ML20079R164
| ML20079R164 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/15/1983 |
| From: | Golden J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1049D-25, NUDOCS 8306220086 | |
| Download: ML20079R164 (1) | |
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Commonwealth Edison
)N ona First Natiorni Plaza. Chicigo, Illinois O 7 Address Reply to: Post Office Box 767 =a N / Chicago,11tinois 60690 FRINcIPAL_ STAFF f S.. l lif] t L L 1.L._ is_!
b& LJ _ f.3 i L ,1 6, e i D L.: , su i June 15, 19835{/M' i 6 i$ l b~)
g OL l t?iLElj h Mr. J. Keppler , g i' Directorate of Inspection and Enforcement y Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Re. Dresden Radiological Monitorina Program In accordance with the Dresden Unit 2 Technical Specifications, this
~1etter is to inform you of a change in dairy sampling locations. On May 14 it was found that the Corbin Farm (D-25) had sold its cows. The nearest dairy farm, belonging to Mr. V. Biros, has agreed to provide milk to the sampling program. His herd totals 130 and he is milking 50 cows. Additional details regarding the Biros farm will be provided in the annual environmental report.
If you have any further questions, please feel free to contact me.
j Sincerely ours, e v J. C. Golden Supervisor of Emergency Planning JCG:LAL: pap
- #1049D/25 I
cc: D. J. Scott G. P. Wagner D. L. Farrar L. A. Literski 8306220006 830615 PDR ADOCK 05000237 R PDR g;5,.y JUN 17 1983 g($
' k,2 SHAw, PITTMAN, POTTs & TROWBRIDGE A DAATNERSMep OF PetOFESetO88AL Comf*0AATIONS Administrative Judges Gary J. Edles, Chairman John H. Buck Christine N. Kohl June.20, 1983 Page Two The second report covers INPO's corporate assistance visit to Licensee coincident with INPO's evaluation of TMI-1.
Respectfully submitted, W t.dM,#.
Ernest L. Blake, Jr.
Counsel for Licensee ELB/tjc Encls.
cc: Attached Service List
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t
Before the Atomic Safety and Licensing Appeal Board f
In the Matter of )
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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP (Restart)
(Three Mile Island Nuclear Station,-Unit No. 1) )
SERVICE LIST Administrative Judge Administrative Judge Gary J. Edles, Chairman Ivan W. Smith, Chairman Atomic Safety & Licensing' Atomic Safety & Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 i Administrative Judge Administrative Judge- Walter H. Jordan John H. Buck Atomic Safety & Licensing Board Atomic Safety & Licensing 881 West Outer Drive 37830 Appeal Board Oak Ridge, TN U.S. Nuclear Regulatory l Commission Administrative Judge Washington, D.C. 20555 Linda W. Little i
Atomic Safety & Licensing Board Administrative Judge 5000 Hermitage Drive Christine N. Kohl Raleigh, NC 27612 Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel l- Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Jack R. Goldberg, Esquire (4)
Office of the Executive Atomic Safety & Licensing Appeal Board Panel
' Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing.& Service Section (3) Douglas R. Blazey, Esquire Office of the Secretary Chief Counsel U.S.-Nuclear Regulatory Department of Environmental Commission Resources 4
Washington, D.C. 20555 514 Executive House P. O. Box 2357
- Harrisburg, PA 17120
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John A. Levin, Esquire -Ms. Gail Phelps Assistant Counsel ANGRY /TMI PIRC
. Pennsylvania Public Utility 1037 Maclay_ Street Commission Harrisburg, PA 17103 Post Office Box 3265 Harrisburg, PA 17120 Jordan D. Cunningham, Esquire Fox, Farr & Cunningham Mr. Henry D. Hukill 2320 North Second Street Vice President Harrisburg, PA 17110 GPU Nuclear Corporation Post Office Box 480 Ellyn R. Weiss, Esquire (1)
Middletown, PA 17057 William S. Jordan, III, Esquire (l) -
Harmon & Weiss Michael F. McBride, Esquire 1725 Eye Street, N.W., Suite 506 l
LeBouef, Lamb, Leiby & MacRae Washington, D.C. 20006 l- -1333 New Hampshire Avenue, N.W.
- Suite 1100 Mr. Steven C. Sholly Washington, D.C. 20036 Union of Concerned Scientists 1346 Connecticut Avenue, N.W.
! Ms. Louise Bradford Dupont Circle Bldg., Suite 1101 TMI ALERT Washington, D.C. 20036 1011 Green Street Harrisburg, PA 17102 Chauncey Kepford
- Judith H. Johnsrud
! Mr. Norman Aamodt Environmental Coalition on R. D. 5 Nuclear Power Coatesville, PA 19320 -
433 Orlando Avenue
- - State College, PA 16801 John Clewett, Esquire l _ David E. Cole, Esquire
' The Christic Institute 1324 North Capitol Street Smith & Smith, P.C.
Washington, D.C. 20002 2931 Front Street Harrisburg, PA 17110 Michael W. Maupin, Esquire Hunton & Williams Administrative Judge 707 East Main Street Gary L. Milhollin Post Office Box 1535 Atomic Safety & Licensing Board Richmond, VA 23212 4412 Greenwich Parkway, N.W.
Washington, D.C. 20007 i
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. 9s EVALUATION of THREE MILE ISLAND NUCLEAR GENERATING STATION l
GPU Nuclear Corporation 1
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First Draft June 10,1983
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THREE MILE ISLAND (1983)
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SUMMARY
INTRODUC'ITON The Institute of Nuclear Power Operations (INPO) conducted an evaluation of GPU Nuclear Corporation's Three Mile Island Nuclear Generating Station, Unit one (TMI-1),
during the weeks of May 9 and 16,1983. TMI-1 is an 800 MWe (net) Babcock & Wilcox pressurized water reactor. The station is located on Three Mile Island in the Susquehanna River about ten miles southeast of Harrisburg, Pennsylvania. The unit began commercial operation in. September 1974 and has been shut down since February 1979.
PURPOSE AND SCOPE INPO conducted an evaluation of site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas needing improvement. Information was assembled from discussions, interviews, observations, and reviews of documentation.
The INPO evaluation team examined station organization and administration, operations, maintenance, technical support, training and qualification, radiological protection, and chemistry. The team also observed the actual performance of selected evolutions and l surveillance testing. As a basis foe the evaluation, INPO used perfwmance objectives l
and criteria relevant to each of the areas examined; these were applied and evaluated in light of the experience of team members,INPO's observations, and good practices within the industry.
