ML19345F382

Testimony Responding to CLI-80-5,Issue 2,TMIA Contention 5, Sholly Contention 14(e) & Anti-Nuclear Group Representing York Contention 4.TMI-1 Maint Organization Has Grown & Modified Significantly,Reflecting Gpu Commitment

ML19345F382
Person / Time
Site:	Three Mile Island
Issue date:	02/09/1981
From:	Ballard B, Dyckman D, Harper R, Shovlin D, Snyder M GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML19345F374	List: ML19345F373 ML19345F377 ML19345F382
References
CLI-80-5, ISSUANCES-SP, NUDOCS 8102170367
Download: ML19345F382 (133)

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION

, r i BEFORE THE ATOMIC SAFETY AND LICFNSING BOARD 5 '

In the Matter of )

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/TETROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP

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LICENSEE'S TESTIMONY OF DANIEL M. SHOVLIN, MELVIN G. SNYDER, RICHARD R.' HARPER, DENNIS V. DYCKMAN AND BLAINE BALLARD, SR.

IN RESPONSE TO CLI-80-5, ISSUE 2, TMIA CONTENTION 5, SHOLLY CONTENTION 14(e),

AND ANGRY CONTENTION IV (MAINTENANCE AT TMI-1)

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1 OUTLINE This testimony, by Messrs. Daniel M. Shovlin, Melvin G.

Snyder, Richard R. Harper, Dennis V. Dyckman and Blaine Ballard, Sr., addresses Issue 2 in the Commission's March 6, 1980 Order, CLI-80-5, TMIA Contention 5, Sholly Contention 14(e), and ANGRY Contention IV, insofar as they concern the Maintenance organization and maintenance practices and procedures at TMI-1.

Maintenance work at TMI-l is organized into three areas:

preventive maintenance, corrective maintenance and shift maintenance. The Manager of Plant Maintenance is responsible for all of these activities. Reporting to him are the Corrective and Preventive Maintenance Managers, as well as the Lead Shift Maintenance Supervisor. The TMI-l Maintenance organization is comprised of 146 employees in production and supervi'sion positions.

As described in detail in the testimony, computer programs are used for organizing and keeping track of preventive and j corrective maintenance at TMI-1. This method of doing business had developed gradua'ly over the past several years at TMI-1, as evidenced by the change from the manual work request system to the automated job ticket forms. Other policies and procedures also have changed, such as the overtime policy, training programs, the priority system for identifying important maintenance work, and the establishment of a separate Preventive Maintenance group within the Maintenance organiza-tion. All of these actions reflect Licensee's ongoing com-mitment to safely and effectively operate and maintain TMI-1.

1 INDEX Introduction .................................................. 1 Organization of TMI-l Maintenance Department .................. 2 The Performance of Preventive Maintenance ..................... 12 Corrective Maintenance ........................................ 14 GMS System ............................................... 14 Prior System ............................................. 21 Other CM Documents ....................................... 34 Scheduling and Performing CM Today ....................... 39 Scheduling and Performing CM Under Prior System .......... 51

! Recent Status of CM at TMI-l ............................. 69 Overtime Policy ............................................... 70 The Review of Maintenance Activities .......................... 72 l Conclusions ................................................... 77 l

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BY WITNESSES SHOVLIN, SNYDER, HARPER, AND DYCKMAN The purpose of this testimony is to provide information regreding the qualifications of the personnel, the organiza-tional deeign, the methods used in the conduct of maintenance at TMI-1 and specific explanations of certain exhibits that were entered as evidence in support of TMIA Contention 5. This testimony also addresses Issue 2 in the Commission's March 6, 1980 Order, CLI-80-5, Sholly Contention No. 14(e), and ANGRY Contention IV regarding the adequacy of maintenance programs and staff at TMI-1.

The organization and practices of the TMI-1 Maintenance Department have changed considerably since March of 1979.

These changes have taken place in a meaningful and methodical sequence and have been supported, throughout the management levels involved, as appropriate means to improve management control over TMI-l maintenance activities. The scope of responsibility of key individuals has been narrowed to provide for a more intense focus on the various aspects of the maintenance within one nuclear power plant unit. Three major areas of responsibility have been identified as: Preventive Maintenance and Technical Specification Surveillances; Corrective Maintenance; and Shift Maintenance. Each of these areas is staffed with personnel dedicated to carrying out their assigned responsibilties. The area of responsibility for the Manager of Plant Maintenance (formerly titled Superintendent of Maintenance) prior to March of 1979 was both TMI Units 1 and 2.

With the separation of the Units, maintenance responsibilities,

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i rno, have been separated and the manager of Maintenance at each unit har responsibility for maintenance for his unit only.

This testimony addresses TMI-1 and the personnel assigned to I

the Unit 1 Maintenance organization.

A. ORGANIZATION OF TMI-l MAINTENANCE DEPARTMENT The Manager of Plant Maintenance reports to the Operations and Maintenance Director of TMI-1 and provides maintenance support for the Unit. This position is responsible for planning, organizing, integrating and directing the maintenance effort of TMI-1 in order to insure optimum equipment / systems availability and reliability. Maintenance work at TMI-1 is organized into three areas: preventive maintenance, corrective maintenance and shift maintenance. The Manager of Plant Maintenance is responsible for assuring the plant is properly maintained. He has available plant resources for accomplishing the work and he has the authority to assign maintenance work to company and contract to resources in fulfilling this responsi-bility.

The minimum qualifications for the position of Manager of Plant Maintenance are seven years of responsible power plant experience or applicable industrial experience of which a minimum of three years shall be nuclear power plant experience.

An Associates Degree in an engineering or scientific field is preferred and may be credited to the remaining four years of experience. The individual should have non-destructive testing familiarity, craft knowledge and an understanding of electrical, pressure vessel and piping codes. j The current Manager of Plant Maintenance, Mr. Daniel M.

Shovlin, is a Navy veteran of twenty-seven years. During his Navy career, Mr. Shovlin spent six years as Chief Engineer and Repair Officer on several large combatant surface ships. In this capacity, he was responsible for the operation and maintenance of the ship's main propulsion plant, auxiliary machinery, and piping systems, and for the operation and maintenance of electric power generation and distribution systems. From 1972 to 1973, Mr. Shovlin served as a member of the Naval Board of Inspection and Survey as an Engineering Inspector. Mr. Shovlin began working at TMI in 1973 as the Unit 1 Supervisor of Maintenance in charge of Instrumentation and Cont.rol, Mechanical, Electrical, and Utility Maintenance functions. He remained in this position until January 1977, at which time he assumed the responsibilities of Supervisor of Maintenance at TMI Unit 2. In December of 1977, Mr. Shovlin became the Superintendent of Maintenance responsible for all maintenance activities on Three Mile Island. In November 1979, when the TMI-l and 2 organizations and units were formally separated, Mr. Shovlin was designated as the Superintendent of Maintenance at TMI-1. Recently, his-title has been changed to Manager of Plant Maintenance.

The TMI-l Maintenance Organization is comprised of 146 employees in production and supervision positions as shown on the attached organizational chart (Attachment 1). To summarize, there are 95 employees who work in Corrective Maintenance; 36 of these employees work daylight hours and 59 are assigned to the six rotating shifts designated as Shift Maintenance which provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week plant maintenance coverage. There are 25 employees assigned to Preventive Maintenance with 8 of these employees on rotating shifts. The Utility group of 16 reports directly to the I

Manager of Plant Maintenance as do the Welding Supervisor, the Project Coordinator, and the Administrator. In addition, there are five production clerical employees who report to the Administrator.

Included in the Preventive Maintenance (PM) group of the TMI-l Maintenance Department are the Electrical, Instrumenta-tion and Control, Mechanical, and Utility disciplines. There are a foreman and four to eight craft personnel within each discipline.

t The PM Manager reports to the Manager of Plant Maintenance and provides preventive maintenance support for the Unit. He is responsible for organizing, modifying, and conducting the preventive maintenance for TMI-1. The Preventive Maintenance l

Manager has the responsibility of identifying / justifying

! resources requisite to accomplishing the PM program. The PM Manager has the authority, as delegated by the Manager of Plant Maintenance, to assign preventive maintenance tasks not performed by the Operations department to company and 4

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contractor resources identified by management. He has the authority to establish and/or modify the operation of the PM Program not required by Technical Specification Surveillance and as censistent with Company policies. The minimum qualifications for the PM Manager are the same as those specified for the Manager of Plant Maintenance.

! The current Preventive Maintenance Manager, Mr. Melvin G.

Snyder, worked in the United States Navy from 1958 to 1962 as an Electronics Technician. He attended Electronics Technician Class A School (1958-1959). During his last year and a half in the Navy, Mr. Snyder was the leading petty officer of the i Electronics Division aboard the USS GALVESTON. In 1966, Mr.

Snyder joined the Saxton Nuclear Experimental Corporation as an instrument technician. He stayed with Saxton until 1972, at which time he joined Licensee as an instrumentation maintenance foreman. Mr. Snyder left TMI in December of 1976 and became self-employed. He returned to TMI in June of 1978. While.at TMI, Mr. Snyder became the Maintenance Department instrument i

and control supervisor (November 1978), and was named the Preventive Maintenance Supervisor in November 1979. His title was recently changed to PM Manager.

Through its preventive maintenance program and staff of 25 employees, it is the goal of Licensee to assure reliable performance of equipment and to reduce to an absolute minimum the amount of corrective maintenance work at TMI-1. By regularly inspecting and performing other preventive l

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maintenance work on TMI-1 systems, particularly those related to the facility's safety and reliability, equipment is less likely to experience failure during operation; consequently, i both safety and availability of the unit is improved.

The Corrective Maintenance (CM) group includes the Electrical, Instrumentation and Control, and Mechanical disciplines. (Utility maintenance reports directly to the Manager of Plant of Maintenance through its utility super-visor.) There are a lead foreman and one or more foremen in each discipline within Corrective Maintenance who supervise the permanently assigned daylight personnel and support the shift maintenance foremen in their conduct of maintenance by shift maintenance personnel in each discipline.

The Corrective Maintenance Manager reports to the Manager of Plant Maintenance and provides corrective maintenance support for the TMI-1 Unit. This position is responsible for planning, organizing, integrating, and directing the corrective maintenance effort for Unit 1 in order to insure optimum equipment / systems safety, availability and reliability. The CM y Manager is responsible for the identification, justification, i

and utilization of resources requisite to the corrective maintenance program. He has the authority, as delegated by the Manager of Plant Maintenance, to assign corrective: maintenance tasks to company and contractor resources identified by i

management. The minimum qualifications of the CM Manager are I

the same as those specified for the Manager of Plant Maintenance and the PM Manager.

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The current Corrective Maintenance Manager, Mr. Ri a- '

Harper, served in the United States Navy from 1962 to 1968 as an electronics technician and nuclear reactor operator. While in the Navy, Mr. Harper attended Electronics Technician Class "A" School (1962-1963), the U.S. Navy Nuclear Power School and U.S. Navy Nuclear Power Prototype Training (1964-1965), and served as a reactor operator on the submarine, USS ANDREW JACKSON. In 1968, Mr. Harper joined the Saxton Nuclear Experimental Corporation as an instrument technician. He stayed at Saxton until 1969, at which time he joined Licensee at TMI as a Maintenance instrument foreman. While at TMI, Mr.

Harper became the instrumentation and control supervisor (1974). Mr. Harper was transferred to Licensee's Portland Generating Station (Sept. 1978) as the Supervisor of Station Maintenance. In November 1980, Mr. Harper rejoined the TMI-l staff as Supervisor of Corrective Maintenance.

In addition to the preventive and corrective maintenance personnel employed on site during the day, TMI-l has a shift maintenance work force composed of six rotating sections. Each i section is normally comprised of a minimum of two men from each discipline: Electrical, I&C, Mechanical, and Utility l

(approximately ten men per section). Shift maintenance works on corrective and preventive maintenance items that can be completed during an eight hour shift. Each section is headed l

by a maintenance foreman. These shift maintenance foremen report to the Lead Shift Maintenance Supervisor. During the

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week on the 3 to 11 and 11 to 7 shifts and on al'1 ahifts on the weekend, one of the CM and PM Managers and the Lead Shift Maintenance Supervisor is on call as an Emergency Maintenance Coordinator. There is also one of three supervisory personnel on call in each discipline whom the Shift Maintenance Foreman on duty can call if he needs guidance or additional expertise on a problem.

The Lead Shift Maintenance Supervisor reports to the of Corrective Maintenance Manager. It is the responsibility of the Lead Shift Maintenance Supervisor to organize, coordinate and direct both corrective and preventive maintenance performed on shifts. The minimum qualifications for this position are the same as the qualifications required for the PM and CM Managers and the Manager of Plant Maintenance.

The current Lead Shift Maintenance Supervisor, Mr. Dennis V. Dyckman, received a Bachelor of Science degree in mechanical engineering in 1968 from the University of Missouri. He served in the U.S. Navy from 1968 to 1979. During this time he attended the U.S. Navy Nuclear Power School and Prototype Training. Upon receiving this training he uas qualified as a Nuclear Engineer Officer in 1973. He served on two different nuclear submarines as Electrical Officer, Main Propulsion Assistant, Engineer Officer and Executive Officer (second in command). He also supervised equipment overhauls, reactor defueling and refueling and reactor startup and testing on two nuclear submarine overhauls in 1972 and 1976 as Senior I

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Supervisory Watch. Upon leaving the Navy in 1979, Mr. Dyckman joined GPUSC, working as a Maintenance Engineer. His initial assignment was Supervisor of TMI Unit 2 Auxiliary Building charcoal filter changeout and the design, implementation and maintenance of an emergency air breathing system for Unit 2.

Mr. Dyckman was assigned as temporary Supervisor of Corrective Maintenance in October 1979 and served in that capacity until the present assignment in November 1980.

The activities of the TMI-l Maintenance Department are totally independent of the TMI Unit 2 activities so that the dedicated focus of maintenance management and expertise at TMI-l is uninterrupted. The Maintenance organization works

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closely with the TMI-l operations Department to plan, organize, integrate, and direct the daily maintenance that takes place in Unit 1. All regular maintenance activities in the Unit are under the cognizance Managers and Lead Shift Maintenance Supervisor including the work done by any outside contractors or vendor representatives. Major construction activities such as plant modifications or additions and major outage activities will be under the direction of the Maintenance and Construction Division of GPU Nuclear Corporation in close coordination with the TMI-l Maintenance staff. This planning and direction on the part of the Maintenance and Construction Division will permit the TMI-l Maintenance organization to give the day-to-day activities at TMI-l their undivided attention.

The planning of the day-to-day maintenance work in TMI-1 is done by the planners who report to the CM Manager, and who are directed by the Supervisor of Manangement Control.

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The Supervisor of Management Control reports to the CM Manager and is responsible for the planning of major maintenance tasks and the development of schedules for the accomplishment of tasks within specified time frames, such as a refueling outage or unscheduled outage. The minimum quali-fications for this position are seven years of responsible industrial experience or applicable power plant experience, a minimum of three years which shall be nuclear power plant experience. An Associate Degree in an engineering or scientific field is preferred and may be credited to tha remaining four years of experience. The individual should have management methods familiarity and an understanding of scheduling tools such as bar charts, CPM and PERT.

The present Supervisor of Management Control, Mr. Richard C. Troutman, received a Bachelors Degree in Electrical Engineering in 1970 from Pennsylvania State University. He served in the U.S. Army from 1970 to 1973, during which he received training in top secret communications equipment. In 1971, he became an instructor in this equipment. Upon leaving the Army in 1973, he joined Met Ed in Lebanon as a junior engineer. He accepted a position as an engineer at TMI in July of 1974. From January 1975 to January 1979 he was assigned as the engineer in charge of outage planning. During this time he l

was responsible for the planning and scheduling of a number of major maintenance activities. In January 1979 he was named as l the Supervisor of Management Control (SMC).

The Maintenance Department works closely with the QC and O/QA groups to ensure that maintenance work is performed in accordance with the operational Quality Assurance Plan.

Quality assurance audits and monitorings provide continuous checks on procedural adequacy and compliance with NRC commitments, rules and regulations and with ANSI and other

! standards on which the O/QA plan is based.

The maintenance organization has welcomed and is firmly committed to the TMI-l technical training program. One sixth of the maintenance production personne'l are scheduled for training each week. These weekly sessions provide for a continuing enhancement of the technicians job skills, job .

knowledge level, and overall plant systems understanding. The training provided includes health physics awareness and radiati,on work practical factors sessions which develop the sense of responsibility and sharpens the safe job performance l

abilities of the maintenance technician.

f I Finally, the Maintenance staff works closely with the Radiological Control (Rad- a) group to identify and implement the work methods and practices that will accomplish a given task in the safest possible manner for both plant personnel and the general public.

Job Ticket C4763 (Attachment 2) is an example of the type of job that is reviewed by the ALARA group in the Radiological Controls Department. This equipment is located in the TMI-l l

l Auxiliary Building which is one of the areas classified as l

Radiologically Controlled.

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Following the ALARA review, the Rad-Con technicians prepare a Radiation Work Permit (RWP) that will outline the requirements for performing the work in a radiologically safe manner.

BY WITUESSES SHOVLIN AND SNYDER B. THE PERFORMANCE OF PREVENTIVE MAINTENANCE The performance of Preventive Maintenance work is scheduled and documented by.use of a portion of the Generation Maintenance System (GMS) and utilizes GPU's central data processing equipment via a terminal at TMI. The GMS has a number of modules (preventive maintenance, corrective maintenance, machinery history, etc.) and was developed over several years through a coordinated effort by the Generation Division of the GPU ccrpanies in concert with the GPUSC Information Services Division. The implementation has been coordinated with the ir.glementation of a much broader information management system developed by the GPU companies and called COMEC (Construct!on, Operation and Maintenance Expenditure Control). The PM codule of GMS was implemented as an automated system at TMI in 1976, and provides numerous print-outs covering the machinery history of preventive maintenance (the results record), task lists, component lists, long and short term schedules, and a weekly checklist.

The PM Weekly Checklist is used for the development of the Weekly Work Schedule that assigns the PM jobs for each day and L

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1 shift. The Weekly Checklist is accompanied by a check sheet for each " current week" job listed. It also contains the "Past Schedule Week" open items. The check sheet has on it the necessary information and spaces for approval signatures for performance of the job. T3e procedures to be used are attached The PM to the check sheet by PM Department personnel.

Department foremen plan and schedule the job a week in advance.

The Quality Control Department reviews all of these PM work packages that are within QC scope, identifying any hold points or portions of the job that they wish to observe during performance.

The PM Department foremen assign craft personnel to perform the job at the scheduled time. Following job completion and sign-off, the results are entered in the computer, thereby updating the preventive maintenance history for the component. Data sheets associated with the task are kept on file in the Maintenance Department.

The establishment of a se'parate PM group and the i

concurrent increase in the resources available for PM has significantly increased the percentage of identified PM tasks that are being completed. PM is performed during the day by the PM day workers, as well as on four shifts. The average job completion rate for the Maintenance Department in 1979 was 49.3% of the jobs identified; in 1980, the average job completion rate rose to 71.6%. The increased completion rate also is due to the availability of the scheduling module since

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1 GMS was totaily automated in December 1978. The previous system of PM scheduling was completely manual, with work requests being generated to accomplish the PM tasks. Many of the tasks were so large and cumbersome that they were difficult to accomplish in a timely and effective manner, i.e., a single task might call for the performance of pre entive maintenance on all components in the Condensate System. Plant systems have now been broken down into smaller workable segments providing for greatly improved work scheduling and accomplishment.

While the Preventive Maintenance work backlog has steadily been reduced, the PM work base has been broadened. Jobs identified as valuable preventive maintenance have been added to the computer program and procedures have been written by which the jobs will be accomplished.

BY WITNESS SHOVLIN, HARPER AND DYCKMAN C. CORRECTIVE MAINTENANCE

1. GMS SYSTEM Corrective Maintenance also is performed using the automated Generation Maintenance System (GMS) with its associated forms and reports. Corrective maintenance is l

performed through the use of the GMS job ticket Form. The job Ticket is a tool whe-eby any person in the plant who sees a potential problem may fill out a job ticket to describe the malfunction or request a modification.

The Job Ticket is a four part (4 color) NCR form. The entire process of filling out a job ticket and the subsequent l

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routing is contained in detail in Maintenance Procedure 1407-1.

The following description summarizes this process.

When an individual is of the opinion that particular corrective main:enance work is appropriate, he fills out the component designation, request date, recommended priority, a description of the problem or modification, the cause of the problem (if known) and signs his name on a job ticket form. He then forwards the job ticket to his supervisor for concurrence

! and approval. After the supervisor signs the job ticket, it is sent to the senior planner, who fills in the necessary accounting data, department assigned plant conditions and the actual priority of the job ticxet. In addition, he fills out a Review-Classification-Routing Control Form (RCR). He answers the following questions on the RCR form (the numbering system is per the RCR form):

1. Does the work represent a change or modification to an existing system or component? If yes, an approved change modification is required per AP-1021.

(Yes) (No)

- If Yes, a Change / Modification Request is filled out and submitted by the Supervisor of Maintenance to Plant Engineering.

l 2a. Does the work require an RWP? (Yes) (No)

- This is determined based on the location I or type of component. All work in the i

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i Auxiliary, Fuel Handling and Containment Buildings are in the RWP areas.

(Additional areas are as defined by Rad- j

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2b. Is a Radiological Engineering Review for t

ALARA required? (Yes) (No) Rad. Engr.

signature if yes. (

- This is determined based on floor plans marked up by ALARA showing those areas in which work to be performed must be reviewed by ALARA. The signature of the Radiological Engineer performing the review  ;

is required if the answer is Yes.

