ML18046A927

Evaluation of Palisades Nuclear Power Plant.

ML18046A927
Person / Time
Site:	Palisades
Issue date:	07/31/1981
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
To:
References
NUDOCS 8109250244
Download: ML18046A927 (46)

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! . July, 1981

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l 1 EVALUATION of l

PALISADES NUCLEAR PLANT l

Consumers Power Company l

.J July 1981

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SUMMARY

INTRODUCTIO~

The Institute* of Nuclear Power Operations (INPO) conducted its first evaluation l of Consumers Power c::;ompany's Palisades Nuclear Plant during the weeks of March 30 and April 6, 1981. Palisades Nuclear Plant consists of one 700 megawatt (net electrical) Combustion Engineering pressurized water reactor

-_J plant. The site is located on the eastern shore of Lake Michigan five miles south of South Haven, Michigan. The plant was placed in commercial operation in December 1971, achieving full power in March 1973.

l PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant operating safety, to evaluate management systems and controls and to

} identify areas needing improvement.

The evaluation was based on INPO experience of best practices within the l industry and written evaluation criteria furnished to the plant in advance.

Information was assembled from discussions, interviews, observations and re-views of plant documents. Emergency preparedness was not included in the ie scope of the evaluation, nor were corporate activities, except training, which recently became a corporate function.

The evaluation team examined station organization, training, operations, mainte-

-, nance, radiological and chemistry activities and site technical support. Since evaluations were based on best practices, the recommendations made are not limited to minimum safety requirements.

• 1 DETERMINATION I Within the scope of this evaluation, the team determined the* plant is being safely operated. The following beneficial practices and accomplishments were J noted:

o The corporate and plant goals and objectives are well prepared and effectively utilized. Employee communications within the plant were found to *be very effective. The industrial safety program is effective with strong corporate support and individual involvement at all levels.

o We observed a very quiet, orderly control room with effective access control.

j Improvements were recommended for the following general conditions:

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• o Shortcomings in the plant training program were observed, including a lack of qualified instructors, lesson plans, opera tor requalifica tion train-ing and facilities.

PALISADES (1981)

Page 2 o Personnel shortages were noted, particularly for the positions of reactor operator, instrumentation and control technician, health

• physics technician a.nd training personnel.

o Activities and equipment other than safety-related were .found excluded from. the quality assurance and preventive maintenance programs.

l Recommendations are intended to augment Consumers Power Company (CPCo) efforts to achieve the highest possible standards in its nuclear operations.

l Specific evaluation findings and recommendations are contained in the accompa-nying DETAILS, and information of an administrative nature is included in the 1 ADMINISTRATIVE APPENDIX~ These findings were presented at an exit meeting at the plant on April 10, 1981.

In addressing these findings it is important to look beyond correction of the l specific deficiencies. The response should consider the underlying issues since certain findings may reflect multiple deficiencies within a particular area.

CPCo's responses have been reviewed and are considered satisfactory. To follow timely* completion of these responses, INPO requests written notification, as improvements are achieved, on or before key target dates.

The evaluation team appreciates the excellent cooperation received from all levels of the Consumers Power Company. Palisades Nuclear Plant personnel were prompt and courteous in responding to our requests and dedicated many hours and personnel *solely for this eval!lation.

E. P. Wilkinson President l

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Consumers Power Company l Response Summary l Consumers Power Company concurs with INPO's conclusion that the Palisades Plant "* ** is being safely operated." Consumers aISo recognizes there are areas for improvement and the Company is committed to meeting, or exceeding, INPO's recommendations to ensure excellence *of plant operations. There are 1 several broad areas of improvement that will have the greatest impact on addressing most of the findings.

The Palisades Plant staff is being increased in 1981, and additional staff increases are under review for 1982. Special recruiting efforts -have been made to add these authorized staff members as quickly as possible.

The corporate Nuclear Operations Training Department staff is being increased with special" emphasis on the hiring of qualified instructors and administrators, and on acquiring programs to meet the needs of all Nuclear Operations Department personnel. The training of individual groups* of employees using programs for each work group is in progress. A new training facility and a simulator for both the Midland and the Palisades Plants are presently under l construction.

Plant facilities will t;>e upgraded, following a thorough review of all requirements and plant needs, through a Site Facili_ties Study expected to be completed by 1 January 31, 1982. This study. will include the training facilities, chemical laboratory facilities, maintenance shops, acc~ss control,* security, office spaces, as well as other support requirements.

l A major effort is being made to standardize many of the activities throughout the Nuclear Operations Department through the establishment qf a "Standards l Manual." This contractor supported program will expand many of the safety-related practices presently in use to include critical non-safety-related prac-tices.

Specific. implementation dates *have been established wherever possible.

Consumers will continue to. welcome follow-up INPO evaluations to assess program implementation and effectiveness.

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Page 4 DETAILS This portion of *the report includes the detailed findings. It is composed qf six se.ctions, one for each of the major evaluation areas. Each section is headed by a l summary describing the scope of the evaluation and the overall finding in that area. The summary is followed by the specific findings, recommendations and utility responses related to each of INPO's evaluation procedures. Items which relate to criteria that have not been included in INPO procedures but which are 1 generally recognized as desirable, accepted techniques of industry and manage-ment are listed as General Criterion. The evaluation procedures that were use*d are listed in the ADMINISTRATIVE APPENDIX.

l ORGANIZATION AND ADMINISTRATION 1 In this area, the organizational structure, personnel qualifications, administra-tive controis, management gqals and objectives, quality assurance, industrial safety and equipment surveillance were evaluated.

I Major* strengths in this area are the well-defined goals and objectives provided by the general office to the plant. At the plant the goals and objectives are 1 published and their progress monitored by the general manager and the depart-ment heads.

The dedication to industrial safety by the corporate office and plant staff is J reflected in the effective plant .safety program and record. Some areas in the Organization and Administration area do not meet -the INPO criteria, as noted in the following findings.

I OBJECTIVF.S l (INPO Procedure OA-101, Revision 1)

The evaluation team examined the methods used to establish and publish management objectives as well as how attainment of the objectives is monitored.

I The objectives were examined to determine if they prqvide substantive guidance to managers and supervisors. and support the plant and overall company objec-i tives. The degree to which the objectives are used to guide day-to-day activities I

ii was also reviewed.

Finding All criteria in this area were met.

J ORGANIZATION STRUCTURE i ) (INPO Procedure OA-102, Revision 2)

• An evaluation was performed to determine how effectively the organization, as structured, provides for management of the station to ensure safe, efficient J operation. Areas reviewed included applicability of the organizational structure J *~ .

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diagrams, position descriptions for all station_ personnel, personnel performance .

evaluations, supervisors' authority, assignment of backup* personnel *for key l positions and staffing levels.

1. Finding (Ref. Criterion *A)

The current organizational structure is new and incomplete. An evolu-l tion began. approximately six months ago as a management effort to improve organizational effectiveness. Although new and incomplete, the proposed changes noted for the* Operating, Technical and the Planning 1 and Scheduling departments appear to have excellent potential for providing desired improvements.

Recommendation

• 1 Publish and maintain current organization diagrams reflecting the actual reporting lines in effect.

Response

Plant organization diagrams reflecting the* actual reporting lines in 1 effect will be published and maintained in established Plant Adminis-trative Procedures within thirty days following NRC approval of the Technical Specification request submitted on plant organization changes

. dated December 3, 1980.

2. Finding (Ref. Criteria Band C)

Position descriptions, defining authority, responsibility and accounta-bility of in~ividuals assigned to the positions, have not been developed for the plant and corporate tra_ining staff.

• Recommendation Define in writing individuai job functions, responsibilities, *authorities and accountabilities that can be used for defining job qualifications, selection and performance appraisals and for determining training re-quirements of individuali:; at each position.

Note:This finding and recommendation applies to INPO 'procedures OA-l 108, TQ-211 (includes corporate training staff}, OP-303, MA-401 and RC-501, Criteria A, C & F, B, C & E respectively. Each of these criteria has requirements based on job analysis and will not l Response be listed as separate*findings.

. The plant will develop procedures that describe current individual job functions, responsibilities, authorities and accountabilities for the plant staff. Within the context of current company job evaluation, perform-ance appraisal and promotion selection. systems, these procedures will be used for defining job qualifications, selection and performance appraisals and for* determining training requirements of each position. The Nuclear Operations Training Department will establish similar procedures for the training staff. These efforts will be completed by March 31, 1982 for the plant staff and January 1, 1982 for the corporate nuclear trainfog staff.

