ML20023E223

Review of Current & Projected Expenditures & Manpower Utilization for Gpu Nuclear Corp

ML20023E223
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Site:	Oyster Creek, 05000000, Crane
Issue date:	02/28/1983
From:	BASIC ENERGY TECHNOLOGY ASSOCIATES
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^ e y i' I. I \\- A REPORT ON A REVIEW OP CURRENT AND PROJECTED EXPENDITURES AND MANPOWER UTILIZATION FOR GPU NUCLEAR CORPORATION q 1 l CONDUCTED BY l ~ BASIC ENERGY TECHNOLOGY ASSOCIATES, INC. ARLINGTON, VIRGINIA J. I' 1 FEBRUARY 28, 1983 I i Property of GPU Nuclear Corporation Not to be reproduced or distributed without prior written consent of GPU Nuclear Corporation. om f I' t e e. 8306150185 830613 PDR ADOCK 05000289 H PDR . -..- ?-

... c:. .. c. TABLE OF CONTEN'IS CHAPTER PAGE + L, OVERALL ASSESSMENT 1 B. INTRODUCTION A. Objectives and Scope 3 B. Method of Approach 6 C.

Background

11 D. Reporting of Findings 16 Bl. TMI-1 FINDINGS General 18 A. Site Management 20 B. Operations 22 C. Maintenance 23 D. Chemistry it E. Plant Engineering 25 F. Radiological Controk 16 G. Materials Management 28 H. Human Resources 31 1. Administration 31 l I IV. OYSTER CREEK FINDINGS } General 32 A. Site Management 33

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B. Operations 36 C. Decontamination 36 D. Maintenance 37 E. Chemistry 43 F. Plant Engineering 43 G. Radiological Controh 46 H. Nuclear Safety Review 47 1. Administration 48 J. Materials Management 50 i P 9 i ,,---,,w.--. ,--.,--v---,-,-~,,--.-.,w-....., _.---._,-e-9--,-------,----

PAGE V. NUCLEdR ASSURANCE FINDINGS General 52 A. Reading Group 58 B. Training l Corporate / Headquarters 54 TM1-1 58 i Oyster Creek 59 l l C. Quality Asurance Engineering 80 Operations 81 Manufacturing Assurance 82 QA Plan 82 TMI-1 QA $3 [ VI. TECHNICAL FUNCTIONS FINDINGS 's General 84 A. Efft.etiveness 85 B. Engineering Services 86 C. Licensing and Regulatory Affairs 88 D. Engineering and Desiga 83 l E. Systein Engineering 70 F. Engineering Projects 74 ~ G. Startup and Test 78 77 H. Chemistry VII. ADMINISTRA'I10N FINDINGS General 79 i l A. Effectivenes 79 l l B. Management Service 81 81 C. Operational Analysis .g D. Materials Management 82 i 83 3 E. Security 92 F. Safety and Health VIII. HUMAN RESOURCES FINDINGS 94 IX. RADIOLOGICAL AND ENVIRONMENTAL CDNTROL FINDINGS 98 General 99 A. Radiological Engineering l} B. Environinental Monitoring 100 m-r M d g .n-,- -, - - - - -,,---,-.-n-,- A "'~'""***S9'**"**

i PAGE X. MAINTENANCE AND CONSTRUCTION FINDINGS General 102 A. Corporate 103 XI. COMMUNICATidNS FINDINGS 105 ~ XH. GENERAL FINDINGS f A. Stpervision 106 B. Paperwork 110 C. Decision-Making 112 D. Poor Performers 114 E. Staffs 115 XIII. COMPARATIVE ANALYSIS RESULTS A. Summary 116 B. Objective 116 O. Methal of Approach 117 ( D, Lnpower Anslysis Ruults 11 E. Cost Anelysis liesults 136 I 1 l. e = a G e iii le v -- -. }

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CHAPTER I. OVERALL ASSESSMENT Basic Energy Technology Associates, Inc., (BETA) was tasked by GPU 4 Nuclear Corporation (GPUN) in January 1982, to conduct an independent l. review of the Three Mile Island, Unit 1 (TM1-1) and the Oyster Creek (0/C) I nuclear plants in order to identify areas where improvements could be made which would result in work being performed more efficienth and at less overan expense. It is our opinion, based on the extensive review conducted, our knowlege of the nuclear utility industry, and our more. than twenty-eight years of ~ experience in the nuclear power generation field thati in an overall sense, there are very few functions, activities or work efforts, either being done or contemplated by GPUN, at TMI-1 or Oyster Creek that are unnecessary. i We find that in 1979 GPUN embarked on a determined program to create a nuclear utility that had clearly taken to heart the shortcomings of tha past, experienced throughout the nuclear industry for the last three decaJes, and has achieved the espebDity to demonstrate that it non operate avul l f maintain its nuclear plants safely. It is now in the process of being able to I do this e!!ielenty. This effort has not reached tha desired end point as yet; there are stin a number of areas where further effort k needed. However, our review indicates that, regardles of the level within the organization or the particular area reviewed, there is a universrj desire to make GPUN a model of the Industry. GPU management has set the gosh and has recognized that achieving these goals wouM be costly, not on:y in manpower and effort but in dollars, While they evidence concern over these costs and their continuing upward trend, as they should, they show evidence of continued determination, it is our opinion that these goals can be achieved, that costs can be stabilized, and that the organization, with proper direction, can settle down. One major contrbuting factor to the comparatively high cost at GPUN is the number of employees, both inhouse and contractors. In comparison to other nuclear plants of similar age and type, the total number of GPUN l employees used to operate and maintain their plants is high. OveraH yearly l expenses are high. In BETA's opinion this is due to a number of reasons, One reason is that in an areas of its operation, the manning was aDowed to increase as it had to, in order to fulfill the yet to be fuBy defined needs of creating a new and unique nuclear corporation. While GPUN management attempted to exercise some degree of control on this growth, the highest priority was given to getting the new organization established, manned and working on the known tasks which had to be done. In doing so, GPUN i management had to accept the possibility that overstaffing would occur. Given the alternative of understaffing which would have eesulted in goals and objectives not beirg met, a conscious decision was mad.e. 'Ihe net result l was a tendency to overstaff in order to assure that each function was properly covered. Doing this within tight bu%etary constraints did not become a high priority issue within the organization untD the,beginning of, 1982, when some of the elements of the organization began to stabilize and i the overstaffing became evident. 1982 can be viewed as the start of the settNog out phase of the development of GPUN. WhDe there are stin a i l few areas where a partleular group needs to develop further and grow in size, most areas are over-manned. 1 ,_____ _...-.---- n..v

Another reason can be traced ta the irery preinise upon which GPUN was created. GPU management determined that an underlying objective was to develop an organization which had the capability and resources to perform - effectively an those functions considered essential to operate and maintain l-their nuclear plants safely and efficiently. The very nature of this decision dictated the need to increase rather dramaticaDy the number of people on the payroll. While BETA can find inefficiencies in how some of these functions are being carried out, the basic objectives are sound and not necesarDy overdone. E The third reason why GPUN. manpower and costs are higher than other plants can be attributed to the fact that GPUN is the owner of the phnt that had the accident. It was forced by circumstances to react much more rapidly to an of the new requirements imposed by the regulatory agencies. It was also apparent that GPUN had to show concrete evidence that they were taking immediate and bold actions to prove to aB concerned that they ?. were repeting to the accident. This put GPUN in the forefront of the rmelear utility Incustry h muklog char.ges, inaorporating.new procedures and programs, and generaDy increasing the scope and depth of theit coverage. It could Le estimated that GPUN k et least one year ahead of the average of tre indastry in many of these areas. l The substantId build tip of new peop e in a relatively short period cf time created inefficiendes as k typical in any Irrge indurtrial/engineerirg organizstion. Many new people we e hired who were minimally trained or experienced and were put into jobs that were not weH-defined. Growing pain-had to be expected and they are still in evidence, albeit reduced. There are a number of comments that relate to the actual conduct of the BETA review, partleularly with respect to the changes noted by BETA during the year it took place. The. review began in January 1982, and was completed in December 1982. At the outset, BETA concentrated on understanding the GPUN bu%et process; how it was arrived at; how it was approved; how costs were controDed. This brought the reviewers into direct contact with GPUN top management, namely division directors, other directors and managers. What was noted in these early stages were the foBowing: A lack of genuine or serious concern over the budget proces and its importance to controlling oosts. Overly concerned with issues relating to divisional responsibDity. A lack of sense of total ownership with respeet to their role within the overall accomplishment of GPUN objectives. l Much effort being devoted to adjusting to the new functional organization, creating documents and trying to figure out how g work was supposed to get accomplishe4 and I Working to asimilate the large inDux of new people into their organizations. I 2 ~ = - ... n --

Throughout the period of the review, BETA noted significant improvements in each of these. Specific areas where program was most ~; pronounced were: f Throughout GPUN, people were taking the bu%et proces seriously. Procedures and programs were established which ~ allowed people to begin to understand the bu%et proces, to track commitments and expenditures, and to influence the rate of expenditures. The people who were charged with the responsibDity for -j accomplishing work understood and realized that they had the authority, responsibility and wherewithal of controlling c,osts. In early 1982, these functions were perceived to be held by the Administration Division. For a number of reasons, the management of Oyster Qeek, at t sD levels, dramatically improved. Previously noted problems with j attitude at the middle management and worker levels has begun to be turned areund and is now more positive. There was a marked improvement in cooperation between divisions st the lower levels. The attitude of GPUN employees at TMI-1 has remained esentially positive, which, in light of the continuing delays in restart, is an accomplishment. Notwithstanding the above, there still remains a number of areas where progres has been slow or where significant improvement stlH needs to be made. These include: Productivity Broughout the GPUN organization is still at a low level primarily because of the. lack of. proper supervision, poor planning, cumbersome union agreements and late or incomplete technical support. .i Plant maintenance at Oyster Creek and TMI-I has yet.to. reach, the point where required equipment reliability can be reasonabhr_ asumed. 1-Technical support, wh!!e improving is stb 1 slow, unresponsive to plant needs and too often technically incomplete, w> There are a number of actions that* Ban be taken immediately that should result in increased efficiency of the GPUN operation. These are detailed in other chapters of this report but enn be summarized as follows: Continued prcasure by the Office of the President on the Division Directors to strive for more effielency in their operations. Greater effort to force individual managers to make their people more productive and to make better use of GPUN's performance evaluation system. 3 ~

l .r..~-- l i l l Continued effort to reduce paper. 1 i l Continued effort to reduce the smaR *eens" that have been created. ( f-Continued efforts by GPU and GPUN to eliminate inefficiencies caused by past provisions contained within the labor agreements 'f and practices. Continued effort to force acceptance by the workers of greater responsibility for high quality radiological' work performanee. Review the number of people asigned to the plants who perform strictly administrative work. r-Continued effort to improve the irteraction between Techrdgal functions a_nd the sites. !I Continued efforts to make the operatirg divisions, in contrast to the support divisions, feel grcater tesponsibi.lity for cost performances across the board, particularly with respect to contracted work, l With respect to GPUN manning, BETA concludes that, for a number j i. l of reasc,r.s listed below, the current approved level, whDe it can be reduced in certain areas, can not be reduced substantiaBy in the near term (6 to 12 l months) time frame. These reasons relate to: i Continuation of the need to resolve technical and non-technical i issues raised by the regulatory agencies at Oyster Creek and TMI-1. The backlog of known technica1 problems rehted to the two plants. The accomplishment of known maintenance and modification work I at the two plants, l '. The still-existent lack of maturity of the organization and the i [ lack of experience of many of the relativeh newh hired people l [ within the organization. BETA is of the opinion that a multi-reactor, multi-site, functionaBy-run nuclear power utility, in the most ideal situation, can be run with a total of 750 utility people per nuclear plant. 'Ihis assumes a reasonably high degree of inhouse technical espablEty such as' the goal of GPUN. BETA's number for the les than ideal situation is 900 - a number whleh l BETA feels can be scheduled for achieving when major milestones are reached. There is the need to balance the size of the fuB-time GPUN employee level with the size of the contractor effort. Extremes in either direction are harmful. The 900 number should aBow for GPUN to handle in-house those tasks which arise from what could be described as normal operational situations, whereas outside assistance would be required for unu'sual or not often repeated circumstances. Based on where GPUN is today, that would ~ i 4

,e mean a drop of about 200 people. While BETA can, and has identified to the Office of the President where it considers these excess positions exist, a far better approach in the near-term wouM be for the Office of the President to continue applying presure on the Division Directors to cut l excesses where they are identified, and to remove from their roles those people who are not performing at the expected level. Reductions beyond i the100 or so should be possible in the long term but this decision should be based on a review made when the major work effort has subsided and the organization has settled down. I One further objective of the BETA review was to perform a comparative i analysis using cost and manning data from other plants. For a number of I reasons, discussed in Chapter X111 of this report, this analysis did not produce l the hoped for result'. While the comparative data shouM not be ruled out completely as being meaningles, it is not accurate enough to analyze any specific function, group or cost center. Without intimate knowledge of the other plants, how they function, how they are organized and how they collect e and report manning and cost data, it wouM be foolhardy in BETA's opirlon for GPUN to make drastic changes based solely on the accumulated data. There may be sorte adv.tntage 6 hav!ng a freer exchance of 16as between A l the muager ot a giver, function in GPUN with his countstpart in enother utility if the comparative data indicates a glaring disparity la mannir.g. l l f \\ t mw l l l l l O e 5 e, % - Omae oeeO*w e en one e J. 0*

H ' 4 f t 9 I e I f 0 1 CHAPTER E INTRODUCncN n F l l' 4 l. l 1 l l l 9 Y Q '/ l e 4 e t i t I t i l I I

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~ .c____ CHAPTER 11. ' INTRODUCTION A. OBJECTIVES AND SCOPE Basic Energy Technology Associates, Inc., (BETA) was tasked by GPU l Nuclear Corporation's (GPUN) Office of the President in January 1982, to l conduct an independent review of current and projected manpower and overall cost expenses for the Three Mile Island Unit-1 (TMI-1) and Oyster Creek nuclear plants. The review was to cover TMI-2 only to the extent of I-determining allocation of GPUN resources assigned to TMI-1 and Oyster I Creek. ~ The objectives of the review were to: 1. Determine the appropriateness of performing the functions, l activities and tasks currently underway and planned. 2. Make a ju% ment as to the effectiveness and efficiency of efforts being used to perform.those functions, activities and tasks. 3. Perform a comparative analysis, usfrg data obtained from r. number of otha.r utilities, to determine if such an analysis might provide 1 meaningful indicators. The data was to cover manpower, operations j l and maintenance (O&M) costs, espital costa, and general and administrative (G&A) costs. 4. Provide GPUN management with significant impressions throughout the period of the review, and l 5. Provide a final report of the BETA findings, conclusions and p. recommendations. The findings of the first three objectives listed above are briefly L described in Chapter I of this report, "Overall Assessment". Speelfic findings and recommendations relatirg thereto are contained in the remaining chapters of this report. BETA provided the Office of the President with interim reports throughout the period of the review outlining significant impressions. The scope of the BETA effort was to conduct the review in aE of the GPUN divisions, with the exception of TM1-2, as previously noted, covering i every area, function and activity within GPUN. The BETA review of I contractor effort was restricted to interviews of GPUN personnel and records or data in the possession of GPUN. i The comparative analysis involved fourteen privatply-owned nuclear utilities located in the United States andJneluded the two GPUN planta. GPUN resources were used to obtain the' data from the various utilities, put the data in useable form, and provide the data for BETA to analyse. i B. METHOD OF APPROACH 1. In performing the review as previously outlined, BETA felt there were a number of situations existing within GPUN that had to be i 6

I i 'l given egstant recognition throughout the review period. These were: a. Constantly Changing Situation. The major reorganization, which. occurred les than two years. ago, was still in its - r-formative stage. It was a major reorganization, not only in the sense that people were moved, but in very beste terms of organization. A functional organization replaced a typical project organization. Functions, activities and espabilities, heretofore not included within the former structure, were added. The organization grew in size (number of people) over l a relatively short period of time. The BETA onsite review, conducted over a five month period, was stin seeing a process of settling down. Correction of organizationalInterface problems, absorbtion of new people, creation and implementation of new polieles and procedures; these wm all much in evideace throughout the review period. 3 Many instances of inefficiencies, noted by BETA early la its l review, were in the proces of correction and were corrected l by the end of the review. I'! b. Creation of GPL'N. While the newness of the organization, L Biscussed abnve, Efected the BETA review, the character and j i 3 complexity of the new orge!zation wh!ch had been erested also had a marked effect on the review. The c are very few, if any, nuclear util! tie.s that have opted to form a totally complete nuclear organization, structured along functional i lines. This type of management was being put in place by combining the personnel asets of two owner utilities, Metropolitan Edison and Jersey Central, each of which had headquarters espabilities at different locations, Le., Reading, Pa., and Morristown, NJ. In addition, there were groups at k the GPU headquarters offices in Parsippany, N.J., and at both of the nuclear sites. AB of these groups.had to be combined into one organizational entity, while continuing to function. it was also significant to the review that TMI-1 was still in a shutdown condition and undergoing its third year of attempting to get back on the line. A number of critical TM1-1 issues continued to face GPUN during the period of the BETA review including: 1 (1) Steam generator leak problem. (2) Psychological stres issue with tpg.NRC and the courts. (3) The reactor operaloIcheating issue. l. l (4) Issues related to obtaining Atomic Safety 'and Licensing Board (ASLB) and NRC agreement to restart. I Each, in its own way, prevented key GPUN people from devoting their fun attention to the task of making the new organization work. I 7 .. =

c. the Uniqueness of GPUN. Recognition had to be given to the fact that GPUN was created from elements of the company that had experienced the accident at TML While it could be argued that now, after three years, it should not still have an unsettling effect on the organization, its people, and how work is performed, this is not the case. it was apparent throughout the review, that a corporate deelslon had been made shorth after the accident that OPU would embark on a program to create the best nuclear organization in existence. This aspect is important, particularly in the com prative portion of the BETA review, because it shows that, :n many respects, GPU is in the forefront of all of the utilities used in the comparison insofar as aehleving an in-house technical capability, and in reacting to outside (NRC and others) suggestions, demands, or requirements. One element of the BETA review was to see if GPUN had overreacted to these pressurek ~ 2. The method of approach, used trf BETA in conductirg this review, i consisted prl:narily of interviewing a large number of GPUN personnel in order to determine what they considered their job to be, how they performed it, what impMiments they face 4 and where they felt improvements could and shonld be made. In conducting thS review, DETA was able to take advantage of its past involvement with GPUN (1980, Review of Management Capability and Technical Resourecs).which provided BETA with a better understanding of the organization and the key people

involved, Prior to conducting the interviews, BETA reviewed the key organizational documents issued by GPUN in establishing the functional roles. Documents and procedures issued by each Division outlining how that Division operated and interfaced with other 1

Divisions were also reviewed. In addition, BETA was provided with a comprehensive description of the new budgeting and cost accounting system, which was in the proces of being implemented. In order to fulfill the objectives of this review, BETA looked into a number of areas including: a. Determining if the functions, activities, or items of work (O&M and Capital) which are being, or will be, performed are things j which should be done, and second, if they are being performed in an efficient manner. This included reviewing: 1981 and 1982 workplan and bugeY I Assignments of manpower 1 Assignments of work I Planned workload Actual workload Performance 4 Constraints Backlog of work Overtime 8 i

N Rework l Parm-out work Cost and cost control Requirements for work ' Paperwork ~ Concurrence load Decision process r i-b. Conductirg a review of past, current and future manpower I and cost figures for GPUN major contractom used at TMI-1 s 'and Oyster Creek in order to ames the reasonablenes of the effort and the assoelated costs. Conducting a review of major capital cost figures for TMI-1 c. and Oystar Creek. L d. Reviewing the GPUN salary structure to determine if it was '~ nominally in line with the industry and the area. [ Seeing if it was meaningful to compare returned costs at e. GPUN aad other plants on a number of TMI modificatfore required by NRC to be dor.e at all 7.uclear plants that have been done at TMI-I and/or Oyster Creek. L~ f. Seeing !! It was possible to determine the emount of manpower effort that has been estimated in 1982 for handling matters which might be considered unique to 'fMI-I and Oyster Creek because of their close association with TMI-2. r-g, Determining how much money is programmed in 1982 for building up repair / spare parts inventory and compare this to e previous years. t b h. Determining and analyzing turnover and buildup rate of personnel at TMI-1, Oyster Creek and Parsippany for the past year. ~ 3. In conducting the comparative analysis, GPUN management decided they, rather than BETA, would provide the necessary resources to obtain the data from the various utilities. BETA provided GPUN with a list of the types of information considered appropriate for t. review. That 11st was refined, and GPUN, in conjunction with one other utility, obtained data from fourteen nuclear utilities, in all cases someone from GPUN or the other utility visited the plant or the headquarters offices of the utility in qtretion. Upon completion of the data-collecting proces, the data was then entered to a data bank so that the various analyses could be accomplished. The analysis of the data and the conclusions derived @erefrom, as provided in this report, are those of BETA and are not necesarDy those of the persons who collected the data for GPUN. e 9

~ i 4. Two in-depth record analyses were performed to determine if a quantitative measure of effectiveness or efficiency could be

l obtained. In one case, using GPUN people to coneet the data, a

] complete review of available TMI training records covering the period January 1,1982, through March 31,'1982, was conducted Data covering the followirg areas was coBeeted and tabulated: Courses planned to be conducted Courses scheduled to be conducted. I Courses actually conducted Number of students in each class. Frequency and duration of each elass. I. Instructor for each class. 1 Where the class was taught. I Monitors used for the clases. Who they were and whether I reports were written, i Classeoom httendance recorda. l Nature of the. ins *ruction, Le., lecture. elass notec, study, i video tapa. 'l l .~ Tests cc examinations given and, if so, what kind, how l many, etc Critiques held and repwted. i " Customer" involvement ) The other area subjected to a detailed records analysis was TMI-1 Quality Assurance (QA). The review was based cn current written procedures, reports and records available in Quality Assurance, Auditing, Engineering, and Inspection as web as on j personal observations of monitorings, audits, and inspections in I, process. The purpose was to assess the effectiveness of selected control documents and the effort required to process them. Similar i to Training, above, the review covered the first three months of l 1982, in order to make the foBowing determinations: l I j reviews) planned inspections, document Actions (monitorirgs, audits, l Actions scheduled l Actions conducted Time spent in preparing for, conducting, and reporting the QA actions. ~ Alternatives used when scheduled QA actions were canceled or could not be performed. I For each QA seetion, time spent on work other than the principal function, Le., monitorings, audits, inspections, and document review. Established a pertentage for each category of "other work't Percentage of Material Noncompliance Report (MNCR's) [ l I and Quality Deficiency Reports (QDR's) written in the last three months that had been resolved On the average, the amount of QA time required by each procurement action (procurement specification, purchase r requisition, purchase order, receipt inspection, resolution i of MNCR's written at receipt insnection). g e 10

_ __ a . _ __.-. ___ a - -. - I I In both of these detailed record reviews, useful information was obtained pointing up areas where inefficiencies existed. However, neither of the reviews provided a useful means for establishing quantitative measures of work efficiency. It is BETA's opinion that these types of analyses do not lend themselves to - l-determining the efficiency of operations of this nature any more so than work sampling or time studies. More is to be gained by improving the performance of the supervisors, l j l C. BACKGROUND l 1 l r l in early 1980, the deelslon was reached by GPU to reorganize and ~ create a new corporation within the GPU system which would encompass au three nuclear plants, TMI-1, TMI-2 and Oyster Creek. A new corporation, called GPU Nuclear Corporation (GPUN), was formed in September 1980, and officially became functional on January 1,198t The GPUN Corpcration differed from the past organizations in that it was structured along functional lines rather than being project oriented. Under the Office of the President , q there were estabushed nine Divisions, each with a Directors ( I Approved I'ottl Number l Divisinn s [* Of Employ _eje (1982) L TMI-1 340 2. TMI-2 290 3. Oyster Creek 272 l 4. Technical Functions 425 2 !i 5. Nuclear Assurance 265 l ' f-6. Maintenance and Construction 207 , g 7. Radiological and Environmental Controls 255 8. Administration 526 l 9. Communications 34 b

10. Human Resources (not a Division) 34 l

t As of September 1,1982, there were 2611 employees working for or assigned to GPUN at four locations: s TMI, Middletown, PA Oyster Creek (including Forked River), Forked River, NJ h GPU Headquarters, Parsippany, NJ GPU Service Corporation, Reading, PA While the 2611 emp?oyees are identified as GPUN employees, it should be noted that those belonging to a bargaining unit actually remain on the owner company roles (Met Ed and Jersey.Cantral) because, at present, there is no contract between GPUN and the bargaining units. However, for the l purposes of this review, an of these people are considered to be "GPUN employees". Not included within the 2611 employees are a number of contract (or secunded) employees, who are operating within the functional organization of GPCN, La., they are occupying positions within the GPUN framework. In addition, there are varying numbers of contractors who perform work for 11

.....:...-...-...= l l I GPUN. On July 1,1982, there were 558 contractor personnel working under l GPUN contracts. This work is performed either at the sites, such as in the case of construction er modification work, or at locations remote from GPUN, such as for engineering support. Approximately one-third of the l GPUN annual bu%et is devoted to contractor work. * ~ Due to the functional nature of the organization, the. number of people at a given location is a summation of the numbers of employees assigned to each Division located at that site. For example, there are 834 (as of December 1,1982) GPUN employees located at Oyster Creek, yet only 272 report to the Director, Oyster Creek. The others are assigned the remaining Divisions having responsibilities at Oyster Creek. The breakdown of GPUN manpower by location is as follows: Location Employees l I TMFI 750 i TMI-2 537 l Oystec Creek 834 Parsippany 413 l Reading 52 l l The following is a breakdown of how it was planned to allocate the l breakdown of the 1982/3 approved level of GPUN employees by plant assignment. GPU NUCLEAR STAFFING - 1982/1983 (APPROVED LEVEL) LOCATION TMI-1 TMI-2 OYSTER CREEK GPUN 'IOTAL On Site 750 537 834 2,121 i l, Off Site 156 88 261 485 6 TOTAL 906 605 1,095 2,606 Fossil System Lab Personnel 30 Undistrbuted Personnel 9 Saxton Manager m" 1.0 Forked River Support 2.9 l ! Tech.~ Functions Tra' nee

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GPUN SYSTEM PERSONNEL CONTROL LEVEL 2R 12 v--- i.---

b [ rq q ~ 2/3/83 1963 CI'UIC MWUHt7. N210URZ EIERTKM Orster Creek 1MI-I 1NI-2 CPUIC _ Division /Dessutnant _Ot-Site Off-Site 1btal _Di-Site Off-Site 1btal Ot-Site Off-Site _1ctal _0ther _1 Ural. _EXW Offlee of the President 150 Bisentive Offlee 1100 GRB 2.6 2.6 4 1.3 1.3 1.0 1.0 9.1 M.0 1.0 1.0 .5 .5 1DTE WP 36 d 1.8 y -e-1.4 2 y _16.0 .4 .4 .1 2.0 350 Orater creek Divialen 2000. V.P. &, Staff M.0 %.0 2100 Operations 77.0 77.0 2.0 16.0 2120 Reemste Operstlens 33.0 33.0 77.0 2140 Omnistry 22.0 22.0 33.0 2200 P1 ant Fstinseries 39.0 39.0 2300 Maintenance 85.0 22*0 85.0 39.0 l 1UTE 0.C. 2M.0 M d d J 2 72.0 85.0 .350 M-1 Division 3000 V.P. & Staff j 3100 Anninistration 2.0 2.0 3200 Site Operations W. 1.0 1.0 2.0 = (ed 3210 Operattons 7.0 7.0 1.0 3212 Radweste 92.0 92.0 7.0 26.0 92.0 3220 Maintenance 26.0 i 3:30 Omnistry 159.0 159.0 26.0 19.0 15 9.0 3300 Ergineertig 19.0 e 29.0 19.0 29.0 3400 Plans & Progens i 5.0 29.0 hD ~~ 10Du, M -1 _ 5.0 3 d 30.0_ 4- _50.0 d 3r.0.0 _4tXS M-2 Division ~ ,t 4000 V.P. & Staff 4200 site Operatione W. 3.0 3.0 3.0 430 Operations 5.0 i 5.0 5.0 4212 Omnistry . 72.0 72.0 72.0 4220 Maintenance 25 0 25.0 25.0 4260 Plant Ergineer{,g 121.0 121.0 121.0 4300 1henvery Proarame 16.0 16.0 16.0 (; 4300 1.icensitet & Reclose Safety 23.0 23.0 23.0 4300 Rteovery'llreh. Planning 21.0 21.0 21.0 I, 4.0 4.0 6.0 1tIRI. M -g d -0. 290.0 4-g J. 290.0 \\

3 ,i Oyster Cavek i DiviolartfDrpsetsent 0 M ite of f-Site 'DC-1 1Ht-2 .150 meduilest Ractions _ Tot.11 Di-Site O'E-Site Total psite _of f-si te Total _0ther _1UTM. t CFUPC h, 5000 V.P. & Staff 2.1 2.1

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l c.___. i The 1982 GPUN budget, as it was proposed in November 1981, was: Plant O&M Capital Total ($ millions) l TMl-1 53.6 43.0 96.6 l , /C 72.4 79.1 151.5 O l Because of the further delay of the start of the Oyster Creek major outage into mid 1982, and the desire on the part of GPUN management to reduce expenditures, the official bu%et was revised as foBows: t Plant O&M Capital Total ($ millions) TMI-1 53.6 40.0 93.6 O/C 60.0 83.0 125.0 l l Then in February 1982, whch the scope of the TMI-1 steam generator repairs became evident and with a delay in the a;vailability of external i funding foe TMI-2 eleanup, the following eBocation was made as the phn for 198?: l Plant O&M Capital Total ($ millions) i TMI-l ' 74.4 25.0 39.4 O/C 80.0 85.0 125.0 f The returns for 1982 will be approximately: Plant Est. Returns ($ millions) TMI-1 83 O/C 102 D. REPORTING OF FINDINGS in the chapters which follow, BETA has provided a nunber of specifie findings and recommendations which, if taken, should result in a more efficient operation.. The chapters are grouped by divisional responsibility. In conducting the review, it was not always pomble*(o draw a clear Mne between a finding or observation WhEh, if corrected, would direeth ] lead to a cost saving in contrast to just making an improvement in a given I situation. Foe example, included in the Fin' dings section of this report is the observation that it takes too long to complete a personnel action. On the surface, it may appear that correcting this problem does not necesarDy i l result in saving money. We have taken the position that it does, albeit indirectW. Therefore, aB findings which reflect on somehow improving the functionig of GPUN have been included within this report. e 9 16

• ~'

u. S The detaNed comments and recommendations that follow in this report I are aimed at niaking GPUN more effective and effielent. They should not i be interpreted as an attempt to change the t.??arall goals and objectives set by the management. It should also be noted that due to the nature of the BETA review, whlch consisted of several hundred discussions with GPUN personnel, a great many minor observations came to light and were discussed, and subsequenth action was taken to improve or correct the existing situation. These minor points have not been included in the findings and recommendations which follow. Those which are reported are situations either requiring broader management action or issues where presenth approved policy is not being l carried out fully. + h ~ 1 1. O r-l 1-l i i i I pup t .s 17

-.. ma .:..~..~. e o e W G o l 5 CflAPTER E S [' TAII-1 PINDINGS AND RECOMMENDATIONS I* M e I l l e I i t i L..

