ML19308B675
| ML19308B675 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/06/1979 |
| From: | Herbein J Metropolitan Edison Co |
| To: | NRC - TMI-2 Bulletins & Orders Task Force |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001160637 | |
| Download: ML19308B675 (40) | |
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2,* \\/5 j i _______________________________-_x j l h.' 4 j! 5 NUCLEAR REGULATORY COMMISSION' S ') L-6 TMI SPECIAL INQUIRY GROUP p-7 __-_--_--___--_--_--_-__-_-__-x 8 (Oral deposition of JOHN GILES rCRBEIN) 9 10 APPr R NCES: 11 SPECIAL INQUIRY GROUP 12 George Frampton, Jr., Esquire David Evans, Esquire j 33 Mr. Dennis Allison 9 Mr. Ronald Haynes 9 15 METROPOLITAN EDISON COMPANY 16 SHAW, PITTMAN, POTTS & TROWBRIDGE By: Matias F. Travieso-Diaz, Esquire j7 1800 M Street, N.W. Washington, D. C. 20036 18
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'aken at: 20 Three Mile Island 9:30 a.m., Wednesday g Trailer No. 11 September 19, 1979 Middletown, Pennsylvania (i g h, 23 80011h6$th 25 wo sen stewoonaeaic stevies. issa o60 wi66 nome. wvowissmo. sa..issio I
== 114 o fphasesoftheincicent. I l It was difficult to creciselv determine source terms 4 3 because the in-plant monitors were off scale. That posed i i a difficulty. But with the portable instruments we had 4 5 and the TLD readings and air samplers, that I mentioned, I 6 think we had a pretty accurate picture of what was occurring 7 off site. 8 Q Would it have been useful to have more on site 9 but outside the building type monitors to measure source 10 term? I am specifically thinking, for example, about the 11 suggestion that I saw in some of the lessons learned papers 12 drafted by plant personnel about monitors floating on 13 balloons over the plant and so on. L/ 14 Would it have been helpful to have towers or something 15 on top of the stack or up on the roof of some of the buildings 16 with instruments on them? Would that have given you a lot 17 more information. Or should that information be available ja from stack monitors had they had the right number of -- 19 A I think that it would have had the on-site plant 20 instruments had a sufficient range. I think we would have 21 been able to cover that. I don't know that I agree that the 22 need to suspend detection devices from balloons or from ~ 23 elevated devices is really necessary. 2a Q Let,me turn to another subject now. %gl 25 As you know, there have been allegations in the media l l l l . omen str=cea..mc eravier ms oso mLL ao.o. wvomssi=e.. 'ieeio l
/ 3 115 g l i 1 that Unit Two was rushed into commercial operation before the i 1 n \\ 2 end of calendar 1978 in part in order to realize certain I 3 tax or rate advantages. And that was one of the issues uhat 4 is within the scope of our inquiry. I know you have been 5 asked questions about this in prior testimony, and I will 6 try not to repeat those. But we have some more specific l 7 questions that I would like to ask you. 8 What is your understanding of the significance of putting 9 a unit into commercial operation? Do you see that as an 10 accounting designation primarily? 11 A Well, I think that's one of the things that I view it as. 12 ~ 33 But it also indicates that the plant has been through b 34 the start-up and test phase, it has met the Nuclear Regulatory 15 Commission requirements for ascension to full power operation. Additionally, it means, in our case, that we have been 16 37 through a pretty thorough in-house review in a number of 3g areas that are documented in a commercial review procedure which we use. ), 20 So, it means that the unit, having met the Nuclear 21 Regulatory Commission requirements and the in-house require-22 ments,is really satisfactorily in a position to be declared V. 23 commercial and in turn is a used and useful unit ready for service to the public. And in turn ready for inclusion 24 W1 25 in our rate base upon which the company earns the return asceseCK STENOOmapNeC SERveCE. tal3 OLD MILL ADAO wv0esesstN4. PA. 19410 e
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116 I i 1! -{dacignatedbythePublicUtilityCommission. 2 Q It is your understanding that the date that the i i 3 unit is declared commercial is the date that it becomes 4 included in the rate base under applicable state utility 5 regulations? 6 A No, that's not the case. That's to be applied 7 for outside of the -- and in addition to the forum wherein 8 it's declared commercial. Getting it included in the rate 9 base is another process that requires hearings by the Public 10 Utility Commission before an Administrative Law Judge who 11 in turn then hearing our request and reasons for the request, 12 as well ar any intervenor concerns on the part of the Consumer 13 Advocate or Public Utility Commisson Staff, then in turn (d 14 makes a recommendation to the Public Utility Commission with regard to an increase in rate base and allowable rate of 15 3 return. 17 Q So it is your understanding that the date on l i 18 which the plant may be included in the rate base may, 39 depending on the Utility Commission's decision, be a day later than the date the plan was declared commercial? g A It may not be not only a day later, but it could 21 be several months later. g Q A date later, I am sorry. 23 ~ A A date later, yes. That's correct. g N3# Q Could it also be a date earlier than the date 'y 1 I l womeCR BTimoenaeweC samvect. 1818 OLD wiLL moaO. wvonsistems. pa. testo S
117 li 1 i 1 ' on which the plan goes into commercial operation, according 8 .id to your understanding' o Ireallydon'Jknowhowtoanswerthat. I feel A 3, I 3 i 4 i that with the in-house procedure that we established, which i 1 5, basicallv said the olant has been through the start of the test phase, met the Nuclear Regulatory Commission requirements 6 i 7 it's been through our in-house review and approval phase, i g is then ready for commercial service, precludes any declara-tion with regard to inclusion in the rate base prior to 9 being declared commercial; I don't think it works that way. 10 I think the unit goes through the requirements that jj I have outlined and hen it's declared commercial and then g subsequently gets included in the rate base. g I l To have it included in the rate base without being g commerical I don't think is possible. 16 0 Is there any direct connection between finishing 17 the power ascendance test required, or whatever is required 18 by the NRC, that step by step process, anddeclaring a plant 19 to be commercial? 20 A We decided to do that. That was an in-house 21 decision. I guess it would have been possible to declare the 22 unit commercial at a power lower than a hundred percent. 23
- p. Q Have you ever heard of that being done in fact?
