ML20035H638

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Nuclear Safety & Compliance Committee Semiannual Rept 18, Oct 1992-Mar 1993
ML20035H638
Person / Time
Site: Oyster Creek, Crane
Issue date: 04/15/1993
From: Laney R, Trost C, Wilson W
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20035H637 List:
References
NUDOCS 9305060136
Download: ML20035H638 (17)


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NUCLEAR SAFETY AND COMPLIANCE COMMITTEE SEMIANNUAL REPORT NUMBER 18 OCTOBER 1, 1992 THROUGH MARCH 31, 1993 i

APRIL 15,-1993 1

[

l ADM C. A.

H. TROST

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, cu%

ROBERT V.

LANEY I

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LAWRENCE'L. hup HREYSV

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,6 EILLIAM A.

WILSON.

9305060136 930429-PDR ADOCK 05000219 R

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e CONTENTS 1.0

SUMMARY

2.0 EVALUATION OF SAFETY AND COMPLIANCE 2.1 MANAGEMENT ATTITUDE TOWARD SAFETY 2.2 OPERATIONS 2.3 MAINTENANCE / MATERIEL CONDITION 2.4 TECHNICAL SUPPORT 2.5 RADIOLOGICAL AND ENVIRONMENTAL CONTROLS 2.6 TRAINING 2.7 EMERGENCY PREPAREDNESS 2.8 PROCEDURES 3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL 3.2 COMMITTEE ACTIVITIES 3.3 STAFF ACTIVITIES EXHIBIT 1 NSCC STAFF ACTIVITIES /INFORMATION SOURCES EXHIBIT 2 PERSONS INTERVIEWED / CONTACTED DURING REPORT PERIOD i

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1.0

SUMMARY

Safety and compliance at the Oyster Creek, Three Mile Island i

(TMI-1 and TMI-2) and Saxton facilities of the GPU Nuclear Corporation (GPUN) were the object of independent evaluations by the Nuclear Safety and Compliance Committee (NSCC) of the GPUN

-Board of Directors and by the NSCC Staff from October 1, 1992 to l

March 31, 1993.

These evaluations focused on operator performance, procedure utilization, and maintenance activities as they relate to compliance and safety.

The Committee believes that during this period all facilities were operated safely and, with the exceptions noted herein, in compliance with relevant i

requirements and good practices.

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The Committee also compared performance in 1992 with previous years and concluded the overall level of safety provided by the corporation had increased.

An increase in the level of safety at Oyster Creek and a consistent level at TMI-1 provided the basis for this conclusion.

A strong commitment to nuclear safety was evident in the operation of GPUN facilities.

During the 14R Refueling Outage, l

Oyster Creek effectively implemented a shutdown risk management program.

Evaluations of a scram at TMI-1 and an~ event involving l

inadequate shutdown cooling at Oyster Creek resulted in

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commitments to strengthen management review of proposed deviations from normal procedures or operating lineups.

See pages 3, 4,

and 8.

t Operating performance indicators were excellent at TMI-1 and Oyster Creek.

Plant operators generally displayed proficiency during normal operation and transients, although there were some events which indicated a need for improved awareness of Technical Specifications requirements, general operating principles and personnel safety.

See pages 4 and 5.

The 14R Refueling Outage at Oyster Creek was completed successfully due to disciplined reliance on a fairly l

comprehensive integrated schedule and the cooperative efforts of all contributing organizations.

Fuel handling evolutions were error free.

See pages 5 and 6.

Materiel condition of both plants is generally good.

The 14R R

Refueling Outage work scope included several modifications to improve-the' reliability and safety of Oyster Creek.

Establishment of a group of System Engineers at both sites and a Component Maintenance team at Oyster Creek should provide greater focus on improving plant reliability.

See pages 5, 6,

and 7.

Human performance deficiencies in maintenance' activities, particularly at Oyster Creek, continue to occur.

Management efforts to improve performance should continue.

See page 5.

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Both plants met or exceeded virtually all radiological goals for 1992.

