IR 05000358/1979021
| ML19254E643 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 09/26/1979 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Bechhoefer C, Bright G, Hooper F Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7911020117 | |
| Download: ML19254E643 (1) | |
Text
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September 26, 1979 M
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- b Charles Bechhoefer, Esq., Chairman Dr. Frank F. Hooper Atomic Safety and Licensing School of flatural Resources Board Panel University of Michigan U.S. Iluclear Pegulatory Cormiission Ann Arbor, Michigan 48109 Washington, D.C.
20555 Mr. Glenn 0. Bright Atcmic Safety and Licensing Board Panel U.S. fluclear Regulatory Commission Washington, D.C.
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In the Matter of Cincinnati Gas and Electric Company, et al.
(Wm. H. Zimmer Nuclear Power Station, Unit No.1)
Docket ?!o. 50-358 Gentlemen:
Previously it had come to our attention that the Applicants may not have been accurate in their statements before the ACRS regarding staffing at the Zincer facili ty. The Office of Inspection and Enforcement investigated this matter.
We are enclosing a copy of this investigation (Reg. III, Report No. 50-358/79-21)
as a Board flotification for your information. The Staff will introduce this report as a part of the licensing proceedirg as a part of the Staff's assessment of Applicant's technical qualifications.
Sincerely, h
Ghd Charles A. Barth Counsel for f1RC Scaff
Enclosure:
As Stated
REGION III==
Report No. 50-358/79-21
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Docket No. 50-358 Licensee:
Cincinnati Gas and Electric Co.
Facility Name: k'illiam H. Zimmer Nuclear Power Station Investigation At: NRC RIII Office and at the Zimmer site
$/u.tft hb Investigator Peter E. Baci 7!30 !77 IE Headquarters
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Reviewed By:
Charles E. Norelius
'7[30/77 Assistant to the Director Investigation Summary:
Investigation on May 21-24, 1979 (Report No.
50-35S/79-21)
Areas Investigated:
Accuracy of Statements made by CG&E before the ACRS regarding staffing of the Zimmer facility.
Reviewed records and interviewed NRC and licensee personnel.
This investigation involved 32 manhours by one investigator.
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Results:
IE Staff and CGC personnel have differing views as to the clarity and accuracy of information presented tc the ACRS.
No items of noncompliance were identified.
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REASON FOR INVESTIGATION NRC inspectors believed that the licensee misrepresented the Zimmer staffing situation before the Advisory Committee on Reactor Safeguards (ACRS).
An investigation was conducted to determine the facts related to the licensees presentation and to determine if there was any intent on the part of the licensee to misrepresent the facts.
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SUMMARY OF FACTS On February 27, 1979, representatives of CGEE management appeared before an ACRS subcommittee in connection with the utility's application for a license to operate the William H. Zimmer Nuclear Power Station.
During the course of the meeting, the subject of plant staffing was addressed, particularly with regard to the adequacy and availability of back-ups for key supervisory personnel.
Responding to questions of the subco mittee chairman, the Zimmer Station Superintendent indicated that CGEE was developing a back-up capability within the staff on a "one-to-one rela-
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tionship as more or less second-line assistants to the principals." When asked if these individuals would have another job as well as being the back-up, he replied:
"No sir. Not necessarily, no sir.
That isn't what we had in mind.
In other words, if there is a staff member who is assigr.ed as assistant to the maintenance supervisor, that is his function, and he would act as an assistant maintenance supervisor."
Region III inspectors who had an ongoing concern with weaknesses and 1ack of depth of the Zimmer staff as documented in prior inspection reports and who were present at the subcommittee meeting, felt that the Superintendent's statements concerning staffing were misleading.
They interpreted the Superintendent's statements to indicate that a full time back-up was available for all key positions at the site which is at variance with the situation as they knew it to be.
This concern was brought to the attention of regional management and the decision was made to discuss the matter with the Plant Superintendent and request clarification of his statements.
On March 5-6, 1979 the inspectors visited the Zimmer site and met with the Superintendent.
After having the questioned portions of the transcript read to him, the Superintendent stated that he could see where they might be misleading and would discuss their clarification with CG&E management prior to the full ACRS meeLing on March 9, 1979.
The plant superintendent again discussed staffing before the ACRS meeting on March 9, 1979.
