ML20086G489
| ML20086G489 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/16/1995 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| OLA-3-I-MOSB131, NUDOCS 9507140413 | |
| Download: ML20086G489 (41) | |
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&~YZ4 25- G h 3 Z wsan ,e/.,a-sn222 s/a/es MR. ROBINSON: y, 1 It is now 11:36 a.m.$E 0FFICE OF ,
2 AugGst 14, 1990. This is an intervie1000Kff Ci 3 employee of Georgia Power Corporation at Vogtle Electric !
4 Generating Plant. The interview is being conducted on 5 site at the Vogtle plant. The interview pertains to 6 information compiled regarding diesel generator start 7 information and a DC card regarding the timing of the 8 signature on a temporary change to procedure form.
9 Present at the interview are Mr. Cash, Mr. Art Domby, from 10 the firm of Troutman, Sanders, who is representing Mr.
11 Cash here today, Mr. Pete Taylor from NRC Region Two, Mr.
l 12 Bob Carroll from NRC Region Two, and Larry Robinson from 13 NRC OI. Mr. Cash, do you have any objections to being 14 sworn to your testimony here today?
15 MR. CASH: No, sir.
16 NR. ROBINSON: Please stand and raise your i 17 right hand. Do you solemnly swear that the information l 18 you are about to give in this matter is the truth, the 5 19 whole truth, and nothing but the truth, so help you God?
l j 20 MR. CASH: I do.
3 21 MR. ROBINSON: Thank you. Prior to getting l }
n 22 into the substantive portion of the interview, Mr. Domby, i 2 l 23 would you briefly explain the nature of your i 2 5
24 representation of Mr. Cash?
25 MR. DOMBY: My name is Art Domby. I i 1 @{T k 9507140413 950516 PDR ADOCK 050004 4 PR / OF_N PAf P(S) d T
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1 represent Mr. Cash as his personal representative here !
2 today in this interview. I also serve as general counsel 3 to the Nuclear Operations Department of Georgia Power 4 company. Mr. cash and I have discussed my representation 5 of dual clients. If a conflict of interest occurs or is 6 identified by me, I will inform both him and Georgia Power 7 of that; I see no conflict of interest at this time.
8 MR. ROBINSON: Mr. cash, are you satisfied with 9 Mr. Domby's representation of you here today?
10 MR. CASH: Yes, sir.
11 MR. ROBINSON: Just for the record, a 12 transcript of this interview will be made available for !
13 your review and correction in the NRC resident's office on i
14 site probably within two days from now, as soon as 15 possible. As soon as they become available to us, they ,
16 will be made available for your review and correction.
I 17 And at that time if you desire and request it a copy of l
! 18 that transcript will be made available to you.
3
,i 19 MR. CASH: Yes, sir.
l l 20 MR. ROBINSON: Mr. Taylor.
i y 21 MR. TAYLOR: Thank you.
g 22 3
X 23 EXAMINATION 2
5 24 BY MR. TAYLOR 25 Q. I need to ask a few questions concerning unit one 2
1 J
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, i 1 diesel generator starts, reliability and operability of the l _
i 2 unit one diesel generators. The period of time I want to
- 3 discuss is between March the 20th, 1990, to April 19th, 1990,
- 4 and the documents that are involved with that time frame are
- 5 the presentation by Georgia Power in regional office, which was 6 April the 9th; Georgia Power's letter ELV 1516, dated April 7 9th, which was response to our confirmation of action letter 8 issued March 23rd, 1990; and there was an LER on the same 9 subject matter, LER 90-006, revision 0, dated April the 19th, 10 1990. Who compiled the diesel generator 1-A, 1-B successful 11 start information used in the regional presentation?
12 A. I did.
13 Q. What instructions were given to you to get this data?
14 Who gave you the instructions to obtain this data?
15 A. George Bockhold.
16 Q. What was his instructions?
i 17 A. His instructions were to review the log books and
! 18 determine how many starts we had had with no significant 4 19 problems. The term successful valid starts did not enter into j 20 the conversation, because at that time most of these starts a
i 21 were troubleshooting starts, maintenance restarts, and as such r
g 22 were not successful valid starts. So I was not looking at it a
g 23 from that aspect, just merely reviewing the logs to determine j 24 the number of starts that we'd had without significant 25 problems.
4 3
l
1 Q. Where you were -- what type of logs were you ,
1 2 reviewing?
3 A. I reviewed . . .
4 Q. What type of data?
5 A. I reviewed the unit control logs and the shift 6 supervisor's logs.
7 Q. When was that information compiled?
1 8 A. It was -- I don't remember the date, but it was the 9 day before, I believe, the confirmation meeting in Atlanta.
10 Q. Uh-hum (yes). Other than the operator logs, were 11 there any other sources used to gather information on the 12 diesel generator? )
l 13 A. I did not use any other sources. i 14 Q. Just the logs?
15 A. Yes, sir.
16 Q. What type of information would be in those logs with ;
j 17 respects to starts, successful starts, type of information that l 18 you would find in those logs?
3 1 l 19 A. For these starts in general -- and like I say, most l 20 of these starts were maintenance troubleshooting starts -- the s
i 21 information that would be logged would be, " Started diesel g 22 generator 1-A for maintenance troubleshooting, tripped diesel 2
23 generator 1-A per over speed trip," you know. That was the 5 24 type of log entries that I was looking at; very short, very 25 brief.
4
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! 1 Q. Why was this information being compiled on the diesel 5 _
- 2 generator? The information that you were obtaining, why was j
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2 3 that being compiled?
3 4 A. For the presentation for the confirmation letter, to 4
5 determine the number of starts that we had had upon -- with the i
j 6 diesel without significant problems.
J j 7 Q. Uh-hum (yes) . What was your involvement in the 1
l 8 preparation and review of the diesel generator start i 9 information? Did you sit -- after you collected your i
! 10 information, did you participate in the -- with George or other j
} 11 people in doing something with that data?
t j 12 A. I turned the data over to Mr. Bockhold and he
\
j 13 prepared some point papers, which I assisted Gloria Walker, his i 14 secretary, with the format only . . .
i
} 15 Q. Uh-hum (yes).
\
i 16 A. . . . because she had a -- he was very briet with his
! i: 17 description of the format and I understood the format he wanted)
I ! 18 better than she did. But I had no other . . .
