ML20032C173
| ML20032C173 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/03/1981 |
| From: | Blake E SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Buck J, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-SP, NUDOCS 8111090327 | |
| Download: ML20032C173 (4) | |
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Ti5iiPTC RELATED CORRESPONDENCZ i
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'81, NOV ~4 P4 58 SHAW, PITTMAN, PoTTs & TROWBRIDGhFICE OF SECRETRY seOo M sw tT. N. W-00CHETING & SERVICE WASm NGTON, D. C. 20036 BRANCH R AMSAY D. POTTS M ARE AUGENBLICM DAveD M. RUBENSTEIN MOWARD M. SMAFFERM AN STEWART L PiTTMAN E RNE ST L. BLAnE. JR.
12O21822-eOOO MATI AS F. TRaviESO-Du 1 DE80 RAM S BAU$CR GEORGE F TRowSRiDGE C ARLETON S JCNES vsCrons A J. PERMsNS SCOTT A ANENBERG STEPMEN O POTTS TMOM AS A. BAxTER JOMN MsO'N EILL. JR.
SETM M MOOGAStAN GE RALC, CH ARNCF F JAMES M. BURGE R JAY #.EP?TIEN S *staLA E. McCAFFERTY PMtLLip D. SOSTWICM SMELDON J. WE'SEL TELEC0A L A RAN ; 4 = ALLEN C E LISSA A. R&DGWAY lit. TIMOTMT MANLON JOHN A. McCULLOLOM TIMOTHY B. MceRsDE 8.LNNET A J M AUTMAN B2021822-eO99 & 822-is99 GEORGE M. ROGERS. JR J. PATRICM MiCm ED ELISABETH M. MENDLETON E AviO LAWRENCE MILLER FRED A LITTLE ~
GEORGE P. MICMAELY. JR.
PAUL A. MAPLAN ANNE M MR AUSROPF JOHN 3. RMiNELANDER J AM E S T MOM AS LE N M ART M ARRY M, GLASSPIEGEL F REDERICM L. MLEIN GRUCE w CMURCMcLL STEVEN L. MELTZER TELEM R ANDAL 8. liELL GORDON R MANOFSKY LESL E A. NICHOLSON JR.
DEAN O AULICM TMOMASM McCORMICM SALLY C ArdDREwS 8 0' O'3 'I"##'"* *I"'
MARTIN D. MRALL JOMN ENGEL WILLa AM P. B ARR JEFFREY f GP ANCOLA RtCMAvD J MENDALL STEPMEN e WTTLER CABL E *SMAwLAw-susan M FREUND MANN AM E W LIE BERM AN JAv E allLSE RG WINTMROP N BROWN JOMN L. CARR, JR.
SANDRA E. FOLSOM GAREARA M ROSSOTTI JAMES 5. MAMLIN PMatipJ.MARvEv MARCsA R. NfRENSTCIN b
RED DRAS ER R CMARD E. GALEN WRITER'S DIRECT DIAL NUMBER RSA A D4 f EDWARD 0 0m
/4 R ME RosERT e ROesiNS sONN E NATM.Nov wE eS.TER l7R$0W9 N,EL P RE ED. JR STEvCN M LUCAS gpgg tz Novo g IS81*
h' November 3, 1981 m u..,Qgm, 7
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ll Administrative Juo <
Administrati've Judge f\\/
John H. Buck Christine N. h pl' I t/
Atomic Safety and I ensing Atomic Safety lind-Licensing Appeal Board Appeal Board U.S. Nuclear Regulat;ry U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)
Docket No. 50-289 SP (Restart)
Dear Judges Buck and Kohl:
In accordance with procedures outlined in my letter to the Appeal Board of October 1, 1981, I enclose copies of an Evaluation o'l Three Mile Island Nuclear Power Station - Unit One, dated October, 1981, which reports on the recent Institute of Nuclear-Power Operations (INPO) evaluation of TMI-1.
g The report's Determination (at page 1), states:
" Based on the evaluation, it appears that when the
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outage work in progress is completed, TMI-1 will be ready to operate safely.
Additionally, within the scope of the evaluation, the taum determined that the plant is in an acceptable material condi-tion and is being maintained shutdown in a safe manner by qualified personnel.
The Determination continues on to describe beneficial practices and accomplishments and recommended improvements intended to assist Licensee in ongoing efforts to improve all aspects of its nuclear 8111090327 811103 PDR ADOCK 05000289 o
PDR a
i SHAW, PITTMAN, POTTS & TROWBRIDGE Administrative Judge John H. Buck Administrative Judge Christine N.
Kohl November 3, 1981
--Page Two program.
While it is instructive wd informative, it would not appear to warrant formal consideration in this proceeding and is forwarded because.of its potentia.i general interest to the Appeal Board and parties cnd because of the particular interest o
in INPO's evaluation of TMY-1 expressed'by the Licensing Board during the evidentiary hearie.g (Tr. 13,271-72).
Respectfully submitted,
& $. $Q&
Ernest L. Blake, Jr.
Counsel for Licensee ELB/tjc Encl.
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Attached Service List O
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal' Board In the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart)
(Three. Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Administrative Judge Robert Adler, Esq.
John H. Buck Karin W.
Carter, Esq.
Atomic Safety and Licensing Assistant Attorney. General Appeal Board 505 Executive House U.S. Nuclear Regulatory Post Office Box 2357 Commission Harrisburg, PA 17120 Washington, D.C.
20555 Atterney General of New Jersey Administrative Judge Atta:
Thomas J, Germine, Esq.
Christine N.
Kohl Deputy Attorney General Atomic Safety and Licensing Division of Law - Room 316 Appeal Board 1100 Raymond Boulevard U.S. Nuclear Regulatory Newark, New Jersey 07102 Commission Washington, D.C.
20555 John A.
Levin, Esquire Assistant Counsel James R. Tourtellotte, Esq. (4)
Pennsylvania Public Utility Office of Executive Legal Commission Director Post Office Box 3265 U.S. Nuclear Regulatory Harrisburg, PA 17120 Commission Washington, D.C.
20555 John E. Minnich Chairman, Dauphin County Board Docketing & Service Section (3) of Commissioners Office of the Secretary Dauphin County Courthouse U.S. Nuclear Regulatory-Front and Market Streets Commission Harrisburg, PA 17101 Washington, D.C.
20555 Robert Q. Pollard Walter W.
Cohen, Esq.
609 Montpelier Street Consumer Advocate Baltimore, MD 21218 Office of Consumer Advocate 1425 Strawberry Square Harrisburg, PA 17127 J
g 4
. Jordan D.
Cunningham, Esquire William S.
Jordan, III, Esquire Fox, Farr & Cunningham Harron & Weiss 2320 North Second Street 1725 Eye Street, N.W.,
Suite 506 Harrisburg, PA 17110 Washington, D.C.
20006 Ms. Louise Bradford Chauncey Kepford TMI ALERT Judith H.
Johnsrud 1011 Green Street Environmental Coalition on Harrisburg, PA 17102 Nuclear Power 433 Orlando Avenue
'Ellyn R.. Weiss, Esquire State College, PA 16801 Harmon & Weiss 1725 Eye Street,'N.W., Suite 506 Marvin I.
Lewis Washington, D.C.
20006 6504 Bradford Terrace Philadelphia, PA 19149 Steven C.
Sholly Union of Concerned Scientists Norman Aamodt 1725 Eye Street, N.W.,
Suite 601 R.
D.'5 Washington, D.C.