However he did not explicitly discuss the subject in terms of clarifying earlier statements.
It is his view that this presenta-tion satisfied the concerns raised.
It is the view of the Inspectors 1260 003
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involved that the matter was not clarified and that the licensee's statements to the ACRS on staffing were misicading.
h'o information was developed to show that there was any intent on the part of the licensee to mislead the ACES with regard to staffing of the Zimmer Plant.
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DETAI_LS 1.
Interview with Region III Inspector Terry Harpster On March 21-23, 1979, the Investigator interviewed Reactor Inspector Terry L. Harpster in the Region III Office in Glen Ellyn, Illinois.
Harpster explained that since being assigned to the Zimmer Station in October 1977, he had developed an increasing concern over the
' adequacy of station staffing.
This concern had been discussed with CG&E management on several occasions and was documented in inspection reports during March, August and November of 1978 (DN: 50-358, Report Nos. 78-06, 78-11 and 78-20).
Particular concerns were the ability of the existing staff to adequately conduct the preopera-tional test and start-up programs and the extensive use by CG&E of contract personnel for technical support.
The latter created a problem in that much of the experience and knowledge learned during the start-up and test program would be lost with the departure of the contract personnel. Another concern voiced by Harpster was the minimal involvement of the corporate staff in the pre-operational test prograo.
This continued until the formation of a mechanical
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engineering / nuclear section within the CG&E corporate structure formed to support site operations ~and which was subsequently moved to the site.
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Acccrding to Harpster, a meeting was held on July 13, 1973, in Bethesda, Maryland, to discuss weaknesses in the utility's staffing as it related to the Zimmer Plant.
CG&E was represented by Messrs.
Earl Borgmann, Vice-President / Engineering Services & Electric Production; Steve Salay, Manager, Electric Production; James Flynn, Licensing Manager; and Zimmer Plant Superintendent Schott.
NRC sas represented by Inspector Harpster of Region III and Messrs. Donald Skovholt,'
Walter Haass and Irving Peltier of NRR.
A subsequent meeting was held on September 21, 1978, at the CG&E corporate offices in Cincinnati with Messrs.
Harpster and Robert Warnick representing NRC and Messrs. Schott and Salay representing CG&E.
At this meeting, the lack of progress in augmenting the existing station staff was discussed as well as its impact on the preoperational test program, the operational preparedness of the station and the fuel loading date.
According to Harpster, particular concerns were the lack of a main ~tenance supervisor, lack of a reactor engineer who met the requirements of ANSI 18.1, the size of the station staff and the involvement of the corporate technical staff in the preoperational test program.
Harpster sta; 3 that on February 27, 1979, he and Inspector John Meaning attended the,.CRS subcommittee meeting on Zimmer as observers.
He stated that the Chairman, Mr. Bender, raised the question of the station's ability to provide adequate back-up support in the event of the loss of key personnel.
Superintendent Schott's reply indicated that alternate members of the station staff were being designated to-4-
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act as backup to key supervisory positions and that these people would not have other jobs.
Harpster stated that he understood that to mean these individuals would function as full-time assistants to the supervisors they were backing up.
He felt that Mr. Schott's statements were contrary to his knowledge of the staffing situation gained through inspections and discussions with cc:
,te management, including Mr. Schott.
At the close of the meeting
- cpster informed Irving Peltier (licensing project manager, NRR) t.wt he felt Schott's
, testimony did not reflect the true staffing situation at Zimmer.
Upon his return to Region III, Harpster informed regional manag-. ment of his concerns re Schott's testimony and the decision was made to have him travel to Zimmer and discuss the matter with Mr. Schott.
On March 5 and 6, 1979, Inspectors Menning and Harpster met with Mr. Schott and discussed their respective interpretations of Schott's testimony.
Harpr.cr informed Schott that he felt his testimony mislead the ACRS subcommittee since he was unaware that any formal contingency plan existed or was being developed such as Schott had described to the panel.- Harpster further told Schott that it was his opinion that adequate technical staff was not available to provide fulltime back-ups as described.
He asked Schott if perhaps
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there was information concerning this capability that he was not aware of.
According to Harpster, Schott said he had not intended to give the impression that such a plan had been implemented or that they had the personnel to provide full time back-ups for all key positions.
