ML20149M420

Forwards 830519 Note Case to Cummings W/Attachments,Per 840302 Telcon

ML20149M420
Person / Time
Issue date:	03/02/1984
From:	Rich Smith NRC OFFICE OF INSPECTOR & AUDITOR (OIA)
To:	Combs F NRC
Shared Package
ML20149M377	List: ML20149M375 ML20149M390 ML20149M420 ML20149M434 ML20149M444 ML20149M457
References
FOIA-87-728, FOIA-87-853 NUDOCS 8802260036
Download: ML20149M420 (1)

Text

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,? May 19,1983 NOTE TO J. J. CUMMINGS RE: HARTMAN ALLEGATIONS In response to my note to you and Dick DeYoung of April 18,1983 and my previous oral discussions with Tim Martin (Region 1), I have received or have been made aware by those indicated below of the following written material related to the Hartman allegations currently in the possession of NRC. I understand that none of this material has been made publicly available or furnished to the Board or Panel involved in the THI-1 restart proceeding.

(1) By Region I -- As listed in the Martin memorandum to Case of March 28, .1983 (attached hereto as Enclosure 1). In addition, I have been informed by Tim that a box of records and analyses related to these allegations exists and is physically located in the Region I office.

(2) By IE -- As listed in Sniezek note to Case of April 22, 1983 (attached hereto as Enclosure 2).

(3) By Vic Stello - "Results of Faegre & Benson Investigation of Allegations by Harold G. Hartman, Jr. , Concerning Three Mile Island Unit 2." September 17,1980 (four volumes) and "Deposition of Harold W. Hartman, Jr." incident to the GPU B&W 1awsuit (291 pages).

(4) By Jim Cummings -- Interview of Chuck Mell by Subcommittee on Nuclear Regulation of the Committee on Environment and Public Works, Wednesday, August 22, 1979, and letter from Chairman Palladino to Attorney General Smith dated April 11,

. 1983.

Although there may be more written material available on this matter, I in accordance with our previous discussions with Vic Stello and others l on this subject of early March, I suggest that you now determine l whether the Department of Justice has written objections to making any or all of the available written material listed above publicly available, or otherwise available to the Board and Panel involved in the THI-1 For your information, the Commission has been Restart. Proceeding.

informed that.ve are taking,this action by means.of the NRC Staff's Comments on the Analysis of GPU V. B&W Transcript of April 18, 1983.

(Enclosure 3 -- see footnote 6 on page 4)

O at , m@l O .

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J. J. Cummings -2 If you need copies of any of the listed written material currently in my possession, (see numbered paragraphs (1) (3) and (4) above),

please let me know. I am sure that others who received copies of this note will afford you the same courtesy.

'd Edson G. Case

Enclosures:

1. Memo to E. G. Case fm T. T. Martin dtd 3/28/83

2. Note to E. Case fm J. Sniezek dtd 4/22/83

3. NRC Staff's Comments on the Analysis of

. GPU V. B&W Transcript dtd 4/18/83 cc w/o encls.

H. R. Denton V. Stello R. DeYoung T. Martin

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' MEMORANDUM FOR: Edson G. Case, Deputy Director, Office of Nuclear- Reactor

', - Regulation FROM: Thomas T. Martin, Director, Division of Engineering and Technical Programs, RI

SUBJECT:

HARTMAN INVESTIGATION TRANSCRIPTS .

Per our discussion, enclosed are transcripts, testimony and interview records associated with subject investigation.

c.cs - Y i

Thomas T. Martin, Director

' Division of Engineering and Technical Programs Enclosures :

.As stated O

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9qdb y . a MA@M% - _ - -___-_ __ __ _ _ _ _ _ _ _ _ _ _ __

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INDEX OF * '. .iNTS PROVIDED TO JAMES CUP 'Nt... OIA .

7. .

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Graph chart of CR0 scr,een,ing . interviews

}- 1.

2. Transcript of original post accident Hartman interview on May 22, 1979 by Tony Fasano and Jim Creswell

3. Transcript of Hartman interview by HRC Special Inquiry Group 4 Transcript of Hartman interview by R. K. Christopher and Tim Martin on March 26, 1980.*

5. Sworn statement of Harold Hartman obtained by R. K. Christopher on March 26, "

1980.

