ML20079P607

Informs That B Mehler Replaced W Zewe as Radwaste Operations Manager.N Hernissey Replaced D Dyckman as Shift Maint Foreman.Resumes & Documentation Re Mgt Practices Encl

ML20079P607
Person / Time
Site:	Three Mile Island
Issue date:	01/27/1984
From:	Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Buck J, Edles G, Kohl C Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8401310283
Download: ML20079P607 (27)

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January 27, 1984 822-1213 Administrative Judges Gary J. Edles, Chairman John H. Buck Christine N. Kohl Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)

Docket No. 50-289 (SP)

Dear Chairman Edles and Judges Buck and Kohl:

In accordance with our practice of notifying the Appeal Board and parties of changed circumstances or new information on issues under consideration, Licensee hereby provides the following information.

' In a December 3, 1982 letter to you updating personnel changes at TMI-1, Licensee described the assumption of the position of Radwaste Operations Manager, TMI-1, by Mr. William Zewe. Mr. Zewe has left GPU Nuclear Corp. Replacing him as Radwaste Operations Manager is Brian Mehler. Mr. Mehler's resume is enclosed.

In paragraph 162 of the August 27, 1981 Partial Initial Decision (PID), the Licensing Board referred to the qualifi-cations of Mr. Dennis Dyckman, who supervised the TMI-l shift 8401310283 840127 gDRADOCK 05000289 PDR m

SHAw. PITTMAN. PoTTs & TROW 2 RIDGE 9 A pastNEmswer OF pmOFEttecesAL CompOmateONS Administrative Judges Gary J. Edles, Chairman John H. Buck Christine N. Kohl January 27, 1984 Page Two maintenance personnel and who testified extensively before the Board on Licensee's maintenance practices. Mr. Dyckman is now a member of the TMI-l Independent Onsite Safety Review Committee. Replacing Mr. Dyckman as lead shift maintenance foreman is Mr. Neil Hernissey. Mr. Hernissey has been at TMI for approximately 12 years in the maintenance organization and has some 18 years of previous maintenance experience at a fossil power plant.

In the testimony of Mr. Robert C. Arnold #iled during the initial management proceeding, reference la :ade to the conduct of facilities management and industrial safety acti-vities within the Administration division of GPU Nuclear.

See Arnold, ff. Tr. 11,434, at 25. These activities have been reassigned within the GPU Nuclear organization. Safety and health activities now are a part of the Radiological and Environmental Controls Division. Facilities management now are a part of the Maintenance and Construction Division.

On September 1,1983, the NRC Office of Investigations (OI) issued an Interim Report on its investigation into allegations by Messrs. Parks, Gischel and King regarding activities at TMI-2. Enclosed is a January 16, 1984 letter sent to Harold Denton, Director, Office of Nuclear Reactor Regulation, NRC, from Philip R. Clark, President of GPU Nuclear, providing Licensee's comments on the OI Interim Report.

Sincerely, M M d . b m %.

Deborah B. Bauser

! Counsel for Licensee DBB:jah Enclosures ,

cc: attached Service List

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UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Anceal Board In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP (Three Mile Island Nuclear )

(*'* "

Station, Unit No. 1) Phase

)

SERVICE LIST Administrative Judge Administrative Judge Gary J. Edles, Chairman Ivan W. Smith, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board U.S. Nuclear Re,gulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Sheldon J. Wolfe John H. Buck Atomic Safety & Licensing Board Atomic Safety & Licensing U.S. Nuclear Regulatory Commissic Appeal Board Washington, D.C. 20555 l U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 Gustave A. Linenberger, Jr.

Atomic Safety & Licensing Board Administrative Judge U.S. Nuclear Regulatory Commissio Christine N. Kohl Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel l Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Jack R. Goldberg, Esquire (4)

Office of the Executive Atomic Safety & Licensing Legal Director Appeal Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory

, Commission Commission i Washington, D.C. 20555 Washington, D.C. 20555 l

l Docketing & Service Section (3) Douglas R. Blazey, Esquire t

Office of the Secretary Chief Counsel l U.S. Nuclear Regulatory Department of Environmental Commission Resources l Washington, D.C. 20555 514 Executive House P.O. Box 2357 Harrisburg, PA 17120 n

John A. Levin, Esquire Ms. Gail Phelps Assistant Counsel ANGRY /TMI PIRC Pennsylvania Public Utility 1037 Maclay Street Commission Harrisburg, PA 17103 Post Office Bcx 3265 Harrisburg, PA 17120 Ellyn R. Weiss, Esquire (1)

Mr. Henry D. Hukill William S. Jordan, III, Esquire Harmon & Weiss Vice President 1725 Eye Street, N.W., Suite GPU Nuclear Corporation 506 Washington, D.C. 20006 Post Office Box 480 Middletown, PA 17057 Michael F. McBride, Esquire LeBouef, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Suite 1100 Washington, D.C. 20036

• Ms. Louise Bradford TMI ALERT 1011 Green Street Harrisburg, P.A 17102 Mr. Norman Aamodt R. D. 5 Coatesville, PA 19320 Joanne Doroshow, Esquire The Christic Institute 1324 North Capitol Street Washington, D.C. 20002 t Michael W. Maupin, Esquire

' Hunton & Williams 707 East Main Street l Post Offi.ce Box 1535 l Richmond, VA 23212 David E. Cole, Esquire Smith & Smith, P.C.

