ML20212D640
| ML20212D640 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/15/1986 |
| From: | Matt Young NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Blake E, Jim Hickey SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| CON-#187-2054 CIV-PEN, EA-84-137, NUDOCS 8701020126 | |
| Download: ML20212D640 (34) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION DCCKETED o
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WASHINGTON, D. C. 20655 USNFC l
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'86 DEC 19 P2 :43 CFFf December 15, 1986 j,
Ernest L. Blake, Jr.
J. Patrick Hickey Shaw, Pittman, Potts a Trowbridge 2300 N Street NW Washington, DC 20037 BY HAND In the Matter of GPU NUCLEAR CORPORATION (Three Mile Island Nuclear Station, Unit No. 2)
Docket No. 50-310 (Civil Penalty) CIVNA/
Dear Sirs:
b Enclosed are copies of the documents produced by the..NRC in the 'above-referenced proceeding as identified in the "NRC Staff Supplemental Response to GPU Nuclear Corporation's First Set of Interrogatories and Request for Production of Documents," dated December 15, 1986.
Sincerely,
[
Mi
. Young Counsel for NRC Staff *
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- o DRAFT FOR MYSTERY MAN AFFIDAVIT C.-
' On pages 36-37 of my affidavit I expressed reservations at George Kunder's role as Plant OperatioJs Review Committee ("PORC")
,s and Safety Review Group ("SRG") chairman, in light of the significant 6
nature of those jobs and Kunder's performance during the TMI accident.
I also' disclosed that Kunder had been identified in discussions at Site Operations- ("SO') offices as the man who shut off the High Pressure Injection ("HPI") pumps.
This-portion of my affidavit was an extremely condensed
- introduction to iny ' concerns, both about Kunder's role in the cleanup r
and the events surrounding the damage to Unit II during the accident.
m.
Since investigators Meeks'and Vors\\ are investigating the issue this statement-will fully disclose -my concerns.
I am available for further
+
interviews with the NRC on the relevant underlying analysis.
Initially, certain statements from my affidavit must be clari-fied and presented in their proper context.
General Public Utilities Nuclear ("GPUN") -- in congressional testimony summarizing the pre-9 liminary findings of the Stier investigation for which it contracted --
attempted to rebut my discrosure by dissecting the literal meaning of individual phrases examined in isolation.
By expanding my dis-closure t bough this statement, this confusion should be eliminated.
4 For instance, Bernie Smith discussed Kunder's activities at the accident in much more general terns than Joe Chwastyk, who identified the safety injection pumps.
Further, the discussions about Kunder
. und the pumps involved several different actions -- shutting down the Reactor Coolant Pumps ("RCP") and the HPI, or safety injection pumps.; (The HPI pumps are also known as the makeup pumps).
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- The time-frame that-I recall Kunder being identified as the man who shut 'ekf the safety injection pumps was during March 1983.
v Earlier conversations involved his actions turning off the RCP's.
To the best of my recollection, the' specific language from DHWASTYK in March involved a statement that George " shut off the safety injection pumps."
' am not sure whether he also used the words " mystery man" in reference to Kunder.
My affidavit should not be read as a quotation in this respect.
I did intend to dis-close - the meaning of what I had heard, however.
It meant that, if true, Kunder was the " mystery man" written about in the press 4Ctadti op dee-4e the GPU - Babcock and Wilcox ("B&W") trial.
The trial and news accounts naturally were discussed on site, and the term had come up En discussions'at the SO office area.
.In addition to clarifying the details, I wish to remove any lack of clarity about my motives in raising the issue.
I do not and did not harbor any dislike toward Mr. Kunder.
We have had a professional working relationship since 1980 and only had hard feelings once.
That occasion was around last Christmas and I apologized to him within a few minutes.
My grumbling at the time was soon forgotten.
While I do not wish Kunder ill, I felt that his unique position in the TMI cleanup raised a serious question about management competence and/or integrity.
The PORC committee which Kunder led had the responsibility to review procedures, although final approval was through Larry King as S9 Director.
