ML20076M279
| ML20076M279 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/18/1983 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8307200215 | |
| Download: ML20076M279 (69) | |
Text
- - - - .- - ._ _. . - .
w i LS SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNEmSMep OF pmOFESSIONAL ComPOmATIOess ISCO M STREET. N. W.
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W85ffER'S DenECT O6AL Mussegm (202) 822-1084 Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ::
4 4
Victor Gilinsky, Commissioner g
[
U.S. Nuclear Regulatory Commission 6 Washington, D.C. 20555 s Thomas M. Roberts, Commissioner F j-Jul'191983>p3 U.S. Nuclear Regulatory Commission ', m :
Washington, D.C. 20555 me~ *se.- E W4 g -
James K. Asselstine,. Commissioner .g i *
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U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of
- Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit:No. 1) l t
Docket No. 50-289 (Restart) t
Dear Chairman Palladino and Commissioners:
In a Memorandum from the Secretary, dated June 28, 1983, the Commission has offered an opportunity to parties to the.
TMI-l Restart-Proceeding to comment.on the Memorandum and re-lated documents, including the transcript of the Commission's .
June'21, 1983 briefing by the NRC Staff. Licenseeloffers the following! comments.
i F
8307200215 830718 t-PDR ADOCK 05000289 O PDR "ISD3 -.
Y# ;SHAW, PITTMAN, PoTTs & TROWBRIDGE i
- 4 nammcas . or e= onces.ouat con onations Commissioners, NRC Page Two July 18, 1983
! Licensee retains confidence in the capability and integrity of the present GPU Nuclear organization and personnel to operate l- and support'TMI-1. The personnel reassignments outlined in i Mr. Dieckamp's letter of June 10 have been undertaken in-the face
{
of the Staff's'"open issues" to provide an additional level of
- confidence that any inappropriate attitudes or practices of the
! past have not been carried forward and will not manifest themselves
} in GPU Nuclear. That plan is being implemented.
i During the Staff's briefing of the Commissioners on June j 21, questions were raised concerning the emphasis which our re-
- assignment of personnel placed on those in Met Ed's employ at the j time of and prior to the accident (as opposed, for example, to j those in the employ of GPU Service Corporation at the time), and' t on the recent shift of primary responsibilities'between Messrs.
- Arnold and Clark within the Office of.the President of GPU Nuclear.
. In this regard, we urge the Commissioners to review the attached l excerpts from the transcript of Licensee's meeting with the NRC Staff on June 20, 1983, in which these two areas were explored
- In some detail.
! The attached excerpts include corrections to the transcript of the June 20 meeting with the Staff. We have also attached to i these comments for the benefit of the Commission and all parties
! a complete listing of transcript corrections for the entire meeting
! with the Staff and a revised set of Licensee presentation notes i which were bound into the transcript of that meeting. As was
- pointed out at the outset of the meeting (Tr. 12), Licensee has l continued to comb through the GPU Nuclear organization to ensure l a thorough implementation of its personnel reassignment goals and l anticipated thatuits continued review could yield some changes in i the numbers of persons affected. Those changes which have been I identified are reflected in each instance by a vertical bar along-side the new information in Licensee's revised presentation notes.
Finally, Licensee notes the continued;high priority the Commission places on completing _its immediate effectiveness decision, aus stated in the Secretary's Memorandum of June 28,-
1983. Based on~the favorable testing results to date since com-pleting the steam generator repair and on the status of completion
- of certification items, Licensee anticipates that TMI-1 will be l . physically ready to restart in September. We urge the Commission' to maintain its sense of priority on closing out open issues
l SHAw, PITTMAN, PoTTs & TROWBRIDGE A PARTNER 5Mi* CF P8EOFES$3ONAL CompORATIONS Commissioners, NRC Page Three July 18, 1983 which would enable a determination on restart of TMI-l as early as September of this year._*/
Respectfully submitted, f i $ b h.
Ernest L. Blake, Jr.
Counsel to Licensee Enclosures cc: per Certificate of Service
- / Questions about the Staff's abilih.y to support a September
_ restart decision are posed by Mr. Dirck's Memorandum to the Commissioners of July 15, 1983, which Licensee just rm, aived.
Licensee will be responding to that Memorandum.
r t.NITED STMES OF AMERICA NUCLEAR REGULATORY CC1MISSICN BENRE 'IEE CCMESSION_
)
In the Mattar of )
)
Docket No. 50-289 hm mISCN CINPANY )
(Restart)
)
('Ihree Mile Islarxi Nuclear )
~
Station, t. hit No.1)
SERVICE LIST Ad"'4"iatrative Judge Gary J. Edles Mmzio J. Palladino, Omiman Cha.2.:: man, Atcznic Safety and Licensing U.S. Nuclear Begulatory Cm=4 =aion Appeal Board '
Washa.ngccn, D.C. 20555 U.S. Nuclear Begulatory Cannission Washington, D.C. 20555 victor 414nsky, r ccmni==ierwar U.S. Nuclear Begulatory Ce **im A%4niatrative Judge John H. Buck Washington, D.C. 20555 AtcInic Safety and Licensing Appeal Board U.S. Nuclear Begulatory Cannissicn Washington, D.C. 20555
'Ihcmas M. Roberts, Ccmuissioner U.S. Nuclear Begulatory 0:zrmimaicn Adminiatrative Judge Christina N. Kohl Washingtcn, D.C. 20555 Accznic Safety and Mm=4m .& T Board James K. Asamistine, renimmimer U.S. p_w la=v pagniatory Emmianim Washingecn, D.C. 20555 U.S. Mv 1 mar Regulatory r*
- aim Washingtcn, D.C. 20555 Adminimuotive Judge pun =1a L. Getchy Ph4n4-u tive Judge Ivan W. Smith Atomic Safety and M-*ing .W 1 Board N 4 man, A W e safety and U.S. Naclear Ragulatory rmmi**im Washingttm, D.C. 20555 Licensing acord U.S. p_v1 pg,1 *my rmei mmim Jack R. Goldberg, Esquire Washingtcm, D.C. 20555 oM4m of the Emacutive Iagal Dim.ter AA=4n4 6.tive Judge Walter H. Jordan U.S. pela=e Regulatory rmminim Washington, D.C. 20555 A* min Safety and Mm=4M Board 881 West Outer Drive m;ing and Service Section (3)
Oak Ridge, Tiermaamma 37830 Office of the Secretary Wn4-u.tive Judge Linda W. Little U.S. Mv lane P-,1*my M anim Washington, D.C. 20555
.Aemic Safety and Mm=4ng Board 5000 normitage Drive Aemic Safety and Licensing A& 1 Board Balmigh, North Carolina 27612 Panel U.S. Nuclear Regulatory Ccam anim Washingtcm, D.C. 20555
Atcmic Safety and Licensing Board Panel Ellyn R. Weiss, Esquire U.S. Nuclear Bagn1atm7 Cn=4 ==4 cn Hazmcn & Weiss Washingtcn, D.C. 20555 1725 Eye Street, N.W., Suita 506 Washingtcn, D.C. 20006
. Douglas R. Blazey, Esquire Steven C. Sholly Chief Counsel Obicn of Cm- =-=' Scientists Department of Enviwam.r.atal Resources 1346 0- edent Avenue, N.W. #1101 Ccamenwealth of Pennsylvania Washington, D.C. 20036 514 Executive House, P. O. Box 2357 Harrisburg, PA 17120 ANGRY /'IMI PIPC 1037 M elay Street John A. Iavin, Esquire mM =htq, PA 17103 Assistant c_am==1 Pennsylvania Public Uts.lity nrmnimairm P. O. Box 3265 Mr. and Mrs. Ncean Aamodt mM ah17, PA 17120 R.D. 5 Coatesville, PA 19320 Jordan D. Cunningham, Esquire Fcx, Farr & Cunningham Io'4ca Bradford 2320 Nor:h Sect:rxi Street 'IMI ALpc mr, =hr7, PA 17110 1011 Green Street mM <h tg, PA 17102 Will i am S. Jordan, III, Ram'i m m m & Weiss & = m Keoford 1725 Eye Street, N.W., Suite 506 Judith J. Johnsrud Washingtcn, D.C. 20006 Envh .ad.al Coalition en Nuclear Power 433 Orlando Avenue Adnunistrative Judge Gary L. Milhollin State College, PA 16801 Atanic Safety & Licensing Board 4412 Greenwich Parkway, N.W. John Clewett, Esquire Washington, D.C. 20007 The Christic Institute 1324 North Capitol dtreet Michael F. McBride, Esquire Washington, D.C. 20002 IeBoeuf, Lamb, Iaiby & MacRae 1333 New Hampshire Avenue, N.W.
Suite 1100 Washington, D.C. 20036 David E. Cole, Esquire Smith & Smith, P.C.
2931 Front Street Harrisburg, PA 17110 Michael W. Maupin, Esquire Hunton & Williams 707 East Main Street P. O. Box 1535 Richmond, VA 23212 l
l
.. I l
e Proposed Transcript Corrections for GPU and Meeting With NRC Staff June 20, 1983 Page Line Correction 3 12 Change "here" to " hear".
10 9 Change " regressively" to " aggressively" 11 10 Change " unresolved" to " resolved" .
18 3 Change " board" to "GO RB " .
21 3 Change " President" to "Vice President".
21 18 Change "TMI to" to "TMI-2."; change " people" to " People".
21 20 Change "to" to "too".
28 3 Change second "of" to "and".
28 5 Insert comma (",") following " licensing".
28 25 Change "there" to "three".
30 1 Insert "our review" following "1974".
30 . 2 Change period (".") following "date" to comma (",").
30 4 Change first "and" to "in".
30 5 Change "and" to "in".
34 8 Change "New Jersey" to " Jersey Central".
34 23 Change " Fred" to "Floyd".
34 23 Change " Levy" to " Leva".
37 10 Change "other" to "of the".
37 13 Change "are" to "were".
37 14 Change "are" to "were".
39 23 Change "one" to "one hundred".
41 6 Change "have" to "had".
41 25 Change "Certainly," to "I am not certain".
Page Line Correction 42 3 Change "or" to "our".
44 16 Change "it" to "I".
44 25 Change "PIV" to "PID".
45 19 Change " Quin" to "Quinn".
48 16 Change "On" to "One".
