ML20080J232
| ML20080J232 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/21/1983 |
| From: | KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, METROPOLITAN EDISON CO. |
| To: | |
| Shared Package | |
| ML20080J220 | List: |
| References | |
| NUDOCS 8309260261 | |
| Download: ML20080J232 (77) | |
Text
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.a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 g
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'd GPU RESPONSE TO "TMIA INTERIM COMMENTS ON B&W TRIAL RECORD" September 21, 1983 9309260261 830922 PDR ADOCK 05000289 0
e TABLE OF CONTENTS Introduction...........................................
1 April 23, 1978 Overcooling Event.......................
2 PORV Problems..........................................
11 PORV Maintenance..................................
11 PORV Indicator Light..............................
14 Tailpipe Temperatures Analysis....................
16 Alleged Leak Rate Falsification...................
21 Hartman Cross-Examination.........................
22 Condensate Polishers...................................
24 Water in Air Line.................................
26 The Keaten Task Force..................................
28 Maintenance................................
39 Maintenance Budget and Staffing...................
40 Maintenance Staffing.........................
41 Budget Cuts....................
42 Repair Parts......................................
43 Paperwork.........................................
45 Overtime..........................................
45 Daniel Shov1in....................................
46 Training...............................................
54 Richard Zechman...................................
57 The Book Letter...................................
59 Management Structure..............................
62 Managers..........................................
62
3 LICENSEE RESPONSE TO "TMIA INTERIM COMMENTS ON B&W TRIAL RECORD" Introduction TMI ALERT filed on July 1, 1983 its "TMIA Interim Comments on B&W Trial Record" (TMIA Comments).
As demonstrat-ed in detail below, the TMIA Comments distort the trial record and repeatedly mischaracterize both the oral testimony and documentary exhibits.
The TMIA Comments are divided into two main sections in which TMIA purports to show that (1) "the B&W record sup-ports the argument that the Licensee is inherently incapable of learning f rom past mistakes or correcting recognized prob-lems"; and (2) "the B&W record, read in light of other new in-formation which has come to light reflecting on Licensee's management, fundamentally undermines the credibility of the ASLB decision, and the PIDs cannot be used to lawfully justify restart of TMI-1."
The TMIA Comments fail to establish either of these propositions.
When analyzed, the Comments prove to be primarily a collection of unsupported and unsupportable as-sertions or misstatements about the facts regarding past GPU Service Corporation and Met-Ed (TMI 1 and 2 Licensee at the time) actions which fail to sustain TMIA's arguments that Unit l
I should not be restarted and that the ASLB decision should be overturned.
i I
l l
l 1
April 23, 1978 Overcooling Event In the first section of the TMIA Comments (after the introduction), TMIA argues that some of the B&W trial evidence showed that Licensee was " incapable of learning from past mis-takes."
(Comments, p. 4.)
Its first purported example is the April 23, 1978 overcooling event at TMI-2.
This is an inci-dent which occurred when the main steam safety valves on the t
l secondary side of Unit 2 failed to reclose following a reactor
~
l trip.
The resulting loss of energy from the secondary side caused the temperature and pressure to drop in the reactor l
coolant system.
This was a fundamentally different transient from the Unit 2 accident where the pilot-operated relief valve (PORV) on the primary side pressurizer failed to close result-I ing in a loss of coolant accident.
In contrast to the March 1979 accident, there was no steam or water release from the primary side of the unit during the April 23, 1978 event.
The TMIA Comments' position is that management per-sonnel currently with GPU Nuclear and who were with Met-Ed or GPUSC in April 1978, failed to adequately analyze and respond to that plant event.
They endeavor to support that assertion with discussions on three primary points:
1.
The event showed pressurizer level could in-crease while pressure was decreasing and "because Licens-ee presumably failed to attach significance to th'is as-pect of the transient (see, e.g., Keaton dep. at 225), it did not bother to modify emergency procedures or training i
2
to instruct operators what to do in the event the system experienced the condition again."
(Comments, p. 7);
2.
Neither Robert Arnold (President of GPU Nuclear Corporation, and then Vice President-Generation, GPU Ser-vice Corporation) nor John Herbein (then Met-Ed Vice President-Generation' but no longer with GPU Nuclear)
" learned the most fundamental lesson from the event."
(~omments, p. 7); and C
3.
" Operators were extremely confused by the number of alarms which went off at the time of the event" and the response by Met-Ed and GPUSC was unsatisfactory.
(Comments, pp. 7-8.)
Assessing each of these specif!c issues requires an understanding of the response that management did make to the April 23 event.
As indicated by the TMIA Comments (p. 7),
management at the time " considered the event very signifi-cant."
A special task force was set up and chartered to con-duct an extensive review and analysis of the event.
(See Ap-pendix A, attached, Memorandum from R.C. Arnold to R.W. Kea-ten, Re:
TMI 2 Cooldown Transient of April 23, 1978, May 2, 1978.)
As can be seen from Appendix A, the charter was very comprehensive and called for a thorough and objective effort by appropriate technical personnel.
Because of the work al-ready completed or underway, the task force was able by May 9, 1978 to make twenty-three (23) specific and substantive recom-mendations to reflect lessons learned from the event.
The 3
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't recommendations were given priorities according to categories:
prior to restart, near term and long term.
All were included in the final task force report, as was an additional recommen-dation for more extensive post-trip monitoring capability.
(GPU Service Technical Data Report TDR No. 001, B&W Ex. 186.)
(The latter recommendation in fact resulted in the addition of equipment which provided much of the data utilized for analy-sis of the TMI-2 accident.)
A complete review of the record shows that management's response to the April 23, 1978 event j
I was thorough and professional.
That is not to say that one cannot go back to that event and find the footprints of other i
lessons since obtained from subsequent events.
However, the management' competence issue is whether a responsible and tech-nically competent effort was made to learn from the April 23 event and to utilize those lessons to improve safety, not
.whether 20-10 hindsight can identify traces of other insights that might have been gained if the organization had recognized the significance of relatively obscure peripheral details.
Regarding the first point, both before and after the April 23 event, B&W instructed users that.the pressurizer's water level was the appropriate and accurate ind cator of wa-ter inventory in the reactor coolant system (Lind trial tr.
5227-28;. Frederick trial tr. 4022-4023; GPU Ex. 2347, pp. 61, 74; Marzec trial t<:. 6398-99).
Throughout the April 23, 1978 event, the water level in the pressurizer in fact continued to be a reasonable -- though possibly not perfect -- indicator of 4
~
the volume of water in the reactor coolant system and in fact 1
dictated correct operator action.
Scrutiny of this overcool-ing event by not only Met-Ed and GPUSC but also by the NRC and l
B&W, failed to produce any suggestion that the pressurizer should be abandoned as a guide to water inventory in the reac-tor coolant system.
During the April 23 event, the operators monitored pressurizer level and regulated high pressure injection in ac-cordance with their training and plant procedures with no del-i.
eterious effects.
As pressure and pressurizer level fell, an operator promptly (43 seconds after the reactor trip) started a second makeup pump and increased make-up flow through the high pressure injection flow path.
At one (1) minute, eleven (11) seconds after the trip, high pressure injection was auco-matically initiated and full high pressure injection flow would have been established if it had not already been accom-plished as a result of prompt operator action.
Pressurizer level had by then dropped below the range of level indication.
I At two (2) minutes and thirty (30) seconds into the event, about twenty (20) seconds after pressurizer level was back in the indicating range and thirty (30) seconds before pressure started to increase, the operator began to reduce the flow of high pressure injection pursuant to his training and proce-dures.
For this event, the operator's manipulation of high i
pressure injection was accepted as appropriate by all who re-i 5
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viewed the event including B&W.
Thus, the existing procedures and training had directed a correct operator response.
B&W analyzed the April 23 event extensively, specif-ically commented favorably on the operator's handling of the high pressure injection system (B&W Ex. 186, TDR 001, p. A4-3) and attached a graph showing the points where the high pres-sure injection was initiated and throttled on April 23 in the same manner as would be done eleven (11) months later, on March 28, 1979.
Thus, the April 23, 1978 event, far from be-ing an event that should have alerted GPU to improper proce-dures or operator action, was instead an event that appeared to confirm the appropriateness of existing training and proce-dures.
Subsequent to April 1978, both the NRC and B&W ana-lyzed a number of different overcooling events at various plants, including the April 23 event at TMI-2.
On February 14, 1979, the NRC convened a meeting at B&W's Lynchburg head-quarters specifically to address the issue of pressurizer lev-el indication.
In attendance were several top technical peo-ple from B&W, including Bert Dunn (author of the B&W internal memorandum which stated that the Davis-Besse event showed that I
training and procedures for LOCA's were incorrect) and also representatives of Met-Ed and other owners of B&W plants.
Mr.
J. E. Foster of the NRC, who conducted the conference, " stated that as far as he was concerned loss of pressurizer level in-dication was merely an operational inconvenience and the loss 6
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^
of pressurizer level was not a safety concern.
He was recom-i mending that this issue be closed."
(GPU Trial Ex. 84, inter-nal B&W memorandum, March 9, 1979.)
When asked about his i
failure to express any safety concerns at this meeting, Bert Dunn stated that the issue of loss of pressurizer level in these overcooling events was a separate issue from his concern j
that operators would secure HPI based on misleadingly high pressurizer level indications during a loss of coolant acci-l dent (Dunn NRC Special Inquiry Group Deposition, 10/4/79, pp.
63-64).
Thus, both the NRC and B&W concluded that overcool-ing events such as the April 23, 1978 event did not produce any significant revelations and therefore the existing proce-dures did not need to be revised.
In iight of these analyses performed by engineers from several different organizations, TMIA's assertion that Met-Ed and GPU Service Corp. should have recognized the need to revise its pr,ocedures for loss of cool-ant accidents after the April 23 overcooling event is simply not supportable.
The TMIA Comments state at pages 6-7 that during the April 23 event, the pressurizer level increased while pressure dropped, a " condition.
. plainly not contemplated by.
l procedures or training."
However, as pointed out above, no one -- including the NRC or B&W -- deduced anything of signif-icance from the very brief period, of no more than a minute's duration, when pressurizer level turned upward slightly in ad-i 7
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vance of pressure also turning upward.
A review of the graph attached to the B&W analysis of the April 23 event (B&W 186, TDR 001, p. A4-4) reveals that pressure and pressurizer level did trend in the same direction during that event, as expect-ed.
The high pressure injection flow added water and caused pressurizer level to increase.
The fact that an increase in pressure followed less than a minute later rather than simul-taneously did not appear to the NRC, B&W or GPU to undermine i
the then current understanding that pressure and pressurizer level would trend together during a LOCA.
Indeed, the minimal delay in the recovery of pressure during the April 23 over-cooling event -- a delay so slight that it would not even have been discernible on the control room recorder chart and which resulted in no incorrect action on the part of the operators
-- is an entirely different phenomenon than a susta?,aed low pressure condition in conjunction with a high pressurizer lev-el such as occurs during a LOCA at the top of the pressurizer.
TMIA's own comments show responsible action by man-agement in responding to the April 23 event.
As TMIA points i
out, GPUSC considered the April 23 event significant and formed a task force to study the event and to supplement a Met-Ed report on the transient (Comments, p. 7).
These ef-forts by GPUSC and Met-Ed management to assess the overcooling event demonstrate the importance which management placed on l
I learning from prior transients and illustrate the steps which it took to respond to significant plant events.
8 L
~~
TMIA's assertion that GPU Service Corp. did not re-port technical specification violations occurring on April 23 to the NRC (Comments, p. 10) is misleading.
The Metropolitan Edison Company had reported April 23 technical specification violations to the NRC (L.E.R. #78-33, May 8, 1978; L.E.R.
- 78-34, May 8, 1978).
The citations from the B&W record by the TMIA Com-ments do not support its second point -- that neither Arnold nor Herbein to this day have learned "the most fundamental lesson from the event."
TMIA states:
"And Arnold still maintains in testimony that '(a)ny time we were identifying a loss of coolant accident,
. the pres-surizer level and pressure would both trend together' Thus, not only did the President of the company fail to learn the most important lesson from the April 23 transient
. he failed to learn the very same lesson from the acci-dent itself.
This perhaps says more about the Licensee's fundamental inability to learn from the past
. than any other single incident in this trial record."
(Comments, pp. 7-8, emphasis in original.)
TMIA has misread Arnold's testimony, attempting with the words "still maintains in testimony" to make it appear that Arnold 'still" believes that pressure and pressurizer level trend together during all loss of coolant accidents.
