ML20002C888
| ML20002C888 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/10/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20002C886 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8101120288 | |
| Download: ML20002C888 (67) | |
Text
g 4
"J NUCLEAR REGULATORY COMMISSION O
r f (
In the Mattar of:
l l
DISCUSSION OF INDIAN POINT ENFORCE!ENT ACTION CLOSED -- EXEMPTION 7
(
DATE: December 10, 1980 PAG'S: 1 thru 77 E
AT:
Washington, D. C.
1 i
l l
i l
l l'
.unensox'- (azmmsa i
L 0
400 Virgisia Ave., S.W. Wasningt=n, D. C. 20024
}
b i(
Talaphene: (202) 554-2345 l
9 t
8101200 sq
1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
PISCUSSION OF INDIAN POINT
'(
ENFORCEMENT ACTION 4
CLOSED -- EXEMPTION 7 5
6 Nuclear Regulatory Commission 1717 H Street, N.W.
l, 7
Washington, D.
C.
Wednesday, December 10, 1980 8
The meeting came to order, pursuant to notice, at 9 3:00 p.m.,
where were presents 10 NRC COMMISSIONERS PRESENT:
11 JOHN F. AHEARNE, CHAIRMAN VICTOR GILINSKY 12 JOSEPH HENDRIE PETER BRADFORD 13 NUCLEAR RESULATORY COMMISSION ST AFF PRESENT s k
14 MR. EICKWIT, COUNSEL 15 J.
URRAY T.
MARTIN 16 V.
STELLO J.
SNIEZEK 17 W.
DIECKS E.
HANRAHAN 18 19 20 21 22 23 24 k
25
((
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 664-2345
2 1
iEEE11EIEEE 2
CHA!EhAN AHEARNE:
Today we vill have the
,e 3 discussion of the Indian Fcint enforcement actica, and I 4 would like to close the meeting under imposition of civil 5 penalty exemption All in favor to vote to close say aye.
6 (A chorus of ayes.)
7 CHAIEMAN AHEARNE:
The meeting is closed.
Is 8 there someone from the secretary to verify it is a closed 9 meeting?
- aggg, 10 ME. 54eT4 Thare's only NRC staff here.
N 11 CHAIRMAN AHEAENE:
Thank you.
Go ahead.
12 ME. STELLO:
What we are going to do this 13 af ternoon is to describe a proposed enforcement action and 14 before we get into the enforcement activities themselves 15 since the investigation report I think the Commission ought 16 to have a copy.
17 Our intent vill te to introduce that with our 18 enforcerent action.
We are going to describe and highlight 19 Pretty much the results of the investiga tion tha t followed 20 the Cctober 17 incident and then get into the enforcement 21 ac tion.
22 There is one point that I do vant to make th a t I 23 think is important because we use the proposed enforcement 24 policy on an interim basis.
There was one area that we vill
,(
25 highlight in particular in which a question of Coccission
~
ALDERSON REPORTING CoWPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345
3 1 approval, at least, is raised.
It was my intent in tne 2 enforcement policy, as ry best recollection also the 3 Commission's intent, that when we exceeded certain criteria, 4 enforcement nctions, before we take those actions, we vould Y f#$I 5 come down and tell the Commission what we were doing hma j
f the Commission guidance, if there is anything 6 trying te 7 further that we might do.
8 I did not view it then, and do not view it now, in 9 the context of the for:a1 Commission approval, but following 10 this general guidance that vc had developed in the policy 11 paper.
I make this point because it is one of the things we 12 vant to weigh very carefully in finalizing it and I want to 13 bring it to your attention -- the issue of Commission 14 approval -- as to what that is really intended to mean.
I 15 think it is intended as to what I described.
16 CHAIE!AN AHEARNE:
Is that an issue here this 17 afternoon?
18 MP. STELLO:
It will be an issue here this 19 af ternoon.
20 COMMISSIDEEE BRADFORD:
Is that a particular item l
21 in the package, or is it just the package as a whole?
22 MP. STELLO:
No, it vill be covered directly in 23 the briefing.
It specifically relates to an iter where if 24 you have a severity level 3 category for which the total
(
25 fine in a severity level 3 exceeds $100,000, then the policy l
ALDERSoN REPORDNG CoWPANY. INC, 400 VIRCINIA AVE, S.W, WASHINGTON. D.C. 20024 (232) 554 2345 i
l
u 1 statement we issued said if that is the case then we would 2 come down here and tell the Commission about that.
And we 3 will highlight that specific issue when we get here.
.{
4 COMMISSIONER GILINSKY:
You are telling us about pa sAMAA f WoI. / -
8A 5 the whole thing, aren 't you?
s
'I L Q spg#,% : -Q but[epart of the enforcement 6
MR. STELL0s
- Yes, i
7 package, when we get to it.
The specific area is there is a l
8 severity level 3,
in my judgment, which the civil penalty 9 that I think is appropriate exceeds $100,000.
Per the 10 announced policy statement there is a statement in it that 11 says when we get to that kind of a situation we come to the 12 Commission.
I would not tak e that action without coming to 13 the Commission.
Thet is wha t the policy statement says, and 14 we're going to run into one of those for the first time in enf orcemetts. n o k hac age 6.. d' 15 this case as one part of the p
v & OW M.EISSIONER GILINSK : ^.st
"
- d; - - [
COM is up t o y ~2 t:
16 6 **e Me.
It is up to us to prove it?
17g t i.
18 MR. STELLO:
I'm here to tell you this is what I 19 propose as an enforcement action.
Of course, if the 1
20 Commission gives me further guidance or suggests that I do 21 something difftrent, then obviously I will co in thet 22 direction.
23 I have what I believe to be the way I think it l,
24 ought to go.
!(
COMMISSIONER GILINSKY Okay.
25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASH'NGToN, D.C. 20024 (202) 554 2345
5 XE. STELLO:
With that, Tim, wh y d on ' t you give a 1
2 summary of the results of the investigation, and then we'll y
3 go directly to Jim and he will talk about what the proposed 4 enf orcement action package lookc like.
5 ME. MARTIN:
Gentlemen, my name is Tim Martin.
I 6 am Section Chief in Eegion 1,
and I was the team leader for 7 the investigation.
I would like to very quickly set the 8 stage for the event so you can understand both the sequence 9 of the events and the enforcement items.
10 The first item here is the fan cooler units.
It 11 is brought by service water from the Hudson River.
The 12 piping to the fan cooler units is made up of carbon steel The headers on the box are 13 lined with concrete. kw f &%-
14 copper-nicke matching into little tubes, which are made of A
15 copper-nickel, and between the copper-nickel and the carbon 16 steel you can have a corrosion action.
It will result in a 17 tax on the wells located in the surf ace well system which 18 will cause problems.
19 In addition, you have a cooler on the motor 20 system.
It has flexible couplings coming from a small 21 diameter carbon steel pipe coming down to the motor cooler 22 and flexible heles over to the motor cooler itself.
There 23 is a citation there where they failed to control the 24 materials.
25 There are five fan cooling units in the vapor ALDERSoN REPORTING COMPANY,INC, 400 VIPGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
6 1 containment.
- he air flow -- there arc dew point devices 2 located outside the fan cooler unit which we will have some 3 comments about.
4 There is also a condensate collection system 5 located under the cooling core which feeds a weir, which is 6 used to measure the rate of condensation on these coils.
Lal21 7 Obviously, any leakag'e dwe the fan cooler will also go into 4
8 these collection systems and be indicated on the weir.
9 As we noted, the weir is fastened to the floor in 10 the containment.
It is normal to have water on this floor.
11 Th e dew point devices --
12 CHAIRMAN AHEARNE:
It is normal to have some 13 w a t e r, but not the amount that we are going to find.
l' 14 (Lauchter.)
15 R.
EARTIN:
Secondly, the dew points device is 70 16 degrees.
Since we were running at the time of the event, 17 all of the things reading at the bottom we cannot see a l
18 ch ange in the humidity in the containment.
19 1971-73, the Licensee experienced a number of 20 failures in the motor coolers.
These are made by 21 Westinghouse Sturdevant Division.
The Licensee went to 22 Westinghouse to get them to pay for the replacement of these 23 motor coolers.
Westinghouse charged that the Licensee had f.
24 operated these coolers with excessive flow rates, causing
\\ (
l 25 erosion.
l l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINtA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554-2345
7 1
COMMISSIONER BEADFORLs 1971 to '737 2
ME. MARTIN:
'71 to
'73.
September of '71 they
<g 3 vent into service.
By January of '73 they replaced them.
4 So these cotor coolers in '73 were replaced.
As a result of S the charge by Westinghouse the Licensee did his one and only 6 failure analysis.
They actually removed the motor coolers, 7 did a destructive examination, found, in his conclusion, 8 that it was f abrication and a design problem, knowing that 9 the other fan cooler units -- there are actually ten banks 10 here -- were made by the same division using the rame 11 specs.
They just assumed that they were going to have leaks 12 on this system and that they were probably going to be the 13 same cause as the ea rlier f ailures.
14 The failures that they experienced were in the 15 headers in this area in the stub tubes to header, and the 16 stub tubes to the tubes, and the actual leaks in the tubes 17 th emselves.
They also had failures on the carbon steel line 18 pipe.
They did repairs -- what they called " temporary 19 repairs" or " temporary fixes".
The put on clamps around the 20 outside.
They used epoxy to cover up the leaks.
21 They did not regard these as modifications because 22 they were " temporary repairs".
23 CHAIRMAN AHEARNE:
But continuous repairs.
That 24 is, th ey continued to make these.
25 MR. MARTIN:
That is correct, sir.
And we will ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
B 1 point that out in a second.
2 In 1979 there were a number of challenger to the 3 repair technique.
In early 1979 they rtarted an 4 invectication of the technique.
The original results of 5 thst evaluation said these are not satisfactory for 6 long-term fixes.
They have the probability of failure in a 7 loss of cooling accident because of the. temperature.
As a 8 result of that, Licensee did some additional evaluation.
9 They never did an evaluation which encompasses all the range 10 of parameters which would be expected upon a loss of cooling 11 accident.
12 In fact, even today they have not conpleted an 13 evaluation of the causes of those leaks, even though the 14 leaks were, in come cases, different from the leaks M
15 experienced on the 1: ::= coolers.
I can characterize the I
cooling leaks as brazing failures in the stub tube 16 17 area, and on the stub tube to header and the stub tube to 18 tubes l
19 When they sta rted experiencing failures on the 20 failures themselves and when they did an examination -- a l
21 visual examination -- last summer of this header using a l
l
=
l 22 boroscope and found additional corrosion mechanisms that 23 were not seen in the original motor coolers, they did not 24 say stop, we have got some other mechanism.
They just 25 continued to use the repair techniques they had ini the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
p 1 past.
It was a +ece t e chniq u e, not an identification cost.
2 May I have the next slide?
3 4
This is a gram, or a dictogram of the various 5 leaks that were experienced on the fan cooler units.
This 6 was a maintenance work request.
In any maintenance work 7 request a number of leaks may be repaired.
This would 8 encompass the repairs on the carbon steel pipe on the stub 9 tubes -- on the tubes themselves, but all of them are 10 leakage-associa ted and point to a general increase in 11 leakage with time, or the general increase in the to M 12 requirement '"- tr repairs to maintain those systems h
13 C,
1*~
l'.
('
14 It should be pointed out that leakage on these 15 things should only be detected by noting an increased input 16 from containment to the waste system, since they get a vaste 17 holdup tank in leakage calculation.
So every time you cet a 18 leak you have to count on that water being delivered to the 19 wa ste holdup tank.
20 That requires that certain pumps be operable.
If 21 they are not operable, your system has failed and you can 22 not identify leaks unless you have a progrem of routine 23 inspections of the containment, which they did not have.
24 Next drawing, please.
25 COMMISSIONER BRADFORD:
k' hen you talk about the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
10 1 analyses that were done, I take it that they didn't analyze 2 what might happen to the water.
That is, the analyses were 3 in terms of the fan coolers themselves and they assumec the 4 pumps worked and the water was taken out of the building.
5 MR. MARTIN.
Their calculations to determine, had 6 they had a leak at those purps delivering the water to the 7 holdup tank, it was never assumed those pumps would fail.
8 They are not safety-related purps.
They are standard sump 9 pumps you would use in your own basement.
10 All right.
This is a cross-section of the vapor 11 containment.
There were three floodin; events at this vapor 12 containment before we had our event of October 17.
The 13 first one was due to temporary piping that was used for the 14 fan coolers, which are located in here, during the A, ads-15 pre-operation containment leak test.
The piping failed to 4
16 dump water on the floor.
The water collected and actually 17 covered the lower section of the reactor vessel.
18 At that time there was no fuel on the vessel.
Te j
19 vessel wa s cold, but this was surf ace water.
The water was 20 required to be cleaned up.
And this was prior to operating 21 license.
a 22 Subsequently, there was a feedvater line thee-hed 23 jt break.
This also put water into the vapor containment and 24 also into the pit.
It should be pointed out that af ter the 25 first flooding event they recognized the need to have sump ALDERSON REPORTING COMPANY,INC, 400 VIRONA AVE., S.W, WASHINGTON. o.C. 20024 (202) 554 2345
(
11 1 pumps in this location.
It van not part of their design, 2 but they wrote a request to modify the system by adding 3 these sump p u r.p s.
That was written in
'72.
It was not e
4 implemented until, I believe,
'75, though, after another 5 flooding event.
6 COMMISSIONER BRADFORD:
Just out of curiosity, if 7 I remember rightly, they didn't have similar pumps in Unit 3.
8 ER. EARTIN:
I can't answer that.
I can't answer g that, sir.
There are pumps in that sump in Unit 3, but I do 10 not know if they are similar.
11 COM ISSIONEP ERADFORD:
Oh, I'm sorry.
I must 12 have misunderstood an earlier briefing and I thought there 13 were no pumps in that.
14 ER. EARTINs To my understanding there are pumps 15 there, but I don't know if they are the same.
16 COEMISSIONER BRADFORD:
Okay.
17 MR. KARTIN:
So in '75 there were pumps installed, l
18 but before that we had a second flooding event.
