ML20052G943
| ML20052G943 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/11/1982 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| Shared Package | |
| ML20052G940 | List: |
| References | |
| NUDOCS 8205190174 | |
| Download: ML20052G943 (33) | |
Text
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1982 Evaluation FO an
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TROJAN NUCLEAR PLANT v
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@ 1982 Institute of Nuclear Power Operations. Limited reproduction by INPO members and participants for internal company use is permitted.
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TROJAN (1982)
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SUMMARY
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1 INTRODUCTION p
The Institute of Nuclear Power Operations (INPO) conducted its second evaluation of Portland General Electric Company's (PGE) Trojan Nuclear Plant during the weeks of f
January 11 and 18,1982. The station is located on the Columbia River near Rainier, 1
Oregon, and has an 1130 Mwe (Net) Westinghouse pressurized water reactor. The unit began commercial operation in April 1976.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas 4
needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews cf documentation.
The INPO evaluation team examined station organization and administration, oper-I ations, maintenance, technical support, training and qualification, radiological pro-tection, and chemistry. The team also observed the actual performance of selected y
evolutions and surveillance testing. Corporate activities were not included in the scope j:
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 seven areas examined; these were applied and evaluated in light of both the experience
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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 1
excellence in all phases of nuclear plant operation. The conditions found in each area are compared to best practices, rather than to minimum _ acceptable conditions or requirements.
Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance.
DETERMINATION Within the scope of this evaluation, the team determined that the plant is. being operated in a safe manner by well qualified personnel.
Certain beneficial practices and accomplishments were noted:
The station goals and objectives program is well implemented and highly effec-tive.
The clean and orderly condition of the auxiliary building and the.small number of contaminated areas provide case of access and a good working environment.
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The qualification and experience Icvel of shift personnel is impressive. The licensed operator training pro' gram is exceptionally effective, as indicated by the high success rate of license candidates.
TROJAN (1982) y Page 2 The overall material condition of the plant is impressive.
The maintenance foremen's experience level, proper use of maintenance history, and an excellent
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valve preventive maintenance program contribute to this effort.
Improvements were recommended in a number of areas. The following are considered
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to be among the most important:
More timely follow-up is needed in resolving identified equipment or design problems.
Increased management attention is needed in three aspects of radiological y
protection: compliance ;vith existing procedures, clarification of some work controls, and training for personr.el who perform radiological work.
Steps should be taken to alleviate the overcrowded working conditions in the I&C, Radiological Protection, and Chemistry work areas. Two of these areas were o
noted as needing improvement during the previous INPO evaluation.
It is d
recognized that PGE has current plans to provide improved facilities.
In each of the seven areas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria.
All PERFORMANCE OBJECTIVES reviewed
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during the course of this evaluation are listed in APPENDIX II.
Findings and recommendations resulting from this evaluation are listed under the PERFORMANCE OBJECTIVES to which they pertain. Particularly noteworthy condi-m
~h tions that contribute'to meeting PERFORMANCE OBJECTIVES are identified as Good Practices.
Other findings describe conditions that detract from meeting the PERFORM ANCE-OBJECTIVES. It would not be productive to list as Good Practices those things that are commonly donc properly in the industry since this would be of no i
J benefit to Trojan Nuclear Plant 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
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conditions, pursue underlying causes and issues.
As a part of the second and succeeding evaluations of each station, the evaluation team will follow up on responses to findings in previous reports.
Findings with response actions scheduled for future completion have been carried forward in APPENDIX I to this report. In areas where additional improvements were needed, a new finding that
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stands on its own merit has been written. Thus, this report stands alone and reference to previous evaluation reports should not be necessary.
The findings listed herein were presented to PGE management at an exit meeting on
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January 20,1982. Findings, recommendations, and responses were reviewed with PGE and Trojan Nuclear Plant management on March 11, 1982.
PGE's responses are considered satisfactory, i
.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.
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The evaluation staff appreciates the cooperation received from all levels of Portland General Electric Company.
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PORTLAND GENERAL ELECTRIC COMPANY I
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Response Summary Portland General Electric (PGE) Company agrees with the INPO conclusion that the Trojan Nuclear Plant is being operated safely by well-qualified personnel and acknowl-edges the positive comments relating to plant goals and objectives, the clean and orderly condition of the plant, the qualifications of shift personnel, and the overall material condition of the plant.
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I PGE acknowledges that improvements can be made in a number of areas. Management has recognized the need to better coordinate the efforts of the plant staff with the corporate engineering staff to review and resolve significant equipment problems.
,1 Joint review groups are established when required. Management is closely following the resolution of identified equipment and design problems.
4 Additional attention is being focused on the plant radiation protection program by all levels of management. Additional management attention will be given to all aspects of radiological protection. Additional space is being provided in the Control Building to l
alleviate the overcrowded working conditions in the Instrument and Control, Radiologi-I cal Protection, and Chemistry work areas. Completion of these areas will begin the middle of 1982, with completion of the majority of the planned building modifications scheduled for January 1983.
A report will be prov'ided in six months identifying the status of actions completed or 4
planned, as noted in this report.
PGE appreciates INPO's efforts in evaluating the operation of the Trojan Nuclear Plant.
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U OPERATIONS 1
PLANT STATUS CONTROLS
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PERFORM ANCE OBJECTIVE: Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.
