ML20101F939
| ML20101F939 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/30/1984 |
| From: | Jackie Cook, Fischer S, Green H MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20101F938 | List: |
| References | |
| TAC-56594, NUDOCS 8412270366 | |
| Download: ML20101F939 (19) | |
Text
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GRAND GULF NUCLEAR STATION UNIT 1 50 PERCENT POWER OPERATIONAL READINESS REVIEW November, 1984 Performed by: MP&L SRC Special Subcommittee for Review of Plant
. Operational Readiness Members:
Mr. H.J. Green - Chairman Mr. J.C. Cook Dr. S.R. Pischer Dr. J.M. Hendrie Dr. D.W. Jones Dr. F.E. Tate 8412270366 841221.
PDR ADOCK 05000416 p
PDR; m
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REPORT OF THE CORPORATE SAFETY REVIEW SU3 COMMITTEE PRIOR TO EXCEEDING 50 PERCENT OF FULL POWER I.
Introduction t
This report documents the review and evaluation performed by the SRC Special Subcommittee' for Review of Plant Operational Readiness.
The subcommittee was appointed on August 2,1984. The members, since that date,
. independently and periodically visited the plant interviewing people, reviewing documents and observing activities in progress. This effort culminated with a concentrated effort during a two we.ek period beginning November 5,1984 which resulted in this report.
The subcommittee's conclusions ard recommendations are based on findings re-sulting from interviews, observations, discussions and where necessary reviews of pertinent documents. They are by no means all inclusive, but to the best of our knowledge and belief are cor rect and appropriate.
In the course of our evaluatio a we formulated a number of recommendations. These should not be considered as requirements to be met prior to exceeding 50 percent power. The subcommittee cone:.udes, that observing normal procedural controls plant and personnel are ready to proceed with power ascension.
The 50 percent readiness review is a requirement of paragraph 2.c.(4) of the Grand Gulf Operating Licensa. This report is organized to follow the seven areas listed in paragraph L.c.(4) of the license. For clarity Section II of this report summarizes our eval aation of each of the seven areas and Section IV lists recommendations.
The subcommittee, in the course of its investigation, reviewed the resolution of comments and recomme ndations contained in the 5 percent Power Operational Readiness Review Report. Our observations are presented in Section III of this re por t.
II.
Review and Evalsation (1) Status sol Readiness of The Plant and Systems Needed to Support Intended Modes of Operation and/or Testing.
a.
Int roduction This section of the report summarizes our views on the status and readiness of the Plant and Systems to support operation and
- esting above 50 percent power.
.__u b.
Startup Testing The logic behind the planned test sequence is to first test those systems which are required for subsequent tests. Grand Gulf's plan for performing these tests follows standard industry practices which have been proven at other facilities. In addition, systems at Grand Gulf reflect a much higher than normal completion status j
and have been preop tested which provides assurance that they are available for higher power and testing.
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The results of testing at Test Condition - 1 (TC-1) are documented.
In general, the power ascension and test program proceeded well, the most significant problems encountered are identified below:
Durjng TC-1, the steam bypass piping failed. Investigation by the utility revealed that a resonant frequency might be established in the piping at 18 percent flow. To address this problem the sche-dule 40 piping was replaced with schedule 100 piping. In addition drain holes were drilled in the condenser bypass sparger to reduce water accumulation in the bypass piping. These actions appear adequate to support higher power operation.
Frocess computer sof tware problems were experienced. These pro-blems were related to dynamic conditions which are intrinsic to t
,4 an operating plant. Immediate problems appear to have been resolved.
j The Cang Drive feature of the Rod Control and Information System has intermittantly left the rods in a gang at different positions.
Gang Drive is not used in power range operation. Therefore, this problem will not affect operation above 50 percent power.
A cold quick start of RCIC was attempted. The test failed due to steaa leakage, which is not permissable by test criteria. The steam leak. has been repaired and following a reactor scram due to voltage ffluctuations on the grid the RCIC system successfully maintained reactor water level. The RCIC system is considered ready for testing it will experience at TC-2.
c.