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3a. Is the work on a QC component as defined in j GP 1008. (Yes),(No) ,

- This is determined by checking GP 1008 to see if the component listed on the job ticket is listed as a QC component.

3b. If 3a is yes does the work have an effect

" Nuclear Safety? If 3b is yes, PORC l

reviewed Superintendent approved procedure must be used. (Yes) (No) f

- This question is answered only if 3a is Yes, Does the WORK have an effect on  ;

Nuclear Safety? is the question. This is l l

a judgment decision based on the malfunc-

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planner and reviewed by the SMC. If there I are any conflicts or questions the Manager

, of Plant Maintenance resolves them. If the l

answer is Yes, then a PORC-reviewed Unit Manager-approved procedure MUST be used.

If the answer is No then see step 4.

l 4. Agreement that a PORC reviewed, Superin-tendent (now called the Manager of TMI-1]

approved procedure is not required for this work because it has no effect on nuclear safety. (7pplies only if 3a is Yes and 3b is No).

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- If 3a is Yes (QC component) and 3b is No (does not affect nuclear safety) then the

(&M Director agrees by his signature.

Sa. Is the system on the Environmental Impact

list in AP-1026. (Yes) (No)

- This is determined by looking at Table #1 of AP-1026 which lists those systems that can have environmental impact.

Sb. If Sa is Yes, is an approved procedure required to limit environmental impact.

(Yes) (No) l - This question is answered in conjunction 1

with question 6 by the Manager of Plant Operations. .

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. 6. Agreement that 5b is No. (Required only if Sa is Yes)

- The Manager of Plant Operations answer both 5b and 6 based on his knowledge of the plant and the details of any attached procedure. If he answers 5b - Yes, an approved procedure is required. If he answers 5b - No, then his signature is

required.

7. Plant status or prerequisite conditions required for work.

- This is based upon the priority code letter assigned i.e. A means operating; B means Turbine outage; C means Reactor l

Cutage; D means Vacuum Broken and E means i Refueling Outage.

After all forms and blanks are filled in and any required l pre-approved procedures indicated, the job ticket is forwarded to the Supervisor of Management Control (SMC). The SMC reviews all the blocks and boxes for correct data and determines if the job should go to planning or is ready for field work. The SMC then sends the job ticket to the Maintenance Office clerk who l assigns a job ticket number from the sequential numerical Maintenance Log and records data from the work request in the Log. If a procedure has been indicated by the planner or the SMC, the clerk attaches a copy of the latest revision to the Procedure and then either returns the job ticket to the SMC (if planning has been indicated), or sends the job ticket out for required signatures as indicated on the RCR. In addition, the clerk removes the copy 4 and sends it to the GMS Coordinator for computer entry. Upon return of the job ticket after routing, the clerk places the job ticket in a basket labeled

" Work to be scheduled". The SMC or CM Manager then reviews the job ticket, approves it for work and either sends it to the responsible discipline for scheduling or places it in a file holding job tickets for future work. A CM Status Activity Form (CMSAF) is submitted to the computer to indicate the job ticket is ready to work. Even if the job ticket is to be planned and therefore not yet scheduled for work, the copy 4 is still removed and forwarded for computer entry, and a CMSAF is submitted for computer entry to indicate that the job status is in a planning hold. The job ticket is then forwarded to the SMC.

The SMC's function is four-fold. One, with guidance provided by the O&M Director he develops and promulgates a long range Operations / Maintenance schedule for each month. This schedule includes major Operations Department evolutions and major maintenance items. The schedule also includes necessary plant conditions. Two, based upon plant conditions he schedules the testing of components that have been repaired but not yet tested. Three, based upon the promulgated schedule, he feeds job tickets to two planners (one for I&C and Electrical i

4 jobs and one for Mechanical jobs) for work up into complete

packages. Fourth, he promulgates and updates the 24-hour work schedules that are produced at the Monday through Friday 4 p.m.

daily scheduling meeting. Therefore, the jobs to be planned are selected and sent to the planners by the SMC.

The planners physically field-scope the work, verify the procedures required (if none are available, they draft the procedure), order the required parts and enclose all the above information in the job ticket work package. The package is then returned to the SMC. The SMC checks the package contents and if the package already has an approved procedure and the parts are available he sends it to the Maintenance clerk for appropriate signature routing as indicated on the RCR form. If the parts are not available but on order, he fills out a CMSAF for computer entry to indicate the job ticket is on parts hold.

If the procedure is not already approved then the work package is sent to the Unit 1 Safety Review Manager (currently, the PORC Chairman) for review. If the procedure applies to a QC component, it is then reviewed by PORC, revised by the SMC if necessary, and then finally approved by PORC, QC and the unit manager. The job ticket work package is then returned by the SMC to the clerk to complete the routing as indicated on the RCR form.

In summary, after the receipt and numbering of the job ticket, it could be in one of the following locations:

- Maintenance Office - in " Work to be Scheduled" job file.

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- Responsible department office - job is on weekly work schedule.

- In routing to ALARA, QC or OEM Director for signatures.

i - With the Supervisor of Management Control for planning, part hold, retest hold or awaiting PORC approval of the job ticket procedures.

the job Ticket is required to be kept for a period of six years. This requirement is included in TMI Unit 1 Administra-i tive Procedure (AP) 1024 governing required QC documentation.

i AP-1024 is based upon Reg. Guide 1.88 10/76 Rev. 2. AP-1024 only requires the retention of QC work requests and job tickets; however, Maintenance keeps all work requeses.

The GMS system has many advantages over the old, entirely manual, system of work requests. Through the use of the GMS t system and its forms the life of an open corrective maintenance item can be properly documented, tracked, closed out and referred to in the future quickly and easily.

2. PRIOR SYSTEM The manual work request system for controlling maintenance at TMI-1 was in effect until December 4, 1978, at which time the automated GMS was started and the computerized job ticket forms began.

The old work request forms evolved slowly over a period of approximately 5 years (originally promulgated by AP-1016 and then AP-1026). The computerized job ticket form took all of the information from the final version of the work request form i l

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4 and either computerized the informatior. or incorporated it on the RCR form.

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Under the prior system, work requests also could be written by any plant personnel. However, the processing of the identified work item was entirely different from the current system. The work request, once initiated, was sent to the initiator's supervisor for concurrence and then forwarded to the Supervisor of Maintenance. No planners existed so work requests were processed by the clerical staff -- e.g.,

numbering the work request and assigning account numbers, etc.

The Supervisor of Maintenance or his designee would then answer the substantive pre-job questions included on the work request form, such as whether a change / mod was required, whether the work was on a QC component, and whether the work involved nuclear safety. Next, the document was forwarded to the responsible discipline within the Maintenance Department for action.

The responsible discipline groups would do all the staff work on the work request, e.g., obtain the required procedure, get the parts, obtain QC approval. The lead foreman would approve the work request for work. Each discipline per sji did not keep track of the status of maintenance work in accordance with its importance. Important maintenance was discussed at the Monday, Wednesday, and Friday 9:00 a.m. Plan of the Day (P.O.D.) meetings. All daily and forthcoming plant evolutions and major and important maintenance items were discussed..

,In addition to the maintenance items that were picked out at the P.O.D., each week the lead foremen in each discipline would go through his drawer of active (not completed) work requests and select additional work requests to be completed.

His selection was based upon plant condition, knowledge of any system, systems or parts of systems that were shutdown or could be shut down and those items that were a continuing source of problems.

On the average, somewhere between 50 and 80 work requests were (and still are) generated in.one week. Because no automated system (i.e., computer program) was available under the prior work request system, it was virtually impossible to determine promptly which work requests were outstanding and which were complete. Some examples of jobs that were backlogged (but not improperly deferred) are as follows:

I BY WITNESS DYCKMAN

a. TMTA EXHIBIT 12: TMIA Exhibit 12 (W. R. #18471) is an example of a modification that was initiated by Metropolitan Edison Generation Engineering in Reading. This was not prompted by an NRC requirement. Generation Engineering Memorandum (GEM) 3074 of November 8, 1976 was written recommending the FW-V-5A/B operators and feedwater latch system j be modified. This recommendation was based on the desire of Generation Engineering and the General Office Review Board to upgrade TMI-l so that it would be able to withstand a single l

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failure during main steam accident conditions. kfollow-on letter GEM 0009 of January 31, 1977 included the recommended electrical changes to the FW-V-5A/B valves to support GEM letter 3074. A work request (#18471) to perform the work was written on November 11, 1976 and a follow-on Change /Modifica-tion Request (No. 849) was written on January 11, 1977. The change / modification was approved on February 10, 1977 and the work was slated for the March /May 1977 Refueling Outage.

The project was stopped during the 1977 Refueling Outage (without any actual work having taken place) due to the desire by Engineering to review the design criteria to be invoked.

GPUSC Licensing and Met Ed Generation Engineering re-evaluated the original design concept and recommended that the work be scheduled for the 1979 Refueling Outage (as documented by GEM letter 3007 of June 29, 1978). The work was completed during the 1979 Refueling Outage on March 16, 1979. All required signatures are either on the work request itself or on the

! attached addenda. All testing was completed on June 22, 1979, l

l the paperwork administratively reviewed by QC on Jul.a 26, 1979 and the work request signed off as completed on June 27, 1979.

Change / Modification No. 849 paperwork was completed on July 2, 1979.

Consequently, even though the original project was formulated in November of 1976 and not completed until July of 1979, the work was properly planned, deferred, scheduled and completed.

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BY WITNESS SNYDER

b. TMIA EXHIBIT 13: TMIA Exhibit 13 (W. R. #7.3310) was a task that came about as a result of the valve FW-VSA being closed during the 1978 refueling outage. This valve is normally open. In the open position, leakage, if any, is' minimal due to the valve being on its back seat during operation; however, if the valve is closed, it may leak. The plant was shut down on March 18, 1978 for the 1978 Refueling-outage. At that time FW-VSA (normally open) was closed, in order to do other maintenance work. As a result of thE valve being closed, water dripped on to feedwater valve 17A, damaging it. Work Request #23310 was written on March 30, 1978 asking

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for a drip shield to be installed under FW-VSA.

A plastic drip shield was installed at the time the problem was discov led. The shield adequately protected FW-V17A from the FW-V5A leakage. The FW-V17A valve operator was rebuilt as a preventive maintenance task during the 1978 refueling outage which corrected the internal and external damage reported on the work request. There were no reports of l

unsatisfactory operation of FW-V17A between the 1978 and 1979 refueling outages. An_ aluminum drip pan was installed in i AugEst of 1979 to close out the work request and to replace the plastic pan installed at the time the problem was identified.

Therefore, the maintenance required for this work request was carried out quickly in accordance'with its priority; however, the work request was properly held and closed out at a later date. ,

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l j BY WITNESS DYCKMAN

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c. TMIA EX.7IBIT 23: TMIA Exhibit 23 (W. R. #24246) is an example of a non-priority work request generated and completed in a timely fashion.

During the period June 12-15, 1978 (while in an un-

scheduled outage to replace RC-P-1C seals), the NRC conducted a i

routine inspection. The inspection report (50-289/78-14) identified an item, " Adequacy of Alarm Circuits to Monitor Operability of the Reactor Building Access Hatch Interlocks,"

that needed to be resolved by Metropolitan Edison. On June 15, 1978 at the conclusion of the NRC inspection, Engineering wrote work request #24246 to re-position one limit switch on each of the four containment building doors. The work request was given a 2A priority. Parts were required to repair the interlocks; in the interim, in addition to the already l

l installed alarms for monitoring the position of each door, I

administrative controls were placed into effect to ensure containment integrity. The required material was ordered on August 23, 1978 (P.O. 463701) and additional material was identified and ordered on January 4, 1979 (P.O. #66169). The material was received on February 8, 1979 and February 28, 1979 and released by QC for use on February 16, 1979 and on March 2, 1979 respectively. The shift superviser authorized com-mencement of the work on February 26, 1979. All four doors were completed on March 14, 1979 with final signoff on May 14,

/1979',lThe NRC conducted an additional routine inspection 4-

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(50-289/78-20) of TMI Unit 1 from Fovember 6-9, 1978 (prior to the door repair). The unresolved item (50-289/78-14-01) was commented upon, and it was noted that new limit switches were on order, the repair was scheduled for February of 1979, and satisfactory administrative controls were in place until repairs could be effected.

In summary, the maintenance identified on this work request was properly identified, planned, scheduled and completed in a timely fashion.

d. TMIA EXHIBIT 40: TMIA Exhibit 40 (W. R. 420801) is an example of maintenance that was initially thought to be high priority and was later cancelled in favor of a lower priority work request and change / modification. Work request #20801 was written on July 22, 1977, noting that the reactor coolant pump fl seal leak off recorder was intermittently alarming. The calibration was not suspect because 2&C Department had just calibrated the recorder per PM IC-79 on June 11, 1977. Nor was there a problem with low seal flow as both the seal leakoff recorder printer and local visual indication showed satis-factory leakoff. What actually was happening it was deter-i mined, was that the recorder was alarming on a non-alarm condition. W.R. #20801 was never approved to go to work by the Supervisor of Maintenance and subsequently was cancelled. A new work request (#21061) was written on August 17, 1977 which stated, " Seal leak off recorder, switch input alarms." A Change / Modification (C/M) request (#936) was written on August

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17, 1977 to change the recorder inputs as described in W. R.

1. 21061. This change was proposed for the following reasons:

(1) the recorder is a 12 point recorder, but points 9-12 are not used; (2) points 9-12 print downscale, points 1-4 print upscale and points 5-8 print midscale; (3) because the recorder is linear and must jump back to the beginning (1) when it gets to the end (12), the recorder requires that the timing be perfect and that there is no mechanical friction due to wear; and (4) if there is friction, point 1 prints before the recorder has travelled full scale and hence you get an alarm.

C/M #936 was instituted to switch the inputs to prevent the alarm. While the C/M was being reviewed by Engineering, tne recorder was again satisfactorily calibrated per PM IC-79 on November 23, 1977. W. R. #20801.was cancelled on July 31, 1978 because it no longer was required, due to the engineering work being done on C/M #936. Subsequently, Engineering decided that C/M #936 was not the proper solution and so C/M #936 was cancelled on November 16, 1978, prior to the initiators of the work. Work Request #21061 was cancelled on Lecember 15, 1978.

A new work request (#25957) was written on November 6, 1978 to l

increase the speed of the recorder balance motor to improve the recorder timing. The corresponding new C/M (#1238) was written i

on November 15, 1978.

The problem with the intermittent alarm on the recorder sometimes still occurs. Work request #25957 has been reduced from a priority 2 to a priority 3, based on engineering guidance; C/M #1238 is still open. Engineering feels that the ,

l C/M is a nice-to-do item but has no significant priority because the recorder functions and prints normally and only an occasional spurious alarm occurs. Work request #20801 probably should have been cancelled at the time C/M #936 was written and not a year later to avoid apparent confusion. However, the work was properly identified, researched and deferred as a low priority item.

When the transition began from the old work requeste and AP-1026 to the new computerized job tickets and MP 1407-1, several problems were identified.

Firste during the GMS test phase, prior to actual GMS implementation, approximately 2,000 work requests were entered into the computer to form a test data base. Unfortunately there was no easy way to identify on the work request itself whether the work request was entered into the data base; the computer printouts had to be examined to determine if the specific work request was part of the data base. Therefore, many of these test work requests were completed or cancelled without the computer being updated. Second, there was no l

mechanism in the old AP-1026 to identify the reason a work request might have been cancelled, nor a method to insure cancelled work requests were properly logged out. Third, no l method, procedure or mechanism existed in either AP-1026 or MP l

l 1407-1 that provided guidance in how to account for work l

request / job tickets that might get misplaced. And finally, due l

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to the fact that there were still literally hundreds of old work requests outstanding at the time of GMS implementation which vere not transferred to GMS, both AP-1026 and MP 1407-1 were left effective for a period of transition. In other words, there was no " clean" complete turnover from work requests to job tickets.

To help correct the above problems, a program of action was set up in late 1979.

The first item, updating the computer, was and is still being corrected by a monthly review of all outstanding work requests with an emphasis on clearing from the computer old work requests by cancelling / completing the work or providing a superseding job ticket. The second item, identifying why a work request was cancelled, was solved by utilizing the same cancellation codes provided for the newe job tickets. The third item was solved by the use of a newly developed form, the Misplaced Job Ticket Reconciliation Form, represented by TMIA l Exhibit 42.

TMIA Exhibit 42 (W. R. #13047 Misplaced Job Ticket Reconciliation Form) is one example of a form that was generated in December 1979 to account for lost work requests or job tickets. In the course of 6-7 years, approximately 30,000 work requests / job tickets have beer. written. Of these, a small percentage have been lost over the years. In late 1979 a review of all outstanding work requests / job tickets (as indicated by the computer) was conducted. All departments were i

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encouraged to " purge" their files; meaning that all old work requests that were incomplete or completed but not closed out or a very low priority should be reviewed, marked as to disposition, and returned to the Maintenance office for proper closecut. Upon the completion of this " purge", an additional review was conducted and all job tickets that could not be i

located were documented using the Misplaced Job Ticket Reconciliation Form. The form is not derived from a particular procedure, but was drafted in order to document lost paper.

The dates of completion or cancellation were obtained by one of several methodst (1) verification from the discipline work log that the work was cancelled / completed and the date; (2) location of a subsequent job ticket / work request that properly documented the cancellation / completion of the work; (3) verification from a foreman that he had performed the actual l

work described; or (4) verification from a foreman through field inspection that the component had been repaired.

Initially, after a field verification was performed, the date entered on the JT Reconciliation Form was the approximate date the work was performed or cancelled. Later, the date entered l on the form was the actual date the field verification was conducted. Hence, there may be cases where, e.g., a 1976 work request / job ticket was cancelled and replaced by a subsequent work request / job ticket; however, a completed date of 1976 may exist on the Job Ticket Reconciliation Form. This is the case with TMIA Exhibit 42.

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It should be noted that TMIA EXHIBITS 42, 43a and 43b (misplaced job ticket reconciliation Forms, WR #13047 and WR 924854) are similar examples of a record keeping problem, although it is not clear whether these documents would have been misplaced if the discovery room had not been set up and original completed / cancelled documents forwarded to the discovery room. The actual history of WR 13047 (WDL-P "/B) is as follows -- as reconstructed from logs. WR #13047 was written on December 19, 1975 (priority 2A) and approved to go to work on January 12, 1976. No work was accomplished. WR 13047 subsequently was cancelled on February 12, 1976, as indicated by the Mechanical Department Log. In all likelihood, no problem existed. Rather, oil was spilled on the pump while it was being filled and an individual identified this'as leakage. However the cancelled work request was not returned to the Maintenance office but was left in the Mechanical l

l Department WDL System file. On August 9, 1978, WR #24854 was written for WDL-P-7B; it was approved for work on August 14, 1978. In reviewing the WDL file, WR 413047 was probably noted as still open and hence the notation, " Cancel /to be completed under WR 24854" was written across the top of the WR. WR #13047 was then returned to the Maintenance office and filed.

Unfortunately, the cancellation date was not logged in the Maintenance Work Request Log. WR #24854 was satisfactorily completed and closed out on August 25, 1978.

In late November 1979, in response to a request to supply documents to the discovery room setup for the TMI-1 restart

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proceeding, Maintenance provided original completed / cancelled work requests along with xerox copies of outstanding work requests. Records were kept of all documents sent to the i discovery room. Our records indicate that the original work request #13047 was sent up to the discovery room in December of 1979. In May, 1980, however, WR #13047 could not be located at the Discovery Room. A check of the Maintenance Log revealed that WR #13047 was open. A check with the Mechanical Department was made and their log said the job was completed on February 12, 1976. Subsequently a Job Ticket Reconciliation Form on WR 13047 was filled out indicating the completion date of February 12, 1976.

TMIA Exhibits 43a and 43b reveal two problems. One, a completion date/ cancellation dare probably would not have occurred if the cancellation date of WR #13047 had been recorded in the Maintenance Log as required when the WR was turned into the Maintenance Office. Two, the problem of a misplaced paper form would not have occurred if the original WR #10437 had not been sent to the discovery room.

The fourth and final item for resolution as a result of the change from the manual work request to the computerized job ticket system, was the coexistence of two maintenance procedures, AP-1026 and MP 1407-1. Resolution of this matter currently is underway; all remaining old work requests are being duplicated on the new job ticket format and the old work requests are being cancelled. This change is not only desirable from a management viewpoint but is required to support the new Construction Operation Maintenance Expenditure  !

Control (COMEC) system that was implemented on December 22, 1980.

BY WITNESSES SHOVLIN AND DYCKMAN

3. OTHER CM DOCUMENTS In addition to the computer, which assists in automatically tracking a job ticket, a manual method is also available through the use of the Maintenance Log. This log is an unofficial document that is maintained solely as an aid for the CM Manager by the Maintenance clerk. MP 1407-1 requires that a number be assigned to all job tickets. A simple number checkoff sheet could be utilized. However, over time, the Maintenance Log has evolved from a simple number, description, assigned to, completion date log into the detailed log of today.

The current Maintenance Log contains the following i

l information: the date the job is processed; the number on the job ticket; a description of the work required or the problem i

involved; the applicable account number; to whom the work is I

assigned; the designated priority; whether the work requires l

issuance of an RWP; whether the work is on a QC component;  ;

whether the work has an effect on nuclear safety; whether the I

system is on the Environmental Impact list; whether the component is on the Nuclear Plant Reliability Data list; w w . y - ywq y. y e- - >-e- -e- .

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I 4 whether the work requires the ASME Code inspector to be notified; the status of the job ticket; the close out date of the job ticket and the change modification number, if applicable. The status column tells you the location of the job ticket, i.e., sent and returned from planning, QC, Alara or a particular maintenance discipline.

