ML20087P077

Forwards Hd Hukill 840330 ltr,840229 Notice of Violation, Licensee 840402 Revised Response & Gpu & Status Rept Re Licensed Operator Experience.Related Correspondence

ML20087P077
Person / Time
Site:	Crane
Issue date:	04/04/1984
From:	Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Buck J, Edles G, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
NUDOCS 8404060018
Download: ML20087P077 (101)

Text

M (O RaATED CORRESrwuclQ

)

SHAW, PITTMAN, PoTTs & TROWBRIDGE A PARTNresMin or enortssioNAL componATioNs CCD

._O j,

'A 1800 M STREET, N. W.

WASHINGTON, O. C. 20036 maMsat o..oTTs. pc JoMN ENGEL. p c.

oE.o

.. caessE m MamTMa.ooNE nowaN' w.E mg e

." =

w::,r,=:"at

ara =e:e Si?.rfJat" "*""' l g===t/Mr

'a"t U.",P;'t.,,

?' fit:&"ch"2mt

• ! "M A"A,"#,"otf,"fc'

"'=co '<"

.1 ""a:Pr*

r m ren* owe'.

c":1,.".*:n'J.~5

m=== a u sza a.

TM

%f"l'i TT"tas? ""4 "8: = Jd;t!" # c.

I'm "??"J.*4:7.

I,"tJa;

"."A*c". ETA.

Fasah'a'?"Jii,W,Fie.

!!YJETM*' ^i ".JO*JI in'*i"E" " ' '"tA""

t%"EE"."E'"J ', ^*.t'"A" "

227J"..".bs!0!+',2:.c a* ir*E ioo "Wu E23!".';.""fa"ItsN htt'o",l2 f&&"" "'

"'c7c!I-l".^2,,a ;^& "'

womi.22..on

"'c*^"a".E"!!. 't' "'

"?;'M#.",l',t'5"e "'

27c'.!&'s'f.'J4,.o'

'kn'."?'s*f?%"".*'c'""

T

"'"l'a^v"a"fE," ".'Tc' "I Z 'M"I 17.L' " " '

Ettla^ C'"Ja'h.

L*""s"#'s?f"'"

TELEE N SMg's r$

ffN wE.STE R p C.

E SA. TM'M DLETON

.9 2693 (SMAWLAW WSM)

TMo a CM L

"'!."'E5'E."*//% t" "'

"'""If,ft^?ca',;5?c'L' cA.LE.

..LA.-

E'#uiE'L","E"t!'

""J',",I'2"!r$3'" -

offoe, so.ES pC.

AYL SM MoNTANGE JU0iTM A S N LE WDo Trains cA 1"S"it'.Ofe!NE "8l'. "c 2'kh *^'

so

r. oEALT-IR**"% %3?""? "'

= "???J a' =s'"'"

i".hT! "Jc'i#'4

""n".tJ'*JS'!;oM

...coTT cu.TE. s=

"Lc*J."?t!&" E., s.

= 'J".T.' Y/,,"J.',.c "

o o

TEV NL LTZE 8 P C.

NN E S Go LE.

COute SE L PETE'R J A?.ECRER FER ARA C

RO M OEa.N O. AuLeCn. P C.

MoWARD M. SMAFFE RM AN HELEN ToRELLI

• st.E RT WA5MeteGToh H

• eOT ADeestigo sm O C

...n..

..E c7

..L uM.E.,

April 4, 1984 822-1215 Administrative Judge Administrative Judge Gary J. Edles, Chairman John H. Buck Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Chfistine N. Kohl Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 C

i In the Matter of Metropolitan Edison Company

/

(Three Mile Island Nuclear Station, Unit No. 1)

Docket No. 50-289

Dear Chairman Edles and Administrative Judges Buck and Kohl:

In accordance with our practice of notifying the Appeal Board and the parties of changed circumstances or new information on issues under consideration, Licensee hereby provides the following information.

In a March 30, 1984 letter from Mr. H. D. Hukill, Director, 3

TMI-1, to Mr. R. C. DeYoang, Director, Office of Inspection and

-~

Enforcement, Licensee provided.its response to a February 29, 1984 Notice of Violation and Proposed Civil Penalty.

By letter dated April 2, 1984, Licensee submitted to the Staff a revised page two to Licensee's March 30 response, which corrected speci-fied clerical errors in the March 30 submittal.

Enclosed is a

]b 8404060010 840404 PDR ADOCK 05000289 O

PDR

(

r

e i

i

- SHAW, PITTMAN, PoTTs & TROWIIRIDGE A PARTNERSHIP Or PROFEte40NAL CORPORATIONS Administrative Judge Gary J. Edles Administrative Judge John H. Buck Administrative Judge Christine N. Kohl April 4, 1984 Page Two copy of the March 30 letter (with attachment), the February 29 Notice of Violation and the April 2 letter (with attachment).

In-the enclosed March 30, 1984 letter (with attachments) from Mr. H. D. Hukill, Director, TMI-1, to Mr. Thomas E. Murley, Region I Regional Administrator, Licensee provided to the NRC Staff a summary of the current operating experience of TMI-1 licensed operators.

It reflects in summary form updated infor-mation on TMI-l operating personnel and their experience since the close of the management record.

Also enclosed is a' March 28, 1984 letter from Mr. P. R.

Clark, President, GPU Nuclear to Mr. E. P. Wilkinson, Presidenty' Institute of Nuclear Operations (INPO), along with the status report which the March 28 letter forwards.

This report provides the status of actions taken by Licensee in response to the May 1983 INPO evaluation of.TMI-1, a draft of which was provided to the Appeal Board and the parties by Licensee's counsel on June 20, 1983, followed by provision of the final report on September 7, 1983.

Respectfully submitted, OM 0. $r 46 Deborah B.

Bauser r

Counsel for Licensee i

DBB:jah r

[

Enclosures cc:

Service List attached e

.e n.-

e

-ru-

.s.

t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4

Before the Commission In the Matter of

)

)

METROPOLITAN EDISCN COMPANY

)

Docket No. 50-289

~

)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

SERVICE LIST N

Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Comission John H.

Buck Washington, D.C.

20555 Atomic Safety & Licensing Appeal Board Victor Gilinsky, Conunissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Thomas M.

Roberts, Commissioner Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.

20555 Board U.S. Nuclear Regulatory Commission

,, l James K. Asselstine, Commissioner Washington, D.C.

20555 ii U.S. Nuclear Regulatory Comunission Washington, D.C.

20555 Administrative Judge f

Ivan W.

Smith, Chairman Frederick Bernthal, commissioner Atomic Safety & Licensing Board

/

U.S. Nuclear Regulatory Connaission U.S. Nuclear Regulatory Commiss n

Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe t

t Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commission l

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 T-f Washington, D.C.

20555 I

I n

Administrative Judge Mr. Henry D. Mukill Gustavo A. Linenberger, Jr.

Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear segulatory Commission 7.0. Box 480 Washingt6n, D.C.

2055$

Middletown, PA 17057 Docketing and Service section (3)

Mr. and Mrs. Norman Aamodt office of the Secretary R.D. 5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C.

20555 Ms. Louise Bradford Atomic Safety & Licensing Board TME ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Barrisburg, PA 17102 Washington, D.C.

20555 Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Christic Institute Soard Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.

20002 Washington, D.C.

20555 Ms. Gail Phelps Jack R. Goldberg, Esq. (4)

ANGRE/TME PIRC

~

office of the Executive Legal 1037 Maclay Street N

Director Barrisburg, PA 17103 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan Maxine Woelfling, Esquire 2001 S Street, N.W.,

Suite 430 Assistant Counsel Washington',

D.C.

20009 Department of Environmental Resources Michael F. McBride, Esq.

514 Executive Ecuse Letoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W Iarrisburg, PA 17120 Suite 1100 Washington, D.C.

20036 John A. Levin, Esq.

Assistant Counsel Michael W. Maupin, Esq.

Pennsylvania Public Utility Hunton & Williams Commission 707 East Main Street i

P.O. Rex 3:45 P.O. Box 1535 Harrisburg, PA 17120 Richmond, VA 23212 David E. Cole, Esq.

Smith & Smith, P.C.

2931 Front Street Barrisburg, PA 17110 i

o.

l l

l L

a

7-sl GPU Nuclear Corporation IW 1 Muclear

=,omeg48o s

Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

5211-84-2081 March 30, 1984 Mr. R. C. DeYoung Director, Office of Inspector and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. DeYoung:

Three Mile Island Nuclear Station, Unit I (TMI-1)

' Operating License No. DPR-50 Dod<et No. 50-289 Response to Notice of Violation and Proposed Civil Penalty, Regarding Inspections 83-25 and 83-26 and Enforcement Conference 83-33.

Attached are the responses to the individual violations that were requested by your February 29, 1983 Notice of Violation and Proposed Civil Penalty. Based on our review of these violations we do not believe a civil penalty is warranted or required.

We agree that errors did occur.

We are concerned that they occurred.

However, With two exceptions, these errors were discovered oy GPUN and in all instances appropriate corrective action was promptly taken without NRC urging. While the number of errors that occurred is larger than we desire, they were not individually significant. tereover, they occurred over a two-month period during which several non-routine, complex operations were accomplished, and should be judged in the light of the many challenging l

operations that were perfTmed correctly.

The individual human errors that did occur were dealt witn using our progressive disciplinary program.

We believe this program coinbined with rewards for good performance and the corrective actions taken for the specific events will continue to reduce the j

number of errors.

There have been two developments since the proposed fine was issued which we believe warrant yot.'r attention in assessing this response. First, a revised l

General-Statement of Policy and Procedure for Enforcement Actions was l

promulgated by the Commission on March 8,1984. Although it was not effective when the fine was proposed, it clearly is now. The second.is that you and Dr.

Murley have conducted personal interviews of TMI-1 site personnel.

1 l

l GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation w

'2.

~

We have reviewed the Notice of Violation against the revised enforcement action policy statement.

The revised' statement explicity allows aggregation of violations for the assignment of a severity level as has been done in this instance. However, irt providing the flexibility to aggregata certain violations,-the Commission had in mind focusing attention gn an " underlying.

problem or programmatic deficiencies when appropriate." 4! Fed. Reg. 8584 (1984)'

We do not believe that test is met here and thus e.ucstion whether aggregation in this instance is appropriate. In fact, we sgree with the

= statement in Mr. Staroste&i's Decenber 23,1983' letter thrt "thase problems are considered to be isolated cases and not~ indicative of I,orcqrammatic problem". Further, review of the items in the Notice of Vicitalon, taken individually or even collectively, do not rise to the shrih ut problems enumerated as illustrative of Category III severity iterr in the revised statement -- viewed either as operational matters (Supplement I) or as health pyhsics-concerns (Supplement IV). Thus, we question the appropriateness of categorizing our violation as Category III at all. Finally, viewed even as a

- Category III violation, we note that the Commission has chaliged its' policy with regard to this category from "usually imposing fines to simply considering" fines. Surely, when compared with the illustrative examples within the range of Category III severity, the items noted in our proposed violation notice cannot be viewed as severe.

The second development since the civil penalty was proposed is-your's and Dr.

Murley's visit to TMI-l on March 5,1984. During the visit you met individually with management, supervisory personnel, and first level

' employees. We 'can understand that prior to this visit you may have believed that 'it was necessary to invoke a civil penalty to promote ~ proper attention

.and reaction within the TMI-l organization as a whole.

Based on our prompt and comprehensive. corrective actions, which from the enforcement conference and your inspection at the site we understand you accept, and based on the positive attitudes which you observed during your visit, we believe that a

~

civil penalty is unnecessary to further NRC's enforcement objectives.

Other positive indications of this organization's approach are:

1.

Unannounced Off-Shift Tours by Management.

2.

On-Shift QA mnitors.

3.

Site Managers meetings periodically where problems such as these violations and other significant matters are discussed for general understanding and multidisciplinary feetack.

4.

The Establishment of the Nuclear Safety and Compliance Committee..

5.-

Frequent discussions between management and the operators.

3 '

~

6.

Discussions between the shift workers and the Unit Vice President (2 conducted in 1983).:

' 7.

Plant 'E' vent Reports and followup discussions for'a complete and broad understanding (including those which are not reportable).

8.

The existence and enforcement of a Conduct of Operations Procedure.

9.

The Annual QA Effectiveness Review.

These efforts ars

..u representative of an organization which must be penalized to take effective action. We believe that a civil penalty in this case would serve no legitimate regulatory purpose;and is unnecessary to improve professionalism in all areas of our operation.

We believe that a civil penalty in this regard would be punitive in nature rather than encouraging good performance.

Based on the above we request that the proposed $40,000 civil penalty be rescirded in its entirety.

In the event, however, that after assessing this response and taking into account particularly the revised Statement of Policy and the results of your judgement of our corrective actions and your discussions with personnel at TMI-l you still believe that the civil penalty is warranted, we will promptly provide payment.

8 Sincerely, s

D.

kill, Director, TMI-l HDH:mle Attachments cc:

Dr. Thomas E. Murley R. Conte Sworn and subscribed to before me this _ % ay of d

%.e

, 1984.

www4a u/

Notarf Public DAALA JEAh BfRit.'NOTAD PU8 tlc liiDOLET0 nit 30ic. L40FHl4 COUNTY MY C0mMliSl3N [XPIRI! JUNE 17.1985 Member. Pennsylvania Asw.at...n cf Noranes c.,

/

j Violations Related to 'ontainment Inteority C

Violations la and lb 1.

Technical Specification 3.6.1 requires that containment integrity be maintained when reactor coolant (RC) pressure is 300 psig or greater, RC temperature is 200oF or greater, and nuclear fuel is in the core.

Technical Specification 1.7 defines containment integrity and specifies as one of its' conditions that all nonautomatic containment isolation

~^

valves are closed as required by the " Containment Integrity Checklist" attached to the operating procedure " Containment Integrity and Access Limits."

s Operating Procedure (OP) 1101-3 Revision 27, August 18, 1983, (Temporary Change Notice No. 1-83-0158, dated August 24, 1983) Containment Integrity and Access Limits, Enclosure 1, Reactor Building (Containment)

Integrity Checklist, requires for containment integrity, in part, that nonautomatic containment isolation valve IA-V20, Instrument Air Isolation Valve, be closed (paragraph 18.2) and nonautomatic containment isolation valve FS-V405, Fire Service Test Connection / Drain Isolation Valve, be closed and capped (paragraph 17.1).

Contrary to the above, with RC pressure greater than 300 psig, with RC temperature greater than 200'F, and with nuclear fuel in the core:

a.

Nonautomatic containment isolation valve IA-V20 was not closed between August 27, 1983 and Septerrber 20, 1983; and, b.-

Nonautomatic c6ntainment isolation valve FS-V405 was neither closed nor capped between August 27, 1983 and September 16, 1983.

Response to' Violation la r

l (1)

Admission or Denial-l

~

This violation was identified by GPUN and reported as LER 83-28 on September 20, 1983.

(2)

Reason for Vidlation This violation was personnel related in that the operators who checked IA-V20 closed on 8/18/83 and 9/15/83 did not recognize that the valve l

stem bushing nut was backed out and therefore the valve was not closed.

In addition, the engineer inspecting containment on 8/31/83 recognized that the valve stem bushing nut was improper but did not realize that

.the valve was not closed.

As a result a job ticket to correct this problem was not prepared until 9/6/83 and was not elevated to l

Management's attention until 9/20/83.

o i

0987K

Contributing factors were that the valve stem was not so significantly

~

out of position that the valve's position could unamoigously be determined.

In fact four supervisors were consulted and could not conclusively establish t.he valve's position until leakage testing and valve disassembly was accomplished at the direction of the Operations &

Maintenance Director.

(3)

Corrective Action Taken As discussed in LER 83-28 IA-V20 was repaire',: closed, and tested.

d (4)

Steps Taken to Prevent Recurrence As discussed in LER 83-28 the irrportance of timely followup on Containment isolation related items has been emphasized.

The Containment Integrity Checklist (OP 1101-3) has been changed to include checking for valve damage or obstructions which may prevent full closure. Other manual containment valves are being inspected to confirm that the stem bushings are adequately retained.

(5)

Date of Full Compliance Full compliance has been achieved and steps to prevent recurrence will be completed by May 1, 1984.

Response to Violation lb (1)

Admission or Denial This violation' was identified by GoUN during a reverification of containment integrity that was being conducted at GPUN's initiative and was reported as LER 83-25 on September 16, 1983.

(2)

Reason for Violation The reason for this violation was personnel error in that the operator did not properly reclose FS-V405 and install'its cap subsequent to performing local leakrate testing.

(3)

Corrective Action Taken FS-V405 was closed and capped to correct this violation.

The remainder of the containment re-verification did not identify any further problems.

(4)

Steps Taken to Prevent Recurrence

~

A complete review of this event was conducted and as a result disciplinary action was taken with the operators involved.

In addition, the event was discussed with all Operations personnel to emphasize the l

cause and consequences of the event. A management verification of the l-containment integrity checklist will be conducted after containment L

integrity is set for the next heatup.

l l

[

. (5)

Date of Full Compliance

~

Full compliance was achieved on 9/15/83 when FS-V405 was closed and capped. Steps to prevent recurrence will be completed the next time containment integrity is set.

General Discussion of Violations 1.a and 1.b The fact that-these violations were identified by GPUN is to GPUN's credit.

' 'The containment inspectinn was very thorough and Management's followup to -

potential problems once identified was aggressive and appropriate. We would have preferred a more timely follow up to the problem identified for IA-V20 by the engineer performing the inspection (he has been counselled in this regard).

However, once identified to Management the status of IA-V20 was quickly determined, resolved, and actions to prevent recurrence were taken.

Based on this, these events were discovered and corrected as a result of the efforts of a Management striving for excellence.

Violations Related to Procedural Imolementation Violation 2a 2.

Technical Specification 6.8.1 requires, in part, that written procedures important to safety shall be established, implemented, and maintained.

Contrary to the above, on four occasions, written procedures important to safety were not properly implemented, as evidenced by the following:

a.

Operating Procedure (OP) 1104-43, Revision 19, February 11, 1983, Nuclear Plant Sampling, paragraph 3.2.2.12.c and Enclosure 1, require, in part, that the Makeup Tank Liquid Sample Flush Valve, (CA-V95), be closed after a makeup tank liquid sample is collected.

However, between August 20 and 29, 1983, CA-V95 was opcn with no makeup tank liquid sample being collected.

Response to Violation 2a (1)

Admission or Denial l

This violation is admitted and was identified by GPUN in the process of l

determining why an unplanned release of Kr-85 tracer gas had occurred on August 29, 1983.

(2)

Reason for Violation l

This violation was caused by failure of the chemistry technician to properly follow the procedure and close CA-V95 as required following t

completion of sampling.

l l

0987K

i

_4-(3)

Corrective Action Taken

~

A plant incident report was prepared, CA-V95 was closed, and a complete valve line-up of the nuclear sample room was conducted. All chemistry technicians were counselled concerning this event.

(4)

Steps Ta'<en to Prevent Recurrence Disciplinary measures taken for non adherence to procedures associated

-with other events and the resultant internal publicity should prevent-recurrence.

(5)

Date of Full Compliance Full compliance was achieved on August 29, 1983 when CA-V95 was closed.

Violation 2b b.

Operating Procedure 1104-43, Revision 19, dated February 11, 1983, Nuclear Plant Sampling, paragraph 3.2.2.15.g and Enclosure 1, require, in part, that Makeup Tank Gas Sample Return Isolation Valve (CA-V47) and Makeup Tank Gas Sample Bomo Bypass Valve, (CA-V48) be closed after a

' makeup tank gas space sa@le is collected.

However, on August 27, 1983, Valves CA-V47 and CA-V48 were open with no makeup tank gas space samle being collected.

Response to Violation 2b (1)

Admission or Dienial This violation is admitted and was identified by GPUN while attempting to establish a hydrogen overpressure on the Makeup Tank.

The event was reported as LER 83-022.due to exceeding the Technical Specification hydrogen limits for the Waste Gas Holdup System (TS 3.22.2.5).

