ML20090C094
| ML20090C094 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/11/1984 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 8407130162 | |
| Download: ML20090C094 (51) | |
Text
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'Of 12 July 11,, 1984 4//,,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart-Management (Three Mile Island Nuclear
)
Phase)
Station, Unit No. 1)
)
NOTICE TO COMMISSION, APPEAL BOARD, LICENSING BOARD AND PARTIES Enclosed for information of the Commission, Appeal Board, Licensing Board and parties is a copy of a complaint by Lawrence King and Gloria King which names as defendants, GPU Nuclear, Bechtel and certain individuals. The complaint was filed in the United States District Court for the Middle Dis-trict of Pennsylvania on July 9, 1984, and seeks redress for alleged injuries sustained as a result of Mr. King's discharge from employment at TMI-2.
Licensee was not served with the complaint but obtained a copy this date.
Respectfully submitted, W $ A ho Ernest L.
Blake, Jr.,
P.C.,
Counsel for Licensee 8407130162.840711 PDR ADOCK 05000 Q
DATED:
July ll, 1984 cc:
Attached Service List
a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Three Mile Island Nuclear
)
(Restart - Management Phase)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S.
Nuclear Regulatory Commission John H.
Buck Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Thomas M.
Roberts, Commissioner U.S.
Nuclear Regulatory Commissi6 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge James K. Asselstine, Commissioner Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commissi@
Frederick Bernthal, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Ivan W.
Smith, Chairman Lando W.
Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commissi@
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 Commissi@
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
2-Administrative Judge Mr. Henry D.
Hukill Gustave A.
Linenberger, Jr.
Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.
20555 Middletown, PA 17057 Docketing and Service Section (3)
Mr. and Mrs. Norman Aamodt Office of the Secretary R.D.
5 U.S. Nuclear Ragt latory Commission Coatesville, PA 19320 s
Washington, D.C.
20555 Ms. Louise Bradford Atomic Safety & Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C.
20555
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Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street n & Ruclear _Raau12torv Commission Washington, D.C.
20002 i
Washington, D.C.
20555 Lynne Bernabei, Esq.
vernment Accountability i
Jack R.
Goldberg, Esq. (4)
Pro]ect Office of the Executive Legal 1555 Connecticut Avenue Director Washington, D.C.
20009 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Harmon, Weiss & Jordan Thomas Y.
Au, Esq.
2001 S Street, N.W.,
Suite 430 Office of Chief Counsel Washington, D.C.
20009 Department of Environmental l
Resources Michael F.
McBride, Esq.
505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.
Harrisburg, PA 17120 Suite 1100 Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, VA 23212
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HARRIS su A d. v.s.
171ti Locust Street
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(215) 546-G651 A't LERK P E 3' Mi
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l:ARTII: GREITZER GRSITZER A!!D LOCES 1500 Walnut Street
' Philadelphia, PA 19103 (215)'893-5440
' Attorneys for Plaintiffs Ul!ITED STATES DISTRICT COURT FOR TI!E. IIIDDLE DISTRICT OF PE!!!!SYLVAt:IA LAUR21;CE PETER kit!G,'JR.,
CIVIL ACTIOli
- and GLORIA KIIIG,
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GPU l'UCLEAR CORPORATIO!!, DECHTEL COU2LA,IET i
I ORTII AtlERICA PO'-TER CORPORATIOli, ROBERT C. art!OLD, BAH!!A!! K. KAt!GA, :
'PHILLIP R. CLARK, JOHli J.
BALTOli, jai!CS 17. THIESII:G, MILLIAf! E. AU.STI!!,,DARRELL II.
BLIZZARD, JAt4ES U.
BUELL, DAVID R. BUC!!At!Uti, and RICHARD E.
GALLAG!!ER, Defendants.
JURY TRIAL DEllAPIDED
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'a Plaintiffs, by their attorneys, bring this civil action to seck redress and obtain damages, both cocpencatory and punitive, f rom the defendants naaed herein, and complain and allege the O
d i-1. -C l tollowing.
I.
JUIitODUCjJoy 1..This is an action for compensatory and punitive damages arising under the coccon law of.the Commonwealth of Pennsylvania in orde~r'to obtain redress for plaintiffs from defendants for personal injuries sustained as a result of plaintiff Lawrence King's wrongful discharge from employment by Aef and'nt CPU t!uclear Corpora, tion.
1 II.
JDSJSDJ.C2JOILbED_JLCDU.S 2.
This complaint is filed and 'these proceedings are instituted under diversity of citizenship, 28 U.S.C. Section 1332. The named plaintiffs are citizens of the State of Virginia.
