ML20087H798
| ML20087H798 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/20/1984 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Buck J, Edles G, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-DSB-4 NUDOCS 8403210187 | |
| Download: ML20087H798 (35) | |
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wMtTER S Ot#ECT OsAL seuMSEN March 20, 1984 822-1215 Administrative Judge Administrative Judge Gary J. Edles, Chairman John H. Buck Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge 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
Dear Chairman Edles and Administrative Judges Buck and Kohl:
In accordance with our practice of notifying the Appeal Board and the parties of changed circumstances or new information on issues under consideration, Licensee hereby provides two letters from Licensee to the NRC Staff.
In the enclosed March 7, 1984 letter trom Mr. H. Hukill, l Director, TMI-1, to Mr. J. F. Stolz, Division of Licensing, Office l l of Nuclear Reactcr Regulation, Licensee' identified to the Staff I the reviews of the teaching performance, ability and attitude !
of Mr. DD conducted in 1983. I l
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i 8403210187 040320 PDR ADOCK 05000289 o PDR Q
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.I k SHAw, PirrMAN, POTTs & TROWCRIDGE A PARTMEmswap OP pmO'ReseONAL COm#0AAfiOpve Administrative Judge Gary J. Edles Administrative Judge John H. Buck Administrative Judge Christine N. Kohl i March 20, 1984 Page Two In the enclosed February 28, 1984 letter (with attachments) from Mr. P. R. Clark, President, GPU Nuclear to Mr. Richard C.
DeYoung, Office of Inspection and Enforcement (I&E), Licensee responded to the I&E letter of February 3, 1984 forwarding a Notice of Violation based on the NRC's investigation of allegations raised by former TMI-2 Site Operations personnel.
Respectfully submitted, BM /3. h Deborah B. Bauser Counsel for Licensee DBB:jah Enclosures cc: Service List L _
e
g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
Before the Commission In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
SERVICE LIST .
Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Comission Administrative Judge Washington, D.C. John H. Buck 20555 Atomic Safety & Licensing Appeal Victor Gilinsky, Commissioner Board U.S. No. clear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
Was'hington, D.C. 20555 20555 Thomas M. Roberts, Constissioner Administrative Judge U.S. Nuclear Regulatory Commission Christine N. Kohl Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board James K. Asselstine, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 U.S. Nuclear Regulatory Comunission Washington, D.C. 20555 Administrative Judge Ivan W. Smith, Chairman Frederick Bernthal, Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comunission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Cosuaission Washington, D.C. 20555 Washington, D.C. 20555
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Administrative Judge Mr. Henry D. Nukill Gustave A. Linenberger, Jr. Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Comanssion P.O. Sox 430 Washington, D.C. 20555 Middletown, PA 17057 Docksting and Service Section (3) Mr. and Mrs. Nomman Aamodt office of the Secretary R.D. 5 j U.S. Nuclear Angulatory Commission Coatesville, PA 19320 ,
Washington, D.C. 20555 l Ms. Louise tradford I Atomic Safety & Licensing Board TM1 ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Earrisburg, PA 17102 Washington, D.C. 20555 Joanne Doroshow, Esquire I Atomic Safety & Licensing Appeal The Christic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Cossaission Wachington, D.C. 20002 Washington, D.C. 20555 Ms. Gail Phelps Jack R. Goldberg, Esq. (4) ANGRr/TM1 PIRC Office of the Executive Legal 1037 Maclay Street Director Harrisburg, PA 17103 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ellyn R. Weiss, Esq.
Harmon & Weiss Maxine Woelfling, Esquire 1725 Eye Street, N.W., suite 506 Assistant Counsel Washington, D.C. 20006 Department of Environmental Resources Michael F. McBride, Esq.
514 Executive 3ouse LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W 3arrisburg, PA 17120 Suite 1100 Washington, D.C. 20036 John A. Levin, Esq.
Assistant Counsel Michael W. Maupin, Esq.
Pennsylvania Public Utility Hunton & Williams Commission 707 East Main Street P.O. Box 3265 P.O. Box 1535 Harrisburg, PA 17120 Richmond, VA 23212 David E. Cole, Esq.
Smith & Smith, P.C.
2931 Front Street Barrisburg, PA 17110 5
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CPU Nucle:r C:rport.tbn i
Nuclear m',"ign'So Middletown, Pennsylvania 17057 0191
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717 944 7621 i TELEX 84 2386 Writer's Direct Olal Number:
5 -
- 5211-84-2057
- March 7, 1984 i
i Office of Nuclear Reactor Regulation i Attn: J. F. Stolz, Chief i Operating Reactors Branch No. 4
- Division of Licensing
- U. S. Nuclear Regulatory Commission
- Washington, D.C. 20555
'i
Dear Sir:
Three Mile Island Nuclear Station, Unit I (THI-1)
- Operating License No. DPR-50 Docket No. 50-289 Training Observation
- As discussed between you and Dr. R. L. Long on December 2, 1983, GPUN has continued
.. to monitor DD's perfomance and has detemined that DD's teaching ability, attitude 3 and willingness to cooperate has been satisfactory. DD no longer holds an operating license and does not train operating license holders or trainees.
- GPUN regularly monitors DD's performance and his work assignments are consistent with that perfomance. In 1983 the following monitorings were perfomed:
i Date, Type of Review Observer
.: Mar 83 Classroom Teaching Perfomance Operator Training Manager May 83 Classroom Teaching Perfor=ance Operator Training Manager 2
Jul 83 Classroom Teaching Performance Mgr. - Training
- Nov 83 Classroom Teaching Performance Op. Training Manager
- Nov 83 Classroom Teaching Perfomance Mgr. - Educational Projects
- Apr 83 Counseling Discussion Mgr. - Training, Op. Training i Mgr., & Supv. Non-Lic. Oper.
- Training
- Jan 83 Quarterly Perfomance Mgr. - Plant Operations i Apr 83 Quarterly Perfomance Mgr. - Plant Operations i Jul 83 Quarterly Perfomance Mgr. - Plant Operations Oct 83 Annual Perfomance Review Op. Training Manager i Sincerely, 5 31 i E M u. u:ill, 3
Director, TMI-l E HDH:CWS:mle cc: R. Conte, J. Van Vliet GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation f
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- sMwEnIgay wMa GPU Nuclear 100 lnterpace Parkway Parsippany, New Jersey 07054
< 201 2634500 TELEX 13S482 Writer's Direct Dial Number:
(201) 263-6797 4410-84-L-0031 February 28, 1984 Office of Ii.spection and Enforcement Attn: Mr. Richard C. DeYoung US Nuclear Regulatory Commission Washington, DC 20555 Oear Mr. DeYoung:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. OPR-73 Docket No. 50-320 Response to Office of Investigation Report This letter is provided in response to your letter of February 3, 1984, which forwarded a Notice of Violation based on the NRC Cffice of Investigations' investigation of allegations raised by former TMI-2 Site Operations personnel.
The attachment to this letter provides GPUNC's detailed response to each citation. For your convenience the documents referenced in the responses NRC. are enclosed even though all have been submitted previously to the As a general conclusion, on the subject of these violations, the following excerpt from GPUNC letter dated January 16, 1984, Mr. P. R. Clark to Mr. H. R. Denton, is as applicable to this Notice of Violation as it was the Office e
of Investigations Interim Report:
"1.
