ML20071H034

Evaluation of Oyster Creek Nuclear Generating Station, 1982

ML20071H034
Person / Time
Site:	Oyster Creek
Issue date:	03/31/1983
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
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ML20071H039	List: ML20071H034
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NUDOCS 8305240476
Download: ML20071H034 (44)

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1982 Evaluation n n vyster ureek Nuclear

Generating Station l General Pualic i Utilities l Owned by l

Jersey Central Power & Light Company Operated by GPU Nuclear Corporation 1

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.i EVALUATION of 1 OYSTER CRREK NUCL2AR GENERATING STATION J

O led d General Public Utilities ,

Owned by Jersey Central Power & Light Company Operated by GPU Nuclear Corporation i

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. i F March 1983 i

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7 OYSTER CREEK (1982)

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SUMMARY

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1 INTRODUCTION s

The Institute of Nuclear Power Operations (INPO) conducted an evaluation of the Oyster Creek Nuclear Generating Station during the weeks of October 25 and l November 1,1982. The station is located on Barnegat Bay, near Forked River, New a Jersey. The unit began commercial operation in December 1969.

) 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 3

needing improvement. Information was assembled from discussions, Interviews, obser-5 vations, and reviews of documentation.

1 The INPO evaluation team examined station organization and administration, oper-

ations, maintenance, technical support, training and qualification, radiological pro-

] tection, and chemistry. The team also observed the actual performanca of selected evolutions and surveillance testing. Corporate activities were not included in the scope

) of the evaluation, except as an incidental part of the station evaluation. As a basis for

the evaluation,INPO used performance objectives and criteria relevant to each of the areas examined; these were applied and evaluated in light of the experience of team q

members, INPO's observations, and good practices within the industry.

5 INPO's goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant operation. The recommendations in each area are based on i best practices, rather than minimum acceptable standards or requirements. Accord-ingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance.

f i DETERMINATION 1

g Within the scope of this evaluation, the team determined that the Oyster Creek Nuclear Generating Station is being operated in a safe manner by experienced personnel.

1 The following beneficial practices and accomplishments were noted:

J strong overall corporate commitment to station improvements 3 increased involvement of senior station managers in the details of plant operation t

significant improvement in radiological protection practices including reduction

of radioactive solid waste l

9 improvement in material condition, preservation, and housekeeping in many areas c

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A number of areas needing improvement were noted. The following are considered to be among the most important:

a first-line supervisory support of management initiatives, and involvement in on-7 the-job station activities 1

several areas of training, including initial training and qualification of equipment operators and on-the-job training for most technicians 3

most aspects of plant chemistry the quality of plant procedures industrial safety practices 1

j off-site engineering support of the station s In each of the areas evaluated, INPO has established PERFORMANCE OBJECTIVES and

, supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of this evaluation are listed in APPENDIX IL I 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 3 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 General Public Utilities 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 1 efforts to improve all aspects of its nuclear programs. In addressing these findings and j recommendations, the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.

s 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 i this report. In areas where additional improvements were needed, a new finding that 5 stands on its own merit has been written. Thus, this report stands alone, and reference to previous evaluation reports should not be necessary.

j The findings listed herein were presented to General Public Utilities Nuclear Corpora-tion (GPUN) management at an exit meeting on November 4, 1982. Findings, recommendations, and responses were reviewed with GPU management on February 22,1983. Responses are considered satisfactory.

To follow the timely completion of the improvements included in the responses, INPO I requests a written status by September 30, 1983. Additionally, a final update will be

! requested six weeks prior to the next evaluation.

The evaluation staff appreciates the cooperation received from all levels of General Public Utilities.

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GENERAL PUBLIC UTILITIES l

1 Response Summary i

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GPU Nuclear appreciates the professional manner in whleh the Institute of Nuclear Power Operations (INPO) team conducted the evaluation of the Oyster Creek Nuclear

] Generating Station. The recognition by the team of the improvements and accomplish-ments since the last evaluation is especially appreciated. GPU Nuclear remains strongly committed to accomplishing station improvements and is dedicated to operat-T ing nuclear power plants safely and efficiently. This evaluation will help us focus our p efforts in making additional improvements.

q The findings by the evaluation team are valid and address principal areas in vhich improvements can be made. Comments on the most important of these areas e.ee as follows:

1 Improved first-line supervisory support of management initiatives is a significant

] step in achieving progress. Management leadership will be necessary to achieve this improved support. Increased involvement by first-line supervisors in on-the-1 job station activities should ensue from the continued involvement and interest of j senior station managers in the details of plant operations.

Initial training and qualification of equipment operators is an area that has been i

i programmed for improvement in 1983. Upgraded standards and increased training for equipment operators are considered important elements in improving the

, reliability and safe operation of Oyster Creek.

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') A major restructuring and upgrading of the plant chemistry program is already in progress. Management support and attention similar to that provided in the upgrading of GPUN radiological controls program is planned.

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Plarit procedures are receiving detailed in-depth reviews by senior management as part of the revision and review process. These efforts should result in improved quality and workability of plant procedures.

l A significant reduction in lost-time due to industrial accidents was achieved i during 1982. Continued development of the industrial safety prog am is planned j along with improvements in safety performance.

3 Improvements in the off-site engineering support of the station are planned. A h

closer working relationship between plant engineering and corporate engineering

/ groups is being fostered.

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) ORGANIZATION AND ADMINETRATION 1

e STATION ORGANIZATION AND ADMINETRATION PERFORMANCE OBJECTIVE: Station organization and administrative systems should ensure effective implementation and control of station setivities.

2 Finding Numerous industrial safety deficiencies exist throughout the plant.

(OA.1-1) Although the reportable injury rate has been reduced, injuries are still high compared to nuclear Industry averages. First-line

) supervisors are not routinely identifying safety hazards and re-quiring their subordinates to comply with safety rules. Safety 1

training is not always conducted by each department. It is

~( recognized that new procedures have recently been issued to improve industrial safety.

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f Recommendation Hold first-line supervisors accountable for industrial safety viola- 1 tions of their subordinates and for safety hazards in their areas of l

_ the plant. Ensure safety training is conducted by all departments.

j Response The responsibility of first-line supervisors for the industrial safety {

of their subordinates is clearly stated in their job descriptions. '

They will be held accountable for their performance in industrial safety in performance evaluations and salary reviews.

1 Training for supervisors and managerial personnel in safe work practices and in a newly developed GPUN Safety and Health j Manual will commence by March 1983. The attendance of depart- j ments at monthly safety meetings is monitored and enforced by 1 management.

A station objective of reducing the lost-time accident rate in 1983  ;

r by one-half, as was achieved in 1982, has been established, l i '

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OPERATIONS a

n CONDUCT OF OPERATIONS

'] PERFORMANCE OBJECTIVE: Operational activities should be conducted in a manner that achieves safe and reliable plant operation.

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J Finding Action is needed to. reduce the number of annunciators in an

, (OP.2-1) alarmed or lighted condition during normal plant operations. Al-i though a new annunciator system is scheduled to be installed during

) the 1983 outage, it will not correct this condition unless some design modifications are accomplished.

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! Recommendation Perform an engineering design review of those annunciators that are in an alarmed or lighted condition during normal plant oper-3' ation. Where feasible, incorporate logie changes in the new J

annunciator system to eliminate alarmed or lignted annunciators.

