ML20039F448

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Responds to NRC Request for Summary of Progress Re Util Commitments to Systematic Assessment of Licensee Performance for Sept 1979-Aug 1980.Tasks & Implementation Activities Identified for Reorganizing Nuclear Div
ML20039F448
Person / Time
Site: Beaver Valley
Issue date: 09/25/1981
From: Carey J
DUQUESNE LIGHT CO.
To: Haynes R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20039F446 List:
References
TAC-43748, NUDOCS 8201120483
Download: ML20039F448 (28)


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'gN Pa (412) 456-6000 September United States Nuclear R 25, 1981 Office Attn:

of Inspection egulatory Commission Mr. Ronald C. Haynesand Enforcement Region 1 631 Park Avenue

, Regional Director King of Prussia, Pennsylv ania 19406

Reference:

Beaver Valley Power St 1980 Systematic AsseDocket No. 50-334; Licea tion, U nse No. DPR-66 Gentlemen:

osment of Licenc ee Performance This letter and provides summary of our progress iresponds to the verbal re a

in response to the Syst quest of parformed by the NRC and n mettiag commitments whichthe NRC R August 31, 1980.

ematic Assessment of Li pector dated Januarythn SALP are document dSpecifically, covering the were made the m er 1 1979 cad May 7,1981.19, 1981 in Duquesne Light Compacommitments which wer,e mad throug e

and April 2, 1981 and NRC lny letters to Mr. Boyce Hre e in Nuclear Division, headed bin general, Duquesne Li h etters dated March 31

. Grier

, 1981 y a Vice President.g t Company conitted to heva ware identified in the SALPsufficient qualified manp ower to This reorganize qu*alified personnel.

address and form as being deficient in pand controlr.cw Nuclear Division a new the erformance activities which A reorganization of hxve been identified and i or this numbers of scope is manngement:

a major mplementation is beit g actiundertaking.

vely pursued by DivisionThe follow Identification of the Nuclear Division a dand corporate (completed March 27 approval of t;.e n

, 1981). appointment of the Vice Presidentorganizational struc Selection and appointme

, Nuclear Preparation nt of Department Heads (co of approximately 159 job mpleted April Wage and Hour evaluati descriptions (100 per 20, 1981).

on of job descriptions (91 cent complete).

percent coeplete).

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Besvat Vality Powar Station, Unit No. 1 1980 Systematic Assessment of Licensee Performance-September 25, 1981 Page 2 Design and construction of modifications to existing plant structures to provide additional work space and office space for new employees.

  • Space within the plant protected area'(preliminary design under evaluation).
  • Modifications to BVPS Administration Building (90 percent complete).
  • Relocation of Nuclear Division Training Department to the Johnson Street School,'Aliquippa, PA, approximately 7 miles from the site _(complete).

1

  • Modification and furnishing of two floors of the Stone & Webster Building at the BVPS site (80 percent complete).

Installation of an expanded on-site telephone system.

Preparation of Technical Specifications for the Nuclear Division (original submittal on April 10, 1981; three revisions have resulted from ongoing negotiations with the NRC; the NRC has not yet issued a Technical Specification).

Purchase and installation of office furniture and equipment

  • BVPS Administration Building (80 percent complete)
  • Stone & Webster Building (80 percent complete)
  • Emergency Response Facility Building (in design)
  • New Training Building (in design)
  • Johnson Street School (100 percent complete)

Revision of all Nuclear Division procedures to reflect the new organization

  • Quality Control Procedures (completion expected by 12/31/81)
  • Radiation Control Procedures (completion expected by 12/31/81)
  • Station Administrative Procedures (completion expected by 10/31/81)
  • Nuclear Division Directives (completion expected by 10/31/81)
  • E&C Engineering Management Procedures (completion expected by 5/31/82)
  • Nuclear Engineering Department (completion expected by 3/31/82)

Engineering Management Procedures

Implementing Procedures Recruitment of new employees to fill vacant positions.