2931 Front Street Harrisburg, PA 17110 l

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RESUME BRIAN A. MEHLER EDUCATION High School Graduate - Class of 1959 U.S. Air Force 3345th Technical School - Aircraft and Missile Ground Support Equipment Course - 25 weeks.

U.S. Air Force 204A Field Training - Air Conditioner Course - 2 Weeks Job Related Training - Reactor Operating Training Course 10/20/69 to 9/18/70 (48 Weeks)

Three Mile Island Staff General Electric Turbine Course 7/19/71 to 7/30/71 (20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />)

General Electric Reactor Familiarizatior. Program 9/13/71 to 10/1/71 (1 week)

PSU Staff PWR Simulator Training 6/20/73 to 8/31/73 (30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />)

B&W Westinghouse Turbine Training

• (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />)

Westinghouse n

CIVILIAN JOBS l '

DATE PLACE DUT!_E,S, S

1963 to 1966 Aluminum Sales, Lebanon, PA Worked on receiving and disbursing of construction material s.

1966 to 1967 Aluminum Co. of Anerica Work on production, repair &

Lebanon, PA installation of Aluminum products.

1967 to 1969 Metropolitan Edison Co. Started May 9, T967 as Crawfoij Station Utility Worker A.

Worked in the following departments, Coal Gang, Boiler Room, Turbine Room and Mechanicai Maintenance Department. Promoted to Fireman 2nd Relief in 1968. Duties were to assist Fireman 1st Clar.s on the operations of high and low pressure boilers, checked rotating equipment for proper operation and assisted in mechanical maintenance on repairs of equipment.

1969 to 1976 Three Mile Island Promoted to CR0 Unit I and worked under the direction of Shift Foreman. Was responsible for the proper operation of the Unit.

During this period, i participated in the '

construction, testing, initial fueling, startup and refueling of Unit I.

Participated in the writing and reviewing and

. implementing of the following: Operating '

procedures, emergency procedures, abnomal

• procedures, alarm responses -

. and surveillance procedures for Unit I.

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DATE PLACE DUTfES 1976 to 1978 Three Mile Island Promoted to Shift Foreman Unit 11 an reported to Unit II Supervisor of Operations and Duty Station Shift

' Supervisor. Was responsible for the actual operation of Unit II during assigned shift and directed the activities of the operators

. and auxiliary operators.

Participated in the construction testing, initial fueling and start up phases of Unit II.

Participating in the writing, reviewing and implementing of the following: Operating procedures, emergency procedures, abnomal procedures, alam responses and surveillance procedures for Unit II.

1978 to 1981 Thme Mile Island Promoted to Station Supervisor and reported to

- Unit I Supervisor of Operation and Unit II Supervisor of Operations.

Directed the activities which effect both units.

Responsible for the l

safe-operation of both units, to insure the safety

( of the general public, station personnel and equipment. To insure compliance with Tech.

l Specs., use of proper procedures during nomal l

operations and aergencies.

Involved in Unit I refueling and Unit II accident.

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DATE PLACE DUTIES 1981 to 1983 Three Mile Island Promoted to Shift Supervisor Unit I and reported to Manager, of Plant Operations. Duties were to direct the activities of Unit I Shift Foreman and -

coordinate all interface of activities which effect Unit I.

Responsible for the safe-operation of Unit I, to insure the safety of the general public, Unit personnel and equipment. To insure compliance with Tech.

Specs, use of proper procedures during normal operations and emergencies.

Was involved in preparation for Unit I Restart.

1983 to 1984 Three Mile Island Promoted to Operations and i

Maintenance Supervisor Unit I, and reported to Operations and Maintenance Di rector. Responsible to interface with Operations, Maintenance, Startup and MAC Departments.

1984/Present Three Mile Island Promoted to Radwaste Operations Manager Unit I and report to Manager, Plant Operations. Authorize and responsible for the Unit I Radwaste Operations Department.

