ML20214N258
| ML20214N258 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/26/1987 |
| From: | Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Jim Hickey GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| CON-#287-3598 CIV-PEN, EA-84-137, NUDOCS 8706020117 | |
| Download: ML20214N258 (14) | |
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NUCLEAR REGULATORY COMMISSION USMC 8
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May 26, 1987
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90CEETj.yiY,Q-ana; J. Patrick Hickey, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, D.C.
20037 In the Matter of-GPU Nuclear Corporation (Three Mile Island Nuclear Station, Unit No. 2)
Docket No. 50-320 License No. DPR-73 EA 84-137 (Civil Penalty)
Dear Mr. Hickey:
The Staff is forwarding to you a complete copy of a document previously identified by the Staff and sought in your February 4,1987 Motion to Compel (item 3, page 48).
By letter dated March 2,1987, the Staff noted that it had been unable to locate a portion of that document. The two missing pages have been located, and are enclosed with the remainder of the document.
With respect to the document identified in GPUN's Memorandum Concerning Pending Discovery Motions, dated April 6, 1987, at p.
32, item 3 and referred to by Judge Smith as having been misplaced (see Tr., at 142, 143)
("TMIPO Staff drafts of input to SECY-84-36 evaluation oTvarious OI findings of Parks' safety allegations"), we have been unable to locate this item.
Sin
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Counsel for NRC Staff
Enclosure:
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MEMORANDUM FOR:
THIPO Staff (Hg. and Site)
FROM:
Bernard J. Snyder, Program Director THI Program Office Office of Nuclear Reactor Regulation REVIEW 0F ALLEGATIONS BY I4R. P.ICHARD PARKS sun [ D. by
SUBJECT:
As ynu are aware, a Bechtel employee, Mr. Richard Parks, has transmitted a 56 page affidavit to the NRC, via a March 23. 1983
((he Government Accountability Project Devin 'aj.eSngla.irect0y L
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has alls sa, Preli inary review ofj affidavit by Lake Tom, Mike. and myself has 4
revealed no immedi_ ate safety problems.
However our office has the 7
obligation to carefully review all of @%'-,' allegations which may have a significance for safety of the THI-2 site, tintil we have concluded our review, I do not intend to approve,aTTakt n ger licensee proposals which
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have Connection with Roy of Mr. ParksX a 1ons.
For example, we will not take action on licensee submissions on the polar crane or Technical Soecifications ** hug ** "alatiac ta -the Safatv Ravfas G ra> >a.
Please bring to my or Lake's attention any other pending items which we should defer action until our review is satisfactorily completed.
Attached is a list of nine categories of allegations with specific issues identifled.j ext to each category I bcVe identified the individual who has N
.ne lead responsibility to conduct the review of that category.
Obviously, c hers may provide contributions to the lead in a given category where they have informa tion.
In carrying out this review, the following guidelines should be followed:
- 1. Our review is to be conducted strictly independent of any activities that GPU or Bechtel personnel may have underway.
By this I mean that we should directly access whatever infonnation may be available in their files, etc.
I have no objection to our discussing matters with licensee or Bechtel personnel, since that will obviously be necessary.
However, I do not want any of the NRC staff to be in the position of relying only on what the licensee gives them.
I will be sending the attached letter to GPU to infonn thera of what we are doing, in general tenns, and request their cooperation in making their records and personnel available to us, fg,
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2.
The results of,your review should be documented in a fonn that:
defines the issue - making specific references to 'the affidavit, blj summarizes what information you reviewed (sen item 3. below).
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I c) gives your bottom-line conclusions, d) provides your rationale for conclusions.
If everyone follows this fonmat, we can more efficiently review your work and aggre, gate ell imputs into a single report.
3.
In conducting your review, you should footnote to the specific refer-ences you utilized.
You should retain a copy of the reference, identified by category and sequentially numbered.
For example, references for the Polar Crane category would be identified as Ref. 4-1. 4-2, etc.
Keep a clean copy of each of these references so they can all be put together in one place when we are finished.