! r ,
.: 5 19 Q. What format did you give Mr. Bockhold that 1
1 i 20 information?
1 i
! j 21 A. I'll have to think back minute.
I k
- g 22 Q. I'm thinking in terms of documentation of the -- how I
1
. g 23 did you transmit this information to Mr. Bockhold?
1 j
j 24 A. I had a -- I listed the information in a table form 25 that had date, time started, reason started, and any other 5
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1 information that would -- and a comments section. I had that table, I also had a summary of number of starts, and I believe
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3 I gave both of those to Mr. Bockhold. He used, I think, mainly l
i 4 just the summary of starts. l 5 Q. Was that in memo form to him?
6 A. No, it was -- it was not in memo form, it was just a j 7 vritten list, and at the confirmation -- the hearing on what 8 the terminology is for -- at the meeting in Atlanta, I turned I i 9 that information over to Mr. Burr, Kim Burr. He requested '
10 that, and I didn't have a copy of it, I just gave him my list.
11 Q. Is that, then, the same information that you provided i
i 12 Mr. Bockhold, you provided the NRC, Mr. . . . l 13 A. No, Mr. Burr is corporate . . .
14 Q. Ken Burr?
15 A. Ken Burr is corporate engineering.
16 Q. Okay. Are you familiar with the transparency that j i 17 they used for the presentation in Atlanta on the status of the
! 18 diesel generators?
19 A. I remember it but I couldn't tell you what was on it
- 20 exactly. I mean, I remember there was a transparency, but I
-l i
i l 21 don't remember the details of what it contained at this time.
4 r
.; g 22 Q. I'd like to show you that transparency and make a
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9 23 couple of questions in that area, if I could.
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i g 24 A. Sure.
i 25 Q. I'm handing Mr. Cash a paper, one sheet, that reads :
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1 at the top " Diesel Testing," a series of tests under one column l 2 labeled 1-A, another labeled 1-B with -- at the botton, column l 3 1-A has eighteen successful starts and column 1-B has nineteen l 1
l j 4 successful starts.
5 A. Yes, sir.
i i 6 MR. ROBINSON: Do you recognize that as . . .
j 7 A. Yes, sir.
1 1 8 MR. . ROBINSON: . . . the transparency?
l J 9 A. Yes, sir.
i l 10 Q. The listing of data that's on this . . .
8 l 11 A. Transparency.
j j 12 Q. . . . transparency here, is that the sequence of I
i 13 information that you gave to Mr. Bockhold?
1 14 A. Yes, sir. l 1
! 15 Q. What time period does these starts represent with
- 16 respect to counting up eighteen successful starts and nineteen l i 17 successful starts? Can you give me a start and ending point i ! 18 with this data?
I l f 19 A. The start point is the night of 3/20 with the i l
! i 20 troubleshooting starts that we did on 1-A.
1 i
! 21 Q. Uh-hum (yes).
ii g 22 A. The ending was sometime shortly before the meeting in 2
i 23 Atlanta. I do not know the date of that.
< I
) j 24 Q. Are there more than eighteen or nineteen successful 25 starts with respects to the data that's on that diesel testing, i
J i 7 1
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s 1 the transparency that was represented in Atlanta?
l 2 A. ~ I don't understand the question.
3 Q. The -- are there only eighteen successful starts, 4 nineteen successful starts on this piece of paper, or are there 5 more starts?
6 A. That was all the starts that I was aware of at the 7 time.
8 Q. Do you have a number -- is eighteen and nineteen the 9 number that's represented?
1 10 A. Those were the numbers that I came up with at the 11 time, yes, sir.
12 Q. The term " successful start," what does that mean to 13 you?
14 A. There is a term " valid successful start," that is 15 fairly well defined which, at the time, I did not look at 16 things as valid successful starts because, like I've stated i 17 before, these were troubleshooting starts and maintenance 18 restarts. I only looked at starts where from the log entries 5
,5 19 it appeared the diesel started, it ran, we tripped it for
! 20 troubleshooting reasons, and that's as much as I had time to do i
j 21 and get the information for Mr. Bockhold. I did not go into g 22 any great details in my research. In other words, let me see 2
23 if I -- I looked at just successful maintenance starts, not 5 24 valid successful, operational, declared operable, starts. I 25 did not look at it from that point of view.
8
1 Q. Okay. So what does the term mean " successful start" 2 by itself, not adding -- is there a . . .
3 A. Not using the term " valid," it means nothing.in the 4 official terminology of diesels.
5 Q. Okay.
6 A. In the official terminology.
1 7 MR. DOMBY: What you're saying then, these l
8 cre eighteen and nineteen instances where the diesels were 9 attempted to be started and you viewed it as they started?
l 10 Whether or not those are valid tests or . . .
11 A. Correct.
12 MR. DOMBY: . . . surveillances or whether 13 or not they were required for emergency conditions, or l 14 whether or not they were required for testing and 15 troubleshooting, simply, they ran? Is that it?
16 A. Yes, sir.
( i 17 Q. Mr. Cash, does the term " successful start" have any 18 statistical value when evaluating diesel generator reliability 19 and operability?
!i 20 A. Not without valid or invalid in front of it, that I'm i i i 21 aware of.
ig 22 Q. What do you believe to be the reliability and
- 3 j 23 operability status of the diesel generator 1-A and 1-B when
- j 24 unit one entered mode two on April the 15th?
25 A. I believed -- I believed them to be totally reliable l
4 9 5
8 4
i I
1 and operable.
~
2 Q. Georgia Power Corporation issued a letter on April 3 the 9th, same time frame as the presentation in Atlanta; this 4 was a response to the confirmation of action letter that we had 5 issued, and that letter stated that, "Since March 20th, 1990, i
1 6 had eighteen successful starts, diesel generator 1-A, nine'een c 7 successful starts, diesel generator 1-B. No failures or ,
I l l
8 problems have occurred with any of these tests." What does the 9 statement, "No failures or problems have occurred with any of j 10 these tests," what does that mean to you?
11 A. It means that no failures -- exactly what it states, j 12 that no failures or problems had occurred with any of these.
