ML20135A076
| ML20135A076 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/06/1985 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Edles G, Johnson W, Kohl C Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-452 SP, NUDOCS 8509090349 | |
| Download: ML20135A076 (17) | |
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September 6, 1985 (202) 822-1215 Gary J. Edles, Esquire Dr. W. Reed Johnson Christine N. Kohl, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)
Docket No. 50-289 SP (Restart Remand on Management - Training)
Dear Chairman Edles and Administrative Judges Johnson and Kohl:
Enclosed is a letter (with enclosures) dated September 3, 1985 from Mr. Philip R. Clark, President, GPU Nuclear, to Com-mission Chairman Nunzio J.
Palladino.
The letter responds to a congressional inquiry of the NRC concerning contractor materi-als used during a 1983 training course conducted once at Oyster Creek.
As Mr. Clark's letter reflects, the course was not taught at TMI, nor did personnel assigned to TMI attend.
The objectionable statements in the course material concerning com-munications with the NRC are contrary to well established GPU Nuclear policy.
Nevertteless, GPU Nuclear is taking a number of steps, as set forth '.n Mr. Clark's letter, to ensure there is no contrary message convened to its employees.
Sincerely,
%9$0 9
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g Deborah B.
Bauser Counsel for Licensee Enclosure cc:
Service List
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i
In the Matter of
)
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
)
(Restart Remand (Three Mile Island Nuclear
)
on Management)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission Gustave A. Linenberger, Jr.
Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Thomas M.
Roberts, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Gary J. Edles James K. Asselstine, Commissioner Chairman, Atomic Safety and U.S. Nuclear Regulatory Commission Licensing Appeal Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 Dr. W. Reed Johnson Atomic Safety and Licensing Lando W.
Zech, Jr., Commissioner Appeal Board U.S. Nuclear Regulatory Cor. mission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Ivan W. Smith Christine N. Kohl Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 i
i Administrative Judge Docketing and Service Section (3) i Sheldon J. Wolfe Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission l
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
SERVICE LIST PAGE 2 Atomic Safety and Licensing Mr. Henry D.
Hukill Board Panel Vice President U.S. Nuclear Regulatory Commission GPU Nuclear Corporation Washington, D.C.
20555 P. O. Box 480 Middletown, PA.
17057 Atomic Safety and Licensing Appeal Board Panel Mr. and Mrs. Norman Aamodt U.S. Nuclear Regulatory Commission 200 North Church Street Washington, D.C.
20555 Parkesburg, PA.
19365 Jack R. Goldberg, Esquire Mrs. Louise Bradford Office of Executive Legal Director TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington, D.C.
20555 Harrisburg, PA.
17102 Thomas Y. Au, Esquire Joanne Doroshow, Esquire Office of Chief Counsel
.The Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C.
20002 505 Executive House P. O. Box 2357 Lynne Bernabei, Esquire Harrisburg, PA.
17120 Government Accountability Project Michael F. McBride, Esquire 1555 Connecticut Avenue LeBoeuf, Lamb, Leiby & MacRae Washington, D.C.
20036 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan Michael W. Maupin, Esquire 2001 S Street, N.W.,
6430 Hunton & Williams Washington, D.C.
20009 707 East Main Street P. O. Box 1535 Richmond, VA.
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GPU Nuclear Corporation UCEMI 100 Interpace Parkway Parsippany. New Jersey 07054 1149 (201)263 6s00 TELEX 136-48 Wnter's Direct Dial Number, September 3,1985 (201) 263-6797 0980k Nunzio J. Palladino, Chairman United States Nuclear Regulatory Commission 1717 H Street, NW Washington, DC 20555
Dear Chainnan Palladino:
I am aware from press inquiries and reports that Congressman Markey has inquired of you regarding certain materials used during a training course presented at Oyster Creek in the Fall of 1983.
Our review of the matter has developed the following information:
o The course was developed and presented by a contractor rather than by GPU Nuclear, o
The title of the course was " Containment System Leakage Testing".
