ML19326D811
| ML19326D811 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/03/1979 |
| From: | Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| References | |
| NUDOCS 8007030345 | |
| Download: ML19326D811 (86) | |
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> -clN THE -MATTER.0F:.'.
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INTERVIEW OF DAN STERNBERG
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ACE - FEDERAL REPORTERS,INC.
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-UNITED STATES OF A! ERICA 2
NUCLEAR REGULATORY COMMISSION 3
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7 IN'IERVIEW OF DAN STERNBERG
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8 9
1825 Arlington Road l
Bethesda, Maryland
-n 10 Friday, August 3, 1979 11 12 13 l
An interview of Dan Sternberg was conducted 14 i
by Fred Hebdon, and William C. Farler, Esq., U.S. Nuclear 15 Regulatory Commission, commencing at 12:55 p.m.
1 16 17 18 19 20 21 22 23 I
.24 l
Ace-Federal Reporters, Inc. f 25
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2 PROCEEDINGS 1
Whereupon, 2
DAN STERNBERG 3
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!'was sworn by Fred Hebdon and was e::amined and responded as 4
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Q Have you read and do you understand the witness 7
notification I have just given you?
g A
Yes, I have; and yes, I do understand.
9 O
S'Oulf vcu clease state vour name?
10,;
i A
Daniel P.yer Sternberg.
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O What is vour current occupation?
1211
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A Section Chief of the Reactor Projects Section ';o.
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i ' Reactor Operations and Nuclear Support Branch, L*. S. Nuclear 14 Regulat ry Commission's Region-5 office of Inspection &
15 Enforcement.
g Q
What was your position in March of 1978?
- 7 A
My - fi ial p sition was that of reactor inspector;
-18 however, for a period of about five months, from sometime in 39 January through sometime in July, I was acting as a section 20 211' chief of the Pressurized Water Reactor Section in Recion-l.
O How many oecole reported to vou in vour acting 22 23,.cacacity?
I A-Approximately seven.
24 Ace-Fede,ol Reporters, Inc.
To'whom did.vou report?
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A-Officially I reported to_Eldon Brunner, who was 2 i the Reactor Operations Branch Chief during the period of March
'78 until Eldon was assigned temporary duty in Bethesda, 3
1 4I and Ebe McCabe was Acting Branch Chief.
5l 0
What was the temporary duty to which he was 6
assigned-in Bethesda?
7, A
Enecutive Officer for support in the Zeus job.
I e
8 Q
Would you describe your employment history, including 94 positions held'at the NRC?
10 l
A I came with the NRC in April 1st, 1974, and I was i
i 11 d reactorf insoector in Nuclear Succort Section, covering a
12 ll reactor start-ups and initial criticalities, incident i
13. analvsis.
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14 i
I was assigned to the boiling water reactor section i
f 15 in 1975, and served in that capacity until I left Region-1
~1, in August 1978.
17 I was assigned as project inspector at vermont 18 Yankee,-and Pilgrin, and, subsequently, at Nine Mile Point, 19 and Oyster Creek.
20 Q
So your experience was primarily with bciling water 21 reactors?
22 A
Yes, with the NRC; yes.
e 23 Q
And prior to coming to the NRC?
24 A.
Well, let me go back to college and work forward?
Ace-Federal Reporters, Inc.
25
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Q All right.
2 A
I graduated wi'h a degree in electrical engineering 3
Jfrom the Universit; of Pennsylvania in 1964; entered the ba 4
Navv Nuclear Power Procram in 1964; attended Nuclear Power 5 " School; was assigned to a nuclear submarine.
I left nhe 6
Navy in 1969.
7 I spent the next five years in General Electric in
- 8. the aerospace industry, electrical system s engineer, I
9 ins trumentation, telemetry, subsystem engineer.
10 tI And I joined the Come.ission, as I said, in 1974.
UI 11 l 0
What is your educational background?
12 A
Degree in electrical engineering, University of 13. Pennsylvania, and Navv Nuclear Power School.
14 O
Prior to March 28, 1979 what knowledge did you have i
15 concerning the incident that occurred at Three Mile Island 16 on March 29, 1978?
17 A
While acting section chief I became aware of a 18 safety injection in a reactor blowdown event, probably on 19 the 29th or the 30th of March,
'78.
20 I became very familiar at that time with the details 21 cf the various aspects.
Don Haverkamp was the inspector, 22 and Don uas involved directly in'the inspection at the site; 23 and I was basically providing the management review of his 24 actions as well as the licensee's action relative to determin-Ace-Federal Reporters, Inc.
25 ing the cause and corrective action, and the action taken by b
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the licensee prior tx) restarting.
2 As I recall, they had just gone critical for the 3
first time.the day before.
The primary concern that I had at 4
that time dealt with the injection of sodium hydroxide in 11 5
6l.
It has occurred previously, prior to initial 7'
criticality and we were very concerned now that the reactor
-8 had been critical that the possibility for sodium activation 9
problems, and additional stress and corresion problems frcr 10 the sodium hydroxide; and I was basically very concerned with Il the design that "as producing this sodiur hydronide injection, 121, which was not suppcsed to get into the reacter coolant system, l
4 13 ', but was there for containment build,ing spray.
14 But, because of the alignment cf the high pressure 15 injection system, and the containment spray system, they 16 shared a common suction header; and whenever there was a safety 17 injection with the then existing design, the sodium hydroxide 18 tank opened up on the same suction header; and, although the 19 stuff was_not_ intended to go into the reactor, that's where it 20 went, because there wasn't a containment spray initiation 21 signal.-
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22 So the main thrust of our concern at that point was 23 the B&W analysis into the chemical clean-up of the reactor 24 coolant system; and there was a rapid cooldown, we were keFecer=l Rmonm, Inc.
i 25 concerned about the analysis associated with that, as sort of I
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1 La peripheral issue,-though.
2 When I determined that the safety injection was 3. ' initiated and unannunciated by the fact that the whole event 9
49 had'heen caused by an inverter failure, and, as a result of 1
5(the'lossofpower,thepoweroperatedreliefvalveZailedin 1
6 the open position, depressurizing the primary; I felt that l
7 that was also vorthy of some attention.
8
- And I guess, judging-by the date of the memo, the
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9 't, - same day that I informed headquarters of the event bv the i
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10e P.N mechanism, Preliminary Notification mechanism, I wrote a l\\
- ;l 11 b - mer: requestine a review of the design adequacy of the PORV li -
i l' circuit that would let it fail open.on a single icss of 12i 13 electrical power, and a loss of power to one buss.
14, And I. pointed out that it was not safe to me, and 15 I still felt it should be reviewed by TMI-2 and other B&W 16 plants.
17 0
Okay, let me go back through some. of the things 181 you have said and try and fill in a couple of spots.
19 Why specifically did the information about T"I 20 come to your attentiome-21 A
Well, it was a pressurized tater reactor in Region-1 22 and, therefore, in the section in which I was acting section 23 chief I had responsibility for the assigned project inspectors.
24 Don Haverkamp was in that section, and I was just acting Ace-Federo! Reporters, Inc.
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' supervisor.
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1 Q
Haverkamp was in the section you were acting section 2
leader for?
3 A
Um-huh.
I 4
O Now, if I recall your description of your qualifica-5 tions, you mentioned your experience had previously been-in 6
BWRs; how did it come that you were in charge of a section 7
that involved at least one PWR7 8
Uas there any attempt to divide that?
9 A
It was all PWRs.
10 For one thing, my Navy experience was pressurized 11 water reactors.
I had attended I&E Pressurized Water Reactor 12 School in 1974.
L3.
O Um-huh?
I.
14 A-Approximately the same time I attended SWR School.
15 Throughout the time I was there, because I have a 16 strong background in electrical and electronic instrumentation 17 things, I had periodically been involved in reviewing events 18 and problems ~that -- pressurized water reactors -- it was an 19 area, you'know, where I had scme particular capability.
20 The arbitrary break-up of boiling water and 21 pressurized water reactor sections in Region-1 was not 22 uniform across the country in terms of the regions.
It 23 happened to be the way, at that time in Region-1 was organized.
24 It subsequently changed with the advent of the resident AuJeder:I Reporters, im:.
25 program; they no longer maintain that' deep distinction.
8 irG8.
1 And, again, the section chief job is mot one 2
that recuires a detailed in-depth knowledge of a particular 3.reacter or type of reactor to serve the function of, you know,
'4 assuring from an everview point of view that the inspection q
1, 5 ll program is-being' conducted correctly and that identified
'll 6
problems are surfaced and acted upon.
7 Well, the fact that I was as_
ned to the PWR Section, 8. I think, had to do with the people who were available and l
9 you know, management's opinions of, you know, who could handle 10 that particular job and other activi ties at the same time.
Il O
Okay.
12 Was it normal for your in your capacity as section 13 leader te receive the informaticn that ycu did receive 14 concerning that particular incident?
15 A
Well, I think since I ha'd been heavily involved 16 in some of the previous events at Three Mile Island, we had 17 just gone through the final throes of licensing recommendations, 18 the final close-out of the open items list, and the work of 19 me getting letters drafted directing the licensing to NRR; 20 that I had been in, you know, probably daily contact with i
21 the plant.
22 It may be that Don Haverkamp wasn't in the office j
l I don't recall; in fact, I'm not even sure that I got the 23 24
'first notification.
Ace Fooerol Reporters; inc.
25 I certainly became aware of it shortly if not
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immediately after the office became aware of it.
And I had 2
some cuestions, generated some phone calls; and it wouldn't 3
surprise me that if an event occurred anf the assigned project 4 l inspector wasn't there, I might have very well in any plant-n 5 0 told the operator, "give me the call," and I would, you know, ll 6
take whatever action in terms of, you know, making a determina-7 tion of what else should be done, myself.
8-Q What was your responsibility or function'with 9
respect to the informatien once you received it?
i, 10 0 A
An initial screening to determine whether or not II for example we should dispatch an inspection tear right il 12 t' wnether or not --
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Did you decide whether you should?
j I#f no, we -- it may very well be, an
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15 I Haverkamp was probably on site at this time; and so I knew 16 we had inspectors either in Unit 1 or Unit 2.
I7 There was nothing particular about the transient i
18 II that was in any way endangering.
There was no decay heat in 19 the core, you know, essentially the plant had not even gotten 20 up to one percent; it had gone critical the day before.
2Il My immediate concern was that no restart be 22 attempted until, you know, we had had a good chance to look 23 at it, and Metropolitan-Edison had a good chance to evaluate 24 all the aspects of it.
Ace-Federo! Reporters, Inc.
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25 And, you know, I determined right away that w.'-t j
10
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1 you know, they weren't planning to start up again that 2
afternoon; and that they were getting in touch with B&W to 3
get analyses performed.
4 I made the decision that we notify Headquarters 5lright'awaythroughthepreliminarynotificationnechanism,.
i 6 ll and decided the morning report should be ' completed so that the 7
next =orning it would automatically shrw up in the morning 8
report, I&E's field input to Headquarters.
i 9 l; In terms of overview, it was really to make sure thar N
101: it was of a routine enough nature not to require anything il il 11 'i, extracrdinary.-
i 12 I think basically I had concluded that, too.
13 And, acain, cettinc. back., v.ou know, the concern was I.the sodium hydroxide issue;. and, you knew, tryidg to"see that 14 15 people were aware that this was happening.
16 In that regard I did and frequently stay in touch 17 with the licensing project manager, Harvey Silver, to let i
18l him know -- sometimes he knew about things at the same time
.I 19'l I did through another mechanism; but, you know, I expressed l
20, my concerns abcut the design adequacy of the safety injection
'21
. system and the sodium hydreride emissions system.
22 So it was really just to make sure that people who i
1 23
.had.to be aware of this were made aware of the event, that 24 the design or the-incident review was taking place.
Ace-Federal Reporters, Inc.
O Now, as to the sodium hycrc':1de matter, was the 25 l:
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problem that worried you, the result of a design deficiency of 2
some kind?
3 A
Well, I don't know quite how to define the 4 I " design deficiency" -- in my mind, it wasn't a good design.
l 5" Whether it met.some definition, "this is sufficient, this is e
6
. acceptable," I don't know.
-7
-And throughout ny time with the NRC 2 have tended 8
to revise things in terms of a practical engineering acceptance, 9 l'Isitagoodidea?Orabadidea?"- not so much, "does it I.
10 ' meet the design?"
l 11 i
And I felt it was not a good idea, and whether or 12 not it me any specific design criteria, I didn't know - and 13 I didn't particu2arly care.
14 I just wanted people to really understand that this 15 is what was happening, and that people who were responsible 16 for, you know, licensing,-reviewing the design of the plant, 17 were aware that this condition existed.
18 O
When was that condition corrected?
1 19
- A I think following that injection the initiation 20 signal to open the sodium hydroxide valve was changed from a
'21 regular safety injection signal to probably a containment 22 type pressure signal.
1
' 23 0
Is that a change that the licensee carried out 24 under the licensing authority that it had?
Was any regulatory
' Ace Fedecol Reporters. Inc. l 25 review and.apprcval required?