Finding The following Good Practice was noted: An effective method is (OP.3-1) used to identify normal and technical specifications limits of control board meter indications. A green band on the meter face shows the normal operating range, and a red band shows the technical specifications limits.
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1 Finding The folloiving Good Practice was noted: The station has an excel-(OP.3-2) lent system to identify safety-related equipment that is removed from service. A uniquely colored sheet for train A, train B, and
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non-train-related equipment is attached to the clearance sheet.
J The colored sheet provides for the following information:
a.
equipment to be removed from service J
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reason for and estimated duration of the outage l
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technical specifications relating to equipment d.
verifications required before removing equipment from service or returning to service e.
appropriate approvals j
Finding The following Good Practice was noted: Effective methods of (OP.3-3) communicating information to on-shift personnel are in use. The methods include a night orders book, which is updated daily by the operations supervisor with pertinent and useful information for operating personnel.
In addition, a Quarterly Events Report is issued with a summary of operating events and corrective actions that should be taken to help prevent similar events from recurring in the future.
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TROJAN (1982) i i
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s Finding A set of rounds sheets for auxiliary operators is needed to ensure
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(OP.3-4) important equipment is properly monitored. Provisions should also be made for recording and reporting out-of-specification or ab-i normal conditions.
l Recommendation Expand.the " Routines" program to provide more specific guidance to operating personnel making rounds and checking equipment.
Implement provisions for recording and reporting abnormal and i
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out-of-specification conditions.
Response
The present method for ensuring that important equipment is being properly monitored is via the Routines Notebook located in the 1*
shif t supervisor's office. These routines give a very detailed list of equipment and parameters to be monitored.
Maximum and minimum values for parameters are noted by colored markings on most instruments. Procedure AO-6 will be revised to require the operator to notify the control room whenever a e
parameter is found outside of the noted values or when other l
abnormal conditions are noted. It will also be required to record out-of-specification value on the operator's turnover sheet.
In addition, it will be required to note any routines not completed on the turnover sheet. This revision will be issued by April 1982.
A copy of the applicable watch station routines will be utilized as U
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. guidance by the operator when he makes his plant tour.
The operator will also carry the turnover sheet for use in recording out-of-specification parameters or abnormal conditions.
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TROJAN (1982)
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MAINTENANCE PLANT M ATERIAL CONDITION PERFORMANCE OBJECTIVE: The material condition of the plant should in main-tuined to support safe and reliable plant operation.
Finding Ventilation louvers are obstructed on a number of instrument (M A.2-1) cabinets containing heat-sensitive components. Plastic sheeting is taped over-the louvers in an apparent attempt to keep dust out.
Recommendation Survey all instrumentation, control, and switchgear cabinets to determine the extent of the problem.
Remove obstructing ma-t terial from louvers on panels containing heat-sensitive components g
and replace with appropriate filter materialif needed.
Response
The plastic sheeting that was obstructing ti.e ventilation louvers has been removed. In addition, craftsmen and plant operators have been reminded to be alert for such items that may have been installed due to temporary dusty work.
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1 WORK CONTROL SYSTEM a
PERFORMANCE OBJECTIVE: The control of work should ensure that. identified maintenance actions are properly completed in a safe, timely, and efficient manner.
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Finding The planning and scheduling of the instrument and control (I&C)
J (M A.3-1) shop preventive maintenance program needs improvement to en-sure that maintenance actions are completed in a timely and efficient manner.
This is a contributing factor to the current 3
J backlog of overdue preventive maintenance items.
Recommendation Develop and implement reliable schedules for preventive mainte-nance and test equipment calibration. Improve coordination be-tween I&C and off-site data processing groups to reduce I&C planning and scheduling problems.
Response
A review of the existing schedule will be made to identify errors and, as past-due items are found, the required preventive mainte-nance will be performed. This review will be completed by August
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1982, and all preventive maintenance and calibration checks will be current by December 1982. A study of -the current system and requirements is being conducted with the Corporate Data Services Department, which will result in improvements or replacement of the present system. This study will be complete and recommen-dations made by August 1982.
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CONDUCT OF M AINTENANCE PERFORMANCE OBJECTIVE: Maintenance should be conducted in a manner that j
ensures efficient and effective plant operation.
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Finding The following Good Practice was noted: The preventive mainte-(M A.4-1) nance repacking program for plant safety or reliability-related i
valves is highly effective. These valves are repacked on a periodic schedule, resulting in a low valve packing failure rate.
An exceptionally low incidence of valve packing leaks was noted during the evaluation.
MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Facilities and equipment should effectively support the j
J performance of maintenance activities.
Finding Improvement is needed in the level of order and cleanliness (M A.8-1) maintained in the plant maintenance shops.
Recommendation Assign specific area accountabilities and conduct shop inspections to promote and sustain improvement in shop order and cleanliness.
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Response
Shop cleanliness is being reemphasized with all maintenance work 3
groups.
Responsibility is assigned to appropriate department supervisors to ensure that shop areas are maintained in an ordered and clean condition. In the case of the I&C Shop and improperly stored equipment, the new shop facility will alleviate the problem.
It is expected that new shop facilities will be in use by January 1982.
-1 Finding Improvement is needed in the storage of selected spare parts.
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Some parts that are sensitive to environmental conditions are not adequately protected.
