ML20070Q735

Evaluation of Point Beach Nuclear Plant,1982

ML20070Q735
Person / Time
Site:	Point Beach
Issue date:	12/31/1982
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
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ML20070Q709	List: ML20070Q704 ML20070Q735
References
NUDOCS 8301270156
Download: ML20070Q735 (37)

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i. 1982 Evaluation

! Point Beach Nuclear Plant

. wisconsin Eec:ric

Power Com3any

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EVALUATION of PODIT BEACH NUCLEAR PLANT Wisconsin Electric Power Company December 1982

POINT BEACH (1982)

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SUMMARY

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INTRODUCTION .

, s The Institute of Nuclear Power Operations (iNPO) conducted an evaluation of Wisconsin ,

Electric Power Company's (WE) Point Beach Nuclear Plant curing the weeks of August 23 and August 30, 1982. The station is located on the west shore of Lake Michigan,

_approximately 10 miles north of Two Rivers,' Wisconsin. Unit No. I began commercial operation'in December 1970, and Unit No. 2 began commercial operation in October-1972.

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PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of documentation.

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

ations, maintenance, technical support, training and qualification, radiological pro-tection, and chemistry. The team also observed the actual performance of selected evolutions and surveillance testing. Corporate activities were not included in the scope of the evaluation, except as an incidental part of the station evaluation. As a basis for the evaluation,INPO used performance objectives and criteria relevant to each of the areas examined; these were applied and evaluated in light of the experience of team members, INPO's observations, and good practices within the industry.

INPO's goal is to assist member utilities in. achieving the highest standards of excellence in nuclear plant operation. The recommendations in each area are based on best practices, rather than minimum acceptable standards or requirements. Accord-1.. ingly, areas where improvements are recommended are not necessarily indicative of l unsatisfactory performance.

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DETERMINATION i

Within the scope of this evaluation, the team determined that the plant is being i operated in a safe manner by well qualified personnel The following beneficial practices and accomplishments were noted:

Strong involvement of managers and supervisors in day-today plant activities is evident.

Plant personnel display a positive attitude, good morale, and high productivity.

, The station has an impressive availability and capacity factor record.

l Material condition and cleanliness of the plant are impressive.

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. POINT BEACH (1982)

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-. improvements were recommended in a number of areas. The following are considered to be among the most important:

-Increased emphasis is needed in attention to detail in maintenance activities.

Prededural guidance and documentation should be upgraded in several areas.

Increased adherence to proper radiological protection practices and procedures is needed.

In each of the areas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of 4

this evaluation e.re listed in APPENDIX II.

Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to I

which they pertain. Particularly noteworthy conditions that contribute to meeting PERFORMANCE OBJECTIVES are identified as Good Practices. Other findings describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It

. would not be productive to list as Good Practices those things that are commonly done

- properly in the industry since this would be of no benefit to WE or to INPO's other member utilities. As a result, most of the findings highlight conditions that need aprovement.

l The recommendations following each finding are intended to assist the utility in ongoing m

' efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations, the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.

As a part of the second and succeeding evaluations of each station, the evaluation team

will follow up on responses to findings in previous reports. Findings with response actions scheduled for future completion have been carried forward in APPENDIX I to i this r6 port. In weas where additional improvements were needed, a new finding that stands on its own merit has been written. Thus, this report stands alone, and reference to previous evaluation reports should not be necessary.

The findings listed herein were presented to WE management at an exit meeting on September 2,1982. Findings, recommendations, and responses were reviewed with WE management on November 30,1982. Responses are considered satisfactory.

To follow the timely completion of the improvements included in the responses, INPO

, requests a written status by July 1,1C83. Additionally, a final update will be requested six weeks prior to the next evaluation.

The evaluation staff appreciates the cooperation received from all levels of Wisconsin Electric Power Company.

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1 POINT BEACH (1982)

Pg63 WISCONSDi ELECTRIC POWER COMPANY Response Summary ,.

Wisconsin Electric Power Company (WE) is pleased to have had INPO conduct an evaluation of site activities at the Point Beach Nuclear Plant (PBNP). We acknowledge the great deal of time and effort expended by the evaluation team, and express our appreciation for minimizing the impact upon plant operations. The evaluation identi-fled areas where we can specifically improve on the goal to excellence while other findings reemphasized our ongoing efforts toward improvement.

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We appreciate 'he comments given as " beneficial practices and accomplishments," the findings of " Good Practices," and acknowledge the recommendations for improvements.

. A direct response to each identified concern has been provided, and evaluations of findings will continue to determine if any additional underlying causes exist. Several of our responses indicate that actions have not yet been completed, but are planned or in progress. We will report the status of all newly completed and open items by letter to INPO before April 1,1983. This report will include projected future completion dates for all open items.

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POINT BEACH (1982)

Page 4 ORGANIZATION AND ADMINETRAMON 81AMON ORGANIZATION AND ADMDilSTRAMON PERPORMANCE OBJECMVE: Station organization and administrative systems should ensure effective implementation and control of station activities.

Finding 'Ihe following Good Practice was noted: 'Ihe assignment of (OA.1-1) operating shift personnel as system experts on plant systems results in ocetinuity of knowle%e being maintained on tham systems. 'Ihis knowledge is utilized effectively in monitoring, troubleshooting, maintenance, and modification activities.

Finding Increased attention to detail by plant personnel is needed in some (OA.1-2) areas. Specific areas include the following:

a. work-related activities such as control of weld materials, reinstallation of fasteners, and completion of required documentation

b. adherence to proper radiological protection practices and procedures Recommendation Managers and supervisors should increase day-to-day emphasis on those areas enumerated above. The increased emphasis should include more detailed observations of plant activities.

Response It is the philosophy of WE to play close attention to detan and have l

l plant management actively involved in all phases of operation on a daily basis. This philosophy has been a majcr contributing factor in the past record of good performance and high plant availability and will continue to be emphasized.

In addition, substantial personnel increases have recently been made to the Engineering, Quality & Regulatory Services Group, which is the in-plant QA group, in an even greater effort to improve the surveillance of activities and adherence to adminis-trative procedures by all personnel.