4 The schedule for completion of the review hy each individual will be C.O.S. Manday 4/4.
At that time, each of those identified on the attached list should provide completed input to either Lake or myself.
This is to be a high-priority effort.
However, we cannot neglect other assignments, especially at the site, which nust also be carried out concurrently to ensure we are meeting our responsibilities.
If you encounter a conflict between this review assignment and other tasks which you feel must be done to ensure public health and safety, bring them to the immediate attention of Lake or myself for resolution.
. As soon es your input is provided, Lake. Rick and I will review it and nake any requests to you for further input, if necessary.
We will pull together the entire package into a comprehensive report which I anticipate will be sent to the Comy.ission.
My target for completing the report is April 11 I appreciate that this will be a difficult task, with -a tight schedule.
I am certain that a good job will be done.
__ _ _ -. e &-=
Bernard J. Snyder, 'P'rogram nirector TMI Prog'am Office r
Office of Nuclear Reactor Regulation
Attachment:
As stated e
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- A LIST OF POSSIBLE SAFETY ISSUES RAISED BY HR. RICHARD PARKS IN HIS AFFIDAVIT OF MARCH 21, 1983
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Schedule Integration ko u.*8-0
- a. Page 5 - Paragraph 2 - What are the safety implications of not having an integrated schedule between the polar crane and the reactor vessel head MC&ecH.pu$qdeder o'
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cf the organization not following proper administrative procedures, i.e.,
without proper review of engineering paper work.
Many other items lille this throughout the affidavit.
- b. Page 8
.Page 9 (middle) - QA deficiencies identifie<i starting on Page 8 to the middle of Page 9 throughout the affidavit.
Allegations that organization did not comply with QA requirements.
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- c. Page 24 (top) - Is the Bechtel procedure CDPI 20 a violation of the OA program?
- d. Page 25 and Page 26 - Is the circumventing of the TWG in violation of NRC regulations relative to the QA program?
- e. Page 39 (top of page) - Are there any QA concerns regarding the items 4 % *3 %
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Reactor Building Sump bety
- c..' age 13 extending on to Page 14 Assumption of adequate bcren concentration '
in sump without Supporting criticality calculations.
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. Pol:r Crane
- a. Page 14 (middle) - Adequacy of loc'ai drop analysis of the pressurizer 3
missile shield.
- c. Pace 14 The adequacy of load drop calculations for polar crane testing.
- c. Page 17 - Is the polar crane SER as submitted by GPU acceptable? ^
- c. Page 19 -(top)
Was the submittal of the SER for the polar crane to NRC witnout site operations review a clear violation of tech, spec. 6.8.,27
- e. Page 20 (top) - Prom the public health and safety point of view is there anything wrong with the polar crane modifications not conforming to AP 1043 modifications control procedure?
- f. Page 21 - Paragraph 2 - Is Parks' first comment on the test procedure for the polar crane an'unreviewed safety qucstion or not?
- g. Page 25 - bottom paragraph - Have there been dissimilar replacements in"the refurbishment of the polar crane?
- h. Page 30 (bottom) Page 31 (top) - Is the load testing of the rigging for the polar crane adequate?
- i. Page 34 (bottom) - Does the alleged cutting back of the polar crane progra:::
from a 55 - 510 million program to a $2.5 million program have any safety significance? -
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- j. Page 34 - Paragraph 1 - Why isn't the polar crane cable safety grade and covered by QA/QC7 l
- k. Page 39 (bottom paragraph) - Has GPU reviewed adequately all of the crane testing and the results of that crane testing?
Furthermore, has MRC also I
I made similar reviews?
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- l. Page 40 - first full paragraph - Have dur:rny fuses been utilized in the crane test program?
If so', were we aware at them and if they were, are they safe?
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- m. Page 42 - What is the safety significance of requirement to test the length of cable that w,ill be required.fon the head lift as well.as the load testing of the test frama?
4
- n. Page 43 - Paragraph 2 '- Is ECMS 1017 a problem from the perspective of safe electrical protection,'for the polar crane?
- c. Pages 53, 54, 55 - boes the March 7 Snycer approval letter conflict with the March 10 procedural disapproval letter by Barret,t?
