ML20039A297
| ML20039A297 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Crane File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 11/02/1981 |
| From: | Arnold R METROPOLITAN EDISON CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML093430786 | List: |
| References | |
| NUDOCS 8112170034 | |
| Download: ML20039A297 (2) | |
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Metropolitan Edison Company y
4-p Post Office Box 480 gj Middletown, Pennsylvan,a 17057 i
717 944-4041 Writer's Direct Dial Number 717-948-8189 November 2, 1981 Mr. Ronald C. Haynes Director Of fice of Inscection & Enforcement U.S. tbclear Regulatory Ccmmission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Haynes:
We are forwarding a ccpy of a recent evaluation of TMI Unit No.1 that was conducted by the Institute for tbclear Power Operaticns (INFO).
The purpose of the evaluation was:
I "to make an overall determination of plant safety, to evaluate management systems and centrols, and to identify areas needing improvement."
Based uoan information " assembled from discussions, interviews, observations, and reviews of plant dccuments," the evaluation team concluded:
"that when the outage work in progress is ccmpleted, TMI-1 will be ready to cperate safely.
- dditionally, within the secpe of the evaluation, the team determined that the plant is in an acceptable material ccndition and is being maintained shutdown in a safe manner by qualified perscnnel."
Pages 1 through 5 of the Evaluation Paport provides a description of the evaluation method, a summary of the results, and a summary of GRJ's response to the evaluaticn.
INPO is an industry-sponsored organization, as described.in Attachment 1, dedicated j
Their to st.pporting safety of operations of ccmmercial nuclear generating facilities.
l activities include develcpment of " standards of excellence" and an annual assessment of how the operaticns of each nuclear unit compare with those standards.
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We thought you might find their report on TMI-l to be of interest.
If you have any questions or desire any further discussion of either INPO, their activities, or their evaluation of TMI-1, we would be happy to do so at a convenient time for you.
1 Sincerely, I
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INPO was established by the nuclear utility industry as an independent, non-profit organization shortly after the 1979 accident at Three Mile Island INP0's responsibility is to assist its member utilities in enhancing (TMI).
Every utility in this country with safe operations of nuclear power plants.
an operating license, a construction permit or a limited work authorization The for a nuclear power plant is a dues paying member of the Institute.
Institute is located in Atlanta, Georgia.
Primary functions of INPO are:
Establishing performance criteria designed to achieve the highest
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degree of operating safety at nuclear power plants; Evaluating all U.S. nuclear utilities to determine that performance criteria are being met; Analyzing unusual operating events that occur at of significant events to member utilities to reduce the possibility of more serious occurrences; Assisting members in the development and implementation of the best possible training and education programs for employees involved with operation, maintenance and support of nuclear plants; Helping member utilities in emergency preparedness procedures and health' physics programs; Providing examples of good plant practices and procedures and supplementing these, as nessary, by original studies and analyses, t-..
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o Evaluation Report i
j October 1981 i
e T1ree Vi e Is anc Nucear Power Sta: ion - Unit One Genera 3uoic Ltiities Jersey Central Power & Light Company Metropolitan
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i EVALUATION of THREE MILE ESLAND NUCLEAR POWER STATION - UNIT ONE b
D GENERAL PUBLIC UTILITBS Jersey Central Power & Light Company Metropolitan Edison Company Pennsylvania Electric Company
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TMI-1 (1981)
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SUMMARY
INTRODUCTION The Institute of Nuclear Power Operations (INPO) conducted its first evaluation of General Public Utilities' (GPU) Three Mile Island Neelear Power Station, Unit One (TMI-1), during the weeks of July 27 and August 3,1981. ' TMI-1 is an 800 MW net Babcock and Wilcox pressurized water reactor. The site is located in Dauphin County on Three Mile Island in the Susquehanna River about ten miles southeast of Harrisburg, Pennsylvania. The unit began commercial operation in September 1974 and has been shut down since February 1979.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of-plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of plant documents.
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 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.
