ML20138C460

Provides Review of Certain Matls Used During Training Course Presented in Fall 1983

ML20138C460
Person / Time
Site:	Oyster Creek
Issue date:	09/03/1985
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20138C450	List: ML20138C445 ML20138C460
References
0980K, 980K, NUDOCS 8510220434
Download: ML20138C460 (14)

Text

_. . .-_.-- _ -. . - .

! E'! CLOS'JRE 2 i

, l GPU Nuclear Corporation

'..h j U Mf 100 intercace Parkway Patsccany New Jersey 07c54114 (201)263 6500

• TEl.EX 136 482 Writer s Direct Dral Numter.

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, September 3,1985 (201) 263-6797 f 0980k

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! l Nunzio J. Palladino, Chairman.  !

United States Nuclear Regulatory Commission I

1717 H Street, NW ,

k'ashington, DC 20555

Dear Chaiman Palladino:

l I am aware from press inquiries and reports that Congressman Markey has- 'l 4 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:

l o The course was developed and presented by a contractor rather than by '

I

GPU Nuclear. j i 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 6PU Nuclear expected to be  ;

l covered. The material was not reviewed by GPU Nuclear prier to  !

presentation. The entire section of the course material on this ,

aspect is enclosed (Enclosure 1). i

! t 3

o The contractor advises that the material was revised in 1983 af ter [

presentation at Oyster Creek based, in part, on the critical coments  ;

from GPU Nuclear attendees, i 1  :

, o The course was given once at Oyster Creek. It was never given at -  !

TMI. Seventeen people attended. This did not include anyone assigned l

. to TMI. However, one person in our Technical Functions Division who i l supports TM1 as,well as Oyster Creek did attena.

l o The material is contrary to well established GPU Nuclear policy. The

GPU Nuclear policy on, " Employee Contact with Regulatory Agencies" .;

concludes

l 1

i

}

m "f g E E8'PDR CORRESI r

j GPu uuciear Corocrationis a sutsiciary of GeneraiPuthe Utut.es Corcerat.on "

l

-, l

I i 2-

.i "Again, the interests of the Company, its employees, and i 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 1 contractors working at our plants are given instruction that company policy is to be fully open and candid with the NRC and otherf j regulators. This instruction is repeated each year, o in addition, this policy is covered in other widely disseminated

, documents including:

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 Enclosure 2.

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.

l o Reviewing other course material provided by the contractor to '

determine whether any similar problems exist. We will take any q needed action.

4

. o Asking the contractor to provide formally his assessment of this l situation and steps he has taken to prevent future similar situations.

o Reviewing internal controls over contractor provided training and training material, t

i Much of this information was provided on August 31, 1905 to media representatives but, regretfully, was largely not reflected in published accounts the next day.

, _ _ - . _ _ _ _ _ _ . . _ - _ , . _ - . . _ . _ _ _ _ . _ _ _ . _ _ _ , . _ , , _ . . _ , _ _ _ . _ . ~ _ _ _

9 3-I wili be glad to furnish additional infonnation on this matter.

Sincerely, f b. .

P. R. Clark President ,

pfk J

Enclosures .

cc: Thomas M. Roberts, Commissioner James X. Asselstine, Commissioner Frederick M. Bernthal, Commissioner Lando W. Zech, Jr., Commissioner

, 0 4

- Enclosure 1 I

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_ . _ . ,m INTERACTIONS WITH THE NRC KEY PHASES 9 CONSTRUCTION PERMIT - PSAR COMMITMENTS ,

e OPER ATING LICENSE FSAR COMMITMENTS & TECH SPECS i l

e PREOPERATIONAL TEST - LOTS OF ATTENTION

. I e COMMERCI AL OPERATIONS -UPDATES AND PERIODIC TESTS e OPERATING LICENSE RENEWALS -UPDATES AND PLANT MODIFICATIONS

SUBMITTALS AND UPDATES I

i e SARs (PS AR, FS AR)- CONT AINMENT AND SYSTEMS

e TECHNIC AL SPECIFICATIONS - 9JBMIT AT LEAST 6 MONTHS-PRIOR TO USE (10CFR50.55c(g)(5)(ii))

