ML20096F923
| ML20096F923 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/24/1984 |
| From: | Scalice J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20096F922 | List: |
| References | |
| OL-3, NUDOCS 8409100273 | |
| Download: ML20096F923 (50) | |
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UNITED STATES OF AMERICA
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, b NUCLEAR REGULATORY COMMISSION i .-
us5(c" In the matter of:
l LONG ISLAND LIGHTING COMPANY 84 SEP -7 A11 :21
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- (Shoreham Nuclear Power Station, 7 s-n-u,.i eU- ,h,.A. , Docket No* 5 0 - 32 2-OL- 3
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Unit 1) E+:p;cy O
Deposition of: John A. Scalice
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Location: Hauppauge, New York Pages: 1 - 47 Date: Friday, August 24, 1984 i
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L TAYLOE ASSOCIATES
, Court Reporters 1625 i Strwt N.W. Suite 1004 Washingon. D.C. 20006 B409100273 840906 PDR ADOCK 05000322
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- CORRECTIONS TO DEPOSITION OF JOHN A. SCALICE, AUGUST 24, 1984 f
Page: 10 Line 19 change " fuel rods" to " control rods" Page;29 Line 19 change "and" to "in" PageL32 Line 8 change " system" to " assistant" Pagel34 Line 9 ' change "are" to "we"
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Page'39 Line 8 change "SDA" to~"STA" a
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I UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION WU50 "E"
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BEFORE THE ATOMIC SAFETY AND LICENSIfi3 BdARD7 All :21 4 r . ,.. y 7,
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5 In the Matter of: : i 4U1 6 LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL-3
- (Emergency Planning 7 (Shoreham Nuclear Power Station, : Procedures)
Unit 1) :
8 ----------------------------------X 9 DEPOSITION-OF JOHN A. SCALICF 10 H. Lee Dennison Building
( -#
- Ninth Floor 11 Veterans Memorial Highway Hauppauge, New York 11787
.12 Friday, August 24, 1984 13 14 Deposition of JOHN A. SCALICE, called for 15 examination by counsel for the Intervenor, taken before 16 Myrtle H. Traylor, Court Reporter, beginning at 11:40 a.m.,
17 pursuant to, agreement of counsel.
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I_ APPEARANCES:
(f 2 On Behalf of the Applicant:
3 :
LEE B.--ZEUGIN,. ESQUIRE .
4 ?: 'Hunton &. Williams-3' 707 E.. Main Street Richmond, Virginia.23212
, 5
'On Behalf of the'Intervenor, Suffolk County:
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CHRISTOPHER M. ' McMURRAY, ESQUIRE-
- 7. MICHAEL ~S. MILLER,: ESQUIRE
' Kirkpatrick, Lockhart, Hill, Christopher & Phillips 8 ' 1900 M Street, N. W.
1 Washington, D.~C. 20036
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On Behalf of the Intervenor,. State of-New York:- -
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' RICHARD J.-ZAHNLECTER, ESQUIRE.
, Special1 Counsel to;t.he Governor
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Executive. Chamber
.12 Room 299
. State Capitol. .
13 Albany,'New. York 12224 ,
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4 5 Witness: Examination by: Page:
6 John A. Scalice Mr. Miller 4 7
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v l 1 PROCEEDINGS 2 Whereupon, 3 JOHN A. SCALICE 4 was called as a witness and, having first been duly sworn, 5
was examined and testified as follows:
6 MR. MILLER: Mr. Scalice, my name is Michael 7 Miller. I am with Jir. McMurray from my office', and we 8
represent Suffolk County in the licensing proceedings 9
before.the Atomic and Safety Licensing Board regarding the 10
- Shoreham plant.
/
II
~And we are here pursuant to agreement of 12 counsel to take your deposition for discovery purposes 13 regarding the strike' issues.
14 If you have any questions, or if you want 15 clarification,fr'om me during the course of the deposition, 16 please just ask for it.
II ' WITNESS SCALICE: Fine.
DIRECT EXAMINATION BY MR. MILLER:
. ./
N Q Would you please state'your name and business 21 address for the record?
22 A My name is John A. Scalice. I work at 628 --
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, ; .j Post Office Box 628, Wading River, Shoreham Nuclear Power
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2 Station, New York.
3 Q And you are the Operations Manager at Shoreham?
4 A That's correct.
5 Q Are you the only Operations Manager?
6 A Correct.
7 0 Who do you report to?
8 A Plant Manager.
9 Q Who is?
10 A William Stieger.
Q And what was your position prior to April 15, 11 12 1984 when you became Operations Manager?
