ML20078P723
| ML20078P723 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/03/1983 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Buck J, Edles G, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-SP, NUDOCS 8311080204 | |
| Download: ML20078P723 (42) | |
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November 3, 1983 we,,, m,,.mEC,,,a,
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(202) 822-1084 Administrative Judges Gary J. Edles, Chairman John H. Buck Christine N. Kohl Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D.C.
20555 IN THE MATTER OF METROPOLITAN EDISON COMPANY (Three Mile Island Nuclear Station, Unit 1)
Docket 50-289 SP (Restart)
Dear Chairman Edles and Judges Buck and Kohl:
On July 26, 1983, we distributed to the Appeal Board and parties a copy of Licensee's " Responses to Recommendations of Basic Energy Technology Associates, Inc. Set Forth In Their Report Dated February 28, 1983."
Enclosed is an updated status of Licensee's response to the February 1983 Beta Report.
Respectfully submitted, k
sh l
Ernest L.
Blake, Jr.,
Counsel for' Licensee cc:
Attached Service List l
8311080204 831103 PDR ADOCK 0S000289 G
ppg s
n
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
- ^'
(Three Mile Island Nuclear
)
Ph e
Station, Unit No. 1)
)
SERVICE LIST Administrative Judge Administrative Judge Gary J.
Edles, Chairman Ivan W.
Smith, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Sheldon J. Wolfe John H. Buck Atomic Safety & Licensing Board Atomic Safety & Licensing U.S. Nuclear Regulatory Commission Appeal Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 Gustave A.
Linenberger, Jr.
Atomic Safety & Licensing Board Administrative Judge U.S. Nuclear Regulatory Commission Christine N.
Kohl Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Jack R. Goldberg, Esquire (4)
Office of the Executive Atomic Safety & Licensing Legal Director Appeal Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Docketing & Service Section (3)
Douglas R. Blazey, Esquire Office of the Secretary Chief Counsel U.S. Nuclear Regulatory Department of Environmental Commission Resources Washington, D.C.
20555 514 Executive House P. O. Box 2357 Harrisburg, PA 17120
a I
John A. Levin, Esquire Ms. Gail Phelps Assistant Counsel ANGRY /TMI PIRC Pennsylvania Public Utility 1037 Maclay Street Commission Harrisburg, PA 17103 Post Office Box 3265 Harrisburg, PA 17120 Ellyn R. Weiss, Esquire (1)
William S. Jordan, III, Esquire (1)
Mr. Henry D.
Hukill Harmon & Weiss Vice President 1725 Eye Street, N,W.,
Suite 506 GPU Nuclear Corporation Washington, D.C.
20006 Post Office Box 480 Middletown, PA 17057 Michael F. McBride, Esquire LeBouef, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Suite 1100 Washington, D.C.
20036 Ms. Louise Bradford TMI ALERT 1011 Green Street Harrisburg, PA 17102 Mr. Norman Aamodt R. D.
5 Coatesville, PA 19320 Joanne Doroshow, Esquire The Christic Institute 1324 North Capitol Street Washington, D.C.
20002 Michael W. Maupin, Esquire Hunton & Williams 707 East Main Street Post Office Box 1535 Richmond, VA 23212 David E. Cole, Esquire Smith & Smith, P.C.
2931 Front Street Harrisburg, PA 17110 Administrative Judge Gary L. Milhollin Atomic Safety & Licensing Board 1815 Jefferson Street Madison, Wisconsin 53711 l
-.. a RESPONSES TO RECOMMENDATIONS OF BASIC ENERGY TECHNOLOGY ASSOCIATES, INC.
AS SET FORTH IN THEIR REPORT DATED RBRUARY 28,1983 SORT BY BETA FINDNG GPU NUCLEAR CORPORATION THRD QUARTER 1983 STATUS UPDATE NOVEWER 1,1983
'l
6 3
e a
i Preface The review of current and projected expe..
res and manpower utilization for GPU Nuclear Corporation conducted by Basic Energy Technology Associates, Ini_., BET A) was issued in a report dated Feb. 28, 1983.
The focus of the review was on resources devoted to Three Mile Island Unit I and Oyster Creek. A total of L
eighty-five (85) findings resulted in one hundred fif ty-six (156) separate recnmmendations.
4 This report represents the GPUNC Response. The 156 recomendations (paraphrased) have been assigned to one of five (5) broad categories:
l.
Org.3nization - understanding and working within the functional GPUN structure.
1
- 11. Manning - appropriate staffing levels.
111. Operat 'ng/Managemen t Ef ficiency/ Product iv ity IV. Personnel-Related Matters - personnel practices.
V.
Traininq Within each of the above categories, responses have been placed into one of five classifications (STATUS CODE):
A.
Agree - Complete: agree with recommendation, action is complete.
4 B.
Agree - Action Underway / Goal: agree with recommendation, action is underway and/or action is a 1983 goal.
C.
Agree - Action to be Scheduled: agree with recomendation, action to be taken in the future.
D.
Under - Evaluation: either recommendation or appropriate action is under evaluation.
E.
Disagree: disagree wi th recommendation.
This report is sorted by BETA finding and recommendation.
Appendix A provides a listing of those GPUNC 1983 Corporate and/or Division Goals and Objectives ref erenced in recommendation responses contained in this report.
The GPUNC Response Report (sorted by BETA finding) will be updated quarterly. This revision contains 3rd quarter 1983 updated status. Since the last update, 31 additional open items have been completed (as noted by asterisk
.in the comment column) for a total complete or disagree of 83.
Seventy-three items remain open.
I k
I 10/28/83
e i
P TABLE OF CONTENIS BETA FINDINGS & RECOMMENDAil0NS PAGE t
l TMI-1 Plant and Division 1-4 O.C. Plant and Division 5-11 Nuclear Assurance Division 12-15
(
Technical Functions Division 16-19 Administration Division 20-24 Human Resources Division 25 Radiological & Environmental Controls Division 26 Maintenance & Construction Division 27 i
Communications Divison 28 General 29-33 4
i r
P 4
l 4
i t
10/26/83 BETA REPORT - GPUNC RESPONSES BY BEIA FINDING BETA FINDING /
STAluS RECOMMEND.
PARAPHRASED RECOMMENDATION & StNMARY RESPONSE M.
DIVISION CODE COMMEN TS TMI-l Findings & Reconssendations Finding III-A:
The role of the Director THI-l needs to be clarified and strengthened with respect to his over-all site responsibilities.
Ill-A (a)
Rec:
Of fice of the President f oster understanding I.
0/P B
4th Q 1983 of how functional organization should operate.
Resp:
Continuing ef f ort reflected in Corporate a)JectIve 5.
In 1983, Corporate Goal 9 & Management Training Program respond directly.
Ill-A (b)
Rec:
Continue emphasis on support role of non-plant divisions.
I.
0/P B
4th Q 1983 Resp:
Continuing effort reflected in Corporate Gijective 5.
Added specific wording to Plant Division Functions Strengthened Plant Division role in Budget Process Ill-A (c)
Rec:
Emphasize elimination of jurisdicticial disputes.
I.
0/P A
Complete Resp:
Covered in Corporate & Divisional Staff Meetings &
during Inter-divisional work progress / status meetings.
Substantial improvement achieved.
Ill-A (d)
Rec:
Encourage support and working within new organization.
I.
THI-l B
4th Q 1983 Resp:
Being met by THI-I Goal 2.
TMI Division Staf f meetings included Support Divisions and this issue was addressed directly and indirectly. Reconnend close-out 4 th Q 1983.
til-A (e)
Rec:
Encourage freer discussion among divisions.
1.
0/P B
4th Q 1983 Resp:
1983 Corporate Goal 9 directly addresses issue.
Ill-A (f)
Rec:
Encourage upward not downward corporate policy 111.
0/P B
4th Q 1983 complaints.
Resp; Continuing ef fort reflected in Corporate Objective 5.
1983 Corporate Goal 9 and managenent program respond directly.
Finding III-B:
The positions for five " engineers" presently reporting to the THI-l Manager, Plant Operations should be better defined 111-B Rec:
Better define role of five engineering positions II.
IMI-1 A
Conplete*
l reporting to Plant Operations.
Resp:
There are five operational engineers assigned to Plant Operations. Position descriptions have been prepared.
Positions have been reviewed and are considered ap-propriately located within the organization. (Five positions are 2 Primary Plant Engineers,1 Secondary Plant Engineer, I Radwaste Engineer and 1 Trainee.)
~.
10/26/83 BETA FINDING /
SIAIUS RECanMEND.
PARAPHRASED RECOMMENDATION f. StHMARY RESPONSE CAT.
DIVISION CODE COMENIS Finding III-C:
Maintenance at IMI-1 can improve its support of the plant.
III-C (a)
Rec:
Schedule more day shif t maintenance work and ensure III.
TMI-I A
Complete stronger supervisory support.
Resp:
Personnel changes have been implenented to ensure strong supervisory support on day shif t.
Complete but will monitor for proper implenentation.
!!I-C (b)
Rec:
Assign system responsibility in P lant Engineering I.
IMI-I B
Ist Q 1984 l
for maintenance tasks.
Resp:
Plant Engineering Director has scheduled trip to DC to review their revised P.E. organization.
