ML20087G582
| ML20087G582 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/15/1984 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Buck J, Edles G, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8403200066 | |
| Download: ML20087G582 (61) | |
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March 15, 1984 822-1215 Administrative Judge Administrative Judge Gary J. Edles, Chairman John H. Buck Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Christine N. Kohl Atomic Safety and 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 No. 1)
Docket No. 50-289
Dear Chairman Edles and Administrative Judges Buck and Kohl:
In accordance with our practice of notifying the Appeal Board and the parties of changed circumstances or new information on issues under consideration, Licensee hereby provides the following information.
As stated in the enclosed press release, Mecsrs. Lawrence L. Humphreys and Warren F. Witzig have been elected to GPU Nuclear Corporation's board of directors. Along with Mr. Robert V. Laney, who was elected to the board in January, Messrs. Humphreys and Witzig will make up the Nuclear Safety and Compliance Committee, 8403200066 840315 PDR ADOCK 05000289 CN O PDR \.)
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l j SHAw, PITTMAN, PoTTs & TROWM:DGE
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Administrative Judge' Gary J. Edles Administrative Judge John H. Buck Administrative Judge Christine N. Kohl March 15, 1984 Page Two established by GPU in order to provide further assurance that TMI-l will be operated safely.
Licensee has conducted another status report on its progress toward completion of required actions identified in the February, 1983 BETA Report. (Earlier status reports were provided to the Appeal Board and the parties by Licensee's counsel on July 26 and November 3, 1983.) Enclosed is a copy of the current status report, along with a cover memorandum transmitting the report from Mr. P. R. Clark, President, GPU Nuclear, to the Chairman of the Board of Directors, GPU Nuclear.
1 In December, 1983, at GPU Nuclear's request, a group of QA shif t monitoring engineers and their supervisore participated in an Institute of Nuclear Power Operations (INPO) training program on INPO evaluation techniques. Enclosed is a letter from E. P.
I Wilkinson, President of INPO, to Philip R. Clark, President, GPU Nuclear Corporation, which forwards two INPO memoranda commenting on Licensee's shift monitor program. Also enclosed is a memorandum from R. L. Long, Licensee's Vice President-Nuclear Assurance, to
- Mr. Clark responding to the INPO comments.
Licensee has revised its rectart schedule to include work on reactor coolant pump IB prior to precritical non-nuclear hot functional testing. This work will not impact Licensee's scheduled capability of June 1, 1984 criticality. Licensee also has scheduled the completion of other major work items and surveillances in order to take best advantage of the " precritical" period. Enclosed is a letter from Mr. H. D. Hukill, Director, TMI-1, to Mr. H. Denton, Director, Office of Nuclear Reactor Regulation, reflecting this revised work schedule.
Respectfully submitted,
.b .4Smr./(. , ee%
Deborah B. Bauser Counsel for Licensee DBB:jah Enclosures cc: Attached Service List w -
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% l UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
)
(Three Mile Island Nuclear )
Station, Unit No, 1) )
SERVICE LIST 1 Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Conunission John H. Buck Washington, D.C. 20555 Atomic Safety & Licensing Appeal Victor Gilinsky, Conunissioner Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Was'hington, D.C. 20555 Thomas M. Roberts, Comunissioner Administrative Judge U.S. Nuclear Regulatory Comunission Christine N. Kohl Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board James K. Asselstine, Comunissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 U.S. Nuclear Regulatory Cossaission Washington, D.C. 20555 Administrative Judge Frederick Bernthal, Commissioner Ivan W. Smith, Chairman U.S. Nuclear Regulatory Comunission Atomic Safety & Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Atomic Safety & Licensing Appeal Sheldon J. Wolfe Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Cossaission. U.S. Nuclear Regulatory Commi Msion Washington, D.C. 20555 Washington, D.C. 20555
i ')
Administrative Judge Mr. Henry D. Mukill Gustavo A. Linenberger, Jr. Vice President Atcaic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear mogulatory cosaission 7,0. Box 480 Washington, D.C. 20553 Middletown, PA 17057 Docketing and Service section (3) Mr. and Mrs. Norman Aamodt office of the SaMatary R.D. 5 U.S. Nuclear Dagulatory Commission Coatesville, PA 19320 Washington, D.C. 20555 Ms. Louise Bradford Atomic Safety & Licensing Board TME ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Coimaission Barrisburg, PA 17102 Washington, D.C. 20555 Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Christic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Cosuaission Washington, D.C. 20002 l
Washington, D.C. 20555 Ms. Gail Phelps Jack R. Goldberg, Esq. (4) ANGRY /TM1 PIRC Office of the Executive Legal 1037 Maclay Strest Director Barrisburg, PA 17103 U.S. Nuclear Regulatory Cossaission Washington, D.C. 20555 Ellyn R. Weiss, Esq.
Harmon & Weiss Maxine Woelfling, Esquire 1725 Eye Street, N.W., Suite 506 Assistant Counsel Washington, D.C. 20006 Department of Environmental Resources Michael F. McBride, Esq.
514 Executive Housa LeBoeuf, Lamb, Leiby & NacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W Warrisburg, PA 17120 suite 1100 Washington, D.C. 20036 Job A. Levin, Esq.
Assistant Counsel Michael W. Maupin, Esq.
Pennsylvania Public Utility Hunton & Williams i Cosumission 707 East Main Street P.O. Box 3265 P.O. Box 1535 Harrisburg, PA 17120 Richmond, VA 23212 David E. Cole, Esq.
Smith & Smith, P.C.
2931 Front Street Warrisburg, PA 17110 I
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L News Release 2:ni.'a"d Post Office Box 480 luCleer Middletown. PA 17057 Public Information Services 717-948-8197 For Further Information Doug Bedel1, Gordon Tomb Contact.
For Pelease.
Immediately Feoruary 23, 1984 Date:
- 22-843 dPU NUCLEAR ELEC TS JIRECTURS, COMPLtTING SAFETY C9MMITTEE Middletown, PA -- GPU Nuclear Corporation today announced the election of Lawrence L. Humphreys and Warren F. Witzig to the GPU Nuclear board of directors. Along with Robert V. Laney, wno was elected to the board in January, Humpnreys and Witzig will make up a Nuclear Safety and Compliance Comnittee to monitor the operation and maintenance of tne GPU System's nuclear units with specific a*.tentica to adherence to procedures E.nd license requirements. Laney is cnairman of the connittee.
Election of tne tnree men, who were drawn from outside the GPU System, and the establisnment of tne Nuclear Safety and Compliance Comnittee fulfill a GPU dMision announced last Novemoer tnat was intenCed to provide further assurance that Three Mile Island Unit I will De operated safely when the plant is restarted. Tne board-level Nuclear Safety and Compliance Comnittee will nava an independent staff of its own.
Pnilip R. Clark, Sr., president and cnief executive officer of GPU Nuclear, said, "These three men were drawn from outside tne GPU System to 1
i oroaden tne range of experience and perspective on tne GPU Nuclear aoard of airectors. Their presence on tne board and as a Huclear Safety and Compliance Committee will provide additional deptn to tne management of our nuclear facilities. We are pleased to have sucn nignly qualified individuals in thesa positions."
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e' February 23, 1984 f t22-d4N As previously announced, Jonn F. O' Leary, fonner Deputy Secretary of the U.S. Departinent of Energy and an independent energy consultant in Washington, O.C., nas been elected as the outside chainnan of the GPU Nuclear board. The board now nas a full coinplement of seven directors from witnin the GPU System and four outsiae directors.
Humpnreys nas served since 1980 as cnief executive officer of UNC Nuclear Inaustries. He worxed from 1968-80 for electric utilities, attaining tne position of executive vice president ano nolaing responsibilities in nuclear plant engineering and construction, safety, regulatory compliance and stea:ii plant operation. He eerked from 1900-68 at research and development facilities of tne. feceral government near dichland, Wasnington, attainiiig the -
! position of nuclear reactor supervisor. Humphreys nol'.s a cacnelor of science degree in cnemistry from Linfield College, dciinnville, Oregon, and master of science degree in chemistry froai Oregon State University.
Witzig is enainnan of the iluclear Engineering Department at Pennsylvania State University, wnere ne also nas served as a professor since 1967. He serveu from 1960-o7 as senior vice president and a director of NUS Corporation, a nuclear consulting firm. He worked in various nuclear researcn programs from 1942-o0 arid now is engaged in researcn in the aisposal of radioactive waste, nuclear fuel cycle and e.nergency planning. He nolds 4 oacnelor of science aegree in electrical engineering from densselaer Polytecnnic Institute, Troy, New York, and a master of science degree in electrical engineering and a coctor of pnilosopny degree in pnysics, oatn froai tne University of Pittsbargn.
As reported previously, Laney is a consultant in nuclear and energy project management.
994 n
o ENuclear memorandum 7ourth Quarter 1983 Status Update -
Subject:
GPUNC Responses to Recommendations of Date: February 29, 1984 Basic Energy Technology Associates, Inc.
Set Forth in their Report Dated February 28, 1983 Fnxn: P. R. Clark Location: Parsippany President To: Chairman, GPU Nuclear Corporation Board of Directors A commitment was made to the Board to provide a quarterly report on progress toward completion of required actions identified in the BETA Report. The fourth quarter 1983 Status Update is attached, in which 37 additional open items have been completed, leaving 32 of an original 156 recommended actions in progress or under evab2ation.
This Status Update will also be provided to the Atomic Safety and Licensing Appeal Board through the of fices of Shaw, Pittman, Potts, and Trowbridge.
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P. R. Clark PRC/FLD :sms Attachment 0050i/22 cc: l GPU Nuclear Corporation Board of Directors GPU Nuclear Corporation Directors H. M. Dieckamp R. P. Fasulo L. L. HumFb reys P. B. Fiedler E. E. Kintner I. R. Finfrock W. G. Kuhns W. L. Gifford R. V. Laney R. W. Hecard J. R. Leva H. D. Hukill J. F. O' Leary B. K. Kanga F. J. Smith R. L. Long W. A. Verrochi F. F. Manganaro W. F. Witzig D. G. Murray R. F. Wilson AGM0648 8-83
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Preface ,
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The review of current and projected expenditures and manpower utilization for GPU Nuclear Corporation conducted by Basic Energy Technology Associates. Inc. (BETA) was issued in a report dated Feb. 28, 1983.
The focus of the rewtew was on resources devoted to Three Mile Island Unit I and Oyster Creek. A total of eighty-five (85) findings resulted in one hundred fifty-six (156) separate reconnendations, t This report represents the GPUNC Response. The 156 recommendations (paraphrased) have been assigned to one of five (5) broad categories:
j I. Oraanization - understanding and working within the functional CPUN structure.
II. Hanning - appropriate staffing levels.
III. Operatina/Manaaement Efficiencv/ Productivity IV. Personnel-Related Matters - personnel practices.
V. Trainlas Within each of the above categories, re:nonses have been placed into one of five classifications (STATUS CDDE):
A. Aaree - Comoigtg: agree with recommendation. action is complete.
B. Aaree - Action underwav/ Goal: agree with recommendation, action is underway and/or action is a 1983 goal.
C. Aaree - Action to be Scheduled: agree with recoquendation, action to be taken in the future.
D. Under - Evaluation: either reconnendation or appropriate action is under evaluation.
I E. Disaaree: disagree with recommendation.
! This report is sorted by BETA finding and recommendation.
i Appendix A provides a listing of those GPUNC 1983 Corporate 2nd/or Givision Goals and Objectives referenced in recommendation responses contained in this report.
, The GPUNC Response Report (sorted by BETA finding) will be updated quarterly. This revision contains the 4th quarter 1983 updated status. Since the last update, 37 additional open items have been completed (as noted by asterisk in the connent column) for a total complete or disagree of 124. Thirty-two items remain open.
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h TABLE OF CONTENTS BETA FINDINGS & RECOMMENDATI0t.S EAGE
', THI-1 Plant and Divtsion 1-5 1
O.C. Pla.rt and Division 6-13
'O Nuclear Assurance Division 14-17 Technical Functions Division 18-22
] Administration Division 23-28 I Human Resources Division 29 i
i Radiological & Environmental Contrcis Division 30
)
Maintenance & Construction Division 31 .