i e EXEMPTIONS TO 10CFR50 APPENDIX J e RELIEF REOJESTS FOR ASME SECTION XI VALVE TESTING 4

PREOP AND PERIODIC ILRT SJMMARY REPORTS (INCLUDES LLRT TESTING SJMMARY SINCE LAST ILRT) e SECONDARY CONTAINMENT TESTING REPORT (PER TECH SPECS) e LIAISON EVENT REPORTS (REPORT ABLE OCCURRENCES) t e ASME SECTION XI REPAIR / REPLACEMENTS, AS APPLICABLE (NIS-2 FORM AVAILABLE PER W82A & LATER) 4 u . _ - - - _ . . _ - - . . . .. - - .. . - .... .... a 3-I

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PERSONAL INTERESTS AND KNOWLEDGE AFFECT AREAS SCRUTINIZED I AND EMPHASIS I INSPECTOR'S PREJJDICE WILL VARY ON , ,

INTERPRETATION / APPLICATION OF REOJIREMENTS

, NRC POSITION C AN BE "OJESSED" BASED ON EXPERIENCE  !

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. EXPERIENCE AT OTHER PLANTS I l

! . PREVIOJS INSPECTIONS l l

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REGIONAL PREFERENCES MUST BE CONSIDERED f

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SPRINGING CHANCES ON NRC HAS BENEFIT O .

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COMMUNICATIONS.

BENEFITS:

[ UTILITY C AN LEARN OF NRC FOSITION A

REVIEW IS PERFORMED, UTILITY CAN DEFEND ACTIC ,

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WAS ASSUMED TO CONSITUTE TACIT APPROVAL " .

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INTERACTIONS WITH THE NRC DAY-TO-DAY COMMUNIC AT'ONS (CONTD)

O INFORMING THE LOCAL INSPECTOR IT'S IMPORTANT TO KEEP LOC AL INSPECTOR INFORMED OF CURRENT DEVELOPMENTS -

ENCOJRAGE INSPECTOR TO WITNESS A TYPE C TEST, BJT . . . DON'T BE FOOLISH:

NOTE: PERFORM DEMO ON AN " EASY" VALVE WHICH HAS TRADITIONALLY NOT BEEN A " PROBLEM LEAKER" 9 NRC-WILL WANT TO CONCENTRATE ON EAST PROBLEM AREAS AND PET PEEVES PLANT STAFF SHOJLD REVIEW ALL NRC COMMENTS / PROB' EMS WITH PAST ILRTs AND ENSJRE PROPER RESOLUTION EXAMPLE: VALVE LINEUP (BEFORE AND AFTER TESTISG; CHECK PLANT HISTORY) e 3-4

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i INTER ACTIONS WITH THE NRC DAY 10 - DAv COMMUNICATIONS (CONTD) 9 TRADITIONAL INDUSTRY APPROACH TO ILRT TESTING PROBLEMS HAS BEEN PREDICATED ON NOT STATING TO NRC: -

1 WHEN THE TEST BEGAN (THJS ALLOWING FOR REPA!RS AFTER PRES 9)RIZATION COMMENCED)

THE " TYPE A" TEST FAILED (SINCE 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?")

NOTE: DISCUSSION OF THE ABOVE EXPERIENCE SHOJLD IN fna WAY INDIC ATE ENDORSEMENT OF ANY OF THESE OBSERVED APPROACHES.

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INTERACTIONS WITH THE NRC KEY CONSIDERATIONS IN PEPARING PROGR AM e REVIEW PL ANT DESIGN FOR INSPECTABILITY/ TESTABILITY

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e DETERMINE AREAS OF NONCOMPLIANCE WITH REOJLATIONS, CODES, STANDARDS, ETC.