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A-I don't recall.
2 0-
-How did you bring to someone's attention your 3
concerns about the sodium hydroxide injection?
4 A
Primarily through the phone calls with NRR and back I
i.5j to the licensee. -Again, you know, my feeling is that this I
6 was nothing the licensee wanted; and, you know, I just wanted 7,
to nahe sure that they shared my concerns and that they were 1
8 going to do something.
9i You know, sometimes it became convoluted because i
10 0 what I was telling the licensee sc=etimes, I said, you know, 11I "go back to licensing, get this worked out to get it changed,"
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-12 0 you know, "is there a reason vou can't chance this?
Do vour 1
l tech specs require this'" --
13
'a^ause, yc' kncv, then I would 14 [ try and know the mechanism to get tech specs changed, or ll 15 whatever was necessary to get a condition like that corrected.
16 And again it was my engineering judgnent that it
-17 was not a good idea.
It is not that it was an unanalyzed
)
.18 condition; I mean, the fact that it happened a few days or a
-19 week before, and that the world didn't collapse:
B&W knew 20 about.it, Licensing knew about it, you know; nobody said-any-21 thing specifically at that point, that we.were going to change 22 before we continue, that gave ne confidence, you know, that 23 I should pursue'it again; but not, you know, make it a Federal-24 case.
Ace-Federal Repo,ters. Inc.
25 BY MR. PARLER:
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1 Q ~
How do you know B&W knew about it?
2 A
Because B&W performed as analysis, a chemical 3 ! ahalysis, and stress cocidewn analysis, d
Q Who was your contact at NRR cn this matter?
5 A
I believe it was Harley-Silver, the licensing 6
project manager.
7 0
With regard to the open items prior to the issuance 8
of the operating license that you referred to earlier, in your F
9i judgment were there an unusally large number of open items?
j
.i.
If 10 A
No, not from my experience.
Il!
As I recall, what happened there -- it had happened t
12 I before -- is we generated a list that basically set forth i
3, i,
~ ji c12:grent p ateaus.
Idl The list cf things to be completed was longer tIhan l
15 it needed to be for initial criticality.
So we said, these 16 things had to be completed before criticality; then prior to 17
-going to one-percent power the next things had to be completed.
il 18 I
And I believe it was a graduated list o f open 19
' tems.
Again, those were recommendations to NRR who ultimately i
20 ' is the licensing authority.
I 2I BY MR. HEBDON:
22 O
You say the list was longer than it needed to be 23 for initial criticality; what do you mean by that?
24 A
Well, there were certain -- and I don't recall any keFesrad Repem, Inc j
gf the specifics -- but, for example, let us say something, well, 25 i
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2 a 1 w p wer physics testing, where you would not be generating any heat and requiring any secondary heat sink capability, 3
)itwouldbesomethingthatsaid:
that feed system is not 4
I
- l. complete, and it must be complete prier to going abcve one i
5 percent er something like that.
6 Acain, that is not an example, but --
7 8
j Well, was your concern with the physical size of the 9
list, er with the content of the items that were on the list?
10 i
A Well, I didn't have any concerns.
11 i
i l
Sill asked me was it entracrdinarily long?
I think 12 t
l 13 j it was lenger than it needed to be for just initial critical'ity.
It was a complete list of things, if you will,-that had to be
),
comoleted before coing commercial.
15 0
.that I am getting at, though, is I think your choice 16 the term " longer than it needs to be."
I am trying to get 17 18 [at whether vou mean there was some sort of a perception that I
j9llthelistwastoolong, so let's see if we can move some of the jthines to another list.
t 20 i
Or was it just a matter of, you went through and i
21 1
looked at it and realized some of the things did not need to be i
22 done at certain milestones?
23 A
The latter is the point; ves, that there were things 24 see-Federat Reponen. ene.
on tne list t.nat woulc. not prevent corne critica_ or fuel-25 t
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2 However, there were things -- again, fuel-loading 3llisagoodexample:
there were things that were on the list I.
41 - that had to be done prior to fuel loading, that you could not 15y go critical until you did several mere things on the list.
ll 61 O
Yes?-
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7 A
It was a matter of upgrading that list and each time 8,
it was time to remove one of the license conditions, and that
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90 is how our functional concerns are transla ad 4 - a reculation P
4 10 "li effectivelv.
It was that the license had conditions on it, P
llN and effectivelv what would ha_n.nen is we uculd review the 12 h. results of, what would you say, the fuel-10adang, and the 13 1ow pcwer testing, and ske a recommendation to 14 Licensing that certr.in conditic'ns be rencv'ed basci.on our 15,
inspection of the completion of certain outstanding items.
I 16 So it was basically a condition of removal process.
17 0
h' hat significance did you attribute to the incident l
-18 l that occurred on the 29th?
Was that a particularly serious
- 19. event cc= pared tc the other types of incidents that occur 20 l from time to time in plants?
Or is this a routine -- where 21 would you put it in that sort of a spectrum?
- 22 A
I would make it routine; inadvertent safety injections
- 23 were not uncommon, from my' experience.
24 And,_again, my inspection or enforcement philosophy Ace Federd Reporters. Inc.
' 25
-- I accept-the fact there are going to be safety injections; lL as
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.they are going to occur.
I.am curious how they got there, 1
2 what prompted them, but, you know, the fact that there was a 3
safety injection doesn't really surprise me.
That happened
'il. in: plants before.
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So I then. tend to.look backwards, and say, okay, 6
people you've handled safety injections'before, let's go back 7
and see why they had them.
8 My feeling is all along when you identify a cause, I.
L 9
correct.that cause, realizing-that'you may not prevent the next i
11 10l one which.will be frem a different unsuspected cause; but at l
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'11 l} least 'ycu will: have eliminated the possibility or reduced the l
l'
~12
' possibility of~a recurrence of the one which occurred this 13 1 time.
14
. So, you know, my philosechy was, well, : hey had r
15 another safety' injection; let us see what we can do, what can 16 we learn from that one to prev. tnt the next one f:om occurring i
17 from.the same cause.
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18
- For example, a previous safety injection had occurred 19 from a totally separate cause; and,.in fact, a 1-en days later
- 20 ~ they_. had another one,.or in some period of time there, I don't 1
~-
21 know-'if it was a week or a month later,
. But again, it came from another cause; so the 22 23 significance-I placed on it was it simply had to be reviewed
'24
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A). tofmake.sure it wac safe to resume operation; 3) that-H
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-whatever we' could get out: cf it, whatever cures we could get
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- I in place would be done.
2 O
With whom did you discuss the incident?
3 A
Well, the licensee, I think primarily it was 1
- hJimSeelingerIworkedwith,EbeMcCabe, Don Haverkamp,
.i 5
Harley Silver; that may well be it as near as I can remember --
6 not that I can recollect specifically, you know, talking to 7
Ebe about it.
But that's functionally what would occur so 8
I assume it did.
9 Q
Did you see or discuss any reports produced as a b
10 ' result of the investications or analvses associated with the II incident?
I 12 A
I don't believe I ever saw the B&W report.
I
-l
'l2 certainly saw the inspection report Den Haverkamp produced, 1
Id l
because*I signed off on it as the acting section chief.
15 0
What did you do with that report before you signed 16 off on it?
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I7 A
Read it, you know, made sure that it reflected the 1
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18 situation that I understood had occurred; you know, that it was l
l9 l an accurate representation of the actions that we had taken; i
20 and that the licensee had taken.
21 O
You read it for its technical content?
22 A-Yes.
23 0
Did you write a memorandum dated March 31, 1978 in 2d which you raised concerns about the design of the electromatic Ace Focieral Reporters. Inc.
25 relief valve?
W 4
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did.
1 A
Yes, I 0-For the purpose.of the record, this is a memorandum 2
f r K. B. Siyfrit to Ebe McCabe from Dan Sternberg,':iay 1st, 3
1975, TMI Pressuri::ed Relief Valve Control System; is that 4
the rnemo you wrote?
5 (Handing document to interviewee.)
6 A-Yes, it is.
7 0
iTny did you write that memo?
8
'A Again, my feeling was I did not think that this was 9
the right way for a system to werk, and that I wanted somebody 100 to look at it, you know, to call it to their attention.
jj My feeling is that the regional people are the first 12 line eyes and ears of what is out in the field api their job f-13 i
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33listoidentify, surface, technical issues and concerns so that
.the licensing people and other technical people can review
-15 and make corrections as appropriate.
16 Q.
Tirny did you not feel that this was the way the thing j7 18 I
"9" l
A My engineering background and experience said that j9
.1 ss of coolant accidents are not a good thing to have.
They 20 represent challenges to the safety systems, and I believe 21 in defense-in-depth; and anytime you identify a situation 22 where you have lost one of the layers of defense-in-depth, 23 that's not gcad.
-24 I
Ace Federol Repo,9ers. Inc.
I And an electrically initiated, unannunciated coolant 25
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I accident is_just something that when it is so easy to correct, 2
is something that shouldn't exist.
3 0
You also mentioned in the mero you feel the valves 4 i should be safety-related?
. I 5 'l A
Well, --
1 I
6 Q
Why did you feel that?
g 1! '
A I didn't say that.
7 l-8 I will read the sentence and I will tell you what i,
9 ll my thinking was, t
10 Q
All right?
11 A
The paragraph says, "this relief valve does not I appear to be a safety-related component, and it opens on a 12 i
13 one cut of one logic power arrangement. producing a loss of 14 coolant condition."
15 There is a certain ongoing and probably still 16 ongoing battle of "what is safety-grade, safety-significant"?
17 I have been involved in these kinds of battles in 18 the past.
I personally felt that something that produces a 19 loss of coolant accident is safety-significant.
20 The fact that it may not be en somebody's 0-list 21 or Class-1. or Class-1E is one of the standard arguments people 22 would use and say, we.can't do any more in that area.
23 So I wanted to define right off that I understood 24 and recogni=ed it was not safety-related; but I still felt
! Ace Federal Reporters, Inc.
L25 that'something should be done to review this.
~
s 20 j
In other words,l that could come back and somebody
-2 could say, it's not safety-related; and I just wanted.to get r
3 that on the table, to call people's attention to it.
14 i.
~Q What did " safety-related" mean to you?
.l
~A'
. cil, it means a lct of different things to a lot 5)
I 6
of different people.
7 One way of looking at it is if it is called
~
8 -
" safety-related," it. comes under uhe purview of the quality 9 ! assurance' program, and it has to meet certain requirements i
10 that 'a nonsafety-related component does not.
+.
'1 Safety-related has to do with whether er not 1
12 certain redundancy and diversity requirements and separation 33,, of po wer systems,-
things like that -- would apply to it.
It simply means to me that a. higher level of 34 sn 15 control and attention to. the design, fabrication, manufacture, 16 installation, testing takes place for safety-related j7 components, than, as I have learned, is applied to nonsafety-18l related' components.
j-
'j9 0
What'is normally required for something to be 20
. classified safety-related?
A-That tends to : occur in what I call the darkness 21 22 and paths of--the nuclear. power. plant.
I might point out that my experience in'the NRC was always. plants very close'to 23 24 initial' criticality'and in the operations phase.
Plants ih the z u eF.a nd hem ws iac
- 25 (very.early construction; phase, I never had anything to do with.
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In those days in the' FSAR and PSAR where lists of 2
components.and systems are set forth, a quality assurance 3, program is written identifying wnich components and systems t
4 and pipes wil.1 be safety-class and which ones are not, i
5 So it tends to be a set of givens by the time I see a plant.
6 And so -- I forget exactly your original question.
7 0
I'm just wcndering what you felt it took for 8
something to be classified as safety-related?
What was your 9
perception?
10 j A
It was a given.
11 O
What was included in that?
12 A
It was a given to me, it was en somebody's list.
13 B Y F.R. PAFJ ER:
14 O
Dan, you referred earlier in a part of your answer 15 about safety-grade versus nonsafety-grade to ongoing battles",
16 presumably " discussions," about classifications of various 17 pieces of equipment one way cr the other.
18 Would you be a little more specific on that?
Were 19 these controversies within the regional office er between i
i i
20 regional office and headquarrers, or between the NRC anc 21 the utility, or what?
22
_A I don't think there was ever any significant 23 disagreement in the regional office.
I think invariably the 24 inspectors felt that we were being saddled, being asked to Ac}Fooero! Reporters, Inc.
25 put on blinders; and that there were memos written, you know, i
J m.
m ljrb22 22 f
i 1
to. request that certain things be added to the Q-list.
2 For example, while reviewing an event at Peach 3 !! 3ottem'having to do with loss of three of the four diesel Igenerators, I found out that the diesel air starting system, 4
l H
5 which was the reason the three generators became unavailable the loss of air bled down the three starting air
'6-I
~7 receivers -- that the starting air system was not safety-l' related; whereas the diesel generator itself was.
8 9 [!