Beaver Valley Power Station, Unit No. 1

-1980 Systematic Assessment of Licensee Performance September 25, 1981 Page 3 At the present time, staffing of the Nuclear Division, excluding engineering support provided by the corporate Engineering and Construction Division, is as follows:

Nuclear Division Organization Status

  • as of September 15, 1981 Planned Authorized Positions Department Positions Positions Filled Vacancies Vice President's office 25 7

6 19 Nuclear Operations 308 287 230 78 Nuclear Safety & Licensing 142 56 32 60 Nuclear Engineering 81 2

2 79 Nuclear Support Services 120 89 56 64 121 121 **

in training.

676 562 447 300

  • Does not include Beaver Valley Unit 2 personnel or Shippingport Atomic Power Station personnel
    • Includes 71 in operations training and 50 in radiation technician training As set forth above, Duquesne Light Company is actively pursuing the organization and manning of its Nuclear Division and we believe we have made significant progress toward full implementation. Recruitment of sufficient numbers of qualified persons continues to be the most difficult aspect of the reorganization effort and we plan to place greater emphasis upon this portion of the task immediately.

The detailed commitments related to reorganization activities were set forth in Duquesne Light Company letters dated January 19, 1981 and April 2, 1981. to this letter lists the commitments made in the January 19, 1981 letter and the progress made related to each commitment and Attachment 2 provides the same information relative to the April 2, 1981 letter.

Should you have further questions regarding this matter, do not hesitate to contact my office.

Very truly yours, 8

J.

Carey Vice President, Nuclear Attachments

Betysr Valliy' Power Station, Unit No. 1 1980 Systematic Assessment of Licensee Performance September 25, 1981 Fage 4 cc:

D. A. Beckman United States Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 United States Nuclear Regulatory Commission c/o Document Management Branch Washington, D. C.

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ATTACHMENT 1 e

NRC Com.ent_

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the The NRC's comment in Section 3, Maintenance, Instrument and control group appears barely able to keep up Insuffi with routine calibration and maintenance activities.

staff at both supervisory and technician levels appears to be the pri=ary problem."

1.

The Pcwer Stations Departmen: will request approval establish, fill and train an additional nt=her of M-and control Repairman positions so as to have a sta Tne large enough to satisfy the work reqairements.

number will be established by station perscnnel.

Status As Of September 15, 1981:

Approval for increasing Meter and Control Repairman positions-by as many as ten (10) has been established.

At the present

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We are continuing to evaluate the time, none have been-filled.

number of positions required at this time.

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ATTACHMENT 1 NRC Comnent t

The NRC's ccmment in Section 3 Maintenance, the with routine calibration and maintenance activities. I staff at both supervisory and technician levels appears to be Insuffi.cient the primary problem."

2.

The Power Stations Department will request approval to establish, fill and train, as necessary, the additional Instrument and Control Foremen and Instrument Engineers needed to effectively superrise the work.

The nu=ber will be established by staticn personnel.

Status As Of September 15, 1981:

One (1) established and was filled on September 1, additional Instrum en

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1981.

One (1) and, at the present time, additional Instrument Engineer position has has not been filled.

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NRC Cetment_

in part, The NRC's comments in Section 6, QA/QC states, "The enforcement history in function areas subject to the Operational Quality Assurance Program reveals a lack of understanding and implementation of CA by the on site de--

The licensee has not effectively utilized partments."the productive capabilities of the quality-related departmentslicen in implementation of the program" appear to need additional training and familiarization with the facility license rega'-=-="ts and regulatory regaire=ents...".

The Quality Assurance Department will initiate action 1.

to review the programs new used to train personnel on the recuire=ents of the Quality Assurance Program for operations with the intent of improving the effective-Thi~s could be an expansion in the ness of the training.

it would be scope of the training curriculum in that tailored to the specific needs of the various functional groups.

Status As Of Sectember 15, 1981:

A comprehensive training program for all site employees has been This.new training developed by the Quality Assurance Department.

program has been designed to be interesting and inform Over 900 site employees have which site personnel must work.

attended the first module of the program.

