ML19305A652
| ML19305A652 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/28/1979 |
| From: | Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| References | |
| NUDOCS 8001160692 | |
| Download: ML19305A652 (56) | |
Text
..~ - - -
E O < ;. > :n, Q ~l, f i
u i
l f,l l
NUCLEAR REGULATORY COMMISSION r.
-4
}
IN-THE MATTER OF:
THREE MILE ISLMID SPECIAL INTERVIEWS I
DEPOSITION OF PAUL JOSEPH KELLOGG t\\
Place -
Bethesda, Maryland i
Date -
Friday, September 28, 1979 Pages 1 - 56 4
rs.,non.:
(:o2)ur.uco ACE-FEDERAL REPORTERS,INC.
OffresalReporurs AM North Capitol Street
/
Weshington, D.C. 20001 f0 N
NATIONWIDE COVERACE DAILY 60 C g0011
c-
,~,.-.. -. - -....
,,.. ~..--....~._.....:.
- - -.. =.: - a ;,:=-
1
~CR7330
'JRBs jrbl~
I UNITED STATES OF AMERICA O
2 NUCLEAR REGULATORY COMMISSION 3
7 4
DEPOSITION OF 5
PAUL JOSEPH KELLOGG 6
-d 7
-8 9
6935 Arlington Road Building 10 Bethesda, Maryland Friday, September 28, 1979 12 13
(-
Deposition of Paul Joseph Kellogg, pursuant to 14 notice, before R. LAWRENCE VANDENBERG and DAVID EVANS, 15 Three-Mile Island Special Inquiry Group, when were present:
16 PAUL JOSEPH KELLOGG, Deponent 17 R. LAWRENCE VANDENBERG, Member, TMI Inquiry Group 18 DAVID EVANS, Member, TMI Inquiry Group 19 4
20 21 22 L
23 24 Ace was Reconen, inc.
25 t
-jrb2 2
I EEEEEEES n,
. ('
2 WITNESSES EXAMINATION 3
Paul J. Kellogg 3
s.
4 5
6 4:
7 EXHIBITS MARKED FOR IDENTIFICATION 8
.No. 1115, Depondent's Resume 4
9 No. 1116, Letter, Oct. 26,
'77, w/Atch 15 10 No. 1117, Letter, Feb.
2,
'77, w/Atch 45 11 12
(
13 14 15 16 17 18 19 C
20 5-21
. (
22 23
.24 A% Ja,W Rgo,te,s, Inc.
25
~
gjrb3 3
I
_P _R _O C _E _E _D _I _N _G _S g
2 MR. EVANS:
Let 's go on the record.
3 This ir a deposition of Mr. Paul Kellogg being
'4 held by the NRC's TMI Special Inquiry Group.
It is being held 5
at the Offices of the Special Inquiry Group on Arlington Ro,ad, 6
in Bethesda, Maryland, on September 28, 1979.
4 7
Present, in addition to Mr. Kellogg, are Mr. Lawrence 8
Vandenberg, and David Evans, of the Special Inquiry Staff.
9 MR. EVANS:
Mr. Kellogg, have you had an opportunity 10 to read the witness notification form, and the letter sent to 11 you on behalf of Mitchel, Rogovin,'which has been previously 12 given to you?
13
(
MR. KELLOGG:
Yes, I have.
14 MR. EVANS:
Do you understand the contents of those 15 two documer.ts?
16 MR. KELLOGG:
Yes,. do.
17 MR. EVANS:
Do you understand you have an opportunity 18 to have an attorney here with you today if you would like to?
19 MR. KELLOGG:
Yes.
A 20 MR. EVANS:
Do you have such an attorney present?
21 MR. KELLOGG:
No, I do not.
22 MR. EVANS:
Are you willing to proceed under these 23 conditions?
24 MR. KELLOGG:
Yes.
Am
.wW Rgenws, lrc 25 MR. EVANS:
Mr. Vandenberg?
I
jrb4 4
1 Whereupon,
-~.
4
\\
2 PAUL JOSEPH KELLOGG 3
the deponent in this matter, was sworn by Mr. Vandenberg and p-4 was examined and testified as follows:
5 EXAMINATION 6
BY MR. VANDENBERG:
7 Q
Would you state for the record your full name?
8 A
My fall name is Paul Joseph Kellogg.
9 Q
And what is your current permanent position?
10 A
My current permanent position is Chief, Nuclear 11 Support Section-2, neactor Operations and Nuclear Support 12 Branch, Region-2, Office of Inspection and Enforcement.
(
And I am currently acting as Reactor Projects 13 14 Section-3 Section Chief, in the 2 office.
15 Q
Did you bring with you a brief resume?
16 A
Yes, I did.
17 Q
And is this that resume?
18 (Handing document to witness.)
19 A
Yes, i' is, a
20 MR. VANDENBERG:
Could we get this marked, please, 21 as Exhibit No. 1115.
22 (Resume of Deponent was marked 23 Deposition Exhibit No. 1115.)
24 BY MR. VANDENBERG:
. Ace ne neoonen, Inc.
25 Q
And is this resume an accurate statement of your i
e_
jrb5 5
1 experience since graduation from college?
.( n
'2 A
Yes, it is.
3 It contains everything except my current acting
-m 4
pcsition.
5 O
Thank you.
6 Mr. Kellogg, would you tell us the time period when O
7 you were responsible for part of the inspection program at 8
Three Mile Island-2, and what your responsibilities were?
9 A
I assumed the project responsibility for Three Mile 10 Island-2 in approximately May of 1977, and continued that 11 position through March 1978.
12 In my position as project inspector at Three Mile
(
13 Island I had both units; Unit-1 was in normal operation,
-14 NR-2515 inspection program; Unit-2 was in preoperational 15 testing.
About the time I took over they were getting ready 16
-- they had hydro'd the plant, and they were getting ready --
17 hydrostatically-tested -- and they were getting ready to go on 18 to more preoperational tests and preparation for hot-functional 19 testing prior to core-load, s
20 During the time I was there, they successfully 21 performed the preoperational hot-functional testing and the 22 plant had an operating license.
-C 23 Q
Did you spend most of your time on Unit-2, or Unit-l?
24 A
Most of my time was spent on Unit-2.
'AE. ; Jens Roomn, ime.
25 The way that our inspection program is set up, we i
.i
u..
1 1
jrb6 6
t I
really have two programs that were in effect, 2513 and 14 on 2
Unit-2, 2515 required me to go to that unit about once a 3
quarter; and periodically if they had a problem I would stop 3
4 over there from my Unit-2 inspection, and see what was going on.
5 The vast majority of the time was spent on Unit-2.
6 Q
Are those numerical references to --?
7 A
They are manual chapters.
They are an entire 8
inspection program.
9 But, to continue
., with respect to the responsibilities 10
-- my responsibilities were to ensure that these inspection 11 programs were completed, that the unit was in fact -- well, 12 it was not my responsibility to see that the unit was in fact 13 constructed as the FSAR calls for; that's the licensee's
(
14 responsibility and the Construction Branch's responsibility 15 for making that determination.
16 But I am responsible for the coordination of the 17 inspection program to ensure that all the areas are covered,
18 and that all the open items that we have identified and the 19 Construction Branch has identified, are all either completed 20 or included in a license amendment, a licensing condition in 21 the applicant's license.
22 Q-When you began there in May of 1977 what was the 23
' status of Unit-2 at that time?
24 A
-The. status of Unit-2 was, it was in preoperational Act.
eral Mepo,ters, Inc.
25 testing.
They were performing some of the preoperational tests, I'-
jrb7 7
I and Ted Rebelowski and I -- Ted was primarily the preoperational 2
test inspector for Region-l.
He and I did the preoperational
~s 3
testing inspections and witnessing of the various tests on the 4
unit.
5 7 don't know exactly what you are looking for as far 6
as what tests were going on at that time?
e 7
0 Were there, for example, any tests which the 8
licensee -- which were causing severe problems?
9 A
Well, tests that caused severe problems, I don't know 10 the meaning of your terminology " severe".
II At that point in time there is no nuclear fuel in the 12 core.
The fuel was on-site.
It's not in the vessel.
The 13 vessel is basically empty, with the internal package in it, 14 but no fuel.
15 During hot functional testing they did manage to 16 damage all the reactor coolant pump seals -- I think that's 17 what you are looking for.
18 Q
Can you recall for us how that happened?
19 A
Yes.
20 It was a sequence of events that they finally came to 21 the point -- I believe I used the terminology "of breaking the 22 plan t".
