ML20076E861

Nuclear Mgt Appraisal Rept for Nebraska Public Power District

ML20076E861
Person / Time
Site:	Cooper
Issue date:	04/30/1983
From:	LRS CONSULTANTS
To:
References
NUDOCS 8308250052
Download: ML20076E861 (102)

Text

{{#Wiki_filter:. [()sS$f NUCLEAR MANAGEMENT APPRAISAL REPORT FOR THE NEBRASKA PUBLIC POWER DISTRICT f,, 4 BY 4 LRS CONSULTANTS 355 West 14th Street Idaho Falls, Idaho 83402 if e APRIL 1983

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e-TABLE OF CONTENTS Section Title Page

1.0 INTRODUCTION

1 2.0 ORGANIZATION, MANAGEMENT AND PERSONNEL 3 3.0 SAFETY COMMITTEES 28 4.0 LICENSING 34 1 5.0 ENGINEERING 38 6.0 OPERATIONS 45 i 7.0 MAINTENANCE 52 4 8.0 TRAINING 59 i 9.0 EMERGENCY PLANNING 67 li 10.0 QUALITY ASSURANCE 70 'l in 11.0 RADIATION PROTECTION AND ALARA 75 f 12.0 RADWASTE MANAGEMENT 82 l. 13.0 CHEMISTRY 86 14.0 ENVIRONMENTAL 89 15.0 PROCUREMENT, INSPECTION AND STORES 94 m '2 -4,s es i c--- - - - -, - - -, -,. + -. - - - + y .,,-w

LIST OF FIGURES Figure Title Page 2-1 SUGGESTED NUCLEAR ORGANIZATION 17 2-2 SUGGESTED NUCLEAR OPERATIONS DIVISION 18 ORGANIZATION 2-3 SUGGESTED NUCLEAR SUPPORT DIVISION 19 ORGANIZATION 2-4 SUGGESTED QUALITY ASSURANCE DIVISION 20 ORGANIZATION 11-1 WORKFORCE EXPOSURE 77 11-2 AVERAGE DOSE PER WORKER 79 12-1 SOLID RADWASTE (Measured in Curies) 84 12-2 SOLID WASTES (Measured in Volume) 85 14-1 GASE0US RELEASES 90 14-2 LIQUID RELEASES 92 l l t. l ii

.e s. -, LIST OF TABLES Table Title Page ? l 2-1 COMPARISON OF TEN NUCLEAR UTILITIES AND 23 NPPD OPERATING ORGANIZATIONS 2-2 COOPER NUCLEAR STATION ATTRITION 25 7-1 OVERDUE PM's 55 ? i ,f* 'l. f .]

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1.0 INTRODUCTION

In accordance with Agreement No. 83A-Cl and Amendnent No.1, LRS Consultants, Inc. (LRS) has conducted an appraisal of the Nebraska Public Power District's (the District) General Office corporate management organization responsible for and involved in the overall management, operation and support of the Cooper Nuclear Station (CNS), and the CNS supervisory organization. Emphasis was placed on safety and reliability of nuclear operations. However, wherever appropriate, efficiency of the District's nuclear program was considered. The factual basis for the findings in the report were derived from an evaluation of many documents and in-depth interviews with the NPPD staff and the Board of Directors during the month of March 1983. The recommendations in the report are based on LRS Consultants' judgment gained through extensive experience with similar nuclear utilities ar.d aimed at providing realistic options the District can pursue to remedy difficiencies. The major findings were cross-checked by the Consultants with each other and many members of the District's staff to. assure their validity and then LRS' recommendations were analyzed to assure they were practical, capable of being implemented and above all would contribute to a more efficient NPPD nuclear program. The report is organized into fourteen functional areas of Safety Committees, Licensing, Engineering, Operations, Maintenance, Training, l, Emergency Planning, Quality Assurance, Radiation Protection, Radwaste Management, Chemistry, Environmental, Procurement and Stores, Records Management and Document Control. Also included is a section titled Organization, Management and Personnel. It is in this latter section that the major cross-threads of common problems brought out in the 5 -- fourteen functional areas are summarized and presented along with an overall look at the complete organization that includes the plant, the General Office and the Board of Directors.

4... As is the case in any management appraisal report there is a i* tendency to concentrate on negative areas. It is in these areas the problems lie and where the organization must concentrate its energies to effect change. However, any appraisal would do the District a disservice if it did not mention the tremendously successful operating record of

i the Cooper Nuclear Station and the hardworking, dedicated personnel in the nuclear sector.

i l' The Cooper Nuclear Station with its eighty-one percent cumulative availability factor through 1982 is first in the nation among BWR's - -

t some twelve percentage points, above the average of similar plants.

This lI fact coupled with the good economy of Cooper Station power generation, 1, averaging around twenty mills / kilowatt hour as opposed to an industry s

i average of approximately twenty-seven mills / kilowatt hour, saved the District rate payers some $37 million in the approximate 5.3 billion

,e kilowatt hours generated in 1982.. 34 l' It is in the spirit of maintaining this outstanding operating performance while recognizing the changing regulatory climate and the t;j increased competition for nuclear trained personnel that the recommendations l1 in this report are made. l lL I i i l* i e-1 {3 L 1 1 i ! p l bs v., - - - m~,--., . -... - -.-.--,,-- _--, m. -

i 2.0 ORGANIZATION, MANAGEMENT AND PERSONNEL t' The objective of the NPPD General Office corporate organization as it relates to the nuclear sector is to provide for the safe, economical generation of electricity from the Cooper Nuclear Station. i' Corporate management discharges its responsibility towards meeting 4. this objective byhestablishing: I An organization framework and qualified personnel to staff the o organization. Policies and procedures outlining the nuclear sector's goals o and objectives, how the organization is to function to meet those goals and how those goals fit into overall District goals. 'd. A feedback mechanism to measure the organization's perfonnance o in meeting those goals. 8 o A method of assessing the performance of key management personnel and a mechanism to assure that succession of key personnel is a well planned activity. . t The necesssary administrative support functions such as f, o Personnel, Financial, Procurement, Legal and Records are responsive to and support the nuclear sector. l1. I An independent audit capability, separate from the line o N-organization, in the fields of nuclear safety and quality assurance, i 6- { ' 1 i I., l !? ! ___.__,...c_.,___,,,

2.1 Organization In reviewing the organizational structure of the District it is obvious that the Board of Directors must be considered, since the corporate powers of the District are, by statue and the by-laws, vested in and exercised by the Board of Directors. Although presumably in common practice, the General Manager (GM) could be delegated equivalent responsibilities and authorities to those of a Chief Executive Officer of an investor-owned utility, the summary of the GM's duties and responsibilities (Resolution No. 433, passed in 1946) do not officially delegate much apparent authority to that position. Further there do not exist position or job descriptions for the General Manager or Assistant General Manager's (AGM) so there is a marked lack of clarity regarding responsibility and authority at the top minagement level in the District. To lay the foundation for a discussion of the District's organization, the following summary of Board powers and General Manager duties and responsibilities is recapped from pertinent by-laws and resolutions. Board of Directors The corporate powers and control of the District shall be vested in and exercised by the Board of Directors subject only to those delegations of authority to the officers and employees of the District as shall be adopted by the Board. The Board shall select the General Manager. 4,,

~ General Manager The General Manager shall advise and consult with the Board of Directors on all matters pertaining to the operation of the District and shall be the Chief Executive Officer of the District in enforcing the legislative action of the Board of Directors. The General Manager shall have general supervision and control over all employees of the District except as i otherwise provided in these by-laws, by resolution of the Board or by contracts of the District. A summary of the 1946 resolution defining the Duties and Responsibilities of the General Manager which purport to be i " powers and duties" follows: 4 A. General direction and control of all operations subject t to the rules and regulations of the Board and is Chief Administrative Officer of the District. i B. Attend Board meetings. I C. Provi.de Board with a monthly report. 1 l D. On or before November 1st of each year provide the Secretary and Controller copies of the budget for the ensuing year. l4 E. Provide recommendations on all contracts or agreements pertaining to electric service or to general operations to the Board for approval. Authorized to execute agreements on street lighting, water pumping, wholesale power, [ . right-of-way, residential, commercial and industrial f' service, but must report all such agreements to the Board at the next following meeting. .4 '9. i._

i i F. May (with Controller approval) prescribe rules and regulatio.:s for expenditures of operations and maintenance funds up to $50,000. In excess requires prior approval of the Board. G. Certify to the Board that supplies, equipment, materials, etc., are received before funds can be expended. j H. Responsible for money until deposited. l' I. Recommend employment, dismissal, transfers, etc. Compensation of all employees is set by the Board. The GM recommends wages, salaries, rules, regulations and working hours, governing employees. J. Prepare rules and regulations on conduct of business i including duties of all employees for approval by the Board prior to implementation. 3 K. Responsible to keep proper books of accounts. 1, il L. Generally administer the District in an efficient and economical manner. ( ) t 9 l 1 i

2.1.1 Board Organization / Staff Interfaces l Although the foregoing describes the formal relationships at the Board of Directors / General Manager interface, of '~ much more interest and pertinence is how the interface is really working. This latter is somewhat difficult to determine today in view of the recent change in General i Managers. During the last several years of the previous i GM's term, the relationship was not totally satisfactory, resulting in a number of problems that did not stop at the Board /GM interface, but permeated the entire organization. Without attempting to fix any blame, the following listed problems detailed below as findings are perceived to 1 exist at the Board / General Management level. I 2.1.1.1 Findings i o Neither the Board nor General Management have defined the long range plans and goals for the District. i i o The Board does not appear to be a policy organization 1 but appears to be too involved in many details that 1-would be better left to management. .t o Top management appears in'some cases to be intimidated l, by the Board and in other cases has given up trying to get things done out of frustration. l o The Board has persuaded management and even the lowest levels of personnel that the only thing that is important is reducing costs wherever and however 1*- possible. l' i.- u U % l

o There is a strong feeling on the part of the staff that they are not trusted by the Board. Conversely, there have been numerous actions by management in recent years that fostered such a feeling. o The poor relationship between legal and management has been largely eliminated under the new General Manager. o It is not clear that the Board recognizes its potential impact on CNS plant safety and operational effectiveness through its approach to personnel and purchase actions. o It is also not clear that District, management has i done an adequate job of presenting the nuclear organization and CNS's needs to the Board. o Management has also not done an effective job in presenting to the Board, the impact of what happens in the rest of the nuclear world on NPPD. o The District has drifted for the past several years with minimal general direction from the B'oard or General Manager and inadequate teamwork below the level of the GM. o Some key nuclear management staff have had less than optimum relations with some members of the Board. 6 o._ ..-m._-.._ ..._,-....___..__.__v ,.__.....-_,._x,,,.

2.1.1.2 Recommendations The following recommendations should be considered. OM-1 The Board should develop some long range overall Goals and Objectives for the District that could be adjusted from time to time but would survive Board member changes. OM-2 The staff should develop near term and long term strategies, plans and programs throughout the organization that will accomplish the Board's overall direction. OM-3 The Board should consider more definitive delegation of broader authority to the General Manager thus removing itself further from operational details. A clear job description would be necessary in this regard. a i' OM-4 Top management needs to improve significantly its nuclear communications to the Board, which in turn needs to be receptive. OM-5 Team work between the Board and management based on mutual trust and respect, needs to be developed. 1I ' l-OM-6 Top management needs to make some hard and possibly unpleasant decisions to gain credibility with the Board. ,i OM-7 A planned program ~ needs to be developed for assuring the continuing provision to Board members of critical nuclear info rmation. This should not be accomplished with pounds of documents but by carefully abstracting vital information i._ from NRC, NSAC, INP0, NPPD and other utilities and providing approximately a one or two page summary each ' ' ~ week. This document might serve a useful function for lt-senior staff also. I !l" 3. I' _g. ,-e e .ci e+--m ---r

~ 2.2 District Organization and Management The organization of the District appears to have been quite fluid in recent years at the top management levels below the General Manager. This fluidity does not seem to have significantly affected operation of CNS since "~ most direct line managers above the Station Superintendent and other General Office managers have exercised minimal management authority or control with regard to either operation or support of CNS. 2.2.1 Discus _sion The present structure of the District results in all four Assistant General Managers being involved to some degree in the operation or support of CNS. The AGM - Operations has the bulk of the nuclear activities reporting to him through a Senior Division Manager for Power Operations. The Senior Division Manager is the only senior division position in the District and effectively interjects an additional management layer between the Station and the General Manager, without adding a management level that i has added authority to make pcsitive decisions. The AGM - Operations is the only AGM that devotes more than i 25% of his time to nuclear activities which must be difficult considering the extent of his other responsibilitie's. At the division level in Operations, there is only one manager whose time is devoted solely to nuclear. The l division manager to whom the CNS Superintendent and Nuclear Fuel Manager report spends less than half time on j nuclear matters, about the same as the senior division i i manager to whom he reports. l l

f The functional organizations reporting to the AGM's for Corporate Services and Finance and Administration through several division managers include purchasing, safety, training, personnel, realtime systems and records support to the nuclear organization. The time allocation of these organizations to CNS and other nuclear support areas varies from a small percentage to greater than 50%.