' W A review of alarms in a lighted condition during normal plant operation has been completed. This review included an evaluation j of the location of the alarms in the new annunciator system to determine whether or not the new location will minimize operator h distraction, and also included an evaluation of possible logic or

.) other hardware changes. Recommended changes will be incorpo-rated during the 1983 outage.

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.Y PLANT STATUS CONTROLS j PERFORMANCE 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.

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l Finding 'Ihe current shift turnover practices do not ensure a complete and D (OP.3-1) comprehensive turnover of plant status. For example, operational J and narrative logs are not routinely reviewed, and turnover check IIsts are not used as an integral part of the shift turnover process.

f I Recommendation Expand the existing turnover requirements to include the following N additional guidance to the operators:

.) a. Utilize the existing turnover sheets as an integral part of J the turnover process, n

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b. Perform a review of operational and narrative logs, major I outstanding clearances, and a test of main control panel j annunciators.

m c. Require control operators and group shift supervisors to j perform a walkdown of control panels during shift turn-over.

Management personnel should periodically monitor shift turnovers to ensure proper performance in this area.

Basponse To immediately address this finding, a memorandum was issued on

'h November 16,1982 delineating proper shift turnover practices.

Furthermore, a revision to station procedures incorporating the y guidelines presented in INPO Good Practice OP-201, " Shift Relief j and Turnover," has been developed and will be put into effect by March 1983. In addition, department management personnel are periodically monitoring turnovers as part of their daily interaction j? with the shifts.

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OPERATOR KNOWLEDGE AND PERFORMANCE PERFORMANCE OBJECTIVE: Operator knowledge and performance should support l l safe and reliable plant operation. l

) l 5 Finding Equipment operator knowledge of some plant systems needs im-1 (OP.4-1) provement. Several operators were not sufficiently familiar with l d

some plant equipment to be able to detect abnormal conditions. I 5 Many of the systems included on their rounds sheets are not ,

covered on the systems check-out list for qualification.

Recommendadon Evaluate the current level of equipment operator knowledge and provide appropriate remedial training. Upgrade the equipment

, operator systems check-out requirements to include all systems monitored during rounds.

s Response The 1983-1985 Non-licensed Operator Retraining Programs will

] include training on all the systems that an equipment operator (EO) is required to monitor with priority on those systems not previously covered in training. Furthermore, future EOs will be formally a trained in the new Equipment Operator Training Program on all plant systems prior to qualification, with the present EOs sched-

• uled to retrain ur. der the new criteria as manpower requirements j permit.

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In addition, a new standardized qualification card is being de-i veloped that will require detailed systems knowledge on systems j monitored by EOs. This qualification card is expected to be in use by December 1983.

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J OPERATIONS PROCEDURES AND DOCUMENTATION I

h PERFORMANCE OBJECTIVE: Operational procedures and documents should provide appropriate direction and should be effectively used to support safe operation of the 1 Pl ant.

3 Finding Some operations procedures are _ overly difficult to use and contain 1

(OP.5-1) erroneous references. Some procedures do not contain sufficient

) information to complete evolutions without frequent references to other procedures. These references are not always correct.

1 1 Recommendation Conduct a procedure usability review of all operating procedures that will not be replaced by new emergency procedures. Revise g deficient procedures as necessary. While conducting the review, i place emphasis on human factors considerations such as erroneous l references, non-specific references, and procedure subparagraphs.

Ramnanna In addition to revising the emergency operating procedures and

,; implementing the symptom-oriented emergency procedures, a pro-gram will be initiated to improve the review and revision of

'; operating procedures. This willinclude the development of proce-j dure writing guidelines that take into consideration, among other standards, human factors, format, and usability. Implementation s of such guidelines is expected to be completed by December 1983.

j This will ensure that future review and generation of procedures

> are conducted in a controlled manner. Review priority will be assigned to abnormal events procedures and emergency operating procedures.

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] Finding Improvement is needed in the method for making temporary j (OP.5-2) changes to operating procedures. The following problems were noted:

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a. Temporary changes are not verified to be entered in all procedures prior to use for plant operation.

b. Temporary changes are not tracked to ensure proper

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, c. Some temporary changes have required as long as six i months for review by the Plant Operating Review Com-mittee and implemention in the plant as permanent proce-a dure revisions.

j Recommendation Improve the administrative controls for temporary procedure changes to ensure that all procedures used in the conduct of plant

, operations contain applicable temporary changes, and that tempo-e rary changes are tracked to ensure timely review and implementa-tion as permanent procedure revisions.

Hampaana A change to Procedure 107, " Procedure Control," has been devel-f ,

oped that clarifies handling of temporary and one-time changes.

Procedure 103, " Document Control," is also under review.

1 Required changes to these procedures will be issued by April 1983.

f The Plant Operation Review Committee is meeting daily to reduce the backlog of procedure changes. This backlog should be elimi-nated early in 1983.

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l OPERATIONS FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Operational facilities and equipment shouki effectively support plant operation.

Finding The following Good Practice was noted: The plant practice of not

, (OP.6-1) using the paging system for routine communications leaves this system free for use during plant emergencies. Plant background noise attributable to the paging system is practically non-existent.

i. P Finding Much of the equipment in the turbine building and some important

, (OP.6-2) valves and components in the reactor building are not identified with permanent and distinguishable labeling.

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Recommendation Implement a comprehensive program to coordinate the labeling a

efforts of various plant groups to ensure that important plant valves and equipment are properly identified.

, Response During the past year, many of the large components and systems were marked with permanent labels. A comprehensive system walkdown and component marking program will continue to com-3 pletion during 1983-84.

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Finding The plant pogitg system cannot be heard in some locations of the (OP.6-3) reactor building or turbine building. In some locations it is

'i muffled, and in other locations it cannot be heard above running equipment.

s l Recommendation Evaluate the plant paging system for plantwide audibility, and

/ adjust installed speakers or add speakers as appropriate.

? Response An engineering survey will be performed to determine which areas of the plant and surrounding areas require paging system upgrading.

. This study will be conducted during plant operation when worse-W case conditions are present. After the problem areas are deter-mined, methods to rectify the problems (additional speakers, amplifiers, strobe lights, signs, or maintenance) will be defined.

This survey is expected to be completed by March 1983. Required i system modifications will be budgeted and scheduled for installa-i tion in accordance with approved corporate procedures.

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.. MAINTENANCE .

J MAINTENANCE ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: The maintenance organization and administrative sys-I tems shoidd ensure effective control and implementation of department activities.

Finding Administrative procedures that define maintenance and mainte-(MA.1-1) nance supervisory positions need to be revised. The new main-tenance organization is not ciently understood by all maintenance

, personnel Recommendation Revise station administrative procedures to define the newly a

established maintenance organization. Ensure changes are commu-nicated to all station maintenance personnel Response Changes to the Station Administration Procedures (101 Series) and to the GPU Nuclear Organization Plan have been completed.

' Information on the Maintenance and Construction (M&C) Organiza- '

tion and the Material Department has been communicated to all

[ station maintenance personnel. A rnajor revision to Procedure 105,

" Conduct of Maintenance," has been drafted and will be published by March 1983.

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PLANT MATERIAL CONDITION l PERFORMANCE OBJECTIVE: The material condition of the plant should De main-

[ tained to support safe and reliable plant operation.

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Finding A number of plant material deficiencies ot: served during the (MA.2-1) evaluation were not documented in the work control system.

Exaniples noted included pump seal leaks, valve packing leaks, clogged drain lines, and leaking relief valves.

