ML20151B439
| ML20151B439 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/16/1988 |
| From: | Myers M PENNSYLVANIA, COMMONWEALTH OF |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151B434 | List: |
| References | |
| NUDOCS 8807200367 | |
| Download: ML20151B439 (30) | |
Text
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- . xn COMMONWEALTH Or PENNSYLVANIA Ornce or GCNERAL COUNSF.L HAnnissuno MorsEy M. MYERS GENERAL COUNSEL June 16, 1988 William T. Russell, Regional Administrator United States Nuclear Regulatory Commission Region I 475 Allendale Road King cf Prussia, Pennsylvania 19406 Re:
Comments on the Revised Plan for Restart of Peach Bottcm Atomic Power Station
Dear Mr. Russell:
At the Governor's direction, I am forwarding to you the Commonwealth of Pennsylvania's Comments on the Revised Plan for Restart of Peach Bottom Atomic Power Station.
These comments are detailed and follow careful study.
They describe many areas of concern, but I wish to highlight for you some of the mest important issues.
In general, we are pleased with Philadelphia Electric Company's decision to reorganize top corporate management.
In our previous filings with the NRC, we have argued strongly that ultimate responsibility for Peach Bottem's problems rested with top corporate management.
The change in personnel at the Peach Bottom plant and in the nuclear sector of the corporate manage-ment now give us hope of real reform at the plant.
In many ways, however, the Restart ~ Plan-is lacking.
Much of the Plan is too general and provides insufficient background information to permit a full evaluation.
In particular, the Plan fails to disclose information about the culpability of former control room operators despite PECO's proposal to retain most of them for future operations.
PECO should provide a full evaluation of and justification for continued employment of each operator and former plant manager it-retains.
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The Commonwealth has comments also on a variety of other staffing concerns.
Most important is PECO's failure.to commit to a designated number of licensed' operators telew ehich'it will not operate the plant.
A shortage of operators, which led to burdensome overtime Yequirements a'id low morale, played a major role in Peach Bottom's operator problems.
PECO also fails to commit to industry-establishtd standards'for plant operators, security personnel, p' lane'nanagers and plant safety
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experts.
PECO executives themselves helped to develop these 8807200367 880616 DR ADOCK 05000277 PDC
standards.
Of equal importance, PECO has not developed an adequate program to protect and encourage whistleblowers to report safety concerns not only to Upper level managemen; but to outside authorities if necessary.
Despite Peach Bottom's serious previous problems, they were eventually reported only by outside contractors.
Beyond staffing levels and qualifications, our comments focus on internal relationships.
We are concerned that the doubling of plant management may actually impede rather than aid future operations.
That doubling makes internal communica-tions all the more difficult.
We are even more concerned about the independence of the safety and quality review groups at the plant.
These groups necessarily will play a crucial role in insuring that Peach Bottom does not repeat its prior performance.
Rather than l
reporting through a line organization, these groups should operate independently and have access to all levels of plant and corporate management and all outside regulatory bodies.
PECO should explicitly adopt qualifications for group member-ship that will insist upon only experienced, independently minded reviews.
The chairmen of these groups should have proven track records of emphasizing safety over corporate relations.
Furthermore, before restart, they should demon-strate their abilities and the willingness of Peach Bottom management to respond to safety concerns, by reevaluating the impact on Peach Bottom's safety of numerous safety issues raised by industry and vendor reports issued over the last several years.
In addition to management issues, we comment on the general industry problem involving the containment structures of Mark I power plants such as Peach Bottom.
Serious concerns have been raised about the capacity of such a structure to withstand a severe accident.
We reiterate the view we have taken in court papers dealing with PECO's power plant at Limerick that the NRC should decide the viability of severe accident mitigation system that may supplement the containment structure.
These systems are being installed throughout Europe.
We urge speed both by the NRC and by PECO so that the Mark I containment issue is resolved prior to restart.
Most importantly, the Plan is -lacking because of its failure to reduce its proposals to specific verifiable commit-ments and to specify an adequate system for tracking those commitments.
Although new corporate management raises hopes 1
I for real reform, PECO has too often failed to follow through on prior commitments for improvement.
The NRC-and PECO must assure that all reform proposals are made by improving the quality and vigour of inspections.
The Commonwealth is anxious to participate closely in future oversight.
We look forward to seeing.our concerns fully addressed.
Sincerelyj
% I h.uk i
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Morey M. Myers MMM/ls Enclosure cc:
Eugene J. Bradley
S l
Comments of the Commonwealth of Pennsylvania l
on the Revised Plan for Restart of Peach Bottom Atomic Power Station and the Actions of Philadelphia Electric Company Leading Up to and Succeeding the March 31, 1987 Shutdown Order of the Nuclear Regulatory Consnission i
June 16, 1988
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l Comments of the Commonwealth of Pennsylvania on the Revised Plan for Restart of Peach Bottom Atomic Power Station and the Actions of Philadelphia Electric Company Leading Up to and Succeeding the March 31, 1987 Shutdown Order of the Nuclear Regulatory Commission INTRODUCTION The Commonwealth of Pennsylvania provides the following i
comments on the proposed Plan for Restart of Peach Bottom Atomic 1
Power Station, Revision 1 ("Revised Restart Plan") which the Philadelphia Electric Company ("PECO") submitted to the Nuclear Regulatory Commission ("NRC") by letter dated April 8, 1988.
Determining that the continued operation of Peach Bottom was an immadiate threat to the public health and safety, the Shutdown Order required that PECO place or retain the Unit 2 and Unit 3 i
reactors in a cold shutdown condition.
The order requires that PECO provide for the NRC's approval "a detailed and comprehensive plan and the schedule to accomplish the plan to assure that the 1
facility will safely operate and comply with all requirements."
l The Revised Restart Plan is PECO's current attempt to satisfy this requirement.
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The Commonwealth is pleased by changes 'in the highest level of corporate management.
In the Commonwealth's previous filings with the NRC on restart issues, the Commonwealth has argued strongly that ultimate responsibility for Peach Bottom's problems rested with top corporate management.
PECO, understates this problem when it lists as its fourth root cause of its mismanagement that "(c)orporate management failed to recognize the developing severity of the problems at [ Peach Bottom) and thus, did not take sufficient corrective actions."
As irrefutable evidence now establishes, top corporate management was repeatedly told of operational problems and chose to ignore them.
The removal of former top management and the new attitude taken publicly by the replacements are encouraging.
