ML20099E932
| ML20099E932 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/25/1983 |
| From: | Long R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| NUDOCS 8411260156 | |
| Download: ML20099E932 (21) | |
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1 j CPil NtlCLEAR l Response to the Rohrer, Hibler & Replogie (RllR) Report j on " Primary Concerns of Licensed Nuclear Operators" i
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I R. L. LONG I
VP, Nuclear Assurance Division 1 -l 5/25/83 8411260156 830525 i
PDRADOCK05000g P
'l I E RIIR TARI.E CPUNC RESPONSE TO RllR ACTION STEPS (A) (R) (C) (D) (E)'
Agree -
RIIR TARI.E
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Agree - Underway Action to be Under TOTAI.
Complete or '83 Coal Scheduled Evaluation Disagree-
- 1 Safety Action Steps 10 1 1 12
- 4 Training Action Steps 1 11- 3- 15 f5 Career Action Steps 3 1 4
- 6 Cooperation Between Departments Action Steps 1 7 I 9
- 7 Pay Action Steps 1 1 1 ,
- 8 Rotating Shift Action Steps 1 1 -2 99 Quality of Management Action Steps 2 I 3
- 10 Implementation Phase Action Steps -1 1 2-TOTAL 4 35 3 7 1 -50
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( A) . Agree - Caseplete e
(B) Agree - As t les timJeewav/
- e I #1.e 8 (C) Agree - Aettwe[t's be Schied (p) twee t..t t t.
RilR REPORT
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Response Summary RIIR REPORT RESPONSE RESPONSIBILITY ACTION STEP u TABLE NO. CATECORY TIME LEAD /StfPPORT
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Procelures - Simplification of emergency operating procedures. 1 B 1983 THI-1 OC / NA TF 1
RESPONSE: THI -' Cuidance for use of 25*F subcooling margin simplifies some emergency procedures, ATOG will facilitate process of identifying correct procedure for handling a plant transient.
OC - At present, the Licensed Operators are in Training on the new symptom oriented Emergency Operatirg Procedures (EOP). These procedures simplify the existing Emergency Procedures and
<should alleviate the operator's concerns with the existing cumbersome nature of the current 500 Series Emergency procedures.
s
-1 B 1983 THI-l DC Dialogue on and analysis of procedural compliance issues in J
2 special cases.
RESPONSE: TMI - Procedural compliance requirements and prob-less regislarly discussed with licensed opera-tors; procedure owner concept, with plant operating procedures usually assigned to an ,
SRO, gives operators direct input and identi-fies specific contact person for any problems ,,
i with a particular procedure. Revisions to i 10CFR50 which become effective June 1, 1983 allow an SRO to depart from license conditions or technical specifications in an emergency; plant procedures will reflect this change and training on implications and implementa- s/25/W1 i
tions will be provided.
RilR REPORT Response Summary RilR REPORT RESPONSE RESPONSIBILITT NO. ACTION STEP TABLE NO. CATECORY TIME LEAD / SUPPORT.
2 (con't)
RESPONSE: OC - Operations Management continues to stress
! verbatim compliance with procedural control.
In line with this concept, a continuing
- dialogue with shift supervision is main-tained to identify and correct those areas where this philosophy causes problema due to unique plant conditions. Operations utilizes the 107 Procedure (Procedure Control) to make changes to procedures at the time of implementation if conditions warrant (on a one-time basis) to support our verbatim compliance requirements. Our efforts in this area have received positive feedback from the NRC in the recent SALP report on Plant Operations.
5/25/83
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RilR REPORT I
Response Summary RilR REPORT RESPONSE RESPONS181 LIT 5 NO. ACTION STEP TABLE NO. CATECORY 'TlHE LEAD / SUPPORT Improve speed of feedback on procedural change recommendations
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3 1 B 1983 THI-1 / OC made by operators. Establish policy on this.
RESPONSE: TH1 - Procedure owner concept resulting in signifi-cant improvement; further effort is underwry to streamline the required administrative and review processes.