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ATTACHMENT 1 NRC Cement

.s The NRC's ccmments in Section 6, QA/QC states, in part, "The enforcement history in function areas subject to the Operational Quality Assurance Program reveal:; a lack of understanding and implementation of QA by the on site de-

"The licensee has not effectively utilized paa ents."

the productive capabilities of the geality-related departments in implementation of the program" licensee personnel appear to need additional training and familiariration with the facility license regairements and regulatory regairements...".

2.

The station staff and others will make greater use of the Quality Assurance reparc=ent's capabilities in the future.

Status As Of September 15, 1981:

Department Managers have been made aware of the valuable capabilities of the quality related departments and greater use of these capabilities is being made to enhance unit operability and safety.

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ATTACHMEWM 1 NRC Comment _

in part, The NRC's comments in Section 6, QA/QC states,bject to the "The enforcement history in function areas su k of Operational Quality Assurance Program reveals a lac ite de-understanding and implementation of QA by the on s"The lice l

d departments partments."the productive capabilities of the quality-re atelicensee personn in implementation of the program" i

i tion with the appear to need additional training and famil ar rafa l

Assurance Department will schedule additiona f the current The Quality training, 'as required, based on the review o 3.

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crogram and any expansion in the secpe of t e c 1981.

The training will not start before February 28,

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15, 1981:

Status As Of September familiarization The training which is designed to provide additional i

ments is with facility license requirements and regulatory requ r training.

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ATTACHMEN"3' 1 NRC Comment The NRC's conclusion in Section 8, Committee Activities is "The facility staff cannot properly support both routine activities and ccmmittee review."

1.

The Pcwer Staticens Department will regaest approval t:

establish and fill several full time positions to per-form safety cet=nittee work and other related technical functions.

The number of such positions will develop from the consultant's study; hcwever, a srep in that direction should be made immediately.

Status As Of September 15, 1981:

One (1) Emergency Planning Supervisor position has been established and, at the present time, has not been filled.

One (1) Safety Review Committee Coordinator position has been identified and, at the present time, has not been.

established.

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4 ATTACHMENT 1 NRC Comment g

The NRC's conclusion in Section 13, Radiation Protection,

" Satisfactory performance, with a staff sire a potential serious problem and a comment in Section 15, Emergency Preparedness, a

" Staffing adequacy concerns identified in..

13 (Radiation Protection) indicates a corresponding need to carefully evaluate operational and support staff adequacy under energency conditions."

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The Pcwer Stations Depar :=ent will start a training class for 17 Radiation ~ Technicians in February, 1981.

These employees will eventually replace the contract persennel.

This would fill all currently authorired positions and could bring the number of Duquesne employees functioning as Radiation Technicians to about 26, depending upon attrition.

The training period shculd be about eight montbJ.

Status As Of September 15, 1981:

Radiation Technician Class #1, consisting of seventeen (17) l(

Radiation Technicians, was started in February, 1981.

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ATTACHMENT 1 NRC Cenment The NRC's conclusion in Section 13, Radiation Protectie..n,

" Satisfactory performance, with a staff size a potential serious problem" and a cocment in Section 15, Emergency Preparedness, (Radiation

" Staffing adequacy concerns identified in..

13 indicates a corresponding need to carefully evaluate Protection) operational and support staff adequacy under emergency conditions."

The Pcwer Stations Department will request approval to 2.

fill and train an additional 27 Radiation establish, Technicians so as to reach a manning level of Duquesne employees needed to have both nc:nal and emergency respense One class of 14 will start in Aprs.1, 1981 capabilities.

1981.

The training and the next class of 13 in June, period should be about eight months.

Status As Of September 15, 1981:

(14)

Radiation Technician Class #2, consisting of fourteen 1981.

Radiation Radiation Technicians, was started in June, consisting of twelve (12) Radiation Technician Class #3, 1981.

Technicians, is tentatively scheduled to start in September, i

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ATTACHMENT 1 NRC Cct stent _

Radiation Protection, The NRC's conclusien in Section 13, i

" Satisfactory perfor=ance, with a staff sire a potential ser cus and a coc=ent in Section 15, Emergency Preparedness, proble="

(Radiation

" Staffing adequacy concerns identified in..

