ML20082E418
| ML20082E418 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/23/1983 |
| From: | Pollard R, Weiss E UNION OF CONCERNED SCIENTISTS |
| To: | Bernthal F, Gilinsky V, Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8311280194 | |
| Download: ML20082E418 (3) | |
Text
!
i ex. w:.c.5. 0....z8.. 9 3cs wr mm DOCKETED USNRC UNION OF m m 2s azu CONCERNED SCIENTISTS 1346 Connecticut Avenue, N.W.. S. I101. Wkh[
g'(202) 296 5600 BRANCH November 23, 1983 Nunzio Palladino, Chairman Victor Gilinsky, Commissioner Frederick M. Bernthal, Commissioner James Asselstine, Commissioner Thomas Roberts, Commissioner U. S. Nuclear Regulatory Commission Washington, DC 20555 d
RE: TMI-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 report has been distributed by GPU to the press, it has not been received by the parties and we therefore rely upcn 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 ob.iectives" 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 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.
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 violated. We will give you simply two of the more recent examples.
j 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 TMI-1, GPU l
l 0311280194 831123
{DRADOCK 05000289 l
PDR 1
gb Main Office: 26 Church Street. Cambridge, Massachusetts 02238. (617) 547 5552
,e
\\.
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 Nuclear Corporation requested a delay in implementing some fire safety requirements from April 1,1983 until the first refueling after restart.
In a letter to the Licensee dated March 9, 1983, the NRC Staff noted that GPU Nuclear apparently did not even intend to begin the modifi-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 ch::nge in performance if they are to achieve the goal recommended by Admiral Rickover of being in the top one-sixth of all commercial nuclear plants.
In addition to the physical deficiencies in fire protection at TMI-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 TMI-1 license and the station procedure and training program do not even address quarterly training. Further, the THI-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 Rickover's report also apparently highlights the radiation control program at TMI-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 commitment 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 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 with three apparent procedure violations involving the handling of radioactive waste which " collectively represent an apparent breakdown in proper implementation of [GPU Nuclear's]
radiological control program." (emphasis added) Furthermore, the Staff found that the violations "could have been reasonably precluded by corrective 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.
i However, when examining GPU Nuclear's performance, one finds a breakdown of the radiation control program. Furthermore, the NRC Staff'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."
l In the case of the fire protection standards discussed above, GPU requested I
? -
exemptions from requirements which virtually every other operating plant meets. The TMI-1 restart proceeding is studded with examples of GPU's gredging compliance with minimum standards applicable to the industry at large. The history of the high-point vents and the reactor water volume 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 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 maragement should not be permitted to avoid that responsibility by assuming a new corporate title.
In addition, mismanagement of TMI-2 cleanup was excluded from consideration beca::se, although it involves the same management, it involves different kinds of activities. On its face, this ground for exclusion is completely unjustified. The management principles which are stated to apply to operation of TMI-1 are equally applicable to the cleanup.
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 27 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 frecuently at odds with their words.
Sincerely,
&l0L f
Ellyn R. Weiss General Counsel t* $//
Robert D. Pollard Nuclear Safety Engineer cc: TMI Service 1.ist i
-