20006 Coatesville, PA. 19320 Ms. Gail Phelps John.Clewett, Esquire ANGRY The Christic Institute 245 West Philadelphia Street 1324 N. Capitol Street York, PA 17404 Washington, D.C.
20006 Administrative Judge '
Ivan W. Smith Chairman, Atomic Safety &
Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555-Administrative Judge Walter H. Jordan Atomic Safety & Licensing Board i
U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 i
Administrative Judge Linda W.
Little I
Atomic Safety & Licensing Board U.S.. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 k
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Evaluation Report E NDY -4 P4:59 Ob5Ebfkhc'g vh i
N October 1981 g
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T1ree Vi e Is and Nuc ear Power Station - Unit One Genera Duaic Utiities Jersey Central
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Power & Light Company Metropolitan
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Edison Company Pennsylvania
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Electric Company
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EVALUATION j
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,2 THREE MILE ISLAND NUCLEAR POWER STATION - UNIT ONE i
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GENERAL PUBLIC UTILITIES d
Jersay Central Power & Light Company Metropolitan Edison Company i
Pennsylvania Electric Company J
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October 1981 l"1
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SUMMARY
INTRODUCTION 1'1 The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of General Public Utilities' (GPU) Three Mile Island Nuclear Power Station, Unit One (TMI-1), during the weeks of July 27 and August 3,1981. TMI-l is an 800 MW net Babcock and Wilcox pressurized water reactor. The site is located in Dauphin County on Three Mile Islam in the Susquehanna River about ten miles southeast of Harrisburg, g;
Pennsylvania. The unit began commercial operation in September 1974 and has been y
shut down since February 1979.
PURPOSE AND SCOPE 7
INPO conducted an evaluation of site activities to make an overall determination of j
plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of plant documents.
r-S The INPO evaluation team examined station organization and administration, training, shutdown operations, maintenance, radiological and chemistry activities, and on-site technical support.
Corporate activities were not included in the scope of the evaluation, except as they related to the areas evaluated. As a basis for the evaluation, INPO used performance objectives and criteria relevant to each of the six areas
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examined; these were applied and evaluated in light of both the experience of team members and INPO's observations of good practices within the industry.
a INPO's goal is to assist member utilities in achieving the highest standards of I
excellence in all phases of nuclear plant operation. Accordingly, the conditions found in j"
each area were compared to best practices, rather than to mimmutn acceptable.
conditions or requirements.
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DETERMINATION Based on the evaluation, it appears that when the outage wot k in progress is completed, TMI-1 will be ready to operate safely. Additionally, within the scope of the evaluation, the team determined that the plant is in an acceptable material condition and is being l-maintained shutdown in a safe manner by qualified personnel.
Certain beneficial practices and accomplishments were noted:
The commitment by corporate headquarters to acquire top level talent.
The overall commitment to training as demonstrated by the assignment of one
- .j entire shift to training, new training facilities, a computer-aided instruction j
program, and plans for both a basic principles simulator and a full-size plant-1, specific simulator.
l" The Operations Department administration including the operations surveillance l,
system and the comprehensive shift turnover process.
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TMI-1 (1981)
Page 2 The excellent radiological protection training and retraining programs, including r
the reouirement that workers demonstrate their abilities in practice.
'j 'i The commitment to quality assurance and quality control programs.
The program of management tours of the plant in off-normal hours.
The senior executive technical training program.
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Excellent communications among the different organizations at the site.
7 Dedication and positive morale of station personnel.
Improvements were recommended in a number of areas. The following are considered
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to be among the most important:
1J A need exists for more involvement by middle management and supervisors in day-to-day plant operations. In addition, training is needed to increase their
,7 ability to identify deficiencies and potential problems.
Lj Programs to analyze in-house events and to derive benefit from industrywide operating experience should be improved.
J Many excellent procedures have been developed, but are not yet being used to best advantage. Some of these provide guidance for the preventive maintenance program, work control system, surveillance program, and method of identifying plant deficiencies. They require improvement in implementation. In particular, there is a need for more preventive maintenance and an improved ability to 1
identify deficiencies requiring corrective maintenance.
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The plant chemistry improvement program that emphasizes procedures, methods of quality control, and training needs to be completed.
In each of the six areas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of this evaluation are listed in APPENDIX A.
lJ Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to which they pertain.
Particularly noteworthy conditions that contribute to meeting PERFORMANCE OBJECTIVES are identified as Good Practices.
Other findings describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It would not be productive to list as Good Practices those things ti,at are commonly done in the industry since this would be of no benefit to GPU or to INPO's other member utilities. As a recult, most of the findings highlight conditions that need improvement.
The recommendations following each finding are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.
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The findings listed herein were presented to GPU management at an exit meeting at the plant on August 7,1981. Findings, recommendations, and responses were reviewed with
,j GPU management. GPU responses are considered appropriate.
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,2 TMI-l (1981)
Page 3 To follow the timely completion of the improvements included in the responses, INPO requests written notification of status six months from the date of this report.
The evaluation staff appreciates the excellent cooperation of all levels of General Public Utilities.
k E. P. Wilkinson
.1 President
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Page 4 GENERAL PUBLIC UTILITIES Response Summary R}
Since the accident at Three Mile Island Unit 2, the organization for conduct of General L.
Public Utilities' nuclear activities has been completely restiuctured. Three Mile Island Unit I has been the lead site for many of the efforts associated with implementation of
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the nev, organization.
Thus, the evaltation by the Institute of Nuclear Power j
Operations (INPO) of TMI Unit I was expected to be, and indeed was, very helpful to l
GPU. We gained from the INPO evaluation added confidence in the soundnes: of our L
approach as well as additionr1 insight into areas in which the implementation of cur new l
programs remains to be completed.
a We believe that findings by the evalmtion tean; are valid and address principal areas in which improvements can be made. Our summary comments on the most important of 1
these areas in which improvements are recommended are:
1q One of the principal goals of GPU in development of the current organization was
' ~j to structure the supervisory and management positions at the site so they would be able to be adequately involved with day-tcrday plant operations. We believe the organization, as established, does provide that capability, and we will continue our efforts through training and use of various management controls to develop H
the desired level of involvement by managers and supervisors in day-to-day plant l
activities. Also, the actions set forth in response to Findings OP.3-1 and M A.1-1
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are expected to contribute significantly to improvement in this area.
GPU also recognizes that radiological controls, preventive maintenance, mainte-
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nance management, and test equipment activities require more complete and
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consistent implementation of prescribed procedures. These are areas which have I
been extensively reviewed during the past two years and for which major procedure modifications have been developed. We will continue our efforts to realize full implementation of these programs through the specific actions set i
forth in the various responses and by developing greater understanding on the part H
of all elements of the organization as to the standards of performer.a expected in t
these areas.
A As a result of the focus on analyses of plant experiences resulting from the TMI-2 accident and preparation for restart of Unit 1, GPU bad to develop and commit to in-house programs prior to the availability of some of the current industry efforts for review of plant experiences. We will continue to review our program and take advantage of industry efforts (particularly the INPO review of plant experiences) f to improve the effectiveness of our own prugram. We request that INPO consider cross-referencing SOERs to oth; industry and NRC documentation of plant events.
GPU has been working since early 1981 on a comprehensive upgrading of the TMI-1 plant chemistry program.
While we believe that both primary and secondary water chemistry have been maintained within specifications very 7
effectively, as indicatec hoth by plant records and material condition of the unit, we agree that upgrading is necessary to achieve a high quality, comprehensive plant chemistry program that is consistent with reliability objectives.