INPO's goal is to assist member utilities in achieving the highest standards of excellence in all phases of nuclear plant operation. Accordingly, the conditions found in each area were compared to best practices, rather than to minimum acceptable conditions or requirements.
DETERMINATION Based on the evaluation, it appears that when the outage work 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 maintained shutdown in a safe manner by qualified personnel.
Certain beneficial practices and accomplishments were noted l
The commitment by corporate headquarters to acquire top level talent.
The overall commitment to training as demonstrated by the assignment of one entire shift to training, new training facilities, a computer-aided instruction
- program, and plans for both a basic principles simulator and a full-size plant-specific simulator.
The Operations Department administration including the operations surveillance system and the comprehensiva shift turnover process.
. TMI-1 (1981)
Pago 2 The excellent radiological protection training and retraining programs, including the requirement that workers demonstrate their abilities in practice.
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.
Excellent communications among the different organizations at the site.
Dedication and positive morale of station personnel.
Improvements were recommended in a number of areas. The following are considered to be among the most important:
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 ability to identify deficiencies and potential problems.
Programs to analyze in-house events and to derive benefit from industrywide operating experience should be improved.
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 identify deficiencies requiring corrective maintenance.
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.
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 that are commonly done in the industry since this would be of no benefit to GPU or to INPO's other member utilities. As a result, 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.
The findings listed herein were presented to GPU management at an exit meeting at the plant on August 7,1981. Findings, recommendations, and re:ponses were reviewed with GPU management. GPU responses are considered appropriate.
TMI-1 (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.
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E. P. Wilkinson President
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TMI-1 (1981)
Paga 4 GENERAL PUBLIC UTILITIES Response Summary Since the accident at Three Mile Island Unit 2, the organization for conduct of General Public Utilities' nuclear activities has been completely restructured. Three Mile Island Unit I has been the lead site for many of the efforts associated with implementation of the new organization.
Thus, the evaluation by the Institute of Nuclear Power Operations (INPO) of TMI Unit I was expected to be, and indeed was, very helpful to GPU. We gained from the INPO evaluation added confidence in the soundness of our approach as well as ' additional insight into areas in which the implementation of our new
. programs remains to be completed.
We believe that findings by the evaluation team are valid and address principal areas in which improvements can be made. Our summary comments on the most important of these areas in which improvements are recommended are:
One of the principal goals of GPU in developmenc of the current organization was to structure the supervisory and management positions at the site so they would be able to be adequately involved with day-tNay 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 the desired level of involvement by managers and supervisors in day-to-day plant activities. Also, the actions set forth in response to Findings OP.3-1 and MA.1-1 i
are expected to contribute significantly to improvement.in this area.
GPU also recognizes that radiological controls, preventive maintenance, mainte-nance management, and test equipment activities require more complete and consistent implementation of prescribed procedures. These are areas which have 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 forth in the various responses and by developing greater understanding on the part of all elements of the organization as to the standards of performance expected in these areas.
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 had 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) to improve the effectiveness of our own program. We request that INPO consider cross-referencing SOERs-to other 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 effectively, as indicated both 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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TMI-1 (1981)
Paga 5 Implementation of our corrective actions will not only correct the specific deficiencies noted but are also consistent with overall efforts that address underlying causes and issues for which the specific deficiencies are but symptoms.
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 4
result of the evaluation.
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Phga 6 TRAINING AND QUALIFICATION
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TRAINING ORGANIZATION PERFORMANCE OBJECTIVE: Provide a clearly defined training organization staffed with qualified personnel capable of accomplishing all assigned training tasks.
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Finding A good practice was noted in the training organization's develop-(TQ.1-1) ment and conduct of an excellent Instructor Development Program.
The one-week course covers methods and techniques of training design, presentation.and evaluation. Topics include needs and task s
analysis, development of learning objectives, training analysis,
~ training methodologies, training materials, lesson plan preparation 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' approaches to training.