The entire context of the testimo-ny quoted by TMIA indicates that Arnold was referring only to his pre-a'ccident understanding -- which was consistent with the understanding of the industry generally.
(See, e.g., GPU i
Ex. 132, B&W internal memorandum.)
9 i
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i The third point associated with the April 23 event 4
that is identified in the TMIA Comments concerns management action regarding control room alarms.
TMIA states that during the April 23 event and during the Three Mile Island accident, operators were confused by the number of alarms (Comments,
- p. 8).
TMIA alleges (p. 9) that an alarm window correction program, recommended after the April 23 event, was never put into effect.
TMIA correctly asserts.that an alarm window correc-tion program had been recommended; but it incorrectly asserts that the alarm window correction program was " explicitly dis-approved by Met-Ed corporation management, B&W 767, and thus i
never put into-effect."
(p. 9.)
The only cited reference for this. assertion is B&W Ex. 767, which' concerns the PORV indica-tor light and has nothing to do with the alarm upgrade pro-gram.
Indeed, testimony established that the alarm upgrade program was put into effect and that it remained in effect, as an ongoing project, up to the day of the accident (Zewe dep.
845; Zewe trial tr. 2180-82; Frederick trial tr. 3567-68; GPU Ex. 2067).
TMIA does not support its assertion (p. 8) that op-erators, during the 1979 accident, were " extremely confused" 1
by the number of alarms that went off during the accident.
Mr. Zewe did testify that the sheer number of alarms present on the day of the accident may have interfered with his abili-ty to prioritize available information (Rogovin dep. 177-78, 1
l 10 l
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9/11/79).
However, the presence of a large number of control room alarms during a major transient was the norm rather than the exception in power plant control rooms prior to the acci-i dent, and operators received training at the B&W simulator as to how to systematically analyze large numbers of alarms.
Thus, Mr. Frederick specifically testified that he had been trained by B&W to analyze large groups of alarms and so had not been confused by the alarms present on the day of the ac-cident (Frederick trial tr. 3278-79, 3568-69, 3224-25, 3271-72).
PORV Problems In its section entitled "PORV Problems" (p. 11),
TMIA jumbles together a number of loosely related assertions.
The gist of TMIA's allegations appears to be that the PORV was poorly maintained, that the PORV was leaking before the acci-dent, that management purposely ignored this alleged leakage, and that operators falsified leak rate data in order to keep the plant on line.
As described below, TMIA's citations to the trial record fail to support these propositions and, in-deed, ignore the substantial body of contrary evidence.
PORV Maintenance TMIA states at page 11 of its Comments that the PORV had a history of problems.
Thus, TMIA points out that the PORV experienced some leakage in 1977.
However, as the Com-ments also note, the valve was repaired and the leakage cor-I rected (Comments, p. 12).
Indeed, Sieglitz specifically tes-11 i
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.o tified that the valve was removed, sent to the TMI machine shop where mechanical " lapping" was performed, tested, and confirmed to be satisfactory (Sieglitz trial tr. 5764-65).
As is discussed further below (pages 16-21), although there was some mention of PORV leakage in post-accident interviews -- at a time when attention was very much focused on the PORV --
there is no scientific evidence of PORV leakage after the 1977 repair of the PORV and before the day of the accident.
To the contrary, the evidence reveals that a code safety valve rather than the PORV was leaking.
The TMIA Comments also note that the Unit 2 PORV had at one time been installed at Unit 1 (Comments, p. 11).
TMIA fails to mention Met-Ed's action in sending the valve back to its manufacturer, Dresser, to be refurbished and retested af-ter this initial use at Unit 1 (Technical Data Report No. 160
("TDR 160"), PORV Investigation by Q. Billingsley and J. Cor-rea, 7/8/80, p. 14, B&W Ex. 456).
This action by Met-Ed and the valve manufacturer indicates, as does the 1977 repair of PORV leakage, continued responsible activity by Met-Ed with regard to PORV maintenance.
TMIA further states, at page 11, that the difference in' voltage at Unit ] and Unit 2 m.y have damaged the PORV.
TMIA asserts, as if it were'an established fact, the possibil-ity raised in a GPU technical data report (TDR 160 at p. 10) that the PORV may have been damaged by operation at a higher voltage than it was designed for during its temporary instal-12 i
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lation in Unit 1.
It is speculative as to whether a higher voltage supply to the Unit 2 PORV harmed the PORV.
- Moreover, as is discussed above, after its use at Unit 1 and prior to its reinstallation at Unit 2, the PORV was completely over-hauled and tested for any problems by its manufacturse, Dress-er Industries.
It was returned to the site in "like new" con-dition and in conformance with the technical and quality as-surance requirements imposed on the original purchase order for the valve (TDR 160, Appendices 5 & 6, B&W Ex. 456 at pp.
11353, 11355).
Thus, even if there had been any damage as a result of the temporary installation of the valve on Unit 1, the return of the complete valve, including the solenoid, to Dresser Industries should have resolved any such problem.
The TMIA Comments also assert (p. 11) that the al-leged difference in voltage was "never believed significant enough" to warrant discussion at the plan of the day meetings.
However, in the testimony of Mr. Sieglitz cited in s'upport of this proposition, Sieglitz merely agreed with the questioner that the issue of different voltages had not arisen in his presence at plan of the day meetings.
TMIA also contends (pp. 12-13) that the frequent cy-cling of the PORV could have had an adverse effect on PORV re-liability.
The cited Keaten testimony does not support that proposition.
Moreover, even if in theory the frequent cycling of a valve can damage a valve, there is no evidence that the cycling of the Unit 2 PORV during the April 23 event in fact i
13 l
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s caused damage of any kind.
The PORV functioned normally dur-ing several subsequent Unit 2 events prior to the accident and, as is discussed below (pages 16-20), there is no convinc-ing evidence that there was leakage through the PORV following that event.
PORV Indicator Light The TMIA Comments allege (p. 12) that a "better" PORV indicator light was requested in 1978 and that this re-quest was denied by Met-Ed corporate engineering.
TMIA tries to create the impression that Sieglitz had recommended a change in the PORV light and that " corporate engineering" had rejected the request out of hand, shortly before the accident.
This assertion is substantially misleading.
The PORV position indication instrumentation which was added to the Unit 2 control room following a March, 1978 event had been installed only after review by several engi-neers within B&W's Lynchburg headquarters (GPU Ex. 368; Rogers trial tr. 5462-72) and was wired to the PORV solenoid.
A mod-ification of the position indication mechanism to employ a limit switch was proposed within Met-Ed in December, 1978 as a result of PORV testing (referred to as an " incident" in the TMIA comments, p. 12).
As Sieglitz testified, an engineering decision was made to reject the proposed modification because it was not a better alternative (Sieglitz trial tr. 5804).
Richard Noll, an engineer in the Met-Ed Generation Engineering 4
Department, carefully reviewed the proposed modification, 14
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spoke with other engineers regarding the proposal, and con-cluded that the modification was not an improvement over the existing PORV position indication mechanism (Seiglitz trial tr. 5804; Noll dep. 92-93, 96; B&W Ex. 767).
Thus, the change was not effected.
TMIA further misrepresents the nature of the deci-sion regarding the proposed change in the PORV indicator light by implying that Sieglitz made a request'for o'perator training on the proposed modification and that that request was turned down.
In fact, the change request submitted to Sieglitz sim-ply indicated that if a change to the PORV light were made, the operators should be trained on the modification (Sieglitz trial tr. 5799-5803; B&W Ex. 767, p. 4).
As Gary Miller tes-
~
tified, operators were trained on virtually all plant modifi-cations (Miller dep. 298).
Since the accident, and as a result of the Lessons Learned from the accident, the TMI-1 control room has been up-graded by installing devices which measure flow past the PORV and the pressurizer code safety valves -- an approach prefera-ble to either the prior indication or the December, 1978 pro-posed indication.
15
~:....
Tailpipe Temperatures Analysis In a somewhat garbled discussion of the tailpipe temperatures (Comments, pp. 12-18), TMIA appears to conclude that simply because the PORV tailpipe temperatures were ap-proximately 180* prior to the accident, (a) the PORV must have been leaking and (b) Met-Ed, and S'ieglitz in particular, were negligent for not investigating and repairing this alleged leakage.
A brief summary of the trial recorc regarding leak-age from valves at the top of the pressurizer indicates that Met-Ed engineers reasonably determined before the accident that a code safety valve and not the PORV was leaking before the accident.
This was confirmed after the accident by GPUSC engineers.
A further elaboration of this information may be found at pages 34-37 of the Licensee's response to the NRC no-tice of violation, B&W Ex. 707.
The testimony of Sieglitz and others establishes that leak rates and tailpipe temperatures were routinely moni-tored prior to the accident (Sieglitz trial tr. 5719-20, 5746; Zewe trial tr. 2847-48; GPU Exs. 2095 and 2096).
For months I
prior to January 1979, temperatures on the PORV tailpipe had been consistently running in the 180 range (Sieglitz trial tr. 5746-47; GPU Exs. 2095 and 2096).
During this period, there was minimal leakage from the reactor uoolant system (Sieglitz trial tr. 5746-47; Ex. 2095).
16 i
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The fact that only minimal leakage existed for months while the PORV tailpipe temperature was in the 180*
range confirmed that a 180* temperature was normal for the PORV discharge pipe on Unit 2.
The 180* reading was also con-sistent with the configuration of the PORV thermocouples in relation to the pressurizer and other hot equipment in the same area of the containment building (Sieglitz trial tr.
5734-38, 5747).
Thus, the persistence of a 180* temperature while there was no significant identified leakage meant that 180* was not an indication of PORV leakage (Sieglitz trial tr.
5809).1 Following a two-week outage at TMI-2 in January, 1979, there was simultaneously a marked increase in the iden-tified leakage and in the temperature of the code safety valve discharge pipes.
As the TMIA Comments indicate (p. 14), after that outage, the code safety valve discharge pipe temperatures jumped to 200* from a previous range of 110* to 120*.
There was a prompt discussion of this temperature rise at plan of the day meetings (Sieglitz trial tr. 5713, 5719-23).
In light of the sudden appearance of significant identified leakage and 1
The leak rate involved here is the " identified" leak rate and not the " unidentified" leak rate which was the main focus of allegations by Harold Hartman.
See p. 21, in-fra.
All leakage going past either the P5RV or pressur-izer code safety valve seats was collected in the Reactor Coolant Drain Tank and measured.
Thus, such valve leak-age has no direct relationship to the " unidentified" leak rate.
17
elevated temperatures on the code safety valves, it was deter-mined that the higher temperatures and leakage were caused by a leaking code safety valve (Sieglitz trial tr. 5716, 5719-23; Exs. 2230, 2231, 2232, 2233).
As a result of the determination that a code safety valve was leaking, a repair ticket was written for a code safety valve (Sieglitz 5739; Ex. 2072) and repair of a code safety valve was placed on the list of work to be completed during the next outage (Sieglitz trial tr. 5471; Ex. 2086).
The valve leakage through the code safety valve, as measured at the time and confirmed after the accident, never reached the point where the plant was required to shut down pursuant to the technical specification limit on identified leakage.
GPU management was certainly ready and willing to repair any pressurizer valve if necessary.
This is illustrat-ed by the fact that other valves on the pressurizer (isola-tion, or " root" valves for the level transmitters) were, in fact, repaired during the January,1979 outage (Sieglitz trial tr. 5747-49; Zewe trial tr. 2832-34; Ex. 2092) and that, when a code safety valve started to leak after the January outage, that valve was promptly scheduled for replacement.
In summary, as was concluded by post-accident stud-ies of the issue, the evidence available to and appropriately assessed by Met-Ed personnel indicated that a code safety valve, not the PORV, began to leak after the January 1979 out-age (TDR 160, pp. 1, 17, 20; TDR 126, Investigation of TMI-2 18 I
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Pressurizer PORV Discharge Pipe Temperatures, 2/28/80, pp. Ib, 12).
TMIA's apparent arguments to the contrary are based on little more than a characterization of the 180* PORV tailpipe temperature as an " elevated temperature," and on various mis-characterizations of testimony, discussed below.
Furthermore, contrary to TMIA's assertions (Comments, p. 13), emergency procedures did not require closure of the PORV block valve prior to the accident to check for leakage as a result of the high PORV tailpipe temperatures.
The procedure pertaining to PORV leakage to which TMIA refers never became applicable be-cause it had been appropriately determined that the PORV was not in fact leaking.