Following this review, a proposal will be submitted to 0/P. Goal is to assign responsibility for each plant system to a specific engineer.
[
III-C (c)
Rec:
Dela assignment of corrective maintenance 0/P C
4th Q 1983 func ton to M8C untti after Unit I restart.
Resp:
Re-evaluation postponed to 4th Q 1983.
Finding Ill-D:
Major deficiencies in the chenistry program at IMI-l were identified two years ago. Corrections have been slow.
III-D Rec:
Upgrade of chemistry program, key manager, standard-Ill.
T. F./
B Ist Q 1984 l
i ize analytical procedures.
THI-l Resp:
TMI-1 Goal & Objective 3.
Simificant progress has been made; however,1st quarter 1984 Detter target date because of large scope and ef fort required.
l Finding III-E:
The nunber of different engineering groups at the site is contributing to loss of ef ficiency.
III-E Rec:
Review number of site engineering groups and their 11.
0/P A
Complete
- l direction with objective of reducing their number (all appilcable divisions).
Resp:
Combination of Functional Organization and use of gen-eric titles (Engr. I, etc.) Essentially all positions tends to give appearance of large nunber of groups.
identified require engineering background. Review complete.
i I
--. - ~
l-10/26/83 BETA i'
FINDING /
STAIUS RECOMMEND.
PARAPHRASED RECOMMENDAll0N & SlNMARY RESPONSE CAI.
DIVISION CODE COMMEN IS Finding Ill-F:
There are too many instances where rad controls are not as good as they should be.
The work force has not accepted enough of the responsibility for high quality rad work performance. Excessive generatinn of radioactive waste is part of these probl ems.
Ill-F (a)
Rec:
Increase efforts of manager and supervisors to achieve III.
IMI-1 8
4th Q 1983 excellent radiological performance by their workers on every job.
Resp:
Significant prgress made on IMI-I goals 5 and 8.
Skin contaminations are however, still above goal.
Other parameters are at or below goal. Will close out action in 4 th Q 1983 but will remain an ongoing ef fort.
Ill-F (b)
Rec:
Improve Rad Con management and work force IV.
R&EC/
A Complete management work ing relationships.
IMl-1 Resp:
Experience with OTSG and other work shows current organization and personnel working well together.
Ill-F (c)
Rec:
Upgrade rad. technician performance by improv-III.
R&EC B
4th Q 1983 l
ing ability to identify and report deficiencies.
Resp:
Cyclic training specifically addresses recom-mendation; increased number of RDR's sthmitted by technicians indicate improvement.
Ill-F (d)
Rec:
Speed correction and problem sniving of rad.
III.
RLEC/
A Conplete deficiencies.
THI-I Resp:
Response to Ill-F-(c) will help on this. Efforts underway to provide T. F. assistance on recurring items requiring engineered solution.
til-F (e)
Rec:
Look to decrease number of rad. techs. as work II.
R&EC B
3rd Q 1984 l
force practices good rad. work performance.
Resp:
Will be addressM in setting '84 & ';BS authorized levels of manpower. For 1984 the nunber of rad.
f, techs will be reduced if-the plant goes on line; This is not due to improved rad work practices.
III-F (f)
Rec.
Achieve recommendations III-F(a) through Ill-F(e) 111.
R&EC/
A Complete re: radiological practices without new systems TMI-1 and gimmid(s.
Resp:
No new systems or gimmicks have been used.
See responses to Ill-F(a) through lil-F(e).
a
10/26/83 BETA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE
CAT.
DIVISION CODE COMMENIS Finding Ill-G-1: The warehouse inventory records have enough nomenclature inaccuracles to degrade ef ficiency.
Ill-G-1 Rec:
Program to improve nomenclature of inventory records.
Ill.
Admin./
B 4 th Q 1983 Resp: Physical inventory complete. Warehouse discrepancy TMI-1/
reports being used. Systematic program and schedule MLC MLC Division will support to be set 4Q'83. Warehouse discrepancy reports being Materials Management in this used ef fectively, ef fort to improve nonencla-ture of inventory records.
Finding III-G-2: The amount of stock at TMI is excessive.
Ill-G-2 Rec:
Purge TMI stock of unnecessary material.
III.
Admin.
B 4th Q 1984 Resp: Program underway. Admin Division Goal for 1984.
Finding III-G-3: The period of time from preparation of a requisition to delivery of purchased material is too long.
III-G-3 Rec:
Plant Engineering prepare generic specs. for com-III.
IMI-I C
Ist Q 1984 monly used materials and consumable stock items.
Resp: All Purchase Orders being reviewed. Will under-take general program af ter Restart. Some generic specs being produced on a case-by-case basis.
Finding III-H:
There is a need for the TM1 Iluman Resources group to improve further their responsiveness to site needs.
III-H Rec:
Review manning and effectiveness of Human Resources II.
H. R.
A Conplete support of TMI-l Resp: Effectiveness substantially improved. Manning will be addressed as part of XII-E.
Finding III-1:
A review of the number of people assigned to adninistration work at THI-l appears excessive, 111-1 Rec:
Look to reduce on-site clerical / admin. support II.
THi-l B
3rd Q 1984 l.
Resp: Operations Analysis is currently studying division-by-division beginning with the Administration Division.
Plans are in place to reduce the TMI Information Center by 73 temporaries by 12/83 and by 8 GPU System employees ny 12/84.
1 4
i 10/26/83 BETA FINDING /
SIAIUS 1
REC (NMEND.
PARAPHRASED RECOMMENDATION & SINMARY RESPONSE CAT.
DIVISION C00f CtK4? MIS l
Oyster Creek Findings & Reconnendations Finding IV-A-1: The role of the Director, Oyster Creek needs to be clarified and sts tegthened with respect to the overall site operation.
i IV-A-1 (a)
Rec:
Office of the President foster understandtog I.
0/P B
4th Q 1983 of how functional organization shonid operate.
g Resp:
Continuing ef fort reflected in Corpwate tbjective 5.
In 1983, Corporate Goal 9 L Hanagement Training 1
Program respond directly.
IV-A-1 (b)
Rec:
Continue emphasis on support role of non-plant divisions.
I.
0/P B
4th Q 1983 Resp:
Continuing ef fort reflected in Corporate Objective 5.
)
l Added specific wording to Plant Division Functions I
Strengthened Plant Division role in Budget Process IV-A-1 (c)
Rec:
Emphasize elimination of jurisdictional disputes.
I.
0/P A
Complete Resp:
Covered in Corporate & Divisional Staff Meetings &
during Inter-divisional work progress / status meetings.
Sibstantial improvement achieved.
l IV-A-1 (d)
Rec:
Encourage support for and working with'in new 1.
O. C.
B 4th Q 1983 i
wgan iza t ion.
Resp:
0.C. Div. Staf f meetings include Support Divisions and this issue is addressed directly and indirectly. Experience during O.C. Outage will rapidly mature organization.
t IV-A-1 (e)
Rec:
Encourage freer discussion among divisions.
I.
0/P B
4th Q 1983 Resp:
1983 Corporate Goal 9 directly addresses issue.
IV-A-1 (f)
Rec:
Encourage upward not downward corporate policy ill.
0/P B
4th Q 1983 compla in ts.
l' Resp:
Continuing effort reflected in Corporate Objective 5.
1983 Corporate Goal 9 and n.anagement program respond i
directly.
1 j
Finding IV-A-2: The functions now performed by Plans and Programs could be accomplished more efficiently.
IV-A-2 (a)
Rec:
Hold section to current size (Plans & Programs).
II.
O. C.
A Conplete Resp; Size has been held.
IV-A-2 (b)
Rec:
Use O.C. Plans and Programs section as service 1.
O. C.
A Complete
}
not line authority organization - coordinator I
Resp:
Role has been clarified - Ref: PRC memo of 2/11/83.
-E-4
(
10/26/83 BETA FINDING /
STATUS RECOMMEND.
PARAPIIRASED RECOMMENDATION & SlHMARY RESPONSE CA I.
DIVISION CODE COMENTS finding IV-B:
There is a lack of involvement by Operations in Oyster Creek operator training.
I V-B Rec:
Ensure Operations involvenent in Dyster Creek V.
0.C.
A Conplete training programs.
Resp:
Steps to increase Operations Department involvement in operator training have been t ak en. OC Objectives 7 and 10.
i F_inding IV-C:
Workers do not pick up af ter themselves.
IV-C Rec:
Management to emphasize worser tidiness in job III.
M&C/
B 4th Q 1983 p er f ormance.
0.C.
i Resp:
Oyster Creek Objective 4 Still a problem, especially with contractors. M&C Managenent has emphasized worker tidiness in job performance.
This is an ongoing process. Periodic checks are being performed by supervisory personnel on both on-and of f-shif t tours.
Finding IV-D-1: The ability to perform maintenance on the plant in order to assure a reasonable degree of reliability needs substantial improvement.
IV-D-1 (a)
Rec:
Senior PRC personnel increase involvement in I.
M&C B
4th Q 1983 organizational and divisional interface problems.
I Resp:
Being addressed by PEC Div. participation in DC Ongoing ef fort.
outage meetings and M&C Div. meetings with M&C l
maaapnt at 0.C. dowr, through area supervisors.
]
FEC is routinely represented at Site Director meetings.
PRC is complying with this recommendation.