DC - An operations staff Coal for 1983 is to Improve Procedures and Enhance Procedure Review Compliance Through a Complete Evalua-tion / Review oj[ all Operations Department i
Procedures. A program for licensed shift personnel to review and revise the 200 and 300 Series Procedures has been developed and implemented. To date, a total of-approxi-mately 80 procedures have been reviewed and j approximately 22 requests submitted for -
procedure revisions. The Operations Staff has also independently reviewed and revised specific administrative procedures (100 Series) as well as approximately 20 refueling proce-dures (205 Series). On new procedures, the Operations Staff review these procedures and encourage the writer to meet with a'GSS/ Shift personnel to. factor their input into the final draft prior to approval.
4 Improve mechanism of consultations with operations on develop- 1 8 1983 TM1-1 / OC ment of procedures.
RESPONSE: TML - Procedure owner concept improving consultation process; plant staff is working with Tech Functions to achieve timely responses to plant requests for procedural guidance, e.g., on OTSG tube ruptures.
OC . - Included in response to No. 3. ,
. RilR REPORT i Response Summary RilR REPORT RESPONSE RESPONSIBILi%
14 0 . ACTION STEP TABLE NO. CATECORY T1HE LEAD / SUPPORT 5 Improve process of review of procedures by operations prior to 1 B 1983 TMI-1 OC implementation.
RESPONSE: THI - Major procedure changes, especially emergency procedures, are checked out at'the simulator before implementation. Once approved, all shifts are trained on the procedure at the simulator.
DC - Included in response to No. 3. gt >/ ..
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i 6 Cooperation Between Departments - Especially speed of repair 1 B 1983 THI-1 OC / H&C of backup equipment.
RESPONSE: TMI - Corporate Coal 9 - discussions with exempt employees or CPUN organization, TMI-1 Goal
- 2 - discussions with plant employees, individual discussions by VP - TM1-1.
OC - Operations Management converses daily with.M&C and Plant Material on the identified needs to repair plant equipment. A concerted effort to improve the cooperation between departments is.
being practiced at the Manager level and strongly encouraged at the Supervisor level.
Included in this effort is the identification by the Plant Division of the Reduction o{
Backlog Maintenance Job Orders as the No. I priority in our Urgent Needs list.,
5/25/83
HilR REPORT j
Response Summary RilR REPORT RESPONSE RESPONSlHIL19 NO. ACTION STEP TAllt.E HO. CATEGORY TlHE LEAD /SUPPORB 7 Union and Management - At Oyster Creek. 1 C 1983 llR RESPONSE: Discussions between management and RHR are planned.
8 Operator Experience - Increase " hands on" experience; more 1 H 1983 NA / THi-1 (x[
time of trainees in plant and with equipment; more coacaing i from shift supervisors; refine efforts for keeping instruc-tors of trainees and licensed operators current on plant equipment, instrumentation and procedural changes. j RESPONSE: The availability of DC BPT plus THI DPT and Replica simulatorg will greatly expand " hands on" experience (The.0.C, replieg_ia_still-ir. our'futufe plans).
The newly established Operator Training Review Committees at THI and O.C. will have this as an 2 agenda item.
0.C. has committed to establish a formal DJT Program.
They sent operations people to San Jose for refueling training prior to the 1983 outage.
Increase attention in supervisor Development Training to coaching and counseling.
Instructors participate in Licenced Requalification Training and have required reading assignments now.
This requires further evaluation and a decision on allocation of resources to accomplish more instructor time in plant familiarization.
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Rilk REPORT Response Summary
' HilR REPORT RESPONSE RESPONSIBILITY NO. ACTION STEP TABl.E NO. CATEGORY TlHE LEAD / SUPPORT 9 Personal and Family Problems - Determine utilization rates by 1 B Early llR .
licensed operators of Stress Control Services. 1983 i
RESPONSE: Use of Stress Control Services will be reported by Bargaining Unit coverage and Salaried.
