ML19308C519
| ML19308C519 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 10/12/1979 |
| From: | Grier B, Rivenbark G NRC - NRC THREE MILE ISLAND TASK FORCE, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280518 | |
| Download: ML19308C519 (39) | |
Text
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Ok ge t
l l
I O
i N U CLE AR R E G U L ATO R't COMMIS S!C N l
O l
I l
1 IN THE MATTER OF:
i THREE MILE ISLAND i
SPECIAL INQUIRY DEPOSITIONS l
I DEPOSITION OF BOYCE H.
GRIER O
l i
Place -
King of Prussia, Pennsylvania Date -
Friday, October 12, 1979 Pages 1 - 38 I
r l.chen.:
(202)347-3700 l
ACE -FEDERAL REPORTERS,INC.
y c,p (T r=? ? O G Q D R '
OfficialReporters h'b6 hub 0
444 North Ccpitol Street g00 128gpg Washington, D.C. 20001 NATIONWIDE COVERAGE DAILY
1 RW 4950 jp i
2' THE NUCLEAR REGULATORY COMMISSION'S :
3 SPECIAL INQUIRY GROUP fp s
l l
I 5l Oral Deposition of BOYCE H. GRIER l
6 !
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l 7
APPEARANCES:
i 8
)
8l MR. GEORGE RIVENHARK NRC - Special Inquiry Group
~
9!
on Tnree Mile Island I
1 10 '
MR. PETER SICILIA, JR.
j NRC - Special Inquiry Group
}
11 i on Three Mile Island a
l 12l h
13 l TAKEN AT:
i l
ljl 14 Region 1 Nuclear Regulatory
- Friday, Commission Headquarters Office October 12, 1979 15f Room 208B 8: 00 a.m.
f 631 Park Avenue 16j King of Prussia-PA l
j 37 t
l-la INDEX 19 l]l
! WITNESS:
EXAMINED BY:
PAGE t
l Boyce H. Grier, 20 21 recalled Mr. Rivenbark 2
(lh 23 t
i 24 25 i
MON CM sig NocmaFH'C SERVICE. 1413 OLD MIL L RO A O. WYOMtSSING. P4 19610
2 l
1 P R.0 C E E D I N G S l
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MR. RIVENBARK:
This is a continuation of our
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3 September 28, 1979, deposition.of Mr. Boyce H.
Grier, Director Ou 4
of the Region I Nuclear Regulatory Commission Office of
)
5 Inspection and Enforcement.
6 The deposition is being conducted by the Nuclear J
7 Regulatory Commission's Special Inquiry Group on Three Mile 8
Island.
This deposition is taking place at King of Prussia, 9
Pennsylvania, in the Region ~ I Headquarters Office 'on October 10 12, 1979.
11 i Present in addition to Mr. Grier are Peter Sicilia, i
12 Jr., and George Rivenbark of the Special Inquiry Group.
13 BOYCE H. GRIER, recalled 14 BY MR. RIVENBARK:
1 15 Q
Mr. Grier, I will remind you that you are still 16 under oath from the previous deposition.
17 A
I understand.
18 Q
My questions are going to be jumping around to 19 different areas.
Inasmuch as we discussed some of these areas 20 in the previous deposition I will try not to cover the same 21 ground twice.
Though,- since I don't have a copy of what we 22 did before, only my notes, I may on occasion touch on a p) 23 subject that we have previously discussed.
24 I think I will begin by touching on. the. emergency
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I 25 response plans and your perception of these plans at the time MO NIC E STE NO GR AP, HIC SERV,C E, 9 413 OL D MiLI. RO AO. W YOMistlNo PA.
19480
3 l
1 of the incident, those at the time the incident occurred, not h
2 as they were actually implemented.
But as your perception as a
3 to what we would be doing and how we would be~doing it at that
]
4 moment.
5 The headquarter's plan doesn't mention the Region's 6
response.
Are you aware of that?
i 7I A
The headquarters?
8 Q
Headquarters Incident Response Center Plan does not 9
mention the region per se?-
l i
A Okay, I didn't realize that specifically.
I thought 10 l there was sone' mention.
11 12 Q
It doesn't define a role.
It may mention a tele-13 I P one contacts.
But it doesn't define a role.
Is that your h
la understanding?
15 A
I guess that's true, yes..
16 Q
I am not trying to.put words in your mouth.
If you 17 really don' t know, just indicate that you are not aware of 18 whether it does or not.
19 A
Well, I had not considered that specifically, I 20 guess.
21 ;
Q Now, the region plan'does not specifically mention 22 the EMT, the Emergency Management Team, or: specifically mention C) i 23 receiving directions from Headquarters ERAT.
Are you aware 24 of that?
O
25 A
Yes, I am aware of that.
Well, let me maybe M o%iC M ET ENOGR A PMtC S Env>C E.
1419 OL D MtLL RO A D W VOMtSSING. 8 A, f94tO i
4 1
explain where we were as I viewed it at the time.
When I O
2 arrived in Region I which was August of 1977, Region I Incident N_/
3 Response Plan had just been developed under the -- its O
4 development had started under the former regional director, 5
Mr. O'Reilly.
And it was about ready for issuance when I got 6
here.
This was late '77.
I'm not sure when we issued it.
I
^
7 But I think it probably carries a '7.7 date on 'it.
During early ' 7N a f ter Mr. Allen, had arrived as 8
9 deputy in Region I we-had some discussions about the plan and 10 the need to revise it.
So, a ; task. force was set up, and my-j recollection is April '78, to make some revisions in the 11 i
12 ; Region I Plan.
Now, that was carried out then during the 13!
middle months of '78.
But-I think we had issued a revision I
v 14 to the Region I Plan sometime late in '78.
15 Now, sometime in late.'78, and I don't precisely 16
-- I don't recall precisely the time, but there was a meeting ~
17 of all representatives from all regions and headquarters here 18 in Region I to talk about the regional _ response plans and the 19 development of headquarters response plan.
This was in con-20 nection with the work that was going on to develop the 21 Incident Response Center in:. Headquarters.
p 22 I think we recognized then that.there needed to be U
23 a uniformity in the regional incident response plan and 24 integration of regional responses with headquarters.
But we U
25
_did.-not get the headquarters response plan until I believe i
3
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MON >Cm STE NOGR A PHic SEmysC E, 1413 OLO utLL eO AD. WYOMISSING PA.' 19410 m.
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1 5
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1 February '78.
'We had gotten it prior to TMI, but we had not
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2 had any exercises with the plan.
And we recognized that our
~
3 plan needed further revision then to interface with Head-(])
4 quarters' plan.
But that just had not been accomplished.