(2)

Reason for Violation This violation occurred due to personnel error in that the chemistry technician did not restore the proper valve lineup following sampling of the Makeup Tank.

(3)-

Corrective Action Taken CA-V47 and 48 were closed and the chemistry technician was counselled under our progressive discipline program.

(4)

Steps Taken to Prevent Recurrence l-A plant incident report was prepared and was discussed with Chemistry l

Department Personnel.

I L

0987K

(5)

Date of Full Compliance

~

Full compliance was achieved on August 28, 1983 when CA-V47 & 48 were j

closed.

Violatinn 2c c.

Emergency Plan Implementing Procedure (EPIP) 3004.15, Temporary Change Notice No. 1-83-0201, dated September 30, 1983, Post Accident In-Plant Sampling, paragraph.5tl.7 and Attachment 4, require' that' Reactor Coolant Letdown Sample Valve (CA-V16) be closed prior to implementing'the procedure for obtaining a Reactor Coolant System (RCS) sample.

However, on September 30, 1983, the procedure for obtaining an RCS sanple was implemented, but valve CA-V16 was not closed.

Response to Violation 2c (1)

Admission or Denial This violation is admitted and was identified by GPUN during the process of determining why a " demonstration" post accident RCS sample could not be drawn.-

(2)

~ Reason for Violation This event occurred as a result of two evolutions being conducted 3 simultaneously using the same equipment. Both evolutions werd being conducted using approved procedures but without awareness that the other was in progress and without proper coordination.

The first evolution was a demonstration post accident sample for NRC observers.

The required valve' lineup was completed and the technician.

went-to~get the tRC observers.

During the technician's absence a second technician entered the lab and performed the valve lineup for a normal RCS sample. -The normal RCS sample was-interrupted by plant testing which caused CA-V13 to close.

The technician left the sample room until the testing was completed and normal sampling could resume. In the meantime, the first technician returned with the NRC observers and continued:with the-post accident sample demonstration but was unable to establish sample flow due to CA-V16 being opened for a normal RCS sample.

(3)

Corrective Action Taken CA-V16 was closed and the post accident sample demonstration was completed.

09.87K

(4)

Steps Taken to1 Prevent Recurrence

~

A plant incident report was prepared and discussed with Chemistry Department supervisors and technicians.

It was emphasized to the Foremen that their primary responsibility is coordination of activities and control of the technicians and activities.

(5)

Date of Full Compliance

' Full compliance wks achieved on Sept. 30, 1983 when CA-V16 was closed.

Violation 2d d.

Administrative Procedure (AP) 1002, Revision 27, dated August 1,1983, Rules for the Protection of Employees Working on Electrical and Mechanical Apparatus, paragraph D.1.1 and Enclosure 1, requires, in part, that for apparatus to be taken out of service, an application form operations personnel must be completed to assure technical specification operability requirements are met.

However, on August 23, 1983, the Condenser Off Gas System Radiation Effluent Monitor, RM-A5, a monitor required by the technical specifications to be operable, was taken out of service for approximately 30 - 40 minutes by closing the sample pump inlet isolation valve VA-V17 without the required application from operations personnel being completed.

Response to Violation 2d (1)

Admission or D'enial This violation is admitted and was identified by GPUN and reported as LER 83-019.

(2)

Reason for Violation This violation was a result of personnel error.

Technicians trouble shooting for a vacuum leak in newly installed monitoring equipment shut VA-V17 without realizing that shutting this valve also isolated the condenser offgas monitor (RM-A5) which was required to be operable with a condenser vacuum established.

(3)

Corrective Action Taken Valve VA-V17 was opened reestablishing flow to RM-A5 within 40 minutes of its initial closure.

09,87K

g.,

?

.7 -.

(4)

Steps Taken to Prevent Recurrence'

~

I&C and Startup & Test personnel were instructed to coordinate their testing and trouble' shooting activities with the Shift Supervisor / Foreman and obtain any necessary permission to take equipment out of service.

(5)

Date of Full Compliance 1

. Full compliance was achieved on. August 23,.1983 when VA~-V17 was opened restoring flow to RM-A5.

" General Discussion of Violations 2a through 2d All of the above violations were discovered by GPUN, corrected in a timely manner, and reported to the NRC.

The violations are considered to be of minor safety significance.

The events were caused by random unrelated individual human errors rather than a lack of respect for procedural compliance.

In fact we believe we have reached a point where we can expect procedural compliance because of the procedure quality we have achieved.

In addition,' personnel know that they can not hide behind poor procedures to cover up inadequate personal perfomance.

Our procedures can always be improved. However, the quality of our procedures is in.part responsible for the high level of respect we believe our people have for them.

We are concerned at the number of human errors which occurred but we do not believe that they are indicative of a single underlying cause.

Management expressed its concern and the need for improved performance to the TMI-l staff well before any NRC action was taken.

We believe our personnel disciplinary policy ~and actions, and continued emphasis on procedural compliance will be successful in preventing recurrence of these types of problems.

Violations Related to Procedural Intrecretation Violation 3 10 CFR 50.54(q) requires.the licensee to follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements.of 10 CFR Part 50, Appendix E.

Technical Specification 6.8.1 requires written procedures be established, implemented and maintained covering, among other things, emergency plan implementation.

Emergency Plan Implementing Procedure 1004.1, Revision 9, August 22, 1983,

. Unusual Event, paragraphs 1.0 and 3.4.lb define a condition that shall be regarded as an Unusual Event at TMI-l with respect to exceeding the technical specification _ primary system leakrate.

Paragraph 3.4.lb lists the indications of.this initiating condition, in part, as confirmed (procedurally indicated) 0987K

.,, a - -

-8.

unidentified reactor coolant leakrate greater than l' gallon per minute (gpm).

Further, paragraph 3.3.1 considers plant conditions which may indicate a' potential degradation of.the level of safety of the plant to be regarded as an Unusual Event.

Contrary to the above, on September 22, 1983, as of 6:00 PM, a plant condition of a confirmed (procedurally indicated) unidentified primary system leakrate in excess of 1.0 gpm (calculated as 1.2 gpm) was not classified as an Unusual Event.

. e;(. u.

,.=

Response to Violation ~3 (1)

Admission or Denial GPUN considers that this violation arises from a reasonable disagreement concerning the interpretation of EPIP 1004.1. Based on the above statement of violation, we understand the NRC's interpretation to be essentially that, regardless of the applicability of the Technical Specifications (TS) on leakrate, when RCS unidentified leakage is greater than 1 gpm but less than 50 gpm an Unusual Event must be declared.

This interpretation essentially renders inoperative the words Technical Specification in the procedure's initiating condition, which reads " Exceeding primary system leak rate technical specification".

The NRC interpretation is not consistent with the fact that leak rate measurements are not made or required when the plant is below 525cF and that the 1 gpm limit is inoperative when at or below hot shutdown.

(2)

Reason'for Violations GPUN did not interpret EPIP 1004.1 the way the NRC staff did and therefore did not declare an Unusual Event.

(3)

Corrective Action Taken Section 3.4.1 of EPIP 1004.1 will be modified to clearly indicate that an Unusual Event should be declared when leakage exceeds the stated limits (eg; unidentified leakage exceeds 1 gpm) and the reactor is critical.

(4)

Steps Taken to Prevent Recurrence The above change will be explained to the operators to assure a full understanding and prevent recurrence of this type of event.

In addition, a revision to the RCS leakrate procedure (SP 1303-1.1) will be issued that clearly defines how to calculate, how to confirm, and the time allotted for confirmation of unidentified leakage. It should be noted that at the time of this event, management was convinced that the leakage was into a closed system which directed it to a collecting tank and was therefore " identified leakage" as defined in Regulatory Guide 1.45..All operators will be thoroughly trained on the procedure revision.

0987K

o (5)

Date of Full Comoliance

~

' Full compliance will be achieved by June 1,1984 when EPIP 1004.1 and SP 1303-1.1 will be revised.

Violation 4

_ Technical Specification 6.8.1 requires, in part, that procedures important to safety-shall be implemented covering Emergency Plan Implementation and Administrative Procedures.

i Administrative Procedure (AP) 1001A, Revision 4, dated June 14, 1983, Procedure Review and Approval, paragraphs 3.3 and 3.4 require, in part, that the control and approval process for revision / changes to procedures is by use of a Procedure Change Request (PCR) form (Figure 1001A-1) or a Temporary Change Notice (TCN) form (Figure 1001A-2). Administrative Procedure 100lG, Revision 4, dated October 13, 1982, Procedure Utill'zation, paragraph 3.3.10, states, in part, that Special Temporary Procedures (STP) are subject to the same level of control and approval as their permanent counterparts.

Contrary to the above, on August 29, 1983, STP No.83-115, dated August 27, 1983,. Injection of Radioactive Tracer Gas into the RCS, was revised / changed in that certain valves to be checked in a prerequisite valve lineup were added to this list and this revision was made without the use of a PCR or TCN.

The revision / change consisted of adding certain flow path isolation or boundary isolation valves to prevent inadvertent release of radioactive material.

Response to Violation 4

~

(1)

Admission or Denial This violation is admitted. We note that the procedure in question was cancelled prior to its use in the revised form. Therefore no operations were performed using the improperly revised procedure.

(2)

Reasons for Violation l

The TMI-l Administrative Procedures did not. clearly address how changes I

to Special Temporary Procedures (STP) are to be made. The nature of an STP is for.one time use.

We had little experience witn changes to them.

This resulted in an oversight in properly processing the changes.

(3)

Corrective Action Taken The STP was cancelled and explicit guidance has been included in E

administrative procedures concerning revisions / changes to STP's.

(4)

Steps Taken to Prevent Recurrence All PRG members have been made aware of this event.

This combined with the above changes in the administrative procedures should prevent recurrence.

0987K

,n s' -

- 10 d'

. 6 (5)

Date of Full Compliance Full compliance has been achieved by' cancelling the STP.

Violation 5 10 CFR 50.54(q) requires the licensee to follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements of 10 TR Part 50, Appendix E.

.c

~

Technical Specification 6.8.1 requires written procedures be establi'shed, implemented and maintained covering, among other things, emergency plan implementation.

Emergency' Procedure 1202-12, Revision 14, dated May 18, 1983, Excessive Radiation Levels, paragraph 2.3.a.l.e and Enclosure II, require that a Planned / Unplanned Release Report be initiated by the shift supervisor when an atmospheric monitor reaches the alert setpoint.

Administrative Procedure 1044, Revision 12, June 30, 1983, Event Review and Reporting Requirements, paragraph 3.2.2.a.8, and 10 CFR 50.72, require notification of the NRC within one hour upon occurrence of any accidental, unplanned or uncontrolled radioactive release.

Contrary to the above, a Planned /Unplamed Release Report for an uncontrolled release of krypton-85 was not initiated by the shift supervisor after the fuel handling building atmosphere monitor RM-A4 reached the high alarm setpoint (higher than Alert) and plant effluent atmospheric monitor RM-A8 reached the Alert setpoint between 4:45 PM and 4:55 PM on August 29, 1983. In addition, the NRC was not noti'fied until approximately 8:56 PM, August 29, 1983 of the o

release.

Response to Violation ~5 l,

(1)

Admission or Denial l

This violation'is admitted and was, at least in part, discovered and corrected by GPUN within about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the event.

(The failure to complete the planned / unplanned release forms was identified by the NRC.)

(2)

. Reasons for Violation Prior to the addition of Kr-85 to the RCS GPUN had performed l

. calculations to determine the consequences of release of all 20 curies.

These calculations indicated that such a release would result in insignificant offsite dose consequences.

During the first attempted

. addition of Kr-85 to the RCS (8 curie container) some of the activity was released (Violation'2a). At the time of the release it was known, based on the above calculations, that the consequences were trivial.

l l '

0987K

.. - ~.

. ~

e

o. The operators did not immediately recognize that the event-had triggered

~

the then existing prompt notification requirements. As a result, the event was not reported to the NRC until greater than 1 hotr had elapsed and no release report was completed.

(3)

Corrective Action Taken The unplanned release was reported to the NRC, albeit late, on August 29, 1984.

The release forms have not been completed after the fact since-the evaluation of a release that the forms were supposed to trigger was completed and completing the forms at this time would serve no useful purpose.

(4)

Steps Taken to Prevent Recurrence AP-1044 has been revised to reflect changes to 10 CFR 50.72 which went into effect on January 1,1984.

The reporting requirements under the new rule would not have required reporting of this event (not withstanding a news release).

In addition, all Shift Supervisors have been reminded of the reporting obligations under 10 CFR 50.72 and of the administrative requirements of EP 1202-12 regarding documentation of unplanned releases.

(5)

Date of Full Compliance Full compliance has been achieved.

General Discussion of Violations 3, 4, & 5 The above violations'are administrative in nature and had no impact on public health or' safety.

They nevertheless should not have occurred.

We believe that we have learned from these mistakes and have used them to reemphasize the need for the attention to detail.

i 0987K

• 1,3 s. ([' i NUCLEAR REGULATORY COl.'.t.'tS5LCN tpQF.5 REGION 1 8

s:1 PARK AVENUE g%pgg g p

xisc or rRu::s:A, PENN:YLVAsi!A re:o3 Docket No. 50-289 License No. OPR-50 EA'83-140 GPU Nuclear Corporation ATTN:

Mr. P. R. Clark President, GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 Gentlemen:

Reference:

Notice of Violation (NRC Inspection Report Nos. 50-289/B3-25, 50-289/83-25, and 50-289/83-33)

This. refers to NRC inspections conducted August 24 - September 7,1933 and August 29 - October 3, 1983, at the Three Mile Island Nuclear Station, Unit 1 (THI-1), Middletown, Pennsylvania,' of ac:tvities ac:horized by NRC License No. OPR-50.

Both inspection recorts were forwarded to you by letter dated October 28, 1983.

During these inspe=tions, apparent violations of HRC require-ments were identified.

On November 8,1983, an enforcement conference was held with you and other members of your staff, during which the apparent violations, their underlying causes, and your corrective actio.1s were discussed.

This enforcement conference is documented in NRC Inspe ion Report No. 50-259/53-33.

~

The resultant violations are described in the enclosed Hotice of Violation.

The violations involved a radiological occurrence in which a substantial pctential existed for a radiation exposure in excess of NRC regulatory l

limi:s; two examples of nonautomati: :ontainment isolation valves being left open when they were required to be closed; f ur instan:es in which proceduves i=pertant to safety were not followed; a failure to pr:perly classify an event in accordance with the Emergency Plan Impicmenting Pre:edure; the impreper revisi:n of a procedure used to check injecticn of radica:tive tracer gas inte tne reactor coolant system; and failure te c:..plete a e:uired report er to 70:ify the NRC Of an unplanned release.

l l

Tr.e viciations are classified in the en: cse: 'c-i:e a; Severity Level s in a::arcance with the NRC Enforcement Eci'Oy.

'.C CFE Part 2. A:pe., dix 2.

'ne

.iciations involving rea: tor c:erati:ns are ca:egeri:e: ir :ne 1;g e; ate as a Severity Level III preole=.

The violation involvis; :ne raciclogical cc:ur ence is cate'gorized as a Severity Level III violation.

CERTIFIED MAIL RETURN RECEIPT REQUESTED l

I l

i l

GPU Nuclear Corporation 2

The occurrence of these violations at this facility are of con:ern to us.

-The unit has not been o,. orating for several years and now is preparing for restart. We have oeen assured that you have in place an organization second to none in this country in terms of its ability to ceal with the operation of TMI-1.

'The violations described in the attached Notice incicate that you have not yet acnteved this goal.

To emphasize the need for you to redouble your efforts to ensure that procedures are properly implemented including procedures for verifying correct performance of operating activities, we have decided to propose a civil penalty of Forty Thousand Dollars (S40,000) for these viola-tions.

We could also have proposed a civil penalty for the radiological occurrence violation but, in view of the fact that you identified and reported the violation and took prompt and extensive corrective action, we have decided not.to propose a civil penalty for this violation and no further response to

'this Violation is required.

In addition, the Director of the Office of Inspection and Enforcement and I have decided that we would like to visit the site and discuss with you and your staff the root causes of the events and the corrective actions you propose.

You are required to r.espond to this letter and should follow the instructions specified in the attached Notice when preparing your response.

In your response, you should document the specific actions taken and any additional acticas you plan.to prevent recurrence.

Your response snould specifically address corrective actions concerning independent verif t' cation and adherence to procedures.

In accordance with Section 2-790 of *1ihe NRC's " Rule for Practi:e," Part 2, Title 10, Code of.r deral Regulations, a copy of this letter and its en:losure e

will be placed in the NRC Public Occueent Room.

The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget, otherwise required by the Pacerwork Reduction Act of 1950, ?L 95-511.

Sincerely, r

ffAMY,

Thomas E. Murie)

Regional Acministrator

Enclosure:

Notice of Violation and Proposed Imposition cf Civil Penalty

NOTICE OF VIOLATION AND PROPOSED imp 0SITION OF CIVIL :ENALTY GPU Nuclear Corporation Cocket No.

50-289 Three Mile Island Unit 1 License No. DPR-50 EA 83-140 During NRC inspections conducted August 24 - September 7,1983 and August 29 -

October 3,1983, violations of NRC requirements were identified.

Th'e violations involved a radiological occurrence in which a~ substantial potential existed for a radiation exposure in excess of NRC regulatory limits; two examples of nonautomatic containment isolation valves being left open when they were required to be closed; four instances in which procedures important to safety were not followed; a failure to properly classify an event in accordance with the Emergency Plan Implementing Procedure; the improper revision of a procedure used to check injection of radioactive tracer gas into the reactor coolant system; and failure to complete a required reper and the resultant failure to notify the NRC of an unplanned release.

l To emphasize the need for you to redoub'le your efforts to ensure that procedures are properly implemented including procedures for verifying correct performance of cperating activities, the Nuclear Regulatory Commission proposes to impose a civil penalty of Forty Thousand Do11arr (540,000) for these violations.

In accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the violations are set forth below:

A.

Violations Assessed a Civil Penalty 1.

Technical Specification 3.5.1 requires that c:ntainment integrity be maintained when reactor coolant (RC) pressure is 300 psig or greater, RC temperature is 200*F or greater, and nuclear fuel is in the cere.

Technical Specif t:ation 1.7 defines containment in egrity and specifies as one of its conditions tha; all nenautoma i: centainment isolation valves are closed as re:uired :y the "C:ntaineen: I r.t e g ri ty Checklist" attached to the :: era:ir; : c:ecu e "Centainter.: :ntegrity and Access Limits."

Operating Precedure (CP) 1101-3 Revision 27, August 18, 1983, (Temporary Change Notice No. 1-53-0153, cated August 24 1933) con-tainment Integrity and Access Limits, Enclosure 1, Reactor Building (Containment) Integrity Checklist, requires fer containment integrity,,

in part, that nonautomatic containment isolation valve IA-V20, Instrument Air Isolation Valve, be closed (paragra:h 18.2) and n:n-au cmatic containment isolation valve F5-v405, Fi e Service Tes:

Conne: tion / Drain Isolation Valve, be closed and ca: ped (paragra:n 17.').

Centrary to the a:ove, with RC ressure g ea:sr : nan 300 psig, ef:n RC temperature greater than 200'F, anc with na:iear fuel in :ne core:

Notice of Violation 2

e a.

Nonautomatic containment isolation valve IA-V20 was no: closed i

between Av ust 27, 1933 and September 20, 1983; and, b.

Nonautomatic containment isolation valve FS-VcOS was neither closed nor capped between August 27, 1983 and September 16, 1983.

2.

Technical Specification S.8.1 requires, in part, that written procedures important to safety shall be establisned, implemented, and maintained.

Contrary to the above, on four occasions, written procedures important to safety were not properly implemented, as evidenced by the following:

Operating Procedure (0P) 1104-43, Revision 19, February 11, 1983, a.

Nuclear Plant Sampling, paragraph 3.2.2.12.c and Enclosure 1, require, in part, that the Makeup Tank Liquid Sample Flush Valve, (CA-V95), be closed after a makeup tank liquid sample is collected.

