ML12023A085

G20120036/LTR-12-0018/EDATS: SECY-2012-0028 - Ltr., Rep. Jeanette Mott Oxford, Reactor Shutdown at Callaway - Questions on Followup to the October 2003 Incident

ML12023A085
Person / Time
Site:	Callaway
Issue date:	01/05/2012
From:	Oxford J State of MO, House of Representatives
To:	Jaczko G NRC/Chairman
References
G20120036, LTR-12-0018, SECY-2012-0028, EDATS: SECY-2012-0028
Download: ML12023A085 (16)

Text

EDO Principal Correspondence Control FROM: DUE: 02/16/12 EDO CONTROL: G20120036 DOC DT: 01/05/12 FINAL REPLY:

State Representative Jeanette Mott Oxford State of Missouri TO:

Chairman Jaczko FOR SIGNATURE OF : ** GRN ** CRC NO: 12-0018 Collins, RIV DESC: ROUTING:

Reactor Shutdown at Callaway - Questions on Borchardt Followup to the October 2003 Incident Weber (EDATS: SECY-2012-0028) Virgilio Ash Mamish OGC/GC DATE: 01/20/12 Leeds, NRR Wiggins, NSIR ASSIGNED TO: CONTACT: Burns, OGC Chang, OEDO RIV Collins SPECIAL INSTRUCTIONS OR REMARKS:

Ref. G20110648 (ML113220374).

EDATS Number: SECY-2012-0028 Source: SECY I Geea nomto Assigned To: RegionIV OEDO Due Date: 2/16/2012 11:00 PM Other Assignees: SECY Due Date: 2/16/2012 11:00 PM

Subject:

Reactor Shutdown at Callaway - Questions on Followup to the October 2003 Incident

Description:

CC Routing: NRR; NSIR; OGC ADAMS Accession Numbers - Incoming: NONE Response/Package: NONE IOte Inor ato I Cross Reference Number: G20120036, LTR-12-0018 Staff Initiated: NO Related Task: Recurring Item: NO File Routing: EDATS Agency Lesson Learned: NO OEDO Monthly Report Item: NO Ig Prcs gnomto I Action Type: Letter Priority: Medium Sensitivity: None Signature Level: RegionlV Urgency: NO Approval Level: No Approval Required OEDO Concurrence: NO OCM Concurrence: NO OCA Concurrence: NO Special Instructions: Ref. G20110648 (ML113220374).

Docmen Inforatio Originator Name: State Representative Jeanette Mott Date of Incoming: 1/5/2012 Oxford Originating Organization: State of Missouri Document Received by SECY Date: 1/20/2012 Addressee: Chairman Jaczko Date Response Requested by Originator: NONE Incoming Task Received: Letter Page 1 of I

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed:-Jan 20, 2012 10:40 PAPER NUMBER: LTR- 12-0018 LOGGING DATE: 01/18/2012 ACTION OFFICE: EDO AUTHOR: Jeanette Oxford AFFILIATION: MO ADDRESSEE: Gregory Jaczko

SUBJECT:

Questions regarding shutdown by plant operators at the Callaway plant ACTION: Direct Reply DISTRIBUTION: RF, SECY to Ack LETTER DATE: 01/05/2012 ACKNOWLEDGED No SPECIAL HANDLING: Made publicly available in ADAMS via EDO/DPC NOTES:

FILE LOCATION: ADAMS DATE DUE: 02/16/2-01]a. DATE SIGNED:

EDO -- G20120036

CAPITOL ADDRESS HOME ADDRESS State Capitol 2910 Lemp Avenue 201 West Capitol Avenue St. Louis, MO 63118 Jefferson City, MO 65101-6806 Tele: 314-771-8882 Tele: 573-751-4567 Fax: 573-751-2769 jeanette.oxford @ house.mo.gov MISSOURI HOUSE OF REPRESENTATIVES JEANETTE MOTT OXFORD State Representative District 59 January 5, 2012 Dr. Gregory B. Jaczko, Chairman United States Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Dr. Jaczko:

As you noted in your December 16, 2011 letter, on November 8, 2011 1 met with Anton Vegel and David Dumbacher of the US NRC Region IV to discuss the 10 questions I submitted to you on August 26, 2011 regarding the October 21, 2003 passive reactor shutdown at Callaway Plant.