13 A I was officially a Reactor Engineer.
14 Q Mr. Scalice, when did you first become aware 15 of tIhe Board's' July 24th Order regarding the strike issues?
16 sA I. don't know exactly, maybe the 25th, 24th.
17 Q Very soon after~the Order was issued?
18 A' 1(The witness nodded in the affirmative.)
19 Q And who showed it to you or told you about it?
20 A I had a request to attend a meeting with Lee 21 and Mr. Stergakos of the Company for a meeting that they j 22 had on it.
6
, 1 Q Was this the meeting on July 25th?
2 A I don't know the date.
3 Q Shortly after the Order was issued?
4 A (The witness nodded in the affirmative.)
5 Q A meeting with lawyers for LILCO?
6 A Correct.
7 Q Was Mr. Irwin at that meeting?
8 A. Yes.
9 Q Who attended the meeting? Tell me, if you 10 can, who the attendees were at this meeting?
fI 11 A Mr. Irwin, Mr. Zeugin, Mr.-Stergakos, Mr. Rigert,
.12 and there were some other people that I can't recall at 13 this time.
14 .Q , Was Dr. Cordaro,at the meeting?
15 A No.
'Did you learn at this meeting that you would
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16 Q 17 be testifying on behalf of LILCO at the trial?
18 MR. ZEUGIN: I will object to that on the 19 grounds of attorney-client privilege. I don't see the
) 20 relevance of that, to what we are talking about.
21 BY MR. MILLER: (Continuing)
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,) 22 Q Let me just ask you, Mr. Scalice, when did you
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- 1 first learn.that you would be testifying on LILCO's behalf 2 at the trial?
3 A About a week later, in that area.
4 O The beginning of August, end of July?
5 A I would say that's about accurate.
6 0 How did you learn you were going to be testifying 7 on LILCO's behalf? Who told you that?
8 A Mr. Irwin and Mr. Zeugin.
9 Q Mr. Scalice, your affidavit regarding the strike to issues, did you begin preparation of that affidavit shortly 11 after the meeting, around July.25th?
12 A That's correct.
13 .Q. Did you work with anyone in preparing this 14 affidavit?
15 ,A No.
16 Q And what did.you do to prepare the affidavit?
-17 A Basic knowledge of what I know about the plant 18 and reference to -- specific reference to our procedures.
19 Q You looked at some documents, and those would
() M be the Shoreham procedures?
21 A Yes.
s j 22 Q Are those the documents attached to your
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. j. : affidavit?
~2 A SPecificallythosedocuments,has.
3 Q Anyth'ing other than the documentsfattached to
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4- your affidavit?
~5 A Not that I recall..
6- Q So, for --
4 7= A But I have familiarity with several.other e ' procedures. .
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9- Q'- -For example,_did.you look at'the-FSAR for
.: n.. 10 Shoreham?-
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11 ' A' Yes. I think -- I believe -- yes,.I did.look-- .
p .12 at the FSAR and" technical specifications.
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14 . r. : A ;- - Itowa's,.either Mr.,Irwin'or Mr. Zeugin.. I 1
', ' ..] ll 15 don't recall which.# ' 'l o ._
16- * -Q,, ' Dotyouiknow,jMr.TScalice', why you were asked-
-17L .to prepare the affidavit rather than some-other LILCO 18 - employee?
~19 A. . Well-,-I'm Operations Manager so I'm familiar h , - 20 with operating the plant. I would suspect that's-the j 21 - reason '.
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./ ;Now,[sinceithe preparation of your affidavit,_
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4- ..what,Lif.anything, have you done to prepare for the: hearing i , t. ' mj i _ "* -
5 ~ which begins next week?
6 A' I answered some questions that you entlemen 7 had,regarding'some' additional details.
8 Q That,was in reponse to a discovery request-by-9 'New York State and-the County?
~1 10 A* Yes.
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- 11 Q- So,.you'were provided questions and you. pre-
.12 pared answers.to.those~ questions?
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c.' 13 Anything else?
14 ' .A- 'Could you be. specific? In my normal work-15 : -function?-
_16 ~Q- Anything in preparation for the hearings which 17 -' begin'next week?
18 ' A' .I reread my affidavit.
e 19 Okay.~ Have you performed any calculations?
Q km,f 20 - A No.-
21- .O Have you had discussions or meetings with
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,A. Excuse me. -About performing calculations --
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2 you asked Mr."SYergako's"and'I~ overheard it, so I just
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3_ did;my own quicks calculati'on._
4 . ., 0. ., < 4 What calculation did you-just perform?