However, between August 20 and 29, !?S3, CA-V95 was open with no makeup tank liquid sample being cc11ected.

b.

Operating Procedure 1104-43, Revision 19, dated February 11, 1983, Nuclear Plant Sampling,. paragraph 3.2.2.15.g and Enclosure 1, require, in part, that Makeup Tank Gas Sample Return Iso 1'ation Valve (CA-V47) and Makeup Tank Gas Sample Bemb Bypass Valve, (CA-V48) be closed after a' makeup tank gas space sample is

-- coll ected However, nn August 27, 1983, Valves CA-Vt7 and CA-V48 were open with no makeup tank gas space sample being cellected, Emergency Plan Implementing Procedure (EpIP) IC04.15, Temporary c.

Change Notice No. 1-83-0201, dated. September 30, 1983, Post Accident In-Plant Samoling, paragra:h S.1.7 anc Attachment 4, equire that Reactor Coolant Leid:wn -Sam:le Valve (CA-V16) De c': sed prior to i.rplementing tne :re:edure for eb aining a Reactor Cociant System (RCS) samole.

However, en September 30, 1953, th

ro:edure for :::aining 1..

RCS sample was implemented, but valve CA-V16 sas not :icsed.

d.

Administrative Procedure ( AP) 1002, Revision 27, datec August 1, 1983, Rules for the Protection of Emoloyees Working on Ele::rical l

and Mechanical Apparatus, paragraph D.1.1 and Enclosure 1, requires, in part, that for apparatus to be taken cut of service, L

L an as:lication from operations pers:nnel must be c:=plete assure technical specification operability requirements are et.

However, on August 23, 1983 the Corcensar Off Gas System Radia-tion Ef fluen Monitor. RM-A5, a moni::r -e:uired :y :Fe te:ned:ai specific:: ions to be c:eracle, was aien out Of se-v' e f:r approximately 10 - 40 minutes Oy icsing tne samole : ump iniet I

u

a Notice.of Violatien 3

I isolation valve VA-V17 without the required apolication from operations per onnel being completed.

3.

10 CFR 50.54(q) requires'the licensee to follow and maintain in effect emergency plans which meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E.

Technical Specification 6.8.1 requires written procedures be established, implemented and maintained ccvering, among other things, emergency plan implementation.

. Emergency Plan Implementing Procedure 1004.1, Revision 9, August 22, 1983, Unusual Event, paragraphs 1.0 and 3.4.lb define a condition that shall be regarded as an Unusual Event at TMI-1 with respect to exceeding the technical specification primary system leakrate.

Paragraph 3.4.Ib lists the indications of this initiating condition, in part, as confirmed (procedurally indicated) unidentified reactor coolant leakrate greater than I gallon per minute (gpm).

Further, paragraph 3.3.1 considers plant conditions which may indicate a potential degradation of the level of safety of the plant to be regarded as an' Unusual Event.

Contrary to the above, on September 22, 1983, as of 6:00 PM, a plant condition of a confirmed (procedurally indicated) unidentified primary system leakrate in excess of 1*.0 gpm (calculated as 1.2 spm) was not classified as an Unusual Event, 4

Technical Specification S.8.1 requires, in part, that procedures inportant to safety shall be implemented covering Emergency Plan Implementation and Administrative Precedures.

Administrative Procedure (AP) 1001A, Revision 4 dated June 14, 1983 Precedure Review and Approval, paragra:hs 3.3 and 3.4 recuire, in part, 'that the control and approval process fer revision / changes to procedures is by use of a Procedure Chan;e Re:ues: (?CR) f:rm (Figure 1001A-1) or a Temperary Change N: f:e (TCN) form (Figure 1001A-2).

Administrative Procecure 20013, F.evi sian 4, cated 0:::bar 13, 1982, Procedure Utili:atien, caracra:n 3.3. '0, states, in part, that Special Temporary Procedures (STP) ar.e su:Je:t to the same level of centrol and approval as their permanent counterparts.

Contrary to the above, en August 29, 1953, STP No.83-115, dated August 27, 1983, Injection of Radioactive Tracer Gas into the RCS, was revised / changed in.that certain valves to be checked in a prerequisite valve lineup were added to this list and this revision ~

was made without the use of a PCR or TCN.

The revision / change consisted of adding certain flow path iselatien or boundary l

isolation valves to prevent inacvertent release of radicactive material.

-,.n-,

e e

n-.

~,-,,--n.,,

,..-r

i Notice of Violation 4

i I

S.

10 CFR 50.54(q) requires the licensee to follow and maintain in j

effect emergency plans which meet the standards of 10 CFR 50.47(b) i and the requirements of 10 CFR Par 50, Appendix E.

Technic'al Specification 6.8.1 requires written procedures be established, implemented and maintained covering, among othi.r things, emergency plan implementation.

Emergency Procedure 1202-12, Revision 14, dated May 18, 1983, Excessive Radiation t.evels, paragraph 2.3.a.1.e and Enclosure II, require that a planned / Unplanned Release Report be initiated by the shift supervisor when an atmospheric monitor reaches the alert setpoint.

Administrative Procedure 1044, Revision 12, June 30,1983. Event '

Review and Reporting Requirements, paragraph 3.2.2.a.8, and 10 CFR 50.72, require nottfication of the NRC within one hour upon occurrence of any accidental, unplanned or uncontrolled radioactive release.

Contrary to the above, a Planned / Unplanned Release Report for an uncontrolled release of krypton-85 was not initiated by the shift supervisor after the fuel handling building atmosphere monitor RM-A4 reached the high alarm setpoint,(higher than Alert) and plant effluent atmospheric monitor RM-A8 re' ched the Alert setpoint between 4:45 PM a

and 4:55 PM on August 29, 1983.

In addition, the NRC was not notified until approximately 8:56 PM, August 29, 1983 of the release.

Collectively, tnese violations have been categori:ed as a Severity Level III proble=,

(Supplement I) Civil Penalty - 340,000.

S.

Violation Not Assessed a Civil Penalty Te:hni:a1 Specification 6.11 recuires, in oart. that precedures for i

persennel ractati:n protection shall be achered to for all operations l

involving personnel radiation exposure.'

l l

Con:rary to tne at:vs, on June 20, 1953, peccedures f:r personnel aciation orotection were not adhered to during decentamination of a " Hit: man" liner, an opreration involving personnel radiation exposure, as evidenced by the following:

Radiological Control Procedure (RCP) 1610.1, Revision 6, January 10, a.

i 1983, entitled Centrol of Locked High Radiation Areas, paragraph 6.6,,

l and Appendix A to this pro:edure, paragraph 5.0, require, in otrt, l

that the Rad Con foreman / technician inform ea:h individual entering a locked high radiation area of their stay tir.e and/or maximum i

i exposure 1t=1; and to exit.he arsa prior to exceeding that limit.

(

Hewever, en June 20, 1933, Racia: ten Cen:tmina:icn (Rad Con) feremen/tecnnicians resp:nsible for :ne :cate:1 of exposure during the transfer of a "Histman" liner ::ntaining solidified racicac:f ve was.e (spen resin) did n:t inform individuals entering a locked

~..

Notice of Viclation 5

'i high radiation area of their rtay time and/:r maximum expesure limits, and t%t they should exit the area prior to exceeding those

~

limits.

b.

Radiological Control Procedure (RCP) 1613 Revision 22, March 4, 1983; entitled Radiation Work Permits (RWp), Appendix B, paragraph 2.1.a states, in part :

...an RWP will be terminated if conditions in the area degrade significantly frcm the conditions stated on the original RWP."

Further, RCP 1613, Appendix A, paragraph 1.4 requires, in part, that, after completing an RWP, the RWP, plus all applicable forms, such as ALARA reviews, will be taken to the Rad Con department and discussed with the Rad Con representative to assure understanding by the workers of the scope of the job and the radiological control requirements.

Additiona: /, RCP 1513, paragraph 5.1.3, requires that, if current survey information is not available to prepare the RWP, the most recent survey will serve as a guide for completing the RWP.

However, on June 20, 1983, durin'g the transfer of a "Hittman" liner containing solidified radioactive waste (spent resin):

.i 1)

The RWP was not terminated even though the conditions in the area, namely, an average dose rate of 6 R/hr, were a significant degradation of the conditions stated in the original RWP, namely, a dose rate of. 75'mr/hr;

~

)

All personnel involved in the operation were not given a pre-job briefing to ensure they underst:od the scrpe of the job nor

!l did Rad C:n personnel specify to tne workers all applicable radiological controi requirements as stated c,n the ALARA review;

and, l,

3)

Survey information btained on June 17, 1953 was used in pre-paring the RWP in lieu of esce re:ent survey information :htained en June 19, 1923.

t Radiological Con rei procedure 16'1, :ev'sien 10, April 15,1933, 0:simetry Use and Ex::sure

n:r:1s. saragra:n 5.3.2.4 re::u t re s that personnel wearing self-reading cosimeters (SRCs) shall :eriod-ically esserve the cestmeter readings and return to the centr:1 :oint any time the low range dosimeter rea:ing rea:hes 75% ef full s: ale, i

However, on June 20, 1983, two radwaste operators did not Observe the readings on their SRDs while working for a period of 20 minutes in a locked high radiation area during the de:cntamination of a "Hittman" liner containing solidified radioactive waste (spent resin), whose cer. tact dose rate _ average: 6 R/hr.

Up:n :: pleting their tast and returning to the : ente i ;; int, the SR3s were Observed :: be off-scale Sigr..

This is a Severity Level !!I violation (Su::'emen: IV).

1 Notice of Violation 6

l 4

Pursuant to the provisions of 10 CFR 2.201, GPU Nuclear Corporation is hereby required to submit to the Director, Office cf Inspe= tion and Enfor:ement, USNRC, Washington, OC 20535, with a copy to this office, witnin 30 days of the date of this Notice, a written statement or explanation in reply, including for each alleged violation:

(1) admission or denial of the alleged violation:

(2) the reasons for the violation, if admitted; (3) the corrective steps that I

will be taken and'the results achieved; (4) the corre:tive steps that will be taken to avoid further violations; and (5) the date wnen full ecmpliance will.,

be achieved.

As stated in the letter, response is not necessary for Violation B.

Consideration may be given to extending the response time for good cause shown.

Under the authority of Section 132 of the Act, 42 U.S.C. 2232, this response i

shall be submitted under oath or af firma. ion.

Within the same time as provided for.hc response required above under 10 CFR 2.201, GPU Nuclear Corporation may pay the civil penalty in the amount of Forty Thousand Dollars or may protest imposition of the civil penalty in whole or in part by a written answer.

Should GPU Nuclear Corporation fail to answer within the time specified, the Director, Office of Inspecti:n and Enforcement, will issue an order imposing the civil penalty in tne amount proposed above.

Should GPU Nuclear Corporation elect to file an answer in ac:ordance with 13 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violations listed

.in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed.

In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors contained in Section IV.9 of 10 CFR Part 2, Appendix C'should be addressed.

Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the s atement or explar.ation in reply pursuant to 10 CFR 2.201. but may inc:rporate by specific reference (e.g., citing page and paragrapn nurbers) to avoid repetition.

Tne attention of GPU Nuclear Corpora-ion is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty due, which has been subsecuertly deter-mined in ac::rdance with the apoli:able :r: visions :f 10 CFR 2.205, t.-is maner may be referreo to the Attorney General, an:

ne :ena' y, unless ccm: :.ised, remit.e:, er mitigated, may te collected by civil 1:t' n suan. :: 5s:-i:-

224c cf tne A::, 42 U.S.C. 2232.

FCR THE NUCLE.A:t RESULATORY' CN.M*33:0N l

I e

fY l

Thomas E. Murle

~

~

Regional Acministrator Oated at King of Prussia, cennsylvania

nisyfcayofFebrua'y1934 L.

nWLm GPU Nuclear Corporation

,4} ())

GQ g

Post Citico Fox 480 a

d A-Route 441Jouth Midctatown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Olal Number:

5211-84-2087

' April 2, 1984 Mr. R. C. DeYoung Director, Office of Inspector and Enforcement U. S. Nuclear Regulatcry Commission Washington, D.C. 20555

Dear Mr. DeYcung:

Three Mile Island Nuclear Station, Unit I (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation and Proposed Civil Penalty, Regarding Inspections 83-25 and 83-26 and Enforcement Conference 83-33 Revision Attach 3d is a revised page two to our March 30, 1984 response to the above Notice of Violaticn and Proposed Civil Penalty.

The revised page corrects three clerical errors.

The changes are indicated by margin cars on tne attached revised page.-

We regret any inconvenience tnat these errors may have caused.

Sincerely,

(

l H

111, Director, TMI-l HDH:CWS:mle Attachment cc: Dr. Thomas E. Murley R. Conte

I 2

We have reviewed the Notice of Violation against tne revised enforcement action policy statement.

The revised statement explicity allows aggregation of violations for the assignment of a severity level as has been done in this j

instance.

However, in providing the flexibility to aggregate certain J

violations, the Commission had in mind focusing attention on an " underlying problem or programmatic deficiencies when apprcpriate." 49 Fed. Reg. 8584 (1984). We do not believe that test is met here and thus question whether aggregation in this instance is appropriate.

In fact, we agree with the statement in Mr. Starostecki's Deceaber 23, 1983 letter that "these problems are considered to be-isolated cases and not indicative of a programmatic problem". Furthur, review of the items in the Notice of Violation, taken individually or even collectively, do not rise.to the severity of problems enumerated as illustrative of Category III severity items in the revised statement -- viewed either as operational matters (Supplement I) or as health I

physics concerns (Stoplement IV). Thus, we question the appropriateness of categorizing our violation as Category III at all. Finally, viewed even as a Categcry III violation, we note that tne Commissicn has changed its policy with regard to this category from "usually imposing" fines to simply "considering" fines.

Surely, when compared with the illustrative examples within the range of Category III severity, the items noted in our proposed violation notice cannot be viewed as severs.

The second development cince the civil penalty was proposed is your's and Dr.

Murley's visit to TMI-l on March 5,1984. During the visit you met individually with management, supervisory personnel, and first level enployees. We can understand that prior to this visit you may have believed that it was necessary to invoke a civil penalty to promote proper attention and reaction within the TMI-l organization as a whole.

Based on our prompt and cow.-Wtsive corrective actions, which from the enforcement conference and your nu ' ion at the site we understand ycu accept, and based on the positive attituces which you observed during your visit, we believe that a civil penalty is unnecessary to further NRC's enforcement objectives.

Other positive indications of this organization's approach are:

9 1.

. Unannounced Of f-Shift Tours by Management.

2.

On-Sbift CA Monitors.

3.

Site Managers meetings periodically where problems such as these violations and other significant matters are discussed for general understanding and multidisciplinary feetback.

4.

The Estaclishnent of the Nuclear Safety and Compliance Committee.

j 5.

Frequent discussions between management and the operaters.

4

- ~-

,-._y.

y.

.-m y-.

y.

.,.-y

.~

GPU Nuclear Corporation I t" p J l

g gp Post Office Box 480 m-Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

i 5211-84-2085 March 30, 1984 Or. Thomas E. Murley Region I, Regional Administrator U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA.19406

Dear Dr. Murley:

Three Mile Island Nuclear Station Unit I, (TMI-1) i Operating License No. DPR-50 Dod<et No. 50-289 Licensed Operator Experience Review and Summary Although TMI-l is not a Near Term Operating License (NTOL) plant, we are aware of EC's recent heightened interest in licensed operator experience at NTOL plants coming on line. Because of. our long period shutdown and the large nucber of new operators that have been licensed during this period, our situation in regard to operating experience is somewhat akin to that of the N TOL 's.

In preparation for restart, therefore, we have made a thorough study of our licensed operators' prior experience to ensure ourselves that the experience level is adequate to safely startup and operate the plant.

We also have reviewed experience level in relation to shift assignments to make certain that the experience'lesl among the various operating shifts is relatively consistent. We decided to compare our situation to the NTOL Working Gro@'s proposal, as we find this to be a convenient baseline for comparison.-

The attachments to this letter indicate the operating experience of TMI-l licensed operators on each shift for both a six-snift rotation and a four-shift rotation. We believe that the attachments clearly demonstrate that TMI-1 possesses the requisite. experience in its staff of licensed operators to

. safely start @ the plant.and to perform power escalation testing in a deliberate and controlled manner. Thus, for example, while the baseline for NTOLs provides for 6 years of nuclear plant experience and 13 years of power-plant experience, our crews at TMI-1 far exceed that amount of experience.

GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

-.i-

2 It should ba noted that the operating expericnce indicated for each licensed operator is based on our own employment and training records supplemented by information provided to us by the individuals themselves.. Additionally, because of the uncertainties involved in applying the NTOL Working Group experience factors due to the lad < of detailed records.on prior experience, we have added conservatisms by (1) decreasing the power / nuclear plant experience level calculated for each individual to the next lower 1/2 man-year, and (2) by not including the Licensed Classroom Training and Exam factor in compiling the experience level for any operators.

The worksheets used to develop the attachments to this letter are available for review on site.

There are several other factors that provide added confidence that we have the needed overall experience on each shift to safely startup the unit and proceed to full power operation.

These include:

TMI-1 operators have maintained normal plant functions on an ongoing shift routine.

This has allowed many hours of exposure to equipment operation, including set tp and recovery from maintenance functions, performance of surveillance testing, and many hours of system walk-down and training access that can only be provided by fbnctional plant systems.

The recent hot functional testing of the steam generators of about 42 days provided invaluable hot operating experience for all shift During this hot testing period, the majority of refueling crews.

interval surveillances were conducted, giving the staff a large exposure to difficult and infrequent operations.

A qualification program with official sign off cards for both licensed and auxiliary operators was developed to require equipment, system and evolution checkout, operation or walkdown as appropriate during hot testing and'pdwer escalation testing (PET). This program was designed to require that each operator perform specific evolutions and tasks, dependent on plant conditions, or if the evolution could not actually be performed, a walkdown be conducted.

These cards were used during hot steam generator testing and will be continued throughout PET. Completion of these qualification cards will give us the assurance that each operator has participated in, or has as a minimum, observed or walked-thru those evolutions he could reasonably be expected to encounter during normal plant operations PET has been designed to be conducted in a very closely controlled and deliberate manner.

Two 30-day periods each at reduced power (48% and 75%) have been designed into the program specifically to provide operator training and familiarization time. At the conclusion of PET, the qualification cards of each operator will be reviewed to ensure all operators have completed the required evolution or walk-thru, as appropriate.

The plant will not proceed to full power commercial operation until operators have completed all essential evolutions.

The Shift Organization at TMI-l has been developed and expanded to provide the Operations Shift Supervisor sufficient talent and expertise to perform work and investigate problems with minimum disruption to on-shift Operations personnel. Around the clock STA, rad con, chemistry and maintenance shift coverage is in place.

A

The shift maintenarce crew consists o'f a Foreman with consideraole

,experienc'e at TMI~ and.a maintenance crew of.about ll technicians Isporting to him. ;The! experience of the Maintenance Foreman and his crew is an invaluable asset to the Shift Supervisor.

A degreed _ individual from the QA Department has been assigned on shift around the clock to monitor operations and maintenance performance.

An Off-Shift Management Tour program, which provides for periodic unannounced off-shift tours in the plant by management, has been in place for several years.

The A10G program has been implemented.

Implemantation of this program, was carried out using our " crew team concept" mode of training and operation.

Each crew was tested on the simulator as a crew and will be tested in the Control Room as a crew.

TMI-l currently has 13 qualified SRos and 20 qualified R0s in the shift operating crews.

Three of the R0s have passed the simulator and oral examinations for SRO and are awaiting results of bleir written examinations. A class for soven new R0s commenced in February.

Morale at Unit I, especially among the licensed operators, remains remarkably high in spite of the numerous setbacks and frustrations e perienced over the past few years. As a measure of this, only one licensed operator.has resig1ed in more than two years. Our people express confidence that permission to restart will be granted and that they can accomplish this in a safe and professional manner.