Communications Divison 32
! General 33-37 i
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, BETA REPORT - GPUNC RESPONSES BY BETA FINDING .
BETA FINDING / STATUS MCQtefMD. PARAPHR$$ED RECDP9tENDATION 1 SUpttARY RESPONSE CAI. DIVISION CODE COP 9 TENTS IMI-1 FindjnsL1_Reccianendations findina III a:t The role of the Director. TMI-l needs to be clarified and strengthened with respect to his over-all site responsibilities.
- III-A (a) Rec
- Office of the President foster understanding I. 0/P A Complete " l
- of how functional organization should operate.
Resp: Continuing effort reflected in Corporate Objective 5.
- Substantial Completion. l In 1983. Corporate Goal 9 & Management Training Program respond directly.
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III-A (b) Rec: Continua emphasis on support role of non-plant divisions. I. 0/P A Complete " l Resp: Continuing effort reflected in Corporate Objective 5.
- Added specific wording to Plant Division Functions
- Substantial Completion. l
- Strengthened Plant Division role in Budget Process III-A (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.
1 Substantial improvement achieved.
1 III-A (d) Rec: Encourage support and working within new organ 127.tton. I. TMI-1. A Complete " l
- Resp
- Being met by TMI-l Goal 2. TMI Division Staff meetings included Support Divisions and this issue was addressed directly and indirectly.
III-A (e) Rec: Encourage freer discussion among divisions. I. 0/P A Complete
- l Resp: 1983 Corporate Goal 9 directly dddresses issue.
III-A (f) Ree: Encourage upward not downward corporate policy III. 0/P A Complete
- l complaints.
Resp: Continuing effort reflected in Corporate Objective 5.
- 1983 Corporate Goal 9 and management program respond directly.
Eindina_Ill-a: The positions Ibr five " engineers" presently reporting to the TMI-l Manager. Plant Operations should be better defined.
4 III-B Rec: Better define role of five engineering positions II. TMI-l A Complete reporting to Plant Operations.
, Res;. There are five operational engineers assigned to Plant
' Operations. Position d2scriptions have been prepared.
Positions have been reviewed and are considered ap-1 propriately located within the organ 12atico. (Five positions are 2 Primary Plant Engineers, 1 Secondary
- Plant Engineer, I Radwaste Engineer and I Trainee.)
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BETA FINDING / STATUS MC0ftilifiD. PARAPHRASED REC 0tetENDATION 8
SUMMARY
RESPONSE CAI. DIVISION _f0DE_ CO M NTS ElpdhlallL-C: Maintenance at TMI-I can improve its support of the plant.
III-C (a) Wec: Schedule more day shift maintenance work and ensure III. THI-l A Complete stronger supervisory support.
Resp: Perst.nnel changes have been implemented to ensure strong supervisory support on day shift. Complete but will monitor for proper implementation.
III-C (b) Rec: Assign system responsibility in Plant Engineering I. TMI-l B 2nd Q 1984 l for maintenance tasks.
Resp: Estimate completion 2nd quarter 1984. The Plant Engineering Director has made a trip to Oyster Creek to review their, revised Plant Engineering organlaation. A proposal for revising the Engt-
~
neering organlaation at TMI-l will be submitted to 0/P. Our goal is to assign responsiblitty for each plant system to a specific engineer; i.e.. establish a program of " system experts".
III.C (c) Rec: Delay assignment of corrective maintenance I. 0/P C 3rd Q 1984 function to M&C until after Unit I restart.
Resp: Re-evaluation postponed to 3rd Q 1984. , l Lindina IIL-D: Major deficiencies tri the chemistry program at THI-l were identified two years ago. Correctians have been slow. .
III-D Rec: Upgrade of chemistry program, k2y manager. III. T. F./ A Complete " l standardi2e analytical procedures. TMI-1 Fesp: The formal Chemistry Upgrade Program has been completed and the Plant Chemistry Department is prepared to support restart and extended plant operations. An NRC audit of the Chemistry Pro-gram in November 1983 confirmed the readiness of the Chemistry Program to adequately support the plant- An ongoing iction item system has been est::blished between LNr plant and Technical Functions to track those items where further improvement is still desirable and any new emergent items.
L________ _ _ _ _ _ _ _ _ _ - _ _ _ _____
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BETA FINDIhG/ STATUS R[CQtti[BQ. PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE _ CAI. 01y1510M CODE COMMENTS flading_III-E: The numbrr of different engineering groups at the site is centributing to loss of efficiency.
III-E Rec: Revttw number of site engineering groups and their II. 0/P A Complete dirc: tion with objective of reducing their number (all applicable divisions).
Resp: Combination of Functional Grganization and use of gen-eric titles (Engr. I, etc.) tends to give appearance of large number of groups. Essentially all positions identified require engineering background. Review complete.
Elndina_Ill:f: There are too many instances where rad controls are not as good as th?y should be. The work force has not accepted enough of the responsibility for high quality rad work performance. Excessive generatton of radioac.tve waste is part of these problems.
III-F (a) Rec: Increase efforts of manager and supervisors to achieve III. THI-1 A Complete
- l excellent radiological performance by their workers on every job.
Resp: This item should be closed out; however, ongoing Ongoing effort efforts and programs to achieve excellent radto-logical performance must continue as a normal way of conducting operations and maintenance of the plant.
4 In 1983 the plant came in well under the person-rem goal but exceeded the personnel contamination goal.
More emphasis and attention to reducing skin contami-nations are being applied. Radiological goals have been established for 1984. Will continue to emphasize Rad Awareness and continue effort % with M&C.
III F (b) Rec: Improve Rad Con management and work force IV. R&EC/ A Complete management working relationships. THI-1 Resp: Experience with OTSG and other work shows current organization and personnel working well together.
III-f (c) Rec: Upgrade rad. technician performance by improv- III. R&EC A Complete
- l ing ability to identify and report deficiencies.
Resp: Cyc1tc training specifically addresses recom-mendation; increased number of RDR's submitted by technicians indicate improvement.
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BETA FINDING / STATUS RECQtit M Q. __ PARAPMBASED RECQtt!ENDAUDN & St991ARY RESPONSE _ CAI. 0lY111QN CQQL. .
COMMENTS III-F (d) Rec: Speed correction and problem solving of rad. III. RAEC/ A Complete deftetencies. THI-l Resp: Response to III-F-(c) will help on this. Efforts 4 underway to provide T. F. assistance on recurring items requiring engineered solution.
III-F (e) Rec: took to decrease number of rad. techs. as work II. R&EC A Complete
- l force practices good rad work performance.
Resp: M ll be addressed in setting '84 & '85 authorized levels of manpower. The numbe* of rad. techs.
has been reduced from 30 to 24. This number will be maintained for 1984.
III-F (f) Rec: Achieve recommendations III-F(a) through III-F(e) III. R&EC/ A Complet.a re: radiological practices without new systems TMI-l and gissMcks.
Resp: No new sy:*tems or gieunicks have been used.
See responses to III-F(a) through III-F(e).
Ejndin.e_1114:1: The warehouse inventory records have enough nomenclature inaccuracies to degrade efficiency.
III-G-1 Rec: Program to improve nomenclature of inventory records. III. Admin./ B 3rd Q 1984 l Resp: Physical inventory complete. Warehouse discrepancy TMI-1/
reports being used effectively and service has to- M&C M&C Division will support proved significantly. Improvements in inventory Materials Management in this nomenclature have been made via AMMS for items pro- effort to improve nomencla-spectively procured. Warehouse and site personnel ture of inventory records.
. have also made changes on a case-by-case basis.
Technical Functions and Materials Management are jointly proposing establishment of a unit to assign consistent and accepted nomenciature. These efforts must be conducted in parallel with reduction of surplus inventory items wh nh is part of ongoing Warehouse Reassessment Program scheduled for com-pletion in August 1984.
Hnding_H 1 1 2: The anount of stock at TMI is excessive.
III-G-2 Rec: Purge TMI stock of unnecessary material. III. Admin. 3 4th Q 1984 Resp; Program underway. Admin Division Goal for 1984.
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BETA FINDING / STATUS RECOMMQtD _PAk4 PHRASED RECOMMENDATION & SUPetARY RESPONSL_, CAI. DIVISION _CQQL. C.MNTS Eindina III-G-3: The period of time from preparation of a requisition to c~titvery of purchased material is too long.
III-G-3 Rec: Plant Engineering prepare generic specs. for com- III. TMI-l A Complete
- l monly used materials and consumable stock items.
Resp: Gen (ric specs have been prbduced for a large Ongoing effort, number of items and are used whectver appropriate.
Others are being prepared on a case-by-case basis for comanonly used items as time permits. This is
- an ongoing program that will continue through Ilfe i of the plant. Present progress is good considering other vital restart work in progress. The number of reviewers in the approval cycle contributes more to administrative delay than the availability of generic specs.
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Findina III-H: There is a need for the TMI Human Resources group to improve further their responsiveness to site needs.
III-H Rec: Review manning and effectiveness of Human Resources II. H. R. A Complete support of THI-I Resp: Effectiveness substantially improved. Hanning will be addressed as part of XII-E.
Findina III-I: A revtew of the number of people assigned to administration work at THI-l appears excessive.
III-I Rec: Look to reduce on-site clerical / admin. support II. TMI-I B 3rd Q 1984 Resp: Operations Analysts is currently studying division-by-division beginning with the Administration Olvision.
- Complete for TMI-1 Otvision Plans.are in place to reduce the TMI Information Center by 13 temporaries by 12/83 and by 8 GPU System employees by 12/84. Operations Analysis review of ;
non-exempt, non-bargaining secretarial support com-pleted for THI-1 staff in 1983.
2/27/84
- BETA FINDING / STATUS RECDPe1END. PARAPHRASED RECPtetENDATION & SUP94ARY Resp 0NSE CM. DIVISI0h CODE COMMENTS Qxiler Creek Findinas & Recomendations Eindina IV-A-1: The role of the Director. Oyster Creek needs to be clarified and strengthened with r.:spect to the ccerall site operation.
IV-1. -1 ( a) Rec: Office of the President foster understanding I. 0/P A Complete " l nf how functional organization should operate.
Resp: Continuing effort reflected in Corporate Objective 5.
In 1983, Corporate Goal 9 & Management Training Program respond directly.
IV- A-1 (b) Rec: Continue emphasis on support role of non-plant divisions. I. 0/P A Complete
- l Resp: Continuing effort reflected in Ccrporate Objective 5.
- Added specific wording to Plant Division Functions
- Strengthened Plant Olvtston role in Budget Process IV-A-1 (c) Rec: Emphast2c ellaination of jurisdictional disputes. I. 0/P A Complete Resp: Covered in Corporate & Divisional Staff Meetings &
ouring Inter-divisional work progress / status meetings.
Substantial teprovement achieved.
IV-A-1 (d) Rec: Encourage support for and woeWing within new I. O. C. A Complete " l organtaatton.
Resp: OC Div. Staff meetings include Support Divisions and this issue is addressed directly and indirectly. Experience during OC outage will rapidly mature organization.
IV-A-l (e) Rec: Encourage freer discussion among divisions. I. D/P A Complete
- l Resp: 1983 Corporate Goal 9 directly addresses issue. ,
I IV-A-1 (f) Rect Encourage upward not dowrmrd corporate policy III. 0/P A Complete " l
. complaints.
Resp: Continuing effort reflected in Corporate Objective S.
1983 Corporate Goal 9 and management program ree'sid directly.
findingjV A-2: The functions now performed by Plaas and Programs could be accompitshed more officiently.
IV-A-2 (a) Rect Hold section to current size (Plans & Programs). II. O. C. A Complete l Resp: Size has been held.
IV-A-2 (b) Rec: Use DC Plans and Programs section as service I. O. C. A Complete not line authority organt2ation - coordinator Resp; Role has been clartfled - Ref: PRC memo of 2/11/83.
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2/27/84
- BETA FINDING / STATUS RfCDMEIMD. PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE COMMENTS
_ E3ndtna_IV:S: There is a lack of involvement by Operations in nyster Creek operator training.
IV-B Rec: Ensure Operations involvement in Oyster Creek V. 0.C. A Complete training programs.