And it was clear and apparent to me that the diesel H
lt 101 generators were of no value on their own if their air was not I
i 11 ll there to start them.
et li 1211 But it was that type of frustration of, you know, 1:
il 13 ~i seelne ciesel cenerator, diesel fuel transfer system was on t
t t
14!
the list,,.but diesel generator starting air system was ndfon l:
15 l the list -- that kind of problem was relatively common.
l l
16 When I camein the Commission in
'74, you know, it 17 didn't take long before I was first hit with an example of i
l 18 that; and I went to complain, to find out a "welcome to the 19 club," kind of thing, you know, "we've-been trying to work 20 j with the people who are reviewing quality assurance plans, I
21 ' people in headquarters and things like that."
l 22 And I realized that it had been an ongoing battle 1r.
23 and that I was not going to in any way significantly win ', hat 24 battle or anything else, but learn to live with it, and
' AceFederal Reporters, Inc.
25 surface things independently.
b o _
jrb23 23 1
Q More specifically, the ongoing battle that you were 2
aware cf was between the people who were in the regional offices 3 i that identified these concerns and with the quality assurance 4I people at headcuarters?
Or was it somebody else?
5 A
well, I really can't say.
I did not get actively I
6 involved in that.
7 I knew, you know, of the existence of this kind of 8
thing.
I knew there had been menos written, there had been
~
c' responses back; sometimes it was 18 months and nothing had l;
10 happened; you know, it was a condition that I believe was 11' generally recognized.
e 12 i
And I think, you know, I don't know what organiza-i 13 l tion id specific.
i I
s Id it Q
Did you write any such nenos?
15 A
No, I did not.
16 O
Do you have any that are available to you that you 17 could give us at a later time?
18 A
I don't.
19 If you want to talk to somebody who probably would 20 be able to give you some details, Bill Ruhlman, who's now in 21 Region-2, RUHLMAN; because Bill was active in the 22 quality assurance inspection program.
Bill served as sort of a 23, menter in the early phases of my inspection activities.
i 24 0
Now, as a specific example, you cited this incident A&Fooeral iteporters. Inc.
25' at Peach Bottc=; wer e ycu ever able to get the air starting i
l
24 Orb 24 1
system _added to the list of safety-related equipment?
2 A
No.
3 When I wrote that inspection report I generated 4
what I call " inspector concerns," sort of a laundry list of 5 ' things that absolutely in my mind had -- that diesel air 6
starter system would have been on a long list of items not 7
in compliance; because of the way our enforcement program 8
goes back through the quality assurance program, and the
~
9!
tech specs, appendix 3 -- they were not items of noncocpliance l
10 although several noncompliant items did come out of the 1
11 event.
I 12 i O
Even recognizing that it wasn't safety-related?
13 A
Yuh, but the f,act that three of the four diesel 14 generators were inoperable, you know, a significant event; 15 from that point of view.
16 Q
It was significant because the three generators 17 were out of service, but then it wasn't a violation that the 18 three were out of service because the air system had failed, 10 or tne fact that three air rystems had failed?
i 20 A
There was a concern about separation criteria, they 21 were concerned about maintenance on that system, leaks that 22 were known to exist, deviations from the as-built drawings, 23 the fact that operators weren't going in there and making a i
I check on a frequency that I felt was necessary to do it --
24 AceJederal Reporters, Inc 25 all sorts of things.
I
N
^
25' 1
And, you know, I didn't mean to dig out that inspec-2
_ tion report; it's certainly afield from the Three Mile Island event.
I just cited it as an example of the classical coint 3
n-
!!g ij that I ran into as one that just came into my mind, that's all.
lI..
5 O
Could you tell me approximately when this inspection 6 I
! was conducted at Peach Bottom, so we could go back and get the 7
I inspection report?
Or could you urovide it later?
8, 9 }, -
A Unfortunatelv I'm not in Region-1 any more.
I.
10 A.. pr ba..
nAy was.-,,, _aner or early o.
i As e
i l
11 l Q
Late '77 or early '75?
l A
That's ny recc11ection.
12 jo-I'm trying to think of a simple way te get the
- p 14 jp information; I conceivably have a personal copy in my own l
l i
15 personal file.
16 Q
If you should happen tc run across it er think of j7 a more specific date you can tie it to, I would appreciate it.
It would make it easier to track it down.
18 DWhat you are saying, I guess, is that that system j9
-- 11 av " if it didn' '. uv en th.e list cf safety-related equipment, there 21 was a censiderable reduction in the quantity of testin -
22 and the quality of the QA that's applied to it, and all the 1
23 rest of it, as opposed to it being on the list of safety-related?
24 Ace-Fede,ol Reporters. Inc.
25 A
- Well,
o jrb26.
26
'O That'there's a major difference in the way safety-
- j related equipment and nonsafety-related equipmert is maintained 2
and installed and tested?
3 i
.A I don't know that I would go that far, but I do 4
1 w that I;E's ability, you knew, to identify nnd correct 5
, problers is significantly impaired if the item is not defined 6
l I as a safetv-related con.oonent.
The licensee mal very well do everything the same.
g gp I am not, you know, trying to say the licensee does or he doesn't.
10' I
i Sut I am saying when the field inspector identifies
_ j j [.
a proble= in a nonsafety-related component, you bas..cally 12 turn the other way.
j *, i l
At TMI-1, I was there 'for initial criticality, and j,
..i
-i walking through the auxiliary building; I saw a pipe which 15 16 I considered to have excessive pipe vibration.
And I wanted, you know, to get something done about 37 it.
And I-was told, "that's a recirc line in feed pump and 18 j9 it is outside,.you know, it's not safety-related, in the 20 secondary system."
I accepted that.
I had come from the Navy chilosophy 21 you know,;there's one reactor plant there, you know, you don't 22 make distinctions upstream / downstream of the mainstream 23 isolation valves.
24 Ace Federal Reporters, Inc.
That's a' distinction however that I&E does make in
'25 7
L
27 jrb27.
1 terms of its inspection program.
2
'That is not to'say, you know, a problem is identified 3
-that'is 'in any way significant that you can't discuss it; 4
but:it is not your primary mission, and it is not the intent i
5 ' of our inspection program to identify areas out of the safety 6
boundary.
7 C
Getting back to the mam that you wrote on March 8
31st, do I understand you correctly, then, that you did not 9
feel or you were not recommending that that particular 10 '.part of the system be included as safety-related?
11 A
No, I did not feel tha t was germane.
I tended to be 12 somewhat pragmatic as a result of. you know, my feelings, 13 : as I indicated; I tended to lock at a condition whether or not i
14 I felt it was good engineering or, you know, whether it 15 was the right way for something to happen.
16 And when I realiz'ed it's not safety-related, you 17 know, I give that its dues, but nonetheless, you know, say 18 I think' something should be done.
19 So,_you know, I was *.ot trying to fight that 20 bat-le; as I said, that was a three or four-year old battle 21 at that. point; and one that, you know, I could let it go on.
But let's get. around about out business of being sure these 22 i
I
'23 plants are operated as safely as can be done.
24 Q
Well, if you _had the perception that there was a Ace Federal Reporters, Inc.
25
_ reasonable charce of getting c omething added to the list of
l
-28 rb28 21 safety-related equipment, would'you have then recommended' that 2 l - this particular piece. of equipment-be added?
t t
3 A
Perhaos.
I
~
4
'4 Except that po' int.it would be ene of many things, 4
~
5 y and I would have been :looking for a program that relooked 11
- 6 l at everything, and ' got all of. those things -- either get rid 7
of the definition of, you know, " safety-related" and say, 8
you know, the component is in the nuclear power plant, it 9
'shculd be as good and safe as possible.
10 I,
for one, you know, recognice the need for these 11 kinds of lists, but I do not, you know -- it gets to be a 12 l legal game, whether it's on the list, whether it's not on the 13
' list.
'It never seemed to me that inpertant.to core up with p
14 good lists, b'ecause as soon as you do, one of the ' arguments 15
-- getting back,.for example, to diesel generators, has to do
~
.16 with whether or not the fuel for diesel generators was 17 safety-related.
18
.You know, if you have a tank-full of what you think 19 is - diesel-fuel and it turns, out ~ to be salt water, again nhe
~
20 diesel-generator won't work.
21 Q
Let me interrupt:
22 How would 'anyone view that fuel. for the diesel 23 generator is not safety-related if they argue the diesel
'24 gererator is?
-- for the obvious reason that you say, if you-Ac F.d. cat a.po,
,s, inc.
~
25 don't have'any_ fuel for it, it doesn't do~you any good?
jrb29 29 A-Well, I don't know the answer to your question.
1 2, I do know that that was one of the examples.
3 Again, if you want 'to know the person that pursued t
gh that item, that was Ebe McCabe, who was arguing the fuel for ll dis 5*15* or:t::S Sh* ld h* 5 f*t7- *1 ted : d> ther*f 5
fall in a quality' assurance program.
6 In other words, the samples should be anlyzed, there 7
o should be some control over where it's purchased from; you know, g
9g what's put into the tanks.
.d One of the counterarguments -- and I don't know 10 who raised it -- they said, "well, if you are going to make 11, the fuel safety-related, well how about making the air for 12 13, the diesel generators safe,ty-related; because,you don't want
~
to run out of air, either?"
j4 And sometimes it devolved into one of these 15 pr ductions, you know, of an absurd situation kind of thing.
16 But I think one of the arguments was it was a 37 18l c nsumable, and therefore it didn't fall under the QA program because the QA program excluded consumables.
j9
-- Again, to me, I-tend to look at things technically, 20 and whether it's consumable didn't really matter; if it was 21 essential, you know, to me, a safety objective, then it was 22 by original definition safety-related, and that 's the way I'd 23 have it.
24 Ace-Feeer;l Reporters, Inc.
0 Getting back to the memorandum which you wrote, was 25
J,jrb30 30 I
that memciandum part of the normal function of your job?
2 A'
Possibly not, no; perhaps a real section chief, not 3, acting, would have an inspector write it.
i 4
I sort of was neither a fish nor a fowl:
I felt lil like myself I was an inspector at the same time I was acting 6
section chief.
I knew that the inspector assigned to the 7
facility, who would..have written it if he were available was
~
o I had the
,18 tied up at the site.
I felt it had to be done.
I had the background and the details of the event.
9, time.
t.
10 I could answer any questions which would come up.
11 As.you can tell from the length, it didn't take a long time I
12 J to write; and so I wrote it.
I wanted to get it out fast.
(
13 Fl And it did.'You knew, again, look at the date; I am pleased 14 when I look'back at it, it didn't take long in typing, you know, 15 it was concurred in right away by Ebe, and we got it out.
16 0
Why did you feel you had to get it out quickly?
17 A
Well, I don't want to give a false sense or urgency 18' to it; perhaps I.was more afraid it might slip through the 19, cracks if I ferget; it was fresh in my mind.
20 I can say it was a Region-1 philosophy to what we 21 call " track things" to headquarters; you know, to bring to 22 headquarters' attention things like this, you know, anomalous 23 conditions that came up, that was the modis operandi of the
,= _
office, was, you know, to write a memo, get any actionitem 24 AceFeoeol Reporters, Inc.
25 in the tracking systen.
1 l
l
3rb31 31 1
So I felt it was well'within our normal way of 2
doing business.
The only thing is you might ask whether, you 3
know, I thought it was significant -- really not; an inspector 4
I typically would write that if he were in the office.
He i
5 might do it at the direction of the section chief, or again 6
as an. individual; it's sort of a management rule to identify 7
those areas that are particularly significant or potentially 4
8lgenericand,youknow, to ensure that they are passed cn.
9l 0
I notice that you sent the memo through Ebe McCabe; a
10 l is there any particular reason why you did it that way?
I 11 A
No.
12 I wrote that and, nc, I don't recall why I did it.
13 There were always discussions in the office about 14 what level in th'e office could contact what level in 15 headquarters organization, things like that; and it may be
.16 because it was going to an AB that effectively it should come 17 from a branch chief.
18 There was another thing that was going on around 19 about recognition of individuals.
The policy in the past had 20 been everything was signed by a branch chief or a director.
21 The result was that the people who were actually doing the 22 work, their names were never heard of, you know, at headquar-23 ters, and NRR.
24 And there was an attenpt, and it may have been Ebe's Ace-Federcf Reporters. Inc.
25 attempt, to, you know, give the guys who were writing some I
1
~jrb32 32 I
recognition, so, you know, it didn't appear the branch chief 2
was doing everything in the region.
3 ]
So cavbe it was for that curcose.
It really couldn't p
AUccmefromasectionchieftoanAD, but it would go through a 5llbranchchief.
There were things like that that were going il 0llon.
il 7
0 Earlier you mentioned your concern about an 4
8 unannunciated LOCA; would you explain what you mean by that n
9 i ters?
1 101 A
Unannunciated -- the thing I found particularly Il i difficult to believe when I heard it was that there was not a 12 I lic_ht or an annunciator or alarm sa. vine. the cower coerated I
13l relief valve was open.
Id O
What indication was available?
15 A
No direct indication at all.
16' It was, as we know, decreasing pressurizer level, 17 or perhaps increasing pressurizer level, reactor coolant 18 system pressure, reactor drain tank, pressures, temperatures 19 and-levels -- but, you knew, I guess I was a little surprised 20 j that considering the thousands of lights, meters, gages,
~~~
i 21 alarms in the control ~ room that something, you know, seeing 22 the valve was being co=manded open did not exist.