My meeting with Mr. Vegel and Mr. Dumbacher was very productive, and I would like to thank your Regional Administer, Mr. Collins, for arranging the meeting. I would also like to thank Mr.

Vegel and Mr. Dumbacher for meeting with me.

At the meeting and/or in Mr. Collins follow-up letter, I was informed of the following regarding the events of October, 21, 2003:

1. It is the NRC position that prior to tripping the turbine, the NRC licensed operators at Callaway Plant operators were not aware the reactor would subsequently passively shut down due to a lack of steam demand and the buildup of Xenon-135. That is, it is the NRC position that the shutdown of the nuclear fission reaction around 10:18 am on October 21, 2003 was neither noticed nor expected by the operating crew. (It was also noted that "passive" is not a defined term, but that in this case it means a "natural consequence" of how the system was set up.)

2. It is the NRC position that as reactor power lowered five decades from the power range into the source range, the NRC licensed operators at Callaway Plant mistakenly believed the reactor was still critical and maintaining approximately 2% power. The licensed operators did not become aware that the reactor had passively shut down until the channel 2 Source Range Nuclear Instrument energized (which Mr. Criscione claims occurred at 1

11:25 a.m. based on nuclear instrument data but which the NRC believes occurred at 11:34 a.m. based on control room log entries).

3. The NRC's independent inspection and investigation efforts did not identify any information or testimony that would suggest that managers at Callaway Plant were aware that the reactor had shut down upon tripping the main turbine. However, Mr. Criscione contends that upper management should have been able to determine this by reviewing the control room log, which documented the Source Range Nuclear Instruments were energized at 11:34 a.m., and it appears that this is also the NRC's position.

4. The NRC did not attempt to ascertain whether or not the Operations Manager was in the control'room when the source range nuclear instruments were energized. The question of Dave Neterer's presence or absence was not seen as relevant to the safety of the reactor.

This remains of great concern to me. I believe the Operations Manager should have ensured that the events of the day were documented with a condition report given the following:

• the operating crew first recognized that the reactor they had been monitoring had inadvertently passively shut down over an hour earlier;

• the operating crew decided - with no formal calculation - that Xenon- 135 could be relied on to prevent the reactor from inadvertently restarting while they continued aligning steam plant equipment for shutdown operation and while they commenced a minipurge of containment; and

• the operating crew decided that operating in the source range with the control rods at their last critical rod heights was acceptable.

5. It is the NRC position that the actual safety significance of the event was not impacted by whether or not the operators either had actually performed a formal calculation determining that acceptable levels of Xenon-135 would continue to exist to prevent a reactor restart or were merely making assumptions regarding xenon levels when they decided not to immediately insert the control banks upon recognizing the reactor was in the source range with the control rods at their last critical rod heights.

The five items above are not direct quotes, but rather my understanding of the November 17, 2011 letter from Mr. Collins. I have copied Mr. Collins on this letter and would appreciate it if he would review the five items above and correct any misperceptions I might have regarding the NRC's position.

On September 17, 2010, Mr. Criscione submitted a IOCFR2.206 petition to the US NRC. He requested that the NRC issue a demand for information to Ameren to get answers to some questions regarding the testimony of Shift Manager Dave Lantz to the Office of Investigations and regarding the role which Operations Manager Dave Neterer had in the shutdown. The NRC rejected Mr. Criscione's petition. It is not clear to me why it is not important for the NRC to have answers to Mr. Criscione's questions. Enclosed with this letter are some of the questions which Mr. Criscione would like answers to. I would appreciate it if the NRC would review the 2

questions and for each one either provide a transparent answer or provide an explanation as to why the question is not relevant.

I would like to note that, although Mr. Criscione's September 17, 2010 10CFR2.206 petition was rejected due to procedural reasons, there is nothing which prevents the NRC from submitting a Demand for Information to Ameren to gain an acceptable understanding of what occurred on October 21, 2003 at Callaway Plant. The Office of Enforcement could issue a 10CFR2.204 Demand for Information to Ameren asking some or all of the questions which Mr. Criscione suggested in his petition.

