ML20092P370
| ML20092P370 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/29/1984 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20092P371 | List: |
| References | |
| 5211-84-216, NUDOCS 8407060216 | |
| Download: ML20092P370 (8) | |
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GPU Nuclear Corp <xation NUCIMr 100 lnterpace Parkway Parsippany, New Jersey 07054 201 263 6iS00 TELEX 136 482 Writer's Direct Dial Number:
June 29,1984 (201) 263-6797 5211-84-2164 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Eisenhut:
Three Mile Island Nuclear Stetion Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No.60-289 Employee Protection and Company Communications Your letter of June 14, 1984 advised that you are reviewing the Office of Investigation investigation reports received to date concerning matters related to the issue of GPU management integrity with respect to the restart of Three Mile Island Unit 1 and requested a response that addrer.ses each of the questions in the enclosure to your letter.
The.equested response is enclosed.
As.'hown therein, it has been and is the policy of GPU Nuclear Corporation to:
1.
Protect its employees and those of its contractors and subcontractors from discrimination as a result of raising safety concerns (including activities covered by 10 CFR 50.7) and to take needed disciplinary action to enforce that policy.
2 Ensure that communications between its officers, employees, and contractors and the NRC are complete and accurate.
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation t
y Mr. Darrell G. Eisenhut Page 2 Employee Protection and Company Communications June 29,1984 As discussed in the enclosure, this policy has been broadly promulgated and implemented in a variety of ways. We continue to look for and act on ways to increase the understanding of and compliance with all of our policies.
Very truly yours, il j
P. R. Clark President Enclosures cc: J. Axelrod R. Conte J. Gutierrez T. Murley W. Russell J. Stolz J. Van Vliet Sworn and subscribed to before me this
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THREE MILE ISLAND UNIT 1 DOCKET NO. 50-289 RESPONSE TO INFORMATION REQUEST OF JUNE 14, 1984 LETTER FROM DARRELL G. EISENHUT TO PHILIP R. CLARK The NRC questions address GPUN policies in two general areas:
1.
Protection of employees of GPUN and its contractors and subcontractors from discrimination as a result of engaging in activities covered by 10 CFR 50.7.
2.
Assurance that consnunications between GPUN, its officers, employees, or contractors and the NRC are complete and accurate.
The NRC questions also address the GPUN response to Mr. Parks' allegations of harassment.
GPUN Policies with Regar'd to 10 CFR 50.7 and Communications with NRC:
Establishment and effective implementation of policies within GPUN are carried out in a variety of ways. Because the two areas addressed in NRC's questions on GPUN policy are the subject of laws and NRC regulations, they are generally addressed by the following documents which are central to GPUN activities and widely disseminated within the company.
A.
Organization Plan of the Corporation:
This document defines the organizational responsibilities within the Corporation. The responsibility of the operating divisions (TMI-1, TMI-2, and Oyster Creek) and the technical support divisions (Technical Functions Radiological & Environmental Controls, and Nuclear Assurance) includes the requirement to carry out all activities, "in accordance with corporate policies and applicable laws, regulations, licenses, and technical requirements".
B.
The Corporate Mission:
This document states, " Manage and direct the nuclear activities of the GPU System to provide the required high level of protection for the health and safety of the public and the employees.
Consistent with the above, generate electricity from the GPU nuclear stations in a reliable and efficient manner in conformance with all a)plicable laws, regulations, licenses, and other requirements
- and lie airections and interests of the owners."
- Emphasis added 1
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4 4ESPONSE TO INFORMATION REQUEST OF JUNE 14, 1984 Page 2 LETTER FROM DARRELL G. EISENhUT TO PHILIP R. CLARK June 29,1984 a
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The essentials of this Mission statement for GPUN were first enunciated in March 1980 as a statement of responsibilities applying to the GPU Nuclear Group, the predecessor to GPUN. They have been unhanged since then and were republished in 1982 and 1983 in conjunction with the Objectives and Goals of the Corporation. Thus, p
they were in effect during the January through June 1983 time period.
