ML20128F358

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Forwards Licensee Proposed Evaluation Plan for Satisfying Board long-term Requirement to Institute Procedure for Evaluating Performance of Trained Operators in Job Setting After Training for Rev to Training Program.W/Svc List
ML20128F358
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/28/1985
From: Bauser D
SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Bradford L, Jordan W, Wagner M
HARMON & WEISS, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD), THREE MILE ISLAND ALERT
References
CON-#285-163 SP, NUDOCS 8505290625
Download: ML20128F358 (150)


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. A m. - .A waiver S oiRECT oiA6 NvMaER May 28, 1985 (202) 822-1215 MEMORANDUM TO: Mary Wagner, Esq.

OELD William Jordan, Esq.

Harmon & Weiss Ms. Louise Bradford TMIA Thomas Au Commonwealth of Pennsylvania FROM: Deborah B. Bauser Enclosed is Licensee's proposed plan for satisfying the Licensing Board's long-term requirement that Licensee in-stitute a procedure for evaluating after training the perfor-mance of its trained operators in the job setting for revision of the training program. Consistent with the Board's Order, Licensee would like to discuss with each of you your comments on the proposed plan prior to its formal submittal to the Board. I will be calling you within the next week to arrange such a discussion.

cc (w/ enc.): Service List 8505290625 850528 PDR ADOCK 05000289 O h

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q UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart Remand (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 J. Edles James K. Asselstine, Commissioner Chairman, Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Appeal Board 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 I Chairman, 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 l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 l

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1 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 d

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.. May 28, 1985

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'SYRf PROPOSED EVALUATION PLAN

1. INTRODUCTION CFT(CE OF SECREDm v 00CdE7;NG & SEFw ~

On'May 3, 1985, the Atomic Safety & Licensing Boar $3fs' sued"'

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-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 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, l 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 peraonnel. This pro-cedure and the existing TMI-1 plant procedure for evalua-tion of abnormal events (AP-1044, entitled " Event Review

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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-l 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 I

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, i

4/15/85, along with the licensed operator training

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Rev. O, 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 l

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.

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3. DESCRIPTION OF EVALUATION PROCESS l

The formal mechanism used to evaluate TMI-1 licensed oper-

x 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 evaluation 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, l

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" 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-dure is provided as Attachment 1. The procedure (S 4.1.1.2)

I specifically includes requirements to identify any unexpected j or abnormal response to a transient by plant personnel and to I

review the records of operator actions and plant activities af-fecting an event (SS 4.1.2 and 4.7.1.1.7). The " Transient Assessment Report" (Exhibit 5 of the procedure) includes a sec-tion entitled, " Operator Action / Procedural Adequacy" which fo-cuses on operator actions taken during the transient. 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 pro-posed that a few minor revisions to Sections 4.4.2.4, 4.4.2.5, 4.7, and 4.7.1.1.7 will be made to this procedure to more clearly indicate the requirement to evaluate licensed operator response during each step of the analysis pr'ocess.

TMI Administrative Procedure AP 1044, entitled, " Event Re-view and Reporting Requirements," specifies the applicable i 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 i

2. Enclosure 7 of AP 1044, provided as Attachment 3,is the potentially reportable event form which is filled out by the

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4 shift supervisor. GPUN proposes to revise Enclostge 7 to in-cluder i - ,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.

Enclosure 7 also requires a detailed description of the event, plant status and immediate corrective actions.

TMI-l Administrative Procedure AP-1029, " Conduct of Opera-l 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 4. The' review process under AP-1029 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) !Ls* oC areas to be evaluated.

.y 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 5. Due to :.he range and variation of 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 en the job. This will ensure coverage of the breadth of on-the-job activities when the supervisor is evaluating the questions contained in Exhibit 2 of Attachment 5. These areas for evaluation will be included l.

as an attachment to each of the licensed operator training pro-gram descriptions, and are provided as Attachments 6 end 7.

Licensee also will revise the training program descriptions to include the provision for required on-the-job performance eval-untions. Attachment 8 provides the proposed language for the i proposed program description revisions.

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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-2682.10 (Attachment 5) to evaluate training related I

4 performance in the areas listed in the areas for evaluation for Ros and SROs (Attachments 6 and 7). Subsequent evaluations 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 documents will be transmitted to the Operator Training Manager who will also 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 su-pervisory personnel. When the report is complete, the Su- '

f pervisor Licensed Operator Training, Operator Training Manager, l

l and Manager of Plant Operations TMI-l will meet to review the I

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-cess," which is provided as Attachment 9. The operator tr'aining program descriptions will be modified to reflect the above described process for handling licensed operator perfor-mance evaluations.

The above-described process is consistent with the I Training Systems Development process (T&E Procedure 6200-ADM-2682-01), used by Licensee. This procedure is pro-vided as Attachment 10. Through its supporting procedures, TSD

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ensures that all proposed revisions of training are systemat-ically 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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e ATTACHMENTS

1. Technical Functions Procedure 1000-ADM-7370.04, entitled,

" Analysis of GPUN Plant Transients (Post Trip Review)"

2. TMI Administrative procedure AP 1044, entitled, " Event Review and Reporting Requirements"
3. Enclosure 7 of AP 1044
4. TMI-l Administrative Procedure AP-1029, " Conduct of Operations"
5. TSD Procedure 6200-ADM-2682.10 Trainee Evaluation Once Back On-The-Job, Rev. O, 4/15/85
6. ' Proposed Attachment to Initial and Requalification RO Training Program Descriptions
7. Proposed Attachment to Initial and Requalification SRO Training Program Descriptions
8. Proposed Change to TMI-l Operator Training Program Descriptions
9. TSD Procedure, 6200-ADM-2682.03, " Technical Content Review & Interface Process," Rev. O, 4/15/85
10. Training Systems Development (TSD) Process Procedure 6200-ADM-2682.01, " Training and Education Department Training System Development Process" Rev. O, 4/15/85

{.e, ATTACIDIST !

GPU Nuclear Corporate Policy N eer and Procedure Manual (EP-029)

ANALYSIS OF GPUN PLANT TRANSIENTS (POST TRIP REVIEW) 0 00 DRA97 /-oo

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GPUE-wide, except TMI-2 YNUO***

This document is important to safety C Yes a No Effecove Oate Uet of Effective Pagee 11/15/84 DeaM Da 22 T-2o-2 s Page Revision g Revision 1.0 0-00 E3-1 0-00 2.0 0-00 E4- 1 0-00 3.0 0-00 E4-2 0-00 g #*r# , ,g g d ,17 e 3 4.0 0-00 E4-3 5.0 0-00 E4-4 0-00 are hip 4 //f M d w/W 0-00 6.0 - 0-00 /-80 7.0 0-00 E4-5 E4-6 0-00 ((douMe/a'/ JG b 0-00 8.0 0-00 E4-7 0-00 " P' .

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, 15.0 0-00 16 .0 0-00 E l- 1 0-00 El-2 0-00 EZ-1 0-00 Signature Concumng Organizational Element 0ata j onginator l} Q ('J/{tj .

l Engrg. Procedures & Stds. Manager l f/Ji/ N Concurreo byll # M'MM l Manager-Plant Analysis l /4/q/ff l /gW l Director-Systems Engineering j ,j. g f. f y

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ENuclear d'$7 4 i Analysis of GPUM Plant Transients (Post Trip Review)

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SUMMARY

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 2 Revised to include plant transients at Oyster Creek 3 Delei:ed reference to LP-003 0-00 Extensively rewritten to include new corporate format and include requirements of NRC Letter 83-28 for Post Trip review of transients.

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J Nuclear " ""c*r coraora a Po uc7 ne ese-m0.m Procedure Manual i M' Analysis of GPUN Plant Transients (Post Trip Review) Reisen T-00 I

  • 1.0 PURPOSE ,

This procedure establishes a consistent method for conducting the tech-nical analysis of TliI-1 and OC plants' performance during transient events.

2.0 APPLICABILITY / SCOPE 2.1 This procedure applies 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 T!!I-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, l

Systems Engineering and the Station Operations Director.

3.0 DEFINITIONS

, 3.1 TRANSIENT EVENT - Any unscheduled reactor trip, or unscheduled power excursion, or other event which in the estimation of r management warrants an evaluation.

3.2 TRANSIENT ASSESSitENT REPORTS (TAR) - A comprehensive analysis of

.' a transient event and its inpact. It includes a sequence of l' events, a discussion of nuclear safety concerns, and corrective action assignments. ,

l 3.3 TRANSIENT ASSESSf'ENT PROGRAlf (TAP) - A program to improve infor- i mation flow among B&W operating utilities concerning lessons learned from operating plant experience (described in Transient Assessment Program Guidelines B&W Report 12-1122130-Re v) . l 3.4 POST TRIP REVIEU GROUP (PTRC) - A group consisting of a Plant Analysis, Plant Operations and Plant Engineering representative called together immediately after an event to gather, analyze and l report on information, data and events that took place at the time of the transient event.

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3.5 NUCLEAR NETWORK - A conputer assisted reporting and information
excnange system whereby timely information is fed to a central 3 computer and can be retrieved by member utility users.

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!l ACCCTOSC1' 2.0

N GpU Nuclear Corporate Policy and MNuclear proceeure Manuai Rmun Na

-ACff-7370.04 I Analysis of GPUN Plant Transients (Post Trip Review) 0-00 l No I

4.0 . PROCEDURE REQUIREMENTS 4.1 General 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:

1. Determine the imediate and root cause(s) of the trip.
2. Identify unexpected, abnormal response to the trip by plant systems, equipment, and personnel.
3. Assess the impact of identified abnormalities on nuclear safety, equipment reliability, system performance, and availability.
4. Develop corrective actions /recomendations to prevent the recurrence of the trip and mitigate abnormal
responses.
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 normal.

The scope of the information reviewed under the program is sufficient to accomplish its objectives and includes data on plant system behavior, actuation and sequence of equip-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 in-depth evaluation that supports preparation of internal and external reports. The' program also outlines the criteria for determining the approval and concurrence

5. levels for plant restart. I 5

4.1.3 The prog ams major steps are illustrated in Exhibit 1.

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Analysis of GPUN Plant Transients (Post Trip Review) l 0-00 f

! The reactor trip review program consists of four distinct

! phases: .

fi 1. Post-Trip Review

2. Independent Review l 3. Restart Decision
4. Subsequent Evaluation l Every reactor trip wf11 be subjected to a Post-Trip Review j and Restart Decision. Only reactor trips with abnormali-i ties identified will undergo an Independent Review. In such cases, this review will be completed prior to the Restart Decision. Planned reactor trips, where no abnor-malities have been identified, need not proceed to the subsequent Evaluation phase. The nafor 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 Plant Transients Flow Chart (PO-002) and is outlined in the steps in Section 5.0. The role of each participant is sunnarized below.

4.2.1.1 Plant Operations is responsible for opera-ting the plant. Under the progran, the Shift Supervisor (SS) is responsible for notifying plant management of a transient event. The Shift Technical Advisor (STA) is the Technical Functions' contact with the operating plant. The STA is responsible for notifying Technical Functions (TF) personnel per TF Engineering Standard ES-005, "STA Duties and Responsibilities". The Operating Crew along with the STA, are responsible for diagnosing and controlling the event and thus wf11 have firsthand knowledge of the event. This information is to be pronptly docunented to help ensure that a complete record of the

event is obtained.

a.2.1.2 The Plant Analysis Section at the operating

_i site is responsible for supporting the Post

~. Trip Review. The Plant Analysis Section j reports to the Director of Systens Engineer-i ing and thus will provide an independent

j assessment of the plant's behavior and the I acceptability of restarting. The

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Revision No l Analysis of GPUN Plant Transients (Post Trip Review) 0-00 l

-l j Post-Trip Review nust be conpieted and docu-mented prior to restart. In addition, Plant I

Analysis will perform the subsequent evaluation, if necessary.

4.2.1.3 Various Technical Functions Departrents, especially Systems Engineering, and Engi-neering & Design, will provide analytical and technical support and recorriend correc-tive action as required.

4.2.1.4 The Plant Engineering, and Operations &

Maintenance Departments will make a prelininary determination of the root I cause(s) of the event and specify and implement corrective actions.

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 for con-curring with restart Plans and corrective actions.

4.2.1.7 In addition, the Independent On-Site Review Group and Plant Review Group may conduct additional evaluations.

4.3 Oualification Recuirements Technical Functions individuals will serve in the transient event review and analysis function. Independent of their cuali-fication for a particular position via expertise in an engineer-ing, science, or operational discipline, it is also required that all cognizant individuals in charge of the analysis process be qualified either as responsible technical reviewers or inde-pendent safety reviewers. Certain analysis may be perforned by non-qualified individuals as long as it is under direct super- '

vision of a qualified individual.

Personnel certifying completion of steps in the review process will be qualified to one of the below Tevels:

4.3.1 Senior Reactor Operator (SRO) 3 4.3.2 Shift Technical /dvisor (STA) 7

?, 4.3.3 Responsible Technical Reviewer (PTR) ll l' 4.3.4 Independent Safety P.eviewer (ISP) i-5.0

GPU f4uclear Corporate Policy and

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  • '".Aa,, 73 70.04 g, Revision No Analysis of GPUf! Plant Transients (Post Trip Review) 0-00 i I 4.4 Post Trio Review ,

The Post-Trip Review is performed irrediately after plant stabi-lization from a trip and completed prior to restart.

4.4.1 Purpose The purpose of the Post-Trip Review is to:

1. Determine the cause(s) of the trip.
2. Identify other-than-expected performance of plant systems and equipment.
3. Assess the impact of identified abnormal perfor-mar.ce on safe operation.

4 Specify corrective actions required to restart.

5. Ensure continued availabfifty of infornation l

and data pertaining to the event.