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LICENSE HELD Place Three Mile Island Generating Station - TMI-I Type: A.E.C. Operator License Number: OP3618 Issue Date: 9/8/74 Three Mile Island Generating Station - TMI-I and TNI-II Type: NRC SRO License Number: SOP 3084 Issue Date: 10/19/79 Three Mile _ Island Generating Station - TMI-I Type: NRC SRO License Number: SOP 4247 Issue Date: 4/18/82 e

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GPU Nuclear Corporstion NMCIMr 100 lnterrace Parkway Parsippany, New Jersey 07054 201 263 6500 TELEX 1316 482 Writer's Direct Dial Number:

(201) 263-6797

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January 16, 1984

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Mr. Barold R. Denton, Director (Q-  ; , ;0 Office of Nuclear Reactor Regulation ,j  ! e, , _ .

United States Nuclear Regulatory Commission Mail Stop P-428 s

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Washington, DC 20555 \ cp '

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Dear Mr. Denton:

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On September 1,1983, the NRC's Of fice of Investigations (01) issued an Interim Report on an investigation into allegations by Messrs. Parks, Cischel, and King regarding activities at Three Mile Island Unit 2. This Interin Report was forwarded to the Commission by a memorandum dated September 1, 1983 from the Director of 01.

This letter provides our comments on the 01 Interim Report and its forwarding memorandum. It fulfills both the promise in Mr. William G. Kuhne' letter dated November 1,1983 to NRC Chairman Nunzio J. Palladino to provide comments to the staff and separate commitments made by other CPU Nuclear people in discuseions with the staff.

We have waited to comment on the OI Interim Report until the completion of both the GPU Nuclear commissioned investigation by Edwin W. Stier,

! Esq. into the allegations that initiated the OI investigation and of our

( futernal review. Volumes I and IV of the Stier Report, which relate to l 1ssues discussed in the 01 Inter.e Raport, are enclosed for reference and I

comparison with the OI Interim Report. Also enclosed is a September 23, l 1983 letter from Mr. Stier addressing some of the major points.

The OI Interim Report sets forth, in Part D-10 entitled, "Results of the Technical Examination of Alleged Procedural and Managerial Deficiencies at Three Mile Island, Unit 2", twelve general issues covered by 01's in-vestigation. Stier's investigation covered in considerable detail the specific allegations in the employee's affidavits. The differences in scope and structure of the two investigations and the reports make it l impractical to creas reference specific sections that cover the same l issues. However, we have assessed the extent to which the Stier Report and the OI Interim Report cover the same issues and conclude that the

! Stier Report approximates the coverage in the 01 Interim Report in most respects, l

GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation l

1 l

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Mr. Harold R. Denton January 16, 1984 This letter and its attachment comment on Ol's general issues. We address the issues in the following categories:

- Management's Attitudes and Motives

- Adherence to Administrative Requirements

- Technical Judgments on "Important to Safety" Classifications

- Consistency of Organization and Staffing with Technical Specifications

. - QA Program and Management Support of it

- Functioning of the NRC's TMI Progras Office Each of these categories is addressed in Attachment I to this letter.

While the bulk of the comments rely on the Stier Report, we have provided additional cossents on the Quality Assurance Program and the conformance of the TMI-2 Organization to the Technical Specifications based on our internal review.

We recognize that the 01 Report is "Interia". Nonetheless, we are con-corned by the conclusions which may have been drawn from the Interim Report and the forwarding memorandum of September 1, 1983 from the Director of 01 to Chairman Palladino.

We believe that the total information now available does not support the preliminary conclusions on the major issues which can be drawn from that memorandum. We believe that the Stier Report is definitive and well bal-anced on those issues. Specifically, Stier found:

"The evidence gathered in the course of this investigation clearly demonstrates that the allegations, in their broadest sense, are unfounded. That is, the claims that the management of TMI-2 is unconcerned about the safety of the recovery effort and retaliated against employees who attempted to es11 these deficiencies to management's attention are contradicted by the weight of the evidence".

This is directly contrary to the 01 memorandum statement, "The allega-s tions were not only substantiated but we found them to be illustrative rather than exhaustive". While we believe that this 01 statement was likely intended to soply only to procedural compliance - even in that limited sense, it is in our judgment, an exaggeration.

Second, the 01 memorandum states, " Dissatisfaction with this cordition led the allegers to the course of action that triggered this investiga-tion". Stier's investigation led him to conclude that the procedural violations were being addressed by GPU Nuclear management and that Parks, 1

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Mr. Harold R. Denton . January 16, 1984 Cischel, and King knew this. His report makes it clear that their public allegations were precipitated primarily by other matters not affecting safety which they felt endangered their continued employment at TMI-2.

These matters did, in fact, result in personnel actions by the company.

Finally, the 01 memorandum states that, "The f ailure of senior licensee management to responsibly monitor Bechtel's work and hold Bechtel ac-countable is the underlying cause of the TMI-2 procedural probless".

Thus, it is implied that a fundaments1 deficiency exists in the ability and willingness of CPU Nuclear management to enforce its procedures.

