ML20076E927

Comments on 830524 Commission Meeting & on IE Insp Rept 50-289/83-10.Continued Ref to Hartman Allegations Clouded Purpose & Results of Revalidation Effort.Safe Operation Assured

ML20076E927
Person / Time
Site:	Three Mile Island
Issue date:	05/27/1983
From:	Dieckamp H GENERAL PUBLIC UTILITIES CORP.
To:	Palladino N NRC COMMISSION (OCM)
References
NUDOCS 8306010351
Download: ML20076E927 (4)

Text

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, Herman Discump Prest.>ot

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GENERAL PUBLIC m UTILITIES ' 100Intupace Parkway CORPORATION

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pyy P1 S Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Wnter s Direct Dial Nurnber L"- 9 PacD. & LA IL n,c..Q.

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May 27, 1983 Chairman Nunzio J. Palladino U. S. Nuclear Regulatory Commission Washi ng ton , D. C. 20555

Subject:

Comments on the Commission meeting of May 24, 1983 and on' Inspection No. 50-289/83-10.

Dear Chairman Palladino:

l l The staff's " revalidation" inspection report presents an extremely thorough and f avorable assessment of the management of TMI-1. This result is a tribute to the management attention, the key personnel, and the resources that have been devoted to TMI-l since the accident. We urge each of you to study the full report.

Unfortunately, during the Commission meeting on May 24 the purpose and results of the revalidation ef fort became clouded by references to the Hartman allegations .

• The staff did not rei nves tigate the Hartman allegations. The staf f did identify and examine those fundamental management characteris tics necessary to preclude behavior or conditions similar to those alleged by Hartman.

These characteris tics generally relate to procedures , adherence to procedures, di s ci pli ne , and management atti tude. Additionally the staf f evaluated the ef fectiveness of actions taken at TMI-l to enhance safe plant operations in accordance with the lesaons learned and they reviewed LER's , SALP reports, and INPO evaluations for insight regarding procedure adherence and management issues since the staff's safety evaluation was presented to the ASLB. F ur the r ,

the staf f reviewed the assignment of specific personnel with potential involvement in the Hartman allegations.

The above scope is not narrowly cons trained to the Hartman allega ti ons . The scope is a comprehensive evaluation of f undamental management issues relati ng to competence for and dedication to safe ope ra ti ons . The le/el of ef fort and the number of senior managers

• Our concern about the s taf f's characterization of their own conclusions and that of our consultant regarding the Hartman allegations are the subject of a separate communi ca ti on.

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j and engineers, including those same individuals who were NRC's expert witnesses on management capability and integrity in the restart proceeding, provide a sound and further basis for the significance of the conclusions of this inspection, namely:

" --That the licensee's policies and practices related to adherence to procedures and license condi tions , as reflected in its management

' organization, procedures , training , reviews and commitment to safety and quality are -

acceptable and do support the res tart of TMI-1.

" --The numerous changes and improvements in or-ganization, procedural adherence and per-

. sonnel at TMI-l that have occurred since the l Hartman allegations provide assurance that i these allegations do not now present health and safety concerns that require resolution prior to the res tart of Unit 1.

--Management initiatives observed during the in-spection were found to be positive toward safety and reflected a desire and commitment to operate

. TMI-1 safely."

The significance and strength of these conclusions can not be diminished by some narrowly defined nexus to the Hartman allegations.

The Hartman allegations may have prompted the inspection .but they did not constrain the thoroughness or the general applicability of the results of this inspection of fundamental management issues.

The s taf f's memorandum of May 19 s tates that "the issues raised by the Hartman allegations should not by themselves be a bar to res tart" . The concluding sentence , however , s tates that the "open issues" prevent a staf f conclusion regarding management integrity at this time . While we recognize that these or other open issues must ultimately be resolved, we are concerned about the lack of criteria or a threshold of relevancy, currency, or validity necessary and suf ficient to preclude a conclusion on management competence and i nteg ri ty. The current state of management commitment to procedures, adherence, di scipli ne , and safe operations , provides the requisi te assurance, as i t has in the case of the Hartman allegations , that the organization is not vulnerable to the pas t conditions that may underlie most of the "open issues" . The King / Parks allegations ,

albeit in a dif ferent and unprecedented environment, can be generalized as relating to prt 1 dural adherence and management

, u commitment to safe operations . The subject inspection covered these fundamental and pervasive topics. The s taf f is unable to inform us of the specific subject of any new item (s) from the GPU/B&W litigation materials. However, it is our belief that the implications of any such item (s) which necessarily stem from a period of at least four years ago would be similar to those covered by this and other inspections and would be likewise corrected by the current organization. To the extent that the BETA and RHR reports discuss issues beyond the scope of the subject inspection, issues important to safety can be readily evaluated.

Wi th respect to the consultant's reports , the subject inspection report should be amplified to explicitly note that these reports were called to the attention of the team leader by Mr. Hukill, v .p.

TMI-l early in the inspection on his own initiative and without prompting or questioning by the team. Because the BETA report is directed toward cost ef fectiveness and the RHR report relates to operator opinions and future access to such opinions It , we is indicated our belief a

preference to retain possession of these documents.

that these reports do not contain information that changes the basis of the ASLB deliberations and findings. The reports ce r tai nly, contain information relating to TMI-1, but no more so than the myriad of information attendant to day to day management of TMI-1.

We are reassured in our belief by the inspection team's finding:

"In summary, when the inspection team's findings from the BETA and RHR reports were integrated with the onsite in-spection findings , the team's fi ndings regarding management integri ty and procedure adherence were not changed. "

The safe operation of TMI-l depends upon the correction of those deficiencies identified by the accident and the subsequent inves tigations and inspections . TMI and its management have been subjected to unprecedented scrutiny including public hearings before an ASLB which covered virtually the entire panoply of lessons learned. Neither we nor the NRC can achieve absolute assurance that there is no remaining information f rom the past that could relate to the safe operation of TMI or the fi tness of its operating and management personnel. Nevertheless, the scope , diversity and independence of the numerous i nves tigati ons , i nspec tions , and hearings provide more than reasonable assurance that the fundamental requi reme nts for safe operation have been identified. Wetoasthese an

organization have directed our attention to responding le arni ngs in order to assure safe operations i n the future. We are grati fied that the subject investigation concerning many of the The r f undamentals of good management has revalidated our capability.

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remaining open issues need not bar operation but can be dealt with when appropriate investigations provide resolution or identify the need for corrective action. Responses to any addi tional insights will then provide further improvements in the basic capability tt at has been put in place at TMI-1.

The Commission has the requisi te assurance that i t sought wi th its 1979 orders that TMI-l can and will be operated safely.

Si e ly,

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H. Dieckamp Ida l

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