Other personnel changes at the plant level outlined in the Revised Restart Plan are also encouraging.
The Commonwealth is similarly pleased by PECO's desire to maintain a level of eighty-five licensed operators, although that "goal" should be a firm commitment.
Throughout the Restart Plan, general statements describing such matters as PECO's intention to demand the highest standard of excellence, its proposal to initiate various training programs, and its proposals to insure 1
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regular meetings among corporate management and with frontlina workers are laudable.
Giving credit where credit is due, the Commonwealth nevertheless remains concerned by many elements of the Restart j
Plan.
-The plan on the whole remains too general to permit proper 1
evaluation.
Some of the most crucial areas, for example the responsibility of individual' operators and those managers, who are retained for previous misconduct and the justifications for their retention, remain undiscussed.
Certain basic problems, such as drug abuse and previous sanctions against whistleblowers, are either not addressed at all or are insufficiently addressed.
Independent assessment organizations need even greater independence and must satisfactorily demonstrate reanalysis of problem reports (such as Significant Operacing Events and vendor reports) that may have triggered inadequate responees over the i
last few years.
Finally, and most importantly, the reforms.
generally proposed must be reduced to specific, clear, verifiable commitments and proper avenues outlined for verification.
The Commonwealth is anxious to be able to verify each of the commitments made by PECO.
I.
BACKGROUND The sufficiency of a solution depends on the scope of the Problem it addresses.
s Properly determining the nature of the Problem at Peach Bottom is therefore the first-step in an analysis of the Restart Plan.
From 1981 to 1987, the NRC annual Systematic Analyses of Licensee Performance Bottom poor performanc(e ratings.SALP) reports have consistently given Peach During the past several years, the SALP reports have found PECO's performance in several categories "unacceptable," placing Peach Bottom at or near the bottom in performance ratings of nuclear power plants in the
-l entire Northeast.
The poor overall performance during this period has included i
particular safety incidents calling for substantial, civil penalties totalling $485,000.
In 1986, for example, operators failed to follow specifications in the adjustment of control rods after a computer failure required manual adjustment.
As the 1987 SALP described it, the "root cause" of this incident was "an apparent complacent attitude by operations personnel."
The Commission fined PECO $200,000 for this breach.
Also in 1986, the Commission fined PECO $50,000 for a supervisor's firing of an employee who had expressed concern over safety matters.
'These incidents and others indicate, in one SALP report's language, "a
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pattern of inattention to detail, failurc to adhere to procedural requirements, and a generally complacent attitude by the operations staff toward performance of their duties."
This repeated pattern of poor performanca, manifested in such areas as maintenance and security, led even into the control Key control room staff slept periodically on the job or r,o o m.
engaged in paper ball fights.
condoned this behavior.
Management apparently knew of and Although the scope of the mismanagement is now well known a striking feature of this period was that mismanageme,nt coexisted with repeated commitments for improvement.
For example, in 1984, as a Steering Committee representative in the ad hoc Nuclear Management and Resources Council (NUMARC),
efforts in a demonstration of the industry's commitment. Peach Bottom com These areas were:
1.
Development of personnel training, qualification and accreditation programs; 2.
Enhancement of the performance of corporate nuclear management involving the direction and support of power plant activities; 3.
Enhancement of licensed operator performance and professionalism; 4.
Improving the readiness for operation of plants soon to receive operating licenses; 5.
Improving the diagnostic abilities of shift operating personnel; 6.
Development of utility nuclear management experience; 7.
Improving human resource management activities to help alleviate a shortage of qualified personnel; 8.
Improving utility fitness for duty programs; 9.
Reducing automacic reactor trips; j
- 10. Improving management effectiveness.
In a November, 1986 briefing to the NRC, NUMARC reported that all nuclear utilities had successfully fulfilled these commitments.
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But of the ten areas listed above, PECO's Restart Plan itself identifies seven as problem areas which the plan addresses (all but 4, 5 and 9).
Furthermore, PECO's commitment to number 4, improving the readiness of new plants such as Limerick, may have contributed to its failure to fulfill its other commitments.
Another example of a failed commitment lies in PECO's reaction to the NRC's Generic Letter 83-28 of 1983.
At the Salem atomic power plant, the plant's usage of an incorrect groase for a circuit breaker led to the failure of the facility to scram automatically, requiring an operator to drop the control rods into the reactor core.
The circuit breaker error resulted from the plant's failure to keep up with problems learned by the circuit breaker's vendor.
The Generic Letter, setting forth actions required as a response to Salem's problems, required enhanced communications between plants and vendors.
In response, the industry established the Nuclear Utility Task Action Committee (NUTAC), in which PECO participated.
NUTAC recommended that plants establish a specific, detailed program known as VETIP for communicating with vendors and responding to the technical information they provided.
In a letter duced April 23, 1984, PECO told the NRC that it generally complied 'sith most aspects of the program" and that administrative controla of the program would be completed by March 1985.
Events since 1985, however, have cast serious doubt on fulfillment of this commitment.
The Septehber 8, 1987 SALP and subsequent SALP meeting revealed that PECO was impeded in performing required maintenance on technical manuals for its auxiliary emergency diesel generators, which are a safety related plant component, because of inadequate or outdated technical manuals.
These technical manuals would have been updated had PECO been in compliance with the VETIP requirements.
In addition PECO has proposed several prior plans that have not been implemented.
These are the Peach Bottom Imorovement Plan (1985), The Peach Bottom Enhancement Procram (1986) and the Commitment to Excellence Action Plan (1987).
Because of PECO's history of poor performance, and in particular because of operator misconduct, the Commission issued the Shutdown Order of March 31, 1987.
The NRC recognized "that the licensee, through its enforcement history and from what has been developed by the ongoing investigation, knew or should have known of the unwillingness or inability of its operations staff to comply with Commission requirements, and has been unable to implement effective corrective action."
The Shutdown Order recognized that continued o'perations of the facility was an immediate threat to the public health and safety.
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Unfortunately, even after the shutdown, operations at the plant have continued to be suspect.
Drugs have several times been found within or immediately outside the plant and t
indictments were handed down or November 8, 1987 of six individuals for drug offenses.
Four of the individuals were PECO employees, and the other two were contract employees.
There have been continued reports of excessive overtime and forcing security personnel to work through breaks.
To the extent that the two problems are related--if drug abuse represents an attempt to stay alert during periods of overtime--they are particularly troublesome.
PECO's initial resporse to the Commission's closure order provided little hope of improvement.