Some activities at THI-2 were not conducted in conformance with applicable administrative requirements. He fully endorse the need for adequate administrative controls. Mr. Kuhns' letter (of November 1, 1983) made clear that we accept responsibility for any i
GPU Nuclear is a part of the General Public Utilities System l
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February 28, 1984 Mr. Richard C. DeYoung 4410-84-L-0031 deficiencies in their content or implementation. We have undertaken and are committed to completing the actions needed to correct the identified problems.
- 2. Physical work at THI-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."
GPUNC believes that the underlying causes for the non-compliances cited in the attachment have been identified and have been or are being effectively addressed.
Very truly yours,
/s/ P. R. Clark P. R. Clark President sie Attachment
Enclosures:
Stier Report Volume IV GPUNC Letter 4410-83-L-0244 dated October 11, 1983 GPUNC Letter 4410-83-L-0257 dated October 25, 1983 GPUNC Letter dated January 16, 1984 from P. R. Clark to H. R. Denton l
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I. NOTICE OF VIOLATION Administrative Procedure AP 1047, "Startup and Test Manual", paragraph 1.1.2, establishes the authority of the Test Working Group (TNG) as the 4 central approval and coordinating body for the Unit 2 Recovery Test Program. Paragraph 2.2.C establishes review and approval of test procedures prior to test performance as one of the principle responsibilities of the TNG.
Contrary to the above, the RBPC No-Load Test Procedure was written, approved, and performed without the TWG's review and concurrence. Unit i Work Instruction (UNI) 4374-3891-83-PG-2, the UNI for BNoC Work Package M0048 which implemented the RBPC No-Load Test was signed as having been completed by the Responsible Supervisor on February 16, 1983. However, TNG meeting notes show that the TWG had not met for any reason for a l period beginning from October 2, 1981, and ending March 4, 1983.
l GPUNC RESPONSE GPUNC concurs that the RBPC No-Load Test Procedure was written, approved, and performed without the TNG's prior review and ccncurrence. The reasons for this administrative non-compilance are extensively discussed .
- in the THI-2 Management and Safety Allegations Report (Stier Report) prepared by Edwin H. Stier for GPUNC (Volume IV, Polar Crane Allegations Section pages 28-32 and 71-79) and provided to the NRC via Mr. Clark's letter dated January 16, 1984. As part of the corrective action for this
- occurrence the TWG met on September 14, 1983, to review the no-load test plan and at this meeting verbally approved the results. As followup to this review TWG formally documented its approval of the no-load test (See GPUNC Letter 4410-83-L-0244 dated October 11, 1983, and GPUNC Letter 4410-83-L-0257 dated October 25, 1983). Additionally, GPUNC Letter 4410-83-L-0244 stated that AP 1047 would be complied with on a mandatory basis and that all personnel involved with polar crane activities, including contractors, would be trained on this procedure and other selected procedures. This activity is on-going. All personnel involved with testing of the polar crane are trained on AP-1047 before'their active involvement in such activity.
II. NOTICE OF VIOLATION l GPU Nuclear Quality Assurance Program, paragraph 3.1.3.2, Revision I, dated September 1, 1982, requires that the Quality Assurance department review administrative policies, procedures, and instructions which delineate the methods o# complying with the Recovery Quality Assurt.nce Program.
l Contrary to the above, the Quality Assurance Department did not review COPI-20 which delineated QC requirements and how to establish hold / witness points for QC coverage.
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GPUNC RESPONSE GPUNC agrees that CDPI-20 was not reviewed by the Quality Assurance Department. However, GPUNC disagrees with the citation in that CDPI-20 did not delineate QC Requirements for activities nor define how to -
establish hold / witness points for QC coverage. CDPI-20, Control and Documentation of work after release by GPUNC, was a procedure written by BNoC for Document Control. Its intent was to define the methods for collecting documentation of work for turnover.
ine QC requirements and Hold / Witness points for the Polar Crane were established in the Polar Crane Functional Description and were concurred with by Quality Assurance. These requirements were satisfactorily implemented during the polar crane refurbishment program.
CDPI-20 claimed to replace existing GPUNC procedures, which is unacceptable. This problem was identified during the Polar Crane Review Process and was corrected. In addition GPUNC Letter 4410-83-L-0244 provided a commitment to convert all CDPI's (including CDPI-20) into the THI-2 procedure program by the end of 1983. This activity was accomplished in that GPUNC procedures have been issued which supplant the functions served by CDPI's. Effective December 31, 1983 CDPI's no longer existed.
III. NOTICE OF VIOLATION Procedure AP 1021, " Engineering Change Memorandum (ECM)," states that an ECM is the traveler by which proposed plant tie-in, betterment, and modification packages are assembled, reviewed, and coordinated with GPU's site organizations for their effects on the existing plant systems, components, and structures.
Procedure AP 1043, " Work Authorization Procedure" establishes a means by which proposed changes to TMI-2 are initiated, reviewed, and approved in accordance with plant Technical Specifications. It requires a Work Permit to be issued as the document to authorize initiation of work proposed by an ECM and track the ECM work through completion, turnover, test, and final records retention.
Contrary to the above, the following was performed using a BNoC Work Package in3tead of the required GPU Nuclear-approved ECM or Work Permit.
A. A temporary Jib Crane was installed on the RBPC trolley using BNoC Work Package M-0024.
- 8. The Polar Crane Pendant, Cable, and Festoon Cable was instclied using a "non-like" for "like" component replacement via BNoC Work Package E-0046.
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C. The trolley power / control bypass was installed using a "non-like" for "like" replacement via BNoC Work Package E-0055.
D. 200 amp fuses were installed in place of 300 amp fuses in the polar crane main disconnect via BNoC Work Package E-0037.
GPUNC RESPONSE GPUNC concurs that the activities identified in this section were initially installed via a Work Package instead of an ECM. This problem was identified and documented by GPUNC Quality Assurance via Quality Deficiency Report CHK-011-83 dated March 8, 1983. This and other circumstances surrounding the' situation are documented in the Stier Report (Volume IV, Polar Crane Allegations Section, Pages 16-23). In order to correct the immediate problem identified by on-going Polar Crane Investigations, ECM's were generated for these modifications. GPUNC Letter 4410-83-L-0244 committed to provide ECM's for the Installation of the Jib Crane, Trolley Power / Control Bypass Cables, and the Pendant and the Festoon Cable, and GPUNC Letter 4410-83-L-0257 documented co.rpletion of these ECM's. On November 1,1983 an ECM was issued to document elimination of the Polar Crane Main Disconnect Fuses, a further modification of the work identified in Item D above.
To prevent recurrence of this event, GPUNC conducted training on AP 1021 and AP 1043 for all personnel involved in Polar Crane Refurbishment and testing activities as committed to in GPUNC Letter 4410-83-L-0244. This training was completed as of November 11, 1983.
1 IV. NOTICE OF VIOLATION AP 1021, " Engineering Change Memorandum," Appendix A, Section 12.1.1.2 states that if an instrument Not Important to Safety (NITS) is installed and its associated pressure probe penetrates and Important to Safety (ITS) barrier, then the ECM shall be classified as Important to Safety and subjected to the applicable QC, installation, and inspection procedures.
Contrary to the above, the following Safety-Equipment Change Modifications (S-ECM's) were issued with misclassification as follows:
A. S-ECM 1121, D-Ring Gantry Crane Railway was classified NITS instead of ITS.
B. S-ECM 1066, Temporary Equipment Hatch Enclosure Wall was classified NITS instead of ITS.
C. S-ECM 1053, Drain Path from OTSG A was classified NITS instead of ITS.
D. S-ECM 1099, UNICOM Communication System was classified NITS in:tead of ITS.
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GPUNC RESPONSE The apparent violation identified above identifies four specific ECM's which the NRC states were issued with mlsclassifications, i.e., the ECM's were ;1assified NITS vice ITS and thus by implication would not be subject to the applicable QC installation and inspection procedures.