24 A Yes,, I have' heard of that being done. That is W 25 possible. 1 eeOseicst Stree00maeusC Stavict. la t a OLD teeLL WO A D. wYoss'S SING. ' A *19410 e
118 } l $ Q So as far as your understanding was you could S 2 well have declared the plant, or sought to declare the l 3 plant commercial before completing the NRC's hundred percent 4 power testing? 6 A We could have done that. 6 0 You chose not to do that? 7 A That's correct. a Q Do you know if there would have been any cost pen-9 alties associated'with that in the sense that once you 10 have declared a plant commercial it is supposed to be 11 available to provide a hundred percent of rated power? 12 A I am not really sure I know how to answer that. 13 0 Let me come at it a little bit differently. (/ ja Do you know whether I am correct in thinking that once a plant is declared commercial and is supposed to be available 15 16 the grid, you are obligated to pay some cost penalty or t make some g contribution to the grid in some way for the time the plant then is down and isn't available to the grid? 18 A That's correct. We commit a certain amount of 39 capacity to the system and to the extent that we don't meet g that capacity why Chen we are subsequently penalized. So it's to our benefit to declare the unit commercial at some s~ specific power level that we are reasonably confident 23 we can meet on a regular basis. And in turn that means ,d e \\cl that the plan has got to operate at,an acceptable capacity. l 25 ( ....e..re.......e....... i.i oso. u.................. i.... L l e -~ w
119 l'l i 1[ Q What I was getting at in the previous cuestion'was i I l 2 whether you know if you could have declared'the plant 3 commercial at 60 percent of its maximum megawatts electric ratinc? 4 A That would have been possible. 5 0 That would have been possible? 6 A I don't think it would have been -- 7 Q Regardlessofwhetheritwouldhavebeenfinancial1h 8 advisable. 9 A Yes. 10 I would also point out that this is not my particular 3) area of expertise. 12 Q I fully understand that. 13 What I am really trying to probe is your understanding t.;/ J 34 at the time of what this meanu and the significance of it. A es. 1.5 0 I think you testified in a prior deposition that 16 you had been told that it would be desirable to go commercial g before the end of the calendar year? A Yes. 9 20 0 Do you recall who told you that, or whom you 21 had discussions with? 22 A I think we discussed it a number of times between 23 myself and Walt Creitz,with Bob Arnold. But at no time 24 during those d,iscussions was the intention to force the natural j l %2.0 l 25 process which one goes through with a new unit. There are man.cn sT =oona*=ic es= vies vais oss usu. noao. wvomissimo. en. vesio e
9 120 i
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cartain things that have to ba done to bring it out and make 1 I i 2' 'sure it's going to operate satisfactorily before it can really, 3 be declared ready for commercial service. 4 So while it was desirable, because as I understand it 5 there were certain tax advantages that would flow through, 6 not to the corporation, but to the customers, it was not our 7 intent at any time to force the plant into operation. g Q Let's leave aside for a moment the question of 9 getting the plant into the rate base and talk only about the 10 tax aspect of it. 11 Was it your understanding that there would be some tax 12 advantage to the company, whether or not it would flow 13 through to the shareholders or to the customers, that there 14 would be some tax advantages to somebody in getting the 15 plant into commercial cperation before the end of the calendar 16 year as opposed toa few days'in January, or January 15th, 17 let's say, 1979? Was that your impression? 18 A It was my impression that there would be advantages ~ But that that was in reality of minimal consideration. 19 20 That was not, by any means, a driving force to hurry the 21 Plant through its operational. paces so that we could 22 declare it commercial before the end of the year. 23 Q And you recall that you learned this in discussions 24 with Mr. Creitz and Mr. Arnold? That would be your general V 25 impression? ....e.. n..... .e.....es. .. n o. u,..... m...............
'b 1 93 I l 1' A Yes, that would be my general impression. ~ 2 O I believe that you set up a rather elaborate set 2 of criteria and anorganization to actually review and make 4 a determination as to when the plant would become commercial 5 -- in commercial operation, did you not? 6 A Yes, we did. 7 Q Do you know why -- that wasn 't done for Unit 8 one, was it, t.21 quite the same amount of elaboration, at 9 least? 10 A I would say that it was done. j; O That it was done? A But that it wasn't documented to the extent that 12 13 we documented it for Unit Two.
- bs' ja But all of the elements in the procedure that we used 15 to judge whether the unit was ready for commercial operation were in fact applied in a similar review on Unit one.
I 16 was involved in that review; Mr. Arhold was involved;
- 7 18 Mr. Verrocchi was involved.
I think the construction manager 19 at the time, Mr. Heward was involved. And all of those 20 same elements were reviewed in detail. I don't believe 21 the emphasis on documentation existed in 1974 as I think we 22 all recognize it does today. I am not sure of why. I 23 think that's just -- it would be L general observation on my 24 part. V 25 Q Did you ever hear, or did you ever learn that Mr. MosesCst STEMOORADM6C SERvlCC tot a OkO MILL 90 A O. WYOMIStiNO. # A. 19410
122 1 [ Dicekamp was the principal parson who initiated the need for l t ~ a more formal documentation of the various criteria to be 2 3 applied? A I don't know that I ever heard that, or that that's' 4 5 a particularly valid assumption. I think Mr. Arnold recognized the need for that, like we all did. I think Mr. Dieckamp 6 was involved in that recognition process. 7 MR. FRAMPTON: Let's mark as Exhibit 13 of this 8 date a document dated October 26, 1978, a Met-Ed/GPU document 9 entitled, quote, " Determination of Technical and Organizational-g Readiness for Placing Three Mile Island, Unit Two, into Commercial Operation." (Herbein Exhibit No.13 identified.) BY MR. FRAMPTON: 15 Q Mr. Herbein, I know you have been asked about this 16 document in previous testimony. 17 Is this a collection of the presentations made to a meet-18 ing on October 26, 1978, of people who got together to review 19 the status of the plant vis-a-vis commercial operation? i 20 A Yes,'that accurately describes this document. l l 21 Q And I believe in the front of that document is 22 a document listing criteria for commercial operation that. s 23 appears to have been signed earlier,in June actually, c2 that 24 year; is that right? .f;pi I g 25 A That is corract. uOhica ettNOOn AputC SteveCE 9413 OLD MILL RO A O, WYOsetSSING.