A further discussion of this issue may be found at pages 34-36 of the Licensee's response to the NRC notice of violation, B&W Ex. 707.
The section of the TMIA Comments on valve leakage contains the type of mischaracterizations of testimony that are found throughout the Comments.
For example, TMIA states, at p. 13, in italics, that "no leak rate was being monitored,"
citing as support Sieglitz trial tr. 5811., However, at the page cited by TMIA, Mr. Sieglitz testified that "no leak rate l
was being monitored back to that area" meaning, as Mr. Sieg-litz explained during his testimony, that it had been deter-mined that there was no leakage from the PORV ("that area")
i (Sieglitz trial tr. 5896).
Mr. Sieglitz did not testify that leak rates were not monitored.
Indeed, he expressly described l
19 l
the review of leak rate reports at the plan of the day meet-ings (Sieglitz trial tr. 5715-21).
TMIh also states (p. 13) that Sieglitz was "so igno-rant of the situation that he did not know that 180' was even an elevated temperature, claiming that it was not his iob to know such details," citing Sieglitz trial tr. 5809-10.
In fact, Sieglitz testified that when he looked at the leak rate and at the 180* temperatures and saw that there was no signif-icant identified leakage, he and others concluded that the 180' temperature was normal (Sieglitz trial tr. 5809, 5816).
Mr. Sieglitz did testify that his job responsibilities, which pertained to the maintenance of equipment and not to opera-tions, did not require familiarity with the details of a plant operating procedure which referenced PORV tailpipe tempera-cures (Sieglitz trial tr. 5809-10).
TMIA goes on to state (p. 13), citing Sieglitz trial tr. 5815, 5817, 5844, that because Sieglitz "never thought to ask" if 180' could signify leakage, "these high temperatures were thus never discussed at plan of the day meetings.'"
However, contrary to the implication of TMIA, Sieglitz did not give this testimony regarding plan of the day meetings in re-sponse to a question about whether he "never thought to ask if 180
. could signify leakage" (Commente, p. 13).
In fact, Sieglitz testified that the 180' PORV temperature was not dis-
]
cussed prior to the January, 1979 outage because it was known, 20 4
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based on leak rate data, that there was no significant identi-fled leakage (Sieglitz trial tr. 5815-16).
Alleged Leak Rate Falsification Repeatedly in its discussion of alleged PORV leak-age, TMIA refers to Hartman's allegations that tests for un-identified leak rate were falsified (Comments, pp. 11, 14, and 16-17).
TMIA's citations fail to establish either that leak rates were falsified or that GPU management knew of any pur-ported falsification.
The allegations that leak rate test results were falsified or " fudged" originated with Harold Hartman, who was a control room operator at Three Mile Island prior to the ac-cident.2 Hartman, during cross-examination under oath at his GPU v. B&W deposition, substantially limited his allegations regarding leak rate testing falsification.
As a result, the implications of his earlier accusations were seriously, if not totally, undermined.
It is therefore remarkable that TMIA (p. 14) relies on Hartman for the proposition that every shift supervisor and shift foreman knew that leak rates were being falsified, citing only Hartman's speculation ("I thought that it was just the fact that everyone knew that these leak rates were hard to get
").
Hartman's cross-examination re-vealed that Hartman could not identify with certainty a single 2
Hartman was discharged by Met-Ed shortly after the acci-dent.
Only after his discharge did he make the allega-tior.s regarding leak rate falsification.
21
_ _ _ _ ' ~ ~; J _ - _,, _ _.. _ _ _
operator other than himself who had attempted to falsify leak rate tests -- a marked change from his earlier allegations..
The results of the Hartman cross-examination are summarized below.
Hartman Cross-Examination Operators routinely add both hydrogen and water to the makeup tank for legitimate reasons (Hartman dep. 263, 261).
However, if water is added during a leak rate test, the addition must be " logged," so that the test results will take that water into account.
Hartman, at his sworn deposition, admitted that he had seen only one operator add water during a leak rate test (id, at 260-61).
Hartman also admitted that although it was his belief that the operator had added the wa-ter in order to affect test results, he had not looked to see whether the operator in question had logged the addition of water (id. at 261-62).
Hartman testified that he personally had never added water to the makeup tank in order to affect test results (id. at 260).
Hartman believed that adding hydrogen to the makeup tank during a leak L3te test would result in inaccurate test results.
In his deposition, Hartman repeated his assertion that he personally had added hydrogen in an attempt to influ-ence leak rate test results.
However, on cross-examination he admitted that he had no recollection of seeing anyone else add hydrogen in order to affect a leak rate test (id at 274).
He also admitted that operators were not required to record hy-22 4
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drogen additions made during leak rate tests and that he did not know whether hydrogen additions had ever in fact affected leak rate test results (id. at 264, 272-74).
Thus, Hartman's cross-examination revealed that the only attempted manipulation of a leak rate test result to which he could testify with certainty was his own occasional attempt to affect results by the addition of hydrogen.
Other than TMIA's misleading citations to Hartman's testimony, the only support cited for the contention that op-erators were " fudging" leak rates is the Faegre & Benson re-port.
That review of the Hartman allegations was prepared by outside concultants at the request of Metropolitan Edison.
TMIA cites page 17 [vol. 1] of the Faegre & Benson report for the proposition that operators were "' fudging [ leak rates) continuously" in order to keep the plant on line (Comments,
- p. 16).
However, at the cited page, Faegre & Benson recog-nized only that in the three months preceding the accident the rate of leakage from one of the pressurizer relief valves was increasing.
Faegre & Benson did conclude that that increase in identified leakage may have made it more difficult to ob-tain an accurate unidentified leak rate figure, because of the way the leak rate test computer program was designed (Faegre &
Benson, vol. 1, p. 26).
However, the Faegre & Benson report nowhere endorses, on page 17 or elsewhere, the proposition Eor which it is cited by TMIA.
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Condensate Polishers i
The third topic raised by the Comments (pp. 19-20) concerns the Unit 2 condensate polishers and the failure of GPU to install an automatic bypass valve on these polishers.
TMIA cites no technical authority whatever to establish the advisability of such a bypass.
Moreover, the Comments ignore the fact that management gave serious consideration to the suggestion to add a bypass and rejected the idea for sound en-gineering reasons (Toole dep. 446-47).
Mr. Zewe's suggestion, in the handwritten memorandum referred to by TMIA (Comments, p. 19), that an automatic by-pass be installed on Unit 2 was the result of familiarity with a bypass at Unit 1 (Zewe trial tr. 2202; Toole dep. 446; Ross-dep. 113-14).
However, the condensate polisher system on Unit 1 is significantly different from the type of system on Unit i
2.
The Unit 1 system consists of filters embedded with a com-pound called Powdex which causes impurities in the secondary-side water to coagulate and stick to the filters; the Unit 2 deep-bed demineralizer system used ionic resins to remove im-purities.
Unit 1 had to have an automatic bypass valve in or-der to protect the Powdex filters from damage (Toole dep.
396).
As shown by the testimony of Ronald Toole, a GPUSC startup and test engineer, protecting the Powdex filters from high differential pressure was the sole design use and func-tion of the automatic bypass valve on Unit 1 (Toole dep. 400).
l 24
~.
The Unit 2 deep-bed demineralizers did not require protection from high differential pressure; thus, they did not need an automatic bypass valve (Toole dep. 447).
Any bypass of the condensate polishing system on Unit 2 would have degraded secondary-side water purity, and was, therefore, viewed by GPU, B&W, and Burns & Roe (the ar-chitect engineer) as inadvisable (Arnold trial tr. 1502; Toole dep. 447).
In fact, B&W specifically advised against bypass-ing the condensate polishing system.
During a May, 1978 B&W User's Group meeting, B&W reviewed Unit l's condensate polish-ing system operating experience and stressed the importance of maintaining secondary water purity to avoid damage to the steam generators.
As summarized in the meeting minutes, B&W concluded with the imperative that the condensate polishers should "never" be bypassed (GPU Ex. 2031, p. 3, emphasis in original; GPU Ex. 2028, p. 5; O'Hanlon trial tr. 1067; Toole dep. 320-21; 452; Ross dep. 95-96).
Moreover, an automatic bypass would probably not have functioned rapidly enough to prevent an isolation of the condensate polishers from inducing a feedwater trip (Miller dep. 783; Zewe trial tr. 2202; 2209-10; Toole dep. 448).
As discussed above, the bypass on the Unit 1 Powdex system had not been designed to prevent a feedwater trip, nor had it been tested to determine its ability to do so.
i 25
._.....m
Water in Air Line Not only are the Comments misleading with respect to the purported need for an automatic bypass on Unit 2, but TMIA goes on to assert, incorrectly, that nothing was done to rec-tify the problem of water getting into the instrument air lines of the condensate polisher system (Comments, p. 19).
In response to a 1977 startup and test event when water got into the instrument air lines, Michael Ross, a shift supervisor, and John Brummer, an instrument and control engineer, wrote an extensive memorandum outlining steps to be taken to reduce the.
possibility of a similar occurrence (Ross dep. 121; B&W Ex.
165).
Every one of the nine recommendations in this memoran-dum was carried out (Ross dep. 129-35; Zewe dep. 415-16).
Ad-ditionally, in or about April, 1978, chemistry technicians were assigned to monitor closely the operation of the Unit 2 condensate polishers (Toole dep. 478).
The Comments state (p. 20) that, as of the date of "
the accident, there were " fully thirteen" work requests out-standing "with respect to" the Unit 2 condensate polisher sys-tem.
The Comments fail to state either the nature of these work requests or how long they had been outstanding.
More-over, thirteen other work requests involving the condensate polishers were carried out within the three months preceding the accident (Shovlin dep. 165).
Such activity with regard to the polishers supports Mr. Arnold's testimony that a number of decisions were made and actions taken with r,egard to the pol-L 26
ishers following the condensate polisher event in May of 1978 (Arnold trial tr. 1497-98, 1644, 1649).
Finally, the section of the TMIA Comments concerning the condensate polishers contains significant mischaracteriza-tions of testimony.
For example, at page 1642 of Arnold's trial testimony, the following question and answer appear:
"Q:
Did you become aware of an incident in the spring of 1978 in which water again got into the instrument air lines on the discharge valves for the condensate polishers?
-A:
I think I was aware of that incident at that time contemporaneously with when it was happening, when it had happened."
(Arnold trial tr. 1642.)
Incredibly, TMIA cites this testimo-ny for its contention (p. 20) that " Bob Arnold claim [s] to be entirely unaware.
. of the 1978 [ polishers) incident pro-voking Zewe's memo," citing Arnold trial transcript at pages 1497, 1642.
As indicated, the actual Arnold testimony, at page 1642, is contrary to the TMIA assertion.
At the other page cited by TMIA, Arnold testified to discussions which oc-curred at an October, 1978 meeting regarding progress in the resolution of problems with water in the instrument air lines.
The Comments assert (p. 20) that "perhaps most im-portant for present purposes, Arnold still does not consider this problem as representing any threat to the safe operation of the plant."
(Id. at 1498, emphasis in original.)
Once again, the cited Arnold testimony (at p. 1498) does not sup-port TMIA's assertion.
The cited testimony says nothing re-27
i s
j garding Arnold's present understanding.
Rather, Arnold, after testifying that activities had been underway in 1978 with re-gord to the condensate polishers, explained that at that time he "did not consider the problem with water in the instrument air line as representing any threat at all to safe operation 3
of the plant from a nuclear safety standpoint.
In sum, the focus placed by the Comments on the con-densate polisher system at Unit 2 mischaracterizes testimony and seriously misrepresents the efforts taken by GPU to deal with the pre-accident issues regarding design and operation of the polishers.
As shown, the GPU/ Met-Ed management did,'in fact, take responsible action to evaluate and deal with con-densate polisher matters prior to the accident.
The Keaten Task Force The next section of the TMIA Comments -
" Licensee's response to the accident" (pp. 20-37) -- concerns the Keaten task force.
This was an internal task force investigation un-dertaken on the initiative of GPU management to explore the causes of the accident.
The Comments attempt to establish 3
Of course, the secondary side of the plant, where.the condensate polishers are located, does not contain any nuclear fuel.
Although a secondary side upset, such as a loss of feedwater, might take the plant off line, causing operational' inconvenience, such upsets were expected and considered an anticipated operational occurrence for which the plant was designed and licensed (Womack trial tr. 4645; 10 C.F.R. 50, Appendix A:
Definitions and Ex-planations, " Anticipated Operational Occurrences"; Crite-rion 29).
i 4
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that "[a]fter each draft (of the task force report] was sub-mitted to management for comment, the task force rescinded significant findings of culpability which had been previously reached, unanimously, by members of the task force."
