ML20107M509
| ML20107M509 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/26/1985 |
| From: | Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| CON-#185-797 SP, NUDOCS 8503010314 | |
| Download: ML20107M509 (18) | |
Text
{{#Wiki_filter:9 1, s, gCORRO OogdgTE8 +* Februaly 26, 1985 '85 Em 28 N0:45 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r r, r.- - r E r. ? :' ' p,.,,. t NOTICE TO COMMISSION, APPEAL BOARD LICENSING BOARD AND PARTIES;- In the Matter of ) ) METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP ) (Restart) (Three Mile Island Nuclear ) Station, Unit No. 1) ) On November 3, 1983, February 27, 1984 and August 9, 1984, Licensee provided copies of status reports on its re-sponse to recommendations made to Licensee in a BETA Report, dated February 28, 1983. The latest of these reports is en-closed for information. Respectfully submitted, f-sh Ernest L.
- Blake, Jr.,
P.C. SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W. Washington, D.C. 20036 (202)822-1084 Counsel for Licensee Enclosure cc: Service List 8503010314 850226 PDR ADOCK 05000289 G PDR TSO3
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~ RESPONSES TO RECOMBOATIONS OF BASIC EERGY TECHNOLOGY ASSOCIATES, NC. AS SET FORTH IN THlR REPORT DATED FEBRUARY 28,f83 SORT BY BETA FNDMG OF OPEN ITEMS SEW-ANNUAL STATUS UPDATE-1984 ISSUE DATE EBR4ARY 20,1985 i m
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TABLE OF CONIENTS i BETA FINDINGS & RECOMEleATIONS PAGE IMI-l Plant and Division 1-2 G.C. Plant and Division 3-5 Nuclear Assurance Division 6 Technical Functions Division 7-8 Administration Division 9-10 Hu. nan Resources Division 11 Radiological & Environmental Controls Division Maintenance & Construction Division Communications Division Genera 1 12-14 49
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2/12/85 BETA FINDING /
STATUS RECOMKro.
PARAPHRASED RECOMKf0ATION & SIMMRY RESPONT CAT.
DIVISION CODE COME NTS F inding III-C:
Maintenance at IMI-l can improve its support of the plant.
III-C (b)
Rect Assign system responsibility in Plant Engineering I.
THI-l R
let Q 1985 l
for maintenance tasks.
Resp Our goal remains to assign responsibility I
for each plant system to a specific engineers i.e., establish a program of " system experts".
A major reorganization of the Plant Engineering l
Department was scheduled for 4th Quarter 1984.
Because of significant efforts required for restart and steam generator repairs, this re-organization was delayed until the 1st Q 1985.
This effort is in progress and includes the assignment of responsibility for each plant system to a specific engineer. Completion let Q 1985.
l Ill-C (c)
Rect Delay assignment of corrective maintenance I.
0/P A'
Complete. Assignment after l function to MC until after Unit I restart.
restart.
I Resp formal assignment of CH function to M&C will not take place until after Restart.
Findirn III-G-1: The warehouse inventory records have enough nomenclature inaccuracies to degrade efficiency.
III-G-1 Rect Program to improve nomenclature of inventory racords.
III.
Admin./
A' Complete.
Resp Alttrugh the current M&S inventory record system THI-1/
limits description of inventory items to 40 charac-M&C M&C Division will support ters, the introduction of Arms has provided a source Materials Management in this l of improved nomenclature which, when used in con-effort to improve nomencle-l Junction with the M'0ENTS F indiruz IV-D-5: M411e maintenance is a costly way to perfonn plant maintenance.
IV-D-5 (a&b) Rect Consider negotiating agreements with better utill-IV.
M&C A'
Complete l
zation of M&ilo Maintenance. Consider makiraj Mobile Maintenance employees who perform most of thear work at Oyster Creek part of M&O Division.
Resp:
MEC Divisica is taking steps to reduce the number of M & lle Maintenance personnel located et tte site.
Mobile Maintenance personnel associated with the l
1983/1984 Oyster Creek Outage departed thn plant premises in the 4th Quarter 1984. MAC Division is workirq with JCP&L Labor Relations regardbg the question of the utilization of Mobile Maintenance personnel at Oyster Creek. Some discussion in tte l
3rd Quarter 1983 occurred properatory to the labor negotiations. Additional efforts are proposed for the 1985 labor negotiations. An effective mechanism has been established within GPIM to address this.
More current assessment in outage review pinvides i
mechanism to follow ep.