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I 1 ll 'O Do you know who developed those criteria, who actuallywrotetIem~andeditedthem? 2 3 .A. To gpe best of my knowledge Mr. Bachofer, who 4 reports to Mr. Arnold, was instrumental in actually drafting 5 this procedure, which was subsequently reviewed by the people who have signed the page 305 portion of the procedure, which 6 7 is titled" Determination of Technical and Organizational 8 Readiness for Placing a Generating Unit into Commercial 9 Operation." Q There is some mention in this document of full power gg testing in October. I presume that wasn't a realistic s
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possibility on October 26, 1978, was it? g A That's correct. I believe the plant at that 33 time was between 30 and 40-some percent. g 15 0 At the time of this meeting, was there discussion 16 about what a realistic date was at that time for going 17 commercial? 18 A I assume that there was. I don't remember the 19 specifics with regard to the general discussion. I believe 20 we were targeting for before the first of the year at that 21 time. 22 Q So you were definitely targeting for 1978 at that 23 point, namely, October 26th? 24 A Yes. On October 26th we were of the opinion V 25 that ne cculd complete the required testing, gain some W O ne:CR STgevogaapung gg#VlCE. 1813 OLD assgL aca0. wvOesessisee, ma isolo
-a 1?4 i l I l i !!oporating experience, and confident thct the unit was ready i 2 for commercial service prior to the.end of 78. l 4 3 0 Was a subcommittee formed after this October 4 meeting? 5 A Yes, one was. 6 Q Who was on that? 7 A As I recall, it was myself, Mr. Hirst, Mr. Bachofer. I am not sure if Mr. Arnold was an official member of the 8 subcommittee or not. 9 10 Q How about Mr. Wilson? b-A Yes, I believe -- )) Q Mr. Richard Wilson. 12 A Yes, he was a member of the subcommittee also. 13 \\ Q Mr.' Gary Miller, was he a member or not? 14 A I don't recall that he was officially designated g as a member, but he had input through me to the activities g of the subcommittee. l,e Q What was this subcommittee supposed to do? You have got a subcommittee now and presumably you have 19 to make a determination at some point about commercial 21 operation and whether the criteria are met. 22 But between October 26th and the end of the year, what 23 are these people actually supposed to do, as of October 26th, 24 if anything? V 25 A The charter for the subcommittee I think is tsOMsCN STtmOGeammtC stavfCE. 1413 C.D aseLL SOAO. wv0esiss'44.'A 13600
125 1 1 fairly wall documented with regard to the kinds of activities 2 and additional open items that we felt needed to be reviewed 3i before a recommendation could be made to the overall 4 committee that the unit should be declared commercial. I 5 believe the specific kinds of things we looked at, again, are fairly well documented. It had do with reactor coolant 6 system flow; the power level output from the generator; I 7 g think we looked at some of the operational aspects of the 9 make-up water system. And there may have been four or five ther items. I believe there was a list of some eight 10 to 10 areas that we wanted to look at in depth and know the g particular status of activity in these areas to satisfy ourselves that that was appropriate before we, as a sub- .b# committee, made the recommendation that the unit be declared 13 commercial. 16 Q If there were any major problems or obstacles 17 to be overcome as of January 26th, what did you perceive 18 those to be? A Excuse me, sir, do you mean October 26th? j9 Q October 26th, I am sorry. 20 21 Looking back and trying to remember what it was A 22 like on October 26th looking forward, the major obstacle 23 which I perceived at that time were to complete the power 24 range testing and the test procedures which we committed to 25 complete as a part of that power escalation. I don't know .c..mo.... e... vies..... oso =u no.. co i. m.... ...ie r
126 I 1' that I vicwcd them as obstacles, but they were requirements I l S - which had to be met. At the time we potentially perceived 2 3 we might be a little short on reactor coolant flow and with 4 the maximum flow achievable perhaps might not be able 5' to get the full megawatt thermal output from the reactor core. 6 Additionally we discussed the generator output which I 7 believe was 950-some megawatts, and possible need to limit 8 the core output because of restrictions on steam flow 9 through the turbine. 10 In other words, there was a possibility we could be 11 limited on megawatts thermal because of the reactor coolant ~ 12 system flow, a value that was lower than we had originally 13 anticipated, or that we could experience a limit on generator 4 %-4 ja megawatts output. Having achieved that generator output 15 before we had used up the full value of the available heat 16 from the core. 17 Those, I think were the kind of things that we talked 18 about. 19 The other items were of course the items that we 20 documented for the subcommitted followup. I think that 21 pretty well covers the expanse of the review. 22 Q Was there more than one subcommittee? Was there 23 a coordinating subcommittee and a number of other subcommittees? l l 24 A No. There was this main committee and then there Y} 25 is the group we previously discussed. -o..e..mo.....e.....e .... o so -.u..... me.............. 9
127 i .1 (Short recess.) 2 (Herbein Exhibit 14 identified. ) 3 MR. FRAMPTON: Back on the record. 4 BY MR. FRAMPTON: 5 Q
- 12. Herbein, do you recall that there was a GPU 6
Service Company Board of Directors' meeting in early December 7 of 1978, at which the subject of Unit Two's coming into 8 commercial operation was discussed? 9 A Yes. 10 Q Did you know about that and did you attend it? A ISon't' ow. I don't think that I attended it j ), ^ t 12 You said it was a GPU Service Company Board of Directors'? 13 Q I believe that's right. Either GPU Service '. L.: 14 Company or GPU. 15 A No, I don't believe I attended that. I don't typical-16 ly attend those meetings. And had I attended that, I would 17 have remembered it. Is Q Do you recall whether Mr. Arnold had any conversa-19 tions with you,or anyone else had any conversations with. 20 'you as a result of that meeting, on the subject of meeting t 21 the criteria for taking the plant into commercial operation? i 22 A I. don't recall that, s 23 Q Do you recall Mr. Arnold or anyone else showing you 24 or discussing with you criteria that are set out in a ruling 25 or regulations of Federal Income Tax Laws as to what has to oo.,c..ve~oo n. e.....cr. i m o o -.u. ao.a. c o='u'~a
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128' i l l I f lx) dona to mest the tax law requirem:nts for tho.cquivalent 2' of going into commercial operation? 3 A No, I don't recall-- 4 O Do you have any knowledge of criteria set out 5 in thmgtax-laws'for this kind of thing? 6 A No, I do not. 7 Q Do you recall discussing such criteria with anyone 8 at any time? 9 A No,'I don't recall that. That may have-been 10 discussed when I was present at one of Walt Creitz officers' j; meetings where our controller, Mr. Ray Wertz, may have said 12 some things about that. But I don't recall the specific 13 remarks or even the general intent, other than to say that t ja it nay have been desirable from a tax standpoint that the unit go commercial before the first of the year, which I 15 think I have already stated. 16 17 Q Do you recall any discussion with Mr. Arnold in 18 or about early December 1978 concerning whether he had told 19 the TPU or GPU Service Board of Directors that he thought 20 that Unit Two would meet all the applicable criteria and 21 would go into commercial operation before the end of the month? 22 A I don't recall that specific conversation. I 23 think that Bob and I felt at that time that.that was a 24 realistic assessment of the situation. \\;S 25 Q Do you recall any knowledge as to whether the ~ MO*elCE STf 4042APMet graveCE. tela OLD MILb ROAD. wv0metsans. pn teet0 ~ ---,.--,w
