ML20092P378
| ML20092P378 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/18/1982 |
| From: | Arnold R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20092P371 | List: |
| References | |
| 1000-POL-1740.0, NUDOCS 8407060222 | |
| Download: ML20092P378 (27) | |
Text
Enclosura 2 Numb:r Nuclear GPU Nuc lear Corporate Policy and Procedure Manual 1000-POL-1740.01 Title Revision No Employee Contact With Regulatory Agencies 0
Applicacihty/ Scope Responsible Of fice Office of the All GPUNC Employees President - 1000 This document is important to safety 0Yes/No Ef fective Date List of Effective Pages Page Revi sion 1.0 0
2.0 0
El-1 0
El-2 0
CONTROLLED DISTRIBUTIO DOCUMENT SERIAL NUMBER-Signature Ccncurring Organizational E ement Date Onginator ll
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Manager of Management Services n-n-pu concurred
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Approved by /
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7" 8407060222 840629 A0001051 3 82 PDR ADOCK 05000289 1.0 P
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Number Nu21 ear GPu suciear carp 2 rate Policy and Proc; dure Manual 1000-POL-1740.01 Title Revision No.
Employee Contact With Regulatory Agencies 0
1.0 PURPOSE To establish a GPUNC policy regarding standards for GPUNC employees to follow when dealing with a regulatory agency.
2.0 APPLICABILITY / SCOPE This Policy shall apply to all GPUNC employees.
3.0 DEFINITIONS REGULATORY AGENCY - A department of the United States, state or local government charged with investigation / enforcement of laws governing the nuclear power industry to protect the public health, safety or environment.
4.0 POLICY 4.1 It will be the policy of GPUNC to require openness, candor, and honesty from its employees in regards to their dealings with representatives of the various regulatory agencies.
4.2 This Policy is explained in detail in the attached exhibit.
5.0 RESPONST"ILITIES As defined in the attached exhibit.
6.0 REFERE NCES GPUNC Policy,1000-POL-1020.01, "Onbudsman - Nuclear Safety."
7.0 ATTACHMENTS Exhibit 1, R. C. Arnold 10/9/81 Memo to Employees.
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iUCIear GPU Nuclear Corporate Procedure No.
J Policy and Procedure Manual 1000-POL-1740.01 Title Employee Contact With Regulatory Agencies OPU Nuotoar UCIMF 100 Intercace Parkway i
Parsicoany. New Jersey 07054 20t 2634500 TELEX 136-482 Writer s Direct Dial Number:
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Dear Mr..:
.. a.l The special demands inherent in the utilization of nuclear technology impose upon the Company additional responsibilities and needs not generally found in other Industrial situations. Because of the potential for the facilities to affect the surrounding communities, our employees have a broader responsibility for diligent, capable and professional performance than just their obligation to the Cos;eny. For these same reasons, a large body of regulatory requirements have developed.
The obligation for compliance with these various requirements extends to all of us. As the government regulators carry out their responsibilities for assuring compliance, they interact throughout the organization.
Under these circumstances, we think it is helpful to remind you of the Company policy on the relationship with the regulatory agencies and to provide you with explicit guidance on this subject. Although what we are discussing are legal requirements, please remember the objectives of the requirements -
protection of public and amployee health and safety. All of us, the Company included, have a self-interest with regard to those objectives. Indeed, the Company's interests are best served when it is clear to everyone that we are sincerely committed to fulfilling all of our obligations, including those that 1
are embodied in regulatory requirements.
With that background, we request you consider the following:
1.
lie have a legal as well as a moral obligation for our activities to be in compliance with all relevant lave and regulations. It is the policy of the Company to be in full compliance with these requirements s
as a minimum and actively strive to achieve full compliance where they haw not been met.
1 2.
Our status relative to company and legal requirements needs to be elest and easily visible within the organization. To this end, employees are responsible for reporting to their supervision 1
conditions or situations that are not in accordance with Cor pany or l
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1egal requirements which they have reason to believe that appropriate 3
management personnel are not aware of.
Dese cocaunications l '
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GPU Nuctear is a part of the Generat Puche Utihties System i
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P MmgG M GPU Nuclear Corporate Procedure No.
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s Policy and Procedure Manual 1000-POL-1740.01 Title Employee Contact With Regulatory Agencies I
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will flow most reliably when there is generally an atmosphere of openness and candor. I might note that we recognize circumstances and i
personal considerations asy occasionally seem to hamper communications within the organisation. Because of this, the CPU Nuclear organization, established in September 1980, includes the function of Cebudsman within the helear Safety Assessment De partment for reporting of information or concerna in such instances. Whe n appropriate, reports to the Osbudsman are confidential.