6. Transcript of Inquiry Group interview of Hartman on October 29, 1979.

7. Transcript of interview of Jim Flojd by R. K. Christopher and Tim Martin on March 27,1980.

8. Transcript of interview of Kenneth Hoyt by R. K. Christopher and Tim Martin on March 27, 1980. .

9. Transcript of interview of Bernie Smith by R. K. Christopher and Tim Martin on March 27, 1980. .

10. Transcript of interview of Brian Mehler by R. K. Christopher and Tim Martin on March 27,1980.

11. Statement of Hugh McGovern dated April 10, 1980.

12. Results of interview with John Blessing on April 10, 1980.

13. Statement of Earl Hemmila dated April 10, 1980. ,

14. Results of interview with Marty Coope.r dated April 10, 1980. ,

15. Results of interview with Raymond Booher on April 10, 1980.

16. Results of interview with Joseph Con'gdon dated April 10, 1980.

17. Unsigned statement of Mark Coleman. ,

18. Report of interview of Mark 'Coleman dated April 11, 1980.

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'* ATTACHMEN,TJ m nam

,/

):

NUCLEAR REGULATORY COMMtsslON

\ nasMwestom, o, c. sosse March 24, 1983 9 .

m e* ,

" Bernard J. Snyder, Program Director -

MEMORANDUM FOR:

TMI Program Office Lake'H. Barrett, Deputy Program Director FROM:

TMI Program Office '

SUBJECT:

SIM4ARY OF TMIP0 SITE ACTIONS RELATED TO THE POLAR CRA PARXS' ISSUES The purpose of this me(norandum is to document historical inf concerns. In general Mr. Parks' concerns has its. roots in GPU's long standing difficulties to establish good comunications, integrate efforts and promote good working relationships between t::e various internal Departments e.g.,Alt Operations and Engineering.

in the last year, there is still room for considerable improvement. .

( Additional background on these interface problems can be found in the Unit 2 SALP report, Attachment 1.) _

Our efforts to get GPU to accelerate improvements For in this area have example, on been a constant challenge since I was assigned to TMI. days before February 16,1983,(2 Parks approached The root Operations procedure (Attachment 2) because it had technical errors.

cause of the errors was poor coordination between the Operations andIn ad Engineering Departments. told Mr. Kanga, on the same day, that I expected good qual from GPU and that my staff was reporting to me that GPU procedure quality was decreasing. I stated that he should take appropriate action to correct the situation. He said he would look into the matter.

On February 18, 1983, Mr. Parks approached 114fP0 the NRC. Joel Wiebe, informed U-2and the Region SRI, OI documented his allegation in Attachment,3. At no time, to my inowledge, and initiated an inquiry into Mr. Parks' concerns. As my staff did any TMIPO personnel disclose Mr. Parks' identity to GPU. .

interviewed GPU personnel it was not uncomon for GPU to mention Mr. Parks and Mr. Gischel because the issues we were evaluating The wereresults the sameof issues this inquiry that is Mr. Parks and Mr. Gischel had widely discussed. 10,1983 (Attachment 4). This documented in the J. Wiebe memorandum of March inquiry was carried out while maintaining contact with Regional investigators.

The chronology of the interviews is as follows:

2/18 Informed Region 2/22 Wiebe interviews King (Operations)

WI 33 b l

MS50il--_----- ------ - -- - --- - -- - _

,, s 2/22 NRC requests internal GPU correspendence on Polar Crane 2/23WiebeinterviewsGischel(Operatiens) 2/23 Poindexter (TMIF0 Bethesda) .perfoms surprise inspection of Pular Crane calculations in Bechtells Gaithersburg office (Attachment 5) 2/24 Wiebe interviews Hanson (Engineering-Licensing) '

2/24 Wiebe interviews Theising (Engineering) 2/24 Wiebe interviews Kitler (Engineering) .

2/24 Gage /Fasano interview with Fenti and Prabhakar (QA Department-)

On the afternoca of February 24, I caucused the staff and summarized our findings and informed the Region. With their concurrence we set up a meeting to tell Parks the results of our inquiry on February 25.

Mr. Arnold and Mr. Clark called at 3:00 PM, Febnaary 24, and asked why the NRC

• had been questioning GPU Operations and Engineering personnel about the Polar Crane. I said we were gathering information about safety and I was not at liberty to discuss it further at this time. They demanded to know if it was an IE inspection, NRR technical review or 01 investigation. I said I interpreted it as an infonnation gathering inquiry to detemine if further NRC action was I

warranted. They said NitC action had to fit one of their three categories.

said I didn't think so but if it made them ' feel better" they could call it an "inspection" activity. Mr. Arnold then told me they were inwstigating a conflict of interest with Mr. King and Quiltech. I told him I never heard of Quiltech an'd what the NRC was looking at was independent of Quiltech.