1 CHAPTER III. TM1-1 FINDINGS AND RECOMMENDATIONS A. GENERAL The TMI-1 nuclear plant is unique in the nucidar utility businesa, it l has been in a shutdown condition for almost four years, not because of malerial problems but because it was located adjacent to TMI-2. Since there is little hope that TMI-2 can be restored to an operating condition in the near future, emphasis by many interested and concerned groups has shifted over to the issue of restarting TMI-1. Thus, for an intents and purposes the burden of proving or disproving the ability of GPUN to operate a nuclear facility safely has shifted away from the plant that had the accident, and the burden of proof now rests with its sister plant TMI-1. Without arguing the merits of this philosophy, any review of TMI-1 must accept that situation and attempt to understand the effect it has had and continues to have on the entire GPUN organization. l The outside observer and even the occasional inside viewer has little appreciation for the magnitude of the effort that has faced those who were f charged with the task of rebuilding the confidence of the regulatory bodies, I the public and even the people directly involved. From.the beginning it was apparent that this entire effort would be scrutinized and judged with a skepticisni' heretofore unheard of in this business. It was clear that major changes would have to be made in every, aspect of TMI-1, including i~ management, design, training, technical espability, and organization. Merely dressing up the preaccident situation would not suffice. [- BETA's involvement with this process started some eight months after the accident, after the decision had been made by those **Ithin the GPU organizations to take those actions necessary to regain not only the required approvals but also the public's confidence in its ability to operate a nuclear plant safely. BETA's role was and has been one of providing GPU rranagement I with an ever-present, independent and critical analysis of their efforts. BETA's relationship with GPU has not been a typical customer-cilent relationship. From the beginnkg, BETA has been in the unique position of l being given complete freedom to probe any area it felt necessary and to report its findings to the highest levels of management. It has never been tasked or directed to perform a function which would undermine its position as a surrogate of an outsider looking in. Similarly, BETA has not been the l architect of the changes. ~ In one of its earliest tasks for GPU, BETA undertook a review of an Issue raised by the NRC and the Kemeny Commission relative to the restart L. of TMI-1. The issue, which was listed as a speelfic iterp,to be considered by the Atomic Safety and Licensing Boar involved an assessment of GPU's (or Met Ed's) management capability echnical resources. The BETA review of this area began in the fan of 1979, and continued throughout most of 1980. There was substantial interest and involvement by NRC and others 4 in this question which resulted in the issuance of a set of NRC eriteria which was to be used to assist in the determination. l While GPU did not use the NRC criteria as specific models to buDd its new organization, their existence was known and recognition had to be given to the fact that they would be used in making a final judgment on i 18 r-= -

=~=-======--

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Met Ed's ability to restart TMI-1. This, along with other pressures and GPUN's own desire to create a tctally acceptable organization tended to dive up the number of employees. Thus, when BETA was tasked in December,1981,'to undertake a review l of GPUN to determine if the new organization was functioning efficienth, it had to be done with this background in mind. in the ease of TMI-1, BETA attempted to approach the problem (, differenth from the clasical cost efficiency stan@oint where each function 8 and the degree to which it was performed would be matched against a hard Ene official requirement. To do that would be tantamount to asemirg against preaccident conditions--the very con.11tions that have been blamed for the accident. In each instance, BETA attempted to first base its ~ assessment on a level of capability that an outside, knowledgeable person would expect to find which would satisfy the weakneses identified as a result of the postaccident investigations. Then, once having done that, to see if there sere avenues to obtain greater efficiency. It might be worthwhile at this point to elte an example which IDustrates I. the above. Prior to the accident, utilities generally followed the NRC requirements for selection, training and qualification of operators. This was J' done, in most cases, by using those NRC requireme its and guidance issued [~ in ANS standards in a fairly strict sense. How good a particular utility was was measured by the pcm-fall rate of the applicants for the NRC examinations. Little effort or resources were devoted to going much beyond f, this level of knowledge. A single nuclear plant having 3 or 4 people devoted -[ to this effort was not unusual. Because of the issues raised as a result of the accident, training of operators has become much more important and f* broader in scope. Today, there are some 50 people devoted to training at TMI. The questions that needed to be addremed were: L Is GPUN meeting not only the requirements but also the intent of 1. those requirements so as to satisfy itseif that its operators cand others) are properly trained and qualified? i 2. Has GPUN gone too far in its efforts to have its people trained, Le., has it become " gold plated"? 3. And finally, is what GPUN doing in the area of training TMI personnel being done in a nominaDy efficient manner or have resources just been thrown at the problem in order to fix it? BETA reviewed an of the basle elements which today constitute essential functions. These included: A s. OveraB management b. Engineering / Technical 4 e. Operations d. Training e. Maintenance ~ f. Radiation protection g. Quality assurance j h. Nuclear safety asemment 19

l -~~m..- i L Licensing J. Emergency planning k. Security L. Facilities m. Fiscal management { n. Human resources l 3 o. Labor relations p. Industrial safety g. Public relations l r. Fire protection s. Environment In general, what was found was that in each category, substantial changes had been made resulting in improvements. New people had been i added and, in some cases, people had been replaced. With very few exceptions, BETA could find no unnecessary function or task being performed. There were cases where BETA has concluded that efficiencies can be realized and that these functions and tasks can be performed with less people. The I, specific cases are either detaDed in the chapters which foDow or have been transmitted orally to GPUN management (Office of the President). i eeee j TMI-1 SITE MANAGEMENT FINDING ID-A I The role of the Director, TMI-1 needs to be clarified and strengthened with respect to his over-aB site responsibilities. l r.- DISCUSSION l b One major change which came about as a result of the creation of GPUN was that of going to a functional organization. From the point of l view of the Plant Director, this meant that instead of essentially being totally responsble for everything and ever responsibility and authority was reduced. ybody at the site, his direct Whue the actual shift in responsibility was not that great,.the perception was created that the Plant Manager was no longer directhr responsible for a number of areas critical to the plant; namely, training, radeon, QA, major engineering, security, warehousing, sto. As the new funetional organization was put into place, m~uch attention was given to the fact that these functions became the responsibility of other Directors. BETA is stD1 of the opinion that this fofm' of functional organization is appropriate and worthwhil(but it also feels that it is the most difficult to make work. Generally, people have little trouble g understanding a straight line project organization where there is one person respcnsible for all aspects of a given unit. It becomes much more difficult when various Directors become responsible for "pleces" of the jobs. 'Ihe Director, TMI-1 elearbt understands this and has made substantial progress in establishing a working relationship with the other Directors. However, there needs to be a better understanding across all Divisions that while au Directors are " equal" on the organization chart, the Plant Director, in reality, ~ 20

}[ ~ ~ l l l j is a little bit more equal This does not mean that any responsbility. is taken away from the other Directors. It means that the Plant Director has the ultimate responsibility to make sure everything or anything that h w.. I at his site works to his satisfaction. If it is not,F the final analysis then he must take it on, working with or through the other Directors. , if I l son}ething at the site fails to function properly, be it security, training or the like, the Plant Director.wou14 and should, feel responsble. It should not be like the street car conductor who says he's in charge-but in reality, isn't. Only the Plant Director !r. permanenty located at the site and has the ability to see firsthand what is going on. He must be in a position to use whatever resources are available to him to cause proper action, but stin work within the framework of the functional organization. Another aspect of this problem is that there is a tendency.for the i other Directors to feel not totally responsible for the outcome of the entire effort. l For example, other Directors who provide support services to the plant, should not look upon their jobs simply as isolated segments of the whole. If a problem exists at the plant wherein a Division has some element a of responsibility, that Division 'should feel responsible for the total final outcome and not take the position that it has done what was asked for, and if the end product did not happen to come out right, then that was somebody else's fault. There is also little to be gained in spending hours in meetings tryirg to decide whose piece of the job failed. l While these comments derive not so much from observing the Directors 1 l themselves, but from lower levels within the organization, the Directors are responsible for making sure their people evidence the proper support. RECOMMENDATION 4' As an important ongoing effort the Office of the President needs a. to reinforce the understanding not only of the various Directors, but also of lower levels in the organization, of just how a functional organization is supposed to work. These actions should include l the Office of the President evidencing a greater sensitivity to instances where the functional organization breaks down and using l these instances as examples. Similarly, the Office of the President must ensure that it is not weakening the functional concept by directing contrary actions in the name of expediency. As difficult as it may be, every effort should be made to make the organization work, not bypass it when convenient. b. Efforts need to continue emphasizing that aB Divisions, other than the plants, are support divisions. They perform a supporting role to the plants. If the plants did not exist, they Would have no job. If the plants do not work right-drefficiently, the support divisions are probably not doing their jobs correeth, and they can't pass the blame oft The Directort need to impress on their people that the time has e. come to stop worrying over, and spending time on jurisdictional issues. There is little to be gained by attempting to put a jurisdictional definition in black and white on every situation that ~ 21 ~

.- a = Arises. There will always be grey, undefined areas, where somebody just does the work and doesn't argue about who is supposed to do it. i d. The Director, TMI-1 needs to impres upon,his senior people that they need to make the new organization work by using it, not fighting it. They need to understand that people in other Divisions have just as much a stake in succesful operation as they do, and that if there are shortcomings, they need to do what they can to help eliminate them, but not to bypas them. The Director, TM1-1, in concert with other Directors, needs to e. find a way within the current procedures to stimulate a freer flow of discussion between Divisions without having to bring aB subjects i. up to the Director level f. The Director, TMI-1 needs to instBI in his senior managers the ~ concept that their complaining about corporate policy " upward" is acceptable and encouraged. Complaining " downward" is not s acceptable. Dis comnient, while listed under the Director, TMI-1, applies equally to all Division Directors. eeee l_ TMI-1 OPERATIONS FINDING IH-B The positions for five " engineers" presently reporting to the TMI-1 Manager, Plant Operations should be better defined. i DISCUSSION l There are five " engineers" presenth reporting to the Manager, Plant Operations. While the functions that this group performs may be necessary and might need to be retained, it should be determined if they were created to serve a specific purpose in the past and if their existence today is still necessary. Based on the BETA review, they are not performing functions which could be truly called engineering. His may be a problem in nomenclature. In. BETA's experience, an employee given the title of " engineer" is usally a person with a college degree in engineering and if the job is one which requires it to be filled with an engineer, it is usually an engineerirg job. L lt is ais Po sibie that staffs such as this ame into exist nee because of frustration in not being able to obtain necessary %ork from those organhations asigned the responsibDity. "' .WhDe there are exceptions, every effort should be made to have plant engineerirg functions performed by Plant Engineering. Dis w!H ensure that there is a proper degree of supervision over all engineering work conducted at the site. BETA recognizes there are tasks to be performed outside of Plant Engineering that are best done by people with engineering background and experience. When this is done, great care must be exercised that these groups do not usurp engineering responsibilities assigned elsewhere. ~~; ~ 22 .~

.a l RECOM MENDA'I1DN The five engineering positions reporting directly to the Manager, Plant Operations should be better defined. If they are performing a necessary nonengineering function, such as planning, scheduling, budgeting, etc., then the positions should be redesignated and filled with appropriate people at safaries commensurate with the tasks. If they are truly performing a plant engineering function, then a determination should be made to ensure that the function is not better performed by Plant Engineering. s eeee l TMI-1 MAINTENANCE FINDING IE-C Maintenance at TMI-1 can improve its support of the plant. c DISCUSSION t* The performance of maintenance at TMI-1 has improved significantly during the last two years. flowever, weaknesses still exist which tend to / degrade the quality, quantity, and efficiency of maintenance work. For

• example:

There are 151 people in the Maintenance Department at TMI-1, a. comprised of 106 work force people and 45 who are in management, supervisory or support positions. In effeet,45 people plan, supervise and account for the work of 106 others. Since 6 foremen and 59 workers are assigned to the six rotating shifts, the daylight maintenance force is comprised of 39 people in management and suppcrt positions, with 47 people in' the work force. The daylight f - l'. shift is obviously the main shift, with support available from management, work planning, clerical support, machinists, stores, l transportation--aB that is needed to make the wcirk move. Yet, ! a review of maintenance department performance reveals that most maintenance work is done on the two backshifts with 10 workers and one foreman on each. The conclusion has been reached in the Operations Department (the Maintenance Department's eustomer) that they don't expect to get much work done on the 'I daylight shift-it is too hard, too many people Interfere with the work, too many other things get in the way. Much of this is .I brought about because it is during the dayshift that the heavily t manned modification work is performed caufng the normal maintenance work to be pap"er-worked rathe,r than mechanie-worked. ' l' One principal difference between the backshifts and the day shift is in the supervision of the rotating shift maintenance people. At night, the rotating shift maintenance force is under the control of the Shift Supervisor, whereas the rotating shift on day shift is under Maintenance Department management with the regularly assigned daylight shift people. An improvement in efficiency is Ekely if those in the rotating shift on day shift were assigned to 23 l :, -

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.u. =.: I l ~ the Shift Supervisor for accomplishment of jobs less than one shift duration, and those regularly assigned to daylight could undertake the longer duration jobs. His should help abate the feeHng in Operations that "nothing can be done on day shift." l-b. The BETA interviews of site people concernirg maintenance at TM1-1 had a repeati theme that: " Problems do not get solved." There is the percept on at the site that repairs are made, the t l component is returned to service, but the problem that caused the failure has not been solved. Our review indleates that when this situation occurs, it is because Engineering has not ibeen brought into the solution of the problem. Dis fa!)ure to obtain engineering l l support is a problem in proper supervision, both in the Maintenance l Department and Plant Eng:neering. i l There is a genuine concern at the site over the contemplated c. transfer of the corrective maintenance work to the M&C Division. Mr. Arnold's letter of May 27, 1982, to the Vlee Presidents directs ~ a realignment of the maintenance function at both TM1-1 and r Oyster Creek, whereby the corrective maintenance function will be assigned to the M&C Division. That shift has taken l .. Oyster. Creek.t ut will not happen at_TMI-l untlI~a' deite Ts,p. lace..al_. l t seleetad 1 "which wlB not Interfere wlth restart". Because of the magnitude f of the change and.the.need for stability at TMI-1 at this time, it is recommended that the date selected be later than the currently t 1 scheduled restart date. There will be some temporary disruption l in the Maintenance Department when the change is made which can be accommodated easier after the current restart effort is completed. Although there are some shortcomings in the current 8* maintenance program, the program is adequate to carry the plant to restart. RECOMMENDAT10N Deliberately schedule more work for the day shift. Increase the a. effort of those in supervir.ory support positions toward clearing the i interferences that slow down work on the daylight shift. Put the i same effort into planning and scheduling " tomorrow's" daylight shift as is currenth devoted to " tonight's" back shifts. 1 [- b. Assign system responsibility in Plant Engineering. Establish the concept of the cognizant engineer. Ensure engineering review and concurrence, an4 when thought necessary by Plant Engineering, direction of maintenance actions planned and in progress. Do not make the change of assigning the corrective maintenance e. function to the M&C Division until after restart of the Unit. ,i { 24 .J:.

a._ -. I i eeee i TMl-1 CHEMISTRY FINDING ID-D I .I Mapr defielencies in the chemistry program at TMI-1 were identified two years ago. Corrections have been slow. t DISCUSSION TMI-1 has recenth reorganized to strengthen the chemistry program. I, The position of Chemistry Manager has been added. An experienced manager i with a degree in ehemical engineering has been moved into this position from another job at TMI-1. Efforts are being made to hire two staff .)- chemists to help revise the large number of chemistr provide other heb in upgrading the chemistry program.y procedures and to s All of the previous ehemis'try group except its supervisor was moved ( from Plant Engineering to Operations and Maintenance. The functions of I the single chemistry person remaining in Plant Engineering are to provide a day-to-day byerview.of the chemistry program, to provide interface with others on technical problems, and to help solve chemistry problems. Retaining l this chemistry involvement in Plant Engineering h also needed to help ensure chemistry is actively considered in engineering deelstons where chemistry l has not received er.ough attention in the past. 1 RECOMMENDA'110N BETA considers TMI-1 is on the right track to upgrade its chemistry program.. It is particularly important that the Director TMI-1 have a key manager he can hold accountable for ehemistry operations; the chemistry manager shouM develop this responsibility. It will be more efficient and F produce a better product if the chemistry analytical procedures for TMI-1 and Oyster Creek are standardized. The two chemistry managers should I take action to force this standardization. I [ eeoe y TMI-1 PLANT ENGINEERING FINDING IE-E k The number of different engineering groups at the site is contrbuting l to los of afficiency. DISCUSSION t 'There are at least 21 different section level groups having engineers at the TMI-1 alte reporting to five different Division Directors. This leads to confusion in some cases as to which group will handle a given problem. It causes a slowdown of work due to the need to pass a technical document through a number of these groups before it can be issued. Many of these groups are necessary, and they should be separate. However, it is BETA's ~ 25 .r

. = = -

n i opin!on that there are too many of them. As long as the plant has been shutdown thh problem has not loomed larger than an inefficient annoyanee. The time win soon come when there will be a need for rapid engineering l and technical work to be accomplished. Under the this could be hampered by the large number of groups,present elreumstances,d ,f-engineerirg structure. RECOMME!1DATION I-The various engineering groups at TMM should be reviewed with the ) I goal of reducing the number. In the engineering areas, if there are several different groups within a given division there should be one person at the site designated as the lead Division re,presentative who w'ould assume the adminktrative and other responsibuities other than technical j t eeee TMl-1 RAblOLOGICAL CONTROL FINDING ID-F i l \\ There are too many instances where radiological con'trols are not as '~ good as they should be. The work force has not accepted enough of the responsibility for high quality radiological work performance. Excessive ,~ generation of radioactive waste is part of these problema. t 1 DISCUSSION BETA has been constantly involved for three years at all levels of l~, GPU in upgrading the radiological control program at TMI-1. Since BETA L has frequently dheused with top officials its detaDed findings and recommendations nn radiological controls for TMI-1, an overview will be j more useful in this repet. Management support for a strong radiological control program continues to be apparent not just in the words used, but in the aDocation of money i and manpower. In three years of making improvements, however, the stated objective of a high quality radiological control program standing among the best in the industry has not yet been achieved. As a result, the perception l 1 persists that radiologleal control continues to increase costs and to prevent l work gettig done. The next steps are essential to increasing efficiency and decreasig time and cost of radioactive work. I' There are two fundamental steps in developin high quality radiological control program. The first step is reducing"g ato small numbers and to sman significance the radiologicalTeficiencies found in routine deny work. The term radiological deficiency k used here to mean anything that eculd have been done better. TMI-I has reached the stage where few of Its radiological deficieneles are of enough significance to be noted by NRC inspectors. TMI-1 has reached the level where it can be called average in comparison with other utilities in performance of the radiological control ceganization. Nevertheless, there are far too many defielencies, there are 7 too many esses of loose control of radioactive contamination, there is too much radioactive waste, and the performance of radiological control personnel 26 =-==n = T::: r T ~ TTT

= and of radiation workers is often poor. Inevitably, this kind of situation i means there wDI be some important deficieneles. Preventing the big problems requires keeping the small ones under control ao that there is time to plan for and to anticipate future events. l-This. first step may be recognized as the traditional approach to achieving compliance. It can lead to a minimum level of radiologleal performance where violations of NRC rules are uncommon. 81 nee it relies primarily on a " police force" approach by radiological control personnel, this f '(- approach can not by itself raise the radiologleal work performance to the desired level. There can never be enough " policemen" to prevent the worker from making a mistake. BETA has never observed a high quality radiological l control program which has not gone through this upgrading step, but the second step is also required. The second step is getting the work force and their supervisors to believe that excellent radiological performance is the normal way to work ,s and to demonstrate this belief in their routine work. In theory, this could be independent of step one. In practice, the radiological control organization has to set the example. To achieve this performance requires a radiological i control force that believes in getting the work done, that will show the workers how to. do it right Instead of just stopping what is wrong, that will l evolve to more than a ' police force". Ilowever, the responsibility for this l second step k with the work force. The radiological control organization can force step one, but they can only set the stage for step two-they can not make it happen. The major advantages of a high quality radiological control program I do not show up until late in step two. The normal measures of radiological performance need to improve, such as manrem, frequency and severity of abnormal occurrences, personael contaminations, amount of radioactive waste, and numbers of radiologleal deficiencies. But then, the feature that surprises many is that cost and time to do work will decrease. Ther; w!!! be less rework. Better planning will pay off in reduced manhours for work performance. There will be fewer events which stop work while senior personnel scramble to resolve pmblems. There will even be a decrease in size of the radiological control organization. l The status at TMI-1 is that the radiological control organization is l well into step one, but the work force is still in early stages of step two. The TM1-1 radiological control group has had a number of changes to l strengthen its management. As a result, however, each of the managers in thh group is new to his job within the last few months, Only one of the I five radiological engineers who are GPU employees has mgre than one year experience in radiological engineering at TMI-1. nere are many improvements needed in the radiological doTtrolgroup, but there are in place systems for identifying these items and the commitment to make the Improvements. The greatest need inside the group is to raise their standards for compliance.with good radiological practices. At the same time this i group needs to make a major improvement in its relations with the work force. The perception that the radiological control group is merely a police force in charge of stopping work has not yet been corrected. When functioning weR, thk gmup should be of major help in getting the work done. Further upgfadirt 'Is also needed in training of radiological control technielans and + 27 ...d...., p n -...-w =-e..

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a foremen to handle unusual situations not covered by written procedures.