5 So, that's the background as I understand it.
6' Q
I understand that the Region I Plan indicates that 7
the Region I Director will direct the response?
8l
'A Yes.
I i
9 Q
I also understand that.the region plan does not-10,
state that the region is, responsible for direction only until l
i 11 the EMT is formed?
12 A
That is not in our plan.
That is in the manual 13 chapter.
Well, I guess it may not say region.
But it says
(_-
ja that IE is responsible for the initial response until the EMT 15 is formed.
16 Q
Yes.
17 A
Yes.
is Q
At the time of the incident what was your perception 19 at that moment as to who directs the region's response?
20 A
Well, certainly I have responsibility for the 21 immediate response.
When Headquarters Response Center is 7 s, 22 manned I would expect to receive some direction from ' them.
%)
23 Q
Did you really believe that you were-going to get a 24 lot of direction from them at that time or before TMI did you 25 expect that you would be directing the region activities MON'CM sit NOGR**Mic st evrca. 1413 000 uiLL moao, wrouissign. pa tesio
6 1
requesting assistance as needed from Headquarters?
Did you
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i 2
believe at that time that you were going to get into a 3
situation.where Headquarters was dealing as directly and i
f" 4
detailed with the on-site team as they actually did?
V) 5 A
Yes.
I think I generally would have expected it to 6
go that way.
I think we have had in lesser significant 7
situations where, in effect, Headquarters takeslover in terms 8
of dealing directly with regional representatives who get.to l
9.' the site.
We have continually had problems with region i
l to [ being bypassed in such situations.
So, I think' based on the l
l experiences in those types of situations one could have 11 i
12l anticipated Headquarters to assume the direction.
I 1
One specific thing that bears this out that I
j happened on Wednesday morning of the 28th was, of course, the 14 l
15 !
initial setup being the region was the relay point for infor-16 ; mation from Three Mile Island site to Headquarters.
Steps 1
17 were taken at Headquarters to develop the direct communication ;
18 line.
And I think you will find it -- I presume it is on the 19 l tape somewhere, that when Mosley directed me in conversation 20 here. to make the telephone setup so ~ that Headquarters was 21 i communicating directly with the on-site team I raised some 22l objections because 1 pointed out that I would lose control
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I 23 over my inspectors, but promptly overruled, of course.
24,
And so, after that I felt that Headquarters because
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l of their direct lines of communication with the site was f
25 l
1 M O ms t C M Sf f NOGR A 8ke'C S ERY:CE. 14t 3 OL D M:1. L RO AD. W YOMISSING. PA 196t0
7 1
assuming responsibility for the directing of the response.
2 Q
Is that Mosley conversation you are talking'about 3
one that occurred late in the afternoon about four o' clock on
]
4 Wednesday wh'en he called and said something to the effect that 5
we are having difficulty getting operational information from I
6' the site and in which I believe you indicated that.you thought 7
that that was because they didn't have a direct line between
[
8 Unit I and Unit II?
Or is that a separate --
9 A
I think that is a separate conversation.
There i
10j were two problems or 1 think'two different things.
I'm not it 11 i sure.
That one may have been related to splitting operational 12 and radiological environmental because there was some diffi-lcultybecauseallinformationwasgoingonthesamechannel.
13 p
Y 14 And so, there was an effort to split so that we were only 15 l handling operational information on Unit II's circuit.
So, I 1
16 h think the tie-in which put Headquarters on a direct circuit, i
17j the conference situation which put Headquarters' direct com-l 18 l munication with the site was earlier than the late afternoon.
19 Now, that is my recollection.
But I have not reviewed the 20 [ tapes.
21 Q
I believe that's right.
Mr. Mosley's conversation, 22 '
the one I am referring to, occurred at about four o' clock?
u) 23 ;
A.
Okay.
My impression is that was with an effort tr 24 separate operational and radiological environmental.
O 25l Q
I was going to ask you based on Mr. Mosley's con-l McNtCM ETENOGeaPH'C SERVICE 1413 OLD MILL RO A D. w roMissimo. Pa testo e
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8 1
versation about not getting operational information, what you 2
recalled doing in response to that?
That was late in the 3
afternoon, four o' clock.
Up until this point I had wondered Q
4 because of the coincidence of Mr. Ke.imig's being assigned 5
within minutes almost if that was in any-way related to Mr.
6 Mosley's call about the communications at the site?
7 A
No, I don't think that there was any connection.
8 My assignment to Keimig was, based on recognition +that we were 9
getting more and more, people at the site.
We.needed somebody 10 supervisory in nature to take over on charge at the site.
And 11 it was with that in mind that I directed Keimig to go. 'But I 12 [ don't have any recollection that was associated with the 13 ;
communications problem with Head. quarters at all.
J l
l 1.5 Q
It is fair to say that you don't remember specifi-15 cally what you did in response to the fout o' clock --'
l 16 A
No, I don't except my impression is that that was 17 direct as I indicated, that that was directed towards separat-is ing operational and radiological environmental.
But what I 19 did specifically in response to that, I have no recollection.
20l Q
Mr. Grier, would you describe what you perceived l
21 l your personal role to be on Wednesday and if you cant to l
i
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relate how this runs over to Thursday and up until the time 22 l
23,
you went to the-site.
That would be a good way to da it I I
2.: l believe.
I 25 A
Well, I think initially it was to direct [the MON'CK STE NOG 4&PNC SERVICE. t4 t 3 OL D M 6 LL RO A D. WVOMIS SING. P A.
19810
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1 response in terms of getting a response team on-site, setting
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2 up the communications, manning the center here.
And then continuing to manage ' n terms of assuring that poople were i
3 Q
4 available, recognizing soon..that we had to maintain around-5 the-clock staffing, sufficient numbers on-site as well as here 6
in the Region I Response Center, assuring that the people were 7
available to gather the information and communicate it to 8
Headquarters.
That essentially was the! role as I viewed it.
9l And responding to whatever requests or-problems-that Head-10 quarters might identify.
11 Q
In order to carry out 'that responsibility did you
~
~
12 find it necessary'to have personal telephone conversations
+
I 13 with Headquarters over and beyond those telephone calls that O
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14 !
Headquarters placed to you?
Did you feel that you needed to 15l talk to them to make suggestions or to call them up to find 1
16 !
out what they were doing?
h 17ll A
Well, yes, I think so.
I isj Q
Did you feel that you needed. more information than 19 f they were volunteering to you?
20 A
Yes, 1 did.
No question about that.
I may not have 21 asserted myself enough to' find out -- try to find out.
But I 22 believe.there were calls to Mosley, John Davis on occasion in J
Y 23j an effort to find out what Headquarters was doing, you know, i'
24 whdt they were planning.