C.
Corporate Objectives and Goals:
The Corporate Ob,jectives for 1984 were expanded to include objectives specifically related to informatiot, flow within the company and to public officials. These are:
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Assure absolute openness of -information availability and O
exchange within GPUN so as to assure that all information which t
might affect safety of mclear activities is available to
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respons1 Die compshy officials.
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Provide infonnation in a timely and trustworthy manner on the s'
activities and operations of THI-l and TMI-2 and Oyster Creek to the various publics of GPU; i.e., public officials, the media, t.he general public, employees, shareholders, and governmental Jagencies.
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In additioti to-the'promu)9ation of these broad policy statements, we have establir.hed a number of formal mechanisms by which employees can identify s0fety concerns and have the".i addressed. These mechanisms have been imolemented by'fonaal procedures which were put into place Hm tb8 GPU Nucleer Group before GPUN was formed and then were carried a + by'rward by. tl.e Mew CWN Corporation when it was established in s
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N' January 1962fTioyJprnvide processes for evaluation and disposition
,s of any concerns id9ntified.. These include:
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'4ny employec. may raise concerns hing'those r.wthods,
\\y GPUN also has Matablished a virid;y of formal groups wiihin the s'
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Corporation wp,se' purpose is tu dcLk out, identit.y. and obtain resolution of sa.fety issues, k These include:
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P RESPONSE TO INFORMAN 0N REQUEST OF JUNE 14, 1984 Page 4 LETTER FROM DARRELL G. EISENHUT TO PHILIP R. CLARK June 29,1984 identified and aired without fear of discrimination. To this end, the need to identify and address safety concerns is discussed in meetings by the GPUN Fresident with his staff and by that staff with their managers.
The Ombudsman Program is explaint;d in General Employee Training and is publicized by postings at various locations around the plant and other work locations, and by articles in company newsletters. Form NRC-3 is posted at the plant site and other work locations. The TMI-l Plant Director specifically solicits safety concerns and emphasizes the Corporate Policy and legal requirements on these matters in annual individual meetings with each licensed operator.
He also discusses this policy with members of the plant staff during their scheduled training period at least annually.
Additional examples of specific steps we have taken to emphasize our policy on these matters include:
A.
Hemo from R.
C'. Arnold to TMI-2 personnel dated April 13, 1983 (Enclosure - 3).
B.
Memo f rom P..R. Clark. to employees assigned to. nuclear activities dated February 27, 1984 (Enclosure 4).
C.
Memo from P..R. Clark to Directors dated May 21,1984 (Enclosure 5).
D.
t;emo from P. R. Clark and.H. D. Hukill to TMI-l Shift Supervisors cated March 2,.1984 (Enclosure 6). Similar. memos have been issued approximately annually since late 1979~.
This body of information which has been made available to employees, taken in conjunction with the attitudes fostered by management, makes it' clear that discrimination against individuals for engaging in the protected activities under 10 CFR 50.7 is prohibited.
The cotapany would exercise administrative sanctions against_any individual who discriminates against employees or contractor personnel for 10 CFR 50.7 activities. These sanctions' range from reprimand to time off without pay to discharge depending upon _the severity and other circumstances associated with the particular case.
Specifically with regard to contractor personnel, we have as a general condition:of GPUN contracts:
Contractor, its employees and representatives shall at all times comply with all applicable federal, state and local laws, ordinances,
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statutes, rules'or regulations including but not limited to those telating to wagesc heurs, fair employment practices, equal opportunity,-antidiscrimination, safety, fire prevention and working
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RESPONSE TO INFORMATION REQUEST OF JUNE 14, 1984 Page 5 LETTER FROM DARRELL G. EISENHUT TO PHILIP R. CLARK June 29,1984 1
In addition, contractor employees who work on-site are provided with copies of the R. C. Arnold letter (Enclosure 2) and informed of the
' Ombudsman Program as part of the same General Employee Training given to GPUN employees.