13 Q. Right. Did you participate with the data and the
} 14 formation of this data . . .
i j 15 A. No, sir. !
i 1'
! 16 Q. . . . for this April 9th letter?
{ ! 17 A. Other than the fact that I believe the data was taken 1
! 18 from these numbers, I would have had no prior knowledge of the
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! 19 letter until after it was issued.
i
! j 20 MR. DOMBY: So you didn't participate in its i
j i 21 preparatior.?
+
i g 22 A. No, sir.
2
- j 23 MR. DOMBY
- "Its" being the April 9th 5 24 letter?
1 25 A. Correct.
10 I ;
_ _ _ . . - . . . . . , , , , . . . . . - . _ - , . . . , . . . , , , , . _ , . , . . . . ~ , - . . . -
e i 1 MR. ROBINSON: Do you know who drafted the 2 letter?
j 3 A. No , sir.
]
4 MR. ROBINSON: Do you know if it was drafted on j 5 site here at Vogtle or over at SONOPCO?
6 A. No, sir, I do not.
i 7 Q. LER 90-006, issued April the 19th , stated that 8 subsequent to the test program diesel generator 1-A and 1-B f 9 have been started at least eighteen times each and no failures l 10 or problems during any of these tests. Did you participate in i
) 11 this IZR . . .
i l 12 A. No, sir.
! 13 Q. . . . preparation?
' No, sir.
14 A.
15 MR. ROBINSON: Do you know how that number of 16 starts was arrived at in the wording in that LER?
e
! ,I 17 A. I believe that that number of starts in the LER and 18 in the letter were derived from this information. But this i 5 i j 19 intornation was never intended to be used for that purpose, and i
j j 20 all'it was was some information, and it was particularly
- 3 i ! 21 because the information that was presented here was already I
i i g 22 known to the majority of the people in exactly the context in ;
i 3 j
2 j 23 which it should have been understood by the people that were at j3 24 the meeting on -- in Atlanta.
t j 25 Q. Now, here we are on April the 19th; were you i
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1 instructed, ordoyouknowofanybodyelseinstructedtogooutf l
l 2 and take a look at logs, diesel generator start data, to I
- 3 confirm any of these figures that are in the LER?
1 l 4 MR. DOMBY: Are you aware of any actions 5 taken by Georgia Power personnel to confirm the numbers of 6 eighteen or nineteen as it's reflected in the LER?
7 A. I know that there were actions, but I do not know the 8 dates at which they took place. I remember that there was some 9 questions about the numbers, but I think that by the time I was 10 aware that the letter and the numbers were in the LER and that 11 there was questions about the numbers was after everything was 12 issued, the LER and the letter were both issued.
13 MR. DOMBY: Did you and up having to go out 14 and reverify the counts?
15 A. No.
16 MR. DOMBY: You didn't?
I 17 A. I did not.
I 18 Q. While you were issuing the LER 90-006, did you or 19 anyone else you know make a phone call to anyone in the NRC i 20 regional office concerning the diesel generator start a 4 i 21 information that was going to be in the LER?
g 22 A. No, sir.
3 23 MR. DOMBY: In other words, you didn't and i 24 you're not aware of anybody else that did?
25 A. I didn't, and I'll be honest, I did not see the draft 12
l i
1 LER, so I wasn't even aware that the numbers were in it.
2 Q. ~ All right.
3 MR. ROBINSON: And you were not aware of any 4 phone call?
5 A. I'm not aware of any phone call, no, sir.
I 6 Q. On June 29th, a revision one came out to LER 90-006 l
7 adding clarification with respects to diesel generator starts 8 on April the 9th and the LER 90-006 issued April the 19th.
9 This LER specified the starting and an and point for the 10 activity. Did you participate or . . .
11 A. No , sir.
12 Q. . . . work on this information?
13 A. No, sir.
{
! 14 Q. Now, what they did, they established the first l l 15 successful test as the procedure 14980-1 as the starting point i
i 16 and the end point being April the 19th. Who, to your knowledge i
17 -- do you know . . . l 18 A. I do not know.
s e l f 19 Q. . . . who collected that data?
1
,i j 20 A. I do not know.
. 3
} 21 MR. DOMBY: If you don't know, we can find
)g 22 out for you.
7 i j 23 Q ., Well, I'm still inspecting, so I can probably . . .
j 24 MR. DOMBY: Okay.
25 Q. . . . get that.
4 13 A
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1 MR. DJMBY: All right.
2 A. Can I . . .
3 3 Q. Go ahead.
l l
4 A. There were several -- I believe there were several 5 groups of people actually counting the number of starts. I 6 know that Mark Agaluni's (phonetic spelling) group, Q.A., was, 7 and I believe that engineering was also. To say -- but I do 8 not know where the numbers official came from that ended up in 9 the LER at the end.
, 10 Q. The LER or revised?
11 A. The revised LER. I to not know where those numbers 12 came from. I do know that there were several groups on site 13 that were -- that were counting.
14 Q. Prior to issuing that revision one to LER 90-006, did 15 you or anyone else you know make a phone call to anyone in the 16 regional office cor.cerning the diesel generator start
, je 17 information that was going to be placed in this revision?
18 A. No , sir. I'm aware of no phone calls that were made
! 19 to the regional office or to any other NRC person at any time l 20 regarding the number of starts that were in either the LER or l
i s i
! 21 the letter.
, g 22 Q, Okay.
3 23 MR. DOMBY: Did anyone ever raise a concern 5 24 to you about the number of starts either reflected in this 25 chart or the LER . . .
14 i .
',.. . . j i
1 A. There was . . . I 2 MR. DOMBY: . . . in this time frame?
} 3 A. I know there was a question and I was asked, and I
- l 4 can't remember who asked me now, where did I get the numbers.
5 And I explained to them how I came up with the numbers that I i
, 6 came up with, exactly as I've explained it to your that it was 7 never intended to be considered valid successful starts, that 8 it was troubleshooting starts that occurred with no significant 9 problems.
10 MR. DOMBY: Okay.
11 Q. I have no further questions.
12 13 EXAMIN'. TION 1
14 BY MR. ROBINSON 15 Q. A couple of questions. When Mr. Bockhold instructed 16 you to get a count on the number of starts without significant .
l 3
- 17 problems, during your process of making that count did you note 18 starts that did have significant problems?
