ML20054A108
| ML20054A108 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/31/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| References | |
| NUDOCS 8204150290 | |
| Download: ML20054A108 (40) | |
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EVALUATION of ZION NUCLEAR GENERATING STATION Commonwealth Edison Company i
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ZION (1981)
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SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Commonwealth Edison Company's (CECO) Zion Nuclear Generating Station during the weeks of November 30 and December 7,1981. The station is located on Lake Michigan, approximately six miles north of Waukegan, Illinois. Unit 1 began commercial operation in October 1973, and Unit 2 began commercial operation in November 1974.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of documentation.
The INPO evaluation team examined station training, operations, maintenance, radio-logical and chemistry activities, on-site technical support, and organization and administration. The team also observed the actual performance of selected evolutions 1
l 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. 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 qualified personnel.
Certain beneficial practices and accomplishments were noted:
Management has recently identified and implemented improvements in many areas.
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The overall cleanliness of the auxiliary building is excellent and indicative of a strong effort to upgrade this area.
The non-licensed operator training program is detailed and comprehensive.
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ZION (1981)
Page 2 An aggressive program has been developed to promote employee involvement in the plant " Professionalism" (PRO) program.
Improvements were recommended in a number of areas. The following are considered to be among the most important:
The use of a device to disable multiple control panel audible alarms is of concern, and immediate corrective action is needed.
The instances of failure to follow procedures indicate that additional emphasis is needed to support station policies and procedures.
Some aspects of shif t turnover were superficial, and for some operators, watch-standing discipline needs improvement.
The material condition of the turbine building needs to be upgraded.
An improved preventive maintenance program is needed.
Better use should be made of industry significant event information.
Radiological control practices and procedures should be upgraded in the following two areas:
a.
minimizing the spread of contamination b.
dosimetry practices 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 the APPENDIX.
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 properly in the industry, since this would be of no benefit to CECO 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 CECO management at an exit meeting at Zion Station on December 11, 1981. Findings, recommendations, and responses were reviewed with CECO management on February 4,1982. CECO responses are considered satisfactory.
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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ZION (1981)
Page 3 The evaluation staff appreciates the cooperation received from all levels of Commonwealth Edison Company.
E. P. Wilkinson President l
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Page 4 COMMONWEALTH EDISON COMPANY Response Summary The Commonwealth Edison Company (CECO) is pleased that INPO found the Zion Nuclear Generating Station being operated in a safe manner. Commonwealth Edison appreciates INPO's constructive findings and recommendations and supports INPO's goal of utilizing this approach to achieve the highest possible standards of operation.
Commonwealth Edison also appreciates the " beneficial practices and accomplishments" noted by the evaluation team, in particular those relating to cleanliness in the auxiliary building, the excellence of our non-licensed operator training, and our aggressive involvement in the plant " Professionalism" (PRO) program. However, in addition, we recognize that there are areas needing improvement, and we will address those in a prompt manner. Our commitments to address areas needing improvement are shown in the responses to individual findings.
Commonwealth Edison has already taken action to implement changes in several areas as a result of the INPO evaluation and finding recommendations. In the several areas of the report where INPO noted Commonwealth Edison had already identified an area of concern and was taking corrective action, the actions will be re-evaluated in light of an outside perspective.
A specific response for each finding is contained in the body of the report. Where appropriate, Commonwealth Edison has identified target dates for completion of corrective actions. Commonwealth Edison will keep INPO advised of progress toward l
implementing its responses and welcomes INPO's review and assistance.
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Commonwealth Edison views the recommendations as a new source of ideas to be utilized in evaluating existing programs for continued improvements.
We appreciate the cooperation and dedication of your organization and are committed to the prompt completion of our corrective actions, l
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ZION (1981)
Page 5 TRAINING AND QUALIFICATION TRAINING ORGANIZATION PERFORMANCE OBJECTIVE: Provide a clearly defined training organization staffed with qualified personnel capable of accomplishing all assigned training tasks.
Finding The following Good Practice was noted: A comprehensive instrue-(TQ.1-1) tor development program is implemented. The program is based on position descriptions, task identifications, technical qualifications, and a detailed instructional skill qualification and development system.
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 The following Good Practice was noted: A comprehensive training (TQ.2-1) ability documentation system provides easily retrievable infor-mation for all plant employees. Examples of some of the specific forms used in this program are personnel resumes, training record reviews, training waivers, program evaluations, required reading status, performance reviews on licensed personnel, training defi-ciencies, and trainee evaluations. Additionally, the record man-agement system provides convenient and timely record entry and retrieval.
ZION (1981)
Page 6 SHIFT TECHNICAL ADVISOR TRAINING PERFORMANCE OBJECTIVE: Develop and maintain the skills and knowledge neces-sary for Shift Technical Advisors (STA) to perform their assigned job functions.
Finding The Shift Control Room Engineer (SCRE) Training Program has not (TQ.7-1) been fully implemented. Although supervisory skills subject matter has been identified and developed, SCREs have not received the training.
Recommendation Schedule and implement the developed supervisory skills programs.
Response
A structured SCRE training program has been developed at the corporate level and is in process of implementation. The final schedule for this training program will be published by April 1,1982. Training modules will begin to be implemented by May 1, 1982, and the program will be fully implemented by October 1,1982.
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Page 7 OPERATIONS
- OPERATIONS FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Provide plant facilities and equipment that are operated and maintained at a level to support safe and efficient operation.
Finding Announcements made over the public address system could not be (OP.2-1) heard or understood in all areas of the station. Speakers were muted, and the public address system was ineffective in some areas of the crib house, auxiliary, and turbine buildings.