On the morning of March 6, 1979, Harpster was present while the relevant portions of the testimony were read to Schott over the'
phone by Rcbert k'arnich (Chief, Reactor Projects Section 2, Region III).
After hearing his testimony, Schott indicated to Harpster that he could see how it might be misleading, but that this was
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because he hadn't been prepared to address those questions in depth.
Schott then told Harpster that he would discuss clarification of his testimony with CG&E management prior to the' full ACRS meeting scheduled for March 9, 1979.
Harpster and Menning both attended the ACRS meeting on March 9, 1979.
Harpster stated that although the matter of staffing was discussed in depth, he felt that CGRE offered no clarification of its earlier misleading statements.
He advised regional management of his continued concerns and these were further reflected in a memorandum and statement of factr provided to IE/HQS on April 10, 1979.
Harpster stated that his primary concern was that while the Zimmer station staff might meet the minimum requirements of ANSI 18.1, the ability to provide adequate back-up for key supervisory personnel 1260 006
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was questionable.
Harnster's opinion is based on his inspection experience at Zimmer and on the minimal prior nuclear experience of the staff.
A copy of Inspector Harpster's written statement is appended to this report.
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Interview with RIII Inspector John Menning
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On May 21, 1979, the Investigator interviewed Reactor Inspector John Menning in the Region III Office in Glen Ellyn, Illinois.
'Menning described his knowledge of the Zimmer Plant staff situation as gained through periodic inspections of the facility from October 1978 to the present.
Menning's description of the staffing situation basically agrees with that of Inspector Harpster.
With Harpster, he attended the February-27, 1979, ACRS subcommittee meeting and heard the testimony of Station Superintendent James Schott relative Lo the utility's back-up capability for key supervisory personnel.
Menning felt that Schott's description of CG&E's back-up plan was not consistent with the utility's planned or existing capability as he knew it to exist.
He indicated that he and Harpster made this concern known to Region III management after their return and also discussed the matter with Mr.
Schott on March 5-6, 1979.
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According to Menning, Schott indicated that he had not intended to give the ACRS subcommittee the impression that the plant had established or was planning to establish a formal structured program for the development of fulltime back-ups for key personnel.
He told M<nning that he had only intended to communicate that individuals existed on his staff who could function as backups to key staff members and that if the transcript of the subcommittee meeting reflected otherwise, then a clarification might be in order.
At the meeting of the ACRS on March 9, 1979, the capabilities of'the plant staff were discussed, but Menning, who was present as an observer, felt that the matter of the misleading statements remained unresolved.
Along with Inspector Harpster, Menning expressed his continued concern to Region III management upon his return from the ACRS meeting.
A copy of Inspector Menning's written statement is appended to this report.
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Other Interviews with NP,C Personnel The following NRC personnel were also interviewed with regard to the matter under investigation:
James G. Keppler, Director. Region III Gen W. Roy, Deputy Director, Region III Charles E. Norelius, Assistant to the Director, Region III Robert Warnick, Chief, Reactor Projects Section 2, Region III Robert F. Heishman, Chief, Reactor Operations & Nuclear Support Branch, Region III 1260 007
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Those interviewed are all Region'III management personnel who were aware of the problem with the appaient misleading statements at the ACRS subcommittee meeting.
The concern of Inspectors Harpster and Menning was shared by Region III management and resulted in the instant investigation.
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Interview with James R. Schott
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On May 24, 1979, Zimmer Station Superintendent James R. Schott was
' interviewed by the Investigator at the plant site in Clermont, Ohio.
Also present during the interview were Thomas Vandel, Project Inspector, USNRC, Region III and W. W. Schwiers, Principal Quality Assurance and Standards Engineer, CG&E.
Mr. Schott was advised of the nature of the NRC investigation and provided a signed statement, a copy of which is appended to this report.
Mr. Schott discussed his testimony before the ACRS subcommittee and was aware of the fact that NRC had regarded some of his statements as misicading.
He stat a that Inspector Harpster had advised h.4, of KRC's concerns when he met with him at the plant site subsequent to the ACRS subcommittee meeting on February 27, 1979, Schott stated
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that after having the transcript of his testimony read to him by Robert Warnick (USNRC, RIII), he had initially agreed with Inspector Harpste: that his testimony could be misinterpreted and had agreed to discuss its clarification with his management.
