ML20117L639

Forwards Proposed Input for Section 13.1 of Draft SER Re Facility Restart Mgt Integrity

ML20117L639
Person / Time
Site:	Crane
Issue date:	07/03/1984
From:	Russell W Office of Nuclear Reactor Regulation
To:	Cunningham G, Harold Denton, Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20115A397	List: ML20115A395 ML20117L495 ML20117L592 ML20117L639 ML20117L721 ML20117L769
References
FOIA-84-633 NUDOCS 8505160331
Download: ML20117L639 (13)

Text

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M STATES REICLEAR NEGULATORY COMMISSION

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amannesroot e,c.semes July 3. 1984 H. R. DeatpaNRR Il0TE TO:

R. DeYoung. -IE. NAE T. Murl

. A1 G. Cunni ELD E. Case

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8. Snyder. IIII MR J. Axelred. IE'.'

G. Lainas K. Ium J. Stola GL. W.

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SUBJECT:

DRAFT SER S'UPPLEIST INI-1 RESTARNeulAGDeff IalTEGRITY I

he licensees msponse to Wit's recent 19 CFR 50.54(F) letter.has bes's I

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received and mvissed. Enclosed is a pmp-M input for Section 13.1 of the

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,p = R Willlem T. Russell Deputy Director.

4Hvisten of Numan Eacters Safety. M. <

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k INSEAT for Section 13.1. following third paragraph on page 13.g The ability of NRC to' regulate licensed activities depends on the completeness and accura.cy of a licensee's reports and the licensee'sCurrent willingness to discover potential public health and safety issues.-

GPUN policy and practice.' with retpect to completeness and accuracy'of reports is critical to the staff s overall to INtC, in light of past Met-Ed failuresSimIlarly, srun policies that protect evaluation of annagement integrity..

employees from harassaant am a unasum of the company's willingness to jC Documentation and discover potential public health end safety issues.

response to MRC's questions that establish GPUN's policies in these areas j

See P. R. Clark were provided under oath hy P. R. Clark, President of GPUN.

letter to D. Eisenhut,' Director. Division of Licensing, NRR, TaTed June 29,

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1984 with attached response to.E questions.

SPUN policy is to " assure absolute omnness of information availability and exchange within SPut so as to assure that all infomation which uright affect safety of huclear activ-ities is available to responsible company officials" and to

"[p}rovide informatica la a timely and trustworthy manner on the activities and operetions of TNI-1 aAd TMI-2 and L

Y Oyster Crvek to the we'rious publics of GPU; f.e.,.public O

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., 4, M efficials, the media,tel associos.gublic employees, sham cp holders and govemma f

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similar strong polfcy stataments in r,e.,d. at 1.

cent letters to all EPUN asoloyees opgaggd to nucipar activities.

For example.

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1983.~asphasized "the need s

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P. Clart's letter of teemeber $. ions. both~within the compaq, Ti@

At to have full and ce4mpnicat h.'

and between us' esir +eplators." and his letter of

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, in addition to identifying issues faternally, as wiil keep the NRC fully Q

informed of pre @, difficip1 ties and guestions."

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The staff finds these policies ers clear and reflect GruN's understandingN N

-E their responsibilities, to casuunii:ste accuretely'and completely with imC. '

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The staff also beltetes that a sincem effort to promulgate these policies:

has been ande by the Pvesidest of eftal, f

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The staff concluded in Section 10.'3.1 that GPUN failed in its respons'ibility

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to protect Parks, a contrect' r aspigyee, from intimidation for raising safety o

The staff abo conclu6ed in Section 1tl.3.4 that GPUN policies concerns.

totich protect GPUM and contractor; employees from barassmen

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i.+g aesitted that they did opt review or investigate'the relationship betusen Parks and his employer.'Gechte'1, or as f t celated to the ques'tioning df Parts #'*

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<, 'l-by Bechtel soployees er Parkt' supervisor. 'Id. at 6.

The Stier Aeport.

although it does review two of Partts complaf'nis, is incosplete. The staff n

eenc1 mees that GPUN abdicated its responsibility ynder 10 CFR 50.7 to r

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The staff fines, however, that investigate Parts allegation of harassment.

