ML20195C337

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Nuclear Safety & Compliance Committee Semiannual Rept 9, Apr-Sept 1988
ML20195C337
Person / Time
Site: Oyster Creek, Three Mile Island, 05000000
Issue date: 09/30/1988
From: Humphreys L, Laney, Witzig W
GENERAL PUBLIC UTILITIES CORP.
To: Murley T
Office of Nuclear Reactor Regulation
References
1000-88-2821, NUDOCS 8811030012
Download: ML20195C337 (18)


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NUCLEAR SAFETY AND COMPLIANCE COMMITTEE i SEMIANNUAL REPORT NUMBER 9 APRIL 1, 1988 TO SEPTEMBER 30, 1988 OCTOBER 14, 1938

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CONTENTS 1.0 SUMHARY 2.0 EVALUt. TION OF SAFETY AND COMPLIANCE 2.1 OPERATIONS 2.2 MAINTENANCE 2.3 TRAINING 2.4 TECHNICAL SUPPORT 2.5 QUALITY ASSURANCE 2.6 RADIOLOGICAL CONTROLS 2.7 NUCLEAR SAFETY 2.8 OTHER ACTIVITIES 3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL 3.2 COMMITTEE ACTIVITIES 3.3 STAFF ACTIVITIES EXHIBIT 1 NSCC DOCUMENT /INFORMATION SOURCES EXHIBIT 2 NSCC STAFF ACTIVITIES /INFORMATION SOURCES EXHIBIT 3 PERSONS INTERVIEVED/ CONTACTED BY NSCC STAFF DURING PEPORT PERIOD

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SUMMARY

Safety and compliance at the General Public Utilities Nuclear (GPUN) Oyster Creek and THI-1 facilities were the object of  :

independent evaluations by the Nuclear Safety and Compliance  ;

Committee (NSCC) of the GPUN Board of Directors and by the NSCC Staff during the period April 1, 1988, through September 30, 1988. These evaluations focused on operator performance, procedural compliance, and maintenance activities.

In general, satisf actory performance was observed at both plants during this report period. ,

i The Committee believes that, with the minor exceptions noted herein, both plants were operated in compliance with relevant requirements and good practices. Management at both sites i displayed a positive attitude toward safe operation and took  ;

conservative measures to deal with operational problems.  ;

There are four areas in which GPUN should empitasize corrective actions:

o Shortage of licensed personnel, particularly at Oyster Creek. .

This currently affects only Operations and Training, but it I also limits the potential for moving experienced personnel into other functional areas. (Refer to Section 2.1.)

o Errors caused by lack of attention to detail in performing '

i unique or infrequent evolutions, such as switching and tagging l

and surveillance testing. During this period, such errors t i resulted in heat sink isolation at both plants. (Refer to l Section 2.1.) l j o Procedure adequacy. There were several instances where i incorrect procedures or inadequate instructions resulted in r errors. Moreover, the required biennial review of procedures i

is still not fully implemented. (Refer to Section 2.7.) (

l o Event critiquing. Only minor progress has been made in

) providing procedural guidance. Critiques vary extensively in scope, tameliness, and the adequacy of cause analysis and  ;

i corrective actions. (Rifer to Section 2.7.)  :

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2.0 EVALUATION OF SAFETY AND COMPLIANCE  !

The following is a functional evaluation of THI-1 and Orster  !

Creek for the period April 1, 1988, through September 30, 1988.  :

The GPUN functional organizational groupings do not necessarily correspond with the structure. For the most part, the statements pertain to conditions existing at the time of the evaluation.  ;

Corrective actions of which the Committee is aware are also noted. All items of significance have been discussed between the  :

Committee and the Staff and reported by the Committee to the CPUN Board of Directors and corporate management at regular monthly meetings.

2.1 OPERATIONS >

Both units had extended periods of continuous operation at or near full power during the report period. Shutdowns were experienced and the "D" Reactor at THI-1 for the periods of the 7R Refueling Outage Coolant Pump seal repair, and Oyster Creek was shut down during the 11U-7 Outage to repair Main Steam

, Isolation Valve 3A.