This is l
l 19 feedwater.
The feedwater line ruptured, put water into the 20 pit.
It is reported that it never reached the reactor 21 vessel. It covered about six feet down here.
22 Subsequently, before the third break, we did get 23 the sump pumps installed, but the modification takes l
24 electrical power f rom Wee down stream of the fuses of one of l
25 these sump pumps.
That is going to be critical, because ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W. WASHINGTON. D.C. 20024 (202) 564 2345
92 1 when these pumpf fail they are going tC take one of these 2 sum; pur.ps with them.
3 The third problem vac a reactor coo; pump seal 4 ruptura, which also dumped water down here.
Nete inat the 5 last two events, though, were het water.
They were 6 demineralized water, so the temperature compatibility is 7 much better.
And, obviously, the chemical compatibility is 8 better.
9 CO !!SSIONEE EEADFORD:
Then the water didn't 10 reach the reactor vessel?
11 ME. MARTINS If you look at the calcula tions, it 12 came very closo.
Eecause of the margin of error, we cannot 13 prove one way or the other.
'/
14 CHAIEEAN AEEAENE:
k' hen was the last one?
15 MF. MAETINs The last one was in
'75.
Jim, do you 16 remember th e date?
It was '75 or '76 -- somewhere in that 17 rang e.
18 Okay, some other things I would like to point out 19 here.
There are two sump pumps in the pit.
They discharge 20 into the main sump.
They do not discharge directly out, so 21 if the eater rises on this floor and starts to spill out on 22 th e lef t, these pumps are ineffective.
If they are AE M 23 basically on +'=
""-fir These pumps a're located on the 4
24 higher elevation.
There are five of ther. They empty out to s '
25 this drain system, which then dumps onto the floor.
ALDER $oN REPORTING CoWPANY,INC.
400 VIRGINIA AVE, S.W WASHINGTON D.C. 20024 (202) 554-2345
13 It is common to have water on the floor -- not 1
2 that much, but some water on the floor.
Then the surfacepe5 ^'
3 lines are to the h,catin and fan units.
Finally, we have n
n-a 4 two pumps located h
""7, g
5 May we have the next drawing, please?
6 This is a cross-section of the vapor containment 7 sump.
You may have seen this drawing earlier, but it is 8 corrected.
This has got some new survey information on it.
9 The point that I would like to make here is that there are 10 two pumps.
They are controlled by their own floats.
Each 11 floa t's a bout ba sketball size.
The basketball is captured 12 on a rod.
It can move on the rod.
The rod NIiittle 13 collars on it.
Once it rises and picks up a collar, then 14 there's actually a little switch that starts it.
15 Originally, these set points were down in this 16 rang e.
The start was by here, and the stop wa s in th is 17 area, between 29 inches and 33 inches. It would mean that 18 back in 1973, when the system description was written, it 19 would be abnormal to have a 45-inch light, and further 20 abno rmal to have a 51-inch light.
21 At the time of the event, the start point was 22 generally somewhere below 45, but above 7 -- excuse me, the 23 stop point. But the start point was above 51.
The pumps' 24 failure to start above this point would not be indicated s
25 until you actually overflowed the sump.
It should be ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
14 1 pointed that most operators thought 91-inch light 2 corresponded to two inches above the lip of the sump.
In 3 fact, it was about five inches above the sump.
And so you 4 actually get a flooding condition on top of the sump.
- And, 5 in fact, before you go over to the left, you should actually 6 pick up the 91-inch light, if the stocks are in the same 7 position as they were at the time of the event.
8 Purportedly, this ligh t never came on.
So we 9 really do not know the water went over this curve.
The to Licensee is trying to determine if there are other sneak 11 paths.
One of them may be the siphon path of the vapor pit 12 pumps and that, if their check valve stuck open and they had 13 time to pump to keep water in the line and then they shut 14 down or failed, then it could siphon back.
15 The Licensee, on Sunday, two days into the vent, 16 drilled a hole in the pipe in about this area, which should 17 have broken any siphon.
He reports he saw nothinc as a 18 result of that, so we don't know.
We don't know how the 19 water got down there.
i l
20 These indicators de not correspond with real l
l 21 conditions.
The one-inch light is really about 13 inches l
22 of f the floor.
The operators don 't know that.
The 23 seven-inch light was about 17-1/2 inches, et cetera, et 24 cetera.
25 May we have the next drawing, please?
ALDERSoN REPORTING COMPANY,INC, 400 VIRGtNIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
15 1
Okay, we are going to go into the event now.
I 2 think we have pretty well discussed the background you need 3 to understand this.
Water f rom the f an cooling units, I 4 believe this is number 22, the surface e.ter, d ra ined onto S the floor.
One of these pumps was failed because it had 6 blown fuses, probably becauce when the pump down here failed 7 it took that pump with it.
The second pump will fail A rb /
8 beca use its float gets
- 75 t.
A 9
Now, the sequence of events, please'.
10 On 10/1 a containment entry was made to repair fan 11 cooler number 25.
At this time we basically said, back to 12 May of
'80, the 51 light has never been recorded on the 13 every-four-nour log.
There have been a few 7-inch lights 14 reported, but normally it is 45.
They go in and --
15 CHAIRMAN AHEARNE:
When the 45 goes on, does the 7 16 go of f ?
No, sir.
It stays on.
There are 18 individual fil- - t : mi each one.
19 CHAIRMAN AHEARNE:
If the 45 is on are they 20 recording the seven?
21 MR. MAPTIN:
They only record the highest one.
So 22 at that time they repaired cooler unit nu,mber 25. The reason W
23 they did that was because the holdup tank leakage A
24 calculation showed excessive leakage.
25 They searched through the primary building and, 4
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
16 1 having f ound no leaks there, they then shut down the 2 discharge valves from the vapor containment, noted a marked 3 decrease in the vaste holdup tank and leakage, even though 4 the pump may now be pu: ping against the shutoff head incide 5 the container.
Then they would go in, discover what the 6 problem was and then fix it.
7 So they fixed fan cooler number 25.
On the third 8 they go in to fix fan cooler nutber 21.
During that entry, 9 the operator -- actually it was the chief opera tions to engineer, a management position, because union will not make 11 an entry ke power, that j
12 CHAIRMAN AHEARNE:
Union won't make an entry in 13 power because the management has signed a contract with the 14 union saying it won't.
15 ER. EAETIN:
The union says it will net, and that 16 is the contract ultirately signed.
That is correct.
17 CHAIPMAN AHEARNE:
There is a contract.
18 ER. YARTIFs Yes.
19 Now, during this entry he was asked to go over and 20 check the operation of the sump pumps and the operation of 21 the level lights, because this 45 light had been on for some 22 time.
There was some question whether the 51 would ever 23 vork.
So he reportedly diggled the 45 light, jiggled the 51 24 light, end lifted at least one pumps float.
Now up to this 25 time we've only recorded 45-inch lights as the maximum level ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON D.C. 20024 (202) 554-2345
17 1 since Fay.
2 Shortly after his entry, the 51 light is noted.
3 It maybe came on and stayed on after he lifted it, but from 4 then on the 51-inch light stays on, a condition which is not 5 tyeical. And they did not pick it up.
76 6
CH AIR M.'.N A HE A RNE :
But they had pec write it down 7 every four hours.
8 R.
MARTIN:
That is correct.
So after entry 9 reduction der flow out of containment "fhis is really comic j
10 to u s, beca use we were congratulating ourselves on how we 11 had really reduced the leakage problems in the containment.
12 k'e now believe the reason they had such a reduction was 13 beca use it wasn 't pumping out any more.
14 At 10/1h they had an indication of high level on 15 the weir for association with cooler number 22.
Now
& (k'W$
16 remember, w that m on the coils -- condensino on the 4
17 cohls inside the fan cooler unit.
They noted that they had 18 no radia tion detector alarms.
The leakage calculations for 19 the prima ry system showed no abnormalities.
The dew point 20 device had not come off its peg, so it didn't seem to have 21 any problems.
And their calculation of in-leakage to the
~
22 waste holdup tank showed no abnormalitien.
23 So everthing said to them that this was fine.
The 24 fact that we now believe that this was the cold water, it is l
25 not coing to cause a dev point problem.
It is not going to I
l l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345 l
l I
(
18 1 cause a radiation probler. It is not going to affect the 2 reactor coolant leakage calculation.
And, if you lost the 3 pump, it's not going to affect the in-leakage calculation.
4 Basically, they concluded that this system var 5 inoperable and did not r.a k e an entry.
They just chose to 6 let it co off scale and accept it.
Subsequently -- days 7 la t er -- it would come back on scale.
Water is pouring down 8 from the upper level onto the instrument.
It is probable --
the instrunents failed sometime 9 in fact we found out 10 during the 10/03 to 10/17.
We believe it failed some time after 10/14 11 after this event CHA)
EAPNE:
Would you have expected thee --
12 13 to make an entry?
4 14 ER.
ARTIN:
Yes, sir, particularly since the only 15 back up they have f or identif ying leaks is those puxos.
They 16 really should have, I believe, a routine entry procedure.
17 CHAIE AN AHEARNE:
But they didn't.
Do you have a 18 feeling as to why they don'.t have a routine procedure?
1 19 MR. MARTIN:
I; o, sir.
I don't.
Obviously another 20 w a y to do it is to have better lighting level system on the 21 sump.
Put we violated tha t the way the sump lights are 22 currently operatino.
So may we have the next slide?
23 On 10/17 they started to experience problems with 24 one of the power range nuclear instruments.
The STA was not 25 called.
In fact, he only learned about it a couple of hours ALDERSoN REPORTING CoWPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. D.C. 20024 (202) 554-2345 t
19 1 later when he vac making a routine tour of the control 2 room.
There was an erratic indication and the cperators 3 deterrined that the nuclee instrument was inoperable.
So 4 they decided that they had to disable it.
In the process of 5 disabling it, they in te r pr et ed the fact that they had e decided it was inoperable to mean that they didn't have to 7 do the immediate steps.
They could go right into the 6 subsequent action.
9 One of their requirements is it should be below 70 10 percent power before you pull the fuses on the bistables.
11 The fact tha t the vere still at 90/ percent when they pulled
~J d: ' ^*
12 the f uses caused d : ' ' - - i n rd runback.
A fJ 13 Subsequently, beca use the rods were 2h
.m iing i t.
4 14 the manual, the reactor was producing a greater power level, 15 and the turbine was pulling.
Therefore, the temperature on 16 the system started to increase.
They attempted to override ps,/M r/ :-3 17 the runback by removing the load limits out of the way.
In 18 the process of doing that they cranked the load limits in 19 th e wrong direction, which caused the turbine to go further 20 down in power.
21 In that process they set up an ossilation in the 22 steam genera tor which tripped them out on load level the 23 first trip.
5anagement was aware of what was going on.
Th e 24 chief operating engineer and the plant manager had been in 25 constant telephone conversation during this period.
They ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554-2345
20 1 decided to restart.
They th ough t they understood the 2 problem.
The station -- the shift technical adviser didn't 3 see it.
He saw no problem with it.
He was reviewing tech 4 ranuals to try to understand the trip itself.
5 The plant was restarted and during the restart 6 proress they got up about three percent power.
The 7 technicians were still trying to find the problem on their 8 nc.. lear instruments.
They were doing comparison checks 9 between the inoperable channel and another channel.
They 10 did not realire that they could back down the set points of 3
11 the overpowered delta T trip point to about JMI percent trip 12 power.
13 In the process of inserting fake signals into the 14 operable channel they caused another trip.
Again, STA found 15 nothing wrong with their restart, but management felt that 16 they understood what had taken them out.
They decided to 17 start up again.
During the next hour the technicians had 18 decided the probler was in the containment and they did have 19 a spare nuclear instrument.
So they decided it is a good 20 idea to go ahead and shut down and replace them.
The reason 21 to shut down was one, they would have to do daily in-core flex 7" M _
- 1 which would wear out the instrumentation.
22 A
23 They would have to, if they were going to repair the powerj 24 they couldn't use the union people and that is not an ea sy 25 instrument to haul around.
In fact, it was just easier to j
l ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE, S.W. WASHINGTON D.C. 20024 (202) 554-2345
29 1 do in a shut down condition.
2 So they did shut down.
3 THAIRMAN AHEARNE:
They didn't expect the shutdown 4 to be very long, isn't that correct?
5 MR. "ARTIN:
Three hours was maxiumum.
That was 6 their estimate.
7 THAIRMAN AHEARNE:
Your report, I gather, they 8 vere looking into a weekend and they figured why don't we 9 get this done before the weekend?
10 MR. MARTIN:
Rasically the weekend is not a power 11 problem for them.
It is the weekdays that are a problem.
12 They could actually have ridden out the whole weekend and as 13 long as they were back on-line on Monday tha t was no problem.
14 So they shut down, and by 10s30 they were making 15-plans f or entry.
They entered around 12:30.
The team --
16 four people -- went to the upper elevation; th ree went to 17 the lower elevation.
The th ree who went to the lower 18 elevation f ound water on the floor.
The noted that there 19 were leaks -cocing out of the fan cooler units.
l 20 They left the containment because they were not 21 dressed for wading in water. The reports were made to 22 various people in the control room and to the plant manager 23 in the chief operations engineer, who decided to make an j
24 entry with boots on and go in and replace this instrument 25 and made a second entry around 2:00.
I l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) E54 2346
22 t
The people who went into the refueling cavity, 2 where you have to go to put the nuclear instrument into the 3 hole, found steam coming out of the assembly.
They already 4 knew there was water on the ficor.
They drew no connection 5 between the water on the floor and steam coming out of the 6 assembly.
In fact, tha t piece of inf err.ation gets lost.
7 l
8 9
10 11 12 13 14 15
'6 17 18 19 20 21 22 23 24
(
25 ALDERSON REPoRTNG COMPANY,INC.
400 VIRGMIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2346
..j
23 1
2
"~.
The people who vent down to the lower 3 level found the water got deeper.
They characterized it "up 4 to their ankles."
Some people say two to four inches, some 5 say six.
But the number that got carried over to plant 6 management was two to four inches.