4 IV-D-1 (b)
Rec:
Other site management must increase involvenent 1.
M&C /0.C./
A Conplete 4
in resolving interface problems resulting fran R&EC/N. A.
maintenance realigranent.
Resp:
Efforts by Division Directors including Staf f meet in gs. Outage coordination, etc., have sub-stantially reduced interface prdblems.
I IV-D-1 (c)
Rec:
Ensure familiarity and practice of new maintenance III.
M&C/
B 4 th Q 1983 pr ocedures.
0.C.
Resp:
Dyster Creek Objective 5.
Experience to date satisfactory. PRC Division is complying on an onping basis; incorporated as part of Uie re-quired training.
4 4 1 l
10/26/83 o
o BETA FINDING /
SIAIUS RECOMMEND.
PARAPilRASED RECOMMENDATION & SlHMARY RESPONSE CA T.
DIVISION CODE COMMENTS Finding IV-D-2: The sanctity of cof fee breaks at Oyster Creek is a sizeable contributor to poor productivity.
IV-D-2 (a)
Rec:
Negotiate morning cof fee break out of union agreement.
IV.
- 11. R. /
E Disagree Resp:
Part of the Labor / Management Agreenent; would be very O. C.
cunplex to change and the conclusion is to not attenpt the change.
IV-D-2 (b)
Rec:
Eliminate p.m. break or allow managenent to IV.
- 11. R./
C 4th Q 1983 determine timing.
O. C.
Resp:
Management has ability to set whether break is allowed and if so, the timing. Managenent rights identified to all managers and tupervisors by JCP&L in training programs. Plan is to address this throupi supervisory training af ter negotf a-tions are concluded.
Finding IV-D-3: Mechanics under contract through PEC do not stay on the job until the end of normal working hours.
4 l
IV-D-3 Rec:
Keep M&C contractor employees on job until end of I V.
M&C/
A Conplete a working hours.
0.C.
Resp:
Contractor shif t schedules have been f ormalized and received by Site Director. Contractor work hours in accordance with contract.
Finding IV-D-4: Only a fraction of the preventive maintenance routines planned for accomplishment are completed.
IV-D-4 (a)
Rec:
Expedite loading preventive maintenance systen III.
O. C.
B 4 th Q 1983 schedule in GMS.
Resp:
Oyster Creek Materiel Department Goal f or '83 (OC 32) PMS schedule is being loaded into a progran, g
IV-D-4 (b)
Rec:
Learn from TMl-1 preventive maintenance program.
III.
O. C.
A Conplete Resp:
Direct P.M. liaison established and functioning.
IV-D-4 (c)
Rec:
Consider reducing Preventive Phintenance Manager's II.
O. C.
D 3rd Q 1984 staf f when program stabilizes.
Resp:
Will address in '85 budget based on first half
'84 experience.
Finding IV-D-5: Mobile maintenance is a costly way to perform plant maintenance.
l I V-D-5 ( a&b) Rec:
Consider negotiating agreements with better utili-IV.
M&C B
4 th Q 1983 zation of Mobile Maintenance. Consider making Mobile Maintenance enployees who perform most of their work at Oyster Creek part of M&C Division.
Resp:
Proposals submitted to JCPR f or negotiations.
l.
10/28/83 BETA FINDING /
STAlUS RECOMMEND.
PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE
CAT.
DIVISION CODE COMMEN IS Finding IV-E:
Problems in performance of the chemistry control program at Oyster Creek were found to be similar in the problems at IMI-1.
IV-E Rec:
Continue upgrade of chem. program - designate key Ill.
- 1. F./
8 4 th Q 1983 manager, standardize analytical procedures.
O. C.
Resp:
Progress is being made consistent with recomien-dation. Chemistry function has been transferred fran Engineering to Operations and the Chemistry Manager is providing the required leadership.
Conpletion of Oyster Creek 1983 tbjective 10 and related Operations Department Objectives 21 to 25 will conplete response. Continued chemistry program upgrade results are highly satisfactory. NRC/QA audits have resulted in no findings. Procedure rewrite is 991 complete. New QA/QC procedure has been written, new instrumentation installed, daily review of all chemistry results, and current cogni-zance of chemistry of miscellaneous systems ongoing.
Finding IV-F-1: There are too many separate section level groups having engineers at Oyster Creek.
IV-F-1 Rec:
Provide lead site representat ive f or each Division II.
O. C./
0 4 th Q 1983 for nontechnical items.
TMl-1 Resp:
Will continue to evaluate but improved understanding of roles and Divisional internal guidance has largely 4
achieved resuit.
Finding IV-F-2: The projected manpower level is high for the Oyster Creek Nuclear and Core Management group.
IV-F-2 (a)
Rec:
Develop operating procedures to reduce dependence on 111.
O. C.
B 4 th Q 1983 Core Management Group (Nuclear and Core Management).
Resp:
Implementation of power shape monitoring system will reduce dependence on Core Engineering.
0.C. Plant Engineering Department Objective 46.
IV-F-2 (b)
Rec:
Assure no duplicate ef forts with TF Nuclear Analysis 1.
T. F./
A Conplete and Fuels section (0.C. Nuclear & Core Management)
O. C.
Resp:
Review shows no overlap. Improved coordination has developed.
IV-F-2 (c)
Rec:
Re-evaluate and look to reduce staffinq level of fore ~
II.
O. C.
E Disagree l
Management Group.
l Resp:
Evaluation of requirements indicates a staf fing of six engineers and a manager / supervisor is required.
Reduction of one engineer from Plant Engineering planned for 1984, not specifically from Core Group.
10/26/83 BETA FINDING /
SIAT95 RECOMMEND.
PARAPHRASED RECOMMENDATION & StNMARY RESPONSE CAT.
DIVISION CODE COMMENTS Finding IV-G:
There are too many instances wtere rad controls are not as good as they should be.
The work force has not accepted enough of the responsibility f or high quality rad work perf ormance. Excessive generation of radioactive waste is part of these problems.
[
IV-G (a)
Rec:
Increase management ef forts to obtain excellent radio-111.
R&EC/
B 4th Q 1984 logical performance by their workers routinely on jobs.
0.C. /ME Resp:
This is an ongoing ef fort which is supported by Oyster Creek, ME and R8EC senior people. The Radiological Assessment program, plant tours by management and Radio-logical Deficiency Programs are being used to monitor progress on this ef fort. Has been incorporated into the ME 5-Year Plan and a man rem reduction program is.
i included as a 1984 ME Division Goal. Attention will i
be focused on pre-planning the radiological aspect of selected jobs.
IV-G (b)
Rec:
Improve Rad Con management and work force management 1.
R&EC B
4th Q 1983 work ing relationships.
0.C. /ME Resp:
Preparation for and initial work during outage have i
resulted in substantial improvements in working rela-l tionsh ips. Will continue to address throughout 1983.
A Radiation Awareness Connittee has been formed and t
has held routine meetings since 5/20/83. See responses to IV-G(a) and (c).
i IV-G (c)
Rec:
Use radiological awareness committee similar to Ill.
0.C. /M&C /
A Complete
- I that at TMI-l to help in accomplishing recommen-REE l
1 dations IV-G-(a) and (b).
Resp:
An 0.C. Radiological Awareness Con.nittee was
[
8 established and has functioned since 5/20/83.
IV-G (d)
Rec:
Upgrade performance of rad. con. techs. by improving 111.
R&EC A
Complete
- l rad. deficiency identification and reporting.
Resp:
Ef forts continue via cyclic and seninar tralning; improvements have been as indicated by fewer find-ings of posting and labeling deficiencies by O. C.
Rad Assessor. Effective implenentation to continue.
IV-G (e)
Rec:
Accelerate correction of rad. deficiencies and III.
R&EC/T.F.
A Complete
- I increase attention to problem solving.
0.C /ME/
Resp:
The response to Reconenendations IV-G-(a), (c) and (d) will help on this issue as well. Also, efforts are underway to get assistance from Technical functions on recurring problems that require engineered solutions.
Backlog of open rad. deficiencies has been significantly l
reduced and enphasis placed on this area by f ormation I
of the Rad Improvement Connittee in 8/83. -
I 10/28/tt)
BEIA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMMENDATION & SINMARY RESPONSE CAT.
DIVISION CODE COMMENTS IV-G (f)
Rec:
Look to decrease number of rad. techs. as work II.
R&EC B
3rd Q 1984 l
force practices good rad. work performance.
Resp:
Will be addressed in setting '84 & '85 authorized Complete for 1983.
g levels of manpower. Will reduce number of Coapany rad. techs as work practices improve.
IV-G (g)
Rec:
Commence rad technician training to handle unusual V.
REC /
A Complete situations not covered by written procedures (Rad. Con.)
- 0. C.
Resp:
Emergency drills and seminars initiated and being held on a recurring basis. Each session is documented.
IV-G (h)
Rec:
Utilze existing management systems to achieve III.
REC /
A Complete improvement in radiological practices.
0.C./MAC Resp:
AII related recommendations are being carried out using the present management systems.
Finding IV-H:
Senior management people at Oyster Creek are spending too much time on PORC matters.
IV-H Rec:
Review Tech. Specs to determine if present wording Ill.
O. C.
B 2nd Q 1984 requires PORC to review documents beyond a scope considered appropriate. No rewrites by PORC of poorly written procedures.