Structurally, the General Office (GO) engineering support to CNS is located in the Power Projects Division that reports to the AGM - Engineering and Construction. This 3, l: division manager spends about 33% of his timp on nuclear activities and the AGM much less. p There are not in existence functional descriptions of the organizational responsibilities for any of the AGM areas and consequently they also do not exist for the subordinate h organizations. Job descriptions also do not exist for 1 the AGM positions. The only position / job descriptions that exist in the q District are below the level of the AGM and are Hay questionnaires that have been filled out by incumbents in i most' cases. These generally do not contain clear definitions of functional interfaces with other organizations or positions, nor necessarily accurate descriptions of the position responsibility and authority. The Hay points appear to have been adjusted to artificially inflate the 1 value of some positions to the detriment of other key positions, including some in the nuclear organization. e-en e cm

There is an apparent lack of willingness on the part of many District managers to make hard management decisions, even when it is clear that higher management and/or the Board would probably support the action. Line management in the General Office with responsibility for the nuclear plant operatij ;do not appear to have actively sought, in recent years, to manage or control how the CNS is managed and operated. At the same time, the Station Superintendent has tended to isolate CNS not only from NPPD, but from what is current in the industry. Management training and development as well as succession planning do not appear to be formalized programs in the District. Due perhaps the lack of clarity in lines of responsibility, a " management by committee" syndrome has developed with the AGM's comprising several of the committees Also, perhaps due to the concentration of the Board on details, there appears to be and excessive concentration by AGM's on technical and/or minor details rather than management direction. It is not clear that an effective method of project control exists within the G0 or at the CNS to monitor progress and signal problem areas. It also appears that there is little effective communication or teamwork between the G0 and the CNS. i I i - - -.-. -

2. 2. 2 _

Findings The following summarizes the significant findings in this area. o-All four AGM's are involved in-line or in-support of f CNS. t o There is too little effective attention given to nuclear activities on the part of senior and top management as well as the Board. 1 o No one at the AGM level is fully devoted to nuclear and there is no one at the AGM level that is in a position to interface effectively with the Board of 4-Directors on nuclear matters. P o Two excess layers of management exist between the GM and the CNS Superintendent. o The AGM - Operations has a disproportionate share of non-nuclear responsibilities vis-a-vis the other I AGM's, which dilutes his ability to concentrate on nuclear matters. t-1. o The key support function, nuclear engineering, is F split between two AGM's and therefore coordination 3' of this function is poor. 9-b. ? h* ?- o Key positions at CNS appear to have been under-cvaluated in comparison to 'some of the G0 and non-nuclear positions. o The lack of functional organization jurisdictional 3, statements and individual job descriptions results in confusion as to responsibilities of organizations and individuals. t o Nuclear management outside the Cooper Station appears to be more by default than by active intent. o The CNS Superintendent is essentially unsupervised. o General Office support to CNS has been weak and inconsistent. o The combination at CNS of a dictatorial management style, poor personnel policies and communications is judged to be a significant factor in the high plant attrition rate. i' o There have been limited opportunities for management promotion in the Cooper Station. Some individuals who appeared to be in grooming to succeed to Plant Superintendent have left due to the apparent restrictions l l* on their promotion possibility. o There has been no upward mobility in the entire nuclear organization. Most management positions 7 o (sometimes by different titles) have incumbents with i many years in the position. o There is limited non-NPPD related nuclear management experience in the District. {

2.2.2 Recommendations The following recommendations are made with respect to the organization and management of the District Staff. OM-8 Establish the position of Assistant General Manager - Nuclear, with clearly defined responsibilit'ies, duties s and authority. OM-9 Either assign an AGM - Nuclear from within the District or if no one internally is deemed qualified, select an Acting AGM and initiate recruiting efforts promptly. OM-10 Consider organizing the Nuclear Operations of the District in general accordance with the attached organization charts, Figures 2-1, 2-2, 2-3 and 2-4. OM-ll Develop jurisdictional statements for the nuclear organization and for its components. 0M-12 Develop clear and accurate position descriptions for all I key nuclear and nuclear support personnel. OM-13 Several present line and support management personnel should be considered for removal from the nuclear management structure of the District to allow for promotions and/or i new personnel. l'- OM-14 Active involvement of General Office management in the CNS must be developed. Conversely, CNS management needs i to eliminate the isolation it has established and become active participants with the General Office. 9. Se -

4 .l., OM-15 Management training and development programs need to be implemented for the nuclear managers and supervisors. I l' OM-16 The District needs to develop a succession planning 4 program, especially for key positions such as CNS Superintendents, division managers and the AGM - Nuclear. \\' OM-17 Delegation of signature authority for routine matters should be encouraged and supported at all levels of management. OM-18 Management and the Board should recognize the hazards J to safe and efficient operation resulting from high t,- turnover of key personnel at CNS and take action to reverse this trend. i. OM-19 Recruitment of supervisory personnel with nuclear and management experience for assignment to CNS and the i il General Office should be a high priority effort of the

i' District.

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FIGURE 2 - 1 SUGGESTED NUCLEAR ORGANIZATION i GENERAL MANAGER ASSISTANT GENERAL MANAGER - NUCLEAR TECHNICAL STAFF ii ASSISTANT !4- .a 9 NUCLEAR SUPPORT NUCLEAR OPERATIONS QUALITY ASSURANCE l DIVISION DIVISION DIVISION l. e i._,

FIGURE 2 - 2 SUGGESTEDNUCLEAROPERATIONSblVISIONORGANIZATION ASSISTANT GENERAL MANAGER - NUCLEAR NUCLEAR OPERATIONS DIVISION - CNS i TECHNICAL SUPPORT OPERATIONS

G.O. SUPPORT ADMINISTRATIVE SUPERIl4TENDENT SUPERINTENDENT COORDINATION SERVICES MGR 3

4 f REACTOR OPERATIONS Stores l ENGINEERING Clerical - Security TRAINING MAINTENANCE Purchasing Personnel PLANT CHEMISTRY & ENGINEERING HEALTH PHYSICS Records j o-0... o

FIGURE 2 - 3 SUGGESTED NUCLEAR SUPPORT DIVISION ORGANIZATION t o ASSISTANT GENERAL MANAGER - NUCLEAR a 1' t NUCLEAR SUPPORT DIVISION l I 4 NUCLEAR NUCLEAR NUCLEAR LICENSING EMERGENCY ENVIRONMENTAL ENGINEERING AFFAIRS FUEL PLANNING 9 S. I l, ~ l \\

FIGURE 2 - 4 SUGGESTED QUALITY ASSURANCE DIVISION ORGANIZATION ASSISTANT GENERAL MANAGER - NUCLEAR OVALITY' ASSURANCE 8 DIVISION i 0FFSITE AUDIT QUALITY ASSURANCE ADMINISTRATION SUPERVISOR - CNS SUPPLIER AUDITS ENGINEERING & CNS OPERATIONS MAINTENANCE PURCHASING 0FFSITE ADMINISTRATION C0ORDINATOR AUDITS MODIFICATIONS

2.3 Personnel As has been demonstrated in numerous serious or potentially serious incidents in nuclear power plants, the major factor in avoiding or mitigating the effects of critical hardware failures is the overall capability of the a operating personnel involved. The condition of the highly complex equipment in a nuclear plant is highly dependent upon the quality, experience and dedication of the maintenance (I&C and mechanical) personnel who keep the equipment functionally in good operating condition. Similar comments can be made about the radiation protection, quality assurance, engineering and supervisory personnel. 4, In other words, the safety and efficiency of nuclear plants-is largely dependent upon the quality of the il i; personnel involved in the operation and support of the

s plant.

1~ .i 8 2.3.1 Discussion and Findinos lJ For many years ex-nuclear Navy personnel provided the core of plant operating, I&C and supervisory personnel 'lj for the nuclear utility industry. In recent years, however, this source of, manpower has been reduced at the same time that demands have increased, for example, due n. to new plants coming on line, NRC dictated expansions of operating crews, increased complexity of systems and increased training requirements. The results of these J-factors has been increased pressure to recruit trained, I - experienced and qualified personnel from other nuclear utilities while at the same time establishing good training programs to develop the necessary skills starting with high school, vocational-technical school or college graduates. l.. l H {:

2.3.1.1 Staffing . Staffing levels in the District are low in comparison to other nuclear utilities. In fact, compared to the operating staffs of ten nuclear utilities reported in an internal nuclear utility study, NPPD's staff of approximately 219 personnel is significantly less than the ten unit average of 337 personnel. (A comparison by organizational element is included in Table 2-1.) As noted in the study, caution should be used in applying the data, as local regulatory requirements, labor agreements, etc. can be important influences on staff size. There are some key areas in which the District is cbviously comparatively understaffed, including Quality Assurance, Training and Maintenance. There are also some areas such as plant, home office and nuclear engineering in which the numbers are close, but in which the overall and plant-specific experience of the District personnel is very low. As discussed in Section 6 - Operations, the numbers of personnel in operations is close to the average. However, attrition has resulted in expediting I plant equipment training and then licensed training 3 leading to a situation where the average plant-specific experience level of operators in all categories is less than desirable. As a general comment, it appears that both the staffing level and the average level of experience of the NPPD staff are lower than desireable for optimum support to maintenance, modification and operation of the Cooper Station. 8, S-..

TABLE 2-1 COMPARISON OF TEN NUCLEAR UTILITIES AND NPPD OPERATING ORGANIZATIONS Function Ten Utility Average

• NPPD*

Operations 59.0 49 r Plant Maintenance 93.9 60 t Plant Engineering 25.8 22 Chemistry 10.8 5 1 Health Physics 22.8 11 Training 17.8 2 Off-Site Licensing 4.1 4 Home Office Engineering 28.7 26 i QA/QC 23.4 8** a-Off-Site Environmental 5.2 4 Off-Site 1 Nuclear Engineering 9.0 2*** 1 Reliability 3.3 0 i Procurement and

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Stores 9.8 3 Office Services 19.7 23 Off-Site s. Radiological Controls 4.1 0 i Total 337.4 219 Em Includes vacancies and in some cases equivalent full time personnel. QA only, QC is included in the plant staff. Nuclear Fuel personnel. 3 u..

2.3.1.2 Attrition In reviewing the Cooper Station attrition history tabulated in Table 2-2, there are some indicators that should concern NPPD management. First, the attrition rate seems to be increasing. Averaging around 10 per year in the 1970's, the attrition rate increased from 9 to 15 to 18 for 1980,1981 and 1982 respectively. Also, according to the preponderance of those interviewed, ur.less significant h changes are made, the attrition rate will remain high. Second, the high attrition is in areas that hurt the organization the most - - engineering, licensed operators and I&C technicians. These three groups represent the highest skill levels at the plant, are the most difficult to recruit and. require. the most plant-specific training to become effective. Obviously there are many factors at play in the attrition '~ problem but the most important factors were loss of job 2 satisfaction, NPPD personnel policies and an overall sense that the Cooper Station organization is stagnant.

i The stagnation or lack of any movement up or within the l[l organization, was uppermost to the engineers but it also plagued the operators and technicians that in CNS, once an operator / technician - - always an operator / technician.

1 The stagnation was also very apparent when tracking the l-flow of personnel between the Cooper Station and the L General Office. With the exception of two or three persons leaving CNS before the Station went' critical, there has been no cross-fertilization. This lack of a healthy natural circulation between the plant and the General Office is no doubt a source of some of the friction that exists between the organizations.