Such training has recently commenced using semi..ar sessions for small groups. In the work force the greatest change needed is to make good radiological performance a natural part of each job. The oW negative { attitude of operations and maintenance personnel belag against radiological controls has been stamped out, but it has not yet been replaced with the a needed positive attitude. RECOMMENDATION Increase the efforts of managers and supervisors tc get excellent s. radiologleal performance as an inherent part of every job performed by their workes. 1 '~ b. Improve the working relationships between the managers and supervisors of the radiological control groups and the managers ,iM and supervisors of the work force. This requires station management as weH as' radiological control management attention since a one-sided effort to cooperate will not work. Upgrade the performance of radiological control technicians by c. improving their ability to identify and report radiological deficiencies, d. Speed up the correction of radiological deficiencies and increase the attention on solving problems which lead to repetition of defieleneles. Both' radiological control personnel and others in the station are required for these efforts. b Decrease the numbers of radiological control technicians as the e. l work force pleks up its own regonsibility for good. radiological t-work performance. l l f. New written procedures, new management

systems, new committees, and new gimmicks shouM not be considered necessary l

l to carry out these recommendations. Each one of the recommendations is a logical extension of what has been started and would likely be defeated if buried in new papework. TMI-1 MATERIAIE MGMT Warehoustrur l ,.u w { FINDING 15-0-1 I .The warehouse inventory records have enough nomenciature inaccurseles to degrade efficiency. DISCUSSION The inspection of Maintenance Department work planning revealed that the warehouse inventory records were inaccurate to the point as to be 28

l l considered unreliable by the job planners. The records were used when assembling the material for'a job, but only after the planner had been to the warehouse to personalh sight the required material--verifying its location and the quantity of stock on hand. This obviously degrades the efficiency of assembling material for the job. In fact, the Maintenance Department i has chosen to asign a material runner to assist in locating and asembling l miterial for a job. An Inventory of stock on hand has commenced since that initial observation and when completed, should resolve the pmblem referred to above. Three months after the inventory referred to above had commenced t and was in progress, BETA reviewed the number of adjustments to inventory l found to be necessary. The number was surprisingly small. It now appears that the principle deficiency with inventory records at TMI-1 is nomenclature. The stock is not defined with words suitable for letting a user seek out and ~ determine the stock he needs. RECOMMENDAMON To impmve the efficiency of using stock material, a program should be started in close cooperation with the job planning section of the Maintenance Department to verify or revise as necessary the nomenclature F used in the inventory records. I. ~ .eee TMI-1 MATERIALS MGMT Stock Levels FINDING 10-0-2 s The amount of stock a't TMI is excessive. DISCUSSION There are approximately 60,000 !!ne items of stock material at TML f Approximately*8,000 line items of stock experience some turnover action in L a year, while 52,000 line items remain inactive. This inventory could be reduced to improve efficiency and reduce the cost of stores handling. 'Ihis ,f proposed reduction of stock should be carefully coordinated with maintenance 9 and engineering, since the current usage records, with the plant shut down, ,l are not truly indicative of the need for stores when the plant will be operating. Some recent attempts to reduce stockfrg levels of infrequently I used stock have created material availability problems for maintenance work. 1 BETA reviewed the procedure that is now in use to redite ' stock on hand in an orderh and efficient manner, and corfEhrs in the approach. BETA was i

I also informed of plans for selling 10,000 line items' of material unique to i

TMI-2. ~- l Another aspect of stock at TM1 is that there is no scheme for purging g stock from inventory when technical or administrative requirements prohibit the use of material presenth in stock. l 9 29 m7 7--

-~- - n,._ -~*m ,vw. a l l RECOMMENDATION Material that will not or can not be used by TM1 should be purged I from stock. s I MATERIAIE MGMT TMi-1 Purchasing FINDING 1H-0-3 The period of time from j purchased material is too long. preparation of 'a requisition to delivery of I DISCUSSION Our discusions with maintenance people repeatedly came to the point 5 where concern was expressed for, the difficulty encountered and time required to purchase material In pursuing this issue in TMi purchasing, the problem could usually be tracked to the difficulty in getting a suitable purchase speelfication or in getting a copy of the ordering data for the previous order of the same material i Oyster Creek has made significant progres in developing purchase specifications for stock material, but TMI has not. f-Progrem has been made in microfiching, for the ready reference of requisitioners, copies of previoush issued purchase orders and the inventory records have been modified to Indicate the previous purchase order numbers. In spite of the difficulty deserbed above, the trend in warehouse issues and purchasing activity from 1980 to 1981 (no data for 1982 available yet) indicates that the availability of material is improving. rs I The purchasing concepts of blanket purchase orders, limited purchase l orders, and recently restructured local purchase orders are calculated to reduce the effort required of the requisitioner and decrease the time for procurement of sman value items. Their use is encouraged. RECOMMENDATION To improve the efficiency of purchasing, Plant Engineering should be tasked to prepare a compilation of purchase specifications, approved by Plant l l Engineering and QA Engineering, for spare parts and consumable stock items for ready use in replenishing stores. The work being doh6 at Oyster Creek should form the basis for the TMI worir." 1 e 1 a 30

k a.. = l ee ~ TMI-1 H UM AN. RESOURCES -e ' FINDING lll-H t There k a need for the TM1 Human Resources group to improve further their responsivenes to site needs, f DISCUSSION At TM1, under the Director, Human Resources, there is an Area Manager, Human Resources and a staff of fourteen people who handle i personnel and industrial relations matters for both TMI-1 and TMI-2. There i l are five people assigned to industrial relations, seven to personnel and three to the Area Manager. Based on BETA's judgment, this is more people than necesary to carry out the functions assigned. What is"of concern, however, - are the number of comments made by TMI-1 site people that this group is not responsive to site needs. There were indications that this situation was improving, but still needed improvement. One of the side effects of having 3 too many people to do a given job is that peripheral jobs get created in the form of writing new personnel procedures, studies, analyses, etc., which tend to distract from the original purpose of the group. Several years ago, there was a need to have a sizable Human Resources force at TMI in order to handle the heavy influx of new people. This has slowed down now and it is time to relook at the manning. RECOMMENDATION The Director, Human Resources, should review the manning of his TMI group to determine if it is stlE necessary to be as large as it is. He should also dheus the effectivenes of his TMI group with the TMI-1 Director, to i find out ways that his operation can be more supportive of site needs. <I eoee TMI-1 ADMINISTRATION FINDING III-I A review of the number of people asigned to administration work at u TMI-1 appears excessive. DISCUSSION For dheunion of this finding, refer to Oyster Creek finding IV.I. s RECOMMENDATION 4. See Oyster Creek finding IV.I. = e s. i.... .. 1.1.......

g m e S O b o I b e CHAPTER N OYSTER CREEK FINDINGS AND RECOMMENDATIONS O I 9 r-1 l i i I i IB@ G l 9 l e G M'****~ e-e r - $ s .,s w e s.e s.... w m.g es

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,.a CHAPTER IV. OYSTER CREEK FINDINGS AND RECOMMENDATIONS i The BETA assessment of the Oyster Creek plant followed guidelines similar to those outlined for TMI-1. The differences came about. primarDy because of the situation existing at Oyster Creek in contrast to that at TMI-1: -l,. Oyster Creek is an operating plant owned by Jersey Central Power and Light. Jersey Central is part of the GPU system and part owner of TM1, but not responsible for the operation of TMI, whose licensee is Met Ed. Oyster Creek was geographically and organizationally distant from the accident. It was not forced to I shutdown as a result of the accident. In some respects its role l paralleled that of any other nuclear plant outside of TMI. Once the effort to create the GPUN Corporation was started in early 1980, this role began to change. However, Oyster Creek was not brought under the GPUN umbrella untB some time later (September 1980) even though the Oyster Creek people knew it was going to happen. In BET 5's ' opinion, these differences created conditions at l Oyster Creek that were unlike those at TMI-1. For understandable l reasons the people at TMI-1 have been more prone to understand r. the need for and to accept changes than those at Oyster Creek. Also, the people at TMI-1 have been operating directly under the i - new GPUN system for almost a year longer than those at Oyster Creek, and as a result, are more settled down and comfortable with it. In addition, there were stlE changes being made in the organization and in key personnel asignments at Oyster Creek throughout the period of the BETA review a period when ' r h preparations were also underway for a major o,utage. In short, Oyster Creek lagged TMI-1 in having in place those organizational ,r l entitles upon which BETA made its TMI-1 asemment. Recognition lf had to be given to this fact. [ Another aspect that bears upon Oyster Creek differently than at TMI-I relates to the material condition of the plant itself.

~ '

Oyster Creek k five years older than TMI-1. At the time of the accident Oyster Creek had ten years of operation whereas m. TMI-1 had five. Oyster Creek is a BWR whUe TMI-1 is a PWR; I. this inherently makes Oyster Creek a more difficult plant to maintain because of the larger extent of radioactivity throughout ~ the plant. s l, As a result of TMI-2 post-seeldent requirements by GPUN, maintenance gained added attention and Oyster Creelefound itself with a fairly large backlog of maintenance work. This, coupled I with two potentially serious plant technical problems (sparger and l torus) that could require extensive work, caused the outage, originally. scheduled to begin in 1982, to increase in scope. There are more GPUN people aufgned to Oyster Creek than to TMI-1 (1119 vs 919). The 1983 proposed budget (current status) for Oyster Creek is $155.8 million vs $85.6 million for TMI-1. These differences are reflective of the situations previously l 32 =

l l described, but principally due to the Oyster Creek outage now scheduled to, start in February 1983. It was within this franiework that BETA conducted its review. As in the case of TMI-1, BETA found, with a few exceptions, no function, task 4~- or work effort that was being performed unnecessarily. Many functions and people were still in the early stages of development and, because of that, functions were being performed by people who did not yet have a clear i understanding of what needed to be done. It is also significant that over l the past two years Oyster Creek has had four different plant directors. This 4 alone was cause for unrest and confusion. Throughout this period of change it was essential to insintain the proper I level of key personnel experienced with and qualified on the Oyster Creek plant. Thic had to be done, and it was. But it has had a slowing down effect on management's ability to bring new people into the organization. 9 ' In an overall sense, there are more avenues to improve efficiency at Oyster Creek than at TMI-1, bdt they will be more difficult to achieve in ~ the near term because of their earlier stage of development. It is also apparent that even when the 1983 major outage is completed at Oyster Creek, there will still be a significant backlog of maintenance and modification work remaining to be scheduled for the following outage. This, 'will further delay the day that Oyste-Creek could be characterized as being in a normal, settled down condition of operation. ~ eoee O/C SITE MANAGEMENT Role of the Director FINDING IV-A-1 The role of the Director, Oyster Creek needs to be clarified and strengthened with respect to the overaB site operation. DISCUSSION ~ This finding is similar in nature to that at TMI-1. While there are i differences in degree, the same recommendations apply. At Oyster Creek there is a tendency for the Director and his managers to focus on problerrs and areas under their direct control to the exclusion of problems of other groups which also affect the plant. BETA could see improvement in this ( situation during the period of the review. However, there needs to be a l greater understanding at all levels of management responsible for overall site operation. In the early stages of the. BETA review there was noticeable l Infighting at the site, particularly among groups reporting to different Divisions. This infighting evidenced itself in finger pointing, lack of cooperation and, in some cases, malicious bypaming and stalling to hold g work. We found few groups who held other groups in high regard. In late 1982, when BETA returned to Oyster Creek to check on its findings, this situation had changed considerably for the better.

• 0

~ 33

I ~. While there has been improvement, efforts to correct this situation need to be continued because the net result is that work still takes an inordinate amount of time to accomplish, it has also resulted in the swelling l of the robs as each group feels the need for more people to either enhance l their position or to do work normally done by others. 4 ~ Thk problem will not disappear overnight and will not be solved by orderirg it so. The Director, Oyster Creek een and shouM have a direct hand in correctirg this situation by first working on the managers (an of them) assigned to the Oyster Creek site. His Interesta should be universal and not division-oriented. This problem exists in aB areas throughout the site, I While the recommendations which foBow are identical to those provide'd i for TM1-1, there are differences mosth brought about by two situations: 1. Oyster Creek lags TMI-1 and consequently, has fbrther to go to l achieve its goals. This is further impeded by the waning, but stD1 s present feeling at Oyster Creek, that they are " outsiders" in the GPUN organization. 2. Oyster Creek is the lead plant on shifting maintenance from the plant to the newW formed M&C Division at the same time the plant is beginning a major one-year outage. It is going to take Herculean effort on the part of the Director, Oyster Creek and the Director, M&C and their managers to make this work, particulary in a productively efficient manner. RECOMMENDATION As an important ongoing effort the Office of the President.needs a. to reinforce the understanding not only of the various Directors, but also oflower levels in the organization, of just how a functional organization is supposed to work. These actions should include i-the Office of the President evideneing a greater sensitivity to instances where the functional organization breaks down and using these instances as examples. Similarly, the Office of the President j must ensure that it is not weakening the functional concept by directing contrary actions in the name of expediency. As difficult 'as it may be, every effort should be made to make the organization work,'not bypass it when convenient. b. Efforts need to contin.se emphasizing that aB Divisions, other than g the plants, are support divisions. They perform a supporting role l to the plants. If the plants did not exist, they would have no job. If the plants do not work right or efficiently, tte support divisions are probably not doing their-jebs correcty, and they can't pass g the blame oft The Directors need to impress on their people that the time has e. come to stop worrying over, and spending time on jurisdictional lasues. There is little to be gained by attempting to put a jurisdictional definition in black and white for every situation that arises. There will always be grey, undefined areas, where somebody just does the work and doesn't argue about who is supposed to do it. I 34 7 ,m- - - - - "7'

l -e - i d. The Director, Oyster Creek needs to impress upon his senior people that they need to make the new organization work by using it, t not fighting it. They need to understand that people in other l Divisions have just as much a stake in successful operation as they do and that, if there are shortcomings, they need to do what they -I. can to help eliminate them, but not to bypass the organization. The Director, Oyster Creek in concert with other Director, needs e. to find a way within the current procedures to stimulate a freer flow of discussion between Divisions without having to bring all subjects up to the Director level. s I f. The Director, Oyster Creek needs to inst!D in his senior managers the concept that their complaining about corporate policy " upward" is acceptable and encouraged. Complaining " downward" is not acceptable. eeee f O/C SITE MANAGEMENT I i Plans and Prostrams FINDING IV-A-2 , L The functions now performed by Plans and Programs could be accomplished more efficiently. DISCUSSION ~ Reporting to the Director, Oyster Creek is a function entitled Manager, Plans and Programs with a staff of five people. The BETA understanding is that this group is to assist the Director in matters involving interface ( between the plant and other Divisions, keeping track of commitments by others affecting the plant and establishing the requirements by the plant for the accomplishment of key events to plant approved cardinal date schedules. BETA acknowledges that this is a useful function and that usefulinformation is provided to the Director. However, as currently functioning, BETA concludes that, in some respects, it is redundant. The risk associated with having a group like this reporting directly to the Director is that they wD1 assume, and to an extent have assumed his mantle-becoming authoritative and regulatory in their contacts with other functional groups. Better that this group kept totally complete records and status of plant commitments, displaying requirements, obtaining commitments fkom other Divisions and other plant departments, arte following up to determine problems that will be of concern to the Director. For example, establish key events and cardinal detes for issue with the authority of the Plant Director, but do not specify or schedule the actions requbed by others in meeting cardinal dates for key events. BETA encountered too many instances where resentment, antagonism, and recalcitrance was being induced by the actions of Plans and Programs in attempting to schedule and direct work which is the responsibility of other departments or divisions to accomplish. Obviously, Plans and Programs must 35 l

. _....... -. n.. ---- - m s..-- - ~ be aware and be capable of recognizing problems that wiB Interfere with proper and timely completion of key events, but they are not, nor should they be, staffed or qualified to regulate the functions of others. RECOMMENDATION ' I T.. Hold 'the size of the Plans and Programs section to its current a. size for estabiL;hing key events, cardinal date schedules, and status of progres and pieblema. I b. Do not use Plan's and Programs as a line authority organizatieri scheduling and directing work, rather as a service organization identifying problems and amisting the Plant Director in his dealings I with other division directors, as these problems relate to performance in accordance with existing commitments, key events ~ and cardinal dates, s e... O/C OPERATIONS FINDING IV-B l, There is a lack of involvement by Operations in Oyster Creek operator training. DISCUSSION As previously indicated, Oyster Creek is about one year behind TMi-1 in havirg its training program in place. One of the problems encountered .and solved at TMI-1 was a lack of involvement by Operations in the training program. 'Ihis same problem is in evidence at Oyster Creek. RECOMMENDATION The Director, Oyster Creek should make whatever adjustments are l l' necessary to ensure that Operations is more involved in the Oyster Creek training programs, espeelaDy operator trainig. e. O/C DECONTAMINATION l FINDING IV-C w Workers do not plek w after themselves. DISCUSSION j A large part of the work of the decontamination group has been cleaning up after workers. Although there have recently been some improvements, the performance of workers in this area is worse,than BETA has observed elsewhere. This stoppiness increases the work of the decontamination group, increases the generation of radioactive waste, increases radiation exposure, 36 z

1 l l spreads radioactive contamination, and increases costs and time to do work. It has also been one of the causes behind the excesively slow improvement in radiological performanes of the work force. RECOMMENDATION, k - Managers and supervisors need to keep on their workers so that it is uncommon, rather than routine, to leave a mess at the end of a work period. O/C MAINTENANCE FINDING IV-D-1 The ability to perform maintenance on the plant in order to amure a reasonable dqree of reliability needs substantial improvement. DISCUSSJON This is a broad but important issue. The BETA review was conducted during a period of drastic change and one that is stID in its early stage of development. In October 1982, the primary responsibility for the performance L of maintenance work was shifted to the Director, Maintenance and Construction and away from the responsibility of the Plant Director. This is a new concept and it is beirg inaugurated coincident with the start of a major one-year outage. BETA will not dwen on problems which were evident before the change took place but wlB concentrate on high-lighting areas that appear to be causing difficulties today and particularly those asociated i f, with the transition. A number of the problems efted existed prior to the transition and appear to stD1 exist. l .o I Even though BETA wD1 confine its comments to the transition period, it is worthwhile to understand the situation leading up to the present. At the time of BETA's initial review at Oyster Creek in April 1982, various excuses were advanced to explain the poor materlat condition of the plant t, such as: a lack of engineering support during maintenance, clumsy design with difficult accem or durability, poor ehemistry control, inadequate cathodic r protection, etc. However, the fact remains that the maintenance roll was large and the material condition of the plant was poor. The backlog of corrective maintenance job orders was ever increasing, the rate of accomplishing preventive maintenance was a fraction of that planned, and the same maintenance problems recurred. In spite of the large Plant Maintenance Department, heavily staffed with supervisors, engineers, and P eierks, the M&C Division was maintaining about 80 contraetor mechanles on site during nonoutage periods to perform 7ssential jobs that couM not be ~ acecmplished in the required time or with the required capability by Plant i~ ~ Maintenance. Easing the Maintenance Department's load by assigning a large Site FacDities group, staffed with utDity workers to accomplish maintenance tasks not directly related to the generating plant, has been useful, but not to the extent that Plant Maintenance was producing the desired material condition. 37 ~.-

There were several groups at Oyster Creek categorized as maintenance: Correetive Maintenance, Preventive Maintenance, Facility Maintenance, Maintenance and Construction, and Site Facilities. Altogether, there were.;. approximately 350 people in these organizations during nonoutage periodM with responsibility to maintain the plant, and yet, the phnt was not belar .tT P l l adequately maintained. Hearsay examples of maintenance job orders being reported complete when no work had been done, of temporary fixes that lasted a week, of repeated occu Tence of the same material problem, or of long delays before starting required maintenance were efted by operators. '( While most complaints were in the mechanical area, there were suffielent examples in electrical and I&C to make it an acros the board Imue. l During the period of our initial review, the Maintenance Departnient i was under the management and supervision of people who, with a few exceptions, have been at the phnt during the entire time that the situation deserbed above developed and persisted. These are valuable people because i l of their knowle%e and experience with the plant, but they were not 9 maintaining or improving the material condition of the plant. GPUN has since realigned the maintenance function in October,1982, placing mechanics,. electricians, instrument technielans and their direet supervision under control of the M&C Division which wDI accomplish work requested by the plant. It was GPUN's intention that the total number of j people performing maintenance under this new arrangement wouW not be increased. M&C will need to find the work methods and procedures to improve the utilization of mechanics in working off the backlog of maintenance work and keeping up with new job orders. The illusion exists within some quarters of GPUN that the maintenance problem at Oyster Creek is a fundamental problem growing solely out of h the union " problem" which has resulted in the manual effort in the fleM l never being properly controlled and that, because of the union, nothing has l ever happened to increase the effectivenes of hands-on work. If this is so, l L lt leads to a conclusion that the work force and the union agreement must l be restructured. BETA agrees there are serious problems with the laber-management agreement which require immediate attention and which, if resolved, would assist in improving effielency and productivity; however, l l-there are other considerations, not restrained or affected in anyway by the agreement with the. bargaining unit. It was BETA's observation that the union agreement by itself did not i have a major bearing on the productivity of the workers. With the pombla exception of a few people with malicious intent, who, if existing, can be . easily found and discharged, workers will do a day's work. Their efficiency and utilization does not depend on them--rather on thelegupervision. The worker will do what he is tow to do, what he is shown how to do, what he k trained to do, what he can do given the access, speelal tools, speelal l clothing, plant conditions,_ tag outs, work permits, procedures, materials, Inspection support, radeon support and supervision that are required. Deprive the worker of any of these, and his effielency and productivity declines. He will then do what he is tom to do or what he is allowed to do. So, to l blame inefficiency and lack of productivity on the worker is a poor excuse- -even to blame it on his group supervisor is sidestepping the issue. The group superviscr's work ethic is much like that deserbed above for the 38 y -..-.a--..

\\ l worker. Even he must be put in an environment and be provided with the procedural, material and management support conducive to doing work. Put him in an environment where he can not work, and he and his gang will c l accomplish nothing. Concentrate the effort on those who generate the work l requirements and create the work environment, and manage the work within W [- the existing contract, whDe negotiating to improve any features of the bairgaining unit agreement which prove to be inhbiting. All of these items discussed so far are wen-known to both the Plant I Director and the Director, M&C. They are areas that need to be addressed and solutions found if maintenance work at Oyster Creek k to improve. In [ addition, BETA has noted a number of problems assoelated with the transition that also need correction. BETA understands that whenever such a drastle I change takes place there wlH always be a period of time that people are unsettled, confused and working at odds. This is to be expected. However, BETA senses a fundamenta11ack of understanding on the part of fairy senior people (managers) Involved of just how thh new arrangement is supposed to 9 work, particularly in the details. A very detailed procedure has been written .and issued which, at least at this stage, is not fully understood by those I charged to carry it out. As the system attempts to be use4 roatlocks are encountered and there doesn't appear to be a mechanism to bring the right people together to resolve the holdup. For example, there is a large backlog of inctallation 7rocedures held up awaiting PORC review (a subject discussed elsewhere ;n this report). 'Ihis is a step in the sequence of events, one of many, that needs to be I resolved if it is taking an inordinate amount of time. Without arguing the whys, it is essential that the issue get resolved and this can only be done by people enpowered to make decisions. As the plant moves further into the outage and the large workload begins, many more of these types of problems are going to arise. RECOMMENDATION Senior people in M&C, including the Vice President, the Production a. Director and the Manager of Planning should increase their direct and daDy participation in solving organizational and divisional interface problems arising at Oyster Creek as a result of the transition. This recommendation is not to be interpreted as a means to force decision-making upward or to usurp the l respons!bDities of those people at the site. Rather, it is recommended as a means to obtain quick resolution of problems that may be beyond the reach of those at the site. At this stage l of development there are probably very few people who have a elear understanding of how this new organizatien is intended to work. The few that do, need.te be put in the breech. N , b. In concert with the above recommendation, other senior people at the site such as the Vice President, Oyster Creek, the Manager, RadCon Oyster Creek, the Manager, Oyster Creek QA, and the senior T/P site representative need to increase their personal involvement in resolving the time-consuming roadblocks arising as a result of the transition. 39

I l w i Care must be exercised not to assume automatically that the large c. i number of newly prepared procedures relating to the conduct of maintel19nce at Oyster Creek are, or will be, understood by those required to follow them. Initial observations indicate that some a of these procedures may be overly prescriptive. eeee O/C MAINTENANCE Coffee Breaks l s FINDING IV-D-2 'Ihe sanctity of coffee breaks at Oyster Creek k a sizeable contributor to poor productivity. DISCUSSION l t The agreement with the b'argaining unit specifies one fifteen minute coffee break. It does not specify when the break is to occur. Rarely is the break completed in the specified period of time or at a time that would have the least effect on work. In addition, it is now common practice to take a coffee break in the afternoon, with no reference in the bargaining unit agreement. - Again, that break is seldom completed in fifteen minutes s, or taken at an appropriate time. Should these two breaks be taken by workers involved in areas requiring protective clothing, at least two hours I of nonproductive time results. b RECOMMENDATION I Undertake to negotiate the morning coffee break out of the a. bargaining unit agreement or at least allow management to deelde. when the break is to occur. b. Eliminate the afternoon coffee break or allow management to determine if, when, and under what condiUons there will be an afternoon break. eeoe O/C MAINTENANCE Working Hours for Contracted Employees l. FINDING IV-43 s Mechanics under contract through M&C do not stay on the job until the end of normal working hours. DISCUSSION g The current practice is to release M&C contractor employees from the job in time for them to be off Company property by the end of working . hours. The explanation of this unusual practice was that they come to work 40

l I on their time, but leave work on Company time. This is an added cost, and it also has a bad effect on the Company employees who are supposed to stay on the job. Y* RECOMMENDATION ' M&C contractor employees should be kept on the job untu the end of working hours, g O/C M AINTENANCE Preventive Maintenance FINDING IV-D-4 Only a fraction of the preventive maintenance routines planned for accomplishment are completed., s DISCUSSION The relatively new preventive maintenance program at Oyster Creek has made progres-the program was started from zero. For Instance, the rotating screens at the intake structure are now lubricated on a schedule, l rather than only when rebuilt after failure. I With the transfer of the maintenance funetton to M&C, the preventive maintenance function win stabilize. Previously, when needed, preventive maintenance workmen were diverted to corrective maintenance work. This !~ is the principal deterrent in accomplishing planned preventive maintenance. I.- At the time of our initial review in' AprD 1982, job planning was stD1 1 done manually by engineers on the Preventive Maintenance staft When the program is automated in the Generation Maintenance System (GMS), this I l work can be done cheaper with job planners, and the engineers can be released to engineering work. RECOMMENDATION Expedite loading the preventive maintenance system schedule b a. GMS. b. Maintain close contact with TMI-1 Preventive Maintenance in order i to benefit from TMI experience. e. Consider reducing the size of the@reventive Maintenance Manager's staff as the preventive maintenance program stabilizes. l l e e +- s. , - -, ~

.t eeee O/C MAINTENANCE Mobile Maintenance .y 5:r. 1 FINDING IV-IH l MobDe Maintenance is a costhr way to perform plant maintenance. DISCUSSION I One of the loosely, or informally, controBed expenses is the cost incurred through the use of the Mobile Maintenance force maintained by JCP&L at a remote station. Fortal to portal pay-including overtime for that in excess of 8 hours, mileage, meals, mealtime, motels, per diem, etc., l cause the effective hourly rate for Mobile Maintenance employees to far exceed that of a plant employee or an M&C contracted craftsman. Apparently, requests for Mobile Maintenance people are made oraDy-no real scope of work definition is required, if Mobile Maintenance can provide the I requested people, they will be provided at their exorbitant cost. If they can not be provided, the plant must go through the administrative burden. of trying to reschedule the work before starting the job with mechanies under contract to M&C. Ushg Mobile Maintenance people under these conditions is dbruptive to work planning and destroys any attempt to control i, costs to the bu%et. (Bu%ets are prepared at the plant payron rate, not the inDated Mobile Maintenance rate). The manner in which costs are accrued by MobDe Maintenance,and the informal controls over the use of this high cost service create a disregard I, for cost in those who use Mob!!e Maintenance. It might have been a good idea ten years ago, but today it doesn't work, except for speelalty tradesmen, such as turbine overhaul specialists. \\ Any Mobile Maintenance people with unique Oyster Creek skDis who perform most of their work at Oyster Creek could be taken up on the plant roHs to reduce these abuses. RECOMMENDATION ~ a. Consider negotiating agreements which result in better utuization of Mobile Maintenance. b. Consider taking on to the M&C ron those MobDe Maintenance l employees who perform most of their work at_ Oyster Creek. I e 42 L x-2

.m . e e. O/C CHEMISTR ,y FINDING IV-E ~ Problems in performance of the chemistry control program at Oyster Creek were found to be similar to the problems at TMI-1. DISCUSSION The same actions are underway at Oyster Creek as deserbed in the previous section for TMI-1 chemistry; they are not repeated here. An experienced manager has recenth been hired from outside GPU to be chemistry manager. RECOMMENDAMON s BETA considers Oyster Cre' ek k on the right track to upgrade its f chemistry program. It is particularly important that the Director, Oyster Creek have a key manager he can hold accountable for ehemistry operations; the chemistry manager should develop this responsbility. It will be more I efficient and produce a better product if the chemistry analytical procedures for TMl-1 and Oyster Creek are standardized. The two chemistry managers L should take action to force this standardization. eoee O/C PLANT ENGINEERING Engineerirg Groups i FINDING IV-P-1 i There are too many separate, section level groups having engineers at Oyster Creek. DISCUSSION Our review indicates that there are at least nineteen section level groups having engineers onsite at Oyster Creek operating under the direction of five Division Directors. Many of these are necessary and should be separate, However, it is our opinion that there are too many. 1here are such groups in each of the foBowing: L Under Director, Oyster Creek s s. Manager, Programs and Controls I. b. Plant Operations Director c. Manager, Plant Operations d. Manager, Radwaste e. Plant Engineering L Mpnager, Plant Material e 43

.. -. ~. _

.a.:

= l i \\ L 2. Under Director, Technical Functions a. Licensing b. Plant Analysis I c. Plant Proces Computer l l e. Start-up and Test ' d. Engineering Projects l 3. Under Nuclear Asurance a. Quality Control b. Quality Asurance I c. Welding i d. Safety Review i 4. Under Director, Radiological and Environmental Controls ! q a. Radiological Engineering b. Environmental Control i 5. Under Director, Maintenance and Construction a. M&C Technical Support l Because of this, there is often confusion as to just whleh group or groups will handle a given problem, which in turn, adds to the time it takes to resolve a problem. It also creates a situation where one group thinks another group is handling a problem while, in fact, r%ody is. It also results In there being 80 engineers located at the site. t. RECOMMENDATION t J The number of separate engineering groups at Oyster Creek should be reviewed with the goal of reducing the number.. This should also result in reducing the need for having 80 engineers at the site. Where there exists a need to have multiple engineering groups, there should be one person at the site designated as the lead Division representative who would asume the administrative and other responsibilities other than technical eeee l O/C PLANT ENGINEERING Nuclear & Core Management FINDING IV-P-2 w l The projected manpower level is high for the Oyster Creek Nuclear and Core Management group. DISCUSSION The onsite Nuclear and Core Management group at Oyster Creek has i been authorized to expand its manpower to six engineers in 1983. At the l present time there are three engineers filling those positions. Oyster Deek i 44 I m.-,.