, Recommendation Implement measures to ensure timely identification and correction I cf plant deficiencies. INPO Good Practice MA-301, " Plant Materi-al Deficiency Identification," could be of assistance in this effort.

Heanaama Specific items observed during the evaluation were addressed; however, the long-term resolution of the problem lies in the forthcoming revision of Procedure 105, " Conduct of Maintenance."

L This complete revision of plant material deficiency identification, documentation, resolution, and close-out procedures is intended to B

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s OYSTER CREEK (1982) j Page 11 s minimize the number of undocuinented or unresolved deficiencies.

, The recent realignment of functions between the M&C Organiza-

> tion and the Material Department and the inception of the M&C Work Management System will aid in resolving this problem.

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7 Finding Some balance-of-plant gauges and meters are in need of calibra-

$ (MA.2-2) tion. Additionally, several gauges and meters do not have calibra-

tion stickers affixed as required by plant procedures.

< Recommendation Ensure the recently established program for calibration of balance-

of-plant gauges and meters is carried out in a timely manner and that calibration stickers are affixed to all gauges and meters as required by plant procedure.

1 Rea A program to resolve this finding has started, including placing " cal stickers" on all balance-of-plant gauges and meters. It is antici-pated that this program will be completed by the end of the 1983 outage, i

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) Finding Significant material deficiencies exist at the intake structure that (MA.2-3) could affect plant operation. The following examples were noted:

i j a. Number three screen is running with degraded bearings.

, b. Numbers two, four, five, and six screens have bent catch

. trays and missing fasteners.

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i c. Number two screen wash pump upper bell housing is cracked.

d. tiumber one screenwash pump has excessive sealleakage.

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e. The chlorine addition pump is d'egraded, rusty, and has excessive leakoff.

ll Recommendation Identify and repair material deficiencies and leaks at the intake structure. Clean and preserve equipment and structures.

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, Ecuponse The intake structure deficiencies were previously identified, and an j extensive refurbishment program for the intake system has been Initiated, Modifications, which include new screen wash pumps, p! ping, valves, stainlese steel baskets, and cathodic protection, were started in 1980 and should be completed during the 1983 refueling outage.

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WORK CONTROL SYSTEM L

PERFORMANCE OBJECTIVE: The control of work should ensure that identified

, maintenence actions are properly completed in a safe, timely, and efficient manner.

Findlag Mechan' cal maintenance work request planning and coordination (MA.3-1) needs improvement. A considerable number of manhours are lost while mechanics wait for the supervisor to complete administrative 1 prerequisites such as tagouts and shift supervisors' review and approval

Recommendation Implement planning, scheduling, and coordination improvements for

,1 mechanical maintenance activities to increase the production effi-

ciency of maintenance supervision and perscnneh L

Response The following steps are being taken to effect improvement in the I planning, scheduling, and coordination techniques for maintenance:

il a. The daily work schedule / plan is being prepared and distri-y buted to supervisors the day before. This allows supervi-sors to prepare for the assignment of work to the crafts L by 8 A.M. the following day, r b. The area supervisors meeting is now held prior to the L start of the shift. The scope of the meeting was reduced to review urgent job orders only. This allows the urgent

) jobs to receive the highest level of attention immediately and permits rapid mobilization of personnel and resources 5 in preparing.to correct the identified items.

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c. The Work Management System provides for planning jobs by planners, instead of by production supervisors and j labor. This relieves the production work force from that f responsibility, and allows them to concentrate on produc-( tion activities.

Periodic work sampling to monitor the effectiveness of these steps is planned.

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Page 13 CONDUCT OF MAINTENANCE PERFORMANCE OBJECTIVE: Maintenance should be conducted in a manner that ensures effleient and effective plant operation.

b Finding Increased emphasis on maintenance work practices is needed.

} (MA.4-1) Examples of problem areas include the following:

a. Piping flanges are not always protected from damage gnd

, piping is not protected from intrusion of debris. '

b. Maintenance work sites are not always left in an orderly condition after completion of tasks.

, Recommendation Place additforial emphasis on maintenance work practices to in-clude the organization of maintenance work sites, protection of 1 system piping and flenges, and prevention of inadvertent damage of

, parts that are removed from equipment during maintenance.

Management should stress adherence to proper work practices as

,, part of the routine monitoring of jobs in progress.

) Response Indoctrination in good maintenance work practices is an ongoing activity at all employee levels. This includes protection of i material and equipment and maintenance of work areas. Emphasis

/ will be placed on the items in the finding.

e Quality of observations during management walk-throughs, as well i as monitoring of jobs in progress by direct line supervision, is being Improved. Recognition of ownership, responsibility for activities, and accountability for results are being stressed at all levels.

,1 These actions are expected to improve the material condition of the plant and the efficiency and effectiveness of plant operation.

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s PREVENTIVE MAINTENANCE 1

PERFORMANCE QBJECTIVE: The preventive maintenance programs should contribute .

, to optimam performance and reliability of plant equipment.

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Finding The following Good Practice was noted: The recently established (MA.5-1) vibration monitoring and analysis program should provide for early

, detection of potential equipment failures.

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, MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Facilities and equipment should effectively support the performance of maintenance activities.

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Finding The following Good Practice was noted: The use of movable l (MA.8-1) "manlifts" for maintenance and as an operator aid in the reactor

, and turbine building has reduced the need for scaffokling and f provides for ready secess to valves gnd erpdgment located in normally inaccessible areas. '

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Finding Not all lifting equipment is properly controlled and inspected to (MA.8-2) ensure sefe load-hfting espacity. Some slings where not uniquely

identified and some worn slings were available for use.

Recommendation Expand the current station inspection program to include identi-I fication and testing of selected lifting slings and devices.

Response A program for !nspection, test, and control of the slings will be h developed by March 1983. This program will be implemented by May 1983.

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! Finding Improvement is needed in the order and cleanliness of the plant

[ (MA.8-3) maintenance shops. Material was not properly stored or protected.

Recommendation Increase supervisory attention to general housekeeping in the

maintenance shop areas. Consider assigning specific responsibil-ities for housekeeping of each area.

l Response Overall responsibility for the maintenance shops is assigned to specific area supervisors. By March 1983, group supervisors L (foremen) will be assigned specific responsibilities with defined i objectives for maintenance shops. These assigmnents will establish l ownership and accountability for maintenance shop areas and will I

help ensure proper housekeeping of the shops and control of work within them.

Numerous improvements are being planned for the maintenance shops and their utilization. This is expected to result in more safe l and organized use of the facilities.

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TECHNICAL SUPPORT j

OPERATING EXPERIENCE R? VIEW PROGRAM 7

i PERFORMANCE OBJECTIVE: Industrywide and in-house operating experiences should I

be evaluated and appropriate actions undertaken to improve plant safety and reliability.

',l SOER STATUS

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1 The status of Significant Operating Experience Report (SOER) recommendations is as j follows:

Number of Recommendations Action Taken

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41 Satisfactory 74 Not applicable i 35 Pending The following recommendations are pending action:

SOER Number Recommendaticn Number 80-6 3,4,6,7,10 4 81-3 1,2,3

) 81-10 1 81-13 12,14 81-15 la 82-1 u 82-2 1,2a,2b,2c,2d,4 1,2,3,4,5,6,7 82-5 6 82-9 1,2,3,4,5,6,7,8,9 An update on the status of each recommendation listed in the "pending action" category shown above is requested in the six-month follow-on response to this report. In

, addition, the status of each immediate action (red tab) SOER recommendation received subsequent to this evaluation should be included in the six-month follow-on response. A tabular summary, similar to that above, is requested.