49 13 Insert "and" following " administrative".
50 5 Insert "and" following " composition".
50 7 Change "DP" to "VP".
50 11 Change " Board" to "GORB".
54 16 Insert "you what" follow "give".
55 4 Change " Device" to "The Vice President, no".
55 4 Delete last word ( "Vice ") .
55 ,
5 Delete " President now".
55 6 Insert period (" . ") following "specifically".
55 17 Change "our" to "are".
58 11 Change "oversigh" to " oversight".
58 17 Change " stopped" to " staffed".
59 11 Insert period (".") after "with"; change
" recognizing" to " Recognizing".
62 25 Change " sere" to "were".
64 5 Delete "to" following " shift".
65 14 Delete "aos" following "will".
69 24 Change "or" to "are".
l' l 70 12 Change " plant" to " planned". )
- i. 72 15 Change "supplicability" to "its applicability".
78 7 Change "overchocked" to "overcheck";
change "crosschecked" to "crosscheck".
e Page Line Correction 78 21 Change "The" to "They".
79 9 Change " Corp" to "GORB" .
81 2 Change "need" to " meet".
81 17 Change " accepted" to " excepted".
81 18 Change "Non-emergency" to "Now, Emergency".
82 20 Change " cross-checked" to "crosscheck".
91 14 Change " conversation" to " concentration".
91 22 Change " plant" to " plan".
92 25 Change "was" to "way"; change "words" to
" works".
93 18 Change " RADON" to " Rad Con".
95 2 Change first "has" to "in".
96 13 Change "he" to "we".
96 25 Change "GORB-NRC" to "GORB and NRC".
97 14 Insert period (".") following " advised".
97 15 Change "in" to "In".
102 24 Change "to" to "the".
107 11 Change "som may" to "so many".
109 14 Insert "For" following " budget."; change "The" to "the".
110 12 Change "a" to "in".
115 22 Change "now" to "not" .
117 17 Insert comma (",") following "it".
.j
bW2 rg6 a
1 ,
MR. CLAdK: Essentially the same assignments.
2 Page four is a quote from Mr. DiecKamp's letter 3 which addresses the current organization. I think in addition 4 to what is stated there, what is in the letter is that the 5 organization is designed to provide all reviews and cross 6 checks, and of course that is the organization which was re-7 viewed by the ASL3 with the f avorable conclusions.
8 page five shows the current organization and it 9 is color-coded or marked to show those who were with Met Ed 10 prior to 3/79 at any time, people who are new to the entire 11 GPU system since 3/79,and people who were with the GPU system 12 but not with Met Ed prior to 3/79. Met Ed now is the organi-13 zation which was operating TMI.
14 . As we go down through the office of the president, 15 ' we see that Mr. Arnold was with Met Ed prior to 3/79, but not 16 I am new to the GPU system. The direct-at the date of 3/79.
17 ors of Oyster Creek TMI-1, TMI-2 are new to the GPU system.
18 The directors of administration, communications and maintenanc e 19 and construction are new to the GPU system. And that the 20 directors of tech functions, nuclear assurance and radiation 21 andenvir[onmentalcontrolswerenotwithMetEdpriortothe 22 accident and have moved in from Jersey Central and the service 3- corporation since the time of the accident. That also applies 24 to the chairman of our general office review board, Mr.
25 Finfrock.
10 e
1 This chart also shows by the dotted lines the 2 formally defined access to the Board of Directors from the GORb 3 chairman of the berrd and the vice-president of nuclear as-End two. 4 surance.
5 6
7 8
9 10 11 12 ,
13 14 15-16 17 18 19 20 21 22 23 l
26 l
19 bw21bl 1 I think that gives a good picture of the twelve 2 senior jobs in GPU nuclear: . Eleven of them are filled by 3 people who were never with Met Ed, the twelfth by someone 4 who was with Met Ed, but not after sometime in 1977.
5 MR. DIECKAMP: Phil, perhaps at this point we 6 ought to inject a little bit about the service company because 7 of a characterization of the service company as being separate 8 from Meted. At die time of the accident and before the accident 9 the service company's responsibility was for design and constru co 10 tion of new generation facilities, whether they be nuclear or 11 fossil. This service company had no direct responsibility 12 for the operation of TMI. On the other hand, this service 13 company did have a number of technical personnel,who, on 14 occasion, were called upon to support TMI in terms of some 15- specific analysis. Probably the most prominent one was
?
[ 16 nuclear fuel management, a task being done by this service 17 company in support of the operation.
I '
y 18 Other examples, which today may stand out, are i 19 things like the efforts of some of Bob Keaton's people and the 20 service company to assist in analyzing what have today been 5
21 identified as some of the precursor events, the pressurizer 3
22 transients that were observed either in the start up- turnover f
23 program for TMI 2 or during the actual nuclear start up of 24 TMI 2. So there was no direct operating responsibility, no 25 direct supervisory responsibility but indeed there was a l
hw31b2. 20 1 technical arm of the company, a resource, that was made 2 available to assist Meted.
3 MR. DENTON: Can you refresh my memory on what 4 was the relationship between Meted, the service company, and 5 the overall holding company in '79? Who did the president 6 of Meted report to, for example?
7 MR. DIECKAMP: The president of Meted reported to 8 the Metropolitan Edison Company Board of Directors and probably ,
9 in a more generalized kind of a chart, it would be Mr. Kuhns 10 as the Chairman of the Board, Gach of GPU's operating subsid-11 iaries at that time. In an analogous way Oyster Creek was, 12 from an operating responsibility point of view, totally within 13 the Jersey Central organization which again, in a similar 14 way, reported to the Jersey Central Board of Directors, with 15* Mr. Kuhns again as the Chairman of the Board.
0 l 16 The service company also reported to its own Board O
o 17 of Directors and then to Mr. Kuhns, as the Chairman of the i '
18 Board. I was president of the service company starting, I think, t
Mr. Arnold, at the i
E 19 sometime in 1974 and continuing today.
20 time of the accident, was the service company Vice Pres'ident
{ 21 in charge of the Design and Construction D'ivision of the 3
l 22 service company.
23 MR. DENTON: Who would have been in change, respon-24 sible, for operations of Unit 1 at the time of the accident, 26 organizationally?
)
1 MR. DIECKAMP: Organizationally, the line would go 2 down through Walter Creitz, who was President of Metropolitan 3 Edison, toJackHerbein,0V President of Generation, had both 4 the nuclear and fossil stations for Metropolitan Edison down 5 to Gary Miller, who was the Manager of the Station, the 6 Station Manager down through Joe Logan, who was the Superin-7 tendent for TMI 2.
8 MR. CLARK: That basically is the first chart we 9 looked at. It shows the organization for operation of TMI.
I 10 MR. DIECKAMP: Harold, again to make sure that we l
11 are clear on this item, people like Dick Heward was the Program 12 Manager for the construction of TMI, and I think for a large 13 fraction of TMI 1 and TMI 2. By the time of the accident, 14 he had phased out and was spending his time on the Fodud Rbar 15- Project, which was being reactivated in New Jersey. So during h
I g 16 the period of 1977, largely when we had the turnover,- this O
l l 17 start up and test turnover from construction to the operators,
- 26. -
lIl 18 DickHewardwasstillinvolvedinthatphaseofTMItofeople '
t 19 like Dick Wilson and Bob Long on the left of the chart were 5
20 not as -- well, they were involved in TMI to0-- from a construc l
21 tion management point of view. But again, by the time the
{
3
$ 3 accident had come around were well into devoting their time 2 to Forked River Project.
24 The scheme that we used was that the survice 2 company had responsibility for design and construction manage-
7RC 631b4 1 ment. They integrated the ef fort s of the architect engineer, !
2 the nuclear steam supplier, the construction manager, and any 3 other contractors associated with the job. As we completed 4 construction and systems were checked out to assure that they 5 conformed with the design requirements, Metropolitan Edison 6 provided the operators. The service company supervised, or 7 sort of provided the project leadership, to the turnover but 8 as soon as the operations were done by Meted individuals then, 9 upon turnover, it became the responsibility of Meted to operate 10 those systems.
11 The construction permit was delegated from the 12 owners, with Meted being the 50 percent owner, to the service 13 company. And then, when yie got the operating permit for 14 TMI 2, in about February of 1978, full responsibility for the 15
- license transferred to Metropolitan Edison Company.
} 16 MR. DENTON: I think this is a key area. _Maybe 17 f it warrants a bit more discussion because after the accident 1
18 Bob, and others from your service company, became very visible j 19 and active in planning operations from there. I think that
!5 lg 20 did lead to questions as to involved they had been in the past.
21 Some people jumped to the conclusion that since Bob Arnold
{
3 j 22 did play a very active role right after the accident that he 23 was the man in charge of operations also.
24 MR. DIECKAMP: Let's be specific about Bob Arnold.
25 He was Vice Presiden t of Generation at Meted up until ,about
23 bw31b3 a
1 May of 1977 and then Jack Herbein followed him. Bob moved 2 to:the service company in May of '77, to become Vice President 3 of Design and Constru ction, or Generation we called it at i
4 that time. His predecessor, Bill Veaxrti, moved to Penelec 5 to be the President of the Penelec subsidiary. Arnold, Wilson, 6 Long, Heward, people of that sort were some of our major 7 resources back in Parsippany to bring to bear on the problem 8 at the time of the accident. -
9 In fact, the first response was to send Dick 10 Wilson and a team of guys out to begin to investigate. They 11 arrived at the site on Thursday after the Wednesday of the 12 accident and immediately found that it was more than just an 13 investigation, it was a matter of getting and assisting the 14 operation. And so, in effect, what the company did was to h 15 - take all of its resources -- and I say that, you know, 95 o
} 16 percent of the resources available at the service company at 0
I l 17 Parsippany -- and drop everything else and apply them to
, i ~
l} h 18 managing the accident and its aftermath.
=
i 19 MR. DENTON: I think it has been -- I, read in one 8
g M of the allegations that Unit 1 operations were the Cadillac
- 21 and Unit 2 were the Hudson. ,
Zi MR. ARNOLD: Studebaker, I think.
M (Laughter.)
24 MR. DENTON: Studebaker. Do you have any comment M on why there would be a difference in the way the operations
Go h31b8' were perceived on the Island? They were both under Meted's
~
I 2
control at the time.