Recommendation Implement a program to ensure that the public address system provides adequate coverage throughout the station.
Adjust in-stalled speakers and add additional speakers as determined by testing.
Response
A program for improvement of the public address system audibility in the plant is in place. Following the INPO evaluation, mainte-nance requests were issued to adjust existing speakers to ensure adequate coverage. This maintenance work will be completed by March 1,1982. In addition, the basic outage computer schedule has been revised to include readjustment of pagers after each outage.
A review of the need for additional speakers has been completed, and it was concluded that additional speakers are not required.
CONDUCT OF SHIFT OPERATIONS PERFORMANCE OBJECTIVE: Ensure that shift operations are conducted in a safe and reliable manner.
Finding The conduct of some control room operations personnel was not in (OP.3-1) accordance with best operating practices. Some operators ap-peared too casual in their approach to routine duties with the units operating at power.
Response to annunciator alarm conditions needs to be improved. Non-professional and other non-job-related reading materials were present in the control room, contrary to station procedures.
Recommendation Provide guidance and instructions to the control room operators on improved monitoring of control room panels. Increase management attention to the supervision of control room operations.
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Response
Good practices for the conduct of control room operations are prescribed in station administrative procedures. The requirement to adhere to these procedures has been re-emphasized at manage-ment meetings and with operators at weekly shift meetings. In addition, management and supervisory personnel will frequently monitor the conduct of control room operations.
Finding Multiple annunciator panel audible alarms are periodically disabled (OP.3-2) by use of a device to silence nuisance alarms. The device, placed over the annunciator pushbutton, disables the horn function for the nuisance alarm, the panel that contains the alarm, and some adjacent panels.
Recommendation Implement controls to prevent the use of this multiple alarm disabling device. Investigate methods for temporarily silencing the audible alarm for individual annunciators to reduce or eliminate the distraction of operators by repeated actuation of nuisance alarms. Establish a procedure to formalize the conditions under which nuisance alarms can be silenced.
Response
A modification request has been issued to Engineering to resolve the nuisance annunciator problem.
Engineering, parts procure-ment, and installation of the modification are oeing aggressively pursued. This modification will preclude the need for the annun-ciating disabling device in the future. A technical staff engineer has been assigned to deal with the arinunciator problem on a daily basis.
Procedural controls have been implemented that give directions for conditions under which nuisance alarms can be silenced.
Finding Control room operator logkeeping practices need to be improved to (OP.3-3) contain a descriptive chronology of events. Operating log entries are not always recorded by event sequence as required by station procedures.
Recommendation Review station procedures on logkeeping with all control room operators. Increase supervisory attention in the review of logs and require that procedure adherence be enforced.
Response
Station procedures on logkeeping will be reviewed and re-empha-sized at management meetings and at weekly operator shift meetings. In addition, management and supervisory personnel will
ZION (1981)
Page 9 monitor control room operations to ensure that procedures are followed. This action will be implemented by April 1,1982.
PLANT STATUS CONTROIE PERFORMANCE OBJECTIVE: Maintain plant status in a condition that ensures equip-ment and system availability as necessary for safe and reliable plant operations at all times.
Finding Uncontrolled notes and instructions of a temporary nature used as (OP.5-1) operator aids are attached to control panels and equipment at various plant locations. No method exists for approving, reviewing, updating, and verifying these temporary messages.
Recommendation Develop and implement a policy to control the posting of labels, curves, notes, and instructions. Include a mechanism to ensure
.that any necessary posted material remains current and reflects approved operating information.
Minimize the use of posted information.
Response
A program to control the posting of information around the station will be developed by July 1,1982, and will incorporate the items identified above.
In the meantime, uncontrolled notes and in-structions have been removed from all station areas. Material that must be posted will be reviewed, approved, and indexed prior to re-posting.
Finding Action is needed to reduce the number of control room annunci-(OP.5-2) ators that are normally in a lighted or alarmed condition during normal plant operation.
Recommendation Implement an aggressive program to reduce the number of annun-ciators that are normally in a lighted or alarmed condition during power operation.
Response
Zion Station has implemented an aggressive program to review alarm status and reduce the number of alarms that are normally in a lighted or alarmed condition during power operation. The status of this effort will be provided in the six-month follow-up report.
ZION (1981)
Page 10 SIIIFT TURNOVER PERFORMANCE OBJECTIVE: Ensure a continuous and correct understanding of plant conditions at all shift operating positions through proper shift t arnover.
Finding Shift turnovers are not always conducted in accordance with (OP.6-1) station procedures.
Turnover checklists were not initialed or completely filled out with pertinent shift status information. Some operators do not conduct an adequate verbal exchange of important information or walk down the control panels as part of shift turn-over.
Recommendation Require that all shift turnovers be conducted in a formal manner using completed checklists, good verbal exchange of information, and panel walk-downs as part of the turnover process. Encourage supervisory personnel to periodically monitor the turnover process.
Response
Station procedures define shift turnover policies. These policies will be reviewed and emphasized at the management meetings and at weekly shift meetings with operators.
This action will be completed by April 1,1982. In addition, supervisory personnel will frequently monitor shift turnovers to ensure that station policies are followed.
TAGOUT PRACTICES PERFORMANCE OBJECTIVE: Protect personnel and plant equipment by implementing effective tagout practices.
Finding Tagout procedures need to be expanded to provide for the periodic (OP.7-1) review of the status of tagouts. Although reviews of tagouts are periodically performed, the physical status of tags in the plant is not verified.