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Page5 Implementation of our corrective actions will not only correct the specific deficiencies noted but are also consistent with overall efforts that address
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underlying causes and issues for which the specific deficiencies are but symptoms.
'g The evaluation of TMI-1 was carried out objectively and professionally by a very competent INPO team. We welcome peer review and are convinced that we will have stronger management systems and consequently a greater assurance of safety as a result of the evaluttion.
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Page 6 TRAINING AND QUALIFICATION r
TRAINING ORGANIZA'I10N f
PERFORMANCE OBJECTIVE: Provide a clearly defined training organization staffed with qualified personnel capable of accomplishing all assigned training tasks.
Finding A good practice was noted in the training ceganization's develop-(TQ.1-1) ment and conduct of an excellent Instructor levelopment Program.
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The one-week course covers methods and techniques of training L
design, presentation, and evaluation. Topics include needs and task analysis, development of learning objectives, training analysis, training methodologies, training materials, lesson plan preparation m
and use, presentation techniques, and evaluation of presentation effectiveness. Allinstructors surveyed responded positively to this It has provided a basis for conducting and evaluating course.
training efforts and has helped standardize various instructors' d
approaches to training.
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TRAINING ADMINISTRATION PERFORMANCE OBJECTIVE: Ensure that activities necesury to initiate and control personnel qualification programs are accomplished in a well-defined, coordinated, and
'M effective manner.
Finding A training program for middle-level managers in plant systems and (TQ.2-1) technology is needed. Currently, such courses exist for individuals at the operator / technician level and at the senior management le-L However, individuals in positions between these levels
- + ve no such training.
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Recommendation Pt' oe plant systems and technology training to middle-level managers. Existing programs for personnel at operator / technician levels and/or senior management levels could be utilized in this effort.
Response
GPU agrees that a formal training program for middle-level managers in plant systems and technology is needed. A specific l-course on pressurized water reactor (PWR) systems and technology is under development and is scheduled to be available in July 1982.
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Attendance at this course, or portions thereof, will be determined
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on an individual basis taking into considerMior. the background, work assignments, and professional development objectives of the l
individual employee.
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TMI-1 (1981) fl.
Page 7 Finding A good practice was noted in that supervisory personnel from the (TQ.2-2)
Training Department periodically monitor and evaluate training
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sessions. The Plant Training Manager publishes monthly schedules assigning his supervisors to evaluate specific training sessions. The r
formal, scheduled assignment of individuals to conduct specified j
evaluations of training sessions is the key to this good practice.
The system provides assurance that the monitoring and evaluations will actually be accomplished.
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Page 8 OPERATIONS CONDUCT OF SHIFT OPERATIONS PERFORMANCE OBJECTIVE: Ensure that shift operations are conducted in a safe and reliable manner.
Finding Several weaknesses relating to inattention to detail and the need (OP.3-1) for improved supervisory; involvement were noted during plant n
tours and during observations of plant testing. Examples include y
the following:
a.
The material condition and cleanliness of the plant were acceptable, but need upgrading.
b.
Observations of emergency feedwater and secondary river
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water pump hot functional testing indicated a lack of under-Et standing of some aspects of the evolutions by plant personnel, inattention to the calibration and indication requirements of installed instrumentation, and a misunderstanding of actual pump conditions. Several minor deficiencies were overlooked either during the test or in the concluding walkdown.
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Persons conducting an electrical preventive maintenance test were unable to verify that the equipment and test devices a
were in a safe or correct condition as specified in the
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procedure.
Recommendation Administrative controls are in place to correct the details in the above finding; however, implementation needs upgrading. Manage-y l
ment should address the need for greater attention to detail at both supervisory and bargaining unit positions and should become more involved in daily plant activities. Responsibilitics should be reemphasized and personnel held accountable for these responsi-6 bilities.
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Response
GPU believes the attitudes and performance of the operations j
staff, particularly those on-shift, are central to safe operations.
Clearly, their attention to detail and their awareness of the status of equipment, procedural requirements, and methods for ensuring the validity of the results of their testing and operational activities are strong indications of their ability to operate safely.
The desired level of performance on the part of the operations staff will be achieved most reliably when there is a visible, consistent, and effective involvement in plant activities by members of management. We will continue efforts for full implementation of
'1 the established administrative controls through our department meetings and the emphasis provided in our training and re-training programs. In addition, we think that actions specified in response to several of the other recommendations will contribute to cor-recting deficiencies identified in this finding.
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l T MI-1 (1981) 7-Page 9
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PLANT OPERATIONS PROCEDURES
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PERFORMANCE OBJECTIVE: Provide timely, effective guidance to operators in the for.n of written procedures.
Finding The following good practice was noted: Numerous well-developed (OP.4-1) programs exist within the Operations Department. It is obvious
,l that considerable effort has been made to achieve procedures that are operator oriented and allow efficient operation within existing i
requirements.
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mi Finding Uncontrolled notes, portions of procedures, labels, and drawings of (OP.4-2) a temporary nature that are used as operator aids are attached at q}l various work areas and local control panels in the plant.
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program is in place to control these types of aids and has resulted in good examples displaycd in various locations; however, complete j
implementation has not been achieved.
Recommendation Additional emphasis should be placed on complete implementation of the existing practice of controlling the distribution and use of operator aids of the types listed. Periodically supervisors should include observations of the effectiveness of this program during regular plant tours.
Response
GPU will continue the ongoing program of removing uncontrolled notes, portions of procedures, labels and drawings of a temporary a
nature. Removal and replacement with permanent authorized aids
~j will be accomplished by December 31, 1981.
Management and supervisory personnel have been advised to identify temporary
" operator aids" during their plant tours.
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SIIIFT TURNOVER PERFORMANCE OBJECTIVE: Ensure a continuous and correct understanding of plant conditions at all shif t operating positions through proper shift turnover.
'l Finding The following good practice was noted: Shift turnover document?
j (OP.6-1) are pertinent and comprehensive. In addition, the briefings con-ducted for shift operators by the shift supervisor after turnover ensure improved continuity of information between shif ts.
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Page 10 r-j.
TAGOUT PRACTICES PERFORM ANCE OBJECTIVE: Protec' personnel and plant equipment by implementing effective tagout practices.
[T gj Finding The current tagout procedure needs to be implemented more 1
(OP.7-1) effectively. Observations indicate that tags are being used for q
other than their intended purpose, and some tags are illegible due j
to deterioration. The semi-annual audit of the tag system has not identified these deficiencies because the audit does not include observations of tags out in the plant.
,c Recommendation Emphasize through additional training or department meetings the l
necessity of compliance with the intent of company procedure AP1002, " Rules for the Protection of Employees Working on j
Electrical and Mechanical Apparatus," and AP1037, " Control of Caution and DNO Tags." In addition, expand the current Opera-tions Surveillance OPS-528, or develop a new audit system to include periodic in-plant checks of existing tagouts.
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Response
Review of procedures AP1002 and AP1037 is required on an annual basis. We will increase our emphasis on the necessity of compli-3 ance with these procedures effective October 1,1981 and will include this issue in the program described in response to Finding
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O A.4-1.
A cLnplete check of all tagouts will be made prior to restart. Additionally, Operations Surveillance Procedure OPS-528 a
will be modified by September 1,
1982 to incorporate the q
requirement to observe physically all tags and to replace those that are deteriorated, damaged, or missing on a semi-annual basis.
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Page 11 MAINTENANCE 9
MAINTENANCE ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: Provide a clearly defined maintenance organization that is adequately staffed, assigns responsibilities, and delegates ad(quate authority for the accomplishment of required tasks.