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%,a-TRAINING ADMINISTRATION PERFORMANCE OBJECTIVE: Ensure that activities neceaary to initiate and control personnel qualification programs are accomplished in a well-defined, coordinated, and 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 level.
However, individuals in positions between these levels receive no such training.
Recommendation Provide 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 i
- effort.
Response
GPU agrees that a formal training program for middle-level managers in plant systems and technology is needed. A specific course on pressurized water reactor (PWR) systems and technology s
is under development and is scheduled to be available in July 1982.
Attendance at this course, or portions thereof, will be determined on an individual basis taking into consideration the background, 9
work assignments, and professional development objectives of the i
individual employee.
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Paga 7 Finding A good practice was noted in that supervisory personnel from the (TQ.2-2)
Training Department periodically monitor and evaluate training sessions. The Plant Training Manager publishes monthly schedules assigning his supervisors to avaluate specific training sessions. The formal, scheduled assignment of individuals to conduct specified 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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TMI-1 (1981)
Page 8 OPERATIONS n
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 tours and during observations of plant testing. Examples include the following:
a.
The material condition and cleanliness of the plant were acceptable, but need upgrading.
b.
Observations of emergency feedwater and secondary river water pump hot functional testing indicated a lack of under-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.
c.
Persons conducting an electrical preventive maintenance test were unable to verify that the equipment and test devices were in a safe or correct condition as specified in the procedure.
Recommendation Administrative Mxols are in place to correct the details in the above findir% :wier, implementation needs upgrading. Manage-ment sbcC u ires the need for greater attention to detail at both r.c r e and bargaining unit positions and should become more ;,oe.u.c cally plant activities. Responsibilities should be reemphusized and personnel held accountable for these responsi-bilities.
Response
GPU believes the attitudes and performance of the, operations staff, particularly those on-shif t. are central to safe operations.
Clearly, their attention to detail 2nd 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 the estaolished 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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TMI-1 (1981)
Paga 9 PLANT OPERATIONS PROCEDURES PERFORMANCE OBJECTIVE: Provide timely, effective guidance to operators in the form of written gucMares.
Finding The fonowing good practice was noted: Numerous well-developed (OP.4-1) programs emst within the Operations Department. It is obvious that considerable effort has been made to achieve procedures that are operator oriented and allow efficient operation within existing requirements.
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 various work areas and local control panels in the plant.
A program is in place to control these types of aids and has resulted in good examples displayed in various locations; however, complete 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 uncontroHed notes, portions of procedures, labels and drawings of a temporary nature. Removal and replacement with permanent authorized aids will be accomplished by December 31, 1981.
Management and supervisory personnel have been advised to identify temporary
" operator aids" during their plant tours.
SHIFT TURNOVER PERFORMANCE OBJECTIVE: Ensure a continuous and correct understanding of plant conditions at all shif t operating positions through proper shif t turnover.
Finding The following good practice was noted: Shift turnover documents (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.
TMI-l (1981)
Paga 10 TAGOUT PRACTICES PERFORMANCE OBJECTIVE: Protect personnel and plant equipment by implementing effective tagout practices.
Finding The current tagout piccedee needs to be implemented more (OP.7-1) effectively. Observations indicate that tags are being used for other than their intended purpose, and some tags are illegible due 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.
Recommendation Emphasize through additional training or department meetings the necessity of compliance with the intent of company procedure AP1002, " Rules for the Protection of Employees Working on 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.
Response
Review of procedures AP1002 and AP1037 is required on an annual basis. We will increase our emphasis on the necessity of compil-ance with these procedures effective October 1,1981 and will include this issue in the program described in response to Finding O A.4-1.
A complete check of all tagouts will be made prior to restart. Additionally, Operations Surveillance Procedure OPS-528 will be modified by September 1,
1982 to incorporate the requirement to observe physically all tags and to replace those that are deteriorated, damaged, or missing on a semi-annual basis.
TMI-1 (1981)
Paga 11 MAINTENANCE MAINTENANCE ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: Provide a clearly defined maintenance organization that ls adequately staffed, assigns responsibilities, and delegates adequate authority for the accomplishment of required tasks.