Recommendation Provisions to protect sensitive materials and components from adverse environmental effects should be reviewed for adequacy, including such measures as use of desiccants, sealed containers,
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humidity controls, and heating.
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TROJAN (1982)
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., Response All electronic instrument spares and circuit boards have been-wrapped and sealed. Future stock reorders for electronic compo-.
- f' nents will include requirements for supplying the items " packaged
. for long-term inside storage." Additionally, an evaluation of the company's commitment to Regulatory Guide 1.38 and ANSI N45.2.2 will be completed by June 1982 to determine if further actions are required.
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TECIINICAL SUPPORT
..,3 OPERATING EXPERIENCE REVIEW PROGRAM PERFORMANCE OBJECTIVE: Industrywide and in-house operating experiences should be evaluated and appropriate actions undertaken to improve plant safety and reliability.
Finding The review of some Significant Operating Experience Report (TS.3-1)
(SOER) recommendations needs to be improved. SOER recommen-dations were incorrectly assumed to be included in Significant Event Report (SER) reviews and as a result some SOER recommen-dations were not properly addressed.
I Recommendation Review each SOER recommendation to the depth necessary to ensure appropriate action is taken and recorded.
Response
An in-depth review will be conducted and documented for each specific recommendation included in an SOER. This review has now been completed for all SOERs issued to date.
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Finding Action on some recommendations included in SOERs has not been (TS.3-2) completed. Recommendation status for SOERs 80-1 through 80-6 and 81-1 through 81-17 is as follows:
Number of Recommendations Action Taken 36 Satisfactory 25 Not applicable 17 Pending
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16 Need Further Review The following recommendations are pending action:
SOER Number Recommendation Number 80-4 1,2,3
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81-4 2,2a,2b,3 81-15 la,1b,1c,2a,2b,2c,3 l
81-17 1,2,3 l
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TROJAN (1982)
Page 10 The following recommendations need further review:
SOER Number Recommendation Number 81-3 2
81-4 4
81-5 1, 2, 3, 4 81-6 1,la,2 1
81-7 1
J 81-9 2a,2b,2e 81-10 1
81-11.
4a,4b Recommendation Initiate further review or complete action as appropriate on SOER recommendation listed above. Advise INPO of the status of each
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recommendation in the response to this report.
Response
A review of all SOERs has been completed and actions have been
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initiated as appropriate.
An update on the status of these a
recommendations will be provided in the six-month progress report.
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Finding The following Good Practice was noted: The system used to track (TS.3-3) operating experience documents is very effective. The station's Required Action Tracking System (RATS) accurately tracks indus-try experience documents such as SOERs, SERs, IE Bulletins, Notices, Circulars, and Plant Review Board (PRB) commitments, and aids in ensu-ing that approved actions are taken. It also serves as an historica' record for these actions.
-3 PLANT MODIFICATIONS PERFORMANCE OllJECTIVE: Plant modification programs should ensure proper re-view, control, implementation, and completion of plant design changes in a safe and
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timely manner.
Finding In two important instances, plant design and operational problems j
(TS.4-1) are not receiving timely resolution.
These instances are listed below:
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emergency diesel generator (EDG) protective relaying l
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120VAC preferred instrument bus inverter reliability d
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Page 11 2
Recommendation Conduct a review of the EDG protective relaying circuit and the
. instrument bus inverter reliability problem. Evaluate the effec-i ti'.cness of proposed design changes and past maintenance prac-tices. Determine and implement appropriate actions to achieve proper and reliable operation of this important equipment.
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Response
A design change request has been initiated to correct problems with the emergency diesel generator protective relaying.
This design change is scheduled for completion duriLg the 1982 refueling i
outage.
A task ~ force consisting of members of the plant and corporate engineering staffs has been formed to review the problems with the j
inverters and establish a corrective action program. Initial actions are planned for the 1982 refueling outage.
In an effort to more effectively resolve plant design and opera-tional problems, the Company has instituted the conduct of join +
engineering / operations meeting on a regular basis to ensure that 7
proposed design change priorities are understood and properly communicated. In addition, more comprehensive reviews of LERs will be conducted, which involves off-site technical and licensing support to determine the root causes. These actions will improve a
the timeliness of review, control, implementation, and completion of design chnnges.
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3 Finding Station personnel do not always have "as-built" conditions indicated J
(TS.4-2) on drawings for completed modifications prior to returning revised systems to service. The existing process provides revised drawings 1
to the station within two working days of modification work com-pletion.
Recommendation Strengthen procedural controls to ensure that affected drawings marked to indicate the "as-built" status prior to placing are modified systems into service.
Response
Procedures will be revised to ensure drawings will be marked to reference correct data or be updated to reflect the as-built status of modified systems, prior to placing the system in service.
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Finding Some electrical jumpers / lifted Icads have been installed without an
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(TS.4-3) adequate technical review.
The administrative order for the bypass of safety functions requires that a safety review be completed; however, it allows the evaluation to be performed by l
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TROJAN (1982)
Page 12 U
the responsible supervisor or shift supervisor without an inde-pendent technical review.
3 Recommendation A technically qualified individual who is independent of the oper-ations department should be involved in the review process for authorization of proposed jumpers' and other temporary modifi cations. If there are selected jumpers / lifted lea'ds that can be authorized and performed by operations personnel, these should be T
specified in an administrative order.