- 23 Again, I hark back to my BWR experience, where a 24 similar valve, the target rock relief valve -- you know, to Ace Federd Reporters, Inc.
25 me that's basically a target rock relief valve sitting in the.
jrb33 33 1
pressurizer.
2 There_was an automatic position and a manual position
.3 and there was a light on it, and that's what I would have I
4 l expected, you know.
5 When I discussed it with the inspector and the 6
people at MeiTEd, the event, they said their first indication
.,t.
7 i of a problem 'other than the loss of the inverter was they 1
8 had a safety injection on their hands; and I found that l9 ' surprising, 4
li 10 ]
And I pursued it enough to find out that there was i
11 l no light or anything, an indicator.
ii 12 j O
Why did you not in your memo reccamend some sort 0
12" cf indica. tion be trovided en the relief valve'?
1 i
14 L A
When I discussed this with you before,.I indidated l
'15 that another attitude, if you will -- I am not quite sure 16 how to describe it -- a feeling of "we-don't want to do some 17 things."
18 And one of the things we did not want to do was 19 write what we call purple words or purple memos.
20 I had in the pasi written memos of this nature i-21 [ with a sentence, "I recommend this item be transferred to 22 NRR for review."
23 And somehow back through the system I had been 24 informed, "You do not put those kinds of words into a meno."
Ace-Federal Reporters.- inc.
25 In effect,JI was preempting the headquarters prerogative l
J
jrb34 34 1
for analyzing events, making the decision which ones to 2
transfer over to licensing.
N 3
As a matter of fact, I think I changed the wcrds 4
around, as I look at the meme, " producing a loss of cociant 5
condition".
I did not want to make anything particularly 6
infla=matory, you know, an unannunciated LOCA.
7 I don't have the PN with me that's referenced here.
8 Q
I don't have it right here, but I can go get it.
9 I A'
It might be worth looking at.
I had a feeling i
10 the fact that there was no light indication may have been 11 discussed.
12 MR. HESDON:
Let's take a break for about five 13 minutes.
!j 14 1 (Recess.)
15 MR. HE3 DON:
Let's resume now.
16 We will resume now, you are still under oath, and 17 the witness notification you read earlier still applies.
18 SY MR. HESDON:
19 0
What ycu have been looking at, for the record, is a 3
20 preliminary notification of event or unusual occurrence, 21 PNO78-68,. dated March 30, 1978.
22 A
Okay.
23 I notice in there that again -- and I had written 24 that PN, and I did not discuss an-annunciator light.
It is Ace-Fedwal Repo,ters. ' Inc.
25 even conceivable that at this time I had not been aware that
35 jrb35 1
there was no light.
~
7 However, I do know I subsequently did become aware 3
of it, because I had words with the licensee, Metropolita~
4 Edison, en this subject.
5 Q
What do you =can by "you had words"?
6l A
We discussed the fact that I': 1 sure they didn't 7
wcnt this, either; that they could have the PORV go open 8
and not have an indication of it.
l 9
And I suppose I became somewhat placated in this 10l whole issue when Metropolitan Edison acreed -- or maybe even I
11 propose i' 'hemselves -- to chance the lecic arrangement d
12 so that the PORV would not fail open in the loss of a buss; 13 it would fail closed on a loss of that buss.
And that they l
14 did install an indicating light on the control panel to show 15 that the valve was being commanded ope $.
l 16 At that point two significant concerns I had about 1
17 the event, as far as the PORV goes, was placated.
18 Q
Okay.
19 Oculd we go back a little bit to the discussion we 20 started to get into concerning this issue of " purple words" 21 or." inflammatory comments"?
22 You have said this is a perception that you have.
23 What caused you to feel that way?
What caused the perception?
24 A
It had come out at staff meetings, whatever you call Ace Federal Reporters, Inc.
-25 it; I think I may.have paraphrased it as " purple words," it was I
l
jrb36 36 what we call " maturity of judgment," how you said and wrote
)
certain~ things so that it conveyed the technical safety 2
e neerns without appearing to be immature or not being wise 3
i.4llinyourjudgment.
l!
- nd 90c35 it h"d C ** "P ti"* ^^d ti'* 's^in V*r' 5]
6,' you know, the time I was there and to me it was just simply 7
a way of doing business.
It was not in any way restraint on what was said, it was more, if you will, advice on how to g
1 effectively prepare a. memo, you knew, that would get the 9
10,! pcint across without, you know, being necessarily condemning f
- ) L of anybody or anything else, but simply, you know, to keep I
the meno addressed en the technical issues.
12 O
Who were you trying to -- and this may be overstating L3..
l i it a little -- who were you trying to shield from these 34 n
amma ry w rds?
l 15 Was it a concern about headquarters reading this 16 type of material?
37 Or was it.a concern the utility would be upset if 18 39,they'saw these sorts of things?
A I really don't know.
20 j L
king back at it I would suspect that it basically 21 resulted from the-public record,nd things being quoted out 22 f context.
1 23 24 l-And, you know, perhaps the thing was not to put more An FWwol Rgenm. Inc grist into the antinuclear mill, you know, saying certain 25
=-
~~ '
jrb37' 37 1
things when you read that sentence alone either without the.
2 background of the issue or without the technical knowledge -
3 that, you know, surrounds the work we do; and it would seem i
4I to represent to the layman a more significant or serious I
5] event than'it actually was.
I 6
And I think, you know, part of the caution was to 7, be sensitive to this type of thing, and to, you know, if I
4 8 ' nothing else be circumspect in what was being said or written.
9 BY MR. PARLER:
10 C
The caution came from what source?
From Headquarters, 11 l. or the then director of the office, or frcm someone else?
t 12l A.
I assume it came from headquarters.
It was passed 13 On in staff meetings.
L 14 O
By the* person in charge of the regional office?
15 A
Down through the branch chief or the section chief.
16 BY MR. HEBDON:
17 Q
Was it passed through in basically the same context 18 you have it here, or was this your interpretation of something 19 someone else said?
20 l
A It. basically is the same.
It was never, you know, I
i-21 ' it was never an attempt to say, " Don't inform us of things, 22 don't,,you know, pass on safety concerns."
23 You know, nobody -- it's not that we don't want to 24 hear it -- and I think the term " maturity of judgment" came Ace-Federal Reporters, Inc.
25 up time and again.
L.-
1
jrb38 38 1
And it was a matter of selection of words and things.
2 O
Why did you feel that the term "unannunciated LOCA" 3
would fall into this category of words?
4 A
The more I think about it, the more I think I might i
5 not even have been aware at the time of the lack of 6
annunciation.
7 I have a feeling, the more I think about it, judging e
8 by the timing of that memo, that we had not in any way finished 1
9 our investigation of that event.
10 And I think the fact, as I told you before, that 11. that was a " purple word" -- it's probably a mistake on my l
12 part.
13
.I think.I became aware of the lack of annunciation 14 afterwards, and therefore, it was really something that 15 transpired between Met Ed and I and Don Haverkamp in terms 16 of what things were we looking for the licensee to have done 17 as a result of this event.
18 And one of the things that did come out of it was 19 the installation of a light.
20 Q
Mell, looking back on it, regardless of the time 21 when you thought of the term, why now would you consider 22 "unannunciated LOCA' to be an inflammatory term?
23 Is there any significance associated with that
.24 particular term?
Ace-Federo! ' Reporters,' inc.
-25 A
I don't -- I think I might have overstated it when I L_
-~
- j rb39:
39 I
talked to you before.
2 I did not have thau memo when you and I spoke over 3
the telephone.
And, you know, I was trying t: recollect d
then whether or not L discussed it.
5 l!
But the more I think about it the more I have a 11 '
6
' feeling that it did not come to my attention until afterwards.
o 7
That, even today, might not be the way I would 8
characterize this condition.
It is a succinct way of saying 9 { it, but I might state it differently simply to more 10 l accurately define what it was, the condition of a relief valve i
I being open without-any indication that it was being totally i
12 topen.
i
'13 g.
To whom did you send the memo?
1
~
Id A
Karl Siyfrit.
15 Q
Why to him?
16 A
It was sometimes confusing to figure who to send I7 something to in headquarters -- at least to me it was 18 confusing.
I9 However,-at that time I knew that my branch chief, 20 Eldon Brunner, was always on top of who things should be 21 directed to.
I found sometimes the organization.in headquarters 22 personally to me to be confusing,.and quite often I would 23 simply ~ask someone:
here's my concern, who do I send it to?
- 1 I'And.Eldon would make a decision and tell me.
24 Ace Fasol Rgenm. lac I
25 And I have-a feeling that at that point it was 44-M6m mmh WmW N
.jrb40 40
'l probably, you know, based on my asking Ildon, or, since 2
probably Elden wasn't there I may simply have gone back to the 3
last meno I had uritten er semebody else had written, and 4
gotten the name and title.
I ft 5
0 I notice the distribution on the memo does not 6
include a copy to anyone in NRR; do you recall if copies were 7
sent to anyone outside of I&E or to any in NRR?
8 A
It was very infrequently, if at all, that memos 9
of this nature would automatically be cc or vec to NRR.
I 10[
Q Why?
11 4
A I really don't knew.
12 It was simply, I think the headquarters organization 13 served c, screen and turn these types of things over.
Id Q
So even at a VCC level it would have been considered 15 inappropriate to have included NRR?
16 A
I don't know whether it would have been inappropriate, 17, I believe it was not a way of doing things.
i 18 N Q
What did you have in mind should be done with them?
19 A
They should be sei.L to NRR, and that, you know, 20 very simply what it says there:
"the adequacy of this design 21 should be reviewed."
22 It was my feeling it was not an adequate design, 23 thatLit was not'the way somebody -- whether or not it was 24 intended to function that way really didn't matter to me;
~
AceFeeeral RepoHert Inc.
J 2.5 ! 'but 'now that the significance of that design had come to my l
jrb41 41 I
attention, I felt that it was not what somebody would really 2
want, and once called to their attention it would require, 3 : you know, the change.to be made, to make it not~ fail open 4 ll on loss of electrical power.
5 0
You felt then it should be sent to NRR for revieu?
6 A
Yes.
7 0
Why did you not include a recommendation in the 8
memo to that effect?
9 A
As I indicated a few minutes ago, once er twice or 10 even more often I had included that type of request in the 11 memo; and I had gotten feedback through the organization that 12 that was not the type of thing that would be included in a I ~'1 memo; that that decision was to be made by the headquarters Idli organization.
15 Q
You were not even given an option of making a 16 recommendation?
17 A
I am sure that the letter wouldhave been typed and 18' forwarded with that recommendation in it; yes.
I was given lo the option.
It was just I had no reason at that point to 20 put it in after I had been asked not to put it in.
I O
What was done as a result of the memo?
22 A
Well, there was a response which came back a few 23 months later, I think in May, i
24 i
O For the record, this is a memorandum for E.
C.
Ace Fedecol Reporters. Inc.
25 Brunner, dated May 3rd, 1978, from K. 3.
Siyfrit; is that
jrb42 42 1
the response you received?
(handing document to interviewoe.)
Y**'
it i"*
3 Q
Did the response that you actually received
. cersonallv include a copy of section 74116 of the FSAR which 5'
is referenced in the memo?
l A
No, not.that -I recall.
I read'it, cpened it up I
t and looked at it.
8 0
You did look at that section of the FSAR?
9 A
.Yes, I did.
10' O.
What did you get cut cf that, what did it tell you?
A I am coing to read it again.
12 l
~
Q Certainly.
13 1.
(Pause.)
A Okay.
It told me about what I already knew, that somebody l had considered it could fail open, and the'v had put a block 17 valve in'it.
Again, my concern all along had been, yuh, I know 19 that; to me it represented an unnecessary challenge to the 20 l
l reactor-coolant system integrity; and that you just didn't 21 want things randomly popping open on a loss of electrical oower situation.
23 O
From reading that particular section of the FSAR, did' you.-- do you read that to say that the valve not only i
I
jrb43 43
'I was consideration given that the valve might fail open, but 211 the valve was intended to fail open for a fairly specific 1
3g reason?
4 A
No, I had a feeling they had considered the valve 5l could fail open.
It says in the event that the relief valves 6
were to f ail in the open position, then pressure could be 7
contrciled by cycling the block valve.
~
8 Q
But it says earlier in the section that the t
9 redundancy is provided by the blocking' valve, and the only way 1
10 ' that redundancy could be provided by the blocking valve is if l
i 11 l the relief valve itself f ails open?
12 A
Well, I didn't reed it that way.
I 13 In fact I am not quite sare even now that I cuite 1
14' understand what they mean by redundancy.
15 vor example, en a safety valve there is no back-up 16 capability; there is no redundancy.
17 Q
The redundancy of the other safety valve?
18 A
.Well, that's a functional redundancy, that's 19 parallel valves.