3 MR. DIECKAMP: I would give you a generalized kind 4 of thought about it, is that by the time we got to 1978 and 9, 5 Three Mile Island Unit 1 had been operating for four years and 6 as a result had gone through a lot of that early learning 7
process, debugging process, getting the wrinkles out of the 8
system and getting it down to the point where it was operating 8 And there was no question.then that, as we very smoothly.
10 moved into Unit 2, we were starting over again on that debugging II kind of a process and, as-you recall, the start up program was 12 significantly extended because we encountered problems with 13 the operability of the safety relief valves on things:of 14 that sort which required major modifications.
15 -
And I think we also have to say that the organiza-4
'g 16 tion was sufferingithe problems of growing pains. It was 8 17 g a significant job to pick up from operating one plant to being
'* 18 y able to operate two plants, and those things all contributed i
18 to a difference in the smoothness, the happiness, the effective-I 20-i ness with which the operation was going forward.
21 MR. DENTON: To the extent there was a difference f
jj 22 in the quality of operation -- the reason-I'm asking is do you 23 think Bob Arnold was responsible for,the difference in,the quality of operations? He had left prior'to Unit 1 coming on-25 line and I thought, since these issues are kicked around and
BW4,syl 28 1
MR. CLARK: Let me suggest that we go back and 2 look at page 3 for a minute because I think the discussion 3 relates to the operation of the Service Corp -crf Metrolpolitan 4
Edison. If you look at the chart, you see a Meted quality 5 assurance, licensingj training, and under the Engineering, 6 design engineering, project engineering, radiation safety 7 and environmental engineering.
8 So the Meted organization had essentially all 9 of the elements that go with operating and maintaining the 10 plant, and could call on Service Corp as described. They 11 had the organizational responsibility and the people for all 12 of those aspects at TMI.
13 MR. DENTON: Did Meted generate any non-nuclear 14 power?
15* MR. CLARK: Yes.
16 MR. DENTON: So the Vice President for Genoration 17 also worried about fossil plants.
18 MR. CLARK: Yes.
19 MR. DIECKAMP: Yes.
20 MR. EISENHUT: How many different corporations, 21 then, were there in the overall system in addition to, say, 22 the Meted one? How many --
23 MR. DIECKAMP: If you look at GPU at the time, 24 reporting to the holding company, there were four subsidiaries; 25 operating utilities, Jersey Central Power & Light,
BW4,.sy2 29 1
Metropolitan Edison Company, Pennsylvania Electric Company 2 What happens in a holding and the GPU Service Company.
company is that the SEC requires that those things that would 4
normally just be called a corporate staff be identified as 5
a service company, and they tend to prescribe certain 6
accounting principles as to how those costs shall be allocated to the operating utilities.
8 And as you recall, Meted is a 50 percent owner 8
and operator. Jersey Central and Penn Elec were each 25 10 percent owners.
11 MR. CLARK: To go back to page 5, it shows GPU/
12 Nuclear. That is, of course, now a fifth subsidiary of the 13 Unless there are questions, General Public Utilities System.
14 I think we've pretty well gone through page 5.
15' MR. DENTON: I think we have. Are you going to 16 come back and cover Wilson, Long, Heward, there?
l 17 MR. CLARK: I forget if they show in this handout
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18 or not.
19 MR. ARNOLD: It would be better now.
- MR. DENTON: Yes.-
21 MR. ARNOLD: Let me pick up on Dick Heward first, 22 becuase he probably had the most involvement with Three Mile 23 Island. If you don' t hold me to the dates, I think I can 24 give them to you fairly representative 1y.
25 MR. CLARK: How about 19677 Heward was hired by
7@
-BW4,sy3 g
- p 1 P'en Elec in July of 1967, and as of 1974 went back to the 2 Unit 1, the license date y April 1974, Service Corporation 3 as Manager of Design, August of 1975, Project Manager of 4
M Generation and Service Corp., and in 1977, Manager of Projects 5 Service Corp, which continues through the accid'ent.
6 In all those cases, his office was located in New Jersey.
7 MR. ARNOLD: He initially came from Penn Elec.
8 The Service company was not formed until May of 1971. So 9 people who were with the nucleus of the service corp, what 10 became the Service Corp, prior to May of 1971 had to be on 11 one of the operating company payrolls. Dick Heward was never 12 really involved with anything other than the Service Corp 13 and its predecessor.
14 MR. DENTON: Let's use Mr. Heward as an example, 15* then. You know what is in the B&W/GPU lawsuit record probably 16 better than we do, but if we were to search through all of 17 that, would you expect to find eny mention of Mr. Heward?
18 MR. ARNOLD: I don't believe he was one of those 19 that were deposed. As I sense the things in the B&W 1awsuit 20 records, which have become'of interest, ones relating to the 21 design and construction side, probably have their earliest 22 one in September 1977 when we had the contamination of 23 Nuclear Services cooling water system that led to having to 24 shut down all of the auxiliaries for the reactor plant. The 26 reactor plant did not have fuel in it or anything at that time .
BW4;cy4 i
1 MR. DENTON: Would you expect him to be involved 2 in the Hartman allegation?
3 MR. ARNOLD: Let me finish up on that. Heward 4 had left,'being the Program Manager _Or .II-2 in about 5 August, as I recall, of 1977. And . 31ow by the name of 6 John Barton replaced him. Heward came back to Parsippany 7 or take a position at Parsippany where John Barton reported 8 to him, as well as the Forked River. And at that point, fall 9 of 1977, he-started transferring his major interests to 10 Forked River.
11 I would not expect Heward to have anything at all M to do with any of the allegations relating to -- that 13 Mr. Hartman has made. I reall'y. don't think so. I guess my 14 answer is no, I don't think he would even have anything to do 15' with any of the issues in the B&W lawsuit files that will be 16 of any concern.
17 That's kind of a long-winded answer for a simple 18 no.
19 MR. DENTON: Do you want to cover the other two?
20 MR. CLARK: Yes.
21 MR. ARNOLD: Bob Long came with us in early 1978, 22 as I recall. June of 1978, and Bob initially came into a 23 section of the Design and Construction Division of the Service 24 Corporation, which at that point was called Generation 25 Division, where we were providing corporate staff support to
1 officiency monitoring and improvsment progrcma. This is j 2 productivity; not from a manhour unit of work, but station 3 output. Station and capacity factor of the units. And l
1 4 Bob initially was the Manager of Generation Productivity. l 5 That had to do, again, with capacity factors of the plant, 6 not people productivity as such.
7 He then was promoted in August of 1979 to what i
8 was a predecessor really to the Nuclear Assurance Division.
9 So at the time of the accident, which I guess is really 10 of interest to us, at the time of the accident he was still 11 Manager of Generation Productivity and had no responsibility 12 for operations at the site and really no visibility in 13 day-to-day operations at the site.
14 MR. DENTON: Would you hazard an answer like you 15 did for Mr. Heward with regard to the record or the Hartman i
16 ' allegation?
17 MR. ARNOLD: I do not think that Bob Long would l
18 have anything to do with the Hartman allegation. I don't 19 think his name would come up in connection with that at all.
20 Dick Wilson --
l i
21 MR. EISENHUT: How about -- on Long, how about the 22 lawsuit, the same questions that you addressed for the 23 Hartman allegations?
24 MR. ARNOLD: I was trying to remember whether
- 25 Long had any involvement with the analysis made by Keaton
BW4,sy6 33
, ]
1 and Rogovin and others of what are now referred to as 2 precursor type events. I don't believe he did, Darrell. I 3 don't think he would even come up in any of the balance of 4 the B&W lawsuit records.
5 Dick Wilson initially joined the company as a 6 Manager of Quality Assurance in the Service Corporation in 7 March of 1973. He was put in charge of tech functions, which 8 was pretty analagous to what we have now in tech functions 9 except that in August of 1977, mid-1977, he became, in effect, 10 the Chief Engineer of the service company, Generation Division, 11 He did have at that time quality assurance underneath him 12 which is not a part of technical functions today. He did not 13 have licensing and environmental affairs, which is a part of 14 the tech functions today. So there is that change.
15- Dick would not have had anything in the way of 16 involvement in any of the Hartman allegations that I can 17 imagine. I think he would not be touched by that. He would 18 have had some peripheral type involvement perhaps with some 19 of the TMI-2 design issues, either as QA Manager or late in i
20 the completion of construction. It was his people, for l
- 21. example, that had to approve the architect engineer's fix for zt the steam generator steam safety relief valve problems, l 23 for example. But he was almost totally involved with Forked l 24 River in the year prior to the accident.
25 MR. DIECKAMP: With respect to the precursor event,.
BW4,Gy7 I 34 j 6
1 Bob Keaton reported to Dick Wilson? l 2 MR. ARNOLD: Yes. Bob Keaton was a systems 3 engineering manager for Dick Wilson at that time, so those 4 types of analytic capabilities were a part of technical 5 functions. And, of course, they have played a prominent 6 role in the B&W lawsuit discussions.
7 MR. CLARK: The only other one is the Finfrock, DetW$
8 he was with -Ned' Jersey Power & Light from about 1952 on and 9 was involved in Saxton and then Oyster Creek, but not with 10 TMI.
11 MR. GOLDBERG: On this chart, there is no shading 12 on the Board of Directors box, and does that mean the same 13 thing that the no shading did on page 3 of the chart?
14 MR. CLARK: I had the chart made up and I did not 15 ' view them as employees of the company, I guess is the reason 16 it's not shaded anywhere.
17 MR. ARNOLD: If it were coded, it would be coded 18 with the combination of the first two.
19 MR. DIECKAMP: Let me first define for you who is 20 in that box. That box includes Mr. Kuhns and myself. It 21 then includes the presidents of each of the subsidiaries that
%I own Three Mile Island, so that is the President of Meted,
%I Peed Smith, the President of Penn Elec today, Jim bevy,
[zNdLe 24 President of Jersey Central Power & Light, Bill Verrochi. l 25 It then includes two vice presidents from the Service company ,
1 l
I
- 1
BW4,sy8 35 I who have nuclear backgrounds but not involved in GPU/ Nuclear 2 today -- Vice President of Planning, Bud Cherry, Executive 3 Vice President of Electric Operations, Shep Bartnoff. And 4 then it's closed out with Bob Arnold and Phil Clark.