10 Disseminate information on confidentiality and on availability 1 B Early llR / THI-l OC of services through Stress Control and alternate sources. 1983 RESPONSE: Information on Stress Control and similar agencies -
will be disseminated through use of Bulletin "*-I'j Boards, News Updates and similar media. /
11 Consensus on Components of Safety - Develop consensus between 1 F 1983 'NA top management and operators on those factors contributing to safety on which there is divergence. '
RESPONSE: Table 11 was reviewed in an O/P-VP Staff Meeting on
' April 12, 1983. Differences between operation and -
top management felt to be consistent with their !'-
respective positions. !
l t'l i 12 Develop consensus within top management on those factors con- 1 li 1983 NA tributing to safety on'which there is divergence.
RESPONSE: Dr. D'Arcy requested to provide individual responses
, to management respondents for identification of any wide divergences from "mean weights" in Table 11.
5/25/83
. RilR REPORT Response Summary RilR REPORT RESPONSE RESPONSIBILITY 10 . ACTION STEP TABLE NO. CATECORY- TIME LEAD / SUPPORT 13 Requalification - Eliminate " comprehensive test" portion of 4 D 1983/1984 NA / TF requalification test. Decision by Mid-May RESPONSE: This will be an Operator Training Review Committee agenda item. By July 15th T&E Department will make its recommendation to management. (This could be effected by NRC final decision on how they will handle the 20% requalification exam audit.)
14 Make repetitive parts of requalification training more 4 B 1983/1984 NA / THL-1 OC attractive.
RESPONSE: BPT and Replica Simulators will enhance training in this regard.
0.C. is presently trying to use instructors as discussion facilitors in GET requalification training. If this proves successful, the idea could be expanded into Licensed Operator Trng.
15 Post-schedule for coming year of requalification training 4 B 1983 NA including outline of content on operator Bulleting Board '
at each facility.
RESPONSE: At 0.C. each trainee gets a training schedule for the next six months. This schedule will also be posted in the control room. During the first cycle of training, time was spent discussing the plans for the year.
TML plans to dn the same as 0.C. S/25/83 l
. KilR ltEPoltT j
Response Summary Ril!t REPOttT . RESPONSE RESPONSIB1LITY
.40.
ACTION STEP tan!,E NO. CATEGORY TIME LEAD / SUPPORT 16 Content and Methods - Include industry and community issues 4 D 1983/1984 NA / THI-l DC as well as GPU Nuclear approach to these issues in the training of operators.
RESPONSE: Senior THI managers now introduce each six-week training cycle with coimeents and respond to operator trainees.
Report says operators do not want this. Plan to further evaluate with the Operator Training Review Committee.
17 Reintroduction of " systems approach" for Navy trainees to 4 B 1983/1984 NA understand role of equipment in plant.
RESPONSE: Current CR0 programs on shift time have been expanded.
Also, plan to incorporate ex-Navy trainees into systems portion of non-licenced operator training.
THI has separate system training module for ex-Navy trainees.
18 Develop diversified approach for mastery of theory for ex-Navy 4 B 1983/1984 NA Nukes and trainess coming up from plant.
RESPONSE: The BPT simulators will aid in this area. The. theory instruction to non-licensed operators has been increased.
THI also permitted ex-Navy trainees for R0 Licenses to take validation exams (" test out") in theory area.
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5/25/83
Rillt REPOltT
- Response Summary i
RilR REPOl(T RESPONSE RESPONSIBILITY No. ACTION STEP TAltLE NO. CATEcoltY TlHE LEAD / SUPPORT 19 Simulator specific to THl. 4 B 1982-1987 TF / NA RESPONSE: Placement of order expected during June. 1983. . ._Th i s
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also requires (couunitmEnt for additional staff to \'
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support Replica Simulator.
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20 Develop method for trainee to gauge his growth in competency 4 15 1983/1984 NA to operate during training period.
RESPCNSE: -The BPT simulators will aid in this area. Doing more plant walkarounds at 0.C. to obtain trainee feedback. At 0.C. new CRO class on-shift time '
increased from 13 to 20 weeks. ,
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The training programs require qualification check-offs from which the trainee should be able to judge his own growth and accomplishment.