Resp: Steps to increa e Operations Department involvement in operator training have been taken. DC Objectives 7 and 10.
Findina IV-C: Workers do not pick up after themselves.
IV-C Rec: Management to emphasize worker tidiness in job III. M&C/ A Complete " l performance. 0.C.
Resp: Oyster Creek Objective 4. Still a problem. Ongoing effort especially with contractors. M&C Management has emphastaed worker tidiness in job performance.
This is an ongoing process. Periodic checks are being performed by supervisory personnel on both
. on- and off-shift tours. Progress made in 1983 despite outage.
Ejndina 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 M&C personnel increase involvement in I. M&C A Complete " l
. organizational and divistanal interface problems.
Resp: Being addressed by M&C Otv. participation in DC Ongoing effort, outage neetings and M&C Div, seetings with M&C management at 0.C. down through area Supervisors.
M&C is routinely represented at Site Director meetings.
H&C ts complying with this recommendation.
IV-D-1 (b) Rec: Other site management must increase involvement I. M&C/0.C./ A Complete in resolving interface probless resulting from R&EC/N.A.
maintenance realignment.
Resp: Efforts by Division Directors including Staff meetings. Outage coordination. etc., have sub-4 stantially reduced interface problems.
IV-D-1 (c) Rec: -Ensure familiarity and practice of new maintenance III. M&C/ A Complete " l procedures. 0.C.
Resp: Oyster Creek Objective 5. Experience to date Ongoing effort.
satisfactory. M&C Division is complying on an ongoing basts; incorporated as part of the re-quired training.
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. 2/27/84 -
BETA FINDING / STATUS RECoretEND. PARAPHRASED REC 0PetENDATION & SuretARY RESPONSE QI. DIVISION CODE COMMENTS Elnding_lL D J: The sanctity :A coffee breaks at Oyster Creek is a sizeable contributor to poor productivity.
IV-D-2 (a) Rec: Negotiate morning coffee break out of union agreement. IV. H. R./ E Disagree
, Resp: Part of the Labor / Management Agreement; would be very O. C.
complex to change and the conclusion is to not attempt the change.
IV-D-2 (b) Rec: Eliminate p.m. break or allow management to IV. H. R./ C 2nd Q 1984 l r determine timing. O. C.
Resp: Management has ablitty to set whether break is allowed and if so, the timing. Management rights identified to all managers and supervisors by ,
JCP&L in training programs. Plan is to address this through supervisory training after negotta-tions are concluded.
1 findina IV-D-3: Mechanics under co9 tract through M&C do not stay on the job untti the end of normal working hours.
IV-D-3 Rcc: Keep MEC contractor emoloyees on job until end of IV MLC/ A Complete
.w orking hours. 0.C.
Resp: Contractor shift scnedules haet: been formalized and received by Site Director. Contractor work
, hours in accordance with contract, h fingwa IV-D-4: Only a fraction of the preventive maintenance routines planned for accomplishment are c wpleted.
IV-D-4 (a) Rec: Expedite loadtng preventive maintenance system III. O. C. A Complete " l schedule in GMS.
Resp: Oyster Creek Materiel Department Goal for '83 (DC 32) FMS schedule has been loaded into a program.
IV-D-4 (b) Rec: Learn from TMI-l preventive maintenance program. III. O. C. A Complete Resp: Direct P.M. liaison established and functioning.
~
l IV-D-4 (c) Rec: Consider reducing Preventive Maintenance Manager's II. O. C. D 3rd Q 1984 staff when program stablitzes.
Resp: Will address in '85 budget based on first half i '84 experience.
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2/27/84 . i i
BETA FINDING / STATUS I
, RLC0fetEND. PARAPHRASED REC 0petEnDATION & SLBetARY RESP 0NS[. Cal. DIVISION _.CQQ[_ ,
C0retENTS 1 f1Dgina IV-D 5: Mobile maintenance is a costly way to perform plant maintenance.
IV-D-5 (asb) Rec: Consider negotiating agreements with better uttit- IV. MLC
- 8 4th 0 1984 l
- j. 2ation of Mobile Maintenance. Consider making l Mobile Maintenance employees who perform most of their work at Oyster Creek part of MEC Division.
1 Resp: MEC Division is taking steps to reduce the number of i
, Mobile Maintenance personnel located at the site. In i progress through attrition. Target completion 40 1984.
1 Findina IV-E: Problems in performance of the chemistry control program at Oyster Creek were found to be similar to the problems at TMI-1.
!' IV-E Rec: Continue upgrade'of chen. program - designate key III. T. F./ A Complete
- l I
manager, standardize analytical procedures. O. C.
Resp: Progress is being made consistent with reconnen- Ongoing effort.
j- dation. Chemistry function has been transferred l from Engineering to Operations and the Chemistry Manager is providing the required leadership.
Completion of Oyster Creek 1983 Objective 10 and related Operations Department Objectives 21 to 25 !
! will complete response. Continued chemistry program I upgrade results are highly satisfactory. NGC/QA
- audits have resulted in no findings. Procedure rewrite is complete. New QA/0C procedure has 2 been written new instrumentation installed, daily ,
review of all chemistry results, and current coent-l lzance of chemistry of miscellaneous systems ongoing. !
1 .
Findina IV-F-1: There are too many separate section level groups having enstreers at Oyster Creek.
IV-F-1 Rec: Provide lead site representative for each Division II. 0/P A Comp'lete
- l
.for nontechnical items. O. C./
. Resp: Improved understanding of roles and Divisional TMI-1 5
internal guidance has largely achieved result. i
, No further specific actlen planned. ,
- findina IV-F-2
- The projected manpower level is high far the Oyster Creek Nuclear and Core Management group.
IV-F-2 (a) Rec: Develop operatiae procedures to redut.e dependence on III. O. C. A Complete
- l
, Core Management Group (Nuclear and Core Managemer:d).
-9 esp: Implementation of Powcr Shape Monitoring System (PSMS) will reduce dependence on Core Engineering. 0.C. Plant
, Engineering Departrent Objectiva 46. PSMS implemented.
- No effect on manpower yet.
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2/27/84 ,
BETA FINDING / STATUS RECOMMEND PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE CDryENTS IV-F-2 (b) Rec: Assure no duplicate efforts with TF Nuclear Analysis I. T. f./ A Complete and Fuels section (0.C. Nuclear 1 Core Management) O. C.
Resp: Review shows no overlap. Improved coordination has -
developed.
IV-F-2 (c) Rec: Re-evaluate and look to reduce staffing level of Core II. O. C. E Disagree Management Group.
Resp: Evaluation of requirements indicatec a staffing of six engineers and a manager / supervisor is required.
Reduction of one cngineer from Plant Engineering planned for 1984, not specifically from Core Group.
- Eindian_Iy:G: 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 perfonmance. Excessive generation of radioactive waste is part of these problems.
IV-G (a) Rec: Increase management efforts to obtain excellent radio- III. R&EC/ A Complete " l logical performance by their workers routinely on jobs. 0.C./M&C Resp: This is an ongoing effort which is supported by Oyster Ongoing effort.
Creek, M&C and R&EC senior people. The Radiological Assessment program. plant tours by management and Radio-logical Deficiency Programs are being used to monitor progress on this effort. Has been incorporated into the M&C 5-Year Plan and a man rem reduction program is included as a 1984 M&C Division Goal. Pre-job briefings have been formalized. The briefings are conducted by craft supervision who emphasize the need for good radio-logical practices. Improved Rad Awareness Ccamittee is
. in place.
IV-G (b) Rec: Imprcve Rad Con management and work force sanagement I. R&EC B 2nd Q 1984 l working relationships. 0.C./MLC Resp: Preparation for and initial work during outage have resulted in substantial improvements in working rela-tionships. A Radiation Awareness Committee has been formed and has held routine meetings since 5/20/83.
4 See responses to IV-G(a) and (c). Programs are in place to improve the working relationships; however, additional effort is needed.
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2/27/84 .
BETA FINDING / STATUS Bf10HMENQ. PARAPHRASFD RECOMMENDATION &
SUMMARY
RESPONSL_ CAI. DIVISION _CQQL_ COMMENTS IV-G (c) Rec: Use radiological awareness committee similar to III. 0.C./M&C/ A Complete that at THI-l to help in accomplishing recommen- - REAC dations IV-G-(a) and (b).
Resp: An 0.C. Radiological Awareness Committee was established and has functioned since 5/20/83.
IV-G (d) Rec: Upgrade performance of rad. con. techs. by improving III. R&EC A Complete rad. deficiency identification and reporting.
Resp: Efforts continue via cyclic and seminar training; improvements have been as indicated by fewer find-ings of posting and labeling deficiencies by O. C.
Rad Assessor. Effective implementation to continue.
IV-G (e) Rec: Accelerate correction of rad. deficiencies and III. R&EC/T.F. A Complete increase attention to problem solvins. 0.C/MEC/
Resp: The respcase to Reconnendations 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 reduced and emphasis placed on this area by formation of the Rad Improvement Committee in 8/83.
IV-G (f) Rec: took to decrease number cf rad. techs. as work II. REEC B 3rd Q 1984 force practices good rad, work performance.
Resp: Will be addressed in setting '84 & '85 authort2ed Conplete for 1984 levels. l levels of manpower. Will reduce number of Company rad. techs as work practices improve.
i IV-G (g) Rec: Commence rad technician training to handle unusual V. R&EC/ A Complete situations not covered by written procedures (Rad. Con.) O. 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 systess to achieve III. R&EC/ A Complete improvement in radiological practices. 0.C./H&C Resp: All related recommendations are being carried out using the present management systems.
2/27/84 -
BETA FINDING / STATUS RECOMMEhD PARAPHRASED RECDMMENDATION & SUMMARL RESPONSE CAI. DIVISION CODE .. CDHMENTS Elpding IV-H: Sentor management people at Oyster Creek are spending too much time on PORC netters.
, IV-H Rec: Review Tech. Specs to determine if present wording III. O. C. B 2nd 0 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 to and Expect implementation issued by NRC which will meet this recommendation. early 1984.
Equivalent issue under new review procedure will be addressed during implementation of new admints-trative procedures.
Findina IE-1: The number of people assigned to administrative work at Oyster Creek appears excessive.
IV-I Rec: Reduce on-site clerical and administrattve positions. II. 0/P D 1st Q 1984 (All divisions.) Office of the President set arbitrary number.
Resp: Is being addressed in overall manning: Operations Analysts will study IQ884.
Findina IV-J-1: The purchasing operation at Oyster Creek is receiving inadequate clerical support.
IV-J-1 Rec: Consider reassigning under-uttitzed clerical personnel II. O. C. A Complete to Purchasing to support processing of requisitions.
Resp: Additional rarsonnel assigned to purchasing. Routine requisitions sent to Parsippany to handle. Aspect of
, recommendation pertaining to under-uttlized personnel will be covered in response to IV-I.
{
Findina IV-J:2 The storas 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 III. O. C. A Complete direct access'to inventory records.
Resp: CRT's at site can be used to gain access to Inventory Control System.
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2/27/84 .
.. BETA FINDING /: .
Bf C0tetEND'. PARAPHRASED RECOMENDATION 1 St##tARY RESPONSE CAI. Q1y] SIGH ~CODE STATUS ComENTS i:
? 'I li J-2 (b) Rec:
s Carefully plan disposal of on-hand direct turnover III. Admin./ B Review for status 2Q 1984 {
material not required for. plant: support. O. C.
Resp: Substantial progress in improving support to site .'
j' i
operations by the warehouse has occurred under the ~- .
Warehouse Reassessment Program implemented in 9/83. -
Surplus OTO matertals have been identified to the user community for 1) addition to inventory; 2) use 1
on ongoing outage projects; and 3) for disposal. . ,
The latter effort is being hampered by the lack of ! + / '
sufficient engineering support to review candidate -
items for disposal; issue has been elevated to -;
~ senior renagement for resolution. Review for status '
6/84.
IV-J-2 (c) Rec: Consider staging of material on a job basis. III. M&C/0.C./ A Complete / i' '
Resp: Review conducted. Proceeding to " stage" in Admin.