.l Finding More aggressive efforts are needed to klentify and correct defi-1 (M A.1-1) ciencies in order to optimize the plant's material condition prior to startup. Many plant deficiencies noted during the evaluation were not reflected in the work control system. The 5fot Functional Test (IIFT) program is organized, in part, to inspect and identify plant l
problems. However, this aspect of the HFT program is not being managed in an aggressive manner. One plant system that recently completed Hot Functional Testing was evaluated for its overall 7
material condition. Although the system was operational, several problems were identified that had not been documented during the test program.
'i Recommendation Conduct more comprehensive system material inspections to com-plement the retests, surveillance tests, and job ticket reviews currently required to certify systems ready to support start-up.
l Translate the identification of deficiencies into applicable work J
lists for orderly correction and overall improvement in plant material condition.
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Response
Guidance will be developed to use during field inspections of systems to identify deficiencies in the material condition of the system. This guidance will be used during a walkdown of the plant systems prior to startup. Items identified during the walkdown J
which are not satisfactory will be t.nslated into a work item that will be complet?d prior to certifyug the system ready to support startup. Supervisory personnel will spot check system walkdowns to ensure inspections are being conducted properly and deficiencies a
are being identified.
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lJ WORK CONTROL SYSTEM PERFORMANCE OBJECTIVE: Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently disposi-
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tioned and documented, m
Finding The work control system needs to be utilized more effectively to
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(M A.3-1) optimize the material condition of the plant. About one-third of all current job tickets are considered by the plant to be workable.
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Page 12 i
The remaining two-thirds are awaiting retest or are on administra-tive hold. Many of those 9 hold have remained outstanding for an extended period of time. Outstanding job tickets, should receive a comprehensive periodic review.
Recommendation Conduct periodic reviews of each job ticket in the work control system to reconfirm validity of current designations, uncover unwarranted administrative delays, reestablish work priorities, and review supply support.
Respanse Once each quarter a management review at the department head level of all outstanding work requests will be conducted to recon-firm validity of current designations, uncover unwarranted admini-
'l strative delays, reestablish work priorities, and review supply support. The first of these quarterly reviews will be conducted before the end of 1981.
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Finding Improved. coordination between the Supply and Maintenance (M A.3-2)
Departments is needed in the planning, scheduling, and conduct of maintenance. Correction of material deficiencies is of ten delayed by problems in the mechanics of the procurement process including missing, changed, or cancelled material requisitions, all of which make parts status difficult to track. Approximately 125 jobs are on hold for parts. A sampling of 50 of these revealed that the required parts actually were available on site for 12 of the 50.
Recommendation Assign responsibility for monitoring the timely procurement of parts required to support maintenance activities. Include Supply Department representation at appropriate Maintenance Depart-ment planning and scheduling meetings for the purpose of im-proving interdepcrtmental coordination.
Response
A material expeditor for the maintenance planning group has been authorized for 1982. This position will be responsible for monitor-r ing the timely procurement of parts to support maintenance o
activities.
The Manager-Plant Maintenance will conduct a monthly meeting to review all maintenance jobs that are on administrative held. The purpose of the monthly meeting is to determine the reason for the l
hold status and to coordinate the actions required by various departments to release the job for execution. A representative from Materials Management will attend each monthly meeting.
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TMI-l (1981)
Page 13 MAINTENANCE PROCEDURES l
PERFORMANCE OBJECTIVE: Ensure that adequate plant maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of L.
maintenance activities.
Finding Vendors' manuals are not always subjected to a technical review (M A.4-1) and approval process prior to being used for reference in mainte-nance activities. Only manual references used in safety-related procedures are subject to review and approval.
In addition, improved controls are needed to ensure that vendor manuals used
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in conjunction with maintenance are kept up-to-date.
a Recommendation Establish a system that ensures that all vendor manuals used for j
reference in conducting maintenance of plant systems and compo-I nents are current or are given appropriate engineering review and are certified adequate for the work to be performed.
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Response
Maintenance procedures are utilized in the conduct of maintenance activities. Key information such as torque values, critical clear-ances, etc. are normally addressed in the procedure.
Some maintenance procedures do, however, specifically reference the technical manual for accomplishment of the required task. In these cases, generic maintenance procedures will be revised to require engineering review and concurrence on the technical ade-J quacy of the manual for the task at hand. These procedures will be revised by June 1,1982.
Additionally, document control procedures are being improved.
These controls will differentiate between those technical manuals
^
that will be maintained up-to-date and those that will not. The applicable document control procedures will be revised by July 1, 1982.
1 PREVENTIVE M AINTENANCE (PM)
PERFORMANCE OBJECTIVE: Optimize equipment reliability and performance to enhance plant safety and availability.
2 7
Y Finding The condition of some systems and components reflects a need for 3
(M A.6-1) improvements in the preventive maintenance (PM) program. All PM activities are not being completed as scheduled, resulting in a
}
backlog. Some examples of inadequate cleaning, lubrication, and routine maintenance were noted. A number of regularly scheduled priority PMs have been deferred at least once.
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TMI-l (1081)
Page 14 Recommendation Upgrade the effectiveness of the preventive maintenance program by reevaluating the scope and depth of coverage.
Objectively establish the type and frequency of reventive maintenance actions required to achieve safe and tellat..e plant operation and then carry out the program as scheduled.
Response
A reevaluation of the preventive maintenance program for assess-ment of required periodic routine maintenance requirements to
']
ensure reliability based upon the equipment's purpose, function, and design will be completed by January 31, 1983. Increased staffing for preventive maintenance will be continued during 1982, and a review of the adequacy of resources available for executing the preventive maintenance program will be conducted in October 1982.
t
. 4 CONTROL OF MEASUREMENT AND TEST EQUIPMENT (M&TE)
L P*
PERFORMANCE OBJECTIVE: Control the use and calibration of measurement and test U
equipment to ensure the necessary accuracy for calibrated deview.
lJ Finding Measurement and test equipment is not always controlled in an (M A.7-1) efficient and effective manner.
Equipment is not permanently identified.
a.
b.
Equipment designated not ready for use should be marked with a tag showing information relating to the rejection.
The storage and issuance of measuring anu test equipment is c.
not fully in accordance with GPU Administrative Procedure 1022. For example, controlled equipment storage facilities contain non-controlled equipment. Controlled equipment is m
issued to any requestor rather than to designated technicians.
7]
The required inventory is not being maintained. A consider-able amount of instrument and control (l&C) equipment is inoperative.
d.
Improvements are needed in the control of out-of-service equipment. Better safeguards are needed to prevent using out-of-calibration equipment on plant instrumentation.
Recommendation Conduct a review of the control, storage, and issuance of mechanical, electrical, and I&C measurement and test equipment a
j to identify and correct existing problems. Action taken should include the following:
Establish a system of permanent equipment ioentification.
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a.
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TMI-1 (1981) l-Page 15 b.
Develop a tag for rejected equipment that specifies date, e,
l l reason, and identification of individual rejecting.
I c.
Segregate controlled (calibrated) test equipment to preclude the inadvertent use of non-controlled or not-ready-for-issue equipment.
1 d.
Designate individuals certified to use controlled measure-j ment and test equipment.
e.
Inventory and determine calibration status of all measure-ment and test equipment, and purge or augment the system as required.
Response
a.
GPU will establish a system to identify permanently meas-urement and test equipment by May 1,1982.
b.