T the defsciencies exhibited in the: Parks matter wars isolated occurrences and b

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are not programentic la nature.

In this 5ER. the staff investipated three l

other allegations of discrimination against GPUN employees who had raised safety concerns.

In each of these three cases (Hartman. Gischel. King), the staff found the all tions to be.without merit, and that GPUN had acted properly in its deal

. arith these employees.

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In reviewing the attachment to GPUN's June 29. 1984 letter, it is clear that corporate management has in place m11cies designed to protect employees

. raising safety concerks ~thether tW are GPUN or contractor employees.

In particular, the 'Innsens learned" from the Stier Report (Attachment 4) b.

highlights its curreet etas of how employees raising safety concerns are te d.

be treated.

"Whem differences of opinions arise. such differences must he recognized and rwsolved on their merits in a cooperative manner.

They must not be characterized or treated as differences due to their organizational background or personality conflict." Additionally. GPUN has a strong written comitment to deal appropriately with amployees or contractors who discriminate against aspigyees for engaging in activities covered by 10 CFR 50.7.

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Seven of the ten functional areas evaluated were assessed as Category 1 (high level of performance); the remaining three functional areas were rated as

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' Category 2 (satisfactory perfomance).

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The results of the most recent SALP assessment, for the period October 1, 1982, through January 31, 1984, were sumarized by the staff as follows:

Overall, this assessment found that the licensee is continuing to devote considerable resources to improve performance in all areas of the organization. Manage-ment attention in identifying and correcting weaknesses is apparent from licensee initiatives noted in the var-fous areas reviewed. Management's commitment to safety is also apparent from their extensive commitment to personnel training, the continuing efforts to staff the organization with highly technical, competent personnel, and the implementation of a stringent policy regarding procedural adherence.

l The staff rated the licensee's performance in the following areas as Category 1:

radiological controls, maintenance, preoperational/ surveillance testing, fire protection and housekeeping, cmergency preparedness, security and safeguards, and quality assurance / control. The other areas evaluated l

were rated as Category 2: plant operatio n design, engineering and modi-

.fications; and licensing activities.

f NFinally, and most importantly, the staff finds that the individuals currently responsible for the leadership of GPUN were not implicated in past wrong-doing on the part of Met-Ed. This 'inding is discussed in detail for each current GPUN official involved or potentially implicated in any of these matters in Section 13.2.

Based on the totality of the circumstances, and balancing the past improper i

activities of the licensee against its subsequent record of remedial actions and performance, as well as the record of current senior management of the licensee, the staff concludes that there is reasonable assurance that GPUN can and will conduct its licensed activities in accordance with regulatory requirements and that GPUN can and will operate THI-1 without undue risk to the health and safety of the public.

13.2= Staff Position on Individual Integrity In addition to evaluating the activities discussed in Sections 4.0 through 11.0 to arrive at a position on corporate character or integrity, the staff has considered the implications of those activities in terms of the fitness of particular individuals to hold responsible positions related to j

NRC-licensed activities. The staff emphasizes that its assessment of the

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" managerial integrity" of the individuals addressed in this section does noti reflect a judgment about the personal morals or ethics of any individual.

The staff's assessment of individual " managerial integrity" is, instead, a subjective decision by the staff as to whether there is reasonable assurance l

that GPUN can and will meet its regulatory responsibilities with the partic-ular individual in a position related to those responsibilities.

NUREG-0680 13-9

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Individuals are obviously responsible for activities in which they have had direct involvement. An individual's position in the management structure, n'

however, may also result in responsibility for activities within his super-(

vision. Depending on the particular circumstances, an individual in a senior corporate management position may be deemed responsible in some part for a wide range of corporate activities in which the individual played no direct role.

13.2.1 Current GPU/GPUN/TMI-1 Management As discussed in Section 13.1, the staff has concluded that improper activities by Met-Ed in four areas raise serious integrity questions.