This implication is not supported by the 01 Interim Report, and it is contradicted by the Stier Report which found that the procedural defi-ciencies which existed for a period during the cleanup resulted f rom

" ineffective consunications during a major management reorganization" and that the deficiencies clearly were neither " acceptable to or tolerated by" GPU Nuclear management. Stier also found that GPU Nuclear management had the appropriate concern for safety and was taking steps to identify and correct the procedural problems.

We think the key points that come out of all the investigations and dis-cussions resulting from the public allegations are the following:

1. Some activities at TMI-2 were not conducted in conformance with appli-

, cable administrative requirements. We fully endorse the need for adequate administrative controls. Mr. Kuhns' letter made clear that we accept responsibility for any deficiencies in their content or implementation. We have undertaken and are coesitted to completing the acticas needed to correct the identified problems.

2. Physical work at TMI-2 was accomplished safely.

3. GPU Nuclear management displayed an active regard for safety.

4. GPU Nuclear management did not discourage the raising of safety issues or suppress their consideration.

5. GPU Nuclear management recognized the structural and communications problems within the organization, was actively involved in correcting them, and is proceeding to complete those actions.

A great deal of effort has already been spent on responding to the alle-gations. We hope that both we and the NRC can now concentrate our resources on continuing to complete safely and effectively the decontaa-ination and defueling of THI-2. We will continue our efforts to ensure that our corrective seasures fully address the problems which have been identified.

We believe it is also important to assure that unwarranted damage to the public credibility of the cleanup program be prevented. Many honest, n.

\ .

Mr. Harold R. Denton January 16, 1934 competent, and well-intentioned employees of the NRC, CPU Nuclear, and Bechtel have been publicly challenged and impugned by the allegations which, in the most part, have been shown to be unfounded. We trust that j the Stier Report will set the record straight in this re e ard.

We believe there is an additional important lesson to be learned from the investigations of the allegations. That lesson involves the method by which the ragulatory process deals with the application of standard regulatory requirements, practices, and policies to a unique situation such as that at TM1-2. We believe that all of those who are conducting, reviewing, monitortag, and investigating a unique situation, such as the cleanup, must have a full understanding of the circumstances and must act with judgment to apply or adapt regulatory requirements and guides which were written for vastly different circumstances.

A prime example of this is the application to the current TM1-2 situation i

of requirements developed for a plant operating at power levels of 1,000,000 kilowatts or more, pressure of 2,500 pounds per square inch, and temperature of 6000F. TM1-2 is now producing about 30 kilowatts of heat, pressure of about 15 pounds per square inch, and temperature of about 1500F.

We will be paying close attention in the coming months to identifying similar situations, correcting them ourselves, or asking racommendations to the NRC staff to correct them. In this way we will apply this learn-ing and by so doing facilitate the safe and timely cleanup of TMI-2.

Very truly yours, P. R. Clark President pik Attachment I Enclosures - Volumes I and IV of the Stier Report September 23, 1983 letter from Mr. Edwin W. Stier, Esq.

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ATTACHMENT I )

Manasement's Attitudes and Motives The attitudes and nocives of TMI-2 management and senior company manage-ment toward safety are clearly a very fundamental issue. No charge could be more serious than that the Recovery Progras > ras being managed under a policy or attitude of disregard for safety.

This issue is the major.these of the allegations and, presumably, a prin- .

i cipal focus of the investigations. The OI Interim Report itself is not explicit on managenera attitudes. It does not state a finding on this issue. Unfortunately, however, the 01 Interim Report is organized so that it implies an improper management attitude.

For example, in part D-10 of the OI Interia Report, at page I-4, it is stated:

"The general allegation that procedure violations and a his-torical pattern of misclassifying the safety importance of various plant modifications represent evidence 'that the management of Three Mile Island Unit II (TMI) has sacrificed its own system of safety-related checks and balances for the TMI Cleanup activities in order to meet unrealistic time schedules' (Parks' Affidavit, Pg. 1) . . ."

The 01 Report then lists the seven findings concerning Managerial Organi-sation issues, such as the inadequacy of THI-2 management support for QA and the conflicts between the THI-2 organizational structure and Techni-cal Specification requirements. The juxtaposition of the seven findings with the sweeping generalization quoted above suggests that the 01 team uncovered evidence of a willful decision made by TMI-2 management to circumvent its safety review system.

Similarly, the 01 memorandum which forwards the Interim Report to the Commission, while not definitive, leaves the clear impression that 01 concludes that there was a deliberate decision on the part of Bechtel personnel, to which GPU Nuclear senior managesant acquiesced, to circum-vent required administrative controls for the sake of expediency.

The Stier Report is explicit, and to the contrary, on this critical issue. The Stier Report contains extensive analysis of the attitude of TMI-2 management toward safety. Various administrative problems were investigated to determine the underlying safety review policies upon which TMI-2 management operated. In Volume I, Summary and Conclusions, page 13, the Stier Report states:

"The evidence gathered in the course of this investigation clearly demonstrates that the allegations, in their broadest sense, are unfounded. That is, the claims that the manage-ment of THI-2 is unconentned about the safety of the 4

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4 recovery effort and retaliated against employees who )

attempted to call these dericiencies to management's i attention are contradicted by the weight of the evidence".