A.4.2 Scoce

, The secpe of the Post-Trip Review has been established

, to ensure that abnormal performance in important sys-tems will be identified. Guidelines and criteria,

, which define the range of expected response, are used in the process. The major eierents of the Post-Trip Review, and the responsible lead organization are:

1. Plant Analysis with assistance fron Station Operations, will gather plant data.

l 2. The responsible Station Operations Departrent will make a preliminary determination of the cause(s) of the trip.

3. Plant Analysis will rake a preliminary deter-l mination of the reactor trip sequence.

I 4 Plant Analysis will review the pre and post-l trip behavior of key parameters that reflect overall plant performance and will tentatively identify abnormal perforrance of important system s, e r 'Penr aes ,0vnene / = peen. ,/

g 5. Plant Analysis will review the performance ofa

! ..d ,fimportant systems and equipnent, both safety and l 5 control, to tentatively identify other-than-expected response to the trip.

! 6. The responsible Station Operations Cepartrent 2 or Technical Functions Section will conduct

! additional review as required based on t' identified abnormal response.

! 7. The responsible Station Operations Departrent a1d Technical Functions will identify corrective j

actions that nust be corcTeted crier *o re m r*

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GPU Nuclear Corporate Policy and New

.R LMNuclear grocecure senuai iOC0_,c,..,y0.3 g, Revision No Analysis of GPUN Plant Transients (Post Trip Review) 0-00 , _

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{ 4.4.3 Data Collection

4.4.3.1 The data specified 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 maintained as a permanent record, i In as much as the data to be used in the

! analyses may be original plant documents such as Togs, 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 Plant Computer System will be a prime source of data used to determine and eval-uate plant response.

When the computer is not available much of the data specified in Exhibit 2 will not be available. Other sources of data should be used, if possible, to determine and evaluate plant response. All available data from Exhibit 2 will be collected including, in-depth interviews of involved personnel, copies of all strip chart recorders, operating staff logs and any hand calculations or manually plotted graphs.

i 4.4.4 Imolementation {

The Reactor Trip Review Program will be inplerented i via a Plant Administrative Procedure.  !

4.4.5 Post-Trio Review Grouc  ;

As soon after a transient event as is practical, the l Post Trip Review Group will be assenbied. This group l will consist of representatives of Plant Analysis, Plant Operations, and Plant Engineering. Additional ,

5 personnel may be assigned to the PTRG as reouested by ,

~

the above members. The activities of the PTRG will '

fnclude event analysis to confirn the cause, sequence, I and response of the event, and development of I appropriate corrective actions, reccnnendations, and $

2 conclusions. This information will be docurented in I written form. It will be distributed to the i

j. Operations & l'aintenance Ofrector (T!'I) or the Plant  !

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4.4.6 Data Analysis 4.4.G.1 The Post-Trip Review Group will analyze the plant response to determine anomalies.

Areas to be analyzed are listed below:

4.4.6.1.1 RCS and Core Heat Removai 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 l

4.4.6.1.5 Containment Environment &

Isolation i 4.4.6.1.6 Radiation Controi

4.4.6.1.7 Electrical Power

, 4.4.6.1.8 Chemistry Controi

4.4.6.1.9 Safety System Status 4.4.6.2 The Post-Trip Review has been established to ensure that abnormal performance in impor-tant systems will be identified. A prede-termined check-list, to be contained in a Plant Administrative Procedure, 11stina specific plant performance criteria will be used to conduct the review.

l 4.4.6.3 Any deviations in plant response shall be

documented and the event placed into one of I the following categories.

i 4.4.6.3.1 Category 0

, The RPS trip function and root cause(s) are positively known and have been corrected; plant response was normal with all equip-ment functioning properly during the event.

2 4.4.6.3.2 Category I i The root cause(s) is not positively known and corrected or plant response was abnormal 5:

or safety related equipment did not function 3

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I GPU Nuclear Corporate Policy and J Nuclear groceau,, sanuai "T886'.ACs-7370.04 : I i rme Analysis of GPUN Plant Transients (Post Trip Review) Ren n No. 0-00 i I

properly or conditions associated with the transient resulted in operation in violation ,

of the Technical Specifications.

4.4.6.3.3 Category II  :

Cold shutdown is required.  !

. Events classified as Category I or II will require an Independent Review prior to restart.

4.4.6.4 The Post-Trip Review Group will ensure investigation of the cause of the trip to the fullest extent possible. When the root cause is unknown attempts to locate and duplicate the cause through troubleshooting

, and testing, and appropriate calibration and I maintenance checks will be made. If the i root cause(s) of an event can not be deter-mined then it wf11 be classified as a Category I event, requiring an Independent Review prior to restart.

4.4.7 Corrective Actions The Post-Trip Review Group will specify corrective actions required prior to startup to. prevent or miti-gate the consequences of future reoccurrences so as to ensure an orderly plant restart.

4.5 Indeoendent Review 4.5.1 Under certain conditions, further review must be per- j formed prior to restart to ensure that all questions regar' ding the ability to safely restart and operate the plant are resolved. They are as follows:

4.5.1.1 If the immediate (RPS trip function) and root cause(s) of the trip cannot be determined, or 4.5.1.2 Plant post-trip response is abnormal, or 4.5.1.3 If any unresolved safety issues exists, or 4.5.1.4 *If compliance with licensing requirements is

5. in question.

. 4.5.2 The Independent Review will be performed by a group of z

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N#" 3 GPU Nuclear Corporate Policy and ENuclear groceoure xanuai IOOO un.73,0,0, hvision No Title Analysis of GPUN Plant Transients (Post Trip Review) 0-00 l

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experienced and knowledgeable individuals, such as RTRs or ISRs, designated by the Operations a ffainten-ance Director (THI), or Operations Director (OC), and the Director Systems Engineering.

4.5.3 In addition, it nay also be appropriate to forward data and event information to the NSSS vendor if it is 6 beneficial to obtain their analysis. Transient data wf11 be released to the NSSS vendor via the vendor resident engineer. Data released to the NSSS vendor will be proprietary, for vendor internal use only, unless specifically released for further distribution by GPUN Systems Engineering.

! 4.5.4 Results will be reported to the Operations & ffainten-ance Director (Tit!), or Operations Director (OC), and the Director, Systems Engineering.

4.6 Restart Cecision 4.6.1 Prior to restarting the unit, Operations and Technical Functions must ensure that:

4.6.1.1 The cause(s) of the trip (RPS Trip function and initiating event).are known or have been investigated to the fullest extent cossible.

4.6.1.2 The plant's transient response was as expec-ted.for the type of event, and either did not identify any problems that impact the ability of the unit to be safely restarted and operated or that the problems have been corrected.

4.6.1.3 Any problems with ecuiprent subject to Tech Spec LCO requirements are corrected as ,

required. ,

4.6.1.4 The corrective actions identified during the Post-Trip Review as being required prior to restart, are implemented.

E 4.6.2 The decision to restart will be made by the Plant Vice

~. President or his designee with Technical Functions concurrence, per the Exhibit 3 ratrix.

2 2 4.7 Subsecuent Evaluation 4

i Every unplanned trip will be subjected to a follow-up, in depth

!! evaluation as specified by Plant Analysis. In addition, planned J j reactortripswhichshowabnormalitiesinplantfresponsewilige ojc0{

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N GPU Nuclear Corporate Policy and

Nuslear proceeure sanuai T666'.ACM-7370.04 i i

)

Revesson No.

M* Analysis of GPUN Plant Transients (Post Trip Review) l 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 Post-Trip Review and expands upon it in areas of identified abnormal response. It ensures that the more subtle aspect of system performance, even though they did not significantly affect the plant response, are evaluated and needed corrective 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 I' analysis. The responsible Technical Func-tions engineering sections will analyze the i plant response to determine response anoma-lies. Areas to be analyzed include, but are not ifmited to, those listed below.

4.7.1.1.1 Reactivity control, fuel integrity, and core transient conditions; 4.7.1.1.2 Core heat removal, RCS heat removal, and RCS inventory and pressure control; 4.7.1.1.3 Steam generator heat transfer, inventory and pressure control (TMI only);

4.7.1.1.4 Normal and emergency electrical system performance; 4.7.1.1.5 Containment environment & isolation g 4.7.1.1.6 System and component operation as c5 accrocriate; p/ 40 4.7.1.1.7 h jprocedures, training, and control I y 'I p r ge <Slp 4.7.1.1.8 room designp ---- - - - - - - - - -

Potential effect of different plant Of7 conditions or additional credible failures / errors, c 4.7.1.2 If abnormal response is indicated, then Sys-

[ tems Engineering will coordinate additional

. specific ar,alyses to determine the cause of g the abnormal response and to investigate

" alternate event paths, as appropriate.

4 7 -

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N GPU Nuclear Corporate Policy and M '-ADM-7370.04 !

Nuclear proceeure Manuai j Tw. Analysis of GPUN Plant Transients (Post Trip Review)  % vision No. 0-00 l

4.7.2 NSSS Vendor For some events, a review and site visit by the NSSS vendor may be necessary.

4.7.2.1 The Plant Analysis section will be the interface between the NSSS vendor represen-tatives and the plant staff.

4.7.2.2 The format of the NSSS vendor review for TM:

will be as specified in current Transient Assessment Program Guidelines (B&'d Report 12-1122130-Rev) .  !

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 l transient assessment, if necessary.

. 4.8 Owners Group Notification The Plant Analysis section will formulate the required notifica-tion to the appropriate Owners Group Utilities, preferably via Nuclear Network. Exhibit 4 provides a sample format.

An event sur. mary for Nuclear Network, shall be released with the concurrence of the Director, Operations and !!aintenance (TMI) or Operations Director (OC), following approval by the Director, Systems Engineering for each event investigated. This event summary should be released within one working day following the event.

4.9 Report Precaration 4.9.1 The Plant Analysis section is responsible for prepar-ing the Transient Assessment Report. Exhibit 5 con-tains a sample report format. This report shall be approved by the Director, Systems Engineering with Operations and Maintenance Director (TMI-1), or Opera-tions Director (OC) concurrence and released within 30 days of the event.

4.9.2 Any subsequent Technical Data Reports detailing the analysis of a transient aspect by the responsible Technical Functions department and/or plant depart-ment, will be prepared in accordance with 5 5000-ADM-7316.01.

1 7

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' Title nevision No Analysis of GPUN Plant Transients (Post Trip Review) 0 . I l 4.9.3 The appropriate Licensitig section will process Licen-I see Event Reports (LER) in accordance with 1000-A0ff-1216.03. The appropriate plant department will provide input for the LER submittal.

4.10 Followup Action 4.10.1 The Plant Analysis section will utilize 5000-A0t'-

7370.02 to initiate, monitor and document the inple-mentation of corrective actions recommended in the Transient Assessment Report.

5.0 RESPONSIBILITIES -

5.1 Analysis of GPUN Plant Transients (Refer to the Procedure Flow Chart, Exhibit 1) .

l I 5.1.1

! POST TRIP Gathers event data /information (see Exhioit 2) j REVIEW GROUP Forwards event data /information to DSE, CaliD (Tf!I)

(PTRG) or OD (OC)

Assembles as soon as possible after transient l event  !

Confirns sequence of events Evaluates plant response  ;

Confirms cause of initiating event l Reconmends corrective actions .

Generates written docunentation of results  !

5.1.2 1 PLAtlT AflLYSIS Forwards event data /infornation to NSSS vendor,  !

SECTI0ft (PAS) if needed, for preliminary analysis, and speci-  ;

! fies extent of analysis  !

! Forwards documentation of results to C&lt0 (T?!!) or I i 00 (OC), PED  !

I

' i 5.1.3 .

STATI0ft Deternines corrective actions I CPERATI0flS

-j DIVISI0tl El (500) b 5.1.4 2l l NSSS T VEtIDCP. Conducts site visit, if appropriate g (NSSSV) Performs pretininary analysis of event data and prepares sunnary report, if necessary l j: l' I

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GPU Nuclear Corporate Policy and Numon yUCgear proceeur,3,nu,i 1000-ADrr-7270.04 I", " ' l Revision No.

Analysis of GPUN Plant Transients (Post Trip Review) j 0-00 5.1.5 DIRECTOR, SYS- Assign Section !?anager(s) to investigate transient TE!!S ENGINEER- Reviews and approves 'NSSS vendor Prelininary Summary (DSE) Report or DIRECTOR, i Ef!GINEERIt!G }

AND DESIGN i I (DED) l 5.1.6 l PLAT!T ANALYSIS Prepares event summary for release to Owners' Group SECTION (PAS) Utilities via NUCLEAR NEDICRK l

Submits surriary to O&MD (TMI-1) or OD (OC) for con-  ;

j currence .

Perform subsequent Evaluations, if required 5.1.7 ,

CPERATIONS Concurs with event sumary for NUCLEAR NETWORK i

& i%INTENAf!CE i DIRECTOR (TfI)  !

(0&f!D) or CPERA-TIONS DIRECTOR, OC i (0D) '

5.1.8 DIRECTOR, SYS- Approves event sumary and authorizes release to l TE!!S ENGINEER- Owners' Group Utilities via NUCLEAR NETWORK i ING (DSE) l

\

5.1.9 i' SECTI0ff PANAGER Perform further analysis as warranted Assists Station Operations in review of Restart '

(S!!)

Criteria -

Assists Station Operations in planning of recovery  ;

actions l Prepares reports of specific analysis, if warranted j i

5.1.10 STATION OPERA- Plans and impiecents plant recovery actions l TIONS DIVISION Completes required recovery action (SOD) Prepares LER Input and submits to Licensing

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5.1.11

DIRECTOR, SYS- Concurs with restart plans

. TEf!S Ef:GINEER- Approves Transient Assessment Report and authorizes i ING (DSE) release

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5.1.12 i STATI0ft CPERA- Approves Plant restart

. T!0N DIVISIO!!  !

