ML20117J181
| ML20117J181 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah, 05000000 |
| Issue date: | 11/30/1981 |
| From: | INSTITUTE OF NUCLEAR POWER OPERATIONS |
| To: | |
| Shared Package | |
| ML20114F819 | List: |
| References | |
| FOIA-84-44 NUDOCS 8505150011 | |
| Download: ML20117J181 (52) | |
Text
" ~
t, _' ~ _
, .g 1 ey
.. 4, Evaluation ;
Report
, November 1981
~
Secuoyah
\ L C ear D a'.i
~~
ennessee Va ey Au: lori:y
$\
3ah
. to* .
V f4 em 0
8505150011 841121 -
' ~ ~
O TEN 44 PDR
h ; ,
e EVALUATION Of SEQUOYAH NUCLEAR PLANT Tennessce Valley Autitority November 1981
F m . .
7tQUOYA H (1981)
Page1 SJMMARY IF1 RODUCTION The Institute of INelear Power Operations (INPO) conducted its first evaluation of Tennessee Valley Authority's (TVA) Sequoyah Nuclear Plant during the weeks of July 13 snd July 20, 1981. Sequoyah consists of two 1129 megawatt (electrical) hestinghouse pressurized water reactor units. It is located on the l Tennessee River near Daisy, Tennessee. Unit I was placed in commercial operation in Decembe 1980. Unit 2 is in preliminary operation.
f.
PURPOSE AND SCOPE l
INPO conducted an evaluation cf site activitics to make an overall determination of plant operating safety, evaluate management systems and controls, and identify areas needing improvernent. Information was assembled from discus-l siens, interviews oascrvstions, and reviews of plant documents.
The to.am examir.ed station organizatien, training, operations maintennnec, rtQ':c prol and chemistry activities, and on-site technical support. Corporate a e t t w.10., were net included in the scope of the cycluation, except as en i incidente1 tirt cf the station evaluation. As a basis for the evaluation, INPO e.ied .a e::grience on Dest practices in the industry and written evaluat!on criternt furnished to tt:e plant in odvance. INPO's goal is to assist memte-utilities :n achievin:7 the highest standards of excellence in all phases of nuc!c tr plant operation. Accordingly, the conditions found in each area were compared
- to best practiccs, rather than to minimum acceptabic conditions or require-monts.
i UETERMINATION 1
l l
l
v.. ,
SEQUOYAli (1981) ,
Pcge 2 Specific evaluation findings are in the accompanying DETAILS, and information of an administrative nature is in the ADMINISTRATIVE APPENDIX. These findings were presented at an exit meeting at the plant on July 24, 1981.
Recommendations are intended to augment TVA efforts to achieve the highest standards in its nuclear operations. In addressing these findings and recom-mendations, TVA should, in addition to correcting or improving specific con-ditions, pursue underlying causes and issues.
The excellent cooperation received from all levels of the Tennessee Valley Authority is appreciated.
3 E. P. Wilkinson President e
- o. . .
SEQUOYAH (1981)
Page 3 TENNESSEE VALLEY AUTHORITY Response Summary This evaluation has afforded TVA a perspective of Sequoyah's activities com-pared to INPO criteria and, consequently, the rest of the industry. TVA considers the recommendations for improvements INPO has made as objective and with basis and will take the appropriate actions to implement the accompanying recommendations in a timely manner.
TV/. tecognizes that the INPO findings detailed in this report were based on a comparison of Sequoyah operational practices with criteria that have been established by INPO as standards of excellence for the nuclear utility industry.
In this perspective, the INPO findings do not indicate that Sequoyah is being operated in an unsafe manner but do indicate areas of p!snt operation in which improvements can and should be made. TVA particularly recognizes weaknesses in the areas of adherence to procedural requirements and the past tendency of plant management to become so involved with activities of an administrative nature that the experienced input of these individuals into all aspects of plant operation was diluted. TVA acknowledges the INPO recommendations as providing assistance in these areas.
The INPO recommendations have been evaluated and will be implemented as reflected in the following detailed response to specific items. Recommendations with generic significence will be implemented at other plants as appropriate.
Full implementat:on, when achieved, will further enhance TVA's ability to operate its nuclear power plants in a safe and efficient manner.
/
e e
t
SEQUOYAH (1981)
- . P ge 4 DETAILS Tilis portion of the report includes the detailed findings. It is composed of six sections, one for cach of the major evaluation areas. Each section is headed by a summary describing the scope of the evaluation and the overall finding in that aren. The sumn ary is followed by the specific findings. recommendations, and utility responses related to each of INPO's evaluation procedures. Items listed as Category 11 relate to criteria not included in INPO procedures, but generally recognized as desirable, accepted techniques of industry and management. The
~
evaluation procedures that were used are listed in the ADMINISTRATIVE APPENDIX.
ORGANIZATION AND ADMINISTRATION .
In this area, organizational objectives, organizational structure, manpower resources, administrative controls, and programs for management quality assur-ance, industrial safety. and equipment surveillance were evalunted.
Overall, the plant appears to be organized and administered effectively. How-ever, areas in which improvements were recommended include organizational structure and objectives, manpower resources, administrative controls manage-ment quality programs, and surveillance programs.
ORGANIZATIONAL OBJECTIVES (INPO Procedure OA.1)
An evaluation was performed to determine how effectively goals and objectives are cisseminated throughout the plant organization and if effective means are provided for periodic assessment of progress. Also, a review was made of the employee appraisal pregram.
Finding (Criteri1 A and B) ,. .
- ~~ - - "
Recommendation
- * ' - * * ~ ~
nesponst-L
SEQUOY AH (1981)
. Page 5 ORGANIZATIONAL STRUCTURE (INPO Procedure OA.2)
An evaluation was performed to determine how effcetively the plant organi-zation supports operations and maintenance activities. Areas reviewed included the applicability of the organizational diagram, the use of position descriptions for supervisory and professional staff positions, span of control for plant man-agement positions, and individual workload.
Finding (Criterion A)
Recommendation ,
Response
MANPOWER RESOURCES
(!NPO Proceduro OA.3)
An evaluation was performed to determine the methods by which qualifications <
are estaolished and qualified personnel are selected to fill job positions affecting plant safety and rel!cility. Areas reviewed included manpower plannin;.
personnel selection proecss, written qualification requirements, and periodic review and revision of qualification requirements for caeh plant position.
Finding (Criterion D)
Recommendation
' ~ *
Response
ADMINISTR ATIVE CONTROL,S llNPO Proccdurc OA.4)
! An evaluation was performed to determine the effectiveness of the plant's administrative controls. Areas reviewed addressed the program for administra-tive controls for purpose, scope, responsibility, level of administrative action.
and ef fectiveness, t
r.