INPO's goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant operation. The recommendations in each area are based on best prac-tices, rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance.
! DETERMINATION 7tthin the scope of this evaluation, the team determined that TMI-1 is in an acceptable material condition and is being effectively maintained by qualified personnel.
! The following beneficial practices and accomplishments were noted:
- There is a well-defined program focused on operational planning and preparation for startup, including the startup qualification program.
There is a strong commitment to management self-assessment activities, including
, the Operations QA Program, the Radiological Assessment Program, and the Off-l shift Tour Program.
THREE MILE ISLAND (1983)
Page 2 Station personnel are well qualified. Their morale, positive attitude, and motivation reflect commitment to improved performance.
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There is an overall improvement in station housekeeping.
Improvements were recommended in a number of areas. The following are considered to be among the most important:
The overall station chemistry program, including coordination between on-site and off-site activities, needs to be strengthened. .
There is a need for more first-line supervisory involvement in unlicensed operator and chemistry activities.
l The warehouse program for ensuring adequate inventory and quality of spare parts 4 needs to be upgraded.
Increased emphasis is needed on the industrial safety program to reduce the number of lost-time accidents.
In each of the areas evaluated,INPO has established PERFORMANCE OBJECTIVES and supporting criteria. All PERFORMANCE OBJECTIVES reviewed during the course of this evaluation are listed in APPENDIX II.
Findings and recommendations are listed under the PERFORMANCE OBJECTIVES to l which they pertain. Particularly noteworthy conditions that contribute to meeting PERFORMANCE OBJECTIVES are identified as Good Practices. Other findings describe conditions that detract from meeting the PERFORMANCE OBJECTIVES. It would not be productive to list as Good Practices those things that are commonly done properly in the industry since this would be of no benefit to GPU Nuclear Corporation or to INPO's other l
member utilities. As a result, most of the findings highlight conditions that need improvement.
The recommendations following each finding are intended to assist the utility in ongoing l
efforts to improve all aspects of its nuclear programs. In addressing these findings and l recommendations, the utility should, in addition to correcting or improving specific l
conditions, pursue underlying causes and issues.
As a part of the second and succeeding evaluations of'each station, the evaluation team will follow up on responses to findings in previous reports. Findings with response actions that are incomplete but progressing on a reasonable schedule have been carried forward in APPENDIX I to this report. In areas where additional improvements were needed or where resoonse actions have not been timely, a new finding that stands on its own merit has been written. Thus, this report stands alone, and reference to previous evaluation reports should not be necessary. For this evaluation there are two new findings relating to previous findings and four findings carried forward in Appendix I.
l The findings listed herein were presented to GPU Nuclear Corporation management at an exit meeting on May 19, 1983. Findings, recommendations, and responses were reviewed with management on . Responses are con-sidered .
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THREE MILE ISLAND (1983)
Page 3 1 To follow the timely completion of the improvements included in the responses, INPO requests a written status by . Additionally, a final update will be requested six weeks prior to the next evaluation.
The evaluation staff appreciates the cooperation received from alllevels of GPU Nuclear Corporation.
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Page 4 GPU NUCLEAR CORPORATION Response Summary l
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Page 5 c ORGANIZATION AND ADMINISTRATION INDUSTRIAL SAFETY PERFORMANCE OBJECTIVE: Station industrial safety programs should achieve a high degree of personne1 safety.
i Tu=L I Ineressed emphasis is~needed on industrial safety. Although the (OA.5-1) , established program is effective in correcting identified safety deficiencies, the trend of lost-time accidents has not improved, and 'several examples of lack of adherence to safety rules were noted. A company safety manual has been under review for some time, but has not been approved for use.
Recommendation Upgrade the existing industrial safety program with emphasis on the following~ areas:
- 'i a. timely approval and issue of company policies regard-ing industrial safety
- b. strengthened supervisory involvement in promoting adherence to safe work practices
- c. Improved safety awareness and compliance with safety rules by all personnel
Response
1 DOCUMENT CONTROL PERFORMANCE OBJECTIVE: Document contro1 systems should provide correct, readily accessible information to support station requirements.
Finding Vendor technical manual content, distribution, and use are not (OA.G-1) rigorously controlled. Some manuals marked " Controlled Copy" were noted in the plant without evidence of proper control.
Some maintenance procedures refer to portions of technical manuals for detailed work instructions even though the refer-enced portions have not been reviewed for technical adequacy.
Recommendation Establish improved control of vendor technical manuals to ensure they are complete and current. Ensure that portions of manuals used to control work are technically adequate.
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Pago6
, Response i
QUALITY PROGRAMS -
PERFORMANCE OBJECTIVE: Quality programs should contribute to the effective performance of activities important to safety and reliabDity. Quality programs include quality assurance, gaality control, and other programs .that provide an Indaaandant ama=== ment of plant activities or that function specifically to promote quality of work-manship. .
Finding The foRowing Good Practice was noted: An effective lwogtam (OA.8-1) is in use for monitoring plant operations. The Operat.;ons QA Program has ten dedicated monitors who are SRO licensed or L have equivalent experience. Activities to be monitored are selected using a graded approach based on safety importance, previous experience, uniqueness, and plant data trends.
Summary reports listing all findings are given to responsible line supervisors for information and appropriate action. These findings include minor deficiencies corrected in the course of monitoring. . Corrective actions for more significant findings are tracked using.' Material Non-Conformance Reports or Quality Deficiency Reports.
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THREE MILE ISLAND (1983)
Pcge 7 OPERATIONS CONDUCT OF OPERATIONS PERFORMANCE OBJECTIVE: Operational activities should be conducted in a manner that achieves safe and reliable plant operation.
O Finding Shift supervisory personnel need to be snore effectively involved (OP.2-1) in routine operations activities outside the control room.
Although supervisory tours are conducted, routine activities of operations personnel are not consistently monitored to ensure conformance with station policies and good operating practices.
Recommendation Emphasize shift supervisory involvement in routine operations activities outside the control room.
Response
Finding The following Good Praetfee was noted: An effective program (OP.2-2) is used to administer and control routine non-technical speciff-cation surveBlances conducted by the Operations Department.
The program includes items such as the following:
- a. component lubrication
- b. component operability and performance l c. rotation of non-operating equipment l d. Inventory of chemicals, fuels, and other supplies l
l e. data acquisition for long-term trending of equipment i The control and administration of these items using a single, l computerOved orogram contributes to equipment reliability I and minimizes the administrative burden on the ',fanager Plant Operations and shift personnel.
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TIIREE MILE ISLAND (1983)
Page 8 PLANT STATUS CONTROIS PERFORMANCE OBJECTTVE: Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.