19 A. No, sir. I noticed some . . .
j 20 Q. Were you asked . . .
4 3 i 21 A. . . . starts that did have some problems, but none
! 22 were significant.
g 5
E 23 Q. Okay. Relative to the number of starts that were
,5 24 successful, what were the numbers that had some problems?
25 A. There were only two or three that were identifiable b
- i 15 i
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4 l l i
l 1 by log entries, and they were typically items like high fuel :
- I
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l 2 oil filter DP alarm came in, which is something that 3 occasionally happens when we swap filters. This is not a j l
4 significant item. l 5 Q. Did you have any discussions at all with Mr. Bockhold 6 about those problems or . . .
j 7 A. No, sir.
- 8 Q. . . . small problem starts?
I 9 A. I do not recall having such a discussion.
i
! 10 Q. You said you started your counts on the night of J
j 11 March 20th until just prior to the region presentation . . .
- 12 A. Yes, sir.
)
i 13 Q. . . . is that correct? Obviously, the -- is it your l 14 knowledge that basically the numbers of successful starts that 1
15 you developed for the presentation at the region were used in l f
4 16 that presentation, in the confirmation of action response, and l i 17 in the first edition of the LER?
j'
~
18 A. At this time, that is my knowledge. It was -- I was 3
. ,5 19 not aware of it at the time that the letter and the LER were l 20 prepared, though.
[i 21 Q. How do you know that at this time?
1 22 A. Well, because we've discussed it in here and because
! ;g i j 23 I have read the LER. All LER's go into our required reading i
. i 33 24 book and I saw a copy of the letter after I saw a copy of the 25 LER. i 16 e
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1 Q. Okay. And you're aware of the fact that the wording l
2 in the L5R indicates that the number of starts were after the 3 comprehensive test program as opposed to since March 20th, 4 right?
l 5 A. Yes, sir.
6 Q. Okay. And that -- what -- how do you account for the j 7 difference in that time frame, or can you account for the
- 8 difference in that time frame?
.! 9 A. I cannot.
i l l 10 Q. Okay. Was that basically the subject of the 11 correction of the LER, among other things?
12 A. I believe so. I was -- once again, I was not i
13 involved in the recounting of the numbers or anything like
} 14 that, so I really can't say for sure. I have not went back and j 15 reviewed myself and counted again.
16 MR. DOMBY: Okay. I think what you're i 17 saying is you don't know the basis, necessarily, of I
r 18 subsequent numbers used in revising . . .
f 19 A. Correct.
- ; 20 MR. DOMBY
- . . . the LER?
- ; 21 A. Correct.
g 22 Q. I noted that when Mr. Taylor asked you what a 2
23 successful start means with respect to diesel generator 5 24 reliability and operability, you essentially said it means 4
25 nothing?
17 1
],- .
i i i
) 1 A. officially.
1
- 2- Q. officially nothing.
3 A. Yes, sir.
) 4 Q. Did you have any -- when you were gathering the start i
j 5 count for Mr. Bockhold, did you have any discussions with him j 6 about the fact that successful starts by themselves really mean
- 7 nothing officially?
1 8 A. Not when I was gathering it; it was not something 1
j 9 that I really considered when I was gathering the information.
t j 10 After the meeting in Atlanta, as we were leaving and I had seen ;
I f
j 11 this transparency, I did mention to Mr. Bockhold that they were 4 12 not valid successful starts. And George said, "Everybody here 13 knows that because everybody here has been involved. It's not
- l
{ 14 an issue."
l i 15 MR. DOMBY: Okay. When you use terms like i
i 16 valid successful starts, valid failures, invalid failures, j i 17 do these have special regulatory meanings?
1
}! 18 A. It comes straight out of the NU REG, and I forget the ,
5 l 5l 19 number, but it gives definitions of what is a valid start, what I 20 is an invalid start, etcetera, and they're well defined.
lil 2
!! 21 They're in our procedures also.
- r lg 22 Q. Can I ask one more question with respects to valid 4
l;g 23 testing?
I ij 24 A. Yes, sir.
25 Q. Do you know what it takes to have a valid --
i 18
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4 1 successful valid test?
~
l 2 A. Yes, sir.
3 Q, Could you quote that to me?
l 4 A. I can't quote the exact numbers, I'd have to -- as 5 far as time, I think it's eleven split seconds to speed and 6 voltage,.and I'd have to pull the numbers out for what the l
7 boundaries are on that. l l
8 Q. And . . .
9 A. Also, you're required, if you load the machine, that 10 it maintains load and you do not have to shut it down for any 11 reason. There's some requirements on that also.
12 13 EXAMINATION 14 BY MR. ROBINSON 15 Q. Did Mr. Bockhold talk to you at all about how he was 16 going to use these numbers of successful starts other than to 17 just make a presentation out of them?
l
! 18 A. No, sir.
19 Q. He didn't indicate to you that he was going to make a
! 20 reliability or operability judgment based on those starts?
i j 21 A. Not directly based upon these starts, that they were, a 22 you know, part of the troubleshooting process and that we were ,
2 l 23 demonstrating what we had done and how we had gotten to where 5 24 we were. But, you know, it was, like I say, an evolutionary 25 process of determining what our problem was with the diesel.
s 19 i
l .
- I 1 Q. Was the fact that this was just during the troubleshooting process brought up in the presentations to the l 2
3 region, do you recall?
4 A. I do not recall.
5 Q. I don't have any other questions. Do you have any 6 other questions?
7 MR. DOMBY: No, I don't.
8 Q. Do you have any final comments regarding this topic 9 before we go to the next issue, Jimmy, that you want to make?
10 You can take a minute if you so desire.
11 MR. DOMBY: Why don't we go on to the next 12 issue?
13 A. I don't believe I have anything else. That pretty 14 well covered it.
15 Q. All right. The next issue regards the . . .
16 A. Would it be possible for me to take a short bathroom j 17 break?
! 18 Q. Absolutely. Absolutely.
E j 19 (OFF THE RECORD) j 20 MR. ROBINSON: It's 12:10 and we're back on the i i
- 21 record. I'll repeat the question; Mr. Cash, do you have g 22 any final comments that you want to make regarding the U !
23 diesel generator issue?
6 24 A. No, sir.