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e POINT BEACH (1962)

Page 5 MB8 ION, GOALS, AND OBJECTIVES PERFORMANCE OBJECTIVE: Station mission, goals, and objectivps should be estab-lished and progress monitored through a formsl program.

Finding Development and implementation of the station goals and ob-(OA.2-1) joetives program need to be completed. A method of reporting and tracking goal achievement needs to be included in order to monitor program success.

Recommendation Prepare and distribute goals and objectives for the station. Devel-cp a method for reporting and tracking progress toward goal and objective achievement.

Response WE has a companywide Management By Objectives (MBO) program and FBNP is included as part of the Nuclear Power Department.

Eight departmental objectives were issued on February 15, 1982; sevea involved PBNP. The program has focused on goals and objectives for responsible individuals, and the 1983 goals for plant Individuals are now being completed.

Coordinated, formalized station goals and objectives to support the corporate MBO program will be developed when the new corporate objectives are formalized in December 1982.

MANAGEMENT ASSESSMENT AND QUAIMY PROGRAMS PERFORMANCE OBJECTIVE: Management should assess station activities to ensure and enhance quality performance of all aspects of nuclear plant operation.

Finding The following Good Practice was noted: Operational parameters l (OA.3-1) are effectively trended to allow the timely identification and resolution of problems. For example, containment parameters, Including particulate and gaseous activity, humidity, and service water temperature are graphically monitored and reviewed each shift. As a result, potential problem areas are detected in a timely manner and early corrective actions are initiated.

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Page 6 GPERATIONS CONDUCT OF OPERATIONS PERFORMANCE OBJECTIVE: Operational nativities shculd be conducted in a manner that mehleves safe and reliable plant operatka.

Finding De following Good Practice was noted: he station has a policy of (OP.2-1) initiating prompt eerrective action to minimize continuous alarms in the control room. It was observed, during a number of tours through the control room, that activated alarms were minimized.

PLANT STATUS CONTROLS PERFORMANCE OBJECTIVE: Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.

Finding The current Efted wires, jumpers, and bypass program needs (OP.3-1) improvement. Wirca are not always lifted and identified in accordance with administrative procedures. Additionally, the audit of lifted wires, jumpers, and bypasses does not include a physical

, check of the tag and component position. -

Recommendation Emphasbs adherence to administrative procedures for the control of lifted wires, jumpers, and bypasses with all operators. Revise the administrative procedure to include a physical check of tags and component position in the audit of lifted wires, jumpers, and bypasses. INFO's Good Practice OP-202, " Temporary Bypass, Jumpers, and Lifted Lead Control," could be of assistance in this effort.

Response Adherence to the administrative procedures for lifted wires, jum- l pers, and bypasses will be stre:: sed with all operators. The adndnistrative procedure will be revised to require, on an annual basis, a re?!ew of the continued applicability and a physical check for all outstanding items in the log. The revision should be completed by March 1,1983.

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POINT BEACH (1982)

Page 7 OPERATIONS PROCEDURES AND DOCUMENTATION PERFORMANCE OBJECTIVE: Operational procedures and documents should provide appropriate direction and should be effectively used to agport safe operation of the plant.

Findird Improvements are needed in the the tagging system. Some tegouts (OP.5-1) are not being performed in accordance with the Equipment Isola-tion Procedure. Additionally, a periodic physical check of all tags and component positions is not required or performed.

Recommendation Emphasize adherence to the Equipment Isolation Procedure. Ex-pand the present tagout audit to include th? following:

a. a review of the tag index

b. verification of,the adequacy of tagouts

c. a check of the condition of posted tags

d. verification of proper attachment of tags and position of tagged equipment

e. a check for the presence of unauthorized tags

f. a check for tagouts remaining in effect beyond their need INPO's Good Practice OP-203, " Procedures for Protection of Employees Working on Electrical and afechanical Components,"

could be of assistance in this effort.

Response Some administrative aspects of the procedure have been identified that were a problem, and consequently a major revision was issued and implemented on October 1,1982 to address the INPO recom-mendations. The revised form and procedure will help clarify the troublesome administrative aspects.

Finding 1%mtrolled notes, graphs, portions of prowJures, labels, and (OP.5-2) sketches are posted throughout the plant. A methed is needed to authorize and update these operator aids.

Recommendation ' Implement an administrative program to control posted operator '

aids. This program should include authorization of posting and a periodic review to ensure currency and legibility. The number of posted operator aids should be minimized.  !

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POINT BEACH (1982)

Page 8 Response PBNP will revlei the current practices g3 Identified in the finding.

This review will include a review of the appropriate authorization level for each item, how the item re;nains culTent, and which of those aids presently in use can be made permanent. Based on that review, further administh ativa controls, if necessary, will be estab-11shed. This review will be accomplished prlw to April 1,1983.

OPERATIONS FACIIJTIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Operational facilities and equipment shouk! effectively support plant operation.

Finding Many plant valves are not uniM identified. Some valves have (OP.6-1) not been assigned unique numbers and many valves are not labeled.

RecommeN2ation Review plant systems, and assign unique valve numbers where needed. Attach identification tags on valves that are not properly identified.

Response PBNP will review its systems to determine the additional valves that need to be identified. This systems review will be done by t

April 1,1983. A program for VMye identification and drawing 1 changes will be developed following the review.

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POINT CEACH (1982)  !

Page 9 MAINTENANCE MAINTENANCE ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: h maintenance se .ni tlen and administrative '

systems should ensure effective control and implementation of department activities.

Finding 'Ihe following Good Practice was noted: The evaluation of instru-(M A.1-1) ment technician readiness for assignment to perform technical specification surveillances is very effective. An observation by the

, instrument and control superintendent of the technician performing an actual surveillance test is combined with written and oral examinations to provide a reliable assessment of technician readi-ness for increased responsibility.

~ i WORK CONTROL SYSTEM PERFORMANCE OBJECTIVE: The control of work should ensure that identified maintenance actions are properly completed in a safe, timely, and effielent manner.

Finding 'Ihe following Good Practice was noted: 'Ihe lebe. liny of plant (MA.3-1) material defielencies with maintenance tags is effective in ensur-lag that identified deficiencies are entered in the work control system and in reducing duplicate maintenance requests.