At 7:30 PM Larry King called Joel Wiebt at home and told him his badge had been taken and he had been escorted off site (Ref. ' Report of Allegation," dated March 1,1983, Attachment 16). King felt thi's action had been taken because he had talked with the NRC earlier (Joel. Wiebe had interviewed him when following up Parks' concerns on the Polar Crane).

l At 8:00 AM, February 25,1983, I called Mr. Arnold and expressed my concern -

that GPU employees may interpret Kings sus:ension as a signal that bringing up safety concerns were discouraged by manageeent. He said he was aware of the problem and would inform employees that the King suspension was a conflict of interest and not because of safety concerns.

As was arranged the previous day, Wiebe and I met with Mr. Parks in my office for over an hour. I told Mr. Parks we found nd evidence of threats but we could not on the other hand prove that they did not occur. We found no irregularities in the calculations at Gaitnersburg. We found no safety issues  !

that were not already being considered by either GPU or the NRC. We also told him that we were concerned with the poor relationships between departments and were concerned with the degradation in quality of procedures. I asked if he had any sp,ecific safety issues concerning .he crane or snything else at TMI that he thought was unsafe. He said no, but that he just had general concerns about administrative procedures and harass: ant. I saic that if he made a formal allegation, I could get an outsice investigator to come in if he wanted. We also He declined and said he would rather wait to see wnat GPU CA would  ! toic do. we him generally discussed the King suspension of the previous nignt.

would continue to look at the Polar Crare :icsely in our review process.

>---,----------.--------.___-____-__-__.-n-,,.,_,.,,,.,_,,,,,,,,,,,,,.w - - -

l . Bernard .J. W6JV .

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f a fonnal allegation, there was

.Although Mr. Parks did not pursue the issue o For example, two fonnal 1

l continuing NRC action on closely related items.

inspection report items did directly result from our inquiry, Open Itean 83-02 (GPU resolution of. internal safety connents) and 83-03 (Administrative Procedures /QA) which are documented in our monthly Inspectfon Report 50-320/83-03, dated March 14, 1983 (Attachment 6). This left these items open .

for possible enforcement action as we gained more infonnation..

l In the afternoon of February 25. I met with 8. Kanga and J. Barton (DirectorI '

and Deputy Director, Unit 2) to discuss the quality of Unit 2 performance. l said GPU employees were upset and perceived that reprisals would be taken if We discussed the general findings of our inquiry they raised safety concerns. I said I thought he (Kanga) pushed schedule to (the same things I told Parks).

hard and GPU was now in the "no time to do it right but time to do it over" mode.

I told them I expected them "to get their house in order pronto' and that I was "doubling the watch" on their activities. I told them the old 1

Engineering / Operations and GPU/Bechtel animosities were a big problem. '

Also during the week of February 22, my staff was reviewing. procedures that GPU had submitted for approval for future Reactor Coolant System depressurization and partial draindown. These were poor quality proceduresThese and I refused to deficiencies approve them for technical reasons noted. 24,in1983,Attachment meeting 7.w'th GPU. In were comunicated to GPU in a February addition, we included the s0bject of poor quality procedures in thea March 14, 1983, format I'nspection Report ~

(Attachment 6, page 4) foi possible enforcement action. . ,

On Monday, February 28, late morning, Mr. Arnold told me This about the Februm resulted in the 25 King / Clark meeting and showed me a copy of Clark's notes.

Arnold / King March 4,1983, letter (Attachmant 8).

On the morning af February 28, King called Region I (R. Keinig) requesting an investigation.

On March 1,, K. Christopher (RI Investigator) contacted King and interviewed him on March 2 (Attachment 9). ..

On Mrch 4, 7:00 PM, Mr. Arnold called me at home to say he is initiating e special General Office Review Board (GORB) revfew by two no (Griebetime which and 1. owe).him of the inter-departmental problems and lower quality I told work. We did not mention Parks.

On March 7, I called Bill Ward of 01 and said I would like 01 to go with WieDe to interview King and ask King if we had any additional safety. issues thct weren't already being considered. He said that it was OK for TMIPO to concuct the interview alone, that the Comission was fully briefed, I ac:ected and histhat in ops judgement coinion this was a lower priority than other job 5.

and directed Fasano/Wiebe to contact King.