I e has had difficulty in finding people willing to stay in those jobs, primarDy because they feel the job h too narrow. The worklo' d for this group, a assuming they do not duplicate offsite functions, could be reduced so that it would not require a staffing level of six. It is understood that partial Nstification for this ' level is to support shift operations for such events as power level changes, startup, data taking, etc. RECOMMENDAP.ON Operating procedures should be prepared that will reduce the a. dependence on the Core Management group during planned plant evolutions and during periods of taking data. It is understood that forthcoming plant changes (cycle 10 outage) will simplify the procedure requirements. b. Action should be taken to assure that the Oyster Creek Core Management group does not duplicate efforts of the Nuclear Analysis and Fuels seejlon in the Technical Functions Division. F Reevaluate the staffing level of the Core Manage' ment group. c. L- [ m IJ L I i l 1 i 45 .-..,...e+

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l l 1 O/C RADIOLOGICAL CONTROL l FINDING IV-O l There are too many instances where radiological controls are not as good as they should be. The work force has not accepted enough of the responsibility for high quality radiological work performance. Excessive generation of radioactive waste is part of these problems. DISCUSSION The findings and recommendations on radiological control for Oyster Creek are summarized here in words similar 'to those for TMI-1. 'Ihe discussion section under TMI-1 radiological controlis not repeated leere but it provides useful background information for Oyster Creek. There is a more urgent need to improve the radiological control program [ at Oyster Creek than at TMI-I for the following reasons: The consequences of not having a good radiological control program a. at a boiling water reactor are worse than at a pressurized water reactor because there is more radioactivity spread throughout more systems and throughout more routinehr occupied arena, f b. Major radioactive work in the long cutage now just beginning at Oyster Creek. I~ Correction of the poor attitude toward radiologleal controls has - c. not progressed as far at Oyster Creek as at TMI-1. Neither the work force no,r radiological control personnel perceive that the i radiological control organization should be helping to get the work l done. Productivity is worse at Oyster Creek than at TMI-1 and radiologleal controls are blamed as a major cause of this low productivity of the work force. d. The radiological control organization at Oyster Creek has been slower in developing radiological engineering competence than at TM1-1. Many of the radiological control technicians at Oyster Creek have been contractors, whDe TMI-1 has seldom used l . contractors for these jobs. These situations mean that it has been hard for the radiological control organization to exercise the leadership needed in getting the radiological work performed with good radiological control m RECOMMENDATlONS ~ a. Increase the efforts of managers and supervisors to get excellent radiological performance as an inherent part of every job performed by their workers. b. Improve the working relationships between the managers and supervisors.o.f the radiological control groups and the managers l l 46 V-

and supervisors of the work force. His requires station management as well as radiological control management attention-i l since a one-sided effort to cooperate wlR not worir. c. Use a radiological awareness committee similar to that at TMl-1 i to heb in accomplishing these first two recommendations, i d. Upgrade the performance of radiological control technicians by improving their ability to identify and report radiological deficieneles. e. Speed up the correction of radiological defielencies and increase {. the attention to solving the problems which lead to a repetition of defielencies. Both radiological control personnel and others in the station are required for these efforts. l f. Decrease the number of radiologleal control technicians as the 1 9 work force pleks up its own responsibility for good radiological l work performance. ' ( l g. Commence promptly the training of radiologleal control technielans covered by written procedures. and their first line supervisors to handle unusual situations not 1. h. New written procedures, new management systems, and new gimmicks should not be considered necessary to carry out these I recommendations. Each one of these recommendations is a logleal extension of what has been started and would likely be defeated If buried in new paperwork. eee. O/C NUCLEAR SAFETY REVIEW Plant Operations Review Committee (PORC) l FINDING IV-H ~ l Senior management people at Oyster Creek are spending too much time on PORC matters. DISCUSSION k BETA was informed by several members of the PORC that they spend twenty hours or more a week in PORC meetings at Offter Creek. De members of the PORC are key managerfrent people at the site who are regonsible for areas requiring their, daily attention. By spending so much of their time in PORC meetings, the plant is deprived of their services. It was also reported that some of the items reviewed by the PORC are of minor significance which should not require that level of review. It was l also indicated that the PORC is spending much time rewriting poorly prepared i documents. These two actions result in placing a heavy demand on the i members. 1 47 a

i l RECOMMENDATION l A review should be made of the Technical Speelfications to determine i if the present wording is such that it requires PORC to review documents !~ beyond the recognized scope considered appropriate,'or if minor items are being PORC reviewed because of local interpretation. Action should be taken to expedite the changes made at TM1-1 for conducting independent onsite safety review. In addition, poorly prepared documents which are 1 submitted to the PORC for review should not be rewritten by the PORC, l' but returned to the author for correction. Once the people understand that the PORC will not do their work for them, the documents wDI be better prepared. The Director, Oyster Creek, should expedite these actions in order to free up his key management people from excesive time spent in PORC so they can perform their normally assigned jobs and to eliminate the excessive delays when documents are held up pending PORC review. l eeee s O/C ADMINISTRATION FINDING IV-I The number of people asigned to administrative work at Oyster Creek 4 appears excesive. DISCUSSION ~ There are 48 GPUN people at the Oyster Creek site that fall in the category of Administrative Support / Services. These are broken down as foHows: Building Services /FacDity Maint 4 { Emergency Planning 1 i Quality Control 1 Licensing 1 Training & Education 3 M&C Planning & ScheduHng 3 M&C Field Const 1 M&C Tech. Support 2 M&C Admin. Support 3 l l Contract Admin. 2 Procurement / Purchasing 2 g Computer Operations 2 Document Control 11 Industrial Safety 2 Personnel "5~ Word Processing 4 Plant Admin. 1 TOTAL F e 48 l- - --- -.=. = = : - - = 2 2 - - - - --- = --

X In addition, there are 56 GPUN employees at the Oyster Creek site identified as Clerical / Secretarial Services. following groups: These are assigned to the Management /Mgmnt Support 10 s. Senior Control Room Operator 1 Radwaste 1 Start up & Test 1 !( Plant Maintenance 1 Building Services 3 Planning & Scheduling Engineering .5 Emergency Planning 1 QA 3 QC 1 Nuclear Safety Review 1 Licensing 1 Training & Education 3 i s Environmental Control 1 HP D J 3 Radeon 2.5 M&C Planning & Scheduling 1 M&C Tech Support 1 M&C Admin Support 4 i Conksch 1 Proedrement 1 Storeroom / Warehouse 1 Plant Project Engineering 1 Bu%et & Cost Analysis 8.5 I. Industrial Safety 1 Personnel 2 Security 1 Plant Admin. 1 TOTAL C These two categories of employees account for 104 employees. It appean to BETA that this number is larger than necessary to carry out the onsite tasks. There is no single area where large numbers of people are assigned, and in each individual case, a logical argument could be made for there being a person or so assigned. It is the total number that leads to the belief that excesses exist. Elsewhere in this report, there is discussion on the building up of individual staffs. It is suspected that a number of u i the positions listed above faR in that category. It is difficult for BETA to recommend just which of these positions could or should be eliminated. Collectively, six Divisions are responsible for these 104 It would appear that a number of the functions or tasks they'12eople. perform could be combined and shared; however, this wouWrequire some give and take on the part of six Division Directors. REC'OMMENDATION The -six Division Directors involved with providing the 104 administrative /elerical positions at Oyster Creek should be advised that the total number of these two types of positions onsite at Oyster Creek will be ~ reduced. The Office of the President should set an arbitrary number, l 49 l in. - - -~~~~~ ~ '~~~~~~~...-.

.~_a l l l NOTE: This item has equal applicability at the TM1-1 site where there ~ are 106. employees in the categories of administrative support and clerical services. eoee O/C MATERIA 13 MANAGEMENT Purchasing i i FINDING IV-J-1 The purchasing operation at Oyster Creek is receiving inadequate clerical support. DISCUSSION in connection with the previous comment concerning excessive clerleal 9 personnel at Oyster Creek, there.are situations where required clerical work is not being adequately performed. This situation is an example of where under-utilized clerical people are not being assigned useful but possbhr enerous functions at the site. At the time BETA conducted the review of Purchasing at Oyster Creek, in April 1982, purchase requisitions were being j received at the rate of 75 per week. At that same time, there w6s a i backlog of 111 requisitions awaiting typing. In the previous section of this report, BETA comments on the excessive number of clerleal and administrative support positions at Oyster Creek, yet in Purchasing, the support is scant. BETA was subsequently informed of procedures and methods to reduce the backlog and preclude recurrence by processing some Oyster Creek requisitions in Parsippany. p assoelated with the upcoming cutage, the efficiency of purchasing wo I improved if the excessive clerical people already present.necessary clerical support were onsite I RECOMMENDADON Consider reassi [ support processing o'gning Ightly loaded clerleal people to Purchasing to requisitions. eoee O/C MATERIAIS MANAGEMENT Warehousing FINDINO IV-J-2 ess The stores and warehouse function [ Oyster Creek can improve its j support of the plant. DISCUSSION Past performance of the' warehouse at Oyster Creek was inadequata. Even for items said to be in inventory, difficulty in locating and issuing was frequently encountered. A recent inventory has revealed large quantities of direct' turn over (DTO) material on han4 as web as errors in the stock records, compHeating the warehousing job. 50

'I........ .. - - -. A- *- - - The inventory b now on-line, low limits are specified for automatic reorder. Shelf-life items are identified, and a workable program for preparing ordering data for stock and spares is in proces in Plant Engineering. I' - The usefulnes of the improvements in warehousing wlB be enhanced when the CRT terminals giving acces to inventory records are installed in the plant. The next step which should be undertaken in the warehouse is warehouse assistance in staging material for jobs scheduled to start soon. In this . concept, warehouser.icn would asemble the material for a job and have it ready for hsue on a job basis rather than on a line-Item of-material basis. RECOMMENDATION Expedite instaLtion of CRT's in the plant to give direct acces a. to inventory records. ** [ b. Carefully plan the disposal of direct turn over material on hand that is not required for plant support. Consider undertaking stagirg of. material on a job basis.. c. eeee _O/C MATERIAIS MANAGEMENT Accounts Payable FINDING IV-J-3 l Delays in proceming invoices for payment are creating significant problems for Purchasing. DISCUSSION At the time of the BETA review in AprD 1982, the Purchasing Manager was encountering situations in which suppliers were demanding Cash on Delivery or payment by certified check prior to shipment. One supplier had established a pattern of filing a claim in Sman Claims Court simultaneously with submitting his invoices. All of this is a distraction and decreases the efficiency of the purchasirg operation. BETA was informed of steps taken and of plans in proces intended to solve this problem and of progres made 4e-date. RECOMMENDATION The backlog in Accounts Payable should be promptly eliminated, i 51

? 1 I I I O e 6 e r* N e Ee O P .1 CliAPTER Y 1 s UCLEAR ASSURANCE FINDINGS AND RECOMMENDATIONS G. ~ e-A 4 4m L. \\ l l O .O e M e f i. 0 I - 9._ . c, .--o --s-.

CHAPTER V. NUCLEAR ASSURANCE PINDINGS AND RECOMMENDATIONS GENERAL I The creation of the Nuclear Assurance Division is probably unique within the nuclear community. It brings together in one division three separate groups whose independence from the day-to < lay operation is an Important ingredient. It encompasses Quality Assurance (QA), Training and Education (T&E), and Nuclear Safety Assurance (NSA). At the time of its establishment QA was for all intents and purposes, a fully functioning group operating out of the Met Ed (TMI) organization. About two years after the l accident, Oyster Creek QA was folded into this group. While there has been a sizeable effort to make the GPUN QA more effective and cohesive, it was essentially a going organ!zation at the time the Nuclear Assurance Division was formed. From the time of its first involvement with GPU in early 1980, BETA has been impressed with the management of the QA program, its depth of experienced people, its philosophy of coverage, and q the support it received from the corporate levet l Under the current task, BETA did not find, nor did it expect to find glaring deficiencies or flagrant cases of over-coverage. The question which was addressed, was whether or not the present QA management was doing its share to create the most efficient. operation while at the same time not compromising its high principles. In the early stages of its review BETA did conclude that not as much effort was being devoted to this aspect as I should have been. Over the ensuing months it became apparent that this situation changed for the better. QA management has instituted a. number of changes which will result in obtaining the proper amount of QA/QC [ coverage but with less people. This effort should continue. 6-- The Training and Education Department was and is a different story. A major issue arising out of the accident at TMI-2 was training, particularly ) operator training. As a result, a major effort to create a comprehensive training program at TMI was initiated. But unlike QA, it had to start from a rather meager base. An organization which at one time consisted of less ? than six people had to be expanded in a short time. Nonexistent training programs and courses had to be created, and new people had to be assimilated. At the same time this was going on, the same leading people were needed to prepare testimony and give it for the legal proceedings. If this were not enough, the problem coming out of the operator examination cheating l Incident arose. Circumstances dictated that key members of training j managem'ent devote considerable effort in attempting to resolve this problem. A further complication was the need to institute a vigorous training program I at Oyster Creek.

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s What BETA found in the Training and Education Department was what was expected in view of the-circumstances.- When compared with the state existing in 1979, significant progress had been made and was continuing. However, there were many situations where it was apparent that a given 1 program had been conceived and work started, but, due to lack of management attention and the lack of qualified and experienced people, the goals and objectives of the program were falling shwt. It would appear that too many things were being attempted, in too short a time, with untrained people, ( 52 =:

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1 1 and where full management attention had been diverted to other things. This is one area within GPUN where the program morely needs the opportunity l to settle down. The third element of Nuclear Assurance is Nudlear Safety Assurance. ,~ Even though this department was incorporated into NA at the time of its formation, it was not staffed at the headquarters level for the first year, Subsequently NSA provided the corporate framework for establishing the newly imposed requirement that there be an independent onsite safety review group (IOSRG). The functionirg of NSA has just recently started and the ~ effort to staff it continues, BETA found it too earW to asses the ( effectiveness of the TM1-110SRG, and such a group has not yet been formed at Oyster Creek. As a note of explanation, when BETA began its review in January 1982, the System Laboratory located in Reading, Pa., was organizationally under the Director, Nuclear Assurance. Midway through the review the laboratory was shifted to come under the Director, Technical Functions. BETA's findings relative to the System Laboratory are covered under Technical Functions. .I eees ~ N/A READING GROUP FINDING V-A The group presently assigned to Nuclear Assurance located at Reading should be eliminated and the functions reassigned to Parsippany. DISCUSSION e There is a group of three people located at Reading who report to the o' Director, Nuclear Assurance and handle budgeting and administrative functions for the division. There is no reason related to GPUN work performance for this group to be located in Reading and the fact that they i g are there rather than at Parsippany is an inefficiency. RECOMMENDATION b Consider eliminatirg this group at Reading and reassigning the functions to Parsippany. u i e 53

l. N/A CORPORATE

• TRAINING Development Courses l

FINDING V-B-1 +- ~ There are many training and development courses offered whleh are useful but not essential. DISCUSSION l It is BETA's opinion that GPUN training resources should be focused more on resolving known and immediate problems directly related to the nuclear power plants. To do otherwise only dilutes the effort from those important areas. A. review of the GPUN Training and Education' Course Catalogue (dated March 25,1982) shows thirteen Management Development Courses offered; ~ some on a voluntary basis. They are: 1. Management Development Program 2. Communications: Proces in Perspective 3. Decision Analysis Course 4. Effective Writing 5. Effective Writing, Phases 2 & 3 6. Dynamics of Face-to-Face Communleation 7. Leader Effectiveness Training 8. Listening: Sharpening Your Analytical Skills F 9. Scientific Analysis of Ideas: Communleations Course i

10. Basic Supervisory Development Program

11. Fundamentals of Supervision

12. Supervisory Training for Managers i

13. Perception: Key to Effective Management Communication WhDe a case could be made that every one of these courses is worthwhile and would improve the effectivenes of GPUN, it is BETA's opinion that many of them, as presently structured, are not esentiaL There should be a course, or possibly two given to employees who are, for the first time, being put into a supervisory position. Such courses are necesary and are i

l discussed elsewhere in this report dealing with supervision. As far as the other courses are concerned,,each Division Director and his managers should ,I bear the responsibility for training their own people on matters such as how to perform their job more effectively. The Training Department could be tasked to prepare course material for these subjects which would be available to Division Directors to use in informal.non-clamroom type of instruction. It is BETA's opinion that having Training perform this function creates a } number of bad side effects: It ten' s to relieve supervisors of their responsibDity. d a. b. The courses are viewed as a nice place to go for a rest. Because of the nature of some of the courses, it is possible that c. the people teaching the course know less than the students. 54 = - - - -=

d. It' creates a problem for some of the senior managers who, for whatever reason, will not let their people attend these courses, and then are viewed by their own people as being against company pohey. RECOMMENDATION Review the courses offered in Management Development with the aim of eliminating those which do not materially contribute to the safe and efficient operation of the GPUN plants. t ee N/A HEADQUARTERS TRAINING EFFORT Effectiveness + FINDING V-B-2 The headquarters training group is not concentrating enough on coordinating plant training efforts. DISCUSSION In the GPUN functional organization there is a headquarters group responsible for training. This group is headed by the Director of Training and Education who reports to the Vice President-Nuclear Assurance. Reporting to the Director of Training and Education there are three managers: a manager for plant training located at TMI, a manager for plant training located at Oyster Creek, and a manager for corporate training located at headquar*ers. The functions and responsibilities of the two site managers are clear, and while there remains more work to have these site organizations operate t effectively, at least the direction they are headed is correct. BETA questions the direction being taken by the headquarters group, including that of l l Corporate Traini.v. BETA does not question Corporate Training's responsibility for training GPUN personnel located at Parsippany. This is t i an appropriate task. What is questioned is an apparent lack of headquarter's coordination of site training. BETA expected to find a headquarters grou that kept track of what was going on at the sites to make sure efforts were ( not being duplicated or that the two sites were not going off in different directions. Very little of this was found. One contributing cause for this was GPUN's inability to fill the Director of Training and Education position for most of 1982. ~ As a result, the responsibilities of this position have been divided between the Vice President-Nuclear Assuranat$ and the Manager of Corporate Training. A further distractf5h was the assignment of the Vice 2 President-Nuclear Assurance to the TMI-1 Steam Generator Task Force in February 1982, which reduced the amount of time he was able to devote to training. Assuming these complications did not exist it is still BETA's opinion that the headquarter's role in training, as described above, is not being pursued to the extent that it should. Whether this function belongs in Corporate Training or with a separate staff assigned to the Director of s 55

) = -.%.C Training and Education is not the issue. The irsue, as far as BETA is concerned, is that there are people in the headquarters organization that could be doing this function but they are not. l l RECOMMENDATION The goals and objectives of the headquarters training and education group should be reviewed to ensure that higher priority is given to carrying out the function of coordinathg and overseeing the efforts of the two site i j training groups. ~ .e N/A TMI-l TRAINING Schedulirur FINDING V-B-3 There are ineffielencies in the TMI training effort due to a lack of meaningful scheduling. The Training Department has difficulty in obtaining data to schedule its training. DISCUSSION _ Based on interviews conducted and a detaDed review of the records, BETA concludes that inefficiencies in the TMI training program are brought about due to the lack of a realistic schedule. It stiould be possible, at this l stage of events at TM1-1 and in the Training Department, to develop a one year training schedule which can be generally adhered to, espeelally with regeet to start dates for classes. Consultation between TMI-1 and the Training Department should result in knowing that, during the next year, there will be so many classes taught to licensed and nonlicensed operators, requalification, etc. With this information, Training should be able to develop a long range schedule that makes the most effielent use of the instructor staff. This is particularly evident in the case of Security Training, wherein a number of classes were held with just one student. The argument was advanced that the Security people never knew ahead of time when a new security person would be hired. Thus, Training was always put in the position of having to train someone on short notice and of doing it inefficientW. A simple change could be made wherein Training would schedule four (or some number) of Security clases per year, starting on fixed dates. It would then be encumbent on Security and Human Resources to have Mw hires available on those dates. f RECOMMENDATION All divisions involved with having people trained at TMI and the TMI Training Department should arrive at a realistic training schedule that covers one year ahead. This will require these divisions to feel some degree of I responsibility for whatever inefficiencies they create by not providing useful data or by being insensitive to the needs of Training. i 56

eeee N/A TMI-1 TRAINING ^ A ttitude I' ~ FINDING V-B-4 There is an overly " understanding" attitude which prevails in the TMI r Training Department, especially with respect to operator training. DISCUSSION 7 I Interviews conducted by BETA in March and AprD 1982, Indicate that I there existed an attitude, not only within the TMI Training Department, but also at the plant, of almost patronizing the students. There seemed always to be excuses why students did poorly, why operators made mistakes, or if there were cheating, why it occurred. It appeared that the Training Department had become very "und' erstanding" of aH the problems the students 1 may have and, as a result lacked the degree of toughness, accountabDity, L and insistence on performan,ce needed in the nuclear profession. In a foDow-up review conducted in November 1982, BETA found this situation improved but not entirely corrected. WhDe there is merit in making the task of l learning as easy as possible for the student, our experlenet. indicates that m. y-the student must be chaDenged; he must feel some pressure to exert himself; i he must have some apprehension over not doing well. While these concepts may differ from the so-caDed " modern" form of education, we contend that they work. The students are being paid a good salary to learn, and they need to be tom what is expected of them and then to be hem accountable. For example, having students evaluate their instructors may be an essential part [ of modern education, but it tends to put the student in a position to justify j his own lack of initiative and sense of responsibility. Instructor evaluations shouM be conducted by the training staff or other elements of the i organization, such as Operations or Technical Functions. AB elements within GPUN concerned with training have been put under a lot of pressure over the past three years as a result of the TMI-2 accident and then t))e exam cheating incident. There have been groups, committees, etc., auditing, rWvieW!nfEd analyzig the TMI training program. WhDe most of this couM not have been avoide4 care must be taken that it has i not caused attitudes to develop within the Train;1g Department that can result in a less than optimum product. In its review, BETA did not attempt to make a first-hand determination of the quality of tf4 training effort. 1 For example, we did not attempt to fintiout if licensed operators were ~ j beirg taught the correct material in quality or quantity. flowever, in our I attempt to make some ju% ment on the efficiency of the operation, we dM have an opportunity to talk to the training staff, the students and the product Based on this, it is our opinion, that too much emphasis is being h users. placed on proving to the world that the training program is good and not enough on doing what shouM be done to produce a competent operator. 'Ihe i Trainirg Department needs to settle down, get back to what they know their job is, and concentrate on that, rather than constantly looking over their shoulder wondering what it is they are doing wrong. 57

'l RECOMMENDATION (~ To the extent possible, GPUN management should resist bringing a. b-in more outside groups to review the training program. hre are t ample means within GPUN to do this, i b. Now that the outside pressure has abated somewhat the Director, r Training and Education, should direct the efforts of the TMI Training Department to concentrate more on producing the best A product they know how, and less on trying to prove it. Greater effort should be spent on making the students more c. responsible for their own performance. eeee N/A TMI TRAINING Instruetor Supervision FINDING V-B-5 ~ .i There exists a lack of supervision of instructors in the TMI Training Department. DISCUSSION During the time of the BETA review of TMI Training, a number of instances were noted indicating that the training staff lacked needed ( supervision. In some cases, it was because supervisors, who were present, -[ ,I did not react to situations where instructors were not performing their j assigned tasks. g Based on these obseryations, such lack of reaction appears typical of the normal mode of operation within the training building. Had this not been the case, the job inattention noted would not have been as obvious and distracting. In other cases, it was noted that there just was not any supervisinn present. i It would seem that this findirg should be unnecessary considering the seniority and experience level of the training staff. However, BETA was alerted to the possibility of this condition by a number of comments made by GPUN people outside the Training Department. The main thrust of these '~ comments applied to the leek of supervision _ over the instructors in the classroom. BETA was not able, or In a position to observe instruve perfo Dree in the classroom nor would it have provided the necessary atmosphere to make a mean,ingful judgment. HowevW, based on the observations made, there should be concetT over classroom performance. l bstructor performance, good or bad, has a Insting effect on students. ~ If instructors demonstrate a lack of interest in their jobs in any way, thia is transmitted to the students. As far as BETA is concerned, this is another l Indication for the need for a more tightly run Training Department. 58 ? .-.._n.--

I i i RECOMMENDATION There are 15 supervisors in the 53-man Training Department at a. TMI. 'Ihis is a much higher ratio of supervision to workers than normal. The Manager, TM1 Training, should review the basic l -t principles of supervisor responsibility with his supervisors, b. It is BETA's opinion that the Manager, TMI Training, creates the ~ impression that he is inaccessble to his staff by the location of his office in the Training Building. While he should have a private office, it might be better if that office were located'out in an area where he could see his staff, and they could see him. When the Manager, TMI Training and the Operator Training Manager c. are both absent from the Training Building, someone should be designated in charge and assume the responsibility to monitor what is going on in the Training Building. ee N/A O/C TRAINING Effectiveness t, FINDING V-B-6 Findings reported on TM1-1 Training have applicability at Oyster Creek. DISCUSSION ~ i ~ In the BETA review of GPUN Training, a conselous decision was made to cencentrate the effort on TMI-1. While a cursory review was made of Oyster Creek training, it was felt that since the TMJ-1 training program had received a greater share of attention for a longer period of time, it would, therefore, provide a more realistic basis for review, flowever, it is BETA's opinion that each of the findings and recommendations contained in this report relating to TMI-1 Trainirg also have app!!cability at Oyster Creek. I In this connection, it is noted that there appears to be very little communication or interplay between TMI-1 and Oyster Creek training. There s seems to be an attitude that "if we didn't do it, it isn't any good". We saw numerous cases where each site was developing its own procedure, document, plan, etc. For example, there has been an identified problem in chemistry training at both sites for a long period of time. Yet, at the time of the BETA review, there was almost no interaction between the two sites on this subject. It is also BETA's opinion, based on Jte cursory review of Oyster Creek . training that, as in the case of TMI-1, more attention is being paid to the l " trappings" of training rather than to a concerted effort on obtaining an effective end product. RECOMMENDA'110N Headquarters Training and Oyster Creek Training should review a. the findings and recommendations contained in this report listed 59 s.