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Response
The plant procedure for bypass of safety functions will be revised to require an independent technical review. This will be completed by May 1982.
J PLANT EFFICIENCY AND RELIABILITY MONITORING
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PERFORM ANCE OBJECTIVE: Performance monitoring activities should optimize plant J
thermal performance and reliability.
w Finding The scope of the existing plant performance monitoring program g
(TS.6-1) needs to be increased.
Some data is collected and trended; however, the data is not used effectively to improve plant perfor-
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mance.
Recommendation Expand and implement a more comprehensive program for plant
.1 performance monitoring with an objective of improving the plant operating efficiency and reliability.
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Response
The January 1982 INPO publication on Recurring Findings and
'~.A Recommendations and Good Practices has a number of recom-mendations for improving plant performance monitoring programs.
These recommendations will be reviewed and appropriate improve-ments, where warranted, will be implemented by January 1983.
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TROJAN (1982) i Page 13
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U TRAINING AND QUALIFICATION q
TRAINING ORGANIZATION AND ADMINISTRATION PERFORMANCE ODJECTIVE: The training organization and administrative systems should ensure effective control and implementation of training activities."
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Finding The following Good Practice was noted: The training department (TQ.1-1) is staffed with highly qualified licensed personnel with extensive t
operating experience.
Training staff personnel take an active j
interest in and periodically participate in operational activities.
These factors have resulted in a positive attitude toward training by operations personnel and directly contributes to the success of both the training and operations departments.
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NON-LICENSED OPERATOR TRAINING AND QUALIFICATION PERFORMANCE OBJECTIVE: The non-licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform g
assigned job functions.
Finding Non-licensed operator training for Rover, Turbine Building, and (TQ.2-1)
Auxiliary Building watchstanders needs to be expanded.
For example, additional coverage is needed in the following areas:
a.
power plant fundamentals b.
emergency and off-normal instructions c.
practical factors d.
safety system checkouts Recommendation Evaluate the previous training and experience of candidates to determine individual training needs in power plant fundamentals.
Evaluate the content and requirements of the watch station 1
qualification cards to identify needed improvements.
IN PO's
" Nuclear Power Plant Non-Licensed Operators - Guidelines for i
Qualification Programs" (GPG-04) could be of assistance in this area.
Response
The training program for non-licensed operators will be expanded to provide additional training in-those areas outlined in the finding.
Training in safety system checkouts will be implemented by May 1982 and the other areas by January 1983.
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TROJAN (1982)
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RADIOLOGICAL PROTECTION RADIOLOGICAL PROTECTION ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: The _ organization and administrative systems should ensure effective control and implementation of the radiological protection program.
Finding Station personnel do not always comply with radiological protec-tion procedures and requirements.
Examples include failure to (RP.1-1) frisk upon leaving contaminated areas, frisking improperly, not following procedures for respiratory protection af ter continuous air monitors alarmed, and not controlling respirators properly.
Communicate management's commitment to enforcing good radio-Recommendation logical protection practices to all station personnel, and require all supervisory personnel, especially those in maintenance and opera-The tions, to take an active role in enforcing this commitment.
l need to adhere to good radiological protection practices and procedures should be stressed in the training of plant personnel.
l The Company will continue to emphasize the need for procedure 1
Response
compliance by having all supervisory personnel, including opera-The tions and maintenance, take an active role in enforcement.
l Radiation Protection Department, through the Radiation Protec-tion Supervisor, will continually strive to upgrade the department's i
radiological protectica practices. Station management's commit-ment to the enforcement of good radiological protection practices will be communicated to all plant personnel during the annual retraining program.
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Practices and procedures to inform workers of radiological condi-Finding j
(R P.1-2) tions in work areas are not always effective; for example:
9 The posting of radiological conditions at the entrances of a.
radiologically controlled areas were sometimes incom-
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plete. Several such postings were not in plain view or had fallen down.
Radiation Work Permits (RWPs) are not routinely updated b.
to reflect changing radiological conditions.
1 RWPs rely excessively on oral instructions from chemistry c.
and radiological protection technicians to inform workers of needed protective measures in radiologically controlled areas.
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Recommendation Upgrade practices and procedures to more effectively inform workers of radiological conditions. The following actions should be included in this effort:
Provide area postings with complete radiological condi-a.
tions and requirements. Check postings periodically for accuracy.
b.
Take measures to ensure that in-use RWPs are updated when radiological conditions change.
a c.
Ensure that RWPs contain complete instructions.
Hasponse a.
A review will be made of methods and practices for posting radiological conditions of controlled areas to in-clude the following:
a 1.
Review the necessity, procedures, and the appro-priateness of materials and methods for posting radiological conditions with Chemistry and Radiation Protection Technicians (C&RP). This will be com-pleted by April 1982.
a 2.
Conduct surveillances of the posting practices of C&RP Technicians to ensure compliance with plant procedures and regulatory requirements on a weekly basis.
b.
RWPs will be updated as required to ensure workers are aware of changing requirements. This requirement has been communicated to the C&RP Technicians.
c.
The use of oral instructions will be minimized and RWPs will be updated as discussed above.
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e EXTERNAL RADIATION EXPOSURE A
PERFORMANCE OBJECTIVE: External radiation exposure controls should minimize personnel radiation exposure.
t Finding Neutren survey meters used to determine personnel exposures are (RP.4-1) not calibrated in accordance with standard practices. The neutron radiation source utilized has insufficient source strength to enable l
proper calibration.
