ML20080A555
| ML20080A555 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/16/1983 |
| From: | Walker R HOUSE OF REP. |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20080A548 | List: |
| References | |
| NUDOCS 8402060116 | |
| Download: ML20080A555 (2) | |
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ROGEfG C WALKER starr m cuamos, ten. DoesicT. Punnsv6vassa MAnTHA c. MonnisON
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wasumotou ancs couwersas, MARC T. PHILLIPS C0HEress of II.JelHuitch 6tateg
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GOVERNMENT OPERATIONS
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Jpouse of Representatibed mast;(naton,s.c. 20sts December 16, 1983 The Honorable Nunzio Palladin0 Chairman Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555
Dear Mr. Chairman:
I am writing on behalf of my constituent, Ms.
Francine Taylor of Lancaster, Pennsylvania, a member of the TMI Public Interest Resource Center.
Ms. Taylor has provided me with several reports about which she has reservations.
First, she is concerned that new emergency feedwater flow instruments installed in Unit 1 do not meet.
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the NRC's criteria or the GPU's committment in the restart proceeding.
In addition, she questions GPU's commitment to its stated management objectives and strongly feels that Unit 1 should not be restarted before GPU's competence and integrity are fully revieved.
The reports to which Mr. Taylor referred are enclosed for your review.
I would greatly appreciate any information you could provide on this subject so that I may make a complete reply to my conztituent.
Thank you for your cooperation in this regard. I will look forward to hearing from you at your earliest opportunity.
C r ially, obert S. Walker am enc.
8402060116 840125
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W Thrao Mila Island Public Interest Resource Center 1037 Maclay Street e
Harrisburg, Pa. 17103 e
717 233-4241 My name is Francine Taylor and I am a member of TMI-Public Interest Resource. Center -- a coalition of 8 concerned citizens groups formed af ter the accident at TMI.
We are here to ask all elected of ficials to demand the Nuclear Regulatory Commission to do its job by being the public's protectisfi..
It is urgent that the officials who are entrusted with our health and safety put pressure on the Commission to re-open the record and to hold hearings on management competence and integrity -- and NOT to rely on self-reports by GPU just recently made public.
Even as recently as September 13, 1983, the NRC Office of Investigrtions charged that GPU circumvented proper procedures and adopted techniques of questionable safety with regard to the clean up of Unit 2.
On October 7, 1983, the NRC staff listed seven areas related to management that it said required further investigation before it could revalidate its own favorable 1980 decision on GPU's competence and integrity.
On November 7, a Federal Grand Jury charged a subsidiary of GPU with criminal misconduct in its operation of TMI.
On Monday, November 28, 1983, GPU had a whole day before the NRC to explain its re-organization plan.
(We know now that the only change was Robert Arnold was their sacrificial lamb).
This Monday, December 5, the public will have 40 minutes to air its views before the NRC.
An interesting comment on how the NRC views the public.
As a matter of fact, the public's perception is that the NRC has lost sight of its mandate.
TMI-Public Interest Resource Center agrees with the Kemeny Commission when it said the problem with the NRC is one of mindset.
I am quoting from the Kemeny Commission:
" Fundamental changes are necessary in the NRC's attitude which must change from one of complacency to one that says nuclear power is potentially dangerous, and must be con-tinually questioned whether the safeguards already in place are sufficient to prevent major accidents."
l As long ago as 1980, the NRC staff concluded that there had l
been misconduct and falsification of very important safety data l
by 'IMI personnel.
These safety violations led to the 11 court criminal indictments.
This is the same management that is running TMI; therefore, it is outrageous that the NRC is considering giving GPU the go ahead to restart Unit I before the criminal indictments have gone through the courts and all other management issues have been thoroughly dealt I
with.
Today we are distributing background material compiled by inte'r-nationally known scientists.
Anita N rJea, Grow Representing York, Centrel Pennsyt.ania Union Costition, Environmental Coalition on Nuclear Power. March 28 Cc+1ition. Newberry Tom.a6ues TM4 Somering Comanettes, People Against Nucteer Energy, Susquehanna Volley AllMaise, Tieras Mes selee,d Aters
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1 UCS 12/9/83 UNITED STATES OF AMERICA NUCLEAR REGULATORY COM4ISSION BEFORE THE C0ffiISSION In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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REQUEST EOR OPPORTUNITY '10 RESPOND 'IO STAFF PROPOSAL FOR RESTART OF TMI-l On December 5, 1983, the Cmmission held a session to allow response by Intervenors and the NEC Staff to the GPU June 10, 1983, proposal for restart of
'IMI-l and subsequent GPU modifications of that proposal.
At that meeting, af ter the Intervenors' opportunity to speak, the Staff presented a totally new proposal to restart the reactor at 25% power initially, to ascend to full power after OI concludes its ongoirs investigations of leak rate falsification and other matters bearing on GPU's competence and integrity.
This Staff proposal was made for the first time in the Staff's oral presentation.
It was not even made available in writing on the day of the tracting in the form of a SECY paper, as is normally the case.
Therefore, Intervenors were canpletely prevented from considering the proposal or voicing their views to the Comission.