Each crew of licensed operators spent blirteen days in training at the B&W simulator in 1983 and have spent five days already.in 1984.

We plan 01ree additional days at tne simulator for each crew in April and May (included in attached experience charts).

This training period will be primarily devoted to PET evolutions and normal plant operations and malfunctions.

To ensure the effectiveness of the simulator training program, senior management directly participated or observed and will continue-to do so.

Additionally, for each simulator session since January 1983, tne operating crew was required to pass an operating examination administered by -a TMI-1. Emergency Director at the end of the training period.

This practice will continue in the future. All simulator training is done using the " crew team concept" in order to improve and practice the individual operators' abilities to work with and communicate with each other.

All licensed operators have been examined using the new NRC examination procedures regardless of their pre-accident license status.

All licensed operators without on-line operating experience at TMI-l have-passed an NRC-administered simulator examination.

4.'

Du' fng starttp a6d testing,. experienc'ed Startup and Test personnel-r will. be on shif.t.to provide guidance.and assistance to the operating

.c....,

-e7g,p s, As previously noted, Attachment I to this letter indicates the operating experience of* 1icensed operators at TMI-l on a six-shift rotation and indicates the operating experience of licensed operators if a four-shift rotation were employed.

Using either shift rotation, we far exceed the NTOL Utility Working Grotp's recommendations for power plant experience

- and nuclear plant experience. However, with a six-shift rotation we do not meet the N10L Grotp's recommendations in regard to the following two specific hot operational experience factors:.

2nd SRO 6 Weeks at >20% Power (Not met on 4 of the existing 6 shifts)

Shift Supervisor Starttp/ Shutdown (01 one shift, the Shift Supervisor has made a shutdown, but no startups).

In a four-shift rotation we greatly exceed all the experience recommendations of the NTOL Utility Working Group.

GPUN strongly endorses and plans to utilize the six-shift rotation plan for licensed operators during startup and PET for the fbilowing reason:

.There is more Ulan adequate nuclear power plant experience (total)

.in all shif ts.

On a six-shift rotation, we will ha've at least five licensed operators on each shift (3 SR0s and 2 Rus or 2 SR0s and 3 R0s) which exceeds the requirements for 2 SR0s and 2 R0s per shift.

These crews.have-trained and worked together for a consideraole

~

r period of time and have developed a." crew team concept", not only with the licensed operators, but also with the auxiliary operators and other shift stoporting grotps.

By " crew team concept", we mean that everyone on shift has a position and each position has specific, but different responsibilities.

By each individual applying himself to his own responsibilities and integrating these responsibilities with the others on shift, the " crew team concept" takes place.

Once the individuals learn to communicate and work together they are a team.

Each crew, not including Maintenanco, Rad Con, and Security support personnel, consists of a Shift Supervisor (SRO), Shift Foreman (SRO), Primary CR0 (RO), Secondary CR0 (RO),

Switching and Tagging CRO, STA, and six Auxiliary Operators.

The CR0s are interchangeable, but will always know which position diey are filling.

the " team concept" is an important ingredient to safe and professional operations.

Remaining on a six-shift rotation continues to provide one week in every six for training.

l 5

' Four-section~ rotation has the' undesirable result.of more people' in i

.tbe C.ontrol Room. because of, the. large,nymb.er. of licensed operators.

.iri 'eachlshift.

f.

...l

.3 n

' Control, re'spon' sib'ility, and cha'in of commalid must be very clearly spelled out because of the large number of Ros and SR0s on shift in a four-section rotation.

The six-shift rotation has been strongly endorsed by the Commonwealtn of Pennysivania and GPUNC.

. It has taken. considerable time, effort and planning to get enough.

people licensed to man six shifts. Now that this has been achieved, we should not retrench unless absolutely necessary.

In reviewing the shift manning requirements, a five-shift rotation was also investigated.

We would come very close to meeting the NTOL Working Group's recommended experience levels on five shifts, but would have to use management and Training personnel to do so.

It is considered that this would be extremely disrtptive to the overall management and control of the plant and was, therefore, eliminated as an option at the present time.

If you desire more information or want to discuss this matter in more detail, please so a&ise us.

Sincerely,

. D.

ukill, Director, TMI-l HDH:mle Attachments cc:

R. Conte J. F. Stolz

,r.-

-~*-

~

ATTACHNENT1 (Six Shift Rotation)

~

OPERATING SHIFT EXPERIENCE "A". SHIFT

~

NUCLEAR ll0T PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND

'. '; 6..

EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SilIFT SUPERVISOR (NOLL).

9.5 6.5 SR0 41/2 yrs.

Y Y

SENI.0R. 0PERATOR

'(BRA.NTLEY) 12.5 3.5 SR0

+11 months

.N N

f..

l LICENSED OPERATOR

~(Kell.ER) 6.5 2.0 R0 LICENSEbOPERATOR (MAST.ERS) 14.0 4.5 R0 LICENSED.0PERATOR 1

'(TREADWAY) 10.0 3.5 R0 T.0 tai... '

52.5

' 20.0

> +AT POWER TRAINING TIME J '-

INCLUDED C

• LICENSED TRAINING TIME i-ON SHIFT INCLUDED.

l

. C Y = YES N=NO t,

,q.

f 7

t h

"B" SHIFT NUCLEAR HOT PARTICIPATION EXPERIENCE AT THI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND EXPER'.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIFT SUPERVISOR (SMITH, D. E.)

14.5 4.5 SR0

+17 months Y

~

Y SENIOR OPERATOR (PAULES) 7.0 3.0 SR0 0

N N

SENIOR OPERATOR (WYNNE) 6.0 2.0

• • R0 0

N N

LICENSED OPERATOR (BEZILLA) 3.5 1.0 R0 LICENSED OPERATOR (LANE) _

5.0 3.0 R0 LICENSED OPERATOR (NILAND) 5.5 3.0 R0 TOTAL 41.5 16.5

+AT POWER TRAINING TIME INCLUDED

• LICENSED TRAINING TIME ON SHIFT INCLUDED.

Y = YES N=N0

• • AWAITING NRC SR0 WRITTEN EXAM RESULTS - PASSED NRC SIMULATOR AND ORAL EXAMS.

i. -

D

2' -

f,..

a "C"' SHIFT

~

NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND EXPER.

EXPER.

OPERATION 3 HUT 00WN

• 6 MONTHS ON SHIFT POSI ION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIFT SUPERVISOR SU-No (SMITH,.D. A.)

11.0 5.0 SR0

+10 mos.

SD-Yes Y

SENIOR OPERATOR (DAVIS) 7.0 4.0 SRO O

N N

SENIOR OPERATOR (HASS) 7.5 3.5

• • RO O

N N

LICENSED OPERATOR

'(CAMPBELL) 5.0 1.0 R0 LICENSED OPERATOR

-(MOORE) 6.0 2.0 R0 TOTAL:

36.5 15.5

• LICENSING TRAINING TIME ON SHIFT INCLUDED.

+AT POWER TRAINING TIME INCLUDED l

Y = YES

'(.

N=NO

• • AWAITING NRC 1R0 WRITTEN EXAM 1,

RESULTS.

PASSED NRC SIMULATOR

(

AND ORAL EXAMS.

O E

'c I.

V

'f.

x "D" SHIFT

~

NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT

. P6SITI6N (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIF.T' SUPERVISOR (JANES).

18.5 6.5 SR0 2.75 yrs.

Y Y

SENIOR OPERATOR 2 (HERMAN) 12.5 2.0 SR0

+7 mos.

Y Y

]

ElCENSED OPERATOR

' (CHALECKI) 12.0 6.5 R0 LICENSED OPERATOR

'(WALSH) 6.0 3.0 R0 LICENSED OPERATOR (HONSON).

5.5 1.5 R0 j

.T6TAL' 54.5 19.5

+AT POWER TRAINING TIME INCLUDED

• LICENSING TRAINING TIME ON SHIFT INCLUDED.

Y = YES x.

N = NO I

n

• 6

?

F

. - ~

i 4

--,r----

8

~

.g. SHIFT

~ ~ ~

. NUCLEAR HOT PARTICIPATION EXPERIENCE AT THI s

POWER POWER

>20%

STARTUP a

PLANT PLANT POWER AND EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT (IN YRS)

(IN YRS)

. LICENSE TIME EXPER.

AT HOT CONDITIONS POSITION

[' SHIFT'. SUPERVISOR (B0YER) 8.5 2.5 SRO

+1.4 yrs Y

Y SENIOR ^ OPERATOR (FRASER) 8.0 4.5~

SR0 "0

N

.N SENIOR OPERATOR

.(MAAG) 7.5 3.5

• • RO 0

N N

. LICENSED OPERATOR (HEILMAN) 10.0 6.5 R0

^

LICENSED OPERATOR

r (WILLENBECHER) 4.0

.50 R0 LICENSED ~0PERATOR

'(GALLAGHER) 8.5 4.5 R0 l,

TOTAL 46.5 22.0 1

+AT POWER TRAINING TIME INCLUDED

- 'q -

• LICENSING TRAINING TIME ON SHIFT INCLUDED.

i 4

Y = YES I

N = NO

..c

~

• • AWAITING NRC SRO WRITTEN EXAM

(

RESULTS.

PASSED NRC SIMULATOR

~

AND ORAL EXAMS.

.y l

a e

i

"F" SHIFT NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER' AND EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIFT: SUPERVISOR (CR0USE) 17.5 9.0 SRO 4.16 yrs.

Y Y

SENIOR OPERATOR (MARTIN) 9.5 5.0 -

SR0 0

N N

LICENSED OPERATOR

-(G000 LAVAGE) 10.0 6.5 R0 LICENSED OPERATOR (BUGELHOLL) 5.0 2.0 R0 LICENSED OPERATOR (BIXLER) 4.0 1.5 R0

.t TdTA 46.0 24.0 1

• LICENSING TRAINING TIME ON SHIFT INCLUDED.

i i-Y = YES

'~

}t; N=NO

~

-,j s,

e

e

=

0FF'hHIFTPERSONNEL L'

NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS (Olive) 8.5 3.0 SR0 0

N N

(Ross) 17.5 10.0 SR0

++5 yrs.

Y Y

(Shipman) 12.0 4.0 SRO

+1 yrs.

Y Y

' (.Bolyz) 10.0 6.5 SR0 4.5 years Y

Y (Kacinko) 3.5 1.5 R0 0

N N

(Wilt) 4.5

.50 R0 0

N N

ls '.

TOTAL:.

56.0 25.5

+ Af.'. POWER TRAINING TIME INCLUDED

• -Lly'e. included 2 years hot operations at other PWR.

++Not nsing Training Time on shift included.

Y = Yes N = No N e'.

I

.t -

e ATTACHMENT 2 r

(Four Shift Rotation)

C OPERATING SHIFT EXPERIENCE "A" SHIFT-i

.g NUCLEAR liOT PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND EXPER.

EXPER.

OPERATION SilVTDOWN

• 6 MONTHS ON SHIFT POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIFT SUPERVISOR

(,.NOLL) 9.5 6.5 SR0 41/2 yrs Y-Y SENIOR OPERATOR

',(BRANTLEY) 12.5 3.5 SR0

+11 mos.

.Y Y

~ SENIOR OPERATOR

.(0 LIVE) 8.5 3.0 SR0 0

N N

SENIOR OPERATOR

,](WYNNE) 6.0 2.0

• • R0 0

N N

LICENSED OPERATOR i

.'(MAST ERS) 14.0 4.5 R0

+

LICENSED OPERATOR

,,KELLER) 6;5 2.0 R0

(

LICENSED OPERATOR j.TREADWAY) 10.0 3.5 R0

+AT POWER TRAINING TIME INLCUDED

.[(LANE)

ICENSED UPERATOR

• LICENSING TRAINING TIME 5.0 3.0 R0 ON SHIFT INCLUDED

• • AWAITING NRC SR0 WRITTEN EXAM RESULTS.

PASSED NRC SIMULATOR

. TOTAL 72.0 28.0 AND ORAL EXAMS.

y.

Y = YES

)

.f.

N=NO 4

J' "B" SHIFT NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI J-POWER POWER

> 20'l STARTUP PLANT PLANT POWER AND EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT

. POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIFT SUPERVISOR

.(JANES) 18.5 6.5 SR0 2.75 yrs.

Y Y

5ENIOROPERATOR

~(HERMAN) 12.5 2.0 SR0

+7 mos.

Y Y

SENIOR OPERATOR

, (MAAG) 7.5 3.5

• • RO O

N N

SENIOR OPERATOR

',(HASS) 7.5 3.5

• • R0 0

N N

LICENSED OPERATOR (CHALECKI) 12.0 6.5 R0 LICENSED OPERATOR

..(WALSH) 6.0 3.0 R0

' LICENSED OPERATOR

' (MONSON) 5.5 1.5' R0

+AT POWER TRAINING TIME EICEkSED OPERATOR INCLUDED

..(NILAND) 5.5 3.0 R0

• LICENSING TRAINING TIME ON SHIFT INCLUDED TOTAL-75.0 29.5

• • AWAITING NRC SR0 WRITTEN RESULTS.

PASSED NRC SIMULATOR AND ORAL EXAMS.

b' I

Y=Yes 3-N=No

. t O

~

~

"C" SHIFT NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND t

EXPER.

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT POSI'TIOil (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS SHIFTLSUPERVISOR~

(B0YER.)

8.5 2.5 SR0

+1.4 yrs.

Y Y

SENIOR OPERATOR (SMITH,D.E.)

14.5 4.5 SR0

+17 mos.

Y Y

SENIOR OPERATOR (FRASER) 8.0 4.5 SR0 0

N N

SENIOR OPERATOR (PAULES) 7.0 3.0 SR0 0

Il N

LICENSED CPERATOR

'(HEILMAN) 10.0 6.5 R0 8

4.0

.50 R0 i

LICEN. SED OPERATOR (GALLAGHER) 8.5 4.5 RO

+AT POWER TRAINING TIME LICENSED OPERATOR INCLUDED (BEZI,LLA) 3.5 1.0 R0

• LICENSING TRAINING TIME ON SHIFT INCLUDED LICENSED OPERATOR

(.fj00RE),

6.0 2.0 R0 Y=YES i

N=N0 TOTAL;j 70.0 29.0

a h-

.t.:.

s,.

s "D" SHIFT

I NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI

,1 POWER POWER

> 20%

STARTUP 7.;-

PLANT PLANT POWER AND 1

EXPER.

EXPER.

. OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT

^

POSITION (IN YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS i

SHIFT' SUPERVISOR (CROUSE) 17.5 9.0 SRO 4.16 yrs.

Y Y

SENI0hlOPERATOR SU-N

.(SMITH,D.A.)

11.0 5.0 SRO

+10 mos.

SD-Y Y

W-0 SENIOR OPERATOR (MARTIN).

9.5-5.0 SR0 0

N N

-.c '

SENIOR OPERATOR (DAVI5)'.

7.0 4.0 SRO O

'N N

~

LICENSED OPERATOR (GOO.D. LAVAGE) 10.0 6.5 R0 LICENSED OPERATOR (BUGELHOLL) 5.0 2.0 RO l

4, LICENSED OPERATOR (BIXLER) 4.0 1.5 R0 7

+AT POWER TRAINING TIME LICENSED OPERATOR INCLUDED (CAMPBELL) 5.0 1.0 R0

• LICENSING TRAINING TIME i~

ON SHIFT INCLUDED 34.0 Y=YES TOTAL'.

69.0

i N=NO

. 's.

k' f.;, '

z.

.V 1

.c.

i i

.y..

3

.OFF SHIFT PERSONNEL NUCLEAR HOT PARTICIPATION EXPERIENCE AT TMI d..

POWER POWER

> 20%

STARTUP PLANT PLANT POWER AND EXPER..,

EXPER.

OPERATION SHUTDOWN

• 6 MONTHS ON SHIFT

POSITION W.'. YRS)

(IN YRS)

LICENSE TIME EXPER.

AT HOT CONDITIONS

,(ROSS),

17.5 10.0 SR0

++5 yrs.

Y Y

JSHIPMAN) 12.0 4.0 SRO

+1 yrs.

Y Y

-JBOL,Z) 10.0 6.5 SR0 4.5 yrs.

Y Y

.,( KACINK0) 3.5 1.5 R0 0

N N

GWILT;)

4.5

.5 R0 0

N N

. TOTdL..

47.5 22.5

+AT. POWER TRAINING TIME ilNClUDED

++NOT INCLUDED 2 YRS. HOT OPERATIONS AT OTHER PWR.

• LICENSING TRAINING TIME:

J.ON.%HIFT INCLUDED

.'Y=YkS N=N07

?

3.-

r.*..

p

.. l" 9

i

.I

$ch.

e s

I, GPU Nuclear Corporation e PM tuclear

gges's48o Middletown. Pennsylvania 17057 717 944-7621 TELEX 84-2386 Wrrter's Direct DialNumber

March 28, 1984 Mr. E. P. Wilkinson, President Institute of Nuclear Power Operations 1820 Water Place Atlanta, Georgia 30339

Dear Mr. Wilkinson:

Enclosed is a status report of actions taken in response to the findings frcm the May 1983 INPO 'DII-l evaluation.

'Ib avoid the necessity to cross-reference hetaeen the status report and the Evaluation Peport you published, we have elected to include your findings and rwmerdations, our initial response, and the current status of the findings all in this one document.

Sincerely, kf.

P. R. Clark President PPC/HDH/pjl Enclosure l

cc:

H. D. Hukill l

l l

l l

l l

GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

f g*

-.a

., m.

~

Finding Increased eriphasis is needed on industrial c=.fdty. Although.

(OA.5-1) the established program is effective in correcting identified safety deficiencies, the trend of lost-time accidents has not inproved, and several evamples of lack of adherence to safety rules were noted. A cmpany safety manual has been under review for sme time, but has not been approved for use.

h - +ndation Upgrade the existing industrial safety program with ernphasis on the following areas:

timely on.u.vval and issue of ocznpany policies a.

regarding industrial safety b.

strengthened supervisory involvement in prcxnoting adherence to safe work practices inproved safety awareness and ocxnpliance with safety c.

rules by all personnel The need for 1rprovernent in the area of industrial safety

Response

had been remgnized, and several actions had been initiated to accarplish it. 'Ibese actions included the establishment of a 1983 goal of reducing the number of reportable and lost-time accidents / injuries by 25 percent frm the 1982 level and the preparation of a draft Nuclear Corporation Safety Manual, which is now under review by the operating carrpanies.

Subsequently, each department in the plant has been assigned specific goals for the reduction of accidents / injuries over the next six months. Progress in meeting these goals will be reviewed by senior management with the appropriate depart-ment head'on a periodic basis to measure effectiveness and to L@l - nt further actions when adequate progress is not being achieved. Trainincj of all supervisors on the contents of the revised Safety Manual and their responsibility for its inplanentation and the enforcement of safe work practices will be accmplished by September 1983. 'Ihis will be followed l

by safety training of all cmpany ertployees involved in l

industrial-related functions or who work h an industrial environment. Adequate safety training is already being conducted through the general suployee training and retraining programs for those individuals who are not normally associated with industrial work or environments.

l The @U Nuclear Safety and Health Manual has been approved Status and issued to all @U Nuclear enployees at the plant, including all supervisors. In order for this manual to becme the official safety guidelines for bargaining unit personnel (Met-Ed enployees), we need the union's acceptance, which can only be obtained through successful negotiations

- 1

9 0

s.

.c (OA.5-1 Continued) and ratification of an agreement mntaining a provision to adopt the GU Nuclear Safety and Health Manual.

Approximately 30 training sessions have been conducted for supervisory personnel on the mntents of the manual, and they have been instructed to use it as the basic guidance in planning and monitoring errployee work activities. In January 1984 the Safety and Health section of General Diployee Training (CET) was expanded to cover in more detail the Safety and Health programs at 'IMI.

