ML20126L042
| ML20126L042 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/17/1985 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Linenberger G, Smith I, Wolfe S Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-478 SP, NUDOCS 8506190397 | |
| Download: ML20126L042 (170) | |
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-0.tTER s DIRECT DIAL psyMgER June 17, 1985 (202) 822-1215 Administrative Judges Ivan W.
Smith, Chairman Sheldon J. Wolfe Gustave A.
Linenberger, Jr.
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)
Docket No. 50-289 SP (Restart Remand on Manacement - Trainino)
Dear Chairman Smith and Administrative Judges Wolfe and Linenberger:
Enclosed is Licensee's proposed plan (Rev. 1) for satis-f l
fying the Licensing Board's long-term requirement that Licensee institute a procedure for evaluating the post-training perfor-mance of its operators in the job setting for revision of the training program.
Enclosed as attachments to the proposal are those procedures pertinent to the plan's implementation.
As explained in the proposal itself, in some cases, only discreet elements of the attached procedures are applicable to or part of the proposed plan.
In some cases, previously existent pro-cedures are applicable.
In other cases, Licensee proposes to modify its procedures to conform to the plan.
Proposed modifi-cations are highlighted by double bar indications in the g506190397850617 R
ADOCK 05000289 O
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t SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNEnSMar INCLUDING PROFESSsON AL ConPORATIONS Ivan W. Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A. Linenberger, Jr.
June 17, 1985 Page 2 attachment.
The double bars reflect both the changes Licensee initially proposed and distributed earlier, and the changes proposed by other parties and adopted by Licensee.
In accordance with the Licensing Board's Order, Licensee provided a popy of its proposal (Rev. O) to the parties on May 28 and 29.1 At that time, Licensee invited each of the par-ties to discuss with Licensee any comments or questions they might have regarding the proposed evaluation plan.
In addi-tion, a meeting was convened on June 11, 1985 to discuss the proposal.
All of the parties were individually invited to the meeting.
UCS (Mr. Jordan), TMIA (Mr. Shohet of GAP), the NRC Staff (Ms. Wagner, Mr. Persensky and Ms. Morisseau) and Licens-ee (Dr.
png,Mrs. Bauser and Mr. Washington) attended the meeting At the June 11 meeting, the parties offered their respec-tive comments on the proposed plan.
These comments in turn were addressed by either GPU Nuclear Vice President of Nuclear Assurance, Dr. Long, or by Licensee's counsel.
Satisfactory explanations were given to resolve several of the identified concerns.
Other concerns were taken under advisement by Licensee.
Licensee has seriously considered all of the suggestions made by the parties.
A number of these suggestions have been adopted.
Others have not been.
The following paragraphs sum-marize the comments of each of the parties as Licensee under-stood them, and provide the resolution to the comments proposed 1/
On May 28, a copy of the proposal was hand-served on the Commission, the Licensing Board, UCS, TMIA (Ms. Doroshow) and the NRC Staff.
At the same time, a copy was sent by Federal Express to the Commonwealth and to TMIA (Ms. Bradford) in Harrisburg.
2/
The Commonwealth of Pennsylvania did not attend the meet-ing; however, Licensee has had one conversation about the pro-posed plan with Mr. Au of the Commonwealth of Pennsylvania.
Mr. Au asked one question, concerning the periodicity of the evaluation, which appeared to be resolved by the ensuing dis-cussion.
1
SH AW. PITTM AN. PoTTs & TROWBRIDGE A PARTNERSMsP INCLUDING PROFES$1CNAL CORPORAfiONS Ivan W. Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A.
Linenberger, Jr.
June 17, 1985 Page 3 by Licensee.
Where a suggestion has not been endorsed, an ex-planation as to Licensee's rationale is provided.
Licensee notes its own self-criticism about its proposed plan that it may appear to be rather complicated.
The plan itself is not complex; it is the integration of the plan into the large num-ber of existing coordinated programs and processes in place at TMI-l that may make the proposal appear complicated.
Licensee considered developing a separate procedure which would satisfy the Licensing Board's condition.
On balance, however, Licensee felt that it would be much more advantageous to integrate the proposal into other existing TMI-1 programs and processes than to isolate it.
NRC Staff.
The Staff had seven comments.
Two were re-solved during the meeting.
The other five comments were taken under advisement by Licensee.
All five suggestions have been adopted and are reflected in the enclosed proposal (Rev. 1).
Based on this agreement, Licensee understands that the NRC Staff finds the proposal to be fully satisfactory.
The five NRC Staff suggestions were:
1.
S 3.11.6 of Attachment 9 (Procedure 6200-ADM-2682.01) contained an ambiguous reference to " job performance-oriented" evaluations.
This reference has been de-leted.
2.
The document initially designated as Attachment 3 to the proposal in fact was an enclosure (Enclosure 7) of Attachment 2 (AP-1044).
The original Attachment 3 now has replaced Enclosure 7 of Attachment 2.
The remaining Attachments have been renumbered according-ly.
3.
The proposed attachment to the initial and requalification SRO training program descriptions (Attachment 6 to Rev. 1 of the proposed plan) should include a category concerning the SRO's ability to evaluate reactor operators.
This suggestion has been adopted.
language calling for the implementation of an appro-priate course of action, based on the findings from I
the evaluations.
This suggestion has been adopted.
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SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNER 5Me# INCLUDING PmOFESSLC*tAL CQRPORATIONS Ivan W. Smith, Esquire Sheldon J.: Wolfe, Esquire
'Mr. Gustave A. l Linenberger, Jr.
June 17, 1985 Page 4 5.
Four specific clarifications should be made to
- (Procedure No. 1000-ADM-7370.04) in order to make licensed operator performance clearly subject to the evaluation process required by the procedure.
Specifically:
a.
S 4.1.1, subitem 5, after " plant," insert "and personnel";
1 b.
S 4.4.1, subitem 2, after " performance of,"
change the text to " plant systems, equipment and personnel";
i c.
S 4.4.6.2, after " abnormal performance in," in-4 sert " personnel actions and"; and d.
S 4.7, page 11.0, first full 1, second sentence, change text to " subtle aspects of system and personnel performance."
i These suggestions have been-adopted.
UCS.
UCS made a number of comments, the first four of which vere characterized as " general" and, accordingly, do not propose specific changes to'the proposed plan.. The other two-suggestions are more specific; however, they propose an ap-proach significantly at variance from the approach proposed by Licensee.
UCS' suggestions are discussed in turn.
1.
In general, UCS stated that the proposed 6-month in-terval between the completion of training and the op-erator's on-the-job evaluation was too far removed from the completion of training to provide reliable-data for.the improvement of the training program.
Licensee does-not agree with this comment and has not adopted it.
Licensee recognizes the judgment involved in specifying the amount of time after initial training that on-the-job eval-uations.should be conducted, and so indicated to UCS.
Licensee believes, however, that its proposal is the most advantageous.
As Licensee explained to UCS, i f operators were evaluated imme-diately after the completion of training, their performance arguably would reflect 1the intensity of their recent training i
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SH AW, PlTTM AN, PoTTs & TROWBRIDGE A PARTNERSM*P INCLUDING PROrt$$iONAL CompORATIONS Ivan W.
Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A.
Linenberger, Jr.
June 17, 1985 Page 5 experience, not their longer-term familiarity with their job.
For this reason alone, Licensee is uncomfortable with a shorter post-training evaluation time-frame.
In addition, as indicated to UCS, evaluations of operators' performance after a six-month period on the job will provide the supervisors with a sampling of the operators' abilities in a variety of situations which in all likelihood would not arise in a shorter time-frame.
Licensee further explained that the administrative work associ-ated with the more frequent evaluations would likely serve to unduly burden the supervisors to the detriment of their other important responsibilities.
2.
UCS recommended that the evaluation process should be individualized so that personal problems,could be differentiated from institutional problems, and so that poorer operators could receive greater attention than those with better performance records.
Licensee has considered this general comment and considers it to be no more advantageous than the approach it pro-poses; accordingly it has not been adopted.
Licensee does not believe this comment is a cause for con-cern because the supervisors' intimate familiarity with their crews allows them to discern the difference between individual (or personal) and institutional problems.
The supervisors are aware of the varying strengths and weaknesses of each operator that they evaluate.
Moreover, management personnel in the Operations and Training departments will review the su-pervisor's report and, should an operator exhibit any perfor-mance deficiencies which, for example, merit individual atten-tion, management will have discussions with the individual operator.
The purpose of the Licensing Board's condition is to provide an additional mechanism for validating the adequacy of training.
By requiring evaluations of each operator, it will be possible for Training to evaluate whether generic weaknesses in the training program exist or, conversely, whether an indi-vidual operator is exhibiting weaknesses in an area.
Licensee does not believe it is necessary and perhaps might be less advantageous, to have an individualized evaluation process which would result in a different number and scope of evalua-tion for each operator.
This UCS suggestion would make it very difficult to compare evaluations with each other and to make across-the-board judgments about training.
As a practical mat-ter, it also would be extraordinarily difficult to accomplish.
(
SH AW, PITTM AN, PoTTs & TROWBRIDG E A PARThER$5 ssp INCLUO'NG PROFES$sONAL CORPORATIONS Ivan W.
Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A.
Linenberger, Jr.
June 17, 1985 Page 6 3.
UCS recommended that as a part of responding to the evaluations that are conducted of licensed operators, Licensee's proposed plan include in it considerations as to how the job should be changed because of the findings reached.
Licensee has considered this gen-eral comment and believes that it is outside the scope of the Licensing Board's order; as well, this issue is addressed through other means at TMI-1.
Licensee does not believe this general UCS suggestion is an element in the development of a plan to evaluate the post-training performance of operators for revision of the training program.
As described during the reopened proceeding, there are a variety of mechanisms in place at TMI whereby inconsistencies between training and performance are assessed and, as necessary, changed.
For example, changes to procedures effectively change the operator's job.
Licensee does not be-lieve that it is necessary for its proposed evaluation plan, which is designed to validate training, to formally address job modifications.
Licensee does note, however, that part of the TSD process, described in Attachment 9, is to do a needs analy-sis, which includes assessment of where there is a need for change, based on a formal evaluation (including the proposed on-the-job evaluations).
The needs analysis could precipitate a job change.
4.
UCS inquired about the method of operator evaluatic.n.
It also indicated its concern with the subjectivity of the shift supervisors, who will evaluate operators on-the-job.
Licensee has not adopted any changes in response to this comment.
At the June 11 meeting, Licensee explained to UCS the method by which the operators would be evaluated.
Licensee also stated its view that the Operations supervisors were in the best position to conduct on-the-job evaluations and, in fact, other individuals probably would not be able to conduct such evaluations effectively.
5.
UCS specifically proposes, in accordance with Dr. Regan's suggestion, that Licensee conduct reviews of operators on a daily and weekly basis, with declining frequency based on the adequacy of operator performance and the importance of the task, using a
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n-SHAW. PITTMAN, POTTs & TROWBRIDGE A PARTNER $Mep INCLUDING PROFESSIONAL CORPORATIONS Ivan W. Smith, Esquire Sheldon J. Wolf e, Esquire Mr. Gustave A.
Linenberger, Jr.
June 17, 1985 Page 7 sample of tasks from the detailed OJT checklist.
This job would be done by the shift supervisor.
This proposal would be in lieu of Licensee's proposed pro-cess for conducting on-the-job evaluations, which Dr.
Regan essentially rejects.
Licensee has considered this proposal; however, for a number of reasons, Licensee has not adopted it.
}
Licensee b'elieves that UCS' suggestion for daily and weekly evaluations using a detailed OJT check list reflects a fundamental difference between the UCS and GPU Nuclear concepts of performance evaluation.
Licensee views the performance evaluations done six months after completion of training and annually thereafter as the su-pervisors' composite reviews of individual employees' perfor-mance over the six month (or year) interval.
Exhibit 2 of (T&E Procedure 6200-ADM-2682.10) and Attachments 5 and 6
(" Areas of Evaluation") guide the supervisors through re-flective evaluations of each individual licensed operator's performance in the various aspects of his job, both as an indi-vidual and as a member of a shift crew.
Any plant incidents or potentially reportable events involving plant operators are recorded and evaluated in accordance with AP-1029 and AP-1044.
During the six month (or year) interval, supervisors will have opportunities to observe operators' performances in various areas listed in the " Areas of Evaluation."
Performance in the majority of these areas is covered by detailed plant procedures and the supervisors closely monitor compliance with these pro-cedures.
In contrast, UCS appears to view performance evaluations as discreet events in time in which supervisors observe indi-vidual employees performing one or more tasks identified in the job / task analysis and specifically taught in the training pro-gram.
The supervisors would have in hand check lists of the various steps in the tasks along with written criteria for de-termining whether or not each step is performed satisfactorily.
Licensee believes that these UCS check lists are comparable to the detailed check lists which are used by Licensee to verify the satisfactory completion of on-the-job training tasks for candidate licensed operators.
These OJT checklists for candi-date ROs and SROs are 136 and 70 pages long, and include 437 and 191 tasks, respectively.
It takes approximately 7 and 4 l
i-
m SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNERSpetP DNCLUDING PROFESSIONAL COR*CRAftONS Ivan W. Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A.
Linenberger, Jr.
June 17, 1985 Page 8 months on-the-job for the candidate RO and SRO, respectively, to obtain the supervisors' approval of satisfactory mastery of these tasks.
Licensee does not believe that it is necessary, nor is it an effective use of supervisors' time, to repeat these detailed OJT check-out observations on each licensed op-erator in the six month and one year interval following comple-tion of initial or requalification training (muchless on a daily or weekly basis, as UCS suggests). Supervisors only have so much time available to them to do their job.
It is impor-tant that the on-the-job evaluation process not create a sig-nificant distraction for the supervisors from their other du-ties.
The supervisors' basic responsibility is to ensure that each operator is performing satisfactorily and functioning as an effective member of the control room team.
Performance evaluations, as proposed by Licensee, along with the regular exchange of information between Operations and Training person-nel described in detail during the remanded proceeding, will ensure effective feedback into the training program of operator performance in the job setting for revision of the training program where appropriate.
6.
The.second part of UCS' specific proposal, which would replace Licensee's proposed plan, is to require simulator (and possibly other job) tests, randomly given to a sample of operators, and given indepen-dently of the training program.
The frequency of these tests had not been determined.
The purpose of this process would be to test operators, indepen-dently of their training program, and according to their individual needs and capabilities. Licensee does not believe that this UCS suggestion is respon-sive to the Board's requirement for on-the-job evalu-ations for feedback into training.
Consequently, the suggestion has not been adopted by Licensee as a part of its proposed plan.
Licensee has not adopted the UCS simulator proposal as a part of its proposed plan.
Licensee does, however, favor fre-quent use of the simulator and, for example, already has imple-mented regular use of the Basic Principles Training Simulator during requalification training.
This was reflected in Licens-ee's testimony during the reopening proceeding on training.
Moreover, following completion of on-site final acceptance testing of the TMI-l replica simulator, licensed operator l
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e SHAW, PITTMAN, PoTTs & TROWBRIDGE A PARTNERSecP lhCLUD8NG PROFESSIONAL CORPORATIONS Ivan W.
Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A.
Linenberger, Jr.
June 17, 1985 Page 9 requalification training also will include use of the replica simulator throughout the training cycle.
This will increase the number of hours of simulator training and frequency of ex-posure to the simulator each year.
Evaluations of operators at the replica simulator will be performed by licensed or certi-fied SROs.
Simulator drill guides will specify performance-based instructional and/or scenario objectives, which will in-clude acceptance standards for real plant operations, and guidelines for evaluation of training performance.
Any identi-fied deficiencies will be used in the development of subsequent training.
These replica simulator sessions will be very "real," in that the operators will be required to use current plant procedures and will follow the approved procedural, ad-ministrative and equipment limits and precautions which have been established for TMI-1.
Although not independent of the training program, Licensee's simulator program currently in ex-istence and, as proposed when the TMI-l replica simulator is available, will provide another vehicle for realistic evalua-tions of operator performance.
This view was expressed by Licensee in.the reopened proceeding.
It is not, however, part of Licensee's proposed plan for conducting on-the-job evalua-tions of operators.
TMIA.
On June 11, TMIA provided to Licensee two somewhat general comments about the proposed p These comments were furtherspecifiedonFriday, June 14.-}pn. Licensee does not be-lieve that TMIA's comments raise concerns which require modifi-cation of the proposal.
l.
TMIA expressed concern about the subjectivity and qualifications of the shift supervisors to perform the evaluations in question.
Licensee discussed with TMIA the Zenger-Miller supervisory training given to supervisors which addresses, inter alia, supervisory skills in assessing employee performance.
As previ-ously stated, Licensee believes that the Operations 3/
At 11:00 a.m. on Friday, June 14, Mr. Shohet of GAP called Licensee's counsel and indicated that " time constraints" pre-vented TMIA from providing Licensee in writing with its com-i ments before Monday, June 17.
Licensee notes, in this regard, that the proposed plan has been in TMIA's hands for over two weeks.
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SHAW, PITTM AN, PoTTs & TROWBRIDGE A PARTNER $ Map INCLuCING PROFESSIONAL CORPORATIONS Ivan W.
Smith, Esquire Sheldon J. Wolfe, Esquire Mr. Gustave A. Linenberger, Jr.
June 17, 1985 Page 10 supervisors are the most qualified and the best situ-ated to perform on-the-job evaluations of licensed operators; accordingly, TMIA's concern has not prompted any change in Licensee's proposed plan.
2.
TMIA commented that the proposed " Areas for Evalua-tion" forms (Attachments 5 and 6) lack sufficient de-tail.
No specific alternative level of detail was offered.
As previously stated, Licensee does not be-lieve that a detailed check list, such as the OJT check list, is necessary nor would it be practical.
Attachments 5 and 6 were derived from the OJT check lists and, in Licensee's view, adequately identify for supervisors the areas that should be considered in making performance evaluations.
Licensee' there-fore has not adopted any changes pursuant to this comment.
On June 14, TMIA also specifically endorsed UCS' prefer-ence for more frequent evaluations, and generally endorsed UCS' June 11 comments.
Our response to UCS' suggestions are addressed above.
Licensee believes that its proposal is fully responsive to the Licensing Board's concerns and urges the Board to approve the plan as proposed.
Using this proposal, along with the many other formal and informal mechanisms in place at TMI-1, Licens-ee will thoroughly evaluate TMI-l licensed operators and ensure that operators are being taught what they need to know.
Sincerely, bA/Arral N.
Deborah B.
Bauser Counsel for Licensee DBB:jah Enclosures cc:
per Certificate of Service n
nr O
ItEl.ATED CORRESPONDENCE June 17, 1985 80CKETED USNRC
'85 JUN 18 A10 56 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION b
ifb b5 '?' '
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter if
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart Remand on
)
Management - Training)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
I hereby certify that copies of a letter dated June 17, 1985 from Licensee's counsel to the Licensing Board with at-tachments were served this 17th day of June, 1985, by hand de-livery upon the parties identified by one asterisk and by de-posit in the U.S. mail, first class, postage prepaid, upon the other parties on the attached Service List.
49M 4. /bau -
Deborah B.
Bauser n
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart Romand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J. Palladino, Chairman
- Administrative Judge U.S. Nuclear Regulatory Commission Gustave A. Linenberger, Jr.
Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Thomas M. Roberts, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Gary.T sdles James K. Asselstine, Commissioner Che'. nan, Atomic Safety and U.S. Nuclear Regulatory Commission micensing Appeal Board l
Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 Dr. W. Reed Johnson Atomic Safety and Licensing Lando W.
Zech, Jr., Commissioner Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 l
- Administrative Judge Administrative Judge Ivan W. Smith #
Christine N. Kohl Chairr.an, Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
- Administrative Judge Docketing and Service Section (3)
Sheldon J. Wolfe Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
rz-e SERVICE LIST PAGE 2 Atomic Safety and Licensing Mr. Henry D. Hukill Board Panel Vice President U.S. Nuclear Regulatory Commission GPU Nuclear Corporation Washington, D.C.
20555 P. O. Box 480 Middletown, PA.
17057 Atomic Safety and Licensing Appeal Board Panel Mr. and Mrs. Norman Aamodt U.S. Nuclear Regulatory Commission 200 North Church Street Washington, D.C.
20555 Parkesburg, PA.
19365 Jack R. Goldberg, Esquire
- Mrs. Louise Bradford Office of Executive Legal Director TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C.
20555 Harrisburg, PA.
17102 Thomas Y. Au, Esquire Joanne Doroshow, Esquire Office of Chief Counsel The Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C.
20002 505 Executive House P. O. Box 2357 Lynne Bernabei, Esquire Harrisburg, PA.
17120 Government Accountability Project Michael F. McBride, Esquire 1555 Connecticut Avenue LeBoeuf, Lamb, Leiby & MacRae Washington, D.C.
20036 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan Michael W. Maupin, Esquire 2001 S Street, N.W.,
- 430 Hunton & Williams Washington, D.C.
20009 707 East Main Street P.
O. Box 1535 Richmond, VA.
23212
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.s June 17, 1985 - Rev. 1 1
(May 28, 1985 - Rev. 0)
PROPOSED EVALUATION PLAN 1.
INTRODUCTION On May 3, 1985, the Atomic Safety & Licensing Board issued its Partial Initial Decision (PID) on the remanded issue of licensed operator training at TMI-1.
In its decision the Board concluded that the TMI-l licensed operator training program is adequate to train reactor operators and senior reactor opera-i tors to operate the unit safely; provided that Licensee insti-tute a procedure for evaluating after training the performance of its trained operators in the job setting for revision of the training program.
The Board stated that implementation of this requirement should be effective but the license should not be laden with any unnecessary detail.
The Board also reaffirmed l
its position that an order imposing an operator evaluation con-dition would be considered a long term requirement within the meaning of the notice of hearing and that, consequently, imple-mentation need not precede restart.
Licensee will have demon-strated reasonable progress toward the completion of this requirement if it begins immediately to satisfy the require-ment.
The purpose of this submittal is to respond to the Board's order that Licensee, within thirty days of the PID, present to the NRC Staff and other participants in the remanded proceeding its proposal for an evaluation plan.
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2.
BASIC PLAN Upon receipt of the PID, Licensee began immediately to prepare a plan to meet the Licensing Board condition.
This proposed plan creates a formal, periodic mechanism for evaluating licensed operators on the job for the purpose of validating and revising the licensed operator training program.
There are three elements included in the basic plan:
1.
For abnormal events involving licensed operators, the ex-isting Technical Functions Procedure 1000-ADM-7370.04,
" Analysis of GPUN Plant Transients (Post Trip Review)"
Rev.
O, 11/15/84, requires the identification of unexpect-ed, abnormal responses to a trip by personnel.
This pro-cedure and the existing TMI-1 plant procedure for evalua-tion of abnormal events (AP-1044, entitled " Event Review and Reporting Requirements," Rev. 13, 12/29/83) will be revised to more clearly indicate the requirement to evalu-ate the specific response and performance of the licensed operators.
Procedure 1000-ADM-7370.04 already provides for evaluating training impact and feeding back any recom-mended changes to the licensed operator training program.