He further stated that after reviewing the testimony and discussing it with management, that they had concluded that his original statements were correct.
When askee Lo clarify his earlier statements to the ACRS, Schott stated the CG&E was providing backup capability to key positions by designating alternate members of the technical staff to serve as,
backups for second-line supervisors.
He stated that this backup capability would be on a one-to-one basis, with Lackups serving as
"more-or-less second-line assistants t^ the principals."
Schott's testimony, in response to questioning from Subce-aittee Chairman BeLJer, indicated that the backup would not have another job in addition to being backup; further, that "if there is a staff member who is assigned as cssir. tant to the maintenance supervisor, that is his function; and he nuald act as an assistant maintenance supervisor." This was the aspect of Schott's testimony which the inspectors regarded as misleading, namely, that a fulltime backup did not exist and was not planned who would function solely as an assistant to the principal.
Schott explained that what he meant was that the backup would te a fullti.ne employee, worr.ing for the principal in the same area (i.e. maintenance, operations, rad-chem, etc.).
When queried about his statement that the individual would not have another job, his explanation was that he would not be working or have any responsibilities in another area.
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Mr. Schott stated that he presented a staffing chart to the full ACRS ceeting on March 9, 1979, which he briefly reviewed with the aid of an overhead projector.
He said that he felt hir presentation satisfied all concerns and expressed surprise and ire when he learned that NRC was conducting an investigation into the matter.
Schott felt that E. A. Borgmann's letter to Director 1:eppler,' date.d May 18, 1979, (copy attached) clarified the situation; but nevertheless provided in his statement a detailed account of the CG&E plan for ensuring backup for supervisory personnel.
It should F_ noted that Mr. Schott does not intend to formalize the backup p1 a he describes.
5.
Review of Records Documents The following records / documents were reviewed by the Investigator during the course of the investigation:
Inspection Report 50-358/78-06 3/22/78 Inspection Report 50-358/78-11 8/2/78 Inspection Report 50-358/78-20 11/17/78 Safety Evaluation Report - NRR 1/79
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Final Safety Analysis Report - Revision 41 - 3/78 American National Standards Institute Selection and Training of Nuclear Power Plant Personnel - N18.11971 A review.of the Inspection Reports cited above revealed a continuing concern on the part of NRC as to the adequacy of Zimmer Station staffing.
Comments from the inspection reports include:
"...the qualifications of the personnel selected for review will meet the minimum regulatory requirements prior to fuel load, however, the cumulative prior nuclear experience is
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minimal..." (#78-06)
"...the corporate technical staff need to gain a baseline familiarity with the facility systems to be able to adequately augment the site personnel's expertise..."
(#78-11)
"The size and limited experience of the plant staff would net be adequate to cope with the additional staffing problems created as a result of normal attrition of personnel during the startup and test programs."
(#78-11)
"Because of the heavy reliance on contracted technical support, much of the baseline knowledge and experience gained as a result of participation in the startup and test program would Icave with the contracted support personnel."
(#78-1]T
"We do wish to point out a potential staffing problem as it relates to the support of the preoperational testing program,
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vhich if not resolved in a timely manner could have a negative impact on the operational preparedness of the plant as equipment and management control systems are turned over from contractors."
(#78-11)
"We do wish to emphasize our concerns regarding station staffing and the status of the station, administrative, maintenance and procurement programa."
(#78-201 The NRR Safety Evaluation Report (SER) dated January 1979 states:
"We reviewed the qualification requirements for ;tation personnel described in Section 13.1 of the Final Safety e.aalysis Report (FSAR) and find they meet those qualifications described in ANSI-N18.1-1971."
In summary, the SER shows the qualification requirecents for station personnel meet the requirements described in the ANSI standards.
However, RIII inspection reports have expressed continued concern regarding the adequacy of the Zimmer staff.
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Attachments:
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Statement by T. Harpster 2.
Statement by J. Menning 3.
Statement by J. Schott 4.
Letter dated 5/18/79, Borgmann to Keppler
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STATEtiEllT I, Terry L. Harpster, Reactor Inspector, USNRC, (SS! 2G9-32-3338),
employed in the Office of Inspection and Enforcement, Region III, was contacted by Peter E. Baci, Investigator, USt1RC on 5/21/79 at 1:30 p.m.