1; (S00) i

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. e i- GPU Nucicar Corporate Policy and i Nus br grocecure sanuai iOOO-,cr-7370.0a Revision No Analysis of GPUN Plant Transients (Post Trip Review) 0-00

, 5.1.13 OPERATIONS & Concurs with Transient Assessnent Report l MAINTENANCE DIRECTOR j Tril-1 (OfiD) or OPERATIONS DIRECTOR I

OC (OD) 1 5.1.14 '

! LICENSING Processes LER in accordance with *

SECTION (LS) 1000-ADM-1216.03 (LP-002)

{

f 5.1. 15 l PLAT!T ANALYSIS Distributes final event reports l SECTION (PAS)' Assigns followup corrective actions regarding training, operating procedures and/or plant design

, a 5.1.16 NUCLEAR ASSUR- ifanager, IOSRG reviews event reports ANCE DIVISION ffanager, Plant Training impienents training (NA) progran changes as required Pfanager, Quality Assurance implements OA procedure change as necessary -

5.1.17 '

STATION OPERA- Implements changes in plant operating and/or l

TIONS DIVISION naintenance procedures as necessary  :

(500) l 5.1.18 ENGINEERING PRO- Initiates plant design changes as required -

JECTS/ ENGINEER-ING AND DESIGt! ,

(EP/ED) i i

5.1.19 I SYSTE?tS ENGI- Determines if additional evaluation is required NEERING (SE) on action item followup response 5.1.20 PLANT ANALYSIS Reviews / approves action taken

. SECTION (PAS) Recomends additional action as required Files closed-out action document i

5 2

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. r Nume;r GPU Nuclear Corporate Policy and

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6.0 REFERENCES

! 6.1 5000-ADM-7316.01 - Technical Reports' f

j 6.2 1000-ADM-1216.03 - Regulatory Correspondence Management and j Ccemittment Control 6.3 5000-ADM-7370.02 - Review of Industry /GPUN Operating Experience l

6.4 ES-005 "STA Duties and Responsibilities" l

7.0 EXHIBITS i 7.1 Exhibit 1 - Procedure Flow Chart 7.2 Exhibit 2 - Transient Event Data Requirements 7.3 Exhibit 3 - Restart Decision / Concurrence Matrix 7.4 Exhibit 4 - Nuclear Network Transient Notification 7.5 Exhibit 5 - Transient Assessment Report Format O

I.

5 6

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  • E GPU Nuclear Corporate Policy and g 7 Procedure Manual N N -A0ff-7370 004 Reisson N l Title Analysis of GPUN Plant Transients (Post Trip Review) 0-00 l

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EXHIBIT 2 l TRANSIENT EVENT DATA RE0ViREMENTS I

The GPUN Plant Analysis Section engineer and Shift Technical Advisor, assisted

. by Plant Engineering and Operations personnel, will gather data associated I with a transient event. The following data should be gathered:

1. Plant Equipment Configuration before, during and following the event
2. Computer Chronological Alarm Listing (TMI)
3. Computer Sequence of Events Printout 4 Computer Post Trip Review Surmary
5. Transient Monitor System Data Dumps and Plots (TMI)
6. CRT Video-Copied Data generated during the event (TMI) 7 Computer Utility Printer data gathered during the event (TMI)
8. Operating Staff Logs
9. Applicable Strip Chart Records 10 . Any other data that may be useful in analyzing the transient event.

Specific requirements are further detailedin the impienenting plant procedure. .

NOTE: To preserve the original records of the plant transient, photostatic copies of the above should be used where practical.

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' Title ewsion No i Analysis of GPUN Plant Transients (Post Trip Review) 0-00 EXHIBIT 3 i

RESTART CONCURRENCE f%TRIX l

Cause(s) Plant Cold Known Response Shutdown Tech. Functions Catetary and Corrected Normal Recuired Concurrence Level Yes Plant Analysis l 0 Yes No Manager (TMI-1,0C)*

l I l i

, l l 1 l Yes l No No l Director, Systems Engineering

  • l No Yes l No Ofrector, Systems l l Engineering
  • l l II l l

--- Yes VP-Tech. Functions

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l Title g Analysis of GPUN Plant Transfents (Post Trip Review) 0-00 i

! EXHIB!T 4 - PART I B&W OkNERS GROUP TRANSIENT NOTIFICATION (TMI-1)

TMI-1 s

f PLANT _, TRANSIENT DATE:

TYPE OF TRANSIENT '-

TRANSIENT TIME:

l k g  %

EXECUTIVE SUMitARY

.u s

l I. A. PLANT CCNDITIONS: (Prior to Transient)

Reactor Power: RCS TH : Tc:

RCS Press: Pressurizer Level:

Steam Press: OTSG Level: A B RCS Pumps l Combination MFW Punp Status I ICS Mode:

} B. Testing in Progress:

5 C. Abncrmal Lineups er Plant Conditions: (Pertfnent to the trans f ent) 4 7-i

2. a:

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N GPU Nuclear Corporate Policy and T500LADM-7370.04 I NUCIGar procedure Manual

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> D. Major Equipment Out of Service: (Pertinent to the transient) i II. EVENT SwiMARY:

A. Major parameters during the transient l l

RCS Temp: Max. Max. RCS Cooldown Rate:

Min.

Min. Subcooling Margin:

l RCS Press: Max. Pressurizer Level:

i

! Min. Max.

l 1 Min.

OTSG Press: OTSG Level:

1 1

Max. A Max. A B B Min. A B Min. A B III. DESCRIPTION OF EVENT:

Initiating cause:

l l

l Trip Mode: Auto Manual If Auto, wnich function

( Core Cooling Mode: Forced Natural l Convection Convection l

I HPI

5. Quantity Water in RS if HPI Cooling

=

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I EXHIBIT 4 - PART I (Contd.)

l l

Immediate operator actions and procedures used: ,

l l

HPI Initiated? Yes No Manual? Auto?

Energency Feedwater Initiated? Yes No Manual? Auto?

Was PORV challenged? Yes No Were Code Safeties challenged? Yes No Were ?1ain Steam Safeties lif ted? Yes No Was Itain Steam er Feedwater isolated? Yes No l

Pressurizer Level off scale? Yes No H igh? Low?

Duration, if yes GTSG levels off scale? Yes No H igh? Low?

Duration, if yes Max. Radiation / Activity Levels in RB I

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GPU Nuclear Corporate Policy and !N"***'

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! groo,,,,, sanue3 liOOO-A0n-7370.04 g, j Revision No.

Analysis of GPUN Plant Transients (Post Trip Review) 0-00

EXHIBIT 4 - PART I (Contd.)

! Any ancmalies or unusual circumstances observed in the l event?

I l

! I Supplemental Operator actions and procedures used:

IV. PRESENT PLANT CONDITI0ft DATE:

TIME :

RCS Temp: RCS Press.

Pressurizer Level: OTSG Level:

A B I - Core Cooling tiode: Radiation Levels 1

=

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Inside Containment:

1 5 Outside Containment:

I  :

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! Analysis of GPUN Plant Transients (Post Trip Review) 0-00 EXHIBIT 4 - PART I (Contd.)

Class Emergency Declared:

NRC/Public Notification: Yes No ret %RKS: (Include an assessment of present plant cond ition) l V. Intentions: (Include plans concerning changes to plant conditions and imediate corrective actions if known)

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EXHIBIT 4 - PART II OWNERS GROUP TRANSIENT NOTIFICATION (0.C.)

l l Transient Date: T ime:

i Name of Event:

Executive Summary:

i

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! GPU Nuclear Corporate Policy and

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1000-ACM-7370.04 Revision No.

i Title Analysis of GPUN Plant Transients (Post Trip Review) 0-00

! EXHIBIT 4 - PART II (Contd.)

! A. Plant conditions prior to transient:

l (Insert Data Sheet #1) f B. Testing in Progress:

t i

C. Abnormal lineups or plant conditions (pertinent to trans ient):

D. Major equipment out of service (pertinent to transient):

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! 7.tte Analysis of GPUN Plant Transients (Post Trip Review) 0-00 l EXHIBIT 4 - PART II (Contd.)

E. Parameter Values During Transient Thermal Power: Max. mkt

! Min. MhT Reactor Level: Max. in GEFAC Min. In GEMAC l

Reactor Press: Max. P sig Min. Psig Recirc Flow: Max. gpmx10 4 Min. gpmx10 4 Drywell Temp.: Max. 'F Min. *F Drywell Press: Max. Psig Min. Psig Torus Press: Max. P s ig Min. Ps ig g

Torus Temp.: Max. F 3 Min. , "F 2

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EXHIBIT 4 - PART II (Contd.)

i l F. Descriotion of Event I

! Initiating Cause:

Scram Mode: Auto / Manual If Auto, which function?

Was tiain Steam or Feedwater isolated?

Yes No Isolation Condensers Initiated?

Yes No Core Spray Initiated?

Yes No Containment Spray Initiated?

Yes No Any 01RVs Lift?

Yes No Any Safety Reliefs Lift?

i j

Yes No T

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R UINuclear l1',%"23 "'" " "c' '"' "ELcM-m0.04 i

l Revi$lon No l Title Analysis of GPUN Plant Transients (Post Trip Review) 0-00 l l EXHIBIT 4 - PART II (Contd.) l l

Maximum Radiation / Activity Levels in Drywell and Reactor Building?

l __

Maximum Rad /Act. Level at Site Boundary?

Imediate operator actions and procedures used:

Supplemental operator actions and procedures used:

Any Ancnalies or unusual circumstances observed durinc the event?

c

Class Emergency Declared?

NRC/Public Notification? Yes No 7

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' '"* 5' i GPU Nucicar Corporate Policy and

!. US I Procedure Manual 1000-ACM-7370.04 Revision No l Tide I Analysis of GPUN Plant Transients (Post Trip Review) 0-00 EXHIBIT 4 - PART II (Contd.)

l 1

G. Plant Conditions Af ter Transient: ,

(Insert Data Sheet 72) i Max. Radiation / Activity Levels in Drywell and Reactor Building:

Max. Radiation 7 Activity Levels at Site Boundary:

Assessment of Present Plant Conditions:

Intentions (Corrective Actions Planned and/or Changes in Plant Conditions Contemplated) :

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! Nuclear  % $ l' O '^t' "If00ACH-m0.04 r,ue Revis.on No Analysis of GPUN Plant Transients (Post Trip Review) 0-00 EXHIBIT 5

! TRANSIENT ASSESSMENT REPORT i

(SAMPLE FORMAT) f Transient Assessment Recort i

A Transient Assessment Report will be prepared fer all reactor trips. Re-ports may also be prepared for other significant events. The purpose of the report is to provide transient event information for all Owners' Group Utilities. 'The operational experience shared in this program will lead to -

improved plant reliability and a better understanding of the plant's per .

formance by all Owners' Group Utilities.

The format of the report should be as follows:

I. Summary II. Transient Assessment A. Sequence of Events B. Plant Perfomance

1. Pre-Trip Review
2. Initiating Event
3. Plant Post-Trip Response 4 Operator Actions / Procedural Adequacy C. Safety Considerations D. Assessment Conclusions E. Corrective Actions The "Sumary" section should be a short description of the event, highlighting the major aspects of the transient and the resulting evaluation.

The "Secuence of Events" section should contain those major events or con-ditions, wnicn celineate the progressive course of the transient.

The " Pre-Trio P.eview" section should contain a statement of the plant con-ditions prior to the transient. Examples to be included wo'ild be power level, ICS status, maintenance or testing in progress, and equipment deficiencies.

- Additionally this section should provide the framework for evaluating the in-itiating event and root cause of the transient.

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GPU Nuclear Corporate Policy and Numcu ,

l i Nuclear proceau,, sanuai icoo-Acti-7270.c4 74, Revision No Analysis of,GPUN Plant Transients (Post Trip Review) 0-00

EXHIBIT 5 - contd.

The " Initiating Event" section should be used when a transient is initiated by a complex series of events such that detailed analysis is required to delin-eate the occurrences.

9

! The " Plant Post-Trio Response" section should include a discussion of the

, response of tne N55 and BOP frem a process point of view; i.e., TAVE, RC

! Pressure, Pressurizer Level, Feedwater 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 components and their departures from the expected. Proposed corrective actions and i corrective actions previously completed may be included in the text of this section.

The " Operator Action / Procedural Adecuacy" section should include information concerning specific operator actions taken during the transient which have not been included in any previous sections. Additionally, procedures followed during the transient, and any information which would be beneficial to other operators should be included. This section should be considered fer input into. procedure revisions.

The "Saf ety Considerations" section should include the bases for which safety, as it relates to tne transient, has been considered. Those bases might in-ciude plant design requirements, FSAR accident analysis, or other infonnation.

The "Assesscent Conclusions" section should be a summary of the significant aspects of tne transient, including departures from expected components and plant performance. .

i -

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ATTACIDIENT 2 i

OR USE IN UNIT l ONLY '

Qpgia

.IMPORTANT TO SAFETY ' ' ' ' '

NON-ENVIRONMENTAL IMPACT RELATED CONTROLLED COPY FOR

^

USE IN UNIT 1 ONLY i.

THREEMILEISLANDNUCLEARSTATIOk UNIT NO.1 ADMINISTRATIVE PROCEDURE 1044 EVENT REVIEW AND REPORTING REQUIREMENTS ED.' & .C.C.

Table of Effective Pages Pagg Revision la.gg a Revision PR Revision Pm 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 t

6.0 13 31.0 13 7.0 13 32.0 13 8.0 13 33.0 13 i

9.0 13 34.0 13 10.0 13 11.0 13 12.0 13 13.0 13 -

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'S'gnature /L 2.9 1 Date O

Signature l 2-h Date

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/' Signature a .z. ,- u Date '

Document ID: 00308 FOR USE IN UNIT I ONLY

FOR USE IN UNIT l ONLY

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s",,on i3 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 1

3.1.1 10 CFR 50.72, Immediate Notification 4.0 3.1.2 10 CFR 50.73, Licensee Event Reports 4.0

~

3.1.3 10 CFR 20. Radiological 5.0 h ~

3.1.4 10 CFR 50.36 Technical Specification Safety Limits, LSSS and LCO 5.0 3.1.5 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 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 6

1.0 4

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, . . .. . . ..s... . . . .