3 It is Company policy, and in some instances a legal requirement as well, that we provide complete and timely disclosure when circumstances provet.t full compliance with the requirements.
Siellarly, the Company will cooperate with the regulatory agencies in any inspections or other reviews directed toward determining the status of cospliarae. Baployees should be straightforward, open and professioaal in their interfacing with reguletory agency employees.
An employee may have information that is potentially embarrassing to the Company, but that should not inhibit providing that information to a representative of an outside agency that has a legitimate interest in it.
4.
When a representative of a regulatory agency wants to talk with an individual employee about matters of laterest to the agency, tha representative has the right and the authority to pursue discussions, with the employee. In the course of any discussions, the employee is less11y responsible for being truthful. The agency should not carry out those discussions at a time or in a manner that hinders the employee from fulf1711ng assigned work responsibilities. The employee must exercise his judgment as to the circumstances and respond accordingly (checking with supervision if appropriate). Also, when a private interview with an esployee has been requested by a repre-sentative of a regulatory agency, it has frequently been their policy to permit the employee to be accompanied by someone of the employee's choice during the interview, to record the interview, or to consider other requests by an esployee that will facilitate proceedings with the *.nterview.
If a representative of a regulatory agency aska an employee for an irter.lew, the employee shor'd not hesitate to request from the agency representative an explanation of the availability of these or other options prior to pror.eeding with the interview. This request should be made if the employee has any concern as to the purpose or reason for the interview.
Assin, the interests of the Coexnv. Its employees, and the public are best served by an open and cooperative attitude and honesty in our interactions with the governmental amenetes responsible for replating our various activities.
We expect your active support in fulfilling these aspects of our public and corporate responsibilities.
Sincerely, R.C. Arnold j
Qilef Operating Executive o~
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Revision El-2 No.
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Intar Office M:mcrandum
- 2 D:te April 13, 1983 g
Subject To TMI-2 Cleanup Program Personnel As you probably are aware, Ed Gischel has provided me with an affidavit ex-pressing his concerns about TMI-2 operations and the recovery efforts.
He also asked me to give the NRC staff a copy of the affidavit and I have done so.
The subject matter of his concerns has been routinely raised and dis-cussed throughout the year.
All of us, including the GPU Nuclear Board of Directors, myself and our senior officers, recognize the right and the obligation all have to advise us promptly of problems that could affect the health and safety of the pub-lic or personnel'at TMI-2.
We urge all of you to share this recognition of Mr. Gischel's rights on these matters which he believes were not being ad-dressed.
This event highlights the fact that if anyone in the GPU Nuclear organiza-tion has concerns about health and safety matters, those concerns should be promptly passed on to others in the organization so they can be addressed.
Usually this can be done, as it was in this case, through the regular super
- visory channels.
If, for any reason, you think this might not be effective, you should not hesitate to get'in touch with the Office of the Ombudsman, Mr.
Kanga, Mr. Clark, or myself about the matter.
Our common objective is to CLEAN UP Three Mile Island Unit 2 IN A SAFE MANNER so that any potential threat to public and worker health and safety is removed.
I am confident we all share a broad comitment to this objective.
This confi-dence is based upon the excellent results achieved to date by the dedicated and very capable performance of so many.
t Inherent in the commitment we have is the necessity for everyone to address safety concerns raised by any member of the organization promptly, profes-l 31onally and on the merits of the issues. A major reason for Mr. Gischel's conclusion that he had to give voice to his concerns in the manner in which he did, was his sense that issues raised by Site Operations were not ad-dressed objectively and on their merits.
While, based on the information I 1
have at this time, I do not share his concerns as to the issues he has raised, l
the Conpany will be investigating fully the concerns raised by Mr. Gischel as l
well as those recently expressed by others.
It is essential that every mem-
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ber of the organization behave in a professional manner.in all their activi-ties here at Three Mile Island. Anything less reduces the credibility and effectiveness of the organization even if it does not result in any activity beind done in an unsafe manner.
h y'.A R. C.
ld President slm I
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' e' NEEMI 38 100 Interpace Parkway Mw E
Parsippany. New Jersey 07054 201 263-6500 1
TELEX 136-482
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Writer's Direct Dial Number:
1 February 27, 1984 (201) 263-6797 T0:
ALL GPU SYSTEM EMPLOYEES ENGAGED IN NUCLEAR ACTIVITIES
SUBJECT:
SOME IMPLICATIONS OF THE INDICTMENT OF METROPOLITAN EDISON COMPANY FOR PREACCIDENT ACTIVITIES AT TMI-2 The recent Federal indictment of the Metropolitar Edison Company on charges relating to preaccident activities at TMI-2 points up important lessons and leads me to write this letter to each of you. As we look fomard, I want to reemphasize our policies in areas related to the charges in the indictment.