PREVEN'1TVE MAINTENANCE PERFORMANCE OBJECTIVE: 'Ihe preventive maintenance programs should contribute to optimum performance and reliability of plant equipment.

l Finding h existing preventive maintensnee program does not include I (MA.5-1) appropriate t teventive maintenance for soue equipment spares and materials la the plant warehouse. Examples include the followirg:

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l a. Soi9e large electric motors are not scheduled for periodic l rotation or lubrication.

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POINT BEACH (1982)

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b. There is no formal program for the control of shelf life items to ensure that items are not issued or utilized beyond their usefullife. ,

Recommendation Establish controls to ensure that equipment spares in storage receive necessary preventive mainter.ance. Include establishment of shelf life controls to track the receipt and age of affected items to prevent issue or utilization of outdated materlab.

Response Equipment spares in storage will be reviewed and additional pre-ventive maintenance deemed necessary will be established by July 1,1983. A standard written plant policy over shelf life controls for spare parts has been established. Organization and

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implementation of a formalized program will be established by September 1,1983.

MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Facilities and equipment shreld effectively sgport the perfeemance of maintenance activities.

Finding Lifting slings are not always controDed and inspected to ensure (MA.8-1) safe load-lifting espability. Some slings with improper load ratings and some worn and damaged slings were available for use.

4 Recommendation Expand the current station inspection and load testing program for

, lifting devices to include lifting slings. Establish controls to j prevent the use of slings with improper ratings or the use of worn and damaged slings.

Response A companywide " Safe Load Path" program has recently been implemented that will require all slings in use to have a unique identification number as well as a clearly marked capacity rating.

To further address the concern on sling inspection, the corporate Accident Prevention Group will provide periodic sling inspection services.

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.,- POINT BEACH (1982).

Page 11 Finding Maintenance measuring and test equipment (M&TE) is not effee-(MA.8-2) tively controlled to' ensure proper checkout and return of equip-l ment or tracking of equipment usage. When MATE is found to be out of calibration, an evaluation is not conducted to determine the impact on the performance of affected installed equipment.

Recommendation Establish controls over the storage and issue of M&TE used by the

- maintenance department. Include documentation of M&TE usage in maintenance activities. Implement a method for evaluating the imppet on affected installed ejuipment when M&TE is found to be out of calibration.

Response Management controls will be reviewed concerning the storage and

, issue of M&TE used by the maintenance department. The review will be completed by July 1,1983. Appropriate corrective action will be taken based on the results of the review.

Finding Improvements are needed in the control and storage of welding l (MA.8-3) : mater 3als. Current practices do not effectively support optimum performance in weld repair and fabrication activities. Problem areas include the following:

a. Some weld rod is issued from shop ovens without docu-mentation of the job for which it is to be used.

b. Some unused weld rod is not stored in ovens or sealed containers when required.

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c. Weld rod oven thermostats are not calibrated or ovens checked for proper temperatures.

Recommendation - Establish controls over the issue and storage of welding materials to include documentation of weld rod issue, proper storage of L

unused weld rod, and preventive maintenance of weld rod ovens.

Response In response to INPO recommendations, and in order to ensure proper control of welding materials, a new policy on weld rod control has been implemented for both QA and non-QA weld rod.

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POINT BEACH (1982)

Page 12 TECHNICAL SUPPORT OPERATING EXPERIENCE REVIEW PROGRAM PERFORMANCE OBJECTIVE: Industrywide and in-house operating experiences should be evaluated and appropriate actions indertaken to improve plant safety and reliability.

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

. Number of Recommendations Action Taken 44 Satisfactory 42 Not applicable

'42 Pending 13 Further review needed The following recommendations are pending action:

SOER Number Recommendation Numby 81-4 1,2a,2b,3,4 81-5 1,2,3,4 81-6 -

1, la, 2 81-7 1, 2 81-8 4 81-9 1,2a,2b,2c 81-17 1,2,3 82-5 1,2,3,4,5,6 82-7 1,2,3,4a,4b,4c,4d,4e,4f,5 82-8 1,2,3,4 The following recommendations need further review:

SOER Number Recommendation Number 81-1 1, 2 81-2 1,2a,2b,3,4,5,6 81-3 1,2,3 81-14 2 An update on the status of each recommendation listed in the "pending ection" or "need further review" categories shown above is requested in the six-month follow-on response to this report. In addition, the status of each immediate action (red tab) SOER recommendation received subsequent to this evaluation should be included in the six-month follow-on response. A tabular summary, similar to that above, is requested.

l POINT BEACH (1982)

Page 13 PLANT MODIFICATIONS PERFORMANCE OtlJECTIVE: Plant modification programs should ensure proper re-view, control, implementation, and completion of plant design changes in a safe and timely manner.

Finding Improvements are paadad in the plant modification program to (TS.4-1) ensure that design changes are implemented in a timely manner.

The plant modification tracking system does not clearly identify the current stat t.s of modifications for management review and appropriate action.

Recommendation Review the outstanding modification requests to determine if assigned priorities are still approptlate. Upgrade the present modification tracking system to provide the current status of ecch modification. Consider adding information such as the following:

a. identification of those modifications that are in progress '

and those that are completed

b. expected completion dates for modifications in progress i

c. required in-service dates where epplicab?e Response Outstanding modification requests have been reviewed to ensure that assigned priorities are correct.

The modification system will be reviewed with regard to timely implementation and tracking of the current status of modifications to provide management review and appropriate action. Appro-priate system changes will be implemented by July 1,1983 in response to the recommendations.

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FindMg Current as-built drawings are rd always provided for a modified  :

(TS.4-2) system prior to the return to service of that system.

Recommendation Revise the administrative controls for plant modifications to ensure that affected drawings are marked to indicate the as-built status of the plant prior to placing modified systems or components in service.

Response The plant modification program will ensure that drawings in the control room that are necessary for proper plant operation reflect the ms-built condition of the system prior to placing that system in operation. Appropriate administrative controls will be reviewed by July 1,1983 in response to the finding.

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POINT BEACH (1982)

Page 14 Finding Some alat:n setpol 3 in the plant computer have been changed

. (TS.4-3) without a prior technical review.

Raeommendation Identify the setpoints that operators are authorized to modify.