.. . Table of Contents (Cont'd) r Section -

Page 4.0 ENCt.0SURES

, 4.1 Enclosure 1 - 10 CFR 50.72 13.0 4.2 Enclosure 2 - 10 CFR 50.73 - 18.0 4.3 Enclosure 3 - 10 CFR 20 22.0 4.4 Enclosure 4 - 10 CFR 50.36 26.0 4.5 Enclosure 5 - 10 CFR 73.71 -

28.0 4.6 Enclosure 6 - Events 5f-95tential Public Interest 31.0 4.7 Enclosure 7 - Potentially Reportable Event Form 33.0 4.8 Enclosure 8 - Public Inquiry Policy 34.0

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4 1.0,, GENERAL. ,

i[ 1.1 Purpose i The purpose of this procedure is to specify the evaluation and reportirg requirements when an event has occurred which may require

(

notification of MRC representatives and/or company management. )

1.2 Scope This procedure applies to personnel at the TMI-1 site.

1.3 References 1.3.1 10 CFR 50.72, Immediate Notification Requirements for

s. Operating 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) h 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 Noncompilance 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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aevision ia The' Shift Supervisor ~ l'sr ' e'sponsible 'for'mhking the initial deter-

't:2 mination regarding reportability. He shall insure 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 reportable occurrences brought to his attention are submitted to the PRC for evaluation.

2.4 The PRG Chairman shall ensure timely review by the PRG of f

potentia 11.yorepoetable occurrences and-secommend appropriate action to the Operations and Maintenance ofrector.

2.5 The Operations and Maintenance Director or his designee (in non-emergency situations) shall make the final determination regarding reportabl11ty and ensure that appropriate on-site and  !

{ off-site organizations are notified. l

~

3.0 REQUIREMENTS 3.1 Potentially Reportable Events 3.1.1 10 CFR 50.72, Immediate Notification a.c.. I Evaluate.the" event,under. consideration against the  !

criteria specifled 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, Licensee Event Reports a.

Evaluate the event under consideration against the

-criteria specifled in Enclosure 2.

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""' 5 ' oa ' 3 g 'g7 the' event 1s considered reportable under 50.73 7

then make notifications as des'cribed in 3.3.2.

3.1.3 10 CFR.20, Radfological

a. .

Evaluate the event under consideration against the 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 applicable.

3.1.4 10 CFR 50.36,' Techntcal Specifications,.Section 2.0 a.

Evaluate the av.ent under. consideration against the 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.

{ 3.1.5 10 CFR 73.71, Security a.

With direction from Security personnel, evaluate the i

event under consideration against the criteria specified in En'losure c 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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.3 , y, 6 " l ' CFR# il,"DeNi:'ts 'and ' Nonce pilaNce

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i a.

10 CFR 21 requires notification of the NRC upon

, ,, dt.scovery 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

a. '

The Emergency Plan requires spectal NRC notification for.. specific events. The Emergency Plan shall be s.-2..used for quidance in making.those notifications.

NOTE:
Initiation of the Emergency Plan is in itself report I able within one hour under 10 CFR 50.72.  :

b.

Events reportable under the Emergency Plan may also be reportable under 10 CFR 20 or other requirements.

(. 3.1.8 Events of Potential Public Interest .

a.

. These are events that may not be considered report -

able under other sections of this procedure. Refer to Enclosure 6 for a list of these events. It has been committed that notification of such events will be made to the GPUN Public Informatlon Representa-tive, The TMI-1 Duty Superintendent, the Site Duty NRC Representative and the Unit 2 Control Room.

NOTE:
The declaration of an event of potential pubile  :
interest shall not be made in lieu of the declara.  :
tion of a formal emergency classification (i.e.,  :

Unusual Event). ,

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aevision i3 r a .

b'.Thi' Shift'$upe'rvisorisresponsiblefornotifying

-s the Operations and Maintenance' Of rector, or his designee,.an.d the,below listed personnel of signift-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. TMI-1. Duty. Superintendent
4. Unit 2 Control Room
NOTE:
The OPX network shall not be used for routine  :

communications with the NRC. -  :

c. Additionally, an entry should be made in the Shif t

(

Foreman's Log Book (left-hand section) describing the event.

d. In the event a call is received by Control Room personnel by members of the pubile concerning plant 4

status or a perceived plant problem, refer to the guidelines provided in Enclosure 8.

e. Upon termination of the event notify the Public Information Representative.

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. Revision u

.s3,2' '" Initial Re'vieV Process' " ' ' ' '

,, 3.2.1 L -

The Duty Shift Supervisor is typically in the best p

, osition.to become aware, first. h.and, of a potentially reportable event. Sources of information available to him include:

a. Results of Tech. Spec. surveillance.

4 b.

Operations or maintenance activities that may reveal  !

Improper methods or malfunctioning equipment.

3.2.2 For events.. brought to his attention, the Shift Supervisor

..., shall make.the initial determination regarding report- I 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 Superylsor determines that the event is clearly not reportable, he shall inform the Manager-Plant Operations.

3.2.4 If the Shift Supervisor determines that the event is potentially reportable, additional action is required as '

spe.cified in Section 3.3.

3.3 Follow-up Review and Reporting 3.3.1 Emergency Notification System (ENS)

a. For events potentially reportable via the ENS, the Shift Supervisor shall lamediately notify the Operations and Maintenance Director or Duty Super-intendent. The Operations'and Maintenance Director or Duty Superintendent will make the final i

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. . . .n.. _._;..m , - -

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" gSMnIlhtlb..' ~

n.regarding reportability (If unable to f- s,

. contact the Duty Superintendent or Operations and

. Maintenance Dtrector, the Shift Supervisor will make the determination).

b.

If he determines the event is reportable, he or his designee shall notify:

1.

The Public Information Representative (see On-site Duty Roster) 2.

Site NRC Duty Representative (see current

. a.

" Weekly Schedule -- NRC on.CA1.1. Representative" in the Shift Supervisor's office) 3.

NRC Operations Center via ENS (red phone),

Notification to the NRC Operations Center shall i be made within the required time frame and the

( applicable CFR or other reporting requirement shall be Identified, j

NOTE:
A copy of the NRC " Checklist for Licensees Making  :
Notifications of Significant Events in accordance  :
with 10 CFR 50.72" may be found at the red phone.  :
This checklist is descriptive of the type of  :
Information the NRC may requsst and is supplied for  :

your information and aid. There is no requirement to.use this list.  :

c.

If the EMS is inoperative, then make the required notifications -via commercial telephone service, other dedicated telephone system, or any other t_.

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. method which 'w111 eiis~u re~ t' hat 'a' report"1s made as~

soon as practical to the NRC Operations Center.

. NOTEi
NRC IE Bullettn No. 80-15 requires TMI 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.

During 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 not understood e.

Maintain an open, continuous connunication channel with the NRC Operations Center upon request by the NRC.

1.

. The Shift Supervisor shall complete and distribute a Potentially Reportable Event Form provided as Enclosure 7 to this procedure, s

(/ 10.0 FOR USE IN UNIT I ON _.Y

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. .3'.3.2"~0ther* Notification'an'd Repor'ttng a.

The Shift Supervisor shall notify the Operations and .

Maintenance Director 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" a.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 Enclosure 7 to this procedure, c.

PRG will review the poter.tially reportable event and make a recommendation concerning reportability to the Operations and Maintenance Director. The PRG reportabillty recommendation wi.11 be documented. A PRG recommendation concerning reportabillty 1s not required if the event has already been reported. If the item requires further technical evaluation, a Preitsinary Safety Concern Evaluation Form may be submitted in accordance with LP-007. Applicable procedures shall be reviewed following a reportable b 11.0 FOR USE IN UNIT I ONLY

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occurrence such.as an accident, an unexpected transtant, significant operator error, or equipment

. malfunction to determine whether procedure changes are required.

d. The Operations and Maintenance Director 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

~ .

.m

.. _.. . -and. Malatenance .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.
b. Notify Company Management.
c. Notify the Pubile Information Representative
d. Notify the PRG Chairman.

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3 I.

_10 CFR 50.72 Notifications _

One-Hour Notification Requiremeffs

.(a)(1)(1)

The declaration of any of the Emergency Classes specified the licensee's approved Emergency Plan.

(b)(1)(1) (A)

The initiation of any nuclear plant shutdown required b 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: -____
departs from a license condition or: a Techn i Specification in an emergency when  :

this a

safety and no action consistent with license condi-
tions and Technical Specifications that can provide::
adequate or equivalent protection is immediately :

apparent.

\ .

@LE: __

Refer also to 50.73 (a)(2)(1)(A),(B),(C) .._

(b)(1)(11) Any event or condition durina ooeration 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; (B)

In a condition that is outside the design basis of the plant; or I

. 13.0 FOR USE IN UNIT I ONLY.

FOR USE iN UNIT I ONLY 00fsioni3 Enclosure 1 (Cont'd)

(\ .

(C) In a condition not covered by the plant's operating and

~

emergency procedures.

l

NOTE: Refer also to 50.73 (a)(2)(11) i 5 1

(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 i

.the p'lant.

NOTE: Refer also to 50.73 (a)(2)(111) 4 (b)'(1)(1v) Any event that results or should have resulted in Emergency Core Cooling. System (ECCS) discharge into the reactor coolant

(

4  !

system as a result of a valid signal. .

NOTE: Refer also to 50.73 (a)(2)(1v)  :

(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-i

) tion, Emergency Nottf tcation System, or offsite notification system).

l s.

i-1 i

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Osionia l Enclosure 1 (Cont'd)

I (b)(1)(vi) Any event that posesa'n actual threat to the safety of the y

~ nuclear 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 re. leases, or radioactive releases. ,

1

NOTE:

Refer also to 50.73 (a)(2Nx) -

II. Four-Hour Notification Requirements (b)(2)(1)

Any event...found..while.the. reactor is shutdown. that, had it l 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 I unanalyzed condition that significantly compromises plant

( safety, t

s  : ._--------

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 Protection 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)(tv) -

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, Enclosure 1 (Cont'd) t' (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 sh'utdown 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)

I (b)(2)(1v) (A) Any airborne radioactive release that exceeds 2 times the applicable concentrations of the limits specified in Appendix 8. 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 exceeds 2 times the limiting combined Maximus 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. (Immediate notifications made

~

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, ' Enclosure' 1 ~ Icon't'd)

,s under this paragraph also satisfy the requirements of paragraphs (a)(2) and (b)(2) of subsection 20.403 cf

, , Part 20 of this chapter.)

NOTE:

Refer also to 50.73 (a)(2)(v111)(A)(B)

(b)(2)(v)

Any event requiring the transport of a radioactively contaminated person to an offsite medical facility for treatment.

(b)(2)(vi) Any. event or situation, related to the health and safety of the public or onsite personnel, or protection of the environ-ment, for which a news release is planned 'or notification to other government agencies has been or will be made. Such an event may include an onsite fatality or inadvertent release of

{ radioactively contaminated materials.

4 e

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Enclosure 2 -

_~

10 CFR 50.73 Reports '

(a.)(2)(1)1 (A)

The completion of any nuclear plant shutdown required by the plant's Technical Specifications; or (8)

Any operation or condition prohibited by the plant's Technical Specifications; or (C)

Any deviation from the 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 from a Itcense condition or a Technical  :
Spectf1 cation in'an emergency when this action is  :

,  : immediately needed to protect the public health and

safety and no action conststent with license condi- ::
tions and Technical Specifications that can provide  :
apparent. or equivalent protection is immediately adequate  :

( NOTE:

Refer also to 50.72 (b)(1)(1)(A)(B) -

(a)(2)(11) Any event or condition that resulted in the condition ofe th 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 signiftcantly compromises plant safety; (8)

In a condition that was outside the design basis of the plant; or 18.0 FOR USE IN UNIT I ONLY .

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Enclosure 2 (Cont'd)

(C) In a condition not covered by the plant's operating and emergency proce'dures.

NOTE:

Refer also to 50.72 (b)(1)(ll) and (b)(2)(1) I (a)(2)(111) Any natural phenomenon or other external condition 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 powerplant.

NOTE: Refer also to 50.72 (b)(1)(tti)  :

(a)(2)(tv) Any event or condition that resulted in manual or automatic actuation of any Engineered Safety Feature (ESF), 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 not be reported.

NOTE:

Refer also to 50.72 (b)(1)(tv) and (8)(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 cond1 tion; .

(8) Remove residual heat; 19.0 FOR USE IN UNIT I ONLY ~

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.. ... . . ~ ~ ., : ~ - - ~

Enclosure 2 (Cont'd)

(C) Control the release of radioactive material; or  !

~ ~

(D) Mitigate 'the consequences of a'n acciden't.

NOTE: Refer also to 50.72 (b)(2)(111)

(a)(2)(vi) Events covered in paragraph (a)(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 inadequacles. However, individual component failures need not"be reported puriuant'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 at t

  • least one independent train or channel to become inoper-s 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 shutdown condition; (B) Remove residual heat; (C) control the release of radioactive material; or (D) Mitigate the consequences of an at:ctdent.

l l

e 20.0 FOR USE IN UNIT I ON _Y

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OR USE IN UNIT l ONLY -

s'f, ion n

,,n .

Enclosure 2 (Cont'd)

(a)(2)(v111) (A) Any airborne rad.toactive release that exceeded 2 times thit applicable concentrations of the limits specified in Appendix B. Table II of Part 20 of this J l

chapter in unrestricted areas, when averaged over a {

time period of one hour.