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I Finding The plant is not actively participating in the Nuclear Plant J. (TS.3-1) Reliability Data System (NPRDS). It is recognized that plans are p currently underway to re-establish failure data reporting.

,1 Recommendation Re-establish failure reporting to support the SEE-IN program and lj, the sharing of equipment history information with other utilities.

l Review plant records and report past failures to NPRDS as appropriate. Review plant engineering data and update the data base to the new reportable scope guidelines.

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OYSTER CREEK (1982)

] Page 16 Response Plans are being pursued for reactivation of NPRDS at Oyster l} Creek. Job order close-out data, currently being reviewed for machinery history and trending data by Plant Material personnel, L

will be modified for use with NPRDS. Personnel have received initial training on NPRDS. Submittal of failure reports and associated engineering data on failed components for failures (j associated with Licensee Event Reports and limited conditions for

operations will begin by April 1983. NPRDS will be fully opera-l tional at Oyster Creek by July 1983.

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l Finding 1he program for the review and dissemination of industry operating (TS.3-2) experienee does not ensure that applicable information is provided

to allaffected personnel For example

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a. Periodic independent evaluations of items classified as non1pplicable are not conducted by a second knowledge-i able person.

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l b. Routine evaluations used to enhance program effective-p ness are limited in scope.

c. Applicable information is not always provided to licensed

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) Reeosamendation Improve the industry operating experience program including ad-l dressing the above items, l

ll Response Most operating experience items previously classified as non-applicable received review by two knowledgeable individuals.

Ilowever, these reviews were not always documented. A system

, has been implemented that requires two reviews of each item and

? documentation of these reviews. The effectiveness of the operat-ing experience review program has been reviewed periodically over P

the past two-and-one-half years, and this review will continue in the future. Future reviews will be increased in scope to improve overall program effectiveness. A reading file for licensed opera-j tors was established over a year ago. Additional effort will be made to ensure applicable operating experience information is f placed in this file.

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Finding Information concerning in-house events with possible generic impli-(TS.3-3) cations is not provided to other utilities in a timely manner.

Recommendation Establish peccedural guidelines for notifying the industry of in-house events with generic implications.

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> OYSTER CREEK (1982) j Page 17 Response The examples given as events with possible generic implications

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during the INPO review were Licensee Event Reports. These were

reported to the NRC and provided to INPO for scrconing in a timely manner. The current procedural guidelines for notifying the industry of in-house events cover reports required by the NRC and other plant transients. These guidelines will be reviewed for

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completeness. In addition, a plant engineering supervisor has been designated as plant contact for industry (NOTEPAD) reporting.

This should improve the timeliness of reporting.

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Finding he current tracking system for industry operating experience (TS.3-4) review corrective actions does not track corrective actions to completion.

Recommendation Improve the tracking system used to monitor the disposition of SERs and SOER recommendations.

Response All SERs and SOER recommendations are tracked from receipt until completion or until another tracking system such as a design t

modification is initiated. A procedure change will be made that will allow tracking of SER and SOBR recommendations associated with design modifications until completion of the modifications.

, This procedure change will be in effect by April 1983.

F PLANT MODIFICATIONS e

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 De current modification process does not ensure that operability (TS.4-1) and maintainability are adequately addressed in the detailed design phase of modifications. Modifications have been installed such I that individual instrumentation cannot be isolated for routine t maintenance, and equipment has been installed such that routine 6

outage activities result in damage to the equipment.

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? Recommendation Provide an effective interface between off-site engineering and the plant staff in the modification process to identify and resolve operability and maintainability concerns in the detailed design phase.

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OYSTER CREEK (1982) 1, Pago 18 Rw A new design process hes been implemented that requires the plant staff to concur with the criteria for modifications and review and participate in preliminary design reviens. Input regarcing oper-

' ability and maintainability conkiderations will be obtained during the preliminary engineering phase and used to guide the datalled j

design. For more complex projects, review meetings will be held with plant personnel to ensure that the design meets operability and maintainability needs.

t TECHNICAL SUPPORT PROCEDURES AND DOCUMENTATION PERFORMANCE OBJECTIVE: Technical support procedures and documents should provide appropriate direction and should be effectively used to support safe operation of the plant.

Finding Control room drawings used for plant operations do not always L (TS.7-1) refleet the actual conditions of the piant. A number of as-found conditions have not been incorporated in control room drawings.

p y Recommendation Ensure that all identified as-found changes are reflected in plant

! drawings.

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'i Response A program has been in!tiated to review plant drawings versus as-built conditions to determine drawing differences. This determina-L tion will allow drawings to be corrected to reflect the as-built

[ condition of the plant. Work on this long-term project, which is l- expected to take between two and three years, has already

commenced.

7 A group of drawings, designated by Operationa as control room l drawings, will be revised to incorporate Field Change L Notice / Requests, notmally within 30 days. In the interim, com-posite marked-up prints will be made available to the control room H prior to receipt of official as-built drawings.

The basic procedures are in place and will be clarified by

. March 1983.

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• OYSTER CREEK (1982)

Page 19 Finding Plant &awings are not always updated in a timely meaner. As-(TS.7-2) built drawing change requests submitted to the off-site technical functions division are frequently not incorporated as drawing revisions fo extended periods of time. It is recognized that a program revision has recently been initiated to address this prob-

[. Iem.

. Recommendation Estabilch a target completion date for closing out the open requests for drawing changes. Establish a method for ensuring timely action on future drawing change requests.

Response Procedure EP-025, "Techniesl Functions," provides a list of draw-ing types that will be revised. Drawings designated by Operations as control room drawings will be revised to incorporate Field Change Notices / Requests, normally within 30 days.

No set timo frame is established for revising non-control room drawings. Ergineering Data and Configuration Control Section notifies the cognizant engineering section manager when more than six changes are posted against a specific drawing. Pcoceduro EMP-015, " Field Questicanaires, Change Notices, and Change Requests,

win be modified to require not only engineering section manager notifiestion, but also to require updating of the drawing incor-porating the change notices. This will be done by May 1983.

All drawing lists for Oyster Creek are available to site personnel in an on-line computerized data base. Field Change Notices / Requests are immediately listed against every drawing upon issuance, thus permitting all personnel to ascertain the current status of every drawing on a real-time basis.

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] Page 20 TRADUNG AND QUALIFICATION i}

J NON-LICENSED OPERATOR TRAINING AND QUALIFICATION

'] PERFORMANCE OBJECTIVE: 'Ihe non-licensed operator training cml qualification program should develop and improve the knowledge and skills necessary to perform assigned job functions.

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! Finding 'Iha on-the-job training (OJT) programs for radweste operators and (TQ.2-1) equipment op need improvement. These non-licerfed opera-tors are not required to receive a checkout on (J1 systems associated with their watchstation prior to assuming watch re-g sponsibilities. Also, practical factors and knowledge requirements lj are not delineated, nor are performance standards defined.

, Recommendation Conduct a review of the OJT programs for radwaste operators and

!i equipment operators. Implement changes to ensure that adequate l.! system knowledge and job-related task performance are required l prior to assuming watch responsibilities. INPO's Good Practice l: TQ-501, " Development and Implementation of On-the-Job Training

Programs," could be of assistance in this area.

s Raiponse A standardized OJT program will be established and controlled by a site procedure. Each department will be responsible for estab-lishing an OJT program for its organization consistent with the site-standardized requirements. INPO's Good Practice TQ-501, 7 " Development and Implementation of On-The-Job Training Pro-

) grams," will be used to develop the program.