Recommendatio, Expand the tagout system to include a periodic review to ensure that tags are legible, posted on the right equipment, and removed when no longer effective.
Response
The tagout procedure will be revised by April 1,1982 to provide an in-plant verification of tag status. The scope and frequency of the review will be specified, along with corrective action require-ments.
ZION (1981)
Page 11 Findmg The size of yellow caution tags is too large for control board use.
(OP.7-2)
Tags are of a size that labels, indicating lights, and control switch positions can be obscured.
Recommendation Correct current conditions where tags are obscuring lights and switches. Investigate the use of smaller tags that will not obscure control board lights or switches.
Response
Efforts to obtain the smaller caution cards and procedures to implement their use are being pursued.
This action should be completed by June 1,1982.
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Page 12 MAINTENANCE WORK CONTROL SYSTEM PERFORMANCE OBJECTIVE: Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently dispo-sitioned and documented.
Findmg The portion of the work control system that utilizes equipment (MA.3-1) tags for the identification of plant deficiencies is often not properly utilized. Some plant deficiencies were tagged but had not been submitted as work items. Some deficiencies submitted as work items had not been tagged, and some old tags had not been removed after the completion of corrective maintenance.
Recommendation Emphasize the importance of attaching equipment tags to reported deficiencies, removing tags when corrective action is completed, and reporting deficient conditions that are not tagged. Periodi-cally monitor the equipment tagging practices for effectiveness.
Response
Station Administrative Procedures will be revised to more clearly define use of equipment tags. This procedure revision will be re-emphasized to affected station personnel and will be completed by June 1,1982. In addition, tagging practices will be periodically monitored to ensure that tags are being used correctly.
Finding Outstanding work is not always effectively controlled and (M A.3-2) reviewed. Work items sometimes remain outstanding on some im-portant plant systems for extended periods of time. Although priority A and B-1 jobs receive sufficient management and supervi-sory attention, work of a lower priority needs more effective review. A random sampling of mechanical work requests indicated that some had active duplicates and that others had been com-pleted under other work requests. Some work requests reviewed contained confusing or contradictory information.
Recommendation Institute a periodic review of outstanding work requests to ensure their timely completion, climinate duplicate or contradictory in-formation, and ensure prompt close-out of completed work.
Response
Work requests will be reviewed periodically by senior station management personnel. In addition, a review of work requests that are more than one year old will be conducted periodically by senior individuals in the Operations Department. This program will be formslized and implemented by June 1,1982.
ZION (1981)
Page 13 MAINTENANCE HISTORY PERFORMANCE OBJECTIVE: Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvements in equipment performance.
Findmg The maintenance history does not always contain sufficient detail (MA.5-1) to fully describe the circumstances, conditions, and significance of the maintenance activity to allow for meaningful evaluations of equipment performance and identification of persi. stent or recur-ring maintenance problems. The results of periodic tests, vibration analysis, and trending are not kept as a part of the history, nor are they referenced. Maintenance history is not being maintained in accordance with the current administrative procedure. In addition, the current administrative procedure needs review and updating.
Recommendation Review the current plant instructions on maintenance history and revise as necessary to obtain a more consistent and effective history. Include in the history important information concerning maintenance action or equipment problems.
Response
This item will be addressed in the station's preventive maintenance program. See response to Finding MA.6-1.
PREVENTIVE MAINTENANCE (PM)
PERFORMANCE OBJECTIVE: Optimize equipment reliability and performance to enhance plant safety and availability.
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Finding The preventive maintenance program should be defined to ensure (M A.6-1) proper coverage of all important plant equipment. Although the plant has established practices for trending and vibration analysis, the frequency and scope are left to the system engineer for non-l safety-related systems. Currently, the instrument air compressors are the only pieces of balance-of-plant equipment for which a complete review has been conducted and periodic preventive maintenance performed. A written procedure or instruction cover-ing the preventive maintenance program has not been issued.
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Recommendation Establish a formal, written preventive maintenance program. In-clude specific instructions for the use of trending and vibration analysis. As was done for the instrument air compressors, review l
Vendor manuals and operating experience and establish routine inspections, adjustments, and parts replacement for other major equipment and systems. Ensure that the program includes pro-visions for periodic review and adjustment.
ZION (1981)
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Response
The draft of the Preventive Maintenance Program - Zion Station, will be issued by May 1,1982. It will include utilization of mainte-nance procedures, tech staff surveillances, periodic tests, a lubri-cation program, a vibration analysis program, and a maintenance history program.
The PM program will be implemented by December 31,1982.
Finding Plant lubrication practices need review and improvement. Several (M A.6-2) pieces of equipment have not been lubricated within the frequency prescribed by the lubrication sheet. Other plant equipment, such as some motor-operated valves and frequently operated manual valves, is not included in the lubrication program. The lubrication program is not formalized by a descriptive written instruction or guideline.
Recommendation Establish a program to achieve the necessary lubrication of plant equipment. Review plant equipment lubrication requirements and establish lubrication frequencies. Include periodic reviews of the lubrication records to ensure that equipment is being lubricated as scheduled.
Response
This item will be addressed in the station's preventive maintenance program. See response to Finding MA.6-1.
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Page 15 RADIATION PROTECTION AND CHEMISTRY MANAGEMENT OF RADIOLOGICAL PROTECTION PERFORMANCE OBJECTIVE: Provide effective management of the radiological pro-tection program.
Finding Station personnel do not always comply with radiological protec-(RC.1-1) tion procedures or requirements. Examples include frisking tech-niques, donning and wearing of protective clothing, handling and surveying contaminated material, failure to frisk on leaving con-taminated areas, and failure of supervisors to correct violations.