(B) Any 11guld effluent release that exceeded 2 times the limiting combined Maximum Permissable Concentra-tion.(MPC)(see Note 1-of Appendix B to Part 20 of l this chapter) at the point'of entry into the receiv-ing water (i.e., unrestricted area) for all radio- l nuclides except tritium and dissolved noble gases. l 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 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 fires, toxic gas i

releases, or radioactive releases.

NOTE: Refer also to 50.72 (b)(1)(vi)  :

t 21.0 FOR USE IN UNIT I ONLY

- - _ . - - ._,.,_y, . , , , . . , . _ _ ._ , .-_,,_.,,_.....,.,.7 _-, ,_ . -e--..-. , m f ra- .-

OR USE IN UNIT I ONLY Esion13

.. . , - ~- - -

Enclosure 3

/' '

, 10 CFR 20 20.402(a)(1)

Each licensee shall report.to the Connission, by telephone, immediately after it determines that a loss or theft of licensed material has occurred in such quantities and under such circumstancas that it appears to the licensee that a substantial hanrd may result to persons in unrestricted areas.

NOTE:
Telephonenotificationshallbemadeviath[hhlSas  :

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

(

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 4

individual to 375 rems or more of radiation; or (2[*Thereleaseofradioactivematerialinconcentrations

. 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 B. Table II of this part; or 22.0 FOR USE IN UNIT. I ON _.Y

s",,on33 FOR USE IN UNIT I ONLY .

"' ' ~ '

s Enclosure 3 (Cont'd)

( ', (3)* A loss of one working week or more of the operation of i

, ,. any facilities affected; or i

(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 event involving itcensed material possessed by the i licensee ttrat 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 exposurs 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"ged 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 500 times the Ilmits specified for such materials in Appendix 8. 'able 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.

23.0 FOR USE I.N UNIT 1 ONLY l

FOR USE -lN ONIT I ONLY s'isionia  ;

Enclosure 3 (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 this 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-Indlyidual 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 required 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 license.

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Revision n Enclosure 3 (Cont'd)

(c)(1) '

In addition to any notification requtred by sub-section 20.403 of this part, each licensee shall make a report in writing of levels of radiation or releases of radioactive material in excess of 11mits speciffed 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.

NOTE:
Written reports are required within 30 days as in  :

10 CFR 50.73.

f 9

e 9 f 9

9 G

e e

N e

9 8 25.0 FOR USE IN UNIT 1 ONLY

OR USE IN UNIT l ONLY

. . .c Osion n .

Enclosure 4 10 CFR 50.36 Requirements

-(c)(1)- Safety 'llalts and Limiting Safety Synes Settings (Technical i Specifications, Section 2.0)

(t)(A) Safety limits for nuclear reactors are limits upon important process variables which are found to be neces-a 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 4

I . 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

untti 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 Ilmit is exceeded. If, during operation, the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting dun the reactor. He shall notify the 26.0 FOR USE IN UNIT I ONLY

~

FOR USE IN UNIT l ONLY s'f,,,,33 Enclosure 4 (Cont'd)

Commission, re' view the matter and record the results of the review, inciuding the cause of the condition and the basis for corrective action taken to preclude reoccurrence. .

(c)(2) Limiting Conditions for Operation (Technical Specifications, Section 3.0)

Limiting Conditions for Operation are the lowest functional capability or pe,rformance levels of equipment required for safe operatton .of- the. facility.. When a.L-1st. ting 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 notify the Commission, review the matter, and record the results of 1 5 l the review, including the cause of the condition and the basis for corrective action taken to preclude reoccurrence.

1 4

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FOR USE IN UNIT I ONLY

FOR USE IN UNIT l ONLY -

=,,o,i3

. ~

~

y Enclosure 5 ,

10 CFR 73.71. Security (a) Each 11censee 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 l

Investigation. The licensee shall also file within a period of fifteen

~

l (15) days a written report to the appropriate NRC Regional Office setting l

)

forth the details and results of the trace l'ivestigation. R (b) Each 11ctnsee sha11' notify-the7NRC Operations Center via the Emergency Notification System 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 commit a theft or unlawful diversion of special nuclear material which it is licensed to possess, or to commit 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 Regional Office shown in Appendix A of this part setting forth the details of the incident.

(c) Each licensee under either a specific or general license shall notify the NRC Operations Center via the 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 physical security system as established by regulations in this chapter, or by the 11,censee's approved physical security, contingency, and security personnel qualification and s

e e 28.0 FOR USE IN UNIT I ON _Y

-- 1044 FOR USE IN UNIT l ONLY s

""' 5 'oa ' 3 '

Enclosure 5 (Cont'd) 4-r

training plans, or by both. '

(See below:)

(1) 10 CFR 73.71 requires notification of the NRC within one hour upon occurrence of any of the following events:

(A) Explicit Threat An explicit threat is information received by security organt-4 zation that an act df theft or radiological sabotage will be attempted.

, (8) Major. loss:of physica.l. security effectiveness. A major loss of physical security effectiveness occurs when security features breakdown which allow unauthorized or undetected access to Vital Areas. i (2) 1 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  ;

i occurrence of any of the following events:

(A) Potential Threat A potential threat is information received by a security i

l organization which supports belief that an act of theft or '

radiological sabotage will be attempted. I (8)

Majorcloss 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 spectfled in either of these plans. It means measures implemented within 10 minutes of an event occurrence that provide,a level of security equivalent to that existing before the event. -

29.0 i

FOR USE IN UNIT 1 ON Y

i 1044

~

aevision i3 FOR USE IN UNIT I ONLY 6 ' Enclosure'5 (Cont'd)

(C)

Moderate loss of physical security effectiveness. A moderate '

loss of physical security effectiveness occurs when. (1) a major loss of effectiveness occurs but is properly compen-sated, (2) security features break down which allow unauthorized or undetected access to Protected Areas,'(3) a breakdown cf 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 specified in a Security or Contingency Plan or, if the event is not specified in either of these plans, it means k 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.

i 30.0

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FOR USE IN UNIT I ON _Y l

- 1044 FOR USE IN UNIT I ONLY -

Revision n Enclosure 6

/'

. Events of Potential Pub 11e 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 51te 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 radioacttve spill, leak _or.. dropped. cask or liner of radioactive material or a plant operational problem which results in an evacuation of a building due to confirmed high radiation or alrbourne radioactivity levels.

) 6.

Personnel have received a radiation exposure in excess of the Federal 1

( limits for the whole body, skin, extremities and critical organs.

7.

Failure of the SPC system and/or the makeup system which results in a

(

loss of RCS pressure and/or level control (as applicable).

8.

Environmental samples, directly affected from THI 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.

./

31.0 FOR USE IN UNIT I ONLY

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Ofsioni3 Enclosure 6 (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,mayheofpubiteinterest.

t O

h 32.0 FOR US$ IN UNIT I ON Y '

1044 jOR USE IN UNIT I ONLY -

aevisia i3 Enclosure 7

(%. POTENTIALLY REPORTABLE EVENT FORM' '

1. Reportable per: 10 CFR 50.72, item:

10~CFR 50.73, item:

10 CFR 20, Item:

10 CFR 50.36, Item:

10 CFR 73.71, ites:

10 CFR 21, item:

2. Time and Date of occurrence.
3. Document Tech Spec Section Violated 4.

Detailed description of event, . plant status, and f amediate corrective 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 Director Manager, Plant Operations PRG Chairman Manager. QA Mod / Ops Manager, Safety Review Manager, Plant Analysis Training Coordinator

\

33.0 FOR USE IN UNIT I ON Y

O 1044 FOR USE IN UNIT I ONLY -

a a tsi a is o

EnclosuYe8

' ~

Public Inoutry Policy '

Control Room Action I..

A. Determine the following Information:

1. Name of Caller:
2. County of Residence:
3. Telephone Number:  ;
4. Date and Time of CaII:
5. 8rtef Description of Problem:

1 8.

Inform the possible. caller that someone will get back to him as soon as C.

Refer to the Onstte Outy Roster and notify the Pub 11c Information Representative of the above situation. '

II. Pubite 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

- Cumberland - 238-9676 Dauphin - 236-7976 Lancaster

- 299-8373 i

Lebanon - 272-2296 York - 843-5111 i

The next working the following: day the Public Information Department shall notify N. Gifford - 8350 S. Levin - 8326 R. Rogan - 8048 J. Thomas - 234-2111 R. Toole - 8005

8. Onsite NRC Office - 948-1155 Other Problems -

1.

Pubite Information Representative should handle the problems on a case basis.

  • l i

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l 34.0 t FOR USE IN UNIT I Oh Y

ATTACIDiENT 3 1044 Raisica 13 FOR USE IN UNIT I ONLY Enclosure 7 POTENTIALLY REPORTA8LE EVENT FORM'

1. Reportable per: 10 CFR 50.72, Ites:

10 CFR 50.73.. ites: -

10 CFR 20, ites:

10 CFR 50.36, item:

10 CFR 73.71, ites:

10 CFR 21, 1 tem:

2. Time and Date of occurrence.
3. Document Tech Spec Section Violated
4. Detailed description of event. p .nlafu9 coucevuSh lant status, and lamedi

. A ,

actions. Attach additional sheets if necessary. Especially, include information which may not be available the following normal work day. -

I .

N SHIFT SUPERVISOR: DATE:

cc: Operations and Maintenance Director Manager, Plant Operations PRG Chairman Manager. QA Mod / Ops Manager. Safety Review Plant Analysis Manager 'INI-1 Manager, Plant Analysis - Parsippany Manager, Plant Training i

i

! (' 33.0 l

o FOR USE 'N UN T 1 ONLY

, 1029 ATTACHMENT 4 Revisicn 14

,. IMPORTANT TO SAFETY

% NON-ENVIRONMENTAL IMPACT RELATED CONTROLLED COPY FOR

, USE IN UNIT I ONLY

' THREE MILE ISLAND NUCLEAR STATION

( UNIT NO. 1 ADMINISTRATIVE PROCEDURE 1029 CONDUCT OF OPERATIONS Table of Effective Pages ksCQj 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 S.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

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m

$tgnature 4 lA

' Date (c'Y-$Y Q Signature ,

Date

& Signature 4-7-t+

Date Document 10: 0025B

. FOR USE IN UNIT I ON_Y UMsioni2 g

THREE MILE ISLAND NUCLEAR STATION

^* UNIT NO. 1 ADMINISTRATIVE PROCEDURE 1029 CON 00CT OF OPERATIONS N

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 PROCEDURE 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 Hanning 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 Personnel 19.0 5.12 Procedural Compliance 20.0 5.13 Housekeeping and Cleanliness 22.0 Ml FOE USE (R UN.h i On!.Y

. FOR USE IN UNIT I ONLY 1029 Revision 12 Table of Contents (Cont'd)

(

Section g 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 s

e r e n

.I FOR USE IN UNlT I ONLY 1029

. Revision 11

1. 0 GENERAL 1.1 Purpose

, The purpose of this procedure is to establish guidelines and requirements for the safe, formal and przfessional conduct 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

( This procedure 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 to assigned responsibilities and to avoid distractions to those operators specifi-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 ERENCES
a. AP 1009 - Unit 1 Organization and Chain of Connand
b. AP 1012 - Shif t Relief and Log Entries l
c. AP 1001J - Technical Specification Surveillance Program *
d. AP 1016 - Operations Surveillance Program
e. AP 1037 - Control of Caution and Dh0 Tags t

e

%, s 3.e0

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FOR USE IN UNlT 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 Employees Working on Electri-cal and Mechanical Apparatus J. AP 1011 - Controlled Key Locker Control
k. AP 1033 - Operating Memos and Standing Onfers
1. AP 1044 - Event Review and Reporting Requirements
m. AP 1032 - Dissemination of Infonnation
n. AP 1008 - Good Housekeeping
4. 0 RESPONSIBILITES
a. It is the responsibility of all members of the plant staff to carry out the requirements of this procedure.

( b. It is the responsibility of the Operations and Maintenance Direc-tor, THI-1 to insure Unit 1 operations are conducted in acconfance 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 operation of the Unit is the highest priority of the plant staff and shall be uppennost in their thinking and
  • actions at all times.
U f'. kIb b kfj.0

. FOR USE IN UNIT I ON._Y 1o,,

Revision 11

- 5.2 Conduct of Al1~ P'ersonnel' I a. All on-duty personnel and supervisors must be aware of and msponsible for the plant status, especially in their imedi-ate area of responsibility at all times.

This includes Shift Supervisors / Foreman being msponsible for the performance of all personnel assigned to their shift who could affect plant safety, reganiless of specialty affiliation. Knowledge of the plant's status must be assured at shift changes by a formal shif t turnover and relief in accortlance with Ap 1012.

b. All operations must be carried out in the highest professional manner with clos,e 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 immediate 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 ar(/ instrumen- l 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 abnormal situations, and report same to the Shift Supervisor / Foreman.

s ,

I Oh {, j Eb-[: (Is.O(l!El l Ch! Y

. FOR USE IN UNIT I ONLY 1029 Revision 11

. f. A pmfessional'and fomal atmosphere will be maintatiied 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 immediate attention of the Shift Supervisor / Foreman for resolution. In this regards, the following rules apply:

1. No reading material of any kind except that directly related to the operation and maintenance of the plant shall be pemitted in the plant except as indicated below,
a. Appropriate reading materia) such as daily newspa-

.pers and text books may be located in designated lunch rooms when these rooms are not used as work g areas or watch stations. This material may be read before starting shif t when arriving early; during lunch b'reaks (if not on shift) and during t.ompany allowed breaks with the Foreman's or Supervisor's specific pemission.

b. No unappropriate reading material such as scandal newspapers, puzzles, or'other distasteful literature will be pemitted in the plant at any time.
c. The 0 and M director shall be the sole judge as to 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

. , ..c . ' - - '

' i .'