i 129 1 i , - Board of either company had mado an incuiry about this matter l 1 s 2 at about that time? 3 A I don't recall that. 4 Q Did the subcommittee of the commercial operation 5 review Board,of which you wel a member, have any meetings, 6 actual meetings, in November c: December to go over the 7 things that still remained to be done? 8 A I don't recall that we had any formal meetings. 9 Q Did you have any meetings, formal or informal? 10 A Not that I specifically remember. But we may 11 have communicated through various phone calls the status o.f 12 the concerns as we understood them. And I am speaking of the 13 concerns that were listed for ongoing subcommittee activity. \\.) I am not sure if we had a conference call with Mr. Arnold t ja 15 and other members of the subcommittee to go over the status 16 of those particular items that were listed. We may have done 17 that. I don't recall it specifically. 18 Q Were you aware in December of 1978, that a hearing 19 or argument was scheduled before the state, Pennsylvania 20 State Public Utilities Board,or before an Examiner of that 21 Board, on the rate base issue for early January of 1979? 22 A I am not sure if I was specifically aware of that 23 or not. 24 O Let me show you what the reporter has marked as kl 25 Exhibit 14 of this date, which is a document entitled " Report MOMsCR STtseO6maPMtC SERVICL tota OLD MILL moap, wvouetstase. *a. 19810 0
130 1 I [ of Review Board" and dated 26 October, 1978, a documenr of i l 2 six pages listing various criteria with some attachments. i 3 Supplement A to this document is a three-page supplement 4 signed at the end of page two by, what appear to be the 5 members of your subcommittee. Is that correct? 6 Can you tell me what that Supplement A is? 7 A The supplement to which you are referring as 8 Supplement A constitutes the areas of subcommittee concern 9 that we recognized needed to bc examined prior to declaring 10 the unit commercial. And it provides the status of each of 11 those items. Those specific items were the reactor coolant 12 flow concern that I mentioned; the instrumentation associated 13 with the flow measurement; the concern that I expressed about t%.I ja the~ turbine first stage flow design limits; and the limita-15 tion associated with generator output at 959.2 megawatts. 16 Additionally, the condensate system deep-bed demineralizer's 17 ability to remove sodium is discussed. As are difficulties 18 or unresolved problems with the heater drain pumps. And 19 the potential shortages of make-up water associated with 20 the operation and design difficulties associated with the 21 Unit Two Los Angeles Water Treating System. Q What do those signatures at the bottom of page 22 two mean? Do those signatures mean that the people who 23 24 signed, or were signed for, had determined that the plant NM 25 was ready to go into commercial operation in their view? l l l mo.e. m.o...me... vies. im oso mu..o... me....... '.m l [ 1 t
131 l 1 A Yes, that's what it means. And it msans that i 2 'these specific items, which I mentioned, were accurately 3 characterized in this document and that in view of rhat ^ 4 status we felt that the unit was acceptable for commercial 5 operation. 6 0 Can you tell me why that decision has a line ) indicating that it was reviewed by Mr. Miller, who was 8 a subordinate to you and was junior in seniority, at least, 9 to the other people on the subcommittee? Why would their 10 decision be reviewed by him? 4 A Basically to see that Gary agreed with our decision jj to view the unit acceptable for commercial operation and 12 to see that the items listed here were accurately characterized 33 (J according to his understanding of the. conditions of the plant. ja He being the on site senior representative with direct 15 knowledge of the plant condition. 16 Q Let me ask you a couple of questions about p sentences that I have marked in this exhibit which are 18 19 not part of Supplement A but are part of the main report. 20 On page four there is a discussion of items outstanding on which work must be done, and there is the statement made 21 22 that plans exist to, quote, blitz, end quote this work s 23 during the screen outage. Do you know when the screen outage was scheduled for at 24 that time? 25 =ca.c eve =oona...e scavice. ino c6o wu nomo. wvomise>=o... i.eio (
132 h 1 l A I don't cpacifically rem mbsr whan it was schedulsd. l l 2 But typically after some set number of hours at or near l l 3 full steam flow the protective screens in front of the turbine 4 inlet valves are -- 5 Q Finally taken out? A That's correct. 6 7 And it was during that outage that we intended to clean 8 up a lot of the loose ends or open items. Hence, the term 9 " blitz" the work during the. screen outage. 0 D y u know when the screen outage ultimately 10 was held, ultimately was? 3) A No, I don't remember specifically when we took g the screens out. g t'# Q Was it in the last week or so of December, or 14 thereabouts? 15 16 A I don't remember. 17 0 Do you know why on the last page of Supplement A 18 Mr. Arnold signed for you and Mr. Miller? 19 A Yes. It had to do with geography and the ability to procure our signatures. He did have Mr. Hirst and Mr. 20 Wilson present in his office building area, whereas, myself 21 and Mr. Miller, of course, were here in Pennsylvania. I g think rather than put the paper in the mail and experience 23 1 the natural de, lay time that causes, why, he went ahead and g \\6/ asked for our telephone call approval and then indicated that 25 ..e. m................, m o s.. u..... m m..............
133 1 i he had cocured that with his signaturo, which wa had no 2 problem with and agreed was certainly appropriate. 3' O Did the GORE or the PORC have any role in 4 determining when the plant would go into commercial operation? 5 A I think the PORC did indirectly in that all the 6 test results and the comparison of those results to the test 7 criteria were viewed by the PORC who in turn then would 8 approve the procedure activity as having been completed 9 satisfactorily when the test results matched the criteria. 10 And we had indicated that the testing phase would be completed up to or very close to full power prior to commercial g service declaration. The GORE, I believe, was aware of this procedural review, \\" the conditions that existed at the plant during the start-up g and test phase and our plans to go through this process. First meeting the NRC criteria then meeting our own in-house review criteria before we declared the unit commercial. I 17 believe the GOR 3 was in agreement with that general approach. Q As the schedule for commerical operation slipped during 1978 back; who was it who would set that date, who would revise the schedule? Was it this committee or was it 21 22 Mr. Arnold or some other person or committee? 23 A The Service Company role in Three Mile Island 24 Unit Two was similar to the role in Unit One. Basically the N 25 service company and the major plant construction arm of the -o-c..n........e u...cr. .. oo. .u..... o-...... *f...i.