Recommendation Communicate management's commitment to enforcing adherence to radiological protection (RP) practices to all station personnel.
Require that supervisory personnel more rigorously enforce station procedures and good RP practices. Stress the need for adhering to good RP practices during general employee training.
Response
Zion Station agrees that adherence to the radiation control stan-dards and RP procedures is essential for providing an effective radiation protective program. Station management will stress to all supervisory personnel their role in enforcing this policy.
In addition, this policy will be addressed in Nuclear General Education Training (NGET) as well as pre-outage meetings with station personnel. The posting of instructions and requirements will be evaluated and upgraded as necessary. Rad / chem personnel will be instructed to enforce RP procedure adherence throughout the plant. These actions will be completed by May 1,1982.
Finding The station Radiation Occurrence Reports (RORs) could be more (RC.1-2) effectively used to improve the radiological protection program.
For example:
a.
RORs are not currently being evaluated to determine trends or recurring problem areas.
b.
The corrective action taken in many cases appears to have had little effect in improving compliance with radiological protection procedures and requirements.
c.
The number of RORs written does not appear to be representative of the extent of radiological protection prcblems, and not all types of problems are covered by RO Rs.
ZION (1981)
Page 16 Recommendation Evaluate the Radiation Occurrence Report System. Implement the corrective actions identified to improve the effectiveness of this reporting system.
Response
Station management is taking an active role in reviewing all RORs.
Each ROR is evaluated on its merit and management response, and corrective action is pursued. The Rad / Chem Supervisor will review with all the rad / chem personnel what circumstances warrant initiating RORs. In addition, an ROR trending program will be initiated to facilitate follow-up corrective action. These items will be completed by May 1,1982.
Finding A formal mechanism is not currently used to identify radiological (RC.1-3) conditions and prescribe radiological protection requirements for many jobs in controlled areas.
It is recognized that a new Radiation Work Permit (RWP) system is being developed by the company.
Recommendation Proceed with plans to develop and implement a new RWP system.
This RWP system should specify radiological protection require-ments for work in contamination and radiation areas.
Response
A new RWP system, which encompasses this recommendation, is currently being discussed with the union within the rad control standards framework and will be implemented pending completion of the discussions. The status of this item will be provided in the six-month follow-up report.
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 Employees are not required to demonstrate practical abilities such (RC.2-1) as the donning and removal of protective clothing, proper frisking techniques, and the use of step-off pads during general employee training (GET).
Recommendation Expand the GET program to require that each employee demon-strates practical abilities in radiological protection.
ZION (1981)
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Response
The current GET class includes a videotape of the method for donning and removing protective clothing and for using step-off pads. The program will be revised to incorporate actual demon-strations of these techniques by personnel who have not previously worn protective clothing.
This revision will be completed by July 1,1982.
Finding Some radiological protection and chemistry technicians (RCT) need (RC.2-2) additional retraining in health physics and chemistry. Retraining for these personnel is currently scheduled to commence in January 1982. A comprehensive training program has been developed for new technicians.
The following examples support the need for improved retraining:
Some technicians were weak in their knowledge of chem-a.
istry theory.
b.
Some technicians utilized poor health physics and chemis-try practices.
c.
Retraining during 1981 was limited primarily to new equipment and procedure changes and to nonradiological and chemistry subjects.
Recommendation Proceed with current plans to implement retraining for the radia-tion chemistry technicians beginning in January 1982. The program should ensure retraining in health physics and chemistry on at least an annual basis for areas identified as weak or problem areas.
Changes in procedures, equipment, and operating conditions should also be included.
Response
Three weeks of RCT retraining is scheduled for 1982 and will include both health physics and chemistry areas. The retraining will be conducted annually and will address identified problem areas as well as changes in procedures, equipiaent, and operating conditions.
i ZION (1981)
Page 18 PERSONNEL DOSIMETRY PERFORMANCE OBJECTIVE: Accurately determine and record radiation exposures.
Finding The quality control program for personnel dosimetry has indicated (RC.3-1) a number of problems without apparent follow-up action.
The following are examples:
correlations between dosimetry measurements by pocket a.
ion chambers (PICS) and film badges b.
correlations between spiked film badge measurements and actual exposures complications in using film badges - the plant's use of c.
film badge measurements for legal exposure records com-plicates control of personnel exposure during outages because of the lengthy turnaround time required to obtain film badge measurements and some loss of data due to the inability to process contaminated badges d.
insufficient documentation of program evaluations Recommendation Improve the program for performing and documenting the results of evaluations in personnel dosimetry and for follow-up corrective action.
Determine the reasons for problems with correlations between dosimetry measurements by PICS and film badges and between spiked film badge measurements and actual exposures.
Evaluate the feasibility of changing from film badges to TLDs.
Response
Improvements in the quality control program for personnel dosi-metry are being undertaken by the Zion Rad / Chem Department.
Particular attention is being given to ensure that all evaluations made in clearing discrepancies between film badge results and self-j readers are being properly documented. Acceptance criteria and evaluatior.s for the spiked film badge program will be established.
These actions will be completed by June 15,1982.
Commonwealth Edison has evaluated replacing the film badge l
I system with a TLD program and has decided to make the change.
A schedule for implementation of the TLD program is under development.
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ZION (1981)
Page 19 EXTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: Minimize personnel external radiation exposure.