In addition, TMI-1 plant procedure, AP-1029, entitled
" Conduct of Operations," Rev. 14, 6/17/84, provides a pro-cess for reviewing incidents occurring on shift which, although viewed as not potentially reportable, could re-quire some corrective actions, including revision to the licensed operator training program.
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2.
A routine on-the-job performance evaluation will be per-formed for each individual licensed operator six months after his/her initial licensing and thereafter annually.
The existing procedure on trainee evaluation, 6200-ADM-2682.10 Trainee Evaluation Once Back On-The-Job, Rev.
O, 4/15/85, along with the licensed operator training program descriptions, will be revised to reflect the re-quired routine on-the-job performance evaluations.
3.
The Training Systems Development (TSD) process (Procedure 6200-ADM-2682.01, " Training and Education Department Training System Development Process" Rev.
O, 4/15/85) used by Licensee ensures incorporation of any revisions indi-cated by the on-the-job evaluation process into the appro-priate training program descriptions and lesson plans.
3.
DESCRIPTION OF EVALUATION PROCESS The formal mechanism used to evaluate TMI-l licensed oper-ators for the purpose of validating and/or revising the initial and requalification licensed operator training programs in-cludes three primary components already in place and described in the PID:
simulator evaluations, drills, and written and oral examinations.
While part of the operator evaluation pro-cess, they are not part of this proposed plan.
The components of the operator performance evaluation plan outlined in Section 2 include the evaluction of performance during an abnormal and/or potentially reportable event and the formal evaluation of routine on-the-job performance.
Technical Functions Procedure 1000-ADM-7370.04, entitled,
" Analysis of GPUN Plant Transients (Post Trip Review)," estab-lishes a consistent method for conducting the analysis of the GPUN plants' performance during transient events.
This proce-T dure is provided as Attachment 1.
The procedure (S 4.1.1, subitem 2) specifically includes requirements to identify any unexpected or abnormal response to a transient by plant person-nel and to review the records of operator actions and plant ac-tivities affecting an event (SS 4.1.2 and 4.7.1.1.7).
The
" Transient Assessment Report" (Exhibit 5oftheprocedurb) in-cludes a section entitled, " Operator Action / Procedural Adequa-cy" which focuses on operator actions taken during the tran-sient.
And the Procedure Flow Chart (S 5.1.16 and Exhibit 1) indicates, as part of the review process, evaluation of training impact and subsequent change to appropriate training programs.
It is proposed that a few minor revisions to Sec-tions 4.4.2, subitem 4, 4.4.2, subitem 5, 4.7, and 4.7.1.1.7 ll will be made to this procedure to more clearly indicate the requirement to evaluate licensed operator response during each step of the analysis process.
TMI Administrative Procedure AP 1044, entitled, " Event Re-view and Reporting Requirements," specifies the applicable evaluation and reporting requirements when an event has oc-curred which may require notification of NRC representatives and/or company management.
AP 1044 is provided as Attachment
- 2. of AP 1044 is the potentially reportable event N,
e form which is filled out by the shift supervisor.
GPUN pro-poses to revise Enclosure 7 to include:
a requirement for the shift supervisor to comment on potential training-related deficiencies and/or necessary training program changes which he finds as a result of the event; expansion of the distribution list to include the Man-ager of Plant Training, Manager of Plant Analysis in Parsippany and the Plant Analysis Manager, TMI-1. also requires a detailed description of the event, plant status and immediate corrective actions.
TMI-l Administrative Procedure AP-1029, " Conduct of Opera-tions," in Section 5.10 describes the steps to be taken when an event occurs or finding is identified that places the plant or personnel in an unsafe condition, but where the event is not viewed as potentially reportable under AP-1044.
AP-1029 is provided as Attachment 3.
The review process under AP-1029 ll provides for a copy of each incident report to be sent to the Training Department for inclusion in the operator training pro-gram as applicable.
The proposed process for the evaluation of routine on-the-job performance will be accomplished by a combination of two elements.
The first element is a proposed revision to the generic procedure for evaluating trainee performance once back on the job.
The second element consists of proposed revisions to the program descriptions for licensed operators to include position specific (RO and SRO) lists of areas to be evaluated..
I The GPU Nuclear Training Systems Development process contains a generic procedure for evaluating trainee performance once back on the job which is 6200-ADM-2682.10.
This procedure is provided as Attachment 4.
Due to the range and variation of ll training programs within GPU Nuclear to which this procedure applies, it has been deliberately designed to allow administra-tive flexibility.
Included as Exhibit 2 of this procedure is a proposed revised supervisor's survey of the employee for whom the supervisor is responsible.
In addition, Licensee will use position-specific areas for evaluation for evaluating ROs and SROs on the job.
This will ensure coverage of the breadth of on-the-jcb activities when the supervisor is evaluating the questions contained in Exhibit 2 of Attachment 4.
These areas for evaluation will be included ll as an attachment to each of the licensed operator training pro-gram descriptions, and are provided as Attachments 5 and 6.
N Licensee also will revise the training program descriptions to include the provision for required on-the-job performance eval-uations. provides the proposed language for the N
proposed program description revisions.
4.
IMPLEMENTATION The supervisory performance evaluation, "Once Back On-The-Job," shall be conducted approximately six months after a candidate has received his/her license utilizing Exhibit 2 of 6200-ADM-2582.10 (Attachment 4) to evaluate training related 0..
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performance in the areas listed in the areas for evaluation for ROs and SROs (Attachments 5 and 6).
Subsequent evaluations N
shall be done on an annual basis as part of the requalification process.
The completed evaluations shall be forwarded to the Manager of Plant Operations TMI-l for review and comment.
Upon completion of this phase of the review, the document s will be transmitted to the Operator Training Manager who will 01:o re-view and comment as appropriate.
The documents will then be transmitted to the Supervisor of Licensed Operator Training who will prepare a summary report of all of the observations and recommendations made by the supervisory personnel.
When the report is complete, the Super-visor Licensed Operator Training, Operator Training Manager, and Manager of Plant Operations TMI-l will meet to review the scope of the summary report and determine an appropriate course of action for each of the recommendations.
The meeting shall be conducted consistent with the TSD Procedure, 6200-ADM-2682.03, " Technical Content Review & Interface Pro-N cess," which is provided as Attachment 8.
The operator training program descriptions will be modified to reflect the above described process for handling licensed operator perfor-l mance evaluations.
The above-described process is consistent with the l-i.
Training Systems Development process (T&E Procedure 6200-ADM-2682-01), used by Licensee.
This procedure is pro-
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vided as Attachment 9.
Through its supporting procedures, TSD 0
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ensures that all proposed revisions of training are systemat-ice.11y analyzed for incorporation into training program de-scriptions and lesson plans as appropriate.
5.
SUMMARY
AND CONCLUSION The TSD approach to training implemented at TMI-l is a dy-namic process that ensures that training is performance based.
Consistent with the TSD approach, a number of procedures are in existence, both formal and informal, that require the perfor-mance of licensed operators to be reviewed and fed back to Training.
The purpose of this proposed plan is to add to these procedures additional requirements for formal on-the-job per-formance evaluations.
All of the components of the evaluation process will be used to validate and revise, as appropriate, the licensed operator training program.
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ATTACHMENTS 1.
Technical Functions Procedure 1000-ADM-7370.04, " Analysis of GPUN Plant Transients (Post Trip Review)"
2.
TMI-l Administrative Procedure AP 1044, " Event Review and Reporting Requirements" 3.
TMI-l Administrative Procedure AP-1029, " Conduct of Operations" 4.
TSD Procedure 6200-ADM-2682.10, " Trainee Evaluation Once Back On-The-Job," Rev. O, 4/15/85 5.
Proposed Attachment to Initial and Requalification RO Training Program Descriptions 6.
Pr. posed Attachment to Initial and Requalification SRO Training Program Bescriptions 7.
Proposed Change to TMI-l Operator Training Program Descriptions 8.
TSD Procedure 6200-ADM-2682.03, " Technical Content Review & Interface Process," Rev.
O, 4/15/85 9.
TSD Procedure 6200-ADM-2682.01, " Training and Education Department Training System Development Process" Rev.
O, 4/15/85 O
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LIST OF MODIFICATIONS TO ATTACHMENTS 1!
WHICH CONFORM ATTACHMENTS TO PROPOSED PLAN :
Technical Functions Procedure 1000-ADM-7370.04,
" Analyses of GPUN Plant Transients (Post Trip Review)" Rev. O, 11/15/84.
p.
1.0 List of effective pages p.
3.0 4.1.1 part 5 p.
6.0 4.4.1 part 2 4.4.2 part 4 and part 5 p.
8.0 4.4.6.2 p.
10.0 4.7 p.
11.0 4.7
'4.7.1.1.7 :
TMI-l Administrative Procedure AP 1044, " Event Review and Reporting Requirements."
Cover page List of effective pages p.
33.0 :
TMI-1 Administrative Procedure AP-1029, " Conduct of Operations."
No modifications necessary Training and Education Procedure 6200-ADM-2682.10
" Trainee Evaluation and Back On-The-Job" Rev. O, 4/15/85 p.
1.0 List of effective pages 1/
All proposed changes to attachments made by Licensee in Rev. O or, in response to comments, in Rev. 1 of the Proposed Plan'are reflected by double bar indications in the right-hand margin of each attachment.
6 p.
2.0 2.2 4.1.4 4.1.5 p.
4.0 4.3.4 4.3.4.1 p.
5.0 4.5.3 4.6 p.
6.0 5.3.3 Exhibit 2 Supervisor's Survey :
Proposed Attachment to Initial and Requalification RO Training Program Descriptions Newly developed :
Proposed Attachment to Initial and Requalification SRO Training Program Descriptions.
Newly developed :
Proposed Change to TMI-l Replacement Operator Training (RO) (SRO) and Licensed Operator Requalification Program Description.
Newly developed :
Training and Education Procedure 6200-ADM-2682.10,
" Technical Content Review and Interface Process" No modifications necessary :
Training and Education Procedure 6200-ADM-2682.01
" Training & Education Department Training System Development Process" Rev.
O, 4/15/85 p.
1.0 List of effective pages p.
10.0 3.11.6
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OF CHANGE APPROVAL DATE 1
This revision supersedes previous procedures issued with the number EP-029.
Rev. O refers to " Document Distribution" and not the subject of this series l
2 Revised to include plant transients at i
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3 Deleted reference to LP-003 0-00 Extensively rewritten to include new corporate fermat and include requirecents of NRC Letter 83-28 for Post Trip review of transients.
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l 1.0 PURPOSE This procedure establishes a consistent cethod for conducting the tech-nical analysis of TMI-1 and OC plants' performance during transient events.
2.0 APPLICABILITY / SCOPE 2.1 This procedure appifes to the Technical Functions Division, and other divisions within GPUN which are responsible for performing specific tasks associated with the review and analysis of tran-sient events.
This procedure does not apply to THI-2, 2.2 This procedure applies primarily for reactor trips, but can be used for guidance in conducting the technical review of non-reactor trip transient events, as determined by the Director, Systems Engineering and the Station Operations Director.
3.0 DEFINITIONS 3.1 TRANSIENT EVENT - Any unscheduled reactor tric, or unscheduled power excursion, or other event whicn in the estimation of management warrants an evaluation.
3.2 TRANSIENT ASSESSFENT REPORTS (TAR) - A comerehensive analysis of a transient event anc its inpact.
It includes a secuence of events, a discussion of nuclear safety concerns, and corrective action assignments.
3.3 TRANSIENT ASSESSMENT PROGRAM (TAP) - A crogran to improve infor-mation flow among B&W operating utilities concerning lessons learned free operating plant experience (described in Transient l
Assessment Program Guidelines 2&W Report 12 -1122130-Re v).
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l 3.4 POST TRIP REVIEU GROUP (PTRC) - A group consisting of a Plant I
i Analysis, Plant Operations and Plant Engineering representative called together immediately after an event to gather, analyze and report on 11 formation, data and events that took place at the i
time of the transient event.
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3.5 NUCLEAR NETWORK - A conputer assisted reporting and infernation excnango system whereby timely information is fed to a central computer anc can be retrieved by member utfifty users.
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' me Analysis of GPUN Plant Transients (Post Trip Review) 0-00 4.0 PROCEDURE RE0VIREMENTS 4.1 General j
4.1.1 This procedure establishes guidelines for a systematic method of conducting the technical review and analyses of Oyster Creek and TMI-1 plant performance associated with reactor trips in order to:
i 1.
Determine the it:rnediate and root cause(s) of the trip.
2.
Identify unexpected, abnormal response to the trip by plant systems, equipment, and personnel, j
3.
Assess the impact of identified abnormalities on nuclear safety, equipment reliability, system performance, and availability.
- 4. Develop corrective actions /recortunendations to prevent the recurrence of the trip and mitigate abnormai responses.
a-L ra d 5.
Document observed plant, behavior for use in subse-quent evaluations.
6.
Satisfy reporting requirements.
4.1.2 The GPUN Reactor Trip Review Program implemented at TMI-1 and Oyster Creek applies to every reactor trip, planned and unplanned. However, planned reactor trips need not undergo all phases of the review if response is noma 1.
The scope of the information reviewed under the :rogram is sufficient to accomplish its objectives and includes data on plant system behavior, actuation and secuence Of ecui:-
ment operation, and records of operator actions and plant activities affecting the event. The program prescribes activities that are performed imediately following a trip, prior to restart, and continue through a subsequent l
in-depth evaluation that supports preoaration of internal and external reports. The program also outlines the criteria for determining the approval and concurrence 5
levels for plant restart.
4.1.3 The programs major steps are 111ustrated in Exhibit 1.
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Analysis of GPUN Plant Transients (Post Trip Review) l 0-00 The reactor trip review program consists Of four distinct phases:
1.
Post-Trip Review 2.
Independent Review l
3.
Restart Decision 4
Subsequent Evaluation Every reactor trip will be subjected *w a Post-Trip Review and Restart Cecision. Only reactor trips with abnornali-ties identified will undergo an Independent Review.
In such cases, this review will be completed prior to the Restart Cecision. Planned reactor trips, where no abnor-malities have been identified, need not proceed to the subsequent Evaluation phase. The najor elements of each of these phases is described in following sections.
4.2 Roles and Authorities 4.2.1 Various Plant and Technical Functions personnel coordinate their efforts in the post-trip review program. An over-view of the entire program can be seen in the Analysis of l
Plant Transients Flow Chart (PC-002) and is outlined in I
the steos in Section 5.0.
The role of each participant is surnarized below.
1 A.2.1.1 Plant Ocerations is resconsibie for coera-ting the plant. Under the progran, tne l
Chift Supervisor (SS) is res;:ensible for notf #ying plant nanagement of a transient event. The Shif t Tecnnical Advisor (STA) is l
the Technical Functions' contact with the l
operating ciant.
- he S*A is resocnsibie #cr notifying *echnical functions (77) ::ersonnei per TF Engineering Standard ES-COS, *STA Cuties and i
Resconsibilities".
The Coerating Crew alor'g with the STA, are responsible for diagnosing i
and controlling tne event and thus will nave fiasthand knowledge of the event. *his information is to be prerotly docurented to f'
l help ensure that a corplete record of the event is obtained.
I d.2.1.2 Thrs Plant Analysis Section at the operating i
si:e is resconsible for supcorting the Post
- rip Review. The Plant Analysis Section 3
recorts to the Oirector of Systers Engineer-i ing and thus will provide an indecenc'ent i
assessment of the olant's behavior and the I
acceptability of restarting.
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, Aevision No Analysis of GPUN Plant Transients (Post Trip Review) 0-00 Post-Trip Review rust be corpleted and dccu-mented prior to restart.
In addition, Plant Analysis will perform the subsequent evaluation, if necessary.
4.2.1.3 Various Technical Functions Departrents, especially Systems Engineering, and Engi-neering & Cesign, will provide analytical and technical support and recommend correc-tive action as required I
4.2.1.4 The Plant Engineering, and Operaticas &
l Maintenance Departments will make a j
j prelininary determination of the root cause(s) of the event and specify and i
implement corrective actions.
I 4.2.1.5 Plant Management is responsible for deter-mining when and how the unit is to be restarted.
4.2.1.6 Technical Functions is responsible #or con-curring with restart Plans and corrective actions.
4.2.1.7
- n addition, the Indeoendent Cn-Site Review Group and Plant Review Grouc ray conduct additional evaluations.
i 4.3 Oualification Recuirerents Technical Functions individuals will serve in the transfert event review and analysis function.
- ndependent of their cuaii-fication for a particular position via expertise in an engineer-ing, science, or operational discioline, it is also recuired that all cognizant individuals in charge of tne analysis process be qualified either as responsible tecnnical reviewers or inde-pendent safety reviewers. Certain analysis nay be performed by non-qualified individuals as long as it is under direct sucer-vision of a qualified individual.
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Personnel certifying completion of steps in the review process I
will be qualified to one of the below levels:
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4.3.1 Senior Peactor Operator (SRO) i 5
4.3.2 Shift Technical Advisor (STA)
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4.3.3 Responsible Technical Peviewer In R) l 4.3.4
- nd? pendent Safety '.eviewer (!SP) i 5.0
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4.4 Post Trio Review The Post-Trip Review is performed irrediately after plant stabi-i l
11:ation from a trip and compieted prior to restart.
4.4.1 Purcose The purpose of the Post-Trip Review i: to:
1.
Cetermine the causc(s) of the trio.
2.
Identify other-than-expected. performance of plant systems and equipment M M.
0 3.
Assess the im, pact of identified abnornal perfor-I mance on safe operation.
4 Specify corrective actions required to restart.
5.
Ensure continued availability of information and data pertaining to the event.
a.4.2 Sccoe The sccce of the Post-Trip Review has been established to ensure tnat abnormal performance in inocetant sys-tems wiii be identified. Guidelines and criteria, which define the range of ex ected rescense, are used in the process. The rajor eierents of the P0st ' rip Review, and the responsible lead organization are:
1 Plant Analysis with assistance fecr Station Operations, will gather plant data.
2.
The res;:ansible Station Ccerations :ecartrent will make a preliminary determination of tne cause(s) of the trip.
3.
Plant Analysis wiii rake a :reiiminary deter-mination of the reactor trio secuence.
4 Plant Analysis will review tne pre and :ost-trip behavior of key parameters t9at reflect overail plant perforrance and wili tentatively identify abnormai Jerformance of imcortant systen s, e y <s ync a~ y pwn~e /.
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Plant Analysis will review the performance afa 2:
ud dimportant systems and ecuipment, both safety and
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control, to tentatively identify otner-than-expected response to tne trip.
e-6.
The responsible St stion Operations Cesartrent or Technical Functions Section will conduct additional review as recuired based en identified abnormal response.
7.
The rescensible Station Oceraticrs cepart ent and Technical runcticns witi identi#y correct've 3
j' actions that must be cere'eted cr4cr te -es*=
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I 0-0C 4.4.3 Data Coltection 4.4.3.1 The data soecified in Exhibit 2 shall be gathered as soon after each event as prac-tical. This data will form the basis of event analysis and shall be naintained as a permanent record.
In as much as the data to be used in the analyses may be original plant docurents j
such as legs, recorder charts, etc., care shall be expressed when using them. It is advisable to use a photostatic copy of this material whenever possible.
4.4.3.2 The Piant Computer System will be a prire source of data used to determine and evai-uate plant response.
Lhen the computer is not available much of the data specified in Exhibit 2 will not be avafiable. Cther sources of data should be used, if possible, to determine and evaluate plant response. Ali available data from Exhibit 2 will be collected including, in-depth interviews of involved personnei, t
copies of ali strip chart recorders, operating staff Togs and any hand calculations or ranually plotted graohs.
4.4.4 Inolerentation The Reactor Trio Review Orogram will be freierented via a Plant Administrative Procedure.
4.4.5 Post-Trio Deview Grouc As soon after a transient event as is oractical, the Post Trip Review Group will be asseroled. *his group will consist of representatives of Plant Anaiysis, Plant Operations, and Plant., Engineering. Additional 2
personnel ray be assigned to the PTRG as recuosted by the above members. The activities of the PTRG will
~
include event analysis to confirn the cause, sequence, I
and response of the event, and deveiocrent of I
aoprocriate corrective actions, recorrendations, and conclusions.
This information will be decurented in i
written form.
It will be distributed to t"e Operations & "afntenance Ofrector (7":) or tne Piant c
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C-C0 Operations Director (CC), the Plant Engineering Director, the Director, Systems Engineering, and other interested parties as warranted.
l 4.4.6 Data Analysis 4.4.G.1 The Post-Trio Review Group will analyze the plant response to determine ancmaties.
Areas to be analyzed are listed below:
4.4.6.1.1 RCS and Core Heat Removal 4.4.6.1.2 RCS Pressure & Inventory Control 4.4.6.1.3 Reactivity Control 4.4.6.1.4 Fuel Integrity & Core Heat Removal 4.4.6.1.5 Containment Environment &
Isolation 4.4.6.1.6 Radiation Control 4.4.6.1.7 Electrical Power 4.4.6.1.8 Chemistry Control gp 4.4.6.1.9 Safety System Status a
4.4.6.2
- he Post-Trip Review has been estab? issed t:
ensure that abnormal performance inAir:or-
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tant systems will be identified. 4 Orede-termined cneck-list, to be contained in a Plant Administrative Procedure, listinc specific otant performance criteria wifi be used to conduct the review.
4.4.6.3 Any deviations in plant res:ense snali be documented anc tne event :Taced int: One 0 #
the fc110 wing categories.
4.4.6.3.1 Category C The RPS trip function and *00t cause's) are positively known and have been corrected; plant resconse was normat with all e uis-ment functioning properly during the event.
4.4.6.3.2 Category :
The rcot cause(s) is not ON itiveiy known and correctec or plant resconse was abrar a!
or safety related e uiprent did rot functi:-
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transient resulted in operation in violation of the Technical Specifications.
l 4.4.6.3.3 Category II i
j Cold shutdown is required.
l Events classified as Category I cr II will require an Independent Review prior to restart.
4.4.6.4 The Post-Trip Review Group will ensure intestigation of the cause of the trip to tha fullest extent possible. 'nhen the root cause is unknown attempts to locate and duplicate the cause through troubleshooting and testing, and appropriate calibration and maintenance checks will be made.
If the root cause(s) of an event can not be deter-mined then it will be classified as a Category I event, requiring an :ndependent Review prior to restart.
4.4.7 Corrective.ctions The Post-Trip Review Group will specify corrective actions required prior to startuo to ;:revent er miti-gate the consequences of future reoccurrences 50 as t0 ensure an orderiy plant restart.
4.5
- ndecendent Review 4.5.1 Under certain conditions, further review must be ::er-
)
formed prior to restart to ensure that all cuestions i
regarding the ability to safely restart and c erate the plant are rescived. They are as f:11cws:
4.5.1.1 If the imrediate (RPS trio function) and rect cause(s) of the trip cannot be determined, er 4.5.1.2 Plant cost-trip resconse is abncreal, or 4.5.1.3 If any unresolved safety issues exists, or 4.5.1.4
- f compliance with licensing requirements is j
in question.