SEQUOYAH (1981)
Page 6 Finding (Criterion C)
Reconimenditi6ii
Response
MANAGEMENT QUALITY PROGRAMS (INPO Procedure OA.5)
An evaluation was performed to determine the effectiveness of the quality programs to enhance safe and efficient cperation. Areas reviewed included management control, approved quality assurance (QA) programs, program effee-tiveness, and qualifications of quality assurance personnel.
- 1. Finding (Criterion Al Re' commendation
, Response W - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
SEQUOYAH (1981) -
.;. Page 7
- 2. Finding (Criterion n)
Recommendation Res%se SURVEILLANCE PROGRAM (INPO Procedurc OA.6)
An evaluation was performed to determine if an effective program exists for surveillance inspection und testing requirements. Areas of the surveillance program reviewed included completeness, acceptance criteria, results review, control of off-standard conditions, management control systems, actions to correct dcficiencies, and proper use of procedures.
Finding (Category II)
Recommendation Resoonse i
. . . 1 SEQUOYAH (1981)
Page 8 INDUSTRIAL SAFETY (INPO Procedure OA.7)
An evaluation was performed to determine the effectiveness of the plant safety program in providing a safe, orderly working environment. Areas r9 viewed included the plante safety program, management support for the program, and employee participation.
Finding O
e O
6 0
l
SEQUOYAH (1981)
Page 9 TRAINING AND QUALIFICATION The following areas were evaluated: training organization und administrations training facilities and equipment; and training prograr s for licensed and non-licensed operators, shift technical advisors, instrum, nt mechtnics, electricians, and mechanical maintenance personnel. These areai vero evaluated at both the Sequoyah Plant and the Nuclear Training Erar.ch Power Operations Training Center.
Tennessee Valley Authority's overall commitment to training is demonstrated in several ways.
However, several areas need improvement, as described in the following findings:
TRAINING ORGANIZATION (INPO Procedure TQ.1)
An evaluation was performed to determine if a clearly defined training organiza-tion exists that is staffed with quallfled personnel and is capable of accom-plishing all assigned training tasks.
- 1. Findirut (Criterion B) e Rec'oinmen~dattori d
SEQUOYAH (1981)
,, Page 10
Response
- 2. Finding (Criterion D)
' ~
Recommendation ,
Response
, TRAINING ADMINISTRATION (INPO Procedure TQ.2) ,
e An evaluation was perfurrr.ed to dete.mine if the activiti<.:: necessary to develop and implement personnel training and qualification programs are accomplished in a well-defined, coordinated, and effective manner.
Finding (Criterion C)
~ ' ~
Recommendation
Response
f TRAINING FACILITIES AND EQUIPMENT (INPO Procedure TQ.3)
An evaluation was performed to determine the adequacy of facilities, equipment, and materials available for the delivery of effective training for plant personnel.
SEQUOYAH (1981)
Paga 11
. hinding (Criteria A and D)
Recommendation
Response
NON-LICENSED OPERATOR TRAININO (INPO Procedure TQ.4)
An evaluation was performed to determine if initial and continuing training for non-licensed operators Is sufficient to develop and maintain the skills and knowledge necessary for the performance of assigned job functions.
- 1. Finding (Criterion A)
Recoinmencation t
f t
Response
SEQUOYAH (1981)
Page 12
- 2. Finding (Criterion H) ,
Recommendation
Response
- 3. Finding (Criterion J)
Recommeiulation
Response
LICENSED OPERATOR TRAINING (INPO Procedure TQ.5)
An evaluation was performed to determine if initial training for licensed operators is sufficient to develop the skills and knowledge necessary for performance of assigned job functions. -
~
s
SEQUOYAH (1981)
Page 13 LICENSED OPERATOR REQUALIFICATION TRAINING (INPO Procedure TQ.6)
An evaluation was performed to determine if continuing training for licensed operators is sufficient to maintain the skills and knowledge necessary for performance of assigned job functions.
- 1. Finding (Criteria C and E)
Recommendation
Response
e SHIFT TECHNICAL ADVISOR TRAINING (INPO Procedure TQ.7)
An evaluation was performed to determine if Initial and continuing training for shif t technical advisors (STA) is sufficient to develop and maintain the skills and ,
knowledge necessary for performance of assigned job functions.
i
- 1. Finding (Criterion C)
SEQUOYAH (1981)
Page 14 Recommendation
Response
- 2. Findina Rec o~ mmendation
Response
. MAINTENANCE PERSONNEL TRAINING (INPO Procedure TQ.8)
An evaluation was performed to determine if initial and continuing training for maintenance personnel are sufficient to develop and maintain the skills and knowledge necessary for performance of job functions.
- 1. Findina e
R'ecommendation
l SEQUOYAH (1981)
' Page 15
)
)
~
Reso'onse O
e 0
f
SEQUOYAH (1981)
Page 16
. OPERATIONS The area of operations was evaluated using current INPO criteria for perform-ance in the areas of conduct of shift operations, organization and administration, use of procedures, tagout practices, plant status controls, facilities and equip-ment, and shift turnover. The department was staffed with well trained personnel. In particular, the technical knowledge of the shift engineers was impressive. However, improvements could be made in several areas, particularly conduct of shift operations, the use of procedures, and plant status controls as described in the following findings.
OPERATIONS ORGANIZATION AND ADMINISTRATION (INPO Procedure OP.1)
An evaluation was performed to determine if the operations organization provides for efficient accomplishment of required tasks. Areas reviewed included crganizational structure, job descriptions, shift administrative assign-ments, written and oral instructions and orders, and administrative programs.
Finding Recommendation
Response
OPERATIONS FACILITIES AND EQUIPMENT (INPO Procedurc OP.2)
An evaluation was performed to determine if plant facilities and equipment are operated and maintained in a manner that ensures safe and efficient operation.
Areas reviewed included equipment operability, equipment availability, effect of '
the working environment on safe and efficient station operation, adequacy of communication equipment, and shift station assignments.
Finding
=
- SEQUOY AH (1981)
.. Page 1" CONDUCT OF SHIFT OPERATIONS (INPO Procedure OP.3)
An evaluation was performed to determine if shift operations are conducted in a safe and reliable manner. Areas reviewed included operator activities, plant cleanliness and order, response to abnormal conditions, logkeeping practices, reliability of control room instrumentation, and operator awareness of plant conditions.
- 1. Finding Recommendation
Response
- 2. Finding
- Recommendation 4
Response
- 3. Finding Recommendation ,
I
Response
} f
-, - - - - , . -e,- ,----.,n-,r- ---- e,e - , -y e---~.--.-- m n _ _ ,.,-,-a-. .-,,-,-,-r-, -p--- - - - , ,,,_.- -.,w-,.- . - , em-,, , , ,- ---
SEQUOYAH (1981)
,, Page 18 PLANT OPERATIONS PROCEDURES (INPO Procedure OP.4)
An evaluation was performed to determine whether procedures were properly used to conduct plant operations safely and reliably. Areas reviewed. included management policy for utilization and revision of procedures. In addition, procedures were reviewed for. clarity, availability, continuity, identification of
" sequence required" actions, and suitable advisory information.