Since the establishment of GPU Nuclear, its Mission has been clear:
" 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."
Each and everyone of us is responsible and accountable to carry out this Mission faithfully.
A major purpose of faithfully discharging this re-sponsibility is to warrant public trust. Such trust cannot be retained if our compliance with procedures and limits is uncertain.
Basically, the indictment charges that this responsibility was not fulfilled by Metropolitan Edison Company with regard to Reactor Coolant Inventory Balance Testing at TMI-2 in 1978 and early 1979.
To understand the indictment, it is helpful to consider the structure of l
our NRC Operating License.
1.
The License requires that we abide by or meet Federal laws, ~NRC regulations, and the License itself including the Technical Specifications.
2.
NRC regulations and our License require that we have and comply with procedures for many activities.
The indictment of Metropolitan Edison Company makes three general charges which have important implications to our current and future activities:
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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o They were required to meet a specified limit or to take correc-tive action.
(The specific limit was related to unidentified leakage but that is just an example of the general case).
They established a procedure to determine if this limit was met.
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They knew that the procedure was inadequate to do the job, i.e.,
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it gave such widely varying results that it could not show '
whether the requirement was met or not.
They did not resolve the issue by either improving the procedure o
or getting the requirement changed.
l The point for us is:
Whenever any of us believes that something we are doing is in-o proper or incapable of meaningfully achieving its purpose, it must be identified and we must get the question resolved. We must not " live with" or continue questionable practicies. We have established in GPU Nuclear a variety of means for identify-ing any such problems and must use them.
They include Procedure Change Requests, Radiological Deficiency Reports, Preliminary Safety Concerns, and for safety issues, if the other mechanisms 3
do not work, the Ombudsman.
2.
They did not follow the administrative procedures which were deve-loped and issued to implement the regulations and our License.
i Specifically:
They did not enter in the logs the start and end of each Reactor o
Coolant Inventory Balance Test.
o They did not keep all test data.
For tests they considered invalid, they did not document wh it o
was considered invalid.
The point for us is:
o We will follow our procedures. This has been emphasized time and again. We also have defined how to change a procedure which is believed to be unworkable or wrong.
3.
They did not infom the NRC:
That they were having difficulty getting good test results, and o
o Of the conclusion (by some or many) that the test was not
. meaningful.
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. The point for us is:
In addition to identifying issues intarnally, we will keep the NRC o
fully informed of problems, difficulties, and questions.
None of these points is new--all of them hava been stated and emphasized
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repeatedly over the last several years.
Complying with them is important to help ensure we operate our plants safely.
It is also our obligation under our License.
In many cases, failure to comply can result in civil or criminal penalties on the company or on individuals.
Separately and independent of any action by the government, failure to comply may be cause for disciplinary action by the company. Will ful, knowing failure to comply will make the individual subject to discharge.
kb-P. R. Clark President cc: Mr. R. O. Keim, Vice President, Human Resources, Meted Mr. J. J. Westervelt, Vice President, Human Resources, JCP&L t
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.7 Nuslear memorandum I
Subject:
Lessons Learned from Situation At TMI-2 Date:
May 21, 1984 (Subject of Stier's 'Whistleblowers')
From:
P.R. Clark, President Location:
To:
Chairman, GORB Director, Administration Director, Communications Director, Human Resources Director, Maintenance & Construction Director, Nuclear Assurance Director, Oyster Creek Director, Radiological & Environmental Controls Director, Technical Functions Director, TMI-l Director, TMI-2 Attached for your information and discussion with your staff is a paper developed on the above subject.
P.R.Cl ark PRC/mak attachment cc: Executive Vice President A0000648 8-83
l Nualear ucmarandum Subj:ct:
Lessons Learned from Situation At TMI-2 Date:
May 21, 1984 (Subject of Stier's Report 'Whistleblowers')
From:
P.R. Clark, President Location:
To:
GPU Nuclear Board of Directors At its November 1983 meeting, the Board requested that we reflect on general lessons to be learned from the situation which existed at TMI-2 in late 1982 into early 1983. The attached paper was developed in response to that request.