-..~.;._, i I l 6 TABLE 2-2 l i COOPER NUCLEAR STATION ATTRITION l i I l YEAR TOTAL MECH I&C ELEC LIC OP STA OP ENG ADMIN HP 1 i 1971 3 1 1 1 l 1972 6 1 1 1 2 1 1973 6 1 2 2 1 1974 11 2 1 1 3 3 1 !b 1975 9 1 1 3 4 l 1976 9 1 2 2 1 3 i 1977 4 1 1 1 1 ] 1978 13 3 2 4 2 2 l 1979 9 2 1 2 2 1 1 t 1980 9 2 2 2 2 1 1981 15 2 1 4 1 5 2 1982 18 1 5 3 1 5 2 1 l l 1983 5 1 1 1 2 i TOTAL 117 11 16 3 21 11 28 17 10 i S i i k i

2. 3.1. 3 Compensation and Benefits In reviewing the salaries and benefits of personnel in the nuclear organization several items were noted as follow:

1 a o A few positions appear to have salary midpoints that i match the industry competition reasonably well. If o Below the Plant Superintendent at CNS there are some mismatches in comparison to similar positions in other nuclear plants. o The engineering salaries appear to be competitive at the entry level positions. o The recently implemented license bonus for licensed reactor operators although tardy, was a positive move. 3 o A residence mortgage assistance policy for new hires I and transfers does not exit. 1 2.3.2 Recommendations The following recommendations regarding Personnel that are not covered in other sections of this report and that should be considered follow. ,[ OM-20 The District should assure that their compensation policy is competitive with the rest of the nuclear industry. ha 04

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Benefits should be evaluated and modified, if required, OM-21_ to assure the ability of the District to attract new, senior nuclear personnel and to transfer present personnel as needed between the G0 and CNS. Line nuclear management needs to work closer with the 05-22 recruiting personnel to better assure meeting the staffing needs of CNS and supporting organizations. Personnel in supervisory or management positions that l t OM-23_ are impeding the growth potential of more productive employees, should be considered for reassignment to allow upward movement of present subordinates. The staffing level and average competence / experience i OM-24 level of the s'taff need to be increased through active l l recruitment and acquisition of experienced nuclear persone, through improved training of present personnel and throogh significantly reducing attrition. 1 [ t 3.0 SAFETY COMMITTEES _ There are two committees required by NPPD's license from the NRC to tions be in place and performing in accordance with the CNS Technical Spec These committees are the Safety Review and Audit Board (TechSpecs). (SRAB) consisting entirely of General Office personnel and the Statio 3 Operations Review Committee (S0RC) with membership solely of The performance of these committees in fulfilling the Tech Spec requ as well as thhrbroader mission of helping to assure safe operation of the Station were evaluated and are discussed separately in the following i sections. j Station Review and Audit Board (SRAB)_ 3.1 The SRAB is required to do the following: Verify that operation of the plant is consistent with o company policy and rules. Approve operating procedures and operating license provisions l o Review safety related plant changes, proposed tests and o procedures. Verify that unusual events are promptly investigated and corrected in a manner which reduces the probability of o recurrence of such events. l Detect trends which may not be apparent to a day-to-day l o observer. l I 3.1.1 Discussion _ A review was performed of the SRAB Charter and implementing procedures, Section 6.2 of the Tech Specs and minutes of

Also, l

all meetings of SRAB for the past two years. i~ interviews were conducted with all SRAB members and s 1 alternates. p-l l ~. - -

The SRAB Charter was originally issued in March 1973 and was revised in July 1981. The present Charter revision plus the implementing procedures, also revised in July and August of 1981, are generally consistent with the Tech Spec requirements. The Charter and procedures do rat include the necessity to review some of the industry related information such as INP0 operational assessment reports, NSAC significant operating event evaluations or any of the various NRC bulletins, notices or other documents related to operational safety of nuclear power plants. Although these industry and NRC documents are not required by CNS Tech Specs to be utilized by the SRAB, they can be beneficial to that Board in its deliberations of safety concerns and operational problems. As the importance of the safety review functions performed by off-site safety review committees has come to be recognized in the industry, many utilities have implemented 2-y training programs for their SRAB members. This training a can include plant specific systems lectures, simulator demonstrations and. lectures and discussions on safety evaluations, unreviewed safety questions,10CFR Part 21, 50.59 requirements, SRAB Charter and procedures. i The SRAB Charter states that Board members will witness selected operations, such as reactor startup, reactor shutdown, refueling and survei11ance activities. F i. 3.1.2 Findings b-(, There are several significant findings in the area of the SRAB operation as follow: f M D t-M

o Very few of the required reviews are performed in committee, with the normal review methodology being the routing of documents to the members. This method of review does not have the advantage of interactive discussions. o Seldom are items of safety concern brought to SRAB meetings for resolution by the full Board and the minutes of meetings do not always reflect the resolution of those concerns. o The time available on the part of the middle management members to devote to their SRAB reviews is limited due to their many other responsibilites and duties. o An effort is underway to revise and improve the Charter and implementing procedures and to develop a training program for SRAB members. o The extent to which SRAB reviews the audit program, operating procedures or proposed tests is not clear. ~ o It is also not clear the extent to which SRAB members 1. witness plant evolutions on a planned and systematic basis. 3.1.3 Recommendations The following recormendations should be considered to improve the performance of SRAB: S-1 Consideration should be given to a more formalized ~ review of items of potential safety significance l in committee. ' l ls. . -..,. - _ - _ - ~

S-2 Consideration should be given (a) to expanding the Board size to enhance the coverage of all the necessary disciplines and technical competence required, (b) to designating members with more time to devote to the reviews and (c) to including at least one member i of 50RC on the Board. S-3 A training program should be developed and implemented. S-4 Assure the active support of the General Manager to the SRAB and assure the independence of the Chairman. l 1 S-5 A review should be performed to assure that all activities specified for SRAB review or other activity (e.g., audits, witness of plant operations, procedure reviews, etc.) are being performed according to prescribed methods and schedules.

s S-6 Consideration should be given to review by SRAB of

' ~ the various industry and NRC operational event 1' information. I 3.2 Station Operations Review Committee (SORC) 8 i l The function of SORC is to review and/or investigate a wide r variety of documents and/or events such as the following: o Normal, abnormal, maintenance and emergency operating procedures. 1-o Proposed tests and experiments involving nuclear hazards. i, o Proposed changes to Tech Specs,' license and FSAR. o Proposed changes to station systems. b 4 - " ~

o Station operation to detect potential unsafe conditions. o All reported instances of Tech Spec violations. o All events required to be reported to the NRC in writing within twenty-four hours. 1j' o Drills on emergency procedures. o All procedures required by Tech Specs including the Emergency Plan and the Security Plan at intervals of not more than two years. The reviews of SORC provide advice to the Station Superintendent and to SRAB. 3.2.1 Discussion and Findings The methods of operation of the CNS SORC is somewhat unusual in that most of the Tech Spec required reviews i are conducted by the members on their own. These reviews are documented, signed off and form permanent records of .s the S0RC reviews. A few minor concerns exist with regard l' to the SORC activity as follow: s. l o It is not obvious that individual review of matters having safety concern is as effective as the dynamic interplay of a committee, meeting as a bcdy. o The administrative procedure establishing the method of operation of SORC (AP 1.18) does not indicate how l reviews will be documented of proposed changes to the Tech Specs, license and USAR which are routed to l appropriate SORC members for review rather than it being reviewed in SORC meetings. i e. l ~

o There appears to be a possible inconsistency between the Tech Spec requirements for review of drills on emergency procedures and AP 1.18. o At CNS, 50RC approval can be based on reviews conducted outside of the meetings with the minutes not reflecting review of this material. It is not clear that this is completely consistent with the Tech Spec requirements. 3.2.2 Recommendations Recommendations related to SORC are as follow: 2' S-6 Consideration should be given to assuring that all items of potential safety significance are reviewed in a meeting. S-7 Any inconsistencies between the Administrative Procedures (i.e., 1.18, 1.3, 1.12, 1.10, 1.13) and Section 6.2.1 of the Technical Specifications need to be rectified. a. a 't i_ .i it. [ e. l in. -^ %.

4.0 LICENSING The primary objective of the licensing function is to assure that the Cooper Nuclear Power Station operating license is kept current. To accomplish this, the licensing organization should: o Provide a working level interface between NPPD, the NRC and the state and local governments in the areas of reactor regulation, inspection and enforcement. o Maintain a formal licensing commitment tracking system for outstanding comitments and confirmatory issues to assure meeting NPPD's commitments. o Support the line organizations in license related activities. o Provide a method by which management is kept current on licensing issues that could have a significant safety, technical, cost or schedule impact on plant operations. o Be of sufficient size and depth of experience to operate in a 1 pro-active mode with regard to potential new licensing issues. ll Pro-active means that during the regulatory requirements and rule making process, NPPD's technical comments, interests and viewpoints have been sufficiently researched and effectively i entered into the process. This can be accomplished through a direct, owner groups, or regulatory response group participation. 4.1 Discussion The NPPD Licensing organization is composed of a Licensing Manager, a Licensing Engineer and a Licensing Specialist. Both the Licensing Manager and Engineer have approximately five years of civilian nuclear power licensing experience, including other nuclear utilities, and prior nuclear navy experience. The group is backed up and receives licensing direction from the Division Manager of Licensing and Quality

Assurance who has twenty-five years of nuclear experience including ten years as the principal NPPD spokesman on licensing issues relating to Cooper Nuclear Station. The licensing group maintains a formal licensing commitment tracking system for corporate level licensing issues. As the licensing organization is the formal receiving and distributing point for all NRC correspondence, it is the responsibility of that group to keep management informed of all pertinent licensing issues. Due to the relatively small size of the group and its understood role, licensing does not develop responses to NRC requests or requirements. Rather, the group functions mainly as a technical secretariat, passing assignments on to other departments in the District. The group has not in the past, nor does it feel it is in its present charter to pass technical judgement on or to verify the factual correctness of the material it receives from the operating and engineering organizations. The group l functions in a staff capacity and feels it is line management's responsibility to attest to the gaality of the work done in the line organizations. i The licensing group has been judged by previous NRC SALP reports to be an effective and responsive grpup in responding l to licensing requirements. The group does not, however, feel it is operating in a pro-active mode in terms of getting out in front of the major issues and influencing the regulatory process. NPPD does belong to the GE Owners Group and the BWR I Regulatory Response Group, is a member of the AIF, EEI, INP0, NUTAC and supports EPRI. O .O 9" 8

In its role as the technical secretariat for licensing issues, the licensing group is the primary, and judged by the majority interviewed the most effective, method of communications between the General Office organization and the Cooper Station. t

4.2 Findings

The principal findings in the area of Licensing are as follows: o The licensing group appears to function smoothly in handling the bulk of the work dealing with licensing issues. o The computerized commitment tracking system for commitments that are derived by or flow through the licensing group is excellent. However, the system does not track those commitments generated by the CNS through submission of Licensee Event Reports (LER's). There is no formal system to track LER related commitments at CNS. o The size of the group seems appropriate if it is to function solely as a technical secretariat. It is not staffed to direct, from a technical point of view, the work being done in support of licensing in the engineering 4 and operations organizations. Nor is it charged with responsibility to pass judgement on the correctness of the material provided by line organizations. o It is not clear by what authority the Division Manager for Licensing and Quality Assurance operates under when transmitting information from NPPD to the NRC. The fact that the licensing organization operates mainly as a staff function but appears to have some form of line management responsibility when transmitting information to the NRC is confusing and could lead to some serious communications problems. i.. [, --

o Equally unclear is the Division Manager's responsibilities to attest to the correctness of the material transmitted over his signature if that material was supplied by the line organizations. Spot checks reveal that information supplied by the CNS organization and transmitted to the NRC by the Division Manager for Licensing and Quality Assurance can be misleading or even factually incorrect without Licensing being aware of the situation. l 4.3 Recommendations The following Licensing related recommendations are made. L-1 The corporate signature authority in transmitting official, attested information to the Nuclear Regulatory Commission should be changed from the Division Manager for Licensing and Quality Assurance to the i Assistant General Manager having line management responsibility over the operation of the Cooper Nuclear Station. While the licensing group would still play its extant role in disseminating and collecting licensing information, the official transmittal to the NRC would have the benefit of 4 line management authority and accountability. L-2 A formal system should be implemented to track NRC commitments made at CNS through LER's or other documents. L-3 Consideration should be given to expanding the licensing staff by one individual to allow pro-active participation in future licensing issues. = ~-m e..- ,,,-.,,~-,.....,.,._.m~. .m,-

5.0 ENGINEERING The primary objective of the engineering function in the District should be to provide the necessary engineering support to maintain safe and economical plant operations. Of equal importance to the maintenance cf day-to-day operations, the engineering function should continually analyze plant performance and recommend modifications in plant systems or procedures to enhance the performance or safety of the plant. l The engineering function should also be charged with the responsibility of configuration management of the engineering design bases and the as-built condition of the Cooper Nuclear Station. To accomplish these tasks the engineering function should be staffed with personnel in the technical disciplines of nuclear, mechanical, \\ electrical, civil and chemical engineering, instrumentation and controls, thermal-hydraulics, metallurgy and chemistry. As a minimum, the staffing should be of sufficient depth to bear the primary technical responsibility of the engineering work even if the work is contracted. 5.1 Discussion o There are two separate and distinct engineering groups that provide overlapping engineering support for the Cooper Station. While each group possesses approved procedures by which it accomplishes engineering work for CNS there is no overall charter or interface document that describes the responsibilities or interrelationships of these two engineering functions. In fact, the two groups report up through two different Assistant General Managers which could lead to technical problem resolution at the General Manager level or conversely to resolution by j de faul t. 9.. .. -... - - _ -,. - _,,,,. _, - _ _, - - - _ _ _ - ~ _ _. _,,..,,., .-_..-7-.