In addition, the Nuclear Operations Training Department will develop J training programs to meet job requirements on an ongoing basis.

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! " Page 6 ADMINISTRATIVE CONTROLS .

CINPO Procedure OA-103, Revision 1)

The station administrative procedures were examined to determine if clearly defined controls are in effect and if adherence to these controls is maintained.

Finding (Ref. Criterion E) *

• The administrative control system consists of many administrative

• procedures. The complexity of the procedures prevents effective implementation by the plant staff. Plant management" has established a goal to review and modify existing administrative procedures for simpli-fication and clarification.

Recommendation Complete review and modification of administrative. procedures and ensure adherence.

Response

A schedule will be established to review and modify Plant Administrative

• Procedures with the objective of simplification and clarification by December 1981, and to complete the project by December 31, 1983.

Meetings have been held to establish procedure review responsibilities.

• A project coordinator is to be appointed in the near future.

QUALITY PROGRAMS (INPO Procedure OA-104, Revision 4)

The quality assurance (QA) program was reviewed to determine if an approved program is in place that covers all aspects of* plant operations, the program is adequately staffed and the organizational* relationships ensure the independence l of the QA staff.

Finding (Ref. Criterion B)

The *QA program in place covers only the technical specification I requirements and is not used for non-safety-related plant equipment.

Recommendation

. Expand the QA program to include non-safety-related equipment that

. can improve quality and plant performance.

Response

A study will be completed by Jurie 1982 to identify non-safety designated plant equipment that is important to safety, and this eq:uipment will be incorporated into the QA program. Remaining equipment will be evaluated for inclusion in this program.

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Page 7 INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 1) l The team examined the industrial safety program to determine if management is clearly committed to industrial safety, the program is supported at all levets of the plant staff and the program is effective in minimizing safety hazards and accidents.

Finding A very effective industrial saf.ety program exists at Palisades, and strong support is received from the utility's corporate offices. Substantial involvement by supervisors, the Plant Safety Committee and plant personnel is reflected in the current safety record.

l All criteria in this area were met.

lI I SURVEILLANCE PROGRAM (lNPO Procedure OA-107, Revision 1) 1 The team examined the surveillance program to determine if adequate proce-dures, including acceptance criteria, are in use. They also evaluated the methods used to schedule surveillance tests, control operations so that safety is l not adversely affected during testing and identify and resolve deficient condi-tions found.

• l Finding .

No findings were made in this area.

l l PERSONNEL QUALIFICATIONS (INPO Procedure OA-108, Revision 1)

An evaluation was performed to determine if a program exists for providing

~ appropriately qualified personnel to operate and maintain the plant. Areas I

reviewed included the application of job and task analysis to each station position, the program for personnel selection arid promotion and the program for periodic review of job and task analysis.

Finding (Ref. Criterion A)

This criterion is addressed under Procedure OA-102, Finding 2.

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l. TRAINING AND QUALIFICATION l In this area, the team evaluated the training organization, administration of training programs, training resources and training effectiveness. Training programs for the following job classifications were also evaluated: licensed l operators, non-licensed operators, shift technical advisors, mechanical and electrical maintenance personnel and instrumentation and control (I&C) techni-cians. Positive features noted were that the facility has established a commit-1 tee to determine the training needs of the plant staff and the corporate training section has recognized the necessity of having an effective training organization at Palisades Nuclear Plant. However, there are conditions where opportunities for improvement exist regarding training administration policy and procedures, training resources, training for plant staff other than licens.ed operators and evaluation of training effectiveness.

TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)

I The team examined the on-site training organization and the administrative guidance used by the organization to develop, implement and evaluate training activities and programs used for the qualification of plant personnel.

1 1. Finding (Ref. Criterion B)

The training organization is not of sufficient size to develop program 1 materials and achieve professional *development of the training staff.

The condition has been recognized by man~gement, and an organizational development plan has been submitted.

l Recommendation.

A review of staffing needs for training should be performed and additional staff members should be added so that training support activities, as well as classroom presentations, can be adequately per-J formed.

Response

Three instructors have been added to the Palisades training staff since l the date of the INPO audit; one each for training in mechanical maintenance, electrical maintenance and in basic mathematics and physics. At least one additional senior reactor operator (SRO) licensed

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instructor is also being obtained to assist in licensed operator training.

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• the staff.

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2. Finding (Ref. Criterion C)

The finding for the corporate training staff is addressed under Procedure l OA-102, Finding 2.

l 3. Finding (Ref. Criterion D)

The plant is not conducting a formal program for training, qualification and retraining of-mechanical an.d electrical maintenance personnel. In J

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Page 9 l: addition, I&C technicians are not receiving site specific training. This has been recognized by training management, and programs are being 1 developed.

Recommendation Develop and implement programs for initial training and retraining, including qualification requirements, for all technical disciplines.

1 Response .* * .

A continuous training program for Mechanical Maintenance and Elec-trical Maintenance personnel has been established. Two instructors with 1 experience in these respective areas have been added to the general office training staff. I&C technicians will receive generic training at the Midland Nuclear Training Center, and site specific training will be 1 conducted at Palisades. A program for plant specific training for I&C technicians will be developed by fall 1981. Wnile qualification requirements guidelines have not been established for all techni~al l groups, they are* under consideration for* development and should be det~rmined by late 1981.

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I 4. Finding (General Criterion)

• The training section *does not have an approved training manual that describes the administrative policies and procedures for various types of I training and retraining program development. The organization has no guidance or policy to explain the interface with other plant departments.

The staff has no guidance or policy to describe the responsibilities of the training organization. This deficiency is affecting the training organiza-l tion's ability to satisfy t_he plant's training needs.

Recommendation .

Establish and implement a training department manual to ensure that l administrative policies and procedures are communicated to all levels of the organization.

Response

The recent change in corporate training management *has delayed the development of a training department manual; however, it is scheduled

• for distribution by February 28, 1982.

TRAINING RESOURCES (INPO Procedure TQ-221, Revision 2)

The team examined the training facilities, equipment and materials available to support training programs for plant personnel.

1. Finding (Ref. Criterion A) .

Classroom training facilities are not adequate to handle all formal group instruction provided at the site. Facilities do not provide sufficient training support areas to accommodate the activities of the trainees and the training staff. This condition has been recognized by the training section. Three new classrooms .and office space for four instructors will l be available by mid-1981.

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Page 10 Recommendation Management should evaluate training facility needs and requirements, including classroom facilities, and provide improvements as necessary.

Res po~

The two mobile classroom facilities being installed at the time of the INPO audit are now in. daily use. These facilities provide three l additional classrooms (total now of six) and office space for five instructors. The Nuclear Training Center located in Midland, Michigan is scheduled for ground breaking in June 1981 and initial use in June 1982.

1 TRAINING EFFECTIVENESS (INPO Procedure TQ-231, Revision 2) l The team *examined plant managE;:?ment and training organization practices relating to the evaluation of training program effectiveness, the audit of training activiti_es and the evaluation of instructor and trainee performance in training programs.

1. Finding (Ref. Criterion A)

Plant and training management does not conduct structured, regular, written evaluations of training programs. A procedure requiring such systematic appraisals of training effectiveness does not exist. The absence of good communication has resulted in a lack of understanding as well as a lack of sharing of common goals and objectives by personnel in the training and plant organizations.

Recommendation.

A program of formal, . periodic evaluations of training effectiveness should be established. A principal objective of this program should be to determine if each training program is meeting its respective goals and objectives. Continuous, less formal feedback from persons receiving training should also be encouraged so that training curriculum can be changed as necessary to adequately address the needs of field personnel.

Respoffie *

• A program* of formal, periodic evaluations of plant training effectiveness

. will be established i;ind implemented by December 31, 1981 by the Nuclear Operations Training Department.

I NON-LICENSED OPERATOR TRAINING (INPO Procedure TQ-242, Revision 2)

The team examined the training program and training practices used to initially qualify non-licensed operator candidates and to maintain and improve the qualifications of existing non-Hcensed opera tors.

1. Finding (Ref. Criteria A and D)

I Continuing training and retraining of non-licensed operators are not being conducted to maintain and improve capabilities of non-licensed J

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Page 11 operators to perform their current job. This condition has been recognized by training management, and it is understood that a program l for non-licensed operators will be implemented by mid-1981.