Procedure AP1022 will be modified by April 1,1982 to
~
require that a tag be placed on rejected equipment (i.e.,
equipment in a hold status) that specifies date, reason, and identification of individual rejecting the equipment.
c.
Procedure AP1022 will be revised by April 1,1982 to require segregation of controlled (calibrated) test equipment to pre-clude the inadvertent use of non-controlled or not-ready-for-issue equipment.
m 1
d.
Technicians will be certified individually by supervision as to their qualification for using various specialized measurement and test equipment. Formalization of thir program will be incorporated into the training manual by July 1,1982.
J e.
A complete inventory, including verification of permanent identification and calibration status of all controlled meas-urement and test equipment will be completed for all equip-ment available for use. y December 31, 1981. An inventory y
and status of equipment not available for use will be com-a pleted by April 1,1982. AP1022 will be revised by April 1, j
1982 to require annual inventories and verification of status of measurement and test equipment.
]
s
'T Finding Improvements are needed in the prom;u for calibrating installed (M A.7-2) plant instrumentation. Calibration stickers indlea;3 that a sizeable number of instruments are overdue for calibration. Some stickers are unreadable. Some instruments have no sticker.
']
Recommendation Continue with the development and implementation of the new J
program for the calibration of installed plant instruments. This program should differentiate clearly instruments requiring calibra-tion at specific frequencies from those that do not.
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TMI-1 (1981)
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Page 16
Response
The company will continue with the detsopment and implementa-l tion of our program for the calibration of installed plant instru-ments. The program will be completed by October 1,1982 and will differentiate clearly instruments requiring calibration at specific frequencies from those that do not.
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TMI-l (1981) l' Page 17 RADIATION PROTECTION AND CHEMISTRY MANAGEMENT OF RADIOLOGICAL PROTECTION PERFORMANCE OBJECTIVE: Provide effective management of the radiological pro-tection program.
l
,.}
Finding Plant personnel do not always comply with radiological protectica (RC.1-1) procedures and requirements.
For example, personnel were ob-served on several occasions exiting the controlled area without monitoring themselves for contamination, and several occasions were noted where workers had moved radiation and contamination signs and barriers without authority.
Recommendation Emphasize adherence to good radiological protection practices by
~'
existing methods such as department meetings, training programs, and posted instructions.
Response
A minimum period during each training cycle of operations and maintenance personnel and a portion of department meetings will be dedicated to discussion of current radiological control policies and difficulties.
This practice will be started by December 1,1981.
Proper radiological procedures and practices will also continue to be emphasized in the general employee initial training and retraining programs.
Additionally, a monthly meeting will be conducted by the Director-TMI-1 with the Operations and Maintenance Director and the Manager-Radiological Controls to review implementation of effee-tive radiological controls.
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l.J rr Finding Modifications are needed in the Radiological Deficiency Report (RC.1-2)
(RDR) system to ensure that trends in personnel adherence to radiological protection procedures and requirements are brought to the attention of management.
Recommendation Expand the use of the RDR system, or develop and implement another system to identify personnel compliance problems in the area of rad:ological protection.
(,
Response
We agree that the plant is not fully utilizing its RDR system and lj will reemphasize the importance of this system via the IIP Awareness Committee and other plant information systems. Addi-l, tionally, a Radiological Control Engineer has been Wgned once a
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TMI-1 (1981)
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Page 18 day on a short-term basis to observe work taking place in radio-
-)
logical controlled areas. He will document personnel deficiencies via the RDR system. Effective immediately, Radiological Engi-neering has implemented trending of RDRs and Radiological Incident Reports (RIRs).
b d ll Finding Corrective actions resulting from Radiological Engineering investi-
)4 (RC.1-3) gations of radiological occurrences are not always comprehensive.
Recommendation Ensure that radiological engineering ir.vestigations of occurrences address all of the causes as well as the symptoms, in order to minimize probability of recurrence.
Response
We agree that corrective action is not always sufficient from Radiological Engineering investigations. A seminar training session will be developed for the Radiological Engineers to improve the RIR system.
This training will be completed by a
December 31,1981.
Finding A good practice was identified in that the plant periodically (RC.1-4) discusses radiological problems in a scheduled meeting led by maintenance department management, with representatives of radiological control and operations present.
!e J
e RADIOLOGICAL PROTECTION TRAINING PERFORMANCE OBJECTIVE: Ensure that personnel on the site have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.
Finding A goud practice was identified in that each person is required to (RC.2-1) demonstrate practical abilities, including the donning and removal of protective clothing and the proper use of personnel monitoring
}
devices, as part of general employee training.
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i TMI-1 (1981) i Page 19 Finding A good practice was noted as fellows: the training and retraining
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(RC.2-2) program for radiological protection personnel is comprehensive.
Foremen and technicians receive training one out of every six weeks.
i 1
.I EXTERNAL RADIATION EXPOSURE
]
PERFORMANCE OBJECTIVE: Minimize personnel external radiation exposure.
Finding Radiation exposure reduction efforts associated with routine work (RC.4-1) need improvement.
Radiological engineering inputs to reduce external exposure for such work were minimal. Few exposure goals were established for routine work during 1981.
Recommendation Expand the exposure reduction program to include preplanning and j
establishment of goals for routine radiological work.
Ensure radiological engineering considerations are addressed and imple-mented as required.
Response
GPU agrees that radiation exposure reduction efforts for routine work need to be upgraded. To provide improvement in this area, goals will be established for routine radir logical work and the 7
Man-rem Reduction Program will be revis rd by January 1982 to provide more feedback to the radiological workers and their supervisors.
Additionally, the ALARA engineers have been re-q quired on a daily basis to spend time in the field observing work,
'3 including low exposure rate work, which will facilitate better preplanning. The already established exposure goal for the Unit has been re-emphasized to all managers through the Unit Director's d
staff meetings.
w SOLID RADIOACTIVE WASTE PERFORMANCE OBJECTIVE: Minimize solid radioactive waste volumes.
Finding Several practices that would result in a reduction of solid radio-(RC.7-1) active waste volumes should be implemented or emphasized.
Recommendation Establish methods to segregate radioactive material from non-radioactive material in controlled areas. Minimize the amount of material taken into contaminated control areas, for example, by separating out shipping material.
Emphasize waste reduction P
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.I TMI-1 (1981)
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Page 20 methods in training programs. Continue with efforts to ensure that maximum compaction is achieved.
Response
On August 17,1981, a procedure was issued to formally control and m
minimize equipment and materials entering the controlled areas.
GPU will establish methods to segregate radioactive material from non-radioactive material in controlled areas by July 1,1982.
~
GPU's goal is to achieve an average compaction of 300 lbs. per drum by December 1,1981.
U By December 1,1981 both operations and maintenance cyclic training and general employee training programs will be restruc-tured to describe clearly and reemphasize waste reduction pro-
[L grams and efforts.
7 J
RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Minimize contamisted equipment and areas in the plant and minimize personnel contamination.
Finding A good practice was noted in that the plant has made a concerted (RC.9-1) effort to reduce the number of contaminated areas in the plant.
^
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i d a
l Finding Some containers of radioactive material ~ere not identified and I-(RC.9-2) labeled.
It is recognized that the plau * )lemented interim corrective action during the evaluation.
Recommendation Continue with efforts to implement a pr7 gram that ensures radio-active materials are identified and labeled and that they receive proper disposition.
ll-
Response
During the evaluation, items were identified and labeled. Subse-
~
quent to the evaluation, approved locations for storage of radioac-tive materials were established and will be implemented by November 15,1981.