At a minimum, I would like the Nuclear Regulatory Commission to transparently (i.e. beginning with a "yes" or a "no") answer the following two questions:

" Is it the NRC's position that the Shift Manager at Callaway Plant for the October 21, 2003 passive reactor shutdown (i.e. David Lantz) was honest and forthright with the investigator when he was interviewed under oath on April 1, 2008?

" Is it the NRC's position that they have no regulatory concern as to whether or not the Operations Manager (David Neterer who is now the Plant Director of Callaway Plant) was in the Main Control Room at 11:25 a.m. and was aware that the operating crew had inadvertently allowed the reactor to passively shut down, yet took no action to ensure the.

control rods were immediately inserted and to ensure the incident was properly documented?

If neither of the above questions can be answered or if the answer to either of them is a "no",

then I would like transparent answers to the questions in the Enclosure to this letter so I can understand where the NRC's comprehension of the incident differs from Mr. Criscione's.

Again, I would like to thank Mr. Vegel and Mr. Dumbacher for coming to St. Louis to meet with me. I believe we are making significant progress in the transparency of the NRC's positions regarding this incident.

Sincerely, Jlt2 oitt Oxfr Enclosure (23 pages)

Cc: Elmo Collins, Regional Administrator, US NRC Region IV Lewis Mills, Missouri Public Counsel Tom Voss, Ameren David Lochbaum, Union of Concerned Scientists Ed Smith, Missouri Coalition for the Environment 3

Questions

§1 Procedural Guidance for Allowing the-Reactor to Passively Shut Down In his April 1, 2008 testimony to Crystal Holland, Dave Lantz made several statements indicating that he intentionally allowed the reactor at Callaway Plant to passively shut down on October 21, 2003 and then intentionally relied on an informal estimation of Xenon-1 35 levels to ensure the reactor stayed subcritical. For the context in which these statements were made, please see the transcript pages from which these statements were taken that are provided at the end of this document:

1. And, you know, we're going to go subcritical,but we're not planning on staying online, anyway. So we'll just continue on with the shutdown from this point. (page 11, lines 12-14)

2. The shutdown was ongoing the entire time. The control rods remained stationaryduring that course in time. But Xenon poison was continuing building, so the shutdown was progressingwhether those rods were moving or not. As soon as we tripped the turbine offline, we no longer had any steam demand to maintain a set power. And Xenon, which is.a poison, was continuing to build in, in the core, which was causing the reactor to shut down. We had a negative startup rate during that entire period of time. So the shutdown was never stopped. (page 13, lines 1-13)

3. So when I made that direction to him to have the turbine taken offline, in my mind, that was going to initiate the reactorshutdown, because of the continual buildup of poisons andnot having a steam demand on the reactoranymore. So that's really, in my mind, what the reactorshutdown - where we had made the decision to start that. There was no turning back at that point. (page 17, lines 17-24)

4. There was a short delay where rods weren't moved, but the reactorwas continuing to shut [down] during that entire time frame. (p. 56 line 25 and p. 57 lines 1-3)

Request 1.1: It appears that in statements 1, 2 and 3, Mr. Lantz is stating that his crew intentionally shut down the reactor by removing steam demand (i.e. tripping the turbine while average coolant temperature was 50 F below the lift point of the condenser steam dumps) and allowing passive affects to take the reactor subcritical. Please provide me the NRC position regarding their understanding of Mr. Lantz's testimony. Is it the NRC's position that in his April 1, 2008 testimony Mr. Lantz is claiming he intentionally shut down the reactor by removing steam demand? If not, what is the NRC's position on what Mr. Lantz was indicating by his statements on lines 1-13 of page 13 of his testimony (provided above)?

Request 1.2: It appears that in statements 2 and 3, Mr. Lantz is stating he intentionally relied on an informal estimation of Xenon-135 to maintain the reactor subcritical. Please provide me the NRC position regarding their understanding of Mr. Lantz's testimony. Is it the NRC's position that in his April 1, 2008 testimony Mr. Lantz is claiming he intentionally relied on an informal estimation of Xenon-135 levels to maintain the reactor subcritical during the 106 minutes (between 10:18 am and 12:05 pm) that the reactor was shutdown with the control banks still at their last critical rod heights? If not, what is the NRC's position on what Mr. Lantz was indicating by his statements to the 01 investigator?