4.5.2 The :ndependent Review will be perferred by a grcup cf
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Revis on No Analysis of GPUN Piant Transients (Post Trip Review) i 0-00 experienced and knowledgeable individuals, such as RTRs or ISRs, designated by the Operations & Mainten-ance Director (TMI), or Operations Director (CC), and the Director Systens Engineering.
4.5.3
!n addition, it ray also be appropriate to forward data and event information to the NSSS vendor if it is beneficial to obtain their analysis. Transient data will be released to the NSSS vender via the vendor resident engineer. Data released to the NSSS vendor will be proprietary, for vendor internal use only, l
unless specifically released for further distribution i
by GPUN Systems Engineering, 4.5.4 Results will be recorted to the Operations & Fainten-ance Director (TffI), or Operations Director (OC), and the Director, Systems Engineering.
4.6 Restart Cecision 4.6.1 Prior to restarting the unit, Operations and Technicai i
Functions must ensure that:
4.6.1.1 The cause(s) of the tric (D.PS Trip ' unction and initiating event) are known or have been investigated to the fullest extent oossibie.
4.6.1.2 The piant's transient resconse was as ex ec-ted.#cr the type of event, and either did not identify any croblems that iroact the ability of the unit to be safely restarted l
and ocerated or that the ;;roDiers nave bee".
corrected.
l 4.6.1.3 Any :rcblers with scui: rent subject to *ech Spec LCD requirerents are corrected as required.
4.6.1.4
'he corrective actions icentified during !"e i
Post-Trip Review as being required ::rior to restart, are frp1& rented.
-i 4.6.2 The decision to restart will be made by the Piant " ice President or his desia I
concurrence,perthe!neewithTechnicalFunctions xhibit 3 ratrix.
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2 4.7 Subsecuent Evaluation J
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5 Every uncianned tric will be subjected to a folfow-up, in de:th i
evaluation as specified by Plant Analysis.
- n addition, : Tarred j
reactor trips which show abnormalities in piant es;:ense wii' l ll
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C-00 also receive further evaluation. The purpose of the Subsequent
~
Evaluation is to ensure that all aspects of the events are fully investigated, evaluated, and documented.
The Subsequent Evaluation takes the knowledge gained from the I
Post-Trip Review &nd expands upon it in areas of identified a
rmal response.
It ensures that the more subtle aspects of i
j system performance, even though they did not significantly affect the plant response, are evaluated and needed corrective M M action identified. This report need not be. completed before restart. The scope of the Subsequent Evaluation is prescribed to ensure that all reporting requirements can be met.
4.7.1 GPUN Analysis 4.7.1.1 The Plant Analysis Section, represented by the STA shall ensure that the proper material is forwarded to the appropriate Technical Function section(s) for detailed analysis. The responsible Technical Func-tions engineering sections will analyze the plant response to determine resconse anoma-lies. Areas to be analyzed include, but are not ilmited to, those listed below.
l 4.7.1.1.1 Reactivity control, fuel integrity, and core transient conditions; 4.7.1.1.2 Core heat removal, RCS heat removat, and RCS inventory and pressure control; i
4.7.1.1.3 Steam generator heat transfer, inventory i
I and pressure control (TMI only);
4.7.1.1.4 Normal and energency electrical system I
performance; 4.7.1.1.5 Containment environment & isolation i
4.7.1.1.6 System and concenent coeration as
/e accrocriate;
/ N 4.7.1.1.7 Cff e udprocedures, training, and controi
/pd #e, room design cpr:ter c;;g;,cc,-
Y; g Potential effe; _ct of different plant 4.7.1.1.8 f
/*la conditions or additionai credible failures / errors.
l i
j 4.7.1.2 If abnormal resconse is indicated, then Sys-tems Engineering will coordinate additional specific analyses to determine the cause of the abnormal response and to investigate 3
alternate event paths, as appropriate.
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4.7.2 NSSS Vendor For some events, a review and site visit by the NSSS vendor may be necessary.
l 4.7.2.1 The Plant Analysis section will be the interface between the NSSS vendor represen-tatives and the plant staff, i
4.7.2.2 The format of the NSSS vendor review for TM:
will be as specified in current Transient Assessment Program Guidelines (B&W Report 12-1122130-Rev).
l 4.7.2.3 For those events when a site visit by the NSSS vendor is made, an exit interview will be conducted to discuss their preliminary transient assessment, if necessary.
4.8 Owners Grouc Notification The Plant Analysis section w411 formulate the required notifica-tion to the appropriate Owners Grouc Utilities, preferably via Nuclear Network.
Exhibit 4 provides a sample format.
An event summary for Nuclear Network, shall be released with the concurrence of the Directcr, Operations and Paintenance (TMI) cr Operations Director (OC), felicwing aoproval by the Director, Systems Engineering for each event investigated. This event summary should be released witnin one working day foll0 wing the event.
4.9 Recort Precaration 4.9.1 The Plant Analysis section is resconsible for crecar-ing the Transient Assessment Recort.
Exnibit 5 con-tains a samole report format.
This recort snail ce approved by the Director, Systems Engineering with Operations and Maintenance Director (TM:-1), or Ocera-tions Director (CC) concurrence and released witnin 30 days of the event.
4.9.2 Any subsequent Technical Cata' Reports detailing the I
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analysis of a transient aspect by the responsicle Technical Functions decartment and/or plant depart-ment, will be prepared in accordance with 5000-ADM-7316.01.
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4.9.3 The appropriate Licensing section will process Licen-see Event Reports (LER) in accordance with 1000-ADf t-1216.03. The accrocriate plant department will provide input for the LER submittal.
i l
4.10 Followuo Action 4.10.1 The Plant Analysis section will utfif:e 5000-aC"-
7370.02 to initiate, monitor and document the incle-i mr,ntation of corrective actions recomenced in tne j
Transient Assessment Report.
i!5.0 RESPONSIBILITIES 5.1 Analysis of CPUN Plant Transients (Refer to the Procedure Flow l
Chart, Exhib t 1).
E.1.1 POST TRIP Gathers event data /information (see Exhibit 2)
REV!EW GROUP Forwards event data /information to DSE, CL"O (Tt!!)
(P TRG) or CD (OC)
Assembles as soon as possible after transient event Confirms secuence of events Evaluates plant response Confirms cause of initiating evert Reconnends corrective actions Generates written docunentation of resuits 5.1.2 PLAT:T at:LYS:S Forwards event data /inferration to 'iSSS veMor, SECT:0f: (P AS )
if needed, for preliminary analysis, are scecf-fies extent of analysis Forwards docueentation of results to C&!'O (T"!) or OD (CC), PEC 5.1.3 STATI0ti Ceternines corrective actions CPERAT 0t:5 0!V:5!0t:
=;
(500) i 2
5.1.4 i'
NSSS 5
'!E!DCR Conducts rite visit, if appropriate (NSSSV)
Performs.:reliminary analysis of event data and j,
prepares surrary report, if necessary 1
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Analysis of GPUN Plant Transients (Post Trip Review) 0-00 5.1.5 DIRECTOR, SYS-Assign Section Panager(s) to investigate transient TEMS ENGINEER-Reviews and approves NSSS vendor Prelininary Suneary (DSE)
Recort or DIRECTOR, Et!GItlEER:NG AND DESIGN (DED) 5.1.6 PLANT ANALYS:S Prepares event sumrary for release to Owners' Grcup SECTION (PAS)
Utilities via NUCLEAR NETWCRK Submits sunnary to O&MD (TMI-1) or CD (nc) for con-currence Perform subsequent Evaluations, if recuired 5.1.7 OPERATIONS Concurs with event sunnary for NUCLEAR NETNCRK
& MAINTENANCE D:RICTOR (U!!)
(0&ffD) or CPERA-T!ONS D: RECTOR, CC (00) 5.1.8 D: RECTOR, SYS-A;; roves event surrary and authorf:es release to i
TEMS ENG:!:EER-Dwners' Croup Utilities via $:UCLEAR NETWCRK ING (DSE) 5.1.9 SE:T:Ct "At:AGER Perform 'urtner analysis as warranted (S")
Assists Station Cperations in review of Restart Criteria Assists Station C;erations in cianning of recovery actions Prepares recorts of specific analysis, if warranted 5.1. 10 ST% TION OPERA-Pians and ircierents plant recovery actions T!ONS DIVIS!0N Completes required recovery action (500)
Prepares LER Input and subnits to Licensing 5.T.11
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STAT:GN CPERA-Approves Piant restart i
TION C:V S:Ct 1
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CPERATIONS &
Concurs with Transient Assesscent Report MAINTENANCE DIRECTOR TiiI-i (OMO) or CPERATIONS DIRECTOR OC (00) i 5.1.14 L! CENSING Processes LER in accordance with SECTION (LS) 1000-ADM-12 76.03 (LP-002) 5.1.15 i
PLANT ANALYSIS Distributes final event reports SECTION (PAS)
Assigns followup corrective actions regarding training, operating procedures and/or plant design 5.1.16 NUCLEAR ASSUR- ??anager, IOSRG reviews event reports ANCE DIVISION "anager, Plant Training impienents training (NA) progran changes as required Pfanager, Quality Assurance implements os procedure change as necessary l
5.1.17 STATION CPERA- !cpiements changes in plant operating and/cr T!ONS 0:V:S!0N naintenance cc0cedures as necessary (500) 5.1.18 ENG:NEERING PRO-Initiates piant design changes as required JECTS/ ENGINEER-
!NG AND DES Gt!
(EP/ED) 5.1.19 SYSTE"S ENGI-Determines if additional evaluatien is recuirec NEER:NG (SE) on action item folicwup response 5.1.20 t
PLANT ANALYS!S Reviews /accreves action tal.en SECTION (PAS)
Reconnends additional action as recuired Files closed-out action dccument i
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6.0 REFERENCES
6.1 5000-ACM-7316.01 - Technical Reports 6.2 1000-ACM-1216.03 - Regulatory Corresocndence Managecent and Committment Centrol 6.3 5000-ACM-7370.02 - Review cf Industry /GPUN Operating Experience 6.4 ES-005 "STA Duties and Resocqsibilities" 7.0 EXHIBITS r
I 7.1 Exhibit 1 - Precedure Flow Chart 7.2 Exhibit 2 - Transient Event Data Requirements 7.3 Exhibit 3 - Restart Cecisien/ Concurrence Matrix 7.4 Exhibit 4 - Nuclear Network Transient Notification 7.5 Exhibit 5 - Transient Assessment Report Fermat cc h
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EXHIB!T 2 TRANSIENT EVENT DATA RE0ViREMENTS The GPUN Plant Analysis Section engineer and Shift Technical Advisor, assisted by Plant Engineering and Operations personnel, will gather data associated with a transient event. The following data should be gathered:
1.
Plant Equipment Conf iguration befcre, duri g and fo11cwing tne event 2.
Computer Chronological Alarm Listing (TMI) 3.
Computer Sequence of Events Printout 4
Computer Post Trip Review Summary 5.
Transient Monitor System Data cumps and Plots (TMI) 6.
CRT Video-Copied Data generated during the event (D4!)
7 Computer Utility Printer data gathered during the event (TM:)
8.
Operating Staff Logs 9.
Applicable Strip Chart Recorcs 10. Any otner data that may be useful in analyzing the transient event.
Specific requirements are furtner detailedin tne implementing plant procedure.
NCTE:
- o reserve the criginal reccccs of the plant transient, photostatic copies of the above shculd be used where cracticai.
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Plant Cold Known
Response
Shutdown Tech. Functions Catetcry and Corrected Normal Reauired Ccncurrence Level i
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B&W OW4ERS GROUP TRANSIENT NOT!FICATICN (TM:-il TMI-i PLANT TRANSIENT CATE:
TYPE CF TPANS!ENT TRANSIENT TIME:
EXECUTIVE SUM!'ARY a.
PLANT CCND*T:CNS:
(Pricr to Transient)
Reactor Pcwer:
RCS Ty:
T:
C RCS Press:
Pressuri:er Level:
Stean Press:
OTSG Level: A B
RCS Pures Canb ina t icn
!7W Punp Status ICS Mode:
5 E.
Test f rg in Progress:
5 C.
Abncmal Linetes er Plant Conditions:
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f D.
Major Equipment Out of Service:
(Pertinent to the transient) i l
l l
II. EVENT
SUMMARY
A.
Major parameters during the transient RCS Temp: Max.
Max. RCS Cooldown Rate:
Min.
Min. Subcooling Margin:
RCS Press: Max.
Pressurizer Level:
Min.
Max.
Min.
OTSG Press:
OTSG Level:
Max. A 3
Max. A 3
Min. A 3
Min. A 3
DESCRIPTION OF EVENT:
- nitiating cause:
Trip Mode: Auto Manual f Auto, -nicn function Core Cooling Mode: Forced
'f a tura l Convection Convection FPI 5
Quantity Water in R5 if HP: Cooling i
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Immediate coerator actions and procedures used:
HPI Inftfated? Yes No Manual?
Auto?
Erergency Feedwater Initiated? Yes No
'tanual?
Auto?
'las PORV challenged? Yes No Were Code Safeties cnallengec?
ves No were 'tain Steam Saf aties f if ted? Yes No was 'fa f n Steam er Feedwater isciated? Yes No Pressuri:er Level cff sca te? Yes No High?
Lew?
Ouration, if yes CTSG Tevels cff sca f e? Yes No Wign?
Lew?
Ouraticn, if yes
' tan. Radiation / Activity Levels in R3 L
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Any arcmalies er unusual circumstances cbserved in the event?
Suoplemental 0:erater actions and procedures used:
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PRESE':T DLANT COND:T:C'l CATE:
- ME:
RCS Temp:
RCS Press.
Pressurizer Level:
0TSG Level:
A 3
Core C:ot ing *tode:
Radiation Levels i
- nside Centainment:
}
Cutside Centainment:
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Class Emergency ceclared:
i NRC/Pubife Notification: Yes No REf tARKS: (Include an assessment of present plant cond it ion)
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Intentions:
( 9clude plans cencernirg changes to plant canditions and inmediate corrective acticns if kncwn)
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0'aNERS GROUP TRANSIENT NOT:FICAT:CN (0.C.)
Transient Date:
T ime:
Name of Event:
Executive Sunnary:
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A.
Plant conditions prict to transient:
(Insert Data Sheet #1)
B.
Testing in Progress:
C.
Abncrmal ifneups or plant conditions (pertinent to tran s ien t) :
O.
"afer ecuicrent cut of service (:ertirent to transient':
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E.
Parameter Values Durino Transient Thermal Power:
Max.
MWT Min.
MWT i
Reactor Level:
- Max, in GEMAC i
i Min.
in GEMAC Reactor Press:
Max.
P sig Min.
Psig 4
Recirc Ficw:
Max.
gpmx10 M in.
gpmxio4 Dryuell Tee: :
'i a x.
'F ttin.
'F Drywell Press:
'ta x.
Psig Min.
Psig l
Torus Press:
Max.
Psig Min.
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EXHIBIT 4 - PART !! (Contd.)
F.
Descriotion of Event Initiating Cause:
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Scram Mode: Auto / Manual If Auto, which function?
'fas Main Steam or Feedwater isolated?
Yes No Isolation Condensers !nitiated?
Yes No Core Spray :nitiated?
Yes No "antainrent Spray :nitiated?
Yes No Any EMRVs L if t?
Yes No Any Safety Reliefs Lif t?
E Yes No
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Maximum Radiation / Activity Levels in Drywell and Reacter Building?
Maximum Rad /Act. Level at Site Boundary?
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Inmediate operator actions and procedures used:
Supplemental Ocerat:r actions and procedures used:
Any ancrat ies or unusual circumstances ceservec curirg the event?
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c4RC/Public Nctificat ion? Yes No I
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Plant Conditions Af ter Transient:
(insert Data Sneet rz)
Max. Radiation / Activity Levels in Drywell and Reacter Building:
Max. Radiation / Activity Levels at Site Boundary:
Assessment of Present Plant Conditions:
!ntentions (Corrective Actiens Planned and/cr Chances in Plant "onditiens C ontemolat ed) :
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,u, Analysis of GPUN Plant Transients (Post Trip Review) j 3 00 EXHIB!T 5 TRANSIENT ASSESSMENT REPORT (SAMPLE FORMAT)
Transient Assessment Recert A Transient Assessment Report will be prepared fcr all reactor trips. Re-parts may also be prepared for other significant events. The purpose cf the repcrt is to provide transient event inf ormation for all Owners' Group Utilities. The operational experience shared in this program will lead to ingroved plant reliability and a better understanding of the plant's per-formance by all Owners' Group Utilities.
The fermat of the report should be as follows:
I.
Summary II. Transient Assessment A.
Secuence of Events B.
Plant Performance 1.
Pre-Trip Review 2.
- nitiating Event 3.
Plant Post-Trip Rescense 4
Operator Actions / Procedural Acecuacy C.
Safety Considerations D.
Assessment Conclusions E.
Corrective Actions The *Surrary" secticn should be a shcrt descriptien of the event, hignlignting tne ma;ce ascects of the transient and tne resulting evaluation.
The "Secuence of Events" secticn shcule contain tncse majcr events er cen-ditions, anicn cei tneate the progressive course of tne transient.
The " Pre-Trio Review" section should contain a statenent of tne plant cen-ditions prior to tne transient. Examples to be included would be pcwer level,
- CS status, maintenance er testing in progress, and ecui: ment deficiencies.
Acditionally this section should provide the frarework for evaluating tne in-itiating event and root cause of tne transient.
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' Eevi$.Cri No img Analysis of GPUN Plant Transients (Post Trip Review) l
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The " Initiating Event" section should be used when a transient is initiated by a ccmolex series cf events such that detailed analysis is required to celin-eate the occurrences.
The " Plant Post-Trio Resconse" section should include a discussion of the response of tne N55 anc 3GP frem a process point of view; i.e., T yg, RC A
Pressure, Pressurizer Level, Feecwater Flow, OTSG Level, and Main steam Pressure.
These parameters should be plotted versus time and annotated to indicate major events, departures, etc. to support the text of this section.
Also, this section should include a discussion of performance of ccmocnents and their departures fecm the expected. Proposed corrective acticns and corrective actions previously completed may be included in the text of this section.
The "Ocerator Action / Procedural Adecuacy" section should include inf ormation concerning specific o=erator actions taken during the transient which have not been included in any previous sections. Additionally, procedures fc110wed during the transient, and any information which would be beneficial to other operators should be included. This section should be considered fcr input into procedure revisiens.
~he "Saf ety Considerations" section should incluce the bases for ahicn safety, as it relates to tne transient, has been censidered. These bases nignt in-ciude plant design recuirements, F5AR accident analysis, cr otner infcrmatien.
~he " Assessment Cerclusions" section should be a summary of the significant as ects of tne transient, including departures from expected cer:cnents and plant =erformance.
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THREE MILE ISLAND NUCLEAR STATION UNIT NO. 1 ADMINISTRATIVE PROCEDURE iO44 EVENT REVIEW AND REPORTING REQUIREMENTS ED.' & cc Table of Effective Pages Page Revision Page Revision M
Revision Page Revision 1.0 13 26.0 13 2.0 13 27.0 13 3.0 13 28.0 13 4.0 13 29.0 13 5.0 13 30.0 13 6.0 13 31.0 13 Proposed changes are 7.0 13 32.0 13 highlighted with ll 0
double bar indication in right margin 10.0 13 11.0 13 12.0 13 13.0 13 14.0 13 15.0 13 16.0 13 17.0 13 18.0 13 19.0 13 20.0 13 21.0 13 22.0 13 23.0 13 24.0 13 25.0 13 A
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THREE MILE ISLAND NUCLEAR STATION UNIT NO.1 ADMINISTRATIVE PROCEDURE 1044 f
EVENT REVIEW AND REPORTING REQUIREMENTS Table of Contents Section Page 1.0 GENERAL 3.0 1.1 Purpose 3.0 1.2 Scope 3.0 1.3 References 3.0 2.0 RESPONSIBILITIES 3.0 3.0 REQUIREMENTS 4.0 3.1 Potentially Reportable Events 4.0 3.1.1 10 CFR 50.72, Imediate Notification 4.0 3.1.2 10 CFR 50.73, Licensee Event Reports 4.0 3.1.3
- 10 CFR 20, Radiological 5.0
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3.1.4 10 CFR 50.36, Technical Specification Safety Limits. LSSS and LCO 5.0 3..l.5 10 CFR 73.71, Security 5.0 3.1.6 10 CFR 21, Defects and Noncompliance 6.0 3.1.7 Emergency Plan 6.0 3.1.8 Events of Potential Public Interest 6.0 3.2 Initial Review Process 8.0
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3.3 Followup Review and Reporting 8.0 3.3.1 Emergency Notification System 8.0 3.3.2 Other Notification and Reporting 11.0 s
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':OR USE !N UNIT I ONLY s'f,,on,3 Table of Centents (Cent'd) r Section Page 4.0 ENCLOSURES 4.1 - 10 CFR 50.72 13.0 4.2 - 10 CFR 50.73 18.0 4.3 - 10 CFR 20 22.0 4.4 - 10 CFR 50.36 26.0 4.5 - 10 CFR 73.71 28.0 4.6 -EvenEsof-P5tentialPublicInterest 31.0 4.7 - Potentially Reportable Event Form 33.0 4.8 - Public Inquiry Policy 34.0
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1.0 GENERAL s
1.1 Purpose The purpose of this procedure is to specify the evaluation and reporting requirements when an event has occurred which may require notification of NRC representatives and/or company management.
1.2 Scope This procedure applies to personnel at the TNI-1 site.
1.3 References 1.3.1 10 CFR 50.72, Imediate Notification Requirements for
,Cperating Nuclear Power Reactors 1.3.2 10 CFR 50.73, Licensee Event Report System 1.3.3 10 CFR 20, Standards for Protection Against Radiation 1.3.4 10 CFR 50.36, Technical Specifications 1.3.5 10 CFR 73.71, (Security reports)
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1.3.6 Memo from Vice-President. THI-1, dated June 1, 1981 concerning additional desired notifications 1.3.7 Emergency Plan for TMI-1 1.3.8 10 CFR 21, Reporting of Defects and Noncompliance 1.3.9 NUREG 1022, Licensee Event Report System 1.3.10 LP-007, Management of Preliminary Safety Concerns and Potential Licensee Event Reports 2.0 RESPONSIBILITIES 2.1 All employees are responsible for ensuring that, items which could adversely affect nuclear safety are brought to the attention of the Shift Supervisor.
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'2.2 The Shift Superviser'Is responsible for making the inttial deter-
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mination regarding reportability. He shall ensure notification is made to the Operations and Maintenance Director, Outside Agencies, Public Information Representative, Manager-Plant Operations, PRG Chairman and Lead Engineer as appropriate.
2.3 The Lead Engineer or Department head shall ensure that potentially reportabl.a occurrences brought to his attention are submitted to the PRG for evaluation.
2.4 The PRG Chairman shall ensure timely review by the PRG of potentia 11-y repor. table occurrences and. recommend appropriate action to the Operations and Maintenance Director.
2.5 The Operations and Maintenance Director or his designee (in non-emergency situations) shall make the final determination regarding reportability and ensure that appropriate on-site and
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off-site organizations are notified.
