ML20072B321
| ML20072B321 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/10/1983 |
| From: | Dieckamp H GENERAL PUBLIC UTILITIES CORP. |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20072B310 | List: |
| References | |
| NUDOCS 8306130395 | |
| Download: ML20072B321 (9) | |
Text
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Pres.dem 5<I
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UTluTIES 100 Interpace Parkway i CORPORATION 83 3110 P2:25 Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Wnter's Direct Dial Number June 10, 1983 Docket No. 50-289 Chairman Nunzio J.
Palladino U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555
Dear Chairman Palladino:
Recently, the NRC s taf f s tated, "because of all the open issues.... the s taf f can draw no conclusion regardi ng management integri ty at this time". Addi ti onally, the Commonwealth of Pe nns ylv ani a 's
" Supplemental Comments" of June 2,
1983, stated that, "the Commonwealth will not support the res tart of TMI-l until i t receives adequate assurances f rom the Commission that the management of GPU Nuclear Corporation is willing and able to operate the plant in a safe and competent manner".
We have again evaluated the present GPU Nuclear organization to reassure ourselves and to provide a basis for the confidence of others that any inappropriate atti tudes or practices of the past have not been carried forward and will not manifest themselves in GPU Nuclear.
We retain confidence in the capability and integrity of the GPU Nuclear organization and personnel. The basis is further evidenced by the in-depth assessment conducted by the Licensing Board, as well as by independent measurements by industry's INPO, NRC's SALP and other inspections and by Licensee's own consultants.
As a preliminary matter, it is useful to review the Meted organization that was responsible for operation of the TMI Station 8306130395 830610
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9 at the time of the accident. No member of Meted's/TMI senior management is now i nvolved wi th TMI. Four levels of management, the Me tEd president, vice-president, s tation manager, and both uni t managers responsible for TMI at the time of the accident are not wi th GPU Nuclear. The senior management responsible for operation of TMI-l today is dramatically di f ferent than that which existed at the time of the acci de nt.
In s tructuring GPU Nuclear we have provided dedicated on si te personnel for each of the generating stations with a highly experi-enced senior manager on site. We have provided experienced managers and staf f for a number of centralized support f unctions such as engineering, health physics, quali ty assurance, trai ni ng,
mai nte nance, and construction in order to ef fectively support the s tation management. Addi tionally, the organi zational s tructure was specifically' designed to provide i nherent checks and balances. GPU Nuclear, i ts operational philosophy, i ts senior managers, and numerous other key personnel within the organization were reviewed in depth and endorsed by the ASLB.
Over one hundred individuals,
including top managers, appeared before that board in public hearings.
A broad look at the elements of GPU Nuclear which will be involved in the operation of TMI-l reveals that the organi zation, down through two levels of management below the GPU Nuclear vice preside nts,
encompassing 86 such posi tions, contains 16 individuals that were wi th Meted prior to the accident. Of the balance, 30 are new employees since the accident and the remaining 40 come from other components of the GPU Sys tem. The executive v.p.
of GPU l
Nuclear and the vice president directly responsible for TMI-l si te operations are new.
V At the time of restart we expect to utilize 38 currently licensed operators for TMI-1; 25 are newly licensed since the accident. Out of the remaining 13 that were licensed at the time of the accident, 10 are assigned to shif t activities. These operators need to be viewed as a source of experience for the safe operation of TMI-1.
Their prospective perf ormance must also be assessed in light of (1) the fact that all have been licensed under the new tes ti ng cri teri a, (2) the ability of GPUN to provide 6 shi f t coveraIge for TMI-l which provides one shif t out of six for training, (3) the presence of shi f t technical advisors, and (4) 'signi ficantly improved procedures.
As f urther assurance:
- 1) We will, prior to restart, reassign personnel such that no TMI-2 licensed operator will operate TMI-l (except for the manager of operations who was licensed on Unit 2 but who' was evaluated in depth and speci fically endorsed by the ASLB), and
- 2) We will, prior to restart, add full time on shif t operational quality assurance coverage by degreed engineers until the open issues are resolved. We would defer to the NRC should it wish to provide full time on shif t resident inspector coverage of TMI-l operations.