=, under TMI-1 Training and consider them for applicability to Oyster Creek. k b. Headquarters Training should establish a inechanism which forces TMI and Oyster Creek Training Departments to communleate, 9 cooperate and interact with each other as a matter of routine. t Nf(A QUAIJTY ASSURANCE Engineering FINDING V-C-1 I i out the requirements contained in the GPUN. Operatio t Plan. DISCUSSIO N Assurance Design and Procurement shall, among other d I i "1.6.1.2c. other organizations when these procedures control or ex i upon important-to-safety systems, components or activities." and I "1.6.1.2g. Review engineering specifications and procurement i-documents to azure quality requirements are incorporated," Similarly, at the plants, the Manager, Quality Absurance Mod / Ops shaB, among other dutes. "1. 6.1.3 d, Review engineering specifications and procurement documents to amure quality requirements are incorporated" BETA concurs with these assigned duties as reasonable and appropriate. It is BETA's perception, however, that the QA engineering groups go significantl procedures.y further, reviewing not only speelfications, but also drawings and For instance, M&C installation procedures, as wen as the engineering specifications on which they are based, are receiving QA engineering review prior to release. Lkewise Plant Engin& fring or Technical Punctions resolution of QDR's and MNCRYteceive QA engineering review -, and concurrence prior to release. BETA considers that many of the QA engineering reviews and approvals currenty occurring beyond that specified in the OQA Plan are redundant and delay the accomplishment of work. After approval of the engineering speelfications and the material procurement documents, the burden shifts to the engineering and work performance groups who are also bound by the OQA Plan. The functions of QA Engineering at this point should be to ) provide asurance to those managers not in the QA organization that the i ~ 60 g. _ ______.... a -- - m

~' o n OQA Plan is being complied with. This could be done by sampHng procedures and drawings already approved by Tech Functions and Phnt Engineering and M&C procedures implementing engineering specifications. I The current QA reviews do serve useful pugoses, however. It is during these reviews that the plans for future monitoring are developed and in which the QC holdvints are determined and speelfled. The review of procurement documents eBows for developing receipt inspection phnning and procedures. Lkewise the review of engineering resolutions of MNCR's and QDR's eBows the proper pknning of the necesary reinspections. Also, QA reviews are frequently sought by the PORC as an assist to the PORC's review and approval. All of these considerations lead to extensive QA reviews. None can be said to be unnecessary or meaningless, but all become one more hurdle in the issue of approved procedures and working documents. l The thrust of this it.em is to encourage the development, of phns wherein QA reviews, other than those required by the OQA Plan are performed simultaneously with ongoing work, rather than sequentially in the preparation ~ of work procedures. RECOMMENDATION As Tech Funettons, Plant Engineering, and M&C mature, eensider i reducing the number of engineers assigned to QA Engineering. eeee I l N/A QUAIJTY ASSURANCE Operations i FINDING V-C-2 There are too many people asigned to Ops QA for the expected decline in the future workload. DISCUSSION a Operations Quality Assurance (Ops QA) provides direct asistance to the operations, maintenance, and engineering supervisors performing important-to-safety work, usually by objectively monitoring work in process and providing observations to the supervisor of the work. This function is l g of value to the Company, partleularly in Eght of the training and detaDed l 9 knowle%e of the QA Plan on the part of the Ops QA monitors. The issue L k the extent to which thh service is pr,osided. As the Company becomes o s more stable and mature, the value of extensive monitoring is decreased. RECOMMENDA'110N ~ Consider reducing the number of Ops QA monitors as the work force stabilizes and matures. To phase down the size of this group, consider not filling vacancies, when occurring. l l 61

eeee N/A QUAIJTY ASSURANCE -Manufacturing Asurance - Y } FINDING V-C-3 The Manufacturing Assurance section is larger than is required for known future work. DISCUSSION t in the future, the need to purchase large quantities of important-to-safety material will be reduced as the modification work at TMI-1 and Oyster I Creek approaches completion. This should reduce the level of effort required { in the Manufacturing Asurance section and should permit reducing its size. RECOMMENDATION Consider reducing the size of the Manufacturing Assurance section as, the manufacturing effort associated with the recent large modification efforts decrease. m eoee N/A QUALITY ASSURANCE Operational Quality Assurance Plan FIND 1NG V-C-4 There k a rkk asociated with the new Operational QA Plan. DISCUSSION No specific fnit is four.d with he new Operational QA Plan--even the i NRC accepted the Plan without comment. Certainly, the Plan, as a plan, L-is not bad, and fits the often stated intent of the President of having the best Quality Assurance. During the interview phase of this assessment, however, an undefined, not clearly stated concern and worry on the part of many in the Company was expresed regarding the complexity and workability of the new Plan. Since the Plan is complex and forcefuBy worded, it wS1 be important during the implementation phase to exercise the finest judgment to avoid paper wars, work stoppages, and organizational conflicts. A wan-engineere4 objective, supportive implementation of this* Plan wlR enhance the Company's performance. i RECOMMENDATION l The QA Director must stay closely involved during the implementation phase. His best ju% ment will be required. I e 62 i

I' "oeoe N/A QUALITY ASSURANCE TMI-1 QA I' FINDING V-C-5 The TM1-1 QuaHty Assurance Department creates the illusion in the minds of others that the Department is not supporting the plants. DISCUSSION ~ We frequently encountered senior people in GPUN who felt that the QA Department was not responsive to the absohte need for QA support. The opinion was expressed that the QA Department was not urgently concerned with resolving problems and clearing deficieneles. Some felt that QA was unnecesarily interfering vf th the accompHshment of work. i ? Although it was disconcerting to encounter these feelings and opinions in important people, BETA can not, in fact, based on close dealings with TM1-1 QA personnel, confirm the opinions of others expressed above. It is important, however, that such feelings do exist, and they must be overcome. BETA beHeves progres is currently being made in disabusing people of such concepts of the QA Department. As long as such feelings do exist, however, QA win remain in an adversary role, rather than the support role intended. RECOMMENDAMON s. The Director, QuaHty Assurance should recognize that these feelings exist. He should make an effort on his own, talking to various senior people in other divisions, to find out the basis for these feelings. It would then be encumbent on him to find out what is causing this problem, to take the necessary corrective action in his own department, and to work with the senior people in other divisJons to determine if there is somethirg they can do ~ l to ease the problem. a b. The Vice Presidents should ensure that their people support the Corporation's Operational Quality Assurance Plan. In this instance, " support" does not mean simple compliance with the letter of the law, rather " support" means beHeving in the Plan, m u g I l l 5 63 .=== -

e - h e 0 f e o h i CHAPTER VI [ r. e TECHNICAL FUNCTIONS FINDINGS AND RECOMMENDATIONS ( e I \\ r, l 8 V s [ O e G "v-

CHAPTER VI. TECHNICAL FUNCTIONS FINDINGS AND RECOMMENDATIONS GENERAL 9-Of all of the Divisions, Technical Functions (T/F) was the most difficult to establish and to get productive, not because of its uniqueness, but because of its departure from the past in two significant areas. One was that it assumed line responsibilities and the other was that it was given the task to build an in-h'ouse technical capabDity where little had existed previously. i 'Ihis meant assembling a group of over 200 engineers by bringing together the nuclear engineering resources of Met Ed, GPU Service Corporation and, I later, Jersey Central. But it also meant hiring from the outside a large riumber of its group. Doing this would probably have been accomplished without too much difficulty if there had been a one or two year hiatus on i l work, thus allowing the new organization to form and become somewhat q capable. Instead, heavy demands were placed on T/F as if it were a fuBy operational group and this resulted in technical work needed at the sites to , fab further and further behind. It is also significant that the demands during this period were abnormal. At TMI-1, in addition to all of the design changes resulting from the accident (TMI Lessons Learned), the steam generator tube. leakage problem had to be faced and resolved. At Oyster Creek the engineering workload increased significantly because of the sparger and torus problems, in addition to the numerous repair problems. Other Divisions within GPUN had to face many of the same problems but not with the same intensity. Either they were organizations which essentially already existed such as in the case of the plants, or their services were not as time sensitive to plant operation, such as Maintenance and Construction (M&C). For example, if M&C did not reach fuH capability for two years, which it didn't, the plants did not have to do without a maintenance capability albeit less effective. The same could be said of a number of other divisions. However, T/F had to produce and do it during a period of rapid growth. EssentiaDy, this is what BETA found in its review of T/F. It found an organization struggling to get its work done with a lot of new people i still tryirg to figure out what their jobs were. It found top management within T/F having to spend an inordinate amount of time solving day-to-day problems that a mature organization would be handling in a routine manner. It found T/F management still attempting to put in place methods of operation suitable for running a large 250 man engineering force in contrast to their past experience of running smaller groups and depending"more on outside contractors. The situation was further complicated by the one year or so taken to Incorporate Oyster Creek engineering into T/F. Prior to the formation of t GPUN, there existed a relatively small but knowledgeable group under Jersey l Central at their headquarters location in Morristown, New Jersey. For the i first year of T/F's existence, it primarily concerned itself with TMI-1 and l TMI-2 problems eBowing the group at Morristown to continue handling the Oyster Creek work. In May 1981, the Jersey Central engineering group was moved to Parsippany and came under more direct control of T/F. Because of their unique knowledge of BWR technology, they could not be distributed l 64

l throughout the new T/F organization and were set up as a separate group. This is one reason why today there exists a large Oyster Creek contingent i in Engineering Projects., Anomalies such as this are being worked out and progre_ss is being made. The situations deserbed above are not cited to indicate that the decisions were wrong or untimely, but to provide an understanding of the problems that had to be faced. It will take more time for T/F to mature into an effective, smooth running organization. The speelfic findings which foHow reflect some of the problems BETA considers esential to solve in reaching that point. l T/F OVERALL EFFECTIVENESS =. FINDING VI-A ~ The overall effectivenes of T/F in supporting TMI-1 and Oyster Creek is lacking. DISCUSSION In order to achieve an efficient operation at the two plants, it is essential that there be timely and competent engineering support. When thb does not occur jobs will not be done properly, there will be much rework, the plants wlH suffer and costs will be high. This generally characterizes the situation existing today. It is more pronounced at Oyster Creek than at TMI-1. i l There has been a notleeable improvement in this situation over the past two years and further evidence of improvement can be seen. 'there are many factors, previously discussed which contribute to T/F's inability to support the plants effectively. Most prominent is the newnes of the organization, new people learning their jobs and the large backlog of problems facing the new organization. As T/F matures, BETA expt ets to see continued improvement. The purpose of this finding is to point ou'. a number of basic areas that BETA considers are not being resolved within T/F at the needed l pace or in a proper manner. T/F has over 250 engineers and technical people devoted to TMI-I and Oyster Creek. That is a sizeable engineering force to manage. It takes l people who are capable of directing the efforts of many,multidiselplined 's l groups, ensuring that aR the elements that. go into creating a productive l engineerirg force are handled. This includes such things as: l,* ~ a. . Hiring. b. Trainirg e. Work assignment d. Organization e. ScheduMng of work L Work performance evaluation g. Customer needs/ satisfaction h. Cost performance 65

1. Contracting ~ It is BETA's opinion that the management of T/F has not grown er matured at the same rate that the size or needs of the organization have ~~ growfl. Management is still attempting,to function as if T/F were a smaB, independent, cab-me-if-you-need-me group of offsite engineers. It has not developed the capability to use effectively the large number of people now in place. High level managers become so engrossed in daily technical issues that the bulk of the engineering talent is left to fend on its own without sufficient direction. Managers need to learn how to stay involved in the technical details but not to the extent that their people are deprived of j direction. The organization has not learned how to discipline itself to meet commitments with a quality product. Achieving this is not just a matter of hiring more engineers. In fact, it is BETA's opinion that very few people should be added to T/F until the present organization can demonstrate it l can manage what is already there. Ultimately, T/F should be in a position to be the leading professional group within GPUN. It should be respected by the other Divisions for its technical competence and for its ability to solve technical problems at the plants before they become causes of lengthy shutdowns and delays. Today this has not happened, particularly at Oyster Creek. I RECOMMENDATION s. Hold the size of T/F to about where it is for the present. b. Look at how to enhance the capabilities of the various levels of management of T/F to run a large engineering group. c. Seek outside help if necessary to provide assistance to T/F management in learning how to run a large engineering group. eoee T/F ENGINEERING SERVICES Procedure Changes FINDING VI-B-1 It is too hard and takes too long to get a Technical Functions procedure changed. i 1 DISCUSSION The principal problem in the Engineering Procedures and Standards group is that it takes too long to get a change issued to a procedure. 1he feelings of others in Technical Functions are that since the procedure "can't" be change 4 and since it " won't work" as written, the procedure is simply knored. Responding prompty to change requests is a large part of establishing the authority of procedures and of building a memory into the system. l 66 l

( RECOMMENDADON Respond to change requests to Technical Functions procedures prompth. I T/F ENGINEERING SERVICES Engineering Cost Analysis \\ FINDING VI-B-2 ' The Engineering Cost Analysis section is not analyzing costs. DISCUSSION The service curvently provided by the Engineering Cost Analysis section ' ( is vital to the proper functioning of the Division, but the effort is not devoted to the principal reason for the section's existence-cost estimating I ~ [ and analysis. This section spends essentially fuH time interfacing between Technical Functions and the accounting systems. The normal accounting methods used in the GPUSC computer systenr (COMEC) of advance bookings, invoices rolled forward, and journal entry corrections (vital to the Treasury function) serve to generate confusion in the management of a project or activity. Since the busines information currently made available by COMEC, does not help make work management deelsions, the Engineering Cost Analysis section is required to devise and construct other busines reports that are useful to work managers. Fortunately, the section is able to do this, but only with significant effort which detracts from the primary function of estimating and analyzing costs. 'The Director, Fiscal and Information Management has been making efforts to resolve this problem. RECOMMENDAMON Concentrate the effort of the Cost Analysis section on cost estimating and cost analysis. Get this group out of the cost reporting business, eeoe T/F ENGINEERING SERVICES Design and Drafting FINDING VI-B-3 I ' Drawings have not been revised to show completion of modification work. j DISCUSSION The availabuity of corrected draw'Ings, showing changes made to l systems, is not good, During our interviews in Technical Functions, we were informed that drawirgs were not revised until five design change notless 67 J _m..n m ._m

(DCN's) had been completed. Then, the drawing would be revised, showing all five of these DCN's. Since the interval from the first DCN to the fifth DCN could be protracted, some drawings are not current as regards modifications. l RECOMMENDATION y Revise &awings when DCN's are received in Design and Drafting such that no DCN will be more than six months old. f T/F ENGINEERING SERVICES Design and Drafting I FINDING VI-B-4 l >g Rework, as measured by the number of Field Change Notices, is excessive. l l DISCUSSION Ideally, there would be no need for a Field Change Notlee, however the need will always exist. Some Field Change Notices should never have been written-the one requesting correction of a misspelled word, for example. But others are reaL AD are difficult to cope with and increase the cost of doing work. The number of Field Change Notices, and hence the amount of rework required, will decrease only to the extent the accuracy of the L original drawing is improved. Others have solved this problem by design reviews with consideration for constructability, ALARA, operation, maintenance, and accessibility. This should not require a large review board to accomplish, rather plant checks for existing conditions and supervisory review should suffice. R ECOMMENDATION_ Technical Functions, involving Plant Engineering as appropriate, should l conduct design reviews before work is started to decrease the need for Field Change Notices during construction, operation, or maintenance. j T/F LICENSING & REG AFFAIRS Staffing m FINDING VI-C There are too many people assigned to the Director, Licensing & Regulatory Affairs. DISCUSSION There are 38 people in this group. There are 14 assigned to PWR licensing,7 of whom are at the TM1 alte, and there are 11 assigned to BWR l l 68 l

licensing, 4.of whom are asigned to the Oyster Creek site. Seven are in Environmental Liceitsing and 4 are in Generic & Regulatory Affairs. 'Ibers o is justification for GPUN to carry a krger number of Licensing people than other nuclear units, partleularly during the past several years while hearings were-going on relative to TMI-1 restart. However, when the TMI-1 restart ' imue is resolved, the total number of people in this group shouW be reduced. The BETA review indicates that the size of this group is justified on the r basis that it performs engineering functions which shouM be done by [ Engineering and Design or Systems Analysis. Licensing and Regulatory Affairs (L&RA), to be most effective, shouM be in a position to provide a knowledgeable interface between GPUN and the regulatory bodies. It shouM avoid functioning in the extremes, where on one hand they are merely a paper-pasing mail &op, and on the other hand being in a position where they make tecimical decisions. They shouM provide a technical input into the decision making proces based on their unique knowledge of the regulatory process. BETA also questions the neceIsity to have a separate group of 3 people a assigned specifically to Generle & Licensing Affairs. That function could be performed by one person in the headquarters organization. It is also BETA's opinion that seven people, including those located at the sites (3), are too many to handle Environmental Licensing.. RECOMMENDATION The role of L&RA should be redefined to ensure it acts as the knowleckeable interface between GPUN and the regulatory bodies. It should be possible to effect a reduction in the number of people asigned to Licensing and Regulatory A'ffairs. After the TMI-1 restart, a further reduction should be possible without sacrificing the performance of any necesary fbnetion normally expected of this group. eeoe T/F hrlGIN5ERING AND DESIGN FINDING VI-D l There is a lack of intimate, day-to-day knowle%e of the problems being found at the plants that require engineering support or involvement. DISCUSSION k One esential element in creating an gffective engineering group that takes a leading role in improving the operation of the plant is knowle%e of what is happening at the plant. Our review indicates that this is lacking at Oyster Creek and TMI-1. There still exists too much of the attitude that if Technical Functions support is needed, the plant will ask for it. We couM l not detect a sense of " ownership" or inquisitiveness. There have been efforts made to improve thh situation but the results so far are meager. It takes time and effort to develop a headquarters engineering group that has the confidence in itself and has developed the confidence of the site peopla. The people in Engineering and Design need to have a better means of keeping informed on what problems exist at the sites without creating a burden on l 69 =-- ,= = = -

^ .u the plants. Each site has a Technical Functions representative and it may be appropriate to make more use of him as a source. 9 RECOMMENDAT10N The Engineering and Design Director should investigate means for having plant information and problems Dow into his organizat on on a routine basis and not just when Technical Functions support is called for. He should also ( instill into his people the feeling that they are more than just a service waiting to be tasked. P l1 T/F SYSTEMS ENGINEERING l STAS FINDING VI-E-1 The Shift Technical Advisor (STA) program at both sites, but particuhrly at Oyster Creek, needs to be reviewed and strengthened. DISCUSSION There are a number of problems asociated with the STA program at both sites. These problems are known by GPUN management and action is being taken to correct them. These problems involve attrition, the STA training program, and proper utilization of the STAS, both in their training period, and in their status as qualified STAS. There are a number of observations which BETA believes should be considered in GPUN's effort to improve the STAS; 11 appears that the STA training program is too operator oriented. 'Ihe purpose of an STA is to provide the Shift Supervisor on watch a higher degree of technical expertise during a plant crisis than normally resides with i i, the Shift Supervisor. While the STAS need to understand how the phnt operates, they are not there to act as a " super" shift supervisor. Their training should be criented towards developing a high degree of technical knowlecte of the plant, understanding why thirgs happen the way they do, and develop!rg the ability to anticipate phenomena at a technicallevel higher than normally expected of a Shift Supervisor. Our observation is that this k not being done. One contributing factor could be the practice of actually attempting to qualify STAS as SROs. .= There is a serious hek of understanding on the part of the Shift Supervisors at both plants on the role of the STA. To some extent, there is an element of distrust of the STAS' ability and of their motives. There is also a hek of understanding on the part of the STAS as to just what role they are to play, particularly during the vast majority of time that the phnt is not in an abnormal mode. ~ m 7'O 'M> .a. . n.. ..a..

l i e RECOMMENDATION In the proces,of developing the STA training program, whleh is -k. a. now underway, greater emphasis should be placed on providing the trainee with a firm technical foundation and les on making him a qualified operator. b. Consider changing the practice that STA's obtain an SRO Meensa. There may be certain factors that would lead GPUN to conclude that this practice be continued. However, all factors should be considered. STA's should be SRO trained and should be required to pas all requirements except the NRC examination. Incentive bonuses could stlE be awarded for this accomp1hhment. e. Make sure there are sufficient STAS in the training program to, handle, not only expected attrition, but to ensure that promised rotation out of the STA role will take place. d. Review th'e ground rules on just what an STA is expected to do during abnormal situations, and, just as important, what he is expected to do during normal day-to-day operations. After reviewirg these gmund rules, make sure the Shift Supervisors i [., understand them. eoee T/F SYSTEMS ENGINEERING Systems Analysis D_irector FINDING VI-E-2 The need for a Systems Analysis Director is questionable. DISCUSSION, There exists within Systems Engineering a group entitled Systems Analysis. It has two groups; Safety Analysis and Plant Control, and Plant Analysis. The former group, consisting of ten engineers, is basically responsible for developing and using the software to analyze plant safety. '~ The latter gmup performs trend analysis and is responsible for the STAS. Each of these groups k headed by a Idanager. The Systems Analysis ,k Director also handles Human Factors engineering. It is the opinion of BETA that the existence of the position of SystemgAnalysh DirecMr is unnecessary and can be eliminated. All of the function's now performed can be performed within, the two groups. RECOMMENDA'I10N BETA understands that action has been taken on this item. i i 71 ' L^- .. coo. % e y.

T/F SYSTEMS ENGINEERING Involvement in Training l FIN DING 'VI-E-3 There is lack of involvement by Technical Functions in the conduct of the Training Program, particularly operator training. DISCUSSION Consistent with the creation of the functional GPUN organization is the concept of greater involvement in aB technical areas by Technical Functions. Because of the many problems being found in the training programs at TM1-1 and Oyster Creek, BETA assumed that there would be noticeable evidence of Technical Functions involvement with the corrective effort. BETA could detect very li,ttle, and it is not clear that there is at this time much interest in having any, either on the part of Technical Functions, the plants, or the Training Division. BETA considers this to be I a mistake, particularly with respect to operator training. BETA recognizes that at its present state of development with its limited capability, T/F is hardyressed to move into this area at this time. However, there should be ways T/F can become more involved in training than it is today. I i RECOMMENDA' MON Technical Functions should consider ways to take a more active interest in providing technical guidance to the training programs, especially operator trainirg. eoee T/F SYSTEMS ENGINEERING Nuclear Design Capability l ! FINDING VI-E-4 l GPUN's goal to achieve an in-house licensed nuclear design capability l , may not provide the anticipated advantages. DISCUSSION During the review of the Technical Functions Division, Nuclear Analysis and Fuels group, it was apparent that GPUN management Was aware of and ~ concu Ted in a projected change in directrofin the group's operation. The long term objective is to provide an in-house capability to perform nuclear calculations to support issues relating to licensed matters. Three advantages are given for providing this capability. The first was to reduce GPUN's dependence on core vendors, the second was that a better job would be done by GPUN, and the third was that it would save money. Other secondary advantages, such as flexibility, airo would result from this approach. 72

- -.w Based upon BETA's review, it is concluded that the proposed design capability upgrading would not provide GPUN with a complete independence from core vendors. The nuclear design calculations to be performed by GPUN would depend upon information and calculations performed by the e v.. ers who also must obtain NRC approval of their work. GPUN's design calculations would depend upon the use of: 1. Standard fuel assemblies or bundles available from the vendors. 2. The results of vendor analyses which specify the range of acceptable fuel performance parameters for these standard fuel assemblies or bundles. In addition to the above dependence on the core vendors, GPUN would also depend on the core vendors or other Ntside suppliers to perform certain licensing calculations to support the GPUN nuclear design group. An example ~ is loss of coolant calculations. These licensing calculations, which are t performed infrequently, would be, performed by consultants or the ecce vendors. As can be seen from the above, developing the planned in-house analytical capability will not provide a complete Independence from the core vendor or outside consultants. At the present time, with its existing manpower in the Oyster Creek group, Nuclear Analysis performs calculations to assure that the core vendors provide optimum reload configurations. This in-house optimization capabDity currently assures that BWR core reloads are indeed optimir.ed. There is no reason to believe that converting to a licensed analysis'would provide a more optimum core configuration than is currently obtained. To achieve an in-house licensed nuclear capabDity is difficult. While a few utilities have efforts underway to obtain such NRC authorization, as of mid-1982, only one was close to achieving this objective. It would appear that a nuclear engineering manpower levelof approximately fifteen engineers for each pkat would *we aquired to develop this capability and meet the l day-by-day plant support requirements. This represents a net manpower Increase of about five engineers per year per plant type to achieve this objective. Several years' (three or four) effort would be required. ' f l, The other stated advantage for developing an in-house licensed nuclear design capability is cost savings. It is understood that core vendors currently charge approximately $1.2 - $1.7 million for a licensed major core configuration design. Routine reload calculations cost approximateh 1 $500,000, whDe minor design modifications cost approximately $200,000. Present GPU in-house capability for Oystertreek is able to calculate routine reloads and minor design modifications. It is understood that these calculations currently satisfy NRC requirements for showing that minor loading changes meet license requirements. Based upon the estimated costs for service by core vendors and consultants and the GPU estimated manpcWer requirements to develop and maintain an in-house licensed ce? ability, it appears the cost to provide this in-house capability would be offset by the l savirgs that would result (this is a breakeven situation). 73

1. l In summary, the advantages resulting from the proposed GPUN action are not substantial in addition, there is a significant potential disadvantage that has not been addressed. in most cases the techniques that will be used i by GPUN are those that are being developed by EPR1. GPUN does not plan a to have an in-house method development espability. As long as oore i operations do not result in the discovery of new phenomenon, the EPAI 'I model should be satisfactory. It is anticipated that new phenomenon wD1 not occur if GPUN eentinues ( to use the current class of fuel assemblies which have been thoroughly proven t in operation. However, if GPUN anticipates they will want to use 9 state of the art" fuel assemblies, they should recognize that operational experience may raise issues. This would require use of performance models whleh are ~ not includm!in the EPRI estalogue. GPUN will be dependent on the des %ner for technical support. By GPUN actions to obtain independence they wD1 find it difficult to obtain this support when required. RECOMMENDATION Unless GPUN is willing to restrict its fuel selections to proven ~ technology and not attempt to incorporate advantages in performance natil they have been thoroughly tested in operation at other plants, BETA believes that there is no reason to develop an in-house licensed nuclear desgn If such a capability is not developed, a nuclear analysis staff capability. of nine engineers per reactor type should be adequate to handle GPUN's analytical fuel requirements. 1 1 T/F ENGINEERING PROJEC15 Task Assignments FINDING VI-P-1 l Engineering Projects personnel are performing tasks that could be better i i dune elsewhere in the Divisien, thus decreasing their capacity for the management of engineering projects. DISCUSSION Project engineers in the Oyster Creek Engineering Project are spending time making material lists from drawings in preparation for requisitioning material. This is a distraction from their primary function. The material I lists could be prepared more readily in the drafting room under the supervision of the Manager, Design and Drafting. Requisitioning..could be more effectively done either by Design and Drafting or Engineering and Design. These.latter organizations traditionally perform these functions in most The advantage would be that the Project. Engineer wouM be companies. l freed from f& a chores and could devote his time to the project management The above are aspect of hk work, which urgently needs greater attention. just two examples of the Oyster Creek Engineering Project engineers doing the work that should be done in Design and Drafting or Engineering and Design. We conclude that this is a holdover from the previous JCP&L Oyster Creek Generation Engineering practice, which in that environment, was ~ 74 ~

entirely proper and required. However, the previous Generation Engineering group is now an Engineering Project group. About one-half of the Oyster Creek projects are still in the okf Generation Engineering style. A multitude of ta'sks are being left undone in' the Oyster Creek Engineering Project, although the group is quite large relative to the TMI-l Engineering Projects Too many jobs exceed budget and too many fan to meet schedule. s. These phenomena usually come as a surprise and can be avoided l by closer tracking and guiding of costs and work in progress. b. Approximately 20% of the total GPUN budget is spent on Technical 1 Punettons originated contracts for engineering. That work,

r. won as the in-house work in Engineering and Design shouM be tracked closely by the Engineering Project to ensure costs are wort'.ny and Ij performance is satisfactory.