To reiterate, the Maintenance Log is an unofficial log established by the CM Manager as an aid, and there are no legal requirements for it to be completely filled in. Reflecting its informal nature, the Maintenance Log is not included in our audit or review program. The official documentation of work performed is the work request or job ticket itself.

The GMS System provides for a number of computer printouts to assist in tracking and locating work requests and job tickets. Like the Maintenance Log, these computer printouts are unofficial documents; but are used by management to tract,

! control and manage maintenance. The printouts available are described in detail in the GMS Corrective Maintenance System Users Manual. However, a brief summary of some of the printouts available and their uses follows:

Outstanding job tickets in job ticket order - This is a listing of all outstanding job tickets in numerical l

1 sequence. It is useful to check against the Maintenance Log to pick out job tickets that are (1) completed but still listed as outstanding in the computer; and (2) outstanding but not on the computer data base. This printout is used by the senior planner.

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Outstanding iob tickets in component deder - This is a listing of all outstanding job tickets in alphabetical order by each system. Within each system the components are listed alpha-numerically; for example all outstanding job tickets against component AH E 0020 A (air handling fan 0020 A) are grouped together. This printout is used by the CM Manager and SMC for planning purposes and used by the senior planner to avoid the issuance of duplicate job tickets.

Outstanding job tickets in department order - This is a printout of all outstanding job tickets arranged so that all of the jobs assigned to a discipline, e.g., the Mechanical Department, are grouped under the appropriate heading, such as Mechanical. Within each discipline section, the job tickets are in numerical order. This printout is used by each of the lead foremen to assist them in tracking job tickets assigned to their respective disciplines.

Priority Report - This is a printout of all outstanding job tickets arranged in priority sequence i.e., all the priority l's grouped together, priority 2's etc. Within each priority listing the job tickets are arranged numerically. This printout is used by the CM Manager to ensure that priority job tickets are being l

worked, planned, etc.

Current Status Hold - This is a printout of all outstanding job tickets in discipline section order.

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l Within each discipline the job tickets are grouped numerically under the respective " hold" code. Some examples of hold codes are: 02-part hold; 04-QC hold; 06-change modification hold; 07-engineering hold;

! 08-planning hold; 55-post maintenance test hold. This printout is used by the CM Manager and the SMC as an aid in determining where job tickets might be delayed.

Job Ticket Summary Report - This is a printout showing total numbers of outstanding job tickets, field l work complete job tickets and new job tickets issued for a l

selectable period of time. The numbers are broken down by discipline. This is utilized on a weekly, monthly, and l

annual basis by the CM Manager to track back-log and productivity.

Job Ticket Master Report - This is a printout listing all work requests that are on the computer data base. The listing is in numerical order. This printout includes all j work requests and job tickets whether worked or not, and paper work complete or not. This printout is used by the Unit #1 GMS Coordinator and the Maintenance clerk to verify correct data entry of various information.

Component History Report - This is a printout of all job tickets in which the final paper work has been signed off. This is a listing of all completed jobs in alphabetical order by each system. Within each system the components are listed alpha-numerically. If a job ticket

is closed out (whether completed or cancelled), it would appear here. This printout is used by Manager of l Maintenance, the Lead Shift Maintenance Supervisor, the SMC, planners or foremen to assist in locating previous jobs that may assist in their current work.

There are other special printouts available but rarely used by Maintenance. With the exception of the Component History Report, at least one copy of each of the above printouts is obtained weekly. An updated Component History Report is usually obtained monthly. Although useful now for management, these printouts are and probably will remain unofficial documentation for several years until (1) a sufficient data base has been built up to permit a good machinery history; (2) corrections are made to update the original test data that was inserted in the computer data base; and (3) a computer program idiosyncrasy with regard to QC/non-QC designation on the Component History Report is corrected. Specifically, the QC yes/no column in the Component History Report is based on limited data which was put into the computer memory on the basis of the information from GP 1008, t Quality Assurance System Lists. There is not a QC block on the l

computerized job ticket form and so the computer does not take QC information from the job ticket. When a job ticket is written the computer program compares-its data base with the component designator, i.e., the name and number of the component, as indicated on the job ticket. If the component l

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designator is located in its data base then the component is considered QC and a "Y" or "yes" is printed in the QC code column. If the component cannot be located in the data base then an "N" or "no" is printed in the QC code column. The problem with the Component History Report is thus: 1) if the component is QC on the data base but the component information is incorrectly entered on the job ticket, the printout will say N; 2) if the component has been incorrectly keypunched on to the data base and the QC component is entered correctly on the job ticket then the printout will say N; 3) if the component was never entered into the data base and the QC component is entered correctly on the job ticket, then the printout will say l

l N; and 4) if GP 1008 were read incorrectly and the wrong l

l component was entered as QC and a non-QC component is entered l

correctly on the job ticket then the printout would say Y.

Because of the above problems the Component History Report L is not used as an official document. An alternative under consideration is using the QC/non-QC information directly from the job ticket. In the meantime, in accordance with the NRC requirement that a machinery history be maintained for six years, machinery history is maintained on machinery history cards per AP-1026 and not yet through the use of GMS.

BY WITNESSES SHOVLIN AND DYCKMAN

4. SCHEDULING AND PERFORMING CM TODAY l The work request / job ticket system insures that Corrective Maintenance work is properly identified. However,

__ __ _ 1 __ . _ . . n to insure that the maintenance work is properly scheduled and worked in a timely fashion, several elements come into play.

These elements are the priority system, the Plan of the Day (P.O.D.) meetings and the weekly and daily scheduling meetings.

The present priority system was promulgated by a Superintendent of Maintenance memo in November of 1979. It was approved by PORC and the Unit Manager'as Revision 7 to MP 1407-1 in March 1, 1980. The memo promulgated by the

' Superintendent of Maintenance in November 1979 was utilized as guidance until officially approved as procedure in March 1980.

Because this guidance was an amplification of the previous prio.rity system, it met all approved procedures. When Revision

, 7 was approved in March 1980, the new priority system was implemented in its entirety. MP 1407-1 Rev. 7 was officially signed and promulgated on October 22, 1980, upon the receipt of new forms. The new priority system is set forth in Licensee Exhibit 2.

It is essential to understand the following priority assignment procedures:

(1) The recommended priority (upper right hand cover of the job ticket form) is filled in by the author of the job ticket. His supervisor approves that priority when he signs the supervisor approval block. If the job is marked as a priority 1 or 2, the reason for this high priority must be contained in-the work request. A priority 1 job must be approved by the Manager of Plant Maintenance, a Department Head or Shift Supervisor; l

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(2) The CM Manager may change the priority of any job ticket. He can upgrade or lower the priority without any consultation. (Of course, common sense and current practice dictate that he confer with and obtain concurren-ce from the Manager of Plant Operations or the individual l

who approved the job ticket before lowering any priority 1 or 2 work request.) A job ticket may be processed initially as a priority 1 or 2 and subsequently, it may be downgraded to a priority 2, 3, or 4. This change would be made in the computer and consequently would be in the Component History Report; however, it may not always show up on the job ticket or in the Maintenance Log.

Priority 1 job tickets are processed as soon as they are received in the office of the CM Manager and are walked through the approval process, i.e., obtaining the required procedures and signatures. The total processing time is on the order of one to three hours, depending on whether there are already approved procedures or procedures have to be written, an independent review is required by a qualified person (s) and QC and O&M Director signatures obtained. The priority 1, Jb l

l ticket is then immediately sent out to the responsible discipline for work. The job is then worked until completion.

When or if the job is re-evaluated and it ceases to require constant maintenance effort it ceases to be a priority 1 job.

In some instances, the TMI-1 Technical Specifications state that if a particular component breaks there is a time clock in

which it must be repaired or the plant must shutdown e.g., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 7 days. Items with a short " time clock" (24 or 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) would generally become priority 1; for longer " time clocks" (3 days, 7 days, 14 days etc.,) the job would generally be a priority 2. Priority 1 jobs under this system are generally safety-related, i.e., industrial safety, nuclear safety, safety and health of personnel (including the public),

or impact power generation capability. Priority 1 jobs are discussed in detail at the Monday, Wednesday, and Friday P.O.D.

Meetings and at the daily 4 p.m. scheduling meeting.

Priority 2 jobs are processed in the normal manner. These jobs generally have a reason listed why it is a priority 2, l e.g., because it affects or potentially affects plant operation or reliability. These jobs are planned and scheduled as soon as practicable. Many of these jobs depend on specific plant conditions or require parts or procedures. The jobs are held until the parts, precedures or plant conditions are met. The  !

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l actual repair time, once started, is generally less than two weeks (discounting delays caused by new problems noted when the [

l component is opened for repairs.) Priority 2's may show up on the P.O.D. list of work if they are of special concern to Operations, if they impact achieving a particular plant  ;

t condition or if the plant has-been placed in a special l condition to allow the work to take place.

Priority 3 jobs are processed.in the normal manner. These I are usually filler jobs that do not impact plant operations l

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e.g., build a work bench, repair a door, a redundant non-safety related component is malfunctioning, etc. These jobs are usually left for the shift maintenance staff to fill small time slots e.g., waiting for other paperwork to process, parts to come from the warehouse, at end of a shift, etc. These jobs may start and stop and could take over a month to actually complete. The job may not show up on a schedule for months after being submitted.

Priority 4 jobs are processed in the normal manner. These are usually change modifications that are not urgent. Once the change modification has been approved a priority 1, 2 or 3 would be applied as required. An urgent change modification would not fall under this category; rather, it would be processed by Engineering in several days, it's urgency determined by the job ticket priority supplied and confirmed.

The following sample work requests of each of the priorities are attached (Attachments 3 to 6):

(1) Job ticket C 4132 (FS-P-3) is an example of a priority 1 job ticket. The job ticket was written on September 24, 1980, by a Mechanical Engineer who also (properly) signed in lieu of his Supervisor. The job was priority 1 with a 7 day

" time clock". The job ticket required a special procedure which was written and walked through approval on September 24, 1980. The job was approved both by the CM Manager (then, the CM Supervisor) and the Shift Foreman on September 24, 1980.

The job was worked with engineering assistance and completed

- - .- .-. -- - . . . .- c and returned to service on September 30, 1980. The job was completed in 6 days, no overtime was utilized and the work was performed on daylight facilitating engineering coverage. Final review of the paperwork was completed by QC on October 6, 1980, and signed off by CM Manager (then, the Supervisor of Corrective Maintenance) on October 7, 1980.

(2) Job ticket C 4289 (DF-P-1B) is an example of a priority 2 job ticket. The DC fuel oil pump on the "B" emergency diesel would not start. The job was priority 2 because the "A" diesel was still fully operable. The job ticket was written and received in the Maintenance Office on October 13, 1980. It was routed and approved for work on October 23, 1980, and work commenced on October 26, 1980. The work was completed on November 14, 1980, with final review and closeout on November 25,,1980.

(3) Job ticket C 3186 (GS-V-0013) is an example of a priority 3 job ticket. The job ticket was written on May 9,

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1980. The job is definitely a priority 3 as the missing test lift plate for GS-V-13 would only be required for the cycle PM of testing reliefs (5 year cycle). The job ticket was received in the Maintenance office on May 16, 1980, and approved for work on May 20, 1980. The job was carried as a filler job and eventually completed by a machinist on September 10, 1980, with the paperwork closed out on September 16, 1980.

(4) Job ticket C 4408 (TMI Bldg. 2) is an example of a priority 4 job ticket. The job ticket was written on October 1

29, 1980, and the recommended priority was a 1. It was obvious from the description of the work required that a change /modifi-cation request was required and that the job met none of the criteria for a priority I or 2. The Maintenance office issued change / modification request #1524 on October 31, 1980 and assigned a priority 3 to the original job ticket in concurrence with the originating supervisor. The job ticket was entered on the computer as a priority 4 in conformance with procedure.

When the change / modification is approved, the job ticket will be issued to the field for work as a priority 3.

The priority system is one tool used to assist in determining the planning, scheduling and working urgency of a job ticket. Another element is the Plan of the Day meeting.

This meeting is held on Monday, Wednesday, and Friday of each week at 9:00 a.m. The attendees generally consist of the O&M Director, Manager of Plant of Operations, Shift Supervisor, Plant Engineering Director, Corrective Maintenance Manager, Supervisor of Management Control, a representative from QC, a representative from QA, currently a representative from the startup group and a representative from materials management.

The P.O.D. form is a computerized form which is updated prior l to each meeting. The P.O.D. form contains: plant conditions; operations / tests planned (which includes items of major concern for Operations, Maintenance, Engineering, QA/QC, materials management); primary and secondary chemistry results and Technical Specification items (surveillances for past, current, I

l l

and future weeks). During the P.O.D. meeting, which generally lasts 45 minutes, the P.O.D. form is run through item by item.

Each of the items in the Operations / tests planned section has a cognizant individual assigned by name on the form. This individual reports on his progress, difficulties, etc., and entertains questions from the groups. At the conclusion of the meeting, the Manager of Plant Operations may list additional maintenance items that are of immediate concern to him. These may be processed as job priority 1, 2, 3 or 4 jobs, as appropriate. Additionally, each Tuesday the Manager of Plant Operations sends to the CM Manager and the SMC a list of jobs that he would like to see scheduled either the following week or as soon as possible. This assists the SMC in assigning jobs to the planners.

The final element in the planning, scheduling, and working of a job ticket is the Weekly Work Schedule and Daily Scheduling Meetings. The input from Operations Department for l

the Maintenance weekly work is gleaned from P.O.D. meetings, inputs at the daily 4:00 p.m. Scheduling Meetings and the list submitted by the Manager of Plant of Operations each Tuesday.

The Weekly Work Schedule is generated each Thursday to commence on the following Friday. The CM Manager gives each discipline job tickets to be worked the next week. The lead foremen l schedule these jobs on the work schedule. The schedule is gone l

over in detail at 3:45 p.m. each Thursday with Operations, HP, QC, Startup and Maintenance. Any coordination or plant t

I l

l l .

~

I condition problems are identified at that' time. Each day at 4:00 p.m. Monday through Friday a Daily Scheduling Meeting is held. The meeting covers the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of work and discusses the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of work. The Weekly Work Schedule j is updated at this time.

i After the previous detailed descriptions of the inner workings of the Maintenance Department, an overview is appropriate. Assume we have three job tickets that are received on Tuesday, a priority 1, a priority 2 and a priority

3. These tickets would be handled in the following manner.

l The priority 1 ticket is rece'ived and Operations is called to i confirm the priority. The senior planner informs che CM Manager of the priority 1 and processes the job ticket, i.e.,

obtains the necessary numbers, procedures, etc., and walks or has walked through the job ticket. When it is ready to work, che senior planner presents'the job ticket to the CM Manager for review and approval. After the priority 1 is approved, the lead foreman of.the applicable discipline is called and given the job ticket. The lead foreman immediately stops a lower l

priority job and assigns people to the project. While the job ticket was being processed, the necessary coordination work with Oparations, Rad-Con, and any other support groups has been set up. The job is worked to completion. Meanwhile, the senior planner is processing the priority 2 and 3 job tickets.

Let us assume the priority 2 job requires that parts be identified. The priority 2 job is processed and sent to l

planning. The priority 3 job requires no planning, so it is processed and sent to the CM Manager to be placed in the " Work to be Scheduled" file. When Thursday comes, the priority 3 job is placed in the responsible discipline file. The job ticket is picked up by the lead foreman of the applicable discipline t and placed on the schedule for the following week. The job may be scheduled to be performed on a certain day and shift or it l

l may simply be listed on the schedule as a " filler" job. The priority 2 job ticket will be planned based on information that the SMC has with regard to its urcancy. Since not all jobs can be planned at once there is obviously an additional desired order or priority as to which priority 2 jobs get planned first. This order is not based solely on the date the priority 2 job ticket is written; rather, it is based on the concerns previously discussed, e.g., importance of work, potential safety significance, potential shut down item. The availability of parts is checked, the work package is put j together, the necessary signatures are obtained and the job ticket is sent to the CM Manager for approval and placement in the " Work to be Scheduled" file.

As can be seen from the above scenario, many priority 3 jobs in actuality may be worked much faster than a priority 2.

However, this is the way the system is designed. A priority 3 is a very simple iob with little or no planning or parts required; hence, it is easily processed and ready to work.

In summary, priority 1 job tickets are noted, worked upon

. . ~ . -- .- . - - - . . - - .- -. -.

l l

quickly and monitored to conclusion. Priority 3 jobs are usually worked fairly quickly because they are mainly short durations or filler jobs. Priority 2 jobs are tracked using a combination of computer printout review, P.O.D. meetings, Daily Scheduling Meetings, and Operations Department work lists. The

! overall checks are the independent monthly reviews of the l

printout by the SMC and the CM Manager (or his designee).

l l Through the use of the Weekly Work Schedule, which is promulgated to the operations, Rad-Con Quality Control and all of the Departments which provido schedule input, the various disciplines are kept informed of the work which is scheduled for the upcoming week. The job tickets which are sent to QC i for review are determined by the Maintenance staff utilizing GP-1008, the QA Systems List. The QC Department reviews the l

packages and indicate; on them with a stamp any work which they I

wish to surveil. The QC Department requires four hours advance notice of the start of any job that they have put on their schedule to observe. The CC monitor assigned observes the task and ensures verbatim compliance with the procedure. He identifies any deficiencies in the procedure and issue a Quality Deficiency Report to the cognizant Department Head to ensure that procedures are corrected, if any deficiencies are noted. In particular, the QC inspector assigned observes the portions of the task as indicated by QC witness / hold points.

Any deficiencies noted during the performance of the task are required to be documented as Quality Deficiency Reports (CDR) l r

l

_.. -m 2 _. __ . . _ _ _ . _ . _

, . +-

or Material Nonconformance Reports (MNCR). These documents are reviewed for potential reportability by the OQA Section (QDRs) or QC section (MNCR). Any deficiency or nonconformance found to be potentially reportable is brought to the immediate attention of the Unit Manager and Licensing, if applicable.

The documents (QDR, MNCR) are then forwarded to the cognizant party for evaluation and disposition. The QC inspector also files an inspection report, indicating the results of the task witnessed.

l The work packages for jobs that would open the Reactor Coolant System or that are in the "ALARA review" areas that are outlined on lay-out drawings provided by radiological engineering are reviewed by the ALARA group of the Rad-Con Depart'ent.

m The ALARA review provides recommendations for work methods, establishes what monitoring is required, specifies the design and quantity of shielding, etc., to essentially t

choreograph the task in a way that will minimize the exposure of employees performing the task and reduce the possibility of

! any threat to the health and safety of Ehe public.

The Rad-Con Department is made aware of the needs for Radiation Work Permits via the Weekly Work Schedule. The RWP applications, for the work scheduled, are submitted by I maintenance at least one shift in advance of the start of the jobs to provide adequate time for the Rad-Con technicians to make radiation surveys and prepare the RWP. In addition to making radiation surveys and preparing RWPs, Rad-Con personnel t

are available to assist in dealing with any special needs that l l

arise, such as setting up additional controlled areas and l providing necessary anti-contamination clothing and materials.

BY WITNESSES SHOVLIN AND DYCKMAN

5. SCHEDULING AND PERFORMING CM UNDER PRIOR SYSTEM Under the old work request priority system described l

below, the definitions and hence the application of the priorities were much more general than under the new system.

Priority 1 - Urgent; it may be necessary to call in personnel or work overtime.

Priority 2 - Routine; accomplish during normal working day.

Priority 3 - Low Priority; accomplish as time and personnel are available.

As can be seen from the definitions, no working time interval was established. Also, the priority did not reflect whether a job might be of any safety concern (nuclear or industrial).

Per the then-existing procedure AP-1016 or AP-1026, "the person initiating the work request shall assign his estimate of the priority, which may be changed at the discretion of the Supervicor of Maintenance." Consequently, the janitor could write a priority 1 work request to fix a leaky faucet because to him it was urgent. The procedure did not require the priority to be physically changed on the work request (some were, some were not) if the Supervisor of Maintenance decided the priority was different than recommended.

I

Work requests were scheduled and completed in a timely manner consistent with safety, plant conditions and/or considerations prescribed by the Supervisor of Operations and the Superintendent of Maintenance as discussed at the P.O.D.

meetings.

Examples of high priority work requests that were handled in a timely and proper manner are as follows:

BY WITNESS SNYDER (1) TMIA EXHIBIT 11. This exhibit (W.R. #21910) is an example of a job that was a high priority and had normal immediate steps taken which are adequate for this type of problem. The work request was written on November 14, 1977 and the repair was made the same day. The Maintenance Supervisor recognized that the long term repair required was to repack the valve, thus it was designated a 1 D, indicating that it wac l

a top priority work item when the plant was shut I

down. It would not be unusual for a valve packing to be adjusted several times prior to scheduling a repack. At the first shut-down opportunity, the 1978 refueling outage, FW-V17A was repacked (on April 12, 1978) as evidenced by TMI-1 Clearance Control Document No. 516 dated April 12, 1978, and was returned to service the same day. The work request was then held open for observation under operating conditions until six months later. It is not unusual l

i i

to obsarve a repair for this period of time to ensure that the repair is complete and holding properly.

The work request was closed out on November 27, 1978.

i This work request was properly handled as a lA work request. The required signatures are on the attached packing traveler.