(Com-ments, pp. 21-22.)
This insinuation is not consistent with the evidence in the B&W trial record and is'at odds with the actual development of the task force report.
Keaton testified at great length regarding the work of the task force and man-agement's overriding directive that the task force produce a report which contained only what was " factual and clear and accurate" and " consistent with the best belief of the task force."
(Keaton dep. 60, 641.)
Keaten described in his tes-timony how the task force was still conducting its investiga-tion as the various drafts of the report were being prepared.
He also noted'that some of task force's investigative work re-mained incomplete at the time of the final report and that, in some areas, work continued subsequent to the completion of the final report (Keaten dep. 679).
TMIA's Comments attribute to management a role in the development of the task force which is not supported by the B&W record.
For example, according to TMIA, management reviewed the first draft of the report (dated September 28, 1979) and directed the removal of conclusions unfavorable to GPU.
In fact, there was no management review of the report until after the October 29, 1979 draft, which was intended as the task force's interim summary report, and there is no evi-
{-
29 a.
dence in the record of any prior management review.4 More-over, Keaten's testimony makes clear that.the September 28, 1979 first draft was intended not as a definitive report for management's consideration but rather as a talking piece to
" trigger discussion" among the task force members (Keaten dep.
732).
Keaten testified that he dictated this first draft into a hand-held recorder while driving across Pennsylvania (Keaten dep. 460), which is corroborated by the cover memo transmitting the draft to the task force members, in which Keaten invited them to " Feel free to attack without mercy."
(B&W Exhibit 347.)
This memo was sent to Mr. Arnold without the draft report attached (id.).
Keaten elaborated on his rationale for preparing this draft in his testimony by stating that his purpose was:
. to dictate something myself for the entire report, not worrying about if what I dictated was right or whether I even agreed with what I dictated, but just sim-ply to get down on paper so people can shoot out (sic), so this is what I did.
And if you look at this initial draft, you will find errors of fact as well as shaky conclusions or conclusions that were later completely reversed, so I am perfectly willing]to answer questions on this draft,a lot of them the answer is going but [to to be that's just something I put down to get something down to get people to start working on."
4 Indeed, the statement by Keaten in his memo transmitting the October 17, 1979 draft to the Task Force that "R.C.
Arnold has directed me to issue the interim report with-out his review" indicates that up to that point, Arnold had not yet seen the report.
(See B&W Exhibit 350.)
30 cc ;. _.. _ _-
(Keaten dep. 461.)
Keaten went on to testify that "he elected to start preparation of the report recognizing that the investigation was not complete, but feeling that we had learned enough in some areas to make it profitable to start the process of I
getting it into a report."
(Keaten dep. 502.)
As a result,
~
Keaten testified, the first draft w&s dictated "without any r
attempt to be very careful or very precise in the wording since [he] recognized that there would be a great deal of work that would be required in order to convert this draft into one which was really clear and accurate."
(Keaten dep. 566.)
Thus, the statements contained in the first draft did not rep-resent task force conclusions at all and were not even conclu-sions Keaten hed reached in his own mind (Keaten dep. 461-62).
l Above all, there is no evidence of any management review or revision of the draft report at this early stage or any other attempt to influence the content of the report.
The B&W record reveals that the first management re-view of the report came after issuance of the Interim Summary Report of the task force on October 29, 1979 (B&W Exhibit 351).
The cover memo accompanying transmittal of this report to Mr. Arnold and Herman Dieckamp, president of GPU, notes that "although the investigations are not yet complete, the task force has been able to draw conclusions regarding many of the relevant issues."
(Id., emphasis added.)
Following issu-ance of this report, Keaten testified, he and Dieckamp dis-(
31 i
cussed it.
During this discussion, Keaten and Dieckamp large-ly concentrated on Dieckamp's understanding of the report as written, with a view towards clarifying ambiguities in pas-sages in which Dieckamp felt that the task force had not ade-quately communicated what it had intended to say (Keaten dep.
638-40).
Keaten further testified that he and Dieckamp also discussed the bases for information contained in the report and possible areas of additional work for the task force (Kea-ten dep. 640-41).
Keaten testified that subsequent to this discussion, revisions to the draft report were made in an attempt to clar-ify areas previously seen as ambiguous, consistent with the direction given Keaten by Dieckamp that nothing should be add-ed, removed or revised unless it was " consistent with the best belief of the task force."
(Keaten dep. 641-43.)
As a result of this effort, the task force produced a revised Interim Summary Report on November 28, 1979 (B&W Ex-hibit 352).
Keaten testified that Dieckamp and Arnold were the intended audience for this report and that since he had previously discussed task force activities with them, an in-terim report would be "a useful opportunity for management to give the task force any revised or new direction regarding things that we should be doing."
(Keaten dep. 655, 657.)
Keaten further testified that there were no substantial i
changes in direction, but that Dieckamp and Arnold did suggest 32
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some further investigation by the task force (Keaten dep.
659).
A comparison of the October 29, 1979 and November 28, 1979 versions of the Interim Summary Report shows that most of the revisions reflect Dieckamp's expressed concern over possible ambiguities in the report.
Minor editorial changes can be found throughout the report.
Section II.A of the November 28th version also contains the task force's new conclusion that water in the instrument air system probably caused the sudden closure of the condensate polisher outlet valves.
Section II.B, dealing with the rationale for the con-trol room and staff personnel response, was extensively re-vised.
Dieckamp had told Keaten that he dad not believe the interim report adequately conveyed what he believed to be the task force's conclusion that the operators were misled on the day of the accident by the location of the break in the pres-surizer vapor sp' ace which resulted in parameters which did not resemble the LOCA response which the operators had been trained to expect (Keaten dep. 638).
Accordingly,Section II.B was substantially restructured and expanded, in particu-lar, to explain the effect of the break location on operator response, but also generally to convey more clearly the task force's conclusions (Keaten dep. 642-43).
Certainly, no fair reading of the revised Section II.B in comparison with the Oc-tober 29th version can yield anything but the conclusion that the authors were attempting to express themselves more clearly 33
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and fully in explaining the operator's response.
No material which could be considered critical of GPU was removed from this section.
The other significant change in the November 28th report is in Section II.F dealing with the closure of the emergency feedwater block valves.
The October 29th version notes that "The surveillance procedure (for checking the oper-ability of certain valves in the emergency feedwater system]
clearly violates this technical specification," referring to a technical specification which, the report states, requires that three independent emergency feedwater pumps and associat-ed flow paths shall be operable as a limiting condition for operation.
The November 28th version states that the emergen-cy feedwater system is defined in the technical specification as three independent pumps and flow paths, which must be oper-I able, even though one " system" may be inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The report points out that there is no statement es to pumps or flow paths out of service and the actual requirement is thus unclear.
The report concludes that "while the surveillance procedure may not (of have violated the literal req luirement the technical specifications
, the Task Force believes that it was contrary to the intent of the specifications.
In con-i trast, the TMI-l surveillance procedures indicates that at no time may two emergen-cy feed trains simultaneously be out of service."
Also, the November 28th version does not make mention of vio-lation of this technical specification by a second surveil-l 34 1
lance procedure (although that procedure and its requirements are discussed).
Reference to the " violation" of the technical speci-fications was omitted from the " Conclusions" section of the November 28th draft.
At his deposition, Keaten addressed this revision of a " conclusion," which first appeared in the rough draft of September 28th.
Keaten testified that:
"At the time that this was written, I think I believed based upon work done by others, not by me personally, that the way in which that surveillance testing was done was contradictory to the requirements of the technical specifications.
I should add that a later and more careful investi-qation of that contradicts what is said here."
(Keaten dep. 490-91, emphasis added.)
The changes made in the November 28th version thus do not reflect a management " white-wash" with respect to this surveillance procedure, as TMIA im-plies at pp. 32-33 of its Comments.
Rather, they reflect the results of a more careful investigation of what the technical specification actually says and what it actually requires, and a finding that the specification may not have been violated.
Further, any allegations of a " whitewash" should be stilled by I
the finding that although the literal requirements of the specification may not have been violated, the procedures as implemented were nonetheless contrary to the intent of the specifications.
In general, the November 28th report, which incorpo-rated, among other things, Dieckamp's comments, continued to 35
. - ' ~ -
l
be what he directed, an accurate summary by the task force of its findings.
The November 28th version cites several defi-ciencies within GPU and the nuclear industry in general which contributed to the accident, and strongly recommends correc-tive action.
TMIA's mischaracterization of the report as a management cover-up ignores these self-criticisms which are evident throughout the substance of all versions of the re-port.
The November 28th Interim Summary Report was sent to both Dieckamp and Arnold (Keaten dep. 653-54).
The next re-port produced by the task force was a draft Final Summary Re-port dated March 24, 1980 (B&W Exhibit 354).
This draft con-tained various minor changes in the section on operator re-sponse (II.B) and assessment of core damage (II.G).
The " Con-clusions" section of the November 28th report noted that while the task force had not performed a thorough review of the rea-son for the widespread eristence of problems in the TMI opera-tion, there appeared to be a lack of management awareness of problems, insufficiently stringent standards to evaluate oper-ations, and a management tolerance of this situation, at least in the short run.
This conclusion does not appear in the March 24, 1980 report, which notes that the task force did not l
thoroughly review the role of TMI management " relative to the identified problems," because of the significant changes made l
j since the accident in management structure.
36
l l
TMIA has seized on this section as further "evi-dence" of a management cover-up (Comments, p. 34).
In fact, the role of management is not listed among the seven areas the task force was directed to investigate.
(See TableiI at the beginning of each version of the report.)
In complaining about the removal of " pejorative" statements describing man-i agement's " culpability," TMIA has ignored the purpose of the l
task force, which, Keaten testified, was not to fix blame for the accident, but rather "to understand where were areas where improvement or change were either necessary or desirable in l
order to reduce, as far as possib3e, the probability of this I
type of event occurring again."
(Keaten dep. 583.)
TMIA to-tally ignores the fact that the March 24, 1980 report fulfills this mandate by making several recommendations not contained in the November 28th report which involve changes by plant management.
These include recommendations 3 (implementation of an integrated system for procedure development and review),
13 (formal system for assuring action on employees' sugges-tions for improved plant operation), 14 (assuring that plant f'
improvements are not hindered by difficulties in obtaining au-thorization and establishing an annual resource fund to that end), and 17 (careful evaluation of plant operation under de-graded conditions).
Each of these recommendations appears in the final version of the Final Summary Report, dated December 15, 1980 (B&W Exhibit 356), along with an added recommendation (number 14) that a formal system to document degraded plant 37
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~
~
equipment conditions and ensure corrective action be imple-i mented.
Far from being a cover-up, the March 24, 1980 report instead represents GPU's continuing attempt to learn from the accident and to improve its nuclear operations.
TMIA's empha-sis on the removal of certain " pejorative" language should not be allowed to obscure the larger point that GPU continued to engage in penetrating self-criticism and to take corrective action.
A subsequent draft of the task force final summary report was produced on May 12, 1980 (B&W Exhibit 255), and, Keaten testified, was later distributed widely among GPU's up-per management, including William Kuhns, Philip Clark and Richard Wilson, along with Dieckamp and Arnold (Keaten dep.
683; see also, B&W Exhibit 357).
The final version of the Fi-nal Summary Report was released on December 15, 1980; there was no Keaten testimony about management comments on the May 12th draft.
Aside from some editorial changes, and a supple-mentation of the section on " Pressurizer Relief Valve Failure Modes" (II.D), the December 15th report is substantially simi-lar to the May 12th draft.
Indeed, TMIA admits as much in its comments (see TMIA Comments at pp. 31-32).
Thus, the draft of the report most widely distributed to GPU management resulted in virtually no significant changes.
A careful review of the B&W record refutes TMIA's attempt to impeach the integrity of the work done by the Kea-ten task force.
Plainly, the earliest drafts reflected tenta-38 a-p
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tive hypotheses, sometimes exaggerated for use as talking points, based on incomplete investigative work.
The later drafts, which were the only ones reviewed by management, re-flect not a " whitewash," but a continual development of under-standing and a refinement and clarification of the task force's conclusions.
Indeed, all of the drafts were main-tained, and produced in the B&W litigation.
Above all, the task force effort represents a thorough self-examination, en-couraged by GPU's management, and the final report contains numerous criticisms of both GPU and the nuclear industry, ac-companied by strong recommendations for reform.