23 About, I would say about a month before the actual 24 transient that damaged the seals, they were cleaning a feed-Am
- r0 Reporters, Inc.
25 water heater which trisodiumphosphate, a chemical cleaning agent i
^
jrb8-8 1
.used throughout steam plants.
2
- The design of the Three Mile Island-2 steam generators 3
feed system did not call for any phosphates to be introduced p
4 into the steam generators.
As a result of a leaking drain 5
valve on a heater that they were cleaning, they introduced 6
phosphates into the condensate system, into the main condenser, t
7 and, therefore, into the steam generator.
8 There was a large concern on B&W's part and the 9
licensee's part to get rid of those phosphates as quickly as 10 possible, because the plant was hot.
11 They, therefore, needed large quantities of water to 12 clean up the steam generators, the refueling water storage 13 tank, or at this point, the borated water storage tank, BWST, 14 was filled with water but was not borated.
It was primary-15 grade water without boron.
16 So they decided to use that water to fill -- flush --
17 the steam generators.
18 In doing so they had to modify the water makeup 19 system by the removal of a check-valve, and blow the BWST back 20 into the demineralized water header, and then they could use it 21 in the condensate system.
22 And that's what they did.
The thing they neglected to
~.
23 do was reinstall that check valve.
24 Later on, somewhere between two weeks and a month Ace *- wW Rego,w,s, Inc.
25 later, they.were hot and they had evidently flushed one of theirt t
~.
u.
jrb9 9
l 1
condensate resin demineralizers, and in doing so had gotten 2
some of the resin back up into the demineralized water-header, 3
because the check-valve wasn't there.
4 They then made up to the nuclear services closed 5
cooling water system, and in dting so, flushed some of the 6
resin into that system's makeup tank, surge tank.
7 The system at that time had some very small filters 8
installed to collect anything that got in there, and it did.
9 It caused the loss of the system, the pumps tripped due to lack 10 of suction pressure; and tho'se pumps delivered cooling water 11
. to the reactor cooling pump motors to the makeup pump motors, 12 and to other equipment in the plant -- but those are the 13 more significant ones at this time.
(
14 The result of the loss of the nuclear services closed 15 cooling system was that they had to secure the reactor coolant 16 Pumps; and they also had to secure the makeup pumps.
17 Now, the makeup pumps, in addition to providing 18 charging into the primary plant, also supply seal injection, 19 which is a cooling mode for the seals on the reactor coolant 8
20 pumps.
21
.They lost the makeup pumps because they lost the 22 cooling water to those; they lost the head turn-off reactor 23 coolant pumps, because they lost the cooling to the motors on 24 those.
l An ad Rgomes, te-25 There is an attached impeller and an emergency heat I
jrb10 10 1
e.< changer, if you will, on the reactor coolant pumps; that if (3'
2 the pumps were still running, the seals would still be provided 3
some cooling; because the impelier is attached to the main 4
shaft, when you turn-off the pump, you lose that, also.
5 There was an interlock, and there is a cross-connector 6
to the nuclear river water system; they could not get the valves 7
open in the nuclear river water system because the pressures 8
Would not allow the interlock to be made -- the pressure switches 9
had not been calibrated at that point.
10 So the seals went through a temperature transient 11 which required each one of the four seal packages to be 12 replaced.
13 MR. EVANS:
Off the record.
14 (Discussion off the record.)
15 MR. EVANS:
Back on the record.
16 BY MR. VANDENBERG:
17 Q
Mr. Kellogg, did that incident delay the licensee's 18
.preoperational test program?
19 A
Yes, it did.
I would have to look at the various t
20 inspection reports to give you an idea; but it is about a 21 month's uffort to go in and remove all four reactor coolant 22 pumps and replace those seal packages.
23 Q
Was there any reason for you to believe that the 24 initial cause of the accident was perhaps due to the licensee's s
. se om,ws, inc.
25 attitude, that they were trying to rush through that portion I
jrbli 11 1
of the preoperational test program?
2 A
I wouldn't use the terminology " rushed-through" but 3
they were pushy with their program.
i 4
The test superintendent has a job to do.
He had to 5
get the plant tested and to turn it over to the operational 6
group.
7 It was my feeling at that time that the testing 8
program was being pushed to its absolute limit in that they 9
would have to wait periodically for systems to be calibrated, 10 for cable terminations to be done; at the various points in the 11 procedure they would have to stop at a given point in the 12 procedure and wait for some other system to be finished or 13 some other work or repair to be done, such that they could go 14 on.
15 And in the hot-functional test program I think 16 if you look at the length of it, you will see that it turned 17 out to be quite lengthy.
Once they got the plant hot, they 18 wanted to get all the testing done they could while it was hot, 19 so that they wouldn't have to take it hot again.
20 And in doing so it was drug-out, if you will, by 21 the fact that all the support systems were not ready; and they 22 had experienced a number of problems which -- that's the purpose u
23 of the test program, to identify problems.
24 But it did get drug-out, and drug-out to the point Am ' w d R g e n ws,lre.
)
25 where as I say they finally managed to damage the reactor coolant l
l I
jrbl2 12
.1 pump seals.
( -
2
.Q When you say the plant was " hot," you mean by usin g --
3 A
Reactor coolant pump motors to heat the systems up.
4 Q
Has it been your experience at other plants that 5
licensees get committed to a schedule and then force themselves 6
into a rush to complete portions of the test program?
7 A
I would say it is normal for the licensees to establish 8
a -- what I would call an extremely optimistic schedule; and the n
9 push to a given degree to see that the schedule is met, which 10 then in the normal event of things causes some intermediate 11 Position to be reached.
12 They do not make the extremely optimistic schedule, 13 but they would not be as long as they would as if they had
(
14 scheduled for six months; if they scheduled for two, they might 15 end up doing it in three.
16 At TMI, I think they were pushing a little harder 17 than I had seen in other plants in the test program at this 18 Point in time; they were very interested in an operating license.
19 I am not sure -- and they may be able to provide e
20 the information with respect to the tax structure and the rate 21 structure, and the changes at the beginning of the year.
But 22 at the end of the year, there was a very large interest of
,A 23 _ getting it done; for once the first of the year came along the 24
. interest was still there, but it wasn't quite as peaked as it Ack ' ' Joral Reporters, Inc.
25 was -- if memory serves me right.
I
jrb13 13 I
Q When you say the "end of the year," which year now are
(
2 you talking about?
3 A
This would be January 1st, 1978, December 31st, 1977.
4 Q
So you think there was a big push to get a certain 5
amount of the test program completed by December 31st, 19777 6
A Yes.
7 I think that financially the company would have been 8
better off to have the unit licensed at that point.
9 Q
By " license" you mean having an operating license?
10 A
By having an operating license and get into their II start-up test program.
I am not sure whether it is a quarterly 12 thing, or whether it's an annual thing', with respect to how 13 their payment base changes when the plant is licensed; but 4
14 there appeared to be more of a push in the October-November 15 time frame than there was later on.
16 Q
They actually got their operating license February 8, 17 1978; is that your recollection?
18 A
yes.
19 Q
Do you think the licensee got their operating license i
20 too early in the sense that there were uncompleted preoperational 21 test items still to be completed?
22 A
No.
23 It's my responsibility to assure that they didn't.
24 Q
Is there some leeway there?
! Ace r %1 Reporters, Inc.
25 A
Yes.
There is some leeway; yes.
I
)
jrbl4 14 1
There are some preoperational tests which you really
.('
2 can't do prior to the time you load the fuel and take the 3
plant up; the radioactive waste systems, for instance, cannot
(,
4 really be adequately tested without some radioactivity in them; 5
and there is none prior to the time you take the plant critical, 6
and you have radioactive wastes.
7 But there are a number of tests which really cannot be 8
accomplished without the core and criticality.
Those types of 9
tests would be the type that would be identified in these 10 letters that are a portion of the record, which we call our 11
" outstanding items list".
12 We would in this listing, if you take a look at it, 13 we have listed the outstanding items from inspection reports; 14 and I believe our MO here -- modus operandi -- were -- I think 15 later on we started the ones we felt needed to be completed.
15 This is a computerized listing that Region-1 keeps 17 for each reactor, which contains all of the outstanding items 18 from i'nspection reports and enforcement for the inspector's 19 use.
And this is how I control the project, one of the tools t
20 for controlling it.
21 Q
A copy of this list you are looking at is attached 22 to --
t.
23 A
It is attached to a memorandum to Roger Boyd from 24 James Smiezek, dated October 26, 1977.