Additional Comments Management has taken a keen interest in and provided timely and prudent decisions related to the testing program. This is evi-denced by the methodical and orderly pace of testing, cleanliness of the plant, and the presence of Management in the plant on all shifts.
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The material condition of the plant appears ready to support power 3
ascension. The results of an aggressive cleanup, painting and labeling program are evident.
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(ii) Readiness of Personnel to Conduct Intended Operation and Testing i
The subcommittee examined the staffing of the plant and support or-a.
ganizations. Plant Staf f size has Laen at 684 budgeted positions L
for 1984, an increlse of about 12 percent over 1983. With an on-board strength on November 1st of 555 MP&L employees, openings are filled Li most cases with consultants and contractor staff.
There has bee ~ significant progress since the 5 percent review a year ago in filling staff positions with permanent HP&L employees.
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The Operations group has an adequate number of licensed personnel.
i There are 12 Senior Reactor Operators (SRO) in Operations, 10 i
distributed among 5 shif ts as Shif t Supeintendents and Shif t Super-visors and 2 as Operations Superintendent and Assistsnt. (There 1
are also 3 SRO's in the Training Department). The Operations group has 15 Reactor Operators (RO) on active status. They are assigned 3 to each of the 5 shifts. There are 7 people in training due to take the RO examination in December 1984. At the same time.
2 people will take the SRO examination. Behind them in the license g
pipeline, 9 people are in training for the June 1985 examination.
Essential supporting groupe are for the most part adequately 4
staffed. Maintenance has a few open positions each in the Electrical, Hechanical, and Instrument and Control groups but 2
these are due primarily to the increase in budgeted positions over last year (12 craft slots in Electrical and 16 in I&C, for in-stance). There have been some recent losses of I&C technicians:
steps have been taken by the company to improve incantives in this area. The Health Physics group is essentially staffed; Chemistry has lost people but is adequate for continued operations.
The main staffing problem in Chemistry seems to be in retaining a Plant Chemist. Other plant groups; Technical Support, Radwaste, F
Security, and Training are adequately staffed, as are the Engineering, Quality Assurance and Nuclear Support departments outside the plant.
5 Overall, the staffing levels in all essential departments are suffi-3 4!
cent to support continuation of the startup and show progress to-ward an MP&L permanent staff that does not need consultant and contractor support for normal operations.
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- r b.' ' Training and Experience The training and experience level of plant staff are. improved over that of a. year ago by virtue of the extensive operator requalifi-cation program, improved formal training programs for craf ts as well as licensed personnel,, and by the additional year's experience with the plant.
An element of hot operating experience on shift crews is still t:
supplied by BWR Shif t Advisors, as at the 5 percent stage, and this i'
will continue until MP&L operators have appropriate hot experience.
. Worming relations between shif t crews and shift advisors appear to 4
have smoothed out and improved with the passage of time. Shift
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1 Superintendents and Supervisors utilize the experience reservoir of the Advisors to good advantage,. but without being dependent on them.
1 There has been a marked improvement in. training, and new management -
in the Training Department is working toward preparing and Lsproving the training programs for INPO accrediation. This will take i
several years. In the meantime training has moved into a new 3
building with excellent facilities, an Operation Shif t Supervisor (SRO) has taken over operations training, and there : are 2 other -
MP&L SR0s. assisting in training now. The consultant-instructors have. improved their plant knowledge, craft training is very much improved, and student-instructor relations are improved.
b The training and ' experience of plant staff are sufficient to sup-j port continued startup and full power operation.
c.
Staff Performance
. A key element in the Subcommittee's assessment of personnel readi-4' ness to proceed above 50 percent power is the performance of the relatively long and satisfactory experience in reactor operation at up to 5 percent power. Since issuance of ~ the full power license d
the startup has worked into the 20 - 25 percent range and the l
turbine-generator side of the plant has been exercised. Plant Staff performance has been generally excellent. There have been-
- few personnel errors. Some problems have arisen as power has been
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i increased and previously unexercised equipment has been brought into operation. The problems have been equipment-related, and further have been of a design nature rather than plant-staff caused.
There has been a clear improvement in plant staff performance over the past year and that ' improvement, together with the-satisfactory.
performance of power escalation maneuvers and tests to date, sup-port continuation of the startup to full power.
