1) conducted. Tags exist in the plant that are in a degraded condition, and no determination is made to ensure that tags that are no longer needed are removed.

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

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

a. Conduct redew of the tag index.

b. Verify the adequacy of tagouts.

c. Check the condition of posted tags.

d. Verify proper attachment of tags and position of tagged equipment.

e. Check for presence of unauthorized tags,

f. Check for tagouts remaining in effect beyond their need.

Response AD-1803.00, Safety Tagging Procedure, has been revised to require a periodic audit by Operations, which will provide the improve-ments suggested.

I

DAVIS-BESSE (1981)

Page 11 MAINTENANCE MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Support the performance of maintenance activities by providing adequate facilities and equipment.

Finding More effective use should be made of maintenance shop areas.

(M A.2-1) Equipment, parts, and material associated with numerous un-finished jobs occupy much of the work space. This situation exists both in the mechanical and I&C shops. Space 'o not provided for incomplete work that is held up while awaiting parts.

Recommendation Improve the storage and disposition of materials, par.;, and tools in and around shop areas. Consider constructing storage bins or areas for incomplete work. Provide for periodic inspections by manage-ment to ensure an optimum working environment in the shops.

Response The maintenance shops have undergone extensive housecleaning.

Storage bins are on order and are expected by March 1982.

Previous plans for additional caged areas for controlled storage are in the review process with final approval expected by August 1982.

Plans for long-term expansion of maintenance facilities are well underway, and groundbreaking for a new Personnel and Shop Facility is planned for the fall of 1982. Current management tours of work areas will continue and will stress a clean and efficient working environment.

Finding 'Ihe following Good Practice was noted: The Limitorque valve (MA.2-2) training assembly built by electrical shop personnel provides mean-ingful training to electricians and mechanics on maintenance problems associated with similar installations in the plant. The training assembly includes valve, operator, 440 volt breaker, op-erating control switches, and indicating lights.

l WORK CONTROL SYSTEM l PERFORMANCE OBJECTIVE: Provide an administrative control system within which equipment problems can be identified and reporteA, and safely and efficiently dispo-sitioned and documen*ed.

DAVIS-BESSE (1981)

Page 12 Finding Improvements are needed in the present method of managing (MA.3-1) pending work. A large number of outstanding work orders remain open. Work scheduling should place more consideration on assigned priorities. The status of outstanding Maintenance Work Orders and Work Requests is not tracked to expedite long-standing open items.

Recommendation Review each outstanding Maintenance Work Order and Work Re-quest to determine the current status. Those awaiting parts should be categorized and procurement expedited. Improved management techniques should be implemented to monitor the status of out-standing work and ensure timely completion. The methods adopted should be compatible with the computerized work control system being developed at the station.

Response A management person and a clerk have been assigned to this function. Their task is to review, consolidate, and close out the backlog of Maintenance Work Orders and Work Requeats. They are working with the cognizant system engineers to prioritize and schedule open work items. For the long term, the station will be implementing a computerized maintenance management system, which will allow for optimum tracking and monitoring of outstand-ing work.

Finding (MA.3-2)

'Ihe material condition of some systems, equipment, and com-ponents reflects a need for improved inspection techniques and deficiency identification methods. Examples of deficiencies ot>-

served include water, oil, air, and boric acid leaks; improper or burned out lamp indicators; radiation monitors showing no indica-tion of operation; open junction boxes; damaged or missing pipe insulation; inoperative or off-scale gauges; and unidentified valves and control switches.

Recommendation Develop a method for conductir.g more comprehensive material inspections. Translate the identification of deficiencies into applicable maintenance work orders for orderly correction and overall improvement in plant material condition.

Response Current managemt.nt toitrs will continue as established with a renewed emphasis placed on the identification of recurring types of deficiencies. The need to continue to report deficiencies via work requests will be reinforced to operations and maintenance person-nel so that appropriate action can be taken. Written instructions have been given to shift supervisors to have operators identify plant deficiencies via work requests. Management will monitor the foregoing to verify that improvement in plant material condition is being achieved.

l

DAVIS-BESSE (1981)

Page 13 PREVENTIVE MAINTENANCE PERFORMANCE OBJECTIVE: Optimize equipment reliability and performance to enhance plant safety and availability.