Individuals cur-rently with GPUN, who held management positions within Met-Ed or GPUSC, may be responsible for these improper acts. This responsibility may involve either an active role in connission of the event or a supervisory role with respect to the acts of subordinates. Current GPUN management who previously.

held management positions within Met-Ed or GPUSC and who may be held respon-sible for improper' acts of Met-Ed are the following:

W. G. Kuhns, Chairman of the Board and Chief Executive Officer, GPU H. M. Dieckamp, President GPU P. R. Clark, Sr., President GPUN R. L. Long, Vice-President Nuclear Assurance, GPUN H. D. Hukill, Vice-President TMI-1, GPUN M.-Ross, Operations Manager, THI-1, GPUN J. J. Colitz, Plant Engineering Director, THI-1, GPUN B. Mehler, Manager Radwaste Operations, THI, GPUN Table 13.1 indicates the involvement of these individuals in Met-Ed and GPUN events that could reasonably be considered to relate to their managerial i

integrity. While the staff does not find that the GPUN events (i.e., harass-l ment of Parks and failure to provide RHR, BETA, and Faegre & Bens 6W Reports in a timely manner) are significant factors in evaluating GPUN's management i

integrity, it has included these events for the purpose of assessing events that may be considered by others to be more significant.

W. G. Kuhns The staff finds that Kuhns had no personal involvement in any of the events

' which raised questions concerning Met-Ed or GPUN management integrity. As Chairman and Chief Executive Officer of the Board of Directors of GPU and a Director of GPUN, Mr. Kuhns must shoulder some portion of the responsi-bility for the improper activities of GPU's subsidiaries, Met-Ed, GPUSC, and GPUN. As discussed in Section 13.1 above, however, the staff has concluded that GPU/GPUN has by its performance (i.e., the creation of GPU Nuclear Corporation and its improved regulatory perfonnance as demonstr:ted by past l

two SALP reports) demonstrated a sincere and successful effort to correct for i

past mistakes. Kuhns' personal efforts and success at augmenting the board l

of directors with individuals of recognized nuclear experience and integrity i

is a further indication of his positive actions to assure that GPU and GPUN l

meet their public health and safety responsibilities.

For the reasons l

discussed, the staff revalidates its position with respect to Kuhns and concludes that there is reasonable assurance that GPUN can and will meet its NUREG-0680 13-10

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's' Table 13.1 Individual integrity of current GPU 'of GPUN officers and caployees

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Events False Timely..

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THI-2

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.& Management Accurate BETA /RHR Harassment Position teak rate Training Coverup NOV Response Reports of Parks Conclusion W. G. Kuhns No Personal Involvement CEO GPU II. M. Dieckamp Yes Personal Involvement Pres. GPU Not Improper P. R. Clark. Sr.

Yes Personal Involvement Pres. GPUN Not Improper R. L. Long Yes

. Personal Involvement V.P. Nuclear Not leproper a

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11. D. liuk il l. Jr.

Yes Personal Invol llot Imprs.per,vement w

V.P. lHI-I M. Ross

,Yes Yes Personal Involvement Mgr. Operations leot Improper IMI-I J.'Colitz Yes Personal Involvement Eng. Dir. IMI-I Not Improper

8. Mehler Ves*

Insufficient Evidence N nager. Realwaste Operations THI

• llertawn' ECP allegation included.

YES = Individual directly involved or implicated

- = Individual not involved C ]

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regulatory responsibilities with Kuhns in a management position related to "W

those responsibilities with no undue risk to public health and safety.

H.'M.' Dieckamp The staff foun'd, in'Section 8.3, that Dieckamp was' involved in review of the licensees response to the Notice of Violation.- Dieckamp stated that he thought the NOV response that isolation of the emergency feedwater system was not a violation of the Technical Specifications was " kind of thin," however, he chose not to intervene. ' Evidence was not developed that would indicate Dieckamp's involvement in reviewing the response to the NOV was improper nor was any evidence developed which would indicate Dieckamp had personal knowl-edge that the response was incomplete, inaccurate or contrary to conclusions reached by others within Met-Ed or GPUSC. The staff finds that Dieckamp's involvement in the licensee's response to the NOV was not' improper and that he had no involvement in any of the other events which raise questions con-carning management integrity. However, Dieckamp bears responsibility for the

' action of his subordinates and companies over which he had direct supervisory responsibility. As discussed in Section 13.1 above, the staff concluded that a pattern 'of improper acts.by Met-Ed in 1981 and before are so serious with

- respect to licensees' character, that the staff would likely have concluded 3

that reasonable assurance of no undue risk to public health and safety was not provided. -' It follows, therefore, that Dieckamp had not met his re-sponsibilities.in 1981 and before that time.