This list was published Ac, era Report.rs. Inc.
' 25 on about a monthly basis from about -- wel, it was supposed to f
jrbl5.
15 I
be 90 days prior to licensing.
It should have been published
(,,
2 monthly, and I believe it was, up until the time the last 3
submittal -- or last outstanding items; which basically says that i
i
~4 we find the plant has been essentially completed in accordance 5
with the application; that they have implemented a quality 6
assurance program for operations that meets the commitments 7
that they made to the Commission; and we feel that these items 8
should be conditioned in the license, the ones that are remain-9 ing at that time.
10 MR. VANDENBERG:
Could we introduce as Exhibit 1116, 11 the October 26 letter together with the attachments.
12 (Letter, Oct.-26,
'77, w/atchmts, 13
(
was marked Deposition Exhibit 1116.)
i 14 BY MR. VANDENBERG:
15 Q
Mr. Kellogg, could you also explain the additional 16 attachments to the letter of October 26, '777 17 A
The instructions that we have for preparing this 18 letter is a manual chapter module which is No.94-300; and 19 that requires several areas to be addressed.
20 One of them is the outstanding items that you have, i
21 that you feel need to be closed.
They come from inspection 22 reports, bulletins, circulars, enforcement things.
23 The other thing is the status of the inspection 24 program, which modules have been completed and which ones are An ', Jeral Repo,to,s, Inc.
25 still outstanding.
I
L
~jrbl6 16 i
I In addition to that there is an enclosure a which
(,
2 addresses the testing program.
It gives preoperational test 3
results and start-up test program status with respect to the
_(
's 4
procedures.
It gives you the number of tests that the licensee 5
has, the percentage that he'has completed; and any test 6
deficiencies that have been identified that are still outstand-7 ing.
8 The construction status section, which is enclosure C, 9
addresses those systems which have not yet been completed, just 10 on a large scale.
What that means is that it addresses a II large system, such as reactor building hydrogen control, or 12 reactor building cooling purge supply and exhaust.
It does not 13 give you the necessary position of where in the construction 14 phase that system was; it was just not completed yet and had 15 not been construction-tested and turned over to the start-up 16 test group for testing at that point in time.
17 Q
Mr. Kellogg, the list of open items here is a list 18 prepared by the Office of Inspection & Enforcement; is that 19 right?
20 A
That's correct.
21 Q
Did the licensee also have what is called a 22
" punch list" of open items?
23 A
Yes, he did.
24 c
Q And was that punch list something.that had to be Aa, Jeret floporters, Inc.
25 reviewed prior to granting'of the operating license?
4 I
jrbl7 17 1
A Yes, it did.
~
2 Q
Do you recall how many items were on that punch list?
3 A
Several thousand.
4 It was contained-in about three three-inch volumes.
5 0
was that in your view an excessive number at that 6
point in licensure?
7 A
It was a larger number than I had been previously 8
exposed to at other programs of that type.
9 0
Well, how did you go about reviewing that multi-10 thousand punch list of items and for what purpose?
II A
The punch list which I reviewed initially was the 12 result of their quality control group's inspections and 13 construction deficiencies dhat were turned over when the system 14 was turned over.
15 In other words, the construction is not fully complete r 16 some terminations are not done, valve-labeling had not been 17 done; but they turned the system over to get on with the 18 testing, and then there would be a deficiency list that came 19 over with it.
20 The quality control group would -- and the start-up 21 test group would -- perform inspection of the system, walk-22 through of the system, and generate additional lists of items 23 that were not correct -- things like are strikes, hangers 24
- missing, terminations not de 7,
labeling not installed.
Ac.
we n,=,.. inc.
25 And this is the type of punch list that you had.
It i
i
~
~
jrb18 18 1
was not a computerized punch list; it was a hand-generated.
(~'
2 Each system had a listing and that is the way they filed them, 3
by system numbers.
Each system had a listing in these books; 4
and what you would do is basically when I initially started in, 5
I looked at the size of the job, and the individual that was 6
tracking these items, and basically for the first few months 7
just went through it to ensure that there was close-out in fact 8
af:the items and that they were working on it -- because the 9
numberwas quite large.
10 And I think that in one of these other submittals 11 I happened to look through, there is a reference in there to the 12 punch list with the items remaining outstanding.
13 Q
In other words, the IE review of the licensee's punch 14 list could lead to an open item appearing on the 'I&E list of 15 open items?
16 A
Yes.
And in fact I believe there is one here that 17 just says he has to complete the significant items on his la punch list.
19 What we finally wound up doing prior to licensing
~
20 say, a month before licensing, or maybe three weeks before, is 21 we sat down -- I sat down, and went through each one of the 22 punch lists on an item-by-item basis; and I made a determination 23 of those items that must be corrected prior to the time that I
24 I wouli say that I&E was ready to say the plant was ready to be
- Me Ly namwn,'w.
25 licensed.
l-t
a e
4 0
jrbl9 19 1
Q How many of those items were there, do you recall?
t i 2
A At the time of licensing there were none of those 3
items left.
e 4
In the initial stages there were probably in the 5
area of -- oh, I would say 500.
6 Q
Initial stages would be about three weeks prior to 7
licensing?
8 A
Yes, at that time they had the capability of taking 9
several crews and going out and just working on puch lists.
10 Those people had been involved in testing and in system 11 construction prior to that, and as the systems were finished 12 and turned over, then these groups became available; they would
/
13 just take a punch list for a system and go out and verify.
14 And in a lot of cases it was the paper trail that was 15 behind the actual work.
Inother words, quality control would 16 go out and make this initial punch list; then that punch list 17 would sit there.
It vould be given to a worker; he would go out 18 on his day and clean up a group of these items, label all the 19 things, make the terminations; then the listing I would look at 20 would wait until QC then had additional bodies to go back out 21 and reinspect that system.
22 And then we would line off the various items that they 23 had corrected.
24 So in some cases the punch list itself actually An _JwW Reonen, Inc.
25
' lay behind the work, because quality control inspection had e
jrb20 20 1
actually closed the item out on the punch list.
(.s 2
O Were you assisted in your review of the licensee's 3
punch list items?
p 4
A I did utilize other inspectors in the review of the 5
punch list to ensure that they agreed with my determinations 6
of those items that were significant.
There were some items 7
that by reading the punch list you couldn't tell whether they 8
were significant or not; and you had to have the licensee 9
identify those and say, " hey, explain them to me.
Show me what 10 they are out in the plant so that I can understand their 11 significance, or fix them."
12 Q
Now, who were those inspectors who assisted you in
~
13 those inspections?
14 A
Ted Rebelowski, Bill Coleman, 31.11 Raymond; I would 15 say that 's about it -- oh, Bert Davis, A.
Davis; also early o.
16 in the stage we sat down and Bert looked at the list with me l'7 to ensure that he agreed with my determinations as to what 18 the significant ones were.
19 Q
Why did you decide at that point to review the entire 20 licensee punch list items, rather than having the licensee 21 review them, identify the important ones, and then review the 22 licensee's process for identifying them and reviewing just those 23 ones the licensee felt were important?
24 A
That's a good question; the thought had not occurred Al ans newwrs, w.
j 25 to me, i
.u jrb21 21 1
I would have to say that at that point in time the
(
2 licensee did not have anybody who could go through the punch 3
list and determine for each system involved what 1 would have 4
considered significant and what he would have considered 5
significant.
6 We had agreed early in these stages that some of these 7
things would be of significance, such as painting, final painting 8
of the junction boxes, and various things like that.
We had 9
made other agreements that things would have to be corrected 10 and evaluated, things like are strikes on pipes, and electrical 11 terminations had to be done; and we had established a ground 12 rule before I went through the list as to what generically 13 I would feel would be significant, what would not, having 14 looked through the list previously to see what type of items 15 were there.
16 Q
When you say "we" agreed, you mean you and some 17 representative of the licensee?
18 A
Ron Toole.
He was the GPU Service Company Start-up 19 Test Superintendent.
20 Q
Was Ron Toole also responsible for the work crews 21 who completed the punch list items, the significant punch list 22 items?
s 23 A
No, he was not.
24 Ron, as the start-up test superintendent, had a
.A.
c Roo,wn, sme.
25 group of start-up test engineers that worked for him.
The I
-_.L.
jrb22 22 i
start-up test engin ears controlled the testing, they conduct
('
the testing, they supervise the operators, if you will, while 2
3 these tests are being done; they take the data.
They may have
('
an electrical maintenance man there to take the readings, and 4
5 they record the readings down and make sure the guy does it right.
