ML20099E904
| ML20099E904 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 08/15/1983 |
| From: | Aamodt M, Aamodt N AAMODTS |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8411260133 | |
| Download: ML20099E904 (26) | |
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UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSIONERS: .
Chairman Nunzio Palladino
, Victor Gilinsky John Ahearne homas Roberts James Asselstine In the hatter of i
METROPOLITAN EDISON COMPANY Docket 50-289 SP (hree Mile Island Nuclear i Generating Station. Unit 1)
AAMODT COMMENTS CONCERNING NRC STAFF REVIEW OF GPU v. B&W COURT TRIAL TRANSCRIPT.
AND MOTIONS TO REOPEN RECORD ~ OF RESTART PROCrsmING s
TABLE OF CON'I'MTS I. INTRODUCTION 2812.
.............................. 2 II.
SUMMARY
................................... 3 III. DISCUSSION ................................ 5
- 1. New/significant Information ............ 5 he Hartman Matter ................ 5 1978 TMI In-house Management Audit .. 8 Court Chastisement of Robert Arnold for Misleading Testimony ........... 9 B&W - GPU Interface Concerning Plant Procedures ................. 10 Operator Capability for Handling Emergencies ..................... 13
- 2. New Understanding of TMI-2 Jccident ... 14
- 3. he Staff's Review .................... 16 IV. CONCLUSIONS ............................... 24 V. MOTI6NS .................................. 25 041126gg3g$$$9 ppR AD PDR O
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I. INTRODUCTION March 16, 1983, the Commission provided that interested parties to the TMI-1 Restart Proceeding might comment in writing to the Commission on the NRC Staff Review 'of the
' transcript record of the G4neral ._Public Utilities versus Bebcock and Wilcox lawsuit, here after GPU v. B&W.
We call attention of the Commission to the voluminous and highly technical nature of the record, constraints which 92welude a complete evaluation of the Staff's review of the record in the designated time frame of fifteen days. Nevertheless, we were able to demonstrate (1) that the record, contrary to the Staff's assertion, does contain new material relative to the Restart Proceeding which challenges the Idcensing Board's conclusions that GPU Nuclear i
management integrity is adequate to the task of safe operation of TMI-1. This material is so significant, in and of itself, that a fair consideration of it, by a reopening of the Restart Proceeding, would inevitably lead to a denial of the license of i GPU Nuclear to restart the TMI-1 plant;
. (2) that the record provides a . base,.not apparent to the :
, reviewers, for the possible resolution of identified inadequacies i
in operator training, a matter inappropriately resolved by the
- Idcensing Board's recommendations;
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(3) that the Staff Review with regard to the NRC's under- '
i standing of the TMI-2 accident failed to draw a most significant conclusion with regard to the failure of operators to timely 4
recognize that the open PORY was causatives and
! (4) that the Staff's review methodology was not only deficient, but deliberately deficient, in order to conceal new ,
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and significant information.
These are serious allegations which we do not make lightly.
We have not been able to exhmine the entire Court Trial transcript; in fact, we have not examined most of it. We have, however, devoted our time over the ten days,since the NRC Staff Review arrived,to the task of assessing the Staff's neview of those portions which we have read and studied thoroughly. Unlike the Staff reviewers, we gig intimately familiar with the Restart Proceeding record, having participated actively in nearly all phases since September 1979. Unlike the Staff reviewers, we have provided citations for most of our references. We are dismayed that our comments will be filtered throuEh the Office of General Council since "it does not have anyone at the Commission level .
thoroughly conversant with the accident record and' the investi- ;
I gationn." (Briefing, April 6, 1983, p. 82,85) . We would trust j that the Commissioners would take the time to personally read our ,
comments with the same regard as we did their invitation to participate in the Restart Froceeding and to comment on the l Staff's Review.
II.
SUMMARY
i The Staff review of GPU v. B&W was incomplete. It was ,
wholly biased, in the areas reviewed, toward GPU. interests. It failed to acknowledge significant information and significant new information, which if received as evidence by reopening the t
record of the Restart Proceeding, would challenge the Licensing
, Board's recommendation for restart of Unit 1.
The most significant information examined in GPU v. B&W that was not examined in the Restart Proceeding is the Hartman allegation that operators at U'n it 1 deliberately falsified leak
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_ rates to keep the plant open. GPU management direct:d'thic deception and violation of NRC procedures.
The quality of the TMI operators' testimony has been j
markedly,, conflicting and inconsistent throughout all proceedings concerned with management issues, including GPU v. B&W. In the i latter proceeding, operators changed their testimony concerning.
! events which happened nearly four years ago. Recent affidavits of engineers at TMI-2 allege that management used intimidation to control the flow of information from on-site personnel.
i Information concerning B&W's proprietary codes and 4
unexcelled expertise provided a base for the possible resolution l
of training deficiencies and an invalid licensing process, acknowledged by the Licensing Board in their decision on restart. ,
B&W, the vendor of the TMI plants, should have a responsible role in training and certification of operators and should be the
, source for material' used in constructing and grading the licensing I
exams.
Concerning the capabilities of the operators to handle
! emergencies. Robert Arnold, president of GPU Nuclear, contradicted i
j the Licensing Board's findings of adequacy. Arnold's testimony
! indicated the need for an offsite decision center where experts i view plant data and advise the operatoia.
Four motions are included (1) to have the record of the Restart Proceeding opened to receive information revealed in l
! GPU v. B&W in order to reevaluate' GPU Nuclear management capability 1
I and integrity; (2) for further review of GPU v. B&Wg (3) for provision of a 1980 GPU report on the Hartman matter, not served in the Reopened Hearing on cheating; and (4) for obtaining from the Department of Justice the record of a motion concerning
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allegr.tions of inappropriate influence on the operators' ' testimony by GPU attorneys.
III. DISCUSSION
- 1. New/significant Information .
. The Hartman Matter. The Hartman testimony is signi-ficant new information. It is significant to the investigations of the TMI-2 accident and the TMI-1 Restart Proceeding. It is also "new", not on the record of those proceedings, although the NRC has been aware of the Hartman allegations since May 1979.
At that time NRC deposed Hartman, referred the case to the United States Department of Justice, and discontinued their own investi-gation. The NRC has withheld the Hartman deposition from public view. The Hartman case has languished in the DOJ for nearly four years. All DOJ investigations are conducted in secret; even the status and case number cannot be disclosed to the public
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according to Federal Attorney Jim West who is in charge of the case. Hartman, however, would have been free to testify in other proceedings, if requested. The GPU v. B&W brought the Hartman information into public view for the first time.
The Staff is clearly at fault for recommending restart of TMI-1 before the Hartman matter has been resolved. The Staff once considered CLI-3-80, Item '10 pendant on the resolution of the DOJ investigation. (NUREG-0680, Supp. 1, p. 36,37). Then,
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four months later, without further explanation, the Staff described the matter as only of " historical interest". (NUREG-0680, Supp. 2,
- p. 10). Th e .G PU v. B&W transcript shatters the Staff's obvious attempt to coverup the Hartman. matter. ,
Hartman testified (GPU v. B&W, Tr. 7008-7995)I that reports 1
All orErnuStes which man and followatwere appear taken from GPU's cross-questioning Tr. 7025-7093.
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to the NRC concerning leak rates at TMI-2 were falsified for a B peric, of three months prior to the TMI-2 accident. Technical specifications for TMI-2 allowed a leak rate of one gallon per minute, however all tests which Hartman took during that period --
which numbered between 50 and 100 -- yielded leak rates in excess of technical specification. Hartman testified that "all readings '
above nuecifications were discarded into the westepaper basket",
"When it rot down to setting close to 72 ' hours (the pericd between each report), they wanted a good leak rate. so we got them one."
Hartman or other operators would add hydrogen or water to the system to obtain a false low reading. Hartman described his actions as " sneak fins) a little nas into the makeun tank. " Hartman stated ' '
that "everyone knew we were doing this", specifically naming his i shift supervisor and foreman, Dick Hoyt and Bernie Smith.
Although GPU's attorney attempted to disparage Hartman's testimony by implying that those who added hydrogen or water may not have known the significance of their actions, Hartman was firm in asserting that he was aware that the additions did not I i
reduce leakage but only made it appear that leak rates were lower '
than they actually were. GPU's attorney attempted to characterize Hartman's allegations concerning the addition of water as
" hearsay" since Hartme.n had claimed he had-onlf added hydrogen.
Hartman countered by describing his observation of Ray Booher, another operator, who " fluttered" water into the makeup tank, a procedure which had no other purpose than to conceal the loss of water from the reactor. Further, Hartman testified that he !
recognized that the reactor was being operated in violation of I i
technical specifications and that 1,t should have been shut down
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and the. valve (PORV) repaired.
Hartman was told by his shift foreman, "Me.ke sure you destroy these sheets (the tests in excess of allowable link rate); we don't want them lying around." .
The significance of the Hartman information to the TMI-1 restart proceeding is readily apparent. The decision to falsify leak rates was made by management. It is not unlikely that
- Robert Arnold, now president. of GPU Nuclear, was cognizant of the matter since the overriding reason for such a decision could only have been to keep the plant on line to avoid purchase of replacement electricity while TMI-1 was down for refueling.
I B&W's attorney made such an assertion in his presentation to the ;
court. (GPU v. B&W, Tr. 113,114). The Hartman testimony is clear evidence of the lack of integrity of GPU management, an f important issue of the Reopened Iyoceeding which was concerned ,
with management involvement or influence on the " cheating" behavior of ope,rators. The Idcensing Board came to an opposite conclusion i
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-- / onallegedly t5e basis of a lack of evidence. The Hartman information was
~ 'e^en 'th'is ihfarmation.alone . - 1 not in evidence; if it were, it couldvbaye been deduced that the '
character and day-to-day operations performance of TMI management l vas such as to have encouraged or even instructed the operators to '
cheat on tests in order to obtain their NRC licenses.
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] TMI-1 could not start without a sufficient complement of ;
licensed operators. Management had the identical motivation to
- facilitate the operators' cheating as they did to direct the operators' faloification of leak rates avoidance of the costs of replacement power. The operators had less motivation to cheat of their own volition; they were retained despite repeated failure l on exams while if they cheated and were caught, they could lose -
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th31r jobs. An occumpticn that man g:::nt cncsurag:d and -
approved of cheating would explain why Robert Arnold did not ask the operators who cheated extensively why they cheated or why answers to examination questions were solicited, unabash-edly, over the loud speaker system. (Tr. Nov. 12 ', 1981; Staff Ex. 27, Enclosure 10).
The Hartman information, including the court trial testimony and all depositions, needs to be incorporated into the record of the Restart Proceeding.2 1978 TMI In-house Phnerement Audi_t. The Staff reviewers were interested . in knowing the date of the first public disclosure of this audit; however when they learned that GPU had withheld this safety-related information until it was presented as B&W's exhibit in the court trial, the Staff failed to pursue what amounted to a violation of NRC regulation.
The NRC requires all safety-related information to be reported promptly; the audit identified important safetymrelated defici -
encies.
Some of the deficiencies in training are discussed in the transcript at p. 1689-1699 where it was noted that " Training in the Operations Department is at the present time a s'erious matter" with attendance hovering about 40%. The audit (B&W Ex. 843) stated that the quality of the operations personnel was in a continuous downhill trend due to lack of training.
This information is clearly new and exceedingly germane to 2
Our motion to have Hartman sub onsed was enied.
(Anmodt Findings genuary 18, 1952, para. 28 Tr.26,346-348).
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th ir j:ba. An occum'ptirn that manag :nt cnteuraged and -
approved of cheating would explain why Robert Arnold.did not ask the operators who cheated extensively why they cheated or why answers to examination questions were solicited,-unabash-edly, over the loud speaker system. (Tr. Nov. 12 ', 1981; staff Ex. 27, Enclosure 10).
2he Hartman information, including the court trial testimony and all depositions, needs to be incorporated into the record of the Restart Proceeding.2.
1978 TMI In-house Manerement Judit. he Staff reviewers were interested . in knowing the date of the first public disclosure of this audit; however when they learned that GPU had withheld this safety-related information until it was presented as B&W's exhibit in the court tr.ial, the Staff failed to pursue what amounted to a violation of NRC regulation.
The NRC requires all safety-related information to be reported h promptly; the audit identified important safety-related defici ..
encies.
Some of the deficiencies in training are discussed in the transcript at p. 1689-1699 where it was noted that " Training in the Operations I)epartment is at the present time a s'erious matter" with attendance hovering about 40%. She audit (B&W Ex. 843) stated that the quality of the operations personnel was in a continuous
( downhill trend due to lack of training.
This information is clearly new and exceedingly germane to 2
Our motion to have Hartman sub (Aamodt Findings January 18, 19Nonsedwasfenied. , para. 28 Tr.26,346-348).
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-9 to the investigations of the accident,which found inadeq'uate training contributory to the accident,and to the Restart Proceeding as it reiates to wilfull negligence on the part of management who failed to remedy attendance in the training program and withheld this information from the Restart Proceeding. An operator who testified in the Restart Proceeding (on cheating) suggested a simpie remedy that would separate off-time shift from the training shift in order to discourage operators from extending their vacations through the training week. Neither this remedy or the obvious remedy -- manadatory attendance in training were takg/ "Abugs 3 P64 NUEe*yMitpu1at.d an exhibit which he believed represented the numbers of hours the in 1980 - 1981 operators spent in training / we believed, that the presentation was misrepresented. (March 1, 1982, Aamodt Findings, para.
363-365). ,
- Court Chastisement of Robert Arnold for Misleading Testimony. In GPU v. E4M, the Court found the testimony of Robert Arnold, pres'ident of GPU Nuclear, less than forthright.
l The judge, comparing Arnold's responses to B&W attorney's cross-questioning ~to Arnold's prior testimony concerning the training program at TMI, snapped, "The Court finds that (prior testimony) mis 1eading." (Tr. 1741) . Arnold was ocknowledging in his responses to B&W that a 1978 in-house audit had revealed low attendance (44%) in the training program and prob 1 ems in the training department described as "a serious matter". Arnold acknowledged that he was not aware of any address of these problems. (Tr. 1690-1699) . The court scolded Arnold for having described the training situation as "all hunky-dory".
i (Tr. 1741).
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Judge Milhollin (in the Reopened H aring ca ch: sting) also noted Arnold's lack of forthrightness, disbel'ieving Arnold's i statement that he had not saked the operators why they cheated L
- because that information was not critical to the prevention I i Judge Milhollin concluded that
[ of cheating in the future.
Arnold had not asked because he already knew why the operators cheated. Judge Milhollin's conclusion, not adopted by the i- Licensing board, is given greater weight by GPU v. MW.
i MW objected to the evasive manner in which Arnold answered [
! their questions, and the Court sustained noting, "We don't need '
i (Tr. 1555) . During the Restart Proceeding, this l a speech here."
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j kind of evasive response through unnecessary elaboration was used throughout the Eastert Proceeding by glib management officials.
- The Licensing Board did not object and allowed the hearing to be 1
unnecessarily prolonged by this legal manuevering of GPU.
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l MW - GPU Interface Concernina Plant Procedures.
l l Information presented in the court trial by GPU's attorney could be expected to lead to a more adequate resolution of deficiencies l 1 t
! in training of TMI-1 operators than provided by the Licensing l
- l l Board from the record of the Restart Proceeding.
f GPU and MW sgreed (tr. 4-186) I that MW's technical resourdes, that are needed to achieve adequate training of the f
operators, are superior to GPU's. MW bolds in their computers l l the proprietary codes which describe ths TMI reactors' operating characteristics (to which neither GPU nor NRC has access), NW l 1
3 Introductory presentations of GPU and MW.
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technical personnel have thermodynamica expertise unequaied by GPU personnel, and B&W has access and capability to analyze transients at B&W plants throughout the industry.
B&W attempts to provide pertinent un~w information to the
. utilities. However, in the case of the Davis-Besse incident, a precursor of the TMI-2 accident, the information failed to reach the training department or the operators although it was presented to TMI management through a quarterly industry meeting.
B&W made the point that TMI had three similar incidents of their own prior to the accident, yet they had not even recognized the significance of these incidents or the relationship to the Devis-Besse incident. (Tr. 185-186).
Arnold tactified that GPU had "very limited capability in the absence of codes to do the kinds of transient analysis that only B&W was capable of providing." (Tr. 1561).
B&W asserted that 90% of the GPU training program for operators at TMI was completely ineffective. " Met Ed didn't teach the operators the fundamentals of an overcooling transient
, based on those very (three) incidents at their own plant."
(Tr. 155). B&W described the limited technical capabilities of the supervisor of training who did not have an NRC license and who failed an NRC licensing exam after studying under the i
instructors he supervised. The supervisor did not understand '
bestup/cooldown curves, applicable to every operating procedure .
(Tr. 129-130) . Only 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> annually were reserved *for each operator for on-hands experience at the B&W simulator -- just 10% of the training schedule -- because GPU "did not want to pay very much for the . simulator training. " (Tr. 125).
B&W could just as well have been describing the training t
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situation at TMI as it was revealed in the Restart Procee' ding.
The instructors have remained. The operators attempt to understand reactor theory through consensus of their opinions although " bootstrapping" is hardly a valid educational method when operators and instructors have little or no formal education beyond high school. (Tr. 25,696; 26,462; 26566).
The amount of simulator training for licensed operators is presently the same number, of hours as were scheduled before the accident.' One-half of the senior operators failed the second licensing exam given in 1981, and there was still considerable doubt about the operators' understanding of when they should terminate the HPI pumps.
The Idcensing Board's recommendations (Decision, August 27, 1981, para. 2421) for improving training -- application of
- quality assurance / control techniques -- fails to come to grips
, h with the root of the problem: DPU's lack of resources., B&W, on the other hand, has the resources to appropriately train the operators.
GPU v. B&W made that eminently clecr: GPU ascribed the ultimate responsibility for technical understanding of plant performance to B&W, In order to know all, of the information that is needed to operate the plant safely, the proprietary information, uniquely held by B&W,::must be incorporated into the training and testing program. In light of the proprietary nature of the information, B&W must participate in the operator training and certification programs. The most appropriate independent agency to certify
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the performance of the operators is the company that manufactured the equipment, whose reputation is at risk.
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The NRC Examiners who construct, administer and grade the licensing exams have even fewer resources than GPU. The examiners went to the operators and instructors at TMI for the information from which they constructed and graded their
- tests. Judge Milho111n questioned .the validity of these teste of the TMI-1 operators (Special Master's Report, para. 235.340),
. however the Licensing Board set aside these concerns and believed that the licensing process was adequate until NRC had time to improve their tests. (Decision, July 27, 1982, para. 2362-237?).
The obvious solution becomes. apparent from the GPU v. B&W transcript. NRC should obtain the cubject matter for' the TMI licensing exams from B&W. B&W is the repository of all pertinent operating information specific to the TMI plants. Only B&W knows what questions te,ask and what are the right answers to
- assure safe operation of the ,TMI-1. plant. .
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Onerator Canability for kn.111nn herrencies. The GPU v. B&W transcript calls into question the Board's decision that the operators were able to handle emergencies with no undue risk to the public. (tr. 33,65,79,80). GPU's attorney alleged that only an . experienced thermal hydrologist like Dr. Dunn of B&W could have figured out what to do during the TMI-2 accident.
Contrary to "the Licensing Board's findings in the Bestart ,
Proceeding (Decision, August 17,1981, para. 265,266) GPU asserted that environmental stressors in the control room --
"many indications, some of them indirect, some malfunctioning, hundreds of lights on and numerous other signals" -- reduced the operators' capabilities to the extent that problem-solving was impossible.
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The only appropriate resolution of the uncertainty of appropriate operator response during an emergency. is provision of off-site decision centers manned by nuclear. experts where all pertinent date is displayed. NRC has proposed dec.ision centers
,for the future, however GPU's assertions in the court trial are evidence that TMI-1 should not be allowed to pestart without the backup of a deciclon center. Since B&W has proprietary plant
, information and unique technical expertise critical to under-standing performance of the TMI-1 plant, B&W experts should be 4
utilized for decision making. In fact, the jeded operating history of B&W plants (Tr. 22, 23) should have spurred such a j provision by B&W management.
There can be no viable argument against providing remote 4 readout capability. All significant readout instruments in the i
control room already have the capability to be tapped for data
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transmission purposes. Transmission is simple and relatively inexpensive. >
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- 2. New Understandina of TMI-2 Accident The Hartman testimony may have provided an answer to a I critical question remaining from the investigations of the TMI-2 j accident. There has been no satisfactory explanation of why the operators failed to realize that water was coming out of the PORY
! et a rate so high as to foil all attempts to stablize the reactor.
Indeed, the PORY had been stuck open over two hours, uncovering 1
) a significant portion of the core, before Brian Mehler closed the block valve. It should be noted that Mehler concluded that the 1
PORY was "lesking". (NUREG/CR-1250, p. 19). It should also be noted that Frederick offered a somewhat different/ interpretation
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03ecause noone couid think of why - (the block valve was closed):
i of anything else ' to do. " (Id.). These apparently contradictory statements become conciliatory when viewed in the light of l Hartman's testimony. For three months the operators had i
- operated the plant routinely with the knowledge they had falsified data to hide the fact (from the NRC) that the valve was leaking.
l They had observed temperatures at the FORY during " normal" i operation similar to thoscobserved during the accident. They i were conditioned to innore the potentially devasting role the I stuck-open FORY was to play on March 28, 1979. Here was "mindset", established by management.
Much as been made about the misleading indicator at TMI-2 l which signaled that .the FORY was closed. However, the operators i .
- were wary of signal light problems and were accustomed to checking ~
I I, through other indicators. One such indication was elevated relief i
i$ valve discharge temperatures. Sewe attributed these to the fact ,
- that "the FORY had been leaking anyway." (Id..p. 17) that he had "seen higher readings than these under reasonably normal
! circumstances." (Id.) The operators' disregard of another '
l indicator, noticed by three operators at 4:30 a.m., water pouring l
h- into the sump (Tr. 140), most probably resulted from an attitude '
I of disconcern about a leaking PORY which they no longer took -
seriously.
At 4 :14 a.m., with the accident barely starting, the l
i operators noted an increase in the reactor coolant drain tank l I
pressure and at about 4 820 a.m. Zewe noted failure of the rupture disc. . At 4 :38 a.m. Zewe and Frederich were aware that l overflow from the drain tank was collecting on the containment i building floor.. Yet noone closed the block valve. One could l
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conclude that had the.operetors not been' conditioned to live l with the leaking PORY, they would have closed the block valve promptly,and there would have~been no accident.
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j 3. The Steff's Review -
! The material we found in the GPU v. B&W transcript, in the 4
j few days that we had to devote to the task of reading it, ,
- demonstrate that the Staff f.s Review, to which four investigators devoted ten weeks, can only be a blatant attempt to cover and ;
distort.
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j he Staff has a vested interest to protect -- their j positions of complete support of GPU management and qu'ick restart ;
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i of the TMI-1 reactor -- and their review represents no more than f I
that. The Staff was too buried in the conclusions of prior i j ,
studies to acknowledge that anything revealed in the GPU v. B&W ;
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4 transcript was significant. 5 hey included no citations to the transcript; all references were to prior investigations. l i
The quality of the Staff's review cannot be dismissed !
i j l as being too blind to see the' forest because of the trees'. I That would be nonsense. The reviewers were intimately familiar ;
} with the details of the TMI-2 accident investigations, in fact i .
j they were chosen because of this knowledge. (Briefing, April 6, !
1 !
l 1983). Since the issues of the Restart Proceeding were only those l l ' with nexus to the TMI-2 accident, the matters of the TMI-2 accident i
! l j and the issues of the Restart Hearing are inextricately entwined.
Commissioner Ahearne so noted at the briefing. (Id. , p. 10) .
The director of the review, Victor Stallo, as Director of Inspection l
and Ehforcement, was involved personally in both hearings of the l
1 i Restart Proceeding.
Stello's pless of innocence, when the Commissioners criticised 1
th3 challcwr.cco of tha revicw, io too fcallier to thoco ,who have participated in the restart hearings. Two notable past protestations were that GPU management could " knowingly" .
misinform the Commonweslth of Pennsylvania about the severity of the TMI-2 accident without wilfully" misinforming them.
and thet Stello did not know that NRC had the right to exclude management from investigative interviews with operators.
(Tr. 25,428-30). ,
Commissioner Gilinsky questioned the possible bias of the reviewers toward GPU. Concerning the dispute with B&W about the initiation of the HPI pumps at 5:41 on the morning of the accident, Gilinsky stated, "I am surprised that your conclusion is as firu as it is in view of the uncertainties." (Briefing, p. 65).
Stello admitted that he "did not independently
- do a calculation to confirm that that (GPU.'s: point of view) was the case..."
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because he did not consider the dispute significant enough.
(Id., p. 38,46). Stello's excuse, hardly appropriate for a seasoned investigator, was that the issue was not important
- enough to warrant the time required to make the calculations.
(Id., p. 66, 67), ,
in view of the Staff's evaluation of the significance of the HPI issue and the purpose of the review of the GPU v. B&W transcript -- to apprise the Commission of significant information that could affect their decision on restart - , the Stpff'.s emphasis of the HPI dispute in their review and briefing can hardly be justified. The HPI issue is, however, important to GPU in,their lawsuit against the United States, which is presently i in appeal. The reviewers have, without thorough independent
ennlycio and fer n3 purpose important to the review, ad' opted GPU's position!
Stello considered his review of the HPI issue to be thorough (Id., 38,46), however the Staff failed to examine 3&W exhibits that were prepared for the trial but not presented because of the out-of-court settlement. (Staff Review, Appendix A).
Stello's excuse was that, because of voluminousness of the exhibits that were prepared but not presented, he was awaiting the Commission's order to review them. (Id. , 27) . This excuse is ,
particularly shallow since ensuing Commission discussion concerning the institu't; ion. of the Staff review clearly indicated that the j Commission had intended a full review. (Id., p. 82). The NRC Staff presented a parallel excuse in the Reopened Hearing concern-
! ing I&E's investigation of cheating at TMI-1 which the Commission i
j, had also ordered to be a " full investigation". (Tr. 24,279-81; j} 25,428; 25425).
- 1 5here are 1767 exhibits and 81 depositions which were j prepared for the trial and less than a third of this number j were entered into the transcript of the trial court record.
}
i Robert Arnold has sorted the remaining documentsinto two piles
! and made one, containing 580 documents "which may contain some-I ,
( thing of interest", available to NRC. (Staff Estiew, Appendix A).
j Arnold's stated concern, that the transcript and related exhibits
$ did not contain all germane information...is thinly guised, i
therefore his judgment concerning relevancy of the documents ,
cannot be trusted.
t j 2he NRC reviewers did not examine the remaining documents, i !
not entered'in the court trial. They all need to be reviewed l
t sad ande available to all perties. B&W did not c.omplete its l
presentation in the trial due to settlement with GPU so that 1
the unentered B&W exhibits are likely to contain information of significance.
The Staff failed to note that GPU's investiga, tion in
,1980 of the Hartman matter should have been provided to the parties of the Reopened Hearing on cheating. Judge Milho111n ruled that GPU must provide all records subsequent to the TMI-2 accident concerning cheating of any kind. The report should be .provided now to all parties. GPU's violation of a court order to provide all documents is also a matter of interest to the Commission and the parties.
The Staff Review is totally in error in stating that the Hertaan matter "was also the uubject of a Licensing Board decision." (Id., p. 38). The Licensing Board clearly stated that they did not consider the Hartman matter (Decision, August 27, 1981, para. 504, 505).
The entire treatment of the Hartman matter including the
~
failure of the Staff to fully brief the Commission concerning the exposure of the Hartman information in the GPU v. B&W transcript is. completely baffling. We cannot understand why the matter was not fully air'ed in the Restart Froceeding. The matter was highly relevant. According to Jim West, the federal attorney in charge of the Harrisburg office, the Justice Department would not have discouraged or prevented Hartman from appearing in any other trial.
The standards of the Justice Department are not those of an administrative hearing so that failure of the DOJ to indict
, cannot be assumed to resolve the issue of relevancy of the Hartman matter to the Restart Proceeding. DOJ must find evidence
+ - - . _ , - - , , - - , - - - - - , - - . . - . , , _,
of criminality and which is beyond all reasonable doubt to indict. The Commission's decision on restart (and the decisions of the Idcensing Board and Judge Milhollin) are concerned with a broeder range of issues, many related to the Hartman matter, and are determined on the weight of the evidence.
We would expect that the Hartman allegations will result in indictments of GPU management unless the manuevering of GPU's attorneys can prevent corroborative testimony. Robert Arnold ' forgot', reporting on the status of the DOJ investigation (Briefing, p. 24-26), to tell the Commission that the investiga-tion was suspended to consider allegations of improper interference on the operators' testimony by GPU's attorneys.
The Staff reviewers failed to see the possibility of improper GPU influence in the operators' changes in testimony concerning
.' the initiation of the HPI pumps. (Staff Review, p. 5,6). The operatorqwere appearing as GPU's witnesses and the changes in the operators' testimony were important to the success of GPU's case.
Recently breaking information, not part of the court trial, but referenced in the Staff Review (p. 21) provides evidence that GPU management has attempted to manipulate employees through threats and innuendoes. Three personnel involved in the clean-up operations at TMI-2 alleged that management, reaching to Robert Arnold, threatened them for reporting violations to the NRC.
Richard D. Phrks, a Bechtel engineer, in an affidavit prepared last month, stated that Site Operations Director Isrry King and Director of Plant Engineering Edward Gischel were threatened by John Barton, Deputy Unit 2 Director. King's and 01schk1's jobs were threatened in a telephone call from Barton, alleEedly because e
4
21- .
they would not .' sign-off' (approve) the Safety Ikaluation' Report for the polar crane. Phrks claimed that the SER had been sub-mitted to the NRC without reviews required by Technical Speci-fications. Gischel had written a memo describing their concerns about the refurbishing of the polar crane which Barton wanted to keep from NRC view. Phrks also alleged that he was warned by Rj ck Gallagher, Assistant Director of Site Engineering,that Edward Kitler, Superintendent of Startup and -Test, had requested upper-management to transfer Phrks off-site. Jim Theising, Manager of Recovery Programs, threatened Phrks,when he refused i
to approve an order which circumvented the entire QA/QC review, with the news that a meno had been issued to relieve Phrks of his job. Subsequently, Iarry King was suspended by Barton, presumably at the behest of Robert Arnold, on the pretext that King had conflict of interest. Parks, and King's secretary, were
- i prevented from retrieving King's personal belongings by a guard and an unidentified individual in street clothes. Giachel, who had suffered a stroke some time beforehand, was ordered to have I a psychiatric exam through the company medical offices. Aing's secretary Joyce Wenger was accused of stealing a memo, suspended and subsequently visited by GPU personnel accompanied by an '
unknown, unidentified person to discuss " humiliating personal subjects". Parks was warned by 'B. P. Kanga, Director of Unit 2, "not to go public with my concerns. He (Kanga) said that once before things had gotten much worse for nn employee who had tried
! that and was ' humiliated ' . " King and Gischel have signed aff14.*.
davita confirming Phrks' allegations.
The altered testimony of the operators in GPU v. B&W and the threats reported by Phrks, King and Gischel support our 9
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findings that the operators who testified in the Reopened Proceeding were under pressure to conceal the truth. (Aamodt, January 18, 1982, para. 16, 56). There was evidence of in-appropriate contact between GPU ettorneys and two. witnesses.
.The evidence is that the attorneys did admit, when faced with the evidence, to preparing two operators against Judge Milhollin's
'I express order. (Id. ; Tr. 26,797). Judge Milhollin believed that the violation of the Sequestration Order had been a misunderstanding and in good faith, despite the fact that he was troubled by the poor quality and character of some of the operators' testimony (Tr. 26,797), including the two operators known to have been prepared by GPU. (Special Master's Report, para. 108-111).
Although Judge Milho111n considered GPU's~ c'ontacts with the-operators to have been a " good faith" misunderstanding,4the Commonwealth noted that GPU's interpretation of the scope of j sequestration differed from the Commonwealths!, other, parties' and Judge Milhollin's. (Tr. 26,852).
4 In discussing the conflicts in the operators' testimony in GPU v. B&W, the Staff reviewers adopted an explanation provided several years ago by the writers of NUREG-0760. . (Staff Review,
- p. 5.6). The Staff's conclusion appears naieve, particularly in view of the Hartman allegations and the affadavits of Phrks, King and Gischel.
Further evidence that the operators perjured themselves on the instructions of management is provided by the Phrks affidavit.
Ibrks concurs with the B&W position that there is a ' mystery man' who turned off the HPI pumps at 5:41. This not only means that 4
The initial discussion of this breach in sequestration was discussed off therrecord at the instigation of GPU's attorney, Blake (Tr. 26,712; 26,797 ) . !
I
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G
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l they would have had to be turned on, but that information concerning the identity of this person was withheld and for a purpose. Phrks stated that everyone at the plant knew that this person uns George Kunder. Parks indicated that management attempted to persuade him from revealing this information about Kunder.
The matter of GPU's alleged interference with the operators' testimonies should be of interest to the Commission:end the parties of the Restart Iroceeding. A showing has been provided by the operators' testimony in the court trial, where testimony was changed concerning an event that happened nearly four years before -- initiation of the HPI pumps. Evidence of the influence of management on the operators to give false testimony was provided by Hartman who alleged that management directed the <
T operators to falsify (leak rates). Existing on the Restart h record is evidence of the violation of the Sequestration Order by GPU's attorneys. Hidden within the Justice Department, in an action which halted the DOJ investigation of the Bartman matter, is en allegation of improper interference of GPU-attorneys.
The conflicting testimony of the operators noted in NUREG-0760 and by the parties to che Reopsned Hearing was evidently a problem in the DOJ investigation. It was noted in GPU v. B&W and anti-cipated by Chairman Palladino.at .the briefingc.(' What did 'they say now?") . Considered together, these examples provide sufficient evidence to show that there is a problem. An alleged cause, the interference of GPU, appears to be surfacing. Further investi-gation is needed since the matter is highly relevant to the Commission's decision concerning restart. There is no issue l ,
more important than whether GPU and the operators can be relied
~
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~ '
upon to tell the truth.
IY. COHCLUSIONS The implications of falsification of leak rate data at.TMI-2 reach beyond its impact on the accident. In the sontext of the Restart Froceeding, the nexus is the issue )
of management integrity, litigated in the Reopened Hearing.
This blatant example of deceit with its attendant trial of damage to the pltnt, shareholders' earnings, customers' electric rates, the nuclear industry's image and insurance program, and most importantly, the community at risk, cries for renewed litigation. The fact that GPU withheld information on their investigation of falsification of leak rate data in response to our interrogatory calling for all records of information dealing with any and all forms of cheating provides in itself y adequate basis to reopen the Restart Iteceeding.
) This new information can be expected to resolve an un-e answered question of the Reopened Hearing: Why was it se
~
difficult to extract the truth from the operators concerning
' cooperation' or cheating on examinations? Were the operators
' stonewalling' on express instructions from their employer, GPU?
Were the operators, who were our witnesses and not GPU's, coached by GPU's attorneys? Was the integrity of the hearing compromised after all? It is incumbent on the Commission to see that this issue is litigated.
The fact that the NRC Staff was willing to conclude the Restart Proceeding and make a recommendation for restart of TMI-1 before the Justice Department investigation of Hartman was resolved or to make this information record evidence in the Restart i
_ _ - . _ _ . - - _ - . - , . . , , , , . , , , , , -.,....-.y.
- r
-Proceeding, makes -the Staff culpable as well. The Staff',
in their briefing of the Commissioners and in their review, made it appear that the Hartman information is still buried in the secrecy of the DOJ. investigation and in 'a B&W deposition
,not yet.provided. This is contrary to facts. The Hartman
^
matter was aired in GPU v. B&W and is available in the transcript.
, T MOTIONS
- 1. Our review of GPU v. B&W transcript provides sufficient showing in fact to support the following: motion:
The Aamodt Phaily motions the Commission to order the record of the TMI-1 Restart Proceeding to be reopened to receive the new information contained in the GPU v.
,EW action for the express purpose of reevaluating -
OPU Nuclear management capability and integrity.
- 2. Although it was not possible to make a complete analysis of the trial (GPU v. B&W) record, as discussed, we have found
~.
new evidence that is significant to <.he TMI-1 Restart Proceeding.
, This evidence calls into question the Licensing Board'r findings on GPU Nuclear management tategrity and ec=petency as well as
^
the training program and NRC licensing of TMI-1 operators. We i
have presented the Hartman evidence as well as some other evidence as a showing of the importance of this evidence. However, we need considerably more time and more ready access to pertinent ,
documents to proceed further. Therefore, The Aamodt Phmily motions the Commission to provide an additional sixty days for comment and to instruct the Staff to serve the transcript and the exhibits of the trial (both those entered into evidence and those not entered but prepared) directly on us. !
- 3. The GPU investigation of the Hartman matter, discussed above, should have been served on the parties to the Reopened Hearing in response to Judge Milhollin's prehearing ruling a
,n,-.,, , , , . . . - .,.,m.,n,.,.,,,... ,,.___.._m,, .--.,.,_,,,,,_-,n ,y,,, ,
Y (October 2, 1981). 'lhis material could reasonably be expected to have materially influenced findings, particularly with regard to management integrity. Therefore ,
The Aamodt Family motions the Commission to direct GPU to serve the report of inquiry into the Hartman matter on the parties to the TMI-1 Restart Proceeding.
- 4. The conflicts in the testimony of the operators in GPU v, B&W. with their prior testimony must be viewed in light of recent information supplied by brks, Xing and Giechel as inappropriate influence by GPU and their attorneys. This matter is highly relevant to the Restart Proceeding and to the Commission's decision. 'Iherefore, The Aamodt Family motions that the Commission serve the affidavits of Parks, King and Gischel on all parties to the Restart Proceeding and obtain and provide the transcript and all documents related to the allegations in the Justice Department investigation of Hartman that GPU attorneys exerted improper influence on the testimony f in that investigation. -
h Respectfully submitted,
, (.A M L L M. 0. 18D 1 th q Norman O. Aamodt A% L~ bdda c-K) l Marj e M. Aamodt
~
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UNITED STATES
! o NUCLEAR REGULATORY COMMISSION
{ , WASHINGTON. D. C. 20555 i ,/ FYI cc: T. Murley November 18, 1983 n R. Starostecki JMG - 11/28/83 Ivan W. Smith Sheldon J. Wolfe Administrative Law Judge Administrative Judge Chairman Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC'20555 Washington, DC 20555 Gustave A. Linenberger, Jr.
Administrative Judge Atomic Safety & Licensing Board :
U.S. Nuclear Regulatory Comission Washington, DC 20555
... In the Matter of METROPOLITAN EDISON COMPANY, ET AL.
(Three Mile Island Nuclear Station, Unit No. 1)
Docket No. 50-289 (Restart Remand on Management)
Dear Administrative Judges:
Relevant to the matter of reactor coolant system leak rate testing at Babcock and Wilcox nuclear power reactors, we forward the enclosed report on leak rate testing at the Rancho Seco and Davis Besse facilities for your information. By means of this letter, copies of the report are also being provided to the Comission, the Appeal Board and the parties to the TMI-1 restart proceeding.
Sincerely, N1ack R. Goldberg Counsel for NRC St ,
cc w/ enclosure:
Chairman Palladino
! Comissioner Gilinsky Comissioner Roberts Comissioner Asselstine Comissioner Bernthal THI-1 Appeal Board
- Service List Y hh -
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aq- '
FYI:
UNITED STATES OF AMERICA T. M eley NUCLEAR REGULATORY COMMISSION f ftarostecki T. !!artin B_EFORETHEATOMICSAFETYANDLICENSINGAPP 7/29/83 In the Matter of METROPOLITAN EDISON COMPANY, ET AL. _ .
Docket No. 50-289 (Three Mile Island Nuclear Station,)
Unit No. 1)
)
NRC STAFF'S MEMORANDUM ON THE STATUS OF ITS TMI-1 RESTART REVIEW Jack R. Goldberg Counsel for NRC Staff July 21, 1983 9
_ i
UNITE 6 STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289 .
) (Restart) .
(Three Mile Island Nuclear Station )
Unit No. 1) )
NRC STAFF'S MEMORANDUM ON THE STATUS OF ITS TMI-1 RESTART REVIEW Jack R. Goldberg
- Counsel for NRC Staff l
July 21, 1983 l .
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l I
. - - - - - - - ___. .. . . _ __ .._ _.. ,._,__,. . _ , _ _ . _ _ . . .___.i
UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION BEFORETHEhTOMICSAFETYANDLICENSINGAPPEALBOARD In the Matter of METROPOLITAN EDISON COMPANY, ET AL.
Docket No. 50-289 (Restart)
(Three Mile Island Nuclear Station, Unit No. 1)
NRC STAFF'S MEMORANDUM ON THE ,
STATUS OF ITS TMI-1 RESTART REVIEW I. INTRODUCTION
~
By Orders dated June 16, 1983 and July 6, 1983, the Appeal Board
- directed the Staff to file with it and the parties no later than July 21, 1983, a memorandum outlir.ing the progress of the Staff's " revalidation."
In accordance with those Orders, the Staff hereby outlines the status of its review pf the five open issues identified in the Staff's May 19, 1983 ,
memorandum to the Comission (" Revalidation Memorandum").
l II. STATUS OF STAFF'S REVIEW l On June 28, 1983, the Comission provided the. Staff with guidance for completing the TMI-1 restart review. By Memorandum from William J.
Dircks, Executive Director for Operations, to the Comissio6 dated July 15, 1983 (" Implementation Memorandum," sent to the Appeal Board and parties on that date), the Staff described its proposals to complete its .
review of the open issues in accordance with the Commission's June 28th l
I l
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. _ . _ _ _ _ _ _ . _ _ _ _ _ . _.1 guidance. The Staff informed the Comission that " completion of the entire review, including an ultim' ate position on management integrity, i realistically appears to the staff to be.many months away." Implementa-tionMemorandumat5.1/ ,
The status of the Staff's review of the five open issues in accordance with the Comission's guidance and the Staff's implementation plan follows.
- The Veracity of the Hartman Allegations A.
. As noted in the Revalidation Memorandum (at 2), the matter of the Hartman allegations is still pending with the Department of Justice. A grand jury is in session on this issue and the Staff does not know when its consideration of the matter will be completed. In addition, the Comission's Office of Investigations (OI) also is conducting an investi- -
gation into the veracity of the Hartman allegations. Because the grand
-1/ The Staff also stated that it " believes that the Comission should give serious consideration to whether an evidentiary hearing on management competence and integrity should be held prior to the
- ' restart of TMI-1." Implementation Memorandum at 4 (footnote omitted).
- , The Staff's suggestion that the Comission consider whether a - -- -
j hearing on management competence and integrity should be held prior to restart is-not inconsistent with the Staff's position that the 4
Appeal Board should defer ruling on reopening the record until the significance of the open issues can be determined. The Comission, -
of course, has the discretion to order further hearings before
, restart if it believes it is in the public interest to do so, and
- l the Comission is free to define the scope of such a hearing as it
- believes appropriate. The Appeal Board, however, can reopen the i record only if, as a matter of law, the Comission's standards for reopening a record are satisfied, and the reopened proceeding ,
! nece.ssarily would be limited to those issues on which the standards for reopening were satisfied. At this time, in this proceeding, the Staff has asked the Appeal Board to defer ruling on reopening the record on the basis of the five open issues because l their significance, and whether they likely would affect the resolution of any of the issues, two of the elements of the reopening standards, have not yet been detennined.
l .
.- 2 w ,
4 jury proceeding conceivably may place constraints on OI',s investigation, it is not.certain.that 0I's investigation can be completed without delay.
OI's present estimate for submitting to the Commission a report of investigation is December 30, 1983. The NRC Staff has not undertaken any f
investigations or other actions regarding the veracity of the Hartman .
allegations independent of the OI investigation.
i.
B. Review of the GPU v. B&W Record The Staff has undenvay an extensive effort to review the GPU v. B&W record documents which were described to the Connission at a June 21, 1983 briefing.E Further details of the review are provided in the attached Memorandum from William T. Russell to Jack Goldberg dated July 20,
~
1983. As stated therein, the Staff will review the GPU v. B&W documents vis a vis the Staff's Restart SER (NUREG-0680) and its supplements, the Connission Orders, and the Licensing Board and Appeal Board decisions in this proceeding. The results of the review will be published as a NUREG document which will identify and sunnarize the relevant material reviewed and provide.a basis for the conclusions reached by the Staff..
The NUREG document also will identify possible integrity issues which require further review (i.e., step 1(a) of Implementation Memorandum at 3). Although completion of the review of the documents themselves and
- issuance of the NUREG document may be possible by September,1983, an
-2/ The transcript of the June 21st briefing was distributed to the parties by the Office of the Secretary on June 24, 1983.
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evaluation of their impact, if any, on the integrity of individuals is not feasible by September,1983. Considerable additional time will be required to complete the other steps in the GPU v. B&W record review (Implementation Memorandum at 3) and complete the other open issues (Implementation Memorandum at 3-4) needed to reach a Staff position on management integrity. ,
C. The Parks and King Allegations 01 has been investigating these allegations and expects to submit to the Connission'a report on the technical issues involved by August 1, 1983, and estimates that it will issue a report on the harassment aspect of the allegations by October 1,1983. The Staff will consider those reports in formulating an overall position on management integrity. ~
D. The BETA and RHR Reports The Staff expects to complete its review of the impact of the BETA and RHR reports on the restart proceeding issues and contentions, except for management competence / integrity, on a parallel schedule with the GPU v. B&W record review, and to address the impacts of the BETA and RH' R reports in all issue areas other than management competence / integrity in a report to be issued in September,1983. With respect to management competence / integrity, the results of the Staff's review of the BETA and i
RHR reports will be incorporated with the other open issues and possible
- integrity issues raised by the GPU v. B&W record review into an overall position on management integrity.
1
.M
%mem- __^ - -
E. Licensee's Failure to Provide Prompt Notification of Documents By memoranda dated June 22, 1983 and June 29, 1983,'the Staff advised the Connission of its conclusions regarding Licensee's obliga-tions to notify the Connission and/or adjudicatory boards of the BETA and RHR reports and the Licensee's report on the Hartman allegations.E .
The Staff concluded in its June 22nd memorandum that Licensee can be considered to have failed to meet its duty to make a board notification and its obligations under section 186 of the Atomic Energy Act by failing.
to provide the BETA and RHR reports more promptly. In the June 29th memorandum, the Staff concluded that the Licensee should have made a more prompt board notification of its report on the Hartman allegations.O The Staff has requested OI to determine the circumstances and reasons why the BETA and RHR reports were not provided to the NRC earlier.
(The i Staff is not aware of an OI estimate for completin, its investigation into this matter.) The Staff will consider the effect of those conclusions and circumstances on management integrity when it formulates its overall position on management integrity after completing its review
~~~
of the other open issues described above. .
)
i 3/ The memoranda of June 22nd and June 29th were served on the Appeal Board and parties on June 22, 1983, and July 12, 1983, respectively.
y The Staff has. acknowledged that "it might also be subject to-criticism for not providing additional infonnation on the Hartman matter. The Staff did not do so in order to avoid any possible interference with the 00J investigation." June 29th memorandum at 7-8.
i
.p.
III. CONCLUSION '
This_ memorandum describes the status of the Staff's TMI-1 restart review. The completion of the Staff's review of the open issues and formulation of a Staff position on management integrity realistically appear to be many months away.
Respectfully submitted, ack . Goldberg Counsel for NRC Staff Dated at Bethesda, Maryla'nd this 21st day of July, 1983 i
O I
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%,, UNITED STATES a
NUCLEAR REGULATORY COMMISSION
( ) wasHWGTON, D. C. 20555
, [ July 20,1983 .
Memorandum for: Jack Goldberg Office of the Executive Legal Director From: William T. Russell, Project Director -
GPU v. B&W Lawsuit Document Review
SUBJECT:
GPU V. B&W LAWSUIT DOCUMENT REVIEW i
You have asked that I provide information for transmission to the TMI-1 1-Restart Appeal Board regarding the nature and current status of the staff's Cosmission-directed review of the GPU v. B&W lawsuit documents.
This memorandum responds to your request.
1 The nature of the review we are conducting was recently described in a l July 11, 1983 memorandum from Harold R. Denton to several Division Directors. This memorandum is attached. It should be read in j' conjunction with the July 15, 1983, memorandum from William J. Dircks to
' the Commission on " Completion of TMI-1 Restart Review in Response to the -
Connission's Guidance of June 28, 1983," a copy of which you sent to the Appeal Board and parties on July 15, 1983. ,
t With respect to current status of the review project, as of July 20, 1983, the screening review (the initial stage discussed in the July 11, 1983 Denton memorandum) was approximately 75% complete. Approximately
) 1900 professional staff-hours had been expended in the screening review to that date. I expect the screening review to be completed during the week of July 25.
i 1
M (6 ? _7
-CA William T. Russell, Project Director GPU v. B&W Lawsuit Document Review 1 cc: H. Denton
)
D. Eisenhut 1
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"g UNITED STATES 7.
NUCLEAR REGULATORY COMMISSION I WASHINGTON. D. C. 20555 4 ._, f July 11,1983 -
- ooo* ,_
MEMORANDUM FOR: Occrel1 G. Etsenhut. Director
. Division of Licensing Thanis P. Spets, Director -
Division of Safety Technology Richard H. Vollmer, Director 1 -
Division of Engineering Roger J. Mattson, Director -
Division of Systems Integration .
Hugh'L. Thompson, Director Division of Hunan Factors Safety -
FROM: Harold R. Denton, Director .
Office of Nuclear Reactor Regulation
SUBJECT:
NRR REVIEW OF GPU VS. BaW LAISUIT DOCUMENTS Tha purpose of this memo is to defin'a the purpose,' scope, and approach to the subject review. This approach outlined below is consistent with the Commission's directions contained in the Staff Requirements memorandum of -
June 28,1983 (Enclosure 1).
- 1. purpose: To issue a staff report that documents whether any of the ~.
staff conclusions, or their principal bases, supporting our TMI-1 - --
Certification process need to be amended in light of the infonnation contained in the GPU vs. B&W lawsuit docun. ants in our possession. For the purpose of this review, lawsuit documents shall mean: (1) the .
trial transcripts and exhibit admitted into evidence, (2) exhibits used during the trial or identified by either party for possible use during the trial but not admitted into evidence, and (3) the depositions taken in preparation for the trial as well as the exhibits used in -
taking the depositions.-
- 2. Scope: The. review will encompass all safety issues being evaluated in +
connection with restart of TMI-1. The staff will review the GPU vs. . ,
84W 1awsuit documents against the overall safety evaluation hearing framework composed of the Staff's SERs (NUREG-0680) and its Supplements, Commission Orders and ASLB and ALAB decisions. The staff report, to be published as a NUREG docunent by September 1,1983, will (a) identify -
the portion of the record reviewed, (b) provide summary of the material reviewed, (c) state our conclusions, and (d) provide our bases for the conclusions. Except for any specific requests for additional documents from the licensee that may be necessary, the revieds.. limited to the documentation presently in our possession.
-e . .8m 2-
- /
/ -
/ 3. Limitations: 'The review will have three basic constraints: :
A. The review will be an audit review similar in concept to the nomal staff safet;y review.
B. The review will be based on the existing lawsuit documents plus "Keaten Tapes."
i C. The review will not be designed with a specific objective of dis-
. covering new technical / safety lessons learned from the TNI-2
! accident. However, if new technical / safety lessons learned from the TMI-2 accident are identified, they will be referred to the appropriate NRR divisions for review. Any significant infomation identified which is matertal and relevant to the restart proceedings,
- will be promptly reported to the Commission.
- 4. Approach: The general approach to this task is to utilize the line organization of NRR with DL providing the overal1 management and ~ ~
technical, divisions providing appropriate technical evaluation. The
! step-wise approach will be i
! A. The lawsuit documents will be ' divi [ fed into " bins" as follows: (DL
) Action). -
l1 - Operator Training -
? -
Procedures -
l Operating Experience l Licensee Qualifications and Management Competence .
1 1l - Quality Assurance and Maintenance I Equipment and System Design and Functions Accident Analysis _.
Radiation Protacion . . .. l Emergency Planning Management Competence / Integrity
- i
! B. The documents will be screened to assure all infomation relevant to one or more of the acove " bins"is sent to the technical review divisions. ,Infomation related to Management Competence / Integrity j will be sent to the Office of Investigations. To assist with
! transition of this task from the Executive Director's staff to NRR,
! the OL staff will be assisted by R. Hoefling, ELD and J. Craig,
, IE. OL will contact GPU to obtain infomation concerning cataloging .
i and indexing of these documents, which were all provided by GPU. - -
l Screening (i.e., reading of each document to detemine content) will be perfomed by personnel not previously involved with review I
of the GPU vs. B&W lawsuit documents. Infomation which is related to litigation issues (GPU vs. NRC lawsuit) will be identified and .
provided by ELD to OGC.
l l
- 4. . l l
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C. In parallel with the document screening, DL will identify within each review area the safety issues being. evaluated in connection with restart of TMI-1. This will include all TMI-1 certification items (both long a.1d short tern), safety issues which are not 1 hearing related and the related sections of the Staff's SER (NUREG- l 0680) and it's supplements. Commission Orders and ASL8/ALAB Decisions are included in certification items.
D$ DL will contact and, if appropriate, will meet with outside organizations (e.g., Congressional Staff and hearing intervenors) to obtain their ccaments on the GPU vs. BaW 1awsuit documents.
The objective is to identify documents which are perceived by others to be relevant and important. ,
E. NRR technical review divisions will' review the infonnation sent to them by the Director, DL, and provide, under Division Director's signature, SER-type inputs, with no open issues, that: ,
(1) Identify and synopsize the information reviewed with appropriate citations to the record, -
(2) Compare (relate) this infomation to pertinent restart certificaten issues for which they are responsible, n
(3) Conclude whether any of their technical conclusions should be modified, presenting the basis therefore, and, if modification is needed, previding the necessary input for a future supplement SER.
- Information which requires review by other Offices or Region I will be fonvarded by the Director, Division of Licensing to the -
appropriate manager for action on a schedule consistent with task . ..
completion by September 1,1983. .
In parallel with technical review, the Lead Project Manager for each area will review relevant lawsuit documents (from item B above) and related safety issues being evaluated in connection with restart of TMI-1 (item C above). He will also closely follow the progress of the technical review and will coordinate SER inputs. If necessary, l the Lead Project Manager assignments will be modified to ensure an equitable distribution of work and timely completion of this task.
,F. Should the only way to resolve an open issue be through additional - -
infonnation supplied from the licensee, technical divisions will prepare the Requests for Additional Infonnation (RAI), as necessary, in the same manner as is done for a nonnal safety review, except that they would be transmitted under Division Director's signature .
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- - - r to Director, Division of Licensing with a copy to the responsible Lead PM and Project Director. Early and aggressive technical division management attention to any such requests will be necessary to preclude unnecessary inquiries and to ensure that all issues are closed prior to August 8.
G. OL will prepare and issue a report on the results of our review.
The B&W plant Project Managers will prepare their respective ,
- sections (i.e., bins) of the report using inputs from the technical divisions. OL will provide an outline of the final report by July 15, 1983.
The DL organization framework for accomplishing this effort is H.
attached. ELD will provide a representative to coordinate
- information related to litigation issues (GPU vs. NRC lawsuit) and will provide a representative to act as Lead Project Manager for the " bin" on Management Competence / Integrity.
- 5. Schedule: Completion by September should be scheduled. Technical divisions will receive review material from the Division of Licensing by July 8 1983, and should provide SER inputs by August 8,1983.
RAI's, if needed, must be provided to DL by July 14. Overtime can be directed, if necessary to meet this schedule.
/ A Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
. As stated .
ec w/ enclosure:
W. Dircks G. Cunningham R. DeYoung R. Murley, Region I O
e 9
6
' Action: u:nton ..w x*
. Cys: Dircks
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UNITED STATES Roe
/ ,, NUCLEAR REGULATORY COMMISSION -
Rehm
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waswinavon, o.c. 2osss stallo p DeYouna 4 **-*.'w/+#f. June 28, 1983 '
Davis
~' Minocue pnes er Tua ~ GCunningham sacasTA:w - -
TMurley, RI Eisenhut, NRR MEMORANDUM FOR: William J. Dircks, Executive Director c Russell, NRR for Operations , , ,
- Hersel E. E. Plaine, General Counsel p
John E. Ierbe, Director, FROM: Samuel J. Chilk, Secre , ,
SUBJECT:
STAFF REQUIREMENTS - DI CUSSION OF TMI-1 RESTART, 10:30 A.M., TUESDAY, JUNE 21, -
1983, COMMISSIONERS' CONFERENCE ROOM, ,,
DC OFFICE (CLOSED-EE. 10)
This memorandum has been prepared'to serve the dual function r of providing guidance to the NRC staff per the staff's request and to notify the parties to the TMI-1 restart procceding of the status of the.Co- 4ssion's pending 1:mnediate effectiveness decision on. restart.*
Tho. Commission at the June 21 meeting discussed the overall -
status of the TMI-l restart proceeding and reviewed issues which may require further clarification or action before a dccicion on restart. In light of staff's withdrawal of its -
overall endorsement of management and the possibility that - --
ongoing staff reviews and OI inv'estigations may develop ,
cignificant information bearing on management, the Occmission l cencluded that it is~ unable to decide the management issues.
- for restart purposes at this time. Given the Commission's prosent understanding of the schedules for these staff
- . rcviews and CI investigations, no such decision appears possible before September 1983. However, the Commission will continue to revise its decision-making schedule as
! information from the ongoing reviews and investigations l bccomes available'and can be assessed. . .
The commission continues to place a high priority on completing itc TMI-1 immediate effectiveness restart review as early as practicable and in a manner which includes a complete and ccroful review of the important management issues. .
In the context of this memorandum the immediate effectiveness decision on " restart" refers to the Commission decision whether
':MI-l may operate pending completion of the full merits decision in the TMI-1 restart adjudicatory proceeding. Nothing in this memorandum is intended to affect the. merits of the adjudicatory
. .oroceeding.
. . ./ . .
)
2 s .
O Cor=ission requested that the transcript and handouts em the open s.e_ssion be served on the parties to the TMI-l start proceeding. Any party may submit coc=ents on this ,
morandum or the documents related to it within twenty days em the date of this memorandum. (SECY) (SECY SUSPENSE: 6/30/83)
GPU v. B&W Record Review ,
- c. The Commission, by a vote of 3-2 (Commissioners Gilinsky and Asselstin.e dissenting). decided-that it was not bound to wait for completion of a further review of the GPU v. B&W trial. record
~
- prior to an 1:mnediate eTiectiveness decision on TMI-1 restart.
- b. The Commission dete= mined that although it was not ,
bound to wait for a review of.the GPU v. 3&W trial record prior to a restart decision, the review was important'and it directed the EDO to initiate the review by NRR as recozmnanded in his memoranfum to the Commission, subject: " Completion of TMI-l Restart Re. view" dated June 10, 1983. The Commission provided the fol16 wing additional guidance:
(1) The review should constitute a " reasonable -
effort." Citations to the record should be included-where appropriat.e and judgement should be exercised to focus efforts on the most important issues. ..
~"
(2) An additional review area pertaining to '
" management ccmpetence/ integrity" should be added to the list of review areas identified en page 3'of the GPU v. B&W lawsuit review handout. ELD should be asked to assist NRR in this area.
(3) Any significant information identified during the review, particularly that pertinent to he,alth and safety, should be' reported to the
- Cc= mission as seen as it is identified.
(4) The review should be completed in accordance with the schedule presented to the Commission
- in the meeting (including issuance of a final evaluation report by 9/1/83),
(5) Although the review is directed at letermining whether any of the staff conclusions in the restart proceeding need to be amended in light of the infordation contained in the lawsuit
( _ _ _ .
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documents, litigation issues (the GPU v. NRC lawsuit) should not be ignored if identified.
To assist in the identification of th'ese, OGC *:'
will provide guidance and ELD should be asked to assist NRR in this endeavor.
(EDO/OGC) (SECY SUSPENSE: 9/1/83)
~
, 2. Partial Initial Decision The Commissioners expressed views that a partial restart
. decision was not possible for at least a couple of months but that there appeared to be individual issues such as hardware, emergency planning, design basis and perhaps others (but not management competence and integrity issues) which could be resolved in the near future for restart purposes. OPE was directed to prepare a new schedule identifying target dates for resolution of those issues. (OPE) (SECY SUSPENSE: 7/8/83)
- 3. EDO Recommendation for Completion of TMI-l Review ,
The Commission decided to await the completion of the relevant portions of the current investigations prior to resolving the management competence / integrity issues.
The Commission did not approve the EDO recommendation to separate individuals from organizational structure
. for the purpose of deciding management competence and integrity issues for restart.
- 4. GPU Proposal The Commission took no action on the GPU proposal . ..
contained in their June 10, 1983 letter and determined that staff should review the proposal to the extent .
that it affects the staff position on revalidation. .
The results of any staff review will be served on the parties. (EDO) (SECY SUSPENSE: 9/1/83) l cc: Chairman Palladino Commissioner,Gilinsky l Commissioner Ahearne '
l Commissioner Roberts .
Commissioner Asselstine Commission Staff offices PDR
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TNI-l GPU VS. 84W LAW 5uli MVIEW CAGANIZATION -
j Project alrector .
W. Aussell a ,
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Technical j Assistant ;
T. Nichaels' Techalcal Coordinators
- R. Capre I g *
- E. Butcher GPWvs.NRCtawsu$tCoordtaatar
- (Ets)
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operator Procedures ' operaties -
Tralelag Licensee Management lluality
- P.M.
P.M. I".I**'*
P M.
t Ilficattees Ceapetence Assurance R. Hernan 2 J. Sue yon 2 Management lategrity H. Grotenhuis 3 T. keny N. MnN Capotence P.M.
Nelatenance P.M.
P.N. (ELD), 11. Eadashi,j3 M. Fairtile,j3 i ,
I I l l
-* Equipment & Accident
.I
' System Destga Radletten Emergency Analysis Protecties
& Functlos Pleaning A P.M. P.N.
t P.M.
P.M.2 6. Visslag 2 A. DeAgazio 2
- 5. Ni-r t. xista., A.DeAgaalg J. Wilson 3 M. n.u,b.y J. morrisi I .
full-time until completion of SER ('Og/01/83).
2 50% , rom June 17. 1983 to completion of SER ( 09/01/83). '
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s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~BEFORE THE ATOMIC SAFETY Af!D LICENSING APPEAL BOARD In the Matter of ,
METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear Station,)
Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S MEMORANDUM ON THE STATUS OF ITS TMI-1 RESTART REVIEW" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 21st day of July,1983:
- Gary J. Edles, Chaiman Dr. Linda W. Little Atomic Safety & Licensing Appeal Administrative Judge Board 5000 Hemitage Drive U.S. Nuclear Regulatory Comission Raleigh, North Carolina 27612 Wasnington, DC 20555 George F. Trowbridge, Esq.
- Christine N. Kohl Shaw, Pittman, Potts & Trowbridge Atomic Safety &' Licensing Appeal 1800 M Street, NW Board Washington, DC 20036 U.S. Nuclear Regulatory Comission Washington, DC 20555 Douglas R. Blazey, Esq. . . . .
Chief Counsel
- Dr. John H. Buck Department of Environmental Resources Atomic Safety & Licensing Appeal 514 Executive House, P.O. Box 2357 Board . Harrisburg, PA 17120 U.S. Nuclear Regulatory Comission Washington, DC 20555 Honorable Mark Cohen 512 0-3 Main Capital Building Harrisburg, PA 17120
- Ivan W. Smith Administrative Judge Ms. Marjorie Aamodt .
Atomic Safety & Licensing Board R.D. #5 U.S. Nuclear Regulatory Comission Coatesville, PA 19320 Washington, DC 20555 Mr. Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection Administrative Judge Dept. of Environmental Resources 881 W. Outer Drive P. O. Box 2063 Oak Ridge, Tennessee 37830 Harrisburg, PA 17120
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Mr. Marvin I. Lewis William S. Jordan, III, Esq.
6504 Bradford Terrace Hannon & Weiss Philadelphia, PA 19149 1725 I Street, NW Suite 506 Mr. C. W. Smyth, Supervisor Washington, DC 20006 Licensing TMI-1 Three Mile Island Nuclear Stat, ion John Levin, Esq.
P. O. Box 480 Pennsylvania Public Utilities Conn.
Middletown, PA 17057 Box 3265 Harrisburg, PA 17120 Ms. Jane Lee R.D. 3; Box 3521. Jordan 0. Cunningham, Esq.
Etters, PA 17319 Fox, Farr and Cunningham 2320 North 2nd Street Gail Phelps Harrisburg, PA 17110 ANGRY /TMI PIRC 1037 Maclay Street Louise Bradford Harrisburg, PA 17103 Three Mile Island Alert
. 1011 Green Street Allen R. Carter, Chainnan Harrisburg, PA 17102 Joint Legislative Comittee on Energy Post Office Box 142 Ms. Ellyn R. Weiss Suite 513 Harmon & Weiss Senate Gressette Building 1725 I Street, NW Columbia, South Carolina 29202 Suite 506 Washington, DC 20006 Chauncey Kepford Judith Johnsrud Mr. Steven C. Sholly Environmental Coalition on Nuclear Power Union of Concerned Scientists 433 Orlando Avenue 1346 Connecticut Avenue, NW State College, PA 16801 Dupont Circle Building, Suite 1101 :
Washington, DC 20036 Gary L. Milho111n, Esq. ,
4412 Greenwich Parkway, NW Ms. Frieda Berryhill, Chairman Washington, DC 20007 Coalition for Nuclear Power Plant . --
Postponement Mr. Henry D. Hukill 2610 Grendon Drive Vice President Wilmington, Delaware 19808 GPU Nuclear Corporation Post Office Box 480
- Judge Reginald L. Gotchy Middletown, PA 17057 Atomic Safety & Licensing Appeal Board Michael McBride, Esq. U.S. Nuclear Regulatory Comission LeBoeuf, Lamb, Leiby & McRae Washington, DC 20555 Suite 1100 .
1333 New Hampshire Avenue, NW
- Atomic Safety & Licensing Appeal Washington, DC 20036 Board Panel U.S. Nuclear Regulatory Comission David E. Cole, Esq. Washington, DC 20555 Smith & Smith, P.L. .
Riverside Law Center
- Atomic Safety & Licensing Board Panel 2931 N. Front Street U.S. Nuclear Regulatory Comission Harrisburg, PA 17110 20555 Washingtgg,DC i
_ _ _ _ _ - - - _ _ . - _ _ ,- - - _ - _ . - - - - _ - . - - -. - - - .- __ = = .
- - _ - - . . - - ~ ^
p-
- Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Connission Washington, DC 20555,
- 0r. Lawknce R. Quarles Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Connission Washington, DC 20555 Michael W. Maupin, Esquire Hunton & Williams
' 707 East Main Street P. O. Box 1535 Richmond, VA 23212 R. Goldberg 4 Pounsel for NRC Staff 4
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l 1982 Evaluation Oyster Creek 1
Nuclear Generating Station
- General Pualic Utilities Owned by 1 Jersey Central Power & Ught Company Operated by GPU Nuclear Corporation i
, ja INP9 .
1
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f EVALUATION of OYSTER CREEK NUCf.RAR GENERATING STADON General Public Utilities Owned by Jersey Central Power & Light Company Operated oy GPU Nuclear Corporation a
i March 1983 l
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.. .o OYSTER CREEK (1982)
- Page1
SUMMARY
DITRODUCTION .
The Institute of Nuclear Power -Operations (INPO) conducted an evaluation of the Oyster Creek Nuclear Generating Station during the weeks of October 25 and November 1,1982. The station is located on Barnegat Bay, naar Forked River, New Jersey. He unit began commercial operation in December 1969.
PURPOSE AND SCOPE 4
' INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, 'and to identify areas needing improvement. Information was assembled from discussions, interviews, obser-vations, and reviews of documentation.
De INPO evaluation team examined station organization and administration, oper-ations, maintenance, technical support, training and qualification, radiological pro-i tection, and chemistry. The team also observed the actual performance of selected i
' evolutions and surveillance testing. Corporate activities were not included in the scope of the evaluation, except as an incidental part of the station evaluation. As a basis for
, the evaluation, INPO used performance objectives and criteria relevant to each of the areas examined; these were applied and evaluated in light of the experience of team members, INPO's observations, and good practices within the industry.
INPO's goal is to assist member utilities in achieving the highest standards of exceHence in nuclear plant operation. The recommendations in each area are based on
! best practices, rather than minimum acceptable standards or requirements. Accord-
! ingly, areas where improvements are recommended are not necessarily indicative of
[
unsatisfactory performance.
DETERMINATION Within the scope of this evaluation, the team determined that the Oyster Creek Nuclear Generating Station is being operated in a safe manner by experienced personnel.
The following beneficial practices and accomplishments were noted:
strong overan wryw.te commitment to station improvements increased involvement of senior station managers in the detaus of plant operation significant improvement in radiological protection practices including reduction of radioactive solid waste improvement in material condition, preservation, and housekeeping in many areas y- -g, ww,.ww-w w
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OYSTER CREEK (1982)
Page 2 l
A number of areas needing improvement were noted. The foHowing are considered to be, among the most important: ,
first-Une supervisory support of management initiatives, and involvement in on-the-job station activities several areas of training, including initial training and qualification of equipment operators and on-the-job training for most technicians j
most aspects of plant chemistry
. the quality of plant procedures industrial safety practices f off-site engineering support of the station In each of the areas evaluated, INPO has established PERFORMANCE OBJECTIVES and supporting criteria. AH PERPORMANCE OBJECTIVES reviewed during the course of J this evaluation are listed in APPENDIX IL
! FinM'ws and recommendations are listed under the PERPORMANCE OBJECTIVES to which they pertain. Particularly noteworthy conditions that contribute to meeting Other findings
, PERFORMANCE OBJECTIVES are identified as Good Practicea.
describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It l
would not be productive to list as Good Practices those things that are commonly done properly in the industry since this would be of no benefit to General Public Utilities or
! to INPO's other member utilities. As a result, most of the ffrwHiwu highlight conditions t
that need improvement.
he recommendations foHowing each finding are intended to assist the utility in ongoing
' efforts to improve an aspects of its nuclear programs. In addressing these findings and recommendations, the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues.
As a part of the second and succi, evaluations of each station, the evaluation team win fonow up on responses to findings in previous reports. Findings with response
! actions scheduled for future completion have been carried forward in APPENDIX I to this report. In areas where additional improvements were needed, a new finding that stands on its own merit has been written. Rus, this report stands alone, and reference to previous evaluation reports should not be necessary.
The fir 41c,7 listed herein were sae ated to General Ptblic Utilities Nuclear Corpora .
l tion (GPUN) management at an exit meeting on November 4,1982. Findings, i
recommendations, and responses were reviewed with GPU management on February 22,1983. Responses are considered satisfactory.
To foBow the timely completion of the improvements included in the responses, INPO requests a written status by September 30, 1983. AdditionaHy, a firal update win be requested six weeks prior to the next evaluation.
De evaluation staff appreciates the cooperation received from all levels of General Public Utilities.
OYSTER CREEK (1982)
Page 3 ..
GENERAL PUBLIC UTIllrIES Response Summary Power Operations (INPO) ce team condu t dGPU Nucle Generating Station. The recognition athe manner by th in of which the Institute of Nu evaluation the Oystere Cre kN ear strongly committed toe accomplishing team of the improvements appreciated. station s- iments uclear and accompli s h ing nuclear power plants safely and effi i c ently.
efforts in making additional improvements mprovements and is dedicated to opera This evaluation will help us focus our The findings improve by the evaluation team fonows:ments can be made.
Comments on the most important whichof thare valid ese areas are as Improved first-line superv step this in achieving improved support. progress.isory support of management initiatives i s a significant job station activitiesIncreased should ensue finvolvement ary bytofirst-line achieve suMana senior station managers in nthe details of pla trom the continued i operations. erest of programmed for improvement in 1983 Initial tralrung a for equipment operato"; are e consider operators uipment di isneen an area that reliabnity and safe operation e.
of Oyster Cre k mportant elements in improving theng A major progress. restructuring and upgrading of th upgrading of GPUN radiological controls prManagement n Plant procedures are ereceiving detail d i ogram is planned.ar t part of the revision and review process quality and workabaity of plantn-depth.
procedures These reviews by senior management efforts should resultvedin s impro a
A significant during 1982. reduction in lost-time d along with improvements ce.in safety performanContinued deve e
a safety program is planned .
Improvements in the off-site engine .
closer working relationship between plante-ing groups is being fostered.
- e. A support of the engineering and corporate engineering ..
i
- i OYSTER CREEK (1988)
Page 10 KAINTENANCE MAINTENANCE ORGANIZATION AND ADMDUSTRATION PERFORMANCE OBJECTIVE: The maintenance organization and administrative sye-tems should ensure effective control and implementation af department activition.
1 I
i Plading Ahinistrative WJares that define maintananne and mainte-i (MA.1-1 ) annes supervisory positices need to be revised. The new main-tenance organization is not clearly understood by all maintenance
- personnel.
Recommendation Revise station administrative procedures to define the newly established maintenance organization. Ensure changes are commu-nicated to aII station maintenance personnel Be Changes to the Station Administration Procedures (101 Series) and to the GPU Nuclear Organization Plan have been completed.
Information on the Maintenance and Construction (M&C) Organiza-tion and the Material Department has been communicated to all station maintenance personnel. A major revision *e PicsMare 105,
" Conduct of Maintenance," has been drafted and will be published by March 1983.
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T Finding Some halana*-of-plant gauges and meters are in need of enlibra-(MA.2-2) tion. Additionally, several gauges and meters do not have calibra-tion stickers affixed as required by plant procedures.
Recommendation Ensure the recently established program for calibration of balance-of-plant gauges and meters is carried out in a timely manner and that calibration stickers are affixed to all gauges and meters as required by Mant procedure.
l Response A program to resolve this finding has started, including placing " cal
! stickers" on all balance-of-plant gauges and meters. It is antici-pated that this program will be completed by the end of the 1983 outage.
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OYSTER CREEK (1982)
Page 19 l
Finding Plant drawings are not always updated in a timely mannae. As-
, (TS."-2) built drawing change requests submitted to the off-site technical functions division are frequently not incorporated as drawing revisions for extended periods of time. It is recognized that a program revision has recently been initiated to address this prob-lem.
Recommendation Establish a target completion date for closing out the open requests for drawing changes.- Establish a method for ensuring timely action on future drawing change requests.