If a project engineer spent more time managing the cost, schedules, l c. and performance of an engineering task, he wouM not have to i devote the large amount of time now devoted to justifying or accounting for cost overruns and schedule delays. d. A modification to the plant is developed technically in Engineering and Design and the modification is taken up by Engineering Projects. Base Ene engineering is, on occasion, performed in Engineering Projects. It is' cur opinion that base Mne engineering wouM be performed better and more logically in Engineering and Design under technical supervision. This, again, wouM free up project engineer time for project management. RECOMMENDA'I10N I The functions currently being performed in the Engineering Project that detract from the project management capability of a project engineer should be eva uated and reassigned to strengthen the eff::tiveness of j Engineering Projects. eeee 9 l T/F ENGINEERING PROJECTS Training of Engineers PINDING VI-P-2 The training of project engineers is* weak. DISCUSSION Project engineers are not given training on how the Company is structured or how it is supposed to work. Thcre are too many who do not understand the organization. They fall in the category of "new to the l Company" or "still livirg in the oM days". 75

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Because of the impact that a project engineer can have on the proper control and management of a project, specifle training in the Company's methods and policies is essential -t ~ RECOMMENDATION Provide trainirg to Project Engineers in the Company's structure, methods and policies. ~- eeoe l T/F, ENGINEERING PROJECTS Cost Information FINDING VI-F-3 Project engineers do not receive adequate information concerning the progress, cost, and trends in progress and cost for the budget activities for i which they were the originating sodree of authority for the modification or the major O&M project. l I DISCUSSION A project engineer is the person at headquarters who is responsibis for the budget activities assigned to him. Ile, with assistance, of course, developed the initial budget and schedule and initiated the requisitions for, contraeted engineering servlees, long-lead material, and the work authorization to M&C. Having converted the job from an engineering concept to a cost incurring project, he must have feed 4ack on costs and progress l I of the work-not only to manage the project in Technical Functions, but i also to prepare himself for more effective work on subsequent jobs. The current reports are not adequate for the need. RECOMMENDATION Er.gineering Projects, Engineering Se* vices, M&C; the plants, and ' l Information Services should devise the reports that will permit having a running knowlege of cost and performance. To offset the cost of this ' work, this same group could easily determine a number of current reports i I which could be eliminated. eoee T/F STARTUP AND TEST FINDING VI-G A separate group at the Director level for Startup and Test is questionable. DISCUSSION There is no question that there need to be people who are assigned the responsibility for startup and test. BETA questions the need for creating 76

s ,3 a separate group at the Directar level and having 23 people assigned. At the site these needs can be filled by asignments within Plant Engineering. At headquarters they*Ean be filled by assignments in System Engineering. There should not be a need to have 23 people assigned fbil-time to this area. RECOhlMENDATIO_N_ Consider reamigning this group at headquarters into the System Engineering group. Assign the site people to Plant Engineering and reduos r the overau number of full-time people. As needs dictate, each of these groups can be augmented by engineers at the locations needed, eeee T/F CHEMISTRY FINDING VI-R Neither the chemistry group In Technical Functions nor the System Laboratory has assumed a leadership role in the TM1-1 or Oyster Creek I l chemistry improvement programs. DISCUSSION I Until recently, Oyster Creek and TMI-1 have lacked competent management of their ehemistry programs. Although the ehemistry deficieneles had been reasonably well identified, the plants did not recognize how to solve their key problems. Talented chemistry personnel capable of helping the plants solve their chemistry problems, including the management ones, have been available under Technical Functions Chemical Engineering and in the System Laboratory located at Reading, Pennsylvania. Although this Laboratory was not transferred to Technical Functions until April 1982, it was available under Nuclear Assurance previouah. Strong feelings were apparent against the other ehemistry groups among eenfor personnel at System Lt.1, oratory, Ch::m! cal Engineering, and the nuclear plants. Signs of jealousies, finger pointing, turf battles, and expressions of "that is not my job"have been all too evident. Although Chemical Engineering i ; and System Laboratory personnel feel they have provided great assistance to TMI-1, they have not provided what has been needed to solve the major chemistry problems at TMI-1 and Oyster Creek in a reasonable time. A chemist has recenth been hired from outside GPU as director over Chemical Engineering and System Laboratory. One of his first priorities is to resolve ,g the conDiets between these groups and between these groups and the plants. l-m f RECOMMENDATION l Resohtien of the conflicts among the chemistry groups could be simplified by removing Systcm Laboratory from GPUN. This would have the advantage of removing about thirty manyears per year of nonnuclear

i work from GPUN since about 90 per cent of the work of System Laboratory

'j k for fossil plants. Because this reorganization would make it harder in the short term to use the resources of System Laboratory, this change should l! 77 l .. - - -. ~ - - -

be viewed as a long term objective after the chemistry programs at'TMI-1 and Oyster Creek have been improved. The new T/F Chemistry Director has been directed to get activey f involved in all areas required to obtain the needed improvements in TMI-1 'A and Oyster Creek chemistry programs. BETA considers this broadening of assignments to T/F chemistry personnel should help resolve the previous problems. e 9 f e e 9 S l l e \\ 1 l W. 9 I l l 78 1 '3~'-. ~ l'

4. o h O q* 4 4l I CHAPTER VR ADMINISTRATION FINDINGS AND RECOMMENDNI10NS e i 1. e m

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1 l CHAPTER Vll. ADMINISTRATION FINDINGS AND RECOMMENDATIONS GENERAL -When GPUN was formed it was clear that there would have to be certain divisions such as the plants, technical functions, etc. It was also known that there would have to be a division to handle the administrative load of the corporation. What happened was that the Administration Division became the recipient of any function which did not clearly belong in one of the other divisions. This is irhy there ended up being so many diverse activities located within Administration. The fact that it " controlled" the money and the people immediately put this Division into a position of l perceived power. It was soon evident that it, as a Division, would have ( more GPUN people on the payron than any other division. These conditions lead to problems. l During the past year, BETA has been able to observe a needed l retrenchment in the breadth and scope of functions coming under ! k Administration. BETA has also recently seen a start in the reshaping of I the role Administration plays in carrying out corporate policy in contrast to l the role it appeared to be taking in the early phase of its development. These are healthy signs. The specific comments which foHow further expand on this theme. e. . ADMIN EFFEC'I1VENESS FINDING VH-A The Administration Division needs to improve its ability to provide a service function and to lessen the perception that it is a control function. DISCUSSION l l It is BETA's opinion that the Administration Division, with the number l : of functions it now performs, has become overly oriented towards attempting to control events rather than providing a service. This opinion is shared universally throughout GPUN. There is, and has been, an effort to correct t~ils situation within the Division. However, BETA feels that some fondamental changes are necessary before this problem will be resolved. ~ [. The original composition of the Administration Division included l handling essentially the foHowing functions:

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a. Fiscal Management i b. Material Management c. FacDities Management d, Contract Management e. Security f. Human Resources g. Information Management h. Other l l 79

.,j + I The Division was sot organized strictly along these Enes, but they were the major areas covered. They au provided a service of one kind or another to other divisions. Because of the nature of these services, they needed to be consistent across the divisions and, in some cases, such as in Fiscal Management, they needed to act as control functions in the name of the Office of the President. Policy is established by the Office of the President i and in many cases it is then the job of Administration to determine if it is being carried out. It should do this in a mode of cooperation and assistance to the other divisions rather than in the role of an adversary. It should be the goal of Administration to develop procedures and methods for carrying out corporate policy in such a way that it causes the least amount of disruption within the other divisions and without creating the impression that r. j these functions are an and unto themselves. i ~ For example, it is certainly corporate policy that costs wlB be controlled. There are certain requirements imposed on GPUN by the GPU l Service Corporation and others on. Just how this is to be done..However, I even within these constraints, Administration stb 1 has the freedom to create i a system within GPUN for controlling costs. In doing so, Administration can take the approach that it wDI develop a system that accomplishes the desired end but is so complex and onerous that the divisions either can't i' comprehend it or haven't the time or people to carry it out. On the other j1 hand Administration can approach the problem by, first, understanding the problems and capabilities of the other divisions and, then, seeing if they can c develop a system that is effective but not overpowering. l It is BETA's opinion that, at least for the first year or so Administration took the first approach. It created the impression that it was all powerful and imposed its will as it saw fit in the name of the Office of the President. A number of actions since then have eased this situation. For example, in October 1982, the Human Resources Department was transferred from Administration to the Office of the President with the Director, Human j-Resources reporting directly to the Executive Vice President. RECOMMENDATION g The Director, Administration and his leading people should continue I a. to redirect their efforts with the aim of providing an effective service to the other divisions. This. can be enhanced by Administration doing those things that the divisions can not do and by lettirg the divisions do what they are structured to do best. I The Administration Division should attempt change the impression that they and they alonf,. determine how,tocorporate po b. is to be carried out in administrative matters. I e. Adopt the motto, "We Serve the Plants". e 80-

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ee ADMIN MANAGEMENT SERVICES FINDING VH-B r The Manager of Management Services has a narrow scope of work assigned. DISCUSSION At the time of our review the Manager of Management Services was - res7onsible for the Policy and Procedures system and the Limit of Signature Authority procedure. He was also preparing a supervisor training course. Since the time of our interview, the Manager of Management Services at TMI-2 and the two people working for him have been assigned to the Manager i of Management Services. BETA notes that GPUN has undertaken to concentrate the support functions for TMI-2 in the TMI-2 site organization ~ and considers it would be logical to assign the TMI-2 Management Services g seetion to the Director, TMI-2, rather than have a Pars ppany manager responsible for three people at TMI-2 who are working exclusively in support of that site. Since the procedures ment'ioned above have been issued and implemented in GPUN, BETA considers the scope of work does not justify the position i " Manager of", nor the staff asigned. RECOMMENDATION Consider increasing the scope of work asigned to this senior manager or deleting the position. eeee ADMIN OPERATIONS ANALYSIS [ FINDING VH-C The efforts of the Operations Analysis (Ops Analysis) group within Administration are not effectively channeled. DISCUSSION . R; Having an Ops Analysis group within GPUN can provide the Office of the President with useful information that'~might not be readily available elsewhere. However, based on the review conducted by BETA, it does not agpear that very meaningful or even useful areas have been reviewed. It g is also our opinion that this situation wD1 not be improved if the Ops Analysis group is asked to come up with the items to be reviewed or to set the priority. Under normal circumstances, each manager should do his own operations analysis, and, if he is capable and honest about it, the most expert answer will emerge. If Ops Analysis is used in an " investigative" mode, then QA is usually the place to turn. Where an Ops Analysis group g t 81 = =

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[ can be used, and it should be used only by the Office of the President, is to look into areas that don't fan in either of the two previously deserbed. Based on BETA's review, the present Ops Analysis section is not being. used-properly. In fact, it is BETA's understanding that during the recent past, this group has been used to imphnt a cost control system within GPUN, a role completely outside the accepted function of such a group. r-l NECdMMENDA'110N The efforts of the Ops Analysis group within Administration should be directed by the Office of the President. l eeee i i ADMIN MATERIAIS MANAGEMENT Contracts l FINDING VH-D The cost reductions possible with more sophisticated contracting methods are not being achieved. DISCUSSION Our early experience and exposure to contracting at GPUN erested an initial feeling of concern. Essentially aH work was on a time and material basis, and insignificant effort on the part of the requisitioner was devoted to managing the contracted work. Comments on the role of the requisitioner are in Finding VI-P-1. j\\ The current assessment of Contracts Management was d9ne hte in our review period, and we found much has been done in Contracts Management to correct the early problems. Contracts Management now works closely with requisitioners and provides assistance, advice, training, and support in ,1 developing requisitions that can be converted to the best type of contract. Contracts Management has recently instituted a series of seminars for requisitioners, working with sman groups, and pkns to reach au prospective requisitioners. The seminars are to exphin GPUN contracting polley. l RECOMMENDATION a. Continue training of requisitione;3, Also, devise a scheme for measuring the success of this tra ning, e.g., how many requisitions must be returned for lack of compliance with instructed methods. b. Place greater emphasis on using Cost Plus Incentive Fee type i contracts. This will require having better scope of work definitions. I e. Consider establishing monthly progress reports from major contractors.in which work progress identified by task, and actual , costs to the contract, by task, are reported., Also"tonsider 82 l

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establishing quarterly reports from major contractors in which they forecast work progress and anticipated expenditures. 4 ADMIN SECURITY FINDING VH-E I There needs to be overall improvement in the Security Division in order to improve its efficiency. DISCUSSION In the security area, BETA contracted with an outside firm, Theodore Bany and Associates (TB&A), at the request of GPUN to amist BETA in its review. Two representatives of TB&A conducted a review at the two reactor sites and at headquarters. In addition, BETA independently reviewed a number of areas in the security area. These reviews indicate that whDe there are no serious problems whleh would contribute to high costs or poor effielency, there are a number of findings which indicate that security management is not aggressively pursuing an aerom-the4oard effort to improve its operation. The BETA findings whleh foBow are examples of these indicators and are derived from the TB&A review as web as the BETA i review. TB&A has prepared

t. detailed report of its findings and recommendations, a copy of which has been transmitted to GPUN management.

RECOMMENDATION I Refer to speelfic Findings that foBow. eeoe 6 ADMIN SECURITY Administration FINDING VH-E-1 l e Some security administrative fuoctions at TM1-1 and -2 can be combined to save manpower. ~ DISCUSSION m Cunently the security forces at TMid and -2 work jointly and share responsibilities in several areas. For example, Unit 1 operates the site* security computer system for both Unit I and Unit 2. At this time, both TMI-1 and -2 have accem control clerks and clerk l typists. The TM1-1 accem controlis computerized while the TMI-2 operations are manual The TMI-1 supervisor stated that the TMl-2 accem control workload could be handled by the TM1-1 elerk. 83

= RECOMMENDATION It is recommended that the TM1-1 accem control clerk handle the TMI-2 workload

• Changes to the administrative procedures can be made to accommodate this change and a savings of one clerk at a cost of j

approximately $20,000 per year. In addition, TMI-l's clerk typist should be W e-used to suppigt TMi-2 at a savings of an additional clerk. BETA has determined that such a joint effort is consistent with current practice at TMI, is not contrary to the separation of facility requirements in effect at the site, and would not constitute a mode of direct access between Unit 2 and Unit 1. I u 9 ! I i. \\ l I e M i 84

= O e eeoe ADMIN SECURITY TM1 Response Force FINDING VU-E-2 The Response Force capability at TMI-1 and TMI-2 can be considered to be 10 armed guards (each plant will support the other). Because outside support is readily available, a s:naller Response Force would meet NRC requirements. DISCUSSION I In several areas the security forces at TMI-1 and TMI-2 work jointly and share responsibility. For example, TMI-1 operates the site security computer system for both units. Also the entrance gate security responsibility b shared. This shared responsibility is accepted by NRC. In the event of an armed attack, both the TMI-1 and TMI-2 tif indicate they will go to the aid of the other group. The response force capability is 5 guards at g 1 each plant. NRC requires a site response force of from 5 to 10 guards, depending on the availability of outside help. In the case of the TM1 site, because of the offsite response capability, it is judged that NRC would consider acceptable a response force of less than 10 guards, for example, 6 to 8 guards. It is recognized that a reduction of response force requirements win not necesarily mean a one-for-one reduction in guard force manpower, however, TMI-l's security supervisor indicated that at least one guard position could be eliminated if the response force requirements were reduced. i RECOMMENDATION i GPUN should consider the combined response force capability at TM1 in meeting NRC requirements. A reduced total capability of 6 to 8 guards should be negotiated with NRC. Where possible, the guard force should be I reduced reflecting the above change. For each guard position canceled,4.5 l man-years of guard cost will be saved. BETA has determined in discussions with NRC and GPUN staff, that the proposed combined TM1 effort is i consistent with other TMI joint security efforts and is not contrary to the NRC requirements regarding separation of TMI-1 and TMI-2 facilities. In addition, this type of potential direct acces between Unit 2 and Unit 1 (emergency related) was specifically identified in GPU's statement regarding limited direct acces of Unit 2.to Unit 1. 'i o e S 85 . n

i eoee ADMIN SECURITY f,e TM1 Engineering Support ( FINDING VII-E-3 V l

• Inadequate engineering and construction support for the TMI-1 and TM1-2 security operations is resulting in the need to substitute guards for security hardware. Such substitutions are expensive.

DISCUSSION i The review disclosed, that because of minor engineering or construction scheduling problems, guards were being used in phee of installed (or to be installed) seculty hardware at TML Examples include: The use of a guard, 4 shifts, seven days a week, to observe the a. [ locked unalarmed gate separating the TMI-1 and -2 sections of the fuel handling bays (doors 73 and 74 in the environmental barrier). The barrier has been installed for over thirteen months, however, l the electrical work was not completed and the door alarms have f not been activated. Guards used in place of the alarms have oost over $100,000 during the past thirteen months. At the time of i this review, the installed door alarms were yet to be connected. Construction scheduling was identified as the cause for this delay. b. Doors 11 and 16 at TMI-2 have used guards to control acces since f the accident in 1979. 'Ihis has cost in exces of $100,000 per year. Prompt installation of properly monitored door alarms would have saved this expense. Once door alarms were installed, the alarms were not used due to a simple problem associated with the alarm display. During the period of this review this problem was resolved and the guards are no longer used at this location. RECOMMENDATION ~ Adequate engineering and construction support should be supplied a. for security operations. Priorities should addres the large costs asoelated with supplying manual backup to the security hardware. i b. Procedures should be' developed to require a periodic review of those cases where minor degradations in security system performance are compensated for stationing guards to assure that, l in some cumulative manner, these do not result,-in GPUN's not meeting its commitments to NROr-The alarms at fuel handlig bay doors 73 and 74 should be activated I c. and the manpower allocated to the TM1-1 guard force should be reduced by 4.5 manyears. 2 d. The manpower allocated to the TMI-2 guard force should be reduced by 4.5 manyears to reflect the activation of the alarms at doors i 11 and 18. i 86 l -- -

l eeee ADMIN SECURITY TMI-2 Protected' Area I FINDING VH-E-4 l The TMI-2 entrance to the protected area uses a temporary building and manual search to control entry of personnel. His faellity and its operation is inefficient in the use of guard manpower. DISCUSSION During this review it was noted that the protected area entrance at TMI-2 had a larger number of guards than TMI-1. This is a result of the lack of metal detectors, hence, the requirem,ent for manual search and of the sman and inefficiently laid out building. TMI-l's processing center l operates with a significantly smauer staff. RECOMMENDATION If funds can be made available, the TMI-2 processing center should be-upgraded. Temporary structures can be used but sufficient space should be provided to aDow effielent operation. In addition, metal monitors and i explosive monitors should be provided. it is estimated that the annual savings In guard salary will eventuaDy offset the cost to upgrade the facility. l eoee ADMIN SECURITY TM1 Alarm System FINDING VH-E-5 1 The protected area perimeter alarm system at TM1 has an excesive number of alarms. DISCUSSION During this review it was noted that the perimeter alarm system at TMI has an excessive number of alarms. His is a result of false alarms and, in addition, results from the pasage of workers and guards through the monitored areas. It is anticipated that this level of performance wiB not meet. future NRC requirements. It is u.lerstood that GPUN is evaluating f and upgrading the alarm system. l RECOMMENDATION l The perimeter alarm system should be upgraded to produce a system with a minimum number of false alarms. e 87 r ...= . =. -

eeee ADMIN SECURITY' Manpower FINDING VII-E-6 Manpower requirements fluctuate as a result of training requirements, special security assignments and multi-shift operations. Extensive overtime .i( is required to support this fluctuating workload. DISCUSSION l There may be cost reduction potential in changing tour durations and reconfiguring shifts. Due to the high number of craft wotters at aB sites, there is a peak security manpower need during shift changes. It may be possible to provide security shift configurations which cover these peak periods while not retaining exces manpower beyond the actual need. For example, revolving four 10-hour days could be used to provide a two-hour overlap in the morning and evening to facilitate ingress and egress proceming of high numbers of outage craft. l RECOMMENDA'I10N i Review the current structure to determine when additional staff are i needed to handle peak security requirements. Examine alternative shift scenarios and tour configurations in an effort to reduce the overau manpower requirement and use of overtime. eeee ADMIN _ SECURITY ( Unnecessary Guard Protection FINDING VB-E-7 l Guard protection is being provided to areas that may not require the protection or warrant the expense. i DISCUSSION The foBowing examples may indicate that the cost effectivenes of current guard coverage has not been assessed: Evening guard protection is provided for the TMF1' raining / Visitors o Center. Coverage could be accomplished bfinstalling a local security alarm (or usirg a leasedline to the Central Alarm Station) and utilizing random phk o Guard coverage is provided at Forked River. If possible, valuable l materials that could be subject to pilferage should be liquidated or stored l at other facilities. 88

_.. =. 1 ~ The TMI south gate needs to be covered by security guards only o during th'a peak shift-change hours. Currently, the south. gate serves predominately TMI-2 contractors. At the current eraft manpower levels, the south gate acces point could be closed except for peak ingress and egress times (approximately 0600-0800 and 1430-1630). The north gate can accoriiimodate the additional trafffic from the south gate at nonpeak hours. RECOMMENDAT10N The above security considerations should be evaluated for cost j effectiveness. It is estimated that these changes would save 8.5 to 9 l manyears of effort. 9 I i ADMIN SECURITY Contractor Support FINDING VD-E-8 GPUN has not received adequate support from Vikonics in correcting keycard acces system defic!encies. l DISCUSSION l The card acces system has been plagued by hardware and software problems for several years, Ykonics, the turnkey supplier of hardware, software and instaDation, has failed to provide adequate support towards correcting system deficiencies. The problem has been exacerbated by the fact that GPUN has not dedicated someone with a strong computer background 1 specifically to support the system and to act as a liaison with Ykonles. GPUN has recenty threatened citing nonperformance and withholding the f performance bond retained against Ykonics in an effort to force Vkonles l to correct deficiencies. RECOMfuiNDATION GPUN should consider having an engineering evaluation made (either by GPUN, GPUSC, or contractor personne ) of this problem. His engineer should evaluate the proposed Vikonics' corrective action. This evaluation should include inputs from the other utilities using Vikonics' equipment. His evaluation should consider the effectivenes of the system as is, and the 1kelihood Vkonies will correct the existing deficieneles. Based upon this ig review a plan of action should be identified which includes both engineering and legal alternatives. i. e 89

) eoe. ADMIN SECURITY Position of Lieutenant FINDING VIl-E-9 Approval has been requested to reorganize the security force to establish a Lieutenant position at each site. DISCUSSION It is understood that in order to provide additional administrative support and advancement opportunities, action is underway to establish a Lieutenant position at each site. I RECOMMENDADON q If it is decided to provide.this new position, the total number of / managers in Security should not be increased. eoee i l ADMIN SECURITY Overtime FINDING Vll-E-10 The security operations require extensive overtime. DISCUSSION Current security operations at the three sites require the use of approximately 18 man-years of overtime. Considering the premium costs associated with thk overtime, it represents a significant fraction of the cost of guards and should be includsd in establishing manpower levels. For example, the current onboard staffing of the Security Department l at Oyster Creek is 62. However, the current overtime usage raises this number to the equivalent of 72 man-years. The end of year 1982 authorized level is 54. It appears that this number does not refleet the use of overtime i and, unless it is controDed, the possibility exists that overtime will be increased to offset the reduction of personnel For TMI-1 the onboard g staffing is 54, with overtime, the staffing is the equivalent of 57.5 man-Agal,n it would appear years. The end of year 1982 authorized level is 50. 3~ that this number does not reflect the usejf overtime. RECOMMENDAMON o Manpower assessments in the security area should include consideration of the overtime usage. I 1 90 h-

o Based on comments in this and other findings in this section, the recommended staffing levels, including the use of overtime, are as follows: f Manyears Effort - Oyster Creek 82.0 TMI-1 43 4 l I I \\ I i fir. 1 / O e 91 .O*e es

l eoee ADMIN SAFETY AND' HEALTH Need for Doctor FINDING VII-F GPUN has no employee who is a medical doctor at headquarters or TMI-1 or Oyster Creek to oversee medical aspects of the GPUN radiological health program. Part time contract physicians and a contractor are used for these functions. DISCUSSION In addition to conducting physical examinations, physicians are needed for several radiological health functions, including treatirg injuries involving radiation or radioactivity, advising workers and the company on radiation t workers who have unusual conditions, assistirg in radiation injury ekims, and ensuring medical records will support future needs regarding radiation injury chims. ' Part-time contract physicians have, been conducting physleal examinations at TMI-1 and Oyster Creek but they have not been trained for these other functions. There have been examples where these other functions have not been performed well. These other functions require a degree of expertise and sensitivity and trainirg that is unlikeh to be obtained n part-time contract personnel t- [ BETA considers a company physician to be an important part of a radiation chims prevention program. The value of such a person has been demonstrated in past BETA experience to outweigh the difficulties in obtaining, training, and retaining a physician interested in occupational medicine. The position does not call for a nationally recognized radiation medicine expert; such people are available as consultants when needed and the limited work requiring such an expert at GPUN would not keep him challenged as a fuB-time employee. In past BETA experience the benefits to the radiation claims prevention program have been achieved by obtaining a physician trained in occupational medicine and providing him extra training in radiation. Ensuring close ties with the radiological control organization has also been esential The need for a GPUN employee to perform this work is partleularly important for TM1 Unit Two because of the increased amounts of radioactivity and radiation and the unusual nature of the work compared to other licensed power reactors. The potential for radiation injury claims is greater at Three Mile Island than elsewhere. l n Salaries are high for occupational nfedicine physicians and they are hard to find. However, some of the also high costs of contract physicians I,, could be saved. OveraB, costs would probably not decrease, but they should not increase much if one company physician were hired. There is a large l l potential cost saving in radiation injury claims that is much greater than the salary of such an employee. It is possible to obtain most of the benefits of having a physician l employed by GPUN without having one for each nuclear plant. The physician i I 92 L

...... =- l 1 could be located at Three Mile Island and spend about one day per week at Oyster Creek. ~ RECO.MMENDATION GPUN should consider employing a physlelan at Three Mile Island and assigning him medical radiological health responsibilities for TMI-1, TMI-2, [ and Oyster Creek. 1. l I 4 i l i O ~ i I g[ am l 9 b 93

e o e U e e -e e CHAPTER M 1 k HUMAN RESOURCES FINDINGS AND RECOMMENDNI10NS 1 o l f* 1 e l i. I 8 9"U 0 e i i l e i ..e...o. .c. Q2 _=;.=--.o--o o-. -9 q

l l HUMAN RESOURCES tompleting Personnel Actions I FINDING VID-1 There is a need to reduce the time it takes to complete a personnel setion. DISCUSSION For a number of reasons some personnel actions take too long to be completed. Without arguing the merits of any given case, examples of personnel actions inyolving hiring, termination, pay status, benefits, transfers, etc., were noted to take months to complete. Reasons ranged from their being too many approvals / concurrences required, to too much paper work required, to the need for " committee" action, to just having a paper sit on someone's desk for several weeks awaiting action. Not only does this create a bad impression of Human Resources, but, more importantly, it has resulted in the feeling down within the organization,,that top management is insensitive to the. gut issues that affect an individual's personal weR-being. BETA was informed by a number of people that contrbuting to the I Inability to move quickly on personnel matters is the existence of a number of high-level corporate committees, such as the Presidents' Committee and the Personnel Practices Committee, that seem to get involved in too many issues that should be handled routinely. If this is true, it is another example where decision-making within GPUN has been elevated to the paint that it takes inordinate time to get a decision, and just as important, people at the lower levels automaticaDy push the decision upward to avoid future i reversal RECOMMENDATION All levels of management need to understand better the need to take quick action on any matter affecting personnel--either good or bad. Human Resources needs to bring to the attention of management any instances where there h a needless delay in taking a given personnel action. This means Human Resources needs to be able to keep track of the status of pending personnel actions, eoee w HUMAN RESOURCES Position Titles vs Salary ~ i . FINDING VIB-2 The number of GPUN personnel who have the title of " Manager" or above, is high in comparison to the total number of GPUN employeer. 94