Recommendation Establish a retraining program for non-licensed operators that includes changes to plant systems, operating procedures and administrative 1 controls which affect the non-licensed operator's duties.

Res[X)nse A retraining program for non-licensed operators has been established separate from that for licensed operators. This program involves each non-licensed operator once every five weeks and includes studies on fundamentals, theory and plant systems. Time is also spent with the licensed OI_)erators in join~ training.

LICENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)

The team examined the training program and practices used to initially qualify license candidates.

Finding All criteria in this area were met.

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LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ-244, Revision 2)

The team examined the reqtialification programs and training practices used to maintain and improve the qualifications of licensed personnel.*

Finding (Ref.* Criterion G)

The licensed operator requalification program does not include a com-prehensive oral examination to monitor the operator's knowledge and skills. The oral evaluation should be directed toward determining the licensed operator's knowledge* of plant systems and the operator's capability to analyze and respond to abnormal and emergency plant conditions.

• Recommendation The licensed operator requalification program should include a struc-l tured oral examination conducted at least annually.

Response

Provision has been made in the 1981 annual requalification examination j schedule to include oral examinations of all licensed operators.

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SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-245, Revision 1) l The team examined the qualification program and training practices used to qualify shift technical advisor (STA) candidates and to maintain and improve the l qualifications of the ST A.

Finding (Ref. Criterion D)

A program or training plan has not been developed to provide retraining 1 for STAs.

Recommendation Develop and implement an annual refresher training program for STAs.

l Response .

The present ST As are serving on an interim basis and are expected to be replaced by November 30, 1981 by a group of engineers in training for

., SRO licenses. Refresher training for this interim group of STAs will be accommodated by their selected participation in the licensed operator requalification program.

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PALISADES (1981) l Page 13 l- OPERATIONS The area of Operations was evaluated using current INPO criteria for performance in shift conduct, organization and administration, use of proce-dures, tagout practices, plant status controls, facilities and equipment and shift l turnover.

• The team found that the plant is generally clean, control room access is well l controlled and the use of fixed maintenance tagouts is an efficient method of performing switching and tagging orders.

1 It was noted that improvements could be made in the areas of conduct of shift operations, tagout practices, organization and administration, plant status con-trols and shift turnover. These improvements are discussed in detail as follows.

1 CONDUCT OF SHIFT OPERATIO NS (INPO Procedure OP-301, Revision 2)

An evaluation was performed to determine the effectiveness of shift operations in maintaining quality shift performance. Areas reviewed included operator activities, station cleanliness and order, response to abnormal conditions, log-keeping practices, control room instrumentation reliability and operator aware-ness of plant conditi~ns.

Finding (Ref. Criterion C) _

Alarms on control panels exterior to the c_ontrol room are not promptly cleared, and numerous alarm conditions exist for excessive periods of time.

Recommendation Develop and implement an ongoing program to clear alarms and alarm conditions on control panels exterior to the control room.*

l Response Additional emphasis has been placed on the maintenance and operation of the radwaste and makeup systems to which this finding applies.

Project engineers have been assigned to evaluate system and component J performance and initiate design changes, identify maintenance activities to correct underlying problems and schedule processes to optimize system performance.

TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)

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An evaluation was performed to determine if established tagout practices ensure protection for personnel and station equipment. Areas reviewed included senior reactor operator (SRO) approval of safety-related tagouts, double verification of tagged equipment for personnel safety, double verification of important manual valves when repositioned, tag coloring and numbering and review of clearance J logs.

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Page 14 Finding (Ref. Criterion G)

An audit was being performed*for caution tags and bypass and jumper l installation, but no physical audit was being done of the red workmen's protective tags. Since the evaluation the procedure has been changed and a physical audit has been performed.

• Recommendation l Management .should periodically assess the audit program to ensure that it is being performed in a timely and effective manner.

R~po~e .

Procedures have been changed to require periodic physical audits of workmen's protective tags, and monthly audits of these tags have been

• initiated. In addition QA audits, or surveillances, will be conducted on a periodic basis to determine departmental adherence to these require-ments.

OPERA TIO NS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP-303, Revision 2)

An evaluation was performed to determine the existence of a clearly defined operations organization that provides for assignment of responsibilities and delegation of adequate authority for accomplishment of required tasks *. Areas reviewed included organizational" struc.ture, job descriptions, shift administrative assignments, written and oral instructions and orders and miscellaneous admin-istrative programs.

• Finding (Ref. Criterion C)

Currently an inadequate number of licensed reactor operators are available for a normal shift rotation and retraining. This condition also limits the availability of personnel for senior reactor *operator (SRO) training. This situation has been recognized by management, and an active recruitment program has been implemented.

Recommendation Increase staffing in the operations department so adequate personnel are available for licensed training, coverage during vacations and reduction in overtime.

R~ponse ii The goal for the operations staff will be to maintain eighteen. RO licenses and thirteen SRO licenses in order to provide six-shift rotation; there are currently ten RO . licenses and nine SRO licenses wit_hin Operations. A six-candidate RO class is in progress, with an expected examination date of January 1982. A second RO class of six candidates and an SRO class of four candidates are scheduled to commence in early 1982, with NRC exams in early 1983~ In addition, six engineers are being hired to commence STA training followed by SRO training, and they will be assigned to shift work when they are licensed. Replacement RO and SRO classes will be scheduled in 1983 to compensate for any reassign-ment or turnover that may occur.

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Page 15 USE OF PROCEDURES (IN PO Procedure OP-304, Revision. 2) l An evaluation was performed to determine proper use of procedures for the safe and reliable conduct of plant operations. Areas reviewed included management policies for tise and change of procedures (short-term and long-term). In addition, procedures were. reviewed for clarity, continuity, identification of "sequence required" actions and.suitable advisory information.

Finding The criteria of OP-304 were met.

l PLANT STATUS CONTROL (INPO Procedure OP-305, Revision 1)

An evaluation was performed to determine that plant status controls are provided to ensure adequate equipment and system availability. Areas reviewed included management programs or policies that provide guidance for status control, actual practices in status control, responsibilities of senior licensed operators assigned to monitor and review status control and provisions for status control under specii;tl conditions such as outages, accident recovery or refueling.

Finding (General Criterion)

Approved procedures arid policies were nqt in effect to prevent the use of uncontrolled instructions, notes or drawings attached to plant compo-nents or consoles. Since this finding, a procedure has been developed and implemented to control these instru~tions, notes and drawings.

OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedure OP-:306, Revision 2)

An evaluation was performed to determine if plant facilities and equipment are operable and* maintained in a manner that ensures safe and efficient operation.

Ar~as reviewed included equipment o"perabi.lity, equipment availability pro-gram(s), working environment, adequacy of communication equipment and watch station assignments.

• Finding The criteria of OP-306 were met.

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Page 16 SHIFT TURNOVER (INPO Procedure OP-309, Revision 2) 1 An evaluation was performed to ensure continuous, correct understanding of station conditions is maintained at all shift positions. Areas reviewed included 1 programs and policies controlling turnover practices for watch stations, check-lists, operating panel reviews and station activities in progress or planned.

Finding (Ref. Criterion B) 1 Checksheets are not used for any of the four assigned auxiliary operator watch stations to verify plant status during shift turnover.

Recommendation 1 Develop and implement checksheets for the assigned auxiliary operator watch stations.

Response

A shift turnover sheet has been developed and implemented for all l auxiliary operator watch stations.

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Page 17 j - MAINTENANCE l The maintenance organization, preventive maintenance programs, maintenance procedures, maintenance history and administrative systems for. controlling and l documenting maintenance work and special processes were evaluated. The I methods used to control test equipment were reviewed, and the overall adequacy of the maintenance facilities and equipment was assessed.

The evaluation team noted that the. Periodic Activity Control (PAC) system in use has the potential to become a strong and comprehensive administrative tool in the work control, preventive maintenance and maintenance history programs.

An area where improvements are recommended includes a need for increased experience levels and qualifications of personnel. Additlonaliy, administrative programs need refinement.

• l MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 2)

An evaluation of this area was performed to assess how effectively the maintenance ad_ministrative programs and organization contribute to* the per-formance of maintenance tasks. Areas reviewed included organizational struc-ture, reporting requirements and practices, staff size, training and certain administrative programs.