4 PREPARE EXEMPTION REOJESTS FOR APPENDIX J PROGRAM (TYPE A, B & F TESTS) e- PREPARE RELIEF REOJESTS FOR ASME SECTION XI, C ATEGORY A VALVE TESTING

( e DISCUSS MAJOR PROGRA A CONCEPTS / CHANGES WITH NRC.EARLY IN DEVELOPMENT 4

PERFORM DEVELOPMENTAL AND IMPLEMENTATION TASKS AS EARLY AS POSSIBLE e

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- DEPENDING ON YOJR REGION, NRC STAFF MA . _. .c COMPLI ANCE WITH PORTIONS OF ANSI 56.8 NOTE: NRC PLANS TO ACCEPT ANSI S6.8 BY REG. OJIDE  !

4 BECHTEL TOPICAL REPORT BN-TOP-l' l

NRC DOES NOT LIKE SHORT DJR ATiON TESTING BJT . . . ,

l NRC HAS (AND IS EXPECTED TO) ACCEPT THE SHORTENED ILRT ON A CASE EASIS 6 ILRT - ILRT SEOJENCE CONSIDER ATION [

i NRC RECOGNIZES THAT ILRT FAILURE "HAS TEETH" t

PJBLIC WILL BE PROTECTED IF INTEGRATED LEAK ACE IS "lN SPEC" CONSIDERiNG ILRT BEFORE LLRT TO DETERMINE "AS FOJND" CONTAINMENT LEAKAGE CONDITION REVISION TO 10CFRSO APPENDlX J CONTINJES I 3-7

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.nt i o s e s GPU Nuclear

' U s e a v. ew e s y 07C54 201 263-6500 TELEX 136462 wnter s Deect Dial Numter December 8, 1983 (201) 253-5797 TO: /

GPU SYSTEM EMPLC F ASSIGNED TO NUCLEAR ACTIVITIES and the Office of the President of GPU Nuclear Corporation.Last w I know all of you share with me deep appreciation for '

Bob sinceArnold's the accidentunstinting efforts and leadership during the nearly five years 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 ma3cr goals we have set.

steps taken The changes during the lastMr. Kuhns announced, when added to other ma yor 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 authorizing the Restart of TMI 1 -

without awaiting

.Cemniss:en Staff. resolution of the "open issues" identified by the Act:on responsibil ty of the NRC. We on authorizing Restart of Unit 1 :s the Mcwever, as :

wil) begin my assignment as president of GPU Nuclear Corporatio I want to reerphasize the importance of meeting egr responsibilitfes .

GPU Nuclear Corporation must meeting all of our responsibilities. continue to be fully committed to ofour of ouremployees.

activities so as to protect the health and safety of the pub 1:e andP Under our license, and our agreement wit.) the owners of GP*T s nuclear plants GPU Nuclear Corporation and the Metropolitan Edison and Jersey sobering Central employees assigned to our nuclear sites have that very responsibility.

or herself to meeting that Each of us must fully accept and devote himself responsibility.

that we have chosen to engage in nuclear power generation with :ts inhIt comes d erent potential for serious consequences to public health and safety. Our Job :s to assure that risk is kept acceptably low.

o The ownersthey overriding importance andplace our Board of Directors on fulfilling have made clear the that responsibility.

Mission states:

Our

" 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 CPU 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."

However. Many things are involved in carrying out this Mission.

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 ones in keeping with the responsibility we bear.is that we must set our own sta

exceed the regulatory requirements. They must encompass and We must actively seek excellence.

both The second is the need to have ,fuJ,1 and open communications-- ']

withinconcerns, the company and between us and our regulators.

! problems, In particular, !

t openly. and uncertainties need to be identified and addressed [

believe is.not being adequately addressed.I stand ready to' discuss) with any

/

The third 'is rigorous and f aithful adher'ence to all of our

, requirements and standards as a minimum.

responsibilities. Cur success depends on everyone faithfully fulfilling their In accepting election to the position of president. GPU '

Nuclear do so. ICorporation.

ask eacn of Iyou have to committed do likewise.myself to the Board of Directors to have promised their full support.The members of the GPU and GPU Nuclear Boa joins me in pledging to you our very best efforts.Mr. Kintner, Executive Vi,ce President, Very truly yours, R . -

P. R. Clark President 1

. ._ , , , - - , . .,. , , ,----