ML20151B790
| ML20151B790 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/31/1988 |
| From: | LOUISIANA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20151B793 | List: |
| References | |
| NUDOCS 8804110270 | |
| Download: ML20151B790 (56) | |
Text
[.
y g7 Louisiana Power 8 Light Company NUCLEAR OPERATQ@MS
. MIDDLE SOUTH.
UTil.lTIES -SYSTEM S
LEADQkl@ TME WAY T@ RECHLLRhl@H N
ces g;
4
.~
WATERFORD STEAM ELECTRIO STATION - UNIT No. 3 1987 SALP PROGRESS REPORT t
x March 1988 b
s
!!A"A88cR8!880502 G
__ _ ___ j
i Attachment to:
W3P88-0302 Louisiana Power Light Company WATERFORD STEAM ELECTRIC STATION - UNIT No. 3 1987 SALP PROGRESS REPORT March 1988 r
I
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 1987 SALP PROGRESS REPORT TABLE OF CONTENTS Page No.
Section SALP Performance Functional Area 1
Introduction 8
A Plant Operations 18 B
Radiological Controls 22 C
Maintenance 27 D
Surveillance 29 E
Fire Protection 31 F
Security and Safeguards 38 H
Outages 41 I
Quality Programs and Administrative Controls Affecting Quality 46 J
Licensing Activities 50 Training and Qualification Effectiveness i
NS20745 l
=.
i t
l LOUISIANA POWER & LIGHT COMPANY
,vATERFORD 3 1987 SALP PROGRESS REPORT INTRODUCTION The 1987 SALP rating period saw Waterford 3 complete its transition from a startup oriented organization to an operations based organization. A number
{
of positive changes were implemented over the past year directed towards building and maintaining a cohesive Nuclear Operations Group founded on opera-tional excellence. In fact, the watchword adopted by our new Senior V3ce
(
President for Nuclear Operations during his first full year at Waterford 3 has l
been "excellence" - excellence in all aspects of the nuclear organization.
Our approach towards excellance in operations is perhaps best exemplified by
{
plant performance. Waterford 3 Senior Management set a goal of achieving a capacity factor of at least 75% for 1987. This goal was particularly ambitious in that a refueling outage continued into February 1987. We exceeded our goal
[
with a capacity factor of 78.9% for 1987. As a direct result, for the two l
years, 1986-1987, Waterford 3 safely generated a total of 15,482,960 megawatt-hours of electricity - the top US nuclear generator for this period.
(
Excellence in regulatory affairs was a key goal last year and will remain one for the future. During the latter part of 1987, Waterford 3 management insti-tuted a series of actions to assure that the information interchange between
(
plant staff and the Resident Inspectors would be enhanced. These actions included instructing the supervisor for the Event Analysis & Reporting unit to provide a briefing for the Resident Inspectors following any significant events l
at Waterford and to provide periodic briefings on Potential Reportable Events I
and Licensee Event Reports. The expansion of the Event Analysis and Reporting organization in size and responsibility under the Vice President-Nuclear's Human Error Reduction Program is also expected to have a positive impact on the regulatory interface.
The Plant Manager has instructed key plant personnel to provide the Residents with regular briefings on activities within their depart-ments as well as discussin;; potentially significant events or conditions. The l
Plant Manager has also renewed efforts to discuss issues involving plant operation more frequently with the Resident Inspectors as well as to increase the frequency of communications with Regional Management.
In fact, the NRC
[
Resident Inspector periodically attends the plant Plan-of-the-Day meeting and I
is invited to address the staff assembled on any area of interest. The Licensing organization has continued its practice of frequent and detailed communications with NRR personnel.
In the time these actions have been in f
effect, the communication process has improved considerably. We will continue to monitor this situation to assure the Resident Inspectors receive the infor-mation they require in a timely manner.
Waterford 3 has taken actions tc innrove radiation monitoring systems reliabil-ity. These actions include personnel enhaacement in the affected areas, train-ing enhancement, equipment replacement in some cases, analysis of failure history and trends on radiation monitors, providing solutions for recurring problems, and development of a tracking system for the radiation monitor system database and a basis for the numbers contained in the database.
. NS20745
L
(
Waterford 3 has continued actions to reduce the level of airborne radioactivity L
in the Reactor Auxiliary Building and intends to maintain a high visibility and priority for the effort to minimize both liquid and gaseous releases. We also intend to institute a Leak Reduction Task Force to concentrate effort in this
(
area.
The Nuclear Operations organization within LP&L has recently undergone an
[
organizational restructuring to increase the efficiency of operation.
In I
general, the restructuring includes the creation of a new position, entitled Nuclear Operations Management Systems Manager (this department will be respons-ible in part for Nuclear Operations management information systems), which
(
reports to the Vice President-Nuclear; the Nuclear Sai'ety & Regulatory Af f airs Department now reports directly to the Senior Vice President-Nuclear Opera-tions; the elevation of the Event Analysis and Reporting Engineer to the Event
{
Analysis, Reporting, and Response Superintendent, who now reports to the Plant Manager-Nuclear rather than the Assistant Plant Manager-Technical Services (this change will also add additional responsibilities to this group such as j
trending, root cause analysis, and Part 21 evaluations); and, the repositioning l
of the Nuclear Operations Construction Hanager, who now reports to the Nuclear Operations Engineering Manager rather than the Vice President-Nuclear.
f Perhaps more important than organizational restructuring was the management rotation implemented at the same time.
In order to broaden the experience base in Nuclear Operations, the majority of managers immediately below the senior level, including those reporting to the plant manager, were rotated into comparable positions of responsibility.
Two significant achievements in Nuclear Operatioas Training occurred in December 1987 with the accreditation of Waterford 3's 10 basic training courses and granting of full membership in the National Academy of Nuclear Training.
In January 1988, an INPO evaluation was completed with an overall INPO rating of "2".
INPO identified 15 findings, 6 strengths, and 3 good practices. This compares to an overall rating of "3" with 25 findings, 3 strengths, and 3 good practices in the previous evaluation conducted in February 1987.
In :ommenting on the evaluation, the INPO team leader was favorably impressed by the follow-ing:
strong management assessment programs have contributed to improved personnel performance, housekeeping, and material condition; the station continued to have high availability and good plant thermal performance during the past year; efforts to reduce contaminated areas and radiation exposure are noteworthy; and, station personnel exhibit a strong desire to improve and achieve excellence in operation.
Although not a specific area of NRC SALP review, we feel that the frequency of lost time accidents is an important indicator of employee morale and employee dedication to achieving operational excellence.
In this regard, we are proud to report that since May 1985 to date, Waterford 3 maintains a "zero" lost time accident rate.
Over five million hours have been worked during this period without a lost time accident.
The remainder of this report reviews, in detail, the accomplichments of Waterford 3 personnel for each SALP functional area since the previous SALP evaluation period ended on January 31, 1987.
Selected highlights are summarized below: NS20745
r L
A.
Plant Operations A Management Observation Program was implemented to improve the monitoring of routine activities by dividing responsibilities for touring and observ-ing plant work amongst responsible plant supervisors and managers.
Key plant personnel have been assigned as Area Coordinators within the plant to improve the material condition of the plant.
An Operations Writers Guide based on human factors expertise has been developed and is being utilized to assist in the technical and human factors upgrade of normal and off-normal operating procedures.
A marked reduction in erroneous, misleading or unnecessary control room annunciations continued through 1987 as a result of the Annunciator Reduction Program.
Temporary alterations have been significantly reduced.
The role of the Shift Technical Advisor in support of emergency assessment has been re-emphasized, reducing the STA's administrative workload.
As part of the Human Error Reduction Program under the cognizance of the Vice President-Nuclear, the Event Analysis and Reporting organization is being upgraded and expanded to provide additional emphasis on root cause determination, trending of conditions adverse to quality and NRC communications.
Significant procedotal and hardware improvements have been, or will shortly be, implemented to increase operator capability and flexibility in dealing with plant upsets during partially drained RCS conditions.
As part of the trip reduction effort, plant modifications have been imple-mented to further reduce the frequency of plant trips.
Due to concerted efforts directed towards retention of experienced opera-tors, there were no operator resignations during 1987.
B.
Radiological Controls Significant management and technical attention has been, and continues to be, directed towards reduction of radioactive leakage in liquid and gaseous systems.
Senior Health Physics staffing has been increased with the addition of experienced personnel chartered with direct oversight of radiation protec-tion programs and additional in plant presence.
A number of procedural and hardware changes have been implemented to minimize the potential for contaminated personnel to leave the site.
LP&L representatives continued their leading role in the Central Inter-state Low-Level Radioactive Waste Compact. NS20745
i Extensive efforts have resulted in the reduction of contaminated areas in the plant from 22,800 square feet to 5,100 square feet - less than 5% of the total radiation controlled area outside the Reactor Containment Building.
C.
Maintenance The Staticn Information Management System (SIMS), a comprehensive computer-ized data base used in all aspects of corrective / preventive maintenance, surveillance tasks, inservice inspections, etc., became fully operational.
The Material Management Information System (KMIS), which includes approxi-l mately 70,000 material items, was implemented for Waterford 3 in late 1987 to automate and substantially enhance the information control for procure-ment aad material functions.
l Strong emphasis has been placed on SIMS and MMIS implementation. Responsi-bility for these management systems now lies with the newly formed Nuclear Operations Management Systems Department, which reports directly to the Vice President-Nuclear. Previously, these areas fell under the Nuclear Operations Support & Assessment group, reporting directly to the same officer. Both major management information systems were implemented within the past eight months.
The corrective maintenance backlog was reduced from 572 items in December 1986 to 477 items in December 1987.
The preventive maintenance backlog has been reduced from over 1000 tasks to less than 365.
Repetitive maintenance tasks were reduced from 20,700 in January 1987 to 15,709 by November.
Containment work conditions will be substantially improved by the install-ation of a containment air conditioning system for the refueling outage.
D.
Surveillance A task force has been created to evaluate and provide solutions to problems associated with the radiation monitoring system.
Five process radiation menitors will be replaced during the upcoming refueling outage with models of proven reliability.
The Waste Gas Holdup System Explosive Gas Monitoring System has been completely redesigned and, upon implementation, should greatly reduce the number of nonroutine surveillances.
E.
Fire Protection
^
Management attention has been successful in maintaining fire impairments at or below the goals set.
Consequently, routine fire watches have been significantly reduced.
-4+
NS20745 A
The annulus fire detection syster. will be replaced during the refueling outage to enhance access, operation and maintenance during all modes of operation.
F.
Emergency Preparedness A ciren feedback and monitoring system will shortly be implemented in the local parishes to allow continual remote monitoring of critical siren system functions.
Training programs for emergency response personnel are continuously up-graded based on drill performance, reviews of the training programs by management and Quality Assurance, NRC input, etc.
The Waterford 3 Simulator is being utilized to develop and conduct emergency preparedness drills.
The Alert Notification Sys*.em has been tested and approved by FEMA -
telephone surveys conducted by FEMA indicated that 91% of persons surveyed were directly alerted by the test, the highest rating for any plant in FEMA Region IV.
G.
Security and Safeguards In the most recent period for which statistics are available, random urinalysis tests showed less than 1% positive findings as a result of management attention to drug awareness education.
A large number of Security Department systems and programs have been, or are in the process of being upgraded, including the perimeter detection system, security computer system, and access control program.
Management continues to place emphasis on individual personnel responsi-bility for security through upgrades to training programs, meetings to acquaint personnel with new Security reporting requirements, informational postings and outage instructions.
l The criminal history check requirements of 10CFR73.57 have been implemented.
Contract Security personnel and the Security Training Program are certified by the State of Louisiana.
l The attrition rate of Security personnel was reduced from 20% in 1986 to l
11% in 1987.
A complete redesign of the closed circuit television system which is currently in progress will greatly enhance the operation, performance and reliability of the system.
l l
i NS20745
(
L H.
Outages As with the successful first refueling outage, the planning, organization and training of outage personnel was begun well in advance of the second refueling outage scheduled to begin in April 1988.
The efficiency and coordination of equipmcnt outages has been significantly improved through implementation of the Station Information Management System, consolidation of tasks and scheduling system improvements.
I.
Quality Frograms and Administrative Controls Affecting Quality A number of hardware upgrades to the plant monitoring computer (PMC) are in progress or planned to increase the PMC reliability including upgrades to the static uninterruptible power supply and fixed incore detector signal cables, purchase of a more reliable sof tware system for CPU 3 and install-ation of a hardware reset switch.