13 indicates a corresponding need to carefully evaluate Protection) operational and support staff adequacy under e=ergency conditions."

The Pcwer Stations Department will request approval to 3.

fill and train, as necessary, the fcur establish, additional Radiation Control Fore =an pcsitions needed There are three to effectively supervise the work.

foremen on the jcb ncv.

In addition, one Instra.cter position will be requested to i= prove the training capabilities.

Status As Of Seotember 15, 1981:

The additional four (4) Radiation Control Foreman positions have been established and have been filled.

The additional Instructor position has been established and filled.

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ATTACHMans A N_RC Comment l

ere The.NRC's ccmments in Section 19, Managemen i

lity.

Site i

failure to properly staff and manage the nuclear faciin-house Ehe most cevere.

management is overloaded; kload.

there is poor control over contractors' wor ssential The lack of adequate management control is the one eThe root c l

ganized problem which overlaps other areas.

in Maintenance is too small a stafd and not prcper y 1 and 4).

The caused by inadequate management overview (It (Section 3).

tivities (Section 8).

i (ISI) efforts and ccm=ittee review coordinates the contracted In-Service Inspect onise to provide adequate appears to need additional technical expertLittle assurance exists Ebat t contract control (Item 11).

i ht and ensure present licensee staff can provide adequate overs gin desicient d that current and future work will not resultDesign changes were impleme (section 12).

l and installationsthe ce==ittee 's ') ior submittal to the -NRC for appro i

(Section 10). - Licensee needs to eviiuate cperat ona(Secticn 15) without staff adequacy under e=ergency cenditions

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The services of an outside consultant have been re to eviluate Duquesne's present organizatien and manpcwer 1,.

against NRC requirements, as specified in specifi doc =ments, The study is to be ecmpleted Beaver valley No. 1 Unit.

by February 28, 1981.

1981_:

Status As Of Sectember 15, i

tion and The consultant retained to evaluate Duquesne's organ za1981 and essen manpower requirements was completed on March d by Duquesne 1981.

Light Company management on March 27, I

ATTACHMENT 1

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NRC Comment t

The.NRC's ccmments in Section 19, Management Controls, were the most severe.

The many management control problems indicate failurc to properly staff and manage the nuclear facility.

Site management is overloaded; in-house resources are inadequate; there is poor control over contractors' workload.

c The lack of adequate management control is the one essential problem which overlaps other areas.

The root cause for the preblems in Maintenance is too small a staff and not properly organized (Section 3).

The problems in Operations and Surveillance are caused by inadequate management overview (Items 1 and 4).

The facility staff cannot properly support both routine activities and cen:=ittee review (Section 8).

The licensee group which' coordinates the contracted In-Service Inspection (ISI) efforts appears to need additional technical expertise to provide adequate contract control (Item 11).

Little assurance exists that the present licensee staff can provide adequate oversight and ensure tha't current and future work will not result in deficient designs and installations (Section 12).

Design changes were i=plemented without the cccmittee 's prior submittal to the -NRC for approval

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(Section 10).

Licensee needs to evfluate operational and supporting staff adequacy under e=ergency conditions (Secticn 15).

2.

The Personnel Department has increased its recruitment efforts to fill existing entrance level engineering vacancies.

The status as of January 2, 1981 is as follcws:

B.V.

SAPS.

C-eneral Office E&c Authorized but unfilled positions 35 4

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Status As Of Seotember 15, 1981:

The following is a number of entry level engineers who have been hired since February 28, 1981 from each department:

Nuclear Support Services 9 engineers 3 vacancies Nuclear Safety & Licensing 4 engineers 5 vacancies Nuclear Operations (SAPS) 5 engineers 6 vacancies Nuclear Operations (BVPS) 23 engineers 5 vacancies

ATTACHMENT 1 l

I NRC Ccmment i

The.NRC's ccm=ents in Section 19, Management Controls, were the most severe.