- 1. Finding (Criterion A)
The policy defining the use of procedures is not sufficiently comprehen-sive to provide adequate guidance to users of procedures.
Recommendation
Response
l
- 2. Finding Recommendation t
Response
i
SEQUOYAH (1981)
Page 19 PLANT STATUS CONTROLS (INPO Procedure OP.5)
An evaluation was performed to determine if plant status controls ensure adequate equipment and system availability. Areas reviewed included manage-ment programs and 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 special conditions such as outages, accident recovery, and refueling.
- 1. Finding Recommendation
Response
- 2. Finding (Category II)
Rec'ommendation
Response
S111FT TURNOVER (INPO Procedure OP.6) ,
An evaluation was performed to determine if a continuous, correct understanding ,
of plant conditions is maintained by all shift positions. Areas reviewed included programs and policies for controlling turnover practices for shift stations, checklists, operating panel reviews, and review of plant activities in progress or planned.
Finding
SEQUOYAH (19E1)
,, Page 20 TAGOUT PRACTICES (INPO Procedure OP.7)
An evaluation was performed to determine if established tagout practices ensure protection for personnel and plant equipment. Areas reviewed included senior t
reactor operator (SRO) approval of safety-related tagouts, double verification of tagged equipment for personnel safety, double verification of important manual valves that are repositioned during maintenance or test, tag coloring and numbering, and clearance logs.
- 1. Finding (Criterion A) l Recommencation l
~
Response
- 2. Finumy, Re'commenoauon Resynne e
9 l
f
I SEQUOYAH (1981)
Pega 21 MAINTENANCE The evaluation included the maintenance organization, preventive maintenance l program, work control system, maintenance history, control and calibration of l
, test equipment, procedures, facilities and equipment, and control of special processes.
The maintenance organization is responsive to immediate problems and short-term goals. However, significant management effort is needed to improve the long-term maintenance effort. Specific areas for consideration are presented m the following findings.
MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA.1)
The maintenance organization and administrative programs were evaluated to determine their effectiveness in supporting safe plant operations. Areas reviewed included the organization structure, staff size, assignment of authori-ties and responsibilities, training, and certain administrative programs.
Finding (Criterion D) e Recommendation -
4
, , - , , ~ , . ,,
SEQUOYAH (1981)
.., Page 22 MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA.2)
The location, size, and condition of offices, work, and storage spaces were examined in 6ddition, the number, type, condition, and location of maintenance tools and equipment were reviewed.
Finding WORK CONTROL SYSTEM (INPO Procedure MA.3)
The effectiveness of the work control system was evaluated. The system functions were checked to see if they promote adequate identification of potential work; define and authorize work to be performed by the maintenance 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 (Category II)
Recommendation Ow
Response
MAINTENANCE PROCEDURES (INPO Procedure M A.4)
The team evaluated the degree to which procedures enhance the quality and effectiveness of maintenance activities. Procedures and manuals were examined
- to determine the types of maintenance covered, scope, level of detail, review '
and approval process, document control requirements, and methods of revision. '
Finding
SEQUOYAH (1981)
Page 23 MAINTENANCE HISTORY (INPO Procedure M A.5)
The ability of maintenance history records to support maintenance was reviewed.
Arcas covered were the equipment included in maintenance history, content and accessibility of records, history review and evaluation methods, and procedures for program implementation.
Finding PREVENTIVE MAINTENANCE (INPO Procedure M A.6)
The team evaluated the effectiveness of maintenance in optimizing equipment reliability and performance. The preventive maintenance program was assessed to determine if it was well defined and effectively implemented. Other areas of review included criteria used to determine the equipment to be included in the program, frequency of maintenance, effectiveness of program control and coordination, and adequacy of individual procedures. .
- 1. a Findkng (Criterion C)
Redommendation ,
Response
- 2. Finding (Criterion D)
Recommendation' h
OS .
SEQUOYAH (1981)
Page 24
- 3. Finding (Criterion G)
Recommendation Resnanna _
- 4. Finding (Category II)
Recqmmendation
Response
CONTROL OF MEASUREMENT AND TEST EQUIPMENT (INPO Procedure MA.7)
The team evaluated the adequacy and effectiveness of methods used for calibration and control of test equipment and instrumentation. Specifically, methods used for identifying, calibrating, storing, issuing, transporting, and using measurement and test equipment were examined. Procedures establishing anc governing the calibration program and existing calibration records were also reviewed.
Finding (Criterion C) '
Recommendation
~
SEQUOYAH (1981)
Pcga 25
. esponse l
)
CONTROL OF SPECIAL PROCESSES (INPO Procedure Md.8)
The qualification and control of personnel, procedures, equipment, and material were evaluated to ensure the quality of welding processes.
Finding (Criterion D)
Recommendation
Response
9 i
l f
I m,-- -a , -
-r-,+ - - , nr- - , - v----- -- - ---,+ -
~
SEQUOYAH (1981)
- . Page 26 RADIATION PROTECTION AND CHEMISTRY Radiation Protection and Chemistry were evaluated by reviewing performance in ;
radiological protection training, personnel dosimetry, external and' internal radiation exposure, radioactive contamination control, chemistry, solid radioac-tive waste, transportation of radioactive material, and management of radiologi-cal protection. This portion of the evaluation was primarily an examination of programs as they function under normal conditions early in the life of the plant.
- A number of good practices were observed in radiological protection and chemistry. These practices included the use of supervisory radiological protec-tion personnel on backshifts, the training of radiological protection technicians, the calibration program for chemistry instrumentation, and the control of chemical reagents. Several areas require improvement, and they are described in the following findings.
. MANAGEMENT OF RADIOLOGICAL PROTECTION (INPO Procedure RC.1)
An evaluation was performed to determine the effectiveness of the management of radiological protection.
i Finding RADIOLOGICAL PROTECTION TRAINING (INPO Procedure RC.2)
An evaluation was performed to determine if personnel on site have the knowledge and practical abilities necessary to effectively implement radiological protection practices.
Finding i.
PERSONNEL DOSIMETRY ,
(INPO Procedure RC.3) ,
An evaluation was performed to determine if personnel radiation exposures were i accurately determined and recorded.
i t
J
, - - ..- ,.- , , ..m, .__mo. .,. __ _ ,y, , _ . . . . .. , - - - , ,, ,.. ,_. , ,.,%,,.,-_.,_,_.-._m,,,~,..m_, .-__.-rn-. ..--r_ . _ , . ,
SEQUOYAH (1981)
Page 27
- 1. Finding (Criterion B)
Recom mendation Resoonse
- 2. Finding ((
, Recommendation
Response
f
SEQUOYAH (1981)
Paga 28 EXTERNAL RADIATION EXPOSURE (INPO Procedure RC.4)
An evaluation was performed to determine if the plant was minimizing external radiation exposure to personnel.
