ML20149M434

Forwards NRC Responses to 840216 Questions Re TMI-2 Cleanup Allegations

ML20149M434
Person / Time
Site:	Three Mile Island
Issue date:	05/31/1984
From:	Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To:	Myers H HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
Shared Package
ML20149M377	List: ML20149M375 ML20149M390 ML20149M420 ML20149M434 ML20149M444 ML20149M457
References
FOIA-87-728, FOIA-87-853 NUDOCS 8802260043
Download: ML20149M434 (21)

Text

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e . /ada a pu-tiay 31, 1984 l

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l f4EHORANDUM FOR: Henry Myers Subcomittee on Energy and the Environment Coct:ittee on Interior and Insular Affairs United States House of Representatives FROM: Carlton Kamerer, Director Office of Congressional Affairs

SUBJECT:

STAFF RESPONSES TO QUESTIONS ON THI-2 CLEANUP ALLEGATIONS

/

Attached are the NRC staff responses to your February 16, 1984 questions conceriting the THI-2 cleanup allegations.

Attachnent:

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ENCLOSURE 5

. RESPONSE TO HENRY MYERS' QUESTIONS Oil TMI-2 POLAR CRANE ALLEGATIONS D

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t 3 QUESTION 1. I am enclosing a chronology of crane statements, contentions and allegations. Does NRC staff dispute elements in this chronology?

If so, which ones?

NRC RESPONSE .

The staff has clarifications for some of the elements in your chronology. In the list which follows, we have provided a response to each of your ch-onological  ;

events. Where the staff cannot confim nor deny statements or conversations '

or disput's what you have stated, we have responded with "no comment." The staff has also added some important events to the list that should be a part o'/

a complete chronology of the activities related to the polar crane during this pe riod. ,

As is discussed in some of our responses, the polar crane functional description, safaty evaluation, cr'ane operating procedure and load test procedure are different docinents, each with a different purpose. Therefore, it is possible to approve one of these documents and disapprove another without being in conflict. These docunents constitute the major elements of the staff's reviews related to the polar crane.

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CHRONOLOGY I

H. MYERS ITEMS NRC STAFF C(WWENTS DATES

• 0ctober 12, 1982 Functional Description submitted by GPU to the RC for review

( and approval.

IGtC TMI Project Office m rts NRC nonnally reported GPU January 17, 1983 that the crane load test is proposed schedules without scheduled for late February. stating if they wre opti-mistic or pessimistic. In the case of the polar anne.

GPU schedules were ve';

optimistic when consi v <-

ing the outstanding issues A, that they had to resolve '

prior to perfonning the load test.

8 50 reviews crane SER. No Comment.

January 20, 1983 -

Februa ry 10 1983 Polar crane was inspected by No Comment.

Janua ry 24, 1983 NRC consultant. The inspection did not "identify any hardware deficiencies Alch could delay the , crane recovery schedule."

Gischel (plant engineering director) No Conunent. ,

February 10, 1983 writes King TMI-2 Site Doerations Director, a memorandum stating that the safety evaluation of the crane was "technically unacceptable as presented."

• Denotes itons added to the chronology by the NRC staff.

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NRC STAFF CMENTS DATES H. MYERS ITEMS King and Gischel inform IMI-2 chief No Comment.

February 11, 1983 Kanga that they had problems with the polar crane safety evaluation and would not concur.

TMI-2 deputy chief Barton complains No Comment.

February 14, 1983 to King about Gischel's not agreeing with the crane safety evaluation.

King finds that the crane safety As may be seen on the GPU February 14, l_983 concurrence list for the evaluation had been sent to the polar crane load test NRC without his having reviewed it. This, according to King, was safety evaluation, a violation of the NRC regulations. Larry King apparently did concur on that document bafore submit-tal to NRC staff as his initials appear on h the document (See Attachment 1). .

King and Gischel send memoranda to King and Gischel sent a l February 14, 1983 memo to management on upper management expressing funda-mental disagreement with crane the polar crane SER on I

program.

February 17, 1983, not February 14, 1983.

Parks says that, "On Monday No Comment.