Findmg Use of recently developed exposure reduction techniques needs to (RC.4-1) be formally adopted by the station. ALARA efforts were recently initiated that included establishment of a station ALARA coordi-nator, issuance of a corporate ALARA program, and application of effective temporary shielding techniques to six recent high radi-ation level jobs. Procedures for ensuring the continued application of these techniques are needed.
Recommendation Address implementation of the new corporate ALARA program in station work control procedures.
Response
The corporate ALARA program will be implemented by December 31, 1982.
In addition, an ALARA checklist will be developed and inserted into the modification program to generate exposure reduction ideas in the planning of station modifications.
The checklist will be completed and implemented by October 1, 1982.
Finding Weaknesses were noted in the instrument calibration program as (RC.4-2) follows:
a.
inconsistencies between procedures and data sheets used for calibration b.
insufficient source strength for high range instruments c.
lack of a formal program to identify when instruments are due for calibration Recommendation Proceed with plans to purchase a new calibration source and the development of a program to identify when instruments are due for calibration. Review and modify calibration procedures to ensure consistency with data sheets.
Response
The procedures for instrument calibration will be revised by May 15,1982, to eliminate inconsistencies with the data sheets.
A 400 Ci Cs-137 source has been ordered, and a technical specifi-cation change to receive the source has been submitted to the NRC. Use of the source will be implemented upon NRC approval of the technical specification change.
ZION (1981)
Page 20 A computer program to document instrument calibration records and provide an automatic means to list calibration due dates is being developed and will be implemented as soon as possible. The status of this item will be provided in the six-month follow-up report.
INTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: Minimize internal exposure due to radicactivity associ-ated with the plant.
Finding Breathing air connections are not unigt'e to the breathing air (RC.5-1) system. It is possible to connect breathing air manifold supply lines to air and water supply lines.
Recommendation Modify breathing air connections so that only breathing devices can be plugged in.
Response
This situation will be reviewed by the Station Nuclear Engineering Department, and plans for corrective action will be provided in the six-month follow-up report.
Finding The plant's records of monitoring for internally deposited radio-(RC.5-2) activity indicate that many station personnel had low levels (well below established limits) of fission and corrocion products. Al-though the levels are only a small fraction of the established limits, the number of workers involved indicates the need for improving either contamination control or respiratory protection.
Recommendation Investigate the reasons for indication of low levels of internally deposited radioactivity and correct the cause.
As part of the investigation, evaluate both external radioactive contamination and actual internal deposition.
Response
Station whole-body count (WBC) results have been reviewed as part of a program to reduce the number of persons who show apparent low levels of internally deposited radioactivity.
All personnel, except office workers, are now required to disrobe and wear paper smocks while being counted.
This procedure should climinate possible low levels of external contamination from appearing in WBC results. The effect of these actions will be evaluated in March 1982 and follow-up action taken as appropriate.
Further status will be provided in the six-month follow-up report.
ZION (1981)
Page 21 SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Minimize solid radioactive waste volumes.
Findmg Reduction in the station's solid radioactive waste volumes can be (RC.7-1) achieved.
Waste materials are not effectively restricted from entry into radiologically controlled areas and compactable waste is not segregated.
Recommendation Establish methods to segregate radioactive from nonradioactive material in controlled areas and to minimize the amount of material taken into contamination controlled areas. Emphasize waste reduction methods in training programs.
Response
Zion Station will establish an aggressive program to do the following:
a.
train and develop awareness b.
establish guidelines and staging areas c.
Institute positive control of materials being taken into contaminated areas d.
segregate waste materials in controlled areas e.
maximize use of reusable containers This program will be in effect by September 1,1982.
I RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Minimize contaminated equipment and areas in the plant and minimize personnel contamination.
Finding Control of low level radioactive contamination needs to be im-(RC.9-1) proved. For example:
a.
During a recent outage, a number of personnel were found to be contaminated after being monitored out of contaminated areas, b.
Plant surveys periodically find contaminated items out-side controlled areas.
ZION (1981)
Page 22 c.
Whole-body frisking for radioactive contamination is not being performed at the exit of some contaminated areas or at the exit of controlled areas. Portal monitors are being used as primary means of personnel monitoring.
This instrumentation used does not have the sensitivity required to ensure station contamination limits are met.
d.
The contamination surveillance program should be more comprehensive. Several previously unidentified contami-nated areas were found in the turbine building.
Recommendation Establish methods to improve personnel monitoring on exiting contaminated work areas and the controlled area. Require whole-body frisking of workers when leaving contaminated or potentially contaminated areas. Place more emphasis on the proper monitor-ing of material leaving the controlled areas. Review the contami-nation surveillance program and increase the frequency and scope of smear surveys based on expected radiological conditions.
Response
The station will take the following additional steps to improve the contamination control program:
a.
NGET training will stress the need for, and a method of performing, whole-body frisking after working in a con-taminated area, b.
A low-background area for whole-body frisking will be provided at each of the lower levels of the auxiliary building.
c.
A liquid scintillation foot monitor has been purchased and will be installed upon delivery. Additional GM detectors for personnel contamination surveys have been purchased l
and will be used at work exit areas where practicable. In addition, Commonwealth Edison will evaluate current personnel contamination monitoring techniques and estab-l lish a common method for use by all CECO plants.
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The policy of surveying all tools and equipment upon leaving controlled areas will be enforced.
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A more comprehensive survey program for the turbine l
building that includes identification / decontamination has been implemented.
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Page 23 Finding Several components and areas were found to be improperly posted (RC.9-2) or not labeled as contaminated.
Fuel handling tools were not identified as radioactive.
a.
b.
Contaminated areas were not barricaded on all sides or posted as contaminated areas.