A human factors review of Operations and Maintenance procedure writing guidelines has been completed and the results will be used to upgrade procedures and reduce procedure violations due to human factors problems.
The remaining open items from the NRC's EQ Inspection have been addr-ssed.
The station modification process has been upgraded to enhance plant configuration control.
The number of open station modification packages has been reduced by 635 since January 1987.
An integrated Receipt Inspection Plan was implemented to consolidate the audit, receipt inspection and material issuance processes.
The Quality Trend Program was upgraded to provide more meaningful informa-tion to management and implement an improved root cause identification system.
J.
Licensing Activities The few remaining longstanding issues with the NRC were resolved during 1987 including details of the redesign of the Safety Parameter Display System, the Detailed Control Room Design Review, and the confirmatory analysis and monitoring program associated with the basemat cracks.
A high level of senior management involvement in licensing activities continued through implementation of periodic Nuclear Operations senior management meetings which regularly consider current regulatory issues.
Licensing actions necessary to support the second refueling outage and Cycle 3 were presented to the NRC well in advance of the scheduled outage resulting in no anticipated license based delays. NS20745 U
i The Middle South Utilities System and Waterford 3 management in particular have adopted as a primary goal the achievement of regulatory excellence and
(
have taken a number of steps in pursuit of that goal.
K.
Training and Qualification Eftectiveness The Training Department has successfully accredited all 10 INPO training programs.
The Waterford 3 simulator is operational, has supported four cycles of operator requalification training and has proven useful in supporting other areas of plant operations such as procedural improvement.
Non-licensed personnel training programs bave been given strong emphasis through the accreditation of INP0 training programs and implementation of monthly systems training.
Through cooperation with the University of Maryland a Bachelor of Science Degree Program is being offered to nuclear plant operators and delivered locally. NS20745
l L7 c
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area A.
PLANT OPERATIONS 1986 SALP Category: 2 1985 SALP Category: 3 Summary of NRC Recommended Licensee Actions 1.
Continued efforts to clear illuminated annunciators, remove temporary plant alterations, and eliminate spurious ventilation actuations should be given priority.
2.
Shift technical advisors should be removed from duties involving largely administrative functions so they can concentrate on tne duties and respons-ibilities outlined in Technical Specifications.
3.
Licensee management should ensure preparation, tracking, and closure of regulatory compliance issues are pursued with the same systematic approach
{
normally taken in the licensing area.
Current Status The successful performance of Waterford 3 during 1987 was due in large measure to the professionalism and dedication of the Operations Department. During the year, a number of new and continuiug initiatives contributed to our good record of safety and plant availability.
1.
Continuing Management Involvement Appropriate management emphasis has been placed on correction of recurring plant problems.
Advisory groups are being utilized in the maintenance, operations,'techni-cal support, and administrative areas. These groups, which include key members of each department, are tasked to identify and recommend solutions to station problems, and draw expertise from other groups when needed.
Group meetings are usually held monthly or when significant plant events occur. Reconnendations or requests for support are forwarded to the Plant Manager-Nuclear. The activities of these groups facilitate timely solu-tions to problems that affect the station. For instance, the Technical Services Advisory Group with assistance from the Operations Group investi-gated t':e root cause of the reactor trip which occurred on 1/1/28. Recom-mendations from this investigation resulted in guidelines for Axial Shape Index (ASI) monitoring during reactor startups being added to the operating procedure, additional training for Operations personnel on Core Protection NS20745
[
Calculator monitoring of ASI at low power, and stationing of a reat*or engineer in the Control Room for consultation on reactor startup through the 20% power level.
The efforts of the advisory groups to prevent recurring plant problems are supplemented by the Management Observation Program, the Plant Improvement List, as well as a concerted effort by line management to identify and correct problems as they occur.
In March 1987, a formal Management Obser-vation Program was established to improve the monitoring of routine activi-ties at Waterford 3.
The program tracks the monitoring actions and divides responsibilities for touring and observing station work among supervisors and managers. During 1987, over 50 formal observation tours were conducted including observations in the areas of: Health Physics, Chemistry, Opera-tions, Maintenance, Simulator, and Back Shift. Results to date indicate a positive impact in the areas observed.
Area coordinators are assigned to control housekeeping, to identify and monitor correction of nagging minor problems, and to ensure area cleanli-ness levels are satisfactory. Each area coordinator is given a check list of typical concerns to be monitored routinely in the area.
In addition, management sponsors are assigned oversight responsibilities for designated area coordinators. The Assistant Plant Manager, Operations and Mainte-f nance, along with a team of specialists from Industrial Safety, Health Physics, and Maintenance, conducts weckly walk-throughs of specific areas with the responsible area coordinator. This walk-through provides direct feedback to the area coordinator on the level of achievement in his area.
Items that require correction are identified on a Condition Identification if they involve maintenance on plant equipment or on the Plant Improvement List if they are of a housekeeping or minor nature. The assignment of key personnel to collateral duties as area coordinators has done much to improve the material condition of the plant.
Plant Management utilizes the Nuclear Operations Support and Assessment Organization (NOSA) for detailed independent assessments of significant or recurring plant problems. For instance, during 1987 NOSA undertook, among other things, evaluations or assessments of Health Physics outage readi-ness, primary and secondary chemistry control, instrument and station air system performance, maintenance of dry cooling tower fan motors, and j
reactor coolant drain down operations. Operation Assessment & Information i
Dissemination, a subgroup of NOSA, also reviews industry operating experi-ence (e.g., INPO SOERs) to provide Plant Management with recommendations for plant safety and performance improvement. The Quality Assurance organization is another resource available to Plant Management which can provide surveillances on request to ascertain quality levels and recommend improvements.
2.
Plant Status Controls Waterford 3 management recognizes the importance of maintaining accurate system status control.
9 NS20745
e O
I The Operations Superintendent continues to emphasize to operations person-nel the importance of using and updating administrative systems for plant status control. Additionally, the Operations Department reviews methods for improvements to administrative controls.
Some actions taken include:
a.
Periodic valve alignment checks.
b.
Actions to control the Annunciator Status Log.
c.
Actions to enhance control of Caution Tags.
d.
A review of the overall Temporary Alteration Program was completed (see Item 6, below).
In addition, the Control Room drawing program was reviewed in detail and strengthened considerably as a result. For example, the Control Room document distribution practices were expedi-ted; drawings were converted to an aperture card file and an aperture card reader was provided. A further result of this review was a new practice to distribute the Temporary Alteration Request list periodi-l cally at the Plan-of-the-Day meetings for the information of l
supervisors and managers.
3.
Identification of Plant Deficiencies The Operations Superintendent has stressed the need to identify plant a.
deficiencies through three interrelated techniques:
(1) supervisors' meetings, (2) departmental all hands meetings, and (3) publication in the daily instructions. A vital part of the Management Observation Program has been surveillance of Operations Department personnel on shift with direct feedback to the personnel observed and reports to the Plant Manager. Also, the SIMS system (sce item 5. of Section C.
Maintenance) is now on-line and available for status of deficient plant conditions.
b.
Administrative ccatrols have been improved as follows:
- 1) Operations group administrative procedures have been reviewed and revised as necessary.
- 2) Procedures were approved to implement SIMS. As a result, Condition Identifications can be initiated or queried for status from approximately 130 terminals on-site, which includes key manage-ment and supervisor work areas.
f
- 3) The following sections have been added to and are regularly updated on management schedules:
a) Action Required Equipment Out-of-Service Schedule b) Quality-Related Equipment Out-of-Service Schedule c) Forced Outage List d) Temporary Alterations
- 10 NS20745
- 4) The weekly schedule is receiving increased management attention at Waterford 3 to ensure proper priorities are established.
Procedure OP-10-001, General Operating Procedure, has been changed to c.
require a review of valve tagging along with periodic valve alignment checks.
In addition to the above actions, the Plant Improvement Program with its area accountability assignment (see Item 1 of Section C, Maintenance) further assists the operations staff in the identification and correction of deficient plant conditions.
4.
Operations Procedures and Documentation l
The Waterford 3 Operations Group is continuing to review and revise operat-ing procedures.
Guidelines for these revisions are delineated in the "Operations Writers Guide" which was developed based on human factors input by an industry expert (see Section I, Item 2 for further information).
Selected procedures have been chosen foc revision based on their importance in the upcoming refueling outage (e.g., OP-10-001, General Plant Opera-tions; OP-1-003, RCS Drain Down; OP-9-005, Shutdown Cooling; and OP-901-046, Loss of Shutdown Cooling).
In the future, operating procedures will receive a human factors and technical review during the normal biennial review process.
The Waterford 3 simulator was placed in service in 1987. Operator Team Training combined with Training Department feedback have resulted in significant improvements in soma operating procedures.
5.
Annunciator Reduction Program The annunciator reduction program implemented at Waterford 3 was incorpor-ated primarily to improve operating efficiency and reduce personnel errors by providing reliable and precise annunciation of potential problems. The goal of this program is to achieve a "black board" control room. Although achieving this goal is ambitious due to annunciations that are inherent to normal plant operation (i.e., transients), setting such a goal will elimi-nate erroneous, misleading, o-unnecessary annunciations.
A maintenance engineer has been assignec the lead responsibility for this program, which, it present, involves the following:
Coordinating the implementation of work tasks involved in trouble-a.
shooting and correcting alarm concerns.
b.
Providing technical assistance for all annunciator related jobs, tasks, or investigations.
Monitoring alarms for trends and providing steps needed to implement c.
corrective actions if such are needed, d.
Providing status reports on a regular basis.
Initiating action when a station modification is needed.
- e. NS20745
O f.
Communicating closely with Operations personnel to uncover annunciator concerns and monitoring their "Annunciator Status Log Book".
Marked improvements have been made since the implementation of this pro-The total number of annunciator problems has been reduced from 67 gram.
on February 19, 1987 to 41 on February 10, 1988, a 39% reduction. The number of annunciators taken out of service has been decreased from 42 to 20, a 50% reduction. The number of unidentified and/or transient annunci-ators has dropped from 15 to an average of 11 (a 27% reduction). Of the 41 remaining problens, 11 are scheduled for the April 1988 refueling outage, corrective action for which will reduce the present total count by more than 25%.
6.
Temporary Alteration Requests (TARS)
Minimizing the number of temporary plant modifications has been an ongoing task and is proving to be successful. During critical operation in 1987 as many as 42 TARS were in effect.
As of February 26, 1988, there are a total of 15 active TARS.
One TAR is c:heduled for completion during March 1988.
Another TAR has an estimated completion by the end of 1988. The balance of 13 TARS are scheduled for resolution during the 2nd refueling outage.
7.
Spurious Actuations of Control Room Ventilation System a.
Chlorine Detection System The installation of new and improved detectors in the chlorine detection systen represented substantial pregress in improving the reliability of the control room ventilation system. During 1987 there were no spurious actuations due to the chlorine detection system.
b.
Broad Range Toxie Gas Detection System (BRTGDS)
Waterford 3 is located in the vicinity of chemical plants and also within proximity of industrial transportation corridors. Accordingly, LP&L has taken every ptodent measure to assure that the Waterford 3 Control Room Operators are protected and are able to maintain control of the plant in the event of a toxic chemical release.
21, 1987, the NRC issued a Safety Evaluation Report (SER)
On July and Technical Specification (TS) governing operation of the Broad Range Toxic Gas Detection System (BRTGDS). The NRC's approval repre-sented the closure of a longterm regulatory issae for Waterford 3.
The NRC requirement and LP&L's initiative for an operable BRTGDS represented technical and regulatory challenges. The system initially installed proved unreliable. A different replacement system was installed but required design modifications. Further, LP&L was required, without benefit of any historical or predictive performance data for this state-of-the-art technology and pursuant to an NRC license condition for Waterford 3 to propose a TS for the system prior to the startup following the first refueling. This posed another NS20745
I l
challenge because, typically, TSs for such a system require a numerical value for the alarm and actuation setpoint - information which is generally derived from performance and historical operating data.
On the basis of technical, regulatory, and operational justifications, LP&L proposed a TS based on a system performance objective - the lowest achievable gas concentration level of detectable toxic gases providing reliable operation. This approach was accepted by the NRC, and LP&L was able to perform a 6-month background measurement testing program to establish an optimum setpoint based on operating experience.