In this role Kunder and 1
. PORC still reported to the SO Director and was one of the resources for the department in TMI's checks and balances.
While I was sometimes irritated at delays, it was part of the job.
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When Kunder began to serve as SRG Chairman, however, his 1
qual'ilications assumed increased importance.
SRG would have more l
j legitimacy than PORC, because the members'would work full time.
. Mos t significant, in my opinion and detailed in another statement, SRG represented an illegal attempt to bypass SO without Nuclear
-Regulatory Commission approval.
The new committee would report to Mr. Kanga.
It could now be a resource to rebut the SO position, which simultaneously was stripped of the review base PORC rmerly represented.
This organizational switch to SRG occurred around the time pressure wqs building on SO to approve the polar crane and headlift procedures before our concerns and comments were properly addressed.
J Due to SRG's questionable legality and role motivation, the cleanup C
could be significantly compr[ sed if the chairman were not sufficiently objective and invulnerable to management pressure in order to provide j
an indepen, dent review.
In these respects, Mr. Kunder's record, especially at the accident, made me doubt whether management had good faith motives to place him in charge of the SRG.
To illustrate, Mr. Kunder did not appear objective.
He accpeted procedures from Recovery Programs ("RP") with cursory reviews but subjected the S0 efforts to unnecessary scrutiny on occasions, sugh as with procedures that I prepared and were eventual 13 approved for draining the "A" Steam Generator.
I felt that Kunder's quick approvals of inadequate headlift procedures could lead to safety hazards, while his meticulous reviews of other procedures created unnecessary burdens on well-controlled programs within the cleanup.
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I questioned management appointing Kunder to this position
~
in light bf his record at the accident.
My concerns about his appointment go beyond whether Mr. Kunder was the " Mystery Man."
At the accident he also followed procedures literally and shut off t
the Reactor Coolaitnt Pumps, although there were conflicting signals and indications that literal procedural compliance could be a mistake at the wrong time.
In short, I was concer'ned that during the accident Kunder did not see the forest t' rough the trees, and h
now he would continue that approach as ERG Chaihnan.
I sincerely J
believed that the role of SRG and the qualifications of its chairman were issues about the cleanup that needed to be raised. -
I also questioned Kunder's independence from management pressure, due to the events during the accident.
+
I was concerned' that KundEr would not feel sufficiently independent to challenge the management pressure surrounding the headlift.
He is vulnerable if he indeed was responsible for significant damage.
If Kunder is also the
" mystery man" he would be even more vulnerable.
My concerns about Kunder's independence were not just hypo-PaAC thetical.
I have disclosed specific questionable
- approval practices
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in my other statements.
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I knew that at the trial an analysis from EDS Nuclear, Inc.
was introduced to conclude that the HPI pumps were not turned on at 5: 41 A.M.
(the approximate time at issue in my affidavit).
I knew that this analysis was introduced *just before operators Zewe and Fredericks, who were among those reponsible for the HPI pumps, switched their testimony in conformance with the EDS calcula-Z Kdol THAT* TM Al tFbJSe77trD tions.' Operator Faust did not, however. OIhe EDS ana had de### ///.
K41beR unproven, incomplete and inaccurate assumptions, which make it ge f.fg(7//
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especially questionable as a basis to effectively rewrite the fff y 7pg god M4cy!
history or Sequence of Events already published by GPU and not yet amended, to my knowledge.
Finally, the trial was settled abruptly and unexpectedly shortly after the EDS report was introduced.
I knew of these developments and the mystery man, because as dis-cussed earlier the trial and its settlement was a common topic on site.
All of these events convinced me that the " mystery man" issue should be investigated thoroughly.
My own review of the EDS report suggests that its conclusions are premature.
Access to the relevant supporting data is necessary for more definitive conclusions.
My evalu:stion of the EDS report is based on the adequacy of its premise.
The analysis basically rests on the premise that the level of the makeup tank also deter-mined whether the second HPI pump, makeup pump "C", was initiated at 5:41.