Enclosure (23 pages)

Request 1.3: Please provide me the NRC's position as to whether or not the Reactor Shutdown Procedure (OTG-ZZ-00005) at Callaway Plant allows the operators to intentionally conduct a reactor shutdown by removing steam demand and allowing passive affects to take the reactor subcritical? Was there any procedural guidance at Callaway Plant for conducting a reactor shutdown by removing steam demand and waiting for passive affects to take the reactor subcritical? Since the Shift Manager recognized that passive affects (i.e. an increase in average coolant temperature and an increase in Xenon-1 35 levels) were going to cause the reactor to shut down, what is the NRC's position as to the reason the control rods were not manually inserted to actively ensure the shutdown occurred?

Request 1.4: Please provide me the NRC's position regarding whether or not in line 1 of page 57 of Mr. Lantz's testimony, when he says there was a "short" delay where rods weren't moved, the NRC believes he is referring to the 106 minutes between 10:18 am (the time when letdown flow was restored and the off-normal procedure was exited) and 12:05 pm (the time when the operators began inserting the control rods)? Does the NRC view the 106 minute delay for inserting the control banks as a "short" delay?

§2 Training at Callaway Plant regarding "conservative action" In his April 1, 2008 testimony to Crystal Holland, Dave Lantz discussed training he had received on the need to take "conservative action" in responding to reactivity transients. For the context in which this statement was made, please see the transcript page at the end of this document:

And the forefront of our - of all our actions were to do things conservatively, and that's the primarydriver that I directed the turbine trip, was to conservatively shut down the turbine in response to a temperature excursion. And I've had years of training that that's the right thing to do in response to an issue like that, take conservative action and addressit and don't try to chase it with reactivity. So that's what we elected to do.

Request 2.1: Please provide me the NRC's position as to whether or not in the formal training of NRC licensed operators it was ever taught that it was acceptable to shut down a reactor by allowing passive affects (i.e. Xenon-135 buildup and core temperature increases) to cause the reactor to go subcritical when active means (i.e. control rods and boron) were available to drive the reactor shutdown? During the 106 minutes that the reactor was shutdown with the control rods at their critical rod heights, was it a "conservative action" to rely on an informal estimation that Xenon-1 35 levels were sufficient to prevent the reactor from becoming critical?

Enclosure, page 2

§3 Response to Off-Normal procedures In his April 1, 2008 testimony to Crystal Holland, Dave Lantz made several statements indicating that the performance of "off-normal" procedures substantially contributed to the 106 minute delay in inserting the control banks. For the context in which these statements were made, please see the transcript pages from which these statements were taken that are provided at the end of this document:

1 .... from a proceduralhierarchy, the off-normal procedures take precedent over the normal operatingprocedures. So we suspended the normal operatingprocedures, went to this procedure to take the actions in response to the NN failure. (p 16 line 25 and p.

17 lines 1-4)

2. And there's several pages- about four or five pages of actions we have to take to verify.

And it also branches to an attachment, that's about anotherthree or four pages, that lists all the instrumentationthat was affected by that loss, to verify that that - all that instrumentationis still properly functioning. So that took us quite a while to go through all that guidance to verify all the things that were operatingproperly. (p. 17 lines 5-14)

• 3. Again, so now we're in two off-normal procedures and responding to those. So that's preventing us from going on with the reactor shutdown procedure. So that was the biggest delay. (p 17 line 25 and p. 18 lines 1-3).

4. So, again, we're still in the off-normal procedure for the loss of the NN bus, and that's ongoing. (p. 18, lines 7 & 8).

5. And then at 11:37, on line 8 [of the Shift Supervisor Log], was when we exited OTO NN1. So that was the last- that was the first time we had exited all the off-normal procedures we were in; where we go back, and now we are only focused on the plant shutdown procedures. So at 11:37, we exited the last off-normal. (p. 19 lines 16-21)

6. So there was really no delay in there. We were responding to two off-normal procedures. (p. 21 lines 3-4)

7. As I mentioned before, once we got letdown restored,we focused on the off-normal for the loss of NN bus, or to finish up all the actions from that, until we had all those actions completed. And then once they were completed, we focused on - back on the rest of the plant shutdown activities. (p. 24, lines 8-13)

8. But the reason for the delay (in] the continuingon with the control bank insertion was what I previously discussed, about the actions we were still doing in two off-normal procedures,in addition to all the normal plant equipment steps that take place before you get to the reactorshutdown step, as far as taking equipment out of service. So we were following the prescribedprocedure guidance to do all that stuff. (p. 26 lines 24 &

25 and p, 27 lines 1-6).