I 20 Here's it's functional redundancy, if you will, to 21 close a loss of coolant path, and the valves you place in 22 series; so the concept of redundancy on safety valves is a 23 functional redundancy, that in two valves each_of which is 24 I capable of relieving-the pressure; whereas here you are ac. F.d. col n.porwn, ine.
_.25 talking.about redundancy -- and the ability to close, like they
jrb44' 44 j
are talking about a bloc: valve can.be operated outside the ntrol room, 2
3 Sea I don' t -- I. am not quite sure what they. mean i
I here by redundancy.
4 O
Well, as I understand it, what they are talking i
S about there is that the functicn to be performed 6
is the ability to contrci pressure.
7 And what they are saying is that you can manually 8
9 operate the relief valve to control pressure during a shutdown, which is the centent of section 7.4 cf the FSAR.
10 A
Yuh.
jj O
Now it's the redundancy of that function, the 12 ability to control'oressure, it's crevided bv the fact that 13 i
l, j4 there's also a blocking valve that can be operated, that can be opened and shut;-and that that redundancy is provided by 15 virtue f the fact that if the relief valve fails, it vi'1 16 fail open, leaving the path open, so that you can then use the j7 18 blocking valve to perform that function.
A That's one war of looking at it.
I wouldn't'look
.j9 l
L
.210 at.it that.vay; yuh.
-21 Q
And'I assume that what you're saying, you didn't l
1 k at it that way.when you read it?
22 23 Tolme-that safety valve is something that's open A
2g for an extremely short' period of time, for the vast majority J Acefusieral Reporters, Inc.
'25 of?the safety valve, tr a relief valve, it' won't'be open f'y I-I-.
r
45 lrb45 r
and I can see how you are reading that.
.j
. Functionally 2 don't think of a safety relief valve 2
l 3 }.in=that context.
t As_a matter of fact, if that were the case I would 4
e ae
.a ser us concernt about ine change which Ene 5(
1 l
licensee had made if, indeed, failing in less of power the 6
bistable was a design intent,'then I would have consideredit 7
an unreviewed safety question to make the change to have it 8
fail closed on a loss of power to bistable.
9 10 C
Well, that. was one of the qusstions that I was l
jj going to.ask you, that - did you think the licensee's decision to have the valve fail shut, rather than failed open, was 12, an issue that required a review before the change could be 13 made?
j4 A
Not one involving NRC, no, I didn't.
15 Part f it, and I can fall back very comfortably 16 at this point, and say it was not safety-related; and again, 37 l
that could change what was required in terms of what the i
18 licensee had to do.
j9 20 The changes made to systems that aren'u i
safety-related fall into a different category of design review 21 and approval than do those that are safety-related.
22 The realissue here was, you know, what I harken 23 24 back to very simply is, the bistable, does it energize or Ace-Federal Reporters, Inc.
25 deenergize to' perform its function?
r t..
- n.
.l
jrb46_
46 1
And I'know design considerations go in for 2
engineered safeguard questions, which way the bistables 3 l energize or deenergize, whether they energize to perform their 4 i function or deenergi e to perform their function.
t il S il To me the way that I thought the system should be 6
was'that anything that can induce a loss of coolant accident 7
shculd fail safe, and fail safe in my mind - in this parameter 8
the valve fails closed; to take positive action to produce
,,9 ll that infrequently desired event of opening the reactor n
11 10 1 coolant system essentiallv atmosphere -- not that it failed i
I 11 i in that position.
i 1
12:1 0
So then in your mind there was no analysis of that ti I!
h 13 chance in desien recuired bv the Staff?
~-
14 A
Not by NRC S taf f, no.
15 Q
What about the utility?
What analysis was required 16 on theirpart?
-17 A
Whatever was required by the plant design change 18 ! procedure which, that procedure itself, was reviewed by the 19 NPC and -
20 Q
Uould it be part of their tech specs?-
21 A
Not directly.
22 It may say the plant operation review committe. was 23
~ responsible for all changes, but the actual package of'the 24
- plant design change -- in other words, the thing that would
- Ace-Federal Reporters. Inc.
25 set forth ~why they. would want to make the change, how they
eb47-47 1
would propose ~to make it, that whole design change package is 2
a system that the NRC looks at, and essentially in erms of 3
an adequate system.
4 So I knew the change that would do this was done 5 [
in accordance with that.
Did you -- as you understand that change procedure, 6
O 7
would the change have been. reviewed by the plant operations 8
review committee?
9 A
Absolutely.
l 10 I
Q Do you know for a fact whether or not it was?
l 11 d A
I don't recall.
'i i
12 I remember the issue was discussed in Don
- 13 ;' Eaverkamps report.
I. don't know whether or net he indicated ei p
14 i he reviewed that design package.
15 So I do not'know if that was done.
i l
16 I
Q Did you find the response that you received to be-17
-adequata?
I 18 l-A Well, first let ne say, I said yes to the 19 Kemeny Commission in answer to that question.
20 I will say yes, again, and qualify it the same way 21 ;.I did there -- I hope --
2:2 A)-
I was somewhat flakey about the fact uhat
'23 Met Ed at Three Mile Island-2 had changed their bistable and p
i 24 had installed the indicator light; AceJederal Reporters, Inc.
25 E)
I believed then and still believe that it's the I
jrb48-48 1
purpose of headquarters to establish a priority of things that 1
2 come in from the field.
3 And'my basic conclusion was, yes, the FSAR did 4
address it, the idea of a PORV failing open, you know, was not 5
an alien concept.
6 But I knew, you know, for a variety of reasons 7
a relief valve cculd fail open.
Target rock relief valves e
8 in boiling water reactors periodically fail open.
And I, 9, you know, understand that potential.
t 10H I felt I had dispensed an obligation, that a 11 condition had come to my attention; I had passed it on; I knew 12 that headcuarters hac seen it.
Thev had researched it to the l
13 peint at least of estab'4e'i ng the FSAR.
4 14 And they had responded to me.
In effect, a loop 15 was closed.
.16 In that regard, the response was back, I got a 17
-response; somebody had looked at it, somebody in a position 18 of looking at it from the perspective of the other things that 19 are going on; and they addressed the matter back to me.
20 I feel in that regard it was adequate.
21 I willagain emphasize what I told the Kemeny 22 people:
that had somebody gone to battle' stations on this, 23 it would not probably have changed Three Mile Island PORV 24 failure, in -that A), it didn't fail 'ojen because of an electrica l ke Federal Reporters, Inc.
25 problem; and 3) that valve does not lend itself as it was l'
lirb495 49 1. presently designed in any form of direct position indication.
2 I thought it was a great breaktrhough for safety 3J when t;ey put the light in parallel with the celanoid.
I I!
4pl.would have probably -- had I been asked:
is that an l
adequate positien-indicatien? -- would have said yes, 5
t-6 l considering what would be necessary tc get direct indication.
i 7l You have to essentially replace that valve, redesign i-it.
8 0
9h would have been -- probably I wasn ' t in a position A
a't 10 p tc de this -- butmentally I wculd have said the cost Of 11 doing that comparing it to the benefit -- there are indications
~
that the valve is open.
12 13 y -
And I also knew that even when you have pcsitive l' valve indidations you get problems in other valves with a 34 stem and a disc of a gate valve become disconnected, and the 15 16 stem clearly indicates the valve is open, although the disc is fully closed.
37 i
There is so far you can carry this, 18 j9 I think I would have been totally content in the 20. best of all worlds if the response had come back and said, ves, I
t 21. we required all B&W plants to ensure that the valve fails 22 closed wiyh loss of power and they put these indicating 23
- lights in. parallel with the celanoids.
24 And that would have in my mind been 99 percent of
, - Ace-Fooerd Reporters, Inc.
25 the best of all possible worlds, rather than going in and
.w.m.
q m=.-
=+
,e.-
4
'jrb50 50 1
modifying the valve -
~I don't think I would-have felt it 2
was warranted or demanded it if I were totally in charge of 3
this thing.
4 Q
What did you'do after you received the response?
i 5
A Basically ignored the issue at that time.
6 As I said, at Three Mile Island-2 it was solved, 7
and I might have been sensitive to another occurrence.
8.
I in the past when something didn't quite go the I,
90 way I wanted it, I became sensitized to it; and in reading i
1.
10 notifications from other regions or a book which I discussed 11 with the Kemenv ceople -- it's called Nuclear Power E :reriences.
l
.12 It comes out monthly and has.very good summaries of 13 operating events and problems at plants.
14, If I had neticed something I might have r'esurrected 1
15 the issue.
I've done that in the past.
16 l-A thing that I had been concerned with in the past i
!~hadbeenoperatorerrors.
I had tried to get an I&E bulletin 17 i
18 written on the subject of operator errors, and it was 19 not received.
20 I
Q What was the subject?
What were the details?
21 A
Well, if you want to see it, it did subsequently 22 did get issued after~another event; and I was going to bring 23 it-up.
24 I was sensitized to that issue, and after the
. AceFedecol Reporters, Inc. j-25 Millstone inadvertent criticality, I proposed the bulletin
Mb51-51 1
again;.and this time it was issued; 2
However, it was issued as a circular,_I&E Circular.
3 7607.
14 And I think I've got a copy of that if you're 5
interested, down in the car.
I
- 6 O
.I've got a cocy.
7 A~
Okay.
8 And the thing that concerned me was events which had 9
been occurring, and I think I used the words, " degradation t
.I 10' in defense-in-depth contribution of the operator".
I strongly 11 believe that we were going to have a problem with operater 12 error, that it was going to play a significant role in it.
13 And again that becane a point with me.
It was i
.14 necessarily the licensed operator but the guy who was doing 15 tests, leaving valves closed, things like that.
16 0
Why wasn't the memo sent out or the circular sent 17 out when~you first proposed it?
18 A
Well, I had gotten involved in writing several 19 bulletins and' circulars, and, again, it is a matter of, you 20 know, feeling defeat before you start.
21 I can remember the example of a bulletin I had 22 proposed.
There were several having to do with switch gear; 23 that,:you know, a response would come back, "we've checked
/
24
'with a couple of plants, they don't have that problem."
Ace-Federst Repo,ters. Inc.
25 To me that was. missing the idea of the bulletin.
The t
+
.jrb52 52 1
bulletin was.to go out to everybody, to alert to a problem, lyouknow, do.a spot check through the other plants, see if they 2
3 have the problem, because it may be the fourth plant you would ai have called that had tue problem.
5[
RSo the issue of headquarters issuing bulletins I
6 and circulars had been one I had been involved with several 7
times in the. past.
D 8
As a matter of fact, as I think about it nou, I am 9
not even sure that I had written or prcposed in writing a-10r bulletin befoie the Millstone criticality.
I had discussed it 11 probably with Jim O'Reilly tenonetic), the Regional Director 12 at the time; and I thinkwe reached the conclusion that it 13 wasn ' t the kind of thine. that was c.oin. to cet issued.
14 But he strongly supported it.
As a matter of fact, 15 within about 20 minutes of the inadvertent criticality 16 notification in Region-1 he directed me to go ahead and write 17 the bulletin about operator errors.
18 0
I guess I still haven't quite figured it out:
what
_19 was the reason he felt it would not get issued?
20 A
I guess I no longer can remember enough to be 21 meaningful to the thing here.
I don't remember whether I had 22 written one.
I can remember that at the time of the criticality 23 I: felt _that we had enough at this point to go with one.
24 0
- What sort of reasons would form a basis for not Ace-Federal Reporters.' inc.
~ ' 25 issuing a circular'when someone~ felt that there was a need to
-jrb53 53 1
issue one?
2 4
I really don't know what went into that kind of 3
decision.
I still don't know.
I i
4 I
EY IIR. PARLER:
l 5
O That was a decision that was made at headquarters, 6
I understand; was it?
7 A
I don't recall on that particular bulletin whether 8
we attempted it in writing or not.
There's no doubt in my 9
mind' that at' the time of the Millstone criticality I knew that 10 l we-had enough justification to trv it; whether or not I felt 11 before there weren' t e..our h specific er.amples, I had been a
12 involved in several events that were operator errer contribu-I T3 i tions which were sicnificant..
a i
14 And I felt that this was an issue that had to be 15 addressed.
And' clearly at the time of this criticality we 16 went ahead and wrote that proposed bulletin.
17 I was basically. disappointed it was not issued as 18 I a bulletin.
I can remember mentally saying to myself:
be 19 grateful at getting it out; don't fight the battle that it's 20 a circular :.ct a bulletin.
i 21 l
.The significant difference is
'..h t there 's no l
1 22 action required of a licensee with a circular, whereas in a 23 bulletin licensees we.21d have had to commit in writing to what 24 they would have done in response to that, what was issued as Ace-?sderal Reporten. Inc.
~25 a circular.
i 1
l i
?jrb54 54 1
Q And where was the decision made to issue it as a
~
2
.circularLrather than as a bulletin?
3 A
In headquarters, and I don 't know where or by whom.
4 O'
Do you have -- you submitted it as a bulletin?
'5 Did you submit just the document as such, or is there a cover 6
letter that says why it ought to be a bulletin as opposed to 7
a circular?
8 What are the mechanics of that?
9 A
You propose it in the form you would like to see it 10 issued.