25 Q. All right. And if not, we'll proceed to the DC on i
20
1 the temporary change to procedure issue. Mr. Carroll.
2 3 EXAM 3 NATION 4 BY MR. CARROLL 5 Q. Mr. Cash, could you please describe your personal 6 involvement with the generation of the final disposition 7 process for TCP Number 18028-C-7-90-1 to the loss of instrument M 9ll4f?o 8 procedure?
9 A. Yes, sir. The TCP came before the PRB, and I forget 10 the exact date but it was, I believe, on a Friday. That -- it 13 was tabled by the PRB because of a recommendation by Skip 12 Kitchens, who was the chairman, that I review it for potential 13 improvements that would enhance the usability of the procedure.
14 I was an alternate member on the PRB on that day because Jim 15 Swartzwelder was not at work and I was filling in for him, 16 okay? I reviewed the procedure. The specifics are the i 17 procedure is split into three sections. One section is an at 18 power loss of instrument error, one section is a mode three l 19 loss of instrument error, the third section is a mode four, j 20 five and six loss of instrument error. The TCP addressed a a
21 plant design change which had taken an automatic closure away f
g 22 from the turbine building instrument error isolation. We had 3
23 found that when this valve goes closed that we lose our -- all 5 24 of our extraction steam feed water supply and we basically lose 25 the secondary system, lose feed flow from the secondary system, 21
1 1
1 so it was not a prudent thing to have occur when we had a temp 2 mod installed, to take the actuation off of this valve, the 3 actuation signal away from this valve, and the TCP was 4 forthcoming. We decided to go ahead and change our procedures 5 to reflect this change in the plan.
6 Skip recommended that I look at the modes three and 7 modes four, five and six section -- sections of the procedure 8 to determine if we ought to leave some type of instructions for 9 the operators to go and manually isolate this valve in case of 10 a loss of instrument error. I looked at that Friday afternoon 11 after it was tabled by the PRB, determined that that would be 12 an enhancement to the procedure. And we prepared a revision to 13 the procedure on Monday and it went to the PRB on the 12th and 14 was approved. I believed that it went to the field on the 15 12th; I was wrong. I . . .
16 Q. The revision?
i 17 A. The revision, yes. [
= ,
! 18 Q. Let me stop you a second . . . I i
j 19 A. Okay.
20 Q. . I'm trying to understand. Are you telling me l . .
i 21 that you've got a TCP in place . . .
g 22 A. Right.
i 23 Q. . . . at the same time you had a permanent revision l I
2 i 24 that was basically doing the same thing, or . . . ;
25 A. Well, we had a TCP. The TCP deleted all references 22 i l
1 in all sections of the procedure to the instrument error --
{
2 turbine building instrument error isolation valve. Okay, what 3 we decided to do was to put instructions in the nonpower 4 operations sections to instruct people to go and manually close 5 this valve, okay? All right, that was not exactly what the TCP 6 did. Okay, do you understand that?
7 Q. The TCP was against the existing procedure which, I 8 believe, was . . .
9 A. Rev. seven. .
10 Q. . . . Rev. seven, okay.
11 A. Yes, sir.
12 Q. And so the revision that you're talking about . . .
13 A. Is Rev. eight, i 14 Q. . . .'is Rev. eight, okay. l l
15 A. Yes, sir.
16 Q. All right.
i 17 A. It was approved by the PRB on the 12th.
! 18 Q. "It" being the Rev. eight?
19 A. Yes, sir.
j 20 Q. Okay.
i;
- 21 A. Okay. The TCP in itself merely reflected the design ,
i r i 22 condition of the plan, okay? The revision that we eventually l2l 4
i g
23 did represented the design condition and gave additional i I l j j 24 instructions to the operators for nonpower conditions on i
! 25 actions to take on a loss of instrument error. So it was an
,( 23 l
i
i
. I. ;
- 1 enhancement to the procedure, okay? It was my understanding !
4 2 that that procedure was issued on the 12th and that the TCP was I
j 3 voided on the 12th.
- . 4 Q. Okay.
5 MR. ROBINSON: What are tha mechanisms to void 6 the TCP?
7 A. The department head disapproves the TCP.
8 Q. You said you were acting for Swartzwalder . . .
9 A. Yes, sir.
10 Q. . . . in the PRB, who basically would be the division 11 head for that TCP at that time?
12 A. Yes, sir.
13 Q. Okay. What was told to you by the PRB in that 14 regard? Did they -- with regard to the TCP, what's . . .
15 A. A statement was made that Jim had marked approve, he 16 had done this without -- and I've talked with him subsequently i 17 about this and he agrees that he should not have, that he I
18 should have disapproved it, and we should have done -- the 19 procedure should have been revised as it was revised, rather l 20 than deleting all mention to it. I was acting in Jim's place, a
21 I had full signature authority for Jim Swartzwalder. I had the l
g 22 authority to change his signature, and that is what I did.
j 23 Q. Let me put on the record, I want to show you a copy 6- 24 of the voided TCP.. . .
25 A. Yes, sir.
k 24
.- . _ ~ _ ..-. _ - _. -
i .
- r .
)
1 Q. . . . 18028-C-7-90-1. And I want to ask you a few I
- 2 questions about that.
l 3 A. Yes, sir.
i j 4 Q. Okay. You said that Jim had marked approved . . .
t j 5 A. Yes, sir.
i j 6 Q. . . . and I'm looking here at the . . .
) 7.
A. Right.
i
{ 8 Q. . . . copy of the final approval blocks down here, 9 okay, which was dated . . .
i i 10 A. 5/31.
1 j 11 Q. . . . 5/31/90. Okay, now, let's see, you said that
, 12 the -- this right here is your signature, right here?
i
! 13 A. Yes, sir.
j 14 Q. okay.
15 MR. DOMBY: That's the signature over Jim
} 16 Swartzwalder's signature . . .
i i i
I; 17 A. Correct.
i
!! 18 MR. DOMBY: . . . with 6/12/90 after it? l 1 3 j ,5 19 A. Yes, sir.
1 1
! i 20 Q. The 6/12/90 date that is right here, is that the date ;
i i
{j 21 that you actually signed that, or is . . .
jag 22 A. No, sir. That is the date that I believed at the ff,
'=
23 time that this procedure was removed from the field and the new j 5 24 revision was issued. The actual date that I signed that was 25 6/15. I i
4 25 1
i
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) -
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4 1 Q. 6/15.