Finding More aggressive efforts are needed to identify and correct defi-(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 Hot Functional Test (HFT) program is organized, in part, to inspect and identify plant problems. However, this aspect of the HFT program is not being managed in an aggressive munner. One plant system that recently completed Hot Functional Testing was evaluated for its overall material condition. Although the system was operational, several problems were identified that had not been documented during the test program.
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.
Translate the identification of deficiencies into applicable work lists for orderly correction and overall improvement in plant material condition.
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 which are not satisfactory will be translated into a work item that will be completed prior to certifying the system ready to support startup. Supervisory personnel will spot check system walkdowns to ensure inspections are being conducted properly and deficiencies are being identified.
WORK CONTROL SYSTEM PERFORMANCE OBJECTIVE: Provide an administrative control system within which a
equipment problems can be identified and reported, and safely and efficiently disposi-tioned and documented.
Finding The work control system needs to be utilized more effectively to (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.
TMI-1 (1981)
Paga 12 The remaining two-thirds are awaiting rstest or ara on cdministra-tive hold. Many of those on hold have remained outstanding for an extended period of time. Outstanding job tickets should receive a j
comprehensive periodic review.
1 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.
Response
Once each quarter a management review at the department head i
level of all outstanding work requests will be conducted to recon-firm validity _ of current designations, uncover unwarranted admini-strative delays, reestablish work priorities, and ceview supply support. The first of these quarterly reviews will be conducted before the end of 1981.
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 often 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 interdepartmental coordination.
Response
A material expeditor for the maintenance planning group has been authorized for 1982. This position will be responsible for monitor-ing the timely procurement of parts to support maintenance activities.
The Manager-Plant Maintenance will conduct a monthly meeting to review all maintenance jobs that are on administrative hold. The l
purpose of the monthly meeting is to determine the reason for the hold status and to coordinate the actions required by various departments to release the job for execution. A representative i
from Materials Management will attend each monthly meeting.
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Paga l3 MAINTENANCE PROCEDURES PERPORMANCE OBJECTIVE: Ensure that adequate plant maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of 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 !n safety-related procedures are subject to review and approval.
In addition, improved controls are needed to ensure that vendor manuals used in conjunction with maintenance are kept up-to-date.
Recommendation Establish a system that ensures 'that all vendor manuals used for reference in conducting maintenance of plant systems and compo-nents are current or are given appropriate engineering review and are certified adequate for the work to be performed.
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-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.
PREVENTIVE MAINTENANCE (PM)
PERFORMANCE OBJECTIVE: Optimize equipment reliability and performance to enhance plant safety and availability.
Finding The condition of some systems and components reflects a need for (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.
TMI-1 (1981),
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 preventive maintenance actions required to achieve safe and reliable 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.
CONTROL OF MEASUREMENT AND TEST EQUIPMENT (M&TE)
PERFORMANCE OBJECTIVE: Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.
Finding Measurement and test equipment is not always controlled in an (M A.7-1) efficient and effective manner.
a.
Equipment is not permanently identified, 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 and 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 issued to any requestor rather than to designated technicians.
The required inventory is not being maintained. A consider-able amount of instrument and control (I&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 to identify and correct existing problems.
Action taken should include the following:
Establish a system of permanent equipment identification.
a.
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Page 15 b.
Develop a tag for rejected equipment that specifies date, reason, and identification of individual rejecting.
c.
Segregate controlled (calibrated) test equipment to preclude the inadvertent use of non-controlled or not-ready-for-issue equipment.
d.
Designate individuals certified to use controlled measure-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 AI-1022 will be modifiedby 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.
d.
Technicians will be certified individually by supervision as to their qualification for using various specialized measurement and test equipment. Formalization of this program will be incorporated into the training manual by July 1,1982.