I know I'had some difficulty in O
25 getting any guidance in terms.of what they were thinking and McNaCK STtNOGR APM*C St4v8CE 1413 OLD MILL moao, wy0 MISSING.' P4 19610
10 1
what planning I would be doing about getting more people and 2
that sort of thing.
There was recognition that we needed 3
assistance from _ the other regions and going through Head-(v7 4f quarters to request that on the basis that we had to' continue j
5 at the level that we were at that time.
I have described c
somewhere already I think my somewhat annoyance in the 2
7i Thursday. conversations that I had there when there were re-8 quests'to make what I;would describe as the administrative I
9}
arrangements to handle visitors that were going through, the
!t 10 '
congressmen and the senators.- And so -- and I got requests 11 to provide drivers, transportation, meet them at the airport, 12 get their rental cars set up and that -- so, I didn't have the 13 staff to provide t. hat service.
And that was an an'noyance.
14 Q
In those telephone calls to Headquarters asking for 15 help from the other regions did you request the Hltthat came 16 from the other regions to provide around-the-clock coverage 17 at the site?
If you didn't, do you know who did?
18 A
I did not that I recall.
I, in fact, I believe that 19 the word that they were on their way or wcre coming came to me 20 ;
through George Smith.
And I guess I don't know specifically 21 whether George requested it.
I am assuming that he did that 22 in decision with Headquarters.
- v 23 Q
We talked to George yesterday.
He didn't.
Ile did 24-not.
He did not know who_did.
O. -
'~
25 A
Well, I think that is typical of Headquarters doing
. o ~,c,. u s... ~ c.....c c u n ot o o u.o.
. m o.... ~ o... w. i.
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f e
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11 1
these things and not telling us.
And we found that on a
(
2 number of occasions.
3 Fre instance, the Friday morning move to the site Q
4l with the large number -- I had no real preparation for that, l
5!
that that was being considered.
And I think I was caught by surprise with the word that there were some 30 people from the 6
7 other regions en route to the site and directing either me or 8
Mr. Allen to go to the site.
9 So, these plans were not discussed with me, with me
?
~
10 i. at all and were already under way when I learnbd-about them.
11 l Q
1s it fair to.say that you did not know alno about 12 the request from Headquarters for HP assistance from Argonne l
l 13,
National Laboratory and from Oakridge National Laboratcry?
l
(
14 A
No, I think we i e of that under the Radiological 1
15 ' Assistance Plan.. On the first day reques,ts were made -- well.,
f 1
j 16 that was Brookhaven.
17 Q
Now I am not talking about rad teams or ohms teams.
18 I am talking about a separate, independent activity requesting HP coverage individuals to come and to serve under, if possi-19 1
20 ! ble, and under NRC surveillance?
21 A
Well, I guess I was not aware until.this point of 22 such a request.
23 Q
Did your awareness of what Headquarters and the a
24 overall.NRC plans were with respect to our response to TMI
\\-)c 25 improve after you went to'the. site on Friday?
Did yoi still i
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' MOh*CN SYE NQGRAPHiC Stpvset. 1413 OLD M'tL RO A D. WVOMISSthG. PA 19610 l
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4
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have ' problems with that a fter you went to.the site on Friday?
2 A
I~think so if it is in terms of overall response, 3
yes.
There were activities 1 think under NRC direction that.
l O 4
-t reettr
=ot i=cormea or-5 Q
Did the: lack of that knowledge impede your 6
operation?
7, A
Well, I don't think so.
If in terms of the IE activitiesasIviewedbhemtheresponsibilitiesthatwehdd-8 9
we were providing personnel in three areas, reactor operations 10 t inspectors for surveillance of; the' operations, in the Unit II E
l Control Room, radiation-specialists for surveillance of in-11 ll i plant health physics, and the environmental survey teams and 12 13l coordination of all the environmental information.
l So, in the area of conducting those activities I 14 15 ' don't think that the other NRC act'ivities really affected or 16 l my lack of knowledge or information.
17 Q
After the Denton ' team came to the site who maintained 18 the radiological and environmental lead? 'Did that go over to 19 NRR at that point?
I know the last time we talked to.you on 20 the 28th that you mentioned that at some point you had told 21 your IE people that they should be responsive to NRR, that NRR lp hadi he lead'now.
I don't recall if you specified any t
22 i
V
-23 particu'ar' areas or if that was in general?
l 24 A
_Specifically in the in-plant activities the shift:
25 supervisor was directed to take his instructions.from'.the
.cu.ycJc
.m oto
.u. no.. mesi..m..
. i.no
-o,o w.oc.,
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13 1
. senior NRC representative on site which was NRR.
So, I
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2 specifically placed that direction under the NRC.
v 3
Q Both the radiological aspect and the operational f~T 4 !
aspect of the IE cffort?
s-)
5 A-Yes.
Now, the environmental was continued independ-6 ently I guess you would say.
Well, I don't mean to say inde-7 pendent, but was handled separately.
My understanding was 8
Denton was relying on us principally to provide environmental 9
information and briefings.
We supplied him regularly with l
10 l briefing information either written or oral in terms of 6
11 h environmental status, i
12 Q
1 get the impression from talking 'to you that maybe I
d 7g 13 g the IE NRR interface of relative roles was never clearly
(_./
la lI defined at the site?.
g 15l A
That's correct.. My feeling -- when we arrived on 16 site on the Friday evening there was direction to set up the I
l 17 ;
organization.
And if it was to be towards the integrated i
18 organization, that was expressed I guess by Stello,Vollmer 19]1 was setting up the organization as far as. NRR goes.
- Now, F
20 ) there was, some integration in terms of the IE people were 21 li
. working within prescribed groups but -- also contain NRR people.
73 22 I guess I had some difficulty in that I didn't feel their
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i 23!
organization was ever clearly defined.
And I didn't know how 24 to fit my organization in with'theirs.
That is one factor, j
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25 The other factor is.that, _ of course, we have our hi O NIC M STE P40G# APWC St RViC f 14 9 3 OLD M.LL 40a 0. w v 0M8 SSPNG Pas 15610
14 1
traditional roles of NRR reviewing and approving procedures, O) 2 if you will.
And IE having the role of verifying.
Now, it 3
in my. view the organization could have been continued to be i-Q 4
-set up along those lines that -- if those in charge had made l
5 use of the IE personnel in~ that role.
l 6
Now, let me give you a specific example which I 7
think is typical of the way things went.
There was an occasion, 8
and I'm-not sure in thectime.
It may.not have been till~some-9 time the first week in April.
I'm sure'it'was~not the first i
10 day, but after things had settl'ed down a bit there was some 11 question from Headquarters that had originated at 'the Com-12 mission about something that had happened.