~
. 2 MR. ROBINSON: Is there a significance to the 3 fact that that procedure cancellation be dated 6/12 as l
4 opposed as 6/157 l 5 A. Yes, sir.
6 MR. ROBINSON: And what is that significance?
7 A. Well, the significance to me, at the time -- and the 8 only thing that I thought of at the time, was that was the date 9 that I believed that this procedure was voided, and that was j 10 the only . . .
11 MR. ROBINSON: Is there any other significance?
12 A. The other significance is that 6/12 is fourteen days, 13 which is our tech spec, that's in section six of tech specs, 14 for processing TCP's. That's . . .
15 MR. ROBINSON: Did that significance ever enter 16 your mind when you were signing that document?
! 17 A. No, sir. l
! 18 MR. ROBINSON: Okay, excuse me, go ahead.
5 j 19 Q. Were you aware of the fourteen day requirement that l 20 you just mentioned to us?
3 i i 21 A. I was aware of the fourteen day requirement. I am an 1 g 22 SRO, I have been trained on section six. At that time, I
/
3 23 forgot that fourteen days was in section six. I was -- I was 5 24 not aware of it from that standpoint at that time. It's only 25 been since that I've remembered and re-reviewed that section of 26 i
l
j .
- I o
1 tech specs.
Did you have any conversations
~
2 Q. Let me ask you this.
3 regarding the disposition of the TCP prior to your signing 4 these, scratching through Mr. Swartzwalder's signature and 5 signing above that?
6 MR. DOMBY: Conversations with anyone?
7 Q. With anyone regarding the handling of this or . . .
8 MR. DOMBY: Why don't you explain the manner 9 in which your signature came about?
10 A. Okay.
11 MR. DOMBY: That might be the best method.
12 A. When we -- when the PRB met on 6/12 . . .
13 Q. Okay.
14 A. . . . and authorized the procedurer I told -- I 15 believe it was Greg Lee that I told -- that we had authorized 16 18028, and that we needed to go ahead and -- we'd authorize ;
i 17 Rev. -- Revision 8, and that we needed to go ahead and void
- i 18 this TCP on Rev. 7, because the Rev. 8 procedure was to be 5
j 19 issued that day. I was no extremely familiar with the process 20 of voiding a TCP. I did not pursue it after that, I completely l
21 forgot about it until the following Friday, the 15th, when r
g 22 .. .
3 g 23 Q. 15th.
2 i 24 A. . . . 15th, I believe it's the 15th. This was 25 Tuesday . . .
27
l I
1 1 Q. Oh, okay.
2 A. ~ , . . Wednesday, Thursday, Friday, okay -- when Greg 3 brought this procedure to my office and said, "We forgot to 4 sign this when we voided the TCP."
5 Q. Greg?
6 A. Lee.
7 Q. Lee.
8 A. Okay. I signed 6/12 because that was the day I l 9 believed that the TCP was voided and removed from the field, )
10 because I -- as the Revision 8 was issued.
11 Q. How did Greg become aware of this, did it just show 12 up on his desk, or . . .
13 A. I believe that this TCP was returned to him from the 14 PRB secretary, who I believe had physical possession of the 15 original.
16 Q. Okay.
3 17 A. I believe that to be the case.
- So the secretary basically just -- you just think she 18 Q.
19 brought it to him and said he needed to . . .
I 20 A. Taka care of this.
i i 21 Q. Okay.
I g 22 MR. ROBINSON: Did Lee mention anything to you 3
g 23 at that time about the need to have that thing signed 2
5 24 within fourteen days?
25 A. No, he just stated that this is the procedure that we 28 4
,.-- ,-.. . . , --r - m -
1 voided when we issued the AOP on the 12th. And I believe ha 2 mentioned the 12th.
3 Q. Okay. Are you aware of any LER's, deficiency cards, 4 or any other documents which were generated as a result of the 5 processing of the subject TCP?
6 A. Yes. I was -- there were two deficiency cards that 7 were written. And one of them, I believe, was ongoing over 8 fourteen days, and the other was on an incorrect date, I 9 believe is what the deficiency cards were written on.
10 Q. I'd like to show you the two deficiency cards that 11 you mentioned . . .
12 A. Yes, sir.
13 Q. . . . as we continue talking here.
14 A. Okay.
15 Q. The first one is -- number is 1-90-282, basically 16 concerning the fact that an inappropriate date was used on the 17 TCP form, i.e. a 6/12/90 date as opposed to a 6/15/90 date.
l
! 18 Would you hand this to Mr. Cash? And the second, which number 3
l 19 is 1-90-283, which concerned the fourteen day requirement that l 20 had not been met from the tech specs.
I j 21 A. Yes, sir.
! 22 Q. Okay.
2 23 A. Yes, sir. Looking at those DC's, who was the person i 24 who was responsible for investigating or following up the 25 deficiencies themselves?
i 29 j
- c '
1 1 A. The resolution . . . ,
~
2 Q. Yes.
3 A. . . . of the DC's? That was me.
4 Q. That was you?
5 A. Yes, sir.
6 Q. Okay. The date of these DC's, just to get an idea of 7 time frame here, appears to be -- what does that say?
8 A. 22nd.
9 Q. The 22nd, okay.
10 A. Yes, sir.
11 Q. And that was written by . . .
12 A. Caroline Cross Tynan. Caroline Tynan.
l 13 Q. Caroline Tynan. She is the . . .
14 A. Secretary of the PRB. l 15 Q. Okay, teen support. Okay, do you know -- when tech l 16 support basically writes two deficiencies against -- these i
17 responsible people for operations, did they call or talk to ll I 18 anybody, yourself or Mr. Swartzwalder, or anybody before they !
I
?
5 19 wrote tasse DC's?
l 20 A. Yes, they did, they talked to Jim and Jim talked to i; And I had looked at the dates and had prepared a DC for --
21 me.
r g 22 I realized that we had missed the 12th and the procedure had 2
% 23 not been issued until the 13th. And I had the -- I had found 2
5 24 -- Jim had mentioned it to me that day, the 22nd, and I had 25 looked at it, I determined that we had violated the fourteen 30
1 days, had prepared a DC, and was taking it to C&T. And when I 2 got there Mr. Robinson said, "Oh, I've got another one on 3 this," and that's when I found that Caroline had already 4 prepared and issued a DC.