Finding (Criterion A)
Recommendation Resnorte INTERNAL RADIATION EXPOSURE (INPO Procedure RC.5)
This area was evaluated to determine if internal exposure was being minimized.
Finding f
RADIOACTIVE EFFLUENTS '
(INPO Procedure RC.6)
This area was evaluated to determine if releases of radioactive effluents to the environment were being minimized.
I L.
~
~
SEQUOYAH (1981)
Page 29
. 1. Inding (Criterion A)
Recommendation Rey,nse
- 2. Finding (Criterion C)
Recommenoanon Respons6 ~
SOLID RADIOACTIVE WASTE (INPO Procedure RC.7)
This area was evaluated to determine if the station was minimizing the generation of solid radioactive waste.
Finding (Criteria A. D. and F) '
~
i Re60mmencation 1
i M
SEQUOYAH (1981)
Page 30
Response
TRANSPORTATION OF RADIOACTIVE MATERIAL (INPO Procedure RC.8)
This area was evaluated to determine if the plant is meeting requirements for the transportation of radioactive material.
Finding RADIOACTIVE CONTAMINATION CONTROL (INPO Procedure RC.9)
This area was evaluated to determine if the plant was minimizing the contamina-tion of equipment, areas of the plant, and personnel.
Finding (Criterion A)
Rec'ommendation
Response
---,w.< -,-- --r. ,.w . - - - - - -.- - -r
+-c -- --, - --- ---- - - -- - - --c - . . - , - --- .
SEQUOYAH (1981)
Page 31 CHEMETRY (INPO Procedure RC.10)
This area was evaluated to determine if chemistry parameters are accurately measured and effectively controlled. .
- 1. Findine (Criterion D)
Recuinmendation _
- 2. Finding (Category II)
Recominendation l
s Response - - -
g
SEQUOYAH (1981)
Page 32 e
- 3. Finding (Category II)
Rec 6inmendation
~ -
Response' ss l
SEQUOYAH (1981)
Page 33 TECHNICAL SUPPORT The on-site technical support was evaluated in the areas of organization and administration, plant efficiency and reliability, nuclear operating experience evaluation, plant modifications, and reactor engineering.
ON-SITE TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure TS.1)
An evaluation was performed to determine if on-site technical support is effectively organized and adequately staffed. The capability to perform all assigned duties, responsibilities, and training to enhance engineering skills m re examined. Determinations were made as follows: ,
Finding (Criterion C)
R(commendation ,
\
Response
PLANT EFFICIENCY AND RELIABILITY (INPO Procedure TS.2)
An evaluation was performed to determine if an on-site program exists to '
optimize plant thermal efficiency and reliability by monitoring plant perform- ',
ance routinely and collecting and analyzing pertinent data. Determinations were made as follows:
Finding (Reference Criteria A, C, D, and E) .
- . - - , . - - - - , ,. - . - - . - - , . .. - --.- . . . - - , , - - - . - . - . ..,--- . .~ ---,,
SEQUOYAH (1981)
,. Page 34 Recommendation
Response
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS.3)
An evaluation was made of the current program for evaluating in-house operating events as well as those occurring throughout the nuclear power industry. The reporting, review, and follow-up of corrective actions for in-house events as well as the method for disseminating the information to the appropri-ate plant personnel and the industry were examined. For industry events, examination was made of the sources of reviewed information, of the screening and classification process, of status of actions taken on recommendations from outside sources, and of the disposition of events relevant to the plant. De ter-minations were made as follows:
- 1. Finding (Criterion A)
Recommendation ,
Response
9 e
- -- - - - - - - - - - - , --,--g- - --, - - - -
SEQUOYAH (1981)
,, Page 35
. 2. Finding (Criterion C)
Recommendation
Response
I
- 3. Finding i
Re Resiponse 4
i
- 4. Finding 9
i i
e i
4 0
0 0
1 1
I t
I 5
4
. --- .y. ..-.,...__.,..,___m.__ . - ~,. _ . _ . _ . , , _ , , . _ . - . _ - ~ _ _ . , _ _ , , . _ - , , - . , - - _ - - - - - . . _ _ . _ . . . .
SEQUOYAH (1981)
Page 36 I
a L
Recommendation
.," ~
Resocnse
.e i
PLANT MODIFICATIONS (INPO Procedure TS.4)
An evaluation was made of the plant design change process, including temporary alterations, to determine if design changes are being implemented in a safe and timely manner. Determinations were made as follows:
- 1. Finding c
(Criteria A, D, and F) 4 i
, Recommendation l
l
SEQUOYAH (1981)
Page 37
+
Response
- 2. Finding (Cri Recommendation l
- Response ,_
- 3. Finding (Criterion J)
Recommendation Rao6onse '
e i
-v -
--- -.-- , - - . . . , , , , , . - , , . . - - . - , . - - . , - , - - - - . . , - , . - , - . , , - - - . . . - . , , . - , . , ,- ,_-n.n,,,--..- ..-.. ,,, , , .,
SEQUOYAH (1981)
, Page 38 ON-6ITE REACTOR ENGINEERING (INPO Procedure TS.5)
An evaluation of reactor engineering was made to assess the use of appropriate procedures, computer programs, and control of changes to them and to assess the quality and adequacy of the support functions provided by the on-site reactor engineers during all modes of plant operation. .
Finding .
me S
9 j
G e
i
. 4 SEQUOYAH (1981)
Appendix Page1 ADMINISTRA flVE APPENDIX I. LISTING OF AREAS EVALUATED .
ORGANIZATION AND ADMINISTRATION OA.1 Organizational Objectives OA.2 Organizational Structure OA.3 Manpower Resources OA.4 Administrative Controls OA.5 Management Quality Programs OA.6 Surveillance Program OA.7 Industrial Safety TRAINING AND QUALIFICATION TQ.1 Training Organization TQ.2 Training Administration TQ.3 Training Facilities and Equipment TQ.4 Non-licensed Operator Training TQ.5 Licensed Operator Training TQ.6 Licensed Operator Requalification Training TQ.7 Shift Technical Advisor Training TQ.8 Maintenance Personnel Training OPERATIONS OP.1 Operations Organization and Administration OP.2 Operations Facilities and Equipment OP.3 Conduct of Shift Operations OP.4 Plant Operations Procedures OP.5 Plant Status Controls OP.6 Shift Turnover OP.7 Tagout Practices MAINTENANCE M A.1 Maintenance Organization and Administration MA.2 Maintenance Facilities and Equipment M A.3 Work Control System '
M A.4 Maintenance Procedures
- MA.5 Maintenance History '
MA.6 Preventise hiaintenance MA.7 Control of Measurement and Test Equipment MA.8 Control of Special Processes ,
SEQUOYAH (1981)
Appendix
' Page 2 RADIATION PROTECTION AND CHEMISTRY RC.1 Management of Radiological Protection RC.2 Radiological Protection Training .