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TMI-l (1981)
Page 21 Finding Severa. conditions were noted which have the potential for the Fl'.
(RC.9-3) spread of contamination and/or the unnecessary, exposure of per-sonnel. The recommendations below address these conditions.
~
Recommendation a.
Separate the solid radioactive waste compaction and interim storage area located in the auxiliary building from the laundry sorting area.
7 j
b.
Eliminate the potential spread of contamination by re-astablishing the plant's count room where radiological con-trols nave already been established.
I d
c.
Locate personnel monitoring stations in the plant to reduce the potential spread of contamination within the radio-logically controlled areas.
d.
Eliminate the use of toilet facilities within radiologically 7
controlled areas.
i"
Response
o Steps are in progress to provide better separation between the trash compactor room and the laundry sorting area. This ny project will be completed by November 1,1981.
b.
A facility study will be undertaken to address an improved
]
location of the GeLi count room, DeCon facility, and the j
RadCon lab. As an interim measure, GPU will establish a procedure to control the handling, labeling, and transporta-tion of radioactive samples to the GeLi count room in the I
Turbine Building. This procedure will place a limit on the level of radioactivity permitted to be taken to the count room. This procedure will be in effect by January 1982.
IJ c.
The approaches being considered include a high quality, sensitive, fast access portal monitor.
To provide better I
control of personnel exiting the contaminated areas, GPU will establish control points at the exits from contaminated areas. The control points will provide frisking equipment, when it is technically available.
d.
By October 1,1981, the toilet facilities within the radiologi-cal control areas will only be used as decon and dressing facilities.
M9
]
Finding Radiological controls need improvement in a few situations to (RC.9-4) prevent the possible release of radioactive material to the environ-ment. Situations noted were as folloas:
fn f
a.
Radioactive ion exchange rasins and liquids are being trans-p ferred by hose to a shed located outside of the auxiliary building.
T, TMI-l (1981)
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Page 22 j
b.
Several large doors at the boundary of potentially con-taminated areas and airborne radioactivity spaces are some-times left open to the environment.
The resin transfer operation should be modified to provide
~
Recommendation a.
permanent piping for the transfer system, improved control over the quantity of resin and water which is allowed to accumulate in the liner, and an improved cask venting system 7
j which is not subject to clogging. In addition, modifications to the existing shed to ensure that radioactive materials are not released inadvertently should consider the following:
d 1.
Increasing the physicalintegrity of the building.
2.
Installing a ventilation and high efficiency filtration sy~em.
3.
Providing overpressurization protection.
]
b.
Implement a program that ensures doors are kept closed at J
the boundaries of potentially contaminated and airborne radioactivity areas except in cases where thay are required
'9 to be opened for plant operations.
The program should require authorization by the Radiological Control Depart-
.j ment prior to opening any door that serves as a boundary.
Hard piping will be installed by December 15. 1981 to
Response
a.
connect the external pipe connections at the Auxiliary Building door with the liittman Building. The piping modifi-cations will ensure that hard piping exists from the Auxiliary Q]
Building to isolation valves located within the curbed area of the temporary solidification building. The building founda-tion pad and curb have been designed to meet the require-1 J
ments of NRC Regulatory Guide 1.143. The containers used in the Hittman solidification system are scaled and vented to the Auxiliary Building during filling and solidification operc-tions. The exhaust from the vent line is monitored by a J
portable air monitor.
A study is underway to develop and install a permanent solidification system. This permanent system will correct the remaining comments associated with the resin transfer operation. It is estimated that this system will be installed
~
by late 1983.
b.
By November 1, 1981, the Fuel llandling and Auxiliary Building doors will not be opened without Rad Con approval and establishment of a control point with frisk capabilities.
Prior to opening those doors, plant instrumentation will be monitored to ensure that airborne activity does not exceed specified limits.
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TMI-l (1981)
Page 23 CHEMISTRY l
PERFORMANCE OBJECTIVE: Ensure accurate measurement and effective control of
~'
chemistry parameters.
Finding Several problems were identific.d in the plant's chemistry program 7
(RC.10-1) in such areas as chemistry procedures; receipt inspection of bulk j
chemicals and chemical reagents; and controls for the issue or use of decontamination agents, sealants, and solvents.
In addition, improvements are needed in quality controls, trend analysis, and q
the technician training program.
g It is recognized that the plant had identified these problems prior to the evaluation in a plant quality assurance audit.
Recommendation Develop a comprehensive plan to correct the issues addressed in 7
the finding, including the timely correction of deficiencies that are j
easily corrected. Establish priorities and completion dates for the remaining items.
Response
The deficiencies noted in this finding have been previously identi-fied by GPU through both internal audits and external evaluations of the Chemistry Program. A major program began on May 18, 1981 to significantly upgrade the Chemistry Program. Key chem-istry procedures are scheduled to be completed and implemented by December 31, 1981. These procedures include administration, p
quality control / assurance, and the more important analytical pro-cedures. The remaining pcceedures will be prioritized and com-
[~
pleted during 1982. A training document has been written and approved and the initial and retraining Chemistry Technician Programs have been impleme.ded.
A periodic Requalification
- d Program for Chemistry Technicians will be implemented by August 1982.
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TMI-l (1981)
Page 24 4
m TECIINICAL SUPPORT l
1 ON-SITE TECIINICAL SUPPORT ORGANIZATION AND ADMINISTRATION
- 5 PERFOR',1 ANCE OBJECTIVE: Have a clearly defined on-site technical support organi-zation that is adequately staffed, assigns responsibility, and delegates adequate 1
authority for the accomplishment of required tasks.
a Finding A training program that includes plant systems training is needed (TS.1-1) for on-site technical s% port personnel. Some training is being accomplished in specific Ochnical areas, and preliminary planning
~
has been completed with regard to a more comprehensive training program.
Recommendation A training program that includes plant systems tr~..Ing should be implemented for technical support personnel. Thi program should
~
be implemented on a department level to ensure that uniform Ij training is provided to all technical areas of the plant engineering group.
Response
The response to the Finding TQ.2-1 will also fulfill this recom-mendation.
i NUCLEAR OPERATING EXPERIENCE EVALUATION PROGR AM PERFORM ANCE OBJECTIVE: Ensure industrywide and in-house opert ting experiences are evaluated and appropriate actions are taken to improve persoru el awareness and equipment reliability, w
p Finding Improvements are needed in the program to r' view in-house plant UJ (TS.3-1) incidents and operating experiences. Incidents are being identified and reviewed in accordanca with procedures AP-1029, Conduct of Operations, and EP-017, deview of Industry /GPU Operating Experience.
These procedures, however, provide only minimal guidance to control the uniformity and depth of the review process.
Procedure EP-029, Analysis of GPU Plant Transients, addresses
~
this area, but it is currently available only in draft form.
Recommendation Procedure revisions should be implemented to provide a more comprehensive program for the review of plant events. Procedures 7
in use at other facilities evaluated by INPO have been identified as j
good practices in this area and were discussed with GPU personnel.
These procedures should be reviewed with the objective of making
.)
additional improvements in the GPU program.
a 0
7,
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TMI-1 (1981)
,i Page 25
Response
The comprehensive procedure on the review of plant transients
'o (Technical Functions procedure EP-029), currently in draft form, will be implemented prior to the restart of TMI-1. The procedures in use at other facilities for this purpose, which were given to GPU by INPO, will be considered in finalizing EP-029. This procedure will ensure a complete review of plant events and, in addition to adding new requirements for event review, it consolidates some
- 1 presently existing plant procedures and practices for review of j
plant events.