) I Operators at both sites continued to demonstrate high proficioney  !

during transients,routine operation, planned power changes, and operational The shortage of licensed operators at Oyster Creek i and theisneed period a concern.to continue a five-shift rotation for an extended I

This shortage affects the capability of moving experienced I personnel into other departments. We note GPUN's i operating response (page 6) to the NSCC's last report , in which we called attention to the shoctage of licensed operator instructors at  !

Oyster Creek. However input quotas may have g,iven insufficient weightthe NSCC to the believes that prel increasing demand for licensed operators in nonoperating capacities such as i planning. engineering, and training. We believe that present l trainee input at both stations should be reviewed with this consideration in mind, end that conservative estimates of  !

attrition ratus should be used. For Oyster Creek, some thought -

should be given to outside recruiting to relieve the present shortages. i Also of note are continued 6eficiencies in conduct of unique or i infrequent activitins such as switching and tagging and surveillance testing. At THI-1 in June, Technical Specification requirements relating to pressurizer level and cooldown rate were violated during a Low Pressure Injection System survoillance test. In another i: d ent, 300-400 gallons of reactor coolant were spilled in the ctor Building when operators drained the  ;

pressurizer while maictenance was being performed on several valves in the drain header. 1 2

i At (vster Creek, an airborne release f rom the Auxiliary Of f Gas Bui) ling occurred in April when loss of power to various solenoid valves was not considered in the cou:se of a transfer of power supplies. 11. June, Technical Specification time limits for equipment out of service were exceeded as a result of the improper surveillance testing of the Contait ment Spray heat exchangers. In August, improper valve operations during surveillance activities resulted in the f.nadvertent actuation of one Isolation Condenser. Inoperability of the second Isolation Condenser resulted from an inadequate surveillance procedure for local leak rate testing.

Although pro:edural inadequacies contributed to some of these events, inattention to detail and lack of awareness and control of equipment status are the major concerns that must be addressed.

The plants are mont vulnerable to these types of errors during cutagec. At Oyster Creek, the assignment of two licensed operators exclusively to coordinate switching and tagging and system outages during the 12R Refueling Outage is viewed as a positive step toward avoiding such problems.

Also, while proper attention must be given to accuracy in switching and tagging and component testing, greater consideration should be given to valve lineup verifications at the end of major outeges. The inoperability of an Isolation Condenser at Oyster Creek following the 11U-7 Outage right have been avoided if this had been done.

t Management attitude toward safety continued to be positive.

Several events et Oyster Creek resulted in decisions to commence shutdown, restrict power level, and modify operating parameters, and action was initiated as soon as the aberrant condition was evaluated. The prompt decision to shut down THI-1 because of the erratic behavior of the "D" Reactor Coolant Pump mechanical seal was prudent and timely.

In the course of the more significant events at Oyster Creek--

those involving the containment Spray heat exchanger and the isolation condenser, for example--the Plant Operations Director published an action plan outlining the nature of the condition, Technical Specification requirements, significant action steps, and decision points. A similar plan was published for the startup from the 110-7 Outage. Such actions constitute a Good Practice; they supply accurate information, improve communication, and provide operational guidance.

In the it.st semiannual report, the NSCC expressed concern about the failure to interpret Technical Specifications in an appropriately conservative manner. There have been no incidents during this period to reinforce that concern. Changes to Oyster 3

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Creek procedures in GPUN's responseregarding)

(psge 4 tocontrol rod operability, the last report, have as describe.d significantly reduced the potential for incorrect interpretation.

Conservatism in interpretation and action were also observed in various incidents associated with the Isolation Condensers.

Occasionally, however, there have been instances where the significance and reportability of events have not been recognized in a timely fashion. The reportability of the Low Pressure Injection incident at THI-1 and the Isolation Condenser initiation at Oyster Creek were not correctly evaluated at the time of occurrence.