The balance of the TMI-1 site s taf f in engineering, maintenance, and supervisory roles contains numerous individuals with prior experience in the operation of TMI-1, experience which is important to the safe operation of TMI-1.
The prospective performance of the current TMI-l site staf f must be assessed in light of (1) the evaluation by the ASLB, (2) the NRC's Jan. 1983 SALP and (3) the mos t recent inspection 50-289/83-10 which found very favorable results in the pervasive management areas of procedures, adherence, 1
discipline, and attitude toward safety.
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l In order to provide added assurance; We will reassign personnel such that 'those f unc ti ons which provide an overview assessment, analysis, or audit of plant activities specifically; General Office Review Board Independent On-Si te Safety Group Shi f t Technical Advisors O/A Audit O/A and Q/C Site. Sta5f Lice nsi ng Radiation Control Emergency Preparedness will contain only personnel with no pre-accident inv61vement as exempt employees at TMI-1 or 2. We will conti nue this cons traint until the open issues are ef fectively resolved.
As a f urther action to s trengthen TMI-1; We have reallocated the priorities and assignments within the of fice of ' the president of GPU Nuclear, which of fice includes the president and executive vice president, such that TMI-l will report to the executive vice president and such that he will be able to devote his prime attention to TMI-l matters.
In a letter to Governor Thornburgh we have committed to the actions which we think necessary to satisfy the issues under appeal by the Commonwealth of Pennsylvania. A copy of that letter is attached.
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- We are taking these steps in order to provide addi ti onal assurances during the period necessary to resolve the open issues. We are confident that the actions necessary to provide these added assurances will not detract f rom the firs t priority of safe ope r a ti ons.
We will work with your s taf f to communicate the specifics of these s teps.
In closing, we urge the Commission to expedi tiously resolve the open issues so as to provide assurance that the learnings of the accident have been identified and implemented. We pledge our cooperation in that ef fort so that the TMI-1 management and s taf f can be accorded the full support of the Commission and the public.
Sincerely, t
H.
Dieckamp lda enclosure cc:
Governor Thornburgh i
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g UT1UTIES 100 intercace Parkwtiy 1
CORPORATION Parsecany. New Jersey 07054 201 263-6500 TELEX 136-482 June 10, 1983 wntar s Drect Dial Numtec
'Ibe Honorable Richard 'Ihornburgh State House Harrisburg, Pennsylvania 17120
Dear Gcuernor 'Ihcrnburgh:
In your letter of June 2 to Chairman Palladino, you expressed concern about a nu=ber of issues relating to the restart of 'IMI-1 and stated specifically:
"I would find it particularly inappropriate for the Ccmmission to take such acticn prior to hearing this ccmmerwealth's appeal en the cperator cheating issue."
We had been hopeful that this matter would have been resolved by the appeal processes by this time. Since it is not, we have undertaken a review of the actions that we can take to resolve this issue and to prcuide assurances with respect to other issues. We want to inform you of the folicwing ccanitments en the part of the Ccepany with respect to the three remaining outstanding issues en which the Ccmmerwealth filed excepticos with the Atcmic Safety and Licensing Appeals. Board on August 20, 1982.
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- 1) 'Ibe Ccmpany will not utilize anyone to cperate 'IMI-1 who was found by the ASLB to have cheated on an NRC* administered licensing exam or en a ccupany administered training exam (Mr.H. ).
- 2) 'Ibe Ccmpany will not utilize Mr. DD (whose attitude was criticized by the ASIB) to operate 'IMI-1 or to. train cperating license holders or trainees.
- 3) 'Ihe rmparty will direct the ASIB mandated ' raining audit to t
specifically evaluate Mr. ED's performance as an instructor and the ccupany will ecmply with the findings in a timelyf and appropriate manner. Prior to the audit the emparty will continue to monitor Mr. ED's performance and assign work consistent with that performance.