5 So that's the makeup of the GPU/ Nuclear Board of 6 Directors. None of those people had direct responsibility 7 for TMI-2 at the time of the accident.
8 Again, if you --
9 MR. ARNOLD: Let me correct what I said to you.
10 With the exception of Floyd Smith and myself,. tlie bottom 11 two categories, they are either new to this system or were 12 .not with Meted prior to the accident. You have heard my i
13 history. Floyd Smith was with Meted in 1975 and earlier, 14 something like that, but he was over in the electric operations 15 ' side. He had no involvement with generation.
cnd 4 16 17 18 '.
s 19 21 l
I 23 -
24 :
25 ,
.w.
9
j l 10, 4, 89 I commitment to the plant and safe operation of the plant is 2 very important. We cannot lose sight of that when we make 3 these kinds of changes.
4 MR. CLARK: I think the NRC people who were on the 5 site last week had an opportunity to interface with a lot of 6 the people. We are giving a calibration on that, but our 7 sense is it has gone well and better then we were afraid and 8 probably even a little better than we expected.
8 MR. DENTON: Shall we move to the next one?
10 MR, CLARK: Page 19, which is the Priorities and 11 Assignments within the Office of the President.
e 12 If you turn to the next page, which is unnumbered,
(
13 it is an enclosure -- maybe before you start reading that --
14 the Office of the President does have two people in it, 15 - Bob Arnold and me. And clearly, from the very beginning, we 16 have not both been doing everything.
17 And the agreement, when the Office of the President 18 was set up, was that each of us would have access to all parts 18 of the organization and all of the activities of the 20 organization, but that we would establish what has come to 21 be called " areas of concentration."
22 And what that means is that, first order, anybody 23 in that area looks to the designated officer, Bob or ne, for 24 their direction. That is who they report to. That is who 25 they send recommendations to. That is primarily overseeing
jl 10,35 90 I that activity.
2 We also made it clear that if you can't get to that 3 guy on something you need timely action on, you can go to the 4 other one.
5 So that the fact that I was in Europe, where does 6 Hukill go, he could go to Bob Arnold.
7 And this now is. the third version as, from time 8 to time, depending on the circumstances, there has been a 9 redefinition of where Bob would concentrate and where I would 10 concentrate.
11 And you will see that it says I will concentrate 12 on TMI-1. The last -- prior revision of this had that listed 13 for Bob and, conversely, had Oyster Creek with me concentrat-14 ing on it. In fact, that is what I have done with a good bit 15 - of time.
16 And then we take the other support divisions and 17 designate a lead.
16 So, I think the first two paragraphs of the memo, 19 which are not changed from the prior versions, describes what l
20 is meant by " area of concentration."
l 21 And then we, each one, make a definitive
'cnd 10 22 assignment.
El ,
24 26
Lcarne 91 i
min. into t.
Isji 11 1 1 MR. ARNOLD: We did do some editing of the second 2 paragraph, but it is intended to say the same thing in case 3 someone makes a comparison.
4 MR. GOLDBERG: In the restart proceeding, there 5 was concern expressed about your lack of familiarity with 6 B&W reactors and your need to rely on others for the detailed 7 knowledge of their operation, Phil.
8 Since the record was closed on that, do you feel 9 you have. gained familiarity that is needed to take over the 10 day-to-day responsibility of TMI-l? ,
11 MR. CLARK: First, the day-to-day responsibilities 12 for operating TMI-l is Hank Hukill. He is there on-site.
13 So, in no sense am I or Bob, for that matter, for W cinTNIL N W 14 areas of con.uisawien, day-to-day running, any of those to - operations. We have senior experienced people.
16 The ASLB hearing stipulation with regard to me went 17 to my role in the emergency plan as the Emergency Support 18 Director, which, in our terminology, is the senior company 19 official responsible for overall management of the emergency.
20 We did conduct and I did take a course in the l
21 TMI-l plant and systems, with specific regard to the emergency 22 planf so that the safety systems, the off-site release l 23 points, things of that kind -- as I recall, it ran about eight 24 or ten sessions of about three hours each, with about three 25 exams, all of which I took and passed and probably have
1122 22 I recorded it to clear the record.
2 I'm not sure how that happened.
3 I went back, Jack, and reviewed the MR. ARNOLD:
4 testimony I gave in the ASLB proceedings relative to my 5 And it included, I think, most of the area of involvement.
6 -- it included.the questioning of me as to Phil's background 7
and ability to fulfill his functions.
8 I am satisfied that what we are doing here is 8
not inconsistent with the commitments made before the ASLB.
10 MR. CLARK: I also went back and reread that 11 portion of the record.
12 MR. DENTON: Without getting to vacation coverage 13 and that sort of thing, let's take the routine responsibility 14 for TMI-1.
15-How do you two split that out, given that that 16 is your area now? What would be the normal way that you 17 would oversee that area?
18 MR. CLARK: Recommendations from Hukill with 19 regard to things on TMI-1 which would need action by the 20 office of the President would be directed to me. Guidance 21 from the office of the President for TMI-l would go from me.
22 I don't know whether that is responsive. It is 23 intended to be.
24 MR. ARNOLD: Harold, perhaps the next chart 25 f L maybeabletodescribethewapitworfsonaroutine, -
3
~
W 1 day-to-day basis.
2 The Office of the President has a major function 3 in providing the inter-divisional coordination and direction 4 that is needed, the integration of the support divisions with 5 the plant divisions and the providing of policy and general 6 direction on activities.
7 I think if our chart does not get too enthusiastic 8 -- we intended to have this identify how that would work on 9 the day-to-day with the nine divisions.
10 MR. CLARK: Let me read the paragraph: "The 11 officer listed below is lead for a particular activity, 12 listing about TMI-1. For TMI-1, I am the normal, direct 13 reporting point within the Office of the President for TMI-1.
14 Substantive written communications addressed to me should be 15 copied to Mr. Arnold."
16 And then, if you go on down through the rest, I 17 have the technical functions lead, I have the nuclear.
@viCD1 .
18 assurance lead, and I have the lead for RAGON and ...
19 environmental controls for TMI-1. Bob Arnold has them for 20 Oyster Creek. I have the TMI-l GORB, and I have the NRC 21 interaction for TMI-l for the Office of the President for 22 TMI-1.
D Now, the things I am not listed as the lead on 24 that would have some interaction with TMI are administration.
25 Now, that does not sound -- that is not saying I'm not 1
_._._______j
jl.ll:4 1 involved in it; I am. And it says, "If you are supporting 2 specific division interface with the office having the lead."
3 So, for TMI-l things, that would be me.
4 MR. DENTON: Let me ask a question.
5 As I remember Drucker from years ago, he said the 6 ability to reward and punish employees is sort of a key to 7 control.
8 What relationship do you have to deciding to 9 promote or demote or raise salaries and these kinds of 10 things?
11 MR. CLARK: Let's take salaries.
12 Bob and I have both reviewed in the past, and I 13 would anticipate we would in the future, review the salary 14 recommendations for senior people or anybody above a certain 15* 1evel. They are also reviewed by the Board of Directors.
16 And the salaries of all of the officers of the company, 17 which are the 10 people reporting to us, are set by the Board cnd 11 18 of Directors.
19 M
21 22 23 24 26
l3W12 ,rgi 95 1 Typically the person having the lead rceponcibility W
2 for the division hes discussions, has the most to say and has a
3 been given the most weight. He has the greatest visibility 4 of the people in that particular function.
5 MR. ARNOLD: I would also add, Harold, that in the 6 position description for the executive vice-president, and I 7 think we described this in the ASLB proceeding, I am not as 8 clear on it, we identify that the executive vice-president 9 has the same authority to act as the president does. Any 10 authority I have as a president, he has the equivalent author-11 ity to exercise when he feels it is necessary.
12 MR. CLARK: The, question that we have kicked around, 13 and we thought people would ask is, suppose for some reason 14 that the president decided to overrule me, and I think that
- 15. is a good question. And the answer to that is that it has 16 always been understood by me and Bob and the Board of Director s 17 that as a member of the Board of Directors, I clearly have, 18 and Bob and I both have, and would raise that kind "of a sub-19 stantive issue to the Board.
M MR. DENTON: I think this is an area that the 21 Commission is going to be interested in. If they decide that M they want to go forward in this, suppose you had to tell them D in 100 words or less what this inter-office memo means. I 24 have read the words here and maybe you can tell me one more 25 time about the extent that you see that you would be
BW12 rg2 96 l' responsible for day-to-day operations versus Bob being respon-2 sible.
3 MR. EISENHUT: What'it is not as well as what it is.
4 MR. CLARK: It is not a statement that Mr. Arnold i:s 5 excluded from any TMI-l activities. It is not that. It is 6 a statement that the normal direct reporting relationship 7 from the Director of TMI-1, who was the on-site guy running 8 that division and coordinating all activities in support of )
9 TMI-1, his normal direct reporting relationship is to me, that 10 he would address recommendations or requests for action whi'ch 11 need action by the office of the president to me. And that 12 I would respond. That he would copy them to Mr. Arnold on d
13 substantive things, I forget exactly how ye said it but 'sub-14 stantive things would be copied to Mr. Arnold just as in 15- divisions where Mr. Arnold has the lead responsibility they 16 would be copied to me.
17 MR. DENTON: Were you previously worried about 18 Oyster Creek? Bob would take over that.
19 MR. CLARK: Yes. One is Oyster Creek to him, TMI-l 20 to me. I think we switch the nuclear assurance. I think that 21 used to be the opposite way, if I remember.
i l
22 There are a number of things in there like RADCON 25 and GORB and NRC where it goes with the plant division.
24 Whoever has the lead for the plant division has the lead for 0M.
25 the GORD NRC interaction and a number of other things that
3PJ12 rg3 97 1 support that plant.
2 MR. THOMPSON: It might be helpful if you could 3 give Harold some examples of when it was switched the other 4 way, when you had Oyster Creek, the types of things that you 5 would normally handle and the types of things that you would 6 want to normally raise up to Bob.
7 MR. CLARK: I am trying to think of.Whati if any-8 thing there was in Oyster Creek that I had to review with B'ob 9 rather than advise him of what I was doing. And, frankly, 10 none come to mind. The setting of the outage schedule, those 11 things I thought I had the authority and did have the authorit'(
12 to act on.