I In each of these events, no entries were made in operator logs until after the determinati.n of reportability. This implies a practice of screening events before recording them. Management should insist on having all significant, off-normal events logged regardless of whether they are reportable. We note that GPUN s response (page 2) to the NSCC's last semi.snnual report indicates plans for periodic management audits of logkeeping at both sites.

In general, the quantity, quality, and timeliness of operations event critiques has improved at both sites.

(See Section 2.7 for additional comments.) TMI-1 has initiated a program to investigate events that do not require a Plant Incident Report but that might provide valuable lessons.

2.2 MAINTENANCE 3

The maintenance organizations at both sites provided generally good support throughout the period of this report. The maintenance backlog increased slightly during the period at Oyster Creek; it decreased slightly at THI-1.

More effort is apparently needed to improve the quality of maintenance work. There have been several instances of problems caused by maintenance errors. On two occasions at TMI-1, electricians caused a loss of electrical power supplies during preventive maintenance or surveillance testing. Instrument i Technicians performing surveillance 'est steps out of sequence caused the loss of Decay Heat Cooling in June. At Oyster Creek, Instrument Technicians have caused oeriodic half-scrams, Standby Gas Treatment System initiations ar.d Main Steam Line isolations by bumping or grounding instrumen'.s during surveillance testing.

That the problem of significant rework persists is reflected by the incident involving the Service Water Pump in April and that involving Main Steam Isolation Valve 3A during the 11U-7 Outage.

Administrative controls are generally adequate but there are

! areas for improvement. The inadequate technical content of THI-1 procedures has been documented in recent Quality Assurance audits and surveillance. The upgrade of maintenance procedures at l

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Oyster Creek has recently been completed. A spot check of these procedures by the NSCC Staff indicated that they are better than before, but that many are still lacking in technical content and rely heavily on references to vendor manuals. Although vendor manual control at both sites appears good, the lack of technical detail in Maintenance Procedures creates a potential for error.

In July, for example, THI-1 received a Notice of Violation for performing incorrect maintenance activities while using an uncontrolled copy of a vendor manual. In April at Oyster Creek, a replacement Service Water pump was damaged during initial operation because a step in a vendor manual was overlooked.

Oyster Creek post maintenance testing guidelines need to be improved. A lack of detail regarding electrical and instrument post maintenance testing promotes a general disregard for using the guidelines. The guidelines should also be coordinated with In Service Testing requirements. They require full baseline testing following component replacement, but procedures have not been developed to facilitate these requirements.

Preparations for, and the conduct of the 7R Outage at THI-1 were well coordinated and resulted in successful completion of the outage ahead of schedule. Preparations for the 12R Outage et Oyster Creek have been very extensive and, in general, goals for engineering and materials readiness have been met.

2.3 TRAINING Site Training organizations at both plants have effectively responded to plant needs.

Several management, supervisory, and instructor changes were made at Oyster Creek during this report period. The effect of these changes will be monitored by the NSCC Staff.

Initial Licensed Operator examination results continue to be excellent. Oyster Creek had a 100 percent success rate in the most recent examinations.

The shortage of licensed instructors at Oyster Creek continues.

A shortage of simulator instructors at THI-l has affected the rate at which corrections to simulator deficiencies can be tested and cleared. NSCC comments on the shortage of licensed personnel are contained in Section 2.1.

Good progress is being made toward the reaccreditation of INPO -

accredited programs at THI-1.

Deficiencies in Mechanical Maintenance On the Jnb Training (0JT) at Oyster Creek have been oddressed. The availability of a mechanical maintenance laboratory has improved progress in completing OJT tasks. 5

Certification of the THI-1 simulator is now planned for the third quarter of 1989. Considerable progress has been made in clearing factory-related discrepancies and deficiencies discovered during site testing and the warranty period. THI-1 Simulator certification will probably be dependent on the completion of modifications to the simulator to update it to matei the plant.

Until recently, progress was hindered by disagreement between the varie,s divisions involved and the complexity of the administrative process for authorizing, completing, and documenting modifications. The creation of a steering committee for modifications should provide better direction. Every effort should be made to streamline the administrative process of simulator modification.