It is being distributed to all Division Directors who will discuss it with their Staff. With regard to item 8, a policy has been issued calling for return to work examinations in appropriate cases.
In regard to item 9, we have retained new separate contractors for psychological screening and employee assistance. Written guidelines on confidentiality are part of the arrangments with these contractors.
P.R. Clark PRC/mak attachment 1
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LESSONS LEARNED FROM THE EVENTS AND SITUATIONS DESCRIBED IN THE STIER REPORT
- 1. Management must be alert to the overall attitudes and interactions of the organization and must assure that organizational and people issues are being effectively addressed.
Continuing conflicts and disputes within the organization need to be understood, dealt with, and resolved openly and promptly.
Appropriate resources are to be made available for resolution of all such issues.
Areas of concern
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include 2, 3, 4, and 5, below:
- 2. BACKGROUND: One of the more difficult lessons learned is that there is a judgment to ts exercised by all supervisors and managers in
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accepting different opinions, allowing discussions, and then termi-nating the debate or dispute and going ahead with appropriate actions.
SUMMARY
- Open discussion on technical issues is to be encouraged.
However, each employee must understand his role and the limits of that position.
The appropriate manager has the ultimate responsi-bility to exercise control, terminate a dispute, and take appropriate action including advising those involved of the basis for such action.
- 3. BACKGROUND: A number of' misunderstandings and disputes in the working relationship between several groups may have been avoided if the groups had a proper understanding of their responsibilities and the procedures under which the particular. task would be perfomed. As an example, if all groups had had a proper understanding of how the work would be perfomed for refurbishment of the polar crane and the pro-cedures that would be used for that work, almost all of the major problems could have been avoided.
SU!U1ARY: The various groups involved in a task should have a common understanding of the applicable procedures under which the task will be perfomed and what the procedures require.
If they do not, the misunderstanding must be ~ identified and resolved before proceeding.
- 4. BACKGROUND: In the past there have been problems associated with individuals belonging to GPU Nuclear and Bechtel organizations view-ing each other more from an organizational background rather than as individuals.
GPU Nuclear and Bechtel Executive Management have l
instituted, through the Organizational Development
- Program, a
management direction to overcome these differences.
SUMMARY
- Individuals from different organizations need to. work in close cooperation with each other with open, unambiguous communica-tions.
Where differences of opinion arise, such differences must be recognized and resolved on their merits in a cooperative manner.
They must not be characterized or treatea as differences due to their H
organizational background or personality conflicts.
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- 5. BACKGROUND: Some of ehe concerns of voiced by certain personnel may have been caused due to their personal perception of other parts of the organization competing heavily against them personally, or their group's.
SUMt%RY: A certain amount of competition between groups is to be expected and, indeed, encouraged for overall efficiency of the pro-
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ject.
- However, excessive competition or "oneupmanship" between groups should not be tolerated.
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- 6. BACKGROUND: An employee had indicated his dissatisfaction of working in the THI-2 organization and his lack of acceptance in the integrat-ed organization as early as sumer 1982 During that time, he was encouraged to interview with different divisions in Parsippany.
SUMtMRY: Management should identify employees who are not satisfied with assigned positions or the conditions of work. Management should have such employees define their problems (orally or in writing, as appropriate).
If, after discussions and review of the concerns such employees continue to be dissatisfied, appropriate personnel action should be taken.
- 7. BACKGROUND: All employees need to clearly understand and appreciate the problems created by written communications that are not written in a professional manner.
SUMMARY
- Both internal and external communications such as letters, memos, reports, etc. must be written in a professional, unambiguous manner stating facts and clearly identifying opinions where opinions are expressed.
Under no circumstances should such communications in-clude attacks on an individual's motives, personal capabilities, lack of knowledge, etc.
If there is concern about such items, it should be brought to the attention of appropriate management where action, if appropriate, will be taken.
- 8. BACKGROUND: Any differences in treatment of employees after returning from major illnesses, unless properly documented and justified, could result in misunderstandings.
SUMttARY: An appropriate corporate policy should define the type of fitness check, doctor's certificate, etc. that should be required of an employe: who returns to work after a major illness.
Such a policy should be applied to all employees.
It may be necessary to make certain distinctions in terms of the requirements based upon reason-able differences in the employee's position and work.
- 9. BACKGROUND: Mr. Stier has indicated the problems created by comments
. from Stress Control to certain employees and by referral of employees to Stress Control.
s.
SU! NARY: Appropriate policy and guidelines should be issued regarding i
the confidentiality of information and the dissemination of informa-tion to GPU Nuclear by organizations such as Stress Control.