13 However, Bob and I typically talk every day, every 14 other day. We share that office, so I was keeping him advised ,
15 - lIn terms of were there any that I could not have acted on if 16 he were not available. None really come to mind. I do not 17 want to say there weren't any.
18 MR. DIECKAMP: One of the kinds of things that Bob 19 has done, and I think very likely continues to do, which is 20 not shown on this chart, is the interaction with the State 21 PUCs. We have sort of tried to divide that job up so that 22 not everybody was totally consumed by it.
23 MR.' CLARK: That is the rate. case, the bulk of it, 24 as well as the communications.
26 MR. DIECKAMP: Does everybody understand the
3W12 rg4 1 extreme clevernses of the "crocc-your-haart" dotted linaa on 2 that chart? What that means is that the executive vice-3 president, if the executive vice-president wants to work on 4 something relative to RADCON and environmental controls, for 5 example, he does not have to go through the president to get 6 there. He can come directly on that subject.
7 And I think also one way to think about this is if 8 you thought about these two fellows divvying up their job of 9 working 90 percent on something versus 10 percent on other 10 things, this is kind of the 90-10 spot, and we need to keep 11 the ten there in order to keep the total organization working 12 as an entity, and in order that any one piece of the organi-13 zation does'not'become cloistered. So we have uniformity in 14 policies and awareness in coverage in case there is a need 15 for backup.
16 MR. DENTON: Let me ask you, Herman, how are you 17 going to assure that if the people down on the island do not 18 like Phil's guidance and are always running over to' Bob saying ,
19 hey, here's the way we really want you to do it, we want to 20 override him for this time and this time and this time, what 21 kind of instructions are you going to give them to keep the 2 channels straight? Or maybe you don't have that problem?
23 MR. DIECKAMP: My instruction does not go to the 24 people on the island. My instruction goes to Bob Arnold and 25 Phil Clark. And just as Phil Clark has been told that he is
SW12 rg3 99 l
I to be the lead guy in taking care of TMI, Bob Arnold hnc bacn 2 told the corollary of that, that he is not to be the lead guy 3 in TMI-l and is to not do those things. So I think as time 4 goes on, Harold, we will have ample indications of whether 5 this is working the way it is supposed to work. If it is not 6 working the way it is supposed to work, I would expect either 7 Phil or Bob to speak up in the Board of Directors meeting.
8 Again, I think '.t is important to note that while 9 we do have a degree of pecking order here, in order to main-10 tain organizational coherence and logic, we still have these 11 two fellows both participating in the Board of Directors, both 12 having direct access to the Board.and I think~that by means 13 of their past behavior, ample demonstration that they are both 14 willing to speak up when the time comes. That is what we
- 15. have to depend upon.
16 There certainly is no plan or hope that this be 17 subverted. In fact, we don't want that to happen. I think we 18 will have the visibility to know whether it is or is not.
19 MR. CLARK: Before we ever got into issuing these M memos, it was pretty clear to me and to Bob both that the 21 Board looked to us to share the office of the. president and H to raise to them substantive safety issues or programmatic 2 issues where we differed. I think that has been clear for .
24 three or plus years and is still clear. I think we will con-25 tinue to be clear.
9%12 rg6 loo 1 We also pointed out as we went through that there 2 are two or three places in t he organization where there is 3 direct access to the Board, around Bob and me.
4 The GORBs, the nuclear assurance division director, 5 and the quality assurance manager all have direct access to 6 the Board and exercise that on a routine basis.
7 MR. DIECKAMP: Again, you can ask yourself what doe s 8 the Board of Directors do. I think there is testimony on that 9 in the ASLB proceedings. But it does the same things that a 10 normal board of directors performs. It selects the key mana-11 gers. It maintains sufficient visibility in terms of the 12 operation so as to gain an. awareness of whether those key 13 managers are doing the job or not. It reviews and approves 14 those major policy issues that may impact the total operation, 15- its effectiveness or its safety or its budgets.
16 And af ter that, it determines the compensation of 17 the officers of the organization. We do that by means of a 18 monthly meeting where Bob and Phil carry most of the laboring 19 or providing to that Board of Directors meeting on a struc-20 tured basis a review of certain parameters that we have chosen 21 to be indicative of the perf[ormance of the performance of the l
22 organization.
23 And then, after reviewing that, to talk about 24 specific problem areas that GPU Nuclear is grappling with or 25 specific issues where we need to more or less work out what
1 is our attitud3 toward tho00.
2 We also have that Board to visit each of the plant 3 sites twice a year so that the Board not only has visibility 4 of Bob Arnold and Phil Clark, but when we go to the sites, we 5 purposely arrange the agenda so that members of that operating 6 plant staff come forward and make presentations to the Board 7 so that we can see those people and gain some insight into 8 them and their capabilities.
9 MR. DENTON: Let me probe this area a little bit 10 further. As you know, we have a matrix organization, so 11 usually when 1 meet on a project I also have to have technical 12 staff there. If you look at your normal day-to-day operations, 13 when you used to meet on Oyster Creek for exampic, did you 14 also have tech functions or do you give more time to the 15 operating plants, more time to the other technical functions?
16 How did that -- how does your activity break down?
17 MR. CLARK: I'm not sure if I have precise functions.
18 Tech functions is in Parsippany. I would be review ~ing the 19 individual matters, programmatic matters with the director N of the tech functions two or three times a week. A specific 21 item,'I might'be in touch.Q1th him on the phone.
22 I get a daily report on the operating status 23 from the plant every morning and go through the plant status 24 releases, any incidents, things of that kind. I typically 2 talk to the director of the plant most days, but certainly I
I
BWie fgo 102 0
I every other day.
2 And I was visiting Oyster Creek, probably every 3 other week, sometimes every week depending on what was going 4 on. During the visits, I would interact with the plant 5 director, some of his staff and not infrequently have a 6 meeting where we would get everybody together. In that case, 7 it was preparations for the outage, for how were we doing at
~
8 the outage. That kind of review would have Oyster Creek di-9 vision tech functions divisions, WUXDN,QA, and I guess I would 10 foresee the same kind of interaction with TMI-1.
11 MR. DENTON: Nhen you switch, say, Oyster Creek and 12 TMI-1, does it mean a whole new bunch of relationships with 13 people? Do you have to get to know them, or have you two 14 worked so that the plants know you already?
15' MR. ARNOLD: What Phil described what he was doing 16 for Oyster Creek, he was doing perhaps at least half of that 17 type of effort for TMI-l right along as well. While we would
~
18 try to both be at TMI-1, say, preparation for restart meetings 19 and things like that, if it came to a priority between TMI-2 ar.d 20 THI-l then I would typically cover THI-2 and he would cover 21 TMI-1. So I think he has every bit as much both currency 22 in terms of TMI-l activities and conditions and the relation-8 ships developed there that he has got for Oyster Creek.
24 MR. CLARI(:
N I had 4e lead on the technical end of 25 the steam generator problem for TMI-l that was being run
4 1 basically by tech functions from Parsippany. I had the lead 2 for tech functions. I was there. I have a design background 3 so I was heavily involved in that.
4 I have known Hukill far longer than Bob has, from pre-5 GPUN days. I had a lot of interaction with Colitz, Toole.
6 I think many of the licensed operators would recognize me and 7 I certainly know the RADCON and quality assurance people out 8 there. It is not starting from scratch with any of the 8 relationships. I know those people.and I think they know me.
10 MR. EISENHUT: I'm trying to get a better feel, 11 Bob, for what you just said. If you're going to a meeting 12 where you are getting ready for_a. restart, do pou' typically 13 having both been there in .the.past, .do you envision that in the 14 future?
15 - MR. ARNOLD: I think to the extent that we can put 16 that much of our joint time into it, yes. But I think what 17 we would continue is what we really have been doing. If there 18 is a conflict in our time, then whenever possible I've had 18 Phil stay with TMI-l and I take care of the TMI-2 or the PUC 20 or whatever it was that created the conflict.
21 MR. CLARK: Like where are we on the Oyster Creek 22 outage? And if we have a major programmatic review of where 23 are we on the Oyster Creek outage hereafter, Bob would clearly i 24 be there and if I could, I would too. But it is such'a big
! # part of the overall nuclear operation that I do not want to L~ +
\
I be 100 percent divorced from that .
l 2 f!R. DIECKN!P: Ine. contrast with all of the day-to-3 day coverage and communications and decision-making, those 4 kinds of major reviews constitute the good opportunities for 5 the two members of the office of the president to stay glued End 12. 6 together on what is happening.
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f 4
"DE SENIOR MANAGEMENP RESPCNSIBLE FOR OPERATION OF 'IMI-l 'IODAY IS DRAMATICAILY DIFFERINP THAN MRT WHICH EXISTED AT ME TIMS OF TE ACCIDENP.
IN STRUC'IURItU GPU NUCLEAR WE IRVE PROVIDED DEDICATED ON SITE PERSONNEL FOR EACil OF TIE GENERATING STATIONS WITil A IIIGILY EXPERIENCED SENIOR MANAGER ON SITE. WE IIAVE PROVIDED EXPERIEtGED MANAGERS AND STAFF FOR A NtNBER OF CENTRALIZED SUPPORT FUNCTIOtB SUCII AS ENGINEERING, IEALTI PilYSICS, QUALITY ASSURANCE, TRAINItG, MAINPENANCE, hND CCNSTRUCTION IN ORDER 'IU mr.CPIVELY SUPPORT DE STATION MAtEEMENT."
- H. DIECKAMP IEITER DATED 6/10/83 6/27/83
_ _ _ . _ . _ __ _ . _ _ _ _ _ _ _ . _ _=-
BOARD
, . . . . . . . . . . . . . . . . . . . . . . . . OF DIRECTORS ....
...................s
- GPU NUCLEAR :
i CORP. i
_1____, :
I _ _ _0FFICE OF THE i
! l PRESIDENT i l
i l
l hI D L ll l I
GPU Nuclear dorporation i l ::::: EXECUTIVE *:::: I i i l :: VICE PRESIDENT *:: l j i l :0 P.R. CLARK !