6
^
7 In the organization there were UE&C supervisors there who controlled the actual maintenance and the actual crews 8
that went out and did this work.
9 jo The inspections of the workers were actually done by ij another group, which was under GPU also, which was the 12 quality control department.
g3 But none of these departments reported to Ron directly
(
ja They reported to the project engineer who was Bill unn:
15 and 'another individual, whose name escapes me.
16 Q
Mr. Kellogg, did Mr. Toole in your view control 37 more or less the schedule for the people who were assigned the 18 responsibility of completing the punch list items?
19 A
Mr. Toole controlled the schedule for the test 20 program, and he became involved in the scheduling of that as 21 it became apparent that the open items on the punch list, if 22 y u will, were the items that were going to control when he 23 got his license; he became -interested in it at that point in 24 time.
' Ace nel deporwes, Inc.
25 And there were meetings between he and the site QC 1
jrb23 23 1
people to ensure that the work not only got done but the
('
2 inspectors got enough bodies to get out there and inspect it, 3
to bring the status up to date, such there was a daily planning
' ('
4 meeting, he would go to the various project managers would go 5
to, each one of the basic leaders of these individual groups; 6
,Cavaletti was there, UE&C was there, the supervisors; and they 7
would all meet in the morning and Catalytic through UE&C 8
would provide where they felt they were with the items' list.
9 Their numbers were always significantly below what 10 the actual records would show, because they were doing the II work; and the difference was the numbers QC had inspected af ter 12 that was done, after the work was completed to bring the books 13 up to date.
Id Q
Was it your view that Mr. Toole was setting the 15 schedule unilaterally, or did you perceive an ending-date for 16 this schedule as being set at a management level above 17 Mr. Toole, and he was charged with just seeing the test program 18 was done by that date?
19 A
I believe there'was an ending-date set which was the 20 date they wanted an operating license; and Mr. Toole knew 21
.what he had to accomplish between now and that date; and he 22 managed his test program to attempt to get that.
23 Q
Do you think that as a result that test program was 24 pushed too hard?
_ Aw r0 Repo,tm, Inc.
25 Do you have any indications that certain tests were 4
I
e jrb24 24 I
attempted and perhaps should have been delayed?
k' 2
A There is one indication that he was pushing and he 3
wanted to get on, and it is contained in the inspection report i
4 7732, which contains an item of noncompliance with respect 5
to the conduct of the preoperational test program the licensee 6
had written into his own procedure a specification on lithium 7
concentration in the reactor coolant system.
8 He had to meet the requirement prior to exceeding 9
the temperature, and they had added the lithium to the plant; 10 it did not come up to the temperature requirement.
They put 11 another additional load of lithium into the plant, and exceeded 12 the temperature requirement before they had sampled it to 13 make sure that the lithium in fact made it to 'where it was 14 supposed to go.
15 And again they were a little bit short.
But the 16 decision was made not to wait for the time for the reactor 17 coolant system to circulate -- the come to equilibrium and to 18 draw another sample.
19 He basically gambled and lost in that case.
But, you 20 know, it's an example, it was one of the first things that we 21 pointed out to him that we did not care to see the program 22 run at that pace that you had to take chances, which is basically 23 what he did.
24 Q
How did you point that out to him?
Aa Jersi Reporters, Inc.
25
.A We pointed it.out to him -- Mr. Rebelowski -- when I I
a
. L.
_jrb25 25 I
say "we" -- Mr. Rebelowskt and myself in this case, pointed out 0
2 to Mr. Toole in our discussions with him, in our exit interview 3
and also in this item of noncompliance.
<~
(
4 Q
And that item of noncompliance was in what month and 5
year?
6 A
The actual date of the inspection report covered the 7
period from August 8 to the 19th, and the -- about August 15, 8
1977.
9 Q
Did you notice any other items sinilar to this after 10 you had these discussions with Mr. Toole?
11 A
No, we had further discussions with Mr. Toole through-12 out the hot-fun ctional portion of the program where we felt 13 that the plant completion was actually scheduling his testing 14 his evolutions in that time.
15 In other words, he would have to -- he had to schedule 16 his tests around getting systems' turned over and calibrated, 17 and electrical terminations being made.
When that got done, 18 then he could go ahead with the test program.
19 So he was somewhat frustrated by having to wait 20 for that.
There was a period when I questioned whether he should 21 actually shut down, cool-down, and wait for the rest of the 22 work to get done.
But that was not my decision; it was his.
m-23 Q
That sort of sounds to me like that the test program 24 was not being pushed or rushed at all, since he apparently had l
Am, m v Ra m m m.ine 1
25 - to wait on. construction; is that right?
jrb26 26 1
A I think that is true in some cases, yes.
2 Q
Well, then, how does that coincide with the prior 3
example of where he was attempting to do too much, apparently?
r~.,
4 A
Okay.
5 The prior example, ther ewere a group of tests he could 6
initially get done and out of the way, and he wanted to get on 7
with the program; and he said, "Let's go."
8 Once you get started then it's easier to put pressure 9
on the construction group to get the work done, because you are 10 holding up the testing function.
It's kind of a whose-got-the-11 ball-in-whose-court.
12 Until you start the hot-functional test program 13 the ball is in Toole's court because he's holding things up 14 because he's not testing.
Once he starts testing, he comes to 15 a point that he can test no longer, because construction is 16 not complete.
17 Then the weight of who's holding the program up falls 18
-on the construction crew.
And that's not Toole's realm of 19 responsibility.
20 So it appears that it wasn't pushed, but it's more of 21 who's holding the project up?
In other words, as long as Toole
'22 could say, "It's construction that's holding me up in getting 23 this test program done," then he's in good shape.
24 Q
And was-that the way it was for --
A=
pol Reporters, Inc.
25 A
Towards_the end of the hot-functional test program, I
a a
r
jrb27 27 I
yes.
(
2 He managed to get all the testing done he could, 3
(..
then he had to sit there and wait.
4 Q
And that situation continued until the time the OL 5
was issued?
6 A
- Well, not entirely -- well, yes; it did.
7 He basically waited because of the damage they'd 8
done to the reactor coolant pump seals; there were also some 9
additional problems with reactor coolant pumps.
We had 10 questioned some of the seals on the reactor coolant pumps from U
the gage indications that were available as to whether they 12 had damaged the seals previously due to foreign material or 13 for some other reason.
I'm not sure what it was.
Id But we had noted some abnormalities.
There had been 15 some abnormalities with respect to lubrication systems on the 16 reactor coolant pumps, and power to the reactor coolant pumps.
17 And there were also volute leaks on at least one of the pumps, 18 if not all of them.
19 Q
When you say " problems in the lubrication systems,"
20 are you referring to maintenance problems in lubricating?
2I A
No.
22 The reactor coolant pumps are rather large.
They have 23 their own oil systems that function.
Their normal pumps are 24 driven by the reactor coolant pump itself, it lubricates itself, Am Jere Renon, Inc.
25 an attached oil pump, if you will.
In addition to that, they i
a
_._w..
~
jrb28 28 I
have what they call lift pumps which are a free lube pump
%g 2
that they run prior to starting the reactor coolant pump.
3 Your starting sequence is to start the lift pumps,
(~ \\.
4 that supplies oil to the bearings, and then you start the 5
reactor coolant pump; when the reactor coolant pump is running, 6
then you can turn the lift pump off after a period of time.
7 0
What were the concerns that you had?
8 A
There were leaks in the oil system and that caused 9
oil to be spread around in the reactor coolant pump bays in the 10 containment.
II In addition to that, they had experienced some tripping 12 of reactor coolant pumps that should not have occurred.
They 13 thought they had found the problem with that; and I don't 14 remember the details associated with it.
But it left us ques-15 tions with respect to the reliability of the pumps at that I6 point in time.
And it was one of our items that we were track-17 ing on our open item list that we wanted to take a further look 18 at.
19 As it turns out, because of the damage and also 20 there were some volute seal leaks on the pumps, that were 21 repaired, we were able to satisfy ourselves with respect to the 22 reactor coolant pumps.
(
23 MR. VANDENBERG:
Do you have questions?
24 MR. EVANS:
I just have one question.
- Am
,rm neoorms, Inc.
i 25 i
.jrb29 29 1
(_
BY MR. EVANS:
2 Q
Mr. Kellogg, the punch list items that you reviewed, 3
(_
have you done that-at other units?
4 A
Yes, I have.