The details of the 13 specific situation are not important.
But I'm not sure that la I recall exactly what happened.
15 But in any event, during this time, now uriderstand 16 we had IE inspectors in the co'ntrol room.
There was a need to
~
17 get some information from the control room.
This was Mr.
18 Stello sort of in charge at the' time rather than obtaining the 19 information through the IE representative. in the control room 20 he 'sent his own NRR man from the trailer to go get the' infor-21 mation.
22 So, I had the feeling that, the use' of 'the IE people 23 was j ust.' not. being done.
I can understand the fact that you J
~
24 know~your own people, you have confidence in them..You can
- sJ 25 rely on them.
And that perhaps' affects NRR action because MONCR sf NOGR A.H4C S tRVIC E,,1413 OLD MtLL, RO AD W YOMISSehG PA 19410 t
.]
1 15 h
l 1
they know what to expect of their people.
Aad they don't know
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2 the IE people.
So, I think this is indication that we need to
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4 together to get integrated teams some way so that you don't i
5j have this problem of defining roles and nmybe questions about 1
6 ll who you can rely on and the information that you want.
O 7]
Q Moving to another area, the emergency response plan 4
8 [ indicates that the NRC.will provide radiological assistance to S
9i the licensee until relief by other groups with specific 10 ' responsibility.
Now, am I correct
] that the NRC never did cease to provide radiological assistance?
11 12 They never did turn their task over to completely to DOE, RAT?
f A
That is correct, we did not.
13 D
H
[i Q
Would you have any idea why we didn't?
Why we did 14 15 g not rely completely on DOE for the off-site work?
15]
A No, I think that there was a continuing need, or at 0
17 [ 1 east we felt there was a continuing need for us to have the 9
18,I infornation ourselves within NRC.
19]
Q Is that a parallel between IE and NRR situation N
20 ll where you don' t really think you can rely totally on the 21i other party because you don't know them?
o 22p A
1 guess there is a similarity there, yes.
I would
(
0 23 1 agree that that is the same situation, yes.
24 l Q
Is it fair to say that our reason for being in the O
ffieldwas that we wanted to verify firsthand some of the 25 u c.Ni c a sign Maa psic sE ns c t, tat s oto p LL noAo wrowissrNG PA teolo
16 1
measurements?
(~J) 2 A
Yes, but I think we went beyond that because we were s.
3 independently doing not as a matter of verification, but the
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only measurement in certain areas.
We ended up with survey
%J 5
teams having defined areas of responsibility which was part of 6
the overall environmental plan, if you will.. Now, that serves 7
I guess to verify the other information.
But it was not 8
totally one of verification.
9 Q
Was the reaso'n that we didn't. turn _it over com-
~
P etely to RAT because_they didn't have the manpower to cover l
10 11 it adequately or was 'it ' that we j ust felt'that we needed to
~
12 have a presence there?
p A
I think it was just that we felt we needed to con-14 tinue to have a presence there.
It may be that they did not
~
15 have sufficient manpower to do it all at the thne, but I 16 presume they could have supplied additional manpower if we turn.it over to them.
17 18 Q
Is that an area that we might consider revising for 19 any future response plans as to how we --
A Yes, I think --
20 21 Q
-- interface with DOE-RAT?
A Right, that is an area that needs to be defined, 22 b-s-
_23 responsibilities defined and the plan clearly developed, no
- 24 question.
s b
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25
.Q I have talked some about the. DOE coordination with
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,m o<o o,u..o m o....,~....
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17 1
Mr. Smith yesterday.
I have been asked to pose this question 2
for you by a number of the SIG related to our work with DOE
^
3 with the following background understanding which I will des-( )
4 crib'e for you.
Then I will pose the question.
5 The first few days info was transmitted to NRC by 6
the AMS/ NEST team via phone and little other information was 7l communicated.
Is that a fair statement?
l.
8 ll A
Yes, as far as I know.
Now, there was ultimately I
!i 9 ] believe provision for transmission of headquarters by a 1
10 facsimile.
11 g Q
Now notice that this say. nothing about transmitting H
12 L ground information.
This is the AMS --
gm 13 A
Only the airborne?
1 n
14 j Q
NEST.
I!
4 15 D A
Only the aerial survey information.
Yes, as far as 16,
I know it was transmitted by telephone only.
I 17 Q
On Friday Phil Stohr of NRC participated in organi-18 [ zation of the daily coordination and exchange of radiological f
i 19 j information at the Capital City Airport but no routine liaison 20 wa s in p la ce a t that time?
l!
21f A
1 guess that is true on Friday.
As we moved more PeoP c to the site there was routine liaison fra. our opera-l 22 i
.+
IEW l tion into the trailer with the DOE operation of Capital City l
)
23 l
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s 24 Airport.
That was handled by Dr. Bores.
l 4
25-Q Do you recall when Bores came to the site?
l I
i l
MONiCR S T f N0 G R A PH' C *A E R v ic t.
1413 OL D MI L L ROAD. WYOMP
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18 1
A l'm not sure I can.
I'm not sure.
I can find out.
2 My impression is it was perhaps on Saturday.
I don't recall 3
that he was there on Friday.
But he was there shortly after Q
4 we got there.
5
.Q Do you know how we were getting any ground informa-6 tion before Friday or before Saturday?
How did we obtain the 7
ground information from the other people or did we ever get 8
'any before then?
Now I.know that we were taking some environ-9 mental measurements odrselves 10 the field?
10 A
Yes.
1 11 Q
So, the NRC had its own data.
Did the NRC --
12 A
Well, you understand during those first
- well, 13 after Wednesday night we had our mobile laboratory on site la under Phil Stobr's direction.
And on Thursday t'elephones were 15 installed in the mobile laboratory.
And I think the coor-16 dination of the environmental efforts started then.
l 17 Q
Were they in coordination with the DOE?
18 A
Yes.
19 l Q'
The' RAT teams?
1 20 A
Yes.
And now, so that was limited communications 21 capability.. But it was handled from the mobile laboratory 22 until:we had the trailers set up and operating late on Friday X
23
.or during Saturday.
And then we had the' radio communication 24 with the ground.
See, that service was provided by the-l 25 forestry service who arrived on Friday evening with the com-1 uos.cn sis ~onnaeme sanvice i.5 3 ot o uitt nea o.' w,ou.e sina. ca. i. e io'
_. 1
A 19 1
munications capability that was extended to the -- understand',
2 the RAT teams have their own through the DOE / NEST organization 3
I guess.
But after we arrived on site on' Friday night and ;got 4
the support from the forestry service with the radios, then Q
5l we had the radio communications from the IE trailer where we 6
were coordinating the environmental effort with RAT teams, l
7j with aren monitoring service and so on.