In 1983 a goal to reduce the lost time and reportable accidents by 25% from the level in 1982 was established. An actual reduction of 21% was achieved. Ibr 1984, the THI-l goal is to further reduce the nunber of repri.able and lost time accidents by 10% below the 1983 level. In addition, a pr@uuu was initiated in late 1983 which requires that the individuals involved in a lost time accident, their imediate supervisor, and the on-site Safety Manager meet with the Vice President / Director TMI-l to review the accident and discuss measures that can be taken to prevent recurrence of similar type accidents.

e l

l l

l I

(

l l

l. _,

r.

~

'.... ~, ;g :.

.H..,

• x.-

g.;..,..y b :/.;

.y.

3._

Finding Vendor.techni~ cal. manual content', distribution, and use'are (OA.6-1)-

not rigorously bontrolled. Sczne manuals' marked " Controlled Copy" were noted in the plant without evidence of proper control. Scme maintenance procedures refer to portions of technical manuals for detailed work instructions even though the referenced portions have not been reviewed for technical adequacy.

l Roccamandation Establish improved control of vendor technical manuals to j

ensure they are ocuplete,and current.. Ensure that portions of manuals used to control work are technically adequate.

Response

A list of about 60 technical manuals, which were considered to be the most lupiant for plant operation and maintenance, has been selected for priority review and updating, including vendor participation as required. The revised manuals will be issued as " controlled rh =nts" using the normal M'=nt i

control system. This is a long-term project that may take two years to ocmpleto. Procedures are in place for the control of these manuals. All manuals that are currently in the plant will be stamped "for information only". As controlled copies frcan the initial list of 60 manuals are received, additional manuals will be selected for review and upgrading as part of this continuing program. When a manual has been issued as a controlled doctanent, all "information only" copies of that manual will be purged frczn the plant.

Maintenance Procedure 1407-1, Corrective Maintenance, will be revised by November 1983 to require that an engineering review be conducted of the applicable portions of technical marmla whenever technical manuals are used to control work.

Status All technical manuals in the plant have had the " Controlled l

Copy" stanp deleted and have been marked "Pbr Information Only" except for those revised and updated manuals that have been officially received frczn the Technical Functions Division.

l These updated manuals are marked " Controlled cbpy" and are l

maintained in the Maintenance Library. - As an adjunct to the program already established to upgrade technical manuals on a selected basis, we have in re.,guse to the NBC's generic letter on the Salem ATWS event, ocmmitted to reviewing and updating all vendor safety related th'wntation within the next three years. Contracts are scheduled to be'in place and work started on this effort by the third quarter of 1984.

Maintenance Procedure 1407-1 had been revised to require Engineerinct review of "Information Only" technical manuals prior to use. However, QA review identified problems in the inplementation of this ocmnitznent. The problems basically stemned from the fact that full and absolute conpliance with the ocxtmitznent would have placed an unrealistic additional l.

L I

3_

-~

.f.,',.

.y p.' ;...,, g..

. :., g,. c. f3

~ g,.

' ' ' ' r (OA.6-1 Continued) workload on the Engineering staff at the plant, which consequently would have resulted in a significant inpact on productivity with very little, if any, corresponding inprovement in the technical adequacy of the manual or the work being performed. We have, therefore, decided to revise the requiranants put into Maintenance Procedure

1407-1 to provide definitive criteria under which Engineer-3 ing' review is required. This. criteria will also be aMad to other appropriate procedures, such as those governing preventive maintenance and surveillances, so that standard guidance for use and review of technical marmla will be provided for all situations in which technical manuals will or could be used. The exact criteria is still being devalepad and will be based on the type of activity the technical manual will be used for; such that plant safety or operability types of information will require Engineering review, whereas use of technical manuals as general informa-tion and non-safety related work would not. Ibr exanple, the Engineering review might not be @ed when the technical manual is used for a relatively sinple disassembly of a ww#nt, but would be required for maintenance requiring specific bolt torques, lubrication requirements, tolerances, etc.

Efforts to revise procedures and iT =nant this new approach are underway and should be 1

ccmpleted by July 1984.

The entire subject of up-tcxiate and correct technical manuals is a major generic issue facing all utilities that will require a dedicated effort and considerable time to correct. In scxne cases the original manufacturer of a piece of equignent is no longer in business. Additionally, on occasion, even when a technical representative of a manufacturer is called on site to assist in the repair of a major wgent, he arrives with a manual admittedly out-of-date because the manufacturer has never updated it.

l GPUN is aggressively addressing this issue, but the solution of the basic problem as a whole is extranely difficult, and as noted above, will take several years to correct.

l

(

l-(

l l

I l

-4 l

.,ym s.,

.,g..,

J '.;.

.. s, i,,.. amf.

c s.

Finding Shift supervisory peisonnel need~to be more effectively

' (OP. 2-1) involved in routine operations activities outside the control rom. Although supervisory tours are conducted, routine activities of operations personnel are not consistently monitored to ensure conformance with station policies and good operating practices.

R===ndation sphasize shift supervisory involvernent in routine operations activities outside the control rom.

Response

h is is considered to be a significant finding and, as such, will receive considerable management attention. As noted, supervisory tours are being conducted, but the supervisors do not consistently and effectively monitor to ensure personnel conform with station policies and good operating practices.

The requirements for monitoring plant evolutions, and especially operator / maintenance technician performance and empliance with station policies and good operating practices, have been and will continue to be ernphasized to all super-visory personnel, especially the shift supervisors and shift foremen. In addition, the following actions will be taken in response to this finding:

Managers involved in the Off-Shift Tour Prwumu have a.

been instructed to review supervisor involvement in activities in the plant outside the control rom.

Ihis includes the requirement to actually a m ny the shift supervisor, shift foreman, and shift main-tenance foreman on their tours of the plant on a periodic basis.

b.

A senior, experienced former SPD-licensed shift super-visor will be assigned and report directly to the Operations and Maintenance Dir G r.

His primary reoggsibility will be to nonitor operations and main-tenance activities.in tha plant on a continuing basis.

This assigment will be effective by August 1983, c.

For at least the next one tc two years, a degreed engineer, in addition to the STA, will be assigned as a QA operations nonitor on a 24-hour shift assigment

. basis whenever the plant is critical. %ese nonitors will report to the QA manager on site and will be responsible for. monitoring and reporting plant operator and maintenance technician performance and adherence to high standards and good operating practices.

-l 3 m..

~

(OP.2-1 Continued)

Status

'Ihe need for shift supervisory personnel to be nere effectively involved in routine operations activities outside the Control Ibczn has and continues to receive considerable management attention. The following specific actions have been taken or are underway to directly or indirectly address this issue:

a.s Managers involved in the off Shift 'Ibur Pmp. u have been instructed to review supervisor involv ment in activities in the plant outside the Cbntrol IbcIn.

On many occasions the~ manager conducting the Off Shift Tour actually acompanies the Shift Supervisor /

Forman on his rounds of the plant. This requirement was enphasized by the Vice President / Director in writing to all managers and further discussed by him at a Plant Managers Meeting.

b.

A senior, experienced former SIO-licensed Shift Super-visor was assigned directly to the Operations and Maintenance Dirc, L.u. with the primary responsibility to monitor operations and maintenance activities on a continuing basis. Unfortunately, due to unplanned personnel changes, this individual was prcnoted to Radwaste Manager. To fill the gap created by his transfer, licensed SBos are being assigned to the position of Operations and Maintenance Supervisor on a six week rotating basis. The duties of this position will include monitoring operations and maintenance activities on a continuing basis, A degreed individual, in addition to the STA, has been c.

assigned as a QA operations monitor on a 24-hour shift assignment basis. Our conmitment is that this individual

(

will be on shift whenever the plant is critical; however, l

in practice, the position is being manned on a continual I

basis even with the plant in the cold shutdown condition.

i I.

l l

t 1

)

p,;.,.c

. Finding r

~.

Additional emphasis"is' needed."to' improve operator response.

to.equignent alarms, particularly those' outside the control i

(OP.3-1)

Equipnent is sanetimes operated with unresolved local roan.

alarms.

Recorax3ation Enphasize to operators the need for timely and thorough investigation of equipnent alarms. Increate supervisory involvement in shift activities to ensure that ala= on operating equignent are minimized.

Response

' All operators'will be reinstzlucted by October 1983 on the absolute requirenent for timely and thorough investigation, response, and reporting of equipnent and system =1==.

Supervisors have also been instructed to re-enphasize the 1 r@rtiance of proper alann response to their operators.

Although the acove action is needed and will be done on a periodic basis, the real key to solving this finding will be a continuing management enphasis that achieves direct, on-the-spot observation and instruction, as-appropriate, by the operators' first-line supervision.

Status All Shift Supervisors, Forenen and their crews have been instructed on the proper response to =1==.

'Ihis subject has also been included in the Operator Training Fr @ cus.

The actions taken to improve shift supervisory involvement in routine activities outside the Control Roan, as discussed in finding OP.2-1, should also result in inproved operator response to ala m outside the Control acom as a result of the additional scrutiny and on the spot management of the plant operators' activities.

4 i

4.

1

9-Finding Perfor!rance of independent verification of valve-position (OP. 3-2) needs improvement. The second verification of valve position is scznetimes performed by observing the first individual check the valve position rather than performing an independent second check.

W andation Revise current operating practices to ensure that the second valve position verification is acecriplished by an independent check.

Response

Guidance to ensure that the second valve position verification is a m H ahed by an independent check will be included in the next revision to Administrative Procedure 1029, Conduct of Operations. This procedure is currently under review, and the change should be issued by Septernber 1983. To ensure

~

this guidance is understood and is being followed, supervisors will be instructed to monitor selected valve lineup evolutions as part of their plant tours.

Status A revision to Administrative Procedure 1029, Conduct of Operations, which clearly spells out the requirements for independent verification of valve postion has been issued.

To ensure operators understand this guidance and are ccanplying with it, follow-on lineup checks are and will continue to be conducted by supervisory personnel for certain safety related systems such as the contairmnent integrity lineup.

l I

l l -

1 t

l l

l

y n..,.i

~-

., ~ Finding '.

" Operator and' supervisor-knowledge ~need'inprovement in sme

,(OP.4-1) areas. S ee auxiliary operators could not explain proper operation of the diesel engine support systes. Additionally, s m e control room operators and supervisors had difficulty discussing electrical distribution controls and using electrical drawings to analyze unusual transients.

P-ndation Inprove supervisor and operator knowledge in the areas l

identified above. Include these areas in the existing pre-startup training, program.

Response

Training in the diesel generator and its auxiliaries will be included in the training cycle for both licensed and non-licensed operators. Practical deonstrations will be included as part of this training. Also, training in electrical diagram and logic drawings will be included in the operator training program. The initial phase of these training modules will be conducted by Noverrber 1983.

Additionally, a joint review of the training piwima by the operations and Training departments will be cmpleted by June 1984 to identify any other general weak areas that are not currently covered by the training pi%iam.

i The Operations Plant Manual, which is currently under devalent, will provide a significant inprovement in ensuring that the operators are provided appropriate informa-tion and background for training in inportant plant systems and equignent. This manual is scheduled to be ocmpleted by January.1984.

Status Training on the diesel generator and its auxiliaries and training in electrical print reading have been conducted.

1 The Operations Plant Manual (9 volmes) has been issued l

and is about 80% c m plete. We anticipate that essentially l

all chapters in the manual will be ccmpleted and ire,rporated into the manual by June 1984. This mamsal represents a significant inprovment in training information/ aids for licensed operators, as well as other personnel who require plant systes training.

The joint review of the training r@ian by =+=rs of the Operations and Training Departments has been ocmpleted and a final repu.L issued. The r+ --Mations of the report are under review and those agreed to by management will be incorporated into the operator training programs by the end of 1984.

f -

V

...~

,' Finding Scme energency 'and operating procedures need improvenent to.

(OP. 5-1) enhance their usability. Sme cautions follow the action steps to which they apply, and sme notes contain procedural steps.

It is recognized that extensive effort has been made to inprove emergency and operating preadures.

E_-.. -ndation Durire normal review and revision of plant procedures, identify and correct the type of problems noted above.

Response

Administrative Procedure 1001D will be revised by October 1983 to include the requirement that cautions precede rather than follow the action steps to which they apply and that procedural steps are clearly indicated as part of the procedure and not contained in notes. Current procedures will be re-viewed for these conditions and corrections made as appropriate during the required biannual procedure review process.

Emergency procedures will be given priority.

. Status Administrative Procedure 1001D has been revised to clearly indicate that cautions precede the action steps to which e

they apply and that procedural steps are not contained in notes. Current procedures are being reviewed for these conditions, and corrections made as appropriate during the required biannual procedure review process.

&+

i l

(-

l l

l.

i i

! L

..,~....

.,

: :;u.x.'...

~

Finding Control'of maintenance activities needs improvement.

~

(Im.1-1)

Maintenance activities are not always formally dtv'-nted to reflect appropriate review and authorization of changes in work scope. QA requirenents, use of procedures and vendor manuals, and post-maintenance test requirements need to be established and a m = nted prior to continuing jobs with changes in work scope.

Pam==ndation Inprove control of maintenance activities. Ensure that proper review and approval by. appropriate managers is atv = nted for extended work scope.

Response

A procedure change to Maintenarce Procedure 1407-1 is being prepared to ir s prate the guidelines indicated below for reviewing and approving changes in work scope. 'Ihis change will be inplemented by October 1983.

Work done on an item will be limited to that which ' falls within the boundary of the instructions in the job ticket.

Additional maintenance work determined to be needed as a result of troubleshooting or the performance of the authorized work will be controlled by a new job ticket or by addition of the new work to the initial job ticket by the responsible manager or superviscr. In the event a change in work scope is added to the initial job ticket, it will receive review and approval appropriate to the new scope prior to comence-ment of the work.

Work on the backshifts will be controlled in the same manner, with the exception of emergency maintenance.

Maintenance procedure 1407-1 has been changed to irm.cu. prate Status

~

the guidance and direction indicated in our initial response to this finding.

> =., -

~t Finding The plant needs to improve the identification and processing

. (MA. 3-1) of deficiencies for corrective maintenance acti6n. Many valve, flange, and pump deficiencies are not included in the work control systs.

In addition, scrne caution tags identify deficiencies that are not included in the work control system.

E x--

• tion Develop measures to ensure timely identification and process-ing of plant deficiencies for corrective maintenance. INPO Good Practice MA-301, " Plant Material Deficiency Identification",

could be of assistance in this effort.

i F#.=ycise By January 1984, a formal systs will be established so that all employees, especially Operations Department perinusel, can identify material deficiencies and determine if the de-ficiency is covered by a job ticket or not. Pbr an interim period, a senior, experienced former SBO licensed shift super-visor will be assigned responsibility by August 1983 for monitoring general overall maintenance conditions in the plant and ensuring that material deficiencies are identified and job tickets are prepared as required. He will coordinate efforts between Operations and Maintenance, ensuring that the concerns of the operators are comunicated to Maintenance and that appropriate follow-up action is taken.

Status A pr%.m has been established whereby the Manager of.

Operations is provided a ocmputer printout weekly of all outstanding corrective maintenance job tickets categorized by equignent and system. This atmputer printout is main-l tained in the Control Room where it is used to confirm l

that a job ticket is in the system for deficiencies that are noted by the shift operating crew; or if a job ticket I

has not been issued for an identified deficiency, one is prepared. This printout provides the shift operating crew an up-to-date status of those deficiencies that have been identified previously and job tickets prepared. The printout has also proven to be very helpful in reducing the number of duplicate job tickets submitted.

T e

I l

f-9 t

J

. e Findingi

."'s Inprovement isineeded in warehousing practices to ensure

,y (MA.9-1) that 'the quality of stored itas. is naintained.. Storage requirements, preventive maintenance, and envirorrnental and shelf-life controls are not adequately inplernented.

W-ndation Establish programs that address storage requirements and preventive maintenance for stored equignent and material.

Upgrade existing efforts in the area of envirornnental and shelf-life controls. Ensure these programs inchxle materials in " direct turnover" status.

Response

The vacant position of' direct.cr of materials management has recently been filled by a highly qualified individual with extensive experience. One of his primary responsibilities is inproving warehousing practices at all three GPU nuclear plants. He has initiated devalmpmnt of a long-term master plan with milestone empletion dates for achieving these 4

inprovernents. The plan should be empleted by August 1983.

'Ihe iterns noted in this finding are all included in the master plan and should be essentially coupleted and in place by July 1984. Preventive maintenance (PM) requirements, where applicable, for spare parts are currently being in-corporated in the Maintenance Department's PM program. 'Ihis effort should be ocupleted and the PM program for spare parts inplemented by October 1983.

Status A Warehouse Reassessment Master Plan which addresses the concerns in the finding in addition to other needed inprove-ment items has been issued and inplemented. This plan integrates all required warehousing iliprovement iterns into l

a total program with milestone events and action items which are checked and tracked on a weekly basis for progress.

l See subject plan attached FAreto.

l I

6

'd - -..

~

~.

6:.'

.. ~. -

3..;.

_..,. ~..,

_ - ~...

' Finding

'Ihe. warehouse spare parts program does not_ fully suEport (MA. 9-2) the Maintenance Department. Problem areas include the following:

a.

Sme items for critical plant equignent are kept in uncontrolled shop and plant storage areas. Items are issued in standard quantities, and current pro-cedures do not provide for returning unused itens to inventory, b.

Cons==hla= required for the preventive maintenance program are not always available.

Maintenance Department is scnetimes not informed when c.

their rE - erdations for spare parts stocking are revised or disapproved. This scznetimes 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 tracking of spare parts inventory requests.

h-ardation Inplanent appropriate actions, including those listed below, to strengthen warehouse support of the Maintenance Department.

Upgrade the spare parts issue and return procedures a.

to am-.-- Ste returning unased items to inventory.

Provide for traceability and storage of usable equip-ment removed frcm the plant or equipnent obtained by P

direct purchase.

b.

Revise the spare parts provisioning W an to ensure Maintenance Department input in de+= mining itans to be stocked and stocking levels.

Inprove the H=al%ess of the review process for spare c.

parts inventory requests.

d.

In conjunction with b and c, consider a weekly status report to maintenance planners on outstanding purchase requisitions and spare parts inventory requests.

Response

Inplernentation of the rs-...+rdations in this finding are included in the master plan for upgrading the warehouse. 'Ihe specific responses and actions to be carried out with approxi- -

mate ocupletion dates are indicated below:

I The master plan will assess the needed process for a.

return of unused items to inventory and storage. In conjunction with QA and site Maintenance, an appropriate procedure will be established by January 1984.

l l

i

~.

-n:( g gI contin S ).

2 2

t - 'r T f:' M.J 'e ; -

if.

~

b.

Coordination with site activities will be expanded to ccroplement the existing PM pregram for early identification of PM consumable items. This, along with priority procurement action, should be in place and operable by Oc+rhar 1983.

c.

Current pKcidures (7231-WHP-6480) call for return to the originator of all revisions /A Awtuvals of spare parts stocking.re,--+ndations. Materials Management will take action to ensure full ocmpliance with the existing procedure and coordinate effectively with originators of spare part rar-nandations.

d.

Full inplementation of master plan actions, to be essentially ccmpleted by July 1984, should enhance warehouse support to site maintenance. 'Ihis involves inproved identification of inventory requirements and on-line access to status of purchase requisitions, purchase orders, and stores inventory.

Status A Warehouse Reassessment Master Plan which addresses the concerns in this finding in addition to other nee-kd inprove-ment items has been issued and inpleented. 'Ihis p2an integrates all required warehcusing improvement items into a total program with milestone events and action items which are checked and tracked on a weekly basis for progress.

See subject plan attached hereto.

I i

l l

l h

l

1 l-

.s.

~.-

m I

. (..;. '

- v (,.

Finding Th'e' operating experience' ~ review ' program should be inproved.

(TS.3-1)

Although sme vendor bulletins are currently being addressed, a cmprehensive prwimu is not in place to review and process appropriate vendor information.

Pa t-er.:1ation Modify the prwima 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 i=1a=nt a separate r%imu to ensure that vendor information is s p ly reviewed and processed.