BY WITNESS DYCKMAN (2) TMIA EXHIBIT 19. This exhibit (Work Request 19590) i is an example of identified work that was properly l scheduled for an outage. The work request required the removal of one nut at a time, relubrication and retorquing of these nuts, located on the upper and lower primary manway, auxiliary nozzle on the z-axis and the primary handhole of each steam generator. A little background: each refueling outage a work -

request is written to remove and reinstall the above l

. listed handholes and manway covers to allow eddy l~

current testing (for leaks) of the steam generators. ,

After the handholes/manways are reinstalled, a work request is written to remove, relubricate and retorque each handhole/manway nut after the subsequent heat-up and cooldown. This is a preventive measure to insure that all the covers are l

tight. The heatup would be the heatup at the end of the current refueling outage and the cooldown would occur at the next outage whether planned or not.

l l

i l

~^ ^

i . . - - . .- . . - . . L. . - - - .-- . . _ . . . . . . . ,

.. l

)

l l

Therefore Work Request 19590 was written on April 7,

_ 1977?during the 1977 Refueling Outage. It was intended'that the relubrication, retorquing etc.,

'would be accomplished during the 1978 Refueling i

Outage (since no other outages were scheduled in

. ~ ,

.between). The Supervisor of Maintenance wrote the l

procedure for WR 19590 on July 14, 1977.

On September 15, 1977, TMI Unit 1 was shutdown for an unscheduled outage due to a condenser vacuum problem.

It was decided to complete WR 19590 since a

/heatup and a cooldown had now been conducted.

The procedure that hed been written was approved by PORC and the Unit Superintendent on September 16.

Addendum #1 to'WR 19590 was written and approved by PORC and the Unit Superintendent on September 18.

! Addendum #1 permitted the~ Supervisor of Maintenance or the Unit Superintendent to decide to retorque the manway/handhole nuts without nut removal if the lubricant on the studs was adequate and two torque-check passes were made. The addendum also required tha,t any closure torqued under this addendum should be inspedted at hot shutdown for leaks and any closure not completely torque checked must be inspected at hot shutdown. Work request 19590 was

[ ., completed during this outage on September 21, with

~

t e except, ion'6f the bottom primary manway of the "B" ,

h l A

. I * - .,

i  ?

?

OTSG. The manway was not completed at this time due to high radiation and was properly deferred in accordance with Addendum 41. The work request was subsequently scheduled to be completed during the 1978 Refueling Outage. Planning for the 1978 outage included eddy current testing for both the "A" and "B" OTSG. A new work request (#22878 dated February 18, 1978), to open and close the manways on both OTSG's was written. Work request #22878 was completed on April 28, 1978 during the 1978 Refueling Outage. This work request (#22878) was surveilled by QC and a report of satisfactory closure of all primary manways/handholes is contained in surveillan-ce report 78-71 dated April 11, 1978. Work request #19590 has this surveillance report number entered in block 22 with a QC signature. Work request fl9590 was noted as not being closed out when planning for the 1979 outage. It was correctly closed out by operations on January 16, 1979, by QC on February 1, 1979 and by the Supervisor of Maintenance on February 2, 1979.

BY WITNESS SNYDER (3) TMIA EXHIBIT 21. TMIA Exhibit 12 (WR #22268), which involved a problem with the manual operator on valve MU-V74B on December 27, 1977, is an example of a job r

that was worked immediately. The repair was l

l 1

[ . . . _ . . _ - . . . . . .. _.. . . _ _ _ .

satisfactorily completed and this valve was successfully operated as recent as January 11, 1981.

However, the indicator pin had not been replaced and this was the reason for not closing out the Work Request prior to the Job Ticket system purge on November 5, 1979. If another work request were to be written to cover this aspect of the originally identified problem, it would have the lowest possible priority assigned to it, as the position indicator is not really necessary to determine the position of this valve. This valve is used in the full open or full closed position and is placed in that position manually, thus the valve would be positioned by feel rather than by an indicator on the valve stem. Few manually operated valves have position indicator pins on the stem. A position indicator would be advantageous on a valve used for " throttling" (intermediate positioning); however, MU-V74B is not l used for throttling. In summary, although WR 922268 was initiated at the end of 1977, that portion of the work which remains outstanding is of very minor l significance, if any. The important aspects of the job were completed in one day.

BY WITNESS DYCKMAN (4) TMIA EXHIBIT 22. This exhibit (WR 625166) is an example of work that was initially deemed desirable l -

by Engineering but later cancelled by Engineering because it was replaced by a better modification.

t W. R. 925166 was written on September 5, 1978 to attach chains to hammers and drift punches so the tools which could be used to disassemble the Reactor

, Building Personnel and Emergency Hatch linkages in an

(

! emergency would not inadvertently get lost. A l

change / modification request (No. 1175) was written on September 8, 1978 and subsequently cancelled on September 20, 1978 when Engineering determined that a change modification was not desired. The hammers and drift punches were in fact placed in the doors, but were not chained in place. Discussion by Engineering with the vendor, Chicago Bridge and Iron, revealed

, that several modifications could be done to the doors to preclude the requirement for hammers and punches.

Hence on January 15, 1979 two work requests #CO371 and #CO372 were written to perform eight separate l

l modifications on the Emergency and Personnel access hatches, respectively. A change / modification request (No. 1281) was written and approved on January 25, 1979 to perform the eight modifications during the next outage. W. R. #C0372 on the Personnel Access Hatch was field work completed on March 29, 1979 with subsequent final signoff on September 17, 1979. W.

R. #CO371 on the Emergency Access Hatch had CM 1281 1

items 1, 2, 5, 7 (which included the door safety modification) completed on March 29, 1979 with subsequent final signoff on September 17, 1979. A follow-on work request was written to complete C/M 1281 on the Emergency Access Hatch. In November of 1979, while reviewing the outstanding work request files, W. R. #25166 was correctly cancelled as the work was not required and had been intenticnally superseded by C/M 1281.

(5) TMIA EXHIBIT 39. This exhibit (W. R. 423635) is an 4

example of a high priority work request written and properly deferred to the next outage. The WR was written because four CRD thermocouples each had a bad indication on the computer (the computer would indicate bad by a series of ???? vice a temperature 1

I reading). At the time the WR was written (April 28, 1978) TMI Unit 1 was shutdown for the 1978 Refueling i Outage. The theraocouples were okay, but a section of cabling supplying these four thermocouples was bad. The item was reviewed by PORC. The loss of the four thermocouples was deemed to be not significant from a nuclear safety viewpoint because the thermocouples were not a Technical Specification l.

requirement but were installed to prevent damage to a

$20,000 piece of equipment, namely the Cor. trol Rod i

Drive Motor itself. Because all other CRDM L

4 thermocouples were operational and the Intermediate Closed Cooling System was fully operational, possfble damage to these four CRCM's was virtually nil. If in fact a CRDM did fail, it would have no effect on the ability to safely shutdown the reactor. The material to support this work request was requisitioned on June 6, 1978, received on March 8, 1979, and accepted by CC and released for use on March 9. The field work was completed on June 28, 1979, tested and released for normal use the same day, reviewed by CC on July 2, 1979 and signed off as completed on July 16, 1979.

This particular work request is an example of maintenance's quick response to check the problem, as well as a properly documented deferral until the material and plant condition were available.

BY WITNESS SNYDER An example of lower (non-priority) work requests handled in an appropriate time frame is TMIA Exhibit 15.

TMIA Exhibit 15 (W. R. #20856) is an example of a task that would have been considered " fill-in" work. Priority 2A indicates there was not an immediate need to have these "various" hydraulic shock and sway suppressers (" snubbers")

rebuilt and tested. This work request should have been classified as a priority 3 as these snubbers were placed on the shelf to be used in the event of a problem with an installed

)

4 snubber of the same size and type. At the time of such replacement a work request would be written to accomplish the testing, appropriate adjustment and installation of the spare from the shelf. The snubber identification and test results are kept on file in the Mechanical Engineering Department so that it is known at all times which seria1 number snubber is l installed at any of the approximately 260 locations in the plant and the results of the testing done on the snubber. Any defective snubber that is removed would then be identified as requiring overhaul and would be held with others until a sufficient number accumulated that a Work Bequest, such as 20856, would be initiated to overhaul them.

Several of the snubbers that were overhauled per W. R.

420856 remain on the shelf as of January, 1981 as rebuilt spares to be tested and installed when needed. W. R. (20856 was closed out on September 5, 1978. Finally, in addition to the above described on-going corrective maintenance activity, there is a program for testing and returning to service a specified number of snubbers each year. This work request was properly treated as to priority and was accomplished in a routine manner.

A problem which was noted early in the work request system but was only recently corrected by Revision 7 to MP 1407-1 was the continuing use a work request for work in addition to the originally identified problem. This is currently called a blanket job ticket. Though not specifically covered under

prior procedure, the blanket work request nevertheless was utilized in practice; however, everyone handled these job tickets differently, resulting in a major paperwork problem associated with the old work requests. Because no computer program existed to help pick out duplicate work requests, ten, fifteen or twenty work requests could be writtes to perform a task that was being done under one work request already held by the discipline. Conversely, new jobs that should have had a separate request. written for them were being done utilizing a blanket work request. Examples of these problems are as follows:

BY WITNESS DYCKMAN (1) TMIA EXHIBIT 16. TMIA Exhibit 16 (W.R. #15350) is an example of a priority work request that was generated to perform a specific task, change the IC-F-1A/B filters, but was utilized to perform the task more than once. W. R. #15350 was generated on 5/11/76. It was approved through QC on May 11, 1976 and authorized for work the same day. The Shift Supervisor approved the work request for work on May 11 and the equipment was tagged out (Tagging Order No. 46). Both filters were changed (May 18, 1976) and the filters tested and returned to service on May

18. However, instead of closing out the paperwork, I the work request was held for observation and, if necessary, additional filter change outs. This l

l i

practice was not unique; however, the work requests were not normally signed off in blocks 20 and 21 until the work was finally completed.

This work request should have been closed out either at the time of completion or at the end of 1976. It was improperly left open and utilized on February 4, 1978 to perform a filter changeout on IC-F-1A/B again. The work request was signed off by ,

the Shift Supervisor on February 4, 1978; reviewed for administrative accuracy, use of QC material and performance by QC on February 13, 1978 with QC noting that surveillance of the work had not been performed ,

(nor was it required since no QC hold / witness points had been 1..dicated by a cover stamp) and finally closed,out by the Supervisor of Maintenance on ,

February 15, 1978. Current practice is to allow a blanket work request, normally generated for minor, i repetitive ~, non-QC maintenance, to remain open for a l maximum of one year. In a few selected, controlled cases a single work request is utilized to perform a repetitive function on a QC component during a short time frame, usually less than a month (i.e.,

MU-F-4A/B, seal injection filters changeout which is performed repeatedly during plant heatup after cold shutdown due to crud buildup on the filters).

In summary, although this work request was improperly utilized twice, all identified work was in

fact properly authorized, documented as completed and properly tested and restored to operation.

BY WITNESS SNYDER (2) TMIA EXHIBITS 17a-f and 18. The documents in these exhibits are work requests that deal with pump seal

! leakage on several river water pumps, but mainly Nuclear River Water Pump 1B. This series of work requests is an example of one type of ongoing, I,

repetitive task that is required to maintain any industrial plant. Adjusting packing leaks is a never ending chore with the present state-of-the-art. In som'e areas, the problem is worse due to the abrasiveness of impurities in the water which normally passes through the seal to keep the seal lubricated. Such is the case at TMI-1 and there is l

l presently in progress an Engineering Project for upgrading the TMI-l River Water pumps (see Attachment

7) which includes an improved lubrication water system.

It must be understood that the leakage identified in these work requests is necessary leakage, it occurs by design to provide lubrication of the pump shaf t rotating within its seal. The real problem which Maintenance must take care to avoid is the absence of pump seal leakage. When this happens, the lubricant which is saturated into the seal l

l 1

[

material for such emergencies is rapidly used up and the seal burns up and is thus lost. In light of this fact, the obvious question is "how much leakage is i enough?" The answer is, enough to keep the seal well lubricated, but not so much that it travels up the shaft and gets slung around the pump base and onto the floor, rather than running into the seal water catch ares and to the floor drain as intended. Thus, the undesirable part of the seal leakage situation on NR-PlB was that the floor was always wet around the pump base -- a house-keeping problem. However, because the water is river water, non-radioactive, and it does not come in contact with any components which.are radioactive, its presence on the floor does not pose a threat of any kind to the health and safety of the public. Nevertheless, this series of work requests illustrates Maintenance's prior paper l

work problem. At the time these WR's were written, more paperwork was created than was needed to accomplish the task of adjusting pump packing.

Moreover, the priority assigned to this job was inconsistent with the seriousness of the problem.

l l Today, the priority would be a 3. However, an.

examination of the manner in which these work requests were handled indicates little discrepancy in i

the. conduct of the work under the prior and current l

l

l system. Under the prior system, it occurred rather normally that a work request would be held after a packing adjustment to see if the adjustment was adequate before closing out the work request. In those cases where further adjustment was required, the Maintenance man would go make another adjustment utilizing the same work request. At the same time, the Auxiliary Operators would see the leakage and they would write another work request. Consequently, there would be several coincident work requests on a given task. This system was cumbersome to administer and is avoided by the much improved administrative control that we have today. The Auxiliary Operators made visual checks of these running pumps daily and there were frequent adjustments made to pump packings. Some of these adjustments would result in the absence of work requests being initiated for a period of time which can be seen from the attached bar chart. (See Attachment 8) Most of these adjustments were not documented; however, evidence exists to show that they were, in fact, made. W. R.

1. 15741 (Attachment 9) shows a period of time from June 9, 1976 through February 10, 1978 during which 1200 man-hours of pump packing adjustments were accomplished.

i Under the present system, the outstanding work items on a given component are reviewed any time a l

t __ . . . _- -

r ._ ._. . _ _ -_ ___ _ ___ __. .

s new work request is received on that component.

, Duplicate work orders are not entered'into the system if there is already a job ticket in place to cover I

the task. The cognizant discipline lead foreman is contacted to ensure that the work item is on the work schedule if the job is workable or to verify status if the job is not workable at present. Job tickets that have been worked, but not closed out are tracked by the CM Supervisor or his designee to ensure that job close-outs occur in a timely fashion.

In conclusion, with respect to this particular task, i.e., packing adjustment, under the present j system, a blanket job ticket on this work would be issued and allowed to remain cpen for some prescribed i

amount of time during which this repetitive task can be performed, as specified in MP-1407-1. A provision is made for reporting each performance of the task so that machinery history is retained. Under the prior system, as evidenced by TMIA Exhibits 17a-f and 18, these packing adjustment work requests were handled l without complete documentation. However, the work was performed properly, in a manner consistent with current practices.

(3) TMIA EXHIBIT 28. TMIA Exhibit 28 (WRf15349) is a work request that was written during the 1976 refueling outage to change both the 1A and IB Makeup l

and Purification Filters. This was accomplished prior to the plant start-up following refueling and should have been closed ou. at that time; however, the work request was held open and was utilized for the following filter changes as evidenced by work request line 19 and the attached CC Accept tags and Tagging Applications:

a) MU-F-1B - Changed 12/2/76 (Plant was shut-down) l b) MU-F-1B - Changed 1/14/77 c) MU-F-1B - Changed 5/6/77 (Plant was shut-down) d) MU-F-1A - Changed 5/8/77 (Plant was shut-down)

• e) MU-F-1A - Changed 8/17/77 j *f) MU-F-1B - Changed 9/28/77 (Plant was shut-down)

• Work Requests 21050 and 21405 respectively, were written to change out the 1A & IB filters however, they were cancelled and WR #15349 was used to l

l accomplish the work.

l Administrative procedures presently in effect provide l

l for the review and close out of work requests following completion of the work. An exception to this is that repetitive type tasks can be covered by a " blanket" work request, as previously discussed. In this instance, WR l

l

... L -

2 ,.w

1. 15349 should have been closed out at the end of 1976 and a new work request written for 1977.

(4) TMIA EXHIBITS 33a-m and 34 a-k. These work requests involve changing filters on AH-F4A and B and AH-F6A and B. They were written over a two year period from May of 1977 to May of 1979. One of the 24 work i

requests is incorrectly marked as being nuclear safety related. Nine of the 24 are incorrectly marked as yes, in answer to the "Is the work on a QC component as defined in GP-1008?" question. GP-1008 specifically mentions AH-F4A/B and AH-F6A/B on page 10 of 63 and for both units the QA applicability is referenced as specified in notes 10 and 12. Notes 10 and 12 on page 2 of 63 state:

10: Included for structural design aspects; electrical or filter aspects are not within the scope of the Met Ed QQA program.

12: Purchase orders for replacement-in-kind parts and components need only specify commercial quality and require only CC review to verify replacement-in-kind status.

j Thus it is clear that these filters are not within CC scope.

While these filters are not within the scope of QC, nor is the work involved in these work requests 9

l nuclear safety related, they should be replaced in a timely fashion. The build up of dust on these filters would very gradually reduce the air flow through them and cause the temperature to rise in areas of the control Building where there is equipment that would be sensitive to high tempera-tures. Because lack of air flow or rising tempera-tures was not reported as a problem during the time these work requests were generated, it is highly probable that the system was doing its job satis-factorily. Nevertheless, it was not a good practice to delay replacement of these filters.

The replacement of AH filters has been given greater emphasis in the past year. The Preventive Maintenance program now directs Maintenance personnel 1

to inspect all AH filters monthly and to perform AH filter changes when prescribed differential pressures are reached. Utility maintenance personnel are assigned to the PM group with the changing of filters being one of their primary functions.

BY WITNESS SHOVLIN AND DYCKMAN l

l 6. RECENT STATUS OF CM AT TMI-l At the Time of TMI Unit #2 accident on March 28, 1979, there were 1299 outstanding job tickets. This number was markedly reduced in the following manner:

l From March 29, 1979 to 1427 Job Tickets Were Written December 31, 1 979 924 Job Tickets were Completed 823 Job Tickets Were Cancelled

(

e From January 1,,1980 to 2493 Job Tickets Were Written December 31, 1980 2132 Job Tickets Were Completed 470 Job Tickets Were Cancelled TOTALS March 29, 1979 to 3920 Job Tickets Were Written December 31, 1980 3056 Job Tickets Were Completed 1293 Job Tickets Were Cancelled As of January 1, 1981, there were 870 job tickets outstanding.

One of these 870 is a priority one. There are 187 priority twos, 585 priority threes, and ninety seven priority fours.

BY WITNESSES SHOVLIN AND SNYDER D. OVERTIME POLICY There are occasions when the work schedule for a particular task requires the use of overtime to compensate for delays caused by factors over which management has no control, or to provide for the timely completion of work that could delay the accomplishment of an entire project. These occasions must be judged on a case-by-case basis to determine the amount 1

l of overtime to be utilized. Overtime assignments are made with an effort to equalize the overtime work offered among personnel I

of the same classification in accordance with the contract I

between Local Unions 563, 603, 803, 1261 and 1482 of the IBEW (AFL-CIO) and Met Ed. The use of overtime is acceptable to accomplish important tasks in a timely fashion, provided the guidelines of NRC IE Circular No. 80-02 are followed. The O&M Manager's Operating Memorandum 80-01 directs the Operations and l

l Maintenance Departments to comply with this NRC memorandum. A I copy of each of these document is attached. (Attachments 13 and 14.)

The present overtime policy in force at TMI-1 is much more ,

restrictive in the use of overtime than the previous policy, which did not specify the number of consecutive days that could be worked, nor provide a recommended number of total hours to be worked in a week. However, previous policy did state that, "All Managers / Supervisors are expected to plan their operations in a manner that will minimize overtime wherever possible without seriously affecting the effectiveness and efficiency of their own or other departments interfacing with them." Under no circumstances were employees forced to work overtime. As long as sufficient notice was given by the employee, he/she would be excused from an overtime job. At the same time, absence without prearrangement was not condoned, as indicated in Attachment 10.

It should also be noted that under the previous policy when employees were asked to work longer than nine hours, they were given a meal period and a meal was provided for them by Met Ed. The meal period would last from one to two hours. In addition, there were work breaks observed in the middle of each l

half of the normal eight hour shift, and a half hour (minimum) meal period in the middle of the normal shift which provided several rest periods for the employees. If their work location I

was in the radiologically controlled areas which required them to be dressed in anti-contamination clothing, they would leave these work locations from one-half hour to forty-five minutes l

before quitting time to allow time for undressing, body

._._ J ^ .._ l.

- ' ' ~

E~'~

surv'eys, dressing and washing-up. (See attached typical 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> work day, Attachment 11). All of these practices are applicable today.

Finally, although significant amounts of overtime are shown in TMIA Exhibits 44 a-h, it is important to recognize that even in these cases, which in all likelihood represent the l

hours of the highest overtime workers on the job during the period of time in question, the current guidelines for overtime were followed 88 percent of the time; that is, using the data in these exhibits, these eleven employees over a seventy-eight week period (858 man-weeks) only worked more than thirty-two hours overtime in one week, per the current guidelines, for 101 man-weeks, which is twelve percent of the total time period.

Moreover, there was never an instance when greater than a 12-hour shift was scheduled. For purposes of comparison, the overtime of Norman Reismiller during his tenure at-TMI has been plotted in Attachment 12.

l BY WITNESS BALLARD l

E. THE REVIEW OF MAINTENANCE ACTIVITIES l

l There are several checks and balances administered by the Nuclear Assurance Group to insure that maintenance is properly performed and documented. Briefly, Quality Assurance's function is to review site procedures from a QA standpoint, and to establish adequate site monitoring and inspection programs necessary to verify conformance with Quality Assurance Program

! requirements. To insure that the function of Quality Assurance

^^^'^^^^^^--

^ ^ - ~ ^ - ^ ^ -

. - . - . . . . . - - . _ . _ X. - . ~ .._.2 7 2:^ T:: '

l is properly carried out with respect to maintenance there are three QA groups performing the required checks.