~ '
data base, tag stock material for specific jobs ,
and stage major jobs for outage. <
E10dina IV-J-3: Delays in processing invoices for payment are creating signtficant problems for Purchasing.
IV-J-3 Rec: Backlog in A/P should be promptly eliminated. III. O. C. A Complete Resp: Substantial progress made. Backlog has been significantly reduced to manageable levels.
Monthly trending is in place.
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4 BETA
. FINDING / STATUS 1 RECOPMEND PARAPHRASED REC 0ffiENDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE COMMENTS MuClear Assurance Findinas and Reconsnendatio01 E10dina 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 administrative functions I. N. A. A Complete
, from Reading to Parsippany.
Resp: D. hetrick no longer with GPUN: Function assigned in Parsippany under R. Hedges.
Ejndina V-B There are many training and development courses offered which are useful but not essential.
4 V-6-1 Rec: Review Management Development courses and elistate V. N. A. A Complete I those which do not materially contribute to safe and efficient operation oF the plants.
Resp: Extensive review of all management development i programs have been made and present selection of programs is considered to contribute to the up-grade of managerial skills.
Eindina V-B:2: The headquarters training group is not concentrating enough on coordinating plant training efforts.
V-B-2 Rec: Coordinate and oversee effe !s of the two site V. N. A. A Complete training groups.
- Resp
- New Director. T&E is coordinating plant training i efforts. establishing Departmental Policies and Procedures and modifying present corporate train-
- ing structure.
Findina V-B-3: There are inefficiencies in the THI training effort due to a lack of meaningful schedultr.g. The Training Department has difficulty in obtaining data to schedule its training.
V-B -3 Rec: Develop realistic training schedules on an annual basis. V. N. A. B Ist Q 1954 l l Resp: The 1983 scheoule for all supervisory and management development has been generated. New initial training programs in operator and other technical areas have
- been scheduled. Efforts to expand master schedule and resolve scheduling probless will continue on an on-going basis. Finding should be closed by March 1984.
1 i Eindina_Y:B:3: There is an overly " understanding" attitude which prevails in the TMI Training Department, especially with respect to operator training.
V-B-4 (a)' Rec: Mir,imize use of outside personnel to review training V. N. A. A Complete program utilize in-house personnel instead.
Resp: ,Will follow except for AStB mandated audit and INPO.
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2/27/84 .
BETA FINDING / STATUS BfCQttlEND. PARAPHRA3ED RECOMMENDATION & St#etARY RE5PONSE CAI. dlVISION _CQQE._ C0fetENTS V-S-4 (b) Rec: Concentrate on providing best training program, not V. N. A. A Complete proving it.
Resp: Efforts to improve program contents, instructor capabilities and delivery systems continue. T&E has develaped and adopted TSD (Training Systems
. Development process). Training Advisory Committee 4
is being formed.
V-B-4 (c) Ree: Hake students more responsible for their own performance V. N. A./ B 2nd Q 1984 in training. All Div.
Resp: Each training site has generated documents of student
- M&C ti making diligent
responsibilities when in training. Documents are effort to enforce better being discussed for agreement with user departments, participation and disci-THI-l Plant Staff has loaned one SRO and two R0s to pline of its employees Training to assist in Simulator Training & Development. during company training Three R0s to take SRO exam in March. Licensing of programs
, these three SR0s will permit the Plant to provide i Training Department with some SRO licensed operators on a permanent basis. The Plant Staff is also coordi-nating the effort to prepare and issue the Operations Plant Manual which will be used as the basis for oper-ator training. Five of nine volumes have been issued but still have material to be added. Estimate that i this manual will be 95% complete by 7/1/84.
- Findina V-B-5
- There exists a lack of supervision of instructors in the THI Training Department.
V-B-5 (a) Rec: Review supervisory responsibilities with those V. N. A. A Complete assigned as supervisors of training instructors.
Resp: T&E Supervisors attend appropriate supervisory and management development courses. The formal instructor evaluation programs assure that super-visors observe their own instructors as well as i those from other sections at the Training Dept.
V-B-5 (b) Rec: Manager THI Training, improve accessibility to staff III. N. A. E Disagree by relocating office.
Resp: Office is in Training Building. Accessibility has been emphasized. Relocation not needed.
2/27/84 .
BETA FINDING / STATUS RECOP91END. PARAPHRASED RECOMMENDATION & SupetARY RESPONSE CAI. DIVISIQll CODE CDPetENTS V 8-5 (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.
Resp: Individual supervisors and lead instructors are always held responsible for monitoring the actt-villes of persons reporting to them. During sustained periods of absences (e.g. vacation, simidator training), an acting manager or super-visor is designated by memorandum.
Findina V-B-6: Findings reported on THI-1 Training have appitcability at Oyster Creek.
V-B-6 (a) Rec: Apply reconnendations for TMI Training to training V. N . A. A Complete program at Oyster Creek.
!: Resp: Headquarters and Oyster Creek Training Cepartments have reviewed BETA TMI training recommendations.
The responses in this report are applica3Ie to all three training locations.
4 V-B-6 (b) Rec: Headquarters Training mandate the coordination of V. N. A. A Complete training programs at TMI and Oyster Creek.
Resp: T&E Department Policies and Procedures have been developed and are being implemented as official i document for coordination of site training programs.
Eindina v-C-1: There are more QA engineers tLan necessary to carry out the requirements contained in the GPUN Operational Quality Assurance
)
' Plan.
- V-C-1 Rec
- Reduce the number of engineers assigned to QA II. N. A. A Complete j
. Engineering as Technical Functions. Plant Engi-neering, and M&C mature.
i 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-l is still waiting restart.
TMI-2 is still in a recovery mode and Oyster Creek is in a prolonged outage), it is anticipated that j
the number of engineers assigned to QA Engineering will remain the same. Activities indicated by the production indices have increased. QA Engineering has looked at and continues to look at new means for becoming more efficient.
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2/27/84 .
BETA
- FINDING / STATUS RECOMMEND PARAPHRASED RECOMMENDATIDN &
SUMMARY
RESPDNSE CAI. DIVISION CODE CDMMENTS E10Glpa V-C-2: There are too many people assigned to Operations QA for the expected decline in the future work load.
. V-C-2 Rec: Reduce number of QA monitors through attrition as II. N. A. A Complete
, 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 management ini-tiatives directed at THI-l resulted in an increase of six QA shift engineering monitors for Unit 1.
No changes were made for Unit 2 or 0.C. since no reduction in work load or production indices was .
projected for 1984.
Eindina v-C-3: The Hanufacturing Assurance section is larger than is required for known future work.
V-C-3 Rec: Reduce size of Manufacturing Assurance section as II. N. A. A Complete manufacturing effort associated with large modifi-cations decreases.
Resp: The number of QA representatives in the Manufacturing Assurance Section was reviewed during the 1984 Budget process. As a result of efficiencies established by i that section, the number of contractor hours required to support the program has been significant'f reduced but
- the number of QA representatives will remain the same.
' This will again be reviewed in 1985 budget process.
I EJndina 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 Complete implementation of the new Operational QA Plan.
- Resp
- QA Director has remained involved. Implementation complete.
.} E1011na v-C- 5: The THI-l QA Department creates the illusion in the minds of others that the Department is not supporting the plants.
4.
1 V-C-5 (a) Rec: The Director. Quality Assurance, take necessary III. N.A. A Complete i positive steps to improve perception of the QA Department among senior r.anagement.
. Resp: Director, QA has specifically addressed this with his staff - significant improvement noted.
V-C-5 (b) Rec: Division Vice Presidents encourage staff personnel III. '0/P
- Complete to support and assist in the execution of the Corporation's Operational Qudlity Assurance Plan.
Resp: Support has been made clear by all Directors to ti.etr staff. Results evident.
2/27/84 -
BETA FINDING / STATUS i BECQt?'{HQ. PARAPHRASEILBICattENDAIIONMutEARY_RESNMSL CAI. 01YISION .f.001_ COMENTS
- JgstulinL.Eunctigos Findinas & Rec-ndations Eindina VI A
- The overall effectiveness of Technical Fur.ctions in supporting IMI-I and Dyster Creek is lacking.
VI-A (a) Rec: Maintata present manning levels within Tech Functions. II. T. F. A Complete
. Resp: Authorized level for 1983 was same as 1982. 1984 will be sitehtly lower.
VI-A (b) . Rec: Revicw methods to improve the senagement of the III. T. F. B 4th Q 1984 l l large engineering group within TF.
Resp: Since thJ BETA review over a year ago, Technical Functions has made significant improvements which facilitate the management of engineering work.
These include the issuance of detailed schedules
, for significant engineering projects, computerized i ~
" work-in-progress" status and look ahead reports, etc.
In addition, most management positions have been filled and required procedures have been issued.
4 As the organization has matured, the procedures have been revised to reflect improvements.
From time to time, the Technical Functions staff meets to discuss problems (and solutions) which tend to de-tract from the efficient management of-its activities.
During such discussions, we have not uncovered internal pro blems which were not resolvable within the present
, organizational structure and procedural system. We view
, this mechanism as an ongoing process required of all j organizations to permit them to detect and respond to ,
, current or impending problems. There continues to be 4
problems of a corporate kind which impact the efficient operation of a central engincering group. Suggestions s
have been made to Dffice of the President for resolution.
- VI-A (c) Rec
- Evaluate and procure outside assistance to train TF III. T. F. D ist Q 1984 l
, Management in supervising a large engineering group.
Resp: During the first quarter, 1983 Technical Functions arranged for Sterling Institute to present a 35 hour4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />
. course entitled " Technical Management" to approximately 50 managers / senior engineers. This course was designed
, around GPUN organlaational responsibilities and Technt-e cal Functions' procedural system. The program was only moderately successful. We have recently requested the Training Department to interview key Technical Functions directors / managers to determine if there still exists perceived deficiencies which are resolvable by perhaps another training firm. Dur plan of action will be
- finalized during the first quarter of 1984.
f 2/27/84 . '
BETA FINDING /. STATUS 8[CQtt1ENQi PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. DIVISION _f0DL ComtENTS Eind101_Y1:R:1: It is too hard and takes too long to get a Technical Functions procedure changed.
VI-B-1 Rec: Respond to requests for chaages to Engineering III. T. F. A Complete Procedures and Standards promptly.
Resp; Initial issue of interface procedures complete.
Timeliness improved and now adequate.
Findina VI-B-2: The Engineering Cost Analysis section is not analy2ing costs.
VI-B-2 Rec: Redirect the efforts of the Cost Analysis section III. T. F. A Complete 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 Management persun to T. F. to provide cost reporting.
E111di!19_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 III. T. F. A Complete s and maintenance purposes when Design Correction Notices are received so that drawings are current as regards modifications so no applicable DCN will be sere than 6 months old.
Resp: Engre. Procedure EP-025 issued and describes policy on updating. Being fcilowed by Tech Fur.ctions. Backlog is being reduced.
Findine VI-B-4: Rework, as measured by the number of Field Change Notices, is excessive.
VI B-4 Rec: Conduct design reviews before work is started to III. T. F. A Complete decrease need for Field Clinge Notices during construction, operation, or maintenance.
Rasp: Procedures now require design reviews. This has been implemented since Fall '82.
Findina VI-C: There'are too many people assigned to the Director. Licensing & Regulatory Affairs.
VI-C (a-1) Rec: Effect reductions in the' number of people assigned II. T. F. A Complete
, to L&RA.
Resp: Is being addressed in '84 & '85 budgets as appropriate.
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2/27/84
- BETA FINDING / STATUS
, RECOMMEND. PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. D'YJSIDM CODE COMMENTS VI-C (a-2) Rec: Redefine the role of Licensing and Regulatory Affairs I. T. F. A Complete (LaRA) 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.
- Findina VI-D
- There is a lack of intimate day-to-day knowledge of the probleas being found at the plants that require engineering support or involvement.
VI-D Rec: Investigate means for having plant information and III. T. F. A Complete problens flow into the Engineering and Design organi-zation on a routine basis, not just when TF support is required.
Resp; Specific systems and components have been assigned to off-site engineering groups to increase day-by-day
' involvement. Also, anst on-site Technical Functions engineering groups, such as Startup & Test and STA's, are almost fully staffed and intimate knowledge of plant problems,has become a reality.