, - - - -n -,., --- --,-.n- - -

. Bernard J. boycer

?r '

- 0n March 7. Kanga infomed me that Bechtel Auditing was to investigate Parks' relationship with Quiltech because a secretary had said that Parks was involved in Quiltech, since Parks, asked her to . type several present GPU employee's -

resumes on Quiltech stationary. ,

On March 8. GPU staff (Kanga included) infonned the NRC staff (Grant et. al. e and myself) of the action the'y were initiating to improve their procedure quality. I said we would judge them by performance, not by intentions or

• prourises. ,

On March 9, 5:00 PM, Fasano/Wieba set with King in the Hddletown Office King tomade review Site Operations documents to identify any new safety issues.

broad general allegations which were forwarded to OI and 0IA (Attachments 10 '

and 11). .

Rick Parks said '

On March 10, Joel Wiebe met with Rick Parks and Carl Hrbac.

GPU was trying to set him up to be fired for coming to the NRC with his concerns. This is doeurented in the March 11, 1983, Wiebe memo (Attach-ment 12) .

On March 10, GPU requested NRC approval of the Polar Crane Generic Operating Procedure (NRC approval of this procedure alone would*not pemit use of the crane with significant loads because a load specific procedure would also be requi red). I did not approve the procedure M becausel of of this the technical procedure followed deficiencies months of NRC personnel monitoring and~y disapprovacommentin noted in Attachment 13.

detailed crane procedures. As a policy, l'have not discouraged GPU from providing internal drafts of GPU documents, e.g. technical plans, safpty evaluations, schedules, procedures, and NRC submittals to my staff on an infonnal basis. My staff tees thousands of internal documents to keep abreast I

of the multiple complex tecnnical issues being worked on in the cleanup.

have instructed them that when they read this, infonnation and they find things -

that they have safety concerns about, they should inform This GPU, is at the often done working level (Engineer-to-Engineer), about their concerns.

verbally or in hand writing on the GPU document that they are looking at.

These are not considered as formal NRC reviews but do serve to identify safety issues as early as possible so that GPU can promptly address them to avoid unnecessary cleanup delays. This thorough NRC staff technical involvement also results in a more detailed technical knowledge'of alternatives considered and all aspects of safety.

The Polar Crane procedures have hac a longer than usual history when compared to similar technical avolutions, e.g. EPICOR profilter inerting and waste water GPU provided my lead site engineer on the Polar Crane processing systems, etc. Gage and Poindexter (Bethesda (Les Gage) more than the usual number of drafts.

TMIPO) reviewed multiple procedure drafts and returned them to GPU An with example coments written in the margins and general hand written cements.

of this is Attachment la where Gage and Poindexter identified a lot of c::ments . This was no surprise because the Polar Crane procedure development 12, 1983, has experienced significant problems as was indicated at the January GPU meeting (Attachment 15).

,. m .

On March 18, R. Arnold called me and stated he had received a letter from

- . Morris K. Udall regarding an inquiry of the Ccanittee on Interior and Insular Affairs into the TMI-2 accident and cleanup. -A copy of this lett sr is shown in

' Attachment 17. (Note the names that'Udall requested are all associated with -

the *)tystery Man' during the accide,n t.)

The above has been a sunnary of the NRC onsite. activities up to March 12, 1983. '

I have not approved the use of the Polar Crane for lifting loads (except "no load' refurbishment tests and with a maneal 5-ton hoist for small loads not near the reactor). Until EPU adequately resolves all open issues with the polar crane, I will not approve its use.

I will continue to constantly push GPU towards higher quality work. We will only approve cleanup operations that maintain public health and safety and accelerate the cleanup. As all of the above illustrates Our it not easy to response to the Parks accomplish this objectiva ("push on a repe*).

statement is pr'esently being formulated.

Lake H. Barrett Deputy Program Director TMI Program Office P.S. All of the above is not1 typical at THI-2. We just don't usually get this much attention. .

Attachments: .

As Stated cc w/ attachments: '

R. Haynes i H. Denton

! J. Fouchard r K. Christopher l .

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'p p *4 NUCLEAR REGULATORY COMMissl0N at3soes i ATTAQ8ENT 4 4

I ' 431 PADW. AVSNWG

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.ua er .vuia. ===snva=ia is.