EDS analy e and prepared graphs for the makeup tank e
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- m "othnt eovees surrounding two. times that it concluded HPI pumps were
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' initiated, at 4:02 and 7:20,, as well as for 5:41.
The graph for 5:41.did not exhibit the same characteristics. Although the EDS analysis is reasonable, it's significance is limited due to the see v; selective use of data and unjustified assumptions, all biased in favor of the EDS premise.
Th'ere are a series of questionable factors with re'spect to the EDS claim that turning on the HPI pumps at 4:02 accounts for the graph in its report.
In some instances the facts as reported
.are suspect.
For example, ED,S asserts that an operator started MUP 1-A and opened MU-VI6b at the time of the reactor trip.
But the Sequence 'of Events ffMNid reports that the evolution did n"t occur until 41 seconds after the reactor trip or 4:01:31 A.M.
j Similarly ED,S offers no citation for its claim that the BWST suction valve, DH-VSA, opened at 4:02:13.
This assumption also is not verified in the SOE.
In fact,. the Emergency Core Colling System (ECCS), which includes the HPI pumps, did not have to be turned on at all at 4:02 in order to produce the characteristics on the EDS graph.
Alternate AuAb E
3 sources better explain the increase in pressure.
EDS did not===1y ha whether the increase in pressure at 4:02 could have 'come from oepning the MUT Level Control Valve (MU-V-9 ) to refill the tank from the Reactor Coolant Bleed Tanks (RCBT),.instead of from the HPI' pumps.
This explanation would be consistent with the require-L.
ments in emergency procedure ~2202-1.3 for operators.
In other words,.EDS failed to consider the possibility that the operators l-l l '
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followed,tpe procedures at 4:02.
Similarly,.EDS failed to consider whether at 4:02 water was drawn automatically through the _ makeup level control valve,. again as an alternative to the HPI' assumption'.
These. alternative explanations are even more persuasive when the EDS assumptions.are compared with the capacity of the HPI pumps and the data provided by EDS.
The ED'S graph discloses a four inch rise (approximately 280 grams per minute) in the makeup
. tank during the 26 seconds from 4:02:13 - 4:02:39.
That is a sub-stantially higher rise than 'is achievable ' solely from HPI pump recirculation -flow.
Finally, even if EDS' assumptions and facts were accurate, th's results demonstrate that conditions.were not analogous at 4:02 and 5:41.
For instance, different pumps would have been involved.
At 4:02 the' A&B pumps would have been used.
At 5:41 the Asc pumps.would have been running.
The C pump can only draw from the BWST.
Even more' revealing, the 4:02 incident would have involved ed switching 1two pumps.
The 5:41 event would only have involved switching M on the C pump.
The EDS analysis.of events at 5:41 is no more definitive.
To illustrate, in some~ cases the analysis is incomplete.
On page 12 of
~ its report EDS states that upon ECCS actuation'DH-VSA was opened.
On page 13 EDS states that the injection valves MU-V-16A and. B also opened.- Unfortunately, the report failed to identify when 4
they were shut af ter 4:0.2 and plot the effectr on4 graph.
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, Ths EpS analysis :concerning 5:41 concludes that the BPI pumps could'not have been turned on at 5:4,1, since the makeup
- tank leve1 was only at 59l ~ However, EDS failed to analyse the special circumstances then in effect, such as increased letdown-flow, _ lowered reactor coolant system pressure, and higher tempera-tures than normal.
- Most persuasive, EDS' conclusions about 5:41 contradict other data in its report.
On page 16 of the report EDS stated that a makeup tank pressure of 39 [Uf would have been
.necessary to achievat the 59" level.
But figure 14 in the same report indicates that the 59" level was achievable with 31.5 $8, Finally, the EDS ' analysis of conditions at 7:20 assumes an Linitialmakeuptankpressureof27[(6 only nominal 3y higher i
[thannormal.