Finding Additional emphants is needed to improve operator response to (OP.3-1) equipment alarms, particularly those outside the control room.
Equipment is sometimes operated with unresolved local alarms.
Recommendation Emphasize to operators the need for timely and thorough in-vestigation of equipment alarms. Increase supervisory involve-ment in shift activities to ensure that alarms on operating equipment are minimized.
Finding Performaree of Independent verification of valve position needs (OP.3-2) improvem mt. The second verification of valve position is sometimes performed by observing the first individual check the
. valve peeltion rather than performing an independent second check.
Recommendation Revise current operating practices to ensure that the second t valve position verification is accomplished by an independent l check. 1
Response
I OPERATOR KNOWLEDGE AND PERFORMANCE i PERFORMANCE OBJECTIVE: Operator knowledge and performance should support safe l and reliable plant operation. j Finding Operator and supervisor knowledge need improvement in some (OP.4-1) areas. Some auxiliary operators could not explain proper opera-tion of the diesel engine support systems. Additionally, some control room operators and supervisors had difficulty discussing ,
electrical distribution controls and using electrical drawings to analyze unusual transients. i i
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Page 9 Recommendation Improve supervisor and operator knowledge in the areas identi-l fled above. Include these areas in the existing pre-startup training program.
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Response
OPERATIONS PROCEDURES AND DOCUMENTA'ITON PERFORMANCE OBJECTIVE: Operational procedures and documents should provide' appropriate direction and should be effectively used to support safe operation of the Plant.
1 Finding Some emergency and operating procedures need improvement to (OP.5-1) enhance their usabRity. Some cautions follow the action steps to which they apply, and some notes contain procedural steps. It
! is recognized that extensive effort has been made to improve l emergency and operating procedures.
Recommendation During normal review and revision of plant procedures, identify and correct the- type of problems noted above.
Response
Finding 'The following Good Practice was noted: Emergency action (OP 5-2) leveh for initiation of the emergency plan are placed at appro-priate steps in emergency and abnormal condition operating procedures. This method of indicating when specific emergency plan classifications should be implemented eliminates the need for referring to other documents at a time when rapid response is important.
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Page 10 OPERATIONS FACHJFIES AND EQUIPMENT PERFORMANCE OBJEC'!TVE: Faellities and equipment should effectively support plant operation.
Finding The foDowing Good Practice was noted: The station has an (OP.6-1) effective cleanliness and ;-r _-i::;-ing program. The program includes the following key elements:
- a. clear definition of area responsibilities
! b. weekly inspections by plant management
- c. written inspection reports with follow-up action on noted deficiencies
- d. off-shift tours by senior management that include a review of plant cleanliness conditions As a result of this program, the station has maintained a high level of cleanliness during a period of extensive maintenance.
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Paga 11 MAINTENANCE MAINTENANCE ORGANIZATION AND ADMINBrRA'ITON PERFORMANCE OBJEC'ITVE: Maintenanen organimation and administration should ensure effective implementation and control of maintenance activities.
Finding Control of maintenance activities needs improvement. Mainte-(MA.1-1) nance activities are not always formally documented to reflect appropriate review and authorization of changes in work scope.
QA requirements, use of procedures and vendor manuals, and post-maintenance test requirements need to be established and documented prior to continuing jobs with changes in work scope.
Recommendation improve control of maintenance activities. Ensure that proper review and approval by appropriate managers is documented for extended work scope.
Response
WORK CONTROL SYSTEM PERFORMANCE OBJEC'ITVE: The control of work should ensure that identified main-tenance actions are properly completed in a safe, timely, and efficient manner.
Finding The plant needs to improve the identification and processing of (M A.3-1) defleiencies for wiative maintenance action. Many valve,
. flange, and pump deficiencies are not included in the work con-trol system. In addition, some caution tags identify deficiencies that are not included in the work control system.
Recommendation Develop measures to ensure timely identification and processing of plant deficiencies for corrective maintenance. INPO Good Practice MA-301, " Plant Material Deficiency Identification,"
could be of assistance in this effort.
Response
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THREE MILE ISLAND (1983)
Page 12 PREVENTIVE MAINTENANCE PERFORMANCE OBJECTIVE: Preventive maintenance should contribute to optimum performance and reliabuity of plant equipment. i l l Finding The following Good Practice was noted: Infrared heat sensors (MA.5-1) for monitoring steam trap performance are used by maintenance personnel to detect and photograph hot spots in electrical equipment and systems. This practice has resulted in the early identification and correction of electrical deficiencies in equip-ment such as inverter and control rod drive cabinets, isolated phase bus duct grounding straps, and various distribution systems.
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MATERIALS MANAGEMENT l l PERFORMANCE OBJEC'IYVE: Materials management should ensure that necessary parts and material are avaBable when needed. .
Finding Improvement is needed in warehousing. practices to ensure that (M A.9-1) the quality of stored items is maintained. Storage requirements, preventive maintenance, and environmental and shelf-life con-trols are not adequately implemented.
l l Recommendation Establish programs that address storage requirements and pre-ventive maintenance for stored equipment and material. Up-grade existing efforts in the area of environmental and shelf-life controls. Ensure these programs include materials in " direct turnover" status.
Response
l Finding The warehouse spare parts program does not fully support the (M A.9-2) Maintenance Department. Problem areas include the following:
- a. Some items for critical plant equipment are kept in uncontrolled shop and plant storage areas. Items are
. issued in standard quantities, and current procedures l
do not provide for returning unused items to inven-tory.
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- b. Consumables required for the preventive maintenance program are not always available.
- c. Maintenance Department is sometimes not informed when their recommendations for spare parts stocking are revised or disapproved. This sometimes results in inadequate spare parts inventory and causes increased direct purchasing of material and supplies,
- d. Maintenance planners spend the majority of their time in parts procurement activities because of inadequate ,
warehouse inventory, direct purchase activities, and i
- tracking of space parts inventory requests. '
Recommendation Implement appropriate actions, including those listed below, to strengthen warehouse support of the Maintenance Department.
i a. Upgrade the spare parts issue and return procedures to accommodate returning unused items to inven-tory. Provide for traceability and storage of usable equipment removed from the plant or equipment obtained by direct purchase.
- b. Revise the spare parts provisioning program to ensure Maintenance Department input in determining items to be stocked and stocking levels,
- c. Improve the timeliness of the review process for spare parts inventory requests.
- d. In conjunction with b and c, consider a weekly status report to maintenance planners on outstanding pur-chase requisitions and spare parts inventory requests.