It is upon this process of self-criticism and its follow-through that the NRC staff should concentrate.
Maintenance In its section on Maintenance, pages 37-50, TMIA makes a number of derogatory assertions regarding the quality of maintenance at TMI both before and after the accident.
In fact, however, TMI-l's maintenance record had built a reputa-i tion in the industry for excellence.
B&W's manager of Operat-ing Plant Services, James Phinney, recognized that TMI-l's good operating record and history of reliability was a result of the high quality of the outage planning and of the mainte-nance performed during outages (Phinney dep. 6-10; GPU Ex. 394, Metropolitan Edison minutes of B&W Operating Seminar, at p. 4).
39 l
TMI's argument that a favorable assessment of cur-rent maintenance conditions cannot be accurate if there were unfavorable maintenance conditions in the past is dubious at best.
In any event, the exemples given of allegedly poor maintenance, drawn almost exclusively from the GPU v. B&W tri-al and depositions, do not demonstrate safety-related prob-lems, either in the past or the present.
Maintenance Budget and Staffing Seeking substantiation from the B&W trial record, TMIA's first criticism of maintenance (pp. 39-42) focuses on what it labels " budget cuts and understaffing."
Purportedly relying on a tape-recorded interview (B&W Ex. 360) with former station superintendent Gary Miller, the Comments seek to un-dermine certain ASLB findings.
Among the ASLB findings favor-able to GPU which TMIA attacks are:
(1) that the " Licensee's records under the old system were auditable" (Comments, p. 42; PID 1 314); (2) that the Licensee has, under the past and pres-ent systems, adhered to company standards in performing main-tenance in a timely fashion (Comments, p. 42; PID 1 289); (3) that even in times of financial stress, GPU management has shifted available resources to meet its clear obligations (Comments, p. 42); and -(4) that there is no improper deferral l
(
l of maintenance work "of significance" (Comments, p. 42; PID i
l 1 296).
As developed below, TMIA fails to marshall any evi-l l
I 40 l
l
~
1 dance from the B&W trial record or elsewhere to undermine these findings.5 Maintenance Staffing The Comments argue (pp. 40-41) that prior to the ac-cident there were about 800 open maintenance items and that the maintenance staff and budget should not, therefore, have been reduced.
TMIA has neither cited nor quoted any testimony to show that 800 open maintenance items was an unreasonably large number for a 2-unit nuclear station, which has hundreds of thousands of pumps, motors, pipes, lines, valves, switches, filters, relays and other instruments and machines.
Nor has TMIA cited any evidence to establish that those 800 items were left "open" for unreasonable lengths of time.
THIA has also 1
failed to indicate how many of the 800 items were major or whether any of those items wert safety related.
In fact, Miller, in his recorded interview, indicated that " priority one" Jobs, i.e., the important jobs, were always done (B&W Ex.
260 at p. 22, Comments, p. 41).
Nothing in the Miller state-ments indicates improper deferral of maintenance work or that significant work was deferred.
Miller's comments indicate that, prior to the acci-dent, maintenance staffing for the two units was approximately 5
For example, with respect to whether the TMI maintenance records wers "auditable" (Comments, p. 42), nothing in the Miller statements quoted by TMIA in any way pertains to the Board finding.
41
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135 persons, plus outside contractors, whose staffing was be-ing gradually reduced (Arnold trial tr. 1661-65).
Arnold tes-tified that, in or about 1978, the maintenance staff increased by about 50%, to approximately 150 people (Arnold trial tr.
1656-58).
Before the accident, GPU studied the adequacy of its maintenance staffing.
It found that the level of staffing at TMI compared favorably with other utilities and that GPU was on the high side of the range of expenditures for all nu-clear activities when compared to other utilities (GPU Ex.
2056; Arnold dep. 395, trial tr. 1774-75, 1782-84).
Budget Cuts As TMIA concedes (Comments, p. 41), the ASLB has al-ready rejected TMIA's contention that a proposed 1979 budget cut lacked due regard for safety.
TMIA's attempt to find evi-l dence to the contrary in the GPU v. B&W trial record has failed to provide any evidence to further support its conten-tion.
The fact that Miller would have preferred not to reduce the maintenance budget does not undermine the Board's conclu-sion.
Miller presented his views on th= budget to GPU manage-ment (Arnold trial tr. 1664; Miller dep. 1038-39) and the Com-ments make no allegation that Miller's views were not fairly considered.
TMIA states as a criticism (Comments, p. 41) that budget cuts were also considered in 1977 and 1978.
In fact, the decision of management not to implement budget cuts in 4
those years, if anything, seems to bear out the ASLB finding 9
42
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that GPU shifted available resources to meet nuclear obliga-tions, even in times of financial stress (Comments,.p. 42).
Repair Parts d
In a further part of the TMIA Comments on mainte-nance, TMIA attempts to criticize the pre-accident repair parts documentation at TMI (Comments, pp. 43-44).
As TMIA recognizes, the issue of repair parts documentation was iden-tified by Met-Ed management in its 1978 management " audit,"
B&W Ex. 843.
The thrust of the portion of the audit quoted by TMIA was that, in 1978, it took a long time to obtain repair parts.
However, the Comments (p. 43) quote from only a por-tion of the 1978 audit which found that there was " difficulty in locating repair parts known to be in the warehouse."
The Comments fail to indicate that'the audit went on to explain what it was referring to:
"There were complaints of long lines at the service window, and that often the service window is not manned for long periods of time."
(1978 Audit at
- p. W45228.)
The other audit finding quoted by TMIA (p. 43) is that it took "an inordinate amount of research to identify the Met-Ed stock numbers required for requisitioning material" (id. at p. W45228).
These relatively minor inconveniences that existed five years ago do not even begin to be valid rea-sons for delaying the restart of Unit 1.
The references.to the "Glickman Audit" of late 1979 in the TMIA Comments (p. 43) misrepresents both the effort and the contents of the document.
Mr. Glickman's effort was di-43 i
l
~~
rected at interviewing a number of management personnel in or-der to be sure that any concerns tl.ey may have had would be met with a sympathetic ear in the new GPU Nuclear organization being set up.
Thus, to the extent that problems in fact ex-isted, they would be addressed effectively.
The report pro-vided as a result of that effort drew no conclusions on these issues and Mr. Glickman in writing the report was acting as a reporter of the informally received opinians of the interview-ees and not as a confirmatory editor (Glickman dep. 476-77, Arnold trial tr. 1771-72).
TMIA's example of " concrete evidence" from the trial record of an alleged repair parts problem is that "B&W discov-ered that a spare PORV was ordered in 1975, and delivered to the Island until 1978 [ sic).
Yet in early 1979, the Supervi-sor of Maintenance (Sieglitz) was still unaware that it had been delivered" (p. 43, citing Sieglitz trial tr. 5766-67).
As Mr. Sieglitz pointed out at the cited transcript page:
"I did not keep track of each and every component.
There are thousands and thousands of line items in the warehouse.
I was not specifically looking for any one component when it arrived unless I had a component that was broken down.
I had no reason to look for [a spare PORV) unicss I felt I had a, main-tenance problem."
(Sieglitz trial tr. 5766-67.)
As Mr. Sieg-i litz understandably pointed out, he relied on a computer printout, not his memory, to keep track of spare parts, and that printout was approximately 18 inches thick (Sieglitz tri-44
al tr. 5792-94).
Clearly, Sieglitz should not have memorized a list of the equipment components contained in the warehouse; i
records were available from which that information could be determined.
In short, the purported " concrete evidence" from the B&W trial record fails to demonstrate any safety problem in j
the location or documentation of spare parts.
Paperwork The third part of the Comments' section on mainte-nance (pp. 44-45) addresses the time spent by the raintenance department on paperwork.
As Arnold has testified, a paperwork burden is endemic to the nuclear industry, which requires an enormous amount of paperwork (Arnold dep. 380).
As is also established in Arnold's testimony, GPU has taken many steps to reduce this burden.
The steps taken prior to the accident in-cluded additional new office machine equipment, additional staffina (e.g., use of a " switching and tagging" operator),
and evaluations by the Met-Ed operations analysis section of ways to reduce paperwork and streamline administrative control procedures (Arnold dep. 379-86).
Overtime l
'?MIA addresses the issue of overtime on page 46 of l
the Comments.
As TMIA admits, the ASLB has dismissed the pu-l tative overtime issue," finding no abuses (Comments, page 46); TMIA, in its Comments, provides no evidence relevant to the Board't finding on this point.
In its discussion of half 1
45 l
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a page (Comments, p. 46), TMIA cites only so-called " audit" findings that are four and five years old, regarding working hours on site.
The need five years ago for personnel to put in long hours arose from a unique and temporary situation existing at that time, i.e.,
the intensive efforts needed for startup and test of Unit 2 (Arnold dep. 348-49, 367).
The Comments do not assert that an overtime problem presently exists or indicate why concerns with overtime in 1978-79 are relevant to restart.
Daniel Shovlin The final portion of the TMIA Comments on Mainte-(pp. 46-50) attempts to utilize the deposition testimony nance of Daniel Shovlin, the current Unit 1 Maintenance Supervisor, to attack his competence and credibility.
TMIA is unsuccess-ful on both counts.
As demonstrated below, its unfounded at-tacks on Mr. Shovlin rely either on statements taken out of context or on his understandable inability to recollect the details of events which occurred between three and a half and seven years prior to the date of his deposition.
The TMIA Comments on Mr. Shovlin begin by citing his i
deposition for the proposition that when he first came to TMI as supervisor of maintenance, "he felt that there was nothing he needed to do to familiarize himself with TMI-1."
(Com-ments, p. 47, citing Shovlin dep. 30.)
The actual testimony j
given by Mr. Shovlin reads quite differently:
l 46 l
o "Q.
And in July 1973 you found yourself as a supervisor of maintenance for a nu-clear power station (i.e., TMI).
Did you do anything to familiarize yourself with how that station was constructed or de-signed, or how it worked?
"A.
Yes."
(Shovlin dep. 30.)
After giving this clear testimony directly contrary
~
to what TMIA asserts, Mr. Shovlin observed correctly that, with the exception of "the radiological hazards" (id.), which he noted as a " major difference," a fossil plant and a nuclear plant have many similarities.
It was only in that context l
that Mr. Shovlin gave the testimony under cross-examination which TMIA cites (id.).
TMIA's assertion that Shovlin has never "seen a maintenance log" (Comments p. 47) is similarly misleading.
Shovlin has seen and was familiar with logs kept in the Unit 2 maintenance department (e.g.,
Shovlin dep. 88), including the maintenance log itself.
The context of the testimony cited by TMIA, which concerned solely start-up log entries, makes clear that B&W's counsel was incorrectly using the terms "mainte-i nance log" and " start-up log" interchangeably.
Shovlin did testify that he had not reviewed GPUSC start-up logs.
Those logs were kept b'y GPUSC engineers and pertained not to mainte-nance, but to start-up and test activities within the respon-sibilities of the GPUSC engineering department.
l Another example of TMIA's loose treatment of testi-mony is its assertion that "in 1975, [ Gary] Miller held Shov-lin, among others, responsible for a ' low level of interest 47 i
I
and seriousness'" with which the Unit 2 procedure writing ef-fort was pursued (Comments, p. 47).
In fact, however, Miller did not attribute such an attitude to Shovlin or to any par-ticular person.
The document containing the language quoted by TMIA, B&W Exhibit 763, is a memorandum from Gary Miller which is merely addressed to Shovlin, among other persons, and which also contains a lengthy distribution list, including "each engineer" involved in the procedure-writing effort.
Shovlin was not even questioned about this memorandum at his deposition.
As for its author, Mr. Miller, he testified as follows regarding his memorandum:
"The reason for the statement is that
. I wanted to have more resources which means more individuals devoted to writing the chemistry, HP, and maintenance precedures, and that is why the addresses are Mr. Sawyer, Shovlin, Dubiel, and Ro-manski, and I don't think it is fair to say this characterized a low level of in-terest in Unit 2 procedures, but it did characterize the fact that the Maintenance and Health Physics Departments needed to recognize Unit 2 was to get some more pri-ority."
(Miller dep. 135-36.)
Thus, TMIA's attack on Shovlin, based on the Miller memoran-1 dum, falls wide of its mark.
In addition to taking statements out of context, TMIA's attack on Shovlin seems to assume that as of July 1982, j
when his deposition was taken, Mr. Shovlin should have re-called the details of incidents which took place as many as seven years before.