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TROJ AN (1982)
Page 16 5
Recommendation Obtain sufficient NBS traceable sources to calibrate neutron survey meters on the scales used for measuring dose rates in plant.
Calibrate these meters to be consistent with manufacturer's in-structions and American National Standards Institute (ANSI) N323-1978.
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Response
The Company will acquire proper neutron radiation' sources or use an off-site calibration facility to perform required calibration of 1
neutron survey meters and will be consistent with ANSI 323-1978.
This will be completed by July 1982.
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SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Solid radioactive waste controls should minimize the volume of radioactive waste and ensure safe transportation of radioactive material.
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Finding Several practices that would result in a reduction of solid radioac-(RP.7-1) tive waste volumes should be implemented or emphasized.
Ex-amples of such practices are enumerated in the following recom-mendation.
i Recommendation Incorporate waste reduction methods into plant procedures and
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employee training programs.
Emphasize the minimization of material taken into radiologically controlled areas. Where practi-cal, segregate radioactive from nonradioactive material leaving controlled areas. Greater compaction ratios can be achieved with d
existing equipment by using a compression disc.
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Response
Current practices have resulted in sub :tantial reduction in waste volumes during 1981. A review of the recommendations will be y
made, and appropriate practices will be developed to further reduce waste volume. The general employee training program will be modified to include a discussion of techniques to reduce the generation of solid radioactive waste such as the minimization of material taken into controlled areas and ensuring that only radio-active materials are disposed of as radioactive waste.
These actions will be implemented by June 1982.
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TROJ AN (1982) p Page 17 PERSONNEL DOSIMETRY PERFORMANCE OBJECTIVE: The personnel dosimetry program should ensure that radiation exposures are accurately determined and recorded.
Finding The plant does not effectively use evaluations' of differences (RP.8-1) between pocket ion chamber (PIC) and thermoluminescent dost-meter (TLD) measurement to ensure the accuracy of dosimetry measurements. Although differences as high as a factor of two have occurred, actions to identify the causes and to prevent recurrence.wcre not evident.
Recommendation When acceptance criteria are not met, identify whether PIC results, TLD results, or the recording of exposure information is in Af ter the cause k " been identified, take corrective action
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error.
to prevent recurrence. L information should be documented and trended to determine if corrective action is effective.
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Present plant procedures will be fully utilized to evaluate differ-
Response
ences between PIC and TLD measurements for possible generic problems.-
Documentation of the investigations is now being
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generated and will be periodically reviewed by management to determine effectiveness in resolving problems.
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RADIOACTIVE CONTAMINATION CONTROL PERFORM ANCE OBJECTIVE: Radioactive contamination controls shouild minimize the contamination of areas, equipment, and personnel.
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Finding The plant experienced a large number of personnel skin and (RP.S-1) clothing contaminations during the last outage. Idientified correc-tive actions to reduce these instances have nct be:en implemented in all cases.
Recommendation Implement identified corrective actions prior to t'he next planned Review contamination incidents to monitcnr trends, identi-outage.
fy the underlying causes for problem areas and irmplement correc-tive action to reduce skin and clothing contamimations.
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management should be made aware of skin auf clotthing contamina-3
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tions, trends, causes, and the effectivenessuaf corrective measures.
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Response
A procedure defining radiation control practie es during plant s 3 refueling activities is being developed. T'nis procedure addresses previous problems and corrective actions. Thtis wrill be completed a
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by April 1982 and implemented during the r?nfweling outage.
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Page 18 I
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Plant management will continue to review skin and clothing
!,j' contaminations on a weekly basis via the Radiation Protection Department's weekly report. This report will be used to determine corrective actions and to require further information, if necessary, s
concerning the reported contaminations.
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t Finding Several pra~ctices for the handling and storage of radioactive waste (RP.9-2) have the potential for the contamination of personnel and the These include
' s unnecessary spread of radioactive contamination.
the following:
f compacting radioactive waste in a crowded room with a.
double doors open to a high traffic passageway b.
t'hihandling of waste drums prior to monitoring for loose surface contamination by personnel without protective I
q clothing a
open bags of radioactive waste in noncontaminated areas c.
1 the mixing of trash and used protective clothing which d.
J require sorting prior to processing Recommendation Consider expansion or relocation of the solid waste compacting This facility to provide adequate storage and working space.
facility should be completely enclosed with appropriate ventilation to reduce the potential for spread of contamination.
Review 1
current plant practices for handling radioactive waste. Emphasize proper practices to survey and handle contaminated materials in the training of those involved in radioactive waste handling.
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A proposal to build a new waste handling facility located adjacent
Response
to the fuel building train bay is under review.
The proposed 1
facility would provide for handling equipment and ventilation to
,J minimize the probability for spread of contamination. This review is expected to be completed by December 1982.
A review has been made of radwaste handling procedures with plant C&RP technicians and utility workers. This review stressed the requirement for adequate monitoring of all waste containers and to ensure that all waste bags are properly sealed and stored.
Whenever practical, sufficient containers will be placed at exit j]
areas to allow separation of protective clothing and trash.