February 14, 1983 morning, February 14, 1983 Mr. King informed the 50 staff that he had received a phone call from Jonn Bartoo asking 'what the hell' Ed Gischel was doing writing l

' the polar crane memorandum.

Larry KLg reported Barton's threat -

• I don' t need peopie like that working for me. I'll fire their ass.'"

(Parks p.18-19.)

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H. MYERS ITEMS NRC STAFF COWEENTS .

DATES 1MI-2 engineer Parks infones No Casument.

February 17, 1983 Radb111 (leader of the Polar l

Co.se Task Force) that the polar crane test procedure did not comply with administrative

• I procedures.

• Februa ry 17, 1983 Revision 2 to the functional Description was submitted

. by GPU to the NRC.

February 18, 1983 Kitler (TMI-2 management official) No Comument.

l threatens to have Parks renoved l

from the site.

1 Februa ry 18, 1983 NRC TMI Project Office reports. that No Comument.

the polar crane load testing is ,

7 "scheduled to be accomplished during the next two weeks."

GPU sutzeits polar crane load test

• Februa ry 18, 1983 safety evaluation to NRC for .

review and approval.

4 Meeting at dich King and Parks No Comument.

February 22, 1983_

explain that crane refurbishment did not comply with administra-tive procedures 1043 and 1047.

Kanga orders King to appoint a test director for the polar crane test. King refuses.

4 Februa ry 23, 1983 Agreement is reached that Q/A would As indicated in the review procedures for polar crane February 23, 1983 internal modification and testing. GPU memorandum from

8. Ballard to 8. Kanga, (Attachment 2) QA clearly indicates that they were previously involved in the over-sight of the polar crane i

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NRC STAFF C90ENTS DATES H. MYERS ITEMS i refurbishment program. , ,

Although 04 identifies l administrative deficiencies. .!

they do state that they

".. .found no significant l programmatic probits i

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with the Safety Evaluation l or the polar Crane refurbishment process....".

At 5:00 p.m. 8arton (TMI-2 No Cameent.

February 23, 1983 I Deputy Chief) asks King if he is president of Quiltek. King said yes and Barton "lif ted King's badge." (King was suspended, prohlht ted from the site and fired on p.

March 23.

We would like to clarify Februa ry 25, 1983_ MC-TMI Office Chief Lake Barrett what transpired in the ,

infonas Parks that NRC had meeting between Mr. Parks inspected the crane and could find no problems. and the MC staff on February 25, 1983. The

' M C staff (L. Barrett and J. Wiebe) told Mr. Parks that MC found no probless that were not already being considered. For completeness, the staff summarizes below the relevant discussion given in Attachment 3, 3/24.meno L. Barrett to 8. Snyder, which locludes an account-ing of what took place at the February 25, 1983 meeting with Mr. Parks.

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NRC STAFF COMMENTS DATES H. MYERS ITEMS As was erranged the previous day, J. Wiebe and Mr. Barrett met with Mr. Parks in the TMIPO offices for over an hour. Mr. Barrett told Mr. Parks the NRC found no evidence of threats but we could not, on the other hand, prove that they did not occur. The NRC had conducted an inspection and had found no irreg-ularities in the calcu-lations at Gaithersburg.

1 Mr. Parks did not identify any safety issues that were not already being considered.

Mr. Barrett and Mr. Wiebe also told Mr. Parks that the NRC was ,

concerned with the poor relation- y ships between departments and

• with the degradation in quality of procedures. Mr. Barrett asked if Mr. Parks had any specific safety issues concerning the crane or anything else at TMI that Mr. Parks thought was un-safe. Mr. Parks said no, but that he just had general concerns about administrative procedures and harassment.

Mr. Parks was told that if he made a fonnai allegation, an outside investigator would come in if he wanted.

Mr. Parks declined and said he would rather wait to see what GPU QA would do.

Mr. Barrett and Mr. Wiebe also generally discussed

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.s NRC STAFF CWW4ENTS-DATES H. MYERS ITDtS the King suspension of the previous night.

Mr. Parks was told that the NRC would continue to look at the Polar Crane ciescly in the review process. -

90tC TMI Project Office reports No Comument.