Its proposed "Commitment to Excellence" report in the fall of 1987 suggestod that major changes in management were necessary only at the plant level.
The report not only sought to deflect responsibility from corporate management, but, as NRC Staff noted, the report did not address PECO's past inability "to self-identify problems and implement timely and effective corrective actions."
In addition, the manner in which the proposed corrective actions were supposed to address the "root causes" of Peach Bottom's problems were "unclear and inconsistent," and lacked "sufficient detail."
These continued poor, operations and management led the Institute of Nuclear Power Operations (INPO) to issue a highly critical report in January which evaluated this year of Peach Bottom's performance both before and after issuance \\qf the Shutdown Order.
This background suggests three features that define the Peach Bottom problem.
First, the failings at Peach Bottom lie with management as a whole, not with any particular segments.
The solution must be equally comprehensive.
Second, in part because the problems at Peach Bottom extend to so many areas of plant management, management failures rise to a level at which the public health and safety is threatened.
The NRC explicitly recognized this level of concern in its shutdown order.
The Commonwealth is accordingly concerned with the NRC's proposal to find that proposed amendments to Peach Bottom's technical specifications do not raise significant hazard considerations.
52 F.R.
48593 (December 23, 1987 The NRC's reasoning appears to be that changes in these amen)dments alone do not raise health and safety concerns because they are only one small part of the Peach Bottom problem.
But the health and safety concerns cannot be divided into pieces that do not individually raise the same concerns; because the solution must be comprehensive, each aspect of mismanagement must be viewed with the seriousness of the statutory standard.
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through on reform commitments, the problem is notFinally, bec proper proposals for change, but assurin just assuring plans must be made in the form of clear,g actual change.
Reform Generalities do not suffice.
verifiable commitments.
II.
GENERAL COMMENT
S The Commonwealth divides its comments into the general and Following these comments, the Commonwealth discusses need for specific commitments and for credible methods of verification.
The importance of these features merits a seoarate section.
A.
PECO should disclose the method of its analysis of its problems, and the NRC should reveal the standards it will apply in judging the Revised Rentart Plan.
identification of four root causes was "[b)ased on extensive investigation and review activities."
provides no further elaboration.
The Revised Restart Plan This statement provides no insight into the development process and raises obvious important questions.
Who performed the investigations and review activities?
consultants? Were the individuals employeeh or outside Can the Commonwealth secure the reports or field notes orW y
interviews of the individuals who identified the four "root causes" but no others?
not reported?
Were other root causes identified, but performed the review?What are the qualifications of the individuals who What methodology was used?
In PECO's previously rejected "Commitment to Excellence Management Analysis Company ("MAC") with the as y
In-House Management Review Team from PECO.
Plan does not specifically refer to this assessmentThe Revised Restart was developed before PECO acknowledged its co Because it The Commonwealth wishes to know the answers to these questions.
Although the Commonwealth has the fruits of the self-analysis, it must rely in part on the quality of PECO's self-analysis.
PECO must establish the basis for confidence in its work.
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For similar reasons, the Commonwealth is anxious to know the standards by which the NRC will judge the Restart Plan.
Although the restart does present several substantive hardware or technical issues, the major focus is on management problems.
But the NRC has not promulgated regulations to address these or related management issues.
In addition, the Commonwealth is unaware of any formal or informal NRC policy which addresses these types of issues.
Thus, the Commonwealth is interested to know what standards or criteria the NRC will or has applied to a Restart Plan after a facility is shutdown for management failures.
In addition, the Commonwealth is anxious to know if the NRC accepts PECO's analysis of root ceuses and the basis for this acceptance.
The NRC should identify the individuals, reports and studies undertaken in the course of its decisionmaking, Finally, the Commonwealth would like to know the role that INPO will play in the Peach Bottom restart.
The Commonwealth understands that the NRC will not begin its integrated inspection program for considering restart of Peach Bottom until after INPO is satisfied that PECO is ready.
In addition, PECO has referenced INPO or INPO documents or procedures in several
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1 areas of the Revised Restart Plan.
For example, PECO states that each shift operating team successfully completed a Team Training Course "demonstrating their full proficiency and cohesiveness as teams during the simulator training to the full satisfaction of INPO and NRC evaluators."
Because of the role apparen(Section II, p. 61, emphasis added).
tly accorded thfs industry group, the Commonwealth requests that the NRC describe its relationship with between the NRC and INPO which may relate to the issues at P
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Bottom.
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B.
The revised restart plan lacks the necessary degree of detail.
One of the principal problems with the Restart Plan is its excessive generality.
Throughout the Plan, PECO uses vague terms.
Words such as "timely",
"ade "effectively", "ensuring", "implementing",quately",
"establishing",
"maintaining", "excellence", "nuclear excellence" suggest standards whose satisfaction is often in the eyes of the beholder.
In particular, PECO's repeated dedication to maintain the "highest standards of excellence" requires elucidation.
Section 2.4 reference is made to standards of excellence in areas In of operations that are deli'eated by SALP and INPO evaluations.
n (Section I, p. 17).
Which standards?
Similarly, in Section 3.2 of the Restart Plan, PECO notes that the goals of its Nuclear 7
Performance Management Program will be developed after the first year.
(Section I,
- p. 37).
But PECO states that the Program will be fully operational within a year.
How can a program be fully operational before it has developed its goals?
Goals should be established now and standards of excellence can and should be defined (they may be different for different parts of the crganization).
The Restart Plan should do so.
Other areas of unacceptable vagueness are discussed in the specific comments section.
Perhaps the most significant are the Revised Restart Plan's statements that a "strehgthened commitment tracking program will be developed" and that (a) responsibility chart which conforms to the new nuclear organization will be developed." (Section I, pp. 43-44, emphasis added).
Such programs are crucial to the verification of the commitments.
At the Plan's present level of generality, and without completed description of programs to be developed and implemented, the Plan does not permit the Commonwealth to provide a full evaluation of restart activities.
C.
PECO must disclose further background information to permit proper analysis of the Revised Restart Plan.
A second factor inhibiting full evaluation of the Restart Plan, is the Plans failure to disclose sufficient background information to determine the Plan's viability.
Further disclosure is also necessary to assure full accountability, a self-stated goal of the Plan.
The most important area requiring further disclosure involves the culpability of individual operators and managers.
Disclosure of such information is necessary to know whether any individuals who were important figures in misbehavior will be involved in the future.
If they are, full disclosure is necessary to justify their continued retention.