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Page 14 TECHNICAL SUPPORT OPERA'ITNG EXPERIENCE REVIEW PROGRAM PERPORMANCE OBJECTIVE: Industrywide and in-house operating experiences should l be evaluated and appropriate actions undertaken to improve plant safety and reliability.
SOER STATUS The status of Significant Operating Experience Report (SOER) recommendations is as follows:
Number of Recommendations Action Taken 109 Satisfactory 28 Not appilcable 36 (1 red tab) Pending - awaiting decision 19 (No red tab) Pending - awaiting implementation 0 Need further review 16 Previously evaluated as satisfactory or not applicable The following recommendations are pending - awaiting decision:
SOER Number Recommendation Number l 81-6 2 81-8 1,4 81-15 la,1b 81-16 1,3 82-7 1,2 82-10 1,2,3,4,5,6,7 I
82-11 5 82-12 1 l 82-13 1,2,3,6,7,8,10 82-15 1,4 i 82-16 1 83-1 1,2,3,6,7,10,11,12 l
The following recommendations are pending - awaiting implementation:
l SOER Number Recommendation Number 81-5 4 l 81-6 1,la I
81-10 1 81-15 2e 32-8 1 82-11 1,2,3,4 82-13 5,9,11,12,13 82-15 3 83-1 9,13,14 2
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THREE MILE ISLAND (1983)
Page 15 An update on the status of each recommendation listed in the "pending - awaiting decision" or "pending - awaiting implementation" categories shown above is requested in the six-month follow-on response to this report. In addition, the status of each red tab SOER recommendation received subsequent to this evaluation should be included in the six-month follow-on response. A tabular summary, similar to that above, is requested.
Finding The operating experience review program should be improved.
(TS.3-1) Although some vendor bulletins are currently being addressed, a comprehensive program is not in place to review and process appropriate vendor information.
l Recommendation Modify the program currently being used to process INPO and NRC information, as described in GPU Nuclear procedure No.
EP-017, to specifically include vendor information, or develop and implement a separate program to ensure that vendor infor-mation is properly reviewed and processed.
Response
PLANT MODIFICATIONS PERFORMANCE OBJECTIVE: Plant modification programs should ensure proper review, control, implementation, and completion of plant design ehe. e in a safe and timely manP s.
Finding Some temporary modifications are instaHed on operating (TS.4-1) systems without a technical design review. Procedure AP 1013 for electrical jumpers, lifted leads, and mechanical bypasses requires only a limited safety evaluation. It does not require technical design reviews similar to those performed for permanent modifications.
Recommendation Conduct technical design reviews of electrical jumpers, lifted leads, and mechanical bypasses currently in place on operating systems. Implement controls to ensure technical design reviews are performed on future temporary modifications prior to plac-ing modified systems in service.
Response
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Page 16 Finding The review of plant modification designs needs improvement.
(TS.4-2) Plant personnel do not always perform operability and maintain-ability reviews. Designers sometimes fail to identify physical obstructions and structural restrictions.
Recommendation Ensure that plant modification designs are reviewed for opera-bility and maintainability. Increase involvement of Operations and Maintenance personnel in the reviews. Ensure that reviews include plant walkdowns by designers prior to construction.
Response
REACTFOR ENGINEERING PERPORMANCE OBJEC'11VE: On-site reactor engineering activities should ensure optimum nuclear reactor operation without compromising design, safety, or nuclear fuel limits.
Finding Formal controls need to be established for software devel-(TS.5-1) opment and revision on the computer used by the nuclear engi-neer. This computer is used for important reactor physics calculations in support of plant operation.
Recommendation Develop administrative controls for software development and revision.
Response
PLANT PERFORMANCE MONYFORING PERFORMANCE OBJEC'ITVE: Performance monitoring setivities should optimize plant efficiency and reliability.
Finding Improvements are needed in the plant performance monitoring (TS.6-1) program. Some instrumentation used for data collection is not included in the surveillance or preventive maintenance calibra-tion programs. The responsibility for performing data analysis is not clearly defined. Important system or component degrada-tion may not be readily detected due to the time delay between data collection and transmittal for analysis.
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Page 17 Recommendation Include instrumentation used for plant performance monitoring data collection in a routine calibration program. Establish clear responsibilities for data analysis. Consider increasing the fre-quency of data transmittal for analysis to ensure system or component trends do not go undetected.
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Paga 18 TRAINING AND QUALIFICATION IJCENSED OPERATOR TRAINING AND QUAIRICA'ITON FERFORMANCE OBJECTIVE: 'the licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job feetions.
Finding Improvements are needed in the on-the-job training (OJT) pro-(TQ.3-1)' gram for licensed operators. Although good OJT study guides exist for some major plant evolutions covered by procedures, additional study guides should be developed to identify the actions, knowledge, and skill requirements for each OJT task or checkout.
Recoinmendation Develop guidelines for actions, knowledge, and skills required for successful completion of each OJT task or checkout. INPO Good Practice TQ-501, " Development and Implementation of
. On-the-Job Training Programs," may be of assistance in this effort.
Response
MAINTENANCE PERSONNEL TRAINING AND QUAIRICATION FERFORMANCE OBJEC'ITVE: The maintenance personnel training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job factions.
i Finding Mochanical, electrical, instrument, and utility maintenance (TQ.5-1) personnel need initial training in basic maintenance funda-i mentals or plant systems prior to job assignment in the plant.
Recommendation Provide systems overview and maintenance fundamentals train-ing to all personnel prior to their assignment to in-plant mainte-nance duties. Evaluate the existing skills and knowledge of experienced personnel entering the maintenance force, and provide initial training as necessary. INPO documents " Guide-lines for Mechanical Maintenance Personnel Qualification" (GPG-05), " Guidelines for Electrical Maintenance Personnel Qualification" (GPG-07), and " Guidelines for Instrument and Control Technician Qualification" (GPG-08) could be of assis-tance in this effort.
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Response
Finding OJT for mechanical, electrical, and utility maintenance person-(TQ.5-2) nel needs improvement.. OJT tasks and clieckouts have not been established to ensure that these personnel are appropriately trained or evaluated in required skills and knowledge.
Recommendation Develop and implement a more structured OJT program incorporating the following:
- a. identification of tasks to be performed, simulated, or discussed
- b. identification of individuals or classifications of individuals qualified and responsible for conducting OJT
- c. skill and knowledge required for each identified task to be performed, simulated, or discussed
. d. Identification of individuals or classifications of-individuals qualified and responsible for conducting final checkouts
- e. assurance that individuals have demonstrated com-petency in specified tasks prior to job assignment The existing minor maintenance qualification sheets, which document competency on selected minor maintenance tasks, could be expanded to document completion of OJT. INPO Good Practice TQ-501, " Development and Implementation of On-the-l Job Training Programs," could be of assistance in this effort.