The NRC was formally apprised, on July 21, 1987 of the successful completion of testing for the BRTGDS setpoint and the completion of other support activities (maintenance calibration procedures, techni-cian training, and the availability of spare parts). Since LP&L had kept the NRC apprised of the operational status of the system, and the NRC had completed its technical review, the technical specification and the SER were approved by the NRC that same day - a demonstrated effort of teamwork, perseverance, and creativity on a dif ficult regulatory and safety issue.
8.
Utilization of Shift Technical Advisors (STAS)
Waterford 3 management has taken action to remove the administrative burden on the Shift Technical Advisors (STAS) so that they can concentrate on the duties and responsibilitf's outlined in the Technical Specifications.
These actions include issuance of a Nuclear Operations Executive Directive (ED-28) which, in part, presents the established LP&L policy concerning the duties of the STA. This directive states that the STA is to have no specific operational duties which could preclude him from assessing overall nuclear safety during an emergency condition.
Consister.t with this policy, a revision to Administrative Procedure UNT-7-Oll, "Duties and Responsibili-ties of the Shift Technical Advisor", was issued and specifically points out that the STA's primary duties involve accident assessment. The STA is not to be assigned routine duties which divert him from his primary func-tion.
In addition, the STA has been removed from the administrative process of the temporary alteration request system.
Waterford 3 is continuing the effort to obtain seafor reactor operator licenses for Shif t Technical Advisors (STAS).
At this time, there are six certified STAS at Waterford 3, two of which are licensed and one that is in the current license class.
9.
Human Error Reduction Program During the latter part of 1987, Waterford 3 conducted a review of plant practices and industry initiatives aimed at reducing the f requency and impact of human errors. Although certain elements of an effective program were in place, they were not well integrated and were not utilizing state of the art methodologies. Consequently, the Vice President-Nuclear direc-ted implementation of a Human Error Reduction Program with the following key components: NS20745
l a.
Dedicated personnel trained in state of the art root cause determina-tion methodologies.
b.
Meaningful event and root cause trending based on the above methodolo-
- gies, A clearly defined and c9nsistently applied disciplinary policy.
c.
d.
Provision for e noring that internal and regulatory commitments are reasondle, properly i:aplemented, and promptly closed.
l As an outg.rowth cf (dis prcgram, the Event Analysis and Reporting organiza-tion was upgraded to report to t'ae Plant Manager.
It was expanded in size and responsibilite; to include the functions of root cause evaluation and trending, co3)liance end vartaus ireporting responsibilities such as 10CFR21, in addition to their previous 10CFR50.72/73 responsibilities. The new Event Anal sis Reporting snd Response group is currently in an organi-7 l
zatic', pharg. Once the group 2s fully functional it is expected, in l
conjustica with tha overall Human Erro Reductien Program, to have a signii, ant iupect in reducing the frequency of personnel errorc, and is also expected to provida other benefits sut'h as tmproving the NRC Regional intert.sce as disc M ed in the followir; section.
10.
Deparation, Tracking and_Clasure of Region {V and I&E lssues To en..ance. preparation, tracking, and closure of regulatory compliance issues, tha Vice Vresident-pudthe directed that the following actions be taken during the IW 2r part of 1187:
the Event Analyiis and Reporttag (EA&R) unit supervisor provides a a.
briefing tor the ResMent Inspectors following significant events at Waterford 3.
b-Ths EA&R supervbor provides a briefing to the Resident Inspectors on Potentially Reportebb Events and Licensee Event Reports periodically during the review and dotecerJ.ation process.
c.
Key plant personnel provide the Resident Ipspectors with regular l
briefings on theia & partmental activitias as well as discussing potentially signi(? cant eventa or condit. ions.
l The Plant Manager his also renewted ef fort,, to discuss events / issues with I
the Resident Inspect +rs and to cowaunicate mort frequently with Regional Management.
l Long-term improvt.arnt erforts tnat LP&L is taking in t?.is area involve
[
organizational changes that are aimed at strelgthening tha NT4 i nte r t we.
Two major organizattonal Loves were adc la t'.h a re.0:
The Nuclear Saf aty i Regulatory Aff aira (NS&RA) r>epartment has beer; a.
separated from duelear ritrvices and wil r ; ort diritcly to the benior Vice President-Nuclear Operaticris.
Res' r ct uriny, to elevate HS&RA to the group level will ptovide increased empbisis or-the NRC interface (
NS20745 i
n
p I
and safety review functions. The direct reporting relationship will allow for additional Licensing input into major technical and policy decisions being made at the senior manager level, b.
The Event Analysis and Reporting organization formed early in 1987 has proven successful in increasing the quality and scope of event reviews.
Experience to date has indicated a need to add staff to this organiza-tion due to the workload. In doing so, it was decided to also central-ize trending activities and plant staff compliance efforts into this organization, as well as to elevate the reporting level. The new organization, entitled Event Analysis Reporting & Response, now reports to the Plant Manager. The newly structured organization is expected to bring the related areas of event analysis, reporting, trending, and NRC Resident Inspector interfacing into sharper focus and improve the communication process.
During 1987 the Operational Licensing and Regulatory Compliance Units coordinated the closure of approximately 73% of the 92 Inspection Report (IR) items that were addressed to LP&L.
The Operational Licensing Unit and the Regulatory Compliance Unit of
(
Nuclear Safety & Regulstory Affairs served as the focal points for coordin-ating and tracking, respectively, the response / closure of I&E items. The Regulatory Compliance Unit utilized a computer system to assist in the tracking and closure of IR/I&E items. This system also provided the Operational Licensing Unit with a centralized bank of information that the unit could use to coordin.:te/ assist in the development of responses to IR and I&E items. As the Event Analysis Reporting & Response organization is staffed up during 1988, it will become the focal point for providing all information necessary for closing Region IV open items.
- 11. Practice of Transferring Experienced Licer. sed Operators to Training Department Continues The Vice President-Nuclear and Plant Manager have emphasized a policy of providing experienced licensed operato;s to the Training Department.
Transfers take place based on needs in the Training Departnerit consistent with the completion of licensing of new R0s and SR0s.
Currently, six SR0s and two R0s that were former Operations Department Control Room personnel are siembers of the Training Department's simulator and classroom instruc-tion staff.
- 12. Efforts to Reduce Airborne Radioactivity.n Reactor Auxiliary Building Reduction of short-lived airborne radioactivity in the Reactor Auxiliary Building has been a management priority that has translated into an aggres-sive attitude toward leak reduction. Extensive efforts have been made in previour outages to repair / replace valves, fittings and flanges. Leak reduction will continue to be one of the main objectives of future outages.
Identificction and timely correction of leaks during plant operation is also stressed. A discussion of leak reduction activities may be found in the Radiological Controls section of this report (section B).
, NS20745
~
I
}
In plant levels of airborne radioactivity are not recorded and, therefore, reduction of airborne radioactivity cannot be directly verified. However, a comparison of Semiannual Radioactive Effluent Release Reports indicates that the total quantity of fission and activation products released in 1987 was approximately half that released in 1986, indirectly demonstrating that efforts to reduce in plant airborne radioactivity have been successful.
The most significant single factor in reducing in-plant airborce radio-activity appears to be repairs made to the Gaseous Waste Management Syste:n during the first refueling outage. Valves were replaced, certain piping rerouted and, in general, leaks reduced so that the system can effectively contain gases collected for decay prior to release.
Progress has also been made in identifying sources of airborne radioactiv-ity.
Improvements in gaseous leak detection methods have improved the capability to detect smaller leaks, while improved operation of the area-wide radiation monitoring system has enabled plant staff to identify trends in increased radiation levels and to correlate the increases with particu-lar activities which release airborne contaminants such as collecting reactor coolant system samples.
13.
Part-Loop Operation At the direction of Waterford 3 management, and in conjunction with Generic Letter 87-12, a multi-disciplinary task force conducted a review of plant operations during partially drained RCS conditions.
This review resulted f
in significant improvements to the operating procedures necessary to drain the RCS and maintain level at the hot leg mid plane.
Improvements were also implemented to increase operator capability and flexibility in dealing l
with a plant upset during a partially drained condition.
Changes ranged from a minor study to confirm RCS draindown levels for various maintenance activities to the planned installation of control room RCS level indication during the April 1988 refueling outage.
Of primary concern during the task force review was the capability of the Waterford 3 design to respond to a limiting loss of shutdown cooling event.
In this regard, the task force was guided by the event postulated in Generic Letter 87-12 involving an opening in the RCS during mid-loop operation. Analyses by both Waterford 3 and the CE Owners Group confirmed l
the capability of the plant to successfully mitigate the limiting event and led to firmer administrative controls regarding HPSI pump operability, maintaining steam generator level and a secondary side steaming path.
14.
Correction of Discrepancies As System Lineups Are Performed j
Operations has developed guidelines for system walkdowns. As part of I
procedure OP-10-001, General Plant Operations, operations personnel peri-odically perform alignment checks on systems while at power. During the walkdowns, operators ensure tags are attached and accurate, system lineups match P& ids and plant procedures, and that housekeeping / cleanliness is adequate. The walkdowns identify problems which may exist with procedures, drawings, and system configuration. Once identified, problems are corrected. US20745 f
f I
15.
Station Modifications to Reduce Trips To reduce the number of reactor trips at Waterford 3. LP&L established a Reactor Trip / Root Cause Determination Program. As part of this effort several modifications vere made or will shortly be implemented at Waterford 3 which include the followingt A Station Modification has been issued to reduce the frequency of feed-a.
water pump trips due to High Drain Tank Level.
b.
Control room indication and bypass control have been added to the Condensate Polishing System.
A new vibration monitoring system has been installed on the Turbine c.
Generator.
d.
A Steam Generator High Level Bypass switch was added to prevent reactor trips at low power levels.
A new Main Steam Isolation Valve Skid was installed which should help e.
eliminate transients and trips resulting from spurious operation /
failures.
16.
100% Operator Retention - Incentive Program Considering educational background, experience level and invested training, nuclear power plant operators are key assets at Waterford 3.
In recogni-tion of their value and to retain trained operators at Waterford 3, a plant operator Incentive Program, based on added compensation, was formulated in 1984. During 1987, the third full year of the program, 100 percent success was achieved. There have been no licensed operator losses due to resigna-tion since 1985. The Incentive Program has been revised and reinstituted for another three year period through 1990.
l WS30745
)
LOUISIANA POWER & LIGHT C0riPANY WATEPIORD 3 SALP PROGRESS REPORT Performance Functional Area B.
RADIOLOGICAL CONTROLS 1986 SALP Category: 2 1985 SALP Category: 2 Summary of NRC Recommended Licensee Actions 1.
Ensure appropriate action to reduce radioactive leakage from liquid and gaseous system to an acceptable level.
2.
Ensure first-line health physics supervisors spend adequate time in the plant overseeing radiation protection work activities.
3.
Ensure that stability is maintained with health physics professional staff.
4.
Evaluate benefits of a permanent low-level radioactive waste storage
'scility.
Current Status LP&L coatinues to make significant improvements in the area of Radiological Controls as exemplified by the following:
1.
Occupational Radiation Safety Planning for Next Refueling Outage Since the beginning of the year, contract personnel have been added to augment the permanent radiation protection staff. Additional planners, radiation protection project coordinators and supervisors, dosimetry, ALARA and operational health physics technicians have been phased in both to assist in outage planning and to receive appropriate training prior to the outage.
Planning efforts include reviewing scheduled outage activities to develop radiation work permits, estimacing exposures (person-rem) and setting exposure goals, and procuring the supplies (both consumables and hardware) necessary to support the outage activities. The Health Physict Department is also assisting in mock-up training of craft personnel.
2.
Improvements Regarding Better Control of Contaminated Workers Leaving the Site To improve control of contaminated workers leaving the site, a number of procedural and hardware changes were made, as well as strengthening en-forcement of existing procedures. Workers exiting the Radiation Controlled Area (RCA) who alarm the Personnel Contamination Monitor (PCM-1) are observed by Health Physics personnel as they perform the whole body frisk. NS20745
h Personnel are not allowed to leave the RCA without being cleared by Health Physics. The procedure addressing release of items from the RCA has been made more specific regarding what can be released. Modifications to the portal monitors at the Primary Access Point (and associated procedures) ensure that proper monitoring of exiting personnel o u urs during power interruptions. Also, the incident in which a contaminated worker was able to leave the site has been discussed with all personnel who work inside the Protected Area to minimize the potential for recurrence.