1?o II i corporation were responsible for the scheduling and allocation I 2l of resources up through the point of the declaration of t 3 commercial service. Hence, we, the operating company, looked 4 to the service company and the manag, ment group set up to 5 coordinate the Unit Two effort to in turn set the schedules 6 both for key milestone events and final declaration of 7 commercial service. And that group responsible for constree-8 tion and the management associated with that effort came 9 under Mr. Arnold. 10 Q And that group was responsible for the scheduling? 11l A Yes. Wit,h regard to the overall project status 12 and key milestones. There were certain facets of the 13 detailed implementation of tae start and test program that k'/ ~ ja the operating company had input to. 15 the start-up and test function also reported through But 16 the construction-management,with strong input from the 17 operating group with regard to their activities and related schedules. 18 j9 Do you know when the full power generator trip Q test was held? 20 1 21 A ~Before we -- correction. I believe we did that j 22 test close to Christmas and we restarted after that full ~ 23 power test and were I think on the 30th of December at 75 24 or 80 percent power when we said the unit was suitable for O 25 commercial operation. I don't remember the specific date. ....e.m........e...........6.-,u......mo...............
135 h 1 O Wero all ths outstanding problems listad in 2 Exhibit 13 and all the criteria listed in Exhibit 13 met 3 or dealt with at the time that the unit was declared in j 4 commercial operation? 5 A To the best of my knowledge they were or were 6 documented, as we indicated here in Appendix -- excuse me -- 7 Supplement A, to the report of the Review Board for the determination of technical and organization readiness for g 9 placing TMI Unit Two into. commercial operation. Q Were you ever instructed or told that Unit Two 10 had to be ready for commercial operation before the end of g the calendar year? A No, I was not. \\:.:.. I 14 Q Was any pressure put on you by anyone to take any 15 shortcuts or take any other measures that might risk the 16 unsafe operation of the plant in order to get the Unit Two 17 into commercial operation by the end of the year? 18 A No such pressure was placed on me. In fact, quite 19 the contrary. I thinkMr. Arnold, myself, and Mr. Miller, wanted 20 to be sure that the plant systems and components were 21 functioning the way they should before we declared the 22 unit commercial, and we wanted to go slow and do things in 23 a right andproper fashion in accordance with good engineering 24 practice. d 25 Q Mr. Herbein, as you may or may not know there was asceseC4 StresosaapeesC Stevict, tels OLD esaLL poa0. wToesISSless pa. 19e10
136 i l 1 1 at least onn article in tha Philadelphia Inquirer Ncwspaper 2 in April of 1979 relating to allegations that shortcuts { 3 were taken to get the plant into commercial operation before 4 the end of the year. 5 And I would just like to ask you one or two questions 6 from that article and ask you to respond to those. 7 A Yes, sir. 8 Q The newspaper article reported that a subordinate 9 to you recalled overhearing conversations about mechanical 10 breakdowns between you and others and recalled that he would say to you, quote, "It seems like the men are taking short- ); 12 cuts," end quote, and that you would say, quote, "A lot of 33 times you have to take shortcuts to get back on line,"end quote, referring to the times when the unit was indeed on ), 15 Do you recall making any such comments to anyone? g And if you do, do you have any comment on that? g A I don't recall making any such comments. I would g 19 state that I believe that all of us here have a certain 20 degree of pride in being able to repair problems in a relative] y 21 short period of time and restore the unit to service when 22 it does -- when it did go down. I think the pressure, if you 23 will,,was to a great extent generated by an esprit de corps 24 that all of the operating and maintenance force personnel here U 25 at Three Mile had and still-have, to do the best we could i i MQastCet STtescenaeusC staveCE. 1413 OLD aseLL #0AD. wYoterssene Pa. testo
1.37 l l 1 and work hard to keep the schedule off t:me co a minimum. f 2 But with no intent of taking shortcuts in areas of safety I 3 . significance. To the extent that we can look at a 4 schedule and through manpower utilization techniques and 5 accelerated procurement efforts shorten our schedules, why, 6 naturally we proceed along those lines with vigor, but never 7 with any intent of shortcutting safety, either nuclear safety a or personnel safety. 9 Q During the year 1978 after Met-Ed received the 10 operating license, was the start-up program still under the supervision of the service company until the plant went 11 commercial? Or was that rewponsibility transferred in 1 2 1 February of 1978 to Met-Ed? l 33 I A No, the start-up activities were still under the j4 15 responsibility of the service company, although Met-Ed was 16 the licensee and had the responsibility to comply with the 17 conditions of the license and the technical specifications ja which in fact implemented the license from an operating stand-j9 point. 20 Q Would there have been any tension between Met-ED 21 and the service company with respect to the question of going 22 commercial in which the service company would perhaps wish 23 to get the plant into commercial operation as soon as 24 possible, but the operating company would not want to accept %ei l 25 the plant and responsibility for it until the operating l l MOes*CR STE400RapM4C SE RVtCE. 1413 OLD WILL ROAD. wv0MfSSleeG. Pa 19610 l
138 1 company itcalf was satisfied that the service company had 2t adequately completed the start-up program? Was there at any i 3 time any divergence of interest there that would tend to make 4 the start-up program -- insure that the start-up program 5 would be completed adequately? 6 A I wouldn't express it necessart as a diversion 7 or division of interest. I think it was recognized that 8 there were two separate and dirtinct roles that ultimately 9 led to a common goal. To the extent that there was inter-10 action between the two groups, each with their own function i 11 to perform, I believe that was healthy. I don't believe the ^ 7 12 interests of the operating company and the operational 13 staff were sacrificed by those making the schedule. I think (%4/ obviously when you have a very complex operation, as we do ja 15 here, particularly when reaching the final stages of con-16 struction and start-up and testing, that you are going to J 17 have various schools of thought. That it is the coming 18 together of those schools of thought and the blending of those 19 into a common purpose that is mutually agreed upon that really 20 gives the final product. i 21 Yes, I am aure there were on occasion some discussions 22 between schedulers and operators. I wouldn't try to 23 characterize the extent or detail discussions that took 24 place. But I think that's only natural.- I view that as V 25 healthy. And I don't see that that caused us a problem. i l uomen stamoonamaic samvica. tais o6o wi66 acao. weemissmo en. iseio l 1