Response

A procedure will be deva 1W that will formalize the process of reviewing and tracking action on information provided frm vendors. Special attention will be given to the results of the recently empleted Salem review in this area. This pr%sma will integrate the actions taken by Systans Engineer-ing, Engineering Projects, Plant Maintenance, and Plant Engineering on vendor information received fr a vendors, will ensure that it receives the appropriate technical review, and will ensure that applicable itens are sent to the appropriate department for inclusion in maintenance'and operating pro-cedures, design changes, and training, as required. The procedure for this pr%sma is scheduled to be inplanented by October 1983.

A revision has been made to Technical Functions' Procedure Status EP-017 which formalizes the review and inplementation of vendor technical information.

s s.

.s.,.

)

t ;. '. -' ' [:\\

..fa * ':.?.&.:(..a. 5.e..%'y v:."p@* '...u;. d, dificAtions;:are'; installed ;on operati...7 m y 15s

.: :.. -y y;.

.. :r. ;...

ng-F.

.ihding Sane +

(TS.4-1) systians without a technical design review. Procedure AP 1013 for electrical jutpers, lifted leads, and mechanical bypasses requires only a limited safety evaluation. It does not require technical design reviews similar to those per-formed for permanent modifications.

h -..+ndation conduct technical design reviews of electrical jumpers, lifted leads, and mechanical bypasses currently in place on operating systems. Inplement controls to ensure technical design reviews are performed on future 6 p rary modifica-tions prior to placing modified systems in service.

Response

A design review by Plant Engineering of electrical jutpers, lifted lam =, and mechanical bypasses currently in place will be conducted prior to restart. The procedure for installation of these devices will be modified by October 1983 to require the review and concurrence of Plant Engineering (an engineer in the applicable discipline) for all electrical jumpers, lifted l ada, and mechanical bypasses that are not already specifically approved by plant procedures prior to making these temporary modifications to in-service systems.

Status.

A safety evaluatiorv' design review has been performed by Plant Engineering of all eJectrical jutpers, lifted leads -

and mechanical bypasses currently in place for greater than one year. Plant Engineering has reviewed all electrical junpers, lifted leads and mechanical bypasses in place less than a year to determine which ones have to be removed prior to startup. For those that will remain, a safety evaluation / design review will be canpleted prior to startup.

Many of these have already been ecmpleted. Procedure AP-1013 has been changed to require the review and concurrence of Plant Engineering (an engineer in the applicable discipline) for all electrical jutpers, lifted leads and mechanical bypasses that are not already specifically approved by l

plant procedures prior to making these 6 @ rary modifications to in-service systems.

L

. L

l s

4

. *:., ;:fa...y: fQ.g

.;g..

g.

1 (TS. 4-2)

Plant personnel do'not always perform operability and main-tainability reviews. Designers smetimes fail to identify physical obstructions and structural restrictions.

h m.+ndation Ensure that plant modification designs are reviewed for operability and maintainability. Increase involvenent of operations and Maintenance personnel in the reviews. Ensure that reviews include plant walkdowns by designers prior to

, construct.. ion.

Response

Constructibility reviews have been held on 'IMI-l nodifications over the past year. A revision to Procedure EMP-014 was in progress at the time this finding was issued. The revision specifically calls for operability / maintainability /constructi-bility reviews of the nodification design when the engineering is at or near the 80 percent empletion stage. The operability /

maintainability /constructibility review meeting is designed as a multidisciplinary meeting held at the plant. The review is scheduled such that there is sufficient design material available to scope out the design change, but is early enough

~

to permit changes in the design, if necessary. ENP-014 will require an examination of the detailed design for operability and maintainability by plant personnel and a walkdown by the design engineers prior to issuing the modifications for con-struction.

The revision to EMP-014 is scheduled for issue by August 1983.

Status

'Ihe revision to procedure EMP-014 incorporating the cmmitments in our original response has been issued.

t O

~

~;.

v.;.

F - _. :,,Q. :;..l:'

l~ '?

, zw G.R., ?;c.':,.,;.sy. i' y '.:j. ; < ; ;,.

Q. :;

Finding.

Formal controls need to be established.for software develop-(TS.5-1) ment and revision on the ccuputer used by the nuclear engineer.

'Ihis ccmputer is used for inportant reactor physics em1mla-tions in support of plant operation.

hue.ndation Develop administrative controls for software develognent and revision.

Response

The need for more formally controlling the develognent,

~

revision, and use of cmputer software has been previously identified by Plant Engineering and listed as a Nuclear Engineering goal. A Plant Engineering Procedure, PEP-5, will be issued that inwrporates the guicance in Technical Functions Procedure EP-007, " Standard Ccmputer Program Controls". This will reflect current practices in software control and provide written guidance to help ensure that new p w - s and revisions continue to be handled in an appropriate manner. This procedure will be inplemented by December 1983.

Status A Plant Engineering Procedure PEP-5, Plant Engineering Ccuputer Software Control, has been approved and issued.

'Ihis procedure addresses current practices in software control and provides written guidance to help ensure that new programs and revisions are handled in the appropriate manner.

e T

i I

i

l

, //.. 9.,, < f - $.,. L..,W.,

,,,,. - ::,..s.

\\.,,,

,o

':., :. V

~

., _ ~

h.~,

,,.; H.

,e Finding Inp.mts are needed in the plant performance monitoring.

3

-(TS.6-1) program. Sme instrumentation used for data collection is not included in the surveillance or preventive maintenance ealibration programs. The responsibility for performing data analysis is not clearly defined. IHportant systs or caponent degradation may not be readily detected due to the time delay between data collection and transmi.ttal for analysis.

h - - --rdation Include instrunentation used for plant performance mcnitoring data collection in a routine r'al4bration program. Establish clear responsibilities for data analysis. Consider increasing the frequency of data L.awuittal for analysis to ensure sys-tem or emponent trends do not go undetected.

Response

he following actions are planned to address the finding:

a.

Instrumentation used for the Plant Thermal Performance Monitoring Pro tmu will be added to the Preventive s

Maintenance calibration Program by October 1983.

b.

S e responsibility for data analysis lies within the Technical Functions Division. Further delineation of responsibilities within h chnical Functions is needed.

Se Ebrmal Description (Engineering Standard) of the pro imu will be empleted by October 1983 and will v

specify the responsibilities of the Plant Analysis section, both on site and at Headquarters and of other Technical Functions sections.

c.

he intent of the Plant Performance Monitoring Pregimu is to detect changes in plant or equignent performance that are slowly developing in nature. Plant degrada-tions that are rapid in nature would be detected by normal Operations Department watchstanding practices, by STA nonitoring, and through the use of plant an-nunciator and cmputer-based alarm systems. In addition, Operations engineers perform a daily review of plant operating logs.

l l-Plant data are analyzed on a monthly basis. his fre-l quency ensures the availability of sufficient data to clearly define a trend. This frequency is supported by one year's experience gained through conduct of a per-formance monitoring program at GPU's Oyster Creek Nuclear Generating Station.

L l

Re Plant Analysis Section will require the Plant Per-l formance Monitoring Program to identify desired program enhanc m ents on a refueling cycle interval based on actual 'IMI-l experience. ~ The frequency of data analysis will be included as part of the cyclic review.

L l _

3,

,, C ;,.. c.,..

......., :. e *... N.,., w..

. <... c..

/p.- : p;.:~ 3'.

s,"f...

(TS.6-1 Continued)

~

~

,~,.,.

s Status Instrumentation used for the Plant Performance Ibnitoring Program has been identified to the plant by the Technical Functions Division and included in the Preventive Main-tenance Pr%uun. A Technical Data Report &v'_= nting methods and rs=y,isibilities for producing the 'IMI-l Plant Performance Report will be issued by April 1984.

O e

"4

.;. v:,..:

,...u..

v:. ~,

.~ v.

• a 7,. *,

• r:

~

',,, y. 1

=

. ~. "

\\ ~ :.:.;.

Finding Inprovem2nts are needeEl in the on.tNe-job training. (03T)"

(W.3-1) program for licensed operators. Although good 03T 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 03T task or checkout.

h - ardation Develop guidelines for actions, knowledge, and skills required for successful ocmpletion of each 03T task or ctht. INPO Good Practice 'IQ-501, "Develegnent and IT =nantation of On-the-Jcb Training Pr@i.

", may be 1

of assistance in this effort.

Pesponse A special review team consisting of licensed operators and personnel frcm the Training Department has been established to review the entire operator training prw2.mu.

Improvement of Q3T guidelines and procedures is a specific area being reviewed by the team. %-501 is being used as a guideline in performing this review. W e results of this review are expected to be available in August 1983. The target date for issuance of revised guidelines for 03T checkouts is January 1984.

Status The Replacement Operator Training Program has been revised and is in the final stages of management approval. It includes guidelines for actions, knowledge, and skills required for successful ocmpletion of each 03T task or checkout. He rex- +rtaations of the Operator Training Review Team (discussed in our initial response) were included in the revised 03T guidelines. S e Review Team r+>----rtaed that some additional O]T requirements be added and that redundant requirements be deleted. INPO Good Practice W501 was also used in developing the new 03T guidelines. Se revised Pap 1===nt Operator Training Program has been inplenented for the Replacenent CRO class which comnenced in February.

e 22-p m

r w,-i e,

s.v..e.

,,,.e

+ -, - -. - -

~...q:

h

=,*

• :.s':

,s.

J' 1

.r.'.. Mr j...

I

,. Finding Mechanical,~ electrical, instrument', and utility maintenance (70 5-1)

- personnel need initial training in basic maintenance funda-mentals or plant systems prior to job assignment in the plant.

h-. andation Provide systems overview and maintenance fundamentals training to all personnel prior to their assigment to in-plant maintenance duties. Evaluate the existing skills and knowledge of experienced per u El entering the maintenance force, and provide initial training as necessary. INPO dr==nts " Guidelines for Mechanical Maintenance Personnel Qualification" (GPG-05), " Guidelines for Electrical Main-tenance Personnel Qmlification" (GPG-07), and " Guidelines for Instrument and Control Technician Qualification" (GPG-08) oculd be of assistance in this effort.

Response

A pr@ tau will be devalepad by January 1984 to provide training in generic maintenance fundamentals, basic plant systems, and administrativa requirements to newly hired utility personnel prior to independent job assigranent in the plant. Craft-specific training will be provided when an individual advances frcan the utility classification to a craft (mechanical, electrical, instrument) classification.

Provisions will be included to allow personnel with prior training and experience to be exerrpt frczn portions of the program based on denonstrated knowledge level and performance.

A program for plant familiarization,and procedural training for those individuals who are hired directly into a higher classification will be devaltv=d and inplemented by January 1984. In addition, the knowledge and skills of such individuals will be evaluated to determine if any remedial l

training in maintenance fundamentals or craft skills is needed, and such training will be e m lished prior to iwlanandent l

l job assigment in the plant.

An indoctrination prwsmu has been devalq=a that will be Status l

given to all entry level and selected other I&C, Electrical, Mechanical and Utility enployees upon initial assignment to the Maintenance Department. This prwsma is 10 days in length. The first class ocnnenced in March 1984 and included as a minimam the following topics:

L Blueprint Reading i

Schenatics and Symbols Shop Math i

l Measurements Hand Tools a:xi Portable Power Tools Procedures l '

.:.p,....

.y.

c,

.. j..

(W.5-i continued)

Cranes and Rigging Safety (Fall Protection, Hard Hats, Scaffolds, Ladders, etc.)

Primary Systans Overview Secondary Systens Overview Electrical Systems Overview First Aid' Craft-specific training for an individual who advances frcm the Utility classification to a specific craft (Mechanical, Electrical, Instrument) classification will be included in the Q3T program which is being developed and will be inplement-ed in August 1984 (See W.5-2).

t i

l l

i l

I 1

I l l

]

y. -

s.

y-

.v Finding m for mechanical, electrical) and utility maintehance

('IQ. 5-2) personnel needs inprovement. M tasks and checkouts have not been established to ensure that these personnel are appropriately trained or evaluated in required skills and knowledge.

hx-. andation Develop and inplement a more structured m pr%tmu inmrporating the following:

'E

' aC. identification of tasks to be pesivuu d, sinulated, or discussed b.

identification of individuals or classifications of individaals qualified and responsible for conducting m

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 demonsi r.ated empetency in specified tasks prior to job assign-ment t

'Ihe existing minor maintenance qualification sheets, which l

document,m g wncy on selected minor' maintenance tasks, could be expanded to th'==nt atmpletion of M.

INPO Good Practice 'IQ-501, "Devel===nt and Inplementation of On-the-Job Training Programs", cx:nld be of assistance in i

this effort.

Response

A nore formal and structured a pr% mu for mechanical, electrical and utility maintenance personnel will be developed and inplemented by August 1984. '1his prwimu will include the r+,-... -Mations listed above. -

I Status A schedule has been prmulgated and actively pursued to develop and inplement a nore structured and formal m l

program for mechanical, electrical and utility maintenance personnel. By August 1, 1984, we expect the pr% &ma to be fully developed and initial imn1===ntation started.

t W

h l r

I

~

-~

' l..'v :.

-,y, i

.t.-

.a.,4 f -

.,]

f...

s Finding

- Inprovements'are needed in the study'and reference

('IQ. 9-1) material available for use in systems training. Existing system descriptions are out of date. The plant is aware 7

of this situation, and an Operations Plant Manual is being written to provide updated system descriptions.

Pam-nandation Oamplete the devalmnant of the Operations Plant Manual.

IT== ant a process to ensure that the newly deva 1 W 1

~

material will be kept updated to' reflect system modifications.

Response

'Ihe Operations Plant Manual'is scheduled to be ocznpleted by January 1984. A specific individual has been assigned as coordinator for this manual, with an individual " owner" assigned to each section. It will be the owner's res-ponsibility to review periodically and update his/her section of the manual in accordance with a specific schedule.

Individuals using the manual can re-ad changes, as appropriate, by sinply contacting the owner of the section involved. Updates required due to modifications to plant equipnent/ systems will be formally controlled through Administrative Procedure 1043, Control of Plant Modifica-tions.

Status As noted in Finding OP.4-1, the Ogsations Plant Manual (9 volunes) has been issued and is about 80% ocmplete.

We anticipate that essentially all chapters in the manual will be ocmpleted and incorporated into the manual by June 1984. A system is in place to keep the manual updated to reflect modifications made to the plant.

1 l

I "D-

...l...

q._.

..,.; 7 Finding The criteria used.for extending radiation work permits (RP.1-1)

(IEP) is not sufficiently defined. Most routine IUPs are extended for seven days without a requirement to resurvey areas on a routine basis to ensure that radio-logical conditions have not changed.

I h ndation Provide additional guidance in the IMP procedure on extending IMPS. Establish resurvey requirements for extended IMPS.-

Besponse The PNP procedure is being revised to include criteria i

for extending IMPS and the requirement to resurvey extended IUP work areas at least every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Additionally, the procedure revision will require that copies of extended IEPs De placed at a discrete location for daily foreman review. The revision to this prdwe will be inplemented by October 1983.

Status The actions necessary to correct this finding are considered cmplete. The IUP procedure (RCP 1613) has been revised such that 1EP's are Irrmally written for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

Specific supervisory review and approval is required to extend the use of these PWP's.

In no case are IMP's allowed to be in effect greater than 7 days. On a daily basis =11 IMP's worked are evaluated by supervisory personnel relative to the need for further radiological evaluations.

l

~

\\

r

r-

...c

'y e

• ?

...:n.

,, _.J...,..... ;. s..

Finding The station AIARA p'rogram has not-been ful'ly' imp _lemented. -

(BP.4-1)

Additional items needing implementation are as follows:

man-rsn estimates and exposure goals for specific a.

jobs b.

man-rem action levels requiring post-job reviews Rec.umerdation Cmplete inplementation of the station AIARA pr%

by addressing the areas noted above.

Response

he following actions are planned to address the finding:

Radiological Controls will expand efforts to establish a.

~

man-rem estimates and goals for specific low level exposure work. This will be a g lished through increased use of the man-rsn estimate section of the IMP and/or AIAFA reviews, coupled with inplementation of an Exposure Tracking Number (EIN) systan. This effort is expected to be cmpleted by November 1983.

b.

Se AIAFA procedure will be revised to include guide-lines for determining when a post-job review is required. The revision to this procedure should be irmism=nted by November 1983.

he actions necessary to correct this finding are currently Status being implemented. A major revision to the AIARA procedure (PCP 1651) has been subnitted which incorporates the AIAPA review and person-rem estimating of all radiological tasks expected to expend greater than.5 person-rem. The pro-cedure change also establishes post job review criteria based upon deviation frcan estimated to actual person-rsn and total dose expenditure. EIN numbers are currently being assigned to all Unit 1 BWP's which undergo specific AIAPA review. EIN numbers will be assigned to all PWP's generated following the installation of the emplete EIN library and cmpletion of appropriate technician training. The l

l cmpletion date of this item is projected to be April 30, 1984.

i

.v,z :;,; - '

r:,. :..~;.....

e,;

__..g_.._

Finding

'Ihe' quality coritrol prog,, ram for' the new thermolumines~ cent (RP.8-1)

~ dosimeter (TLD) system does riot include spiked TLDs whose identity is unknown to personnel performing the analysis.

Recmuendation Expand the existing dosimetry quality control program to include spiked TLDs whose identity is unknown to personnel performing the analysis. Develop acceptance criteria for j

the accuracy of these anci= ter results, and evaluate u

cases where acceptance criteria are not met.

Esponse The existing TID quality control prwimu will be expanded to include use of spiked TLDs, whose identity is unknown to personnel performing the analysis, on a periodic basis in addition to the use of known spiked TIDs as is presently done. Acceptance criteria for dosimeter results will be established that include appropriate evaluation and action when the acceptance criteria are not met. These actions will be cmpleted by November 1983.

Status A dosimetry procedure is being written to formalize the existing Panasonic QA/QC Program, which will meet the requirements of the National Bureau of Standards Laboratory Accreditation Program for Personnel Dosimetry Processors.

'1his dosimetry procedure will be empleted by May 31, 1984.

In the iterim, the blind spike program previously used for the Harshaw System will continue to be used for the Panasonic TIDs. This test achieves the QA/QC criteria required for a blind spike prwima..

i l

I i

l-l i

~

t t

I

. l

-~

.c, -

,y S.,.. i.

9. y

' Finding Inprovements are needed;in th5 self-reading pocket

~

(RP. 8-2) dosimeter (SRPD) program. The following areas need inprovement:

a.

the identification of faulty SRPDs when there are unfavorable conparisons with TIDs b.

the criteria for investigating the results of ocm-

=r4 ens between TIDs and SRPDs the cause'of the high percentage of SRPDs that fail c.

the calibration check h- - --dation Revise the SRPD program to include the following:

Issue SRPDs to workers by serial number. Perform a.

ealibration checks on SRPDs when unfavorable ocmparisons with TLDs occur.-

b.

Iower the threshold and acceptable deviation per-centage values for SRPD and TID conparison.

Establish operating histories for SRPDs and remove c.

problem dosimeters.

INPO Good Practice EPN-03, "Ca parison cf Dosimetry Results",

could be of assistance in this effort.

Response

h following actions will be taken to address the finding:

By November 1983, SRPD issue by serial axober will a.

be examined, and inplementation of this p%mu will be made if it is determined to be efficient and useful.

b.

'Ihe existing criteria for SRPD/ TID ccuparisons will be examined by Novenber 1983, and'necessary corrective action will be initiated.

The performance test failure rate of SRPDs will be c.

reviewed on a periodic basis and corrective actions I

taken as necessary.

Status

'Ihe issue of direct-reading pocket dosimeters (DRPDs) by serial number to individuals was examined for feasibility.

Based on a preliminary evaluation and review ccmpleted in j.

i.--

r& ler 1983, the following actions are being taken:

l On a trail basis DRPDs were permanently assigned by serial number to Radiological Controls Field Operations personnel in 'IMI-l and 'IMI-2 for tso months on March 1, 1984. Also, DRPDs were permanently assigned by serial ;

s 5-g.,:

i....;..

