ML20107A240
See also: IR 05000219/1973003
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UNITED STATES'
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ATOMIC ENERGY COMMISSION
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631 Park Avenue
King of Prussia, Pennsylvania 19406
SEP 7 1973
TO:
James P. O'Reilly, Director
Directorate of Regulatory Operations, Region I
THRU:
J. P. Stohr, Senior, Environmental Protection and Special
Programs Section, Directorate of Regulatory Operations, Region
ENFORCEMENT AND LICENSING ACTIONS RESULTING FROM INSPECTOR'S
EVALUATION AND R0 REPORT 50-219/73-03
In response to Mr. Thornburg's memo dated August 13, 1973 on the
above referenced subject, it appears that the areas of concern dis-
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cussed in my evaluation memorandum have been adequately responded to.
During my review of the subject memo for resolution of technical
issues, my attention was directed also to comments on report writing,
areas inspections should concentrate on and oar discussion during the
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telephone conversation immediately af ter learning, that the Inspector's
Evaluation had been released to the press.
I disagree to varying
degrees with these comments and/or felt that they may be misleading.
Without belaboring L.e issue:
1.
With re-ect to the two items which are not inspection / enforce-
ment matters , I believe that these matters may have affected our
overall relationships with the licensee. Prior to the release of
this memo there was little cooperation by management in the area
of environmental matters.
Recently, I have heard from various
sources that Jersey Central P4wer and Light personnel are nou
"f alling over themselves" tc/'be cooperative. If true, this
represents a big step from a statement by GPU representatives
that they would hold of f as long as possible until DL directed
them as to what to do.
2.
As far as the second item is concerned relating to the proprietary
report, I suppose that out of context it might appear that we,
the AEC, were guarding the licensee.
In the context of the eval-
uation memo itself, however, especially the last line of that
same paragraph, I believe this to be unlikely. When this pro-
prietary report was first read, I discussed the matter with the
other inspector at the site; then I personally decided to inform
the licensee of the matter.
I did this so that our report would
not be delayed due to the correspondence that would have ensued
between the AEC and Jersey Central Power and Light.
9604120199 960213
DEKOK95-258
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3.
I, of course, disagree with the statement that the report and
evaluation memo are extremely wori . If it were not for the
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detail in the report, the evaluation memo would not have been
based on sufficient information.
The fact that two air samplers
were out for 10 months is one thing.
The fact that Jersey
Central Power and Light did not even know about it is another.
In order to document all pertinent information relating to
enforcement action, I included more detail.
The problem with
the licensee's program went deeper than simple noncompliance,
and I believe that the report brings that out.
One must
remember that in conducting an environmental inspection, one
entire facet of an operating reactor is reviewed at one time
by one individual, and it is covered in one report. With
respect to the second part of that paragraph, (" generally do
not follow the basic concepts of our documentation procedures,")
it should be noted that we feel that report and evaluation memo
followed the guidelines and requirements set forth in PI 1000.
4.
I agree that the implementation of a program should be eval-
uated. However, as professionals, we also will be making some
evaluation of program content during the course of the inspection.
We choose not to overlook obvious deficiencies which cause the
program to not meet current standards. We do not " push" the
licensee in regards to the recognized, content deficiency although'
it is discussed. Rather this information is passed on to DL for
their review and subsequent incorporation into revised Technical
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Specifications as DL sees f '
Close contact is maintained be-
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tween DRO and DL so that dup _4 cation is minimized but DRO in-
spectors are in a unique position in that they see a different
aspect of the plant than does DL.
As a matter of fact, when
CAO accompanied this inspector recently, they were impressed
by the. fact that DRO had the expertise to evaluate the entire
program and not only report f acts with respect to implementation.
5.
The last paragraph indicates that J. P. Stohr felt that eval-
uation memos should be tightened up.
This is a misconception.
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J. P. Stohr and I discussed tightening up the dissemination of
these memos but did not mean to imply that they be " sanitized."
6.
As far as the last statement is concerned, I would like to say
that this statement was made in jest and not meant to be taken
literally.
I do not want to convey to anyone that I am in the
least bit afraid to write a similar report and similar evaluation
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memo if the situation called for it.
In talking to DL, I was
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told that my reports and memos were of assistance to their
efforts.
I have reviewed every report and memo written since
coming with the Commission and have confirmed to myself that I
was justified in writing what I did concerning Oyster Creek.
I am afraid that Oyster Creek and Forked River will be a prob-
1em for some time to come but both my feet are firmly on the
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ground and not in my _ mouth.
I believe that if a reactor is
deficient in some aspect over which I have control, then I too
r deficient.
In every environmental and emergency planning
inspection that I have conducted, I have assumed the respon-
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sibility of seeing that these areas are being handled properly
and will continue to do so..
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Dr. Charles 0. Gallina
Radiation Specialist
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