Itagw=== Procedure EP-025, " Technical Functions," provides a list of draw-ing types that will be revised. Drawings designated by Operations as control room drawings will be revised to incorporate Field Change Notices %-Ms, normally within 30 days.
No set time frame is established for revising non-control room drawings. Engineering Data and Configuration Control Section notifies the cognizant engineering section manager when more than six changes are posted against a specifie drawing. Procedure EMP-015, " Field Questionnaires, Change Notices, and Change Requests,"
will be modified to require not only engineering section manager notification, but also to require updating of the drawing incor-porating the change notices. This will be done by May 1983.
All drawing lists for Oyster Creek are available to site personnel in an on-line computerized data base. Field Change Notices / Requests are immediately listed against every drawing upon issuance, thus permitting all personnel to ascertain the current status of every drawing on a real-time basis.
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PIANT STATUS CONTROIE PERPORMANCE OBJECTIVE: Operational personnel should be aa-n' =at of the status of plant systems and equipment ieder their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.
Pinding '!he eurent duift turnover practices do not ensure a complete and (OP.3-1) comprehannige traover of plant statua. For example, operational and narrative logs are not routinely reviewed, and turnover check lists are not used as an integral part of the shift turnover process.
Boeommendation Expand the existing turnover requirements to include the following additional guidance to the operators:
- a. Utilize the existing turnover sheets as an integral part of the turnover process.
( b. Perform a review of operational and narrative logs, major outstanding clearances, and a test of main control panel annunciators.
- c. Require control operators and group shift supervisors to perform a walkdown of control panels during shift turn-over.
Management personnel should periodically monitor shift turnovers to ensure proper performance in this area.
Respanne To immediately address this finding, a memorandum was issued on November 16,1982 delineating proper shift turnover practices.
Furthermore, a revision to station pror.h in-wting the guidelines presented in INPO Good Practice OP-201, " Shift Relief and Turnover," has been developed and will be put into effect by March 1983. In addition, department management personnel are periodically monitoring turnovers as part of their daily interaction with the shifts.
Pindbg (TS.3-4)
'the current tracking system for industry operating experienee review corrective actions does not track corrective metions to oossplation.
Recommendation Improve the tracking system used to monitor the dispopition of SERs and SOER recommendations.
Ramponse All SERs and SOER recommendations are tracked from receipt until completion or until another tracking system such a:: a design modification is initiated. A procedure change will be made that will allow trackiry of SER and SOER recommendations associated
' with design modirleations until completion of the modifications.
This procedure change will be in effect by April 1983.
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l TECHNICAL SUPPORT PROCEDURES AND DOCUMENTATION 4
i PERPORMANCE OBJEC'HVE: Techniani support procedures and documents should
! prwide appropriate direction and should be effectively used to apport safe operation of the plant.
Pinding Contml room &awings used for plant operations do not always
('IS.7-1) reDeet the actumi eonditions of the plant. A number of as-found conditions have not been inevipereted in control room drawings.
1 Recommendation Ensure that all identified as-found changes are reflected in plant drawings.
! W agww- A program has been initiated to review plant drawings versus as-
. built conditions to determine drawing differences. 'Ihis determina-tion will allow drawings to be corrected to reflect the as-built condition of the plant. Work on this long-term project, which is l expected to take between two and three years, has already commenced.
A group of drawings, designated by Operations as control room
- drawings, will be revised to incorporate Field Change i Notiee/ Requests, normally within 30 days. In the interim, com-i posite marked-up prints will be made available to the conf.rol room
! prior to receipt of official as built drawings.
i 'Ihe basic procedures are in place and wD1 be clarified by March 1983.
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OPERATIONS PROCEDURES AND DOCUMENTATION PERPORMANCE OBJECTIVE: Operational WiJares and documents should provide appropriate direction and should be effectively used to support safe operation of the plant.
I L
Finding (OP.5-1) Some operations Wh are overly diffleult to use and contain erroneous references. Some procedures do not contain sufficient
- information to complete evolutions without frequent references to other procedures. These references are not always correct.
Recommendation Conduct a procedure usability review of an operating procedures that will not be replaced by new emergency procedures. Revise deficient procedures as necessary. Whne conducting the review place emphasis on human factors considerations such as erroneous, references, non-specifle references, and procedure subparagraphs.
h=w===
In addition to revising the emergency operating procedures and implementing the symptom-oriented emergency procedures, a pro-
- gram will be initiated to improve the review and revision of operating procedures. This will include the development of proce-dure writing guidelines that take into consideration, among other standards, human factors, format, and usability. Implementation of such guidelines is expected to be completed by December 1983.
This wiH ensure that future review and are conducted in a controned manner. generation of procedures Review priority win be assigned to abnormal events procedures and emergency operating procedures.
9
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l 1- Finding kaprovement is needed in the method for making temporary (OP.5-2) changes to operating Wderes. The foHowing problems were f noted: l Temporary changes are not verified to be entered in all a.
procedures prior to use for plant operation.
- b. Temporary changes are not tracked to ensure proper review and implementation.
- e. Some temporary changes have required as long as six months for review by the Plant Operating Review Com-mittee and implemention in the plant as permanent prece-dure revisions.
Recommendation Improve the administrative controls for temporary procedure changes to ensure that au procedures used in the conduct of plant operations contain applicable temporary changes, and that tempo-rary changes are tracked to ensure timely review and implementa-tion su permanent procedure revisions.
Rempanse A change to Procedure 107, " Procedure Control," has been devel-oped that elarifles handling of temporary and one-time changes.
Procedure 103, " Document Control," is also under review.
Required changes to these procedures w!Il be issued by April 1983.
he Plant Operation Review Committee is meeting daDy to reduce the backlog of procedure changes. his backlog should be elimi-l nated early in 1963.
1 1
(TS.3-3) Information ennearning in4mune events with passble generie impli-
, entions is not provided to other utGities in a thnely manner.
Roeommendatlan Establish iwvedoral guidelines for notifying the industry of in-house events with generic implications.
Response
The examples given as events with possible generic implicat during the INPO review were Licensee Event Reports. These reported to the NRC and provided to INPO for screening in a timely manner. The current procedural guidelines for notify industry other plant oftransients.
in-house events cover reports required by the NR completeness. These guidelines will be reviewed for In addition, a plant engineering supervisor has been This should improve the timeliness of report
?
/
d .
/
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/ l l
PLANT MATERIAL CONDFTION PERFORMANCE OBJECTIVE: The material condition of the plant should be main-tainari to support safe and reliable plant operation.
Finding A numher of plant material dafleiencies observed during the (MA.2-1) evaluation were not documented in the work control system.
Examples noted included pump seal laaks, valve packing leaks, clogged drain lines, and !*ng relief valves.
Maanmmendation Implement measures to ensure timely identification and correction of plant deficiencies. INPO Good Practice MA-301, " Plant Materi-al Deficiency Identification," could be of assistance in this effort.
Maapan=a Specific items observed during the evaluation were addressed; however, the long-term resolution of the problem lies in the
' forthcoming revision of Procedure 105, " Conduct of Maintenance."
This complete revision of plant material deficiency identifleation, documentation, resolution, and close-out procedures is intended to minimize the number of undocumented or unresolved deficiencies.
The recent realignment of functions between the M&C Organiza-tion and the Material Department and the inception of the M&C Work Management System will aid in resolving this problem.
_. .- ._ . _ , _ _ _ . _ _ , _ - _ . _ _ _ _ . - _ _ , , , . - _ _ . - .-.._y_ _... .-,..,. .n. -_. . ____ .. - . . _ _ _ _ _ __ ._., . _ ._, ,__.___,.,m, ,,_ ._ . ,
[ '%, UNITED STATES
~
NUCLEAR REGULATCRY COMMI:;SION 5
- jg ako:ow i 631 PARK AVENUE
, . o., , g .usc or Prussia. PENNsVLVANI A 19406
-***** AUG 08 1983 Docket No. 50-289 GPU Nuclear Corporation ATTN: Mr. R. C. Arnold, President
'100 Interpace Parkway Parsippany, New Jersey 07054 Gentlemen:
Subject:
Inspection 50-289/83-21 This refers to the unannounced special team inspection conducted by Mssrs.
A. Gody, S. Collins and C. Holden, of this office on July 18-22, 1983, of activities authorized by NRC License No. DPR-50 and to the discussions of our
< findings held by Mr. Gody with Mr. P. Clark and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the ins'pection consisted of selective examinations of procedures and representative records, l and interviews with personnel.
Within the scope of this inspection no violations were observed. The inspection '
focused on your policies and practices relative to the General Office Review Boards.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosury -
will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the require-ments of 2.790(b)(1). The telephone notification of your intent to request
) withholding, or any request for an extension of tne ten day period which you i
believe necessary, should be made to the Supervisor, Files Mail and Records, USNRC, Region I, at (215) 337-5223.
No reply to this letter is required. Your cooperation with us in this matter is appreciated.
Sincerely, 6 . M4 Thomas T. Martin, Director Division of Engineering and Technical Programs
Enclosure:
NRC Region I Inspection Report No. 50-289/83-21
- $s24-6A95- 9
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TMI Unit 1 RCS Leak Rate Tests.
April 1, 1978 - March 31, 1979 Jin W. Chung September 21, 1983 r
i- _ _ _ .
U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 50-289/83-20 9
Docket No. 50-289 License No. OPR-50 Friority --
Category C Licensee: GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted: July 11 - September 9,1983 Inspectors: # [( Luij U~
W.~Chung, L'ead Rea r Engineer date h
a M . (?
. *C. Wen, Reactor E JA 9-2/-71 date nef /
9+- # sc-
- j. C.'Vanterpo'ol, Summer Technical Intern 9 Auk date S
J. Tusar, Summer Technical Intern Eh date Approved by: k L. H. 6~etterfhausen, Chief, Test Programs Section h/d date Inspection Summary:
Inspection on July 11, 1983 - September 9, 1983 (Report Nember 50-289/83-20)
Areas Inspected: Special unannounced inspection of Reactor Coolant System Leak Rate test procedures, equipment and records for the period of April 1, 1978, through March 31, 1979. The inspection included approximately 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> at site and local NRC offices and 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> at the NRC Regional office by two region-based inspectors and two technical interns.
Results: Instances of failure to follow station procedures and regulatory requirements were found. ,
Y. M D Jf) J L2
t l
1ABLE OF CONTENTS Page EXECUTIVE
SUMMARY
5 DETAILS 8-1.0 persons Contacted 8 2.0 Scope of Inspection 9 t 2.1 Objectives 9 2.2 Documents and Records Reviewed 9 2.3 Summary of Record Review 11 3.0 Reactor Coolant System (RCS) Leak Rate 16 3.1 Background 16 3.2 RCS Leak Rate Calculations 17 3.3 Procedural Inadequacies 22 3.4 Measurement Sensor Limitations 24 3.5 Uncertainty of Make-Up Tank (MUT) Chart Time 26 3.6 System and Human Error Potential 26 4.0 Effects of Hydrogen Addition on Leak Rate Test Results 28 4.1 Discussion 28 4.2 Makeup Tank Level Shifts with Hydrogen Addition 28 4.3 Findings Regarding Hydrogen Addition 30 4.3.1 Existence of Loop Seal 30 4.3.2 Test to Develop Recorder Trace for Hydrogen Addition 31 4.3.3 Hydrogen Additions During Leak Rate Tests 32 5.0 Effects of Water Addition on Leak Rate Test Results 37 5.1 Discussion 37 5.2 Findings Regarding Water Addition 38 6.0 Effects of Reactor Coolant Drain Tank (RCDT) Level Inputs on 40 Leak Rate lest Results 6.1 Discussion 40 6.2 Findings Regarding RCDT Level Inputs 40
r ~ - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- -- -- -- -
Pagg 7.0 Management Meetinos 43 ATTACHMENTS .
A. Copies of RCS Leak Rate Test Raw Data Supporting Table'2, Feed and Bleed Operations B. Copies of RCS Leak Rate Test Raw Data Supporting Table 6, Hydrogen Additions C. Copies of RCS Leak Rate Test Raw Data Supporting Table 7, Water Additions D. Computer Program Listing of RCS Leak Rate Calculation E. Applicable Technical Specifications F. Surveillance Procedure SP 1303-1.1
" Reactor Ceolant System Leak Rate", Revision 7, May 25, 1976 k
5 EXECUTIVE SUMvARY OBJECTIVES
' The basic objective of this inspection was to verify that records of Reactor Coolant System (RCS) leak rate testing at Three Mile Island (TMI) Unit 1, from the period April 1, 1978, to March 31, 1979, showed no indications of practices similiar to alleged irregularities at Unit 2. The allegations related to Unit
) 2 RCS leak rate testing involved the following:
-- That tests were often repeated until the results met the acceptance criteria and that unfavorable results were discarded; q
%go ;
-- That RCS water inventory was adjusted contrary to procedural requirements; in that water additions were made and not recorded in the test package nor e '
included in the RCS leak rate test calculations; m [
'j( h ' -- That computer data entries for the leak rate calculations were " fudged" to make the leak rate test calculations appear acceptable; and, K
k
-- That hydrogen gas was added to the Make-Up Tank (MUT) to influence leak rate test calculations, p, Supplemental objectives of the inspection were to:
-- Examine compliance with the Technical Specifications on RCS Leak Rate;
} -- Inspect the leakage test procedure for technical and functional adequacy; and, f 4 --
Examine the effects of instrument calibration and variations on leak rate determinations. .
CONDUCT OF INSPECTION e
- From July 11, 1983 to September 9,1983, members of the engineering staff of ,
g Region I conducted an inspection of TMI-l records, procedures, equipment and ,
specifications related to reactor coolant system leak rate testing performed by hg station personnel in the year immediately preceding the accident at THI-2. The
, inspectors reviewed and correlated diverse records related to leak rate tests, '
.. performed an "as-built" walkdown of related plant systems and instrumentation, and, in conjunction with licensee personnel, demonstrated by system operation ki i s
Nf' g
a technique by which RCS leak rate results could be modified. I I
El i
t.
f
$(gG Surveillance records for RCS leak rate tests were reviewed for the perte i from April 1, 1978 through March 31, 1979. Six hundred and forty-five test records Lh[ /
SP were the principal object of this review. These surveillance records were com-pared with control room logs, power traces and makeup tank level recorder
@ charts developed during the tests to determine abnormal test operations, adequacy of records and compliance with test procedures. The station surveill-l L_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____ _ .
6 ance test procedure in effect at that time was evaluated for completeness and adequacy. Independent leak rate calculations were performed by the NRC staff with an NRC microcomputer and compared with TMI-1 data to verify the validity of licensee calculations.
The inspector performed a walkdown inspection of the makeup system and verified that the instrumentation system for measuring makeup tank (MUT) level contained a loop seal. The significance of this loop seal is that hydrogen additions made to the MUT during a test could result in errors in RCS leak rate test calculations. Further, a review of plant maintenance records for 1978 identi-fied narrative which described the effects of gas additions on indicated Make-Up Tank (MJT) level.
The MUT strip chart recorder traces were independently analyzed and evaluated by the inspectors to identify instances of improper performance of RCS leak rate tests, such as the addition of hydrogen or water during the performance of the leak rate test. Strip chart data were compared with control room logs and surveillance test calculations to determine if test conditions as indicated by the strip chart were incorporated, or considered, in the calculation of leak rate. Further, the inspectors directed and monitored an actual demonstration of the effects of gas additions to the MUT at Unit 1 on indicated MUT level to
! support their conclusions. Licensee personnel assisted in this demonstration and acknowledged the resulting conclusions.
MAJOR FINDINGS The RCS leak rate tests performed at TMI-1 during the year prior to the acci-
~
dent at TMI-2 contained several inadequacies and deviations from procedural and regulatory requirements. These would, in most instances, have lead to a less conservative calculation of RCS leakage rates, s
- a. The RCS leak rate procedure, Sp 1303-1.1, Rev. 7, in use during the time period reviewed, was inadequate because:
o it contained incorrect procedural steps ($3.3);
o it did not prohibit acceptance of test results showing negative leakage ($2.3);
o it failed to incorporate temperature compensation for several leak rate factors (53.3);
o it omitted several important factors; such as, no provisions to include steam generator tube leakage as identified leakage or the effects of pressure variation in the RCS (53.3); and, o it utilized incorrect values for volume and water mass change per unit level change ($3.3).
4 i .
_-_-__.___m_--. _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ , _ _ _ _ , _ _ , _ _ _ _ _
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- b. The as-built configuration of the MUT level instrument system provided a e loop seal en the low pressure reference leg, which introduced the poten- E tial for non-conservative effects on RCS leak rate test results from Y MUT gas additions. During discussions with station operating personnel, the inspectors were informed there was no loop seal in the makeup tank level instrument system. An NRC walkdown revealed the loop, which pro- .
vides a means to affect leakage calculations (54.3.1).
- c. An analysis of MUT level strip charts for the period inspected indicated %
at least-swac, hydrogen additions were made during RCS leak rate tests.
There were no entries in the control room logs which recorded the fact )% %
that these gas additions were made nor were they compensated for in the .
N %
leak rate calculations. The calculated leak rates, therefore, were in error. Actual leakages were, in fact, higher than the recorded values (54.3.3).
U-d.
%vh
-Seven instances of apparent water addition to the RCS during leak rate @ b tests were identified. In only one test was the water addition accounted for in the calculations; and, in that case, the volume accounted for was considerably less than the apparent actual addition. These unaccounted %
additions resulted in recorded leakage values lower than actual leakages 07 (S5.2).
TM A instances of apparent feed and bleed operations during testing E4eren
- s e.
were identified, for which the leak rate calculation was not properly IR3 g\
a gs b correctedfprtheoperator-causedyaterinventorhchange(52.3),'s cnu Wsrb c.a. 6t 4 Ocmb4pm ck s W- m c' G tL 4 rn , k is. A number of instances of substantial apparent level changes in the Reactor Coolant Drain Tank during leak rate tests were identified. No logbook entries which would explain these level changes were found. (86.2) I g.
The licersee established a conservative administrative test frequency for hg.
. RCS leak rate testing of once per shift, whereas, technical specification required only daily testing. .kventeen missing test records were iden- \D g tified ($2.3). Eh ?'
CONCLUSION o personnel, it is concluded that there were indications of* practices at IMI i y [ Based s
on Unit l related tothis RCS leakreview rate testingof licensee simil records 4thoseallegedatUnit2; 1.e.';.W7) exa ,1 s of water additions,b (7) examples of hydrogen and limite j
gas additions, a*4 examples of feed and bleed operations were '
identified, from a population of 645 test records. i were not properly .
incorporated in RCS leak rate test calculations. Qg
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8 DETAILS 1.0 Persons Contacted GpU Corporation J. D. Abramovici, Mechanical System Engineer, Parsippany R. Barley, Lead Mechanical Engineer N. Hollerbush, Supervisor, Document Control H. Hukill, Director, 1MI-1 V. Orlandi, Lead I&C Engineer F. Paulewicz, Mechanical Engineer M. Sanford, Supervisor, Plant Engineering, Parsippany H. Shipman, Operations Engineer C. Smyth, Supervisor, licensing P. Snyder, Manager, Preventive Maintenance H. Wilson, Supervisor, Preventive Maintenance USNRC R. Conte, Senior Resident Inspector F. Young, Resident Inspector The inspector also held discussions with other licensee employees during the inspection, including operations, technical support, and administra-tive personnel.
9 2.0 SCOPE OF INSPECTION 2.1 Ob.iettives The basic objective of this inspection was to verify that records of Reactor Coolant System (RCS) leak rate testing at Unit 1, from the
- period April 1, 1978, to March 31, 1979, showed no indications of
! practices similiar to alleged irregularities at Unit 2. The allega-tions related to Unit 2 RCS leak rate testing involved the following:
l
-- That tests were often repeated until the results met the accept-ance criteria and that unfavorable results were discarded;
-- That RCS water inventory was adjusted contrary to procedural l requirements; in that, water additions were made and not re-corded in the test package nor included in the RCS leak rate test calculations; i
l
-- That computer data entries for the leak rate calculations were i " fudged" to make the leak rate test calculations appear accep-table; and, i l
-- That hydrogen gas was added to the Make-Up Tank (MUT) to influ-ence leak rate test calculations.
Supplemental objectives of the inspection were to:
-- Examine compliance with the Technical Specifications on RCS Leak Rate;
-- Inspect the leakage test procedure for technical and functional r adequacy; and, Examine the effects of instrument calibration and variations on leak rate determinations.
2.2 Documents and Records Reviewed l The RCS leakage test records for the period of April 1, 1978, through March 31, 1979 were reviewed. The requirements and commitments discussed herewith are those applicable specifications and require-ments for that review period.
2.2.1 Specifications / System Oescriptions
-- FSAR, Unit 1, Sections 4.2.3.8 and 4.2.3.9.
-- Technical Specifications Amendments through March 1979: Amendment Nos. 11, 15, 17, 29, 32 and 35.
I
i 10 '
-- Make-up and Purification System. Preliminary System description by Babcock and Wilcox (B&W), Med. Ed. Co.,
TMI Unit 1, Initial Issue, August 14, 1969. ,
-- Pressurizer Instruction Mcnual, Babcock & Wilcox Instruction Book No. 620-0006, 01-0110 01.
Drawings: RCS, TMI Unit 1, DWG #4192 C-302-650, Revision 21; Make-up and Purification, TMI Unit 1, DWG
- 4192-C-302-661, Revision 23; Liquid Waste Disposal, l
TMI Unit 1, DWG #4192-C-302-690; Make-up Tank, B&W 35-44-002-05; Reactor Cooland Drain Tank, B&W DWG
- 37-44-001-01.
2.2.2 Procedures
-- Sp 1303-1,1, Reactor Coolant System Leak Rate, Re-l vision 7, May 25, 1976; Revision 8, August 21, 1981; Revision 10, May 18, 1983; Revision ll, July 13, 1983. ,
-- TP 600/10, RCS Hot Leakage Test, Revision 0, December 16, 1973, performed February 19, 1974 l
Operating Procedure (OP) 1101-1, Plant Limits and Precautions, Revision 15, May 18, 1983.
-- OP-1102-4, Power Operations, Revision 34.
OP-1103-4, Soluble Poison Level Control, Revision 20 l -- OP-1104-2, Make-up and Purification System, Revision l 41. .
l
-- OP-1101-21, Nuclear Plant Setpoints.
l
-- Station Administrative Procedure (AP) 1012, Shift Relief and Log Entries, Revision 8, November 4, 1977 2.2.3 Control Room Records
-- Control Room Operator (CRO) Logs, dated April 1,1978 to March 31, 1979.
-- Senior Reactor Operator (SRO) Logs, dated April 1, 1978 to March 31, 1979.
-- Technical Specification Surveillance Procedure (SP) 1303-1.1 Records, dated April 1,1978 to March 31, 1979.
11 Selected Computer Outputs, Daily Summaries
-- Selected Auxiliary Operator Logs Makeup Tank (MUT) Strip Chart Traces, dated April 1, 1978 to March 31, 1979, excluding those dated July 8, t
1978 to August 4, 1978 Power Range (NI-5) Recorder (SA-125) Traces, April, 1978 to March, 1979 l 2.2.4 Other Records
-- Selected Instrument Calibration Records; Reactor Coolant Drain Tank (RCDT) Foxboro Temperature Sensor, July 26, 1972; RCS Wide Range Pressure Sensor, March, 1972; Pressurizer Level Detector, June 5,1971; RCS RTD, December 15, 1973, August 22, 1974; pressure vessel specification data sheet for MUT and RCDT.
> -- Selected Chemistry and Sampling records, 1978 Plant Operations Review Committee (PORC) minutes of
' meetings, dated December 31, 1975 to December 30, 1976; January 1, 1978 to December 3, 1978; January 8,
! 1979 to January 22, 1979.
l
-- Selected Work Requests (WR).
l I 2.3 Summary of Record Review l Surveillance records of RCS leak rate tests were reviewed for a l period from April 1, 1978 through March 31, 1979. During that period, there were 290 days which required daily RCS leak rate testing in accordance with Technical Specification Table 4.1-2, item 7. The reactor was not in operation during June 22-29, 1978 and February 16 - March 27,1979.
The surveillance test procedure (SP 1303-1,1) records were compared I
with SRO Shif t Foreman and CR0 log entries in order to obtain the
! number of times of test performance. The following entries were i identified:
l Record No. Tests Period l CR0 Log 713 4-1-78/3-31-79 SRO Log 707 4-1-78/3-31-79 SP 1303-1,1 714 4-1-78/3-31-79 l
I
12 lhe surveillance records from the period of July 8,1978 to August 4, 1978 were not reviewed due to missing MUT recorder traces. Thus, 69 surveillance test records could not be reviewed. Therefore, 645 surveillance test records were reviewed against MUT recorder traces and other data, such as daily logs and computer listings.
The licensee had established a conservative administrative test frequer.cy of once per shift. Tests were often performed once per shif t, whereas Technical Specification required a daily test.
The total number of days covered by surveillance record was 290 days, during which the following tests were completed:
No. Tests Performed Per Day No. Days
]13 1 (Daily) 27 2 (Twice Daily) 114 3 (Each Shift) or more 149 Major findings from the record review are:
-- Some of the tests noted in the CR0 and SRO shift logs were missing in the surveillance files. These surveillance records were either never created, lost, discarded or misfiled. Two test records were found filed out of normal sequence and six were found misfiled, i:;e-+=en missing test records were j $(1
'M identified. They are listed in Table 1.
-- The surveillance test records frequently showed negative leak rate results. Two months of leak rate test data were reviewed to identify examples of test records demonstrating negative leakage. The following summarizes the results of that review:
May, 1978 June, 1978 May + June 1978 Total Test Records Reviewed 60 61 121 Number Test Records Demonstrating Negative Leakage Rate Results Leakage Plus Losses 10 4 14 Gross Leak Rate 20 16 36 Unidentified Leak Rate 28 20 48
13 hy Table I s
Lost, Misfiled, Discarded or Never Created RCS Leak Rate Test Records Date Time 1 4-29-78 1400 2 5-07-78 1436 "
3 5-21-78 1025 _
4 6-06-78 0530 5 7-04-78 2205 6 7-10-78 0338 7 8-19-78 1450 8 9-03-73 1247 9 11-05-78 1955 10 11-10-78 1125 11 12-11-78 0432 12 01-07-79 0600 13 01-18-79 0530 14 01-18-79 1310
- 15. 01-26-79 0032 16 01-29-79 0310 17 02-11-79 2230
i 14 Almost 40* (48 out of 121) of the calculated and recorded unidentified leak rates during the two month period had negative values.
-- The RCS leak test procedure, SP 1303-1,1, recommended water additions such as Feed-and-Bleed (F&B) operations be avMded during the test. The inspector identified at Icast'44 N sts, lRi l during which F&B operations appeared to have taken place; and in each case, the change in water inventory was not properly f compensated for by the operator in the computer calculations of RCS leakage rates. They are identified in Table 2.
These record review findings are indicative of the failure of the l licensee to comply with regulatory and procedural requirements for l record-keeping and test performance.
l l
l l
i l
f
F 15 Table 2 Apparent Uncompensated Feed & Bleed Operations During RCS Leak Rate Testing F&B Recorded No. Date Test Start Time In CRO/SRO Log Power
- 1 5-12-78 0047 No 89.5 Steady 2 5-30-78 0134 No 99.0 Steady 3 7-02-78 0256 Yes 89.0 - 87.0 Decreasing 4 8-05-78 1456 No 100.5 Steady 5 9-15-78 0921 No 101 Steady 6 11-13-78 0304 No 100 Steady 7 11-16-78 0426 Yes 72.0 - 81.0 Increasing 8 11-20-78 2110- Yes 100.0 Steady 9 11-24-78 0423 No 102.0 Steady 10 11-24-78 1111 No 102.0 Steady 11 11-24-78 1724 No 102.0 Steady
- Strip chart traces of power range recorder, SA-125. " Steady State" was assumed if there was less than 1 0.2*4 Variation on the recorder traces.
Attachment A contains copies of records for these tests.
4
16 3.0 Reactor Coolant System (RCS) Leak Rate 3.1 Backoround .
The TMI Unit 1 Technical Specifications,-paragraph ^5.1.6 and Table 4.1-2, required that RCS leakt.ges be determined at least once per day during steady state operations, and that the leakage plus-losses, total. gross leakage and unidentified leakages be maintained within their respective limits of 30 Gallons-Per-Minute (GPM),10 GPM and 1 GPM. The TMI-1 Final Safety Analysis Report (FSAR), Section 4.2.3.8.a. specified that the leaktges were measured by counting water inventory changes within the RCS pressure boundary'for a fixed time interval.
The test procedure included a precaution to avoid addition or removal of water and chemicals from the RCS. The procedure also recommended that, for the most accurate leak rate determination, the initial and final values of power, RCS temperature, RCS pressure and pressurizer level should be maintained identical.
The procedure specified a test duration of one to eight hours, and specified the plant computer as the favored tool for performing test calculations. Hand calculations were allowed as a backup when the computer was not available. There was only one record of a hand cal-culation during the one year period from April, 1978 thru March, 1979.
When the computer program was initiated, data was taken automatically from hard-wired, pre-designated computer points, except for RCDT water levels, which did not have the direct input points to the computer. Therefore, RCDT levels were always required to be taken from a local patch panel using a digital voltmeter (DVM), and were entered manually into the computer calculations. Other manual actions required by the computer method were input' specifications, such as test time interval (normally one hour), ar) identified leakages and the operator actions of make-up water additions and RCDT pumping. RCS leak rate calculations were automatically done by the computer when the above steps were completed. For hand calculations, the preferred data source was defined to :n DVM readir.gs from a patch panel rather than data obtained from control roctr indicators, due to the inherent inaccuracies in the latter readings ,
The procedure also specified a set of corrective steps to be taken when the RCS leakages were in excess of the requirements. The first step was to perform another leak rate determination, followed by careful examination of the operator actions affecting the water inventory. The final step was to initiate action to determine the i source of the leakage, and then to proceed with tie ACTION statemente l specified in Technical Specification 3.1.6, which required placing l the reactor in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection of excessive leakage.
17 3.2 RCS Leak Rate Calculations The leakage determination was based on a mass balance of the RCS water inventory changes over a prescribed time-interval, normally one hour, even though the procedure allowed a test duration of up to eight hours.
The station surveillance procedure for RCS leak rate testing, SP 1303-1.1, Revision 7, May 25, 1976 (effective through August 21, 1981), determined " total RCS leakages plus losses" (30 gpm limit) from the difference between initial and final water inventory of the RCS, compensated for thermal expansion (or contraction) and level changes in the pressurizer and the make-up tank. " Gross RCS leakage rate" (10 gpm limit) ras determined from the difference between
" total RCS leakages plus losses" and changes to Reactor Coolant Drain Tank inventory. The " unidentified leakage" was determined from the difference between the gross and operator identified leakages, excluding the combined effects of normal evaporative losses and Reactor Coolant Pump (RCP) seal purge. An evaporative loss of 0.51 gpm was applied, based on the results of preoperational test TP 600/10, performed February 19, 1974.
Details of the computer algorithm and calculational steps are illustrsted in Figure 1.
Where the symbols used are:
Tc,, Th, = A loop Tcold, Thot ( F)
Tc , Th =B1 pT cold, T b b not (*F)
Z = Water level (in) p = density (lb ,/ft3 )
am = mass change (ib,)
AV = volume change (gal)
AV' = operator induced change to the RCS or RCDT (gal)
CF = conversion factor from lb, to gallon, a function of Tyy, based l
on a linear' interpolation about 2155 psig l
i
FIGURE 1. TMJ-1 RCS LEAVs RATE CALCULATION (pre-April 1979) 1303-1.1 Rev. 7, 5/25/76 READ FINAL TIME DATA:*
READ INITIAL TIME DATA?
dt Tca sh g,Tcg,Th 8' PZF' mu.Zrcdt Tc,,Thg ,TcB ' , p r. mu, B
- Data from hard-wired computer points, y
except Zredt (operator input).
(I ) final I c3 +Th 4
+T c ITh)g (Tave) initial = 4(Tc3 +Th A cB
+Ih)B B
I u
u density calc.:
linear interpolation based on value and rate of jO p
V initial ((Tave) initial) change of value at 2155 psig V final =g ((Tave) final)
=(finitial-[ final)*V asi
> Amagi v
V pg)
= 10,673 f t 3 ampzr = ((Z pzrlinitial -(2 zr) p final)
- CF 1 CF1 = 120.8 Iw/in w .
v-c V 1
,,vE ,
r TMI-1 RCS LEAK RATE CALC. (pre-April 1979) i 1 i 1303-1.1 Rev. 7, 5-25-76 v
O CONTINUE I T,y,= 4((Tave) initial
+ (Tave) final) ,,
ammu 2 = 250 lbm/in
= ((Zmu} initial -(Zmu) final)
- CF2 M
u u
l CF = CF(Tave) i conversion factor om rcs " IA* R81 *ompzr + Ammu) from lbm to gallon b v
> CONTINUE i 2 i 6Vrcs " A m res
i f
1 l
TMI-l RCS LEAK' RATE CALC. (pre-April 1979) 1303-1.1 Rev. 7, 5-25-76 '
I CONTINUE 1
- INPUT:AV rcS CU DB TOR)
, y PROCEDURE STATED LEAK RATE FOR RCS PLUS LOSSES 30 g
"(AVhcs+AVrcs)/ot a
v 2 l amredt = ((Zredt) initial - (Zredt) final)
- CF3 CF3 = 3540 lbm/ volt u **Z rcdt from patch panel 9LV redt " 0 %cdt
- CF digital voltmeter readings entered by operator.
v INPUT: AV. (WATER REMOVAL redt . CAUSED BY OPERATOR
> CONTINUE
TMI-l RCS LEAK RATE CALC, (pre-April 1979) 1303-1.1 Rev. 7, 5-25-76 I CONTINUE f ,' GROSS LEAK RATE =
PROCEDURE STATED
!N! res + 4Vr cs + 4Vredt - 4V'cdt)/At r
ACCEPTANCE CRITERIA: 10 q-
,e P7ASURED Y0 A h "^ f u
CONRECTION TERMS = EVAPORATIVE LOSSES' +
RCP SEAL #3 PURGE = b.23 gpm u
UNIDENTIFIED RCS LEAK RATE = GROSS LEAK RATE - PROCEDORE STATED IDENTIFIED LEAK RATE + CORRECTION ACCEPTANCE CRITERIA: 1 gt" TERMS y
I END
21A Table 3 Selected RCS Leak Rate-Results Comparison A
(NRC'- GPU)' I NRC I GPU USNRC A %a Leakage-P)us-Losses 6-21-78: 4.1299 4.14771 0.01781 0.42939 7-6-78: 0.2205 0.22516 0.00466 2.0696 9-11-78: -0.3875 -0.389682 -0.002182 0.5600 11-28-78: 0.1972 0.2029785 0.0057785 2.847 1-6-79: -0.1774 -0.179124 -0.001724 0.9624 Gross 6-21-78: 1.1721 1.189077 + 0.016977 1.42775 7-6-78: -0.1476 -0.13949 +0.00811 5.814 9-11-78: -0.3562 -0.36010 -0.0039 1.0830 11-28-78: -0.1162 -0.10750 +0.0087 8.093 1-6-79: -0.3648 -0.366395 -0.001595 0.435 Unidentified 6-21-78: 0.9421 0.959077 +0.016977 1.7701 7-6-78: -0.3776 -0.36949 +0.00811 2.140 9-11-78: -0.5812 -0.59010 -0.0039 0.6610 11-28-78: -0.3462 -0.33750 -0.0039 1.156 1-6-79: -0.5948 -0.596395 -0.001595 0.2674
l l
22 CF 3
= pressurizer water mass change per level height change (lb /in).
CF, = make-up tank mass change per level height change (lb,/in).
CF, = reactor coolant drain tank mass change per level sensor voltage output change (Ib,/ volt)
Subscripts:
pzr = pressurizer mu = make-up tank redt = reactor coolant drain tank R&l = reactor vessel & loops res = reactor coolant system To verify the licensee surveillance calculations, a program was written for an Osborne portable computer, based on SP 1303-1.1, Revision 7. Sample calculations were performed for five test cases.
The results indicated an average of 0.31% difference between the licensee's and NRC calculations with a 2.98% standard deviation. The results are tabulated in Table 3. Most of the differences in licensee and NRC calculations are attributed to the use of different density correction factors. The NRC computer program then was used to independently check licensee results for many of the tests examined and to calculate the effects and changes due to the irre-gularities found and described in the sections which follow.
3.3 Procedural Inadecuacies 3.3.1 Total RCS Leakaoe Plus Losses Technical Specification Section 3.1.6.8 stated in part, " Loss of reactor coolant through reactor coolant pump seals and system valves to connecting systems which vent to the gas vent header and from which coolant can be returned to the reactor coolant system... when added to leakage shall not exceed 30 gpm."
Surveillance Procedure SP 1303-1.1 computed " Total RCS Leakage Plus Losses" as shown in Figure 1. The calculational procedure did not account for temperature and pressure differences between the MUT and RCS. Table 4 shows that the MUT water is normally at 125'F in comparison to RCS Tave of 579 F. Failure to convert MUT level changes to equivalent RCS~ conditions volume changes resulted in errors in the leak rate calculations and was a l procedural inadequacy.
n L
l l
l
I 1
23 To illustrate this, assume that during-a one hour test period an operator adds _60' gallons' of water (at 125") into the MUT.
If temperature correction was not required, the 60 gallons would remain 60 gallons and the calculation would not be in error. 'In reality the 60 gallons would expand in the RCS to 82.56 gallons, but SP 1303-1.1' assumes no expansion and there-fore would introduce a nonconservative reduction in.RCS leakage rates of 0.376 gpm.
3.3.2 Total RCS Leakage Technical Specification 3.1.6.1 stated, "'f the total reactor coolant leakage rate exceeds 10 gpm, the reactor shall be placed
- in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection". The total reactor coolant system leakage was called the " Gross RCS Leak Rate" in SP 1303-1.1 and was computed as shown in Figure 1.
Surveillance Procedure SP 1303-1.1, Rev. 7 incorrectly-accounted for RCS leakage collected in the Reactor Coolant Drain Tank (RCDT) which was removed by operator action, since the calcu-lation failed to correct for the lower temperature of RCDT water as compared to the RCS; thus, each gallon removed from the RCDT caused a nonconservative estimate of " Gross RCS Leak Rate."
3.3.3 Unidentified RCS Leak Rate l Technical Specification Section 3.1.6.2 states: "If unidenti-fied reactor coolant leakage (excluding normal evaporative losses) exceeds one opm or if any reactor coolant leakage is evaluated as unsafe, the reactor shall be placed in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection."
i Surveillance Procedure SP 1303-1.1 computes " Unidentified RCS Leak Rate" as shown in Figure 1. The calculational procedure incorrectly accounts for Reactor Coolant Pump #3 Seal Purge in that the value of this purge was added to the calculation of
" Unidentified RCS Leak Rate" as a correction factor. Since the purge is taken from the MUT and ultimately flows to the RCDT, it is appropriately compensated in the calculation of " Total RCS Leakage."
3.3.4 Other Procedural Deficiencies 1
The evaporative loss factor (-0.51 gpm) utilized in com-puting " Unidentified RCS Leak Rate", was obtained from the pre-operational test results TP600/10, "RCS Hot Leakage Test", Revision 0, performed March 14, 1974. In that procedure, the evaporative loss (-0.51 gpm) was calculated
- assuming 125*F MUT water, which was not corrected to equivalent RCS conditions.
4
23A Table 4 System Data for RCS. Leak Rate Calculations System Operating Conditions Reactor Coolant System T,y,, *F 579 volume (without pressurizer, at 579*F), ft3 10678 Pressure, psig 2155 Make-up Tank Vertical, Cylindrical pressure psig 15 - 35 Temperature, "F 125 Level, inch 73 Volume, gallon 2955 Reactor Coolant Drain Tank Vertical, Cylindrical Pressure, psig 0 Temperature, "F 105 - 110 Level, inch 94.5 o Volume / Level, gal / inch 35.4 Volume, f t3 771 Pressurizer pressure, psig 2166 Temperature, *F 648 Level, inch 220 Volume (liquid), ft 3 800 Volume (Steam), ft3 702 Volume / Level, gal / inch 240
1 l
l I
l 24 !
1
- In addition to the f ailure to correctly convert MUT level changes to equivalent RCS water inventory changes, due to failure to correct for the higher RCS temperature, the procedure assumed the MUT and RCDT were maintained at a constant temperatures, and therefore did not account for the effects of temperature variation on water density.
- The Reactor Coolant Pump #3 Seal Purge was incorrectly converted to equivalent gallons at 534 F versus the proper conversion to 579 F.
The procedure failed to account for the effects of changes in pressurizer pressure on pressurizer level.
The procedure utilized an RCS Volune figure (excluding the pressurizer) of 10,673 ft3in calculations; whereas, the correct Volume figure at an RCS Tave of 579 F was 10,678 3
ft ,
The procedure utilized a MUT water mass change per unit level change of 250 lbm/in in calculations; whereas, the correct value for 125 F was 255 lbm/in.
3.4 Measurement Sensor Limitations The sensors and instrumentation used in leak rate calculations were examined for accuracy and repeatability. Since these instruments have direct input (except for the RCDT level) to the plant process computer for use in the leak rate calculations, an understanding of their accuracy and repeatibility is useful when reviewing leakage rate determinations.
Table 5 summarizes the estimations of accuracy and repeatability.
These estimations were checked against a period of stable reactor operation and found to be realistic. Instrument and sensor limita-tions and performance were not found to be limitations in leak rate calculations. A conservative estimate of measurement error due to instrument repeatability is 11.6 gallons regardless of test duration.
i l The following reference documents were reviewed to determine repeat-ability to construct Table 5.
Calibration notes, TMI-1 Bailey BYXXX0 type differential pressure transmitter specifi-cations E 21-17, page 31; Type BY8230-A Make-up Tank level l differential pressure transmitter, order number, A-29062Z, calibration specifications sheet No. 150L339.
-- Foxboro model E13DM Differential pressure Transmitter, MI l 20-110, January 1969.
26
-- RCS RTD Calibration Acceptance Test Data Sheet, February 8, 1974.
-- Model 6S4A Converter, Foxboro; Model 620 Series indicating transmitter
-- Model 1152GP Rosemont pressure transmitter
-- Foxboro 99B series totalizer specification sheet, February 1967.
A significant variation in reactor coolant system parameters can be expected due to inherent periodic oscillations of some of these para-meters. The oscillations can be significant if a beginning or final data set is gathered over a time span which is comparable to the period of oscillations. It was understood that due to relatively improved system tune-up for Unit 1, during the one year period of interest, the system oscillation or inherent periodic perturbation in Unit I was negligible compared with the expected errors from such perturbation in Unit 2. This was understandable since Unit I had been in commercial operation since 1974 and Unit 2 started its operation in December 1978.
A stable period of plant operation was selected to check for such oscillations. The inspector noted that the reactor was maintained at 100'. power for seven hours during a period of 1600-2300 hour on September 30, 1978.
The inspector reviewed computer summary sheets for the same date, and verified that the cold and hot leg temperatures (total six readings; 4 cold legs and 2 hot leg readings) were indeed maintained constant during the entire seven hour period. Also, the T,y, variation was far less than one tenth of the RTD uncertainty and less than the estimated repeatability of the instrumentation.
Accuracy of the RCS leakage calculation is not dependent on the absolute accuracy of the RCS inventory measurements but rather is dependent on accurate measurement of the inventory changes. There-( fore, test accuracy does not depend on the absolute instrument l
accuracy of the individual detection systems, but rather on each l
instrument's repeatability, or closeness of agreement among a number l of consecutive measurements. Based on several discussions with
! licensee representatives and review of listed documents, it was learned that repeatability of pressure, temperature and level detec-tion elements was considerably better than their respective accura-cies.
Table 5 shows a summary of the instrument accuracy and estimated repeatability and consequenty expected measurement errors. Note that the measurement errors due to the instrument repeatability are independent of the test duration. For example, total measurement l
25A Table 5 .
Instrument Repeatability Expected Inventory Change Instrument Accuracy Repeatability yariance Individual Over-all (RMS) parameter gal RCS Temperature (100 F span) 0.52% 0.052% . <6 gal.
RTD 0.25%
Drift 0.25%
after 2 yrs. ,
Bridgc 0.35%
Signal 0.15%
Conversion RCS Pressure (800 psi span) 1.128% 0.113%' ~0 Transmitter 0.5%
Buffer 0.15%
Amplifier Isolation 1.0%
Amplifier Pressurizer Level (400 inch span)-
Level 0.5% .4 inch 0.4" 9.6 gal RTD (same 2.8 F/700 F as RCS RTD)
MUT level, (100 inch span) 0.5% 0.05" 1.5 gal RC01 level, (120 inch span) 0.5% 0.06" 2.1 gal Flow Totalizer 0.25% 0.1%
Total RMS Variance in Inventory Change Calculation <11.6 gal
26 errors estimated from the instrument repeatability would be 11.6 gallons regardless of test duration, and subsequent contribution to the leak rate error would be 0.19 gpm and 0.05 gpm for one and four hour test durations, respectively.
3.5' Uncertainty of Make-Up Tank (MUT) Chart Time During the one year period, 264 water additions were logged in CR0 logbooks and these entries were identified on the MUT strip chart tracings, as tabulated in Table 10. The purpose of this comparison was to determine the accuracy and validity of the chart time. It was understood that the time entered in the shift log by an SR0 and CR0 was the control room clock time, and the control room MUT recorder time was adjusted periodically to the control room clock time at midnight.
The traces of water addition on MUT charts were compared statisti-cally with the CR0 log entry times. Statistical analysis showed that the chart traces of water additions were ahead of the log times by an average of 3.2 minutes with a standard deviation of 10.73 minutes.
This was an expected result since the operator or SRO would enter the water additions into the shift log after completion of the operation.
On this basis, it was determined that the MUT recorder chart time was accurate statistically to i 10 minutes.
This information was later utilized to isolate the interval of the MUT level strip chart trace which bracketed the period of test performance. The resulting interval of strip chart was typically 80 minutes wide, (a 60 minute test + 13 minutes before + 7 minutes after) starting 13 minutes prior to the recorded test start time in terms of chart time. All available records were then correlated to identify the actual period of test performance within this interval.
3.6 System and Human Error Potential Beside the procedural inadequacies and the "As Built" system limita-tions, there are three additional expected or potential errors in the -
RCS leakage rate calculations.
(1) RCDT level patch panel DVM readings The procedure specified that all other level readings besides the RCDT's were automatically fed from the process computer input data points. RCDT levels were manually entered after taking patch panel DVM readings. Since a small error in DVM readings could cause a large error in the RCS leak rate result, the RCDT level readings could be a major source of the errors in leak rate calculations. This is discussed further in Section 6.0.
27 (2) MUT Water Addition Procedure SP 1303-1.1 recommended that no addition of make-up water be made during a test, and further specified that water addition, if any, be entered manually into computer.
If make up water was added during a test, after initial data taking but before final data reading, and the addition was not included in the computer calculations, the RCS leak rate cal-culated results would be inaccurate and understated. This is discussed further in Section 5.0.
(3) Hydrogen Addition Because of the configuration and environment of the MUT level detection instrumentation system, water condenses and collects in the low pressure reference leg. Under this condition, hydrogen additions to the MUT during a test cause an increase in the indicated MUT level without actually adding water into the system. This would definitely change the RCS leak rate test results, yielding inaccurate and understated RCS leak rate test results. So long as the condensed water is blocking the low pressure U-leg as described above, hydrogen addition would cause an indicated MUT level shift upward.
Details are discussed in the Sections 4.0.
i
W 28 4.0 Effects of Hydrogen Addition on Leak Rate Test Results 4.1 Discussion Hydrogen addition to the make-up tank is often required in order to limit the oxygen content in the Reactor Coolant System. The RCS leak rate test procedure, SP 1303-1.1, prohibits the addition of chemicals during a test, although the procedure did not specifically identify hydrogen as a chemical.
As discussed later, the addition of hydrogen to the make-up tank (MUT) can cause an indicated increase in the MUT level without water addition. Therefore, addition of hydrogen at an appropriate time (af ter initial data collection, and preferrably just prior to final data readings) will affect the leak rate results in a non-conser-vative fashion. The conditions under which such hydrogen additions were made resulted in a characteristic trace on the MUT level chart record. In order to isolate hydrogen additions, level recorder charts were searched for the characteristic trace of the hydrogen addition. These traces, once found, were then compared with the CR0 logbook entries and surveillance records.
4.2 Makeup Tank Level Shift with Hydrogen Addition The water level in the make-up tank is determined by measuring the differential pressure between the top and bottom of the tank, as shown in figure 2. With the level instrumentation operating prop-erly, any change in cover gas pressure (P 3
) will be applied equally to the top and bottom of the tank, and the level transmitter will give the pressure P 2 , representing the liquid head in the tank. The piping leading from the bottom of the tank to the higher pressure side of the level detector is intended to be filled with water, and the piping from the top of the tank to the low pressure side of the detector is intended to be dry. The water in the MUT is normally at 125 F, a higher temperature than the ambient room temperature, and the saturated water vapor over the MUT water is at a higher pressure than that which can exist in the colder pipe. Thus, the Low Pressure Piping will act as a slow vapor condenser, and the condensed water will gradually fill the " dry" low pressure leg (see figure 2).
If enough water exists in the loop it will form a water loop seal and, for small pressure changes, serve to isolate the low pressure side of the level detector from the make-up tank.
I
29 FIGURE 2 LOOP SEAL LOW PRESSURE LEG P
MAKEUP @ (P1 + Pp) - P1=P2 TANK LEVEL TRANSMITTER P2 j P3+Pp I'
HIGH PRESSURE LEG .
RCS WATER P
Pi 3 v
d P1 w -
(P 1+P)-P3=P2 2
P -
2
( oj P1+P2 HYDROGEN ADDITION P3+Pg ___4 P+e 1
- Pg-e l M
l (P1+P 2 + PH ) -(P3 + e) ,
P2
=
P2+Pg -e (je P3+P2+PH NOTE: The "e" term accounts for the slight compression of the trapped gas due to the movement of the water column and is approximately equal to zero.
- - _ , _ a p --.-%___ ,- -,w. - -..-,,m. .g.
30 Referring to the bottom diagram in Figure 2, if a small amount of pressure, say PH, is added to the MUT, the condensed loop seal water will behave like a manometer, and the high pressure side will sense the additional pressure (PH) added to the tank, but the low pressure side will only sense a small percentage of the addition. The net effect will be an apparent increase of the MUT water level, equal to the pressure increase (PH ) expressed in inches of water. For each inch of apparent level change, it takes only 0.036 psi pressure addition (Pg), or 1 psi pressure addition can give 2.3 f t (27.69 inches) water level increase. To influence the leak rate, it takes only a few inches level change, since the water volume change for each inch of level in the MUT is 30.8 gallons. For example, by adding 0.072 psi hydrogen pressure (P g ), the apparent MUT level will increase by 2 inches, an apparent inventory increase of 61.7 gallons, resulting in a decrease of the calculated gross and unidentified leak rates by 1.028 gpm in a one hour test.
The characteristic trace of a hydrogen addition on the MUT level recorder when a water loop seal is present will be a strip chart trace like a step increase with over-and under-shoot. This pattern
(.f-) of over/under-shoot is due to the manometer-like oscillation of loop seal water in the incompletely filled low pressure reference leg due to the sudden pressure increase.
Obviously, the effect of a pressure addition on the level is limited by the height of the water column in the loop seal. Any excess pres-sure will either push the water column toward the top of the U-loop and into the detector or cause gas bubbles through the water seal, negating the pressure effect. For practical purposes, 2 - 4 inch level changes by hydrogen addition will not cause any measurable gas compression on the detector side of the loop seal in the low pressure leg.
4.3 Findings Reaarding Hydrogen Addition 4.3.1 Existence of Loop Seal The inspector questioned several licensee staff members relative to the possible existence of a loop seal in the MUT level instrument system legs. These licensee repre-sentatives informed the inspector that no loop seal existed.
During an as-built inspection on July 11, 1983, the inspec-tor found the existence of a loop seal in the " dry" leg of the MUT level instrumentation. Subsequently, the inspec-tor, accompanied by a licensee representative, verified that the U-loop in the dry leg is more than 4 ft. in height. The following entries in the plant maintenance logs indicate that some members of the plant staff were aware of the effect of water condensation in the low pressure leg of the level instrument:
31
-- Work Request (WR) No. 23660, April 28,1978 at 2200 hour0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br />, "make-up tank level recorder is not responding correctly. Put in 100 gallon - recorder went up 8" or 240 gallons. If you change make-up tank pressure 4 lbs. - level changes 218".
-- WR No. 23904, May 16, 1978 at 2145 hour0.0248 days <br />0.596 hours <br />0.00355 weeks <br />8.161725e-4 months <br />, "while adding H2 to MUT-1, received MUT-1 high level alarm..."
-- WR No. 23852, May 23, 1978, Make up tank level in-crease 10" for addition of-100 gal. - should only move by about 3"."
-- WR No. 24843, August 8,1978, " Transmitter / recorder erratic. Suspect that reference leg has moisture in it"; blow down low side. Got a lot of water."
-- WR No. 21284, September 12, 1979 at 1900 hour0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br />, '...
suspect MUT-1 level transmitter" 4.3.2 Test To Develop Recorder Trace For Hydrogen Addition On July 28, 1983, the licensee challenged the proposition that hydrogen addition would cause an increase of the MUT's indicated level and produced MUT strip chart traces from a test. The inspector recognized that during this test, the licensee introduced over 20 psi pressure. This pressure was much greater than that required to affect MUT level.
It would require a loop seal 46 feet in elevation versus the existing loop seal with a maximum four foot elevation.
To demonstrate the effect of a realistic hydrogen addition on MUT level, the inspector proposed a test.
On July 29, 1983, two inspectors were accompanied by licensee representatives inside and outside of the MUT room, and another inspector with a licensee representative directed the test from the control room. The test was per-formed with nitrogen gas. The effect of the pressure addition was observed as summarized in the following:
-- When the loop seal was drained immediately preceding the test, no effect of pressure addition was observed on indicated level.
-- 'dith water in the loop seal, small amounts of nitrogen gas were introduced for 1 second, 2 seconds and 10 seconds by opening and closing MU-V-27, and the resulting level increases were 1.0 inch, 2 inches and 7 inches. The pressure increases during these tests were too small to register on the pressure indicator in the control room.
32
-- The trace of the level shift due to the pressure increase (_k-) was the same as'those suspected hydro-gen additions on the MUT chart for the period April 1978 thru March 1979. (See Table 6)
The test traces are shown in Figure 3. For clarity, Figure 3A provides a magnified hand drawn version of the appropriate section of Figure 3. A computer graphic trace is shown in Figures 4 for this test. After the test, licensee representative acknowledged the inspector's findings of the effect of hydrogen additions and their characteristic traces on the MUT level charts.
4.3.3 Hydrogen Additions During Leak Rate Tests The Control Room Operator's and Shift Foreman's logs were searched for entries showing hydrogen addition during the periods of leak rate testing records. This was done for records from April, 1978, through March, 1979. No entries showing the hydrogen additions were observed in the logs.
The makeup tank level strip chart was then examined for the additions; 13 additions were identified. Considering the accuracy of MUT chart times, seven hydrogen additions during RCS leak rate testing were confirmed as shown in Table 6. The hydrogen additions were not recorded in the logs nor compensated for in the leak rate calculations.
Wnen the hydrogen additions and consequent level shifts were included in the leak rate calculations, the unidenti-fied leak rates were all increased, and all but one ex-ceeded the limiting conditions of operation in Technical Specification 3.1.6.2, which specified the limit as 1 gpm.
Further, Technical Specification 3.1.6.2 stated that if the unidentified reactor coolant leakage exceeded 1 gpm, the reactor should be placed in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection.
These findings constitute examples of apparent failure to comply with procedural and regulatory requirements.
l P
Figure 3. Hydrogen Addition Test, July 29, 1983 n
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T Figure 3A. Detail Sketch of Make-Up Tank Level Response Hydrogen Addition Test, July 29, 1983 Time and Level Expansion of Figure 3.
55 inches g __. . . ._
a .-
t- .
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_ _ _ _ time _
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FIGURE 4.' Process Computer Display Hydrogen Adriition Test MUT Level Shift on Gas Addition :
10 Seconds Opening / Closing
. Test Conducted:
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A498 MU TANK LVL (IN) INH 2O ZERO= 0. 0 FULL = 100.C A497 ftU LETDOHN FLON ( GPfi ) GPM ZERO= 0.00 FULL = 100.OC A500 MU FLON TO REACT COOLANT (GPM) GPM ZERO= 25.0 FULL = 150.C
. AO92 AMBIENT-DRY BULB T E f1P DEGF ZERO: 70.O FULL = 119.C PLOT RATE = 2 SECOND(5)
Table 6 Hydrogen Additions To Makeup Tank During Leak Rate Test Unidentified Leak Effect on Leak Rate, Gallon Rate, gpm Hydrogen Temperature Temperature Entry in Power
- Effect on Level CR0 tog %
Date Time inch not corrected corrected Original Corrected 84.996 -0.1099 1.3067 No 99.5, steady 8/8/78 0735 2 61.77 127.439 -0.5823 1.5417 No 99.0, steady 9/8/78 1629 3 92.649 1 30.883 42.512 0.4014 1.1099 No 100.0, steady 9/18/78 2355 61.17 84.996 0.0168 2.1536 No 100.0, steady 9/19/78 2348 2 92.649 127.457 0.0293 1.4612 No 99.0, steady 10/2/78 1645 3 0816 1. 5 46.32 63.761 -0.1954 0.8673 No 100.0, steady 11/12/78 3 92.649 127.509 0.4092 2.5344 No 102.0, steady 2/3/79 1608 C$ trip chart traces of Power Range Recorder, SA-125 Attachment B contains copies of records for these tests.
r-37 5.0 Effects of Water Additions on Leak Rate Test Results 5.1 Discussion When water is added to the makeup tank during an RCS leak rate test (before the final readings but after the initial data taking), it should always cause an apparent reduction in the leak rate results.
Even though procedure SP 1303-1.1 recommended against any water additions during the leak rate test, the procedure provided for the entry of the water additions into the computer.
As stated earlier, the computer program did not account for the water expansion as the cold water from MUT (125 F) heated up in the RCS (579 F), and consequently, even a correctly entered water addition would result in an error. For example, a 100 gallon water addition and subsequent computer entry would result in a 100 gallon water inventory increase, even though that 100 gallons of water would expand to 137.6 gallons in the RCS. If not manually entered into the calculation by the operator, this would give a 1.67 gpm (100 gal. in 60 min.) reduction in the uncompensated gross and unidentified leak rates for a 60 minute test and would result in an actual 2.29 gpm (137.6 gal into RCS in 60 min.) reduction of the leak rates.
The water additions to the RCS are required to be entered in the Control Room Operator's (CRO) log in order to account for the opera-tor actions. Therefore, one would expect to see any operator-induced water addition to the RCS recorded in the CR0 log as well as in the computer calculations.
Water addition could be identified from the makeup tank level record-er chart, whose traces shifted upward in level when the water was added. This characteristic pattern or trace could be easily corre-lated with the entries in the CR0 log. However, the trace of a water addition would be different than the trace or pattern seen when hydrogen was added. The hydrogen addition would result in an almost perfect step increase with a characteristic overshooting due to the loop seal water oscillations. In contrast to this, water additions would not produce sharp, right-angled step-wise indicated level changes with overshoot, but would show some slope of increasing indicated level with time.
The makeup tank recorder chart was reviewed in order to determine if water additions had been made during RCS leak rate tests without recording the addition in the control room CR0 and SRO logs, and/or without including such additions in the RCS leak rate calculations.
r 1 38 5.2 Findings Regarding Water Addition During a previous inspection, four such water additions were identi-fied. During this inspection it was determined that three of them were wrongly identified. In fact, one of the three wrong cases is now identified as a hydrogen addition.
Based on the review of MUT strip chart traces of water addition, surveillance SP 1303-1.1 computer output and pressurizer level response during tests, seven tests were identified during which water additions were made but were not entered into the computer calculations. Table 7 summarizes these water additions.
In some cases, the chart traces indicated that water might have been added gradually to the RCS. One test, performed January 6, 1979, accounted for 300 gallons of water addition in the computer calcula-tions. However, the level shift, a characteristic trace of water addition on the MUT strip chart, indicated that approximately 479 gallons of water was added instead of 300 gallons. This recorded MUT level shif t provided additional evidence of the existence of a loop seal in the low pressure reference log, since raising MUT level compresses the MUT cover gas and causes the same effect as a gas addition discussed in Section 4.
When these water additions were accounted for in the leak rate calcu-lations, all but one showed that the failure to enter the water addi-tion into the computer resulted in the unidentified leak rate in excess of I gpm, as tabulated in Table 7. This was contrary to the requirement specified in Technical Specification 3.1.6.1 and are further examples of apparent failure to comply with procedural and regulatory requirements.
Table 7 Water Additions During RCS Leak Rate Test Without Entry Into the Computer Water Addition Entry in Unidentified Leak Rate, GPM Power **
CR0 Log Original Compensation Corrected %
Dat7 Time inch callons 8.0 247.1 Yes -0.7443 3.384 4.930 90, steady 5/12/78 1643 0804 9.0 277.9 Yes -0.5826 5.215 6.977 97, steady 6/11/78 ,
6/21/78 0341 8.0 247.1 Yes 0.9421 5.060 6.613 99.5, steady 8/31/78 0801 5.5 169.86 No -0.4141 2.417 3.481 100, stesdy g; 11/7/78 1608 2.0 61.77 No 0.0445 1.0735 1.553. 100, steady 12/13/78 1842 10.0 308.83 Yes -0.2170 4.930 6.865 100, steady 1/6/79* 0756 15.5* 478.69* Yes -0.5948 0.1497 0.900 101, steady 8300 gallons of 478.69 gallons added were included in the original leak rate calculations.
CCStrip chart traces of Power Range Recorder, SA-125 Attachment C contains copies of records for these tests.
40 6.0 Effects of Reactor Coolant Drain Tank (RCDT) level Inputs on Leak Rate Test Results 6.1 Discussion The Reactor Coolant Drain Tank collects the effluent or leakage from the pressurizer PORV and code safety valves. It also collects leakage past the reactor coolant pumps primary mechenical seal. The tank fluid can be circulated througn a cooler and returned to the tank by spraying into the tank vapor space. The RCDT also has a connection to the Reactor Building Sump. Surveillance Procedure SP 1303-1.1, Revision 7 (effective revision during 1978-79), treated the water level change in the RCDT as a loss of Reactor coolant covered by Technical Specification 3.1.6.8. Therefore this was not subject to the 10 gpm limit of total RCS leakage. This treatment of RCDT water would allow leakage through relief and safety valves and reactor coolant pump seals to approach a 30 gpm limit.
6.2 Findings Regarding RCDT Level Inputs Manuai reading of RCDT level .nd manual input of the value into the computer were required. The RCDT level transmitter output was not hard-wired into the computer, and consequently its value had to be manually entered into the computer after taking a patch panel DVM reading. A 0.1 volt error in the reading could lead to a 1.0 gpm error in total and unidentified leak rate measurements during a one hour test. Normal RCDT level readings were 8 to 9 volts. It was not possible to cross-check records to determine if actual errors were made.
When an operator took an action such as pumping out water from the RCDT, this action is required to be logged in the CR0 shift 109 As listed in Table 8, the RCDT tank levels were decreased substantially according to the surveillance records of leak rate tests; yet, no entries in the SRO or CR0 logs were identified reporting the cause for the apparent large volume of water removed from the RCDT. An unaccounted water removal values of calculated from the rate.
gross leakage RCDT would result in conservative These are additional apparent f ailures to follow procedural requirements concerning required log entries.
Based on the computer printouts of surveillance results, Table 9 lists those RCDT level changes greater than 60 gallons of water during the review period. If these changes are overstated, the resulting RCS leak rate calculations will be nonconservative.
, i 41 Table 8 i
Reactor Coolant Drain Tank Decreases During Leak Rate Test (< 0.1 Vcit)
Level change Volume change Effect on Datei '
Time Volt at 579 F, gal Leak Rate gpm 4/27/78 0805/0905 -0.112 -66.212 5/12/78 -1.104 1643/1743 -0.279 -164.939 -2.749 5/16/78 1615/1915 -0.117 -69.168 -0.384 6/7/78 1646/1835 -0.100 =108.777 9/14/78 -0.906 2355/0055 -0.218 -128.877 -2.148 10/16/78 1852/1952 -0.890 -526.150 12/13/78 -8.769 1842/1942 -0.592 -349.979 -5.833 I
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42 Table 9 Reactor Coolant Drain Tank Increases During Leak Rate Test (2 0.1 Volt) I Date Level change Volume change :
Time Volt Effect on at 579 F, cal Leak Rate, opm 5/8/78 2320/0120 5/21/78 0.123 72.715 0328/0428 0.114 0.606 6/1/78 0746/0846 67.395 6/2/78 0.145 1.123 0046/0340 85.721 1.429 6/2/78 0.247 1658/1858 146.021 0.82 6/9/78 0.175 103.457 2341/0441 0.430 0.862 6/11/78 0804/0904 254.207 6/12/78 0.111 0.847 1645/1745 0.187 65.621 1.094 6/16/78 0035/0135 110.551 6/16/78 0.928 1.843 1925/2125 548.615 9.144 6/20/78 0.190 0041/0141 112.324 0.936 6/21/78 0.112 0341/0441 0.309 66.212 1.104 6/21/78 0912/1012 182.675 7/7/78 0.480 3.045 1603/1903 283.766 7/8/78 0.181 4.729 1935/2135 107.004 7/11/78 0.190 0.594 1535/2035 112.324 7/17/78 0.117 0.936 0040/0440 69.168 8/15/78 0.219 0.235 0455/0555 129.468 8/23/78 0.224 0.539 2349/0349 132.424 11/5/78 0.217 2.207 1712/1812 128.286 12/24/78 0.105 0.535 0740/1040 62.074 1.035 12/28/78 0.395 233.516 1627/1927 0.151 1.300 1/12/79 2347/0047 89.268 0.111 0.496 65.621 1.094
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7.0 MANAGEMENT MEETINGS An entrance meeting was conducted with H. Hukill and staff on July.11, 1983. The purpose and scope of the inspection was discussed at this meeting. No other management meetings were held. No written notes or requests were provided to the licensee by the inspectors during the course of this inspection.
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44 Table 10 Log Time Versus-MUT Recorder Chart Time for Water Additions Time blo_. Date CR0 Chart A, min.
- 1. 4/30/78 1400 1355 5
- 2. 5/4/78 0130 0145 -10
- 3. 5/5/78 0005 0005 0
- 4. 5/5/78 0315 0315 0
- 5. 5/5/78 1700 1700 0
- 6. 5/5/78 0520 0515 5
- 7. 5/8/78 1300 1255 5
- 8. 5/9/78 2055 2050 5
- 9. 5/10/78 0830 0820 10
- 10. 5/12/78 1745 1735 10
- 11. 5/12/78~ 1543 1547 -4
- 12. 5/11/78 1800 1746 14
- 13. 5/13/78 0815 0800 5 '
- 14. 5/13/78 1505 1500 5
, 15. 5/14/78 2225 2220 5
- 16. 5/15/78 0050 0045 5 !
- 17. 5/15/78 1845 1840 5 !
! 18. 5/16/78 2120 2110 10 l
- 19. 5/16/78 0500 0450 10 1 l
! 20. 5/17/78 0325 0320 5
! 21. 5/17/78 1530 1530 0 l 22. 5/18/78 1340 1340 0
- 23. 5/19/78 0415 0415 0
- 24. 5/20/78 0525 0523 2
- 25. 5/21/78 0315 0315 0
- 26. 5/21/78 0003 0005 -2
- 27. 5/21/78 1930 1930 0
- 28. 5/21/78 2245 2245 0
- 29. 5/22/78 0419 0419 0
- 30. 5/22/78 1130 1130 0
- 31. 5/23/78 0530 0520 10
- 32. 5/24/78 0630 0625 5
- 33. 5/26/78 2200 2200 0
- 34. 5/26/78 0112 0107 5
- 35. 5/26/78 1826 1810 16
- 36. 5/28/78 1925 1910 15
- 37. 5/28/78 0320 0315 5
- 38. 5/30/78 0240 0235 5
- 39. 6/3/78 0214 0150 24
- 40. 6/3/78 1515 1450 25
- 41. 6/4/78 0847 0850 -3
- 42. 6/5/78 0140 0140 0
E 44a Time No. Date CR0 Chart A, min.
- 43. 6/6/78 '1500 -1500 0
- 44. 6/7/78 0330 0330 0
- 45. -6/8/78 0620 0620 0
- 46. '6/8/78 ^ 1930 1925 5
. 47. 6/9/78 1440 1440 0
- 48. 6/9/78 1230 1230 0
- 49. .6/9/78 0500 0500 0
- 50. 6/11/78 0755 0750 5
- 51. 6/11/78 0838 0830 8
- 52. 6/11/78 1000 0952 0
- 53. 6/11/78 1055 1050 5
- 54. 6/11/78 1125 1120 5
- 55. 6/12/78 1035 1035 1
- 56. 6/13/78 1110 1055 15
- 57. 6/13/78 1848 1835 13
- 58. 6/14/78 1140 1133 7
- 59. 6/14/78 1325 1315 10
- 60. 6/14/78 1615 1555 20
- 61. 6/14/78 1730 1720 10
- 62. 6/15/78 0845 0840 5
- 63. 6/15/78 1812 1807 5
- 64. 6/15/78 2000 1955 5
- 65. 6/15/78 2131 2113 18
- 66. 6/16/78 0840 0840 0
- 67. 6/16/78 1752 1745 7
- 68. 6/17/78 0200 0155 5
- 69. 6/17/78 1225 1220 5
- 70. 6/17/78 2005 2000 5
- 71. 6/18/78 1500 1455 5
- 72. 6/19/76 0445 0446 -1
- 73. 6/19/78 1105 1055 10
- 74. 6/19/78 1735 1727 8
- 75. 6/19/78 2040 2030 10
- 76. 6/20/78 0632 0625 7
- 77. 6/20/78 2029 2015 14
- 78. 6/20/78 1530 1520 10
- 79. 6/21/78 0030 0032 -2
- 80. 6/21/78 0200 0152 8
- 81. 6/21/78 0325 0315 10
- 82. 6/21/78 0450 0440 10
- 83. 6/21/78 0730 0710 20
- 84. 6/21/78 0900 0832 28
- 85. 6/21/78 1100 1040 20
- 86. 6/21/78 1315 1240 35
- 87. 6/21/78 1415 1350 25
- 88. 6/21/78 1620 1620 0
- 89. 7/1/78 0740 0705 35 1
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r-44b Time No. Date CR0 Chart A, min.
- 90. 7/3/78 2225 2215- 10
- 91. 7/5/78 0730 0722 8
- 92. 7/5/78 1815 1810 5
- 93. 7/7/78 0445 0440 5 i
- 94. 8/6/78 1535 1535 0
- 95. 8/7/78 0345 0345 0
- 96. 8/9/78 1600 1608 -8
- 97. 8/9/78 1859 1905 -6 l 98. 8/10/78 2335 2335 0 l 99. S/11/78 2330 2330 0
- 100. 8/12/78 0042 0050 -8 l 101. 8/12/78 2313 2314 -1 102. 8/13/78 2315 2320 -5 l
103. 8/14/78 0507 0510 -3 104. 8/14/78 2315 2320 -5 105. 8/15/78 0610 0610 0 i 106. 8/15/78 2310 2310 0 l 107. 8/16/78 0801 0735 26 l 108. 8/16/78 1115 1115 0 l 109. 8/16/78 2320 2320 0 j 110. 8/17/78 0615 0615 0 l 111. 8/18/78 1955 1950 5 l 112. 8/20/78 0015 0032 -17 113. 8/20/78 0910 0917 -7 114. 8/22/78 0700 0700 0 115, 8/24/78 0815 0815 0 116. 8/26/78 0142 0140 2 117. 8/28/78 1600 1550 10 118. 8/30/78 0355 0345 10 119. 9/1/78 0032 0027 5 120. 9/2/78 0725 0710 15 121. 9/2/78 1947 1940 7 l 122. 9/3/78 2240 2235 5 123, 9/4/78 0830 0828 2 124. 9/4/78 1520 1516 4 125. 9/5/78 1945 1940 5 126. 9/7/78 2015 2005 10 127. 9/9/78 0050 0050 0 1
128, 9/9/78 0715 0705 10 129. 9.9/78 1830 1825 5 130. 9/10/78 0557 0550 7 l
131. 9/10/78 2245 2240 5 132. 9/12/78 0530 0528 2 133. 9/12/78 1715 1710 5 134, 9/13/78 0300 0330 -30 135. 9/13/78 2035 2035 0 136. 9/16/78 0240 0238 2 l
i L
44c Time No. Date CR0 Chart A, min.
137. 9/16/78 2345 2345 0 138. 7/18/83 0030 0032 -2 139. 7/18/78 2147 2143 4 140. 9/19/78 2315 2308' 7 141. 9/20/78 1435 1435 0 142. 9/20/78 2345 2343 2 143. 9/21/78 1501 1455 6 144. 9/27/78 0725 0715 10 145. 0/27/78 2142 2125 17 146. 9/29/78 0740 0715 25 147. 9/30/78 1915 1900 15 148. 10/3/78 0125 0115 10 149. 10/4/78 2140 2135 5 150. 10/5/78 0800 0755 5 151. 10/5/78 2215 2215 0 152. 10/7/78 2330 2335 -5 153. 10/8/78 1425 1430 -5 154. 10/8/78 1940 1950 -10 4 155. 10/9/78 0035 0050 -15 156. 10/10/78 1122 1140 -18 157. 10/12/78 1820 1855 -35 158. 10/13/78 0605 0635 -20 159. 10/15/78 0405 0400 5 160. 10/15/78 2145 2140 5 161. 10/15/78 2226 2221 5 162. 10/17/78 1503 1455 8 163. 10/17/78 1902 1850 12 164. 10/17/78 2237 2233 4 165. 10/18/78 1350 1340 10 166. 10/18/78 2015 2015 0 167. 10/19/78 0859 0850 9 168. 10/19/78 2330 2325 5 169. 10/22/78 2305 2308 -3 170. 10/23/78 0220 0215 5 171. 10/24/78 2340 2339 1 172. 10/25/78 2130 2125 5 173. 10/25/78 1556 1540 16
, 174. 10/27/78 0100 0100 0 175. 10/27/78 0844 0843 1 176. 10/28/78 1859 1853 6 177. 11/3/78 2205 2200 5 178. 11/5/78 1520 1510 10 179, 11/6/78 0530 0520 10 180. 11/6/78 1935 1925 10 181. 11/7/78 1530 1518 12 182. 11/8/78 1352 1338 14 183. 11/9/78 0409 0358 11
r= ,
44d Time No. Date CR0 Chart A, min.