3.
Actions Taken to Reduce Radioactive Leakage from Liquid and Gaseous Systems The continuing plant inspection / area walkdown program (Plant Improvement List), in conjunction with the improved work control system, has provided Waterford 3 plant management with added assurance that fluid leaks are identified and corrected in a timely manner. Area walkdowns have been scheduled through the end of June 1988. An ownership approach has been implemented where supervisory personnel have been assigned as Area Coordi-nators for all areas in the plant. The responsibility of each Area Coordi-nator is to identify and correct deficient plant conditions in their respective areas. Management representatives have also been designated to provide additional support to the Area Coordinators.
In addition to this increased management attention, specific maintenance-related actions include coordinating outages of safety-related systems with the Operations Department to repair leaks during plant operation, when possible, rather than waiting until plant outages; tracking repairs on leaking components to identify chronic problems for part replacement rather than continued repair; utilizing improved materials and/or methods when repairing or replacing valve packing and flange constituents; and providing insnediate response when notified of the necessity for adjustments to valve packing. There is also a program in place to repack all valves in the plant over the next few years. Approximately 600 valves were repacked during the first refueling outage and another 1000 are targeted for repack-ing during the upcoming outage.
Additional information on the reduction of airborne radioactivity in the Reactor Auxiliary Building is contained in Section A, Plant Operations, Item 11.
4.
Health Physics Improvements In May 1987, Radiation Protection group staffing was increased by the addition of two senior positions in the technical support area. The number of first line supervisor positions was also increased from two to four in order to enhance the observation of workers, correct poor radiological work practices, and to provide 24-hour LP&L supervision during outages. The new positions were filled with experienced candidates who were tasked to assess current deficiencies and recommend action plans and priorities for correc-tive actions to plant management. The resulting action plan reflected the extensive experience of the new supervisors. With the increased staffing, there is more direct supervisory oversight of the radiation protection program, providing additional manpower and expertise to implement and ensure adherence to programs and procedures.
In addition to the Radiation Protection Group, the Nuclear Operations Support and Assessment Group NS20745
_N
surveillances, Quality Assurance surveillances and the Management Observa-l tion Program have resulted in an increased frequency of observations of L
both worker and Health Physics technician perforisance.
Health Physics technicians have been instructed in the methods and tech-(
niques of worker observation and provided with a checklist to enable them to better identify and correct poor radiological work practices. This is now included in the cyclic training program for Health Physics technicians.
Plant Staff supervisors have received training in observation techniques in the Safety Training Observation Program.
In addition, Plant Staff super-visors have been provided a copy of the Health Physics checklist regarding radiological work practices to use in briefing their crews.
The revised Radiation Work Permit format and procedure were implemented in June 1987. Since that time, the procedure has been reviewed and revised to f
correct human factor deficiencies, and is currently in the formal review and approval process.
(
A new procedure, "Radiological Deficiencies", has replaced the Radiological Occurrence Report and Radiological Infraction Report Programs. This procedure strengthens the previous programs by addressing root causes and stressing personnel accountability.
5.
Low-Level Waste Storage At the present time, LP&L does not find a permanent on-site low-level radioactive waste storage facility necessary. Waste is not anticipated to routinely remain on site more than a few months prior to shipment offsite for disposal. The need for a storage facility is monitored on an ongoing basis, and as long as waste can be shipped offsite, LP&L does not antici-pate having an on-site facility. However, LP&L has had a facility designed, and can have it constructed within 18 months, should conditions warrant.
6.
Central Interstate Compact In response to a federal mandate, the states of Arkansas, Kansas, Louisi-ana, Nebraska, and Oklahoma negotiated the Central Interstate Low-Level l
Radioactive Waste Compact. To ensure compliance with the federal mandates, the Compact created a commission composed of one voting member from each state. The Commission is tasked with establishing the framework for a cooperative effort between the member states in order to promote and develop a low-level radioactive waste disposal facility within the region.
The development of a regional disposal facility has proved to be a long and difficult process.
Early on, Louisiana Power & Light recognized the need for waste generator l
involvement in the development of a regional disposal facility, and a decision was made to devote manpower and resources to this effort.
Ini-tially, LP&L followed the progress of the Compact Comission in the early stages of site development and the commissioning of an engineering group to perform a site suitability study in the Central States region.
In 1984, LP&L, in conjunction with Arkansas Power & Light and Middle South Services, NS20745
(
organized the Central Interstate Regional Association for Low-Level Radio-active Waste Management. This group, consisting of institutional, indus-trial and nuclear power waste generators, functioned to provide information and support to the Compact Commission. LP&L was appointed to represent the Louisiana Waste Generators on the Louisiana Advisory Committee.
LP&L continued its leadership role during the site developer and the host state selection processes, and was instrumental in the formation of the Major Generators Group. As Technical Representative for this group, LP&L worked directly with the Compact Commission during the contract negotia-tions between the Compact and the selected developer, U.S. Ecology.
In this capacity, LP&L was responsible for coordinating technical input and financial expertise from the generators to the Compact negotiators.
The disposal site development process has steadily progressed in a positive direction while ensuring the public's concerns for health, safety and economy are adequately addressed. On December 15, 1987, in a meeting held in New Orleans, the Compact Commission selected Nebraska as the host state for the siting area. Additionally, with the submittal of the disposal site development plan to the Department of Energy and Nebraska's acceptance of the host state's responsibilities, the Compact has achieved the January 1, 1988 milestone established by the Waste Policy Act.
The Compact still must select the proper location, complete design of the facility, and license and construct the facility to meet our final goal.
7.
ALARA Program Strengthening of the ALARA Program has occurred by designating the Water-ford 3 Plant Manager as chairman of the ALARA Committee (this committee reviews plant conditions and personnel suggestions and makes recommenda-tions for maintaining exposures ALARA). Waterford 3, with its 138 person-rem exposure for 1987, is placed in the top quartile of person-rem exposures for the U.S. commercial nuclear industry.
8.
Contaminated Area Reduction Significant successful efforts have been made in reducing the total square feet of contaminated area in the RCA at Waterford 3.
These efforts (repairing leaks, surface decontamination and painting) have reduced the total previous RCA surface contamination from 22,800 square feet to 5,100 square feet, which is less than 5% of the total RCA outside the Reactor Containment Building. NS20745
I
(
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area C.
MAINTENANCE 1986 SALP Category:
2 1985 SALP Category: 3 Summary of NRC Recommended Licensee Actions 1.
Licensee management should work toward reduction of the outstanding routine maintenance backlog and implementation of programs such as SIMS.
[
2.
Initiatives to improve the containment working environment should be I
considered.
Current Status Many maintenance improvement initiatives and other related activities occurred in 1987, which include the following:
1.
Continued Management Involvement Management and operations walkdowns have continued with additional emphasis placed on identifying and tagging equipment deficiencies and correcting them in a timely manner.
The continuing plant inspection / area walkdown program (Plant Improvement List), in conjunction with the improved work control system, has provided Waterford 3 plant management with added assurance that plant problems such as fluid leaks are identified and corrected in a timely manner. Area walkdowns have been scheduled through the end of June, 1988.
As discussed more fully in Section A Plant Operations, Item 1, Area Coordinators have been assigned for plant areas to maintain management oversight and instill a continuing sense of ownership.
2.
Planning, Scheduling, and Backlog Management The ongoing efforts of the Condition Identification and Work Authorization l
Review Committee and implementation of the Station Information Management System (SIMS), during 1987, significantly improved the abilities of the staff to plan, schedule, and close work items.
The procedure for prioritization, scheduling, and closcout of work tasks was reviewed and revised to provide additional guidance for effective priority control.
Provisions for adjusting work task priority as task importance changes are included in the process. The effectiveness of work scheduling and prioritization will be periodically evaluated. NS20745
1' The Condition Identification / Work Authorization (CIWA) backlog was exten-sively reviewed twice since July 1987. The efforts of the CIWA Review Committee changed the priority of or closed out over 1000 CIWAs.
SIMS implementation and priority work control have been aided by the development and/or revision of the following procedures:
UNT-5-002 Condition Identification UNT-5-015 Work Authorization, Preparation and Implementation PLG-9-007 Routine Scheduling of Station Activities MD-1-026 Maintenance Department Work Center Planning
(
In addition, an Integrated Planning / Implementation Scheduling data base has been developed for use in conjunction with SIMS scheduling. Schedule reviews are conducted by the Maintenance Superintendent to review justifi-
[
cations for schedule changes in order to enforce schedule accountability in I
the line organizations. The benefits of the integrated planning /implemen-tation scheduling data base and usage of the SIMS continue to accrue; however, the full potential of the capabilities added to date will not be realized until sufficient historical data and experience is acquired.
3.
Temporary Plant Alteration Control Continuing audits by Control Room personnel, supervised by Plant Manage-ment, provide assurance that Temporary Alterations are identified accur-ately to Operations Department personnel.
Technical reviews are now an integral part of the Temporary Alteration Program.
4.
Program Revisions Some major Maintenance-related programs were revised as follows:
Modification Projects - December, 1987 NOP-014, Design Changes is a new procedure establishing new defini-tions, responsibilities and improved work flow.
Trending - November, 1987 MD-01-016, Failure and Trend Analysis was revised to provide more direction in this area and to become better integrated with other departments which utilize trending and failure data to analyze piant problems and recommend enhancements or corrective action.
Independent Verification - December 1987 MD-01-025, Independent Verification Progran was written to enhance the guidance provided to maintenance personnel.
Materials Procurement and Management - November 1987 Materials Management Information System (MMIS) implementation (see Item 8, below). NS20745
UNT-08-044, Requisition and Return of Items to Stores Revised to reflect the MMIS implementation (see Item 8, below).
Conduct of Maintenance - December 1987 MD-01-014, Conduct of Maintenance was revised after the Phase II reorganization (permanent staff implementation), SIMS and MMIS imple-mentation were completed.
The Maintenance Advisory Group was chartered in August to provide recom-l mendations/ resolutions to management for innovations, improvements, I
reduction of personnel errors, incorporation of "lessons learned" and provisions for long tera corrective actions.
l Repetitive Task Reduction - Maintenance Engineering evaluations of cur-rently identified tasks were initiated to determine tasks that could be eliminated or for which the frequency of performance could be reduced.
(
This effort resulted in a 24% reduction in repetitive tasks by the end of 1987.
Individual Training Plans have been developed for maintenance technicians in the Maintenance organization identifying specific training requirements for 1988.
5.
Station Information Manasement System (SIMS)
On July 21, 1987, SIMS became operational, ahead of schedule. SIMS is a system which is used by all groups in Nuclear Operations to enhance the total operation of Waterford 3.
Briefly described, SIMS is a cross-discipline computerized program which is utilized in the total processing - from initiation through approval and monitoring to closure - of corrective and preventive maintenance, surveil-lance tasks, inservice inspections, station modifications, and commitments.
There are approximately 130 display stations throughout the site which communicate through modems and controllers with the mainframe located at the Middle South Utilities Computer Center. SIMS provides rapid recall of design engineering, maintenance engineering, and historical data for 61,000 plant components.
To facilitate usage, general and specific training of site personnel has been successfully conducted, allowing the component data base to be used in the first refueling outage. With the information stored in it, SIMS will help the planner develop better work packages; the system engineer to perform timely and accurate analysis of equipment failures; the design engineer to develop better design packages; and the sebedulers to better define system and subsystem outages.
6.
Maintenance Backlos Corrective maintenance items accounted for 5,910 completed activities (38.1%) of the total of 15,522 documented maintenance work activities completed ir 1987. NS20745
In February 1987, the Maintenance Review Committee (MRC) was formed to review a backlog of open Condition Identification Work Authorizations.
L (This committee was also known as the Condition Identification and Work Authorization Review Comiittee - see Item 2, above.) The MRC net weekly and tracked actions required to close Work Authorirations greater than 3 l
months old. Because of the implementation of the previously mentioned programmatic improvements in planning, scheduling, and backlog management, the MRC now meets monthly and reviews Work Authorizations greater than 3
{
months old that are in work preparation or on hold. Actions of the MRC and the implementation of planned maintenance of a routine nature have been instrumental in reducing the backlog of corrective maintenance items. The corrective maintenance backlog was reduced from 685 items in December 1986, to 572 items in December 1987.