Oyster Creek achieved the majority of its goals for the 14R Refueling Outage.

Implementation of new work practices for radiation workers' respiratory protection warrants close attention in job planning.

See page 7.

Lessons learned from evaluation of an intrusion event at TMI-l should be factored into security and emergency response plans at both sites.

See page 8.

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2.0 EVALUATION OF SAFETY AND COMPLIANCE The following is an evaluation of GPUN performance from October 1, 1992 to March 31, 1993.

The report topics do not necessarily correspond to GPUN's organizational units.

Statements largely pertain to conditions at the time of the evaluation.

Corrective actions of which the Committee is aware are also noted.

All items have been discussed by the Committee l

with its Staff and, if appropriate, have been reported by the Committee to the GPUN Board of Directors and Corporate Management at regular monthly meetings.

Additionally, the Committee has reviewed the GPUN responses to its previous report (No. 17).

Where pertinent, these responses j

are commented on in this report.

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l 2.1 MANAGEMENT ATTITUDE TOWARD SAFETY l

GPUN continued to display a strong commitment to nuclear safety in the operation and management of its facilities.

Oyster Creek proceduralized and effectively implemented a l

shutdown risk management program during the 14R Refueling Outage.

l This program ensured all plant configurations provided redundancy l

of vital safety functions.

Plans to perform discretionary maintenance on components during operation which would l

voluntarily invoke a Technical Specification Limiting Condition for Operation (LCO), were scrutinized and, in some cases, l

rejected.

The checklist used in these reviews is being incorporated into an Operations Standard.

Commitment to minimizing operator challenges was evidenced in accepting a power coastdown prior to the 14R Refueling Outage rather than perform sensitive control rod adjustments, and in deferring final installation of a digital feedwater control system until equipment reliability is confirmed and operators receive appropriate training.

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In its previous report (No. 17), the NSCC expressed concern that an unfounded sense of urgency led to the September scram at TMI-1.

GPUN's review of the event concluded this was not the primary cause; rather, reliance on successful isolation of the system in the past had resulted in the failure to select the least risk alternative.

Managers have been instructed to obtain proper staff input and to ensure a detailed review of the risks associated with each alternative is completed prior to approving similar evolutions in the future.

The NSCC agrees tighter controls are warranted, and cautions against the overconfidence and complacency that may result from long periods of successful operation.

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Similarly, inadequate technical reviews of a temporary procedure change preceded an event at Oyster Creek in which reactor coolant temperature exceeded Technical Specification requirements.

Investigation of the event revealed that, while intended to be expeditious, this method of changing plant procedures often failed to achieve the level of technical review expected for procedure revisions.

Tighter control of temporary changes was implemented as an interim measure, while an evaluation of the overall process is conducted.

The Committee noted the temporary procedure change process at THI-l includes more stringent controls.

At both sites, there was extensive discussion of some Technical Specifications requirements (e.g.,

fire watch requirements at TMI-1, and reactor manual control operability at Oyster Creek) which has resulted in better guidance and has minimized impact on

-plant operation.

The process for evaluating Potential Safety Concerns (PSC) at Oyster Creek has not always provided prompt resolution.

A proposal to cancel the process was appropriately rejected; instead, an improved procedure revision provides a mechanism for screening inputs and redirecting them to other corrective action programs, when appropriate.

Concerns which require extensive evaluation will still be handled by the PSC process.

2.2 OPERATIONS TMI-1 operated continuously throughout the period, except for a three-day outage following a scram in March.

Oyster Creek operated continuously outside the 14R Refueling Outage.

Performance indicators, such as capacity factor, have been excellent at both plants.

TMI-1 operators demonstrated proficiency in response to the scram and to other events, such as Integrated Control System transients.

Likewise, plant shutdown, refueling operations, and the startup power ascension program were well handled.at Oyster Creek.

There were, however, several events which, while not resulting in a significant nuclear safety hazard, indicated a lack of awareness of Technical Specifications or general operating principles -- e.g., bypassing of the Decay Heat Closed Cooling Heat Exchangers at TMI-1; exceeding reactor temperature limits and changing mode switch without minimum neutron monitoring channels available at Oyster Creek.