In the event GPUN were to determine that a contractor had discriminated against an employee for engaging in protected acts under 10 CFR 50.7 sanctions up to and including termination of the contract would be exercised depending upon the circumstances involved in any specific case.
Continued attention will be applied to this area to ensure that our practices ~ and policies on these matters will remain effective.
With regard to the issue of accuracy and completeness of comunications with NRC, the broad policies articulated above, coupled with the day-to-day attitude and professionalin. of our management promote adequate assurance of full and accurate communications. Specific examples of management's attitude and attention to this matter are P. R. Clark's memo of December 8,1983 identifying the need for full and open communications within the company and with regulators (Enclosure 7),
P. R. Clark's memo of September 1,1983 on the need for clarity and explicitness (Enclosure 8), and P. R. Clark's memo of May 15,1984 and i
i reference memos on reportability of information relative to issues under review by licensing boards or NRC staff (Enclosure 9).
In addition, we have instituted a Corporate procedure that defines the system of management and the organizational elements responsible for review of regulatory correspondence. This procedure was promulgated in August 1981 to apply to the GPU Nuclear Group and has been incorporated into the Corporate Procedure Manual for GPUN.
Engineering or technical information that is developed to support regulatory correspondence is subject to internal peer review and coment by formal procedure.
Adherence to procedures is in turn auaitable in accordance with the Corporate Quality Assurance Plan.
The company would exercise administrative sanctions against any :
individual who willfully violates policy on these matters. These.
sanctions range from reprimand to time.off without pay to discharge depending upon the severity and other circumstances of the particular Case.
With regard to contractors, we have as a geneN1 condition of GPUN contracts:
Contractors shall conduct the work in a systematic manner and shall establish a quality assurance program and control procedures which will provide a systematic independent check and confirmation of data collected and analyses made therefrom and the recording of the quality control efforts.
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I RESPONSE TO INFORMATION REQUEST OF JUNE 14, 1984 Page 6
- LETTER FROM DARRELL G. EISENHUT TO PHILIP R. CLARK June 29,1984 GPUN reviews or audits most information provided by its contractors.
Errors or omissions are corrected and steps taken when appropriate to assure accuracy of submissions.
GPUN would exercise sanctions for willful, flagrant, or continuing failure to supply complete and accurate information. Depending upon the severity of the particular case, the contract could be terminated.
In summary, it is the policy of GPUN to:
1.
Protect its employees.and those of its contractors and subcontractors from discrimination as a result of raising safety concerns (including activities covered by 10 CFR 50.7) and to take needed disciplinary action to enforce that policy.
2.
Ensure-that communications between its officers, employees, and contractors and the NRC are complete and accurate.
GPUN's Response to the Parks' Allegations of Harassment:
e Edwin H. Stier was retained by GPUN to investigate and report on the Parks' allegations, among others. Stier reported on Parks' allegation that he was replaced as alternate startup and test supervisor at page 79-81 of Volume IV of his report and on Parks' allegation that he had been removed as the primary site operations representative on the Test Working Group at page 81-84 of Volume IV. Stier found those two allegations unsupported.
Stier also investigated and reported on Parks' allegations that Ed Gischel, '.awrence King, and Joyce Wenger, all GPUN employees, had been harassed and found these allegations unsupported.
Since Parks was an employee of Bechtel. North American Power Corporation and not of GPUN and Bechtel was performing its own inquiry to defend the US Department of Labor proceeding Parks had initiated, GPUN agreed with Bechtel that Stier would not independently investigate the relationship i
between Parks and Bechtel except to the extent Parks' safety allegations overlapped that relationship.. Stier, therefore, did not investigate the questioning of Parks by Bechtel employees or the suspension of Parks.-
It was expected, however,E that these' two allegations would be thoroughly aired in the DOL proceeding. That proceeding was settled without attribution of fault or liability and Parks withdrew his harassment complaint. GPUN was not a party to the settlement but was kept informed l
of its negotiation by Bechtel and executed a mutual release with Parks.
GPUN believes that Parks' allegations of harassment have been adequately-addressed.
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