The efore, this two year l
item is considered complete.
-l Finding IV-G:
There are too many instances where rad. controls are not es good as they should be.
The work force has not accepted enough of the responsibility for high quality red work performance. Excessive generation of radioactive weste is part of these problems.
IV-G (b)
Rect Improve Red Con management and work force management I.
R&EC A*
Complete l
working relationships.
0.C./M&C l
Resp Preparation for and initial work during outage have resulted in substantial improvements in working relv tionships. A Radiation Awareness Committee has been fonned and has held routine meetings since 5/20/83.
See responses to IV-G(a) and (c). Programs are in place to improve the working relationships; however, additional effort is needed. Red Awareness Committee l
has not succeeded but will be reinstituted in January l
1985 A report is being prepared with recommended l
. actions for issuance in Febrimry 1985 to address this sivt Item IV-G(f). Recent review of radiation control practices at Oyster Creek punvides a more useful cur-rent assessment and items to follow tg> then this two year old recosamendation. Iten is considered co picte.
l 4
2/12/85 BETA FINDING /
STATUS E CONPoe.
PARAPHRASED KC0 DEEP 0ATION & SupeMRY KSPONSE CA T,,
DIVISION cme
- 00l#ENTS IV-G (f)
Rect Look to decrease number of rad. techs. as work II.
R&EC A*
Complete l
force practices good rad. work performance.
Resp:
Will reduce number of Company rad. techs as work l
practices improve. Unable to reduce due to current level of radiological understanding of workers, supervision and management at Oyster Creek. Recent review of rad. control practices at Oyster Creek H.
provides a more useful current assessment and items to follow up than this two year old recommerd Go...
Item is considered complete.
l F inesino P.'-I:
The runnber of people assigned to administrative work at Oyster Creek appears excessive.
IV-1 Rect Reduce on-site clerical ana adni..i:strative positions.
II.
0/P &
A*
Complete l
(All divisions.) Office of the President set arbitrary
. Admin.
ntsaber.
Resp Operations Analysis completed a study of 25 clerical ongoing buctjet reviews and I
positions in Oyster Creek Division. The report was OA program will coritinue to l
issued in November 1984 and most recommendations will address.
be carried out. Q/A studies are planned for Oyster Creek based Nuclear Assurarre and Red Con administra-Live support staff in 1985. We believe that further l
actions to reduce staff or con 1uct staff utilization I
analyses should result from specific requests by the l
cognizant Division Directors.
l Findirn IV-J-2: The stores and warahouse function at Ofster Creek can improve its support of the plant.
IV-J-2 (b)
Rect Carefully plan disposal of on-hand direct turnover Ill.
Admin./
A*
Complete l
material not required for plant support.
O. C.
Resp The Warehouse Reassessment Program, which was initi-l ated in September 1983, has resulted in significant operational improvements withirt the Oyster Creek ware-house. Support of the warehouse to site operations during the recent Oyster Creek outage is evidence that l
improvements have been implemelted. We recommend this l
item be closed.
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~ p_ 2/12/85 BETA FINDINC/ Sygygg E Q1MEPO. PARAPHRASED ECOMEM)ATION &
SUMMARY
RESPONSE
CAT,. DIVISION cme COME NIS F indino VI-F-3: Project engineers do not receive adequate information concerning the progress, cost and trends in progress and cost for the budget activities for which they were the originating source of authority for the modification or the major DAM project. VI-F-3 Rect Devise reports that will permit having a running III. Admin./ A* Complete l knowledge of cost and performance. 0/P Resp The Business Systems Planning (BSP) study, and two other committees (Budgeting, Estimating, and Cost Control Committee; and Plant Hodificataan Study Ten.m) have reviewed all systems, practices, etc. The three l committees established to review systems, practices and reporting have all completed their studies and have made recommendations, which were accepted by the 0/P and in some instances have been implemented. The implementation of the recommendations, together with the continued enhancements of existing cost reports, should adequately complete this findiruj. e 2/12/85 EIA FINDING / STATUS RECDMEW. PARAPHRASED RECODOEWAIION & S199fARY RESPONSE CAT. DIVISION CIE1E COD 9ENTS Findino VII-D: The cost reductions possible with more sophisticated contracting methods are not being achieved. VII-D (a) Ree: Continue training requistioners of materials and V. Admin. A* Complete l services and develop a means to measure success i of training. l Resp A number os recent contracts have been awarded which l l incorporate sophisticated award fee provisions and l l which shift the risk squarely on the shoulders of the contractors. Increased use of fixed price contracts and cometitively awarded blanket purchase orders has also occurred within the past year. Iglementation of l ApetS has improved our ability to manage this function. l l Dwerall Terma and Conditions for contracts have been i tightened in ways that benefit the Company. 