1. Finding (Ref. Criterion B)

An insufficient number of experienced lnstrument and control (I&C) technicians are available to perform normally assigned duties. Of the ten technicians currently employed, four have work experience of six months or less. Palisades maintenance management has previously recognized these concerns and has initiated a formal skills training program to compensate for low experience levels of new workers.

Recommendation Action should be taken to fully implement training for existing plant technicians as recommended in TQ-211, Criterion D. Concurrent with actions to address recommendations made in MA-401, Criterion G, increased supervision. and attention should be made available to less

• experienced workers.

Response

The authorized staffing of the I&C work group has been increased from 12 to 19 with recruiting for the new positions in progress. All newly hired technicians will receive approximately three months of basic I&C technician training within 12 months of being hired. Simultaneously, steps are in progress to contract the adaptation of the Midland I&C technician training and certification program to Palisades. This project is projected to be completed by January 1, 1982, with upgrading of existing technicians and full implementation completed by January 1, 1983.

PALISADES (1981)

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2. Finding (Ref. Criterion G)

I&C supervisors are required to devote a significant amount of attention to non-supervisory tasks. Tasks such as maintenance order work planning, maintenance of portable laboratory measuring and test equip-ment records, procurement activities and upkeep of maintenance history records are diverting attention from supervisory activities. The rel-atively low* experience levels of existing I&C technicians and the proposal to add new technicians that will require additional supervision contribute to the significance of this concern.

Recommendation Concurrent with actions taken to address recommendations made in OA-

. 102, Criteria B and C, management should review the existing require-ments of I&C supervisors versus the job functions. Action should be taken to streamline the necessary administrative functions and to reduce or delegate tasks that can be handled by non-supervisory personnel.

Response

Effective June 1, 1981, a Plant Planning and Scheduling Department was established reporting to the Operations and Maintenance Superintendent.

Within this department will be one I&C planner and one material technician who will assume responsibility for job planning and material expediting to support work in progress or scheduled. The organizaton of the I&C Maintenance group will be revised by December 1, 1981, to increase supervisory time spent in the field; personnel recruiting is underway.

PREVENTIVE MAIN'rEN ANCE (INPO Procedure MA-402, Revision 1)

The evaluation of this area was performed to determine the effectiveness of the maintenance effort to optimize equipment reliability and performance. Preven-tive maintenance (PM) programs and activities were assessed to determine if they are well defined and effectively implemented. A part of the review was equipment included in the program, type and frequency of preventive mainte-nance and effectiveness of program control and coordination.

1. Finding (Ref. Criterion B)

No specific guidelines or criteria have been established that describe the type of equipment to be included in the PAC program for preventive maintenance. Although a large num.ber of instruments and equipment are specified for PM, several equipment items utilized to perform or satisfy regulatory requirements are not included. Additionally, some items whose reliability affect plant generation are not included.

Recommendation Establish specific criteria for items to be included in the PM program.

The equipment categories described in this performance criterion are suggested as a guide. Existing PM lists should be reviewed against the plant criteria and items added or deleted as appropriate.

Response

The Administrative Procedure governing this program was revised April 23, 1981 to define specific criteria for entering equipment into the

PALISADES (1981)

Page 19 preventive maintenance program. A more comprehensive revision to this procedure is under* development which will further update existing activities and identification of new activities to meet the stated criteria. This revision should be issued by October 1, 1981.

2. Finding (Ref. Criterion F)

The lubrication activities currently being performed are not comprehen-sively described by a formal program. Additionally, the listing of l lubrication specifications provided by the "Mobil Engineering Service Report" is subject to revisions without benefit of engineering reviews.

No positive controls *are established for revision and distribution of this 1 report.

A plant effort is underway to establish program controls by adding lubrication activities to the PAC listing.

l Recommendation

• Carry out plans to establish lubrication program requirements in the PAC system. Lubricant specifications should be reviewed for accepta-bility and formally approved prior tci use. The listing of authorized lubricants should be placed under document controls, and revisions to the listing should be subjected to engineering review and approval.

R~poIBe .

The Mobil Lubrication Manual has been incorporated into the plant document . control system in the Controlled -vendors File. Periodic activity X-TECH007 has been established to require a technical review J of this manual every 24 months. Development of PACs for individual component lubrication requirements - should be completed by August 1, 1981.

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3. Finding (Ref. Criterion G) .

The description of PM program responsibilities in administrative proce-dure Chapter 5.3, Rev. O, Periodic Activity Control Program, does not specify requirements for assessment of PM effectiveness, review and evaluation of corrective maintenance documents (for needed changes to l the PM program); for review and develop.ment of PM procedures; or for review of maintenance histories (for changes to PM). These functions are not being performed except on an informal and intermittent basis.

Recommend~tion Action should be taken to provide a more comprehensive description of PM program responsibilities. These- functions should be fully imple-mented as part of the overall PM program.

J R~ponse A comprehensive revision to Administrative Procedure 5.3 is under development that will assign responsibilities for the update of the PM j program including equipment history review and procedure update. This revision should be issued by October 1, 1981.

4. Finding (General Cri.terion)

A criterion under development calls for the PM program to be fully implemented as evidenced by good equipment condition and maintenance records. The I&C PM program is not fully implemented as evidenced by J

PALISADES (1981)

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deferred and backlogged work and by the condition of instruments and instrument systems external to the control room. Additionally, the PAC l program content for both maintenance and I&C is not fully utilized.

Palisades maintenance management has. previously recognized the con-cerns regarding I&C PM activities. The proposed actions to increase I&C l staff size arid to implement an I&C planning function should provide an opportunity to upgrade this area.

Recommendation l Ensure action taken fully implements needed PM activities. The content of the PAC listing should be subjected to a comprehensive review, and actions should be initiated to incorporate missing items. Those program features considered not desirable or optional should be specifically 1 identified in the administrative procedures.

Response

The size of the I&C staff is being enlarged to decrease the amount of 1 def erred and backlogged work. In addition, an I&C planning supervisor has been approved and will be added to the planning *and scheduling staff by July 1, 1981, to further increase emphasis of maintenance on all plant instruments. A comprehensive review of the PACs for plant instrumen-tation is in progress to ensure both frequency and adequacy of instru-ment PM are appropriate. The overall administration of this PM program is under review, and revision on the controlling administrative

• procedures will be completed by October 1, 1981.

MAINTENANCE PROCEDURES 1 (INPO Procedure MA-403, Revision 2)

This performance area was evaluated to assess the adequacy' of maintenance J procedures and the extent to which procedures are used. Procedures and manuals were examined to determine the types of activities covered, scope, level of detail, review and approval process, document control requirements and methods of revision.

1. :finding (Ref. Criterion A)

Procedures are not provided to guide preventive and corrective mainte-nance on some safety-related and critical non-safety equipment. Vendor manuals are sometimes referenced for work instructions, yet they are not specifically approved for use as procedures and are not subjected to effective document controls.

Recommendation Maintenance management should conduct a review of work activities not governed by procedures and take action to develop procedures for work on safety-related and critical non-safety equipment items. References to vendor instruction manuals should identify controlled manuals which have been subjected to an approvals review similar to that provided for plant procedures.

Response .

The Company has contracted a vendor to update existing maintenance

' J procedures that will incorporate applicable portions of the vendor's J

PALISADES (1981)

Page 21 manuals for specific maintenance activities. A follow-on contract will prepare maintenance procedures for selected maintenance activities for which procedures do not exist, with emphasis on critical non-safety 1 equipments. The initial portion of this effort should be completed by December 31, 1981, the second portion by December 31, 1982.

l 2. Finding (General Criterion)

A criterion under development states that maintenance procedures 1 should provide sufficient detail and guidance to ensure safe and reliable completion of work. This criterion also calls for a format to be utilized that is clear and consistent.

l The content of maintenance procedures does not provide good guidance for work. Additionally, the format of these procedures is not consistent.

Palisades maintenance management has recognized a need to upgrade the maintenance procedures. A contract is bein*g sought to provide technical writing services for reworking plant procedures. An assistant mechanical maintenance supervisor has been designated to coordinate this effort.

Recommendation Corrective actions should be implemented as needed to provide upgraded maintenance procedures.

Response _

Consumers has contracted ~ith a consultant to update existing mainte-nance procedures with_project completion scheduled for December 1982.