We believe that these ccanitments remcue the concerns that are the subject of the Wealth's appeal before the Atcmic Safety and Licensing Appeal Board / ~
We will be informing the NBC, with a copy to you, of additional ccamitments
'O that we will also be ecmpleting price to restart so as to prcvide additional assurance regarding protecticn of public he,alth and safety and a further basis for confidence in the integrity of athe management and staff which will be irwolved in the cseration of 'IMI-1.
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'eijD UNITED STATES OF AMERICA
'83 Jun 10 P2:25 NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 (Restart)
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(Three Mile Island Nuclear
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Station, Unit No. 1)
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1 CERTIFICATE OF SERVICE s
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kJ I hereby certify that copies of Licensee's letter to T
tho' Secretary of the Commission were served this 10th day of
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June 1983, by hand delivery.to those persons identified by
'an asterisk (*) preceding their names, and by deposit in the 1
United States mail, postage. prepaid, addressed to the others persons on the attached Service List.
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s Ernest L.
Blake, Jr.
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DATED: _ Ju o 10, 1983
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP estart)
(Three Mile Island Nuclear Station, Unit No. 1)
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SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Linda W. Little Commission Atomic Safety & Licensing Board Washington, D.C.
20555 5000 Hermitage Drive i
Raleigh, NC 27612
-Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Administrative Judge Commission Gary J.
Edles, Chairman Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board John F. Ahearne, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Thomas M.
Roberts, Commissioner John H. Buck U.S. Nuclear Regulatory Atomic Safety & Licensing Commission Appeal Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission James K. Asselstine, Washington, D.C.
20555 Commissioner U.S. Nuclear Regulatory Administrative Judge
. Commission Lawrence R. Quarles Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Administrative Judge U.S. Nuclear Regulatory Ivan W. Smith Commission Chairman, Atomic Safety &
Washington, D.C.
20555 Licensing Board U.S. Nuclear Regulatory Administrative Judge Commission Christine N.. Kohl Washington, D.C.
20555 Atomic Safety & Licensing i
l Appeal Board i
Administrative Judge U.S. Nuclear Regulatory Walter H. Jordan Commission Atomic Safety & Licensing Board Washington, D.C.
20555 L
801 West Outer Drive Oak ~ Ridge, TN 27830
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W Administrative Judge Mr. and Mrs. Ncrman Ah 3dt Reginald L.
Gotchy R.
D.
5 Atomic Safety & Licensing Coatesville, PA 19320 Appeal Board U.S. Nuclear Regulatory Michael F. McBride, Esquire Commission LeBoeuf, Lamb, Leiby & MacRae Washington, D.C.
20555 1333 New Hampshire Avenue, N.W.
Suite 1100 Administrative Judge Washington, D.C.
20036 Gary L.
Milhollin Atomic Safety & Licensing Board Ms. Louise Bradford 4412 Greenwich Parkway, N.W.
TMI ALERT Washington, D.C.
20007 1011 Green Street Harrisburg, PA 17102 Jack R.
Goldberg, Esquire (4)
Office of the Executive John Clewett, Esquire Legal Director The Christic Institute U.S. Nuclear Regulatory 1324 North Capitol Street Washington, D.C.
20002 Washi D.C.
20555 Michael W.Maupin, Esquire Docketing & Service Section (3)
Hunton & Williams Office of the Secretary 707 East Main Street U.S. Nuclear Regulatory Post Office Box 1535 Commission Richmond, VA 23212 Washington,' D.C.
20555 Ellyn R. Wepss, Esquire Atomic Safety & Licensing a mon & Weiss Board Panel I Street, N.W.,
Suite 506 U.S. Nuclear Regulatory Washington, D.C.
20006 Commission Washington, D.C.
20555 David E.
Cole, Esquire Smith & Smith, P.C.
Atomic Safety & Licensing 2931 Front Street Appeal Board Panel Harrisburg, PA 17110 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Robert Adler, Esquire Assistant Attorney General 505 Executive House Post Office Box 2357 Harrisburg, PA 17120 John A. Levin, Esquire Assistant Counsel Pennsylvania Public Utility Commission Post Office Box 3265 Harrisburg, PA 17120
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