3 Training is working with Operations to develop system check-off j sheets for operators.

, Milestones and target dates for program development and imple-

mentation will be established by April 1983.

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Finding Some equipment operators have not been provided formal training

} (TQ.2-2) on appropriate subjects and plant-specific systems associated with

the watchstation prior to assuming watchstanding duties. Although a new initial training program for equipment operators has been

developed, equipment operators currently standing shift are not j scheduled to attend these courses, y Recommendation Using the new initial training program as a reference, determine l training needs, and provide appropriate training for equipment

> operators currently standing shift. INPO document GPG-09,

" Nuclear Power Plant Non-Licensed Operators - Guideline for Qualification Programs," could be of assistance in this area.

Resporme The 1983-85 Non-Licensed Operator Retraining Program will in-5 clude training on those systems which the equipment operator (EO) i must know. During 1983, EOs will be trained in areas not previously addressed in EO training.

! Training has been conducted on control rod drive hydraulics,

/ primary containment systems, and secondary containment systems in anticipation of the 1983 refueling outage and the increased i contact the EOs will have with these systems.

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Faure equipment operators (beginning with the first presentation 3

of the Upgraded Non-Licensed Operator Training Program) will be l trained on all plant systems prior to qualification. This training 2

willinclude both formal classroom trairing and OJT, in accordance with detailed systems qualification cards that are under develop-ment.

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MAINTENANCE PERSONNEL TRAINING AND QUALIFICATION h

PERFORMANCE OBJECTIVE: 'Ihe maintenance personnel training and qualification 1

program should develop and improve the knowledge and skills necessary to perform l assigned job functions.

Finding The on-the-job training (OJT) programs for mechanical, electrical,

' and instrument and control personnel need improvennent. The tasks (TQ.5-1) s to be performed, observed, simulated, or discussed are not delin-eated and the skill and knowledge performance standards asso-

) ciated with each task are not defined.

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Page 22 J

Recommendation Implement structured OJT programs for m&Intenance personnel These programs should include the following:

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a. tasks to be performed, observed, simulated, or discussed

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b. identifiestion of individuals or classifications of indivi-duals quallfled and responsible for conducting OJT

c. skill and knowledge performance standards

d. Identification of individuals or classifications of indivi-

', duals quellfied and responsible to conduct final checkouts

e. assurance and documentation that the individual has de-g monstrated competency in specified tasks prior to job

, assignment INPO's Good Practice TQ-501, " Development and Implementation

} of On-the-Job Training Programs," could be of assistance in this 1 area.

Response A standardized OJT program will be established and controlled by a j site procedure. Each department will be responsible for establish-ing an OJT program for its organization, consistent with the site g

standardized requirements.

INPO's Good Practice TQ-501, " Development and Implementation of On-The-Job Training Programs," will be used to develop the

! program.

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Milestones and target dates for program development and imple-g mentation will be established by April 1983.

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TECHNICAL TRAINING FOR MANAGERS AND ENGINEERS PERFORMANCE OBJECTIVE: 'Ihe technical training program for engineers and mana-g gers should broaden overall knowledge of plant processes sax! Mment as e supple-i ment to position-specific education and training.

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{ Finding Plant engineers are not provided instruction on job-related tasks, 3 (TQ.6-1) administrative procedurcs, or the use of plant technical specifica-tions prior to assuming plant engineering responsibilities. Informal j checklists of required reading material have been generated by i each engineering section, but each engineer's progress has not been tracked, and most engineers have not completed the reading requirements.

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,1 3 OYSTER CREEK (1982) j Page 23 Recommendation Implement an orientation program for plant engineers. This program should include training on job requirements, admini-strative procedures, and technical specifications. Ensure comple-tion of required training in a timely manner. INPO document INPO 82-022, " Technical Development Programs for Technical Staff and

Managers," could be of assistance in this area.

~ Response A draft program for plant engineer orientation training has been prepared utilizing INPO guidance on the subject. It provides for classroom, self-study, and OJT. The draft program is in the process of review and comment.

. An implementation schedule will be established when the program is approved. The target date for the implementation schedule is March 1983.

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OYSTER CREEK (1982) a Page 24 RADIOLOGICAL PROTECTION I

RADIOLOGICAL PROTECTION ORGANIZATION AND ADMDUSTRATION PERFORMANCE OBJECTIVE: 'Ihe organization and administrative systems should ensure effective control and implementation of the radiological protection program.

s Finding The following Good Practice was noted: Radiological engineers are (RP.1-1) used in the radiological protection organimation to identify and solve radiological problema, provide a program to reduce the runnhar of high radiation areas and contaminated areas, and per-form audits. These engineers also incorporate radiological controls into plant design changes and procedures.

Finding Improvement is needed to ensure corrective actions are taken or (RP.1-2) completed on Unusual Incident Reports, Radiological Engineering Audits, and Radiological Deficiency Reports. For example, re-quests have been sent to plant engineering and corporate to correct radiological deficiencies, but the current status of corrective action is not always known.

Recommendation Maintain a current status of identified radiological protection corrective actions that require action by other plant or corporate departments. Follow up to ensure actions are taken.

W A radiological protection corrective actions program is being developed. The program willinclude identification, evaluation, and tracking on a monthly basic. The program will be implemented by March 1983.

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9 OYSTER CREEK (1982) j Page 25 RADIOLOGICAL PROTECTION PERSONNEL QUALIFICATION i

PERFORMANCE OBJECTIVE: The radiological protection qualification program should ensure that radiological protection personnel have the knowledge and practical abilities necessary to effectively implement radiological protection practices.

, Finding The following Good Practice was noted: Oral examinations are (RP.2-1) used to determine radiological protection technician and supervisor ability to apply knowledge to practical plant situations.

The examinations require personnel to recognize symptoms of prob-Iems, initiate immediate corrective actions, determine additional actions needed, and provide an overall evaluation of the problem.

EXTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: External radiation exposure controls should minimize personnel radiation exposure.

Finding A more effective temporary shielding program needs to be imple-(RP.4-1) mented. Deficiencies include the following:

I a. Shielding planned for the January 1983 outage has been 1.

under review at the corporate office since January 1982.

b. There are a number of plant areas where temporary shielding should be used to reduce radiation levels.

! c. Stress analysis has not been performed for some com-ponents and piping where temporary shielding is installed.

Recommendation Provide a more timely review of proposed shielding by corporate engineering so that shielding can be installed as soon as prac+1 cable to minimize personnel radiation exposure. Identify plant areas where shielding could effectively reduce radiation levels. Expedite stress analysis of shielding already installed.

Response A temporary shielding procedure that establishes administrative b

controls for the application of shielding and a generic authorization for installation (based on load stress analysis) is in the develop-a mental stage and should be approved by April 1983. A list of areas where shielding could be applied to reduce radiation levels was

', submitted for evaluation in December 1982. The evaluation will be completed by June 1983.