184. 11/9/78 1345- 1335 10 185. 11/12/78 1415 1402 13 11/13/78 2025 2020 5-186.
187. 11/13/78 0100 0052 8 2145 2140 5 188. 11/14/78 189. 11/15/78 1553 1542 11 1810 1805 5 190. 11/15/78 191. 11/17/78 0645 0638 7 192. 11/18/78 0315 0305 10 193. 11/16/7e 1437 1410 19 194. 11/19/78 0408 0357 11 11/19/78 '2110 2105 5 195.
11/20/78 0813 0810 3 196.
11/20/78 1015 1013 2 197.
198. 11/21/78 0120 0105 15 199. 11/22/78 0520 0505 15 200. 11/23/78 0610 0600 10 201. 11/23/78 2350 2350 0 202. 11/27/78 2220 2220 0 203. 11/28/78 1400 1400 0 204. 11/30/78 1300 1330 -30 205. 12/1/78 0424 0458 -34 206. 12/2/78 1145 1220 -35 207. 12/5/78 1132 1123 9 208. 12/7/78 0520 0508 12 209. 12/7/78 2332 2330 2 210. 12/9/78 1415 1403 12 211. 12/10/78 2220 2230 -10 212. 12/11/78 1000 1008 -8 213. 12/13/78 1110 1130 -20 214. 12/13/78 1858 1915 -17 215. 12/15/78 0504 0528 -24 216. 12/16/78 0540 0546 -6 217. 12/16/78 1805 1813 -8 218. 12/18/78 0430 0430 0 219. 12/18/78 2130 2135 -5 220. 12/19/78 1330 1335 -5 221. 12/23/78 0350 0350 0 222. 12/23/78 1245 1255 -10 223. 12/23/78 2345 2348 -3 224. 12/25/78 2145 2145 0 225, 12/26/78 0035 0035 0 226. 12/27/78 0900 0850 10 227, 12/28/78 1950 1947 3 12/28/78 2335 2330 5 228.
12/29/78 0730 0723 7 229.
230. 12/29/78 2230 2220 10
44e Time No. Date CR0 Chart A, min.
231. 1/5/79 0807 0740 -27 232. 1/6/79 0915 0917 -2 233. 1/8/79 0900 0908 -8 234. 1/8/79 1905 1914 -9 235. 1/9/79 1625 1630 -5 236. 1/10/79 0750 0743 7 237. 1/11/79 0701 0735 -34 238. 1/11/79 1745 1738 7 239. 1/12/79 1437 1425 12 240. 1/13/73 1000 1538 12 241. 1/14/79 0940 0930 10 242. 1/15/79 0417 0408 9 243. 1/16/79 1800 1750 10 244. 1/20/79 1520 1512 8 245. 1/21/79 2330' 2323 7 246. 1/21/79 2350 2340 10 247. 1/23/79 2115 .2108 7 248. 1/24/79 1641 1532 9 249. 1/27/79 0335 0408 -33 250. 1/28/79 0623 0640 -17 251. 1/29/79 1620 1655 -35 252. 1/30/79 1930 1945 -15 253. 2/2/79 0210 0205 5 254. 2/3/79 0830 0820 10 255. 2/4/79 0508 0517 -9 256. 2/5/79 0350 0342 8 257. 2/5/79 2335 2330 5 258. 2/6/79 2205 2215 -10 259. 2/7/79 0510 0515 -10 260. 2/9/79 0315 0305 10 261. 2/10/79 1930 1943 -13 262. 2/13/79 1040 1043 -3 263. 2/14/79 1325 1315 10 264. 2/15/79 1745 1738 7
ATTACHMENT D COMPUTER PROGRAM LISTING OF RCS LEAK RATE CALCULATION l
l I
O
_ 7 --
Document Nare:
MEMO FOR CHRISTOPHER Requestor's ID:
.OPR3 Author's Name:
.KIRKPATRICK-Document Comments:
Please print for T. Martin and K Christopher Destination Name:
LEADOP Notes:
Comments Distribution Ne.T.a; NRCIE_J0YCE_1421 Addressee:
Chris i
MEMORANDUM FOR: R. Keith Christopher, Director Office of Investigation Field Office, Region I FROM: Donald C. Kirkpatrick, Nuclear Engineer '
Engineering and Generic Communications Branch Divistcr. cf D::crgcr.cy Prcperedncss and Engineering Response Office of Inspection and Enforcement *
SUBJECT:
REVIEW AND COMMENTS ON NRC REGION I INSPECTION REPORT 50-289/83-20 The subject document, dealing with reactor coolant system (RCS) leak rate testing at TMI Unit 1, was reviewed as you requested. The copies of strip charts, leak rate test records, and operator logs, provided in support of the i report, were analyzed and compared in detail. The results provided in the i subject inspection report were compared to the results of the investigation of allegations of leak rate test falsification at TMI Unit 2. In addition, the l
inspection results have been discussed with T. Martin and Dr. Chung. As a result, Dr. Chung wrote a revision to the inspection report (Draft Rev.
to IR 50-289/83-20 dated February 22,1984), which was also reviewed.
l In my view, the findings of the inspection are not indicative of a consistent pattern of falsification of RCS leak rates at TMI Unit 1, although they do identify many procedural inadequacies. Of the 39 sets of test records pro-vided, there were only two in which the intervention was effective in reducing an excessive measured leak rate to an acceptable value. These two tests l represent a very small fraction of the over 720 tests reported during the time
! period examined. There were 10 other tests that did have an appreciable impact on the calulated leak rate. Even if all 12 of these tests are considered suspicious, this still represents less than 2% of the 720 RCS leak rate tests conducted. '
For a majority of the data sets reviewed, the apparent manipulation, although procedurally improper, had little effect on the leak rate test results. Due to a number of differences that existed between the situations on Unit 1 and Unit 2, there was much less motivation to falsify the leak rate test results for Unit 1. The reasons for these conclusions are detailed in the following sections.
Differences in Approach Between the Inspection Report and This Review The inspection report properly focused on the procedural inadequacies in '
l RCS leak rate testing at TMI Unit 1. This review, however, focused on the more narrow question of whether these inadequacies were indicative
- of a consistent pattern of falsification of leak rates for TMI Unit 1. As
F i R. Keith Christoper a result, there were some differences in the approach to the analysis of the data on leak rate testing. For example, the author of this memo tended to apply stricter criteria when attempting to answer the question of whether the indications on the makeup tank strip charts represented attempts by the operators to influence the results of the leak rate tests. In order to be objective, the author did independent calculations of the effects of the identified manipulations on the test results. However, the makeup strip chart traces from which these effects were determined, frequently included many purturbations caused by plant oscillations or other operational occurrences which tended to obscure the effects of the manipulations. Generally, the makeup tank level changed caused by the manipulations could only be measured with confidence to the nearest half inch or more. It is to be expected, therefore, that tie eut!.ar said sometiaea errive at a different value for these effects than those reported in the inspection report. Despite these differences in approach, most of the items appearing in Tables 1, 3, and 4 dealing with the manipulations are consistent with the corresponding items in the tables in the revised inspection report. Where differences do appear, they generally involve only the magnitude of the effect on the test result.
Although few apparent attempts to effect the test results were identified by the review, it is clear in most cases, that the identified manipulations were procedural violations that compromised or invalidated the test results.
Hydrogen Additions For a hydrogen addition to be effective, the hydrogen must be added toward the end of the test. This is due to the bi-stable nature of the water slug in the " dry" leg of the level measuring system. As discussed in Section 4.2 of the inspection report, it takes only a .036 pst increase in makeup tank pressure to cause a one-inch positive error (rise) in the indicated water level. This effect, however, is limited by the height of the existing slug (the largest such error identified is about four-inches). This effect is l diagrammed in Figure 1. A small decrease in tank pressure has the opposite effect, causing a negative error (drop) in the indicated water level. This is also limited by the slug height (Figure 2). Any actual reduction in makeup tank level, such as that caused by RCS leakage, also causes a reduction in pressure. The result is, that any positive level error caused by a hydrogen addition is dissipated as the tank level resumes its usual downward trend.
Analysis of the hydrogen addition indications shows that, under average conditions, the effect of the addition is reversed in about 30 minutes to an hour. This effect is confirmed both by review of the hydrogen addition indications on the makeup tank strip charts, and by the testimony of M. S.
Colman, taken during Unit 2 operator interviews, in which he stated that hydrogen only had the desired result when it was added just before the computer read the results.
The data sets on hydrogen additions, provided in Attachment B to the inspec-tion report, were examined in relation to the effect described above. The results are summarized in Table 1, and detailed in the following paragraphs.
The values for the timing of the trace shift from the end of the test, and the deviation of the level at the end of the test, are based on the corrected chart times discussed in Section 3.5 of the revised inspection report. (Note, i
R. Keith Christopher the hydrogen additions for September 8, 1978 and September 19, 1978 in the original inspection report have been deleted from this section.)
Six of the addition indications, those of August 8, 1978, August 30, 1978, August 31, 1978, January 6,1979, February 2,1979, and February 3,1979 occur 32 minutes or longer before the end of the test period and had either a small effect or no effect on the test results. Although the hydrogen addition on January 6, 1979 is listed in Table 1 as having no effect, this test also had a water addition that did have an effect on the test results. This is discussed with the other water additions below.
The additions of October 2, 1978 and November 7, 1978 were made toward the end of the tut,10 end 20 minutes frca thc cnd rc:pcctivcly, but had unusually rapid shift reversals and so had small effects also.
The addition of September 18, 1978 was also made 15 minutes from the end of the test. However, it followed an unexplained short rapid level decrease earlier in the test, which largely offset the effect of the addition. As a result, there was little deviation of the makeup tank level trace at the end of the test from the long-term slope of the trace. Therefore, the addition had little effect en the test results.
The additions of November 12, 1978 and January 11, 1979 were made 10 minutes from the end of the test and had a relatively large effect. However, the addition effect had originally resulted in the calculation of negative uniden-tified leak rates for these tests, so that the corrected results were still well within the allowable limits.
A comparison of the makeup tank levels from the computer test printout with those on the strip chart, shows that the indication of December 18, 1978 occurred shortly before the beginning of the test period. The test sheet shows that the tank level dropped one and a half inches during the test. If the test had started before the level shift, there would have been a rise of about this magnitude instead. Due to the shift reversal effect described above, any error caused by a hydrogen addition starting before the test, would tend to result in an increase in the derived leak rate.
There are several things to indicate that the hydrogen additions were not generally made in order to reduce the derived leak rates. In the first place, most of them were not made near the end of the test period, and for the reasons discussed above, would not be expected to be very effective in reducing the calculated leak rates. Secondly, all of them were done during test periods when the actual leak rates were quite low and there would have been no reason to attempt to reduce the test result. For all of these tests the gross leak rate was determined independently from the slope of the level trace on the associated makeup tank strip chart. These are also shown in Table 1. The maximum gross leak rate was 0.57 gpm and the average was 0.29 gpm.
The possibility that the hydrogen indications were made at random, as a result of normal plant operations was considered. If this were the case, similar indications caused during non-test periods should appear on the strip charts.
With this possibility in mind, all of the strip chart copies provided in the
R. Keith Christopher attachments to the inspection report were searched for such indications.
Three level trace purturbations having similar characteristics to known hydro-gen additions were identified. Their dates and times are listed in Table 2.
None of these additions occurred during known RCS leak test periods. These additions would tend to support the claims of the operators, made during 01 interviews, that the hydrogen additions were made for legitimate operational reasons.
Water Additions The 15 data sets on water additions, provided in Attachment C of inspection report, were also reviewed to determine the effect of the indicated manipulatic ,
on the result: cf the te:ts. The rc: ult: src :u=:rt:cd in T:bic 3. (Note:
the water additions for June 11, 1978, August 31, 1978, and November 7, 1978, in the original inspection report, have been deleted from this section.)
Six of the water additions appear to have significantly reduced the measured leak rates. In each of these, the original unidentified leak rate calculated by the computer had a large magnitude negative value. In each of these cases also, there was a large discrepancy between the computer calculated gross leak rate and the gross leak rate derived from the makeup tank level trace slope.
The first three of these tests, the two on April 30, 1978, and the one on May 26, 1918, have makeup tank level traces showing the rapid rise characteristic of the usual water addition. In two of these three cases, the unidentifed leak rates, corrected for the water addition, exceeded the allowable 1 gpm technical specification limit. The April 30, 1978 test, conducted at 1532 hrs., had a corrected leak rate of 1.92 gpm and the May 26, 1978 test had a corrected value of 1.45 gpm.
The last three of these six tests, done on September 8, 1978, September 11, 1978, and October 17, 1978, were classified by the reviewer as possible water additions because the makeup tank level traces do not exhibit the sharp rise of the characteristic water addition. Their classification as water additions are based on a combination of circumstances, such as an unusually large pur-turbation of the trace and the discrepancy in gross leak rates described above. It is possible that these are " jogged" additions, that is, water additions made in many small increments to hide the addition.
For the tests conducted on September 15, 1978, September 18, 1978, and January 18, 1979, the makeup tank level trace shows neither sharp rise nor significant difference in the levels at the beginning and end of the tests. The purtur-bations appearing in the trace during the test are similar to other pur~tur-bations on the same chart and could be caused by normal plant oscillations.
Regardless of their cause, they do not appear to have had a significant effect on the test outcome. While these indications are significant enough to raise questions as to the validity of the tests, they do not appear indicative of attempts to falsify the test results.
The water addition indications of May 12, 1978 and December 13, 1978 are corroborated by long-term shifts in the makeup tank level trace of five-inches
R. Keith Christopher and eight-inches. These shifts are indicative of water additions of 1250 lbs.
and 2000 lbs. respectively, and resulted in the calculation by the computer of large negative losses (meaning water was added) to the RCS. However, in both of these cases a drop of comparable magnitude was recorded in the drain tank levels during the test. This is physically impossible unless the drain tank was pumped out during the test. These anomalies cancel each other out in the calculation of the unidentified leak rates so as to produce correct results. A logical explanation is, that water was pumped directly from the drain tank to the makeup tank during these tests, and the operators failed to account for the manipulation by entry into the computer. All of the leak rates, calculated during these two tests, were corrected for this error.
These recalculated results were all still within the allowable limits. Since nothing could have been gained by the:c manipulations, they do not appear to be attempts to falsify the test results.
The unusual flattening of the makeup tank slope, appearing on the strip chart about an half hour before the end of the test on June 21, 1978 was also analyzed.
The control room log entries indicate that a problem existed with the "C" reactor coolant pump seal, causing an unusually high leak rate from the reactor coolant system. This leak rate could be determined independently of the computer calculation, from the average of the unpurturbed slopes on the MUT st ri,) chart, and the sum of the water additions recorded in the control room operator's log. The change in the makeup tank level of 5.5-inches, also derived from the printout, is also consistent with this leak rate. It is concluded that, regardless of its cause, the flattening does not appear to have had a signficant effect on the test results.
In the test of August 29, 1978, the water addition indication appears on the makeup tank strip chart at a time closely corresponding to the beginning of the leak rate test. A comparison of the level slope on the strip chart with the makeup tank level change derived from the test sheet shows that the addition was made before the acquisition of the first data set. If the shift had occurred before the beginning of the test, the makeup tank level recorded by the test sheet would have shown a rise rather than the small decrease actually recorded. Due to the dissipation of the slug effect, discussed under the hydrogen additions, any residual effect from this water addition would have tended to increase the calculated leak rate.
The Control Room Operator's Log records that 300 gallons of water were added to the reactor during the test of January 6,1978. As indicated in the inspec-tion report (Section 5.1), this amount was entered into the computer calcula-tion. This test extended for four hour period during which hydrogen additions and a feed and bleed were performed also. The initial sharp rise of more than 11-inches was followed by a one-inch reduction, which may be the dis-sipation of an overshoot caused by the familiar water slug effect. This event is followed by a gradual five-inch rise and equal fall occurring over the next half hour, which appears to be related to a feed and bleed. During this half hour period, one or more hydrogen additions were also made. The feed and bleed and hydrogen addition do not appear to have had any effect on the test results.
They did not result in level changes and were over before the end of the test.
The long-term shift in the level trace was measured by approximating the level I
R. Keith Christopher traces before and after the water addition with a straight line. This shift was about 10-inches. Since both the initial rise and the long-term shift are consistent with a 300 gallon addition, the operator's entry of this amount into the computer appears to be correct. Due to the failure of the computer program to account for the expansion of the water in the RCS, this addition would have resulted in a reduction in the calculated leak rate of about 0.5 gpm.
However, this was an error in the computer calculation that was probably unkown
.to the operators at that time and would not represent an attempt to manipulate the leak rate.
The tests on April 30, 1978 and May 26, 1978 were the only cases, of all of the tests reviewed, for which the corrected leak rate values, exceeded the technical specification limits. These two tests and the test on June 21, 1978, which involved the failed pump seal, were the only tests for which a relatively high leak rate existed. For the remaining tests, the gross leak rate derived from the makeup tank slope averaged only 0.43 gpm.
Feed and Bleed Operations Feed and bleed operations are usually done to reduce the RCS boron concentra-tion and the amount of coolant removed is rormally equal to the amount added.
Doing this during a test would tend to reduce the accuracy of the leak rate test. However, it would not be an effective means of reducing the measured leak rate unless the amount of coolant added exceeded the amount removed.
The 13 data sets on feed and bleed operations, provided in Attachment C of tha inspection report, were each examined to determine if a long-term shift existed in the slope of the level trace, that would indicate that the manipulation had an effect on the results of the tests. The results are summarized in Table 4.
(Note: the feed and bleed tests for May 30, 1978, August 5, 1978, September 15, 1978, November 12, 1978, and the three tests on November 24, 1978, in the original inspection report, have been deleted from this section.)
In four of these tests, those for May 13,1978, July 2,1978, November 20, 1978, and November 28, 1978, the water additions were about equal to the removals and so had no significant effect on the test results.
The long-term level shift could not be determined for the test on June 11, 1978 because of numerous water additions made near to the test period. However, the gross leak rate calculated by the computer was larger than the gross leak rate independently derived for the same time frame from the slope of the makeup tank level trace. From this it is concluded that the effect of the feed and bleed, if any, was in the conservative direction of increasing the measured leak rates.
For the test on September 17, 1978, there was an unusually large decrease appearing on the makeup tank level trace during the test. As with the pre-vious test, if there was any effect from a feed and bleed operation, it was to incrase the leak rate, which would have been in the conservative direction.
This test did result in a somewhat higher than average leak rate, but it was
R. Keith Christopher still within the allowable limit. The effect of the feed and bleed is listed as zero for these last two tests, because although it was not definitely deter-mined, it was conservative.
During the tests of November 13, 1978 and January 9, 1979, feed and bleed operations were apparently started during the tests and completed after the end of the tests. A control room log entry reports that a feed and bleed operation was completed during the period of the November 13 test, however, the strip chart shows the makeup tank level rising during the test and still dropping at a high rate after the last data set was taken. No feed and bleed entry appears in the log for the January 9 test period, but the strip chart shows the risa and fall characteristic of many feed and bleed operations, with most of the fall occurring after the completion of the test. Thcss operations had the effect of reducing the leak rates by 0.69 gpm and 0.49 gpm for the November 13 and January 9 tests, respectively.
During the tests of May 3,1978 and November 21, 1978, it appears that the test may have started during a feed and bleed operation in which the quantity of RCS water was decreased prior to the test and increased up to a former level during the test. The effect wat, to decrease the leak rates for these tests by 1.38 gpm and 1.07 gpm, respectively.
These last four tests were the only tests of those with indications of feed and bleed operations where there appeared to be definite evidence the operation reduced the measured leak rate. However, none of the corrected leak rates exceeded the allowable limits because these errors had caused the originally calculated leak rates to have large negative values.
For the test conducted on May 12, 1978, the purturbations appearing in the trace during the test are similar to many other purturbations on the same chart and could be caused by normal plant oscillations. It is not likely that all of these oscillations would be feed and bleed operations. As dis-cussed before, feed and bleed operations are normally done to reduce the RCS boron concentration. However, the operator's log for May 12 shows that the boron concentration remained constant during the shift in which the test was performed.
The effects of the feed and bleed operations for the tests on September 22, 1978 and November 16, 1978 were obscured by the numerous operations that were conducted near that time period. On September 22, the plant had previously undergone a power transient and plant operations had apparently not yet become completely stab 11 zed. The test on November 16 was conducted during a power increase. The Technical Specifications normally require leak rate testing only during perids of stable operation.
To summarize the effects of the feed and bleed operations on the test, only four could be shown to reduce the measured leak rates for the effected tests.
The corrected leak rates for these four were all within the allcwable lisaits.
With these tests also, there appeared to be no motivation to falsify the test results, as the gross leak rates derived from the makeup tank slopes averaged
r R. Keith Christopher quite low. Even though many of the feed and bleed operations could not be shown to have reduced the leak rates, they were contrary to the procedure and, as indicated in the inspection report, the effected tests should be considered to oe-invalid.
Differences Between Unit 1 and Unit 2 A number of differences existed between Unit I and Unit 2 in the RCS leak rete test area, that resulted in significantly less motivation for test falsification on Unit 1. These involve both a more accurate measurement capability and less restrictive leakage requirements on Unit 1.
The overriding error that caused the greatest problem to the Unit 2 operators, was the use of the wrong water density in the computer calculation of the identified leakage collected in the reactor coolant drain tank. For Unit 2, the gross leakage (the sum of the RCS losses) was calculated in pounds of mass and converted to gallons using the' average density, about 6 lbs/ gallon, of the high temperature RCS water.* The identified leakage, however, was the increase in gallons, at ambient temperature, in the drain tank (8.31 lb:/ gallon at 80 F). Since the unidentified leakage was the difference between these two values, the existence of any identified leakage always resulted in calculation of an amount of unidentified leakage which was too high. In fact, any time the identified leakage exceeded about 2.5 gpm, the computer should theoretically have calculated an unidentified leakage inexcess of the allowable 1 gpm limit, even if the actual unidentified leakage was zero. For the majority of the time, during the last four months of operation prior to the accident, the identified leakage from Unit 2 did exceed 2.5 gpm.
The decrepency in the density calculations did not exist in the TMI 1 calulational procedure. The TMI leak rate test procedures and computer programs provide some insight into how this difference came about. Unit I control room instrumentation provided information on the quantity of water in the reactor coolant drain tank in the form of level detector output voltages. During the time period covered by the subject inspection, these voltages were taken automatically by the computer data acquisition system and used by the computer program to calculate drain tank inventory changes. Specifically, the mass change in pounds was calculated by taking the differences between the final and initial drain tank voltages and multiplying by the factor of 3540 lbs/ volt.
(Second page of computer program, Attachment D). This quantity was then converted to gallons using the same factor (.1674 gallons /lb at 580.4 F) used to convert RCS losses to gallons. The use of a constant value to convert tank level values to mass was possible because the Unit I tank was in the form of a vertical right circular cylinder having a cross sectional area that does not vary with the water depth.
- Specifically, the computer multiplied the mass in pounds by the reciprocal of the density, 0.1674 gallon /lb at 580.4*F.
R. Keith Christopher' The Unit 2 computer program was adapted from the Unit 1 program with few changes.
However, the Unit 1 method of calculating drain tank quantities could not be used because Unit 2 has a circular tank having a horizontal centerline and, consequently, a cross sectional area that varies with water depth. Another difference was that the Unit 2 instrumentation provided drain tank levels measured in inches of depth. The new programmer (the original person had left) incorporated an existing table of tank volume in gallons versus inches of depth into the computer program. An existing interpolation routine was used with this table to determine the quantity of tank water in gallons.
Since the programmer already had the tank quantities in gallons and was .
apparently unaware of the density inconsistency, he used the change in drain tank gallons directly in the calculation, ignoring the original factor for Conversion of In&hs I.u 96llOhb.
- A feature of the computer program, common to both units, was a table of temperature versus RCS density that extended no higher than 582*F. This table was used in calculating the correction to the RCS water inventory for the effect of density changes. This was not a problem for Unit I because the average RCS temperatue practically never exceeded 582 F. However, Unit 2 operated at a higher temperature and for about a third of the tests reviewed, one or both of the data sets had an average RCS temperature that exceeded 582 F. When this occurred, the computer used a density based on the 582'F table limit. Thus, if the reactor was operating above 582'F at the beginning or end of the test, any temperature change was not properly accounted for by the computer code. This deficiency introduced an error of the order of I gpm into the results of those tests which exceeded 582'F.
The Technical specification requirements for both unity are summarized in Table 5. The Unit I technical specification limits for RCS leak rates were less restrictive than those for Unit 2 due to two significant differences. The first of these was paragraph 3.1.6.6 (Unit 1 TS) which said, in effect, that RCS losses to certain connecting system, such as the reactor coolant drain tank were not to be considered leakage, and that such losses when added leakage could be as high as 30 gpm. For Unit 2, (and most other PWR plants) leakage to the drain tank (also known as the Pressuizer relief tank or quench tank) is considered to be identified leakage which has a limit of 10 gpm.
The second important difference is that the Unit I technical specifications have an allowance for evaporative losses (par. 3.1.6.2), which Unit 2 does not. The evaporative losses were measured during hot functional testing and fixed at 0.51 gpm. This allowance is one of the values goes into the calcu-lation of the unidentified leakage before the I gpm limit is applied. This evaporative loss allowance would not be expected to remain constant, and is probably too high, as it results in the calculation of a high percentage of negative leak rates. This treatment of the evaporative loss allowance is common to other older B&W plants, but is not included in standard technical specifications, such as those for Unit 2.
A final significant difference between Unit 1 and Unit 2, is that Unit I had lower actual leak rates, and could tolerate a larger measurement error before calculating an unacceptably high value. The water losses from Unit 1 RCS (called leakage plus losses by the Unit 1 procedure) were determined
R. Keith Christopher independently of the computer calculation, by measuring the slopes of unpur-turbed level traces on the makeup tank strip charts. This method neglects RCS water mass changes due to temperature, pressure, and pressurizer changes.
However, these changes do not have a very significant effect on the leak rate when averaged ever the several hour long periods represented by the traces used in the determinations. The RCS leak rates were determined by this means for most of the strip charts in Attachments A, B, and C of the inspection
- report. The results are included in Tables 1, 3, and 4. The highest of these values was 4.34 gpm on June 21, 1978 and was associated with the failed pump seal on that day. These values were about 1.64 gpm for the tests of April 30, 1978 and May 26, 1978, which had the high corrected unidentified leak rates.
These three values were high compared to those for the othar tests, but well within the 30 gpm Technical Specificatien li=tt for this ic:k rate. For the remaining tests, the highest value was 1 gpm and the average was 0.41 gpm.
The TMI-1 computer calculation derives the unidentified leak rate from the gross leak rate by subtracting the identified leakage (which averages .1 gpm) and a constant 0.23 gpm value that includes the evaporative losses. If these values were also applied to the independently determined gross leak rate. The resulting unidentified leak rate would be only about 0.1 gpm.
Conclusions The findings of the inspection are not indicative of a consistent pattern of falsification of RCS leak rates at TMI Unit 1, although they do identify many procedural inadequacies. Of the 39 sets of test records provided, there were only two in which the intervention was effective in reducing an excessive leak rate to a calculated value that was within limits. There were 10 other instances (2 hydrogen additions, 4 water additions, and 4 feed and bleed operations) that had a significant impact on the unidentified leakage calculated by the TMI-1 computer program. Most of the manipulations that were effective in reducing the measured leak rates had caused large negative leak rates to be calculated so that the corrected leak rates were still within the allowable limits.
For the remaining data sets reviewed, the apparent manipulation, although procedurally improper, had little effect on the leak rate test results. If all 12 instances that resulted in an appreciable change in the calculated leak rate are assumed to be significant, this represents only a very small fraction of the over 720 leak rate tests reported during the time period examined.
Therefore, I do not conclude that the results show a consistent pattern of falsification of RCS leak rates at TMI Unit 1.
R. Keith Christopher A number of differences existed between the situations on Unit I and Unit 2 relative to RCS leak rate testing. These include that Unit I had more accurate computer calculations, less restrictive technical specifications, and lower actual leak rates. For these reasons the Unit 1 operators were much less likely to encounter unacceptable test results than were the Unit 2 operators.
As a result, there was no obvious motivation for falsification of the Unit I tests, such as existed for Unit 2.
Donald C. Kirkpatrick, Nuclear Engineer Engineering and Genwric Communications Branch Division of Emergency Preparedness and Engineering Response, IE
Enclosures:
- 1. Table 1
- 2. Table 2
- 3. Table 3
, 4. Table 4
- 5. Figure 1
- 6. Figure 2
- 7. Table 5 l
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3cete 1
, Effect of Hydrogen Addition Indications on Test Results DATE TIME RCS LEAK RATES (gpm) CorNENT EFFECT ORI GIPML LNID LR OROSS LR AT END COMPUTED CORRECTED FROM MUT OF TEST UNID LR BY EFFECT LVL TRACE 38/08/78 0735 0.34 -0.11 0.23 0.29 Added 45 minutes !
M from end of test.
38/30/78 1952 0.28 0.10 0.38 0.29 Added 5 nutes d 4 f rom encs of t e s t . A[
38/31/78 0801 36 0.34 -0.41 -0.0 0.21 0 dI Adde d 32 'mi nu t e s / w+ ' 3 from end of testl /
39/18/78 2355 0.39 0.40 0.79 0.14 Added 15 minutes from end of test.
10/02/78 1645 0.29 0.03 0.32 0.36 Added 20 minutes from end of test.
11/07/78 1608 0.28 0.04 0.32 0.21 Added 15 minutes fr'om end of test.
31/12/78 0816 0.69 -0.20 0.49 0.57 Added to minutes from end of test.
B2/18/78 0830 0.00 0.52 0.52 -
0.36 Shift occurred before beginning of test.
31/06/79 0756 0.00 -0.59 -0.59 M- 1 1 19' - Lif 0.36 Added 2 Hr). from end.
AM# See water additions.
31/11/79 1606 1.38 -0.62 0.76 V 0.21 Added 10 minutes from end of test.
32/02/79 1600 0.34 0.33 v C2't4p' 0.67 0.21 Added 53 minutes from end of test.
tt /
p2/03/791615 0.00 0.47 0.47 0.29 Added 50 minutes c f/ 3 t. from end of test.
l l
4'
Table 2 Hydrogen Addi tion Indications Occurring Outside of Leak Rate Test Periods DATE TIME EFFECT OF TIME UNTIL INDI CATI ONS TRACE RETURNS ON LEVEL TO ORIGINAL TRACE (IN) SLOPE (MIN) 0 II 08/05/78 0735 2.5 25 09/15/78 0718 3.0 30 11/13/76 0812 2.5 30 9
4 4
9 4
e
TOD10 3 Effect of Water Addition Indications on Test Results DATE TIME RCS LEAK RATES (9pm) COMMENT EFFECT OR10!NAL UNID LR GROSS LR AT END COMPUTED CORRECTED FROM MUT OF TEST UNID LR SY EFFECT LVL TRACE d
'04/30/78 1532 3.78 -1.86 1.92 1.64 Unidentified LR tased on MUT level trace =1.58gpm L-
.'04/30/78 2321 1.38 -0.97 0.41* 0.57 Unidentified LR based on c V'I MUT level trace =0.19 9 pm 05/12/78 1643 0.00 ,-0.74 -0.74
'O 0.50 Lar ge drop in RCDT level shows RCDT pumped to MUT 05/26/78 1656 2.20 -0.75 1.45 1.64 Unidentified LR based on MUT level trace =1.08 06/21/78 0341 0.00 0.94 0.94 /, f3 4.34 4.13gpm Gross LR fm test matches MUT trace slope.
08/29/78 1547 0.00 0.16 0.16 0.2y'j 0.14 Shift occurred before
, / beginning of test.
09/09/78 1629 1.38 -0.58 0 . 80 L' O.50 Possible addition.ULR fm MUT level trace =0.27 9 pm 09/11/78 1827 1.38 -0.60 0 . 78 v/' O.36 Possible addition.ULR fm MUT level trace =0.30gpm
' 09/15/78 0921 0.00 -0.55 -0.55o,yg 0.36 Level changes may be due to normal oscillations.
09/18/78 2035 0.00 -0.43 -0.43c.6 0.14 Level changes may be due to normal oscillations.
10/17/78 1201 1.30 -0.46 0.92 - O.50 Possible addition.ULR fm MUT level trace =0.179 pm 12/13/78 1842 0.00 -0.22 -0.22og/- 0.64 Large drop in RCDT level shows RCDT pumped to MUT 01/06/79 0756 0.50 -0.59 -0.09,,,99[ 0.36 Level shift consistent w 300g1 computer entry.*
01/18/79 0401 0.00 -0.69 -0.69 0.64 Level changes may be due Orbf to normal oscillations.
o The effect on the leak rate was due to the error in the computer calculation, rather than, inappropriate operator action. The operator corr ec tly entered the 300 gallons into the computer. g, yJ F
Tcb10 4 Effect of Feed and Bleed Indications on Test Results s
DATE TIME RCS LEAK RATES (gpm) COMMENT EFFECT ORIGINAL UNID LR GROSS LR AT END COMPUTED CORRECTED FROM MUT OF TEST UNID LR BY EFFECT LUL TRACE 05/03/78 1822 1.38 -0.77 0.61 k# 1.00 Test started after bleed but before end of feed.
05/12/78 0047 0.00 -0.38 -0.38 h 0.78 Level changes may be due to normal oscillations.
05/13/78 2340 0.00 0.59 0.59 v/ 0.71 Lack of long term effect shows addi t i on= removal .
06/11/78 0804 0.00 0.58 0.58 LI 0.78 F & 8 may have increased
, the measured leak rates.
07/02/78 0256 0.00 0.73 0.73 \/ 0.36 Lack of long term effect shows addition = removal.
09/17/78 0508_ 0.00 0.77 0.77 L/ 0.21 F & 8 may have increased
~ the measured leak rate.
09/22/78 2100 ---
-0.04 --- ---
Effect obscured by many transients & Ivl changes
, 11/13/78 0304 0.69 -0.55 0.14 b/ 0.29 Test ended before completion of bleed.
11/16/78 0426 ---
0.61 -- O'
( ---
Effect of feed & bleed masked by p owe r increase 11/20/78 2110 0.00 0.88 0.88 V! '
Additions = increases.
MUT slope masked by F&8.
g&
11/21/78 0206 1.07 -0.51 0. 'fg -
Test std. after start o bleed before end of F&B.
11/28/78 1653 0.00 -0.35 -0.35 v/ 0.43 Lack of long term effect shows addi t i on= removal .
01/09/79 1936 0.49 -0.30 0.19 h 0.36 Test ended before 00 ;
completion of bleed.
i f
UAMI Tchte S , ,
j Compartson of Teghnical Specificat'lon Leak Rate Limits for TM1 Unit 1 and Unit 2 UNIT 1 >
UNIT 2 TYPE METHOD OF NAME USED TECH SPEC NAME USED TECH SPEC DERIVATION ,
LIMIT LIMIT A sum of RCS leakage plus 30 gpm gross 11 gpm changes losses leakage B rise in losses to 30 gpm identified up to drain tank connecting ileakage 10 gpm systems (b)
C type A minus gross 10 gpm unidentified 1 gpm type B leakage leakage (a)
D speciar identified 10 gpm identified up to measurement leakage leakage 10 ppm (c) (b)
E type C minus unidentitled 1 gpm (not derived) type D minus leakage (d) evaporative losses Notes (a) The unidentified leakage could be reduced by any type D identified leakage, however, this was rarely dotie in practice.
(b) The combined type B and type D identified leakage could not exceed to gpm.
(c) Any RCS losses, not collected in the drain tank, that could be quantified, became identified leakage.
(d) No evaporative loss allowance was permitted for Unit 2.
Figure 1 Makeup Tank Level Measurement Position of water seal during increasing level and pressure, causing the maximum positive error in level measurement.
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Effect of Hydrogen Addition Indications on Test Results DATE TIME RCS LEAK RATES (gpm) C0tt1ENT i EFFECT ORIGINAL LNID LR GROSS LR AT END COMPUTED CORRECTED FROM MUT OF TEST UNID LR BY EFFECT LVL TRACE
)S/08/78 0735 0.34 -0.11 0.23 0.29 Added 45 minutes d from end of test.
<)S/30/78 1952 0.28 0.10 0.38 0.29 Added 57 nutesed Y from end of test. M
')S/31/78 0801 0.34 36
-0.41 -0.0 0.21 Added 32 m'inutes / w + ' ]
O SI from end of testa /,
')P/18/78 2355 0.39 0.40 0.79 0.14 Added 15 Iinutes from end of test.
10/02/78 1645 0.29 0.03 0.32 0.36 Added 20 minutes from end of test.
(1/07/78 1608 0.28 0.04 0.32 0.21 Added 15 minutes fr'om end of test.
J l1/12/78 0816 0.69 -0.20 0.49 0.57 Added 10 minutes from end of test.
12/18/78 0830 0.00 0.52 0.52 -
0.36 Shift occurred before begi nn i rig of test.
01/06/79 0756 0.00 -0.59 -0.'59 M 14li'4-21'S' 0.36 Added 2 Hr. from end.
M , See water additions.
+)1/11/79 1606 1.38 -0.62 0.76 V 0.21 Added 10 minutes from end of test.
02/02/79 1600 0.34 V E'2 & y '
0.33 0.67 0.21 Added 53 minutes from end of test.
C 2.
92/03/79 1615 0.00 0.47 0.47 0.29 Added 50 minutes 0J/3L from end of test.
l l _ _- _- .. --
~
DRMI Table 2 Hydrogen Addition Indications Occurring Outside of Leak Rate Test Periods DATE TIME EFFECT OF TIME Ut4TIL INDICATIONS TRACE RETURNS ON LEVEL TO ORIGINAL TRACE (IN) SLOPE (MIN) 08/05/78 0735 2.5 25 0 l( '
09/15/78 0718 3.0 30 11/13/78 0812 2.5 30 O
9 9
e i
Tcblo 3 Effect of Water Addition. Indications on Test Results DATE TIME RCS LEAK RATES (gpm) COMMENT EFFECT ORIGINAL UNID LR GROSS LR AT END COMPUTED CORRECTED FROM MUT OF TEST UNID LR BY EFFECT LUL TRACE u' )
04/30/78 1532 3.78 -1.86 1.92 1.64 Unidentif ied LR based on MUT level trace =1.58 9 pm L- ,
04/30/78 2321 1.38 -0.97 0.41 ' O.57 Unidentified LR based on ;
o V o/ MUT level trace =0.19 9pm 05/12/78 1643 0.00 -0.74 -0.74 0.50 Lar ge drop in RCDT level 8'O shows RCDT pumped to MUT 05/26/78 1656 2.20 -0.75 1.45 1.64 Unidentified LR based on MUT l evel trace =1.08 06/21/78 0341 0.00 0.94 0.94 /, f3 4.34 4.13gpm Gross LR fm test l 7 matches MUT trace slope. l 2\
08/29/78 1547 0.00 0.16 0.16 c.2gf 0.14 Shift occurred before !
/ beginning of test.
09/08/78 1629 1.38 -0.58 0.80 L/ O.50 Possible addition.ULR fm MUT level trace =0.279 pm 09/11/78 1825 1.38 -0.60 0.78 v# O.36 Possible addition.ULR fm MUT level trace =0.30gpm 09/15/78 0921 0.00 -0.55 -0.55o,yg 0.36 Level changes may be due to normal oscillations.
09/18/78 2035 0.00 -0.43 -0.43 c, {o - 0.14 Level changes may be due to normal oscillations.
10/17/78 1201 1.38 -0.46 0.92 - O.50 Possible addition.ULR fr MUT level trace =0.17 c,m 9 i 12/13/78 1842 0.00 -0.22 -0.22 c,f% 0.64 Large drop in RCDT level shows RCDT pumped to MLIT 01/06/79 0756 0.50 -0.59 -0.09,,9y( 0.36 Level shift consistent w 300g1 computer entry.* '
i 01/18/79 0401 0.00 -0.69 -0.69 0.64 Level changes may be due !
0'bE to normal oscillations. I l
o The effect on the leak rate was due to the error in the computer calculation, rather than, inappropriate operator action. The "L l operator correctly entered the 300 gallons into the computer. ,
l i
1
9Cb10 4 Effect of Feed and Bleed Indications on Test Resul ts
- DATE TIME RCS LEAK RATES (gpm) COMMENT EFFECT ORIGINAL UNID LR GROSS LR AT END COMPUTED CORRECTED FROM MUT OF TEST UNID LR BY EFFECT LUL TRACE 05/03/78 1822 1.38 -0.77 0.61 k' 1.00 Test started after bleed but before end of feed.
05/12/78 0047 0.00 -0.38 -0.38 h 0.78 Level changes may be due to normal oscillations.
05/13/78 2340 0.00 0.59 0.59 v/ 0.71 Lack of long term effect shows addition = removal.
06/11/78 0804 0.00 0.58 0.58 L/ 0.78 F & 8 may have increased the measured leak rates.
07/02/78 0256 0.00 0.73 0.73 \! 0.36 Lack of long term effect shows addi t ion = removal .
.09/17/78 0508 0.00 0.77 0 . 77 L/ 0.21 F & 8 may have increased the measured leak rate.
09/22/78 2100 ---
-0.04 --- ---
Effect obscured by many transients & Iv1 changes 11/13/78 0304 0.69 -0.55 0.14 L/ 0.29 Test ended before l completion of bleed.
11/16/78 0426 ---
0.61 -- b ---
Effect of feed & bleed masked by power increase 11/20/78 2110 0.00 0.88 0.88 V! ---
Additions = increases.
MUT slope masked by F&B.
11/21/78 0206 1.07 -0.51 ---
Test std. after start of 0.56 47]
bleed before end of F&B.
11/28/78 1653 0.00 -0.35 -0.35 v/ 0.43 Lack of long term effect shows addi t i on= removal .
01/09/79 1936 0.49 -0.30 0.19 0.36 Test ended before CO compl e t i on of bl eed.
I Tob10 S Comparison of Technical Specification Leak Rate Limits for TMI Unit 1 and Unit 2 UNIT l- UNIT 2 TYPE METHOD OF NAME USED TECH SPEC NAME USED TECH SPEC DERIVATION LIMIT LIMIT A sum of RCS leakage plus 30 gpm gross 11 gpm changes losses leakage B rise in losses to 30 gpm identified up to drain tank connecting leakage 10 gpm systems (b)
C type A minus gross 10 gpm unidentified 1 gpm type B 1eakage leakage (a)
D special e identified 10 gpm identified up to measurement leakage leakage 10 gpm (c) (b)
E type C minus unidentitied 1 gpm (not derived) type D minus leakage (d) evaporative losses Notes (a) The unidentified leakage could be reduced by any type D identified leakage, however, this war rarely done in practice.
(b) The combined type B and type D identified leakage could not exceed 10 gpm.
(c) Any RCS losses, not collected in the drain tank, that could be quantified, became identified leakage.
(d) No evaporat ive loss allowance was permi t ted f or Un i t 2.
1 Makeup Tank Level Measurement Position of water seal during increasing level and pressure, causing the maximum positive error in level measurement.
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FEB 28.19g4 MEMORANDUM FOR: Robert L. Baer, Chief, Engineering and Generic Communications Branch, OIE FROM: Lee H. Bettenhausen, Chief, Test Programs Section, EPB, DETP
SUBJECT:
REVISION TO INSPECTION REPORT 50-289/83-20, REACTOR COOLANT SYSTEM LEAK RATE TESTS AT TMI-l Attached is a memorandum and revised pages for the subject report. This report was provided to you in September,1983, in support of your work. The revisions will be incorporated into the fihal report package.
Lee H. Bettenhaus n, Chief Test Programs Section
Attachment:
As stated cc:
T. Martin
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION l
BEFORE THE COM ISSION In the Matter of .
METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 '
(Restart)
(Three Mile Island Nuclear Station, Unit No. 1)
NRC STAFF'S COM ENTS ON THE ANALYSIS OF GPU V. B&W TRANSCRIPT April 18,1983 Jack R. Goldberg Counsel for NRC Staff
-65perst4a
V.,V.
I
+
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION 4
BEFORE THE ComISSION In the Matter of ~
METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 >
(Three Mile Island Nuclear Station,1 (Restart)
Unit No. 1) )
NRC STAFF'S COMENTS ON THE ANALYSIS OF GPU V. B&W TRANSCRIPT I. INTRODUCTION By Memorandum dated March 16, 1983, the Office of the Secretary advised the parties to the TMI-1 restart proceeding that the Commission had decided to permit the parties to submit " written connents on the Commission staff's analysis of the trial transcript in the GPU v. B&W case" not later than 15 days after the service of the analysis on the parties. On March 29, 1983, the parties were served with the " Report of the Review of the Babcock and Wilcox - General Public Utilities Lawsuit Trial Court Record" dated March 28, 1983 (" Report").1/ The Staff hereby submits the following comments.
1/ The review of the GPU v. B&W record and the preparation of the Report was done by a
- review team" under the direc' tion of the Deputy Executive Director for Regional Operations and Generic Requirements. Report at 1. The NRC Staff, as a party to the TMI-1 restart proceeding, provided.no input for the Report.
a
_ , _ . - ,,s. _ . , , _ _ _ _ _ - - . . - - . . , ,- . - - - _ _ . - _ _ - - , . ,
^
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II'. DISCUSSION ,
A. The Report In General !
In connection with the Conunission's insnediate effectiveness review in this TMI-1 restart proceeding, the Staff submitted comments on the ~
' J insnediate effectiveness of the Licensing Board's August 27, 1981, F ManagementPID,U its December 14, 1981, Plant Design and Procedures, 27, 1982 Cheating Separation and Emergency Planning PID,E and its July PID.#l In sumary, the Staff stated its view that the findings reflected 4
in those PIDs, if accepted by the Comission, remove the corresponding bases for the immediately effective shutdown order. It therefore was l
the Staff's position that those three partial initial decisions provide The the basis for the Commission's lifting the TMI-1 shutdown order.
Staff has reviewed the Report on the GPU v. B&W record. Except as explained in Part II.B. below, the Report provides no basis for changing the Staff's position reflected in its imediate effectiveness coments.
2/ NRC Staff Coments on Immediate Effectiveness with Respect to Licensing Board Decision on Management Competence / Operator Training, September 11, 1981. See also NRC Staff Reply to Coments on Immediate Effectiveness with' E spect to Licensing Board Decision 28, 1981. ,
on Management Competence / Operator Training, September NRC Coments on Imediate Effectiveness with Respect to Licensing 3/ Board Decision on Hardware / Design Issues, Unit Separation and Emergency Planning, January 28, 1982. See_also NRC Staff Reply to Parties' Coments on Imediate EffectivenesUebruary 4,1982. i NRC Staff Coments on Imediate Effectiveness with Respect to 20, 1982.
4f Licensing Board Decision on Cheating Incidents, August l See also_ NRC Staff Reply to Parties" Coments on Imediate U Tectiveness with Respect to Licensing Board Decision on Cheating l Incidents, September 1, 1982, i
B. Falsification of Leak Rate Calculations The Report briefly discusses the issue of falsification of leak ratecalculations(theHartmanallegations). Report at 17-18. A brief sumary of the background of the Department of Justice (DOJ) investigation into the allegation 'of falsification of leak rata data concerning TMI Unit 2 was included in NRC Staff documents (NUREG-0680, Supp. Nos. I and 2) entered into evidence in the TMI-1 restart proceeding in connection withCLI-80-5(March 6,1980) Issue (10). Issue (10)concernswhether the actions of Licensee's management (or any individual member thereof) in connection with the accident at Unit 2 reveal deficiencies which must be corrected before Unit I can be operated safely. The Staff stated that the NRC "will resume its investigation of the concerns when DOJ has completed its investigation of the matter." NUREG-0680, Supp. No. 2.
The Staff concluded that based on its limited review of the infomation then available, "there appears to be no direct connection with the Unit 2 accident," and that "the identified concerns appear to be only of historical significance."N H. The Licensing Board, in its Management PID, quoted from NUREG-0680, Supp. No. 2, and concluded: "Due to our limited information and given the posture of an ongoing DOJ investigation, we have no basis to conclude that restart should not be permitted until the 00J investigation is complete." 14 NRC 381, 557. The Licensing
-5/ In retrospect the wording of this last conclusion in Supplement No. 2 should have been more precisely stated to be that the actions taken by the Licensee in light of the Hartman allegations were adequate to address the concprns identified.
. ' ' - =
Board further concluded that "[s]ubject to this [ leak rate] matter," and except as identified in the detailed findings, there were no deficiencies in GPU management arising from the Board's inquiry into GPU's response to the Unit 2 accident which have not been corrected and which must be corrected before there is reasonable assurance that Unit I can be operated safely. I,d,.
Subsequently, in a reopened hearing in response to the discovery of cheating by TMI-1 operators on the NRC's operator licensing examination, i
the TMI-1 restart proceeding focused specifically on the character and integrity of the TMI-1 management and operations staff. The Hartman allegations, among other things, touch upon the competence and integrity
- of TMI management. Thus, to insure that these allegations do not present i
health and safety concerns which require resolution prioYto restart, the Staff is initiating actions to revalidate the NRC Staff position,
- supporting TMI-1 restart, on the management integrity issue. These actions include an evaluation of the effectiveness of the steps GPU has taken to insure adherence to station operating procedures and a review of current i TMI-1 personnel and their current responsibilities vis-a-vis their responsibilities during the time frame of the Hartman allegations.
Upon completion of this effort, now estimated to be mid-June, the NRC Staff will advise the Commission of the results.
In addition, the Staff will review its position on management and j j ,
cheating issues in light of any additional information it obtains from 00JaftertheD0Jinvestigationiscompleted.N Subject to 00J agreement, f
! y The Staff also will seek DOJ' clearance to make appropriate notifica-
- tions concerning relevant documents currently in the possession of the Staff prior to the completion of the 00J investigation if such notifications do not compromise the DOJ investigation.
l
,. f- ,
the Staff will promptly make appropriate notifications of any significant newinformationthatitobtains.E III.. CONCLUSION ,
Except as explained herein, the Report on the GPU v. B&W record provides no basis for changing the Staff's position that the Connission can authorize the restart of THI-1 based on the Licensing Board's three partial initial decisions. Because the Hartman allegations do touch upon management competence and integrity, however, the Staff is initiating a program to revalidate its position on management integrity supporting TMI-1 restart and will advise the Connission of the results
, before restart. The Staff also will review its position on management
~
and cheating issues in light of the information it receives afte'r the DOJ investigation is complete and, with DOJ agreement, will promptly make appropriate notifications of any significant new information.
Respectfully submitted, ack R. Goldberg Counsel for NRC Staff Dated at Bethesda, Maryland this 18th day of April,1983
. y Based on the additional information obtained, the Staff will l initiate enforcement action if appropriate.
s
}
-:=_____.
-- ~5 UNITFn STATES OF AMERICA NUCLEAR REGULATORY C0fMISSION BEFORE THE C0tWISSION 1
~
In the Matter of METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 ,
(Restart)
(Three Mile Island Nuclear Station, Unit No. 1)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S C06MENTS ON THE ANALYSIS OF
, GPU V. B&W TRANSCRIP" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 18th day of April,1983:
- Samuel J. Chilk
- Christine N. Kohl Secretary of the Comission Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety & Licensing Appeal Washington, DC 20555 Board U.S. Nuclear Regulatory Comission
- Leonard Bickwit, General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555
- John H. Buck Administrative Judge
- Ivan W. Smith Atomic Safety & Licensing Appeal Administrative Judge Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comission 4
U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 George F. Trowbridge, Esq.
1 Dr. Walter H. Jordan Shaw, Pittman, Potts & Trowbridge
{ Administrative Judge 1800 M Street, NW
! 881 W. Outer Drive Washington, DC 20036 l- Oak Ridge, Tennessee 37830 l Robert Adler, Esq.
, Dr. Linda W. Little 505 Executive House l- Administrative Judge P. O. Box 2357 l 5000 Hennitage Drive Harrisburg, PA 17120 Raleigh, North Carolina 27612 Mr. Thomas Gerusky l
- Gary J. Edles, Chairman Bureau of Radiation Protection l
Atomic Safety & Licensing Appeal. '
Dept. of Environmental Resources Board P. O. Box 2063 U.S. Nuclear Regulatory Comission Harrisburg, PA 17120 Washington, DC 20555 l
l i
... l Gary L. Milhollin, Esq. Honorable Mark Cohen 4412 Greenwich Parkway, NW 512 D-3 Main Capital Building Washington, DC 20007 Harrisburg, PA 17120 Mr. Marvin I. Lewis William S. Jordan, III, Esq.
6504 Bradford Terrace Hamon & Weiss Philadelphia, PA 19149 1725 I Street, NW ,
Suite 506 Mr. C. W. Smyth, Supervisor Washington, DC 20006 Licensing TMI-1 Three Mile Island Nuclear Station John Levin, Esq.
P. O. Box 480 -
Pennsylvania Public Utilities Comm.
Middletown, PA -17057 Box 3265 Harrisburg, PA 17120 Ms. Marjorie Aamodt R.D. #5 Jordan D. Cunningham, Esq.
Coatesville, PA 19320 Fox, Farr and Cunningham 2320 North 2nd Street Gail Phelps Harrisburg, PA 17110 ANGRY /TMI PIRC 1037 Maclay Street Louise Bradford Harrisburg, PA 17103 Three Mile Island Alert 1011 Green Street Allen R. Carter, Chaiman Harrisburg, PA 17102 Joint Legislative Comittee on Energy Post Office Box 142 Ms. Ellyn R. Weiss Suite 513 Hannon & Weiss Senate Gressette Building 1725 I Street, NW Columbia, South Carolina 29 W Suite 506.
Washin'gton, DC 20006 Chauncey Kepford Judith Johnsrud Mr. Steven C. Sholly Environmental Coalition on Nuclear Power Union of Concerned Scientists 433 Orlando Avenue 1346 Connecticut Avenue, NW State College, PA 16801 Dupont Circle Building, Suite 1101 Washington, DC 20036 Ms. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant *Dr. Lawrence R. Quarles Postponement Atomic Safety & Licensing Appeal 2610 Grendon Drive Board Wilmington, Delaware 19808 U.S. Nuclear Regulatory Comission Washington, DC 20555 Mr. Henry D. Hukill Vice President
- Judge Reginald L. Gotchy GPU Nuclear Corporation Atomic Safety & Licensing Appeal Post Office Box 480 Board Middletown, PA 17057 U.S. Nuclear Regulatory Comission Washington, DC 20555 Michael McBride, Esq.
LeBoeuf, Lamb, Leiby & McRae Ms. Jane Lee Suite 1100 ,
R.D. 3; Box 3521 1333 New Hampshire Avenue, NW Etters. PA 17319 Washington, DC 20036
'e '[ ^
]. ,,
. David E. Cole
- Atomic Safety & Licensing Smith & Smith, P.L. Board Panel Riverside Law Center U.S. Nuclear Regulatory Comission 2931 N. Front Street Washington, DC 20555 Harrisburg, PA 17110
- Atomic Safety and Licensing Appeal Michael W. Maupin, Esquire Board Panel Hunton & Williams U.S. Nuclear Regulatory Comission
, 707 East Main Street Washington, DC 20555 P. O. Box 1535 Richmond, VA 23212 -
- Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Comission Washington, DC 20555 pack R. Goldberg '
}
Counsel for NRC Staff
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A REPORT ON A REVIEW OF CURRENT AND PROJECTED EXPENDIT ES AND MANPOWER UTILIZATION FOR GPU NUCLEAR CORP, ORATION g .
CONDUCTED BY g
, BASIC ENERGY TECHNOLOGY ASSOCIATES, INC.
ARLINGTON, VIRGINIA i
.1 FEBRUARY 28, 1983
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f TABLE OF CONTENTS CHAPTER PAGE L OVERALL ASSESSMENT 1 E. INTRODUCTION A. Objectives and Scope 6 B. Method of Approach 6 C. Background 11 D. Reporting of Findings 16 HI. TMI-1 FINDINGS General 18 a' A. Site Management 20 B. Operations 22 C. Maintenance 23 D. Chemistry 25 '
E. Plant Engineering 25 F. Radiological Controls 26 G. Materials Management 28 H. Human Resources 31
- 1. Administration 31 IV. OYSTER CREEK FINDINGS !
'1' General 32
/ A. Site Management 33 B. Operations 36 g C. Decontamination 36 x'
D. Maintenance 37 E. Chemistry 43 F. Plant Engineering .
43 G. Radiological Controls 46 H. Nuclear Safety Review 47
- I. Administration 48 J. Materials Management 50 d9 I
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PAGE V. NUCLEAR ASSURANCE FINDINGS General 52 A. Reading Group 53 B. Training Corporate / Headquarters 54 TMI-1 56 Oyster Creek 59 C. Quality Assurance
. Engineering 60 Operations 61
- Manufacturing Assurance 62 4
I QA Plan 62 l TMI-1 QA 63 VI. TECHNICAL FUNCTIONS FINDINGS General 34
. A. Effectivenem 65 l B. Engineering Services 66 C. Licensing and Regulatory Affairs 68 l D. Engineering and Design 69 i
E. System Engineering 70 .
F. Engineering Projects 74
- ' G. Startup and Test 76
- . H. Chemistry 77 i VB. ADMINISTRATION FINDINGS
!- General 79
! A. Effectivenes 79 -
l B. Management Service 81 C. Operational Analysk 81
)
D. Materials Management 82 l4 E. Security 83 i F. Safety and Health ,
92 ,
i i
VIII. HUMAN RESOURCES FINDINGS 94 IX. RADIOLOGICAL AND ENVIRONMENTAL
'[jg -
CONTROL FINDINGS General 98
) A. Radiological Engineering 99 B. Environmental Monitoring 100 S
11
PAGE X. MAINTENANCE AND CONSTRUCTION FINDINGS General 102 A. Corporate 103 XI. COMMUNICATIONS FINDINGS 105 XH. GENERAL FINDINGS A. Supervision 106 B. Paperwork 110 C. Decision-Making 112 D. Poor Performers 114 E. Staffs 115 XIII. COMPARA'!1VE ANALYSIS RESUL'IS A. Summary 116 B. Objective 116
/ C. Method of Approach 117 i
D. P.ianpower Analysis Results 118 E. Cost Analysis Results 136
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CHAPTERI t-OVERALL ASSESSMENT e
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CHAPTER I. OVERALL ASSESSMENT .
Basic Energy Technology Associates, Inc., (BETA) was tasked by GPU Nuclear Corporation (GPUN) in January 1982,. to conduct an independent l review of the Three Mile Island, Unit 1 (TMi-1 and the Oyster Creek (0/C) nuclear plants in order to identify areas wh~ere morovements e5 iib be made, '
which wouW result in work bemg performed more efficientI;* and at les overen expense. ,
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It is our opinion, based on the extensive review conducted, our knowledge 1
of the nuclear utility industry, and our more than twenty-eight years of ,
experience in the nuclear power generation field thati in an overall sense,
- ~tners - . m y f.w funellons, activities 'or work efforts, either being done
- or contemplated by GPUN, at TMI-1 or Oyster Creek that are unnecesary.
We find that in 1979 GPUN embarked on a determined program to create 4 a nuclear utility that had clearly taken to heart the shortcomings or tne j past.
exoertenCthroughout the nuclerindustry for the last three decades, '
and has achieved the capability to demonstrate thatlt can operate and" f
!I mmnum its nuclear plants safely. It is now in the proces of being soie to do this effiMly. Tnts effort has not reached the desired and point as j
yet; there are stir a number of areas where filether effort is needed. !
However, our review indicates that, regardlem of the level within the organization or the particular area reviewed, there is a universal desire to make GPUN a model o' the industry. GPU management has set the goals and has racesium.u Inst acnn.vu, Inese goals wouW be costly, not only in manpower and effort but in doDars. While they evidence concern over these i costs and their continuing upward trend, as they should, they show evidence of continued determination. It is our opinion that these goals can be achieved, that costs can be stabilized, and that the organization, with proper direction, i
can settle down.
One major contrbuting factor to the comparatively high cost at GPUN is the number of employees, both inhouse and contractors. In comparison to other nuclear plants of similar age and type, the total number of GPUN employees used to operate and maintain their plants is high. OveraR yearly expenses are high. In BETA's opinion this is due to a number of reasons.
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One reason is that in an areas of its operation, the manning was allowed to increase as it had to, in order to fulfill the yet to be fully defined needs of creating a new and unique nuclear corporation. While GPUN management ,
i l attempted to exercise some degree of control on this growth, the highest I priority was given to getting the new organization established, manned and
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working on the known tasks whleh had to be done. In doing so, GPUN !
I management had to accept the posibility that overstaffing would occur.
- Given the alternative of understaffing whleh wouW have resulted in goals -
and objectives not being met, a conscious decision was made. The not result p' was a tendency to overstaff in order to amure that each function was properly covered. Doing this within tight budgetary constraints did not i
i become a high priority issue within the organization until the beginning of
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1982, when some of the elements of the organization began to stabilize and the overstaffing became evident. 1982 can be viewed as the start of the j
settling out phase of the development of GPUN. While there are stin a few areas where a particular group needs to develop further and grow in size, most areas are over-manned, i
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1 Another reason can be traced to the very preinise upon which GPUN was created. GPU management determined that an underlying objective was .
to develop an organization which had the capability and resources to perform l'-
effectively aR those functions considered esential to operate and maintain their nuclear plants safely and effleiently. The very nature of this decision dictated the payron. the need to increase rather dramatically the number of people on l' -
While BETA can find inefficiencies in how some of these functions are being carried out, the basic obleetives are sound and not i.
necesarHy overdaaa -
The third reason why GPUN. manpower and costs are higher than other plants can be attributed to the fact that GPUN is the owner of the plant that had the accident. It was forced by circumstances to react much more i
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rapidly to a1 of the new requirements imposed by the regulatory agencies, j lt was also apparent that GPUN had to show concrete evidence that they 1
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were taking immediate and bold actions to prove to aH concerned that they were reacting to the accident. This put GPUN in the forefront of the j
nuclear utility industry in making changes, incorporating new pr_ o@.and programs, and generaHy increasing the scope una ceptn or tnetr coverage, j. >
lt could be estimated that GPUN is at least one year ahead of the average of the industry in many of these areas. '
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The sestantial buDd-up of new people in a relatively short period of j
organization. ineffleieneles as is typical in any large industrial / engineering time created Many new people were hired who were minimally trained or i experienced and were put into jobs that were not wen-defined. Growing pains _had to be expected and they are still in evidence, albeit redh W
,_ There are a number of comments that relate to the actual conduet of the BETA review, particularly with respect to the changes noted by BETA '
during the year it took place. The review began in Januarv 1981 and was completed in December tes2 At the outset, BETA concentrated on dnderstanding the GPUN N* atla ~ gss; how it was arrived att how it was approved; how costs were controHed. This brought the reviewers into direct contact with GPUN to namely division directors, other directors foHowing:
and managers. p management,What was noted in these early sta Rek of genuine or serious concern over the Nwtet process _and la importance to controllinr cos.ts.
Overly concerned with issues relating to divisional responsibility.
A ek of sense of total, ownership with respect to their role with n overan a6,,,vas iment 'of GPUN objectives. .
l Much effort being devoted to adjusting to the new functional organization, creating documents and trying to figure out how _
i work was supposed to get accomplished, and l
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Working to asimilate the large inDux of new people into their organizations. ;
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I improvements Throughout in eachtheofperiod these.of Specificthe review, BETA noted significant pronounced were areas where program was most Throughout GPUN, people were taking the bu%et proces
_ seriously. Procedures and programs were established whleh avowerpeople to begin to understand the bu%et proces, to track commitments and expenditures, and to influence the rate of expenditures.
The people who were charged with the responsibility for accomplishing work. understood and realized that they had the authority, responsibility and wherewithal of controlling costs, in i early 1982, these functions were perceived to be held by the Administration Division. . -
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- For a number af -is, the management of Oyster Creek, at f ,an leve@gmatWLrimproved. Previously noted problems with i
attitude at u.. ....uole manag'ement and worker levels has begun to be turned around and is now more positive.
There was a marked- ' in cooperation between divisions at the lower levels. --
Ibo-attitude of GPUN employees at TMI-1 has remained esentially
/Cnositisia, which, in light of the continuing delays in restart, is an
, accomplishment.
4 Notwithstandi the above, there still remains a number .ar===
4 rem has be or where significant improvement stlR mu anese ine : to be Productivity throughout the GPUN organization is still at a low level primarily because of the lack of proper supervision, poor planning, cumbesome union agreements and late or incomplete technical suppo-t.
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Plant maintenance at Oyster Creek d TMI-I reach the point where required equipment reus,;by can__ . reasonably i
asumed.
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w Technical support, while impmvinr is still slow, unresponsi to j
plant needs and too often ically3elntpT I
f, There are a number of actions that can be taken immediately that should result in increased efficiency of the GPUN operation. These are j
, a detailed in other chapters of this report but can be summarized as follows: <di4N,
- NNA Continued pressure by the Office of the President on the Division Directors to strive for more efficiency in their operations.
[/g Greater effort to force individual managers to make their people more productive and to make better use of GPUN's performance evaluation system.
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Continued effort to reduce paper.
Continued effort to reduce the sman " cells" that have been, created.
Contimed efforts by GPU and GPUN to' eliminate inefficiencies caused by past provisions contained within the labor agreements
.and praetices.
Contimed effort to force acceptance by the workers of greater responsibihty for high quality radiological work performance.
Review the number of people asigned to the plants who perform strictly administrative work.
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Contimed effort to improve the interaction between Technical Functions and the sites, r
Contimed efforts to make the cperating divisions,'in contrast to the support divisions, feel greater responsibility for cost performances across the board, particularly with respect to contracted work.
With respect to GPUN manning, BETA concludes that, for a number of reasons listed below, the current approved level, while it can be reduced in certain areas, 'can not be reduced substantially in the near term (6 to 12 months) time frame. These reasons relate to:
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Contimation of the need to resolve technical and non-technical imues raised by the regulatory agencies at Oyster Creek and TMI-1. -
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The backlog of known technicalproblems related to the two plants.
The accomplishment of known maintenance and modification work
( at the two plants.
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The still-existent lack of maturity of the organization and the lack of experience of many of the relatively newly hired people
[ within the organization. ~
l BETA is of the opinion that a multi-reactor, multi-site, ' etionally-j- run nuclear power utility, in the most ideal situation, can be an with a total of 750 utility people per nuclear plant. This assumes a reasonably high degree of inhouse technical capability such as the goal of GPUN.
l,l BETA's number for the less than ideal situation is 900 - a number which
. BETA feels can be scheduled for achieving when major milestones are reached.
There is the need to balance the size of the fun-time GPUN employee i level with the size of the contractor effort. Extremes in either direction are harmful. The 900 number shouk! allow for GPUN to handle in-house
- I those tasks which arise from what could be described as normal operational situations, whereas outside assistance would be required for unu'sual or not often repeated circumstances. Based on where GPUN is today, that would .
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mean a gp of about 200 people. While BETA can, and has identified to the Office of the President where it considers these excess positions exist, a far better approach in the near-term would be for the Office of the President to continue applying pressure on the Division Directors to cut excesses where they are identified, and to remove from their roles those people who are not performing at the expected level Reductions beyond the 200 or so should be possible in the long term but this decision should be based on a review made when the major work effort has subsided and the organization has settled down.
t One further objective of the BETA review was to perform a comparative analysis using cost and manning data from other plants. For a number of reasons, discused in Chapter X111 of this report, this analysis did not produce the hoped for resulte. While the comparative data should not be ruled out completely as being meaningless, it is not accurate enough to analyze any specific function, group or cost center. Without intimate knowledge of the other plants, how they function, how they are organized and how they collect and reort manning and cost data, it would be foolhardy in BETA's opinion
" for GPUN to make drastic changes based solely on the accumulated data.
There may be some advantage in having a freer exchange of ideas between the manager of a given function in GPUN with his counterpart in another utility if the comparative data indleates a glaring disparity in manning.
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I CHAPTER II a
!*g INTRODUCTION b
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CHAPTER 11. INTRODUCTION
, A. OBJECTIVES AND SCOPE Basic Energy Technology Associates, Inc., (BETA) was tasked by GPU Nuclear Corporation's (GPUN) Office of the President in January 1982, to '
conduct an independent review of current and projected manpower and overall cost expenses for -the Three Mile Island Unit-1 (TM1-1) and Oyster Creek nuclear plants. The review - was to cover TMI-2 only to the extent of I determining allocation of GPUN resources assigned to TMI-1 and Oyster Creek.
The objectives of the review were to:
- 1. Determine the appropriateness of performing the functions, activities and tasks currently underway and planned.
2._ Make a judgment as to the effectiveness and efficiency of efforts being used to perform those functions, activities and tasks.
- 3. Perform a comparative analysis, using data obtained from a number of other utilities, to determine if such an analysis might provide j
meaningful indicators. The data was to cover manpower, operations and maintenance (O&M) costs, capital costs, and general and -
administrative (G&A) costs.
4.
Provide GPUN management with significant impressions throughout the period of the review, and
- 5. Provide a final report of the BETA findings, conclusions and r recommendations.
'k The findings of the first three objectives listed above are briefly I described in Chapter 1 of this report, "Overall Assessment". Specific findings and recommendations relating thereto are contained in the remaining chapters of this report. BETA provided the Office of the President with interim reports throughout the period of the review outlining significant impressions.
The scope of the BETA effort was to conduct the review in all of the GPUN divisions, with the exception of TM1-2, as previously noted, covering every area, function and activity within GPUN. The BETA review of contractor effort was restricted to interviews of GPUN personnel and records or data in the possession of GPUN.
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.i The comparative analysis involved fourteen privately-owned nuclear utilities located in the United States and included the two GPUN plants.
' GPUN resources were used to obtain the data from the various utilities, put the data in useable form, and pr3 vide the data for BETA to analyze.
B. METHOD OF APPROACH
! 1.
In performing the review as previously outlined, BETA felt there were a number of situations existing within GPUN that had to be 6
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given constant recognition throughout the review period. These
, were:
- a. Constantly Changing Situation. The major reorganization, which occurred less than two years ago, was still in its fF formative stage. It was a major reorganization, not only in
( the sense that people were moved, but in very basic terms of l organization. A functional orgertization replaced a typical j project organization. Functions, activities and capabilities,
(- heretofore not included within the former structure, were added. The organization grew in size (number of people) over L _ a relatively short period of time.
The BETA onsite review, conducted over a five month period, was still seeing a process of settling down. Correction of organizationalinterface problems, absorbtion of new people, creation and implementation of new policies and procedures; h these were all much in evidence throughout the review period.
l Many instances of inefficiencies, noted by BETA early in its review, were in the proces of correction and were corrected by the end of the review.
- b. Creation of GPUN. While the newness of the organization, discused above, affected the BETA review, the character and complexity of the new organization which had been created l .
also had a marked effect on the review. There are very few, t
if any, nuclear utilities that have opted to form a totally complete nuclear organization, structured along functional
lines.- This type of management was being put in place by combining the personnel assets of two owner utilities,
!, Metropolitan Edison and Jersey Central, each of which had headquarters capabilities at different locations, i.e., Reading, i
Pa., and Morristown, N.J. In addition, there were groups at i s the GPU headquarters offices in Parsippany, N.J., and at both of the nuclear sites. All of these groups,had to be combined into one organizational entity, while continuing to function.
, It was also significant to the review that TMI-1 was still in a shutdown condition and undergoing its third year of attempting to get back on the line. A number of critical TMI-1 issues continued to face GPUN during the period of the BETA review including:
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(1) Steam generator leak problem.
(2) Psychological stres issue with the NRC and the courts. -
(3) The reactor operator cheating issue.
l (4) Issues related to obtaining Atomic Safety and Licensing Board (ASLB) and NRC agreement to
, restart.
I' Er. ?'1, in its own way, prevented key GPUN' people from devoting their full attention to the task of making the new organization work.
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- c. The Uniqueness of GPUN. _ Recognition had to be given to -
the fact that GPUN was created from elements of the company i .
that had experienced the accident at TMI. While it couki be .
1 argued that now, after three years, it should not still have an unsettling effect on the organization, its people,' and how work is performed, this is not the case. It was apparent throughout the review, that a corporate decision had been made shortly after the accident that GPU would embark on a program to create the best nuclear organization in existence.
This aspect is important, particularly in the comparative
'. portion of the BETA review, because It shows that, in many
_ respects, GPU is in the forefront of all of the utilities used in the comparison insofar as achieving an in-house technical capability, and in reacting to outside (NRC and others) suggestions, demands, or requirements. One element of the BETA review was to see if GPUN had overreacted to these pressures.
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- 2. The method of approach, used by BETA in conducting this review,
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consisted primarily of interviewing a large number. of GPUN personnel in order to determine what they considered their job to be, how they performed it, what impediments they faced, and where they felt improvements could and . should be made. . In conducting this review, BETA was able to take advantage of its past involvement with GPUN (1980, Review of Management Capability and Technical Resources) which provided BETA with a better understanding of the organization and the key people involved.
m Prior to conducting the interviews, BETA reviewed the key organizational documents issued by GPUN in establishing the functional roles. Documents and procedures issued by each Division outlining how that Division operated and interfaced with other l
i Divisions were also reviewed. In addition, BETA was provided with a comprehensive description of the new budgeting and cost
. accounting system, which was in the process of being implemented.
In order to fulfill the objectives of this review, BETA looked into a number of areas including:
- a. Determining if the functions, activities, or items of work (O&M and Capital) which are being, or will be, performed are things
' which should be done, and second, if they are being performed in an efficient manner. This included reviewing:
1981 and 1982 work plan and budget Assignments of manpower Assignments of work i' -
Planned workload Actual workload l i
Performance !
Constraints Backlog of work Overtime -
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Rework Farm-out work Cost- and cost control Requirements for work Paperwork Concurrence load Decision process p -
7- :- b. Conducting a review of past, current and future manpower and cost figures for GPUN major contractors used at TMI-1 p and Oyster Creek in order to ames the reasonablenes of the i- effort and the associated costs.
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- c. Conducting a review of major capital cost figures for TMI-1 and Oyster Creek.
l d. Reviewing the GPUN salary structure te determine if it was f" nominally in line with the industry and the area. .
, e. Seeing if it was meaningful to compare returned costs at GPUN and other plants on a number of TMI modifications required by NRC to be done at all nuclear plants that have been done at TMI-1 and/or Oyster Creek.