It's proposed as a bulletin.
11 Q
All right.
12 A
And in terms of a cover letter, no, I don't think 13 a cover letter -- I don't think justification is necessary.
The 1
l idea is it is supposed to be self-standing.
14 15 Yuh, but the argument, the decision of whether it's 16 a bulletin or a circular is not included in the bulletin itself, 17 Q
So it would seem as though there were going to be a 18 l decision made, particularly if there's a chance that the 19 decision would be made to issue it as somethine different 20 from what you originally proposed, that you wculd want to 21 include some sort of description or justification of wny you 22 had~ prepared it as what it was, as a bulletin?
O 23 A
Well, I don't know the answer to that question.
24 I can tell you-that it is not significantly different Ace-Federal Reporters, Inc.
2.5 today than it was then in terms of getting sonething issued as
l
'jrb55 55 u-I a bulletin.
2 O
So you write these things up as a bulletin, you send 3
them in to headquarters,.and it may be issued as a circular?.
d And1 headquarters,. based on their decision without g
5
-any input from you issues what they feel -- issue it in 6l.whatever form.they feel it ought to be?
t 7
A
- Two things:
one, there are criteria, and it is 8
stated in our manuals what is a bulletin, what is a circular; seendly, the' battles which I have been having recently in thae 9
' 10 l area have not been on bulletins or circulars I have proposed, i
II l but those that have come across my desk for review being i
12 forwarded as a circular as issued and sent cut to all regions 13 for comment.
Id Chay, aEd in my comment on a lot of the circulars 15 I say, these should have been bulletins, that they should 16 demand action of licensees.
17 Essentially the circular says all the right things 18 I but doesn't require it.
And essentially a licensee could 19 ignore it.
20 The responsibility then effectively shif ts to the f
21 l inspector to review what has licensee done in response to that l.
22 circular.
Well, legally, the licensee could do nothing and 23 become compliant; typically, the licensee is responsive to the 2d circular,-not because he has to but because he is respon-Ace-Feder:1 Reporten,' inc.
25 sible.
1
56 rb56 c..
And it just seemed to me that in a larga numbar of j
cases things are issued as circulars which~should be issued as bulletins.
3 I am not familiar with, you know, what are the 4
l reasons and'probleDS that go into that decision-making it U+ process.
6I i
I know I have had frequent discussions with our l
7.-i I headquarters up to now because one of my jobs in my current g
9g position is to. review bulletins and circulars when they ccme v into the Office and pass on our comments back to headquarters.
.i" 10 t
And if I were to lock for the single-most common jj eierent it is, vou've cot the right subject material, but I 12 lt think it should be a bulletin not a circular.
13 O
What happens, do vou make those. recommendations in 14 the response you provide?
g A
Yes, cuite often they over the telephone; sometimes 16 they are in writing.
g
- """Y
- U O
18 circulars to bulletins?
)9 20 A
da I am aware o f.
O Out of about how many ycu have recommended on?
21 A
Five to ten, I imagine.
22 Q'
Getting back to the memo that vou wrote in the 23 March 29 incident, did vou feel that that incident had anv 24 AceFederal Reporters, Inc.
ceneric 1molications?
,5
-jrb57 57 1
A Yuh.
I had indicated in the memo I thought it should be reviewed at TMI-2 and all B&W plants.
C The' solution that the utility proposed of changingr 5l the-valve to fail shut and puttine an indication, did you feel I that that had any generic implications? -- that that should be imolemented on other plants?
7 A
I think I forcot.
The Kemenv Commission asked me 8l
~
~
' the same question, and somehow it had been solved in my mind 9I at Three Mile Island and uhat the other plants were doing at that point sort of escaped me.
_))
I know it was a concern when I urote the meno, 21 bec'ause I thought it wnuld be part of the system succlied by I,*
thh NSSS; and when I got the response I had been trying to
)
think why I did not propose a bulletin or a circular at the 15 time; and it was basically a verv simple,-straightforward 16 matter.
17
^*
18
-simple question to ask; and it seemed to me Licensing was e
ne a
u ge e
n ma on and make f.ne c'ange n
20 necessary, you know, to go out and tell them, you know, to g
make sure it goes this way instead of that way.
And it is not -- for example, the bulletins I 23 had written in the past had to do with, if you had this 24 Ace-Foecol Reporters, Inc.
i particular model GE circuit breaker, there's a problem with t,e n
25 l
1 i
d
jrh58 58 1
ratchet, or something.
God only knows where they are in the 2
plants who has them, you know; that requires some research.
3 So I think the reason I didn't even consider a a
bulletin at the time, it was a rifleshot kind of thing; it was 5
a very clean question.
That's why it only took one paragraph 6
essentially to raise the technical concern and, you know, 7
request the etion required.
8 0
'icensing never knew about this, they never 9 I were involvet ny of this exchange?
10 i
A Well, I would not swear to it, but there's no doubt 11 in my mind that Harley Silver heard my concerns.
i' 12 And again I'm not trying to put Earley on the spot 13 because it may be that I am wrong.
But I have a feeling i
14 that in my discussion with Harley which was very frequent, 15 that I raised that issue.
16 BY !!R. PARLER:
17 0
I have a question:
18 I gather from some of your responses that it is 19 typical for a per7on in the regional office, such asyourself, 20 te have frequent contact with the project manager for a 21 particular plant.
22 On the other hand, when an inspector such as yourself 23 in a regional office has a significant,potentially significant, 24 9afety matter, that may have generic implications brought to Ace-Fede,el Reporters. Irm 25 the attentien of ' he headquarters people, that in such a
j rb59 -
59
'I situation that the individual inspector has to go through 2
is pretty much bound by the decision of I&E 733 Headquarters, 3
neadquarters.
A Is that understanding of these channels of.communica-5 tion correct?
0 A'.
Yuh, I think it's essentially correct.
There has never been any. suggestion about prohibition of direct 8l communications over the' telephone with the licensee project 9
. manager.
10 "l But in terms of really getting into -- I can remember on the sodium hydroxide issue that I kept imploring 4
12, F.arley to get somebody to do something in licensing to get lthissodiumhvdroxidesituationcorrected.
1s tij And I can remember his te17.ing me that he had gone 15 up and talked to the reviewers and that nobody seemed to share 16 our concerns; that he, you know, didn't seem to find a vast i
17 ! resconsive audience out there with that kind of concern.
i 18 That~ suggested essentially to me that had I gone 19 through the ' formal route that it wouldn't be particularly 20 i
I different.
There's a point here on the PN which is issued
~
-- by the way, the region propos=6 a preliminary notificaticn; 23 headquarters' makes a decision whether or not to issue a PN.
24 The region is then informed whether or not the PN has been
< Ace-Federal Reporters, Irw
-25 issued. 'And PNs do get over to NRR.
I
~
- jrb60 60 1
And in that PN which I had written, I believe
'2 there's probably some reference to the relief valve f ailing 3
open,'which, you know -- yuh, I did indicate it, does open 4
in lcss of power.
8 5l Q
The PNs which are issued get over to NRR, but I l
61 guess a PN, if somebody at I&E Headquarters decides not to e-l 7
issue one, then there is a chance that NRR will not know about 8
the situation?
9 li A
Yuh.
Il
!i 10 Let me emphasize that a PN is a separate piece of 11 f paper.
It is sort of like a news flash, compared to a l!
12 '
request for action, which, you know, goes another route.
13 NRR does ge: Pns and that ddes get over tc NER.
14 Q
'Are the' majority of PNs which are proposed by 15 regional offices, as far as you are aware, issued by 16 headquarters?
17 A
Yuh, I would think it would have to be an extremely 18 trivial matter before it isn't issued by headquarters; or 19 it may be coming in from a let of different plants -- for 20 example, if a Part 21 report ecmes in and that affects all i-21 Westinghouse plants, each region may submit a PN for each 22 licensee that calls it in.
23 But headquarters will only issue one PN perhaps 24 onLthe subject.-
Ace-Federo! Reporters, Inc.
25 So, yuh, I don't think there's been any problem I
m
jrb61_
61 j
in.PNs not being _ssued.
.Y MR. HEBDON:
2 Q
Were there any other aspects of the March 29, 1978 3
i incident at TMI that are relevant to the March '79 incident 4
5l ~~ '"**
I I
A I think there's something I was reading, someone 6
may have suggested it -- the high pressure injection pumps 7
j had been secured -- oh, they were secured during the March 29, g
.I I '78 event.
9 10 But again there was no essential need for safety jj injection, and the reason for securing them was one I agreed with completely, to minimize sodium hydrcxide being injected 12 into the reactor coolant system.
13 I
There wasn't any real concern on fuel damage, as I ja said, the core was essentially clean.
15 O
The next few quastions concern the relationship 16 between I&E and the Region and some of these things we 've j7 already touched on; but I would kind of like to go over them 18 39 again just to ha'e a complete discussion.
20 What is your general perception of the relationship bet'<.'een I&E Headque.rters and the IEE Regicns?
21 A
Well, I can speak from an interesting coint:
I've 22 23 n w been in two regions; I started in Region-1 and now I'm in Region 24
' Ace-Federal Reporters, Inc.
25 For ora thing I would say it does not significantly
=
62 jrb62 differ-between the two regions.
j The regional office feels that'it has its mission 2
1 assigned to' it and that periodically as a result of the 3
guidance which is provided with interaction with headquarters 4
I 5]
8 #8E2iT8d*
I am not quite sure what to answer your question 6
with, since I am not sure specifically what you are getting 7
IB! at.
I 9 ;
Q Uell, is it more of a friendly relationship or more i
' cf an advarsary relationship?
10 A
I think it is definitely friendly, definitely one
);
l of, you kneu, people basically know each other, know the 12 4
13,j pr blems each other has, you know, respects the prchlems; 34 ] each unders tands the ether's mission and the objcctive of, y u know, all of them getting the jo'r done the best they 15 can with the available resources.
16 I would not in any way characterize it as an 37 i
adversary one, jg I think there are times when there are differences j9 of pinion resulting from a difference of perspective on 20 21 given issues, but, typically, it is not a hostile one.
BY MR. PARLER:
22 Q
Is the mission as you understand it, Dan, of 23 I&E Headquarters essentially the same as the mission of 24
- Ace-Federd Reporters, Inc.
25 regional offices?-
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A No.
I characterize the mission of I&E Headquarters 2
l 3 b' as basicallv inter f acing w.'.th the outside world, namely, ti all the other offices within NRC, Congress, the public, in 4
i b
5 "l developing progranmatic guidance for the field of fice.
I 6l censider that a different missicn than the regional office,
' which is, as I said earlier, the eyes and ears of the NRC 7
to gc out where the plants are to ensure that the plants are 8
O 9g reatly :ne way the people who license ther and establish the h
l; 10 " standards think they are, and to surface issues where correc-11 tions may be recuired.
^
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3Y MR. HE3 DON:
12 I
Q Would vou sav I&E Headcuarters enhances or hinders 13 i
your efforts to perform what you consider to be your f"4nction?
14 A
I think they provide an essential leveling action, 15 that there it no doubt in my mind that there are differences 16 in the aggressiveness of inspectors, branch chiefs, regional 37 directors; and that they provide some sense of uniformity.
jg They collect good ideas and recommendations where 19 4
20 they exist in the field and disseminate them in the program l to evervbodv; i
and if necessary -- I am not sure I could cite 21 n I.
1 an example, you know -
essentially come back to a region 22 23 and say, knock it off, or get started in this area; you are 24l not doing enough.
Ace-Feder I Reporters, Inc.
I think in that sense they provide and complement 2s.-
11 i
i
.64' Ljrb64 the I&E field.
j O
What is your perception-of,the relationship between 2
I&E regi ns and NRR?
3 l
A There probably is very little formal connection 4
l" between the regicas and NRR.
chere is probably a great deal 3
f inf rmal relationship with project inspectcrs and as I say, 6
Project managers, because of problems which occur where a 7
li ensing pr e t manager wants to know about something 8
or there is a meeting and we're involved in the same meeting.
9 Sometimes when a ccncern was issued it was also 10 an NRR meeting, the LPM, Licensing Project Manager is there.
jj S
it is n t that I feel I am a well-known fixture 12 in licensing as an inspector, but I am a lot closh: to NRR 13 jgj!thanIwouldbe, say, to Congressional Affairs or Standards Development people.
15 Q
Do you feel that the I&E and NRR relationship 16 facilitates the feedback of operational experience in the 37 18 licensing process?
A Not directly.
I am not sure, you know, what jo l
mechanism does exist to do that; but I do not think at the 20 21' field level stuff gets fed directly to licensing, other than through an informal phone call.
22 O
D esn't get_ fed at all?
You say it doesn't get 23 24 fed directly; does it ever get there?
Ace-Federal Reporters, Inc.
25 If y u have a concern, for example, that you didn't
jrb65 65 l
1 think it was a good idea that PORVs fail ope.1.
Do yo'1 think 2
that concern, by whatever mechanism, ever got to the licensir.g i
i 3p, reviewer who reviews the particular place in the FSAR where i,
I 4
it say that valve fails open?