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Page 19 CIIEMISTRY I
CIIEMISTRY CONTROL PERFORMANCE OBJECTIVE: Chemistry controls should ensure ' optimum chemistry conditions during all phases of plant operation.
x Finding The following Good Practice was noted: The plant maintains (CY.3-1) reactor coolant pli high in the range of vendor specifications. This practice minimizes plant radiation levels caused by crud build-up.
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LABORATORY ACTIVITIES PERFORMANCE OBJECTIVE: Laboratory and countingsroom activitics should ensure
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accurate measuring and reporting of chemistry parameters.
,j Finding The equipment used for the determination of iron and copper 3-(C Y.4-1) concentrations in secondary systems does not have required sensi-tivity. Minimum detectable concentrations for the equipment are greater than station limits.
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Recommendation Provide instrumentation that has sufficient sensitivity to accurate-ly determine iron and copper concentrations at or below specified limits.
Response
Use of flameless atomic absorption spectrometer (AA) technique
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will be implemented to lower the minimum detectable concentra-tions for iron and copper by August 1982. Interim samples will be h
taken and analyzed off site to the required sensitivity at least monthly until the AA technique is implemented.
>1 Finding Spiked samples are not used as part of the chemistry quality (CY.4-2) control program. It is recognized that a procedure was recently approved requiring the analysis of spiked samples. IIowever, this procedure does not adequately address the frequency and number of spiked samples which should be analyzed to ensure that techni-cians, who are rotated between chemistry and radiation protection groups, can accurately analyze routine samples.
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Recouymendation Require technicians to analyze spiked samples prior to assuming e'
S chemistry duties. In addition, expand spiked sample program to 9
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include other routine analysis such as lithium and silica.
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Response
The quality control program will be expanded to include lithium g
and silica.. Spiked samples are now being analyzed by all C&RP
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3 technicians on a specified frequency, regardless of assignment to
,._c chemistry or radiation protection.
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Finding Improvement is needed in the Icvel of order and cleanliness j
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(CY.4-3) maintained in the plant " hot" and " cold" chemistry laboratories, g
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j Recommendation The chemistry laboratories should be maintained clean and equip-1 ment organized to best support the analyses which are performed.
o Additional space should be provided for both laboratories for
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storage of equipment and material and to perform assigned duties.
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Response
Counting equipment has been moved from the " hot" laboratory to s
the counting room to relieve the crowded conditions in the " hot"
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laboratory.
By January 1983, we will have expanded our " cold" l'
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laboratory to relieve the crowded conditions at this location.
C&RP technicians will be instructed on good chemistry techniques y
and practices to help maintain laboratory cleanliness.
Also, a j
regular schedule for janitorial services with chemistry technician supervision has been implemented to improve general laboratory cleanliness.
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TROJAN (1982)
APPENDIX I Page 1 APPENDIX I Summary of outstanding response action from previous evaluation (1980) 1.
TRAINING RESOURCFE (INPO Procedure TQ-221, Rev.1)
Finding (Ref. Criterion F)
Training materials (system descriptions) and lesson plans have not, for the most part, been updated since they were developed during the cold license training program. Review of the system descriptions and lesson As a plan files showed outdated system descriptions and lesson plans.
result of using outdated material, instructor preparation time is signifi-cantly increased; lectures providing consistent, cohesive information are more difficult to achieve; and trainee confidence in self-study material accuracy is reduced, as is the incentive for self-study.
Some lesson plans have been updated by the training staff utilizing the inputs provided by the station's " Request for Plant Change" proced*pe.
Plant change information is routinely made available to the traiMog group.
Recommendation It is recommended that a program be developed and implemented to The review and upgrade the existing station systems descriptions.
ij' priority for upgrading the existing lesson plans should be raised to a level that will ensure all lectures are supported with site-specific materials.
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A long-range program should be developed for periodic review of system descriptions and lesson plans.
Response
of upgrading our lesson plans, which include system The program descriptions, will start in March 1981 and is expected to be complete by June 1982. A program for continued updating will be implemented as the lesson plans are upgraded.
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Status The initial upgrading program for lesson plans is currently on schedule and should be completed by the June 1982 target date.
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND j
2.
INSTRUMENTATION (INPO Procedure M A-406, Rev.1)
Finding (Ref. Criterion F)
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The storage of Instrument and Control (l&C) test equipment is crowded J
and does not meet the intent of this criterion in that conditions are not i
appropriate to maintaining instrument quality. Instruments kept in the shop were found stacked and non-segregated. Insufficient shelf space J
requires storage of some instruments on work benches and shop furni-Instrument storage located behind the control room consoles was ture.
also identified as an area warrantim, improved storage arrangement.
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Page 2 s
The intent of this criterion also was not satisfied in that test devices
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which are identified as out-of-specification are not provided a separate storage location to preclude their inadvertent use.
Action to improve the crowded shop facilities has been indicated by plans to include an expanded shop area in the new building addition now under construction.
Recommendation Provide expanded storage space for I&C test equipment to accommodate s
all of the controlled items. A separate storage area should be estab-T lished for rejected test devices to preclude their inadvertent use.
Response
2 Expanded storage space will be provided by expanding the I&C shop area.
This project will be completed by January 1983. The expanded shop will also allow the use of separate storage areas for rejected test devices.
The storage of I&C equipment outside the shop area has been improved, on an interim basis, by using locked storage cabinets.
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Status The overcrowded condition in the I&C shop area still exists.
A modification to the control building is in progress and is scheduled to be
,j' completed by January 1983.