This assumption fails to analy a the severe effects 4
of 'the accident; which between 5:30 and 7:20 had led to superheated,
' steam and significant portions of the reactor coolant system 'in a steam-void condition by 6:00 A.M., to two-thirds of the reactor core uncovered by around 6:20, to hydrogen generation and half the reactor coolant system free volume in a steam hydrogen mixture by
. aroun4 7:00'd.M.
These conditions could well have led to abnormal
~
overpressurization due to steam and/or hydrogen in the top of the makeup tank, a possibility not considered by EDS.
I will cooperate fully with the NRC in answering specific I
questions in more detail about my assessment.
I am confident that my analysis can be expanded significantly if I can examine 1-the underlying data relied on by EDS.
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UNITED STATES
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u.s.Nac U83 SEP 13 #10 46 SEP 1 2 1983 ffFEE CfINVE3fSAT10NS F.EADQUARTERS NOTE T0:. Ben Hayes
SUBJECT:
. MEETING WITH LARRY KING AND JOE CHWASTYK 1The subject meeting was arranged through Larry' King's wife during a teTephone'
- conversation on September 6,1983.
discussed at the meeting despite several attempts to do so.I was unable to o I indicated
- during the initial-telephone conversation that I would consider the matter further and get back to her.
I sought the counsel of Mr. Dircks and Mr.
t Hayes before agreeing to this meeting and under what circumstances I should
'a gree.
After the discussion it was suggested I' meet these individuals and Mr. Hayes agreed to either-attend the meeting or provide someone from his sttff acceptable to King and Chwastyk.
~
I telephonically contacted Mrs. King to indicate ~ acceptance and suggested that Mr. Hayes ~ and I attend the meeting.
She. indicated that that was unacceptable that Mr. King wanted a meeting with
.me alone and perhaps if further meetings were needed Mr. Meeks would be an acceptable NRC representative to have for any further discussion.
The
. meeting was set for September 8,1983 at 11:30 p.m. at the Ramada Inn in Rockville... Maryland.
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The following notes document the various subjects discussed during the meeting ~although the purpose (s) was not clearly indicated throughout the discussion.
A.--
Mystery Man Issue.
In the course of casual conversation and a subject of current interest,
(
I. inquired of Mr. Chwastyk of his recall as to how the " mystery man"
~ issue evolved.
He indicated that it was unclear to them why an issue was being made of the " mystery man" and was aware that it evolved from
(-
the GPU/B&W lawsuit. He indicated that he did not believe that there
~
was a " mystery man" and conversations related to the subject involving himself were explained.
In particular, he indicated that Parks had overheard conversations in his (Chwastyk's) office when Mr. Kunder had sent an assistant to determine at what time the primary coolant pumps were turned off during the accident.
He responded in what he character-
~
. 1 zed as a disturbed and loud manner.
--Why is Kunder asking the question he was involved in turning off the pumps.-- He indicated that
. it was well known on the island that Kunder was involved in deciding to turn off the primary circulating pumps on the morning of the accident.
There was no mention during the conversation with Kunder's assistant l
about turning off the high pressure injection pumps. Mr. Chwastyk i
s.
O
~ s Myers, as he recalled during the spring of this year. indicated He indicated that the conversation was brief (about ten minutes) and that it was about
~
" mystery man."
He indicated confusion as to why he was asked to come to Washington to have a discussion since it was so brief and could have been handled by a telephone call.
brought up the mystery man issue and speculated that there were twoHe possible explanations (1) lack of understanding of the issue or (2) it may have been purposeful.
Y B.
Management Problems at TMI Both Mr. King and Chwastyk characterized a number of management problems that they had encountered while working for GPU.
From an overview he suggested that what they had been describir.; to me were management difficulties that arose as a result of incorporating the Bechtel Corporation into the mangaement structure at TMI. They both agreed emphatically that that was the basic cause of the mangement difficulty that they had experienced.
Examples were cited that it would take months or more of planning for GPU operations (both Chwastyk and King were in the operational part of the organization) to obtain permission to enter the reactor building.
They were frustrated by the organ-izational arrangement since they were responsible for TMI-2 operational aspects They found it strange that they would have to report to and 1
through Bechtel people to get their work done.