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3 OYSTER CREEK (1982) j Page 26 l

'Ihe Phase I report (Stress Analysis and Shielding Design Inside

] Drywell) was completed in November 1982. The final report

) (Stress Analysis and Shielding Design Inside and Outside Drywell) is scheduled for completion in March 1983.

n i All temporary shielding identified as a potential safety concern has been evaluated. All concerns except one have been resolved. This

, remaining identified concern will be resolved by July 1983.

i Finding Personnel need to be made aware of radiation hvels in selected s (RP.4-2) outside areas to aid in minimizing exposure. The fence around the outside radiologically controlled area is posted as a radiation area, but only high radiation areas are posted within the fenced area. '

Radiation levels of 2-15 mrem /hr. were measured on and around l the old radwaste building and nearby storage trailers within the fenced area.

. Recommendation Implement a method to identify to workers those areas where they l should not spend time unnecessarily due to the radiation levels.

Renponse Custom-made radiological caution signs with appropriate wordmg have been ordered. As soon as the signs are received, they will be posted in the outside areas where higher than background radiation levels exist.

U Finding Post-job information is not effectively used to aid in minimizing )

(RP.4-3) personnel radiation exposure. Post-job reviews to identify problem )

areas are often not performed. Total exposure results for some i jobs are not readily available for use in planning future radioactive m

work.

Recommendation Perform post-job reviews to help identify and resolve problems.

Implement the radiation exposure data collection system currently being developed.

l Response The present criteria for the performance of post-job reviews is J currently being evaluated to ensure that reviews will be performed when necessary and the information .used effectively to aid in minimizing personnel exposure. This evaluation will be completed

. and necessary changes implemented by April 1983. All 1983 outage jobs with significant exposure will receive post job reviews The -

radiation exposure data collection system was implemented in January 1983.

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OYSTER CREEK (1982)

Page 27 INTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: Internal radiation exposure controls shouki minimize l internal exposures.

Finding There is evidence of smoking and eating within the radiologically 7 (RP.5-1) controlled area. Cigarette butts and food wrappers were observed in severallocations in the radiologically controlled area.

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, Recommendation Enforce plant regulations that prohibit eating and smoking within 5

the radiologically controlled area.

a Response Special signs, which will remind personnel of the prohibition on 3 smoking and eating, have been ordered and will be permanently j mounted at strategic locations throughout the radiologically con-trolled area. Also, the Plant Training Department is placing j increased emphasis on the subject during general employee train-

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ing. Discipline for violations has been re-emphasized to all

, supervisors in daily planning meetings. Surveillance for these j

activities has been stepped up by radiological control and plant supervisory personnel

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Finding The number of areas in the plant requiring respiratory protection (RP.5-2) needs to be reduced to improve accessibility for operations and j maintenance personnel While an aggressive decontamination pro-J gram has been implemented, most areas requiring respiratory f protection are a result of high surface contamination levels.

g Recommendation Accelerate the program to eliminate the sources of high contami-j nation and decontaminate areas to levels where respiratory pro-tection is not required for entry.

) Response The program to eliminate sources of contamination and to decon-

> taminate areas requiring respiratory protection will receive in-creased emphasis. Weekly progress reports are submitted to the Vice President-Director, Oyster Creek and appropriate managers.

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• OYSTER CREEK (1982) 1 Page 28 RADIOACTIVE EFFLUENTS l '

PERFORMANCE OBJECTIVE: Radioactive effluent controls should minimize radio-active materials released to the environment.

Finding Improvement is needed in the program for monitoring potcntial

, (RP.6-1) reimana paths for radioactivity. In addition, the monitoring of i

normally clean systems for contamination needs to be improved.

Examples of problems include the following:

a. Between January 1980 and April 1981 there were seven unplanned releases of radioactivity from the condensate storage system.

b. Examples were noted where there was no apparent follow-up to radioactivity detected in clean systems.

c. Some normally clean systems, such as the fire water

• system that is connected to the core spray system, are not monitored for radioactivity.

i: d. Monitors such as the service water monitor have rela-tively high background count rates that reduce sensitivity.

Recommendation Perform a review of the program for monitoring potential release paths and contamination in clean systems and implement necessary improvements. This review should address items such as the

following

a. corrective actions taken as a result of previous events

b. identification of clean systems that interface with con-taminated systems and the need for additional monitoring

c. sensitivity of monitors designed to detect radiation in i clean systems i d. sampling and counting of samples to ensure accurate b results

, e. documentation of program results Response A review of the program for monitoring potential release paths and contamination in clean systems is being performed . Special emphasis will be placed on those items noted in the recom-mendation. This review will be completed and corrective actions implemented by July 1983.

The final draft of a :eport addressing potential paths for releases to the environment via plant drains is being reviewed. Action required will be identified and scheduled by March 1983.

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Page 29 SOLID RADIOACTIVE WASTE 7

PERFORMANCE OBJECTIVE: Solid radioactive waste controls should minimize the  ;

volume of radioactive waste and ensure safe transportation of radioactive material i

Finding The following Good Practice was noted: An effective solid (RP.7-1) radioactive waste reduction program has been implemented. Ele-ments of the program include the following:

a. supervisory inspection of work areas to observe work practices and identify sources of unnecessary waste

b. use of deficiency reports to identify problams so that corrective action can be taken

c. training of personnel to minimize unnecessary materials taken into contaminated areas

d. segregating clean and radioactive trash within the radio-logically controlled area

e. tracking of each bag of waste from the point of genera-tion until compacted or packaged

f. use of compaction devices to increase waste density in shipping containers i

RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Radioactive contamination controls should minimize the a

contamination of areas, equipment, and personnel.

, Finding 'Ihe foHowing Good Practice was noted: An aggressive program to (RP.9-1) control radioactive contamination at its source has been imple-mented by the use of containment tents, glove bags, drip trays, and

funnels attached to floor drains.

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OYSTER CREEK (1982) I l .

Page 30 ,

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Finding 'Ihe outside radiologically controlled area couki be reduced in size 1 (RP.9-2) to minimize the potential for contaminating large areas of soil and

) roadways. There is a large unused area within the outside radiologically controlled area. Present practices allow transfer of j contaminated materials throughout this area that could become j contaminated in the event of inadvertent spills.

Recommendation Consider reducing the size of the outside radiologically controlled area to minimize the area subject to inadvertent contamination.

Dampnnem A program for reducing the outside radiologically controlled area j will be established by March 1983. This program will quantify the

size of the outside radiologically controlled area and report status and progress to management.

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Finding Deficiencies in radiological protection work techniques were ob-(RP.9-3) served. Examples include the following:

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a. Technicians do not always survey meterial removed from contaminated areas.

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b. Technicians sometimes allow workers to move contami-nated materials to previously uncontaminated areas.

c. Some contamination and radiation areas were not properly posted or barricaded.

d. Items were observed with several radioactive mato/ial tags with different radiation levels indicated on each.

e. Survey methods for release of tools and equipment from the radiologically controlled area need to be clarified with technicians.

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} Recommendation Enforce proper radiological protection work techniques. Clarify survey methods, and discuss work techniques with technicians. The 1 recently implemented training seminars could be used for this purpose.

Response Management tours and audits will emphasize enforcement of proper radiological work practices.

A block of time during the weekly technician seminar training has i been set aside to discuss proper radiclogical work techniques. In regard to the survey methods for relee.se of tools and equipment, a separate station procedure for release-type surveys has been developed. This procedure contains detailed requirements for release of tools and equipment removed from the radiologically controlled area.

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, CHEMETRY a

CHEMETRY ORGANIZATION AND ADLIINEFRATION PERFORMANCE OBJECTIVE: The organization and administrative systems should ensure effective implementation and control of the chemistry program.

Finding Personnel performing reviews of chemistry data do not always 1

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(CY.1-1) recognize non-routine results. Because of this, confirming samples are not always taken when it would be desirable to do so.