Establish upper and lower limits for thae setpoints. Perform a technical evaluation on those limits for approval Response The setpoints that operators are authorized to modify, along with the upper and lower limits for those setpoints, will be identified and a technic-1 evaluation of these limits performed in conjunction with the new computer system expected to be installed by July 1, 1984.

Finding '"sehnical evaluations of jumpers and lifted loads ne not always (TS.4-4) dneunented. Although such evaluations are being performed, they are not always documented so that operators and technicians can l- subsequently review the impact on the plant operations.

Recommendation Revise the administrative controls for jumpers and lifted letds to ensure that the results of technical evaluations are doeuraented and available fcr operator and technician review.

Response The lifted wires, jumpers, and bypasses procedure will be revised by March 1,1983 to require documentation of technical evaluations on the log sheet for those items that have a significant impact on plant operations.

Finding Lead shielding is installed on some systems without a review of its (TS.4-5) effect on piping stresses.

Recommendation Conduct engineering reviews of existing temporary lead shielding to ensure that unacceptable stresses have not been created.

Establish controls to ensure that potential pip evaluated prior to installation of future temporary,ing lead shielding.stresses Response Lead shielding that was installed on piping at the time of the 79-14 backfitting inspection was included in the analysis of seismic adequacy of the piping system. This lead shielding is indicated on the isometric drawings developed during the course of the 79-14 work.

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, POINT BEACH (1982)

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= Guidelines have been obtained from an engineering consultant to allow the determination of acceptability of temporary lead shield-ing on standard wall or heavier piping systems. Installed lead

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shielding will be analyzed according to these guidelines. An update status willbe provided by April 1,1983.

TECHNICAL SUPPORT PROCEEURES AND DOCUMENTATION

, PERPORMANCE : OBJECTIVE: Technical support Wh- and documents shoukt 4 provide appropriate direction and should be effectively used to support safe operation .

of the plant.

Finding Reactor ."--Sg procedures used to perforta surveillance tests (TS.7-1) do not always specify instrument requirements such as range and accurney. Additionally, reactor engineering procedures do not include traceability of the instruments used.

Recommendation Revise reactor engineering surveillance test procedures to include specification of instrument requirements such as range and accu-

. - racy and identification of instruments used to ensure traceability.

Response Reactor engineering surveillance test procedures will be' revised to address test instrument requirements. A means of test instrument use traceability will be provided. These revisions should be implemented by August 1,1983.

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Finding Reactor engineering test engineers need to be provided formal (TS.7-2) guidance on how to use procedures for the performance of surveil-lance tests.

Recommendatica Provide formal guidance to reactor engineering test engineers on the use of procedures including the following:

a. when to use the procedure for general guidance

b. when to follow the procedure step-by-step

c. when to sign-off the step as com71eted l' '

EJapanse The reactor engineering test engineers will be provided with formal guidance on the use of test procedures by August 1,1983.

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POINT BEACH (1982)

Page 16 TRAINING ~AND QUALIFICATION TRAINING ORGANIZATION AND ADMINISTRATId'N ,

PERFORMANCE OBJECTIVE: 1he training organization and administrative systems should ensure effective control and i'nplementation of training activities.

. Finding The foDowing Good Practice was noted: An excellent instructor (TQ.1-1) training program has been developed and implemented. The program results in a college certificate in adult education and consists of 42 credit hours in areas such as professional issues, directed teaching in adult education, inues in education, psy-chology of education, research in education, and educational mea-surement and evaluation.

4 Finding Trsining department prgiam devCopment assignments are not (TQ.1-2) being completed in a timely manner. Examples include lesson plan development for t ilant systems presentations and improvement of the general employee training pregram.

Recommendation Review current training department responsibilities, and establish priorities for development of programs. Consideration should be given to reassigning responsibilities or increasing training dapart-ment resources.

Response The training group has just completed a preliminary self-evaluation and is in the process of making recommendations to management based on these results. Consideration will be given to any practical means by which training resources and/or personnel may be aug-

, mented. Recommendations are scheduled to be implemented by January 1,1984.

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. POINT BEACH (1982)

Page 17 MAINTENANCE PERSONNEL TRAINING AND QUALIFICATION PERFORMANCE OBJECTIVE: 'Ihe maintenance personnel training and[ qualification program should develop and improve the knowle%e and skills necessary to perform assigned M functicas. i Finding A formal training program for instrument and control (I&C) re-(TQ.5-1) pairers needs to be developed and implemented. I&C repairers work for approximately three years without formal training before-  ;

entering the I&C technician training program. It is recognized that a Traini:.g Department Action Order has been issued to address this problem. i Recommadation Develop and irr.plement a fctmal I&C repairer training program.

The INPO documen1L, " Guidelines for Instrument and Control Tech-  ;

nician Qualification"(GFG-08), could be of assistance in this area.

Response The training group recently tcok action to address the development and implementation of a formel I&C repairer training program.

Development is progressing as materials and resources are being  ;

examined. The " guidelines" mentioned in the recommendation are being used as an input. The program should be developed and implemented by Maren 1,1983.

Finding A continuirg training program for mechanical-electrical repairers, (TQ.5-2) radiochemical technicians, and radiation control operators has not been developed. ' A continuing training program for I&C technicians has been developed but is not implemented.

Recommendation Develop and implement a continuing training program for the mechanical-electrical repairers, radiochemical technicians, and ra-diation control operators. Implement the RC technician continu-ing training program.

The following INPO documents could be of assistance:

a. " Guidelines for Electrical Maintenance Personnel Qualifi-cation" (GPG-07) .

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b. " Guidelines for Mechanical Maintenance Personnel Quali-fication"(GPG-05)

c. " Guidelines for Instrument and Control Technician Quali-

! fication" (GPG-08)

e. " Radiological Protection Teclnical Qualifications" (INPO 82-006)

POINT BEACH (1982)

Page 18 Response The continuing (retraining) training program in the areas of I&C, chemistry and health physics, and maintenance are in the develop-ment stage. Presently, the need for such formal, programs has been documented in a self-evaluation performed by the training group.

Programs are expected to be implemented by January 1,1984.