3.0 REQUIREMENTS 3.1 Potentially Reportable Events 3.1.1 10 CFR 50.72 Imediate Notification Evaluate.the' event, under. consideratton against the a...
criteria specified in Enclosure 1.
b.
If the event is considered reportable under 50.72, then make notifications using the ENS (red phone) as described in 3.3.1.
3.1.2 10 CFR 50.73, Licansee Event Report's Evaluate the event under consideration against the a.
criteria specified in Enclosure 2.
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b If the event is considered reportable under 50.73,.
then make notifications as des'cribed in 3.3.2.
3.1.3 10 CFR.20, Radiological Evaluate the event under consideration against the a.
criteria specified in Enclosure 3.
b.
If the event is considered reportable under Part 20, then make notifications as described in 3.3.1 and/or 3.3.2, as appitcable.
3.1.4 10 CFR 50.36,' Technical Specifications,.Section 2.0 Evaluate the sv.ent under. consideration against the a.
criteria specified in Enclosure 4.
b.
If the event is considered reportable under 50.36, then make notifications as described in 3.3.1 and 3.3.2.
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3.1.5 10 CFR 73.71, Securfty With direction from Security personnek, evaluate the a.
event under consideration against the criteria specified in Enclosure 5.
b.
If..the event is. considered reportable under 73.71, then make notifications as described in 3.3.1.
Senior Security personnel should make these notifications.
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'10 CFR 21, ' Defects and Noncompliance 10 CFR 21 requires notification of the NRC upon a.
discovery of substantial. safety defects.
. Individuals generating reports in accordance with 10 CFR 21 shall provide a copy to the PRG Chairman and the Operations and Maintenance Director.
3.1.7 Emergency Plan The Emergency Plan requires spec 1al NRC notification a.
for. specific events. The Emergency Plan shall be
-.... used,for quidance in. making. those notifications.
NOTE:
Initiation of the Emergency Plan is in itself report- :
able within one hour under 10 CFR 50.72.
b.
Events reportable under the Emergency Plan may also k.
be reportable under 10 CFR 20 or other requirements.
3.1.8 Events of Potential Public Interest These are events that may not be considered re;1 ort-a.
able under other sections of this procedure. Refer to Enclosure 6 for a list of these events. It has been-cosuiltted that notification of such events will be made to the GPUN Public Informatlon Representa-tive, The TMI-1 Outy Superintendent, the Site Duty NRC Representative and the Unit 2 Control Room.
NOTE:
The declaration of an event of potential public interest shall not be made in lieu of the declara,-
tion of a formal emergency ci,assification (i.e.,
Unusual Event).
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'b.
The' Shift Supe'rvisor is responsible for notifying
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the Operations and Maintenance' Director, or his designee, and the below listed personnel of signif t_
cant events:
1.
The Pubile Information Representative (see On-site Duty Roster) 2.
Site NRC Duty Representative (see current
" Weekly Schedule - NRC on Call Representative" in the Shift Supervisor's office) 3.
THI-1. Duty Superintendent 4.
Unit 2 Control Room NOTE:
The OPX network shall not be used for routine communications with the NRC. -
Additionally, an entry should be made in the Shift c.
Foreman's Log Book (left-hand section) describing the event.
d.
In the event a call is received by Control Room 1
personnel by members of the pubile concerning plant l
status or a perceived plant problem, refer to the guidelines provided in Enclosure 8.
Upon termination of the event notify the Pubite e.
Information Representative.
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'3.~2 "' Initial Review' Process 3.2.1 7he Duty Shift Supervisor is typically in the best
, osition to become aware, first hand, of a potentially p
reportable event. Sources of Information avaliable to him include:
a.
Results of Tech. Spec. surveillance.
b.
Operations or maintenance activities that may reveal improper methods or malfunctioning equipment.
3.2.2 For events. brought to his attention, the Shift Superviser
..- shall make the inttial determination regarding report-ability of an event. He shall review the event for reportability in any of the categories described in section 3.1 of this procedure.
3.2.3 If the Shift Supervisor determines that the event is clearly not reportable, he shall inform the Manager-Plant Operations.
l 3.2.4 If the Shift Supervtser determines that the event is potentially reportable, additional action is required as spectfled in Section 3.3.
3.3 Follow-up Review and Reporting 3.3.1 Emergency Notiflcation System (ENS)
For events potentially reportable via the ENS, the a.
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Shift Supervtsor shall immediately notify the l
l Operations and Maintenance Director or Outy Super-intendent. The Operations and Maintenance Director or Duty Superintendent will make the final i
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""' $ ' oa ' 3 determination regarding reportabil';y (If unable to contact the Duty Superintenden't or Operations and Maintenance Director, the Shift Supervisor will make s
the determination).
b.
If he detertaines the event is reportable, he or ht s designee shall notify:
1.
The Public Information Representative (see On-site Duty Roster) 2.
Site NRC Duty Representative (see current
" Weekly Schedule - NRC on. Cal.1 Representative" i
in the Shift Supervisor's office) 3.
NRC Operations Center via ENS (red phone).
Notification to the NRC Operations Center shall be made within the required time frame an1 the applicable CFR or other reporting requirement shall be Identified.
l NOTE:
A copy of the NRC " Checklist for Licensees Making Nottftcations of Significant Events in accordance with 10 CFR 50.72" may be found at the red phone.
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This checklist is descriptive of the type of Information the NRC may request and is supplied for your information and ald. There is no requirement to use this list.
If the ENS 1s inoperative, then make the required c.
notifications via conumercial telephone service, 1
other dedicated telephone system, or any other s
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1044 FOR USE IN UNIT.l ONLY method which'wlli ensure that a report is made as soon as practical to the NRC Operations Center.
NOTE:
NRC IE Bulletin No. 80-15 requires THI to notify the NRC Operations Center by commercial phone or relayed message within one (1) hour of the time that one (1) or more extensions of the ENS (NRC Red Phone) is found to be Inoperable for any reason.
Refer to EPIP :
1004.6, Attachment V for the commercial telephone no. :
d.
Durir.g the course of the event, immediately report:
1.
Any worsening of conditions 2.
Declaration of an emergency, if not already made 3.
Change of emergency class, including termination 4.
Results of evaluations of plant conditions 5.
Effectiveness of response or protective measures taken 6.
Information related to plant behavior that is
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not understood Maintain an open, continuous comunication channel e.
with the NRC Operations Center upon request by the NRC.
f.
The Shift Supervisor shall complete and distribute a Potentially Reportable Event Form provided as to this procedure.
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- 3. 3. Other' Notification 'an'd Reporting The Shift Supervisor shall notify the Operations and a.
Maintenance Otractor or the Duty Superintendent.
The Shift Supervisor will then, as appropriate. make the following notifications:
1.
The Public Information Representative (see On-site Duty Roster) 2.
Site NRC Duty Representative (see current
- " Weekly Schedule - NRC on Call Representative"
.c.in.the Shift. Supervisor's office) 3.
Manager - Plant Operations 4.
PRG Chairman b.
The Shift Supervisor shall complete and distribute a Potenttally Reportable Event Form provided as to this procedure.
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PRG will review the potentially reportable event and c.
make a recommendation concerning reportability to the Operations and Maintenance Otractor.
The PRG reportability recomendation wi.11 be documented.
A PRG recomunendation concerning reportability is not' required if the event has alreidy been reported.
If the item requires further technical evaluation, a Preliminary Safety Concern Evaluation Form may be submitted in accordance with LP-007. Applicable procedures shall be reviewed following a reportable t
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occurrence such as an accident, an unexpected transient, significant operator error, or equipment
. malfunction to determine whether procedure changes are required.
d.
The Operations and Ma-intenance Ofrector or his designee will make the final determination regarding reportability. He shall then take the following action as appropriate:
1.
If the event is not reportable, the Operations
... and. Maintenance.Dir.ector-shall.. inform the PRG Chairman.
2.
If the event is reportable, the Operations and Maintenance Director or his designee shall:
a.
Notify the NRC within the required time frame.
i b.
Notify Company Management.
c.
Notify the Public Information Representative d.
Notify the PRG Chairman.
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'Enclosu~re 1 j
s.
-10 CFR 50.72 Notifications I.
One-Hour Notification Requirements (a)(1)(1)
The declaratton of any of the Emergency Classes speciff ed the licensee's approved Emergency Plan.
(b)(1)(1)
(A)
The initiation of any nuclear plant shutdown required by the plant's Technical Specifications.
(B)
Any deviation from the plant's Technical Specifications authorized pursuant.to subsection 50.54(x) of this part.
NOTE:
50.54(x) - A Itcensee may take reasonable action that :
departs from a license condition or a Technical Specification in an emergency when this action is Innedtately needed to protect the pubile health and:
i safety and no action consistent with license condt-tions and Technical Specifications that can provide adequate or equivalent protection is immediately apparent.
NOTE:
Refer also to 50.73 (a)(2)(1)(A),(B),(C)
(b)(1)(11) Any event or condition during oceration that results in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded; or results'in the nuclear power plant being:
(A)
In an unanalyzed condition that significantly compromises plant safety; (8)
In a condition that is outside the design basis of the plant; or k
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(C) In a condition not covered by the plant's operating and emergency procedures.
NOTE:
Refer also to 50.73 (a)(2)(11)
(b)(1)(111)
Any natural phenomenon or other external condition that poses an actual threat to the safety of the nuclear power plant of significantly hampers site personnel in the performance of duties.necessary for the safe operation of
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. the. p'l an t.
NOTE:
Refer also to 50.73 (a)(2)(111)
(b)(1)(tv) Any event that results or should have resulted in Emergency Core Cooling System (ECCS) discharge into the reactor coolant J
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system as a result of a valid signal.
NOTE:
Refer also to 50.73 (a)(2)(lv) l (b)(1)(v) Any event that results in a major loss of emergency assessment capability, offsite' response capability, or communications capability (e.g., significant portion of control room indica-tion, Emergency Notification System, or offsite notification system).
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(b)(1)(vi) Any event that poses an a:tual threat to the safety of the nucTear power plant or significantly hampers site personnel in the performance of duties necessary for the safe operation of the nuclear power plant including fires, toxic gas releases, or radioactive releases.
NOTE:
Refer also to 50.73 (a)(2)(x)
II. Four-Hour Notification Recuirements (b)(2)(1)
Any event...found..while.the.rearter i s shutdown, that, had i t been found while the reactor was in operation, would have resulted in the nuclear power plant, including its principal safety barriers, being seriously degraded or being in an unanalyzed condition that significantly compromises plant I
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safety.
NOTE:
Refer also to 50.73 (a)(2)(11)
(b)(2)(11) Any event or condition that results in manual or automatic actuation of any Engineered Safety Feature (ESF), including the Reactor Protect 1.on System (RPS). However, actuation of an ESF, including the RPS, that results from and is part of the preplanned sequence during testing or reactor operation need not be reported.
NOTE:
Refer also to 50.73 (a)(2)(lv) 15.0 FOR USE IN UNIT I ON Y
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- (Cont'd' (b)(2)(111)
Any event or condition that alone could have prevented
.the fulfillment of the safety function of structures or systems that are needed to:
(A) Shut down the reactor and maintain it in a safe shutdown condition, (B) Remove residual heat, (C) Control the release of radioactive material, or (D) Mitigate the consequences of an accident.
NOTE:
Refer also to 50.73 (a)(2)(v) and (a)(2)(vi)
(b)(2)(1v) (A) Any airborne radioactive release that exceeds 2 times the applicable concentrations of the Ilmits specified in Appendix B, Table II of Part 20 of this chapter in
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4 unrestricted areas, when averaged over a time period of ene hour.
(B) Any 11guld effluent release that exceeds 2 times the limiting combined Maximum Permissable Concentration (MPC)(SEE Note 1 of-Appendix'B to Part 20 of this chapter) at the point of entry into the receiving water (i.e., unrestricted area) for all radionuclides except tritium and dissolved noble gases, when averaged over a time period of one hour.
(Inmediate notifications made L
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Enclosure' l' '(Con t' d) under this paragraph also satisfy the requirements of paragraphs (a)(2) and (b)(2) of subsection 20.403 of l
Part 20 of this chapter.)
i
- )TE:
Refer also to 50.73 (a)(2)(v111)(A)(B) i (b)(2)(v)
Any event requiring the transport of a radioactively i
contaminated person to an offsite medical facility for l
l treatment.
(b)(2)(vi) Any. event or situation, related to the health and safety of j
l the public or onsite personnel, or protection of the environ-ment, for which a news release is planned or notification to
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other government agencies has been or will be made. Such an i
event may include an onsite fatality or inadvertent release of radioactively contaminated materials.
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"" "'ca '3 10 CFR 50.73 Reports (a)(2)(1). (A)
The completion of any nuclear plant shutdown required by the plant's Technical Specifications; or (B)
Any operation or condition prohibited by the plant's Technical Specifications; or (C)
Any deviation from tne plant's Technical Specifications authorized pursuant to subsection 50.54(x) of this part.
NOTE:
50.54(x) - A licensee.may take reasonable action that :
-departs fremt a license condition or a Technical Specification in'an emergency when this action is immediately needed to protect the pubile health and safety and no action consistent with Itcense condi-tions and Technical Specifications that can provide adequate or equivalent protection is immediately apparent.
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NOTE:
Refer also to 50.72 (b)(1)(1)(A)(8)
(a)(2)(11) Any event or condition that resulted in the condition of the nuclear power plant, including its principal safety barriers, being seriously degraded; or that resulted in the nuclear power plant being:
(A)
In an unanalyzed condition that significantly compromises 5
plant safety; (B)
In a condition that was outside the design basis of the plant; or i
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(C) In a condition not covered by the plant's operating and emergency proce'dures.
NOTE:
Refer also to 50.72 (b)(1)(11) and (b)(2)(1)
(a)(2)(Itt)
Any natural phenomenon or other external condition that posed an actual threat to the safety cf the nuclear power plant or significantly hampered si'e personnel in the perform nce of duties necessary for the safe operation of the nuclear powerplant.
NOTE:
Refer also to 50.72 (b)(1)(iii)
(a)(2)(lv) Any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (EST), including the Reactor Protection System (RPS). However, actuation of an ESF, including the RPS, that resulted from and was part of the preplanned sequence during testing or reactor operation need i
not be reported.
NOTE:
Refer also to 50.72 (b)(1)(tv) and (B)(2)(11)
(a)(2)(v) Any event or condition that alone could have prevented the fulfillment of the safety function of structures or systems that are needed to:
(A) Shut down the reactor and maintain it in a safe shutdown condition; (B) Remove residual heat; 19.0 FOR USE IN UNIT I ON _Y
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(C) Control the release of radioactive material; or (D) Mitigate the consequences of an accicent.
NOTE:
Refer also to 50.72 (b)(2)(111)
(a)(2)(vi) Events covered in paragraph (t)(2)(v) of this section may include one or more procedural errors, equipment failures, and/or discovery of design, analysis, fabrication, construc-tion, and/or procedural inadequacies. However. Individual component failures need not-be reported pursuant to this paragraph if redundant equipment in the same system was operable and available to perform the required safety function.
(a)(2)(v11)
Any event where a single cause or condition caused ai:
least one independent train or channel to become inoper-able in multiple systems or two independent trains or channels to become inoperable in a single system designed to:
(A) Shut down the reactor and maintain it in a safe
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shutdown condition; (8) Remove residei.1ea t; i
j (C) contro) % rA ase of radioactive material; or (D) Mitigat= the consequences of an accident.
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(a)(2)(v111)
(A) Any airborne rad.loactive release that exceeded 2 times the applicable concentrations of the limits specified in Appendix B. Table II of Part 20 of this chapter in unrestricted areas, when averaged over a time period of one hour.
(B) Any liquid effluent release that exceeded 2 times the limiting combined Maximum Permissable Concentra-tion (MPC)(see Note 1 of Appendix B to Part 20 of
' - this' chapter) at the point 'of entry into the receiv-Ing water (i.e., unrestricted area) for all radio-nuclides except tritium and dissolved noble gases, when averaged over a time period of one hour.
(
NOTE:
Refer also'to 50.72 (b)(2)(tv)
(a)(2)(1x) Reports submitted to the Commission in accordance with para-graph (a)(2)(v111) of this section also meet the effluent release reporting requirements of paragraph 20.405 (a)(5) of l
Part 20 of this chapter.
(a)(2)(x) Any event that posed an actual threat to the safety of the nuclear power plant or significantly hampered site personnel in the performance of duties necessary for the safe operation of the nuclear power plant including fire.s toxic gas releases, or radioactive releases.
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NOTE:
Refer also to 50.72 (b)(1)(vi) t 21.0 FOR USE IN UNIT I ONLY
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10 CFR 20 20.402(a)(1)
Each 1.1censee shall report.to the Commission, by telephone, immediately after it determines that a loss or theft of l
licensed material has occurred in such quantitles and under such circumstancas that it appears to the licensee that a i
substantial hazard may result to persons in unrestricted areas.
NOTE:
Telephone notification shall be made via the ENS as in 10 CFR 50.72. Written reports are required within :
30 days as in~10 CFR 50.73.
20.403 Notifications of Incidents (a) Immediate notification Each licensee shall immediately report any events involving by product, source, or special nuclear material possessed by the
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licensee that may have caused or threatens to cause:
(1)* Exposure of the whole body of any individual to 25 rems or more of radiation;
- exposure of the skin of the whole body of any individual of.150 rems or more of radiation;
- or exposure.cf the feet,. ankles, hands or forearms of any individual to 375 rems or more of radiation; or (2)* The release of radioactive material in concentrations which, if averaged over a period of.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, would exceed 5,000 times the limits specified for such materials in Appendix 8. Table II of this part; or 22.0 FOR USE IN UNIT I ONLY
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. (Cont'd)
(3)* A loss of one working week or more of the operation of any facilities affected; or (4)* Damage to property in excess of $200,000.
(b) Twenty-four Hour Notification Each licensee shall within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of the event, report any avant involving licensed material possessed by the licensee that may have caused or threatens to cause:
(1)
Exposure of the whole body of any individual to 5 rems or
.more of. radiation; exposure of the skin of the whole body of any individual to 30 rems or more of radiation; or exposura of the feet, ankles, hands, or forearms to 75 rems or more of radiation; or (2) The release of radioactive material in concentrations
(
which, if avera'ed over a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, would g
exceed 500 times the limits specified for such materials in Appendix B, Table II of this part; or (3)
A loss of one day or more of the operation of any
. facilities affected; or (4) Damage to property in excess of $2,000.
NOTE:
Telephone notification shall be made via the ENS as in 10 CFR 50.72.
1 l
l 23.0 l
FOR USE IN UNIT I ONLY
1044 FOR USE IN UNIT I ONLY aevision u
, (Cont'd) 20.405 Reports of overexposures and excessive levels and concentrations.
(a)(1)
In addition to any notification required by sub-section 20.403 of thfs part, each licensee shall make a report in writing concerning any one of the following types of incidents within 30 days of'its occurrence:
(1 ( Each exposure of an Individual to radiation in excess of the applicable limits ~in subsection 20.101 or 20.104(a) of this part, or the license;
. (11) Each exposure of.an-Indiv.f dual to radioactive material in excess of the applicable limits in subsection 20.103(a)(1), 20.103(a)(2), or 20.104(b) of this part, or in the license; (111) Levels-of radiation or concentrations of radioactive material in a restricted area in excess of any other applicable limit in the license; (iv) Any incident for which notification is re;utred by subsection 20.403 of this part; or (v)
Levels of radiation or concentrations of radioactive material (whether or not involving excessive exposure of any individual) in an unrestricted area in excess of ten times any applicable limit set forth in this part or in the Itcense.
4 24.0 FOR USE IN UNIT I ONLY
i s"sion i3 FOR USE IN UNIT I ONLY
. (Cont'd)
(c)(1)
In addition to any notification required by sub-section 20.403 of this part, each Ilcensee shall make a report in writing of levels of radiation or releases of radioactive material in excess of limits specif1'ed by 40 CFR Part 190, " Environmental Radiation Protection Stan.
dards for Nuclear Power Operations," or in excess of license conditions related to compliance with 40 CFR Part 190.
NOTEi Written reports are required within 30 days as in 10 CFR 50.73.
l s
25.0 l
FOR USE IN UNIT I ONLY
FOR USE IN UNIT I ONLY s"sion i3 10 CFR 50.36 Requirements
-(c)(1)
Safety Limits and Limiting Safety System Settings (Technical Specifications Section 2.0)
(1)(A)
Safety limits for nuclear reactors are limits upon important process variables which are found to be neces-sary to reasonably protect the integrity of certain of the physical barriers which guard against the uncon-trolled release of radioactivity.
If any safety limit is exceeded -the.reac. tor.shall be. shut down.
The licensee shall notify the Commission, review the matter and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude reoccurrence. Operation shall not be resumed k
until authorized by the Commission.
(11)(A)
Limiting Safety System Settings for nuclear reactors are settings for automatic protective devices related to those variables having significant safety functions.
Where a Limiting Safety System Setting is specified for a variable on which a safety limit has been placed, the setting shall be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded.
If, during. operation, the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting down the reactor. He shall notify the 26.0 FOR USE IN UNIT I ON Y
i a
o FOR USE IN UNIT l ONLY s'f,ioni3 a
. (Cont'd)
Connaission, review the matter and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude i
reoccurrence.
(c)(2)
Limiting Conditions for Operation (Technical Specifications, Section 3.0)
Limiting Conditions for Operation are the lowest functional capability or performance levels of equipment required for safe operation.cf the. facility.. When-a. Limiting Condition for Operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the Technical Specification until the condition can be met. The licensee shall l
notify the Commission, review the matter, and record the results of l
the review, including the cause of the condition and the basis for corrective action taken to preclude reoccurrence.
a e
e 27.0 FOR USE IN UNIT I ON Y
FOR USE IN UNIT I ONLY gg,,,,,3 10 CFR 73.71. Security (a) Each licensee who conducts a trace investigation of a lost or unaccounted.
for shipment pursuant to subsection 73.27(c) shall notify the NRC Opera-tions Center via the Emergency Notification System as soon as possible, and in all cases within one hour, of the details and results of its trace investigation. The licensee shall also file within a period of fifteen (15) days a written report to the appropriate NRC Regional Office setting forth the details and results of the trace investigation.
(b) Each licensee sh'all' notify the NRC' Operations Center via the Emergency Notification Syst1m as soon as possible, and in all cases within one hour, of any incident in which an attempt has been made, or is believed to have been made, to connit a theft or unlawful diversion of special nuclear material which it is licensed to possess, or to connit an act or
~
radiological sabotage against its plant or transportation system.
The initial notification must be followed within a period of fifteen (15) days by a written report, submitted to the appropriate NRC Regloial Office shown in Appendix A of this part settir.g forth the details of the incident.
(c) Each Ilcensee under either a speelfic or general license shall notify the NRC Operations Center via tne Emergency Notification System as soon as possible, and all cases within one hour, of any event which significantly threatens or lessens the effectiveness of a physic'al security system as established by regulations in this chaptor, or by the 11.censee's approved physical security, contingency, and security personnel qualification and 28.0 FOR USE IN UNIT I ON Y
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training plans, or by both.