(The need for this justification gains particular urgency in light of allegations that a cot was only recently removed from an area near the control room.
This allegation was made at the recent May 17, 1988 public meeting.) Disclosure is also necessary to understand completely the basis of the problem to develop a proposed solution.
Finally,'PECO must establish that prior unacceptable conduct received appropriate sanctions.
The NRC and PECO need to track this information.
The Commonwealth firmly believes that no lateral mo.ve within PECO is acceptable without full disclosure and examination of each individual's prior role.
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Even apart from evidence regarding individual culpability, further information regarding problems at Peach Bottom should be disclosed to' permit a full evaluation of the proposed Restart Plan.
Such disclosure is particularly necessary to permit evaluation of PECO's analysis of root causes.
Many materials are actually referenced by the Plan but not produced.
For example, PECO states in its Revised Restart Plan that, following the Shutdown Order Mr. Smith conducted individual interviews with every opera, tor.
Intensive interviews were also conducted by PECO's Claim Security Division v'th each operator and other shift personnel.
Information from tnese interviews and a signed statement given by each interviewee were made available to Mr. Smith.
(Section II, p. 58).
Neither this information nor the signed statements were included in the Appendix of the Revised Restart Plan.
The Commonwealth seeks access to these materials.
The Commonwealth understands that PECO's insurance agreements require it to make reports to its insurer regarding its operations.
If this understanding is correct, the Commonwealth wants to know whether PECO has provided any report regarding the circumstance leading up to and following the iscuance of the Shutdown Order.
If there are such reports, the Commonwealth wants to know whether the NRC or INPO have received copies, and the Commonwealth desires to have access to these reports.
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Finally, the most important source of information lies in that accumulated b Bottom's failures.y INPO in its intensive examinations into Peach an open, candid and cooperative relationship with.As part of PECO's com
. public agencies" (Section II, Appendix F, make this information available.
- p. 181), PECO should agree to requests:
In particular, the Commonwealth 1.
Copies of all letters, documents and other communication between the Philadelphia Electric Company and the Institute of Nuclear Power Operations regarding its investigations, reviews or evaluations of Peach Bottom.
2.
Documented status (including start dates and estimated completion dates) of all programs at Peach Bottom developed by INPO for its members.
3.
If PECO has failed to incorporate INPO-recommended programs, an explanation of why.
9
o 4.
Copies of the handwritten field notes of all INPO site visits or evaluations performed at Peach Bottom since 1984.
5.
Documented status of all actions (including start, and estimated completion dates) taken in response to'INPOL evaluations performed at Peach Bottom.
6.
PECO management justification for no actions being' taken in response to INPO findings during site visits.
7.
Access to and copies of PECO's Operating Experience Assessment Group's files, including all documented evaluations and a listing of all actions taken as a result of these evaluations.
8.
Copies of all investigations made by PECO the.NRC and INPO into licensed and non-licensed operations personnel misconduct and the conclusions of these j
investigations.
As a minimum, the investigations I
should establish when the misconduct occurred, the identity of the personnel involved, and the identity of the administrative personnel in charge during the period of misconduct.
9.
PECO's actions taken in response \\o the conclusions _and t
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recommendations contained in INPO.s letter of January 11, 1988.
10.
Any NRC files documenting the NRC's review of the handwritten field notes for all'INPO evaluations i
performed at the Peach Bottom Atomic Power Station.
11.
Any NRC files documenting the NRC's review of INPO documents pertinent to the Peach Bottom Atomic Power Station.
12.
PECO documentation of its completion of the Action Items committed to in NUMARC's "Action Plan For Meeting Industry Commitments Made Through NUMARC."
t D.
PECO should address three additional root causes.
Although a lack of adequate background information inhibits analysis, the Commonwealth has identified several additional root causes for the problems at Peach Bottom.
The first root cause insufficiently addressed is the lack of corporate and plant direction to encourage and protect 10 e tee.,.
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whistleblowers.
The NRC first learned of the serious charges of i
sleeping in the Peach Bottom Control Room and other examples of inattention to licensed duties, not from PECO employees, but from General Electric Contractors.
Section II of the Restart Plan rofers to a "Tell It To The Manager" program, which has reportedly produced over a thousand submissions.
This program is laudable, but insufficient.
Peach Bottom has at least two ongoing disputes with employees who claim that terminations or sanctions were the result of raising safety concerns.
PECO must reassess each of these disputes and provide convincing proof that sanctions were not related to whistleblowing.
PECO's proposal is also inadequate because it falls to establish a system of awards and fails to address protection for disclosure made to outside authorities.
The employee code of conduct should expressly state that the loyalty to the public health and safety overrides the allegiances to PECO or other employees.
PECO should establish a system of rewards for employees who make material disclosures either to upper level management or to outside agencies after failing to gain satisfaction from their immediate superiors.
A second, unaddressed root cause of the problems at Peach Bottom is the drain of qualified personnel from Peach Bottom to PECO's Limerick Power Station.
PECO should\\ identify this situation and evaluate what individuals and resources have been drained from Peach Bottom for use at PECO's Limerick Power Station.
Although the Plan now commits some Limerick personnel to Peach Bottom, it must guarantee against significant future drains and discuss any future plans for reversion.
Third, the NRC and PECO must address the problem of drug abuse.
In general, the NRC needs to expedite development and implement a Fitness for Duty proposal.
In addition, because such widespread drug abuse has been reported at Peach Bottom, the NRC and PECO need to provide further assurances above and beyond a
]
generic proposal that the individuals involved in plant operation and security at Peach Bottom will not be impaired by drug abuse, stress or other related problems.
A Peach Bottom site specific Fitness for Duty program should be implemented prior to consideration for start-up.
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E.
PECO should prove its reform by demonstrating a reanalysis c,f Significant Operating Event reports, vendor reports and issues raised by INPO reports.
Whatever tho merits of the Restart Plan, it is ultimately a piece of paper.
Paper plans csn at most show the potential for improvement; actual improvements must be verified.
Scrutiny of management improvenents, however, need not wait until actual restart.
Many managepent efforts, required to remedy the previous lackadaisical approach to safety, are scrutinizable now and they will indicate the strength of PECO's commitment to excellence.
For years Peach Bottom and all other nuclear power plants have received reports from INPO by mail or through the Nuclear Network.
These reports identify problems found at other plants or potential improvements in practices.
These reports include:
1.
Significant Operating Experience Assessment Reporta (SOERs);
2.