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POINT BEACH (1982)

Page 19 RADIOLOGICAL PROTECTION RADIOLOGICAL PROTECTION ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: h organization and administrative systems should ensure effective control and implementation of the radiological protection program.

Finding P! ant personnel do not always comply with radiological protection (RP.1-1) yn,ssas and requiremmts. Examples noted include the follow-ing:

a. moving the instrument probe too rapidly when monitoring for personnel contamination

b. not adhering to the requirements of radiation work per-mits

c. not monitoring protective clothlag for contamination prior to storing the clothing in personnellockers i Recommendation Re-emphasize the importance of adhering to radiological pro-tection procedures and requirements with all plar.t personnel.

Managers and supervisors, including operations, maintenance, a'id radiological protection, should more aggressively enforce adher-ence to radiological protection procedures and requirements and ensure tl'at personnel are held accountable for violations.

l Response PBNP supervision will continue to emphasize to all plant employees and contractor employees the necessity for compliance with radio-

. logical p otection procedures and individual ALARA responsibili-ties through orientation training, on-the-job training, group meet-ings, and plant safety meetings.

Finding h reporting and correction of radiological deficiencies needs

(RP.1-2) improvement. Corrective actions taken as a result of reported l deficiencies are sometimes not sufficiently comprehensive-to pre-vent recurrence. Personnel skin contaminations are not routinely documented.

Recommendation EmpLasize the use of the Health Physics Incident Report System to ensure that radiological protection problems are brought to the attention of management. Document personnel skin contamina-tione. Use the information gained determine basic causes, and develop,to identify appropriate problemac-corrective areas, tions.

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. POINT BEACH (1982)

Page 20 Response ~A review of the Health Physics Incident Report will be made and recommendations deemed appropriate including documenting of personnel skin contaminations will be completed by April 1,1983, with appropriate corrective action following.

EXTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: External radiation exposure ecatrols should minimize personnel radit. tion exposure.

Finding Measurements of beta radiation dose rates are act routinelf (RP.4-1) performed for work in high beta radiation levels, i Recommendation Develop and implement methods and procedures for beta radiation surveys.

Response Appropriate procedures will be developed and implemented to ensure that surveys for beta radiation are perfomed in areas where ,

high beta radiation levels are expected. These procedures should be developed by July 1,1983.

Finding Several conditions were noted where the radiation exposure of (RP.4-2) personnelis not being minimized. Examples include the following:

a. personnel spending time needlessly in or adjacent to high radiation areas

b. w*k breaks taken in radiation areas rather than in areas with lower dose rates

c. establishing a contractor's 59tk table in a radiation area Recommendation Radiation exposure control practices should be reviewed aM up-graded. ' The points discussed in the finding should be addressed.

j Response Radiation protection practices of plant employees are a matter of i supervisory concern. Plant supervisory personnel and employees

are continually reminded of their individual responsibilities for

!' ensuring that work activities are accomplished in a radiologically safe manner. Supervision will continue to provide employees with classroom and on-the-job training in ALARA principles and em-phasize the necessity of a pctsonal ALARA commitment through group meetings and plant safety meetings. Contract health physics

. POINT BEACH (1982)

Page 21 technicians assigned to monitor contractor work activities will increase thuir field observations to ensure that ALARA principles are maintained where practical and where work ectivity allows.

SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Solid radioactive waste controls should minimize the volume of radiometive waste end ensure safe transportation of radioactive material Finding Radiolcgical controls dur'ng the processing and handling of radio-( P.P.7-1) active waste need to be sti-d=+1 Examples include the following:

a. Airborne radioactivity levels are not routinely monitored during op.eration of the waste compactor.

b. Rt.diation dose rate measuring devices are not always available to the workers.

c. A number of practices were observed that could lead to the spread of contamination such as handling contami-nated drums without protective gloves.

d. Workers do not routinely check the reading on their pocket ionization chambers to control their exposure.

Recommendation Review and upgr?de radiological controls during the processing and handling of radioactive waste. The points discussed in the finding should be addressed.

I Response An evaluation of the radiological controls used during the pro-l cessing and handling of radioactive waste will be conducted to address the points discussed in the Unding. Appropriate corrective action will be implemented by July 1,1983.

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. POINT BEACH (1982)

' Page 22 PERSONNEL DOSIMETRY PERFORMANCE OBJECTIVE: 'Ihe personnel dosimetry program should ensure that radiation exposures are accurately determined and recorded.

Finding Improvement is paadad in the pocket lonization chamber (PIC)

- (RP.8-1) dosimetry program. This is exemplified by the following:

a. the large number of PICS that fail the routine drift and response checks

b. a number of PICS found with offscale or irregular readings

c. the large numb >r of correlation errors between thermo-luminescent dosimeter and PIC resdings

• Recommendation Identify the cause of the high failure rate of PICS, and take appropriate corrective action. Accelerate the implementation of the program *o improve the accountatslity arid handling of PICS. .

Consider replacing 0-500 mr PICS w!th 0-200 mr PICS to aid in reducing the number of correlation errors as 0-200 mr PIC readings can be Inore accurately laterpreted. -

Response PBNP has been aware of the prcblem associated with PICS as noted in the above finding. A commercial PIC calibrator (for response checking of PICS) was ordered in the early part of 1982 and has not yet been delivered. It is felt that this unit will enable PBNP to

! eliminate some of the inherent errors of the present method used l

for checking PICS. PBNP has determined that the policy of issuing PICS to all plant and contractor personnel whether or not they enter the controlled zone may be the major contributor to the problems noted in Findings b. and c. This practice is presently being reviewed by management in an effort to determine a reasonable and workable method to correct the problems noted.

l RADIOACTIVE CONTAMINATION CONTROL PERFORWANCE OBJECTIVE: Radioactive contamination controls should minimize the I cos.tamination of areas, equipment, and personnel Finding Some practices were observed that ecald result in the spread of i

(RP.9-1) contamination. Examples include the following:

a. personnel not always wearing gloves when handlinc con-taminated or potentially contaminated material or equip

• ment l

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POINT BEACH (1982)

Page 23

b. the reuse of rubber overshoes in contaminated areas of the plant

c. smoking in unauthorized areas of 'the radiologically controlled area (RCA) and not monitoring for personnel contamination prior to smoking in authorized areas

d. the use of toilet facilities within the RCA without moni-toring for personnel contamination Recommendation Review and upgrade appropriate contamination control practices at the station. The points discussed in the fir. ding should be ad-

' dressed.