5 Q
So it is typical for I&E inspectors to go over 6
the punch list items that have been developed by the constructors 7
for the utility or QA-QC program, and specify which items on 8
that list must be corrected before an OL can be issued?
9 A
In one fashion or another, yes.
10 Each utility performs this a little bit differently.
11 In previous experience, the licensee had made proposals with I2 respect to, "these are the items I am going to close; these are
(^
13 the significant ones; here is the whole list; see if you agree 14 with me?"
15 We had established that somewhat with TMI with 16 Mr. Toole as to, "these are the types of items you should look 17 at; and then when you get those all done, we'll take a look at 18 the remaining items and see if there's anything else we feel 19 should be done."
20 But the problem we ran into was that they were working 21 on them but it was a lag problem with getting the QC people 22 out to look at it and verify that it was done.
That caused me 23 to personally go through the list and say, "okay, here are the 24 items I want verified that actually have been done at this Aca wel Repenws, Inc.
j 25 point in time."
l
..___m._____...._.._,
x 1
l jrb30 30 1
Q What was your -- why couldn't you wait for them to t,
2 get the QA-QC people back in to go through the list?
3 A
I felt that if the work was done it was not fair to the
. (~ \\
4 licensee to hold him up waiting for a paperwork trail to be 5
finished.
6 Q
The QA-QC people work with the licensee, is that 7
correct?-
8 A
Yes.
9 Q
So in other words, if the licensee did not have enough 10 people to keep up with the paperwork, I&E took the responsibility 11 to do that review for them?
12 A
I had to accomplish the review one way or the other.
^
13 Q
Why?
N 14 A
Because I had to assure myself that there were not 15 items on that list that should have been done prior to 16 licensing.
17 There are two ways of doing it:
I could either tell 18 the licensee, "do.everything on the list, and call me when you 19 are through," -- which is not realistic.
20 Or, you can go through it with the licensee and say, j
21 "okay, here are the types of items," -- which is what I did.
22
(
The licensee can come to you with a proposal and ask; 23 that's kind of a mutual thing; it was "here 's the types of things 24 c
that have.to_go away."
And we arrived at an agreement that these Aa f>WRgewn,W.
f 25 were the things that would be done.
i
jrb31 31 1
The -- even with that sort of thing, the licensee
(,
2 would go through and come up with his list, "these are the items 3
that I have to get done," but that, then, would leave me (I
4 in a position that if I did not look at the list, I would not 5
know there was not something on there in the types of items we 6
had established, that needed to be done that would not remain 7
on that.
8 So you really have to go through the list at some 9
point in time, anyway; no matter whether he comes to you with 10 a proposal, or you go through the list initially and say, "do 11 all these things."
12 Q
Is there an established I&E procedure for this?
4
(
13 A
Not, really.
14 Normally, the NRC procedure is kind of a sit-back 15 and you.make a proposal to me, and I'll tell you it's all right 16 or not.
It would be the normal function.
17 But that leaves you with the problem that, you know, 18 it's my responsibility to assure that there aren't any items 19 on that list that should have been done that the licensee may 20 have overlooked.
21 The only way I can do that is by looking at the list; 22 so in my spare time when there weren't other things that needed 23 to be done, then I would take a look at the list.
24 BY MR. VANDENBERG:
- An Asl Rego,te,s, Inc.
25 Q
Mr. Kellogg, did anyone at any time express to you E
i
jrb32 32 1
a concern that the construction or test program for TMI-2 (1
was being rushed, or that too much was being attempted in too 2
3 short a time?
(.
4 A
I would say no.
5 You normally have the delays that you see as you go 6
through the record, as to when they wanted and operating license 7
and when the? felt they would be ready to load fuel; we make 8
comments in our letters. -
9 The October 26 letter is an example of that, with 10 respect to what we feel the licensee -- whether we feel the 11 licensee can make the date or not.
12 Again, it is typical that the optimistic schedule e
13 is there and they move it only when the date passes.
I think 14 Murphy's Law comes into account here, it basically says, you 15 know, the job will fill up the time that is allowed for it.
16 So what you do is you schedule optimistically, and when you 17 are forced to change that schedule, you change it to another 18 optimistic schedule.
19 And by that way, you manage to accomplish the task 20 in the shortest possible time.
You find that in licensee's 21 schedules for outages, you find it in construction of the plants 22 you find very few of the plants that actually say, "this is
- (
23 going to be my date," and get there by that time.
It is just
-24 in the way you operate.
- Ace to n porwes, ene.
25 Q
Are you familiar with an incident where in early s
=
m_
jrb33 33 3
1978 a former employee at the TMI-2 site came to I&E with a
( 'j 2
report of faulty welding that had occurred in prior years?
3 A
No, I am not.
(:
4 There was one allegation, as we call it, if I remember 5
correctly, made with respect to structural steel and problems 6
that might be encountered with structural steel.
But, no, I 7
know of no allegations as to faulty welding; no.
8 Q
Didyou investigate this structural steel allegation?
9 A
No.
jo I did look when I went out to the facility at the 11 steel, after I was aware what the problem was;
""t that was 12 followed by our Construction Branch, I believe.
,m 13 It had to do -- it wasn't anything the licensee had V
34 done, or that his constructor had done; it was a fabrication 13 problem that they had found at a vendor's plant.
16 In other words, these large steel I-beams would come j7 out -- there was a way of radius'ing cuts where you bolt these 18 together, where you cut the webs, and you radius the cut.
19 Evidently the machine they had used or the person that had done 20 it, had overcut some that had been supplied to another licensee, 21 and then had gone back and just filled in with weld material, 22 that area that had been overcut, with no explanation -- painted, 23 it looks like the rest of it.
24 They had experienced a problem with this vendor.
I Am.
rQ Rgorwes, tm, i
25 can't remember the vendor's name -- that had supplied the same i
.=
jrb34 34 that was at TMI-2.
y Q
Were you at TMI-2 when United Engineers and Constructors 2
were replaced by Catalytic, Inc.?
3 A
Yes, I was.
4 Q
Do you have any insight into the reason why the 5
licensee changed constructors at that point?
3 A
It is not abnormal for a constructor to change at that 7
p int.
If you look at TMI's history, and I don't know when they 8
^
started Unit-1, but a lot of the people that worked on Unit-1 9
finished and then walked down the other end of the island and 10 worked on Unit-2.
11 And there was probably about at least a ten-year if 12 n t a fifteen-year career right on that island in the building
{
13 area if you were a pipefitter or a welder, you have a tendency ja after living in the place for fifteen years and that has been 15 your lifetime to not wish it to come to an end.
And the people g
that had been working there had a tendency not to get the 17 utput that you got in the initial stages, 18 So it is not abnormal; if you look at the Salem units, j9 they did basically the same thing at about 95, 98-percent 20 mplete, they basically fire the constructors that they had, 21 and they bring in another group thac does not have the longevity 22 i
there, if you will, to finish the job.
23 24 And it is primarily because they do get the output
~
As pW Reporwn, Inc.
25 ut of the people that are going to be leaving.
If they k2os j
l 1
l
jrb35 35 i
i they are going to be leaving, they'll put it off as long as they 2
can, of course, to get time to look for another job.
3 Q
Once the operating license --
4 A
Now, they did retain -- I'm sorry.
5 Q
Go ahead?
6 A
They did retain U&E and Catalytic management control 7
and key people, UE and C people there for -- what do I call it?
8
-- coordination of the project.
9 In other words, they just didn't walk in and i
10 Catalytic started with a whole new group of procedures.
It is Il rather an involved thing to break in another outside contractor 12 because of the quality assurance programs; they've got their 13 procedures and everything.
They maintained the QC and Catalytic I4 came right in under U&E management, so to speak, and provided 15 the laborers and first-line supervision under UE&C.
16 But the UE&C people never really changed on the management 17 level.
Mr. Karkala was UE&C, and he remained through the 18 evolution there as the head man on-site to control the work 19 activities for Catalytic.
20 Q
Do UE&C have a separate start-up and test engineering 21 group that also continued?
22 A
UE&C never had a start-up test group.
UE&C would 23 have been involved in some of the construction testing, which 24 would consist of things like hydrosratic tests and flushes Aa ps nm,im, inc.
25 of systems; but they were not involved in the start-up tests, I
jrb36 36 1
preoperational testing, start-up testing follows the UE&C
(-)
2 service contract.
They did maintain UE&C there for basically 3
a work force to fix things.
()
4 Q
once the operating license for Unit-2 was granted 5
In February of 1978, did you ever learn of a schedule that 6
existed for completion of power ascension testing?