- l
- g :0........ . .... ... ... .:.:-
g
. CHAIRMAN GORB ,
- l. R. FINFROCK. JR.-
I f//////////l/I LEGEND I ! I i ::::::::::':::::::'::::::::: :::0:::::::0: *- ':0:0:::: :0::0:
O WITH MET-ED ANYTIME PRIOR i :.VICE PRESIDENT.:. : VICE PRESIDENT : ::::::IllRECTOR;::::::
TO 3/79 i :5 0YSTER CREEK,::: I* O *
- T M i-1 : :: ; :.:0 TMl-2 :.:.: ..:.
CIS NEW TO GPU SYSTEM SINCE 3/79 j '
- :P. 8. FIEDLER ;*::
H. D. HU KILL. JR. :
- :B. K. K ANG A*0:-
O NOT WITH MET-ED PRIOR TO 3/19 j O:O*0:0:0::O*~ : .*. ?: .: 0::(BECHTEL)::O' i
- OPERATIONS e OPERATIONS e OPERAIl0NS
- FR SITE e ADMINISTRAll0N e ADMINISTRATION
- ADMINISTRATION e PLANT ENGINEERING e REC 0VERY PROGRAMS
- PLANT ENGINEERING e MAINTENANCE j
- MAINTENANCE e PLANT ENGINEERING e MAINTENANCE I i l
.j VICE PRESIDENTi;
. . - . - ............ . . . . .. i I
i VICE PRESIDENT i V ic'iPIl5S'li)5'.' , ' VlC
' ' h ' PRESIDENT : ', jRAD.& ENVIRON :VICE : VICE PRESIDENT :
' TECHNICAL i , NUCLEAR .. :.
PRESIDENT;!
- MAINTENANCE a
FUNCTIONS : ,:: ASSURANCE:: COMMUNICATIONS
- - ADMINISTRATION :'.
, E. E. KINTNER -
- CONTROLS: , . CONSTRUCTIDN--
.- . . W. L. GIFFORD... . -- ' -
i R. F. Wits 0N!! .
R. L. LO NG :.:.,.,..,.,.,.,.,...:.:
0........
.. . . ........ . . . . .:.: !R. W. H EWARD. JR.:
.:F. F. M ANGAN ARD :
e SYSTEMS
- OUAL.ASSUR. e flSCAlllNFORMATION e PUBLIC AFFAIRS e IRAINING e UNIT I RAD CNil e MAINT. & CONST. TMl 1 e ENG. & DESIGN MGMI. e PUBLIC INFDP.MAf t0N e NUCLEAR SAFETY . e UNIT 2 RAD CNil e MAINT. & CONST' e LICENSING e MATERIALS MGMT. e SPECIAL PROJECTS e DC RAD CNTRL ASSESSMENT e ENG. PROJECTS e SECURiiY. e ENVIRON CNTRL OYSTF9 CREEK e EMERG. PtANNING FACillilES. INDUS. e RAD ENGINEERING e STARTUP & TEST SAFETY & HEALTH e RAD ASSESSMENT
- ENG. SERVICES
- HUMAN RESOURCES 6/27/83
- SYSTEM LAB I
0FFICE OF THE
! PRESIDENT l l l PRESIDENT !
GPU Nuclear Corporation l R.C. ARNOLD l
1 I I I I I LEGEND l EXECUTIVE l TOTAL l VICE PRESIDENT l A APPROXIMATE TOTAL EMPLOYEES l P. R. CLARK l
APPLIED TO TMI-1 922 .g l
B KEY PERSONNEL INCLUDING ~ ~ ~ ~ ~~~~~~
MANAGERS, TECHNICAL /
PROFESSIONAL AND LICENSED OPERATORS 442 CHAIRMAN GORB
- 1. R. FINFROCK, JR.
C NUMBER OF THOSE IN "B" NEW TO SYSTEM (POST 3/79) 233 D NUMBER OF THOSE IN "B" NOT WITH MET-ED (PRIOR TO 3/79) 100 I
! VICE PRESIDENT TMl-1 - 5 H. D. HUKILL, JR.
C- 30 D- 3 I I I I I I VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT TECHNICAL NUCLEAR ADMINISTRATION COMMUNICATIONS RAD. & ENVIRON. MAINTENANCE &
FUNCTIONS ASSURANCE R. F. WILSO N R. L. LO N G E. E. KINTNER W. L. GIFFORD R. W. H EWARD, J R. F. F. M ANGANARD A-155 A-130 A-195 A-15 A-70 A-30 B-105 B-100 B- 55 B-10 B-60 B-15 C- 40 C- 80 C- 24 C- 3 C-45 C-10 D- 45 D- 15 D- 20 D- 2 0-10 D- 5 6/27/83 f
i' i
"A BIERD IDOK AT TIE ELEMENIS OF GPU NUCLEAR WEIIOl WILL BE INVOLVED IN '11E OPERATION OF 'INI-l REVFALS 'IllAT 'I1E ORGANIZATION, DOWN 'I11ROUGil 'IWO LEVELS OF MANAGD1ENP BEIIM 'ITE GPU NUCLEAR VICE PRESIDENIS, ENC 04 PASSING 86 SUCil POSITICNS, CONPAINS 16 INDIVIDUALS THAT WERE WI'IR METED PRIOR 'IO TIE ACCIDENP. OF 'I1E BALANCE, 30 ARE NEW EMPIDYEES SINCE 'ITE ACCIDENP AND '11E REMAINING 40 CDE FRCM OI1ER 004PONENIS OF TEE GPU SYSTEM. 'I1E EXIIITPIVE V.P. OF GPU NUCLEAR AND TIE VICE PRESIDENP DIRECTLY RESPCNSIBLE EUR 'IMI-l SITE OPERATIONS ARE NBl."
II. DIECKAMP IEITER DATED 6/10/83 6/27/83 4-e
GPU NUCLEAR CORPOPATION CCNPOSITION AND PRIOR HIS'IORY OF MANAGH4ENT ItNOLVED IN 'IMI-l ACTIVITIES (EXCEPT STRICTLY ADMINISTRATIVE FUNCI' IONS) DOWN THPGGH 'IWO LEVEIS BELN DIVISION V.P.
Ebployee of MetFd Office of President (3) Prior to March 1979 Gamment f
President Yes . Develognent & performance of 9/69 to 5/77 GPUN Organization 3/79 to date
. NRC SALP
. INPO
, Special NRC Inspection
. Safety Overview & Checks
( designed into organization including:
GORB, Dir. Nuclear Assurance &
Quality Assurance Dir. with direct access to Board of Directors
. Shares Office / President with Exec.
V.P. who also sits on Board of Dir.
Executive V.P. No k
. . . . "'IMI-l will report to the Executive Vice President and such that he will be able to devote his prime attention to D1I-l matters."
Chairman - Gen. Office Yes . JCP&L Employee 5/71 - 12/82 Paview Boards (GORB) 6/52 to 5/71 . Assignments: Non-Nuclear 6/52-8/59 Saxton 9/59 - 7/64 Oyster Creek 8/64 - 7/81 Division Technical Functions (31) None except:
311-1 Start-up Technical & regulatory and Test Mgr. . Indirect role in plant safety.
adequacy of all activities
. Others set acceptance criteria.
. Signoff by Plant.
. Subject to Quality Assurance Plan, etc.
Nuclear Assurance (16) None Quality Assurance Nuclear Safety Assessment Emergency Preparedness Training bhintenance & Oonstruction (9)
Establish policies, practices None except: . Indirect impact on safety -
& procedures for Maintenance & M3 r - M&C . Does not set requirements for work Construction - carry out major Planning 'IMI-l or verify completion maintenance & modifications . Quality Assurance Plan & other overviews apply to M&C work 6/27/83 ,
L..
m Employee of Meted Prior to March 1979 Coment Division (continued)
. Radiological & Environmental (10) One 1 Controls Division Radiological . Indirect role in plant safety-Training Mgr.
Establish and implement . Establishment & Enforcement Radiological & Environmental of Nuclear Management policies, practices and pro- Direction & Policies cedures and carry out monitor-ing and survelliance programs. . Performance as evaluated by ASIR, SALP, INPO, Special NRC Inspection
. Organizational Design provides multiple overviews & checks
'IMI-1 Division (17)
Operate 'and maintain 'IMI-l safely, consistent with corporate requirements, and in compliance with laws, regulatory requirements and technical requirements.
V.P. No Operations & Maintenance Director No 3 #
- Mgr. Plant Operation Yes . Establishment & Enforcement of Nuclear Management
, Ptyr. Plant Chemistry Yes , Direction & Policies Mgr. Plant Maintenance Yes Performance as evaluated by i.
ASIB, SALP, INPO, Special Admin & Technical Support Yes NRC Inspection J
. Organizational Design provides multiple overviews & Checks'
\
6/27/83
,g.
9 Employee of MetFd Prior to March 1979 Comment Division (continued)
. IMI-l Division (continued Plant Engineering Director Yes f
l Establishment & Enforcement of Lead Mechanical Engr Yes Nuclear Management Direction
& Policies Imad Nuclear Engr. Yes
. Performance evaluated by ASIR, Lead I&C Engr. Yes SALP, INPO, Special NRC
) hInspection Lead Electrical Engr. Yes Technical Functions role Fire Protection Yes including Design Control &
Review of Operating and Special Project Yes Emergency Procedures Chemistry Yes i Overview, particularly IOSRG Mgr. Plant Administration Yes Coordinating Indirect r_de Mgr. Plans & Programs No
'Ibtal 86 a
i s
I l
6/27/83.
A _.-*** -
ie-'
m , -- m, m _ ~ :_,
~ "AT ME TIME OF RESTARP WE EXPECP 'IO 11rILIZE 38 CURRDf1LY LICENSED OPERA'IORS FOR 'IMI-1; 25 ARE NNLY LICDISED SINCE
'I1E ACCIDENP. OLTP OF ME RD1AIN1NG 13 TIAT WERE LICENSED AT ME TIME OF 'INE ACCIDDff,10 ARE ASSIGNED 'IO SilIPP ACTIVITIES.' WlESE OPERA'IORS NEED 'IO BE VIBED AS A SOURCE OF EXPERIENCE FOR 'I1E SAFE OPERATION OF 'IMI-1. 'ITEIR PROSPEnrIVE PERFOBMANCE MUST ALSO BE ASSESSED IN LIGTP OF (1) 'IllE FACP TilAT ALL llAVE BEEN LICENSED UNDER TIE NEW
'IESTIts CRITERIA, (2) 'I1E ABILITY OF GPUN 'IO PROVIDE 6 SIIIPP COVERAGE FOR 'IMI-l WilIGI PROVIDES ONE SilIPP Olff OF SIX FOR TRAINItD, (3) 'I1E PPESENCE OF SilIPP TECilNICAL ADVISORS, AND (4) SIGNIFICANPLY IMPROVED PROCEDURES.