Thus, for example, TMIA challenges the fact that he couldn't recall whether or not he had seen a let-48
ter which was sent from Lee Rogers to John Herbein dated July 30, 1975.
Similarly, TMIA attacks Shovlin for not recalling the details of various incidents which took place in 1977 and 1978.
For example, TMIA criticizes Shovlin for not recalling that in. September of 1977 the Unit 2 PORV was removed for in-house repairs.
There is no reason why that standard repair, properly performed, should have stood out five years later as a memorable event.
It is simply unfair to criticize someone for being candid enough to state that he is unable to recall such events when they took place so many years before.
TMIA's attack on Shovlin for failing to recall such events is particularly unfair in light of his responsibilities during much of the period in question.
Beginning in late 1977, Shovlin was superintendent of the TMI maintenance de-partment with overall responsibility for the planning, organi-i zation and direction of maintenance for both Units 1 and 2.
At that time, Shovlin also assumed the additional position of supervisor of maintenance on Unit 1, a position he had held from 1973 throug*. 1976 and which he had held throughout most of 1978 (Shovlin dep. 4-12).
Thus, with regard to detailed maintenance issues, as opposed to the overall administration of maintenance, Shovlin focused principally on Unit 1 during that period.
For the details of Unit 2 maintenance matters, Shovlin relied on Richard Sieglitz, the Unit 2 supervisor of maintenance, who Shovlin testified "ran the maintenance activ-ities at Unit 2."
(Shovlin dep. 161-62).
As both superinten-49 l
dent of maintenance on the Island and supervisor for Unit 1, Shovlin appropriately relied on the Unit 2 supervisor to han-i die the detailed maintenance oversight of Unit 2 while dealing with such matters himself on Unit 1 (Shovlin dep. 195-98).
Accordingly, TMIA is simply off base in criticizing Shovlin for not recalling, years later, minute and detailed facts con-cerning events at Unit 2.
There is no need to commit to memo-ry and retain in one's mind for as long as seven years de-tailed information on numerous maintenance efforts which are all accurately recorded by the company and retrievable by any managerial or supervisory
- personnel when they need to know about it.
In light of this background, many of TMIA's specific criticisms of Mr. Shovlin must be rejected out of hand.
For example, TMIA criticizes Shovlin for not knowing that there were 13 work requests outstanding on the Unit 2 condensate polishers at the time of the accident and that 13 more were carried out from January to March of 1979.
Since Unit 2 main-tenance was performed under Sieglitz's direct supervision, not Shovlin's, Sieglitz certainly did not need to inform Shovlin of each of these work requests, nor would Shovlin be expected to recall these statistics years later even if he once knew them.6 i
6 Ironically, in a subsequent section of its Comments deal-ing with " Management Structure," TMIA criticizes manage-ment for allegedly failing to delegate responsibility ef-(Footnote continued) 50 9t-.
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Shovlin's personal involvement in the details of Unit 1 maintenance is clearly reflected in his deposition.
Thus, while TMIA criticizes him for not recalling leakage from valves at the top of the pressurizer in Unit 2, it fails to mention that he did recall learning of such leakage in Unit 1.
(Shovlin dep. 125-56.)
In view of his line responsibility for Unit 1, dating back to 1973, it only stands to reason that his knowledge and recollection with respect to that Unit, which is also the sole subject of his present responsibilities, would be greater.
TMIA's criticisms of Mr. Shovlin also ignore the ba-sic division of responsibility between GPUSC and Met-Ed, par-ticularly as it relates to Shovlin's area.
Most of the inci-dents at Unit 2 with respect to which TMIA criticizes Mr.
Shovlin took place during the start-up and test phase of the Unit in 1977 and 1978.
As TMIA is well aware, GPUSC, not Met-Ed, was responsible for the start-up and test program.
In-deed, a number of the specific incidents cited by TMIA, in-cluding the PORV failure in August 1977 and the condensate system problem in the fall of 1977, were addressed by GPUSC engineers in start-up problem reports.
As Shovlin testified (pp. 161-62), when Unit 2 went commercial in December 1978 it l
l I
(Footnote 6 continued from previous page) fectively (Comments, pp. 57-58), while in its section on Shovlin TMIA inconsistently criticizes management person-nel for not being involved in the minute details of de-partment activity.
51
- ': ' T
was the responsibility of Mr. Sieglitz to handle maintenance issues remaining from the start-up and test phase; only those problems which were considered at that time to be highly sig-nificant would be referred by Sieglitz to Shovlin.
Thus, the details of at least some of the events which TMIA criticizes shovlin for not recalling would not even be expr:ted to have been brought to his attention in the course of his duties.
Finally, in criticizing Mr. Shovlin for failing to recall the details of a particular incident, TMIA often fails to note, or discounts the fact, that Shovlin did have a gener-al recollection of the event and his participation in it --
which is all that could reasonably be expected so many years later.
Thus, for example, TMIA states that Shovlin is "en-tirely unaware of the April 23 (1978] transient or of doing anything in connection with it."
(Comments, p. 47.)
At best, this is a half-truth.
While Mr. Shovlin could not, four years later, specifically recall the events of April 23, 1978, he
" remember (ed] very vividly" the fact, which was most pertinent from a maintenance point of view, that the main steam relief valves had lifted and stuck open (Shovlin dep. 58-59).
Since Shovlin was in charge of maintenance and not engineering or operations, it stands to reason that the maintenance aspects of an cperating event would remain with him longer than the engineering or operational details.
52
, - -. -. ~ _ _
I Similarly, TMIA criticizes Shovlin for not recalling specific instances where problems were encountered with the condensate polishers, resulting in the loss of feedwater, but fails to note that he did recall participating in discussions as to whether an automatic bypass system would address those problems.
Specifically, Shovlin testified that he had pursued the matter first with one of his lead foremen, Doug Weaver, and then with GPUSC's lead start-up and test engineer, Ron Toole, who co'ncluded that such a system was not necessary since the plant was designed to accommodate safely any loss of i
feedwater (Shovlin dep. 163-64).
Far from serving as a basis for criticism, Mr. Shovlin's recollection of this incident, omitted by TMIA, illustrates the fact that he attended to his duties in a conscientious and appropriate manner.
In sum, Mr. Shovlin's deposition testimony does not raise any serious issue with respect either to his credibility or to his competence to serve as supervisor of maintenance at Unit 1.
Training The Comments attack the current training at TMI by mining the B&W trial record for alleged indications of "long-standing and well-recognized" training problems which "the company did absolutely nothing about until forced to do so af-ter the accident."
(p. 50.)
A fairer reading of the trial record, however, reveals that Met-Ed was addressing training concerns before the accident.
53
- T
. E n
The focus in the Comments on "non-attendance" at re-qualification training (pp. 52-53) is seriously misleading.
In the first place, all of the operators enrolled in the re-qualification program were already licensed, had passed the NRC licensing exam and were qualified to operate a plant.
In fact, operators from TMI performed better than the average on the NRC licensing exams (B&W Ex. 707, p. 1, memorandum from Arnold re:
Response to Notice of Violation; GPU Exs. 2305, 2306).
The material presented in the requalitication program (to which the TMIA Comments refer) was presented for the pur-pose of maintaining operator qualification in accordance with the guidelines established by the NRC in the mid-1970's.
(See Frederick trial tr. 3210; GPU Ex. 2320, 10 CFR 55, Appendix A.)
Both the NRC, in 1977 and 1978, and the GPU Quality As-surance Department, in 1978, audited the training department programs (GPU Exs. 509, 510, 511).
The results of all of those audits were favorable.
Moreover, before one can draw any conclusion from classroom attendance figures, it is crucial to note that the number of scheduled classroom hours at TMI was far greater than the hours required either by the NRC or by Met-Ed's own internal procedures (Arnold trial tr. 1760-63; Zechman dep.
596).
For example, a minimum of only six training lectures is recommended in the NRC-endorsed "American National Standard for Selection and Training of Nuclear Power Plant Personnel" (GPU Ex. 2256, ANSI /ANS-3.1-1978, p. 9; GPU Ex. 2258, NRC Pro-54
posed Revision 2 to Regulatory Guide 1.8, February 1979. pp.
2-3; Arnold trial tr. 1760-61).
Yet, Met-Ed committed itself to offering 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of training (GPU Ex. 2155, Unit 2 Final Safety Analysis Report ("FSAR") 5 13.2.2.1; Frederick trial tr. 3328), and typically offered many more hours of training lectures during each annual requalification cycle (Zechman dep. 900 - more than 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of scheduled training offered).
That operators in fact attended classroom hours in excess of requirements is illustrated by GPU Exhibits 3030 and 3031 (Frederick trial tr. 3327-38; GPU Exhibit 2154) which graphi-cally depict the excellent 1978 attendance records of the four operators on shift on the day of the accident.
In the even; that operators were not able to attend a classroom training session, they studied the material pre-sented through make-up packages, a practice provided for in the NRC-approved FSAR (Frederick trial tr. 3327, 3333; Arnold trial tr. 1759; GPU Ex. 2155, Unit 2 FSAR, S 13.2.2.1).
This i
study, which was done on company time, was tracked by the training department (Arnold trial tr. 1760; Zechman dep. 191).
The level of attendance at training was in part the result of the five-shift schedule in effect prior to the acci-dent.
(See Herbein dep. 367-68; Miller dep. 501-03; 1978 Au-dit, p. W45229.)
The five-shift schedule in fact contributed i
to valuable operator training in that the operators had in-creased exposure, on a five-shift schedule, to important tests and evolutions performed only during the start-up and test pe-55 l
l
~
~ ~ ~ ~ '
i riod (Arnold trial tr. 1755-56, 1958; Herbein dep. 366-67, 371).
Met-Ed management planned to return to six shifts after the start-up and test program and did so shortly before the accident (Herbein dep. 367, 371-72; Arnold dep. 366-67; Arnold trial tr. 1755-57; Miller dep. 503; Herbein dep. 503).
The six-and five-shift schedules at TMI compared favorably to the schedules of most nuclear plants, where four-and five-shift schedules were generally found (Arnold trial tr. 1756).
The memoranda cited by TMIA at page 51 do not sup-port the allegations regarding training; i f anything, they in-dicate that management gave training serious and appropriate attention.
Thus, for example, the Comments quote from a memo written by Miller in 1977 stating that greater progress was necessary in on-the-job training if a deadline (four months away) was to be met.
(The on-the-job training referred to is a process whereby operators witness and participate in specif-ic aspects of plant operations, so-called plant evolutions.")
Miller's tracking of the on-the-job training program, and the fact that there were frequent training department audits of this program, speak well for the organization of the training program.
TMIA presents no evidence that operators did not complete on-the-job training in 1977, or that operator train-ing requirements were not met.
' TMIA notes a concern with the relevance of classroom training to plant operations (Comments, pp. 51, 54-55).
Inev-itably, a certain amount of training will be devoted to sub-56 e
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jects on which operators are to be tested on the NRC licensing examination and on the requalification examinations given by the utility and audited by the NRC.
Some of the operators might consider some of the topics in these exams not immedi-ately relevant to plant operating needs.
However, that does not change the fact that the NRC training requirements needed to be met and are met by the TMI training department.
Richard Zechman The Comments (p. 53) state that the trial record contains the " revelation" that Richard Zechman, supervisor of training, did not have an operator license.
In fact, there was neither a requirement nor a necessity for Zechman to be a licensed operator.
Zechman had an extensive' background in nuclear oper-ator training and had held both a RO and a SRO license at the Pennsylvania State University research reactor prior to join-ing the TMI training department in 1974 (B&W Ex. 554, Zechman resume).
His position as supervisor of the Met-Ed training department was primarily administrative, and his teaching re-sponsibilities were in theoretical areas such as reactor the-ory (Zechman dep. 737, 744, 751-52, 760).
Thus, his position did not require a knowledge of plant-specific information, such as that possessed by a licensed operator.
It was not a job requirement that the head of the Met-Ed training department hold an operating license; nor was it standard in the industry for the supervisor of training to I
57 l
i l
l
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0 hold a license.
For example, Richard Marzec, GPU's expert witness on training at the GPU v. B&W trial, and one of the nation's leading experts in operator training, did not himself hold an operating license on a B&W plant during the time that he was the head of operator training programs at Duke Power Company, which had three B&W reactors.
Met-Ed and GPU management knew of Zechman's decision to take the challenging senior reactor operator license exami-nation (rather than the simpler control room operator's exami-nation) (Herbein dep. 278; Arnold trial tr. 1705).