Drums containing radioactive material in the fuel building c.
and auxiliary building were not labeled.
Recommendation Provide additional emphasis and direction to radiation and chemis-try technicians who routinely survey controlled areas to actively confirm that all areas and components are properly posted or labeled.
Response
Rad / chem management has re-emphasized the need for more vigilance by the rad / chem technicians regarding posting and label-ing of work zones and equipment. Radiation protection foremen, through plant visual surveillances and on-the-job supervision, will continue to ensure good rad / chem technician performance. R e-training for all RCTs is being completed in phases during the year and will be completed by December 31,1982.
CHEMISTRY PERFORMANCE OBJECTIVE: Ensure accurate measurement and effective control of chemistry parameters.
i Finding Hydrogen analyses have not been performed for extended periods (RC.10-1) of time. In addition, erroneous results have been recorded in some cases when problems developed with analytical or sampling equip-ment. It is recognized that a new primary sampling system is being installed and a new gas chromatograph has been purchased. The gas chromatograph is not operational at the present time.
Recommendation Expedite the installation of the primary coolant sampling system and the repair of the gas chromatograph. Evaluate the need for back-up equipment and spare parts for sampling systems and analytical equipment used in evaluations of key parameters.
Response
Installation of the primary coolant sample system is scheduled to be completed by June 1,1982.
The gas chromatograph has been repaired.
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Page 24 A new lab depressurizer panel is being constructed and should be operational by June 1,1982.
The need for back-up equipment and spare parts will be evaluated by April 1,1982, and action taken as appropriate.
Finding Chemistry results are not recorded in a fashion that facilitates (RC.10-2) trend review. Results are listed on a log sheet without listing the corresponding plant conditions.
Recommendation Modify log sheets to include plant conditions when recording chemical parameters. Utilize this information when plotting data to facilitate trend analysis.
Response
Log sheets will be modified to include plant conditions.
In addition, key chemical parameters will be plotted to facilitate trend analysis. This will be implemented by May 1,1982.
Finding The method used for processing demineralized water utilized for (RC.10-3) the preparation.of chemical standards does not ensure that chemi-cal contaminants that can interfere with analytical results are re-moved.
Recommendation Provide a water purification system in the chemistry lab that will consistently produce water suitable for preparing chemical stan-dards. Upgrade calibration methods to account for contaminant contribution to standard curves.
Response
Work has begun with the vendor to re-evaluate the present water quality system.
Additionally, various standard-type calibration methods are under consideration to eliminate contaminants in curve preparation. These actions will be completed by May 31, 1982.
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Finding Spiked samples are not used as part of the chemistry and radio-(RC.10-4) chemistry quality control program. The use of spiked samples to evaluate technician and equipment performance was a part of the QC program in the past but was discontinued. It is recognized that l
ZION (1981)
Page 25 plans are being made to upgrade the QC program in the chemistry section and that work has already begun in this area.
Recommendation Expand the chemistry quality control program to require radiation and chemistry technicians to analyze spiked samples according to a predetermined schedule. The results of these analyses should be evaluated to determine program effectiveness.
Response
A program that utilises spiked samples in the chemistry lab is under development and will become part of the quality control program by September 1,1982.
This program will be used to evaluate both technician and equ pment performance on a regular basis.
Finding The method used for the analyses of iron and copper is not (RC.10-5) sufficiently sensitive to detect these parameters at the limits specified in plant procedures. The station is aware of this problem and is in the process of purchasing instrumentation that will meet the sensitivity requirements.
Recommendation Complete the purchase of new instrumentation and develop a method of analysis that has sufficient sensitivity to detect iron and copper at the limits specified in plant procedures.
Response
New instrumentation for the detection of iron and copper required by system limits has been purchased, and delivery is expected by March 1,1982. Installation, procedure development, and imple-mentation will be completed by September 1,1982.
i Finding Out-of-specification pII measurements in secondary systems have (RC.10-6) periodically occurred over several months. This problem had been evaluated by plant chemistry personnel, and the cause was found to be maintenance problems with hydrazine addition pumps.
Recommendation Complete the planned purchase and installation of new hydrazine addition pumps.
Response
The purchase and installation of hydrazine addition pumps is now in progress, and completion is expected by July 1,1982.
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Page 26 TECHNICAL SUPPORT PLANT EFFICIENCY AND RELIABILITY PERFORMANCE OBJECTIVE: Optimize plant thermal efficiency and reliability.
Finding The existing plant thermal performance monitoring program is (TS.2-1) fragmented and limited in scope. Some data, including information from a partially implemented computer program, is collected and trended by various groups; however, use of this data is not formalized.
Recommendation Formalize the present program by developing a procedure that defines equipment parameters, frequency of collecting data, and data analysis. Assign program responsibility and complete imple-mentation of the existing program.
Conduct an analysis to determine additional parameters or equipment that should be in-cluded in the program.
Response,
A formal program *a monitor plant thermal performance will be developed based on the existing thermal performance program.
Procedures will be developed that will define the analysis method, the equipment parameters, and the frequency of data collection.
The existing program will be reviewed to determine what addi-tional equipment needs to be monitored.
The formal program should be implemented by October 1,1982.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM PERFORMANCE OBJECTIVE: Ensure industrywide and in-house operating experiences are evaluated and appropriate actions are taken to improve personnel awareness and equipment reliability.
Finding The process for review of industry operating experiences needs (TS.3-1) improvement in several important areas:
Significant industry events are not screened in a consis-a.
tent manner by corporate operating experience review personnel. There are no formalized screening criteria to identify applicable events and necessary corrective ac-tions.
b.