. AS FURTIER ASSURANCE:
- 1) WE WILL, PRIOR 'IO RESTART, REASSIGN PERSONNEL SUQi TIIAT NO 'IMI-2 LICHEED OPERA'IOR WILL OPERATE 'IMI-l <
f (EXCEPT FOR 'ITE MANAGER OF OPERATIONS WID WAS LICENSED ON UNIT 2 BLTP WID WAS EVAIlJATED IN DEPTil AND SPECIFICALLY ENDORSED BY 'I1E ASIB) . . . "
l
'II. DIECKAMP IEITER IATED 6/10/83 6/27/83
/
Current Holders of 'IMI-1 Licenses SRO License 21 Status Title Current License # Cbmment Will not be Shift Supervisor ' ' SOP 3084 licensed at tigr. Radwaste Ops. SOP 2485 restart Supv.ibn-licensed SOP 3704 Op. Trng.
(3) f Licensed on Unit MJr - Operations SOP 2053 . Heavily reviewed by ASIB 1 and 2 prior to Ross including cheating 3/79 (1) proceedings i.Performanceasindicated in SLAP-Special Review
. Parely functioned on
. Unit 2 Reexamined 1982 Cross Checks 4
.% e Licensed prior Shift Supervisors SOP 4113 . Relicensed under new to 3/79 Shift Supervisor SOP 3235 procedures Shift Supervisor SOE3273 . ASIE Feview of cheating Shift Supervisor SOP 4263 g Special'NRC Faview Shift Supervisor SOP 2783 ,. Cross 01ecks including Engr Sr II SOP 3393 . Shift Technical Supv. Simulator Inst. SOP 2784 survelliance (new) 2.gc. .t n. Sr. III SOP 2702 . Management Ehforcement (License being dropped) )g of Policy & Practice h (7)
Licensed Shift Foreman SOP 4358 subsequent Shift Ebreman SOP 4361 to 3/79 Shift Ebreman SOP 4395 Shift Foreman SOP 4460 -
Shift Ebreman SOP 4245 Shift Foreman SOP 3703 Shift Tech Mvisor SOP 4359 Shift Tech Mvisor SOP 4114 Shift. Tech Mvisor SOP 4360 x i (9)
Total SRO~
Licensees at Restart l -17 4
4
% 7 t.
' {I
- 6/27/83
. . -- - ~.:. w a , -
Current Holders of 'IMI-1 Licenses (con't)
RO License Status Title License Comment Will not be Control Room Operator OP5010 licensed at Restart (1) s r.
Licensed on Unit Shift Foreman OP4888 . Relicensed under new 1 prior to 3/79 Control Room Operator OP5915 procedures Control Roca Operator OP3604 f . ALSB Paview of cheating Control Room Operator OP4642 . Special NRC Review Control Pocm Operator OP4101 4. Cross checking including l (5) , Shift Technical Surveliance (new)
. Mmagement Enforcement Policy & Practice s
Licensed sub- Control Room Operator OP6229 sequent to Control Pocm Operator OP6293 3/79 Control Room Operator OP6294 Control Rocm Operator OP6295 Control Room Operator OP6296 Control Rocm Operator OP5913 Control Poom Qoerator OP5751 Control Poco Operator OP6292 Control Poom Operator OP6230 Control Pocm Operator OP6297 Control Room Operator OP5909 Control Room Operator OP5910 Admin Nuc Tech Trng OP6030 (13)
Total current (18)
PCs to be licensed at restart Recently passed Control Rocxn Op (to be assigned)
NRC Reactor OP Control Poom Op (
)
examination Non-Licensed Op Trng (
)
(3)
'Ibtal RO Licenses at Restart (21)
'Ibtal Licensed ,
at Pestart (38) 6/27/83
i l-t
' 2) . "WE WIIL, PRIOR 'IO RESTART, ADD EUIL TIME ON SIIIFT OPERATIONAL QUALITY ASSURAtCE COVERAGE BY DEGREED ENGINEERS LNPIL THE OPEN ISSUES ARE RESOLVED. WE WWLD DEFER 'IO TIE NRC S100LD IT WISil 'IO PROVIDE FULL TIME ON SiiIET RESIDENP INSPECIOR COVERAGE OF 'IMI-l OPERATIONS."
'IUIS IS IN ADDITION 'ID SHIFT TECINICAL ADVISORS (STA).
H. DIECKAMP IEITER DATED 6/10/83 6/27/83
"IN ORDER TO PIO/IDE ADDED ASSURANCE:
, WE WIIL REASSIGN PERS0tNEL SUCH M1AT M10SE FUNCTIONS WHIO1 PIO/IDE AN OVERVIEW ASSESENENP, ANALYSIS, OR AUDIT s:
.' . OF PIANP ACTIVITIES SPECIFICAILY;
' GENERAL OFFICE REVIEW BOARD b INDEPENDENP ON-SITE SAFE 1Y GROUP SHIFT TEONICAL ADVISORS O/A AUDIT.
O/A AND O/C SITE STAFF
- ' LICENSING RADIATION CONTROL i EMERGENCY PREPARE 0 NESS WIIL CONTAIN ONLY PERSONNEL ~WI'I11 NO PRE-AOCIDENT INVOLVEMENP AS EXEMPP MENED EMPIDYEES AT iMI-l OR 2. WE WIIL 00NPINUE 1111S CONSTRAINT UNTIL TtE OPEN ISSUES ARE mu;PIVELY RESOLVED."
, H. DIBCKAMP IEITER DATED 6/10/83 6/27/83
ELUCTIONS WHICH PROVIDE AN OVERVIBd ASSESSMEIC, ANALYSIS, OR AUDIT OF PLAtc ACTIVITIES Employee of Meted General Office Paview Board Prior to March 1979 Comment
-- Consider potentially signiti-cant nuclear and radiation cafety and related management matters
-- Reports to office of the President, GPUN. Has direct access to Board of Directors, GPUN --
10 members - 5 GN U,
- 5 Out.,ide Chairman GORB . Assignments: Non-Nuclear 6/52-8/59 Saxton 9/59 - 7/64 Oyster Creek 8/64 - 7/81 SEE PAGE 18A Cbrporate Nuclear Safety Assessment Department (NSAD)
-- Investigate assess & recommend...
to assure overall safety.
Reports to VP & Director, Nuclear Assurance Division.
Manager plus 3 professionals None Independent On-Site Saff;ty Review Group
-- Ebil time - on-site Reports offsite to Manager, NSAD -
Manager + 4 professionals Two (Reassign prior to restart and until resolution of uncertainties) 6/27/83 J , _ -
Et)NCTIONS WHIOi PRNIDE AN OVERVIDi ASSESSFENT, ANALYSIS, OR AUDIT OF PIRTP ACTIVITIES Employee of !%tFd Shift Technical Advisors Prior to March 1979 Coment
- Degreed engr. apecifically qualified. On-Shift - Report to Technical Functions Division -
not to Plant 7 One Reassign prior to Festart.
Radiological Controls
- exempt personnel below management 13 None Emergency Preparedness
- exempt personnel below management 5 One Beassign prior to Restart Licensing
- exempt personnel below management 12 None
?
_-17 _
~,, _
- 6/27/83 . -
BJNCTIONS MIICH PPOVIDE AN OVERVInf ASSESSMC7P, At& LYSIS, OR AUDIT 01 DLANT ACPIVITIES Exempt Meted Employee Assigned to 'IMI Site Division 3/77 to 3/79 (bmment Quality Assurance QA Audit & O/A O/c
'IMI-l Site Staf f 52 Ops OA Mgr Provide replacement coverage for 'IMI-l prior to Restart Maint M&I Provide replacement coverage Monitoring Supv for 'IMI-l prior to Restart Ops Radeon Provide replacement coverage Monitoring Supv for 'IMI-l prior to Restart QC Inspector Provide replacement coverage for 'IMI-l prior to Restart QA Engineer Provide replacement coverage for 'IMI-l prior to Restart QC Project Provide replacement coverage Engineer for 'IMI-l prior to Restart QC NDE Welding Provide replacement coverage Supv for 'IMI-l prior to Restart Admin Trng Monitor Provide replacement ~ coverage for 'IMI-l prior to Restart
'IMI Audit Supv Provide replacement coverage for 'IMI-l prior to Restart QA Monitor Provide replacement coverage for 'IMI-l prior to Restart l
6/27/83 b
= % e & , ^a e- 5 u- .- --
1 GPUNC MANAGD4ENT OR OVERSIGff PERSOtMEL WID WERE MEMBERS OF THE PREDECESSOR 'IMI GORB PRIOR 'IO !
'IO 3/79 DATE OF ASSIGNMENT TO PRESE2TP POSITION PREDECESSOR 'IMI GORB
. President 02/73*
. Chairman GORBs 03/72-
. V.P. Radiological T. Env. Controls 11/69
& Member 'IMI-l GORB
. Dir. Licensing & Pegulatory Affairs 09/71
& Member 'IMI-l CORB
. Outside Member 'IMI-l GORB 11/69
. Outside Member 'IMI-l GORB 01/79 CIM4EtTFS:
. Open issues unlikely to involve these individuals solely because of their prior GORB membership. Any other sources of vulnerability are considered and addressed above (pp. 8 to 10 and 16 to 18).
. Current 'IMI-l GORB strengthened relative to 3/79 Structure and controls of GPUN provide better visibility of day to day performance and permit more effective review.
Previously two outside members; now a minimum of three required.
- Greater emphasis on GORB role and functions reflecting lessons from 'IMI-2 accident.
- Chairman's only other assignments are Chairman of 'IMI-2 and Oyster Creek GORB's Ebrmal direct access to Board of Directors.
Increased Staff Support.
- Expanded use of subcommittees.