Docket No. 50-320 MAR 141933 GPU Nuclear Corporation - -

ATTN: Mr. 8. K. Xanga

. Director of TMI-2 P.O. Box 480 -

Middletown, Pennsylvania 17057 ,

Gentlemen:

Subject:

Inspection 50-310/83-03 This refers to the routine safety inspection conducted by Mr. J. 5. Wiebe of f this office on January 30 - February 26, 1983, of activities authorized by N; License DPR-73 and to the discussions of our findings held by Mr. Wiebe with l '

Messrs. J. Chwastyk and J. Theising and other members of your staff at the conclusion of the inspection.

Areas examined during this inspection are desc'ribed in the NRC Region I Inspection Report which is enc 1p_ sed with this letter. Within these areas, t inspection consisted of selective examinations of procedures and representative records, interviews with personnel, measurements made by the- -  :

inspector, and observations by the inspector.

Within the scope of this inspection, no violations were observed.

In accordance with 10 CFR 2.790(a), a :apy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office by telephone, within 10 days of the date of this letter and submit written application to withhold information contained therein within 30 days of the date of this letter. Such applicationThe must be consistent with the telephone notification of your intent to -

requirements of 2.790(b)(1).

request withholding, or any request for.an extension of the 10 day period should be made to the Supervisor, Files, Mail >

l which you believe necessary,(215)

Records, USNRC Region I, at 337-E223.

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2 GPU Nuclear Corporation- gi ; Lo33 .

No reply to this letter is requirea. Your cooperation with us in this matter .;

.is appreciated. ,

Sincerely. l

' l Richard [ 5 tar i. Director' Division of Proje and Resident I

- Programs J

Enclosure:

NRC Region ! Inspection Report 50-320/83-03 ec w/ enc 1:

J. J. Barton, Deputy Director, THI-2 J. J. Chawastyk, Acting. Site Operations Director J. E. Larson, Licensing ano Nuclear Safety Director -

J. J. Bryne, Manager, TMI-2 Licensing J. W. Thiesing, Manager, Recovery Programs E. G. Wallace, Manager, PWR Licensing -

J. B. Libennan, Esquire -

G. F. Trowbridge, Esquire r

PublicDocumentRoom(POR)(LMR)(NSIC)

Local Public Document Room  :

Nuclear Safety Information Center .

NRC Resident Inspector ~

Coninonwealth of Pennsylvania .

Ms. Mary V. Southard, Co-Chainnan, Citizens for a Safe Environment (Without Report) .

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U. S. NUCLEAR REGULATORY COMMlbh10N Region ! MM 34 #R N .

a cy Mi~"~' 'N PNN Report No. -

50-320/83-03 -

cu.n;; q .:.Aus nsa 10 cra Docket No. 50-320 s. m. _ . .

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Priority -- Category C ,

License No. OPR ~/3 _

Licensee: GPU Nuclear Corporation

. P.0: Box 480 Middletown. Pennsylvania 17057 Facility Name: Three Mile Island Nuclerce Station, Unit 2_

Inspection At: Middletown, Pennsylvania Inspection Conducted: January 30 - February 26, 1983 Inspectors:

J

[N Mb iebe, Senior Resident inspector (TMI-2)

__ 3/?)P'J d(te/ signed b &L J E3 ia ion ~5pecnaltst dite' signed K.4)rr,R la d 'ad -

B. O'feill / Racfation, Specialist shks date ' signed

- \AlASArk,L _

3l9173 ena siiinEf

, Thonus, ' icentpnspector(TMI-2T Apprc/ed by: V M 8/ U L~te/ signed

~

K. Faspo, Chief, Three Mila Island-2 Projects SectTon,.rojects Branch No. 2 9

Inspection Surrvnary:

Inscection conducted ch January 30 - February E6.1983 (I isoection Report Nur:bar 50-320/83-03) Rcutine safety ins'pection conducted by site inspectors of Arcas Insoected: .

licensee action on NRC circulars; p'eriodic and special reports; routine plant operations; licensee event reports; jolar crano; procedures; surveillanen activiti'es; health physics reviaw; reactor building entries; and radioactive i material shipments. 'The inspection involved 260 inspector-hours.

Results: No violations or deviations were identified.

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DETAILS f a ,

1. Persons Contacte_d.. l General Public htilitioL(GpU) Nu'elear Corporation -

• S. Ballard, Sr., Manager, TMI Quality Assurance Modifications / Operations * '

• 5. Chaplin, Licensing Engineer *

'J. Chwastyk, Manager, Plant Operations l

• W. Cnunty, Quality Assurance Auditor J. Dettorre, Decontamination and Radweste Task L9ader .