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d.
Summary Staffing is adequate in all essencial departments to support operations to full power. The state of training and experience of the plant staff is good and supports continued startup. The performance of the operating staff to date has been good and sup-ports continued power escalation.
Based on these factors, and on the Subcommittee's assessment from interviews and observations of plant staff, that the staff is confident in their knowledge of the plant and is committed to safe operation and adherence to procedures, the Subcommittee concludes that plant personnel are ready to conduct the intended startup test, and power escalation.
(iii) Morale and Attitudes of Plant Personnel That Have A Bearing on Safe Plant Operation Morale is uniformly excellent in the managers and other personnel interviewed and observed by the Subcommittee. It is apparent that the success achieved thus far in starting up and operating the plant has resulted in an attitude of confidence and a high level of moti-vation. Morale in the maintenance craf te and in licensed and nonli-censed operators has reached the highest level in the history of the project.
A list of attainable goals for 1984 was developed and displayed conspicuously. Plant Management makes frequent reference to status of achieving these goals. A strong sense of responsibility and accountability has been fostered. Praise is given generously for achievement and concern for safety is evident. Likewise, deviations f rom expected standards are dealt with consistently and equitably.
The result has been an increase in the pride personnel take in ful-filling their responsibilities. Complaints are few and when expressed are more likely to be aimed at company policies rather than toward plant management.
Licensed senior reactor operators and reactor operators initially suf-fered a setback in morale last year when they were faced eith the necessity of the recertification program. They now report that they benefited greatly from the experience. They approach their duties now with greater confidence. Operations has had a sufficient number of SR0s and R0s to function on a five shif t rotation. This has reduced the amount of overtime, an obvious boost to morale and atti-tude. Reactor operators have been assured they will have opportunities to be selected for SRO training and thus for promotion when openings exist.
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'nterface between Plant Staff and Nuclear Plant Engineering was re eted by a number of individuals as having rignificantly improved.
Likewise, Operations personnel describe other plant departments au quite responsive. Evidence of a team effort abound, although these important interfaces will continue to require additional effort and refinement to reach their optimal effectiveness and efficiency.
As might be expected, some problems were reported that relate to pay levels, ovetime pay policies, and benefit programs. Mississippt Power and Light is evaluating these issues and recommendations for improvement are forthcoming. The most frequent reason given for resignations appear to be opportunity for higher pay. Within a few days a recently hired Nuclear Human Resources Manager will be on board and should provide leadership to ensure that concerns with company policies will be addressed.
Overall, it is the conclusion of the Subcommittee that morale is con-sistently high and that positive attitudes prevail. There is no reason in this area to preclude the continuation of the startup pro-gram beyond the 50 percent power level.
(iv)
Past Performance In Plant Operations and Adherence to Procedures and Administrative Controls The performance of Plant Staff with respect to plant operations and adherence to proceduralized administrative controls was evaluated.
Particular emphasis was placed on performance of plant personnel during startup testing since receipt of the full power license although activities since the 5 percent power readiness review were also considered. The basis for this evaluation was obtained through numerous in-depth interviews with the key plant personnel combined with a review of various documents.
Plant startup testing since September has proceeded extremely well during those times when the plant was available for testing. Pro-blems encountered have been identified and resolved in a satisfactory manner.
Plant and MP&L corporate management have agressively pursued reso-lution of technical and administrative problems always keeping the safe operation of the plant their primary concern.
During the past year plant personnel have become better acclimatized to the operating environment and more familiar with plant procedures and the administrative program. This increased familiarity has re-l sulted in a significant reduction in personnel errors.
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The General Manager has made significant. efforts to keep plant personnel well informed of critical plant activities through daily and'veekly staff meetings. The recently implemented self-monitoring program has provided an opportunity for senior plant managers to become more familiar with each other's ' programs and responsibilities.
Additionally, the periodic off-shif t, olent walkdowns and the house-keeping walkthroughs performed by blant supervision help to enforce management presence in the plant and indicate their concern for a
. quality operatior..
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a.