The material apparently referred to by Mr. Markey was incidental to the course purpose and not part of what GPU Nuclear expected to be covered.
The material was not reviewed by GPU Nuclear prior to presentation.
The entire section of the course material on this aspect is enclosed (Enclosure 1).
o The contractor advises that the material was revised in 1983 after presentation at Oyster Creek based, in part, on the critical coments from GPU Nuclear attendees, o
The course was given once at Oyster Creek.
It was never given at TMI.
Seventeen people attended.
This did not include anyone assigned to TMI.
However, one person in our Technical Functions Division who supports TMI as well as Oyster Creek did attend, o
The material is contrary to well established GPU Nuclear policy.
The GPU Nuclear policy on, " Employee Contact with Regulatory Agencies" concludes:
l GPU Nuclear Corporation rs a subsidiary of General Pubhc Utikties Corporation i
"Again, the interests of the Company, its employees, and the public are best served by an open and cooperative attitude and honesty in our interactions with the governmental agencies responsible for regulating our various activities.
We expect your active support in fulfilling these aspects of our public and corporate responsibilities."
o During General Employee
- Training, GPU Nuclear employees and contractors working at our plants are given instruction that company policy is to be fully open and candid with the NRC and other regulators.
This instruction is repeated each year.
o In addition, this policy is covered in other widely disseminated documents including:
i o
Corporate Objectives which state, " Continue to provide full and accurate information in a timely manner on GPUN activities and operations to the various publics of GPU; i.e.,
NRC, public officials, the
- media, the general
- public, employees, shareholders, and governmental agencies, so as to continue to deserve their trust".
o Letters to employees from corporate management, such as.
We are also taking the following action:
o Contacting each of the course attendees presently employed by GPU Nuclear to reinforce their understanding of our policy on this
- matter, i
o Reviewing other course material provided by the contractor to determine whether any similar problems exist.
We will take any needed action.
4 o
Asking the contractor to provide formally his assessment of thi s situation and steps he has taken to prevent future similar situations, i
o Reviewing internal controls over contractor provided training and training material.
Much of this information was provided on August 31, 1985 to media representatives but', regretfully, was largely not reflected in published accounts the next day, l
1
n I will be glad to furnish additional information on this matter.
Sincerely,
/? /$$.
P. R. Clark President pfk Enclosures cc: Thomas M. Roberts, Commissioner James K. Asselstine, Commissioner Frederick M. Bernthal, Commissioner Lando W. Zech, Jr., Ccemissioner 4
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INTERACTIONS WITH THE NRC KEY PHASES 9
CONSTRUCTION PERMIT - PS AR COMMITMENTS e
OPERATING LICENSE - FSAR COMMITMENTS & iECH SPECS e
PREOPERATIONAL TEST - LOTS OF ATTENTION e
