ML20107A510
See also: IR 05000219/1973003
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631 Park Avenue
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King of Prussia', Pennsylvsnia 19!.-
SEP 7 1973
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TO:
James P. O'Railly, Director
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Directorate of Regulatory Operations, Region I
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THRU
J. P. Stohr, Senior, Environmental Protection and Special
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Fregrams Section, Directorate of Regulatory Operations, Engion I
ENPORCDENT AND LICINSING ACTIONS RESULTING PROM INSPECTOR'S
EVALUATION AND RO REPORT 50-219/73-03
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In response to Mr. Ihornburg's memo dated Auguet 13, 1973 on the
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above referenced subject, it appears that the areas of concern dis-
cussed in my evaluation memorandten have been adequately responded to.
Durin;; trf review of the subject memo for resolution of technical
issues, my attention was directed also to co'seents on report writing,
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areas inspections should concentrate on and our discussion during the
telephone conversation irunediately after learning that the Inspector's
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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 the issue:
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1.
With respect 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
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this memo there was little cooperation by management in the area
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of environmental matters. Recently, I have heard from various
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sources that Jersey Central Power and Light personnel are now
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" falling over themselves" to be cooperative.
If true, this
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represents a big step from a statement by CPU representatives
that they would hold off 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 sgpose that out of context it might appear that we,
the AEC, were guarding the licensee. In the context of the eval-
untion memo itself, however, especially the last line of that
sans 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
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the licensee of the matter.
I did this so that our report would
not be delayed due to the correspondence that would have ensued
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between the A3C and Jersey Central Power and Light.
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3.
1, of ocurse, disagree with the statement that the report and
evaluation memo are astremely wordy. If it were not for the -
detail in the report, the evaluation mano would not have been
based on sufficient information. The fact that two air respiere
were out for 10 months is aos thing. De fact that Jersey
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Central Power and Light did not even know about it is another.
In order to doctament all pertinaat information relating to
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enforcement action, I, included more detail, he problem with
the lieansee's program went deeper than simpts noncompliance,
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and I believe that the report,briass that out.
One aust
reuse er that in conducting an environmental inspection, one
entire faaet of an operating reactor is reviewed at one time
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by one individual, and it is covered in one report. With
respect to the second part of that paragraph,
( generally do
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not follow the basic concepts of our decismentation procedures,")
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it should be noted that we feel that report and evaluation memo
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followed the guidelines and requirements set forth in PI 1000.
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4.
I agree that the inq>1ementation of a program should be eval-
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usted. However, as professionals, we also will he making some
evaluation of program content during the course of the inspection.
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We choose not to overlook obvious deficiencies which cause the
program to not meet current standards. We do not " push" the
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licensee in regards to the recognised, content deficiency although
it is discussed.
Rather this information is passed on to DL for
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their review and subsequent incorporation into revised Technical
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Specifications as DL sees fit. Close contact is maintained be-
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tween DRO and DL so that duplication is minimized but DRO in-
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spectors are in a unique position in that they see a different
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aspect of the plant than does DL.
As a natter of fact, when
GAO accompanied this inspector recently, they were impressed
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by the fact that DRO had the expertise to evaluate the entire
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program and not only report facts with respect to implementation.
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5.
ne last paragraph indleates that J. P. Stohr felt that eval-
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untion menos should be tightened up.
H is is a misconception.
J. P. stohr and I disenesed tightening up the dissemination of
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these menos but did not mean to imply that. they be "sanitised."
6.
As far as the last statement is concerned, I would like to say
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that this statement was made in jest and not maamt to be taken
literally. I do not want to convey to anyone that I an 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 usens were of assistamos to their
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efforts. I have reviewed every report and memo written since
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soning with the Commission and have eenfirmed to myself that-I
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was justified in writing ehat I did concerning Oyster Creek.
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I am afraid that Oyster Creek and Forked River will be a p' rob-
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len for some time to case but both my feet are firmly on the
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ground and not in my mouth.
I believe that if a resetor is
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deficient in some aspect over which I have _sentrol, then I too
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an deficient. In every environmental and emergency planning
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inspection that I have sendmeted, I have assumed the respon-
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sibility of seeing that these areas are being handled properly
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and will continue to do so.
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Dr. Charles 0 Callina
Radiation Specialist
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