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6. Eidas, Oe.ta Acquisition Manager '

J. Flanigan, Radiological Engineering Manager i E. Gischel, Manager Plant Engineering C. Hknsen, Licensing Engineer . '

j L, King, Director, Site Operations -

E. Kellogg, Quality Assurance Auditor

• G. Kunder, Manager, safety Review Group

3. McMullen, Comand Center Coordinator

• J. Marsden, Quality Assvrance Engineer J. Quinette. Plant Engineer J. Tarpinian, Decontamination and Radwaste Engineer ,

• R. Wells, Licensing Engineer Other licensee personnel were also interviewed.

• denotes those present at the exit interview. .

Licensee Action on NRC Circulars '

2. ,

Closed 78-18, results of UL fire test. The licenses The performed a review 1

i ceramic fibre of sprinkler locations and actuation temperatures.

blankets referred to in the circular are not used at THI-2.

The fire pumps. at Closed 7913, diesel fire pump starting contactors.

TMI are of a different model than the types which experienced the contactor problems.

3. Review of Periodic and Special Reports Periodic and special reports were reviewed for information The monthly relative operatingto the safety of the plant in its current status.

reports for December 1978 through March 1979 and the series of three startup reports were reviewed. No conditions or occurrences adverse to-current plant safety were identified.

4 Routine Plant Operations inspections of the f acility were conducted to assess compliance with general operating requirements of TS 6.8.1 in the follo status from a maintenance / modification viewpoint including plant

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. . 3 cleanliness; licensee control of ongoing and special evolutions including

' control room personnel awareness of these evolutions; control of documents including log keeping practices; and area radiological controls. ,

Random inspections of the control room during regular and back shift hours were conducted at least three times per week. The selected ,

sections of the shift foreman's log and centrol room operator's log were reviewed for the period January 30 - February 26, 1983. Selected sections of other control room daily logs were reviewed for the. period free midnight of the day of review to the time of review. Inspections of areas outside the control room occurred on January 31,1983 and Febnsary 2, 3, 7, 8, 9,14,15,17, and 25,1983. Selected licensee ,

planning meetings were observed. All areas observed were acceptQ1e. ,

5. Licensee Event Reports

• The inspector revieved two Licensee Event Reports (LERs) required to be submitted in accordance with Technical Specifications (TS) 6.9.1.8 and 6.9.1.9 (and NijREG 0161) to verify the following: Event and cause description clearly reported event information; the required LER form was .

' properly completed; and adequate corrective action was specified.

LERs 83-01/01L-0 and 83-02/01L.0 were reviewed. ,

Initial screening of these' events was cogleted to determina generic applicability, need for additional'si,te verification, and the necessity for additional NRO management review. No additional actions were warran,ted for these LERs. .

Surveillance Activities j 6.

! On January 31,1983, the inspector observed selected portions of the 1 monthly diesel generator operability test. The '8", diesel performed satisfactorily and met the acceptance criteria in procedure 4303-M16 A/B.

7. polar Crane Inspection .

- The inspector interviewed personnel and reviewed licensee documents to evaluate the licensee's ability to resolve

• internal coments concerning  :

the polar, crane. The following items were noted: ,

a. Internal coments are receiving adequate. management attention and -

are being addressed. .

b.. ; Inter-department comunication problems appear to be causing some

! ' engineers to perceive that their coments are not being adequately

'. addressed and in some cases that their coments are not welcome.

This item will receive additional NRC review following Licensee development of corrective action (320/83-03-01).

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It is not clear how administrative procedures AP-1043, "Work l

• c. l Authorization Procedure" and AP-1047, "Startup and Test Normal",

should be applied to the refurbishmaint of the polar crane. The  ;

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' licensee's Quality Assurance personnel are reviewing this matter,

-- This ites will receive additional NRC review following completion of l the. Licensee reviews (320/83-03-02). .

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l i 8. Quality of Procedures submitted for NRC Review -

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The inspector reviewed procedures for reacter coolant system (RCS) l draindown which were submitted to the NRC for approval pursuant .to. ,

Technical Specification 6.8.2. The NRC disapproved the procedures for the following reasons:

i a. Two procedures (2104-10.1, Operation of Secondary Plant Systes and i

2104-10.2, Primary Plant Operation Procedure), allowed secondary i

system pressure to ucted RCS pressure. 'This situation would ,

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violate limits and conditions established in existing procedures and also silow plant conditions not permitted by the Safety Evaluation l

Reports for the RCS draindown.