21 Standards - Tighten standards and evaluation of trainees. 4 B Early NA / THI-1 OC 1984 RESPONSE: The qualification check offs will be used to establish performance standards for trainees.
4 The Licensed Operator Certification procedure at
- each plant plus the Control of Exain procedure also addresses this area.
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RilR REPORT Response Summary-
-l RilR HEPORT RESPONSE RESPONSI B11.ITV '
rio. ACTION STEP TAHLE NO. CATEGORY TIME LEAD / SUPPORT 22 Evaluate instructors on pedagogic skills with view to coaching 4 B Mid 1983 -NA and improving.
RESPONSE: This is being done through the instructor evaluation program and the Instructor Training Program. >
23 Develop method for montitoring and improving consistency between 4 n 1983-on NA training for licensing and requalification and testing for the same.
RESPONSE: The Operator Training Review Committees will be addressing this issue.
A T&E has contributed to improvements in the NRC test by providing them questions for their test bank.
24 Develop method for monitoring and improving consistency between 4 ,A 1983-on. NA / TH1-1 OC training and ability to operate.
RESPONSE: T&E regularly seeks feedback from operations (and other user groups) on their training needs.
25 Task analyses of what operators actually do as basis for 4 8 1983/1984 NA / TM1-1 OC' training relevance.
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RESPONSE: T&E subscribes to the task analysis approach. This issue is under study to determine wh't procedure is most meaningful for our situation.
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! . AllR REPORT Response Summary l
f HRHR REPORT RESPONSE RESPONSIBILITY.
N00 ACTION STEP TABLE NO. CATECORY TIME LEAD / SUPPORT 26 Administration - Promote improved relationships between opera- 4 B Hid-1983 NA / THI-l DC tions and training personnel.
RESPONSE: Each site will have an Operator Training Review Committee to look at program issues. The T&E Department has a goal to establish a Training Advisory Committee which may also address this area.
27 Turgeted interviews in Training Department to explore issues, 4 D 1983 IIR and other departments.
RESPONSE: T&E will have further discussion with RilR to determine further action.
28 Entry - Improve pay dif ferential between licensed operators 5 D 1983-on llR and other departments.
RESPONSE: Wage and license bonus amounts are established through the bargaining agreement.
29 Provide some training in theory to AO's with potential for RO. 5 B 1983 NA RESPONSE: T&E has increased the theory training to non-Licensed a
operators.
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! RilR REPORT Response Summary i
1 RilR REPORT RESPONSE RESPONSIBILITY NO. ACTION STEP TABLE NO. CATEGOP.Y TIME LEAD / SUPPORT-f 4
i j 30 College credentials - Fecilitate getting of degrees; credits 5 B 1983/1984 NA / IIR for in-house courses, ;>cograms in area colleges, Career Counsel.
RESPONSE: T&E and lluman Resources are jointly developing
' educational career counseling programs (Ilit Goal 6.A).
Effort underway to bring degree programs from local colleges / universities to CPUN sites. By the end of 1983, appropriate site training programs will be evaluated for granting of college credit.
31 Career Paths - Develop and publish possible career paths and 5 B 1983/1984 IIR / NA qualifications for them.
RESPONSE: Additional career path opportunities can be made available to employees provided sufficient flexi-bility can be worked into shift schedules. A draft progression was sent to applicable Vice Presidents on April 18, 1983.
32 Emphasis on Cooperation - Discussion of issues with department 6 A Early 1983 NA:
heads.
RESPONSE: Entire RilR report reviewed with O/P and Division VPs in meetings on March 22 and April 12 anal 14, 1983. Several Divisions are planning followup meetings with RilR.
5/25/83
- RilR REPORT Response Summary RilR REPORT RESPONSE RESPONSI BI L ITY '
NO. ACTION STEP TABLE NO. CATECORY TI!!E LEAD /SUPP]RT 33 Reinforce concept of organizational structure that operations 6 B 1983 NA / OP is a key function and other departments have support function.
9 RESPONSE: lucluded in effort described under No. 34.
i 34 Hake cooperation between departments a CPU Nuclear Corporation 6 B 1983 NA/ OP Objective.