(1) Site Quality Assurance Auditing Group. This group performs a program review of corrective and preventive maintenance at least once per year to ensure that Maintenance is conforming to the i guideline of the O/QA plan and Maintenance Department procedures. This audit is reviewed up through the i Director-Unit 1. Items indicated as deficient must l be corrected within a time frame specified on the audit report; normally 60 days. The audit group also audits the Operations Quality Assurance and Quality Control groups to insure that they are performing I their intended functions.

(2) operations Quality Assurance Group. This group ,

performs a review of all administration procedures I

when they are issued or revised and some maintenance procedures at random intervals. Additionally this group conducts monitoring, essentially mini-audits, of ongoing maintenance a6tivities and provides the nondestructive testing activities associated with plant inservice inspection programs.

(3) Quality Control Group. This group is responsible for l

l the continuing and on9Ging review of corrective and preventive maintenance work authorizations on QC components. QC reviews each job ticket and PM check l

i l

l

sheet that involves a QC comportent both prior to and l at the completion of the work. The job maintenance activities indicated on the job tickets / check sheets and procedures to be inspected are identified by a stamp stating, "QC Witness Points Indicated, Notify QC at least four hours prior to commencing work." A red arrow with an "B" or "W" (QC hold point; QC witness point) designates the steps of the procedure at which CC is required to be notified in order to be present during the performance of the task. Hold or witness points may be waived by the QC Department; however, the reason for the waiver of hold points must be documented and approved by the QC Manager.

Similarly, the waiver of witness-points must be documented and approved by the lead discipline inspector.

In the case of corrective maintenance, once the job has been completed in the field, the maintenance foreman signs and dates the RCR form. The Operations Department then aligns the component for testing and signs the RCR form. The testing is l

then performed and the component is realigned and released for normal use and approval by the shift foreman on the RCR form.

l (There are times when testing cannot be performed due to plant l

I conditions. In that case, after the maintenance foreman completes his work, the job ticket is returned to the SMC for test scheduling.) After the shift foreman returns the component l . __ . . _ _ _ _

i . . . . . _ _ . _ _ _ _ _._ _ . . . . . _ ..__ _ -__

to normal operating status, the job ticket is returned to the maintenance office, reviewed by the senior planner and sent to QC for review. There are no procedures or guidelines governing the time frame in which the CC review should take place after this work is perford, the guidelines do state that an adequate l

review shall be performed. CC reviews the paperwork to insure that documents are properly filled out, QC tags attached (if required), test data attached (if required), etc. Some job tickets might not be reviewed by QC for months after a job is completed in the field simply because the testing has not been completed on the job or the job is being held open for observation etc. Examples of the above are TMIA Exhibits 20 and 31.

BY WITNESSES BALLARD AND DYCKMAN (1) TMIA Exhibit 20. This exhibit (W.R. #22181) is an example of work identified during plant operations which could only be done deting an outage. The work request was written on December 13, 1977 to inspect RC-V-1 and RC-V-2 torque switches. The work was planned for the 1978 Refueling Outage (March-May 1978). The work request was reviewed by QC on March 2, 1978 and QC put on a stamp "QC Hold Points Indicated." On March 20, 1978 work was authorized to begin. Before the work commenced, however, it was noted that no QC Hold Points had been indicated in the procedure so CC re-reviewed the work request. In re-review, on March 29, 1978, QC deleted the QC Hold d

Point stamp as noted on the front page of 22181 by stating " Void QC Hold Stam.n" and initials of the QC reviewer REN 3/29/78 (Ralph E. Neidig). Addition-ally, valve RC-V-1 was to have its limitorque operator changed per WR 21132 and hence its switches would be inspected at that time. Therefore, in concurrence with Engineering, RC-V-1 was deleted as noted in 2 places on the front of work request 22181 (RC-V-1 is crossed out and below it the initials REN (QC) and 3/29/78) and on the right hand side of the page " Void RC-V-1 insp. part of W/Rt ." (The illegible portion was probably WR #22132).

Subsequently WR #22181 was performed on April 8, 1978 i and tested and released for normal use on April 19, 1978. The job was later reviewed by QC on January 15, 1979 and closed out by the Supervisor of Maintenance on January 18, 1979.

(2) TMIA Exhibit 31. This exhibit (W.R. #C0178) is an example of a properly prepared, approved, worked and completed job ticket. The job ticket was wricten on l

January 7, 1979, supervisor approved January 8, 1

approved for work on January 9, work completed on the same day and, per the attached approved procedure, tested on January 9 and signed off by the maintenance foreman on January 9. The job ticket was held by Operations (no longer the current practice) for observation and finally signed off on August 3, 1979..

QC administrative 1y reviewed the completed paperwork on August 8, 1979 and the job ticket was closed out by the Supervisor of Maintenance en August 10, 1979.

There is no specific time frame within which QC must review completed job tickets. The work was important and was completed in a timely fashion.

After the completion of QC review, the job ticket is sent to the CM Manager for his review, approval and closecut. The Maintenance clerk then logs the completed date in the Maintenance Log and forwards the copy 2 of the job ticket to the computer for data entry. After data entry the job ticket cover sheet, copy 2 and any attached job ticket documentation, i

! e.g., QC tags etc., are filed in the completed job ticket l files.

l l

l BY WITNESSES SHOVLIN, SNYDER, DYCKMAN, AND HARPER E. CONCLU'SIONS In conclusion, the TMI-1 Maintenance organization has I grown and has been modified significantly since March of 1979.

These changes reflect the commitment on the part of GPU

l. Management to establish an organizational design in which well qualified individuals are placed in management positions with an appropriate scope of responsibility, that will ensure the safe and reliable maintenance of the TMI Unit 1. This commitment extends throughout the management levels that

[

provide our programs and policy guidance, the organizations that interface with the Maintenance organization to provide support that enhances our maintenance effort, and through the production employee levels who accomplish the day-to-day work activities in the plant.

A regular training program along with other educational

! opportunities are provided for Maintenance department personnel to ensure that job skills and knowledge levels are constantly growing and improving.

i Administrative procedures and controls have been modified or established to ensure that maintenance requirements are properly identified, coordinated, accomplished and closed-out in an effective and timely fashion. This has been an on-going process at TMI since its early days to ensure that plant policies and procedures fulfill safety requirements and utilize current methods available within the industry.

Lines of communication throughout the years have been well established within the Maintenance Department and with other plant operations support groups so that the necessary attention is directed from all areas when a top priority situation arises. These groups meet daily for a planning update on important plant maintenance and testing that is in progress or scheduled.

The establishment of a Preventive Maintenance group has set aside a segment of the maintenance organization that is committed to identifying and implementing well-conceived and progressive preventive concepts so that the safety, reliability, and availability of TMI-1 plant equipment is maximized.

The use of information technology has been greatly expanded and the computer will continue to provide even more of l the vast quantities of data that is required in the maintenance i

of a nuclear plant. This technology has been suc cessfully applied in both the corrective and preventive maintenance areas and with the planned "on-line" capability, it will become even more valuable.

In sum, we have upgraded proceduras, established new i

controls, provided technician training, and modified our organization to provide for greater responsiveness. These l

actions demonstrate a management capability and the substantial effort that continues to be devoted to the safe and effective management of the TMI-1 nuclear facility.

l l

t u v r a i i n o u v.in. m -

MODIFICATIONS / OPERATIONS SECTION PERSONAL EXPERIENCE

SUMMARY

RECORD Pago 1 - of 4 NAME:

, B. E. Ballard, Sr. DATE: REV: O, This information Data Sheet snail be completed upon initial cert ficatton and updated at recerofication and/or wnenever additional certification is/becomes necessary.

Total From To Time Organization / Title or Experience. Activities or Mo/Yr (Most Comcany Pesition Responsibilities Mo/Yr 5/65 7/71 74 mos U.S. Navy Machinist qualified to operate and maintain Mate U.S. Navy power propulsion units.

, 2/66 9/66 7 mos USS Aucilla Lower Leve: Qualified to perform and operate A0-56 (USN) Engine Root engineering plant equipment on Evaporator U.S. Navy oiler, and perform

& Throttle maintenance as required.

Watch Oper.

11/67 3/68 4 mas G.E. S36 Nuc. Nuclear Qualified to stand all nuclear Prototype Unit Prototype prototype watch stations during Plant Oper- operations.

ator 7/68 5/69 10 mos USS Thomas Edison, Nuclear Qualified to stand all mechanical SSBN 601 (USN) Plant engineering watch stations on naval Mechanical nuclear powered submarines, quali-Operator fied emergency nuclear welder.

l 5/69 7/71 26 mon USS Long Beach, Nuclear Qualified to supervise all engin-i CGN-9, (USN) Plant Me- eering watch stations as engine chanical room supervisor and engineering Operator, watch supervisor on nuclear ERS & EWS surface craft.

6/70 7/71 13 mos USS Long Beach, Ships Force Assigned responsibility for ships CGN-9 (USN) Overhaul force coordination of nuclear plant overhaul during yard period Management Supervisor and refueling at Naval Shipyard.

Responsible for coordination of preventive maintenance work l activities also.

9/71 1/75 40 mos Liberty Loan Corp. Manager Performed management duties as l St. Louis, M0 Assistant Office Mgr., Collection (home office) Mgr., Legal Accounts Mgr. and Office Mgr. in a Louisiana Corp.

office; supervised cashiers, secre-l taries, and loan personnel in the Reviewed and Accepted By: e *. 0 . .e . .__. -

g . ccas er cA u.cv TMf-220 7 90 . MO-1121 (Fev. C) l

MODIFICATIONS / OPERATIONS SECTION PERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Pag 3 2 of 4 B. E. Ballard, Sr. DATE: REV: 0 N'AME:

1 Total Rom To i s/

Organizacion/ Title or Experience, Activities or Mo/Yr Mo/Yr Most Company Position Responsi'ailities (Continued) performance of their duties and performed periodic audits and checks on overall office performance.

4/75 4/76 12 mos Insitute of Chairman, Chair =an of University Branch Electrical North- of IEEE, Northwestern State Electronic western University, outstanding leader-Engineers State ship award 1976 member of IEEE.

Univ. Power Engineering Nuclear Branch Science and Communications Societies member since 1973.

5/76 4/77 11 mos Litton Ingall: Nuclear Nuclear Power Division ' Planner i Shipbuilding, Power responsible for project. level Nuclear Power Division planning of mechanical /-

, Division Planner electrical nuclear submarice overhaul work packages,; tech-nical and work instruction

-development, audit and review, implementation of pre-arrival deficiency inspection of ,

electrical / mechanical systems. l 4/77 8/79 28 mos MP&L GCNS Plant Responsible for the review and Quality monitoring of the implementatio:

Supervison of the on-site GGNS operations QA program and the supervision,-

training and certification of t the plant quality representa-tives, engineers and inspection persor nel. Participated in the-development of the corporate operational quality assurance l

program, represent plant staff i

in QA/QC meetings, provide QA/Qt technical guidance to other sections of plant operating staff, provide operational QA training assistance to the plan:

responsible for the development and implementation of plant i

rw. :: 7 30 YO 112 3 inev. Cl

~~~ ~~ ~ ' ~ ~ ~ '

J D

~ ~ ~

QUALITY ASSURANCE

. e / MODIFICATIONSIOPERATIONS SECTION

^

i PERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Pega 3 - of 4 N'AME:

B. E. Ballard,' Sr. DATE: REV: 0

/

e TotM Time From To &Vks/ Organization / Title or Experience, Activities or i Mo/Yr Mo/Yr Mos) Company Position Responsibilities 1

(Continued) quality monitoring, review and 4

inspection programs to support and verify plant operating activities.

6/78 11/7,9 17 mos MP&L GGNS Procedure Committee provides management Review reviews of plant administrative Committee procedures to establish plant policies, identifies and provides scoping statements for new plant administrative procedures when required and determines any additional concurrence or reviews desired from a management standpoint but not required from an admin-istrative control point of view s

8/73 11/79 16 mos MP&L GGNS Plant Committee provides timely and Safety continuing review of plant Review operations to verify that the Committee day to day activities are Member conducted safely and in

/ accordance with plant adminis-I / trative procedures. They per-form periodic reviews, investi-gations, and monitoring of plant activities and programs to ensure they meet current I regulation and industy stan-dards.

8/79 11/79 3 mos MP&L GGN Training / Responsible for the developmen.

, Adminis- and implementation of the over-

/ 8 trative all training program for all

, g Grand Gulf Nuclear Station i

Super-visor employees including reactor i

operations, health physics, Q.A., General Employee and Maintenance Training. Respons--

ible for the recruitment and hiring of staff personnel for

..s J

l

' VC-112 3 (Rev. 01 rMI222 %.43 7

• N t

-- - - .-,- .1?

~ ~ ' - ~ ~

UUAC11 T ACQUnN4GC '

MCOlFICATIONS/ OPERATIONS SECTION PERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Paca 4 - of 4 NAMS. B. E. Ballard, Sr. DATE: REV: 0 Total From To (f Organization / Title or Experience, Activities or Mo!Yr Mo/Yr Mos) Company Position Responsibilities (Continued) assigned to the nuclear station and for the Administration of the Personnel and Administrativ progra=s at the site.

11/79 -- --

GPU QA Modifi-- Responsible for the review, cations / inspection, and monitoring of Operations the on-site TMI QA progra=s Manager - for Operations on Unit I and TMI Recovery on Unit II. Addition-ally responsible for the management and supervision of the IMI QA Modifications /

Operations Section of the QA Department and for the super-vision and training and certifi cation of Operations QA and QC personnel. Assisted by a QC Manager and OQA Supervisor.

Participated in the development

'of the TMI Unit 1 Operacions QA Plan and the Unit 2 Recovery QA Plan. As Site Manager, responsible to coordinate and interface all QA department activities on the TMI project under the direction of the

, GPU Manager of Quality Assure.

I ance, l

i 12/79 -- --

MEC - TMI Plant Committee provides timely and Operationa continuing review of plant Review operations to verify day-to-day Committee activities are conducted safely Member - and in accordance with plant Unit 2 administrative procedures.

9-  ? -- --

MEC-TMI Emergency Responsible to assist the E=er-l Support gency Support Director in =oni-l Secondary toring Operational and Radiolo-Communica-. gical Co==unications resulting tions from a site e=ergency at TMI.

I I

r?.ti t2 7 30 VC-11t 3 LEev. Cl

- MODIFICA lbSlOPbAhlO5S SECTION PERSONAL EDUCATION

SUMMARY

RECORD Paga 1_ of 6

. B. E. Ballard, Sr. DATE: REV: 0 NAME:

This informaton Data Sheet snail be completed upon initial certification and upcated at racertification anc/or whenever-additional certification is/becomes necessary.

Total Time Graduated Or School / Institution Completed Course / Program / Seminar From To (wks or Content Mo/Yr Mo/Yr Mos.) Activity (Yes/No) 9/62 5/65 36 mos No. Little Rock High School General high school education, Senior High special courses completed in .

School power mechanics, drafting and {

No. Little science. .

1 Rock, Ark.

I 9/65 2/66 4 mos U.S. Navy Machinist Mate 16 weeks training in steam Great Lakes, IL "A" School USN generating plant operations and maintenance 9/66 2/67 6 mos U.S. Navy Nuclear Power 24 weeks design, construction Bainbridge, MD School and operatiens technology on naval nuclear power plants 4

i 9 mos S3G Nuclear 8 weeks classroom training, 8 l 3/67 11/67 U.S. Navy Saratoga Prototype weeks operator certification ,

Springs, NY reactor operator, electrical i operator and mechanical operator I on G.E. S3G nuclear prototype unit, 12 weeks engineering laboratory technician training in radiological controls and plant water chemistry, 14 weeks of clant operations.

5/68 7/68 2 mos J.S. Navy USN Submarine 8 weeks training on submarine few Londoti, School technology, systems and enn. operations.

i High pressure 16 weeks nuclear welding 9/68 1/69 4 cos J.S. Navy Cew London, stainless steel technology, training and cert-l nuclear welding ification on high pressure

onn.

school stainless steel velding and high/ low pressure carbon steel welding Reviewed and Accepted Sy: $ fr3 e _ . . .-

QaAS or CA M'CM J

MO-112 2 (Rev. 01 P.u.2 21 7 80 L

- . . _ ._ _ ~~~ ~ ~^~ ~

._ QUALITY ~ASSURANUh MOOlFICATIONS/ OPERATIONS SECTION PERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Pago 2 og 6 B. E. Ballard, Sr. REV: 0 MAME:

DATE:

a School / Course /

From To (Wks/

Institution / Program / Scope / Method /Obj ective Mo/Yr Mo/Yr M os) Co=pany Seminar of Training 4/70 5/70 2 mos U.S. Navy Preventive 4 weeks training in preventive Vallejo, CA '-tainten- maintenance systems and over-ince haul computer scheduling.

9/71 2/72 6 mos Liberty Loan Asst. Mgr. 24 weeks of instruction and Corp. of and Mgr. on-the-job training in loan l St. Louis training corp. management and auditing.

course 9/72 9/73 12 mos Louisiana Pre- Major-Electrical Engineering State Univ. engineer- Credit Hours: 32 Alexandria, ing Degree: None La. courses 9/73 5/76 36 mos Northwestern Engineer- Major-Electronics Engineering State Univ. ing Credit Hours: 108 Natchitoches, Courses Degree: BSEE La. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> credit trwards MSEE, specialized cour.,es: quality control, educational psychol. ,* j computer technology. I l

5/75 -- -- Federal Comm. FCC Radio- Licensed as a second class  !

Commission telephone radiotelephone licensee by the Dallas, Texas license Federal Com=unications Commis-examina- sion, Dallas, Texas. License ,

tion required to repair and maintain!

radio communication and micro- l wave communication facilities i in the U.S. Also licensed amateur radio advanced operator i for A=ateur Radio Services.

Certified amateur radio instruc-tor by the A=erican Radio Relay -

League.

I rMI 22t 7 30 . Mo.112 3 Jtev, on

QUALITY ASSURANCE

- MOOlFICATIONS/ OPERATIONS SECTION PERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Pege 3 of 6 NAME: B. E. Ballard, Sr. DATE: REV: 0 From To

[a (Wks/

School /

Institution /

Course /

Program / Scope / Method / Objective Mo/Yr Mo/Yr Mos) Company Seminar of Training 9/76 9/76 40 hrs Litton IngallsRadiation 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training in radiation Shipbuilding, Control worker fundamentals and tech-Pascagoula, MSaorker nology.

school &

certifica-tion 12/76 2/77 2 mos Litton IngallaManage- Supervisor training course in Shipbuiling, =ent Deve-. techniques and management Pascagoula, MS lopment principles.

Course 4/77 4/77 40 hrs Penn. Power & QA Indoct- 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training in nuclear Light Co., rination plant quality assurance funda-Allentown, Pa. mentals and principles.

4/77 9/78 periodic Edison Elec- Quality Participation in utility task meetings tric InstituteAssurance force on nuclear quality Meeting Task Force assurance problems. Operations Operationo Subcommittee Member Sub-Com-mittee member 8/77 9/77 40 hrs Bechtel Powe.r Auditor 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> formalized training Corp. Training in audit techniques and audit-ing programs.

12/77 12/77 40 hrs American ASME Short ASME short courses on Section Society Course III and XI boiler and pressure Mechanical Section vessel code reqairements 0.9 Engineers, III, IX, ceu(s).

Atlanta, Ca. and XI Wi 2:2 7 30 MO-112-3 Pev. c)

. -QUALITY ASSURANCE . _ _

- MODIFICATIONS /OPERATTONS SECTION PERSONAL EDUCATION / EXPERIENCE CONTINUATION. SHEET Fage 4 of 6

r .-w NAME:- B. E. Ballard, Sr. DATE: REV: 0 a

School / Course /

From To (Wks/ Institution / Program / Scope / Method /Obj ective Mo/Yr Mo/Yr Most Company Seminar of Training 10/77 10/77 24 hrs American ASQC Shor: ASQC short courses in quality Society Course on assurance requirements for Quality procure- procurement, design, operation Control, ment, de- and inspection.

Washington, sign, D.C. operations and in-spection 6/78 7/78 5 wks General BWR/6 5 weeks of engineer training on Electric Grand Gulf Grand Gulf Nuclear Station Nuclear BWR/6 reactor plant systems Iechnolog; design, setpoints, and Engineers engineered safety features.

Course 8/78 8/78 8 hrs General QA Indoct- Indoctrination on G.E. IS&E Electric IS&E rination RPV and Piping Inservice on reactor Inspection QA Programs.

pressure vessel IS]

& piping 9/78 9/78 2 hrs American Statistic- 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> seminar on statistical i Society al QC ap- quality control applications.

Quality plications Control, Jackson, Ms.

9/78 4/80 Periodic Edison Elect- Quality Participation in utility task Meetings ric Institute, 4ssurance force on nuclear quality assur-Syracuse rask Force ance problems. Operations Subcomittea Member 10/78 10/78 24 hrs American So- ASQC ASQC tutorial courses and ciety Quality rutorial technical sessions on Operation-l Control, courses or al Quality Assurance.

Knoxville, TN 3peration-al Qualit3 Assurance l

TMt.::t 7-30 MC 112-3 (Rev. 01 l

s ,

QUALITY ASSURANCE MOOlFICATIONS/ OPERATIONS SECTION c . .EERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Page 5 of 6 NAME: 3. E. Ballard, Sr. DATE: REV: O a

School / Course /

From To (Wks/ Institution / Program / Scope / Method /Obj ective Mo/Yr Mo/Yr Most Company Seminar of Trainine 6/79 6/79 40 hrs George Quality 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> course in quality Washington Control control engineering techniques.

University, Engineer-Wash., D.C. ing 7/79 7/79 56 hrs General BWR Con- ENR Simulator training on Electric trol Room Dresden Plant.

Morris, IL Si=ulator Training, Dresden Plant 8/79 8/79 24 hrs Middle South Lead Course on lead auditor training Services, Inc. Auditor and certification.

training 11/79 11/79 8 hrs MEC TMI General TMI General Employee Employee Nuclear Training in RAD protection Plant plant alarms and security Iraining requirements.

3/80 3/80 4 hrs MEC TMI Radiation Radiation work permit practical Protectior factor training.

Practical Factors 4/80 --

periodic Edison Elect- Quality Participation in Utility Task meetings ric Institute Assurance Force on nuclear Quality meetings rask Force Assurance proble=s. Operations aperations Subcommittee Member subcommit-tee member 9/80 9/80 2 hrs MEC - TMI Emergency Emergency Planning Training on Plan offsite medical support Training facilities.

TMI.222 7 30 MC 112-3 @ev. 01

. _ _ . ~ ._ _ _ ._

QUALITY ASSURANCE MODIFICATIONS /CFERATIONS SECTION PERSONAL EDUCATION / EXPERIENCE CONTINUATION SHEET Page 6 of 6 P[AME: B. E. Ballard, Sr. DATE: REV: 0 School /

ha Institution /

Course /

Program / Scope / Method /Obj ective From To (WkW Mo/Yr Mo/Yr Most Company Seminar of Training 9/80 10/80 24 hrs American ASQC ASQC Tutorial and Poster Session.

Society Tutorial on Nuclear Plant Training, Quality and Poste -Operations QA, Design and Control, Sessions Procurement.

Houston, Tex. on Qualit: r Assurance l k l

l TMt.2 t 7 30 MO 112-3 iRev. 01 l

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NPRO FAAURE $ TART Su OP M0 CO RF MS LR YR- M0 DAY N'R utN

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. 2 . ASS 4 sting CEPAATWEmi .. ~ .'.. . . . ASS 6 STING CEPARiwENT .

. - ASSISilhG OEPARTMENI L.-" ' RESP. LDCATICN EST . ,,-~ . "ESTu? f./ * ' ~ RESP.LOCATICN ~ EST '

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• 58 59 - - - * " ~ 68

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in A Nea0 FA4URE END . Faust saune ORIGINATOR-SUPERVISOR-SUPERVISOR OF MAINTENANCE i No. stAms CO C g,, ,, y,y MAINTENANCE FOREMAN-JOB PERFORMER-MAINTENANCE -.

yz,,l og i 4 9 4s a, so FOR EM AN -SUPERVISOR OF MAINTEN ANCE-

! 6 CM COORDIN ATOR DATA ENTRY. SUPERVISOR OF M AINTEN ANCE l i3 0 BA l CM COORDINATOR. DATA ENTRY

. . 6. *:4. . *. .* ..* .-.. Q.M..:. .s - ~-

• A N."to NPa0 CAUSE OF F AILURE CCCES . EFFECT C5 -6 *6 ACTION TAKEN CCCES LICENSE EVEN T - -

. ~. . J'J.lM. .! . ~~

C Fatt. FAA g .g . FA4URE CCCES '%E,C. . REPORTE0 0 ATE - N' .9. Pr '. -

~ f .; .;. "-

l TIM CD y typs MOCE - A- 8 A 8 YR WO-~ CAY  ? ? 5.:.-- - C --- f.

ji 4 M so si 47 43 50 St $$ 56 7 !3 65 64 71 .4,-* -~ -

COPY 2

.3. 0 . 9A ._ - _

....e . . .* *=*-.N- . - 4 - **

• a o ju o fu . A' .' ".

GENERATION CORRECTIVE M AINTENANCE SYSTEM UNIT 1

. JOB TICXET FORM (WORK REQUEST).THREE MILE ISLAND cc muv cis cutch auast cart are: n o.oe

,SYS CO .s

• c0M S.

ic o

h. U Sc M0 YR

, svPs , o , l CAY bD c P 20 0 3 5 0 0 1 c MI5fg 3 c # 7lg 3 / 2l.2 f (p f

,,.v,,, lhtsc duAf f e. eh f 4 m! k 'L en s TEt PS i r $ l

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/,:ca turton CEft4E0 l l r? t f l.- A C $ O h AO fk I

& ll l OAU320F

?.iALFUNCTION f

l ItF KNOWN)

ORGhATCR'$ ,J SuPERViscR'S .)

EMP. NO. / EMP. NO. / /

M'~/J/PXJ Jn. - l2/.1s/M) 0 5L 7 i, cacNArca s suruas e e care O f 2. 7 f suPeaviscR s s= rune e sus WORK ORCER Nu98E8 GC ~ ACCOUNT PLANT C040liiON .

NPRO FAILu*E $rAAr LC0Ar:0N SErtiAL SU CP wC ;0 RF 45 LR VR MO CAf min y , f M4 3 2 .2 CC 0 l SYi 60 E3' 6i l l I I ( l 6 l 1 l

n' noo m

wir, s,

.o s, o u....o ri,  ;;

5l=5 cec, y V y c  ! l 0 .A c!0 N NA f; cA*codrEfE$!

M0 DAY 'ia gv

/ cn s c ,

.a as:19 1

3 i

. ?., -.?" REVIEW REQUIRED L."M IU COMMENCING WORgMPLY VilT!! THE PROVIS10t;S

                                                                                                      "I p' '.                              %RTH IN Ap;ogg' ;g93 t.,,_,,,.                                                                            D MET ED SAFETY MANUA~t'

, a) Personnel GO'TEY STH THE IISIO3s SET F : TH I3 r :.100-1 .003 L'O .4ET ED ~.J'ETv ...ANU/.L . b) Equipment me o0 '3'Y c) Environment ,o e c .S . -

8

                                                                                                              'IO'I9               tV;^iO [[ I\!I,Q'     OO a '

• L",IL'C- /,O ,I.I 3 'CII d) Nuclear I 5 d II"}7 - U d : 8 \ U-Post Maintenance Testing required and Acceptance Criteria.

UP AT COMPlT!0N OF .!03 O N,y,0,Re ac a7aIn es a a r e eri e* * - - W- - - - - -}

1 -3

 , s.'                                     -,

t o l.'. !i\'.

                                                                                                                                                   !. 9 3 'f NOUN NAME I                   DESCRIPTION                          !
                    "                                                             E5E6                                                     l          .. ' J
                                                 $;%'t=
                                               ,=.                                r?n

• COMPLETE PDMP.& MCff0F; k; , I?':) j 'W?M) h.I[[' (

STOCK Nug1BER 1 7 j;.sf5c.a..f..,,;,ev.+, SY STEM

                                                                                ; q. A /:~.WDL4-     / TAG NUMBER,             [

P 1.7,20 542-052-4500gL; wed h,, .h;w{- e . SIZE t QUANTITY P.O. NUMBER 58370 E 1 wmsmemmesar .._-.....s-~ ~ ~. ~

                            .'...:-                                         g37.go                         ,

Quality Control ' 9 l ACCEPT , . . . . . . . _ . . _

                                                                                                           !'                                   !'$l$                       .'

P.o. s o. U 3 7 o ITEM No. . Q.C. INSP. h- <d/# DATE # 3 /o a 1 ., [h j 1 TMt-05A REV.1176 GPF 4008.003 i idy, . r-

                                                                                                           -e                   o     2.                 n

A. - f JOB TICKET (WOHX REQUMiT)

                              ,               REVIEW CLASSIFICATION ROUTING C.,i' TROL FORM JOB TICKET NUMBER NN 3

• 1. Does work represent a change or modification to an existing system or component?

If yes, an approved change modification is reqired per AP 1021. a. C/M No. Yes No I / 2 a. Does work reouire an RWP. Yes No 2 b. Is a Radiciogical Engineering Review for Afara required. Yes No Rad Engr W fSignature Abr/8/ if yes m J 2 -.3 /.,- 2 0 Date 3 a. Is work on a QC component as defined in GP 1008. Yes No 1 3b. If 3a is yes does work have an effect on Nuclear Safety? If 3b is yes. / PORC reviewed Superintendent approved procedure must be used. Yes / No

4. Agreement that a PORC reviewed. Superintendent approved procedure is not required for this work because it has no effect on nuclear safety. (Applies only if 3a is Yes and 3b is No).

Unit Superintencent' h Data f S a. Is the system on the Critical Plant System List in 1407-1. Yes V N Type of Critical System [J'A ,

                                                                                                                                        /

S b. If Sa is Yes is an approved procedure required. Yes No V

6. Agreement that 5b is No. (Required only if Sa is ).

l l A Unit Supenntenden ennsor of Operation

                                                                                  /                  LV(

4 ' udN#9 Datv '" l 7. Plant status or orerequisite conditions required for work. (Operating and/or Shutdown) s

8. QC Dept. review, if required in item No. 3. 2 A-

                                                                                                                                  /

8 l Manager QCL j dM> 14 % 1/7f Date M'r l (

                                                                                             ~

9. Does work require code inspector to be notified. Yes No ly

10. Supervisor of Maintenance approval to commence work:[/hM Date /k 2C ./O

11. Maintenance Foreman Assigned: A W'M

12. Code inspector notified. Name Date

13. Shift Foreman's approv to commence work. When required, approval shall be given only if an ins::ection has been perfor t r' R e-f unda n t Strings of Sa/ety Rela ted Equipmen t are fully operable. -jd/ . /, y-Date /~;'

• 2 f 5 3 7

Initialif Shift Foreman signature is not required

                                                                                                                                                       .o?C
            ,         ,                                          JOB TICKET (WORM REQUEST)

REVIEW . C!. ASS!FICATION ROUTING CONTROL FORM

                                                                                                                                                 ~

JOB TICKET (WORK REQUEST) NUMBER ' i 3 14 Component repaired and is released for Opger tions Department System realignment and operability testin Yes y g No O

15. Work Performed by/date [gfy,j , gQ g. .j; Work Reviewed . Maintenance Foreman's Signature f)_'.[.! cyp:W

                                                                                                                            /f-f f'- ?O                       '

Dat.

16. Operations Department Post Maintenance Testing Required. (Required if Ei:W, ESAS. RPS work.)

17. Testing Acceptance Criteria (Required if EFW, FSAS, RPS work.)

t t hl{$ ' D**0 *D'3

                                                                                                        .cc            c          .S.'.             m

18. Component alignment .fer operability testing has been verified and component is ready for Operati. '

l Decartment Post Maintenance Testing. l l Initial if S.F. signature is not required. AJ<s /2. -2. (, - 7 s9,t ,,, . S .n. . o...  ;

19. Operations Department Retest met Acceptance Criteria Yes U No O N/A %

20. Operability Testing completed and component aligned (independent verified if applicable) and released for norr use.

Initial if S.F. signature is not required. D' /).96 d (f Shift Forem.6s Signature cat.

21. Quality Control Department review of werk and testing completed (CC work only).

                                   /?/A?

Surv Hanc. Recort No. d Cerch l- Elae!? /- W- f/ . CC Desertment Date

             '12. Superviser of Maintenance Job Ticket (Work Request) and precedure are complete and signed off as require                                     I Change /medificaticn form has been signet off as required.

m ,.~,.g..nt._.s.. A

                                                                                                                                                 }"       c... , -;

w-w am, ,. _ s r:.9 .. - . Revision 0 .2-6

 'T         -.-                                         .
       '                                                                                                             01/24/76

( ) p /~ WORX REQUEST PROCEDURE /J'j'tM,Y[~ .. '

                                                                                                                                    ~
                              -                                 T?.11 Nu: lear S:stion fAaintenance Procedura Forr.,at and Approva!                 .fI.,.....,..,.*

d(! ! '-fi y . Q T .7 m Unit No. 1 I!Ht-d!!:3 This form out ines the format and act; as c :over sheet for a maintenanca procedure. Due to th: of the form, adtlitional pages rnay be attachvl as re ;uired. '.'.'crk Request procedure AP 101S See:ic.; De used as a guide in preparing the maintenmca proct <!ure.

1. Pracciure Title F. ::0.:

UDI.-P-i7/WOL-P-20, REPLACEME3T OF Pt':iP/M070Rt OVERHAUL OF UtlIT 1420-WDL-1

2. ?ntpase:

T; provide instructions for tha replacemint of WDL-P-17 and WDL-P-?.0, pu- ,', : :r uni t. Overhaul of unit. D. D$ scrip:ian of system cr componsnt to ha worked on. 3.1 M:t::r/pu .p assy. . f 4. Retarances: 4.4 Met-Ed Safety Ma-. i

                    ?.1    Instruction Manual Crane-Chem Pump, Serie's G                               4.5 P.iley Beard D'.:3 E' '.17-507 4.2 TMI Admin. Procedure #1002 4.3 TM1 Admin. Procedure #1003

5. Sp;cialT0o13,i.lateriais and Qualificatiens rtquired.

7.1 Pump / motor assy., part llc. !-iDL-GO-5X-152 H-1S 7.2 Hand tools 7.3 Hydrostatic Test Pump G. Datailed Procedura (attach additional ps;as.s requirsd) SEE ATTACHED Supervisor of !aaintenanca neommands s;;revsl [[Mr ,d/uydd Date .# - 7. 7[ ONM.ds; _ _, Da:s /- /d- 76

• PDRC Recommends a;;rc, Igchairmta ~

c. , S-d 'd _ Oste / -2 </- 7 [

                                       *Uttit/$tation Superintsaden Apprevat 00                      /

• NOTE:

Thne approvsts require.1 only o, Nue' ear safety Rebted/Itadiation v.ork pennit jobs. s Standing Procedure /'. d .N! /' 7 i' - 70

                                                                                                                                                    +"

su vga qq, zer

                                                                                                               .6 o            o n.1 X L

            . f.                                                                                                               42 - 7
  .           ..'-                                                                                           1420-liDL-1 Pavision 0 01/24/76 G.0 PP.CCEDUP,2 6.1     Inspect replacement puap/cotor assc:bly, take resistance of motcr windings using a Wheatstoaa bridge, record on data sheet.

6.2 If strainer is installed in pump discharge, remove same. 6.3 If heat trace is not already installed on pump / motor, install as cer sketch (Detail C) on reference (4.5). Sand as required. - 6.4 Tag UOLPl7/UDL-P-20 out of service in accordance '. tith reference 4.2. Shift Supervisor, must give permission before cc=tencement of any work. All work is to be in accordance with reference (4.3). 6.5 Disconnect UDL-P-17/WDL-P-20 punp suction / discharge flanges, foundation bolts, ground strap and disconnect motor and heat trace leads. (All windings must be identified and proyecly marked prior to disconnecting). !! hen disconnected recove f entire pump /cotor assembly to a suitable place for overhauT. CAUTIC:l: The following sliding links must be open or valves will .open and spill radioactive water. Links 6.21 l feed pump flush valve, 6.24 feed pump suctica valve, 6.25 feed pump discharge valve. 6.6 Connect replacement unit motor leads, insulate same and bump test totor to check direction of pump rotation by looking into the pump suction with a flashlight. (Should be counterclockwise as viewed through pump suction piping. If direction is incorrect reverse the motor levcis to change direction). 6.7 Upen verification of correct direction of rotation, install unit fcundation bolts, pump suction / discharge flange bolts, 1.0 D**D oof e DSf'Th U . A fru :2 i

q, . .

                                                                                                                     #-7
   ' "         '                                                                                       1420 'JCL-1 Revision 0 01/24/76
                                  . connect haat trace utring and grcunding strap. Reclose all sliding links.      Instn.11 lagging around pump / motor. Take insulation resiste.,ce of cator usir.g a r. egg?r and record readings on data sheet.
         -                     6.8 Uhen operations permit, test operation of pump /cctor, measure starting current, running current and record on data sheet.

Verify heat trace de-energizes when pump starts and energizes when pump totor is stepped. Measure heat trace current and record en data sheet. 6.9 If purp/cotor operational test is satisfactory and motor running current is 12.4 amps or less return unit to service. Record serial no. of unit installed and make :ppropriate entry in Nachining History. Disassci,bly of Purp/P.ator Proved Frca Service. 6,10 Collect any solidified baron found in pump housing, n.ator I cavity. Save for analysis of evaluation of the design proble.:. 6.11 Disassemble pump / motor as per paragraph 4-4,2,1 of reference (4.1). Conduct pericdk insp2ction as described in Section 4. P.eplace any worn or defective Maintenance of reference (4.1). parts. See attached sheets frcm reference 4.1. 6.12 Reassemble pump / motor in reverse order, step 6.11. 6.13 If heat trace is defective, replace trace as per step 6.3. I l i 6.14 Take megger and phase resistance readings and store unit in a suitabic place, place appropriate tag, status of unit, if radioactive, it is to be tagged as per requir ments of reference 4.3. If unit is to be used, return it to the system per steps 6.6 thru 6.9. I D

                                                                                                        ]

144u-aut.- - - Revision 0 a-f 01/24/75

                                                                                                      -=.~'
                  , 6.1.5 AcN eptance Crf teria

a. Phase rasistance readings agree within 1 101.

b. i-teggar R2: ding ?:ct::r :nly > 5 Megoh;ns P.ctor and cablo > 1.5 if agoh.c.s

c. Running current less thaa 12.4 amps.