JJ 3.
MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Rev.1)
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Finding (General Criterion) (Category II)
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A stock of repair parts and materials should be readily available to the maintenance organization. The materials indexing system in place at the plant warehouse is not adequately organized to permit timely location of
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items required in support of maintenance. The generic type indexing I
system being used does not effectively interface with the maintenance staff's capability to identify needed materials.
Trojan warehouse personnel have previously recognized this concern. A corporate representative from the computer management group has been brought on site for the purpose of preparing a proposal for an upgraded 3
inventory indexing system.
Additionally, the plant is reviewing a proposal for a computer-based maintenance management system that may address this area.
Recommendation Institute an improved system for locating parts and materials. The indexing of stock items should be made sufficiently flexible to promote
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efficient receipt and storage of materials as well as to provide a capability to quickly identify stock items from specifications or descrip-tions normally available to the maintenance organization. The ware-
'y housing reviews currently being performed by the plant should be pursued
,J as necessary to provide a timely resolution of this concern.
t Reponse Development of a computer-based Maintenance Management System is L) planned which will meet the above criteria. The portion of this system for identifying and locating parts and materials will be completed by January 1983.
TROJAN (1982)
APPEN DIX I Page 3 s
Status The manual material indexing system which is used for the location of repair parts and material is still in use.
A computer-based indexing system is being installed, and the materials management program is on schedule to meet the January 1983 completion date.
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RADIATION PROTECTION AND CIIEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Rev.1)
Finding (Ref. Criterion B) j s
l The plant and corporate procedures that address the conduct of opera-tions for radiation protection have not been revised to reflect the organizational changes that have occurred since the procedures were first prepared about two to three years ago.
Neither the corporate radiation protection program procedure (PGE 8005) nor the on-site f]
Radiation Protection Manual agree with the current on-site organization.
Plant Administrative Orders AO-1-5 and AO-1-8 do not include responsi-bility statements for the positions of radiation protection engineer, radiation protection specialist, radiation protection records coordinator, and radiation protection utility man.
It was noted that the radiation protection supervisor has made plans to H
revise the plant's Radiation Protection Manual in 1981.
Recommendation The Radiation Protection Manual, AO-1-5, AO-1-8, and PGE 8005 should
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be revised to reflect the actual plant organization and new corporate organization, where appropriate.
Response
j Changes have been made to administrative orders and to the Chemistry and Radiation Protection Manuals to reflect the current organization and current responsibilities. PGE-8005 will be revised by September 1,1981.
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Status Revision and issue of the Corporate Radiation Protection Program document, PGE-8005, is scheduled for March 1982.
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HEALTIl PHYSICS FACILITIES AND EQUIPMENT (INPO Procedure RC-509, Rev. 2)
Finding (Ref. Criterion C)
Existing health physics facilities are overcrowded and in some cases
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inadequate to support certain activities such as respirator decontamina-tion, instrument maintenance and calibration, counting instrument oper-ation and radioactive materials storage. The plant has initiated plans to modify the main access control area to improve the facilities there and
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obtain the most efficient arrangement of health physics functions possible within the limited space available.
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TROJAN (1982)
APPENDIX I 1
Page 4 Recommendation q
The planned reconfiguration of the access control area should considera-i' bly improve the efficiency of the health physics facilities in that area; however, since very little new space will be created, problems will still remain for some of t;:e areas mentioned. The plant should investigate the possibility of corserting more space within the auxiliary building to health physics use and of constructing additional storage space for
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radioactive materials.
Response
Additional space will be made available as a result of the control building modification. This will be complete by July 1,1982.
The process steam boiler area will be converted to a respirator mainte-nance area by July 1,1982.
A roof will be constructed over the outside radwaste storage area by July 1,1982.
Status Construction activities are continuing to provide additional space for health physics utilization. This work is scheduled for completion by the 1
end of 1982. Roof construction for the outside radwaste storage area has been deferred. Completion is expected by the end of 1983.
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APPENDIX II Page1 k
APPENDIX II 1
Performance Objectives Reviewed
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ORGANIZATION AND ADMINISTRATION i
OA.1 Station Organization and Administration Station organization and administrative systems should ensure effective imple-
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mentation and control of station activities.
I O A.2 Mission, Goals, and Objectives Station mission, goals, and objectives should be established and progress monitored through a formal program.
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l OA.3 Management Assessment and Quality Programs Management should assess station activities to ensure and enhance quality performance of all aspects of nuclear plant operation.
f O A.4 Personnel Planning and Qualification Personnel programs should ensure that station positions are filled by individuals with proper job qualifications.
OA.5 Industrial Safety j.l Station industrial safety programs should achieve a high degree of personnel safety.
OA.6 Document Control I
Document control systems should provide correct, readily accessible infor-mation to support station requirements.
OPERATIONS OP.1 Operations Organization and Administration The operaticns organization and administrative systems should ensure effective control and implementation of department activities.
OP.2 Conduct of Operations Operational activities should be conducted in a manner that achieves safe and reliable plant operation.
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TROJAN (1982) l]
APPENDIX II
~j Page 2 OP.3 Plant Status Controls 1
Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.
OP.4 Operations Knowledge and Performance Operator knowledge and performance should support safe and reliable plant operation.
OP.5 Operations Procedures and Documentation Operational procedures and documents should provide appropriate direction and
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should be effectively used to support safe operation of the plant.