(See below:)
(1) 10 CFR 73.71 requires notification of the NHC within one hour upon occurrence of any of the following events:
(A) Explicit Threat An explicit threat is Information received by security organt-zation that an act o'f theft or radiological sabotage will be attempted.
(B)
Major. loss of physica.L se.curity effectiveness. A sujor loss of physical security effectiveness occurs when security features breakdown which allow unauthorized or undetected access to Vital Areas.
(2) 10 CFR 73.71 requires notification of the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> upon occurrence of any of the following events:
(A) Potential Threat A potential threat 1.s information received by a security organization which supports belief that an act of theft or radiological sabotage will be attempted.
(B)
Major. loss of physical security effectiveness which has been properly compensated for. Properly compensated means measures as specified in a security or contingency plan or, if the event is not specified in either of these plans, it means measures implemented within 10 minutes of an event occurrence i
that provide,a level of security equivalent to that existing before the event.
29.0 FOR USE IN UNIT I ONLY
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, (Cont'd)
(C)
Moderate loss of physical security effectiveness.
A moderate los.s of physical security effectiveness occurs when. (1) a major loss of effectiveness occurs but is properly compen-sated, (2) securtty features break down which allow unauthorized or undetected access to Protected Areas, (3) a breakdown of security features protecting Vital' Areas occurs which leaves these areas under the protection of only one system.
(This includes the loss of either alarm station).
(3)
Items not reportable.to the NRC that require internal Security incident reports:
Moderate loss of physical security effectiveness which has been properly compensated for.
" Properly Compensated",
means measures as speelfled in a Security or Contingency Plan or, if the event is not specified in either of these plans, it means measures implemented within 10 minutes of an event's occurrence that provide a level of security equivalent to that existing before the event.
There is no requirement for reporting such events to the NRC.
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Events of Potential Public Interest 1.
Any plane crash in the immediate vicinity of TMI.
2.
Any near or onsite toxic or flammable gas or liquid release.
3.
Any ambulance leaving the site while transporting a patient to a hospital 4.
Any fire on TMI regardless of whether offsite assistance was needed (and which does not require declaration of an Unusual Event, Alert, Site or General Emergency).
(A good rule of thumb is if the stren was activated except for testing, then notifications should be made.)
5.
An unanticipated.radioacti.ve spill,- leak.or.. dropped cask or liner of i
radioactive material or a plant operational problem which results in an evacuation of a building due to confirmed high radiation or airbourne radioactivity levels.
6.
Personnel have received a radiation exposure in excess of the Federal limits for the whole body, skin, extremitles and critical organs.
q 7.
Failure of the SPC system and/or the makeup system which results in a loss of RCS pressure and/or level control (as appitcable).
8.
Environmental samples, directly affected from TMI operations, indicating greater than ten times the background levels of radioactivity.
9.
An uncontrolled release which results in a valid 11guld or gaseous effluent radiation monitor increase which is greater than ten times the normal radiation levels (other than controlled releases).
- 10. Loss of a licensed radioactive source.
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. (Cont'd) 11.
Other plant conditions (not covered by the four emergency classifica-tions) that are in progress or have occurred which do not indicate a potential degradation of the level of safety of the plant but may be construed by the public to be detrimental to the environment or,the health and safety of the public or plant personnel.
12.
Planned evolutions that, in the judgement of the Shift Supervisor / Foreman orGPUNCmanagement,maybeofpubkicinterest.
h 32.0 l
FOR US$ IN UNIT I ONLY
FOR USE IN UNIT I ONLY s'f,,oni3 e
POTENTIALLY REPORTABLE EVENT FORM' 1.
Reportable per: 10 CFR 50.72, item:
10 CFR 50.73..Ites:
10 CFR 20, Item:
10 CFR 50.36, item:
10 CFR 73.71, ites:
10 CFR 21, ites:
Emergency Plan item:
2.
Time and Date of occurrence.
3.
Document Tech Spec Section Violated l
- A 69 conce<uG 4.
Detailed description of event,. plant status, and,lanediate corrective A
actions. Attach additional sheets if necessary.
Especially, include information which may not be available the following normal work day.
SHIFT SUPERVISOR:
DATE:
cc: Operations and Maintenance Olrector Manager, Plant Operations PRG Chairman Manager, QA Mod / Ops Manager, Safety Review Plant Analysis Manager - TMI-l Manager, Plant Analysis - Parsippany Manager, Plant Training
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33.0 FOR USE IN UNIT I ON Y
FOR USE \\N UNlT l ONLY n",,on,,
Public Incuiry Policy I.
Control Room Action A.
Determine the following information:
1.
Name of Caller:
2.
County of Residence:
3.
Telephone Number:
4.
Date and Time of Call:
5.
Srlef Description of Problem:
8.
Inform the caller that someone will get back to him as soon as possible.
C.
Refer to the Onsite Outy Roster and notify the Pubite Information Representative of the above situation.
II. Public Information Action A.
If the problem is stren related:
upon receipt of the above infor-mation the Public Information Representative should contact the respective County Emergency Management Office to determine the extent of the problem and to confirm that Mark Bitting has been notified and contact the caller.
County Emergency Management Office Phone Numbers CumberIand
- 238-9676 Dauphin
- 236-7976 Lancaster
- 299-8373 Lebanon
- 272-2296 York
- 843-5111 The next working day the Public Information Department shall notify the following: W. Gifford
- 8350 S. Levin
- 8326 R. Rogan
- 8048 J. Thomas
- 234-2111 R. Toole
- 8005 Onsite NRC Office
- 948-1155 B.
Other Problems 1.
Pubite Information Representative should handle the problems on a case basis.
b a
34.0 FOR USE IN UNIT I ON Y J
1029 ATTACIDIENT 3 Revision 14 e
IMPORTANT TO SAFETY NON-ENVIRONMENTAL IMPACT RELATED CONTP.OLLED COPY FOE -
USE IN UNIT I ONLY THREE MILE ISLAND NUCLEAR STATION t
UNIT NO. 1 ADMINISTRATIVE PROCEDURE 1029 CONDUCT OF OPERATIONS ksG.E Table of Effective Pages Page Revision Page Revision Page Revision Page -
Revision 1.0 12 26.0 12 2.0 12 27.0 11 3.0 11 28.0 11 4.0 11 29.0 14 5.0 11 30.0 14 6.0 11 7.0 13 8.0 11 9.0 11 10.0 11 11.0 11 12.0 11 13.0 11 14.0 11 15.0 12 16.0 12 17.0 12 18.0 12 19.0 12 20.0 12 21.0 12 22.0 12 23.0 12 24.0 12 25.0 12 A
0 4
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Signature
' ' Date (o b-$Y Q
Signature Date 03 d-7-s+
5!gnature Date Document ID:
0025B
FOR USE IN UNlT I ONLY OHsioni2 THREE MILE ISLAND NUCLEAR STATION I
UNIT NO. 1 ADMINISTRATIVE PROCEDURE 1029 CONDUCT OF OPERATIONS Table of Contents Section Page 1.0 GENERAL 3.0 1.1 Purpose 3.0 1.2 Applicability 3.0 2.0 SCOPE 3.0
3.0 REFERENCES
3.0 4.0 RESPONSIBILITIES 4.0 5.0 PROCECURE 4.0 5.1 Primary Responsibility 4.0 5.2 Conduct of Operating Personnel 5.0 5.3 Communications on Shift 11.0 5.4 Relief Procedures and Briefings 12.0 5.5 Component Labeling and Signs 13.0 5.6 Working Hours 14.0 5.7 Shift Manning Requirements 14.0 5.8 Log Sheets / Log Books 16.0 5.9 Operating Memos and Standing Orders 17.0 5.10 Incidents Occurring on Shift 18.0 5.11 Incident Review for Shift Petsonnel 19.0 5.12 Procedural Compliance 20.0 5.13 Housekeeping and Cleanliness 22.0 h
E OE. US$ lif OllldIt i O; s 5. Y
OR USE IN UNIT I ONLY 1029 Revision 12 Table of Contents (Cont'd) s.
7 l
Section Page 5.14 Radiological Controls 23.0 5.15 Control of Plant Setpoints 24.0 5.16 Independent Verification of Components 24.0 5.17 Components Found Out of Desired Position 25.0 Attachment I Plant Incident Report (form) 27.0 Attachment II Plant Incident Review Attendance Report (form) 28.0 Attachment III Command Responsibilities (letter) 29.0 i
)
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FOR USE IN UNIT I ONLY Revision 11
- 1. 0 GEN ERAL l
1.1 Purpose The purpose of this procedure is to establish guidelines and requirements for the safe, fonnal and professional onduct of operations in the plant.
1.2 Applicability This procedure is applicable to all personnel assigned to the Operations and Maintenance Director, TMI-1, and all personnel perfonning work in the plant. The requirements of this procedure, specifically those regarding distractions to on-shif t personnel and control of access to the Control Room, are also applicable to all personnel who enter the plant, no matter what their business.
- 2. 0 SCOPE l
This procedum presents methods by which plant personnel, especially shif t operating personnel, shall control plant routine matters and evolutions in a fonnal manner so as to insure attentiveness tu assigned responsibilities and to avoid distractions to those operators speciff-cally charged with the safe operation of the plant. This procedure also clearly establishes the authority and responsibility of Licensed Operator on duty to shutdown the plant when conditions so warrant.
- 3. 0 REF ERE NCES a.
AP 1009 - Unit 1 Organization and Chain of Connand b.
AP 1012 - Shif t Relief and Log Entries AP 1001J - Technical Specification Surveillance Program c.
d.
AP 1016 - Operations Surveillance Program AP 1037 - Control of Caution and Dh0 Tags e.
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- 3. 0
FOR USE IN UNIT I ONLY 1029 Revision 11 f.
AP 1031 - Nuclear Plant Staf f Working Hours i~
g.
AP 1013 - Bypass of Safety Functions and Jumper Control h.
AP 1036 - Instrument Out of Service Control 1.
AP 1002 - Rules for the Protection of Einployees Working on Electri-cal and Mechanical Apparatus j.
AP 1011 - Controlled Key Locker Control k.
AP 1033. - Operating Memos and Standing Orders 1.
AP 1044 - Event Review and Reporting Requirements m.
AP 1032 - Dissemination of Infonnation n.
AP 1008 - Good Housekeeping
- 4. 0 RESP 0NSIBILITES It is the responsibility of all members of the plant staff to carry a.
out the requirements of this procedure.
I b.
It is the responsibility of the Operations and Maintenance Direc-tor, TMI-1 to insure Unit 1 operations are conducted in accordance with this procedure.
- 5. 0 PROCEDURES 5.1 The primary responsibility of all personnel on the plant staff is to carry out their assigned duties in a safe and responsible manner using approved procedures in order to ensure safe operation of the Unit and compliance with the License, technical specifications and rules, regulations and orders of the NRC and,other regulatory agencie s.
The safe opegation of the Unit is the highest priority of the plant staff and shall be uppennost in their thinking and actions at all times.
i f - [ ' b..
l fd.0 s
FOR USE IN UNIT I ONLY 1029 Revision 11 5.2 Conduct of All Personnel
/'
a.
All on-duty personnel and supervisors must be aware of and responsible for the plant status, especially in their imedi-ate area of responsibility at all times.
This includes Shift Supervisors / Foreman being responsible for the perfomance of all personnel assigned to their shift who could affect plant safety, regardless of specialty affiliation.
Knowledge of the plant's status must be assured at shift changes by a fomal shif t turnover and relief in accordance with AP 1012.
b.
All operations must be carried out in the highest professional manner with close attention to detail.
c.
All on-duty personnel shall be physically fit and mentally al ert.
The Shif t Supervisor / Foreman is responsible to ensure
(
that all personnel, both licensed and non-licensed, meet this criteria and that person who does not exhibit physical fitness and mental alertness is imediately relieved of all duties associated with the operation of the plant.
d.
Operators shall remain within their imediate areas of respon-sibility until properly relieved, and be particularly atten-tive to the instrumentation and controls located within these areas at all times. Operators shall believe their instrumen-tation and be alert for and properly identify any instrumen-tation which is out of comission or out of calibration.
e.
Operators shall also be alert for any unusual trends in plant parameters, early signs of abnomal situations, and report same to the Shift Supervisor / Foreman.
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FOR USE IN UN!T I ONLY 1o29 Revision 11 f.
A pmfessional and fonnal atmosphere will be maintained in the
/
plant, especially in the Control Room, at all times.
g.-
Potentially distracting activities in the Control Room or at other plant areas shall be prohibited at all times. Any such distractions must be brought to the imediate attention of the Shift Supervisor / Foreman for resolution.
In this regards, the 1
following rules apply:
1.
No reading material of any kind except that directly related to the operation and maintenance of the plant shall be penaitted in the plant except as indicated below.
I Appropriate r,9a91ng materia) such as daily newspa-a.
pers and text books may be located in designated lunch rooms when these rooms are not used as work i
areas or watch stations.
This material may be read before starting shif t when arriving early; during l
lunch b'reaks (if not on shift) and during Lompany allowed breaks with the Foreman's or Supervisor's specific pennission.
b.
No unappropriate reading material such as scandal newspapers, puzzles, or other distasteful literature will be pennitted in the plant at any time.
l c.
The 0 and M director shall be,the sole judge as to j
what is and what is not appropriate reading material.
2.
No radios except those specifically designed for control of plant operations and comunciations and except for l
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those indicated below shall be permitted in the plant at any time.
a.
Radios may be located in designated lunch rooms when these rooms are not used as work areas or watch stations and played before starting shift when arriving early; during lunch breaks; and during Company allowed breaks with the Foreman's or Supe'r-visor's specific permission.
3.
Commerical televisions are not permitted in the plant.
4.
No games, horseplay, or other distracting activities shall be permitted in the plant at any time.
5.
Access to the enclosed area of the Control Room shall be limited to those persons on official business only and loitering in this area is prohibited. All personnel except Operations personnel and on duty Shift Technical J
i Advisor must obtain permission from the Shift Super-visor / Foreman or their designee prior to entering the enclosed area of the Control Room.
It is the responsi-bility of the Shift Supervisor / Foreman to limit the number of people in the Control Room at any time to insure that operators are not distracted from their primary responsibility for the safe. operation of the plant and to insure that a professional atmosphere is maintained.
t j
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FOR USE IN UNIT I ONLY m,
Revision 11 6.
Meals shall not be eaten at the Control Console Areas of the Control Room.
Operators on duty at that area shall
/ -
be properly relieved for meal s and eat their meal s away from the Control Consoles.
This restriction does not apply to eating or drinking a single item.
7.
All necessary plant-related technical / administrative business must be conducted at a location and in such a manner that neither Control Room Operator attentiveness nor the professional atmosphere in the Control Room will be compromised.
h.
Only licensed operators or trainees under their direct control are pennitted to manipulate the controls that directly affect the reactivity or power level of the reactor.
i.
Trainees shall be pennitted to operate equipment / systems, to l
manipulate controls, or to take log readings only under the dirtet supervision and control of a qualified operator.
The qualified operator is responsible for the actions taken by a trainee under his supervision, j.
Licensed operators are required to be present at the controls at all times during the operation of the plant, either in an operating or shutdown condition.
Specific shift manning responsibilities are contained in Section 5.7 of this proce-dure.
k.
Operation of equipment or systems shall only be accomplished with the knowledge and consent of the Shif t Supervisor or Shift Foreman.
In this regards, operations of systems and
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N.> i N L 'l t-
FOR USE IN UNIT I ONLY 1mg Revision 11 equipment in the plant by Auxiliary Operators shall be con-I' ducted only on the direct orders of the Shift Supervisor, Shift Forenan, or 010 on duty at the panel, except in cases of i
emergency, or if necessary to prevent personnel injury or equipment damage.
Direction to Auxiliary Operators by the CR0 on duty at the panel in no way relieves the Shift Super-visor / Foreman of his responsibility for the safe conduct of operations and the direction of plant activities.
1.
No operators of other crews (not presently assigned on shift) will take operating actions unless specifically authorized and directed by the on-shif t operating crew.
Should conditions exist that reqaire non-duty personnel to act without direction from the duty crew, the individual involved shall be fully
(
accountable for such action.
The intent of this guidance is not intended to restrict qualified operators from taking appropriate actions in an emergency situation when such action is clearly required for the healtn and safety of the public, safety of personnel, or to prevent major equipment damage.
m.
All surveillance evolutions shall be conducted in accordance with either AP 1016 or AP 1001J as applicable.
n.
All switching and tagging operations will be performed in accordance with AP 1002.
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FOR USE IN UNlT I ONLY 102s Revision 11 i
Independent verification of operational activities affecting o.
f safety will be accomplished as follows, when the affected systems are required to be operable:
1.
At each shift relief, ESAS and EFW Readiness Checklists and log sheets will be reviewed by both the on-coming and i
off-going operator in accordar.ce with AP 1012.
2.
Alternate safety trains shall be verified operable prior to removing one from service, and upon restoration of a safety component / system to service, it shall be verified operable in accordance with AP 1002 or the applicable testing document.
I 3.
Following surveillance tests or special operations on ESAS and EFW Systems, two independent valye and breaker lineups will be conducted within the boundary of the l
system affected by the tests or special operations to provide assurance that the system is returned to full operational status.
l p.
The Shift Supervisor, Shift Foreman, and CR0 on duty at the i
panel have the authority, and in fact the responsibility, to i
order or affect the plant to be shutdown and placed in a safe condition or to take whatever timely and proper action neces-sary whenever in his judgement such action (s) is necessary for l
the health and safety of the public or to prevent serious injury, serious equipment damage, a major incident such as the uncontrolled release of radioactive material, or to prevent exceeding technical specification limits.
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FOR USE IN UNIT I ONLY 102g Revision 11 q.
The Shif t Supervisor has the primary management responsibility
(
until properly relieved, for the safe operation of the plant under all conditions occurring on shift.
The unique respon-sibilites and authort ty of the Shift Supervisor are clearly delineated in the attached letter from the Director, THI-1 and tne President GPU Nuclear Corporation to all TMI-1 Shift Supervisors ( Attactinent III).
r.
The Shift Supervisor on duty shall not be assigned administra-tiie or other functions whic'h detract from or are subordinate to his primar/ responsibility for assuring safe operation of the plant.
The administrative duties assigned Ao the Shif t Supervisor shall be reviewed annually by the Managar, of Plant Operations and a report thereof submitted to the Operations and Maintenance Director, THI-1 and to the Vice President, 7
TMI-1 for their review and approval.
s.
Operators on duty should not nonnally be assigned other responsibilites or work which interferes with their prkmary responsibility for the safe operation of the plant.
t.
Shif t Supervisors, Shif t Foremen and CR0s shalI wear the special clothing provided by the Company while on duty. Other members of the plant staf f shall wear neat and clean clothing as appropriate for their assigned responsibilities. No open toed shoes, sandals, or excessively worn or tattered clothing will be pennitted. Personnel shall be well groomed and neat in appearance as befitting their position of responsibility for the proper and safe operation of a nuclear power plant.
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FOR USE IN UNlT I ONLY 1029 Revision 11 u.
Before acknowledging or resetting'an alanning annunciator, the f
operator shall have read or have knowledge of the annuncia-tor's window nomenclature and verified no other alann came in i
coincident with the alann being acknowledged.
5.3 Comunication on Shif t a.
Comunications to operating personnel must be clear and concise.
Directions should be given only when you have the complete attention of the individual to whom they are given.
These directions shall be given in such a manner that they are explicit and understandable.
This shall be verified by having the operator acknowledge the direction so the director is satisfied that the orders are understood. Upon completion of the dirteted evolution, the operator shall report back to the controlling station the exact action that he has taken.
Whenever possible, the individual onfering an action shall verify that it has been carried out correctly by observing expected indication (indication lights, meters, gauges, etc. )
and plant / system reaction.
Proper comunications both face to face and by page, radio, phone or other means are essential 4
for all operational functions.
b.
Whenever possible, comunications for major plant evolutions i
should be controlled by the use of the Maintenance and Instru-mentation telephone syste,m vice the gray page telephone.
c.
The page announcing system shall nonna11y be used by operating personnel to announce emersencies, unexpected events, to relay i
infonnation regarcing plant status and, where not possible by
]
direct phone comunications, to direct actions in the plant.
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FOR USE IN UNlT I ON_Y so,,
Revision 11 d.
Routine comunications to personnel in the Cor<ml Room shall I
be conducted by the regular dial telephone system, when availabl e.
e.
When answering a telephone, the 1ocation, name of the indivi-dual and position, i.e. Shif t Foreman, G0, should always be given.
f.
Critical steps in an evolution shall be announced in the Control Room and if applicable over the plant paging and/or the Maintenance and Instrumentation telephone system.
g.
Horseplay or unofficial use of the plant paging system is a serious breech of discipline and good order and offenders will be deal t wi th acconlingly.
5.4 Relief Procedums and. Briefings At shif t change a fonnal shif t relief shall be accomplished a.
and the oncoming Shift Supervisor / Foreman shall brief his shif t on plant status and upcoming evolutions or work in accordance with AP 1012.
b.
Other briefings shall be conducted when deemed necessary by the Manager, P1 ant Operations, Shi ft Supervisor, Shift Fore-man, or GO prior to conducting critical, complicated, unusual or infrequent operations.
5.5 Component Labeling and Signs a.
Personnel shall not independently label plant components or systems or post signs.