GPU, which was provided an opportunity to speak after the Staff (and was prestnably aware in advance of the substance of the Staff proposal), did coment on the proposal.
The Intervenors are entitled to an equal opportunity to address the Comnission orally.
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-2 The Staff's proposal would place escentially no restrictions on the operation of 'IMI-1 beyord those ' hat are necessary in any case for start-up of a reactor that has teen out of operation for almost five years. 'Ihe testing woul6 simply be at a maximm of 25% power rather than 40% as GPU would prefer.
The Staff conceded that the 24-hour inspector presence is a public relations necessity -- a man on the scene to answer public queries. The Staff proposal in no way responds to the questions of GPU management integrity and competence.
It simply ass mes that there are none.
In addition, the Staff proposal completely overlooks the fact that the public is entitled to a role in the process of consideration of the evidence bearing on GPU's integrity.
This insensitivity is perhaps the most remarkable aspect of the proposal.
It is proposed that the Staff -- which failed for over three years to notify the Licensing and Appeal Boards of the nature of the evidence of leak rate falsification and continued to endorse GPU management in the adjudication throughout that time -- will " resolve" these issues by authorizing full power operation without the public ever having had the opportunity to present any evidence or question any witnesses.
Two questions the Staff did not explicitly address are: 1) If the OI investigation conclu3es that widespread leak rate falsification took place, is mI-l to then shut down? and 2) Do the reopened hearirgs take place after the plant goes to full powar and if the Board concludes that GPU lacks the requisite empetence and integrity, does 'IMI-l then shut down?, The proposal makes no provision at all for the occurrence of these contingencies, neither of which is unlikely, which makes it clear that it is not an interim restart proposal, but an ultimate restart proposal.
If we " face facts," as counseled by Admiral Rickover, the Staff's proposal is in all significant respects the same as GPU's.
It allows GPU to restart the
,e reactor first and later determines whether the company has the competence and integrity to - do so.
Moreover, once operation has restned, we can be sure that the formalities involved in resolving the competence and integrity questions will becme an empty gesture.
These and other questions concerning the Staff proposal should be addressed in an open meeting where the public has the opportunity to be heard.
Conclusion For the above-stated reasons, UCS uroes the Cmmission to schedule a meetire for the purpose of allowing responses to the Staff's proposal of December 5, 1983.
Respectfully subnitted, L
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Ellyngit. Weiss N
General Counsel Union of Concerned Scientists Dated: December 9, 1983 e
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8 UNION OF CONCERNED SCIENTISTS me c...e.ti.u.e..e, u.w.. s. iio1. washi.,te.. oc 2c23.. <2o2> 2,64 03 November 23, 1983 Nunzio Palladino, Chairman Victor Gilinsky, Comissioner Frederick M. Bernthal, Commissioner James Asselstine, Commissioner Thomas Roberts, Commissioner U. S. Nuclear Regulatory Commission Washington, DC 20555 RE: THI-l Restart /Rickover Task Force Management Review Gentlemen:
The press is reporting today that Admiral Rickover's task force has reported favorably on GPU management. While that reportehas been distributed by GPU to the press, it has not been received by the parties and we therefore rely upon the account given in Energy Daily for November 23, 1983.
Since GPU is meeting with you to discuss management on Monday, November 28, we anticipate that this issue may come up.
Therefore, UCS wishes to provide for your consideration our initial thoughts on the review as it is being reported by the press.
First, we believe that the seven " management objectives" enunciated by the task force are sound. They are: require rising standards of accuracy; be technically self-sufficient; face facts; respect even small amounts of l
radiation; require relentless training; require adherence to the concept of total responsibility; and develop the capacity to learn from experience. As the task force noted, however, management policy, "provided it is confirmed by deeds," marks a radical departure from the past.
l On this point--whether the stated policy is reflected in deeds--the task force seems to have done limited research.
indeed, comparing the claims made to the task force by GPU management to actual contemporaneous events leads to l
the conclusion that the principles of sound management are being consistently l
violated. We sill give*you simply two of the more recent examples.
New safety requirements shown to be necessary as a result of the 1975 fire at the Browns Ferry plant were incorporated into NRC regulations which became effective on February 17, 1981. The present management of THI-1, GPU
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Main Office: 26 Chur.h Street. Cambridge, Massachuutta o2238. (617) 547-5552
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s Nuclear Corporation, then embarked on a series of attempts to gain exemptions from the implementation schedule for those safety requirements.
For example, on July 1,1982, GPU Uuclear Corporation requested a delay i,n implementing some fire safety requirements from April 1,1983 until the first refueling after restart.
In a letter to the Lictuee dated March 9,1983, the NRC Staff noted that GPU Nuclear apparently did not even intend to begin the modiff-cations until the third quarter of 1983 and proposed a schedule that was "not consistent with the schedules of the great majority of other licensees which will, almost without exception, be complete by April 1983." When GPU Nuclear's deeds place them at the bottom of the heap, it will take a dramatic change in oerformance if they are to achieve the goal recommended by Admiral i
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Rickover of being in the top one-sixth of all commercial nuclear plants.