7 A
If I was, I don't remember it.
It seems to me like 8
I had seen a three-month schedule, or maybe we have discussed 9
a three-month schedule; but sortly after the operating license 10 was issued, I was notified I was leaving Region-2 -- excuse me, 11 Region-1 -- and going to Region-2; and I started to turn the 12 project over to Don IIaverkamp at that time.
13 0
Before you left TMI-2 was any date or goal mentioned 7,
N 14 for reaching commercial operation in TMI-27 15 A
Not that I remember.
16 Q
When you turned over the plant to Don Haverkamp 17 what kinds of meetings did you have?
18 A
The normal turnover; I turned both units over to 19 Don -- consisted of the in-office turnover of records and 20 files, inspection reports, LER's -- Licensee Event Reports --
21 the outstanding items list.
22 Don, normally when I turncd _ne unit over to him, Don 1
23 is very through to ensure that things are accurate; and he 24 would basically go through the back history of inspection A
e noemn, sne.
25 reports to ensure all the items open were in fact closed; and 4
.~
jrb37 37 1
the ones that weren't in fact appeared on the open items list.
C./
2 We would go through the outstanding items and discuss 3
what the particulars were at each one; and the way I did p'
4 business, I had,in addition to this list -- this list was an 5
index in a book that I had; and I would take each inspection 6
report and cut them up for the appropriate item, and paste them 7
on an individual page in the book.
3 And then as I went back and reinspected each item, 9
if in fact the licensee had done something, then I would note 10 what the inspection numtar was, and what he had done there; 11 so you had a track record every time it appeared in an inspection 12 report, it was on the same page, until you had the final close-
,m 13 out.
N 14 So it was relatively easy to sit down and go through 15 with Don the outstanding items that existed at TMI, both units.
16 Then we would also have on-site inspections together 17 such that he could become familiar with the units, and also 18 with the personnel he would be interfacing with.
19 Q
Did you have similar kinds of meetings when you took 20 over the plant in May '77?
21 A
Yes, I did.
22 O
You were there for about ten months, then?
23 A
Yes.
24 Q
Was that considered a relatively short time to be 3
. Acet r0 Reconen, Inc.
25 assigned to a unit, actually to be assigned to a site?
l
jrb38 38 1
A It -- there is no requirement in I&E as to the length 2
of tour.
It is short, it was shorter than we anticipated when 3
I initially went there.
I was assigned to TMI-2 because I
( ',
4 was -- I had finished the start-up testing on both Calvert 5
units; I was familiar with start-up testing, preoperational 6
testing; and I had helped on two other units, Millstone Unit-2, 7
and a little bit on Beaver Valley.
8 And I was the guy with the most experience to go into 9
that.
We did not have anather inspector at that time.
The 10 person I relieved was Tony Fassano; and Tony was going into the II
-- as an inspector -- the Construction Branch, as an inspector; 12 and the Operations Branch, there wasn' t another inspector who 13 was basically qualified to take TMI at that time.
14 There was a necessity to get someone there who had 15 experience, and to do so in a relatively short period of time.
16 Q
Do you think that Unit-2 suffered from an excessive 17 turnover of I&E inspectors, or from a lack of fully qualified 18 inspectors available at all times?
19 A
No.
I think that by my going there, having been 20 involved in the licensing of several other units, that that 21 was probably more advantageous fur them than giving them someone 22 who had never done it before.
23 There are a lot of problems that would have arisen 24 that I was able'to steer the licensee clear of.
An Asl Reporters, Inc.
25 MR. VANDENBERG:
Let's take, a five-minute recess.)
e 1
.~
jrb39 39 1
(Recess.)
(
2 MR. EVANS:
Back on the record.
3 BY MR. EVANS:
( ~'
4 Q
Mr. Kellogg, could you elaborate what you mean by 5
" steering the licensee away from problems"?
6 A
Yes.
7 The Unit-1 -- well, in getting to the organization of 3
TMI, you have GPU Service Company, who is involved in the 9
construction and the testing of the unit.
They then turn it over 10 to the operations side, which is actually Met Ed.
Met Ed has 11 a fully functional staff there at this time -- Metropolitan 12 Edison Company -- who was the licensee that was going to be 13 operating the plant.
14 The licensee at this timois involved in system 15 operation, extending watches in the plant, and in generating 16 procedures for operations, emergency alarm, and the various 17 surveillance tests that come out of the technical specifications 18 The thing that had changed was the type of 19 technical specifications tha't they were going to have on Unit-2 20 versus the ones that they had for Unit-1 that they were 21 familiar with.
22 You will find throughout the average plant history 23 that the licensee has a learning curve with respect to how to
/-
24 utilize his technical specifications, and what they in fact Aa Am no.,
. inc.
25 ' mean.
You will find early in their lifetime they violate s
u
40 jrb40 several of these due to their lack of knowledge of the
(/
specifications -- they overlooked it or they overlooked the 2
3 surveillance interval, or the surveillances they actually write
(
does not perform the check that the specification requires.
4 5
The new specifications that were going on Unit-2 6
were the standard technical specifications for B&W units at that 7
time; and they contained many more surveillances and other 8
nuances of reporting requirements, of surveillance requirements, 9
a ni action required by the licensee.
io once the specifications came into effect and -- what ij I mean by " steering clear" -- is I was able to by having gone 12 through licensing a couple of other standard technical 13 specification plants, point out areas that Met Ed had apparently s
j4 not looked at.
15 And I say "apparently," I could find no method by 16 which they were tracking various items.
j7 For instance, it is a requirement that you perform 18 a surveillance that is required for a mode of operation or an 19 operational mode prior to entering that mode the surveillance i
20 must be current.
By current it must be within its frequency:
21 if it's a monthly, you have to have it done within the past 22 month, or you have to run it before you increase plant 23 temperature, pressure, or whatever mode.
24 In the new construction and initial criticality in Ace. rj Reporters, Inc.
25 a lot of cases what the licensee does is ha takes credit i
l
jrb41 41 I
for having run the preoperational test, and that would be the
, (r 2
first surveillance.
Whatyou need to do in that case, though, 3
is too track when the operational test was done to ensure you p
4 don't exceed the tLme limit before you enter the mode, or else 5
you have to have the surveillance done, also.
6 And they needed a system to do that.
So that was 7
one of the things that they had.
8 There were also other specifications which I 9
questioned their ability to meet, because they were upgraded to from what they had seen before.
Some of these had to do with Il charcoal filters and various filter drains.
12 The new specification called for some testing that I
[~
13 knew another plant of the same vintage had a very hard time 14 meeting.
I pointed this out to them.
That one evidently fell 15 in the cracks, because iust prior to licensing or just af ter-16 wards, they decided they couldn't meet that specification.
17 There were other examples of this type -- this is what 18 I term " steering-clear problems" -- I don't like to see a 19 licensee get in trouble because he is unfamiliar with something, 20 if I have the time to point it out to him beforehand.
It 21 terves no useful purpose to the health and safety of the public 22 that the licensee blunders through this, if there is some guidance 23 I can glve him to cause him to be better.
24 Q
Let me follow up on this thought-by asking what your
- Aa pel Reporters, Inc.
25 t
-jrb42 42 1
understanding is of the regulatory requirement that a licensee s
2 be technically qualified to operate and construct a nuclear 3
unit?
4 A
My understanding of that is that the licensee has 5
the technical people in his organization that understand and 6
are familiar with the plant, that know how to operate the plant, 7
and that they are familiar with the rules and regulations 8
and that they make their best attempt to meet those rules 9
and regulations.
10 Q
In your experience with Three Mile Island Unit-2 11 do you believe GPU or Met Ed was technically qualified to 12 construct and build-up that plant?
13 A
Yes, I do.
14 O
This is true in spite of the fact that you believe 15 that there was a need for some steering away from problems?
16 A
Yes, I dot 17 The steering, if you will, were things that I had 18 seen, you know, other utilities fall into the trap; and there 19 is no sense in my mind to go ahead and reinvent the wheel and 20 say, " gee, I knew that was going to happen."
You know, that's 21 kind of entrapment.
22 I feel, you know, if I can provide them information, 23 "let's do it right the first time," that because of their 24 7
_ relative inexperience with this type of a specification that A s,,m n o w a n.s=.
25 I just don't believe in operating that way.
It's like I got the
JRB43 43 1
answers in my shirt pocket, but I am not going to tell you what 2
tey are until you fail the test.
3 I would say there are several areas that I attempted
(.