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 by December 31, 1981. An inventory and status of equipment not available for use will be com-pleted by April 1,1982. AP1022 will be revised by April 1, 1982 to require annual inventories and verification of status of measurement and test equipment.
t Finding Improvements are needed in the program for calib' ating installed r
(M A.7-2) plant instrumentation. Calibration stickers indicate '. chat 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 program for the calibration of installed plant instrum,ents. This program should differentiate clearly instruments requiring calibra-tion at specific frequencies from those that do not.
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Paga 16
Response
The company will continue with the development and implementa-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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Page 17 RADIATION PROTECTION AND CHEMISTRY MANAGEMENT OF RADIOLOGICAL PROTECTION PERFORMANCE OBJECTIVE: Provide effective management of the radiological pro-taction program.
Finding Plant personnel do not always comply with radiological protection (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 Mangger-Radiological Controls to review implementation of effee-tive radiological controls.
Finding Modifications are reeded in the Radiological Deficiency Report (RC.1-2)
(RDR) system to e nsure that trends in personnel adherence to radiological protect on procedures and requirements are brought to the attention of mar agement.
Recommendation Expand the use of the RDR system, or develop and implement another system to dentify personnel compliance problems in the area of radiological protection.
Response
We agree that the plant is not fully utilizing its RDR system and will reemphasize the importance of this system via the HP Awareness Comrr4ttee and other plant information systems. Addi-tionally, a Radio'ogical Control Engineer has been asciigned once a
.TMI (1981)
Page 18 day on a sh' ort-term basis to observe work taking place in radio-logical controlled areas. He will document persennel deficiencies via the R DR system. Effective immediately, Radiological Engi-neering has implemented trending of RDRs and Radiological Incident Reports (RIRs).
k Finding Corrective actions resulting from Radiological Engineering investi-(RC.1-3) gations of radiological occurrences are not always comprehensive.
Recommendation Ensure that radiological engineering investigations 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 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
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radiological control and operations present.
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 good 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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Page 19 Finding A good practice was noted as fonows: the traming and retraining (RC.2-2) program for radiological protection personnel is comprehensive.
Foremen and technicians receive training one out of every six weeks.
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 establishment of goals for routine radiological work.
Ensure radiological engineering considerations are addressed and imple-mented as required.
Responoe 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 radiological work and the Man-rem Reduction Irogram will be revised by January 1982 to provide more feedback to the radiological workers and their supervisors.
Additionally, the ALARA engineers have been re-quired on a daily basis to spend time in the field observing work, 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 staff meetings.
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 i
,TMI-1.(1981)
Paga 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 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.
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-grams and efforts.
RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Minimize contaminated 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.
t Finding Some containers of radioactive material were not identified and (RC.9-2) labeled.
It is recognized that the plant implemented interim corrective action during the evaluation.
Recommendation Continue with efforts to implement a program that ensures radio-active materials are identified and labeled and that they receive proper disposition.
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.
TMI-1 (1981)
Paga 21 Finding
_, Several conditions were noted which have the potential for the (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.
b.
Eliminate the potential spread of contamination by re-establishing the plant's count room where radiological con-trols have already been established.
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 controlled areas.
Response
a.
Steps are in progress to provide better separation between the trash compactor room and the laundry sorting area. This 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 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 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.
c.
The approaches being ccasidered include a high quality, sensitive, fast access portal monitor.
To provide better 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.
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 follows:
a.
Radioactive ion exchange resins and liquids are being trans-ferred by hose to a shed located outside of the auxiliary building.
l w
TMI-1 (l'981)
Phg2 22 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 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:
1.
Increasing the physical integrity of the building.
2.
Installing a ventilation and high efficiency filtration system.
3.
Providing overpressurization protection.
b.
Implement a program that ensures doors are kept closed at the boundaries of potentially contaminated and airborne radioactivity areas except in cases where thay are required to be opened for plant operations.