The
. guidelines should also define to whom and in what manner those organ-izations will comraunicate such information to GPU Nuclear.
Such a statement should then be published and available to all employees who avail themselves of the services of these organizations.
Guidelines clarifying the circumstances under which employees should be referred to organizations such as Stress Control need to be issued to those in supervisory positions.
- 10. BACKGROUND: There were instances in which personnel failed to follow through on relevant information made known to them.
SUMMARY
- All employees have an obligation to discharge their duties in a thorough, professional manner.
Failure of an employee to act accordingly is unacceptable.
May 7, 1984 9
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GPU Nuclear Corporation MUClear 2'te9'Z'souin S 48 Midcletown. Pennsylvania 17057 717 944-7621 TELEX 84 2386 I
Writer"s Direct Dial Number:
File: Procedures /
Policies 3000-84-096 March 2,1984 TO: TMI-I SHIFT SUPERVISORS
SUBJECT:
COMMAND RESPONSIBILITIES
/
Nuclear generating facilities have the potential to significantly impact the health and safety of the public. This potential impact places a special burden and responsibility on those who manage and command operations at the Three Mile Island Nuclear Station.
The first line of defense in protecting and assuring the health and safety of the public and the safety of personnel within the plant is the safe operation of all plant systems and components. You, as the Shift Supervisor, hava the primary management responsibility until. properly relieved, for the safe operation of the plant under all conditions occurring on your shift.
Accordingly, you are directly charged with both the responsibility and the command authority over all shift operations, and maintenance activities, and implementation of radiological controls under nomal and abnormal conditions.
Both the supervisor coming on shift and the supervisor teing relieved shall make certain they review, convey and understand plant status and on-going activities and that the activities are deemed to be in accordance with safety requirements.
Your responsibilities require you to constantly maintain the broadest perspective of operational conditions potentially affecting the general public, TMI personnel, and the safety of the plant.
Maintenance of this broad perspective shall be your highest priority at all times when you are on 5'
duty.
In this regard, in times of emergency, you should be sure never to become so involved in any single operation that you are preoccupied to the extent that you might not provide adequate direction when multiple operations are required in the Control Room.
During accident situations while functioning as Emergency Director you shall remain in the Control Room to l
manage and direct the activities of the Shift Foreman, Control Room l
Operators, Shift Technical Advisor, Radio'.ogical Controls Personnel, other l
plant operators and required support personnel in accordance with the I
approved Emergency Plan until properly relieved.
l GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation l
- February 2,1984 3000-84-096 An essential element of protection of public health and safety is timely notification of State, local, NRC and Company officials in the event of an accident. There should be no reluctance on your part to initiate the notifications called for by the Emergency Plan if conditions indicate a potential threat to public health or safety even if more evaluation is necessary to confirm the existence of such a threat. Further, it is imperative that you provide the opportunity for guidance and direction from the line management to which you report by prompt notification to them of the existence of abnomal conditions.
In making these reports both to the State, local, NRC and Company officials the following principles must be observed:
l Promptly report all facts and other information concerning plant conditions and the potent 41 threat to the public.
l Be thoroughly and totally candid in your reports and do not withhold any information.
i Answer any questions asked to the best of your ability, whether or not they appear to you to be pertinent to the situation at hand.
Make every reasonable effort to convey infomation so that the recipients have an understanding of the significance of the report including the degree of uncertainty that may exist as to plant conditions and the prospect for further degradation in the situation.
In any abnormal event or unusual occurrence, whether or not it falls into one of the emergency event classifications, it is also of the utmost importance that the Communications Division's Duty Representative be informed as soon as possible.
It is essential that the Communications Division receive early notification so they may be prepared to respond to public and press inquiries.
Constant, vigilant recognition of your management role to maintain a command overview of the situation, to make decisions and to direct operations is the -
most important element in executing your responsibility to protect under all conditions, the health and safety of the public, the personnel on your shift, and the safe operation of plant systems and components under normal, off normal, and accident conditions.
This letter replaces and supersedes our letter to you, same subject, dated May 25,1983.