             '            d. Haat trace o,n_ uhen rotor is off and off when r.otor is on.

2.1-D**D *D

                                                                              =c w               o     2 }\  . _a

                  ,,                                                                1420-WCL-l         .2 -m Revision 0 01/24/76 D.1TA SHIET                    WR c e/ 7G

1. If'.a '.!heatstona bridge of rotor uindings.

A3 1 U C ___ / . 'f ? v Ca / , 4 9 C/

2. Teke meggar readings of motor windings.

                                     ~
                        ~[//E/// // /

3. Record motor starting and running current.

St:rting Current T8 _ Running Current 7/ 9A 7/

4. Caes hen trace de-er,ergiza when pu p st:rt Yes' or M Onesheattraceenergizewhenpu.; steps (es')orfio_

v

5. !iaasure heat trace current

                                , // A         amps.

6. Entry made in !!achinery Histor Yes)ortio

                                                                                   /
                                                                                 //fv^'

gew2g _m e m v ykm o2g .Lx 3.0 F

1420-WDL-1 2 -u ,

    .f.

Revision 0 1 01/24/76

                                                                                   - sis t:r'K.

• r.:b' l,e': %.?..I'* si .h.s!*)*I s s.e a \ 2 0

                                                    .                                                                                        e ast*7a-                                                                                                                            e I w.g 5 -,3~s!nr    g ; f . g p> l eriu u s- v e .'-
                                                                                     .                                                                                                                                                                                            (.

put c5 fer :n :.ddi:ionn) !$0-) runn:v b.m. .. o.. ..

                                                                                                                                                                                                                                                      .m...
                                  . i;<.

a ' su :.s.. #. .... ..  %, rwn$s cf 0; :n.t:en, schicheser o. m: fits:. l' nc. ...

       .?              ...                             .              i tien, i.nen. stdl indica:es only stight wear, ,::e g . .. ,,

s. O,s.c.

                                                                                                                                      *I

• 5 U TE trsin in de:.:rmin :; remedi:s for various If. has cer hearing must be ch;n:ed a: the in:"2:

pecM: .n. .ste Tab?c 4-3 Troubic Shu::ng. P:;;; inspectirn, they will need to be ch:5.ed :.cain in  ::.e time pericd. which neceuitated a chan c t' t"- 5

                                                                                                                                                                                                                                                   "*    w--

2G and 21. rer.su:.:: ,. En:pc.:h. oa insp ....

                                                                                                                                                 ..:,n. i.c. 1.<00 running heers.                                          .

y f,. . ..... c, period i: bear.m; mspectron can best b: 1500 . .

    ',:nA, .in<                 rec i.w raf the unit                                     must
                                                                                           . . .r oc-.be   . made                     at. ......_'.-e                                                                                             ---

t . ..:..:

                                                                                                                                                 . mfor      s. tepta'    . hs, e.aen caa t eu be :mdi :.;;d.. .....i.. .  " -

w...:-i.. i...... . . . .4.c..

                 .. s. , , .s . . . y. 4. . .
                                                                                                                       .:,..                                                       c S.u br::v:nt inspectien pari                        - . , r. ,g -
    ..       imi.: .. staron s:                               ~
                                                                                   .....            53 ....           t.

s.t,. ,, '!.a. c...s. ia w (..r r .. m ..s it.....i.... E :.iinp can be inp ::ed ar'd repla: d .ithm:t : :v. in :e ca .e >i.e :.d : ny

                                                                                                                                        .m; ::: ; e .p ca i..; inn., the li+:e. No enda -ir. ,** ~ib.'

i g Pr..;r :;b -,-I

2. t at- -

O ran..n p.n: .: e.t.n J N:.c. d Wre : '.er.rs. E:.:.: it -

                                              .                                                                                           cenned:.m. ne.d be bre!.cn. !; e P;.r: pap'i
    .:tien shm.i!.: melude ..: tent.. a W th6 points note.! ra assem5:y and Rew.embly. >:arn g on Page 2!).
    ;.; ci thc is-::owing p:.r.:7.phs.

To tes: for bearin,t wear:

1. M.asure the ined: diame:crs of th: fron: and ::s:

     '.1. P.ccommen$J Tor. :                                                                            .,

bearing and compare wi:h the dierter c:f h: Dial h . ic.:wr. (.20T tracci) for d:ternun: .; er.? rc:a: sh i; joutr.a!. Ifindicated the diderence in di m: : s play I' p,:ater than tha: in Tame 4-1, Pg: Ye:rd.:s :nd S/lV-m-3 tdesw-!: Eaue:.s for '

                                                                                                                 -                               1- *erla"- th t a ,n,is-            -       "

inm;.::on of be:rieg 1.D siaf t cicarance '-aie. 2. Inspect the thrust faces of the frent and re:r ha . aad O.U. ef re:ur sa.S jr.r:na!>- .in p. 1. nn. scorin; wear is s i>u::h. rcd. me:.v::: the !.ngth of the be.sta.p. ne;; c. :' : $ e- 9. :' i-, i. 3 , ..n..,--

  , -1,- ., .    .
                                          .i                                                                                                       th: measured knyth is less than tha: ir.di::/:J :.
                                                                      .m cre ! .".i :d!y !!ceve typ:                                               Tab:e :.l. Page 1S.
   .icte 9: S.criner in                          :h:s int. ..'
                                                           ;    ..:   c ar:: c inspection a id re.                                                                                                                                .

e.

3. Eumine the hean.nes fer any croov:nae er see:-.r.

c arms s.

     . ;.e- .. : ; 4 -i ra ! becJ c.t c. verier::c m e.::h p;r-
  .. ular msta..                   na tion. I! ear.nc hfe .u'd. dep:nd.10 some i                                                            pa:tice,.arly on the ms. Je m.. -ame::: and.tner f:.:rt.
                                                                   .                                                         :s.                    'I,n: en>tence o., pomme or 5:onnt. indica::s th:
   .stt nt. on variab!e fr ton mem                       ,
                                                                           . J me, t bncation u                 quah. .           -

presen.e of sc.a.Js.or fore s- ca matter m th: ,u:e.n an:. 2.ts."> s. vi3:cu: .. :nd emi.:r::ure. nem,aer in 3: arts.d be:.nc numped, as we.. a v ,,:.h t m

                                                                                                                                                                      .5,.,.ou.d be chm ated prior to acam te*:rt. .:

espension content c., :,..: . tie 8 . . .

                                                                                                                                                          .w                                                                          -
                                                                      ,                                                           .                  c.r-.... .aon.                                                                       -
    .3 ambiert :emt. : ture ant. atme. phen.: conm:::ns o,                                                                .

4 1,3. Refer .'.ssembly in:pecti:n as optr:ai.m! ar.2. E.xh time one o,. these f : tors :s changed, compensa:!oa .:ust be ap;s! icd m bearin; in-The comp,.a.te rc:ur assemMe should be m. us., .t. . tp:: tion:! p::i* is. sp::: d for crc ks, breat.s. pi: ting, or cerresier. lhi: . As noted abave. initial inspection of the hearin;s mus: mith: d:stroy the etic:tiveness o! the herr.:::i:.:Ly. l be md: :: 1500 runnin: bours. or three men:hs. scaled re:or end covers and 5!ceve. .. . l whichtser c::urs first af::t initial starting. This insp:c- isu .v - tion is nee.:warv to determic: the , rate of bearin"- we. r. The retor assemb!v shaft should :.lco b- " ' v.-- w - s

r ese:cuo.r.

e conta - - fo 6er* -- -

                                                                                                                                                                                                                                                        -n - /

t! crehv ena,,..an"; t,.: se::ina .. e up o. a4-1 pro'for t.::: m:n- s,t cted7 um,.c .n wear. I.-' tn- baantweance .xecs ' w.eanundercu::me .. :::- c-and rep':. ::m:n: sch::..u l:. See Tab!: .v. l nem wear ai.mwab,.c. Pace IS. ting or sceria; is cause for rotor repla:Or :nt. me:n :.!! v. ble shaft ciam:ter is not:d in T:.M: .f-1. l 17 the i .nzetion in:!!:n :5 that b:aring are no: w ::ing P2;;e 13. er are w ca-ing very siign:!y. the n .st insp: tica may b: ceer;n;; :nd hurr.:1 E,m n'tcia Table M , D{} O Bearing terr ,d .

                         =                                                                                                                            i Diametrieel Oe.uan v                                          ;           p re.*: d                           a I                                                                 ss." * !.                                    BearinD                       I.___Si arin.s i: hurmb

,rai;e

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uax, Iront .

q...  :.

Mee;,1 Ou:>1d: Ob. Ag;o, ,j g g g, i E32,7; g_ ;

                                        ~

New New' scaring i . , . t h,,, i

                                                  ~

n~ri) 43".0.9150., lj C.y i .n~ < r .c. 8.n- , -

                                                                                                                                                            "- 25"                0042"                  .013" II                              j        ' ' ' ,t p-l G, A. , e.: . G,         .

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l i.c3.cy,

               . . . . , -... , .m c::.,07::.l                1.1 E33"-1.18 '0" 1 1.1533"-l IS..,. l.- '_' ' * . _ . . e                                       -
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                               -                     --                . . ~ . . -                   -

Revision 0

                    ..                     .                                                                                                                                                                                    .2 -4
  ..r.

0'/24/75

nd Ind ?by ststor liner v.hich ::d;::: destrhy the e ?e ^. f:;; .<

h.L4 J. st: rn7 tic. Thrun Es!:;n the brr::r. In.p-: Son T :: pr..vhim: ef at:n:na*!c sh- st be . ec: dcJ.:n in t e Inspe:: th: v. iring o t!:: st ::or a-s:n b!; : . .: -

he isihte per: ion of :$.: e. an.;e.or ! d f ."- - . l 5: :8 G Cir:rg ru:n; 9:: 2:; :Ise um :n; e;! t2 :: .

emien. er fmyed imutadon. the ch::;; P : ced writ:n,: ::'.j - tu m,2?: pn.per 5.. :12.:e :::n- . a- .. ef de motor windian. b takina. r: .ic. . . . . pe,sures. :n;v:::s tha:  : c! ne sic.::1 in.p::.'en 5: . fa r.:. n e.y :n: .p::,ar. :n ::: be. tao w:: i .;. i n: rer. wi:h an chme:er anI a :;eper. If we ch:- .. ., . p. at: no: within 209. of :he va!ae> h. .. .- . -

                                                                                                                                                                                                                  ; _f;.

n. nr ! f: cat re:er end cover :: th : .r: re.:.rm; ir.-

P ;: 25 th: 2. tatar ce.cm!$ly mu.c be repi:.:f.

,":::5 n i. m..de.

w.i ..s

r. i >.t . >e ... ..g. . . 4s. , w..,.:.. .~ _ :....,.,. ....t..,....,u,...

4-I.6. Genera! In:pe: Hon imit cIh; pt:y :. fis!!oc.s:

1. Inspe:t the intr:11:: nut thre:d: en 0 : r : ::..::

1, For ,ah ne!eis. af::r rernovin; :h: ::: '::::n: to insure they a.: r.ut cet. pr:<:ed. .e- - . : :;,. heuung fre.n the unit a+.! wi:h :i: e$:r pas:5 .- p!:::. rne:<.ure the :ot.:! a.iel ( f ru..: t .> ::::k > Medels GA. GB. GC GVilS. G!.D h.ve .. A - .i threads. Mcdel5 GD. GE. GG. GFD. EC.;. ' .'. . m vem:nt of the shaf t, er. GVE. Gvil have : ira:.1,and threads.

     ., . ni .a.:e cas: o , ,. ,. a.
                                                                   ,.2   '., A . u,.    .. CC ::c,           G.....
                                                                                                                      .rm

2. De sure th:t s!! madn; faces are fre: c' m::. ; ./ .

c:: y, :d:ei tLe uni: has b:en scr ra:;.' 't.r . th: burrs so that :Sev v.it proen: 2 s c. - p :r ;' .da;:. nea ar th: to:.d si d ifr. : . c:: ba:L, surn; a .gegd c L C!:rn c:t ...:y .: : , ,. : e :. . movem :: cf (n.: !.c.p. : r :.se n ; tasket ma:crial. If th: r.::.oured cnd p! v emev.but er. . :P e 2 cheJ. '

3. ..bke sure a", parts are cle:.n. Inne:a (2:v.) ne::d la T.sh!.? .:-2.' i' ape l'). : ..a reme.e th.: m.iy b: elesned wi:h a sma!! lrush a- . .. l J.

pdier from S sh.iit ::rd :he t ,:ad.:;s fre. : %ei : :r: 2. p,'inted :ool. The circula: ion line sho c. c: - : ,s ' r-cor ehren5.r. .i uali,s et mine th,; Npe:'er sen! h.: cu: .sah fi!:eicd. ci!. Lee cempr;;t.,,ec :.

       ' vn: b:arnig houi , eai ta e, nnd :he fr...-: re : -

end cover int n..uce.c !: r.e:r: :Ao :.easu e :i . :::-:5 r. r ,

• c' ti.e fr. r hear;:r : c f:M: .;-1.,'P.:: e 12... IT: :'t ..

                                                                                                                                      -...        L n.a r.s at. ion

n. .t u, .an . .- 7 s .;;.s G Chempumn requires no ex:rr .s - .::

henn.ti;. !; cau .e of i:s ;y. mon. i.

                                                                                                                                      . ... , i;,.,;n.. su r f aces. End o h- r p w                               :n.

c:nce a m wear.) N.+yo :n.: . tim: hear.nz ! n;t:i , . s,. . . s.. .. . .. t . .,y i .. ......,ss...,i................,.,..,:.

                                                             ...         5..                    .......
                                                                                                                                       . . .. ..o..-..a ). hi. !.....m
                                                                                                                                                                   .              -i, im m._..,
                                                                                                                                                                       . . bu.. ..*         ' . .
           ...a      . . new
                         . . . . . beatme witn                                             : si then e.d ?!..: :t t.r.e rew ,c rr.r :
                                      ;.! eh! * *                      .t e n Q Is. .C3.81tJt;. I:.. 4:3h3 *.. . .*

I:!P.:h b:.

                .                  t
                                                                   .                   .. r . p . . :6 . . ....r-*--
                                                                         . , .. ,s., a v .                       r.. .- . -
                                                                                                                                      ~..>.        Ccoh. .n .*

5;.p.3 ..,. . ..... t.. .... ... . . . . . . .a. ...

                                                                                                                                                                                                            . . J ;* .- -
                                                                     -!:1iae:S cam! in the ease f cr fre : 1 Jes; r a                                                                                                            Ti e monir rear bearin

• Fousine tem :-2:

M c' h GD. G Jii. Plii. n.! GliD :::: p mp ca' a:- ;ng; 2:;.x of the erli:Un:v of ihe cEo!.: : : .: . . :.-

an functions of th:. !!uid" irculati;.n Stet  :- :r

al ! : 0 must n: w,.:n ' eyond a :utera",. nm.: :: s

        .must be repaired or repi:ced., tit >!. auld !: r.0:ed ina:                                                                    s..;g,n of the pump. ii. at :nv time d.:r!i; : :: . n.

imder proper eperatim; co ditt ns. v. ear en they!! ner-p rts

• 2e rear bearine housinc a:iem mer .e..:.1. :he .:

due to asial thrust farca v.ii; be ree.ejib'e :.nd wt, 1:m

• de tempern:ure'of the tidid bein:.: pum:::. C ;f: re:::

m:lly ne:. therefore, re ;uir reph:: nen:.1 A: :n: 3;3.;n., housine temperature wi:h a thcre :: f: :o assure'that it dhs n. t exceed the pum;: d '-..: :er;:ra-th: irap:!!:r real, face i> inspee: d ter v. car. 2 g Yifu.u! , ture f astumine that no auxiliary mear.; e: ::  : :::e nspect the wearm; rap : na ;ron: :nwel!:: nuo ter atti [ noticesbb si;ns o! wear. Il exces-!ve 3:-nov':;cr 1:Orh'5 re:irculation i!aw is used sudi as Fea: p.:.:i;c. of the wear ritip or impe;!:r hub is t.ati cd. de impet.:7 ja:kcted circuladan tab.:s. etc.). Rear b::f.-: * : iin: !' temper::ture e:n also be checked bv usin.s.: i.v. .

ir i

must be rep!:.ced. or a standard thermemeter, held agains: :..: r: 2in:: T:ble ,., Ser.ies G 'cnd F,sy . by putty. Moc!ci Tote.15.d P! y - New ! If the fluid tem; cr:ture is satisfac c:ar. :.rrh::dn; !;

                                                                                                                                      ' mest probably cau;:d by a restrie:ici. !: .: :::: .it.-

j GA, GP,, GC_ - .C 5 9 ~. 0 ~M" l tioa tube. Shu:dov.a pump. drain ur.i:. u. .v: the - GD, GE .112".125" I circulatica tube and : lean it ws:h c!:en. pf::.. ::m-GVE .C37".073" l 2 *

• 25 1 P'*55Cd .* II 'h* "" ! 5*Ih #""5 hC!' '#

cie r, disasserabb uni: snd inspe:t. l GVH .032",, .C dS", y

           ,              6. ,.,                                                          . s2 ~        .,i.y
                                                                                                            ~

1 . . .m. s .1 =.Jc " l Gn. v, c.s , u. D . C,'.UTION

                                                                                          .110".if)"

l GM B:tw.en eyeles of pumping !!uids whi:!. . .: sel:i.

                                                                                          .034".106" l                          GV3S
                                                                                          .OM". 073~*                                      ify, su:h as caustic :ods, flu:h the s : ..- wi :-

l . G!.D  :: cam, v:h:r or ti:e procer roivent ta -*: ur[r=: ###~~ j ' I P;'55"~C5 ' 'h# *' # P M *5- Sistor As::mbly !nspec:isa I '" ph:rgm;' up. \.'0'"/.:er: the Cacmpuma a :rt . a 2 7he co,np!:: 3:3.,,7 ,c ,.,.jy 3g , 33 3.,g;y .. y ;. - . - dischst;c fi!rcr, ih:sh pump durin c!i y:i:s ai.J -

                                                                                                                             $2             check disch:rge fitter for plugt,ing j

Wied for cracts, braa;.s. p!inng. :.r corres. . D**]D "]D f 5.0 ~@

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                                                                                                                                                                                                                                                                 '01/24/76 v

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Figure 4.) Ev. pied:d'Victr - - m

                                                                       .,..:..,:h G,g..'....r., f.v...sr-r.).s e- n. r:e u" l. v-vw, oye, Gt -
                                                                                                           -                                             s. u b: set on the iteor or grm*nd. If desired.                                                             th-:

t'." li'/ve-

                                       ?. . o rle'.:  ,s , C I' , C , G','i'                                                 % m.. G:,                                        mola.* s.*:t:s.n g::n be ren.n eda.f t..rom                                                    - . . . .Og i, b... ,..,       ..-
   ...,'.',,.                                                                          r-:. , p.*'a., s.rd,       t      r- * *                 ;..
                                                                                                                                              ...                                      s , t',               .. ; . n y .a g..: ....,.. .d,                               .a c,. t :e f"-

J t. , (: .>*. , s.?,.*V

                                                                                                                                                                                       *.              v. - - .
                                                                                                                                                                                                                  '. .~.                                                              .

c , . ... ... .' .. ., .. . th.! p t .. , ,an s. c.,t.y 4 3 r%- . . mspec.t:an. in tr.rs c:9. . t*;r u;7:: h: .

                                                                                                                                                                                       .b:.se u. used as a ste a :o prete:: '.! c p:r:s.
                                        '"-. , 'g; b) if a base is net su;-:' lied, remove th:

r.c:$r the m:.ver a I. Ci? c 6:d:.tre v.f.e. thu:down pump, at.d th.n 5.-:15: :md if nee c.ty, di ann;;c:L. . 'f the t~dt i< to cke.e *J: v.::t. c ../..:. c:d:! irm ne ee: nut.s..

                               .                                                                                                                                                         b:: tat :.:it u, a w:,.i er. h.

2. .hc. . n ..a.

J - c..C.s C ,.t ..A. GB. CC f.

                                   .                                          ....r...u...
                                                                                   ..a.~             C ... :. .1.,..             .

i

11. sumove the .mtpe!!er na. C.,so.!:!s

      .: sme                 . ; i . ... ,. ., . 6. ..                                                   .

hae left hand thre.:!: .' toh:b OIA GF.. GG. G g~. '. '. .' . ; . ' ". ," ,,. / ' ' GVDS. GVE, GVil have 3ri ht hand thre:d.) "ihec,

4. He eve ri::ch.th.: ,tcc:., b::h !!cch yipin . or remove the impel:Or.

acver..: cir:u! ate:t pr:rg af so qu:pp:c. .

12. Withdrav roter assemb!v frcm r:ar et motor i lur.nv '.vnter j: k; co Iing in' : and dr id :en- tion, t.aking care n.ot to dia v rot. r to drop, th ne:'.m.s. :' used.

che;; shdt to sut stator imer. l re:r be: ring housing to ' 2

6. Renove be:ts..h /. z: .

                                                                                   ~7.
                                                                               ..,en             2,t..s..- t.k. .. 'r: ,c?.n,~,.                                        13. Rs: move th: three screws r.-tainier t s...
                     . . . .,r wm.q;   i
                                                                         .s       ...               .

h.ensing .to the st: tor asse::6iy, :.nd thea rena

7. Renreve t.he scir.. and ic.ekve:she.r holding . tnen th: tne housm;.

rear ! enc; to :.::r bearmg housm;, and . .m; t,a: front re t.~,.,.. . t;a, r ,...e...,. .a.n,.,,. 21 d .in P:r:gr:ph , ,. ,.,

14. Remove the ser:w and !a:kw: she -

l S. CA.:ch end p!ay nx mdi rnove the front bratm;. l . . .

                            -. 19-                                                                                                                                        15. Cheek for beadn; wc:: c:n b: mad: et this time.

9. h:mcv: bolts W:in'e r.mto: s:::fon to pu=p c:s. See Paraersch ~ ~

t-12. Ps:;c 13. c..

                                                                                                                    ,.,,e      bok. .a.n...'.           .c.                                                                                                                                    :

g . . ,',.u.. ,. 5.,..,.,,

                                     .            . . :s ,               . . . 2.r      .e.. }..,v        .. . s..                                                       16. Reassemb!: pu:np by reversinit                                         1 dh.
                                                                                                                                                                                                                                                                                              .. ; ~

E .r.c:~

he t a :::r cedure; reph.cc chi ra5.m..\ .w . . Gv ~.

c u.. l ' mov.: the et'ze ..hch he: Ids e :th:r%:.t. 5i, n.s.:. , r. O TAs. :.. L 5>

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Oth:. izir:. an ! !. i:t -::. :e .5 ni the hc.. w

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eradic , c : . : 1::e b;.le ast.:m ih

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t I 5* s.*. c '* 3 . yg..., [7,' *d l' :.'. [ .. -- , . 6-,'..**'..b...*'1'.a*,.'3..'.k.t'.'.'. .. .. ,.. .:s. 3 . . .3 e . ...

j. c ,'.'. .. .. :.. .g.............:.....,.<,,,....

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                                !urther disar                               .

4.h is inr4-c..:J. n., st.ta . .derd en m. e.te h.nd to inne that i: d.*es st.ru:;ed. bac. .-c;u r.i' m ech. :,. 3.., es;':c- .smp:1!er -sanM, byr.ot bit d. Aho, citerk en i cy .w. nes G. e.ti. .:: to n ce er mar. pe:fsaned en ta: Para;raph 4-1-4. ?:re 19 st: bef5:c nrearsem:i:np C

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t tmit withou. ... hr.ir.g to 1.: movied to :. veci. .- rear beatin7, hcu; I

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                                          .                                                                                                                 08/21/79 JOB TICMET (WORK REQUEST)
                                  .                   REVIEW . CLASSIFICATION . ROUTING CONTROL FORM JOB TICKET NUMBER                        ,/4/-l// h

1. Does work represent a change or modification to an existing system or component?