February 28, 1983 that preparations for polar crane full load test were continuing.

Parks receives response to his No Comument.

Februa or 28, 1983 polar crane comuments. The response stated that certain Q/A require-ments did not apply to the polar crane test procedure.

Parks and Chwestyk (King's replace- No Comument. ,

Nrch I ,1983  ?

ment) write ausnorandum to manage-ment stating opinion of Q/A '

managers that Q/A requirements did apply to the polar crane test procedure.

No Ceaunent.

Nrch 4,1983 TMI Q/A staff state that certain modifications to the crane had not been made in accordance with Q/A requirements.

March 7,1983 NRC TMI Project Office reports that This statement was made in the TMIPO's Weekly the polar crane evaluation was Status Report and was complete and that a polar crane load test was scheduled for the referencing NRC's review latter part of March. of GPUNC's Polar Crane Functional Description.

The staff was already aware of possible admin-1strative deficiencies as is documented in the NRC's February 1983

N. MYERS ITEMS _ NRC STAFF CGOENTS DATES Monthly Inspection Report covering the period 1/30 - 2/26/83 (see Attachment 4). The staff had not completed its technical review of the load test program as of this date because implementing procedures had not been received and the staff had not completed its safety review of the load test SER.

-s March 7, 1983 NRC TMI-2 Program Director states: The TMI-2 Program Director made the referenced state-

"The NRC staf f concurs with ment in the NRC's approval f, the Functional Description as it of the Functional Description relates to the Reactor Buf1 ding for the refurbishment of TMI-2 Polar Crane Load Test using the Polar Crane dated March 17, 1983. t main hoist system. QA/QC has The functional description is a '

been involved at all stages of document that discusses the the refurbshment process in programmatic approach to the addition to NRC staff. Safety refurbishment. Specific .

considerations have been addressed polar crane load test safety i

under a separate letter." issues were addressed in the licensee's Safety Evaluation '

Report dated February 18, 1983, as amended. Because any state-r ments made in the staff's i appraisal of the functional Description relate to re-furbishment philosophy, it was not contradictory to approve the Functional ,

Description and disapprove the detailed procedures. 6 The statement that QA/QC was involved in the refurbishment process means that in our m ------

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NRC STAFF C(MMENTS DATES H. MYERS ITEMS judgement QA/QC was carrying out their audit l functions. (See March 10,1983 discussions below as evidence of this.)

l GPU submitted the Polar .

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• March 8, 1983 Crane General Operating Procbdure for NRC approval.

March 10,1983 TMI-2 Q/A staff express concern to QA forwarded a memorandum to TMI-2 management about crane activi- J. Theising of Recovery Programs on March 10, 1983.

ties not carried out in accordance with Q/A requirements. This memo discussed Polar Crane QA/QC itens that had been previously reviewed. It stated 1*

that polar crane "tests l were technically adequate" even though it appeared that there were some administrative l deficiencies. It also indicated that QA had previously reviewed the functional Description.

NRC TMI Office Chief Lake Barrett It should be noted that March 10, 1983 this disapproval (see disapproves proposed procedures for test of polar crane. Attachment 5) was for the detailed implementing procedure for operating the polar crane. This disapproval was for detailed procedural steps and therefore was not l in conflict with the NRC's l approval of the prograsanatic functional Description.

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DATES H. MYERS ITEMS NRC STAFF CWWENTS March 14,1983 RC 1MI Project Office reports No Comument.

to NRC HQ that the polar crane load test was scheduled for the week of March 21.

March 21,1983 NRC TMI Project Office reports to No Comument.

HQ that the crane test was delayed

• from late March to early April.

• March 23,1983 .

Parl s makes public his affidavit on polar crane allegation.

April 7,1983 NRC TMI Project Office disapproves Disapproval of Polar Crane polar crane test procedures. Test Procedure (see Attach-ment 6) was based on

"... technical aspects of the procedure in areas other ,

than those pertaining to g the Parks /Gischel affidavits. .

These issues are being handled by the NRC's Office of Investigations." The technical reasons for dis-approval are detailed in 18 separate comuments.