7 The team exited the containment, and they went to 8a meeting with the plant manager and the chief opera tionc 9 engineer.
During their period of entry, a supervisor in the M
10 operations group made an entry.
He had h alerted to the 11 fact that there was water on the floor.
He went to check to 12 see if the sump pumps were operational.
He found them both 13 shut down.
14 He jiggled the ficat and was able to get it 15 started.
It had cocked.
It cocked twice again during the 16 even t.
The other pump they couldn't get sta rted again, so 17 they went upstairs and replaced fuses.
When he replaced 18 fuses, he was able to get that started.
He went over to the
& w *e down underneath the 19 vapor containment pit pumps d i r*
"*e 20 reac tor.
He saw the light indicator above them and felt at 21 least one of hem wae perating.
$d
?
L' ret he was looking at didn't have any indication 4
22 4
23 what they were.
They really were moisture lights, 24 indicating they had moisture in the connector on top of the
(
25 pump.
There was really no indica tion that t.'e pumps were ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
24 1 running et all at that point.
Eut he didn't know that until 2 later.
3 COM ISSIONEB BEADFORD:
Tell me again, if those 4 pumps had been running, where would they have been 5 diceharging to?
6 ME. MARTIN:
The enes in the pit?
b^
o
[.
7 COMKISSIONER BRADFORD:
The ones in the e
"'+v 8
MR. MARTIN:
Th,ey would have been discharcing to
..a m & J 9theonesinthemainpaporcontainment, but since they were 10 already flowing in the main sump, they would be flowing into w-a-11 the main pit.
So they would be on meee++e, essentially.
4 12 COMMISSIONER BRADFORD:
Why did that design ever 13 make sense?
l(
14 MR. MAPTIN:
I can't answer that, sir.
It was a 15 back fit and not an FSAP item.
It was not ar original 16 design.
17 MS. STELLO:
I recall hearing reasoning indicating 18 th a t when they went into a refueling mode, they put the ring 19 u p around the top of the cavity to generate a pull for epte,thecaviy 20 ref ueling.
They know t ey get,vate leak j
A a 7nwa ww 21 from that source, and hi e +'-"^ ir r-furlid, they et M
' "M M n}f 4 et the sump pumps to 22 that leakage of water, r~"-
A 23 g e t the water back up out of the cavity when you have that 24 leak source.
My understanding is that's one of the reasons s
25 the sump pum ps were needed.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
25 1
COMMISSIONEP ERADFORD:
That certainly makes 2 sense.
I had understood f rom an ea rlier part of the 3 briefing that the pumps were put into a response in which 4 water had flowed into the cavity from outside and that 5 affected some areas that one would have expected the sump 6 pumps to deal with.
But it doesn't sound as if these pumps allgAk+
89b 7 would have been of any use a t 8
MR. MARTIN:
My understanding was the water from 9 the earlier events made thee recognize that it was difficult 10 to get water out of that pit.
And they hypothesized other 11 vays water would get in there, one of them being the way 12 pointed it out.
It would be nice having pumps located in 13 that sunp.
They're obviously not effective if you float 14 over the top of the lip.
15 COMMISSIONER BRADFORD:
Am I right in 16 understanding that they would not also have been effective i
17 in the f ace of the various kinds of earlier events that made 18 them think about the pumps?
q MR. MARTINS That is correct.
Once you dropped 20 the level below the lip, though, you could help them pump it 21 out.
22 COMMISSIONER BRADFORD:
But you could only do that 23 if the sump pumps are working.
24 MR. MARTIN:
They had never really experienced a 25 previous failure of the sump pumps.
The sump pumps are only ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
26 1 rated for about 50 g.p.m.
apiece, so when you have larce 2 flow rates into the containment, you could actually exceed 3 the ability to pump it out.
But once you terminated those 4 sources of water, they would be capable of pumping that 5 portion of the containment dry.
6 COMMISSI0hER BRADFORD:
Eut on the earlier 7 occa sions, when the water got into the cayity, it was more fl an 8 because they overwhelmed the sump pumps sed because the sump
~
4 9 pumps hadn't worked.
10 R.
MARTIN
- There were very quick pressurizations
&=l d}
11 of water systems, and they quickly hd that.
And A
12 that was quickly terminated.
13 Ok a y.
Sub seq uen tl y, we were in a meeting that was b
14 held around 2: 00 o' clock that afternoon.
The director asked 15 the question, "What is the depth of the water on the 16 floor?"
He was told, "Two to four inches."
He reportedly 17 breathed a sigh of relief and said, "That's good, because if 18 it had been up to six inches, it would have flowed over into eM6*.
19 the pit."
So he asked the right question, and fortunately 4
20 he got the answer that turned him off.
21 Subsequently, around 6:00 o' clock that evening, 22 the chief operations enoineer asked t'he operator to just 23 look into the pit and see if there is any water there.
The l
24 individual looked.
He found water within about four feet of k
l 25 the grating.
That would take you up about eight feet on the l
l ALDER $oN REPORTING COMPANY,INC, 400 VIRGlee: A AVE, S.W WASHINGTON, D.C. 20024 (202) 554 2345
27 1 reactor vessel.
2 He reported that information to the chief 3 operations engineer, who didn't draw the connection.
He was 4 of the belief that the reactor vessel var at a much higher 5 elevation.
And so he was told it should be at least four 6 f eet before it gets up to the grating.
7 He felt confident the reactor vessel had not gep C = 2_ asuvf 8 touched, nor had he believed the stainless-steel s,ir.7-had 4
9 been touched.
So after that information got passed on to 10 the plant manager, that is as far as it got.
Durino that 11 same 2400 o' clock meeting 12 CHAIR!AN AHEAJNE:
If it waspassedon,JvJ.itJ <he s
13 t h a t the water hadn't touched or that the water vas g
14 MR. 5ARTIN:
The water was about four feet down 15 below the grating.
16 CHAIRMAN AHEARNE:
So the plant manager also had 17 some sense of this?
18 ER. EARTIN:
He knew
- t. hat, yes, but they made no 19 connection.
It didn't raise enough of a question in their 20 minds to check the drawings.
And va vill see that a couple 21 of times.
22 ER. STELLO:
I think there is confusion.
Was 23 there any discussion at all of water on the stainless-steel 24 tubes to the vessel?
Was it even discussed?
25 MR. MARTIN:
No, sir.
And when we asked them why, ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345
28 1 this was what they expressed to us They never drew a 2 connection between the two.
3 Durine the 2: 00 o ' clock meeting the technical 4 engineering director was directed to make a call to the NRC S resident to inf orm him of the.f act that they had found water 6 on the floor and they had some fan cooler leaks.
So he 7 attempted to call and cet ahold of the resident inspector.
8 He left a message on the line, "Please give re a call."
He 9 gave no indication of what the problem was.
10 The resident inspector was on leave at this 11 point.
He would not return until Monday mornino.
At this 12 time, for a week, they tried to reestablish contact.
They 13 pointed out that the technical inspector at 2:00 o' clock did 7
14 not know about water in the pit.
15 The rest of the event, basically, they pumped the 16 cont ainment in the cavity, trying to dry it out.
They fixed i
17 the f an cooler unit leaks.
They fixed the steam generator i
18 coolant leak.
l 19 The vice president of power generation learned 20 that water was in the pit on Sunday.
He drew a conclusion, l
1 21 since he knew about the steam generator blowdown leak, he l
j 22 assuned the water that we now found in the reactor vessel 23 pit was associated with the steam generator blowdown leak 24 and not with the e rlier fa le a k,48
/ ^'
W Cl
^
! ~
n 25
-~
f3 he apparently didn't ask the question of what l
l I
l l
l ALDER $oN REPORTING CoMDANY,INC, l
400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202) 554 2345
29 1 was subnerged.
He only asked, "Do you n'eed help getting 2 more pumps to pump the water out?"
3 The plans Friday, Saturday, and runday were to 4 return to criticality as soon s possible.
During the whole M&E E"!
were runni+ng pc.., ;;;l checks.
5 period, they 4
6 CHAIEEAN AHEARNE:
I think you made that point in i
l 7 your investigation several times, that they kept on l
i 8 predicting.
They definitely, at least according to your 9 report, did intend to go back up as soon as they could.
10 MP. MARTIN:
Yes.
The orders that were left 11 Sunday night were:
"As soon as all the fan cooler units 12 leaks are fixed and the pit is dry, that you are to start 13 t."
So the wording was passed on to the Sunday-Monday 14 shif t was that is what they were supposed to do.
They got 15 the pit dry.
They got all the fan cooler unitt, fixed, at j
n po_ yp00o' clock And 16 least according to his estimates.
'it up.
17 the next morning the reactorp ve-c
=
j 18 About 7:00 or 7:30 Monday morning the manager of 19 nuclear power generation came in.
He was
'""r4 cad
. the g
20 situ a tion.
He asked did we have brackish water, did we have 1
21 river water on the conduits?
"Yes, I guess we might have."
l 22 He was concerned and decided to shot down and investigate.
23 A'a d by 11:30 they had reestablished contact wi th the 24 resident inspector and informed him of the condition.
Subsequently, he informed the region, and it goes on from 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
30 1 there.
2 May we have the next slide?
3 On Monday 4
COMMISSIONER BRADFORDs Before you leave the 5 chronology, could we try to understand the information 6 f ollowing the business of the vessel having been uncovered?
7 Obviously, some people saw that the vessel had been under 8 water.
9 KR. MARTINS ho, sir, they didn 't.
At least they 10 saw levels, viiph if they knew the correspondence in elevatio &' M A'^u 'd.
n, ccr-c i... L.,.
If we could go back to an earlier 11 A
12 picture which shows this cross-section, four feet down in 13 this vertical hole corresponds to touching the vessel, but 14 you can't see the vessel from this floor.
15 C05MISSIONER BRADFORDa I see.
I see.
l 16 MR. MARTIN:
This is not a normal place to visit.
17 COMMISSIONER BRADFORD:
Especially when it's under 18 w a t e r.
19 (Laughter.)
20 MR. MARTIN:
But during power operations, this is
{
21 a high-radiation area.
And so in fact even this loop area l
&, L_ 0 l
22 is.
So the only times you r-+"-e
>& this area is during a l
23 ref ueling shutdown, and there is not much down there to i
24 see.
There are inanimate objects, with the exception of the
'~
25 sump pumps which is tested with refueling to see if they l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON D.C. 20024 (202) 554 2345
y J b b.d
+
ya W g y J N R~~%
p
~+
4*'^--
1 work.
You eeally have te go through it t^
-._n fo f Y
2u...e=high-radiation area.weeve A
3 CD MISSIONEE BRADFORDs As nearly as you've been 4 able to tell during your investigation, everyone, from the 5 people who first called, told you what the water level was 6 in the chamber, to all the people who were teld about it, up 7 to the guy who came in on Monday morning, all assumed that 8 that 46-foot elevation meded was below the bottom of the 4
9 reactor vessel.
10 ER. MARTIN:
Apparently.
And in fact, the 11 subsequent calculations -- the licensee came in Monday, 12 Tuesday, Wednesday, and the early part of Thursday -- were 13 all showing that if the water did approach the ve ssel, it 14 got rich t here but didn't touch.
The licensee ^::...
- fik 15 substantiap himself, through inventory calculations, that 16 he never really touched the vessel.
17 It was only on Thursday, when operators who 18 installed the submersible pumps in the vertical hole on 19 Friday night returned to the shift -- they had been off for 20 three days -- wondering why they were still shut down.
They 21 were told, "We're trying to establish what level the water 22 reached."
And the guy said, " Hey, we saw it."
There were 23 four eyewitnesses, and they all put it right in this area.
24 At that time, the observa tion was. we discovered 25 the licensee then called the investigation team and told us ALDERSoN REPORTING COMPANY.INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
4 32 1 that of the people he had talked te subsequently, his swipes 2 on the vessel also showed tha t there was river water residue 3 on the outside of the reactor vessel.
And so by Friday 4 morning, he recognized he had a vetted condition on that 5 vessel.
6 COMMISSIDNER BRADFORD:
What is troubline me is 7 this is obviously going to be a question of some importance 8 to know whether the water had touched the vessel or not.
9 And yet, what you are saying, nobody ex plici tly asked that to question.
11 MR4 MARTIN:
Nobody made the connection.
That is 12 the way I would characterize it.
They basically know that 13 th e reactor vessel sits in this well, but they all felt that 14 it sat higher up.
It didn't raise enough question in their 15 mind to look at th e d ra win gs.
16 CDMMISSIONER BRADFORD:
But if I have understood 17 the inportance of that point, it is pretty startling that 18 they wouldn't have wanted to be absolutely sure of it.
19 MR. MARTIN:
We would concur with that.
20 R. STELLO:
Maybe even moreso, for the tubes that 21 come out of the bottom of the vessel, that come down and 22 come up.
I 23 MR.
ARTIN:
Eight.
Right here and go up through 24 here.
25 MR. STELLO:
Which are clearly known to be some l
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASNINGToN, D.C. 20024 (202) 564 2345 l
[
33 distance under the vessel.
You would think that the first 1 amzart.
2fAAh=51wouldhavebeenraisedoverit.
Ar ! recall, that is 3 in fact the caso.
The first concern was for those tubes 4 which are again some considerable distance below the 5 vessel.
6 MR. KARTIN:
Our discussion with the chief 7 oper ations engineer, which was the first to become aware of 8 the water below 46, said tha t,he recognized that only the 9 first severs 1 feet of these tubes are hot.
So you have 10 chlorides, you have stainless steel, and you have the 11 tem pe ra tu re, and you have stress, but below that, ambient 12 conditions not likely to cause any probles.
13 And he didn 't think, because of his not 14 understanding where the reactor vessel was, that hot tubino 15 had gotten vet.
So he felt quite comfortable to start up, 16 even though you could not see these tubes down there.
He 17 did not go into the containment and physically look at this; 18 he just got reports fron his operatcrs.
19 COMMISSIONER BRADFORD:
But why wouldn't they 20 really have wanted to know that?
21 MR. EARTIK4 They will ask you the same question.
22 They don't know either.
They don't understand why they took l
23 the actions they did.