Defendant GPU Nuclear Corporation ("GPUN") is a corporation sthich is not incorporated. under the: laws of the State of Virginia and does nE2 have its principal place of business in Virginia.
Defendant Bechtel North America Power Corporation ("Sechtc1") is a corporation which is not incorporated under the laws of Virginia and does not'have its principal place of business in Virginia.
Upon information.and belief, defendants Robert C.
Arnold, qahcan 2.
!:enga, Phillip n.
- Clark, James
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- Thiccing, M
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Uilliam C.
Austin, Darrell M.
Dlizzard, Jamed M.
Buell, David n.
Buchanun, Richard C.
Gallagher and John Dalton are citizens of the State of Pennsylvania. This claim alleged herein arose withia this judicial district.
The matter in controversy e::c eed s, i
e::clusi.ve of interest and costs, the sum of ten thousand dollars (S10,000).
,1 III.
L
- 3. The plaintiffs are. residents of the state-of Virginia l
l with a residence address of P.O.
Box
- 228, Rt.
1, Huddleston, Virginia 24105. Plaintiff Lawrence King (hereinaf ter " King"),
4 was employed by GPUN from May 27, 1980 unt'il his wrongful discharge on March 23, 1983. Plaintiff Gloria King is the wife of Laucence l
t King.
- 4. Defendant GPOU employed King in the position of Manager t
of the Operations at Three Mile Island Unit Tuo (TMI-2) from May 27, 1980 until his wrongful discharge on March 23, 1903.
(
S Defendant Dechtel co-managed the recovery efforts at g
Three Mile Island uith GPUM from appro::imately September, 1932 4.
through King's wrongful discharge in March, 1933 G. Defendants, Robert C.
Arnold, Dahman K.
Kanga, Philip n.
Cla rl:, John J.
Dalton, James W.
- Thiesing, Uilliam C.
- Austin, Darrell M.
- Blizzard, James U.
- Duell, David R.
Buchanun and 3
i
. i h
,, - :. -ci nichard C.
Gallagher are officers and/or employees of CPUM or ncchtel.
7.
Plaintiffs are informed and believe and thereon allege, that each
. defendant designated herein is responsible, intentionally, negligently or-in some other actionable canner,
~
for the events and happenings hereinafter referred to, and caused injuries and damages p r o::ii.:a t ely theteay to plaintiffs as
. hereinafter alleged, either through defendant's own conduct or through the conduct of its agents, servants or employees.
Said defendants are responsible for directing, supervising or perpetrating the unlauful acts and other conduct from which this complaint arises.
' 8. For purposes of this
- action, all defendants are one entity, jointly and severally liable for one another's acts.
At all times centioned
- herein, all defendants have operated as agents and/or in' conjunction and agreement with each other.
LV, DByDDbL_bLLDDb'UDDS
- 9. On the 27th day of May, 1980, King and GPuu entered into an caploycent agreement, uhereby GPUM agreed to employ King in the capacity of Operations Manager for the tera of indefinite years from the 27th day of
- May, 1900, and to pay for such services the sua of S4 4,000. 0.0 per year.
Through a series of
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-prouotionc and calary'incroaccc,.;ing, on Augtrat 1, 19 P. 2, becane as
- anager~of Site Operations' at an annual salary ri te of.M0,500 i
dollars.
- 10. Frou the 27th of i'ay, 1900, until his wrongful dischargo i
under said contract, ::ing faithfully diccharged his duties and responnibilities.
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- 11. 7.u..'innager of nitr
" r:.tican, li n.:. uas recponci la f o t..
e e
i certain tasks involving the clean up, recovery and rehabilitation of Three ~Ilile Island a. ter the near nuclear catastrophe in 1979.
- 12. "in car rying ou t his duties and responsibilities, ::ing raised administrative and safety concerns about the Three I:ile
- Island-2 P.ccovery Progran and the polar crane refurbichtent program.
These concerns were c,onveyed to nunerous persons tihroughout G_'lli!
and Dechtel including come, if not all, of th'e
-named defendants.
Attached as E::hibit A
are copics of
. inter-offico comoranduns to and fron Lawrence- :<ing concerning t
~
- said adninistrative~and safety concerns, and e::ccepts of ::ing 's Congressional testicony on this subject.
- 13. O'n the 24th day of
- February, 1903, GPUU, in direct r e t alidtlion. againct ' :*.ing for raising the aforcaentioned safety cnd adainistrative concerna about the recovery prograu dicrogarded the torno-of the aforecentioned contract and I
Oucpended ;"ing without pay.
