ML20059D549
| ML20059D549 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/29/1990 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 4410-90-L-0062, 4410-90-L-62, NUDOCS 9009070091 | |
| Download: ML20059D549 (8) | |
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J OPU Nuclear Corporation
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' arsippa y, New Je ey 07054 '
201 316-7000
- TELEX 136-482 Writer's Direct Dial Number:
i (717) 948-8461 4410-90-L-0062 l
. August 29, 1990 i
Director, 0ffice of Enforcement U.S. Nuclear Regulatory Commission Attention: Document Control Desk-
-Washington, D.C.
20555
Dear. Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating. License No. DPR-73 Docket No. 50-320 Response to. Notice.of. Violation and Proposed Imposition of Civil Penalty This responds to the NRC letter of July 30, 1990, which forwarded a Notice of Violation and Proposed Imposition of Civil Penalty. The NRC's action isibased on the findings of investigations by an'. independent investigator-Edwin'H. Steir-commissioned by GPU Nuclear and by NRC concerning-alleged inattentiveness in 1987 by a TMI-2 shift supervisor.and failure of certain TN-?. site managers to correct the condition.
o GPU Nuclear agrees that the violations did occur and has forwarded payment of the proposed fine of $50,000 under separate cover. The attachment to this letter provides the GPU Nuclear response to the-Notice of-Violation.
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Sincerely,
/ f b Yg P. R. Clark President RDW/mkk Attachment cc:. T. T. Martin - Regional Administrator, Region I OD J. F. Stolz - Director, Plant Directorate IV L. H. Thonus - Project Manager, TMI Site F. I. Young - Senior Resi_ dent Inspector, TMI in"N8#ht pg GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation lI g
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'Jocunont Contrel Desk Augnst 29, 1990 410-90-L-0062 Page 2 NRC Notice of Violation A.
Technical Spcification 6.8.1 requires that written procedures _ be established, implemented,.and maintained covering.the activities recommended in Appendix A of Regulatory Guide ~1.33, Revision 2, February 1978.
Section 1 of Appendix A of Regulatory Guide 1.33, Revision 2,1978 requires in part the establishment of administrative procedures covering the conduct of plant operations.
TMI-2 Departmental Administrative Procedure Manual 4210-ADM-3020.01, entitled
" Conduct of Plant Operations",. Revision 5-02, dated February 27, 1987, written to satisfy the requirements of Appendix A of Regulatory Guide 1.33, requires, in part, in paragraphs 4.4'.2, 4.4.3, and 4.4.4, tht.t'all on-duty operators and supervisors be aware of and responsible'for plant status at all times; be particularly attentive to.their ' instrumentation and controls at all' times; and be alert for any' unusual trends in niant parameters.
Contrary to the above, for indeterminate periods prior to July 1987, on various shifts, particularly during the 11:00 p.m. to 7:00 a.m. shift, the then shift supervisor (senior reactor operator) of the: F-shift, although assigned to be the supervisor directly responsible for the operation and-control of the unit, was at times not alert.or not attentive to his dutin Specifically, the individual exhibited a pattern:of sleeping, giving the appearance of sleeping, or otherwise being inattentive to duties.
B.
10 CFR Part 50, Appendix B, Criterion XVI,: Corrective. Action, requires, in.
part, that measures be established to assure that conditions adverse to quality, such as deficiencies and noncomformances, are promptly identified and corrected; and that for significant conditions adverse to quality, the cause of the condition is determined; corrective action is taken;.and those conditions, causes, and corrective actions are documented and reported to appropriate levels of management.
Contrary to the above,.between the fall of 1986 and July 9,1987, the then -
Plant Operations Manager.was made aware (by-subordinate shift personnel) of allegations that the then shift supervisor of the F-shift was observed sleeping while on duty; furthermore, on three other occasions (on or about April 9, June 24, and July 1,-1987). other site management (including the then Manager,. Plant Operations; the then. Site Operations Director in April -1987; his then successor as Site Operations Director between Apri1 and July 1987;-
and the then TMI-2 Director) became aware, to varying degrees, of alleations that the then shift supervisor of the F-shift was observed'to be sleep 11g on duty. Although inattentiveness by the shift supervisor would constitutc a.
significant condition adverse to quality, measures were not adequately implemented by s'te management to promptly establish the validity'of the allegations.and take appropriate action to correct this condition.