They admit an error.
I 24 C3EMISSIONER BRADFORD:
Okay, why don't you pick l
25 up where you were?
I l
l ALDERSoN REPQRTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (2C2) 554-2345
34 1
MR. MAETINs Okay.
Subsequent to the 2 investigation -- well, subrequent to Monday -- we talked to 3 them Monday afternoon.
We expressed our concerns -- that 4 was the first time that we voiced a concern that the reactor 5 vessel might have been vetted and the hot stainless-steel 6 tubing might have been vetted.
7 We asked, "Did it get wetted, and, if so, what the 8 results were?"
We also got a commitment from them that they 9 would not start up without giving us at least a four-hour 10 wa rninc.
Then we went back and caucused and tried to 11 understand what we could of the event.
12 On Tuesday we issued an immediate -- we solicited
- -.-.J: k k the commitments fo'rth( M letter.
Fednesday 13 and got 14 mornino we issued tha t immediate graction letter, and de
,),,,1
- - l v_ -
5[n
[ d we had the investigation team on site.
From 16 that time until November 21st we conducted the 17 investigation.
18 In addition to that, we have done our independent 19 nondestructive examination of wells on the lower vessel 20 head, a certain percentage of the wells on the stub tube to wells.
We also thesafe-intot}econduit 21 the safe-in and NRbM) 22 initiated a stress analysis a.n+ be.ue done that, and I 23 understand that to be avaiable by mid-December.w NDE O NDE hall the licensee's calculations / e an M*f, Eut 24 g,
25 and W k not identified sJi ;.a problem at this time with A
4 1
ALDERSON REPORTING CoWPANY,INC, 400 VIRGINIA AVE, S.W WASHINGTON D.C. 20024 (202) 554 2345
35 1 this particular event.
2 CHAIRMAN AHEARNE:
What do you mean by "this 3 time"?
4 MB. MARTIN:
This will add a portion of the usage 4
5 that you can get out of this vessel, and you can do this 6 several times and would not significantly increase the usace 7 of this vessel.
8 CHAIRMAN AHEARNE:
I see.
9 MR. MARTIN:
That is w at their calculation NM 10 shows.
As I understand,
~; S:
- t completed their 11 calculations.
12 Basically, with that, I think I will give it back 13 to Jim.
14 CHAIRMAN AHEARNE:
That completes the 15 investication ?
10 MR. MARTIN:
Yes, sir.
17 CHAIRMAN AHEARNEs Could jou comment on prior to 18 th a t particular series of events, any comments about why no l
l 19 action or what kind of action was thought of to be taken as l
l 20 a result of the 51-inch light concept being on.
As you 21 said, they noted it every f our hours.
22 MR.
ARTIN:
It is recorded.
F rst of all, there-23 is no procedure which te"is them that is abnormal.
There is 24 no procedure that er% nc','
the 91-in h is abnormal.
25 The procedure, whic, ret. : ? is on the itself, says that 4
ALDERSoN REPORTING Cod >ANY,INO, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 221t
sDA 1 the lil-mm.2..:n must be greater than seven inches.
You 2 could have a completely flooded containment, and you would 3 be greater than seven inches.
4 There is no procedure which says, "This is how you 5 should control this sump, and if you get this indication, 6 you should do certain things."
Further, it appears that 7 through the lack of calibration procedures and things like 8 that, they allowed the set point of the pump to drift from 9 the 29 to 33 inches, where you would have several lichts 10 bef ore you go out to actually overlapping t e lights that dZm.
MJE[
11 you would count on that would alert you to,r condition.
As 4
12 a result, the 51-inch light, although it is abnormal to 13 record a light, they did know that the start 11 #.7 was 14 coneplace slightly above that.
So it is possible to be 15 above 51 and be okay.
16 5R. STELL0s It doesn't mean if it were somewhat 17 above it, that you periodically would have had to have had 18 the 51 light on, although not recorded, by definition?
19 MP. MARTIN:
That is true, but if you are only 20 going to report it once every four hours and the start point 21 is so close to 51, it is just e little over, then the 22 probability that you will ca tch it in your six readings a 23 day gets miniscule.
24 MR. STELLO:
The point was that if they got to 25 where they were accustomed to seeing the light on from time ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
37 1 to time, the fact that it was not on all the time may not 2 have caused them to take the action.
But, nevertheless, the 3 question of why wasn't there some kind of analysis done on 4 there, all you know is that it wasn 't done.
And there is no 5 good reason that I am aware of as to why not.
6 CHAIRMAN AHEARNE:
During this process -- and you 7 vant to refer to it later -- but during this process, what 8 was the so-called " shift technical adviser" doing?
Was he 9 analyzing this stuff?
10 ME.
ARTIN:
No, sir, he was not.
The shift 11 technical advisers are stationed, but they are not fully 12 trained.
They were within two weeks of completing the 13 f ormal training.
They are not required to be fully trained 14 until January of this year.
15 Discussion with every one of the STAS would l
16 indicate that the majority of their time is spent in 17 f urthering their training.
They have a lot of the 18 nitty gritty of the plant to learn.
They are using the 19 system descriptions -- which are out of date, by the way.
20 They have not established their credibility with 21 the operations people, and the operagions people appear to 22 be tolerating them right now.
They ask a lot of questions.
23 They don't provide much back yet.
They are learning.
They 24 seem to be intelligent people.
They seem to want to try 25 hard.
Put they haven't -- they are too new.
They are just ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 564-2345
38 1 too new at this point.
2 The opera tors did not call them to the control 3 room.
And they discovered problems that they were not even 4 allowed to perform their function.
When the STA discovered 5 the abnormality in the nuclear instrument, when he just 6 happened to walk through, he did try to understand it.
He Sofauf 7 f ^ '2 Ti the system descriptions.
He tried to see what they 8 were doing.
He went back and watched the technicians doing 9 tests on the drawer, quickly realized it was over his head 10 and walked away.
11 (Lauchter.)
12 MR. MARTIN:
Then, when the trip occurred,,he 13 tried to find out why the trip occurred.
He was.. i-_n; t 4
14 the shift supervisor.
That was right after the runback.
It 15 probably occupied the shift supervisor's time when the trip 16 actually occurred, because of the questions he was asking, 17 askino him what he would look for.
He said, "I would go 18 check to make sure the saturation meter was in the right 19 band."
20 I asked him what he would do if the saturation 21 mete r wa sn 't reading right.
I asked him what was the normal 22 temperature in the pressurizer.
He said, "Oh, 750 degrees 23 or something like that."
I asked him, "Do you know what 24 condition you would have if it was that temperature?"
He 25 didn't know.
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
39 1
Easically, they haven't got the practical 2 knowledge of the plant yet.
And they are no t useful to the 3 operators, and the operators don't have confidence in them.
4 They were used consequently f or escort duty (or f
M*y.g/ cps.
Once it is shut down, you don t hm.m 2;-
u 6 problem.
Unless you have a problem, an accident where 7 everybody recognizes the accident, they don't really 8 into a review mode.
If everybody seems calm, to them it is 9 over.
And I have a problem with that.
10 CHAIRMAN AHEARNE:
Do any of you guys have 11 questions on the investigation before we move to Jim and his 12 enforcerent?
13 (No response.)
14 CHAIRMAN AHEARNE.
Okay.
6 15 MR. SNIEZ/K Gentlemen, wgat I will talk about
@ Amvdw 4Ae h
16 today are basic areas of compliancey4 three of 17 them, I will discuss each major area, talking a little bit 18 abou t the violations, the severity level, and the amount of 19 civil pen alty, and i'dentify the generic actions that the NRC 20 is taking based on what we are learning from this event.
21 I would like to mention that the interim 22 enf orcement policy, which was published in the Federal 23 Pegister of October 7, is what we used to guide us in 24 developing our proposed enforcement action.
25 The first slide, please.
1 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
40 1
There are basically three major areas of 2 noncompliance.
failure to promptly notify NBC of the event; 3 f ailure of required manager control systems to cause 4 ef f ective evaluations a nd corrective measures; a failure to 5 utilize the shift technical adviser in the required manner.
6 And I will discuss each of those in more detail.
7 Second slide.
8 Failure to properly notify the NRC.
10 CFR 50.72A 9 requires the notification of the NRC operations center that 10 the plant is not in the controlled or expected condition 11 while operatino or shut down.
This notification is required 12 within one hour.
Likewise, technical specifications require 13 notification of the TRc within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of abnormal 14 degradation in prior containment.
15 As Mr. Martin mentioned, on October 17 the 16 licensee knew there was water in the reactor vessel pit 17 about four feet below the crating.
There was water on the m
18 vapor containment floor.
Steamwasexi/tinotheinstrument 19 thim ble holes.
There were major leaks in the f an cooler 20 units, which constituted abnormal degradation in the 21 containment boundary.
On October 20 the NRC, through the resident 22 23 inspector, received the first report of water on the floor.
We consider this to be a Level 3 item of violation.
The 24 25 amount of civil penalty we propose is $120,000.
This is ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 664-2346
49 1 based on three days lapsing between the identification of 2 abnormalities and the report to the NRC.
3 And because this is greater than $100,000, which 4 is the highest level for the next highest level category, 5 severity 2, according to the interim policy on enforcement, 6 that requires the Commission approval before we can go 7 forward, as Mr. Stello discussed earlier in the briefing.
8 CH AIRM AN AHEARNE:
The way you have put down the 9 October 20th and calculated three days, I ga ther your 10 conclusion would be that if on Friday afternoon, if they had 11 reached the resident inspector and reported water, that 12 would have meant that there were two violations.
Is that 13 richt?
14 MR. SNIEZIK They still would have been in 15 violation of 10 CFR 50.72.
But it would not have been 16 nearly as significant if the NRC would have been notified.
17 MR. STELLO:
There would definitely have been 18 mitigation, but the rule is clear on what and to whom you 19 are to report.
A report is to be made using the installed 20 phone system to the headquarters duty officer.
21 CH AIRMAN AHEARNE:
Is it clear in your mind when 22 ve have defined " controlled or expected," that these items l
l 23 would f all outside of controlled or expected 24 MR. STELL0s Four inches of water en the floor?
25 Yes.
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
42 1
CHAIRMAN AHEARNE:
With thic plant, I am not sure.
2 (Laughter.)
3 MP. STELLO:
Four inches of water on the floor is 4 not, in my view, an expected mode of operation.
5 MR. MARTIN:
In the public statements by the 6 president and by one of his representatives, they clearly
,.3/
g mmL 7 say that water on the floor is c.;;...
1,
- r
- . :: 12 8 condition.
They acknowledge that they should have reported 9 it.
10 MR. STELLO:
Let ne get this.
This is the issue 11 that I was explaining earlier regarding approval.
The 12 lang uage in the policy s ta temen t uses the word " approval" in 13 one section.
Then it makes a reference to another section, 14 which indicates that we clearly went down and discussed with 15 the Commission our proposed enforcement policy.
16 This is the one area from which this question has 17 come up -- n ot the first time, I want to point out.
I think 18 it is something the Commission should be particular in l
19 finalizing their policy.
l l
CHAIRMAN AHEARNEs Would you define for me what' 20 21 led you to the Level 3 rather than a higher one?
l 22 MR. STELLO:
The examples of the issues that are 23 given severity level 3,
the judgment of the kind of safety 4
24 problem that was attempted to be defined by that severity 25 level that says this is where we are.
We clearly are not at 4
l l
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASNINGTON, D.C. 20024 (202) 554 2345 i
l
43 he argument 1 & one where you are locking at an event -- t to.
2 me seems it could be as high as 2.
There are some 3 substantial arguments that it could be, that it might be a dnAyw 5
COMEISSIONEE GILINSKY:
It rrub L; cha racterized 4
62, 3,
or 4?
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
44 1
MR. STELLO:
Let me just give you the examples 2 that are in here. "The system designed to prevent or 3 mitigate serious safety events, not being able to perform 4 its attendant safety functions.
The release of 5 radioactivity off-site greater than five times.
6
"(4)
Violations involving inadequate review or 7 the failure to make your review in accordance with 10 CFR 8 50.59 or 10 CPR 21 that does not result in a severity level 9
1, 2, or 3.
10 "Any license limit not covered by 1,
2, or 3 11 conditions being exceeded.
Failure to meet requirements not 12 covered in severity levels 1,
2, or 3 that measurably 13 degrade the safety of operations of the incident respondent 14 or +he environment, or failure to make a required license 15 384P repe r t, when the reported matter itself does not 4
16 constitute a violation."
17 When I look at the two of them, in my view, 18 alth ough we don't merely have the examples that we have, I 19 believe that three is the proper severity level.
This one 20 of the areas that we are getting comments on in trying to 21 improve our ability to find better the severity levels.
But 22 it is clear to me that this will continue for quite some 23 time, for which this will have to be a considerable judoment J
24 of exercise.
desdA#tAA,g m.
7f J
9 i
25 COXMISSIONER BRADFORD:
One of the
+b4
- c you get i
i l
l l
l l
ALDERSoN REPORTING COMPANY,INC.
1 1
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
c5 1 i s,* w e tried to call the inspector on Friday.
The response 2 you make to that is what?
3 ME. STELLO:
The response I made to the Vice 4 President is I found it very irrita ting to even hear or have 5 it suggested as an answer.
When the NEC has installed 6 special phone systems and we pay for the: and they are 7 convenient, all they have to do is pick up and they have 8 someone on the other end who is reminded that they can tell 9 whatever is needed.
I can't see the possible harm in having 10 them aired by calling the duty officer rather than the
- 11. resi den t inspector.
12 I find tha t kind of an answer, to me, a source of 13 irritation.
14 COMMISSIONEE BEADF0FD:
What makes it a fairly 15 easy case, a t least an easier case, is they didn't reach the l
l 16 resident inspector.
l 17 MR. STELLO:
They weren't going to tell the 18 resident inspector about water on the floor anyway.
All 19 th ey were going to tell him is they had a trip.