(> C L li.'OLjIT rt  !

s *;' 6 I I U !\ - 'I

s FOR USE IN UNlT I ONLY 1,,,

. s

, Revision 11 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 1. sed as work areas or watch stations and pl$yed before starting shift when arriving early; during lunch breaks; and during Company allowed breaks with the Foreman's or Super-

. g. visor's specific permission.

w

~

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 I .

, loitering in this area is prohibited. All personnel 1

except Operations personnel and on duty Shift Technical

^

Advisor must obtain phraission from the Shift Super-visor / Foreman or their d ' signee prior to entering the enclosed area of the Control 'Poom. It is the responsi-s bility of the Shift Supervisor / Foreman to limit the number of people in the Control Room at any time to I

1 insure that operators are not distracted from their

s primary responsibility for the safe operation of the plant and to insure that a professional atmosphere is maintained. *

, g .

.= n...... . . . .

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FOR USE IN UNlT I ONLY 1029 Revision 11 i

G. ' Meals shall not be eaten a t the' Control Console Areas of  !

I (T the Control Room. Operators on duty at that area shall be properly relieved for meals and eat their meals away from the Control Consoles. This restriction does not apply to eating or drinking a single iteu.

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 I

be compromised.

h. Only licensed operators or trainees under their direct control are permitted to manipulate the controls that directly affect the reactivity or power level of the reactor.
1. Trainees shall be pennitted to operate equipment / systems, to 7

l manipulate controls, or to take log readings only under the direct 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

,r. , , . . , , , , ,

! U N V D !' ilB.0 Jis t i i d. , , , si s t. )

FOR USE IN UNlT I ONLY

~

102 ,

Revision 11 equipment in the plant by Auxiliary Operators shall be con-

['

f ducted only on the direct orders of the Shift Supervisor, Shift Foreman, or CR0 on duty at the panel, except in cases of 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 4

dincted by the on-shif t operating craw. Should conlitions <

exist that require non-duty personnel to act without direction from the duty cmw, the individual involved shall be fully

( accountable for such action. The intent of this guidance is not intended to restrict qualified operators from taking

. spy- riate actions in an emirgency situation when such action is clearly required for the health and safety of the public, safety of personnel, or to prevent major equipment damage, m.

All surveillance evolutions shall be conducted in accordance l

with either AP 1016 or AP 1001J as applicable.

n. All switching and tagging operations will be performed in accordance with AP 1002.

I ( 4. ( J h :: ( r9.0 li x*t i O fx!L. Y

FOR USE IN UNlT I ON_Y 1029 Revision 11

, ~ o. ' Independent verification of operatioItal activities affecting (4 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 off-going operator in accordance 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.

3. Following surveillance tests or special operations on ESAS and EFW Systems, two independent valve and breaker lineups will be conducted within the boundary of the system affected by the tests or special operations to provide assurance that the system is returned to full operational status.
p. The Shift Supervisor, Shift Foreman, and CR0 on duty at the panel have the authority, and in fact the responsibility, to j .

order or affect the plant to be shutdown and placed in a safe-l condition or to take whatever timely and proper action neces-sary whenever in his judgement such action (s) is necessary for 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.

i Ois U C Uld O N.:~i i ON LY

FOR USE IN UNtT I ONLY 1=9 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- I sibilites and authority of the Shift Supervisor are clearly delineated in the attached letter from the Director, THI-1 and the President GPU Nuclear Corporation to all THI-1 Shift Supervisors ( Attachment III).

r. The Shift Supervisor on duty shall not be assigned administra-tive or other functions which detract from or are subortlinate to his primary responsibility for assuring safe operation of the plant. The administrative duties assigned to the Shif t Supervisor shall be reviewed annually by the Manager, of Plant Operations and a report thertof submitted to the Operations 7

and Maintenance Director, T}ll-1 cnd to the Vice President, TMI-1 for their review and approval.'

s. Operators on duty should not normally be assigned other responsibilites or work which interferes with their primary responsibility for the safe operation of the plant.

l

t. Shif t Supervisors, Shift Foremen and CR0s shall wear the special clothing provided by the Company while on duty. Other members of the plant staff shall we'ar neat and clean clothing as appropriate for their assigned responsibilities. No open l toed shoes, sandals, or excessively worn or tattered clothing will be permitted. Personnel shall be well groomed and neat .

in appearance as befitting their position of responsibility j i

for the proper and safe operation of a nuclear power plant.

s i

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l ( )lN ;, Y

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FOR USE IN UNlT I ONLY 1ozg Revision 11

., 'u. Before acknowledgirig or resetti'n g an alarming annunciator, the l

-(' operator shall have read or have knowledge of the annuncia-l I

tor's window nomenclature and verified no other alars came in coincident with the alarm being acknowledged.

5.3 Communication on Shif t

a. Communications 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 i the operator acknowledge the direction so the director is satisfied that the orders are understood. Upon completion of the directed evolution, the operator shall report back to the

,. controlling station the exact action that he has taken.

Whenever possible, the individual oniering 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 communications both face to face and by page, radio, phone or other means are essential for all operational functions.

b. Whenever possible, comunications for major plant evolutions 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 normally be used by operating .

personnel to announce emergencies, unexpected events, to relay information regarcing plant status and, where not possible by direct phone comunications, to direct actions in the plant, e ., ,

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FOR USE IN UNIT I ON _.Y 10,,

Revision 11'

.j d.

Routine communications to personnel in the Control Room shall I be conducted by the regular dial telephone system, when availabl e.

e. When answering a telephone, the location, 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 syst'em. '
g. Horseplay or unofficial use of the plant paging system is a serious breech of discipline and good order and offenders will be dealt with accordingly.

5.4 ' Relief Procedures and. Briefings e a. At shif t change a fonnal shif t relief shall' be accomplished 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, Plant Operations, Shift Supervisor, Shift Fore-man, or CR0 prior to conducting critical, complicated, unusual or infrequent operations.

5.5 Component Labeling and Signs

a. Personnel shall not independently 1abel p1 ant components or systems or post signs. Labeling of components or systems and signs shall be in accordance with an approved procedure, ECM, Work Authorization Notice or by the explicit authorization of T (I, s ,d n.

DE~ ff,i3. I\ I I M,.: L-

FOR USE IN UNIT I ONLY 1o,,

Revision 11

, the Manager, Plant' Operations. Energency posting of areas for I safety purposes or operational limitations with t'emporary 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, acceptable mylar or " bakelite". Labels and signs shall be appropriately fastened so they do not become unattached.

Handwritten lables and signs are not permitted in the plant except where specifically authorized by procedure, the Mana-ger, Plant Operations or his designee.

c. When a permanent. 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 affected controlled drawings. Technical Functions will also obtain the revised label and provide the installation package to the field.

5.6 Working hours and overtime regulations for personnel performins 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 permission must be obtained from the Opera-e -

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FOR USE IN UNIT I ONLY g29 sion 12 tiens'and' Maintenanc , Director', THI_1 and the Vice Presiden't, I THI-1 to deviate from these requirements.

Plant > 200*F RCS Temoerature Plant <200*F RCS Temeerature 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)

S Auxiliary Operators 4 Auxiliary Operators 1 Shift Technical Advisor NA

  • May be waived by the Manager, Plant Operations THI-1. Either a quallfled 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 Operator qualified  :
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 i 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 RO's on shift cannot be adhered to on a six shift rotation utilizing qualified licensed personnel within the organization the Manager of Plant Operations shall immediately inform and discuss the situation with the Director THI-1, the 0 and M Director TMI_l, 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 shift rotation for ten consecutive days.

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FOR USE IN UNlT I ONLY EMsion12

., e'. All tr'adiafed r fue'l ha'ndling 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 Coiltrol Room Operator's Log 7-Sheet for each shift.

5.8 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 speci- ,

fled in AP 1013).

8 e ,

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FOR USE IN UNIT I ONLY g27,,,n,,

~

, 4. Instrument Out of Service Log Book (Requirments specified

( in AP 1036).

5. .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.

8 l

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- FOR USE IN UN(T I ONLY sUsioni2

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, S' .10' Incidents Occurring on Sh1'ft 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 i 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  : i
properly relieved.  :

\

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FOR USE IN UNIT I ONLY Mston12 l

, 'b . Notify personnel'/outside agencies as specified by AP 1044 f or the Emergency Plan,

c. S'ubmit Reports:

- AP 1044 Form (Potential Reportability)

P 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-1 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 incident reports will be sent to the Vice President, THI-I and to the Operations and Maintenance, Director, THI-1. Coples 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.

FOR USE IN UNIT I ONLY s#sion12 5.12 Procedural Compli~ance Compliance with approved procedures is absolutely essential

([ a.

. 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 I 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 l

parts of a procedure are to be fol' lowed literally, the inclu-ston 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 i

i and further direction.

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FOR USE IN' UNlT I ONLY E*Isioni2 l 1

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If an' individual cannot or believes he should not follow a

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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 has been revised, approved, and/or reissued in accordance with current administrative controls.

AP 1001G gives specific guidance on procedure usage and latitude allowed for procedure compliance.

g. Supervisory personnel are responsible 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, procedure users often identify but feel inhibited to suggest changes to procedures based on:

(1) Problems identified during use (2) 'nconsistancies i between procedures (3) better ways to perform an evolution (4) a good practice that would increase the effec-tiveness of efficiency of an evolution.

U h U E i. lN29;q;; gNLy

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 "us'er" 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 100lG.
h. Nothing in the above guidance is intended to restrict person-nel from taking immediate actions to prevent or correct an unsafe or cas.ualty 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 procc-dures. Under such circumstances, the individual involvea 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 Manager, Plant Operations, or if he is not available, the Duty 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.

i DR Ubh IIsi2WNil i O!si N t

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FOR USE IN UNIT I ONLY

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. b. Clean 11 ness'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 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 the generation and spread of radioactive contamination.

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FOR USE IN UNlT I ONLY

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disioni2

, c. Operations and Maintenace' supervisors are responsible for m

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 defic'encies 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 Director.

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:

a. Switches, breakers must be independently checked by two (2) separate personnel visually sighting these components in the proper position. Remote light indicators are acceptable where supplied for verification use. If this verification is being performed after the completion of a Surveillance Test, the 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.

g k

1029 aevision 12 FOR USE IN UNIT I ONLY

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

/.ny time a plant component is found out of its proper plant re -

quired position, the following procedure will be followed:

a. Personnel finding a component out of position will notify the Shift Supervisor / Shift Foreman immediately.

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FOR USE IN UNlT I ONLY

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io29 Revision 12

+ b. The Shift Supervisor / Shift Foreman shall evaluate plant / system

. , ~,

conditions to' determine the appropriate position of the component in 'questiori. 'If it sl' actually out of position, the 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

(.I 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.

, , , , . . . ,. .. ..,g i '(,./ h ;d D C. (fy,6.N N I I I "'

. i FOR USE IN UNlT I ONLY 1029 Revision 11

. ATTACHIENT I l TITLE

)

)

PLANT INCIDENT REPORT NO.

DATE TIME OF INCIDENT Plant Conditions Sequence of Events Environmental Impact Personnel Safety Impact Discussion Conclusion Items Incormet/ Lessons Learned Corrective Actions ,

SUBMITTED APPROVED cc: Vice President, TMI-1 Operations and Maintenance Director, TMI-1 PRG Chainnan, TMI-1 Operator Training Manager

- Licensing Department Manager, Safety Review, THI-1 Training Coordinator, TMI-1. , ,

P U h I, I D C ' l 2 7.' 0 LlN.i I\ .i i Olsll N-4 ,._, _ ._. _ _ _ _ _. ____ - - -

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1029 Revision 11

, IT'TACHIENT II PLANT INCIDENT REVIEW ATTENDANCE REPORT PLANT INCIDENT REPORT NO.

Crew Briefed Briefed by Date/ Time Personnel in Attendance Personnel from Crew needing Briefing NME DATE C0ffLETED SIGNATURE

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s 1029 l Revision 14 l

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GPU Nuclear Corporation 4UClear d8 25lteZ's'ouk Middletown. Pennsylvania 17057 ,

/ 717 944 7621 l TELEX 84 2386 Writer's Direct Dial Number:

File: Procedures /

Policies l l

. 3000-84-096

)

March 2,1984 TO: TMI-I SHIFT SUPERVISORS l

SUBJECT:

COMMAND 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 responsibility on those who manage and command operations at the l 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 safe operation 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 responsibility and the command authority over all shift operations, and maintenance activities, and implementation of radiological controls under normal 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 operation 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 subsiciary cf tne General Public Utilities Corporation 29.0

-- ~ - , - - - -w-

~

1029 Revision 14 March 2, 1984

3000-84-096 7~ .

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 abnormal 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 information.

. 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 information 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 informed 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 ycur management role to maintain a comand i 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 p10nt systems and components under normal, off normal, and accident conditions.

This letter replaces and supersedes our letter to you, same subject, dated May 25,1983.

1 M.

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 TMI-I CARIRS - TM1 30.0 '

,4 ATTACIDENT 5

.  ; [w1Nu Elear li ,

._. . -mt. n i Tette . Revision No Trainee Evaluation Once Back on-The-Job 0-00 Apobcabilety Scope Responsible Office I All Training and Education Departrent Personnel Educational Cevelecaent This cocament is impcrtant to safety C Yesd(No Effective Date List of Effective Pages Pace Pevision

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1.0 C-00 2.0 0-00  ; . . _ ,

3.0 0-00 a.0 0-00 5.0 0-00 E1 -1 0-00 E1-2 0-00 El-3 0-00 E2-1 0-00 E2-2 . 0-00

E2-3 0 00 l

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ll Signature Concurnng Organizational Element Date Originator Mm) ,dEG l Educational Dev. Coordinater, TMI ; g j, 77 concurrec by,pd gi)h_Mt4p l Manager, Cowau Mid@ i ,,-7 , E h

anace". Diant Traininc I O //t[#r-

[ v/  %[Mf/)Y.Td y 3 I vj Manager, Plant Train 1nc - i".i nC l g /, A-l h / I I j;  !