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- f. Seeing if it was possible to determine the amount of manpower effort that has been estimated in 1982 for handling matters which might be considered unique to TMI-1 and Oyster Creek -
because of their close association with TMI-2.
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- g. ~ Determining how much money is programmed in 1982 for building up repair / spare parts inventory and compare this to previous years.
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i Determining and analyzing turnover and buildup rate of 4
j personnel at TMI-1, Oyster Creek and Parsippany for the past ycar.
- 3. In conducting the comparative analysis, GPUN management decided
- they, rather than BETA, would provide the necessary resources to obtain the data from the various utilities. BETA provided GPUN
- with a list of the types of information considered appropriate for review. That list was refined, and GPUN, in conjunction with one other utility, obtained data from fourteen nuclear utilities. In all cases someone from GPUN or the other utility visited the plant or the headquarters offices of the utility in question.
Upon completion of the data-collecting proces, the data was then entered to a data bank so that the various analyses could be accomplished. The analysis of the data and the conclusions derived '
therefrom, es provided in this report, are those of BETA and are not necessarily those of the persons who collected the data for GPUN.
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- 4. Two in-depth record analyses were performed to determine if a j quantitative measure of effectiveness or efficiency could be
- obtained. In one case, using GPUN people to collect the data, a complete review of available TM1 training records covering the period January 1,1982, through March 31, 1982, was conducted.
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Data covering the following areas was coHected and tabulated:
Courses planned to be condueted Courses scheduled to be condueted.
Courses actually conducted Number of students in each clan. ;
Frequency and duration of each class.
Instructor for each clan.
Where the clam was taught.
t Monitors used for the clases. Who they were and whether i reports were written.
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Clamroom attendance records, Nature of the instruction, i.e., lecture, elass notes, study,
._ -video tape.
Tests or examinations given and, if so, what kind, how many, etc.
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Critiques held and reported.
" Customer" involvement The other area subjected to a detailed records analysis was TMI-1 Quality Assurance (QA). The review was based on current written procedures, reports and records available in Quality Assurance, Auditing, Engineering, and Inspection as well as on f, personal observations of monitorings, audits, and inspections in process. The purpose was to assess the effectiveness of selected control documents and the effort required to proces them. Similar to Training, above, the review covered the first three months of g 1982, in order to make the following determinations:-
Actions (monitorings, audits, inspections, document reviews) planned.
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Actions scheduled -
Actions conducted.
Time spent in preparing for, conducting, and reporting the QA actions.
Alternatives used when scheduled QA actions were canceled or could not be performed
.I For each QA section, time spent on work other than the principal function, i.e., monitorings, audits, inspections, and document review. Established a percentage for each category of "other work".
i Percentage of Material Noncompliance Report (MNCR's) and Quality Deficiency Reports (QDR's) written in the last three months that had been resolved.
On the average, the amount of QA time required by each procurement action (procurement specification, purchase requisition, purchase order, receipt inspection, resolution of MNCR's written at receipt inspection).
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I In both of these detailed record reviews, useful information was obtained pointing up areas where inefficiencies existed.
However, neither of the reviews provided a useful means for establishing quantitative measures of work efficiency. It is BETA's
? " opinion that these types of analyses do not lend themselves to determining the efficiency of operations of this-nature any mee so than work sampling or time studies. More is to be gained by improving the. performance of the supervisors.
C. BACKGROUND l._ in early 1980, the decision was reached by GPU to reorganize and create a new corporation within the GPU system which would encompass all three nuclear plants, TMI-1, TMI-2 and Oyster Creek. A new corporation,~
-~ called GPU Nuclear. Corporation (GPUN), was formed in September 1980, and officially became functional on January 1,1982. The GPUN Corporation differed from the past organizations in that it was structured along functional 3 lines rather than being project oriented. Under the Office of the President there were established nine Divisions, each with a Directw:
I Approved Division Total Number .
Of Employees (1982)
- 1. TMI-1 340
- 2. TMI-2 290
- 3. Oyster Creek 272
- 4. Technical' Funetions 425
- 5. Nuclear Assurance 265
[ 6. Maintenance and Construction 207
- p. 7. Radiological and Environmental Controls 255
- 8. Administration 526
- 9. Communications h 10. Human Resources (not a Division) 34 L 34 As of September 1,1982, there were 2611 employees working for or assigned to GPUN at four locations:
TMI, Middletown, PA Oyster Creek (including Forked River), Forked River, NJ GPU Headquarters, Parsippany, NJ GPU Service Corporation, Reading, PA While the 2611 employees are identified as GPUN employees, it should be noted that those belonging to a bargaining unit actually remain on the owner company roles (Met Ed and Jersey Central) because, at present, there is no contract between GPUN and the bargaining units. However, for the l purposes of this review, an of these people are considered to be "GPUN employees".
Not included within 'the 2611 employees are a number of contract (or secunded) employees, who are operating within the functional organization of GPUN, i.e., they are occupying positions within the GPUN framework.
In addition, there are varying numbers of contractors who perform work for
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GPUN. On Juky 1,1982, there were 558 contractor personnel working under GPUN contracts. This work is performed either at.the sites, such as in the
' case of construction or modification work, or at locations remote from GPUN, such as for engineering support. Approximately one-third of the GPUN annual budget is devoted to contractor work.
Due to the functional nature of the organization, the number of people 4 r- at a given location is a summation of-the numbers of employees assigned to each Division located at that site. For example, there are 834 (as of
'- . December 1,1982) GPUN employees located at Oyster Creek, yet only 272 report to the Director, Oyster Creek. The others 'are assigned the remaining Divisions having responsibilities at Oyster Creek. The breakdown of GPUN manpower by location is as follows:
- Location Employees TMI-1 750 TMI-2 537 Oyster Creek 834 Parsippany 473 Reading 52 The following is a breakdown of how it was planned to allocate the breakdown of the 1982/3 approved level of GPUN employees by plant assignment.
i f GPU NUCLEAR STAFFING - 1982/1983 (APPROVED LEVEL)
LOCATION TMI-1 TMI-2 OYSTER CREEK
- GPUN TOTAL On Site 750 537 834 2,121 Off Site 156 5 68 261 485 TOTAL 906 605 1,095 t 2,606 Fossil System Lab Personnel 30 Undistrbuted Personnel 9
- - Saxton Manager 1.0
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Forked River Support 2.0 ii Tech. Functions Tra nee 8
- 11 Overhead Support 5 i
GPUN SYSTEM PERSONNEL CONTROL LEVEL 2,664 h
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1983 CMC MMOG IESOURI AI.lECATION Oyster Creek 7 Division /Ihpartment M -1 'IMI-2 Ot-Site Off-Site 'Ibtal CMC th-Site Of f-Site T6tal Ch-Site Of f-Site Total g TUIAL 1000 Office of the Presi< lent 1100 Enecutive Of fice --
2.6 2.6 --
1.3 1100 (DRB 1.3 --
1.0 1.0 9.1 1.0 1.0 --
.5 .5 -- 14.0 1UTAL 0/P 3.6
.4 .4 .1 2.0 4
3.6 1.8 1.8 1.4 1.4 9.2 16.0 2000 Oyster Cteek Division 2000 V.P. & Staff 14 .0 --
14.0 i
2l00 Operations
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77.0 --
77.0 2.0 16.0 !l 2120 Ra< haste Operations 33.0 --
33.0 --
77.0 !
214 0 Owsnistry 22.0 --
22.0 --
33.0 2200 Plant Erwineering !
39.0 --
39.0 --
22.0 2300 mintenance 85.0 --
85.0 --
39.0 i
1UTAL 0.C. 270.0 270.0 85.0 2.0 2 72.0
.3C00 M-1 Division s
3000 v.P. & Staff 2.0 3100 Anninistration 2.0
- 1.0 --
1.0 2.0 3200 Site Operations Myt. 1.0 u 3210 Operattons 7.0 92.0-7.0 92.0 7.0 3212 Ra<beste 92.0 3220 mintenance 26.0 --
26.0 159.0 --
159.0 26.0 3230 Ormistry 19.0 -- 159.0 3300 Ergineertre 19.0 29.0 --
29.0 19.0 3400 Plans & Program 5.0 29.0 5.0 10TAL M-1 340.0 5.0 340.0
-O- 360.0 4000 M-2 Division 4000 V.P. & Staff '
4200 Site Operations W. 3.0 --
3.0 3.0 r
4210 Operations 5.0 --
5.0 5.0 4212 Owmistry 72.0 --
72.0 72.0 4220 W intenance 25.0 --
25.0 25.0 4240 Plant Ergineerira 121.0 --
121.0 121.0 4300 lbcmery Protrans 16.0 --
16.0 16.0 i'
4300 Licenstre & lbclear Safety 23.0 --
23.0 23.0 4500 kcovery Tech. Plarmisg 21.0 --
21.0 21.0 10rAL M-2 4.0 --
4.0 4.0
-O- 290.0 290.0 290.0 I
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t Oyster Creek 1HL-1 Divisior/Dt.partment OrSite Of f-S ite 'lHT -2 QWC Tot..! Qv-Si te Of f-Site Total lb-Site Of f-S ite Total gher l
1UTM. j 5000 Tednical kncticms ii 5000 V.P. & Staff --
2.1 5100 Ergineerint Services 2.1 --
1.1 1.1 --
.8 F
3.0 29.9 32.9 3.0 17.4
.8 11.0 15.0 5200 Licensirs & Re 20.4 --
- 7. 9 7.9 5300 Ergineertra & Design g. Affairs 6.0 13.4 19.4 6.0 7.4 13.4 1.8 63.0 5.0 58.4 63.4 1.3 1.3 .9 35.0 5400 Systems Ergineertra 2.0 42.5 44.5 --
2.4 19.0 23.1 42.1 21.0 2.4 29.7 14 0 . 0 5500 Ergincedrg Projects 4.0 19 .6 40.6 --
.3 .3 --
32.1 36.1 4.0 16.0 20.0 14 0.0 5600 Start-th armi Test 11.0 3.4 14 .4 13.0
- 2. 6 2.6 .3 59.0 2.6 15.6 -- -- --
10rAL 'Ardinical knetions 48.0 210.4 30.0 16 2. 4 49.0 106.6 15 5.6 15. 3 _15.3
_43.7 425.0 6000 kelear Assurance g 6000 V.P. & Staff 5.8 !
- n 6100 QA/QC 38.0 12.6 5.8 50.6 37.4
.5 2.4 7.0 2.9 44.4
.2 1.9 2.1 .2 11.0 L 3' 6200 Trainirs & Education 37.0 2.6 20.6 11.0 31.6 .4 127.0 39.6 38.0 1.3 39.3 17.0 1.0 6330 helear Safety Assessment 6.0 2.0 8.0 6.0 18.0' .1 97.0 I'
6400 bergency Preparedness 2.0 8.0 --
2.0 2.0 lotAL heleer Assurance 5.0 -_ 5.0 3.5 --
3.5 3.5 --
3.5 18.0 12.0 l'
[ 86.0 23.0 109.0 85.4 12.7 _98.1_ 41.3 o
' J000 Alministration 15.9 R .7 265.0 i
~ 7000 v.P. & Staff --
4.7 4.7 2.4 I.
2.4 --
1.7 M 7100 Fiscal & Info. W. 32.0 21.0 53.0 34.8 10.6 45.4 25.2
- 1. 7 17.7
.2 9.0 7200 Meterials Me 31.0 15.2 46.2 36.7 7.7 42.9 .7 %2.0 44.4 26.3 5.6 31.9 .5 MOO Director & St f S.F.S6H) . - - 3.1 3.1 --
1.6 1.6 123.0 7410 Security 54.0 --
54.0 51.0
- 1. 2 1.2 .1 6.0
l M20 Facilities 35.0 51.0 38.0 --
38.0 --
7430 Safety and Health 35.0 26.0 --
26.0 19.0 14 3.0 5.0 --
5.0 4.8 --
4.8 19.0 --
80.0 7610 Accomtirs _10.0 --
10.0 -- --
3.2 --
3.2 --
13.0 j 1DrAL Administration --_ --
_10.0 16 7.0 44.0 8000 Commaticatiens -
21 1.0 153.3 22.3 M 111.7 26.2 137.9 J 526.0
. 8000 v.P. & Staff --
.5 .5 8100 Belic Affaits
.3 .3 - - -
.2 .2 2.4 2.4 5.6 .5 6.1 1.0 8200 kblic Information 3.0 .5 3.5 4.8 4.0 .4 4.4 .1
- 13.0 8300 Special Ptojects --
1.2 4.8 4.7 --
4.7 --
13.0 1.2 2.1 --
_ 2.1 3.7 1DTAL Consistications 3.0 3.7 .- 7.0 4.6 7.6 12.5 .8 $ 12.4 .6 13.0 .1 36.0 i i I 1
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Oyster Creek 1M-1 Division /Ikpartwent *D6 -2 CIMC Ot-Site Of f-Site Total On-Site Of f-Site Total (h-Site Of f-Si te _ Total Other 1UIAI.
.; 9000 Red. and Fnv. Controls 9000 V.P. & Staff / Rad Engrrg. 1.0 2.6 3.6 .6 9100 Rad. Omtrols 'DE-1 1.3 1.9 .4 1.0 1.4 52.0 --
52.0 .1 7.U 9200 Rad. Controls - 1M-2 - - -- --
15.5 --
52.0 9300 Rad. Control s - 0.C. 75.0 15.5 69.5 --
69.5 75.0 -- -- --
85.0 i.
9400 Fnv. Controls 11.0 4.7 15.7 9.3
-- -- -- -- 75,o 2.4 11.7 6.7 1.7 8.4
'IUIAL lEAC 87.0 7.3 _94.3 .2 36.0 77.4 3.7 81.1 76.6 2. 7 79.3 .3 255.0
, 4)G) hintenance & Construction A000 V.P. & Staff - -
7.7 7.7 .4 h A100 MC -gmter Creek 3.7 4.1 --
2.9 2.9 16 7. 0 --
16 7.0 -- -- .3 15.0 '
A200 MC - mi-1 -- -- --
25.0
-- -- -- -- -- my,o 25.0 -- --
10lAL MC 167.0 7.7 174.7 25.0 25.4 3.7 - 29.l 2.9
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_ 2.9 .3 207.0 B000 Ilman Resources j B000 V.P. & Staff --
1.0 1.0 B010 Area Mgr., Parsippany
.5 .5 --
4' .4 3.7 3.7 --
1.9 1.9 .1 2.0 E020 1M1 Area mnager --
1.3 1.3 .1 7.0 u B030 0.C. Area mnager
'5.8 --
5.8 4.2 j
5.0 --
5.0 -- --
4.2 --
10.0 L B070 Org. Plan & Iky. 1.0 3.7 4.7 5.0 1.2 1.9 3.1 .8 1.3 10IAL limen Resources 6.0 2.1 .1 10.0
- 8.4 M 7.0 4.3 11.3 5.0 3.0 8.0 .3 34.0 10rAL 8 34.0 261 . 0 1095.0 g 155.9 905.9 5 37.0 R 605.0 58.1 2u4.0 o
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1
. t e
Y va The 1982 GPUN budget, as it was proposed in November 1981, was:
Plant' O&M Capital Total ($ millions)
TMl-1 53.6 43.0 96.6
~ '
O/C 72.4 79.1 151.5-
/ Because of the further delay of the start of the Oyster Creek major
( outage into mid 1982, and the desire on the part of GPUN management to reduce expenditures, the official bu%et was revised as fellows:
Plant O&M Capital Total ($ millions)
TMI-1 53.6 40.0 93.6 O/C 60.0 65.0 125.0 Then in February 1982, when the scope of the TMI-I steam generator repairs became evident and with a delay in the availability of external funding for TM1-2 cleanup, the following allocation was made as the plan for 1982:
,, Plant O&M Capital Total ($ millions)
, TMI-1 74.4 25.0 99.4 O/C 60.0 65.0 125.0
[' The returns for 1982 will be approximately:
Plant Est. Returns ($ millions)
TMI-1 83 O/C 102 D. REPORTING OF FINDINGS
~
In the chapters which follow, BETA has provided a number of specific -
findings and recommendations whleh, if taken, should result in a more efficient operation. The chapters are grouped by divisional responsibility.
<~
In conducting the review, it was not always pensble to draw a clear line between a finding or observation which, if corrected, would directly
'; l' lead to a cost saving in contrast to just making an improvement in a given situation. For example, included in the Firidings section of this report is the observation that it takes too long to complete a personnel action. On j the surface, it may appear that correcting this problem does not necessarily
' result in saving money. We have taken the position that it does, abelt indirectly. Therefore, all findings whleh refh et on somehow improving the functioning of GPUN havs been included withn this report.
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l The detalied comments and recommendations that follow in this report are aimed at making GPUN more effective and efficient. They should not be interpreted as an attempt to change the overall goals and objectives set g by the management.
It should also be noted that due to the nature of the BETA review, which consisted of several hundred discussions with GPUN personnel, a great many minor observations came to light and were discussed, and subsequently action was taken to improve or correct the existing situation. These minor l points have not been included in the findings and recommendations which ;
follow. Those which are reported are situations either requiring broader !
management action or issues where presenty approved policy is not being l carried out fully, l i
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4 CHAPTER M
[ TMI-1 FINDINGS AND RECOMMENDATIONS r
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CHAPTER 111. TMI-1 FINDINGS AND RECOMMENDATIONS l A. GENERAL The TMI-1 nuclear plant is unique in the nuclear utility busines. It .
l has been in a shutdown condition for almost four years, not because of i material problems but because it was located adjacent to TMI-2. Since i
, there is little hope that TMI-2 can be restored to an operating condition in j the near future, emphasis by many interested and concerned groups has ; !
, shifted over to the issue of restarting TMI-1. Thus, for all intents and .
purposes the burden of proving or disproving the ability of GPUN to operate
- a nuclear facility safely has shifted away from the plant that had the accident, and the burden of proof now rests with its sister plant TMI-1.
Without arguing the merits of this philosophy, any review of TMI-1 must
~
accept that situation and attempt to understand the effect it has had and continues to have on the entire GPUN organization.
s The outside observer and even the occasional inside viewer has little appreciation for the magnitude of the effort that has faced those who were
/ charged with the task of rebuilding the confidence of the regulatory bodies, I
the public and even the people directly involved. 4 com the beginning it
'~
was apparent that this entire effort would be scrutinized and judged with a skepticism ' heretofore unheard of in this business. It was clear that major changes would have to be made in every . aspect of TMI-1, including management, design, training, technical espability, and organization. Merely dresslog up the preaccident situation would not suffice.
BETA's involvement with this proces started some alght months after the a after the decision had baen made by those~ within the GPO~
ations to take those actions necessary to regain not only the required approvals but also the public's confidence in its _abilbyAo operate a nuclear plan fel . BETA's role % .mi haWeen one of providing GPU management' an av -pret mt, independent and critical analysis of their efforts.
BETA's relationshap with GPU has not been a typical customer-client relationship. From the beginning, BETA has been in the unique position of being given complete freedom to probe any area it felt necessary and to report its findings to the highest levels of management. It has never been tasked or directed to perform a function which would undermine its position as a surrogate of an outsider looking in. Similarly, BETA has not been the architect of the changes.
~
In one of its earliest tasks for GPU, BETA undertook a review of an issue raised by the NRC and the Kemeny Commission relative to the restart of TM1-1. The issue, which was listed as a specific item to be considered by the Atomic Safety and Licensing Board, involved an assomment of GPU's (or Met Ed's) management capability and technical resources. The BETA review of this area began in the fab of 1979, and continued throughout most of 1980. There was substantial interest and involvement by NRC and others in this question which resulted in the issuance of a set of NRC criteria whleh was to be used to amist in the determination.
i While GPU did not use the NRC criteria as speelfic models to build its new organization, their existence was known and recognition had to be given to the fact that they would be used in making a final judgment on I 18
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- 2. - - ;- - z --
i Met Ed's ability to restart TMi-1. This, along with other pressures and GPUN's own desire to create a 1otally acceptable organization tended to give up the numbeir of employ ==t Thus, when BETA was tasked in December,1981, to undertake a review l
.~
of GPUN to determine if the new organization was functionine effialantly,_
it had to be done with this background in minc. -
in the case of TMI-1, BETA attempted to approach the problem i
'(
differently from the clamical cost efficiency standpoint where each function and the degree to which it was performed would be matched against a hard line official requirement. To do that would be tantamount to amassing against preaccident conditions-the very conditions that have been blamed i
for the accident. In each instance, BETA attempted to first base its asemment on a level of capability that an outside, knowledgeable person would expect to find which would satisfy the weaknemes identified as a result of the postaccident investigations. Then, once having done that, to see if there were avenues to obtain greater efficiency.
It might be worthwhile at this point to cite an example which illustrates the above. Prior to the accident, utilities generally followed the NRC requirements for selection, training and qualification of operators. This was
' done, in most cases, by using those NRC requirements and guidance issued
,~ in ANS standards in a fairly strict sense. How good a particular utility was was measured by the pam-fan rate of the applicants for the NRC
- , examinations. Little effort or resources were devoted to going much beyond 4
, this level of knowledge. A single nuclear plant havingJLor 4 people datoted to this effort was not unusual. Because of the issues raised as a result of the accident, training of operators has become much more important and
\
V) broader in scope. Today, there are some 50 peanla devoted to traininr at J lr TMI. The questions that needed to be addressed were: ~
- 1. Is GPUN meeting not only the requirements but also the intent of i b-
- those requirements so as to satisfy itself that its operators (and others) are properly trained and qualified?
- 2. Has GPUN gone too far in its efforts to have'its people trained, l 1.e., has it become " gold plated"?
i
- 3. And finally, is what GPUN doing in the area of training TMI personnel being done in a nominally effielent manner or have resources just been thrown at the problem in order to fix it?
j' BETA reviewed an of the basic elements which today constitute j
esential functions. These included:
i
- a. Overan management 4
- b. Engineering / Technical j
- e. Operations
- d. Training
- e. Maintenance
- f. Radiation protection
- g. Quality amurance
- h. Nuclear safety asemment 19
._ ? ---A -- ~ - -
4 -
- 1. Licensing
- j. Emergency planning
- k. Security L PacDities
'- m. Fiscal management
- n. Human resources
- o. Labor relations
- p. Industrial safety
- q. Public relations
- r. Fire protection - -
! s. Environment ~.
in general, what was found was that in each category, substantial 1
changes had been made resulting in improvements. New people had been i
- added and, in some cases, neople had been replaced. With very few I
exceptions, BETA could find go unnecessary function or tas'k belnr performed.
(' There were cases where BETA has concluded Thi't efficiencies can be realized and. that these functions and tasks can be performid with less people. The specific cases are either detailed in the chapters which follow or have been 4
i transmitted orally to GPUN management (Offlee of the President). '
eeee
- ; TMI-1 SITE MANAGEMENT FINDING III-A ,
! The role of the Director, TMI-1 needs to be clarified and strengthened with respect to his over-all site responsibilities.
/
DISCUSSIO",
1 k One major change which came about as a result of the creation of I GPUN was that of going to a functional organization. From the point of view of the Plant Director, this meant that instead of essentially being totally responsble for everything and everybody at the site, his direct responsibility and authority was reduced.
i While the actual shift in responsibility was not that great, the perception was created that the Plant i Manager was no longer directly responsible for a number of areas critical l to the plantsetc.
warehousing, namely, training, radeon, QA, major engineering, security, 3
j As the new functional organization was put into place, much attention was Directors. to the fact that these functions became the responsibility of other given i BETA is still of the opinion that this form of functional organization is appropriate and worthwhile, but it also feels that it is the
!' most difficult to make work. Generally, people have little trouble
} understanding a straight line project organization where there is one person responsible for all aspects of a given unit.
j It becomes much more difficult j when various Directors become responsible for " pieces" of the jobs. The i Director, TMI-1 clearly understands tt s and has made substantial progress i
in establishing a working relationship with the other Directors. However, there needs to be a better understanding across all Divisions that while all l
Directors are " equal" on the organization chart, the Plant Director, in reality, 1
- 20
4 is a little bit more equal. This does not mean that any responsibility, is taken away from the other Directors. It means that the Plant Director has
' the ultimate responsibility to make sure everything or anything that happens at his site works to his satisfaction. If it is not, then he must take it on,
, working with or through the other Directors. In the final analysis, if something at the site fails to function properly, be it security, training or the like, the Plant Director.would, and should, feel responsible. It should not be like the street car conductor who says he's in charge--but in reality, isn't. Only the Plant Director is permanently located at the site and has the ability to see firsthand what is going on. He must be in a position to ;
use whatever resources are available to him to cause proper action, but still :
work within the framework of the functional organization.
Another aspect of this problem is that there is a tendency for the other Directors to feel not totally responsible for the outcome of the entire effort. For example, other Directors who provide support services to the plant, should not look upon their jobs simply as isolated segments of the whole. If a problem exists at the plant wherein a Division has some element
' of responsibility, that Division should feel responsible for the total final I outcome and not take the position that it has done what was asked for, and if the end product did not happen to come out right, then that was somebody else's fault. There is also little to be gained in spending hours in meetings trying to decide whose piece of the job failed.
I While these comments derive not so much from observing the Directors -
themselves, but from lower levels within the organization, the Directors are -
responsible for making sure their people evidence the proper support.
RECOMMENDATION
. a. As an important ongoing effort the Office of the President needs to reinforce the understanding not only of the various Directors, but also of lower levels in the organization, of just how a functional organization is supposed to work. These actions should include the Office of the President evidencing a greater sensitivity to instances where the functional organization breaks down and using these instances as examples. Similarly, the Office of the President must ensure that it is not weakening the functional concept by directing contrary actions in the name of expediency. As difficult as it may be, every effort should be made to make the organization work, not bypass it when convenient.
- b. Efforts need to continue emphasizing that all Divisions, other than the plants, are support divisions. They perform a supporting role to the plants. If the plants did not exist, they would have no job.
If the plants do not work right or efficiently, the support divisions l' are probably not doing their jobs correctly, and they can't pass the blame off.
- c. The Directors need to impress on their people that the time has come to stop worrying over, and spending time on jurisdictional issues. There is little to be gained by attempting to put a jurisdictional definition in black and white on every situation that l
l l 21
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Arises. There will always be grey, undefined areas, where somebody just does the work and doesn't argue about who is supposed to do it. -
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- d. The Director, TMI-1 needs to impres upon his senior people that they need to make the new organizatlan @ hv t, not fightirg it. They need to understand that people in 4
isions !
have just as much a stake in successful operation as they do, and i -
that if there are shortcomings, they.need to do what they can to help eEminate them, but not to bypes them.
-l
- e. The Director, TM1-1, in concert with other Directors, needs to 1
i find a way within the currest procedures to stimulate a freer flow g
i of discussion between Divisions without having to bring aR-subjects '
up to the Director level.
~
- f. The Director, TM1-1 needs to instill in his senior managers the concept that their complaining about corporate policy " upward" is acceptable and encouraged. Complaining " downward" is not acceptable. This comment, while listed under the Director, TMI-1, g applies equally to all Division ~ Directors.
eeee J
- [, TMI-1 OPERATIONS j FINDING 111-B .
I j
The positions for five " engineers" presently reporting to the TMI-1 1
Manager, Plant Operations should be better defined.
DISCUSSION
~
j i There are five " engineers" presently reporting to the Manager, Plant i Operations.
j While the functions that this group performs may'be necessary and might need to be retained, it should be determined if they were created to serve a speelfle purpose in the past and if their existence today is still necesary. Based on the BETA review, they are not performing functions '
which could be truly called engineering. This may be a problem in I nomenclature. In BETA's experience, an employee given the title of
" engineer" is usally a person with a college degree in engineering and if the ,
l*! job is one whleh requires it to be filled with an engineer, it is usually an engineering job.
i l
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)
lt is also possible that staffs such as this came into existence because of frustration in not being able to obtain necesary work from those i
organizations asigned the responsibility. !
' l While there are exceptions, every effort should be made to have plant !
t engineerity functions performed by Plant Engineering. This will ensure that !
there is a proper degree of supervision over all engineering work conducted at the site. BETA recognizes there are tasks to be performed outside of !
Plant Engineering that are best done by people with engineering background and experience. When this is done, great care must be exercised that these i
groups do not usurp engineering responsibilities asigned elsewhere. i e
t 22
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RECOMMENDATION
~
I -
g The five engineering positions reporting directly to the Manager, Plant Operations should be better defined. If they are performing a necessary
, r.onengineering function, such as planning, scheduling, budgeting, etc., then the positions should be redesignated and filled with appropriate people at salaries commensurate with the tasks. If they are truly performing a plant engineering function, then a determination should be made to ensure that the function is not better performed by Plant Engineering.
3 TM1-1 MAINTENANCE FINDING III-C Maintenance at TM1-1 can improve its support of the plant. l DISCUSSION The performance of maintenance at TM1-1 has improved significantly j
during the last two years. However, weaknesses still exist _which tend to ,
derrade the quality 4uantity, and efficiency of maI6tenance work. For
, examples
- a. There are 151 people in the Maintenance Department at TMi-1, [
comprised of 106 work force people and 45 who are in management, supervisory or suppet positions. In effect,45 people plan, cupervise and account for the work of 106 others. Since 6 foremen and 59 workers are assigned to the six rotating shifts, the daylight maintenance force is comprised of 39 people in management and sgport positions, with 47 people in the work force. The daylight jt shift is obviously the main shift, with support available from management, work planning, clerical support, machinists, stores, transportation--all that is needed to make the work move. Yet, a review of maintenance department performance reveals that most l{
maintenance work is done on the two backshifts with 10 worVers'
? and one foreman on each. The~eonclusion has beein reached in i
the Operations Department (the Maintenance Department's r
customer) that they don't expect to get much work done on the daylight shift-it is too hard, too many people interfere with the work, too many other things get in the way. Much of this is I brought about because it is during the dayshift that the heavily manned modification work is performed causing the normal maintenance work to be paper-worked rather than mechanic-l worked.
l One principal difference between the backshifts and the day shift l Is in the supervision of the rotating shift maintenance people. At night, the rotating shift maintenance force is under the control of the Shift Supervisor, whereas the rotating shift on day shift is under Maintenance Department management with the regularly assigned daylight shift people. An improvement in efficiency is likely if those in the rotating shift on day shift were assigned to 23
_...___.,__ _ _ _ _ _ _ _ , _ . _ _ _ - .._._. .~ _ _, _
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- the Shift Supervisor for accomplishment of jobs less'than one shift duration, and those regularly asigned to daylight could undertake -
the longer duration jobs. This should help abate the feeling in Operations that "nothing can be done on day shift."
b._ The BETA interviews of site people concerning maintenance at TM1-1 had a repeatisq: theme that: " Problems do not get solved."
l There is the percept on at the site Inst repairs are mace, tne
}. component is returned to service, but the _ problem that caused the s falkre has not been solved. Our review indleates that wnen this ~
' situation occurs, is k bociuse Engineering has not been broul$t i !'
j, into the solution of the problem. This falkre to obtain engineer ng - l
- support is a problem in proper supervision, both in the Maintenance Department and Plant Engineeringr, a
i
+
- e. There is a genuine concern at the site over the contemplated ,
'
- transfer of the corrective maintenance work to the M&C Division.
- Mr. Arnold's letter of May 27, 1982, to the Ylee Presidents directs a realignment of the maintenance function at both TMI-1 and
( Oyster Creek, whereby the corrective maintenance function will ii be assigned to the M&C Division. That shift has taken place at i
Oyster Creek but will not happen at TMI-1 until a date is selected
' "whleh wiR not interfere with restart". Because of the magnitude
' of the change and the need for stability at TMI-1 at this time, it is recommended that the date selected be later than the currently
!, scheduled restart date. There will be some temporary disruption
- In the Maintenance Department when the change is made which
- jI can be accommodated easier after the current restart effort is l completed. Although there are some shortcomings in the current
- maintenance program, the program is adequate to carry the plant 4
to restart.
I AECOMMEN DATION l
- a. Deliberately schedule more work for the day shift. Increase the effort of those in supervisory support positions toward clearing the interfarences that slow down work on the daylight shift. Put the i
same effort into planning and scheduling " tomorrow's" daylight j shift as is currently devoted to " tonight's" back shifts.
j b. Assign system responsibility in Plant Engineering. Establish the j concept of the cogniaant engineer. Ensure engineering review and concurrence, and, when thought necessary by Plant Engineering, direction of maintenance actions planned and in progress.
, c. Do not make the change of assigning the corrective maintenance i
function to the M&C Division until after restart of the Unit.
r I '
i l 24 l
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._m.-, .. --- - ~ ~~~
TMI-1 CHEMISTRY FINDING IE-D f
Ma)r defleieneles in the ehemistry program at TMI-1 were identified two years ago, Corrections have been slow.
DISCUSION
[-.
TMI-1 has recenthr reorganised to strengthen the chemistry program.
The position of Chemistry Manager has been added. An experienced manager .
with a degree in chemleal engineering has been moved into this position from another job at TM1-1. Efforts are being made to hire two staff
.l ehemists to help revise the large numbe of chemistry procedures and to provide other heb in upgrading the ehemistry program.
All of the previous ehemistry group except its supervisor was moved from Plant Engineering to Operations and Maintenance. The functions of the single chemistry person remaining in Plant Engineertry are to provide a day-to-day overview of the ehemistry program, to prov:de interfaos with t
others on technical problems, and to help solve chemistry problema. Retaining i
this ehemistry involvement in Plant Engineering is also needed to help ensure ehemistry is actively considered in engineering deelsions where chemistry :
has not received enough attention in the past. -
f I
RECOMMENDATION
- BETA considers TMI-1 is on the right track to upgrade its chemistry #
program, it is partleularly important that the Director TMI-1 have a key
- p manager he can hold accountable for ehemistry operations; the chemistry manager should develop this responsibility. It wiu be more effielent and
- i
' produce a better product if the ehemistry analytleal procedures for TM1-1 and Oyster Creek are standardised. The two chemistry managers should take action to force this standardisation.
!l ji ....
!- TMI-1 PLANT ENGINEERING j FINDING IE-E i(
The number of different engineering groups at the site is contrbuting to loss of effielency.
j DISCUSSION i'
i There are at least 21 different section level groups having engineers at the TMI-1 site reporting to five different Division Directors. This leads l
j to confusion in some esses as to whleh group will handle a given problem.
lt causes a slowdown of work due to the need to peu a technical document through a number of these groups before it can be issued. Many of these l groups are necessary, and they should be separate. However, it is BETA's 1
! 25
. _ _ _ _ _ _ _, . _ . _ -j l
.l opinion that there are too many of them. As long as the plant has been '
shutdown this problem has not loomed larger than an ineffielent annoyance.
The time win soon come when there will be a need for rapid engineering ,
and technical work to be accomplished. Under the present circumstances, f, this eeuW be hampered by the large number of groups due to the noneohesive engineeririg strueture.
RECOMMENDATION
{ The various engineering groups at TMi-1 should be reviewed with the
~.
goal of reducing the number. In the engineering areas, if there are several
- different groups within a given division, there should be one person at the site designated as the lead Division representative who would assume the adminhtrative and other responsibilities other than techniest eeee t TMI-1 _ RAbiOLOGICAL CONTROL FINDING 15aF ~
There are too many instanees where radiological controls are not as good as they should be. The work force has not accepted enough of the rerbility for high quality radiological work performones. Excealve N generation of radioactive waste is part of these ' problems, %__/
- c DISCUS 8lON
BETA has been constantly involved for three years at au levels of GPU in upgrading the radiological control program at TMI-1. Since BETA s has frequently discused with top offleials its detaued findings and recommendations on radiological controls for TMI-1, an overview wiu be j more useful in this report.
Management support for a strong radiologleal control program continues to be apparent not just in the words used, but in the eBoostion of money and manpower. In three years of making improvements, however, the stated objective of a high quality radiologiosi control program standing among the best in the industry has not yet been achieved. As a result, the perception persists that radiologion1 control continues to ineresse costs and to prevent work gettiry done. The next steps are essential to ineressing effielency and doeressing time and ecot of radioactive work.
.I*
There are two fundamental steps in developing a high quality radiological control program. The first step is reducing to sman numbers and to sman significanoe the radiologloal defieleneles found in routine daily
work. The term radiologlost defieleney b used here to mean anything that could have been done better. TMI-1 has reached the stage where few of its radiological defieleneles are of enough significance to be noted by NAC inspeetoes.
TMI-1 has reached the level where it can be called average in comparison organisation.
with other utilities in performance of the radiologleal control Nevertheles, there are far too many defieleneles, there are too many esses of loose control of radioactive contamination, there is too much radioactive waste, and the performance of radiological control personnel 26
.. . . -.- : ..= - - - -
= = = . = -
i and of radiation workers is often poor. Inevitably, this kind of situation -
means there will be some important deficiencies. Preventing the big problems requires keeping the sman ones under control so that there is time to plan for and to antielpate future events. -
l- Thh first step may be recognised as the traditional approach to aehleving compHance. it can lead to a mi in mum level of radiological performance where violations of NRC rules are uncommon. Since it relies f ' primarily on a " police force" approach by radiological control personnel, this
( approach aan not by itself raise the radiological work performance to the :
desired level. There can never be enough " policemen" to prevent the worker
- from making a mistake. BETA has never observed a high quality radiological eontrol program whleh has not gone through this upgrading step, but the j second step b also required.
}
i This second step h getting the work force and their supervisors to p
believe that exceuent radiological performance is the normal way to work j .
and to demonstrate this belief in their routine work. In theory, this could be independent of step one. In praettee, the radiological control organlaation 1
! has to set the example. To achieve this performance requires a radiological control force that beHeves in getting the work done, that wlR show the workers how to do it right instead of just stopping what is wrong, that wul evolve to more than a "pollee force". However, the responsbility for this
]
second step b with the work fores. The radiological control organisation
!, can force step one, but they een any set the stage for step two-they een '
not make it happen. -
i The major advantages of a high quality radiolagleal control program do not show up untu late in step two. The normal measures of radiologleal i, performance need to improve, such as manrem, frequency and severity of i
abnormal occurrences, personnel contaminations, amount of radioactive waste, i, and numbers of radiologleal defielencies. But then, the feature that surprises i 4 many is that east and time to do work wiu deeresse. There wiu be less rework. Better planning will pay off in reduced manhours for work
- i performance. There win be fewer events whleh stop work wh!1e senior personnel scramble to resolve problems. There will even be a decrease in sine of the radiological control organization. ;
1 3
': The status at TMI-1 la that the radiologleal control organisation is i won into step one, but the work force is stlE in earW stages of step two. '
The TMI-1 radiological control group has had a number of changes to strengthen its management. As a result, however, each of the managers in ,
this group b new to hk job within the last few months. Only one of the f
t five radiologloal engineers who are GPU employees has more than one year expertenee in radiological engineering at TMI-1. There are many
! Improvements needed in the radiologloal control group, but there are in place i
systems for identifying these items and the commitment to make the improvements. The greatest need inside the group is to raise their standards for compliance with good radiological practices. At the same time this
' group needs to make a major improvement in its relations with the work :
i force. The perception that the radiologleal control group is merely a plice !
i force in charge of stopping work has not yet been corrected. When functLoning ,
wel, this group should be of major help in getting the work done. Further i upgrinding is also needed in training of radiological control technielans and !
I
~
l 27 v-.,,n-,,,n.-.,----e--nm --m,----,-o-c,,,,,,--nnwwww ew-w,-wr m em-we - r w =~-wn ~wm +ww w e eww nm~w m - w--- wr v -,w w--vv-w w-m-~ww~ ' ~ - - - - " '
.;n - - - - n _n - ~ n .__ ._ _ ~ - - -.__
! foremen to handle unusual situations not covered by written procedures. -
Such training has recent$ commenced using seminar sesions for small groups.
In thF work force the greatest change needed is to make good I
radiologleal performance a natural. part of each job. The old negative i
attitude of operations and maintenance personnel being against radiological oontrols has been stamped out, but it has not yet been replaced with the needed positive attitude, AECOMMENDATION 4 a, Ineresse the efforts of managers and supervisors to get exceDent I
I radiologicalperformance as an inherent part of every job performed by their workers. '
^
I b. Improve the working relationships between the managers and i
supervisors of the radiological control groups and the managers 5 and supervisors of the work force. This requires station !
l management as won as radiologloal control management attention l j
i since a one-sided effort to cooperate win not work. '
- o. Upgrade the performance of radiologloal control technicians by 9
improving their ability to identify and report radiological defleieno6ea, j
i f
( !
d, Speed up the correetion of radiologleal defleiencies and increase -
i the attention on solving problems whleh lead to repetition of i defieleneles. Both radiological control personnel and others in the station are required for these efforts.
1 s a. Deeresse the numbers of radiologleal control technielans as the r
work force pleks u .
r- work performance. p its own responsbility for good radiological !
I i'j, f. New written peceedures, new management systems, new
(
j committees, and new gimmloks a and not be considered necessary to carry out these recommendations. Each one of the i recommendations is a logleal extension of what has been started ,
and would likely be defeated if buried in new paperwork. !
eeee '
TMI-1 MATERIAIA MGMT '
il Warehousinr i
i FINDING 15-0-1 i 4
' The warehouse inventory reenrds have enough nomenefature inaccuracies to degrade effieleney. !
t DISCUssl0N t
- t The inspection of Maintenance Department work planning revealed that i j
the warehouse inventory records were inaccurate to the point as' to be
- l i
L t .
28
, . - - , - ~ - - . _ , , _ - - , - . - , _ _ - _ -.- ,_- - ,-- _, - - _ _._m-_.--.._ . . . , _ . ~ , , _ _ .,
considered unreliable by the job planners. The records were used when -
asembling the material for' a job, but only after the planner had been to the warehouse to personally sight the required material-verifying its location and the quantity of stock on hand. This obviously degrades the efficiency
, of assembling material for the job. In fact, the Maintenance Department
/ has chosen to asign a material runner to amist in locating and asambling -
material for a job. An inventory of stock on hand has commenced since
- - that initial observation and when completed, should resolve the problem referred to above.
Three months after the inventory referred to above had commenced b p
and was in progress, BETA reviewed the number of adjustments to inventory found to be necesary. The number was surprisingly smalk It now appears that the principle deficiency with inventory records at TMI-1 [is nomenclature i
~~ The stock is not defined with words suitable for letting a user seek out and .
determine the stock he need{
RECOMMEN DATION 2
To improve the efficiency of using stock material, a program should be started in close cooperation with the job planning section of the
~ Maintenanes Department to verify or revir,e as necesary the nomenclature used in the inventory recorda.
eeoe r TMI-1 MATERIA!A MGMT '
, 5tock Levels FINDING !!!-O-2 The amount of stock a't TM! is excesive.
'f DISCUSSION There are approximately 60,000 line items of stock material at TML f Approximately* 8,000 line items of stock experience some turnover action in L
a year, while 52,000 line items remain inactive. This inventory could be reduced to improve efficiency and reduce the cost of stores handling. This 1
. proposed reduction of sjt ek should be carefully coordinated with maintenance '
.and engineering, since Lthe current usage records, with the plant shut down, are not truly indleative of the need for stores when the plant will be operating. Some recent attempts to reduce stocking levels of infrequently _,,
- used stook have created material availability problems for maintenance work.J '
BETA reviewed the procedure that is now in use to reduce stock on hand in an orderly and effielent manner, and concurs in the approach. BETA was I
also informed of plans for selling 10,000 line items of material unique to l TMI-2.
Another aspect of stock at TMi is that there is no scheme for purging
' stock from inventory when technical or administrative requirements prohibit the use of matetial presently in stock. '
I i p
4 29
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~
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RECOMMENDATION ~-
P v
' ' Material that will not or can not be used by TML should be purged from stook.
i eeoe
- e-
~
3 TMI-1 MATERIALS MGMT Purchasing FINDINO 15-0-3 ;
t The pelod of time from preparation of a requisition to delivery of purchased material is too long.
1 j DISCUNION i
Our discusions with maintenance people repeatedly came to the point
? where concern was expressed for the difficulty encountered and t e required 1 ,
to purchase matarlaL In pursuing this issue in TML purchasing problem ,
4 could usualh be tracked to the difficulty in getting a sul purehase i
i specifloation or in gettJng a copy of the ordering data for the previous order of the same material
} ,
t
' Oyster Creek has. made signifloant progress in devebping punrhase speelfloations for stock material, but TMI has not.
- r Program has been made in microftehing, for the ready reference of requisitioners, copies of previously issued purchase orders and the inventory records have been modified to indicate the previous purchase order numbers, in spite of the diffleulty deserbed above, the trend in warehouse issues l and purchasing activity ftem 1980 to 1981 (no data for 1982 available yet) g rg indiostes that the availability of material is improving.
The purchasing eencepts of blanket purchase orders, limited purchase orders, and recently restructured local purchase orders are calculated to reduce the effort required of the requisitioner and decrease the time for procurement of small value items. Their use is encouraged, RECOMMENDATION
$ To improve the effielency of purchasirs, Plant Engineering should be i
tasked to prepare a compilation of purchase specifications, approved by Plant
! Engineering and QA Engineering, for spare parts and consumable stock items i
for ready use in replenishing stores. The work being done at Oyster Creek j should form the basis for the TMI work.
?
I l
I
! . 30 L.- - - - . - .
. = - - - - ~
. - - . = - ~ ~ . , . ,- - - --- - ---- -. -- --
eee. .
TMI-1 HUMAN RESOURCES FINDING !!I-!!
There is a need for the TMI Human Resources group to improve further -
their responsivenes to site needs.
DISCUSSION j
At TMI, under the Director, Human Resources, there is an Area Manager, Human Resources and a staff of fourteen people who handle f~ personnel and industrial relatiens matter]s for both TMI-1 and TM1-2. There
% five people assigned to industrial relations, seven to personnel and three to the Area Manager. Based on BETA's jug t, this is more people than I
necesary to carry out the functions assigned, t is'of concern, however, are the number of commen_tp made by TMI-1 e people that this group is not responsive to site needs. There were indications that this situation was 3 improving, but still neededisnprovement. One of the side effects of having too many people to do a given job is that peripheral jobs get created in the form of writing new personnel procedures, studies, analyses, etc., which tend to distract from the original purpose of the group. Several years ago, t
there was a need tar have a sizable Human Resources force at TMI in order to handle the heavy influx of new people. This has slowed down now and it
- is time to relook at the manning. -
RECOMMENDAMON The Director, Human Resources, should review the manning of his TMI group to determine if it is still necessary to be as large as it is. He should also discus the effectivenes of his TMI group with the TMI-1 Director, to find out ways that his operation can.be more supportive of site needs, ee TMI-1 ADMINISTRATION FINDING 111-1 A review of the number of people assigned to administration work at TM1-1 appears excessive.
I DISCUSSION L
For discusion of this finding, refer to Oyster Creek finding IV.I.
RECOMMENDATION See Oyster Creek finding IV.I.
9 e
31 i
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e B84 CHAPTER IV q .
OYSTER CREEK FINDINGS AND RECOMMENDATIONS 6
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l CHAPTER IV. OYSTER CREEK FINDINGS AND RECOMMENDATIONS The BETA assessment of the Oyster Creek plant followed guidelines similar to those outlined for TMI-1. The differences came about. primarily because of the situation existing at Oyster Creek in contrast to that at TMI-1:
Oyster Creek is an operating plant owned by Jersey Central P
Power and Light. Jersey Central is part of the GPU system and - -
part owner of TMI, but not responsible for the operation of TMI, whose licensee is Met Ed. Oyster Creek was geographically and 3
organizationally distant from the accident. It was not forced to
- _ , shutdown as a result of the accident. In some respects its role paralleled that of any other nuclear plant outside of TMI. Once the effort to create the GPUN Corporation was started in early '
1980, this role began to change. However, Oyster Creek was not brought under the GPUN umbrella until some time later
, (September 1980) even though the Oyster Creek people knew it a
was going to happen.
~
In BETA's ' opinion, these differences created conditions at Oyster Creek that were unike those at TMI-1. For understandable reasons the people at TMI-1 have been more prone to understand the need for and to accept changes than those at Oyster Creek.
Also,.the people.at.TMI-1 have been. operating directly under the new GPUN system for almost a yer; longer than those at Oyster Creek, and as a result, are more settled down and comfortable with it. In addition, there were st!Il changes being made in the organkation and in key personnel assignments at Oyster Creek
" throughout the period of the BETA review, a period when preparations were also underway for a major outage. In short, Oyster Creek lagged TMl-1 in having in place those organizational entities upon which BETA made its TMI-1 assessment. Recognition had to be given to this fact.
Another aspect that bears upon Oyster Creek differently
' than at TMI-1 relates to the material condition of the plant itself.
Oyster Creek is five years older than TMI-1. At the time of the accident Oyster Creek had ten years of operation whereas TMI-1 had five. Oyster Creek is a BWR while TM1-1 is a PWR; l this inherently makes Oyster Creek a more difficult plant to
' [' maintain because of the larger extent of radioactivity throughout the plant.
As a result of TMI-2 post-accident requirements by GPUN, maintenance gained added attention and Oyster Creek found itself with a fairly large backlog of maintenance work. This, coupled with two potentially serious plant technical problems (sparger and l torus) that could require extensive work, caused the outage, originally scheduled to begin in 1982, to increase in scope.
l There are more GPUN people assigned to Oyster Creek than to TMI-1 (1119 vs 919). The 1983 proposed budget (current status) for Oyster Creek is $155.8 million vs $85.6 million for TMI-1.
These differences are reflective of the situations previously -
i 32
. . _ _ ,. ~__"*~.
_ - - ,, ,,,.___a w.,%- mm
~
l i described, but principally due to the Oyster Creek outage now scheduled to start in February 1983.
i
( It was .within this framework that BETA conducted its review. - As in the case of TMI-1, BETA found, with a few exceptions, no function, task I or work effort that was being performed unnecessarily. _ Many functions and I people were still in the early stages of development and, because of that,
- functions were being performed by people who did not yet have a clear l r understanding of what needed.to be done. it is also significant that over
{ the past two years Oyster Creek has had four different plant directors. This alone was cause for unrest and confusion.
{ Throughout this period of change it was essential to maintain the proper i level of key personnel experienced with and qualified on the_ Oyster Creek plant. This had to be done, and it was. But it has had a slowing down
[ effect on management's abDity to bring new people into the organization.
In an overall sense, there are more avenues to improve efficiency at Oyster Creek than at TMI-1, but they will be more difficult to achieve in l
the near term because of their earlier stage of development. It is also i apparent that even when the 1983 major outage is completed at Oyster l Creek, there will still be a significant backlog of - maintenance and modification work remaining to be scheduled for the following outage. This i
'will further delay the day that Oyster Creek could be characterized as being in a normal, settled down condition of operation.
~
l ....
l
'~
O/C SITE MANAGEMENT l Role of the Director
!~ FINDING IV-A-1 1 ,-
The role of the Director, Oyster Creek needs to be clarified and strengthened with respect to the overall site operation.
DISCUSSION This finding is similar in nature to that at TMI-1. While there are differences in degree, the same recommendations apply. At Oyster Creek there is a tendency for the Director and his managers to focus on problems and areas under their direct control. to the exclusion of problems of other groups _ which also affect the plant. BETA could see improvement in this
( situation during the period of the review. However, there needs to be a greater understanding at all levels of management responsible for overall site operation. In the early stages of the BETA review there was noticeable infighting at the site, particularly among groups reporting to different Divisions. This infighting evidenced itself in finger pointing, lack of cooperation and, in some cases, malicious bypassing and stalling to hold up work. We found few groups who held other groups in high regard. In late 1982, when BETA returned to Oyster Creek to check on its findings, this situation had changed considerably for the better.
33 L_______ = : = == --
=-
P*
While there has been improvement, efforts to correct this situation need to be continued because the net result is that work still takes an
. Inordinate amount of time to accomplish. It has also resulted in the swelling of the rolls as each group feels the need for more people to either enhance their position or to do work normally done by others.
This problem will not disappear overnight and will not be solved by ordering it so. The Director, Oyster Creek can and shouM have a direct l hand in correcting this situation by first working on the managers (all of
- them) assigned to the Oyster Creek site. His interests should be universal and not division-oriented. This problem exists in all areas throughout the site.
While the recommendations which follow are identical to those provided for TM1-1, there are differences mostly brought about by two situations:
- 1. Oyster Creek lags TM1-1 and consequently, has further to go to 1
achieve its goals. This is further impeded by the waning, but still
.present feeling at Oyster Creek, that they are " outsiders" in the
,.- GPUN organization.
l
- 2. Oyster Creek is the lead plant on shifting maintenance from the
, plant to the newly formed M&C Division at the same time the plant is beginning a major one year outage. It is going to take Herculean effort on the-part of the Director, Oyster Creek and the Director, M&C and their managers to make this work, particularly in a productively efficient manner. -
RECOMMENDATION
- a. As an impwtant ongoing effort the Office of the President needs to reinforce the understanding not only of the various Directors, but also oflower levels in the organization, of just how a functional wganization is supposed to work. These actions shoukt include l the Office of the President evidencing a greater sensitivity to instances where the functional organization breaks down and using-r these instances as examples. Similarly, the Office of the President j
- must ensure that it is not weakening the functional concept by
- directing contrary actions in the name of expediency. As difficult as it may be, every effort should be made to make the organization wwk, not bypass it when convenient.
- b. , Efforts need to continue emphasizing that all Divisions, other than i
the plants, are suppet divisions. They perform a suppwting role to the plants. If the plants did not exist, they would have no job.
If the plants do not work right or efficiently, the support divisions are probably not doing their jobs correctly, and they can't pass g ,
the blame off.
- c. The Directors need to impress on their people that the time has come to stop worrying over, and spending time on jurisdictional issues. There is little to be gained by attempting to put a jurisdietional definition in black and white for every situation that arises. There will always be grey, undefined areas, where somebody just does the work and doesn't argue about who is supposed to do it.
34
_ _ _ _ _ lii --- - . L--
- d. The Director, Oyster Creek needs to impress upon his senior people that they need to make the new organization work by using it, not fighting it. They need. to understand that people in other Divisions have just as much a stake in succesful operation as they
- do and that, if there are shortcomings, they need to do what they een to help eliminate them, but not to bypas the organization.
y e. The Director, Oyster Creek in' concert with other Director , needs to find a way within the current procedures to stimulate a freer flow of discussion between Divisions without having to bring all y subjects up to the Director level
- f. The Director, Oyster Creek needs to instill in his seniw managers the concept that their complaining about cwporate policy " upward"
~
is acceptable and encouraged. Complaining " downward" is not acceptable.
eeee
[ O/C SITE MANAGEMENT 8
Plans and Programs
, , FINDING IV-A-2
. L The functions now performed by Plans and Programs could be accomplished more efficiently.
DISCUSSION Repeting to the Director, Oyster Creek is a function entitled Manager, Plans and Programs with a staff of five people. The BETA understanding is that this group is to assist the Director in matters involving interface between the plant and other Divisions, keeping track of commitments by others affecting the plant and establishing the requirements by the plant for the accomplishment of key events to plant approved cardinal date schedules.
BETA acknowledges that this is a useful function and that usefulinformation is provided to the Director. However, as currently functioning, BETA concludes that, in some respects, it is redundant.
The risk associated with having a group like this reporting directly to
- the Director is that they will asume, and to an extent have assumed his mantle--becoming authoritative and regulttory in their contacts with other functional groups. Better that this group kept totally complete records and status of plant commitments, displaying requirements, obtaining commitments hom other Divisions and other plant departments, and following up to determine problems that will be of concern to the Director.
For example, establish key events and cardinal dates for issue with the authority of the Plant Director, but do not gecify or schedule the actions required by others in meeting cardinal dates for key events. BETA encountered too many instances where resentment, antagonism, and recalcitrance was being induced by the actions of Plans and Programs in attempting to schedule and direct work which is the responsibility of other l departments or divisions to accomplish. Obviously, Plans and Programs must i
l 35
s .
W
.~
be aware and be capable of recognizing problems that will interfere .with proper and timely completion of key events, but they are not, nor should they be, staffed or qualified to regulate the functions of others.
RECOMMENDATION
.I
- a. Hold the size of the Plans and Programs section to its current' size for establishing key events, cardinal date schedules, and status of program and problems. ;
b.- Do not use Plans and Programs as a line authority organizatfori scheduling and directirg work, rather as a service organization identifying problems and assisting the Plant Director in his dealings with other division directors, as these problems relate to F' performance in accordance with existing commitments, key events and cardinal dates.
I -
e -
s O/C OPERATIONS FINDING IV-B
- l. Thera is a lack of involvement by Operations in Oyster Creek operator training.
DISCUSSION As previously indicated, Oyster Creek is about one year behind TM1-1 in having its training program in place. One cf the problems encountered and solved at TM1-1 was a lack of involvement by Operations in the training program. This same problem is in evidence at Oyster Creek.
RECOMMENDATION The Director, Oyster Creek should make whatever adjustments are necessary to ensure that Operations is more involved in the Oyster Creek training programs, especially operator training.
i
- O/C DECONTAMINATION 4
l FINDING IV-C Workers do not pick 19 after themselves.
, DISCUSSION A large part of the work of the decontamination group has been cleaning up af ter workers. Although there have recently been some improvements, the performance of workers in this area is worse.than BETA has observed elsewhere. This sloppiness increases the work of the decontamination group,
, increases the generation of radioactive waste, increases radiation exposure, 36
=- - ..
g, _.
- _ = ~ . - - .-
=
spreads radioactive contamination,' and increases costs and time to do work.
It has also been one of the causes behind the excessively slow improvement in radiological performance of the work force.
, , RECOMMENDATION Managers and supevisors need to keep on their workers so that it is uncommon, rather than routine, to leave a mess at the end of a work period.
eoee
- t :
O/C MAINTENANCE FINDING IV-D-1 j The ability to perform maintenance on the plant in order to assure a reasonable degree of reliability needs substantial improvement.
I DISCUSSION l This is a broad but,important issue. The BETA review was conducted l
during a period of drastic change and one that is still in its early stage of development. In October 1982, the primary responsibility for the performance iL of maintenance work was shifted to the Director, Maintenance and Construction and away from the responsibility of the Plant Director. This is a new concept and it is being inaugurated coincident with the start of a major one year outage. BETA will not dwell on problems which were evident before the change took place but will concentrate on high-lighting areas r, that appear to be causing difficulties today and particularly those associated with the transition. A number of the problems. cited existed prior to the
.. transition and appear to still exist.
Even though BETA will confine its comments to the transition period, it is worthwhile to understand the situation leading up to the present. At the time of BETA's initial review at Oyster Creek in April 1982, various excuses were advanced to explain the poor material condition of the plant such as: a lack of engineering support during maintenance, clumsy design with difficult access or durability, poor chemistry control, inadequate cathodic protection, etc. However, the fact remains that the maintenance roll was large and the material condition of the plant was poor. The backlog of
_ corrective maintenance job orders was ever increasing, the rate of accomplishing preventive maintenance was a fraction of that planned, and the same maintenance problems recurred. in spite of the large Plant
^ Maintenance Department, heavily staffed with supervisors, engineers, and clerks, the M&C Division was maintaining about 80 contractor mechanics on site during nonoutage periods to perform essential jobs that could not be
- accomplished in the required time or with the required capability by Plant Maintenance. Easing the Maintenance Department's load by assigning a large Site Facilities group, staffed with utility workers to accomplish maintenance
( tasks not directly related to the generating plant, has been useful, but not to the extent that Plant Maintenance was producing the desired material condition.
37 u__-. .
- ~ ^
' ^
5 There were severalgroups at Oyster Creek categorized as maintenance:
Corrective Maintenance, Preventive Maintenance, Facility Maintenance, l Maintenance and Construction, and Site Facilities. Altogether, there were
{
approximately 350 people in these organizations during nonoutage periods-all '
with responsibility to maintain the plant, and yet, the plant was not being I adequately maintained. Heeremy examples of maintenance job orders being reported complete when no work had been done, 'of temporary fixes that lasted a week, of repeated occurrence of the same material problem, or of l long delays before starting required maintenance were cited by operators. I
'( While most complaints were in the mechanical area, there were sufficient examples in electrical and 1&C to make it an across the board . issue.
{ During the period of our initial review, the Maintenance Departm'ent I
was under the management and supervision of people who, with a few exceptions, have been at the plant during the entire time that the situation l deserbed above developed and persisted. These are valuable people because i of their knowle%e and experience with the plant, but they were not maintaining or improving the material condition of the plant.
GPUN has since realigned the meintenance function in October,1982, placing mechanies, electricians, instrument technielans and their direct supervision under control of the M&C Division which will accomplish work requested by the plant. It was GPUN's intention that the total number of
- people performing maintenance under this new arrangement would not be increased. M&C wl!1 need to find the work methods and procedures to improve the utilization of mechanies in working off the backlog of -
maintenance work and keeping up with new job orders.
The illusion exists within some quarters of GPUN that the maintenance l,_ problem at Oyster Creek is a fundamental problem growing solely out of the union " problem" which has resulted -in the manual effort in the field never being properly controlled and that, because of the union, nothing has
- i ever happened to increase the effectiveness of hands-on work. If this is so, 4 L it leads to a conclusion that the work force and the union agreement must be restructured. BETA agrees there are serious problems with the labor-management agreement which require immediate attention and which, if 4
resolved, would amist in improving efficiency and productivity; however, i.
there are other considerations, not restrained or affected in anyway by the agreement with the. bargaining unit.
It was BETA's observation that the union agreement by itself did not have a major bearing on the productivity of the workers. With the possible j exception of a few people with malicious intent, who, if existing, can be easily found and discharged, workers will do a day's work. Their efficiency i
and utilization does not depend on them-rather on their supervision. The
' ' worker will do what he is told to do, what he is shown how to do, what he
' b trained to do, what he can do given the access, special tools, special
! clothing, plant conditions, tag outs, work permits, procedures, materials,
, inspection support, radeon support and supervision that are required. Deprive the worker of any of these, and his efficiency tnd productivity declines.
He will then do what he is told to do or what he is allowed to do. So, to blame inefficiency and lack of productivity on the worker is a poor excuse-l -even to blame it on his group supervisor is sidestepping the issue. The group supervisor's work ethic is much like that deserbed above for the i
38
' ~ ~ ' ~ ^
L-
.- : .;- - .~ - __
worker. Even he must be put in an environment and be provided with the procedural, material and management support conducive to doing work. Put him in an environment where he can not work, and he and his gang will accomplish nothing. Concentrate the effort on those who generate the work -
_ requirements and create the work environment, and manage the work within the existing contract, while negotiating to improve any features of the bargaining unit agreement which prove to be inhibiting.
l
- All of these items discussed so far are well-known to both the Plant !
Director and the Director, M&C. They are areas that need to be addressed ;
and solutions found if maintenance work at Oyster Creek is to improve. In ~
addition, BETA has noted a number of problems associated with the transition that also need correction. BETA understands that whenever such a drastic change takes place there will always be a period.of time that people are unsettled, confused and working at odda. This is to be expected. However, 4
l BETA senses a fundamentallack of understanding on the part of fairly senior people (managers) involved of just how this new arrangement is supposed to
. work, particularly in the details. A very detailed procedure has been written
.and issued which, at least at this stage, is not fully understood by those f charged to carry it out. As the system attempts to be used, roadblocks are encountered and there doesn't appear to be a mechanism to bring the
) ., right people together to resolve the holdup.
For example, there in.a large backlog of installation procedures held up awaiting PORC review (a subject discussed elsewhere in this report).
This is a step in the sequence of events, one of many, that needs to be ,
- resolved if it is taking an inordinate amount of time. Without arguing the whys, it is essential that the issue get resolved and this can only be done by people enpowered to make decisions. As the plant moves further into the outage and the large workload begins, many more of these types of problems are going to arise.
RECOMMENDATION '
- a. Senior people in M&C, including the Vice President, the Production Director and the Manager of Planning should increase their direct and daily participation in solving organizational and divisional 1' interface problems arising at Oyster Creek as a result of the transition. This recommendation is not to be interpreted as a means to force decision-making upward or to usurp the i responsibilities of those people at the site. Rather, it is recommended as a means to obtain quick resolution of problems 2 that may be beyond the reach of those at the site. At this stage of development there are probably very few people who havs a i
clear understanding of how this new organization is intended to j work. The few that do, need to be put in the breech. '
i' ! b. In concert with the above recommendation, other senior people at the site such as the Vice President, Oyster Creek, the Manager, RadCon Oyster Creek, the Manager, Oyster Creek QA, and the senice T/F site representative need to increase their personal involvement in resolving the time-consuming roadblocks arising as a result of the transition.
39
._ _ _. - . . - - - - - ~ - - -- --- -
c.
Care must be exercised not to assume automatically that the large number of newly prepared procedures relating to the conduct of meintenance at Oyster Creek are, or will be, understood by those required to follow them. Initial observations indicate that some of these procedures may be overly prescriptive.
7 .-
O/C MAINTENANCE Coffee Breaks i FINDING IV-D-2
'Ihe sanctity of coffee breaks at Oyster Creek is a sizeable
- contributor to poor productivity.
DISCUSSION a
r The agreement with the bargaining unit specifies one fifteen minute coffee break. It does not specify when the break is to occur. Rarely is the break completed in the specified period of time or at a time that would
' have the least effect on work. In addition, it is now common. practice to take a coffee break in the afternoon, with no reference in the bargaining unit agreement. Again, that break is seldom completed in fifteen minutes or taken at an appropriate time. Should these two breaks be taken by workers involved-in areas requiring protective clothing, at least two hours of nonproductive time results.
RECOMMENDATION I
- a. Undertake to negotiate the morning coffee break out of the t
bargnining unit agreement or at least allow management to decide .
I when the break is to occur.
I b.
Eliminate the afternoon coffee break or allow management to determine if, when, and under what conditions there will be an afternoon break.
L.
_ O/C MAINTENANCE Working Hours for Contracted Employees FINDING IV-D-3 Mechanics under contract through M&C do not stay on the job until the end of normal working hours. '
- DISCUSSION The current practice is to release M&C contractor employees from the job in time for them to be off Company property by the end of working hours.
The explanation of this unusual practice was that they come to work 40
on their time, but leave work on Company time. This is an added cost, and it also has a bad effect on the Company employees who are supposed to stay on the job.
_ RECOMMENDATION M&C contractor employees should be kept on the job until the end of working hours.
eeee :
i .
j O/C MAINTENANCE '
Preventive Maintenance FINDING IV-D-4 9
Only a fraction of the preventive maintenance routines planned for accomplishment are completed.
DISC USSION The relatively new preventive maintenance program at Oyster Creek has made progress-the program was started from zero. For instance, the
" rotating screens at the intake structure are now lubricated on a schedule, rather than only when rebuilt after failure.
With the transfer of the maintenance function to M&C, the preventive maintenance function wiH stabilize. Previously, when needed, preventive
" maintenance workmen were diverted to corrective maintenance work. This
,1 - is the principal deterrent in accomplishing planned preventive maintenance.
I At the time of our initial review in' April 1982, job planning was still l done manually by engineers on the Preventive Maintenance staff. When the
' program is automated in the Generation Maintenance System (GMSJ, this work can be done cheaper with job planners, and the engineers can be
, , released to engineering work. ,
l RECOMMENDATION
- s. Expedite loading the preventive maintenance system schedule in GMS.
I t
Maintain close contact with TMI-1 Preventive Maintenance in order i
t to benefit from TMI experience.
- c. Consider reducing the size of the Preventive Maintenance Manager's staff as the preventive maintenanca program stabilizes.
I i
41 '
,_ - - ... . :. ~ . -
eeee O/C MAINTENANCE -
Mobile Maintenance FINDING IV-D-5 -
Mobile Maintenance is a costly way to perform plant maintenance.
DISCUSSION 5 t
' One of the loosely, or informally, controHed expenses is the cost
- incurred through the use of the Mobile Maintenance force maintained by JCP&L at a remote station. Portal to portal pay-including overtime for
' that in excess of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, mileage, meals, mealtime, motels, per diem, etc.,
cause the effective hourly rate for Mobile Maintenance employees to far
' exceed that of a plant employee or an M&C contracted craftsman.
Apparently, requests for Mobile Maintenance people are made orally-no real
,_ scope of work definition is required. If Mobile Maintenance can provide the
' requested people, they will be provided ~at their exorbitant cost. If they can not be provided, the plant must go through the administrative burden of trying to reschedule the work before starting the job with mechanies ,
under contract to M&C. Using Mobile Maintenance people under these conditions is daruptive to-work planning and destroys any' attempt to' control i
costs to the budget. (Budgets are prepared at the plant payroll rate, not the inflated Mobile Maintenance rate). ,
The manner in which costs are accrued by Mobile Maintenance. and the
' informal controls over the use of this high cost service create a disregard for cost in those who use Mobile Maintenance. It might have been a good idea ten years ago, but today it doesn't work, except for specialty tradesmen, such as turbine overhaul specialists.
\
Any Mobile Maintenance people with unique Oyster Creek skills who perform most of their work at Oyster Creek coukt be taken up on the plant roRs to reduce these abuses.
RECOMMENDATON
- a. Consider negotiating agreements which result in better~ utilization
- l.t of Mobile Maintenance.
4
- b. Consider taking on to the M&C ron those Mobile Maintenance 4
employees who perform most of their work at Oyster Creek.
I h
l a
42
eeoe
, O/C CHEMISTRY FINDING IV-E Problems in performance of the chemistry control program at Oyster Creek were found to be'similar to the problems at TMI-1.
DISCUSSION S i
The same actione are underway at Oyster Creek as deserlbed in the previous section for TMI-1 chemistry; they are not repeated here. An experienced manager has recently been hired from outside GPU to be chemistry manager.
. RECOMMENDATION 2
BETA considers Oyster Creek is on the right track to upgrade its f chemistry program. It is particularly important that the Director, Oyster Creek have a key manager he can hold accountable for ehemistry operations; the chemistry manager should develop this responsibility. It will be more efficient and produce a better product if the chemistry analytical procedures for TM1-1 and Oyster Creek are standardized. The two chemistry managers
- should take action to force this standardization.
t .
eeee
, O/C PLANT ENGINEERING g Engineering Groups
- i l FINDING IV-F-1 I
There are too many separate, section level groups having engineers at Oyster Creek.
DISCUSSION Our review indicates that there are at least nineteen section level groups having engineers onsite at Oyster Creek operating under the direction of five Division Directors. Many of these are necessary and should be
, separate. However, it is our opinion that there are too many. 1here are such groups in each of the-following: .
- 1. Under Director, Oyster Creek
- a. Manager, Programs and Controls
! b. Plant Operations Director
- c. Manager, Plant Operations
- d. Manager, Radwaste
- e. Plant Engineering
- f. Manager, Plant Materiel l
l 1
43
- - - , - - . - . - - . - - . - - - - - - - - - - - - - - ~ ~ - ~ - - - - ' ~ " ~ ~ ' ^ ' ~ ' ~ ~ ~ ~ ~ ' " ~ ~ ~ ~ ~ ~ ' ~ ~
.,eaM wi 4.# -e=re V'" ? e $N e *W"'MO' - "" * ' ^
- 2. Under Director, Technical Functions
, a. Licensing . '
- b. Plant Analysis
- c. Plant Process Computer f d. Engineering Projects
- e. Start-up and Test
- 3. Under Nuclear Assurance -
it
- a. Quality Control i
- b. Quality Assurance -
- c. Welding
- d. Safety Review i
- 4. Under Director, Radiological and Environraental Controls s a. Radiological Engineering
- b. Environmental Control
- 5. Under Director, Maintenance and Construction
- a. MzC Technical Support Because of this, there is often confusion as to just which group. or group:: will handle a given problem, which in turn, adds to the time it takes ~
to resolve a problem. It also creates a situation where one group thinks
' another group is handung a problem while, in fact, nobody is. It also results in there being 80 engineers located at the site.
RECOMMENDATION l- The number of separate engineering groups at Oyster Creek should be reviewed with the goal of reducing the number. This should also result in reducing the need for having 80 engineers at the site. Where there exists a need to have multiple engineering groups, there should be one person at' the site designated as the lead Division representative who would assume the administrative and other responsibilities other than technical l
O/C PLANT ENGINEERING !
Nuclear & Core Management l
FINDING IV-F-2
' The projected manpower level is high for the Oyster Creek Nuclear and Core Management group.
DISCUSSION The onsite Nuclear and Core Management group at Oyster Creek has i
been authorized to expand its manpower to six engineers in 1983.~ At the l present time there are three engineers filling those positions. Oyster Creek I
44
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- ----yw----r.-- -
,,r-- --g g-- ,. ~y - e
(
l
. l l
has had difficulty in finding people willing to stay in those jobs, primarily because they feel the job is too narrow. The worklo'ad for this group, assuming they do not duplicate offsite functions, could be reduced so that it would not require a staffing level of six. It is understood that partial justification for this level is to support shift operations for such events as power level changes, startup, data taking, etc.
RECOMMENDATION
- a. : '
Operating procedures should be prepared that will reduce the 3
- dependence on the Core Management group during planned plant i evolutions and during periods of taking data. It is understood that forthcoming plant changes (cycle 10 outage) will simplify the procedure requirements.
- b. Action should be taken to assure that the Oyster Creek Core Management group does not duplicate efforts of the Nuclear Analysis and Fuels section in the Technical Functions Division.
- c. Reevaluate the staffing level of the Core Management grouj.
L e
6 bd
\l I
45
. : =.= .: =: -
=._ z =: T
. .L.-
' O/C RADIOLOGICAL CONTROL
, FINDING IV-G t
There are too many instances where radiological controls are not as good as they should be. The work force has.not accepted enough of the responsibility for high quality radiological work performance. Excesive .
generation of radioactive waste is part of these problems. i a
f DISCUSSION '
i The findings and recommendations on radiological control for Oyster
' Creek are summarized here in words similar ~to those for TMI-1. The discusion section under TMI-1 radiological control is not repeated here but it provides useful background information for. Oyster Creek.
There is a more urgent need to improve the radiological control program
[ at Oyster Creek than at TMI-1 for the following reascas:
- a. The consequences of not having a good radiological control program at a boiling water reactor are worse than at a pressurized water reactor because.there is more radioactivity spread throughout more .
systems and throughout more routinely occupied areas.
- b. Major radioactive work in the long outage now just beginning at j Oyster Creek.
I' j e. Correction of the poor attitude toward radiological controls has -
j not progressed as far at Oyster Creek as at TMI-1. Neither the work force nor radiological control personnel perceive that the radiological control organization should be helping to get the work jl done. Productivity is worse at Oyster Creek than at TMI-1 and radiological controls are blamed as a major cause of this low i productivity of the work force.