The staff's evaluation of Dieckamp's managerial integrity must be based on a consideration of all of the relevant circumstances. Additional relevant circumstances in this instance are:. The creation of GPUN to address past problems on the part of Met-Ed, the removal of-a top company officer who may have been involved in wrong doing, and most important, the current conduct

- and-perfomance of GPUN. Clearly, examination of past conduct of Met-Ed is relevant in assessing the prospective conduct of GPUN. However, since GPUN y

has been in existence since January 1982, GPUN's conduct is more relevant

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and, therefore, should be given more weight. The staff found in Section 13.1 that GPUN performance did not raise questions concerning corporate integrity

- and that regulatory performance had substantially improved over that of Met-Ed.

In balancing these relevant factors and considering that Dieckamp

- was not personally. involved in improper activities, the staff finds that the weight of evidence supports revalidation of its position--there is reasonable assurance that GPUN can and will meet its regulatory responsibility with no undue risk-to public health and safety with Dieckamp in a management position c

related to t.'rse responsibilities.

P. R. Clark, Sr.

P. R. Clark joined GPU Service Corporation as Vice-President Nuclear Activities on January 20, 1980. He became the Executive Vice-President, GPUN on January-1,1982, when that corporation was formed. Clark was essentially

- the Deputy to-Arnold for all nuclear activities. On November 25, 1983, Clark became President of GPUN.

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Keaten Ex. 18 at 5). Before the licensee's proposal of June 10,19BT to separate individuals associated with TMI-2 prior to the accident from any responsibilities with TMI-1, Clark's responsibilities were largely concerned with the Oyster Creek Nuclear Power Plant and Arnold concentrated on TMI-1 and -2.

The evidence developed during the various OI investigations into matters that raised questions concerning Met-Ed management integrity would support this division of responsibility within the President's Office of GPUN and the working relationship that existed between Arnold and Clark. Clark was employed by GPUSC at the time of the cheating incidents (discussed in Sections 7.2 and 13.1); however, the facts have established that Arnold and Hukill, to their credit, became personally involved in the licensee's in-vestigation and followup actions. No evidence was developed that would implicate Clark in any activities associated with the cheating events. Sim-ilarly, Clark was a vice-president in GPUSC, at the time various Keaten draft i

reports were forwarded for management review. No evidence was developed during the OI investigation of the Keaten matter that would indicate Clark was involved in any improper activities or had more than a peripheral role in review of the Keaten Report. The prosecuting attorney's Statement of Facts explicitly cleared Clark of any involvement in the TMI-2 leak rate issue. As i

discussed in Sections 5.7 and 6.3, the staff finds that the RHR and BETA and Faegre & Benson reportability issues are not significant factors in evalua-ting GPUN management integrity; rather, they indicate a failure to implement adequate procedures to ensure review of infomation for reportability. Thus, responsibility, if any, on the part of Clark would be limited to the corpora-tion's failure after November 25, 1983, to adopt procedures to ensure the timely review and determination of infomation reportability. The staff finds, therefore, that Clark was not involved in any improper activities (Section 13.1 above). The staff concludes that GPUN can and will meet its regulatory responsibilities with no undue risk to public health and safety with Clark in a management position related to those responsibilities.

R. L. Long R. L. Long was appointed Director of Training and Education and Acting Director of Nuclear Assurance on approximately February 1,1980. On April 1, j

1982, following the fomation of GPUN, he became Vice-President of Nuclear

-Assurance.