Procurement of the Oyater Creek replica simulator appears to be proceeding on schedule.

2.4 TECHNICAL SUPPORT This section addresses corporate and site Technical Functions (including Plant Analysis and Shift Technical Advisors), Plant Engineering, Plant Chemistry, Plant Materiel, and Site Licensing.

During the report period each group generally demonstrated a positive attitudo and responsiveness to plant needs.

The backlog of engineering work requests continued to decrease for both Plant Engineering and Technical Functions, which I

, reflects continued support in this area. However, the c.uality

and timeliness of support is still not consistently gooc ,
especially at Oyster Creek. Examples include poor control of the core boring process for drywell cathodic protection, a Notice of Violation for improper safety review of a modification to torus attached piping, and f ailure to resolve persistent problems with Intermediate Range Monitors (IRMs), control rod accumulators, and radioactive waste evaporators. Consideration should be given to f

increasing the number of engineering personnel as the sites whose emphasis is on operational support rather than long-range design and modification work.

Long-range planning in preparation for the 7R Outage at THI-1 and the 12R Outage at Oyster Creek was successful. With minor i

I exceptions, required engineering packages were ready in time to meet the outage goals.

Support by Plant Chemistry Departments at each site has been satisfactory. The position of Manager, Plant Chemistry, at Oyster Creek has been filled.

! Shift Technical Advisors (STA) at both sites have generally performed well. During the Low Pressure Injection event at l

THI-1 in June, the STA properly pointed out the abnormal l

indications to the Shift Supervisor but failed to notify his own 6

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line management. Had he done so, notification of the event would probably have been more timely. Turnover at Oyster Creek has resulted in a decrease in the STA experience level, a condition that calls for additional management attention.

In August, an Oyster Creek Core Engineer incorrectly calculated the estimated critical position for reactor startup because of a procedural deficiency. Further, a correct calculation of Oyster Creek criticality was performed at Parsippany before the Oyster ,

Creek approach to criticality, but this calculation was not ,

transmitted to Oyster Creek until after the event. This indicates a communication problem between the corporate and site ,

groups. There is also an apparent need for better communication and sharing of experience between the groups at each site because the Oyster Creek group was unaware of a similar occurrence at THI-l in 1987. Additionally, better communication is needed at Oyster Creek. The Core Engineering group at Oyster Creek had information about a reactivity event at another plant which was not communicated to Operations until after an NRC Bulletin was issued to alert all BWRs to the event.

2.5 QUALITY ASSURANCE The Quality Assurance / Quality Control organizations at each site are effective. The Committee previously commented on the need for improved timeliness of response and closeout of audit  :

findings. A recent memorandum from the Quality Assurance l Director addressed this issue, and promulgated guidelines for the i timeliness of response and the escalation of findings. If successfully implemented, these guidelines should correct the problem. We note GPUN's response (page 9) to our last semiannual report, which describes additional actions being taken at Oyster

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l 2.6 RADIOLOGICAL CONTROLS The Radiological Controls program at each site is generally '

effective in meeting regulatory requirements for the protection of the health and safety of employees. However, the 1988 goal  !

i foi cumulative man-rem has been exceeded at Oyster Creek and is  !

very close to being exceeded at THI-1. This is attributable I

primarily to the exceedance of the 7R Outage goal at TMI-l and an insufficient allowance for forced outages at Oyster Creek.

Radiological Controls procedures at both sites are insufficient  !

in the detsil required to ensure consistent performance. In many l cases, good practices are the result of judgment, professional attitude, and the motivation of current staff, unaided by  ;

procede.ral guidance. These practices must b9 captured in I procedures to ensuce they continue despite personnel changes l which occur from time to time.

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Radiological Incident Reports at both sites were reviewed. In general, they indicate that root cause analysis is inadequate and that corrective actions tend to be event-specific. Corrective actions at Oyuter Creek have f ailed to prevent the recurrence of violations of locked High Radiation Area controls and the spread of contaminated articles to outside the Radiological Controlled Arec (RCA). We note GPUN's response (page 9) to the Committee's last semiannual report, which describes actions taken a' Oyster Creek to reduce instances of High Radiation Area doors not being properly secured.