1985 plans call for the development of an AAE cadre to improve contractor performance and take advantage of volume discounts. Contract administration will be improved as a rating scheme is iglemented to allow current performance by a contractor to be a determi-nant in obtaining future contracts from GPUN. Based upon progress to date, we believe it would be appro-l priate that this item be closed. l l l 9
_ m., 2/12/85 BETA FINDING / STATUS RECOMPEPO. PARAPHRASED REEDMpfpOATION & SIMMRY RESPONSE W. DIVISION CG1C CGHpfNIS F inding VII-E-4: The THI-2 entrance to the protected area uses a temporary building and manual search to control entry of personnel. This facility and its operation are inefficient in the use of guard morpower. VII-E-4 Ree: Upgrade THI-2 Processing Center including installation II. Admin. A' Complete l of metal monitors and explosive monitors. Offset is reduction in guards at THI-2. Rep: The cmstruction of a peror.nent Unit 2 Processing Center i to include electronic search equipment has been rejected due to the impending overall status change for IMI-2 that will occur when the core is removed from the ro-actor. Key carded turnstiles were installed during the l 3rd quarter 1984, but the NfC has mandated that three other capital projects be completed before they will allow a reduction in force. These three inter-related projects are funded and scheduled for completion by March 31, 1985 at which time a Physical Security Plan change will be submitted to reduce manning requirements. We recommend this item be considered complete. l Findirwi VII-E-5: The protected area perimeter alarm system at THI has an excessive number of alarms. VII-E-5 Rect Upgrade perimeter alatin systra to produce a III. Admin. A* Complet e l system with a minimun number of false alarms. Resp: Project is underway at IMI, coordinated by lectulical Functions. Estimated completion first quarter 1985. We recommend this item be considered complete. Finding VII-F: GPUN has no employee who is a medical doctor at headquarters or THI-l or Dyster Creek to oversee medical aspects of the GPUN rad. health program.' Part time contract physicians and a contractor are used for these functions. VII-F Rect Employ a physician at THI and assign medical radio-II. R&EC A* Complete l logical health responsibilities for IMI-1, THI-2, and Oyster Creek. Resp Board of Directors has agreed. Physician was re-cruited and hired 5/14/84 Position vacated 6/13/84. Replacement has been hired. Is expected to report l for work at the beginnirw; of the 2nd Quarter 1985. I l l 1 2/12/65 BETA FINDING / STATUS RECOMPEW. PARAPMtASED KCIMEWATION & 9MM5tY KSPONSE CAT. OlVISION CGIE CIMENTS Findir=1 VIII-3: Productivity at the nuclear plant sites is adversely affected by current bargaining unit employees. VIII-3 Rect Condtet review of bargaining agreements to deter-IV. H. R. A* Cnaplete. Ongoing. I mine igact on work efficiency. This is a continuing effort l Resp: Completed for Oyster Creek 4Q'83. Major emphasis but a mechanism within CPtM l has been on enforcireg management rights in current to identify and address I agreement. Remains open for THI and will be addressed these items is now in place. I prior to the May 1985 negotiatiot.s. I e 2/12/85 DETA FINo!NG/ STATUS RE CONK M). PARAPHRASED RECOHKPOAll0N & St##MRY RESPONSE M. DIVISION CODE COHK NIS Findinq XII-A Insufficient or poor supervision is contributing to poor productivity. XII-A (a) Rect Properly train supervisory personnel. V. N. A. A* Complete l Resp: Responses to other recommendations address this Gen./0P problem directly. Revised Supervisory Develap-ment Program now complete and.beinj delivered at IHI and Dyster Creek. Initial efforts at Parsippany have begun. The budjet and schedule is now in place to achieve 80% completion of the Supervisory Development Program during the third quarter 1985. XII-A (c) Rec: Managers should develop their supervisors by V. N. A./ A* Complete l observing them and instructinj them. Gen. Resp: This issue is being addressed in conjunction with the response to Reconnendation XII-A-f. New Supervisory Development Program includes management overview and involvement in the development of their subordinate supervisors. This training will be on-going and will also be an integral part of the CPUN Management Development process. The budget and i schedule in now in place to achieve 80% completinn l during the fourth quarter 1985 of the Hanagement Overview presentation given in conjunction with the Smervisory Development Program. Xil-A (j) Rect Trending of data to ascertain problem areas. 