Contrary to the citation S-ECM 1121, Revision 0, was clas;1 fled Important to Safety when it was originally issued due to installation of Liebig anchors in an ITS structure. GPUNC does concur that S-ECM's 1053, 1066, and 1099 were classified as NIT 3, however, each of these documents identified applicable QC inspection scope which was concurred with by GPUNC QA. Therefore, these S-ECM's did not bypass Quality Control. -
Subsequent revisions to S-ECM's 1053 and 1099 were classified as ITS.
Additionally, if a revision is made to S-ECM 1066, the safety classification will be changed to ITS, a revision to this ECM simply to modify its safety classification is not needed in that the appropriate QC requirements are incorporated into the existing ECM.
The general subject of improper safety classifications was also extensively discussed in the Stier Report (Volume IV, Allegations of Safety Review Deficiencies, Pages 2-9) and GPUNC Letter dated January 16, 1984, Mr. P. R. Clark to Mr. H. R. Denton. In order to prevent future problems with classifications a revised Quality Classification List (QCL) was issued on July 1, 1983, and Site Engineering was designated as the organization responsible for making interpretations of the QCL.
V. NOTICE OF VIOLATION AP 1043, " Work Authorization Procedure," describes the approved method of authorizing work for plant and equipment modifications. AP 1047, "Startup and Test Manual," authorizes the preparation, performance, and documentation of the test program.
Contrary to the above, the licensee released the RBPC to construction (BNoC) for refurbishment work via Joo Ticket CA-258. The Job Ticket procedure, which is authorized by Maintenance Procedure 1407-1, has no provisions for turning equipment over to construction and then subsequently turning the equipment back to operations after testing and modifications have been performed.
GPUNC RESPONSE GPUNC agrees that the RBPC was released to BNoC for the refurbishment work via a Job Ticket. This issue is addressed in the Stier Report (Volume IV, Polar Crane Allegations Section, Pages 3-6) in which it is concluded that Maintenance Procedure 1407=1 invoked the provisions of i 4300-ADM-3240.01, Access to and Work in Containment Building. Thus there I was a procedural basis which permitted work to be performed on the polar crane, and the procedures were specifically designed to authorize a maintenance project such as the polar crane refurbishment. Therefore, GPUNC disagrees with this specific citation, however, we do agree that l
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the refurbishment work and testing subsequent to turnover should have been conducted in compliance with AP 1043 and 1047. We acknowledge those procedures were not utilized in the instances referenced in citations I and III above and our corrective action helps ensure such non-compliance should not recur. ,
VI. NOTICE OF VIOLATION AP 1043, Work Authorization Procedure," Section 3.11.1 establishes criteria to determine whether a PORC review of a Work Permit is required.
Contrary to the above, Work Permit 222-1 which implemented Field Change Request FCR -P0014 involving Decontamination Experiment Penetration was incorrectly evaluated in that a PORC review was not performed, although such a review was required.
GPUNC RESPONSE GPUNC agrees that Work Permit 222-1 was incorrectly evaluated with respect to the requirements for a PORC review. The noncompliance was the result of an individual instance of an incorrect evaluation by the responsible engineer and is judged not to be a programmatic problem.
However, Field Change Request FCR-P0014 was not implemented until ECM 963 was revised as required by the Field Change Request. Based on the ECM revision a replacement Work Permit, 222-2, Revision 0, was prepared which was correctly evaluated as requiring PORC approval; therefore, no work was accomplished on FCR-P0014 without the required PORC review and approval.
Since the time of this occurrence, two major changes have taken place which affect the TMI-2 review and approval process for Engineering activities. As of March 1, 1984 a new procedural system for performing changes will be initiated which affect those changes commenced after that date. As part of this new system the work permit will be superseded by the Unit Work Instruction which requires a much more detailed evaluaticn of each work activity. Additionally, Technical Specification Change Request (TSCR) No. 40 was approved by the NRC and became effective on November 1, 1983. This change request, in part, requires that each Unit Work Instruction be concurred with by an independent reviewer who does not have direct responsibility for the performance of the activity under review. These changes were made independent of this event but will help to prevent recurrence.
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. Attachment 1 4410-84-L-0031
- Attachment 1 to the original letter was a copy of the Stier* Report, Volume IV. This iv'= ant is not being distributed internally. If you desire to review the report, please contact Mr. J. J. Byrne at extension 8461 - m I-2.
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GPU Nucleer Corporation 1 Post Office Box 480 g gp .
Itoute 441 South Medaletown.Pennsylvan's 17057 717 944 7821 ,
TELEX 84 2388 Writer ~s Direct DialNumber:
October 11, 1983 4410-83-L-0244
- m 9.15 8 TMI Program Office -
Attn: Mr. L. M. Barrett .
Deputy Program Director T"J N E' " l US Nuclear Regulatory Comission -
""*""' l c/o Three Mile Island Nuclear Station -
i Middletown, PA 17057-0191 ,
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Dear Sir:
re.le.#erste. e l2i'd'.'L.'" ;
! ' Three Mile Island Nuclear Station, Unit 2 (TMI-2 .
Operating License No. DPR-73 l l;'j,0;ag, w ~ ~ = -
l Docket No. 50-320 1
Additional Polar Crane Refurbishment Infomation Z.'"10' '"i. s
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My staff is in the proc'ess of responding to youY request for additional j ryja;=a a- p
-- m. A infomation as stated in the above letter is to provide the NRC ~ staff with information available thus far referenced letter. Thepurposeofthis{ O,."L. .
regarding the four items at issue and to inform you of projected dates for ,','O .;;,".a -
the completion of those actions underway but not yet complete. Projected Pj ;g-';' y/ ,'
dates for the transmittal of supplemental infomation are included as well, ice-e. i..
The order of the below stated partial responses corresponds with that used T"':f" /
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in the referenced, letter. .
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- 1. Quality Assurance has perfomed a review of the work packages used to
- accomplish the refurbishment of the Polar Crane. Fifty-two packages were reviewed to detemine if
- the appropriete approvals were obtained, inspection results were documented, acceptable material was used, required fests were performed and tests results were appropriately documented, modifications were approved by engineering, engineering reviewed and approved the as-found conditions as a result of the inspections, and there was overall compliance to administrative controls.
The comerits generated as a result of the review were satisfactorily resolved by the Polar Crane Task Group and Design Engineering. There were no material or design problems found, however. It was found that the administrative controls for modifications and testing were not complied irith in all cases. These discrepancies were documented on a Quality Deficiency Report. The corrective actions identified were:
- 1) Comply w'ith the administrative controls for modifications and testing I for all foture work and retrain all Recovery Program personnel responsi - l ble for authorizing work activities in these administrative controls; l
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'.L H. Barrett 4410-83-L-0244
- 2) convert s'11 Recovery programs Procedures that are required to satisfy the THI-2 License. Tech. Specs. Recovery Operations Plan, and Recovery QA Plan into the Unit-2 Procedure Programs; and 3) the Unit Work Instruc-tion will'be utilized when required by procedure for all Recovery Programs work activities. -
.' The status of corrective action is as follows:
A. Recovery Programs is in compliance with administrative controls for modification and testing. Recent changes to the technical Specifications modifying the safety review process are being ac-companied by a revision of the basic procedures governing the ac-complishment of work at TMI-2. Training on the new procedural pro-gramw"ill be a continuing process as the new procedures are approved and impl oented. Please see Item 4 for additional corrective action, i
! 3 Conversion of Recovery Programs procedures (CDPI's) into the THI-2 l procedure program is in progress and will be completed by the end of 198?.
l C. Implementation and authorization of Recovery Programs work activities are done in accordance with the Unit Work. Instruction (UWI) procedure. ,
- 2. Engineering Change Memoranda (ECM's) for changes not previously covered by this process are being produced now and will be subjected to the normal review routing, including the Site Operations Department. This
- process will be completed and copies of these approved ECM's made avail-
- able to the NRC by October 19, 1983 The three ECM's being produced cover modifications regar. ling the Jib Crane. Trolley Power / Control Bypass Cables, ard the Pendant and the Festoon Cable.