9. And when we got to the step to where you commence the reactor shutdown, that's when we - we had finished up all the procedures for the off-normals. (p. 27 lines 7-9)

Request 3.1: Please provide me the NRC's position as to which two off-normal procedures Dave Lantz is referring to in quotes 3, 6, and 8 above. Mr. Criscione believes the statements refer to the off normal procedure for "Loss of Letdown" (OTO-BG-00001 at Callaway Plant) and the off normal procedure for "Loss of Safety Related Instrument Bus" (OTO-NN-00001 at Callaway Plant). Is it the NRC's understanding that these are the two off-normal procedures Mr.

Lantz is referring to in his testimony?

Enclosure, page 3

Request 3.2: At 10:18 am, the operating crew established a letdown flow of 75 gpm and exited the "Loss of Letdown" off-normal procedure (OTO-BG-00001). 10:18 am also corresponds to the approximate time that core reactivity reached the point where it could not be prudently recovered (i.e. the point at which the reactor could be conservatively prevented from passively shutting down). Please provide me the NRC's position as to whether or not the performance of the off-normal procedure for "Loss of Letdown" (OTO-BG-00001) contributed to the crew being unable to insert the control banks during the time frame from 10:18 am to 12:05 pm.

Request 3.3: In a June 26, 2009 letter to Region IV of the US NRC, Mr. Criscione argued that the control room operators were not actively involved in performing the steps of OTO-NN-00001 beyond 08:35 am. That Is, by 08:35 am, the control room operators should have performed all the necessary steps of OTO-NN-00001 with the exception of step 1.7 of Attachment 1A which required that a valve lineup of the auxiliary feedwater system be performed per surveillance lprocedure OSP-AL-00001. Please provide me the NRC position as to what burden off normal procedure OTO-NN-00001 was placing on the control room operators. Were the control room operators actively engaged in performing OTO-NN-00001 between 10:18 and 11:33 am? If so,

'what actions were they performing and how did these actions inhibit them from inserting the control banks? When Dave Lantz stated that it took the operating crew "quite a while" to go 1through the control room actions for OTO-NN-00001, what does he mean? Is he referring to the 15 minutes from 08:21 to 08:35 am or is he referring to the 196 minutes from 08:21 to 11:37 am? How long did it take for the operators to get through the control room actions for OTO-NN-00001? With the exception of performing OSP-AL-00001, was there any action of OTO-NN-00001 not yet completed by 10:18 am?

Request 3.4: Please provide me the NRC position as to whether or not at Callaway Plant there was written guidance which prevented normal operating procedures from being performed in parallel with off-normal operating procedures. Does the NRC believe that, in the excerpts from his testimony provided above, Mr. Lantz Implied to the Office of Investigations that the need to perform the two off-normal procedures prevented his crew from inserting the control rods in accordance with the normal operating procedures?

Request 3.5: OTO-NN-00001 was not exited until 11:37 am. Between 10:18 and 11:37 am, the NRC licensed operators performed the following tasks which were not performed as part of any off-normal, alarm response or emergency procedure:

1034 Secured an Intake Pump 1034 Placed Cooling Tower Blowdown in service 1048 Restored letdown flow to 120 gpm (done in accordance with the normal operating procedure OTN-BG-00001) 1101 Stopped the 'C' condensate pump Please provide me the NRC position as to whether or not, given that the "procedural hierarchy" associated with off-normal procedure OTO-NN-00001 did not prevent the four items listed above from being performed, this "procedural hierarchy" in any way inhibit the control room operators from inserting the control banks.

Enclosure, page 4

Request 3.6: Please provide me the NRC position as to whether or not Mr. Lantz was intentionally being misleading when he stated "once we got letdown restored[at 10:18 am], we focused on the off-normal for the loss of NN bus, or to finish up all the actions from that, until we had all those actions completed". What exactly in OTO-NN-00001 was being focused on from 10:18 am until 11:34 am? Did the performance of OSP-AL-00001 require the focus of the control room operators to the point that it inhibited the insertion of the control banks?