Response
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Page 20 Finding De following Good Practice was noted: De continuing training (TQ.5-3) program for maintenance personnel is effective and comprehen-sive. Maintenance personnel rotate through four weeks of formal training each year. The training content for each cycle of' training is determined by maintenance and training manage-ment. Among topics included are the following: specific t systems, components, or processes; industry experiences; and administrative requirements and procedures. Individuals are assigned to attend scheduled training as deemed necessary by maintenance supervisors.
i TRAINING FACILFITES AND EQDIPMENT j PERFORMANCE OBJECTIVE: The training facDities, equipment, and materials should effectively support training activities.
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1 Finding Improvements are needed in the study and reference material l (TQ.9-1) avaDable for use in systems training. Existing system descrip-l tions are out of date. The plant is aware of this situation, and an Operations Plant Manual is being written to provide updated l
system descriptions.
' Recommendation Complete the development of the Operations Plant Manual.
Implement a process to ensure that the newly developed mate-rial will be kept updated to reflect system modifications.
Response
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RADIOLOGICAL PROTECTION ORGANIZATION A'TD ADMINISTRATION PERFORMANCE OBJECTIVE: Radiological protection organization and administration should ensure effective implementation and control of radiological protection activities.
L Finding 1he criteria used for extM-- radiation work permits (RWP) is l (RP.1-1) not sufficiently defined. Most routine RWPs are extended for l
seven days.without a requirement to resurvey areas on a routine b . sis to ensure that radiological conditions have not changed.
Recommendation Provide additional guidance in the RWP procedure on extending RWPs. Establish resurvey requirements for extended RWPs.
Response
l GENERAL EMPLOYEE TRAINING IN RADIOLOGICAL PROTECT 10N PRRPORMANCE OBJEC'11VE: General employee training should enswe that plant personnel, contractors, and visitors have the knowledge and practical abDities necessary l to effectively implement radiological protection practices associated with their work.
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Finding 1he following Good Practice was noted: During general (RP.3-1) employee training in radiological protection, each individual is
, required to perform the following activities:
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- a. demonstrate practical abilities such as donning and removing protective clothing and the proper use of personnel monitoring devices
- b. work in a simulated radiologically controlled area using a RWP specifically addressing the work to be
- performed i
- c. respond to station emergency alarms and unusual radiological conditions
Response
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THREE MILE ISLAND (1983) l Page 22 EXTERNAL RADIA'ITON EXPOSURE PERFORMANCE OBJEC'tTVE: External radiation exposure controls should minimize personnel radiation expostre.
Finding 'the station ALARA program has not been fully implemented.
(RP.4-1) Additional items needing implementation are as follows:
I
- a. man-rem estimates and exposure goals for specific jobs
- b. man-rem action levels requiring post-job reviews Recommendation Complete implementation of the station ALARA program by addressing the areas noted above.
R88Ponse PERSONNEL DOSIMETRY PERFORMANCE OBJECTTVE: 'the personnel dosimetry program should ensure that radiation exposures are accurately determined and recorded.
Finding The quality control program for the new thermoluminescent (RP.7-1) dosimeter (TLD) systete does not require the analysis of spiked TLDs.
Recommendation Expand the existing dosimetry quality control program to include spiked TLDs with the monthly personnel TLD analysis.
Develop acceptance criteria for the accuracy of these dosimeter results, and evaluate cases where acceptance criteria are not met.
Response
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THREE MILE ISLAND (1983)
Page 23 Finding Improvements are needed in the self ids pocket dosimeter (RP.7-2) (SRPD) program. The following areas need improvement:
- a. the identification of faulty SRPDs when there are un-favorable comparisons with TLDs
- b. the criteria for investigating the results of compari-sons between TLDs and SRPDs
- c. the cause of the high percentage of SRPDs that fail the caHbration check Recommendation Revise the SRPD program to include the following:
- a. Issue SRPDs to workers by serial number. Perform calibration checks on SRPDs when unfavorable com-parisons with TLDs occur.
- b. Lower the threshold and acceptable deviation per-centage values for SRPD and TLD comparison.
- c. Establish operating histories for SRPDs and remove problem doelmeters.
INPO Good Practice EPN-03, " Comparison of Dosimetry Results," could be of assistance in this effort.
Response
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THREE MILE ISLAND (1983)
Pege 24 CHEMBrRY CHEMBTRY ORGANIZATION AND ADMINBPRATION PERFORMANCE OBJEC1TVE: Chemistry organization and administration should ensure effective control and implementation of chemistry activities.
Tue".g
. Supervision of chemistry technicians needs sher.sdaing. The (CY.1-1) chemistry foreman assigned to supervise chemistry technicians is also performing other responsibilities that require significant amounts of time and limit his attention to laboratory activi-ties. As a result, chemistry technician activities are not always prioritized or monitored for optimum use of technician time.
Recommendation Initiate appropriate actions to improve supervision of chemistry technicians.
Response
Finding Coordination of activities between on-site and off-site (CY.1-2) Chemistry Departments needs ster.5Giening. For example, the preparation and approval process for station chemistry proce-dures is not always timely and sometimes results in procedures that are unnecessarily complex. Also, the installation and calibration of new analytical equipment are not always timely.
Recommendation Improve the coordination of activities between the on-site and off-site Chemistry Departments including addressing the items noted above.
Response
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THREE MILE ISLAND (1983)
Page 25 CHEMBrRY PERSONNEL TRADUNG AND QUALIFICATION PERFORMANCE OBJEC"ITVE: 'the chemistry qualification program should ensure that i chemistry personnel have the knowledge and practical abGities necessary to implement chemistry practices effectively.
Finding Chemistry techniciarJ need additional training in fundamental (CY.2-1) water chemistry and plant systems knowledge.
Recommendation Assess the knowledge level of individual technicians in the areas noted in the finding, and develop a training program to correct identified deficiencies.
Response
LABORATORY AC'ITVrITES PERFORMANCE OBJEC11VE: Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters.
Finding Laboratory work areas are not always maintained in accordance (CY.4-1) with good housekeeping practices. Work areas were dusty, and countertops were cluttered.
Recommendation Provide more emphasis on laboratory housekeeping practices.
The chemistry laboratc, ries should be kept clean and uncluttered to provide an atmosphere that promotes optimum analytical accuracy.