- 3. The first f;unctional test of the refurbished polar crane was the no-load test. This was successfully performed in February,1983 Though the Test Working Group (TWG) did not approve the no-load test procedure prier to per.formance, the TWG met on September 14. 1983, and reviewed the test plan and results. These results, reported by both the Polar Crane Task Group and GPU QC, were verbally approved on September 14, 1983. Formal documentation of TWG approval of the polar crane no-load test will be complete by October 19. 1983. l The polar crane load test was written and reviewed in accordance with '
AP 1047. The current revision contains all the required TWG approval .
signatures. The Test Working Group is fully cognizant of all tests completed and contemplated for the refurbished polar crane.
l
- 4. AdministrativeProcedures(AP 1021,1043, and AP 1047) and operational-requirements (Load Test and Operating Procedures) feverning polar crane -
refurbishment and testing activities will be comp 1' ed with on a mandatory l basis. All personnel involved with polar crane activities. including L - . I-
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4410 83-L-0244 L. H. Barrett contract' ors, are in the process.of training on these procedures and requirements. Training on approved procedures will he complete by Novsmber 15, 1983. Training on procedures which are to be yet approved by NRC will be accomplished before implementation of the covered activity.
We are continuing to review and monitor carefully all polar crane modifica-tions, testing, and refurbishment work to ensure compliance with all applicabia procedures and administrative requirements including training, prior to load testing. It is our intention to keep you fully informed of all significant developments in this regard.
Sincerely'. .
l
/s/ B. K. Kanga
- 8. K. Kanga Director. THI-2 BKK/CMH/jrb cc: Dr. 8.J. Snyder. Program Director - TMI Program Office
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Attachment 3 4410-04-L-0031 SPU Nucleer Corporation EMNuclear
- Pae:fa*
Middletown. Pennsylvania 17057 0191 717 944 7821
- TEl.EX84 2386
- . Writer's Direct DialNumber:
October 25, 1983 4410-83-L-0257 Sul.3 TMI Program Office Attn Mr. L. H. Barrett ...
Deputy Program Director w-US Nuclear Regulatory Commission M*"l..YU-c/o Three Mile Island Nuclear Station ..
Middletown, PA 17057 Stat ribut tam f A OII I re.ld.fetet . #
Ard.?rle. In W' Three Mile Island Nuclear Station, Unit 2 (TMI-2) ;"0;'l,..?
i Operating License No. DPR-73 Fla;-a; , kg, i Docket No. 50-320 r = < .a -*.< n. . -
i Additional Polar Crane Refurbishment Information [*:"J"';;1 "
I 0 %:O".u" .
The purpose of this letter is to update the status of Items 2 wa-'a a. . -
and .3 in GPUNC Letter 4410-83-L-0244 from B. K. Kanga to
L. H. Barrett dated October 11, 1983. y;*y;;;,"'-
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Item 2 stated that three (3) ECM's would be prepared by "f*J@.'E"' : '
October 19, 1983. These ECM's have been approved and are %"O ,. ,
available for your inspection. ,g{g;.y",. .
p" *.u.m '"
u Item 3 stated that the Test Working Group (TWG) approval of the polar crane no-load test would be formally documented. This has also bean done and the documentation is available for NRC
....asem.....
inspection. , ,, g . a . ,3 If you have any questions, please contact Mr. J. J. Byrne of '"*
- 2 1 , _
my staff. ffL;;g,7 '
Sincerely. yf'insi~ie
/s/ J. J. Barton for ems $. -
B. K. Ranga Director TMI-2 BKK/RBS/jep CC: Dr. B. J. Snyder, Program Director - TMI Program Office GPU Nuclear Corporatum is a subsidiary of the General Public Utilities Corporation
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TELEX 136 442 Wailst'sDirectDialNumber:
(201) 263-6797
- January 16, 1984 Mr. Narold R. Dentos, Director Office of Nuclear Reactor Regulation United States Nuclear Reguistory Comunission y
- Mail Stop F-428 '
- Vashington, DC 20535 ,
Dear Mr. Destoms On September 1,1983, the RC's Office of Investigations (01) issued as ,
Interia Report on sa investigation into allegations by Messrs. Parks,This '
pischel, and King regarding activities at ihree Mile Island Unit 2. .
Interia Report was forwarded to the Commission by a memorandum datsd September 1,1983 from the-Director of 01.
This letter provides our consents on the 01 Interim taport and its forwarding memorandus. It fulfills both the promise in Mr. V1111am G. Kuhas' letter dated November 1,1983 to NRC Chairman Nunsio J. Falladino to provide consents to the staff and separate commitments ends by other GFU Nuclear people la discussions with the l staff. .
I We have waited to comment on the 01 Interim Report until the completion
- of both the CPU Nuclear consissioned investigation by Edvis W. Stier.
' Esq. into the allegations that initiated the 01 favestigation sad of our internal review. Volumes I and IV of the Stier Report, which relate to
,' f ssues discussed in the 01 Interia Report, are enclosed for reference and Also emelosed is a Septesher 23,
.; comparison with the 01 Interim Report.
- 1983 letter from Mr. Stier addressing some of the major potats.
- The 01 Interia Report sets forth, la Part > 10 entitled. *Results of the Technical Essaination of Alleged Proc.adural sad Managerial Deficiencies
- at Three Mile Island, Unit 2", twelve general issues covered by 01's in-vestigation. Stier's investigation covered la considerable de.tsil the specific allegations in the employee's affidavits. The differences is scope and structure of the two lavsstigations sad the reports maka it impractical to cross reference specific sections that cover the same issues. Wowever, se have assessed the estaat to which the Stier Report sad the 01 Interia Report mover the same issues and conclude that the Stier Report approminates the soverage in the 01 Interia Report la most respects.
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January 16, 1984 Mr. Enrold R. Basom -
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i This letter and its attachneet commast on 01's general 1scues. We ,
address the issues'la the following categories '
- Ma'nagement's Attitudes and Motives .
- Adherence,to Administrative Requirements
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- Techateal, Judgments os "1ss,ortant to Safety
- CIsssifications
! - C asistency of Organisation and Steffing with S :hnical -
Specifications i ,
- qh Program and Managenest Support of it
.1 s-
- Functioning of the,51C's.TMI.Prograa Office
.Each of theos categories is addressed in Attachment I to this letter.
While the bulk of the consents rely on the Stier Report, we have provided additional consents on the quality Assurance Program and the conformance sof the TM1-2 Organisation to the Technical Specifications based os our internal review.
.f i vs recognise that the 01 Report is "Interia". Wometheless, we are com-esraad by ths conclusions which may have been drawn from the Interia Repu and the forwarding memorandum of September 1,1983 from the .