The occurrences of cheating on NRC and licensee examinations, discussed in Section 7.2, are relevant and material to Long's managerial integrity. As discussed in Section 8.2, Long was also a member of the Keaten task force and was directly involved in review and coment on drafts of the licensee's internal investigation into the TMI-2 accident (i.e., Keaten Report). The staff found, however, that there was no improper activity on the part of the members of the Keaten task force nor was there any improper involvement on their part in the preparation of the licensee's response to the NOV (Section 8.3).

The staff finds, therefore, that Long had no involvement in the incomplete and inaccurate statements made in response to the NRC Notice of Violation nor did he have any involvement in the other events that raise questions about management integrity, as discussed in Section 13.1.

NUREG-0680 13-13

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The staff finds that Long did not have a personal involvement in cheating on NRC or licensee-administered examinations nor did he have direct responsibil-q

~ ity for the poor attitude of operators toward their requalification program

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training requirements. The staff believes that this poor attitude on the part of operators was developed over a period of time and had its origins in the preaccident time frame. The licensee's actions to reorganize the Training Department and to learn from its past mistakes and to assess the practices of others (eg., Roddis task force) is indicative of a sincere effort to improve the quality of the training program. Long's responsi-bilities included implementation of these initiatives to improve the quality of the licensee training efforts. With the exception of the examination process itself, the ASLA8 has concluded that the licensee's training programs meet NRC's requirements. The ASLAB reopened the record on a narrowly defined issue concerning any impacts the cheating events may have on expert testimony presented during the ALAB hearing on the quality of the training program.

The Boards found and the staff continues to agree that the remedial actions taken by the licensee to upgrade the examination process are proper and are i

responsive to prevent instances of cheating in the future.

The following factors are significant in evaluating Long's managerial integrity: his responsibility for cheating which occurred on licensee and NRC examinations, his role in implementing remedial actions for the overall training program (which the staff finds was a good faith effort on the part of the licensee to remedy past training deficiencies), the remedial actions directed by Long to preclude instances of cheating on future examinations, and, most importantly, the quality of the current training program that has been implemented under Long's direction. On balance, the staff finds that the quality of the current training program, as discussed in Section 7.3, outweighs the instances of cheating that occurred early in Long's tenure as Director of Training and Education. The staff concludes that there is reasonable assurance that GPUN can and will meet its regulatory responsi-bilities with no undue risk to public health and safety with Long in a management position related to those responsibilities.

H. D. Hukill, Jr.

H. D. Hukill reported to the Three Mile Island Station in June of 1980 and became Vice-President of TMI-1 in September 1980. Hukill was involved in two events that raised questions concerning corporate management integrity (see Section 13.1). These events are the licensee's investigation and foTTowup action concerning cheating that occurred on licensee-and NRC-administered examinations and the licensee's failure to provide to NRC, in a timely manner, the RHR and BETA Reports. The staff finds that Hukill's l

involvement in these events was not improper. Hukill made a valuable con-tribution to the licensee's investigation by demonstrating to his staff that he was determined to correct the problem.

The failure on his part to see the investigation through to the very end and his admission to being naive concerning cheating do not imply improper conduct (see PID, July 27, 1982 at 12269-2270,2396). The record of investigation developed by OI supports a conclusion that Hukill felt the BETA and RHR Reports reflected positively on GPUN management initiative and that he volunteered these reports to the NRC on April 22,*1983.

The staff finds these actions reflect favorably on Hukill's attitude and approach to responsibilities. The staff finds that NUREG-0680 13-14

there is na evidence in th2 various OI investigations related to Met-Ed or GPUN management integrity that would raise any questions on the part of a

G reasonable person as to Hukill's managerial integrity. The staff concludes

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that there is reasonable assurance that GPUN can and will meet its regulatory responsibilities with no undue risk to-public health and safety with Hukill in a management position related to those responsibilities.

M. J. Ross M. J. Ross is the Manager of Plant Operations for THI-1 and has held that position since April of 1978. Before that time, he was a shift supervisor.