'm Finding Improvements are needed in the review and follow-up of recom-(TS.3-2) mendations included in INPO/NSAC Significant Operating Experi-ence Reports (SOERs).
The SOERs issued through No. 81-12 f
,[
include 39 recommendations that are applicable to TMI-1. The status of action taken on 35 of these recommendations could not be determined.
J Recommendation Action should be taken to ensure that SOERs are processed in a timely manner. Also, a written response should be provided to l 1 INPO describing the action taken or planned with regard to the 35 J
pending recommendations.
p
Response
Completion of 27 of the 39 recommendations has been documented.
L Follow-up action is being taken for those items still outstanding and will be completed by November 1,1981. We are continuing to transmit the recommendations in SOERs to appropriate portions of the organization, and to track them as open action items until completed. In addition, we will implement by November 1,1981 an automatic reminder system to shorten the response time. A report j
on the status of SOER recommendations applicable to TMI-1 will L
be provided in GPU's follow-up responses six months from the date of this report.
I PLANT MODIFICATIONS PERFORMANCE OBJECTIVE: Provide a program to implement plant modifications in a timely manner while maintaining the quality of plant systems and components.
Finding Plant operators are not able readily to determine some system (TS.4-1) configurations with available drawings.
The current system of revising drawings and maintaining accurate information in the control room is adequate. However, systems that w :re :r.cdified i
Tl' 7
TMI-l (1981)
Par..
prior to the new drawing control procedure have no* nad their
~
drawings updated.
In order to correct tilis problun, GPU has initiated a program to update these drawings prior to plant startup.
Recommendation The program to update orawings used by operators should be continued to completion.
7
Response
GPU will have baseline engineering drawings essential for plant j
operations updated and in the control room prior to restart.
Review of all old modification packages, which predated the new control procedures, to ensure that previous modifications are prop-erly reflected on the drawings will be completed by the end of 1982.
e Finding Improved controls are needed to ensure piping system mechanical (TS.4-2) stresses are not changed without appropriate engineering review.
The use of lead blankets around system pipes for shielding purposes
- .)
should receive a techr.ical review prior to each installation. An evaluation is in prgress by GPU Technical Functions personnel to
]
determine the effects on systems that currently have add-on lead shielding in place.
Recommendation Complete the engineering evaluation of lead blankets currently in place and develop a program or guidelines to control the future p!acement of temporary shielding on plant piping systems and equipment.
y U
Response
This problem had been identified by the plant staff earlier this year and engineering guidelines are being developed to control the placement of lead shielding on or in the vicinity of piping systems a
and equipment. These guidelines will be implemented by April 1, f
1982. To correct the immediate problem, a radiation survey of the areas where lead blankets were installed was conducted.
As a
{p result, a large amount of the temporary shielding was removed due i'
to reduced radiation levels because of the long period the plant has been shutdown. An engineering evaluation of lead blankets still installed will be completed and appropriate modifications ms 'e C
before restart of the unit.
Finding Improved controls are needed to ensure a proper technical review (TS.4-3) prior to the use of jumpers, lifted leads, and temporary mechanical l
modifications.
The administrative procedure for the bypass of
'J safety functions and jumper control, AP-1013, requires that a safety evaluation be completed; however, it allows the evaluation to be performed by shift supervisors without involvement of Plant t
Engineering or Technical Functions personnel.
1 1-TMI-l (1981)
F Page 27 Recommendation A qualifie:1 individual who is not in the operations department c
j should be involved in the review process for authorization of proposed jumpers and other temporary modifications. A method of achieving this would be to require concurrence in the safety 7
evaluation by either a lead engineer in the Plant Engineering Group l
or the Shift Technical Advisor.
Response
Procedures will be implemented by January 1,1982 requiring q
concurrence frem Plant Engineering or the Shift Technical Advisor
^j on the use of jumpers. 'ifted leads, and temporary mechanical modifications prior to their installation.
i
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Finding The administrative procedure for engineering change modifications (TS.4-4)
(AP-1043) should require operator training prior to placing modi-fled systems into service. It is recognized that a training program is currently in progress to instruct plant operators on modifications that will be installed prior to unit startup. There is, however, no procedural assurance that this type of training will continue for
.,a modifications implemented after the current outage.
Recommendation Administrative procedures should be revised to require that train-y ing be completed prior to turnover of a modified system to operations.
l"
Response
As noted, operators are currently receiving training on plant
~ " " ' " ' ' " ' ' " " " "' "'""" "'" '
The formal requirement for operator training on modifications will L".!
be incorporated into AP 1043 by January 1,1982.
a 3j' ON-SITE REACTOR ENGINEERING PERFORMANCE OBJECTIVE: Optimize nuclear reactor operations without compro-M mising design or safety limits, and control nuclear fuel handling activities to ensure safety of personnel and equipment.
p b'
Finding The following good practice was noted: The Nuclear Engineering (TS.5-1)
Group is supported by an on-site computer applications group with exceptional technical capabilities. GPU personnel are responsible for a major reconfiguration of the plant process computer system.
Operator interfaces with the computer system are being designed
[
taking human factor considerations into account.
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TMI-1 (1981)
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Page 23 ORGANIZATION AND ADMINISTRATION q
I MANPOWER RESOURCES PERFORMANCE OBJECTIVE: Ensure that qualified individuals are available to fill all job positions supporting plant safety and reliability,
'j Finding Written qualification requirements are current for supervisory and (OA.3-1) technical positions. For positions below first-line supervisors, the
-}
qualification requirements need updating.
Recommendation Update and maintain current job specifications for appropriate
~
positions below first-line supervisors.
INPO is coordinating an industrywide job analysis project for certain operator, mainte-nance, and technician positions.
GPU may wish to utilize the results in defining qualification requirements for applicable TMI positions.
Response
GPU has been involved with EEI efforts on validation of job requirements for power plant personnel. GPU will be using that i,
effort and the referenced INPO-led effort in the development of new job specifications for non-exempt personnel. The revised job specifications and a procedure to maintai,1 these current are sched-C uled to be completed by December 1982.
1 t
a ADMINISTRATIVE CONTROLS PERFORMANCE OBJECTIVE: Provide well-defined, organized, and effective adminis-trative controls to direct the tasks, responsibilities, and practices within the organiza-tion to meet the specified mission, goals, and objectives.
l M.
Finding Several plant programs are not achieving desired results. Examples (OA.4-1) of programs where implementation needs improvement include the
,,l control of unauthorized notes and drawings attached to local panels I
l-throughout the plant, enforcement of radiation protection rules, and implementation of the tagout procedures.
Recommendation A plan should be established to periodically monitor programs to evahate whether the programs, as implemented, are achieving the results desired by management.
d
Response
GPU will define by December 1981, and implement by July 1982, a i
plan for periodic monitoring of the effectiveness of the imnlemen-l]
tation of plant management programs.
1.
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II-F TMI-1 (1981)
Page 29 MANAGEMENT QUALITY PROGRAMS I
PERFORMANCE OBJECTIVE: Provide management with accurate indication of the extent of adherence to policies, administrative controls, c(des, regulations, and
]
effectiveness in meeting plant mission, goals, and objectives.
1 q
Finding Improvement is needed in the correction and clearing of long-term (OA.5-1)
QA deficiencies.
Recent management attention to this area is r
resulting in a reduction of the backlog.
Recommendation Management attention to correcting long-term QA deficiencies W
should continue end be maintained on a continuing basis.
1
Response
Management will continue to focus attention on correcting long-I term QA deficiencies, and the effectiveness of this effort will be included in the plan implemented in response to finding OA.4-1.