"Among the numerous specific allegations which have been raised, he have determined that some are factually correct.

However, the manner in which they have been portrayed pub- ,

licly presents a distorted picture of the administrative I problems encountered at TMI-2 and of the attempts made by manegement to solve those problems. This report will de-scribe the various administrative deficiencies that existed at TMI-2 during the period under investigation. Our objec-tive is to make a reasonable assessment of their seriousness, discuss whether management recognized the problems, and describe any efforta undertaken by management to correct the situation".

"The allegations imply that the management of TMI-2 was headed in the direction of increased tolerance of unsafe practices. In contrast, the evidence shows that the trend was toward tighter administrative control to assure that safety standards were met. Whether the problems were brought to the attention of management by "ing, Parks, Gischel or by others, TMI-2 management was responsive. It undertook steps to assess the validity of complaints and acted upon those that were well-founded. The allegations that accuse manage-ment of following a policy of ignoring problems brought to its attention and of punishing employees who raised the issues are untrue."

Therefore, on this most basic of issues, we strongly disagree with any suggestion that TM1-2 management lacked appropriate concern for safety.

We believe that the OI Interim Report and the forwarding memorandum do not provide a proper assessment of management attitudes for two basic reasons:

1. The investigation team did not understand the unique circumstances created by the accident. Thus, they interpreted issues in the in-appropriate contcxt of a normal operating plant. This along with erroneous understanding of some issues, even as they would apply to an operating reactor, distorted the understsnding of the TMI-2 situation.

2. The OI Interim Report gives no credit to the organization for identi-fication and response to the problems by management prior to the public allegations. The Stier Report provides extensive documentation i that the problems were being addressed effectively. The documented actions by management strongly contradict the implication that manage-ment was circumventing its own safety revie*: aystem.

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Adherence to Administrative Requirements This general issue is discussed at length in the Stier Report. The company agrees that there were some activities which did not conform to administrative requirements. The difficulties with utilizing the pre-accident administrative controls because of changed conditions, the large number of new personnel at the site, and the need to provide a z revised organization suited to the unique situation led to an early and '

continuing emphasis on development and use of administrative controls.

The priority on the effort to revise administrative procedures was increased relative to other requirements as safety considerations permitted. Within the procedurs ravision effort, priorities also had to be established. For example, early in the post-accident time period, che Radiological Controls Program was completely and very effectively re-vamped, as was the Radioactive Waste Shipping Program.

Efforts to revise other administrative procedures did not progress as rapidly as the company desired and anticipated. This was due in large part to the ongoing technical and safety needs which had to be met. That situation should be evaluated in the context of the tremendous amount of work that was done safely, competently, and for the majority of the tasks accomplished in compliance with the administrative requirements.

Most importantly, an objective review shows that senior company and TMI-2 management were and are addressing the underlying problems of the need to revise existing procedures, optimize the organizational structure, and train affected personnel on administrative requirements.

Although the 01 Interia Report does not reflect all the training efforts j that did exist, the company recognizes that more training on administra-tive procedures was needed. Consistent with the recommendation in the OI Interia Report, we have initiated action to assure that training and re-training is " comprehensive enough in nature to assure that all personnel l

understand the requirements of the procedures."

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Technical Judgments on "Important to Safety" Classifications This issue, as applied to the polar crane, is addressed at length in the Stier Report. This is probably the area which most clearly *.11ustrates the problem of properly applying standard requirements to ;ne unique TMI-2 situation. As an example, the 01 Interim Report concludes that the entire polar crane refurbishment program should have been classified as Important to Safety (ITS) because the polar crane structural support is classified as ITS; and when the program was classified as not ITS in July, 1982, it had not been determined if the structure would be involved. This conclusion is technically and adminirtratively incorrect. Another incorrect conclusion is that temporary attachments to the reactor coolant system must satisfy 10 CFR 50 Appendix A design criteria as those criteria were originally applied to the design of the plant.

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Consistency of Organization and Staf fing with Technical Specifications This category of issues was not part of the allegations and thus is not addressed in the Stier Report. The first issue in this category is whether the TMI-2 organization was consistent with the Technical Speci-fications. Contrary to the 01 Interia Report conclusion, there was not a conflict between the Technical Specifications and the TMI-2 organization.

Specifically, the OI investigation team incorrectly concluded that the

" Plant Manager" position should have control and authority over activi-ties that were clearly outside the responsibility of the precaccident counterpart position (Unit Superintendent) simply because the activity

- now takes place on site or has the word " operation" in its functional title.