' Direstor of 02 is Chairpaa Falladino.
We believe that the total information now availabla does not support the preliminary conclusions on the major isens which can be draws from that l
sesorandum. We believe that the Stier Report is definitive and well hal-anced on those issues. Specifically, Stier foaad "The evidence gathered la the sourse of this investigette.
alearly demonstirates that the allegations, in their broadest sense, are safaunded. That is, the claims that the management
..; of TM1-2 is seconcerned about the safety of the recovery effort i and retaliated assinst employees who attempted to call these deficiencies Jto management's attention are sentradicted by the weight of the ovideacc*.
.f '
-w This is directly contrary to tu 01 mesorendum statement "The allega-
! tions were not o'aly substantiated kt we found them to be illustrative
.).
rather thsa exhaustive". While we believe that this 01 statenest was likely intended to apply only to procedural compliance - even la that limited esass., it is la our judgment, as saaggeration.
gecond, the 01 memorandus states, " Dissatisfaction with this condition
. led the allegers to the sourse of action that triggered this investiga-tion". stier's lavestigation led his to conclude that the procedural violations were being addressed by SFU suelear assagewat and that Parks, e
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-S- January 14, 1984, Mr. Enrold R. Destem ,
- i Giochel, and King knew this. Eis report makes it clear that their public allegations ~were precipitated primarily by other matters not affecting l safety wtilch they felt endanger (d their continued esployment at TM1-2. l These matters did, in fact, result is personnel actions by the company. I i
- Finally, the 01 memorandum states that, "The failure of senior licensee i management to responsibly monitor Bechtel's work and hold Eachtel as-1 countable is the underlying cause of the 'Dit-2 procedural probless". '
Thus, it is implied that a fundamental deficiency existe la the ability and willingness of GPU 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- l t
I ciencies which existed for a period during the cleanup resulted free ;
- ineffective communications during a major management reorganisation" and j l that the deficiencies clearly were seither " acceptable to er tolerated Stier also found that GPU Nuclear management by* CFD Nuclear management.
had the appropriate concera for safety and was taking steps to identify i i
and correct the procedural problese.
e We think the key points that some out. of all the tavastigations and dis-cussions resulting from the public allegations are the follevings I
- 1. Some activities at TM1-2 were not conducted la conformance with appli-cable administrative requirements. We fully endorse the need for
- adeguate administrativei controls, lir. Euhna' letter made clear that F we accept responsibility for any deficiencies la their content er laplementation. We have undertakes and are consitted to complettag the actions needed to correct the identified problems.
- 2. Physical work at TM1-2 was accomplished safely.
' 3. GPU Nuclear management displayed as active regard for safety. ,
J 4
- 4. GPU Nuclear management did not discourage the raising of safety . issues '
4 er suppress their consideraties.
(*
- 5. GFU Wuclear management recognised the structu al and stumusications
.; probless within the organisation, was actively involved is correcting them, and is proceeding to complete those actions.
- A great deal of effort has already been spent en rasponding to the elle-
- gatiosa. We hope that both we and the ERC can now concentrate our resources on continuing to complete safv.y and effectively the decostaar-insties and defueling of TMI-2. We wi1*4 sostians our efforts to ensure that our corrective asseures fally addriees the problems which beve bees -
)'
identified.
I We believe it is aise important to assare that unwarranted damage. to the '
public aredibility of the elesamp program he prevested. Maay honest, N
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Mr. Eare14 % Seaton i a
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seapetest, and well-inteattened esployses of the ERC, SFU h alear, and Eschtet have been puMisly shallenged and impugned by the allegattees i
which, ~1a'the meet part, have leen shows to be unfounded. We trust that she Stier Report will set the record straight in this regard.
i We believe there is an addittomat important 1eeses to be learned from the s
favestitettens of the allegattees. That lesses favelver the mothed by 4 .
which the regulatory process deals with the applicaties of standard l regulatory reguiremente, practices, sad paltetes to a weigue situaties
,such as thct at 1MI-2. We believe that all of these who are conducting, l' '
reviesis , maattering, dad tavestigattag a amigue situaties, such as the -
l steanup, must have e full inaderstanding of the circumstances dad must act '
l with judgment to apply o'r adapt regulatory reguiraments sad guides which I
. i i were writtes for vastly different circusetaa es. -
1 1
- A prise samaple of this is the applicaties to the cursent TN1-2 sitaaties of seguiremente developed for a plaat operating at pawer levels of 1,000,000 kilevatts or mere, pressure of 2,500 pounds per eguare inck, and temperature of 600*F. TM1-1 is new 7 reducing about 30 kalevatts of heat, pressure of about 15 pounds per eguare tack, sad tes.perature of about 150eF. .
We will be paying elese attenties in the seeing esaths to identifying l l
similar situations, correcting them ourselves, or asking receaseadatiens .
l to the Etc staff to correct them. la this way we will apply this laars=
! ing and by se def ag facilitate the safe and tiesty slasaup of TM1-2.
l
- Very traly yours ,
[.
F. E. Clark
' Fresidaat ffk
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j attachment 1 f -
- 'Baslese:en ' slumes 1 and IT of the stier Esport . . . .
~
..- :: uptember 23,19831stter from Mr. Edvis W. Stier. Esq.
bica E. W. Deschamp W. S. Mshas ., ,
E. Blaha, Esquire, show, Pittaan. Fetts & Troutridge
- E. B. Fiafrock, Jr., Chairman, GCRBs l E. E. Esaga, Director, B11,2 !
3 E. Eintner; Esecutive Vica' President -
- 3. Larses,1M1-2 Licensing' & Maciaar Safety Director
. W. Smyth,1M14 Licenstag Manager l
- 5. E. Stiar, Esquire, Einstem; Friah & Charia .
l J. B. Thorpe,'Direeter, Lisensing & Esgulatory Affaire J. F. Wilson, Esgaire, Bishop, Liberass & Osek e .
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ATIACaMENT 1 Menaneestt's Attitudes and Motives The at itudes and motives of 1M1-1 asassement and seater company assage-No charge
- seat toward safety are elearly a very fundaseetal issue.
he me,re serious thsa that the Secovery Program was being managsd mader a i policy air attitude of disregard for safety.
This issue is the major these of the L11egations and, presuashly, a pria-Th 011steria Report itself is set "
. cipal feess of the investigations. It does not state a finding on this l'
' - explicit en managenest attitudes.
Assue. Unfortunately, however, the 01 Interia Report is organised se that l
? it lay 11es an improper assagement attitude. )
1 l'
- - For example, la part D 10 of the 011steria Report, at page 1-4, it is i stated
- \
"The general allegaties that precedure violations and a his-ir torical pattera of misclassifying the safety taportance of ,
various plant modifications represent evidence 'that the l assagement of Three Mile Island Unit 11 (TMI) has sacrificed '
l .
its own system of safety-related checks and balances for the l TM1 Cleanup activities la order to meet wares 11stic time
- schedules' (parks' Affidavit, F3 1) . . .*
The 01 Report then lists the seven findings concerning Managerial Organi-sation issues, such as the taadeguacy of TMI-2 management support spr S and the conflicts between the 1M1-2 organisational structure and Tec* eat-cal Specification reguirceosts. The juntaposities of the seven fladings with the sweepirq 3eneralisaties quoted aheve suggests t L t the 01 taan uneevered evidence of a willful decisien made by TM1-2lassagement to
- cire mvent its safety review eystem. .