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(([h' l Director, Traininc A Education l_f-/f M AQOC10$1 39.

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Nuclear TRAINING APO EDUCATICN CESARTNENT eR0caAs ceva0 MENT sam a00 4 s-2 a 2.10 Title 8**"N'-

Trainee Evaluation Once Back On-The-Job 1

1.0 RJRPOSE

The purpose of this procedure is to establish a process to evakata training program effectiveness by collectina feedback data from trainees and their swervisors when training is completed and they are back on-the-job.

2. 0 APPCICASILITY APO SCDE:

2.1 This procedure has GPUNC wide applicability.

t'

2. 2 This precedure will becme offactive upon the date of publication.

3.0 DEFINITICNS

3.1 Survey - a detailed study or inspection, as by gathering information through observations, questiennaires, etc. and analyzing it.

4. 0 PmCEDUE:

l 4.1 In order to evaluate the effectiveness of training, data shall be collected from trainees and their swervisors when the training is ccmpleted and the trainees are back en the job.

4.1.1 The Manager of Training shall determine which specialty training courses and/or training programs' trainees are to i

be evaluated in accordance with this procecure.

4.1.2 The Manager of Training shall spooint a person to act as evaluator to collect this data for the training programs conducted at the site.

4.1.3 The evaluator should conduct the surveys frem 4 months to 10 months after training is c:npleted for trainees coming out of initial programs using one of the methods outlined in 4.3.

4.1. 4 For. recpalificatien/ cyclic / refresher training the evaluator shall take a periodic samling of qualified job incumbents using cne of the methods outlined in 4.3.

E 4.1.5 Recnired reviews will be added to appropriate program 5 descriptions.

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, , 05 20 5=  ; ::10 - :c.00: s-TRAI Numow Nuclear e x NINGae APO m AMENT EDUCATION

- CEPARTMENT 622-o-26e2.10 Title Trainee Evaluation Cfce Back On-The Job M*v*on No- 1 4.2 Trere are 5 questions that the evaluator should address:

- How do snployees rate the effectiveness of training?

- How job-Islavant do amployees find training?

- How well is training timed to meet actual job demands?

- What specific tasks require more emphasis curing training?

- What tcpics require less emphasis?

~. 4. 2.1 The questions that are asked of trainees and st.pervisors should support these five areas.

4.3 The evaluator shall accomplish data gathering using any cne of the four methods listed below.

4.3.1 In Person Interviews are the most reliable of the survey methods, cecause the evaluator, acting as interviewer, can pursue particular responses. There is less crance of misinte greting a response.

4.3.1.1 The questions fot.rld on the interview forms, Exhibits 1 and 2 are appropriate for in persen interviews.

4.3.1.2 Explain to the trainee or swervisor the pumose.of the interview.

4. 3.1. 3 All responses shall be sumarized on the inverview form.
4. 3.1. 4 All interviews shall be cenducted in a quiet and private area, i 4. 3. 2 Telechone Interviews are also a reliaole means of gathering data.

4.3.2.1 The questions foi. rid on the inte: view forms, Exhibits 1 and 2, are appropriate for telephone 5 interviews.

Explain to the trainee or sucervisor the

( 4.3.2.2 j ,

pumose of the interview.

5 3

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l l 0570G:02 3.0 acccieso n.s:

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Nuclear TRAINING APO macam ceva. EDUCATION cmENr ma DEPARTMENT am-a-ue2.10 i

rios Trainee Evaluation Once Back On-The-Job Rewmen No.

1

4. 3. 2. 3 All responses shall be summarized on the interview form.

4.3.3 sailed questicnnaires are the least desirable method of data gatnering cecause the interviewer dces not have the ability to question the trainee or st.cervisor concerning vague or ambigtcus responses. However, a mailed questionnaire can be followed up with an interview. Mailec questionnaires are a gccc means of gathering data when time or other job ccmmitments are a censideraticri.

4.3.3.1 When using a mailed questiennaire, a cover letter frem the Training and Educatim Cepartment should be included. This letter shculd:

explain the purpose of the questionnaire giw clear directions including where the questionnaire should be sent upon comisticr1 solicit the individuals help thank the respondent for his ti.me.

4.3.3.2 The questions found on the interview forms, Exhibit 1 and 2, are appropriata for mailed questionnaires.

4. 3. 4 Recuired reviews ccmpleted by the siservisors of trainees once eack on tne job is another method. If a required rmview it wiected then the frequemy of ccministratien shall be determined by user gret.p managment and Trainirq and Education Capartment.
4. 3. 4.1 A list of specific duties desigrec for a specific joo classification may be developec and used with Exhibit
2. This list can. serve as an aid to the persen performing the evaluation. This list srculd be incorporated as an attachnent in the particular training program's Prcgram Oescripticn.

n .

y 4.4.5 Trainees in the same training session should be surveyed in

the see menner.

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0570G:02 4.0 ^ o00 ' C H "

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l TRAI Numeer Nuclear a c =NING AtO EDUCATION OEacmeNT == DEPARTMENT 6200- o -26e2.10 rio. Trainee Evaluation Once Back On-The4cb Mov*en No. 1 4.4.1 The following information shall be included on all types of surveys:

Name (optional for trainee)

. Title Date of Survey Dates of Training Name of Training Program Evaluator Type of Survey I

4.5 All data should be reviewed and analyzed and a summary report 1 prepared which summarizes the significant firdings and reemmendations for improvement.

4.5.1 Supervisor and Trainee informatien should be czpared to discover inconsistancies.

4.5.2 Trainee infornation should be c:rnpared to the indiviial's course or program performance.

4.5.3 Requests for modifications to training based en these surveys shall be forwarded to the accropriate training management for consideraticn by the Technical Content Review and Interface Process. (See 6.2) l 4.6 The indivi&al evaluations will be kept in the Training 0 apartment for a period of 3 years. The purpose of the retentien will be to review the evaluations for trends in recorded training recormandaticris. Emerging t: ends will be used as input to revise l

and/or u::date trainirg. A review cf remedial help will be made for those individuals exhibiting isolated training needs.

5.0 RESFCNSBILITIES

5.1 Director, Training and Education is responsible for develcoing ano i

todating this procedure end for assisting GPUNC Divisions in its implementaticr1.

5.2 Manager of Site Training:-

5.2.1 Determines which specialty training courses' and/or

training procrams' trainees are to be evaluated.
5. '2. 2 Appoints a person to act as evaluator for this precedu:e.

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1 0570G:02 5.0 ^cocicaci' u

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TRAINING AlO EDUCATION DEPARTMENT Nmw ENuclear m0 cans Dev ac,uENT M4Nurt Trainee Evaluatien Cnce Back On-ThedCD 6200-ics-2682.10 Revision No. 1 Title j 5.3 This prcgram st.pervisor or manager shall effect liaison with the user grets swervisors to: '

5.3.1 Allow and encourage the employees who have recently empleted training programs to ccoperate with the evaluator in collecting the data outlined in this precedure.

5. 3. 2 Complete surveys on their ernployees who have recently cermleted a specialty training course and/cr training program.

5.3.3 Assure that required reviews are empleted, ferwarded to Training, a surmia report prepared, and recomendations for revisions comp.e*ad.

6.0 EERENES

6.1' Training and Education Department Training System Develcpment Process, 6200-ADH-2682.01 6.2 Technical Content Review and Interface Process, 6200-ADM-2682.03, 6.3 Evaluatino Training Programs, Ccnald L. Kirkcatrick, Madiscn, Wiscensin: American Society of Training and Deve1coment,1975.

7.0 ATTAC M S:

7.1 Exhibit 1 - Trainee Survey 7.2 Exhibit 2 - Supervisor Survey l

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.i 0570G:02 6.0 Acco'oec'i a:

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Exhibit 1 Rev. 1 l

GPLN TRAINING APO EDUCATION 05/16/85 Pqe l of 3 TRAIEE SLRVEY l

Nene:

Title:

Todays Cate:

Dates of Training:

Instructor: Nane of Trainirg Program:

Method of survey:

Mailed questionnaire l_1 In person interview l_l Telephone interview l_l 1

l Yes No

1. Have you received additional training since l being assigned to your job?

(_l l_l If ye% ple n a explain:

Yes No

2. Have )cu experienced unegected difficulties or problems in job perfomance?

l_l l_I If yes, please ilxplain:

El-1 0570G:02

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Exhibit 1 Rev. 1 05/16/85 Pqe 2 of 3 Yes No

3. Has your stcarvisor given you instructions _ _

different from those you learned during training? l_ l l_l If yes, please

! explain:

4 Have you noticed other differences between Yes No the trahling you received and what is _ _

expected of you now? l_l l_I If yes, what are they:

Yes No

5. Have changes occurred in your jcb since _ _

you were assigned? l_I i,_i If yes, what wars they:_ _

If yes, how were you prepared to handle these changes?:_ l El-2 0570G:02

a:n c."*

. ;3 a 35 4. X:

Exhibit 1 ,

Rev. 1 05/16/85 ,

Pge 3 of 3

6. What tasks do you find the easiest?
7. Which tasks do you find especially challenging? __
8. What specific training benefited you the most?

l Yes No j 9. HaveIerrors been conmitted on the job? l_l l_I L

l- If yes, what were they?

10. Hcw could training better have precared you for your job?

l l

11. What suggestiens would you make to improve training?
12. What additional training do you need for your jcb7

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t El-3 0570G:02

GPUN TRAINING AND EDUCATION SUPERVISOR'S SURVEY Exhibit 2 Employees Name:

Title:

Today's Date Dates of Training or Trud '1g Cycle Supervisor: Name of Training Program:

(Requal or Initial)

Method of Survey

1. Mailed Questionnaire i I
2. In-person Interview l l
3. Telephone Interview l l
4. Required Review l I (Requires signature of supervisor and employeel
1. What tasks is this employee best prepared to perform?
2. What additional training has the employee received since he/she was assigned job responsibilities?

1 .

3. Is this employee able to diagnose conditions and identify alternate solutions for accomplishing a task?
4. Have you observed unexpected results from Training? If yes, describe those results.

J

.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.
18. Has this employee's training prepared him/her to locate, use and properly applicable procedures (Operating, Administrative, Maintenance, Surveillance,etc.)? If not, describe circumstances.
9. Has this employee's training prepared hirVher to properly maintain the records and documentation associated with his/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 cognizant. If not, describe deficiency.
11. Has this employee's training prepared him/her to be able to comply with government and company regulatior.s applicable to his/her position? If not, describe circumstances.
12. Which tasks require excessive time for this employee to complete?
13. What kinds of _ errors-has' this employee committed 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 t' raining for this individual created the need to identify additional training? If yes, describe those needs.
17. Based on your observations, what suggestions would you make to improve initial or requalification training.

Supervisor's Signature Date Employee's Signature Date 5

ATTICHMENT 6 Proposed Attachment to Initial ard Requalification 10 Training Program IMscriptions 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 bock.

-Knowledge and use of plant procedures.

Knowledge / Adherence /Use of Administrative procedures.

Maintenance of shift records.

Use of communications equipment.

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% Proposed Attachment to Initial and

)

Requalification S10 Training Program Descriptions Areas for Evaluation Senior Reactor Operator: Normal 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 LOO 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 systent.(Met-Ed) switching and tagging. '

Communication, knowledge and implementation of system dispatching requirements.

Knowledge and adherence to NPDES permits.

Maintenance of shift foremen log book.

Knowledge, use and coordination of plant procedures.

l

- - , _.s. -.. - - - -.m- -.

j .-

'A.

b Knowledge / Adherence /Use of Administrative procedures.

Use of communication equipment.

Control ~of plant chemistry.

Conduct of audits to insure compliance 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.

e l

l l

ATTACHMENT 8 c

Fwessed Change to THI-1 Replacement Operator Training Program Description (RO) l l

Change paragraph 7.8.1 as follows* '

l

f. Regularly scheduled participant critiques (including once  !

on-the-job per 6200-ADH-2682.10). The completed evaluations  !

shall be forwarded to the Manager of Plant Operations THI-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 TMI-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".

{ 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 l (section 7.3.5).

l l

Change paragraph 7.7.1 to read- I At the conclu:1on of each phase of training and once on-the-job 'for

. approximately six months.

l Proposed Change to THI-1 Senior Reactor Operator Training Program Description (SRO)

Change 7.9.1. to read:

At the conclusion of each phase of training and once on-the-job for approximately six months.....

1 (

l

4 Change 7.6.1 to read as follows:

f. Regularly scheduled part tipants 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 l Training Manager who will also review and comment as appropriate. l

~,e documents wf11 then be transmitted to the Supervisor of Licensed Operator Training who will prepare a summary report of I all of the observations and recommendations made by the i 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 i review the scope of the summary report and determine an appropriate course of action for each of the recomendations.

Tie meeting shall be conducted consistent with the TSD Procedure, 6200-ADM-2682.03, " Technical Content Review &

Interface Process".

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)

Proposed 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, Riant Operations shall provide the Supervisor, Licensed Operator Training or the Operator Training Manager with periodic observations identifying job performance results related to  !

requalification. The completed evaluations shall be forwarded to the Manager of Plant Operations THI-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 coment as appropriate.

n . -

O 1

( 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 l Training Manager, and Manager of Plant Operations TMI-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-ADH-2682.03, " Technical Content i Review & Interface Process".

{

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 B. 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.

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ATTACHMENT 9

)

I gf Training and Educatit , i s Program Davalopment Manual l6200-ADM-2682.03 Title Revision No.