Has NRC staff compiled a list of defects in the proposed crane QUESTION 2. l test program as the program existed on February 23, 19837 As it

• i existed on March 3, 19837 l NRC RESPONSE The basic polar crane test program as stated in Appendix A Table 4 of the B. Kanga to L. Barrett letter, "Polar Crane Refurbishment," dated .

October 8,1982, has remained the same and no changes have been made.

The basic test program (but not the details of the implemen. ting operating and test procedures) was approved by the NRC in a letter from 8. Snyder to B. Kanga on March 7,1983. The GPUN detailed procedures which were to impicment the details of the basic test program did require changes when they were. originally submitted to the NRC for approval. On both February 23 and March 3,1983, the TMIPO staff was awaiting various detailed GPU documents (e.g., polar crane operating procedure and load test procedure) concerning the polar crane and was reviewing other documents (e.g., test results, Polar Crane Safety Evaluation and Functional Description) regarding the polar crane that it had in its possession. The procedure review resulted in L. Barrett's March 10,1983 disapproval of the polar crane operating procedure ( Attachment 5) and L. Barrett's April 7,1983 disapproval of the polar crane load test procedure ( Attachment 6). The reasons for these disapprovals are listed in the above doctnents. lne issues discussed in these disapprovals were based on NRC's technical reviews and did not originate fran any allegations of Messrs. Parks, King and Gischel.

On February 18 ,1983, Mr. Parks contacted the TMIPO regarding concerns he had with the polar crane load test implementing procedure. This led to a TMIPO inquiry into the issue during late February. This inquiry resulted in the March 14, 1983 inspection report ( Attachment 4) which addressed inter-departmental communication problems (NRC item 320/83-03-01)and the use of administrative procedure AP-1043, "Work Authorization Procedure," and AP-1047, "Startup. and Test" (NRC item 320/83-03-02).

l These items were largely initiated because of Mr. Parks' concerns and were to be resolved prior to the polar crane load test. The NRC staff held an l exit interview with GPU management to infonn GPU of these concerns on March 1,1983 (i.e., between the February 23, 1983 and March 3,1983 dates).

l Ctronological details of this time period are included in the attached i

( Attachment 3) L. Barrett to B. Snyder memorandum dated March 24, 1983.

In summary, the defects are listed in the NRC procedure disapproval document (NRC technical issues) and the February inspection Report (Parks' adminis-trative procadure issues).

QUESTION 3. If the crane had been tested in accord with the GPU/Bechtel 1

plan that existed on February 23, 1983, would such tests have violated the NRC's regulations? That existed on March 7, 19837 l

NRC RESPONSE l If the crane had been tested on February 23, 1983, or March 7,1983, the test would have been a violation of the THI-2 Technical Speci#ications (and there-fore a violation of NRC regulations). The TMI-2 Technical Specifications

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require NRC revipw and approval of the GPU procedures required to perfom such activities. However, on February 23 and March 7,1983, it was not possib.e for GPU to conduct the polar crane load test because they had not completed, and the NRC staff had not approved, the detailed implementing procedures for the test. Additionally, the staff had not completed its safety review of the planned load test. Only the basic polar crane functional description (October 12, 1982 Kanga letter) had been approved by the NRC by March 7,1983 (March 7,1983 Snyder letter).

QUESTION 4._ In what respects does the current crane test program differ from that which existed on February 23, 1983? That which existed on March 7,19837 NRC RESPONSE There has been no change to the basic polar crane test program logic nor the load test sequence; however, there have been sone changes to the detailed implementing p ocedures. These changes fall into two categories; technical and administrative. The technical changes were a result of NRC staff and consultant reviews and were not as the result of Parks, King and Gischel all egations. The following is a list of technical changes that were required by the NRC relative to the load test and operating procedures, to improve the safety margin:

' , ,.. .' - e Technical Changes to the Polar Crane t.oad Test and Operating Procedures