COMMERCI AL OPERATIONS - UPDATES AND PERIODIC TESTS e
OPERATING LICENSE RENEWAL 5 -UPDATES AND PLANT MODIFIC ATIONS SJBMITTALS AND UPDATES e
SARs (PSAR, FS AR)- CONT AINMENT AND SYSTEMS e
TECHNICAL SPECIFICATIONS - SJBMIT AT LEAST 6 MONTHS PRIOR TO USE (10CFR50.55c(g)(5)(ii))
e EXEMPTIONS TO 10CFR50 APPENDIX J e
RELIEF REOJESTS FOR ASME SECTION XI VALVE TESTING e
PREOP AND PERIODIC ILRT SJMMARY REPORTS (INCLUDES LLRT TESTING 9JMMARY $1NCE LAST ILRT) e SECONDARY CONTAINMENT TESTING REPORT (PER TECH SPECS) e LIAISON EVENT REPORTS (REPORT ABLE OCCURRENCES) e ASME SECTION XI REPAIR / REPLACEMENTS, AS APPLICABLE (NIS-2 FORM AVAILABLE PEP, W82A & LATER) 3-1
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INTERACTIONS WITH THE NRC INSPECTION AND ENFORCEMENT AUDITS e
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REPAIR AND REPLACEMENT ACTIONS e
INSTRUMENTATION /C AllBRATION PROGRAM ANTICIPATING NRC ACTION / RESPONSES e
LOCAL / REGIONAL (9JRVElLLANCE AND ENFORCEMENT)
PERSONAL INTERESTS AND KNOWLEDGE AFFECT AREAS SCRUTINIZED AND EMPHASIS INSPECTOR'S PREJJDICE WILL VARY ON INTERPRETATION /APPLIC ATION OF REOJIREMENTS NRC POSITION C AN BE "GJESSED" BASED ON EXPERIENCE e
EXPERIENCE AT OTHER PLANTS e
PREVIOJS INSPECTIONS REGIONAL PREFERENCES MUST BE CONSIDERED e
CENTR AL OFFICE - PREPARES / REVISES REOJLATIONS, REG. GUIDES; ISSUES ib 3-2
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INTERACTIONS WITH THE NRC DAY TO DAY COMMUNICATIONS (INDJSTRY EXPERIENCES) 9 SHOJLD THE UTILITY INFORM THE NRC OF CONTEMPLATED PROGRAM CHANGES? THIS 15 DEBATABLE.
ALERTING NRC OPENS UP UTILITY FOR COMMENTS AND SECOND THOU GHTS.
SPRINGING CHANGES ON NRC HAS BENEFIT OF SURPRISE.
NOTE: IT SEEMS BETTER TO KEEP NRC INFORMED ON KEY ISSUES AND TO COMMUNICATE WITH THE INSPECTOR. T_OG AND DOCUMENT COMMUNICATIONS.
BENEFITS: UTILITY CAN LEARN OF NRC POSITION APRIORI. IF NO REi/lEW IS PERFORMED, UTILITY CAN DEFEND ACTIONS BY SAYING "THE NRC HAD SUFFICIENT TIME TO COMMENT (BJT DID NOT)... THIS WAS ASSUMED TO CONSITUTE TACIT APPROVAL."
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t NOTE: PERFORM DEMO ON AN " EASY" VALVE WHICH HAS TRADITIONALLY NOT BEEN A " PROBLEM LEAKER" 9
NRC-WILL WANT TO CONCENTRATE ON RAST PROBLEM AREAS AND PET PEEVES PLANT STAFF SHOJLD REVIEW ALL NRC COMMENTS / PROBLEMS WITH PAST ILRTs AND ENSURE PROPER RESOLUTION EXAMPLE: VALVE LINEUP (BEFORE AND AFTER TESTING; CHECK PLANT HISTORY) l 3-4
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WHEN THE TEST BEGAN (THJS ALLOWING FOR REPAlRS AFTER PRES 9JRIZATION COMMENCED)
THE " TYPE A" TEST FAILED (S!NCE SOME SMOOTH TALKERS HAVE MANAGED TO GET OJT OF FAILURES)
WE'LL DO IT OVER (SINCE IT HAS BEEN POSSIBLE TO OBTAIN NRC AGREEMENT WITH SJCH STATEMENTS AS,"YOJ SAW THE TEST BEFORE AND DIDN'T COMMENT; WHY THIS TIME WHEN WE'VE DONE IT EVEN BETTER?")
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DISCUSSION OF THE ABOVE EXPERIENCE SHOJLD IN NO WAY INDICATE ENDORSEMENT OF ANY OF THESE OBSERVED APPROACHES, l
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REVIEW PLANT DESIGN FOR INSPECTABILITY/ TESTABILITY e
DETERMINE AREAS OF NONCOMPLIANCE WITH REGULATIONS, CODES, STANDARDS, ETC.