WORK CONTROL SYSTEM (INPO Procedure MA-404, Revision 1)

An evaluation was performed to determine the effectiveness of the work control system in use. The system functions were checked to see if they define and authorize work to be performed by the maintenan*ce groups; provide for planning, scheduling, and control of actual work; and have a mechanism to input the maintenance results into an equipment history file for future evaluation.

Finding (Ref. Criterion B)

Status of maintenance orders in the I&C area cannot readily be deter-mined. There is no closed loop feature to review backlogged mainte-nance orders as to cause of delays. The planning function is not formalized.

Recommendation Implement a planning system for I&C work that includes a capability for continuous status control of backlogged maintenance orders. The responsibility for planning should be assigned at an appropriate adminis-trative level. The planned addition of an I&C planner should provide an opportunity to &ddress these concerns.

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Page 22

Response

A Planning and Scheduling Department was established on June 1, 1981,

. which is expected to satisfy this criteria.

MAINTENANCE HISTORY (INPO Procedure MA-405, Revision 2)

An evaluation of this area was performed to assess the capability of maintenance history records to support evaluations of equipment performance. The review also checked for implementation of an evaluation program that contributes to improved equipment performance. Areas reviewed included an assessment of equipment items included in maintenance history; content and accessibility of records, history review and evaluation methods and procedures for program implementation. *

1. Finding (Ref. Criterion B)

In many cases the content of maintenance history documents provides insufficient detail of work performed and conditions contributing to equipment failure to allow meaningful analysis.

Recommendation Review existing administrative requirements for recording maintenance

. ] history, and take the riecess.ary action to clarify responsibilities and upgrade the level of _historical data being recorded. The proposed Maintenance Order format given in Revis.ion 5 of Palisades Administra-tive Procedure, Chapter 5 should provide for good historical detail if fully utilized.

J Response The revised maintenance order is being printed in bulk, and the revised Administrative Procedures (5.1 and 5.2) are expected to be implemented.

2. Finding (Ref. Criteria C and E)

No comprehensive guidelines or procedures are available that describe the methods and responsibilities for implementing the maintenance history programs. Additionally, maintenance history documents are not J

easily traceable for individual equipment items. A cross index capability is not effectively established, and files are not organized to facilitate retrieval of records.

Palisades maintenance management has previously recognized the need

• to upgrade the retrievability of maintenance records. A computer based data storage system is to be implemented which has the potential to J address the concerns in this area.

Recommendation A formal administrative procedure or guideline should be developed to describe the maintenance history program. This procedure should be J sufficiently comprehensive to describe history records format, responsi-bilities and access.

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PALISADES (1981) 1 ..

Page 23 Action should be taken to fully implement an improved system for tracing maintenance history.

l Response

• The requirements for maintenance history input are included in the revised maintenance Administrative Procedure governing the Main-l tenance Order and is scheduled for implementation by July 1, 1981. This revision will- incorporate broader use of the existing corporate micro-fiche record system, keyed to individual equipment and updated quar-terly. An advanced Maintenance Management System, incorporating use l of an online computer system, will be implemented on a companywide basis by the end of 1983.

l 3. Finding (Ref. Criterion D) .

No program for systematic review and evaluation of maintenance history has been implemented. There are instances of isolated equipment l history searches and reviews based on individual initiative and responses to special inquiries.

Recommendation Develop a maintenance management program for evaluating and trending equipment performance that includes responsibilities, equipment to be reviewed, frequency of reviews and scope of reviews. Follow-up actions to adjust PM activities, maintenance practices and operating practices should also be defined.

Response

The PAC program procedure, (Administrative Procedure 5.3) revised April 23, 1981, established criteria for including equipment in this pro-gram. A periodic review of these records will be included in the next revision to this procedure expected to be issued October 1, 1981.

CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION (INPO Procedure MA-406, Revision 1)

A review was made to determine the adequacy and effectiveness of methods used for calibration and control of test equipment and instrumentation. Specifi-cally, methods used for identifying, calibrating, storing, issuing, transporting and using measuring and test equipment were exan:iined. Procedures establishing and governing the calibration program and records were also reviewed.

1. Finding (Ref. Criterion F)

I&:C shop instruments, both controlled and non-controlled, are stored in a common storage location and in some instances are not protected from possible damage.

Recommendation Implement a system for storing measuring and test equipment so quality of equipment is maintained. Controlled and non-controlled equipment should be segregated.

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PALISADES (1981) l- Page 24

l. R~~~e storage space outside the I&C laboratory. Each shop instrument. is assigned a specific shelf location.

The I&C shop instruments have been relocated to a locked and controlled Controlled equipment usage is documented on both the maintenance order and in a usage log* controlled 1 by the I&C supervisor. While these instruments are stored in the same room, the shelv.es themselves are physically separated to prevent inad-vertent instrument mixing.

l 2. Finding (Ref. Criterion G)

No system is in effect for the issuance of I&C test instruments.

l Recommendation

• A method to control the issuance and unauthorized use of measuring and test equipment should be established.

l R~~~e An interim Usage Log has been instituted, which is maintained in the l&C laboratory and controlled by the I&C Supervisor, to control the removal of any test instrument from the laboratory. This will remain in

) effect until Maintenance Department work space modifications are

• completed in August 1981. One of these modifications is the establish-ment of a central Measuring and Test Equipment storage and issuance l facility.

1 CONTROL OF SPECIAL PROCESSES (INPO Procedure MA-407, Revision 1)

An evaluation was performed to determine if personnel are .qualified and

) procedures, equipment and material are controlled for the performance of special processes.

Finding J All criteria in this area were met.

• l MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Revision 1)

The evaluation of this area was performed to determine if facilities and J equipment provided for the maintenance organization effectively contribute to the performance of required tasks~ The location, size and condition of offices, work and storage spaces were examined. In addition, the number, type, condition and location of maintenance tools and equipment were reviewed.

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• Finding (Ref. Criterion C)

.The* size and_ arrangement of maintenance work areas and shops are l insufficient *to contribute to efficient

• performance of work. The maintenance facilities provide *limited* work space for existing mechani-cal, elect~ical and l&C groups .. This. deficiency will increase in signifi- *

• cance as the work force is increased to the authorized levels.

l Recommendation Palisades maintenance management *has previously recognized this con-cern and has performed a review of shop and office facilities. Action l should be taken to relieve the restricted conditions.

Response

The expansion of maintenance work space is in progress and will be l completed* by August 1, 1981, which will result in an increase of approximately 33% in both Electrical and Maintenanc.e shop space. A central Measuring and Test Equipment issuance* facility has been in-cluded as a part -0f this expansion. l&C lab space changes are complete.

l *Further maintenance work space requirements will be addressed as part of a total site facilities study to begin by July 1, 1981.

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Page 26 RADIATION PROTECTION AND CHEMISTRY.

l Radiation Protection and Chemistry *were evaluated by reviewing the perform-ance of radiological protection . training, dosimetry, internal and external radiation* exposure* control, radioactive waste, radioactive contamination control l and water chemistry control. This evaluation was primarily an examination of plant programs and* facilities as they function under normal (non-outage) conditions. A conclusion was made that the plant's radiological protection and l chemistry programs were adequate to protect the public, plant workers and the environment.

• The most significant areas of weakness were the lack of a training program and l an inadequate number of permanent plant employees in the chemistry and radiation protection sections.

• 1 A number of good practices were observed in radiological protectio_n, speci-fically: a com~itment to improving cleanliness and reducing contamination levels in the radiologically controlled areas of the plant; maintaining liquid effluents effectively at essentially "zero" release; strict standards for posting of radiation and contamination areas within the plant; and effectively controlling personnel exposures at the plant (no individual received radiation exposure in excess of four rem during calendar year 1980).

There were several areas where the plant could improve the radiological protection performance.

• l RADIATION PROTECTION AND CHEMISTRY ORGANIZATION AND ADMINISTRATION j (INPO Procedure* RC-501, Revision 1)

An evaluation was performed to determine the effectiveness of- the radiological I protection and chemistry organizations and their associated administrative controls. This area was evaluated by reviewing training plans and records for radiological protection and chemfatry technicians, interviewing radiological protection technicians, reviewing records of audits and appraisals performed by other organizations along with corr-ective actions taken and. a review of the health physics and chemistry organization.

