ML19305D108
| ML19305D108 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/31/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | PENNSYLVANIA, COMMONWEALTH OF |
| Shared Package | |
| ML19305D049 | List: |
| References | |
| NUDOCS 8004140065 | |
| Download: ML19305D108 (19) | |
Text
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'. March 31, 1980 O UNITED STATES OF AMERICA NUCLEAR REGULATdRY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE SUPPLEMENTAL RESPONSE TO PENNSYLVANIA PUBLIC UTILITY COMMISSION FIRST SET OF INTERROGATORIES March 31, 1980 i
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the information required to be supplied by applicants for operating licenses pursuant to 10 C.F.R. S 50.34 (b) and in the quality assurance program requirements of Appendix B to 10 C.F.R. Part 50. ,
In this proceeding, however, the Commission has issued an Order (CLI-80-5, dated March 6, 1980) which supplements its regulations by specifying in some detail the elements of management capability which the Licensing Board should consider..
INTERROGATORY NO. 8 What facts or opinions demonstrate that Met Ed is managerially ;
capable to operate TMI-1, while maintaining TMI-II in a safe configuration and supervising cleanup and decontamination tasks?
If reference is made to documents, attach them or provide ver-batim summaries thereof.
RESPONSE
The fact that Met Ed is managerially . capable of safely operating TMI-1 while decontaminating and restoring Unit 2 is !
illustrated by the strengthened management and technical support fully committed to TMI in the combined Met Ed and GPU Service Company Generating Division technical and management resources presently known as the TMI Generation Group. Pending the approval i
' of various Regulatory Agencies we anticipate that the existing TMI ,
Generation Group with its organizational structure and rescurces will become the GPU Nuclear Corporation. This single organizational entity, the TMI Generation Group /GPU Nuclear Corporation which is headed by R.C. Arnold, who is Senior Vice President of Met Ed and e t
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continues to serve as Vice President to GPU Service Corporation, is responsible for operation of TMI-1, TMI-2 activities, and support activities for both units.
Mr. Arnold as head of the TMI Generating Group and the future President of GPU Nuclear, reports to Herman M. Dieckamp, President of GPU and GPUSC, and acting President of Met Ed. This reporting structure provides a direct link from the Chief Operation Officer of these three Companies to the activities at TMI.
Reporting to Mr. Arnold within the TMI Generation Group are: Mr. Phil Clark, the future Executive Vice President of the GPU Nuclear Corporation, who has over 25 years of Naval Reactor
. Program experience snd who will share the office of the new Corporation President with Mr. Arnold; and, five division heads ,
which in the GPU Nuclear Corporation will be Vice Presidents. In addition, the Manage [ - TMI-2 Radiological Controls is reporting directly to Mr. Arnold.
Using the GPU Nuclear titles of the five division heads (whose functions are the same in the TMI Generation Group) , a more detailed description of the divisions is included in Attachment A. .
Further detail is included in the organization descriptions provided in Section 5 of the Restart Report, copies of which are available in the Licensee's Discovery Reading Room and have been provided to the participants in the hearing. ,
INTERROGATORY NO. 11 State in chronological sequence separately for TMI-1 and 2 the nature, date and disposition of every NRC-alleged or reported violation, infraction or other item of noncompliance with NRC regulations or technical specifications. For each such violation, infraction or noncompliance, state the name of the NRC inspector making the report, and the report number.
ATTACHMENT A (cont s )
II. Vice President TMI-2
. Site Operations 1
.. Operations
.. Maintenance
.. Plant Engineering
- .. Process Support
. Administration and Services :
. Recovery Programs (Proj ec t Management of Bechtel)
III. Vice President Technical Functions
. Systems Engineering
. Engineering and Design
. Proj ect Engineering Management
. Licensing and Environmental Engineering
. Independent Technical Review IV. Vice President Nuclear Assurance
. Quality Ascurance ,
. Training and Operational Safety Support
. Nuclear Safety Assessment .
. Emergency Planning Coordination V. Vice President Administration !
. Fiscal and Administrative Management ,
. Materials Management ,
. Personnel and Labor Relations Management
. Personnel Safety, Security, and Facilities Management I. TMI-1. As previously indicated the Division organization for the operation of TMI-l is under the fulltime direction of a Vice Presi-dent. His sole responsibility is TMI-1. Reporting to him are five managers: Manager Plant Engineering, Manager Unit 1, Manager t
Administration and Services, Manager Radiological Controls, and the Safety Review. Manager. Reporting to the Manager Unit 1 is -
a Superintendent of Maintenance ~ and a Supervisor of Operations. A significant increase in the number of maintenance personnel _and the
ATTACHMENT A (cont.)~
II. The TMI-2 Division operates under the' fulltime direction of a Vice President whose sole responsibility is the recovery and restoration of Unit 2.to commercial operation.. Three departmental managers coordinate site activities: Manager-Site Operations, Manager-Administration and Services, and Manager-Recovery l Programs.