During the j
time that Zechman was studying full time for this examination, administration of the training department was properly handled by others within the department (Beers dep. 110; Herbein dep.
274-75, 281-83).
The Book Letter TMIA quotes at length (pp. 51-52) from a letter by i
T. L. Book which expressed his view on certain training is-sues.
The contentions made in the Book letter have already been investigated by the NRC's Office of Investigations (Memo-randum for Chairman Palladino, et al., from Darrell G. Eisen-hut, Director, Division of Licensing, NRR, re:
Ma.lagement Competence and Integrity - Board Notification 83-71A. June 27, i
1983, attaching a memorandum from Ben B. Hayes, Director, Of-l l
fice of Investigations, re:
TMI-l Allegations of Falsified Training Records, with enclosures - sworn statement by Book, and report of the OI interview of James O'Hanlon).
i 58
The Office of Investigations interviewed both Theo-dore Book and James O'Hanlon, to whom the Book letter had been addressed.
O'Hanlon was at the time TMI Unit 1 Superinten-dent; he is presently Manager Operations Department, Evalua-tion and Assistance Division, at the Institute of Nuclear Pow-er Operations (INPO).
The Office of Investigations concluded, as a result of its inquiry, that no further investigative ef-fort is necessary.
In his sworn statement, Book stated that he knew of no falsification of training records or of any other impropri-eties at TMI.
He explained in his statement that the language in his letter regarding documentation of more hours than were actually used for training meant that when the training de-partment sent out material that was to be covered in one hour, the shift did not always expend a full hour on the topic.
This resulted from interruptions to on-shift training caused by plant events, which would result in the shift's losing track of the time.
Although Book therefore believed it was possible for some hours to be documented that were not used, he did not believe that it was the norm or that it was done blatantly or irresponsibly.
James O'Hanlon, during his interview, stated that he had spoken with Book after receiving the letter and had learned that Book's concern was indeed that, although required training material was covered, it did not always utilize the time allotted it.
O'Hanlon also stated that he has absolutely 59 i
no knowledge of any record falsification at TMI and that he had monitored and was involved in training activities until he left the TMI site in December, 1978.
Regarding the other contentions in Book's letter, O'Hanlon stated that there was a rc31 possibility that Book had not had any training since his requalification exam in February, as was stated in the letter, because they were in a refueling outage at that time.
(See GPU Ex. 2256, ANSI /ANS-3.1-1978, "American National Standard for Selection and Train-ing of Nuclear Power Plant Personnel" (" ANSI /ANS-3.1"),
S 5.5.1.1.1, page 9, indicating that lecture schedules should be spaced throughout the year, taking into consideration heavy vacation periods and infrequent operations, such as refueling periods.)
As is discussed supra, pages 54-55, TMI operators did attend a substantial number of hours of regularly sched-uled classroom training.
O'Hanlon also stated in his interview tha't Book's concern that management or training was not responsive to sug-gestions was unfounded.
He explained that Book had been un-aware of plans to upgrade training facilities, and to include a sixth shift (see discussion supra, at pages 55-56), and had been unaware of the addition of an operator [as instructor] to the training department.
O'Hanlon also said during his inter-view that he had told Book that having the operations person-nel read emergency procedures on backshifts and during "down time" was a worthwhile training method.
(See GPU Ex. 2256, 60 t
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, ~-,-, -,,-
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ANSI /ANS-3.1, 5 5.5.1.2.4, page 10, which indicates that on-shift review and self-study of emergency procedures was in conformance with applicable guidelines.)
Theodore Book, the author of the " Book" letter, has clearly stated that he was not referring in that letter to any kind of impropriety regarding training records or otherwise.
The other concerns raised in the letter, all expressed in equally hyperbolic form, are equally unfounded, as is indicat-ed by the interview with O'Hanlon.
Thus, the Book letter clearly does not necessitate further inquiry nor raise any is-sues relevant to the restart of. Unit-1.
Management Structure The inconsistencies in the Comments' discussion of alleged problems in management structure (Comments, pp. 55-59) have already been discussed, supra, pages 50-51 n.6.
The crux i
of this section of the Comments is TMIA's allegation that "Li-censee must be fundamentally incapable of taking responsibil-ity for its own wrongdoing."
(Comments, p. 59.)
Nothing in the Comments supports this conclusion.
TMIA failed to show any " wrongdoing" by Licensee management.
Moreover, the action items that were consistently developed as a result of self-initiated reviews evidence an important capacity for self-l evaluation and improvement on the part of General Public Util-ities and Metropolitan Edison.
(See, e.g.,
B&W Exs. 883, 884 (follow-up minutes of 1978 Audit); B&W Ex. 186, TDR 001, pp.
I l
61 I
l l
l
56-58 (action items arising out of 4/23/78 event); Arnold dep.
349-50 (previous management audits acted upon).)
Managers In the last section of its Comments (pp. 59-61),
TMIA purports to set forth "the more revealing statements and criticisms of Bob Arnold" from the record in the B&W case.
In i
fact, the excerpts cited by TMIA do not reflect poorly on Mr.
Arnold, nor do they form the basis for any valid criticism of the exercise of his management responsibilities at GPU.
To the contrary, as the following point-by point refutation makes clear, quite the opposite is true.
Several of TMIA's comments purport to rely on the so-called "1978 audit findings" found in B&W Exhibit 843.
That exhibit contains,the results of interviews of fifty su-pervisory personnel conducted over a period of five days by three selected employees.
They were assigned to this task by Mr. J. G. Herbein, Vice President of the Generation Division of Metropolitan Edison, to ascertain the concerns of the TMI supervisory staff within Met-Ed.
Mr. Arnold testified that as Vice President of Generation for GPUSC, he did not recall hav-ing received the report of these interviews, which was ad-dressed to Mr. Herbein.
Herbein did have some discussions with Arnold on issues raised by the effort as, based on their past relationship when they were both at Met-Ed, Arnold en-couraged Herbein to continue to use him as a sounding board (Arnold dep. 345-353).
Arnold also explained that he "would 62 l
not have chosen the nomenclature of an audit for this type of effort" which was in fact one of a series of " attempts to un-derstand the concerns of people within the organization."
(Arnold dep. 345.)
Accordingly, the TMIA comments regarding the " audit" must be viewed in the true context of the report.
-- TMIA criticizes Mr. Arnold first for not recall-
~
ing and then for not agreeing with concerns expressed in the interviews of TMI supervisory personnel thac " upper manage-ment" did not have trust in their abilities and permitted too much "buckpassing" by not holding supervisors accountable in their areas of responsibility.
As to the purported lack of recollection, the 1982 deposition testimony to which TMIA cites makes clear that while Mr. Arnold four years later did not recall these specific findings in a Met-Ed memorandum that may not have been sent to him, he did testify that "these types of concerns on the part of the supervisory levels within the organization were generally known to me and I think that I would not agree with many of those assessments."
(Arnold dep.
388.)
In regard to the merits of Mr. Arnold's disagreement, as a member of " upper management" he was certainly in a posi-
' tion to express his view as to the real source of the concerns expressed.
Thus, Mr. Arnold explained that, in his view, the interview responses to some extent grew out of the require-ments in the nuclear industry which differ from those in the areas (such as fossil plants) that many of the employees were accustomed to, and that upon entering the nuclear industry 63
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some reorientation had to take place (Arnold dep. 388).
- Thus, what a lower level employee might characterize as "buckpass-ing" would merely reflect a disgruntlement with the fact that Met-Ed and GPU supervision and management were more involved in his day-to-day activities than he was accustomed to in pri-or, non-nuclear positions.
-- TMIA criticizes Mr. Arnold for not recalling or agreeing with a post-accident statement by Gary Miller about the difficulty of firing someone at TMI.
However, TMIA cites nothing which suggests that Mr. Arnold was not justified in disagreeing with Miller that GPU had any particular problem in this regard.
In view of federal regulations on equal opportu-nity for various groups, unfair labor practices, union in-volvement and the like, the extensive procedural requirements to support the firing of employees is a universal constraint on American industry.
-- TMIA, implies incorrectly that there is some in-consistency between Mr. Arnold's testimony that he disagreed l
l that " members of the operating staff" had too great a work load at TMI-2 in 1977-78, and his testimony that there was a "need for very heavy commitments on the part of senior members of the staff."
The fact that relatively heavy time commit-l ments are required by senior staff members to complete a major 1
project, such as the startup and test of a nuclear plant, does not mean that such commitments are "too great" in the context of such a project.
i 64
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-- TMIA implies that Mr. Arnold admitted he was re-sponsible for solving the problems identified in the 1978 au-dit and other audits inasmuch as he was the " focal point" fer addressing these issues.
TMIA mischaracterizes the testimony.
The term " focal point" was used by Mr. Arnold in response to a question in his deposition as to why Mr. Herbein, a Met-Ed em-ployee, was discussing some of the problems raised by the 1978 interviews with Arnold, who was head of the GPUSC Generation Division.
Arnold simply explained that some of the issues, which had been raised by Met-Ed's employees, were already be-ing addressed by him on a system-wide basis, so that he "was sort of the focal point for assuring that the systemwide dis-cussion of these issues was undertaken [and] that we were able to get resolution of some of the systemwide policies and prac-tices necessary to address these kinds of problems."
(Arnold dep. 352-54.)
This testimony plainly reflects a responsible approach by management.
TMIA also asserts that Mr. Arnold purportedly "ad-mits" that the same problems discussed in the 1978 interviews were found in a 1975 " audit" that Mr. Arnold had initia'ted.
I Mr. Arnold explained that in 1975 there had been an analogous although less structured effort to ascertain the nature of managerial problems and to obtain recommendations to address them (Arnold dep. 347-48).
However, he explicitly refuted the suggestion by the cross-examiner that the same problems had l
continued, and instead explained that circumstances and spe-i 65 i
l l
i
cifics had changed.
The reasons that the areas examined for problems in 1975 and 1978 were the same is, as Mr. Arnold ex-plained, because they were a reflection of the kinds of activ-ities in which the company was engaged during those time peri-ods (Arnold dep. 350).
TMIA is plainly off base for criticiz-ing Met-Ed management for conducting interviews which focused on subjects similar to those covered three years earlier.
Rather, management acted responsibly in making continual ef-forts via the interview or " audit" procedure to revisit poten-tial problem areas, identify current concerns and take posi-tive steps to make improvements.
The 1978 interviews referred to by TMIA indicated that, as with prior analogous efforts, the focus of the 1978 effort was on concerns over the division and assignment of management responsibilities within the company (B&W Ex. 843).
Testimony in the B&W trial record establishes that steps were being taken to deal with just those concerns.
For example, Mr. Miller testified that the company was moving towards the management organization that had been suggested by an indepen-dent audit conducted in 1977 by an outside consulting firm (Miller dep. 74).
Those changes included putting Mr. Miller in a more direct reporting relationship with Mr. Herbein, and improving the organization of the training department (Miller dep. 74, 541-43).
The responsiveness of Met-Ed and GPUSC man-agement to the issues raised in company reviews is further ev-idenced by the minutes of meetings held after the 1978 " audit" 66
was performed, in which action items were established for each area of concern discussed in the audit (B&W Exs. 884, 883; Herbein dep. 362).
In view of these and other actio~ns being taken to respond to identified problems, Mr. Arnold was acting appropriately and responsibly as a member of GPUSC's senior management.
-- TMIA cites Mr. Arnold's testimony that he under-stood Gary Miller's statement in 1979 that a " dollar crisis" existed at TMI to refer not to a shortage of " total dollars" svailable at TMI, but rather to the dollars available for
" compensation packages."
(Comments, p. 60.)
There is no ba-sis.in fact for disputing Mr. Arnold's interpretation of Mr.
Miller's statement, which appears in a memorandum under the 4
heading " Personnel Retention & Hiring."
Mr. AEnold further testified that in the 1978-79 time frame, he and others were examining the competitiveness of the salary levels and grades of the' TMI plant staffs; that he talked with human resources people regarding data on industry practice; and that in early 1979, fairly substantial modifications had been made to staff salaries (Arnold dep. 404-05).
-- TMIA's effort to criticize Mr. Arnold with re-spect to Met-Ed's selection of Richard Zechman as head of~its training department at TMI-2 is misguided for the reasons
,a stated above in the discussion of Mr. Zechman's qualifications (pp. 45-46).
Zechman's position was primarily that of an ad-ministrator and a teacher of theory, for which he was well-67 c
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_ _. _, _ -. _. ~. _ _ _ _, -. _ _
o qualified and which did not require an operator's license.