Significant Event Reports (S1'Rs);
3.
Operating Plant Experience Reports (OEs);
4.
Operations and Maintenance Reminde,rs (O&MRs);
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5.
Good Practices; 6.
INPO Program Reports developed and distributed to INPO member utilities.
These reports comprise an eight year old data base.
Peach Bottom is responsible for evaluating categories one through four for impact on plant safety and performance in a rigorous evaluation process established by INPO.
In light of the previously shoddy performance, PECO should reanalyze these reports to determine if proper responses were made.
to prove its commitment to excellence, and review of itsIt should demonstrate its re responses by the NRC and by the Commonwealth can help determine the quality of new management.
PECO shoi.d make copies of these reports available to the NRC and to the Lammonwealth and should open its files to permit this review.
For similar reasons, PECO should evaluate its existing VETIP program to demonstrate that its program has been functioning successfully.
If reports have not been arriving re should commit to upgrade and maintain this program.gularly, PECO Again, PECO should open its files to prove the validity of its program.
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Finally, PECO should solicit INPO to make available the field notes of INPO investigations.
These handwritten field notes tend to discuss problem areas in a more detailed and graphic manner than final reports.
Through a random sampling of problem areas, the NRC and the Commonwealth can determine if new management has addressed all problem areas.
III.
SPECIFIC COMMENTS The Commonwealth divides its specific comments into four categories:
and manpower; personnel, which includes qualifications, training intra-plant and intra-corporate relationships; new procedures and hardware issues.
A.
PECO should provide additional information regarding its personnel 1.
PECO should address certain concerns about its new management team Section 2.2.1 of the Revised Restart Plan (Section a.
II, p. 7
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Managemen)t Team. outlines the experience and background of the Plant This action addresses Root Cause 1 which identified a lack of personal leadership and management skills on the part of senior management at the pl' ant.
6).
(Section II, p.
However, Root Cause 3 also identifies "station culture, which had its roots in fossil and pre-TMI operation; that had not adopted to changing nuclear requirements".
42)
A review of the background of those identified as members (Section II, p.
of the Management Team indicates that some of these personnel seem to be from the very culture identified in Root Cause 3.
This culture was in part responsible for the Shutdown issues identified by the NRC in the Order to Shutdown, March 31, 19S7.
Although the Commonwealth does not consider prior involvement with PECO an absolute bar to continued managerial responsibility, former managers were presumably involved in fostering the prior culture.
PECO must establish the basis for their continued involvement by discussing their prior responsibilities and culpability for misconduct and by adequately justifying their retention.
b.
Section 2.2.l'further states that must have a high level of technical expertise... be able to"nuclear managers 13 f
develop and implement effective programs and management systems, be skillful...
managers of people."
(Section II, p. 7 But the i
Commonwealth cannot easily determine the extent to which)the Management Team meets these qualifications.
The Biographical Data for Peach Bottom Managers presented in Appendix B does not discuss the years of formal education and the specific technical.
- nd/or administrative degrees attained by each member of the
'3 Peach Bottom Management Team.
Nor is it possible to identify the specific number of years each team member has in a nuclear and non-nuclear supervisory or administrative capacities.
- Finally, the Plan does not provide a direct comparison between the skill level of plant managers and the personnel who report to them.
In order to inspect and provide adequate comment on the Pecch Pottom Management Team, the Commonwealth needs to have the folacwing information included in the biographical data provided for the Peach Bottom Management Team and for eny other Peach Bottom personnel mentioned by name in Sectici; I ad II of the Plan to Restart:
1.
A comprehensive breakdown of the formal technical and administrative education 0: quired and the specific technical and administrative degrees held ay each;
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2.
A chronological breakdown of the specific number of years each person has in a certain administrative or supervisory capacity with each beihg designated either as nuclear or non-nuclear; and 3.
A comparison of the skills with the technical responsibilities required by the job.
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The new management team, both at plant and c.
corporate levels, makes heavy use of employees with nuclear navy backgrounds.
The Commonwealth questions whether PECO is overrelying on this one source of training.
Naval reactor systems design, function and management are different than those at a civilian commercial nuclear power station.
A naval reactors function is propulsion; its design is for combat.
Everything from the design of the naval reactor core, the reactor protection system and hence its mode of nuclear power station. operation is different from a civilian Boiling Water ("BWR")
are different from their civilian counterparts, so is theAs the desig administration.
Naval reactors are managed in an environment where economics is a relatively minor restraint to design or 14
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The personnel who work on.and operate naval nuclear reactor systems are enlisted for a. fixed period of time and have little option but to do as they are ordered.
Those people who work at or operate a commercial nuclear power plant are salaried utility employes, union or contract personnel each of whom have the right to leave and who will not necessarily do as they are told by their management.
These opposing and sometimes contradictory factors may impede the management of Peach Bottom rather than_ promote or improve its performance until these managers have sufficient training and/or experience in the commercial sector.
The current standards in ANSI /ANS-3.1 (1987)
Selection, Qualification and Training of Personnel for Nuclear (Power Plants) recognizes the need to evaluate and factor nuclear navy experience.
(Table 1,
- p. 16).
The Commonwealth requests that the NRC or PECO evaluate whether PECO has placed too' great a reliance on nuclear navy experience and whether there is sufficient commercial experience in the management team to integrate or offset these experiences.
2.
PECO should address several concerns about its proposed plans for licensed operators The Commonwealth's comments on the plans for a.
changes in licensed operators somewhat track the comments about the new management team.
Of greatest importance is PECO's failure to justify the retention of previous operators without fully explaining individual culpability.
by IMPO, the NRC or PECO has been made public concerning theTo date no f activities and those responsible for the actions that led to the issuance of the Shutdown Order.
PECO proposes to determine the ' potential" for operators, wh apparently have been reassigned from control room duties, change behavior and attitudes "for reassignment to control room to duties" (Section II, p. 58)<
perform individual psycholog_ cal assessments.It has employed RHR, Inc., to provided oral findings, on which PECO has acted.RHR has in turn A few operators have apparently been terminated.
This procedural description is no substitute for an identification of the culpable operators and a reasoned justification for their continued employment.
Similar justifications should be provided for operators transferred to Limerick.
terminated, and the reasons for their termination.PECO should further 15 r1r y.---
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Even as a prc,cedural description, however, the Plan's description of tha psychological assessments is inndequate.
PECO should dicciose detailed information about the types of individual psychological assessments performed.