RESPONSE: Corporate Objective No. 5 is to "... Improve CPU
- Nuclear's functional capabilities." All Divisions j are emphasizing " concept" through staff and employee i meetings, interdivisional meetings, and when needed, j development of interface agreement and procedures.
35 Develop system for evaluating managers on cooperation. 6 A 1983 IIR
! RESPONSE: This is included in the Performance Appraisal form implemented in 1983. Section 3 under Performance j Factors is as follows:
i "3. Working Relationships" F. Communication C. Leadership II . Teamwork
- 1. Employee Development" Further, the Performance Factors - Rating Definitions defines TEAMWORK as " contributing to and cooperation with others in a common effort." In each evaluation,.
this factor is to be reviewed by immediate supervision and those sections of departments which supervisors interface. 5/25/83
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RilR REPORT Response Summary ItllR ltEPORT ltESPONSE RESPONSI till.lTY NO. ACTION STEP TABLE NO. CATECORY TIME LEAD / SUPPORT 36 Facilitating Cooperation - Identification of problems at inter- 6 15 Spring NA / Al.L f aces between 1983 s pairs of departments.- Intergroup problem solving meetings.
RESPONSE: Included in effort described under No. 34.
e 37 Educate departments on each others' roles. 6 B Early NA / ALL 1983 RESPONSE: The following steps are being considere_d,to promote greater cooperation:
(a) Developfsynop,sisj'ofOrganizationPlanfordistri- l '/
bution to all on site. (The Organization Plan is
- on file in the Control Room.) J- ,
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(b) Discuss organization and divisional functions in all training programs including CR0 training.
Training Department to schedule designated v representatives from each Division to discuss divisional roles.
(c) Reinforce through " Nuclear Today" publication y "Did You Know".
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t RilR REPORT Response Summary RilR REPORT RESPONSE RESPONSIBII.ITY.
I NO. ACTION STEP TABLE NO. CATEGORY TIME LEAD / SUPPORT.
38 Training: Supervisors for cooperation, operators in persua- 6 C Early 'NA / ALL sion vs. authoritarian approach, support department members 1983 fresh from school in importance of cooperation.
1 HESPONSE: New Supervisor Training Program will address this topic by 4th Quarter 1983.
Future Manager, Development Program will also address this topic as will the proposed Senior Level Management Training Program.
39 Get people acquainted across departments. Post photographs of 6 In Early NA IIR / Al.L j- both licensed operators and support department foremen and 1983 supervisors at each facility with name and function, circulate
! current rosters of department foremen with areas of responsi-bility location and phone.
. RESPONSE: Dyster Creek and TMI will circulate current rosters ' ,
i of department foremen with areas of responsibility, j location and phone. (Except photc raphs-will not be posted.)
5/25/83
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, RilR REPORT Response Summary EllR REPORT RESPONSE RESPONSIBILITY
- 30. AC1' ION STEP TABLE NO. CATECORY TIME LEAD / SUPPORT l 40 Work toward sufficient flow of trainees so that those with 6 B ~1983 THi-1 OC / IIR NA l
i operational experience can join support departments.
! RESPONSE: Current Status:
l THI-I THI-2 0.C.
- CRO's 4/ shift 3-4/ shift 4/ shift
{ # Aux Ops 6-9/ shift 7+/ shift 84/ shift i
(6 shifts) (5 shifts) (5 shifts)
OC: This has always been a goal of Operations to i provide a career path and options for operators to pursue other areas where their experience and j knowledge can benefit the Corporation. With achievennent of the six (6) shift goal, we can, focus on moving operators into other areas of the
- Corporation. In the interim, Operations continues
!, to recruit and provide yearly classes of trainees l,
consistent with budget allotment.
4 THI: This is well underway and is included in the plan-ning for critical skills section of the five year
- . plan. The plant now has 19 licensed Ros with 3 in *. raining; a licensed RO was just recently.
ll tri.isferred to QA/QC as a beginning of the program jl 4 '
to provide operators the opportunity to move into the support division.