Station procedures need guidelines to ensure more thorough and consistent operating experience reviews.
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Page 27 c.
No formal method is utilized to track the implementation of corrective actions resulting from the review of indus-try operating events, d.
Provisions for periodic reviews of program effectiveness have not been implemented.
Recommendation Impmve the operating experience review program to correct the items described above.
Section TS.3 of INPO's " Performance Objectives and Criteria for Plant Evaluations," dated June 1981, and the INPO Significant Event Evaluation and Information Net-work (SEE-IN) program description, dated November 1980, could provide guidance in this area.
Response
Nuclear Operating Experience Evaluation Program guidelines will be reviewed and revised to address the above finding and recom-mendation by July 1,1982.
Finding Action on some recommendations included in Significant Operating (TS.3-2)
Experience Reports (SOERs) has not been completed.
SOER recommendation status for SOERs 80-1 through 80-6 and 81-1 through 81-16 is as follows:
Number of Recommendations Action Taken 9
Satisfactory 21 Not applicable 59 Pending 2
Need further review The following recommendations are pending action:
SOER Number Recommenetion Number
[
81-1 1, 2 81-2 1-6 81-3 1-3 81-4 1,2,2a,2b,3,4 81-5 1-4 81-6 1, la, 2 81-7 1, 2 81-8 1-4 81-9 1,2a,2b,2e 81-10 1
l T
81-11 1
81-13 1 - 4, 6 - 8, 10 - 12, 15 81-14 1, 2 81-15 la,Ib,Ic,2a,2b,2c,3 81-16 1-3 e
e
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Page 28 The following recommendations need further review:
SOER Number Recommendation Number 80-2 1, 2 Recommendation Initiate further review or complete action as appropriate on SOER recommendations listed above. Advise INPO of the status of each recommendation in the response to this report.
Response
The SOERs listed above are currently being reviewed for appro-priate action. The status of each recommendation will be provided in the six-month follow-up report.
PLANT MODIFICATIONS PERFORMANCE OBJECTIVE: Plant modification programs should ensure proper re-view, control, implementation, and completion of plant design changes in a safe and timely manner.
Finding Some drawings are not revised and issued in a timely manner (TS.4-1) following completion of a modification to a system or component of the plant. It is recognized that a major effort is underway to correct this problem.
Recommendation Continue efforts to reduce the backlog of final design drawings associated with completed modifications. Implement a mechanism to ensure that final design drawings are completed in a timely manner after completion of plant modifications.
Response
The Station Nuclear Engineering Department (SNED) has formu-lated a goal for 1982 to reduce the backlog to six months. A quarterly report is presently generated by an architect engineer and sent to SNED with a copy sent to Zion Station indicating the status of outstanding drawing change requests. The station will monitor the progress of reducing the backlog by reviewing this report. Progress in reducing me backlog will be provided in the six-month follow-up report.
Finding Operator training and procedure revision are not always completed (TS.4-2) prior to a modified rystem being returned to service. A review indicated that these requirements were not met for several modifi-cations.
The modification program does not presently include
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Page 29 provisions to ensure that these items are completed prior to returning a modified system to service.
Recommendation Revise the present program to ensure that appropriate training and procedure revisions are completed prior to placing a modified system in service. Include temporary installations as part of this program.
Response
Guidelines will be established by April 1,1982, F provide that appropriate operator training and procedure revision be accom-plished prior to placing a modified system in service.
Finding Some non-safety-related modifications and temporary installations (TS.4-3) that are designed on site do not receive a formal, technical inter-disciplinary review and approval prior to the implementation of the design change. Several examples of completed modifications were observed where interdisciplinary review was not apparent. The on-site review procedures do not require interdisciplinary review and approval.
Recommendation Revise the modification program to include provisions that ensure each plant design change receives the necessary quality of review and approval.
Response
The review of non-safety-related modifications that are designed on site will be expanded to include additional disciplines as appropriate. Modifications that need expertise beyond the on-site capability will be referred to the Station Nuclear Engineering Department for review. This action will be implemented by July 1, 1982.
Finding Current as-built drawings are not provided to the plant operators (TS.4-4) for some modified systems prior to the return to service of the system or component.
Station operators were observed using uncontrolled drawings for reference in routine operation of the plant. Station procedure ZAP S-52-2, Document Control, and the modification program do not ensure that plant operators readily have access to those drawings pending revision.
Recommendation Revise the modification program to provide plant operators with the as-built condition for those drawings routinely used to operate the plant, such as flow diagrammatics and one-line electrical schematics. The existing uncontrolled drawings should be removed from the control room.
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Page 30
Response
The modification program guidelines will be revised to provide that affected control room drawings be marked to indicate the as-built status prior to placing a modified system in service. This action should be completed by July 1,1982.
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Page 31 ORGANIZATION AND ADMINISTRATION ADMINISTRATIVE CONTROIE PERFORMANCE OBJECTIVE: Provide well-defined, organized, and effective adminis-trative controls to direct the tasks, responsibilities, and practices within the organi-zation to meet the specified mission, goals, and objectives.
Finding Administrative controls for several plant areas need to be im-(OA.4-1) proved. Some examples are as follows:
a.
The Quality Control (QC) Department administrative con-trols are fragmented and need to be consolidated. This has been recognized, and efforts are currently underway to develop a comprehensive administrative procedure for the QC program.
b.
The administrative controls for the ALARA program need to be completed.
c.
The administrative controls for the outage coordinators need to be formalized.
d.