In addition, site managers are dedicated to the functional ,
areas of Recovery Engineering and Proj ect Controls. While these two managers report administratively to the.Vice President-TMI-2, they report functionally to the Technical Functions and Administrative Divisions respectively.
It should be noted that this organizarion structure is atypical, but due to the unique status and conditionsaof the recovery operation, a hybrid organization with most of the elements ,
of an operating facility, augmented by an organization similar to a normal construction project was deemed to be the most effective mode of operation.
The Site Operations Department is responsible for coordinating all normal and recovery plant operations associated with TMI-2.
The following functional sections are contained within this department:
The Operatione Section - is responsible for plant operations, '
processing operations, decontamination, Technical Specification
~
compliance.and operations procedures. .
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ATTACHMENT A (cont.)
The Maintenance Section - is responsible for corrective and preventative maintenance as well as long-term layup_of plant equipment.
The Process Support Sej ion - is responsible for technical direction and administration of decontamination waste processing /
disposal operatic. .
- The Plant Engineering Section - is responsible for systems support engineering, plant chemistry and startup/ testing of new systems related to the recovery effort.
The Administration and Services Department is responsible for coordinating Administrative Controls, Document Control, training, Security, First Aid / Medical, personnel administration l and recovery efforts.
The Recovery Programs Department (Proj ect Management of Bechtel) is responsible for coordinating the activities associated with the recovery of the Containment Building. This includes ,
Technical Engineering, containment decontamination, Construction Management of Support Facilities and fuel removal / reactor systems recovery.
INTERROGATORY NO. 9 Are all management positions within GPU, GPUSC, and Met-Ed presently filled?
RESPONSE
No. Those positions which are unfilled are defined in Answer j
- 10. All positions for TMI-1 are presently filled. The answer to ,
Interrogatory No. 10 addresses the current vacancy status of manage-ment positions which exist in TMI-2, Technical Functions, Nuclear Assurance and Administration.
INTERROGATORY NO. 10 l For each management position not presently filled, state job ;
description, name of the prior incumbent, reason for his termination, !
transfer or leave of absence and length of vacancy to date.
~
RESPONSE
TMI Generation Group Manager Project Operations - Bechtel - Vacant - New Position Since July 30, 1979 Individual %ith technical degree and broad experience on
-PWR plants. Will be principle technical interface with the Bechtel I
Corporation for work conducted between Bechtel and TMI Unit 2. He will provide an Engineering contact for Bechtel, coordinate the review i of Bechtel generated technical plans and documents, provide technical data to Bechtel from Met-Ed Operations. R.F. Wilson is currently acting in this capacity. '
TMI Generation Group - Administration Division The functional responsibilities for the Administrative Division ;
were assigned and its head was named on January 25, 1980. The
responsibilities of the departments in the Administrative Division are described in Section 5.3.3. of the Restart Report and the department head positions have been filled. Subdepartments are ,
currently being established and those'in existence have been i
staffed. At present, therefore, no positions in the management /
supervisory levels of the Administrative Division, which have been defined, are vacant.
1 TMI Generation Group - Technical' Functions l Manager - Environmental Engineering - Vacant.- New Position i Since January 17, 1980 ,
This position is responsible for the management, coordination i and technical adequacy of environmental support for GPU Nuclear Power ,
Plant Site. Responsibilities include providing system-wide environ-mental support to perform system-wide environmental audits, and ' prepare '
and implement environmental impact control plans, environmental ,
monitoring programs and the preparation of environmental documents (e.g., environmental reports, proposed environmental technical i specifications and input to various permit applications). The staff reporting to this position is a highly technical group with expertise ,
in various environmental disciplines. !
TMI Generation Group - Nuclear Assurance ;
Manager - Nuclear Safety Assessment - Vacant - New Position l Since January _17, 1980 !
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! This position will be responsible to identify problems in Nuclear i Plant design, operations and maintenance which have potential for compromising nuclear safety. It.is also responsible to investigate, t
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assess and recommend corrective actions for functional controls This function will also supply.