Since the beginning of this SALP period, the Preventive Maintenance backlog
(
bas been reduced from over 1000 tasks to less than 365.
Currently, the majority of the preventive maintenance backlog items are past due instru-ment calibrations. Additional contract technicians have been brought on
[
board to assist in reducing the backlog. Maintenance Engineering is also reviewing backlogged preventive maintenance tasks to determine if the tasks i
must be worked now or if they can be rescheduled at a latter date with no significant detrimental effects on the plant. This evaluation technique has been incorporated as a routine part of the backlog dispositioning process and has been included in procedure UNT-5-012 "Repetitive Task Identification".
The total number of repetitive maintenance tasks was significantly reduced in 1987 by 4,991 tasks from 20,700 in January to 15,709 in November, a 24%
decrease.
{
7.
Containment Working Environment Improvements Station Modification (SM-1960), Reactor Containment Building Air Con-ditioning, is to be installed for the 1988 Refueling Outage. This mod-ification involves adding branch lines and isolation valves to the existing component cooling water supply and return lines such that chilled water can be supplied to the Containment Fan Coolers during outages to maintain a more desirable temperature inside containment. Temporary chillers will be used to provide chilled water to the fans in the near term until the final installation is completed.
8.
Materials Management Information System (MMIS)
The implementation of the Material Management Information System (MMIS) was formally accomplished during December 1987.
In the late 1970's, by mutual agreeme.nt of the three MSS operating compa-nies, AP&L, MP&L, and LP&L, with support f rom System Services Incorporated, the project was initiated to replace existing materials and stores systems.
These companies banded together and designed the basic MMIS.
By the fall of 1980, the specification for the system had been developed and a batch processing software system had been purchased. Subsequently, an on-line version of the system was obtained and the package was converted to an NS20745
l information management system. A concentrated effort by all of the com-panies ensued over the next 4 years with activities ranging from data input / cleanup to system familiarization, testing and debugging. Approxi-mately 70,000 material items are included in MMIS.
(
As the KMIS's were brought on-line in both fossil and nuclear operations within the various companies, acquired knowledge was shared throughout the system. These communication efforts allowed those who had not completed implementation to further refine their MMIS's to facilitate usage.
MMIS will automate and streamline the procurement and material functions and will substantially enhance the information control of material fune-tions.
The Waterford 3 MMIS accommodates the on-line material transactions in the areas of planned material requirements, procurement, purchasing, invoicing, accounting, receipt / inspection, and issues / returns. MMIS is capable of recommending what to buy, when to buy, and how much to buy.
From planned maintenance and construction jobs and from stores issues, the system generates purchase requisitions and purchase orders based upon procurement lead times. Material is received at the warehouse, and, for quality items, the results of receipt inspections are recorded within the system.
From strategically placed terminals located throughout the plant, MMIS information can be accessed by both authorized users and by the general Nuclear Operations populace.
The organizations most affected by MMIS are Purchasing, Stores, and Accounts Payable. Their methods and procedures were revised and their activities more closely integrated. Their input of data to MMIS will provide timely status information on all material items. The significant benefits of MMIS are:
Providing automatic notification of the need for recurring stock.
Providing lists of qualified vendors and manufacturers and previous purchase order history.
Monitoring vendor performance and generating vendor performance reports.
Automating manual functions.
Providing an up-to-date inventory status.
Providing storeroom location and inspection requirements.
Automating the matching of purch sse orders, Receiving Reports, and invoices and creating exception notices.
Providing timely and accurate information on total purchase order comm* ients and unpaid balances. NS20745
l l
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area D.
Surveillance 1986 SALP Category:
1 1985 SALP Category: 2 Summary of NRC Recommended Licensee Actions 1.
The licensee should continue to pursue procedural as well as equipment
(
changes needed to eliminate nonroutine surveillance problems.
2.
Evaluate the long-term reliability of the Boron Management / Blowdown System radiation monitoring equipment.
3.
Placement of the new hydrogen /orygen analyzing system into routine opera-tional service.
Current Status 1.
Radiation Monitoring Task Forces Waterford 3 has formed a task force to evaluate !!ailure history and trends on the radiation monitoring system and to provide recomraended solutions to recurring problems. The task force evaluation should be complete, with recommendations, by June 1988. Waterford 3 is also participating in a Middle South Utilities task force to assess problems with process radiation monitors at all of the MSU nuclear plants. The MSU task force will provide recommendations to the Middle South Nuclear Management Committee by July, 1988.
2.
Procedure Changes Procedure changes have been made to provide an independent review of non-routine surveillance results and also to confirm input data in SIMS to prevent rescheduling errors.
3.
Radiation Monitoring Equipment The radiation monitors in the Boric Acid Condensate Discharge and Steam Generator Blowdown Lines have proven to be unreliable. Waterford 3 manage-ment has concluded, therefore, that these monitors should be replaced with monitors with a proven reliability record. Similar monitors will also be replaced in the Gaseous Waste Management System and the Liquid Waste Management System. This modification is scheduled for implementation during the April 1988 refueling outage. NS20745
{
4.
Equipment Channes tc Eliminate Non-Routine Surveillance Problem Over the past two years several attempts have been made to repair the Waste Gas Holdup System Explosive Gas Monitoring System (hydrogen /orysen analyz-ins system). Each attempt has proven to be uns accessful. LP&L has, therefore, completely redesigned the system. The new design will allow automatic sampling of the Gas Decay Tanks. This will greatly reduce the number of nonroutine surveillances. Work on the station modification installing the new system has begun and is scheduled to be completed by June 30, 1988.
, NS30745
I LOUISIANA POWER f. LIGHT COMPAhT WATEPJORD 3 SALP PROGRESS REPORT Performance Functional Area E.
FIRE PkOTECTION 1986 SALP Category:
1 1985 SALP Category:
2
(
Sumary of NRC Recomended Licensee Actions f
Licensee management should continue to stress the reduction of the number of inoperable fire barriers and work toward the elimination of routine fire watches in areas containing safety-related equipment.
(
Current Status j
Tire protection activities since the last appraisal period have stressed I
good housekeeping to control trancient combustibles, reduction of fire barrier impairments and fire watches, and improvements in fire protection system operation.
A management goal was set to maintain fire barrier impairments during non-outage periods at 10 or less. This initiative has resulted in timely repair of impairments and a significant reduction in the amount of time spent conducting fire watches. Fire watch patrols have also been reduced as a result of a Technical Specification change in the criteria for fire watch patrols in the annulus. This change not only significantly reduced fire watch patrols and interruptions in the operation of the Annulus Negative Pressure System, but also provided ALARA and personnel safety benefits.
}
To further enhance operation and maintenance of annulus fire detection I
capability, the existing annulus fire detection system will be replaced during the April 1988 refueling outage with a detection system which will be accessible during all modes of operation. Much effort was expended evaluating annulus fire protection and developing the best alternative.
l The NRC was consultsd early in the design process so as to be assured that i
all concerns were addressed.
Consulta G a with the NRC on fire protection issues has occurred frequent-ly, as questions have arisen as to interpretation of fire protection requirements, particularly, whether certain instances may be handled under the evaluation criteria of Operating License Condition 2.C.9.c or require NRC notification.
. NS20745
t
[
t LP&L's goal to maintain the number of fire impairments at or below 10, j
except during outages, is a management priority, and is being largely met.
I The Fire Protection and Safety Group tracks the impairments and apprises plant management of the status, at least weekly. Should the number of impairments exceed the goal, management is immediately notified, the individual impairments are evaluated for closure, and the status is reported on a daily basis until returning to the target level.
I l
- NS20745
v k
LOUISIANA POWER & LICHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area F.
EMERGENCY PREPAREDNESS 1986 SALP Category:
2 1985 SALP Category:
2 Summary of NRC Recommended Licensee Actions 1.
Upper management attention to resolving NRC identified items in inspections and exercises should be increased.
f 2.
Management should evaluate emergency preparedness training programs for all emergency response personnel.
f Current Status LP&L management goes to great efforts to ensure proper response to NRC identified items. Such items are revieved by both the Emergency Planning Department and the affected discipline (i.e., Heelth Physics, Training, etc.).
Items are then reviewed by Licensing and receive the appropriate management reviews prior to final approval of a course of action to resolve
(
the item, and submittal of the course of action to the NRC. NRC identified items are tracked both by the Licensing Commitments Management System and the Emergency Planning Action Item Tracking System to final resolution and determination of adequacy of the corrective action. For example, the NRC identified deficiency to improve command and control in the Emergency Operations Facility (EOF) from the 1986 Exercise was immediately acted upon by LP&L by adoption of a 3 part corrective action plan. This corrective action plan consisted of facility modifications, emergency response organ-ization changes and training emphasis on command and control. The success of LP&L's methods for ensuring proper response to NRC identified items was
(
exhibited by the closure c,f this deficiency by the NRC in the 1987 Exercise noting that command and control were improved by the LP&L changes that were made.
In regard to the still un.esolved item involving Technical Support Center (TSC) size, it should be noted that no action is being taken by LP&L to increase the size of the TSC.
LP&L feels that the current size is adequate f
and lends optimum efficiency to TSC activities.
It is anticipated that this topic will be closed at the NRC Emergency Response Facility Appraisal scheduled for October 1988.
LP&L management is continuously attuned to emergency preparedness training requirements and ensures that any problems encountered with these activi-ties are appropriately corrected. Upgrading of emergency preparedness j
training is an ongoing effort. Problems are identified by performance of emergency preparedness team participants during LP&L conducted drills and NS20745 1
)
f e
call-outs, NRC annual exercises, review and evaluation of the training program by LP&L Quality Assurance and LP&L management ani remilts of NRC inspections. The most recent NRC inspection involving emergency prepared-ness training at Waterford 3 occurred during the period December 14-18,
{
1987. The results of the inspection (Inspection Report 50-382/87-27, dated January 5,1988) indicate that personnel designated to the emergency organization had been provided with appropriate training.
1.
Emergency Planning Enhancements Some other significant areas / items of enhancement accomplished in the
(
Emergency Planning program during 1987 and 1988 to date are:
a.
The Alert Notification System has been approved by FEMA.
b.
LP&L recently awarded a contract for the implementation of a siren feedback and monitoring system.
c.
The Waterford 3 Simulator is now being used for the development and conduct of emergeccy preparedness drills.
d.
The Emergency Action Le' vel (EAL) Procedure is being revised to ensure accurate and prompt classification decision-making.
e.
Emergency response facility changes, emergency response organization changes and additicnal training have been implemented to improve command and control in the EOF.
f.
An independent review of exercise scenario packages has been implement-ed to ensure accuracy and consistency of scenario events and data.
g.
The use of duty rosters and pager activation has been implemented for the offsite emergency response organization (Corporate Command Center and Emergency News Center) to enhance response to an emergency.
h.
State and Parish Representatives now respond to the LP&L Emergency News Center to more effectively coordinate the release of information to the public.
- i. The Operational Support Center (OSC) has been expanded to enhance emergency operations.
J.
Seminars have been held for the EOF, TSC and OSC personnel to improve activation of these organizations.
k.
Additional health physics equipment has been provided in the OSC and TSC to improve habitability monitoring.
1.
A program consisting of periodic emergency first aid training will be established to enhance the response to medical emergencies.
The emergency plan training program has been epgraded to address the m.
NRC identified deficiencies from the 1987 Exercise. NS20745
s r
n.
Presentations were given at the December 1987 Safety Meetings held with L
plant personnel to emphasize the health physics concerns identified from the 1987 Exercise.
(
2.
Siren Feedback and Monitoring System LP&L recently awarded a contract for the implementation of a siren feedback
(
and monitoring system. This system is expected to be in place by June 1988
}
and allows LP&L in conjunction with St. Charles and St. John the Baptist Parishes to continually monitor critical siren system functions such as power and electronic component availability or unwanted intrusion. When
[
the sirens are sounded or tested, the monitoring and feedback system will provide a report within a few minutes on the status of the activation. The system will utilize computer generated mapping to give a visual display of
(
siren activation for a specific geographic region. The siren monitoring and feedbc'k system represents a significant upgrade to the Waterford 3 alert / notification system. Up to the time thit system is implemented, sirens in the system are tested at approximately two week intervals. The monitoring and feedback system is capable of providing an instantaneous report on siren problems. Sound and silent tests are presently verified by the technician visiting each of 62 siren sites to verify activation and
(
availability within the ten mile emergency planning zone. The new system allows monitoring from a central location. Finally, this system will give the risk parishes the capability of knowing the availability status of each
{
siren in the system prior to activation in an emergency.