Neither site follows NRC-recommended practices for more sensitive monitoring of articles that are to be removed from the RCA for disposal. This increases vulnerability to violations.

Radiological waste processing equipment at Oyster Creek has generally been available when needed, but design deficiencies and frequent component failures have required continual maintenance with accompanying high exposure.

2.7 NUCLEAR SAFETY The Emergency Preparedness organizations at both sites continued to demonstrate the capability to protect public health and safety in drills and graded excrcises. The Staff observed the successful annual emergency preparedness exercise at Oyster Creek in May.

The Independent On Site Safety Review Group (IOSRG) provided good support at each site. The only concern that the Committee has is whether each 10SRG has sufficient time for discretionary evaluations. One member of each 10SRG serves as site Human Performance Evaluation System cootdinator, essentially a full-time job. Other substantial projects--e.g., Safety Issues Assessment Program, MORT analyses, Stier investigation support at Oyster Creek--have been assigned by plant or corporate management. Meny of these activities are valid uses of the 10SRG resources, but care should be taken to ensure that sufficient time is available for independent investigation of activities selected by the 10SRC Manager.

Two NSCC Staff members attended the new Safety Reviewer Training Program developed at Oyster Ceeek and found it to be an effective training course.

As previously noted, some progress was made in Operations critiques during this report. The Human Performance Evaluation System was also ef f ectively used to supplement critiques of selected events. Nevertheless the Committee continues to be concerned about the quality of event investigation and corrective actions.

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3 At Oyster Creek, the frequency and timeliness of HCF critiques has improved significantly, although the analysis of identified problems--e.g., the vendor manual problem contributing to the incorrect machining of an MSIV spring retainer, and reason for disconnected wires on drywell chiller--is not always complete.

A Technical Functions critique of the missing hanger for valve V24-30 merely provided a chronology of the problem. The critique of the early criticality at Oyster Creek did not address human performance failures.

In its last report, the NSCC noted deficiencies in the corporate procedure for event critiques (1000-ADM-1201.01) and e.' pressed the concern that impicmenting procedures had not been issued by appropriate divisions. We note from GPUN's response (pages 4 and

11) to that report that progress has been made in revising and issuing procedures, and that such procedures will formalize the process for conducting critiques, and take into account screening criteria and timeliness. We suggest that they also address corrective actions that may result from critiques--how such actions are to be impicmented across organizational boundaries, for example, and how they will be tracked to completion.

Many deficiencies regarding procedure adequacy and adherence were noted during the period of this report. Examples at THI-1 include the Decay Heat Removal isolation, the Technical Specification violation involving ths Pressurizer level and cool.down rate, the mishandling of Safeguards information, and a Technical Specification violation involving the Chlorine detectors. At Oyster Creek, airborne releases during the startup of A0G, the inoperability of the Isolation condensers, and an incorrect prediction of criticality during reactor startup were all attributable in part to inadequate procedures.

Another source of continuing concern is the fact that several procedures for each site are routinely overdue for biennial review. Oyster Creek has initiated a program to postpone the issuance of such procedures until the reviews are completed.

While the method does not prevent a previously issued copy from being used, it reflects a more conservative ettitude than that of THI-1, where no attempt is made to restrict the use of overdue procedures. In fact, it is evident that at THI-1 biennial review requirements are not even considered when major revisions are made. For example, many procedures were substantially revised for use during the 7R Outage and received appropriate technical and safety review, but the additional steps needed to satisfy biennial review requirements were not taken even though the biennial review cycle was due to expire during their period of use.