!' d. The radiological control organization at Oyster Creek has been slower in developing radiological engineering competence than at TM1-1. Many of the radiological control technicians at Oyster Creek have been contractors, while TMI-1 has seldom used contractors for these jobs. These situations mean that it has been j
i hard for the radiological control organization to exercise the
~ leadership needed in getting the radiological work performed with good radiological control
- RECOMMENDATIONS i
- s. Increase the efforts of managers and supervisors to get excellent radiologicalperformance as an inherent part of every job performed by their workers.
j b.
~ Improve the working relationships between the rr.anagers t.nd supervisors of the radiological control groups and the managers
~
- 46
.- . = - - : =.-__ - ---.
_.u .. _ _ . .= -- -- -
and supervisors of the work force. This requires ' station management as well as radiological control management attention-since a one-sided effort to cooperate will not work.
- c. Use a radiological awarenes committee similar to that at TMI-1
! to help in accomplishing these first two recommendations.
7
- d. Upgrade the performance of radiological control technicians by improving their ability to identify and report radiological -
, deficiencies. 't
~3 l , e. Speed up the correction of radiological deficiencies and increase
' j the attention to solving the problems which lead to a repetition of deficiencies. Both radiological control personnel and others in
, the station are required for these efforts.
i' f. Decrease the number of radiological control technicians as the work force picks up its own responsibility for good radiological work performance.
[(
l g. Commence promptly the training of radiological control technicians l
and their first line supervisors to handle unusual situations not covered by written procedures, 1
- h. New written procedures, new management systems, and new gimmicks should not be considered necessary to carry out these -
l recommendations. Each one of these recommendations is a logical extension of what has been started and would likely be defeated if buried in new paperwork.
l, eoee O/C NUCLEAR SAFETY REVIEW Plant Operations Review Committee (PORC)
! FINDING IV-H I
Senior management people at Oyster Creek are spending too much time on PORC matters.
~
DISCUSSION k
BETA was informed by several members of the PORC that they spend twenty hours or more a week in PORC meetings at Oyster Creek. The members of the PORC are key management people at the site who are
' responsible for areas requiring their, daily attention. By spending so much of their time in PORC meetings, the plant is deprived of their services, it was also reported that some of the items reviewed by the PORC are of minor significance which should not require that level of review. It was also indicated that the PORC is spending much time rewriting poorly prepared documents. These two actions result in placing a heavy demand on the members.
l
~
47 :
~ ~ ~ ~
f RECOMMENDATION -
A review should be made of the Technical Specifications to determine if the present wording is such that it requires PORC to review documents beyond the recognized scope considered appropriate, or if minor items are being PORC reviewM because of local interpretation. Action should be taken to expedite tha changes made at TMI-I for conducting independent
, onsite safety revie% in addition, poorly prepared documents which are submitted to the l' ORC for review should not be rewritten by the PORC, -
l but returned to the author for correction. Once the people understand that the PORC will not do theic work for them, the documents will be better -T prepared. The Director, Oyster Creek, should expedite these actions in order -
to free up his key management people from excessive time spent in PORC so they can perform their normally assigned jobs and to eliminate the excessive delays when documents are held up pending PORC review.
eeee O/C ADMINISTRATION FINDING IV-I I'
The number of people assigned to administrative work at Oyster Creek appears excessive.
DISC USSION ,
There are 48 GPUN people at the Oyster Creek site that fall in the category of Administrative Support / Services.
follows: These are broken down as Building Services / Facility Maint 4 i ,[ Emergency Planning 1 Quality Control 1 Licensing 1 Train & Education 3 i M&C P ing & Scheduling 3 M&C Field Const 1 M&C Tech. Support 2 M&C Admin. Support 3 1
Contract Admin. 2 Procurement / Purchasing 2 Computer Operations 2 Document Control 11 Industrial Safety 2 Personnel 5 Word Processing 4 Plant Admin. 1 TOTAL 48 i
i 48
,, - ,- _e_- ,,.7 - - . . . + - - * . - _ , , . , - , , . , , - , - . _ , - - - . . - . , - - - - , , . . . - . , , - + - - , . . , e_+-m ---r-,.m-_- -. we--
_ _ . _ . _ . ~
In addition, there are 56 GPUN employees at the Oyster Creek site -
identified as Clerical / Secretarial Services. These are assigned to the following groups: -
Management /Mgmnt Support 10 Senior Control Room Operator. 1 Radwaste 2 Start up & Test 1
,f' Plant Maintenance 1 -
i\ BuiWing Services 3 i
Planning & Scheduling Engineering .5 **
Emergency Planning I QA 3 QC 1 ,
Nuclear Safety Review 1 l Licensing 1 Training & Education 3 i ,
Environmental Control 1
, HP .5
- Radeon
' 2.5 M&C Planning & Scheduling 1 M&C Tech Support 1 M&C Admin Support 4 Contracts 1 Procurement 1 Storeroom / Warehouse 1
- Plant Project Engineering 1 Budget & Cost Analysis 8.5 Industrial Safety 1 Personnel 2 Security 1
'- Plant Admin. 1 TOTAL F These two categories of employees account for 104 employees. It appears to BETA that this number is larger than necessary to carry out the onsite tasks. There is no single area where large numbers of people are assigned, and in each individual case, a logical argument could be made for
' there being a person or so assigned. It is the total number that leads to the belief that excesses exist. Elsewhere in this report, there is discussion
(. .
on the building up of individual staffs, it is suspected that a number of the positions listed above fall in that category, it is difficult for BETA to I
recommend just which of these positions could or should be eliminated.
Collectively, six Divisions are responsble for these 104 people. It would l appear that a number of the functions or tasks they perform could be combined and shared; hownver, this would require some give and take on
- the part of six Division D3ectors.
RECOMMENDATION The six Division Directors involved with providing the 104 administrative / clerical positions at Oyster Creek should be advised that the total number of these two :ypes of positions onsite at Oyster Creek will be reduced. The Office of the President should set an arbitrary number.
. 49
.I NOTE: '
This item has equal applicability at the TMI-1 site where there -
are 106. employees in the categories of administrative support and clerical services.
O/C MATERIALS MANAGEMENT Purchasing FINDING IV-J-l i The purchrsing operation at clerical support. Oyster Creek k receiving inadequate DISCUSSION in connection with the previous comment concerning excesive clerical
- personnel at Oyster Creek, there are situations where required clerical work is not being adequately performed. This situation is an example of where under-utilized clerical people are not being assigned useful but posibly onerous functions at the site.
At the time BETA conducted the review of Purchasing at Oyster received at the rate of 75 per week. Creek, in April 1982, purchase requisitions were being backlog of 111 requisitions awaiting typing.At In the that samesection previous time, of there this was a -
report, BETA comments on the excesive number of clerical and -
administrative support positions at Oyster Creek, yet in Purchasing, the support is scant. BETA was subsequently informed of procedures and methods
- to reduce the backlog and preclude recurrence by processing some Oyster Creek requisitions in Parsippany.
associated with the upcoming outage, the efficiency of purchasing wou improved if the necesary clerical support were onsite provided from I
excessive clerical people already present.
RECOMMENDATION j, support Consider processing reamigning lightly loaded clerleal people to Purchasing to of requisitions, eee.
O/C MATERIAIJi MANAGEMENT Warehousing FINDING IV-J-2 support Theofstores the plant. and warehouse function at Oyster Creek can improve its DISCUSSION Past performance of the warehouse at Oyster Creek was inadequate.
Even frequentlyfor items encountered. said to be in inventory, difficulty in locating and issuing was A recent inventory has revealed large quantitles of direct turn over (DTO) material on hand, as well as errors in the stock records, complicating the warehousing job.
50 :
~. .
- y. --
=-
g (,
e' The inventory is now on-line, low limits are specified for automatic $
reorder. Shelf-life items are identified, and a workable program for preparing ordering data for stock and spares is in process in Plant Engineering.
l The usefulnes of the improvements in warehousing will be enhanced when the CRT terminais giving accom to inventory records are installed in the plant.
The next step which should be undertaken in the warehouse is warehouse !
assistance in staging material for jobs scheduled to start soon. In this '
. concept, warehousemen would asamble the material for a' job and have it ready for issue on a job basis rather than on a Ene-item-of-material basis.
RECOMMENDATION n.
Expedite installation of CRT's in the plant to tive direct access to inventory recorda.
[ b. Carefully plan the disposal of direct turn over material on hand that is not required for plant support.
^
- c. Consider underta, king staging of material on a job basis. '
oeee '
1 O/C MATERIALS MANAGEMENT
- Accounts Payable FINDING IV-J-3
~
4 j
l' Delays in procesing invoices for payment are creating significant problems for Purchasing.
DISC USSION
- t j
At the time of the BETA review in April 1982, the Purchasing Manager was encountering situations in which suppliers were demanding Cash on j ,
,; Delivery or payment by certified check prior to shipment. One supplier had i' established with submitting a pattern of filing a claim in SmaR Claims Court simultaneously his invoices.
efficiency of the purchasing operation. All of this is a distraction and decreases the a(
BETA was informed of steps taken and of plans in proces intended to solve this preblem and of progres made to date.
RECOMMEN DATION The backlog in Accounts Payable should be promptly eliminated.
1 i
e t
51 2
- - . . ~ - - - . , . . . . . . - . _ _
l .
.g E I I
- i f* i \
!f Ii A
l l, CHAPTER V
,{ NUCLEAR ASSURANCE FINDINGS AND RECOMMENDATIONS 1
5
( .
~ . i
'G.
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l Ii I
i L.
l i
CH A PTER V.~
NUCLEAR ASSURANCE FINDINGS . . !
AND RECOMMENDATIONS GENERAL The creation of the Nuclear Assurance Division is probably unique within the nuclear community. It brings together in one division three separate groups whose independence from the day-to-day operation is an important ingredient. It encompasses Quality Assurance (QA), Training and .
- Education (T&E), and Nuclear Safety Assurance (NSA). At the time of its 2 establishment QA was for all intents and purposes, a fully functioning group i operating out of the Met Ed (TMI) organization. About-two years after the accident, Oyster Creek QA was folded into this group. While there has been a sizeable effort to make the GPUN QA more effective and cohesive, it was essentially a going organization at the time the Nuclear Assurance ,
Division was formed. From the time of its first involvement with GPU in '
t early 1980, BETA has been impremed with the management of the QA program, its depth of experienced people, its philosophy of coverage, and ;
the support it received from the corporate level-l Under the current task, BETA did not find, nor did it expect to find glaring deficioneles or flagrant esses of over-coverage. The question which t was addressed was whether or not the present QA management was doing s its share to create the most effleient-operation while at the same time not compromising its high prinelples. In the early stages of its review BETA '
did conclude that not as much effort was being devoted to this aspect as
- should have been. Over the ensuing months it became apparent that this '
situation changed for the better. QA management has instituted a. number of changes which will result in obtaining the proper amount of QA/QC ,
coverage but with less people. This effort should continue.
The Training and Education Department was and is a different story.
A major issue arising out of the accident at TMI-2 was training, particularly operator training. As a result, a major effort to create a comprehensive training program at TM1 was initiated. But unlike QA, it had to start from l
a rather meager base. An organization which at one time consisted of les ~
e than six people had to be expanded in a short time. Nonexistent training programs and courses had to be created, and new people had to be asimilated. :
At the same time this was going on, the same leading people were needed to prepare testimony and give it for the legal proceedings. If this were not enough, the problem coming out of the operator examination cheating incident arose. Circumstances dictated that key members of training i i
I management devote considerable effort in attempting to resolve this problem.
A further complication was the need to institute a vigorous training program at Oyster Creek. !
- What BETA found in the Training and Education Department was what was expected in view of the circumstances. When compared with the state l existing in 1979, significant progrem had been made and was continuing.
However, there were many situations where it was apparent that a given program had been conceived and work started, but, due to lack of management '
i attention and the lack of qualified and experienced people, the goals and objectives of the program were falling short. It would appear that too many ;
j things were being attempted, in too short a time, with untrained people, <
i.
52 1
'l and where fuH management attention had been diverted to other things.
This is one area within GPUN where the program sorely needs the opportunity -
to settle down.
, The third element of Nuclear Assurance is Nuclear Safety Assurance.
Even.tho@ this department was incorporated into NA at the time of its formation, it was not staffed at the headquarters level for the first year.
y Subsequently NSA provided the corporate framework for establishing the newly imposed requirement that there be an independent onsite safety review group (IOSRG). The functioning of NSA has just recently started and the j
3 3 effort to staff it continues. BETA found it too early to ames the '
effectivenes of the TMI-1 IOSRG, and such a group has not yet been formed at Oyster Creek.
" As a note of explanation, when BETA began its review in January 1982, the System Laboratory located in Reading, Pa., was organizationally under t
the Director, Nuclear Assurance. Midway through the review the laboratory was shifted to come under the Director, Technical Functions. BETA's findings relative to the System Laboratory are covered under Technical Functions.
I ,ee,
~
N/A READING GROUP
- FINDING V-A The group presently asigned to Nuclear Assurance located at Reading should be eliminated and the functions reamigned to Parsippany.
DISC USSION e
There is a group of three people located at Reading who report to the
' Director, Nuclear Assurance and handle budgeting and administrative
- funetions for the division. There is no reason related to GPUN work performance for this group to be located in Reading and the fact that they g
are there rather than at Parsippany la an inefficiency] ,
RECOMMENDAMON Consider eliminating this group at Reading and reasigning the functions to Parsippany.
k 53
4 4g, . W uye.g e M -r *"-'w ## -* - - "
N/A CORPORATE TRAINING i' Development Courses
?
FINDING V-B-1 -
1 There are many training and development courses offered which are useful but not esential -
l i
DISCUSSION z'
I I
It is BETA's opinion that GPUN. training resources should be focused more on resolving known and immediate problems directly related to the nuclear power plants. To do otherwise only dilutes the effort from those important areas.
A review of the GPUN Training and Education Course Catalogue (dated
_ March 25,1982) shows thirteen Management Development Courses offered; some on a voluntary basis. They are:
- 1. Management Development Program
- 2. Communications: Proces in Perspective
- 3. Decision Analysis Course t
, 4. Effective Writing '
- 5. Effective Writing, Phases 2 & 3 -
- 6. Dynamics of Face-to-Face Communication
, 7. Leader Effectivenem Training
- 8. Listening: Sharpening Your Analytical Skills
- 9. Scientific Analysis of Ideas: Communications Course
- 10. Basic Supervisory Development Program
- 11. Fundamentals of Supervision
!! i
- 12. Supervisory Training for Managers
- 13. Perception: Key to Effective Management Communication 4
j While a case could be made that every one of these courses is worthwhile and would improve the effectiveness of GPUN, it is BETA's opinion that many of them, as presently structured, are not esentiaL There should be lt a course, or possibly two given to employees who are, for the first time, being put mto a supervisory position. Such courses are necesary and are l discused elsewhere in this report dealing with supervision. As far as the other courses are concerned, each Division Director and his managers should I bear the responsibility for training their own people on matters such as how to perform their job more effectively. The Training Department couki be tasked to prepare course material for these subjects which would be available to Division Directors to use in informal, non-classroom type of instruction.
' It is BETA's opinion that having Training perform this function creates a number of bad side effects:
- a.
It tends to relieve supervisors of their responsibility.
, b. The courses are viewed as a nice place to go for a rest.
- c. Because of the nature of some of the courses, it is possible that the people teaching the course know less than the students.
l
- 54
- d. It creates a problem for some of the senior managers who, for -
whatever reason, will not let their people attend these courses, '
and then are viewed by their own people as being against company -
Policy.
RECOMMENDADON Review the courses offered in Management Development with the aim of eliminating those which do not materfally contribute to the safe and -
efficient operation of the GPUN plants. i
? ,
I N/A HEADQUARTERS TRAINING EFFORT Effectiveness I
{ FINDING V-B-2 The headquarters trainig group is not concentrating enough on f coordinating plant training efforts.
DISCUSSION in the GPUN functional.. organization there is a headquarters group ,
responsible for training. This group is headed by the Director of Training -
and Education who reports to the Vice President-Nuclear Assurance.
- Reporting to the Director of Training and Education there are three managers:
a manager for plant training located at TM1, a manager for plant training
' located at Oyster Creek, and a manager for corporate training located at headquarters.
The functions and responsibilities of the two site managers are clear, i and while there remains more work to have these site organizations operate
'f-effectively, at least the direction they are headed is correct. BETA questions
! the direction being taken by the headquarters group, including that of Corporate Training. BETA does not question Corporate Training's responsibility for training GPUN personnel located at Parsippany. This is an appropriate task. What is questioned is an apparent lack of headquarter's coordination of site training. BETA expected to find a headquarters group that kept track of what was going on at the sites to make sure efforts were not being duplicated or that the two sites were not going off in different directions. Very little of this was found. One contributing cause for this
- i was GPUN's inability to fill the Director of Training and Education position for most of 1982. As a result, the responsibilities of this position have been divided between the Vice President-Nuclear Assuranace and the Manager of Corporate Training. A further distraction was the assignment of the Vice President-Nuclear Assurance to the TMI-1 Steam Generator Task Force in February 1982, which reduced the amount of time he was able to devote to training.
I Assuming these complications did not exist it is still BETA's opinion that the headquarter's role bi training, as described above, is not being pursued to the extent that 'it should. Whether this function belongs in Corporate Training or with a separate staff assigned to the Director of 55
~ ~ ~
~ ' '~ ~
- .. __ - - . - .L -- - : : ---
Training and Education is not the issue. The issue, as far as BETA is -
concerned, is that there are people in the headquarters organization that could be doing this function but they are not. '
- RECOMMENDATION The goals and objectives of the headquarters training and education group should be reviewed to ensure that higher priority is given to carrying -
out the function of coordinating end overseeing the efforts of the two site
- training groups. !'
' N/A TMI-I TRAINING Scheduling FINDING V-B-3 There are ineffielencies in the TMI training effort due to a lack of meaningful scheduling. _ The Training Department has difficulty in obtaining data to schedule its training.
i n DISCUSSION -
( :
i 1
Based on interviews conducted and a detailed review of the records, -
BETA concludes that (nefficiencies in the TMI training program are brought
' about due to the_ lack or a reansti~c schedule. It stiould be possible, at this I
stage of events at TMI-1 and in the Trainin~g Department, to develop a one year training schedule whleh can be generally adhered to, especially with
! respect to start dates for classes. Consultation between TMI-1 and the Training Department should result in knowing that, during the next year, there will be so many classes taught to licensed and nonlicensed operators, l
' requalification, etc. With this information, Training should be able to develop l' a long range schedule that makes the most efficient use of the instructor ~
staff.
s This is particularly evident in the case of Security Training, wherein i
a number of classes were held with just one student. The argument was advanced that the Security people never knew ahead of time when a new security person would be hired. Thus, Training was always put in the position i
i of having to train someone on short notice ar.d of doing it inefficiently. A simple change could be made wherein Training wouk! schedule four (or some l number) of Security classes per year, starting on fixed dates. It would then be encumbent on Security and liuman Resources to have new hires available on those dates.
I RECOMMEN DATION All divisions involved with having people trained at TMI and the TMI
) Training Department should arrive at a realistic training schedule that covers j
one year ahead. This will require these divisions to feel some degree of
- ~
responsibility for whatever inefficiencies they create by not providing useful data or by being insensitive to the needs of Training.
56
NN- - - --- - - - -- --
'l r
r i
- L F
+
e oeee N/A TMI-1 TRAINING =
_ ,, Attitude
) g t -
FINDING V-B-4 There is an herly "understandhattitude which prevails in the TMI -I Training DepartmenTespeciaWespect to operator training. j-DISCUSSION Ia Interviews conducted by BETA in March and April 1982, indicate that E ~ there existed an attitude, not only within the TMI Training Department, but .
also at the plant, of almost atronizing o the students. There seemed always to becaxcuseTwhy studen did poorl i ' hy operators made mistakes, or if i -
there were cheating, why I curred. It appeared that the Training -
' Department had become very " understanding" of all the problems the students
~
may have and, as a result, lacked the degree of61ighnesitf'secountablitD and [nsistenEE w W formance\needed in the nuclear prolession. In a follow- { ,
up re% w conaucteo in dovember 1982, BETA found this situation improved but not entirely corrected. While there is merit in making the task of
- learning as easy as possible for the student, our_exp.erience indicates that i
- ' the student must be ch enged; he must feel.65ine'presslu e'to exert himself; .>
~-
he must have some apprehensioniever not doing well. While these concepts r
may differ from the so-caated " modern" form of education, we contend that egrff E ~ -
they work. - - - -
The students are being paid a good salary to learn, and they need to "
be told what h e::pected of them and then to be held accountable. For example, having students evaluate their instructors may be an essential part -
[ of modern education, but it tends to put the student in a position to justify -
g his own lack of initiative and sense of responsibility. Instructor evaluations -
should be conducted by the training staff or other elements of the _
organization, such as Operations or Technical Functions.
i All elements within GPUN concerned with training have been put under i a lot of pressure over the past three years as a result of the TMI-2 accident and then the exam cheating incident. There have been groups, committees, r etc., auditing, reviewing and analyzing the TMI training program. While most of this could not have been avoided, care must be taken that it has not caused attitudes to develop within the Training Department that can
- ^ result in a less than optimum product. In its review, BETA did not attempt
- to make a first-hand determination of the quality of the training effort.
" For example, we did not attempt to find out if licensed operators were l
being taught the correct material in quality or quantity. However, in our attempt to make some judgment on the efficiency of the operation, we did have an opportunity to talk to the training staff, the students and the product users.
i i Based on this, it is our opinion, that too much emphasis is being placed on proving to the world that the training program is good and not y
enough on doing what should be done to produce a competent operater. The Training Department needs to settle down, get back to what they know their
- job is, and concentrate on that, rather than constantly looking over their shoulder wondering what it is they are doing wrong.
- 57
. - . . . . _ . = _ _ _ _ _ _ . _ _ . _ . . _ a- . . . _
RECOMMENDATION _ .:
a.
To the extent possible, GPUN management should resist bringing _
P
~
.in more outside groups to review the training program. . There are ample means within GPUN to do this, b.
Now that the outside pressure has abated somewhat the Director, Training and Education, shouM direct - the. efforts of the TM1 -
7 Training Department to concentrate more on producing the best produet they know' how, and less on trying to prove it. -
j
'Ii c.
Greater effort should be spent on making the students more responsible for their pwn performance.
eoee N/A TMI TRAINING Instructor Supervision FINDING V-B-5 Department.There exists a lack of sigervision of instructors in the TM1 Training '3 g- DISCUSSION I ,I During instances werethe time of the BETA review of TMI Training, a number of supervision. noted indicating that the training staff lacked needed In some cases, it was because supervisors, who were present, did not react assigned tasks. to situations where instructors were not performing their Based on these observations, such lack of reaction appears typical of the normal mode of operation within the training buiMing. flad-this not been the case, the job inattention noted would not have been as obvious and distracting.
not any supervision present.In other cases, it was noted that there just was It would seem that this finding should be unnecessary considering the seniority and experience level of the training staff. flowever, BETA was alerted to the possibility of this condition by a number of comments made by GPUN people outside the Training Department.
The main thrust of thase !
- comments applied to the lack of supervision over the instructors in the -
classroom. '
BETA was not able or in a position to observe instructor performance in the classroom, n,or would it have provided the necessary atmosphere to make a meaningful judgment. flowever, based on the observations made, there should be concern over classroom performance.
Il Instructor performance, good or bad, has a lasting effect on students.
If instructors demonstrate a lack of interest in their jobs in any way, this is transmitted to the students. As far as BETA is concerned, this is another indication fw the need for a more tightly run Training Department.
58
?- __ _
_ -. - . - - -- -- - ^ ' ~
RECOMMENDATION
- a. There are 15 supervisors in the 53-man Training Department at -
TMI. This is a much higher ratio of supervision to workers than normal. The Manager, TMI Training, should review the basic
- F principles of supervisor responsibility with his supervisors.
1
- .. b. It is BETA's opinion that the Manager, TMI Training, creates the impression that he is inaccessible to his staff by the location of -
his offlee in the Training Building. While he should have a private i office, it might be better if that office were located out in an area where he could see his staff, and they could see him,
- c. When the Manager, TMI Training and the Operator Training Manager
" are both absent from the Training Building, someone should be designated in charge and assume the responsibility to monitor what is going on in the Trafning Building.
N/A O/C TRAINING -
Effectiveness I
[, FINDING V-B-6 <
Findings reported on TMI-1 Training have applicability at Oyster Creek. -
DISCUSSION
~~
In the BETA review of GPUN Training, a conscious decision was made
~
to concentrate the effort on TMI-1. While a cursory review was made of Oyster Creek training, it was felt that since the TMi-1 training program had received a greater share of attention for a longer period of time, it would, therefore, provide a more realistic basis for review. Ilowever, it is BETA's opinion that each of the findings and recommendations contained in i this repwt relating to TM1-1 Training also have applicabillty at Oyster Creek.
s in this connection, it is noted that there appears to be very little communication or interplay between TMI-1 and Oyster Creek training. There seems to be an attitude that "if we didn't do it, it isn't any good". We saw numerous cases where each site was developing its own procedure,
~ document, plan, etc. For example, there has been an identified problem in chemistry training at both sites for a long period of time. Yet, at the time of the BETA review, there was almost no interaction between the two sites i on this subject.
It is also BETA's opinion, based on its cursory review of Oyster Creek
. training that, as in the case of TMI-1, more attention is being paid to the l " trappings" of training rather than to a concerted effort on obtaining an effective end product. .,
1 RECOMMENDATION .i I
- a. l Headquarters Training and Oyster Crcek Training should review the findings and recommendations contained in this report listed .]
j 1
59
.. .. ~
l
[
. NN_. N . .N -- - - - ~ ~ ~ ~ ~ ~ ~ ~ ~ ^ ~ ~
- under Creek. TMI-1 Training and consider them for applicability to Oyster .
, b.
Headquarters Training should estabHsh a mechanism which forces TM1 and Oyster Creek Training Departments to communicate, cooperate and interact with each other as a matter of routine.
, eeoe '
i' N/A QUALITY ASSURANCE Engineering FINDING V-C-1 i
There are more QuaHty Assurance engineers than necessary to carry Plan. requirements contained in the GPUN Operational Quality Assurance out the 4 ,
/
DISCUSSION The Operational QuaHty Assurance Plan states that the Manager, Quality Assurance Design and Procurement shall, among other duties, i
[,
"1.6.1.2 c.
Review and accept design control procedures prepared by [
other organizations when these procedures control or exercise an effect upon important-to-safety systems, components or activities."
and "1.6.1.2g.
Review engineering specifications and procurement documents to assure quality requirements are incorporated."
among Similarly, other dutes, at the plants, the Manager, Quality A'ssurance Mod / Ops shad, i
"$.6.1.3 d' Review engineering specifications and procurement documents to assure quality requirements are incorporated."
BETA concurs with these assigned duties as reasonable and appropriate.
It is BETA's perception, however, that the QA engineering groups go procedures. further, reviewing not only specifications, but also drawings and significantly engineering specificationsFor instance,onM&C installation procedures, as weH as the which they are based, are receiving QA ;
4 engineering review prior to release. Likewise Plant Engineering or Technical i Functions and concurrence resolutfort of release.
prior to QDR's and MNCR's receive QA engineering review BETA considers that many of the QA engineering reviews and approvals currently occurring beyond that specified in the OQA Plan are redundant and delay the accomplishment of work.
specifications and the material procurement documents, the burden shifts to the engineering OQA Plan. and work performance groups who are also bound by the The functions of QA Engineering at this point should be to provide assurance to those managers not in the QA organization that the 60
__ ,,,,...,--r s - - " * ^ " " ' " " . - - - -
- _ - - . . ~ ,- =.:- + -:: = . - _ = . .
4 I1
.x <
, OQA Plan is being complied with. This could be done by sampling procedures .!
and drawings already approved by Tech Functions and Plant Engineering and M&C procedures implementing engineering specifications. ,
The current QA reviews do serve useful purposes, however. It is during these reviews that the plans for future monitoring are developed and in
' which the QC. hold-points are determined 'and specifled. The review of
' procurement documents aHows for developing receipt inspection planning and procedures. g Lkewise the review of engineering resolutions of MNCR's and g QDR's aBows the proper planning of the necesary reinspections. - Also, QA reviews are frequently sought by the PORC as an assist to the PORC's review and approval.
All of ' these considerations lead to extensive QA reviews. None can be said to be unnecesary or meaningless, but all become one more hurdle in the issue of approved procedures and working documents.
The thrust of this iterc. is to encourage the development of plans g
s wherein QA reviews, other than those required by the OQ A Plan are performed simultaneously with ongoing work, rather than sequentially in the preparation of work procedures.
RECOMMENDATION
.\
As Tech Functions, Plant Engineering, and M&C mature, consider .
i reducing the number of engineers assigned to QA Engineering. _
eeee N/A QUALITY ASSURANCE
,. Operations FINDING V-C-2 M ,
- /
There are too many people asigned to Ops QA for the expected decline /
in the future workload.
DISCUSSION
- 7 _
Operations Quality Assurance (Ops QA) provides direct amistance to the operations, maintenance, and engineering supervisors performing important-to-safety work, usually by objectively monitoring work in proces and providing observations to the supervisor of the work. This function is of value to the Company, particularly in light of the training and detailed knowledge of the QA Plan on the part of the Ops QA monitors. The issue is the extent to which this service is provided. As the Company becomes more stable and mature, the value of extensive monitoring is decreased, a
RECOMMENDATION Consider reducing the number of Ops QA monitors as the work force stabilizes and matures. To phase down the size of this group, consider not filling vacancies, when occurring.
61
. . . . =
7= - - . .. - -
x . : = : - .-. ..- .: a .
II p
N/A QUALITY ASSURANCE Manufacturing Assurance FINDING V-C-3 The Manufacturing Assurance section' is larger than is required for known future work. -
f DISCUSSION In the future, the need to purchase large quantities of important-to-safety material willbe reduced as the modification work at TMI-1 and Oyster Creek approaches completion. This shouki reduce the level of effort required t in the Manufacturing Assurance sect.fon and should permit reducing its size.
RECOMMENDATION -
Consider reducing the size of the Manufacturing Assurance section as the manufacturing effort associated with the recent large modification efforts decrease. -
t eeee N/A QUAllTY ASSURANCE ^
_ Operational Quality Assurance Plan FINDING V-C-4 There is a rbk associated with the new Operational QA Plan.
DISCUSSION No specific fault la found with the new Operational QA Plan-even the NRC accepted the Plan without comment.
- Certainly, the Plan, as a plan, is not bad, and fits best Quality Assurance. the often stated intent of the President of having the
~
During the interview phase of this assessment, however, an undefined, not clearly stated concern and worry on the part of many of in thePlan.
the new Company was expressed regarding the complexity and workability Since the Plan is complex and forcefully worded, it will be important during the implementation phase to exercise the finest judgment
- to avoid paper wars, work stoppages, and organizational conflicts. A well-engineered, objective, supportive implementation of this Plan will enhance the Company's performance.
l RECOMMENDADON i
j phase.The QA Director must stay closely involved His best judgment will be required.
during the implementation i
62
. ~ . - - . . . - . - . - - _ _ _ . . _ - __., _ __;_. _
e ee e ;
~
N/A QUALITY ASS RANCE
, TMI-1 Q A FINDING V-C-5 The TMI-1 Quality Assurance Department creates the illusion in the minds of others that the Department is not supporting the plants. j DISC USSION We frequently encountered senior people in GPUN who felt that the QA Department was not responsive to the absolute need for QA support.
The opinion was expressed that the QA Department was not urgently concerned with resolving problems and clearing deficiencies. Some felt that .
QA was unnecessarily interfering with the accomplishment of work.
h Although it was disconcerting to encounter these feelings and opinions I in important people, BETA can not, in fact, based on close dealings with TMI-1 QA personnel, confirm the opinions of others expressed above. It is
~
important, however, that such feelings do exist, and they must be overcome.
1 BETA believes progress is currently being made in disabusing people of such
( concepts of the QA Department. As long as such feelings do exist, however, 1 i Q A will remain in an adversary role, rather than the support role intended. .
RECOMMENDATION
- a. The Director, Quality Assurance should recognize that these feelings exist. He should make an effort on his own, talking to various senior people in other divisions, to find out the basis for these feelings. It would then be encumbent on him to find out what is causing thh problem, to take the necessary corrective action in his own department, and to work with the senior people in other divisions to determine if there h something they can do to ease the problem.
- b. The Vice Presidents should ensure that their people support the Corporation's Operational Quality Assurance Plan. In this instance,
" support" does not mean simple compliance with the letter of the P law, rather " support" means believing in the Plan.
63
" ""- o-w .s,,,,,,
=emm,,
e o
e 4 I
( 3 i
i
[
! CHAPTER VI r.
TECHNICAL FUNCTIONS FINDINGS AND RECOMMENDATIONS i
a m
9
}
\
e e
~ , _ __ __ _ _ _ _ ___
1m .
3 CHAPTER VI. TECHNICAL FUNCTIONS FINDINGS AND RECOMMENDATIONS GENERAL Of all of the Divisions, Technical Functions (T/F) was the most difficult to establish and to get productive, not because of its uniqueness, but because of its departure from the past in two significant areas. One was that it .
assumed Hne responsibilities and the other was that it was given the task 2 to build an in-house technical capability where Httle had existed previously.' t This meant assembling a group of over 200 engineers by bringing together the nuclear engineering resources of Met Ed, GPU Service Corporation and, later, Jersey Central. But it also meant hiring from the outside a large number of its group. Doing this would probably have been accomplished without too much difficulty if there had been a one or two year hiatus on work, thus allowing the new -organization to form and become somewhat -
capable. Instead, heavy demands were placed on T/F as if it were a fully operational group and this resulted in technical work needed at the sites to s fan further and further behind. It is also significant that the demands during 1 this period .were abnormal At TMI-1, in addition to all of the design changes resulting from the accident (TMI Lessons Learned), the steam generator tube leakage problem had to be faced and resolved. At 'Qyster Creek the .
engineering workload increased significantly because of the sparger and torus problems,-in addition to the numerous repair problems. ;
Other Divisions within GPUN had to face many of the same problems but not with the same intensity. Either they were organizations which -
essentially already existed such as in the case of the plants, or their services were not as time sensitive to plant operation, such as Maintenance and Construction (M&C). For example, if M&C did not reach full capability for two years, which it didn't, the plants did not have to do without a maintenance capability albeit less effective. The same could be said of a number of other divisions. However, T/F had to produce and do it during a period of rapid growth.
Essentially, this is what BETA found in its review of T/F. It found ization struggli get its work done with a let ef_. mew people to figure out frWwere. it-found top man & gemma -
"within 'hlriTI'ng to spend _ an in nate amount of time solving day-to-day problems that aQorganizatIS would be handling in a routine manner. '
It found T/F management sun anernpting to put in place methods of operation suitable for running a large 250 man engineering force in contrast to their past experience of running smaller groups and depending more on outside contractors.
The situation was further complicated by the one year or so taken to '
incorporate Oystar Creek engineering into T/F. Prior to the formation of GPUN, there existed a relatively small but knowledgeable group under Jersey Central at their headquarters location in Morristown, New Jersey. For the first year of T/F's existence, it primarily concerned itself with TMI-1 and TMI-2 problems allowing the group at Morristown to continue handling the Oyster Creek work. in May 1981, the Jersey Central engineering group was moved to Parsippany and came under more direct control of T/F. Because of their unique knoivledge of BWR technology, they could not be distributed '
64
~
'E throughout the new T/F organization and were *et up as a separate group. .
This is one reason why today there exists a large Oyster' Creek conttigent in Engineering Projects. Anomalies such as this are being worked out and n progres is being made.
The situations described above are not cited to indicate that the decisions were wrong or untimely, but to provide an understanding of the -
problems that had to be faced. It will take more time for T/F to mature into an effective, smooth running organization. The specific findings which [
' follow reflact some of the problems BETA considers essential to solve in reaching that point.-
eeee T/F OVERALL EFFEC'11VENESS t
FINDING VI-A The overall effectivenes of T/F in supporting TMI-1 and Oyster Creek is lacking.
- DISCUSSION In order to achieve an efficient operation at the two plants, it is [
l- essential that there be timely and competent engineering support. When this does not occur jobs will not be done properly, there will be much rework, the plants will suffer and costs will be high. 'Ihis generally characterizes the situation existing today. It is more pronounced at Oyster Creek than at TMI-1.
There has been a noticeaO improvement in this situation over the l
past two years and ibrther evidence of improvement can be seen. There i are many factors, previously discused which contribute to T/F's inability to support the plants effectively. Most prominent is the newnes .of the organization, new people learning their jobs and the large backlog of problems ,
facing the new organization. As T/F matures, BETA expects to see continued improvement. The purpose of this finding is to point out a number of basic areas that BETA considers are not being resolved within T/F at the needed l pace or in a proper manner.
1 T/F has over 250 engineers and technical people devoted to TMI-1 and
-l Oyster Creek. That is a sizeable engineering force to manage. It takes
( people who are capable of directing the efforts of many multidisciplined groups, ensuring that all the elements that go into creating a productive engineerirg force are handled. This includes such things as:
r .
i
- a. . Hiring
- b. Training
- c. Work assignment
- d. Organization >
- e. Scheduling of work
- f. Work performance evaluation j g. Customer needs/ satisfaction
- h. Cost performance
! l 65
- - - . - -- , - __~ ~~
J.
~ ~ - - " - ~ -
~.
- i. Contracting It is BETA's opinion that the management of T/F has not grown or y matured at the same rate that the size or needs of the organization have grown. Management is still attempting.to function as if T/F were a small, independent, ear-me-if-you-need-me group of offsite engineers. It has not developed the capability to use effectively the large number of people now -
in place. High level managers become so engrossed in daily technical issues
(
/'
that the bulk of the engineering talent is left to fend on its own without j sufficient direction. Managers need to learn how to stay involved in the technical details but not to the extent that their people are deprived of direction.
The organization has not learned how to discipline itself to meet commitments with a quality product. Achieving this is not just a matter .
1 of hiring more engineers, in fact, it is BETA's opinion that very few people shouM be added to T/F until the present organization can demonstrate it can manage what is already there.
~-
Ultimately, T/F should be in a position to be the leading professional group within GPUN. It should be respected by the other Divisions for its technical competence and for its ability to solve technical problems at the d '
plants before they become causes of lengthy shutdowns and delays. Today :
this has not happened, particularly at Oyster Creek. [
RECOMMENDADON
- a. Hold the size of T/F to about where it is for the present.
- b. Look at how to enhance the capabilities of the various levels of L management of T/F to run a large engineering group.
- c. Seek outside help if necessary to provide assistance to T/F J
manageme.it in learning how to run a large engineering group.
. ee T/F ENGINEERING SERVICES Procedure Changes FINDING VI-B-1 It is too hard and takes too long to get a Technical Functions procedure changed.
DISCUSSION
, The principal problem in the Engineering Procedures and Standards group hs that it takes too long to get a change issued to a procedure. The feelings of others in Technical Funetions are that since the procedure "can't" 1
be changed, and since it " won't work" as written, the procedure is simply
! Ignored. Responding promptly to change requests is a large part of i establishing the authority of procedures and of building a memory into the
- system.
! 66
t
~
RECOMMENDATION .
Respond to change requests to Technical Functions procedures promptly.
e...
T/F ENGINEERING SERVICES Engineering Cost Analysis -
2
~
l FINDING VI-B-2
( Tlv Engineering Cost Analysis section is not analyzing costs.
DISCUSSION t 4 The service currently provided by the Engineering Cost Analysis section is vital to the proper functioning of the Division, but the effort is not devoted to the principal reason for the section's existence-cost estimating and analysis. 'lhis section spends essentially fun time interfacing between
[g/Y' Technical Functions and the accounting systems.
J The normal accounting methods used in the GPUSC computer system ,
@f (COMEC) of advance bookings, invoices rolled forward, and journal entry :
Y corrections (vital to the Treasury function) serve to generate confusion in '
'- the management of a project or activity. Since the business information currently made available by COMEC, does not help make work management decisions, the Engineering Cost Analysis section is required to devise and construct other busines rgorts that are useful to work managers.
(F Fortunately, the section is able to do this, but only with significant effort which detracts from the primary function of estimating and analyzing costs.
' The Director, Fiscal and Information Management has been making efforts to resolve this problem.
RECOMMEN DATION Concentrate the effort of the Cost Analysis section on cost estimating and cost analysis. Get this group out of the cost reporting business, eee.
T/F ENGINEERING SERVICE,S Design and Drafting FINDING VI-B-3 l Drawings have not been revised to show completica of modification _
work. /
DISCUSSION -
h /
I t
The availability of corrected draw'ings, showing changes made to [y),;
systems, is not good. During our interviews in Technical Functions, we were f '<
informed that &awings were not revised until five de: sign change notices
- R 67 C 1
. ..a
= - ~
-(DCN's) had been completed. Then,~ the drawing would be revised, showing -.
all five of'-these DCN's. Since the interval from the first DCN to the fifth i DCN could be protracted, some drawings are not current as regards ..
modifications.
[ RECOMMENDATION Revise drawings when DCN's are received in Design and Drafting such that no DCN will be more than six months old.
i ee.e ;
T/F ENGINEERING SERVICES .
Design and Drafting FINDING VI-B-4
[, ,
Rework, as measured by the number of Field Change Notices, is excessive.
DISCUSSION Ideally, there would be no need for a Field Change Notice, however the need will always exist. Some Field Change Notices should never have i i
been written-the one requesting correction of a misspelled word,' for example.
i But others are reaL All are difficult to cope with and increase the cost s of doing work. The number of Field Change Notices, and hence the amount ,-
of rework required, will decrease only to the extent the accuracy of the original & awing is improved. Others have solved this problem by design reviews with consideration for constructability, ALARA, operation, maintenance, and accessibility. This should not require a large review board !
to accomplish, rather plant checks for existing conditions and supervisory review should sufflee.
f(ECOMMENDATION Technical Functions, involving Plant Engiv aering as appropriate, should conduct design reviews before work is started so decrease the need for Field ,
Change Notices during construction, operation, or maintenance.
eeoe T/F LICENSING & REG AFFAIRS Staffing ,
FINDING VI-C There are too many people assigned to the Director, Licensing &
Regulatory Affairs.
DISCUSSION There are 38 people in this group. There are 14 assigned to PWC licensing,7 of whom are at the TMI site, and there are 11 assigned to BWR i
. 68
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licensing, 4.of whom are assigned to the Oyster Creek site. Seven are in Environmental Licensing and 4 are in Generic & Regulatory Affairs. There - - -
is justification for GPUN to carry a larger number of Licensing people than other nuclear units, particularly during the past several years while hearings were going on relative to TMI-1 restart. However, when the TMI-1 restart imue is resolved, the total number of people in this group should be reduced.
The BETA review indicates that the size of this group is justified on the
" basis that it performs engineering functions which shouW be done by .
Engineering and Design or Systems Analysis. Licensing and Regulatory Affairs i (L&RA), to be most effective, should be in a position to provide a i
> knowledgeable interface between GPUN and the regulatory bodies. ' It should avoid functioning m the extremes, where on one hand they are merely a
- paper-paming mail drop, and on the other hand being in a position where\
they make technical decisions. They should provide a technical input into the decision making proces based on their unique knowledge of the regulatory process. -
s BETA also questions the necesity to have a separate group of 3 people ,
asigned specifically to Generic & Licensing Affairs. That function could be performed by one person in the headquarters organization. It is also BETA's opinion that seven people, including those located at the sites (3),
are too many to handle Environmental Licensing.. ,
1 RECOMMENDATION The role of L&RA should be redefined to ensure it acts as the knowlegeable interface between GPUN and the regulatory bodies. It should be possible to effect a reduction in the number of people asigned to Licensing and Regulatory Affairs. After the TMI-1 restart, a further reduction should be possible without sacrificing the performance of any necesary function normally expected of this group.
.( .
T/F ENGINEERING AND DESIGN
. FINDING VI-D There is a lack of intimate, day-to-day knowledge of the problems being found at the plants that require engineering support or involvement.
DISCUSSION One emential element in creating an effective engineering group that takes a leading role in improving the operation of the plant is knowledge of what is happening at the plant. Our review indicates that this is lacking at Oyster Creek and TM1-1. There still exists too much of the attitude that if Technical Functions support is needed, the plant will ask for it. We could not detect a sense of " ownership" or inquisitiveness. There have been efforts j made to impmve this situation but the results so far are meager. It takes time and effort to develop a headquarters engineering group that has the confidence in itself and hat, developed the confidence of the alte people.
The people in Engineering and Design need to have a better means of keeping informed on what problems exist at the sites without creating a burden on 69
. . - _ _ . _ - - .-._ - - _ _ _ = . -
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the plants. Each site has a Technical Functions representative and it may be apprapriate to make more use of him as a source. .
4 RECOMMENDATION The Engineering and Design Director shouM investigate means for having plant information and problems flow into his organisat,on on a routine basis and not just when Technical Funettons support is called for. He shouW also j' instin into his people the feeling that they are more than just a service ,
waitiry to be tasked.
eeee T/F SYSTEMS ENGINEERING STAS t
FINDING VI-E-1 Th t Technical Advisor (STA) program at both sites, but a Opste@r Creek, needs to be reviewed and strengthened. '
DISC O N f There are a numbe of problems associated with the STA program at ,
both sites. These problems are known by GPUN management and action is being taken to correct thein. These problems involve attrition, the STA ,
trainirg program, and proper utilization of the STAS, both in their training period, and in their status as qualified STAS.
There are a number of observations which BETA believes shouM be considered in GPUN's effort to improve the STAS; It appears that the STA training program is too operator oriented. The purpose of an STA is to provide the Shift Supervisor on watch a higher degree of technical expertise durirg a plant crisis than normally resides with the Shift Supervisor. While the STAS need to understand how the plant operates, they are not there to act as a " super" shift supervisor. Their training should be oriented towards developing a high degree of technical knowledge of the plant, understanding why things happen the way they do, l and developing the ability to anticipate phenomena at a technicallevel higher l than normally expected of a Shift Supervisor. Our observation is that this is not being done. One contrbutirg factor couM be the practice of actually attempting to qualify STAS as SROs. ,
- l There is a serious lack of under:tanding on the part of the Shift l
, Supervisors at both plants on the role of the STA. To some extent, there is l na element of dhtrust of the STAS' ability and of their motives. There is 1 alm a lack of understanding on the part of the STAS as to just what role they are to play, particularly during the vast majority of time that the plant is not in an abnormal mode.
~
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RECOMMEN DATION ~
- a. In the process of developing the STA training program, which is now underway, greater emphasis should be placed on providing the trainee with a firm technical foundation and less on making him a quallfled operator.
There may be certain factors that wouM lead GPUN to conclude ?
that this practice be continued. However, all factors should be considered. STA's should be SRO trained and should be required to pass all requirements except the NRC examination. Incentive bonuses could still be awarded for thh accomplishment.
~
- c. Make sure there are sufficient STAS in the training program to handle, not only expected attrition, but to ensure that promised rotation out of the STA role will take place.
- d. Review the ground rules on just what an STA is expected to do during abnormal situations, and, just as important, what he is expected .a do during normal day-to-day operations. After reviewing these ground rules, make sure the Shift Supervisors t understand them. j
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eeee T/F SYSTEMS ENGINEERING Systems Analysis _ Director FINDING VI-E-2 ga .
r The need for a Systems Analysis Director is questionable.
DISCUSSION, There exists within Systems Engineering a group entitled Systems
- Analysis. It has two groups; Safety Analysis and Plant Control, and Plant Analysis. The former group, consisting of ten engineers, is basically responsible for developing and using the software to analyze plant safety.
The latter group performs trend analysis and is responsible for the STAS.
Each of these groups is headed by a Manager. The Systems Analysis
( Director also handles Human Factors engineering. It is the opinion of BETA that the existence of the position of Systems Analysis Director is unnecessary and can be eliminated. All of the functions now performed can be performed within the two groups. ,
I RECO MMEN D ATION BETA understands that action has been taken on this item.
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T/F SYSTEMS ENGINEERING -
Involvement in Training FIN DING 'VI-E-3
) ,
There is lack of involvement by Technical Functions in the conduct of the Training Program, particularly operator training. ,
i-DISCUSSION 9 I Consistent with the creation of the functional GPUN organization is i -
the concept of. greater involvement in aR technical areas by . Technical Functions. Because of the many problems being found in - the training programs at TM1-1 'and Oyster Creek, BETA assumed that there wouM be
.~ .
noticeable evidence of Technical Functions invcivement with the corrective 1
effort. BETA ~ could detect very little, and it is not clear that there is at this time much interest in having any, either on the part of Technical r
Functions, the plants, or the Training Division. BETA considers this to be a mistake, particularly with respect to operator training. BETA recognizes i that at its present state of development with its limited capability, T/F is
- hard pressed to move into this area at this time. However, there should .
be ways T/F can become more involved in training than it is today. {
RECOMMENDATION s Technical Funetions should consider ways to take a6 more active interest # ,
in providing technical guidance to the training programs, especially operator i training. t eoee
'l T/F SYSTEMS ENGINEERING r Nuclear Design Capability FINDING VI-E-4 -
GPUN's goal to achieve an in-house licensed nuclear design capability e j may not provide the anticipated advantages, f'
DISCUSSION ;
During the review of the Technical Functions Division, Nuclear Analysis and Fuels group, it was apparent that GPUN management was aware of and i
concurred in a projected change in direction in the group's operation. The long term objective is to provide an in-house capability to perform nuclear calculations to support issues relating to licensed matters.
i i
Three advantages are given for providing this capability. The first was to reduce GPUN's dependence on core vendors, the second was that a i
better job would be done by GPUN, and the third was that it wouM save money. Other secondary advantages, such as flexibility, also would result from this approach.
1 72
Based upon BETA's review, it is concluded that the ' proposed design .
capability upgrading would not provide GPUN with a complete independence J
' from core vendors. .The nuclear design calculations to be performed by _
GPUN would depend upon information and calculations performed by the vendors who also must obtain NRC approval of their work. GPUN's design calculations would depend upon the use of: .
- 1. Standard fuel assemblies or bundles available from the vendors.
- 2. The results of vendor analyses which specify the range of acceptable j fuel performance parameters for these standard fuel assemblies or ,
- m. bwdles
. In addition to the above dependence on the core vendors, GPUN wouM also depend on the core ver. dors or other outside suppliers to perform certain licensing calculations to support the GPUN naclear design group. An example is loss of coolant calculations. These licensing calculations, which are "
performed Infrequently, would be performed by consultants or the core
,- vendors.
As can be seen from the above, developing the planned in-house analytical capability will not provide a complete independence from the core vendor or outside consultants. .
At the present time, with its existing manpower in the Oyster Creek -
group, Nuclear Analysis performs calculations to assure that the core vendors ,,
provide optimum reload configurations. This in-house optimization capability .
eurrently assures that BWR core reloads are indeed optimized. There is no reason to believe that convertirg to a licensed analysis'would provide a I more optimum core configuration than is currently obtained.
t To achieve an in-house licensed nuclear capability is difficult. While a few utilities have efforts underway to obtain such NRC authorization, as of mid-1982, only one was close to achieving this objective. It would appear that a nuclear engineering manpower level of approximately fifteen engineers
, for each plant wouM be required to develop this capability am. i meet the day-by-day plant support requirements. This represents a net manpower
, increase of about five engineers per year per plant type to achieve this objective. Several years' (three or four) effort would be required, t
. The other stated advantage for developing an in-house 11eensed nuclear design capability is cost savings. It is understood that core vendors currently charge approximately $1.2 - $1.7 million for a licensed major core configuration design. Routine reload calculations cost approximately
- $500,000, while minor design modifications cost approximately $200,000.
Present GPU in-house capability for Oyster Creek is able to calculate routine reloads and minor design modifications, it is understood that these calculations currently satisfy NRC requirements for showing that minor loading changes meet license requirements. Based upon the estimated costs for service by core vendors and consultants and the GPU estimated manpower requirements to develop and maintain an in-house licensed capability, it appears the cost to provide this in-house capability would be offset by the savings that would result (this is a breakeven situation).
73
- In summary, .the advantages resulting from the proposed GPUN action .
are not substantial. In addition, there is a significant potential disadvantage - Z that has not been addressed. In most esses the techniques that will be used .'
by GPUN are those that are being developed by EPRI. GPUN does not plan to have an -in-house method development capability. As long as core operations do not result in the discovery of new phenomenon, the EPRI model shouM be satisfactory.
It is anticipated that new phenomenon wH1 not oceur if GPUN eentinues to use the current clan of fuel aser.mblies whleh have been thoroughly proven j, in operation. However, if GPUN antleipates they wD1 want to use " state i of the art" fuel assemblies, they shouW recognise that operational experienee may raise issues. This would require use of performance models which are not included in the EPRI catalogue. GPUN will be Mt on the designer for technical support. By GPUN actions to obtain Ise vir.4 .es they will
" find it difficult to obtain this support when required. ,
a RECOMMENDATION Unless GPUN is willing to restrict its fuel selections to proven
- technology and not attempt to ineceporate advantages in performance until they have been thoroughly tested in operation at other planta, BETA believes that there is no reason to develop an in-house licensed nuclear design .
espability. If such a capability is not developed, a nuclear analysis staff 1 of nine engineers per reactor type shouW be adequate to handle GPUN's i
. andytical fuel requirements. -
,,,e 3y"'
T/F ENGINEERING PROJEC15 Task Assignments ,f
' ^
j- FINDING VI-F-1 Engineering Projects personnel are performing tasks that could be better done elsewhere in the Division, thus deeressing their capacity for the management of engineering projects.
DISCUSSION Project engineers in the Oyster Creek Engineering Project are spending l time making material lists from drawings in preparation for requisitioning '
material This is a distraction from their primary function. The material l
'l lists could be prepared more readily in the drafting room under the supervision Requisitioning could be more of the Manager, Design and Drafting. i effectively done either by Design and Drafting or Engineering and Design.
These latter organizations traditionally perform these functions in most p companies. The advantage would he that the Project Engineer would be freed from these chores and could devote his time to the project management
- aspect of his work, which urgently needs greater attention. The above are i just two examples of the Oyster Creek Engineering Project engineers doing the work that should be done in Design and Drafting or Engineering and
[ Design. We conclude that this is a hold 3ver from the previous JCP&L Oyster )
Creek Generation Engineering practice, whleh in that environment, was 74
entirely proper and requirr.d. However, the previous Generation Engineering -
group is now an Engineering Project group. About one-half of the Oyster 1 Creek projects are still in the okf Generation Engineering style. _
A multitude of tasks are being left undone in the' Oyster Creek Engineering Project, although the group is quite large relative to the TMI-Engineering Project:
- a. Too many jobs exceed budget and too many fall to meet schedule.
j These phenomena usually come as a surprise and can be avoided by closer tracking and guiding of costs and work in progress. 3
- b. Approximately 20% of the total GPUN budget is spent on Technical Functions originated contracts for engineering. That work, as well as the in-house work in Engineering and Design shouM be tracked closely by the Engineering Project to ensure costs are worthy and performance is satisfactory. ,
- c. If a project engineer spent more time managing the cost, schedules, and performance of an engineering task, he wouM not have to devote the large amount of time now devoted to justifying or accounting for cost overruns and schedule delaya.
- d. A modification to the plant is developed technically in Engineering 1 and Design and the modification is taken up by Engineering Projects, i Base line engineering is, on occasion, performed in Engineering !
~
Projects, it is our opinion that base line engineering would be .
peformed better and more logically in Engineering and Design under technical supervision. 'Ihis, again, would free up project i engineer time for project management.
4 RECOMMENDATION The functions currently being performed in the Engineering Project that detract from the project management capability of a project engineer ,
~
should be evaluated and reasigned to strengthen the effectiveness of I Engineering Projects.
.. e f
. T/F ENGINEERING PROJECTS
[
4 Training of Engineers a ,
FINDING VI-F-2 The training of project engineers is weak.
DISCUSSION
\
l Project engineers are not given training on how the Company is structured or how it is supposed to work. There are too many wlm do not understand the organization. They fall in the category of "new to the Company" or "still living in the old days".
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e .t -
. - -. u . . . - :: a.- ... , ._.- ---..-. : .: :.: .
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Because of the impact that a project engineer can have on the proper -
~
control and management of a project, specific training in the Company's methods and policies is essential. .
- RECOMMENDATION Provide training to Project Engineers in the Company's structure, methods and polieles.
. e. . .
j
. T/F. ENGINEERING PROJECTS Cost Information FINDING VI-F-3 Project engineers do not receive adequate infoemation 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 i the major O&M project.
DISCUSSION A project engineer is the person 'at headquarters who is responsible for I the budget activities assigned to him. He, with assistance, of course, i
- developed the initial buget and schedule and initiated the requisitions for, I.
contracted engineering services, long-lead material, and the work .
authorization to M&C. Having converted the job from an engineering concept to a cost incurring project, he must have feed 4ack on costs and progress of the work-not only to manage the project in Technical Functions, but also to prepare himself for more effective work on subsequent jobs. The cuttent reports are not adequate for the need.
RECOMMENDATION Engineering Projects, Engineering Servlees, MC, the plants, and Information Servlees should devise the reports that w!Il permit havmg a running knowle%e of cost and performance. To offset the cost of this work, this same group could easily determine a number of current reports which could be eliminated.
T/F STARTUP AND TEST ,
n i. l FINDING VI-G ~ !
A separate group at the Director level for Startup and Test is questionable.
DISCUSSION There is no question that there need to be people who are assigned the responsibility for startup and test. BETA questions the need for creating -
76
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a separate group at the Director level and having 23 people yss';ned. At
- the site these needs can be filled by assignments within Plant Engineering. _
At headquarters they can be filled by assignments in System Engineering.
There should not be a need to have 23 people assigned full-time to this area.
~
- RECOMMENDATION Consider reassigning this group at headquarters into the System
- Engineering group. Assign the site people to Plant Engineering and reduce ,
the overall number of full-time people. As needs dictate, each of these i g
groups can be augmented by engineers at the locations needed. ,
~
..e.
'_ T/F CHEMISTRY FINDING VI-H Neither the chemistry group in Technical Functions nor the System Laboratory has assumed a leadership role in the TMI-1 or Oyster Creek chemistry improvement programs.
DISC USSION
> Oyster Creek and TM1-1 have lacked patent _.
IQ__ Although th hemistry' s J nagemc o c_ hale chemistry __ programs.
deficiencies had been reasonably well identified, the plants did not recognize -
how to solve their key problems. Talen,ted chemistry personnel capable of helping the plants solve their chemistry problems, including the management
- ones, have been available under Technical Functions Chemical Engineering
. and in the System Laboratory located at Reading, Pennsylvania. Although this Laboratory was not transferred to Technical Functions until April 1982, it was available under Nuclear Assurance previously.
Strong feelings were apparent against the other chemistry groups among senior personnel at System Lt.boratory, Chemical Engineering, and the nuclear plants. Signs of jealousies, finger-pointing, turf battles, and expressions of "that is not my job" have been all too evident. Although Chemical Engineering and System Laboratory personnel feel they have provided great assistance to TMI-1, they have not provided what has been needed to solve the major chemistry problems at TM1-1 and Oyster Creek in a reasonable time. A chemist has recently been hired from outside GPU as director over Chemical Engir.ecring and System Laboratory. One of his first priorities is to resolve the conflicts between these groups and between these groups and the plants.
RECOMMENDATION
_l Resolution of the conflicts among the chemistry groups could be simplified by removing System Laboratory from GPUN. This would have the advantage of removing about thirty manycars per year of nonnuclear work from GPUN since about 90 per cent of the work of System Laboratory '
b for fossil plants. Because this reorganization would make it harder in i
the short term to use the resources of System Laboratory, this change should t
U 77
be viewed as a long term objective after the chemistry programs at TMI-1 -
and Oyster Creek have been improved. -
The new T/F Chemistry Director has been directed to get actively involved in all areas required to obtain the needed improvements h1 TMI-1 f and Oyster Creek chemistry programs. BETA considers this broedening of I
assignments to T/F chemistry personnel should help resolve the previous problems.
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W m m'M e e e - -p om-1 I
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CHAPTER VH 1
ADMINISTRATION FINDINGS AND RECOMMENDATIONS t
t h
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O CHAPTER Vll. ADMINISTRATION FINDINGS AND RECOMMENDATIONS '
GENERAL
)
When GPUN was formed. It was clear that there would have to be certain divisions such as the plants, technical functions, etc. It was also known that there would have to be a division to handle the administrative g load of the corporation. What happened was that the Administration Division ,
became the recipient of any funetion which did not clearly belong in one of i J
the other divisions. This is why there ended up being so many diverse 3 activities located within Administration. The fact that it " controlled" the
{ money and the people immediately put this Division into a position .of J pereelved power. It was soon evident that it, as a Division, would have more GPUN people on the payroR than any other division. These conditions lead to problems. ,
Durity the p'ast year, BETA has been able to observe a needed retrenchment in the breadth and scope of functions coming under h Administration. BETA has also recently seen a start in the reshaping of J the role Administration plays in carrying out corporate policy in contrast to l the role it appeared to be taking in the early phase of its development. !
These are healthy signs. The specifle comments which follow further expand ,
on this theme.
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. ADMIN EFFEC 11VENESS -
FINDING Vll-A The Administration Division needs to improve its ability to provide a g servlee function and to leisen the pe.eeption that it is a control function.
DISCUSSION l It is BETA's opinion that the Ailministration Division, with the number of functions it now performs, has beco'ne overly oriented towards attempting to control events rather than providly a servlee. This opinion is shared tmiversally throughout GPUN. There is, and has been, an effort to correct
{ this situation within the Division. However, BETA feels that some fundamental changes are necessary before this problem will be resolved.
{. The original composition of the Administration Division included handling essentially the following functions:
- a. Fiscal Management
- b. Matsela! Management
- c. Faellities Management
- d. Contract Management
- e. Security
- f. Human Resources ,
- g. Information Management .
- h. Other 79
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2
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The Division was not organized strictly along these lines, but they were -
the major areas covered. They all provided a service of one kind or another to other divisions. Because of the nature of these services, they needed to be consistent across the divisions and, in some cases, such as in Fiscal Management, they needed to act as control functions in the name of the Office of the President. Policy is established by the Offlee of the President and in many cases it is tnen tne job of Adeninistration to determine if it is being carried out. It should do this in a mode of cooperation and assistance -
to the other divisions rather than in the role of an adversary. -It should be 1 the goal of Administration to develop procedures and methods for carrying I
.. out corporate policy in such a way that it causes the least amount of disruption within the other divisions and without creating the impression that these functions are an and unto themselves.
l
. For example, it is certainly corporate policy that costs will be i controlled. There are certain requirements imposed on GPUN by the GPU Service Corporation and others on just how this is to be done. . However, even within these constraints, Administration still has the freedom to create a system within GPUN for controlling costa. -In doing so, Administration can take the approach that it will develop a system that accomplishes the desired end but is so complex and onerous that the divisions either can't comprehend it or haven't the time or people to carry it out. On the other t hand. Administration can approach the problem by, first, understanding the t-problems and capabilities of the other divisions and, then, seeing if they can
- develop a system that b effective but not overpowering. }
~
' It is BETA's opinion that, at least for the first year or so Administration '
took the first approach. It created the impression that it was al19owerful and imposed its will as it saw fit in the name of the Office of the President.
3 A number of actions since then have eased this situation. For example, in -
October 1902, the Human Resources Department was transferred from Administration to the Office of the President with the Director, iluman Resources reporting directly to the Executive Vice President.
RECOMMENDATION
- a. The Director, Administration and his leading people should continue to redirect their efforts with the aim of providing an effective service to the other divisions. This . can be enhanced by Administration doing those things that the divisions can not do and by letting the divisions do what they are structured to do best.
- b. The Administration Division should attempt to change the impresion that they and they alone determine how corporate policy is to be carried out in administrative matters, t c. Adopt the motto, "We Serve the Plants".
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ADMIN MANAGEMENT SERVICES
- FINDING V5-B The Manager of Management Services has a narrow scope of work assigned. ,
i 1
. DISCUS 510N 3, At the time of our review the Manager of Management Servlees was -
responsble for the Policy and Procedures system and the Limit of Signature Authority procedure. He was also preparing a supervisor training course.
- Since the time of our interview, the Manager of Menagement Services at TM1-2 and the two people working for him have been assigned to the Manager of Management Services. BETA notes that GPUN has undertaken to -
- ~
concentrate the support functions for TMI-2 in the TMI-2 site organisation and considers it wouM be logical to assign the TMI-2 Management Servlees
- section to the Director, TM1-2, rather than have a Parsippany manager
- responsble for three people at TM1-2 who are working exclusively in support 7
of that site. , , ;
{ Since the procedures mentioned above have been issued and implemented }
4 in GPUN, BETA considers the scope of work does not justify the position '
s
" Manager of", nor the staff asigned. -
1 RECOMMENDATION Consider increasing the scope of work asigned to this senior manager
( or deleting the position. t
') eeee i
, ADMIN OPERATIONS ANALYSIS FINDING V5-C The efforts of the Operations Analysis (Ops Analysis) group within Administration are not effectively channeled.
3 DISCUSSION
'd Having an Ops Analysis group within GPUN can provide the Offlee of j the President with useful information that might not be readily available i elsewhere. However, based on the review conducted by BETA, it does not appear that very meaningful or even useful areas have been reviewed. It i
![
j is also our opinion that this situation will not be improved if the Ops Analysis group is asked to come up with the items to be reviewed or to set the y priority. Under normal circumstances, each manager should do his own h operations analysis, and, if he h capable and honest about it, the most i expert answer will emerge. If Ops Analysis is used in an " investigative" '
3 mode,' then Q A h usually the place to turn. Where an Ops Analysis group i
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1 0 81
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1
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can be used, and it should be used only by the Offlee of the Prt.sident, is to look into areas that don't fan in either of the two previously descrbed. .
> Based on BETA's review, the present Ops Analysis section is not being used properly. In fact, it is BETA's understanding that during the recent past, this group has been used to implant a cost control system within GPUN, a role completely outside the accepted function of such a group. .,
[
- J itECdMMENDATION The efforts of the Ops Analysis group within Administration should be directed by the Office of the President.
.eee l
ADMIN MATERIALS MAN AGEMENT Contracts
(
1 l FINDING Vil-D The cost reductions possible with more sophisticated contracting methods are not being achieved, j DISCUS $10N 1 Our early experience and exposure to contracting at GPUN created an ."
initial feeling of concern. Essentially an work was on a time and material
, _ basis, and insignificant effort on the part of the requisitioner was devoted to managing the contracted work. Comments on the role of the requisitioner
'e are in Finding Y!-F-1.
\ The current amessment of Contracts Management was done late in our review period, and we found much has been done in Contracts Management to correct the early problems. Contracts Management now works closely with requisitioners and provides assistance, advice, training, and support in developing requisitions that can be converted to the best type of contract.
Contracts Management has recently instituted a series of seminars for requisitioners, working with small groups, and plans to reach all prospective requisitioners. The seminars are to explain GPUN contracting policy.
RECOMMEN DATION
}
- a. Continue training of requisitioners. Also, devise a scheme for measuring the success of this training, e.g., how many requisitions must be returned for lack of compliance with instructed methods.
- b. Place greater emphasis on using Cost Plus incentive Fee type contracts. This will require having better scope of work definitions,
- c. Consider establishing monthly progress reports from major contractors Jn which work progress identified by task, and actual costs to the contract, by task, are reported. Also consider 82
. u.n-------.---_____ _ _ _ _ . _ _ ..
establishing quarterly reports from major contractors in which they forecast work progress and anticipated expenditures. _
ADMIN SECURITY FINDING VII-E .
There needs to be overall improvement in the Security Division in order to improve its efficiency.
DISCUSSION
~
In the security area, BETA contracted with an outside firm, Theodore Barry and Associates (TB&A), at the request of GPUN to assist BETA in its review. Two representatives of TB&A conducted a review at the two reactor sites and at headquarters. In addition, BETA independently reviewed a number of areas in the security area. These reviews indicate that while there are no serious problems which would contribute to high costs or poor efficiency, there are a number of findings which indicate that security management is not aggressively pursuing an across-the-board effort to ,
improve its operation. The BETA findings which follow are examples of 4-these indicators and are derived from the TB&A review as well as the BETA review. TB&A has prepared a detailed report of its findings and I recommendations, a copy of which has been transmitted to GPUN .
management. .
RECOMMENDATION Refer to specific Findings that follow. -
ADMIN SEC URITY Administration FINDING Vll-E-1 Soine security administrative functions at TM1-1 and -2 can be combined to save manpower.
DISC USSION Currently the security forces at TMI-1 and -2 work jointly and share responsibilities in several areas. For example, Unit 1 operates the site
- ' security computer system for both Unit 1 and Unit 2.
At this time, both TMI-1 and -2 have access control clerks and clerk typists. The TMi-1 access controlis computerized while the TMI-2 operations are manual. The TMI-1 supervisor stated that the TM1-2 access control workload could be handled by the TMI-1 clerk.
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RECOMMEH D'ATION
- It is recommended that the TMI-1 access control clerk handle the -
TM1-2 workload. Changes to the administrative procedures can be made to
, accommodate this change and a savirgs of one clerk at a cost of f approxintately -$2;),000 per year. In addition, TMI-l's clerk typist shouW be used to support TM1-2 at a savings of an additional clerk. BETA has determined that such a joint effort is consistent with current practice at TMJ, is not contrary to the separation of facility requirements in effect at -
the site, and wouM not constitute a mode of direct access between Unit 2 3 and Unit 1. , . t k
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ADMIN SECURITY -
TMl Response Force FINDING Vil-E-2 The Response Force capability at TMI-1 and TMI-2 can be considered
, to be 10 armed guards (each plant will support the other). Because outside j support is readily available, a smaller Response Force would meet NRC ;
requirements. j DISC USSION_
In several areas the security forces at TMI-1 and TMI-2 work jointly ,
and share responsibility. For example, TMI-1 operates the site security computer system for both units. Also the entrance gate security responsibility -
- is shared. This shared responsibility is accepted by NRC. In the event of an armed attack, both the TM1-1 and TMI-2 tif indicate they will go to the aid of the other group. The response force capability is 5 guards at each lant. NRC requires a site response force of from 5 to 10 guards, depending on the availability of outside help. In the case of the TMI site, because of the offsite response capability, it is judged that NRC would '
consider acceptable a response force of less than 10 guards, for example, 6 to 8 guards. It is recognized that a reduction of response force requirements i will not necessarily mean a one-for-one reduction in guard force manpower, ;
however, TMI-l's security supervisor indicated that at least one guard position ,
could be eliminated if the response force requirements were reduced. ,
RECO MMEN D ATION GPUN should consider the combined response force capability at TM1 in meeting NRC requirements. A reduced total capability of 6 to 8 guards should be negotiated with NRC. Where possible, the guard force should be reduced reflecting the above change. For each guard position canceled, 4.5 man-years of guard cost will be saved. BETA has determined in discussions with NRC and GPUN staff, that the proposed combined TMI effort is consistent with other TM1 joint security efforts and is not contrary to the NRC requirements regarding separation of TMI-1 and TM1-2 facilities. In addition, this type of potential direct access between Unit 2 and Unit 1 (emergency related) was specifically identified in GPU's statement regarding limited direct access of Unit 2 to Unit 1.
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ADMIN SECURITY _
, TM1 Engineering Support FINDING VII-E-3 Inadequate engineering and construction support for the TMI-1 and TMI-2 security operations is resulting in the need .to substitute guards for security hardware. Such substitutions are expensive.
I' DISCUSSION The review disclosed, that because of minor engineering or construction scheduling problems, guards were being used in place of installed (or to be installed) seculty hardware 'at TML . Examples include:
I a. The use of a' guard, 4 shifts, seven days a week, to observe the locked unalarmed gate separating the TM1-1 and -2 sections of the
- fuel handling bays (doors 73 and 74 in the environmental barrier).
The barrier has been installed for over thirteen months, however, the electrical work was not completed and the door alarms have not been activated. Guards used in place of the alarms have cost .
over $100,000 during the past thirteen months. At the time of I this review, the installed door alarms were yet to be connected. i
- Construction scheduling was identified as the cause for this delay. 1
- b. Doors 11 and 16 at TM1-2 have used guards to control access since $
the accident in 1979. This has cost in excess of $100,000 per year. Prompt installation of properly monitored door alarms would have saved this expense. Once door alarms were installed, the alarms were not used due to a simple problem associated with the alarm display. During the pelod of this review this problem was resolved and the guards are no longer used at this location.
RECOMMENDATION
- a. Adequate engineering and construction support should be supplied for security operations. Priorities should address the large costs
- associated with supplying manual backup to the security hardware.
! b. Procedures should be developed to require a periodic review of those cases where minor degradations in security system performance are compensated for stationing guards to assure that, i
in some cumulative manner, these do not result in GPUN's not meeting its commitments to NRC.
- c. Yhe alarms at fuel handling bay doors 73 and 74 should be activated and the manpower allocated to the TMI-1 guard force should be reduced by 4.5 manyears, f
- d. The manpowei allocated to the TMI-2 guard force should be reduced by 4.5 manvears to reflect the activation of the alarms at doors 11 and 16.
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. _ . - . __ _ . . . _ ~~_^ _ _
eoee ADMIN SECURITY TMl-2 Protected Area FINDING VH-E-4
.I The TMI-2 entrance to the protected area uses a temporary building -
l' and manual _ search to control entry of personnel This facility and its ,
operation is inefficient in the use of guard manpower. i i
DISCUSSION During this review it was noted that the protected area entrance at TM1-2 had a larger number of guards than TMI-1. This is a result of the j lack of metal detectors, hence, the requirem,ent for manual search and of
'P the. sman and inefficiently laid out building. TMI-l's processing center.
operates with a s!grificantly smaller staff.
RECOMMENDATION f
If funds can be made avaDable, the TMI-2 procesing center should be-upgraded. Temporary structures can be used but sufficient space should be ;
provided to allow effielent operation. - In addition, - metal monitors and 4 explosive monitors should be provided. It is _ estimated that the annual savings j s
[
in guard salary will eventually offset the cost to upgrade the facility. -
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! ADMIN SECURITY .
! TMI Alarm System
- FINDING Vil-E-5 1
The protected area perimeter alarm system at TMl has an excesive number of alarms.
- DISC USS10N During this review it was noted that the perimeter alarm system at TMl has an excessive number of alarms. This is a result of false alarms and, in addition, results from the pasage of workers and guards through the monitored areas, it is anticipated that this level of performance win not meet. future NRC requirements. It is understood that GPUN is evaluating G and upgrading the alarm system.
RECOMMEN DATION The perimeter alarm system should be upgraded to produce a system l
with a minimum number of false alarms.