4 to give them guidance in that they managed not to steer clear 5
of.
6 There is one specification with respect to in-service 7
testing of components, was one of them; they had to take some 8
immediate action prior to licensing, because I made it a 9
license condition they obtain written relief on the testing.
10 And they felt I was being unreasonable in this case, that I 11 hadn't told them about it six months prior to that.
12 BY MR. VANDENBERG:
13 Q
When you say "I had told them about that," was it s.
14 orally you conveyed it to them? -- a specific member of the 15 organization?
16 A
Yes, Mr. Seelinger, who was Unit-2 superintendent at 17 that time.
18 MR. VANDENBERG:
Off the record.
19 (Discussion off the record.)
20 MR. VANDENBERG:
Back on the record.
21 BY MR. VANDENBERG:
22 Q
Mr. Kellogg, what were the circumstances when 23 Mr. Seelinger came to you just prior to the granting of the 24 OL7
- Acef to nooners, Inc.
25 A
Just prior to the granting of the OL, he had I
jrb44 44 1
discovered some of these nuances of the tech specs that he
(';
2 felt his preoperational test would not meet; and he would 3
require waivers of the technical specifications to continue
('.
4 with his test program, and to go critical and start his power
~
5 ascension testing.
6 Specifically, the one that I remember was this 7
filter, charcoal filter testing, or the results of their 8
charcoal filters would not pass the requirements of the 9
specification; and they had to go to Licensing at that point to in time and get it resolved.
II This had been something I had pointed out to them 12 six months before, that they needed to look at this, because
[
13 it had happened in another plant I.had been involved in.
Id They also could not pass this specification.
15 And I did not want them at that point in time to get 16 to the point of, okay, once specifications are a portion of 17 the license, and the license is issued, it is harder to change 18 them than it is to get an amendment to them, and to get a 19 waiver on them before they actually become part of the law.
20 And at that point in time there was nothing, you know, 21 he came to me and said, "what do I do?"
And basically, I said, 22 "you go back to Licensing and tell them, oh, by the way, I can't 23 meet these, and ask for a waiver on them."
24 c
Q And was that done, as far as you know?
, Aa
,w s neomm, Inc.
25 A
As far as I know, it was; and I believe the waiver i
~.
. ~ -...
45 jrb45 1
was granted for the first refueling.
h 2
Q There was no waiver needed at the time of granting 3
the OL?
4 A
No, because the specification wouldnot have come into 5
effect until they brought the plant up,to temperature and 6
pressure.
7 Since the specifications are tied to the operating 8
modes, your initial mode is what we call mode-6, which is 9
refueling.
If you care to go through -- this is a secondary 10 document which is another one of the outstanding items list --
11 it gives you an idea of how we go about the preoperational 12 test program, when we talked before about all the tests done.
^
13 This is a listing of the tests th'at were not done, and when
_s_
14 they would be done by.
15 And as these later letters come out, these would be 16 upgraded as to the percentage completed, what was going to be 17 done, at what time.
18 In other words, the first one here happens to be 19 part of the fuel load equipment, TP125678, which is actually 20 for test results.
21 MR. EVANS:
Why don't we have this marked as 22 Exhibit 1117.
23 (Letter, February 2, 1977, w/Atch, 24 was marked Deposition Exhibit No.
Aa - mre noso,te,s inc.
25 1117.)
jrb45 45 I
THE WITNESS:
But that document then becomes a portion
[ ')
2 or the appendices from that document become conditions of the 3
license.
(
4 If you look at Three Mile Island's license as it was 5
issued, you will find that most of those appear as conditions 6
for the license to be accomplished, with either a given time 7
frame, or by prior to entering a given mode of operation.
~
8 BY MR. VANDENBERG:
9 Q
So that means, then, that the operating license 10 definitely did contain requirements the licensee had to perform II within a -- or rather by -- a certain date?
12 A
Either a date or an operating mode.
Some were tied 13 to dates, some were tied to operating modes.
Id There was a large change in the fire protection 15 program about this time, and there were, I believe, dates 16 tied to that, not operating modes.
17 There were system changes that had to be made.
These 18 came as a result of an on-site review; and they were tied to 19 future dates down the line.
20 Moreof the preoparational testing things were actually 21 tied to operating modes -- before entering this mode, he had 22 to finish this test, review it, correct deficiencies; and then 23 he was clear.
24 r
Now, the way we functioned in this case is we go out Ao,
,JerW Reporters, Inc.
25 each time the licensee thinks he is ready to go up to the next I
l
jrb46_
46
+
mode.
(
In other words, the first thing he does is he fuels 2
3 the reactor.
Then he goes into mode-5, when he puts the head 7\\
s 4
on, which is called shut-down; when he wants to go to mode-4, 5
there are conditions in here -- and mode-4 is the heat-up phase.
6 He must then finish these.
7 We go out and inspect them.
We write a letter to 8
ur headquarters to transfer to licensing with the fact that we 9
have reviewed them, that he has completed all of the license 10 requirements; and that we feel that he is ready to go to the 11 next mode.
12 Q
Mr. Kellogg, I notice that this Exhibit 1117 33 has three enclosures, A, B,
and C; the memo states that the items ja listed in Enclosure A will be completed by February 7, 1978.
i3 That is one day prior to the actual issuance.
16 And I notice in Enclosure B it says, I&E recommends 37 the following items be completed prior to entering operational 18 mode-4.
19 And similarly for Enclosure C, that those items are 20 being recommended by I&E to be completed prior to initial 21 criticality; that is mode-2.
l 22 D es that then mean that there were no items to be
(
23 made a part of the OL which had to be completed by a specific 24
-date, only those items that were required for completion by Ad
,a neoo,se,s. ene.
25 specific mode?
e t
P jrb47 47 A
No.
- (
There were additional items -- those were the I&E 2
3 items and we tied them all to a mode.
4 In other words, we did not ca' e to put a date down r
5 and say, have it done by this time; because he may have been 6
ready to go in the mode before that time or after that.
7 So what we do is tie them to the change in plant 8
status, if you will, when the operation modes would require 9
the systems be functional, we require them to be tested.
p)
Now, there were additional items which NRR had 11 with the licensee.
This fire protection business is one of them.
12 They had just completed the review.
The licensee met with 13 Licensing, NRR, and agreed to a number of facility changes r
14 that would be incorporated in the facility.
15 Instead of tying those to an operating node, NRR 16 tied those to actual specific dates, or first refueling to j7 have these completed, but by a given date, I will complete 18 this, whether it's an engineering review -- whatever it was, pp We would also verify that he met the dates as well 20 as the operating mode items.
21 0
After February 2nd, but on or before February 8th, 22 1978, did you have some communication with NRR to confirm to 23 NRR that all the Enclosure A items, that is 23 items, were in 24 fact completed?
Ace #
rd Reporters, Inc.
-25 A
Ye8-i 1
jrb48 48 1
The Licensing Project Manager and I were in contact 2
on almost a daily basis from the Island to the Licensing Project 3
Manger.
r 'T 4
Q Did any of those Enclosure A items not get completed 5
by February 8, to your recollection?
6 A
My recollection is they were not.
7 Q
Finally --
8 A
In fact, the last item that I remember specifically 9
closing was one of these on fit of water-tight doors and 10
' flood panel, I think that was the last item that we closed on 11 the list.
12 They had one electrical blackout in the table skirt 13 that hadn't been reported.
s 14 Q
Okay.
15 Mr. Kellogg, in your experience once an OL is issued 16 does the Office of Inspection and Enforcement have some 17 internal and perhaps informal guidelines relating to the maximum 18 time period or minimum time period the licensee should take 19 to complete their power ascension testing?
20 A
No, there are not any informal or internal guidelines 21 with respect to that.
22 There are requirements which are placed in the 23 licensee's test program which are contained in manual chapter 24 2514 with respect to the start-up test program -- the conduct
~ Ace /
ra narwes, inc.
25 of the start-up test program.
I
jrb49 49 1
The problem that we had previously experienced was b
2 the licensee would start his start-up test program, he would 3
escalate through the various stages and complete the program
{T 4
~
up to 100-percent power; and then put the unit on the line and 5
run it for maybe up to a year.
In fact I believe at one of the 6
units it was two or three years before they actually completed 7
the start-up test program.
8 But there was at that time no requirement placed in 9
his program that he must perform the tests within a given period 10 of time.