Request 3.7: Please provide me the NRC position as to whether or not Mr. Lantz was intentionally being misleading when he stated "Again, so now we're in two off-normal procedures and responding to those. So that's preventing us from going on with the reactor shutdown procedure. So that was the biggest delay'. Did OTO-NN-00001 need to be completed prior to performing the steps in the Reactor Shutdown procedure (OTG-ZZ-00005) for inserting the control banks?

Request 3.8: Please provide me the NRC position as to whether or not Mr. Lantz was intentionally being misleading when he stated "So there was really no delay in there. We were responding to two off-normal procedures". Did the performance of OTO-BG-00001 and OTO-NN-00001 justify the 106 minute delay in inserting the control banks?

§4 Activities Required for the Reactor Shutdown In his April 1, 2008 testimony to Crystal Holland, Dave Lantz made several statements indicating that the Reactor Shutdown procedure (OTG-ZZ-00005) required certain actions to be performed prior to inserting the control banks and that the level of activity in the control room justified the 106 minute delay in inserting the control banks. For the context in which these statements were made, please see the transcript pages from which these statements were taken that are provided at the end of this document:

1. So that was all stuff procedurally-driventhat starts- you do all those actions before you start the reactorshutdown. So those - all those actions are ongoing. (p. 19 lines 4-7)

2. So those are all ongoing surveillances that are a requiredpart of making mode changes for doing a plant shutdown. (p. 19 lines 13-15)

3. So there really was no delay in there. We were responding to two off-normal procedures. And we were doing all the normal equipment manipulations requiredfor a plant shutdown, the normal administrativeburdens associated with approving the start of all these surveillances requiredfor mode changes. (p. 21 lines 3-9)

4. But the reason for the delay [in] the continuing on with the control bank insertion was what I previously discussed, about the actions we were still doing in two off-normal procedures, in addition to all the normalplant equipment steps that take place before you get to the reactorshutdown step, as far as taking equipment out of service. So we were following the prescribedprocedure guidance to do all that stuff. (p. 26 lines 24 &

25 and p. 27 lines 1-6).

5. So there - again, a lot of activity going on in that 100 minutes, or whatever it was. So it wasn't like insertingthe control banks was the only thing we had to do that - in that 100 minutes. There was a lot of stuff going on. (p. 27 lines 20-24).

The Reactor Shutdown procedure (OTG-ZZ-00005) was classified by Callaway Plant as a "Reference Use" procedure in 2003, meaning that steps did not need to necessarily be Enclosure, page 5

16 1 problem with the NNI1 inverter, which was the cause of 2 our shutdown.

3 They thought it was repaired, and they 4 wanted to do some post-maintenance testing to see if 5 they had actually fixed the problem. So we had a short 6 brief to -- with the crew members to place that 7 inverter in service to verify whether it was working 8 properly or not.

9 When we made -- put that in service and 10 made that transfer to that inverter, at 8:21, we had a 11 momentary failure of it.

12 MS. HOLLAND: Line 25?

13 MR. LANTZ: Yeah.

14 MS. HOLLAND: Okay. On the Shift --

15 MR. LANTZ: Line 25 --

16 MS. HOLLAND: -- Supervisor Daily Log?

17 MR. LANTZ: -- on the Shift Supervisor 18 Log.

19 MS. HOLLAND: Okay.

20 MR. LANTZ: So we had a momentary loss 21 of NN11 that swapped to the backup power supply 22 automatically. We entered OTO NNI, which was the 23 procedure for a loss of NNO1.

24 So we were -- at that point, that's --

25 from a procedural hierarchy, the off-normal procedures NEAL R. GROSS Enclosure, p. 12 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 procedures and responding to those. So that's 2 preventing us from going on with the reactor shutdown 3 procedure. So that was the biggest delay.

4 At 10:18 we -- on Line 32 -- we 5 completed the actions of OTO BG1 and exited that 6 procedure. That was five minutes after we entered Mode 7 2. So, again, we're still in the off-normal procedure 8 for the loss of the NN bus, and that's ongoing.