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required.to assure nuclear safety.
staff support-for the General Office Review Boards and Generation
~
Review Committees.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE'-
! By/A -
/h j thybrgji/ F. TfbWoridge [
Dated: March 31, 1980.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) . (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF JOHN G. GRAHAM
. State of New Jersey ) ss:
County of Morris )
JOHN G. GRAHAM, being duly sworn according to law, deposes ,
and says that he is the Treasurer of General Public Utilities Service Corporation, that the information contained in Licensee's Response of March 17, 1980 to the following interrogatories from the Pennsylvania Public Utility Commission (first set) are true and correct to the best of his knowledge and belief: Interro-gatory Nos. 1, 3 , 4 , 5 and 6.
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John G. Gr hp Treasude(w Sworn to and subsgribed before me this J 4 day o f. ' March , 1980.
, Notary @ ,,
NOTARY PUBUC CF NEW JERSEY
_ My Commission Expires: "Y C***'"'*" f*" dd' 7* 19 3 F
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
METROPOLITAN EDISON COMPANY e art
)
(Three Mile Island Nuclear )
Station, Unit No. 1) ) ,
AFFIDAVIT OF JOHN G. HERBEIN Commonwealth Pennsylvania )
- SS County of Dauchin )
JOHN G. HERBEIN, being duly sworn according to law, deposes and says that he is the Vice President-Generation with Metropolitan Edison Company; that the information contained in Licensee's Responses of March 17, 1980, to the following Interrogatories from the Pennsylvania Public Utility Commission (First Set), are true and correct to the best of his knowledge and belief: Interrogatory Nos. 2, 3, 7 and 8.
N John G'. Herbein Vice President - Generation Sworn to and subscribed before me this /i day of D , 1980.
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My Comauss!on Espires Oct. 24,198)
My Commission Expires s
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF JOHN R. THORPE State of New Jersey ) ss:
County of Morris )
JOHN R. THORPE, being duly sworn according to law, deposes and says that he is the Director-Environment, Health and Safety of General Public Utilities Service Corporation, that the information contained in Licensee's Response of March 17, 1980 to the following interrogatory from the Pennsylvania Public Utility ~
Commission (first set) is true and correct to the best of his knowledge and belief: Interrogatory Number 11.
n C John R. Thorpe'
/ Director-Environment, Health and Safety Sworn to and subgcribed before me thiso2L day of March, 1980
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- AUCi l'MC"32 NOTARY PUBUC CF NEW JER31Y My Commission Expires: "# # **'" " '" "* '
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
METROPOLITAN EDISON COMPANY e r (Three Mile Island Nuclear )
Station, Unit No. 1) )
AFFIDAVIT OF JOHN G. HERBEIN Commonwealth Pennsylvania )
- SS County of Dauphin )
JOHN G. HERBEIN, being duly sworn according to law, deposes and says that he is a Vice President with Metropolitan Edison Company; that the information contained in Licensee's Responses to Pennsylvania PUC Interrogatories (First Set) Nos.: supplemental response to 8 and nos. 9 and 10 are true and correct to the best of his knowledge, information and belief.
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, John G/ Herbein W N j
'Vice President Sworn to and subscribed before me this J.3d' day of 9/2$ '* - , 1980.
CATHY L BREY,19eny Puttic
!n.s1M. .r u unanem Te, DaucMn Ceum. Pa.
Notary Publief My Commiss.oa Expires Oct. 24.19d3
. j My Commission Expires N hd;,- 23[ .;;g
SHAw, PITTMAN, PoTTs & fROWBRIDGE ,
1800 M STR E ET, N. W.
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. RACFORO v"h"LEN* 'T' REvNOLOS MARR,M.auSS lEaE' March 31 # 1980 COUMSE' FRED A. UTTLE THOM AS M. MeCOMMICM NA M AN EL # SRE CO. JR. W LL AM P ARR l M ARM AUGENGLaCR JOH N L. CARR, JR.
Ef;N EST L. BLAME. JR. PMlup J.MARVEY CARLETON 5. JON ES ROB ERT M. GORDON THOMAS 4. 5AATER J EANN E A. CALDE RON JAM ES M. SURGER SARSARA J. MORGEN' ,
SHELOON J. wEISEL BONNIE S. GOTTUES J pA RC MICK EY S M . MOO AS N JAMES THOMAS LENHART SMEILA E. MeCAFFERTY STEVEN L.MELTZER DEUSSA A. RIDGwAY D EA N O.AUUCK R ENN ETM J. MAUTMAN JOHN ENGEL DAVIO LAWRENCE MILLER
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John Levin, Esq.