Nonconformances/ Procedural Adherence The overall number of LERs has decreased significantly from 1983 levels. This decrease is in part a result of the changed reporting requirements as well as a more experienced, informed staff performing tighter screening c ' reportability.
To reduce personnel errors and stress procedural adherence the General Manager has emphasized to plant personnel the necessity for individuals to accept responsibilities for their actions.
In view of the extraordinary attentio'n to and reviews of the unit Technical Specifications over the last year the Grand Gulf T.chnical Specifications are probably the most-error free in the country. The extensive reviews of surveillance procedures completed a year ago, and some subsequent corrections have put the surveillance procedures in the same state. Operating procedures and administrative procedures have been revised as needed. The low power operating procedures have been exercised ' a lot and well shaken down. Procedures for operation at higher powers, especially on the steam plant side, are being tested in use as the startup proceeds and are changed as found necessary.
Changes have not been of a major nature, but rather of a fine-tuning kind. Overall, the Technical Specifications and station procedures are
~ in excellent condition to support continued startup and power operation.
As. the plant has progressed up in power and Mode 1 surveillances run, some for the first time, and other equipment brought on line for the first time, numerous procedure changes have been required. Despite this recent surge of TCNs they are being incorporated formally into plant procedures within the required time frame.
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L The General Manager has sent a letter to each Department Manager j
instructing ches to inform their staff as to the importance of-p procedural adherence and what was meant by verbatim compliance.
4 The number of PQDRs have been holding constant over the past year..
_ The type of deficiencies that are now being reported tend to be.
more subtle than those reported earlier and flagrant abuse of or non-adherence to procedures is not occurring.
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b.
Operations
_ Operations personnel have performed 9 reactor startups and the reactor has operated approximately 1660 hours0.0192 days <br />0.461 hours <br />0.00274 weeks <br />6.3163e-4 months <br /> at power thus far j.-
experienced by other. units during power ascension.
in 1984. The number of automatic trips has been less than that 4
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. Approximately 50 Temporary Alterations are outstanding and these j
are reviewed monthly by responsible plant management.
1 MP&L has performed an in-depth evaluation of the Health Physics Program using a MORT approach. This evaluation has resulted in an action plan which should result in.a greatly improved and more effective HP program. To gain more in-plant experience GCNS HPs are spending several weeks with HP groups at other operating reactors.
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1 c.
Maintenance Since the 5 percent review, when Maintenance's ability to keep up with the workload was in question, a major turnaround has been j
achieved. Preventive maintenance is now up-to-date'in Electrical
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and I&C areas, in Mechanical there is a large apparent PM backlog l-but re-examination of the need for all of it may result' in sub-f stantial reductions and a strong recovery program is underway for t
the rest.: On MWOs, for corrective maintenance, repairs, and equip-ment changes, Electrical is current with only a normal working number of MW0s in process. I&C and Mechanical have )SiO backlogs generated as the startup has exercised new parts; these. are being worked down in good shape and Maintenance expects to be current in all areas in both PMs and MW0s by the start of commercial operation.
The MPSS system is now fully operational and is used by Mainte-nance to schedule all PMs, I&C calibrations, as well as surveil-lance tests.
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Early in 1984 several events that resulted in LERs were caused by a failure to perform in-depth reviews of MW0s prior to working to determine impact on other systems or operations. To overcome this problem a more formalized multi-tier review process was implemented in Work Control Procedures and individuals are chartered with the responsibility to ensure that the work planned does not impact operations. This process seems to be working in that the number of incidents resulting from inadequate review of work activities performed in the plant has decreased significantly.
d.
Summary In the area of past performance in plant operations and adherence to procedures and administrative controls, the plant and staff are ready to proceed with operations above 50 percent power.
(v) Changes in Current Organization With Regard to Experience and Qualifications of Plant Supervisory Personnel Since the Last Evaluation A major reorganization of the MP&L corporate organization, as related to responsibilities in the nuclear area, took place in May, 1984. This reorganization and realignment of responsibilities was undertaken to better accommodate the needs of a commercial operating nuclear unit and to allow more direct management involvement in those activities necessary to support operations. To bring nuclear experience to the highest management level within MP&L, the position of President and Chief Operating Officer was created and is filled by an individual with previous commercial operating experience and extensive experience in nuclear utility management.