Finding The backlog of Preventive Maintenance (PM) work orders appears (M A.6-1) excessive. A control system to assure tracking and completion of deferred and overdue PMs is needed. During 1981, about two-thirds of the scheduled PMs have been completed for each month.

Of those completed, many were not done within the month scheduled.

Recommendation Upgrade the effectiveness of the preventive maintenance program by reevaluating the scope and depth of coverage. Objectively establish the type and frequency of preventive maintenance actions required to achieve safe and reliable plant operations and carry out the program as scheduled.

Response A Preventive Maintenance Coordinator has been designated to evaluate the PM program and to make changes necessary to upgrade its effectiveness. This person will work with the cognizant systems engineers to develop a more effective preventf ve mainte-nance program. Preventive maintenance tracking will be enhanced when 'he computerized maintenance management system is in-stalled. Current efforts to reorganize the present system should be completed by June 1982.

CONTROL OF MEASUREMENT AND TEST EQUIPMENT PERFORMANCE OBJECTIVE: Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.

Finding Control of measurement and test equipment (M&TE) needs im-(MA.7-1) provement. A significant percentage of I&C equipment is inoper-able, and storage and control of equipment needs improvement.

Recommendation Comply with the requirements of Davis-Besse procedures AD 1849.00, Measurement and Test Equipment, Control and Calibra-tion, and IC 2100.00, Test Equipment Calibration, to ensure the proper control of M&TE. Management should periodically observe instrument conditions, control, and usage to ensure adherence to established requirements.

DAVIS-BESSE (1981)

Page 14 Response The requirements of Davis-Besse Procedures, AD-1849.00, and IC 2100.00 have been reviewed with the cognizant personnel. Test equipment storage and segregation inadequacies have been cor-rected. In 1982, the maintenance department plans to add po',i-tions in each group to be specifically responsible for the control of tools and test equipment. Management will monitor as necessary to ensure that requirements are being met.

l

DAVIS-BESSE (1981)

. Page 15 RADIATION PROTECTION AND CIIEMISTRY A number of strengths were noted in radiological protection and chemistry. These included an effective radiation exposure reduction program, efforts to maintain low plant radiation levels by conscientious chemistry efforts, and actions to decontaminate auxiliary building areas. These strengths stem from the positive attitude of personnel to improve the plant's radiological protection and chemistry.

Discussed below are several findings and recommendations. The more important findings are in the areas of personnel contamination monitoring and in the dec.mtami-nation of the turbine building. The other findings an'd recommendations primarily involve improvements to current programs or efforts.

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

Finding The general orientation radiological protection training program (RC.2-1) needs improvement in the following areas:

a. Some information conflicts with the actual operating procedures used in the plant.

b. Plant employees are not required to demonstrate practi-cal abilities as a part of general orientation radiological protection training.

Recommendation The training department should include practical abilities in the general orientation radiological protection training program. The material taught should be upgraded to agree with actual desired plant practices.

Response Station procedures, which have been modified since the Radiologi-cal Protection Training Program was implemented, were being re-viewed prior to the INPO evaluation. Revisions to the program will be made. Items of significance will be covered in a standup format until the program is revised and updated.

The Chemist & Health Physicist vrill be responsible for transmit-ting significant procedure changes, policy changes, and reasons for changes to the General Training Supervisor for review and possible inclusion in the applicable program.

The Nuclear ' raining Department will develop a Practical Abilities prog %m for personnel requiring unescorted access into radiation

! access control areas. These practical abilities will include donning and removing protective clothing, entrance and exit exercise from i

a controlled area, and individual demonstrations of approved frisk-ing techniques. This program will be developed by February 1982.

DAVIS-BESSE (1981)

Page 16 Finding Two chemistry analyses performed during on-the-job trairdng w, te (RC.2-2) not consistent with procedural requirements. A qualified chemis-try technician was observed to skip steps in both dissolved oxygen and iron analyses while demonstrating reactor coolant chemistry for a trainee.

Recommendation Chemistry and health physics supervisors should emphasize the importance of following procedures during on-the-job training.

Instructors and trainees shoidd use procedures when performing analyses.

Response Step-by-step rocedure compliance is required at all times and will be re-emphasu ed to all chemistry and health physics personnel.