5 Q. Okay, and let me back up so I can get a little better 6 time frame here.
7 A. Okay.
8 Q. I think what you said is that somebody from toch l 9 supporting had talked to Mr. Swartzwalder?
10 A. Yes, sir.
l 11 Q. Who did you say that was?
12 A. I don't know if it was Caroline or if it might have 13 been her boss, I don't know.
14 Q. Okay. What day are we talking about here?
15 A. I don't really remember the exact date. It was -- it 16 might have been Thursday, it might have been Friday. It was --
17 it took me some amount of time to track down everything.
l 18 Q. Okay, so you signed it on the 15th and these DC's 5
,5 19 were written on . ..
l 20 A. The 22nd.
i y 21 Q. . . . the 22nd, so it was sometime . . .
I g 22 A. Right.
2 23 Q. in that time frame?
f; . . .
5 24 A. Yes, sir.
25 Q. Okay. So he basically told you that he had -- Mr. !
l 31
. - - - . -. . . _ . . ..-_ -.-- -_ - _-_ --. - --_=__ ,_-_ -
i V
1 Swartzwalder told you that be had gotten -- had discussions or 2 had a call . . .
3 A. Uh-hum (yes).
4 Q. . . . or whatever from toch support . . .
5 A. Uh-hum (yes).
6 Q. . . . and indicated that . . .
7 A. They had a concern.
8 Q. okay, and that concern was what?
9 A. When Jim -- this is one thing that I didn't 10 understand the problem as quickly as I should have. When I 11 first understood that the concern was the fact that I had lined 12 through, initialed, and dated Jim's signature -- and that the 13 concern was that I did not have signature authority to do that, 14 when, in fact, I did, I was -- I was acting in Jim's place.
15 And my first response was to not worry about it because I did 16 have signature authority. And then when Jim mentioned about i 17 fourteen days, I went and checked the records and found that
! 18 the procedura did not go to the field on the 12th as I thought, 5
j 19 and that it had taken us fifteen days to resolve the issue, and j 20 that's when I prepared the DC. And but I did not -- I did not a
y 21 log that DC because there was one already on the issue.
g 22 MR. DOMBY: So when you took the DC that you 23 prepared to the control room on 6/22 . . .
5 24 A. Right.
25 MR. DOMBY: . . . sometime part . . .
32
1 Q. What was the deficiency that you wrote up? l 2 A. ~ I wrote up that a TCP was not addressed within the 3 fourteen day requirement in the tech specs.
I 4 Q. Okay. And you did not write one up . . .
5 A. No, sir.
6 Q. . . . the second TCP regarding . . .
7 A. No , sir.
8 Q. . . . the inappropriate dates?
9 A. No, sir.
10 MR. ROBINSON: And what did you do with that 1
11 deficiency that you had written?
12 A. Because there was already an existing deficiency upon I 13 that condition, I did not turn the deficiency in, I just threv j 14 it away.
15 MR. ROBINSON: Okay.
16 Q. So I would have to assume that when you finally took i
17 it over to the -- what did you call it, the control room or
? 18 . . .
3
,i 19 A. The clearance and Tagging office.
j 20 Q. I'm sorry.
i
- 21 MR. ROBINSON
- C&T.
I g 22 A. Yeah, C&T.
3 g 23 Q. C&T, okay. That it was at least the 22nd or . . .
I 5 24 A. It was . . .
25 Q. . . . or subsequent?
33
I .
1 A. It was the 22nd, because James Robinson, whose
~
2 signature is here, when I walked in with the DC and handed it 3 to him, he looked at it and he goes, "Well, Caroline just 4 brought ne one on this." So it was shortly after Caroline 5 brought hers down.
G Q. Okay. I believe you said that once you talked to Mr.
7 Swartzwelder and he explained the fourteen days and you went j 8 back and looked and said, "Oh, yeah, I guess we did do that" --
9 I want to look back again at the temporary change procedure 10 . . .
11 A. Okay.
12 Q. . . . form.
13 A. Yes, sir.
14 Q. The date that -- for expiration on these . . .
15 A. Uh-hum (yes).
16 Q. . . . which says here, I believe, 6/12/90, would in 17 fact be the time from -- it got . . .
{a 18 A. Yes, sir.
5 l 19 Q. . . . interim approval to -- would that -- you did i 20 not notice that, or did not -- it did not click in your head at i
j 21 the time when you didn't -- said you didn't think about the g 22 fourteen days or anything of that nature. I guess what I'm 2
23 trying to figure out is that he mentioned the fourteen days to
{
l 24 you and you subsequently discussed with Mr. swartzwalder . . .
25 A. Yes, sir.
34
I
- - I g
1 Q. . . . and you looked at it and said, "Obviously, I J
2 did." You told me you had no prior knowledge of the fourteen 3 days at the time you signed this or . . .
4 A. I wasn't thinking about it, no.
5 Q. Okay, so you didn't -- just didn't -- you didn't see 6 this date for the expiration date as 6/127 7 A. At the tide that I signed this, I was signing the 8 date that I believed that the action took plate -- took place, 9 the action of pulling the TCP from the field actually took 10 place.
11 Q. Let me ask you about that. Is that a common practice 12 that you've used before?
13 A. No. No, it is not, and I've been counseled on it. I 14 don't know why I -- I have no explanation for using that.
15 Typically, I will sign stuff today's date, it was just -- I 16 have no explanation, really.
i 17 MR. DOMBY: Had you ever reviewed TCP's
! 18 before and signed them with Mr. Swartzwalder's signature 5
,i 19 authority?
l 20 A. I've never processed one that had been voided. I had i
i 21 never processed a voided TCP. I have reviewed only approved g 22 TCP's that were being approved. This was the first experience 2
g 23 that I'd had with voiding a TCP and the process that it takes 2
3 24 to do that.
25 Q. You are a licensed operator, correct?
35 l
l
s i 1 A. Yes, sir. ,
2 Q. - And which -- you are used to dealing with official i l
3 records . . .