14.
On the 23rd day of IIs r ch, -
1 ? ': 3,
- GPUM, in
.iitect i
I totaliatipa againct.!in.;
for raininj the afote:tentionan safety i
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a n.1 administrative concerns about the recovery progran dicrogarded the te rr:0 of the cfo r e:.ien t ioned con:ract and te ra:.nated ::ing ' c orc.: lay :en t with GPm'.
- 15. King han been villing,rcady and able to coat nue caid empicytent and carry 'our said contract with.
GDC'.'.
GPU:!
hc0 refused and still refucos to allou King to do so.
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,13. The allegaticas contained in paragraphs 1
through 15 inclusivo are hereby realledged as thcugh fully rewritten herein.
- 17. From the inception of his contract with GPUi till his su ponnion and terr.:ination, King has perforced all conditions, covenants, promices, duties and responsibilities required by him in thic contract.
- 13. On February 24, 1933 and- !! arch 23, 1933, GPUI! breached said contract by first uuupending King-uith.out pay and then termin:Qing his cuployment.
Said suspension and tern:ination was
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uithout juct cauco and in direct retaliation againnt ::ing for hic raicing 'cafety and adainistrative concerna about the roccvery prograa at Three..ile Inland.
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- 19. The allegations contained in paragraphs 1
through la inclusive are-hereby realledged as though fully rewritten herein.
- 20. By repeatedly questioning the aforecentioned safety and-administrative concerns King incurred the ill-will of GPUM and e
Bechte1, the corporations who were jointly responsible for the
- clean up of.Three Mile Island..
- 21. At all; times relevant herein
- GPUN, Bechtel and all individually named defendants had due notice and knowledge of King's coployment contract with GPUU.
22.'Motwithstanding this notice and knowledge, GPUN, Bechtel and all individually named defendants, and each of
- them, knowingly and willfully conspired and agreed among thenselves to break King's contract with GPUM, thereby depriving King of the
-benefits of said contract and depriving King'of the ability and opportunity to earn his 1[velihood.
A VII.
C'0UUT_IUEES;__COUS2IESCY_2C lDJDBS OUEmIU UIS_EEDEESSIOU
'23. The allegations contained in paragraphs 1
through 22 inclusive are hereby realledged as though fully rewritten herein.
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- 24. King, prior to his urongful discharge and breach
- r. :.
contract, had deservedly earned and enjoyed the confidence :ad esteem of his neighborn and acquaintances, and was empicyed an tlanager of Site Operations by CPUti, i
- 25. The defendants,.well knoving King's good reputation and
- standing, entered.into the aforementioned conspiracy with the r
added intOnt.of injuring-King 's good na::e, fane, and credit in his aforesaid profession, and to bring him into public
- scandal, i
infamy and disgrace among his neighbors and co-workers.
2G. In furtherance of this conspiracy, the defendants, in the p'resence and hearing of King's neighbors, contemporaries and subordinates, did malign and impugn King's reputation, good will, 4
confidence and esteen by falsely and faalicicualy spreading false accusations concerning King and his professional behavior while-in the employment of GPUN.
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-27 The allegations contained in paragrapha 1
through 26 4
inclusive are hereby realledged as though fully rewritten horcin.
1 20.
Since his wrongful discharge, GPUU has not released i
- ing's coployment recordu to Xing's prospectivo new employers in a forthright and diligent fachion as requested by
- King, thereby
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causing I*ing to lose several job opportunitien.
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- 29. The allegations contained in paragraphs 1
through 23
-inclusive are here*oy realleged as though fully couritten herein.
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- 30. The aforeocntioned conduct by defendants was tortious in i
nature and resulted in King being wrongfully discharged from his t
contractual relations by GPUll X.
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- 31. The allegations contained in paragraphs 1
through 30*
inclusive are hereby realleged as though fully rewritten herein.
)
- 32. Defendants' conduct was intentional, malicious, wanton i
and done for the purpose of causing King to suffer humiliation, mental anguish and emotional and physical distress and r
proximately caused King.to suffer same.
XI.
_CDDUT_srySD.;,_ E gLIDEULJDEL1D;2DU DLEDD 1DDbL D1D3 DES 3 33.'The allegations contained.in paragraphn 1
through 32
-inclusive are hereby realleged as though fully ecuritten horcin.
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- 34. Defendants' conduct, if not intentional, did negli.jently cause King to suffer h u r.:il i a t i on,
mental anguish and enotional and physical distress and pro::imately caused King to suffer same.
XII.
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- 35. The allegations contained in paragraphs 1
through 34 inclusive are hereby realleged as though fully rewritten herein.