Response
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THREE MILE ISLAND (1983)
Page 26 CHEMICAL AND LABORATORY SAFETY PERFORMANCE OBJEC'ITVE: Work. practices associated with chemistry activities should ensure the safety of personnel Finding Safety practices associated with chemistry activities need (CY.5-1) Improvement. Eating, drinking, and smoking was observed in the secondary laboratory where poisonous chemicals are stored and handled. In addition, safety equipment is not always used or accessible.
Recommendation Place more attention on chemistry and laboratory safety prac-tices. Eating, drinking, and smoking should not be allowed in the secondary laboratory. Keep the areas around safety equipment such as eye wash fountains and emergency. showers clear so that emergency access to these' facilities will not be affected.
Ensure that technicians wear proper eye protection while work-Ing in the laboratory.
Reaponse
THREE MILE ISLAND (1983)
APPENDIX I Page1 APPENDIX I Summary of Outstanding Response Action from Previous Evaluation (1981)
MANPOWER RESOURCES Pinding Written qualification requirements are current for supervisory (OA.3-1) and technical positions. For positions below first-line super-visors, the qualification requirements need updating.
1tecommendation Update and maintain current job' specifications for appropriate positions below first-line supervisors. INPO is coordinating an industrywide job analysis project for certain operator, mainte-nance, and technician positions. GPU may wish to utilize the results in defining qualification requirements for applicable TMI positions.
Response GPU has been involved with EEI efforts on validation of job requirements for power plant personnel GPU will be using that effort and the referenced INPO-led effort in the development of i new job specifications for nonexempt personnel The revised job specifications and a procedure to maintain these current are scheduled to be completed by December 1982.
Status Supervisory and non-supervisory exempt job specif,1 cations have i- been updated, and a program is in place to continue updating as changes occur. Action for exempt positions is considered com-plete. The non-exempt bargaining position specifications are subject to union negotiation and have not been approved. How-ever, since a new union contract was recently signed, the nego-tiation and approval of these position specifications are expected to be completed in the near future.
l l PLANT MODIFICATIONS Finding Plant operators are not able readily to determine some system (TS.4-1) configurations with available drawings. The current system of revising drawings and maintaining accurate information in the control room is adequate. However, systems that were modified prior to the new drawing control procedure have not had their drawings updated. In order to correct this problem, GPU has initiated a program to update these drawings prior to plant ,
startup.
Recommendation The program to update drawings used by operators should be I
continued to completion.
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THREE MILE ISLAND (1983)
APPENDIX I Page 2 Response GPU will have baseline engineering drawings essential for plant operations updated and in the control room prior to restart.
Review of all old modification packages, which predated the new control procedures, to ensure that previous modifications.
are properly reflected on the drawings will be completed by the end of 1982.
Stattu Efforts are progressing to update drawings for 237 modifications processed under the old change modification program. Cur-rently,193 of the modifications have been installed,156 walked down by design drafting, and 44 have not been installed. Draw-ings for all 193 modifications installed will be updated by the time of restart. Drawings for modifications to be installed under this program in the future will be revised as the modifica-tions are installed. This item should be completed by restart.
Finding Improved controls are needed to ensure piping system mechani-(TS.4-2) eal stresses are not changed without appropriate engineering
' review. The use of lead blankets around system pipes for shield-Ing purposes should receive a technical review prior to each installation. An evaluation is in progress by GPU Technical Functions personnel to determine the effects on systems that currently have add-on lead shielding in place.
Recommendation Complete the engineering evaluation of lead blankets currently in place and develop a program or guidelines to control the future placement of temporary shielding on plant piping systems and equipment.
Response This problem had been identified by the plant staff earlier this year and engineering guidelines are being developed to control the placement of lead shielding on or in the vicinity of piping systems and equipment. These guidelines will be implemented by April 1,1982. To correct the immediate problem, a radiation survey of the areas where lead blankets were installed was conducted. As a result, a large amount of the temporary shield-ing was removed due to reduced radiation levels because of the long period the plant has been shutdown. An engineering evalua-tion of lead blankets still installed will be completed and appro-priate modifications made before restart of the unit.
Status Some temporary lead shielding is still in place on plant systems. Most of this shielding will be removed by restart. An engineering evaluation will be made of the remaining temporary shielding to justify continued use. A procedure has been drafted and is scheduled to be issued by restart of the unit. The draft procedure appears to provide the necessary guidance and to require appropriate reviews to control future use of lead shield- )
ing. This item should be complete by startup.
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APPENDIX I Page 3 l TRAINING ADMINBrRATION l
P!nding A training program for middle-level managers in plant systems.
(TQ.2-1) and technology is needed. Currently, such courses exist for individuals at the operator / technician level and at the senior management level However, individuals in positions between j these levels receive no such training.
Recommendation Provide plant systems and technology training to middle-level managers. Existing programs for personnel at operator /techni-I clan levels and/or senior management levels could be utilized in this effort.
Response GPU agrees that a formal training program for middle-level managers in plant systems and technology is needed. A specific -
course on pressurized water reactor (PWR) systems and tech-r l
nology is under development and is scheduled to be available in Jttly 1982. Attendance at this course, or portions thereof, will be determined on an individual basis taking into consideration the background, work assignments, and professional development objectives of the individual employee.
l Status A course in plant systems and technology has been implemented for corporate and site engineers. When this initial course is i
completed in the fall of 1983, it will be modified based on feedback from attendees and an assessment of the needs of middle management. The modified course ir expected to be in place and offered to managers by December 1983.
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Page1 APPENDDCH Performance Objectives Reviewed i
ORGANIZATION AND ADMINISTRATION l OA.1 Station Orgenization and ' Administration Station organization and administration should ensure effective implementa-tion and control of station activities.
OA.2 Management Objectives Station management objectives should be established and progress monitored through a formal program.
O A.3. Management Assessment Management should monitor and assess station activities to improve perform-anee in all aspects of nuclear plant operation.'
OA.4 Personnel Planning and Qualification ,
Personnel programs should ensure that station positions are filled by highly quellfled individuals.
OA.5 Industrial Safety Station industrial safety programs should achieve a high degree of personnel safety.
l OA.6 Document Control Document control systems should provide correct, readily accessible informa-tion to support station requirements.
OA.7 Station Nuclear Safety Review Committee Review of station nuclear activities by a knowledgeable, interdisciplinary group should ensure achievement of a high degree of nuclear safety.