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at Region III Office in Glen Ellyn, Illinois.
I was advised of the nature of the inquiry and make the following statement voluntarily.
I was assigned as the project inspector for the Zimmer Station in October 1977.
I developed an increasing concern regarding the adequacy of the station staffing at Zimmer a-documented in inspection reports during the months of fMrch, August and liovember 1978 (50-358/78-06, 73-11 and 78-20).
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The inmediate concern was the ability of the existing staff to adequately conduct the precoerational test and start-up programs.
A second concern was the extensive use of contracted personnel for technical support.
I'.uc h of the base-line knowledge and experience gained as a result of their part-icipation in the start-up and test program would be lost with their
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departure 5/23/79.
By this I mean that Zimmer station personnel will not gain the experience and training necessary for subsecuent plant opera-tions but that this experience and training will largely benefit only the contract personnel.
The third concern was the adequacy of the corporate technical support.
There was minimal involvement of the ct rporate tech-nical staff in the preoperational test program.
One specific area of concern was the lack of reactor instrumenta 'on and control systems expertise.
These concerns were discussed at various times with both the station management and CG&E corporate management (including James Schott, Station Superintendent, Steve Salay, f',anager, Electric Production and Earl A. cargmann, Vice President, Engineering Services and Electric Production).
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-2-A meeting was held on July 13, 1978 in Bethesda, Marland to discuss weaknesses in ti.e utility's organizational staffing.
The meetin'g was attended by CGLE management, URC Division of Project Management (NRR) cnd myself.
liessers Borgmann, Schott, Salay and Flynn (licensing manager) repre-sented CG&E.
Messrs, Don Skovholt (Assis" Director for Quality Assurance and Operations), Walt Haass (Chief, Quality Assurance Branch) and Irving Peltier (Licensing Project Manager) represented NRR.
A subset,uen meeting was held on September 21,.1978 at the CGSE corporate office in Cinncinnati.
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Attending were Messrs, Salay and Schott representing CGEE and Messrs Harpster and Robert Warnick (Chief, Reactor Projects, Section 2, RIII) representing NRC.
The 1 ck of progress in augmenting the existing station staff was dis-cussed with regard to its impact on the preoperational test program, operational preparedness of the station and the fuel load date.
Specific concerns were the lack of a maintenance supervisor, a reactor engineer who met the r1quirements of ANSI 18.1, the size of the station technical support staff, and involvment of the corporate technical support staff in the pre-operational test program.
In the period following these meetings and prior to the ACRS subcomittee meeting on February 27, 1979 an additional nuclear engineer was hired who met the ANSI 18.1 qualifications for reactor engineer.
This man was placed on site to augment the existing nuclear engineer until the existing nuclear engineer meets the ANSI 18.1 qualifications.
A mechanical engineerir nuclear section was formed by CG&E in the corporate office to su] port site operations and the entire staff was moved onto the site.
A quality assurance technician was contracted for to assist the station quality engineer.
The station training supervisor resigned and was replaced by contracted 1260 012
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help from the General Physics Corporation.
The station was still at this time without a meintenance supervisor.
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As'of the ACRS subcomittee meeting on 2/27/79 the scheduled fuel load date was June 1979.
On 2/27/79 John Menning and I attended the ACRS subcom-mittee meeting to review the application of CG&E for a license to operate the Zinner station.
We were not participants in the meeting but attended as observers.
In response to questions from ACRS members, Janes Schott (Station
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Superintendent) discussed the ability of the station to provide ademate backup support in the event of the loss of key personnel.
Subcommittee Chairman Bc der posed this question because of the apparent lack of depth in th1 organization.
In response to Chairman Bender's question Mr. Schott stated that alternate members of the station technical staff were being designated to act as back up to key supervisory positions.
In subsequent statements Mr. Schott stated that these people designated as backups would not have other jobs.
In other words they would function as full time assistants to the supervisors they were backing up.
These statements were contrary to ry knowledge which was obtained through my inspections of the utility staffing and my conversations with both station and corporate management.
Because I was not a participant, I did a'
bject to this testimony at the meeting but I did, however, infonn re iona, management of the substance of the testimony u
upon my return from the meeting.