II The way that we handled that, it's a matter of 2514, 12 there is guidance now with respect to the tet program that we s],
13 basically force the licensee to put in his test program with 14 respect to the conduct of it; and the guidance goes something 15 like if he is going to be at a power level for an excessive 16 period of time, which I believe is defined as to be a month, 17 at a powar level, let's say just 50-percent; he must complete 18 all of the tests at that power level within that month period; 19 or reduce power to the plateau for which he has fully completed 20 the test program -- in this case back down to your 20-percent 21
- level,
^
22 So we have not done anything with respect to how fast 23 he can do it, but we have put restrictions on it as to how long 24 he can take.
If he got to 100-percent and did not wish to do Ac jwd Reponen, Inc.
25 a test, he would have to go to 80-percent, which would be the I
jrb50' 50
~
1 last plateau, and he would have to remain at that plateau 2
until whatever was holding up his test program was fixed or 3
repaired, or plant conditions were met, before he could go back 1
iT i'
4 up to the 100-percent plateau and finish the program at that 5
level-6 Q
Does that one-month period refer to a continuous 7
period, or could that be broken up, for example, for one week, 8
then with a time separation and then three weeks; and at the 9
end of the three weeks they would have met the one-month 10 criteria?
11 A
I don't think I understand your question.
One month 12 was -- let us say he goes to 50-percent power and he starts
~
13 testing; the one month would start when he gets there; if he s.
14 cannot finish all the tests of that program at that level because 15 of a problem with the plant, then the requirement would be that 16 he reduce power to the next lowest plateau for which he has 17 completed testing.
18 Q
But if it went to 50-percent fa one week, went back 19 down to 40-percent for a week, and then back up to 50-percent, 20 and then the second period back at 50-percent after three 21 weeks he had not completed the 50-percent test, would he then i
22 be required to go back to 40-percent?
Or does he still have 23 an extra week?=
A=/,
24 A
I would think he would have an extra week.
c agawn. w.
25 Now, there are tests where he trips the reactor 1
=_ ;
=.
~
a -. =
jrb51 51 1
and -it brings it right back up again; but the purpose of the 2
time limit of the 30 days, he would not remain at 50-percent 3
for 30 days without having completed all the tests at that plateau.
We did not wish to place a restriction on him that 5
said, you've got to get all the tests done within a month.
6 But, from the time he gqt to 50-percent, if for some I
reason he stopped testing, and just ran for 30 days, he would have to go back down to a lower power level and stay there 9
until he got his test program completion back up to where he 10 could go back up to 50-percent and'run the tests that he had 11 to do there.
12 Q
Would that requirement also include the full-power 13
'^'
generated-trip test?
14 A
Yes.
15 0
So that the reactor would be prohibited by I&E 16 from continuing to run at 100-percent power without doing that 17 test?
18 A
Yes.
19 Now, there is, ifyou look at Reg Guide 1.68, there 20 are two tests in there.
There is a turbine trip from 100-21 percent power.
There is also a reactor trip to 100-percent.
22 And what we do in the early stages is agree with 23 Licensing that one or the other would be run.
Well, we would 24 g
,3,% %
agree with both of them being run, if he chose to do a reactor 25 trip and then a generator trip, if he agreed to do the generator i
I jrb52 52 trip we would not require the reactor trip independent of that, 1
2 because the generator trip is a more severe test; it also trips 3
the reactor.
4 BY MR.. EVANS:
5 Q
Mr. Kellogg, while you'were at the site did you notice 6
any transfer of workers from Unit No.1 to Unit No. 2 in order 7
to complete work on Unit No. 2?
i 8
A I did not specifically notice the transfer of workers, 9
if you will.
I did have some problems with Unit No. 1 during 10 this period of time in that I felt that they were somewhat 11 neglecting Unit 1 in letting it go downhill by the emphasis they 12 were putting on Unit 2.
13 And some examples of this would be, in the adminis-14 trative area the administrative aide that controlled procedural 15 revisions and getting changes put in was transferred to Unit-2 16 to establish the system down there.
The people that replaced I'7 them on Unit-1 really didn' t know what they were doing for a Ir,
- while, 19 And they had had a very good system on Unit-1.
20 In addition I felt that the cleanliness of the No. 1 21 Unit was also being degra(ed somewhat by having a lot of people
~
22 work in Unit-2; and I talked on several occasions with the 23 Unit-1 superintendent about this, and also with Mr. Miller, who 4
24 was the station super; he was one of-the flow people between the 7
Aa w w n co m n,inc.
25 two units.
7
~.
jrb53 53 They were looking hard at Unit-2 and I felt they 1
2 were doing so a little bit to the neglect of Unit-1, and 3
the enforcement history started to go up on Unit-1, and it
(~T 4
concerned me.
So I had discussions with Mr. Miller about it, 5
and the fact he could not neglect Unit-1 while putting all of 6
his forces in Unit-2'.
We were not going to say, okay, that o
7 other unit doesn't exist until we get this uni' on the line, i
8 then we'll go back and look at this one.
9 Q
Did Mr. Rebelowski have any involvement in the 10 power ascension testing at Unit No. 2 to your knowledge?
11 A
I do not know the answer to that.
The support section 12 which covered start-up testing had brought in new individuals
~
13
-- prior to this time the project inspector had been the 14 primary start-up test reviewer.
They had transferred that 15 function to the support section; Bill Coleman was supposed to 16 be taking overthat function and had performed start-up test 17 review on the procedures for the unit.
18 Ted was involved in preop testing and hot-functional 19 testing, and I believe that is where his responsibility was.
20 In other words, it did not involve start-up tests.
21 Q
Mr. Kellogg, what does the term " commercial operation"
^
22 mean to you as an I&E inspector?
How does it affect your 23 jF'?
24 A
Commercial operation to me as an inspector means
.Ao foral Reporters, Inc.
25 nothing.
It is tha utility term that I believe adjusts, again,
~
w
jrb54' 54 1
their rate structure and the payments with respect to the 2
facility, and the fact that the facility is now a reliable 3
power source, that changes the amount of revenue that they could 4
obtain.
5 But as far as our inspection program, commercial 6
operation doesn't enter into it.
7 0
In the course of performing your normal duties 8
their normal duties -- do I&E inspectors become aware of the financial concerns and set-ups which are facing the company 9
10 (n putting the unit into commercial operation?
11 A
The familiarity that I have with that portion of it 12 is what I just told you:
that is what I think happens; and 13 whether it does or not, I don't know.
c 14 It really has no effect on me one way or another, 15 so I didn't concern myself with it.
16 It makes no difference to me what the utility is i
17 paying, or how much money they are collecting.
It has nothing 18 to do with my inspection program.
19 Q
And there is no organized system at I&E to collect 20 information on financial position of a utility and make that 21 available to inspectors?
22 A
No.
23 The only financial information that is collected at 24 all, I believe, is by NRR in the application which requires Am.r
,g Repo,w s,;nc, 25 a licensee to prove he is financially capable of constructing i
g
jrb55 55 I
a plant and operating it, and.'ssuming those costs.
And that s
2 involves financial statements by the company to NRR, which 3
sometimes are contained in the FSAR.
O 4
But that is as far as the financial information is 5
concerned, as far as I am concerned.
6 MR. EVA:fS :
Off the record.
o 7
(Discussion off the record.)
8 MR. EVANS:
Back on the record.
9 BY MR. EVANS:
10 0
Off the record, Mr. Kellogg, you were talking about a 11 reference to commercial operation which you believe exists?
12 A
Yes, I can't find it; I thought it was Reg Guide 1 68, 13 but I did not find it; but memory serves me that there is 14 a reference to the submission of the start-up test report within 15 some period of time af ter completion of the '.est program or 16 commercial operation.
17 BY MR. VANDENBERG:
18 Q
Mr. Kellogg, are there any other areas of information 19 that you think are relevant to the Special Inquiry that you a
~
20 would like to bring to our attention at this time?
21 A
There is nothing I can think of that we have not
~
22 discussed.
23 MR. VANDENBERG:
All right.
24 Thank you very much.
Aa w2 Rewwts, im 25 MR. " VANS:
Let us make it clear on the record we are
. =. -._
jrb56 56 recessing Mr. Kellogg's deposition, rather than terminating 1
2 it, on the outside possibility we might want to talk to you 3
again.
We don't expect to do so, but we would like to have b
4 that opportunity, should it become necessary.
5 Again, thank you for coming today.
6 (Whereupon, at 10:25 a.m.,
the deposition was recessed,)
7
)
8 9
10 11 12 13 14 15 16 17 18 19 0
20
. l 0
21
-22 O
23 24 i
orei Reporters, Inc.
25 i
l
)
-