EXTERNAL RADIATION EXPOSURL PERFORMANCE OBJECTIVE: Minimize personnel external radiation exposure.

Finding A Good Practice was identified in that the plant's total collective (RC.4-1) radiation exposure (man-rem) is among the lowest for all plants in the last three years. The following factors contribute to this performance:

a. low plant radiation levels, which appear to result from conscientious chemistry efforts

b. detailed radiation exposure planning for work in radiation areas

c. effective use of portable shielding

d. a program of flushing crud traps

e. effective use of exposure reduction goals i

l l

i

DAVIS-BESSE (1981)

Page 17 1

{

INTERNAL RADIATION EXPOSURE l 4

PERFORMANCE OBJECTk/E: Minimize internal exposure due to radioactivity associ-ated with the plant.

Finding There is evidence of unexplained, very low level exposures to (RC.5-1) Iodine-131 during the April 1981 steam generator repairs. Al-though this did not result in any significant exposures, methods to minimize the probability of recurrence during similar steam gener-ator work planned for 1982 should be developed.

Recommendation Investigate the low level Iodine-131 exposures. Modify the protec-tion measures including changes in protective clothing, respiratory protection, training, and procedures as necessary.

Response The reason the slight amount of Iodine-131 was initially unex-plained was due to the fact that the concentrations were well below the established investigative levels. Subsequent investiga-tion revealed the activity detected was not the result of internal deposition, but resulted from skin contamination or contamination of the whole body munting system. A newly installed system will enable the evaluation and confirmation of results at the time of counting. Various protection measures have been modified as a result of experience gained during the steam generator repair.

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

Finding Additional efforts should be made to reduce solid radioactive waste (RC.7-1) volumes. The plant's program to segregate radioactive and non-radioactive waste in controlled areas, as described in Standing Order No. 22, is not being fully implemented. For example, nonradioactive packing materials, such as, cardboard boxes, are taken often into controlled areas unnecessarily.

Recommendation Enforce the requirements of Standing Order No. 22.

Response Compliance with Standing Order No. 22 will be more effectively pursued.

DAVIS-BESSE (1981)

. Page 18 Finding Planning nec& to be completed for the transfer of highly radioac-(RC.7-2) tive resins from the spent resin tank for disposal. The plant plans to empty the spent resin tank shortly after the next outage to perform needed modifications. Other plants have experienced the spread of radioactive contamination during resin transfer due to 4

inadequate planning and lack of proper transfer and solidification equipment. Due to long lead times to obtain such equipment, early planning is important.

Recommendation It is recognized that the plant has started planning for this work, including the purchase of a new pump. It is recommended that the plant promptly complete the development of an overall plan for the transfer and disposal of the spent resin.

Response The actual resin transfer and disposal work is being contracted out and will utilize the contractor's equipment. The station is waiting submittal of the contractor's procedure for review and approval by the station review board. A 10CFR50.59 review will be conducted prior to the resin transfer. The transfer will occur prior to the 1982 refueling outage.

RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Minimize contaminated equipment and areas in the 4

plant and minimize personnel contamination.

Finding Personnel monitoring for radioactive contamination nee & improve-(RC.9-1) ment to more positively ensure the detection of low levels of contamination. The portal monitors and hand and shoe monitor, used as the primary means of monitoring for personnel contamina-tion at the exit of controlled areas, are not sufficiently sensitive to ensure detection of low levels of contamination. Personnel are not required to monitor all parts of their bodies that may become contaminated. For example, chemistry technicians are required to monitor only hands and shoes after removal of gloves and shoe covers.

Recommendation Initiate the use of more sensitive instruments, such as pancake G-M probes, for monitoring the whole body for radioactive contami-nation at controlled area exits. Where practicable, expand the use of monitoring stations at the exits from contaminated areas within l controlled areas.

Response A procedure modification has been made detailing the require-i ments for portable monitoring devices of suitable sensitivity at l appropriate locations and for mandatory monitoring of body parts upon exiting contaminated areas.

l t ~ - - - - -

DAVIS-BESSE (1981)

Page 19 Finding Maintenance of radiological pesting needs improvement. For (RC.9-2) example, a labeled step-off pad was not removed when the exit from a contaminated area was changed. Radiological protection requirements posted in the chemistry laboratory were out-of-date.