20 At 3:00 on Friday afternoon --
21 MR.
APTIN:
Let ce peint one thing out. We are 22 told be cannot prove this, b 't e
re told that he was going b&
23 to tell the resident that they c nr_ls; fan coolff unit l
24 leaks, that they were off the line, that they had some water 25 on the floor but they expected to start up within three l
l ALDER $oN REPORTING CoWPANY,INC, 400 VIRGINIA AVE, S W. WASHINGTON. D.C. 20024 (202) 554-2345
46 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
And the night orders read "we will start up by 2 11:00".
3 COMMISSIONER BRADFORD:
You would certainly have a 4 much tougher case if you ever had a situation in which the 5 resident inspector had been told and had not, for some 6 reason, passed the information on.
I guess what I 'm really 7 saying is, in a case like that I hope we have internal 8 procedures such that the resident would have -- would take 9 the initiative in reporting back to us himself.
10 MR. MARTIN:
Commissioner Bradford, if I might 11 comment on the two earlier trips in which the resident was 12 informed on Friday morning.
One of his questions to them 13 w a s, have you informed NRC headquarters.
The technical 14 engineering director went back and verified that they had 15 and got back to him and said yes, we have, on those trips.
16 So yes, he does check that aspect of it.
17 MR. STELLO:
But it is interesting to note that in 18 those instances they both called the duty officer and the 19 residen t.
20 CHAIRMAN AHEARNE:
The rules say they have to call 21 them on the trip.
s 22 MR. STELLO:
On the trip they call both.
23 CHAIR!AN AHEARNE:
I know.
COMMISSIONER GILINSKY:
Can you tell me which of 24 25 these items you are tieing the severity three to?
Let me ALDERSoN REPMTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 564-2346
47 1 give this back to you.
2 MR. STELLC:
Which one of the items?
3 C3MMISSIONER GILINSKY:
It says the violation M
4 involving and four points under it.
4 5
MR. STELLO:
These are e x a m ple s.
You can't fit 6 this to either of those examples.
7 COMMISSIONER GILINSKY:
I see.
Okay.
But you see 8 it as comparable to those?
g PR. STELLO:
Yes.
There is a definition up 10 f r on t.
It speaks to severity levels 1, 2, or 3 -- that i
l 11 these are issues of significant concern.
And I clearly 12 think these are issues of significant concern.
In my view, I
l 13 it belongs in one of the three ca tegories.
I think it is 14 not reaching the intent of clearly 1 or 2, I don't think.
15 COMMISSIONER GILINSKY How did you come up with 16 $4 0,000 ?
17 HR. STELLO:
It is three days, and it is per day, 18 $4 0,000.
19 COMMISSIONER GILINSKY:
How did you come up with 20 40?
21 MR. STELLO:
That is in the table.
i 22 COMMISSIONER GILINSKYs There is some mechanical l
23 w a y t o d o it ?
l 24 MR. STELLO:
Yes.
1 25 COMMISSIONER GILINSKY Good enough.
1 i
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
49 1
MR. STELLO:
It is the policy statement that says isT[40,000.
2 for severity level 3 it 3
Elide 3, please.
4 MR. SNIE" K Next item or major area was the 5 failure of required management control systems.
The 6 technical specifications require review of ihe facility ope ations by the station's nuclear safety committee to the 4 7 / c J.A 2 4 [itrary
/8 } hh " 4
' #" +
5.
Co to that the reactor was A
2p?
9 started up October 28 without the required review being i
10 performed.
The flooding of the pp t -- the exit steam from 11 the thimble holes was not evaluated prior to starting up.
12 The tech specs also require that procedures be 13 established, implemented and maintained in accordance with flo Y 14 Reg Guide
- 1. 3 3 a nd A N SI stan dar d 4 r9t*, which addresses OA 15 f or opera tions.
And there are no set points for containment 16 and sump pump operations which specif y it in the 17 surveillance tests.
18 Likewise, procedures were not established which 19 would sa tisf actorily de tect reactor coolant system leakage 20 i that the calibration of the humidity detectors N the
- ^rN AMEA#
And, likewise, the reactor coolant
& $ performedf ^^ b a h e"-Mm 21
- f A
22 system M versus bw point was not correct.
The 4
23 procedures were not established for controlling containment 24 sump levels to a specified range, a s Mr. Martin had 25 indicated previously.
(
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345 l
I l
49 1
And the procedures for determining when 2 maintenance constituted modifications were not established.
3 That gets into repairing of the coolers with epoxy and 4 Adams-type patches.
Likewise, 10 CFE 50, Appendix E, j
5 requires the QA program to provide control over activities 6 affecting quality.
In the FSAE they are committed to a OA 7 program, again consistent with ANSI standard 16.7, which is 8 QA operations.
4 9
This addresses the prompt detection, evaluation, 10 and correction of problems.
Contrary to this, the causes of 11 the malfunctions and the leakr,in the 'an coolers were not w / c+<as k 12 properly determined es evalu ite and they mae have persisted j
13 over a nunber of years.
14 Likewise, the evaluation of the repair GAAdW r.ater!als were not made for the fan cooler 15 rethodologyg 16 re pairs.
As a sub-set of this, the technical specification 17 also requires that repairs that may constitute a 18 modification be reviewed by the plant
,ommittee.
And 19 this war then done.
Quality control and cr--i_imi reports 4
20 that were reviewed by the inves+1gation tea.s sho ed that p
respondw).s to P i ":
N M 1.11 ], '
W y-closed e+f f~-
^5:
21 they wee not M as M A
d as prescribed by tne plant procedures.
23 As an example, the plant procedure required t at gn^ ^ ^^, t9H Nf 7 24 no rm ally a response on a quality control,rr 4
21, m uvu 25 be received within three days.
Some of the items were I
(
ALDERSoN REPOATING COMPANY,INC, i
400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 554 2345
50 1 ou ts ta ndi ng f or a period of years.
And there are about 2 twenty examples that wa identified, some of which were 3 associated with the fan cooler units and others which were 4 not.
5 The Licensee did not properly identify the 6 flexible hoses en the fan coolers and, therefore, replaced 7 the hoses with the wrong material.
A combination of the 8 failure --
9 COMMISSIONER HENDRIE.
Do they put stainless on it?
If 10 KR. FNIEZ/X*
Yes.
11 MR. MARTIN:
Through a confusion of what material
- 41f 12 was present, they cut JMS holes and removed the center A
13 section.
They put stainless steel holes in its place, 14 assumed it was a or-one replacement and made a assumide stainless steel-to-stainless P-8-to-P-8 w eld,A 15 16 steel.
And that is not a qualified weld procedure for that 17 dissimilar metal.
18 MR. SKIEZ K:
The aggregate is classified as a 19 level 3 violation and that the management system designed to 20 prev ent or mitigate a serious safety vent did not perform
,W 21
$S, intended function and that the conditions preceegpe,
e ^j(^ ^ ^^ ^"3 1
22 ?;.
uy the containment flooding.
The amount of civil g
23 penalty in this case, we propose T50,000, and it is above
$44...
24 th e base figure because we intend to increase it 25 percent 25 over the base CP because of the serious breakdown in the t
l l
ALDERSoN REPoHTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
51 1 control system.
2 CHAIEMAN AHEAENE:
They way you had it phrased 3 here had a better ring to it.
4 (Laughter.)
6 5
MR. SNIEZ/K:
That is too hard to pronounce.
6 COMMISSIONEP BRADFORD:
k' hat are you using for 7 duration to calcula te this?
It looks as though it is just 8 the one day.
B 9
MR. SNIEZ/K:
We did use a one event type 10 calculation.
We did not calculate over all the days because 11 the evaluations -- it was a continuing type breakdown over 12 th e period.
It wasn't an break point.
13 COMMISSIONER BRADFORD:
Presumatly those 10 CFR b
/^
Appendixj[ violations actually went on for years.
14 15 MP. SNIEZ K:
That is correct.
The most j
16 significant of these, we felt, was a failure to evaluate l
17 what existed there before they were ready to stari up the l
18 plan t.
We consider that the most significant aspect of the 19 brea kdown -- the fallare ts evaluate what they had.
20 MR. STELLO:
The real difficulty with picking up 21 some part of this -- the Appendix B problem that was over
.n years -- is if you look at that and you get its isolation, 23 not as part of this larger problem, then that will probcbly 24 move to a category C or 5 issue, than a 3 to begin with.
Do 25 you see my point?
When you look at it by itself, but when l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564-2345
52 1 you look at all of these as part of the failure of the 2 management control system to do the job that it should have 3 with regard to the water on the floor issue, which is the 4 intent or the thrust of this, then I think they fit together 5 and it is an event -- a thing-oriented, rather than any
?
6 number of specific 1.. w.
7 C3MMISSIONER BRADFORD:
Had it consisted simply of 8 getting the pressure vessel wet -- th a t i s, from tha t point 9 on they had understood the seriousness of it and not tried
?n to restart -- my impression is all you.wopld have is the 10 the f ailure o[musf h
90 management t: :::" ire _
11 CFR Appendix B under 12 dee 1-sys t em s.
13 MR. STELLO And the wetting of the cyr'm 1
itself.
That would have now been an event, according to
(}d. M 15 h policy.
A 16 COMMISSIONER BRADFORD:
Right.
17 MR. STELL04 So the major issue, then, would have 18 been the vetting of the vessel.
19 COMMISSIONER ERADFORD:
Yes.
P, ^ 2 ^ / O*
20 MR. SKIEZ/K The tech procedures that we have A
21 listed here, they would still be valid, because that is what 22 attributed to the vessel getting wet.
COMMISSIONER BRADFORD:
I see.
Okay.
So what you 23 24 would lose would be the 6.5.1.6.
MR. STELLO:
Yes.
25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
$U ER.SNIEZ/K:
Because they would have done that 1
2 adequately.
3 MR. STELLO:
You may recall the discussion of the Y
' policy 4
we had.
We talked about the first times that we g
5 would ever use these factors and the emphasis was coing to 6 the lesser amount, the implict; ion being that we would l
7 inform the Commission.
8 This is the first time the issue has come up.
9 CHAIRMAN AHEARNE:
Are they replacing these fan 10 coolers?
11 MR. STELLO:
Yes.
12 Cil AIR M AN nHEARNE:
Are these same approaches -
13 patchvork repair // being done in Unit 3?
14 MR. STELLO:
The way Unit 3 repairs are done, to 15 the best of my knowledge, are using epoxy, or actually a 16 sold er repair.
Am I correct in understanding that?
They 17 are being plugged.
18 The impression I also have -- you remember Mr. Roy 19 Woods looked at both of the physical appearance --
4 20 CHAIRMAN AHEARNE:
Sure, because they are never.
21 MR. STELLO:
But the repair techniques that are 22 being used are different as well.
23 MR. SNIEZ Ks Slide four, please.
24 Mr. Martin really hit this item in his discussion 25 regarding the performance of the shift technical advisors.
ALDERSON REPORTING COk#ANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554 2345
54 1
CHAIEMAN AHEAENE:
We will accept -- Mr. Martin 2 talked about these people who were in training and why they 3 didn't -- why they weren't used.
As he points out, though, 4 in the report they were actually using somebody as a shift 5 technical advisor.
6 MB. SNIEZ Ks The bottom one here -- the shif t 7 technical operations engineer -- acted as a technical October J/ @
That is as far as the investigations 8 engineer on 9 team went, but as far as the discussions, they were actually 10 the chief operating engineer and some of the others.
11 ME. MARTIN:
The reactor engineer and two others 12 were rotating to cover the weekday operations of the STA, so 13 that the ETAs could be in training.
14 CHAIPMAN AHEARNE:
By ro ta tin g them they would 15 just pick.up the label.
They weren't actually a separate 16 engi.neer.
17 MR. MAETIN:
They knew tney had to be within ten 18 minutes of the control room.
They knew that that was their 19 function in life.
But when they entered into a problem, 20 such as the chief operations engineer, he was gising
[
6 21 decisionsj
!R. SNISZ[K:
The NBC in 1979 sent a letter 14M>t g
....wn O t h e y-nd~-" I~ " i r o r
-- the shift supervisor shall 3g 24 no t act a s th e shif t technical advisor, so we don't have 25 production pressures associated with that.
That is the only ALDERSoN REPORTING COMPANY,INC, 400 VIRGINtA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
55 1 other key item on there.
2 COMMISSIONER GILIN SKY :
Is this a situation that 3 is unusual or typical if you have inexperienced advisors to
?
Q w R.tS.%e: J by!gyev+gnaest*L W [.,_dh the opera tors aren 't payin much attention?
4 whom
]
M STELLO:
We are i# the process of deciding, on 5
6 the basis of what we looked at h ere, and trying to make the 7 judgment on what the rest of the plants look like at the 8 moment.
We will be talking about that as an action item, 9 based on t' is experience. As you impose a new request for 10 ew people you do have a learning process.
I think this 4
- too much e learning process to be acceptable.
11 A
12 I don 't know of any specific case where this is 13 done in another plant.
But I feel the need and Harold and I
'14 have talked about the need to get off some kind of a letter 15 that relates experience to make sure if we a re having correctedg M
't I ;"
16 these kinds of problems they get 17 CHAIRKAN AHEARNE:
One of the concerns I would 18 h a ve, listening to Tim talk, it is not clear to me that 19 those people may have finished their training in January of 20 this coming year.
21 ER. MARTIN:
They are within two weeks of 22 finishing their formal training.
23 CHAIRMAN AEEARNE:
But the description you gave --
24 their training and the attitude of personnel toward them --
25 clea rly no major change is going to occur in a couple of l
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W WASHINGTON, D.C. 20024 (202) 554-2345
56 t weeks.
2 MR. EARTIN:
The STAS indicate th a t the situation 3 is getting better.
4 MR. STELLO:
You are looking at a snapshot back in 5 October. There are three more months of training.
6 CHAIRMAN AHEARNE:
You are saying that the 7 operations people are now -- tode y those guys are now going 8 to really know that much?
g MR. STELLO:
Do we have any information in the 10 sense that there is going to be an improvement?
11 MR. MARTIFs The only indication the STAS gave me 12 was their acceptance is lot better than it was in May and e
13 it is improving.
COMMISSIONEF BRADFORD:
These are the STA-W.eae?