1. Rigging was upgraded per NRC consnents dated March 10,1983 and April 7,1983.

2. Vertical lift height limits were added per NRC comment dated April 7,1983.

3. Hook rotation precautions were added per NRC comment dated April 7,1983.

4. Electrical current monitoring requirements were added per NRC comment dated April 7,1983.

5. A sudden stop test was added per NRC comment datred April 7,1983.

6. Mditional miscellaneous changes were made to more clearly define various steps in the procedure.

The administrative changes were to correct the administrative deficiencies that Mr. Parks brought forward (e.g., compliance with Administrative Procedures l 1043 and 1047). These were noted by NRC in the March 1 inspection exit interview l

l with GPU as doctmented in the February Inspection Report, dated March 14, 1983 1

( Attachment 4). For the polar crane program these deficiencies were subsequently corrected by GPU.

15-QUESTION 5._ Is ,it the position of NRC staff that revisions in the plan for testing the crane would have been required even if Parks, King and Gischel had not expressed disagreement with the directives, orders, plans, etc. put forth by their Bechtel-and GPU supervisors?

Is it the position of NRC staff that revisions in the plan for testing the crane would have been required even if Parks, King and Gischel had not gone public with their concerns?

MRC RESPONSE As previously noted, no changes were required to the basic crane load '.est program.. 'Certain revisions in the implementing procedures for testing the crane (see response to Question 4) wculd have been required even if Parks, King and Gischel had not expressed disagreement with Bechtel/GPU supervisors nor gone public with their concerns. The NRC staff was conducting its safety and technical review of the polar crane (refurbishment anu testing) when the allegations were raised. Based en the staff's review, changes were made to the implementing procedures (a.g. , load pathways, upgraded rigging, testing and monitoring requirements) to improve the margin of safety. These require-ments were not influenced by th3 allegations raised.

It should be noted, however, that the administr6tive issues identified by Parks, King and Gischel made their management aware of the deficiencies in the administrative procedures which were uployed to refurbish the polar crane.

As stated previously, these deficiencies were corrected by GPU and NRC was monitoring their corrective action via the February 1983 inspection report open items.

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QUESTION 6. On, March 14, the TMIPO office reported to HQ that the polar crane  ;

loM test ws scheduled for the week of March 21. On March 21, the TMIPO office reported that the crane test was delayed from  ;

1 March to early April. What elements of the plan caused the l change? When did TMIPO receive infonnation which caused it to disapprove the procedures for testing the crane?

NRC RESPONSE The TMIPO Weekly Status Report dates were based on schedule infonnation provided by GPU. The staff just reported GPU's schedule change in the Weekly Status Report. The schedule was delayed because: (1) GPU was having difficulty responding to TMIPO questions on the operating procedure (see Attachment 5); (2) GPU did not submit the load test procedure to the NRC for review and approval until March 31,1983; and (3) GPU was resolving internal consnents, e.g., issues rsised by Parks.

The polar crane operating procedure was received on March 8 and disapproved on March 10, 1983. The polar crane load test procedure was received on March 31, 1983 and disapproved on April 7,1983. The procedures were rejected because they were not acceptable for reasons stated in response f4 QUESTION 7. Does the NRC staff intend to specify which of the Parks, King and Gischel allegat;ons it has substantiated and which it has not substantiated?

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i NRC RESPONSE ,

The NRC Office of Investigations (01) report, dated September 1,1983, I addresses the allegations of Parks, Kir.g and Gischel relative to the polar c rane. The TMIPO presented their analysis of the Septaber 1,1983 report in a paper to the Cm elssion, dated January 25,1984.

QUESTION 8. What is the basis for the staff staternent that tilere ws no evidence of deliberate circumvention of administrative procedures to avoid technical requirenents? Does the staff intend to say there is no evidence of willful violations of NRC requirements

or conspiracies to violate NRC requirst, ants?

NRC RESPONSE 8ased on the staff's review of the infonnation related to the polar crane refurbishment and testing, including the allegations raised by Pa rks ,

King and Gischel, it is the staff's judgement that the licensee had not deliberately or will, fully circumvsnted their technical requirements nor conspired to violate NRC requirements.

In the staff's opinion, the aaministrative deficiencies were more th?

3 result of confusion related to the turnover of the polar crane from GPO to Bechtel rather than any deliberate attempt to bypass GPU administrative requi renents.