Labeling of components or systems and signs shall be in acconiance with an approved procedure, ECM, Work Authorization Notice or by the explicit authorization of i(N i k 5 b b. {!d,j II(.I!
l ( Y b.\\
FOR USE IN UNlT I ONLY 1029 Revision 11 the Manager, Plant Operations. Emergency posting of areas for I safety purposes or operational limitations with temporary labels may be approved by the Shif t Supervisor as long as his signature and date appears on the sign. b. Labeling of components and installation of signs shall be accomplished with neat and legible labels such as metal, acceptabl e myl ar or " bakelite". Label s and signs shall be appropriately fastened so they do not become unattached. Handwritten lables and signs are not pemitted in the plant except where specifically authorized by procedure, the Mana-ger, Plant Operations or his designee. c. When a pemanent. change is needed, submit a Technical Func-tions Work Request or Task Request. Technical Functions will send the WR or TR to Systems Analysis for action. This will ensure a proper Technical Functions review, and revision of af fected controlled drawings. Technical Functions will also obtain the revisec label and provibe the installation package to the field. 5.6 Working hours and overtime regulations for personnel perfomin3 safety related functions shall be< in accordance with Ap 1031. 5.7 Shift Manning Requirements a. Listed below are the minimum shift operations manning require-ments. Specific pemission must be obtained from the Opera-
- Jr.DC l
- 4. 0'- INI ! I kh\\ b '
ig I (!Ts (
FOR USE IN UNIT I ONLY Usion12 tions and Maintenance, Director, THI-l and the Vice President, TMI-l to deviate from these requirements. Plant > 200*F RCS Temeerature Plant <200*F RCS Temoerature 1 Shift Supervisor (SRO) 1 Shift Supervisor *(SRO) 1 Shift Foreman (SRO) 1 Shift Foreman
- 3 Control Room Operators 2 Control Room Operators (at least 2 RO)
(at least 1 RO) 5 Auxiliary Operators 4 Auxiliary Operators 1 Shift Technical Advisor NA
- May be waived by the Manager, Plant Operations THI-1. Either a 1
qualifted SRO, Shift Supervisor, or Shift Foreman must be on shift at all times when below 200*F. NOTE: SRO - Senior Reactor Operator qualified RO - Reactor Operato qualifted b. A minimum of 1 SRO and 1 RO must be in the Control Room at all times when the RCS is greater than 200*F. c. At least 1 SRO or 1 RO must be in the Control Room at all times when the RCS is less than 200*F. d. When the RCS is >200*F and a minimum of,2 SRO's and 2 R0's on l shift cannot be adhered to on a six shift rotation utilizing l l qualified licensed personnel within the organization the Manager of Plant Operations shall immediately inform and discuss the situation with the Directo' THI-1, the 0 and M r Director THI-1, and the Supervisor of Licensing. The supervisor of Licensing shall inform the Commonwealth and the NRC if 2 SRO's and 2 RO's have not been adhered to on a five l shift rotation for ten consecutive days. !\\ f '. [
FOR USE IN UNIT I ON _.Y l0'sion12 e. All irradiated fuel handling shall be supervised by an SRO who ~ (' has no other concurrent responsibilities or duties during this evolution. f. A Fire Brigade of at least 5 members shall be maintained on-site at all times. The Fire Brigade shall not include those personnel required in the Control Room as noted in.b. and c. above nor those personnel necessary for the safe shutdown of the Unit as specified in the Technical Specifica-tions. Only personnel who have satisfactorily completed the required fire fighting training shall be assigned as Fire Brigade members. The members of the Fire Brigade shall be documented on the Control Room Operator's Log Sheet. g. The fact that the minimum shift manning requirements have been met will be documented on the Control Room Operator's Log Sheet for each shift. S.8 Log Sheets / Log Books a. Logkeeping shall be done in a timely, accurate and complete
- manner, b.
The following Log Books will be maintained: 1. Control Room Operators Log Book (requirements are speci-fled in AP 1012). 2. Shift Foreman's Log Book (Requirements are specified in AP 1012). 3. Jumper and Lifted Lead Log Book (Requirements are spect-fled in AP 1013). i ('.h (Ib b ([\\l 6 (0) !,l '; (y,Q('j w
FOR USE IN UNIT I ONLY s$sion12 4. Instrument Out of Service Log Book (Requirments specified in AP 1036). S. Do_No Operate and Caution. Tag Log Book (Requirements specified in AP 1037). 6. Application for Equipment Out of Service Log Book (Re-quirements specified in AP 1002). 7. Controlled Key Log Book (Requirements in AP 1011). c. The following Log Sheets shall be maintained: 1. Control Room Log Sheet 2. Primary Operators Log Sheet 3. Secondary Operators Log Sheet 4. Out Building Operators Log Sheet d. The specified Logs shall be reviewed each shift in accordance with AP 1012 by the Shift Foreman / Supervisor. e. The readings on Log Sheets must be completed unless an excep-tion is granted by the Shift Foreman. The Shift Foreman will list the reason for this exception on the Log Sheet or attach an explanation sheet. 5.9 Operating Memos and Standing Orders a. An Operation Memo and Standing Order Book will be maintained in the Control Room in accordance with AP 1033. b. This book will be reviewed by duty shift personnel in accor-dance with AP 1012. t,'. 1 7.,0.. ' ', O. ;! s.' s s s i s.
FOR USE IN UNlT I ONLY OMsion12 5.10 Incidents Occurring on Shift ^ The following steps should be taken when an event occurs or finding is-identified that places the plant or personnel in an unsafe condition. 1. Place the situation in a safe condition as soon as possible based on the surrounding circumstances. 2. Notify the Shift Foreman / Shift Supervisor of the incident / finding as soon as practical. 3. The Shift Foreman / Shift Supervisor should consider the overall scope and potential effects of the situation and ensure steps are being taken to: a. mitigate the consequences of the event / finding b. prevent the present situation from degrading 4. The Shift Supervisor should contact the cognizant Department Head / Manager and the Unit 1 Operations and Maintenance Direc-tor or his designee if conditions warrent. 5. The Shift Supervisor or the Unit 1 Operations and Maintenance Director or his designee, if consulted, should determine whether corrective action is appropriate and the following followup action is required. NOTE: See guidelines contained in EPIP-1001.1 through 1001.4 and AP 1044. _=_____ a. Implement Emergency Plan =___---___-_____-____-- NOTE: In the event the Emergency Plan is initiated, the Shift Supervisor is the Emergency Director until properly relieved. iiC
- 'h i (Naem 't.ONLY 9
FOR USE IN UNlT I ONLY g,,,,,, b. Notify personnel /outside agencies as specified by AP 1044 i or the Emergency Plan. t c. S'ubmit Reports: - AP 1044 Form (Potential Reportability) - AP 1029 Form (Plant Incident Report) 5.11 Incident Review for Shift Personnel. a. The Manager, Plant Operations shall determine if and to what extent an incident should be reviewed by on shift personnel. He shall be responsible for investigations of operational incidents. Incidents deemed necessary for review shall have a report issued following the format of Attachment I. b. The incident will be reviewed with all shift personnel by the Manager, Plant Operations or his designee. An attendance will ( be taken and documented using Attachment II. Anyone missing the review will be rescheduled or be required to review the written report of the incident. c. Copies of all inciderit reports will be sent to the Vice President, THI-I and to the Operations and Maintenance, l Director, THI-1. Copies will also be sent to the PRG and to Licensing for review as to reportability. d. A copy of each incident report will be sent to the Training Department for inclusion in the Operator Training Program as applicable. e. A copy of each incident report will be sent to the Independent Onsite Safety Review Group (ISORG) for an independent review. l g
FOR USE IN UNIT I ONLY Ssion12 5.12 Procedural Compliance a. Compliance with approved procedures is absolutely essential for the safe operation of the plant. b. THI-l shall be operated and maintained in accordance with written, approved procedures which have been formally issued and distributed for use. c. Personnel shall not give directions,. guidance, recommendations or clarifications which conflict with approved procedures. d. The responsibility for following approved procedures rests with the supervisor directing the work or evolution and with the individual performing the work or evolution. e. Many procedures have in them " symptoms" which may indicate a problem, possibly a need to go promptly into emergency actions. However, a symptom is only an indication which must be evaluated. It may indicate a situation which has no safety relationship. The important consideration is that, while most parts of a procedure are to be followed literally, the inclu-sion of symptoms in procedures gives the operator guidance on which he must exercise judgement. When an operator identifies a symptom, he will first attempt to verify the symptom by checking other available instrumentation. Upon the verifica-tion, the operator shall follow the steps of the procedure and notify his supervisor immediately. If'he is unable to do so, he will immediately notify his supervisor to request guidance and further direction. l i l [ ( N (i h b-ll 20;,Q y p l ();\\ L, \\ N 1
~ FOR USE IN UNlT I ONLY Ssioni2 f. If an individual cannot or believes he should not follow a procedure as written, he shall place the system / component into a stable and safe condition.and advise his supervisor immedi-ately. In such cases, the work or evolution should not be continued until the supervisor resolves the question and the Supervisor determines that the procedure can be followed as written or the procedure har, been revised, approved, and/or reissued in accordance with :urrent administrative controls. AP 100lG gives specific guidance on procedure usage and latitude allowed for procedure compilance. g. Supervisory personnel are respons!ble for: 1. Indoctrination of subordinates in procedural requirements and the requirements for compliance therewith. 2. Ensuring that personnel understand procedures being used including the objectives and desired results to be achieved by following the procedure. 3. Encouraging and promoting positive feedback from person-nel on the ' adequacy of procedures and for promptly initiating.and processing required changes in accordance with current administrative controls. In this regard, p.ocedure users often identify but feel inhibited to suggest changes to procedures based on: (1) Problems identified during use (2) inconsistancies between procedures (3) better ways to perform an evolution (4) a good practice that would increase the effec-tiveness of efficiency of an evolution. ' ' t, ' k. (.b b ki'[2IOikt i h\\b s
FOR USE IN UNlT I ONLY g,,,,,, Each supervisor should be sensitive to, and encourage, this type of feedback so that procedures can be improved as a " user" document. 4. Preventing unauthorized oral approval of changes in procedures either on the part of themselves or others. Requirements regarding telecon approvals are described in other procedures. 5. Enforcing compliance with procedures as written in accordance with AP 1001G. h. Nothing in the above guidance is intended to restrict per son.. nel from taking immediate actions to prevent or correct an unsafe or casualty situation which could adversely effect the health and safety of the public, personnel safety, or lead to { serious equipment / system damage, even when such actions are outside the requirements and guidelines of approved proce-dures. Under such circumstances, the individual involved shall take such actions as necessary to place the equipment /- system into a safe and stable condition and immediately notify his supervisor and the Shift Supervisor / Foreman. The Shift Supervisor / Foreman shall exercise his.best judgement to ensure continued safety of operation and if warranted notify the l Manager, Plant Operations, or if he is not available, the Outy Superintendent. 5.13 Housekeeping and Cleanliness a. A clean and orderly environment is a prerequisite and an essential ingredient for safe, proper and professional opera-tion of the unit. tm Ud' ,., e .. x Iy\\tze;is ; 1 i O,;i t -
~ FOR USE IN UN(T I ONLY b. Cleanliness'is the responsibility of all personnel and no program to establish and maintain a clean operating and work environment can be effective without the active participation and support of all personnel. c. Supervisors / Foremen are responsible to insure that job sites are appropriately cleaned up/ picked up and that tools and equipment are neatly arranged at the end of the working day or on completion of a specific job / evolution. d. Supervisory personnel are also responsible to frequently tour their responsible job sites and areas in the plant to insure that high standards of cleanliness and order are maintained. e. Specific housekeeping responsibilities are contained in procedure AP 1008. 5.14 Radiological Controls a. The implementation of sound. practical, and effective radio-logical practices and procedures is essential to the safe operation and maintenance of the plant. b. The use of proper radiological controls, practices and proce-dures is the responsibility of all members of the plant staff. All personnel must, as a matter of habit, be continuously l alert to the radiological aspects of the work / evolution they are involved in and take appropriate actions to minimize man-rem exposure and to control thc. generation and spread of radioactive contamination, k i n, i,lh ; {lp.0,; ( p j ()lg g i i
~ FOR USE IN UN(T I ONLY OMsioni2 c. ' Operations and Maintenace supervisors are responsible for frequently inspecting their job sites and areas of responsi-biliti.es in the plant.to insure that appropriate and effective radiological procedures and controls are being utilized, and that radiological deficiencies are identified and corrected. 5.15 Control of Plant Set Points Set Points for alarms, control devices, protective devices, breakers, etc. shall be established by original design, approved procedures or approved plant modifications. Set Points shall not be changed except in accordance with approved procedures or approved plant modifications. Any deviation to this policy must be approved in writing by the Manager of Plant Operations and the Operations and Maintenance Ofrector. 5.16 Independent Verification of Components When called for in plant procedures, components shall be indepen-dently verified to be in their proper alignment by the following guidelines: Switches, breakers must be independently checked by two (2) a. separate personnel visually sighting these components in the proper position. Remote light indicators are acceptable where l supplied for verification use. If this verification is being l performed after the completion of a Surveillance Test, the i person doing the independent verification must be different from the person who signed the first position check as part of the conduct of the surveillance procedure. l l l f.C ii : ' lt,2 4 ' 0. ; x'- l' '1 (* ).'\\ ;w \\ ' I' i t s! i v \\ s. s.... l
1 COR USE IN UNIT I ONLY Usioni2 ~ b. Verification of valve positions will be as follows: 1. If the valve has remote indication, two (2) independent personnel may use that remote indication for their verification. 2. For manual valves, two (2) independent checks of position must be performed. Each party will verify its proper position by physically turning the valve in the closed direction. If a valve is found to be in an unexpected position, inform the Shift Foreman or Shift Supervisor and obtain further guidance before changing the valve position. For valves that are difficult to get to (i.e., need ladders to reach or other physical difficulties) it is permissable for one person to operate the valve and a second person to perform the second verification visu-ally. This option will only be accepted as the second check when the second party can by his proximity certify operation was sufficient to determine proper valve position. 5.17 Components Found Out of Desired Position Any time a plant component is found out of its proper plant re-quired position, the following procedure will be followed: Personnel finding a component out of position will notify the a. Shift Supervisor / Shift Foreman immediat~ely. Fu !iS P ids @Nr! ! ON! Y
0 FOR USE IN UNIT I ON_.Y 1029 D Revision 12 g b. The Shift Supervisor / Shift Foreman shall evaluate plant / system t conditions to determine the appropriate position of the If it l' actually out of position, the component in question. s Shift Supervisor / Shift Foreman shall have the component returned to its required position and the system checked for operability. c. The Shift Supervisor / Shift Foreman will investigate the reason the component was out of position. A log entry will be made including component, person finding problem and corrective action taken. d. For critical components, the Shift Supervisor / Shift Foreman will fill out a Plant Incident Report with pertinent informa-tion including the investigation into the possibility of deliberate acts to cause a problem in the plant and forward copies to the Operations and Maintenance Director and the Manager of Plant Operations. e. The Operations and Maintenance Director and the Manager of Plant Operations will determine if any further action is required. ! Ub bb:b lfkSjt I I 8 N *-
FOR USE IN UNIT I ONLY 1029 Revision 11 ATTACHlfNT I TITLE PLANT -INCIDENT REPORT NO. DATE TIME OF INCIDENT Plant Conditions Sequence of Events Environmental Impact Personnel Safety Impact Discussion Conclusion Items Incorrect / Lessons Learned l Corrective Actions l SUBMITTED APPROVED Manager - Plant Operations cc: Vice President, TMI-1 Operations and Haintenance Director, TMI-1 PRG Chairman, TMI-1 Operator Training Manager i Licensing Department Manager, Safety Review, THI-1 Training Coordinator, TMI-1 " (!h (lir iiv Libiti ! O ls't. N l 27.0 \\
~ FOR USE IN UNlT I ONLY Revision 11 ATTACHIENT II PLANT INCIDENT REVIEW ATTENDANCE REPORT PLANT INCIDENT REPORT NO. Crew Briefed Briefed by Date/ Time Personnel in Attendance Personnel from Crew needing Briefing N#4E DATE C0lfLETED SIGNATURE i P
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f e r t oe e r o 9. 's / t-e k U N \\ T 's ' ', V C 1 1 28.0'- '\\. I i m
1029 Revision 14 $ Nuclear Engsao GPU Nuclear Corporation S Middletown. Pennsylvania 17057 / 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number: File: Procedures / Policies 3000-84-096 March 2,1984 TO: THI-I SHIFT SUPERVISORS
SUBJECT:
COMt%ND RESPONSIBILITIES Nuclear generating facilities have the potential to significantly impact the health and safety of the public. This potential impact places a special burden and responsib.11ty on those who manage and command operations at the Three Mile Island Nuclear Station. The first line of defense in protecting and assuring the health and safety of the public and the safety of personnel within the plant is the sa e operation d { of all plant systems and components. You, as the Shift Supervisor, have the primary management responsibility until properly relieved, for the safe operation of the plant under all conditions occurring on your shift. Accordingly, you are directly charged with both the responsib(1Gy and the command authority over all shift operations, and maintenance activities, and implementation of radiological controls under nomal and abnomal conditions. Both the supervisor coming on shift and the supervisor being relieved shall make certain they review, convey and understand plant status and on-going activities and that the activities are deemed to be in accordance with safety requirements. Your responsibilities require you to constantly maintain the broadest perspective of operational conditions potentially affecting the general public, TMI personnel, and the safety of the plant. Maintenance of this broad perspective shall be your highest priority at 'all times when you are on duty. In this regard, in times of emergency, you should be sure never to become so involved in any single operatien that you are preoccupied to the extent that you might not provide adequate direction when multiple operations are required in the Control Room. During accident situations while functioning as Emergency Director you shall remain in the Control Room to manage and direct the activities of the Shift Foreman, Control Room Operators, Shift Technical Advisor, Radiological Controls Personnel, other plant operators and required support personnel in accordance with the approved Emergency Plan until properly relieved. GPU Nuclear Corporation is a sutsic:ary cf the General Puelic Utihties CorcCratton 29.0
o 1029 Revision 14 ' March 2, 1984 3000-84-096 An essential element of protection of public health and safety is timely notification of State, local, NRC and Company officials in the event of an accident. There should be no reluctance on your part to initiate the notifications called for by the Emergency Plan if conditions indicate a potential threat to public health or safety even if more evaluation is necessary to confirm the existence of such a threat. Further, it is imperative that you provide the opportunity for guidance and direction from the line management to which you report by prompt notification to them of the existence of abnomal conditions. In making these reports both to the State, local, NRC and Company officials the following principles must be observed: Promptly report all facts and other information concerning plant conditions and the potential threat to the public. Be thoroughly and totally candid in your reports and do not withhold any infomation. Answer any questions asked to the best of your ability, whether or not they appear to you to be pertinent to the situation at hand. Make every reasonable effort to convey infonnation so that the recipients have an understanding of the significance of the report including the degree of uncertainty that may exist as to plant conditions and the prospect for further degradation in the situation. In any abnormal event or unusual occurrence, whether or not it falls into one of the emergency event classifications, it is also of the utmost importance that the Comunications Division's Duty Representative be infonned as soon as possible. It is essential that the Comunications Division receive early notification so they may be prepared to respond to public and press inquiries. Constant, vigilant recognition of your management role to maintain a comand overview of the situation, to make decisions and to direct operations is the most important element in executing your responsibility to protect under all conditions, the health and safety of the public, the personnel on your shift, and the safe operation of plant systems and components under nonna1, off normal, and accident conditions. This letter replaces and supersedes our letter to you, same subject, dated May 25,1983. f k. ? H. D. Hukill P. R. Clark Vice President & Director, TMI-I President PRC/HDH/NR/dds cc: M. J. Ross, Manager, Plant Operations TMI-I R. J. Toole, Operations and Maintenance Director THI-I CARIRS - TMI 30.0 -..,..,__-,n.__---___,,n_
~ 5 ATTACEE'iT 4 i [e d)] Nuclear, i . -mt. n i ,j l Tstte
- RevtSlon No I
Trainee Evaluation Once Sack on-The-Job 0-00 ADClicabil.ty Scoce Respont.cle Office I All Training and Education Cecart: ent Personnel Educe icnal Ceveler-e - l Tnis cacament is important to safety 0 yes c(No Effecove Date List of Effective Pages Pace Pevisicn 1.0 ll C-00 Proposed changes are 2.0 ll 0-00 highlighted with ll l 3.0 0-00 double bar indication 4.0 l 0-00 in right Irargin 5.0 1 0-00 6.0 H 0-00 El-1 0-00 I El-2 0-00 El-3 0-00 E2-1 ll. 0-00 E2-2 ll C-00 E2-3 ll I 11 i l' S.gna ture Concurnng Organizational Element j Oate Originator M ,[ [ G l Educational f'ev. C0ordina Or, ?"!, y f, g 7 Concurrec evlQ y'QB,',sp l Manager,c:enerate7ainin: 7.- U T,L[/ h Td ! n a-e. o t an- -a 4 n cc c: o //2/p r t "j;ge ivanage, m ar: -rainec - r - i 7 f,.,7 / l l j: t l! l l l l I i, ll l Il I i e l l !'"'""O M b L /) It'anacer, Educational revele en: ! 3. n.3r 1: L, M d, / h Icire::cr,Trainin t Eeuca:4:n
- g.,g.rs--
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' = 20 55
- 20 4
0.00r 0;; o ENUCleGF TRAINING AFC EDUCATION CEPARTNENT PROGRAM CEVE CRENT M. 62CC-.:CH-2682.1C 3 7;ue Trainee Evaluatien Cnce Sack Cn-The-Jcb @'*" N*- 1 i
- 1. 0 RJRPOSE :
The purpcse of this precedure is to establish a process to evaluate training program effectiveness by collecting feecback data frcra trainees and their stcerviscrs when training is ccccleted and they are back en-the-jeb. 2.0 APPCICASILITY WO SM: 2.1 This procedure has GRJC wide applicability.
- 2. 2 This preceours will become effective upon the date of publication.
3.0 TFINITICNS
3.1 Survey - a detailed study or inspection, as by gathering infcrmaticn through observations, questiennaires, etc. and aralyring it.
4.0 PR2CEOLE
4.1 In order to evaluate the effectiveness of training, data shall be l collected from trainees and thel siz:ervisors when the training is cc cleted and tne trainees are back en the #b. 4.1.1 The Manager cf Training shall cetermine which s::ecialty training courses and/or trainirg pregrams' trainees are to be evaluated in accordance with this procecure. 4.1. 2 The Manager of Training shall scooint a cerson to act as evaluator to collect this cata for the training prcgrams conducted at the site. 4.1.3 Tre evaluate should conduct the surveys frem 4,cnths to 10 j months after training is completed for trainees caming out of initial programs using cne of the methcds outlined in 4.3. i 4.1. 4 For. recpalificatien/ cyclic / refresher training tne evaluator l shall take a periodic samling of qualified joo ineweents l using cne of tre methods cutlined in 4.3. i 4.1. 5 E Recnired reviews will be added to acprcpriate program descripticns. 2..* l 3 l 2 i I 0570G:02 2.0
- '083'W
.:5 Ic i= u:I; c.;;: .s_ TRAINING Ato EDUCATION CEPARTMENT N" D" hhM7 ROGRAM CEVE.0FNENT MANUf4. 62CC-tCM-2662.1C i ritt. Trainee Evaluation Once Back Cn-The4cb Revesien No. 1
- 4. 2 Trure are 5 questions that the evaluator should accress:
Hcw do ecloyees rate the effectiveness cf trainirg7 How job-relevant do snployees find trainirg? Hcw well is trainirg timed te meet actual jcb demands? What specific tasks require more emchasis curirg trainirg? What tcpics require less emphasis?
- 4. 2.1 The questions that are asked of trainees and stpervisers should support these five areas.
4.3 The evaluator shall accernplish data gatrerirg using any one of the four methcds listed belcw.
- 4. 3.1 In Person Interviews are the most reliable of the survey metnces, cecause ene evaluater, acting as interviewer, can pursue particular rescansas.
There is less enarce of misinterpreting a rescanse. 4.3.1.1 The questions femd en the inteIview fcrms, Exhibits 1 and 2 are app:coriate fer in persen interviews.
- 4. 3.1. 2 Explain to the trainee or st.cervisor the purpose.of the interview.
l
- 4. 3.1. 3 All resconses shall be surrnarize:: en tre inverview form.
- 4. 3.1. 4 All interviews shall be concucted in a quiet and private area.
4.3.2 Telechene Interviews are also a rellacle means of gatfering cata. 4.3.2.1 The cuestions femd en the interview ferms, Exhibits 1 and 2, are accrecriate for telechere 5 intarview s. I 4.3.2.2 Explain to the trainee or stcervisc: tre aj purpose of the interview. 1 3 i 1 i 1 l 0570G:02 3.0 2xcmc .n i l
- Y 10 !!