Examples include indications of radioactivity in normally clean systems.

Recommendation Increase management attention to ensure that technicians and first-line supervisors respond properly to non-routine results. Re-cognition, verification, notification of proper management person-nel, and tracking of corrective action should be stressed.

Response All data are now reviewed on a daily basis with the Manager-Plant Chemistry. Weekly meetings are held to review trended data.

Non-routine results are evaluated and action is recommended if conditions warrant.

Finding Several chemistry department administrative practices need im-(CY.1-2) provement. For example:

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a. Procedure changes are not always in accordance with station policy.

b. Many data sheets are filed improperly.

c. Some data sheets, especially for non-routine samples, are not labeled with sufficient information to readily identify the sample and the reason it was teken.

Recommendation Plant management should emphasize adherence to the procedure change policy and the need to improve the quality and retriev-ability of data in chemistry department files.

RWee The Conduct of Chemistry Procedure, issued August 30, 1982, addresses procedure compliance. Increased management attention has been directed to this area to ensure compliance. Furthermore, the recent department reorganization provides for upgrading of the filing system. Chemistry supervisors have been instructed on how temporary changes are to be mada.

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'i Page 32 CHEMISTRY CONTROL

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'j PERPORMANCE OBJECTIVE: Chemistry controls should ensure optimum chemistry conditions during aI1 phases of plant operation.

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Finding Corrective actions to maintain plant chemistry parameters in the (CY.3-1) most desirable range are not always taken in a timely manner. For 4

example, the plant has been operating for several months with 0 saltwater inleakage into the condenser, and auxiliary boiler chem-istry parameters are frequently out of specification.

P L Recommendation Establish a policy for responding to undesirable chemistry condi-N tions in all systems for which chemistry is monitored. It is recognized that actions are being taken to obtain the services of a contractor to assist in detecting small condenser leaks. The ability a

to identify and correct small leaks should be maintained either through in-house capability or through the use of a contractor.

] More emphasis should be placed on maintaining the proper chem-ij istry conditions in auxiliary systems.

Response Daily and weekly reviews of plant chemistry identify potential L

problem areas. Chemistry now recommends corrective action to j be taken and follows up routinely on action items. Closely monitoring chemical parameters will allow Chemistry to identify smallleaks and to initiate appropriate action.

In conjunction, Chemistry personnel are being trained to identify I' out-of-specification conditions and bring them to the attention of

, Chemistry management.

, Chemistry personnel have been instructed to add chemicals to the auxiliary boilers when chemical parameters approach minimum acceptable limits. This will ensure that chemistry parameters remain within specifications.

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, Finding 'Ihe quality of water in the closed cooling systems is not always L

(CY.3-2) maintained within makeup water specifications. Sodium chloride f concentrations in some closed systems were often above 1 ppm.

l Actual values for sodium chloride concentrations between 0 and 1 ppm are not known because analytical results in this range are recorded as "less than 1 ppm." For the quality of water present in these systems, hydrazine treatment will not provide adequate corrosion protection.

Recommendation Evaluate the chemistry program for the closed cooling water systems. Identify and implement improvements in methods of analysis and chemical treatment.

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, OYSTER CREEK (1982) j '

Page 33 Response The chemistry monitor ng program for the Turbine Building Closed

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Cooling Water (TBCCW) has been upgraded. This program will ensure appropriate recognition, correction, and follow-up of out-of-specification conditions. A temporary demineralizer will be in-stalled in the TBCCW system during the 1983 refueling outage.

l Furthermore, effort is underway to solicit suppliers to provide alternate treatment methods. A report outlining the various i, alternate treatment methods and recommendations for imple-J mentation will be completed by March 1983.

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[ LABORATORY ACTIVITIES

].- PERFORMANCE OBJECTIVE: Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters.

Finding Several impecvements are needed in the laboratory quality control (CY.4-1) program. For example, the spectrophotometer is not calibrated using multiple standards; most reage .ts and standards are not labeled with shelf-life information; accuracy checks are not per-formed on Eppendorf pipettes; and pH values are not being determined at 250 C.

! Recommendation Improve the laboratory quality control program including address-ing the items noted above. In addition to chemical decomposition, g expiration dates should be based on the potential for conta'mina-i tion, evaporation, absorption of carbon dioxide, and, for dilute standard solutions, loss due to plateout.

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OYSTER CREEK (1982)

Page 34 Finding Chemistry laboratories are cluttered and some equipment and work (CY.4-2) areas need ahaing.

Recommendation Stress the need to keep equipment and work areas clean. New n facilities planned for 1983 should include storage space for in-

, frequently used equipment, tool boxes, and samples held for future reference.

j Response Weekly cleanup of the laboratory is now mandatory. A program has been initiated whereby a supervisor will make at least a weekly tour to identify any areas that are in need of cleaning and initiate corrective action. This is documented on a weekly tour sheet.

Furthermore, the new laboratory facilities projected for com-pletion by December 1983 include adequate storage space for equipment, tools, samples, and other material.

CHEMICAL AND LABORATORY SAFETY PERFORMANCE OBJECTIVE: Work practices associated with chemistry activities should ensure the safety of personnel Finding Incompatible chemicals such as acids, strong bases, and sodium (CY.5-1) peroxide were stored together in the chemistry laboratory. Some of these chemicals were old and the containers were in poor condition.

Recommendation Incompatible chemicals should be segregated and old chemicals, especially those that are potential fire or explosion hazards, should be disposed of. New facilities planned for 1983 should provide proper storage conditions for hazardous chemicals. The following National Fire Protection Association Standards could be of assis-tance.

a. Pamphlet 30," Flammable Liquid Storage"

, b. Pamphlet 49, " Hazardous Chemical Storage" I

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c. Pamphlet 491m, " Hazardous Chemical Reactions" Response The chemicals were removed and, where warranted, properly l disposed of. Furthermore, periodic inventories are conducted to prevent recurrence.

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s OYSTER CREEK (1982) 1 APPENDIX I Page1 APPENDIX I Summary of Outstanding Response Action from Previous Evaluation (1981)

PREVENTIVE MAINTENANCE (PM) i

• i Finding Appropriate mechanical preventive maintenance is not being carried (MA.6-1) out on a considerable number of plant components. Development of the mechanical preventive maintenance program is incomplete.

Recommendation Objectively establish the type and frequency of preventive main-tenance actions required to achieve safe and reliable plant operation, and then execute the program as scheduled.

Response Since the evaluation, more resources have been applied to the mechanical preventive maintenance program development. Specif-ically, a mechanical engineer has been assigned to develop the mechanical PM program and schedule. A computer specialist will computerize the data base and schedule. Well-defined PM tasks have been formally scheduled through the end of this year. , Long-term program development is underway. Plans include a major outage in mid-1982 during which considerable preventive maintenance is planned. A review of the adequacy of management and hands-on resources available for carrying out the PM program on a continuing basis will be conducted in 1983, within four months after plant startup.

Status A mechanical PM program hes been developed covering about 60 percent of the plant systems and equipment. Work on implementing the remaining items is currently in progress. Commencement of the outage mentioned above was delayed until early 1983. An analysis of management and hands-on resource adequacy to support the PM program should be completed by December 1983.

, PLANT EFFICIENCY AND RELIABILITY i

Finding Plant thermal efficiency and reliability are not optimized through an t (TS.2-1) effective plant performance monitoring program. Some plant para-t meters are monitored (by operations, plant engineering, and reactor engineering) by observation of control room instrumentation, shift log reviews, .ind required in-service testing of safety-related equipment.