Response Contamination control practices will be reviewed to adoress the items noted in the finding. The review should be completed by July 1,1983 with appropriate corrective action following.

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POINT BEACH (1982)

Page 24 CHEMISTRY CHEMISTRY ORGANIZATION AND ADMDGSTRAT[ON PERFORMANCE OBJECTIVE: The organization and administrative systems should ensure effective implementation and control of the ehemistry program.

Finding A comprehensive program for the lay-up of plant systems and (CY.1-1) equipment is needed. Such a program would reduce the potential for long-term corrosion of systems and components.

Recommendation Develop a program for the lay-up of plant components and systems.

Include applicable. portions of the program in station operating paocedures.

Response ' As layup requirements are established, operating procedures will be modified or new procedures generated to develop long-term layup instructions. Appropriate layup procedures shoulc be implemented before an extended spring 1983 refueling outage.

1 CHEMISTRY CONT 2OL i PERFORMANCE OBJECTIVE: Chemistry controls should ensure optimum ehemistry I

conditions during all phases of plant operation.

Finding Current vendor recommendations are not followed for dissolved (CY.3-1) caygen in the reactor make-up storage tank and silica in the reactor coolant ~ system. Oxygen concentration in the reactor make-up water frequently exceeds the vendor-recommended limit.

Silica concentration is not analyzed. >

Recommendation Reduce the. oxygen concentration in the reactor make-up water to

! vendor recommendations by either repair or modification of exist-ing systems. Tna silica concentration Umits and analysis frequency

, in the reactor coolant should be evaluated and methods developed L for silica control.

Response The problem of oxygen in the reactor make-up water tank will be l reinvestigated and appropriate repairs and/or modifications will be

! developed. Silica concentration limits and calysis frequency in l the reactor coo! ant will be evaluated. Appropriate methods will be l investigated to control silica concentration in the recctor coolant.

An uviated status will be provided by April 1,1983. j

• POINT BEACH (1982)

Page 25 Finding Eneressed emphasis is needed to correct the rapid degradation of (CY.3-2) makemy water demineralizer resin due to high concentrations of organies in the raw water supply. In addition, e,rganics are passing through the make-up demineralizer water system into the plant make-up system. It is 1ecognized that the plant is investigating this problem.

Recommendation Complete the investigation of the raw water supply problem and carry out the resultant corrective action. Consider the use of organic removing filter media, including activated charcoal.

Response This problem has been recognized and is currently being reviewed

.by the corporate projects office for a solution, on both a technical

and economic basis. An evaluation should be completed by July 1, 1983.

4 1

l LABORATORY ACTIVITIES PERFORMANCE OBJECTIVE: Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters.

Finding 'the existing laboratory quality control program needs to be im-(CY.4-1) proved to provide more frequent standardization of the sodium hydroxide used in a boren analysis and more frequent use of standards during the chloride analysis.

Recommendation Expand the chemistry quality control program to provide daily standardization of the boron analysis and daily use of standards j with the chloride analysis.

l

Response

The chemistry quality control program will be evaluated in the areas mentioned. A more frequent use of sodium hydroxide and chloride standards will be evaluated and appropriate action taken

by July ',1983.

l i

Finding Procedures have not been developed for some routine chemistry (CY.4-2) analyses important to plant operations. Extmples include iodine, pH, and gross beta gamma. In addition, operational procedures for the gamma analysis system have not been developed.

Recommendation Develop a complete set of procedures covering activities per-formed in the chemistry laboratories.

POINT BEACH (1982)

Page 26 Response - The. development of the Chemistry Analytical Methods and Proce-dures Manualis approximately 40 percent complete and is expected to be fully completed by December 1983. .

Finding 'Ihe current analytieel method for measuring hydrogen concen-(CY.4-3) tration in the reactor coolant and volume control tank sometimes results in inaccurate measurements.

, Recommendation Review the method of hydrogen analysis and revise the procedure to prevent inleakage of oxygen during the analysis.

Response A review of the present method of hydrogen analysis v'ill bc l performed and appropriate revision to the method will be evaluated by July 1,1983, with appropriate correctiv a action following. ,

i i

CHEMICAL AND LABORATORY SAFETY PERFORMANCE OBJECTIVE: Work practices associated with chemistry activities should ensure the safety of personnel Finding Chemistry and operations personnel do not always use protective (CY.5-1) equipment while performing chemical analyses or campling radio-active liquids. Gloves are not worn while handling radioactive liquids in the laboratory. Gloves and other protective equipment are not worn when sampling the radioactive waste evaporator bottoms.

Recommendation Upgrade protective equipment usage practices. Surgeon's gloves or the equivalent should be used in the laboratory when handling radioactive liquids. Face shields, rubber aprons, and rubber gloves should be worn when sampling waste evaporator bottoms.

Response 'Ihe use of appropriate potective equipment including the use of gloves for sampling of radioactive liquids has been implemented. A review will be conducted on the use and benefits of handling radioactive liquids with surgeon's gloves in the laboratory. The full review with appropriate corrective action will be completed by July 1,1983.

POINT BEACH (1982)

APPENDIX I Pqe1 APPENDIX I ,

Summarv of Outstanding Response Action from Previous Evaluation (1981)

ADMINISTRATIVE CONTROLS Finding Administrative guidelines or procedures to provide guidance for (OA.4-1) implementation of a number of programs are not provided. Ermples of areas where such guidelines or procedures are needed or need improvement include:

c. pre.'encive maintenance

b. malatenant.e historf-

[

c. controlof measurement and test equipment

d. samp1'nt of systems for chemical and radiological analysis

?. oeeration, caEhration, and standardization of some lab-crutory equipme.nt

f. analytical techniques for chemistry and radiological eval-uation, including periodic use of spiked samples for verifi-cation of techniques

g. determination and controlof chemicalshelf-life

h. quality assurance reviews of chemistry and radiologicallab-oratory techniques and practices.

Recommendation Develop and implement written guidelines or precedures for areas where needed, including those listed above.