Finally, the use of oral findings does not produce confidence about the reliability of the testing.
Proper psychological assessments should be carefully presented and supported by evidence, b.
A second area of concern about the licensed operator proposals deals with staffing levels.
Section 3.0, addresses licensed operator resource development.
II, p. 35).
This section indicates that PECO has an(Section overall goal of 85 licensed operators.
At first glance, such a number seems sufficient to assure an elimination of planned overtime, which the Commonwealth considers a cause of the prior operator misconduct.
But PECO does not make clear how many operators of each type (SRO, RO, and AO) are needed per shift, per unit.
What would be the effect of non-steady state conditione, such as start-up and transient on the required number of operatore?
As important as the overall goal is the assessment of the present situation and the plans for restart.
How many operators does PECO currently have?
How many are in the training pipeline?
What is the schedule for securing additional operator training?
PECO should establish a minimum number of operators required to assure the elimination of planned overtime.'
PECO should not be permitted to restart until it has reached this quota.
Indeed, PECO's agreement to raise its goals for levels of licensed operators calls into question the Technical specifications in its operating license.
PECO claims that "shift I
coverage met safety requirements" presumably because they met Technical Specifications, but admits "there was an inadequate supply of licensed operator personnel to provide flexibility for relief or rotational assignments to handle the chift administrative workload effectively or to assure direct supervision of floor activity" (Section II page 35.
PECO has earlior admitted that its "total and zumulative reso)urce requirements have not been adequate? < considered when the company l
commits to new programs and other c<rrective actions".
(Commitment to Excellence Action Plan, Appendix A).
i The Commonwealth accordingly questions this claim of safety.
The shortage of operators was a root cause of the operator misconduct.
That PECO was in compliance with Technical Specifications when the NRC ordered shutdown only proves that the Specification number is inadequate.
16
9 The only reason not to amend the Technical Specifications to reflect the higher number of operators which PECO acknowledges is necessary for "effective" management is a desire to maintain the freedom to operate Peach Bottom with a lower number of operators.
Such a desire calls into question PECO's own announced commitment to excellence.
PECO should establish a minimum number of operators necessary for effective management and, by amending its Technical Specifications, commit to shutdown if, because of attrition or otherwise, its number of operators drops below that commitment.
The third concern with the licensed operator c.
proposals focuses on the proposed mix of operators.
The Restart Plan proposes a final total of 47 Senior Reactor Operators and 38 Reactor Operators (Section II, p.
38).
What was the breakdown of SRO licensed personnel and RO licensed personnel prior to March 31, 1987?
What is the current breakdown of SRO and RO licensed personnel at Peach Bottom?
In theory, senior operatcrs are more thoroughly trained.
But senior operators generally do not accumulate the actual control panel time of RO's.
If senior operators are created too expeditiously, with reliance on formal training for their qualifications, they may not be as familiar with the plant as RO's even though RO's look to senior operators for guidance.
The Commonwealth would like to know how many hours of actual "control panel" at power time each individual has or will have who is represented in the breakdown at Section II, p. 38.
d.
Finally, the Commonwealth wishes to understand further the reasons for PECO's failure to employ adequate levels of licensed operators.
The Restart Plan states (Section II,
- p. 36):
"Existing personnel policies and compensation practices related to the hiring of new employees were reviewed to determine what changes were needed to permit Nuclear personnel to be hired more promptly and at other than entry levels."
)
The Plan goes on to discuss, in somewhat general terms, the new policies.
To assure that those older policies are not reintroduced, the Commonwealth would like to know what previous policies prevented the hiring of experienced Nuclear personnel promptly and what was the source of those policies.
17 i
i j
i 3.
PECO should commit itself to abide by verifiable standards such as ANSI standards for all plant management and operators.
Although the Plan describes the background of new a.
plant management in general, the description does not permit a formal evaluation of their technical strengths ar.d weaknesses.
Nowhere does PECO comruit to any standards for its managers.
To assure that minimum technical standards are adhered to throughout the Peach Bottom organization, PECO should adopt a set of standards for its management.
The most carefully developed standards avat.lable are those established by the American Nuclear Society, as updated recently in ANSI /ANS-3.1-1987, "Selection, Qualification and Training of Personnel for Nuclear Power Plants."
At the time of this document's approval, a PECO representative chaired the Subcommittee ANS-3, Reactor Operations and Support Systems.
Furthermore, PECO was also represented on the American Nuclear Society's Nuclear Power Plant Standards Committee at the time of this standard's approval.
PECO should similarly commit to following ANSI standards for employment areas outside of management.
The organizational changes identified by PECO and the increase in the size of the work force neceasarily impact the Industrial Security Program at che Peach Bottom.
To make certain that ind'ustrial security standards are adhered to by the Peach Bottom organization, PECO should commit to the American National Standard Industrie.1 Security for Nuclear Power Plants, ANSI /ANS-3.3-1982 or.ts equivalent.
Because operaters have been a particular source of trouble, PECO should also commit to the American National Standard for Medical Certification and Monitoring of Personnel Requiring Operating License for U"clear Power Plants, ANSI /ANS-3.4-1983 or its equivalent.
Finally, because many of PECO's problems have
)
arisen from the failure to self-identify problems and to implement change, quality assurance will play a crucial role.
(Section I, Major Activity Numbers CA4-2.3.1, 4-2.3.2, 4-2.3.3, and 4-2.3.4, p. 66).
PECO should accordingly commit to ANSI standards for quality assurance, American National Standard Quality Assurance Program Requirements for Nuclear Power Plant Facilities, ANSI /ASME NQA-1-1986 (American Society of Mechanical Engineers, New York, New York), or their equivalent.
l 18 l! ___
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4.
PECO should elaborate on the nature of its training programs.
The Restart Plan laudably points to a variety of tralning programs and meetings to foster cultural change, to build team spirit and to inculcate management skills.
If these training programs are substantively meaningful and will continue, they are satisfactory.
Their description, however, is too general to permit a proper evaluation.
They leave the Commonwealth with many questions.
For example, the Plan reports that new managers have gone through four week training courses in managerial skills.. Are these courses a substitute for more formal management training?
Is additional management training planned beyond these courses?
PECO alludes to "services of organization development professionals to provide individual coaching to managers, facilitate management staff meeting and reinforce good management practices" as these are demonstrated in the industry.
(Section i
II, p. 52).
PECO should provide details about the professionals engaged to provide this service, their experiences in this area and their professional administrative background.