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10 h rcuted through them, or it may even get rcuted down to the iln 11 i w n..
1 12 j So part cf my job is to help highlight, call atten-13 '! tien to somethinc, you know, hey, remember the thing fou 14 l saw last week, you want tc take.a look at that second line i
i g
15
-ecause in there is a whole hummer k:..nc or tging.
16 The licensee event reports do get distributed.
17 l God knows, they must get distributed somewhere; licensees i
a 18 l have to submit 30 copies.
I 19 I So I know that, you know, the stuff is there.
When
'O I feel c.articularlv. stronciv it has to be highlighted so as to 21 ; make sure it doesn't slip through -he cracks, I,
you know, 22 will go this route of writine the memo.
23 C
Well, two things from that, though, first, the memo 1
24 ' the concerns that you raisedin the memo would not have been AceFederal Reporters, Inc.
25 reflected explicitly in the LER; and the memo that you wrote 11
>JxUJ 66 1
never got to NRR?.
2 A
_Well,'I would have expected I would have gotten it 3
to NRR when I wrote ~it.
It was there, it was there in the PN, 4
the fact the valve failed open in loss of power.
It was 5fprobablythereintheLLERandthe14-dayreport.
1-6 But there's no doubt in.my mind that sometimes you-7 can get something and perhaps the significance of what you are e
8 reading is not quite as apparent as some of the one-liners.
9 And that.may not be the'best thing.
10 l So, you know, it may be how much time a person has i
11 l to devote to analyzing a given incident; and, you know, I&E l
1 think is tasked with s.cendine. more of its time analv ine_
12.I i
- 13j cperational incidents than the licensing project. manager, 14
..who is looking at a totally different aspect of the nuclear 15 power plant.
16 Q
Do you feel that it's a weakness of the system
-17 the fact that you focused on that one particular problem and i
18 never got to the licensing half of the process?
19 A
Yes.
20 O
Do you feel'it's a.significant weakness or that 21
' it's - something we' ought to try to do better on?
How significan-.
22 do you consider that to be -- how significant a pr Plem do 23
.you consider that to be?
24 A-Enough that the task force I am on -- what I&E Ace Federal Repm lac.
25
- should do differently as a result of TMI, a preventive task
jrb67 67 j
group; it's one of the things I have addressed a proposal to I&E Headquarters to improve that particular path of 2
communications, both establish joint working groups and to 3
4 l essentially establish an antomatic appeal.
I5' For ena=ple,
..-ith my meme, one that's decided no further action would be taken, it would automatically then 6
7 get sent out -- I am proposing; again, it's just a proposal that has not even been reviewed by our I&E management -- that 8
9.., it would go over and get concurrea in oy NER somewhere n
10 " either at the LPM level er some level.
jj So that rather than have to use it as an opinion 12 a dissenting view -- whatever the right word is -- that method 13 where you have to go in an appear; you know, say, I am j4 dissatisfied with this, I appeal it to a higher level; that there be an automatic appeals process built-in.
15 16 And if nothing is going to happen then you get that at least from two independent organizations, both of which j7 i
18 l nave overview responsibility for the identified problem.
39 And I feel something likethat might go a long way 20 towards reducing the probability that something that should have action taken on it would not get action accomplished.
21 O
Is there a method in I&E to exchange information 22 23 among inspectors in similar plants in different regions?
A Well, the morning report is disseminated to all of 24
..AceJeoecol Reporters, Inc.
25 the/ regions.
I
68 jrb68 1
0-Does that get down to the inspector level?
2 A
It's made available, it's posted on the bulletin 3
board where the inspector has access to it.
4 Management will particularly review and highlight
-5 l and circulate an interesting morning report that may appear to
(
6 have a high level of significance or something of generic 7
applicability.
8 PNs from one meeting are distributad to all the 9
other meetings.
10' Q
How nuch attentien do these normally get from 11 the inspectors if you are an inspector on a B&W plant, do you i
12 have the time or the inclination to review in any detail 13.. the PNs frc= the other B&W plants?
r t.
14 F A
I think the key word there is "in detail".
You l
15 can't read it in any more detail than it's written.
16 O
That's part of the problem, of course, in fact it's 17 usually one page?
l 18 A
Yuh.
19 If you read it, yuh, you can absorb it.
It may
-20 trigger a similar occurrence or you might, you know, be 21 more sensitive in your next inspection to something that 22 may have contributed t: that.
23 0
You don't everhave a meeting of all the B&i' 24 inspectors,.that scrt of thing, sit down and discuss problems
. Ace Federal Reponen, Inc.
.25 and concerns?
69
-jrb69 1~
A' No, you don't.
Some of that does take place through 2
the schools they are conducting, the PWR, BWR school; but 3
there is no real counterpart meeting; although they are having I
4 [ counterpart meetings for the resident inspectors.
That's not 1
5" so much to discuss what's going on at thc plants, but aspects 6
o2 the inspection program.
7 BY MR. PARLER:
!8' O
I&E Schools?
I 1
90 A
I&E has their own training center, li h
10 i
O This morning report you referred to, I'ca seen 11 references te it in other places -- who criginates that 12 report?
13 A
It is done in the. regional office.
It i,s done 1
14 j typically by the inspectcr or his section chief.
There are.
15 criteria as to what items should be included in the MR, 16 covered by one of our manual chapters.
17 Typically any prompt report of a licensee event 18 is. included in the morning report the next morning, even if 19 it had previously reported with preliminary notification; and 20 then sometimes significant 30-day reports-are also included 21 in the morning report, and things like licensee meetings-22
'are included in the morning report.
23 They are generated at the regional level and then 24 sent in on one of our communications systems to headquarters Ace-Federo! Reoorters, Inc.
25 where it is' compiled and distributed internally.
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j O
The. reports cover things that have been evaluated 2
during the past 24-hour period, or what?
3
'A Not so much evaluation, just things which have 4
5 0
ave urred?
6 A
For example, the morning report for the 30th March, 7
I hope, would have ind.cated that there had been a safety 8
9l injection of sodium hydroxide event at TMI-2.
Q In other words, all of the occurrences in a. reactor 10 j) of a.particular region?
A All the significant ones.
The significance, it's 12 t
la,j'not as. objective as it sounds; it's basically allthe prompt f.
),I repbrts and.significant 30-day reports.
Q Does I&E review plant procedures?
15 A
es, it does.
16 O
From what perspective?
What is the purpose of 37
- "9 18 A
To ensure that they exist, to ensure that they j9 cover the plant conditions for which they are required to have 20 l pr cedures, 21 The review looks at things in terms of, is there 22
-- are there proper precautions, are there retest requirements, 3.3 24. is it.inlthe required format?
I AcrFeciero! Reporters. inc.
l And finally review for technical adequacy of the 25 a
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71 hjrb71-procedure.
j
'2
_ Q Is. consideration' given to what the operator is
, g,.
9 ing to'see and what the operator is going to do what he 3
sees?
4 A
I den't think anything that explicit is spelled out 5]
in ther requirement and I don't from my own personal experience 6
in looking at procedures.
7 That is not to say that other people who look at 8
them might not include those; but typically it does not get 9
to that leyel of revieu cr attention to that type of detail.
10 Q
D you know if anyone reviews these procedures frca 11 that sort cf perspective?
12 A
I am not aware of any; no.
13 Q
When you review a procedure you mentioned you look ja t
see if precautions are in the right place; do you look at 15 the procedure and say, here's a place sonebody could really 16 go astray; there ought to be a precaution here?
37 Do you look at a procedure from that sort of perspec-18 tive?
j9 A
Yes.
If that issue, you know, if it jumps out
-20 21 at you.
Quite often as a result of evaluating an event at 22 a plant I will discover problems with the procedure.
I would 23 say a majority of the time when we review an event, especially y
Ac6Fedorol Reporters, Inc.
if there's been an item of noncompliance, it rasults
'25
72 jrb72 I
in a revision to'the procedure.
And quite of ten it's1 the 2
' adding of_a precautionary note'or things that I have gotten 3
involved in in the past; that is, it given a. calibration is t
4 done to eight pressure switches, and I fcund'that two of ther I
5 have been left off,:I'd go back and I say to the licensee, 6
what you need is to sign off for each of these eight pressure 7
switches so that, you-know, it' won't be forgotten that two
' e.
8 of ther were left closed.
9 You'know, sit down and mentally'think through
-10 the procedure and think ef,.you know, well this would'be an II
-ambiguous indication or, you know, there's really a good 12
. chance you might misinterpret it.
13 '.
"o,.I've never gotten to that level cf detail.
I i'.
y 14 jf don't know if that'is typical of the typica' 4-epector, but i
15 I suspect it is not that atypical.
16 Q
If you find something in a procedure that you feel
.17 raises a concern, do you have a. mechanism where you can pass 18 that word around to' inspectors from'other plands that are 19
'similar in design?~
20 A ~
Not a simple'one I.can think of, other than the bulletin.
21 22 Q
You would have'to. issue a bulletin or circular, then, i
e 23 to get that' word:to'the other people?
j 24 A
Yuh.
Ace-Fo& rol lleporters, Inc.
J25 I am trying to think of examples where another i
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73 rb73-mechanism e.tists'.
I'm sure.when I go home I'll think of one, 3
but I can't think of any that would do that.
~2 O
Doyou review all the pro <edures, only emergency 3
procedures?
4 A
I personally have not reviewed that many procedures.
5 I In' Region-1 they.had' inspectors who were. assigned the 6l responsibility for reviewing procedures.
I never was one of 7
those people.
8 I,
- Ey actions in reviewing precedures typically were 9
a result of following up an event at a plant; and I would 10 look at the procedures which were being used or the proposed 3) revision to that procedure to correct the problem 'hich had 1
12 13, been identifie0..
0-Do.you ever get inyolvedin, reviewing the Metropolitan ja Edison's emergency plan?
15 A
N, did not.
16 Q
Do you happen to recall the names of anybody up j7 there that did get invcived in such a review?
18
.A If you mean literally the emergency plan, that j9 is ancther branch.
If you are talking about emergency 20 response procedures, for example, having to do with e
21 pressurizer level and stuff, that's another thing.
22 S
BY MR HEBDON:
23
- 24 Q
I think he's asking both at the same time.
AceJederal Reporters. Inc.
A The emergency plan is looked at by the emergency 25
.jrb74 74 I
planning officer.
2 O
Do you recall who is in charge of the group that 3
would review the procedures, plant procedures, emergency 4
procedures?
5 A
The section chief.
6 0
. There is a section that's responsible for procedures?
7 A
Yes, and I do not know -- they've been reorganized
-+.
8 subsequently; but it was a section.
9 Q
Okay, I can find out.
10 A
It would vary with time.
Ebe "cCabe had it fer a II while and others.
They were procedures, quality assurance, 12 I requalification training.
whenf.cureviewanincident, you see an incident 13 0
14 that occurs at a plant and you perform a review, do you l
15' review the incident as it occurred; or do you attempt to 16 extrapolate it to a worst-case condition and see what could 17 have occurred?
18 A
That's a very general question.
-19 I think I tend to extrapolate, but not vildly, inthat 20 one can hypothesize almost anything leading to something 21 cataclismic, 22 0
Would you go-to the extent of saying if that incident 23 occurred at 10 percent of power, I wonder what would have 24 happened if it had happened at 100 percent power?
Ace Fedoroi Reporters, Irw:.
25 A
If it becomes obvious that it's a sensitive parameter c_
V 75
-j rb7 5 -
or something; dependent power level or core history or something; 1
even if y u read that circular I wrote, when I did a lot of 2
the research for the things I was concerned with in operator 3
+1 4
jijerror, _it became obvious to me that an overwhelming number of these things, had they occurred in uincidence with scmethin6-5 could have been serious.
l else, 6
II And vou tend to keep that in the back of vour 7,
mind all the time.
l l
But in terms ef, you knov, running a sensitivity 9
l l
analysis to 10, 51 different variables, no; you typically 10 don ' c do that.
jj I
You know, certain things, for example, we had a 12 I
circular on high start-up rates on SWP.s, short-period scrams; s
and it was clear that those events were strongly dependent n the xenon in the core, temperaturs at the time of the 15 16 event, things like that.
So that you do look at those events or you even 37 i
18 1 get an analysis done by somebody else if it is that sensitive.
_j9 0
If you were to recognize a problem as a result of 20 One of these types of analyses would that fall into the cctegory of inflammatcry terms that you felt ycu ought to 21
. avoid?
22 For example, would you have considered it inappropria te 23 24 to use a-statement in a report to the effect that if this
' Ace-Federd Reporters, Inc.
25 event had occurred at 100 percent power, significant damage I
!G
- jrb76 76 could have resulted?
_j A
I think we avoid putting things like that in those 2
3 l inspection reports.
I think we have been schooled, trained, l ~
to keep judgement out of it.
' conditiened, whatever, 4
5' Now, it's not exactly _ judgment, but it deer no particularly relate to the event.
6 7
Now, that might, if that were apparent to me, be justification, you know, to request something else outside
'A 8
94 an inspection report.