In some cases, inattention to operating conditions resulted in equipment damage at Oyster Creek, such as running a CRD pump and a dilution pump with inadequate lubrication.

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On one occasion at Oyster Creek, two men inspecting a condenser were sprayed with water when operators restored the hotwell makeup system to service before ensuring the men had exited the condenser.

Although there was no physical injury or contamination, the operators displayed poor judgement and l

l inadequate effort to ensure personnel safety.

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2.3 MAINTENANCE / MATERIEL CONDITION l

The 14R Refueling Outage at Oyster Creek was highly successful.

Early completion of engineering and planning, development of a l

good integrated schedule and insistence on adherence to it, a strong outage management organization, and a cooperative attitude l

by all participants were evident contributors to the success.

Most of the planned work scope plus a significant amount of emergent work was completed within the planned outage duration.

Notwithstanding the successful completion of most outage work, there is still room for improvement in workmanship and work practices at' Oyster Creek.

On two occasions, intake mobile

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cranes were misoperated.

The first resulted in collapse of the i

crane boom; the second almost damaged a circulating water pump.

I The Reactor Building crane suffered cable damage due to improper rigging for the lifting of floor plugs.

Rework was required due to installation of an uncertified component in a reactor level indicator, improper alignment of a Reactor Building closed cooling water pump, damage to a dilution pump oil cooler, and installation of incorrectly sized orifices in the steam jet air ejector drain system.

Equipment control deficiencies resulted in overtorquing an isolation condenser valve, leakage from control rod accumulator valves, and a shock to an electrician working on a transformer control circuit.

At TMI-1, a valve misalignment following a completed surveillance of the Reactor Building air monitor resulted in a Technical Specification violation.

Efforts to reduce such errors, such as those described in the response to NSCC Semiannual Report No. 17, should be vigorously pursued.

Work was performed during 14R to correct many long-standing materiel deficiencies and add modifications to improve safety.

These include completion of the drywell corrosion-abatement project; installation of a hardened vent header from the~drywell to the plant stack; modification of Containment Spray and Core i

l Spray system controls;-tie-in of the combustion turbines to provide electrical system reliability during station blackout; 1

and modifications to reactor vessel and fuel zone level L

indication.

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The NSCC noted the establishment of a Component Maintenance Team (CMT) to upgrade the preventive maintenance program at Oyster Creek.

This CMT is still in an incipient stage (staffing is 5

almost complete and short term goals have been established).

Its efforts will be monitored to determine its contribution to improving the reliability of plant equipment.

TMI-1 experienced some equipment reliability problems during this period.

The scram in March was caused by failure of a reactor protection system component.

Problems with the Integrated Control System caused minor plant disturbances on at least two occasions.

Build-up of clams in the circulating water system required significant power reductions on two occasions to clean condenser tubes.

Overall, the materiel condition of the plant is good, owing to aggressive and effective corrective and' preventive maintenance programs.

The TMI-2 reactor building is now in Post Defueling Monitored Storage.(PDMS), and evaporation of the accident generated water continues at a satisfactory rate.

Except for the Containment Building,. dismantling of the Saxton facility is virtually complete.

2.4 TECHNICAL SUPPORT Technical Functions supported the 14R Outage by assigning a large group of project engineers to the. Oyster Creek site.

This move made close monitoring of modifications easier and eliminated communication and travel delays which had occurred'in past outages.

At TMI-1, planning.for the 10R Outage appears to be very thorough.

Oyster Creek Plant Engineering generally provided good outage support, although indecisiveness led to occasional delays, such as occurred during replacement of electrical-cables for the recirculation pump motor-generators.

Better planning and foresight would probably have eliminated the last-minute requests for waivers of compliance on wetted bolt inspection and

-Condensate Transfer System hydrostatic testing.

At TMI the. plant engineering backlog remains low and plant support is timely.