139 1 Q I really wasn't asking about a prob 1cm. What I 2 was asking was, coming at it from the other end, whether a 3l reluctance on the part of the operating company to be 4 rushed or to take responsibility for a plant that wasn't 3 quite ready might have served as a deterrent to any undue rush 6 to declare the plant into commercial operation? 7 A I think, as I -- g Q Did you perceive that as a factor? 9 A Yes. I think,- as I described the blending to together of the two purposes, why certainly that's a check and balance system there. And the operating company would
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12 not and wasn't about to be rushed into declaring the unit 13 commercial without being satisfied that things were the way V 14 they should be. 15 Q Were you aware of any substantial dissatisfaction 16 in the quality or schedule of the work being done in the 17 mechanical maintenance or electrical shops in the latter 18 part of 1978? 19 A No, I was not. 20 Q I would like to ask you some questions about the l l 21 April 23d, 1978, transient at Unit Two and the process of 22 replacing the steam relief valves that came about as a result 23 of that. 24 Do you recall receiving a report or analysis of that %3# transient?_ I believe Mr. seelinger prepared a rather lengthy 25 esOsesCW STENOsmamesC SERVICC. 1413 OLD assLL ROAO. wv0assGSe*ue-(* 19410 9 ~
140 i 1 analysis of that transient. l 2 A Yes, I recall Mr. Seelinger in conjunction with 3 Mr. Keaton together prepared a report of that transient and 4 subsequent analysis. And I recall that I received that report, 5 Q Did you ever receive a handwritten four or five 6 page note to Mr. Seelinger from one of the operators who had 7 been on duty during that trip, Mr. Frederick, Ed Frederick? 8 I will show you what we have previously marked as Exhibit No. 9 8. A No, I haven't seen this report. 10 Q One of the things that Mr. Frederick mentions in j) Exhibit 8, this handwritten note, relates to the number of 12 alarms that go off in the control room when there is a 13 U transient,or severe transient. Subsequently, I believe, 14 a program was initiated, wasn't it, to look at the number of alarms in the control room and see whether, of Unit Two, and see whether that could be reduced somewhat? Are you familiar with that? 18 A Not, not specifically. I think we have recognized for a fairly significant amount of time that with these large reactor plants and the large number of alarms in the control 22 room, it does, during a significant upset, present somewhat s 23 of a problem to the operators. It's my understanding, 24 really, that while the alarms are indeed a helpful aid to N 25 the operator in determining the condition surrounding a plant ...... m........e...m e c..... o u.. u...... m o.............. e e
1 , upeat, the primary recorded paramators on both the secondary l 2 and primary plan are really the key devices that the i 3 operator would and should focus on. I think the alarms are 4 a helpful input. I think now looking back we recognize, 5 with hindsight, that the alarm indication situation really 6 is not as it should be and some additional consideration 7 needs to be given to the way in which we view and treat g alarms in significant transient upsets. 9 MR. DIAZ: Do you mind if we take a break? 10 MR. FRAMPTON: Fine with me. j) (Short recess.) 12 BY MR. FRAMPTON: 13 0 As a result of the April 23 transient, as I under- \\ ;) 14 stand it, you went through some tests of the steam relief 15 valves and ultimately decided that they were going to 16 have to be replaced; is that right? 17 A That's correct. 18 0 can you describe what happened with the testing? j9 As I understand it, the tests of the valves were conducted 20 in another location, not at TMI; is that right? A That's correct. But in addition, some testing 21 22 was done initially here at Three Mile with the valves in 23 place in the steam lines using the pump heat as the steam 24 producing source to actually lift the valves, measure the %$E 25 lif t pressure and the approximate receding pressure. During i l l Monica sTamoenA*NIC stavlCE. ta13 OLD MILL moap. wrousssimo. pa testo l l l
142 l f I 1 those on-site tests it was determined that the valves did I 2 perform erratically and weren't consistent in resetting at 3 a point approximately a hundred pounds below the lift pressure-4 Q Was the decision then made to replace the valves 5 at that time? 6 A No. As I recall it, we felt that some additional 7 testing and possible modification of the valves would make 8 them acceptable from a performance standpoint. As I recall 9 it, we did modify the internals of one or two of the valves 10 in an effort to achieve the correct reset pressure. Those 11 valves did not perform as required and as a result of that 12 and the tests that were performed off site, the decision 13 was made to replace the valves. kJ Q What were the tests that were performed off site? ja 15 A I don't specifically remembcr, but I believe they -- 16 Q Were they contemporaneous with the ones on site? 17 A I don't recall the sequence, But I am fairly 18 certain that we did lift and reseat pressure tests on the valves 19 in. place. I think we had a spare valve that we modified 20 and subsequently installed in place on the steam lines after 21 we cooled the plant down, heated the plant again to the 22 temperature and pressure necessary to conduct testing and 23 found that those modifications did'not yield to correct lift -24 and reset pressure. %Y - 25 Either in parallel with that or in series, testing was wossecut STtNoemaPust stavect, tats OLO meLL moaO. wvoessS888es. *a. testo
143 1 l done at a remote facility, and I don't recall if it was at -- l I, 2 correction. I don't recall it was with a full sized valve i i i 3 or whether it was with a model of the valve. I don't recall 4 the test conditions that were established. But I do know 5 that the tests indicated that the valves with the modifica-6 tions that were attempted still would not perform properly. 7 0 And it was then the decision was made to find -- 8 A Could we go off the record? 9 O Surg. 10 Off the record. 11 (Discussion off the record.) 12 MR. FRAMPTON: Back on the record. t 13 BY MR.'FRAMPTON: '~ O Mr. Herbein, off the record you were saying that ja y u don't have a complete recall of all the events that 15 16 occurred with respect to the program to test and replace the 17 valves, at this time; is that right? 18 A That is correct. 19 0 You have only a general recollection of the sequence 20 of events? 21 A That's true. 22 Q Who would be the people who are most familiar 1 23 with the exact sequence of events? Who would have been 24 directly responsible for this, if you know? Yd7 25 A That would have been the technical functions ....c. m........ .e s. ... o s. -. a... m o-............ 9
144 4 4 1 E group under Mr. Arnold and hsaded up by Mr. Dick Wilson. I i 2h O Do you happen to know who would be che person or j 3 persons we oughr to ask, if we wanted to find out the details of that process of first testing and then deciding 4 5 to replace the valves and getting new valves? A I can't remember the specific engineer that was 7 designated as the coordinating engineer for that project. I imagine that Mr. Arnold would know who that was. -g Q That would be someone reporting up to Mr. Wilson 9 then in turn Mr. Wilson on to Mr. Arnold? g A Yes, I believe that's correct. 12 O Do you recall that the Dresser valves were -- 13 which were the replacement valves -- purchased from VIPCO %) le had already been o'rdered and were on site at the VEPCO site? 15 Do you have a recollection of that? 16 A I believe that I generally remember that. 17 0 The service company had the head responsibility 18 for the replacement of the valves, finding new valves and 39 replacing them; is that correct? A That's correct. 20 21 Q Next to the problem with the problem with the 22 steam valves, was there another incident which delayed the 23 test process from February of 1978 to December of '78?, What 24 was the second. biggest time delay matter, if you can select one. 35 ) i esOweCK Stre ogmaposte stavlCt. 1413 OLD neiLL moaD. wroneesse ws. pa vosso c