1. Finding (Ref. Criterion C)

The plant currently has numerous unfilled chemistry and radiation protection technician positions which cause a general lack of plant specific experience within the radiation protection staff.

Recommendation Management action should be taken to develop and implement a program to_ maintain adequate staffing levels of. qualified, permanent chemistry and radiation protection technicians.

Response . . . . .

Management has implemented a program to reach and maintain staffing levels needed_ to achieve a high quality Chemistry and Health Physics Program. Major elements of ~his program are:

-:j PALISADES (1981)

Page 27 o modified staffing levels based on a job analysis of supervisory, professional and technician staff. needs; l o o

o technician candidate screening; formal training of technicians;

• formal qualification of technicians.

l Compared with 1980 levels, a 70% increase in staffing has been incorporated in plant staffing authorization. Emphasis in recruiting and hiring has been on identifying candidates with previous science training l and the necessary aptitude to grow rapidly in the job. About one year will be needed to attain the intended staffing levels.

l 2. Finding (Ref. Criterion D) .

Technicians have not received practical training other than on-the-job experience. They do not receive reactor plant systems training nor l

• training in specific plant procedures. The plant has made plans to implement a training program during the second quarter of 1981.

Recommendation Develop a training program that . provides theoretical and practical training for permanent employees. Additionally, site-specific training should be given to any contract technicians employed.

Response

l An eleven week curriculum of plant systems training and training in theoretical and applied chemistry and health physics has been developed with cooperation from an experienced consultant firm. This training began in June 1981, and will be available on a recurring basis from the J *Nuclear Operati.ons Training Department. Follow-up training, stressing in-depth practical knowledge, is being developed for pr.esentation to l more experienced technicians and will begin in late 1981.

• Site-specific training for contract technicians is being developed in advance of the forthcoming refueling outage (August Hl81). Results of this effort will be reviewed~ and a standing procedure for such training prepared.

3. Finding (General Criterion)

The various administrative and working level procedures that describe and implement the utility and plant radiological protection programs are not being effectively maintained. Specifically, procedures exist that cover the same subject matter but were promulgated at different management levels. These procedures contain inconsistencies. Proce-dures describing the mechanics of program implementation are not sufficiently comprehensive for some programs, such as personnel dosi-metry and skin contaminations. It is . recognized that the plant has initiated a comprehensive review of . the existing plant radiological protection procedures.

Recommendation In. the current review, ensure the following actions are included:

o Procedures* and* instructions should be written so they can be strictly enforced. If adherence to a particular procedure is impractical, the procedure should be revised.

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PALISADES (1981)

-; Page 28 o Responsibility for the long-term review and maintenance of each radiological protection procedure. should be assigned to appropriate l Response staff members.

A comprehensive health physics program revision is in progress. Included in this effort are all Consumers Power* Company's health physics l . activities. Ma,jor elements of this program are:

o development of a corporate radiation safety standard emphasizing health *physics standardization among the Company's nuclear 1 facilities;

• o Palisades-specific procedures in support of the corporate standard, 1 including revision, expansion or. development, as_ needed for ex-isting procedures; l

• o identification of specific recommendations for action to implement the new radiation safety standard.

Completion* of these reforms is essential to our goal of increased

_ formality in procedural compliance. In the interim, supervisory person-nel have been instructed to initiate temporary changes to those pro-cedures implementing current policies containing significant deviations from practice or inconsistencies with other procedures. These revised program will be in effect by April 1982.

I I ALARA PROGRAM (INPO Procedure RC-502, Revision 1) .

An evaluation was performed to determine the effectiveness of effort's toward maintaining personnel occupational radiation exposure as low as is reasonably achievable (ALARA). Areas evaluated included the company's ALARA policy, responsibilities for ALARA, level of review for the ALARA program, systems for setting goals and measuring progress and overall scope of ALARA activities.

Finding (Ref. Criteria B, C, D and E)

The plant did not have a separate, formal ALARA program; however, the radiological protection activities reviewed included some elements of an informal ALARA program. The util{ty had recognized the need for development of a formal ALARA program and, at- the time of the evaluation, had formed a plant ALARA committee. The committee, comprised of management personnel from the radiation protection, maintenance, and operations organizations, has been involved principally in reviewing selected jobs. In addition, a project team has been established* to study available options and make recommendations for a corporate and plant ALARA program.

Recommendation Continue development* of the formal ALARA program as planned, stressing involvement of corporate management as well as plant super-vision, operation and maintenance personnel in the overall ALARA

.J program.

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l Response The comprehe_nsi.ve* Corporate Radiation Safety Standard currently being developed details the ALARA program with assignments .of duties and responsibilities. This program will be* promulgated with full corporate commitment by January l, 1982. The scope of the current selected

. ALARA efforts is being steadily increased as staff is added.

PERSONNEL DOSIMETRY l (INPO Procedure RC-503, Revision 1)

An evaluation was performed to *determine. the effectiveness of the plant's dosimetry program in measuring, evaluating and recording occupational radiation l exposures. Areas examined included the scope of the dosimetry program, procedural controls, dosimetry selection and use, system operation and exposure records.

Fjnding (Ref. Criterion D)

Deficiencies exist in the quality controls for the dosimetry program.

Specifically, the method used and the acceptance criteria for correlation of thermoluminescent* dosimeters (TLD) and pocket dosimeters (PD) were not documented.

RecommendatiOn

• Formally document qua~ity control procedures for correlation of TLDs and PDs.

Resp0nse Quality control procedures for correlation of. TLDs and pocket dosi-meters will be promulgated by August 1, 1981. Documentation of resolution in cases where correlation is unsatisfactory will be provided.

I RADIATION SURVEILLANCE AND CONTROL (INPO Procedure RC-504, Revision 1)

.. An evaluation was performed to determine the effectiveness of the plant's radiological surveillance program and radiological work control mechanisms in identifying and minimizing radiological hazards to workers and management.

Areas of interest included surveillance program procedures, surveillance program scope, radiological conditions in the plant, surveillance methodology, level of management review of surveillance data and controls placed upon access to and from work .areas.

Finding.

All criteria in this area were met.

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. Page 30 I

I WASTE AND DISCHARGE CONTROL (INPO Procedure RC-505, Revision 2) l Tl:lis area was evaluated to determine if there is a system of controls that will minimize the generation of radioactive waste, reduce the likelihood of having an inadvertent release and detect the presence of contamination in systems where l there should be none; This area was evaluated by reviewing records of solid, liquid and gaseous wastes,* tours of areas containing waste processing systems and waste discharge monitors and tours of the radiochemistry laboratory.

1 Finding (Ref. Criterion E)

Radioactive waste system maintenance* personnel, chemistry and _radia-l tion protection personnel have not received training other than on-the-job experience.

Recommendation A training and qualification program for radioactive waste system l maintenance, chemistry and radiation protection personnel should be developed and implemented in a timely manner.

Response

I Training in radioactive waste systems is one part of a systems training

- program under development. This program will be tailored to the individual work group, i.e., operations, maintenance and technician em-l ployees so as to provide appropriate emphasis on each work group. It is expected to be fully implemented by June 30, 1982. .

RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)

An evaluation was performed to de:termine the effectiveness -of the plant's J radiological survey equipment control and calibration program in maintaining a sufficient inventory of instruments and a high degree of accuracy for radiologi-cal measurements. The evaluation covered procedures, storage conditions, reference standard traceability, operational response checks, equipment identifi-cation and evaluations for out-of-tolerance equipment.

• 1 Finding (General Criterion) 1 It was found that the methods employed for calibration and performance testing of radiation protection in.struments were not appropriate in the following cases:

o Beta Standardization Ion chamber instruments* used for b*eta radiation surveys were not

_standardized against a beta radiation source.

o Inadequate Radiation Standard The Cs-137* well. source used for calibrating radiation survey instruments has a maximum output of 9R/hr. and is therefore not I capable of delivering the exposure rates necessary for calibration of high range portable instruments.

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PALISADES (1981)

' Page 31 l.

Recommendation Calibration and performance testing of radiation protection instruments should be improved to be adequate for the .application of the instrument.

Response ..