Resp:
Tech Spec Change Request has been submitted which NRC action required.
will meet this recommendation. Equivalent issue Expect implementation under new review procedure will be addressed during early 1984, implementation of new administrative procedures.
Finding IV-I:
The number of people assigned to adninistrative work at Oyster Creek appears excessive.
IV-I Rec:
Reduce on-site clerical and administrative positions.
II.
0/P D
1st Q 1984 (All divisions.) Office of the President set arbitrary numb er.
Resp:
Is being addressed in overall manning: Operations Analysis will study IQ'84.
Finding IV-J-1: The purchasing operation at Oyster Creek is receiving inadequate clerical support.
IV-J-1 Rec:
Consider reassigning under-utilized clerical personnel II.
O. C.
A Complete to Purchasing to support processing of requisitions.
Resp:
Additional personnel assigned to purchasing. Routine requisitions sent to Parsippany to handle. Aspect of recomendation pertaining to under-utilized personnel will be covered in response to IV-l.._____ -
10/26/83 I
BETA FINDING /
SIAIUS RECOMMEND.
PARAPHRASED RECtNMENDATION & StNMARY RESPONSE M.
DIVISION CODE COMMENIS Finding IV-J-2: The stores and warehouse function at Oyster Creek can improve its support of the plant.
IV-J-2 (a)
Rec:
Expedite installation of CRT's in plant to give Ill.
O. C.
A C omplet e direct access to inventory records.
Resp:
CRT's at site can be used to gain access to inventory Control System.
IV-J-2 (b) ~
Rec:
Carefully plan disposal of on-hand direct turnover 111.
A.imin./
8 4th Q 1983 material not required for plant support.
O. C.
Resp:
Oyster Creek is reviewing carefully all material initially purchased for direct turnover but not subsequently required for task for which purchased to differentiate between that to be placed in stock fran that to be surplused. A warehouse corrective j
8 action plan has been developed.
IV-J-2 (c)
Rec:
Consider staging of material on a job basis.
Ill.
M&C/0.C./
A Complete Resp:
Review conducted. Proceeding to " stage" in Admin.
data base, tag stock material for specific jobs 4
and stage major jobs for outage.
Finding IV-J-3: Delays in processing invoices for payment are creating significant probleins for Purchasing.
IV-J-3 Rec:
Backlog in A/P should be promptly eliminated.
111.
O. C.
A Conplete*
Resp:
Substantial progress made. Backlog has been significantly reduced to manageable levels.
Monthly trending is in place.
4 i
I 1
f i a
f 10/26/83 BETA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMMENDATION & SttiMARY RESPONSE CAT.
DIVISION CODE COMMENIS
- l, Nuclear Assurance Findings and Recommendations Finding V-A:
The group presently assigned to Nuclear Assurance located at reading should be eliminated and the functions Reassigned to Parsippany.
V-A Rec:
Reassign budgeting and adninistrative functions I.
N. A.
A Conplete fran Reading to Parsippany.
Resp:
D. Hetrick no longer with GPUN: Function assigned in Parsippany under R. liedges.
Finding V-B-1:
There are many training and developnent courses of fered which are useful but not essential.
V-B-1 Rec:
Review Managenent Developnent courses and elimiate V.
N. A.
A Conplete*
those which do not materially contribute to safe and efficient operation of the plants.
Resp:
Extensive review of all management developnent programs have been made and present selection of programs is considered to contribute to the up-grade of managerial skills.
Finding V-B-2:
The headquarters training group is not concentrating enough on coordinating plant training efforts.
O V-B-2 Rec:
Coordinate and oversee efforts of the two site V.
N. A.
A Complete
- training groups.
Resp:
New Director, T&E is coordinating plant training efforts, establishing Dept-tmental Policies and Procedures and modifying present corporate train-ing structure.
Finding V-B-3:
There are inefficiencies in the TMI training ef fort due to a lack of meaningful scheduling. The Training Department has dif ficulty in obtaining data to schedule its training.
V-B-3 Rec:
Develop realistic training schedules on an annual basis.
V.
N. A.
B 4th Q 1983 Resp:
Ef forts to resolve scheduling problems continue to progress. Most of the remaining problems will be eliminated with development of 1984 Master training s chedul e.
Finding V-B-4:
There is an overly " understanding" attitude which prevails in the TMI Training Department, especially with respect to operator training.
V-B-4 (a)
Rec:
Minimize use of outside personnel to review training V.
N. A.
A Cupplete program, utilize in-house personnel instead.
Resp:
Will follow except for ASLB mandated audit and INPO. _ _ _ _ - _ _ - _ _ _
10/26/83 BETA FINDING /
SIAIUS RECOMMEND.
PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE
CAI.
DIVISION CODE COMMENIS V-8-4 (b)
Rec:
Concentrate on providing best training program, not V.
N. A.
A C omplete
- I proving it, q
Resp:
Ef forts to improve progran contents, instructor capabilities and delivery systems continue. T8E has developed and adopted TSD (Training Systems Development process). Training Advisory Comnittee is being f ormed.
3 4
V-B-4 (c)
Rec:
Make students more responsible for their own performance V.
N. A./
B ist Q 1984 in training.
All Div.
Resp:
Each training site has generated documents of student responsibilities when in trainig. Documents are I
being discussed for agreement with user departments.
l TM!-l Staf f is working closely with Training Department, l
both to provide qualified operators to fill Training Department requirements for instructors and to place 4
more of the responsibility for training on the Plant i
Staff and on the individuals being trained. As part of this ef fort, the Plant Staf f is coordinating the ef fort to prepare and issue the Operations Plant Training Manual, which should be completed in early 1984 Finding V-B-5:
There exists a lack of supervision of instructors in Une TMI Training Department.
V-B-5 (a)
Rec:
Review supervisory responsibilities with those V.
N. A.
A Complete assigned as supervisors of training instructors.
Resp:
T8E Supervisors attend appropriate supervisory and managenent development courses. The formal instructor evaluation programs assure that super-i visors observe their own instructors as well as those from other sections at the Training Dept.
V-B-5 (b)
Rec:
Phnager, TMI Training, improve accessibility to staf f III.
N. A.
E Disagree by relocating of fice Resp:
Of fice.ls in Traininh Building. Accessibility has been emphasized. Relocation not needed.
V-B-5 (c)
Rec:
Assign responsibility for monitoring activities in V.
N. A.
A Complete Training Building in the absence of Manager, TMI Training and Operator Training Manager.
4 Resp:
Individual supervisors and lead instructors are 4
always held responsible for monitoring the acti-vities of persons reporting to them. During sustained periods of absences (e.g. vacation, simulator training), an acting manager or super-visor is designated by memorandum.
A
10/26/83 BETA FINDING /
SIATUS l
4 RECOMMEND.
PARAPHRASED RECOMMENDATION 8.
SUMMARY
RESPONSE
CAI.
DIVISION CODE COMEN TS Finding V-B-6:
Findings reported on TMI-I Training have applicability at Oyster Creek.
]
V-B-6 (a)
Rec:
Apply reconnendations for TMl Training to training V.
N. A.
A Conplete f
program at Oyster Creek.
Resp:
Headquarters and Oyster Creek Training Departments have reviewed BETA TMI training recommendations.
i The responses in this report are applicable to all three training locations.
V-B-6 (b)
Rec:
Headquarters Training mandate the coordination of V.
N. A.
A Conplete*
training programs at TMI and Oyster Creek.
l Resp:
T8E Department Policies and Procedures have been l
developed and are being implenented as of ficial document for coordination of site training programs.
Finding V-C-l:
There are more QA engineers than necessary to carry out the requirements contained in the GPUN Operational Quality Assurance Plan.
I V-C-1 Rec:
Reduce the number of engineers assigned to QA II.
N. A.
A Conplete*
l Engineering as Technical Functions, Plant Engi-neering, and M8C mature, 4j' Resp:
The number of engineers assigned to QA has been reviewed in the Budget Process for 1984 and will again be reviewed in 1985. On the basis of where we are today (TMI-1 is still waiting restart, TMI-2 is still in a recovery mode and Oyster Creek is in a prolonged outage), it is anticipated that 1
the number of engineers assigned to QA Engineering l
j will remain the same. Activities indicated by the 1
production indices have increased. QA Engineering has looked at and continues to look at new means for l
becoming more ef ficient.
Finding V-C-2:
There are too many people assigned to Operations QA for the expected decline in the future work load.
I V-C-2 Rec:
Reduce number of QA monitors through attrition as II.
N. A.
A ConDlete*
l work force stabilizes and matures.
+
Resp:
During the 1984 Budget Review Process, the number of people assigned to Operations QA at both TMI and Oyster Creek was evaluated. Special manageeent ini-tlatives directed at TMI-1 resulted in an increase of six QA shif t engineering monitors for Unit 1.
No changes were made for Unit 2 or 0.C. since no i..
reduction in work load or production indices was projected for 1984.
-4
- l l
[
f l
l 10/26/83 l
BETA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMMENDATION & SLNMARY RESPONSE CAT.
DIVISION CODE COMMENIS Finding V-C-3:
The Manufacturing Assurance section is larger than is required for known future work.
V-C-3 Rec:
Reduce size of Nbnufacturing Assurance section as II.