- p. Page 54 (bottom) - Is it correct that the March 10 note, referred to on the bottom of Page 54, contradictory to Sarrett statement that he could find no problem with the polar crane?
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- 5. Underhead Characterizat on g,,g9
- s. Page 16 - Concerns regarding the underhead characterization' SER on * (
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02 cay Heat' Pump g,,,j, /6/pp
- 4. Page 17 - The safety aspects of not testing the decay heat pumps, including the f act that no attempt has been made to decontaminate in A WO A b,
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3reething of Confidentiality /NRC's Of scussiens with GPU Employees /k;Ka
- s. Page 21 (top) Fage 20 (bottom) - Did 4RC breech the confidentiality ef.
the ciscussions that Mr. Parks h'ac with NRC site office people?
D. Page 29 & Page 30 (top paragraph) - What did the NRC say at che February 25 meeting with Mr. Parks?
- c. Page 43 Was the NRC discussicn with Mr. Parks on March 10 responsive to tne concerns that Mr. Parks was e.xpressing?
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8.
URC's Review of GPU Orafts/GPU Review of NRC Drafts 4, lLa.
- 4. Page 31. NRC's practice of reviewing draf t procedures in commenting back to GPU - is this appropriate or is this collusion?
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- . Page 55 - first paragraph - What is Barrett's practice with regard to',
submitting drafts to Arnold or Kanga for editing and coments as. stated I
on Page 55, first paragrap,h?
PORC Mndependent Review Group) Participation in Safety Reviews 9.
- a. Page 34 (2nd full paragraph) - Is the exclusion or ciscouragement of l
PORC members to participate in safety review meetings or technical review meetings. appropriate and consistent with maintaining health.
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and safety at the site?
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- I#' 14, 15, 16, 22, 28, S2 5, 24, 26, 30, 33, 34 Head Lift - Mrb L /G
, 42, 55, 56, 57, 58, 59, 6 7, 8, 10, 23 ewge 4#588 b4 Nh - Joel 17, 18, 38, 49 Administrative Procedu 25, 27, 41, 48, 51re M
Polat Crane - Poinde t x er 5, 37, 43' 44, 45, 50 I M - Joc1
, 53 54 32, 46 M E - J'd * /)f i 39, 40, 47, 62, 64
Open.Is_ sues from Parks Affidavit Items' 1.
GPU socrificed its system of safety-ralated checks and balances to meet time schedules.
(QA) 2.
Equipment modified without proper engineering analysis.
(ECM/UWI) 3.
Quality assurance steps have intentionally been shipped and totally circumvented.
(QA) 4 Rules and documents have been changed after the fact to justify QA violations.
(0A) 5.
These that defend normal checks and balances have faced pressure, intimidation, and retaliation.
(Reprisels) 6.
Many QA violations.
(QA) 7.
Significont. deficiencies with the program to remove the reactor vessel head and remove the fuel.
(HeadI.ift) 8.
Scheduler concerns.
Polar crane / reactor vessel head lift.
(Head lift) 9.
Work request CA258 was deficient.
(UWI)
- 10. No integrated schedule.
(Head lift) 1
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- 11. Plant systems and components modified without proper review of engineering
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paperwork.
(ECM/UWI)
- 12. ECM's not consistently being issued to accomplish plant modifications.
(ECM/UWI)
- 13. Plant management intentionally rude a decision to circumvent the site mndifications control procedure (AP 1043).
(QA)
- 14. Representatives of HLTF meetings not familiar enough with the UWI procedure, T.S., Site QA requirements to odequately develop and submit procedures.
(Training /UWI)
- 15. During initial review procedures UWI 4380-3054-83-R-02 and -03 were signed off by individuals not qualified for the task.
(UWI)
- 16. PORC chairman did not specify that the procedures UWI 4380-3054-83-R-02 and -03 should have NRC, QA/QC, Rad Engineering Manager of Pl. int Operations, and Plant Engineerinp review.
(Site Oper.itions Problem Repoet dated 2/24/03.)
(UWl) 17.