This allows the parish time to dispatch alert teams to a siren site for manual siren activation or to conduct routine alerting so that no time is lost in alerting the public to the need for protective action.
3.
FEMA Alert / Notification System Test The FEMA 44 CFR 350 review process requires that a complete alert /notifica-tion system test be conducted with a survey of the public in the area around a nuclear power plant prior to final FEMA approval of offsite emergency plans. This test for Waterford 3 was conducted by FEMA represen-tatives on April 15, 1987. At that time, all elements of the alert /notifi-cation system were tested including fixed sirens, mobile sirens, industrial alerting methods, cable television override and Emergency Broadcast System f
messages. The helicopter alerting system was not included in this test, but it was tested by FEMA later in 1987.
The FEMA telephone survey following the test indicated that 91% of persons surve,ed were directly alerted by the test. This was the highest system rating for any nuclear plant in FEMA Region VI.
FEMA representatives tested the helicopter alerting component of the system in November 1987. This test included testing the sound propagation equip-ment used along with establishing the times needed to alert the remote areas within the 10 mile emergency planning zone. The FEMA evaluation indicated that the system sound propagation met or exceeded the standards established for this type of equipment.
In addition, the testing of the alert routes showed that all areas around the plant could be alerted within the times established in Federal guidance. NS20745
1 4.
Siren System Availability The Waterford 3 siren system is tested twice per month in accordance with Federal guidance. An audible test is conducted at the beginning of the month with a silent test performed at irid-month.
Information from the tests is recorded by LP&L siren maintenance personnel and test reports are shared with Parish and State officials. This information is then compiled and submitted to FEMA as part of annual certification of the siren system.
FEMA has established a formula for determining the rate of siren system availability based on a straight arithmetic average dividing sirens avail-able by the number of sirens tested For the past two years that the FEMA reporting requirements have been in place, Waterford 3 has maintained a very high rate of siren availability. The siren availability rate for calendar year 1986 was 99. $ For 1987 this rate was 98.9%.
5.
Waterford 3 Simulator Used for Emergency Preparedness Activities
(
In an effort to improve the Waterford 3 emergency preparedness drill program, the Waterford 3 simulator is now being used for the development and conduct of drills and exercises. The simulator was initially used for the 1st Quarter Site Drill.
It provided a more effective test of the operational response to an emergency.
Its use for the development of drill packages should allow for more realistic scenarios and improve the Operator response. The use of the simulator, and the independent scenario-review
(
that has been implemented, should also increase the accuracy of the data presented to the drill / exercise participants.
(
6.
EAL Procedure Revision The EAL procedure has received an intensive review by several Waterford 3 departments. The comments received by these groups are being incorporated into a major procedure revision. This revision should eliminate some previously identified inaccuracies and improve the emergency classification decision-making.
7.
Lessons Learned Seminars l
Seminars were held with emergency response personnel te address "lessons learned" from EOF and TSC/0SC callout drills. The seminars emphasized the importance of prompt activation of the facilities in an emergency situa-tion. As a result of these seminars, we are implementing a pager activa-tion program for the EOF personnel to improve response.
8.
Emergency First Aid Team Mini-Drills Beginning in December 1987, a series of mini-drills were conducted for the Emergency First Aid Team qualified personnel. The drills emphasized prompt medical care and the importance of obtaining assistance from offsite medical facilities. LP&L has initiated a program to provide this addi-tional training on a periodic basis to enhance the treatment of Waterford 3 injured personnel. NS20745
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT r
L Performance Functional Area G.
SECURITY AND SAFEGUARDS 1986 SALP Category:
2 1985 SALP Cctegory:
1 Summary of NRC Recommended Licensee Actions
(
1.
The licensee should continue to enhance the security training of non-security personnel in order to prevent recurrence of physical barrier violations.
2.
Licensee management should ensure the evaluation of the closed circuit television system is complete and appropriate modifications are made.
l Current Status Waterford 3 management continues to apply a high level of attention to the l
security program including the implementation of safeguards requirements, the selection and training of security personnel, the training of non-security personnel regarding the security program, the Fitness for Duty Program, and physical improvements to the security systems.
Waterford 3 management has long supported a drug awareness education program within Nuclear Operations. Our education efforts coupled with random drug testing have resulted in very low positive urinalysis findings.
Of 206 random urinalysis tests recently conducted (June 1987 to January 1988) less than 1%
had positive findings.
Some other significant areas / items of improvement accomplishi.d in the security program during 1987 and 1988 to date include:
1.
Changes within the Security Department:
a.
The perimeter detection system is being upgraded.
b.
The Security Computer System is being upgraded.
c.
The access control prcgram is being upgraded, d.
10CFR73.57 (Requiremen.s for criminal history checks of individuals granted unescorted access to a nuclear power facility or access to Safeguards Information by power reactor licensees) has been imple-mented.
e.
Contract Security Personnel are State certified. NS20745
f.
The Security Training Program is State certified.
g.
The Security Training Program has been upgraded to include a physical training complex for practicing contingency scenarios.
h.
Weapons training has been upgraded,
- i. Security equipment has been upgraded to include special weapons and an
{
increased number of response vehicles.
J.
Select Security personnel have received specialized training by offsite agencies.
k.
The assessment aides systems upgrade is in progress to enhance capa-bilities and replace some cameras.
1.
The attrition rate of Security Personnel was reduced from 20% in 1986 to 11% in 1987.
2.
Other areas of improvement:
l a.
The Behavioral Reliability Training Program has been updated to include l
drug and alcohol abuse, and in addition, the retraining of supervisory personnel was initiated.
t b.
There is now a plant administrative procedure on penetrating physical barriers.
c.
Additional information signs have been placed on potential access portals to vital areas to decrease the potential for vital area barrier violations.
d.
The General Employee Training (GET 1) has been updated to include physical barrier violation information.
e.
Verbal and written information has beta disseminated regarding the new Security reporting requirements, 10CFR73.71.
f.
There is a mandatory retraining class for personnel who violate security programs.
3.
Enhanced Training of Non-Security Personnel Much has been done to make onsite personnel more aware of their security responsibilities. Meetings were held with onsite Nuclear Operations Personnel to acquaint them with the new Security reporting requirements covered by 10CFR73.71 and Regulatory Guide 5.62.
Applicable procedures were updated to reflect the new guidelines. The Security portion of the General Employee Training class has been updated to cover the personal security responsibility of each individual. Personnel who have not com-plied with the Security program are required to attend a Security Retraining Class which includes the Security portion of the General Employee Training Class.
Personnel have been made more aware of the LP&L Drug and Alcohol Program by having the month of February designated Drug NS20745
and Alcohol Awareness Month, such that the monthly on-site Safety Meeting j
is on Drug and Alcohol Abuse.
The Behavioral Reliability Training Program has been updated to include drug and alcohol abuse. Security requirements are also outlined in the Outage Manual which is applicable to personnel granted unescorted access to the plant.
A plant administrative procedure has been developed on penetrating physical barriers (UNT-04-036, Security for Penetrating PA&VA Barriers). A further l
deterrent for accidental penetration of physical barriers is an increased number of information signs on potential access portals to vital areas.
Additionally, the GET 1 class has been updated to include physical barrier violation information.
4.
Enhancements to Closed Circuit Television System A station modification program is in progress that will greatly enhance the operation, performance, and reliability of the closed circuit television (CCTV) system. This project involves a complete revamp of the system, including replacement of major video equipment in the Central Alarm Station (CAS) and Secondary Alarm Station (SAS).
Relocation of exterior cameras will provide improved coverage of the committed areas as well as elimina-tion of undesirable obstacles.
Ine existing cameras will be replaced with a solid state type, providing improvements in ease of maintenance, reli-ability, and quality of video.
Replacement of video equipment in the CAS and SAS will provide expanded alarm assessment capabilities such as "pre-shot" positions for the pan-tilt-zoom cameras.
Completion is scheduled for the latter part of 1988. NS20745
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional rea L
H.
OUTAGES 1986 SALP Category:
1 1985 SALP Category: Not Assessed Summar3 of NRC Recommended Licensee Actions 1.
Licensee management should continue with aggressive involvement in outages.
2.
Some improvement could be made in scheduling of equipment testing /inspec-tion so that multiple equipment outages are avoided.
3.
Progress of the revision of the RWP procedures should be monitored so that the revised program is in place and functioning before the next scheduled outage.
Current Status 1.
Management Involvement and Control For many months prior to Refueling Outage No. 2, Waterford 3 Management has been concentrating on detailed planning and implementation of programs developed to ensure the outage is effective and efficient.
Past successful management control efforts are again being utilized for the upcoming outage. This includes the early creation of a matrixed Outage Preparation Organization with centralized responsibility and control which establishes the following:
a.
Refueling Preparation Manager, with normal reporting to the Plant Manager-Nuclear and direct reporting to the Vice President-Nuclear on all outage related matters. Direct reporting of the Refueling Prepara-tion Manager to the Vice President-Nuclear is key in the centralized refueling organization concept in that participation of all personnel, plant staff / site operations, is assured.
b.
Refueling Director - a dedicated Operations Engineer (SRO) to manage Refueling and all related containment work, operational and radiation protection services, c.
Use of key experienced personnel, enhanced by increased in-house staffing with the organizational authority and training to complete their assigned responsibilities.
d.
Outage Management organization implemented 6 months prior to the outage start. NS20745
e.
Establishment of a trained and experienced refueling / containment control staff.
Pre-outage activities have been identified. Non-outage activities to be performed during the outage period are included in the outage scope.
A Comprehensive Outage Network schedule has been used as the baseline model for integrating outage activities and monitoring scope adjustments.
Ongoing readiness reviews commenced nine sonths prior to the outage with active participation by Scheduling, Contracts, Operations, Maintenance, Radiation Protection and others to identify and resolve difficulties in preparation activities and to achieve integration of activities and services. Major outage activities have lead controllers assigned to manage readiness and successful implementation.
Regular overall status reviews with participation by all Nuclear Operations Departments commenced ten months prior to the outage for prcblem identifi-cation to management.
Control of outage planning was assisted by develop-meat of the Outage Preparation Milestone Schedule by the Preparation l
Manager and maintaining the plan based on emerging events to ensure orderly preparation direction.
Waterford 3 has reviewed and incorporated applicable Refuel No.1 Action Items (lessons learned) identified during the post-outage critiques, INPO and other good practice recommendations including those of the Middle South Nuclear Management Committee Outage Management Task force into the outagc plans. A key improvement was the development of a Refueling and Contain-ment Services Contract under direct LP&L management.
The outage facilities program ensures optimum use of site arear, and the timely erection and demobilization of temporary facilities and related s e rvices.
It incorporates security and fire protection approvals.
The Outage Manual provides a comprehensive tool to orient new and existing employees on our methods of conducting the outage. The final product of many outage preparation programs are presented. Other programs or plans developed for the outaga include training, personnel processing and badging, measuring and test equipment control, and tool control.
As discussed in Item 6 under Section J, Licensing Activities, the task of obtaining regulatory approvals necessary for the refueling outage and Cycle 3 was initiated well in advance of the outage.
2.
Scheduling Equipment Outages Over the past year several programs have been instituted to improve coor-dination between work groups and equipment outages which involve the following:
a.
The Station Information Management System (SIMS) was placed in opera-tion. SIMS will allow plant personnel to quickly review tasks.
In calling-up a particular task, the user can also note other tasks associated with that piece of equipment. This will allow work groups to better coordinate work activities. NS20745
b.
The Maintenance group is presently working to consolidate tasks.
In
(
the past, a task card was written for each task assigned to a particu-I lar component. Wherever possible, several tasks are being consolidated on one task card. This enhances plant personnel's ability to perform several tasks during a component outage.
c.
The scheduling system was improved by allowing long term system and component outage schedules to be developed and maintained.
d.
The scheduling format used by Maintenance Supervisors during normal operations will be used during the outage to enhance user understand-ing.
3.