The TMI-2 organization is structured on the principle that in the unique circumstance of recovery from an unprecedented accident there are many activities which are completely beyond the scope or capabilities of a Site Operations Department organized and staffed to support "scraal" plant operations. At the same time, there is a vital and legally man-dated responsibility assigned to the Site Operations Department to maintain the plant in a safe shutdown condition in compliance with Technical Specifications and other requirements.

For these reasons, the organization established at TMI-2 (and refined on several occasions based on our experience through the course of recov-cry), includes two key elements:

• A Recovery Programs Department heavily staffed by contractor personnel (primarily f rom two Bechtel companies) having credentials and experience appropriata for the unique recovery tasks at hand, and

• A Site Operations Department, which includes CPU's experienced and licensed operators, as well as supporting maintenance, engineering, and other personnel, to provide the extensive plant familiarity, operational capability, and legal accountability to maintain safe shutdown.

These two major organisational units, with supportive elements, have been integrated into a single GPUN Division for maximum effectiveness.

At the time of 01's investigation, the responsibility set forth in the TMI-2 Technical Specifications for the Director - Site Operations is that he "shall be responsible for overall unit operation and shall designate in writing the succession of this responsibility during his absence".

This responsibility, consistent with the Technical Specifications, is assigned in the summary of responsibility for the Site Operations Depart-ment contained in the internal GPU Nuclear Organization Plan, Revision 10, dated September 1, 191 which states the Site Operations Q

e Department is responsible to " conduct plant operations, maintenance, and engineering at Three Mile Island Unit 2 in a safe, reliable, and ef fi-cient manner consistent with corporate requirements and in compliarca with all applicable laws, licenses, regulatcry and tecnnical require-ments". This approach is consistent with the ANSI Standards. The term

" operation" in the ANSI Standards does not imply that the Director - Site Operations has 2xclusive authority over all activities at the site, nor does it suggest that activities of a nature inherently different from normal plan", operations (such as cleanup operations) may not be assigned to another department.

j The TMI-2 organization has been reviewed and approved by the NRC. This organizatica is reasonable, responsive to the demands of the TMI-2 situation, and completely consistent with the facility Technical Specifications.

The second issue in this category is whether, during April /May 1983, John Barton, the Director of Site Operations (acting), had the qualifi-cations called for by the Technical Specifications; i.e., those of a

" Plant Manager" as defined in ANSI N18.1.

The THI-2 Technical Specifications in effect at the time of the investi-gation clearly are" based on the 1971 edition of this Standard. The comparison of J. J. Barton's qualificaticas for Director - Sits Operations against ANSI N18.1 - 1971 is set forth at the end of this section. We conclude that the finding on this issue in the OI Interim Report'is incorrect for two reasons:

1. Mr. Barton fulfilled the Technical Specification requirements for designation as Director - Site Operations. Mr. Barton's 25 years of training and experience are particularly suf;able for the position of TM1-2 Director - Site Operations.

2. The Technical Specifications, through the reference to ANSI N18.1 -

1971, permitted the waiving of certain requirements for the " Plant Manager" including that he have the requisite experience and train-ing normally required by the NRC of a candidate for an SRO license if one or more principal alternates fulfilled that criterion. The Manager - Plant Operations, who was designated in writing as the principal alternate to the Director - Site Operations during the period of interest (April /May 1983), held a current SRO license on TMI-2.

COMPARISON OF J. J. BARTON'S QUALIFICATIONS FOR DIRECTOR SITE OPERATIONS (PLANT MANAGER) WITH ANSI N18.1 - 1971 TECHNICAL SPECIFICATION REQUIREMENT - Technical Specification 6.3 requires each member of the unit staff to meet or exceed the miniaua qualifications of ANSI N18.1 - 1971 ANSI N18.1 - 1971 Requirement for " Plant Manager" _

l. Ten (10) years of responsible power plant experience, three (3) years

, nuclear power plant experience. A maximum of four (4) years of the remaining seven (7) years may be fulfilled by academic training.

2. The Plant Manager shall have acquired the experience and training normally required for examination by the AEC (now NRC) for an SRO's license unless one or more persons designated as a principal alternate sect the nuclear plant experience and AEC examination requirements in which case the Plant Manager need have only one of his ten (10) years experience be nuclear power plant experience and he need not be eli-gible for AEC examination.

3. At least one of the persons filling positions delineated above should have a recognized baccaleureate or higher degree in an engineering or scientific field generally associated with power production.

J. J. Barton's Qualifications J. J. Barton has a BSME from the United States Merchant Marine Academy and thus fulfills this requirement.

Three (3) years Engineering Officer of the Watch U.S. Navy and Merchant Marine.

Four (4) years service with Burns and Roe, Inc., involved in nuclear

plant and startup activities.

Seven (7) years service with New York Shipbuilding Corporation in various test positions in the Naval Nuclear Power Department, including Manager of the Startup organization.