O PREPAPE EXEMPTION REOJESTS FOR APPENDIX J PROGRAM (TYPE A, B & c TESTS) e PREPARE RELIEF REQJESTS FOR ASME SECTION XI, C ATEGORY A VALVE TESTING e
DISCUSS MAJOR PROGRAM CONCEPTS / CHANGES WITH NRC EARLY IN DEVELOPMENT e
PERFORM DEVELOPMENTAL AND IMPLEMENTATION TASKS AS EARLY AS POSSIBLE e
REDJCE EXCEPTION 5 TO TESTING - COMPLETE PLANT MODIFIC ATIONS 3-6
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ANSI 56.8 - 1981 VS. ANSI N45.4 -1972 ANSI 56.8 IS NOT REOJIRED BY NRC FOR PLANTS BJ1LT TO ANSI N45.4 DEPENDING ON YOJR REGION, NRC STAFF MAY REQJIRE COMPLIANCE WITH PORTIONS OF ANSI 56.8 NOTE: NRC PLANS TO ACCEPT ANSI 56.8 BY REG. GUIDE 9
BECHTEL TOPICAL REPORT BN-TOP-l' NRC DOES NOT LIKE SHORT DJRATION TESTING BJT...
NRC HAS (AND IS EXPECTED TO) ACCEPT THE SHORTENED ILRT ON A CASE BASIS 8
ILRT - ILRT SEOJENCE CONSIDERATION NRC RECOGNIZES THAT ILRT FAILURE "HAS TEETH" j
PJBLIC WILL BE PROTECTED IF INTEGRATED LEAKAGE 15 "lN SPEC" CONSIDERING ILRT BEFOP,E LLRT TO DETERMINE "AS FOJND" CONTAINMENT LEAKAGE CONDITION j
REVISION TO 10CFR50 APPENDIX J CONTINJES i
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sc any, ew Je sey 07054 201 263 6500 TELEX 136-482 Writer s Direct Dial Numter December 8, 1983 (201) 263-6797 TO: GPU SYSTEM EMPLO F ASSIGNED TO NUCLEAR ACTIVITIES Last week Mr. Kuhns announced changes in the Board of Directors and the Office of the President of GFU Nuclear Corporation.
I know all of you share with me deep appreciation for Bob Arnold's unstinting efforts and leadership during the nearly five years since the accident at TMI-2.
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.
The changes Mr. Kuhns announced, when added to other major steps taken during the last four years, are intended to strengthen our ability to perform in a professional manner and to provide to the Nuclear Regulatory Commission a sound basis for authori:ing the Restart of TMI-1 without awaiting resolution of the "open issues" identified by the
. Commission Staff.
Action on authorizing Restart of Unit 1 is the responsibility of the NRC.
However, as I begin my assignment as president of GPU Nuclear Co I want to reemphasi:e the importance of meeting our responsibilities.
GPU Nuclear Corporation must continue to be fully committid to meeting all of our responsibilities.
of our activities so as to protect the health and safety of the public andPrimar of our e=ployees.
Under our license, and our agreement with the owners of GPU's nuclear plants, GPU Nuclear Corporation and the Metropolitan Edison and Jersey Central employees assigned to our nuclear sites have that very j
sobering responsibility.
or herself to meeting that responsibility.Each of us must fully accept and devote hims It comes directly from the fact that we have chosen to engage in nuclear power generation with its inherent potential for serious consequences to public health and safety.
to assure that risk is kept acceptably low.
Our job is l
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The owners and our Board of Directors have made clear the overriding importance they place on fulfilling that responsibility.
Cur 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 requirements and the directions and interests of the owners."
Kany 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.
The first is that we cust ones in keeping with the responsibility we bear. set our own standards--demanding They must encompass and exceed the regulatory requirements.
We must actively seek excellence.
The second is the need to have fuJ,1 and open communications-- 'l both within the company and between us and our regulators.
In particular, problems, concerns, and uncertainties need to be identified and addressed openly.
I stand ready to discuss with any of you any safety concern you believe is not being adequately addressed.
j The th$rd is rigorous and faithful adherence to all of our
. 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.
Mr. Kintner, Executive Vice President, i
joins me in pledging to you our very best efforts.
l Very truly yours, f
l
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-d P. R. Clark President I
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_ _ _ _ _