Some barriers at entrances to contaminated areas were down and not visible.

Recommendation Stress the importance of the posting of radiation areas to plant employees and contractors. Emphasize the importance of not damaging radiation signs and barriers and contacting Radiological Protection if a radiation posting is down or not visible. Periodi-cally review controlled areas to ensure they are properly posted.

Response The recommended emphasis is ongoing, and, as the experience level of employees increases, their ability to observe and correct these problems should improve. Performance in this area will be monitored by station management.

Finding Continued decontamination efforts are needed in the turbine build-(RC.9-3) ing to eventually eliminate the need for protective cluhing.

Contaminated areas exist on three levels in the turbine building.

Some contamination is absorbed in the concrete and drain sumps.

Contaminated floor areas hinder operations personnel and could result in the spread of contamination during secondary plant leakage.

Recommendation Decontaminate areas in the turbine building as much as practi-cable. Seal remaining activity into the cement. Flush or chemi-cally decontaminate the drains and sumps in the contaminated areas.

Response  !

The recommendations suggested, with the exception of sealing, are ongoing. The areas continue to exist because of a small primary- l to-secondary leak in a steam generator. Planned steam generator work during the 1982 refueling outage should alleviate the con-tamination problem, at which time any residual contamination will be sealed in the cement.

DAVIS-BESSE (1981)

Page 20 CilEMISTRY PERFORMANCE OBJECTIVE: Ensure accurate measurement and effective control of chemistry parameters.

Finding 'Ihe plant's chemistry program needs improvement in the following (RC.10-1) areas:

a. Reactor plant make-up from the water treatment system.

The plant has been unable to routinely meet vendor make-up water chemi-try specifications for dissolved oxygen.

Dissolved oxygen nas been higher that 2.0 ppm while the vendor specifications is 0.1 ppm. '

b. Verification of technician proficiency. Spiked samples with concentrations unknown to technielans should be used to verify that they can accurately perform chemistry analyses. Known standards are used to verify proper laboratory equipment operation.

Recommendation Repair the degassifier used in the water treatment system. Check for leakage of oxygen through the plant make-up pump glanch and diaphragms on tanks. Develop a program of spiked samples for the nonradioactive chemistry analyses. The spiked samples should include concentrations unknown to the technicians. The spiked sample test should be administered to the technicians periodically.

Response The degassifier repairs have been completed. Efforts are now directed toward locating and repairing any air or vacuum leaks.

The station recognizes the importance of having makeup water with low dissolved oxygen concentrations.

The spiked sample analyses have been added to the qualification program as recommended.

I

DAVIS-BESSE (1981)

Page 21 TECIINICAL SUPPORT NUCLEAR OPERATING EXPERIENOC EVALUATION PROGRAM

~ PERFORMANCE OBJECTIVE: Ensure industrywide and in-hotase operating experiences are evaluated and appropriate actions are taken to improve personnel awareness and equipment reliability.

Finding The method for promptly notifying other utilities of significant (TS.3-1) (vents with generic implications needs improvement.

Recommendation Provide guidelines to the individuals responsible for screening in-house events to assist them in determining which items should be generically significant. Use a system such as NOTEPAD to transmit information in a timely manner.

Response As part of the transient assessment program (TAP), NOTEPAD is used to transmit the details of station transients to other B&W plant owners. TED activities in the TAP are not yet covered by a formalized procedure. Such a procedure is being written and will be expanded to describe use of NOTEPAD for the notification of all utilities for those events that could be considered generically significant to more than just B&W units. This procedure should be in effect by the return to power following the 1982 refueling outage.

Finding Toledo Edison Company has conducted a good review of recommen-(TS.3-2) dations included in Significant Operating Experience Reports. For record purposes the SOER status for 80-1 through 80-6 and 81-1 through 81-14 is as follows:

Recommendations Action Taken 39 Satisfactory 35 Not applicable 7 Pending The recommendations pending actions are as follows:

SOER NUMBER Recommendation NUMBER 81-3 2 l 81-8 1 81-10 1 81-12 1,2,4a,4b

-w w

DAVIS-BESSE (1981)

Page 22 Recommendation Initiate further review or complete action as appropriate on SOER recommendations listed on the previous page. Advise INPO of the status of each recommendation in the response to this report. .