Eleven'(ll) years service with GPU in various power plant related activi-ties, six (6) years of which were solely dedicated to nuclear power plants, including two (2) years previously in this same position.

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, Additional information regarding Barton's experience is as follows:

Received simulator training (one week course).

Served as Shif t Test Engineer for entire Test Program on one nuclear submarine, and- for Hot Functional Testing af ter core load on another submarine; both S5W power plants.

Specializad nuclear power training program which prepared candi-dates for Shif t Test Engineer in the Naval Reactor Program. Upon -

completion of this training, became the Shipyard member of the Joint Test Group for both a nuclear submarine and nuclear f rigate.

Served as Test Director (overall responsibility for Initial Criti-cality and Power Range Tests) for three (3) nuclear submarine test programs.

Served as Nuclear Power Plant Test Director on board one nuclear submarine during initial Sea Trials.

Served as Propulsion Plant Test Director for initial S*.a Trials of

, one nuclear frigate. (This assignment included not caly the reactor olant, but also the complete propulsion plant and all the

auxiliary systems such as the electric power, SSTG).

,In the position of Director, Site Operations, J. J. Barton was qualified as " Emergency Director" as defined in the TMI-2 Energency Plan, sad successfully served in this capacity during actual emergency situations and in quarterly and annual emergency -

drills.

J. J. Chwestyk, who was designated the principal alternate for J. J. Barton in his capacity as acting Site Operations Director during April /May 1983, had approximately fifteen (15) years power plant experience with GPUN/ Met-Ed of which thirteen (13) have been at TMI.

Chwastyk held an SRO license at TMI-2 from November 9,1977 to August 5, 1983. Therefore, Barton was not required to have the experience and training required for examination for an SRO license.

R.

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QA Program and Management Support of it The issues in this category are dealt with extensively in the Stier Re port. The Stier Report concluded that the QA Program was not compro-mised and was not lacking management support.

The 01 Interia Report comes to its contrary conclusion based primarily upon consideration of four areas:

1. Timelineau of performing audits of the Recovery Programs Department,

2. Effectiveness of QA participation in the polar crane refurbishment,

3. Compliance of the QA Program with 10 CPR 50 Appendix B in the method for classifying activities as ITS or not ITS, and 4 Timeliness of correction of QA deficiencies.

Following are our comments on each of the four areas:

1. QA Audits of the Recovery Programs Department - The 01 Interia Report conclusion that the Audit Program was deficient is incorrect. Under our QA Program, we audit activities and organization units.

a) In accordance with the GPUN Recovery QA Program, the Recovery Program Department activities were being monitored by Operations QA for compliance to the Technical Specifications on a routine basis, b) The Recovery Prograc Department was established in September 1982. The QA audit conducted, starting in September 1983, of its activities and organization satisfied the annual audit require-ment of the Technical Specifications.

c) Technical Specification requirements for audits of other activi-ties of the TMI-2 Division have been and are being satisfied.

_ . . 2. Effectiveness of Participation in the Polar Crane Refurbishment Program (RBPCRP) - We disagree with the 01 Interia Report conclusion that the QA Department did not effectively participate in the RBPCRP.

a) There was Bechtel Quality Engineering involvement in the classi-fication of the polar crane activities and the establishment of the Engineering / Quality Requirements.

i l

b) There was coordination by GPUN QA with Bechtel QA Engiasering in l regard to the Engineering / Quality Requirements applied to the polar crane and other Bechtel work.

l l c) GPUN QA did overview the polar crane process in regard to assur-ing that the safety classification was consistent with the GPUN Classification Program.

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d) Bechtel QA had performed audits to assure that the Bechtel Engineering Program is adequate and being implemented on Bechtel work done in Gaithersburg including that on the polar crane.

3. Compliance of the QA Program With 10 CFR 50 Appendix B in the Method for Classifying Activities ITS or Not ITS - The company disagrees with the implication in the OI Interim Report that the process for decisions with regard to ITS/ NITS classifications is not in confor- '

mance with the requirements of 10 CFR 50 Appendix B or is otherwise inadequate. The QA Plan specifies the need for classifying work as ITS or NITS. This requirement was set.

Apparently, based on Procedure ES-Oll, the 01 team incorrectly believed that the QA Plan required additional classifications. When ES-011 was issued, it was thought that the additional classifications over and above regulatory requirements would be helpful in the con-trei of the work. However, attempts to implement the additional classifications turned out to be impractical. This procedure has recently been revised to delete those acuitional classifications and to provida classification of the system, parts, and components into only the ITS and NIIS categories. The QA Plan requirements relative to classification of work as ITS or NITS was not violated as a result of these avects.