1-Ross was alleged to have been involved in improper activities associated with the review of NRC examinations and possibly involved in cheating. An

. extensive. record was developed during the reopened hearing on cheating con-i cerning the charges against Ross.. The Board found that the charges against Ross were unfounded. Similarly, the Appeal Board, after conducting its own i

extensive review and analysis of the record, concurred with the ASLB finding.

For the reasons discussed in Section 5.2, the staff concluded that no evi-dance exists to indicate that Ross was personally involved in leak rate testing. No testimony was given, during TMI-1 leak rate investigation or during the IE interviews as part of the TMI-2 leak rate investigation, to implicate Ross in actual wrongdoing or in pressuring operators to obtain acceptable leak rate test results. The contrast between the perfonnance of

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leak rate testing on TMI-1 and TMI-2 and Ross' direct responsibility for the activities at TMI-1, reflect positively on Ross' management ability. The staff finds, therefore, that Ross' activities associated with leak rate

-testing were not improper.

One could argue that as Manager of Operations for TMI-1, Ross must bear some of the responsibility for the poor attitude on the part of subordinate 11-censed operators toward their requalification training program requirements.

The occurrence of cheating on licensee and NRC examinations by licensed operators is, in the staff's opinion, reflective of a poor attitude on the part of operators.. However, the responsibility for development of the train-ing program and its implementation rests with others.

Further, given the existence of widespread problems with respect to operator training before the accident, continuing implementation deficiencies in the postaccident training program, and the failure of Met-Ed to implement adequate training policy and programs, the staff believes it would be improper and unfair to hold Ross accountable for acts of cheating on the part of his subordinates during the postaccident period.

l The staff concludes that there is reasonable assurance that GPUN can and will meet its regulatory responsibilities with no undue risk to public health and safety with Ross in a management position related to those responsibilities.

J. J. Colitz J. J. Colitz is presently Director Plant Engineering, TMI-1.

Colitz was the Superintendent of TMI-1 from early 1975 through March 1977 when he left to take a position with Met-Ed in Reading, Pennsylvania.

NUREG-0680 13-15 g

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'j Colitz. received his senior reactor operator's license on February 23, 1974; m

this license was renewed on February 23, 1976.

Thus, he was a licensed,

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off-shift senior reactor operator at the time of the Tsaggaris memorandum, discussed in Section 7.1.

During his OI interview on March 6, 1984, Colitz

- stated that he did not have time to attend lectures because of his workload as plant superintendent.

Instead, he did makeup lessons (see OI Report 1-84-004, Ex. 11 at 1). The staff finds that Col.itz may have failed to meet

.50f, lecture attendance for the FSR portion of his requalification program requirements (see Section 7.1). Colitz stated to OI that, after the Tsaggaris memorandum, he did not renew his operators license. However, his license had just been renewed 2 months before the Tsaggaris memorandum. The staff could find no record that his license was dropped after the Tsaggaris memorandum. "Under similar circumstances, however, G. Miller's (Station Superintendent, Unit 2) license was dropped in October 1976.

It appears likely that Colitz's license was allowed to drop at the same time as Miller's license. Based on the passage of time, the staff places no particular sig-nificance on Colitz's statement that he did not seek to renew his operator's license following the Tsaggaris memorandum.

The following matters are relevant to a staff position on Colitz's managerial integrity:

lack of hard evidence of personal failure to meet NRC require-i ments, no evidence of poor attitude on the part of TMI-1 shift operators-during his tenure as station manager, and circumstances of other, higher priority demands on his time. Considering these factors, the staff concludes that there is no basis for other than a positive finding with respect to Colitz's managerial integrity.

The staff concludes that there is reasonable assurance that GPUN can and will meet its regulatory responsibilities with no undue risk to public health and safety with Colitz in a management position related to those responsibilities.

i B. Mehler The staff found in Section 5.3 that there was insufficient evidence to con-clude that B. Mehler was involved in improper activities (i.e. violations

- of NRC requirements) during a reactor startup on April 23, Ti/8, as alleged by Hartman. Mehler was a dual-licensed SR0 and Shift Supervisor before the THI-2 accident and, thus, is involved in the TMI-2 leak rate matters. How-ever, the staff is not aware of the evidence developed by the Department of Justice during its THI-2 leak rate case that would implicate specific shift supervisors in improper acts. The staff finds, therefore, that there is insufficient evidence to implicate liehler in improper acts.