Also, at the adjournment of the meeting I informed the licensing project manager, Mr. Peltier; that I did not believe Mr. Schott's testimony reflected what actually existed with respect to Zimmer staffing capabilities.
Upon my return to the region I discussed the testimony with my supervisor, tir. Warnick, and I proposed that I go to Zimmer 1260 013
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and discuss the testimony with Mr. Schott.
On March 5-6, 1979 John Penning and I went to the Zimmer site to discuss the testimony with Mr. Schott.
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John Menning, Jhm Schott and I discussed station staffing a'.d our re:;pective iriterpretations of the ACRS testimony.
Mr. Schott did not have available a transcript of the ACRS testimony so I suggested we call the regional office and have Mr. Warnick read the applicable portions of the transcript to Mr. Schott over the telephone.
1 informed Mr. Schott that it was my opinion that his testimony mislead the ACRS subcommittee in that I was unaware that anyformalcontingencyplAinasdescribedinthetestimonywasnowbeing
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developed to provide backups to key _ supervisory personnel.
It was also my opinion that adequate technical staff was not presently available to previde full time backups as described.
I 3uggested to Mr. Schott that perhaps there was information regarding staffing available that Johr. Menning and myself were not aware of as a result of our inspections and conversations with station management over the past year and a half.
Mr. Schott' indicated that he had not intended to give the impression that such a plan had been implemented nor that they had the personnel to provide full time backups for all key positions.
On the morning of March 6,1979, Mr. Warnick read the applicable portions of the transcript to Mr. Schott and'myself over the tele-phone on a conference box.
After hearing the transcript Mr. Schott indicated he could see hot, his testimony might be misleading.
He also indicated that this was because he hadn't been prepared to eddress those questions in depth.
Mr. Schott stated that he would discuss clarification of his testimony with his management prior to the full committee (ACRS) or. March 9,1979.
At that point I was satisified that the matter would be clarified at the full co= ittee meeting.
On March 9, 1979 John Menning and I attended the full 1260 014
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-5-committee meeting, again as observers.
The subject of staffing was again
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discussed in depth however CG&E offered no clarification of statements made at the subcomiittee meeting.
Upon my return from the full committee hearing I discussed the ACRS testimony with regional management and the decision was made to forward a statement of ' ;ts to IE Headquarters re-comending that ACRS be made that I viewed the testimony as misleading.
It is my concern that the Zimmer station staff, while meeting the minimum requirements of A!!SI 18.1, does not have the ability to provide adequate backup for losses of key supervisory personnel and that for a staff which
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has minimal prior nuclear experience this should carefully be considered when recomending the issuance of an operating licuse.
Since the ACRS recomendation is part of the licensing and hearing process, I fael strongly that ACRS is entitled to complete and accurate information both from the licensee and the f!RC staff.
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I, Terry L. Harpster, have read the above statement, consisting of 14 handwritten pages and it is true and correct to the best of my knowledge.
I have initialled all changes, additions or crrrections.
Furthernore, I am aware that this statement may be in a judicial proceeding.
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s/41 Reactor Inspector Date 1260 015 N
s/n/71 Investigator
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I, John E. Menning, Reactor Inspector, USNRC, (SS!! 297-38-0310),
employed in the Office of Inspection and Enforcement, Region III, was contacted by Peter E. Baci, Investigator, USNRC on 5/21/79 at 5:00 p.m. at the Region III Offise
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in Glen Ellyn, Illinois.
I was advised of the nature of the inquiry and mada the following voluntary statement.
My first association with the Ziceer staff was October 24 to 27, 1978 during which I initiated the inspection of emer-gency mair.cnance and operatin procedures.
This inspection effort was con-o tinued on February 13 to 15, 1979.
During these inspection visits I had contact with the principal staff in the operations, maintenance and instrument cor> trol groups at well as with the Plant Superintendent, Jim Schott and his
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assistant Paul King.
I observed during those inspections that there was no assigned maintenance :upervisor and that the assistant plant superintendent was attempting to perform the duties of that position.
I also noticed that
_lt'.ough tLe operations supervisor had a shift foreman assisting him, no one was formally designated as his assistant.
On Tuesday, I'ebruary 27, 1979, i attended an ACRS subco=nittee ses.cion, chaired by Mr. Bender, during which matters related to Zimmer Plant licensing were discussed.