N. A.
A Conplete*
l manufacturing effort associated with large modifi-cations decreases.
Resp:
The nunber of QA representatives in the Manuf acturing Assurance Section was reviewed during the 1984 Budget process. As a result of efficiencies established by that section, the number of contractor hours required to support the program has been significantly reduced but the number of @ representatives will remain the same. This will again be reviewed in 1985 budget process.
Finding V-C-4:
There is a risk associated with the new Operational QA Plan.
V-C-4 Rec:
The QA Director remain actively involved during the III.
N. A.
A Conplete implementation of the new Operational QA Plan.
Resp:
QA Director has remained involved. Implenentation complete.
Finding *J-C-5:
The TMI-l QA Department creates the illusion in the minds of others,:-st the Department is not supporting the plants.
V-C-5 (a)
Rec:
The Director, Quality Assurance, take necessary Ill.
N. A.
A Conplete positive steps to improve perception of the QA Department among senior managenent.
Resp:
Director, QA has specifically addressed this with his staff - significant improvenent noted.
V-C-5 (b)
Rec:
Division Vice Presidents encourage staff personnel Ill.
0/P A
Complete to support and assist in the execution of the Corporation's Operational Quality Assurance Plan.
Resp:
Support has been made clear by all Directors to their staff. Results evident.
s 10/26/83 i
BETA FINDING /
SIATUS i
RECOMMEND.
PARAPHRASED RECOMENDATION & StM1ARY RESPONSE CA.
DIVISION CODE COM4 NIS Technical Functions Findings & Recoinnendations Finding VI-A:
The overall ef fectiveness of Technical Functions in supporting IMI-l and Oyster Crtek is lack ing.
VI-A (a)
Rec:
Maintain present manning levels within Tech Nnctions.
II.
T. F.
A Conplete Resp:
Authorized level for 1983 was same as 1982. 1984 will be slightly lower.
f VI-A (b)
Rec:
Review methods to improve the management of the Ill.
- 1. F.
D 4th Q 1983 large engineering group within IF.
Resp:
A number of possibilities identified. Firm 4
plan 4Q'83. Technical Functions Goals I and 2.
VI-A (c)
Rec:
Evaluate and procure outside assistance to lit.
T. F.
D 4th Q 1983 train TF Managenent in supervising a large engineering group.
Resp:
A number of possibilities identified. Firm plan 4Q'83. Technical Functions Goals I and 2.
Finding VI-B-1: It is too hard and takes too long to get a Technical Functions procedure changed.
VI-B-1 Rec:
Respond to requests for changes to Engineering 111.
T. F.
A Conplet e*
l Procedures and Standards promptly.
Resp:
Initial issue of interface procedures complete.
Timeliness improved and now adequate.
~
Finding VI-B-2: The Engineering Cost Analysis section is not analyzing costs.
VI-B-2 Rec:
Redirect the efforts of the Cost Analysis section 111.
T. F.
A Conplete
- l away from cost reporting and toward cost estimating and analysis (the section's purpose).
Resp:
Cost estimating and analysis capability being developed.
initial action complete with assignment of Fiscal & Info Managenent person to T. F. to provide cost reporting.
Finding VI-B-3: Drawings have not been revised to show completion of modification work.
VI-B-3 Rec:
Revise drawings in D&D deemed necessary for operational 111.
T. F.
A Conplete*
l and maintenance purposes when Design Correction Notices are received so that drawings are current as regards modifications so no applicable DCN will be more than 6 months old.
Resp:
Engrg. Procedure EP-025 issued and describes policy on updating. Being followed by Tech Functions. Back log is being reduced.
' 4
5 10/26/83 BETA FINDING /
STAlus RECOMMEND.
PARAPHRASED RECOMMENDATION & SlHMARY RESPONSE g.
DIVIS10h CODE COMMENIS Finding VI-B-4: Rework, as measured by the number of Fleid Change Notices, is excessive.
VI-B-4 Rec:
Conduct design reviews before work is started to Ill.
I. F.
A Conplete decrease need for Field Change Notices during construction, operation, or maintenance.
Resp:
Procedures now require des ign rev iews. This has been implemented since Fall '82.
Finding VI-C:
There are too many people assigned to the Director, Licensing & Regulatory Af f airs.
VI-C (a-1)
Rec:
Effect reductions in the number of people assigned II.
T. F.
A Conple te*
to L&RA.
Resp:
Is being addressed in '84 & '85 budgets as appropriate.
g VI-C (a-2)
Rec:
Redefine U1e role of Licensing and Regulatory Af fairs I.
T. F.
A Complete (L&RA) to ensure that it acts as an interface between GPUNC and regulatory bodies.
Resp:
Role is defined adequately as interface: Recognition by other substantially improved.
Finding VI-D:
There is a lack of intimate day-to-day knowledge of the prchlems being found at the plants that require engineering support or involvement.
VI-D Rec:
Investigate means for having plant information and III.
- i. F.
A Conplete
- l problems flow into the Engineering and Design organt-zation on a routine basis, not just when if support is required.
Resp:
Specific systems and components have been assigned to of f-site engineering groups to increase day-by-day involvement. Also, most on-site Technical functions engineering groups such as Startup & Test and STA's,
' are almost fully slaffed and intimate knowledge of plant problens has becane a reality.
.I Finding VI-E-1: The Shif t Technical Advisor (STA) program at both sites, but particularly at Oyster Creek, needs to be reviewed and s treng th ened.
VI-E-1 (a)
Rec:
In the process of developing the Shif t Technical V.
T. F.
A Complete Advisor (STA) training proyam, place a' greater emphasis on providing the trainee with a firm technical foundation and less on making him a quallfled operator.
Resp:
STA program has been revised to provide technical saphasis in addittor. to operating information.
e
s
- 10/?6/83 i
BETA FINDING /
SIAIUS RECOMMEND.
PARAPHRASED RECOMTNDATION & SUMMAHY RESPONSE CAT.
DIVISION CODE COMKNIS VI-E-1 (b)
Rec:
Consider eliminating the requirenent that SIA's 1.
T. F.
A Ctmplete i
obtain an SRO license.
~
Resp:
Have completed evaluation. License requirenent will be continuej.
VI-E-1(c)
Rec:
Ensure that suf ficient STA's are in the training V.
- 1. F.
A Complete program to canpensate for attrition and to satisfy prunised rotation at the same 'ime.
Resp:
1M1 and 0.C. have adequate nutaers.
VI-E-1 (d)
Rec:
Review responsibilities of the STA's during normal V.
I.F./
8 4th Q 1983 l
and abnormal situations with the STA's and with shif t 0.C./
superv isor s.
TMI-l Resp:
Responsibilities are defined. Procedure ES-005 revised to clarify responsibilities of STAS and will be reviewed with shif t supervisors and fore-men at IMI-I in 40 '83.
Finding VI-E-2: The need for a Systems Analysis Director is questionable.
VI-E-2 Rec:
Eliminate position of Systems Analysis Director.
II.
T. F.
A Canplete Resp:
Action already taken on this item at the time of BETA report.
Finding YI-E-3: There is a lack of involvement by Technical Functions in the conduct of the Training Progran, particularly operator training.
VI-E-3 Rec:
Provide technical guidance to training programs, V.
- 1. F.
B 4 th 0 1983 especially operator training.
Resp:
1983 Goal 14 applies.
T. F. Procedure EP-015
)
developed and now being implemented.
Finding VI-E-4: GPUN's goal to achieve an in-house licensed nuclear design capability may not provide the anticipated advantages.
VI-E-4 Rec:
Do not develop an in-house licensed nuclear design Ill.
T. F.
0 4th Q 1983 capability unless GPUNC is willirg to restrict fuel selections to proven technology and not attenpt to incorporate advantages in performance until they have been thoroughly tested at other plants.
Resp:
Review end reconnendation by 4Q, '83.,
i
'l i
10/26/83 g
BETA FINDING /
SIAIUS RECOMMEND.
PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE
CAI.
DIVISION CODE COMMENTS Finding VI-F-1: Engineering Projects personnel art performing tasks that could be better done elsewhere in the Division, thus decreasing their capacity f or the managenent of engineering projects.
VI-F-1 Rec:
Evaluate functions currently performed in Ill.
T. F.
A Conplete Engineering Projects and reassign those that detract from project management capability.
Resp:
This had been underway. Situation resulted from JCP8L combined engineering for 0.C.
Reassignments complete.
Finding VI-F-2: The training of project engineers is weak.
VI-F-2 Rec:
Provide training to Project Engineers in GPUNC V.
I. F.
A Conplete organizational structure, methods, and policies.
(
Resp:
Training program conducted late '82, early '83.
Finding VI-F-3: Oroject engineers do not receive adequate information concerning the progress, cost and trends in progress and cost for the budget activities for which they were the originating source of authority for the modification or the major O&M project.
VI-F-3 Rec:
Devise reports that will permit having a running 111.
Admin./
B lst Q 1984 knowledge of cost and performance.
0/P Resp:
Improved reports in place. Efforts will continue into '84.
Finding VI-G:
A separate group at the Director level for Startup and Test is questionable.
VI-G Rec:
Consider reassigning the Headquarters Start-Up and I.
T. F.
A Conplete Test group into the Systems Engineering group. Assign site personnel in this group to Plant Engineering.