9 Additionally, you can see --

10 MS. HOLLAND: Okay. Now, we're in the 11 Reactor Operator --

12 MR. LANTZ: The Reactor Operator Log.

13 MS. HOLLAND: -- Log? Okay.

14 MR. LANTZ: There's a lot of plant 15 manipulations going on at this time, too. For example, 16 you know, on Line -- starting on Line 7, we restored 17 letdown to 75 gallons per minute.

18 Line 8, we had to take a superior intake 19 pump -- and these are still some normal steps in the 20 procedures for going on a plant shutdown. Placed the 21 cooling tower blowdown in-service. Restored --- Line 22 10, at 10:48, restored letdown to 120 GPM.

23 MS. HOLLAND: Okay.

24 MR. LANTZ: Line 11, 11:01, secured the 25 Charlie condensate pump. Line 12, place contaminant NEAL R. GROSS Enclosure, p. 14 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 31, at 1758.

2 MS. HOLLAND: Okay. Now, during this 3 time, you were working with the control room 4 supervisor; that would be Mr. Rauch?

5 MR. LANTZ: Correct.

6 MS. HOLLAND: Okay. When you first 7 realized that you were going to have to actually shut 8 the reactor down, did he actually notify you? Or how 9 did that transpire?

10 MR. LANTZ: Well, the discussion I had 11 with Gerry Rauch was at the point where it was --

12 became obvious to me that, you know, it was not 13 conservative to just keep trying to restore this 14 temperature. I said, We need to go ahead and trip the 15 turbine, take it offline; that will address the 16 temperature excursion.

17 So when I made that direction to him to 18 have the turbine taken off line, in my mind, that was 19 going to initiate the reactor shutdown, because of the 20 continual buildup of poisons and not having a steam 21 demand on the reactor anymore.

22 So that's really, in my mind, what the 23 reactor shutdown -- where we had made the decision to 24 start that. There was no turning back at that point.

25 So the discussion was merely to direct NEAL R. GROSS Enclosure, p. 17 COURT REPORTERS AND TRANSCRIBERS 132= RHODE ISLAND AVE., N.W, MON*0AAoA& WAR4INCrTnN n,. 2n005.3701 www.nalmmsa.cm*

25 1 megawatts from where we would normally trip the turbine 2 offline. I mean, I think we were at about 100 3 megawatts when this temperature excursion happened.

4. At 60 megawatts would've been the normal 5 point where we would take the turbine offline. So we 6 were only, you know, 20 minutes away from doing it 7 anyway.

8 And it became obvious to me that once we 9 had taken all the immediate actions we could take in 10 the control room to address this temperature transient, 11 and they weren't effective, there was no longer any 12 valid reason to keep the turbine online.

13 It wasn't-prudent to chase the 14 temperature. So, conservatively, I directed the 15 turbine to be taken offline to address the temperature 16 transient.

SMS. HOLLAND: And can you explain -- and 17 18 this is part of the allegation -- the appearance that 19 maybe the delay was -- the timing of the delay was 20 manipulated to cover up the fact that maybe if you 21 didn't go back online in a certain amount of time it 22 would be viewed as a adverse action or performance 23 problem?

24 MR. LANTZ: I'm not -- I don't think I 25 understand. What's the delay you're talking about?

Enclosure, p. 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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.44-32

6 1 there anything else that you can maybe add to your 2 interview that may help give the NRC an overview of 3 what went on that day and why certain appearances may 4 have 6ccurred or --

5 MR. LANTZ: I mean, my perception of 6 this is that we had a -- we had an extremely busy 7 shift. We were presented with some equipment failures 8 and two off-normal procedures. And I think the crew 9 worked through all those issues in a fairly timely 10 manner.

And the forefront of our -- of all our 12 actions were to do things conservatively, and that's

.13 the primary driver that I directed the turbine trip, 14 was to conservatively shut down the turbine in response 15 to a temperature excursion.

16 And I've had years of training that 17 that's the right thing to do in response to an issue 18 like that, take conservative action and address it and 19 don't try to chase it with reactivity. So that's what 20 we elected to do.

21 MS. HOLLAND: All right. And what you 22 stated earlier is there was no intentional delay --

23 MR. LANTZ: No. There was never a delay 24 in the shutdown. The shutdown had started at one 25 o'clock and it continued until we got to Mode 3. There NEAL R. GROSS Enclosure, p. 22 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

12021 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com