The General Office engineering group is presently staffed with twenty-three engineers, co-op students and technicians with an authorized level of twenty-six. The Cooper Station engineering group is staffed to a level of twenty engineers and technicians with an authorized level of twenty-two. i Both groups received approval for significant increases in theirauth{rizedcomplementoverthepasteighteenmonths which resuTted in roughly doubling the size of both groups. In the General Office engineering group, eight of the fifteen engineers have one year or less experience with the Cooper Station and the remaining seven average slightly more than four and one-half years of experience with CNS. At Cooper Station, five of the engineers have one year or less direct experience at CNS, while the remaining seven average four and orie-half years there. On the subject of staffing, the rationale and justification for increased complements in each engineering group were handled apart from each other and the impact of one group's future staffing pit.ns was not considered by the other group. It appears the individual justifications were based mainly on the cost savings accrued by replacing contracted engineering support. l In the absence of any charter or interface agreement for the two engineering groups, the work assignment is informal. The Cooper Station engineering group tends to take the lead and assumes responsibility for those engineering activities they wish to pursue and Minor Design Changes (MDC's) that interact [' with plant operating systems. The General Office engineering function handles the overflow engineering load at the request of the station and tends to be assigned tasks that are isolated from active plant operations (i.e., the Emergency Operations L Facility and the Clean Water Fire Protection System). In O= P 6

this regard, the General Office engineering function operates as an architect-engineering firm with the Cooper Station as its major and only customer. Operating in this mode, the General Office engineering function bears no continuing responsibility for the engineering design basis or configuration management of the plant. In discharging its architect-engineering responsibilities to the plant, the General Office engineering group attempts to function in the project engineering mode. That is to say, the assigned General Office project engineer for a particular task . will be responsible for that task through the engineering design, fabrication, installation, checkout and acceptance testing. This womb-to-tomb project engineer concept is in general an excellent concept and aids in assuring that key elements of the job are not overlooked. However, the logistic difficulties encountered by a General Office engineer in closely following an engineering task at the Cooper Station tends to detract from the effectiveness of this project engineer concept. It is a three and one-half hour drive from the General Office i in Columbus to the Cooper Station which essentially rules out 8 that mode of transportation for anything but a multi-day trip. lj The NPPD aircraft have been used quite extensively in the b. past; however, the abandonment by the City of Rockport of the l Missouri Meatpackers airstrip forced the use of alternate, more distant airfields. As an example, Falls City which has an acceptable instrumented and lighted airstrip is some thirty-five miles from Cooper Station. A typical CNS workday for a General Office engineer, when you factor car rental and driving time to and from Falls City, is a short four and one-half hours. The effectiveness of the General Office engineering o-group has been severely ympered by this logistics problem. i Os O ' O- -.,n- ,,,. - -., +.. - - -, - -. - -

The morale and effectiveness of the Cooper Station engineering group appears quite high. Each engineer is assigned a specific set of systems as his responsibility. The performance of those systems and any changes in operating procedures or modifications come under the scrutiny of the system engineer. In addition, there is a scheduled plant systems training program that allow; a new engineer to become familiar with the total plant as an operating system. This system training is handled within the Cooper Station engineering group and appears to be a good start at a plant systems training program. The working relationship between the General Office engineering group and the Cooper Station is less than satisfactory. There is a general lack of confidence by the Cooper Station personnel in the qualifications of the General Office engineering personne1. Consistent comments by the Cooper Station personnel were that the General Office engineering personnel were inexperienced in the CNS plant systems, procedures and how to get work done at the plant. There was also evidence of a great deal of resentment t ~J that General Office engineering personnel work forty-hour weeks and spend very little effective time at CNS following their projects. On the other hand the General Office engineers feel that they are treated as second class citizens when at the site, having minimal office space assigned and suffering what seem to be interminable delays in getting access into the, controlled areas even though they are badged. The above attitudes are further exacerbated by an open and acknowledged poor working relationship between the General Office Engineering Manager and the recently resigned Cooper Station Engineering = Supervisor. 1 In a positive vein, a major reason the CNS has such an excellent, low fission product release history and is such a radiologically 't. clean plant is that the reactor engineering function has done G w.. . ~, - - -

an outstanding job of minimizing fuel failures caused by pellet / clad interaction. This has been accomplished through strict adherence to the Pre-Conditioning Management Recommendation ~ ~ ~ program (PCMR) administered by the reactor engineering section. The reactor engineers work directly with the control room operators during power ascension and are on twenty-four hour call to aid in control rod pattern changes. 2

5.2 Findings

The principal findings in the engineering area are as follow: t o There is a lack of understanding, either formal or implied, I l as to how the engineering in support of the Cooper Nuclear Station is to be accomplished in the NPPD organization. o The existence of two engineering groups operating without [ clear charters and reporting up through two Assistant General Managers has tended to obfuscate responsibilities 9 and has helped to create a poor working interface between the General Office and the Cooper Station. i ' o The geographical remoteness of the Cooper Station from the General Office in Columbus makes day-to-day General 14. Office engineering support for the plant difficult and tends to further weaken the strained interface relationship. i. l o The low CNS related experience level of the General Office engineering group and the lack of a plant-specific systems training program in the General Office tends to weaken the Group's ability to support the station, o The poor working relationship between the two engineering group supervisors is judged to be a significant. factor in the deterioration of the working interface. ee a..

6.0 OPERATIONS The primary function of the operations group is to conduct plant operations in a safe and economical manner and in accordance with the Cooper Station Technical Specifications. To accon;plish this the operations group must be staffed with the requisite number of licensed personnel and trained plant operators. I The skill level requirements of the licensed reactor opers. tors are extremely high and are attained through extensive training and only then by dedicated and motivated personnel. The complexity of the job requires continual retraining as the plant is modified to keep the skill level of the operating crew at a peak. For the above reasons, training is one of the most important support functions to the operations group. The high skill levels coupled with a growing demand for trained and licensed operations personnel as new plants come on-line require that the District engage in careful planning to assure that there are sufficient numbers of plant personnel in the training pipeline to provide trained operators as conditions warrant. 4 6.1 Discussion li By several measures the operation of the Cooper Nuclear Power Station has been outstanding. In terms of availabil'ity factor, when compared against other BWR's of similar size and vintage, Cooper with its cumulative availability factor of 81.0% through 1982 is some 22.4 percentage points above the lowest BWR plant and about 12 percentage points above the ten unit BWR average. Even considering all BWR's, Cooper is the industry leader for cumulative availability factor beating out the Quad Cities 1 figure of 78.2%. I e. e-.. ,, - _ ~, _,.,. _. ~ -, _ _. - _ - - - _ ,,v___., . r. - - ,,y .~_.,,.- --

l 1 CUMULATIVE AVAILABILITY FACTOR THROUGH 1982 Brunswick 1 63.0% Brunswick 2 57.6% i Dresden 2 74.8% j,- Dresden 3 73.2% Fitzpatrick 69.1% Hatch 1 65.5% Hatch 2 69.2% Pilgrim 67.9% Quad Cities 1 78.2% 3 Quad Cities 2 76.1% .l \\ t_ Ten Unit Average 69.5% 0' .i q Cocper Station 81.0% lt

8 i

!Ii This high measure of performance is due to the excellent work of those who have designed, constructed, operated, modified ~ and maintained the plant. The nearly 1? percentage points of superiority represent a very substantial financial bbnefit to NPPD and its rate payers. s As remarkable as the operating reccrd is, it is even mere ( remarkable that this excellent operating reccrd has been [ attained with one of the smaller operating staffs. b. 4. 3 c ,, -, -. - -. - - - - -,.,--.,--, - - - - -.. - - - - - - ~ ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - -

h r. This fine operating record must not only be praised, but it must also be protected. The competition for nuclear trained personnel is ever increasing and NPPD cannot afford to rest solely on its record. The turnover rate at Cooper Station is high, resulting in the loss of seven senior reactor operators in the previous two year time period. Of the incumbent shift supervisors, ' senior reactor operators and reactor operators, only three shift supervisors and one senior reactor operator were at Cooper Station during preoperational and startup testing. Due to attrition at the SR0 level, new hires have been expedited through plant equipment and reactor operator hot license training resulting in R0's and SR0's with what LRS views as less than desired plant knowledge. This loss of experience must be made up by assuring that those who have the plant experience have the ability to pass it on to the newer operators through enhanced training efforts. Presently Cooper Station has fifteen senior reactor operating licenses and ten reactor operating licenses with a group of L. five in training. A normal crew is composed of a shift supervisor (SRO), an SR0 and two R0's. Cooper Station is presently on a five shift rotation and plans to. add a sixth shift when at least two of the five in the RO training class pass their examination. The present training staff is limited to one training coordinator and an experienced shift supervisor. - A training supervisor has been authorized since, the fourth quarter of 1982 but plans for filling that position have not c been firm until very recently. I ka I

1 Post-accident analysis of the Three Mile Island accident in March 1979 resulted in many findings and subsequent changes in hardware, procedures, training and operating personnel. One of the significant personnel related findings was that during the course of the accident all of the licensed personnel concentrated on the details of operation and no one stood back and looked at the overall picture, thus missing the significance of a number o'f events that occurred. As a result, NRC has dictated that a Shift Technical Advisor should be available in the c'ontrol room',durin'g any accident. Some utilities are meeting this requiremert through assigning degreed engineers to ' opera ti ng..s.hi fts. Cooper Station is cne of the plants that is. proposing to meet n the Shift Technical Advisor requirement by training and j utilizing " incumbent shift supervisors as STA's. The shift supervisors were given a one week training course on the Dresder:. sim01ator in accident mitigation and have been judged i by Cooper Station management to meet the college level educational ~ requirements outlined in the INP0 Sh'if t Technical Advisor 6 Trair)ing and Qualification Guide, Section 6.1.2, of April 8, jf 1980. The CNS training is in sharp con.trast to an STA training ~ - course at another u'cility that devotes one full year to ,acadsmic training in recommended areas including heat transfer, -J~ fluid flow, mathema, tics, transient analysis, degraded core and accident mitigation. After a two year period that utility ? i ~ will have two SRC't per shift who are qualified as both shift l-supervisors and STA's. On each shift, consequently, one SR0 1s available and desig a ted in the event of an incident to ~ ~ stand back as the STA and view the broad picture while the ~ eth'eE SR0,- directs the activities of the control room operators. 1 ~' ~ R l ~ 4 ~ l s

o / Cu s t . I ', ', h'. 3go. s. s. x c s' g \\..h %.h LRS is concerned that the' training provided by the District to the shift supervisors'in S~A technical requirements is marginal. y i Also, some of the-do'cumentation concerning the academic training of incumbent shift super' visors in meeting the self-imposed i ,requirementsofthe(NP0STATrainingandQualificationGuide ~. may not, in all resoects, accurately reflect the level of ] training received. LRS is further concerned that the CNS ,,[\\ ',niethod.of Undlementing the STA requirement by combining that \\ s Nirtction with that of the shift supervisor could result in the 3 loss of the " stand back" technical advisory role of the STA , t envisicned by the NUREG 0737 requirements. In combining the STA/shif t supervisor function it must be absolutely understood that-during upset conditions the shift supervisor must not get i involved in the details of any particular operation; rather, he must remain cognizant of the total plant situation and interact in the details only when necessary to discharge his overall responsibility. It is. understood that CNS management plans to modify the cont'coi room to include the Technical Support Center (TSC) as an integral part of the control room. (