They indicated that th.e Bechtel organization itrelf was not consolidated in that Bechtel
~
personnel were drawn from the various offices from Maryland, Michigan and California and various key people within the Bechtel organization reported to different management structures.
This made it difficult for Mr. Kanga who is in charge of recovery operations of Bechtel to get the job done.
An example was offered during a meeting where someone was to have a task performed, the task was not finished but it was found that the task had not yet been initiated and the reason given was that it was an internal matter to that component of the Bechtel Corporation, that is, Bechtel managers were not able to hold subordinate Bechtel managers accountable for their work.
One meeting was described where Mr. Thiesing was rude and insulting to
'Mr. Kanga.
Again, both individuals are Bechtel managers.
I inquired as to whether or not GPU management (in particular Mr.
~
Arnold) was or should be aware of these particular problems and issues.
Mr. Chwastyk indicatect that he wasn't sure that Mr. Arnold was aware of the problem.
But in Other case, since it is GPU's problem to be aware of the problems; therefore it was in their view an unacceptable mode of mange-They further explained that there is little delegation of ment.
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authority to get a job done. _That much of the decision-is left for l
collegial decisions nede through committees which take an inordinate amount of timeLfor what (in their judgment).would appear to be a relatively routine matter.
any delineation of plant componentsI asked both gentlemen if they were aware activities.or areas for which
.Bechtel w
- tasks.. ould have the clear respons,ibility for completion of such
- defined particular; responsibilities.Both-indicated that they were. una
-n Mr. King volunteered only "was frustrated by the lack of authority,to get what~he b necessary to get the job-done.
4 Mr. King indicated that.he has~ become very frustrated with the mangae-
- ment people.and was considering leaving-GPU starting in January of this
- year and had discussed _this with Mr. Arnold at which time he suggested
_ that Mr. King should not' leave.and arranged for an offer of several Jb?
other-jobs.within GPU which Mr. King declined.
Chwastyk indicated that
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he really believed it was important to _ expeditiously clean up TMI 2 g $!
-. accident and prepare.it for either decommissioning or operation and was extremely interested in seeing this through; but because of the complex management structure he was working ~ under, he decided to leave the a
- King as'part of his Quiltec' Corporation. company'and did so in Augu a
C..
Possibilities of-Quiltec Working for the NRC
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- Toward the end of the discussion it became apparent tHit another purpose of the meeting was to have an opportunity.to inquire as to whether or
- not Quiltec could work under contract for the NRC.
s I indicated that the NRC-does indeed issue contracts for technical assistance and various
.research activities.
But I reminded him of the Conflict of Interest LStandards and that since Quiltec was working already on Shoreham this.
would be'a major problem.
It would be extremely difficult to work for
~
the industry and NRC and I suggested that it would not be possible to do both especially for a small company (about four people).
I told them that I understand that Shoreham and other utilities were actively l
- looking for and using individuals as well as consultants to help resolve problem but that they had to make a fundamental choice to work for the l
regulatory or regulated industry, but not both.
l had to think through what course of action they should follow and ifI suggested they wanted to pursue further with the NRC working as a consultant that
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they.might want to contact RES or NRR in a particular area in which they felt they.had expertise.
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in the industry because of his involvement and publicity that surrounded allegations related to various activities at TMI.
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W. J. Dircks, ED0 1.
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U.S. Department of Labor E':.p'cyment Standards Administration c**"",,
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Wage ano Hour Division
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Office of the Area Director f:
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Wilkes-Barre, PA 18701 (717) 826-6316 Repfy to the Attention of:
April.18, 9183 Office of Investigations, NRC EWS/434 Washington, DC 20555 Attn: James'Vorse
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Dear Mr. Vorse:
Enclosed is~a copy of a complaint filed by Richard Parks anainst Bechtel North American Power Corporation, at Three Mile Island. Mr. Parks allenes discriminatory employment practices in violation of the Energy Reorganization Act.
I have also enclosed copies of notification letters to the parties for your information.