Within the Nuclear Production Department, the new organization has five positions reporting to the Sr. Vice President - Nuclear, including:
a new position, Director Nuclear Engineering and Construction with responsibilities for outage planning, Unit 2 construction and Nuclear Plant Engineering; Director of Quality Assurance; Vice President, Nuclear Operations with responsibility for overall plant operation and nuclear licensing and safety; a new position, Manager of Nuclear Human Resources, with responsibility for planning, Forecasting and budgeting in the human resources area and for overall nuclear employment policies, recruiting and training; and a new position, Director of Nuclear Support with responsibility for administrative support, nuclear fuels and radiological support. the President - Nuclear Operations position is currently not filled. An individual with previous commercial experience has been hired as the Manager of Nuclear Human Resources. The former Director of Quality Assurance is now the Director of Nuclear Support and the former Manager of Nuclear Site / Quality Assurance has been promoted to Director of Quality Assurance. The new Director of Nuclear
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i Engineering and Construction was previously Unit 2 Construction Manager 3
and had previously been Manager of NPE. Recently a new Manager of NPE has been hired who has commercial BWR operating experience.
At the plant level, the previous plant manager has been replaced by the
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former Assistant Plant Manager for Operations who war promoted to General Manager. A new individual is currently the Acting Manager, Plant Operations. This individual, was previously licensed on 3 BWRs and has eleven years of commercial operating experience. He is well qualified for this position.
The Maintenance Department has been realigned.
Individual discipline superintendents I&C, Maintenance and Electrical, have replaced the 1
previous Maintenance Superintendent. This change provides for more management involvement in important maintenance activities. The Electrical and Mechanical Superintendents are new to their positicn although both have considerable nuclear experience and appear to be well qualified.
The former Operations Superintendent resigned and was replaced by a licensed Shift Superintendent. This individual is licensed at Grand Gulf and meets the requirements of this position. The former Technical Support Superintendent has been replacad by an individual who was previously Startup Superintendent. The previous Technical Support Superintender.t is currently in Senior Reactor Operator License training.
The qualification level of the on-shift supervisory personnel has been enhanced by completion of the extensive recertification and re-examination program. In addition, the shift advisor training program has been improved and formalized. Each level of the operating organization has gained an additional year of experience werking under an operating license.
The subcommittee concludes that these changes in organization and realignment of responsibilities will allow more management involvement in important activities and should promote responsive support to the plant, thereby resulting in a safer and more efficient plant operation.
(vi) Results and Effectiveness of PSRC The subcommittee used several approached in assessing the results and effectiveness of the PSRC.
a.
We were represented at a number of PSRC meetings.
b.
We reviewed the minutes of all PSRC meetings held since July 31 1984 (Meeting 162/84).
c.
We directed an independent review of the administrative procedure controlling PSRC activities comparing its provisions with Technical Specification requirements.
d.
We were briefed by the Site Quality Assurance Manager on an audit of PSRC activities currently in progress.
e.
We interviewed the Vice Chairman of the PSRC.
f.
We reviewed current PSRC requirements and activities in light of the comments contained in the 5 percent power operational readiness review report.
The PSRC appears to be conducting those reviews required by the Technical Specificatioti). The reviews are timely and backlogs are being reduced. The only existing backlogs are in DCIP closeout review and PSRC closeout of old incident reports. These are being handled by a special subcommittee. The backlog is expected to be completely eliminated within a few months. To keep current, the PSRC meets almost every day and on some days twice. On October 19, 1984 it met three times.
Meeting minutes indicate that attendance is frequently the minimum required for a quorum and the attendance by one particular member is the exception rather than the rule.
As recommended by the 5 percent power operational readiness review, the PSRC charter has been revised to provide for a two-committee structure, i.e.,
one operations-oriented chaired by the Manager Plant Operations and a second maintenance-oriented chaired by the Manager Plant Mainte-nance. This two-committee structure is not currently in use because the Manager Plant Operations is not available to serve on the PSRC and the Manager Plant Maintenance chairs all meetings. This is only a temporary condition which will be corrected when the Manager Plant Operations becomes available.