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2.8 OTHER ACTIVITIF' The Committee has received the GPUN memorandum of September 20, 1988, responding to comments in its Semiannual Report Number 8.

l The Committee's comments have received thoughtful consideration and discussion. NSCC comments on the responses have been noted

in the appropriate sections of this report.

i 3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL

The NSCC guides the NSCC Staff's investigations and approves its schedules and expenditures. Staff activities involve both
routine monitoring and special reviews. Routine monitoring covers all functional areas at each site and at corporate headquarters. A long-range schedule of mon $lorieg activities is developed every 6 months. and activities are added at the request

, of the Committee or whenever plant events or industry occurrences j dictate. The Committee reviews various corporate reports such

. as those listed in Exhibit 1. On occasion these reviews result in special tasks for the Staff.

i 3.2 COMMITTEE ACTIVITIES i

In addition to the activities described above, the Committee

meets monthly with the GPUN Board of Directors and reports on any 3

items of significance with respect to safety or compliance.

Questions or concerns that may arise between board meetings may j be d!rected to the Chairman of the Board or the President of GPUI Periodic meetings are held with GPUN executives in which the ,J Staff presents overall observations of plant activities,

, no' .aited to only safety and compliance issues. During this report peri >d, observations Meetings were held at TMI-1 in April

! .and Oyster Creek in August. The Committee meets with menior d

membs.s of the Staff prior to the monthly meetings of the Board 1 of Directors. These meetings frequently include presentations

by, and discussions with, selected GPUN personnel on subjects of J interest to the Committee. During this report period, discussions were held with the Vice-President / Director, Planning and Nuclear Safety; the Vice-President / Director Maintenance, 1

Construction,andFacilities;theDirector[Tralningand Education; the MCF Production and Technica Director; thw Director, Simulator Development; the Manager Oyster Creek Fuel

Frojects;andtheOysterCreekCoreEngineerIngManager. The

! Committee also initiated a plan to interview first line

supervisors and shift personnel. During this period, they a interviewed a shift supervisor and maintenance supervisor at each
site and an STA at Oyster Creek. Similar interviews are planned 1 in the future.

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Committee members made tours at both sites in conjunction with the meetings of the Board of Directors. In addition, Dr. Witzig ,

made unannounced tours of both sites. Mr. Laney attended GORB meetings at both sites, and Dr. Witzig attended one GORB meeting at THI-1.

3.3 STAFF ACTIVITIES i The Staff, which is permanently stationed at the plants, gethers information on plant activities in many ways plant tours; the monitoring of activities; attendance at meetings; interviews with GPUN personnel; and reviews of reports, correspondence, and other documents. Plant oaerations anc naintenance activities receive primary attention, aut support 1,tetions are also evaluated. The  :

NSCC Staff has management, operations, maintenance, training, and licensing and safety review expertise.

Evaluations during this report period concentrated on the areas and activities described in Section 2.0. A list of activities and information sources used in the Staff evaluations is presented as Exhibit 2. The types and number of GPUN personnel contacted during this period are indicated in Exhibit 3.

Six NSCC Staff members attended the GPUN Techniques of ,

observation Training Program in September.

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EXHIBIT 1 NSCC DOCUMENT /INFORMATION SOURCES GPUN SOURCES (both sites unless otherwise noted)

Plant Incident Reports (THI-1)

Deviation Reports (OC)

Licensee Event Reports Licensing Correspondence Significant Events Reports Off-Shift Tour Reports Post-Trip Review Group Reports Transient Assessments Reports IOSRG Evaluation Reports GORB Meeting Reports QA Monthly Assessment Reports QA Quarterly Trend Reports Attendance at GORB Meetings Plant Tours Meetings with GPUN Management OTHER SOURCES NRC Notices NRC Generic Letters NRC Regulatory Guides and NUREGs lGC SALP Reports Industry Periodicals (e.g., Inside NRC, Nucleonics Week)

NRC Inspection Reports INPO E'61uation Reports

  • INPO Nuclear Power Plant Operational Data Report NRC Performance Appraisal Team Reports l

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EXHIBIT 2 NSCC STAFF ACTIVITIES /INFORMATION S0 RACES (both sites unless otherwise nott.d)

PLANT TOURS General Walkthroughs/ Housekeeping Observations Off-Shift Tours Control Room Observations Maintenance Observations Surveillance Test Observations Radwaste Handling Observations HEETINGS Daily Plant Status Meetings Outage Planning Meetings NRC Entrance / Exit Meetings INPO Training Evaluatior.:.