- 36. Prior t'o the physical and emotional injuries suffered by Lawrence
- King, he was able and did perform his duties as a
husband.
Subsequent to the injuries and as a
pro::imate result thereof, Laurence King has been unable,to perform the necessary duties and services usually performed in the care, maintenance, and management of the family home.
By reason
- thereof, Gloria King has been deprived and vill continue to be deprived of the consortium of her
- spouse, including the performance of her husband's necessary
- duties, all to Gloria King's damage and detrimqqt.
MTII.
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- 37. The allegationn contained in paragraphs 1
through 35 inclusivc are hereby realledged as though fully reuritten
- 10
. : <r3-t -e t herein.
33..The actions of. defendants as allege'd herein constitute gro Gly negligent and
- willful, knouing, wanton and intentional misconduct relative to the wrongful discharge of Lawrence ning and~ plaintiffs should be granted an award of punitive damages for said misconduct.
'XIV.
JDBX 2ElbL_DEU31DED 31.. Plaintiffs demand a trial by jury of all the issues herein so triable by. jury.
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32.
MHEREFORE, Plaintiffs pray for concennatory an c::emplary damages against defendants' in a 'reasonabl.e,, fair and
'juot amount to be determined by the jury and such other relief as may be deemed.
just and proper by the Court including reinct'Ilement'and back pay together with reasonabic attorneyc' fees and costs of this action.
i i-Dated:
June 23, 1984.
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9'.i-1-Cl A L L A ll K A t![l E R, ESQ. ~
PAUL LAtlDAU, ES?,
LA?! OPPICES OF ALLAi! EAtitl2C 1718 Locust Street Philadelphia, PA 19103 (215) 546-66G1 7
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ALLAll KAtlllER, ESQ.
!!ARTIN GREITZ Ell, ESQ.
GREITZER A!!D LOCKS 1500 tralnut Street Philadelphia, PA 19103 4
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Attorneys for Plaintiff
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0 - u -i, - V-T bOkOE-O NCO hdOTDCTSDdui"M Data May 21, 1982
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a0 Subject Engineering & Operations Staffing yl j
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To J. J. Barton Locntion TMI/U-2 Site Operations Admin. Bldg.
i The present Engineering and Oocrations staffing levels are inconsistent with our goal,s and responses required by the NRC.
d
. In.the past six (6) months, we have spent thousands of manho6rs research-i
-ing and responding to NRC concerns regarding problems and management controls.
I have become aware of a noticeable increase in NRC questions and concerns which results in our expending considerable resour.ces to respond to these con-This limits Engineering's ability to perform med~ningful tasks for the cerns.
plant:
- 1. Trending of plant data
- 2. Respense to Maintenance requests for Engineering support.
- 3. Review of work requests to determine generic problems
- 4. Review of Operations and Tech. Spec. sure"illances
- 5. Response to Q/A audits
. We are in a reaction mode responding to NRC concerns.
They (Lae Tonus) are digging into old files to uncover problems.
.I am giving direction to John Lee to se,t up separate charge numbers to respond to these concerns:
- 1. jum il iary Building Ventilat ion
- 2. Old-1.ER's
- 3. Trit ime in ground water
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- 4. Containment Air _ Lock Most of these problems are age old proble=s thakarenowgettinghigh visibility due to in depth NRC probing.
In order to respond to these concerns we will have to staff to a level where we can respond in a timely f ashion.
Mr. Barrett has accused us of not being sensitive enough to these issues.
The facts are that h e' has core personnel looking for problems than we have persennel in Engineering that can respond in detail to NRC questions.
This leaves no time to do plan; trending, procedure preparation, etc.
t-l Tne requirement to have individual NRC' procedures for each task we per-t form is requiring expenditure of considerable manpower.
Most of these pro-cedures are being written by Ben Slone and Bubba Marshall.
Engineering does not have the manpower to respond.
I ll believe if I am to manage Site toerations and respond to the NRC concerns in a timely fashion, that I need to have a say in the required canning.
We have identified (K. Draper and B. Slone manpower breakdown)
P that we do not have the manpower to respond to the required 1982 work.
This was before Slone and Marshall's involvement in the " Quick Look" Program.
- v I myself have difficulty responding to all your questions on individual problems.
This certainly leaves no time for getting our house in order It is one hell of a lot easier to ask questions than to respond.
/
1.suggest that we sit down with Mr. Ranga and enme up with a plan for responding to these concerns.