PSRC meetings attended by subcommittee members were conducted in a thorough, professional manner but meeting minutes only marginally document the important elements of reviews conducted. We noted the PSRC as a normal activity was reviewing and dispositioning a listing of items identified by the Licensing Commitment Tracking System (LCTS) as requiring completion prior to exceeding 50 percent power.
The subcomm!ttee concludes the PSRC is functioning satisfactorily and is providing thorough reviews of scheduled documents placing proper emphasis on safety concerns.
, (vii)' -Status of Plant as Compared to Other BWR Startups Based on the Subcommittee's Knowledge and Experience The-subcommittee considers Grand Gulf Nuclear ' Station, when compared to' other BWR units at this. stage in the.startup testing and power ascension. program, to be superior in many respects. This significant-difference exists in part because Grand Gulf has been licensed in excess of two years and because of corrective actions that were imple-mented following fuel load. ' The plant staff has become acclimatized to working in a disciplined and controlled environment and corporate management and support organizations have developed an improved appre-ciation of. functioning in the licensed arena. As a utility, Missis-sippi Power and Light Company has natured and learned some valuable lessons during this time.
The following are specific areas where the plant has benefited by this maturing process:
a.
Completion of Construction It is commonplace for construction activities to be in progress and construction personnel present albeit under the control of the operating forces at the time a reactor receives its operating license. This'was true at Grand Gulf Nuclear Station. GGNS is unique in that because of delays in operation, construction forces finished their work and departed from the operating areas before
- 5. percent power was exceeded. It is the norm for construction forces to be present throughout the entire power ascension pro-gram. This freedom from construction results not only in a neater, cleaner facility but more importantly with less acti-vities -to manage and hence less distractions.
b.
System Readiness As compared to other BWR units at this point in startup, the sys-tems ;are in a high state of readiness. Service and support systems have been in operation for several years. _ Noted defi-ciencies have for the most part been corrected and personnel are-f amiliar with their operation. There are no open ' exceptions resulting from the preoperational test program. Under the sur-veillance program, safety system response has been demonstrated.
-While the prolonged startup has not measurably benefited balance of-plant systems, they have for the most part responded well when called upon. Their readiness compared well to that of other units in startup.
c.
Security Full security is placed in effect at nuclear units just prior to licensing and subsequent fuel loading. In general, by the time the unit reached 50 percent power, full security has been in effect for four months. Full security at Grand Gulf has been in effect since June 1982, well in excess of two years. The security organization and practices at Grand Gulf are matured and experienced beyond the level normally encountered at this stage in initial startup.
d.
Technical Specifications As a result of the Technical Specification Review Program which,)
occurred in March 1984, the Grand Gulf Technical Specificationjg are complete and accurate, we believe the plant is at the fore-front of the industry in this regard.
e.
Surveillance Program Because of deficiencies noted after the initial license was received and surveillance program placed in effect, a complete review of surveillance procedures and their ability to demon-strated Technical Specification requirements was made in the fall of 1982 and early 1983. As a result, the surveillance procedures at Grand Gulf are above the industry norm and no other unit has had its surveillance program in place in excess of two years at this phase of startup.
f.
Operator Qualification The GGNS Operations Group has received more extensive training and has been subjected to nore rigorous examinations than any group of cold licensed operators the subcommittee has knowledge of.
This is a result of the requalification program MP&L con-ducted as a result of questions concerning training records.
(1) The first phase of this program was to require each licen-sed operator to demonstrate his knowledge of operation of each plant system in plant walk-throughs, or on the simulator, as appropriate. Then each operator was recer-tified by the Operations Training Evaluation Committee (OTEC). This committee was composed of an Assistant Plant Manager, an SRO from the Operations Department, and an SRO from the Training Department. The OTEC certification pro-cess consisted of a review of each candidate's record and an oral examination of the candidate's knowledge of the plant.
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6 After completion of the MP&L recertification effort the NRC Region II office re-examined each licensed operator. This consisted of a 2 - 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> oral examination and a 2 - 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> simulator performance examination.