The program should require authorization by the Radiological Control Depart-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 Hittman Building. The piping modifi-cations will ensure that hard piping exists from the Auxiliary Building to isolation valves located within the curbed area of the temperary solidification building. The building founda-tion pad and curb have been designed to meet the require-ments of NRC Regulatory Guide 1.143. The containers used in the Hittman solidification system are sealed and vented to the Auxiliary Building during filling and solidification opera-tions.
The exhaust from the vent line is monitored by a 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 l
operation. It is estimated that this system will be installed by late 1983.
b.
By November 1, 1981, the Fuel Handling 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.
e W------- ----------
TMI-1 (1961)
Paga 23 CHEMISTRY PERFORMANCE DBJECTIVE: Ensure accurate measurement and effective coatrol of chemistry parameters.
Finding Several problems were identified in the plant's chemistry program (RC.10-1) in such areas as chemistry procedures; receipt inspection of bulk 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 the technician training program.
(
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 the finding, including the timely correction of deficiencies that are easily corrected. Establish priorities and completion dates for the remaining items.
Response
The deficiencies noted in this finding have been previously identi-fled 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, quality control / assurance, and the more important analytical pro-cedures. The remaining procedures 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 implemented.
A periodic Requalification Program for Chemistry Technicians will be implemented by August 1982.
TMI-1 (l'981)
Paga 24 TECHNICAL SUPPORT ON-SITE TECHNICAL SUPPORT ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: Have a clearly defined on-site technical support organi-zation that is adequately staffed, assigns responsibility, and delegates adequate authority for the accomplishment of required tasks.
Finding A training program that includes plant systems training is needed (TS.1-1) for on-site technical support personnel.
Some training is being accomplished in specific technical areas, and preliminary planning has been completed with regard to a more comprehensive training program.
Recommendation A training program that includes plant systems training should be implemented for technical support personnel. This program should be implemented on a department level to ensure that uniform 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.
NUCLEAR OPERATING EXPERIENCE EVALUATION PROGRAM PERFORMANCE OBJECTIVE: Ensure industrywide and in-house operating experiences 1
are evaluated and appropriate actions are taken to improve personnel awareness and
]
equipment reliability.
Finding Improvements are needed in the program to review in-house plant (TS.3-1) incidents and operating experiences. Incidents are being identified and reviewed in accordance with procedures AP-1029, Conduct of Operations, and EP-017, Review 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 draf t form.
Recommendation Procedure revisions should be implemented to provide a more comprehensive program for the review of plant events. Procedures in use at other facilities evaluated by INPO have been identified as 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.
~
TMI-1 (1981)
Paga 25
Response
The comprehensive procedure on the review of plant transients (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 presently existing plant procedures and practices for review of plant events.
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 include 39 recommendations that are applicable to TMI-1.
The status of action taken on 35 of these recommendations could not be determined.
Recommendation Action should be taken to ensure that SOERs are processed in a timely manner. Also, a written response should be provided to INPO describing the action taken or planned with regard to the 35 pending recommendations.
Response
Completion of 27 of the 39 recommendations has been documented.
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 willimplement by November 1,1981 an automatic reminder system to shorten the response time. A report on the status of SOER recommenoations applicable to TMI-1 will be provided in GPU's follow-up responses six months from the date of this report.
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 were modified
TMI-1 (1981) ~
Paga 26 prior to the new drawing control procedure have not had their drawings updated.
In order to correct this proble.n, GPU has initiated a program to update these drawings prior to plant startup.
Recommendation The program to update drawings used by operators should be continued to completion.
Response
GPU will have baseline engineering drawings essential for plant 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.
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 technical review prior to each installation.
An evaluation is in progress 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 oi guidelines to control the future placement of temporary shielding on plant piping systems and equipment.
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 and equipment. These guidelines will be implemented by April 1, 1982. To correct the immediate problem, a radiation survey of the areas where lead blankets were installed was conducted.
As a result, a large amount of the temporay shielding was removed due 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 made 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 modifications.
The ad;ninistrative procedure for the bypass of 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 Engineering or Technical Functions personnel.