So, that really 8
started on Saturday I guess.
9, Q
There was a comment made at some point by Dr.. Bores s
l 10f. and I believe it was Friday or_ later wherein' a' single communi-11 l cation he indicated that we were not receiving RAT information l
s 12l 1 was curious to know whether that was something that had~just 13 developed or whether that had been going on~ previous to that.
~
la In other words, that we had not been getting -- I was wondering i
15 if it was a situation where we had not been getting' RAT data 16 i all along up until that late point'or was that something where 17 l the system fell.down and changed?
What was your' impression?
18 A
I don't know what he had in mind when he said that.
19 [ But I have the impression we were getting RAT information l
20 before that.
But I think it really started Saturday and on l
i 21 that the coordinated effort and ' clear" exchange of information n
22
' began.
O 23 Q-Moving to another area.
What'was your understanding 4
1 24i of our involvement in the sampling of the reactor. coolant I
25 j system or of the reactor containment atmosphere?
We were.
1 MONiCK SY E N0GR A PHrC SE RVtCE. 141) OLD M tLL RO AD. W YOMa sstNG. P A.
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1 involved?
Did we request sampics?
(}
2 A
I don't know.
I can only say that we were not 3
. requested.from here to my knowledge.
I did not request them.
[]}
4 It is my impression that that was done -- the licensee 5
decision.
Whether there wns any pressure from NRC or not I 6
don't'know, not fr om Region I.
7 Q
Before you went to the site on Wednesday did Mr.
8 Keimig or anyone else routinely call you to give you an 9
overall updating of the situntion atJ the site?
10 !!
A Well, I spent from'eight'o' clock ~ Wednesday morning 0
hllthroughat least eight o' clock Wednesday. evening and'similarly 11 12 : on Thursday I spent essentially the. full' time in the' operation i
13 ;
center here.
So, I was aware of the information that was
(
14 coming in regularly just by being there.
15f Q
I was wondering if there were communications 16 relative to meetings.with licensee's management and what their 17 plans were, what they were doing, those kinds of things which 18 did not seem to come routinely over the taped conversations?
4 19 A
Well, other than the information that came on the i
20 ;
telephone, no.
21 Q
When-the Vollmer. team went to the site you were told 3
22 ahead of time,. the day before, the night before they left that (d
23 they were going to go to the' site?
24 A
Yes.
I (b 25 Q
. ere.you told then or later thet'a Mr. Jerry.Klingler W
1 esoN eCM $1 E NOGma PM8C Ef Rv4CE. 1413 OL D Mit L RO A D, W WC MISSING PA l9650
21 from I & E headquarters was going to accompany that team?
1 1
\\
()
2 A
I do not recall being aware that he was with the 3
team at the time I learned that the team was going.
I am not
(])
4 sure whether I learned that Klingler was along.
And'I think
[
5 it was probably not until Thursday.
But I have some recollec-6 tion -- but I guess I was never really informed of Klingler's 7
role.
8 Q
That was my next question.
9 A
No.
10 Q
Mr. Mosicy I believe told me in his deposition that 11 Mr.' Klingler was sent; specifically to coordinate between the 12 i NRR group and the IE group.
W'ere you aware that.he --
I
~
13 A
That was never cicarly expressed to me.
la '
Q Were you ever aware that he' functioned in that 15 capacity?
A No.
He was functioning as a part of the NRR group-
}
16 i
17 '
by my observations when I got to the site.
18 Q
Is it fair to say that the IE role at the site 19 following Mr. Vollmer's arrival but before Mr. Denton's 20 arrival was the.same as it had been up until that point, that 21 there was no change in their role at that. point?-
22 A
That is my' understanding'.
l t
23 Q
We talked about the problems with handling the 1
24 congressional delegations.
Do you have.any suggestion as to l'8 25 how such visits ought to b'e handled or_wh' ether such visits.
i.
MONaCR $
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1413 OLD Mst.L RO AD.. W TOM 49 $1NG. P A 19610 f
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ought to be permitted if we have anything to say?
2 A
I think they ought to be discouraged because --
3 well, there were two impacts.
One was dealing with requests O
4 that we had here and trying to respond to that in terms of 5
providing service.
The other was the distraction from the 6
on-site effort because of the environmental people briefing.
7 the congressmen.
8 In effect, I think Keimig was not able to carry out 9;
his role because he was involved with the -- on Thursday he i
10l got there on Wednesday night.
He was involved on Thursday l
with briefing the congressional visitors which detracted from 11 12 his other responsibilities.
13l Q
Sometime after you went to the site were you called O
l 14 ! by John Davis from Headquarters and told something to the 15 effect that or asked do you have people standing around, the 16 inference being standing around not gainfully occupied?
Do 1
17 you recall any conversation like that?
i lai A
No, I don't recall that.
19 Q
If he had asked you that what would you have told 20 him?
21 A
I have no impression that people were standing 22 around with not enough to do, no.
So, my answer would have to 23
'be no'.
~
24
.Q Who would you have believed should have-been moni-U i
25 toring from an IE point of view the situation with respect to 70~.cc.ir ~o.-ee s cov.c. im ot o..cc o.o me....,~.
m 3
q
23 1
the makeup in decay gas tanks at TMI on Thursday and Wednesday 2
when the releases were occurring and when we became aware that 3
there were releases?
Should that have been the operational O
4 people r the radiological peopic?
Do you know which one 5
would have had the primary responsibility in monitoring' both 6,
the -- or~ being aware of the releases, monitoring the activi-l 7'
ties that were leading to the releases?
Or is there one 8
group?
9 A
No, I don't think it is clearly defined, George.
l 10 !
It is both.
I think the way we presently have our responsi-l 11 bilities assigned <the inspections in the rad waste area are 12 assigned to health physicists.
And so, I would extend that 13 to this situation and sa'y th'ey were the -- should be the ones 14 ;
familiar with the system.
15 Now, from the standpoint of system operations i
16l engineering aspect, the operations inspector is the one that i
17 should be.
So, I think it has to be both.
18 Q
Did we have some way of coordinating the ~ operational 19 inspectors' activities with those of the health-physics 20 activities such that they worked together to' come to some 21 mutual understanding on an item like that?
22 A
No,. I _ think this is another problem area we have.
23 i And I am talking-now with the NIE.
There has not been the p
-integration between the reactor operations and health-physics-24
'25 that'is needed.
It ~ is an outgrowth of the organization that J MhNtCR ST ENOGn a PHtC sgmv' eC E.,1413 OLD M,LL RO AD w YOM159s NG P4 19 10
~
74 1
we have functional groups from the regional office to the 2
headquarters sta ff.