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b. Procedure 2104-10.2, allowed RCS draindown to below the 328 ft.

• j elevation. This is not permitted by the previously approved'5afety Evaluation Report for the RC5 draindown. ,

f c. Procedurs 2202-5.5, ' Loss of'RCS Level Indicator", did not j incorporate the new RCS standpipe level ind+cator nor properly j

compensate for RCS pressure on the existing level indicators.

, d. Procedure 2104-10.1, contained an incorrect valve lineup.

i Other errors included: omitted valve in valve lineup,

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inconsistancies in RCS water level elevations and required indications on water level instruments, and a dem~ineralized water patn was omitted when isolating domineralized water sources.

This item is considered unresolved pending further NRC evaluation and licensee corrective action (320/83-03-03). .

9. Routine Health Physics and Environmental Review .

a. Plant Tours ,

The NRC site radiation specialists completed routine plant inspection tours. These inspections included all radiation protection control pointh and selected radiologically controlled areas. Licensee performance in the following areas was satis-factory:

-- Access control to radiologically controlled areas ,

. .. Adherence to Radiation Work Permit (RWP) requirements

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- Proper.use of respiratory protection equipment

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-. Adherence to radiation protection procedures Use of survey met'ars including personnel frisking techniques f . .. . -

! -. Cleanliness and housekeepin' g conditions ,

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! - Fire protection measures.,

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} . b. Measurement Verification i

Measurements were independently made by the inspector to verify the l

quality of licensee performance in the areas of radioactive material i shipping, radiation and contamination surveys, and onsite environ.  ;

mental air and' water sampling and analyses.

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10. Reactor Building Entries ,

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a. The site staff monitored reactor building (R8) entries conducted during the inspection period. The following items were veHfied on ,

a sampling basis. ' .

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- The R8 entry was properly planned and coordinated to assure that task implementation including adequate as low as is reasonably achievable (A1. ARA) review, personnel training, And equipment testing. ..

- Radiological precautions'were planned and implemented including the use of 'a Radiation Work Permit (RWP).

-- Specific procedures were developed for unique tasks and were -

. properly ' implemented.

b. The site staff reviewed selected documents, applicable procedures, and RWPs concerning reactor building entries.

Entries 166 through 184 were conducted during this inspection period. '

Dudng reactor building entry 179, conducted on Thursday, February 17, .  !

1983 coupand cantar personnel notified the NRC that two additional workers were necassary in order to support an in-progress "work package", (M037-installation of five ton electMe hoist) and the work package had been.

changed accordingly. The NRC questioned whether the revised work package ha'd undergone appropMate review. Based on the discussion with. licensee representatives, and observation regarding other recent. reactor building work activities, the NRC detennined that administrative The NRC will controls review for thechanges adequacy to work packages are not well understood.

of the new administrative procedure 4000-ADM-3000.01, THI-2 Unit Work Instruction, regarding current THI-2 radiological work activities (320/83-03-04). . .

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11. Radioactive Material Shipments .

The NRC site radiation specialists inspected several radioactive material ,

! shipments during the inspection period to verify the items listed below.

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-- The licensee had complied with approved packaging and shipping j l

procedures.

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' -- The licensee had prepared shipping papers, which certified that the

- radioactive materials were properly classified, described, packaged, and marked for transport. ,

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! -- The licensee had applied warning labels to all packages and had

, placarded vehicles. l

-- The licenses had controlled the radioactive contamination and dose rates below the regulatory limits.

j i Inspector review of this area consis'ted of (1) examination of shipping 4 papers, procedures, packages, and vehicles, and (2) perfomance of radiation and contamination surveys of the shipments which were inspected. .

12. Unresolved Items, and Inspector Follow Items Unresolved items are findings about which more infonnation o' acceptable. is neededAn to ascertain whether it is a violation, a deviation unresolved ites is addressed in paragraph 8.

' Inspector follow items t e inspector concerns or perc lead to violations if left uncorrected. , Inspector follow items are addressed in paragraphs 7 and 10. .

13. Exit Interview _

- On March 1,1983, a meeting was held with licensee representatives (denoted in paragraph 1) to discuss the ihspection scope and findings.  ;

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