RC.3 Personnel Dosimetry RC.4 External Radiation Exposure RC.5 Internal Radiation Exposure RC.6 Radioactive Effluents RC.7 Solid Radioactive Waste RC.8 Transportation of Radioactive Material
- RC.9 Radioactive Contamination Control RC.10 Chemistry TECHNICAL SUPPORT TS.1 On-site Technical Support Organization and Administration TS.2 Plant Efficiency and Reliability TS.3 Nuclear Operating Experience Evaluation Program TS.4 Plant Modifications TS.5 On-site Reactor Engineering 9
d I
o ,e SEQUOYAH (1981)
Appendix Page 3 II. TENNESSEE VALLEY AUTHORITY CORPORATE AND STATION PERSONNEL CONTACTED Manager of Power .
Director of Nuclear Power Assistant Director, Nuclear Power Plant Superintendent Manager, Power Operations
, Quality Assurance Manager - Power Quality Assurance Manager Nuclear Operations Coordinator Radiological Hygiene Nuclear Plant Coordinator Assistant Plant Superintendent (Operations)
Deputy Manager of Power Assistant Plant Superintendent (3)
Compliance Supervisor Director - Nuclear Safety Review Staff Chief, Field Quality Assurance Staff and Member: Nuclear Safety Review Board Chief, Operation Section, Nuclear Safety Review Staff Assistant To Director of Nuclear Power Shift Engineer (Senior Reactor Operator)
Shift Engineer Mechanical Maintenance Supervisor Maintenance Engineer Assistant Maintenance Supervisor - Special Projects Electrical Maintenance Supervisor Instrumentation and Control Maintenance Supervisor Instrumentation and Control Maintenance Planner Engineering Aide Mechanics Foreman Power Stores Supervisor Plant Services Plant Training Officer Operations Supervisor Assistant Unit Operator Instructor Training Shitt Engineer Supervisor - Nuclear Engineering Group Reactor Engineer Instrument Maintenance Supervisor Assistant Operations Supervisor Assistant Shif t Engineer Unit Operator Assistant Unit Operator Engineering Supervisor Reactor Engineering Unit Supervisor '
Shift Technical Advisor Technical Engineer - Results Unit '
Nuclear Experience Revtew Panel (NERP)- Secretary Reactor Engineer Branch Supervisor Reacter Engineer Branch Engineer Administrative Analyst Assistant Director - Operations (Actir.g)
NOTEPAD Coordinator
. .- I SEQUOYAH (1981)
Appendix Page 4 II. TENNESSEE VALLEY AUTHORITY CORPORATE AND STATION VERSONNEL CONTACTED (Cont'd)
Compliance Unit Supervisor (on-site) .
Auxiliary Unit Operator Plant Modifications Coordinator Document Control Supervisor Assistant Operations Engineer Control Panel Reactor Operator Shift Engineer (Operations)
Supervisor, Radiation Control Unit Radiation Control Technician Engineering and Safety Supervisor Chemical Unit Engineer
- Chemical Unit Supervisor Operator Chemical Technician Health Physics Trainer Chemical Unit Engineer
, Chemical Unit Supervisor Operator i Chemical Technician
. Management Services Supervisor Plant Records Supervisor Nuclear Engineer Administrative Officer Personnel Officer Quality Assurance Engineer l
9 I
i i
6
{
. 9Es M 94 M . 9 M M W eF M
'J. ".".T.J- """4lllll".".L'::":::L*";:ls*3.".".*;'."::.'. ;;T"".~J": """"L"2;,. ..-c .OG~"0"O.~.,." -
. - . ~ . - -
w:u84
gurv coww- SAN ONOFRE l1953)'~~~
Page 29
.w. RADIOLOGICAL PROTECTION ..
RADIOLOGICAL PROTECTION ORGANIZATION AND ADMINISTRATION PERFORMANCE OB3ECTIVE: Radiological protection organization and administration
' should ersure effective implementation and control of radiological protection activities.
- Findirg (RP.l-1)
Recommendation Resporue Findirg (RP.1-2)
Recommendation Io H WEA
aan umurxn (Iyss)
. . Paga 31 vEXTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: External radiation egasure controls should minimize per-
. sonnel radiation e.xposure.
l Fuufing (RP.4-1)
NTERNAL RADIATION EXPOSURE PERFORMANCE OBJECTIVE: hternal radiation exposure controls should minimize inter-
~
nel exposwes. , , . , , ,
l' ? - -
~
Findirg (RP.J-1)
- -w _i
,5 6
Recommendation s
. ragese- ~ '
- Respome i RADIOLOGICAL PROTECTION INSTRUMENTATION AND EQUIPMENT' PERFORMANCE OB3ECTIVE: Irntrumentation arw! equipment used to obtain measurements of radioactivity should be calibrated, used, and maintained so that results are accurately determined.
Finding (RP.6-1)
Recommendation Resporse l
l l
\
SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Solid radioactive waste controls should minimize the volume l
of radioactive waste and ensure safe transportation of radioactive material.
Findits (RP.7 1)
M ' ' ' F_ _1'_ N_T E l_E P - - '" -- -
. _ . . . _ . -- - - .. , . n ra
~
Pcge 33 Recommendation
- Rapeme t
PERSONNEL DOSIMETRY PERFORMANCE OBJECTIVE: The personnel dosimetry program should enswe that radia-tion exposures are accurately determined and recorded.
o Finding (RP.8-1)
Recommendation -
F S
- e -
_ . _ _ _ . . _ . _ . . . . . . . -- - ~
hAN ONOFRE (i9h)' ~
Pcge 34 i -
i RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE:
contamination of areas, equipment, and personnelRadianctive contamination c '-
Finding (RP.9-1)
Recommendation
Response
9 ewm . _
w_, ,
3AN'ONOFRE'(fgie)~
- P:ge 35 15ndirg;,(RP.9 2) .
i - Recommendation l
-Resparse t I
1sn****y,
, -p y
'* * " i ' . s e'e't .- ,,
m -f-
.y; - .
yg.m. .
0 e
.~... w.=wrnu o nei
. ','
- Pcg2 36
? CHEM 5TRY
.* CHEM 5TRY ORGANIZATION AND ADMINISTRATION l PERFORMANCE OBJECTIVE: Chemistry organization and administration should ensure effective control and implementation of chemistry activitics.
1 1
Finding (CY.l-1)
I
~,' Recommendation
.=
. ~ , - - - .
.. -d . .
A r. b nc .
. ,4 .
Findiry, (CY.1-2)
{
ersts m 3 r m a
^
l* -* . Fags 37.