A beta radiation standardization source is under procurement. Cali-l bration procedures for beta radiation survey meters will be revised to make use of this source. The status of instrumentation calibration methods for high range portable instruments is being reviewed by a knowledgeable consultant. **A method for achieving the recommended 1 practice will be chosen and. will be part of the corporate standard on radiation protection instrumentation for high range instruments at all Consumers Pow.er Company nuclear facilities.

l PERSONNEL HEALTH PHYSICS INDOCTRINATION (INPO Procedure RC-507, Revision 2)

An evaluation was performed to determine the effectiveness of the plant's health physics indoctrination program. This area was evaluated by observing the training presented to personnel who enter radiologically controlled areas. Find-ings were as follows:

1. Finding (Ref. Criterion B)

The general employee. training that is used to instruct workers in radiological protection fundamentals is de_ficient in content and quality, specifically:

o No instruction is given concerning the selection and use. of portable radiation survey equipment.

1 o No practical training is provided in donning and removing protective clothing.

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I o No consistent instruction is given pertaining to the protection of fertile or pregnant women.

Recommendation Revise the general employee* trainirig program to include these omis-sions.

I Response I I o The General Employee Training (GET) program will be modified to I j include a demonstration on the selection and use of portable survey equipment.

o While the videotape used. for the GET program does demonstrate the donning of protective clothing, additional hands-on instruction and practical training on the use of this clothing will be provided to those employees who have a reasonable probability of entering radiologically controlled spac"es.

• . o Disciplined, consistent training material is now available to provide 1 necessary fertile female training. The most appropriate format for j'

PALISADES (1981)

Page 32 presenting this material will be determined in the program imple-mented by July 31, 1981.

l 2~ Finding (Ref. Criterion D)

No lesson* plans and no provision to revise and update the general l employee. training program are available.

general employee training are outdated.

The videotapes used for Recommendation 1 Develop approved lesson plans to ensure consistent training, and establish a method to revise and update the general employee training program to ensure the training reflects actual practices in the plant.

Response .

• 1 Lesson plans for GET will be documented in a training manual by December 31, 1981. A formal procedure to revise *anci update GET training to reflect changes in plant practices will be incorporated within 1 *Plant Administrative Procedures.

PROCESS WATER CONTROLS .

(INPO Procedure RC-50&, Revision 2)

An evaluation was *performed to determine the e(f ectiveness of plant process water controls in maintaining the integrity of plant systems. Areas reviewed included procedures; laboratory* quality control; bulk chemical, cleaning agent and reagent control; training; and systems chem1stry. Process water controls appeared to be effective in minimizing corrosion.

Finding All criteria in this area were met.

HEALTH PHYSICS FACILITIES AND EQUIPMENT (INPO Procedure RC-509, Revision 2)

An evaluation was performed to determine the adequacy of the plant's chemistry and health physics facilities and equipment* in satisfying plant needs and in contributing to safe and efficient plant operation. This area was evaluated by tours of the health physics facilities, chemistry laboratories, counting rooms, primary auxiliary b1:1ilding and turbine building.

J Finding (Ref. Criterion C)

Various health physics and chemistry facilities were inadequate from an environmental and design viewpoint, specifically:

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'i PALISADES (1981)

Page 33 o Chemistry Counting Rooms l The chemistry counting rooms were not equipped with the appro-priate environmental control systems to support the computer*

based counting equipment in use.

l o Decontamination Facilities Decontamination of components and equipment is performed in 1 areas not designed for this task.

o South Radwaste Storage Building l Poor drainage existed outside the building, whicb resulted in the south radwaste storage building being flooded during periods of heavy rainfall.

1 o North Warehouse The north warehouse used to store contaminated tools and equip-ment provides inadequate controls for this use; i.e., there is no warehousing program effectively implemented.

Recommendation o Chemistry Counting Rooms Increase the capacity of existing air conditioning units or install separate instrument envir"onmental enclosures.

o Decontamination Facilities An area or room with appropriate radiological controls should be designated for use when decontamination of components and equip-ment is necessary.

• o South Radwaste Storage Building An engineering study should be conducted and corrective action taken* to ensure the drainage is adequate to preclude water entering the building.

o North Warehouse Implement a warehousing *program to enable prompt retrieval of items in the contaminated storage area as well as adequate control of contaminated equipment and components in storage.

Response

The specific issues identified_ in this finding are a subset of the broader issue of overall site facilities. A Site Facilities Study has been initiated to review all existing on-site _facilities for adequacy as well as future facilities that may be required. This study is expected to be completed by January 31, 1982.

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PALISADES (1981)

Page 34 RESPffiATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2) l An evaluation was performed to determine the effectiveness of the plant's respiratory protection program in protecting personnel from airborne radioactiv-l ity. Areas reviewed included policy and procedures, identification and control of airborne radioactivity, selection* and use of respirators, respirator maintenance and emergency capabilities. The plant program was judged to be adequate for the protection of personnel from known hazards.

Finding All criteria in this area were met.

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Page 35 TECHNICAL SUPPORT 1 An evaluation was performed to determine the effectiveness of the on-site engi-neering support group in resolving problems and concerns of a technical nature.

Areas reviewed included organizational structure, size, assignment of responsi-l bilities and effectiveness of coordination with other groups. Programs for control of design changes, on-and off-site incident review,* plant performance monitoring, reactor engineering and other sucn engineering activities were also l reviewed.

There was evidence that management has reviewed the effectiveness of the engineering support activities* and initiated beneficial organization and program l changes in several areas. More changes have been planned for the future.

• TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION _

(INPO Procedure TS-701, Revision 1)

The team evaluated the Technical Department to determine if it is capable of performing all assigned responsibilities, personnel are knowledgeable of their duties~ a training program exists to enhance and develop the skills and knowledge of personnel and non-technical personnel are utilized for administrative or clerical functions.

1. Finding (Ref. Criteria *B and E)

A large backlog of incomplete *and inactive engineering projects exists as well as some important *inactive engineering programs. Most technical personnel do filing and other clerical functions that could be done by

• non-technical personnel.

Recommendation An evaluation of the duties, responsibilities and personnel assigned to the Technical Department should be made, and the results should be used to correct the problem of the large backlog of incomplete and inactive engineering programs and projects.

Response

An evaluation of the Technical Department has been completed resulting in reorganization into the following systems areas: Mechanical (B-0-P and Primary), Electrical/I&C, Reactor/Fuels, Chemistry/Radwaste, and

• Performance. Additionally, budget approval has been obtained for an

-~ Engineering Analyst, Engineering Technician-Draftsman, Clerk, and en-gineers. We will initiate a bi-monthly management review of the engineering project backlog to ensure proper priorities and resource control. An additional evaluation of the Technical Department will be conducted by the Plant Management six months after the next refueling outage.

2. Finding (Ref. Criterion D)

The Technical Department does not have a technical training program in effect to aid in the development of personnel.

PALISADES (1981)

Page 36 Recommendation Training needs of personnel wi.thin the Technical Department should be evaluated and additional training provided as required. The evaluation 1 should consider the need for training in the following areas:

o plant systems and components; l o areas requiring specialized engineering knowledge* or skills; o effective management techniques.

1 Response o A pressurized water reactor (PWR) technology course, designed for newly assigned engineers, has been developed and will be implemented 1 by September 30, 1981. This course is intended to teach generic PWR systems; Specific plant systems training will be made available in conjunction with a systems training program under development and 1 scheduled for completion June 30, 1982.

o An engineer career development* program is being developed that will I identify duty assignments in an orderly progression through the depart-ment head level. . This program should be published by October 31, 1981 and immediately implemented. A part of this program will provide for specialized tra!ning for engineers .

. o The company has always had management training courses available.

A conceded effort will be made over the next 18 months to ensure more plant engineers attend* these courses.

ENGINEERING SUPPORT (INPO Procedure TS-702, Revision 2)

The team examined plant thermal performance monitoring, communication with other groups, document control systems and the engineering support facilities.

1. Finding (Ref. Criterion A)

• The station does not have a program for assessing and improving plant thermal performance.

Recommendation A comprehensive program should be developed and implemented for plant performance monitoring with an objective of improving the plant operating efficiency and reliability.

Response

Recent organization changes in the Technical Department has estab-lished a separate performance .section. Plant thermal performance has been loosely monitored by Chemistry, Operations and the ~eactor Engineer; however, no overall program exists. We will have developed and implemented an assessment and improvement program within six months after the 1981 refueling outage.

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Page 37 I

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2. Finding (Ref. Criterion D)

Some drawings that are sent to. corporate headquarters to be revised and 1 -issued are not completed in a timely manner.