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L. P. King ce -" " u.:.w Acting Director. Site Operations v-
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M t ac!=ent Comments on Polar Crane Decon Proposal -- K. J. Hofstetter 10-19-82
.l.
It would appear that widespread use of chemicals in the Reactor Building is receiving tacit approval.
Is this consistent with CPU policy as evidenced by the recent CORB recommendation?
(a t ta ched )
2.
As the major method of contaminated cher' al disposal appears to be solidification, do we have a group assigned to determine compatibility with cement so lid i f ica t ion, shipping requirements, burial ground require-ments, waste assay, etc.? Appears to be quite a loose end.
3.
Is there a better acid neutralization chemical than Ca(OH) 2?
Very difficult to remove Sr in solutions containing high Ca++.
Why not use Na:C'0 NaHCO ?
3 or 3
4.
- Have the. chemicals and reagents been closely screened to deter =ine ef f ects on:
a)
SDS zeolites
'b) 'EPICOR resins c) corrosion of systems d) compatibility with components e) industrial safety hazards f) chemical toxicity g). residuals that may end up in RCS h).radiolytic breakdown 1).
compatibility with other wastes, etc.
5.
Another ' consequence of rags f alling into the R3 sump would be to plug the pumps. What would be the consequence?
- 6. _ What chemical reactions could take place in the sump if chemicals were introduced and how might-it effect the desludging effort?
7.
The presence of decon chemicals (chelating agents, etc.) does effect w.ter processing!
The first bleed tank be ches had to be a
reprocessed through the SDS.
Cene ra l "CG3nen t I realize that ef fective decon can only take place by using chemicals in a locali:cd~ manner.
Sacrificial cedia can be put in the water processing systems to protect the zeolites or resins, but the generation of new vaste forms and ultimate disposal is. a more pressing problem.
We need to demonstrate that we have carefully thought out the consequences of our decisions.
/
~Perhaps these check lists have been identified and'the decision matrices worked out.
I have not been involved.
I feel that this operation can be cafried out safely with successful decontamination results.
I would only hope that the overall impact of dollars and man-rem expenditt
. heen accurately accessed and just ifies the use of chemicals.
t enink the answer is, whatever I take on, but then again, I thought waste
- '~
- shipping was 'in my area.
You responded negatively to a letter that I wrote,
.,trying to force the issue on "SDS filters".
I believe you said, "Isn't this your responsibility? Do you think somebody would try to stop you?"
Again, I agree with you,
~
wrote the letter because I wanted thatI though it was my responsibility, but only clarified.
It turned out that it wasn't my decision to ske.
How many times has "Mr. Barrett been able to go over our heads to reverse our. decisions"? What support has been received?
I am confused because even if something is in our area of res~ponsibility, we do not. have the authority to make those decisions.
I find myself respond-ing to a series of memos on what I consider " TRIVIA".
The real issues such as the following, seen to drift without any noticeab!c improvement"
- 1. What to do with RCS level
- 2. Cleanup of Auxiliary and Fuel Handling Buildings
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- 3. Inefficiency of'present containment cleanup.
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LPR/j mw Site Operations Director cc: File (s) 9 a
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W i
s inter-Office Memorandum Date October 20, 1982
-4
_r/ d~i Is[ U C[!G S T Suolect Coe. cents on the Polar Crane Decon Plan To J. C. DeVine, Jr.
Location TMI-2 Site Ope:ations 4200-82-448 Ref:
Memo 4500-82-0032 dated October 5, 1982 (received October 18, 1982)
Site Operations has reviewed the proposed plar-for decontaminating the polar crane.
While the planned work sequence appears to be technically sound, the apparent widespread use of chemicals in the reactor building is disturbing. Attached are the cornments of Plant Engineering (K. J. Hofstetter) on -the chc=ical aspects of the decon-tamination effort.
While the use of chemicals may be required for large scale decon-taminations of this type, we must carfully screen the chemicals to be used.
It appears that the Chemical Hazards Analyses section of this plan does not address all the concerns.
Site Operations will assist the Technical Planning and Site Engineering groups in establishing the criteria for approving the use of chemicals in the THI-2 decontamination efforts.
-Until these concerns are resolved or the proposed plan is reduced in scope, I cannot concur with the work effort.
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Site Operations Dir 6r IPK: KJH: hh
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. Attachments cc:
K. J. Hofstetter E. H. Cischel
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3rliOT-difiCO iVlamGrandum Date
-January 10, 1983 y=-q ri.