,1= l 1 A Just to discuss some of the things that occurred, t 2 I remember there was an oil contamination problem in the 3 secondary plant. There was additionally a sodium problem 4 on the condensate demineralizers that caused a delay. And 5 I am not certain specifically when we experienced the problem 6 with the discharge bellows on the atmospheric relief valves. 7 Thore bellows had to be replaced. One of them ruptured and 8 steam escaped into the M-20 area where the atmospheric and 9 steam safety valves are physically located in the plant. 10 The replacement of the tailpipe sections and bellows on the 3; discharge of the atmospheric reliefs did cause us a delay. I don't remember whether that occurred prior to or after g commerical operation. g My difficulty is getting the sequence of the outages g in proper order prior to this commercial declaration date 16 of 30 December, 17 Q In connection with the test process during the 18 year of 1978, did ycu have any role in deciding whether 19 a test had been passed or whether a system had performed 20 acceptably in a given test?- 21 A Not directly. I think if the plant staff had a 22 feeling that a test criteria had not been met that certainly 23 would have surfaced in the plant on-site review committee and 24 in turn would have gone up through Mr. Miller. He then U 25 specifically would have discussed it with me had it not been motetCa STtm00aapulC SERveCE, tota OLO MILL #0AO. wvouestimG. PA. 19610
146 l Ihacknowledgedbytheservicecompanyschedulingandmanagement l 2 group. And we then would have been able to voice our con-3- cerns and have them appropriately resolved. 4 The point being we had a voice in determining whether test 5 criteria was met,and would not have hesitated to execute that 6 requirement. 7 Q Were you aware of any tests that were skipped or 8 faked or in which the criteria were not met but somebody 9 simply reported that they'w'ere met? 10 A No, I am not aware of any of that kind of activity. 11 0 Were complaints ever made to you that the test 12 schedule was too tight, or that adequate time was not really 13 allowed to make a given test, in any given test that you can V ja recall? A Not specifically. I think we recignized that 15 16 there were times when schedules were optimistic, but that was 17 the schedule. That certainly was not the execution in the 18 field. The test execution took the amount of time that it 19 took to perform the test adequately and appropriately 20 assessed the results against the criteria. And that was 21 understood. 22 Q So nobody ever complained to you after the 23 fact that a test had been done inadequately because there l wasn't enough time allowed for it? 24 %dh { 25 A No. l l men.cu ritmoennemc senwice. tais oLo eneLL soap. wvosaissima. on. tesso
l 1 'i G As I understand it, there are two management review 2 committees that are chartered or imposed by the technical specifications for Unit Two, the PLRC and the Generation Re-view Committee, or GRC; is that correct? 5 A That's correct. 6 Q And you have a GORB, a G-O-R-B, which is part of 7 the tech specs for Unit One but not for Unit Two? 8 A That's correct. 9 Q The GRC reports to you; is that right? 10 A Yes, that's correct. 11 Q And the PORC reports to the site superintendent, 12 Mr. Miller? 13 A Yes. U 14 Q Does the GRC review all of the PORC activities 15 in a general way, and if so, how is that accomplished? 16 A I would say that's generally true. The specific 17 review activities of the Generation Review Committee are 18 set forth in the technical specifications. And to.the 19 extent those technical specifications require it, why, 20 post reviews are done on operating procedure changes, 21 equipment change modifications, and design changes, and 22 technical specification change submittals, things of that 23 nature. 24 Q Docs the GRC review all of the PORC minutes? A I can't state specifically that they do or do not. 25 \\ l l mo=ica svamoonaparc sanvict sats oto mitt mono. wvomissimo n. sesso l
169 l' I i 1lijustgettingstarted. We haven't seen what that group is 17lgoingtodo--goingtobeabletodoforus. But those I d 3 fellows were out here during the early phases of the accident and have put out their own report on the sequence 5 of events. And I think they have got a pretty good perspec-tive n the kinds of information we need to exchange. I think 6 l we will see some good things from them. 7 Yes, there will probably be more paper. But I don't 8 know how we are ever going to reduce paper work. It's a 9 f rm f communication and it's part of the system we are all 10 in. g MR. FRAMPTON: Off the record. (Discussion off the record.) g \\ 4 (Short recess.) 14 SY MR. FRAMPTON: 15 16 Q Mr. Herbein, maybe you can clarify the meaning 17 of the signtures of the Commercial Operation and Review Board 18 on Exhibit 14. On page two of that document it appears that 39 i the whole committee signed off on -- or many of them at least, on December 18th, December 21, before the subcommittee 20 finally signed off in the last couple of days of December. 21 22 I What do the signatures on the page two mean? A That with the information presented to them in 23 24 the October 26th report and the coverage here of each of ks2 the items in the Commercial Review Procedure, they were ,5 6 uomica stemoomanuec sravice. sais o6o wi66 acao. wvomissina es tesio I l
170 ) 1 i; natisfied, subject to the subcommittee's subsequent report, 11 I 2, that the unit was in fact in the condition identified here l 3! and notwithstanding any additional problems identified by the 4 subcommittee they were satisfied that this document, which 5 really characterizes the minutes of the meeting, written 6 according to the elements of the Commercial Review Procedure, 7 reflects the plant condition and in fact the unit is ready for commercial. 8 9 Q What I don't understand is that on page one, 10 paragraph 2.0 there is a conclusion that based on considera-y tion of the information furnished the unit is ready to go., Now, obviously as of December 18 there were still various g test that had to be completed and items that had to be g n, v satisfied. A And they said, and I read: " Based upon considera-tion of the information furnished and discussion of that if information," referring in turn to the October 26th meeting, 18 they concluded that the status of the unit with respect j9 to all criteria and procedures is acceptable. 20 So the procedural' criteria had been met and these 21 signatures here indicate that this characterizes the status 22 f each of those criteria and in fact they have been 23 met as evidenced by the specific criteria status and the I-l 24 subsequent conclusions there in 2.0. t N5 O So what you are saying is that that conclusion 25 ..,c. m co....e u.v.cs.