Administrative controls for maintaining the file of proce-dures used by Operations Department personnel and kept in the shift engineer's office need to be developed.
Recommendation Evaluate all areas of plant activities to see that they are ade-quately covered by appropriate administrative controls. Develop or revise controls to correct the above conditions.
Response
Quality Control Department administrative controls, job specifica-tions, and the organizational chart are being revised and will be completed for implementation by July 31,1982. Other procedures I
dealing with QC activities are being developed and will be com-t pleted by October 31,1982. Each will then be included in a QC administrative manual.
Administrative controls for the ALARA program are being devel-oped on a continuing basis. It is expected that lessons learned from the 1982 spring outage will provide additional guidance.
The formalization of the program should be completed by December 31,1982.
An outline defining the requirements to fulfill basic functions of the outage coordinator as defined in the position description attachment of "A Plan for Managing Commonwealth Edison Com-pany's Operation of Nuclear Power Plants" will be provided by July 1,1982.
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Page 32 The Zion administrative procedure for procedure control will be reviewed, and any additional changes will be implemented by July 1,1982.
MANAGEMENT QUAIJTY PROGRAMS PERFORMANCE OBJECTIVE: Provide management with accurate indication of the extent of adherence to policies, administrative controls, codes, regulations, and effectiveness in meeting plant mission, goals, and objectives.
Finding The following Good Practice was Nted: Quality controlinspectors (OA.5-1) were assigned full time to the turbine-generator inspection /over-haul during the recent refueling outage.
Finding The quality control (QC) program should be expanded to include (OA.5-2) important balance-of-plant (non-safety-related) equipment.
Al-though a program is partially in place, it does not provide suffi-cient guidelines in the areas of scope, inspector duties, and documentation for the QC department on balance-of-plant equip-ment.
Recommendation Expand the QC program to include important balance-of-plant (non-safety-related) equipment.
Response
Revisions to the QC Administrative Procedures are in progress.
The revisions will encompass specific guidelines for inspectors reviewing non-safety and reliability-related work for balance-of-plant equipment.
l See also response to Finding OA.4-1.
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Page 33 INDUSTRIAL SAFETY PERFORMANCE OBJECTIVE: Provide an orderly working environment in which station personnel may carry out their work activities safely.
Finding Increased management attention is needed in the enforcement of (OA.7-1) the station's industrial safety program.
It is recognized that improved conditions are expected with the recent appointment of a full-time industrial safety supervisor.
Recommendation Increase management's active participation in upgrading industrial safety practices. Ensure that plant personnel are held more fully accountable for compliance with the station's safety rules.
Response
Plant management, working in conjunction with the safety super-visor and the Industrial Relations Department, will ensure im-proved compliance with the station's safety rules.
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APPENDIX Page1 APPENDIX Performance Objectives Reviewed TRAINING AND QUALIFICATION TQ.1 Trahaing 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 necessary for non-licensed operators to perform their assigned job functions.
TQ.5 Licensed Operator Training Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.
TQ.6 Licensed Operator Requalification Training Maintain the skills and knowledge necessary for licensed operators to perform their asdgned job functions.
TQ.7 Shift Technical Advisor Training I
Develop and maintain the skills and knowledge necessary for Shift Technical Advisors (STA) to perform their assigned job functions.
TQ.8 Maintenance Personnel Training Develop and maintain the skills and knowledge necessary for maintenance personnel to perform their assigned job functions.
1
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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 facilities and equipment that are operated and maintained at a level to support safe and efficient operation.
OP.3 Conduct of Shift Operations Ensure that shift operations are conducted in a safe and reliable manner.
OP.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of written procedures.
OP.5 Plant Status Controls Maintain plant status in a condition that ensures equipmert and system availability as necessary for safe and reliable plant operations at all times.
OP.6 Shift Turnover Ensure a continuous and correct understanding of plant conditions at all shift operating positions through proper shift turnover.
l OP.7 Tagout Practices Protect personnel and plant equipment by implementing effective tagout practices.
l MAINTENANCE i
MA.1 Maintenance Organization and Administration Provide a clearly defined maintenance 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.
ZION (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.
MA.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 History Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvements in equipment performance.
MA.6 Preventive Maintenance (PM)
Optimize equipment reliability and performance to enhance plant safety and availability.
M A.7 Control of Measurement and Test Equipment (M&TE)
Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.
M A.8 Control of Special Processes Ensure that the control and performance of special processes yields quality results.
l 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.
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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 Minimize solid radioactive waste volumes.
RC.8 Transportation of Radioactive Material Meet the requirements for transportation of radioactive material.
RC.9 Radioactive Contamination Control Minimize contaminated equipment and areas in the plant and minimize person-nel contamination.
RC.10 Chemistry Ensure accurate measurement and effective control of chemistry parameters.
TECIINICAL SUPPORT TS.1 On-site Technical Support Organization and Administration llave a clearly defined on-site technical support organization that is adequately staffed, assigns responsibility, and delegates adequate authority for the accom-l plishment of required tasks.
i l
TS.2 Plant Efficiency and Reliability Optimize 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.
TS.4 Plant Modifications Provide a program to implement plant modifications in a timely manner while maintaining the quality of plant systems and components.
i ZION (1981) i APPENDIX Page5 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.
OA.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 meet the specified mission, goals, and objectives.
OA.5 Management Quality Programs Provide management with accurate indication of the extent of adherence to policies, administrative controls, codes, regulations, and effectiveness in 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 equipment and facilities.
OA.7 Industrial Safety Provide an orderly working environment in which station personnel may carry out their work activities safely.
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