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- 5 A You seemed to be interested in the calculation.
for shutting down-the reactor, so I just wanted to'be 6
y_ specific to you if you asked that question later.
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O Let me ask that now, then, since we are there.
9 In your affidavit, you-state that -- I_will paraphrase 10 , this, is that the time needed to go through the seq 6ence p
' 11 of steps in your-affidavit to arrive at cold shutdown is 12 approximately 12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, correct?
13 A That's correct.
, 14 ' O Now, what is the basis for that figure in your 15 affidavit?
16 - -A The basis for'that is my knowledge of how to 17 shut-the plant down, practice at simulators, witnessing
.18 -- at other facilities that are operating. And knowing no. mal 19 . times.it takes to insert the fuel rods and my experience
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(,). lW as Reactor Engineer and as a Licensed Operator.
21 Q Is there a degree of judgment involved in that 22 Lestimation, then?
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, 1 i Only conservatively. It would probably take
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3 Q Could it take~ longer than 12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />?
4 A I see no way.
5 Q And the next paragraph of your affidavit talks 6 about if you manually scrammed the reactor, you could 7 arrive at cold shutdown in approximately eight hours?
8 A That's correct.
9 O Now, what's the basis for that?
10 A Well, I don't have to insert the rods manual.
11 It only takes -- as I indicated in there, and that's 12 conservative again, five seconds for the rods to be 13 inserted when the manual scram is placed into the reactor.
14 Actually, it's usually -- it's in the area of around three 15 but five seconds is --
16 O Mr. Scalice, there is a statement of material 17 facts which was submitted by LILCO to the Licensing Board 18 in which it was stated that -- I will paraphrase again, 19 you can generally arrive at cold shutdown in less than 24 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.
21 Do you recall that statement?
22 A That I made?
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N.. >g .a This ;was iri alstatement of material . facts- that
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was: submitted.a mr ' Have (you'; seen that statement of material 2:
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, 4 Let me show'it to'you. It has got some markings 5' 'of mine. .
6 (Mr. Miller hands the witness a paper. writing.')
'. 7 A What specific page are you referring to? _
3- O Paragraph 5 says that the Shoreham plant staff 9 can.take=the Shoreham plant from full power operation to
. 10 cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following normal procedures.
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11- A .That's correct.
12 0 That: figure is somewhat above your 12 to 16 13 hour estimate, and I'm wondering why the'24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time
.14 ~ period was used, or if you'think there'is no: possibility.
15 that it could take more than.12 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />?
16 A I think the rest of the sentence says: And in t~
i 17 a.much shorter time if necessary.
18 Q . Do you agree i['could take up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
19 A No. Twelve to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> is all I would need.
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20 ~ I stand by my. calculation.
~ 21 Q Do you know why the figure of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was y
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_D ~1- A-a- I assume it was'because of.the notice that we x) - , . g3 .,
2 were; generally .'giiren' pribr ,to~!a strike ,or. we have experienc-3 J " i' 4i "n?~> 1--
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4 Q Now, other than your calculations. performed here 5' a few minutes ago regarding-the time necessary to get the 6' plant to cold shutdown,'have you performed any other 7 . calculation's of any kind regarding the.' strike issues?
8- A. Could you be a little bit more specific?. I
.9 don't understand what you mean,,regarding the strike-g 10 . issues.
' !,"J 11 ' :Q Do you understand =the. issues that are going to-
.12 be heard before the Licensing Board next' week?
13 A To my understanding, how long it would.take'.me
, 1 14 to shut'the plant, put the plant to a cold shutdown.- If
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15 - you are talking about_Mr. Stergakos' area, I did not 16 perform any calculations.
II I'm just talking'about'any ca]culations of any Q'
18 kind.
I' A I have not performed any additional calculations.
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L]/ - N' Q And other than your affidavit, have you-pre-
- 21 pared anything in writing since you learned about the
- Q V- 22 ~ strike issues?
14 1 A No.
2 MR. ZEUGIN: I want to make sure the record is 3 clear on this., Were you including in that, Mike, for 4 Mr. Scalice's clarification, in the discovery document 5 also he said he provided an answer to?
6 MR. MILLER: I was asking for anything in 7 writing. Let's back up and.make sure it's clear.
8 BY MR. MILLER: (Continuing) 9 Q I guess we have, Mr. Scalice, the affidavit 10 you prepared and we have the response, any response, you 11 prepared to a discovery request that has been provided to 12 the County.