Revisions to Radiation Work Permit Procedure Procedure HP-01-110, Radiation Work Permit, was completely revised. The changes included clarification of responsibilities, upgrading the mechanism used to do work in a Radiation Controlled Area and the use of new RWP forms. The procedure changes have been in place since March 1987; there-fore, plant personnel have had a year to familiarize themselves with the changes. This will ensure that problems will be minimized during the upcoming outage.
4.
Future Plans Waterford 3 continues to work at improving outage efficiency by making future plans to develop post-outage critiques and assign action items for improvement. These plans also include improved productivity monitoring by use of SIMS and cost-work order accountability.
e Ef NS20745
)
LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area I.
QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS AFFECTING QUALITY 1986 SALP Category: 2 1985 SALP Category: 2 Summary of NRC Recommended Licensee Actions 1.
Resolve the lingering problems associated with the plant computer system, 2.
Perform additional reviews of plant procedures to eliminate the practice of using informational notes as procedural requirements, 3.
Monitor the follow-up of the concerns identified in the NRC EQ Inspection to ensure continued compliance, and 4.
':anitor the station modification program so that centinued progress is made in reducing the number of outstanding station modifications in the review cycle.
Current Status Waterford 3 management recognizes the importance of plant programs and controls designed to ensure quality.
In November 1987, the procurement control process was significantly strength-ened through the implementation of a computerized Haterials Management Informa-tion System (MMIS). MMIS was developed as an enhancement to the existing Nuclear Spare Parts Inventory System which was only utilized for inventory con-trol.
In addition to the inventory control provision, MMIS can be utilized to generate / process purchase requisitions and orders and to acquire the applica-tion information or generic requirement for a particular part and its end use.
MMIS is discussed in more detail in Section C, Maintenance, Item 8.
The control of design changes has been enhanced to allow better coordination of the change process from initiation of a change to its closure. Nuclear Opera-tions Engineering Procedures have been developed and/or upgraded in efforts to refine each phase of the modification process.
Based on a high level of attention and a more refined scheduling system, significant progress has been made in closing station modifications.
The Operations and Maintenance Departments have developed comprehensive proce-dure writing guidelines in efforts to eliminate procedural deficiencies. These guidelines will be used to develop, revise or upgrade operating procedures which should aid in improving procedural compliance.
Significant improvements in operational procedures should also be realized through training on the Waterford 3 simulator which was placed in service in 1987. NS20745 l
)
The Waterford 3 equipment qualification program continues to be responsive to and in compliance with the applicable regulatory programs and require-j ments.
Other areas of improvement in this category include:
l 1.
Plant Monitoring Computer (PMC)
{
External problems which have resulted in PMC outages have been identified and corrections are being implemented. Problems such as the Static Unin-terruptible Power Supply and the Fixed Incore Detector signal cables are
[
being addressed by station modifications.
It is expected that these i
modifications will result in improved PMC reliability.
Other PMC reliability problems are being addressed by the computer engi-f neering staff. Areas such as operating system improvement, input relay cards and communication failures have been examined and corrective action is either in progress or planned. These improvement initiatives include:
a) A more reliable CPU 3 software operating system has been purchased and should be installed by August 1988.
b) A station modification has been written to replace the currently installed relay input cards with more reliable solid state cards. The changeout of these cards is expected to be complete by June 1988.
c) A station modification to install a hardware reset switch is in the planning stage.
It is expected that this reset ability will reduce PMC outages caused by a loss of communication between the multiplexers and PMC CPU 1.
Waterford 3 has also requested a technical specification change (NPF-38-68) which will minimize the impact of the loss of the PMC on plant operations (i.e., reduce the need for power reductions) due to COLSS/CPC monitoring requirements.
2.
Procedural Related Deficiencies A human factors review of Operations and Maintenance depertment procedures and procedare writing guidelines was performed by an industry expert for the purpose of making recommendations for enhancements. Subsequently, these recommendations were used as input to establish enhanced procedure writing guidelines. These guidelines will then be used as necessary to upgrade procedures as they are reviewed during the biennial review cycle.
To date, a comprehensive Writer's Guide for Operating Procedures has been developed and a separate guide for maintenance procedures is in its final developmental stage. This effort should significantly reduce procedural human factors problems which could lead to procedure violations.
In addition to the above, a series of meetings was conducted by the Plant Manager to improve procedural awareness and attention to detail. These meetings were attended by members of Plant Staff and supporting organiza-tions. Feedback on management efforts to improve procedural awareness and NS20745
n-
)
attention to detail is being solicited from Plant Advisory Groups. This 3
fecdt!.ek will be used to initiate action by management to ensure that station personnel are aware of the importance of procedural compliance from both a human factors and a technical standpoint.
l 3.
LQ Inspection Concerns The r.pecific concerns that were identified in the LP&L QA Program included:
i a) No records to demonstrate qualification for equipment subject to submergence under design basis accident conditions, b) improper temperature lag analysis, and c) inadequate schedules for replacement of components susceptible to aging effects at elevated service temperatures.
Evaluations of the above concerns have been performed and the results reflect continued compliance with the NRC regulations.
Specific responses to each of these concerns are as follows:
a) EQ equipment has been evaluated for submergence during DBA conditions.
There were no pieces of EQ equipment identified that must perform a safety function after becoming submerged.
b) LP&L has evaluated the thermal lag analysis for cable and transmitters and has determined that the calculations contain sufficient margin to meet NRC requirements, c) Components susceptible to aging degradation have been evaluated and replacement / maintenance schedules hcVe been outlined in the EQ Files.
Enviromnental conditions (normal, elevated and accident) have been accounted for when determining replacement / maintenance schedules.
4.
Station Modifications In order to improve the retrieval of documents associated with Station Modificaticu (SM) packages, a policy of a single work authorization per SM package was implemented. This policy enhanced both tracking and retrieval of the work package docum ntation.
Implementation of the SIMS System, part of which provides for the scheduling and tracking of individual condition identifications sith a blanket work authorization for SM packages, supple-ments this policy.
Processing of station modifications has been enhanced by developing and implementing new methodology under a Nuclear Operations Procedure. The new procedure better delineates the steps and controls necessary to maintain positive control of plant configuration. The new logic is also being incorporated into enhanced scheduling and tracking techniques.
The effort to reduce SM backlogs has resulted in closing 635 modification packages since January 1987. NS20745
{
5.
Quality Assurance In line with the teamwork philosophy adopted by LP&L management, the QA organization has incorporated several changes in the QA Program to facili-tate the integration of QA support within plant operations activities:
c An integrated Receipt Inspection Plan was developed and imple-L a.
mented, which consolidated the audit process, the receipt inspec-tion process, and material issuance. This integrated approach
[
should provide:
A performance history of suppliers based on receipt inspection
(
activities.
An increased interface between the audit process and the inspection process enabling a more rapid response to issues raised.
An increased confidence 1cvel in the quality of parts / materials
{
used in plant operations.
b.
Supplier Quality Assurance continued their involvement in the Joint Suppliers Audit Program (JSAP) which allows sharing of audit information and auditing processes with the member companies of Middle South Utilities (SERI and AP&L). The JSAP forum provides for an increased awareness of utili;y issues and results in recom-mended improvements in day-to-day operations.
c.
Enhancements to the Quality Trend Program were made by revising the trend categories to provide more meaningful data to operations management and to maintain consistency with the categories esta-blished and evaluated by the NRC. LP&L visitad other utilities in its effort to develop one of the industry's leading Trend Programs.
The completed program was presented at the 1987 Annual American Nuclear Society Conference held in California. The entire trending program has now been shifted to the Event Analysis Reporting and Response organization, which reports to the Plant. Manager. The QA organization will continue to provide expertise during the transi-tion.
d.
The QA organization conducted an extensive review of quality re-lated records sent to the Waterford 3 Record Center during the operat.ing phases of Waterford 3.
The review team was comprised of four contract personnel and one LP&L coordinator for approximately nine months. The results of the review determined that the quality of the documentation was acceptable and minor deficiencies were able to be programmatically addressed.
The originating organiza-tions were involved in the necessary document corrections and subsequent procedure development or revisions. NS20745 I
1 l
e.
The integration of the QA Inspection organization into the Opera-tions QA Section has enhanced the effectiveness of the QA verifi-cation process through cross-training and better personnel utili-zation. During the April 1988 refueling outage, a functional organization will fully integrate audit / surveillance and inspection t
personnel to maintain coverage around the clock, seven days a week.
f.
Operations QA is taking a more proactive approach to the quality
{
verification function by concentrating on the performance of sur-veillances of on going day-to-day activities and factoring the results of these surveillances into the audit process.
g.
The following is a tabulation of QA support activities for 1987:
Operations Audits 38
[
Operations Surveillances 85 Supplier Audits 82 Supplier Surveillances 19 Involvernent by Quality Assurance in daily plant activities continues through attendance at daily planning meetings, NRC entrance and exit j
meetings, refuel planning meetings, validations of NRC responses, procedure i
reviews, station modification package reviews, inspections, nondestructive testing, procurement document reviews, and maintenance of a Qualified Supplier List. NS20745
s LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area J.
LICENSING ACTIVITIES 1986 SALP Category:
1 1985 SALP Category: 2 Summary of NRC Recommended Licensee Actions
(
1.
Licensee should continue to maintain a high level of management involvement to assure continued improvement.
2.
Continued emphasis should be placed to assure supporting analyses continue
{
to be thorough, complete and timely.
I 3.
Focus on expeditious resolution of the SPDS issues to achieve acceptable l
design and operation.
Current Status The licensing activity in 1987 concentrated on the resolution of the few remaining longstanding issues with the NRC, while at the same time assuring that significant progress was made in the licensing functional areas.
Examples of outstanding issues which were resolved include licensing of the Broad Range Toxic Gas Detection System (see Section A, Plant Operations, Item 7b), the redesign of the Safety Parameter Display System (SPDS), human factors improve-ments required as a result of the Detailed Control Room Design Review (DCRDR),
[
and the confirmatory analysis and monitoring program associated with the J
basemat cracks. Progress continued in standard licensing functional areas such as technical specification enhancements, resolutions of issues, responses to NRC inspections, closure of commitments, and the Cycle 3 reload.
Management continued its direction of, and active participation in all aspects of regulatory activities. A particularly successful action in this regard was instituted in late 1986. The Senior Vice President-Nuclear Operations chairs re3ularly scheduled meetings of his senior staff to review current Waterford 3 performance and provide management guidance and direction for the future course of plant activities. Of prime importance to the senior management group is plant safety and, consequently, the resolution of regulatory issues. As a standard practice, significant licensing issues are presented to the senior managers for their initial direction; thereafter, briefings are presented as needed through final resolution of the issue to ensure management incent is adhered to. NS20745
Significant Licensing Issues 1.
SPDS As directed by the Vice President-Nuclear, in February 1987, an LP&L task
[
force comprised of personnel from Operations, Plant and Srpport Engineer-ing, Reactor Engineering and Performance, Licensing and Nuclear Engineering was established with a goal of resolving the outstanding concerns and noted
[
deficiencies with the present SPDS design for Waterford 3.
The task force implemented intensive work efforts via group meetings, discussions with the NRC, correspondence and executive management interfaces aimed at developing an SPDS Enhancement Program that would accomplish this goal.
By June 1987, a functional design specification for the SPDS Enhancement Program was developed. The specification consisted of a list of modifi-(
cations to the existing SPDS software and hardware that will be implemented not only to address NRC concerns, but to provide Operations personnel with a more efficient and useful system for rapidly and reliably determining the
{
safety status of the plant. An added advantage to the enhanced design is the integration of the SPDS with the Waterford 3 Emergency Operating Procedures which were unavailable during the development of the original design.
In order to provide the NRC with an opportunity to examine the present design, view the proposed display prototypes and discuss the draft func-
[
tional design specification, a meeting with the NRC was held at Waterford 3 in June 1987. Based on the positive feedback that was provided by the NRC at the exit meeting, the specification was finalized and subsequectly transmitted to the NRC. As stipulated in the specification, the enhanced SPDS design will be installed, functionally tested and operational with approved procedures by August 1, 1988, and validation testing on the Waterford 3 simulator will be completed and the results evaluated by December 31, 1988.
In August 1987, the NRC issued an SER providing approval for the Waterford 3 SPDS Enhancement Program. The NRC concluded in the SER that the enhanced design contains no serious safety questions, implementation may continue and the schedule for completing and installing the redesign is acceptable.
Confirmation that the installation and performance are in accordance with the functional specification will be assessed by the NRC once implementa-tion has been completed.