Sincerely,
.},(. *L Ah.C m a
,j MICHAEL J.'CORCORAN Area Director
Enclosures:
Notification letter to Parks & Devine Notification letter to Bechtel & Charnoff Parks complaint Copy of Reg. 24 WH-1444 m
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U.S. Depsitment of Labor -
Emp:oyment Standards Administration Wage anc hcur Division f
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Office of the Area Director i
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Wilkes-Barre, PA-18701 (717) 826-6316 j.
Reply to the Attention of:
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April 26, 1983
- Office of Investigations, NRC
-EWS/434 Washington, DC 20555 Attn: -James Vorse-
Dear Mr. Vorse:
Enclosed is a copy of a supplemental comolaint filed by Richard Parks anainst Bechtel North American Power Corporation, at Three Mile Island. Mr. Parks
. alleqes discriminatory employment practices in violation of the Eneray Reorganization Act.
- 1. h~ ave also enclosed copies of notification letters'to the parties for your information.
Sincerely,.
MMM C m_ -
-MICHAEL.J. CORCORAN Area Director
Enclosures:
Notification. letter to Parks & Devine Notification letter to Pechtel & Charnoff Parks supplemental complaint CERTIFIED MAIL RETURN RECEIPT REQUESTED #636145 t
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U.S. DEPARTMENT OF LABOR Ornca or AoutwistaATIVs LAW JUDO 38
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IN THE MATTER OF RICHARD.D.. PARKS i-v.
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Case No. 83-ERA-8
'BECHTEL. NORTH AMERICAN POWER
-CORPORATION
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-NOTICE OF RECEIPT OF REQUEST FOR HEARING On'May 1.6,-.1983, this Office received a request for a hearing i
from Bechtel North American Power Corporation in order to review the Determination of Michael-J.-Corcoran, Area Director of the Employment Standards Administration, Wage and Hour Division concerning the g,
. complaint of' Richard D. Parks.
'A~ hearing on'this appeal shall be heard as soon as a judge from
-this Office is.available.
The date and time of the hearing shall be set as soon as possible.
All parties will be promptly notified of the hearing dat and time.
l EVERETIE E. THOMAS i
Deputy Chief Judge MM 10
-Dated:
Washington, D.C.
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,A SERVICE SHEET Case Name:'
Richard D. Parks Case No.: '83-ERA-8 Title of Document:
Notice of Receipt of Request for Hearing O!
I certify the.t a copy of t h $regoing document was sent to the kl&.V 18 28v following-on 5kl
~' Legal Clerk
. Richard D. Parks ~
Kennedy P. Richardson 14 Elmwood-V0P Bechtel. North American Power Middletown, PA '17057 Corporation P18-2493337-P.O. Box 480, Route 441 South Middletown, PA 17057 Richard k. Wheeler P18-2493350 Chief Start-Up Engineer Bechtel North-American Power Corporation 15740 Shady Grove Rd.
-Gaithersburg,- MD 20877-1454 P18-2493346 Thomas.Devine Legal Director Government Accountability Project
'1901 Que Street, N.W.
Washington, DC 20009 P18-2493347 Gerald Charnoff, Esq.
Attorney for Bechtel-Corp.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, DC-20036
^
P18-2493348 Nuclear Regulatory Agency Office of Investigations NRC EWS/434 Washington, DC 20555
. ATTN:
James Vorse P18-2493349
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UNITED STATES 9
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2 NUCLEAR REGULATORY COMMISSION a
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I WASHINGTON. D. C. 20585
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-4 March 2, 1984
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MEMORANDUM FOR: William J. Dircks, Executive Director for Operations 3;
FROM:
Ben B. Hayes,' Dire ~ctor.
Mffice of Investigations
SUBJECT:
0
' STAFF ACTIONS REGARDING OI--REPORT ON THI CLEANUP ALLEGATIONS Accordingly A. B.' Beach, Senior Reactor Engineer, OIE, Rog.er Walker, Chief, ProjectsSection II C, RIII, and Walter Rogers, Resident Inspector, RIII, (telephonically coordi'nat'ed), of your staff, carefully reviewed SECY-84-36 with the assistance of Eugene Gallagher of OPE. They documented their observations in a memorandum to me on February 24; 1984, which I-am including for your information (Attachment).