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~v I 1 I reflecus that the criteria set forth in the October 26th l l I 24 document had been met even if the NRC's full test program I I 3-lhadnotyetbeenfullysatisfiedasofDecember18th. I 4 believe you still had some tests -- l 5 A Yes, that's correct. as of December 18th? 6 Q 7 A Yes. But we met the -- 8 0 You met your own internal criteria? 9 A That's true, yes. 10 0 Are you looking to see whether your internal criteria -- jj A No. Just looking at the procedure. 12 33 0 -- require that the NRC's full power ascension (.9 test phase had been completed before your internal criteria ja are met? Can you determine that? 15 16 A I am not sure if I can. 17 There is a reference to the precommercial operational 18 power level in the basic procedure followed to determine 19 the unit's readiness for commercial operation. It does 20 state that the unit will be tested for the approved test 21 Plan and determined to meet the test criteria satisfactorily 22 at least up to and including the precommercial operational j r i 23 power level. Which means that, yes, this procedure here f 24 does provide the flexibility to be met without necessarily %$h 25 going to a full 100 percent power. I think that's the intent j ......................, m....u...................... m
172 I 1. of this document. 20 Q What is the PCOPO, the precommercial power level? r 3l Is that a number or is that a figure that you arrived at? 4 A It's not a specific number. It's the power level 5 that would have existed just prior to declaring the unit 6 commercial, and that would not necessarily have had to have y been 100 percent. It could have been a number like 75 or 80 8 percent. 9 MR..FRAMPTON: 'Off the record. 10 (Dicussion off the record.) jj BY MR. EVANS: 12 Q Just a couple questions, Mr. Herbein,on this 13 issue. Y.J 14 I understood your prior testimony Met-Ed made a commitment 15 to the Pennsylvania PUC to complete its ?SAR listed test 16 before going commercial; is that correct? 17 A I am not sure I said that. That we made that jg commitment to the PUC -- 39 Q Yes. A We may have. 20 Q Let me ask this quection. 21 l 22 Was it the intention of the company to complete all of' 1 23 its power ascension testing before declaring the unit to be in commercial operation? 24 Yb# A Yes, that, as I understood it, was the intent. 25 -o...m.....e.........oso-a............... e
173 j O And are you familiar with the provisions of the 1 ? 2 FSAR 'which detail what are the power ascension tests? 1 3 A I am familiar that such details exist at the i 4 15, 40, 75 and full-power plateaus. 5 Q Do you know if the last power ascension test in the FSAR is the full power generator trip test? 6 7 To rhe best of my knowledge that's the last, or A 3 one of the last tests; yes. Q And,yet under the provisions set forth in what has 9 been identified as Exhibit 13, you don't believe it was g necessary to do that full power generator trip test before, y declaring the unit to be in commercial operation under those criteria? Ld' A I believe that's correct. I believe that this 14 15 procedure applies not only to Three Mile Island, but, as it 16 says in the title, Determination of Technical and Organizational 17 Readiness for Placing a Generating Unit into Commercial 18 Operation. 19 That could be Homer City, that could be Three Mile Island. 20 Q There is no interconnection in your mind between 21 the criteria set forth in Exhibit 13, the FSAR, and the 22 commitments made to the Pennsylvania Public Utility Comis-23 sion? 24 A I think there is -- certainly they are related. 25 I think they are separate and distinct documents, but I think -.....n.......e.....e: .... o6 ->u. .. m o-..........
174 l 1, they do interrelate to the extent that we tell the PUC we 1 2 are going to do all the NRC required power testing before i I 3 we go commercial. And you state that I stated that commitment a was made. I am not certain that's the case, but I will 5 take your word for it. 6 MR. FRAMPTON: Excuse me. I don't mean to 7 interrupt, but I don't think I asked you that question in s 8 prior testimony. 9 MR. DIAI: I would like to state for the record 10 that I do not recall that line of questioning being asked 11 or answered today. You may be thinking of testimony given, yesterday or before somebody else. 12 MR. EVANS: I apologize. 13 h THE WITNESS: It's certainly accepted. But to 34 9" Y* 5"** 15 9 I think the documents do stand as separate entities, but g 17 they are related in that they are speaking about the same thing. 18 performing a series of tests on the unit. And then based 19 on those tests,and criteria set forth in those tests, as 20 well as separate broader criteria documented here in this 4 21 procedure, the determination is ultimately made that the unit 22 is ready for commercial service. 23 The FSAR says some things, the procedure says some l. l l 24 things, the commitments are made to the PUC, if they were 3 D 25 as you say they were. If you would like to ask some specific Mosescu STEMO4aapatC SEnveCE. tala OLO assLL moaO. wvoss'Stiase PA testo l
175 l h i 1 questions on how we separate these things, I think we can I l 2 talk about that. But they are ints;related. 2 BY MR. EVANS: 4 0 Let me simply ask this question. 5 If after the full power generator trip test had been run it was determined that the results of that test were 6 7 not acceptable, what would have been the procedure for a informing the members of the Commercial Operations Review 9 Board? A Well, I think I would have probably told Mr. 10 jj Arnold and I think that wouldhave taken care of telling the rest of the members of the group. Quite simply we wouldn't g have declared the unit commercial. We would have done whatever j3 O we had to do to make that right. Because, as I recall it, 14 one of the things that we had decided,'and I don't believe it's documented anywhere, was that we wanted to do the full power trip test and then recover the unit. We felt that that Was demonstrable to a Certain extent that the unit could under-go a full power, trip and could within a reasonable amount of time recover. And in fact we did that. We did the full oower 20 trip before we went commercial. There were no major problems. The unit recovered nicely. 23 MR. EVANS: No more questions. 24 MR. FRA!GTON: Mr. Herbein, thank you very much 25 for your time, which I know is valuable, and your cooperation. l t mo=ica ste=oema**se samvect. vais oLo wiLL sono. wvowissimo. ea tosto r e}}