The staff did not develop a record to evaluate these isolated events in light of subsequent performance. However, it is the licensee's responsibility to evaluate on a continuing basis the performance of its employees. The recent promotion of Mehler to Manager of Radwaste Operations by GPUN and the current record of GPUN's own performance is evidence that such a record, if developed, would likely be positive.

i The staff concludes that there is reasonable assurance that GPUN can and will meet its regulatory responsibilities with no undue risk to the public health

. and safety with Mehler in a management position related to those responsi-

bilities, j

NUREG-0680 13-16

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s 13.2.2 Past Met-Ed/GPUSC/GPUN Management 6

Past Met-Ed or GPUSC managers who were either responsible for or involved in

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events that call to question the management integrity of Met-Ed are R. C. Arnold, Vice-President, GPUSC J. Herbein, Vice-President, Metropolitan Edison G. Miller, Station Manager, THI, Met-Ed E. Wallace, Manager of Licensing, TMI, GPUSC J. Floyd, Supervisor Operations, TMI-2, Met-Ed W. Zewe, Shift Supervisor, TMI, Met-Ed G. Kunder, Superintendent, Technical Support, THI-2, Met-Ed Table 13.2 indicates the involvement of these individuals in Met-Ed events.

The staff reaches no conclusion at this time on the managerial integrity of individuals who no longer hold management positions with GPUN.

It is the staff's position, and an essential part of the staff's ability to revalidate its position on licensee's management integrity, that GPUN must obtain staff review and approval on a case-by-case basis prior to the assignment of any of these individuals (i.e., R. C. Arnold, J. Herbein, G. Miller, W. Zewe, and J. Floyd) to responsible management positions associated with supervision of operations or maintenance of NRC licensed facilities. The staff will consider these individuals' past Met-Ed, GPUSC and/or GPUN performance, as well as any relevant current performance, in reaching a decision on any such request.

For two individuals (i.e., E. Wallace and G. Kunder) the staff finds that their current positions are not related to a THI-1 restart decision. Staff,

+

action, if any, will be handled as a part of its enforcement action review which is being conducted separately from the revalidation of TMI-1 management integrity.

13.3 Staff Position on Revalidation of Management Integrity Based on'the totality of the circumstances, and balancing the past improper activities of the licensee against its subsequent record of remedial actions and performance, as well as the record of current senior management of the licensee, the staff concludes that there is reasonable assurance that GPUN can and will conduct its licensed activities in accordance with regulatory requirements and that GPUN can and will operate T11I-1 without undue risk to the health and safety of the public. The staff, therefore, revalidates its position on licensee's management integrity.

4 NUREG-0680 13-17 e

-n.-.,

-o

. e.

J.

.y

-: g C$7 lable 13.2 Involvement of individuals in Met-Ed events' S

Events Timely False Provisions of Pre- & Post-Certification Complete &

BETA /itHR tsaac &

IMI-2 Accident

& Management Accurate Faegre & Benson Harassment Posittavi leakrate Training Coverup 160V Response Reports of Parts Conclusion it. C. Arnold Yes Yes Yes Yes None*

V.P. GPUSC/

Pres. GPUN J. lierbein Yes Yes Yes leone

• V.P. Het-Ed flone*

G. Hiller Yes Yes Yes Station Mgr.

lHI C

None*

Yes

+

e E. Wallace Mgr. IMI Iitensing None*

J. Floyd Yes Yes Yes Sugwrvisor Oga rations IHI-2 leone

• W. 7 ewe Yes Shift Sugn:rvisor THX NonE

• G. KunJer Yes Sugr. Tech Supg=>rt Illi-2

• The staff draws no conclusion as to the individual's managerial integrity because the individual is no longer esployed by the licensee or is no longer directly involved in operation or licensing of IMI-1.

Yes a lenlividual directly involved or laplicated w

- Individual siot involved N

4.

%s

.