~...
g .- g. '=~ . ,,
,4
- *W i
S p
W s
i 6
l
+
Findirig (CY.1-3)
L b
Recommendation 4
t.
IW i
i.; f I
i i
r e l
I ':
I 4
! +
l 0 1~
1' . i i !
I I
I.
1' 1~
k' --r -r--,_~._.m
- .,__._,m._.,.___. _. _ _
~_,__,_
'w uwjsL Evaluation b Report s July,1981 Paisaces Nuc ear P ant consumers Dower Comoany
~
7
.2 .
S',
INPO N(si 4
a - - s.
EVALUATION of PALISADES NUCLEAR PLANT Consumers Power Company
. t o
O July 1981
's
. i; .
. '. . PALISADES (1981)
, Pqe1
SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of Consumers Power Company'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 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.
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 industry and written evaluation criteria furnished to the plant in advance.
Information was assembled fr'om discussions, interviews, observations and re-views of plant documents. Emergency preparedness was not included in the 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. .
DETERMINATION i
'g, .
PALISADES (1981)
Page3 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 evaluation.
E. P. Wilkinson President -
O
. . . . 's.
..' PALISADES (1981)
Page 3 Consumers Power Company Response Summary Consumers Power Company concurs with INPO's conclusion that the Palisades Plant ". . . is being safely operated." Consumers also 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 several broad areas of improvement that will have the greatest impact on addressing most of the findinn
, Specific implementation dates have been established wherever possible.
Consumers will continue to welcome follow-up INPO evaluations to assess program implementation and effectiveness.
S 4
- - . - . . - - . . , - - . . ~ - . . - - -.-, ,. - . _ _ . . . , . - .. . - - - - - _ . - -
l
,. ',_ b PALISADES (1981) l Page 4
, l DETAILS This portion of the report includes the detailed findings. It is composed of six sections, one for each of the major evaluation areas. Each section is headed by a 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 generally recognized as desirable, accepted techniques of industry and manage-ment are listed as General Criterion. The evaluation procedures that were used
, are listed in the ADMINISTR ATIVE APPENDIX.
OROANIZATION AND ADMDf1STRATION In this area, the organizational structure, personnel qualifications, administra-tive controls, management goals and objectives, quality assurance, industrial safety and equipment surveillance were evaluated.
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 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 ,
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.
OBJECTIVES ,
(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.
- The objectives were examined to determine if they provide substantive guidance to managers and supervisors and support the plant and overall company objec-tives. The degree to which the objectives are used to guide day-to-day activities was also reviewed.
Finding ORG ANIZATION STRUCTURE -
(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 operation. Areas reviewed included applicability of the organizational structure
- S,
~ --
- PALISADES (1981)
. Page 5 diagrams, position descriptions for all station personnel, personnel performance evaluations, supervisors' authority, assignment of backup personnel for key positions and staffing levels.
- 1. Finding (Ref. Criterion A)
Recommendation
Response
- 2. Finding (Ref. Criteria B and C)
Recommendation
~
Rupme
. 'b .
PALISADES (1981)
._ . :: . . Page 6 ADhbMISTRATIVE CONTROLS
(!NPO 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.
Finctine (Ref. Criterion E)
Recommenostion
Response
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 th,e independence of the QA staff.
Finding (Ref. Criterion B)
Recommendation
Response
e
PALISADES (1981)
Page 7 INDUSTRIAL SAFETY (INPO Procedure OA-106, Revision 1)
The team examined the industrial safety program to determine if management is clearly committed to industrial safety, the program is supported at all levels of the plant staff and the program is effective in minimizing safety hazards and accidents.
Finding SURVEILLANCE PROGRAM (INPO Procedure OA-107, Revision 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 not adversely affected during te, sting and identify and resolve deficient condi-tions found. ,
Finding 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 reviewed included the application of job and task analysis to each station position, the program for personnel selection and promotion and the program for periodic review of job and task analysis.
Finding (Ref. Criterion A)
b.
FALISADES (1981)
~ ,; Page 8 TRAINING AND QUALIFICATION 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 operators, non-licensed operators, shift technical advisors, mechanical and electrical maintenance personnel and instrumentation and control (!&C) techn!- .
clans. Positive features noted were that the facility has established a commit-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 licensed operators and evaluation of training effectiveness.
TRAINING ORGANIZATION AND ADMINISTRATION (INPO Procedure TQ-211, Revision 2)
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. Finding Recommendation
Response
- 2. Finding e
- 3. Finding
~ '
'w.
PALISADES (1981)
Page 9 Recommendation
Response
t
- 4. Finding Recommendation Respome' '
TRAINING RESOURCES (INPO Procedure TQ-221, Revision 2)
The team examined the training feellities, equipment and materials available to support training programs for plant personnel.
- 1. Finding
PAUSADES (1981) r --
. Page 10 c.
Recommendation Response ~
~
TRAINING EFFECTIVENES8 (INPO Procedure TQ-231, Revision 2) --
The team examined plant management and training organ:tation practices '
relating to the evaluation of training program effectiveness, toe cudit of training activities and the evaluation of instructor and trainee performance in training programs.
- 1. Finding (Ref. Criterion A)
Re' commendation
Response
NON-UCENSED OPERA 1DR TRAINING (INPO Procedure TQ-242, Revision 2)
The team examined the training program and training practices used to initially quellfy non-11 censed operator candidates and to maintain and improve the quellflettions of existing non-licensed operators. -
- 1. Finding l
1
'b.
PALISADES (1981) ,
, , Page 11 b
Recommendation Reiponse UCENSED OPERATOR TRAINING (INPO Procedure TQ-243, Revision 2)
The team examined the training program and practices used to initially qualify license candidates.
Finding UCENSED OPERATOR REQUAUFICATION TRAINING *
(INPO Procedure TQ-244, Revision 2)
The team examined the requalification programs and training practices used to maintain and improve the qualifications of licensed personnel.
Finding (Ref. Criterion G)
- Recommendation
Response
b.
~
~ * ~
~ ' PALISADES (1981)
Page 12 SH5T TECHNICAL ADVISOR TRAINING (INPO Procedure TQ-245, Revision 1)
The team examined the qualification program and training practices used to qualify shift technical advisor (STA) candidates and to maintain and improve the qualift. ations of the STA.
Fi.wiing (Ref. Criterion D)
Recommendation
~ ~ '
Response
e S
4 e
G 9
i l
l
.m,
-" ~ i .
Q
~ PALISADES (1981)
Page 13 OPERATIONS O
f 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 turnover.
'The team found that the plant is generally clean, control room access is well controlled and the use of fixed maintenance tagouts is an efficient method of performing switching and tagging orders.