14 15 How do they k no w)
[F 16 MR. MARTIFs Because apparently their discussions 17 are tolerated more.
18 (Lauchter.)
COMMISSIONER BRADFORD:
The operators have a lot 19 20 more time because the plant isn't operating.
(Lauchter.)
21 MR. MARTIN:
When he talked to me it was shortly 22 23 af ter the event and they were discussing the perception of their acceptance prior to the event.
24 COMMISSIONER BRADFORD:
I see.
Just one other 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
1 57 1 question about this chain.
You have, let's see, two letters l
2 and NUREG-0578 in there.
Jim, what is the actual chain that 3 makes that combination enforceable?
Do they have the status 4 of o rders?
5 MR. SNIEZ Ks The NRC conformatory order is what To M w.
6 we are really basing it on.
On February 11,g Cr--i w,4n 7 Dent required the establishment of the STA position within 8 90 days.
That is really what makes the requirement and the 9 letters clarif y the NUREG documents saying what we need to WM 10 be d oing.
p ne cs m.
7 R. MURRAY 11 AL:
The letters ^;-.a p
12 COMMISSIONER BRADFORD:
So they have not 13 established an STA within what we meant ?
14 MR. SNIEZ/K They are not implemented in an 15 acce ptable f ashion.
16 COMMISSIONER GILINSKY:
That is more than "they 17 were properly u tili,t e d ".
d 18 MR. iheva That is correct.
I used those words 4
19 to paraph rase the overall significance.
That is why the 20 chief operations engineer item is down here also.
For this 21 item we do p.apose a $40,000 civil penalty as a level 3 22 violation.
g n,
23 COMMISSIONER GILINSKY:
Why isn't that cer;__;d A
l 24 W by the number of days?
,(
8 25 KR.SNIEZ/K Again, primarily because it is an ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
58 1 aggregate action on the part cf the Licensee.
He hasn't had G [w m 2 any previous --
a -(
COMEISSIOFER GI 1.Np h lThey failed cc..A r A A A. n - ! !.
Y-3
..m M
ssed.
--.;,2;.' k &
Nv failo# +"
4' day.
They failed to r * * #'
ld In)h As - > gh
. m :W C~%
s s,, ^-
jw pp+
l 6
R. SNIEZ/F:
hu 'sm ee c _ h as a one-time L
r4.~ h 7 failure on the part of the Licensee he count the number of 4
8 days, h he investigation determined the specific number 9 of days but looked at the system that broke down.
It was a 10 system for tilizing the shift technical advisors that broke Ch','
?Y.
11 down at i....-
12 COMMISSIONER BRADFORD Do you run into a problem 13 in of the number of days g business with e b c i O. c having^to take a eingle point and treat it as a single 14 4
15 violation or e f e you start counting the days discovering 16 that all of a sudden you have a couple of hundred days times 17 $4 0,000 and you are talking about a penalty up in the 18 millions?
That is, it is very hard to apply this for three 19 days or four days, even though you might like an amount that 20 is more like 7100,000 or $150,000?
l 21 HE. STELLO:
That issue never even ca e up..Jac*
p
,.. L a--_-a y 1
22 decido# that the shift technical advisor ^^" be{u2UAdr 4 y y - Q y
...A
- a.,ggy y Q ^be calculated on penalty could 23 it va s to whether the l
24 the basis of those hundreds of days tires $40 000 25 COMEISSIONER GILINSKY:
If he had v e+ i fim
_ m.-
A ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASNINGTON, D.C. 20024 (202) 554-2345
l A nb> b.-
W -41h**
5*
a g',c=//[4 J~
M 1 O -.-
2-
^
Th - I pr would be inclined to Qe _ f.b bly-j~,.
MR. STELLO:
2 4
3 raise the issue, as we did We would more raise the issue j
e 4 than decide that is right.
If the penalty starts to get up, 5 in the case of Palisades, it would be 417 days, and the 6 number is $80,000, or $30 million.
That doesn't seem to se 7 to be the answer.
8 I think at that point you have to exercise 9 judgment.
10 MR. MURRlf:
At this point there is a problem, but 11 there is also a question of proving each day.
Perhaps you 12 can draw the inference.
That is what we are doing in the 13 Palisades case.
14 I shouldn't discuss the Palisades case. That is 15 now in litigation, but there is a problem of proof.
In 16 other words, the statute requires the time and date, et 17 cetera, f or each violation.
COMMISSIONER GILINSKY But you certainly could do 18 19 it 20 CHAIRMAN AHEARNE:
For the three days that they 21 tried to start up.
R. STELLO:
You clearly could, with some 22 23 ex ceptions.
We have broken this $40,000 down. For example, 24 chief operations engineer.
That was clearly a single part, i
25 which would mean you would now have to take the subparts, or ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASNINGTON, D.C. 20024 (202) 554 2345
I 60 1 the reasons or the rationale, and a pply them to each of the 2 parts you are applying them to.
the herefortheconynienceof 3
There are a lot the actual closed [ enforcement t : ;' _
package l
4 presentation, but in 4
5 they are broken up.
Eut I think that yes, that is 6 legi tima te.
The argument could be made on the basis that it 7 clearly is a matter of judgment to either do it or not do it.
8 The reporting requirement to me seems very clear.
9 There was information that did not get passed on.
With that 10 many days you are now looking at a judgment of the accuracy 11 of the shift technical advisor over a period of time.
It is
,L.L~
clear to E th N U das there over a period of time.
How do 12 n fu 0
13 you'fAM the penalty?
4 t
14 My judgment is it ought to be a single event, just 15 as the management breakdown -a complication you might run 16 into in trying to patch that ep.
Over the period of the the
/
17 year since the bulk of the basis finding was the way & yQ
.-n 2 A 4
13 did not analyze the "a4" of the9 -" r nc..^..^ What M4 was p nin bk?-!
,OLL%
CAa 19 M multiple th'h~ number o.
days, as opposed to the hours 4t'%
(
20 or minutes or seconds.g o that is the way the law is S
written was $10,000 per day of violationjdV 21 g. It COMMISSIONER GILINSKY:
I guess that makes the 22 23 logic pretty clear.
24 MR. STELLO:
It is a difficult judgment.
It is 25 not an easy one, but I don't recall ever even raising the k
0 g&
ALDERSoN REPORTING COMPANY,INC, l
400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345 l
69 1 issue.
It just seemed fairly complicated.
We really did m>
2 try to break them down, especially the management" h~.
If 3 you try to break the specific instances down it is very, 4 very difficult.
I 5
MR. SNIEZ/D Slide 5, please.
l 6
Ona other item of non-compliance should be broken l
7 out separately because we didn't consider it as significant 8 as the others.
This slide Mr. Martin mentioned.
On October 9 17 the power fuses were pulled fo,r th fectiv y" f
& - 11e
./ :.
ion out hedt r::::ir:
+k-
~=e*
10 instrumentay1 lchsnnel wi 4
2n--
4 L,n pyy We consider this a level 4 level to 70 percent,A " -^~
- __mm, 11 12 5 and no civil penalty is assessed for it.
13 Slide 6, please.
14 A summary of the enf orcement actions, three major 15 a r ea s -- th e failure to notify, we propose a 7120,000 --
16 that 's T40,000 over a three-day period.
The f ailure of 17 management controls, $50,000 -- 540,000 plus the 25 percent 18 for the significance of the matter. And the shift technical 19 advisor utilization is an additional 740,000.
The total of 20 $210,000.
21 In addition, the regional office issued an 22 immediate action letter October 22 to get items under 23 control f or the licensee.
We conducted a public meeting on 24 November 5, and subseqently have received several 25 commitments for evaluations of the events by the licensee, ALDERSoN REPORTING CoWPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554-2345
62 1 and expect a report from him on December 22 on his analysis.
2 MP. STELLO:
Before ve move to the next slida, I 3 would like to describe some of the generic actions that have 4 been taken and things we're looking at in the future.
We 5 vant to stop at this point to suggest that my thinking is on 6 how we ought to move forward with the enforcement actions.
7 With the assumption that the Commission does not 8 have any difficulty with the proposal, we are in the final 9 process of preparing the enforcement package.
We would 10 finish that work-up tonight and be prepared to take the 11 enforcement action first thing tomorrow morning and notify 12 the Licensee.
13 We have drafted a press announcement which we 14 would issue giving the Licensee some reasonable period of b
15 tima to 44*? provided the enforcement package and becore at 16 least familiar with it before we issue the announcement.
At 17 that time we would also make a distribution of the actual 18 investigation report.
Simultaneously with providing the l
l 19 announcement of the enforcement nrtion.
Thereisaninterestingoffett's Committee by Mr.
20 p_
j l
21 Eager with the possibility og;~..ag to arrange for a le next week to discuss the l
22 hearing as soon as possi5i- ? M.
Jk "o has specifically requested 23 inspection activitiesg 24 copies, and my proposa> vould be to provide those 4ea to 25 Congress as well tomorrow before we take the action.
[
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON. D.C. 20024 (202) 554-2345
63 1
At this point I will need to know whether that is 2 a reasonable vs y to go forward, or we shall somehow modify 3 our proposal until it is acceptable.
4 COM ISSICNER BRADFORD:
I would like to at least aNA ity3et for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
I just got the package as of 5 ask that 6 about noon.
I want to think a litt e bit, f or example, 7 about whether it makes sense to look at the failure to 8 notify over three days as against the other two just as 9 being a single item violation.
I could ask you about the 10 logic of that here, but I would still like to think about it.
11 Also, I would like to think a little more about it 12 as a separate question.
You may be intending to address it startling g/ m E ;
c
~
13 in another context, but you do ha ve a f airly 14 failures here and, given the location of this particular 15 plan t and the importance of not having this type of failure, l
16 I wonder what you see as being a process by which we reached l
17 the conclusion that we are comfortable having this Licensee 18 opera te a plant thirty miles from New Y rk City.
hA0L A 40$ $
b 19 E. STELL0t g '?: irr't even recommend that now.
l 20 That is not, in my view, an issue.
Not now.
We are going 21 to specifically ask them, and the letter I intend to send s
irement f or them to both
&pecificr --
22 them would include, a
": : ^
l l
23 em phasize in their respons a detailed description of their l
24 plans and actions to improve their management control system.
Until I have seen that I am not prepared to even 25 l
l l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
64 1 address the issue, because there is so r.uch work that needs 2 to be done before I am prepa red to even think about that.
3 C3!MISSIONER BRADFORDs So what you see is putting 4 out this packace as a specific response to violations that 5 have occurred.
The s$y;cific r spon$ee to the results 6
MR. STELLO:
pe 2
~fa-----e 3
p 7 of our investigation, which seeve. -
we have I
A h_ s n m 8 expressed today and the broader c _9^ir-you bring up I have j
9 not prepared anything about it at the moment.
10 COMMISSIONER BRADFORD:
You would be specifically 11 reserving that for a later determination?
Because that g
sth ge is a lot more work 12 MR. STELLO:
13 needs to be done regarding4t h issue.
I 14 MR. !ARTIN:
If I might make a comment, the 15 immediate action on the final item requires reaching one's 16 concurrence bgf orp they start up.
So we do have a hold *e.-
m & 2xnna, 17 rir-a.
/
18 CDE!ISSIONER BRADFORD:
I understand.
19 COEEISSIONER GILINSKY I would be prepared to ao 20 forward with the suggestion, although I would not like us to 21 be foreclosing the possibility af multiplying those fines by L.' T. ), q m.
22 the nur.ber of days, et lea st c'f i mil-i. B ut this thing did 23 come up just a little while ago and I would appreciate as Peter said, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
I 24 having a little more time 25 would like to look at it a little mese, longer too.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
O 65 1
COMMISSIONEP HENDRIEs I would go ahead and they are like taking the 2 approve it.
These things have 3 Good Humor out of the freezer.
You get about fifteen 4 cinutes before it begins to get mushy and drip through your 5 fingers.
6 (Lauchter.)
7 COMMISSIONER HENDPIE You know, the package is 8 prepared at ICE and I could grump one way or another over 9 various elements of it.
10 C0".MISSIONER GILINSKY What is your neern --
7 11 that M d'
N#
+
A 12 COMMISSIGNER HENDRIEa Premature and incomplete --
13 they are c';ing to do this or they are not going to do that, 14 or something.
It is very hard to hold these things.
You 15 will have people f rom the media sniffing that action is 16 imminent and calling all kinds of people, just a word here 17 a n d a word there, and first thing you know you're off.
18 ME. STELLO:
I might add they already know.
ME +&ggf}a d:
4
-- syheyknowabout this meeting but they 19 20 don't know about the recommendations.
21 COMMISSIONER HENDRIEt I would recomend to you, 22 unless you have really grave dif ficulties with the proposed 23 enforcement action, that you consider the merits of getting 24 it clean out of the house.
25 CD MISSIONER BRADFORD:
What we are saying, in i
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON o.C. 20024 (202) 554 2345
O 66 1 effect, by approving this package is that somehow the 2 interplay of law and policy produces from the Indian Point 3 event a result that should cost a Licensee about half of 4 what we are proposing in Palisades.
5 C3MMISSIONER HENDRIE Can we talk about this?
6 Can Peter and I talk about Palisades?
Never mind, I know I 7 can't talk about it to you.
8 MR. MURRAY:
Far be it from me to say that you 9 can't talk to your colleague.
10 COMMISSIONER HENDPIE:
What does ay lawyer say?
11 MR. BICKWITs You are talking generic policy.
12 (Laughter.)
13 COMMISSIONER HENDEIE:
You actually have a more 14 serious problem.
15 CO!!ISSIDFER'BRADFORD:
In Palisades?
16 CD MISSIONER HENDRIE:
You know, we go and sweat 17 and strain about this final barrier around the reactor 18 system and then discovery, Jesus, this is operating with a 19 hole in it.
Oh, boy!
That is something I am prepared to i
20 get a little steamy about.
Here you had a batch of water 21 dripping on the floor.
Clearly there was no failure to come l
l 22 to recognize that this was something that NRC should be 23 notified by no more than putting in a call to a resident's 24 recorder saying yes, th t's bad.