- -
- 1.
- =
NUd@GI TRAINbG Ato EDUCATICH OEPARTMENT N S D*' F90CRtM IVELCPENT vANut4. 6200-EM-26c2.10 i;oe Trainee Evaluaticn Once Back Orr-The4cc
- v'oca No-1
- 4. 3. 2. 3 All rescenses shall be surrarized on tre interview form.
4.3.3 Malled cuesticrnaires are the least desiracle methcd of cata ga:nering cecause the interviewer cces nct have tre ability to cuestion the trainee or swerviser ccccerning vague or amoigw us responses. Mcwever, a mailed questicnnaire can be follcwed up with an interview. Mailec questionnaires are a geca means of gathering data wren time or other job carmitments are a censideration.
- 4. 3. 3.'l when using a mailed questiennaire, a cover letter frcm the Training and Educaticn Cecartment should ce included. This letter srculd:
explain the purpose of the questiennaire give clear directions including where tre cpesticrnaire should be sent upcn cernoleticn solicit the individuals help thank the rescendent fc: nis time.
- 4. 3. 3. 2 The questions found on the interview forms, Exhiti: I and 2, are acpropriata for mailed questiernaires.
l 4.3.4 Recuired reviews comleted by the stcarvisc:s of trainees once ceck on tre jcb is anotrer metred. If a required review 19 Selected then the frecuercy of ecministrati n shall be determirac by user grew management anc Trainirg and Ecucation Cepartment.
- 4. 3. 4.1 A list of specific duties desi; rec for a scecific Jcc classificaticn may be cavelecec and used with Exhibit 2.
This list can. serve as an aid to tre ce sen performing the evaluation. This list sncule be incorporated as an attacntent in the particular training p:cgram's P:cGram Gescripticn. 5 4.4.5 Trainees in tre same trainirg essicn should be surveyed in i the see manner. l ~ E l I r l l 0570G:02 4.0 "'*d
.:i I.: !! W:2.
- 4. ;;;
.c : ' TRAINING Ato EDUCATION DEDARTMENT Numeer ENUCIOG7 m0m em.cmEnT vamm. 6200. o _26a2.10 w 7;o. Trainee Evaluatien once Back On-The4cc h*er' NC-1
- 4. 4.1 The followirg infomation shall be ircluded en all :ypes of surveys:
Name (cotional for trainee) Title Cate of Survey Cates of Trainirq Name of Training P cgram Evaluator Type of Survey 4.5 All data should be reviewed and analyzed and a summary recert precared which summerizes the significant firdings and reccmendaticns fer imp:cvement. 4.5.1 Sy:ervisor ard Trainee informatien snculd be c:rcared te discover irconsistencies. 4.5.2 Trainee info.~etion srculd be empared to the indivital's course or pregram performarce. A.5.3 Requests for mecifications to t:sining cased en these surveys shall be forwarded to the acc coriate training managenent for ccr.sideraticn by tre Tecenical Centene Review and Interface ? recess. (See 6.2)
- 4. 6 The indivital evaluations will be kept in tre Training Cecartment for a cericd of 3 years.
The purccse of tre retentien will ce to review the evaluations for trends in recc:ded training recommendaticns. Emerging trends will be used as incut to revise and/or uccate trainirg. A review cf remedial help will be mace for tPc3e individuals exhibitirg isolatec training needs.
5.0 BESFCNSIBILITIES
5.1 Director, Training and Ectxatico is resronsibis for develocing anc uccatirg this p ccedare and for assistirg GPJNC Civisiens in its itnplementaticn. 5.2 Manager of Site Training:- c 5.2.1 Cetemines which specialty trainirg ecurses' and/c 0 training p cgrams' trainees are tc ce evaluated. Oj
- 5. 2. 2 Acccints a persco to act as evaluator fc tnis c ccecure.
l' I t 9 Ic 0570C:02 5.0 accc' esc '.a
0= 10 != . : ll. 4 4.00: TRAINING A?O ECUCATICN DEPARTWENT Numoer [r ()J %yClM7 50 CRAM CEVELCRENT MANU/4. 6200-/CN-2682.10 y rice Trainee Evaluatico Cece Back On-The-Jcb 8m'en Nc. 1 5.3 This p;cgram stcervisor or manager shall effect lialscn with tre user g:cm sacervisors to: 5.3.1 Allow and encourage the employees wno have recently conpleted training programs to ccccerate witn the evaluator in ecliectirs the data outlined in this prececure. 5.3.2 Congleta surveys on their empicyees aho have recently comleted a specialty trainirg course and/cr training program.
- 5. 3. 3
, Assure that required reviews are corpletec, forwardec to Trainirg, ions co pleted. a surrery recort prepared, and recomencaticas for revis
6.0 EERENCES
6.1 Training and Ecucatien Departroent Trainirg System Develcpment Process, 6200-ACH-2682.01 6.2 Technical Centent Review and Interface Prccess, 620C tCM-2682.03. 6.3 Evaluatiro Trainirc Precrams, Cerald L. Kirketrick, vacisen, Wiscensin: American Scciety cf Training and Dewiccmer.,1975.
7.0 ATTACHENTS
7.1 Exhibit 1 - Trainee Survey 7.2 Exhibit 2 - Sucervisor Survey 1 l E l 5 l 2 i 5 1 7 I 0570G:02 6.0 ^ccc'08c ' ' 8:
c5 20 is .a di a
- 4..: :
- I
'y Exhibit 1 Rev. 1 ~ GPJ4 TRAINING AtO ECUCATICN 05/16/65 Page 1 of 3 TRAI?EE SLHV2Y Name:
Title:
Todays Cate: Dates of Training: Instructor: Nee of Trainirg Program: Method of survey: Halled questiconaire l_l In person interview l_l Telephone interview l_l Yes No 1. Have you ITceived additional trainirq since being assigned to your job? l_l l_1 l If yes, please explain: I i Yes No 2. Have Wu experienced unegeoted difficulties or problems in job perfomance? l_l l_l If yes, please i explain: l El-1 0570G:02 l l
Os 20 25 2::: a -:. 00: .:03 0 Exhibit 1 Y Rev. 1 05/16/85 Pqe2cf3 Yes No 3. Has your sucervisor given you instructions different frem these ycu learned during training? I l l l If yes, please explain: 4 Have ycu ncticed other differences between Yes Ne the training you recalved and what is expected of ycu new? l_l l_l If yea, what are they: Yes No 5. Have changes cccurred in ycur jc0 sirce you were assignec7 l l l l l If yes, nr.at warn they: 1 I l i i I If yes, how were you prepared to handle 6.hese changes 7: l El-2 0570G:02 i l l
ci 10 15 .;:I: 2 -c. Oc: O. - s Shibit 1 ..i Rev. 1 C5/16/65 ~ Page 3 cf 3 6. What tasks do you fine the easiest? 7. Which tasks do you find escocially challengirg? 8. What specific training benefited you the most? Yes 9. Have errors been ccmnitted en the jcb? l l l l i If yes, what wara they? 1
- 10. Mcw cculd training better have precared ycu fer your jet?
- 11. What suggestiens aculd you cake to imcreve training?
- 12. What additional training do ycu need for ycur jcb?
El-3 0 F4 :02 4 e
4 GPUN TRAINING AND EDUCATION SUPERVISOR'S SURVEY Exhibit 2 Employees Name:
Title:
Today's Date Dates of Training or Training Cycle Supervisor: Name of Training Program: (Requal or Initial) Method of Survey 1. Mailed Questionnaire l l 2. In-person Interview l l 3. Telephone Interview I t 4. Required Review l-1 (Requires signature of supervisor and employee) 1. What tasks is this employee best prepared to perform? I '2. What additional training has the employee received since he/she was assigned job responsibilities? 3. Is this employee able to diagnose conditions and identify alternate solutions for accomplishing a task? 4. Have you observed unexpected results from Trainingi If yes, describe those results. E2-1
5 5. Has this employee been commended or warned for unusually good or poor job performance? If yes, describe circumstances. 6. Has extra effort ~ by others been required due to personnel errors or lack of adequate training. If yes, describe in detail. 7. Has this employee's training prepared him/her to interface with and/or direct the activities of others, both within and external to their organization. If not, describe deficiencies. )x 8. Has this employee's training prepared him/her to locate, and properly use _ applicable procedures (Operating, Administrative, Maintenance, ~ Surveillance,etc.)? If not, describe circumstances.
- 9., Has this employee's tr.aini'ng prepared him/her to properly maintain the records and documentation associated with hl.s/her position.? If not, describe his/her deficiencies.
'10. Has this ' employee's training prepared him/her to properly operate and/or maintain systems and equipment under his/her cognizance. If not, describe deficiency. ~
- 11. Has this employee's training prepared him/her to be able to comply with g vernment and company regulations applicable to his/her position?
If not, describe circumstances. .e /
- 12. Which tasks require excessive time for this employee to complete?
w E2-2 t m
o ,13.1What kinds of errors has this employee conmitted indicating a lack of and/or improper training.
- 14. -Has this employee committed errors in'dicative of improper training which
. caused equipment damage or failure? If yes, describe errors in detail.
- 15. For what tasks was he/she inadequately prepared?
- 16. Has training for this individual created the need to identify additional training? If yes, describe those needs. -17. Based on your o'servations, what suggestions would you make to improve o initial or requalification training. () Supervisor's Signature Date Employee's Signature Date E2-3
ATI D2 Err 5 Proposed Attachment to Initial and Pequalification PO Training Program Descriptions Areas for Evaluation Reactor Operator: Normal Plant System / Component Operations Perform technical Specification Surve111ances IAW approved procedures. Perform Operations Surve111ances IAW approved procedures. Take log readings; sensitive to trends and out of spec readings. Perform switching and tagging. Shift turnover communications. Communication / Direction of Auxiliary Operators. Power Operations; plant manuevering. Overall plant control (e.g., Heatup, Rod position manipulations etc.). Adherence to Government and Company regulations. Routine equipment operation and monitoring. Proper response to control room alarms. Effective utilization of reference material (I.e., prints and elec. diagrams). Adherence and knowledge of Quality Control and Radiological Control procedures. Use of plant computer and CRT system. Identification of equipment problems requiring operator response. Communication and knowledge of system (Met-Ed) dispatching. Knowledge and adherence to NPDES permit. Maintenance of Control Room Operator Log book. Knowledge and use of plant procedures. Knowledge / Adherence /Use of Administrative procedures. Maintenance of shift records. Use of communications equipment.
,' l ATIACDIE!E 6 Proposed Attachment to Initial and Pecualification SPO Training Prccram Descriptions Areas for Evaluation Senior Reactor Operator: flormal Plant System / Component Operation Proper control of ESAS and EFW systems (e.g., Redundancy, Removing from service, Returning to service and Testing). Adherence to Technical Specification including actions when Lco exceeded. Adherence to Government and Company regulation. Directions of trends and out of spec readings during log review. Crew turnover briefings. Coordination of support personnel / groups. Prioritization of work / evolutions Implementation of the Switching and' Tagging procedures. Power Operations plant maneuvering Overall plant control (e. change coordination etc.)g., Heatup, rod position manipulation, load Supervision of equipment operation. Proper response to control room alarms. Effective Utilization of reference material. Implementation, adherence and knowledge of Quality Control and Radiological Control Procedures. Use of plant computer and CRT system. Identification of equipment problems and determination of required response or maintenance. Maintenance of knowledge and qualification of system.(Met-Ed) switching and tagging. Communication, knowledge and implementation of system dispatching requirements. Knowledge and adherence to fiPDES permits. Maintenance of shift foremen log book. Knowledge, use and coordination of plant procedures.
0 Knowledge / Adherence /Use of Administrative procedures. Use of communication equipment. Control of plant chemistry. Conduct of audits to insure compifance with company administrative procedures. Overall knowledge of plant status and integrated system operation. Determination of the requirement and content of pre-evolution briefings. Insurance that proper shift manning is maintained. Recommend Operations policy / procedural changes. - On-the-job performance evaluation of personnel. 1
}.. AITACINENT 7 1 Proposed Change to THI-1 Replacement Operator Training Program Description (RO) Change paragraph 7.8.1 as follows: f. Regularly scheduled participant critiques (including once on-the-job per 6200-ADM-2682.10). The completed evaluations shall be forwarded to the Manager of Plant Operations TMI-1 for review and comment. Upon completion of this phase of the review, the documents will be transmitted to the Operator Training Manager who will also review and comment as appropriate. The documents will then be transmitted to the Supervisor of Licensed Operator Training who will prepare a summary report of all of the observations and recommendations made by the supervisory personnel. When the report is complete the Supervisor Licensed Operator Training, Operator Training Manager, and Manager of Plant Operations THI-1 will meet to review the scope of the sunnary report and determine an appropriate course of action for each of the reconnendations. The meeting shall be conducted consistent with the TSD Procedure, 6200-ADM-2682.03, " Technical Content Review & Interface Process". 'Ihe operator Training Manager shall be responsible for the implenentation of corrective actions for the training program. g. Supervisory performance evaluation once on-the-job. The supervisory performance evaluation once on-the-job shall be conducted approximately six months after the candidates have received their licenses utilizing Exhibit 2 of 6200-ADM-2682.10 to evaluate training-related performance in these areas listed in Appendix C of 6211-ADM-2611.01. Other performance evaluations conducted on-the-job shall be conducted as part of the requalification training program (section 7.3.5). l j - Change paragraph 7.7.1 to read: At the conclusion of each phase of training and once on-the-job for approximately six months.... Procosed Change to THI-1 Senior Reactor Operator Training Program Descriptien (SPD) Change 7.9.1. to read: At the conclusion of each phase of training and once on-the-job for approximately six months..... l t
i J
- O Change 7.6.1 to read as follows:
f. Regularly scheduled participants critiques (including once on-the-job per 6200-ADM-2682.10) The completed evaluations shall be forwarded to the Manager of Plant Operations TMI-1 for review and coment. Upon completion of this phase of the review, the documents will be transmitted to the Operator Training Manager who will also review and comment as appropriate. The documents will then be transmitted to the Supervisor of Licensed Operator Training who will prepare a summary report of all of the observations and recomendations made by the supervisory personnel. When the report is complete the Supervisor Licensed Operator Training, Operator Training Manager, and Manager of Plant Operations TMI-1 will meet to review the scope of the sumary report and determine an appropriate course of action for each of the recommendations. The meeting shall be conducted consistent with the TSD Procedure, 6200-ADM-2682.03, " Technical Content Review & Interface Process". 'Ite Operator Training Manager shall be responsible for the inplementation of corrective actions for the training program, h. Supervisory performance evaluation once on-the-job. The supervisory performance evaluation once on-the-job shall be conducted approximately six months after the candidates have received their licenses utilizing Exhibit 2 of 6200-ADM-2682.10 to evaluate training-related performance in areas listed in Appendix C of 6211-ADM-2611.01. Other performance evaluations conducted on-the-job shall be conducted as part of the requalification training program (section 7.3.5) Prooosed Change to Licensed Operator Requalification Training Program Description Change second paragraph of section 7.3.5, Skills Evaluation System, to read: Evaluation of licensed personnel job performance shall be utilized to relate job performance to requalification training. It may also indicate that changes to the respective initial training programs are necessary. The Manager, Plant Operations shall provide the Supervisor, Licensed Operator Training or the Ooerator Training Manager with periodic observations identifying job performance results related to requalification. The completed evaluations shall be forwarded to the Manager of Plant Operations TMI-I for review and coment. Upon completion of this phase of the review, the documents will be transmitted to the Operator Training Manager who will also review and comment as appropriate.
s.. l The documents will then be transmitted to the Supervisor of Licensed Operator Training who will prepare a summary report of all of the observations and recommendations made by the supervisory personnel. When the report is complete the Supervisor Licensed Operator Training, Operator Training Manager, and Manager of Plant Operations THI-1 will meet to review the scope of the summary report and determine an appropriate course of action for each of the recommendations. The meeting shall be conducted consistent with the TSD Procedure, 6200-ADM-2682.03, " Technical Content Review & Interface Process". The operator Training Manager shall be respansible for the inplenentation of corrective actions for the training program. Each licensed individual's performance shall be evaluated during the following situations: 1) Annually during Nuclear Plant simulator exercises (including applicable Basic Principles Trainer Simulator (BPTS) exercises) 2) Plant Drills 3) Annually, on-the-job 4) During actual abnormal / emergency conditions Performance evaluations during simulator exercises and plant drills shall be conducted by the Manager, Plant Operations or his designee utilizing the format of Appendix 8. The on-the-job evaluation shall be conducted by supervisory personnel utilizing Exhibit 2 of 6200-ADM-2682.10 to evaluate training-related performance in these areas listed in Appendix C. The evaluations related to performance during actual abnormal or emergency conditions shall be conducted on a case by case basis, utilizing AP 1044 as guidance. i 4
~ ' g gf Training and Educatic l6200-ADM-2632.03 Progra= Dsvalop=snt Manual Tiue Revision No. GPU Nuclear - Technical Content Review & Interface Process 0-00 Apolicaoshty; Scope Responsicie Office " C 8 All Training & Education Depart =ent Personnel y This document is important to safety KYes c No Effective Date Ust of Effective Pages PAGE REVISION 1.0 0-00 2.0 0-00 3.0 0-00 4.0 0-00 Signature Concurnng Organizational Element Date Onginator [h)g l Educational Development Coord. 3/jf/fg Concurred c(M M / h [ f-L fanager Corporate Training G. //. f;3" l' p ppg l Manager Plant Training - OC lg //g/ pf l Manager Plant Training - TMI l Sj/g g;- pfg,,jg l / I l l l l l l I I l I I l l I i i I l Approved oy l d _ h> -- h Manager Educational Development l 3 11-d[ 8; [k Director Training & Education lJ -/A-$ l [ AOoO10$1 3 1.0 I
se:r~ 1 Training anc Ecacaticn Ccc:. P U1Nu,Jiear gregram Ocve1ccment anca1 pcc.o_2m. a e, Title Eevissor1 No Tecnnical Content Review And Interface Process 0-00 1.0 P'ursese 1.1 ine purpose of tnis proceoure is to estaclish a process for the tecnnica_ content review of training materials and assure an ongoing interface between the Training Department and the user groups. 2.0 Applicacility and Scope: 2.1 This procedure has CPUNC wide applicability.
3.0 Definitiens
3.1 User Department - That cepartment responsiale for the perscnnel ceing trainec.
4.0 Precedure
4.1 Each site training section shall establish a technical content review mechanism for eacn functional organization on site that is supports. 4.1.1 The interface group shall be made up of key personnel in tne Training Department and tne user group. 4.1.2 The Training Cesartment and functional organizaticns shall provide qualified personnel to serve in the group; inclucing Technical Functions, Rad Con / Environmental Control, and Emergency Planning as appropriate in the review anc approval process. 4.1.3 Otr.er interested personnel may be invited to participate in or observe the process. 4.2 Pur;cse of content review process 4.2.1 Verify the need for instruction cy: - Reviewing task analysis - Assessing training needs resulting from job performance cf 9 programs' graduates. 2 - Identifying current and emerging neecs (technology, Jco sccce, 8 etc.) i _E ac:: :s: e: 1591c 2.0
Nemes-p ' Prcnram 0;vcicpment ManualTraining and Ecucation CO::t. gv 4 7
- 6200-ACM-2652. 3
/ Tive Revision NO Technical-Content Review And Interface Process 0-C0 n - Reviewing needs analysis - Interpreting new developments in the fiela - Supporting, when required, Training Department budget reques: 4.2.2 verify content of the course by: - Selecting tasks for training - Determining where in the program the task should be taugnt, (Classroom, OJT, simulator, etc.) - Reviewing training and performance standarcs. 4.2.3 Provice Service to the Training Department anc User Groucs by: - Assisting with long-range planning - Serving as speakers to management if neecec. - Develeping/ reviewing anc recommencing to management the screening stancards for trainees applying for acmission into the training program. - Assisting with the development of the on-tne-joo related instruction. - Advising on programs to meet the neecs of special trainees. - Evaluating the instructional programs. Refer to procecure - Program Evaluation For Process, 6200-ACM-2682.ll; anc Course Evaluation, 6200-ADM-2682.12. 4.3 Each group shall determine the frequency of its meetings. Nothing in tnis procecure is meant to aiscourage the frequent individual activities anc interfaces between training and the user organizations. The company recognizes that these are vital to the proper develcpment and implementation of high quality training programs. 4.4 when apprcpriate, a written agenda should be prepared prior to the meeting. R I E i A0001C50 t t f 1591b 3.0
ENucioer erogram Devs o, ment M nu,1 6 .. 2482.03 r.en W ho-Technical Content Review And Interface Process 0 4.5 Minutes shall be kept and distributed to appropriate personnel to incluce the Manager of Site Training. 5.0 Responsibilities 5.1 Director, Training and Education is responsible for maintaining this procedure and for assuring adherence to its requirments. 5.2 Manager, Educational Development is responsible for developing and updating this procedure and for assisting the Plant and Corporate Training Department in its implementation. 5.3 Division Directors are responsible for implementing this procedure and for complying with its requirements. 6.0 References 6.1 Training and Education Department Training System Development Process, 6200 ADM-2682.01. 6.2 Program Evaluation For Process, 6200-ADM-2682.11. 6.3 Course Evaluation, 6200-AOM-2682.12. 7.0 Attactnents NONE O e 5 ~ ~ 0 2 I i I 1591b 4.0
p j g,j ggggg g, 62CO-AC"-26?2.01 r %. a m..... c..c. I-I ritie Training & Education Department Training'5ystem nevision No Development Process 0 -00 ' ApohcaedstyiScope Responsiole Office All Training & Education Department Personnel Educational Cevelocrent s TNs document is ernportant to sofety o YeeONo Effective Date Paces Revision
- Paces Revision 1.0 ll 0-00 E4-1 0-00 2.0 0-00 E4-2 0-00 3.0 0-00 4.0 0-00 5.0 0-00 6.0 0-00 7.0 0-00 Proposed changes are 8.0 0-00 highlighted with lj 9.0 0-00 double bar indication 10.0 ll 0-00 in right margin 11.0 0-00 12.0 0-00 13.0 0-00 14.0 0-00 15.0 0-00 16.0 0-00 17.0 0-00 18.D 0-00 19.0 0-00 i
El -1 0-00 E2-1 0 00 E3-1 0-00 Senature Concumng Crganizational Element Date ! 0"9'nator llM k h-Manacer, Educational Develocrent 3-M. ss' !concurredbh f]M/MM,&. Manacer, Corporate Training (JJCg[ I N //M N.b 4 M w Manacer, Plant Training - OC '3,.25. P(
- '/l eM Manager, Plant Training - TPI i f a _c,.