2.
DCRDR The Detailed Control Room Design Review (DRCDR) has been ongoing at Waterford 3 since the early 1980s. Entering 1987, only a few technical issues remained to be resolved. Following the same approach as taken with the SPDS, a plan for the resolution of DCRDR technical concerns was formu-lated and a final meeting and plant walk-through was held with the NRC technical personnel in June, 1987. The meeting was successful, and the basis was established for the resolution of all outstanding technical issues. Followup documentation was provided to the NRC in July 1987.
It NS20745
~
is our understanding that a DCRDR SER will be issued shortly and will con-clude that the Waterford 3 DCRDR satisfies all requirements of NUREG-0737, Supplement 1.
3.
Basemat r
L The integrity of the Nuclear Island Basemat was another longstanding tech-nical issue with the NRC. During June and July,1987 LP&L submitted to the
[
NRC the surveillance program and the results of the confirmatory analysis L
program. The Safety Evaluation Report on the basemat was issued in October 1987. The NRC concluded in the SER that LP&L had satisfactorily imple-mented a confirmatory analyses program demonstrating the adequacy of the
[
basemat and had instituted an acceptable basemat surveillance program, as required by License Condition 2.C.17 of the Waterford 3 operating license.
[
4.
License Amendments Twenty license amendments were submitted to the NRC in 1987. These license
[
amendments were aimed for the most part at improving nuclear safety and t
reliability.
5.
Other Licensing Activities
(
The following examples are typical of the m*.y and varied licensing ac-tivities also conducted during 1987:
a.
Control Systems Single Failure Study: This study was submitted to the NRC in 1986. The study involved a detailed and comprehensive failure and effect analysis of the functional loss of a power supply sensor, or impulse line and the postulated effect on control systems. Comprehen-sive questions were generated by the NRC during 1987. LP&L provided acceptable answers to these questions in April and July, 1987. The NRC is expected ;o issue a Safety Evaluation Report shortly, documenting the resolution of this issue.
b.
Boraflex Surveillance Program: Based on industry experience, LP&L determined that the commitments for boraflex surveillance needed to be revised to improve the technical basis and to incorporate new develop-ments in the industry. Detailed technical evaluations were submitted to the NRC in September and November, 1987 to support a modified boraflex surveillance program. The NRC, in December, 1987, issued a Safety Evaluation Keport concurring with LP&L's proposed program, c.
FSAR Annual Update:
Pursuant to 10CFR50.71(e), LP&L must update the FSAR annually to reflect recent changes in design and operation of Waterford 3.
Numerous documents were reviewed including station modifications, new analyses, license document change requests, and correspondence to the NRC resulting in over 150 changes to the FSAR.
The annual FSAR Update was transmitted to the NRC in December 1987. NS20745
=
6.
Cycle 3 Reload As with the Cycle 2 reload, LP&L has taken the initiative to assure that reload activities that require regulatory review are defined and planned well in advance.
In keeping with this philosophy, the Vice President-I Nuclear, Plant Manager-Nuclear, Nuclear Safety & Regulatory Affairs Manager L
and the Licensing Programs Manager met with NRC management in October 1987 to review the expected Cycle 3 reload activities. As a result, licensing actions required to support the Cycle 3 reload have been largely approved
[
by the NRC or will shortly be approved.
7.
Regulatory Excellence The Middle South Utilities System and Waterford 3 have, as a system objec-tive, the achievement of regulatory excellence.
The Senior Vice Presi-
[
dent-Nuclear Operations issued, on December 18, 1987, the LP&L Nuclear L
Operations Executive Directive, ED-049, for excellence in regulatory affairs.
(
To support the concept of regulatory excellence, Nuclear Operations man-agement has emphasized a pro-active approach to safety, regulatory com-pliance, nuclear operations enhancement, and increased Nuclear Operations
(
Senior Management communications with the NRC (i.e., the Vice President-Nuclear and Nuclear Safety & Regulatory Affairs Manager's trip to NRR to meet *he New NRC Project Manager). This perspective is rooted in the l
understanding that safety, regulatory compliance, nuclear operations t
enhancement, and enhanced communications are not disjointed concepts but different aspects of the same goal. The Vice President-Nuclear along with other Senior Managers attended the NRC/ Utility Interface Meeting in Orange County.
Upon returning, the Vice President-Nuclear directed actions to be taken to improve the understanding of the regulatory process, to be more open in communications with the NRC, to improve the professional conduct and interpersonal relationships between the NRC and the Nuclear Operations Department's staff, and to communicate on a more regular basis with NRC inspection personnel to better gauge and understand the impact of NRC inspection activities. We trust that our approach to regulatory excellence has already borne fruit in more open communication. We solicit further input as necessary to continue improving as needed. NS20745
~
0 LOUISIANA POWER & LIGHT COMPANY WATERFORD 3 SALP PROGRESS REPORT Performance Functional Area K.
TRAINING AND QUALIFICATION EFFECTIVENESS 1986 SALP Category:
1 1985 SALP Category:
2 Summary of NRC Recommended Licensee Actions 1.
Management should focus on simulator delivery and making simulator fully functional.
2.
Emphasis should be placed on training nonlicensed personnel.
3.
Corrections should be made of identified deficiencies in training program administration / documentation.ind ensure periodic reviews are performed to identify future problems.
Current Status During 1987, the Nuclear Operations Training Department made significant strides towards improving the training programs. These included:
Successful accreditation of all 10 INPO programs, eight of which involve non-licensed personnel training.
Successful acceptance and installation of the Waterford 3 Plant Referenced Simulator.
Successful integration of the Waterford 3 Plant _".eferenced Simulator into the Licensed Operator Requalification Program.
Continued transfer of experienced plant personnel, including licensed personnel, into open training positions to maintain a high level of techni-cal knowledge on the training staff.
Promotion of experienced training staff members into plant positions. The Vice President-Nuclear has always stressed the importance of maintaining experienced operations and maintenance personnel in the Training Department as well as in Plant Operations.
- Delivery of training on maintenance items to licensed operators during annual requalification utilizing the Skills Training Center Labs.
Initiation of a broadbased Technical-Staff and Managers Training Program.
- NS20745
The above examples indicate the high level of management commitment to maintain
~
training programs in Nuclear Operations that contribute to the safe and effi-cient operation of Waterford 3.
1.
Waterford 3 Simulator Site delivery of the Waterford 3 Simulator commenced with the arrival of the first shir;ing van on April 28, 1987. Coordination of resources between LP&L had the simulator vendor resulted in a hardware installation period of four days. Onsite acceptance testing began immediately there-after and the targeted ready-for-training milestone date of June 15, 1987 was met.
Between June 15, 1987 and December 6, 1987, the simulator supported four cycles of Operator Requalification Training.
Upon comple-tion of the last training session, the simulator's first planned outage for upgrades commenced on December 7, 1987. Emphasis of the outage was directed at enhancing management and performance of the rimulator to meet guidelines set forth in 10CFR55. Listed below are the key areas and tasks addressed as part of the simuistor outage.
a.
Control Room Audio / Visual Recording System This feature has been installed to enhance simulator training and exam evaluation by providing documented review of operator response and actions during training scenarios. The system consists of two cameras, one of which has pan, tilt, and zoom capabilities. Sessions may be viewed dynamically and/or recorded onto magnetic tape for later evalua-
- tion, b.
Instructor Station Software Corrections and Enhancemects This task was specifically targeted at improving reliability of unique simulator features available to the instructor. The majority of this effort was focused in the area of simulator backtrack. This feature allows the simulator to be paced backward to a specified time frame and once again continue a normal simulation scenarfo.
c.
Plant Computer Point Limits This task has provided enhanced fidelity of the simulated / stimulated plant monitoring computer. The modification involved placing high and low instrument limits within the simulation software models for approx-imately 1600 data points. This feature ensures that the simulator does not report parameter values which would not be possible within the actual plant system.
d.
Simulator Approach to Design Limits Alarm Identified as an ANSI 3.5 requirement, this feature involves design of a software package whose purpose is to monitor key process variables and alert the instructor when simulation software design limits are approached. NS20745 l
I
e.
Annual Performance Test Support Program This task integrates 12 additional hard copy pen recorders and a supporting software driver to meet test requirements outlined in the ANSI 3.5 document.
f.
Simulator Computer Intelligent Clock Module This task involves integration of a micro processor based clock module to allow automatic system initialization and enhance the software configuration controls of the system.
g.
Simulator Communication System Upgrade This task involves redesign of the existing communication system to eliminate noise and provide compatibility to allow transmission to the Waterford 3 plant site during emergency drill scenarios.
On February 15, 1988, the simulator was placed back in service with the above upgrades incorporated.
Normal simulator maintenance items are being pursued on an ongoing basis.
These include correcting simulator discrepancies and implementing plant station modifications on the simulator.
2.
Non-Licensed Personnel Training LP&L places strong emphasis on non-licensed personnel training programs and is always striving to improve such programs to provide the knowledge and skills necessary for personnel to achieve peak performance. High on the list of management goals for 1987 was to have all 10 of Waterford 3's basic training courses accredited by INPO. Of the 10 basic courses, eight involve non-licensed personnel training.
In December 1987, LP&L achieved accreditation for all 10 of the training courses and was granted full membership in the National Academy for Nuclear Training.
Since the end of the last SALP review period in January 1987, LP&L's non-licensed personnel training programs have received extensive reviews by INPO and LP&L manage-ment and many program enhancements resulted.
It was through these reviews and enhancements that accreditation was ultimately achieved.
In May 1987, Waterford 3 instituted a program to provide familiarization training on Waterford 3 systems for plant personnel other than operators.
Engineering, Plant Engineering, Instrumentation and Control Technicians, Quality Assurance, Nuclear Support, Nuclear Safety and Regulatory Affairs, and Nuclear Operations Support & Assessments personnel have taken advantage of these system modules to enhance their Fnowledge of Waterford 3 charac-teristics. The system modules are taught at the Licensed Reactor Operator level of knowledge, although 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per session does not provide the same depth of information as an actual licensing course. Each class is repeated four times during a five week interval so that each attendee may find a convenient time to attend. Approximately 20 modules will be giveu so that the entire course may be completed during a 2 year cycle NS20745
At the direction of the Vice President-Nuclear, a specific training program was developed and implemented for Action Engineers. Action Engineers, engineers selected from the Nuclear Operations Engineering Department, are assigned the responsibility of following all phases of station modification implementation which includes design, scheduling, materials procurement, r
construction, testing, as built checks, and closeout. The training program L
for these engineers covers all of tia 9bove aspects of their responsibility.
f 3.
Correction of Training Program Deficiencies Problems identified regarding training program administration / documentation have been addressed. The corrective actions required the rewriting of
[
appropriate procedures making them more restrictive. Examples include NTP003 (Training Records), NTP005 (Training Materials) and NTP204 (Instruc-tor Training).
LP&L has a policy of conducting management reviews, Quality Assurance reviews, annual reviews by the Training Department in conjunction with the Nuclear Operations Support & Assessments Department and evaluations by the trainees themselves after each class to assess training programs and to identify problems. As problems are identified appropriate corrective action is taken.
4.
University of Maryland B.S. Degree Program One of the most special "people programs" at Waterford 3 is the B.S. Degree Program which the Training Department helped design in conjunction with the University of Maryland. Nuclear Plant operators, at their option, are presently enrolled in the academically rigorous program, which will enable them to earn a B.S. in Nuclear Science from the University College of the University of Maryland. Although the courses within the program have a theoretical foundation applicable to many scientific and technical situa-tions, the principles have been specially applied to the nuclear power industry. Case studies and sample problems have been drawn from realistic operational situations.
This approach has two big benefits for Waterford 3 personnel. First, they can learn more quickly by building upon the knowledge and experience which they have already acquired.
Second, they can apply the theoretical aspects of their courses to their work.
Learning takes place in Louisiana using two long-distance course delivery modes. Computer-assisted courses are used to transmit technical material.
Prepared at the University of Maryland, these courses are based on the traditional lecture format but enable learners to work at their own pace.
Open university courses are used for general education requirements, management courses, and electives. These courses are structured around assigned readings supplemented by optional on-site discussion seminars.
Instructors use a combination of person-to person, phone, and mail contact to provide guidance to individual learners. Fall 1987 classes were offered in Calculus I, Physics II, and Management. NS20745 4
__