The Grand Gulf STAS also underwent a recertification effort which included a review of their training records and an oral examination by the OTEC panel.
(2) MP&L has certified each of Grand Gulf's on-shif t advisors.
A specific training program was developed to provide each of these previously BWR licensed individuals with training as to the differences between Grand Gulf, BWR-6, and previous vintage boiling water reactors. This program involved training on plant systems, procedures, and Tech Specs fol-loved by an OTEC examination. Also, each advisor received two additional weeks of simulator training in power ascen-sion and emergency operating procedures and an examination on that training.
The performance of the operations group during the power ascension from the 5 percent plateau has been excellent.
III. Follow-up Observation of Comments and Recommendations Contained in The 5 Percent Power Operational Readiness Review Report The subcommittee, in the course of its investigation, reviewed the reso-lution of comments and recommendations contained in the 5 Percent Power Operational Readiness Review. The following are our observations:
1.
Status and readiness of the plant and systems needed to support intended modes of operation and/or testing.
The intent of the 5 percent Readiness Review comments and recommendations have been met in this area. Our review of the roadiness of the plant and plant systems confirmed the following:
a.
Housekeeping at the plant has shown considerable Laprovement and access to the Control Room is now controlled.
b.
The exception list from the Pre-op Test Program is closed with a few items carried over to the Power Ascension Program.
c.
The Radwaste floors and walls are sealed and a portable crane is used to move the small liners.
d.
An augmented testing and inspection program has been implemented for the diesel generators. In addition, a number of diesel com-ponents were redesigned and installed. Post-maintenance testing was performed following installation. The diesel test loads have been reduced to a value consistent with the expected LOP /LOCA loads Normally energized, safety related Agastat GP relays have been e.
replaced and all defective ITE breakers were replaced prior to exceeding 5 percent power.
ii. Readiness of Personnel to Conduct Intended Operation and Testing An extensive operator requalification program was undertaken by MP&L to correct deficiencies identified in the operator training program. The program was completed prior to progressing above 5 percent power. The stability of the present 5 shift crews are maintained to the extent practicable. The shif t clerk position has been established and is cur-rently staffed with regular MP&L employees. The STAS and BWR Advisors remain assigned to and rotate out for training with the shif t as much as practical. The STAS and Shif t Advisors participate in selected training during the fif th week. The Shif t Advisors appear to be used appropriately and are helping the shif t teams to function effectively.
Operational performance during startup testing to date indicates that
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the startup program is progressing in a safe and proper manner.
2ne training pipeline has improved substantially and with the reduction in turnover there appears to be sufficient numbers of licensed personnel to meet operations needs. Additional candidates will be required to fill licensed training classes to provide licensed personnel for training instructors.
The backlog of PMs in the Electrical and I&C areas have been reduced significantly. In the Mechanical area there remains a significant backlog although measures are being taken to address the problem.
Staffing needs of the I&C and Electrical areas appear adequate while additional personnel may be required in the Mechanical group.
iii. Morale and Attitude of Plant Personnel That Have A Bearing on Safe Plant Operations Morale problems among operations and other plant staff personnel have been resolved as a result of the successful completion of the operator
5 requalification program, the positive changes in plant supervision and
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synchronization to the grid.
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Operations personnel have gained additional respect for the Training Department as a result of (1) the improved familiarity with GGNS i_
achieved by the instructors through time spent on shift during the g -
requalification program, (2) the assignment of an operations SRO as p
Operations Training Supervisor, (3) the assignment of a Training Coordi-nator to assist the Operations Superintendent to interface with the i=
Training Department, and (4) improvements in training material and facilitics.
I Instruction on design changes appears adequate and is provided as part of the fifth week training effort. The Operations Training Coordinator 7
provides last minute instructions on significant design changes to the
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operating shifts. The adequacy and need for additional training i
on general background material was assessed.
The training pipeline includes allocations for providing shif t-experi-7 enced SR0s for training instructors. To achieve this will require con-tinued efforts to fill upcoming licensed operator classes.
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iv.
Past Performance in Plant Operations and Adherence to Procedure and Administrative Controls.