Eindina VI-E-1: The Shift Technical Advisor (STA) program at both sites, but particularly at Oyster Creek, needs to be reviewed and i strengthened.
VI-E-1 (a) Rec: In the process of developing the Shift Technical V. T. F. A Complete i
Advisor (STA) training program, place a greater emphasis on providing the trainee with a firm technical foundation and less on seking him a qualified operator.
Resp: STA program has been revised to provide technical E.shasis in addition to operating information.
4 VI-E-1 (b) Rec: Consider eliminating the requirement that STA's I. T. F. A Complete obtain an SR0 license.
Resp: Have completed evaluation. License requirement will be continued.
VI-E-I (c)- Rec: Ensure that suffletent STA's are in the training V. T. F. A Complete
. program to compensate for attrition and to satisfy promised rotation at the same time.
Resp: THI and 0.C. have adequate numbers.
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- BETA FINDING / STATUS BECOMMEND PARAPHRASED RECOMMENDATION & SLD#tARY RESPONSE CM. QIVIMDH CODE COMMENTS VI-E-1 (d) Rec
- Review responsiblitties of the STA's during normal V. T.F./ A Complete
- l and abnormal situations with the STA's and with shift 0.C./
supervisors. THI-1 Resp: Responsibilities are defined. Procedure ES-005 4
revised to clarify responsibilities of STAS and have been reviewed with shift supervisors and foremen at THI-1. Tecnnical Functions will par-ticipate in discussions with operations personnel if requested by THI-l and Oyster Creek.
a Findina VI-E;2: The need for a Systems Analysis Director is questionable.
3 VI-E-? Rec: Eliminate positic of Systems Analysis Director. II. T. F. A Complete Resp: Action already taken on this item at the time of BETA report.
Eindina VI-E-3: There is a lack of involvement by Technical Functions in the conduct of the Training Program, particularly operator training.
, VI-E-3 Rec: Provide technical guidance to training prograss, V. T. F. A Complete
- l especially operator training.
Resp: Technical Functions Procedure EP-015 developed and now being implemented for both Oyster Creek and TMI-1. Technical Functions is actively re-
- viewing training material for technical content.
Ejndina VI-E-4: GPUN's goal to achieve an in-house licensed nuclear design capability may not provi6e the anticipated advantages.
V!-E-4 Rec: Do not develop an in-house licensed nuclear design III. T. F. E Disagree l capability unless GPUNC is willing to restrict feel selections to proven technology and not attempt to incorporate advantages in performance until they have 4 been thoroughly tested at other plants.
, Resp: Technical Functions disagrees with this recommendation.
Our plans to oavelop in-house reloat capability have been forwarded to the Office of the President for con-currence and authorization of additional personnel.
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2/27/84 .
BETA FINDING / STATUS BECOMMEND. PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. QIVISION CODE COMMENTS Eludina_Yl f;1: Engineering Projects personnel are performing tasks that could be better done elsewhere in the Division, thus decreasing their capacity for the management of engineering projects.
VI-F-1 Rec: Evaluate functions currently performed in III. T. F. A Complete Engineering Projects and reassign those that detract from project management capability.
Resp: This had been underway. Situation resulted from JCPat combined engineering for 0.C.
Reassignments complete.
Findino VI-F-2: Ine training of project engineers is weak.
VI-F-2 Rec: Provide training to Project Engineers in CPUNC V. T. F. A Complete organizational structure, methods, and policies.
Resp: Training program conducted late '82, early '83.
Einding_VI:f:J: Project 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 D&M project.
VI-F-3 Rec: Devise reports that will penmit having a running III. Admin./ B ist Q 1984 knowledge of cost and performance. 0/P Resp: Improved reports in place. Efforts will continue into '84.
E10dina 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 Complete Test group into the Systees Engineering group. Assign site personnel in this group to Plant Engineering.
Resp: Has been considered. No change to be made at this time.
Believe SuaT shculd be within Tech. Functions. D01 Plant Engineering. Work load for next year is high and critical.
Any possible gain by reassignment within Tech Functions would be offset now by disruption due to change.
Einding_Yl-d: Neither the chemistry group in Technical Functions nor the System Laboratory has assumed a leadership role in the THI-l or Oyster Creek Chemistry improvement programs.
VI-H (3-1) rec: Remove System Laboratory from GPUN after the Chemistry I. T. F. E Disagree Programs at TMI-l and Oyster Creek have been improved.
Resp: Disagree. Management of activity to benefit both nuclear and fossil activities best served b/ oresent location.
VI-H (a-2) Rec: Provide T.F./ System Laboratory leadership to plant I. T. F. A Complete Chemistry improvement.
Resp: New TF Chemistry Director has been directed to get actively involved in improving the site chemistry programs. This has been implemented effectively.
a 2/27/84 .
BETA FINDING / STATUS REC 0tetEP(D. PARAPHRASE!LREC0ttlENDAIION &
SUMMARY
RESEQMSL CAI. Oly1SIQg _fQQL COMMENTS AdilllnlitLAt1Dii Findinas & Rec ==andations
. Etadtng_VIlma: The A&ninistration Olvision needs to improve its ability to provide a tervice function and to lessen the perception that it 4 is a control function.
VII-A (3) Rec: Continue to redirect efforts to provide an effective I. Admin. A Complete " l service to other divisions.
Resp: Admin. Division Goal 3 for 1983. Concerted effort i has been devoted to provide responsive support to other dtvisions. Warehouse deliveries to the TMI protected area and extraordinary procurement support to the Oyster Creek outage are two illustrations of I this commitment. Special rate case support, budget administrators operations analysts. Information Center Services, policy and procedure consultants
.i are all in place providing high quality services to the divisions. Many memos of commendations by those served support conclusion of satisfactory service 4
perception by all divisions.
VII-A (b) Rec: Change impression that Administration Division I. Admin./ A Complete determines how corporate policy is to be carried 3/P out in administrative matters.
Resp: Direction proivided by 0/P & Director. Admin. Div.
- through such items as Admin. Div. Goal 3.
VII-A (c) Rec: Adopt the motto "We serve the plants." I. Admin. A Complete 1
Resp: Effectively adopted by Admin. Goal 3.
Fir;ina VII-B: The Manager of M;nagement Services has a narrow scope of work assigned, VII-8 Rec: Increase scope of work as;tened to senior manager IV. Admin. A Complete 4 -(Manager of Management Services) or delete the j position.
Resp:
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Organizetion restructured.
1 Eindina_VII-C: The efforts of the Operations Analyris group within Administration are not effectively channeled.
VII-C Rec: Efforts of Operations Analysis group should be I. 0/P A Complete directed by the Office of the President.
Resp: 0/P met with 0.as. Analysis management to define role and priorities. This will continue.
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2/27/84 .
BETA FINDING / STATUS RECOMMEND PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. DIVISION _CQQE_ CCHMENTS fin 1tna VII-D: The cost reductions possible with more sophisticated contra: ting methods are not being achieved.
VII-D (a) Rec: Continue training requistioners of materials and V. Admin. B 2nd Q 1984 (H&C R&EC) services and develop a means to measure success 3rd Q 1984 (NA, DC THI-1) of training.
Resp: Requisitioner Training Course being revised to tailor to specific GPUN Div. needs presented in a " seminar" 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 requisition activity managers and permit discus-sion of practical problems, causes and solutions vs.
highly theoretical nature of initial training course.
M&C and Rad Con Seminar scheduled for 2nd Q 1984; N.A.,
4 0.C. and THI-1 scheduled for 3rd Q 1984.
t VII-D (b) Rec: Greater emphasis on Cost Plus Incentive Fee- III. Admin. A Complete type contracts.
1 Resp: Emphasis has been applied. Results tracked i monthly.
VII-0 (c) Rec: Monthly reports from major contractors identi- III. Admin. A Complete " l
' fying work progress by task and actual costs.
Quarterly reports from major contractors forecasting work progress and expenditures.
Resp: Procedures for accruing csits and ear,ed value reporting being developed and implemented.
Formal procedures in place; newly placed con-tracts now will incorporate required feature.
Responses will take several months to effect the end-to-end technique.
E1Dalna VII-E: There needs to be overall improvement in the Secarity Division in ordet to improve its efficiency.
Vil-E Rec: There necds to be an overall improvement in the . III. Admin. A Complete " l Security Division in order to improve its efficiency.
(See VII-E-1 through VII-E-10).
Resp: BETA made 14 recommendations relating to Security.
Three were rejected, eight implemented and three (of which this is one) are still open. Since the two other items are now complete or have a target date, this item is closed.
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2/27/84 ,
BETA FINoING/ STATUS RECQtg3EtiQ. PARAPHRA5ED RECOMMENDATION & SUDe(ARY RESPONSE CAI. DIVISION _[QQE_ C0petENTS Eindlag_Yll-E-1: Some security administrative functions at THI-1 and THI-2 can be combined to save manpower.
VII-E-1 Rec: THI-I access control clerk handle TMI-2 workload re- II. Admin. A Complete " l ducing staff by I control clerk. Additional savings
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would be achieved by TMI-l's clerk typist supporting THI-2, Resp: The THI-I Security staff has been reduced by one Administrative Clerk "A". It is not feasible to have THI-2 clerk typist workload transferred to THI-l.
Eindtna VII-E-2: The Response Force capability at THI-I and THI-2 can be considered to be lo armed guards (each plant will support the other). Because outside support is readily availabic, a smaller Response Force would meet NRC requirements.
VII-E-2 Rec: Combine resporse force capability at TMI to reduce II. Admin. E Disagree response force total. Negotiate with NRC to reduce i force to six to eight guards.
- Resp
- Disagree -. Separation committed to in Restart hearings and potential for demonstrations make 1,
further reductions impractical. We reconenend this issue be reconsidered after THI-I is on line as the agreepent with the NRC involves separation of Units I and 2.
Findina VII-E-3: Inadequate enginee. J and construction support for the TMI-I and THI-2 security operations is resulting in the need to substitute suards for security hardware. Such substitutions are expensive.
VII-E-3 (a) Rec: Provide adequate engineering and construction III. Admin. A Complete " l support for security operations.
l Resp: Technical Functions has assigned a Project Engineer to coordinate major Security improvements at TMI &
, D.C. (upgrading of Perim Alert pertseter barrier /
detection systeri. MEC has established a preventive /
, corrective maintenance program at Oyster Creek for Security search and assess control equipment and hardware. Technical Functions. Computer Support is coordinating efforts to correct Security computer deficiencies at 0.C. and TMI. In view of progress, recommend classifying as complete.
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1 HiTA FINDING / STATUS RECOMMEND PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE __ CAI. DIVISION CODE COMMENTS VII-E-3 (b) Rec: Develop procedures to require periodic review of III. Addn. A Complete " l security systems where minor degradations are compensate for by stationing guards to meet NRC 1
commitments Resp: The Manager-Security issued a directive requir-ing a monthly report documanting the review, the degradations and" compensatory measure costs, date of corrective action and any recommendations to ministae chances of a reoccurrence.
VII-E-3 (c) Rec: Activate alarms at fuel handling bay doors 73 and 74 II. Admin. A Complete and reduce guard force at THI-1.
Resp: Complete.
VII-E-3 (d) Rec: Activate alarms at doors 11 and 16 and reduce THI-2 II. Admin. A Complete guard force.
Resp: Cnmplete.
Findino VII-E-4: The TMI-2 entrance to the protected area uses a temporary building and manual search to control entry of personnel.
1his facility and its operation are inefficient in the use of guard manpower.
- VII-E-4 Rec
- Upgrade THI-2 Processing Center including installation II. Admip- B 2nd Q 1984 l of metal monitors and explosive monitors. Offset is reduction in guards at TMI-2.
1 Resp: Key carded turnstiles will be installed at the Unit 2 Processing Center not later than the 2nd Q of 1984.
This will result in a reduction of four man years for J
the Unit 2 Site Protection Officer force. The con-i struction of a permanent Unit 2 Processing Center to include electronic search equipment was rejected for
, the 1984 budget due to tr,e impending overall status change for THI-2 that will occur when the core is j removed from the reactor.
Findino VII-E-5: The protected area perimeter alarm system at TMI has an excessive number of alarms.