TMI-1 (1981)
Paga 27 Recommendation A qualified individual who is not in the operations department 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 evaluation by either a lead engineer in the Plant Engineering Group or the Shift Technical Advisor.
Response
Procedures will be implemented by January 1,1982 requiring concurrence from Plant Engineering or the Shift Technical Advisor on the use of jumpers, lifted leads, and temporary mechanical modifications prior to their installation.
h 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 modifications implemented after the current outage.
Recommendation Administrative procedures should be revised to require that train-ing be completed prior to turnover of a modified system to operations.
Response
As noted, operators are currently receiving training on plant modifications, and our plans are to continue this type of training.
The formal requirement for operator training on modifications will be incorporated into AP 1043 by January 1,1982.
ON-SITE REACTOR ENGINEERING PERFORMANCE OBJECTIVE: Optimize nuclear reactor operations without compro-mising design or safety limits, and control nuclear fuel handling activities to ensure safety of personnel and equipment.
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.
l l
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TMI-l (l'981) '
P~aga 28 ORGANIZATION AND ADMINISTRATION MANPOWER RESOURCES PERFORMANCE OBJECTIVE: Ensure that qualified individuals are available to fill all job positions apporting plant safety and reliability.
Finding Written quellfication 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 maintain these current are sched-uled to be completed by December 1982.
1 i
k ADMINISTRATIVE CONTROLS l
I 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.
Finding Several plant programs are not achieving desired results. Examples (O A.4-1) of programs where implementation needs improvement include the control of unauthorized notes and drawings attached to local panels 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 evaluate whether the programs, as implemented, are achieving the results desired by management.
Response
GPU will define by December 1981, and implement by July 1982, a plan for periodic monitoring of the effectiveness of the implemen-tation of plant management programs.
TMI-1 (1981)
Paga 29 MANAGEMENT QUALITY PROGRAMS PERFORMANCE OBJECTIVE: 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.
Finding Improvement is needed in the correction and clearing of long-term (O A.5-1)
QA deficiencies.
Recent management attention to this area is resulting in a reduction of the backlog.
j Recommendation Management attention to correcting long-term QA deficiencies should continue and be maintained on a cbntinuing basis.
Response
Management wiH continue to focus attention on correcting long-term QA deficiencies, and the effectiveness of this effort win be included in the plan implemented in response to finding OA.4-1.
SURVEILLANCE PROGRAM PERFORMANCE OBJECTIVE: Provide surveillance programs to accomplish coordi-nated monitoring, inspection, and testing to ensure safe, reliable operation of plant equipment and facilities.
Finding No organization or person is assigned overan responsibility for (O A.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 surveillance program. Formally define the pecgram, assign respon-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
)
to ensure full coverage and proper scheduling. GPU acknowledges the need for specific assignment for overall management responsi-bility of the surveillance program and will accomplish same by December 1,1981.
Appropriate procedures will be modified to reflect this assignment at the same time.
l l
TMI-1 (1981)
APPENDIX Paga1 APPENDIX A I.
Performance Objectives Reviewed TRAINING AND QUALIFICATION TQ.1 Training Organization Provide a clearly defined training organization staffed with quali-fled 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-nated, and effective manner.
TQ.3 Training Facilities and Equipment Provide the training facilities, equipment, and materials for devel-opment and evaluation of knowledge and skills needed by nuclear plant personnel.
~
TQ.4 Non-Licensed Operator Training Develop and maintain the skills and knowledge necessary for non-licensed operators to perform their assigned job functions.
Licensed Operator Training TQ.5 Develop the skills and knowledge necessary for licensed operators to perform their assigned job functions.
TQ.6 Licensed Operator Requalification Training Maintain the skills and knowledge necessary for licensed operators to perform their assigned job functions.
I l
TQ.7 Shift Technical Advisor Training Develop and maintain the skills and knowledge necessary for Shift 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-1 (1981)
ARPENDIX Pag 3 2 i
OPERATIONS OP.1 Operations Organization and Administration Provide a clearly defined operations ceganization that is ade-quately staffed, assigns responsibilities, and delegates adequate authority for the accomplishment of required tasks.