13 A That's the sum total of what I prepared.
14 Q Are you in the process of preparing anything 15 at the present time?
16 A No.
17 Q Do you know if you will be preparing anything 18 in writing to submit to the Board next week?
19 A No, I do not.
j 20 Q Have you had any conversations with the NRC 21 Staff, Mr. Scalice, with respect to the strike issues?
) 22 A The staff, no.
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15 i Q The NRC Staff?
v 2 A I've had conversations with the NRC Resident 3 Inspector at our facility.
4 Q Regarding the strike issues?
5 A Yes.
6 Q And what are the substance of the c'onversations y you have had?
8 A Well, I had daily conversations with him --
9 not daily, but conversations during our existing strike, 10 it's casual.
I'" 11 I knew that he was' Resident Inspector at the
.12 Salem Plant at the time of a work stoppage that they had 13 there.
14 Q Who is the Resident Inspector?
15 A Chuck Petrone.
16 Q And there was a work stoppage at Salem and 17 you talked to him about that?
18 A Yes, sir.
19 Q What happened at Salem when they had a work 20 stoppage?
21 A They operated throughout the work stoppage at
(_) 22 a hundred percent power, I believe, or some high power
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2 -Q -The. work stoppage at Salem involved how many 3 employees of the utility that operates that plant?
4 A I don't have the slightest idea. I believe 5 it's a twin unit so there are a certain amount of 6 employees, but I don't know the number.
7 Q Other than-Mr. Petrone, have you had discussions 8 with anyone else from the NRC regarding the strike issues?
9 A No, sir.
10 Q And did your conversations with Mr. Petrone i 1 11 involve the issues raised by the Licensing Board that are
.12 going to be litigated next week?
13 A I don't believe I understand that question.
14 Q Mr. Scalice, let me ask you about this statement 15 of material facts. There are a couple of things in here 16 I was curious about.
17 A Okay.
18 Q It says that approximately two-thirds of 19 LILCO employees in LERO belong to one or another of two
' 20 unions.
21 Is that correct, to your knowledge?
1/ 22 A Could you repeat that again?
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) 1 Q Approximatelytwo-thirds of the LILCO employees 2 in LERO belong to one'or.other of two unions.
3 A I never did the calculation. We have two 4 unions that work at Long Island Lighting Company.
5 Q Do you know how many workers approximately 6 there are in LERO?
7 A I don't have the exact number, no.
8 Q Are there only two unions represented for
.9 workers that. belong to -- let me start again.
10 Are there only two unions to which workers
.a 11 belong in LERO?
. 12 A I suspect so. We only have two there in 13 -Long Island Lighting Company.
14 Q Now, do.you have union employees represented by 15 those two unions that are part of the operating staff at 16 Shoreham?
17 A We have people that are in the emergency
}, 18 response organization. If you consider that to be a 19 wide umbrella, including LERO, then I guess the answer j 20 would be yes.
21 MR. ZEUGIN: Let me clarify the intent of your 22 question, Mike. Are you looking for members of the normal
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- i plant staff and their normal operations as members of a
2 Pl ant staff? Was your question whether those people are 3 union members, or did it relate to emergency planning?
4 MR. MILLER: I was going to the issue of 5 P l ant staff, my last question.
6 WITNESS SCALICE: Not to my knowledge.
7 (The witness, Mr. Scalice, and Mr. Zeugin 8 confer.)
9 WITNESS SCALICE: Are you asking me if part 10 of the plant staff is union, yes.
11 BY MR. MILLER: (Continuing)
.12 Q Okay. Let's try to back up a bit. What is 13 nho total operating staff,.the numbers, of Shoreham?
14 A Well, the numbers change but presently there 15 , 'Are about 320 people on the plant staff with an authoriza-16 tion to go up higher than that.
17 Q Now, do you know how many of the 320 plant 18 staff personnel are unionized?
19 A 173.
20 Q Are the remainder, then, all management 21 personnel?
) h A Classified supervisory management personnel, yes.
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y Q- How many shifts do you run at this plant?
2 A '- Six Operating shifts.
3- Q Is it three shifts a day, six. total shifts?
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4 'A We have six shift rotation; yes, there are 5 three shifts a day.
6 0- Is it fair to say, then,-that the average 7 shift size is,approximately sixty workers?
8 A No.
9 0 -What is the. average size'of.a~ shift?
'101 A The.' average size of a shift i depends'on what.