I attended this session as an observer. During the course of testimony given by Mr. Schott I noted that statements relative to backup provisions for key positions wt e not consistent with the staffing of the plant as observed during my previous inspection visits.
More specifically, I was not aware that alternates had been designated for the key staff positions or that any plans had been made to give the alternates that the same training as the individuals who are being backed up or that finally, any individuals were functioning on a full-time basis as back-ups to key staff positions.
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During a subsequent inspection at Zimmer with T. Harpster on March 5,and 6,1979, Mr. Scho!.t was questioned about our understanding of his testimony before the ACRS subconmittee relative to capabilities for backup of key staff posi,tions.
During the course of these discussions, he indicated that it was not his intent to give the ACRS subcocunittee the impression that the plant had established or was establishing a formal-structured program for the development and training of full-time backups for key personnel.
He indicated that he only intended to communicate to the ACRS subcommittee that individuals existed on his staff who could function as backups to key personnel.
At this
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point Mr. Schott had n >L seen the transcript of the proceedings.
At this time hr. Schott said that if the transcript indeed reflected our understanding o the testimony (eine and Terry Harpster's), then a clarification of the record might be in order. At this point in the discussion, Terry Harpster offered to have R F. Warnick (Chief, Reactor Projects Section, R, III) call up Mr.
Schott and read the pertinent portions of the testimony to him.
In talking with T. Harpster, it is my understanding that this was subsequently done.
At the full ACRS committee meeting on March 9, 1979, although the capabilities of the plant staff were discussed, the utility representatives did not clarify statemente made to the subcommittee relative to backup capabilities for key staff positions.
I, John E. Menning, have read the above statement, consisting of five handwritten pages and it is true and correct to the best of my knowledge.
Furthermore, I am aware that this statement may be used in a judicial pro-ceede I have initir._d corrections and made any changes I desire.
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5/21/79
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1260 017 Witness: Peter E. Baci 5/21/79
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'I, James R.
Schott, Station Superintendent, CGLE Zimmer Station, P.O.
Box 960, Cincinnati, Ohio, 45203, was contcetea 01 3/24
/9 by Peter E.
Baci, Investigator, USNRC and Tom Vandel, Project Inspector, USNRC at 0815 at the Zimmer Station site.
I was advised cf the nature of this inquiry and made the following voluntary statement
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Following the ACRS Subcommittee Meeting held on Tuesday, February 27, 1979, I reviewed a copy of the Subcommittee transcript, specifically pages 120 thru 123, concerning station staffino.
This review Iesulted because Mr. Harpster, Region III Inspe tor, indicated that my testimuny was misleading in regard to our staffing plans, especially as the plans related to providing adequate backup personnel for key supervisory positions.
I reviewed and discussed this testimony with senior members of CG&E management and we concluded the statements were corr ect.
I further indicated to Mr. Harpster on separate occasions that due to the apparent probleus, I would clarify the issue at the full ACRS meeting.
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During the full ACRS committee meeting held on March 9, 1979, I presented a staffing chart and briefly reviewed it with the aid of an overhead projcctor.
Copies of the chart were also provided for each committee member.
I felt this presentation satisfied all concerns.pt5 I became aware that confusion and misunderstanding still existed early last week (May 15, 1979, or thereabouts) regarding the meaning of several of my statements.
I was informed that an intarview and statement nay be required to close this matter out to the satisfaction of all concerned.
I was concerned and-rather appalled at this approach, but we agree that all misunderstandings should be adequately addressed.
Mr. Borgmann's letter of May 18, 1979, to Mr. Keppler, Director of Region III, in my opinion, clarified the situation, but Mr. Baci, the I&E Investigator, indicated the suoject letter added confusion to what CGLE actually meant.
The following specific plans and intentions in the areas of operation, paintenance, I&C, rad-chem, technica.' and training should explain our position.
1260 018 1.
Operations - To provide a dedicated backup to the operations engineer, we intend to designate one of our senior shifc supervisors as a daytime " assistant".
This individual will not have concurrent shift or watch responsibilities, but will aide, assist, or perform other jobs as assigned by the Operations Engineer.
This man will function as the principal in his absence.
2.
Maintenance - A dedicated individual titled Maintenance Starf Engineer, has be_.
assigned full time to the Maintenance Engineer.