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Attachment:
-As stated
-Distributior.:
W I-s/f Case li-83-002-
"01 c/f-DW/19840I/StaffActions/TMI-
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Office :
I Surname: -B.'
es:dl Date 05/84 l
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February 24,1984
' MEMORANDUM FOR:; Ben B. Hayes, Director, I' A
FROM:
.R. D.. Walker, Chief,. Projects Section 2C, PIII
' A. B. Beach, Sr., Reactor Engineer, DIE
SUBJECT:
LASSESSMENT OF THE STAFF' REVIkW kND RESPONSE TO DI
! REPORT' ON THI-2 CLEANUP A!. LEGATION
^ 10n January 25,~1984 the staff provided the Comission its review of the NRC
- Office.of Investigations' (01) interim report entitled, "Three Mile Island
- Huclear Generating Station, Unit 2 Allegations Regarding; Safety Modifica-tions, Quality Assurance Procedures and Use of Polar Crane," dated September
.1, :1983.
.:Per your request, this.memoran_dum provides to you our assessment of the staff
- response and corrective actions to 01 findings.
W. R. Rogers, another technical member of the OI Investigation Team, was also consulted in the review of the matter involving containment penetrations.
- If fyou -need additional information, please~ contact us.
Enclosure:
As stated v
N R. D. Walker, Chief, RIII IO ene 0 A. B. Beach,~Sr. Reactor -
Engineer, OIE l
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Sunrnary of NRC Staff Review and Conclusions C
The staff' conducted a detailed revieu of the specific findings in the Office of Investigations (01) report that were the bases for their.overall conclu-
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-sions. The following summarizes the.' staff's findings as presented in SECY.
84-36 pertaining to the broad categories of procedural control violations
' end onsite management deficiencies that were. identified in the 01 report:
1)
The staff agreed with the OI report finding that ther.e had been
. instances of GPUNC using procedural controls that differed from GPUNC administrativ.e requirements.
.2)
The staff found that there were cases of quality assurance misclassifications, but the extent of the problem was less than that indicated in the OI report.
3). The staff agreed with the OI report finding that the administra-tive procedures training program was not adequate, and problems in consnunication between.various licensee organizations existed, h@
-4)
The staff agreed with the OI report finding that the licensee'd TW, QA/QC Department had not received proper management support to C)W4NG ensure adequate and timely resolution of QA-identified problems i
o during 1981 and early 1982.
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The staff determined that the position requiremen'ts for plant
. 'G manager and the assignment of responsibilities in the licensee's Organizational Plan were in accordance with the. Technical
. Specifications.
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The staff found that actions on the part of the NRC onsite-6 personnel facilitated the safety and promptness of the cleanup effort and did not contribute in any significent way to the licensee's management problems.
-7f ' The staff determined that modifications, to containment penetra-U tions were appropriately made in accordance with the THI-2 Tech-nical Specifications and NRC requirements.
I.. Assessment of Staff Conclusions L
L" The following provides our review of the staff characterization of the OI findings ~as presented in the September 1,1983 report-I-
.1)
The staff agreed with the OI report finding that there had been
. instances of GPUNC 'using procedural controls that differed from GPUNC administrative reiuirements but felt that none of these violations were safety-significant.
Assessmen i
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The staff found that there were cases of quality assurance ~
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The staff determined that the position recuirements for plant
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ensure adequate and timely resolution of QA-identified problems during 1981 and early 1982.
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The staff found that actions on the part of the NRC onsite' personnel f acilitated the safety and promptness of the cleanup effort and did not contribute in any significant way to the licensee's management problemse Assessment 4
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7)
The staff determined that modifications to containment penetrations were appropriately made in accordance with the TMI Unit 2 Tecnnical Specifications and NRC requirements.
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