4 OP.2 Operations Facilities and Equipment Provide plant facilities and equipment that are operated and main-tained at a level to support safe and efficient operation.
OP.3 Conduct of Shift Operations q
l Ensure that shift operations are conducted in a safe and reliable j
manner.
OP.4 Plant Operations Procedures Provide timely, effective guidance to operators in the form of written procedures.
}
OP.5 Plant Status Controls Maintain plant status in a condition that ensures equipment and i
system availability as necessary for safe and reliable plant opera-i tions at all times.
OP.6 Shif t Turnover i
Ensure a continuous and correct understanding of plant conditions at all shift operating positions through proper shift turnover.
I OP.7 Tagout Practices Protect personnel and plant equipment by implementing effective tagout practices.
4 I
MAINTENANCE M A.1 Maintenance Organization and Administration Provide a clearly defined maintenance organization that is ade-i quately staffed, assigns responsibilities, and delegates adequate J
authority for the accomplishment of required tasks.
M A.2 Maintenance Facilities and Equioment Support the performance of maintenance activities by providing adequate facilities and equipment.
TMI-1 (1981)
APPENDIX
~
Paga 3 MA.3 Work Control System Provide an administrative control system within which equipment problems can be identified and reported, and safely and efficiently dispositioned and documented.
MA.4 Maintenance Procedures Ensure that adequate plant maintenance procedures exist and are utilized to achieve quality by the safe and reliable conduct of maintenance activities.
MA.5 Maintenance History Provide a complete and functional maintenance history supporting an evaluation program which contributes to improvements in equip-ment performance.
MA.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)
Control the use and calibration of measurement and test equipment to ensure the necessary accuracy for calibrated devices.
MA.8 Control of Soecial Processes Ensure that the control and performance of special processes yields quality results.
RADIATION PROTECTION AND CHEMISTRY RC.1 Management of Radiological Protection 4
Provide effective management of the radiological protection program.
RC.2 Radiological Protection Training Ensure that personnel on the site have the knowledge and practical abilities necessary to effectively implement radiological protection practices associated with their work.
RC.3 Personnel Dosimetry Accurately determine and record radiation exposures.
i
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TMI-l (1981).
APPENDIX l
~
- 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 plant.
RC.6 Radioactive Effluents Minimize releases of radioactive effluents to the environment.
RC.7 Solid 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 Minimize contaminated equipment and areas in the plant and minimize personnel contamination.
RC.10 Chemistry Ensure accurate measurement and effective control of chemistry parameters.
TECHNICAL SUPPORT TS.1 On-site Technical Support Organization and Administration Have a clearly defined on-site technical support organization that is adequately staffed, assigns responsibility, and delegates adequate authority for the accomplishment of required tasks.
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-usted and appropriate actions are taken to improve personnel awareness and equipment reliability.
1 i
TMI-1 (1981)
J APPENDIX
~
Paga 5
._o TS.4 Plant Modifications-
= Provide ~ a program to implement plant modifications in a timely i
manner while maintaining the quality of plant systems and compo-nents.
~
n.
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.
o ORGANIZATION AND ADMINISTRATION OA.1 Organizational Obhectives Establish missica, 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.
OA.2 Organizational Structure Provide an organizational structure that suoports the affective management of nuclear power plant operation; OA.3 Manpower Resources
/
w Ensure that qualified individuals ~ are available to fill all job positions supporting plant safety and reliability.
1
~
OA.4 Administrative Controls Provide well-defined, organized, and effective administrative con-trols to direct the tasks, responsibilities, and practices within the organization to meet the specified mission, goals, and objectives.
OA.5 hianagement 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.
OA.6 Surveillance Program Provide surveillance programs to accomplish coordinated moni-toring, inspection, and testing to ensure safe, reliable operation of plant equipment and facilities.
OA.7 Industrial Safety Provide an orderly working environment in which station personnel may carry out their work activities safely.
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