That's the purpose of the inspection l!
10 report, to present the. facts of what did occur, not to serve jj as an SER or a probabilistic analysis.
It is_to document?
here are the conditions, here's 12 l
13 ll what has occurred; here 's what the licensee has done as a
~
i ja result of this.
That is not the form, it is not a matter that it is 15 16 inflammatory, it is just not the appropriate place.
37 Q
But you would feel it was appropriate to write 18 such an incident or such a concern in a memo to someone saying l
39 this needs more study.
- g C
Prior to March 29, 1979, prior to the accident at 21 TMI, what knowledge did you have concerning an incident 1
that occurred-at Davis-Besse September 24, 1977?
22 A
Very little if any.
I can't recall any direct 23
-24 knowledge.
us.d.rai a. news i,c 25 At this point it's becoming very confused as there's
i=
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~jrb77 j
so_much' attention to it subsequently.
~
2 You know, I think I'd be hard-pressed to say 3
whether' Davis-Besse was an operating plant or not; it's a
~
4' different region.
S 'l And since going to Region-5 I don't have any 6
responsibility for B&W plants and particularly gensitive 7
issues on B&W plants. I think I was hardly aware at all.
8 Q
Ranco Seco is a B&W plant?
A It's not in my section; the section chief has it 9
10 and may be more aware than I.
11 I am just saying I have no real reason to be g
12 sensitive to B&W,
,13 The incident.$ occurred at Davis-Besse, cf course, was Q
14 while you were still in Region-1, and while you still had a 15 B&W plant;-dtas it r,urprise you particularly knowing now what r
16 you knew about the incident, does it surprise you that you did not know about it before the TMI accident?
17 18 A
No, not at all.
19 There are just so many things which happen.
- That, 20 again, is a point that I made about saying to the licensing 21 i manager, look at the second line of that thing.
22 If somebody starts waving a red flag, my attention 23 is very; rapidly drawn to it.
But unless for some reason-24 I.am particularly sensitive to it, I have this innate belief Ace-Federal Reporten. Inc.
25 in the system that if it's really significant somebody
9: -
[j rb78_
78
~1 else in a parallel' position as mine vi11' recognize and, 2
you knou, do_the' appropriate thing.
.3
'g' well, as a result of that incident at Davis-Besse 4
the ' inspectors raised af concern because of.the f act the
~5 operator secured the high pressure injection pumps and had 6
added to the emergency procedure a note prohibiting the 7h operator rom securing'the high pressure injection pumps, 8l and cautioning him to look to_see if possibly a relief valve h
1 90 was stuck open.
'!!It 10 l
That-precaution is nct in the emergency procedure
'll ' at TMI.
12 Does it surprise you that you are not aware that 13.. that prec2;ation was requested by the inspectc;r, and in fact, 14 h; add'ed to the emerc.ene.v u. rocedure at Davi's-Besse?
I 15 A
It does not surprise me.
I wasn't aware of it, it 16 doesn't' surprise me at all.
It wasn't in the TMI procedure.
17 BY MR. PARLER:
?
18 ll
.O How abcut it surprises ne-dr.at you were not aware of 19 that' situation by semeene in the organication?
20
'A No, it doesn't surprise me at all.
I would 1!1-characterize that as a letail that typically would not 22 surface up the organization, across, and back down.
.w 23 Of equal concern to me is extremely broad' variation 24 in' quality and depth ef, procedures from one facility to Ace-Federal Reporters, Inc.
25 another.
There is very little available other than i
a a
g _e 7jrb79?
-79
_j jawboning by,theiinspector;to bring about equally good lproce'dures from one facility'to another.
~
~
2 l.
3 Therelis: no'-strong mechanism,.if you will, like I-q ((always try; when 'IL find a. good procedure at one plant, I try
. lf a te :let ancther plant hnew ascut it.-
3 And again it's on relat9.ely few occasior.s I~r. ave 6
i.
7;l done.that,'
i l
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g 3 Again, getting-back to an interesting mission at-9]lI&EiIEE's job is-not~ to-act as consultant.
Okay?
You i.
s metimes feel you are even stepping-outside what you are
-10 11 d, supposed to do_ when 'you say, why don't you check witn, you know,
- i. that plant down there?
They've done a good job c-developing 12
- - 13 a pr cedure for,this.
l 14 [
That.is not really our. mission.
I have done it-n ceasion, you know, for-a specific reason;.and I do have L
~15 c.
i 16 e neerns that one plant has extremely good procedures and another' plant, y ou know, has: procedures that are, if you will, 37 L
18 that meet our-requirements, but aren't.anywhere near as good
),
as, you know.another similar pl' ant.
L' 20-Q - How ' do you draw the line?
Or can you-draw the l
l3 -
'21
.line between-not being a consultant and-en the other hand L
being.. vigilant-to assu're that the word is passed about somethinc
_22 I
- o. -
23
~thatfis-very important for them'to understand from the point v.
24 f; safe operation, especially something that is very important l AceJederol Rom-Inc. --:for.tha.t purpose--that-is based on fairly 1recent operating 25 N.:
-l
~
80-Jjrb80' 1
experience?-
2 A
Well, I am not l sure that I would have re;ognized.
'31 in advance the safety significance of the cautionary note
-}
~
d you mentioned of the high~ pressure injection pumps and to
.I 5t suspect. a PORV may be stuck open; so even had I at one plant i
6 seen that.and.gone to the.next plant and seen it -- and I
'7
'might say, if you want to avoid the next Three-Mile Island w
8 you better-add this precaution, this note.
9l My hindsight is much better than my foresight.
e C
10 t
0 To what do you attribute this inconsistency in t
i 11 j.the quality of the procedures?
12 A
Different organizations, the different capability of 13. the organizations, the size of the staff, the experience of 14 the staff, if you.will, the evolutionary nature of the 15 process, the newer plants, they will hire 500 procedure 16 writers from the outside to generate 200, 300 volumes worth 17 of procedures.
18 The older' plants the procedures basically evolve i
19 when problems are identified, the correctedprocedures were 20
.added as.a result of events.
_e
.21 In some plants, a single utility or a utility that
.22
- only has one nuclear power plant tends to do things differently
~
23
- than the utility that has.six or eight plants or belongs 24 'to an; organization like the' Yankee organization where a
' Ace-Federal Reporters. inc.
25-service company is providing support to all of uhe plants in
81 Ljrb81
'I the organization.
2
.And again, it may be that one plant that had bad 3
6perating procedures by my definition -- and not to say that 4
they.are not acceptable may have' good health physics procedures
'S and good cher
- stry and HP procedures.
6 And again, the idea of what good it may be that 7
an extremely good procedure might not have that one cautionary a
8 note in there, which would be an extremely serious flaw
,I 9 !perhaps, but it might be significantly better than a three-step i
n 10t' procedure in another plant which had that note in it.
I i
11 So I don't really have an answer to your question.
12 BY MR. PARLER:
13 0
On the basis of your experience are there any I
~ 14 communications channels informal or formal that typically 15 exist.between a vendor and the regional inspectors?
16 A
There is practically zero interaction between 17 the NSSS, the AE and the operational inspector.
I am not sure 18 l during the construction phase at all what takes place; but 19 I don't think I can ever recall talking to anybody in GE, 20 Westinghcuse er B&W.
21 BY MR. HEBDON:
22 Q.
How would you rate the quality of the procedures 23 at TMI ccmpared to the other utilities, the other plants you 24 l'are familiar with?
Ace Federal Reoorters. Inc.
25 A
I've never looked at them; I really don't know.
r.
ajr,b,821.
82-(
~
'l I've never looked a't them at Unit 2.
s L2 lI:did-inspect at Unit 1.
I was there for the initial 3, criticality of Unit 1.
l 4
I remember-having a fight with the station i.
l S j' superintendent at Unit i relative to valve line-up and valve i
6j.line-upchecks; and there was a reluctance on the part of the k superintendent to form a valve line-up prior to criticality 7
a 8I at. Unit 1.
l 9
As a result I did not feel I had stronc regulatcry
,I 10 1,,basis for doinc. an.vthine..
I 11 I went Out and ccmpared some valves o some valve
-12 line-ups, found valves in apparently the wrony position; l'
13 i.' brought this back to the attentio{. of the superintendent:
14 a va'ive line-up check was then performed by the licensee 15 which identified I think somewhere like 20 or 30 valves that 16 were in the wrong position.
17 And I do recall that event in great detail.
18 A)
I felt frustrated there did not appear to be 19 regulatory recuirements to compell the licensce to perform 20
.the valve line-ups'on the safety systems pric: to taking 1
21 the plant; critical for the first time;-and that I felt relieved 22 I did think of some way, you know, of getting something o-23 done.
24 It resulted I believe in a noncompliance with Ace Fedecol Reporte s. lac.
.25 inspection report for failing to follow procedures, and again, 1
I I
I 83
$rb83 1
I was an extremely new inspector at the time.
And maybe I 2
know of a better mechanism'now, that there are ways in the 3
QA program that you would require qualifications tests.
4
-But valve checks as this a:
act in the requirements l" as I'understandithem now.
5 6
So in terms of your question about TMI procedures, 7
they do not have a procedure to do that, and I feel somehow a.
8 it's related to the TMI-2 event.
9 O
Do ycu know of any other precursor events that 10 i are relevant to the accident at TMI?
l 11,l A
F.undreds in terms of things like valves being 12 left closed while on surviellance test; there are probabis; 13
' hundreds. relative to relief valves failing open, particularly I
14 l in boiling water reactors.
15 In terms of things like the anomalous levelaof 16 indications, I am not aware of any.
l Q
Do you have any additional'information that might 17 18 be relative to our inquiry of the events surrounding Three Mile 19 Island?
20 A
"o, I don't.
1 21 Q
Do you have anything else to add, any comments?
22 A
I'do not.
6 23 BY MR. PARLER 1
24 O
Dan, I understand you were at Region-1 for most of Ac.-F.d.ral n orem, Inc.
25 the period TMI-1 was in operation; is that correct?
"j rb8 4 -
84 1
A Yes, I 'was there the whole time.
I was there for 2
the. initial criticality.
3 Q
I. realize this is a very general question:
Would you 4
describe the general operating experience of TMI-l as being 5) good?
6 A
Yes.
7 0
You were.also at Region-1 during some of the a
8 operation of TMI-2?
9 A
Under prelicensing through initial criticality, and 10 severa honths after that.
11 Q
Would you consider the coerating history of TMI-2 12 from February 8,
'78, or whenever initial criticalty was i
1 13 achieved, thrcugh December 30, 1979 as being good -- or how 14 would you describe that operating history?
15 A
It seemed to me daat things kept happening there.
16 I.couldn't understand at first why they were happening, until 17 I realized how different Units 2 and 1 were.
18 One of the immediate problems we were faced with 19 was the secondary steam safety valve problem which I believe 20 t kept Unit 2 down for four months.
I was involved-right in
~ 21 the beginning directly with that.
22 I think that was one of the things that causec one o
23 of the subsequent blowdowns, was the excess cooldown rate 24 fron the stuck-open ' safety valve.
Ace-Federal Reporten. Inc.
25 And, you know, I couldn't understand, how come i
i l
l LL
m
_85 jrb85; 1
they are havir.g.this: problem? :Then I discovered it's a 2 l different1 piping arrangement, different relief valves, the 3
bird screens are blowing out; then I discovered,_you know, 4 Thcw different Unit 2-and Unit 1 were.
.l.
Q
.Before March 28, '73 and during this period, I asked
'5 '{ -
I
.6 you a. question about -- that is Tebruary to December 1978, o
7 were you aware of'any efforts on the part of the utility to:
I -
J 8
-rush the plant into operation, so that they could get the 9lj~ plant into_ccamercial operation by the end of 1978?
. iO Il -
A I think the term " rush" is very subjective.
I
'I think I've never seen a nuclear power plant that 11 12 is not anxious to get ready for licensing critical operations.
~
13 My feelingEis that nchod'y is interested in dragging that out I
14 any longer than necessary; that people tend to be very
~
15 responsive during this period of time, you know, looking at 16 it perhaps from a narrow point of view, it is easinr to get 17 the licensee to commit right prior to licensing to things 1
18 i that nav not.have a strong regulatory basis.
- 19,
You want something done and they tend to be more 20 cc= pliant with the idea _of'being, let's get it over with.
I 21 'I -don't know how I uculd gage this, you know, fear of people
.i 22 rushed or taking short-cuts; I personally believe that there i
23 are...o'short-cuts taken.
24 BY MR._L2BDON:
AceFede.at Reporters,' lac.
25
-Q.
Have you:anything else to say?
4
.m..
m
.-.-y,
~ __
) jrb86': -
86-
-1
?A
-No.
2 MR. HEBDON:
Thank you ',ery much.
That concludes 3'
the: intervies.
-i 4
-(Whereupon, at 3:14.p.m.,. the interview was B
5 concluded;)-
6 7
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'8 9[
10 11-12 13:
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14 15
-16 17 18 19 20
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21 22
'a 23 24 Ae Federal Reporters, leic.
25 E
A