Stailarly, the 01 semorsade which forwards'the Interia Report to the 1
Commission, while not Jef taitive, leaves the clear impression that 01 i concludes that there was a deliherste decision es the part of Bschtel !
personnel, to which GPU Wuclear senior assagement acquiesced, to cireme-
- vent required adelaistrative aestrels fer the saka of e3pediency.
'3 e The Stier Report is explicit, and to the aestrary, en this critiest . , .
4 The Stier Report aestaine entensive analysis of ghe attitude of Assue.
1MI-2 assagement toward safety. Various adaimistrative problems were i tavestigated to' determine the underlying safety review polici,es spea
' which TM1-1 assagenest oprated. Im Volume 1 Simmary and Conclusteas, j
page 13, the Stier Esport stat, ass ,
f
"The evidence gathered in the seurse of this investigaties !
'elearly demonstrates that the allegsttees, in their broadest
'sease, are mafounded. That is, the slaims that the assage-anat of 1MI-2 se enconcerned shout the safety of the .
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- recovery effort and retaliated agatast esployees who l
attempted to call t'mese defic.tencies to managenest's l
. ' attention are contradicted by the weight of the evidence".
"Arong the muneroes specific allegations which have been :
raised, we have deteraised that some.are factually correct. l Iowever, the manner la which they have been portrayed pub-licly presents a distorted picture of the adalaistrative
- problems encountered at TM1-2 and o( the attempts made by management to solve those problems. This report.will de-scribs the'veriove adelaistrative deficiencies that existed at TMI-2 during the period ander investigation. Our objec-
- tive is to make e reasonable assessment of their seriousness, ,
discuss whether ansagenest recognised the probles, and describe any efforts andertaken by assagement to correct the situaties". -
' "Vbe allegatie'as imply that the assagement of THI-2 was headed la the direction of tacreased tolersace of ansafe e ptactices. In statrast, the evidence shows that the tread was toward tighter 3daimistrative control to assure that safety standards were met. Whether the problems were brought i to the attention of management by King, Farks, Cischel or by ethers, TN1_2_managenest was reopensive. It andertook steps to assess the validity of complaints and acted upon these -
that were well-foueded. The allegatione that accuse manage-meat of following a policy of ignoring problems brought te its attenties and of peatshing employees who raised the issues are astrue."
Therefore, on this most hesis of issues, we strongly disagree with any suggestion that TM1-2 assagement lacked appropriate concere for safety.
t We believe that the 01 Interia Report and the forwarding memorandum do
,1 mot provide a proper assessnest of managensat attitudes for two hasie-m reasons:
- 1. The investigaties teen did set 'saderstand the unique sitcumstances
- . erested by the accident. Thus, t'aey interpreted issues.ta .the in- .
appropriate seatest of a metaal operating plant. This aloeg with erroneous maderstandtag of some issues, even as they would apply to an operattag reacter, distorted Ithe maderstaedia6 of the TMI 2 aitaation.
- 2. The 01 Interim Report gives as credit to e,he orgeaisaties for identi-ficaties and response to the proklaas by managenest prior to the pc'J11e allegations. The Stier Esport provides estensive documentaties that the problems were being addressed effectively. The doewiented
- actions by management strongly centradiet the implication that manage-most sas ciremoventing its eum safety review systes.
9
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Adherence to Administrative Requirements .
- .g The This gendral issue is discussed at length is the stier Report.
company agrees that there were some activities which did not conform to i
l administrative reguirements. The difficulties with sti11 sin 6 the '
' pre-accident adalaistrative controls because of changed tenditions, the large number of new personae 1 at the site, sad the need to provide a revised orgsalsation suited to the weigue situation led to an early and continuing emphasis os developaeat and see of adstaistrative controls.
The priority on the effort to revise adaimistrative procedures was 4
lacreased relative to other requirements as safety coneiderations
- permitted, withis the procedure revistos effert, priorities also had to e
ne established. For example, early 1's the post-accident time period, the Radiological Controls Program was completely and very effectively re-Tamped, as was the Radioactive Wasts shipping Frogram.
afforts ta revise other adaf.mistrative proceduresThis did not wasprogreer due is largeas rapidly as the company desired and saticipated. That part to the ongoing technical and safety needs which had to be net.
! ' situation should M evaluated is the costost of the tressadeus amount of woth that was done safely, competently, and for the majority of the tasks accomplished la comp 1f,Mee with the adaimistrative requiressats.
Most importsatly, as objective review shows that senior company r.ad TM1-2
- assagement were and are addressing the underlying problems of t'ue need to revise esisting procedures, optimise the organisational structure, and'
.traia affe:,ted personnel on adelaistrative requirements.
' AlthoughtheOkIa'teriaReport.doesnotrefloatallthetrainingefforts that did asist, the company recognises that'more trainias on administra-
- tive procedures was seeded. Consistaat with the recommendation la the 01 i
Interia Report, we have initiated action to assure that trainlag and re-trainias is ' comprehensive enough in asture to assure thet all personnel maderstand the requirements of the procedures."
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Techsteal Judgments on "Important to Safety
- Classifications _ .
4 This issue, as applied to the polar arane, is addressed at length ta the Stier Report. This is probably the area which most clearly illustrates
, the problem of properly applying stanJard requirements to the unig TM1-2 situation.
entire polar crane refurbishment program should have been classified as Important to safety (ITS) because the polar crane structural support is .
classified as IT53' sad when the program was classified as not ITC la July, 1982, it.had not been determined if the structure would be involved. This Another conclusion is technically and administratively incorrect conclusion is that temporary attachments to
'; facorrect.
- the reactor coolant aystem must satisfy 10 Cpt 50 AppeMf2 A design f criteria as those criteria were originally applied to the design of the phat.
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Consistency of organisaties'and Staffian with Technical specifications 4 ;
This categsry of issues was not par: of the allegations and thus is set addressed in the Stier Raport. The first issue in this category is wherbar the M-2 organisation was consistent with the Technical Speci-fler:icee. Contrary ts the 01 Interia Report conclusion, there was act a conflict between the Technical Specifications and the TMI-2 organisation.
.' Specifically, the 01 investigation team tacorrectly concluded that the
- plant Manager" position should have sostrol and authority ever activi-
' ties that were elently outside the responsibility of the pre-secident
- counterpart position (Unit Superintendent) sicaply because the activity sow tak:.s place on site er has the word " operation" la its functieaal 5
title. .
The TMI-2 organisation is structured en the principle that in tbs saigue circumstance of recovery from an unprecedented accident there are many setivities which are completely beyond the scope or espabilities of a
' , site Operations Department organised sad staffed to support " normal" plant operations. At the sans time, there is a vital sud legally maa-dated responsibility assigned to the Site Operations Departneat to maintain the plant in a safe shutdown condition la eengliance with i Technical Specifications and other requirassats.
For these*ressons, the organisation established at TMI-2 (and reffaed es several occasions based ou sur esperience through*the course of ree e-ary), includes two key elemmats
'A Recovery Progress Department heavily staffed by contracter personnel (primarily from two Bechtel companies) having credentials and experience appropriate for the anique recovery tasks at hand, and
'A Site Operations Departeest, which lacludes CPU's experienced and
, licensed operators, as well as support ing as a en n it a ce, engineering, j
and other personnel, to provide the estensive plant familiarity. .
operational espability, and legal accountability to maintaig Aafe
- I shutdown.
These two major organisatiemal matts, with supportive elements, have been ,
integrated into a dingle GFWI Division for nazieum effectivsesse.
t
- At the time of 01's insestigaties, the rssponsibility set forth ta the TM1-2 Technical Speelffestions for the Director - Site Operations tw that hs "shall be responsible for overall amit operaties and shall destgaste La writing the successies of this responsibility during his absence".