Yes, you ought not to wet
%^A^2 :,
25 down the reactorg 4
ALDER $oN REPORTING CoWPANY. INC.
400 VIRGINIA AVE, S.W WASNINGTON D.C. 20024 (202) 564 2345 1
67 1
Put in terms of the inability into the essential 2 safety systems to provide protection you can depend on, it
,f-3 just doesn't hang up in that league for me.
4 CHAIRMAN 1:HEARNE:
I guess I share Joe's feeling.
5 I think the earlier question you asked Peter was more than a 6 substantial one of whether this is characteristic of a set 7 of thinos with respect to a particular utility and what 8 conclusions does one eventually want to draw about that 9 utility.
That, to me, is the significant thing raised 10 here.
11 So, although I might have preferred to / tune this 12 somewha t differently, I don't see any resson for us to step 13 in and go againct the director of ICE's conclusions.
M=
?
y
" ' " 1 r'
-=i-o So I would be happy to 15 d on ' t see{',
16 let them go ahead.
17 COMMISSIONER BRADFORD:
What about another 18 comparison?
At Nine Mile Point -- can we talk about Nine Ma&-
A&
19 Mile Poin t?,Jrc an yoneg....
M 4n a hearing on that?
20 XR. BICKWITs No.
21 COMMISSIONER HENDRIE4 An unspecified reactor.
22 COMMISSIONER BRADFORDs You have a situation in 23 which you said a particular individual ought to be barred 24 f rom f uture nuclear activities f or, in ef fect, seeking to 25 mislead the Commission.
And obviously seeking to mislead ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASNINGTON, D.C. 20024 (202) 554 2345
o 68 1 the Commission is serious in that it has all sorts of 2 serious implications in teres of what can go wrong at that 3 particular plant in the future.
4 CHAIRMAN AHEARNE:
Or any other plant.
5 COMEISSIONER BRADFORD:
Yes.
True enough.
Here 6 you have a pattern -- well, failures of management control M'
which in some ways could also give 7 scr the exact phrase 8 rise to serious consequences.
Are you saying with regard to W
9 the incompetences against deliberately misleading, if in 10 f a ct incompetence turns out to be an issue here, that that 11 question is set aside for the moment and that you may deal 12 with it later if it turns out there is a particular 44) 13 individual who he the result of all this who doesn't seem 14 capable of being involved with nuclear opera tions ?
Is that 15 a decision you can still make la ter?
16 ER. STELLO:
In my view, yes, although I don 't see 17 facts which suggest it is going to point to an individual.
18 It a ppears that it's a management system.
19 COMMISSIONER ERADFORD:
Yes, I am just 20 hypothesizing.
I have no idea where it is going to lead.
21 HR. STELLO:
Let me point out, as I am sure you 22 all must recognize, that the judgment in enforcement action 23 is a very difficult thing to suggest to the r of you 24 sitting on the other side of this table.
Me basically come A
25 up with the same scheme or thought process that Iused)
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASNINGToN, D.C. 20024 (202) 554 2345
O 69 1M I just don't think that is likely.
It is a 2 process where I listened to recommendations of the staff.
3 As I listened to them, in fact, they were quite different 4 then my view of what ought to be done.
And at some point 5 this decision process must come to an end and one has to 6 decide.
7 I recognize how much judgment is clearly here and 8 I recognize that every other enforcement action -- 'ina v.ile he,[
W f ' did 9 and Palisades -- theoretically, Palis ad e s,A 10 enf orcement policy I think the fine would be at least as 11 large.
I think that is a more serious issue in rv mind, but 12 it is this process of judgment, of trying to take the 13 benefit of the staff as we move through this enforcement
~
activegefinthelastyear 14 arena that we have now been very 15 and a half, and we are learning it.
I think we probably 16 have quite a bit more to lea rn, but I think every time we 1
l 17 come down here the questions you raise you could raise again 1
18 and again until we have had more expert'nce.
19 There is no way I see out ci che issues which you 20 bring up.
The principal one seems to be the number of days 21 that you apply that these things are wrong in deciding 22 whether there ought to be a per-day violation for some of l
23 these issues.
24 The whole thrust of the new enforcement policy was 25 to try to get away from that as much as we can
- 1.,._t ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) $$4-2345
70 1 trying to be event-oriented.
That was the whole purpose of 2 it.
3 COMM!SSIONER PRADFORD:
Even within this package, 4 I guess I still don 't fully understand why the failure to 5 notify clearly gets multiplied over three days and the 6 f ailure of management control, which went on over those same i
7 three days, only shows up on one count.
I 8
MR. 5ARTIN:
Can I respond r n.._ ; p ?
The people 4
9 who should have been making the notification were alerted 10 again and again to the situation.
The chief operations we 41 e
11 engineer and the pl an t re. ; ; m. - -. t were notified at 6 00 on Fri y of the conditions r i-12 approyimately$ R g*
A 1
r a
13 u+ 5 : : "T=""""'c 14 They came in again on Saturday.
They reviewed 15 their sheet that they fill out to determine who should be 16 notified and concluded on Saturday morning that 17 notifications need not be made.
The question was there in 18 f ron t of them. They had to check the right block and they 1
19 concurred on the checked block that no additional 20 concurrence or no additional notification was necessary.
l 21 Later that afternoon they knew they were 22 experiencing problems with pumping the water out.
The water 23 level was again cha racterized to them in that pit.
24 COMEISSIONER BRADFORD:
On each of these occasions 25 on a couple of those days they were also going through the ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554 2345
79 1 exercise of attempting to restart and it is the attempt to 2 restart that several of those failure of management contr Af %^Y 3 items ; -
uv. c..
A;.
4 y
},
5 intende y the conclusion on your part, but you told us you to multiply thos #
6 rea ly didn*,think about whj =ther orsg msg
,w w 7
MR. STELL0s I can 't reenl that discussion comi o 8 up.
9 COM ISSIONER GILINSKY 1,.vae v2vAations by w.w 10 ' " ' - J _ _ ; r --
I would be prepared to go along with this 11 so lona as we understand this is something we still need to 12 think about and we haven't decided for all time that these 13 sorts of things --
c 14 ER. STELL0s I certainly don't want to preclude 15 you the number of days of violation.
In fact, is it not 16 clear that we have set a precedent.
We are doing it, and 17 whether we ought to do it on more issues or different issues 18 I am prepared to think about it some more.
I think this is 19 the best judgment f or now f or this' case.
4 20 CHAIRMAN AHEAPNE:
But not necessarily setting 21 this limit.
22 MR. STELLO:
No.
COMMISSIONER GILINSKYa I have a fairly high 23 24 threshold f or overturning your recommendations, so I don't 25 necessarily agree that that is the way to do it, but given ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
72 1 that you have recommended that, and as Joe says, I don't 2 have any violent objections to the proposal, I am prepared 3 to go with that.
But I would not like us to have it settled 4 f or all time W
5 The question me,ht to deal with those.
6 "R.
STELLO:
If we had settled it for even one 7 more time I would be delighted.
8 (Laughter.)
9 MR. STELLO:
Much less for all time.
10 CHAIRMAN AHEAFNE:
So you would be prepared to co?
11 COMMISSI NER GILINSKY:
I guess I am sort of
!!=. = W 12 persuaded by Joe's ce:- '^^
principle.
4 13 (Laughter.)
14 C3M ISSIONER GILINSKY:
This thing came up not too 15 long ago and I haven't had a chance to look through it.
I 16 don't want to cause' Peter inconvenience, but I think, as we 17 sa y in the Sta te Department, on balance, I think I will go 18 forward with it.
19 COMMISSIDFER BRADF0ED:
If I were signing off on 20 it this afternoon, my preference would be to multiply each 21 of those violations by three days.
I haven't grasped a 22 distinction on that.
23 COMMISSIONER GILINSKY:
I must say I feel the same 24 way, without having thought a great deal about it.
25 COMMISSIONEF BRADFORD:
The other point I would ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
73 1 make, if we are going to go ahead as of now, is on something 2 like this, when you are looking for immediate action, we 3 jcst have to have the package day in advance.
The problem 4 here isn't so much that the briefing has been inadequate.
5 The briefing has been perfectly fine, bt his is a hundred 24,_]f L
s.
+,1 6 and some pages long and I
.2 J.. : r - " ' y read it.
A 7
COMMISSIONER GILINSKY:
I'll second that too.
It 8 looks like a ver well written report and I want to commend 9 you on that, but it would have been good to have gotten it 10 soon er.
11 MR. STELLO:
I should take the rap for that.
That 12 is m y fault.
13 MR. DIRCKS:
On the other hand, you have a s
14 problem.
The Good Humor is out of the icebox.
15 COMMISSIONER BRADFORD:
But bringing it down here 16 is more like putting it back in.
17 (Laughter.)
18 CHAIRMAN AHEARNE:
I've been with your guys all 19 alon g, but let me say one th ing that irritated me is when I i
20 saw the Licensee was sent this on December 4 and we didn't f
21 get it until December 10, that caused me to be irritated.
l l
22 R.
STELLO:
That is what I was telling you. I 23 take the rap for that.
24 CHAIRMAN AHEARNE:
That got me.
I read reasonably 25 rapidly.
l l
l ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564-2345
74 i
1 COMMISSIONER C 1T'T"Y:
He is confident, but
- a is 2 not much smarter than the Licensees.
3 CHAIRMAN AHEARNE:
When I start reading at 12:30 4 or something, it did somewhat bother me that it was sent to 5 me so late.
6 COMMIESIONER BRADFORC:
When the Chairman gets b SM 7 so thing at 1 330 he ha a real nning start y "M2 8
MF. STELLO:
Let me at least defend myself.
I 9 don't know that I will do it very eloquently, but at least 10 le t me try.
I had severe reservations over whether we 11 should even send it, but I don't think the way to do that is 12 to send you very large reports, whether I send them a day 13 ahead or three days ahead.
I had some second and third 14 thoughts about whether I ought to or not.
15 It was more of a decision that I came to yesterday 1
16 that I thought it was useful to send this down to you before t
17 this meeting.
I didn't believe that that was necessarily l
18 the correct answer, but.at the end of the day I kind of 19 concluded that is where we were.
20 COMMISSI3NER GILINSKY:
Why didn't you send it to 21 us when you sent it to the Licensee?
22 MR. STELLO:
If you would like a copy of every 23 inspection report I send down --
'4'-
24 COMMISSIONER GILIN SKY:
25 inspection reports.
4 ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345
- j 75 yesterdayg I 1
MR. STELLO:
Which ones? I see>+-ene 2 decided this had a lot of visibility.
I hadn't done it.
It 3 was wrong, and I oucht to send it to you.
I came to that 4 conclusion yesterday.
5 CHAIRMAN AHEARNE:
I think we made our point. I 6 would conclude, then, that on balance, well, go ahead.
And 7 it was a very good briefing.
8 COMMISSIONEE ERADFORD:
It was a good briefing and
[7 9 as far as I know it is a good reportj 10 COMMISSIONER HENDRIE:
Before we quit, that 11 enforcement policy is out for comment, isn't it?
12 MR. STELLO:
That is correct.
13 CHAIRMAN AHEARNEs. And public meetings have been p
14 held in at least three cities.
15 MR. STELLO:
Four of the regions.
One more to go.
6 16 MR. FOU/HAED:
San Francisco is still to come.
17 COM ISSIONER HENDFIE:
There will come a time when Y
6 18 the comments will come back in end that will be a time for 4
4.r_f *- -
19 us to scratch our heads over he following.
Discover there 20 is something you found ut abo'+
plant operation.
This is s--
21 the problem that you ver- "- - ^ ' :.mug.
You have a plant A
22 operation that you don't quite like and they have been 23 turning left instead of right, or something like that, and 24 ve think they should have known enough to carry out a
(
25 procedure.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345 I
=
76 1
k' e discover they have been doing this for 200 days 2 and you find, gee, you could actually make a case that this, 3 together with some other things, maker a level 3. Then you l
7 4 say well, good, that is $8 million.
And you say, wait a 5 minute.
It doesn't have the right -- that is just too much 6 for this kind of a thing.
It is not a serious safety 7 deficiency, but, you know, we ha ve a zillion requiremento 8 out there.
Then you rcratch your head and say the way I am if 9 going to cure that is to deci re a gingle event.
M M 4 ^ :^ '
n o w i t[ _ _ _. t _1 f 6 -- I have a great 10 But 11 deal of trouble distinguishing that from a similar sort of 12 circurstance somewhere that we discovered after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> --
13 sa y $80,000 -- that's about the right thump.
14 The only difference between the two is that we 15 caught one after two or three days and we didn't catch the
[,
16 other until 200 days.
COMMISSIONER GILINSKY:
0: ;;_
..._m' 17 M WYEt U bn th:^o N~~ /A :&
9 h
18 R Z_
- "_ or 1 it^2 2
~
e 19 CHAIR AN AHEARNE:
Could I point out that we 20 closed this meeting to discuss the enforcement action, as we 21 should.
I think we are simply going away fron that.
MEISSIDFER HENDRIEs I just note sympathy with 22 23 the point)6 raised earlier, E _.
- does create a A
24 problem.
!(
(Laughter.)
25 f
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
m 77 1
COMP.ISSIONER BRADFORD:
You are sympathizing with 2 the wrong points, Joe.
3 CHAIRMAN AHEARNE:
The meeting is adjourned.
4
( k'hereupon, a t 4 :52 p.m.,
the meeting was 5 adjourned.)
6 7
8 9
10 11 12 f-13 14 15 16 17 18
(
19 20 21 I
22 23 l
24 i (
25 t
ALDERSON REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W, WASNINGTON. D.C. 20024 (202) 554-2346 1
1 l
NUCLEAR REGULATORY CO.WISSION l
i This is Oc certify that the attached proceedings before One i
in the matter Of: DISCUSSION OF INDIAN POINT ENFORCEMENT ACTION CLOSED -- EXCEPTION 7 Date of ?receecing:
December 10, 1980 Decket Nu=ber:
? lace of ?roceeding:
Washington, D.