' -. +..'c. g_.

sh,~:s ;. :

-y ;,._, :.:. ;.,

.,. ;q (RP. 8-2 Continued) nurrber to individuals working on the 'IMI-l reactor coolant purp. 'Ihe administrative and tecimical problems encountered during the above trials will be assessed to determine the feasibility of permanently assigning DRPDs to other indivirhiale. 'Ihe DRPD/ TID

, ratios noted during the above trials will be evaluated to assess the inpact of and need for changing our current ocmparative criteria.

G e

e e

e e._.-

4 r

Y

".m ' '.;-,

' ) >?.

,a m'

s Finding,

Supervision of ch mistry technicians needs strengthening.

(CY.1-1)

The chemistry forernan assigned to supervise chemistry technicians is also performing other responsibilities that require significant amounts of time and limit his attention to laboratory activities. As a result, chemistry technician activities are not always prioritized or moni-tored for optinum use of technician time.

M -- =4ation.

Initiate appropriate actions'to improve supervision of chemistry technicians.

Response

The ability to provide additional supervision of technician activities has been strengthened by the following actions:

Additional clerical support has been assigned to a.

assist the chemistry foreman responsible for technician activities.

b.

An additional chemistry professional was hired to provide technical support for laboratory activities, including procedure review and preparation, and instrment installation, calibration, and trouble-shooting. The foreman previously responsible for this work will be able to devote more time to techni-clan supervision.

An additional foreman on terrporary assigrrrent from the c.

- Training Depart 2nent will provide additional super-vision throughout the restart program until one additional chemistry supervisor is hired.

d.

The assigment of additional first-level supervisors is under consideration.

%e addition of another first-level supervisor (Chenistry

. Status Foreman) is currently being actively considered to provide additional control of technician activities and to support i

the transfer of effluent analyses frm Radiologicd Controls f

to Plant Chenistry.

t l

2 e actions taken as described in our initial re. p have allowed the Chemistry Foreman to spend approximately 50% more thne in tha 3aboratory supervising the technicians.

The additional clerical support provided resulted in considerably less administrative effort required of the foreman, and the addition of a professional chemist relieved the foreinan of special project work and Operations l'

Department interface duties. W e additional foreman who was on tw ary assigment frm the Training Department r

w tLing the Plant Chemistry Department.

is no longer su o

I'

-..e

1,

?.'

,. ~

4.

'~: & *..q '.&[ > * *.~;,,. ;.. :...'; u np.: :yy.n.s.u.g....;

_. l Finding Coordination of activities betweennon-site and.off-site (CY.1-2)

Chemistry Departrnents needs strengthening. Ebr example, the preparation and approval process for. station chemistry procedures is not always timely and scunetimes results in procedures that are unnecessarily cx:rnplex. Also, the installation and calibration of new analytical equipnent are not always timely.

E ---- =Ation Inprove the coordination of activities between the on-site and off-site Ch mistry Departments including addressing the items noted above.

Response

GPU Nuclear Corporation will continue to refine the chemistry assigrinent matrix so that the responsibilities of all affected parties, both on-site and off-site, are clearly defined and understood. A monthly chemistry management meeting is beirx3 conducted at which major problems and interface difficulties are discussed and resolved. h is meeting will also be used to focus attention on and eshh14=h priorities for the support needs of the plant to meet the chemistry upgrade ec= dure review sucss will be program schedule. The r shortened by issuing drafts for review, and then m114ng all rwycnsible reviewers to the site to witness prMwe per-formance and provide final concurrence.

Status ne coordination in the chmistry area between on-site and off-site parties has improved mnsiderably. Responsibilities of all affected parties are reasonably well defined and better understood now that we have had ample time to use and exercise the responsibility matrix. S e extensive prtr#we rewrite pro mu that was on-going in May 1983 v

has been cmpleted, so we are now using our normal procedure review process which is adequate for the present volume of new procedures and procedure changes generated. Monthly meetings, as well as daily ocxmunications,.between Plant Chmistry and Technical Functions are still being conducted to ensure close coordination and definition of responsibilities

.between the two organizations. These meetings and cmmunica-tions are also used to identify arm.vant actions and assign priorities.

s.

r.

. - ~ -.

l

++,;*,.

.k

,~

.h*

+

: r..

,, 4.,

r. r.,t Finding Chmiistry technicians need additional training in (CY. 2-1) fundamental water chmistry and plant systars knowledge.

h.umendation Assess the knowledge level of individual technicians in the areas noted in the finding, and develop a train-ing program to correct identified deficiencies.

E pdnse The ch mistry technicians knowledge level in the area of fundamental water chmistry and plant systems will be assessed by written and oral examination by October 1983.

Deficiencies in knowledge will be corrected through train-ing provided by the training nodules already _ developed.

Experienced technicians with demonstrated knowledge level and practical ability will be reassigned to shift coverage to better utilize their level of knowledge and to conduct QTf for the new technicians. A schedule for training chemistry technicians to inprove deficiencies identified by testing will be provided by Deceber 1983.

Status In the last quarter of 1983, all "A" Chemistry Technicians were requalified in accordance with the 'IMI-l Plant Chmistry Procedure for technician qualification (N1836).

Requalification consisted of (1) a written examination (including questions on Technical Specifications, plant design and processes and chemistry and radiochemistry analyses), (2) an oral examination on selected plant systes (including a walk around) and (3) the performance of each analytical procedure by each technician in the j

presence of a chemistry supervisor. As a result of the l

requalification prwimu, it was noted that no significant difference existed between the knowledge lentel of the i

experienced (operating plant) and the newer technicians.

The reas igment of technicians to provide a better dis-(

tribution of experienced technicians was, therefore, not considered to be necessary. 'No experienced technicians are currently assigned to daylight only shifts to provide greater support for new equipment (Ion Chrtmatograph, Total Organic Carbon Analyzer and Graphite Furnace) and radiochemistry counting. 'Ihc results of the written examina-tion have been analyzed and a training schedule has been established to upgrade technician knowledge in areas of denonstrated weakness. 'Ihe training will be provided as part of the cyclic training pr@imn.

l '. -}, %; :..*;.i!.l';N ki

. q.;.. $.

-%.'w,n, <).;_ w.,[,.f,. ;..

1y.

.. ;3. %.:.. '.. '

. _. ~,

.;..l

{

c Finding.

Iaboratory work areas are not Olways maintained in (CY.4-1)'

accordance with good housekeeping practices. Work areas l

were dusty, and countertops were cluttered.

h " -dation Provide more enphasis on laboratory housekeeping practices.

The chenistry laboratories should be kept clean and un-cluttered to provide an atmosphere that promotes optimum analytical accuracy.

ansponse-mre emphasis is being placed on laboratory housekeeping practices. The inportance of good housekeeping practices has been reemphasized to all Chemistry Department personnel.

Chemistry Department managers / supervisors have been instructed to mor.itor housekeeping practices on a continuing i

basis and to L= =11ately take appropriate corrective actions when housekeeping is found to be deteriorating. Monitoring of the laboratory since the evaluation has not identified housekeeping as a continuing problem. Dust in the labora-tory is due to an inadequate ventilation system filter.

An engineering project to investigate ventilation system inadequacies will be initiated in 1984.

Status As noted in the initial response, continued enphasis is being plaml on good 3aboratory housekeeping practices.

However, due to the limited space available in the laboratories and the need to locate the numerous new

" state of the art" equipnents that have been purchased recently, the countertop space available to the technicians i

is severely limited. This limited Gork space gives the laboratories the appearance of being cluttered. A major expansion of the chemistry laboratories is.the only real solution to this problem. This will be evaluated, but in reality may not be feasible in the short term or desirable due to overall space limitations and time / cost

~

considerations.

A Technical Functions Work Request has been sulznitted to review the primary and secondary laboratory ventilation and environnental control systems and to design necessary I

modifications to reduce contaminants (dust) frca the air i

and provide better tenperature control.

l l

k r.

. 3.... -

> y.y:,...

's s

Finding Safety practices associated with chemistry activities i

(CY.5'lf need'inprovment. Eating, drinking,.and smoking were 1

observed in the secondary laboratory where poisonous 4

chemicals are stored arxl handled. In addition, safety 4

1 equignant is not always used or accessible.

h - -.+r.3ation Place more attention on chemistry and laboratory safety j

practices. Eating, drinking, and smoking should not be i

allowed in the secondary laboratory. Keep the areas around safety equipnent 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 working in the laboratory.

Response

All chemistry managers / supervisors have been instructed to be alert to initiate inmediate corrective actions for laboratory safety deficiencies and unsafe practices.

Obstructions to field safety equignent, as noted during the evaluation, have been removed.

There currently is not adequate space available for a separate eating, drinking, and smoking area in the close vicinity of the secondary laboratory. As an interim measure, a specific location will be established within the laboratory where the technicians will be permitted to eat, drink, and smoke. Chemistry analyses will not be perforned in this area. As a long-term solution, a project is currently being evaluated for inclusion in the 1984 capital budget that will modify the rad con /

chemistry work areas and provide a space that will be adequate for both radiation technicians and chemistry technicians to eat, drink, and smoke.

i i

Status All eating, drinking, and smoking in the secondary laboratory has been stxspped. An alternate facility near the laboratory has been provided for these purposes.

Chemistry managers and supervisors are reminded on a periodic basis to be alert for laboratory safety deficiencies and unsafe practices and to initiate im arliate corrective actions as appropriate.

l l

l l.

i. -.

~

I 4

.g.,;,,,g,,,j,-

g.,.,,,,,

y..s.'e:m.p :,,.;

,.i....p,j,.

. SIM4ARY OF Ot7tSTANDING RESPONSE AC'fICH FRCH PREVIOUS EVALUATICH (1981)

Finding Written qualification ' requirements are current for supervisory i

(OA.3-1) and technical positions. Ibr positions below first-line j

supervisors, the qualification requirements need updating.

E-x -+rdation Update and maintain current job specifications for appropriate positions below first-line supervisors. INPO is coordinating an industry-wide job analysis project for certain operator, maintenance, and technician positions. GPU may wish to utilize the results in defining qualification regairements for applicable TMI positions.

I

Response

GPU has been involved with EEI efforts on validation of job requiranents for power plant personnel. GPU will be using that effort ard the referenced INPO-led effort in the develop-l ment of new job specifications for nonexempt personnel. The revised job specifications and a procedure tz) maintain these 1

current are scheduled to be ocmpleted by %21982.

Status Supervisory and non-supervisory exenpt job specifications (May 1983) have been updated, and a prof.-u is in place to continue updating as changes occur. Action for exenpt positions is considered ocuplete. The nonexenpt position specifications are subject to union negotiation and have not been approved.

However, since a new union contract was recently sigped, the negotiation and approval of these pbsition specifications are expected to be ecmpleted in the near future.

Most of the critical non-exenpt job specifications have been Current Status (March 1984) rewritten and negotiated with the union since this finding was originally written. We have in place updated specifications for Rad Con Technicians, Chemistry Technicians, IEC Technicians, and Operations Technicians. We still need to negotiate new job 2

specifications with the union for Mechanical and Electrical Maintenance Technicians and upgrade mode of progression re-quirements for Auxiliary Operators to incorporate requalification requirenants. These efforts are included in the THI-l Division's 1984 Goals. Formal union negotiations are not sc @ lad until 1985 to coincide with the expiration of.,the ctu rent agreement, and our progress on these itens v311.d:2perd on the union's willingness to discuss these items outside of formal negotiations.

The required action to update supervisory and non-supervisory exenpt job specifications is cx:nplete.

T.

Es.,

... ;-y... 4 /, e C.v.,,,,

q.d,,u

j. n,;.. t :. _. ;,

,i,

,j g,... ;;,.,, y ;,..,..;,

e

.. Finding,

Plant operators are not,able readily to determine s e e (TS.'4-1).

syst e configurations"with'available drawings. '1he current system of revising drawings and maintaining accurate informa-tion in the control room is adequate. However, systems that were modified prior to the new drawing control p wcedure 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.

Roccanandation

'1he program to update drawings used by operators should be continued to ecmpletion.

Response

GPU will have baseline ergineering drawings essential for plant operations updated and in the control roczn prior to restart. Review of all old nodification packages, which predated the new control procedures, to ensure that previous modifications are properly reflected on the drawings will be ocupleted by the end of 1982.

Status Efforts are progressing to update drawings for 237 modifica-(May 1983) tions processed under the old change nodification program.

Currently, 193 of the modifications have been installed, 156 walked down by design drafting, and 44 have not been insta11ma. Drawings for all 193 modifications installed will be updated by the time of restart. Drawings for modifications to be installed under this pr w n in the future will be revised as the modifications are installed.

'1his item should be ocmpleted by _ restart.

Current Status Drawings for all 193 modifications have now been updated.

(March 1984)

Drawings for future modif,ications will be revised as the modifications are installed.

l L

~

= -.

' +. -.;,-G

.q..

' Finding Inproved controls are needed to ensure piping system (TS. 4-2)

' mechanical stresses are.not changed without appropriate engineering review. The use of lead blankets around system pipes for shielding purposes should receive a technical review prior to each installa, tion; 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.

b - - -rg3ation Ccuplete the engineering evaluation of lead blankets currently in place and develop a prug.am or guidelines to control the future placment of terrporary shielding on plant piping systes and equipment.

Response

his problern had been identified by the plant staff earlier this year and engineering guidelines are being developed to cx>ntrol the placement of lead shielding on or in the vicinity of piping systems and equignent. Wese guidelines will be inplemented by April 1,1982. To correct the innediate problem, a radiation survey of the areas where lead blankets were installed was conducted. As a result, a large amount of the 6p u ary shielding was removed due to reduced radiation levels because of the long period the plant has been shutdown. An engineering evaluation of lead blankets still installed will be carnpleted arxl appropriate nodifications made before restart of the unit.

Status Sczne temporary lead shielding is still in place on plant (May 1983) 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.

S e draft procedure appears to provide the necessary guidance and to require appropriate reviews to control future use of led chielding.

Current Status An engineering evaluation of all taporary lead shielding (March 1984) in place on plant systerns has been conducted. This evaluation determined that much of the tenporary shielding must be rernoved prior to restart. 2 1s has been a m lished for

~

the most part, however scrne shielding has been intentionally left in place and will not be renoved until just before restart. This shielding is clearly identified and tracked in the Master Bestart Prerequisite List to ensure it is, in fact, removed prior to restart. A procedure has been issued to control the use of tsporary lead shielding on plant systems in the future.

'w..-

,.. r,,.: 7. s,,.,,,..g.;. g s..

.g g,,,,,g,,

p Finding A training' program for middle-level managers in plant

[

systems and technology is.needed. Currently,' such I

('IO. 2-1) courses exist for individuals at the operator / technician level and at the senior managment level. However, individuals in positions between these levels receive no such training.

l W ndation Provide plant systems and technology training to middle.-

level managers. Existing programs for personnel at operator / technician 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 t.circlogy is needed.

A specific course on pressurized water reactor (PWR) systes and technology is under developnent and is scheduled to be available in July 1982. Attendance at this course, or portions thereof, will be determined on an individual basis taking into consideration the background, work assigments, and professional develop-ment objectives of the individual enployee.

Status A course in plant systems and technology has been (May 1983) inpleanted for corporate and site managers. When this initial course is ocupleted in the fall of 1983, it will be nodified based on fe<-k frca attendees and an assessment of the needs of middle management.

The modified course is rxpect d to be in place and offered to managers by n.,=4 w 1983.

Current Status The course in plant systes and t=c2Eclogy for co;;porate and site engineers was given to those selected to attend (March 1984) by responsible managers in 1983. The response to this course by those attending was very positive. A course has been developed for middle-level managers. 'this.

ocurse was prepared using a ocubination of the material presented previously to senior managers and that presented in the plant systes and technology course for engineers.

The availability and contents of this course will be made known to senior nanagement, and it will be presented when the ntuber of requests for individuals to attend sutnitted by senior management so dictate. It is already planned to conduct this course for selected managers, including some directors, from the '1%chnical Functions Division later this year.

O 40-

_e_

,-..w r-,...,

..,.,,.-.,,.,--_.,--.,-..-.,_,.~-._-,.-~-m-

~

.. y,.

,...,....;.. L, ~.. g,7,:

.s

~

SOER STATUS

• Per your request, the status ob each reccmnendation listed in the'"pending -

awaiting decision" or "perding - awaiting inplementation" is indicated below:

PEDING - AWAITING IECISION SCER Number Reocenendation Number (s)

Status 81-6 2

Pendirg 81-8 1, 4 Pending 81-15 la, lb Pending 81-16 1, 3 Ctztplete 82-7 1, 2 Pending 82-10 1,2,3,4,5,6,7 Ocmplete 82-11 5

cmplete 82-12 1

Pending 82-13 1, 3, 6, 7 Pending 2, 8, 10 cmplete 82-15 1, 4 Cmplete

~

82-16 1

Cmplete 83-1 1, 2, 3, 6, 7, 10, 11, 12 cmplete 83-8*

1 - 10, 12 Cmplete n

Pending

• Red Tab PENDING - AWAITING IMPIDEtTIATION SOER Number Recm1mendation Number (s)

Status 81-5 4

Pending 81-6 1, la Perding 81-10 1

Pending 81-15 2c Caplete 82-8 1

Pending -

.,..;. Q,.f.,. :.,, ; 3. ~ e : *r, f,.,,; ; ;.,.,.j,,.,..

,.,. 7,,.

,,..,,.,,,.,,,,,,y,,,

,i...

PENDING - AWAITING IMPLEMENTATICE (CCNTINUED)-

SOER Number Fs.ume.ndation Number (s)

Status 82-11 1,2,4 Cmplete 3

Pendig 82-13 5, 9, 11-Pendig 12, 13 Omplete 82-15 1, 3 Pendig 83-1 11 Pendig 9, 13, 14 cmplete o

e w

4

\\

l 1

i l -

i

4 MNuclear:

n

~ ' u

+-

.nemorandum u

Subject:

Revision 4 to TMI Warehouse Date:

March 1, 1984 Reassessment Program Location:

Parsippany (CHB)

From:

Director, Materials Management

'0'i MR S

Ali10 23 To:

R.P. Fasulo The attached Master Plan for the THI Warehouse has been updated to show current status and most current revisions.

/__ f Day d L. Herfe, D rector Materials Management DLH:rh cc: R. Kazebee P. Shea e

G G

h e

e A0000648 8 83

.o r~

'.. / r ;

.;n.

.Y

.r.;;...

l.Gr~ y,.

TMI REASSESSMENT PLAN MASTER PLAN January 28, 1984 (Revision 4 Dated January 24,1984)

O

\\

4 9

w

,,wy, e---

y y,-

y.__-.

...Q.. ' '.wy:.i. n..-;:. 4 4 :. ;

... :. ;. ;,, n. 7,. L.....,..:..

g.,

~

'. Revision'4 Dated F'ebruary 24, 1984-t.

~.,

Content and Justification For Revisions Rev. 4.1 Events F-1 and F-2, which are precursors to Event F-3 have been (F-3) completed; however, inadequate user feedback has resulted in an impasse relative to updating and refining St./PM requirements (F-3). This issue is currently under Senior Management review.

IMPACT: Until. adequate user support and input is obtained, complete implementation of this event will be deliberate. As a result, inventoried DTO items may not have end-use integrity.

Rev. 4.2 These events are tied to F-3.

See Rev. 4.1.

(F-5,F-6)

Rev. 4.3 Manning assigned to this event has been diverted to manage our (G-5,6,7) efforts relative to DTO, particularly at Oyster Creek, the unusually high volume of DTO at Oyster Creek ($10M at 0.C.,

$600K at TMI'). has necessitated a rescheduling of these events.

IMPACT: These events will slip 2-3 weeks which will not significantly affect level of storage efforts.

'Rev. 4.4 Technical problems associated with prototyping, in Reading, will (I-3.A-F) cause slippage in successive tasks necessary to complete CRT Order Entry. Tasks A-F have been rescheduled for completion as follows:

A - 3/19/84; B - 3/26/84; C - 3/19/84; D - 4/2/84; E - 4/9/84; F - 4/9/84 IMPACT:

Since the Remote Order Entry / Delivery System is operational, the impact of this delay will be minimal and will not compromise the intent 6f Event I.