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H. D. HuKill P. R. Clark Vice President & Director, TMI-I President PRC/HDH/NR/dds cc:
M. J. Ross, Manager, Plant Operations TMI-I R. J. Toole, Operations and Maintenance Director TMI-I i
CARIRS - TMI n
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GPU Nuclear 100 Interoace Parkway Parsippany. New Jersey 07054 201 263-6500 TELEX 13&482 Wnter's Direct Dial Number:
December 8, 1983 (201) 263-6797 TO:
GPU SYSTEM EMPLOYEES ASSIGNED TG NUCLEAR ACTIVITIES and the Office of the President of GPU Nuclear Corporation.Last wee I know all of you share with me deep appreciation for since the accident at TMI-2. Bob Arnold's unstinting efforts and leadership during That period has seen the establishment and staffing of GPU Nuclear Corporation and placed us in a sound position to push forward to reach the major goals we have set.
steps taken during the last four years, are intended to strengthe ability to perform in a professional manner and to provide to the Nuclear Regulatory Commission a sound basis for auth<rizing the Restart of TMI-l without awaiting resolution of the "open issues" identified by the Commission Staff.
' responsibility of the NRC. Action on authorizing Restart of Unit 1 is the However, as I begin my assignment as president of GPU Nuclear Co I want to reemphasize the importance of meeting our responsibilities meeting all of our responsibilities.GPU Nuclear Corporation must continue to be fully of our activities so as to protect the health and safety of the public andPrima of our employees.
GPU's nuclear plants, GPU Nuclear Corporation and the Metropo sobering responsibility.and Jersey Central employees assigned to our nuclear i
or herself to meeting that responsibility.Each of us must fully accept and devote him that we have chosen to engage in nuclear power generation with its inherentIt c potential for serious consequences to public health and safety.
to assure that risk is kept acceptably low.
Our job is i
I GPU Nuclear is a part of the General Public Utilities System
s The owners and our Board of Directors have made clear the overriding importance they place on fulfilling that responsibility.
Our Mission states:
" Manage and direct the nuclear activities of the GPU System to provide the required high level of protec-tion 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 applicable laws, regu-lations, licenses and other requiremencs and the directions and interests of the owners."
Many things are involved in carrying out this Mission.
However, I want to draw your attention today to three which are vital.
They have all been the subject of prior guidance but they deserve reemphasis.
l 1
The first is that we must set our own standards--demanding
'1 ones in keeping with the responsibility we bear.
They must encompass and exceed the regulatory requirements. We must actively seek excellence.
The second is the need to have full and open communications--
both within the com problems, concerns,pany and between us and our regulators.
In particular, and uncertainties need to be identified and addressed
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openly.
I stand ready to discuss with any of you any safety concern you i
believe is not being adequatelp addressed.
)
The third is rigorous and faithful adherence to all of our
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requirements and standards as a minimum.
Our success depends on everyone faithfully fulfilling their responsibilities.
In accepting election to the position of president, GPU Nuclear Corporation, I have committed myself to the Board of Directors to do so.
I ask each of you to do likewise.
The members of the GPU and GPU Nuclear Boards of Directors have promised their full support.
joins me in pledging to you our very best efforts.Mr. Kintner, Executive Vice president, Very truly yours, i ?' st.
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P. R. Clark President l
MNuclear memorandum CLARITY AND EXPLICITNESS OF Subitch PLANS AND COMMITMENTS Date:
Septsber 1, 1983 Frorn:
P. R. Clark, Executive Vice President Location: Headquarters To:
P. B. Fiedler, Director, Oyster Creek I. R. Finfrock, Chairman, GORBs W. L. Gifford, Director, Comunications R. W. Heward, Director, Radiological & Environmental Controls H. D. Hukill, Director, TMI-l B. K. Kanga, Director, TMI-2 E. E. Kintner, Director, Administration R. L. Iong, Director, Nuclear Assurance F. F. Manganaro, Director, Maintenance & Construction D. G. Murray, Director, Human Resources R. F. Wilson', Director, Technical Functions Recently I have been involved in two situations where we had made commitments where what was understood and intended by those writing them was substantially different (and less meaningful) than most, if not all, readers (including me) would have understood.
'Ihis is of considerable concern to me and should be to you. We must be able to tell from what our people write what really is planned or meant. In many cases, other parties, such as the NRC, must also be able to understand what we mean. Please discuss this matter with your staffs along with the needed action.
The examples are as follows:
1.
As part of our response to a fine at Oyster Creek, we decided to erect an additional seccion of security fence at the intake. Our letter said the fence would be installed by the end of July.
I, much of our management, and the NRC all believed this meant an operable security barrier. What those directly involved say they meant was a fence (only) and that the rest of the security barrier, such as realming cameras, was to be done later. However, our letter was silent on that.
2.