However, the plant does not routinely collect, analyze, and trend i

overall plant data and utilize the results to improve plant efficiency and reliability.

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Recommendation Develop a comprehensive program to monitor and improve plant l thermal efficiency and reliability and to include the following

I'; a. optimum performance parameters established through j baseline data and/or modeling

, b. use of qualified personnel to monitor, record, and analyze 1

J data for trends and plant improvements

c. maintenance of instrumentation accuracy.

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Banpnnan A comprehendve program that will use a new plant computer is planned. Pending implementation of that program, a limited scope program, including the recommended items, has been written and will be implemented by qualified personnel upon startup from the next refueling outage.

Status The limited scope program is progressing and scheduled for comple-tion by the end of the 1983 refueling outage. Implementing proce-dures describing the details of the comprehensive program have not been developed.

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APPENDLX II Page 1 APPENDIX II Performance Objectives Reviewed j

ORGANIZATION AND ADMINISTRATION i

a OA.1 Station Organization and Administraticn Station organization and administrative systems should ensure effective imple-mentation and control of station activities.

j OA.2 Mission, Goals, and Objectives Station mission, goals, and objectives should be established and progress monitored through a formal program.

OA.3.1 Management Assessment Management should assess and monitor station activities to ensure effective performance of all aspects of nuclear plant operation.

OA.3.2 Quality Programs Quality programs should ensure the effective performance of activities im-portant to nuclear safety.

OA.4 Personnel Planning and Qualification

, Personnel programs should ensure that station positions are filled by individuals l with proper job qualifications.

OA.5 Industrial Safety

, Station industrial safety programs should achieve a high degree of personnel safety.

OA.6 Document Control

, Document control systems should provide correct, readily accessible infor-mation to support station requirements.

OA.7 On-site Nuclear Safety Review Committee Review of station nuclear activities by a knowledgeable interdisciplinary group should ensure achievement of a high degree of nuclear safety.

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APPENDIX II Page 2 ,

1 1 OPERATIONS l 1

OP.1 Operations Organization and Administration

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3 The operations 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 sefe and j reliable plant operation.

, OP.3 Plant Status Controls J '

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.

J OP.4 Operations Knowledge and Performance i

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 i should be effectively used to support safe operation of the plant.

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OP.6 Operations Facilities and Equipment Operational facilities and equipment should effectively support plant operation.

} MAINTENANCE 1

j MA.1 Maintenance Organization and Administration i

The maintenance organization and administrative systems should ensure effec-

, tive control and implementation of department activities.

4 MA.2 Plant Material Condition I The material condition of the plant should be maintained to support safe and

reliable plant operation.

MA.3 Work ControlSystem The control of work should ensure that identified maintenance actions are properly completed in a safe, timely, and efficient manner.

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APPENDIX II Page 3 MA.4 Conduct of Maintenance J

Maintenance should be conducted in a manner that ensures efficient and effective plant operation.

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MA.5 Preventive Maintenance j

u The preventive maintenance programs should contribute to optimum perform-ance and reliability of plant equipment.

1 MA.6 Maintenance Procedures and Documentation

'i Maintenance procedures should provide appropriate directions for work and a should be used to ensure that maintenance is performed safely and efficiently.

a' MA.7 Maintenance History 1 The maintenance history should be used to support maintenance activities and optimize equipment performance.

MA.8 Maintenance Facilities and Equipment Facilities and equipment should effectively support the performance of mainte-L nance activities. -

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TECHNICAL SUPPORT TS.1 Technical Support Organization and Administration

'i The technical support organization and administrative systems should ensure effective control and implementation of department activities.

1 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 j required limits.

3 TS.3 Operations Experience Review Program J

Industrywide and in-house operating experiences should be evaluated and appro-priate actions undertaken to improve plant safety and reliability.

i i TS.4 Plant Modifications Plant modifiestion programs should ensure proper review, control, implementa-tion, and completion of plant design changes in a safe and timely manner.

TS.5 Reactor Engineering i

On-site reactor engineering activities should ensure optimum nuclear reactor operation without compromising design or safety limits.

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[ APPENDIX II Page 4 TS.6 Plant Efficiency and Reliability Monitoring Performance monitoring activities should optimize plant thermal performance n and reliability.

1 3 TS.7 Technical Support Procedures and Documentation

] Technical support procedures and documents should provide appropriate direc-J tion and should be effectively used to support safe operation of the plant.

1 j TRAINING AND QUALIFICATION 1

. TQ.1 Training Organization and Administration u

The training organization and administrative systems should ensure effective

,] control and implementation of training activities.

TQ.2 Non-Licensed Operator Training and Qualification i

The non-licensed operator training and qualification program shculd 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 functions.

TQ.4 Shift Technical Advisor Training and Qualification The shift technical advisor training program should develop and improve the knowledge and skills to perform assigned job functions.

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TQ.5 Maintenance Personnel Training and Qualification The maintenance personnel training and qualification program should develop 1 and improve the knowledge and skills necessary to perform assigned job j functions.

TQ.6 Technical Training for Managers and Engineers The technical training program for engineers and managers should broaden u overall knowledge of plant processes and equipment as a supplement to

] position-specific education and training.

a TQ.7 General Employee Training The general employee training program should develop a broad understanding of employee responsibilities ar.d safe work practices.

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Page 5 l TQ.8 Training Facilities and Er4uipment J

The training facilities, equipment, and materials should effectively support training activities.

n R ADIOLOGICAL PROTECTION RP.1 Radiological Protection Organization and Administration 1

j The organization and administrative systems should ensure effective control and implementation of the radiological protection program.

s j RP.2 Radiological Protection Personnel Qualification L The radiological protection qualification program should ensure that radiolog-ll ical protection personnel have the knowledge and prectical abilities necessary y to effectively implement radiological protection practices.

, RP.3 General Employee Training In Radiological Protection General employee training should ensure that plant personnel, contractors, and visitors have the knowledge and practical abilities necessary to effectively j implement radiological protection practices associated with their work.

RP.4 External Radiation Exposure l External radiation exposure controls should minimize persor.nel radiation ex-posure.

a b RP.S Internal Radiation Exposure Internal radiation exposure controls should minimize internal exposures.

RP.6 Radioactive Effluents Radioactive effluent controls should mir:Imize radioactive materials released to 3 the environment.

7 RP.7 Solid Radioactive Waste 3

Solid radiosctive waste controis should minimize the volume of radioactive waste and ensure safe transportation of radioactive material.

J RP.8 Personr.el Dosimetry 3

The personnel dosimetry program should ensure that radiation exposures are

, accurately determined and recorded.

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APPENDDC H Page 6

-j RP.9 Radioactive Contamination Control Radioactive contamination controls should minimize the contamination of areas, equipment, and personnel l CHEMETRY J

] CY.1 Chemistry Organization and Administra4 ion 1

The organization and administrative systems should ensure effective imple.-

mentation and controlof the chemistry program.

I CY.2 Chemistry Personnel Qualification

] The chemistry qualification program should ensure that chemistry personnel j have the knowledge and practical abilities necessary to implement chemistry practices effectively.

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! CY.3 Chemistry Control 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 reporting of chemistry parameters.

CY.5 Chemical and Laboratory Safety

, Work practices associated with chemistry activities should ensure the safety of 1 personnel.

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