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e oe e ADMIN SECURITY' -
Manpower FINDING VH-E-6 Manpower requirsments fluctuate as a rerult of training requirements, special security assignments and multi-shift operations. Extensive overtime ,
II o
is required to support this fluctuating workload. . i DISCUSSION There may be cost reduction potential in changing tour durations and monfiguring shifts. Due to the high number of craft workers at au sites, there is a peak security manpower need during shift changes. It may be pomble to provide security shift configurations which cover these peak .
periods while not retaining excess manpower beyond the actual need. For k example, revolving four 10-hour days could be used to provide a two-hour overlap in the morning and evening to facilitate ingres and egres procesing of high numbers of outage craft.
RECOMMENDA'110N .
t Review the current structure to determine when additional staff are i needed to handle peak security requirements. Examine alternative shift -
scenarios and tour configurations in an effort to reduce the overall manpower -
requirement and use cf overtime. -
' eoee ADMIN SECURITY i
Unnecesary Guard Protection FINDING VH-E-7 ,
Guard protection is being provided to areas that may not require the ,'
protection or warrant the expense.
DISCUSSION The foHowing exampies may indicate that the cost effectivenes of current guard coverage has not been assessed:
o Evening guard protection is provided for the TM1 Training / Visitors Center. Coverage could be accomplished by installing a local security alarm (or using a leased 'line to the Central Alarm Station) and utilizing random patrols.
o Guard coverage is provided at Forked River. If possible, valuable materials that could be subject to pilferage should be liquidated or stored at other facilities.
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...:~.. ._ . ,-.. ::: . - . .- 1 o The TMl south gate needs to be covered by security guards only ;
during the peak shift-change hours. Currently, the - south gate serves 4 predominately-TMI-2 contractors. At the current craft manpower levels, -
the south gate acces point could be closed except for peak ingres and
- , egres times (approximately 0600-0800 and 1430-1630). The north gate can
" accommodate the additional trafffic from the south gate at nonpeak hours.
RECOMMENDATION The above security considerations should be evaluated for cost j'
- j effectiveness. . It is estimated that these changes would save 8.5 to 9 i
. manyears of effort.
ADMIN SECURITY Contractor Support FINDING VII-E-8 ,
- GPUN has not received adequate support from Vikonies in correcting keycard acces system deficiencies.
t
, DISCUSSION The card acces system has been plagued by hardware .and software i
- problems for several years. Ykonics, the turnkey supplier of hardware, -
software and installation, has failed to provide adequate support towards -
I correcting system deficiencies. The problem has been exacerbated by the l fact that GPUN has not dedicated someone with a strong computer background -
A specifically to support the system and to act as a liaison with -Vkonies, GPUN has recently threatened citing nonperformance and withholding the l' performance bond retained against Vkonics in an effort to force Vkonies 1; to correct deficiencies.
RECOMMENDATION
}
GPUN should consider having an engineering evaluation made (either by GPUN, GPUSC, or contractor personneD of this problem. This engineer should evaluate the proposed Vikonics' corrective action. This evaluation should include inputs from the other utilities using Vkonics' equipment. This evaluation should consider the effectivenes of the system as is, and the 1kelihood Vkonies will correct the existing deficiencies. Based upon this 3g review a plan of action should be identified which includes both engineering and legal alternatives.
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- ADMIN SECURITY -
Position of Lieutenant FINDING VH-Fd Approval has been requested to reorganize the security force to establish a Lieutenant position at each site.
DISCUSSION .
It is understood that in order to provide additional administrative support and advancement opportunities, action is underway to establish a Lieutenant position at each site.
, {'
RECOMMENDATION If it is decided to provide this new position, the total number of
/ managers in Security should not be increased.
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i Overtime FINDING Vll-E-10 The security operations require extensive overtime.
, t
- L- DISCUSSION Current security operations at the three sites require the use of
- approximately 18 man-years of overtime. Considering the premium costs associated with this overtime, it represents a significant fraction of the cost of guards and should be inch:ded in ectablishing manpower levels.
For example, the current onboard staffing of the Security Department at Oyster Creek is 62. However, the current overtime usage raises this number to the equivalent of 72 man-years. The end of year 1982 authorized level is 54. It appears that this number does not reflect the use of overtime and, unless it ie controlled, the possibility exists that overtime - will be increased to offset the reduction of personnel. For TMI-1 the onboard ji;j staffing is 54, with overtime, the staffing is the equivalent of 57.5 man-years. The end of year 1982 authorized level is 50. Again, it would appear that this number does not reflect the use of overtime.
RECOMMENDATION o Manpower assessments in the security area should include consideration of the overtime usage.
o Based on comments in this and other findings in this section, the ;
recommended staffing levels, including the use of overtime, are -
as follows: _
Manyears Effort e
Oystar Creek 62.0 TMI-1 48.5
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ADMIN SAFETY AND HEALTH _
f Need for Doctor FINDING Vll-F GPUN has no employee who is a medical doctor at headquarters or Q
TMI-1 or Oyster Creek to oversee medical aspects of the GPUN radiological ,
health program. Part time contract physicians and a contractor are used i!
f' for these functions. !l i
f DISCUSSION In addition to conducting physical examinations, physicians are needed for several radiological health functions, including. treating injuries involving -
radiation or radioactivity, advising workert and the company 'on radiation workers who have unusual conditions, assisting in radiation injury claims, and
- ensuring medical records will support future needs regarding radiation injury claims. ' Part-time contract physicians have , been conducting physical examinations at TM1-1 and Oyster Creek but they have not been trained for
- these other functions. There have been examples where these other functions have not been performed well. These other functions require a degree of ;
I l expertise and sensitivity and training that is unlikely to be obtained in part- 4 time contract personnel. 3l
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BETA considers a company physician to be an important part of a .
radiation c' aims prevention program. The value of such a person has been -
demonstrated in past . BETA experience to outweigh the difficulties in
- obtaining, training, and retaining a physician interested in occupational -
i medicine. The position does not call for a nationally recognized radiation medicine expert; such people are available as consultants when needed and the limited work requiring such an expert at GPUN would not keep him j challenged as a full-time employee. In past BETA experience the benefits t to the radiation claims prevention program have been achieved by obtaining a physician trained in occupational medicine and providing him extra training in radiation. Ensuring close ties with the radiological control organization has also been essential.
The need for a GPUN employee to perform this work is particularly i important for TMI Unit Two because of the increased amounts of radioactivity i and radiation and the unusual nature of the work compared to other licensed power reactors. The potential for radiation injur" claims is greater at Three Mile Island than elsewhere.
Salaries are high for occupational medicine physicians and they are
' hard to find. However, some of the also high costs of contract physicians
!!~ could be saved. OveraH, costs would probably not decrease, but they should i not increase much if one company physician were hired. There is a large 4 potential cost saving in radiation injury claims that is much greater than j the salary of such an employee.
it is possible to obtain most of the benefits of having a physician 1 employed by GPUN without having one for each nuclear plant. The physician 4
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could be located at Three Mile Island and spend about one day per week at Oyster Creek. -
_ RECOMMENDATION GPUN should consider employing a physician at Three Mile Island and assigning him medical radiological health responsibilities for TMI-1, TMI-2, and Oyster Creek. .
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CHAPTER VIH IlUMAN RESOURCES FINDINGS AND RECOMMENDATIONS t
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HUMAN RESOURCES Completing Personnel Actions FINDING VIH-1 '
action.
There is a need to reduce the time it takes to complete a personnel i i
, DISCUSSION For a number of reasons some personnel actions take too long to be completed. Without arguing the merits of any given case, examples of .
'{ { personnel actions inyolving hiring, termination, pay status, benefits, transfers',]
etc., were noted to take months to complete Reasons ranged from their- ,
being too many approvals / concurrences required, to too muel) paper work j required, to the need for " committee" action, to just having a paper sit on someone's desk for several weeks awaiting action. Not only does this create a bad impression of Human Resources, but, more importantly,3t has resulted -
in the feeling down within the organization, that top management is ;
insensitive to the gut issues that affect an individual's personal well-being.}
+
BETA was informed by a number of people that contributing to the inability to move quickly on personael matters is the existence of a number .
of high-level corporate committees, such as the Presidents' Committee and -
the Personnel Practices Committee, that seem to get involved in too many issues that should be handled routinely. If this is true, it is another example -
where decision-making within *. PUN has been elevated to the point that it takes Inordinate time to get a decision, and just as important, people at the lower levels automatically push the decision upward to avoid future
.I reversal.
1 t
RECOMMENDATION All levels of management need to understand better the need to take i quick action on any matter affecting personnel-either good or bad. Human I Resources needs to bring to the attention of management any instances where P.2re is a needless delay in taking a given personnel action. This means Human Resources needs to be able to keep track of the status of pending personnel actions.
Il0 MAN RESOURCES Position Titles vs Salary a
FINDING VIII-2 The number of GPUN personnel who have the title of " Manager" or above, is high in comparison to the total number of GPUN employeer.
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i DISCUSSION s .-
There are four levels of management who have titles of " Managers" -
or above. These positions include: l I 1. Director of -
- 2. Director
- 3. Manager of _
}{
r 4. Manager ,
Within the GPUN organization of 2589 employees, there are 244 who I are " Managers" or above. This does not include supervisors or foremen.
BETA considers this to be greater than necessary. It has been stated that h[
each of these positions was created based on a review of the function to be performed and the level of responsibility involved. Assuming this to be '
3 l
true, it would appear that the " Manager" criteria level may have been set i too low. It is also possible that GPUN has used grade level as a means to ?
obtain competitive salary levels for key personnel, and generally grade levels q ~ l;
- l are tied to positions. There is no question that GPUN must provide competitive salaries for its personnel. In the lower grades, this is relatively
[ easy. In the higher levels, position descriptions and titles must match the M grade level in order to justify salary levels. While there is nothing wrong with this arrangement in the basic structure of the organization, if it is used In excess it win result in there being too many managers. 4 -
,. v It is surmised that when the position descriptions were initially written .
and reviewed, there existed a lack of detailed knowledge of just what the .
job entailed. This is understandable because of the newness of the .
organization. Based on this limited knowledge, a grade level was established high enough to cover what was then considered to be the upper limits of l.
L the job. Since then, there has been sufficient time to better understand the job and to judge the performance of the individual filling the position. It 1 ; -
l is BETA's opinion that if those top positions were evaluated today, there
' would be less managers.
Another bad feature of grade level inflation is the perception of competition between Divisions. Division Directors, Managers, and the workers i[ d within the Division tended to use the number of " managers" within each f 1; Division as a measure of importance. Throughout the BETA interviews, it was evident that great imt.ortance was placed on how high a position was %
~_--
set, particularly when an I: sue had to be settled between Divisions. We ;i.
heard of cases where a " manager" would not return a phone call when that call was made by someone in another Division, but at a lower level. . f:
==
Also, as discussed elsewhere in this report, there is the creation of 2 3'
" cells". In a large measure, this is the result of having too many " managers". '
4 Once a person is hired into or elevatad to a " manager" position, he tends to want to prove that he really is e manager. Tasks that he would normally JE:
perform himself, become chores that are beneath the dignity of his position. -?
As a result, he surrounds himself with a staff. In some cases, noted within __
GPUN, these staffs or "ccils" developed through subterfuge. The " manager" ? 1-could not openly proclaim he needed a staff so he got an " engineer" or an 4
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" analyst". These people, in reality, were assigned administrative tasks, such as budgitting, personnel, etc.
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The following table shows the distribution of " managers" in September 1982.
NUMBERS OF MANAGERS AND DIRECTORS BY LOCATION DIVISION PARSIPPANY TMI O/C READING TOTALS -
OP 3 - - -
3 i O/C - -
20 -
20
( TMl-1 -
9 - -
9
!I TMI-2 21 - -
21 T/F 35 3 3 3 44 9 N/A 22 9 8 2 41 k ADM 40 8 7 -
55 COM 2 6 1 -
9
, RC&E 4 12 6 -
22 M&C 8 5 7 -
20 TOTALS 114 73 52 5 244 I i
( RECOMMENDATION i'
- An evaluation of the top managerial positions should be conducted to -'
determine if the work performed matches the grade levet ]
y- .
IlUMAN RESOURCES Labor Relations -
FINDING Vill-3
- Productivity at the nuclear plant sites is adversely affected by current i bargaining unit agreements.
DISCUSSION l
t The BETA review indicates that operation under the current bargaining unit agreements at both sites is adversely affecting productivity. This is
! not to say that it is the only contributor. However, there were ample examples of current practices that indicate a need for GPUN or GPU to. ..
review its agreements with the bargaining units. DETA did not make such a review for a number of reasons, one being that to do so, would have been too time-consuming since the subject matter is so vast and complex. BETA
}. is aware that this matter is under constant review by GPU management, not only for the nuclear plants but also for the other plants within the system.
BETA has included this item in its findings because it is having a marked impact on work efficiency. If there are truly situations, as were reported to BETA, where a workmen is at his worksite for only two hours ;
j out of an eight hour day, then there is a problem. if part of that probl6m is 1 a result of the bargaining unit agreement, then it should be resolved.
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4 RECOMMENDATION
]
In this case BETA can~ only recommend that appropriate but knowledgeable peonle within GPU (or GPUN) conduct their own review of the situation existing at TMl-1 and Oyster Creek to determine if, and to what extent, current union agreements are impacting work efficiency.
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i l( . 4 CHAPTER IX l
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e RADIOLOGICAL AND ENVIRONMENTAL CONTROIA
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FINDINGS AND RECOMMENDATIONS
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u CH APTER ~ 1X. RADIOLOGICAL AND ENVIRONMENTAL CONTROLS FINDINGS AND RECOMMENDATIONS . }
GENERAL l The present structure of the Radiological and Environmental Controls Division (R&EC) is considerably different from that existing. prior. to the ,
TMI-2 accident. BETA has been more closely involved with assisting GPUN 7
in developing R&EC than any other division. It has been in a position to -
- observe firsthand the many problems encountered in converting what existed -
) in 1979 into the present day organization that can adequately handle the i' radiological effort at TM1-1 and Oyster Creek.
In October 1979, when BETA arrived at TM1, radiological controls and chemistry for both units one and two were performed by the same technicians.
This combined group had two health physicists with degrees in senior positions.
Important early changes that were succesfully made were separation of the site chemistry function and removal of production functions, such as f radioactive waste and decontamination, from the site radiological controls i group. GPU took early action to separate TMI-1 from TM1-2 radiological controls except for a few common functions such as dosimatry. ,
At Oyster Creek the radiological control situation had many similarities i to TM1-1, except that chemistry was not combined with radiological controls. 'i
~~
Starting in 1980, Oyster Creek followed the changes that were being made at TML
~
The managers of radiological controls for each of the three plants were organized reporting directly to a new corporate director of radiological -
controls. More than a dozen manager level leaders were developed in the three radiological control organizations under the Director R&EC. Among other things this has allowed R&EC to gain better control of its contractors such that contractor radiological control personnel are difficult to distinguish from GPUN radiological ecntrol personnel at the plants. Changing the radiological control group from the plant organization to R&EC has
- l. contributed to improving radiological control performance, partly because
- l. the new organization provides better radiological control balance in operations and maintenance.
Radiological engineering groups have been developed withis R&EC at each plant. This is a departure from traditional practice in other utilities and it is working effectively. A radiological assessor at each site has also j been developed who operates independently from the site radiological control
- ceganizations. Standardization of radiological procedures at the three plants is being pushed.
Major early efforts were aimed at improving the training and l qualification of radiological control technicians, improving the radiological training of workers, cleaning up contaminated areas and reducing the numbers of such areas, and improving the control of radioactive contaminatilon.
One area not discussed in the earlier sections on radiological control effectiveness at TMI-1 and Oyster Creek is labor relations. It is BETA's 98
- -- == - = = . . - - = = -
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l opinion that the current methods and procedures .used with. the bargaining .
units interfere unduly.with the need to obtain high quality radiological control ,
performance. This report contains a separate iten. relating to labor relations; - !
however, it is mentioned here with specific reference to the inefficiencies and other problems it has created in performing radioactive work.
b I in summary, GPUN headquarters has set up strong central control of radiological programs with dJtailed technical knowledge of current. plant
( problems. This has been pe" formed with a minimum staff at headquarters -
- and without setting up a layer of management between the plant radiological control managers and the Director, R&EC. BETA considers that R&EC has i*
made considerable progress in creating . an effective radiological control I, program at TM1-1 and Oyster Creek. It is on the right track and merits the continued strong support it has received from corporate . management.
Specific comments relating to areas where effectiveness can be improved ;
f are provided in earlier sections in this report (Chapters 111 and IV).'
s I eeee R&EC RADIOLOGIC L ENGINEERING
{-
FINDING IX-A Little radiological engineering is performed at Parsippany. -
> DISCUSSION
~
'- Radiological engineering is needed in technical work for nuclear plants ~
to help ensure consideration of radiation and radioactivity in design and I,
planning. For work on radioactive systems and nearby nonradioactive systems, _
special attention is needed to radiation exposure of those who will perform the work and to control of radioactive airborne and surface contamination.
These considerations nearly always lead to differences in the design and planning from the way the same job would be handled in a nonnuclear situation. Sometimes the differences are major.
These radiological considerations do not require esoterie skills beyond the competence of normal mechanieci and electrical engineers. In fact, in a mature, well-trained nuclear power engineering organization, each engineer j would be his own radiological engineer. If radiological engineering is not i
done properly from the earliest stages of planning and design, then design work may have to be redone at increaseo sr.st. Or worse, for its impact on cost and time, design work may have to be redone at the plant.
Even in the ideal situation where each engineer does his own radiological engineering, e small radiological engineering group is needed to ensure
! ::tandardization, to develop new concepts for special jobs, to keep up with new developments elsewhere, to help train the nuclear power engineers, and l to ensure coordination with radiological control personnel. To summarize, in i a well-trained nuclear power engineering organization, a separate small
$ radiological engineering group will increase efficiency and productivity and reduce overall costs.
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. .-_ XL L _ - ___ _ _ _ - _ . - . .__ _ - _. ,
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f The existing situation in Parsippany is far from this ideal. The . bulk .
of the engineers are new to their jobs. - They have not had training in ;
radiological engineering. They are not familiar with the best ways to perform ~
radioactive work in an old nuclear plant. Their svoervisors similarly do not have enough experience to make up for the radiological shortcomings of
-l their engineers, in this* situation, a strong radiological engineering group in
- Parsippany is essential ,
in the Technical Functions Division there are no radiological engineers j] performing the functions discussed above. There is one engineer assigned ;
the title radiological engineer, but he does analytical work such as shielding ; -
calqulations and effluent release calculations.
In the Radiological and Environmental Controls Division at Parsippany j there is one radiological engineer, but he does not perform the functions I listed above. As a result, the radiological engineering group at the plant
[. is relied upon to provide the input that should be available at headquarters ,
- much earlier in the design phase. It is too late to add radiological J considerations after a design package has been delivered to the plant. .
I l RECOMMENDATION Develop a small radiological engineering group in Parsippany located .
In the Radiological and Environmental Controls Division to handle radiological J.
engineering for headquarters divisions. This group should not perform the 3 analytical work on radiation shielding and effluent release which is already, ';
properly located in the Technical Functions Division. ,
eeoe 1 .
R&EC ENVIRONMENTAL MONITORING i FINDING IX-B J GPUN is spending more than it should in dollars and manpcwer for environmental monitoring at TMI-1 and Oyster Creek.
DISCUSSION Environmental monitoring for TMI-1 and Oyster Cieek costs approximately $3 million each year, of which more than half is for
< contraetors. Public pressures have been forcing increases in environmental monitoring for nuclear plants. A major cause of such national interest has been concern for radioactivity. This is particularly applicable to TMI-1.
< Radiological environmental monitoring might therefore be expected to be a i large part of the :ost of the environmental monitoring program. In fact, however, other environmental monitoring has been increased so much that j! the costs for the extensive radiological environmental monitoring programs j at TMI-1 and Oyster' Creek are only a small fraction of the total costs.
RECO MMEN DATION BETA considers this an appropriate time to begin reducing unnecessary environmental monitoring. BETA does not recommend reducing radiological -
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l environmental' monitoring. The Director of Radiological and Environmental _
Controls should be asigned the- objective of making initial reductions in.
environmental monitoring early in 1983 and further reductions by 1984. ,
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CHAPTER X MAINTENANCE AND CONSTRUCTION f
FINDINGS AND RECOMMENDATIONS
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CHAPTER X. M AINTENANCE AND CONSTRUCTION ,
FINDINGS AND RECOMMENDATIONS .-
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- GENERAL
-' In the earliest concept of the GPU Nuclear Corporation, long before its official creation as a corporate entity, the Maintenance and Construction Division was included. .
Although the creative planning being done at that tim,e made clear the need for such a Division, the planning was reinforced by NRC orders, the ;-
Kemeny Report, and the President's response to the Kemeny Report, as indicated by the foHowing excerpts:
- NRC Order of August 9,1979, Docket No. 50-289 "6. The licensee shall demonstrate his . . . espability of important
! support organizations such as . . . Maintenenee,"
The Kemeny Report "A.5.(e) Responsibuity and accountability for safe power plant i operations . . . should be placed on the licensee in all circumstances .
. . . with particular attention to . . . Maintenanee." r i
The President's Response dated December Recommendations of the Kemeny Commission 7, 1979, to the {
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page 7 " Primary responsibility for safety must rest with the utility
- I companies that . . . maintain nuclear power plants." .
NRC Order CL1-80-5 dated March 6,1980 4
' ". . . the f.ieensing Board should examine . . . the adequacy of
! the faellity's maintenance program."
U On September 15, 1980, the GPUN Group was formed. The M&C Division was established and continues today in the GPUN Corporation.
i From that date to the present, the effort has persisted in readying the Division for the assumption of respensibility for all modification and
- corrective maintenance work at both sites. The transfer of the corrective maintenance function from the plant to M&C is currently in process at l Oyster Creek, having commenced in October 1982 and is planned for TMI-1
.. after the restart of that plant.
BETA has observed closely during the formation of M&C from the date
!, the Vice President-Director, M&C reported in June 1980 as the Vice President
. designate, and BETA agrees with the intent, method, and scope of the new l organization. It is anticipated that when the organization is fully in place and funetioning as planned that the material condition of the plants will be improved and that the performance of all maintenance and modification work l
will be better controlled as regards procedure compliance, schedule, and cost.
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As previously noted, the transfer of plant maintenance work to the .
Z M&C Division has commenced at Oyster Creek. In conjunction with the finding listed below, attention is directed to the finding contained in the _
Oyster Creek section of this report which discusses a number of problems observed in the maintenance area at Oyster Creek as this transition occurs.
Since, during the time of the BETA review, the main effort of the M&C Division has been one of getting itself in a position to assume its new l
role, there is little that can be commented on with respect to work ;
accomplishment. BETA did spend time reviewing the plans, goals and l procedures being devised for ~ operating the new divbion. Because of the 7-unique nature of the working relationships which need to be established and their departure from past practices, it is expected that a number of problems -
wiH develop. It is not BETA's purpose to list these problems because they will be resolved as the transfer proceeds. However, managers and directors in an affected divisions need to:
- 1. Understand that the decision to transfer plant maintenance to the M&C Division has been made-it is no longer a debate.
- 2. Put whatever disagreement they may have felt regarding this change in the past and they now need to support it.
- 3. Help resolve the issues arising as a result of divisional interface 1 uncertainties, j BETA is confident that these problems will be worked out and that $
this new concept of performing maintenance work at the plant wiH result in .
a better maintained plant and a greater efficiency in doing so. ,
^
eeee r M&C
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FINDl'iG X-A The Maintenance and Construction Division in its effort to become established is not capitalizing on the capabilities throughout the Corporation's functional organization.
DISCUSSION It is BETA's opinion that in establishing the functions, assignments and k responsibilities of the M&C Division, particularly in its early stages, there has resulted an overshift into M&C of a number of functions that should be retained by other divisions. It is understandable how this came about, namely the need to create a new effective system drives a new organization into assuming more of the roles. In theory, the M&C organization with an of its various functions looks good on paper. However, it is not likely to succeed unless reliance is placed on other divisions within the corporation to carry out their duties. M&C should not overdo the philosophy that a function wiH not be done properly unless it is done by M&C.
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There are a number of examples of this. Within the site M&C _
organization there h a group called Technical Suppwt. Care must be taken i that this group does not take over the function of Plant Engineering or -
Technical functions. . In addition, care needs to be taken that this group does not duplicate the work of others or does not become another approval point in series with getting the work done. This same situation is tending to exist in such areas as: contract administration, warehousing and welding engineering. There may be others.
RECOMMENDATION :
7-The Vice President, M&C should review his ordanizational plans and procedures to ensure that wherever a function already exists with GPUN, that function should be used to the fullest and not duplicated within M&C just because it is not supportive. If it is nonsupportive, action needs to be taken with the appropriate division director to correct the situation.
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CHAPTER XI T-i .
9 COMMUNICATIONS FINDINGS AND RECOMMENDATIONS
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r COMMUNICATIONS Staffing FINDING XI -
The number of people assigned to this function appears excesive.
DISCUSSION ,
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BETA fully understands and supports the need for GPUN to have an ;
effective Communications Division. The unique nature of circumstances i surrounding TMI dictate the need for GPUN to have a group dedicated to I , this purpose and also the need fw this group to be larger tha.1 in any other I nuclear utility. However, we do feel that having 36 people to perform these tasks is excessive. A few times throughout the period of the BETA review, j there were opportunities to observe the day-to-day functioning of this group t.
at TML Based on these isolated cases it is BETA's opinion that a number of the people are under-utilized, lack supervision and are sometimes This is performing questionable tasks.needtofor their have services people and when available the desire, the undoubtedly c
' need arises. BETA does feel that it is appropriate at this time to review the manning of this group to determine if all the people are really necessary.
RECOMMENDATION j r
- a. A review should be conducted of the anticipated work load of this y Division to determine if it is properly manned. .
- b. Consideration should be given to finding useful tasks in other I,
Divisions for people in this Division when they are not needed for -
y their primary jobs, s c. More effective supervision should be provided, particularly at TML I
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CHAPTER XH I GENERAL FINDINGS AND RECOMMENDATIONS r
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GENERAL -
Supervision FINDING X11-A Insufficient or poor supervision is contributing to poor productivity.
DISCUSSION j i
Probably the most effective measures GPUN can take to improve productivity throughout its organization is 16 iEiprove supervisiorm During ~
the time BETA conducted its review at the three~ sites,~Eumerods ofs'eryations were made where people _were not productivly employe_d. There are a number of reasons why situations such as this develop. In order for a worker to
- be productive he or she needs all the elements necessary to do the job.
The absence of any one of them will cause the work to stop. Many of these elements are discussed elsewhere in this report. The purpose of this item is to discuss supervision or the lack of it.
In its observations, BETA noted too many cases where poor productivity could be directly attributed to either insufficient or improper supervision. ;
j' Even though the more flagrant cases occurred at Oyster Creek, the same situations were noted at the other two locations. While BETA could provide h
a list of specific examples noted, it is felt that most of senior GPUN .-
management is already aware of similar examples from their own -
observations. What needs to be recognized is that this problem exists to -
varying degrees at all levels in all divisions and is not restricted to the man with a bag of tools. -
(' BETA recognize's that merely recommending an impro rement in
, supervision provides little if any help in solving the problem. .What follows is i a list of possible contributing causes as surmised by BETA along with some suggestions as to how they might be relieved. This list is not in any order of priority or importance. ,
- a. Greater than normal rates of increases in manpower such as have occurred at GPUN, generally result in a drop in the quality of supervision. This is brought about by several factors. People are promoted into supervisory roles at a faster rate than the organization can assimilate them. Also, managers will tend to hire new people more for their specific capability to do a given job and less for their supervisory capabilities, particularly when there is pressure on to build up an organization in a short period of time. Rapid hiring contributes to reduced supervisory capability in another way. New people are generally hired because the work I load has increased. As the new people are brought onboard there is a period of time when their ability to do the work is very low.
This means that the senior experienced people spend most of their time doing the work that they hired the new people to do, and the result is that no time is left for these senior experienced people to train the new hires, particularly in matters of supervision.
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- b. Looseness of supervision tends to become a way of life' and as
- time goes by, it becomes embedded and is very difficult to change.
Quality supervision tends to atrophy with time and needs to be-. _
constantly reinforced. BETA too often heard the expression, " things will never change, they have been that way too long".
- c. Too often people are made supervisors who, if the truth were
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., known, really do not want to be supervisors. Some people have v an inherent distaste for being a boss. Others have grown up in a ,
community of peers, having been close personal friends:with them t O for years and are unwilling to alienate those relationships even i though they may take the job when offered.
- d. ~ Senior managers tend to look no further than one level down in
'their own organization when it comes to supervisory attention.
- e. Senior managers, including Division Directors, are particularly reluctant to flag poor supervision on the spot, ,when it occurs in another Division.
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- f. Some senior people truly believe that all that is necessary to solve the problem of poor supervision is for the Training and Education Department to have an effective supervisor trair.ing course. If it ;
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(- 'isn't working it's because the training course was'no. good. This k l becomes.a convenient crutch because now all the managers need ;
L to do is make sure their people are scheduled to take the course. .-
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Incidentally, BETA strongly supports the need for having a well- -
L taught supervisor training course, as long as ~it does not become --
the sole means to an end. BETA also feels that the current tiend
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to . turn supervisor training courses intc psychological er.ercises is -
- c wrong.
- g. Too many senior managers want to create the impression that they
{ are " good guys", and that their people " love" them. pey have not learned that there is a difference between being 'tcugh and s
being mean. People will respcet a person who is tough, but fair, f and one who knows his busines.
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- h. Supervisors and managers have a better chance of success when their personal appearance reflects their elevated positions. This applies to dress, grooming, demeanor and any other attribute that tends to create an image. In the same light, what a person does outside of working hours should generally be of no emeern to the company unless that behavior becomes grossly offen:4ve and ends up hampering his ability to supervise.
- i. Obtaining effective supervision starts at the top. If top management does not set the tone and constantly reinforce it, it will slacken as it moves down into the organization.
' ' j. Some senior people assume that when a person is promoted to a higher position, he or she automaticaHy becomes qualified, in a
! managerial sense, to perform in that position. This is rarely true.
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- k. Poor supervision will result in a company where the failure to -
meet schedules or commitments has become a normal everyday -
routinc. Employees soon develop an attitude that, "if they (the
- bosses) don't care if it gets done on time, why should I?" In a
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larger but different sense, the constant Inability to get TMI-1 restarted contributes to this.
L There is a reluctance for GPUN managers / supervisors to flag poor
. supervision on the part of contractors. There is the perception that for contractural reasons, GPUN people are not permitted to '.
move into' this area. i
- m. There is the erroneous perception (more an excuse) that union agreements have tied the hands of the supervisors.
- n. Supervisors do not spend enough time at the work sites. This could be for a number of reasons: they have too much desk work; they attend too many meetings; they are running around chasing problems holding up their work; they just don't want to.
- o. Supervisors are not sensitive to, and are not reacting to, poor working conditions at the work sites, such as, too many jobs going on in the same area, cleanliness, etc. ;
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- p. Supervisors too often rely on outsiders (QC, Radeon, etc.) to ensure !
quality of the work rather than themselves. ;
- q. Supervisors, on occasion, blame others for inability to get the work .'
done but seldom do no more to correct the situation than complain
[- to their own workers. -
RECOMMENDAT*ON;( .ot in order of importance or priority)
- a. Most of the causes given above relate to a lack of proper training of supervisory personnel and to a lack of awareness on the part ,
of senior manag:rs that the supervisors are not proper 1v trained.
The tirst step m improving this situation must start in the Office of the President. That office must set the toneGfdfoy oreacntnap but by visible signs that they are concerned, including calling to the attention of individual division directors, noted examples of poor superyision.
- b. A review should be made of the current supervisor training course S to ensure it is providing the material and is being taught by people who are qualified to teach it. Evaluation of the effectiveness of these courses should not be performed by the Tmining Department.
' c. Management should recognize that 90% of effective supervision training is on-the-job. This means that managers, etc., must constantly be in the process of teaching their people how to supervise and correcting their mistakes. This assumes that management is capable.
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- d. Directors (all divisions) need to tour their work areas at irregular I and unannounced times with the express purpose of seeing that their people are gainfully employed, and if they aren't, why. When _
cases of inactivity or laxness are noted, these directors need to raise the issue .with the appropriate managers. .
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Senior managers need to improve their use of GPUN performance i
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evaluation' system's provisions relating to supervisory performance.
At the present time this tends to be perfunctory because of a lack of realistic knowledge of the person's performance in this area. j
. The rapid rate of hiring has subsided and there should be evidence
- of better supervisory performance. As the new people learn their jobs better, managers should be encouraged to devote more of
' their time to teaching their people. This will not happen naturally.
It is harder to deal with people problems than it is to deal with paper problems.
i g. Known cases where people have been put in supervisory roles who I
find that role repugnant need to be flagged and worked on. If that feeling persists, then the person should be moved into a non-supervisory position.
Senior management needs to be conditioned to react to poor i b h.-
supervision whenever it is observed, be it outside their division or 3 within contractor organizations. [_
- 1. It migtit be beneficial to review the provisions contained in .
7
' contracts GPUN has with its major contractors to see what means exist for GPUN to monitor, report, and take action in cases of .
p poor or insufficient supervision. ,
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BETA does not subscribe to instituting a formal productivity q monitoring system or a work / product sampling system. It is our f, feeling that such systems do more harm than good. Efforts spent in making supervisors more effective pay higher dividends. .
However, there may be some benefit to using data which 13 collected for other reasons to get some gross indications of productivity trends. For example, returned costs on jobs of a repetitive nature can be trended. Total calendar time between start and complate dates on repetitive jobs can be compared.
' Total man-tem exposure on similar jobs can be compared. Records of QC rejections or rework can be trended. Supervisor man-rem il I exposure in contrast to his work force can be compared. All of these can provide some small measure or indication of problem l
areas.
- k. In the case of personal appearance, demeanor, etc., no rules or f -
written procedures are neceasary or desired. They can't be written.
l What is needed is an awareness of higher management to cases i that clearly fall outside the norm, followed up with corrective action.
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- 1. At the plant sites, hard hats should be ' distinctively color-coded -
so that there is a visible means of identifying workers, I supervisors / foremen, and officers (managers and above). Major _
contractors should be required to follow this practice.
GENERAL Paperwork FINDING X11-B Tnere is too much paper being generated and distributed throughout i the GPUN organization.
DISCUSSION One area which would appear to provide room for improvement and would make more efficient use of manpower is tighter control of paper - all
' forms of paper. Not only is this a constant source of complaint, but our y observations indicate that it is real. The following areas need correction:
a.- Distrbution - Documents prepared within GPUN, as well as those received from the outside, carry distributions throughout the GPUN system which are much more extensive than necessary. The intent t
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, is understandable, but the result is that too many people receive I documents which they have ilttle or no interest in, but because ?
they receive them, they feel obligated to read them. We 'saw '
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numerous examples of this. -
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- b. Signature / Addressee - There are instances where people within _
) GPUN sign internal memorandums to people outside their Division -
i who are senior to them. If these memorandums were strictly the pasing along of information, it might not be too bad, but that is not the case. In one case, a person two levels down in the organization directed 8 Vice Presidents to do something. In a similar vein, apparently anyone in GPUN can sign out a memorandum or letter. This is dangerous and can lead to problems.
Some form of control should be exercised over who can sign i
correspondence to whom. This is already done in 'the case of expenditure approval authority.
- c. Correspondence Control- With the exception of Licensing and the NRC, it would appear that some better form or system of correspondence control is needed. There exists a rather massive
( computer system for keeping track of " key" documents, but as fa:-
as we can see, it does not control the correspondence, i.e., due dates for responses, etc. Each division and section has their own,
- which may be all right, but that will not keep management up-to-date on how well commitments are being met.
- d. Over-Abundance of Procedures - With the creation of the GPUN functional organization, each division obviously felt the need to formalize their way of doing business. Therefore, each division d
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' initiated the task of preparing procedures on just how their work -
would be done, noE only within their own division, but in all other l divisions. These draft procedures were, and are, routed around _
for comment.- However, because- of the large number of new procedures and the fact that each division was producing their.
own, less time than desired was put into the review of others.
The result is that many of the procedures are not compatible from one division to another, and what is worse - there are just too
- many of them. It is literally impcasible for any one person to even begin to absorb what is in those documents. There are raore :
than 2000 procedures just for TM1-1 alone. We do not fault any 7' of these 2000 procedures because they cover the areas needed to operate and maintain the plan However, if some brake is not applied, each division will have 2000, and GPUN will be faced with trying to get over 15,000. procedures updated, reviewed and fonowed. Writing a procedure seems to be the easy way to solve-a problem. Then once a procedure is ; written, supposedly the .
problem is solved and the burden shifts to the person at the bottom
, -who is supposed to foHow it.
I e. Concurrences - Too many people are being required to concur in documents (procedures). This, in combination with the previous comment on the large number of procedures,' places an impossble burden on the system. What can happen is that people are forced j to concur in docuinents they do not read or do not read thoroughly e unless they have some personal and direct interest. Obviously, 1 each document needs to have some number'of concurrences, but i as it is now, that number is far too large. It is up to division .
directors and their immediate subordinates to slow this down.
RECOMMEN D ATION
- a. Distrbution Each division director should take on the issue as a particular case arises. If he is sensitive to the problem and reacts with his own people to hold down the distribution, some headway can be made. It will do no good to' Issue a . procedure or directive on a matter such as this.
- b. Signature / Addressee Apparently action has already been taken to tighten up signature authority in certain areas. This area should continue to be watched and division directors should react to cases of noncompliance.
- c. Correspondence Control A simple system of controlling correspondence should be
' instituted, at least to the point where the directors have some idea of how well their own people are meeting commitments.
BETA is not proposing the creation of another new massive control system.
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- d. ' Over-Abundance of Procedures ;
The proper operation of a nuclear plant requires the existence of procedures. Each division needs procedures to set forth its methods of operatirsn. The question here is how much is P enough?' There, obvir.usly, is no absohnte answer to this l question; however, each division director should realistically make a ju% ment as to the necessity for creating a new procedure, taking into account not only what is gained, but '
what problems are created. 1hb is particularhr important in .
nuclear plants where verbatim compliance is becoming more 7-and more the rule. Discounting plant operating procedures, which are not meant to be included in the ' thrust of this
- comment, all procedures need to be judged on the basis of necesity,-keeping in mind the need to keep things as simple r . as posible.
- e. Concurrences l The action taken by the Office of the President to resolve I this imue is having effect and should be continued, eeee GENERAL Decision-Making Proces ,1 FINDING XIl-C .
There is an overall tendency within GPUN to force decision-making up _
too high in the organization.
DISCUSSION Throughout the course of the review, BETA repeatedly heard the complaint that too many deelsions are made at too high a level. This
- perception was noted across the board, in all divisions and at all locations.
1 It was felt by those interviewed that this phenomenon originated at the level of the Office of the President and then worked itself down the organization.
In this regard it was interesting to note that division directors would make this observation about the Office of the President.while at the same time, senior people within those divisions would offer the .4me comment about their director, and so forth down the line. In some cases this escalation was blamed on administrative corporate policy procedure * (example, limit of signature authority).
Concurrent with the feeling that decision-making is forced upwards, is l
i the perception 1 that decisions made at the top are too often made by consensus. There is be a natural tendency towards this approach in a functional organization. -However, it was noted that too many decisions are put before all of the division directors for their concurrence even though many of them will have no direct involvement. There are certain decisions made by the Office of the President that are either controversial or 112
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distasteful that need to be made with consultation, but not necessarily with '-
consensus. _
' Having decisions made at higher than normal levels can be expected in newly-formed organizations and ones having large numbers of new people in managerial positions. These people are inexperienced, and in many cases,
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have yet to understand the intricacies of their jobs, where top management is headed and their roles in relation to other managers. As time goes on,
, this situation should change and higher levels of management should have ,
developed a greater sense of confidence in these people, allowing decisions to drop back down to a reasonable level in the organization. BETA feels i this has happened to some extent but not to the point where it should be.
One result of decisions being forced too high, and it is a major element of this review, is that it takes an inordinate amoud of time (and money) to
' get anything done. We attempted to track a number of cases to illustrate
> the poiny and while each case had its unique aspects, the overall pattern was the same. First, a potential problem or need was identified. This was
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foHowed by a rather lengthy, involved process to decide if there really was j~ a problem or need. Depending on the issue, this process worked itself
+ through a number of the divisions, taking weeks to resolve. The same process was then followed on arriving at a solution. By the time the decision was carried out (the work done), several months had elapsed and, in some ;
cases, the fix was changed several times. BETA fully recognizes that the 4
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very nature of the nuclear business requires careful ;nd detailed analysis of 3
- problems and their solutions. It would be foolhardy and dangerous to make .-
snap decisions involving the technical aspects of the plant. Our concern is -
the feeling that too many problems are floated to the top and that all issues -
are treated as if they were of equal importance. There will always be some
' fine thread which can be used to justify the need to elevate the importance :
of an action. Management must be in a position to use its judgment.
Another result of this situation is the feeling at the lower levels that by sharing the responsibility for decision-making among many, somehow no j
one person has to take the full brunt of the blame if things go wrong, and since they share the responsibility, they are not expected to be fully cognizant of the entire job. Besides there being each division with its own ad hoe internal review groups, there are innumerable established committees, that come into play depending on the matter involved. In some cases, this. is necessary and required. However, to the extent possible, decisions should be made by the person responsible, placing on him the burden to satisfy the others within the functional organization. Conflicts between divisions obviously need to be settled by the Office of the President.
- The problem descrbed herein should not be interpreted to apply solely to the Office of the President. It manifests itself throughout the entire organization at all levels.
RECOMMENDATION All levels of management should make a concerted effort to review the decision-making process within their groups with the purpose of having decisions made at the proper level commensurate with the need. This sNuld not result in a written procedure. It should come about as a result of action ,
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taken by the' Office of the President and the division directors on a case-by-case basis. ]
eeee I GENERAL l Handling Poor Performers FINDING X11-D .
There appears to be a reluctance within the GPUN system to take }
- action either to improve the performance of'pbbr performers or to terminate their employment.
, DISCUSSION I'
A fairly large number of GPUN people interviewed commented that action is not taken to correct, transfer or discharge known poor performers.
We asked a number of managers if they had working for them people who l were not contr'buting to the job as expected, and if they would be better ,
I off without them. In almost all cases, we were told that they did have at least one out of ten who fell in that category. In some cases, the number was as high as three out of ten. When asked why they had not done anything ;
'about.this, the answer was usually that it was too hard (impossible) to fire anyone. Further questioning also revealed that the Manager had done little $
on his own to correct the poor performer. -
- There. are a number of issues involved here. First, there is an -
administrative procedure in existence which covers the termination of a GPUN employee for poorperformance. It is not clear that people are willing :
to follow it. This might be a problem relating to the manager involved, or with the GPUN procedure. Secondly, the fact that managers are not actively
, attempting to irrprove the performance of their people is a problem. Finally, there is a proSem if individual managers are not doing anything to thin their own ranks of marginal performers. If every manager felt he could accomplish the same amount of work with 10 percent less people, then a large part of the cost problem would go away. Incidentally, in a number of cases, these same managers were asking for ir: creases in their manpower for 1983.
Telling an employee that his performance is poor is usually a distasteful job and one which " managers" will avoid. But that is a necessary burden of supervision.
3 L RECOMMENDATION
- a. A review should be made of the GPUN procedure, which tells
] people what to do with poor performers, to find out if it is too
- cumbersome, causing people to shy away from it. -
j b. Division directors should review the issue of poor performance with 1 their managers to ensure that:
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I (1) Action is taken to correct the performance of their people +
when called for.
(2) When this has been done to a reasonable extent, and the employee's performance still has not been satisfactory, then steps are taken to discharge the employee.
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GENERAL j
Staffs i FINDING X11-E 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 funettoning groups.
DISCUSSION Throughout the course of the BETA review, situations were noted where small groups or staffs had been created throughout all levels of the organization and in all divisions. These small staffs have grown in size and ;
number. In some cases a " manager" will create such a staff in order to -
i enhance his image or maybe to solve an immediate (but temporary) problem. j The issue is not that the function need not be performed, it is that a Ettff ,-
has been created to do it. ,
RECOMMENDATION -
Each division director should review his manpower staffing so that he knows what each person and group is doing. Every effort should be made g to reduce the number of staffs tha.t have been created down within the >
organization.
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CHAPTER XIH COMPARATIVE ANALYSIS RESULTS f'
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CilAPTER XIll. COMPARA'IiVE ANALYSIS RESULTS ,
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SUMMARY
The results of the BETA analysis of the manpower and cost data obtained from a number of other utilities indicate that the data provides some useful information but only very limited conclusions. It raises more questions than it answers. It was worthwhile for GPUN to have made the
- effort to obtain the data and it would be of some benefit to keep the data .
current in an attempt to make it more meaningful. j-The data suffers from inaccuracies for a number of reasons explained later in this chapter. Nevertheless, it does highlight areas which GPUN
- should take a second look at. It shows, in an overall sense, that both Oyster
- Creek and TMI-1 have more people than any other plant. It shows that both
~
of these plants have exhibited higher costs since at least 1975, and that the higher costs evidenced since GPUN was created is not a new phenomenon.
i It has provided BETA with at least a benchmark or point of departure in
> - - arriving at recommended manning levels for Oyster Creek and TM1-1. It 3
/ reflects a growing trend at all nuclear plants over the past several years not only as a result of inflation but of an increasing demand by regulatory bodies, the public, etc., to have the utilities cover more things in more
~
detail and with more people. It shows the need for GPUN to take a 'look * ,
at itself, as it is doing, and to attempt to settle down and make the present organization more stable and effective.
~
lt would be a mistake to try to use the comparative data in isolation
,- to prove or disprove the validity of any one category. The data is not that
'_ accurate. It would also be a mistake to discount totally the data and say .
It does not mean a thing. The data has a message, but judgment is needed
- to use it properly.
. B. OBJEC'11VE T The comparative analysis effort was aimed at attempting to uncover
), areas of costs and manpower within GPUN wh!ch were noticeably out of '
p line with other plants of similar design and age. At first thought, one would-3 think that such data would already be in existence, or, if not, would be relatively simple to obtain. Unfortunately, neither of these situations exists.
For example, each privately owned utility is required by law to submit a detailed financial and manpower report annually to the U. S. Federal Energy J Regulatory Commission (FERC) now part of the Department of Energy. In the early stages of its review, BETA reviewad these annual FERC reports from some 50 nuclear utilities. Based on this review, it was concluded that, 1- for one reason or another, no meaningful information could be derived from them. It was clear that each utility interpreted the form differently and f
to suit its own Individual needs. This was true in both manpower and cost +
figures, it was also noted that several other organizations had attempted to collect data from the nuclear utilities along these same lines (eel and INPO).
BETA reviewed these results and again, concluded that the data could not be used for this purpose.
t t
116
Finally, it was agreed that through the efforts of CPUN, a number of nuclear utilities would be contacted and asked to cooperate in amassing data. This was done and it is this data that is being reported on.
The requested data fen into two main categories; manpower and costs.
An effort was made to attempt to define the breakdown in each of these categories in such a way that there would be no confusion as to what was meant. Even dolag this and with GPUN people personally visiting many of -
the sites, BETA concludes it is doubtful that the results can be used for i much more than just gross indicators, ._.
In an overall sense, it is BETA's opinion, after reviewing the data that has been collected, that it suffers many of the problems evidenced in the FERC reports and other surveys. The GPUN manpower data is accurate because there was no question as to the meaning or interpretation of the categories. The GPUN cost data is as accurate as the data which exists in the company records, which does not mean it is 100% accurate insofar as allocation is concerned. Data from the other utilities varies in accuracy-downward from there.
Knowing that this was the situation, BETA attempted to cull from this data an/ area where the evidence clearly points to a problem within GPUN. ,
This was the objective.
C. METHOD OF APPROACH The survey involved 9 nuclear utilities owning 12 operating BWR plants and 7 utilities owning 10 operating PWR plants. Totally this involved 14 different utilities, and 15 different sites. Due to prearrangements with the participating utilities, the identification of the utilities and the plants was to be withheld.
Each utility was provided with an explanation of what was needed and a questionr. aire to be filled in. For each, someone from GPUN (or another utility) visited the utility site in ader to help ensure accurate data.
In the manpower area there was the desire to know:
- 1. the job being performed (title) (104)*
~
- 2. the profession (engineer, tech, etc.) ( 19)
[ 3. the job location (onsite/offsite) ( 2)
- 4. the employer (system / contractor) ( 2) 4
- categories AB of this data was then entered into a computer so that any given area could be analyzed from a number of different perspectives, it was this data that BETA analyzed.
)
117
3 D. MANPOWER ANALYSIS RESULTS _
As previously indicated, the manpower data suffers from a number of faults which make its value as a mear.s to compare different utilities very limited. Some of the more significant inaccuracies arise for the following
.- reasons: g l A
- 1. Because of the wide variations reported in any given category, "
]
either the various utilities misunderstood the definitions or they categorized their positions differently. This problem can only be ;
resolved by GPUN people spending much more time at each site, I' interviewing a large number of managers, and compiling their own set of data based on firsthand knowledge. It is doubtful that the various utilities would ever agree to undertake such an effort.
=
- 2. Recognizing that there is little to be gained from comparing each 3 individualline item, the tendency is to combine a number of them a
- =
Into larger groups with the hope that the larger groupings will cancel out the variations. This proved to be of some benefit but 3 r
still suffered from one significant problem--contractors. All 2 l utilities use contractors for some purposes. As in the case of 2 GPUN, there are three ways to use contracted help. One is to put I a contractor into a position normally occupied by a utility employee y because either a person cannot be found to fill the job or because . .
it requires special talents needed for a short period of time. 4 Another way to use contractor help is to farm out specific work i tasks to an architect / engineering firm. Normally the work is ]
performed at the contractor's home office. The third use of
- 5 contractors is for major jobs, usually construction or modification M work which is done at the site during an outage. There are 3 numerous variations on each of these three forms of contractor. ;;:
effort, such as guard forcer, vehicle maintenance, etc. The problem with the manpower data is that each utility counts its contractors I, differently, some not counting them at all, others only counting certain categories of them. Since the number of contractors can have a significant effect on levels of manpower, not knowing how q; each utility counted them, makes even the combined numbers l suspec t.
1
- 3. Another problem encountered in attempting to understand t! e ;
manning data relates to the use of resources belonging to the corporate utility but not coming under the nuclear structure. A good example is the use of a corporate mobile maintenance group.
Q This is a group of maintenance people who are used as the need g arises at all of a utility's plants, nuclear and otherwise. From a E manpower standpoint, they are not counted against any one plant 3 and usually no effort is made to allocate their services. The same ;
. situation exists with some engineering groups. If these numbers 3 are not included in the comparative data, then the data has a a
=
major flaw.
8
- 4. Still another uncertainty arises when consideration is given to &
whether the numbers reported reflect actual onboard numbers or intended levels. While the instructions were clear that each utility i 3
9 118 _
=
was to report approved levels (not onboard), a review of the data ,
'.' - Indicates this instruction was not always followed, primarily because a number of the utilities do not have such a system. They carry so many on the roHs, and if the need arises they get approval on-f'i the-spot to hire additional people. What this means is that in some cases a utility knows it is going to increase its staff within the year in a given area, but this isn't reported because the process
- hasn't reached the point where they can report the increase. BETA *
.- is aware of a significant number of situations where this condition '
exists. __
0 5. Once an these uncertainties are understood,11ere is little hope -
b that any detailed analysis of the manning figures win yield a meaningful conclusion. As previously noted, it is possible to resolve b these uncertainties to a large measure, but it wouki require sending I several GPUN people to each utility for extended periods of time..
BETA is not convinced the results would be worth the effort.
!/l Thus, except for providing some insight into specific cases where GPUN manpower aHocations might be high, the breakdown by individual job
! asignments provides only a vague insight to the overall situation. BETA has used as much of this information as it deems appropriate in arriving at .
the recommendations contained in this report. -
- The foHowing three -tables summarize the total number of people asigned to a plant on the basis of onsite, offsite and totals for both system
, people and system plus contractor people, onsite aru! offsite.
.c t
\ -
9 119 - _ _ - - -
TABLE 1 A tabulation of the total average number of onsite people per plant is listed below .
i Utility Utility &
Plant Only Contractors
.. 1 184 244 2 194 247 ;
3 , 199 257 '
4 211 308 5 280 355 6 280 355 7 303 479 l 8 344 458 9 . 36S 370 I. 448 10 410 l 11 453 526 l 12 462 478 -
t 13 463 718 14 464 545 15 745 779.5 (TMI-1) 1!, 813 877 (Oyster Creek) , 1 Average 386 462 e
e o
e
.e a L
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i e
120
--- ~. ... . _ . ._. _ , _ _ _
TABLE 2 A similar listing of offsite personnel average on a per plant basis shows the following:
Utility Utility &
Plant Only Contractors 1 27.5 50 2 49 161 3 62.3 108.3 i 4 72.8 75.2 5 75.7 75.7 6 90.8 91.2 7 106.9 122.9 8 128.4 157.2 9 130 130 6 10 152 152 11 176.7 182.5 i- 12 176.7 182.5 13 182 219 14 193.7 193.7
. 15 186 198. (TMl-1) 16 . 244.5 256.5 (0/C) ,
Average 128 147
- NOTE: Plant designation numbers on Tables 1, 2, and 3 do not necessarily indicate the same utility / plant.
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'121
. . . ~ . . - . - ~ . .. . .. -..- - .
TABLE 3 A tabulation of the total average number of people per plant, both
- , offsite and onsite indicate the following
, Utility Utility &
Plant Only Contractors
,, 1 256.8 319.2
~
2 284.8 338.2 -
3 306 380 8'
~
I I 4 286.7 384.2
- 5 393 420 6 456.9 527.7 7 456.9 527.7 8 472.8 555.8 9 592 608 10 431.4 636.2 11 526 677 12 616.7 697 13 646.7 719.7 14 512 879
. 15 931 977.5 (TMI-1)
_16 1057.5 1133.5 (Oyster Creek) ,
Average 514 611 f
4 sk 5
d D
1 122
.- . . . _ - _ = _ _ . _ .- . - .
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These listings would lead one to conclude that both Oyster Creek and TM1-1 are heavily manned but, for reasons already advanced, care must be taken in giving too much credence to them in isolation from other considerations.
> The tables which follow are summaries prepared by GPUN based on a survey of the manpower nu.1bers provi? 3 by the various cooperating utilities.
These tables reflect manpower allocation by division using GPUN organizational structure. They do not differentiate between onsite and offsite ,
but do show totals. ;
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3 em E. COST ANALYSIS RESULTS The tables and charts included at the end of this section were prepared and furnished by GPUN, and reflect the summation of data collected from i the various utilities. The validity of the data suffers from many of the _
' same problems identified with the manpower data, particularly with respect -
to capital expenditures and the individual utility's breakdown between capital and O&M expenses. Because of the questionable accuracy of the cost data, -
BETA concludes that any comparative analysis would be of limited valus.
However, from this data a number of conclusions can be reached. [
- 1. The degree of imbalance between GPUN and the other utilities is
~
less pronounced in terms of cost than in terms of manpower. For 2
example, in the case where GPUN shows a manpower ratio between themselves and the lowest reporting of 3.54, the cost ratio between a these same plants is only 2.1 (1981 figures). This could be because ;
there is a tendency for the cost data to be more accurate than the manning data. Also, the cost data reflea.ts historical 2 information whereas manpower data is probably a mixture of -
historical and projected information. Probably the most significant rationalization for this difference is that manning figures do not :
include contractors to the same extent as the cost figures do. .
Where a utility goes out and hires an engineering firm to perform .
a task under a capital project, the people used at 7 not reported i l in the manpower data. Since each utility uses various amounts of 3 contracted work, the reported manpower figures could easily be l.
off by a significant factor. -
- 2. Nuclear fuel costs are not included within the total cost data. If i all utilities used the same criteria for arriving at fuel costs then !
the absence of this number would not affect the overall meaning '
of the cost data. However, based on BETA's knowledge, what a given utility allows to be put in that cost center varies considerably. 2 Even in the case of GPUN some costs associated with nuclear fuel j t management are not chargeable to GPUN. A review of the annual ;
FERC .@ orts on nuclear fuel charges shows ' extremely wide _
variatior.s from utility to ' utility.
- 3. Discounting the absolute numbers, it can be seen that there is a s substantial step increase in expendituMs in all plants in the years following the accident at TMI. (See charts at the end of this :
sec tion). It is suspected that 1982 cost data will show all the ;
plants tending to reach about the same levels, as these plants, i which were lagging in accomplishirg the TM1 lessons learned ;
modifications, start to catch up. .
- 4. An analysis of the cost of capital projects provides no useful means
! of comparison. BETA had anticipated that looking at the return ;
costs to do a similar modification at several different plants might ,
provide an insight to efficiency. Due to a number of reasons this did not prove to be the case.
In summary, it would appear that gross cost comparative data tends to be more meaningful than manning data. Recognizing there are inaccuracles .
136 ,
- . . - - - . . .- ... . _ . ~ ..
- : 2-.. . - . . . . - . . .. . . . . . .
in the cost data, it is still possible to watch the trends. For this reason it is recommended that GPUN continue to obtain cost data from the other utilities to see if the other plants do, in fact, start to come closer together.
Although doing this might prove to be interesting, it will not point to any specific area within GPUN as being out of line.
I e
E 6
e P e lp h
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137
^ ~
_ .- _ -_ ~ -
INDUSTRY SURVEY COST COMPARISON BWR PLANTS HISIDRICAL CDSTS - PER UNIT BASIS
( SIN MILL IONS )
PLANT P! ANT PLANT PLANT PLANT PLANT FIbNT A B C D E F G 1976: 0&M 10.4 14.0 8.1 6.6 5.3 14.0 16.6 Capital 25.0 10.7 1.8* 1.3* 4.1 10.0 2.5*
helear C&A - - - - - 4.0 -
4 35.4 $24.7 69.9 $7 $ 9.4 $28.0 $19.1 Capacity Tactor 67.6 65.6 55.6 83.3 76.8 42.0 42.0 ;.
1977: .C&M 14.8 12.6 8.4 11.1 9.7 21.8 15.3 Capita l 24.0 12.7 5 . 2* 1.1* 9.6 9.1 10.6*
Nuclear G&A - - .7 - - 2.7 -
$ 3 8.8 $2 5.3 $14.3 $12.2 $19.3 $3 3.6 $25.9 Capacity Tactor 57.0 83.4 57.1 74.8 55.1 47.2 46.2 1978: 0&M 15.9 17.9 11.1 9.1 6.4 19.7 14.2 Capital 28.2 10.0- 3.9* 7.1 9.1 8.1 10.2*
mclear C&A - - 1.4 - - 2.1 -
- , i 44. t" 127.9 $16.4 $16.2 $15.5 $29.9 $24.4
- j, capacity Tactor 64.0 80.5 66.2 80.8 82.3 73.3 75.3 '
1979: O&M ,
13.0 24.6 15 . 6 10.6 11.7 20.0 18.4 ,
Capital 17.3 17.5 8 . 2* 4.7 21.9 10.8 6.4*
Nuclear C&A - - 2.2 - -
1.8 -
$ 30.3 E 2.1 326.0 $15.3 $33.6 $32.6 524.8
_ Capacity Factor 80.1 73.0 63.4 92.2 55.3 78.6 84.4 s
?
1980: OEM 37.5 27.6 19.3 18.4 9.4 28.4 27.8 Capital 29.2 22.6 16.5* 8.9 35.4 24.3 38.1*
Nelear C&A - -
4.0 - -
1.9 -
De ferrals - 4.0 - - - - -
$ 6 6.7 $54.2 $39.8 $2 7.3 $44.5 $54.6 $6 5.9 Capacity Tactor 34.4 58.6 51.0 72.3 83.6 62.0 53.1 1%
1981: OEM $ 4 5.2 33.5 18 .6 21.3 26.7 32.7 35.0 4
Cap ital 56.8 85.3 24.7* 31.3 57.5 24.9 44.1*
\ Nelear C&A - - 4 .4 - - 1.6 -
De ferrals - 11.0 - - - - -
j $ 10 2.0 $118.8 E 7.7 $52.6 $84.2 $5 9.2 $79.1
. Capacity Factor 46.2 43.6 68.7 68.2' 60.2 52.3 60.0
)
Plant Vintage 710 Yrs r10 Yrs >10 Yrs PLO Yrs >10 Yr s 5-10 Yrs 5-10 Yrs
- Capital expenditures were not available. One half of prior year and one half of current year capital additions to plant-in-sarvice were used as a substitute.
138
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l! BWR Historical Cost Comparison 19.76-1981-U 125 -
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. PLANT PuMT - FLANT PLANT PLANT FLANT J K L M N O 1976: O&M 17.8 10.9 9.1 5.6 - 5.3 capital 4.5 10.7 1.9* 1.9 - 2.0 melear C&A - - - .6 - 3.1
- $22.3 $21.6 $11.0 $ 8.1 $10.4 s capacity Factor 60.3 62.5 84.9 55.6 . N/A 85.4 {
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- melear C&A - - -
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. s27.0 $33.T $16.2 116.1 $20.1 $U T ,
i capacity Factor 79.1 61.9 66.9 68.2 35.9 76.2 1979: O&M 16.3 24.1 18.2 13.4 24.0 10.0 capital 6.8 7.9 2.9 7.4 4.1 8.5 Nuclear C&A -
_- - 2.9 -
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$2 3.1 $32.0 $21.1, $23.7 $2 8.1 $25.3 Capacity Tactor 11.8 58.6 65.4 61.0 52.1 62.8 1980 : ' O&M 40.7 28.6 .20.8 17.3 39.8 14.0 capital 16.1 25.8 15.3 11.7 1.9 7.8 Welear C&A - - -
3.3 -
8.7 De f errals - - 2.5 - - 3.0
$56.8 $54A $3 8.6 $3 2.3 $41.7 $33.5 Capacity Factor N/A 64.1 .80.8 62.7 46.4 60.9 1981: OEM 54.0 25.4 25.1 19.6 47.0 20.6 Ca pital 32.7 '4.3
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I Capital expenditures were not available. One half of prior yesr and one half l of current year capital additions to plant-in-service were used as a substitute.
I N/A = Not Applicable l
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P.O. Box 480
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Middletown, Pennsylvan,a i 17057
.- 717-944-7621 Writer's Direct Dial Number-.
.V..
. L. -
,s3 _ y, , --9 l;
tv h ; . ' ,g. ' Tehruary 26 . 1982 -
,.sy,e'y*
4400-82-L-0031 -
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office of Nuclear Reactor Regulati F
,7 QMC &- o ,
Attna Mr. Barold R. Denton.iVirector i. "
s.f*/
W I ##0 f# C-U. S. Nuclear Regulatory Com=ission % "",' "
Washington, D.C. 20555
. ff .
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI. 2)
Operating License No. DPR-73 Docket No. 50-320 -
Request to vacate May 22, 1979 Record Retention Order On May 22, 1979, the Nuclear _ Regulatory Co==ission ("Co= mission") issued.
an crder relating to the preservation of records pertaining to the Three. _ __
Milo Island. Unit 2 ("TMI-2") accident. See 44 Fed. Reg. 30788 (May 29.- - ~
~
1979). The order gave notice that the Com=ission had begun a " wide- '
rcnging investigation into all aspects of the Three Mile Island accident". '
'cnd that "[1]n order to assure the effectiveness of the investigation it -
is essential that the investigators have access to every potential source' of data that may be relevant to their work'.'. Accordingly- the Coc=ission ,
diracted that, until further order, "all records that may be related to ' ,
tha cecident at Three Mile Island, or to understanding of all events
- iincidentthereto,shallbepreservedintactbypersonsinpossessionof such records * * *." -
Tha May 22, 1979 order still re=ains in effect, even though the Co==ission's sp,scial investigation has been completed and all associated reports have basu issued. To cur knowledge, there presently are no ongoing investigations into the TMI-2 accident; nor are we aware of any future investigations currently planned. We therefore request that the Co ission enter an order vacating its May 22, 1979 order and releasing the affected records. This vould allow the Licensee to reestablish its nor=al course of business and ,
retain business documents in accordance with existing regulatory retention criteria. ,
In many cases the Ce: mission's May 22, 1979 order has required the Licensee and its contractora to caintain actual physical samples, not. ithstanding -
that the sacples have been counted and the data have been recorded and enclyzed. In other cases, the May 22, 1979 order has required the preser-vation of ce=puter storage disks and tapes tven though the data have been .
transferred to hard copy and/or cicrofilm. Given the licits on available storage space, Licensee can perceive no reason for continuing to caintain .
cod store.such infor=ation. .- .
1 l
~
GPU Nut! car is a bart of the General PubHc Utilities System (
(
(
o -
. ~ - - .
4400-82-L-00M .
Mr. Harrld R. Denton -
The' Cos::nission's May 22, 1979 order explicity contemplated that the Cor=nission -
would issue a subsequent order authorizing release of the records once the purp ses to be served by the initial order had been accomplished. It is now' c1most three yearsT since the THI-2 accident and we believe no purpose is .
carv:d by continuing extraordinary procedures to preserve 'i nformation that has been available to, and carefully reviewed by, those conducting investigations cf the THI-2 accident.
Sincerely,
/s/ R. C. Arnold R. C. Arnold President, GPU Nuclear RCA JJB:djb ces " Dr. 3. J. Snyder, Program Director THI Program Office J Mr. L* H. Barrett, Deputy Program Director. TMI Program Office Mr. Irvin 3. Rothchild III Esquire, Office of General Counsel - -
~ '
Mr. Stephen H. Lewis, Esquire. Office of the Executive Legal Director l
o l
- y .
If *: '
s f ,- -
1 i
May 31; 1983
. The Honorable D. L. Jensen
- Assistant Attorney General Criminal Division U.S. Department' of Justice Washington, D.C. 20530
Dear Hr. Jensen:
Your May 17, 1983, letter to Chainnan Palladino raises a number of questions with respect to the communications between our two agencies which I would like to address.
- First, you state that "...the Department requested the NRC to curb its
, investigative efforts somewhat for a limited period of time to maximize the
- effectiveness of the grand jury proceedings." At several meetings with Department attorneys in late April 1980,- the NRC was clearly and unambiguously ;
requested to stop (emphasis added) all phases of its investigation into the Hartman allegations so as not to possibly impinge on the Department of i Justice's (D0J) investigation.
Second, your letter goes on to state "It is not correct to state, however, that the Department prevented the NRC from oursuing its inquiry into the so-called Hartman allegations." In this regard the NRC recognized from the 1 outset that the DOJ did not have authority to literally prevent the NRC from pursuing its inquiry into the Hartman allegations. However, it is correct to state that at meetings in April 1980, Department attorneys vigorously objected to NRC continuing the investigation. Department attorneys made it quite clear i that if NRC did not accede, then DOJ would consider such a decision to be
- tantamount to hindering / impeding their investigation.
Third, your letter states "However, in October 1981 a Criminal Division attorney advised Mr. James Cumings of the NRC that the NRC should feel free i-to proceed with interviews of any of those employees, except three specifically identified individuals. Mr. Cumings was advised further that those three individuals could be interviewed by the NRC at any time after, ,
November 1981." I disagree. .
By way of background, on October 13, 1981, I met at ifain Justice with Department attorneys Richard, Lippe and Reynolds. This meeting was initiated by me to determine the status of the Hartman matter prior to the Three 11ile Island (THI) restart hearings. f1r. Victor Stello, then Director of HRC's Office of Inspection and Enforcement, was also present at th.is meeting. NRC ,
j was informed as follows: .
\
l . The Federal Rules of Criminal Procedure regarding grand jury testinony l proscribed 00J from providing any detailed information reoardino the case;l l l l l l l l
r w
i
.w.
.$ ' .~ *. .. .. ,_ t r- .+ -
. In D0J's opinion the grand jury process had uncovered .lo new substantive information over and above that which the NRC had found in its
. preliminary -investigation;
. The DOJ was not aware.of any evidence presented to the grand jury which
. would indicate any new public health. and safety issues not already known to the NRC by virtue of its preliminary investigation; o
. Department Attorneys expected a decision would be ma'de by November 1, 1981, on whether to continue the DOJ investigation. They further expressed the belief that by this time most, if not all, of the substantive investigation would be completed particularly with respect to grand jury witnesses and NRC could then proceed with its investigation.
However, they said they would contact U.S. Attorney Carlton O'Malley, Middle District of Pennsylvania to verify the status of the investigation
, and to obtain his concurrence with respect to NRC reinstituting its investigation;
. A D0J decision not to pursue the investigation any further should not- be interpreted by NRC to mean that the D0J investigation found no evidence of wrongdoing;
. If DOJ decided not to pursue this matter then, at NRC's request, DOJ '
4-would be willing to petition the court for release of grand jury testi-mony to NRC. DOJ was pessimistic that the courts would agree to this '
release; and i
n_
. 00J regretted they had not been able to bring this matter to a speedy
- 3 resolution but were not apologetic for this situation as they felt ,
substantial time and manpower had been devoted to the case.
Following the October 13, 1981 meeting, my office called Department attorneys on a regular basis, however, no final decision was forthcoming.
- Mr. O'Malley's hospitalization, the appointment of a new United States i Attorney for the Middle District of Pennsylvania and the reassignment of th'e
' case were undoubtedly factors which contributed to this situation. On March 1, 1983, I met at Harrisburg, Pa, with Assistant U.S. Attorney James West. At this meeting I outlined NRC's interest in the overall Hartman allegations and told him that NRC was considering reinstituting its i investigation. Mr. West was very responsive to NRC's interest in this matter i and advised me that his office and the Federal Bureau of Investigation were giving this matter priority attention and that he hoped the case might be .
j resolved by June or July 1983. Mr. West requested that, if possible, NRC not I reinstitute its investigation or take any enforcement action in this matter l until his office had an opportunity to resolve the matter. Mr. West's request i is totally consistent with the po:ition taken by D0J throughout this investi- '
gation. In fact, your May 17 letter is the first notification NRC has received that the Department no longer objects to NRC reinstituting its l investigation of the Hartman matter.
J Finally, putting aside the comunications issue, I am concerned that with the exception of fir. West, no one in the Department, has committed to a :
orosoective comoletion date for this investication. This matter was referred
,_,,l to the Dep)rtnent in April 1980 and,l to our knowliedge, has no jcomplex l l
. h I b
.~o % ,. *
[
interstate aspects or sophisticated criminal schemes to.be uncovered which could reasonably ,iustify an investigative period in excess of three years.
The NRC .is close to the point where a significant decision must be made with regard to the THI restart. To ensure this decision is responsible, well reasoned, and in the public's interest, it is desirable that all available data be factored into the agency's ' decision making process.
I hope this letter clarifies some of the issues and concerns expressed in your letter of May 17, 1983.
aincerely, s..' %[..' -
,- fjfnpl *I James J. Cunrjings,.x:~:":~9 Director Office of I.nspector and Auditor bec: Ocanission (5)
W. Dircks, EDO B. Hayes, OI H. Plaine, OGC V. Stello, DEDO H. Denton, NRR G. Cunningham, EID T. Martin, BO I R. DeYoung, IE Distribution OIA File OIA rdr s
9
Chronology - Hartman Allegations l May 1979 -
Hartman makes allegations concerning falsification of August 1979 results of reactor conlant surveillance leak rate March 1980 tests with the knowledge and approval / encouragement i of supervisory personnel.
~
sMay 1980 -
Grand Jury convened in Harrisburg, PA and NRC reouested to halt its investigation for approximately six months. i
~
October 1981 - Messrs. Stello and Cummings met with 00J officials to -
discuss progress of case. 00J gave anticipated completion of case as November 1981. It was agreed that if 00J determined not to pursue the case, DOJ would petition the court for release of the Grand Jury -
testimony to the NRC.
l Spring 1982 -
New U.S. Attorney assumed duties, case assigned to new attorney for review.
1 March 1983 -
Determination made to convene new Grand Jury when current Grand Jury expires. The AUSA Jim West anticipates presenting the case to the Grand Jury by July 1983.
1
. \
/
At+,achment 6
1 k , k hkTid R-r l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION FYI cc: T. Murley
(_Tc1fartin -
BEFORE THE CGMMISSION R. Starostecki R. Keimig In the Matter of ) JMG - 2/27/84 METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 (Three Mile-Island Nuclear Station, Unit No. 1)
NRC STAFF'S COMMENTS ON THE COMMISSION'S JANUARY 20, 1984 LIST OF INTEGRITY ISSUES IN RESTART PROCEEDING Jack R. Goldberg February 21, 1984 Counsel for NRC Staff A/ ; , 9 4 AJ s 4 Q 'T f & UT y Q/
( ,
- a TABLE OF CONTENTS P. age
-INTRODUCTION.................................................... 1 STAFF COMMENTS ON LIST 0F INTEGRITY ISSUES...................... 3 I. Items Raised in Original Management Hearing................ 3 A. Whether Licensee Withheld Information During the Accident (the "Infonnation Flow" i Issue)................................................ 3 i
-B. Is Licensee Committed to Establishing an
- Adequate Training Program?............................ 4 C. Did Management Pursue Activities Prior to the
! Accident That Endangered Public Health-and Safety?........................................... 6 D. Possible Influence of Financial Considerations on Technical Decisions................................ 8 t E. Whether the Mailgram Sent by Mr. Dieckamp to i
Congressman Udall on May 9, 1979 Regarding the " Pressure Spike" Was a Materkal False Statement............................................. 8 l F. Hartman Allegations................................... 10 l
II. Issues Raised By The Cheating Incidents.................... 10 A. Adequacy of Management' Response to Cheating........... 10 B. Management's Knowledge of and/or Involvement in Cheating........................................... 11 ,.
C Extent of Cheating.................................... 12 D. Training and Testing Program.......................... 13 E. Licensee's System for Certifying Candidates........... 13 i
III . I tems Raised Si nce Close Of Hearing . . . . . . . . . . . . . . . . . . . . . . . . 15 A. Hartman Matter........................................ 17 B. TMI -1 Lea k , Ra te I s su e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 l
- ii -
PJggt .
C. Parks / King /Gischel' Allegations on Technical Violations and Harassment and Intimidation.................................... 19 D. Timely Reporting of Documents....................... 21
. E. Keaten Report Issue................................. 22 F. T?U v. B&W Trial Material Review.................... 23 G. Boring Brothers A11egations......................... 24 H. Unattended Radiation Worker Examinations and Answer Keys..................................... 25 I. Psychological Testing Allegations (QuinnAllegations)................................. 25 J. Technical Issues.................................... 26 CONCLUSION.................................................... 27 i
l l
O
o' ,-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
Docket No. 50-289 METROPOLITAN EDISON COMPANY, ET AL.