Response The engineering review for the seven outstanding recommendations is still in progress to determine the best course of action. An update of the status of these recommendations will be provided in TED's follow-on responses.

PLANT MODIFICATIONS PERFORMANCE OBJECTIVE: Provide a program to implement plant modifications in a timely manner while maintaining the quality of plant systems and components.

Finding The program for handling jumpers and lifted wires needs review.

(TS.4-1) Not all applications of jumpers or lifted wires receive an indepen-dent technical review prior to installation. In addition, several hundred jumpers or lifted wires have been in effect for an extended period of time and not all are being processed as permanent plant modifications.

Recommendation Utilize a technically knowledgeable individual (or individuals), in addition to the Davis-Besse Taggin

• Supervisor, in the review process for authorizing proposed jumpers or lif ted wires.

Conduct a technical review of the jumper / lifted wire log to minimize long-standing temporary modifications. Entries that cannot be eliminated by restoration to the original condition should be processed as permanent modifications to ensure drawings and procedures are updated to reflect an accurate configuration of the plant.

Response The station has requested information regarding other plants' methods of handling jumpers and lifted wires. Upon receipt, the station will review these methods for possible ways of improving the exiting system. This review should be complete within three months of receipt of the requested material.

Comment: INPO will provide a Good Practice on the handling of jumpers and lif ted wires by January 15,1982.

l

DAVIS-BESSE (1981)

Page 23 Finding Improvements are needed in the design change program to ensure (TS.4-2) plant modifications are implemented in a timely manner. Many Facility Change Requests (FCR) are backlogged in various stages of review, approval, and implementation. The problem is recog-nized by Toledo Edison and various actions are being taken to reduce the backlog.

Recommendation Continue current efforts to reduce the backlog. Suggest considera-tion of the following:

a. Conduct a critical review of all outstanding FCRs and' cancel those no longer considered necessary.

b. Assign one individual the responsiblity for tracking and controlling each FCR from initial approval through imple-mentation.

c. Reduce the workload on the Maintenance Section by procuring materials and developing detailed test proce-dures prior to FCR package transmittal to the station.

d. Consider delegating authority to on-site groups for review, approval, and implementation of certain cate-gories of FCRs.

e. Establish procedures for conducting periodic management reviews of the design change process and recommending improvements.

Response The following comments address specific INPO recommendations:

a. Regular periodic meetings will be held to review FCRs and provide disposition (i.e., void or schedule for imple-mentation).

b. The Facility Engineering Department Administrative Supervisor has been assigned responsibility for the FCR Processing System and for tracking the progress of FCRs from initiation through close-out.

c. AD1845.00 is to be revised to delete the requirement for safety review of procurement documents / specifications as j part of the FCR process. This change will allow procure- <

ment to proceed independently and earlier than FCR ,

transmittal to the station. Organization changes that l would centralize the requisitioning of FCR materials are .

being evaluated. )

l In the future, FCR packages will be released earlier so that more time will be allowed for development of test procedures by the station. It is expected to achieve this earlier release by improved planning, improved organiza-tional resources, and revision of the AD 1845.00 proce-dure.

l J

DAVIS-BESSE (1981) I Page 24 l

d. Revisions to AD 1845.00 are being considered to authorize the on-site Facility Engineering Department to process certain non-safety-related FCRs which do not require off-site involvement.

c. Consideration is being given to establishing procedures for periodic reports on the status of the design change process. These reports would be provided to senior management.

TED management will continue to monitor the effective-ness of the administrative system (AD 1845.00) that controls the design change process. Improvements will continue to be made as required.

Finding The written program for implementing plant modifications should (TS.4-3) include provisions for conducting operator training and fce updating control room drawings prior to placing modified systems in service.

Recommendation Strengthen administrative controls to ensure that training of shift personnel is complete prior to placing a modified system in service.

Establish controls to incorporate drawing revisions into the draw-ings used by operators prior to placing modified systems in service.

Response A method to ensure that station drawings are revised in a timely manner has already been developed and will be incorporated into AD 1848.05, Control of Drawings and Instruction Manuals. To help ensure that station operators receive appropriate training on up-coming system modifications, a new method of summarizing the details of plant modifications and transmitting those summaries to the Training Department has been established and will be incor-porated into AD 1845.00. With these summaries, the existing training program is adequate to ensure proper operator training.