Input of site operations into Hl.TF meetings was not welcomed.
(Repressinn of comments)
- 18. HLTF taeeting minutes did not address all site operations conccens.
(Repression of comments)
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- 19. No OA/QC representation in the HLTF.
(QA)'
(QA)
- 71. Upper management had made a conscious decision to set aside design reviews of modifications performed after the occident.
(QA)
- 22. There is no provision for work packages in Unit II UW1 procedures.
(UWI)
- 23. fiot performing calculations for criticalit'y in the RB su.np and the D OTSG resulted in wo.rk, expert, and radiation exposure.
(Head Lift)
- 24. Threats by Barton to fire people.
(Reprisals)
(Administrative Procedures)
-26.
Rich Gallagher threatened to get Parks transferred off-site.
(Reprisaly)
- 27. General disregard for Admin Procedures by Theising.
(Admin Procedurcs)
- 28. CDPI-20 is used to control work by Hechtol.. (UWI) 79.
Procedure COPI-20 overrides QA controls on work and documentation.
(QA)
- 30. Jim Theising had Rick Parks replaced on 5/UT Test Supervisor Alternate.
The man who replaced him, Dwight Walker was not qualified.
(Reprisals)
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- 31. Frccmcrman indicated that dissimiliar replacements had been used in refurbishing t'ho polar crane.
(Polar Crane)
- 32. Recovery Programs position is that the shitt foreman shnold not control entry to containment.
(Operations) 33.
l.arry King had been fired for bringing up safety issues.
(Reprisals) 34 rd Gischel was being harassed by the Compar.y's stress control center for bringing up safety issues.
(Reprisals) 35.
Polar Cranc SER needs to include miscellaneous crane use and light load special shape load drop analysis.
(Polar Cranc)
QA/QC ir[volvcment was limited. (QA) 36.
- 37. Rigging not load tested.
(Polar Crane)
- 38. Meeting minutes did not include all the items discussed.
(Repressinn of commerts)
- 39. Collusion with NRC based on NRC revicwing procedurcs before they had all internal comments resolved.
(NRC)
- 40. NRC violated confidentiality of Parks.
(NRC)
[.
' 41.
Followup on the four suggestions on.jpplicabilit.y of AP 1043 ar.d AP 1947.
(Admin Procedure) t
- 42. liarassment of Joyce Wenger.
(Reprisels)
- 43. Cranc profcct cut from $5-10 million to $2.5 million without technical justification.
(Polar Cranc)
- 44. Why not inspect the crane cable.
(PolarCrano) 45.
Review safety classification of cranc.
(Polar Crane) 46.
Kunder does not want to get involved with Safety Issues.
(SGR)
- 47. NRC compromised Parks' confidentiality.
(NRC) 48.
Review five modifications that were not made pursuant to AP 1043.
(Admin Procedures) 49.
Not all items included in meeting minutes.
(Repression of Comments) 50.
Review open items on no-load test procedures.
(Polar Crane)
- 51. Was use of cranc on March 7, in violation of Admin Procedurcs.
(Admin Procedures)
- 52. Review use of dummy fuses and paperwork involved.
(ECM/UWI)
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- 53. Review Polar Crane maintenance and inspection checklist.
(Pofa'rCrane) 54 Review temporary power supply to Polar Crane.
(Polar Crane)
- 65. GPU trying to fire Parks by connecting him with Quiltec.
(Repriscis)
- 56. GPU threat against Parks family.
(Reprisals)
- 57. Bechtel management intimidation of Parks.
(Reprisals)
- 58. Apartment broken into.
(Reprisals)
- 59. Kanga warned Parks not to go public.
(Reprisals)
- 60. Removal of Parks from TWG for safety issues.
(Reprisals)
- 61. Review 11 QA violations.
(QA) 62.
NRC issucs draft letters to GPU.
(NRC)
- 63. Systematic attempts to circumvent adniinistrative and QA requirement.s for
, the Polar Cranc.
(QA) b4. NRC knowingly provided informal guidance and formal approval fer this misconduct.
(NRC)
- 65. Gross waste issues.
(?)
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