DISCUSSION There are four levels of management who have titles of " Managers" or above. These positions include: N' i. 3 Director of 2. Director 3. Manager of _ r 4. _ Manager Within the GPUN organization of 2589 employees, there are 244 who are " Managers" or above. This does not include supervisom or foremen. j BETA considers this to be greater than necesary. It has been stated that each of these positions was created based on a review of the function to be performed and the level of responsibility involved. Assuming this to be true, it would appear that the " Manager" criteria level may have been set I too low. It is also possible that GPUN has used grade level as a means to obtain competitive salary levels for key personnel, and generally grade levels s are tied to positions. .There is no question that GPUN must provide competitive salaries for its personnel In the lower grades, this is relatively I In the higher levels, position descriptions and titles must match the easy. grade level in order to justify salary levels. While there is nothing wrong with this arrangement in the basic structure of the organization, if it is used ~ in exces it will result in there being too many managers.' It is surmised that when the position descriptions were initially written g-and reviewed, there existed a lack of detailed knowledge of just what the [ This is understandable because of the newnes of the job entailed. organization. Based on this limited knowledge, a grade level was established x l. high enough to cover what was then considered to be the mppar_ Umh" of the job. Since then, there has been sufficient time to better understand i. the job and to judge the performance of the individual filling the position. It is BETA's opinion that if those top positions were evaluated today, there {~ ~ would be les managers. i Another bad feature of grade level inflation..ls.the. perception of competition between Divisions. Division Directors, Managers, and the workers within the Division tended to use the number of " managers" within each Division as a measure of importance. Throughout the BETA interviews, it was evident that great importance was placed on how high a position was We set, particularly when an issue had to be settled between Divisions. heard of cases where a " manager" would not return a phone call when that call was made by someone in another Division, but at a lower level Also, as discused elsewhere in this report, there is, the creation of " cells". In a large measure, this is the respl3.of having too many " managers". Once a person is hired into or elevated to a " manager" position, he tends to want to prove that he really is a manager. Tasks that he would normally g perform himself, become chores that are beneath the dignity of his position. As a result, he surrounds himself with a staff. In some cases, noted within GPUN, these staffs or " cells" developed through subterfbge. The "mausger" could not openly proclaim he needed a staff so he got an " engineer" or an " analyst". These people, in reality, were asigned administrative tasks, such as bugsting, personnel, etc. 95

~.... .......~o. I l i The following table shows the distrbution of " managers" in September NUMBERS OF MANAGERS AND DIRECTORS r t. BY LOCA'110N DIVISION PARSIPPANY TMI O/C READING TOTAIA OP 3 3 O/C 20 20 TMI-1 9 g TM1-2 31 21 T/F 35 3 3 3 44 N/A 22 9 8 3 41 ADM 40 7 55 COM 2 8 1 3 RC&E 4 12 8 32 M&C 8 5 7 30 TOTALS 114 73 52 5 344 RECOMMENDA'110N An evaluation of the top managerial positions should be conducted to [ determine if the work performed matches the grade level. l eoee HUMAN RESOURCES Labor Relations FINDING V111-3 Productivity at the nuclear plant sites is adversely affected by current bargaining unit agreements. DISCUSSION The BETA review indicates that operation under the eutven't barbaining ~ unit agreements at both sites is adversely affecting productivity. is k not to say that it is the only contributor. However, there were ample examples of current practices that indleate a need for GPUN or GPU to review its agreements with the bargaining u BETA did'not make such a review for a number of reasons, one being"g[ts. that to do so, would have been t too time-consuming since the subject matter is so vast and complex. BETA I is aware that this matter is under constant review by GPU management, not only for the nuclear plants but also for the other plants within, the system. BETA has included thk item in its findings because it is having a snarked impact on work effielency. If there are truly situations, as were reported to BETA, where a workmen is at his worksite for only two hours out of an eight hour day, then there is a problem. If part of that problem is a result of the bargaining unit agreement, then it shou 1d be resolved. i ,l 96

l l RECOMMENDATION In this case BETA can' only recommend that appropriate tmt knowledgeable people within GPU (or GPUN) conduct their own review of ..[' the situation existing at TMI-1 and Oyster Creek to determine if, and to l what extent, current union agreements are impacting work efficiency. 11 P- 'O Y I L I I i I M 6, d G 97~

seme W Su m + 0 b u J. n. e I CHAPTER II S RADIOLOGICAL AND ENVIRONMENTAL CONTROLS l FINDINGS AND RECOMMENDATIONS O 9 I t o' I e

l l l CHAPTER IX. RADIOLOGICAL AND ENVIRONMENTAL CONTROLS FINDINGS AND RECOMMENDATIONS GENERAL - The present structure of the Radio leal and Environmental Controls [- Div' silon (R&EC) is considerably different from that existing prior to the I: 3 TMl-2 accident. BETA has been more closely involved with amisting GPUN in developing R&EC than any other division. It has been in a position to observe firsthand the many problems encountered in converting what existed in 1979 into the present day organization that can adequateh handle the radiological effort at TMI-1 and Oyster Creek. In October 1979, when BETA arrived at TMI, radiologleal controls and chemistry for both units one and two were performed by the same technicians. This combined group had two health physicists with degrees in senior positions. Important early changes that were succesfuBy made were separation of the site chemistry function ahd removal of production functions, such as radioactive waste and decontamination, from the site radiologleal controls group. GPU took early action to separate TM1-1 from TM1-2 radiological controls except for a few common functions such as dosimetry. At Oyster Creek the radiological control situation had many similarities to TMI-1, except that chemistry was not combined with radiological controls. Starting in 1980, Oyster Creek foBowed the changes that were being made at TML The managers of radiological controls for each of the three plants were organized reporting directly to a new ecaporate director of radiological controls. More than a dozen manager level leaders were developed in the three radiological control organizations under the Director R&EC. Among other things this has allowed R&EC to gain better control of its contractors such that contractor radiological control personnel are difficult to distinguish from GPUN radiological control personnel at the plants. Changing the 8-radiologleal ecntrol group from the plant organization to R&EC has contributed to improving radiological control performance, partly because the new organizatica tcmvides better radiological eontro1 balance in operations l and maintenaner RadNice.at v.vineering groups have been developed withis R&EC at each plant tie ir c departure from traditicaal practice in other utilities and it is wo: king effectively. A radiological amessor at each site has also been developed who operates independently from the site radiological control organizations. Standardization of radiological procedures at.the three plants is being pushed. Major eary efforts were aimed at improving the training and qualification of radiological control techielans, improving the radiologleal training of workers, cleaning up contaminated areas and reducing the numbers of such areas, and improving the control of radioactive contaminatlion. One area not discusred in the earlier sections on radiological control effectivenes at TMI-1 and Oyster Creek is labor relations. It is BETA's 98

l n opinion that the current methods and procedures used with. the bargaining units interfere unduly with the nee (I ta obtain high quality radiological control performance. This report contains a separate item relating to labor relations; however, it is mentioned here with specific reference to the ineffielencies and other problems it has created in performing radioactive work. in summary, GPUN headquarters has set up strong central control of k. radiological programs with detailed technical knowledge of current plant This has been performed with a minimum staff at headquarters problems. and without setting up a layer of management between the plant radiological control managers and the Director, R&EC. BETA considers that R&EC has made considerable progress in creating an effective radiological control program at TMI-1 and Oyster Creek. It is on the right track and merits the continued strong support it has received from corporate management. Specific comments relating to areas where effectiveness can be improved are provided in earlier sections in this report (Chapters IH and IV). { 5 eeee R&EC RADIOLOGICAL ENGINEERING [ FINDING IX-A Little radiological engineering is performed at Parsippany. DISCUSSION [ Radiological engineering is needed in technical work for nuclear plants to help ensure consideration of radiation and tedioactivity in design and planning. For work on radioactive systems and nearby nonradioactive systems, r special attention is needed to radiation exposure of those who will perform the work and to control of radioactive airborne and surface contamination. These considerations nearly always lead to differences in the design and planning from the way the same job would be handled in a nonnuclear situation. Sometimes the differences are major. These radiological considerations do not require esoteric skills beycind I the competence of normal mechanical and electrical engineers. In fact, in i a mature, web-trained nuclear power engineering organization, each engineer would be his own radiological engineer. If radiological ergineering is not done properly from the earliest stages of planning and desgn, then design work may have to be redone at increased cost. Or worse, for its impact on cost and time, design work may have to be redone at the plant. I Iven in the ideal situation where each engineer does his own radiological engineering, a small radiological engineerpg group is Meded to ensure standardization, to develop new concepts ror special jobs, to keep up with new developments elsewhere, to help train the nuclear power engineers, and to ensure coordination with radiological control personnel. To summarize, in a well-trained nuclear power engineering organization, a separate small radiological engineering group will increase efficiency and productivity and reduce overall costs. e 1 9_9

~ The existing situation in Parsippany is far from this ideal. The bulk of the engineers are new to their jobs. They have not had training in radiological engineering. They are not familiar with the best ways to perform radioactive work in an old nuclear plant. Their supervisors similarly do not have enough experience,to make up for the radiological shortcomings of g~ l their (ngineers. In this situation, a strong radiological engineering group in Parsippany is esential i In the Technical Functions Division there are no radiological engineers performing the functions discussed above. ' There is one engineer assigned the title radiological engineer, but he does analytleal work such as shielding calqulations and effluent release calculations. In the Radiological and Environmental Controls Division at Parsippany there is one radiologleal engineer, but he does not perform the functions listed above. As a result, the radiological engineering group at the plant l 1s relied upon to provide the input that shouM be available at headquarters much earlier in the design phase. It is too late to add radiological considerations after a design package has been delivered to the plant. I RECOMMENDA'I10N Cwelop a small radiological engineering group in Parsippany located in the Radiological and Environmental Controls Division to handle radiological engineering for headquarters divisions. This group should not perform the analytical work on radiation shieMing and effluent release which is already, properly located in the Technical Functions Division. eeoe I i R&EC. ENVIRONMENTAL MONITORING FINDING IX-B GPUN is spending more than it should in dollars and manpower for environmental monitoring at TMI-1 and Oyster Creek. DISCUSSION Environmental monitoring for TMI-1 and Oyster Creek costs approximately $3 million each year, of which more than half is for contractors. Public presures have been forcing increases in environmental monitoring for nuclear plants. A major cause of such national interest has been concern for radioactivity. This is particularly applicable to TM1-1. Radiological environmental monitoring might therefore be Axpected to be a 1 large part of the cost of the environmental monitoring program. In fact, however, other environmental monitoring has been increased so much that I I the costs for the extensive radiological environmental monitoring programs ~ ~ at TMI-1 and Oyster Creek are only a sman fraction of the total costs. RECOMMENDATION BETA considers this an appropriate time to begin reducing unnecesary environmental monitoring. BETA does not recommend reducing radiologi.e#,, 100 = =

I environmental monitoring. The Director of Radiological and Environmental Controls should be asigned the objective of making initial reductions in environmental monitoring early in 1983 and further reductions by 1984. ~~ ..s ~ e' h+ e P e W um [ 9

• e e

G e e e a e 101 A. m

l e e e e e O W-I r k. CHAPTER X l h.. e MAINTENANCE AND CONSTRUCHON [ FINDINGS AND RECOMMENDATIONS '6 [ d a \\ 9 8 e O l~ W. i e 6 9

CH APTER X. M AINTENANCE AND CONSTRUCTION FINDINGS AND RECOMMENDATIONS GENERAL s 5 the earliest concept of the GPU Nuclear Corporation, long before its offielal creation as a corporate entity, the Maintenance and Construction Division was included. Although the creative planning being done at that time made clear the need for such a Division, the planning was reinforced by 'NRC orders, the Kemeny Report,' and the President's response to the Kemeny Report, as indicated by the following excerpts: NRC Order of August 9,1979, Docket No. 50-289 "6. The licensee shan demonstrate his... espability of important support organizations such as... Maintenanee." The Kemeny Report "A.5.(e) Responsibility and accountability for safe power phnt i operations... should be pheed on the licensee in all circumstances l ... with particular attention to... Maintenanee." The President's Response dated December 7,

1979, to the

~ Recommendations of the Kemeny Commission page 7 ' Primary responsibility for safety must rest with the utility companies that... maintain nuclear power plants." NRC Order C12-80-5 dated March 8,1980 ... the Licensing Board should examine... the adequacy of the faellity's maintenance program." On September 15, 1980, the GPUN Group was formed. The M&C Division was established and continues today in the GPUN Corporation. From that date to the present, the effort has persisted in readying the Division for the assumption of responsibility for aR modification and corrective maintenance work at both sites The transfer of the corrective maintenance function from the plant to M&C is currenty in process at Oyster Creek, having commenced in October 1982 and is planned for TMi-1 L-after the restart of that plant. BETA has observed closely during the formation of M&C from the date the Vice President-Director, M&C reported in June 1980 as the Vice President ? designate, and BETA agrees with the intent, method, and scope of the new organization. It is anticipated that when the organization is fully in place and functioning as planned that the material condition of the plants win be improved and that the performance of au maintenance and modification work will be better controDed as regards procedure compliance, schedule, and cost. i 102 O

As previously noted, the transfer of phnt maintenance work to the M&C Division has commenced at Oyster Creek. In condnetion with the finding listed below, attention is directed to the finding contained in the Oyster Creek section of this report which discuses a number of problems observed in the maintenance area at Oyster Creek as this transition occurs. g b Since, during the time of the BETA review, the main effort of the M&C Division has been one of getting itself in a position to assume its new role, there is little that can be commented on with respect to work accomplishment. BETA did spend time reviewing the phns, goals and procedures being devised for ' operating the new division. Because of the unique nature of the working relationships which need to be established and their departure from past practices, it is expected that a number of problems will develop. It is not BETA's purpose to list these problems because they will be resolved as the transfer proceeds, flowever, managers and directors in all affected divisions need to: 1. Understand that the Meision to transfer plant maintenance to the M&C Division has been made-it is no longer a debate. 2. Put whatever disagreement they raay have felt regarding this change in the past and they now need to support it. 3. IIelp resolve the issues arising as a result of divisional interface uncertainties. BETA is confident that these problems wD1 be worked out and that this new concept of performing maintenance work at the plant win result in a better maintained plant and a greater efficiency in doing so. eoee r M&C FINDING X-A The Maintenance and Construction Division in its effort to become established is not capitalizing on the capabilities throughout the Corporation's functional organization. ~ DISCUSSION It is BETA's opinion that in establishing the functions, asignments and .k responsibilities of the M&C Division, particularh in its early stages, there has resulted an overshift into M&C of a number of functions that should be retained by other divisions. It is understandEble how this came about, nameh j the need to create a new effective system &lves a new organization into assuming more of the roles. In theory, the M&C organization with a1 of its various functions looks good on paper. Ilowever, it is not likely to succeed unlem reliance is placed on other divisions within the corporation to carry out their htles. M&C should not overdo the philosophy that a function win not be done properly unless it is done tg M&C. 103

There are a number of examples of this. Within the site M&C organization there is a group called Technical Support. Care must be taken that this group does not take over the function of Plant Engineeririg or Technical Funetions. In addition, eare needs to be taken that this group does not duplicate the work of others or does not become another approval i point in series with getting the work done. This name situation is tending I to exist in such areas as: contract administration, warehousing and welding g. engineering. There may be others. 4 RECOMMENDA'!10N The Vice President, M&C should review his organizational plans and procedures to ensure that wherever a function already exists with GPUN, that function should be used to the fullest and not duplicated within M&C just because it is not supportive. If it is nonsupportive, action needs to be , taken with the appropriate division director to correct the situation. l 1 l i L p l .ir. 6 - l 104

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l [ COMMUNICATIONS Staffing i FINDING XI f.' _The number of people asigned to this function appears excesive. F f DISCUSSION BETA fully understands and supports the need for GPUN to have an effective Communications Division. The unique nature of circumstances servounding TMI dictate the need for GPUN to have a group dedicated to this purpose and also the need for this group to be larger than in any other i I nuclear utility. However, we do feel that having 36 people to perform these tasks is excessive. A few times throughout the period of the BETA review, I there were opportunities to observe the day-to-day functioning of this group d at TMI. Based on these isolated cases it is BETA's opinion that a number' of the people are ' under-utilized, lack supervision and are sometimes performing questionable tasks. 'Ihis is undoubtedly caused by the fluctuating need for their services and the desire to have people available when the i need arises. BETA does fe=1 that it is appropriate at this time to review - I the manning of this group to determine if all the people are really necesary. RECOMMENDA'!10N a. A review should be conducted of the anticipated work load of this I Division to determine if it is properh manned. b. Consideration should be given to finding useful tasks in other i. Divisions for people in this Division when they are not needed for

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thdir primary jobs. s c. More effective supervision should be provided, particularly at TML I 3 t 105 -.r . - --. 7. 3., - - --...;. __

u f. =-. et_ - U GENERAL FINDINGS AND RECOMMENDA110NS L I e O e WW I e I e 9 hi.. -mi ..i---

GENERAL Supervision t FINDING X11-A Insufficient or poor supervision is contributing to poor productivity. DISCUSSION Probably the most effective measures G' PUN enn take to improve productivity throughout its organization is to improve supervision. During the time BETA conducted its review at the three sites, numerous observations were made where people were not productivly employed. Dere are a number l-of reasons why situations such as this develop. In order fo a worker to be productive he or she needs all the elements necessary to do the job.. The absence of any one of them will cause the work to stop. Many of these elements are discussed elsewhere in this report. he purpose of this item is to discuss supervision or the lack of it. 1 In its observations, BETA noted too many cases where poor productivity could be directly attrbuted to either insufficient or improper rupervision. l' Even though the more flagrant cases occurred at Oyster Creek, the same situations were noted at the other two locations. While BETA could provide a list of specific examples noted, it is felt that most of senior GPUN I management is already aware of similar examples from their own l observations. What needs to be recognized is that this problem exists to ~ varying degrees at all levels in all divisions and is not restricted to the man with a bag of tools. BETA recognizeis that merely recommending an improvement in supervision provides little if any help in solving the problem. What follows is i a list of possible contributing causes as surmised by BETA along with some suggestions as to how they might be relieved. This list is not in any. order of priority or importance. a. Greater than normal rates of increases in manpower such as have occurred at GPUN, generally result in a drop in the quality of supervision. This is brought about by several factors. People are promoted into supervisory roles at a faster rate than the organization can assimilate them. Also, managers will tend to hire new people more for their specific capability to do a given job and less for their supervisory capabilities, partleularly when there is pressure on to build up an organizatiordn a short period of time. Rapid hiring contributes 4o reduced supervisory capability ~ I In another way. New people are generally hired because the work load has increased. As the new people are brought onboard there is a period of time when their ability to do the work is very low. This means that the senior experienced people spend most of their time doing the work that they hired the new people to do, and the result is that no time is left for these senior experienced people to train the new hires, particularly in matters of supervision. 106

e 8 b. Looseness of supervision tends to become a way of life and as ' time goes by, it becomes embedded and is very difficult to change. i Quality supervision tends to atrophy with time and needs to be I constantly reinforced. BETA too often heard the expression," things win never change, they have been that way too long". 1 Too often people are made supervisors who, if the truth were t. known, really do not want to be supervisors. Some people have ~ an inherent distaste for being a boss. Others have grown g in a community of peers, having been close personal friends with them for years and are unwilling to alienate those relationships even u though they may take the job when offered. d. Senior managers tend to look no further than one level down in their own organization when it comes to supervisory attention. e. Senior managers, including Division Directors, are particularly - reluctant to flag poor supervision on the spot, when it occurs in another Division. f. Some senior people truly believe that all that is necessary to solve the problem of poor supervision is for the Training and Education Department to have an effective supervisor training course. If it L isn't working it's because the training course was no good. This becomes a convenient erutch because now all the managers need to do is make sure their people are scheduled to take the course. I-Incidentally, BETA strongly supports the need for having a weH-taught supervisor training course, as long as it does not become the sole means to an end. BETA also feels that the current tiend I to turn supervisor training courses into psychologleal exercises is ~ 7 wrong. g g. Too many senior managers want to create the impression that they / are good guys", and that their people " love" them. They have not learned that there is a difference between being tough and being saean. People win respect a persen who is tough, but fair, and one who knows his business. t l h. Supervisors and managers have a better chance of success when their personal appearance refleets their elevated positions. This applies to dress, grooming, demeanor and any other attribute that tends to create an image. In the same light, what a person does outside of working hours should generaDy be of no concern to the l company unless that behavior becomes grossly offensive and ends up hampering his ability to supervise. L Obtaining effective supervision starts at the top. If top I management does not set the tone and constantly reinforce it, it ~ will slacken as it moves down into the organization. J. Some senior people assume that when a person is promoted to a higher position, he or she automaticaHy becomes qualified, in a managerial sense, to perform in that position. This is rarely true. ll 107 = 59.. - ~. o .e- ._.m .m.

k. Poor supervision will result in a company where the falkre to meet schedules or commitments has become a normal every(day routine. Employees soon develop an attitude that, "if they the i bosses) don't care if it gets done on time, why should It" ka i larger but different sense, the constant inability to get TM1-1 g ~* . restarted contrbutes to this. Y E L There is a reluctance for GPUN managers / supervisors to flag poor supervision on the part of contractors. There k the perception that for contractural reasons, GPUN people are not permitted to 1-move into' this area. ~

m. There is the erroneous perception (more an excuse) that union agreements have tied the hands of the supervisora, n.

Supervisors do not spend enough time at the work sites. Thk could be for a number of reasons: they have too much desk w'ork; they attend too many meetings; they are running around chasing problems holding up their work; they just don't want to. o. Supervisors are not sensitive to, and are not reacting to, poor working conditions at the work sites, such as, too many jobs going on in the same area, cleanlines, etc. p. Supervisors too often rely on outsiders (QC, Radeon, etc.) to ensure quality of the work rather than themselves. q. Supervisors, on occasion, blame others for inability to get the work done but seldom do no more to correct the situation than complain { to their own workers. RECOMMENDATION (not in order of importance or priority) s. Most of the causes given above relate to a lack of proper training of supervisory personnel and to a lack of awarenes on the part. of senla managers that the supervisors are not propwly trained. The first step in improving this situation must start in the Office I of the President. That office must set the tone, not by preaching, but by visible signs that they are concerned, including calling to the attention of individual division directors, noted examples of poor swervision, b. A review should be made of the current supervisor training course l\\ to ensure it is providing the material and is being taught by people who are qualified to teach it. Evaluation of ths.affectivenes of these courses should not be performed,by the Training Department. ~ I Management should recognize that 90% of effective supervision a. ~ trainig k on-the-job. 'Ihis means that managers, etc., must constanth be in the proces of teaching their people how to supervise and correctig their mistakes. Thh assumes that management is capable. 108 m

>i d. Directors (aB divisions) need to tour their work areas at irregular and unannounced times with the express purpose of seeing that their people are gainfuny employed, and if they aren't, why. When 'T eases of inactivity or laxness are noted, these directors need to raise the issue'with the appropriate managers. [ [ 1 's. Senior managers need to improve their use of GPUN performance evaluation system's provisions relating to supervisory performance. At the present time this tends to be perfunctory because of a lack of realistic knowledge of the person's performance in this area. s ). The rapid rate of hiring has subsided and there should be evidence of better supervisory performance. As the new people learn their Jobs better, managers should be encouraged to devote more of l their time to teaching their people. This will not happen naturally. l It is harder to deal with people problems than it is to deal with ( paper problems. Known cases where people have been put in supervisory roles who l g. l l find that role repugnant need to be nagged and worked on. If i that feeling persists, then the person should be moved into a non-supervisory position. ( h.- Senior management needs to be conditioned to reset to poor supervision whenever it is observed, be it outside their division or ~ within contractor organizations. 1. It migtit be beneficial to review the provisions contained in contracts GPUN has with its major contractors to see what means exist for GPUN to monitor, report, and take action in cases of g poor or insufficient supervision. J. BETA does not subscribe to instituting a formal productivity .q monitoring system or a work / product sampling system. It is our feeling that such systems do more harm than good. Efforts spent In making a upervisors more effective pay higher dividends.. However, there may be some benefit to using data which is coBected for other reasons to get some gross indications of productivity trends. For example, returned costs on jobs of a repetitive nature can be trended. Total calendar time between start and complete dates on repetitive jobs cah be compared. Total man-rem exposure on similar jobs can be compared. Records of QC rejections or rework can be trended. Supervisor man tem l exposure in contrast to his work force can be compared. All of these can provide some sman measure or indication of problem areas. " k. In the case of personal appearance, demeanor, etc., no rules or written procedures are necessary or desired. They can't be written. What is needed is an awarenes of higher management to eases that clearly fab outside the norm, followed up with corrective setion. [. l 109

......__.._.__.m. w-L At the plant sites, hard hats should be ' distinctively color-coded so that there is a visible means of identifying workers, supervisors / foremen, and officers (managers and above). Major ,3 contractors should be required to follow this practies. . 5p GENERAL Paperwork FINDING XII-B Inere is too much paper being generated and distributed throughout the GPUN organization. DISCUSSION One area which would appear to provide room for improvement and would make more efficient use of manpower is tighter control of paper - all forms of paper. Not only is this a constant source of complaint, but our observations indicate that it is reak The following areas need corrections a. Distrbution - Documents prepared within GPUN, as well as those received from the outside, carry distributions throughout the GPUN system which are much more extensive than necessary. The intent is understandable, but the result is that too many people receive documents which they have little or no interest in, but because they receive them, they feel obligated to read them. We saw ~ numerous examples of this. 4 b. Signature /Addresee - There are instances where people within GPUN sign internal memorandums to people outside their Division who are senior to them. If these memorandums were strictly the pasing along of information, it might not be too bad, but that is not the case. In one case, a person two levels down in the organization directed 8 Vice Presidents to do something. In a similar vein, apparently anyone in GPUN can sign out a memorandum or letter. 'this is dangerous and can lead to problema. Some form of control should be exercised over who can sign correspondence to whom. This is already done in 'the case of expenditure' approval authority. c. Correspondence Control-With the exception of Licensing and the NRC, it would appear that some better form or system of correspondence control is needed. There exists a rather massive computer system for keeping track of key" docun}ents, but as far as we can see, it does not cont the correspondence, Le., due dates for responses, etc. Each il Ision and section has their own, which may be au right, but that w!D not keep management up-tMte on how well commitments are being met. d. Over-Abundance of Procedures - With the creation of the GPUN functional organization, each division obviously felt the need to formalize their way of doing business. Therefore, each division 110

1 f initiated the task of preparing procedures on bst how their work would be done, not only within their own division, but in all other divisions. These draft procedures werew and are, routed around for comment.- flowever, because of the large number of new 'T l procedures and the fact that each division was produchy their -{,, own, less time than desired was put into the review of others. ~ The result k that many of the procedures are not compatble from != one division to another, and what is worse - there are just too many of them. It is literaly impomble for any one person to even begin to absorb what is in those documents. There are more than 2000 procedures just for TMI-1 alone. We do not fault any of these 2000 procedures because they cover the areas needed to operate and maintain the plant. flowever, if some brake is not applied, each division will have 2000, and GPUN will be faced with trying to get over 15,000 procedures update 4 reviewed and foBowed. Writirg a procedure seems to be the easy way to solve a problem. Then once a procedure is written, supposedh the i problem is solved and the. burden shifts to the person at the bottom who is supposed to foBow it. i I e. Concurrences - Too many people are being required to concur in documents (procedures). This, in combination with the previous comment on the large number of procedures,' places an impossble burden on the system. What can happen is that people are forced to concur in documeats they do not read or do not read thoroughy unless they have some personal and direct interest.