6.2 Findings

The Cooper Nuclear Station is being operated by a knowledgeable and dedicated operating staff but there are forces at play that could seriou!1y erode that capability rapidly. These are: I o The attrition of seven licensed operators over the past two years is causs -for concern particularly when coupled with the attrition in other arNs of the Station which i l accounts for an additiond twenty-six people during that same time period. See also the Attrition Section of this P-l report. i s '1

r o STA training is believed by LRS Consultants to be inadequate to meet the intent of the STA position, o As is pointed out in the section on Training, the licensed operator training function is seriously undermanned. o To a large degree, the licensed operator requalification training is non-scheduled and is left up to the individual operator to accomplish on-shift. o On a five shift rotation, each crew hypothetically has four days every five weeks to devote to requalification training. Due to the shortage of personnel, this four days of relief crew time is frequently sacrificed to fill in for vacations and absences due to illness. o The present plans call for the sixth shift to be a training shift. However, plant management indicated plans to take the sixth crew out of rotation for a period of months and have that crew function as trainers - - not trainees. 6.3 Recommendations i Ln addition to recommendations in the Training and Attrition l Sections the following are made regarding Operations: l l l 0-1 High priority should be given to the retention of licensed l-operators and to the development as soon as possible of a sixth shift. l'. I. 4. -y .----r,, ,.,_..,,,,__.__m_

Qw s 0-2 Consider increasing the complement of Station operators to provide a larger pool from which to draw future R0 and SR0 candidates. 0-3 If the two functions of shift supervisor and shift technical advisor are combined, specific instructions must be issued to the shift supervisor that in upset plant conditions he must stand back and exercise control from the broader perspective of the total plant condition. 0-4 Incorporation of the TSC in the control room should be i reevaluated. 1 i ) 4 .1 i a 4 s t l i I l I l (. I 1 r

~ 1 7.0 MAINTENANCE At the heart of a successful nuclear plant is a cadre of skilled maintenance personnel. The excellent operating and availability record of the Cooper Nuclear Station attests to the caliber and spirit of the maintenance force over the past nine years of plant operation.

However, as was discussed in the Operations Section, the competition in the industry for trained, experienced and qualified nuclear maintenance personnel. is extremely fierce and NPPD will have to take some agressive measures to maintain a skilled maintenance force.

7.1 Discussion The Cooper Station maintenance group is composed of 10 instrumentation and control technicians; 17 mechanics, welders and machinists; 5 electricians; 15 utility men; 3 stores personnel plus 5 management and staff individuals for a total df 55 on-board personnel with an authorized ceiling of 60. The complexity of nuclear plant systems and the consequences of misdirected actions require that the work be performed using formal written and approved procedures by highly skilled personnel. The primary control mechanism to accomplish work ii in the plant is through the use of Trouble Reports (TR's), Maintenance Work Requests (MWR's), Preventative Maintenance Procedures (PM's) an'd Surveillance Test Procedures. The Maintenance Work Request is the only method to accomplish work on Essential systems that could affect the form, fit or function of those systems. However, it is of interest to note that Trouble Reports, whose primary function is to authorize troubleshooting on Essential systems, may be used to actually perform "non-essential" work on Essential systems. Non-essential work being that work that does not impair or degrade the safety function of the Essential component.

o. I Since the Three Mile Island accident, there has been an increase in surveillance test requirements, an increase in the complexity of plant systems and an increased emphasis on preventative maintenance that has resulted in an increased work load for scheduled maintenance work. Since the maintenance forces generally perform the installation and modification work associated.with the accomplishment of the TMI modifications, CNS maintenance forces have been severely strained to keep up with the increased demands. At the time of the audit there were some 480 outstanding Maintenance Work Requests and Trouble Reports. This is not an unusually high number as the Station is preparing to go into its annual refueling outage. However, some concern was expressed by Maintenance personnel that the complexity and the amount of work required by each MWR or TR had increased. These facts coupled with the increased attrition rate of experienced maintenance personnel could lead to a general deterioration of Cooper Station performance unless the trends are reversed. To make an assessment of the impact these negative factors are having on the Cooper Station maintenance pr'ograms, a review of the monthly preventative maintenance report was conducted. Administrctive Procedure 1.7.2 Work Item Tracking-Preventative Maintenance, requires that periodic reports be produced for all overdue PM's. By definition, overdue PM's are those that were not completed within a time period calculated as 33% of their scheduled interval and measured from their last due l date. The overdue PM report is produced monthly and is l reviewed and signed off by the Maintenance Supervisor. i 1-i . k

As is apparent from Table 7-1, there has been an increasing trend in overdue PM's during the past year from a level of less than 100 to a level in the upper 300's. The preponderance of these are in the I&C area. This trend should come as no surprise noting that the attrition in the I&C group in 1982 alone was five out of a group of ten. Replacing these lost technicians with new hires results in a dramatic drop in plant-specific experience level in the I&C group. While the number of overdue PM's in itself may not be a serious matter, the increasing trend in the I&C area should be a management concern, as should be the attrition rate which was discussed in Section 2. The only effective counter for this serious drop in I&C experience level is through increased plant-specific training for the new technicians. The present policy at Cooper Station is that training is accomplished within each group since tnere is no centralized training program or staff. The I&C Supervisor has attempted i to effect an on-the-job training program and, given the resources and time available, he is making some headway. However, the a I&C technicians interviewed were unanimous in their concern about plant-specific training. The large majority of I&C technicians have a two year technical degree and are apparently well trained in the fundamentals of electronics. However, the application of those fundamentals to plant-specific systems needs improvement. l The mechanical maintenance group does not suffer from a high attrition rate problem with only 5 losses in the past four years out of a group size of 17. The Acting Mechanical Maintenance Supervisor, who is a degreed Senior Mechanical wr~ r v --r---, - - - --------ev- , - - - ~ - ,r

7 s s TABLE 7-1 1 OVERDUE PM's Mechanical Total Oue Month / Year Total I&C Electrical and Other that Month December 1982 383 305 17 61 242 November 1982 376 298 21 57 248 October 1982 362 279 37 46 396 September 1982 186 140 18 28 241 August 1982 190 136 33 21 209 July 1982 183 133 23 27 347 May 1 through July 7 no reports due to refueling outage. April 1982 51 29 12 10 192 March 1982 61 42 4 15 February 1982 64 42 2 20 January 1982 99 52 23 24 404 December 1981 67 51 3 13 241 November 1981 118 42 49 27

Engineer, recently instituted a training program for mechanics. The program is composed of fourteen, three to four ho'ur sessions and will cover twenty-two topics during the first half of 1983. Plans are also in place to provide a training program for welders and machinists. Up to this time the electrical maintenance group has remained very stable and is staffed with personnel who have intimate knowledge of plant systems. Because of this high specific knowledge factor, the electrical group is able to function smoothly with such a small group of five. However, if significant attrition were to occur, the impact would be felt immediately. During the interview process, LRS was ma'de aware of the imminent resignation of one electrical maintenance individual. In pursuing the root causes for the high attrition rate in some elements of the maintenance area that were discussed in the attrition portion of the Organization, Management and Personnel Section,'it became apparent that there were problems unique to the management structure and personnel in the Maintenance Section itself. As a matter of everyday working practice, the three maintenance groups are rather autonomous and have very little interaction with the Maintenance Supervisor. Work planning is accomplished through interacting with the Maintenance Planner and the operations group during normal operations. During refueling outages, the three groups work directly with the Assistant to the Plant Superintendent who functions as the outage coordinator. Interaction with the Maintenance Supervisor seems to be solely in the areas of resource requirements and salary administration and in these areas there is a concern that the individual group needs are not provided to upper management with sufficient clarity for problem resolution. l* Id P

l' I

7.2 Findings

The significant findings in the maintenance area are: o The maintenance group over the past thirteen years has 4 been able to satisfy plant needs very effectively despite l their limited resources. Major factors in this accomplishment were the high morale and high plant-specific knowledge. Both of these attributes are now on the decline. o Attrition of I&C technicians is excessive. j o preventative Maintenance is lagging which can lead to l hardwaredeterid, ration,planttripsandotherproblems. l l' o The present training program, particularly in I&C with its high turnove[ rate, is inadequate to meet current and projected future needs. o The use of a Trouble Report (TR) as a work implementing document raises two serious concerns. First, although maintenance personnel are cautioned not to use the TR to perform work on the essential elements of Essential systems, the routine use of TR's to perform non-essential work on those systems establishes a mode of operation that could lead to serious mistakes. The above practice sets up a situation where a technician performing trouble-shooting work in an Essential system could, in the rush of things, perform an unreviewed repair that degrades the ability of the component / system to perform its safety function. Second, using a TR by-passes review and approval by the operations and maintenance supervisors and, unless specifically called for by the maintenance planner or the system engineer. By-passing this level of review places a heavy load of responsibility on the maintenance planner and the shift supervisor to assure the proposed work does not degrade system performance and safety. , r

o Of the 480 outstanding work items, 80% are covered by TR's. 7.3 Recommendations In addition to recommendations in the Training and Attrition sections of this report, the following recommendations in the ha'intenanceareaaremade: M-1 Improvements in the area of personnel recruitment and retention must be made immediately with critical attention to the I&C area. In addition to attempting to understand and correct the causes for the high attrition rate in the I&C area, steps should be taken to expedite plant-specific training. M-2 Estimates should be made of expected attrition rates and 2 a personnel acquisition program should be put in place to provide a cadre of personnel in training to successfully counter the expected losses. M-3 The management structure and qualifications of incumbent personnel in the maintenance organization should be reviewed to determine if changes would improve morale and inhibit attrition. M-4 A review should be conducted to determine the advantage / disadvantage of changing CNS Administrative Procedure 1.7.1 to require that all work on Essential systems be covered by a Maintenance Work Request (MWR). 8.0 TRAINING By any number of measures, the training of nuclear power plant personnel is rapidly becoming one of the most important issues that face the nuclear industry today. The Government Accounting Office (GA0) report in the Fall of 1982 concerning an assessment of the utilities' responses to post-TMI increased plant training needs was a precursor to an amendment to the Waste Management Bill offered by Senator Weicker. The Weicker amendment, that was passed by the Congress and signed into law by the President in December 1982, requires the NRC to report out regulations by December 1983 on formal training requirements for nuclear power plant personnel over and above the present training requirements for licensed operators. Prior to the Weicker amendment, there was a gentlemen's agreement ~ between the industry and the NRC that would allow the Institute for Nuclear Power Operations (INP0) a two year trial period to implement the industry's own, self-imposed training requirements. This, of course, 'will change a'nd some concern exists that the new NRC requirements could be more prescriptive and not necessarily inclusive of the already published INP0 training guidelines. s Notwithstanding the peer pressure from INP0 and the regulatory requirements soon to be issued, the singular most important purpose for increased nuclear power plant training is to counter the dilution of operating experience that is resulting from increased attrition in plant personnel. 1 o. 4 5

8.1 Discussion The training situation at the Cooper Station has not kept pace with the mounting requirements mentioned above. There has been some limited movement in the direction of improving CNS training. However,. training appears to be aimed more at just fulfilling NRC requirements rather than at assuring that CNS workers are trained for the highest quality of plant operations. Regulatory developments of the past few years have added significantly to the responsibilities of nuclear workers. Many changes and modifications have been made in the plants. New control systems have been added and more are being put in place as a result of TMI, the Brown's Ferry fire and the Brown's Ferry failure to scram. Furthermore, even slight off normal operating events may be highly publicized and reflect on plant management. All of this comes at a time when operating plants require many more personnel than were needed ten years ago. More and more new nuclear units are coming on-line and the demand for operations personnel has soared. Utilities with new nuclear units are under great pressure to get an operating license and this in turn means that they must hire experienced personnel. Inevitably this demand has impacted the job market. The Cooper Station has already suffered significant losses of experienced personnel. Also, the Cooper Station already operates with lean staffing and further inroads on the p'lant complement could weaken the overall' technical proficiency with which the Station has operated for many years. It is for this reason that a dramatic enhancement of training is necessary in order to provide licensed operators and qualified service personnel to replace the experienced workers who It-"e CNS.