These approved procedure changes should be completed prior to the 1982 refueling outage. The intent of the above changes is to ensure that the required operator training and drawing changes are completed concurrently with the modified system being placed in service.

I

DAVIS-DESSE (1981)

Page 25 1

ON-SITE REACTOR ENGINEERING PERFORMANCE OBJECTIVE: Optimize nuclear reactor operations without compro-mising design or safety limits, and control nuclear fuel handling (clivities to ensure safety of personnel and equipment. l I

i Finding Important parameters on the plant process computer need to bc (TS.5-1) independently checked and verified periodcally. Procedures do exist on how to conduct backup calcuations on some computer parameters. Ilowever, there are not guidelines to compare the computer parameter and the backup calculation on a periodic basis.

Recommendation Establish guidelines to accomplish the following:

a. Define which computer parameters or calculations are important to plant operation.

b. Provide a backup method to independently verify the computer parameter or calculation.

c. Provide for a periodic check between process computer and backup method results.

Response A review of plant process computer calculations will be performed to determine those calculations and outputs that should be periodi-cally evaluated. A formalized periodic test procedure will then be written to perform the required comparisons. These actions should be completed by the return to power following the 1982 refueling outage.

DAVIS-BESSE (1981)

Page 26 ORGAN 17.ATION AND ADMINISTRATION ORGANIZATIONAL OBJECTIVES l PERFORMANCE OBJECTIVE: Establish mission, goals, and objectives for the organi- '

zational units that improve plant activities or maintain them at Idgh levels of safety and reliability, and establish the process to ach! eve the mission, goals, and objectives.

Finding Although the overall station mission and objectives have been (O A.1-1) established, a supporting system of goals and objectives has not been developed by each section. Station objectives relating to availabilities, reportable events, lost time accidents, ALARA, and non-compliance have been assigned; however, only one section has established its own objectives. Specific objectives, goals, and milest aes need to be developed at the section level to help ensure achievement of the overall station objectives.

Recommendation Develop goals and objectives for each section in support of the station objectives. Implement the overall program including mile-stones and methods of review and feedback.

Response Station Area Heads have been directed to work with their people to develop specific area supporting goals. These goals are to be finalized and promulgated by January 1,1982. The overall review and feedback process of these goals should be developed and implemented by July 1982.

MANPOWER RESOURCES PERFORMANCE OBJECTIVE: Ensure that qualified individuals are available to fill all job positions supporting plant safety and reliability.

Finding Written qualification requirements need to be developed for senior (O A.3-1) staff positions. Although subordinate job position descriptions generally contain qualification requirements, those of senior staff positions do not.

Recommendation Establish written qualification requirements for each job position that affects plant safety and reliability.

Response All staff positions will be reviewed, and required position qualifica-tions will be developed where necessary. This process will be completed by September 30,1982.

_ ..--,---...._---..r--e

D AVIS-BESSE (1981)

APPENDIX Page1 APPENDIX Performance Objectives Reviewed TRAINING AND QUALIFICATION TQ.1 Training Organization Provide a clearly defined training organization staffed with qualified personnel capable of accomplishing all assigned training tasks.

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

TQ.3 Training Facilities and Equipment Provide the training facilities, equipment, and materials for development and evaluation of knowledge and skills needed by nuclear plant personnel.

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

TQ.5 Licensed Operator Training Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.

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

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

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

l

DAVIS-DESSE (1981)

, APPENDIX Page 2 OPERATIONS OP.1 Operations Organization and Administration Provide a clearly defined operations organization that is adequately staffed, assigns responsibilities, and delegates adequate authority for the accomplish-ment of required tasks.

OP.2 Operations Facilities and Equipment Provide plant facMities and equipment that are operated and maintained at a leve! to support safe and efficient operation.

OP.3 Conduct of Shift Operations Ensure that shif t operations are conducted in a safe and reliable manner.

OP.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of written procedures.

O P.5 Plant Status Controls Maintain plant status in a condition that ensures equipment and system availability as necessary for safe and reliable plant operations at all times.