Oyster. Creek Core Engineering worked aggressively to identify leaking fuel assemblies by developing a flux tilt procedure at l

the end of Cycle 13 and coordinating fuel sipping'during the refueling outage.

During the end-of-cycle coastdown, Core i

Engineering provided good direction to maximize power output.

J They also prepared' error-free fuel move sheets for-refueling and developed a computer program to track fuel movements.

The computer' heat balance-calculation at' Oyster Creek received much attention due to inaccuracies in the measurement of feedwater flow.

In one instance. incorrect information was i

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review.

However, this did not affect operation because the resulting unexpected indication was immediately questioned by the operators and the error was corrected.

A modification to improve accuracy by replacing individual loop feedwater flow instruments with a single total flow element was completed in March._

The organization change to establish a System Engineer group at Oyster Creek became effective in March.

Both sites now have such groups.

This is expected to result in improved technical ~ support and recommendations for materiel improvement.

The.NSCC will monitor their progress.

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The NSCC notes that the system to be used for above-grcund spent

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fuel storage at Oyster Creek has been selected.

Installation is expected to be completed in time to support the projected need l

for additional storage in 1996.

An analysis of the structural integrity of the existing spent fuel pool was presented in a report. issued.in June 1992.

The NSCC Staff reviewed this report and held discussions with cognizant Technical Functions personnel.

Concerns regarding the validity of assumptions, i

correlation of field observations with predicted cracks, and the feasibility of plans to-respondcto transients still.need to be j

resolved.

2.5 RADIOLOGICAL AND ENVIRONMENTAL CONTROLS Both plants ended 1992 with excellent results in meeting radiological goals.

Cumulative' exposure for the 14R Outage.was less than originally projected, even with the expanded work scope.

i At Oyster Creek during the outage several internal and external contaminations occurred on jobs,.such as, grinding and polishing of the turbine blade and valve stem work.

The resultant contaminations were caused, in some cases, by inadequate job planning by various work planning groups.

These_ types of jobs should warrant additional care in future job planning._ These contaminations also reflect an attempt to implement the radiological practice of having the option to reduce respirator usage'while accepting-small internal radionuclide. uptakes.

This process is designed to reduce _the radiation workers'~ total internal and: external exposure.

Plant monitoring and inspection reports. continue to identify examples of improper radiological work practices.

Although plant management continues to stress' good work practices, it appears that more attention is needed at the supervisory level.

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The Oyster Creek Director has made a concerted effort to heighten awareness and stress the need to reduce the volume of radioactive waste.

2.6 TRAINING The Training Departments at each site continued to provide good support of plant needs.

l Following successful completion of on-site testing, the Oyster Creek simulator was placed in service for operator training in February.

Its initial performance has been good, and its use should enhance the proficiency of plant operators.

2.7 EMERGENCY PREPAREDNESS TMI declared a Site Area Emergency on February 7 when an intruder drove a car through a gate and then through a door to the Turbine Building.

He was located and apprehended approximately four hours later.

Actions by the security force and the Emergency Response Organization were deemed appropriate by the NRC and other agencies.

GPUN conducted a multidiscipline internal review of the incident which produced several recommendations for improving security at both sites.

Some measures to preclude similar events have already been implemented.

Oyster Creek successfully conducted its annual Emergency Plan drill in October.

An Unusual Event was appropriately declared following a loss of secondary containment in November.

2.8 PROCEDURES As discussed in 2.1 above, the process for revising procedures and its implementation are being reviewed at Oyster Creek.

This review is a result of the January event in which reactor vessel temperature limits were exceeded.

Although the immediate cause was inadequate technical review of a temporary change, it appears that, in general, the quality of review of temporary changes was less than desired._ There were also some instances of inadequate review cf regular procedure revisions.

For example, a sudden plant depressurization during the Reactor Coolant System hydrostatic test and a scram during restoration from the Primary Containment Integrated Leak Rate Test were caused by errors in procedures that had been extensively reviewed.