k. t*

In the licensed training area that takes plant equipment operators through a series of courses in physics, reactor theory and operation, plant systems and other technical areas to assure that they understand all aspects of nuclear power plant operation, training is handled by a shift supervisor and an educational specialist reporting directly to the Station Superintendent. The Station has traditionally emphasized on-the-job training and has engaged in accelerated training for reactor operator license candidates, usually on an eight mo' nth training period where most utilities use a ten to fourteen i month training period. All licensed personnel (R0's and SR0's) are required to pass an annual requalification examination. To meet this need, CNS developed a Requalification Training Program that was approved by the NRC and requires that the operators receive a minimum of sixty hours of training. This formal training was to be i accomplished during a crew's relief-crew-week that is composed of four days of day shift work every fifth week. In place of training, the relief-crew-week is often used for standing shifts as reliefs for unplanned absences in the other operating shifts and to supervising various plant tasks. Serious questions have been raised by the NRC about the amount of training accomplished during the relief-crew-week. l As a result of NRC's examination of the Three Mile Island l accident a requirement was developed for a shift technical advisor (STA) to be on sh'ft. The role of the STA was to i l-stand back and observe the overall condition of the plant from ~ a technical point of view and advise the shift supervisor. i The CNS approach to fulfilling the NRC requirement for the STA I functions has been to utilize the shift supervisor, who holds a Senior Reactor Operator license, as the STA in the event of l. an emergency. STA training consisted of one week simulator training on degraded core and emergency procedures coupled with an affirmation that the individual met the educational requirements identified in the INP0 STA training guideline.

NUREG 0737 specifies that the STA should have a Bachelor of Science degree or its equivalent in engineering or related ' sciences. The purpose of this requirement is to provide the control room with engineering expertise in the event that abnormal conditions develop during plant operations. Training for the non-licensed plant equipment operators is relegated to a large degree to on-the-job training without a formalized or systematized qualification procedure. Plans are in the making to provide some Lind of systems training for the plant equipment operators (two systems courses have been given) and to institute a formal qualification card type of 1 training certification. The instrumentation and control area (I&C), where the plant i attrition rate is the highest with a loss of five out of a group of ten, has an informal training program based on each individual's background and experience. The program topics covered are those necessary to train an experienced electronics technician to function satisfactorily in nuclear power plant maintenance and surveillance procedures. However, the program j is informal, is administered by the I&C group supervisor and relies very heavily on on-the-job training. f As noted in the Maintenance Section of this report, the mechanical maintenance group has a self-administered training program. The program covers topics in personal safety, maintenance practices, respiratory protection, print reading and use, metallurgy, fire safety, gaskets, packing and mechanical seals, pipes and pipe fittings, basic lubrication, valve maintenance, thermal insulation, centrifugal pumps, coupling and shift alignment, piping auxiliaries, positive displacement pumps, steam traps, non-destructive testing, air compressors, bearings, guage glass maintenance, heat exchangers and resurfacing techniques. The course appears to be well planned and has been received enthusiasically by the personnel in the group. The maintenance supervisor has plans to expand the course to provide specialized training for welders and machinists. The CNS Engineering Department has an extensive, though informal, training program. The program consists of weekly, one to two hours lectures on CNS plant systems. The lectures are given by the cognizant systems engineers with help in lesson plan preparation by the training shift supervisor. In addition to the systems training, some fifteen generic topics are planned to be covered in these weekly lectures. These generic topics fg range from reactor theory, scram (reasons and set-points) to metallurgy and how to classify Essential /Non-essential equipment. The present plans call for only Cooper Station engineering personnel to attend the course. 8.1.2 Findings The following findings regarding Licensed Operator training are noted: o Examination of course content and test and classroom observation indicate high quality instruction. Both instructors have lengthy experience at CNS and know the plant well. Both exhibit good communications skills in the classroom and have good rapport with the students. o The Station is vulnerable to a continuing loss of licensed personnel which puts added pressure on training and the trainers. The continued operation of the Cooper Station is critically dependent on having enough licensed operators to fulfill NRC requirements.

6. -

The following finding: regarding Licensed Operator Requalification training are noted: o Licensed operators who were interviewed all expressed a desire for more training in the classroom. They felt that on-shift training was not compatible with giving full attention to their regular assignments. Training is perceived by operators as being of significantly less priority than operations. o Scheduling formal training was a problem due to a shortage of licensed personnel and relief crew assignments. Lack of a sixth shift devoted to training impacts operator morale and makes training difficult. The following finding with regard to STA training is noted: It is seriously questioned that the level of training o given the shift supervisors in the past or that which is taken credit for in their training documentation meets the baccalaureate level training envisioned by the NRC or invoked by NPPD in citing the INP0 STA Training Guideline, Section 6.1.2 as a requirement. The following findings with regard to training in the Maintenance area are noted: o Training being conducted by the mechancial maintenance group appears to be a good start in the right direction. o Training in the I&C area is informal and no time is alloted to accomplish the training on shift. ~. l The following finding with regard to training in the Engineering area was noted: o The CNS systems training program is an excellent 4 start despite its informality. 8.1.3 Recommendations The need for improved training is considered to be serious and demanding of prompt action. While it is true that CNS has an excellent operating record, which reflects 4 competence in its staff, this may have bred complacency. Almost to a man, plant personnel who were interviewed expressed a desire for more training but felt that plant management was not completely convinced of the need. This perception appears to be a contributing factor to lowered morale among workers and could be a factor in increased attrition. l The following recommendations related to training are made: T-1 A Training Department should be organized under the-leadership of a single supervisor with full responsibility l for licensed and non-licensed on-site training. i T-2 One of the first responsibilities of the new training supervisor should be the generation of a comprehensive CNS training program detailing the training needs I (' and the resources to carry out the program. i-T-3 An additional licensed instructor and training clerk i to maintain records should be added to the staff along with the assignment of the present training shift supervisor full time to the training department. 1 .a g,*- V., ' f' .~

I T-4 The Training Manual should be upgraded and systems descriptions should be updated to more accurately reflect the present status of the plant. More emphasis should also be placed on balance of plant systems training. T-5 Consideration should be given to relocating formal training to classroom facilities at the new E0F or at another centralized location. T-6 The sixth shif t should remain in normal rotation and dedicated to requalification training of incumbents. T-7 NPPD should review the STA training situation and determine if remedial training is appropriate for incumbent shift supervisors. T-8 The Training Department, when established, should develop, in cooperation with operations, a formalized training program and schedule for non-licensed Station operators. The qualification card system should tie revitalized and used as part of this I training program. T-9 The critical needs of enchanced I&C training should be reviewed to assure that the diminution of experience in that group is countered by increased plant-l specific training. T-10 Consideration should be given to expand the systems training program given by the CNS engineering group to include General Office engineers. l l l l l ! i

9.0 EMERGENCY PLANNING Unlike the other activities reviewed by LRS, emergency planning is not subject to objective analysis except for assessment of the adequacy of the Emergency Plan and its implementing procedures along with observation of personnel during an actual emergency planning exercise. LRS Consultants did not audit the latter and therefore restricts its critique to that of the plan and its implementing procedures. The NRC criteria underlying emergency planning out to a distance of ten miles have been challenged by the nuclear industry. Two factors are involved - - first, the probability of a severe core disruptive accident and second, the magnitude of the source term (i.e., the amount and nature of the radioactivity released from containment). Many nuclear experts who have studied this issue believe that the NRC's estimate of the source term is very much larger than. indicated by realistic analyses. Despite this situation, present regulations require emergency planning for a ten mile radius around CNS. 9.1 Discussion The Cooper site has only 2,525 people living within a ten mile radius. This represents a relatively low population at risk in the event of a nuclear accident. Given the prevailing winds and a conservative thirty degree segment of the circular area as the risk zone, tne population at risk would be very much less. A core disruptive accident would not normally happen instantaneously, but for most accidents would develop over a period of an hour or more. Furthermore, only a few accident sequences are likely to involve significant releases of radioactivity from containment. Even in the severe core disruption which occurred ' t'

at Three Mile Island, essentially only noble gas release took place and this involved a total of 235 person-rem of population exposure over a total of 28,280 people living in the 0-5 mile radius. An additional 262 person-rem were distributed among 137,474 people living in the next five mile radius. Substituting the appropriate populations for the Cooper site the 0-5 mile radius radiation exposure would have been 1.8 person-rem and that for 5-10 mile radius would have been 1.6 person-rem. The total 3.4 person-rem for all persons living within ten miles of the Cooper site averages out to 1.4 mrem per person or roughly 0.01 percent of the normal background dose that each person receives in a lifetime. In terms of health effects, a commonly accepted risk indicator is that one cancer mortality is associated with 10,000 person-rem of population exposure. This would mean that there would'be only one chance in 3,000 thatonecancerdeathmightbelYnkedtoaTMIscaleaccident if it occurred at the Cooper site, which, would be a very low consequence event.

9.2 Findings

The Emergency Plan and the implementing precedures appear o to be adequate although some revisions are required to comply with all NRC requirements. o The District has lacked an experienced and dedicated emergency planning staff. Responsibility for this duty has shifted from one person to another and NPPD has relied too heavily on contractor assistance. There has been imperfect coordination and communication between the Cooper site and the General Office. m 4

• 4.

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9.3 Recommendations The following reconnendation should be considered in the Emergency Planning area: EP-1AsingigEmergencyPlanningCoordinatorshouldbeappointed with fuT,l' responsibility for the NPPD emergency planning. Adequate staff suppctt should be provided to this individual. 4 e e l} } 4

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10.0 QUALITY ASSURANCE Although frequently erroneously considered to be simply an audit and inspection function, quality assurance basically is the entire program by which the quality of hardware and operations is assured. Consequently, the Quality Assurance program is one that encompasses all safety related aspects of the operation and support of the nuclear mission and places specific demands on all organizations and personnel as to how their job shall be performed in accordance with the Code of Federal Regulation, 10CFR50 Appendix B and the FSAR. This program i should include the following specific functions: o Establishment of QA requirements o QA/QC training and qualification o Supplier qualification and surveillance l o Security and emergency plan audits o Procurement, inspection and stores activities o Document and records control o Non-conformance and corrective action program (including trending) o Design and modi.f.ication control o Observing and auditing on-going activities such as: l) In-process surveillance and performance testing i 2) In-process instrument tests and alignments 3) Control room operations l 4) Training, licensed and non-licensed 5) Radiological protection efforts 6) Chemistry control efforts _7) Rece.fving and stores 8) Maintenance and modifications I. s L l'

10.1 Discussion Quality is assured by the line and support organizations that maintain and operate CNS, design and implement modifications, procure, inspect and store hardware and control numerous other activities. The quality assurance organization is charged with the responsibility to review, audit and inspect the performance and results of the other organizations to ascertain their conformance to NRC and NPPD requirements. Most of the QC activities at the CNS are performed by personnel in the line organizations reporting to the Plant Superintendent which are primarily maintenance, operations and engineering. The quality assurance staff at NPPD consists of eight individuals, three of whom are located at CNS, which is a small staff compared to most other utilities. The General Office QA organ'ization is located approximately 150 miles from the CNS which tends to make training of new people and the efficient use of the total QA staff very difficult. Considering the size of the quality assurance organization, the NPPD audit and surveillance program is reasonably effective in the areas evaluated. However, because of the limited staff, QA is not able to audit and surveil all of the appropriate areas to the extent necessary. Also QA personnel are not able to devote enough time to training, trending, tracking of NRC I&E items and evaluating industry QA problems for their applicability to the NPPD. i i l All of the LER's for the past two years and the NCR's for 1982 l were reviewed. In the course of this review it became apparent that a consistent set of groundrules were not being applied, such as: Was the cause related to personnel error, hardware problems or procedural inadequacies and; did the proposed and actual corrective action prevent recurrence? , H