This responsibility, sessistent with the Technier.1 Specifications, is .
- assigned la the summary of responsibility fqr the Site Operations Depart-most aestaland la the internal GPU Nuclear Organisation Plan, Revisies
- 10, d.sted Septesher 1,1982, which states the Sita Operations i
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Departneat is responsible to
- conduct plant operations, asiatennace, and angineering et Three Nile Island Unit 1 is a safe, reliable, sad effi-ciest' manner consistent with corporate reguirements and in cespliance with all applicable laws, licenses, regulatory and technical require- The tera mests". This approach is consistent with the ANSI Standards.
- eperation" la the ANSI Standards does not laply that the Director - Site .
Operations has esclusive auth9rity over all activities at the site, nor does it puggest that activities of a asture laboreatly different fr .
to another departaast. -
.: This The TN1-1 erganisation has been reviewed and approved by the NRC.
erganisation is reasonable, responsiva to the demands of the TN1-1
~
j situation, and completely coasietent with.the facility Technical Specificatioac. .
The second issue in this category is whether, dortag April /May 1983, John Barton, the Director of Site Operations (acting), had the qualifi-cations eslied for by the Techeical Specifications; 1.e., those of a
' " Plant Manager" as defined la ANSI N18.1.
The TNI-2 Technical Specifiestions la effect at the time of the The tavesti-gation clearly are based on the 1971 edition of this Standerd.
comparisos of J. J. Sarton's qualificttions for Director - Siteis set forth at the end of thi 4 Operations section.
against ANSI N18.1 - 1971We conclude that the finding on this issue la Report is incorrect for two reasoass
. 1. Mr. Barton fulfilled the Technies1 Specification requirearats Mr. Darton's 25 years for of designation as Director - Site Operations.
training and esperience are particularly suitable for the position
- , of TN1-2 Director - Site Operations.
! 2. The Technical Specifications, through the reference to ANSI N18.1 -
1971, permitted the waiving of tortain requirements for,the "Flaat
,j' -
~- Maasser" laelading that he have the saguisite esperlease and trois-ing moraally required by the ERC of a candidate for sa SR0 license The f
- if one er more primeipal alternates inifilled that criterios.
Manager - Plant Operatieas, who was designated la writtag as the 4
principal alternate to the Directer - Site Operations during the period of interest (April /May 1983), held e surrent Sao license ga EMI-2.
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COMPAR130W OF J. J. SARTON'S QUALIFICATIONS FOR .
, DIRECTOR SITE OFtRATIONS (FLANT MANAGER) VITE ANSI W18.1 - 1971 TECENICAL SPECIFICATION REQUIRENENT =
Technical Specificaties 6.3 .
requires each member of the sait etaff to meet er escoed the
- alataum gualifications of ANSI 518.1 - 1971 ANSI W18.1 - 1971 hetuirement for "Flaat Manager" ,_ ,, . _
- 1. Tea (10) years of respousible power plant esperience, three (3) years nuclear power plant experience. A maximum of four (4) years of the 8 remaining seven (7) years may be fulfilled by academic traisins. .
- 2. The 71ast Manager shall have acquired the experience end tratalag i normally reguired for examination by the AEC (now WRC) for sa $10's license unless one er more persons desigasted as a principal alternate meet the nuclear 9 1ant esperience and AEC examination requiremente la which case the Flaat Manager need have only one of his tea (10) years esperiesce be nuclear pesar picat esperience and he need met be eli-gible for AEC esamination.
- 3. At least one of the perseas filling peef-ions de11aested above should
' - have a recogn;nd baccalaureate er highes !egree in an engineering er '
scientific field generally aseeciated with power producties.
J. J. Barton's qualifications i
J. J. Bartca has a 3sME from the United States Marchant Marine Academy and thus fulfills this requiressat.
Three (3) years Engineerias Officer of the Watch U.S. Navy and Merchant i
%dm.
..* . . . ' . . Four (4) years service with Serg and Bae, las., involved la auslaar
,. plaat and startup activittee. ,. .
- . . Sessa (7) years service with New York Shipbuilding Corporaties la various 4 .
test posittens la the Naval Nuclear Fever Departaast, taciuding Nanager A of the Startup orgaalaaties.
l Eleves (11) years service with SFU in various power plant reined activi-
! ties, sia (6) years of which were solely dedicated to analnr power plaats, including two (2) years previsualy is this same posities.
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l Additi luformationregardingBarton'sasperienceisasfollows: -
[ *, Riceived simulator training (one week sourse).
- Served as Shif t Test Engineer for entire Test Program os one sueltst submarine, and for Not Functioral Testing after core load on another submarineg both SSV lower plaats.
J
- Specialised suelear power training program which prepared sandi-I dates for Shift Test Engineer la the Naval teacter Progres. Upon completion of this training, became the Shipyard seaber of the Joint Test Group for both a nuclear submarine and suelear frigate.
?
- Served as Test Director (overall responsibility for Initial Criti-
! cality and Power Range Tests) for three (3) auclear submarine test programs.
i . Served as Nuclear Power Plant Test Director sa board one nuclear submariae suring initial Sea Trials.
o
- Served as Propulsion Flaat Test Director for tattial Sea Trials of one suelear frigate. (This assignment included not saly the 4 resetor plant, but also the complete propulsion plant and all the availiary systems such as the electric power, SSTC).
- In the positioc of Director, Site Operations, J. J. Barton was qualified as " Emergency Director
- as defined in the 1M1-2
. Emergency Plan, and successfully served in this capacity during actual energsacy situations and is guarterly and annual energency drills. ,
J. J. Chvastyk, who was designated the principal alternate for
' < J. J, Bartoa la his capacity sa acting Site Operations Director during April /May 1983, had approzinately fifteen (15) yerra power plant
- experience with GFUN/ Net-Ed of which thirteen (13) have been at TMI.
Chwestyk held sa SRO license at EMI-2 from November 9, 1977 to August 5 3
- 1983. Therefore, Barton was act required to have the esperience and trainias required for esamination for as 810 lisease.
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@ Froaram and Management Support of it
. 4 The issues in this category are dealt with extensively la the stier
- Report. The Stier Report concluded that the S Frogram was not compre-mised and was not lacking managssent support.
The 01 Interia Report comes to its centrary conclusion based primarily ;
upon consideration of four areass !
- 1. Tin disses of performing audits of the Recovery Frograss Department,
- . 2. Effectiveness of S participation in the polar crane refurbishment,
for elsesifying activities as 178 or not ITS, and ,
4 TIseliness of correcties of S deficiencies.
, Following are.eur comments sa each of the four areast
- 1. QA Audits of the Recovery Frograse Departseat - The 01 Interia Report conclusion that the Audie frogram was deficient is tacorrect. Under our QA Frogram, we audit activities and organisaties salts.
a) In accordance with the CPUE Recovery Q& Program, the Recovery ,
Program Department activities were being monitored by Operations
. S for compliance to the Technical Specifications en a routine basis.
b) The Recovery Frogram Department was established la September 1982. The @ audit conducted, starting in September 19f3, of its
- ' activities and organisation estisfied the annual audit reguire-amat of the Technical Specifications.
c) Teetnical Syseificatios reguiressats for audits of other activi-I -
- ties of the TNI-2 Division have been and are being satisfied.