The many management control problems indicate l

failure to properly staff and manage the nuclear facility.

Site management is overloaded; in-house resources are inadegaate; there is poor control over contractors ' workload.

The lack of adegaate management control is the one essential.

problem which overlaps other areas.

The root cause for the prcblems in Maintenance is too small a staff and not properly organized (Section 3).

The problems in Operations and Surveillance are l

caused by inadequate management overview (Items 1 and 4).

The facility staff cannot properly support both routine activities and ccmmittee review (Section 8).

The licensee group which coordinates the contracted In-Service Inspection (ISI) efforts

, appears to need additional technical expertise to provide adequate contract control (Item 11).

Little assurance exists that the present licensee staff can provide adegaate oversight and ensure that current and future work will not result in deficient designs and installations (Section 12).

Design changes were i=plemented without the cermittee's prior submittal to the -NRC for approval (Section 10).

Licensee needs to eviiuate operational and supporting staff adegaacy under emergency conditions (Section 15).

3.

Both E&C and operations Division will review the number of consultants and hcw they are being used within our present organizational structure.

Based on that review, requests will be made to establish and fill. comparable posS.tions with Duquesne employees and to eliminate the. consultants doing work which should be done by Dugaesne employees.

Status As of September 15, 1981:

This work was performed in conjunction with the consultant manpower study dated March 15, 1981.

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ATTACHMENT 1 NRC Comment The.NRC's ccmments in Section 19, Management Controls, were The many management control problems indicate the most severe.

Site failure to properly staff and manage the nuclear facility.

management is overloaded; in-house resources are inadecuater,

there is poor control over contractors' workload.

The lack of adequate management control is the one essential The root cause for the prcblems problem which overlaps other areas.

in Maintenance is too small a staff and not properly organized (section 3).

The problems in Operations and Surveillance are caused by inadequate management overview (Items 1 and 4).

The facility staff cannot properly support both routine activities and ccomittee review (Section 8).

The licensee group which coordinates the contracted In-Service Inspection (ISI) e f fo..-ts

. appears to need additional technical expertise to provide adecuate contract control (Ite= 11).

Little assurance exists that the present licensee staff can provide adequate oversight and ensure that current and future work will not result in deficient designs and installations (Section 12).

Design changes were i=plemented without the ccmmittee 's prior submittal to the -NRC for approval (Section 10)'.

Licensee needs to ediuate operational and supporting staff adequacy under emergency conditions (Section 15).

4.

E&C Divisicn is reviewing the engineering workload.which exists and is foreseen fer both the onsite and corporate engineering groups.

Requests will be made to establish and. fill the positions deemed necessary to scre effectively manage the engineering work.

Status As Of September 15, 1981:

The management consultant recommended the formation of a new Nuclear Engineering Department.

This Department was approved on March 27, 1981 and is to contain 81 positions.

ATTACHMENT 1 NRC Ccement The.NRC's cccments in Section 19, Management Controls, were the most severe.

The many management control problems indicate failure to properly staff and manage the nuclear facility.

Site management is. overloaded; in-house resources are inadequate; there is poor control over contractors' workload.

The lack of adequate management control is the one essential problem which overlaps other areas.

The root cause for the prebis.:

in Maintenance is too small a staff and not properly organized (Section 3).

The problems in operations and Surveillance are caused by inadequate management overview (Items 1 and 4).

The facility staff cannot properly support both routine activities and ccomittee review (Section 8).

The licensee group which coordinates the contracted In-Service Inspection (ISI) efforts appears to need additional technical experrise to provide adeqcate contract control (Item 11).

Little assurance exists that the present licensee staff can provide adequate oversight and ensure that current and future work will not result in deficient designs and installations (Section 12).

Design changes were implemented I

without the cccmittee 's prior submittal to the -NRC for approval (Section 10).

Licensee needs to efifrinate operational and suppcrting staff adequacy under emergency conditions (Section 15).

5.

The Pcwer Stationa Depart =ent is reviewing the workload of the Licensing and Ccmpliance Section to establish a manning level.