I pointed out an observation that I made 3
during -- at some time during the event that there were l
l l
4 inspectors from a regional office, a health physicist and an 5
operations inspector who got acquainted at Three Mile Island.
6 They were from the same office but didn't-even know each 7
other.
Now, we are not that big an organization.
But, yes, a
that is a problem area.
Clearly IE has got its problem-there.
I 9
We have got the problem between IE and NRR.
And so, there --
i b
10 no question that we'.have -- we didn'tlhave the inzegration or
{
k the coordination b5 tween the office that we should hage had,
~
11 h
12 Hopefully we are movingin the' direction 'to resolving some of 13 chose problems with I &'E.
O l
Q You talked about your going to the site on Friday 14 l
15 l and the basis for it then.
Could you give me your rationale l
16 for operating from the region up until that time as opposed 17 to going to the region yourself or sending your number two 1
18 assistant there, that is a higher level person man who was I
j9 at the site at that point?
)
A Well, it was recognition that the on-site effort 2y 1
21 was the magnitude was in terms of number of people to manage l
22 was greatly. increasing. And my feeling that I needed to be 23 there --
i 24 Q
But is it a fact that there were fewer people up i
25., until.that point, was that - the sole basis for not going early; I
(
io~ic< sva~oonnem scavice do oto w [u nono comssma. en sesio
+
~
25 I
cr sending a high-level person to the site earlier?
Did it 2
have to do solely with numbers of people?
3 A
Well, in terms of why I decided to' go when I did --
l Q
No, why you decided not to go earlier?
p 4
U l
A No, I think it was that -- may have been a consid-5 eration.
But it was more that I had no indication from head-6 7
quarters that they were not getting information that they 8
needed, no indication that we needed more management or i
9 i supervisory people at the site.
I was led to believe I guess 10 since there were no indications of problems that things were jj {
going all right.
12 Q
Is that also because you believe that headquarters l!
13l was directing everything at that point?
O 1.1 I.
A Yes.
I was prepared to go at any time if they had thought that they needed...I had no indication from them that.
15 16 they thought I should have gone.
j7 Now, in retrospect whether I should have on my,own 18 initiative decided to go sooner, I'm not'sure.
Our plan does l
say that the regional director.may go.
But<it does not say 19 that he will though.
20 Q
On Saturday and Sunday, and I will try.to -combine 21 these together a little bit, generally what were you'doing on 22 23 S turday and Sunday?' What'was the IE. team doing on Saturday
~
~
24 and Sunday?
Where werevthey deployed?
What kind'of meetings
/N
~
were you attending with.NRR and the utility if tyoulha'd any?
25 MOhtCn $Tt h0GR APHf C &&mVtCE. f 13 OLD Ms LL Road-' WYOMi& SING. PA.
99610 r
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26 1
The general situation on those days, what was going on, your 1
())
2 participation in that, how you were learning things, your 3
involvement on those two days'.
(]
4 A
Well, as' far as the team goes the IE personnel we had by Saturday 1 think pretty well set up the organization 6
in terms of the three functions that I have previously des-I 7-cribed operational surveillance, in-plant health-physics a
surveillance'and environmental..And we had assigned for 9
three-shift coverage.
So, that's the way that the IE people j
10 were being involved.
11 Now, as far as my own ! personal activities on 12 Saturday I -- I accompanied Denton on his press coverage at 13i the Middletown Armory or Borough llall, I guess.
I don't O
14 recall exactly what time that was.
But it seems to me it-was 15 about the middle of the day.
And that -- I don't remember 16 any specific meetings before that except some maybe general 17 discussions in' preparation for. that'.
18 ;
Q Any planning meetings, meetings-for' discussion of 19 what the situation was at the plant, discussionfof views.on s
1 20' what ought to be done with respect to advising' the utility as 21 to what to do?
22 A
I'm not clear on my recollection, George.
There~
c 23 were some meetings and I don't know whether this was Sat'urday.
24 I'm not clear on time frame.
Buti there were some meetings in l
p't t
25 terms of status, yes.
There were-meetings that -- involving 1.e-d.v. ~oo-mc.<.ma
- i... o < o m u oo..: m e.., ~ o....... -
x
n-p 27 i
1 licensee representatives with NRR that I sat in on.
But as 2
far as being able to pinpoint the t ime, I can't de that.
3 Q
On Saturday and Sunday did you feel that you knew
]
4) what was going on at the plant and what the plant plans werc 5
and what the NRR plans at the site were?
Not talking about the 6
plans at headquarters, the overall plans at headquarters, but 7
what was going on at the site?
ai A
Well, I think generally, yes.
Of course, having h
9j the IE inspectors in the plant and communications from the 10 trailer well I had my office with them and having the lj inspectors going on shift and off shift report in to the 11
]
12 tra.iler I think I kept aware of what was ~ going on and what i
a 12 1 was planned.
O 11 j Q
Were you involved?
d A
15 ;l
.Was I involved in the planning de.cisions?
I think 16 l tlic < answer is no.
17 p Q
Were you involved in the discussions as to what to I!
18 g do about the hydrogen bubble?
1 19)
.A No.
20 Q
Were you involved in the discussions with Henry 21 f Madson, -Stello, when Henry came to the site on Sunday?
22 A
No, I was not.
Waa,that Sunday?
Yes.
- 23 <
Q' Yes' j
n
-24 A'
Yes,.okay, no I was not.
Let's see, going on to O'
-!. ' complete the other specific thi'ngs that' stand out in terms of
\\
25l I
l f
_ uoN ex srtNoonap+ve saa ics t ais ole wiLL moAo. wrou'ssiNo. P4 testo
.i
l 28 l
1 my involvement on Sunday which I did not get to accompany O
2 Denton to the airport and attended his briefing when the V
3 President arrived.
And I provided Denton with the information 1
l 4
current status as far as environmental information goes.
That 5
was the middle of the day on Sunday.
On the other meeting.
that I attended was I believe five o' clock on Sunday afternoon 6
7 at the PEMA, Pennsylvania Emergency Manning Agency, offices a I when I, accompanying Joe Diehl and the DOE people who were 9l meeting with the state representatives and the emergency i
l P anning aspect.
10 !
i 11 l Q
Moving to some eery general questions,about the 12 regional office's role and NRC's, role in general, what do you 13 regard as the region office's' role regarding the' review of
~
O ja evaluation and dissemination of: operational feedback informa-tion?
This is by operational feedback information as ex-15 16 Periences gained, lessons learned' that we cari apply,some l
P ace in the system.
What is your. view of the regional 17 office's role?