41 Pay Differentials - Develop data on pay differentials between 7 .n- 1983 liR 1
licensed operators and other disciplines at CPU Nuclear.
RESPONSE: Per discussions with the 0/P on April 16, 1983, this concern may be directed to the CSS or COS levels of salary compared to other exempt positions at 0.C.
Human Resources will study such and respond to the applicable officer level positions. -
JS/25/83
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RilR REPORT Response Suramary HilR HEPORT HESPONSE HESPONSI Bil.ITj No. ACTION STEP Tant.E NO. CATEGORY TIME LEAD / SUPPORT.
42 Develop data on pay differentials in Nuclear Plants run by 7 A 1983 IIR other utilities.
HESPONSE: Surveys are conducted continually during the year. Most recent survey is as of 3/21/83.
Attachments on CR0 hourly rates vs. internal technical positions and as compared to other utilities distributed to applicable officer leve1 positions on April 18, 1983.
43 Use data to reassess policies and plan appropriate action 7 0 1983/1984 lik steps.
RESPONSE: Inasmuch as CPUNC wage and license bonus amounts are subject to the local bargaining agreements,
, differentials can only be adjusted through
- negotiations.
i i 44 Work to initiate 6 shifts at Oyster Creek as soon as 8 n 1983/1984 IIR / OC possible.
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RESPONSE: At the time of the study, O.C. was on a 4 shift rotating schedule; it has since been increased to 5 shifts (February 1983).
Operations and T&E are striving to have i sufficient licenses for 6 shif t operations by the end of the 1983 outage.
5/25/83
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- 4 RilR REPORT Response Summary RilR REPORT HESPONSE RESPONSl Hil.lT(
NO. ACTION STEP TABLE NO. .CATECORY TIME LEAD / SUPPORT 45 Shift Scheduling - Study feasibility of each rotation being 8 D 1983 IIR '/ OC connistently eight hours later than previous at 0.C. Study feasibility of twelve hour shifts.
RESPONSE: This matter needs extensive review and study between Nuclear Assurance and lluman Resources, applicable.
divisional management and operating company labor relations representation. While other options may be available, we reject the concept of 12-hour shifts, i.e., difficult to schedule, fatigue s -
factor, reducing altertness and productivity and f.,
necessity of IBEW negotiations.
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46 Provide advance warning of changes in shift scheduling. 9 B 1983-on THI-l OC
RESPONSE
THL: Advance warning of changes in shift scheduling
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should and will be provided whenever'possible.
OC: Operations Management commits to providing as much advance warning.of shift scheduling changes
, as is possible. ~ Additionally, Operations has
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submitted apisposed schedule change (operators!
, input) to Human Resources for Union concurrence .
l This proposed shif t schedule is one preferred !
' by the operators and implementation will be l indicative to Management's desire to respond I to their con.cerne. _ __,
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S/25/83
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RilR ItEPoltT Response Summary HilR ltEPORT HESPONSE RESPONSIhlLITY-No. ACTION STEP TAllLE NO. CATECORY. TIME 'I.EAD/ SUPPORT 47 Interviews with cross-section of management on issues, concerns 9 D 1983~ NA and quality of management.
RESPONSE: Director, Training & Education and VP - Nuclear ')
Assurance are reiewing the programs available to evaluate and assess individual management styles and practices.
48 Assessment of managers; developmental coaching with individual 9 B 1983-on NA managers; Management training.
i KESPONSE: Will revise prsent Management Development Program to target behavioral objectives to managerial skill development. Iluman Resources and Training &
Education are working together to guide effective assessment of manager performance.
l 49 Presentation of findings to Departments (so that Departments 10 A Early NA /~ALL understand background of Action Steps). 1983 I
RESPONSE: RHR Report has been distributed to appropriate j management personnel in each Division. (Also ree response to No. 32.)
I l 50 Review of suggested Action Steps to determine feasibility, 10 C Early NA / ALL timing, and participants. 1983 RESPONSE: This Response Summary will be reviewed with RilR.
A plan will be developed by July 1, 1983 for i follow-up and feedback to operators.
5/25/83'