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.....2. Effectiveness of Participation la the Polar Crane Refurbishment '~
1 Froaras (RAFCRP) - We disagree with the 01 Interia Repott conclusiesr -
that the @ Department did not effectively participate Ka~the REPCRP.
e) There was Bechtel Quality Ragsamering involvement is the classi-fication of the polar crane activities and the establishment of the Ragineeriag/ quality Seguirements.
CPUN S with Bechtel QA Ragineering la b) There was coordinaties by/ quality Requirements applied to the
- regard to the Ragineering polar cease and other Bechtel work.
c) Sym' S did overview the polar araan preseas is regard to asser-tag chat the enfaty slassifiestion ass sessistaat win the C?gs I
Clasrifiaaties Pressen.
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d) Bechtel S hed performed audits to assure that the 3echtel -
- Engineerlag Program is'adeguate and being implemented en Sechtel work deae in Gaithersburg faciuding that en the polar erase.
- 3. Compliance of the QA Program With 10 CFR 50 Appendia 3 in the Method for Classifying Activities l't$ or Not ITS - The company disagrees with the implication is' the 01 Interim Report that the process for decisions with regard to ITS/ NITS classifications is not la seafor- ,
sance with the requiressats of 10 CFE SO Appendia 5 or is otherwise
- saadeguate. The S Flaa specifies the need for classifying work as ITS er NITS. This reguiressat was set.
- Apparently, based on Precedure 38-011, the 01 tsaa incorrectly
- believed that the S Flas required additional classifications. When ES-011 was issued, it was thought that the additional classifications owir and above regulatory reguirements would be helpful la the coa-trol of the work. Eowever, attempts to implement the additional classifications turned out to be tapractical. This procedure has recently been revised to delete those additional classifiestions and f to provide classification of the system, parts, and components into only the ITS and MITS categories. The S Flan reguirements relative to classification of work as ITS or 5178 was not violated as a result .
of these events.
Contrary to the statement is the 01 Interia Report, the S Flas does not rely esclusively on the cognisant enginear to make a proper safety classification, and engineertag is rat performing a S Depart-ment f6 action when it sakas ITS/ NITS decisions.
Responsibility to make this determination is properly and formally lodged with the
- ~'agineering Departaast. The S Flan does not call for S to review
' activities that have been claecified as ITS or NITS although S perform a sampling verification of the safety classification
-es. Examples of this verification fuelude periodic QA moni-e of work functions la addities to the audit function.
S reises its responsibilkies in this area by: ..
a) Baview and soscurrence with procedures defiatag how classiftsa-tiens are made,
.- b) Feriodic verificaties of alassification and the classificaties
' process.
- d. Timeliness of Correction of QA Deficiencies - The 01 Interia Report concludes that the @ Department did not receive proper assagement support to ensure adeguate sorrective action was takes to serrect S identified findiass. We disagree with that general conclasses.
Pour essaples are ased la the 01 lateria Esport to support its ree-alasisas ru
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a). The first osample refers to a closeout of two quality Deficiesey toports (qDRs) based es techtel's statenest that they will ase the established adelaistrativa sostrels for dotag ITg work and that work psekages are to be ased to accomplish recovery tasks which are determined to be wholly and particularly independent of the GPU Nuclear procedural system. Contrary to the 01 Interia Report conclusion, work outside she scope of the S Frogram may be properly performed to another set of administrative sostrols.
'From a S Frogran point of view, that was sa acceptable response to the QDE.
', b) The second example deals with the timeliness of backfitting
?
destas verification documentation practices os design work per-formed insadiately after the accident to the reguirements of the In
- TM1-1 Modification GFUSC quality Assurance Flaa (QAF-M1).
recognition of the need for rapid installation of sodifications
,during tattial Recovery Operations, the Flan did set require formal documented desiga verification. It did reguire review of design work by gus11fied personnel. The NRC soscurred with that l Flaa. '
The decision to preceed with backfitting of docuneatation on the
- esilier modifications was made following the develoyeest of a new Flaa. The ass S Flas required documentation of design veri-5fication of sodifications la recognittom of the entended time i
aried of the cleanup program and the need to retura to aermal a practices. .h 01 IPteria Report is sorrect as to the length of time it took to clear that QDtc Bowever, given the entensiveness ,
ef the work affort involved and the relative importance of l
- having,'ae compared to other high priority activities, the doeu-mentation complete, the length of time for elearing the @t was
' appropriate. The @t has been closed out and the documentation tackfit effort has been completed. In any event, the time required ta' this lastance'io not typical and does not reflect tho' .
degrae of saassement support for the W Frogram. Numeroeg.
- - 1setances esa be listed which show strong manatenest supperg. .
This is evidenced by the fellowing tables .
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SUNNART OF QUALITT DEFICIENCY REPORTS & AUDIT FIFDINGS .
't 1
1981 1982, 19838 144 117 68 a) Open at bestasias of year 176 70 63
- b) 36w itoes ,
203 119 88 e e) Itsas Raeoived 117 '68 43
- 4) Open at and s,f year e) Itess in (d) eyes lenger 21 7 51 than 180 days -
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c) The third example relates te QDRs where closecut depended spea issuance of revised administrative control procedures. In 1981, work was initiated es a soaplete mistos of Ithe adelaistrative controls systems la see by GFUN. This was a asesive effort but (
necessary to standardise controls la use at GFUN's three avsisav '
facilitise and to reflect the complei,ely rgstructured organ.tsstiaa put into place with the establishment of GFUN. This effort was l
well along by mid-19',2. Eeuever, the decision to integrate j
Bechtel and GFUN composeats of the TM1-2 organisation aise resulted in a decision to have a stagle set of administrative procedures for all site work. Prior to those decisions, Sechtel
- , was tasked with developtag separate procedures for their easite, -
as well as offsite, work. Both of those decisions caused addi-tienal revisions to the saw procedures about to be put inte place. Traasition to the new procederse system took placo en
,' Jammary 3, 1983 with the issuance of'the first forty-five new or .
revised adnimistrative controle procedures. We de not thtak this
" performanse tadicates a lack of managensat support for the @
- Fregram.
) d) The fourth assaple relates to miselasafficaties of safety systems.
- Disagreements over classifiestion have occurred during the re-severy effort. Tht's is not surpristag in light of the saigne airtuastances over the last couple of yeats. Iowever, aestrary l
' views were seasidered la reviewing the decisionsiand the sentrol systems led to serrecties of otrors is classificattoa. It is slee
- important to meta that the Stier investigaties coacauded that technical judgments en elassificaties were made is good faith, Moreover, the app 11sattee of a 'new concept in the scope of the @
- Fragrams that of "important te safety" as aestrasted with " safety related" ans a major shaage for the todastry as well as for O
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TM1-2. The dompany moved aggressively to implement this concept Management .
, resulting ta S coverage of many more activities.
support f or corroeting .all of these probless preceded the publia silegations and sinco has reavited la revistos and update to the
- Quality Classification List m totablishment of guidelines on how classifications are to be made. The revised guidelines more ac-urately refleet the current conditions at IMI-2. .
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- 7; Functionism of RC's TM1 F100kAM OFFICE (TWIF01 i t.L, To the eatsat possihte, without the benefit of interviews of the ERC Mis report
- staff, this issue was addressed la the Stier lavestigation.
sencludes that there were as improprieties en the part of the company or the TMIPO staff in the contee of their interactions. In response to the '
allegation that there was improper internal use by seabers of the TM1-2 staff of RC's informal conneats en draft procedures er planned metivi-
' ties,' explicit instructions have been issued to help assure that does met happen in the future. .
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