18 A
Well, of course, principally our' role I think is 19 20 responding to the event, notification with'res'pect.to the 21 specific facility or where the event occurs;. Now, if we have 22 a responsibility to evaluate that information and at least 23 make an initia1' determination as to whether or not 'we think i
24 it has generic application, now, we are. limited somewhat in 25 what we can do in terms of that because we may. not have all of I
o ~.c. m ~om.
c.m.c... m m o w
..o m e...,~..~,....
b
q 29 1
the facilities or types of facilities or so that '-- to make a 2
generic determination.
But we should be able to make an 3
initial determination of whether it is site specific or has...
3 4 l but they have the obligation, of course, to pass the informa-(u/
i l
5i tion to headquarters in -- again, it depends on the signifi-6 cance.
But there is the PN notification.
There is the daily 7
report notJFication..An'd then there is the follow-up in the a
inspect #.on report of our review and evaluation.
Now, if we 9
determine potential generic applications of an event or I 10 should say that I don't think that we are restricted from 11 making the determination outside.our region there is communi-12 cation between regions and' branch chiefs and section chiefs i
l exploring with the other regions whether they have got that 13 O
la possible problem, I think to assist in' determining whether or.
15 not it is generic.
But then if we think it has implications l
l
)
16 1 generically to propose a bulletin or to propose whatever actio n 17 headqrarters -.to headqualters for their consideration and 18 implementation, i
19 Q
How does I & E go about inspecting an area like for 20 evaluating the test results particularly the entire start-up 21 Program in a reactor?
22 A
Well, the program that is the IE inspection program 23 is generally along the lines of reviewing procedures on a 24 selective basis.. Wall, I guess'the first step is to see that 1 0 1
f N"
25-the licensee has got a program tha't meets his commitment ~ in i
MONtC4 sTENOGR APweC steviCE. 1419 OLD MtLL #0 AD W VCMiSSING PA.
19810 i
30 1
the FFAR, the pre-operational program should be described.
l 2
So,-initially it is determination with respect to t he program 3
meeting the commitment.
Then the procedure to implement the Q
4 program are developed.
And we review certain procedures, 5
selected procedures in more detail.
But verifying that.our 6
procedures are developed.
Then observing certair$ other tests 7
again there are some specifiedarcas of tests that insp'ectors 8
should witness.
But there is some ficxibilit y in the terms.
9 of specific tests.
Then reviewing the results of the tests in 10
'certain selected tests, again reviewing the results specifi-11,
cally.'
l i
Beyond that, verifying that all. tests are-completed 12 l
l
,3 13 and that all test results have been evaluated by the. licensee.
0 1
u, I think that generally is' the way the program goes. '
i 15,
Q How does I & E inspect the technical qualifications 16l Of a licensee?
c 17 AJ Specifically_we would examine the' licensee's 18 vrganization and personnel in the organization.-
I. don't'mean 19 examine ~the' individual.
I mean examine who is there: and what-20 his qualifications are in terms of meeting any -- the commit-21
.ments that-are'in the application.
So, it is principally one
(.
22l of ver'ifying what we can find out about an individual's
. 23' experience 'and qualifications in terms of meeting a commit-24 ment. 'As far as 'any specific determination of technical 25 competence, if you are asking do we do anything that -- of a l
- MONiCE SYt%odmApusC SEnttCf. 1413 QL D M+L L ROSO vv vo*4
- 55 SNG. Pa testo 5
z.
i
~
31' 1
quantitative nature I think the answer is no.
If we have 2
problems which arise during the course of our inspection 3
program which may be indicative of less than adequate technical C
4l competence in a particular area, this would certainly be 5
brought-to.the licensee's attention for correction.
B u t' 'a s 6
far as saying this particular individual is not te chnically 7
qualified, we don't do that.-
8 Q
Do you recall the extent to which the Re; ion I' 9
inspectors evaluat'ed the conduct of the results of the start-up
~
10l program at TMI II ' including its ascension to the va rious fpower l levels?- Do you recall;what the inspectors' ' conclusions were 11 i 12 about that?
13 A-I don't have ary. specific recollection, no.
14 Q
Do you know whether..or not their conclusions con-15 cerning those tests are documented?
16 A
I do not know speci*ically.
That is the sort of 17 thing that would be documenced in inspection reports.
And-18 then specifically we have procedures for identifying to 19l heady ters starting about 90 days before operating license -
20 iss'uance those outstanding things in terms of test programs 21 and -other preparations for operation that have not been
~
22 completed.
And we periodically update headquarters with 23 respect to c'ompleting - those. things required.
And then finally,-
24 we, take a position with respect ' to the readiness' for. issuance 25 of the operating license'.
Now tha't I believe is.alli documente-i.
t
-1 MON *CK ST ENOGR APM[C $[RysC E.
14'S OLD MILL ROAD, WVOMIS5f NG. P A.
19510 L
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B 32 1
Q How would the SIG.Sp'ecial Inquiry Group go about
(}
2 getting that information if we wanted it?
3 A
We can provide it, copies.of inspection reports and
(])
4 copics of memoranda to headquarters.
It should be in the 5
Three Mile Island 11 files.
6 Q
In the docketed files at headquarters?
7 A
It should.bc.
Formal communication between the 8
regionfand --
9 Q
That would include our evaluation of the test h
10j program?
j j
11 '
A Yes, as long as you~ understand the evaluation to
'c 1
12 mean identifying any deficiencies or problems that we had.
13l We do not. ncrmally make an evaluation 1.in terms of positive
)
ja determination specifically.
l 33 Q
Were you ever. unde'r the impression any time between 16 February 1978 and Decemb'er of 1978 that unrealistic schedules 17 were being followed by TMI'II for the start-up program and for I
is necessary corrective actionssuch as the replacement of relief-19 valve?
i 20 A
No, I don't have any recollection that I was advised 21 that their schedule was unrealistic, no.
What role do~ s your office play in enforcing 10 CFR 22 Q
e
%J 23 Part ' 21/ reporting defects and noncompliance?
Has TMI II been 24j the. subjectyof'any completed Part 21 investigation?
7,k)
- 25 A
T.et me answer the.first part.
We have responsi-l
/
wow.>,= sisuoaan.6c scavica ~ i4is oto wt6 aoao. w' omesma. ra iesiv v
t 1 4
y
)
I
33 1
bility for inspecting licensees to see that they have pro-2 cedures in place which are required by Part 21 specifically 3
in terms of evaluating and to determine whether Part 21 report Q
4 is required.
So, we do inspect to verify that the required 5
-procedures ar6 in place.
6 I don't have any specific recollection that we have 7,
done any Part 21 investigations if that is your question in 8
terms _ of failure to report insofar as it relates to Part 21.
9.
At least here from the region I don't recall.
