ML20096F300

Urges Lifting of Two 1979 Orders Directing TMI-1 to Remain in Cold Shutdown Condition,Per 821130 Ltr.Util Has Completed Extensive Reorganization That Ensures Mgt Competence & Integrity of Safe Operation.Served on 840907

ML20096F300
Person / Time
Site:	Three Mile Island
Issue date:	09/06/1984
From:	Boyer V ATOMIC INDUSTRIAL FORUM
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20096F304	List: ML20096F300 ML20096F322
References
SP, NUDOCS 8409070384
Download: ML20096F300 (5)

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.. Atomic Indu;tri:I Farum,Inc.

' 71o1 Wisconsin Avenu2 Bethesda. MD 20814-4505 Telephone (301) 654 9260 TWX 71052496G2 ATC'.*dC FoR DC 5 D .a .sP  :

September 6, 1984 u; G~:ndU 1EP -.5 The' Honorable Nunzio Palladino ,_ 15 2 Chainnan  !;f L U.S.. Nuclear Regulatory ComissionSERVED SEP 7 E84 i Washington, D.C. 20555 #[b:s*

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Dear Chainnan Palladino:

The Atomic Industrial Forum's Comittee on TMI-2 Recovery sent a letter to your .

attention dated November 30, 1982, urging the Comission to lift the two 1979 orders that direct'IMI-1 to-remain in a cold shutdown condition until further order. A copy.of this letter is enclosed. The Comittee continues to maintain this position. A few of the activities that have been completed since November, 1982 and support our position are highlighted below.

\N By letter of September 2,1983, Mr. W.G. Kuhns, Chairman, General Public UtiIitiesi.

requested Admiral H.G. Rickover to perform an independent assessment of the sound-N ' ness of the GPU Nuclear organization. In his report of November 19, 1983, Admiral

\Rickover concluded that, "the Corporation has the management competence and integ-rity to safely operate'IMI-1."

In Admiral Rickover's follow-up-to his November, 1983 report, he indicated that l conpany officials had made substantial progress in addressing issues identified i-previously. He emphasized that these ' actions "give further evidence of their cm-l petence to safely restart and operate the plant" and recomended that the NRC no l longer delay a decision on the restart of TMI-1.

t Additionally, the capabilities of.the GPU Nuclear organization and personnel have

been reinforced by the in-depth assessment conducted by the ASLB as well as by l independent measurements by the Institute for Nuclear Power Operations (INPO) and by the NRC's Systematic Assessment of Licensee Performance (SALP). In the NRC b ~

Region 1 SALP eport dated Apri1 2, 1984, GPU Nuclear received the highest ratings on seven cate ries and satisfactory ratings on the remaining three. The NRC staff concluded that:\

"Overall, this assessment found that the licensee is continuing to devote con-siderable resources to improve performance in all areas of the organization.

Management attention in identifying and correcting weaknesses is apparent from licensee initiatives noted in the various areas reviewed. Management's comit-ment to safety is also apparent from their extensive comitment to personnel ' ~

training, the continuing efforts to staff the organization with highly teclini-cal, competent personnel, and the implementation of a stringent policy r'egar-ding procedural adherence."

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Chairman Nunzio Palladino September 6, 1984-In rupplement No. 5, NUREG-0680, "An Evaluation of the Licensee's Management Inte:grity as it Affects Restart of Three Mile Island Nuclear Station," published in July,1984, the NRC staff concluded that:

"There is reasonable assurance that GPUN can and will conduct its licensed activities in accordance with regulatory requirements and that GPUN can and will operate TMI-1 without undue risk to the health and safety of the public";

and "The Staff also has evaluated the ' managerial integrity' of several current GPU/GRJN officials and determined there is reasonable assurance that GPUN can and will meet its regulatory responsibilities with these particular individuals in positions related to those responsibilities."

In testimony on May 22, 1984, before the Subcommittee on Energy Research and Prod-uction of the Committee on Science and Technology, U.S. House of Representatives, Mr.-Philip Clark, President and Chief Executive Officer of GPU Nuclear Corporation, made the following significant points: -

- GPU Nuclear has more than 2,600 personnel of whom over 900 are applied full-time to operating and supporting 1MI-1. Over 500 are degreed professionals with a total of more than 2,800 man-years of experience in nuclear activities; The top four levels of management directly responsible for operating 1MI before the accident are no longer involved in GPU's nuclear activities. The President, the Executive Vice President, and seven of the eleven senior people reporting directly to the Office of'the President have joined GPU since the accident.

GPU Nuclear's Board of Directors has an outside Chsirman, Mr. John O' Leary, former Deputy Secretary of the DOE and former Director of Licensing of the AEC. Three additional outside Directors sit on the Board, including Dr. Warren Witzig, Professor and Head of the Nuclear Engineering Department, Pennsylvania State University. The Board of Directors collectively represents over one hundred and ninety man-years of nuclear experience.

Three of the outside Directors form a Nuclear Safety and Compliance Committee. This group has been provided with outside staff resources to assist in fulfilling its responsibilities. It reports directly to'the GPU Nuclear Board of Directors.

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Ch irman Nunzio Palladino September 6, 1984 We continue to believe that operation of TMI-1 will help alleviate the economic constraints currently affecting the timely cleanup of'IMI-2. In its third annual report, the Three Mile Island-Unit 2 Safety Advisory Board (SAB) concluded that, "the members of the SAB are unanimous in their opinion that TMI-2 does not cur-rently pose a significant risk to public or worker health and safety." However, the SAB " believes that public and worker health and safety are best served by the timely completion of the cleanup of 'IMI-2."

In conclusion, General Public Utilities has completed an extensive reorganization that has involved all levels of GPU Nuclear from the Board of Directors to the staff operating and supporting TMI-1. To our knowledge, it has provided a timely and detailea response to the NRC's questicas and concerns. It has been involved in-protracted and detailed reviews of its management capabilities, both by the NRC staff and outside parties. Based on the results of these extensive reviews, for the NRC to elect to prolong the review process any further, either by adjudicatory proceedings or additional. staff review, does not appear to contribute at all to the overall safe operation of the plant. Additionally, further delay will continue to bring into question the equitableness and strength of the regulatory process.

Therefore, we encourage the Commission to lift its two 1979 crders as soon as possible.

Sincerely,

.# j Vincent.S. Boyer Chairman Three Mile Island-2 Recovery Comittee VSB:tfm

. Enclosure cc: Comissioner Asselstine Comissioner Bernthal Comissioner Roberts Comissioner Zech w ,