Request approval to establish, fill and train, as necessary, sufficient positions, both technical and clerical, in the Licensing and Compliance Section so tha.t group can function more effectively.

Status As Of September 15, 1981:

Additional positions were approved in the Licensing and Compliance Section.

Recent resignations have prevented attaining any significant increase in manpower levels however.

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ATTACILMENT 1 NRC Comment i

The.NRC's comments in Section 19, Management Controls, were the most severe.

The many management control problems indicate failure to properly staff and manage the nuclear facility.

Site management is overloaded; in-house resources are inadeqcate; there is poor control over contractors

  • workload.

The lack of adecuate management control is the one essential problem which overlaps other areas.

The root cause for the proble:.:

in Maintenance is too small a staff and not properly organized (Section 3).

The proble=s in Operations and Surveillance are caused by inadequate managemenu overview (Items 1 and 4).

The facility staff cannot properly support both routine activities and ccmmittee review (Section 8).

The licensee group which coordinates the contracted In-Service. Inspection (ISI) efforts appears to need additional technical expertise to provide adecuate contract control (Item 11).

Little assurance exists that the present licensee stafd can provide adequate oversight and ensure that current and future work will not result in deficient designs and installations (Section 12).

Design changes were implemented without the committee's prior submittal to the -NRC for approval (Section 10).

Licensee needs to efdicate operational and suppcrting staff adequacy under emergency ccnditions (Section 15).

6.

The Pcwer Stations Deparr=ent is reviewing the potential for promoting technical people f cm other locations into the Beaver Valley organiration.

Status As Of September 15, 1981:

i opportunities in the Nuclear Division have been discussed with individuals who have qualifications useful to the Division and we have been successful in attracting several individuals to the Division.

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ATTACHMENT 1 4

NRC Comment _

The.NRC's comments in Section 19, Management controls, were The many management control problems indicats i

Site failure to properly staff and manage the nuclear facility.

the most severe.

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management is overloaded; in-house resources are ina equa e; there is poor control over contractors' workload.

R il The lack of adequate management control is the one essent aT problem which overlaps other areas.in Maintenance is too sma The problems in Operations and Surveillance are (Items 1 and 4).

The (Section 3).

caused by inadequate management overviewfacility staf The licensee group which (Section 8).

) efforts and committee review coordinates the contracted In-Service Inspection (ISI ide adequate appears to need additional technical expertise to provLittle assurance contract control (Item 11).

present licensee staff can provide adequate oversight and ensur l

i t designs that current and future work will not result in defic enDesign change and installations (Section 12).

oval without the ccmmittee's prior submittal to the -NRC for ap (Section 10).

(Section 15).

staff adequacy under emergency conditions The Power Stations Department is reviewing the work being performed by technical personnel to determine 7

j nating time now being devoted to work which could be better done by clerical persennel or improved by greater clerical support.

1981_:

Status As Of September 15, tial The manpower study completed in March, 1981 recommended substan These clerical additional clerical support for technical personnel.

jobs are currently in the process of being filled.

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l ATTACHMENT 1 NRC Comment The.NRC's comments in Section 19, Management controls, were The many management control problems indicate the most severe.

Site failure to properly staff and manage the nuclear facility.

management is overloaded; in-house resources are inadecuate; there is poor control over contractors' workload.

The lack of adequate management control is the one essential The root cause for the problems problem which overlaps other areas.

in Maintenance is too small a staff.and not properly organized (Section 3).

The problems in operations and Surveillance are caused by inadequate management overview (Items 1 and 4).

The facility staff cannot properly support both routine activities and committee review (Section 8).

The licensee group which efforts coordinates the contracted In-Service Inspection (ISI) appears to need additional technical expertise to provide adeqcate contract control (Item 11).

Little assurance exists that the present licensee staff can provide adequate oversight and ensure that current and future work will not result in deficient designs and installations (Section 12).

Design changes were implemented without the committee's prior submittal to the -NRC "for approval Licensee needs to efdiuate operational and supporting l

(Section 10).

staff adequacy under emergency conditions (Section 15).