There has been little improvement in reducing the time to process changes and in reducing the backlog of biennial reviews at Oyster Creek.

On one occasion a temporary procedure change was not reviewed within 14 days, as required by Technical Specifications.

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One area receiving significant attention is the Oyster Creek

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Emergency Operating Procedures (EOP).

The program for administering the EOPs was previously identified by the NRC as being weak.

The program was strengthened and aggressive work by a team, which included Operations, Engineering and Training personnel, has resulted in issuance of revised flow charts and l

support procedures.

Use of the Oyster Creek simulator-l facilitated validation and verification of the new procedures.

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3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL Membership on the NSCC increased to four when Mr. William Wilson was elected to the Board of Directors in February.

The NSCC guides the NSCC Staff's investigations and approves its schedules and expenditures.

Staff activities involve both routine monitoring and special reviews.

Routine monitoring covers all functional areas at each site and at corporate headquarters.

A long-range schedule of monitoring activities is developed every 6 months, and it is revised monthly to reflect i

Staff activities and Committee requests, or as plant events or industry occurrences dictate.

The Committee reviews various sources of information noted in Exhibit 1.

On occasion these reviews result in special tasks for the Staff.

3.2 COMMITTEE ACTIVITIES In addition to the activities described above, the Committee meets monthly with the GPUN Board of Directors and reports on any items of significance with respect to safety or compliance.

Questions or concerns arising between board meetings may be directed to the Chairman of the Board or the President of GPUN.

The NSCC Staff also holds periodic meetings with GPUN executives to present overall observations on plant activities, that is, observations not limited to safety and compliance.

A TMI-1 observations meeting was held in October.

The Committee meets with members of the Staff prior to the monthly meetings of the Board of Directors.

Between meetings, there is a regularly scheduled conference call to discuss the status of each plant.

The monthly meetings frequently include presentations by, and discussions with, selected GPUN personnel on subjects of interest to the Committee.

During this report period, discussions were held with the Vice-President / Director, Oyster Creek; Vice-President / Director, TMI-1; Vice-President / Director, TMI-2 ; Oyster Creek Operations and Maintenance Director; TMI-2 Site Director; TMI-2 Radiological Controls Field Operations Manager; Oyster Creek Component Maintenance Team Manager; TMI-1 Environmental i

Program Manager; and the TMI-1 Tool Room Supervisor.

J Committee members toured the TMI-1 and Oyster Creek sites in conjunction with meetings of the Board of Directors and General l

Office Review Boards (GORB).

They also toured the Oyster Creek simulator facility.

Admiral Trost and Mr. Laney each attended one GORB meeting at Oyster Creek.

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4 3.3 STAFF ACTIVITIES The Staff, which is permanently stationed at the TMI-and Oyster Creek plants, gathers information on plant activities from_many sources: plant tours; the monitoring of activities; attendance at meetings; interviews with GPUN personnel; and reviews of reports, i

correspondence, and other documents.

Plant operations and-maintenance activities ~ receive primary attention, but support functions are also evaluated..

The NSCC Staff has expertise in management, operations,-maintenance, engineering, licensing, l

training, radiological controls, environmental controls, quality-assurance, and emergency preparedness.

One additional GPUN person was added to the Oyster Creek Staff in March.

Another will be added to the TMI Staff in April.

The Staff at each site will then be. comprised of one contractor and three GPUN personnel (two professional and one administrative).

Evaluations during this report period concentrated on the areas and activities described in Section 2.0.

Information sources to which the Staff avails itself and a list of activities and information sources used in the Staff evaluations'is presented as-Exhibit 1.

GPUN personnel contacted during this period are indicated in Exhibit 2.