VII-E-5 Rec: Upgrade perimeter alarm system to produce a III. Admin. 8 4th 0 1984 (TMI) system with a minimum number of false alarms. 2nd Q 1985 (DC) i Resp: Project is underway at THI and 0.C., coordinated by Technical Functions. This is a long term project with estimated completion 4Q '84 (THI) and 2nd Q 1985 (DC).
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2/27/84 ,
BETA FINDING / STATUS
' PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE DIVISION COMMENTS RECQMMEND. CAI. CODE E1Ddina VII-E-6: Manpower requirements fluctuate as a result of training requirements, special security assignments and multi-shift operations. Extensive overtime is required to support this fluctuating workload.
VII-E-6 Rec: Determine times when security requirements peak and II. Admin. A Complete " l examine alternative shifts to reduce overall senpower and overtime.
Resp: Site Protection personnel at TMI and 0.C. are now assigned to permanent shifts. Experience to date shows that this system matches manpower available to shift manpower needs.
Eindina VII-E-7: Guard protection is being provided to areas that may not require the protection or warrar.t the expense.
VII-E-7 Rec: Evaluate security at THI Training / Visitors Centers. II. Admin. A Complete 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 /> / Jay, 5 days a week. Forked River has minimal coverage. Total reduction of more than 25 achieved in Security since early '82.
Eindino VII-E-h: GPUN has not received adequate support from Vikonics in correcting keycard access systems def tetencies.
VII-E-a Rec: Have an engineering ev3luation made on Vikonics' III. Admin. A Complete
- l equipment, including proposed corrective action e and input frai other ultitties using equnpment.
Provide plan of action, including engineering and legal alternatives.
Resp: Vikonics' equipment, following calibration by Battelle, was accepted by GPUN and is now operational. All outstanding procurement issues with Vikonics have been satisfactorily resolved.
E1Dd189_Yll:E 9: Appr oval has been requested to reor23n%2e the security force to establish a Lieutenant position at each site.
VII-E-9 Rec: If lieutenant position is established in Security. IV. Ad nin. A Completc the number of managers should not increase.
Resp: Implemented with no increase.
2/i7/84 ,
BETA FINDING / STATUS RffQttf[ffD. PARAPHRASED RECOMMEllDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE COMMENTS Eindins_YII:1:19: The security operations require extensive overtime.
VII-E-10 Rec: Manpower assessments in security should 1pclude over- II. Admin. A Complete time usage. Recommended levels includina overtime is Oyster Creek--62 and THI-1--48.5.
Resp: Site Protection personnel at TMI and OC are assigned to permanent shif ts, which system experience shows meets manning needs. Staffing levels recommended for 1984 at TMI-1. THI-2 and 0.C., include a small increase in staffing to address the need for reducing overtime hours.
Eindann_Y11:f: GPUN has no employee who is a medical doctor at headquarters or TMI-I or Oyster Creek to o<ersee medical aspects of the GPUN rad, health progra.m. Part time contract physicians and a contractor are used for these functions.
VII-F Rec: Employ a physician at THI and assign medical radio- II, R&EC B 2nd Q 1984 l logical health responsibilities for THI-1. THI-2, and Oyster Creek.
Resp: Board of Directors has agreed. Executive search firm actively working to recruit physician.
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2/27/84 ,
BETA i FINDING / STATUS RECOtti[NQ. PARAPHRASED REC 0fe4ENDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE cop #4ENTS _
tiLqnan ReSQur_Cei_findinas & Reconsnendatigos U Dalna VIII-1: There is a need to reduce the time it takes to complete a personnel action.
VIII-l Rec: All levels of management understand quick acticn IV. H. R. A Complete required for personnel matters. Human Resources
' . keep track of status and identify delays.
Resp: Has been re-emphas12ed throughout GPUNC. Response improved. H. R. tracking.
fiudint_Yllh 2: The nunber of GPUN personnel who have the title of " Manager" or above is high in comparison to the total number of GPUN employees.
VIII-2 . Rec: Evaluate top managerial positions and determine if V. H. R. A Complete work matches grade level.
Resp: Based on results of recorrelation and overall re- .
view of titles, response to this reconsnendation is complete.
Undina VIII-3: Productivity at the nuclear plant sites is adversely affected by current bargaining unit employees.
VIII-? Rec: Conduct review of bargaining agreements to deter- IV. H. R. B Complete (OC) l
- mine impact on work efficiency. Ist Q 1984 (TMI)
Resp: Completed for Oyster Creek 40'83. THI 10'84.
Major emphasis has been on enforcing management rights in current agreement.
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2/27/84 ,
BETA FINDING / STATUS RECOMMEND PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE- CAI. D1ylS103 _f00L. COMMENTS Ead1AlQalfal and_lUltironmental Controls Find]nas & Recommendations ELDd10a IX-A: Little rad. engineering.is performed in Parsippany.
IX-A Rec: Develop small Radiological Engineering group in I. R&EC/ A Complete Parsippany. OP/T.F.
Resp: Item reviewed with Technical Functions & R&EC to develop action plan including organtrational location of capability. As of 11/1/83 group will consist of a Manager and two Rad Engineers.
Tindina IX-B: GPUN is spending more than it should ta dollars arid manpower for environmental monitoring at THI-I and Oyster Creek.
IX-B Rec: Begin reducing unnecessary environmental monitoring. III. R&EC A Complete Resp: Non-radiological Tech Spec monitoring has been reduced at THI in 1983 after extended interaction with NRC--further reduction will only be entertained a
by NRC after 1988; non-rad Tech Specs at DCNGS were reduced in 1983 by elimination of redundant monitoring requireraents.
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2/27/84 ,
BETA FINDING / STATUS BECOMMENQ. P?RAPHRASED RECOMMENDATION & SUPtiARY RESPONSL__ CAI. DIVISION CODE COMMENTS tlaintenance & Const[:.tgtton Findinas & Reconmendatings Eindinn a : The M&C Diviston in its effort to becane estabitshed is not capita 112tng on the capabilities throughout the Corporation's functional organization.
X-A Rec: Evaluate functions within MEC and assure no III. M&C A Cosoplete dupitcation of other divisions in GPUNC.
Resp: Review and experience at Oyster Creek with re-aligned maintenaace function shows no remaining duplication, i
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2/27/84 ,
BETA FINDING / STATUS
. BECOMMEND. PARAPH. RASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE COMMENTS COW 13UCat1Qih Findinas a Rec - naations EindLngaAi; The number of people assigned to this function appears excessive.
XI (a) Rec: . Review anticipated workload to determine if properly II. Commun. A Complete penned.
Resp: During the 1984 budget preparation sequence, the
, staffing and work load of Comennications, especially the tour personnel, was reviewed.
? XI (b) Rec: Find useful tasks in other divisions for people when II. Commun A Complete not needed for primary jobs.
Resp; Some cross training complete. Was reviewed again as part of '84 budget review. See Rec XI(a).
4 XI (c) Rec: Provide more effective supervision. III. Commun. A Complete
! Resp: Vice President. Communications has spent more time in the T&E Building where the potential problem of effective supervision is greater.
Efforts continue to identify work which can be 4 assigned to those personnel to work load them
- effectively during otherwise low work periods.
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BETA FINDING / STATUS RICDMMEND. PARAPHRASED RECOMMENDATIDN &
SUMMARY
RESPONSE CAI. DIVISIDN CDDE COMMENTS General Findinas & Recommendations
, Eingina XII-A: Insufficient or poor supervtSton is contributing to poor productivity.
5 XII-A (a) Rec: Properly train supervisery personnel. V. N. A. B 3rd Q 1985 Resp: Responses to other recommendations address this Gen./DP problem directly. Revised Super"isory Develop-ment Program now complete and being delivered at TMI and Oyster Creek. Initial efforts at Parsippany to begin in February 1984. This item remains open with 80% completion of the Supervisory Development Program expected during the 3rd Q 1985.
t XII-A (b) Rec: Evaluate effectiveness of current supervisor V. N. A./ A Complete toaining course. OP/ Gen.
Resp: A special task group headed by R. Coe with D. Shalikashvili and J. Wtiliams has reviewed this program including feedback from past students.
. Recommendations for changes, as well as the addi-t tion of suplemental skill modules, will be reviewed with experienced supervisors in the various user groups. Appropriate recommendations have been in-
, corporated into new supervisory development program.
Training with new skill modules has begun.
! XII-A (c) Rec: Managers should develop their supervisors by V. N. A./ 8 3rd Q 1985 l observing them and instructing them. Gen.
4 Resp: This issue will be addressed in conjuction with the response to Recommendation XII-A-f. Has been addressed with all Managers on many occastons.
j New Supervisory Development Program includes manage-ment overview and involvement in the development of i their subordinate supervisors. This training will j be ongoing and will also be an integral part of the i GPUN Management Development process. This item re-i' mains open with 60% completion of the Supervisory
- Development Program expected during the 3rd Q 1985.
XII-A (d) Rec: Spot. unannounced visits by all division directors III. OP/ Gen. A Complete.
to work areas'to evaluate effectiveness.
Resp: All Division Directors will visit each of their
, locations where they have personnel at least per month starting 7/1/83. It will not be once efft-l cient to have very many unannounced visits to other l
locations from the Division Director's normal loca-
} tion be unannounced. This will include inspecting 4
or observing actual work areas. Division Directors are complying with recommendation.
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2/27/84 .
BETA FINDING / STATUS RECOMMEND. PARAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE CAI. DIVISION CODE COMMENTS
! XII-A (e) Rer' Improve senior management use of GPUNC performance IV. H. R / A Complete
- l evaluation system relating to supervisory performance. General
, Resp; Improvements made in 1982 and identified for 1983 provide more effective system. Emphasized in guld-ance for 1983 review. New system vdSL improvement and is being used; system use and importance reviewed with managers on suny occasions. Better definitions relating to job requirements of supervisors included.
i Performaace evaluations were completed for all top man-agement people. Needs continued emphasis but as result of improvement thus far, recomunend close out 4Q '83.
l XII-A (f) Rec: As forces stabilize, supervisors should spend more IV. OP/ Gen. A Complete " l 1 time in people matters.
j Resp: See response to XII-A(c) above The 1984 GPUN Corpo-
- M&C fully supports concept;
- rate Goals & Objectives fully support this concept. incorporated in supervisory The T&E Dept. is developing a consistent management development programs.
i develooment program at all levels det. ling with in-
- R&EC supports; supervisors
, terpersonal/ people-related skill development. At spending more time in this area.
, present, heaviest emphasis is being placed on super-
- TMI-l totally support. Emphasis
! visory training. New programs have been reviewed at manager's and supervisor's l aqJ are being considered for managerial and execu- meetings. An ongoing requrtement.
tive level. This item should be considered closed.
but consider specific action item t
complete.
XII-A (g) Rec: Remove ill-suited Supervisors or solve negative IV. OP/ Gen. A Complete " l attitudes.
- Resp: Being addressed on a continuing basis. Ihe new perfor- Specifically reviewed and 1 mance evaluation system should improve effectiveness addressed during 1983 in 16entifying personnel ill suited for their present Performance Reviews.
,4 assignments. We will continue to focus on identifying and resolving such problems. Major progress has been nede.
XII-A (h) Rec: Senior management should be serisitive to evidence IV. OP/ Gen. A Complete " l of poor supervision wnerever observed (system or
- contractor personnel).
Resp: See response to XII-D(b) and XII-A(g). Major pro- Specifically reviewed and gress has been hade. Continue emphasis but recommend addressed during 1983 complete by 4Q '83. M&C has incorporated in on- and Performance Reviews.
off-shift tours.
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e 2/27/84 ,
BETA FINDING / STATUS REC 0ttiEHQ. P A R A PH R A SED _ REC 0tt1ENDAIIDfLLSutt1ARLBES 20MS E__. CAI. DIVISI0fi _IDDL CoteENTS XII-A (1) Rec: Revtew provisions in contracts with major contractors IV. Admin./ A Complete " l 4 to see what means exist for GPUNC to monitor, report. Gen.(MM) and take action in cases of peor or insufficient supervision.
Resp: " General Conditions" are included as part of all contracts for furnishing labor and/or supervision.