10 Q
Would that 1.nclude Met-Ed or any of its affiliates ii as well as just TMI II?
12 A
I have no recollection of any investigation of 13 failure to report under.Part 21 that relates.to --
14 Q
Are they under way at the present time?
15 l A
Not from the region.
I believe Headquarters was
~
16 conducting an investigation related to 'really B & W's failure 17 to report but growing out of the Three Mile Island' situation.
18 i Q
Do you have an opinion regarding the adequacy, that 19 is the. clarity or the completeness _ of Part 21?
Do you have 20 any view on.it at all?
21 A
No, I -- well, I'-was involved in 'dra f ting the n
22 original Part 21.
And.I thoughtothat it was a regulation that i
%.)
l 23 implemented the legislation.
I think that the problems,:with 24 the Section 206 of the Act-in the legislation in terins of
-l
~
being very cicar.
For-instance, the'one' area that has 25 l
wa s.cn s anoa...wie..v.c c.
i4 i n oto wit c.o, o. w y,
...i~o.
. i...
~
L-J
l 34 I
caused us some difficulty to date is terms of enforcement, 2
whether or 'not there is authority to enforce Part 21 other 3
than specifically the failure to report.
And here I am l
l 4'
referring not to licensees but with respect to non-licensees, 5
vendors, suppliers.
l Q
In your judgment did TMI II appear to impose or o
7 implement any safety measures or practices beyond those that a
were required by NRC?
9{
A Would you releat...
I 10j Q
In your opinion did the licensee at TMI II appear 11 to impose or to implement any safety measures or practices
?
~
12 over and beyond those required by the NRC?
i 13 A
Are you talking about pre-incident now?
O y
Q Yes.
Did'tlicy 'only meet their basic requirements?
15 A
I understand the' question'now.
I don't have any 16 strong feelings one way or the other with respect to that.
17
,I don?t have~any basis for saying that they. did much if any-18 thing'beyond meeting the requirements.
19 Q
Do you believe' there is a lack of direct. licensing 20 and regulatory control'over the vendor?
I think.you indicated 21 that you mighc.
A.
Yes, 'I think there is a lack of enforcement authority.
22 2?
Q
'Do you believe'that makes your mission.more diffi-24
= cult?
\\
A 25
.It does.-
l 4
Mc N i C K Ef tNOGR APHIC' SEN Wf CE.
1,4'S OLD MILL 90AD. WYOM!$$1NG. P A 19410'
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35 1
Q
.Do you believe that there is a lack of almost any g
control over th'e'. architect-engineer?
2 3
A Yes.
.g 4
Q Does,that make the mission more difficult?
5l A
Yes.
6 Q
Do you believe there is a lack of complete and 7
unambiguous refulations?
8
'A Yes.
9f Q
Does that make the mission more, difficult?
10 A
Yes it does.
Q Do you believe that we have to rely on commitment of 11 12 a licensee which are not licensed conditions?
13 A
I do, yes.
14 Q
Does this make your mission more-difficult, ~ not 15 having these commitments a part of th licensed conditions?
16 A
I don't think so.
The only -
you could maybe make 17 it a little more difficult to take enforcement action.
But 18 if it is a matter of safety significance there is authority to 1
19 handle it by order I think.
20,
Q Does this include.the lack of quality assurance I
21 1 programs as licensed ~ conditions?
22 A
Yes, I think that specific requirements in the 23 quality assurance program area are missing.
We don't have 24 very clear conditions.
' 4' 25
-Q Not having those conditions included in the license l
. o s c.... c o.... c......J i, o < o m............,~o...
36-1 does that make it more difficult to carry out your mission, 2
that is'the quality assurance?
3 A
Yes, I understand.
To some extent I think it does.
(l 4
The. thrust-of your questions here I have answered yes to a v
5 lot of them.
But I think that we will never get to the point 6
that we have specific requirements in all areas.
And I guess 7
the thrust it seems to me in terms of specificity of require-8 ments and being able to enforce, I think we have to' rely on 9
the licensee and that we should put requirements in terms of 10 criteria rather than specific.
Every licensee is not the 11 same, every site is not the same.
And it is difficult to t
12 write specific requirements to cover every situation.
13 MR. RIVENBARK:
Do.you have any questions, Mr.
O I
14 Sicilia?
15 MR. SICILIA:' I have no' questions for this witness.
16 MR. RIVENBARK:
I 'have no 'more questions for you, i
17 Mr. Grier, at this time.
Let me say'that this is an ongoing I
ja investigation.
Although I have completed the questions I have 19 for you today we may need to ' bring you back for further i
20 depositions.
We will, however, make every effort'to avoid 21 having to do so.
l I will now' recess this depos'ition rather than l
22
~
23 terminate it.
('
24
. I wish to thank you for your time and your candidnes s.
25 THE WITNESS:
Thank you.
MOhdCM STE NOGR A PM6C S ERVaC E.
6 413 OL D MILL PO AD. W YOMIS$tNG. P A,19510 4
~
- )
37 1
(Whereupon at 9:43 a.m.
the deposition was recessed ?
I) 2 !!
p ss 3!
CERTIFICATE I
('_
I, Roxanne Weaver, the officer before whom the 4
1 xs 5i deposition of BOYCE H. GRIER was taken, do hereby certify that k
6 BOYCE H. GRIER, the witness whose testimony appears in the 7'
foregoing deposition, was duly sworn by me on October 12, 8;
1979, and that the transcribed deposition of said witness is a f
9 true record of the testimony given by him; that the proceed-10 h inds are here recorded fully and accurately; that I am neither 4
11 ;! attorney nor counsel for, nor related to any of the parties to d
1 12 the action in which this deposition was taken, and further f3 13 [ that I am not a relative of any attorney or counsel employed
(-)
14 ' by the parties hereto, or financially interested in this 0
15 h action.
h 16 17d 18 44 4
i R xanne Weaver, Reporter 19l Notary Public in and for the p
Commonwealth of Pennsylvania 20[
MONICK STEN 0 GRAPHIC SERVICE i
21 i My Commission expires July 18, 1983
- _)
23 i i
24
)
25 t
MONCM S T [ NOGI' A PHIC S t #v5CE 1413 G LD M tL L MO A D W YO M e S SI NG P4 19610 6
38 1
- 1. have read the above and it is true and correct to g
2 the best of my knowledge and belief.
3 t
g 4
Boyce H. Grier 5
WITNESSES:
6 I
7 8
9 10 11 12 e
+
13 i
14
, ~,
15 9
-g 16 17 18
, 19 20 21 I
1 1
23 25.
e i Mon tc et sith0Gst aPM'C SERVIC E.
1419 OLD MtLL RO A D, WYOMs99ING. PA. 19510 1
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