If yes, an approved change modification is required per AP 1021. C/M No. - Yes No 7 2a. Does work require an RWP. Yes No V 2 b. Is an approved procedure required to minimize personnel exposure. Yes No 3a. Is work on a QC component as defined in GP 1008.' Yes / No 3b. If 3a is yes does work have an effect on Nuclear Safety? If 3b is yes, PORC reviewed Superintendent approved procedure must be used. Yes / No

4. Agreement that a PORC reviewed, Superintendent approved procedure is not required for this work because it has no effect on nuclear safety. (Applies only if 3a is Yes and 3b is No).

Mi- arW W ml Unit Supeririten' dent Date Sa. Is the system on the Environmental Impact list in AP 1026. Yes No # 5 b. If Sa is Yes, is an approved procedure required to limit environmental impact. Yes No l l 6. Agreement that Sb is No. (Required only if Sa is Yes).

                                                                                                                      //A Unit SuperintendenuSupervisor of Operations                                                      Date

7. Plant status or prerequisite conditions required for work. A l

I

8. QC Dept. review, if required in item No. 3.

QC Supervisor --eb, /M Date 9,

                                                                                                                                                         .          fM.

(' 9. Does work require code inspector to be notified. Yes No

10. Supervisor of Maintenance approval to commence work: Date if24/dO

11. Maintenance Foreman Assigned //kT bA.)E

12. Code inspector notified. Name MM M Date ,

13. Shif t Foreman's approval to commence work ' r-- Date f V' / /

j l t I l Initial if Shift Foreman signature is not required TMbl54 Rev. 5-80 I l 11.0 l

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3-+ 1026 Revision 16 08/21/79 JOB TICKET (WORX REQUEST) REVIEW CLASSIFICATION . ROUTING CONTROL FORM JOB TICKET (WORK REQUEST) NUMBER 4/3.2. 14 Retest met acceptance criteria Yes 7 No -

15. Work Performed by date/ time Work Reviewed - Maintenance Foreman's Signature b - ._ 0 ) { g,

16. 'Nohkcompleted and component aligned for testing.

Initial if S.F. signature is not required. Shift Foreman's Signature Date

17. Testing completed and component released for normal use.

I I initial if S.F. signature is not required. 567: F6(eman's S.gnature f~ Date

18. Quality Control Department review of work and testin mpleted (QC work only).

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Survedlance Report No. F7C artmenT ' ' ' Date f

19. Supervisor of Maintenance Job Ticket (Work Requesti and procadure are complete and signed off as required.

Change / modification form has been signed off as required. whlm o.,e Sue.~i.o, o, ye....e S., .,u,e

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Revision 10

                                                                                                                         - O ."O8/21/79 JOB TICKET (WORK REQUEST)

REVIEW CLASSIFICATION ROUTING CONTROL FORM  ; l i JOB TICKET NUMBER

                                                                                                                              - -^

1. Does work represent a change or modification to an existing system or component?

If yes, an approved changs modification is required per AP 1021. C/M No. Yes No V 2a. Does work require an RWP. Yes No p 2b. Is an approved procedure required to minimize personnel exposure. Yes No /

33. Is work on a QC component as defined in GP 1008. Yes / No 3 b. If 3a is yes does work have an effect on Nuc! ear Safety? if 3b is yes, PORC reviewed Supesintendent approved procedure must ce used. Yes f/ No

4. Agreement that a PORC reviewed, Superintendent approved procedure is not required for this work because it has no effect on nuclear safety. (Applies only if 3a is Yes and 3b is No).

                                                                   /410*Y 0                    A/A Unit Supenntendent                 Date Sa. Is the system on the EnvironmentalImpact list in AP 1026.                                                  Yes           No #

Sb. If Sa is Yes, is an approved procedure required to limit environmentalimpact. Yes. No #

6. Agreement that 5b is No. (Required only if Sa is Yesl.

Unit Sucenntendent/ Supervisor of Operations Date

7. Plant status or prerequisite conditions required for work.h *Mf

8. QC Dept. review, if required in item No. 3.

QC Supervisor g;;_ Date

9. Does work require code inspe'etor to be notified. Yes No #

SG. Supervisor of Maintenance approv i to e mency wqrk: ate / 23f9ts

11. Maintenance Foreman Assigned: * ., _ r2 AMOI

13. Code inspector notified. Name [ te

13. Shift Foreman's approval to comme c work _1 e Date /0!?d!Od l I initialif Shift Foreman signature is not required l

TMI-154 Rev. 5-80 L 11.o

1026

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7. " , 08/21/79 JOB TICKET (WORK REQUEST)

REVIEW CLASSIFICATION ROUTING CONTROL FORM JOB TICKET (WORK REQUEST) NUMBER ,.

14. Retest met acceptance criteria Yes No O

15. Work Performed by date/ time Work Reviewed Maintenance Foreman's Signature (se $ (dCLPf4 BP g ,

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16. Work completed and component aligned for testing. ,

I I Initial if S.F. signature is not required. /M SMGt Fe eman's Signature

                                                                                                                     //'/k~Date

17. Testing completed and component released for normal use.

I I initial if S.F. signature is not required. Stuft Foreman's Signature Date

18. Quality Control Department review of work and testing completed C work only).

ad+ SurveJ4nce Report No. ZdW-QC D'eiertment n/wk Date

19. Supervisor of Maintsnance Job Ticket (Work Request) and proce ure are complete and signed off as required.

Change / modification form has been signed off as required. [I !2.I D Date Superwsor of tegenance Signature l l i l 12 0

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GENERATl0N C0103flVE OQlMi tMM s001F UNIT 1< vpy JOB TICNET FORM (WORK REQUEST).THREE MILE ISLANO I

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b Y c!C# Tin h s'as.'N' oo en l r= p , OS A o St .... 16WS 3 o 3 sm ytnt i l l Limitsand Precautions: a) Persows Comply with the Provisions set forth in AP 1002 and Met Ed Safety Manual b) Equipment , BSL E Vl0ii( AREA C_EAhE) L

                           ., maa,                                                                      U3 A~ COM?_E"lDi\ OF .08 Post Wntenance Testing required and Acceptance Cri:eria.

p QgM .L "A . COPY 1 ORIGINATOR-SUPERVISOR-SUPERVISOR OF M AINTENANCE-MAINTENANCE FOREMAN-JOB PERFORMER-MAINTENANCE FOREMAN-SUPERVISOR OF MAINTENANCE

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JOB TICKET (WORK REQUEST) REVIEW - CLASSIFICATION'- ROUTING CONTROL FORM JOB TICKET NUMBER 0.W. b

1. Does work represent a change or modification to an existing system or component? If yes, an ap-proved change modification is required per AP 1021.

C/M No. Yes No - 2a. Does work requires an RWP? Yes No - 2b. Is an approved procedure required to minimize personnel exposure? Yes No - 3a. Is work on a QC component as defined in GP 10087 Yes' No // 3b. If 3a is yes does work have an effect on Nuclear Safety? ll 3h is yes, FORC reviewed Superinten-dent approved procedure must be used. Yes No /

4. Agreement that a PORC reviewed, Superintendent approved procedure is not required for this werk because it has no effect on nuclear safety. (Applies cnly if 3a is Yes and 3b is No).

Umil SUFlaiNitNotNT* CAIE Sa. Is the system on the Environmental impact list in AP 10267 Yes No / Sb. If Sa is YES, is an approved procedure required to limit environmentalimpact? Yes No / S. Agreement that Eb is No. red only if Sa is Yes). UMi SLPT/5UPV 07 GPEaAliGN5 CATE

7. Plant status or prerequisite conditions required for work. (0 or shut

                                                                        ~                       j

8. QC Dept. review, if required in item No. 3.

ac sumvi5cm l oAIE

9. Oces work require code inspector to be notified? Yes No

10. Supervisor of Maintenance approval to commence work:

              .          AAT)                                                              Date          'SU

11. Maintenance Foreman Assigned: by /

12. Code inspector Notified. Name: // /Y Oate

13. Shift Foreman's approval to commente work: ,d Oate

           /Il U                Initial if Shift Foreman signature is not required.

TMI.154 2 80 I

   .                                                    ---                              '~                    ~

5:4" J08 TICKET (WORK REQUEST) REVIEW - CLASSIFICATION - ROUTING CONTROL FORM JOB TICKET NUMBER 3// b

14. Retest met acceptance criteria? Yes Y No

15. Work Performed By Date/ Time: Tlo/P6 /03# s Work Reviewed-Maint. Foreman's g$U

                                                                 \        -J       !-t -    _2 J

16. Work completed and component aligned for testing.

            \                    initial if S.F. signature is not required.

hlW SHIFT F0riEWWs sign DATE

17. Testing comp!eted and component released for normal use.

h3Ib Initial if S.F. signature is not required. h ff SHIH FChiVWS SIGN- DATE

18. Quality Contrcl Department review of werk and testing completed (QC work only).

iUSIVE'LLANCE PPl. NO-I k

                                                                     ' TC DEPAAIMENT                      DATE

19. Superviscr of Mainter.ance Job Ticket IWork Requesti and procedure are complete and signed off as re-quirei& ns moGation form has been signed off as required.

9~l6-$b DATE St,PV QAiNTENAV.! SIGN-

GENER ATION CORRECTIVE M AINTENANCE SYSTEM J08 TICKET FORM (WORK REQUEST).THREE MILE ISt.AND UNIT 1 Attachmsnt 6

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2. u u m ,c.rnne en<m mm x ^ C' MtFv9-(n P Ki COMPiBiOK OF .0 PCst Maintenance Testing required and Acceptance Criteria.

W M! ORIGINATOR-SUPERVISOR-SUPERVISOR OF MAINTEN ANCE-MAINTEN ANCE FOREMAN-COPY 1 JOB PERFORMER-M AINTENANCE FOREMAN-SUPEFiVISOR OF MAINTENANCE (

f . 2. METROPOLITAN EDISON CO M P A N Y so .., o, c-,i pe u,,i,,;. co . Sfaj-set CHAtX E tODIFICATION Location 'IMI Nuclear Statien

                                                                    -                   Middletown, Pa.

Date To R. BARLE'l - Lead Mechanical Engineer UCT3Il'i!.1 C. HAR'INAN - Lead Electrical Engineer V. CRIANDI - Lead I&C Engineer R. 'IDOLE - Manager Unit I Attached is Change Modification # /'N . 'Ihis item requires your prcr.pt ittention so that the change ray be perfecned. Please take the follcwing action: I

1. Cmplete lines 6 through 9 (page 1) .

2. Prepare a Safety Evaluation (page 2) .

3. Forward to Unit t'anager.

4. Return forms to Maintenance Office for further action.

Your prompt attention to this ratter is appreciated. i o D.V. kman Supervisor of 03rrective Maintenarre IND: tis 1 I l INTER-OFFICE I,1EMORAfJDUM

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January 17, 1980 r g MjfL/vWA.- , It l i n,ee 4 7_ d i h~.(blPW/nt&c%, ud \.s ugg l

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L. * : Sud,ccr Three Mile Island Nuc1 car Station No.1 /- C 7~ Upgrading of T:tI-1 River Water Pumps H M .'../Jv D. G. Clear Loca:on lo TM1-1 IY aject Engineering Manager Mt. Lakes /- [ k j ;73c.

                                                                                                             /-MTA Referenec: T1-0120                                                                        kmll M .       t       th-
                                                                                                                 'As.twk od NEN f3
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1. Scope and Responsibility

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1.1 The Responsible Engineer (R.E.) vill research the files and correspond with Met-Ed personnel so that all previous efforts to resolve this problem can be evaluated. . 1.2 The R.E. will review the recommendation that the pump column bolting be upgraded in strength to SAE Grade 5. This question was raised in May,1976, during a review of the seismic adequacy of the MI-I river water pumps. 1.3 The R.E. Will pursue the equipment manuf acturer, Peerless Pump Company, on the specific design changes,* estimated cost and supporting seismic analysis of the internal column stabilizers required to improve the reliability of the river water pumps. , { J%j f The nuclear related services involved are: ,g i Nuclear Services River Water Pumps Serial No. 361167/68/69 C d' p ?

1. ~

(NR-PIA /B/C). 2 '. Decay Heat River Water Pu=ps Serial.No. 361175/76 (DR-PIA /B) .

                              ~

0ne pump from each service vill be fitted for use with internal column stabilizers to check Peerless design before changes are made to all pumps. 1.4 The TMI Unit 1 existing river wate'r pump lubricating water systems ar'e ineffective and extremely costly to maintain. The R.E. will request the assistance of Systems Engineering to evaluate and redesign the existing system to improve the quality of river water pump lubrication. 1.5 The R.E. will review the river . vater pumphouse silting problems and evaluate their effect on river water pump reliability. 1.6 The R.E. will review the river water pump intiske, structure design , and evaluate its ef f ect on river water pump reliability. DY"l0 *D mM AAJL@ TM _.Co' ' ecnfo re_m_aty;nn h a e.*c.m d C .wral Pubhc Uni.tcs Cor;:oraton

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2. Schedule The proposed schedule for the sesbill:cr installation is as follows:

Design of columns with inte;;ral stabilizers 1/31/80* , order parts 2/15/80 Scismic analysis completc 3/28/80* Parts delivered at T.4I 5/13/80* . Rdbuild h~d-P1B (new columns) 6/13/80 Rebuild DR-PIA (new columns) 6/27/80

• Peerless to confirm Please contact me if you have co::ents or questions.

                                                                                     /     .;or%4 V\ R//SprafdC Exc. 292 S:jem                                                                               ,                       _
 ~

cc: D. K. Croneberger' - . J. P. Moore, Jr. 1

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NR-PIB PACKING LEAK W.R.'s 19773 WR 197g NO. J P M A M J J A S O N D 1978)P J M A M J J A S O N D J P M A M h2k # l ' 18655 19071 21983 4 _t f 22138 $$ A 22211 ha "4 4 R 22420 4-t 22440 a_a 26 "-tf-21 23579 g N s I 23858 9  ; 24252 4  ?- 2'.i056 e y 25124 b 25129 25807 - 1

;                               26004                                                                                              i from L-914                                                                     I       I 15741 S1200 Man-hours of repacking              '

accomplished under this W. R. 3e , O 3 a CD i

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                                             ...PORC r..ewed. Stat.on Superintencent approved procecure.

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                                                                                                                                                                                                       . t me                                                                                                                                                                         Yes             No
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M ETRO POLITAN ED l5ON COM PANY sussmu.nv or crusm rusuc uhimes coneaunon POST OFFICE box 542 READING, PENNSYLVANI A 19803 ,, . ,

                                                                                                                                                                                         - TELEPHONE 215 - 929 3501
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June k,.1976'.

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During the weekend of May 1 and 2 at a very critical point in our refueling recovery effort, a substantial percentage of the bargaining unit employees scheduled to work failed to report for pre-arranged work as scheduled. The failure of these personnel to report had a very detrimental effect on the - progress of the verk that weekend and probably extended the total outage time by 2h-36 hours. In our investigation into the reasons for employees not showing up it was apparent that some of them had valid reasons for not being able to report as scheduled. There vas another group for which the validity of their reason for '

                                                                                                                                                            ~

not. reporting was open to question. . l Since the purpose of discipline is not to " punish people" but to correct conduct or performance which is detrimental to fulfilling the Company's objectives, we have decided to address this situation by means of this letter. Because you vere one of those who did not report for pre-arranged work as l scheduled that ve.;kend, ve are including you among those who are receiving this letter. . This letter does not constitute disciplinary action but is to emphasize to you the requirements under the contract regarding reporting off for. prearranged, l off-schedule work, and of the Company's right under the contract to mA=inister discipline.to employees who fail to fulfill this or any other provision of the contract. A copy of this. letter will be placed in your personnel file for the record. , Specifically, Article V, Section 5 12(c)', of the Agreement.between your Iocal Union (through System Council U-9) and the Company states: ,

                                                     ,"When an employee who has been scheduled for pre-arranged, off-schedule work, fails to notify the Company in sufficient time to obtain a replacement, in order that the job may not be held up, or where absence is for udustifiable reasons. vith the burden of proof on the emuleyee, and disciplinary action is varranted, the matter vill be discussed with authorized Union representatives." (emphasis added).

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                                       . The meaning of this article is clear and emphasizes that employees have a two-                                                                                                                                                                                                                                                                              .

fold obligation:

1. Employee is obligated to report for pre-arranged, off-schedule work, j

                                                                                     -unless he has a justifiable reason for not reporting; and,                                                                                                                                                                                                                                                             I

2. In the event there is a justifiable reason for not reporting for ,

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Pre-arranged,' off-schedule work, the employee is obligated to '..

i. ' " notify the t'r==y in' sufficient time to obtain a replacement in 6. .

i . order that the job.may not be held up." - - The Company realizes that emergencies do arise at the last minute which.may - . Prevent the desired advance. notification. In these situations, especially, we .

think it is clear that the empicyee has the obligation to provide the Compazr.r  :

with adequate assurance that the. emergency did, in fact, exist. . w- S

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As an electric utility we have a special obligation to our customers. We can , affect. very dramatically their well-being by either interruption of service or - the cost of cur service. All of us are aware of the increases in the cost of electric energy experienced nationwide. Many of the reasons for these increases ' are beyond our control, but as employees-and particularly empicyees at Three

                                    ' . Mile Island-ve do have the. ability to ' mitigate the extent of those increases                                                                                                 .                           -

, .for our customers. ,

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                                               'We regret that this situation arose and we are quite villing to assume ve vill" \ ,.' . '.' , ,
                                        '. have your coopeiation 'and support in the' future unless circumstances indicate to '"
   *'                                             us that'this is not the' case. Should thnme ' circumstances, develop, the Company'~

will not hesitate to pursue its rights under the contract as appropriate.. . a. - . n.: ., e.. :

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Attcchm3nt 11 TYPICA1 TtEVE (12) 10UR 'ORKDAY IN A RADIGIU;ICULY TTIP,0III9 AREA 10P'MY = 7:00 A.M. to 7:30 P.M. with 1/2 hour lunch break and an evening meal break. 0700-0730 Dreso and travel to job site w/ tools and equirnent 0730-0845 10'tK lh hot: 0345-0900 thdress and leave job site for break 0900-0910 Braak 0910-0930 Dress and travel to job' site

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            ,                              Ui;1T #1 fut%GET.'S OPEP.ATli;3 iCO. BU-O'                                                    #

METP,OPOl_ITAN EDISON COMPAN Y so,,..u ,, a c~, iuirLMa.i., .z,e-e.

              "gc',c   t    WORKII:G HOURS                                                                       Lw: ion Ti'I i;uc v Station Middlet:..r. P' 1705' Date it. J. ROSS                                                                                        February 24, 19?.0 To D. f t. SHOVLIi!

Re: TiRC I. E. Circular 80-02 l!inutes - fluclear Plant l'.anagament Revieu - January 8,19M Please reed the attached Circular ::d understand that compliance will cartainly effect the way we do business. In order to comply with the wishes of Management an '. the !iRC requirei. cents, ve . vill adhere to the Circular with the following exception. , The 12 hour break bet :ssn work periods will not be irpplemented uhan an 8 hour break is required to accomplish a scheduled shift change. When it appears the requirements of the Circular cannot be mot, and the w;rk is scheduled, it must be authorized by the Manager - Unit #1. This authariza-ion rust

be documented.

When the requirements of the Circular were not met, and the work is unsched;15.d (not scheduled at least 24 hours in advance), ti.e ilanager - Unit #1 n;st he r:.-ified (with documentation),esithin five cays, of the reason. ] UI';nin the Operations and I;aintenance Departments, this memo applies to all persenr.el,- supervisory and union who are performing any task that related to !!uclear Safety. l Although this is a stardir.g r.iemo for an oporatir.g plant,it applies especially d:ric; j the startup and test phase of tha Unit #1 restart.

                                                                             ,                       fj l}            ho.!2.

R J. TOOLE

                                                                             !!anager - Unit (1 l

l l'JT:dk i Enclosures (2) l ct: J. J. Barton l J. J. Colitz l J. G. Herbein l T. L. Hombach-i G. P. ;liller l U. C. Potts l O t gr;.*C n .it:..t. * * *

• 1 t? *. ? 's e .

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AttCchment 14

                                  ~
               -                                                              EllCLOSURE 1 SSIt!S Ho.: 6830 Accession tio.:
                                                                          -UNITED STATES                     7917.190G57 i!UCLEAR REGULATORY COMISSICN OFFICE OF INSPECTION AtlD ENFURCEMF. tit
                                                                  '!ASHIt!GT0!i,
                                                                   .               D.C. 2.0553 IE Circular t!o. 80-02 Date: February 1,1980 Page 1 of 2
                       !!UCL'IAR FOUER PLNIT STAFF WORK HOURS Cascription of Circumstances:

Studies indicate that with fatigue, especially because of Toss of sleep, an individual's detection of visual signals deteriorates markedly, the time it takes for a person to make a decision increases and more errors are made, and re: ding ratas decrease. Other studies show that fatigua results in personnel ignoring some signals beenuse they dawlop thsic own subjective standards as to what is important, and as they become more fatigued they ignore mora signals. Insnections of personnel performance and training since the accident at Three f*in Island, have shown that in certain situations facility perscnnel are either required or allowed to remain on duty for extended periods of tim.s. Also, complaints have boon received from some licensed nuclear power plc.nt operators concarning the number of continuous hours they have been on duty. 1.icensee management is responsible for providing a sufficient number of trained personnel who are in the propar physical condition to operate and maintain tha plant. Ligsm.ato.2 gene,nLsAqu.ld review Qeir ad3 inistrative proceduras cou.2nng the worc,1.ag).o. qts of nuclear power pl_ ant staff. Thes2 procedures should establish a scund policy covering working hours for plant staff who perform safety related functions (e.g., senior reactor operators, reactor o.u rators, health physicists, auxilit y operators, I&C technicians, key main-tenanca parsonnel, etc.) Subcccmittee A!15-3 is currently devaloping criteria to address the subject of cparator work hours. Thesa guidelines util beccme a part of ANSI ill3.7. The i i:RC is alto considcring issuing req'rircmants for adainistrativa pro.:.tdures l that would control staff overtimec Until eithat tha AHSI Standard is issued tr.dendocsadby,lj"RC(viaaRegulatorii:Eide) 3i"fidaE55e"ricTiTliRotrEF6~~

                         }Ei;Wlr/ t!RC,, it is recommenoed~thYthFf5TTc9i633uid5EciIie~uicd- Ilh guidanEEiiib'uH be acpi17651Q;i@Miljhfc,ht$,JGNM                      i                        d Edhi _Quiq,ipnj

1. Scheduled wor % should be limited to the folicwing maximum work hours:

a. An individual should not be pernitted to wor!: more than J_2_!!ours, s,(ra_jpi,. t t00k Oh .

N-A g

       ^:

v Enclosure 1 IE Circular I o. 20-92 s Date: February 1, IMO Page 2 of 2

b. There s;.ould be at least a 12-houy_,brg-3 b#,acn c.11 ucr% meicdi.

c. Aa individual should not ucrk core than .72-b_,ur.s_.in 2ny_.7,da:c;,3,t!,0_p.i

d. /in individual should not work r.iore than 14 consecutiva days t.ith:ut having 2 consecutive d:ys of f.

2. In the event that spedal circunstances arise that require daviation froa tha abov2, such deviations should be a diorized by the Station '!c. asir uith acorcoriate_docu:Yant,ation ofThe c..i.ti..f.a . ..

P.T... nt.s s.h_ou ldT9 sts?f.Ed.. , and ci.n.:dulc.; deva.cpea. 7 cc.__a..2 _s uca T.ur. 2.<cep ti ___ on s ara._.w... . r. : . --re .

3. If an operator is required to work in excess of 12 continuous hours, his duties sNuld be carafully selected. It is prefer:ble that he not be ECsTdited any taskTli3?'JffEcu Ca'Fc~ reactivity or could possibly ender. gar the safe operation of thi plant.

I:o uritten ' response to this Circular is requirad. If you desire additional information regarding this matter, contact the Director of the appr:priate fiRC Reuional Office. n k 0"*D 3] Vg oc o SUh0%}}