8.

The Personnel Department will develop a program to recruit exeerienced engineers and other technical people to meet the needs established by E&C and Operations Divisions and approved by ranagement.

L Status As Of September 15, 1981:

Activities to recruit experienced engineers and other technical personnel have been undertaken but have met with limited success to date.

Company efforts to recruit experienced personnel will be expanded to improve performance in this area.

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ATTACHMENT 2 Commitments Made In Duquesne Light Company Letter Dated April 2, 1981 1

1.

Add 1tional clerical and stenographic personnel *.-ill be provided to assist key station work groups in processing and filing of paperwork.

These vill permit more time to be spent by these individuals in managing and supervising work activities.

Status As Of September 15, 1981:

Twenty-eight (28) positions have been established and fourteen (14) have been filled.

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ATTACHMENT 2 Commitments Made In Duquesne Light Company Letter Dated April 2. 1981 2.

Three additional supervisors for the instru=ent These vill provide closer supervision and more effective controland control grou of the performance of the instru=ent surveillance program and the mainre=ance of the security computer.

Status As Of September 15, 1981:

One (1) additional Instrument and Control Foreman position has been established and was filled on September 1, 1981.

One (1) additional Instrument.hgineer position has been established and has not yet been filled.

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An additional Electrical Maintenance Engineer and an additiona These vill provide for full 3.

Mechanical Maintenance Engineer.

time service on the Onsite Safety Co==.ittee without l

detracting fron the required technical direction of the work force.

15, 1981:

Status As Of September r position has been i

One (1) additional Station Electrical Maintenance Eng nee established and has not yet been filled.

i r position has been One (1) additional Station Mechanical Maintenance Eng nee established and has not yet been filled.

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ATTACHMENT 2 ComrItmentsMadeInDuquesneLightCompanyLetterDatedApril2,1981 4

Additional personnel in the Licensing ac:1 Cocpliance group to relieve station operating and =aistenance superrision from the large majority of special studies and investigations required to respond to regulatory requests.

Status As Of September 15, 1981:

An additional thirteen (13) Engineering positions have been established and six (6) have been filled.

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ATTAC10ENT 2 Commitments Made In Duquesne Light Company Lettar Dated April 2. 1981 5.

Three additional Quality Control Inspectors and two additional Quality Control Engineers.

These vill provide for additional coverage of ongoing work activities and the ability to provide assistance to station work groups by responding to requests for advice in the developnent of work procedures and by the conduct of special studies related to inproving the quality of the work.

Status As Of September 15, 1981:

Three (3) additional QC Inspector positions have been established and two (2) are being processed to be filled.

Two (2) additional QC Engineer positions have been established and have not yet been filled.

ATTACHMENT 2 Commitment $ Mad 7 In Duque'n7 Light Comp.ny Lett7r Dat'd April 2, 1981 6.

Thirteen additional House and Yard Laborers and two Building Maintenance Fore:nen.

These individuals vill implement a station cleanliness program.

Status As Of September 15, 1981:

Thirteen (13) additional House and Yard Laborer positions have been established and have been filled.

Two (2) additional Building Maintenance Foreman positions have been established and are being processed to be filled.

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ATTAC}C2NT 2 Commitments Mada In Duquen7 Light Company Lett':r D'ted April 2. 1981_

7.

A group of 16' additional Start-Up Operators have been added to the

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station staff during this calender year.

This group will provide a stable work force in the plant attendar.t category.

t This group s-ill not be removed from shif t assigucents to partici-pate in the licensed operator training program but s-ill function per=anently as plant attendants.

This vill provide a stability of the work force which is presently lacking in this area due to the existing practice of rotating the Nuclear Operators into the classroom phases of the program.

We anticipate a marked i= prove-ment in the perfor=ance of the work activities remote fro = the controlroom to result from this change in our staffing and train ing philosophy.

Status As Of September 15. 1981:

Sixteen (16) additional Start-Up Operator positions have been established and filled.

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