Two of the CNS QA staff were cross-trained in the Station Maintenance Department which is an excellent practice and should, if possible, be continued. The QA Program is reasonably well written, however, a few of the program requirements are not being scrupulously followed and it does not appear that management enforces complete compliance. 10.2 Findings The principal findings in the Quality Assurance area are as follows: o There is a requirement for CNS Operations, Power Projects, and Quality Assurance to identify Essential structures, systems and components. The systems are identified. However, the identification of structures and particularly components are not well identified. The identification that has been performed has not included input from all three groups mentioned. t o Trending is not being performed on audit and surveillance findings. l o A coordinated program of corrective. action to prevent recurrence of non-conforming conditions is not apparent. l \\ l o Training of NPPD General Office management in the requirements of the QA Program could be improved. o Responses by the General Office organizations to audit findings could be improved both as to their quality and timeliness. f I . 1 l-

o QA does not perform surveillances, audits or reviews of l all of. the non-Essential purchase orders for equipment, material or services for the CNS and therefore some items may be being misclassified and not being ordered as Essential when they should be. o The Division Manager of Licensing and QA does not review the effectiveness of the QA Program with his management on a regular basis as required by the program. o General Office QA management appears to be lacking both authority and credibility at the Station and in the General Office which may in part be due to lack of a routine reporting or communications relationship between the QA management and the Plant Superintendent, the Assistant General Managers and the General Manager. o The last reorganization placed another layer of management between QA and the General Manager which implies a reduced management commitment to the QA Program. 10.3 Recommendations The following recommendations should be considered by NPPD. Q-1 Consideration should be given to relocating the General l Office QA Department closer to the CNS. [ Q-2 Establish a routine reporting relationship of the status and adequacy of the QA Program to the General Manager. Q-3 Increase the CNS QA staff by at least two people as soon j as possible. 1 )_. N L t

Q-4 Identify the Essential and non-Essential structures, systems and components that require QA involvement. Q-5 Initiate a QA training program for General Office management personnel who are involved with the CNS. Q-6 A coordinated corrective action program that includes LER's, NCR's, MWR's, SRAB items, audit and surveillance findings and I&E findings should be developed. This 4 should include a program to analyze trends of significant conditions adverse to quality. ,3. Q-7 Careful consideration should be given to determining I those systems, structures and components that have some 'N significant importance to safety and therefore should require some level of QA program application. Examples of those that should be reviewed are: Post-accident I sampling system, radwaste system, security system, fire protection system, chemistry instrumentation, meteorological monitoring equipment and the HVAC system. -fi l , L

I 11.0 RADIATION PROTECTION AND ALARA The majority of the workers at the Cooper Nuclear Station are exposed to ionizing radiation in the course of performing their duties. All such workers are required to receive training regarding radiation risk and procedures. NRC regulations impose a radiation exposure limit of three rem per quarter on all nuclear workers. NPPD enforces a quarterly limit of 1.25 rem and a yearly limit of five ' rem, but uses a 3 rem annual administrative guideline. t Specific jobs involving significant group exposure are studied to make sure that exposures are As low As Reasonably Achievable (ALARA). This group exposure is estimated in person-rem (i.e., the number of' workers multiplied by their estimated average exposure). For ex6mple, a-crew of ten men working for five hours in a radiation' field of'.02 rem per hour would add up to a group exposure of one person-rem.. Continuation of such a job day after day could involve a total of'many person-rem and special ALARA consideration then given to the work. Radiation levels may be reduced by using lead shielding or by decontaminaticq. Workers may be given special practice in mockups to reduce their exposure time and remotely operated equipment may also be employed, o 11.1 Discussion E NPPD protects the health of its nuclear workers by employing l the services of a professional staff of two supervisors and eight technicians..There has been relatively little turnover l in this staff which averages almost five years in CNS experience. ~ The technicians perform routine radiological surveys in the plant and take air samples to determine the concentration of any airborne radioactivity. Based on surveys of specific areas, Health Physics (HP) issues special work permits stipulating l L what protective clothing and special equipment is required. 1. a l f e.

4 In the event of significant risk of airborne radioactivity, ' workers may be require'd to den full respiratory gear to protect againstninternal contamination. Work crews are accompanied by,, orinoni.tored by HP technicians who have the power to ~ e' shutdown a job should it appear to involve excessive exposure. s s 3 Ra'diation areas are specifically posted and radiation levels z. -\\ within roped bff sectors or locked rooms are specified. When . workers leave a radiation area requiring protective clothing ^

• ^

they ~ remove this and frisk themselves with a radiation meter s s to determine the prese'nce of any residual radioactivity. / Everyone' leaving tha; plant must pass through a sensitive portal monitor that detects small amounts of radioactivity. . g All radiation worke's are required to have a whole body count r when coming on-site for the first time and when they terminate a f. their einployment at the site. Permanent records of these J whole body counts are maintained by NPpD. NPPD s,pbmits to the NRC an annual report detailing the radiation ~ exposure of all workers. This report is also placed in the Publ.ic-Docket. - Fi'gure 11-1 shows the occupational exposure of the CNS work force for the years -1975-1982. The increases in 1980-1981 are due to NRC mandated plant modifications which necessitated c protracted' exposures. The same figure shows the average ~ person-rem for ten oth'er BWR units of comparable pcwer rating ~ '^ brought into operation in roughly the same time frame as Cooper. The occup'ational ' exposure of CNS workers is the lowest of these eleven BWR units and in terms of average person-rem, it' is about dne-third that of the average for the ten other BWR ' units. m s a!~ s S W -c. -4 +------.~mm. .,-..m. m,

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Figure 11-2 displays the average worker exposure (rem / year) for 1975-1982. The CNS increase in 1980 reflects the higher person-rem for that year distributed over a work force which was deliberately kept small to permit higher worker efficiency. Comparable data for ten other BWR units are shown in the same figure. The average individual exposure of CNS workers over a j, seven year time span amounted to 76% of the average for ten other BWR units. It was the second lowest among eleven units surveyed. i The Station has no formalized ALARA program but one is being prepared. Examination of worker dose data shows that radiation controls are basically limiting exposure to the CNS administrative guideline of three rem / year. In 1982 only two workers exceeded this guideline but were well below the five rem limit. Despite the absence of a fontalized ALARA program the workforce expo;cee data support the conclusion that NPPD practices an effective program cf dose reduction at the Cooper Station. Examination of whole body count data as well as the log of l Radiological Safety Incident Reports shows that there has been good control of worker contamination, bot' external and internal. Training of HP technicians to date has been restricted to on-the-job activity. However, the Stadon has recently purchased a training program and is preparing to give classroom instruction on a systematic -basis. The Station is adequately equipped with portable and fixed instrumentation for radiation detection and measurement purposes. .4

Figure 11-2 .__ L 1 . i.d ,[ i-q q_ .I. i y f .._.w _._z -.. } _... :. . _ - (. 19 75 -- 1981 L)--. _ _ -. __.._ _ COOPER STATION _ _ 10 UNIT AVERAGE ~~ . BRUNSWICK-.1,2-. ANNUAL WORKER DOSE ____.._____ _..._ __ ______._. _ DRESDEN 2,3___.. l.5 Rem / Year... ._FITZPASICK HATCH 1,2 [ -QUAD-CITIES--1% ,i.

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I Personnel in Health Physics are competent in the practice of radiation protection and are dedicated to doing their work conscientiously and effectively. They appear to have good relationships with the majority of the operations and maintenance force. It is noted that no contractor HP's are used on outages. This puts a strain on the limited HP staff, even 4 though it is supplemented with assistance from the Chemistry Section. The HP staff is lean and would be degraded in its i efficacy if technicians leave CNS. l The Station does not receive any technical support from the General Office in the area of health physics, i 1 i 11.2 Findings \\ The follcwing significant finding ip Radiation Protection and ALARA is noted. o In general, NPPD measures to control the radiation i exposure of workers at the Cooper site have been very effective in keeping radiation doses well below the NRC regulatory levels and significantly less than the levels attained at other BWR units of comparable power and i vintage. This performance is even more commendable when one considers the relatively small size of the radiation protection staff. m. y-m-----,--.----.,,-w.,- ---,-,,-r- -e -- - - >- + -. --+ --, - -, wg

12.0 RADWASTE MANAGEMENT In addition to gaseous and liquid low level radioactive materials which are discussed in Section 14, there are low, intermediate and high level radioactive wastes (radwaste) generated in the operation of a nuclear power plant. These wastes range from slightly contaminated paper from containment work to highly radioactive spent fuel elements. Management of the low level radwaste is accomplished through such devices as limiting the potential contaminated trash that will come from radioactive work areas by limiting what goes in. For instance, by removing materials from their boxes before taking the materials into the containment, the boxes do not become radwaste. 4 Intermediate level radwaste materials (sucn as filters and resins) can be managed for minimal /olume primarily through operating a relatively low radioactive level at the plant, High level (spent fuel) is menaged at the present time by storing on-site in spent fuel pools. 12.1 Discussion At CNS, radwaste is separated according to its level of radioactivity and form. Contaminated paper and trash is compacted and confined to barrels which are sealed and shipped off-site. Low and intermediate level liquid wastes are mixed with concrete, converted into a solid and shipped off-site in sealed metal barrels. Higher level wastes are also mixed with concrete, solidified and then shipped off-site in shielded casks. All shipments must conform to strict regulations regarding the transportation of radioactive wastes. In addition, they must meet acceptance criteria at the Nevada radwaste facility.. r,- --, -.-,=,._--- n -. - ~

a Management of radwaste processing and shipment is carried out by Operations at the Cooper site. Health Physics personnel monitor the shipments and assist in radwaste operations. There is no dedicated crew of radwaste operators. Annual generation of solid radwaste, measured in curies, is shown in Figure 12-1. The Cooper Station record has been consistently good over the years and averages only 11% of the radioactivity shipped off-site by ten comparable BWR units. The annual volume of radwastes shipped from the Cooper site each year is plotted in Figure 12-2. It is roughly a third of the average annual volume shipped off-site by ten comparable l BWR units. 12.2 Findings Two deficiencies have marred an otherwise exemplary recoro of radwaste s'ipnents. One involved a disputed failure to label n a waste container - - a cask containing fourteen drums of g ( radwaste. The NRC maintained that the cask, as opposed to the drums, should have been labeled (there was no dispute that the vehicle itself was properly safeguarded with an appropriate placard). The NRC subsequently reversed itself on this decision. The other involved a shipment which exceeded the radiation f levels specified by the Nevada radwaste facility. This discrepancy appears to have been due to higher in-plane measurements than taken at the Cooper site and has been rectified by a commitment l to more extensive radiation monitoring at the site. Neither l of these deficiencies resulted in any danger to the public I health and safety. l- ~ 12.3 Recommendations i d No recommendations are made in the Radwaste Management area. =4 t l-WN e -.m. c -e

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INsA'W E-3 -l t 4 ~ SHIPMENTS OFFSITE ~ ~ SOLID WASTES CUBIC METERS PER YEAR 2,000 VOLUME Shipped Offsite-(1975 82) 10 BWR Unite Cooper _ Stat &on-- ..... ~ - _ - - - 1,500 ---10d.TNIT_ BWR _ AVERAGE. ___ --- Brunswiele-1 2 7 _ Dresden-2,3 Fitzpntriek ~ Hatch ~ 1,2 : 1,,000 ._ g Pilgrim _g-. 3 _ _.._..,__.p..._. ._m .o sem..__m p "** *--*' ^- I i I I

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1 13.0 CHEMISTRY Maintaining high water quality insures good fuel performance through facilitating good heat transfer and avoidance of crud buildup which could impair coolant flow. At the Cooper Station emphasis is placed on good control of iron in the coolant since this is felt to be critical to limiting the buildup of cobalt-60, a long lived radioactive species, in the reactor system. Iron concentrations in water are held p, to a level of one part per billion. Vo 1 Corrosion has been indicated in the case of many reactor system components such as pumps and pipes. Careful control of the primary coolant chemistry is essential to minimizing such corrosion which can cause defects and failures requiring extensive outage time for repairs. 13.1 Discussion Both the NPFD plant chemist and lead technician have 'oeen at the Station since startup and are well experienced in management of the plant's chemistry. They are assisted by a staff of three technicicns who have an average of six years plant experience. The CNS chemical laboratory facilities are good and well maintained. Purchases of new equipment are underway to bring intrumentation up to the state-of-the-art. Sampling facilities are well laid out. Based on operating records of the Cooper Nuclear Station it is evident that Abe plant chemistry has been successful in maintaining the system in a very good condition. Corrosion and therefore radiation levels and stress corrosion cracking consequences have been small compared to those experienced at ~ numerous other nuclear plants. -d '4 y >_ .-.-.----.._,.---.-_r. -ry-- v-a

The supporting staff of three technicians is small as judged by industry practice. Although chemistry operations are conducted in an efficient manner, any loss of personnel would impose a considerable stress on the department's functioning. No formal training has been given on-site for technicians. It is understood that a vendor course is being purchased and that formal training will be initiated soon. The measured radiation level (150 mrem /hr) at the main recirculation pump line is maintaining a constant level rather than increasing steadily as has been observed at other BWR's. This achievement, credited to good plant chemistry, serves to reduce radiation exposure to drywell workers. Dissolved oxygen is being kept in the twenty to thirty parts per billion range. No oxygen injection is contemplated. l Silica concentrations are well within desired limits. The most recent inspection of the fuel shows no significant deposttion of crud. 13.2 Findings The only significant finding in this area is that CNS has an i outstanding Chemistry program that is protecting the hardware from corrosion, maintaining low plant radiation levels and, consequently, is ably assisting maintenance of a high availability factor and low man-rem exposures. 1 i

{, >~ 13.3 Reconnendations The following recommendation should be considered in the Chemistry area: C-1 The vendor training course should be supplemented with lesson plans specific to the Cooper plant design. Training of technicians should be formalized and implemented expeditiously.