/ I i l i l ? I l e I h A A l l ,w !! ^DD' d D M ([o Director, Training & Education Jgg 7 l 1.0 dooo'c5' 2-l 1
Nuclear YRAINING & EDUCATION DEPARTMENT PROGRAM DEVELOPMENT MANUAL 6200-ADM-2682 rice TSO PROCESS Revision No. 0-00 s TABLE OF CONTENTS PAGE 1.0 PURPOSE 4.0 2.0 APPLICABILITY / SCOPE 4.0 3.0 DEFINITIONS 4.0 3.1 TSD Process 4.0
- 3. 2 User Groups 5.0
- 3. 3 Needs Analysis 5.0 3.4 Job Analysis 5.0 3.5 Task Analysis 5.0 3.6 Training Analysis 6.0 3.7 Training Standard 7.0 3.8 Program Descriptions 7.0 3.9 Lessoa Plans 8.0 3.10 Trainee Text Material 8.0 3.11 Evaluation 8.0 3.11.1 Evaluation during Development 8.0 3.11.2 Pilot Evaluation 9.0 3.11.3 Trainee Evaluation (while in training) 9.0 3.11.4 Instructor Evaluation 9.0 3.11.5 Trainee Eval' ation Back On The Job 9.0 u
3.11.6 Program Evaluation 10.0 3.11.7 Course Evaluation 10.0 3.12 Training Advisory Council 10.0 3.13 Technical Content Review and Interface Process 11.0 i l 3.14 On-the-Job Training (0JT) 11.0 4.0 PROCEDURE 11.0 4.1 Training Advisory Council 11.0 4.2 Technical Content Review and Interface 12.0 l
- 4. 3 Needs Analysis 12.0 I
4.3.1 Request for Training 12.0 4.3.2 Program Development Team / Project Coordinator 12.0 4.3.3 TSD Process for New Programs 13.0 ~ 4.3.4 Process for Revising Existing Programs 13.0 i= A00C tCSO t 2.0 05431
NuedUimldE"E 9tOSY^"m e20 m s.2e62 TRAIN 8NG & EDUCATION DEPARTMENT N"mcer { T.u. TSD PROCESS R>sion No o 0-00 TABLE OF CONTENTS (Continued) m Page 4.4 Job and Task Analysis (JTA) 13.0 4.4.1 JTA for Job Position Training 13.0 4.4.2 Analysis for the Specialty Course 14.0 4.4.3 Planning and Organizing for Development 14.0 4.4.4 Program Development File 14.0 4.5 Training Standards 14.0 4.5.1 Review / Approval of Training Standard 14.0 4.5.2 Training Standards & INPO Accreditation 15.0 4.6 Program Description 15.0 4.7 Instructional Process 15.0 4.8 Lesson Plans 15.0 4.8.1 Yariation in Lesson Plan Formats 15.0 4.8.2 Lesson Plan Guideline 16.0 l 4.9 Matching Training Materials to Objectives 16.0 4.9.1 Matching Existing Materials 16.0 4.9.2 Revision of Existing Materials 16.0 4.9.3 Preparation of Trainee Texts Guideline 16.0 4.10 Trainee Examinations 16.0 4.11 Pilot Sessions for New Courses / Programs 16.0 4.12 Student Evaluation While in Training 17.0 4.13 Evaluation of Trainee Back on the Job 17.0 4.14 Instructor Evaluation 17.0 4.15 Formal Program Evaluation 17.0 4.16 Course Evaluation 17.0 4.17 OJT 17.0 I j 5.0 RESPONSIBILITIES 17.0 1 5.1 Director, Training and Education 17.0 5.2 Manager, Educational Development 18.0 5.3 Managers, Plant and Corporate Training 18.0 5.4 User Groups 18.0
6.0 REFERENCES
19.0 l 7.0 ATTACHMENTS 19.0 n l 5 5 2
- Ii 2
l 5 I AOCC10$ 3.0 054 % l
ErEjNugiparg' ggjgggggNT humcy " ~ ' ' ' g R;vesion No TSD PROCESS 0-00 ( l.0 PURPOSE The purpose of this procedure is to establish and describe the process used for developing training programs by the GPU Nuclear Corporation's Training and Education Department and for specified programs developed the department by vendors. 2.0 APPLICABILITY / SCOPE 2.1 This procedure applies to all persons assigned to the GPU Nuclear Training and Education Department. It is recomended that training programs developed by other GPU Nuclear divisions follow this process. 2.2 Documents published prior to the effective date of this procedure shall be brought into compliance with the TSD process at such time as the program is required to be submitted to INPO for accreditation. 2.3 The Director of Training and Education may exempt a particular program, or course (s) within a given program, from being developed in accordance with the TSD process. 3.0 DEFINITIONS i 3.1 Training System Development (TSD) process is the systematic approach to program development. It is a step-by-step approach to training program development which incorporates the specialized techniques of modern instuctional technology. See Exhibit 1, TSD Process. Exhibit 2 shows GPU Nuclear's TSD Model. Exhibit 3 shows the full g program development process which makes up TSD. Exhibit 4 shows the organization of the procedures and guidelines of the TSD process. ? I 3l '41 I= A00010501' 4.0 0549G
ypd,R0y'""'y'Vp,"0g"ipHUAL I '"^^'"E*7 ' ' ~ " ~ ' Nc 6200-AcM 25E g no TSO PROCESS g "'*" n* 0-00 ,The steps in this overall process and thisir le ations in the procedure are: Paragraph
- 4. 1 Training advisory council 4.1
- 4. 2 Technical content review and interface 4.2
- 4. 3 Request for Training (needs analysis)
- 4. 3 l
- 4. 4 Job and task analysis 4.4 2
- 4. 5 Training analysis 4.5
- 4. 6 Training standards 4.6
- 4. 7 Program description 4.7 I
- 4. 8 Instructional process 4.8
- 4. 9 Lesson Plans 4.9 I
4.10 Trainee text materials 4.10 I 4.11 Trainee examinations 4.11 4.11-4.16 Evaluation 4.11-4.16 I 3.2 User department / group - that department which utilizes the services of the Training and Education Department to train its personnel. i l l l I These steps are covered by separate guidelines which can be found in the Program Development Manual. The other steps are covered by separate procedures. g 2 Training analysis is treated broadly in the Task Analysis and Training l f Standard Guidelines. 1 7' = i ACC01CSC-5.0 0549G l
l Num eir ~ L A 6200-ADM-2682. Tc T50 PROCESS 0 0') '
- 3. 3 4eeds analysis - The needs analysis is a process which reviews job performance problems and/or cosmitments to assess the relative urgency of developing or revising training programs.
It also assigns program development priorities. The development of a comprehensive curriculum for all jobs cannot be undertaken simultaneously within reasonable resource 1imits. Therefore, it is necessary to make a comparative assessment of the needs for new and revised programs. 3.2.1 The GPUN Training Policy and Training Plan both address the needs analysis process in relationship to the issues of l personnel performance. i 3.2.2 Needs analysis is generally initiated through completing a Request for Training Form. l 3.4 Job analysis is the process of evaluating data regarding the tasks i and conditions of a job. It provides an objective-data base of job-I related information from which training programs are developed, based upon how the job is'actually performed. t i 3.5 Task analysis is the process which examines individual tasks to l determine the required steps (generally called action steps), cues, and skills. It also involves evaluating tasks on the basis of task importance factors such as: task performance and task knowledge levels, mental and physical difficulty, operational and safety l related importance, frequency of performance, and the relative z[ number of job incumbents who perform the task. Task analysis data 3 are then evaluated to decide which tasks must be included in the j f initial and/or ongoing training programs. This last step is jj generally considered to be a part of task analysis. l 1 9 l 1= A0001050tt 6.0 0549G 1
- wme, 1
UA 6200-Arw. m Revision No TSD PROCESS 0-00 3.6 Mraining analysis is the process that takes the results of task analysis and determines which tasks, skills, and knowledge require actual training. It is also the process where each task and its action steps are analyzed to determine what knowledge is required by the trainee in order to safely and effectively perform that task. Many tasks in a job are so simple or routine that formal training is not needed. Other tasks are so complex, or the importance of proper performance is so high, that formal training is needed. 3.7 A training standard is a document which lists all the training requirements as behavioral objectives for each job position or specialty course. The training standard is approved by the user group in conjunction with the Manager of Site Training. The collection of all the individual training standards for each progran forms the complete Corporate Training Standard document. The training standard may be either a generic document or a generic witt site-speci fic appendices. 3.8 Program descriptions provide important need-to-know information to i the instructor as well as anyone else with a special interest in the l course. It is divided into several sections and typically includes I the following: Table of Contents, Introduction, Program Structure, Instructor Training Qualification Information, Program Prerequisites, Trainee Attendance And Evaluation Requirements, Training Documentation, Training Schedule, Program Maintenance, and Program / Course Preparation Checklists or Procedures. 5 2 f, 5 1.a' i ACCC105 7.0 0549G
Numes UA 6200-ADM-2682J M' TSD PROCESS 0 00 3.9 tesson Plans are teaching guides which are composed of the terminal and major enabling objectives, a semi-narrative or outline format, and the Instructor's activities. Lesson Plans should contain a concise sumary of the essential information to be presented to the trainee. 3.10 Trainee text materials include: trainee texts, trainee workbooks or laboratory manuals, and reference materials. In a broader sense it may be necessary in the course of developing texts to also develop slides, transparencies, audio or video tapes. 3.11 Evaluation is the process of analyzing information about the program / course, instructor, and trainee which enables the Training Department to make decisions to improve the quality and effectiveness of the training. There are several levels of evaluation: I 3.11.1 Evaluation during development - The first phase of program evaluation is conducted during the development i of a new training program. This phase provides a i quality control function to ensure that each program document er component is at an adequate level of quality to assure the success of the overall development process. Two illustrations of this type of evaluation are: review comittee assessments and completion of Lesson Plan checklists. A i I_ I 5 5l li E l 9 { 5 a" ACCCtC50** 8.0 0549G
D Nuc, lea [ cpGpEppspNux 622-a -2 m TRAINING & EDUCATION DEPARiFENT I N ' ~' " ' ' ' * " " * ~ ~ u. TS7P'ddE3 T, 0-00 , 3.11.2 Pilot evaluation - The second phase evaluates a " pilot" session of a newly developed training program given to a sample of typical trainees. This trial run determines the ability of the program to bring trainees to mastery of the objectives and identifies any adjustments neeced in content, structure, or sequence. In those cases where a tradition pilot cannot be run, a careful
- .C.n e should be made of the first offering.
3.11.3 Trainee evaluation (while in training). The third phase of evaluation focuses on the trainee's performance while in training. This evaluation ensures that periodic reviews are made and reported. Feedback is provided to all critically involved training personnel to include the trainee and the line supervisor. 3.11.4 Instructor evaluation is the fourth phase of evaluation. It focuses on the instructor's performance as it affects instruction. This evaluation identifies the strengths and weaknesses of the instructing staff. 3.11.5 Trainee on the job evaluation is the fifth phase of l evaluation. It focuses on tne capability of the former l trainee to perform on the job. The evaluation determines whether the training is relevant to the actual job and whether the trainee is capable of l required performance after training. 4 5 5 a 2 0 1 l 4 8 1 ACC0f0$ 9.0 0549G l L
EJWNuclear, e-mem.m ~ - - mn t enpaCGa DEvEt0e E~T # uuet 62CO.4 2ea2- - e, o nm ic TSD W is5' M# I 0-00 3.11.6 Program evaluation is the sixth phase of the evaluation. It is the responsibility of both the Training and Education Department and User Group Management to assure that the programs remain in step with the latest procedures, technology, and regulations. The results of these job perfer=cc-cricated evaluations are fed back to the responsible personnel for planning of program revisions. 3.11.7 Course evaluation is another phase of evaluation. There are situations where small courses such as GET or First i Aid training will need to be evaluated. The formal I program evaluation instrument is designed for the evaluation of large training programs and is not appropriate for the evaluation of these small independent courses. Need may also exist to evaluate l only a course within a larger training program. The course evaluation process is a simplified version of the formal program evaluation process. Course evaluation f has been designed to increase the evaluation options available to the Training and Education Department. 3.12 Training Advisory Council is a select group of individuals primarily from outside of the Training and Education Department. They are I selected from segments of the GPU Nuclear Corporation collectively to ad. vise the Director of Training and Education. This advice i centers on broad matters pertaining to the improvement of training !l programs. 2 U l 5 5 i 4::: :s: - 10.0 0549G
~~., Nuch ac,,8N8NG & EDUCAT!0N DEPARTMENT TRA 0,R m qrte p r v,Nu,e 6200-,cs-zee 2. Revissori No Titl* TSD PROCESS 0-00 3.13 Wechnical content review process is a quality control function set up within each site training organization to ensure the validity of the technical content of a course or program. All major technical training programs shall be reviewed by a technical content review process. The review process will involve key personnel from the Training Department, the plant, and/or support divisions as appropriate. 3,14 On-the-Job Training (0JT) - OJT is an integral part of the overall training process. OJT is a formalized process of training which is I systematically derived from Job / Task and training needs analysis f utilizing the Training Systems Development (TSD) approach to training. This process also utilizes the approved job description / specification that is developed by the Human Resources Department and the applicabl,e user department (s). OJT is that training which is best learned (from an instructional standpoint) by the trainee on the job and focuses on application, integration, and motor skills. It provides a smooth transition for the trainee from i the classroom environment into the workplace by providing an opportunity to apply previously learned skills and knowledges and to l acquire new job skills and knowledge while actually working under controlled conditions. It provides an opportunity for the trainee I to benefit from the extensive background and experience which is held by the job supervisors in a formal, structured manner, i j 3.15 Guideline - a document which provides information for general consideration in performing a task. It is n_oj intended to establisn requirements. \\ T. 4.0 PROCEDURE 4.1 A Training Advisory Council shall be established in accordance witn l 6200-ADM-2682.02, Training Advisory Council Procedure. I A0001 Cl[' ' l 11.0 0549G
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Tio TS&H0C'I$5' ' 0-00 i 4.2 Within each site training organization or each major training program, a technical content review and interface process shall be established in accordance with 6200-ADM-2682.03, Technical Content Review And Interface Process Procedure.
- 4. 3 Periodically, individuals from the field, as well as within the training organization, recognize performance problems for which training may be a possible :olutf or,.
Or, corporate comitments, outside regulatory requirements, etc., might be initiated that may have an impact on new or existing training p.aograms. These observations /comitments can be brought to the attention of those individuals within the training or Human Resource functions who have t'he responsibility to evaluate their significance and respond accordingly. 4.3.1 If it is determined that there is a performance problem, comitment, et.c., then training needs analysis shall be performed in accordance with 6200-ADM-2682.04, Request for Training. j I 4.3.2 If the Manager of Site Training determines that the problem /comitment is found to be a major training need, i j requiring either a new course / program or significant l r..odification to an existing one, then a program development team is formed in cooperation with the Educational Development section. He should appoint a member of his staff to become Project Coordinator. Under certain circumstances the Project 3 Coordinator may be appointed from the Educational Department _j section. (The term project coordinator is used in this E 5 3' E! I 5 .:cc o u - 12.0 0549G
43, .A 6200-Anw-2 m _ Tiue TSD PROCESS p 0-00 procedure as a descriptive title since this individual's actual title may vary according to that person's position within the organization). 4.3.3 If no training program or course exists to address this problem and training has been identified as the root cause for the problem, then a new training program or course should be developed in accordance with the TSD Process outlined in this procedure. f 4.3.4 If a program or course currently exists but is found not to be effective, then modification (s) shall be made to the l appropriate documents (task analysis, training standard, lesson plans, trainee text materials and examinations) to I correct the concern. j 4.4 The Project Coordinator shall ensure that the first step in the development process is to conduct an analysis of what is required. Most programs that will be developed will fall into two categories: programs for training an individual for a job position or a specialty course or program like GET. The Project Coordinator in conjunction with the Manager, Educational Development er the Educational Development Coordinator shall decide in which category the program belongs and choose one of the following options: I 4.4.1 If the needed program is for qualifying an individual a job position then a JOB and TASK ANALYSIS shall be performed. The job and task analysis shall be done in accordance with the Task Analysis Guideline found in the TSD Program Development f Manual. Il a i I. ir A00010SO ' 13.0 0549G
LI yl iaAlkME & LUUL/RION DEPARTMENT gMcGRE g4VF,10)lMgyNUAL 6200-AIM-2682. v Vi1lf IVW-fr. U V VI [ . Revision No T* TSD PROCESS 0-00 d.4.2 If it is a specialty training course, then reference documents governing the skills or functions shall be identified. These shall be researched to enable the program developers to locate potential training requirements. 4.4.3 The Project Coordinator should ensure that a time line/ action plan is completed at the start of the development work. This time line/ action plan will: identify the critical program development steps that must be accomplished to develop the course or program, the estimated time for each step to be completed and identify the person (s) who is (are) responsible for completing each step. This planning shall include which materials must be reviewed by the technical content review process described in 6200-ADM-2682.03, Technical Content Review And Interface Process Procedure. l 4.4.4 The Project Coordinator shall create a development file for keeping all important documents pertaining to the development of this program. l 4.5 The Project Coordinator shall ensure that identified training requirements are included in a training standard for the course or program in accordance with 6200-ADM-2682.05, Training Standard procedure. Further guidance can be found in the Training Standard Format and Guideline found in the TSD Program Development Manual. 4.5.1 The Project Coordinator shall submit the completed training standard to the appropriate individual (s) for review and/or [ approval. c 2 U t I! i:: 1. ACCC1:50 ' 14.0 0549G
g-pl TRAINXNG & EDUCAYION DEPARTMENT 7, c. t, M M03RErREVE.1.QA!$pNUAL ~ 6200-ACM.2632 v M 1 i FM k_LJ WI l R;wsion N2 M' 750 PROCESS 0-00 ,4.5.2 A training program may be submitted for INPO Accreditation before and separate training standard document is developed,. if Training Control Record forms (TCR) exist for all lessons that are taught. A training standard shall be developed pricr to the second submittal of the program for accreditation. 4.6 The Proje:t Coordinator shall ensure that Program Descriptions are developed in accordance with 6200..ADM-2682.06, Program Description Procedure. 4.7 Instructors shculd be familiar with the best instructional processes to prepare for the wide variety of learner attributes, styles, and l training situations. Before Lesson Plans and trainee text materials are developed, the program development team should review the materials in the Instructional Process Guideline found in the TSD ( Program Development Manual (the material in this guideline is taught i in both tne Basic Instructor Course and in appropriate Advanced Instructor Training Modules). l 4.8 Lesson glans shall be written for all lessons and/or t' raining I l modules that are taught. These lesson plans shall be written in accordance with the preferred format described in 6200-ADM-2682.07, Lesson Plan Procedure. The two column lesson plan is the preferred i format for the Training and Education Department's lesson plans. 4.8;l Any use of other lesson plan formats shall first be approved by the Manager of Site Training. yl E 2 3 5 4! E' 2 i ~ 4::: :s: 15.0 05493
kmw ENugleA,,%,,TgggyAggEsT . = _- p-j,g g - Title TSD PROCESS 0-00 4.8.2 For more quidance in writing lesson plans, instructors shoul t i refer' to the Lesson Plan Format and Guideline found in tho 150 Program Development Manual. 4.9 Trainee materials and training materials shall be developed to match the course objectives and lesson plans. 4.9.1 As a part of program review and evaluations, existing materials or lesson plans should be reviewed to ensure that they do indeed match the objectives. 4.9.2 If it is found that the existing materials 'o not adequately d meet the course and lesson objectives, then these materials shall be modified to bring them into conformance, i 4.9.3 Trainee text materials shall be developed in accordance with the Guidelines for the Preparation of Trainee Texts in the TSD Program Development Manual. 4.10 Trainee examinations may be either written, oral or performance or any combination thereof. The construction of these evaluation instruments, processes, or test question bank items shall be developed in accordance with the Guideline For Examination Construction found in the TSD Program Development Manual. 4.11 Newly developed programs or courses should be evaluated via a pilot g session or at the very least when the program or course is offerec to trainees for the first time. This evaluation will be done in accordance with 6200-ADM-2682.08, Pilot Session [or First-Time Offering] Implementation - Evaluation Process. i A000tC5;* 16.0 0549G
g TRAINING & EDUCATION DEPARTMENT as .,,,i p'c PgofaMywxANuAt 6200-Acs-2eaa. ~ ~ R:viscn N3. 7'* TSD PROCESS ^ 0-00 4.12 4tudent evaluation shall be done for the student on his/her training R performance while he/she is in training accordance with 6200-ADM-2682.09, Student Performance Evaluation Procedure. The frequency of these evaluations is determined by the Manager of Site Training for particular programs / courses. 4.13 Evaluation of the trainee after he or she has returned to the job after completing training shall be done in accordance with 6200-ADM-2682.10, Evaluation of the Trainee Back on the Job Procedure. l l-4.14 Instructor evaluations shall be conducted in accordance with 6200-ADM-2607.01, Instructor Evaluation Procedure. 4.15 Formal program evaluation shall be accomplished using the Technical Review Process and the GPU Nuclear Program Evaluation Instrument. This shall be done in accordance with procedures 6200-ADM-2682.03, Technical Content Review and Interface Process; 6200-ADM-2682.ll, i GPU Nuclear Program Evaluation For Process. l l 4.16 Small courses that require periodic evaluation should be evaluated l in accordance with 6200-ADM-2682.12, Course Evaluation. 4.17 The development and implementation of On-The-Job Training shall be done in accordance with 6200-ADM-2605.02, On-the-Job Training. i 5.0 RESPONSIBILITIES t ~ 5.1 Director, Training and Education is responsible for approving this ea procedure and for assuring adherence to its requirements, b 9 5 ACCOt CSC 1 17.0 0549G
Ny m otr gg TRAINING & EDUCATION DEPARTMENT (TQ(M00R$@iVW4NUAL 6200-ADM-2682 ' q, I'* ,;,,,c, y, TSD PROCESS 0-c0 5.2
- Manager, E'ducational Development is responsible for developing and updating this procedure and for assisting the Plant and Corporate Training Departments in its implementation.
5.3 Managers, Plant and Corporate Training, are responsible for implementing this procedure and for complying with its requirements.
- 5. 4 User groups are responsible for providing manpower and other appropriate resources for conducting task analysis and training analysis. They are also responsible for reviewing and approving appropriate training documents as specified in each program's Program Description.
6.0 REFERENCES
6.1 GPU Nuclear Corporation's Training Policy 6.2 GPU Nuclear Corporation's Training Plan 6.3 Training & Education Department's TSD Program Development Manual i 6.4 Training Advisory Council, 6200-ADM-2682.02 k 6.5 Technical Content Review Process, 6200-ADM-2682.03 6.6 Request for Training, 6200-ADM-2682.04 6.7 Training Standard, 6200-ADM-2682.05 l 6.8 Program Description, 6200-ADM-2682.06 l l 6.9 Lesson Plans, 6200-ADM-2682.07 6.10 Pilot Evaluation, 6200-ADM-2682.08 6.11 Instructor Evaluation, 6200-ADM-2607.01 6.12 Student Performance Evaluation, 6200-ADM-2682.09 6.13 Evaluation of the Trainee Back on the Job, 6200-ADM-2682.10 s 6.14 Program Evaluation for Process, 6200-ADM-2682.11 5 6.15 Course Evaluation, 6200-ADM-2682.12 i l
- j; 6.16 On-the-Job Training, 6200-ADM-2605.02
\\ T l 5: E 5 ACCQlCSC l 18.0 0549G
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