We described our fire brigade training program for all fire brigade members as a two-year program with training given quarterly. The straightforward reading is, I believe, that all fire brigade members will be given training quarterly. What was done (but was not explicitly stated) was to offer training quarterly but only require that each person take one of two sessions on a given topic.
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Subject:
REPORTABILITY OF INFORMATION RELATIVE TO Date:
May 15,1984 ISSUES UNDER REVIEW BY LICENSING BOARDS OR NRC STAFF From:
P. R. Clark, President Location:
HQ To:
R. P. Fasulo, Director, Administration P. B. Fiedler, Director, Oyster Creek I. R. Finfrock, Chairman, GORBs W. L. Gifford, Director, Comunications R. W. Heward, Director, Radiological & Environmental Controls H. D. Hukill, Director, THI-l B. K. Kanga, Director, TMI-2 R. L. Long, Director, Nuclear Assurance F. F. Manganaro, Director, Maintenance & Construction D. G. Murray, Director,. Human Resources R. F. Wilson, Director, Technical Functions
References:
My memorandum dated July 22, 1983, Obligation to Report to the NRC BETA and RHR Reports My memorandum dated October 19, 1983, Obligation to Report to the NRC/ Additional Guidance The references provide guidance relative to reportability of information on issues pending before Licensing Boards or the NRC Staff on THI-1. While the specific issues discussed therein relate to THI-1, the general requirements, of course, apply to all of our licensed activities--TMI-1, THI-2, Oyster Creek, and Saxton.
Accordingly, l.
Please assure that all of your managers and professional staff are familiar with the NRC position on this subject.
2.
Assure that they understand that the preparer of any document and his manager are responsible to make the initial determination of reportability.
3.
Confirm to them that the Licensing Manager for the plant involved is to be provided copies of any documents they consider reportable.
AOOOO648 S.83
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e In addition,~ it is requested that the Director, Technical Functicns develop Corporate policy and procedure guidance for this catter in accordance with Corporate Policy 1218.01.
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,m TMI-l RESTART PROCEEDINGS:
October 19, 1983 OBLIGATION TO REPORT TO THE NRC Page 2 ADDITIONAL GUIDANCE C.
Plant Hodification/ Design Issues Modifications to the plant design described in the TMI-1 Restart Report and/or the ASLB Partial Initial Decision on Plant Design and Procedures and Separation Issues.
Relevance and Materiality relative to the Restart Hearing should then be judged against those issues and the Hearing Record on them.
For any other item where we have a pending issue before the NRC (such as a 5 license amendment) the relevancy and materiality are to be measured against
~'~
the particular licensing conditions involved and the basis for them.
~
While each document must be reviewed by the cognizant people, preliminary review of a variety of documents indicates:
I.
Documents with the greatest likelihood of being reportable and the position responsible to assure initial review and determination of reportability are:
1.
QA Audits, QDRs - Responsibility - Director, QA 2.
Reports of any audit or review by outside organizations (except internal financial audits) - Responsibility - Division Director 3.
Radiological Assessor Reports - Responsibility - Manager, Rad Con, TMI-l 4
Documented Differing Professional Opinions - Responsibility -
Department Director 5.
TDRs - Responsibility - Director, Technical Functions 6
GORB Developed Document - Responsibility - Chairman, GORBs 7.
B&W Letters or other outside correspondence - Responsibility -
Director, Engineering Projects and Director, Engineering & Design For documents in Category I developed hereafter, there should be a means provided to show on the document that reportability has been evaluated.
A stamp with space to initial as "Not Reportable", " Reportable", or
" Referred to Licensing" would be one such means.
II.
Documents less likely to be reportable include:
1.
Normal working papers - Procedures, Analys'.s, Specifications, Drawings, etc.
2.
Limited scope items - MNCRs, receiving reports, etc.
3.
Preliminary Safety Concerns 4
Draft documents where a final is reasonably expected in a short time.
The preparer and his line management are responsible to make the initial determination of reportability.
l
t TMI-1 RESTART PROCEEDINGS
- Octcher 19, 1983 08LICATION TO REPORT TO THE NRC Page 3 ADDITIONAL GUIDANCE Where the review described above shows some indication of reportability, the document should be forwarded to the Licensing and Regulatory Affairs Department for final determination. Documents in Types 11-14 should be sent
. to TMI-l Licensing (C. W. Smyth) and all others sent to PWR Licensing in Parsippeny (J. S. Wetmore). The area of concern should be clearly identified.