Contrary to the statement in the 01 Interia Report, the QA Plan does not rely exclusively on the cognizant engineer to make a proper safety classification, and engineering is not performing a QA Depart-ment functisa when it makes ITS/ NITS decisions. Responsibility to make this determination is properly and formally lodged with the Engineering Department. The QA ?lan does put call for QA to review all activities that have been classified as ITS or NITS although QA does perform a saapling verification of the safety classification process. Examples of this verification include periodic QA moni-toring of work functions in addition to the audit function.

QA exercises its responsibilities in this area by:

a) Review and concurrence with procedures defining how classifica-tions are made, b) Periodic verification of classification and the classification process.

4. Timeliness of Correction of QA Deficiencies - The 01 Interia Report

oncludes that the QA Department did not receive proper management support to ensure adequate corrective action was taken to correct QA identified findings. We disagree with that general conclusion.

Four examples are used in the OI Interim Report to support its con-clusion:

- - _ _ n

a) The first example refers to a closeout of two Quality Deficiecey Reports (QDRs) based on Bechtel's statement that they will use the established administrative controls for doing ITS work and that work packages are to be used to accomplish recovery tasks which are determined to be wholly and particularly independent of the GPU Nuclear procedural system. Contrary to the 01 Interim Report conclusica, work outside the scope of the QA Program may be properly performed to another set of administrative controls.

Iron a QA Progran point of view, that was an acceptable response to the QDR.

b) The second example deals with the timeliness of backfitting design verification documentation practices on design work per-formed immediately af ter the accident to the requirements of the TMI-2 Modification CPUSC Quality Assurance Plan (QAP-M1). In recognition of the need for rapid installatica of modifientions during initial Recovery Operations, the Plan did not require formal documented design verification. It did require review of design work by qualified personnel. The NRs concurred with that Plan.

The decision to proceed with backfitting of documentation on the earlier modifications was made following the development of a new QA Plan. The new QA Plan required documentation of design veri-fication of modifications in recognition of the extended time period of the cleanup proEram and the need to return to normal practices. The 01 Interia Report is correct as to the length of time it took to clear that QDR. However, given the extensiveness of the work effort involved and the relative importance of having, as compared to other high priority activities, the docu-mentation complete, the length of time for clearing the QDR was appropriate. The QDR has been closed out and the documentation backfit effort has been completed. In any event, the time required in this instance is not typical and does not reflect the degree of management support for the QA Program. Numerous instances can be listed which show strong management support.

This is evidenced by the following table:

SUMMARY

OF QUALITY DEFICIENCY REPORTS es AUDIT FINDINGS 1981 1982 1983*

a) Open at beginning of year 146 117 68 b) New items 176 70 63 c) Items Resolved 205 119 88 d) Open at and of year 117 68 43 e) Items in (d) open longer than 180 days 51 21 7

• as of November 30, 1983.

c) The third example relates to QDRs where closeout depended upon issuance of revised administrative control procedures. In 1981, work was initiated on a complete revision of the administrative controls systems in use by GPUN. This was a massive effort but necessary to standardize controls in use at GPUN's three 'auclear facilities and to reflect the completely restructured organization put into place with the establishment of GPUN. This effort was well along by mid-1982. However, the decision to integrate Bechtel and GPUN components of the TMI-2 organization also resulted in a decision to have a single set of administrative procedures for all site work. Prior to those decisions, Bechtel was tasked with developing separate procedures for their onsite, i as well as offsite, work. Both of those decisions caused addi-

tional revisions to the new procedures about to be put into

! place. Transition to the new procedures system took place on January 3,1983 with the issuance of the first forty-five new or revised administrative controls procedures. We do not think this 9 performance indicates a lack of management support for the QA

> Program.

d) The fcurth example relates to misclassification of safety systems.

Disagreements over classification have occurred during the re-covery effort. This is not surprising in light of the unique circumstances over the last couple of years. However, contrary views were considered in reviewing the decisions and the coatrol systems led to correction of errors in classification. It is also important to note that the Stier investigation concluded that

technical judgments on classification were made in good faith.

Moreover, the application of a new concept in the scope of the QA Program; that of "important to safety" as contrasted with " safety related" was a major change for the industry as well as for 4

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w TMI-2. The Company moved aggressively to implement tnis concept resulting in OA coverage of many more activities. Management support for correcting all of these problems preceded the public allegations and since has resulted in revision and update to the Quality Classification List and establishment of guidelines on how classifications are to be made. The revised guidelines more accurately reflect the current conditions at TMI-2.

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Functioning of NRC's TMI PROGRAM OFFICE (TMIPO)

To the extent possible, without the benefit of interviews of the NRC staff, this issue was addressed in the Stier investigation. His report

- concludes that there were no improprieties on the part of the company or  :

the TMIPO staff in the course of their interactions. In response to the allegation that there was improper internal use by members of the TMI-2 staff of NRC's informal comments on draft procedures or planned activi-ties, explicit instructions have been issued to help assure that does not happen in the future.

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