In addition to the physical deficiencies in fire protection at THI-1, the training of fire brigade personnel is in disarray. Fire training deficiencies were described by the NRC Staff in Board Notification BN-83-159, sent to the Commissioners on October 17, 1983. Brigade members are not receiving the required quarterly training in violation of the THI-1 license and the station procedure and training program do not even address quarterly training. Further, the TMI-1 procedure and training program represent the same plan "that was initially found unacceptable by the NRC in 1978."
In addition, the NRC Staff reported that "TMI management also stated that they desired not to administer written exams to the brigade members, due to difficulties encountered in corrective action for failures." This is clearly inconsistent with the management principles used by Admiral Rickover to assess GPU Nuclear Corporation--require relentless training, develop the capacity to learn from experience, and face facts.
Admiral Rickovers report also apparently highlights the radiation control program at THI-1 (TMI-2 was excluded), which the report characterized as a "well-directed and effective approach to this important area." Once again, the deeds of GPU Nuclear Corporation do not match its alleged
" management conunitment to the goal of excellence," or 'the current highly acceptable record" of radiation control, to use the words of the report.
In a letter to GPU Nuclear Corporation dated October 28, 1983, the NRC Staff j
reported the results of routine safety inspections conducted.in August, September and October 1983, during which it found " numerous instances of nonadherence to procedures and instances of inadequate procedure reviews...."
In particular, the Staff was concerned wf th three apparent procedure viniations involving the handling of radioactive waste which " collectively]
represent an apparent breakdown in proper implementation of [GPU Nuclear's radiological control program." (emphasis added) Furthemore, the Staff found that the violations "could have been reasonably precluded by corrective t
actions implemented for previous violations in this area in the past." Thus, when one examines only GPU Nuclear's commitments and goals, the radiation control program may appear to be a well-directed and effective approach.
However, when examining GPU Nuclear's performance, one finds a breakdown of the radiation control program. Furthermore, the NRC Staf f's observations show that, while GPU Nuclear may' profess to learn from experience, its performance shows that it does not.
We also find particularly remarkable the statement that GPU follows
" safety and reliability practices which lie beyond regulatory requirements."
In the case of the fire protection standards discussed above, GPU requested
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exemptions from requirements which virtually every other operating plant The TMI-1 restart proceeding is studded with examples of GPU's meets.
grudging compliance with minimum standdrds applicable to the industry at large. The history of the high-point vents and the reactor water volume j
measurement are just two.
It should be noted that the scope of the Rickover task force review was quite narrow. First, it excluded "early events" (we do not know how this was defined) on the apparent grounds that they took place under a " thoroughly different" previous management. The fact is, however, that top management still contains many of the same people. Therefore, the claim that GPU 4
management is thoroughly different is unfounded.
It should be noted that one of the management principles espoused by the report is the " concept of total responsibility". GPU management should not be pemitted to avoid that responsibility by assuming a new corporate title.
In addition, mismanagement of TM1-2 cleanup was excluded from consideration because, although it involves the same management, it involves different kinds of activities. On its face, this ground for exclusion is completely unjustified. Tne management principles which are stated to apply _
to operation of TMI-1 are equally applicable to the cleanupt If one wanted to look at deeds in addition to words, the cleanup experience would have been essential to review.
It is not credible to believe that a management truly reflective of Rickover's stated principles could have so thoroughly evaded and violated correct procedure during the cleanup. Did they shed their good management principles at the gate between Units 1 and 2?
It appears that the evidence we discuss above was not considered during the Rickover task force review of TMI management. Nor was the operator cheating or false certification or leak rate falsification. As we stated at the outset, the principles of good management identified by the reviewers are sound ones. However, GPU's deeds are very frequently at odds with their words.
Sincerely, da Ell n R. Weiss General Counsel dd#A Robert D. Pollard Nuclear Safety Engineer cc: TMI Service List
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TMI-Public Interest Resource Center
Subject:
Environmental Qualification of electrical equipment at TMI Unit 1 Date:
12/2/83 NRC report SECY-82-409 estimates that over 80% of the electrical equipment in operating nuclear power plants relied upon to protect the public in the extent of an accident is not environmentally qualified - that is, it may not stand up to the extreme changes in temperature, and radiation that occur during an accident.
- pressure, Of the equipment tested, over 40% has had to be replaced, modified, relocated, or shieldeds TMI Unit 1 is one of the plants whose equipment has not been environmentally qualified.
Nor has the NRC set a date by which this equipment has to be environmentally qualified.
None of this information can be introduced into the restart hearings.
From another NRC reports"The hearing is not for the purpose of reassessing the safety of TMI Unit 1 it is for the purpose of assessing whether or not the lessons learned from the accident are necessary and sufficient to allow Unit 1 to resume operation."
Therefore, only information specifically related to the accident can.be discussed at the hearings.
I The Union of Concerned Scientists has advised that our elected officials can persuade the NRC to widen the scope of the hearings so that all safety issues related to the operating of TMI Unit 1 can be discussed.
We are requesting that the issue of restart not be discussed until all the. safety equipment in Unit 1 has been environmentally qualified.
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