% ft GORB 3/77 6/27/83
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Inter-Office Memorandum OCl' June 9, 1983 Subject Areas of Concentration for the Office of the President To Vice President, TMI-l Director, TMI-2 location Headquarters /Parsippany Vice President, Oyster Creek Acting Director, Administration Vice President, Canmunications Vice President, Radiological & Environmental Controls Vice President, Maintenance & Construction Vice Pr.esident, Technical Functions' Vice President, Nuclear Assurance Chairman, GORBs The Office of the President memorandum, same subject, dated January 22, 1982, described the then current areas of concentration for the Office of theeffective tion President. This July 1, memorandum describes revised areas of concentra-1983. It supersedes prior guidance.
The officer listed below as " lead" for a particular activity is the normal direct reporting point within the Office of the President for the subject activity. Substantive written communications addressed to the of ficer with lead for a particular activity should be copied to the other O/P officer. As before, any item can be referred to, or addressed to, either the President or the Executive Vice President in cases matter in where the other is unavailable on a schedule suitable for the question.
AREA O/P LEAD ~
TMI-2 President TMI-l Executive Vice President Oyster Creek President Technical Functions Executive Vice President (Vice President, Technical Functions will assist the Executive Vice President in keeping the President briefed on Oyster Creek and TMI-2 specific activities)
Communications President l
I l Accoos4e
~
q r r- '? .
-_ -v~e._ s . ._- _ - _
l Areas of Concentration for Page 2 the Office of the President June 9, 1983
{
AREA O/P LEAD Radiological & Environmental controls:
- Plant Specific President or Executive Vice President with lead for the Plant e General / Headquarters President Administration President NOTEi* Administration Division activities in support of specific Divisions should interface, as appropriate, with the officer having the lead role.
Nuclear Assurance Executive Vice President (Vice President, Nuclear Assurance will assist the Executive Vice President in keeping the President briefed on Oyster Creek and TMI-2 specific activities)
Maintenance & Construction Executive Vice President (Vice President, Maintenance & Construction will assist the Executive Vice President in keeping the President briefed on Oyster Creek specific activit(.1s)
GORB Same as Plant Rate Case President External Matters President (other than NRC)
NRC e Plant Specific.
Same as for Plant involved e General Executive Vice P esident R. C. ld President pk cc Executive Vice President GPU Nuclear Board of Directors
., s. . . .en a ~
- f ' ' ~ ' " ' f
AREAS OF 00tCEtRRATION FOR OFFICE OF PRESIDE;R GPUN g____. BOARD OF DIRECTORS l
l l
I I
I I
I I
I PRESIDENT 7
I g EXEC. VICE i
l PRESIDENT l
I 4 /
/
TMI \
/
- TMI-2 i N
'- - - - NA- Y
/ \
- 0.C .
M&C- / \ -R&EC g
TECH. FUNC. - ,
- ADMIN.
- COM M.
b 6/20/83
C - ..
r- Herman oi:ckamp *
- - Pres. cert J
~
L, GENERAL i PUBLIC E:Ws e
ha J
n UTILITIES
- twtNi CORPORATION 100 Interpace Parkway Parsippany. New Jersey 07054 201 263-6500 TELEX 136-482 June 10,1993 Writer's Direct Dial Number The Honorable Richard Thornburgh State House Harrisburg, Pbnroylvania 17120
Dear Co/ernor 'Ihornburgh:
In your letter of June 2 to Chairman Palladino, you expressed concern about a number of issues relating to the restart of TMI-1 and stated specifically:
"I would find it particularly inappropriate for the Cammission to take such action prior to hearing this Canmorwealth's appeal on 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 revie.v of the actiors that we can take to resolve this issue and to provide assurances with respect to other isstas. We want to inform you of the follcwing commitments on the part of the Canpany with respect to the three remaining outstanding issues on which the Commonvealth filed exceptions with the Atonic Safety and Licensing Appeals Board on August 20, 1982.
- 1) The Company will not utilize anyorn to operate TMI-l who was found by the ASLB to have cheated on an NRC administered licensing exam or on a conpany administered training exam (Mr.H.).
- 2) The Canpany will not utilize Mr. DD (whose attitude was criticized by the ASLB) to operate TMI-l or to train operating license holders or trainees.
- 3) The Canpany will direct the ASLB mandated training audit to specifically evaluate Mr. DD's performance as an instructor and the Canpany will conply with the findings in a timely and appropriate manner. Prior to the audit the Canpany will continue to moni tor Mr. DD's performance and assign wor % consistent with that performance.
We believe that these conmitments remove the concerns that are the subject of the Conmonvealth's appeal before the Atonic Safety and Licensing Appeal Board.
We will be informing the NRC, with a copy to you, of additional ccmmitztents that we will also be ccmpletityg prior . to restart so as to pro /ide additional assurance regarding protection of public health and safety and a further basis for confidence in the integrity of the managenent and staff which will be irnolved in the operation of IM1-1. ,
Si e oly, j r
K. eckamp La Ida Jersey Central Pow r & Ught Company /Metropo!.f an Edison Company / Pennsylvania Electric Company 7 _
..+ . . - . , , .
.s
- o .
,
- Herrnan 0'eckamp * '
, . . Pres. dent m ' GENERAL
'p'. L
. I7 I PUBLIC UTILITIES
- $2 4 CORPORATION 100 Interpace Parkway Parsippany. New Jersey 07054 20t 263-6500 TELEX 136-482 Writer's Direct Dial Number J une 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 ta ted, "because of all the open issues . . . . the s taf f can draw no conclusion regarding management integri ty at this time". Addi ti onally, the Commonwealth of Pe n ns ylv ani a 's " Supplemental Comments" of June 2, 1983, s ta ted that, "the Commonwealth will not support the res tar t of TMI-l until i t receives adequate assurances from the Commission that the management of GPU Nuclear Corporation is willing and able to operate the plant in a safe and compe tent 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 pas t have not been carried forward and will not manifest themselves in GPU Nuclear.
We retain confidence in the capabili ty and integri ty of the GPU Nuclear organi zation and personnel. The basis is further evidenced by the in-depth assessment conducted by the Licensing Board, as well as by independent measurements by indus try's INPO, NRC's SALP and other inspections and by Licensee 's own cons ultants .
As a preliminary matter, it is useful to review the Me tEd organization that was responsible for operation of the TMI Station 1
Jersey Central Power & Light Company /Metrocchran Edison Company /Pconsylvania E!ectric Company .
- l
. . r ,, s
1
-* . ? . . i
,- o . ;
1 at the time of the accident. No member of Me tEd's/TMI se ni or management is now involved wi th TMI . Four levels of management, the Me tEd president, v i ce -pre s i de n t , 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 exis ted at the time of the accident.
In s tructuring GPU Nuclear we have provided dedicated on si te i . .
personnel for each of the generating s tations 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 engineeri ng , health physics , quali ty assurance , t rai ni ng ,
mai n te nance , and cons truction in order to e f fectively support the s tation management. Addi tionally,- the organi zational s tructure was specifically designed to provide inhe rent checks and balances. GPU Nuclear, i ts operational philosophy, i ts senior managers , and numerous other key personnel wi thin the organization were reviewed in depth and endorsed by the ASLB. Over one hundred individuals ,
including top managers, appeared before that board in public he ari ng s .
A broad look at the elements of GPU Nuclear which will be involved in the operation of TMI-l reveais that the organi zation, down L
through two levels of management below the GPU Nuclear vice preside nts , encompassing 86 such posi tions , con tai ns 16 individuals that were wi th Me tEd 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 Nuc1 car and the vice president directly responsible for TMI-l si te ope ra ti ons are new.
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At the time of res tart we expect to utilize 38 currently licensed I
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 as sig ned to shi f t activi ties . These operators need to be viewed as a source of experience for the safe operation of TMI-1.
Thei r prospective per f ormance mus t also be assessed in light of (1) the fact that all have been licensed under the new tes ting cri te ria, '
(2) the abili ty of GPUN to provide 6 shi f t coverage for TMI-1 which provides one shif t out of six for training, (3) the presence of l shift technical advisors , and ( 4) 'signi ficantly improved procedures .
As f urther assurance :
- 1) We'will, prior to res tart, reassign personnel such that no TMI-2 licensed operator will operate TMI-1 (except for the manager of operations who was licensed on Uni t 2 but who was evaluated -i n depth and speci fically endorsed by the ASLB), and
- 2) We will, prior to res tar t, add full time on shi f t operational quali ty assurance coverage by degreed engineers until the open issues are re s olv ed . We would defer to the NRC should i t wish to provide full time on shif t resident inspector coverage of TMI-1 operati ons .
The balance of the TMI-1 si te s taf f i n engi nee ri ng , maintenance , and supervisory roles contains numerous individuals wi th prior l expe rience i n the ope ration of TMI-1, experience which is important to the safe ope ra tion of TMI-1. The prospective performance of . the current TMI-l si te s taf f mus t 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 managemdnt areas of procedures , adhe re nce ,
discipline, and atti tude toward safe ty.
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-In order to provide added assurance; We will reassign personnel such that those f u nc ti ons which provide an overview assessment, analysis, or audi t of plant activi ties speci fically:
General Of fice Review Board Independent On-Si te Safe ty Group Shi f t Technical Advisors .
O/A Audi t O/A and O/C Site Staff Lice nsi ng Radiation Control Emergency Preparedness will contain only personnel wi th no pre-accident involvement as Me tEd exempt employees at TMI-1 or 2. We will continue this cons trai nt until the open issues are e f fec tively resolved.
As a further action to s treng then TMI-1; We have ' reallocated the priori ties and assignments within the office of the president of GPU Nu'elear, 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.
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I In a letter to Governor Thornburgh we have committed to the actions
( which we think necessary to satis fy the issues .under appeal byy the
! Commonwealth of Pennsylvania. . A copy. of that le tter is . attached. t m - ,e-. e
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We are taki ng these s teps in order to provide addi tional assurances during the . period necessary to resolve the open iss ues . We are confident that the actions necessary to provide these added assurances will not detract from the firs t priori ty of safe ope r a ti ons .
We will work wi th your s taf f to communicate the speci fics of these steps.
In closing, we urge the Commissiori to expedi tiously resolve the open issues so as to provide assurance that the learnings of the accident have been identi fied and implemented. We pledge our cooperation in that ef fort so that the TMI-l management and s taf f can be accorded the f ull support of the Commission and the public.
Sincerely, t
H. Dieckamp Ida 2
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- Governor Thornburgh 4
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