4200-83-017 L;Ji_J ( d 'jj ]l ".s i; C Q g"f g
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e V 3 ".~./ S,6 u ScD ect P,esponsibilities for ECM-Related i
Docu=ent Changes
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- 3. K. Kanga Locah.on t
Three Mile Island J. J. Barton_
Unit #2 Admin. Building The following activities are severely handiccpped be'cause of unidentified responsibilities for documents required by ECi to be initiated or changed:
1 (1)
Approval processing of ECi's.
(2)
Turnover to Operations upon ECM completion.
(3)
Maintenance Department, Plant Operations, and Recovery Operations dependent upon the above two items.
The following action is recce= ended:.
(1) A -aating-to discuss and seek agree =ent on responsibilities.
Suggested attendees:
J. J. Barton B. K. Kanga W._F.
Kelly L. P. King J. E. Larsen J.,W. Theising (2)
Hanagement decision and directive to i=ple=ent i=ediately.
-(S)
Incorporation into new modifications control procedures scheduled for. implementation March 1,1983.
The main proble= area is EO!-related procedure changes.
It is 4
suggested that Operating Alarm Response', and Surveillance pro-cc'dures required to be initiated or changed, be the responsibility of the Responsible Engineer, the writer of the ECt.
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4200-83-017.: '.-
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Enclosed is a list of all docu.: ants which can be ef f ected by EG.
Proposed responsibilities are included.
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L.4. King-a Site Operations rector
- n4rst EN/ LPK/ tn
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Enclosure I
W. F. Kelly cc: 1.
'J. E. Larson'
'J.^W. Theising 6
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m % msAu c> - GKi 031S37[dNiG3 MO2IGDYOT.3d'J?T3 Data:
Nove ber G. 1982
'D 02 Y M!
Farsonal Access Facility 2eg,',fw[,J !:f}.}1 f, (h{ (h [
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4200-32-479 TC2
, J."J. Earton Location: IM1/U-2 Sita Operation 2 f
31d. 9222 - P. con 1109 3
RLTE2ENCE: Me=crandum 95211-82-1220 T. A. Grace to 3. K. Kanga j
Much discussion has t2 ken place recently over tha use of savage-i holding tanks on the island, and specifically, the tank installad on the subject facility by S-ZCM 1001.
I At the present ti=e, the use of the abova tank would violate Stace Sewage Act 537, section 7 and Sewage Regulation Chapter 71, sections 5.1 and 5.2.
In addition, no provision is =ade for in-ground tanks in any Londonderry Township orginances.
Please be advised that the use of this tank is unlawful until the propar pernit or variance is obtained.
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a !!anage cat Tool'
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',200-8 3-06 M To:
R. ?!et::ger i.m.a t i on : T::I/U-2 Ft:e op..ra c ians B l d.;. f/2 2 2 - IO o t l09 4
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t The purpose of this memorancum is to once again expreis my con:. erns on the use of a punch list as the means of.:anaging the head lift tasks.
This is an inadcountr-t oc '. f o r r.:0 n t a r i n g 4..- pr. r
..t af the p roj :c because it does not identif y the reintionsl.i,:s or tics be u.ee:t sequencel tasks.
This is of particular importance to Site Operations as we are the icplementing or final nequence on many of these tasks and rely on timely i
input from other groups to caintain our schedule co:mitments.
To date, you have not identificd any instaneca where the group providing input is delinquent except for line #17. There have been numerous i:: stances where
, Site Engineering / Design Engineering have not met thel cccmitments, as
- sho.n on the punch list, but were never shavn as being delinquent.
The ccmcon practice used by these groups to evoid being identified as delin-t quent is to "reforecast" the duc date.
liy using the punch 1,ist, the impact deanstream of thase "reforecasts" cannot be adequately idantified and the schedule changed accordingly.
Site Operations is impacted be-cause as thc.1 plementor va cre held resocasibic for accomplishing the ta sk on tice, regardless of lat. input or lach cf input frum other groups.
This is not a realistic or logical canagement strategy.
It is your job as the controlling group for acecnpliching the head lif t to identify as unacceptable late input on the front end of these taska, and :o fully realize the impact to subsequently scheduled activities.
To use a specific exatr.ple, it was identified to you in a ;irevious
,lettet that information had not been received fenm Desir,n/ Site Engineering on the drain path and level indication for schedule line items 9 and 10.
e rdsponsible parties were identified as Lake and Rider, but you failed to identify the fact that they did not meet their commitment of December 24, 1982.
Even though this front end input slipped, mod! fying pro, edure :,
U't?tini; I UI's.nnl tha phys te21 oth ts.;ociat ed with the tacka.rere i t. i t ]
1
.cxpceted to be accompli.:hed on tirc.