1 In Section 2.7.2 "Management Strategy" of Section I of the Plan to Restart, page 35, PECO statest g
)
"The Organization and Management Development staff is working directly with the Executive Vice President-Nuclear and his staff in an ongoing team development process which includes coaching on individual managerial competencies and managerial styles, teamwork, j
and organizational communications."
Such an undertaking suggests that a well-developed managemer.t training program is in place that goes beyond the training discussed in Section II.
The Commonwealth cannot constructively comment on PECO'n ability to effect management change without specific detail as to the management expertise, the management 1
courses being used, their content, and the basis for their content.
Finally, the Plan inadequately addresses training of l
off-site risk juriodiction emergency response agencies.
While 1
the organizational chart lists the Site-Training Superintendent j
as responsible for monitoring the "effectiveness of site and off-site training" and for coordinating "training for Emergency Planning", the supporting text on page 27 provides only a vague 4
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"communicating such information in a timely manner to corporate Nuclear Training for incorporation into off-site training programs."
(Section II, p. 27).
The Revised Restart Plan does not mention what group will conduct off-site training or whether these orograms will include persons other than PECO employees.
Similarly, the Function Organization Chart for Site Training Superintendents does not refer to of f-rdte training.
PECO should more specifically address plans for off-site training.
B.
The new organization threatens to hamper intra-company communications and does not guarantee sufficient independence or assure vigilant functioning of the i
independent assessment review groups.
1.
PECO's Plan to increase the size of management staff
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threatens intra-company communications una of the primary changes detailed by the Plan is a.
a doubling of the size of plant management.
Peach Bottom Plant Management Staff has been increased by 13 and Peach Bottom Line Panagement reporting through the Nuclear Group organization has been increased b presented, however, y 31 positions.
None of the Root Causes nor any of the corrective actions taken identify the number of management level pegsonnel as a problem.
Although size of management has not been a problem,. Shutdown Issue SD-8 identifies poor communications between different departments and divisions as a problem.-
By increacing management level personnel at Peach Bottom by 44 positions, PECO has increased the number of "cross-relationships" and therefore made effective communications more difficult.
jBut Manacino the Modern Orcanization, (3rd ed., Harrimann) and Nucleonics Week, Vol.
29, No. 19, at page 2, May 12, 1988.
The Plan does not addreas this increase in the complexity of communication.
PECO should address the problem of increased complexity caused by increased numbers of managerc and should satisfactorily explain why these increassi numbers will not impede the management goals.
)
b.
In addition to this overridinc aoncern with complexity, the Commonwealth has questions reganding neveral areas of intra-company relations.
First, the Commonwealth cannot discern from the organizati.onal charts whether many officials will be operating at the plant or corporate level and where their
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PECO should indicate their locations clearly.
The Commonwealth believes that the ISEG, OEAP and Performance Assessment functions should be located on-site at Peach Bottom.
PECO should also address whether financial and personnel controls have been changed.
The Commonwealth is concerned that problems at Peach Bottom had roots in the financial and personnel resources made available to the plant from the Corporate organization.
PECO should establish either that this concern is without merit or should alter the financial and personnel controls that served as impediments to proper management and operation of Peach Bottom.
PECO should also elaborate on its standards of accountability.
PECO's describes its first corrective action objective addressing Root Cause 4 as an intent to:
Change the organizational structure to improve control, accountability and corporate direction for nuclear operations.
Section 2.3 discusses organizational accountabilities.
- However, apart from a general reference to changes in disciplinary procedures, the Plan fails to address those actions that wi.1.1 be taken should management or employees fail to carry out their responsibilities.
(Section I, p.
10)
PECO should elaborate on any changes in disciplinary rules and set forth the results of employee failures to carry out responsibilities.
2.
PECO should address certain concerns regarding the functions and authority of review groups a.
The Corporate Boards:
NRB and NCB Because a cause of PECO's problems has been its inability to police itself, independent review groups will play a crucial role in Peach Bottom's rehabilitation.
PECO responsibly has identified two new review groups at the corporate management board levels.
Whether these groups will operate effectively or as rubber stamps, however, remains unknown.
An important variable in determining whether these groups will perform meaningful review is the frequency of their meetings.
PECO should delineate the frequency of NRB and NRC meetings and explain why th.ese meetings are sufficient.
PECO should also delicente the reports that will be provided these boards.
Statements in Section 4.0 of Part I that they will receive reports "on a regular basis" and "timely information l
21 l
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about nuclear operations" are not sufficient for the Commonwealth to draw constructive conclusions.
In addition, the sources of information for the NRB and NCB are crucial.
These boards should directly receive and review evaluations by ISEG, OEAP and the Performance Assessment Group.
Finally, prior membership on the NRB during the periods of mismanagement should be identified and evaluated to determine whether this prior involvement should preclude or limit an individual's current involvement.
b.
Independent Assessment Organizations: ISEG, OEAG and tha Performance Assessment Group Even more important than concern by the corporate boards is active oversight by those groups responsible for overseeing management performance and tracking safety concerns.
Under the Restart Plan, PECO will have three in place:
the Independent Safety Evaluation Group (ISEG), the Operations Experience l
Assesament Group (OEAG), and the Performance Assessment Group.
i i
These groups must reflect a self-contained commitment.
They must serve as watchdogs over the entire plant organizations.
These organizations should therefore not be line functions within
)
thu the Quality Assurance organization, for they should not be linited by reporting to an on-site manager These groups should in eract independently with each other and'with whatever levels of corporate management they choose.
They should have direct access, if necessary, to all corporate boards.
i Specifically, ISEG, the OEAP and the Performance Assessment Groups must be autonomous and:
I 1.
Have full access to any information they so desire.
2.
Have the right to attend any meeting of any group or organization they so desire.
3.
Have full access to any administrative level of any industry, government, or regulatory organization they so desire.
Because these groups operate as crucial watchdogs, should be chaired by experienced experts with proven trackthey records for independence.
The Restart Plan presently does not discuss chairmanship of these groups.
In addition, to maintain independence, they should not be staffed through rotations of other plant workers.
Although such rotations present the potential advantage that group members will know what requires 22 2--.
review, no member of a group should fear the resentment of colleagues upon return to the normal rotation.
The Operating Experience Assessment Program (described in Part I, Section 3.4, p. 34) is particularly inadequate.
Its l
description suggests that its main function will be "forwarding items as appropriate" and "consulting with relevant organizations."