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3 f ATTACHMENT 2 Intor=@ffloo Momorandum

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Date February 23, 1983 k.h;j Nticlear SMt polar Crane Safety Evaluation 6110-83-039 Locanon TMI Trailar 175 7c. 3. K. Kanga

) Directat , Unit 2 1

l Quality Assurance has reviewed the saf ety Evals.cion for the Polar Crane Load Test and the concarns that have been raised par your request, i Rechtel l' The calculations to back up the safety Evaluation were reviewed.

Quality Assurance was requested and haa reviewed the The only calculations available at the site were Bsw an applicable to the loss of components due to load drop.

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some events were evaluated in a probabelistic manner and no, calculations were made. One axample is the drop of a missile shield directly on the hectcr Nead.

The extent of damage is postulated and not backed up by caleulations.

l Our review also identifie8 two iteEs that were not specifically addressed in

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the safety Evaluation: .

1)

The Icad test should :;ualify the same length of cable that will be required for head'11ft.

2) 1 cad testing of the f abricated load test frame prior to Polar Crans I

load test has not been addressed, although all other rigging componatts have.

"here he", beea additional concerns raised that are not dirnetly rotated We plu u it.tsto: the .iit-i Safety Evaluation but which could be a potanual pror,ies.th is inadequate:

test.

1) Traising f ar :prit:rs ar.d perser x1 dizart',nc the ick:.

2) calibration et the lead cell.

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• .o the Polar "Jar,e--concerns hava been raised that 31 Modif':ations modificauens so the Polar trane vere not a;propriately docu:nented.

4) Test Prgram - verify that the prograrmatic, Omntrols for testing were followed (i.e . Ar-1M1 and At-1047 have been cceplied with) .

3) Reverify inspectica and refurbishment documentation.

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! Memorandue 4110-43.c33 . ,

February 23, 1983

• Page 2 ,

I would recanumand Engineering ' assure themselves that they have adequately covered the two items noted concerning' the Safety Fraluation. Though hse items any not require any modification to the safety tvaluation, they try .

requize change or review for applicabit.ity to the actual load test implementin-procedures. -

I.n stammary, we in 9A hrve found no significaat programmatic problems with the safety Evaluation or the Polar crase refurbistment peccess but we will continu-to assess this prograc apd keep you. appraised of any problems discovered. It should be noted that there appears to be a nuabar vf technical concerns being ,

raised and these showe be addressed fully by Engi.neering.

An interesting ites to nots which we did discuss within QA was the approach Achtel has taken on this specidic safety tvaluation. Though it is acceptable from a programmatis sad engi.neering standpoint to perform the evaluat&tian has on a worst case scenario, in our recovery mods, there may be sw.e operationi considarations t. hat may make th'is approach not always prader.t. An a. alogy is ,

i la our industry for years we considered the large

• break krA the worst case '

limiting accident bef tre the di ace'ident, where as now we have learr.e4 that a small break Loch , deserves i..;ml s' tention. Serder Engineering management should perhaps review this issue.

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. Modifications / operations BER:JTMicam , ,

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Muknewe Pennsyhinia 17M7 reux .n 717 944.7421 4.ter's Oweet Del &imte: -

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MLddEar Ar., WA 17057 4 91 sua assions.

l Dear Sta an' I

These MLla Islard helaar Stathm, Dedt 2 (M-2) W ' "' ' ' ' "' ' l mw='

• 22C"~ I 0parating Liesnee h. Drt 73 i

Dochet 2 . S 320 C'

. Polar Cesan Refu W N 4 Enclooed ibe your approval is the Safety Raluatten laxst (SER) ter the

Folar crans lead Test. This doansne ocecludes andthatera betm aconspl/ahed load test Joes with-noe aanstit:sta an tksmissed Safety

out unian risk to the baalth and of tbs public. Your +Einn j in Mting tbs review and syproval tida h ==re in a tianly ==nnar is seestly vr

• If you have any quast*ms or desire furder %" H=; plaase feel free to er=*=ce Mr. J. J. Byrne of my 6taff.

Sincerely,

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