111. Admin./ A* Conplete l Resp: A major ef fort by the Operations Analysis staf f is Trending Progree ongoing l underway to enhance the indices currently reported and to encourage the use of trending within the divisions. Some divisions have already instituted trendity programs for key operatinj parameters. THI-1, for exanple, trends budget, job tickets, chemistry analysis, and radiological parameters. Rad Con trends man rees, and radiological incident reports. H&C has a trending program to identify problem areas in its operation. Q/A program for indicator development will be ongoing throughout 1985 Inasmuch as trendin) does not directly in-1 paci correcting problems of "insuf ficient or poor supervision" which is the relevant finding above, we reconnend that this item he considered complete. Operations Analysis will continue, however, to use l trending programs to assist divisions in analyzin! l their productivity. l e e m-e t 2/12/85 BETA FINDING / RE CHMIEM).. PARAPHRASED ECIDGEleATION & SUDet4RY RESPONSE. STATUS-g. DIVISION CGIE C0e#ENTS 5 XII-A (1) Rect Color-code hard hats at the site to distinguish IV. TMI-1/ A* Complete l workers, foremen, officers, contractors. Gen./0.C. Resp: Color coding of hard hats has been revised at Dyster Creek. IMI-1 and 0.C. Division Directors j have reviewed this item. At THI-1, the following coding of hard hats is now in places exempt personnel (white); Bargaining Unit personnel (IBEW) - yellow, Construction con-tractor personnel have identifying marks on hard hat to indicate their specific trade: Red Con personnel have an insignia on their hard hats for easy identification; and red hard hats are used in RWP areas. No further coding of hard hats is con-sidered necessary or appropriate. ' Action complete. 4 Findino XII-8: There is too much paper being generaten and distributed throughout the CPUN organization. XII-B (a) Rect Each division. director should help ensure distri-Admin. A* Complete l bution is necessary. Gen./0P Resp A specific cffort has been initiated at the officer level to identify and use case studies to exemplify inappropriate distribution of documents. Operations Analysis has completed paperwork reduction studies in five divisions helping them achieve an average of 18.6 percent paperflow reJuction. 0A plans similar studies in the remaining divisions. At least one year is needed to measure the effectiveness of these efforts.. In addition, Administrative Division has I established a Forms Management function to set up a I process for corporate forms generation and distribution. l As this item has been incorporated into Divisional / l Departmental goals, we recomumend this item be con-l sidered complete. l l XII-B (b) Rec Tighten signature authority; monitor for compliance. III. Admin. A* Complete l Resp: Operations Analysis has been tasked to conduct a Cen./[F l review of the approval and signature requirements Significant progress has l on all e. tsments supportive of CPUDC approval re-been made. Effective l quirements. The review is scheduled for 3rd Q 1985. mechanism has been estab-l In addition, review of the drafts of all new corpo-lished to provide ongoing l rate policies and procedures specifically seeks to effort. l identify instances where signatory authority can be l kept at lower levels. l . i l
e e e .o 2/12/85 8 ETA FINDING / STAIUS EE CtD9EW. PARAPWASED REttDDEWAil0N & SUNNARY RESPONSE CAT. DIVISION CENE ComENTS XII-B (e) Rect Limit recuired concurrences on documents /processres. III. Admin. A* Complete l Resp A formal concurrence review procedsre to clarify and l streamline handling of major corporate documents was l Implemented in October 1984 company-wide. Also, the l "1218" procedure coordinating group will seek to edu-cate egloyees concerning limiting use of concurrence for corporate procedures. This ite:n shasld be consid-ered complete. F inding XI'-Et Since the creation of CPUN, too many small groups (ceals or staffs) have been formed to carry out functions which should be handled within the normal functioning groups. XII-E Rect Each director review rarpower staffing to reesce II. 0/P & A* Complete. Ongoing efforts l unnecessary small staf f build-ups. Admin. provided by budget reviews l Resp Staffing of all Divisions is reviewed as part of and 04 program. I budget process. Staff reduction goals of I-2 per-cent were established in 1984 Further reductions l are planned for 1985 Operations Analysis conducts l 4 - 5 staffing studies annually. In addition, Operations Analysis plans to specifically study cell groups throughout CPUN in 1985. . _ _ _ _ _}}