Resp:
Has been considered. No change to be made at this time.
Believe SU&T should be within Tech. Functions, not Plant Engineering. Work load for next year is high aliif critical.
Any possible gain by reassignment within Tech Functions would be of fset now by disruption due to change.
Finding VI-H:
Neither the chemistry group in Tedmical Functions nor the System Laboratory has assumed a leadership role in the IMI-l or Dyster Creek Chenistry improvement programs.
VI-H (a-1)
Rec:
Remove System Laboratory from GPUN af ter the Chenistry I.
T. F.
E Disagree Programs at THI-l and Oyster Creek have been improved.
Resp:
D isa aree. Management of activity la benefit both nuclear and fossil activities best served by present location.
VI-H (a-2)
Rec:
Provide T.F./ System Laboratory leadership to plant I.
T. F.
A Conplete C hemis try. in provement.
Resp:
New TF Chemistry Director has been directed to get actively involved in improving the site c.hemistry programs. This has been implenented effectively.
s
- 10/26/83 BETA FINDING /
SIAIUS RECOMMEND.
PARAPilRASED RECDMMENDATION &
SUMMARY
RESPONSE
. CAT.
DIVISION CODE COMMEN TS Administration Findings & Recommendations Finding VII-A:
The Administration Division needs to improve its ability to provide a service function and to lessen the perception that it is a control function.
Vil-A (a)
Rec:
Continue to redirect effcris to provide an ef fective I.
Admin.
B 4th Q 1983 service to other divisions.
Resp:
Admin. Division Goal 3 for 1983. Month ly statistical analyses indicate that progressively more supportive services are being provided to other areas of the C orpora t ion.
Vil-A (b)
Rec:
Change impression that Adninistration Division 1.
Admin./
A Conplete determines how corporate policy is to be carried 0/P out in adninistrative matters.
Resp:
Direction proivided by 0/P & Director, Admin. Div.
through such items as Admin. Div. Goal 3.
Vil-A (c)
Rec:
Adopt the motto "We serve the plants."
1.
Adnin.
A Conplete Resp:
Effectively adopted by Adnin. Goal 3.
Finding VII-B:
The Manager.of Managenent Services has a narrow scope of work assigned.
VII-B Rec:
Increase scope of work assigned to senior manager IV.
Admin.
A Conplete (Manager of Management Services) or delete the position.
Resp:
Organization res tructured.
Finding VII-C:
The efforts of the Operations Analysis group within Administration are not ef fectively channeled.
VII-C Rec:
Efforts of Operations Analysis group should be 1.
0/P A
Conplete directed by the Office of the President.
Resp:
D/P met with Ops. Analysis managenent to define role and priorities. This will continue.
Finding VII-D:
The cost reductions possible with more sophisticated contracting methods are not being achieved.
VII-D (a)
Rec:
Continue training requistioners of materials and V.
Adnin.
B 4th Q 1983 services and develop a means to measure success of training.
Resp:
Requisitioner Training Course being revised to tailor to specific GPUN Div. needs presented in a "seninar" type 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> approach; will better insure avail. of key rquisition activity managers and permit discus-r sion of practical problems, causes and solutions via highly theoretical nature of initial training course.
s
- 10/26/83 BETA FINDING /
STAIUS RECOMMEND.
PARAPHRASED RECOMENDATION &
SUMMARY
RESPONSE
M.
DIVISION CODE COMMENIS Vil-D (b)
Rec:
Greater emphasis on Cost Plus incentive fee-111.
Admin.
A Complete type contracts.
Resp: Emphasis has been applied. Results tracked mon thly.
Vil-D (c)
Rec:
Monthly reports from major contractors identi-III.
Admin.
B 4th Q 1983 l
fying work progress by task and actual costs.
Quarterly reports from major contractors forecasting work progress and expenditures.
Resp: Procedures for accruing costs and earned value reporting being developed and implenented.
Formal contractual coverage is awaiting joint Comptroller / Fiscal Management decision on report-ing format and content. Discussion anticipated by mid-Noved>er 1983 and contract terms will be amended accordingly, including both prospective and retroactive coverage, where appropriate.
Finding VII-E:
There needs to be overall improvement in the Security Division in order to improve its efficiency.
Vil-E Rec:
There needs to be an overall improvement in the Ill.
Admin.
B 4th Q 1984 Security Division in order to improve its efficiency.
(See VII-E-1 through VII-E-10).
Resp: BETA made 14 recommendations relating to Security.
To date, six have been implemented and one has not been accepted. One recommendation will be implemented before the end of 1983. Of remaining six, two require
/
further study and evaluation before making a decision on implenentation. Four recommendations ar ong-term e
but will be completed in 1984 Finding VII-E-1: Sane security administrative functions at TMI-l and THI-2 can be combined to save manpower.
VII-E-1 Rec:
TMI-I access control clerk handle TMI-2 workload re-II.
Admin.
D 4th 0 1983 l
ducing staff by I control clerk. Additional savings would be achieved by TMI-l's clerk typist supporting TMI-2.
Resp: Implementation is not feasible at this time. Joint THI-2 Operation - Security assessment of security requirements at TMI-2 in its present status are underwsy. Upon canpletion, this recommendation will be reconsidered.
g o 10/26/83 BETA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMMENDATION & SlHMARY RESPONSE CAI.
DIVISION CODE COMMEN TS o
. Finding Vil-E-2: The Response Force capability at IMI-I and TMI-2 can be considered to be 10 armed guards (each plant will support th e o th er). Because outside support is readily available, a smaller Response Force would meet NRC rejuirenents.
Vll-E-2 Rec:
Combine response force capability at IMI to reduce Admin.
E Disagree
. response force total. Negotiate with NRC to reduce force to six to eight guards.
Resp: Disagree - Separation committed to in Restart hearings and potential for demonstrations make further reductions impractical. We recamnend this issue be reconsidered af ter IMI-I is on line as the agreenent with the NRC involves separation of Units I and 2.
Finding Vil-E-3: Inadequate engineering and construction support for the IMI-I and THI-2 security operations is resulting in the need to substitute guards f or security hardware. Such substitutions are expensive.
VII-E-3 (a)
Rec:
Provide adequate engineerin and construction Ill.
Admin.
B 2nd Q 1984 l
support for security operat ons.
Resp: Technical Functions has assigned a Project Engineer to coordinate major Security improvements at IMI &
0.C. (upgrading of Perim Alert perimeter barrier /
detection system). PRC has established a preventive /
corrective maintenance program at 0.C. and TMI for Security search and assess control equipnent and har dware. Technical Functions, Computer Support is coordinating ef f orts to correct Security conputer 4
deficiencies at 0.C. and TMI.
Vil-E-3 (b)
Rec:
Develop procedures to require periodic review of 111. ' Admin.
B 4th Q 1983 l
security systems where minor degradations are compensate for by stationing guards to meet NRC commitments Resp: The Manager-Security will issue a directive re-quiring a monthly report docunenting Die review, the degradations and compensatory measure costs, date of corrective action and any reconnendations to minimize chances of a reoccurrence.
Vil-E-3 (c).
Rec:
Activate alarms at fuel handling bay doors s73 and 74 II.
Adnin.
A Conplete and reduce guard force at !MI-1.
Resp: Complete.
VII-E-3 (d)
Rec:
Activate alares at doors 11 and 16 and reduce TMI-2 II.
Admin.
A Conplete guard force.
Resp: C omplet e.
1
- l
. =
10/26/83 BETA FINDING /
SIAIUS RECOMMEND.
PARAPHRASED RECOMENDATION &
SUMMARY
RESPONSE
CAT.
DIVISION CODE COMMENIS Finding Vll-E-4: The TMI-2 entrance to the protected area uses a temporary building and manual search to control entry of personnel.
This facility and its operation are inef ficient in the use of guard manpower.
VII-E B Rec:
Upgrade IMI-2 Processing Center including installation 11.
Admin.
B 4th Q 1983 of metal monitors and explosive monitors. Offset is reduction in guards at TMI-2.
Resp: Item reviewed during preparation of 1984 Budget.
Further evaluation is required. On completion of the joint IMI-2 Operation / Security evaluation previously noted, this recommendation will be reconsidered.
a Finding Vil-E-5: The protected area perimeter alarm system at TMI has an excessive nuiidier of alarms.
VII-E-5 Rec:
Upgrade perimeter alarm system to produce a 111.
Admin.
B 4th Q 1984 system with a minimum number of false alarms.
Resp: Project is underway at IMI and 0.C., coordinated by Technical Functions. This is a long term project with estimated completion 4Q '84 Finding VII-E-6: Manpower requirements fluctuate as a result of training requirements, special security assignments and multi-shif t operations. Extensive overtime is required to support this fluctuating workload.
Vil-E-6 Rec:
Determine times when security requirem nts peak and 11.
Admin.
D 4th Q 1983 examine alternative shif ts to reduce overall manpower and overtime.
i Resp: Site Protection personnel at TM1 and 0.C. are now assigned to permanent shif ts. Experience to date L
shows that this system matched manpower available to shif t manpower needs.
Fi: ding Vil-E-7: Guard protection is being provided to areas that may not require the protection or warrant the expense.
VII-E-7 Rec:
Evaluate security at TMI Training / Visitors Centers, II.