To complic::te oat t ern even iurdw..
Site Operations una than rer.uented to accenplish the ala ve on the i,x.i of a new a.:cclerated schedule to nu;1 port the " quick scan".
As a further c:: ample, the punch lint item for final receipt of tha head removal SER is still not shovn.
,\\a late as Februar:.
1, 196J. M te Optstations is ntill being sh.avn an delin<tuent oc.::1:. f ten, when in
- t our cerr.nents ware. returned on L:> 41 der on J.uv.u ry l9,.983.
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io act re f icc tcsi 1.: the fact thut the d".1: w n ni e r ceive.1 in.to':!cf.n
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,9 a Management Tool
'.200-83-068 Ta:
R. Me:::1c:
i.n r.a t i o:'
T:;1/L:-2 Fi te Oper:0 i:ma alda., U222
,iMom "109 5
i The purpose o ~ this memorandum is to one e again express my concerns ton the use of a punch list as the means of :nanaging the head lif t tasks.
This 1.4 an inadequa m tool for monit,riag p rm-aM thu ; r ;j.:c:
because,it dees not identify the relationahips or ties betwen sequenced tasks.- This is of particular importance to Situ Operations as w are the
' implementing or final sequence.on trany of these tasks and rely on timely input from other groups to maintain our schedule commitments.
To date, ycu have not identiificd any. instaneen where the group providing input 1s delinquant except for :linc #17.
There have been nueerous 1:2 stances where
, Site Eastneering/ Design Engineering have not met their commitmenta, as
'shown on the punch list, but.ncre nevar shavn as being delinquent.
The cor:u::an practice used by these groups to avoid being identified as deliu-quent is to "reforecast" the duc date.
By using the punch list, the impact. downstream of the.se "reforecasts" cannot be adequately idantifice!
.and the schedule changed accordingly.
Site Operatiens is impacted be-cause as the implementor v2.are held resocasible for accomplishing the task on time, regardless of late input or lach of input from other groups.
This is not a realistic or lot;ical nanagement strategy.
It is your jol, as. the controlling group -for accenplichin:; the head lif t to identify as unacceetable late input on the front cud of those taska, and to fully realize the impact to subsequently sciicduled activities.
To use a specific example, it was identified to you in a previous
, letter-that information had not been received from Design / Site Engineering on the drain path and level indication for schedule lina items 9 and 10.
'!hn rdsponsib!c parties wre identified as 1.ak'c and P.ider, but you failed to. identif y the fact that they did not meet their commit: rent of December 24, 1982.
Even*though-this. front end input s11pped, =odf fying procedures, Tfting 1:III's t.n.! the phy> leal v. irk tsaociat ed with the tacks vere atill expected to be acco=ulishad on eine. To compl icate; matt era even f uren.'c,
Site Operaciens was then rer,uented tu acconplish the above on the basi af a new accolorated schedule to nupport the " quick scan".
As a further c:: ample, the' punch lint item for fina' receipt of th.2
. head removal SER is still not'shown.
As late as Fuhruarv 1, l '1:i j, 8ite Oparations is sti.it bein[; sh:vn as delineguent on.ni:. f ten, when in
.w t our cerre:entr, vare returned Lt' LS RIrier on January 19,. 90.
What i-net retlected i.; the fact that the S 51'. v.ir n.
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allos fer an adeqmte rc.vte in tt.;ht of e.a.ec m with p.z r,si.n!.
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- s' i:ca; lift Punch 1.i..t
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as a lbnsgement Tao!
g,ge,c ge Ac I f.edicated to y..u and otners, in y.,ur organiza tion, t.m en t -
u.t y to prepurly st.itur and r.onitor all af 'he interfaces requi. ed
'h, lu:ad lif: is thrt ugh an intcerated, deta:;er held litt s ch <:ce l.f
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At t5Ls paint in time we hove nor hri a d t.itled head lif t schedu a
.t inec :?ove:nber 17, 19 C.
Thi; is totally unacceptable and ubculd i.e
';" a tioned by c..: nap,em. n t.
- c. Thicu tnr. : rated at least two ve,J.,
ago that a revised detail..d :: cad lif t schedule was issued, but I be-lieve his state: cat wa s in ceror.
As of this date (February 7, 19d3) this revised schedule has still not been issued.
'.Jhen and if thi.
schedula is issucei, the most apparent problem is that it does not identify the criti:11 path itens and the constraints to these i t e:,s.
U:: of t'.e mer.c critical i te:. :, the pelar cranc, is not uvan sht,un an the head lift schedule.