'n this area of responsibility, the principal assigns work activities such as engineering, advice, review, and assistance.
The Maintenance Staff A tt e c k n.ed 3
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Maintenance (cont'd.) - Engineer assumes the duties of
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the Maintenance Engineer in his absence and thus is the
" dedicated backup".
3.
I&C - Similar to maintenance, except the position has not been filled.
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Rad-Chem - Similar to maintenance except tv; engineering specialists have been assigned to the principal.
These
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individuals will receive experience and cross-training in the involved disciplines.
At this time, the senior individual would function as the dedicated backup.
5.
Technical - The technical staff is being expanded and present capability exists within this group to adequately back up the Technical Enginer.r.
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Trainina - A training Supervisor has been appointed.
This man is the dedicated backup to the Training Coordinator.
It is not my intent to indicate in writing, or include in individual ;ob descriptions, that the above named individuals are " designated backups".
I, Jamas R.
Schott, have read the above statement, consisting of 2 ')O typewritten pages.
It is true and correct to the best of my knowledge.
I have initialled any corrections or changes.
Furthermore, I am aware that this statement may be used in a judicial proceeding.
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/ James R.
Scnott Date Witnesses ('
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" Peter E.
Baca Date Investigator, USNRC
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Thomas Vandel
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Project Inspector, USNfC 1260 019 kW ask-h L 2.0-P1 W.W.
Scnwlers Date Principal Quality Assurance
& Standards Engineer
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THE CINCINNATI GAS & ELECTRIC COMPANY C
CI N C I N N AT I. O' 8 0 4 *.,2 Cr May 18, 1979 C. A. B O R G D4 A N P
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James' Director United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
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Dear Mr. Keppler:
I am uriting you concerning our telephone conversarton of May
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14 during which you indicated that Region III wished to interview.
some of our people further with regard to certain statements made to the Advi sory Committee on Reactor Safeguards (ACRS).
These statements apparently concerned our staffing plan and some con-
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flict between the statements made and our._ctual staffing inten-tions.
Obvioucly, I was quite concerned and looked into the matter promptly.
The facts in this matter from our standpoint are as follows:
Following the subcommittee meeting, Mr.
Harpster, your inspector, along with his supervisor, Mr. Larnick, telephoned Mr.
James R. Schott, our plant superintendent, and voiced his feelings to the e f fect that CG&E's plans with respect to backup personnel should be clarified at the full ACRS meeting.
Mr. Schott advised Mr. Harpst er that he had not seen the transcript out indicated that he had not tried to mislead anyone with his testimony.
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After Mr. Harpster's call to Mr. Schott, we reviewed the transcript of the ACRS subcommittee meeting of February 27 and concluded that we agreed with Mr. Schott's testimony concerning backup capability.
Apparently any problem stems from the discus-s io n of backup to operating personnel between Subcommittee Chairman Bender and Mr. Schott.
In essence, Mr. Bender was trying to assure himself that adequate backup would exist for each key s up'e rvi so r.
The~ maintenance supervisor was used as the example in the discussion which was prompted in part by the fact that our former maintenance supervisor had resigned.
What Mr. Schott stated was that backup capability would be assured at the second line supervisory level and would be full time.
Our intention is to have a dedicated backup for each of the following sections:
operating, maintenance, I &
C, rad-chem, technical, and training.
It was not our intention, however, to
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James Page 2 liay 18, 1979 necessarily give these backup personnel the title of " Assistant" per.se.
Both CG&E and Mr. Schott personally believe that' our inten-tions were clarified at the full committee meeting by describing the roles of the maintenance engineer and the other supervisors, including their support.
This was done through the use of a view graph and Xerox copies of the plant organization chart which were distributed to members of the committee.
It was not until your call that anyone at CG&E had knowledge that this matter hud not been fully resolved to Mr. Harpster's satisfaction.
I hope this letter now resolves this matter to the satis-faction of Region III.
However, in the event you wish to discuss the subject further with our personnel, we will be pleased to cooperate.
As you know, the pre-hearing conferences are scheduled for May 21-2 3 with the evidentiary hearing scheduled to begin on June 19.
For this reason, timely resolution of this apparent
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misunderstanding is essential.
Very truly yours, Ay_
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Borgmann Senior Vice-President
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1260 021
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