GORB Meetings '

Post-Trip Review Group Meetings Maintenance Critiques (OC)

DOCUMENT REVIEW GPUN Sources Plant Incident Reports (THI-1)

Plant Review Group Meeting Minutes Deviation Reports (OC)

Licensee Event Reports ,

Incident Critiques I Licensing Correspondence ,

Significant Events Reports off-Shift Tour Reports QA Audit Reports QA Monthly Assessment Reports '

QA Quarterly Trend Reports Operations QA Monitoring Reports STA Daily Reports Operations Night Order Book Log Books (Operations, STA, Chemistry, Maintenance, Radwaste)

Shift Turnover Forms MNCRs, QDRs Radiation Awareness Reports Post-Trip Review Group Reports  :

Transient Assessment Reports l Maintenance Work Order Packages 13

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EXHIBIT 2 (continued)

GPUN Sources (continued)_

GPUN Administrative Policies and Procedures  :

Station Procedures (e.g., Admin., Operations, Maintenance) l Operations QA Plan ,

Technical Specifications Training System Descriptions Training Lesson Plans Plant Drawings 10SRC Evaluation Reports CORB Meeting Reports Preliminary Safety Concerns Licensing Action Items Status Report i

Other Sources NRC Notices i NRC Generic Letters NRC Regulatory Guides and NUREGs NRC SALP Reports NRC Inspection Reports NRC Performance Appraisal Team Reports -

INPO Evaluation Reports INPO Guides ANSI Standards ASME Codes Code of Federal Regulations (10 CFR)

Industry Periodiccis (e.g., Inside NRC, Nucleonics Week) '

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EXHIBIr 3 PERSONS INTERVIEWED / CONTACTED BY NSCC STAFF DURING REPORT PERIOD SITE PERSONNEL (both sites unless otherwise noted)

Vice President / Director (THI-1)

Vice President / Director (OC)

Deputy Director (OC)

Operations and Maintenance Director (TMI-1)

Plant Operations Director MCF Director Department Managers, Supervisors, and Personnel Plant Operations Plant Material Maintenance, Construction, and Facilities Plant Engineering Plant Chemistry Special Projects (OC)

Plans and Programs ,

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Safety Plant Review ReviewGroupGroup (TMI-1) 10SRG Technical Functions (OC)  !

LicenLing Plant Analysis and STA Startup and Test Training and Education  ;

Radiological Controls Quality Assurance / Quality Control  !

Emergency Planning  ;

I CORPORATE PERSONNEL f Vice President, Planning and Nuclear Safety [

Vice President, Quality and Radiological Controls i Director, Quality Assurance I Chairman, General Office Review Board Managers and Other Personnel Licensing Training and Education l Safety Analysis and Plant Control Quality Assurance j Technical Functions Haintenance, Construction, and Facilities I s

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201-316 7000 YELEX 136-482 Wri'er's Direct Dial Number:

201-316-7797 October 24, 1988 1000-88-2821 Dr. Thomas E. Murley Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555

Dear Dr. Murley:

SUBJECT:

NUCLEAR SAFETY & COMPLIANCE COMMITTEE My letter to you dated April 28, 1968 provided the semiannual report of the Nuclear Safety & Compliance Comittee (NSCC) to the GPU Nuclear Corporation Board of Directors.

Mr. W. G. Kuhns, Chairman of the Board, GPU Nuclean Corporation, has requested that I provide to you the NSCC's Semiannual Report No. 9 for the period April 1, 1988 to September 30, 1988. A copy of the report is enclosed.

Sincerely, jk k.

P. R. Clark President

/pfk Enclosure cc: W. G. Kuhns, Chairman of the Board th O gg N. .dEcDkSP/TM48 Hgt Ass ha e e NAffh$$ fYb il GPU Nuclear Corpora on is a subsdary of General Putk Utit.es Corpooton