GPU Nuclear - Technical Content Review & Interface Process 0-00 Applicanality! Scope Responsible Office

"" l All Training & Education Departm'ent Personnel yefo'p ne This document is important to safety KYes:3'No Effocove Date List of Effective Pagee PAGE REVISION 1.0 0-00 2.0 0-00 3.0 0-00 4.0 0-00 i _

Signature ., Concurnng Organizational Element Date Onginator [4M Educational Development Coord. 3/jf/fg Concurred O(M g h / h [ .d 4 fanager Corporate Training J . //. [f

'y p Q g panager Plant Training - OC g//gg p y g ,} g Manager Plant Training - TMI J/ffgj l

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!! I Approved Dy M Manager Educational Development 3.fla8[

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62Co- a -2se2.c3 Tiue .

Revision No Technical Content Review And Interface Process 0-00 1.0 P'urp6se 1.1 The purpose of tnis procedure is to establish a process for the technical content review of training materials and assure an ongoing interface between the Training Department and the user groups.

~

2.0 Applicability and Scope:

2.1 This procedure has GPUNC wide applicability.

3.0 Definitions

3.1 User Department - That department responsiole for the personnel ceing trained.

4.0 Procedure

4.1 Each site training section shall establish a technical content review mechanism for each functional organization on site that is supports.

4.1.1 The interface group shall be made up of key personnel in the Training Department and the user group.

(

4.1.2 The Training Department and functional organizations shall provide qualified personnel to serve in the group; including Technical Functions, Rad Con / Environmental Control, and Energency Planning as appropriate in the review and approva1 process.

4.1.3 Other interested personnel may be invited to participate in or observe the process.

4.2 Purpose of content review process 4.2.1 Verify the need for instruction by:

- Reviewing task analysis

- Assessing training needs resulting from job performance of l

@ programs' graduates.

2

- Identifying current and emerging needs (technology, job scope,,

i

~ etc.) '

2 I

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ic::t:s: .e:

1591c 2.0

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.Numer Training and Education Cest.

UlNI Program D:velopment Manual 6200-ADM-2652.03 Tiue Revision No

-Technical-Content Review And Interface Process 0-00 r

- Reviewing'needs analysis-

- Interpreting new developments in the fielo

- Supporting, when required, Training Department budget request 4.2.2 Verify content of the course by:

- Selecting tasks for training

- Determining where in the program the task should be taught, (Classroom, OJT, simulator, etc.)

- Reviewing training and performance standards.

4.2.3 Provide Service to the Trainino Department ano User Groucs by:

- Assisting with long-range planning

- Serving as speakers to management if neecec.

- Developing / reviewing and recommending to management the screening standards 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 instructicnal programs. Refer to procecure -

Program Evaluation For Process, 6200-ADM-2682.ll; and Course Evaluation, 6200-ADM-2682.12.

4.3 Each group shall determine the frequency of its meetings. Nothing in this procedure is meant to ciscourage the frequent individual activities ano interfaces between training and the user organizations. The company recognizes that these are vital to the proper development and implementation of high quality training programs.

= 4.4 When appropriate, a written agenda should be prepared prior to the meeting.

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A0001C50t1 5.

1591b 3.0

Nuclear Training and Education Dept.

Prog,am Deve1 nt M.nue1 o00. .u n.03 7,g Revoon No.

Technical Content Review And Interface Process 0 4.5 Minutes shall be kept and distributed to appropriate personnel to include 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 CoGorate l Training Department in its implementatirsi.

5.3 Division Directors are responsible for implementing this procedure and for complying with its requirements )

6.0 References '

1 6.1 Training and Education Department Training System Development Process, 6200-ADM-2682.01.

6.2 Program Evaluation For Process, 6200-ADM-2682.ll.

6.3 Course Evaluation, 6200-ADM-2682.12, 7.0 Attachnents NONE 0

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A000106011I82 1591b 4.0

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MTfACHMENT AU Nuclear

~

S o S AM E i~0PMENT PANUAl.

6 0 h0"-2682.01

. Title Training & Education Department Training'5,vstem Revision so.

Development Process 0 -00 Applicability / Scope Responsible Office All . Training & Education Department Personnel Educational s Develoament This document is important to safety 0 YesONo Effective Date Paaes Revision Paaes Revision 1.0 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 8.0 0-00 9.0 0-00 10.0 0-00

~

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.b 0-00 19.0 0-00 El -1 0-00 E2-1 0-00 E3-1 0-00 Signature Concurnng Organizational Element Date

! 0"9'nator L,, j] L b Manaaer, Educational Develooment

- 3 J5" Concurred bh fjp ,f,,,,, , Manaaer, Corporate Training J 27 ,yI~

I 7 d.M M N.C f f j u Manager, Plant Training - OC 3, AS. P s '

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c'75D Manager, Plant Training - TMI if.:_c , -/

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Director, Training & Education Jpg 7

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1.0 m oiest a.e

ENuclear , TRAINING & EDUCATION DEPARTMENT PROGRAM DEVELOPMENT MANUAL 6200-ADM-2682 Tiue TSD 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 3.2 User Groups 4.0 3.3 Needs Analysis 5.0 3.4 Job Analysis 5.0 3.5 Task Analysis 5.0 3.6 5.0 Training Analysis 6.0

3. 7 Training Standard 3.8 7.0 Program Descriptions 1 7.0 3.9 Lesson Plans 8.0

( 3.10 Trainee Text Material 8.0 3.11 Evaluation 3.11.1 8.0 Evaluation during Development 8.0 3.11.2 Pilot Evaluation 9.0 3.11.3 Trainee Evaluation (while in training) 3.11.4 9.0 Instructor Evaluation ~

9.0 3.11.5 Trainee Eval'uation Back On The Job 9.0 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 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 4.3 Needs Analysis 12.0 2 12.0 4.3.1 Request for Training 12.0 5 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 0 13.0 3

S

, A0001050tt 2.0 054T

- Numoer ENugpyRf yeeayANUAL TRAINING & EDUCATION DEPARTMENT ,

6200-ADM-2682

~

Title TSD PROCESS Revision No 0-00

{

m TABLE OF CONTENTS (Continued)

Page 4.4 Job and Task Analysis (JTA) 13.0 4.4.1 JTA for Job Position Training 13.0 1 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 l 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 1 4.8 Lesson Plans 15.0 4.8.1 Variation in Lesson Plan Formats 15.0 4.8.2 Lesson Plan Guideline 16.0 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  ;

5.0 RESPONSIBILITIES 17.0 i

5.1 Director, Training and Education 17.0 1 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 m

7.0 ATTACHMENTS 19.0

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A0001050 3.0 0549;

ENu9lqtggg/pggg=ENT

. Numb;r g, " ' " ~ ~ ~~

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Revision No.

TSD PROCESS 0-00 1.0 PURPOSE The purpose o'f this procedure is to establish and describe the process used for developing training programs by the GPU Nuclear Corporation's Training the department and Education by vendors, Department and for specified l

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.

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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 3.1 Training System Development (TSD) process is the systematic appr 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 TSO.

Exhibit 4 shows the organization of the procedures and guidelines of the TSD process. l b

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,The steps in this overall process and their locations 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
4. 4 Job and task analysis l 4.4
4. 5 Training analysis 2 4.5
4. 6 Training standards 4.6 4, 7 Program description 4.7
4. 8 Instructional process I 4.8
4. 9 Lesson Plans 4.9 4.10 Trainee text materials I 4.10 4.11 Trainee examinations l 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.

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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.

! 2 Training analysis is treated broadly in the Task Analysis and Training 5 Standard Guidelines.

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3.' 3 Needs 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 limits. 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 personnel performance.

3.2.2 Needs analysis is generally initiated through completing a Request for Training Form.

3.4 Job analysis is the process of evaluating data regarding the tasks and conditions of a job. It provides an objective-data base of job-related information from which training programs are developed, based upon how the job is'actually performed.

3.5 Task analysis is the process which examines individual tasks to 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 related importance, frequency of performance, and the relative 3 number of job incumbents who perform the task. Task analysis data 3

are then evaluated to decide which tasks must be included in the f initial and/or ongoing training programs. This last step is j; generally considered to be a part of task analysis.

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3.6 '~ Training 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 program forms the complete Corporate Training Standard document. The training standard may be either a generic document or a generic with site-speci fic appendices.

3.8 Program descriptions provide important need-to-know information to the instructor as well as anyone else with a special interest in the course. It is divided into several sections and typically includes 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.

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3. 9 tesson Plans are teaching glides 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 summary 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 t

evaluation:

3.11.1 Evaluation during development - The first phase of program evaluation is conducted during the development of a new training program. This phase provides a quality control function to ensure that each program document or 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.

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, 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 needed in content, structure, or sequence. In those cases wt.ere a tradition pilot cannot be run, a careful

.C.me 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. Feedbackisprovidedto{

all critically involved training personnel to include I 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 evaluation. It focuses on the capability of the former 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 required performance after training.

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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 performance-oriented 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 Aid training will need to be evaluated. The formal 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 k 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 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 selected from segments of the GPU Nuclear Corporation collectively to ad. vise the Director of Training and Education. This advice

centers on broad matters pertaining to the improvement of training
programs.

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3.13 dechnical 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 systematically derived from Job / Task and training needs analysis 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 the classroom environment into the workplace by providing an opportunity to apply previously learned skills and knowledges and to acquire new job skills and knowledge while actually working under

, controlled conditions. It provides an opportunity for the trainee to benefit from the extensive background and experience which is held by the job supervisors in a formal, structured manner.

3.15 Guideline - a document which provides information for general y consideration in performing a task. It is not intended to establish

[; requirements.

$ 4.0 PROCEDURE 2

3 4.1 A Training Advisory Council shall be established in accordance with

5 6200-ADM-2e82.02, Training Advisory Council Procedure.

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Within each site training organization or eech major training program, a technical content review rend 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 solution. Or, cerporate comitments, outside regulatory requirements, etc., might be initiated that may have an impact on new or existing training programs. These observations /comitments can be brought to the attention of those individuals within the training or Human Resource functions who have the responsibility to evaluate their significance and respond accordingly. '

4.3.1 If it is determined that there is a performance problem, comitment, etc., then training needs analysis shall be performed in accordance with 6200-ADM-2682.04, Request for l Training. l 4.3.2 If the Manager of Site Training determines that the problem /comitment is found to be a major training need, requiring either a new course / program or significant  !

modification 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 h Coordinator may be appointed from the Educational Department 5 section. (The term project coordinator is used in this 5

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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. ,

4.3.4 If a pragram or course currently exists but is found not to be effective, then modification (s) shall be made to the appropriate documents (task analysis, training standard, lesson plans, trainee text materials and examinations) to correct the concern.

l 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 I

conjunction with the Manager, Educational Development or the Educational Development Coordinetor shall decide in which category the program belongs and choose one of the following options:

4.4.1 If the needed program is for qualifying an individual a job g

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 3 Manual.

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TSO PROCESS 0 00 4.4.2 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 1

process described in 6200-ADM-2682.03, Technical Content Review And Interface Process Procedure.

4.4.4 The Project Coordinator shall create a development file for keeping all important documents pertaining to the developr.. ant of this program.

4.5 The Project Coordinator shall ensure that ident 'ied 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 2 approval.

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,4.5.2 A training program may be submitted for INPO Accreditation before and separate training standard document is developed,.

l if Training Control Record fonns (TCR) exist for all lessons l that are taught. A training standard shall be developed prior l to the second submittal of the program for accreditation.

4.6 The Project Coordinator shall ensure that Program Descriptions are developed in accordance with 6200-ADM-2682.06, Program Description Procedure.

4.7 Instructors should be familiar with the best instructional processes to prepare for the wide variety of learner attributes, styles, and 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 in both the Basic Ir.structor Course and in appropriate Advanced Instructor Training Modules). .

4.8 Lesson plans shall be written for all lessons and/or training 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 format for the Training and Education Department's lesson plans.

4.81 Any use of other lesson plan formats shall first be approved by the Manager of Site Training.

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^ %8.2 For more quidance in writing lesson plans, instructors should l refer to the Lesson Plan Format and Guideline found in the TSD i 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 j materials or lesson plans should be reviewed to ensure that they do indeed match the objectives.

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4.9.2 If it is found that the existing materials 'do not adequately 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 TSO 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 offered

{ to trainees for the first time. This evaluation will be done in g accordance with 6200-ADM-2682.08, Pilot Session [or First-Time 3 Offering] Implementation - Evaluation Process. l 3

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TSO PROCESS 0 00 4.12 '6tudent evaluation shall be done for the student on his/her training 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 / course:;.

4.13 Evaluation of the trainee after he or she has returned to the job after completing training shall be done in accordance with i 6200-ADM-2682.10, Evaluation of the Trainee Back on the Job Procedure.

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-2682.11, GPU Nuclear Program Evaluation For Process.

4.16 Small courus that require periodic evaluation should be evaluated in accordance with 6200-ADM-2632.12, Course Evaluation.

l 4.17 The development and implementation of On-The-Job Training shall be done in accordance with 6200-ADM-2605.02, On-f.he-Job Training.

5.0 RESPONSIBILITIES E

5.1 Director, Training and Education is responsible for approving this

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3 procedure and for assuring adherence to its requirements.

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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 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 6.8 Program Description, 6200-ADM-2682.06 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 (9ck on the Job, 6200-ADM-2682.10 e

6.14 Program Evaluation for Process, 6200-ADM-2682.11 l

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6.15 Course Evaluation, 6200-ADM-2682.12 si 6.16 On-the-Job Training, 6200-ADM-2605.02 f

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7.0 Attachments 7.1 xhibit 1, Training Systems Development.

7.2 Exhibit 2, GPUN Training Systems Development Model.

7.3 Exhibit 3 Program Development Process.

7.4 Exhibit 4, Guideline and Procedure Organization.

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