Response Wisconsin Electric concurs with the recommendation and will effect revision or development of procedures in the above-listed areas.

Some of the areas had been identified and placed on work lists prior

,' to the evaluation. Progress will continue on these and others.

Status Corrective action is complete on all the areas noted in the finding except for items d. and e. The Chemistry Analytical Methods and Procedures Manual, covering both of these items, is forty percent complete and is scheduled to be fully developed by December 1983.

1

.- . * + . . g POINT BEACH (1982)

APPENDIX 1 Page 2 TAGOUT PRACTICES Findirg An !=-% - '=t verification of safety-related equipment, having no (OP.7-2) control room indication, that is repositioned <kring maintenance or testing is not performed, with the exception of the auxiliary feed-water system. It is noted that independent verification is being performed when the eauipment is removed from service.

Recommendation PBNP procedures should be revised to incorporate independent verifi-cation of safety-related equipment having no control room indication.

< This action should be required each time eq 'pment is returned to service following maintenance or testing.

Response Wisconsin Electr!c concurs with the recommendation and has imple-mented this practice fully in the plant equipment red tag procedure .

and partially within other procedures. Implementation is centinuing and will soon include aH safety-related equipment.

Status The existing practice of cbuble verificauon of safety-related valw.s following major outages will be documented in appropriate check-off documents. Operating procedures including survell%nc> procedures ,

will be revised requiring double verification of all non-automated, safety-related valves. The review and change to most applicable documents is complete. The few remaihing documents will be completed by April 1983.

PLANT EFFICIENCY AND RELIABILITY Finding The current program for optimizing plant thermal efficiency is

(TS.2-1) incomplete. The "BALAN PROGRAM DATA SHEET" is used for l logging plant secondary side performance information. This and other data are currently being graphed to determine relevant trends in important plant perameters. However, it has not been determined how the graphs and data will be utilized. The frequency of data j

collection, graphing, and analysis has not been established nor has a j model of the plant been developed for long-term reference.

l Recommendation Develop and implement a comprehensive program for plant perform-ance monitoring with an objective of improving the plant operating efficiency and reliability.

Response Wisconsin Electric has recently hired an engineer whose primary responsibility will be the ongoing evaluation of unit efficiency as it relates to system performance. His job willinclude the development of a program to aid in this effort, which willinclude the baseline data and required performance criteria. In addition, to compensate for operational problems with some instrumentation, Point Beach is installing leading edge flow meters to more accurately determine power level which will enhance unit efficiency.

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N POINT BEACH (1982)

APPENDIX I <

Page 3 Reliability (unit availability) on Point Beach Nuclear Plant Unit 2 has been the highest in the United States for severaf years, with Unit 1

.also being above average. This has been due to careful attention to 4- the components and the systems and subsystems of the units. '

However, in the next few years PBNP's high availability factors will 4

probably fall because of equipment aging and longer planned outages.

We are committed to long-term performance improvements such as steam generator sleeving and/or replacement and are studying othe:-

componer:ts which can impact availability. Further, management has recently committed to a substantially larger inventory of spare parts, including such components as spare LP turbine rotors and one spare reactor coolant pump motor.

Status Development of the performance monitoring program is continuing. .

The program has been partially implemented with full implementa-tion scheduled for August 1983.

CHEMISTRY Finding

~

! ' ', 'Ihe radiochemical technicien training program is not developed or

. (RC.10-1) implemented except for wthe-M training. These technicians are not required to complete the available portions of the existing program before assuming their job responsibilities.

Recommendation Develop a schedule for completion and implementation of the radie chemical technician training program. Develop guidelines to ensure trainees complete the program in a timely manner and prior to their attaining qualified technician status.

Response Because of the low turnover and high experience level of radio-chemical technicians in the past, we had not until recently ex-perienced the need for a significant amount of formal training other than that given on tha job. However, with new hiring, we agree that a' separate, formal program incorporating additional job-related topics is justified. The program is under development and, when completed, willimplemeat the INPO Performance Objective.

> Status The radiochemical technician training program has been developed I

and approved. Implementation will commence with the next sched-uled aaining class.

NON-LICENMD OPERATOR TRAINING Finding A more comprehensive aurulary operator retraining program is (TQ.4-3) needed. Areas which are not being covered for some auxiliary operators include the following:

a. review of plaat systems <

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POINT BEACH (1982)

APPE. 4 DIX I Page 4

b. review of applicable industry operating experiences s

'c. review of job-related technicalinformatibn.-

Auxiliary operators are being kept aware of plant equipment and

. procedure changes.-

Recommendation A formal auxiliary operator retraining program should be established and implemented. The INPO " Nuclear Power Plant Non-Licensed Operator-Guidelines for Qualification Programs" should be considered

'-in determining the.se requirements.

i Besponse . Qualificaticn is not the end of our Auxiliary Operator training. As currently structured, once qualified, the Auxiliary Operator centinues to co:nplste the job skilh sMwn en the checklist. He also begins to work towa.M Control Operator qualification and is routinely sched-

- uled to attend vpropriate sessions in the Licensed Operator retrain-ing program. Development of an Auxiliary Operator requalification program will be coordinated with the review and revision of the

Auxiliary Operator tralidng prcgram. The fully developed formal '

requalification program will include requirements to review each of the areas in this finding.

Status The new training program is being ph>1 sed in, and the requalification effort will follow its full implementation. Retraining is scheduled to start late 1983.

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• POINT BEACH (1982)

APPENDIX II Page1 APPENDIX H s

Performance Objectives Reviewed a .

ORGANIZATION AND ADMINISTRATION OA.A Station Organization and Adminit tration Station organization and administrative systems should ensure effective imple-mentation and cor. trol of station activities.

- OA.2 Mission, Goals, and Objectives l[

Station misston, goals, and objectins should be established and progress monitored through a formal program.

OA.3.1 Management Assessment Management should assess and monitor station activities to ensure effective

! performance of all aspects of nuclear plant operation.

OA.3.2' Quality Programs Quality programs should ensure the effective performance of activities im-(

portant to nuclear safety.

OA.4 Personnel Planning and Qualification

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

OA.5 Industrial Safety Station industrial safety programs should achieve a high degree of personnel safety.

