ML20138B940
| ML20138B940 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/20/1986 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 4410-86-L-0054, 4410-86-L-54, NUDOCS 8603250227 | |
| Download: ML20138B940 (2) | |
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GPU Nuclear Corporation NUCIMr 100 lnterpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:
March 20, 1986 (201) 263-6797 4410-86-L-0054 Mr. James M Taylor, Director Office of Inspection and Enforcement United States Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Taylor:
SUBJECT:
THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 2 DOCKET NO. 50-320, EA NO.84-137 REQUEST FOR HEARING IN RESPONSE TO ORDER IMPOSING CIVIL MONETARY PENALTY Your Order of March 4, 1986 requires that GPU Nuclear Corporation pay a civil penalty for alleged violation of NRC requirements or request a hearing on whether the alleged violation occurred and whether the March 4 Order should be sustained.
The violation alleged was discrimination in 1983 against Richard D. Parks, a Bechtel employee assigned to TMI-2, for raising safety concerns. As I stated in my October 21, 1985 letter:
"GPU Nuclear denies the allegations in the Notice of Violation.
GPU Nuclear views such allegations with the utmost seriousness.
Harassment and intimidation have never been and are not now tolerated by GPU Nuclear.
Such conduct is inconsistent with the Corporate Mission and Corporate Objectives and Goals.
GPU Nuclear has lonjstanding formal mechanisms, such as its Ombudsman program, specifically designed to ensure that any employee of GPU Nuclear or of its subcontractors feels free to raise any safety concern without fear of reprisal.
This objective has been emphasized and reemphasized by GPU Nuclear management, both before and after Mr. Parks' allegations."
Our letter of October 21, 1985 stated that, "the vast bulk of the evidence" persuades us that the allegations of discrimination were untrue and that management actions concerning Mr. Parks were responsible and appropriate.
In supporting that view, we summarized and analyzed substantial evidence provided largely by our contractor, Bechtel, and 8603250227 860320 PDR ADOCK 05000320 0
Pon r2-ly GPU Nuclear Corporation is a subsid:ary of the General Pubhc Uhhties Corporahon
a.~
Mr. James M. Taylor Page 2 supported by an outside investigator, Edwin Stier. We have reviewed the evaluation and conclusion accompanying your March 4 Order and remain convinced that our prior assessment was valid. Therefore, since we are unable in good conscience to agree that the alleged violations occurred, we hereby request the hearing afforded by your March 4, 1986 Order.
In requesting the hearing, we are, of course, fully cognizant of the fact that a full-scale adjudicatory proceeding, following document and other discovery, is likely to impose personnel and economic burdens upon the Commission and GPU Nuclear out of proportion to the civil penalty involved. On the other hand, we cannot accept responsibility for a charge which in our view is unsubstantiated. We would welcome an opportunity to discuss the matter in any appropriate manner in an effort to narrow and resolve our differences if feasible either before or after this matter is assigned to a presiding officer for hearing.
Respectfully submitted, n
/
P. R. Clark President pfk 1207 cc: Guy H. Cunningham, Executive Legal Director, USNRC H. W. Wahl, Bechtel Power Company
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