(Restart)
(Three Mile Island Nuclear Station, Unit No. 1) )
NRC STAFF'S COMMENTS ON THE COMMISSION'S JANUARY 20, 1984 LIST OF INTEGRITY ISSUES IN RESTART PROCEEDING INTRODUCTION On January 20, 1984, the Commission sent to the parties to the TMI-1 restart proceeding a memorandum of that date with an attached " List of Integrity Issues". The Commission provided the parties until February 21, 1984 to submit commente ua:
(1) whether the list is accurate and complete, with the exception of issues referred to 01 which have not been made public; (2) which issues are considered by the parties to be resolved or unresolved; (3) which unresolved issues must be resolved before restart; and (4) for each issue considered unresolved and important:
(a) the basis for the view that the issue is important to a restart decision, and (b) the steps which remain to be taken to resolve the issue, t
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with particular attention to the standards for reopening the record for those ~ issues that were already litigated before the Atomic Safety and Licensing Board and/or Atomic Safety and' Licensing Appeal Board.
The Commission stated in its memorandum that after a complete list of integrity issues is identified, the Commission can proceed to deter-mine the significance of the issues to a restart decision. The Commission
. 'also stated that once the significance of the issues is determined, the Comission will provide a proposed plan of action on restart.
In a memorandum to the parties dated January 27, 1984, the Comission (majority) announced its' tentative views and plan for resolution of management integrity issues prior to restart. The Comission l
! tentatively concluded that, in principle, the temporary separation of .l some GPU employees from nuclear operations, and other. actions, can serve as an interim solution to the management integrity issues pending their ;
! resolution. The Comission also stated its present belief that the only ongoing investigation which may require further resolution before a decision on the management issues is the Unit i leak rate investigation.
l Finally, the Comission announced that it will . provide the parties with i
! a tentative draft decision on the management issues for comment and that it hopes to issue a restart decision by June 1984.
The Staff provides the following coments in response to the Comission's January 20, 1984 memorandum. The Staff wishes to emphasize that these coments, as requested, address only integrity issues which were raised in the original management hearing, by the cheating incidents, or since the close of the evidentiary record. These coments do not address issues other than integrity issues which the Staff, other parties, or the Comission may believe must be resolved before restart.
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n s-STAFF COMMENTS ON LIST OF INTEGRITY ISSUES ;
Except as discussed below in the Staff's more' detailed comments, i the Staff believes that the issues raised in the original management i
hearing (Category I of the Commission's list of integrity issues) and those raised by the cheating incident's (Category II of the Comission's list of integrity issues) are accurate, complete, and resolved by the-Licensing Board's Management and Cheating PID's. With the exceptions l~
noted below, the Staff believes that the issues raised since the'close of the evidentiary record (Category III of the Comission's list of integrity _
issues) are accurate and complete but unresolved. Tne Staff believes
! that the TMI-1 leak rate issue needs to be resolved before the restart of i
- TMI-1 at any power level. With respect to most of the other unresolved issues, the Staff believes tnai the Commission should evaluate the results
! of 01's investigations before allowing TMI-1 to operate above 25% of full
- power. The Staff's specific comments on each of the integrity issues identified by the Commission follow.
I. Items Raised In Original Management Hearing With the few exceptions discussed below, the Commission's list of integrity issues which were raised in the original management hearing is
!. accurate and complete and those issues have been resolved by the Licensing i Board in its Management Partial Initial Decision (Management PID), 14 NRC 381(1981). The basis for the Staff's position on each of the issues follows.
A. Whether Licensee Withheld Information During the Accident (the
! "Information Flow" Issue).
l 1. Was information wilfully withheld?
- 2. Were any current GPU Nuclear personnel involved in any wilfull withholding?
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- 3. Did licensee's response to the accident indicate a lack of forthrightness inconsistent with its responsibilities to the NRC, the Comonwealth, and public health and safety?
- 4. Are steps taken by licensee subsequent to the accident sufficient to ensure a better information flow in the future?
This list of subissues on the "information flow" issue is accurate and complete. The information flow issue was satisfactorily resolved by the Licensing Board in the Management PID 11 469-97 and does not remain an open issue at this time. See also Staff Ex. 5 (NUREG-0760, " Investigation into Information Flow During the Accident at Three Mile Island") at 10-11, 35-45.
B. Is Licensee Committed to Establishing an Adequate Training Program?
- 1. Does the delay in obtaining a TMI-1 replica training simulator reflect adversely on management's attitude toward training?
- 2. Does the amount of time that TMI-1 operators will spend annually in simulator training reflect adversely on management's attitude toward training?
- 3. Does management's failure to establish a training program that is equivalent to a college curriculum reflect adversely on management's attitude toward training?
- 4. Does failure to require operators to attain a 100% test score on the NRC's operating license exam reflect adversely on management's attitude toward training?
- 5. Does licensee maintain an adequate awareness of operator attitude, foster morale and ensure an appreciation of the significance of operator actions?
l E 6. Was the 1978 training program in violation of NRC requirements, and, if so, was management aware of this
, (Bookinvestigation)?
- 7. Has licensee taken adequate corrective steps with regard to any identified deficiencies?
Training issues were considered extensively by the Licensing Board.
The Licensing Board's favorable resolution of the issues regarding Licensee's training program is discussed in the Management PID l
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4 a' ,. l 11 163-276.1/ The Staff considers this list of training issues accurate, complete, and resolved, based on those portions of the Management PID cited bel ow.
Licensee's purchase of a TMI-1 replica simulator is addressed in the
, Management PID 1 258. The Staff believes that the delay in GPU's obtaining a simulator is attributed to backlogs of industry orders and the inability of simulator suppliers to meet schedules, not to any fault of GPU's. The amount of time that TMI-1 operators spend in simulator training, sub-issue I.B.2, is addressed in Management PID 11 252-58. Licensee's requalification training program, which includes simulator training, meets current NRC requirements. The Licensing Board's opinion on the absence of any need to establish a college-level training curriculum, sub-issue I.B.3, appears at Management PID 11 261-63. There is no NRC requirement for a college-level training curriculum. The Staff's position remains that Licensee's training program meets NRC requirements. The 100% test score issue, sub-issue I.B.4, is addressed at Management PID 1 264.
The NRC requirement is an 80% test score overall with not less than 70%
j on each subject area.
With regard to sub-issue I.B.5 on Licensee's awareness of operator attitudes, which was not addressed in the original hearing, the Staff's position is that this issue is resolved as discussed in NUREG-0680, 1
J/ The discovery of cheating on the NRC's April 1981 R0 and SR0 examinations at TMI-1 cast doubt on the Licensing Board's resolution of the training issues, so the Licensing Board retained jurisdiction over the matter and reopened the record. Licensee's training and testing program is further discussed in connection with issue II.D. infra.
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-6' Supplement 4 (October 1983), concerning the Staff's evaluation of the
-BETA and RHR reports.
As to sub-issue I.B.6 concerning O censee's pre-accident training program, as the Comission noted in its January 20th memorandum at 2-3,
-this sub-issue was not considered in the original management. hearing but was identified by the Staff subsequent to the close of the evidentiary record.. See B.N.-83-71 (May 18, 1983); see also "GPU v. B&W Lawsuit Review and its Effect on TMI-1," NUREG-1020, Vol. 1, i 10.3. This issue remains unresolved but, in the Staff's opinion, need not be resolved prior to restart. The Staff plans to evaluate the results of OI's investigation into this matter when it arrives at an overall position on l
4 management integrity. Furthermore, the Staff considers the matter of deficiencies in Licensee's pre-accident training program .to' be included within sub-issue III.F.4., to be addressed below.
With regard to the question of whether Licensee has taken adequate j corrective steps on any identified deficiencies in its training program,
! sub-issue I.B.7, the Staff is satisfied with the corrective steps taken i by Licensee in response to identified deficiencies. See e.g., NUREG-0680, Supp. 4, il 4, 6.5. As an example of a recent Staff inspection of Licensee's training program, see Inspection Report No. 50-289/83-29, January 13, 1984. The staff considers this sub-issue resolved. '
! C. Did Management Pursue Activities Prior to the Accident That Endanaered Public Health and Safety?
- 1. Did GPU defer safety-related maintenance and repair b'eyond the point established by its own procedures?
- 2. Did GPU drastically cut its maintenance budget?
- 3. Did GPU fail to keep accurate and complete maintenance records?
_y_ .
- 4. Did GPU have an inadequate-and un'derstaffed QA/QC ,
program related to maintenance?
- 5. Did licensee. require extensive use of overtime in performing safety-related maintenance? If so, did this lead to poor quality safety-related maintenance?
- 6. -Has licensee taken adequate corrective steps +
regarding'any identified deficiencies? ,
These maintenance issues are addressed in the Management PID 11 277-348. Specifically, sub-issue I.C.1, regarding deferral of safety-related maintenance, is addressed at Management PID 11 2821300. Sub-l
- issue I.C.2, which concerns Metropolitan Edison Company's maintenance budget, is addressed in the Management PID 11 320-24. Su b-i s sue ' I . C. 3, f
l regarding maintenance records, is addressed at Management PID 11 301-19.
l Sub-issueI.C.4onLicensee'sQA/QCprogramisdiscussedatMangeNeitPID l 11 325-30. Sub-issue I.C.5 on overtime is addressed at Management PID 11 331-348. TheStaffconsiderstheseissuesaccurateandcc.gleth,and,
- based on the Managebnt PID as cited above, satisfactorily resolved.
l With regard to sub-issue I.C.6, the Staff is satisfied that Licensee g has taken adequate corrective steps regarding identified maintenance deficiencies. Since August 27, 1981, seven inspections by resident and/or regional inspectors were conducted in connection with maintenance activities at TMI-1. See Inspection Report Nos. 81-27, 82-09, 82-10, 82-18, 82-19, 83-02, 83-22. Although some inspections have identified I !
[ deficiencies in maintenance activities, and the licensee has identified i
deficiencies through its audit and surveillance program, these deficiencies largely have been minor in nature and have received prompt u i
attention from Licensee. Action was taken not only to correct the y
specific deficiency, but also the weakness in the system which allowed i
- it to occur. The Staff considers this sub-issue resolved.
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- g D. Possible Influence of Financial Considerati ns on Technical k - Decisions w
- 1. Are there indications-that financial considerations -
+ had an u'ndue influence on TMI operations prior to the g , accident?-
y.
YJ 2. If there wasuny improper influence, has licensee
?- taken adequate steps to assure that this will not recur?
The issues of pbssible influence of financial considerations on technical decisions was resolved-by the Licensing Board. Management PID
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11 387-401. This issue was raised again, however, duHng the Staff review of -
the GPU v. B&W record anc t s been referred to the Comission's Office of Investigations. See B.N.-83-152 (October 3, 1983); NUREG-1020, i 10.9.
Therefore, although the Staff conside_rs these issues accurate and complete with the exception of issues referred to 01 which have not been made public, i( they remain unresolve<1. The Staff will evaluate the results of those 01 3,
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investigations related to this matter. The Staff does not believe that this issue must be resolved before a restart decision because even if the 01 investigations re/eal that financial considerations did have an undue influence prior to the accident,'the organizational cha'nges made since that time assure that such practices could not continue today. ifhe GPU Nuclear operation is now dedicated solely to operation of the GPU nuclear units, so there sh'ould be no conf 1'icting requirements for financial resources, y
E. Whether the Mailgram Sent by Mr. Dieckamp to Congresman Udall on May 9,w1979 Regarding thel" Pressure Spike" Was a Material, False Statement
- 1. Did Dieckamp know there had been a pressure spike ct 1:50 p.m.
, on March 28, 1979 at the time he wrote to Udall?
[ The subject of Mr. Dieckamp's May 9, 1979 mailgram to Congressman n 'Udall was address'ed b'y the Licensing Board in the Management PID 11s498-503: The Staff's position is that the Dieckamp mailgram does not n
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l constitute a material false statement under the Atomic Energy Act. See Ex. 5 (NUREG-0760), at 45-46. However, neither the Staff nor the Licensing Board viewed the mailgram in the restart proceeding from the narrow perspective of whether it constituted a material false statement, but rather from the perspective of its bearing on management integrity.
See Management PID 1 501. The Staff concluded that Mr. Dieckamp_
believed the statement to be true when made. Tr. 13,060-64 (Moseley).
The Licensing Board believed that the Staff's evidence was sufficiently reliable to resolve the matter. Management PID 1 501.
As described above, the Staff considers the nailgram issue resolved by the Licensing Board. If the Commission does not consider the issue resolved, however, then the Staff believes that another sub-issue must be added to make the statement of sub-issues accurate and complete.
In the mailgram, Mr. Dieckamp stated:
There is no evidence that anyone interpreted the
" Pressure Spike" and the spray initiation in terms of reactor core damage at the time of the spike nor that anyone withheld any information.
Thus even if Mr. Dieckamp knew that there had been a pressure spike, the mailgram statement underlined above would not be false unless Mr. Dieckamp also knew that someone interpreted the pressure spike in i
l' terms of reactor core damage at the time of the spike. Therefore, if this matter is considered unresolved and further pursued, the following sub-issue should be added for accuracy and completeness:
"2. If Mr. Dieckamp did know that there had been a pressure spike at 1:50 p.m. on March 28, 1979 at the time he wrote to Congressman Udall, did Mr. Dieckamp know that there was evidence that someone interpreted the pressure spike and/or spray initiation in terms of reactor core damage at j the time of the spike?"
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F.- Hartman Allegations
- 1. Hartman allegations regarding possible falsification of leak rate data were raised in the proceeding, but not addressed. .
They will be discussed infra.
.The Hartman allegation of falsification of leak rate data at TMI-2 ~
is discussed briefly in the Management PID 11 504-06. This is one of the "open issues" identified by the Staff in its May 19, 1983 memorandum to the Commission. On August 31, 1983,.the Appeal Board reopened the management record on this issue and remanded the matter to the Licensing Board. ALAB-738, 18 NRC 177, 183-92 (1983). By Order dated October 7, 1983, the Commission stayed the Licensing Board proceeding until further order of the Commission. Order (October 7, 1983). This issue will be discussed further in III.A., infra.
In conclusion, with the few exceptions noted above, the Staff believes that the Commission's list of integrity issues raised in the original management hearing is accurate and complete and esolved by the Licensing Board in its Management PID.
II. Issues Raised by the Cheating Incidents The Staff believes that the Commission's list of integrity issues which were raised by the cheating incidents is accurate and complete and that those issues have been resolved by the Licensing Board in its Cheating Partial Initial Decision (Cheating PID),16 NRC 281 (1982), as follows:
A. Adequacy of Management Response to Cheating.
- 1. Did management wilfully constrain the NRC investigation by having m'anagement representatives sit through NRC interviews?
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- 2. Did management conduct a thorough investigation to determine who cheated? .
- 3. Did management impose appropriate sanctions on those who cheated? ~
- 4. Has management taken appropriate steps to make it more difficult for one to cheat?
- 5. Did management break the sequestration agreement and improperly coach GPU employees who testified in the reopened hearing?
These issues regarding the adequacy of GPU Nuclear management's response to cheating are addressed and resolved in the Cheating PID 11 2228-2320. Specifically, sub-issue II.A.1 on management's presence during some NRC interviews is resolved at Cheating PID 11 2229-2234.
Sub-issue II.A.2 regarding GPU's investigation of the cheating incidents is resolved at Cheating PID 11 2235-2271. The sanctions management imposed, sub-issue II.A.3, is addressed at Cheating PID 11 2275-86. Sub-issue II.A.4, concerning the steps management has taken, is addressed at Cheating PID 11 2068, 2237-40, 2321-51.
The question of whether Licensee violated the sequestration order and improperly coached witnesses, sub-issue II.A.5, was resolved by the Special Master. Although the Special Master was dissatisfied with the quality of the testimony of Licensee's witnesses, he found that Licensee's counsel acted in good faith in accordance with the terms of the sequestration order. See Tr. 26,790-98; Memorandua and Order Denying Motion to Stay the Hearing, February 9, 1982.
B. Management's Knowledge of and/or Invovlement in Cheating.
- 1. Did management encourage, condone or participate in the cheating?
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2.: Did Ross attempt to keep the proctor away from the examination room for a prolonged period of time to facilitate cheating?
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- 3. Did Ross unreasonably broaden the answer keys? .
Management's knowledge of and/or involvement in cheating is addressed and resolved in the Cheating PID 11 2191-2227. The Licensing Board concluded that Licensee's management did not encourage, condone or participate in the cheating. Cheating PID 11 2047, 2066. The allegations against Mr. Ross were' determined to be unfounded. Cheating PID 11 2192-2225. The Staff agrees with the Licensing Board's resolution of these issues.
C. Extent of Cheating.
- 1. Does the extent of cheating reflect adversely on management's integrity and ability to operate the plant consistent with public health and safety?
- 2. Do TMI-1 operators have sufficient integrity to perform their duties?
- 3. Does Husted have sufficient integrity to supervise training of unlicensed individuals?
The extent of cheating, sub-issue II.C.1, is described and resolved in the Cheating PID 11 2039-45, 2090-2190. The Licensing Board found no public health and safety consequences resulting from the cheating.
Cheating PID 11 2039-45, 2066. The overall integrity of the operations staff, sub-issue II.C.2, was not'found to be inadequete. Cheating PID 9 2043. Mr. Husted is discussed in the Cheating PID 11 2148-68.
Mr. Husted's training of unlicensed individuals, sub-issue II.C.3, was not addressed directly by the Licensing Board. Although there was no evidence that Mr. Husted's improper attitude is manifested in his performance as an instructor, the Licensing Board recommended that his
performance receive particular attention. Cheating PID 1 2165. Licensee has committed to not-utilize Mr. Husted to operate TMI-1 or to train operating license holders or trainees, and to closely monitor Mr. Husted's performance. Stipulation of Withdrawal, July 6, 1983, at 2. It is the I
Staff's understanding that Licensee in fact is monitoring Mr. Husted's performance as a trainer of unlicensed individuals. The Staff considers Licensee's response to Mr. Husted's improper attitude adequate. The Staff notes that there are no NRC requirements for instructors of non-licensed personnel. Based on all of the above, the Staff considers this issue resolved.
D. Training and Testing Program.
- 1. Is licensee's administration of its operator training and testing program sufficient to provide confidence in the integrity of management?
- 2. Is licensee committed to improving the quality of its training program?
The effect of the evidence on cheating on the Licensee's training and testing program was addressed and resolved hy the Licensing Board in Cheating PID 11 2061-71, 2321-47. Based on improvements Licensee has made and on the license conditions imposed by the Licensing Board
. (Cheating PID 1 2421), the Staff considers these issues resolved. See also NUREG-0680, Supp. 4, 9 4.
E. Licensee's System for Certifying Candidates.
- 1. Is licensee's system for certifying competency of operator candidates seeking to obtain or renew licenses sufficient?
- 2. Did management improperly certify VV to the NRC in 1979?
- 3. If VV was improperly certified, who was responsible for making the certification decision? Was upper management involved?
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- The' Licensee's system for certifying operator candidates for NRC licenses is addressed in the Cheating PID 11 2348-51. The Staff considers Licensee's system adequate. See Staff's July 29, 1983 letter to Licensee. Sub-issue II.E.1 is, therefore, resolved.
With respect to sub-issues II.E.2 and II.E.3, the 1979 VV-0 incident, and 4
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Licensee's certiff ation of VV to the NRC, is addressed in the Cheating
-PID 11 2272-2320. 1his issue was removed from the proceeding by Commission order, and referred to the Staff for a recommendation on whether a civil penalty proceeding should be initiated. CLI-82-31 (October 14,1982). Subsequently the Commission authorized the Staff to i
issue a Notice of Violation and proposed civil penalty in the amount of
$100,000 for a material false statement in connection with Licensee's certification of VV. CLI-83-20 (July 22, 1983).- On July 25, 1983, the Staff issued a Notice of Violation and Proposed Civil Penalty. This enforcement proceeding has been suspended pending the release of a related OI report. Based on these events, the Staff considers sub-issues II.E.2 and II.E.3 to be resolved insofar as restart is concerned, but
- unresolved as enforcement matters outside the context of the TMI-1 restart proceeding. The Staff's overall position un management integrity, however, will take into account the evidence that exists on sub-issues II.E.2 and II.E.3. See NUREG-1020, 5 10.5.
In conclusion, the Staff believes that the Comission's list of integrity issues which were raised by the cheating incidents is accurate 1 and complete and resolved by the Licensing Board in its Cheating PID.
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- III. Items Raised Since Close of Hearing:
The Staff believes that the Commission's list of issues raised since the close of the evidentiary record is accurate and complete, with the exception of issues referred to 01 which have not been made public.
With only a few exceptions, discussed below, the Staff believes these issues are unresolved and should be resolved, as described below, before TMI-1 is permitted to operate above 25% of full ~ power. As a matter of background, a brief summary of the Staff's position on the "open issues,"
and the steps the Staff believes must-be taken to resolve those issues, follows.
o In a memorandum from the Staff to the Commission datec May 19, 1983, the Staff identified five open issues: (1) the veracity of the Hartman allegations; (2) the GPU v. B&W lawsuit review; (3) the Parks and King allegations; (4) possible concerns raised by the RHR and BETA reports; and (5) whether GPU failed to promptly notify the Commission or the Appeal Board of material information in the RHR, BETA, and other reports.
Based on these open issues, the Staff stated that it could draw no conclusion regarding management integrity at that time. In a June 7, 1983 memorandum to the Commission, the Staff outlined the basic steps that would have to be taken before the Staff, for its part, could reach a decision on whether restart should be permitted. These steps included a complete resolution of any outstanding safety issues, and a satisfactory approach to assuring that any individual whose integrity was questioned as a result of the various allegations, reviews and investigations was removed from safety-related activity at TMI-1 pending completion of any required investigations, unless the licensee could
satisfactorily demonstrate that one or more of those individuals could be. retained while they were under investigation. On July 15, 1983, the Staff provided the C mmission with its plan to complete the restart review. -
The Staff ind1cated that it would await the outcome of the various reviews and investigations of open issues and integrate the results of those reviews and investigations-_into an overall staff position on managem nt integrity.
Finally, in a memorandum to the Comission dated January 3,1984, the Staff provided its written response to GPU's June 10,.1983 management organization proposal as modified by GPU on November 28, 1983. The Staff stated:
At the December 5 meeting, the NRC staff informed the Commission that if the Commission desired to decouple operation of TMI-1 from the ongoing 01 investigations in the management integrity area, we did not believe restart would pose any undue risk to public health and safety provided that in addition to GPU's June 10 proposal as supplemented on November 28:
- 1. The NRC Office of Investigations (01) completes its review of leak rate irregularities at TMI-1 and provides to the Commission its conclusions on that issue, as well as a status report on the remainder of its investigations and there are no significant adverse implications for key TMI-1 management or personnel.
- 2. Power level is limited to approximately 25%. This level would limit fission product build-up and would assure limited consequences in the event of an accident, and still provide a stable plant operating level, at which all important plant systems would be operational. Our basis for recommending 25%
includes:
o Reactor Coolant Average Temperature is constant above 15%
while the pressurizer level is constant within the level control dead-band.
o Main feedwater regulating valve control is stable above the 15-20% full power range and is not subject to feed flow perturbations.
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,This would permit a thorough check-out'of the facility itself and permit operator familiarization or refamiliarization'with actual plant operations.
- 3. The' staff provides 24-hour inspection-coverage at least until -
the licensee's operational QA coverage and.the Nuclear Safety and Compliance Committee of the licensee's Board of Directors are solidly in place and functioning.
Subsequently, the Commission could base its decision on further operation beyond 25% of full power on:
- 1. Satisfactory completion of the OI investigations on management-issues.
- 2. The functioning of the Nuclear Safety and Compliance Committee of the GPUN Board of Directors as proposed by GPU on-November 28, 1983.
- 3. A staff report on the plant operations to that point, with no major safety problems having been identified.-
- 4. -An evaluation of the effectiveness of the GPU operational QA coverage.
Memorandum from William J. Dircks to the Commission, January 3. 1984, at 3-4 (footnote omitted).
The Staff will now address each of the major issues areas identified by the Commission as arising since the close of the hearing record.
A. Hartman Matter.
- 1. Was leak rate data at TMI-2 falsified?
- 2. Who was involved in any falsification?
- 3. Did management have knowledge of, encourage or condone falsification? If so, who in management was involved?
- 4. Why didn't licenscc thoroughly investigate matter?
- 5. What impact does the criminal indictment have?
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The Hartman allegations of falsification of leak rate data at TMI-2 was one of the five open issues identified by the Staff in its May 19, 1983 Memorandum. This matter also is discussed in the Staff's "GPU v. B&W-Lawsuit Review and its Effect on TMI-1," NUREG-1020 Vol.1 (NUREG-1020),-
5 10.1. On August 31, 1983, the Appeal Board reopened _the management record on this issue and remand 2d the matter to the Licensing Board.
- ALAB-738, supra. By Order dated October 7,1983, the Comission stayed the Licensing Board proceeding until further order of the Comission. Order (October 7,1983). The Comission's list of sub-issues on this matter is accurate and complete. The Hartman matter remains unresolved and is the subject of an investigation by 01. Final resolution of the issue requires a Comission decision on whether to lift its stay of the Licensing Board pro-ceeding on the matter and tha completion of the OI investigation, which could be affected by the Commission's recent decision, at the request of the Department of Justice, to not pursue this matter until after the federal trial resulting from the November 7,1983 criminal indictment of Metropolitan Edison Company. With respect to the question of what steps remain to be taken regarding this matter before a decision on operation l beyond 25% of full power, the Staff believes that the Comission should i
receive and evaluate the results of the OI investigation into the matter.
l See the Staff's January 3, 1984 Memorandum, supra, at 4. The Staff does i
not believe it is necessary to complete the reopened hearing on the Hartman allegations, if the Comission decides to lift its stay, before a restart decision by the Comission.
I B. THI-1 Leak Rate Issue.
- 1. Was leak rate data at TMI-1 falsified?
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- 2. Who was involved in any falsification?
- 3. Did management have knowledge of, encourage or condone falsification? If so, who in management was involved?
The issue of possible TMI-1. leak rate testing irregularities was raised by the Staff and discussed in Board Notification B.N.-83-138 (9/2/83), 138A (9/23/83), 138B (10/6/83) and 138C (10/25/83) and in a Staff letter to the Licensing Board dated November 18, 1983. The Commission's list of sub-issues on this matter is accurate and complete.
This matter has been referred to 01 for investigation and remains unresolved.
The Staff believes that this issue, which may reflect directly on the integrity of the operators and management who will be present for the operation of TMI-1 and not removed by Licensee's June 10th and November 28th proposals, must be resolved before any operation of TMI-1. See the Staff's January 3, 1983 Memorandum to the Commission, supra, at 3. The majority of the Commission apparently agrees. Tentative Commission Views and Plan for Resolution of Management Integrity Issues Prior to Restart, January 27, 1983, at 2. Therefore the Commission should evaluate the results of OI's investigation into this matter before allowing any start-up
, of TMI-1. See Staff's January 3,1983 Memorandum to the Commission, supra, at 3.
C. Parks / King /Gischel Allegations on Technical Violations and Harassment and Intimidation.
- 1. Did licensee follow procedural requirements relating to clean-up?
- 2. Was management intending to cut corners to the detriment of safety?
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- 3. Did management or others attempt to intimidate or harass individuals who questioned whether procedures were being followed? If so, who in management was involved?
This matter was identified by the Staff in the May 19, 1983 memorandum to the Commission as one of the open issues which led the Staff to state that it could draw no conclusions regarding management integrity at that time. The Commission's statement of sub-issues is accurate and complete. Although OI has issued an interim report of investigation on this matter, the issue as a whole remains unresolved since OI has not completed its entire investigation of the matter. Sge B.N. 83-149_(September 29,1983). On February 3, 1984, the Staff issued a Notice of Violation to Licensee in connection with sub-issue III.C.1. As stated in the Staff's July 15, 1983 memorandum to the Commission, the Staff will evaluate the results of 01's investigation of this entire matter. As far as a restart decision is concerned, the Staff believes that the Commission should evaluate the results of 01's investigation
- before permitting TMI-1 to operate above 25% of full power. See Staff's January 3,1983 memorandum, supra. The Staff considers this an important matter because of the seriousness of the allegations against management. The Staff does not believe, however, that the standards for reopening the record are satisfied at this time since the significance of this matter, and whether it might cause a different result to be reached h
on any restart issue, cannot be determined until after 01's entire
! investigation is completed and the results are evaluated.
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D. Timely Reporting of Documents.
- 1. Did GPU provide the NRC on a timely basis with copies of the RHR/ BETA Reports, Keaten Report -
and the Hartman investigation report (Faegre and Bens)n Report)?
This issue of GPU's timely reporting of documents was raised by the Staff in its May 19th memorandum, supra.E It is accurate and complete. 1 By memoranda dated June 22, 1983 and June 29, 1983, the Staff advised the Commission of its conclusions regarding Licensee's obligations to notify the Consnission and/or adjudicatory boards of the BETA and RHR reports and the Licensee's report on the Hartman allegations.E The Staff concluded in its June 22nd memorandum that Licensee can be considered to have failed to meet its duty to make a board notification and its obligations under section 186 of the Atomic Energy Act by failing to provide the BETA and RHR reports more promptly. In the June 29th memorandum, the Staff concluded that the Licensee should have made a more prompt board notification of its Faegre and Benson Report on the Hartmanallegations.O The Staff has requested 01 to determine the y To the best of Staff's knowledge, this is the firs; time that the timely reporting of the Keaten Report has been raised as an issue.
y The memoranda of June 22nd and June 29th were served on the Appeal Board and parties on June 22, 1983, and July 12, 1983, respectively.
y The Staff has acknowledged that "it might also be subject to criticism for not providing additional infonnation on the Hartman matter. The Staff did not do so in order to avoid any possible interference with the D0J investigation." June 29th memorandum at 7-8.
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circumstances and reasons why the BETA and RHR reports were not provided to the NPC earlier. The Staff will consider the effect of those .
conclusions and circumstances on management integrity when it formu-lates its overall position on management integrity after completing its review of the other open issues. The Staff believes that the Comission should evaluate the results of 01's investigation of this unresolved issue before pennitting TMI-1 to operate above 25% of full power. See Staff's January 3, 1983 memorandum, supra. This is an important issue because of the possibility of the improper acts and motivation of senior GPU management. It cannot be determined at this time (before completion and eveluation of 01's investigation report),
however, that a significant safety issue is involved which might cause a different result to be reached on any restart issue. Consequently, the standards for reopening a record are not satisfied at this time.
E. Keaten Report Issue.
- 1. Did management modify the draft Kcaten Report for the purpose of projecting a more positive view of management?
I
- 2. Do any such changes indicate an unwillingness on the part of management to accept responsibility and take corrective actions?
This issue is addressed in NUREG-1020, i 10.2, and is under investigation by 01. The Commission's statement of sub-issues is accurate and complete with the exception of issues referred to 01 which have not been made public. The Staff believes that the Comission should evaluate the results of 01's investigation of this unresolved l issue before permitting TMI-1 to operate above 25% of full power. See l
- a. ...
Staff's January 3, 1983 memorandum, supra. This is an important issue because of the possibility of the improper acts and motivation of senior GPU management. It cannot be determined at this time (before completion and evaluation of 01's investigation report), however, that a significant safety issue is involved which might cause a different result to be reached on any restart issue. Consequently, the standards for reopening a record are not satisfied at this time.
F. GPU v. B&W Trial Material Review.
- 1. Does Frederick's testimony reflect on the sufficiency of his integrity to serve as supervisor of operator training?
- 2. ~Does Zewe's change in testimony indicate sufficient integrity to serve as Radwaste Operations Manager?
- 3. Does GPU's decision prior to the accident to reduce operator training aid thus possibly violate training program cournitments reflect adversely on management integrity?
- 4. Did licensee recognize that prior to the accident there were serious deficiencies in plant hardware /and its training and maintenance program, yet fail to take appropriate corrective actions?
- 5. Did Arnold's testimony before the Licensing
,' Board mislead the Board by implying that the utility was improving its maintenance and training programs?
- 6. Does licensee's decision not to bypass the condensate i polisher reflect on management integrity?
This list of sub-issues is accurate and compl'ete with the exception of issues referred to 01 which have not been made public. See generally HUREG-1020. With the exception of sub-issue III.F.5, these sub-issues'are unresolved and are related to matters under investigation by 01. See
B.N.-83-152(October 3,1983). The Staff believes the Commission should evaluate the results of those 01 investigations related to.these matters before allowing TMI-1 to operate above 25% of full power. These are important matters which potentially could implicate key individuals in the management and operations staff at TMI-1. At this time, before the completion of 01's investigations and before Staff's evaluation of 01's reports of investigation, it cannot be said that there is a significant safety issue which could affect the resolution of any restart issue. Sub-issue III.F.5, regarding Mr. Arnold's testimony before the Licensing Board on improving the TMI-1 maintenance and training programs, is considered by the Staff to be resolved. The Staff believes that, consistent with Mr. Arnold's testimony, Licensee has improved its maintenance and training programs. See, e A , NUREG-0680, Supp. No. 4, l'4, and Inspection Report Nos. 81-27, 82-09, 82-10, 82-18, 82-19, 83-02, 83-22, and 83-29.
G. Boring Brothers Allegations.
- 1. Were welders with inadequate qualifications working at TMI?
- 2. If so, what was management knowledge and role?
This issue, which is stated accurately and completely, is related to an inspection conducted in July and August,1983, by I&E and Region I.
l*
The inspection resulted in a conclusion that there were no significant safety issues involved. See Special Inspection Report Nos. 50-289/83-24, 50-320/83-13. This issue also was the subject of an investigation which did not identify any evidence to support the allegations. See 01 Report of Investigation No. 1-82-066. This issue, therefore, is resolved.
., . . - . . .,, - -- - ,_ - . , - -.-...p-.- -..
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H. Unattended Radiation Worker Examinations and Answer Keys
- 1. Whether discovery of unattended examinations and answer keys raised questions about .
licensee's training comitments?
The subject of unattended radiation worker examinations and answer keys was addressed in B.N.-82-84 (August 17,1982). The issue, which is stated accurately and completely, was the subject of a motion to reopen the management record filed by Intervenors Marjorie M. and Norman 0.
Aamodt on September 3,1982. The Appeal Board denied that motion in its entirety, concluding that this incident is neither significant nor likely to have affected the Licensing Board's decision. ALAB-738, 18 NRC 177, 193(1983). In fact, it was Licensee which discovered the unattended examinations and answer keys, promptly reported the incident to the NRC, and took prompt corrective action. See Inspection Report No. 50-289/82-07 (July 1, 1982) at 17. The Staff believes that this issue is, therefore, resolved.
I. Psychological Testing Allegations (Quinn Allegations)
- 1. Did management improperly assist a potential GPU employee to pass psychological tests?
This issue, which is accurate and complete as stated, was raised by the Staff in B.N.-83-08 (February 1,1983). The matter has been investigated by 01 and its Reports of Investigation have been provided to the Commission Appeal Board Licensing Board, and parties. See B.N.-84-002 (January 4, 1984). Based on 01's Reports of Investigation, this issue is considered by the Staff to be resolved.
e- -w J. Technical Issues
- 1. Does GPU's schedule of implementation of long-tena items adversely reflect on management's character?
- 2. Do the apparent procedural violations in latest Region I inspection reports indicate inadequate management ettention?
These sub-issues are accurate and complete. Sub-issue III.J.1, regarding GPU's schedule of implementation of long-term items, is considered by the Staff to be resolved. The Commission has ruled in this proceeding that, unless the record dictates otherwise, TMI-1 should be grouped with reactors which have received operating licenses rather than with units with pending operating license applications. CLI-81-3, 13 NRC 291, 295-96 (1981). The record reflects that Licensee is completing the long-term actions on a schedule comparable with other similar operating reactors. See NRC Staff Response to UCS Motion to Establish Criteria for Judging " Reasonable Progress,"
November 7,1983, at 5-6. Nevertheless, the Staff is continuing to monitor the performance of Licensee's implementation of long-term items. The Staff also is conducting a survey of the status of implementation of long-term items at all B&W plants to assure that Licensee is on a schedule comparable with other B&W plants. The Staff will notify the Commission promptly if its position on this issue changes.
With respect to sub-issue III.J.2 regarding procedural violations identified in recent Region I inspection reports (see B.N.-83-177 (November 4,1983)),theStaffisconsideringenforcementaction. The procedural violations identified in B.N.-83-177 do not adversely affect management integrity. The Staff therefore considers this sub-issue resolved insofar as restart is concerned, but unresolved as an enforce-ment matter.
-* - a-In conclusion, the Staff believes that the Consnission's list of issues raised since the close of the evidentiary record is accurate and complete, with the exception of issues referred to 01 which have not been "
made public. With the few exceptions discussed above, the Staff believes that these issues are unresolved and should be resolved, as described above, before TMI-1 is permitted to operate above 25% of full power.
CONCLUSION With the exceptions noted above, the Staff believes that the issues raised in the original management hearing and those raised by the cheating incidents are accurate, complete, and resolved by the Licensing Board's Management and Cheating PID's. With the exceptions noted above, the Staff believes that the issues raised since the close of the eviden-tiary record are accurate and complete but unresolved. The TMI-1 leak rate issue must be resolved before the restart of TMI-1 at any power level becuase of the direct implication of this issue on the integrity of operators and management proposed for the operation of TMI-1. With respect to most of the other unresolved issues, the Staff believes that the Commission should evaluate the results of 01's investigation before
. allowing TMI-1 to operate above 25% of full power. At this time, however, none of the unresolved issues meets the Coninission's standards for h
i reopening the record.
Respectfully submitted, N ,
t' ack R. Goldberg l
Counsel for NRC Staff i
Dated at Bethesda, Maryland this 21st day of February, 1984.
i
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'9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~
BENC THE COMMISSION In the Mattet of )
)
METROPOLITAN E91 SON COMPANY, ET AL.) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear Station.)
Ur.it No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S COMMENTS ON THE COMMISSION'S JANUARY 20, 1984 LIST OF INTEGRITY ISSUES IN RESTART PROCEEDING" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regul,atory Comission's internai mail system, this 21st day of February 1984:
- Samuel J. Chilk
- Christine N. Kohl Secretary of the Comission Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety & Licensing Appeal Washington, DC 20555 Board U.S. Nuclear Regulatory Comission
- Herzel H. E. Plaine, General Counsel Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555
- John H. Buck Administrative Judge
- Ivan W. Smith Atomic Safety & Licensing Appeal Administrative Law Judge Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 George F. Trowbridge, Esq.
- Sheldon J. Wolfe Shas, Pittman, Potts & Trowbridge Administrative Judge 1800 M Street, NW Atomic Safety & Licensing Board Washington, DC. 20036 U.S. Nuclear Regulatory Commission Washington, DC 20555 Maxine Woelfling, Esq.
- Mr. Gustave A. Linenberger, Jr. Office of Chief Counsel Administrative Judge Department of Environmental Resources Atomic Safety and Licensing Board 505 Executive House, P.O. Box 2357 U.S. Nuclear Regulatory Comission Harrisburg, PA 17120 Washington, DC 20555 Mr. Thomas Gerusky
- Gary J. Edles, Chairman Bureau of Radiation Protection Atomic Safety & Licensing Appeal Board Dept. of Environmental Resources U.S. Nuclear Regulatory Comission P. O. Box 2063 Washington, DC 20555 Harrisburg, PA 17120
.iw Mr. Marvin I. Lewis- William S.-Jordan, III, Esq.
6504 Bradford Terrace Harmon & Weiss Philadelphia, PA 19149 1725 I Street, NW Suite 506 Mr. C. W. Smyth, Supervisor Washington, DC 20006 Licensing TMI-1 Three Mile Island Nuclear Ste+4nn John Levin. Esq.
P. O. Box 480 Pennsylynnia Public Utilities Comn.
. Middletown, PA 17057 Box 3265 Harrisburg, PA 17120 Ms. Mariorie Aamodt R.D. #5 Jordan D. Cunningham, Esq.
Coatesville, PA 19320 Fox, Farr and Cunningham 2320 North 2nd Street Gail Phelps , Harrisburg, PA 17110 ANGRY /TMI PIRC 1037 Maclay Street Louise Bradford Harrisburg, PA 17103 Three Mile Island Alert
, 1011 Green Street Allen R. Carter, Chairman Harrisburg, PA 17102 Joint Legislative Connittee on Energy Post Office Box 142 Ms. Ellyn R. Weiss (uite 513 Harmon A Weiss Senate Gressette Building 1725 I Street, NW Columbia, South Carolina 29202 Suite 506 Washington, DC 20006 Chauncey Kepford Jud'th Johnsrud Mr. Steven C. Sholly Environmental Coalition on Nuclear Power Union of Concerned Scientists 433 Orlando Avenue 1346 Connecticut Avenue, NW State College, PA 16801 Dupont Circle Building, Suite 1101 Washington, DC 20036 Ms. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant *Dr. Lawrence R. Quarles Postponement Atomic Safety & Licensing Appeal 2610 Grendon Drive Board Wilmington, Delaware 19808 U S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Henry D. Hukill Vice President
- Judge Reginald L. Gotchy GPU Nuclear Corporation Atomic Safety & Licensing Appeal Post Office Box 480 Board Middletown, PA 17057 U.S. Nuclear Regulatory Commission Washington, DC 20555 Michael McBride, Esq.
LeBoeuf, Lamb, Leiby & McRae Ms. Jane Lee Suite 1100 R.D. 3; Box 3521 1333 New Hampshire Avenue, NW Etters, PA 17319 Washington, DC 20036 4
- . . ,- 3 David E. Cole
- Atomic Safety & Licensing Smith & Smith, P.L. Board Panel Riverside Law Center U.S. Nuclear Regulatory _ Commission 2931 N. Front Street Washington, DC 20555
, Harrisburg, PA 17110
- Atomic Safety and Licensing Appeal Michael W. Maupin, Esquire Board Panel Hunton & Williams U.S. Nuclear Regulatory Commission 707 East Main Street Washington, DC 20555 P. O. Box 1535 Richmond, VA 23212
- Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Ack R. Goldberg Counsel for NRC Staff g
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%...- June 7, 1983 -
~
MEMORANDUM FOR: -Chairman Palladino Comissioner Gilinsky Comissioner Ahearne Comissioner Roberts Comissioner Asselstine FROM: William J. Dircks .
. Executive Director for Operations -
SUBJECT:
' COMPLETION OF TMI-1 RESTART REVIEW The recent staff review which was the subject of my memorandum to the Comission of May 19,.1983, concluded that the issues raised by the Hartman allegations should not by themselves prevent restart of TMI-1. Further, the staff concluded that, due tB'the open issues which..have been identified and.
which were not considered in the revalidation program, the staff can draw no conclusion regarding management integrity as it impacts on restart at this time. Therefore, the staff has initiated actions which will enab1'e it to reach a current position on restart.
These actions will include completion of the review of the B&W-GPU lawsuit documents. The review conducted to date confims conclusions reached in the; report of the previous review of the trial court record dated March 28, 1983*,
that the documents do not contain significant new infomation which affects the agency's understanding of the THI ,2 accident, including the sequence of events. The review has, however, identified information with a potential bearing upon management integrity.
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%, o . . . - f June 7, 1983 -
MEMORANDUM FOR: Chairman Palladino Comissioner Gilinsky Commissioner Ahearne Comissioner Roberts Comissioner Asselstine FROM: William J.-Dircks .
. Executive Director for Operations -
SUBJECT:
COMPLETION OF THI-1 RESTART REVIEW The recent staff review which was the subject of my memorandum to the Commission of May 19 1983, concluded that the issues raised by the Hartman allegations should not by themselves prevent restart of TMI-1. Further, the staff concluded that, due to'the open issues which..have been identified are which were not considered in the revalidation program, the staff can draw no conclusion regarding management integrity as it impacts on restart at this time. Therefore, the staff has initiated actions which will enab.1'e it to reach a current position on restart.
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These actions will include completion of the review of the B&W-GPU lawsuit documents. The review conducted to date confims conclusions reached in the-report of the previous review of the trial court record dated March 28, 1983' ,
that the documents do not contain significant new information which affects the agency's understanding of the TMI ,2 accidant, including the sequence of events. The review has, however, identified information with a potential bearing upon management integrity.
~ '
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.l
! In order to consolidate censideration of this issue within our normal I
licensing review process, I would like to have NRR ccmplete the review of the B&W-Gpu lawsuit documents which consist of (1) the trial transcripts and exhibits admitted into evidence, (2) exhibits used during the trial or identified by either party for possible use during the trial but not admitted
~
into evidence, and (3) the depositions taken in preparation for the trial as well as the exhibits used in taking the depositions. 1/ To assure a smooth transition in this effort, I will make available, for a short period on a detail basis, those staff members who had been assisting Mr. Stello in the review. ..
In addition, as the examination of the issues and documents identified in my May 19 memerandum produces conclusions and recommendations, I will also look to NRR to integrate them in an overall staff conclusion on management integrity.
s 1/ The Staff is also aware of thousands of other documents possessed by the parties to the B&W-GpU lawsuit. However, we are proposing to limit our review to the above B&W-GPU lawsuit document:. We believe these documents are representat'ive and will reasonably identify all safety issues. This is because of the substantial effort undertaken by the parties to prepare the documents in an adversarial process which provided significant incentives for the parties to be exhaustive in their preparation. Obviously more information might .
be available from other documents, but frcm a cost benefit view, we believe our approach is reasonable.
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It appears that a sensible way to approach the review of the B&W-GPU
-lawsuit documents and the ~ cther matters in my May 19, 1983 memorandum is to focus our imediate attention on basic safety matters. 2,/ .Specifically:
is there any new informatiord/ contained in the B&W-GPU lawsuit 4 documents and other documents possessed by NRC such as the Beta and RHR reports, and any other information developed by the ongoing investigations which is material to the resolution of: (i) the questions
/ raised by the Comission in its August 9,1979 order (10 NRC 141) commencing the restart proceeding;-(ii) the additional questions raised by the Comission in its subsequent order of March 6,1980 providing further. guidance to the Licensing Board regarding the management competency issues (11 NRC 408); (iii) the specific _ contentions relating to these issues raised by the parties in the restart proceeding; and (iv) the issues . raised by the Licensing Board in its reopened proceeding on the question of cheating. If so, such information should be identified and evaluated as to whether any actions should be required before restart. _.
~
With regard to the specific issue of management integrity, there are.at lelst two approaches. One is to defer restart until a review and investigation of the impacted individuals is ccmpleted. 'The other approach is to separate out the corporate institution from corporate employees. We redommend the latter approach which divides the issue into two parts. (1)thecorporate i institution, i.e., the stated policier and procedures of the corporate .
! institution and (2) the individuals, i.e., past performance and current
- ~
l competence of the individuals responsible for implementing the corporate .'.'
i ~
2/ The purpose of this review is to resolve the restart issue and not r
! to prepare the NRC defense to the GPU v. NRC lawsuit. The Staff
! will in the review be alert to wheth - nere is any new information that causes a f'Jndamental change to o understanding of the ca'ise
! cf the accident.
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3/ "New infomation" here refers to infcrmation not in the record developed .
by the Licensing Board.
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pelicies and procedures. Absent new information, we do not believe it is advisable to expend time and resources to re-examine the stated policies of the corporate institution. This area, as well as the GPU organizational
-structure, has been reviewed by the staff and found to be acceptable. The competence of the manageinent employees have also been found acceptable. . .
Therefore, we would focus our attention upon the past performance of ~
individuals identified by the various allegations, reviews and ,
investigations.
If we focus our attention,on individuals, we could proceed on a schedule separate from the restart h cision schedule, provided that certain of the individuals are temporarily removed from safety related activity at TMI-1, ,
aLsent a satisfactory demonstration by licensee that one or more of those individuals may be retained for an interim period while they are under investigation. As reflected in the attached organizational plan for TMI-1, we are dealing with a finite number of individus1s who~were involved at TMI-2. Specifically we would review the assignments of these individuals on a case-by-ca:e basis and propose reassignments as deemed necessary; we would I assure that where an individual is. removed, his replacement possesses 'the
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required qualifications for the position.
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As for past actions of those individuals, we would carry on the various investigations and the review of documents and again, on a case-by-case basis as a conclusion is reached, either authorize return of the individual to his prior assignment position or take'whatever enforcement action deemed necessa ry. It may be that as we proceed down this path the number of individuals and pos. cions involved and the actions taken will cause us to reevaluate this approach to dealing with management integrity. Restart of the plant would not foreclose us from taking appropriate enforcement action at that time.
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Our reccmmenda?. ions then are as follows: -. __
consolidate review of' restart. in NRR ir cluding the review of the B&W-GPU lawsuit documents.
on the issue of management integrity:
review assignments cf individua.ls to TMI-1, direct reassignments as necessary, and review competence of replacements, if not already done, prior to restart; '~~r-separate the issue of the past performance of individuals frcm the issue of the corporate institution, at least initially, and focus.a,ttention on individuals as an enforcement matter on a schedule separate frcm restart.
_ . . _ . ._...m ._ . . _ _ _ , _ _ . , _ _
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If these recc ceendations are' acceptable, .the Staff will provide the Comission an estimate of the schedules and resources necessary to complete them. The staff believes that the,above actions will provide all the information necessary for it 'to provide th'a Comission its position on restart.
/
T William J. Dircks Executive Director for Operations
Attachment:
TMI-1 Organiza_ tion CC- SECY
-OPE OGC e
i I
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- :*- a/25/E2 -
?:sition In u ':er.t- P:siti:n - 3/22/79 President - GPU Nuclear '
Robert C. Arnold Vice President - Generation GPU Service Corp., Parsippany Executive VP, GPUNC Phil' R. C1 ark New . , ,
~
Chairman, GURB -I. R. Finfrock . Jersey Central IVP, Oyster Creek P. B. . Fiedl er - New lVP, TMI-l .
H.-D. Hukill New
- YP, Technical Functions R. F. Wilson Director, Tech. Functions, GP C. Service Corp., Generation Div lVP, Nuclear Assurance R. L. Long --
Manager, Generadon Productiv ity, GPU Service Corp.,
Generation Div.
- VP, idministration -
P. R. Cla k (' Acting) New .
!VP, Communications W. L. Gifford New VP, Radiation and . R. W. Heward Manager, Projects, GPU Environmental Controis ,
Service Corp. , Generation Div
~
iVP, Maintenance and F. F. Manganaro New
~
Conjtruction _ . ., _
, ,, 3
~
Manager, Plant Administration, P. G. 'Christman lianager, Generation Admin.,
TMI-l Met-Ed, Reading
- Director, Operations and .
P.aintenance, THI-1 R. J. Toole Unit Superintendent, Mcmer City (fossil), Pennelec Director, Plant Engineering, J. J. Colitz Director, Generation Projects
. TMI-l Engineering, Meted, Reading L.
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3
. Position . Incumbent Pcsition - 3/23/79 f.an'a;cr, Fians and Pr:grais, R. P. Acamiak. New TMI-1 Mana gar, Plant Chemistry E. C. Fuhrer Engineer, Radiation Protectib T?.I-l ' - Reports to . & Chemistry, TMI-]
Director, Ops. & Maint.
M: nager, Plant Operations M. J. Ross -Supervisor of Operations,
',TMI Reports to TMI-1 Director, Ops. & Maint.
Managar, Plant Maintenance D. M. Shoviin -
Superinten' dent of Maintenance TMI Reports to -TMI Directer, Ops. & Ma' int. -
Administrative & Technical R. S. Harbin Tech. Analyst, TMI-1 Support, TMI Reports to Directer, Ops, & Maint. .
Scpervisor, Plant Review - Max Nelson New Group, TMI Reports -
to Director, Ops. & Maint.
?lant Engineering Directorate
__Di rector : J.J: Colitz - TMI-1 Lead Michanical Engineer -
R. D. Parl eq' Lead Mechtnical Engr. , TMI-1 Lead Nuclear Engineer W. S. Wilkersen' Nuclear Engineer, TMI-1 -
Lead Electrical Engineer -
C. Hartmtn .
Lead Electrical _ (ngr. , TMI'-1 Lead IEC Engineer V. P. Orlandi IEC Engineert, TM(-1 Technical Analyst - T. A. O'.Cor.nor Plant Fire Prote"ction -
Fire Protection Tech. Analyst '
Sp:cial Project Engineer P. P. Karish Enginear - Mat-Ed - Reading Supervisor - Chemistry J. G. Reed Chemistry Foreman, TMI-1 4
l
rp 3 .
7._
'Jesition incumbent ?:sitien - 3/26/79 .
V? &-Dire:t:r - Radiological .
1 Envir: .msnt C:ntrois '
R . 'n' . Msward - GPUNC. .
Manager,- Radiological G. A. Xuehn New Controls,~TMI-1 Rad. Engineering Mgr. R. Shaw tiew
. THI-1
- Rad. Fiel d Ops. Mgr'. D. E. Tuttl e New .
TMI-1 Administrator, Rad. Dolores Simmons Desimetry Clerk - Rad. Con.,
Controls, TMI-l Units 1 & 2 .
V?, Nuclear Assurance s R.L. Lc..c - G?UNC -
Director, Quality Assurance N. C. Kazanas Mgr., Quality Assurance, G?U Sve. Corp., Gen. Div.
~
Director, Training & Ed. R. Coe New Mana'ger, TMI QA Blaine Ballard New Modi fications/ Operations,
~
Nuclear Safety R. N. Whitesel
- New Assessment Director .,
Mar.ager, Emergency Prep. R. E. ?.o p n -
- New y_ v.
V? L Direc:cr Iechnical .
Functions R . F. 'r.'i i s c n - G P UN C Chairm'an, THI Generation W. F. Schamaiss ,
El e t. Power & Instru=entatier F.eview Ccamittee Mgr. , G?U Sve. Corp. , Gen. Di
~
Mgr. , Engineering Sycs. C. A. Mascari Engr. - G?U Sve. (Forked ?,ivs ,
Dire: tor, Licensing &
- J. R. Thorpe Mgr., Environmental Affairs, F.eguia: cry Affairs G?U Sve. Corp. , Gen. Div.
.+- . . , .
.Pesition ., Incumbent Position -3/25/79 ,
- Cire
- or, Engineering D. K. Croneberger Mgr. , Er.gineering & Desi gn, L Design DPU Sve. Corp. , Gen. Div.
Director, -Systems T. G. Ercughton Control & Safety Analysis Encineering Mgr. , GPU Sve. , Gen. Div.
~ ~
Director, Engineering R. W. Xecton ' Mgr. , Systems Engineering, Projects GPU Sve. Corp. , Gen. Div.
' Director, Startup & Test J. T. Carroll.. Dyster Creek i 1
lVP & Director - Administration .
i i
P.R. Clark ( Actino) - GPUNC -
i L
l Director,- Fiscal Info. Mgmt. S. E. Fisher Ne0 Director,MaterialsMgmt.71, Herfel New
~
Director, Human Resources T. L. Myers --
New --
("ow rots directly to !
Office of the President)
Director, Security, Facili- R. Russo - Administration Divisien ties, Industrial Safety &
- GPU Sve. Corp. , Gen. Div.
Health .
\
VP & Director - Radilogical -
& Envircamental Controls R. U. Hewa rd GPUNC - . .
...g L Manager, TMI-l Radiological G. A. Kuehn New -
i
.Centrols * .
,' j Director, TMI-2 Radiological J. E. Hildebrand New -
Controls .
1 TMI Radiological Assessment W. C. Craft New Oyster Creek Rad. Assess. C. A. Pollard New - -
l Mar.ager, Oyster Creek D. W. Turner --
i i Rac. Controls Mgr., Env. Controls H. B. Roche Jersey Central '
~
Corp. Rad. ' Engineering T. D. Murphey New
, D. H. Reppert GPU Licensing, Parsippany l c -
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_ . _ _ _ .. _ _ :_ _ -. - _.--- 1 3 - :.
"Iosition' ince bent Positi:n - 3/25/7g '
V? & Oirectcr Maintenance
& : Cor.s tru:: ion , ,
F.F'.Mancanaro. GPUNC
$&CDirector,TMI-1 S. Levin (Acting) Forked River Mgr., M&C Planning G.:J. Treffer Mgr. , Generation QA.
GPU Svt. Corp. , Gen. Div. 1 MSC ?rocuction Director ~ S. Levin --
Forked River Mgr., MEC Methods & Proced.- A. Laird (Hg.) New Unfilled (Island) --
M&C Admin. Support Mgr. D. H. Campbell New
~
Shift Supervisors (SRO) ~~
L. G. Noll ,, Unit 1 SF w/SRO-1 D. I. Smith Unit 1 CR0 w/RO-1 B. A. Mehler Units 1 & 2 SS w/SRO-1 & 2
_ D. C. Janes . Unit 1 S.: w/SRO-1 P.. E. Soye.r Unit 1 CP.0 w/RO-1
', T. L. Crouse Unit 1 SF w/SRO-1 shift .orecen (SRO) D. A. Smith Unit 1 CP.0 - In trng for 20-H. K. Olive New G. M. Davis Hzw J. C. Herman ~ Unit i CR0 w/o license W. A. Fraser Unit 1 CEO w/o license S. K. Martin New S. W. Str ntl ey -(RO) -
Unit 1 CR0 w/?,0-1, Centrcl Room Operators (R.0) Ms. D. J. Xell er Unit 1 A0-A J. L.* Masters Unit 1 CR0 w/RO-1 D. D. Kayhue Unit 1 CR0 w/o license M. E. Wynne New R. S. Campbell Unit 1 A0-3 N. J. Mo'nson Unit 1 A0-A
. F. Chalecki Unit 1 CR0 w/RO-1 P., A. Heilman Unit 1 CR0 w/RO-1 J. R. Gallagher
- New T. H. Goodlavage Unit 1 CR0 w/RO-1 .
G. J. Sixier Unit 2 A0-C
-y ; .. .
o?csition, Incumbent 7:sition - 3/2E/79 ic.. r:1 R::m Operators'(cont'd)
M. P. Kendig 1/ Unit 1 CEO w/o license .
M. 3. Bezilla Unit 2 PORC Secretary J. E. Moore New D. Hass New.
M. D. Willenbecher Unit 1 A0-C .
R. C. Eugelholl New 5
R. J. Lane 2 New R. H. Maag _/ N'"
D. T. Niland 2/. New D. .J. Treadway 37 New .
J. W. Randisi 47 Unit 1 AO-A 1/ Kandig is being moved to QA. License will lapse. -
T/ Maag and Niland have passed their license exams, but have not yet been cleared medically. >
3/ Treadway has to retake the simulator exam.
T/ - Randisi failed the~ 0:tober 1932 RO exam - futu:e in doubt.
Shift Technical Advisors H. C. Crawford - SP,0-1 Unit 1. Plant Eng.
J. R. Paul es - SEO-1 Unit 2 Plant Eng.
W. S. Stanl ey - SRO-1 ,
Meted Licensing - Reading K. Markless Forked' River L. Walter Meted Transmission Dept. , Rc
. W. McSorley New Replacene ,t STAS in Training' W. Burton New -
J. Stair .
Meted Lic.ensing - Reading SR0s Not 'on Shift .
Unit 1 Supervisor of -
-=
Operations M. J. Ross Supervisor of Opera tions , Tlt Unit 1 Primary Plant Eng. H. B.' Shipman Operations Engr., TMI '
tianager, Radaaste Op., TliI-1 W. H. Zewe Shift Supervisor, Units 1 & :
Training Dept. C. E. Husted Unit 1 Training Dept., w/20
- Emergency Planning N. D. Brown Unit 1 Training Dept., w/SRO.
(3rewn's license will lapse) ,
e e
e
/
___._m
~
- resi. tion Ince. bent F sition - 3/2E/7c
?.Os ::: cr. Shi ft 5. J. Kacinko Unit 1 AD-C D L. Wi1 *- it..
..s i no-n, N:to: = Auxiliary Operator in traininc A0
,e
,C' ..
n .e- s = s,ux111ary Operator - trained A0-A
= Auxiliary Operator - fully qualified
. mm *
. -w E,*
4-d
m_
~-
~
February 24,1984 MEMORANDUM FOR: Thomas T. Martin, Director, Division of_ Engineering _and Technical Program -
THRU: Lee H. Bettenhausen, Chief, Test Programs Section, EPB, DETP FROM: Jin W. Chung, Lead Reactcr Engineer, TPS, EPB, DETP
SUBJECT:
REVISION TO INSPECTION REPORT 50-289/83-20, REACTOR COOLANT SYSTEM LEAK RATE TESTS AT TMI-1 Subsequent to the original subject inspection report, additional information became available and additional analyses and reanalyses were performed. It became evident that a revision to the report was needed. Comments by others and an independent review by D.C. Kirkpatrick of NRC/0IE were incorporated into this revision. Report pages incorporating revisions, with the revised information indicated by markings in the right-hand margins, are attached.
These are identified in Table A, Summary of Revisions.
The principle areas requiring reanalysis were timing of charts and understand-ing of computer data handling. A major difficulty in reconstructing the sequence of an event during the RCS leak rate testing was accurate timing of the Makeup Tank (MUT) level recorder chart. The statistical method employed in the original report was found to be inaccurate in many instances. More accurate correlations were developed between the recorded events in the logs and the MUT chart traces. Additional document reviews were conducted, including an onsite review on February 8,1984, of the TMI-1 computer log entries for the software and hardware modification of the RCS Leak Rate Test Program.
Based on the additional information, the leak rate data were reanalyzed more conservatively to incorporate factors such as variations associated with the system perturbations and instrument errors. Also, the rates of the MUT level changes and the recorded water additions, before and after the tests, were considered in order to validate the leak rate results.
The additional findings and revisions are attached.
h
[/
d in W. Chun '
/LeadReac r E gineer Attachments: (_ _
Revised pages to 50-289/83-20
- M 6l3 4if
,. - c.
TABLE A
~
SUMMARY
OF REVISIONS j PaSe Changes 5 Revised
!- 6 Changed from page 5 Revision 7 Revised 7A Added (Summary Table) 7B Added (Summary Table) 7C Added (Summary Table) 70 Added (Summary Table) l 7E Added (Summary Table) 12 Revised 13 Revised (Table 1) 14 Revised 15 Revised (Table 2) 16 Revised 20 Revised 26 Revised 32 Revised 36 Revised (Table 6) 38 Revised 39 Revised (Tab.le 7) 40 Revised e
L 2
m.
O een S
REVISED PAGES TO 289/83-20
r - ,
! 5 l
EXECUTIVE
SUMMARY
08JECTIVES -
! The basic objective of this inspection was to verify that records of Reactor l Coolant System (RCS)-leak rate testing at Three Mile Island (TMI) Unit 1, from I the period April 1, 1978, to March 31, 1979, showed no indications of practices similiar to alleged irregularities at Unit 2. The allegations related to Unit '
l 2 RCS leak rate testing involved the following:
That tests were often repeated until the results met the acceptance criteria and that unfavorable results were discarded; That RCS water inventory was adjusted contrary to procedural requirements; in that water additions were made and not recorded in the test package nor included in the RCS leak rate test calculations; That computer data entries for the leak rate calculations were " fudged" to make the leak rate test calculations appear acceptable; and, l
That hydrogen gas was added to the Make-Up Tank (MUT) to influence leak rate test calculations.
Supplemental objectives of the inspection were to:
s Examine compliance with the Technical Specifications on RCS Leak Rate; Inspect the leakage test procedure for technical and functional adequacy; and, Examine the effects of instrument calibration and variations on leak rate determinations.
CON 00CT OF INSPECTION From July 11, 1983 to September 9,1983, members of the engineering staff of i Region I conducted an inspection of TMI-1 records, procedures, equipment and i specifications related to reactor coolant system leak rate testing performed by ,
station personnel in the year immediately preceding the accident at TMI-2. The inspectors reviewed and correlated diverse records related to leak rate tests, performed an "as-built" walkdown of related plant systems and instrumentation, and, in conjunction with licensee personnel, demonstrated by system operation -
a technique by which RCS leak rate results could be modified. -
Additional information was obtained subsequent to September 9,1983. This f information and previously obtained information has been extensively reanalyzed R1 !
by the staff. This led to revision of the inspection report. Revised l information is annotated by R1 in the right hand margin. ,
l t
l f
6 i
' Surveillance records for RCS leak rate tests were reviewed for the period from April 1, 1978 through March 31, 1979. Six hundred and forty-five tesc records were the principal object of this review. These surveillance records were com- _
pared with control room logs, power traces and makeup tank level recorder charts developed during the tests to determine abnormal test operations, adequacy of records and compliance with test procedures. The station surveill-ance test procedure in effect at that time was evaluated for completeness and adequacy. Independent leak rate calculations were performed by the NRC staff with an NRC microcomputer and compared with TMI-1 data to verify the validity of licensee calculations.
The inspector performed a walkdown inspection of the makeup system and verified that the instrumentation system for measuring makeup tank (MUT) level contained i a loop seal. The significance of this loop seal is that hydrogen additions j made to the MUT during a test could result in errors in RCS leak rate test i calculations. Further, a review of plant maintenance records for 1978 identi-
! fled narrative which described the effects of gas additions on indicated Make-Up Tank (MUT) level.
The MUT strip chart recorder traces were independently analyzed and evaluated by the inspectors to identify instances of improper performance of RCS leak rate tests, such as the addition of hydrogen or water during the performance of the leak rate test. Strip chart data were compared with control room logs and surveillance test calculations to determine if test conditions as indicated by the strip chart were incorporated, or considered, in the calculation of leak rate. Further, the inspectors directed and monitored an actual demonstration of the effects of gas additions to the MUT at Unit 1 on indicated MUT level to support their conclusions. Licensee personnel assisted in this. demonstration and acknowledged the resulting conclusions.
MAJOR FINDINGS The RCS leak rate tests performed at TMI-1 during the year prior to the acci-dent at TMI-2 contained several inadequacies and deviations from procedural l and regulatory requirements. These would, in most instances, have lead to a less conservative calculation of RCS leakage rates.
- a. The RCS leak rate procedure, SP 1.103-1.1, Rev. 7, in use during the time period reviewed, was inadequate because: i o it contained incorrect procedural steps (53.3);
o it did not prohibit acceptance of test results showing negative 1eakage ($2.3); [
o it failed to incorporate temperature compensation for several leak rate facturs ($3.3);
i o it omitted several important factors; such as, no provisions to ;
include steam generator tube leakage as identified leakage or the '
effects of pressure variation in the RCS (53.3); and, o it utilized incorrect values for volume and water mass change per unit level change (53.3). t l
7
- b. The as-built configuration of the MUT level instrument system provided a loop seal on the low pressure reference leg, which introduced the poten-tial for non-conservative effects on RCS leak rate test results fron -
MUT gas additions. During discussions with station operating personnel, the inspectors were informed there was no loop seal in the makeup tank level instrument system. An NRC walkdown revealed the loop, which pro-vides a means to affect leakage calculations (54.3.1). ,
- c. An analysis of MUT level strip charts for the period inspected indicated R1 at least eleven hydrogen additions were made during RCS leak rate tests.
There were no entries in the control room logs which recorded the fact that these gas additions were made nor were they compensated for in the leak rate calculations. The calculated leak rates, therefore, were in error. Actual leakages were, in fact, higher than the recorded values (54.3.3).
- d. Thirteen instances of apparent water addition to the RCS during leak rate tests were identified. In only one test was the water addition accounted R1 for in the calculations; and, in that case, the volume accounted for was considerably less than the apparent actual addition. These unaccounted additions resulted in recorded leakage values lower than actual leakages (65.2).
- e. Thirteen instances of apparent feed and bleed operations during testing were identified, for which the leak rate calculation was not properly R1 corrected for the operator-caused water inventory change (92.3),
- f. One instance of a combined hydrogen addition, water addition and feed and R1 bleed operation was found (54.3.3). R1
- g. A number of instances of substantial apparent level changes in the Reactor Coolant Drain Tank during leak rate tests were identified. No logbook entries which would explain these level changes were found. (56.2)
- h. The Itcensee established a conservative administrative test frequency for RCS leak rate testing of once per shift, whereas, technical specification required only daily testing. Fifteen missing test records were iden- R1 tified ($2.3).
CONCLUSION Eleven instances of hydrogen addition, 13 instances of water addition, R1 13 instances of feed and bleed and one instance of combined feed, bleed, R1 hydrogen and water addition were identified in a population of six hundred and forty five test records eramined. These inventory changes or additions R1 gj af fected MUT level and were not properly incorporated into the RCS leak rate calculations. The instances were limited to performance by only a few R1 individuals. Recalculation using best available information showed that, R1 except for four instances, Technical Specifications would have been met, gj gj
7A
SUMMARY
TABLE R1 0F R1 APPARENT IRREGULARITIES R1 OURING RCS LEAK RATE TESTING R1 R1 (added as a result of Revision 1 to R1 Inspection Report 50-289/83-20) R1
78 .
Samosaf 0F APPAafhT leAEGia,ARITIES BWRImE SC5 LEM MTE TESTIts at leefte AsetTi m spansarm al i--. autauutu EE um/3F LW 3IgfN1Figg LgM MWJW g C10cr TI4 GM&mi/T18( M -.- -
_ euw -
_ess 04/M/78 1532/1632 165/1138 as as -
-1.0548 EI (sali *1.3*;asevel -2*) 1.9248 -
04/30/78 2321/0021 60/2335 as as -
-0.9717 9.4044 (e5/01/7e) (eari et" ; memal -1.5*)
05/R3/78 1822/1922 F84 (60 gel) ne se 'I
-0.7654 4.6142 (eeff *I.7*;asemel -2*)
- 05/07/74 /14M as serveillence deta -0.9933 05/12/78 0047/0147 FAS (60/0125) as yes --
-8.3764 1.0000 at (sali *1.4*;aemel -3*)
- 05/12/78 1643/1743 180/1732 me yes -
-0.7443 S.6337 laRR +6*; assuel -1" ) (M/1745) ~
05/13/76 2340/0040 Faa (se effect) as as -
(45/14/78) 0.5882(tava114 test) al 05/21/78 /1025 as servet11ence data 0.0468 05/26/78 1656/1756 SS/lF53(jegged) ne as (sali +0.4*;aeraal -3*)
h.7514 1.4498 al
- 06/0s/78 /0530 as survettlence dets '
8.5412 06/11/78 0804/0904 fat as yes -
0.5a26(ineelld test) 06/21/78 8341/0441 30/9418.96/0425 as yes #3 (een -6*; a si -11")
0.9421 1.6M1 h0TE # : suspected te ne alsflied, at
- SCST eralmed ; 165 gel. 9 5798F '
l a
7C
- leATEa AESITles IIISMEta Ef1E C10cr TIT suuuuts IE ue/J LW M telefsfflFits LEAt: RBIEAII al EM lantTleE M t==== M - _, ves -
ves 67/cgr/73 02M/03M as yes al 784JI590/03IO) -
0.7266(lavelidtest) fsed100/9340) (fM;1950/8345)
C7/04/78 /2245 as surveillance data 0.9967 al 87/14/78 /n334 as sorwillance data -4.8771 e4/04/78 0735/0635 as as as 2"/8754 -0.1999 8.2M1 (1.5" decayed; 8.5" effective) at 04/19/73 /1450 ne serveillance data -0.2300 7 44/29/78 1547/1647 248/1544 ( les ne -
-0.0673 0.2767 (lefT+0.3*;mermel-1* : 15 gel, effective) 08/30/78 1952/2052 as ao se 1*/1952 0.1023 0.3775 al (0.6* asecayed; 8.4* effective) 08/31/78 0401/0901 as as no 1.5"/0020 -0.4141 S.6179 (leff +1.3* ; mermal -l") ,
al 09/63/78 /1138 se survet11ance data 0.9667 09/04/73 1629/1729 60/1705 se no -
-0.5423 II (fert +1.3*;aermal -I*) 0.7937 09/11/78 1625/1925 60/1840 54(Jegged) ao no -
-0.5462 (self *2.6*;asemel -Z*) 0.7006 ,g 09/15/78 OS21/1023 45/le:0-26(jeggeO ne -
-4.5503 (8 tit +0.3*;aermal -1*[ as 0.4417 gy 1 : aguestianeable 8 I
7D Ie47Es AA9fT998 NE L -s MIE QDCI TIM MIfE suuustu E uus/5F LW N M MlWWFif tig LEM MW,9W '
tmus M -
vsp f ,was 09/17/78 0504/0604 FM(100/0515-57) as ao - a1 (noeffect!) S.7745(fevetid test) 1 09/18/73 2035/2136 45/2100(jogged) as as -
-0.4265 S.6055 en/lant 2355/0055 ne me me 2*/ases (09/19/73) -o.5ars o.7937 0S/22/78 2100/2290 (st!T *l.3*;aems) -1*)
FM ao se -
10/C2178 1645/1745
-4.0373(levelld test) se ne no 2*/1720 -0.8293 0.3147 10/17/73 1201/1301 64/1240-1303(jeggedlee (1.5"dec4yed;e.5*effecties) ne -
-0.4541 8.9179 y 11/05/78 /1955 ca
/1950 se servet11ance data 0.3395 R1 11/07/73 16G4/1704 no me me 2*/1653 0.0445 3.3197
{1.6* decayed; 8.4* effective)
- 11/10/78 /1125 se servestlance data 0.5374 .
11/12/78 0416/0916 ne no me 2*/0003 -0.1954 8.4926 (stil +0.8";aemel -0.5*: l' eif'ecttwe) 11/13/7a a304/0404 Fas(30/c356) al me ne (mi +a.4*; memel -o.7*)
-e.5507 e.1373 11/16/78 0426/0526 Faa . as me - *
(leff +1.S"; memel -8.2*) 0.6059(tavalletest) 11/24/74 2114/2214 ' FM ne ne - i 11/21/78 62e6/83e6 S.8772(invalidtest)
Fas(98 gel) ao se - R1
-8.54?S(lavalid test)
I
7E . .
IIATER AeSlilm INEAests al u .. swuusas IE ue/5F LE M telefartlFIED LEM e4TEAll eATE nort YtME GELM/ilft N teen W -
_ i.vts -
. Lits al 11/24/74 1653/1853 FA4(2es/1728-M) as ne - -4.3462(invelld test) 12/11/78 0432 ne surwetilence data -e.8118 al
" 12/13/78 1842/1942 2M/1920 me" yes - -4.21M e.1417 (st:T +4.3*; seruel -1*)
12/la/7a Daas/es30 as as me /esM(b ) s.522e ai l (aseffecti) 01/0079 07M/11M 400/0023;120f84/1814 300 gel. yes /8937./0940 -0.5944 0.44e6 RI (no effect) 41/04/79 /0600 na servet11ance data e.4442
. /0604 at
! S1/09/79 19M/2SM FAS( M gal) as as -
-0.2901 3.3330 l (sestet *1assen)-1*)
81/11/79 1606/1706 as as as 2*/17M -e.6163 e.7537 i * .