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 contractor. Standardized Terms and Ccnditions were published in 5/83. coordinated with all Divisions.
and briefed to the GPU Nuclear Staff. Article 45 establishes the requirement for assignment of only quallfted, experienced and trustworthy contractor employees. We retain authority to have employees removed for non-performance.
XII-A (J) Rec:
Resp:
Trending of data to ascertain problem areas. III. Admin. B 4th 0 1984 l.
The Activity Indicator Display program has been Gen./0P implemented and we will continue to examine problem areas. Major effort still required. At TMI-l some data, such as budget, job tickets, chemistry analyses j and radiological parameters, currently being trended.
- j. Major emphasis on operating parameters will be started and in place within 6 months after restart. M&C has i trending program which will identify prohlam areas.
i 1 XII-A (k) Rec: Corrective action for cases of personal appearance. III. H. R. A Complete demeanor, etc. - considered outside the norm. . Gen./0P
} Resp: Day-to-day actions are being addressed. Policies i will be issued and stressed by management o.: expected behavior and demeanor. AP-ID29, Conduct of Operations, directly addresses. Managers briefed in standards of formality and professionalism. Policy memo issued on i
shoes and T-shirts at DC. M&C has Jddressed to man-agement/ supervisory level importance of attitude and
! business-like appearance.
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72 i
BETA FINDING / STATUS RECOMMENO PAHAPHRASED RECOMMENDATION &
SUMMARY
RESPONSE __ CAI. DIVISION C00E COMMENTS XII-A (1) Rec: Color-code hard hats at the site to distinguish IV. TMI-1/ D 3rd Q 1984 workers, foremen, officers, contractors. Gen./0.C. '
j Resp: Color coding of hard hats has been revised at Oyster Creek. THI-1 and 0.C. Division Directors 1
' will review this item and coordinate on desirable further revisions. At THI-1, exempt and non-exempt l wear different color hard hats. No current plans 4
to change system to include all categories of people listed. MLC supports; consideration must be given to contractor identification requirements.
I Eindina_1LI_B: There.is too much paper being generated and distributed throughout the GPUN organization.
XII-B (a) Rec: Each division director should help ensure distri- III. Admin. B 4th Q 1984 button is necessary. Gen.r0P
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Resp: A specific effort has been initiated at the officer level to identify and use " case studies." Examples of inappropriate distribution of documents. Corpo-rate Goal 8 also addresses this issue. Operations Analysis study of paperwork at TMI completed with meaningful reconnendations. The group helped THI-I reduce paper generation by more than 10%.At least a year is needed to implement the recommendations and seasure their effectiveness. The Operations Analysis Group is planning to conduct sistlar studies in other divisions. Will need tire to coordinate and implement their recommendations for the Company as a whole.
- i XII-B (b) Rec: Tighten signature authority; monitor for compliance. III. Admin. B 4th Q 1984 Resp: T4ts issue is being (or has been) reviewed in each Gen./0P
- Complete for TMI-I
} division to see whether more formal guidance is needed. Communication with other divisions is parallel or j
downward.
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- Addressed in M&C procedures and monitored in an ongoing l revier process.
l XII-8 (c) Rec: Correspondence control, action item tracking. III. Admin. A Complete i Resp: Action Item Tracking System implemented. All Gen./0P Licensing Managers trained in use of system.
Loading data base in progress.
XII-B (d) Rec: Control issuance of administrative procedures. III. Admin. A Complete l Resp; GPUN Policy Plans and Procedure System has been Gen./0P issued and has been implemented for control of Administrative procedures.
2/27/84 .
BETt FINDING / STATUS RECOMMEND. PARAPHRASED RECDMMENDATION & SUMM,ARY RESPONSE __ CAI. DIVISION CODE CDHMENTS XII-B (e) Rec: Limit required concurrences on documents / procedures. III. A4nin. B 4th Q 1984 Resp: 0/P action on this issue will be centinued. Further
, emphasis needed. D0cuments being considered as part Gen./0P
- Ongoing M&C practice to of Corporate Paperwork Reduction Study. Formal pro- minimize signatures on cedure system has been stream lined to implement documents.
limits on required concurrence.
Findina XII:C: There is an overall tendency within GPUN to force decision-making too high up in the organization.
XII-C Rec: All levels of management should review decision III. OP/ Gen. A Complete making in their groups to assure decisions are being made at the proper level commensurate with the need. Do not unnecessarily force decisions upward.
Resp: This issue will be covered in the meetings being held to meet Corporate Goal 5. Must receive con-Linued attention but consider such improvement has been achieved.
EinaintlII: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 employment.
-XII-D (a) Rec: Review for practical usefulness GPUNC procedure IV. H. R./ B 4th Q 1984 l addressing poor performers.
Resp: Progressive discipline procedure developed and in use. General
- Complete for THI-l H. R. will be working with each Division to review
- Incorpcrated in on- and all Performance Appraisals of 3.4 or below and off-shift tours by H&C.
specific plans for improvement will be developed where appropriate. Review to be completed 40 '83 follow-up during 1984. Program in place to review all people with rating in the 2 level or lower.
XII-D (b. Rec: Each Division Director assure proper action is IV. OP/ Gen. A Complete taken to correct performance where called for, or if unsatisfactory 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.
Findina XIJ_f: Since the creation of GPUN. too many small groups (cells or staffs) have been formed to carry out functions which should be handled within the normal functioning groups.
l XII-E Rec: Each director review manpower staffing to reduce II. 0/P B 4th Q 1984 unnecessary small staff build-ups.
Resp: Staffing of all Divisicns were reviewed as part i of '84 budget preparation. Overall 1-2% reduction planned for 1984. Operations Analyis.is studying.
D e
APPEf0IX A '
GPUNC CORPORATE Ato DIVISION GOALS AND OBJECTIVES REFERENCED IN RESPONSES
._ m . - . _ . . _
e b
1903 CORPORATE GOALS & OBICTIVES ,
Corporate (b iectives
- 5. Improve CPU Nuclear *s fractional capabilities within the authorized manning levels.
Corporate Goals
- 5. Provide an initial five year corporate plan ith defined milestones and objectives by June 1,1983, to use for budget planning for,1964 '_arjd beyond.
- 8. Have me&r.nisms in place by June 1,1983, for identifying and stimulating abolishment of unnecessary paperwork,
- . documentation, or procedural complexity.
- 9. Conduct at least Livo hour discussion so.slone wibi e minimum of 300 exempt W oyees l below the department head level on the functions, responsib'ilities, and interactions of the various elements of the organization by July 1,1982.
i .
- < 1983 DIVISION CDALS & OBICTIVES i
Oyster Creek Division
- 4. Improve working conditions aeid stat' ion appearance by: (a) reducing contaminated areas by 204: (b) reducing areas requiring respiratory protection by 25'E g (c) painting and refurbiching 100,000 sq . f t. o f ar ea.
5.7 Sutsstantially improve the matdrial condition of the.0yster Creek Plant by accomplishing a higi Fercentage of the maintmance work s&eduled during the 1983 outage.
- 7. Establish six operating shifts ea& with two Senior ficactor Operators (SRus).
I 10 . Complete uppaded training prog.ame for all semistry te&nicians; initiate formal training programs for all
! Equipment (berators, and formalize all on-the-job training.
- 21. - Completely revise the plant Chemistry procedurou (800 series) by
- (a) award contract; (b) begin rewrite; and (c) complete project. i
- 22. Improve Chemistry Te&nician job per f rmence proficiency by: (a) improve information flow; (b) complete Chemistry parameter trendings (c) increase supervisory overeirfit; and (d) upgrade documentation.
- 23. Expand Chemical 1.aboratory facilites by: (a) place temporary facilities in operation; (b) start construction of permanent facility; (c) complete construction of permanent facility; and (d) obtain all laboratory instrumentation.
> 24. Implement 24-hour Chemistry support of plant activities.
- 25. Upyade Chemistry Temnicians' training and complete training.
I 32. In conjunction with MEC Division, develop a GMS program for computerized equipment history, trending, and Praventive
- thintenance scheduling.
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Nuclear Power Operations FE8 ; 01984 1100 Circ:a 75 Parkway Suite 1500 Atlar:ta, Georgia 30339 Telephone 404 953-3600 February 2,1984 Mr. Philip R. Clark President GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New-Jersey 07054
Dear Mr. C;-,
L. th e/
As requested, INPO provided some indoctrination training for GPU Nuclear Evaluators, both in Atlanta and at the McGuire Nuclear Station.
Enclosed are two reports on that training that were submitted to me by the principal coordinators of the program. The reports describe sever'ai potential problems that you may wish to pursue. These reports are p.-wided to you independent of our evaluation program and are intended
, sosely for your assistance and we as desired.
I hope that the training that we provided met your requirements and that the enclosed information is useful. If you have any questions, please contact me or Zack.
Sincerely, .
b E. P. Wilkinson Fresident l adw
[ Enclosures cc: Mr. Z. T. Pate 4-
i .
Institut2 of I. Nuclear Pouer Operations Da* December 16, 1983 Memorandum To K. A. Strahm Prepared by:
From R. K. Seiberling Rowewed by:
sub,ect: TMI MONITOR TRAINING Approved by:
Please find attached the outline I used for the introductory and wrap-up sessions. The actual discussicns deviated from the outline in a number of areas, but conformed to the general ideas there. I've also attached the notes I received from other instructors for the course.
In my opinion, the job description for the TMI monitors does not permit or promote effective use of observational evaluation techniques. There may also be a significant problem with the method used for determining and tracking corrective actions resulting from monitor observations.
First, the monitors are obligated to correct any compliance problems on the spot, rather than noting the problems for later correction by the responsible personnel. In so doing, they are assuming responsibility for the correct performance of activities they monitor. I believe this will detract significantly from their potential effectiveness.
Second, they feel constrained to matters where lack of compli-ance with written requirements is the issue. Unless wri~tten requirements or standards are in effect for TMI, they de not feel they have the authority or responsibility to evaluate and comment.
Third, they apparently bear a significant burden for getting appropriate corrective action completed on time. The problems they note may not be receiving attention at high enough levels of line supervision. Also, from their comments, it appears that line supervisor's responses to their findings are often punitive and clearly in response to a monitor's findings. The result is poor credibility and an adversary relationship with production workers, and reduced monitoring effectiveness.
I recommend you discuss these points with your contacts at GPU Nuclear. s RKS:t],p f '
d !,
Attachments /
, /*
i
Institute of V~ .
Nuck:r FNxuer Operations l
Date: December 22, 198?. Memorandum To: K. A. Strahm Psepared by: T. L. Reeder Fmm W. S. Garrett /T. L. Reeder RewwW by W. S. Garrett sue,ect: A90'ced by:
PHASE II TRAINING FOR GPU NUCLEAR EVALUATORS As specified in your memo of December 7, 1983, Phase II training was conducted at McGuire Nuclear Station for four TMI personnel during the period of December 15-16, 1983.
Purpose The purpose of this training was to provide celected TMI shift nuclear evaluators with an introduction to INPO evaluation principles and techniques, and demonstrate their application in the field. The training at McGuire exposed the trainees to the following activities:
the recognition of deficiencies and indicators of plant performance during plant tours the planning and conducting observations of plant activities and how to recognize the quality of performance in observed activities the preparation of observation reports and the best methods of constructively conveying critical info,rmation to manage-ment demonstration of the vertical audit concept to identify root causes of observed symptoms Approach i A thorough tour of the plant was conducted including the ,
l turbine building, water treatment areas, control room and a diesel generator room. In addition, time was spent observing maintenance activities and the conduct of operations in the control room. To avoid lengthy delays caused by the Health Physics l badging process, the radiation controlled zone was not entered.
Throughout the in-plant period, examples of indicators of plant and personnel performance were highlighted and discussed. TMI personnel were asked to relate what they thought the problems were and items not seen were pointed out by the INPO personnel. ;
i l
-. - - . - - - = ..
j,# K. A. Strohm
- Doc 0mbar 22, 1983 j \, '
Page Two ..
l i
j The use of these observed indicators to develop well founded concit2aions and follow-up techniques including vertical audits i
were discussed and demonstrated. The need to obtain factual 1
information to support suspected poor performance was stressed.
i As a follow-up to the in-plant period, a two hour discussion
] session was held. The TMI personnel were asked to recall some
- of the evolutions that they had seen and to discuss how they i would best express their observations in writing. INPO personnel offered suggestions and stressed the need to present management i
with a factual account that clearly pointed out areas of 4 weakness.