It was noted that improvements could be made in the areas of conduct of shift operations, tagout practices, organization and administration, plart status con-trols and shift turnover. These imp ovements are discussed in detail as follows. ,
r CONDUCT OF SHIFT OPERATIONS (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 conditions. ~
Finding (Ref. Criterien C) ',
- Recommendation
Response
i TAGOUT PRACTICES (INPO Procedure OP-302, Revision 2)
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 logs.
- l. .
r ,
PALISADES (1981)
' T , ,J. ,
Pag 314 I,' -finding (Ref. Criterion G) l Recommendation Response -
OPERATIONS 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 structure, job descriptions, shift administrative assignments, written and oral instructions and orders and miscellaneous admin-istrative programs.
Finding Recommendation
Response
e o
k
r PALISADES (1981)
~
. . . . . _: . Page 15 USE OF PROCEDURES (INPO Procedure OP-304, Revision 2)
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 use 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 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 special conditions such as outages, accident recovery or refueling.
Finding 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.
Areas reviewed included equipment operability, equipment availability pro-gram (s), working environment, adequacy of communication equipment and watch station assignments.
Finding l
l l
- t i
L
F i -
~ ' '
g,
~- - -
' PALISADES (1981)
, Paga 16 3*
SNIFT TURNOVER
, (INPO Procedure OP-309, Revision 2)
An evaluation was performed to ensure continuous, correct understanding of station conditions is maintained at all shift positions. Areas reviewed included 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)
Re60mmendation
Response
i e
5 9
9
. . PALISADES (1981) e....... ,
p g 37
.- L: ~ .
MAINTENANCE l 1
l ,
The maintenance organization, preventive maintenance programs, maintenance l procedures, maintenance history and administrative systems for centrolling and !
documenting maintenance work and speelal processes were evaluated. The -
methods used to control test equipment were reviewed, and the overall adequacy of the maintenance facilities and equipment was assessed.
l I
l MAINTENANCE ORGANIZATION AND ADMINISTRATION (INPO Procedure MA-401, Revision 2) i An evaluation of this area was performed to assess how effectively the l maintenance administrative programs and organization contribute to the per-
! formance of maintenance tasks. Areas reviewed included organizational strue-ture, reporting requirements and practices, staff slae, training and certain administrative programs. -
l
- 1. Findint 9
Recommenestaon 1
9 t t
Response [
i i
i r L
1 l I l .
. i
. . PALISADES (1981)
-l, Page 18
- 2. Findine (Ref. Criterion G) l Recommendation
Response
4 s
PREVENTIVE M AINTENANCE (INPO Procedure M A-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. Findine Re6ommendation
Response
l
'w PAUSADES (1981) s Page 19
- 2. Finding Recommendation
Response
- 3. Finding (
Recommendation
Response
- 4. Finding
PALISADES (1981)
. e, - Page 20
~ ~
RecommendsOon
, . Response M AINTENANCE PROCEDURES
(!NPO Procedure MA-403, Revision 2)
This performance area was evaluated to assess the adequacy of maintenance procedures and the extent to which procedures are used. Procedures and manuals were examined to determine the types of activities covered, scope, level of detall, review and approval process, document control requirements and
. methods of revision.
- 1. Finding Recommendation i
Response
i e
i I '
r-
'b.
PALISADES (1981) 1 : I ', , ; , Page 21 n
- 2. Finding Recommendation Response ,
WORK CONTHOL 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 maintenance 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 Recommendation
'b.
PALISADES (1981)
,, , Page 22
Response
e M AINTENANCE 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 implementatien 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 Recommendation
Response
- 2. Finding Recommendation i
I
.. _ , , , , _ . . PALISADES (1981)
- - 3 + Page 23 Resiponse
- 3. Finding i Recommendation Response '
CONTROL AND CALIBRATION OF TEST EQUIPMENT AND INSTRUMENTATION
, (INPO Procedure M A-406, Revisian 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 examined. Procedurss establishing and governing the calibration program and records were also reviewed.
- 1. Finding Recommendation
'N,
. . . 'b.
- ._:I .: 7 .
PALISADES (1981)
.- Page 24 Reprse .
- 2. Finding Recommendation
Response
. . 8 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 MAINTENANCE FACILITIES AND EQUIPMENT (INPO Procedure MA-408, Revision 1)
The evaluation of this area was performed to determine if facilities and 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, typc, condition and location of maintenance tools and equipment were reviewed.
's,
. . . . .. _. . : PALISADES (1981)
Page 25 Finding Recommencation
Response
t 0
e e
Y
~ '
PALISADES (1981)
. ..- . Page 26 RADIATION PROTECTION AND CHEMISTRY 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 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 chemistry programs were adequate to protect the public, plant workers and the environment.
s RADIATION PROTECTI N AND CHEMISTRY ORGANIZATION AND ADMINISTRATION (INPO Procedure RC-501, Revision 1)
An evaluation was performed to determine the effectiveness of-the radiological protection and chemistry organizations and their associated administrative controls. This area was evaluated by reviewing training plans and records for radiological protection and chemistry technicians, interviewing radiological protection technicians, reviewing records of audits and appraisals performed by other organizations along with corrective actions taken and a review of the health physics and chemistry organization.
- 1. Fin, ding (Ref. Criterion C)
Recommendation Response '
'w
' '~' ~ ' # ' PALISADES (1981)
'f '._. Page 27 N. .
- 2. Finding (Ref. Criterion D)
Recommendation .
Response
- 3. Finding (General Criterion)
Recommendation 1
=
h J
l
-- . - , . . . . - - - . . - . . _ , . . _ , , _. , ,,, . . , , . - ,_ ... ., , , . - . _ ~ . , - , _ - - . _ , - - . , - .
b
- :: PALISADES (1981)
~ z' . . Page 28
Response
i ALARA PROGRAM (INPO Procedure RC-502, Revision 1)
- An evaluation was performed to determine the effectiveness of efforts toward maintaining personnel occupational radiation exposure as low as is rea' sonably 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)
Recommendation
. =
b PALISADES (1981)
- - L, . . - Page 29
Response
'm*
PERSONNEL DOSIMETRY (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 exposures. Areas examined included the scope of the dosimetry program, procedural controls, dosimetry selection and use, system operation and exposure records. ,
Finding (Ref. Criterion D)
Recommendation
Response
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 revit w of surveillance data and controls placed upon access to and from work areas.
Finding m
O
N..
- PALISADES (1981)
Page 30 WASTE AND DISCHARGE CONTROL (INPO Procedure RC-505, Revision 2)
This 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 there should be none. This area was evaluated by reviewing records of solid, liquid and gareous wastes, tours of areas containing waste processing systems and waste discharge monitors and tours of the radiochemistry laboratory. I Finding (Ref. Criterion E)
Recommendation Reyme .
RADIOLOGICAL SURVEY EQUIPMENT CONTROL AND CALIBRATION (INPO Procedure RC-506, Revision 2)
An evaluation was performed to determine the effectiveness 'of the plant's-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.