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1 Document Control Desk
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4410-90-L-0062 Page 3 J
I GPU Nuclear Response A.
Admission or Denial of the Alleged Violation L
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GPU Nuclear based on Mr. Steir's investigation-concluded in 1988 and. advised the NRC at the time that.the above violations did occur. We confirm that conclusion.
. B.
Reasons for the Violation On July 10, 1987,-GPU Nuclear engaged Mr. Edwin Stier.to conduct.an.-
independent investigation of the allegations of inattentiveness by a licensed-supervisor at TMI-2 and the. failure of TMI-2 management to respond in a timely and appropriate manner to.the alleged inattentiveness despite a
knowledge of the allegation. Mr. Stier's initial report, addressing thel allegations against.the licensed supervisor, was submitted to the NRC on November 25,.1987 (Reference 1).
Subsequently, on-July 19, 1988 (Reference 2), GPU Nuclear submitted to-the NRC the final report (Volumes I through IV)
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by Mr. Stier entitled "TMI-2' Allegations of. Inattentiveness." The reasons for the'above NRC violations are thoroughly described in Sections IV.A & B and Section VI of Volume'I of the final Stier report.
C.
Corrective Steps That Have Been Taken and the Results Achieved The corrective.-actions taken by GPU Nuclear were discussed at length with the NRC at the er -ecement conference on February 2,.1990. Those corrective actions are su.nmarized below; a
- 1. The shift rupervisor and his a..ediate' supervisor (i.e., the then Plant Operations Manager) have ber; discharged.
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- 2. Appropriate disciplinary acthn was taken against the responsible site managers identified in the Nucice of Violation.
- 3. A number of meetings.and memoranda focused company management on the i
relevant issues by providing reaffirmation of the Company's standards regarding attentiveness to duty, open and timely reporting to management 1
and the-NRC, and the availability of support and resources to help supervisors perform their; duties properly.
- 4. Several major steps were taken in 1987 and 1980 to ensure that all
.l personnel understand what had happened and what was expected of them,
- a. The Stier Report was distributed to the GPU Nuclear-Vice Presidents and steps taken to ensure that each manager and supervisor read Volume 'I of l-the report, as a.ainimum. Additionally, copies.of Volume I were made available to all employees at several locations at TMI for interested i
individuals.
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Document Control Desk August 29, 1990 4410-90-L-0062 Paae 4 This served to emphasize to management and supervisory personnel.
(1) the baset for the disciplinary action taken by GPU Nuclear; (2) their responsibility to be sensitive to employee concerns and i
fully asses
- indications of substandard or unacceptable performance by subordinates; and (3) that each supe ~isor snd manager must ensure his/her management is fully informed in an accurate and timely manner.
of all allegations of iraproper or inadequate behavior, b.
A lessons-learned review of the Stier Report was made to examine several significant issues derived from the Stier investigation (e.g., supervisor and management handling of employee performance problems; openness in comunicating and reporting to the NRC and
?enior management; interdivisional flow of information and requests for outside assistance). The report of this rev'iew was distributed to all GPU Nuclear divisions who were required to respond to the Office of the President on actions taken to implement the recomendations of the~ lessons-learned review.
In addition to re-enforcing the objectives of corrective action No. 4a above, this action also served to ensure that supervisors and managers of GPU Nuclear were aware of the resuurces available within the corporation to assist them in performing their duties (e.g., Human Resources, Security) and the expectation that they utilize these resources, c.
Employees were informed of the reasons for Company actions and lessons-learned from the event.
Specifically:
- A videotape presentation was made available at all TMI videotape stations to provide all TMI employee the' opportunity to learn firsthand from the President, GPU Wuclear what had occurred and why the publicited corrective / punitive actions were taken and to j
reaffirm GPU Nuclear's comitment to high standards of performance, d.
Articles were published in the TMI, Oyster Creek, and Parsippany l
newsletters informing all workers at each site of the results of the Stier investigation, lessons-learned, and the responsibilities of all GPU Nuclear personnel with regard to individual performance and accountability.
S.
Based on the recent publication of the NRC Notice of Violation and to reaffirm GPU Nuclear's comitment to excellence, a special edition of the "GPU Nuclear Supervisors Newsletter" will be published which will provide additional insight into the c.ause and effect of this incident, and will discuss the lessons-learned as a result of the detailed review of the incident.