Adin in.
A Complete i
Forked River, and TMI South Gate. Possible reduction of 8.5 to 9 man-years.
Resp: Training center alarm installed and security coverage dropped. South gate now open only 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> / day, 5 days a week. Forked River has minimal coverage. Total reduction of more than 25 achieved in Security since early '82. s a
=
s +
10/26/83 BETA FINDING /
STATUS RECOMMEND.
PARAPilRASED RECOMENDATION & SlNMARY RESPONSE CAT.
DIVISION CODE COMMENIS Finding Vli-E-8: GPUN has not received adequate support from Vikonics in correcting keycard access systems deficiencies.
VII-E-8 Rec:
llave an engineering evaluation made on Vikonics' Ill.
Admin.
B 1st Q 1984 equipment, including proposed corrective action and input from other utilities using equipme6.
Provide plan of action, including engineer '. g and legal alternatives.
Resp: Three sof tware and four hardware deficiences still exist. Technical Functions, Computer Support is coordinating actions by Vikonics to correct. Soft-ware dorunentation and scheduled training will be forthcoming from Vikonics. Materials Management is
. supervising contract conpliance.
Finding VII-E-9: Approval has been requested to reorganize the security force to establish a Lieutenant position at each site.
Vil-E-9 Rec:
If lieutenant position is established in Security, IV.
Admin.
A Conplete the number of managers should not increase.
Resp: Implenented with no increase.
Finding VII-E-10: The security operations require extensive overtime.
VII-E-10 Rec:
Manpower assessments in security should include over-II.
Admin.
A Conplete*
l time usage. Recommended levels including overtime is Oyster Creek--62 and THI-1--48.5.
Resp: Site Protection personnel at THI and OC are assigned to permanent shifts, which system experience shows meets manning needs. Staf fing levels reconnended for 1984 at THI-1, TMI-2 and 0.C.,
include a small increase in staf fing to address the need for reducing overtime hours.
Finding VII-F:
GPUN has no employee who is a medical doctor at headquarters or IMI-I or Oyster Creek to oversee medical aspects of the GPUN rad, health program. Part time contract physicians and a contractor are used for these functions.
VII-F Rec:
Employ a physician at TMI and assign medical radio-II.
R&EC B
4th Q 1983 logical health responsibilities for THI-1, TMI-2, and Oyster Creek.
Resp: Board of Directors has agreed. Executive search firm actively working to recruit physician.
10/26/83 BE TA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMENDATION & StNMARY RESPONSE CAT.
DIVISION CODE COMMEN IS Human Resources Findings & Recommendations Finding VIII-1:
There is a need to reduce the time it takes to complete a personnel action.
VIII-l Rec:
All levels of managenent understand quick action IV.
II. R.
A Conplete required for personnel matters. Iluman Resources keep track of status and identify delays.
Resp: Has been re-emphasized throughout GPUK,.
Response
improv ed.
H. R. track ing.
Finding VIII-2:
The number of GPUN personnel who have the title of " Manager" or above is high in comparison to the total nudier of GPUN enployees.
Vill-2 Rec:
Evaluate top managerial positions and determine if V.
- 11. R.
A Conplete
- w0rk matches grade level.
Resp:. Based on results of recorrelation and overall re-view of titles, response to this reconnendation is complete.
Finding VIII-3:
Productivity at the nuclear plant sites is adversely af fected by current bargaining unit employees.
VIII-3 Rec:
Conduct review of bargaining agreenents to deter-IV.
H. R.
C 4th Q 1983 (OC) mine impact on work ef ficiency.
Ist Q 1984 (TMI)
Resp: Will be done for Dyster Creek 4Q'83, IMI IQ'84.
Major emphasis has been on enforcing management rights in current agreenent.
4 t L
e s
- 10/26/83 BETA FINDING /
STATUS kECOMMEND.
PARAPilRASED RECOMMENDATION &
SUMMARY
RESPONSE
CAT.
DIVISION CODE COMMENIS Radiological and Environmental Controls Findings & Recommendations I
Finding Il-A:
Little rad engineering is performed in Parsippany.
IX-A Rec:
Develop small Radiological Engineering group in I.
R&EC/
A Conplete*
l P ars ippany.
OP/I.F.
Resp:
Item reviewed with Technical Functions & RLEC
-to develop action plan including organizational location of capability. As of 11/1/83 group will consist of a Manager and two Rad Engineers.
Finding IX-B:
GPUN is spending more than it should in dollars and manpower for envirornnental monitoring at IMI-I and Dyster Creek.
l IX-B Rec:
Begin reducing unnecessary environmental monitoring.
Ill.
R&EC A
Conplete*
Resp:
Non-radiological Tech $pec monitoring has been reduced at TMl in 1983 after extended interaction with NRC--further reduction will only be entertained by NRC af ter 1988; non-rad Tech Specs at 0CNGS were reduced in 1983 by elimination of redundant monitoring i.
requirenents.
i
- l i
a
- 10/26/83 BETA FINDING /
STATUS.
RECOMEND.
PARAPilRASED RECOMMENDATION & StfMARY RESPONSE E.
DIVISION CODE COMMEN TS Maintenance & Construction Findings & Reconinendations finding X-A:
The M8C Division in its ef fort to become established is not capitalizing on the capabilities throughnut the Corporation's functional organization.
X-A Rec:
Evaluate functions within M&C and assure no III.
M&C A
Conplete duplication of other divisions in GPUNC.
Resp:
Review and experience at Oyster Creek with re-aligned maintenance function shows no remaining dupticatlon.
. s
- 10/26/83 BETA FINDING /
STATUS RECOMMEND.
PARAPilRASED RECOMENDATION & StNMARY RESPONSE CAT.
DIVISION CODE COMEN TS Communications findings & Recommendations Finding XI:
The number of people assigned to this function appears excessive.
XI (a)
Rec:
Review anticipated workload to detennine if properly II.
C umnun.
A C onplete
- manned.
Resp:
During the 1984 budget preparation sequence, the staf fing and work load of Communications, especially the tour personnel, was reviewed.
XI (b)
Rec:
Find useful tasks in other divisions for people when II.
Comnun.
A Complete
- not needed f or primary jobs.
Resp:
Some cross training complete. Was reviewed again as part of '84 budget review. See Rec XI(a).
XI (c)
Rec:
Provide more ef fective supervision.
III.
Commun.
A Conplete
- Resp:
Vice President, Communications has spent more time in the T&E Building where the potential problem of ef fective supervision is greater.
Efforts continue to identify work which can be assigned to those personnel to work load Uten effectively during otherwise low work periods.
l i
d a
- 10/26/83 BETA FINDING /
S TATUS RECOMMEND.
PARAPHRASED RECOMMENDATION & SINMARY RESPONSE E.
DIVISION CODE COMMEN TS General Findings & Reconnendations Finding Xil-A:
Insufficient or poor supervision is contributing to poor productivity.
Xil-A (a)
Rec:
Properly train supervisory personnel.
V.
N. A.
B thispeci f ied Resp:
Responses to other reconnendations address Gen./UP this pechlem directly. Their conpletion will close this item also.
Xil-A (b)
Rec:
Evaluate ef fectiveness of current supervisor V.
N. A./
A Conplete*
training course.
OP/ Gen.
Resp:
A special task group headed by R. Coe with
- 0. Shalikashvili and J. Williams has reviewed this program, including feedback fron past s tuden ts.
Reconnendations for dianges, as well as the addition of suplemental skill modules, will be reviewed with experienced supervisors in the various user groups. Appropriate rec-onnendations have been incorporated into new supervisory develognent program. Training with new skill modules has begun.
Xil-A (c)
Rec:
Minagers should develop their supervisors by V.
N. A./
B 4th Q 1983 l
observing them and ins tructing them.
Gen.
Resp:
This issue will be addressed in conjuction with the response to Reconmendation XII-A-f.
Has been addressed with all Managers on many occasions. Progress being made. C on t inu ing effort required but recommend closing 4Q '83.
Xil-A (d)
Rec:
Spot, unannounced visits by all division directors Ill.
OP/ Gen.
A Cunple te
- l to work areas to evaluate ef fectiveness.
Resp:
All Division Directors will visit each of their locations where they have personnel at least once per month starting 7/1/83. It will not be efficient to have very many unannounced visits to other locations fran the Division Director's normal location be unannounced. This will in-clude inspecting or observing actual work areas.
Division Directors are complying with reconnen-l datlon.
I -
o 10/26/83 BETA FINDING /
STAluS RECOMMEND.
PARAPHRASED RECOMMENDATION & SLNMARY RESPONSE g.
DI VISION CODE COMMENTS
- XII-A (e)
Rec:
Improve senior management use of GPUNC performance IV.
H. R./
8 4th Q 1983 evaluation system relating to supervisory performance.
Genera l Resp:
Improvements made in 1982 and identified for 1983 provide more ef fective systen. Emphas ized in guld-ante for 1983 review. New sys tem v as t improv emen t and is being used; system use and importance reviewed with managers on many occas ions. Needs continued enphasis but as result of improvement thus far, reconenend close out 4Q '83.
i XII-A (f)
Rec:
As forces stabilize, supervisors should spend more IV.
OP/ Gen.
B 4th Q 1983 time in people matters.