ObviousW, each document needs to have some number'of concurrences, but as it is now, that number is far too large. It is g to division directors and their immediate subordina?.es to slow this down.

r-l. RECOMMENDA110N i a. Distrbution e Each. division director should take on the issue as a partleular une arises. If he is sensitive to the problem and reacts with his own people to hold down the distrbution, some headway can be made. It wiB do no good to' issue a. procedure or directive on a matter such as this. b. Signature / Addressee Apparenth action has already been taken to tighten up signature authority in certain areas. This area should continue to be watched and division directors should Mact to esses of noncompHance. I e. Correspondence Control A simple system of controlling correspondence should be j institute 4 at least to the point where the directors have some idea of how web their own people are meeting commitments. BETA is not proposing the creation of another new massive control system. a =

d. Over-Abundance of Procedures The proper operation of a nuclear pknt requires the existence of procedures. Each division needs procedures to set forth -

• g its methods of operation. The question here is how much is 4

e enough? Therew obvioush, is no absokite answer to this question; however, each division director should reaHstleaBy I -r make a ju% ment as to the necessity for erestirU a new procedure, taking into account not only what is ga ned, but what problems are created. 'Ihis is partleularW important in nuclear plants where verbatim compliance is becoming more and more the rule. Discounting plant operating' procedures, i which are not meant to be included in the thrust of this j comment, all procedures need to be ju%ed on the basis of necessity, keeping in mind the need to keep things as simple as poulble. e. Concurrences 8 he action taken by the Office of the President to resolve l this imue is having effect and should be continued. eeoe GENERAL Decision-Makirg Proces FINDING XB-C There is an overaB tendency within GPUN to force decision-making up too high in the organization. DISCUSSION s Throughout the course of the review, BETA repeatedly heard the complaint that too many decisions are made at too high a level h is perception was noted across the board, in an divisions and at aD locations. It was felt by those interviewed that this phenomenon originated at the level I of the Office of the President and then worked itself down the organization. In this regard it was interesting to note that division directors would make this observation about the Office of the Presideht while at the same time, senior people within those divisions would offer the same comment about their director, and so forth down the line. In some cases this escalation was blamed on administrative corporate policy procedure * (example, Emit of signature authority). Concurrent with the feeling that deelslon-making is forced upwards, is I the gierception' that decisions made at the top are too often made by consensus. There is be a natural tendency towards this approach in a functional organization. However, it was noted that too many deelsions are put before an of the division directors for their concurrence even though many of them win have no direct involvement. There are certain deelstons made by the Office of the President that are either controversial or 112 ~.

f distasteful that need to be made with consultation, but not necessarily with consensus. ^ Having decisions made at higher than normal levels can be expected in newly-formed organizations and ones having large numbers of new people l In managerial positions. These people are inexperienced, and in many cases, E have yet to understand the intricacies of their jobs, where top management is headed and their roles in relation to other managers. As time goes on, this situation should change and higher levels of management shouW have developed a greater sense of confidence in these people, eBowing decisions to drop back down to a reasonable level in the organization. BETA feels this has happened to some extent but not to the point where it shouW be. One result of decisions bel'ng forced too high, and it is a major element of this review, is that it takes an inordinate amount of time (and money) to l get anything done. We attempted to track a number of esses to illustrate the point, and while each case had its unique aspects, the overaH pattern was the same. First, a potential problem or need was identified. 1his was followed by a rather lengthy, involved proces to decide if there reaHy was a problem or need. Dependinc on the issue, this proces worked itself through a number of the divis.ons, taking' weeks to resolve. The same process was then followed on aniving at a soktion. By the time the decision was carried out (the work done), several months had elapsed and, in some cases, the fix was changed several times. BETA fully recognizes that the very nature of the nuclear busines requires careful and deta!!ed analysis of ~ problems and their sohtions. It wouW be foolhardy and dangerous to make I-snap decisions involving the technical aspects of the plant. Our concern is the feeling that too many problems are floated to the top and that an issues are treated as if they w'ere of equal importance. There will always be some fine thread which can be used to justify the need to elevate the importance of an action. Management must be in a position to use its pdgment. Another result of this situation is the feeling at the lower levels that by sharing the responsibility for decision-making among many, somehow no one person has to take the full brunt of the blame if things go wrong, and since they share the responsibility, t!.sy are not expected to be fuBy cognizant of the entire job. Besides there being each division with its own ad hoc internal review groups, there are innumerable established committees, that come into play depending on the matter involved. In some cases, this is necessary and required. However, to the extent possible, decisions shouM be made by the person responsible, placing on him the burden to satisfy the others within the functional organization. Conflicts between divisions obviously need to be settled by the Office of the President. The problem descrbed herein should not be interprettu to apply solely to the Office of the President. It maniffs'ts itself throughout the entire organization at an levels. RECOMMENDATION All levels of management should make a concerted effort to review the decision-making proces within their groups with the purpose of having decisions made at the proper level commensurate with the need. This shouM not result in a written procedure. It shouW come about as a result of action 113

[ i L taken by the Office of the President and the division directors on a case- -by case basis. g GENER,AL Handling Poor Performers FINDING XII-D There appears to be a reluctance within the GPUN system to take action either to improve the performance of poor performers or to terminate their employment. DISCUSSION A fairly large number of,GPUN people interviewed commented that action is not taken to correct, transfer or discharge known poor performers. We asked a number of managers if they had working for them people who were not contributing to the job as expected, and if they would be better I off without them. In almost all cases, we were told that they did have at least one out of ten who fell in that category. In some cases, the number was as high as three out of ten. When asked why they had not done anything l about this, the answer was usually that it was too hard (impossible) to fire l anyone. Further questioning also revealed that the Manager had done little ~ on his own to correct the poor performer. There.are a number of issues involved here. First, there is an administrative procedure in existence which covers the termination of a GPUN employee for poor performance. It is not clear thaat people are willing ~ to follow it. '1his might be a problem relating to the manager involved, or with the GPUN procedure. Secondly, the fact that managers are not actively attempting to improve the performance of their people is a problem. Finally, there is a problem if individual managers are not doing anything to thin their own ranks of marginal performers. If every manager felt he could accomplish the same amount of work with 10 percent less people, then a large part of the cost problem would go away. Incidentally, in a number of eases, these same managers were asking for increases in their manpower for 1983. Telling an employee that his performance is poor is usually a distasteful l job and one which " managers" will avoid. But that is a necessary burden of supervision. L RECOMMENDATION i a. A review should be made of the GPUN procedure, which tells l people what to do with poor performers, to find out if it is too eumbersome, causing people to shy away from it. b. Division directors should review the issue of poor performance with their managers to ensure that 8 i t I14

(1) Action is taken to correct the performance of their people when called for. ~ (2) When this. has been done to a reasonable extent, and the ~ employee's performance still has not been satisfactory, then T-- steps are taken to discharge the employee. eeoe GENERAL Staffs l FINDING XII-E I l Since the creation of GPUN, too many small groups (cells or staffs) i have been formed to carry out functions which should be handled within the i normal functioning groups. f DISCUSSION i Throughout the course of the BETA review, situations were noted where small groups or staffs had been created throughout all levels of the organization and in all divisions. These small staffs have grown in size and number. In some cases a " manager" wlB erente such a staff in order to enhance his image or maybe to solve an immediate (but temporary) problem. ~ The issue is not that the function need not be performed, it is that a staff has been created to do it. RECOMMENDA110N I' Each division director should review his manpower staffing so that he knows what each person and group is doing. Every effort should be made to reduce the number of staffs that have been created down within the s organization. 6. e 99 6 l ~ 115

En - t_. l. CHAPTER IIR e ?- COMPARATIVE ANALYSIS RESULTS I 'he i ) l [ O h 4 9 -,,.-e n.---.-

__. L._. i i 1 CHAPTER X111. COMPARATIVE ANALYSIS RESULTS A.

SUMMARY

The results of the' BETA analysis of the manpower and cost data obtained from a number of other utilities indicate that the data provides some useful information but only very limited conclusions. It raises more T questions than it answers, it was worthwhile for GPUN to have made the effort to obtain the data and it would be of some benefit to keep the data current in an attempt to make it more meaningfhL The data suffers from inaccuracies for a number of reasons explained later in this chapter. Nevertheless, it does highlight areas which GPUN should take a second look at. It shows, in an overaB sense, that both Oyster Creek and TMI-I have more people than any other plant. It shows that both of these plants have exhibited higher costs since at least 1975, and that the higher costs evidenced ainee GPUN was created is not a new phenomenon. It has provided BETA with at least a benchmark or point of departure in arriving at recommended manning ' levels for Oyster Creek and TM1-1. It / reflects a growing trend at au nuclear plants over the past several years not only as a result of inflation but of an increasing demand by regulatory bodies, the pubife, etc., to have the utilities cover more things in more detail and with more people. It shows the need for GPUN to take a look at itself, as it is doing, and to attempt to settle down and make the present organization more stable and effective. ( It would be a mistake to try to use the comparative data in isolation to prove or disprove the validity of any one category. The data is not that accumte. It would also be a mistake to discount totany the data and say it does not mean a thing. The data has a menage, but judgment is needed to use it properh. B. OBJEC'I1VE The comparative analysis effort was aimed at attempting to uncovar areas of costs and inswower within GPUN which were r.et'seabh out of 'I line with other plants of similar design and age. At first thought, one would-I think that such data would already be in existence, or, if not, would be relatively simple to obtain. Unfortunately, neither of these situations exists. l For example, each privately owned utility is required by law to submit a detailed financial and manpower report annuaHy to the U. S. Federal Energy l Regulatory Commission (FERC) now part of the Department of Energy. In the eary stages of its review, BETA reviewed these annual PERC reports from some 50 nuclear utilities. Based on this review, it was concluded that, for one reason or another, no meaningful information couldAe derived from them. It was clear that each utility intespreted the form differenth and to suit its own individual needs. This was true in both manpower and oost figures. It was also noted that several other organizations had attempted to collect data from the nuclear utilities along these same lines (EE! and INPO). BETA reviewed these results and again, concluded that the data could not be used for this purpose. 116

~~ __._.m Finally, it was agreed that through the efforts of GPUN, a numbar of nuclear utilities would be contacted and asked to cooperate in amassing data. This was done and it is this data that is being reported on. 'Phe requested data feu into two main categories; manpower and costs. t-An effort was made to attempt to define the breakdown ;n each of these categories in such a way that there would be no confusion as to what was meant. Even doing this and with GPUN people personally visiting many of the sites, BETA concludes it is doubtful that the results can be used for much more than just gross indicators. In an overall sense, it is BETA's opinion, after reviewing the data that has been collected, that it suffers many of the problems evidenced in the FERC reports and other surveys. The GPUN manpower data is accurate because there was no question as to the meaning or interpretation.of the categories. The GPUN cost data is as accurate as the data which exists in the company records, which does not mean it is 100% accurate insofar as allocation is concerned. Data froin the other utilities varies in accuracy downward from there. I Knowing that this was the situation, BETA attempted to eull from this data any area where the evidence clearly points to a problem within GPUN. This was the objective. C. METHOD OF APPROACH The survey involved 9 nuclear utilities owning 12 operating BWR plants and 7 utilities owning 10 operating PWR plants. TotaDy this involved 14 different utilities, and 15 different sites. Due to prearrangements with the participatirg utilities, the identification of the utilities and the plants was to be withheld. Each utility was provided with an explanation of what was needed and a questionnaire to be filled in. For each, someone from GPUN (or another utility) visited the utEty site in order to help ensure aces.ste data. In the manpower area there was the desire to know 1. the job being performed (title) (104)* 2. the piefession (engineer, tech, etc.) (19) 2. the job location (onsite/offalte) ( 2) 4. the employer (system /contractorP ( 2) s s ~

• categories AB of this data was then entered into a computer so that any given

, ares could be analyzed from a number of different perspectives. It was this data that BETA analyzed. 117

D. MANPOWER ANALYSIS RESULTS As previously indicated, the manpower data suffers from a number of faults which make its value as a means to compare different utilities very -f limited. Some of the thore significant inaccurseles arise for the following _g reasogs: g 3 1. Because of the wide variations reported in any given eategory, either the various utilities misunderstood the definitions or they categorized their positions differenth. This problem can only be resolved by GPUN people spending much more time at each site, interviewing a large number of managers, and compiling their own set of data based on firsthand knowledge. It is doubtful that the various utilities would ever agree to undertake such an effort. 2. Recognizing that there is little to be gained from comparig each l 4 individualline item, the tendency is to combine a number of them Into larger groups with the hope that the larger groupings will cancel out the variations; This proved to be of some benefit but still suffered from one significant problemwontractors. All utilities use contractors for some purposes. As in the case of GPUN, there are three ways to use contracted help. One is to put a contractor into a position normally occupied by a utility employee because either a person cannot be found to fill the job or because it requires special talents needed for a short period of time. Another way to use contractor help is to farm out speelfic work I tasks to an architect / engineering firm. Normally the work is performed at the contractor's home office. The third use of contractors is for mapr jobs, usually construction or modification work which is done at the site durig an outage. There are numerous variations on each of these three forms of contractor effort, such as guard forces, vehicle maintenance, etc. The problem with the manpower data is that each utility counts its contractors Ia differently, some not counting them at all, others only counting certain categories of them. Since the number of contractors can have a significant effect on levels of manpower, not knowing how each utility counted them, makes even the combined numbers aquL 3. Another problem encountered in attempting to understand the mannig data relates to the use of resources belonging to the corporate utility but not coming under the nuclear structure. A good example is the use of a corporate mobile maintenance group. ( This is a group of maintenance people who are used as the need l arises at all of a utility's plants, nuclear and omerwise. From a manpower standpoint, they are <wt counted against any one plant and usually no effort is made to allocate their services. The same situation exists with some engineering groups. If these numbers i i I are not included in the comparative data, then the data has a major flaw. I 4. Still another uncertainty arises when consideration is given to whether the gumbers reported reflect actual onboard numbers or intended levels. While the instructions were clear that each utility I 118

was to report approved levels (not onboard), a review of the data indicates this instruction was not always followed, primarily because a number of the utilities do not have such a system.- They earry i so many on the rous, and if the need arises they get approval on- { the-spot to hire additional people. What this means is that in j some cases a utility knows it is going to increase its staff within c: P the year in a given area, but this isn't reported because the process hasn't reached the point where they can report the increase. BETA h is aware of a significant number of situations where this condition exists. 5. Once all these uncertainties are understood, there is little hope that any detaDod analysk of the manning figures wlB yield a meaningful conclusion. As previously noted, it is possible to resolve these uncertainties to a large measure, but it would require sending several GPUN people to each utility for extended periods of time. BETA is not convinced the results would be worth the effort. Thus, except for providing some insight into speelfic cases where GPUN I aBocations might be high, the breakdown by individual job manpower assignments provides only a vague insight to the overall situation. BETA has used as much of this information as it deems appropriate in airriving at the recommendations contained in this report. The foHowing three tables summarize the total number of people asigned to a plant on the basis of onsite, offsite and totals for both system people and system plus contractor people, onsite and offsite. k e G S m e 119 - - - - ~

TABLE 1 A tabulation of the total average mmber of onsite people per plant is listed belowa v e Utility Utility 4t I Plant Only Contractors 1 184 244 2 194 247 3 199 257 l 4 4 til 808 5 280 355 6 280 355 7 303 479 8 344 458 9 365 370 10 410 448 11 453 526 12 462 478 13 483 718 14 464 545 15 745 779.5 (TMI-1) 16, 813 877 (Oyster Creek) 6 ~ Average 386 462 me 'M ' S Imum W$a l l l l 120

l TABLE 2 A similar listing of offsite personnel average on a per plant basis shows the following: Utility Utility & l Pfant Only Contractors 1 27.5 50 2 49 161 3 82.3 108.3 i 4 72.8 75.2 5 75.7 75.7 6 90.8 91.2 7 106.9 122.9 i 8 128.4 157.2 9 130 130 l 10 152 152 l 11 178.7-182.5 12 176.7 182.5 e 8 13 182 219 14 193.7 193.7 15 186 198. (TMI-1) 16 244.5 256.5 (O/C) Average 128 147 NOTE: Plant designation numbers on Tables 1, 2, and 3 do not necessarily indicate the same utility / plant. g i 9 0 4 ~ l W O 121 ~

-..l _..._:.__l.. l TAB _LE_L A tabulation of the total average number of people per plant, both offsite and onsite indicate the followirig I Utility dtDity & 7' Plant only Contractors 1 1 258.8 319.2 2 264.8 338.2 3 306 380 4 286.7 384.2 5 393 420 6 458.9 527.7 7 458.9 527.7 8 472.8 555J l 9 592 408 l 10 431.4 438.2 11 526 877 12 816.7 497 13 846.7 719.7 14 512 879 l 15 931 977.5 (TMI-1) 1,6, .1057.5 1133.5 (Oyster Creek) 6 I 811 Average 514 8 i I N 9 122

I i l l These listings would lead one to conclude that both Oyster Creek and TMI-1 are heavily manned but, for reasons already advanced, care must be taken in giving too much credence to them in isolation from other considerations. ~ The tables which follow are summaries prepared by GPUN based on a survey of the manpower numbers provided by the various cooperating utilities. I-These tables reflect manpower allocation by division using GPUN organizational structure. They do not differentiate between onsite and offsite i( but do show totals. G l I. huh ~ L 1 I!b t 4 i .a l ~ I 123

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^ ~~ i i E. COST ANALYSIS RESULTS The tables and charts included at the end of this section were prepared and furnished by GPUN, and reflect the summation of data collected from the various utilities. The validity of the data suffers from many of the _t same: problems identified with the manpower data, particularh with respect l to capital expenditures and the individual utility's breakdown between capital and O&M expenses. Because of the questionable accuracy of the cost data, BETA concludes that any comparative analysis would be of Ilmited value. However, from this data a number of conclusions can be reached. 1. The degree of imbalance between GPUN and the other utRities is less pronounced in terms of cost than in terms of manpower. For example, in the case where GPUN shows a manpower ratio between themselves and the lowest reporting of 3.54, the cost ratio between these same plants is only 2.1 (1981 figures). This could be because there is a tendency for the cost data to be more accurate than l .the manning data. Also, the cost data reflects historleal l information whereas mhnpower data is probabh a mixture of historical and projected information. Probably the most significant rationalization for this difference is that manning figures do not include contractors to the same extent as the cost figures do. Where a utility goes out and hires an engineerirg firm to perform a task under a capital project, the people used are not reported l in the manpower data. Since each utility uses various amounts of contracted work, the reported manpower figures could essuy be I off by a significant factor. j i 2. Nuclear fuel costs are not included within the total cost data. If all utilities used the same criteria for arriving at fuel costs then the absence of this number would not affect the overall meaning of the cost data. However, based on BETA's knowledge, what a given utility allows to be put in that cost center varies considerably. Even in the case of GPUN some costs associated with nuclear fuel I management are not chargeable to GPUN. A review of the annual FERC r:: ports on nuclear fuel chcges shows ' extremely wide variations from utility to 'utuity. 3. Discounting the absolute numbers, it can be seen that there is a i substantial step increase in expenditures in all plants in the years i followirg the accident at TML (See charts at the end of this section). It is suspected that 1982 cost data wD1 show all the plants tendity to reach about the same levels, as those plants, whleh were lagging in accomplishing the TM1 lemons learned modifications, start to catch up. . 4. An analysis of the cost of capital projects provides no useful means i 1 of comparison. BETA had anticipated that looking at the return costs to do a similar modification at several different plants might l provide an insight to efficiency. Due to a number of reasons this did not prove to be the case. In summary, it would appear that gros cost comparative data tends l to be more meaningful than marning data. Recognizing there are inaccuracies I 136 ...m

in the cost data, it is still possible to watch the trends. For this reason it is recommended that GPUN continue to obtain cost data from the other utilities to see if the other plants do, in fact, start to come closer together. Although doing this might prove to be interesting, it will not point to any specific area within GPUN as beirg out of Ene. j'e ib I*$ re 1 l i l l G O O lie W } 4 137

^ L. _.. A. ......r...._. i INDUSTRY SURVEY COST COMPARISON BW PLANTS RISTORICAL CDSTS - PER UNIT BASIS (SIN MILLIONS) PLANT PLANT PLANT PIANT PLANT PLANT FI. ANT A 8 C D E F C jf 1976: DEM 10.4 14.0 8.1 4.6 5.3 14.0 a6.6 Ca'~p ital 25.0 10.7 1.8* 1.3* 4.1 10.0 = 2.5* 4.0 melear C&A = = $ 35.4 $24.7

• W

$'T.T $94 $28.0 ATT ' Capacity Factor 67.6 65.6 55.6 83.3 76.8 42.0 42 0 1977: CEM 14.8 12.6 8.4 11.1 9.7 21.8 15.3 Capital 24.0 12.7 5.2* 1.1* 9.6 9.1 10.6* 2.7 .7 Nuclear C4A $ 38.8 825.3 $14.3 812.2 $19.3 23.6 $25.9 Capacity Factor 57.0 83.4 57.1 74.8 55.1

• 47.2 46.2 1978: OEM 15.9 17.9 11.1 9.1 4.4 19.7 14.2 Capital 28.2 10.0 3.9*

7.1 9.1 8.1 10.2* 2.1 1.4 melear C64 4 44.1 $2 7.9 $16.4 $16.2 $TI T $29.9 $24.4 l, capacity Factor 64.0 80.5 66.2 80.8 82.3 73.3 76.3 1979: C&M 13.0 24.6 15.6 10.6 11.7 20.0 18.4 Capital' 17.3 17.5 8.2* 4.7 21.9 10.8 6.4* 1.8 2.2 l Nuclear C&A $ 30.3 & 2.1 526.0 $15.3 23.6 22.6 824.8 Capacity Factor 80.1 73.0 63.4 92.2 55.3 78.6 84.4 7 1980: O&M 37.5 27.6 19.3 18.4 '9 4 28.4 27.8 Capital 29.2 22.6 16.5* 8.9 35 4 24.3 38.1* 1.9 4.0 helear C&A De ferrals 4.0 $ 6 6.7 $54.2 D 9.8 81 7.3 $64.5 $54.6 $63.9 Capacity Factor 34.4 58.4 51.0 72.3 83.6 62.0 33.1 1981: O&M $ 45.2 33.5 18.6 21.3 26.7 32.7 35.0 4 Capital 36.8 85.3 24.7*

• 31.3 57.5 24.9 44.1*

1.6 4.4 \\ melear C&A 11.0 De ferrale $10 2.0 $118.8 $ 7.7 $5 2.6 $B 4.2 $5 9.2 $7 9 1 i Capacity Factor 46.2 43.6 68.7 68.2 ~ 60.2 52.3 60.0 Flant vintage F10 Ws v10 hs >10 Ws r10 hs *10 Ws 5-10 Rs 5-10 Ws

• Capital expenditures were not available. One half of prior year and one half of current year capital additions to plant-in-service were used as a substitute.

l 138

y rr r r, 3 l a 0 BWR Historical Cost Comparison 19.76-1981 125 CAPITAL i l 08M/ DEFERRED 08M i ~ l I ~ t i l ~ C = s 8 I i o i i ,j' r = s. I t i. l i I n 2 ! Zk ~ l 3. g I h Il 5 7N k 4 A PLANT A l PLANT s l PLANTC PLANTO PLANT E , PLANT F l PLANT 8 , (0YSTER CREER) ,? j ? !*

• l e

i i m r7 ! i -r r' 1 i l l \\ BWR Plants - Historical Costs per Unit Basis 125 l .n. m h8 l ~ f =f 4e 4 [ 'l ~ .d ii p l; 1 g ,f%M r/ o 3* I / / / / i 5 ,,,[ 8 ~ j 3,,,3g, 2e m.Ji.' ,,,,3 r 1 .%.g. - 3., ! i, I Ie o I 1 8 l im g.- e is77 l; 1s7s 197s tese inst t 1976

i i INDUSTRY SURVEY COST COMPARISON FWR PLANTS R1570RICAL CDSTS - PER UNIT SASIS (s1N M111.3DNS) PLANT FIANT

• FLANT PLANT F1. ANT FLANT

( J E L M N Oo 3.{t 197Er: DEM 17.8 10.9 9.1 5.6 capital 4.5 10.7 1.9* 1.9 20 .1 Walear C&A .6 = = = sit'T s2TT sTr3 s"IT -o-s. Capacity Factor 60.3 62.5 84.9 55.6 N/A 85.4 ~ 1977: OEM 13.3 17.4 10.1 8.3 8.4 8.4 thpital 4.9 12.7 13.4 2.1 4.5* 2.4 3.5 Nuclear C&A 1.1 l sTCY 55T K3~.T WIT 3 iTT.T (14'T Capacity Factor 76.2, 39.7 73.7 55.8 69.4 74.3 1978: OEM 18.0 23.7 13.0 9.9 15.6 10.8 Capital 9.0 10.0 3.2 2.6 4.5* 2.1 4.4 1.6 mclear C&A = = SIT.T

• TT.T sTr.T sTCT sT6T SIT.T Capacity Factor 79.1 61.9 46.9 68.2 35.9 76.2 1979: CEM 16.3 24.1 18.2 13.4 24.0 10.0 capital 6.8 7.9 2.9 7.4 4.1 8.5 4.5 l

Nuclear C&A 2.9 EIIT s32.0 s21.1, s23.7 sII"I SIT"I 1. Capacity Tactor 11.8 38.6 65.4 61.0 32.1 62.8 1 1980: 0&M 40.7 28.6 20.8 17.3 39.8 14.0 Capital 16.1 45.8 15.3 11.7 1.9 7.8 8.7 3.3 melear C&& 3.0 2.5 Deferrals i iii'.T ss4.4 sTS T sTT.T sTi~.7 sTI"I Capacity Factor 3/A 64.1 .80.8 42.7 46.4 60.9 i 19 81: O&M 54.0 25.4 25.1 19.6 47.0 20.6 Capital 32.7 14.3 17.7 .14.0 5.6 10.1 10.7 8.7 melear C&A 3.0 ' 2.5 neferrats sII".T s5T.T sTT3 sITT sTTT stT3 l Capacity Factor N/A 79.9 77.8 59.3 56.5 72.1 Flant vintaSe 5-10 De 3-10 we 5-10 Ws 5-10 wa 5-10 ha 5-10 ts

• Capitak expenditures were not available. One half of prior year and one half of current year capital additions to p!'antala-service were used as a substitute.

5/A = Not Applicable 142

g g y 4,' j 1 PWR Historical Cost Comparison 1976-1981 les CAPITAL [ [o'aminerinnesasm l 1s ) k- [ Lea g is l rs 7 ~ a 7, p itill dll nill aill il vill i e PLANT J PLANT K PLANT L PLANT M PLANT N PLANT 9 (TM1-1) s-h,

k ew e 1 9 r I I\\ F '9 A' 1 l 1 i il l PWR Plants - Historical Costs i per Unit Basis t . tes i J / / l 15 1 / / s / \\ / 4 5 n g ) s,,,, se g ,',s. i' =

• /./

/ /,,'. N' ~ ./,/ t i -/ j s*- ,s ~p, } i gg $W~,~ (W ,i/ t t

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~ ~ is7s ,is77 1s7s 1s7s asse iss'I . ' YEAR OF EXPENDITURE j

u .m PWR Historical Cost Comparison 4 1976-1981 so !, i i l I J l d g / se f / l f I f l .-f. A 1 I 4e AVERAGE l / / s / = I s./ L z 4 9 I ,o / u /./*e \\b }d sg I / Lrs g / ~. / / ~ I we i g (% s i,. --- \\ 28 _ s X_ s / ~p Lg y i - i. l l 1 l I e ,,5, l 1975 1977 l 1978 1979 1980 1981 I l' 3 YEAR AVERAGE 9 4 - - - - - - - - - - - -}}