OA.8 Quality Programs Quality programs should contribute to the effective performance of activities important to safety and reliability. Quality programs include quality assur-ance, quality control, and other programs that provide an independent assess-ment of plant activities or that function specifically to promote quality of workmanship.
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THREE MILE ISLAND (1983)
Prge 2 OPERATIONS OP.1 Operations Organization and Administration Operations organization and administration should ensure effective imple-mentation and control of operations activities.
OP.2 Conduct of Operations Operational activities should be conducted in a manner that achieves safe and reliable plant operation.
OP.3 Plant Status Controls Operational personnel should be cognizant of the status of plant systems and equipment under their control, and should ensure that systems and equipment
- are controlled in a manner that supports safe and reliable operation.
OP.4 Operations Knowledge and Performance Operator knowledge and performance should support safe and reliable plant operation.
OP.5 Operations Procedures and Documentation Operational procedures and documents shou'd provide appropriate direction and should be' effectively used to support safe operation of the plant.
OP.6 Ooerations Facilities and Equioment Facilities and equipment should effectively support plant operation.
MAINTENANCE MA.1 Maintenance Organization and Administration Maintenance organization and administration should ensure effective imple-mentation and control of maintenance activities.
MA.2 Plant Material Condition 1
The material condition of the plant should be maintained to support safe and reliable plant operation.
M A.3 Work Control System The control of work should ensure that identified maintenance actions are properly completed in a safe, timely, and efficient manner.
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THREE MILE ISLAND (1983)
Page 3 MA.4 Conduct of Maintenance Maintenance should be conducted in a safe and efficient manner to support plant operation.
MA.5 Preventive Maintenance
. Preventive main'enance should contribute to optimum performance and rell-
, ability of plant equipment.
I MA.6 Maintenance Procedures and Documentation Maintenance procedures should provide appropriate directions for work and should be used to ensure that maintenance is performed safely and efficiently.
MA.7 Maintenance History Maintenance history should be used to support maintenance activities and optimize equipment performance.
MA.8 Maintenance Facilities and Equipment Facilities and equipment should effectively support the performance of~ main-tenance activities.
M A.9. hiaterials Management Materials management should ensure that necessary parts and material are available when needed.
TECHNICAL SUPPORT TS.1 Technical Suooort Organization and Administration Technical support organization and administration should ensure effective implementation and control of technical support.
1 TS.2 Surveillance Testing Program Surveillance inspection and testing activities should provide assurance that equipment important to safe and reliable plant operation will perform within required limits.
TS.3 Ooerations Experience Review Program Industrywide and in-house operating experiences should be evaluated and appropriate actions undertaken to improve plant safety and reliability.
THREE MILE ISLAND (1983)
Page 4 TS.4 Plant Modifications Plant modification programs should ensure proper review, control, imple-mentation, and completion of plant design changes in a safe and timely man-ner.
TS.5 Reactor Engineering i On-site reactor engineering activities should ensure optimum nuclear reactor l operation without compromising design, safety, or nuclear fuellimits. !
TS.6 Plant Performance Monitoring l
Performcnce monitoring activities should optimize plant efficiency and cell-ability.
TS.7 Technical Support Procedures and Documentation Technical support procedures and documents should provide appropriate direc-tion and should be effectively used to support safe operation of the plant.
l TRAINING AND QUALIFICATION TQ.1 : Training Organization and Administration The training organization and administration should ensure effective imple-mentation and control of training activities.
TQ.2 Non-Licensed Ooerator Training and Qualification The non-licensed operator training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job fune-tions.
TQ.3 Licensed Ooerator Training and Qualification The licensed operator training and qualification program should develop ar.d
- i. improve the knowledge and skills necessary to perform assigned job functions.
[ TQ.4 Shift Technical Advisor Training and Qualification The shift technical advisor (STA) training and qualification program should develop and improve the knowledge and skills to perform assigned job fune-tions.
TQ.5 Maintenance Personnel Training and Qualification ,
i The' maintenance personnel training and qualification program should develop and improve the knowledge and skills necessary to perform assigned job fune-tions. '
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Page 5 TQ.6 Training for the Technical Staff The training program for the technical staff should broaden overall knowledge
'of plant processes and equipment as a supplement to position-specific educa-tion and training.
- TQ.7 Training for Super isors and Managers
L The training program for supervisors and managers should broaden overall knowledge of' plant processes' and equipment and develop supervisory and
, ?managem'e nt. skills.
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TQ.8 Genera] Employee Training
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' ' The general employee training program should develop a basic understanding of employee responsibilities and safe work practices.
i ;d 9 TQ.9 Training Facilities and Equipment 3o f. , .
The training facilities, equipment, and materials should effectively support training activities.
! j RADIOLOGICAL PROTECTION l
l RP.1, , , Radiological Protection Organizat' ion and Administration _ _
i-Radiolbgical protection organizsCon and administration should ensure effec-l
/ tive implementation and control of radiological protection activities.
RP.2 Radiological Protection Personnel Training and Qualification l> The radiological protection training and qualification program should ensure i that radiological protection personnel have the knowledge and practical abili-
} ties necessary to effectively implement radiological protection practices.
[ RP.3 General Emoloyee Training In Radiological Protection i
General employee training should ensure that plant personnel, contractors, and
< visitors have, the knowledge and practical abilities necessary to effectively r
f imolement radiological protection practices associated with their work.
RP.4 External-Radiation Exposure External" radiation exposure controls should- minimize personnel radiation s -t exposure.g~ ,- ,
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Page 6 RP.5 Internal Radiation Exposure Internal radiation exposure controls should minimize internal exposures.
RP.6 Radiological Protection Instrumentation and Equipment Instrumentation and equipment used to obtain measurements of radioactivity should be calit' rated, used, and maintained so that results are accurately determined.
RP.7 Solid Radiosctive Waste Solid radioactive waste controls should minimize the volume of radioactive waste and ensure safe transportation of radioactive material.
RP.8 Personnel Dosimetry The personnel dosimetry program should ensure that radiation exposures we accurately determined and recorded.
RP.9 Radioactive Contamination Control Radioactive contamination controls should minimize the contamination of areas, equipment, and personnel.
CHEMISTRY l-CY.1 Chemistry Organization and Administration l
Chemistry organization and administration should ensure effective control and implementation of chemistry activities.
CY.2 Chemistry Personnel Training and Qualification The chemistry qualification program should ensure that chemistry personnel have the knowledge and practical abilities necessary to implement chemistry practices effectively.
CY. Chemistry Control Chemistry controls should ensure optimum chemistry conditions during all phases of plant operation.