Furthermore, Mr. Arnold's testimony, like that of Mr. Herbein and others, indicates that there was appropriate direction of the training program during the period Zechman was studying for his license (Arnold trial tr. 1705).
-- TMIA asserts that Mr. Arnold admits that Met-Ed failed to instill in its operators a sense of respect for its post-accident training program.
The statement to which TMIA refers was made to the NRC by an attorney for GPU Nuclear, who was referring to incidents of operator cheating after the ac-cident.
Mr. Arnold was asked about that statement during the B&W trial in the context of an evidentiary issue.
The fact that Mr. Arnold supported the company's candid recognition, expressed through counsel, and had been involved in developing that assessment of the problem indicated by the incidents of operator cheating, reflects well upon Mr. Arnold, as do the corrective actions subsequently initiated by the company to further ensure appropriate operator attitudes towards training and testing.
During the course of Mr. Arnold's direct testimony, counsel for B&W objected from time to time that Mr. Arnold, as head of Generation of GPUSC in Parsippany, had had insuffi-cient direct contact with certain day-to-day affairs at TMI to provide admissible testimony-on those matters.
(See Arnold i
trial tr. 1504, 1506.)
Therefore, on cross-exa.mination, al-though testimony regarding post-accident events generally was 68 i
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F excluded from evidence under Rule 407, B&W's counsel was al-lowed to ask about Mr. Arnold's awareness of the July, 1979 vv incident in order " arguably" -- as the Court put it -- to de-velop contentions as to Mr. Arnold's knowledge of Met-Ed oper-ations in general and particularly training.
TMIA misleading-ly suggests that the Court's ruling went to an is' sue of fact rather than being, as was the case, an evidentiary ruling as
~to the areas on which Mr. Arnold could be examined.
The Court merely ruled that evidence concerning Mr. Arnold's knowledge of and reaction to the VV incident was admissible.
Mr. Arnold then went on to testify that when he learned of the VV inci-dent he took quick and decisive action to apply appropriate sanctions for the circumstances as he then knew them, and to remove Mr. VV permanently from his supervisory position (Ar-nold trial tr. 1749-50).
-- TMIA criticizes Mr. Arnold because he allegedly "still does not recognize that Mr. VV. cheated in 1979."
For this erroneous proposition, TMIA cites Arnold's deposition taken in July 1982 -- a time when all of the facts relating to VV's conduct were not yet known to Mr. Arnold.
Even at that time, Mr. Arnold had imposed serious disciplinary action upon
]
VV by having him permanently demoted.
Moreover, after reading the ASLB Partial Initial Decision (Reopened Proceeding - TMI-l Restart), dated July 27, 1982, on operator cheating issues, Mr. Arnold, in August of 1982, initiated the Speaker investi-gation, an independent inquiry into, among other things, the 69
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circumstances surrounding VV's actions on the make-up examina-tion in the 1979 training program.
After obtaining all of the facts resulting from these investigations, Mr. Arnold recog-nized that his initial understanding of the circumstances of the incident may have been faulty and led to an erroneous con-clusion as to whether VV had cheated (Oral Presentations on TMI-l Restart, Nov. 9, 1982, Presentation of Mr. Arnold, pages 31-32).
-- As is discussed above (pp. 7-8), TMIA blatantly miscites Mr. Arnold's testimony for the proposition that "Ar-nold still insists that pressurizer level and pressure trend together."
In fact, the testimony cited by TMIA deals not with Mr. Arnold's present understanding, but explicitly and exclusively with Mr. Arnold's Navy training, received over ten years before the TMI accident.
-- TMIA next misconstrues Mr. Arnold's testimony with respect to the response of RCS pressure to a rise in pressurizer water level.
During normal operations, there is a steam space at the top of the pressurizer.
Dr. Richard Lahey, expert trial witness for GPU, testified that an increase in pressurizer water level would result in some condensation of that steam and therefore that one would not experience the same increase in pressure as one would when dealing with a perfect non-condensable gas, as in Boyle's law (Lahey trial tr. 330-31).
The general context of the Arnold testimony cited by TMIA, as well as the question posed to Mr. Arnold by 70 7.7
p B&W's counsel, make it clear that Mr. Arnold was testifying to the same effect as Dr. Lahey (Arnold trial tr. 1605).
Moreover, TMIA mischaracterizes the hot functional test of September 1977.
It is wrong that "it took days to re-move the steam which had formed in the reactor coolant system."
The test logs indicate that the day after the possi-bility of a steam bubble was suspected (its existence was nev-er proven), the engineers applied nitrogen to the pressurizer which apparently collapsed or purged from the system any bub-ble that may have developed in the RCS (B&W Ex. 175 at p.
WO6073).
TMIA's reference to trial tr. 1473 -- a colloquy among counsel on an evidentiary point -
has no bearing on the proposition for which it is cited.
Nor is there any other ba-sis for TMIA's allegations that "one of the most important lessons" of the September 1977 test event, was that "a steam bubble cannot be compressed by a mere increase in pressure."
This conclusion by TMIA is wrong -- in the circumstances of the September 1977 event, any possible steam bubble in the legs of the reactor coolant system would have been quickly compressed by an increase in pressure.
(See B&W Ex. 877, TDR 286, 10/7/81.)
In any event, Mr. Arnold did not testify about this proposition one way or the other.
He merely said in re-gard to the steam space at the top of the pressurizer, that steam is not a perfect gas which is subject to Boyle's law, and, that since there is some condensation of steam, it dif-fers in behavior from an ideal gas.
That proposition is an 71
a 9
inarguable scientific principle, supported in the trial by Dr.
Lahey as well as a B&W document (GPU Ex. 2347, p. 55).
-- TMIA's final Comment, with respect to Mr.
Arnold's testimony on the problem of water in the instrument air lines, is also wrong.
As set forth above (pp. 27-28), the testimony it cites deals excluaively with Mr. Arnold's under-standing of the problem in 1978, not with his perception of the problem after the accident.
TMIA has failed to present any evidence from the GPU
- v. B[jW trial record, or any other source, that detracts from Mr. Arnold's exemplary record throughout his tenure with GPU Nuclear, GPUSC and Metropolitan Edison.
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APPENDIX A i
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da:a May 2, 1978 kRd,SerVECO Su:Ec TMI 2 Cooldown Trannient of April 23, 1978 To Mr. R. W. Kesten Locabon Mountain Lakes We have been requested by Met-Ed Ceneration (J. C. Herbein) to take the lead respon.wibility for conducting a thorougn investigation and analyses j
of the subjcet incident. You are assigned as Chairman of an AdHoc Committee -
consisting of yuurscif and Hessrs. T. G. Broughton, R. C. Cutler, Jr., J. L.
Seelinger, R. M. Toole end E. C. Wallace - to conduct the investigation and prepare appropriate interia and final reports. The investigation should include:
1.
A detailed chronology of the physical events from the time of initiation of the incident until establichment of normal plant conditions.
2.
A review of the automatic response of the plant and the manual actiuns taken by the operator, the consistency of both automatic and manual response with the design philosophy for the unit.
- and the appropriateness of the design philosophy in light of the circumstances of the incident.
3.
The cause for the failure of the steam generator safety valve discharge pipe and expansion joint liners and the adequacy of the corrective act. ion.
4.
A preliminary review of any concerns about the adequacy of plant instrumentation and control raised by Start-Up and Test or plant staff personnel.
5.
Any items which come to your attention which you believe warrant further investigation.
I Your committec should provide a preliminary oral report in a meeting scheduled with Met-Ed Cencration at its facilities at Wyomissing 'for 1:00 p.m.
on Honday, b y 8, 1978. The primary purpose of that meeting vill be to discuss the information developed as of that time and identify any open items which need to be resolved prior to a re-start of the unit. Also, at that time please be prepared to provide me with a target date for a preliminary written report.
A group headed by Jim Seelinger of Met-Ed has been collecting and analyzing information on the incident and I request 'you work with Ron Toole and Jim to i
insure we take full advantage of the efforts to date in this, regard. You have l
the freedom und authority to utilize resources within the Division and at Burns and" Roe as appropriate.
Picase keep Messrs. Heward, Hirst and Wilson apprised l
of your efforts.
I R.C.prn'old l
hatt CPU ik. vs.c Curuv$on i:.a s.utdaary of Coswyh L%LK VLuc; Ca u:xL:n
z, V. RECOMMENDATIONS A.
Prior to Restart 1.
The liners in all horizontal bellows should be replaced by thicker liners designed for the anticipated service conditions.
(Complete) 2.
Analysis by Burns and Roe indicates that the liners in the vertical bellows may be acceptable for at least the next fuel cycle.
This analysis should be carefully reviewed for acceptability.
(Complete) 3.
Tests should be performed to determine (as precisely -
as possible) the blowdown characteristics of each safety valve.
This can be accomplished by heating the system with the reactor coolant pumps to achieve a steam pressure of 950 - 1000 psi, using a hydraulic assist to individually pop the safety valves, and observing at what system pressure valve resents.
(New valves being installed) 4.
The C1 contamination caused by the safety injection should be cleaned up.
(Complete) 5.
Defective components in Nuclear Instrumentation Channels NI-5 and NI-7 should be replaced.
(Complete) 6.
Recorders should be installed to monitor selected l
positions in the circuitry for NI-8, to attempt to determine l
the woint of origin and cause of the spurious spikes which have been observed on this channel. (Complete) l 7.
Set points should be adjusted in the feedwater control l
system to eliminate the instability which occurred in the transfer from the start up control valve to the main control valve.
To help select the appropriate transfer point, the shut off leakage in the main feedwater control valve should be measured, if necessary.
(Complete) 8.
The control system for the pressurizer pressure and level should be tuned up to reduce the cycling which was observed during power escalacion prior to the trip. (Complete) 9.
Checks should be made on a representative sample of pressurizer heaters, to verify that the low level in the pressurizer did not affect the integrity of the. heaters.
(It is recognized that the best test of the heater integrity may be obtained during system heatup-and operation).
(Complete) i I
10.
The feedwater latch system should be checked to verify that it will fully close the FW Block Valve at (or near) design d P, and that it will not interfere with operation of the emergency feedwater system.
(Complete) 11.
The B&W assessment of the impact of the transient on the RCS should be reviewed for concurrence with the assumptions as to the nature of the transient.
(Complete) 1 B.
As Soon As Practical 1.
The Task Force understands that a source of sodium Hydroxide with chlorine contamination less than approximately 0.1% has been located.
An adequate supply of this low chlorine sodium hydroxide should be purchased and used to replace the existing sodium hydroxide.
(Complete) 2.
The logic for sodium hydroxide injection should be modified so that a combination of low reacxor coolant system pressure and low level in the borated water storage tank is required before injection occurs.
This requires a modification to the tec h ical specifications, as well as viring changes.
(Complete) 3.
Some method of monitoring when safety valves pop and (if practical) when they reaeat should be installed.
(Complete) 4.
Open/ closed indicaters for the turbine bypass valve and the main feedwater block valve should be installed in the control room.
Action - GPUSC 5.
There are some indications that the "A" turbine bypass valve responded sluggishly to the transient overpressure.
The resmonse of this valve and its controller should be checked.
Action - GPUSC 6.
There were indications that the #3 turbine stop valve did not close completely.
The valve and the indicator should be checked and if necessary repaired.
Action - GPUSC
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9
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C.
Longer Term 1.
An alternate configuration for the relief valve piping should be explored in an attempt to eliminate the need for bellows.
Action - GPUSC 2.
An alternate system for safety injection which avoids the use of sodium hydroxide (and thus chlorine) should be explored.
Action - GPUSC 3.
The following aspects of the plant control system should be reviewed to determine if modifications are desirable.
(GPUSC) a.
The transfer point from the startup feedwater -
valve to the main feedwater control valve, and the valve trim.
b.
The set points for the turbine bypass valve.
c.
The actuation logic for the atmospheric dump valve.
4.
An in-house capability for performing transient analysis should be developed.
This should permit a prediction of how the system would respond under various upsat and emergency transients, as well as after-the-fact analysis of unanticipated transients.
In addition, this capabilit can be bsed to optimize the control system.
(In Progress 5.
B&W should be instructed to complete the fatigue analysis left as open items in their recent review of the impact of the transient on the RCS.
Action - GPUSC 6.
To permit accurate post event analysis, the possibility of obtaining up to five minutes of post-trip, five resolution data, such as that available from the reactimeter, should be investigated.
Action - GPUSC O
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