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Document Control Desk August 29, 1990 4410-90-L-0062 Page 5 6.
A case study of this event and the lessons-learned has been prepared for use in GPU Nuclear supervisor training progrsns.
7.
The GPU Nuclear embudsman program was upgraded in 1988.
Specifically, an Ombudsman has been established at TMI and Oyster Creek to augment the Parsippany-based Ombudsman, promote visibility and accessibility to these individuals, and encourage use of the Ombudsman, as apprcpriate.
8.
Empicyee attentiveness was emphasized as an important performance factor to be checked during management tours.
Currently, two in-plant tours are made per week by management. Reports are prepared on these tours and followed up.
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9.
In addition to the Management Tour Program, an enhanced QA monitoring program was also implemented starting on August 1, 1987.
QA han continued to include observation of individual attentiveness at TMI-2 as part of their normal monitoring program; monitorings of this nature in 1988 and 1989 resulted in no instances of inattentiveness being observed.
D.
Corrective Steps that Will be Taken to Avoid Further Violations As indicated in item C. above, GPU Nuclear has taken a variety of corrective actions to prevent recurrence of the events described in the Notice of VH1ation. GPU Nuclear corporate management reacted promptly and aggressively to learn the facts (i.e., Stier investigation), and to take i.ppropriate disciplinary action. The ability of GPU Nuclear to conduct this investigation in parallel with NRC's own investigation allowed it to act in iM7 and 1988.
This was recognized by the NRC in the h'otice of Violation letter of July 30, 1990, which stated:
l "The NRC recognizes that corporate management, when first apprised of this condition after receipt of tha July 9, 1987 allegation, immediately initiated an independent investigation of this matter. The NRC also recognizes that once the findings were established by your internal investigation, 'rompt and thorough action was taken to prevent recurre,ce."
GPU Nuclear believes that the continuing, company-wide, comprehensive corrective actions taken, which include increased emphasis on superv'sory development and individual accountability, should ensure employee coi cerns are addressed in a thorough and objective manner, thus precluding the likelihood of a recurrence of this type event and ensuring that upper management and the NRC are appropriately informed of safcty concerns in a o
timely and accurate manner.
GPU Nuclaur believes that no additional corractive actions are required to prevent recurrence, however, incorporation ef the lessons-learned from the case study of this event into supervisory training programs, as appropriate, will be an cngoing actior,.
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Documrnt Control Desk August 29, 1990 l
4410-90-L-0062 Page 6 E.
Date When Ful' Compliance Will be Achieved Based on the above corrective actions and the results achieved, GPU Nuclear believes that full compliance has been achieved.
In conclusion, GPU Nuclear and the NRC have invested a substantial effort in investigating this matter.
GPU Nuclear has taken prompt and appropriate di?ciplinary action against the individuals involved and has implemented a broad ste:trum of corrective actions which serve to heighten awareness of the Company's intolerance to employee inattentiveness ano ensure that employees' concerns are dealt with in a forthright and effective manner. Therefore, GPU Nuclear concludes that no further NRC enforcement action is necessary to ensure compliance with regulatory requirements.
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Document Control Desk August 29; 1990 4410-90-L-0062 Page 7
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REFERENCES j
1, GPU Nuclear letter 5200-87-0208, " Report of Invertigation", dated l
November 25, 1987.
2.
GPU Nuclear 'etter 4410-88-L-0119, " Report of Investigation", dated July 19, 1988.
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Document Control Desk August 29, 1990 4410-90-L-0062 Page 8 METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION Three Mile Island ;)uclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Notice of Violation This letter it submitted in response to the Nuclear Regulatory Commission's letter of July 30, 1990, which forwarded a Notice of Violation and Proposed Irnposition of Civil Penalty concerning alleged inattention to duty by a TMI-2 Shift Supervisor and inadequate response by TMI-2 site management. All statements contained in this response have been rev'ewed and all such statements made and matter set forth therein are true and correct to the best of my knowledge, information, and belief.
P. R. Clark President Signed and sworn before me this c#ff# day of August, 1990.
J Notary Public amVAW DRUEY MTARY PUBUC OF NEW JEltSEY My Comensson Expres Mar. 21,1991 a.
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