Recommendation Additional effort should be made at corporate headquarters to revise and issue all drawings in a timely manner. The station's effort to correct l their control documents requires additional support at the corporate level to be effective.

Response

l Reorganizations in the Gener_al Office in the last two years have resulted in a greater emphasis on the control engineering records. The Engi-neering Records Center (ERC) has been separated from other document control activities. The ERC is streamlining their QA procedures in an 1 effort to expedite the updating of revised plant drawings ("redlines").

Additional technical drafting staff has been provided to complete drawing revisions in a more timely manner. -

Instances of "lost" drawings will be corrected by December 31, 1981, by using plant and ERC staff to walkdown the affected systems and prepare new drawings.

NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision* 1)

The team examined the program for handling fri-house and nuclear industry operating experiences, utilization of experienced technical personnel, periodic review of program effectiveness and periodic independent evaluation of industry experiences to verify proper classification.

Finding (Ref. Criteria D and E)

The existing program does not ensure that the information disseminated to plant personnel is timely, applicable and/or not contradictory.

Recommendation The existing program should be revised to ensure that information disseminated to plant personnel is timely and applicable.

Response

..' The existing program will be upgraded by including the requirements for a nuclear operating experience evaluation program within the Nuclear Operations Department Standards Manual. This manual will be com-pleted by March 31, 1982. This particular standard will define the documents or information to be evaluated, responsible individuals and methods for providing feedback to affected plant and General Office departments.

In the interim Consumers Power will rely upon the diverse reviews of operating events by General Office and plant personnel to accomplish nuclear operating experience evaluations.

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Page 38 PLANT MODIFICATIONS (INPO Procedures TS-704, Revision 1) l The team examined the method for control and processing of plant modifications to determine if they are implemented in a timely manner and if they maintain the proper quality of plant systems, components, procedures and training.

l Finding (Ref. Criterion I)

Operator training may not be _completed prior to a modified system being I returned to service, and some final design documents are not revised and issued in a timely manner.

Recommendation

• The present program should be revised *to ensure that appropriate l training and information has been provided to the operators prior to placing a modified system in service. Consideration should be given to the preparation of an operational description or summary for each modification to aid operations personnel. The present program should

1. also be revised to require timely revision and issuance of drawings affected by plant modification.

Response

The present administrative control requires project engineers to provide information to training and operations at the appropriate time during a modification proj~ct. Review of this method determined that a more formalized method was required. A procedure change to provide a summary in appropriate detail has been implemented. The Training Department will document training given to address facility changes.

Drawings for modifications controlled on-site are issued in a timely manner. For modifications controlled off...:site, revisions are being made to both the start-up manual and a new construction/operations interface policy to require sufficient copies of applicable drawings prior to placing modified systems in service.

ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2) l I

• .* The team examined procedures, availability of an off-site computer, communica-tions with other groups, fuel integrity commitments and refueling activities.

Finding (Ref. Criterion B)

There is not a backup analytical technique to determine a number of core parameters when the plant's data logger is out of service.

Recommen<;)ation A backup analytical method or equipment should be provided to deter-mine all core parameters required .by the plant's technical specifications and/or safety considerations.

Response

A backup analytical method known* as power distribution control, which has been developed, allows the plant to operate at full power should the data logger be out of service. Analysis by Exxon has been completed, J *~

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Page 39 I

I . and the technical specifications change to utilize the power ratio recorder for the next cycle is presently in the initial stages of review for submittal t<? the NRC by Augul?t 31, 1981.

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APPENDIX Page 1 ADMINISTRATIVE APPENDIX l

I: LISTING OF AREAS TO BE EVALUATED ORGANIZATION AND ADMINISTRATION OA-101 Objectives OA-102 Organization Structure OA-103 Administrative Controls OA-104 Quality Programs OA-106 Industrial Safety OA-107 Surveillance Program l OA-108 Personnel Qualifications II TRAINI~G AND QUALIFICATION TQ-211 Training Organization and Administration TQ-221 Training Resources TQ-231 Training Effectiveness TQ-242 Non-Licensed Operator Training TQ-243 Licensed Operator Training TQ-244 Licensed Operator Requalification Training TQ-245 Shift Technical Advise~ Training OPERATIONS OP-301 Conduct of Shift Operations OP-302 Tagout Practices OP-303 Operations Organization and Administration OP-304 Use of Procedures OP-305 Plant Status Controls OP-306 Operations Facilities and Equipment OP-309 Shift Turnover

• • • MAINTENANCE MA-401 Maintenance Organization and Admin.istration I MA-402 MA-403 Preventive Maintenance*

Maintenance Procedures MA-404 Work Control System MA-405 Maintenance History J MA-406 Control and Calibration of Test Equipment and Instrumentation MA...:407 Control of Special Processes MA-408 Maintenance Facilities and Equipment J

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APPENDIX Page 2 RADIATION AND CHEMISTRY

") RC-501 Radiation. Protection and Chemistry Organization and Administration RC-502 ALARA Prograrn RC-503 Personnel Dosimetry l RC-504 RC-505 Radiation Surveillance and Control Waste and Discharge Control RC-506 Radiological Survey Equipment Control l and Calibration l RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment 1 RC-511 Respiratory Protection Program 1! TECHNICAL SUPPORT T&-701 Technical Support Org.anization and Administration T&-702 Engineering Support T&-703 Nuclear Operating Experience Evaluation Program T&-704 Plant Modifications T&-705 On-Site Reactor Engineering J

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APPENDIX Page 3 II. CONSUMERS POWER COMPANY PERSONNEL CONTACTED 1 Chairman and President . .

Executive Vice President, Energy Supply* Department l Vice President, Nuclear Operation Department General Manager Director, Nuclear Operations Training Department l Operations and Maintenance Superintendent Technical Superintendent Chemistry and .Health Physics Superintendent Operation Superintendent 1 Maintenance Superintendent Quality Assurance Superintendent Adm inistra ti ve Supervisor Property Protection Supervisor Operations Supervisor Personnel Director Senior Technical Analyst Nuclear Technical Engineer Technical Engineer Senior Engineers Shift Technical Advisors Shift Supervisors Outage Control Supervisor

• Mechanical Maintenance Engineer 1 Mechanical Maintenance Supervfaor Assistant Mechanical Maintenance Supervisor I Training Supervisor Electrical Maintenance Supervisor Instrument.and Control Maintenance Engineer Instrument and Control Maintenance Supervisor Assistant Instrument and Control Maintenance Supervisor Maintenance Planner Corporate Health Physicist Health Physicist Radiation Protection Supervisor Plant Health Physicist Dosimetry Laboratory Supervisor Radioactive Materials Control Supervisor Document Control Supervisor Control Operators Auxiliary Operators Training Instructors Instrument and Control Technician Chemistry Technician Outage Technician Radiation Protection Technician Operations Clerk Technical Clerk Dosimetry Clerk Maintenance Clerk Planning Clerk J

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APPENDIX Page 4 II. CONSUMERS POWER COMPANY PERSONNEL CONTACTED (Cont'd) l Mechanical Repairman "B" /*

l Welder "A"

• I Electrician "A" l

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• part1allysuppor1ed by ass*slance lromthe Tennessee Valley Author11y !TVA) a Federal agency Under Title VI ol lhe C1\11I R1gh1s Acl ol 1964 and app11cable TVA regu1a11ons no person shall on lhe grounds or race. color or na11onar ong1n. be excluded lrom pan1c1pahon m. be denied !he benehls ol. or be olherw1se sub1ected to d1scnmma11on under !his program II yo1.1 leel you have been excluded from parhcipa11on 1n denit>d the benelils or or othpr.,..1se sub1P.cted 10 d1~rim1na11on uNJcr this program on lhe grounds ol race. COIOr or national ongrn. you or your represenlahYe ha11e the r1qhl lo l1le a wnrten complain/ w1rh TVA no/ later man 90d~ys from the dayot /he a11e9edct1sct1mm~:1.vi The comp..unt st'oOuld be sent to Tennessee va:iey Authority Ottice ol Equal Employmenl Oppor1uMy. 400 Commerce Avenue. EPB 14, Knoxville. Tennessee 37902 The applicable TVA regu1a11ons appear m Pan 1302 ol Tille 18 or the Code ol F e<:1era1 Regulal!Ons A copy ol !he regula!ions may be obtained on requesl by wr1t1ng TVA at !he address given above.

• J Prmled in USA