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14.0 ENVIRONMENTAL Although there are many environmental considerations in the operation of power plants, this section is limited to the radioactive aspects of liquid and gaseous effluents from Cooper Nuclear Station. 14.1 Discussion Every six months NPPD submits to the NRC a report detailing radioactive releases from the Cooper Station. This includes a detailed analysis of the specific isotopes released and the i meteorological conditions during the six month period. Samples are periodically taken of botanical, biological and other specimens in order to determine the extent of uptake due to liquid and gaseous releases from the plant. Also, measurements with radiation dosimeters are taken at various locations around tne Station. 4 f The gaseous releases from the Cooper Nuclear Station are shown in Figure 14-1 for the period 1975-1982. Corresponding data for ten other BWR's of comparable power rating and vintage are also plotted on the same figure. CNS gaseous releases are significantly less than those characterizing these other BWR's. Furthermore, there is no apparent trend to indicate significant fuel deterioration or off-gas system loss of effec'tiveness. CNS radioactive gas releases have not constituted a significant contribution to the natural radiation background characteristics of the plant site. I_ O . L'

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The liquid radwaste discharges from the Cooper site are plotted in Figure 14-2 for the period 1975-1982. On the same figure the annual average liquid radwaste releases of ten other BWR units have been recorded. CNS liquid radwaste discharges have in recent years significantly exceeded the ten unit average even though they were only a small fraction of the releases permitted by the CNS Tech Spec. These discharges wereassociatedwiththenecessitytodraintfktorus,twice in 1980 and once each in 1981 and 1982. These oper&tions imposed a higher than normal load on the radwaste system and higher than normal release of liquid radioactive effluents. 14.2 Findings The following significant findings in the environmental area are noted, o The contributions of both liquid and gaseous releases from the Cooper site to the radiation exposure of people living within fifty miles of the site is less than one person-rem per year. This represents less than 0.005 percent of the radiation exposure of this population due e to the natural background. g o Surface (TLD) measurements at the sample locations around the Cooper site fail to show any significant incremental increase over the natural background. o Environmental samples exhibit no significant uptake of plant connected radioactivity. Food pathway analysis of such uptake shows no biologically significant contribution of CNS radioeffluents to the human diet. 1 e e.e Figure 14-2

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o The comparatively high CNS liquid releases (i.e.,170% of the ten unit average) are anomalous compared to other areas of CNS radiation control activities. 14.3 Recommendations The following recommendations should be considered in the Environmental area: l I EV-1 NPPD should consider developing the capability of ooing its own meterological assessment since experience at other sites shows this to be cost beneficial. EV-2 A program should be adopted to reduce liquid releases. i 9 8 t l l l' 1 L.,.

15.0 PROCUREMENT, INSPECTION AND STORES The procurement, inspection and stores functions are important from several standpoints, including maintaining cost control and assuring the timely receipt of materials required to maintain, modify and operate the Cooper Nuclear Station. In all nuclear plants, there are also regulatory requirements of the NRC on these functions to assure that components and materials vital to cafety and other critica! systens are procured, inspected and stored in such manner as to assure high qaality. In order to provide this assurance of quality the following are among the activities that s'nould be in effect in the District: o The inspection documentation of activities should be reviewed by appropriate levels of management tn ossure an effective implementation of quality in modification work procedures (i.e.. complete, legible end accurate quality records are being maintained) and all conditions adverse to cuality are properly and timely reported, corrected, reinspected and evaluated for trends. Procurement documents should be reviewed and approved by o qualified personnel to verify appropriate design quality requirements are specified including accept / reject criteria. The use of an approved supplier is required for all purchases o of safety related materials and services. o Receipt intpection activities should verify prior to use that + material received conforms to procurement documents and that documentation supplied is traceable to the procured item. Ed -1

s. %

,n._ _.. -

o There should be effective identification and control of material and items entering the warehousing system and a proper-issuance control system should be in effect. o Metheds for marking of materials to assure traceability to purchase documentation should be in effect. o Procedures for irsue and control of cons;maole Aelding riuterials to maintain manufacturer reaa:(ements for ctorage and use should be in effect and followed. o Stored items rcyuiring special environments or periedic maintenance should be Paintained by an inspection orogram that is effective and assures conformance to manufacturer requirements until installed or placed in operation. 15.1 Discussion The procurement, inspection and stores activities of the District are primarily performed by the CNS staff except for nuclear fuel purchases and the modifications being managed by the General Office Nuclear Engineering Department. The General Office purchasing organization only performs a paper handling function. The initiator of the purchase requisition identifies the appropriate supplier, negotiates the price and expedites the shipment. QA confirms the supplier is an approved supplier if the purchase requisition is designated Essential and then assures that the QA requirements are on the l purchase order. The inspections of the received and installed materials and hardware are normally performed by the organization that initiated the purchase order or are in charge of the l e l l 1

=- - 4 maintenance or modification being performed. From a quality assurance standpoint the system seems to work reasonably well j with a few exceptions which are identified in 15.2. Following the initial core procurements from General Electric i that included U 08 (yell weake), NPPD contracted with Allied [ 3 Chemical for conversion, GE for fabrication and bought yellowcake j on the open market. In the time span from 1979 through 1981 the District procured nearly two million pounds of yellowcake at prices between about $24/ pound and $44/ pound. Recently it has been proposed that NPPD enter into a ten year contract to assure supply of three million pounds at prices initially l above the spot prica and later below the prcjetted price, f Based on available information on the present and orojected future marker for yellowcake, the crcpc. sed agreement appears to be reasonable. Reputaole consultants have been utilized to support the fuel procurement efforts. Mcwever, it is not I clear that the nuclear fuel organizatien receives much NPPD management attention despite the large sum of money it controls. Receipt inpection for other than damage and item count is l normally performed by the initiating organization (i.e., i engineering, maintenance,etc). Quality control inspection is normally performed by Station personnel or contractor personnel in accordance with the requirements on the MWR. All NDE is performed by contractor personnel. From a quality assurance i standpoint the system seems to work reasonably well with a few i exceptions which are identified in 15.2. I i l l l

( j i 1 Storage of Essential items is controlled by the Maintenance Department. At the present time, two warehouses are being combined into one so items are somewhat in a state of disarray, i The storage and control of weld rod could be improved and the l identification of Essential spare parts appear to be 'in need of attention. b15.2 Endings i. l The principal findings in the Procurement, Inspection and I Stores areas are as follows: 1 ( o Occasionally purchases are initiated beiore a purchase order is written. o If the purchase order is misclassified as non-Essential, QA may never see it and appropriate quality requiremen+,s j may not be implemented. o The information included on the purchas.e order is not always sufficient to provide enough information for a j complete receipt inspection by anyone except the person l who initiated the order. j o The information included'on the MWR is not always sufficient to provide enough information for a complete inspec, tion by anyone except a person who is intimately familiar with the work being performed. o Some of the information required on completed MWR's is not always included. S..

15.3 Recommendations Although the functions of procurement, inspection and stores appear to be satisfying the broad needs of CNS, there are several specific recommendations, as follow, that can better assure the quality of safety-related hardware being installed in CNS. i P;1 Increase the involvement of quality assurance in the early review of purchase requisitions ihat mal relate to Essential structures, systems and components, ) u P-2 !mprove purchase order intornation to a' low corolete i receipt inspection by a quality control inspector. P-3 upgrade information on MWR's tc allow complete inspection i by an inspector who may not be intimately familiar with the work and enforce the requirement to complete all s portions of the form. P-4 Improve the storage and control of weld rod and the identification of Essential spare parts. i P-5 Consider increased senior management attention to the nuclear fuels activity. including review of the NPPD/Mommsen Associates / Energy Fuels Exploration Company relationships. l e.

( 4 16.0 RECORDS MANAGEMENT AND DOCUMENT CONTROL The proliferation of paperwork in the nuclear business, the NRC requirements for maintaining records for extended periods and the operational needs to retrieve data expeditiously has dictated a computerized records management system. This system needs to meet the following broad requi rements. o The system should assure effective and efficient distribution, storage and retrieval of the plant design, construction, licensing and operationally related data and documents, 7bs records management organization should be delegated o procedural authority to govern recnrds created by all the supported organizations in a standard methodology. The records management organization should have responsibilities o for receipt, storage, preservation, safekeeping, indexing, distribution, updating, retrieval and ultimate disposition of records. e o-A commitment control system should be in effect to track NRC requirements and commitments. o The documents most needed by operations, engineering and project management personnel (e.g., drawings, specifications, technical manuals, NRC correspondence, etc.) should be indexed and microfilmed expeditiously following receipt or issue. o The computer system and software should be adequate to handle the records management requirements. l.. -

f l l 16.1 Discussion Several years ago NPPD recognized the need for computerizing its records management and document control activities. Zytron systems were procured and installed at CNS, the General Office and at Gentleman Station. A concentrated effort was implemented to index, microfilm and store records and documents for ready retrieval. It became apparenc after a few years that the Zytron problems, both hardware and software, made it icoerative that a computer upgrade be acccapiished. A Prime E53 was owchased for use at the General Office and the Zytrons at the GO and Gentleman were scavenged for parts to keep the 045 machine operable. l At Ois, the vast ma,iority of historical records up to about twa yes ago have been indexed and rcicrafilmed. Some records are Drocessed on a current basis (e.g., NCR's, Plant Superintendant reuding file, SWP's, welder qualifications, etc.). Other records, such as chenistry reports are processed two years ^ after the fact. There are about twenty-five categories of records being handled by the records management group, including in addition to those mentioned above, the following: P0's, f MWR's, MDC's, correspondence, surveillance reports, training records, procedure change notices, accident reports, NRC bulletins, etc. t } It is understood that the Plant Management Information System (PMIS) being developed will integrate all of the-data presently up on the Prime and Zytron systems. It will also integrate tne plant process computer, meteorological and radiological data and the safety parameter display system into the overall information system. This has been a good cooperative effort headed by G0 Engineering with CNS and Data Information Services support. l i-t -100- /

~_- 7 16.2 Findings The principal findings in the records management and document control areas are as follow: o At CNS a good jcb has been done in getting historical records into the Zytron system. o A major problem at CNS is the extended time that it takes to search and find documentation in the Zytron system, i i o Furchasing, contracts and engineering records are not being released to Data Information Services cr. a two yeor basis as required, o Generally, the ::mputerized data retrieval systen in the l G0 appears so be providing good suppor t to the Station ~ j and Engineering as weil as support to litigetten. 16.3 Recommendations l The following recommendations are made in the area of records management and document control. RM-1 Expedite changeover from the Zytron to the Prime 650 ) { system at CNS. RM-2 The two year basis for microfilming the active records in the GO should be enforced. l -101-}}