I do not see the logic la this because the polar cranc is reeued to accomplish many of the tasks and failure of this i:.ca to comphte on tima vill literally push the entire head lif t
' schedule out to the ri;;h t.
As a method of docu.nenting my ability to mae.t our committneats, I an pecuaring a form'lett. r ta notify you of ficially when I have not received necessary procedur':s or en -ineerint. inform.1 Lion pertaining to our tas!a.
Distributten vill be made to you and C. 11 Hultman caly.
I am not usinc your punch list addition fern based on ny experience of January 17, 19F5, at which ticie my.;rcup submitted our cha:::;cs and con =cnts and they were not. inputed to tha punch list a:; shet,.n.
I will be available er discuss any aspects of this remorandun.
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~ Site Operations rector I.?K/JFP/Lw h: Fileis) e S
3disOT CiN CG I$$CY D Te3U d MUO D.t ic :
February 7 1983 ev xw:: m:str:j
,,f,G9fYtOdlfW.a ri Yfk,7lb(
kaw.naa_ f m d gi3 7f/!.1%.n.m Q
Subject:
Con,: erns over 1(ead Lif t Se.nedule
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4200-83-069 To:
S. K. Kan;;a/J. J. Barton
, Location: THI/U-2 Site. Operations Bldg. #222 - Roon 4l09 REFERE::CC:
L. P. Kin.:; nemorandu :: #4200-83-068 to R. >!ctns;ce -
Subject:
Headlift punch List. as a Management Tool (Attached)
Site Operations has expressed repeated concerns over not having an integrated schedule.
In order to cope with meeting our end daccc
~ wa have developed detailed schedulus to idantify where inf orha tion is needed to muer milestones en the =sster schaduht-7hs relgro.u W memorandum to R. I'etzs;ct identifics my concerns. Verbal requests have nct sceced to be effective in getting a resocnse.
1,'e have spent several hotirs in a meeting in Room 209 discussing a schedule that was put to;; ether at the last =inuta, with our input.
This was only donc because of the rer;uest by yacr office to hold the meeting in your presence.
The present head lif t schedule does not r.hnv integration with the peiar crane schedule and, if thic had been done, it vould have identi-Eied that the crane vac not available to support CRC 11 removal.
I have revicved,the polar crann schedule and ta' ked to the polar crane schedu-l 1er and the polar crane will not be availabic to remove ':he eissile shields until March 2, 1983.
This fact has not been identified to you and certainly will impact " Quick Scan", CRDM removal and louerlag of thq water.1<svel.
RDf.D continues to work of f mini uchedules withe se identli'ying overall
% pact.
tinci=cly del tvery-of engineering sof tuare has caused lata input of information necessary to write peccedures and perform verk.
h'one of these concerns have been identified ir. the RCf.D head lif t minutes and, connequeritly, na net ton taken to enrrect them.
I believe r.he. integrated :,chedule is needeu itmadiately to identify nny further it. pact on the June 30. 1983 date.
D.ive Lahn needs ricre cinely inpist en n hedula resources and work !n the contalement.
T! e pres. nce of yous-affice is neet ed at t h e "a a'il !. i f t meattom until we arc orce a: pin i.n tr.ek to ueet. t he.h.ne 30 th c :rt.:ta tt:Nat.
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% -[ O 'f - O I N O S 2l5 0 1'e'l C E 3 I Da te's February 8, 1983 FE810 w;L s
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Subject:
Head Lift Minutes and Commitments
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of February 2, 1983 Maeting W d'*M 4200-83-074 To:
R. P. Hetzger Loca tion: THI/U-2 Site Opera t ions Bldg. 0222 - P.oca t109 j
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'The minutes do not reflect the. fact that Si te Opera tions. request ed and received no com;nitment for you to provide an integrated schedule.
A majority of the problems that have existed have been caused by lack of an integrated schedule, p\\f\\
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Site Operations D1 tor LPK/jmv g
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- cc: J. J. Barton R. E. Heidig, Jr.
H. L. knson R. D. Parks D. R. Buchanan 5
H. K. Pastor J. J. Byrne J. F. Perry s
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J. J. Chuastyk R. L. Rider J. A. Flanigan L. C. Rogers
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J. R. Floyd R. E.--Sieglitz R. L. Freemerman C. R. Skillman y.Greenborg J. A. Smith s
J. E. Hildebrand N. W. Spang C. V. Ht.i t ma n
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R. B. Svartzvelder k
B. K. Kanga C
W. Tomb C. A. Kunder J. R. Vogel D. H. Lake H. S. Williams W. J. Marshall H. D. Smith R. Montgomery
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