Assistant Counsel Pennsylvania Public Utility ,
i Commission P.O. Box 3265 '
i Harrisburg, Pennsylvania 17120
Dear John:
Enclosed is the supplement to Licensee's responses of March 17, which we noted would be necessary in our cover letter of that date. It includes modifications to the earlier response to Interrogatory No. 8 and responses to Interrogatories 9 and 10.-
The modifications to Interrogatory No. 8 are as follows: _
- 1. A revised page 5 of the response, deleting the
" Note" which signalled the need for a supplemental response;
- 2. A revised page 6, which adds one sentence on Manager-TMI-2 Radiological Controls at the end of the second complete paragraph;
- 3. A revised'second page of Attachment A to the response which modifies the functional responsibility assign-ments for Vice President TMI-2; and
- 4. New pages which describe the Unit 2 organization and' which should be inserted in Attachment A just before the page which begins "II. Technical Functio'ns Division."
a SHAW, PITTMAN, POTTS & TROW 3 RIDGE John Levin, Esq. l March 31, 1980 ,.
Page Two !
i Also enclosed are affidavits for the March 17 responses and the enclosed supplement.
, Sinodrely, I. Tr [r bas -
1 Enclosures {
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Lic 3/31/80 i
UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION r BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear ) ,
Station, Unit No. 1) )
4 CERTIFICATE OF SERVICE I hereby certify that copies of:
! (1) Licensee's Response to the First Set of Interrogatories from the Aamodt Family (Dated February 16, 1980);
(2) Licensee's Response to the Fourth Set of Interrogatories from the Aamodt Family (Dated February 22, 1980);
(3) Licensee's Response to the Third Set (Sic; Sixth Set] i of Interrogatories from the Aamodt Family (Dated February 25, 1980);
(4) Licensee's Response to the Fourth Set (Sic; Fifth g Set] of Interrogatories from Marjorie M. Aamodt (Dated February 25, 1980);
(5) Licensee's Response to the Second Set of Interrogatories l from Anti-Nuclear Group Representing York; (6) Licensee's Response to the First Set of Interrogatories ;
1 from' Newberry Township TMI Steering Committee . (Dated February 15, 1980);
(7) Licensee's Response to First Set of Interrogatories of-Chesapeake Energy Alliance;
- ,--...-.,e... - , , - . , -, - , . . - ~ , - . . - -
(8) Licensec's Response to Third Set of Interrogatories of Marvin I. Lewis; (9) Licensee's Response to Fourth Set of Interrogatories of Marvin I. Lewis; (10) Licensee's Response to Steven C. Sholly's Fourth Set of Interrogatories; (11) Licensee's Response to Interrogatories (Seventh Set) of Three Mile Island Alert, Inc.;
(12) Licensee's Supplemental Response to Pennsylvania Public Utility Commission's First Set of Interrogatories; (13) Licensee's Responses to UCS Second Set of Interrogatories -c were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 31st day of March, 1980.
wkzeA "l Delissa ( Ric/Jwg /
Dated: March 31, 1980 4
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UNITED STATES OF AMERICA NUCLEAR PIGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear ')
Station, Unit No. 1) )
SERVICE LIST Ivan W. Smith, Esquire John A. Ievin, Esquire Chai man Assistant Counsel Atanic Safety and Licensing Pennsylvania Public Utility Ccmn'n .
Board. Panel Post Office Box 3265 ,
U.S. Nuclear Pegulatory Ccmnission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General
- Atanic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357
- 881 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E. Minnich Dr. Linda W. Little Chaintan, Dauchin County Board
' Atanic Safety and Licensing of Ccmnissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. 'Iburtellotte, Esquire Walter W. Cohen, Esquire Office of the Executive Iacal Director Consumer Advocate U. S. Nuclear Regulatory Ccmnission Office of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Serrice Section Office of the Secretary s
U. S. Nuclear Regulatory Ccmnission
~'
, Washington, D.C. 20555 4
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Jordan D..Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against Nuclem T.M.I. Steering Camittee Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006
'Dwvinre A. Adler, Esquire Widoff Reager Selkowitz & Adler Pcbert Q. Pollard Post Office Box 1547 609 Fcit.pelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. Weiss, Esquire Chauncey Kepford Attorney for the Union of Concerned Judith H. Johnsr'.
Scientists Environmental Coalition on Nuclear Shelden, Harmon & Weiss Power 1725 Eye Street, N.W., Suite 506 . 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylva.lia 16801 Steven C. Sholly Marvin I. Iewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M. Aamodt Holly S. Keck R. D. 5 Iagislation Chairman Coatesville, Pennsylvania 19320 Anti-Nuclear' Group Pepresenting York
. 245 West Philadelphia Street York, Pennsylvania 17404 k
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