Resp:
This issue will be addressed in the Corporate HLC fully supports concept; 1984 Goals. See response to Xil-A(c) above.
incorporated in supervisory deve1opnent programs.
R8EC supports; supervisors spending more time in this ar ea.
XII-A (g)
Rec:
Remove ill-suited supervisors or solve negative I V.
OP/ Gen.
B 4 th Q 1983 at t i tudes.
Resp: ' Being addressed. The new performance evaluation Will specifically review system should improve ef fect iveness in identif ying during 1983 Perf ormance personnel ill suited for their present assignments.
Reviews.
1 i
We will continue to focus on identifying and resol-ving such problems. Major progress has been made, 4
i XII-A (h)
Rec:
Senior management should be sensitive to evidence I V.
OP/ Gen.
8 4 th Q 1983 i
of poor supervision wherever observed (system or contractor personnel).
Resp:
See response to Xil-D(b). Major progress has been made.
Will specifically review Continue emphasis but reconnend complete by 4Q '83.
during 1983 Performance Reviews.
t XII-A (1)
Rec:
Review provisions in contracts with major contractors I V.
Admin./
B 4 th Q 1983 a
to see what means exist for GPUNC to monitor, report, Gen.(MM) 1 and take action in cases of poor or insuf ficient i
superv is ion.
i Resp:
" General Conditions" are included as part of all contracts for furnishing labor and/or supervision.
i.
- Article X-IX " Contractor Personnel" states in part
, that at any time during the course of the work, the owner has the right to terminate contractor personnel for cause and ask for replacements at expense of i
con tractor. This item will be included as part of, Materials Management presentation to GPUN Staf f meet-ing currently being rescheduled for later this year.
30 -
4 I
E 1
10/26/83 BETA FINDING /
SIAIUS RECOMMEND.
PARAPHRASED RECOMMENDATION & StNMARY RESPONSE CAT.
DI VISION CODE COMMENIS Xil-A (j)
Rec:
Trending of data to ascertain prdilem areas.
111.
Admin.
B 3rd Q 1984 Resp:
The Act ivity Indicator Display program has been Gen. /0P implemented and we will continue to examine prd>1em areas. Some data currently being trended, lhjor effort still required. 1984 IMI-I Division Goal.
M8C has trending program as does R8EC Division.
Xil-A (k )
Rec:
Corrective action for cases of personal appearance, 111.
H. R.
A Conple te
- l deneanor, etc. - considered outside the norm.
Gen./0P Resp:
Day-to-day actions are being addressed. Policies will be issued and stressed by managenent on expected behav ior and demeanor. AP-1029, Conduct of Operations, directly addresses. Managers briefed in standards of formality and professionalism. Policy memo issued on shoes and T-shirts at OC.
M8C has addressed to man-agement/ supervisory level importance of attitude and business-1ike appearance.
Xil-A (1)
Rec:
Color-code hard hats at the site to distinguish IV.
IMI-1/
D 3rd Q 1984 work ers, foremen, of ficers, contractors.
Gen./0.C.
Resp:
Color coding of hard hats has been revised at Oys ter Creek. THI-I and 0.C. Division Directors will review this item and coordinate on desirable further revis ions. At THI-1, exenpt and non-exempt wear different color hard hats. No current plans to change system to include all categories of people listed. M&C supports; consideration must be given to contractor identification requirenents.
Finding XII-B:
There is too much paper being generated and distributed throughout the GPUN organization.
Xil-B (a)
Rec:
Each division director should help ensure distri-III.
Admin.
B 4 th Q 1984 bution is necessary.
Gen./0P Resp:
A specific ef fort has been initiated at the of ficer level to identify and use " case studies." Examples of inappropriate dis tribution of documents. C or po-rate Goal 8 also addresses this issue. Operations Analysis study of paperwork at IMI underway.
Xil-B (b)
Rec:
Tighten signatu *e authority; monitor for compliance.
111.
Admin.
B 2nd Q 1984 l
Resp:
This issue is being (or has been) reviewed in each Gen./0P division to see whether more formal guidance is needed.
Operations Analysis will be conducting a study (ten-tatively scheduled for 2Q '84) to determine whether there exists consistent and appropriate signature authority requirements throughout the GPUNC System. -
10/26/83 BETA FINDING /
SIATUS RECOMMEND.
PARAPHRASED RECOMMENDAll0N & StHMARY RESPONSE CAT.
DIVISION CODE COMMENTS Xil-B (c)
Rec:
Correspondence control, action item track ing.
111.
Admin.
A Conple te
- l Resp:
Action Iten Tracking System implenented. All Gen./0P Licensing Managers trained in use of system.
Loading data base in progress.
XII-B (d)
Rec:
Control issuance of artninistrative procedures.
Ill.
Admin.
A Conplete Resp:
GPUN Policy Plans and Procedure System has been Gen./0P issued and has been implemented for control of Adminis trat Ive procedures.
Xil-B (e)
Rec:
Limit required concurrences on documents / procedures.
III.
Admin.
B 4th Q 1984 1
Resp:
0/P action on this issue will be continued. Fur th er Gen./0P emphas is needed. Documents being considered as part of Corporate Paperwork Reduction Study. Formal pro-cedure system has been stream lined to implement limits on required concurrence.
Finding Xil-C:
There is an overall tendency within GPUN to force decision-making too high up in the organization.
XII-C Rec:
All levels of managenent should review decision Ill.
OP/ Gen.
A Conplete*
l making in their groups to assure decisions 3re being made at the proper level connensurate with the need. Do not unnecessarily force decisions
- upw ard.
Resp:
This issue will be covered in the meetings being held to meet Corporate Goal 5.
Mus t receive con-tinued attention but consider much improvement has been achieved.
Finding XII-D:
There appears to be a reluctance within the GPUN system to take action either to improve the performance of poor performers or to terminate their employnent.
XII-D (a)
Rec:
Review for practical usefulness, GPUNC procedure IV.
- 11. R. /
B 4th Q 1983 adcressing poor performe s.
Gener a l Resp:
Progressive discipline procedure developed.and in use.
H. R. will be working with each Division to review all Performance Appraisals of 3.4 or below and specific plans for improvenent will be devel-oped where appropriate. Review to be completed 4Q '83, follow-up during 1984.
R BETA FINDING /
STATUS RECOMMEND.
PARAPHRASED RECOMKNDATION & SlHMARY RESPONSE CAT.
DIVISION C00E COMMENIS XII-D (b)
Rec:
Each Division Director assure proper action is IV.
OP/ Gen.
A Conpl ete
- l taken to correct perf ormance where called f or, or if unsatisf actory performance persists - discharge.
Resp:
This issue has been specifically addressed in both 0/P and Division Director staff meetings. Appro-priate disciplinary actions taken. See Findings XII-A(k ) and XII-D(a) above.
Finding XII-E:
Since the creation of GPUN, too many small groups (cells or staf fs) have been formed to carry out functions which shoulel be handled within the normal f unctioning groups.
XII-E Rec:
Each director review manpower staf fing to reduce 0/P B
4th Q 1984 unnecessary small staf f build-ups.
Resp:
Staf fing of all Divisions were reviewed as part of '84 budget preparation. Overall 1-2% reduction planned for 1984 Operations Analyts 'is studying.
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- 1983 CORPORAlE GOAT S & OBJECIIVES Corporate Object ives 5.
Improve GPU Nuclear's functional capabilities within the authorized manning levels.
Corporate Goals i
5.
Provide an initial five-year corporate plan with defined milestones and objectives by June 1,1983, to use for budget planning for 1984 and beyond.
8.
Have mechanisms in place by June 1,1983, for identifying and stimulating abolishment of unnecessary paperwork, documentation.,or procedural complexity.
9.
Conduct at least two hour discussion sessions with a alnimum of 300 exempt employees below the department head level on the functions, responsibilities, and interactions of the various elements of the organization by July 1,1983, 1983 DIVISION GOALS & OBJECIIVES Oyster Creek Division 4.
Improve working conditions and station appearance by: (a) reducing contaminated areas by 201: (b) reducing areas requiring r 9tratory protection by 25%; (c) painting and refurbishing 100,000 sq. ft, of area.
5.
Substantially improve the material condition of the Oyster Creek Plant by accomplishing a high percentage of the i
maintenance work scheduled during the 1983 outage.
7.
Establish six operating shif ts each with two Senior Reactor Operators (SR0s).
10. Complete upgraded training programs for all chemistry technicians; inillate formal training programs for all Equipment Operators, and formalize all on-the-job training.
- 21. Completely revise the plant Chemistry procedures (800 series) by: (a) award contract; (b) begin rewrite; and (c) complete project.
- 22. Improve Chemistry Technician job performance proficiency by: (a) Improve information flow; (b) complete Chemistry parameter trending; (c) increase supervisory oversight; and (d) upgrade documentation.
23.
Expand Chemical Laboratory facilites by: (a) place temporary f acilities in o permanent facility; (c) complete construction of permanent facility; and (d)peration; (b) start construction of obtain all laboratory instrumentation.
- 24. Implement 24-hour Chemistry support of plant activities.
- 25. Upgrade Chemistry Technicians' training and complete training.
32.
In conjunction with H&C Divis tan, develop a GMS program for computerized equipnent history, trending, and Preventive Maintenance scheduling.
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