! CY.4 Laboratory Activities Laboratory and counting room activities should ensure accurate measuring and reporting of chemistry parameters.
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THREE MILE ISLAND (1983)
Page 7 CY.5 Chemical and Laboratory Safety Work practices associated with chemistry ac'tivities should ensure the safety of personnel.
CY.6 Radioactive Effluents Radioactive effluent controls should minimize radioactivity released to the environment.
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CORPORATE ASSISTANCE VBIT TO.
OPU NUCLEAR CORPORATION 9
May 1983 l
1 9
INSTffDTE OF NUCLEAR POWER OPERA'HONS
GPU NUCLEAR CORPORATION Page1
SUMMARY
The Institute of Nuclear Power Operations (INPO) conducted a corporate assistance visit to GPU Nuclear Corporation (GPUNC) from May 17 through 20, 1983. The visit was l coincident with the INPO evaluation of Three Mile Island Unit 1 (TMI-1). ;
As a basis for the assistance visit, INPO used the September 1982 Performance Objee-tives and Criteria for Corporate Evaluations and Assistance Visits; these were applied in light of the experience of INPO's team members, INPO's observations, and good practices within the irnhky. Information was gathered from discussions, interviews, and reviews of documentation. The team reviewed GPUNC's support and monitoring of activities at both TMI-1 and Oyster Creek, making extensive use of information gathered during the TMI-1 evaluation.
INPO's goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant operation. The corporate recommendations are based on apparent plant needs and on best oractices, rather than minimum acceptable standards or require-monts. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance.-
Recommendations were made in several areas. The specific recommendations are listed in this report under the applicable performance objectives. The recommendations were presented to GPUNC management at an exit. meeting on May 20, 1983. Improving the avaGability and quality of warehouse materials and improving coordination between cocoorate and site chemistry personnel are considered among the most important recommendations.
To assist with development and improvement of the corporate evaluation program at INPO, please provide a reply to this report discussing the actions that GPUNC intends to take in response to the assistance visit. INPO also would appreciate any additional comments or observations that could assist in improving this program.
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GPU NUCLEAR CORPORATION Page 2 MANAGEMENTINVOLVEMENT AND COMMfrMENT PERFORMANCE OBJECITVE: A. Corporation managers assigned fissetional responsibGi-ties for mielear matters should have direct involvement in significant decisions that could affect their . ,- * *Hties. Management commitment to the operation of the nuensar station (s) in a safe and proper manner should be evident from personalinvolve-reent, interest, awareness, and knowledge.
Good Practies The following Good Practice was noted: The President and (1.2A-1) Board of Directors are aware of nuclear plant operational data and trends. Routine reports in an easily understood format provide corporate managers with performance information in a variety of key areas for each plant. Where applicable, long-term goals are established, and improvement measures are implemented and tracked.
O TECHNICAL SUPPORT PERPORMANCE OBJECITVR: A. The corporate wb-Mtechnical staff should be suffleient to carry out the engineering and/or - _"- dg review fimetions necessary to ensue safe and reliable nuclear plant operation.
Recommendation Improve coordination between the Technical Functions Division (2.3A-1) and the TMI site staff. This should' include providing regular feedback to the site such that plant personnel can understand the status of engineering work on problems they have identified,
.and resolving interface problems between the Engineering Service Department and the TMI Information Management Department.
MATERIALS MANAGEMENT PERFORMANCE OBJEC'tTVE: A. Corporrte sipport of materials management of the nuelaar station (s) should ensure that necessary parts and material are avaHable when needed.
Recommendation Improve the plant warehouse program to ensure the availability (2.4A-O and quality of items maintained in the warehouse. The program should ensure the following:
- a. An adequate inventory of spare parts is maintained to support Maintenance Department activities.
GPU NUCLEAR CORPORATION Page 3
- b. Storage requirements are identified and implemented for all items in the warehouse, including direct turn-over (DTO) items.
- c. A shelf-life program is implemented for all applicable items in the warehouse, including DTO items.
- d. Preventive maintenance (PM) requirements are identi-fled and performed for all applicable items in the warehouse, including DTO items.
TRAINING AND QUALIFICA'kTON FERFORMANCE OBJEC'tTVE: A. Senior corporate management attention and apport should be given to the program of developing experienced, trained, and quanffed person-nel required for the operation and apport of the utility's nuclear station (s).
Recommendation Establish qualification programs for maintenance personnel (2.5A-1) These programs should identify the experience, education, and training required for each job specification. Consideration should be given to qualifying maintenance personnel for assigned tasks instead of completing all training associated with a given position before assignment to maintenance duties. This would reduce the time required before an Individual can be used pro-ductively.
FERFORMANCE OBJECTIVE: B. The corporate manager with pr3==ia=1 responsibuity for trahdng in nuclear matters should ensure adequate sipport for and cocedination of station and off-site training activities.
Recommendation Establish corporate policies and guidance to control the overall (2.5B-1) conduct and quality of training. Training at each site is cur-rently controlled locally. This has produced some inconsisten-cies in training programs and duplication of efforts. Corporate guidance should cover general aspects of training program development, delivery, and coordination between sites.
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GPU NUCLEAR CORPORATION Page 4 RADIOLOGICAL PROTECTION PERPORMANCE OBJEC'!TYE: A. Radiological protection activities at the nuclear station (s) should be actively supported and monitored by corporate management.
Corporate policy, guidance, and assistance should be provided to the stations to improve radiological protection.
Good Practice The following Good Practice was noted: A radiological control (2.7 A-1)~ assessor at each plant is responsible for monitoring plant activi-ties to identify radiological control problems and to report such problems directly to the Vlee President, Radiological and En-vironmental Controls. The assessor not only keeps-high level management aware of plant radiological concerns, but also works directly with the radiological protection staff at the plant to correct the problems identified. Periodically, the assessor at each plant visits the other plant to observe activities and exchange experiences.
CNRMNTRY AND RADIOLOGICAL PROTECTION PERPORMANCE OBJEC'lTVE: A. Chemistry and radiological protection activities (PWR primary and secondary and BWR reactor and auxiliary systems) at the r=wlaar station (s) should be actively supported and monitored by corporate management. Corporate policy, guidanee, and assistance should be provided to stations as needed to ensure proper con-trot Itecommendation Coordinate the direction and support provided to the plant (2.8A-1) chemistry manager by the various corporate groups. Laboratory ,
Services, Chemical Engineering, and Pleid Services have respon-sibilities for direction and/or support to the plant. In some areas, these organizations and the plant staff do not appear to have common goals or are not yet in agreement as to how to achieve certain goals.
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