l P. R. Clark Executive Vice President pfk V
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DISTRIBUTION R. C. Arnold, President E. Blake, Esquire, Shaw Pittman, Potts & Trowbridge j
Richard J. Conte, Senior NRC Resident, TMI-1
- 1. R.. Finfrock, Chairman, GORBs W. L. Gifford, Director, Communications R. W. Heward, Director, Radiological & Environmental Controls H. D. Hukill, Director, TMI-1 E. E. Kintner, Director, Administration R. L. Long, Director, Nuclear Assurance F. F. Manganaro, Director, Maintenance & Construction J. R. Thorpe, Director, Licensing & Regulatory Affairs C. W. Smyth, TMI-l Licensing Manager J. S. Wetmore, Manager, PWR Licensing R. F. Wilson, Director, Technical Functions
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Intor-Offico Memorandum Data July 22, 1983 TMI-l RESTART PROCEEDINGS:
h Subject OBLIGATION TO REPORT TO THE NRC BETA AND RHR REPORTS To location Headquarters /Parsippany Directors: Communications Radiological & Environmental Controls TMI-l Administration Nuclear Assurance Maintenance & Construction Technical Functions Chairman, GORBs The enclosed memorandum from Guy H. Cunningham, III, Executive Legal Director to Harold Denton discusses the obligations we have to report information to the NRC.
It provides Mr. Cunningham's legal opinion as to the general basis for the obligations and the conclusion that we were obliged to provide both the BETA and RHR Reports.
The memorandum seems to define an obligation substantially broader (i.e., encompassing many more documents) than we had understood heretofore.
Further, the obligation relates not only to issues before the ASLB/
ASLAB but to other issues before the NRC Staff. A primary considera-tion in the determination seems to be whether it changes information previously provided.
We have been and will continue to seek clarification of the criteria.
In particular, we understand that the Commission in a decision some years ago on a VEPCO matter directed the Staff to develop guidance.
We are requesting that guidance.
However, in the interim, the following steps are to be taken:
1.
The attached opinion is to be provided to and discussed with your managers and professional staff.
2.
TMI-l Licensing is assigned responsibility to review documents they are aware of and any others brought to their attention and make a
~
determination regarding the obligation to provide.
3.
All copies of TMI-l related documents of the following classes are to be provided to TMI-l Licensing for review:
o QA Audits Reports of any audit or review by outside organizations o
o Radiological Assessor Reports o TDRs o CORB Minutes
l TMI-l RESTART PROCEEDINGS:
P ga 2
. GBLIGATION TO REPORT TO TIIE NRC TETA AND RHR REPORTS July 22, 1983 4.
Any other document you or your staff considers potentially reportable under the opinion is to be provided to TMI-l Licensing for review and determination. Your staffs should be particularly sensitive to the need to screen technical correspondence (such as, B&W letters, etc.)
for reportability to the Appeal Board or the NRC Staff.
I recognize that this will involve effort and likely result in the formal subnittal of more information than in the past-and likely in more than is useful to the NRC.
However, in the absence of better guidance, this process should help us and the NRC to reach agreement on criteria.
lOdct&(g)
P. R. Clark Executive Vice President Pk
Enclosures:
Guy H. Cunningham, III, Executive IAngal Director Memorandum Dated June 14, 1983 William J. Dircks, Executive Director for Operations Memorandum Dated June 22, 1983 cc: Mr. R. C. Arnold, President Mr. Richard J. Conte, Senior NRC Resident, TMI-l United States Nuclear Regulatory Commission PO Box 311 Middletown, PA 17057 S
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TMI-l RESTART PROCEEDINGS:
Prga 2 e
CELIGATION TO REPORT TO THE NRC BETA AND RHR REPORTS July 22, 1983 4.
Any other document you or your staff considers potentially reportable under the opinion is to be provided to TMI-l Licensing for review and determination.
Your staffs should be particularly sensitive to the need to screen technical correspondence (such as, B&W letters, etc.)
for reportability to the Appeal Board or the NRC Staff.
I recognize that this will involve effort and likely result in the formal subnittal of more information than in the past-and likely in more than is useful to the NRC.
However, in the absence of better guidance, this process should help us and the NRC to reach agreement on criteria.
l Od c -Lb C
P. R. Clark Executive Vice President Pk
Enclosures:
Guy H. Cunningham, III, Executive Iagal Director Memorandum Dated June 14, 1983 William J. Dircks, Executive Director for Operations Memorandum Dated June 22, 1983 cc: Mr. R. C. Arnold, President Mr. Richard J. Conte, Senior NRC Resident, TMI-l United States Nuclear Regulatory Commission.
PO Box 311 Middletown, PA 17057 9
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