Z The MPSS system is an on-line system that is accessible via terminals
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at key locations. MPSS is used to generate task cards for surveillances, PMs, and I&C calibrations.
The Technical Engineering group is performing a review of selected sur-E F
veillances to ensure that acceptance criteria are being met. Prior to exceeding 5 percent power the 50.59 evaluations on outstanding TAs g
were reviewed.
7 Numerous TCN's are currently outstanding although none are beyond their
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late date. Numerous procedure changes were required to enable Mode 1 surveillances to be run and additional plant equipment to be brought
-; i on line for the first time as the plant has increased power. The processing of TCN's seems to be proceeding in an appropriate mannar.
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To avoid programmatic changes during power ascension the reporting system for nonconformances has not been changed significantly. Clarifications to not require an IR to document LCOs have helped to reduce the number of irs and correspondingly the volume of paperwork.
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N Management has continued to emphasize the importance of procedure adherence. The srecess of this effort is evidenced by the overall reduction in personnel errors in maintenance and operations acti-vities.
v.
Changes in Current Organization With Regard to Experience and Qualification of Plant Management and Supervisory Personnel Since the Last Evaluation Consultants are being retained and used where appropriate. As experi-ence with plant operations increases and staffing with permanent MP&L personnel continues, the need for contractor support will decrease.
The consultant to the Radwaste Supervisor has been replaced by the promotion of an experienced Radwaste Operator who is a permanent MP&L employee. Similarly, two consultants are currently being retained as an Operations Assistant and an Operations Training Assistant to the Operations Superintendent. One Operations Assistant position is cur-rently filled by an experienced MP&L SRO.
Plant Management appears e
.e effectively utilizing their experienced personnel during the startup program. The extended operation of the plant below 5 percent power and the startup testing to date has pro-
=
vided considerable operating experience for plant personnel.
vi.
Results and Effectiveness of The PSRC It is evident that positive action has been taken to alleviate concerns previously expressed concerning PSRC activities. It now appears that the PSRC is conducting those reviews required. The reviews are being conducted in a timely manner, and the PSRC charter has been revised to provide for a two-committee structure.
vii Status of Plant as Compared to Other BWR Startups Based On Subcommittee Knowledge and Experience.
Our review confirmed that management and staff are continuing with their efforts to ensure procedure adherence, encourage attention to detail and instill positive attitudes.
IV.
Recommendations (1) For long term operation we recommend that aggressive action be taken to make the RHR steam condensing mode available for the operator.
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(2) Concerning the Loss of Offsite Power Test (LOP), we recommend de-talled planning to ensure that this test will provide widespread training for operators, that adequate personnel are on shif t at the time of the test and that actions are preplanned in the event that the LOP test does not proceed as expected.
(3) Improve the documentation of PSRC meetings by providing more of the important elements of reviews conducted.
(4) Encourage complete member attendance at PSRC meetings.
(5) Consideration should be given to establishing a group of dedicated radwaste workers to process, package and ship radwaste.
(6) In order to facilitate the sorting and shipping of dry active radwaste consideration should be giva to construction of a staging facility.
(7) Develop and implement a plant water management program to decrease the quantity of make-up water and releases.
(8) A review of the policy allowing food and drinks in the Control Room should be performed.
(9) To reduce the number of instances of " Failure to Follow Administrative Controls"as indicated by nonconformances on PQDRs, periodic training or
-refamiliarization with Plant Administrative Controls should be improved particularly for maintenance personnel. Items such as:
how to obtaia tools / equipment, obtaining warehouse items, processing MW0s, requesting tagging, procedure approvals, etc. need to be well understood by all maintenance personnel.
(10) The need for the Requirement Procedure Tracking System (RPTS) should be evaluated. If the need for RPTS is present then such a system should be implemented in a timely manner.
(11) Consider the merits of establishing system engineers. Each system would be assigned to an engineer charged with overall responsibility for the system. He should know the design, performance, the required PMs, operating procedures, etc., and should look for long-term La-provements.
(12) Trending on nonconformances has improved; however, a more integrated approach looking at root causes of significant irs, PQDRs, MNCRs, and CARS is suggested. A process to provide feedback on trends to manage-ment should be strengthened.
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