OA.6 Document Control Document control systems should provide correct, readily accessible infor-mation to support station requirements.

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

POINT BEACH (1982)

- APPENDIX II Page 2 OPERATIONS OP.1 . Operations Organization and Administration The operations organization and administrative systems should ensure effective.

. control and implementation of department activities.

OP.2 Conduct of Operations Operational activities should be conducted in a manner that achieves safe and reliable plant operation.

~ OP.3 Plant Status Controlg Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.

OP.4 . , Operations Knowledge and Performence ,

Cperator knowledge and performance should support safe and reliable plant operation.

OP.5 Operations Procedures and Documentation Operational procedures and documents should provide appropriate direction and should be effectively used to support safe operation of the plant.

OP.6 Operations Facilities and Equipment

'2 Operational facilities and equipment should effecth aly support plant operction.

MAINTENANCE MA.1 Maintenance Organization and Administration The maintenance organization and administrative systems should ensure effee-tive control and implementation of department activities.

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

MA.3 Wrk Control System i The control of work should ensure that identified maintenance actions are l properly completed in a safe, timely, and efficient manner.

a o sv

'- POINT BEACH (1982)

APPENDIX Il Page 3 MA.4 Conduct of Maintenance Maintenance 'should be conducted in a manner that ensures efficient and effective plant operation.

MA.5 Preventive Maintenance The preventive maintenance programs should contribute to optimum perform-ance and reliability of plant equipment.

. MA.6 Maintenance Procedures and Documentation Maintenance pmcedures should p: ovide appropriate directions for work and should be used to ensure that main.enance is performec safely ad efficiently.

MA.7 Maintencnce History 1

The maintenance history should be used to support maintenance activities and optimize equipment performanec.

M A,8 Maintenance Facilities and Equipment Facilities and equipment should effectively support the performance of mainte-nance activities.

TECIINICAL SUPPORT

, TS.1 Technical Support Organization and Administration The technical support organization and administrative systems should ensure

. effective control and implementation of department activities.

TS.2 Surveillance Testing Program Surveillance inspection and testing activities should provide assurance that equipment important to safe and reliable plant operation will perform within required limits.

TS.3 Operations Experience Review Program 6

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

t TS.4 Plant Modifications ~

l .

l. Plant modificatirn programs should ensure proper review, control, implementa-tion, and completion of plant design changes in a safe and timely manner.

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POINT BEACH (1982)

[. - APPENDIX II Page 4 Raaetor Enrineering TS.5 On-site reactor engineering' activities should ensure optimum nuclear reactor operation without compromising design or safety limits.

TS.6 - Plant Efficiency and Reliability Monitoring Performnce monitoring activities should optimize plant thermal performance and reliability.

TS.7. Technical Support Procedures und Documentation Technical support procedures and documents should provide appropriate diree-tion and should be effectively used to support safe operation of the plant.

TRAINING AND QUALIFICATION TQ.1 Training Organization and Administration i

The training organization and administrative systems should ensure effective control and implementation of training activities.

TQ.2 Non-Licensed Operator Training and Qualification The non-licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job functions.

TQ.3 Licensed Operator Training and Qualification The licensed operator training and qualification program should develop and

-improve the knowledge and skills necessary to perform assigned job functions.

1 i- TQ.4 Shh*t Technical Advisor Training and Qualification

". The shift technical advisor training program should develop and improu the knowledge and skills to perform assigned jcb functions.

, TQ.5 Maintenance Personnel Trabing and Qualification

! The maintenance personnel training and qualification program should develop snd improve the knowledge and skills necessary to perform assigned job-

. .' functions. .

TQ.6 Technical Training for Managers and Engineers The technical train!ng program for engineers and managers should broaden overall knowledge of plant processes and equipment as a supplement to position-specific education and training.

e, POINT BEACH (1982)

APPENDIX II Page 5 TQ.7 ; General Employee Trainint

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,^

The general employee training prog am should develop a broad understanding of employee responsibilities and safe work practices.

l TQ.8 Training Facilities and Equipment The training facilities, equipment, and materials should effectively support training activities.

RADIOLOGICAL PROTECTION RP.1 P.adiological Protection Organization and Administration The organization and administrative systems should ensure effective control and implementation of the radiological protection program.

- RP.2 Radiological Protection Personnel Qualification The radiological protection qualification program should ensure that radiolog-ical protection personnel have the knowledge and practical abilities necessary to effectively implement radiological protection practices. ,

RP.J General Employee Training In Radiological Protection

' General employee training should ensure that plant personnel, contractors, and visitors have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.

RP.4 External Radiation Exposure External radiation exposure controls should minimize personnel radiation ex-posure.

RP.5 Internal Radiation Exposure Internal radiation exposure controls should minimize internal exposures.

RP.6 Radioactive Effluents Radioactive effluent controls should minimize radioactive materials released to

-, the environment.

RP.7 Solid Radioactive Waste Solid radioactive waste controls should minimize the volume of radioactive waste and ensore safe transportation of radioactive material i

- . . , . . . . - . _ _ _ _ . _ . _ . - _ _ _ _ _ - . _ _ _ - , _ . - - - - - - ~ . . _ _ _ . - - _ - - - . _ - _ _ _ - - - - _ _ _ . . - . . - ~ - .

POINT BEACH (1982)

APPENDIX II Page 6 RP.8 Personnel Dosimetry The personnel dosimetry program should ensure that radiation exposures are

• - accurately determined and recorded.-

RP.9 Radioactive Contamination Control 4

Radioactive contamination - controls should minimize the contamination of

- areas, equipment, and personnel.

CHEMISTRY CY.1 gemistry Organization and Administration

., The organization and administrative systems should ensure effective imple-

mentation and control of the chemistry program.

t CY.2 Chemistry Personnel Qualification a

4  ; The chemistry qualification program should ensure that chemistry personnel have the knowledge and practical abilities necessary to implement chemistry

_. prectices effectively.

Chemistry Control CY.3 Chemistry controls should ensure optimum ehemistry conditions during all phases of plant operation.

CY.4 Laboratory Activities Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters.

[..

CY.5 Chemical and Laboratory Safety i Work practices associated with chemistry activities should ensure the safety of l- personnel t

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