Rev. 4.5 This effort was slowed down due to the time required to reach an (J-4,J-5) agreement with various parties (M&C, Bechtel, Plant Maintenance) on how best the system should operate.

IMPACT: A two month slippage will result, however, no significant or adverse results will occur relative to overall objectives.

S y

e

---,-.-,,----rw.,-

--,,w-y-

-,, -, - -,, ---,,-,y,~,

, -,,y-,

,-----,-,w, - - - + -,-. - -

1 e_ / v'.. ;;,

>:,:; : :.,,:-,. g -a: _9..

..- 9 Revision 3 Dated January 6, 1984 Content and Justification For Revisions Rev. 3.1 One month slippage due to slip in F-2; Slippage in F-2 was due to (F F-7) problems encountered with the conversion of data from Wang to the main frame computer.

IMPACT:

This sl<ppage will not significantly affect direct turnover efforts.

Rev. 3.2 9(a) Publish "For Sale" list was added. Scheduled completion Added 9(a) date is 3/5/84.

IMPACT: None a

Rev. 3.3 Engineering (see attached memorandum from J. Colitz, dated (H H-7) 11/15/83) has suspended efforts until additional justification is provided to warrant continued effort.

P. Shea will meet with J. Colitz during the week of 1/9/84 to resolve.

IMPACT,:

In the absence of technical support continuation and completion of this effort is dubious.

I will follow this event closely and, if appropriate, seek higher level resolution.

9 6

-g.

+---,--se

,--,r-

,,-,m

-,--,-,.m.

---

,,.-.---a-,-r---.--n- -., - - - -, -. - - - -

j,

.. O e.

\\;.,

-l '5.,...,,

~,. t n.je :

._.;y..,. u Revision 2 Dated Novenber 23, 1983 Content And Justification For_ Revisions Rev. 2.1 Technical problems were encountered with the conversion of (F-2) data from Wang to the main-frame emputer.

Completion date will slip to 12/5/83.

IMPACT:

The resultant slippage will not have any signifi-cant effects on direct turnover efforts.

Rev. 2.2 Statement of Intent was completed 11/21/83 as a result of the (I-1&I-8).

addition of events I-10 through I-12 which required reptior-itizing remote order entry / delivery requirements.

A deter-mination has been made as to phone system requirements (I-8) and efforts are underway to purchase a system; however, slippage in I-l has resulted in slippage of I-8.

IMPACT: NOE - Event I-12 has been implemented (11/3/83) to nullify slippage in I-l & I-8.

-Rev. 2.3 Evaluate phone system. Efforts are underway to purchase a (I-9) phone recording system and install.

Some slippage will re-sult since funds must be reallocated (expense to capital).

Once the order is issued more definitive dates for completion will be known.

IMPACT: NCNE (See impact statement for Rev. 2.2) l l

e

t' 4

. p '..,' ;d. G.;h: y. '..... 'k: >. :;'R. i. ;.r. i.e : ~i,,.,,.

• r...Q ','

9 ; ?... ;~,

m..e..,..

Revision 1 Dated Nove 2er 2, 1983 Content And Justification Fct Revisions Rev. 1.1 The start date for training with Purchasing and developnent (E-3) of the hot list was delayed with the hiring of a warehouse coordinator; the warehc,use coordinator was on-board 10/31/83.

Start date slipped to week of 10/31/83.

Im act: None e

i

J.u:n t at L.i e

..,:'IM.I.,.WAREHOUS ING-PROJECT: PLAN,

1 Event A:

Consolidation of Warehousing Event B:

Warehouse 1 Issue Point Event C:

Warehouse 2 Move to Warehouse 1 objective (s)

M

~

1..

Focus supervision on high activity areas.

2.

Improve labor utilization 3.

Improve issue point service 4.

Free up on-site storage space The consolidation of operations into Warehouse I converts II and III to a part-time manning status.

Further, the supervisor from these facilities is moved to tne issue point in Warehouse I where all issue activities will De focused.

These moves afford the user full-time, 7-day, 'immediate access to all active inventories, including DTO.

Space freed up in Warehouses II and III is for use as a' job marshalling, a laydown area in support of site operation.

This is a new service not now provided.

,m sEp deT NOV DEC JAN FfR RAR

_ygy EVENT

" " ' 9 "' 's u 'm

'"'"i ?""

'

• uss's

• ,ua

!Mg? u liil Illi lil' i

i l!i e

i

.i.

e.gi;n..

..ne.

apml l

l, i,

I,i ii,

y

.,i

..p..,c..., ca.. n...

+

ggpggl ll i

!ll!

..a, ttnienem mavou.

ill an,.m,a l;

i

!ljj reer =me cout

.;l i

• l,1 = ".e'ca 5

a

$MRm!

ii i !!:

I i

ilI!

!I I

i i!

C=.

. n u c.

+,.i.

. t mengl i

i!Ii

; I lll!

• 1tus Totat

i l

lil i

11 11!!

fiil i;i I

ll 1i

, til

'- lMhn"*

lil tt% nut II!

li!i I!

I!ll I

i !ii llll l

I ll

!il ill i I:;

illl i

l Ii et acn.c.utncat z jj j

j j

ll l i!i iIli I.i I,l!

I

$TSct i

,it I

igg a na rr=at ar ll camaulii ill!

l:

1ill ili 2.

... n....... a un e.... i lil

.I c:wnug 1 ll!

i J At0WC. manning.t i3 l

%Q$%

la l f[ l j

ll l

..... z a 3

'[ $ Y

'"*""'"I

!ll l

"l *h

• h h j.l.

5 %%?QMj ll,

==-

=

l j i

er.qn 2 of LA Event.D:

Warehouse 3 Staging Area.

s.

r

,.y.

Event Es. Personnel Objectives (s)

' Improve site service 1.

2.

Improve information flow among Warehousing, Material Control, Operations, Maintenance and Engineering

~

The Warehouse Coordinator acts as the pivot point or conduit for information tiow among the groups.

Duties include 1.

hork with Planners from operating groups in clearing Jobs; 2.

Expedite and prioritize materials through Receiving, Q/A, and the Warehouser 3.

Operate laydown area for physical allocation of materials for special jobs; 4.

Assist in returning materials to stock or for storage 5.

Alert Material Control of changes in demand for stock items.

This must be converted into a permanent position.

These are new services being offered and will enhance the interface between Materials Management and the operating groups.

ssi" oef NOV DEC JAN FfR MAR Ape MAy

__ E.y EMI__

^5"2" La i,a a uunut

.t i.n u --

i i t i. s-t.'a>$=

a i +eev i i,.ea

.'*,,4n m",.

I l i

II I i 8 ;t 11 l i

i t

t

'- jQ'tng" 2 ^5

- -i 4

tgM961 Ii!i

iiI one l

l

-14 ll

!!!I tili i t II'l i! !

L I-

""5" til 1

ji ilii Ill

l!!

li!I

i i l i =. oor.i.or so..

y,m g,y g

j ii

i;i

!.i, w r. m ia

.. i un.

i;j

g3 gi

il; ang,(g ii

,p

.stippesIto 1p/ 3M83 comut.whtWm%owam lv.

)t:",= jig;m

• lll I*1 'tu" 1M/'L'"*

iIi1 C,omfleN/0%0%I III i!II IIII

-~-

ill I

I i

fl'il li Illi

!!il Illi I!

I I

I i

ll i!

Illi i

ll' Il l

lli1 ll il I

il

!i Illi lll!' llit I

il lil Il lli ll!!

I'!

ll11 Illi l

ll l

ll lli III I

i illl Ill llll l

i

.I I!!I t liii ilit iiil L.-.

l o

.I l

~

5 -

, [-

i Li

~

4_

j' s

G i

f,-Ti.,'I_

'n U

i L.

,A d

~

a

~

~

?

E'

~

n A

~

~

t U

J e'

~

~

i

~

i sn

,o s

ei N

dt.

n l

i iit i

vdu J

a n

onc 4

~

i e

o kcs W

q-g' r

m

\\

tl e Y

i '

9 I

s sad A

1 W g~

Ii 2

uir n co M

1 1

n

~

s e

i mt' dpw 2-

.s nse u

~

a a

n E

n a

,d s

~

- il l

g dal A

in 4~

nl P

l t-(

r

[

e i

t q.

0 o

e a

Ut 4f i

r k j i

v

1. -

g-1-

~

P sr n E h-aio

. i l

\\-

v#

.f eat

& n

'$ i 7 Q. 7 -

W

~__

e g

R i P-g-

c~

si bk n h

e3 g~R-Mt b

3 lL ce i

J l as

'l if l pe s

E t a

g@

~

.J-rl i

r hDlpqg~

1 ce wl p g~

g W-r p

l tt a

i R

uS sis a

g l ci E

i

~

h M- [4 g -

n d ae F

n

~

or i pn

_ a

\\

n a rso

~

( R-(1 e

i 4

a n

U Q

~

I

,t t

e.t i

9 t

osu iN a

rc t 'J t

ock nt a

f uc nn A

i.

~

e

,l e

o Oeo J.

~

t..

ll

~

s mf 1

eet l

E gt s Uen

~

k 9-an ri g'.'-

4

~

~

U\\-

a l

fi ri i

oiw ous C

. S M-Rzn qi E n t

reh D_

s i

s r

i e

ert l

_ s f vO s oiI Uet

~

tD /f ai V

g n

n ri l

i l

een elt O

e vvo n s

ee of e N

u 3

~

~

l rn il r r

Po t eu i

r i ihs u

jl

~

eot sss f

i pti i a

ons ui f

r l_

~

rio qnxt O n ' -

~

i p

p eas i

es R u

i

~

~

yti Mm f ad eF 3

i r h

t 6

a t g on 1P 9

i nemt,t m S

~

~

e

~

e E

m r et r a

o

- F evr S

~

edno aee n

v I I riu re atc e

t l

n e

y<

e e

e.

eb r 123 ao 9

e l'

w g

i e 8

e u

tl r sar t

5 e

,i T

ceP 5

4 a

,s tE A

s E

er

~

i t

)

j

~

L C

c s on.

e e

r r

t v

r roe o

o e

a a s v

v o

o y'

(

r e pi g d

h e

v

't Fe i v t a a

s i.

r l

s i

N.

m a

r F

D i sar i

3 a

e r

i g

t ino an r

i u

d o

r e

5 h S e

t.

t r

c hrt t

Fi t

i t.

u a

i s

s v

t

'r u

o

e t os o

e ie s

m

'p i

t i

s p

int T

n P j f

nr.

v r fy

~a i

l r

b nnf Nm i

n. t. s e b _le r e 2_<mn i f

t O Ii o E au e

=

a i

l u

o

=

e s

t il s

P_n_

9r a

c.

s, tl l

n V

T.iraeg g1 g

a e

u ie l

i r

i 3, -

Us e

c s sa a

t e

E c g

d r

c s

s 9._ e _

a.:

r p

a A

P T 3-5 v

u.

a E

soi

- O r.

s F-t 2

1 4

I 1

11 l

2 l.

2 24 4 3 3

vv ee v v v

R R a e h

,lll

4 Event G:

I.evel of itioIa'g e

~

objective Asstire proper storage conditions for all stock.

Presently, there is no mechanism to alert warehouse personnel of special storage conditions or packaging on inventory. items.

Materials Management will generate a listing, by item, on all Q/A and Active items showing actual storage level.

This must be reviewed and validated by site engineering, entering any special considerations.

This done, the data will be loaded into the data base, carried and displayec on future documents.

A second listing for backfitting inactive stock in inventory will be distributed and worked.

The success, failure, and timeliness of this project area tiinge upon close support from the various groups assigned responsibility to analysis i

l and generate feedcack.

l l

l l

.. +

,,ia ssa nef NdV DEC 1AN FER EAR Apt MAY EVtNT assicatt,.,.,,,

,,,3,,,,,

,,,,33w i I.j il ;i i

l

i;

iI i

. d.i.s y m.vu COM9%% i I i !!.

' '!i 1-

" C

-'- + - -i d t h i44-1.tu#.W!cutiU!.

tow 9u.ui

ll

ii, i

" "r'5"'

i ! ;

i ;il ll tgw;H.uk ;

it i i

T "

• i e

mi" i i !i l: ll lllt i

tom 9Lut - li!

i t I ii ij;i liii i l i

m u....<.uiu.

av.et iili lIl

.Ii

!i:

W h.\\?% 10 %1 i i..au f o.

ev.ri l;,i.

l;i

,,i

i,

- um35.M ii nv.

g,,,,,,,,y,

o,,,,,

4:::::".",

i,i i;ii iiii l

ii i

svi34%

i:

i 43 2....,

I

'l

!Il I

n - a et a

Dal.*t siitrinae av.es i,i

iii jil i

i

! 1li I.ii iii1 e t l l

!llI l8.I

!*!I_

b l t l l 8,

I M eiste Cal t ta j,jl l

i;i

! Il!

Iiil i i!!

!iI' ii. n.no<.ctus evers

, i j-l;: i 12.aas fate Ugl.rt l ljj jl j

ji.!

ll 1 lll l'II III I*'

I' 8

I l!

llfI l1 II lI 13 4elocate if nec.stary (41ecoe j {l.

l,'!l ll

!Il ljll ll1 !

ll!I I

~

la 3th elify if ecc.ssary llll lg lj llll i

lll!

l ! f,

ra,s...

e*

Event H:

Dead Stock Objective (s) 1.

Asset Recovery.

2.

Cost avoidance (eliminate future storage charges)

By conventional standards, at least 70% of the stock items at W I can be considered to be dead.

This relates to about 35% of the warehouse pick locations.

Many items are leftovers from construction and were added to stock in the 1970's.

However, the M I inventory has not supported an operating plant in over four years and items which now appear to be dead may find use on Start Up.

Accordingly, it is necessary to perform a line by line analysis to identify dead and obsolete material.

Realistically, forcing visibility and disposit.icn of dead stock must be an iterative, almost ongoing, effort.

Material Management will pcovide listings of candidates for cisposition based on usage crite:ia, but ultimately the decision, live v.s, dead, must be made by site Engineering.

This project must have full support or nothing can be done.

Concurrent with this project area which will, over a perico of time, weed out dead, inactive items from the inventory, a separate program is to add spare parts to support new modifications made over the last four years.,

i,n

.u.

sse mer Nov one JAN Fft MAR Ape uay !

I ivswr ass :str

,,e,,,,,,

,,,,,,,o,,,,,,,

• 5m ll l l lii' llll Illi li!

11:

'll liil

'l

' t"" af 8aa t+et

%M.,.tpAbd ili i 1. i ;

Iil 1: !I

.I egggmQ,Mg m II i;

!llj ilji

.I N ittriewte l

l.

tl

~ Rev. 2 wira conu

!Ii li WSt(MCADE W %%NMil IilI t' !I' i

j llll i lll jliI il l

ilil i

i!

3.3 4 ineia tenau W.rt

iji, ji;l "dEfWUs""

Ilil I

I till ll: i I!!!

Ill!

u m..

j j;i; j!;i ill1 ij!l l1ii

.m ain o.r.... a n u s,

,,;i

i,;

l

iji

.,,i ll

,j

n:whq I I!Ii i I' 1 2. n voi l11i ti;:

lll I

ill I!i Illi till l'i'

'!i, 1111 llll

'!I lill lii!

I I :..

.llli l'-

ill iltt lll

.111 till

!!ii l'

ill' Itjr

,ili ili il till I

11 i!

lill ll; y.-m p

u-

Prgs 6 oC 14 f

Event I:

Remote Order Entry / Delivery objective (s) 1.

Improve site service.

2.

Labor savings.

Many labor hours are lost passing through the security lock into the protecte.d envelope going to and from the warehouse for materials and supplies.

In this phase of the Project Plan, the warehouse will initiate routine delivery schedules to selected areas within the security fence on orders transmitted to the issue point either by telephone or by order entry on a CRT in the operating area printing the material order in the warehouse.

When in operation, the CRT will probably be used for multiple line requests, phone entry for single line it. ems.

This is a new service not now provideo to the site.

NCTTE: This Event involves alternative means of notification of requirements fran the " protected area": camputer or phrne.

We will examine the alternatives in parallel, implementing the phene system, if practical, while further analysis is performed en the ecmputer network alternative.

staa ita4 l

SEP oct NOV DEC JAN FER MAR APR MAY I JUN EVENT 5 19i.9A 1 in 179Ai?

? M919R 11919?&

T 916 7130 & 199997 9191996 9 e T A? tin ThT1?g 419it'

'. REMOTE ORDER ENTRY / DEL'Y l

l l

1.

Delivery Kazebee COM' LITE a CIETlNh!Ni 2.

Phone Order A. gIdp ing drafi Ka2jbuj CC 9LETE 3.

Install equip.

Kazebee t

CC fqEy C.

Train Kazebee CCifqEy D.

Announce Start up Kazebee CClfLET E c' RmMuct Knese.

.'l F. Start full operation Kazebee CA"! Nulls

'l G. Gomolete final craf t rl l of Procedure tendacki i I f

3. CRT Grder Entry l

A.

Prototype 9 Reading Rusticus I i ' e i!

!<T5'$3.~

tIIN IN Nhb 8.

r NNI.Nh3=kh l l

C.

Prototype at TMI Rusticus 0.

Train

"'8f"(

'l f

$bWMMON*2,fkl

[kIINI #8#I I*

M%M*k'M Lensacki F.

Install System

[rj l

- gyggg l

l] l

]

E l

H l L11 i

1

ca,e <,....

"{

8 w.

Plant Stores Materials

(

Event J:

Obj ective (s) congestion and clutter caused 1.

Reduce (eliminate) by plant materials stored in shop and operating Provide controlled storage for these items and areas.

incorporate them into the existing PM and Shelf 2.

Life programs, as required.

Provide an accurate, consolidated status listing

~3.

of Plant Stores Materials.

The plant personnel will identify the material to be return it to returned and, with minimal information, for any of the following reasons:

Materials Management 1.

Long term storage; To be sold; 2.

Tools for specific jobs organized as kits; 3.

4.

To be added into stock.

Quantities and storage requirements for these itemsthis t The computer mechanism are not known at allocation of space t,o warehousing.

to hancle these transactions is developed but must be j

I testeo, debugged, anc implimented.

now offered to the site.

This is a new service not

.u.

ssa oef NOV DIC JAN FER

.gan Ape M ay

,,o A331GNtt 5,,.., a 3, a n,

3, t utise

<et..t.

t e t a me a m-3, s,,,,a s,in 3.n 7,, 3, q l

eur srms wavu.

.ill l!!I II,

!III i: !:

!tI i

5 EVENT

i;

...I.i..i. 4 F.i-l 4 ' -

Opuni l1ll i.a go sutmas or

!UTI'ei.0i.,.,

" f ""

iI l!iI i!!

I NNU ! '

l'II ii' 3,,,

i

j ;

I{i i1(1-C.owan, i i,I!

. Iii e

i m e a m atias uaou 4.e m l,jl l;j Il

.f i ;-

gu n os.R %

i Rev. ' 4.r...

4MM03*EM i

M"'.S"?""

IIl!

Iiii l l I !~

l i

• *. *

• l Iil i i!l i.

4.5,5-ma & train s...

'll; lljl ll l

l 1

utenu III II

!II Ie'i uar Iii I

4

'1"3;'r,'O;f'5'-

lIf II,t E.

8t"5"' ' dS""

ili Iiii I

l i

il II!

I'I i !,

/

9 ax.w. ston unnu i

jiil l

l 1

n,.,,,

i I

llt!

l l

,I

'll I

'!l

-14

-l i lL "t0MU"n" "'

i l I

l'Il till il lei s,

ll 11ll Ill l

It i

l il i

ILil ill lli lill t ii l

1 ll1/

I ilil I

illi I ! LL.

lll

!ll i

i 11) llll Il ll

!il lij.

111 ill ll,ilii 1111 til ei it 3

1

' <.