C.
were held as herein appears, and that this is the original transcrip therecf for the file of the C==ission.,
Marilyn Shockey Official Reporter (Typed)
/
k0) thy
/
u Official Reporter (Signature) 9 i
J l
l
r MAJOR AREAS OF NONCOMPLIANCE o FAILURE TO PROMPTLY NOTIFY NRC 0F THE EVENT o FAILURE OF REQUIRED MANAGEMENT CONTROL SYSTEMS TO CAUSE EFFECTIVE EVALUATIONS AND CORRECTIVE MEASURES o FAILURE TO UTILIZE THE SHIFT TECHNICAL ADVISOR IN THE REQUIRED MANNER i
i i
_f
FAILURE TO PROMPTLY fiOTIFY THE fiRC o 10 CFR 50.72(a)
NOTIFY NRC OPERATING CENTER IF PLANT IS NOT IN A CONTROLLED OR EXPECTED CONDITION WHILE OPERATING OR S/D o TS 6.9.1.7.1 NOTIFY NRC WITHIN 24 HOURS OF ABNORMAL DEGRADATION IN PRIMARY CONTAINMENT o OCTOBER 17:
WATER IN REACTOR VESSEL PIT WATER ON VAPOR C0tlTAINMENT FLOOR STEAM EXITING INSTRLNENT THIMBLE HOLES MAJOR LEAKS IN FAN COOLER UNITS OCTOBER 20:
REPORTED WATER ON FLOOR TO RESIDENT INSPECTOR o LEVEL III o AMOUNT OF PENALTY S120,000 (40,000 x 3 DAYS) o REQUIRES COMMISSION APPROVAL (GREATER THAN LEVEL II) 4 4
FAILURE OF REQUIRED MANAGEftENT CONTROL SYSTEMS o TS 6.5.1.6 REQUIRES REVIEW 0F FACILITY OPERATIONS REACTOR WAS STARTED UP ON OCTOBER 20 WITHOUT THE REQUIRED REVIEW o TS 6.8.1 REQUIRES PROCEDURES NO SETPOINTS FOR CONTAINMENT SUMP PUMP OPERATION IN SURVEILLANCE TEST PROCEDURES NOT ESTABLISHED WHICH WOULD SATISFACTORILY DETECT REACTOR COOLANT SYSTEM LEAKAGE PROCEDURES NOT ESTABLISHED FOR CONTROLLING CONTAINMENT SUMP LEVEL TO A SPECIFIED RANGE PROCEDURES FOR DETERMINING WHEN MAINTENANCE CONSTITUTED A MODIFICATION WERE NOT ESTABLISHED o 10 CFR 50 APPENDIX B, REQUIRES THE QA PROGRAM TO PROVIDE CONTROL OVER ACTIVITIES AFFECTING QUALITY
- CAUSES OF MALFUNCTIONS (LEAKS) IN FAN COOLERS NOT PROMPTLY DETERMINED, EVALUATED AND CORRECTED EVALUATIONS OF REPAIR METHODOLOGY AND MATERIALS (EP0XY AND CLAMPS)
HERE NOT MADE FOR FAN COOLER REPAIRS
- QUALITY CONTROL INSPECTION REPORTS ARE NOT RESPONDED TO AND CLOSED OUT BY COGNIZANT ORGANIZATION IAW PLANT PROCEDURES
- DID NOT PROPERLY IDENTIFY FLEXIBLE HOSES ON FAN COOLERS AND, THEREFORE, REPLACED H0SES WITH WRONG MATERIALS (INCONEL VS STAINLESS STEEL) o LEVEL III o AMOUNT OF PENALTY $50,000 o 25% INCREASE OVER THE BASE C.P. PROPOSED BECAUSE OF THE EGREGIOUS NATURE 0F THE MATTER i
I l
i
FAILURE TO PROFERLY UTILIZE SHIFT TECHNICAL ADVISOR o NRC CONFIRMATORY ORDER DATED FEBRUARY 11, 1980 REQUIRED ESTABLISHMENT OF STA WITHIN 90 DAYS o NRC LETTER TO LICENSEES DATED SEPTEMBER 13, 1979, STATED THAT IN ORDER TO PROVIDE BOTH PERSPECTIVE IN AdSESSMENT OF PLANT CONDITIONS AND DEDICATION TO THE SAFETY OF THE PLANT, THE STA FUNCTION SHOULD HAVE A CLEAR MEASURE OF INDEPENDENCE FRDM DUTIES ASSOCIATED WITH THE COMMERCIAL OPERATION OF'THE PLANT o NUREG-0578 STATED THAT ADDITIONAL TECHNICAL AND ANALYTICAL CAPABILITY, DEDICATED TO CONCERN FOR SAFETY OF THE PLANT, NEEDS TO BE PROVIDED IN THE CONTROL ROOM TO SUPPORT THE DIAGNOSIS OF 0FF-NORMAL EVENTS AND ADVISE THE SHIFT SUPERVISOR ON ACTIONS TO TERMINATE OR MITIGATE THE CONSEQUENCES OF EVENTS (STA) o NRC LETTER TO LICENSEES DATED OCTOBER 30, 1979, STATED THAT IT IS NOT ACCEPTABLE TO ASSIGN A PERSON WHO IS NORiALLY THE IMMEDIATE SUPERVISOR OF THE SHIFT SUPERVISOR TO THE STA DUTIES.
ALTHOUGH SOME STA WERE AWARE THAT WATER WAS FOUND IN REACTOR VESSEL PIT, NONE HAD A FEEL FOR THE QUANTITY OF WATER OR SIGNIFICANCE OF WETTING THE R.V. OR INCORE INSTRUMENT CONDUITS, OR IMPLICATIONS REGARDING POTENTIAL BORON DILUTION OR SAFETY EQUIPMENT FLOODING.
NONE OF THE STA EVALUATED THE PROPRIETY OF RETURN TO POWER ON OCTOBER 17 OR 20
- STA ARE NOT ALWAYS CALLED TO CONTROL ROOM WHEN A PROBLEM IS IDENTIFIED THE CHIEF OPERATIONS ENGINEER ACTED AS STA ON THE 7 A.M. - 3 P.M. SHIFT ON OCTOBER 17 o LEVEL III o AMOUNT OF PENALTY $40,000 A
. - =. =...
OTHERS l
1 j
o TS 6.8.1 REQUIRES THAT PROCEDURES BE IMPLEMENTED ON OCTOBER 17 THE CONTROL POWER FUSES WERE PULLED FOR DEFECTIVE NI CHANNEL WITHOUT FIRST REDUCING POWER LEVEL TO 70% AS REQUIRED -
THIS RESULTED IN AUTOMATIC RUNBACK o LEVEL V o NO CIVIL PENALTY i
I l
l l
i i
l
\\
1 I
I
SUMMARY
OF ENFORCEMENT ACTIONS l
o FAILURE TO NOTIFY 120 K (40K x 3 DAYS) i o FAILURE OF MANAGEMENT CONTROLS 50 K (40K + 25%)
o STA UTILIZATION 40 g i
210 K
^
i IAL DATED 10/22/80 REQUIRES:
DETERMINATIONS REGARDING CAUSE REPORT RES 1TS OF DETERMINATION I
NRC CONCURRENCE PRIOR TO RESTART 1
i PUBLIC MEETING NOVEMBER 5 f
i 2
0
FAN COOLER FILTER UNIT (SIMPLIFIED)
AIR REclRCULATION I
['
AIR IHLET
=
{
f AIR OUTLET ROUGHlHG FILTER-f((
/
&\\
AIR FAN COOLING C0llS i
V
)
DEMISTER AIR OUTLET J'
ABSOLUTE FILTER X
FAN MOTOR COOLER HEAT EXCHANGER l
-CHARC0AL FILTER 1
(
',":':.::,2:.n.:..,
~
.i i i i i i i i i i i i i i i i i e i i i i i i ILt.LI l_I_1.1 I{
j flRC SUMitARY
~
~
~
~
~
~
~
~
~
TOTAL tlUltBER OF MWR'S ISSUED
~
~
~
~
FOR FAff COOLER UtlIT Afl0 RELATED SERVICE WATER PIPIllG LEAK
~
q.
- 1. _.;_
REPAIRS BY YEARLY QUARTERS'
~
~
~~~
~
~
~
~~
~
1 f^
g q
_ [
l L
~
gj r
i f
t2J s
a w
.l_
A t
t l
l ?
la-p p
1 ll1 l
ld I l g<
(
g l
l t
E a_
~ [
~
'.j
~
~
l
~
~
~
~
l
~
~
J I!
o
~. _
l.
l, -,i h'
1 il rn l
, j l
gg. 34 h
,1 P
i
(
t.,. [ht tj, e
\\
\\
i l
f l ll)
,i h
I a
j f
l l
_ _g h
jl C J
(lh,l [ 'd
! f C
?
4
)
h4 d
3dbC iMd@ Md
~
M UiMWi%.
~
~
~
~
^
W m
u m
m m
A 3
6 { { } }
{
~
~
~
~ ~~
~~
~
~
~
~
~
~
~
~
~
~
~
~
~
~
~
~
}
~
I
~
K p,
y
- y
~{.j] ]G{
- j ~,g-} {. ]g ff G i
w wo mwwc
- nkAu J
.. L
.l _,._.
... _ d _
A
l IND: AN PO!NT Ro.2 CONTAINMENT s
f (SIMPLIFIEDJ t
- sitat u!:=
STEAN EhERAIDR (10f 4)
)
t g
/7
%N
='
8 I
I:75)
I c,:n,,i -
2
,e
([
~5:
( I k*.:n s'gu s
-m neu n,.,
s.
s N\\
2m
/
l,ex,
/
oya f e e,
- c..m y :s,.tt yas~ein?
v.w - -
l (IW !)
EP.wil" t*sy e
-r
LT 941
'LT.940 SKETCH OF V.C. ELEVATIONS.
Figure 2 i-
[c.g..
_ IS'l 1) 0 57" N C""'" "- ~
~~
~~ '
(tst )
i-
~
1%1 1, NOMSEQra \\M PA2EMTMES25
. sgovv c 4 JNotcA7oa u%%
gi
(145-)
+
I N C E.747 P.A\\.
contact ?coM.
(r3y)
~
~
- 2. ALL MEA"; 42EMEMTS APE EEPE?.ENCED PROM THE BOTTDM oi: TWE SOMP PI't
~
.. _... g. y g g 3_g. Eniw w PoaP
. :$crornea ?onas, %.n, 'id
~
' :z in 1 so.
50Mp POMP
- ~.
ggp pupp
_-?
[........
- 101,
.y,y (yT) 7 7
- c..
3r.
x f f..........
. gn,
7
. (,99 I
9t s 1
\\
..Rtaa.s l
... Veda s...
.pg
[
u e.
s-
.w
. _9-h DN q.O
. -l (5g-)
qq) 4-y opp w, OFV e.
in1' cha rmQmtNT*
- 2-r-
e lY CD
_ l
!Su.y p,
(g )
a
....._.9..
- \\
/_
\\
t
'.t.
j I
e EXISTING C>ONTAINMENT SUMP AND REACTOR CAVITY l
I I
i j
REACTOR LEVEL INDICATOR \\ [SUNPPUMP (10F2)
EL 46'-0"
~
V(NOMINAL),,,_
j FLOATS 1
f..
3 1
7 PLATfD.C El.:8'-4" Ov0MINAL)
-2 REACTOR CAVITY t
i l
?_
SE0HE OF EVWIS (1)
IW1 GITAIKEIT DiBED TO REPAIR COOLIR fo. 25 10/3 GiTAlf!ER RifERED TO EPAIR C01ER l0. 21 ALSO LIFTED DE SitP PltP mRROL FLIAT #0 BOTH LEVEL. INDICATIfG FLQ4TS
~
AFTER DITRY REDUCTim IN R.IM OllT OF QUAlt!ThT 45" AND 51" LIGHTS ON IW14 -
INDICATION (WEIR LEVED OF LEAK IN (DOLER NO. 22
- f0 OFIRf% tim (PDISTlRE, Sil'P LFVEl., R0W OlR OF MRAlt!OIT, ND 0%%E WHEN ISOLATED S.W. T0 FD. 22) r
- ECLARED WEIR LEVEL INST. INOPERABLE 0
1
.n--
w-
-r
SEDEME CF EETS (2' 1CV17 1015RE IN N42 BER RGE IUQ. EAR DETECTOR (CALSE NOT EM ATTIfO
- CAUSED ERPATIC It01 CATIONS
- OPEPATOR ACTIONS CAUSED TRIP (4:18 A.M.)
1 ESTARL' BUT TEQUICIANS GEOGNG N42 CAUSED SECD0 TRIP (8:47 A.M.)
BEGkN ESTARL BLTT ECIED TO EPLAE N42 SHJTD0lel (STILL HDD EhTEED CCNTAltifNT G2:20 P.M.)
- DISOMRED 4" MTER W %' R00R SLES8 TENT ENIRY, APPR0XIMTE 6 P.M., WATER DISCOERED IN CAVITY.
10/18-10/19 PlFFED CCHTAlife!T #0 CAVITY 10/20 BEGAN ESTART PROEDURE (s 6:00 A.M.)
~
- SHlHDM TO INVESTIGATE FURTER (8:30 A.M.)
- ESIIENT INSRCTOR TOL.D (11:30 A.M.)
T STRESS ANALYSIS MODEL VESSEL BOTTOM HEAD DURING FLOOD INCIDENT l
ap_
. _j,__
VESSR BARREL POSTULATED WATER f CLADDING-N T'-2i[ RADIUS L
8[
.EL 42'- 11.688*
__ EL42'-3ff CORE BARREL
'N
's
(,_
'xN l'-5'
. EL 40'- 8.937' REACTOR VESSEL s,
N+
V xN T'-4f RADIUS
. 8' - 5 AT6' 9
OPERATING PRESSURE
/
2235 PSI
\\
55
.EL 36'-4.068*
y TYPICAL INSTRUMENTATION
.EL 34'-lL622' s
/
._ _ _.-_ EL 3 4' -0'
[Hi[
VESSEL LOWER HEAD (ENLARGED DETAIU c