OP.6 Operations Facilities and Equipment Operational facilities and equipment should effectively support plant operation.
MAINTENANCE M A.1 Maintenance Organization and Administration The maintenance organization and administrative systems should ensure effec-
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tive control and implementation of department activities.
M A.2 Plant Material Condition The material condition of the plant should be maintained to support safe and reliable plant operation.
M A.3 Work Control System The control of work should ensure that identified maintenance actions are i) properly completed in a safe, timely, and efficient manner.
M A.4 Conduct of Maintenance l
Maintenance should be conducted in a manner that ensures efficient and effective plant operation.
MA.5 Preventive Maintenance The preventive maintenance programs should contribute to optimum perform-l1 ance and reliability of plant equipment.
MA.6 Maintenance Procedures and Documentation
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l Maintenance procedures should provide appropriate directions for work and should be used to ensure that maintenance is performed safely and efficiently.
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TROJAN (1982)
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APPENDIX II Page 3 s
M A.7 Maintenance History The maintenance history should be used to support maintenance activities and optimize equipment performance.
M A.8 Maintenai.ce Facilities and Equipment Facilities and equipment should effectively support the performance of mainte-J nance activities.
-TECHNIC AL SUPPORT
' TS.1 Technical Support Organization and Administration
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The technical support organization and administrative systems should. ensure effective control and implementation of department activities.
j TS.2 Surveillance Testing Program Surveillance inspection and testing activities should provide assurance that equipment important to safe and reliable plant operation will perform within required limits.
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TS.3 Operations Experience Review Program Industrywide and in-house operating experiences should be evaluated and appro-
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priate actions undertaken to improve plant safety and reliability.
TS.4 Plant Modifications
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Plant modification programs should ensure proper review, control, implementa-tion, and completion of plant design changes in a safe and timely manner.
TS.5 Reactor Engineering
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On-site reactor engineering activities should ensure optimum nuclear reactor operation without compromising design or safety limits.
TS.6 Plant Efficiency aN Reliability Monitoring
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Performance monitoring activities should optimize plant thermal performance and reliability.
TS.7 Technical Support Procedures and Documentation
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Technical support procedures and documents should provide appropriate direc-tion and should be effectively used to support safe operation of the plant.
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TROJ AN(1982)
APPENDIX II Page 4 3
TRAINING AND QUALIFICATION TQ.1 Training Organization and Administratio_n The training organiz'ation and administrative systems should ensure effective control and implementation of training activities.
TQ.2 Non-Licensed Operator Training and Qualification The non-licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job functions.
TQ.3 Licensed Operator Training and Qualification The licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job funci%ns.
TQ.4 Shif t Technical Advisor Training and Qualification The shift technical advisor training program should develop and improve the knowledge and skills to perform assigned job functions.
TQ.5 Maintenance Personnel Training and Qualification The maintenance personnel training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job functions.
TQ.6 Technical Training for Managers and Engineers The technical training program for engineers and managers should broaden overall knowledge of plant processes and equipment as a supplement to position-specific education and training.
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TQ.7 General Employee Traiaing The general employee training program should develop a broad understanding of employee responsibilities and safe work practices.
l TQ.8 Training Facilities and Equipment The training facilities, equipment, and materials should effectively support training activities.
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R ADIOLOGICAL PROTECTION RP.1 Radiological Protection Organization and Administration The organization and administrative systems should ensure effective control and implementation of the radiological protection program.
TROJAN (1982) o APPENDIX II Page5 s
s RP.2 Radiological Protection Personnel Qualification The radiological protection qualification program should ensure that radiolog-ical protection personnel have the knowledge and practical abilities necessary to effectively implement radiological protection practices.
RP.3 General Employec Training In Radiological Protection General employee training should ensure that plant personnel, contractors, and visitors have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.
R P.4 External Radiation Exposure External radiation exposure controls should minimize personnel radiation ex-1 posure.
a RP.5 Internal Radiation Exposure Internal radiation exposure controls should minimize internal exposures.
RP.6 Radioactive Effluents Radioactive effluent controls should minimize radioactive materials released to the environment.
R P.7 Solid Radioactive Waste 1
Solid radioactive waste controls should minimize the volume of radioactive J
waste and ensure safe transportation of radioactive material.
RP.8 Personnel Dosimetry The personnel dosimetry program should ensure that radiation exposures are 1
accurately determined an<i recorded.
RP.9 Radioactive Contamination Control Radioactive contamination controls should minimize the contamination of areas, equipment, and personnel.
1 CHEMISTRY
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C Y.1 Chemistry Organization and Administration The organization and administrative systems should ensure effective imple-mentation and control of the chemistry program.
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TROJAN (1982)
APPENDIX II 1
Page 6 CY.2 _ Chemistry Personnel Qualification The chemistry qualific'a' tion program snould ensure that chemistry personnel have the knowledge and practical abilities necessary to implement chemistry practices effectively.
CY.3 Chemistry Control 1,
Chemistry controls should ensure optimum chemistry conditions during all phases of plant operation.
J CY.4 Laboratory Activities Laboratory and counting room activities should ensure accurate measuring and 1
reporting of chemistry parameters.
CY.5 Chemical and Laboratory Safety i
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Work practices associated with chemistry activities should ensure the safety of personnel.
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