O P.6 Shif t Turnover

Ensure a continuous and correct understanding of plant conditions at all shift operating positions through proper shift turnover.

OP.7 Tagout Practices l Protect personnel and plant equipment by implementing effective tagout practices.

MAINTENANCE l

l M A.1 Maintenance Organization and Administration Provide a clearly defined maintensace organization that is adequately staffed, assigns responsibilities, and delegates adequate authority for the accomplish-ment of required tasks.

MA.2 Maintenance Facilities and Equipment Support the performance of maintenance activities by providing adequate facilities and equipment.

l

DAVIS-BESSE (1981)

APPENDIX Page 3 MA.3 Work Control System Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently dispositioned and docu-mented.

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

M A.5 Maintenance IIIstory Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvements in equipment performance.

M A.6 Preventive Maintenance (PM)

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

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

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

M A.8 Control of Special Processes Ensure that the control and performance of special processes yields quality results. -

RADIATION PROTECTION AND CHEMISTRY RC.1 Management of Radiological Protection Provide effective management of the radiological protection program.

RC.2 Radiological Protection Training Ensure that personnel on the site have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

RC.3 Personnel Dosimetry Accurately determine and record radiation exposures.

RC.4 External Radiation Exposure Minimize personnel external radiation exposure.

1 l

DAVIS-BESSE (1981)

APPENDIX Page 4 RC.5 Internal Radiation Exposure Minimize internal exposure due to radioactivity associated with the plant.

RC.6 Radioactive Effluents Minimize releases of radioactive effluents to the environment.

RC.7 Solid Radioactive Waste Mini nize solid radioactive waste volumes.

RC.8 Transportation of Radioactive Material Meet the requirements for transportation of radioactive material.

RC.9 Radioactive Contamination Control Minimize contaminated equipment and areas in the plant and minimize person-nel contamination.

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

TECHNICAL SUPPORT TS.1 On-site Technical Support Organization and Administration Have a clearly defined on-site technical support organization that is adequately staffed, assigns responsibility, and delegates adequate authority for the accom-plishment of required tasks.

TS.2 Plant Efficiency and Reliability Optim:ze plant thermal efficiency and reliability.

TS.3 Nuclear Operating Experience Evaluation Program Ensure industrywide and in-house operating experiences are evaluated and appropriate actions are taken to improve personnel awareness and equipment reliability. l TS.4 Plant Modifications Provide a program to implement plant modificatiors in a timely manner while maintaining the quality of plant systems and components.

1 I

DAVIS-BESSE (1981)

APPENDIX Page 5 TS.5 On-site Reactor Engineering Optimize nuclear reactor operation without compromising design or safety limits and control nuclear fuel handling activities to ensure safety of personnel and equipment.

ORGANIZATION AND ADMINISTRATION OA.1 Organizational Objectives Establish mission, goals, and objectives for the organizational units that improve plant activities or maintain them at high levels of safety and reliability, and establish the process to achieve the mission, goals, and objectives.

OA.2 Organizational Structure Provide an organizational structure that supports the effective management of nuclear power plant operation.

O A.3 Manpower Resources Ensure that qualified individuals are available to fill all job positions supporting plant safety and reliability.

OA.4 Administrative Controls Provide well-defined, organized, and effective administrative controls to direct the tasks, responsibilities, and practices within the organization to met the specified mission, goals, and objectives.

OA.5 Management Quality Programs Provide management with accurate indication of the extent of adherence to policies, administrative controls, codes, regulations, and effectiveness in meet-ing plant mission, goals, and objectives.

OA.6 Surveillance Program Provide surveillance programs to accomplish coordinated monitoring, inspec-tion, and testing to ensure safe, reliable operation of plant equipm.ent and facilities.

l OA.7 Industrial Safety l

Provide an orderly working environment in which station personnel may carry out their work activities safely. . l l

i l 2 1 C.*"*"**

• T.

1'7%*.PT'.'f ****, "*" T. ,'Z",*.~.,% 7.J.*EOO" T '".'.*.*.,0 %l'.".'13.%*.""Z"%I. j

z==.=.=::r ~

--m.~

=:=.;,,a,a ::.u ::.=:==:,~ :.:=: z;::~. ::=:=::

Pr.wed e U S A l