4 A. Yes, sir.
5 Q. . . . and all this and that sort of thing?
l 6 A. Yes, sir.
7 Q. If you were asked to verify that something had been
- 8 done and it occurred several days before, would you do it in l l
9 the same fashion, indicate that it was done and put the date, i
i 10 or would you do it in some other fashion or way to indicate j
] i 11 that, "I verified this was done previously," and use today's l
12 date, for example?
i i 13 A. Um . . .
i 14 Q. I guess . . . j l
j 15 A. I'm trying to think of a case such as that, and the i
best case I could think of is if I was signing off a 16 1
l l i 3
17 surveillance data sheet . . .
I
! 18 Q. Okay.
{
l l 19 A. Okay? I would sign off a surveillance data sheet as l l 20 being completed at the time that it was completed, because
- s l ! 21 that's the time that we use for our record keeping, as far as
! r j g 22 updating the surveillance log, et cetera. I would sign the i 3 23 " Reviewed by" signature, though, on the date that I actually y
1 e 1
5 g 24 reviewed it.
1 25 Q. Okay, so basically, in that situation, there would be 36 s
. ,.---.v, ,er,- --~%.r----p.,.e -. w.w~.-s -
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3 I 1 a signature and date, the date you signed it, with basically a 2 reference back to . . .
3 A. With the signature and a date for the date the actual 4 actions took place.
5 Q. Was there any reason that you wouldn't have done the 6 same sort of thing on this TCP?
7 A. In hindsight, no, sir. At the time, all I -- you 8 know, I was -- it was brought before me, said, " Hey, we pulled 9 this on the 12th." And I signed it on the 12th because that's 10 the day that it left the field.
11 MR. DOMBY: I noticed that the approval of 12 Mr. Swartzwalder was countermanded . . .
l 13 A. By me also.
14 MR. DOMBY: . . . by you?
15 A. Yes, sir.
16 MR. DOMBY: And what date did that take i 17 place?
18 A. Verbally, on the 12th. But the signature was on the 3
,5 19 15th.
! 20 MR. DOMBY: And then I notice there's i
! 21 another date . . .
I g 22 A. Yes . . .
3 23 MR. DOMBY: . . . that says 6/12?
5 24 A. That's -- for every line through, you initial and 25 date.
37
l c&
- I 1 MR. DOMBY: Okay. So you've entered 6/12 in i 2 three instances?
3 A. Right.
Reflecting the date on which you I 4 MR. DOMBY:
5 countermanded . . . .
! 6 A. Right.
7 MR. DOMBY: . . . Mr. Swartzwalder's l l
8 signature . . . . I
' l 9 A. But not . . . .
I 10 MR. DOMBY: as well as the date upon which 11 you believed that the TCP was approved?
12 A. Disapproved.
13 MR. DOMBY: Disapproved, excuse me.
14 A. Yes, sir.
15 MR. DOMBY: And you believe the date that ,
I 16 you actually executed that was 6/157 1
i: 17 A. 6/15, yes, sir. l
! 18 Q. I have no further questions. l 5
19 l
i 20 EXAMINATION 5
y 21 BY MR. ROBINSON r
g 22 Q. I've just got one. Prior to the time you crossed out 3
l g 23 Swartzwalder's signature, signed and dated it with your own
- 2 l 5 24 . . .
25 A. Yes, sir.
(._
38 l
2 r
1 Q. . . . did Lee or Swartzwalder or Tynan or anyone come 2 to you with that form and say, "You need to void this, and by 3 the way, you've already passed the fourteen day period. You 4 need to write yourself up on it," or something to that effect?
5 A. Mr. Swartzwalder was not in that week either, I was 6 acting for him; he was out for two weeks and I forget exactly 7 why. Greg Lee did not, and the only thing that Ms. Cross said 8 is that -- and I believe it was at the PRB, I don't think I l 9 talked to her after that -- was -- I said, "I discussed voiding 10 it and that I would change Jim's signature." And she told me 11 that I could not do that, that I did not have signature 12 authority for it. And that was the only things that were 13 mentioned to me. There was . . .
14 Q. Nothing about the . . .
15 A. There was nothing about fourteen days.
16 Q. . . . fourteen day period?
17 A. No , sir.
l 18 MR. CARROLL: Ms. Cross, is that . . .
E j 19 A. Tynan, she's recently married. ,
i l 20 MR. CARROLL: Okay.
i
? 21 MR. DOMBY: A year ago or so.
g 22 Q. I have no further questions.
2 23 MR. DOMBY: She has a child that I guess was
{
b 24 born -- so let the record reflect she was not recently 25 married.
39
i a q l 1 Q. Do you have anything after that?
l 2 - MR. CARROLL: No, that's. all I have.
1 3 Q. Do you have any additional comments or clarification i
j 4 that you want to make on this issue, Mr. Cash?
l 5 A. I don't believe so.
l 6 Q. All right. Have you given your testimony freely and j 7 voluntarily here today, Mr. Cash?
2 8 A. Yes, sir.
i
- 9 Q. Have any promises or threats been made to you in
! 1 1 10 exchange for your testimony? j 11 A. No, sir.
12 Q. We thank you for your participation. It's now 12:37 13 and this interview is terminated.
14 (INTERVIEW CONCLUDED) j 15 16 2 17 I 18
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j 19 I 20 i
i 21 r
g 22 l 3
j 23 i
3 24 25 40
- - ~ ~ ,, ,,r -_ . .._..-. .n-, ,
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l
- I 1 CERTIFICATE 2 I hereby certify that the foregoing deposition of 3 JIMMY PAUL CASH, consisting of forty-two (42) pages, is a true 4 and correct transcript of the testimony given by said deponent i 1
5 after being first duly sworn; said deposition was reported by !
1 j 6 the method of Stenomask with backup. l f 7 I hereby certify that I am not kin or counsel to the
! 8 parties in the case, am not in the regular employ of counsel of l
l 9 said parties, nor am I otherwise interested in the result of 10 said case.
11 This the day of May, 1989.
. 12 13 . (/d440 . W
/ ,
i , 14 SHARON G. OWENS, CVR l 15 CERTIFIED COURT REPORTER l 16 NSVRA CERTIFIED i!
i 17
. ! 18 i 3 I 19 j 20 e
i 21 i r r
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g 23
- 2 4
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