' Al c1/14/79 oes1/ shot so/045sueseed) as as -
-e.stM s.6ste (sair +1.1*;neemst -1*)
cl/lai7s /13ne as servet11ance esta si e.e7ee 41/26/79 ftC32 as servet11ance data
-e.49AS j s1/2S/79 /0310 se serwet11ance esta -e.3124 i
l e2/s2179 1648/1700 se as se 2*/1614.162e 0.32s7 -
e.6727 (1.5" escaped; 4.5" ef fecttwe) 02/83/79 1615/1715 no as no 2*/1623 0.4692 0.8132 (4.5*effecttwe) 02/12/79 /223e ne serwet11asce data -0.5000 i
- : RCST draleed ; 360 gal. e 579"F ~
12 The surveillance records from the period of July 8,1978 to August 4, 1978 were not reviewed due to missing MUT recorder traces. Thus, 69 surveillance test records could not be reviewed. Therefore, 645 -
surveillance test records were reviewed against MUT recorder traces and other data, such as daily logs and computer listings.
The licensee had established a conservative administrative test frequency of once per shift. Tests were often performed once per shift, whereas Technical Specification required a daily test.
The total number of days covered by surveillance record was 290 days, during which the following tests were completed:
No. Tests Performed Per Day No. Days .
1 Oaily) 27 2 Twice Daily) 114 l
3 Each Shif t) or more 149 Major findings from the record review are:
Some of the tests noted in the CR0 and SRO shift logs were missing in the surveillance files. These surveillance records were either never created, lost, discarded or misfiled. Two test records were found filed out of normal sequence and six at l were found misfiled. Fifteen missing test records have been identified. They are listed in Table 1.
l The surveillance test records frequently showed negative leak i
rate results. Two months of leak rate test data were reviewed to identify examples of test records demonstrating negative l 1eakage. The following summarizes the results of that review:
1 May. 1978 June. 1978 May + June 1978 ,
Total Test Records Reviewed 60 61 121 l
Number Test Records Demonstratino
~
l Ni3ative Leakage Rate Results Leakage Plus Losses 10 4 14 I !
l Gross Leak Rate 20 16 36 Unidentified Leak Rate 28 20 48 {
l l
13 TABLE 1 .
Lost, Misfiled. Olscarded or Never Created RCS Leak Rate Test Records M. DATE TIME R1 1 5-07-78 1436 2 5-21-78 1025 .
3 6-06-78 0530 4 7-04-78 2245 5 7-10-78 RI 0338 6 8-19-78 1450 7 9-03-78 1247 8 11-05-78 1955 9 11-10 78 1125 10 12-11-78 0432 11 01-08-79 0600 Al 12 01-18-79 RI 1310 13 01-26-79 0032 14 01-29-79 0310 '
15 02-12-79 2230 R1 l
r d
I 6
}
- w. _ _ _ _ _ _ - . - _ _ _ - - _ _ _ _ _ _ . --_--_---__-______-_:
14 Almost 40% (48 out of 121) of the calculated and recorded unidentified leak rates during the two month period had negative values. _
~
The RCS leak test procedure, SP 1303-1.1, recommended water additions such as Feed-and-Bleed (F&B) operations be avoided during the test. The inspector identified at least 13 tests, during which F&B operations appeared to have taken place; and R1 in each case, the change in water inventory was not properly compensated for by the operator in the computer calculations of RCS leakage rates. They are identified in Table 2.
These record review findings are indicative of the failure of the ifcensee to comply with regulatory and procedural requirements for "
record-keeping and test performance.
m . .
Table 2 Apparent Uncompensated Feed & Bleed Operations Durtog SC5 Leak Sete Testing IIATIB A80fTIGI IllSMSEE
_ --a IKLuute IE us/5F LW M tellefuitflge LEAK OATE.GFH SATE CLOCK TIE GALLWl/118E M tuguy M N _ Tuty -
- A stW -
i 05/03/78 1822/1922
- F88 (60 gal) ne se -
-0.7658 8.6102 al (seJT +1.7*;neraal -2") '
05/12/78 4
0047/0147 F&s (60/0125) ne yes (seli +1.4*; normal -3*)
-0.3760 1.0000
{ 05/13/78 2340/0040 Fa8 (no effect) , ne ne j
0.5482(tavalidtest) at (05/14/78) , E1
! 06711/78 0004/0904 Ina ne yes -
0.5426(invalid testi j
i 07/02/78 0256/0356 FM l1590/0310p me yes -
0.7766(invelldtest) et FA8 100/0340J (F88;1950/0345) -
i m
09/17/78 0504/060s ' FM(100/0515-57) ne -
ne -
8 (noeffact?) .
0.7745(lavelidtest)
I R1 09/22/78 2100/2200 FAS no no -0.0373(tavalid test) 11/13/7s 4304/0404 Fas(30/0356) ne ne -
0.5507 0.1373 (ftlT +0.4*; normel,-0.7*)
11/15/78 G426/0526 F48 . no no -
(ItlT+1.8*; normal-0.2*) 0.6059(inval1d test) 11/20/78 2110/2210 F&R no i ne -
0.8772(invalid test) 11/21/7s a206/0306 Fa8(!3 gal) ne ne -
-4.5078(invalid test) 8' 11/28/78 1663/1863 F48(200/1720-50) no me -
-0.3462(tavelldtest)
) 01/09/79 1936/2036 F40(
(IslT+1,30 gal) ne no i
t ; norm.1-1*) ..
0.2901 0.3099 i
3 R{
I
n =
e .
16 I
I 3.0 Reactor Coolant System (RCS) Leak Rate 3.1 Background -
The TMI Unit 1 Technical Specifications,' paragraph 3.1.6 and Table
! 4.1-2, required that RCS leakages be determined at least once per day
' during steady state operations, and that the leakage plus-losses, total gross leakage and unidentified leakages be maintained within their respective limits of 30 Gallons-Per-Minute (GPM), 10 GPM and t
1 GPM. The TMI-1 Final Safety Analysis Report (FSAR), Section
! 4.2.3.8.a. specified that the leakages were measured by counting i
water inventory changes within the RCS pressure boundary for a fixed time interval, f
The test procedure included a precaution to avoid addition or removal of water and chemicals from the RCS. The procedure also recommended that, for the most accurate leak rate determination, the initial and final values of power, RCS temperature, RCS pressure and pressurizer level should be maintained identical.
The procedure specified a test duration of one to eight hours, and J specified the plant computer as the favored tool for performing test calculations. Hand calculations were allowed as a backup when the l computer was not ava11ab'3 There was only one record of a hand cal-culation during the one year period from April, 1978 thru March, 1979.
Upon initiation of a computer calculation, data was taken automatically from hard wired, pre-designated computer points. Manual actions required by the computer method were input specifications such as test time interval (normally one hour), any identified R1 leakages and the operator actions of make-up water additions and RCOT pumping. RCS leak rate calculations were automatically done by the computer when the above steps were completed. For hand calculations, the preferred data source was defined to be DVM readings from a patch panel rather than data obtained from control room indicators, due to the inherent inaccuracies in the latter readings.
The procedure also specified a set of corrective steps to be taken
! when the RCS leakages were in excess of the requirements. The first
' step was to perform another leak rate determination, followed by careful examination of the operator actions affecting the water inventory. The final step was to initiate action to determine the source of the leakage, and then to proceed with the ACTION statements specified in Technical Specification 3.1.6, which required placing the reactor in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection of excessive leakage.
I l
lb . - ,_w
TMI-l RCS LEAK RATE CALC. _(pre-April 1979) .
1303-1.1 Rev. 7, 5-25-76 '
1 CONTINUE ,
I t INPUT:AV. (WATER ADDITION rcs CAUSED BY OPERATOR) o PROCEDURE STATED LEAK RATE FOR RCS PLUS LOSSES T E E CRITERIA:
30 gpm
" (dVrcs + AVrcs)/At E$
1 ** **
j 2 i 4
W cdt " ((2rcdt) initial - (Zredt) final)
- CF3 CF3 = 3540 lbs/ volt
- Z rc,
- 1el R1 9T rcdt " ATcdt
- CF dig. DELETED nadings y ento . , . , . . . . , . . .- R1 i , r INPUT ave (WATER REMOVAL redt . CAUSED BY OPERATOR *
> CONTINUE i
~
F 26 errors estimated from the instrument repeatability would be 11.6 gallons regardless of test duration, and subsequent contribution to the leak rate error would be 0.19 gpm and 0.05 gpm for one and four hour test durations, respectively. _
3.5 Uncertainty of Make-Up Tank (MUT) Chart Time During the one year period, 264 water additions were logged in CR0 logbooks and these entries were identified on the MUT strip chart tracings, as tabulated in Table 10. The purpose of this comparison was to determine the accuracy and validity of the chart time. It was understood that the time entered in the shift log by an SRO and CR0 was the control room clock time, and the control room MUT recorder time was adjusted periodically to the control room clock time at midnight.
The traces of water addition on MUT charts were compared statisti-cally with the CR0 log entry times. Statistical analysis showed that the chart traces of water additions were ahead of the log times by an average of 3.2 minutes with a standard deviation of 10.73 minutes.
This was an expected result since the operator or SRO would enter the water additions into the shift log after completion of the operation.
On this basis, it was determined that the MUT recorder chart time was accurate statistically to t 10 minutes.
This information was later utilized to isolate the interval of the MUT level strip chart trace which bracketed the period of test perfo rmance. The resulting interval of strip chart was typically 80 minutes wide, (a 60 minute test + 13 minutes before + 7 minutes after) starting 13 minutes prior to the recorded test start time in terms of chart time. All available records were then correlated -to identify the actual period of test performance within this interval.
3.6 System and Human Error potential Beside the procedural inadequacies and the "As Built" system limita-tions, there are three addittenal expected or potential errors in the RCS leakage rate calculations.
(1) RCDT pumpout entries The procedure required computer entry by operators of RCDT pumpouts. This is discussed further in Section 6.0 R1 R1 R1 R1
z - - . - . .
32 -
The trace of the level shift due to the pressure increase (p)wasthesameasthosesuspectedhydro' gen additions on the MUT chart for the period April -
1978 thru March 1979. (See Table 6)
The test traces are shown in Figure 3. For clarity, Figure 3A provides a magnified hand drawn version of the appropriate section of Figure 3. A computer graphic trace is shown in Figures 4 for this test. After the test, licensee representative acknowledged the inspector's findings of the effect of hydrogen additions and their characteristic traces on the MUT level charts.
4.3.3 Hydrogen Additions During Leak Rate Tests The Control Room Operator's and Shift Foreman's logs were searched for entries showing hydrogen addition during the periods of leak rate testing records. This wr done for records from April, 1978, through March, 1979. No entries showing the hydrogen additions were observed in the logs.
The makeup tank level strip chart was then examined for the additions. Twelve (one combined) hydrogen additions R1 during RCS leak rate testing were identified as shown in R1
- Table 6. The hydrogen additions were not recorded in the logs nor compensated for in the leak rate calculations. When the hydrogen additions and consequent level shifts were included in the leak rate calculations, the unidentified leak rates were all increased.
R1
P .- .
35 5.2 Findings Regarding Water Addition During a previous inspection, four such water additions were identi- _
fled. During this inspection it was determined that three of them were wrongly identified. In fact, one of the three wrong cases is now identified as a hydrogen addition.
Based on the review of MUT strip chart, traces of water addition, surveillance SP 1303-1.1 computer output and pressurizer level response during tests, fourteen (one combined) tests were identified R1 during which water additions were made but were not entered into the computer calculations. -Table 7 summarizes these water additions.
In some cases, the chart traces indicated that water.might have been added gradually to the RCS. One test, performed January 6,1979, accounted for 300 gallons of water addition in the computer calcula-tions. However, the level shift, a characteristic trace of water addition on the MUT strip chart, indicated approximately 480 gallons added. When gas space compression is accounted for, the addition R1 amounted to approximately 400 gallons, instead of the 300 gallons. R1 entered into the computer calculation. This recorded R1 MUT level shift provided additional evidence of the existence of a loop seal in the low pressure reference leg, since raising MUT leval compresses the MUT cover gas and causes the same effect as a gas addition discussed in Section 4.
When these water additions were accounted for in the leak rate calcu- R1 lations, three showed the unidentified leak rate in_ excess of I gpm, as tabulated in Table 7. .This was contrary to the requirement R1 '
specified in Technical. Specification 3.1.6.1. These are further examples of apparent failure to comply with procedural.and R1 regulatory requirements.
4 l .
l Tehle 6 '
Hydreeen Additlens Te Makee Tank Durina Leek Bete Test tiATER ADDITION NTDA0 GEN CHANT INCLllDED IN UW/5F LIE M tall 0Elfilflft LEAK SATE.EPH DATE CLOCK TIME GALLoll/Tilf @ tuini M l-- _ute t _ute 08/08/78 0735/0835 no no no 2"/0750 -0.1099 0.2341 Al (1.F" decg ed; 0.5" effective) 08/30/78 1952/2052 no 'no no 1"/1952 0.1023 0.3775 (0.6" decayed; 0.4" effective) al 08/31/78 0801/0901 no no no 1.5"/0820 -0.4141 0.6179 (MUT +i.3" normal -1") .
09/18/78 2355/0055 no no no 2"/0040 0.5823 0.7937 83 (09/19/78) (MUT +1.3"; normal -1,-)
10/02/78 1645/1745 no no no 2"/1720 -0.0293 0.3147 (1.5" decayed; 0.5" effective) g 11/07/78 1608/1708 no no cn no 2"/1653 0.0445 o,3tg7 ,,
(1.6" decayed; 0.4" effective) 11/12/78 0816/0916 no no no 2"/0903 -0.1954 0.4926 (MUI +0.8"snonnel -0.5": 1" effective) ,,
' 12/18/78 0830/0930 no no no /0834( )0.5220 (no effect?) ,
01/06/79 0756/1156 400/0923;120fAS/1010 300 941. yes /0937./0940 -0.5948 0.4485 (no effect) 01/11/79 1606/1706 no no no 2"/1738 -0.6163 0.7597 02/02/79 1600/1700 no no R1 no 2*/1614.1620 0.3287 0.6727
' (1.5" decged; 0.5" effective) 02/03/79 1615/1715 no - no no 2"/1623 0.4692 0.8132 "I (0.5" effective) 4 h
1
39 Table 7 isater Additiene Durin8 RCS Leak 8e's Test Without Entry Into the Computer IdATER AD0ITION IftgNOGEN WART INCLUDED IN UU/5F LU8 M UNIDENTIFIES LEAK RATE.GPM OATE CLOCx TIME EALLINI/TifE @ tn m g m gm go gm 04/30/78 1532/1632 165/1538 no no --
-1.8580 1.9260 R1 (MUT'+1.3"; normal-2")
R1 04/30/78 2321/0021 60/2335 no no - 0.9717 0*4044 (05/01/78) (MUT +1" ; normal -1.5")
- R1
- 05/12/78 1643/1743 180/1732 no yes - -0.7443 0.6337 (MIT +5"; normal -1" ) .(70/1745)
"I 05/26/71 1656/1756 90/1753(jogged) no no - -0.7518 1.4498 (pelt +0.4"; normal -3")
06/21/78 0341/0441 30/0410.90/0425 no yes - 0.9421 1.6301 (MUT-6"; normal-11")
7 08/29/78 1547/1647 240/1544( )no ne - -0.0673 0.2767 (PtlT+0.3*; normal-1" : 15 gal effective) 1629/1729 60/1705 n' ne - -0.5823 0.7937 09/08/78 (Palf +1.3*; normal -1")
R1 60/1840-50(jogged) no no - -0.5862 0.7898 09/11/78 1825/1925 (MIT +2.6"; normal -2")
R1 09/15/78 0921/1021 45/1010-20(jogged)no no - -0.5503 0.4817 (MIT +0.3"; normal -1")
7 09/18/78 2035/2136 45/2100(jogged) no no -- -0.4265 0.6055 60 /1240-1303(jogged)no - -0.4581 0.9179 10/17/78 1201/1A1 no R1 12/13/78 1842/1942 270/1920 no yes -
-0.2170 0.1417 (MuT +8.3"; normal -1")
I 0756/1156 400/td23;120Fn8/1010 300 gal, yes /0937 /0940 -0.5948 0.4485 01/06/79 (noeffect) 01/1h79 0401/0501 60/0450(jogged) no no -- -0.6938 0.6824 (Isli +1.1"; normal -1")
R1 l
l R1 7 : questionable
- : RCDT drained ; 165 gal. 9 579 0F
- RCDT drained ; 350 gal. 9 5798F
40 6.0 Effects of Reactor Coolant Drain Tank (RCDT) Level Inputs on Leak Rate Test Results 15 . 1 Discussion
'The Reactor Coolant Drain Tank collects the effluent or leakage from the pressurizer PORV and code safety valves-. It also collects leakage past the reactor coolant pumps primary mechanical seal. The tank fluid can be circulated through a cooler and returned to the tank by spraying into the tank vapor space. The-RCDT also has a connection to the Reactor Building Sump. Surveillance procedure SP 1303-1.1, Revision 7 (effective revision during 1978-79), treated the water level change in the RCDT as a loss of Reactor coolant covered by Technical Specification-3.1.6.8. Therefore this was not subject to the 10 gpm limit of total RCS leakage. This treatment of RCDT water would allow leakage through relief and safety valves and reactor coolant pump seal s to approach a 30 gpm limit.
6.2 Findings Regceding RCDT Level Inputs R1 When an operator took an action such as pumping out water from the RCDT, this action is required to be logged in the CR0 shift log. As listed in Table 8, the RCDT tank levels were decreased substantially according to the surveillance records of leak rate tests; yet, no entries in the SRO or CR0 logs were identified reporting the cause for the apparent large volume of water removed from the RCDT. An unaccounted water removal from the RCDT would result in conservative values of calculated gross leakage rate. These are additional apparent failures to follow procedural requirements concerning required log entries.
Based on the computer printouts of surveillance results, Table 9 lists those RCDT level changes greater than 60 gallons of water during the review period. .The last column of Table 9 demonstrates R1 the substantial effect of RCDT level changes on identified leak l R1 rates.
l 1
~
NOTE: _
R1 ATTACHMENTS A, B, AND C TO ORIGINAL REPORT HAVE BEEN REVISED TO R1 REFLECT CHANGES NOTED IN THE REVISED REPORT. COPIES OF THE REVISED ATTACHMENTS ARE VOLUMIN0US AND ARE NOT INCLUDED HERE. R1 4
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M' kd LITIUTIES J CORPORATION 100 Inter pace Parkway Parsippany. New Jersey 07054 201263-G500 TELEX 136-482 Wrner's Direct Dial Number-June 10, 1983 Docke't No. 50-289 Chairman Nunzio J. Palladino U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Chairman Palladino:
Recently, the NRC s taf f s tated, "because of all the open issues . . . . the a taf f can draw no conclusion regarding management integrity at this time". Addi tionally, the Commonwealth of Penns ylv ani a 's " Supplemental Commente" of June 2, 1983, , stated that ,
"the Commonwealth will not support the res tart of TMI-l until i t receives adequate assurances from the Commission that the management of GPU Nuclear Corporation is willing and able to operate the plant in a aafa and compe tent manner" .
We have again evaluated the present GPU Nuclear organization to reassure ourselves and to provide a basis for the confidence of othe rs that any inappropriate attitudes or practices of the past -'
have not been carried forward and will not manifest themselves in GPU Nuclear.
~
, ~. ,
We re tain confidence in the capability and integri ty of the GPU
. Nuclear organization and personnel. The basis is further evidenced by the -in-depth assessment conducted by the Licensing Board, as'well as by independent measurements by industry's INPO., NRC's SALP and ,
other inspe'ctions and by Licensee 's own ennaul tanta.
As a preliminary matter, .it is useful to review the Meted -
organization that was responsible for operation of the TMI Station
~
s 1 Jersey Central Power & Light Company /Metropohtan Edison Company / Pennsylvania Electric Company
-- . - - . - - - , - . -_ s.w, --+*grFM -'
-.- . , = = . . .
2-at the time of the accident. No member of' Me tEd's/TMI senior management is now involved with TMI. Four levels of management, the Me tEd president, vi ce-pre s i de n t , s tation manager, and both unit managers responsible for TMI at the time of the accident are not with GPU Nuclear. The senior management responsible for operation of-TMI-l today is dramatically different than that which existed at the time of the accident.
In structuring GPU Nuclear we have provided dedicated on site personnel for each of the generating stations with a highly experi-enced senior manager on site. We have provided experienced managers and staf f for a number of centralized support functions such as i
engineering, health physics , quali ty assurance , trai ni ng ,
maintenance, and cons truction in order to ef fectively support the s tation management. Addi tionally, the organizational s tructure was . .
specifically designed to provide inharent checke and balances. GPU Nuclear, its operational philosophy, its senior managers, and nuperous other key personnel within the ' organization were reviewed in{ depth and endorsed by the ASLB. Over one hundred individuals, ini:luding top managers , appeared before that board in public he ari ngs . -
A broad look at the elements of 'GPU Nuclear which will be involved in the operation of TMI-l reveals that the organi zation, down through two levels of management below the GPU Nuclear vice - . .
presidents , enco' mp,assing 86 such posi tions , contai ns 16. individuals- -
that were *wi th Meted prior to the accident. Of the balance, 30 are p
e new employees. sin'ce the accident and the remaining 40 come from other components of the GPU Sys tem. The executive v.p. of GPU Nuclear and the vice president directly responsible for TMI-l si te operations are new.
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At the time of restart we expect to utiliza 38 currently licensed
-operators for TMI-1; 25 are newly licensed since the accident. Out i
of the remaining 13 that were licensed at the time of the accident, ~
10 are assigned to shif t activities. These' operators need to be viewed as a source of experience for the safe operation of TMI-1.
Their prospective performance must also be assessed in light of (1) the f act that all have been licensed under the new tes ting cri te ri a ,
(2) the ability of GPUN to provide 6 shif t coverage for TMI-l which provides one shif t out of six for training, (3) the p'resence of shif t technical advisors , and (4) significantly improved procedures.
l As further assurance s
- 1) We will, prior to res tart, reassign personnel suc'h that no TMI-2 licensed operator will operate TMI-1 (except'for ,
the manager of operations who was licensed on Unit 2 but l
- who.was evaluated in depth and specifically endorsed by the ASLB), and- .
i 2) We will, prior to restart, add full' time on shif t operational quality assurance coverage by degreed engineers until the open issues are resolved. We would defer to the
-NRC should it wish to. provide full time on shift resident ,
inspector coverage of TMI-l operations.
^
The balance of the TMI-l si te, s taf f in engineering , maintenance , .and ,
supervisory roles contains numerous individuals wi th ~ prior r- -
experience in the operation of TMI-l', experienceI which is important '
to the safe operation of TMI-1. The prospective performance of the current TMI-l si te s taf f mus t be asses' sed in light of -. (l') the evaluation by the ASLB, (2) the NRC's Jan. 198,3 SALP and ,(3) the
~
j most recent inspection 50-289/83-10 which focad very, f avorable, l
results in the. pervasive management areasl of procedures ,,. adher'ence , . . . i
- discipline, an'd atti tude toward safety. -
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i In order to provide added assurance; We will reassign personnel such that those func tions which provide an overview assessment, analysis, or audit of plant activi ties speci fically; General Of fice Review Board Independent On-Site Safety Group Shif t Technical Advisors ,
O/A Audit O/A and O/C Si te Staf f Licensi ng Radiation Control Emergency Preparedness will contain only personnel wi th no pre-accident involvement as Me tEd exempt employees at TMI-l or 2. We will continue thi's cons traint until the open issues are ef fectively resolved. , .
As a f urther action to' s trengthen .TMI-1; ,
We have reallocated the priori-ties and assi.gnments wi thin j
the .of fice ,of the ,pr.esi dent of GPU Nuclear, which of fice '
]
includes the presia,ent and executive vice president,- such that T I-l will ' report 'to the executive vice pre'sideNt and
~
h such that he' will be able to devote his prime attention. to 1 -
j TMI-l ma t te rs .
.i In a letter to' Governor' Thornburgh .we',have committed to the actions which we think necess'ary to satisfy the issues 'und'e~r 'a'ppeal by the Commonwealth of Pennsylvania. A copy of that letter is attachef.
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l we are taking these steps in order to provide additional assurances during the period necessary to resolve the open issues. We are -
l confident that the actions necessary - to provide these added assurances will rot detract from the first priority of safe operati ons . -
We will work with your s taf f to communicate the speci fics of these s teps .
l In closing, we urge the Commission to expeditiously resolve the open l
issues so as to provide assurance that the learnings of the accident have been identified and implemented. We pledge our cooperation in that effort so that the TMI-1 management and staff can be accorded the full aupport of the Commisaion and the public.
Sincerely, i
H. Dieckamp ida enclos ure -
e cc: Governor Thornburgh .
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- GEORGE W. GE< As
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il)ashington, B.C. 20m a . . , , , , - . . . ,
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04VMe December 7,1983 la 4
Nunzio Pollodino, Chairman b U.S. Nuclear Regulatory Commission gg 717 H Street N.W.
Washington, D.C. 20555 g .
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Dear Chairman Palladino,
gtdhr i am clarmed by the recent NRC staff recommendation to re-start Three Mile Island's Unit I at 25% capacity, and I strongly urge you not to accept that '
recommendation.
In light of the NRC's continuing review of the management integrity issue, the outstanding criminal proceedings involving the former operator of Three Mile Island, and most importantly the unacceptably slow pace of the cleanup of Unit 2, any decision to re-start Unit I is ill-advised. -
Indeed, it is an affront to the people of Centrol Pennsylvania to octively produce nuclear power at Three Mile Island while dangerous radiooctive waste lay practically at -
their doorsteps at Unit 2.
The 1979 occident at Three Mile Island is still with us. Until all traces of that frightening fiasco are erased -including the radioactive wastes festering at Unit 2 - re-start of Unit I should remain on unopened file.
Very truly yours,
. -m ...-
. .J. . . ' .ms y. - _
George W. Gekas cc: T. Martin Member of Congress .
R. Starostecki R. Keimig J. Gutierrez 12/22/83-TEM 12/15...To 0GC for Direct Reply... Suspense: Dec 27.. 0CA to Ack, RF, Docket EDO..SECY. 83-2626 o .
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777 NUCLEAR REGULATORY COMMISSION cc: T. Murley J. Allan BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD M rtin R. Starostecki R. Keinig In the Matter of ,
K. christopher METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289 JMG - 7/5/83 (Restart)
(Three Mile Island Nuclear Station, Unit No. 1) .
NRC STAFF'S ANSWER TO AAMODT MOTIONS FOR PROVISION -
1 0F INFORMATION AND TO LIFT ORDER OF I CONFIDENTIALITY FROM PROCEEDING ON CHEATING
{
i Mary E. Wagner l Counsel for NRC Staff
)
June 27, 1983 l
UNITED STATES OF AMERICA .
NUCLEAR REGULtTORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of .,
METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 (Restart)
(Three Mile Island Nuclear Station, Unit No. 1) )
I 4
NRC STAFF'S ANSWER TO AAMODr MOTIONS FOR PROVISION OF INFORMATION AND TO LIFT ORDER OF -
CONFIDENTIALITY FROM PROCEEDING ON CHEATING f k
i .
4 i
i Mary E. Wagner Counsel for NRC Staff l
June 27, 1983 -
TABLE OF CONTENTS .
PAGE I. INTRODUCTION ............................................ 1 II. DISdUSSION...............................~............... 2 4
A. Request for Information ............................. 2 B. Motion to Lif t Confidentiality Order . . . . . . . . . . . . . . . . 9 III. CONCLUSION .............................................. 11 e
a G l i
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O d
l i
l
- _ , _ - - . _ . , , . - -. ~ - - _ . . . .- ._... - . . - ._ -.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
~
In the Matter of METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289 (Restart) -
(ThreeMileIslandNuclearStation.
Unit No. 1)
NRC STAFF'S ANSWER TO AAMODT MOTIONS FOR PROVISION OF INFORMATION AND TO LIFT ORDER OF CONFIDENTIALITY FROM PROCEEDING ON CHEATING I. INTRODUCTION f i
By Order of June 16, 1983 the Appeal Board scheduled oral arguments on three pending motions to reopen the record. It also provided that the .
- parties could file appropriate coments, by July 1,1983, on three matters
- j. which "may have a bearing" on the disposition of the motions. June 16 Order at5.1/
4 4
I 1/ The three matters are: "im Martin's coments at a May 24, 1983 Comission meeting that ie had been aware since 1980 that the i leak rate data had been 'alsified at Three Mile Island, Unit 2; the proposed actions contairad in a memorandum from William J. Dircks to the Comission, dated June 7,1983, designed to facilitate the Staff's review in connection with the Comission's "immediate effectiveness" determination on restart; and the proposed personnel changes at TMI-1 contained in a letter dated June 10, 1983 from Heman Dieckamp
! to the Comission.
l l
On June 21, 1983, Intervenor Marjorie M. Aamodt filed "Aamodt Motions for Provision of Information and to Lift Order of Confidentiality of Reopened Hearing" (Motion).2/
jn her Motion, Mrs. Aamodt suggests that she needs tha information she cites in order to file comments by July 1, 1983 in response to the Appeal Board's Order of June 16, and to present oral argument on the pending motions to reopen. '
The Appeal Board has ordered that all answers to the Aamodt Motions be in its hands by close of business on Monday, June 27, 1983, in order to facilitate its consideration of the Motion. Accordingly, the Staff's position on the Motion is set forth below.
II. DISCUSSION i
A. Recuest for Information i
i The Staff has construed the Motion requesting information as a discovery request for the production of documents pursuant to 10 CFR 9 2.744.
The responses provided are complete to the best of Staff's knowledge 2/ Although the certificate of service attached to the Motion indicates that the NRC Staff was served by hand delivery of. the Motion to Jack Goldberg (Counsel for the NRC Staff) on June 21, 1983, hand delivery was not made to Mr. Goldberg. Instead, the NRC Staff was first served, and became aware of, the Motion on June 22, 1983 when it received a copy from the Docketing and Service Branch of the Office of the Secretary.
within the very strict time limitations for Staff response.3/ The Staff
- recognizes a continuing responsibility, if it becomes aware of additional documents responsive to the requests, either to provide such documents to the Appeal Board and the parties or to state its objections and basis for
~
not providing them.
Mrs. Aamodt's Motion enumerates ten different areas of infonnation which she seeks to have provided to her. Each item is addressed
- individually below.
"1. All information the Department of Justice has provided to NRC
, concerning the Hartman matter."
The Department of Justice (DOJ) has'provided the NRC with the 1980 "Rockwell Report" prepared for Licensee. This report has been forwarded by the Licensee to the representatives of TMIA and UCS and to I
f Mrs. Aamodt.4/ To the best of Staff's knowledge, Staff has not been i,
-3/ As part of the Staff's effort to respond to the Motion, the following people and offices were provided with a copy of the Motion: Office of Investigations (Ben Hayes, Director); Office of Inspector and Auditor (James Cummings, Director); Office of Inspection and Enforcement (Richard DeYoung, Director; James Sniezek, Deputy Director; Jane Axelrad, Director of Enforcement); Office of Nuclear Reactor Regulation (NRR) (Edson Case, Deputy Director);
NRR Division of Licensing (Darrell Eisenhut, Director; Gus Lainas, Assistant Director for Safety Assessment; John Stolz, Branch Chief, Operating Reactors Branch 4; James Van Vliet, TMI-1 Project Manager);
NRR Division of Human Factors Safety (Larry Crocker, Section Leader, Management Technology, Licensee Qualifications Branch); GPU v. B&W trial record review team (Richard Hoefling, Attorney); Region I (Tim Martin, Director, Division of Engineering and Technical Programs). The TMI Program Office (Rick Weller, Director) was also contacted. The above personnel were asked to identify for Staff counsel all documents in their possession (whether withholdable or not) responsive to the Aamodt request. -
4/ See Distribution of Rockwell Report, May 4 1983.
}
provided by the Department of Justice with any additional substantive ~
information concerning the Hartman matter.5_/
In addition, there has been an exchange of correspondence between Chaiman Palladino and the DOJ concerning the status of D0J's a
~
investigation of the Hartman allegations. The Staff has been informed by the Office of General Counsel that the Commission is currently
, considering whether to release the correspondence in response to two Freedom of Information Act requests. The Staff will inform the Appeal ,
Board and the parties of the Commission's determination, and will provide copies of the correspondence if that action is consistent with 4
l the Comission's decision.
"2. The action within the DOJ investigation concerning the alleged ;
i undue innuence of GPU attorneys. The DOJ 15 not opposed to a j '
motion to obtain this information." 2 i
As acknowledged by Mrs. Aamodt in her pleading (Motion at 3), the
{. Consission denied a prior Aamodt motion to have the Comission request, 1
] from the Department of Justice, documents on this matter, and to l r
distribute any such documents to all the parties. Order of May 5,1983, at 3. To the best of Staff's knowledge, Staff does not have any documents in its possession responsive to Mrs. Aamodt's request and, in fact, is unsure of the existence of a DOJ investigation concerning " alleged undue l influence of GPU attorneys" to which Mrs. Aamodt refers.
5/ Several NRC employees were assigned to assist DOJ in the grand l jury proceedings on the Hartman allegations. While these employees may have received information on the Hartman matter from DOJ l pursuant to their assignments, the Staff has not sought to determine '
whether, in fact, these individuals received any information from -
4 DOJ or the substance of any such information in view of the secrecy
' of the grand jury proceedings.
l 4
1:
I
, . _ . . =- . ___ _ _ _
"3. All NRC correspondence, interviews and investigations of the "
Mari. nun matter, including data, calculations and reports."
The Staff has identified a limited set of NRC correspondence and reports related to the Hartman matter that has already been provided to the parties to the restart proceeding. Specifically, the limited treatment of the matter in the Restart SER, NUREG-0680, Supplements 1 and 2 constitutes a report that was admitted into evidence in the restart hearing. In addition, correspondence on the Hartman matter is i
, contained in, and attached to, a Memorandum to Connissioner Gilinsky l
from William J. Dircks, dated June 10, 1983. The June 10, 1983 memorandum was distributed to the Appeal Board and parties to this f
proceeding on June 14, 1983. See Letter from Mary E. Wagner, Counsel for
~
r NRC Staff, to the Appeal Board dated June 14, 1983. j There are a number of other documents constituting interviews and i 1 _
l draft reports from the previous NRC investigation of the Hartman matter -
t that have been forwarded to the NRC's Office of Investigation (OI) which '
now has an ongoing investigation into the matter. The Director of OI has determined that release at this time of the documents called for
- could jeopardize that ongoing investigation and has requested the Staff l to consnunicate his objection to providing such documents. Accordingly, i the Staff objects to providing these additional documents at this time.
At the conclusion of any further necessary actions (civil or criminal) on this matter, the Staff will provide the Appeal Board and the parties with a copy of OI's investigative report and any other docurrents which
! the Appeal Board should find relevant to the proceeding, necessary for a proper decision and not reasonably obtainable from any other source.
l f
I I_ _ _ _ _ _ . . _ _ _ _ _ . _ . _ . - _ _ _ _ _ _ _ _ _ _ ~ _ _ . . _ . . _ . _ _ . _ _
t "4 Infomation concerning allegations of further cheating on tests which was the subject of a memorandum of February 1. 1983 Trom Darrell G. Eisenhaut (sic) to the Comissioners and which
- information was not provided to us as requested in our letter to Mr. Eisenhaut (sic) of May 3, 1983."
OI's investigation of this matter is essentially complete.
~
However, consideration is being given to whether further investigation should be conducted. Pending the outcome of such consideration, the Director of OI has detemined that the release of documents called for here could jeopardize any further investigation and has requested the -
- Staff to connunicate his objection to providing such documents.
{ Accordingly, the Staff objects to providing such documents at this time. If it is detemined that no further investigation is required, the Staff will provide the Appeal Board and the parties with a copy of 01's ;
investigative report.
"S. Infomation provided to Inspection and Enforcement concerning their investigation of the allegations of the three engineers -
involved in the TMI-Z cleanup. We have been unable to locate j any affidavit of Larry King."
i j As stated in the Connission's Order of May 5,1983, the affidavits l of Richard Parks and Edward Gischel have been available in the NRC Public Document Rooms (PDRs) in both Washington and Harrisburg since at least early May of this year. That Order stated further:
The NRC has interviewed Mr. King, but has not received a formal i
affidavit from him. Since the Comission has determined that
! release of the interview statements of Mr. King could prejudice the '
i NRC's ongoing investigation into the allegations involving Three Mile Island, Unit 2, the Aamodts' request regarding Mr. King is
- therefore denied.
OI(ratherthantheOfficeofInspectionandEnforcement(IE))isconducting an ongoing investigation into the allegations of Messrs. Parks, King and i
j Gischel. The Director of OI has detemined that release at this time of tne information called for (beyond that which has already been served on i
4 all the parties or placed in the PDRs) could jeopardize that ongoing investigation and has requested the NRC Staff to connunicate his objection to providing such documents. Accordingly, the NRC Staff objects to providing these additional documents at this time. At the conclusion of :
any further necessary actions (civil or criminal) on this matter, the Staff will provide the Appeal Board and the parties with a copy of OI's investigative report and any other documents which the Appeal Board should find relevant to the proceeding, necessary for a proper decision, and not reasonably obtainable from any other source.
! "6. Infomation generated by the I&E investigation of the j allegations of the three engineers."
As indicated, 01, rather than IE, is conducting an ongoing investi-r gation into the allegations of Messrs. Parks, King and Gischel. The
(
Director of OI has detemined that release at this time of the '
j infomation called for (beyond that which has already been served on all d
l the parties) could jeopardize that ongoing investigation and has requested i
the NRC Staff to communicate his objection to providing such documents.
- Accordingly, the NRC Staff objects to providing these additional documents at this time. At the conclusion of any further necessary actions (civil or criminal) on this matter, the Staff will provide the Appeal Board and the parties with a copy of OI's investigative report and any other documents which the Appeal Board should find relevant to the proceeding.
necessary for a proper decision, and not reasonably obtainable from any other source.
"7. All information concerning alleged falsification of training
] records at TMI-Z, the sub; ect of Board Notification 83-71." '
OI has completed its investigation into the subject of Board j Notification 83-71. The Staff has identified the following documents responsive to this request:
i,
- =- -. - . . - . . -
i
~
Memorandum from V. Stello, Jr. to H. R. Denton, dated May 17, 1983, with attachments Memorandum from W. Dircks to Ben Hayes, dated May 20, 1983 Board Notification 83-71A, dated June 27, 1983 with attachments (herewith served u TMI-service list) pon the Commission, the Appeal Board, and the Note from Richard Hoefling to File, dated May 20, 1983
! Copies of these documents are attached.
"8. The underlying data of the RHR study that is being provided to 1 the 5ta77."
1 The data underlying the RHR study which has been provided to the NRC Staff is attached, d
- "9. All connunications between NRC and Licensee concerning the i '
Hartman matter."
j The Staff has identified the following correspondence with the
(
i >
Licensee concerning the Hartman matter:
i j
Investigative Report Number 50-320/79-10, October 1979, with' attachments -
I' Letter from R. C. Arnold, Metropolitan Edison, to Victor Stello, Jr.,
NRC, dated December 5, 1979, with attachments Letter from Victor Stello, Jr., to Metropolitan Edison, Attn.
- R. C. Arnold, dated January 23, 1980, with attachments Letter from R.C. Arnold to Office of Inspection and Enforcement, j Attn. V. Stello, dated May 19, 1980, with attachments l Letter from Victor Stello, Jr. to Metropolitan Edison Company,
- Attn. R.C. Arnold dated November 21, 1980, with attachment l Copies of these documents are attached.
"10. The resumes of all new employees considered in the Dircks and
! Dieckamp letters. By 'new,' we mean to the Restart Proceeding."
The June 7, 1983 letter from W.J. Dircks to the Commissioners, to which the Staff assumes request 10 refers, does not identify any '
particular individuals as "new employees." The June 10, 1983 letter from l
Herman Dieckamp to the Comission, as well as the organizational charts distributed and infonnation provided to those present at the June 20,
1983 public meetingbl between Staff and Licensee to discuss the June 10 proposal, neither identify by name, nor provide resumes for, any "new employees." At present, the Staff is unaware of the identities of any "new employees" the Licensee may seek to use pursuant to its proposal to reassign individuals and does not possess any resumes of any such "new employees."
The Licensee's briefing material distributed at the June 20, 1983 meeting as well as the transcript of that meeting are attached.
B. Motion to Lift Confidentiality Order Mrs. Aamodt has also petitioned the Appeal Board to lift the confidentiality order covering the testimony of operators who testified in the Reopened Proceeding (Cheating). The stated reason for the motion
- l is to enable the Aamodts to " discuss the information concerning staffing i provided in the Dircks and Dieckamp letters." Motion at 4. This motion -
is both premature and overly broad, and should be denied.
The Aamodts were signatories to a stipulation of confidentiality which was voluntarily entered into by the parties tc the Reopened Proceeding. It was stipulated, inter alia, that use of a lettering system to identify certain individuals "is capable of permitting an adequate evidentiary hearing on the issues in this proceeding and should be retained and used throughout this proceeding, including any appeals . . . ." Stipulation of November 12, 1981, at 1 1. Pursuant to that stipulation and an order of the Special Master dated November 13, 1981, the identities of various TMI personnel were to be protected from
-6/ Mr. Norman Aamodt was present at that meeting and presented oral comments to Staff and Licensee at the meeting.
J.
public disclosure. It is the Staff's belief that many TMI operators testified _at the Reopened Proceeding with (and perhaps because of) the understanding that their identities would be protected from public disclosure. ,
~
No basis has been provided for a change in circumstances that would warrant lifting the confidentiality order at this time. Mrs. Aamodt has not indicated that there is any individual covered by the order whom she wishes to discuss in the context of the Licensee's proposal for staffing of TMI-1. Indeed, the names of the individuals contemplated for the new staffing proposal outlined in Mr. Dieckamp's letter have not yet been made available to the Staff or to the parties. See Staff's response to ,
request No. 10, supra, with attachments. It is possible that staffing of ['
\
TMI-1 can be discussed without the need to specifically identify by name i individuals covered by the Order. Lifting of the Order at this time is
!. clearly premature.
I The Aamodt Motion is also overly broad. At such time as Licensee identifies, by name, the individuals in its staffing proposal, the Aamodts will be able to compare those names to the names of those l currently protected by the Order.E If individuals are identified about whom the Aamodts have a particular concern based on the testimony l in the reopened proceeding on cheating, they may request an j.n,ncamera session to discuss the proposed use of those individuals under Licensee's j i I
,7f The Aamodts were given a key to the letter designations of those persons covered by the protective order. Thus, they will be in a position to make a comparison of those names with the names of
- those contemplated for use under Licensee's June 10 staffing proposal.
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plan. Such a closed session, or even a limited lifting of the Order should that be determined to be necessary for a resolution of the issues, would continue to protect the id, entities of the many other individuals who have testified under the protective order.
III. CONCLUSION The Staff has attached to this pleading all documents it has identified responsive to the Aamodt request, other than documents to which a specific objection has been interposed. Based upon the foregoing, the Appeal Board should uphold the Staff's objection to production at this time of additional documents called for by the Aamodt Motion.
[
The Aamodt Motion to lift the confidentiality order covering the k Reopened Proceeding on Cheating is both premature and overly broad, and ~
should be denied.
Respectfully submitted, l - /- F
! Mary . dagner Couns & for NRC Staff Dated at Bethesda, Maryland i
this 27th day of June, 1983 l
l l
l l
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l _ ____ _. ___ , _ _ . _ _ _ . _ . _ _ _ _ _ . . _ . ,,. ,_ _ _ _ _ _ _
UNITED STATES OF AMERICA-NUCLEAR REGULATORY COM11SSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of. -
)I METROPOLITAN EDISON COMPANY, ET AL.h Docket No. 50-289 h
(Restart)
(Three UnitNo.1) Mile Island Nuclear Station,)h CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S ANSWER TO AAMODT MOTIONS FOR PROVISION OF INFORMATION AND TO LIFT ORDER OF CONFIDENTIALITY FROM PROCEEDING ON CHEATING" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, or, as indicated by two asterisks, by ;
hand delivery, this 27th day of June,1983:
- Gary J. Edles, Chairman Dr. Linda W. Little ?
Atomic Safety & Licensing Appeal Administrative Judge -
! Board 5000 Hemitage Drive -
U.S. Nuclear Regulatory Comission Raleigh, North Carolina 27612 Washington, DC 20555
'- George F. Trowbridge, Esq.
- Christine N. Kohl Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Appeal 1800 M Street, NW Board Washington, DC 20036 U.S. Nuclear Regulatory Comission Washington, DC 20555 Douglas R. Blazey, Esq.
Chief Counsel
- Dr. John H. Buck Department of Environmental Resources Atomic Safety & Licensing Appeal 514 Executive House, P.O. Box 2357 Board Harrisburg, PA 17120 l U.S. Nuclear Regulatory Comission
- Washington, DC 2C555 Honorable Mark Cohen 512 D-3 Main Capital Building Harrisburg, PA 17120
- Ivan W. Smith Administrative Judge Ms. Marjorie Aamodt i Atomic Safety & Licensing Board R.D. #5 l U.S. Nuclear Regulatory Comission Coatesville, PA 19320 Washington, DC 20555 Mr. Thomas Gerusky Dr. Walter H. Jordan Bureau of Radiation Protection Administrative Judge Dept. of Environmental Resources i
881 W. Outer Drive P. O. Box 2063 l Oak Ridge, Tennessee 37830 Harrisburg, PA 17120 l
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~
Mr. Marvin I. Lewis William S. Jordan, III, Esq.
6504 Bradford Terrace Hannon & Weiss Philadelphia, PA 19149 1725 I Street, NW Suite 506 Mr. C. W. Smyth,-Supervisor Washington, DC 20006 Licensing TMI-1 Three Mile Island Nuclear Station John Levin, Esq.
P. O. Box 480 Pennsylvania Public Utilities Comm.
Middletown, PA 17057 Box 3265 Harrisburg, PA 17120 R.D. 3; Box 3521 Jordan D. Cunningham, Esq.
Etters, PA 17319 Fox, Farr and Cunningham 2320 North 2nd Street Gail Phelps Harrisburg, PA 17110 ANGRY /TMI PIRC 1037 Maclay Street Louise Bradford Harrisburg, PA 17103 Three Mile Island Alert 1011 Green Street Allen R. Carter, Chairman Harrisburg, PA 17102 Joint Legislative Comittee on Energy Post Office Box 142 Ms. Ellyn R. Weiss Suite 513 Harmon & Weiss ;
Senate Gressette Building 1725 I Street, NW Columbia, South Carolina 29202 (
Suite 506 i Washington, DC 20006 Chauncey Kepford -
Judith Johnsrud Mr. Steven C. Sholly -
Environmental Coalition on Nuclear Poor Union of Concerned Scientists 433 Orlando Avenue 1346 Connecticut Avenue, NW State College, PA 16801 Dupont Circle Building, Suite 1101 Washington, DC 20036 Gary L. Milho111n, Esq.
4412 Greenwich Parkway, NW Ms. Frieda Berryhill, Chairman Washington, DC 20007 Coalition for Nuclear Power Plant Postponement Mr. Henry D. Hukill 2610 Grendon Drive Vice President Wilmington, Delaware 19808 GFU Nuclear Corporation Post Office Box 480 ** Judge Reginald L. Gotchy Middletown, PA 17057 Atomic Safety & Licensing Appeal Board Michael McBride, Esq. U.S. Nuclear Regulatory Comission LeBoeuf, Lamb, Leiby & McRae Washington, DC 20555 Suite 1100 1333 New Hampshire Avenue, NW ** Atomic Safety & Licensing Appeal Washington, DC 20036 Board Panel U.S. Nuclear Regulatory Comission David E. Cole, Esq. Washington, DC 20555 Smith & Smith, P.L.
l Riverside Law Center
- Atomic Safety & Licensing Board Panel
! 2931 N. Front Street U.S. Nuclear Regulatory Comission l Harrisburg, PA 17110 Washington, DC 20555
- Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555
- Dr. Lawrence R. Quarles Atomic Safety-& Licensing Appeal Board -
U.S. Nuclear Regulatory Commission Washington, DC 20555 Michael W. Maupin, Esquire Hunton & Willians 707 East Main Street P. O. Box 1535 Richmond, VA 23212 Y,YWy ;
Mary E. gner // ;
Counsel r NRC Stan i 9
F-50.*. :-.4 ,
I cc: T. Murley n
UNITED STATES OF Af1 ERICA R. Starotecki NUCLEAR REGULATORY COMMISSION R. Keimig
~
BEFORETHECOMISS10f In the Matter of )
)
METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289
)
(Three Mile Island Nuclear Station,)
linit No.1) )
NRC STAFF'S REPLY TO THE PARTIES' RESPONSES TO THE COMr1ISSION'S OCTOBER 7, 1983 ORDER AFD NRC STAFF'S ANSWER T0 llCS'S MOTION FOR LEAVE TO FILE RESPONSE TO C0FEISSION'S ORDER OF OCTOBER 7, 1983 Jeck R./Goldberg Counsel for NRC Staff A
i i Mary E. Wagner **
Ccunsel for NRC Staff -
November 14, 1983 71 n1R 1,,,, .-1 8
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMPISSION BEFORE THE COMMISSIDF In the Matter of )
)
METRCPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289
)
(Three Mile Island Nuclear Station,)
Unit No. 1) )
NRC STAFF'S REPLY TO THE PARTIES' RESPONSES TO THE COMMISSION'S OCTOBER 7, 1983 ORDER Af'D NRC STAFF'S ANSWER T0 tics'S MOTION FOR LEAVE TO FILE RESPONSE TO COMfISSION'S ORDER OF OCTOBER 7, 1983 4
! Jack R. Goldberg Counsel for NRC Staff Mary E. Wagner Counsel for NRC Staff November 14, 1983
..i . . .
TABLE OF CONTENTS
?agg I. INTRODllCTION .............................................. I c II. DISCUSSION................................................. 2 A. Licensee's Response................................... 2 B. TMIA's Response....................................... 6 C. Aamodts' Response..................................... 7-D. UCS' Response......................................... 10 III. CONCLUSION................................................. 12
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ll
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TABLE OF CITATIONS Pace NRC CASES:
' fletropolitan Edison Com)any (Three Mile Island. Nuclear Staticn, Unit 1), :LI-81-34, 14 NRC 1097 (1981)............ 3 Metropolitan Edison Company (Three' Mile Island Nuclear Station, Unit 1), ALAB-738, NRC (August 31, 1983)...................................................... 7 florthern States Power Company (Prairie Island Nuclear Generating (Plant, Units 1 and 2), ALAB-288, 2 NPC 390 1975)........................................... 11 Public Service Company of Indiana (Marble Hill Nuclear
> Generating Station, Units 1 and 2), ALAB-493, 8 NRC 253 (1978)........................................... 11 Tennessee Valley Authority (Browns Ferry Nuclear Plant,
- Units 1-3), ALAB-677, 15 NRC 1387 (1982)................... 4 Virginia Electric and Power Comp jan (North Anna Power Station, Units I and F), CLT-76-22, 4 NRC 480 (1976 ) , aff' d , 571 F.2d 1289 (4th Ci r. 1978) . . . . . . . . . . . . . . . 5 4
COURT CASES:
Weinstock v. United States, 3?1 F.2d 699 (D.C. Cir. 1956)........................................... 5 OTHER AUTHORITIES:
Statement of Policy on Investigations and Adjudicatory Proceedings, 48 Fed. Iptg.
36,358 (August 10,1983)................................... 7 l 10 CFR l 2.754(a),(b)........................................... 10 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CON 11SSION BEFORE THE COMMISSION In the Matter of )
METROPOLITAN EDISON COMPANY, rT AL. Docket No. 50-289
)
/Three Mile Island Nuclear Station )
Unit No. 1) )
NDC STAFF'S REPLY TO THE PARTIES' RESPONSES TO THE COMt!!SSION'S OCTOBER 7,1983 ORDER AND NRC STAFF'S ANSWER TO UCS'S MOTION FOR '_ EAVE TO FILE RESP 0tiSE TO COMMISSION'S ORDER OF OCTOBER 7, 1983 I. INTRODUCTION By Order dated October 7,1983, the Comission reouested the views of the parties on whether the Licensing Board's hearing on the Hartman allegations should be stayed until after the Commission's Office of Investigations (01) completes its investigation of that matter and on whether O! also should complete its pending investigations of the Parks / King, Tit!-1 leak rate, and RHR/ BETA reportability matters, and of the GPU management competence and integrity issues identified in NUREG-1020, before any action by the Board on those issues. Responses were filed by TMIA, the Aamodts, the Licensee, the NRC Staff, and by UCS.1/ The Staff hereby provides its reply to the other parties' views on these matters and its answer to UCS's motion for leave to file its views.
-1/ The Comission's October 7th Order limited the filing of briefs on the stay issue to the Aamodts, TillA, the Licensee, the NRC Staff, and the Commonwealth of Pennsylvania, since "no other party participated in the litigation of nanagement issues before the Licensing Board." Order at 2. Notwithstanding this order, UCS, on October 24, 1983, filed a response with an accompanying motion for
. leave to file a response.
2 II. DISCllSSION ,
A. Licensee's Respnnse Licensee's position on the stay issue can be briefly stated as-follows: Licensee opposes a stay if the Comission views the '
Hartman allegations or any other open issue as a basis for the continued suspension of the TMI-1 operating license; if, however, the Comission does not view the open issues as a basis for the continued ;
suspension nf the TMI-1 operating license, then the stay should be 4
exte'ided to allow OI to complete its related investigations. Licensee's Response to Comission Order of October 7,1983 (Licensee's Response) at 10-11. Licensee does not believe that any of the open " concerns" or
" allegations" identified by the Comission in its October 7th Order provide a basis for the continued suspension of the TMI-1 operating license. Id_. at 3-10. _ Licensee argues that the concerns which formed _
i the basis for the Comission's imediately effective shutdown order have been resolved in favor of restart and, therefore, the Comission is obligated as a matter of law to lift the suspension of the THI-1 operating license. hl j I_d. at 2-3, 10. g The crux of Licensee's argument is that the bases for the Comission's imediately effec +ive suspension of the TMI-1 operating license have been removed by the Licensing Board's three partial initial decisions in favor of restart. It is the Comission, however, which has to decide whether the concerns which provided the basis for the shutdown ;
order have been satisfactorily resolved to find reasonable assurance that TMI-1 can be festarted and operated safely. As the Comission has
, held:
i 1
r The Comission is the exclusive administrative body with the power
.to determine whether Unit One may restart . . . .
. . .'. Here, a decision by the Comission rather than granting :
effec'tiveness to a Licensing Board decision, would be determining, based on that decision and other factors, whether the concerns which prompted its original immediate suspension order o# August, 1979, justify a continuation of that suspension. If they do not, and the Commission therefore can no longer find that the "public health, safety and interest" mandates the suspension, then the -
Comission is required by law -- whatever the nature of the Licensing Board's decision -- to lift that suspension imediately.
This is a matter peculiarly within the Comission's knowledge and.
involving the most distraHonary aspects of its enforcement authority.
CLI-81-34, 14 NRC 1097, 1098 (1981). It follows, therefore, that if the Commission believes that the open issues do not pemit it to find that the concerns which were the basis for the shutdown order have been resolved, then the suspension of the TMI-1 operating license need not be lifted. Licensee's argument that the continued suspension of the THI-1 h
operating license cannot legally be ,iusti#ied on the basis of the open
" concerns" and " allegations" is simply wrong, since those matters bear on the original bases for suspending the THI-1 operating license and may raise doubts for the Comission about whether certain of those bases are fully and sufficiently resolved.E Licensee argues that the i
Licensing Board's partial initial decisions resolved all of the Comission's i concerns, but Licensee ignores the fact that the Comission nay find that the open issues cast doubt on whether the Licensing Board's decisions
'-2/ The Staff has identified how each one of the open issues raises questions regarding the soundness of the restart record on the management issues which were, in part, the basis for the imediately effective suspension of the THI-1 operating license.
See NRC Staff's Answer to Three Mile Island Alert Motion to Reopen the Record and Staff Motion to Defer Ruling on THIA's Notion to Reopen, June 13, 1983, at 7-8.
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fully and sufficiently resolve those concerns. The Staff, for its part, is unable tn say that all of the Comission's concerns regarding management' competence and integrity have been resolved. The Staff consequently disagrees with Licensee that the suspension must be lifted now as a matter of law.
As the Staff stated in NRC Staff's Response :o the Comission's October 7,1983 Order, October 27, 1983 (Staff's Response), the Staff supports a stay of the Licensing Board hearing on the Hartman allegations and of action on +% other open issues 3_/ until 01 completes
-3/ nne line of argument by Licensee concerning the importance of the "open issues" warrants special coment because of Licensee's clear misinterpretation of the Staff's analysis of the matter. Specifically, Licensee states that "the Staff has wrongly applied Comission law to view Licensee's failure to have immediately provided [the BETA and RHR] reports as a material false statement by omission." Licensee's Response at 8. Licensee argues that the Staff incorrectly applied a
" relevancy" standard rather than a " materiality" standard, as the law requires, in determining whether Licensee's failure to report the contents of the BETA and RHR reports was a material false statement by omission. Licensee's Response, Attachment (10) at 4-22. Licensee is wrong in both respects.
By Memorandum to the Comissioners from William J. Dircks dated Fay 19, 1983, the Staff identified open issue (5), regarding the reportability of the BETA and RHR reports and other documents, as follows:
The issue of whether the Licensee failed to promptly notify the Comission or Appeal Board of relevant and material information contained in the BETA or RHR reports or any other documents, which failure may reflect on the Licensee's management integrity.
May 19, 1983 Memorandum at 2 (emphasis added). Thus the first time the Staff identified the issue of reportability it was clear that infomation had to be both relevant and material before an obligation arises to report it. In the Staff memorandum which is the subject of Licensee's criticism, it is stated that the three primary sources of reporting requirements are (1) specific license conditions, (2) "the obligation to alert the Comission's adjudicatory bodies to 'new information that is relevant and material to the saatters being adjudicated,'"
ouoting Tennessee Valley Authority (Browns Ferry Nuclear Plant.
Units 1-3), ALAB-677, 15 NRC 1387, 1394 (1982), and (3) the " full (FOOTNOTE CONTINUED ON NEXT PAGE)
its inves+.igations. The Staff does not agree with Licensee's. opposition to a stay in the case where the Comission views the open issues as a basis 'for 'the continued . suspension of the TMIA operating license. As stated in Staff's Response, a hearing on the Hartman allegations or action on the other open issues must, as a practical matter, await the results of 01's investigations on these matters. See Staff's Response at 2-4.
Continuation of footnote y from previous page 3/ disclosure" doctrine tha+ has developed under section 186 of the Atomic Energy Act. Memorandum for Harold R. Denton from Guy H.
Cunningham, III, June 17, 1983 (Legal Memorandum), at 1. The Legal tienorandum then proceeds to reiterate the correct requirement that infomation must be material to give rise to a reporting requirement:
"new information that is relevant and material" (Legal tiemorandum at
, ?; emphasis added); " failures to report material information," (id.
at 3; emphasis added); " materiality of an omission or statement,'-
(id. at 4; emphasis added); "a material matter o' such major importance,"
(Td. at 5; emphasis added). There can be no doubt that the Staff aliplied the correct standard for parties' reporting obligations.
Neither can there be any reasonable doubt that the Staff applied the "nateriality" requirement to the BETA and RHR reports. The entire analysis on pages 4 and 5 of the Legal Memorandum concerns "the question of the reports' ' tendency' or ' capability' to influence the staff."
Legal tiemorandum at 5. Such an analysis is one of " materiality" not merely " relevancy," using Licensee's own definition of " material" that a " document is not ' material' unless it has probative weight, that is, it is likely to influence the decisionmaker in making a detemination required to be made." Licensee's Response, Attachment (10) at 6, citing Weinstock v. United States, 321 F.2d 599, 701 (D.C. Cir. 1956). There should be little doubt that when infomation is capable of influencing the Staff in taking a position on issues in controversy, the information is material. As the Comission has stated, " materiality should be judged by whether a reasonable staff member should consider the information in question in doing his job." Virginia Electric and Power Company (North Anna Power Station, Units 1 and 2), CLI-76-22, 4 NRC 480, 486 (1976), aff'd, 571 F.2d 1289 (4th Cir.1978) (quoted in Legal Memorandum at 4).
In sumary, the record is clear that the Staff used the correct legal standard in determining that Licensee failed in its
! obligation to promptly report the contents of the BETA and RHR reports to the Comission and the Appeal Board.
1 B. .Tt1IA's Response .
TMIA favors proceeding with discovery on the Hartman allegations s
before 01l completes its investigation into that matter provided that discovery not proceed at an expedited pace and that discovery be scheduled such that the " full cooperation of those who might be involved in or who might have knowledge of the relevant leak rate falsification issues" is available. TMIA Connents on Licensing Board Hearing Stay, October 23, 1983 (Tt'IA's Response) at 2-3. For the reasons stated in the Staff's Response, the Staff believes that a stay of the entire Licensing Board proceeding (including discovery and hearing) is warranted and, as a practical matter, necessary.
As TIUt recognizes (TMIA's Response at 3), it is likely that the testimony of some of the knowledgeable individuals will not be available until after the statute of limitations runs on any potential crimes arising out the Hartman allegations. But, at least as far as the Staff is concerned, neither can the relevant documents be made available until after 01 completes its investigation, since the Director of OI has determined that the release of such documents which have not been already made available to the parties could jeopardize the ongoing investigation. See NP.C Staff's Answer to Aamodt Motions for Provision of Information and to lift Order of Confidentiality from Proceeding on Cheating, June 27, 1983, at 5, 8.
It appears, therefore, that there is little that can be discovered until after OI completes its investigation.
With respect to the other open issues TMIA states that there "is no reason to wait for OI to conolete its investigation into these matters." TMIA's Response at 6. TMIA seems to be referring to the l
1 l
absence of any reason to wait "before reopening the record on the.
nanagement competence and integrity issues ...." See M. at 4-5.
The o
only issue ~ on which the record has been reopened, however, is the Hartman allegations. ALAB-738. Motions to reopen the record on the basis of the other open issues were denied. H . Therefore, absent the granting by the Appeal Board or Comission of any new motion to reopen the record, there is no basis for a hearing on any of the other open issues either before or after 01 completes its investigations into those matters.bI Ir. conclusion, the Staff disagrees with TMIA that discovery on the Hartman allegations and any action on the other open issues should proceed without waiting for 01 to complete its investigations into the open issues.
C. Aamodts' Response The Aamodts oppose any continued stay of the Licensing Board's reopened hearing on Hartman allegations. Aamodt Response To Comission Order of October 7,1983 Concerning Resolution of Management Issues, 4/
~ THIA clairns that the Staff's submission to the Comission of the unexpurgated version of NUREG-1020 is a prohibited ex parte communication. TMIA's Response at 6. The Staff's submission to the Comission and Boards of the complete version of NUREG-1020 was in accordance with the Comission's August 5,1983 Statement of Policy on Investigations and Adjudicatory Proceedings, 48 Fed. Rec. 36,358, and served the legitimate purposes stated in that piiTTcy statement.
- . _ _ - ~ . . , . _ . - - - - - - - . . _ - . . _ , - - - _ - _. , - - , - - - . . . , - - - _ . _ ,
8 October 27, 1983 (Aamedts' Response) at 2. They would have the O!
~
investigation proceed in parallel with the hearing. Aamodts' Response at 3. In support of this position, they argue that the Hartman allega-tions already have been investigated, and that a public hearing will develop any additional evidence which might be needed to resolve the matter. The Aamodts cite three matters which they claim have elicited
" sufficient evidence" so that an immediate hearing is warranted: 1) the preliminary Staff investigation in 1980 (which was never completed);
- 2) the "Faegre & Benson" Report (which did not include a single interview with operators); and 3) the position taken by Babcox & Wilcox in their legal defense of the civil lawsuit brought against them by GPU. Ijd. at 9-10.
In contrast to the Aamodts' view, the Staff believes that
,conpletion of the 0; investigation is a necessary prerequisite to any hearing aimed at fully explcring and resolving the implications of the Hartmar allegations. (See Staff's Response at 2-3). The fact remains that a thorough NRC investigation of the Hartman allegations into leak rate falsification, which would allow a full and complete hearing on the matter, has never been completed. The Staff views the ongoing Of investigation as a key, and the first, ingredient in arriving at a Staff position on the inplications of Hartman's allegations for restart.
The Aamodts also allege that a separate hearing should be ordered to consider two matters "which are highly relevant to the issue of manage-ment integrity and were not fully litigated in the restart proceeding":
- 1) TMI management's " misleading" communications with the Commonwealth of Pennsylvania during the accident and 2) management's withdrawal of the projections of initial high radiation releases over Goldsborough and the related loss of in-plant radiation records. Aamodts' Response at 4, 11-12.
n 1
. -g-The Annodts make only the most cursory attempt at explaining why these matters are raised at this tima, by alluding to "other instances of withholdino of information." Jd.at11. Without further explanation of the Aamodt assertions, the Staff is unable to respond to them, other than to note that the only matter that is before the Licensing Board for herring is the Hartman allegations of falsification of leak rate data, and no motion to consider other natters is currently before the Appeal Board.
Finally, the Aamodts state that the members of the Licensing Board who presided over the restart hearing "have disqualified themselves" from further participation, and their objectivity has been discredited.
Aanodts' Response at 12. The Aamodts' attack on the Licensing Board's objectivity is unjustified and unfair. There is ncthing in the record of the restart proceeding or in the Licensing Board's conduct of the proceeding that provides any support for even the suggestion that the Licensing Board was not fully ob.iective. While the Staff disagrees with the Aamodts' criticism of the Licensing Board, the Staff would point out that, due to caseload demands, the Board has been reconstituted for the
. purpose of the hearing into the Hartman matter, with only one of the three original Board members remaining.
In conclusion, the Staff opposes Aamodts' position that hearings on the Hartman allegations and other matters proceed in parallel with 01's !
investigations because the Staff believes that completion of the OI s
e 3
_ - , , _ , . - . , m, _ , . . ....-r ,, _ . . - - - -. -- --, - --.* ,.,,,m-% ,-,-,,,._,_,-.__,-m+,, ~w.~~--,3-~, .-,,. - - . -.-- .- ---- - -
10 investigations is a prereouisite to a Staff position on the open issues andath,oroughhearingontheHartmanallegations.1/
D. IICS' Response On October 24, 1983, UCS filed the Union of Concerned Scientists' Resoonse to Comission Order of October 7,1983 (UCS' Response) with an accompanying Union of Concerned Scientists' Motion for Leave to File Response to Comission Order of October 7,1983, (UCS' Motion). The Comission's October 7th Order, however, did not grant to UCS the rioht to file its views on the stay issue since UCS did not participate in the management hearing before the Licensing Board. October 7th Order at 2. See note 1, supra. Neither does UCS have a right to file its views independent of the Comission's October 7th Order. Since UCS chose not to participate in either the original hearing on management issues or the reopened managerrent hearing on cheating, and did not file
. proposed findings of fact or conclusions of law a the Licensing Board required of the parties (see Hanagement PID 1 35, 14 NRC 381, 399), UCS may be deemed to be in default on all management issues. 10 CFR i2.754(a),(b). The Comission also would be fully justified in excluding 4
UCS from all further hearings, if any, on the management issues. See 5/ The Aamodts moved the Comission to "make an imediately effective decision to permanently deny GPUN their licenses at Unit 1." Aamodts' :
Response at 21. The Aamodts do not discuss the legal or factual basis for " permanently" denying GPU Nuclear Corporation a license to operate TMI-1. Although there are "o nn issues," the Aamodts have not i presented a factual or legal basis for such a drastic action as permanent revocation of the TMI-1 operating license. The Staff :
i therefore opposes that Aamodt motion. !
1 r
. _ _ . _ _ . _ . - . , _ _ _ _ . _ _ _ _ _ , _ _ - _ _ _ , _ _ _ ,._..._._.m._ _
-_._....._,_.-,,_.__,__._,_____-_---__m.___ __-.,___,..,m___
Public Service Company of Indiana (Harble Hill Nuclear Generating Station.
Units 1 and ?), ALAB-493, 8 NRC 253, 269 (1978); Northern States Power n
Company (Prairie Island Nuclear Generating Plant, Units 1 and 2),
ALAB-288, 2 NRC 390, 393 (1975). The Comission therefore has the discretion to consider or to disregard UCS's views on the stay issue. The Sta'f, for its part, does not favor permitting UCS to " step into and out of the consideration of a particular issue at will." Prairie Island, sucra , at 39.1 In the event that the Comission does wish to consider l'CS' views, however, the Staff provides the following response to those views.
UCS supports a partial stay of the Licensing Board proceeding but suggests that (1) discovery proceed to the extent practicable except for the depositions of pertinent operators and management, (2) the O! reports of investigation be provided to the parties after the 01 investigations are completed, and (3) the parties be pemitted to complete discovery after the Of reports are made available.
As noted above, the only issue on which the record has been reopened and on which there un be any discovery, before E after Ol's investigations are completed, is the Hartman allegations. With that in mind, the Staff reiterates its view that, as a practical matter, no meaninoful discovery can take place until after 01's investigations are completed. Consequently, the Staff believes that the entire Licensing
Board proceeding on the Hartmen allegations should be stayed until after 01 completes its investigations.6_/
III. CONCLUSION For the reasons stated ahnve and in Staff's Response to the Corrnission's October 7th Order, the Staff supports a stay of the Licensing Board proceeding, including discovery, on the Hartman allegations. The Staff also believes that 01 should complete all the relevant investigations before actions are taken on the other open issues.
Respectfully submitted, lg, k ack R. Gold erg V
Counsel for NRC Sta /
f dk((
Mary Wagner I< 1 n.
Couns for NRC S ff Dated at Bethesda, Maryland this 14th day of November, 1983 6/
~
In addition, UCS expresses its view that an ultimate decision on management competence and integrity cannot be reached until all of the "open issues" have been resolved. To the extent that UCS intends to imply by this that further proceedings should await the completion of the O! investigations, the Staff agrees with such implication for the reasons previously expressed.
UNITED STATES OF AMERICA NUCLEAR REGULATORY CM115SION a
PEFORE THE COMMISSION In the flatter of )
METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 (Three Mile Island Nuclear Station.)
j Unit No. 1) )
CERTIFICATE OF SERVICE ,
I hereby certify that copies of "NRC STAFF'S REPLY TO THE PAP. TIES' RESPONSES TO THE C0ff41SSION'S OCTOBER 7,1983 DRDER AND NRC STAFF'S ANSWEP TO UCS'S MOTION FOR LEAVE TO FILE RESPONSE TO CM11SSION'S ORDER
, OF OCTOBED 7, 198?" in the above-captioned proceeding have been served
? on the following by deposit in the United States mail, first class, or, i as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 14th day of November,1983:
4
- Samuel J. Chilk
- Christine N. Kohl i Secretary of the Comission Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety & Licensing Appeal 1 Washington, DC 20555 Board i
U.S. Nuclear Regulatory Comission ;
- *Herzel H. E. Plaine, General Counsel Washington, DC 20555 c U.S. Nuclear Regulatory Comission
- Washington, DC 20555
- John H. Buck
- . Administrative Judge
- *Ivan W. Smith Atomic Safety & Licensing Appeal i Administrative Judge Board
{
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 4 Washington, DC 20555 l' George F. Trowbridge, Esq.
- Sheldon J. Wolfe Shaw, Pittman, Potts & Trowbridge j Administrative Judge 1800 M Street, NW
, Atomic Safety & Licensing Board Washington, DC 20036 !
! U.S. Nuclear Regulatory Comission l Washington, DC 20555 .
Douglas R. Blazey, Esq.
- tir. Gustave A. Linenberger, Jr. Chief Counsel Administrative Judge Department of Environmental Rese rces Atomic Safety and Licensing Board 514 Executive House P.O. Box 2357 U.S. Nuclear Regulatory Comission Harrisburg, PA 17120
- Washington, DC 20555
- Mr. Thomas Gerusky i
- Gary J. Edles, Chairman Bureau of Radiation Protection 4 Atomic Safety 1 Licensing Appeal Board Dept. of Environmental Resources U.S. Nuclear Regulatory Comission P. O. Box 2063 Washington, DC 20555 Harrisburg, PA 17120
_ _ . _ _ _ . . .~ _ --
_ _ l. _ _ _ _ _. _ _ _ _ ____ _ _ _ _ _ _ ._..__ _ _
F 4
- Gary L. Milho111n, Esq. Honorable Mark Cohen 1815 Jefferson Street 512 D-3 Main Capital Building Madison, W1 53711 , Harrisburg, PA 17120 Mr. Marvin' I. Lewis William S. Jordan. III, Esq.
6504 Bradford Terrace Hamon & Weiss-Philadelphia, PA 19149 1725 I Street, NW Suite 506 Mr. C. W. Snyth, Supervisor Washington, DC 20006 Licensing Tt'l-1 4 Three Mile Island Nuclear Sta+. ion John Levin, Esq.
P. O. Box 480 Pennsylvania Public Utilities Com.
Middletown,-PA 17057 Box 3265 1
Harrisburg, PA 17120 Ms. Marforie Aamodt R.D. #5 Jordan D. Cunningham, Esq.
Coatesville, PA 19320 Fox, Farr and Cunningham 2320 North 2nd Street Gail Phelps Harrisburg. PA 17110 ANGRY /Till PIRC 1037 Maclay Street Louise Bradford Harrisburg, PA 17103 Three Mile Island Alert 1011 Green Street
- Allen R. Carter, Chaiman Harrisburg, PA 17102 Jcint Legislative Comittee on Energy
- Post Office Box 142 Ms. Ellyn R. Weiss 3 Suite 513 Hamon & Weiss i Senate Gressette Building 1725 I Street, NW Columbia, South Carolina 29202 Suite 506 Washington, DC 20006 i Chauncey Kepford Judith Johnsrud Mr. Steven C. Sholly
! . 433 Orlando Avenue 1346 Connecticut Avenue, NW l State College, PA 16801 Dupont Circle Building, Suite 1101 i
Washington, DC 20036 fis. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant *Dr. Lawrence R. Quarles l Postponement Atomic Safety & Licensing Appeal i 2610 Grendon Drive Board
, Wilmington, Delaware 19808