4 4
Comments / Recommendations
' The TMI personnel were enthusiastic and genuinely interested in techniques which would improve their job performance. Their i
j reluctance to ask questions resulted in most of the training being undirectional. It is believed that their lack of experience and plant knowledge contributed to this situation. During our time with these people, we formed some subjective opinions based on answers to questions and general participacion in'the training process which are summarized below:
! The general level of knowledge of tha shift monitors with j
' respect to power plant hardware and integrated plant operations is low. Responses to questions indicated a need for an '
aggressive continuing training prograin to build on the basic training which the monitors have already received.
r Shif t evaluators were not aware of the many areas within the plant that could provide indicat' ors of plant and personnel
- performance. Shift evaluator supervisors will need to select specific activities to be monitored and train evaluators 4
on how to effectively determine that these activities are properly conducted.
Three shif t coverage with the number of personnel presently in the program will present a particular challenge to maintaining effective communication between shift evaluators <
and supervision. Effective logs as well as video taped and written training material may be necessary to ensure consistency and uniformity.
t The present program requires that each specific deficiency observed be forwarded to responsible levels of supervision and management for corrective action. This highlighting of each individual error could result in corrective actions being directed at specific individuals and could adversely impact the relationship ~between shift monitors and plant personnel. #
Consideration should be given to collecting monitor reports and evaluating them for generic implications and root causes.
The use of shift monitors as " white rats" should be reserved for situations that will affect personnel, equipment, or plant safety. '
E _ . _ _ _ . . __ . _ . . , _ _ _ _ . _ _ _ _ . . . _ _ _ . _ _ _ . _ _ _ _ . . . , _ _ . _ .
,. . Dsc:mber 22, 1983 Pcg3 Thrco
\
While it is commendable that GPU has created a program to provide oversight for their plant operation, it appears that t the implementation of the program is weak. The low knowledge i level of evaluator personnel, their recounted problems in '
interacting with plant personnel and program weaknesses indicate a need for significant management involvement and support to make this an ef fective and worthwhile program.
Because of the minimum amount of time available to train the TMI personnel, the lack of observation of their actual performance and the undirectional nature of the training period, INPO should be cautious of our involvement in TMI's efforts and avoid any implication of approval of the program.
7/J2.
WSG/TLR/rm ,
cc: P. M. Beard, Jr.
C. E. Moore J. P.,Flynn J. P. O'Hanlon a
s G
S l
' memorandum Nuclear Date: March 15, 1984
Subject:
INPO Coments on Shift Monitor Program NA/569 Location:
Cherry Hill Building From: R. L. Lon9 Vice President - Nuclear Assurance to: P. R. Clark President In December 1983, GPUN sent a group of QA Shift Monitoring Engineers and their supervisors to INPO to participate in a training program on INPO evaluation techniques. The program was presented at our request in response to a suggestion made by the NRC staff. We did not request nor did INPO provide any approval of the Monitoring Program. We believe that the INPO training made a useful contribution to the total training received by the Shift Monitors.
In a letter dated February 2, 1984, Mr. Wilkinson, President of INPO, provided copies of two reports that were submitted to him by the coordinators of the INP0 program. This memorandum documents our response to these reports.
The Nuclear Assurance Division is appreciative of the support provided by INP0 through their training sessions for our Quality Assurance Shift Monitoring Engineering Program. We have evaluated the comments provided to us by Mr. Wilkinson and noted that all items had been addressea or were being addressed by Management at approximately the same time that the training session at INPO was occurring. A few of the comments indicated that there was a lack of full understanding by INP0 representatives as to the responsibilities of the shift monitors and the scope of the monitoring program. We have addressed each comment individually, identifying the source of the paraphrased comment in parentheses.
COMMENT:
(Mr. Seiberling) The monitors are obligated to correct any compitance problems on the spot, rather than noting the problems for later correction by the responsible personnel. In so doing, they are assuming responsibility for the correct performance of activities I they monitor.
We believe that this represents a misunderstanding of the
. RESPONSE:
responsibilities of the Shift Monitors. The QA Shift Monitoring Engineers do not have the responsibility for correcting any problems discovered on shift. They are responsible for notification or ch6 appropriate shift supervisory personnel. These Line Supervisors can then correct the problem on-the-spot if it is a minor problem. If the Line Supervisor desires additional time for review and evaluation, the QA Shift Monitoring Engineer may issue a Quality Deficiency Report. If the problem is corrected on-the-spot by the Line Supervisor, it is still documented by the QA Shift Monitoring Engineer in his or her periodic report. For problems which are l corrected on-the-spot, no QDR is issued unless a trend of related I
deficiencies is detected by the later review. ~
j aoooops esi l
. - . _ _ _}
i
'A Page 2 P. R. Clark COMENT:
(Mr. Seiberling) The Shift Monitors feel constrained to matters where lack of compifance with written requirements is the issue. Unless written requirements or standards are in effect for THI, they do not feel that they have the authority or responsibility to evaluate and Co4 Bent.
l
RESPONSE
We believe that the instructions given to QA Shift Monitrring ;
Engineers to evaluate only items involving a lack of compIfante with written requirements or standards are appropriate because of their l level of experience. They are free to observe any items. When they are unable to readily evaluate compliance because there are no written requirements or standards, they have been instructed to refer such matters to a QA Lead Monitor. The QA Lead Monitors have been certified in various specific technical disciplines (i.e., reactor operations, radiological controls, electrical) based on a higher level of em erience in nuclear plant operations. They assist the QA Shift Monitoring Engineers in assessing areas where the Shift Monitor nas insufficient training or experience to determine compliance.
ComENT: Otessrs. Seiberling, Garrett, and Reeder) QA Shift Monitor Engineers apparently bear a significant burden for getting appropriate corrective action completed on time. The problems they note may not be receiving attention at high enough levels of line supervision.
Line supervisors' responses to find <ngs are often punitive and clearly in response to a monitor's findings. The result is poor credibility, an adversary relationship with production workers, and reduced monitoring effectiveness.
RESPONSE
The QA Shift Monitoring Engineers do not have responsibility for getting appropriate corrective action completed on time. This i
responsibility lies with shift supervisory personnel. The QA Shift
' Monitoring Engineer is only accountable frr tracking the status of corrective action and to report to 0A management problems with timely completion of corrective action. The punitive action taken by line supervisors in response to adverse findings is a potential problem in any QA, regulatory, or even INPO verification program. Operations management has taken steps to ensure that punitive measures are reserved for instances where the deficiency resulted from an individual's history of failure to comply with Company requirements or policy, or, where an individual's attitude or behavior indicates unsatisfactory efforts to meet personal and Company responsibilities toward requirements. Recognizing that adversary relationships may develop in any verification program, QA personnel have been instructed to ensure a balanced accounting of shift activities.
Satisfactory and exceptional performance should be identified, as well as negative findings.
l 4
b
s.
f Page 3 P. R. Clark COMENT: (Messrs. Garrett and Reeder) The general lack of knowladge of the Shift Monitors with respect to power plant hardware and integrated plant operations is low. Shift monitors are not aware of the many areas within the plant that could provide indicators of plant and
)
personnel performance. There is a need for an aggressive continuing training program to build on the basic training which the monitors have already received. Specific areas to be monitored will have to be selected by QA supervisors and the monitors will have to be instructed on how to effectively determine compliance.
RESPONSE: We recognized early in the program that, because of the maturity and experience levels of the personnel selected as QA Shift Monitoring Engineers, an aggressive continuing training program would be required. The program used is a combination of formal classroom training, on-the-job training, simulator observation training, self-study, and the use of written examinations as a measure of training effectiveness. The six shift rotation to allows a l continuing training and retraining program to provide an ongoing ,
upgrade of Shift Monitor knowledge.
QA Lead Monitors and Senior Management personnel are required to periodically perform backshift tours of the plant. Shift Monitors accompany them on these tours and are instructed in the many areas of the plant which can provide indications of plant and personnel performance.
QA Shift Monitoring Engineer supervision interacts with QA Lead Monitors to determine in which areas the Shift Monitors should concentrate their observations. The Shift Monitors are then specifically trained in these areas so that they may effectively verify performance.
COMMENT: (Messrs. Garrett and Reeder) Three shift coverages with the number of personnel presently in the program will present a particular cht.11enge to maintaining effective communication between Shift Monitors and their supervisors. Effective logs, as well as video taped and written training materials, may be necessary to ensure consistency and uniformity.
RESPONSE: A logging and reporting system for Shift Monitors was implemented when the program was first established. The monitoring super"ision provides direct communication and direction on a daily basis, as well as spending portions of shifts with each monitor to assist them in their training and evaluation efforts. The system has provided proper communications support on a 24-hour basis.
_. _ - -______ n
(
Page 4 P. R. Clark i
COMENT:
(Messrs. Garrett and Reeder) It appears that the implementation of
- the QA Shift Monitoring Engineer program is weak. The low knowledge level of the Shift Monitors, their recounted problems in interacting with plant personnel, and program weaknesses indicate a need for significant management involvement and support to make this an effective and worthwhile program.
RESPONSE
Each Shift Monitor holds a BS degree in Engineering or related sciences. They are not reactor operators nor experts in nuclear power plant activities; but vs believe it is misleading to say that they have a " low knowledge level". They have received specific training in many of the routine activities that they will encounter or, a day-to-day basis within the plant. As they gain more experfence on shift, they will become increasingly effective in assessing shift performance and compliance. In the interim, they are provided with 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> support by QA management and supervision and have an assortment of technically qualified and certified QA Lead Monitors to assist them in making evaluations of activities in which they cannot readily verify compliance because of their own experience level.
There is an ongoing significant management involvement with the program.
It was a desire on our part to upgrade the knowledge of our Shift Monitors that The prompted us to send a group to be trained in the INPO evaluation techniques.
responsibilities of our Shift Monitors are somewhat different from those of INPO Inspectors; however, we have found the experience to be beneficial. The impressions which we received from the INPO Instructors indicate that we may have a lack of understanding on the part of our Shift Monitors as to what their responsibilities are. Steps have been taken to assure that any misunderstandings are resolved.
t V
R. L.f #RG V.P. NucleaVAssurance RLL/0JC/ lab ,
cc: Dr. Z. T. Pate - Executive Vice President Institute of Nuclear Power Operations (INPO)
.1
- i
.t- .
GPU Nuclear Corporetion le kd Mtaclear :::e9'an" r Middletown, Pennsylvan!a 17057 0191 717 944 7621 i TELEX 84 2386 Writer's Direct Olal Number:
February 23, 1984 5211-84-2041 i c i Office of Nuclear Reactor Regulation Attr; H. Denton, Director
- U. S. Nuclear Regulatory Commission
- Washington, D.C. 20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (D1I-1)
Operating License No. DPR-50 Docket No. 50-289 Master Restart Schedule I The attached master restart schedule has been revised to include work on reactor coolanti pu=p 1B prior to precritical non-nuclear hot functional testing. Vibration proble=s necessitate inspection of the pump shaf t.
This work will not impact our scheduled capability of June 1, 1984 criticality. We reiterate our pending request for approval to perform the hot testing program.
In order to take best advantage of this "precr$tical" period, we have scheduled the completion of the other =ajor work items and surveillances, including centainment integrated leak rate testing. Modifications for which milestene delays are perceived will be rescheduled beyond restart.
Sene of th above modifications or plant activities uill preclude our ability to complete precritical non-nuclear hot functienal esting prior to June 1, 1984.
Sincerely.
. D. E ill Director, TMI-l HDH: RAS :vj f Attachment ec: J. F. Stolz H. Silver J. 7an Vliet R. Conte i
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GPU Nuclear Corcoration is a st.bsidiary of the General Public Utilities Corporation n
7-y;w NY140VED BY:
GW PAK2.ENt CGrGIATION Baseline fievision 2 Detsi 07/71/84 H. C. FOkill THI-1
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