J SURVEILLANCE PROGRAM PERFORMANCE OBJECTIVE: Provide surveillance programs to accomplish coordi-nated monitoring, inspection, and testing to ensure sefe, reliable operation of plant equipment and facilities.
Finding No organization or person is assigned overall responsibility for (OA.6-1) management of the surveillance program. The program may not accurately reflect present requirements as it has been sometime since the scope and depth of the program was evaluated. It is
~
understood that plant management has recognized this concern and is initiating corrective action, Recommendation Specifically assign the responsibility for overall management of the y
surveillance program. Formally riefine the program, assign respon-lj sibility for managing, and include features that will ensure a con-tinued accurate, up-to-date implementation.
Response
During the past few months a complete review of the technical specifications was conducted to itemize all required surveillances.
]
The resulting list of technical specification surveillance require-ments is being compared to our computerized surveillance program a
to ensure full coverage and proper scheduling. GPU acknowledges the need for specific assignment for overall management responsi-i bility of the surveillance program and will accomplish same by J
December 1,1981. Appropriate procedures will be modified to l
reflect this assignment at the same time.
7 i
3 TMI-1 (1981) r APPENDIX
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Page1 APPENDIX A r
r I.
Performance Objectives Reviewed TRAINING AND QUALIFICATION TQ.1 Training Organization Provide a clearly defined training organization staffed with quali-3 fied personnel capable of accomplishing all assigned training tasks.
TQ.2 Training Administration Ensure that activities necessary to initiate and control personnel qualification programs are accomplished in a well-defined, coordi-j nated, and effective manner.
TQ.3 Training Facilities and Equipment 7
Provide the training facilities, equipment, and materials for devel-opment and evaluation of knowledge and skills needed by nuclear i
plant personnel.
d TQ.4 Non-Licensed Operator Training Develop and maintain the skills and knowledge necessary for non-licensed operators to perform their assigned job functions.
TQ.5 Licensed Operator Training Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.
W TQ.6 Licensed Operator Requalification Training p(
Maintain the skills and knowledge necessary for licensed operators to perform their assigned job functions.
TQ.7 Shift Technical Advisor Training Develop and maintain the skills and knowledge necessary for Shift f~
Technical Advisors (STA) to perform their assigned job functions.
[
TQ.8 Maintenance Personnel Training Develop and maintain the skills and knowledge necessary for main-tenance personnel to perform their assigned job functions.
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TMI-l (1981)
APPENDIX J
Page 2 OPERATIONS OP.1 Operations Organization and Administrat!on Provide a clearly defined operations organization that is ade-quately staffed, assigns responsibilities, and delegates adequate
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authority for the accomplishment of required tasks.
a O P.2 Operations Facilities and Equipment
~1 Provide plant facilities and equipment that are perated and main-tained at a level to support safe and efficient c seration.
OP.3 Conduct of Shift Operations Ensure that shift operations are conducted in a safe and reliable manner.
OP.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of written procedures.
OP.5 Plant Status Controls J
Maintain plant status in a condition that ensures equipment and p
system availability as necessary for safe and reliable plant opera-L tions at all times.
OP.6 Shift Turnover Ensure a continuous and correct understanding of plant conditions at all shift operating positions through proper shift turnover.
.L O P.7 Tagout Practices Protect personnel and plant equipment by implementing effective T
j tagout practices.
f MAINTENANCE
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MA.1 Maintenance Organization and Administration Provide a clearly defined maintenance organization that is ade-quately staffed, assigns responsibilities, and delegates adequate authority for the accomplishment of required tasks.
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M A.2 Maintenance Facilities and Equipment ij" Support the performance of maintenance activities t y providing adequate facilities and equipment.
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TMI-l (1981)
E APPENDIX
[*
Page 3 M A.3 Work Control System w
Provide an administrative control system within which equipment problems can be identified and reported, and setely and efficiently dispositioned and doc _mented.
M A.4 Maintenance Procedures 1
"J Ensure that adequate plant maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of maintenance activities.
4 M A.5 Maintenance History Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvements in equip-c ment performance.
M A.6 Preventive Maintenance (PM)
Optimize equipment reliability and performance to enhance plant safety and availability.
M A.7 Control of Measurement and Test Equipment (M&TE)
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Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.
M A.8 Control of Special Processes Ensure that the control and performance of special processes yields quality results, m
RADIATION PROTECTION AND CHEMISTRY RC.1 Management of Radiological Protection y
b Provide effective management of the radiological protection program.
A RC.2 Radiological Protection Training
~
Ensure that personnel on the site have the knowledge and practical abilities necessary to effectively implement radiological protection y
practices associated with their work.
RC.3 Personnel Dosimetry a
Accurately determine and record radiation exposures.
1, TMI-1 (1981)
APPENDlX
~
Page 4 RC.4 External Radiation Exposure Minimize personnel external radiation exposure.
RC.5 Internal Radiation Exposure Minimize internal exposure due to radioactivity associated with the 5
plant.
RC.6 Radioactive Effluents Minimize releases of radioactive effluents to the environment.
RC.7 Sclid Radioactive Waste Minimize solid radioactive waste volumes.
RC.8 Transportation of Radioactive Material Meet the requirements for transportation of radioactive material.
RC.9 Radioactive Contamination Control s
Minimize contaminated equipment and areas in the plant and minimize personnel contamination.
a RC.10 Chemistry Ensure accurate measueement and effective control of chemistry parameters.
TECliNIC AL SUPPORT i
TS.1 On-site Technical Support Organization and Administration llave a clearly defined on-site technical support organization that gr y~,
is adequately staffed, assigns responsibility, and delegates i
adequate authority for the accomplishment of required tasks.
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TS.2 Plant Efficiency and Reliability Optimize plant thermal efficiency and reliability.
TS.3 Nuclear Operating Experience Evaluation Program Ensure industrywide and in-house operating experiences are eval-uated and appropriate actions are taken to improve personnel i
awareness and equipment reliability.
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s TMI-1 (1981) 9 APPENDIX Page5 r
s.
TS.4 Plant Modifications 2
i Provide a program to implement plant modifications in a timely d
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manner while maintaining the quality of plant systems and compo-nents.
t O
TS.5 On-site Reactor Engineering Optimize nuclear reactor operations without compromising design or safety limits and control nuclear fuel handling activities to ensure safety of personnel and equipment.
ORGANIZATION AND ADMINISTRATION OA.1 Organizational Objectives v
Estabiish mission, goals, and objectives for the organizational units that improve plant activities or maintain them'at high levels of safety and reliability, and establish the process to achieve' the mission, goals, and objectives.
O A.2 Organizational Structure Provide an organizational structure that supports the effective management of nuclear power plant operation.
9
/
OA.3 Manpower Resources Ensure that qualified individuals are available to fill all job positions supporting plant safety and reliability.
OA.4 Administrative Controls Provide well-defined, organized, and effective a ministrative con-r trols to direct the tasks, responsibilities, and practices within the organization to meet the specified mission, goals, and objectives.
y OA.5 Management Quality Programs Provide management with accurate indication of the extent of adherence to policies, administrative controls, codes, regulations, and effectiveness in meeting plant mission, goals, and objectives.
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OA.6 Surveillance Program Provice surveillance programs to accomplish coordinated moni-toring, inspection, and testing to ensure safe, reliable operation of plant equipment and facilities.
1 OA.7 Industrial Safety A.
Provide an orderly working environment in which station personnel may carry out their work activities safely.
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