Finding (General Criterion)
PALISADES (1981)
.--- Page 31 l
'
- itecommendation
Response
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 t aining presented to personnel who enter radiologically controlled areas. Find-ings were as follows:
- 1. Finding (Ref. Criterion B)
- ~ ~
Recommendaticn Reisponse
- , - - - - - - - , - - . - - - - , , e - --7 -.,--, >
PALISADES (1981)
_' -- - ; ; Paga 32
- 2. Finding (Ref. Criterien D)
Recommencation
Response
PROCESS WATER CONTROLS (INPO Procedure RC-50&, Revision 2)
An evaluation was ' performed to determine the effectiveness 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 chemistry. Process water controls appeared to be effective in minimizing corrosion.
Finding ,
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 building and turbine building.
Finding (Ref. Criterion C) y , - 9 - , ., ---- _ _ . _ , _ - w. -- - . - - ,
w.
PALISADES (1981)
Page 33 G
G L
Recommendation O
L
Response
o
. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ - - - - ~
. w ie_
s PALISADES (1981) e - - . Page 34 RESPIRATORY PROTECTION PROGRAM (INPO Procedure RC-511, Revision 2)
Finding r-s 9
O e
e G
- O 9~
- m '
. __ PALISADES (1981)
Page 35 TECHNIC AL SUPPORT 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-bilitigs 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 such engineering activities were also reviewed.
There was evidence that management has reviewed'the effectiveness of the engineering support activities and initiated beneficial organization and program changes in several areas. More changes have been planned for the future.
~
TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION (INPO Procedure T5-701, Revision 1)
The team evaluated the Technical Department to determine if it is capable of
'perfor, ming 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)
Recommendation
Response
- 2. Finding (Ref. Criterion D)
~ ' ~ - '
PALISADES (1981)
Page 36 Recommendation
~
Response
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)
Recommend'ation
Response
. . - , . - , - . , . . - . - - - . . - _ _ - - - . ~ , - . . , , - - . - - - . - , _ - . - -
. .E..._. '**
- ~~#~ " l
, ~. PALISADES (1981) j Page 37 .
- 2. Finding (Ref. Criterion D)
Recommendation
Response
~
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM (INPO Procedure TS-703, Revision'1) 4 The team examined the program for handling in-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)
Recommendation
Response
e
~
g
- ,_,
- ,;. , , PALISADES (1981)
. i; . Page 38 PLANT MODIFICATIONS (INPO Procedures TS-704, Revision 1)
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.
Finding (Ref. Criterion 1)
Recommendation
Response
ON-SITE REACTOR ENGINEERING (INPO Procedure TS-705, Revision 2)
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)
Recommendation
Response
l
. 1 PALISADES (1981)
Page 39 e
e e
O 4
e O
b PALISADES (1981)
-" ~ ~J , . APPENDIX
, Page1 ADMINISTRATIVE APPENDIX 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 OA-108 Personnel Qualifications TRAINING 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 Traininir TQ-245 Shift Technical Advisor Training OPERATIONS OP-301 Con' duct of Shift Operations -
OP-302 Tagout Practices -
OP-303 Operations Organization and Administration OP-304 Use of Procedures OP-305 Plant Status Controls O P-306 Operations Facilities and Equipment OP-309 Shif t Turnover MAINTENANCE MA-401 Maintenance Organization and Administration MA-402 Preventive Maintenance MA-403 Maintenance Procedures MA-404 Work Control System MA-405 Maintenance History MA-406 Control and Calibration of Test Equipment and Instrumentation M A-407 Control of Special Processes MA-408 Maintenance Facilities and Equipment i
, . - - , , , . ,e wem.-,-,,n-- - - - ,_w-w-~ ---, - - - - --c--n - - , - * -
~
PALISADES (1981)
. u. ' APPENDIX
, Page 2 4
RADIATION AND CHEMISTRY RC-501 Radiation Protection and Chemistry Organization and Administration RC-502 ALARA Program RC-503 Personnel Dosimetry RC-504 Radiation Surveillance and Control -
RC-505 Waste and Discharge Control RC-506 Radiological Survey Equipment Control and Calibration RC-507 Personnel Health Physics Indoctrination RC-508 Process Water Controls RC-509 Health Physics Facilities and Equipment RC-511 Respiratory Protection Program TECHNICAL SUPPORT TS-701 Technical Support Organization and Administration TS-702 Engineering Support TS-703 Nuclear Operating Experience Evaluation Program TS-704 Plant Modifications TS-705 On-Site Reactor Engineering 4
o 0
O e
o n- ,- -v--, - , - - , - - -- , , , , , . , . - , + -
- , - - - - - - - ~ ~ - , - - , - - - - - - - - - - -, , - - - - ,mw, - - , - , - -
N.
- J PALISADES (1981)
,,,- APPENDlX
_.- . Page 3 II. CONSUMERS POWER COMPANY PERSONNEL CONTACTED Chairman and President
.Exehutive Vice President, Energy Supply Department Vice President, Nuclear Operation Department General Manager ' ~ ~
._ Director, Nuclear Operations Training Department Operations and Maintenance Superintendent Technical Superintendent Chemistry and Health Physics Superintendent Operation Superintendent Maintenance Superintendent Quality Assurance Superintendent 4
Administrative 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 Mechanical Maintenance Supervisor .
Assistant Mechanical Maintenance Supervisor 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 -
- . w, PALISADES (1981)
APPENDIX
- . : .~
~~, - Page 4 II. CONSUMERS POWER COMPANY PERSONNEL CONTACTED (Cont'd)
Mechanical Repairman "B" '
Welder "A" Electrician "A" i
0 0
e e
9 1
f l
w v - - .- - - . , . , - - , - - - . - - ,- m __, -, , ,.,n., , . _ , _ _ - _ . , , , . _ __, , , , , . _ , _ . , ,_ _, _ . _ _ _ ,
. g 9 e %
9 g
4 w
- m a eM
~ *, e o
9 9
e
-=oe.m- -
. %-.e - ....v.4 8 - - .
. - v.s s 4. . e.s. es.r . 4.m.m. .pga
. .8 .t. 9.u s
. 1 v...ec-
-e.
e ne.he. 84 e.w e.P...e .eNE.*C.'D.8. M It# 8h e
.e.e.-s..e-....--
.l.* 90.s
,.4 e.w e..i.
e f eet.s s. N
- e. W .. ee w
4 wm su.usse 4 sine 4PS i. eau ee 4s.= e 3N 18. mm 1 e.g o e.mor*8 a.m.am m. P.se eMJ.1.se 4.s e Cm .ehat.
8 . h. psi.nese. A s. . . .* **>se'*"* "'.' N W Onee .e I.w.,M M.D8.hs.u .1.t.
ose.m h,ps.n .a Ce . up s h soau5A