The Operating Experience Assessment Program must be a strong independent Assessment Organization that thoroughly i
evaluates the information it receives and as necessary draws on the resources of the organization to supplement its own technical expertise.
The corrective actions issued by the OEAP should be backed by the highest officers to ensure compliance and immediate j
implementation.
)
C.
PECO should address certain concerns regarding its policies and procedures..
i The Restart Plan's "Progran to Gupport Procedural Compliance" operating pro (Section II, p. 69) refers to the revision of many cedures and to plans for many future revisions.
Obviously, the development of operating procedures is intricately related to the safety of the plant.
Because these procedure revisions are not explained, the Commonwealth cannot evaluate whether PECO's program is or will be successful.
To permit proper evaluation PECO should accordingly (dentify:
1.
The specific procedures (i.e. procedure number and title) that PECO plans to revise either immediately or over the next two year review cycle; 2.
The procedures it is committing to revise prior to restart and prior to unit startup; 3.
The current systematic method of flagging procedure changes; 4.
The methods of tracking prior commitments to be incorporated into a procedure during subsequent updates or changes; 5.
Current practices that ensure procedural accuracy and the timely updating of procedures, specifically The mechanisms in place to integrate and control a.
temporary procedure changes into the permanent procedure program, and 23 9
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The administrative controls on the life:of a temporary c'ncnge tx) a procedure;L 6.
The methods by which PECO controlled documents prior to establishing a document control center and its current; practice of document control.
D.
PECO must resolve various hardware conearns.
. 1 Although the primary issues involved in ther restart involve management, restart also presentszseveral hardware concerns.
1.
The most important hardware' issue involves'the_ integrity
~
of the Mark I containment-structure.
Many commentors have raised this issues at public meetings.
The Mark I coritainment was used -
as a model for WASH-1400, NUREG-ll50, and the %DCOR safety studies.
c" t
The NRC has yet to make a firm resolution.of this issue.
- i The Commonwealth understands that the NRC expects to issue a generic letter in August of this year requiring plants with Mark
. i I containments to initiate Individual Plant Evaluations' (IPE) of the problem.
In a case now before the United States Court of
)
Appeals for the Third Circuit, the Commonwealth has also i
contended that the Commission must determine the feasibility of l
severe core accident mitigation systems being installed-throughout Europe to lessen the impact of ai l
severe accident.
The NRC should determine the feasibility of severe core accident mitigation systems.
In addition, PECO should initiate its own IPE as soon as NRC requirements for the generic letter i
are known, probably sometime in June, 1988.
This would provide assurance to the public that the margin of safety for the Mark I containments at Peach Bottom are being evaluated and any enhancements necessary would be expeditiously undertaken'before restart.
Y j
2.
Other hardware issues at Peach Bottom raise lesser.
i concerns, but concerns sufficient to warrant comment.
At present i
Peach Bottom Unit 3 lacks sufficient capacity in the spent fuel pool to accommodate a complete core off-load.
l This could become i
an impediment to certain activities where a reduction in reactor water level is needed.
Unit 3 spent fuel pool to expand its capacity.The NRC has approved re-rac i
The completion of-this modification should be given a higher priority and expedited.
3.
leaks which cause an attendant increase in reactor coolantThe m 24 i
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conductivity.
This condition results in power reductions and transients.
A plan to repair or replace these condenser units should be included in the scheduled plant improvements.
4.
Finally, cracks have been reported in some shroud structures found in the reactor vessel.
Although these cracks may not present any risk to the public health and safety, PECO has elected to repair these cracks before any unit operations.
The Commonwealth would like this understanding affirmed by PECO management.
IV.
NEED FOR A LIST OF CLEAR, VERIFIABLE COMMITMENTS, AND A MECHANISM TO TRACK THESE COMMITMENTS A constant theme throughout these comments has been the need for clear, verifiable commitments.
Many of PECO's planned "corrective actions" sound good in general and even occasionally come with sufficient description to provide the flavor of the remedial actions, but are insufficiently specific to constitute i
1 verifiable commitments.
Indeed, it is unclear whether all planned responses are commitments or simply intended courses of Finally, PECO is generally ambiguous about which actions action.
it will take prior to restart and which only in the future, To assure that PECO's actions demonstrate the excellence
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sought by PECO's rhetoric, PECO must reduce'this plan to a series of clear commitments.
These commitments must then come attached with maximum time limits for their accomplishment.
Commitments must be of the kind that can be verified easily by overseeing e
f investigators.
These comments highlight many areas that require
)
j special attention.
In addition to reducing the plan to verifiable commitments, 3
PECO should insure both internal and external systems for
[
verification.
Internally, PECO pledges to develop an "effective f
commitment tracking program."
As discussed previously, this pledge is vague.
PECO must identify who will track commitments, i
t and with what authority they will act.
PECO must identify the remedial steps it will take if it fails to fulfill its commitments.
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Externally, PECO should involve the Commonwealth in its verification role.
Neither the performance of the NRC nor of INPO, to date, provides confidence that sufficient verification will occur.
The NRC was apparently unaware of many forms of misconduct despite its annual investigations and despite the permanent presence of an on-site investigator.
Awareness of control room misconduct ultimately came from plant contractors.
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The NRC should examine its inspection procedures to determine why much went undiscovered, se r.
INPO, on the other hand, was e,p Bottom's poor performance for years.parently aware of Peach Its reviews are more exhaustive than those of the NRC and are more sensitive to "soft" i
management issues.
Only through careful attention to day-in-day-out operational develognents that may not I
independently raise health and safety concerns can investigators 1
truly sense the patterns of mismanagement that do raise those concerns.
Unfortunately, although INPO has proven to be a careful inspector, it has also preiven to a timid prosecutor.
As an industry group, INPO has not surprisingly proved reluctant to expose the flaws of its members.
INPO's exposure of PECO mismanagement in January, while highly laudable and important, came years too late.
i Accordingly, the Commonwealth believes that proper verification that PECO fulfills its commitments should come from permitting Commonwealth representatives to be privy to INPO inspections and to have access to all information available to j
INPO inspectors.
PECO should use its influence with INPO to t
obtain such a role for the Commonwealth.
Commonwealth involvement will provide a more vigorous voice to INPO's watchful g
eye.
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I Respectfully submitted, i
f MOREY M.' MYERS U
General Counsel to the Governor
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Timothy D. Searchinger Deputy General Counsel i
to the Governor Richard P. Mather Assistant Counsel Department of Environmental Resources Date:
June 14, 1988 26
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