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EXHIBIT 1 NSCC STAFF ACTIVITIES /INFORMATION SOURCES (both TMI-1 and OC unless otherwise noted)

PLANT TOURS General walkthroughs/ housekeeping observations off-Shift tours Control Room observations i

Maintenance observations Surveillance Test observations Radwaste Handling observations Emergency Drill observations MEETINGS Production Planning meetings Plant Review Group (PRG) meetings Daily Plant Status meetings Outage Planning meetings NRC Entrance / Exit meetings INPO Training Evaluations

  • GORB meetings Post-Trip Review Group meetings Critiques Radiological Awareness Committee meetings (OC)

Project Review meetings (OC)

Department /Section Staff meetings (OC)

DOCUMENT REVIEW GPUN Sources

  • Plant Incident Reports (TMI-1)

Plant Review Group meeting minutes

  • Deviation Reports (OC)
  • Licensee Event Reports
  • Incident Critiques Station Action Item Tracking System
  • Licensing Correspondence
  • Significant Events Reports
  • Off-Shift Tour Reports
  • Denotes information reviewed by the NSCC 12

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EXHIBIT 1 (Continued)

QA Audit Reports

  • QA Assessment Reports (Monthly and Annual)
  • QA Quarterly Trend Reports Operations QA Monitoring Reports STA Daily Reports Operations Night Order Book Log Books (Operations, STA, Chemistry, Maintenance,.Radwaste)
  • Independent Safety Review Annual Safety Assessment Report Design Basis Documents Shift Turnover Forms MNCRs, QDRs Radiation Awareness Reports
  • Post-Trip Review Group Reports
  • Transient Assessment Reports Maintenance Job Order Packages GPUN Administrative Policies and Procedures Station Procedures (e.g., Admin., Operations, Maintenance)

Division Procedures (e.g.,

Rad Con, Tech. Functions)

Operations QA Plan Technical Specifications Training System Descriptions Training Lesson Plans Plant Drawings

  • IOSRG Evaluation Reports
  • GORB Meeting reports Potential Safety Concerns Licensing Action Items
  • HPES Reports Technical Data Reports Calculations and Verifications Field Questionnaires / Change Notices Failure Trend Reports l

Databases Reviewed Computer Assisted Records & Info Retrieval System (CARIRS)

Generation Maintenance System II (GMS-2)

Material Inventory Control System MICS)

Purchasing System (DKPS)

Nuclear COMEC (NCMC)

Quality Assurance (NQMI)

Nuclear Material Management System (NMMS)

Technical Functions Work Requests (TFWR/TFAAI)

Plant Engineering Work Requests (PEWR/ PETA)

  • Denotes information reviewed by the NSCC 13

EXHIBIT 1 (Continued)

Other Sources l

  • NRC Notices and Bulletins
  • NRC Generic Letters
  • NRC Regulatory Guides and NUREGs
  • NRC Inspection Reports
  • INPO Evaluation Reports INPO Guides l

ANSI Standards ASME Codes Code of Federal Regulations (10 CFR)

  • Industry Periodicals (e.g.,

Inside NRC, Nucleonics Week) l

  • INPO Nuclear Power Plant Operational Data Report Nuclear Network l
  • Denotes information reviewed by the NSCC 14

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EXHIBIT 2 1

PERSONS INTERVIEWED / CONTACTED DURING REPORT PERIOD i

SITE PERSONNEL (both TMI-1 and OC unless otherwise noted) i Vice President / Director Vice President, Saxton, NEC Operations and Maintenance Director Plant Operations Director (TMI-1,-TMI-2)

Plant Engineering Director Site Services Director Department ~ Managers, Supervisors, and personnel

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Plant Operations /Radwaste/ Chemistry Plant Materiel / Maintenance Site Services 4

Plant Engineering.

Logistical-Support Plant Review Group IOSRG Engineering and. Design Engineering Services Licensing Systems Engineering / Plant Analysis (STA)

Engineering Projects Startup and Test Training and Education Quality Assurance Emergency Planning Radiological and Environmental Controls Nuclear Safety Construction Outage Management CORPORATE PERSONNEL Vice-President, Technical Functions Vice-President,-Nuclear Assurance Director, Radiological and Environmental Controls Director, Independent Safety Review Managers and other personnel Licensing Training and' Education Systems Engineering / Plant Analysis Quality Assurance-Engineering and Design Site Services 15

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