A/ i t' area you are talking about. The operating complenent is'-
.12 'different'from the'-- what-I mean by.the operating:
13 complement, people that operate 1the equipment in my 14 divisioncis different,.for instance,'than the maintenance
-15 or clerical ~or. support organization.- Therefore, a-
-.16 considerable number of those people work on days and 17, they are not carried over to the shift..
18 - Q Can you tell me, what is the size of'the 19 - operating staff that would be on hand during a normal'
".p-20 . shift?
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I 21 A. Yes. There'is a watch engineer.. I assume O you-mean an off-shift where normal management people are V 22 -
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- 2. ' Q- ' I'm talking about.the normal-shift during'a
, , 3 normal day,-the operating staff that would be available?
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A The normal day? Okay.
5 Q I realize there are days.where-a number of
!6- . People come.out to the plant that are not specifically 7 assigned to the plant.
-8 MR. ZEUGIN: Maybe I can help clarify a little 9' bit of the Mr. Scalice's question.
10' I'think Mr. Scalice is thinking about, there i, .
N .are some management personnel who he would include'in
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.12 what he would.say would be a day operation shift..who 13 wouldn't be.there at night. I think:he.would include 14;: himself probably.
15 ' ' WITNESS SCALICE: -I don't know which of the 16 two you want me to tell you.-
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17 BY MR. MILLER: (Continuing)
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2 18 Q Let's do it for both. Let's do it for the day 19 and then for the evening. LBut, you can give me the' size i)s 7_ 20 - of the operating staff that would normally be on-hand at 21 the Shoreham plant durin~g a normal shift during the day.
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() A It would be the numbers I just wrote down except
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- 2. .other shifts. So that, for instance, they are working
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I think it's easier ---
4 0 The size is what I'm looking for. If you 5 could give me the size.
6-A Okay. . That's not so easy to do. I would have 7' to take a little time to figure it out.
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8 MR. ZEUGIN: Would you like'a piece of paper 9 so you can write it.down?
4 '10 WITNESS SCALICE: Sure.
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-t V )-. n (The witness is doing some figuring on 12 Paper.)
13 -
I can'round it off to say that approximately 14 a third would not be there, less than a' third'would not.
15 be.there. Out of.this total complement, it's. considerably' 16 less. It would take me a.'long time'~to figure that exact 17 ~ calculation out.
18, BY MR. MILLER: (Continuing) 19- Q I'm confused, Mr. Scalice. During the day now,.
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- - 20L -are you saying.that approximately 200 workers would be --
- 21 A In excess of 200 people, yes.
i 22 Q Per, shift?
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2 0 okay. 8 to 4?
3 A Or later than that, because we never seem to 4 work 8 to 4.
5 Let me see if I can be a little more explicit 6 for you. I understand your confusion.
7 In the plant staff,.320 people. There exists 8 clerical help, managerial help, shift operators, maintenance 9' people, radiochemistry people, health physics people,
- 10 et cetera.
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(~# 11 During the day, the clerical people are there.
12 We do work some people on the 4 to 12 but it's not a 13 significant number. So, out of that portion of that 173, 14 the majority of the clerical functions are not there.
15 The majority of the operations group would not be there 16 except for those that were either covering the operating 17 shift or in training.
18 The maintenance people would be on a normal day 19 ' shift but only would work on evenings to do'special repair.
) 20 The health physics people are onishift in accordance with 21- the technical specifications and will be on shift in
(,) 22 'accordr. ace.with the technical specifications, at least
23 j one HP technician, radiochemistry technician, and then 2 we have normal fire brigade requirements.
3 S , it's not an easy thing. It would take me 4 a little while to put it together to give you the exact 5 number. But the majority of the people are on the days, 6 and under certain circumstances the minimum number of y shift complement plus security people and some extra jobs 8 that are going on are on the night shifts.
9 Q Let's try it a little different way. Could to you tell me what would be approximately the smallest 11 number of persons that could be on duty at Shoreham at 12 any time during the day?
13 A Okay. In accordance with -- there would be 14 the minimum number which would be in accordance with 15 the technical specifications. It would be one watch 16 engineer. I will write that down.
17 (The witness is writing on paper.)
18 I will show you in the tech specs and see if 19 this is the same. A minimum of eleven people not counting 20 security. And that number will go up.
21 Q Okay. So the minimum number would be eleven j 22 persons withe t counting security at any time during the
24 1 d ay . --
2 A And not counting a rad waste operator that we 3 will be hiring in the next couple of weeks.
4 O Now, those eleven persons -- and let's exclude 5 security for now. Of those eleven persons, how many of 6 those would be unionized?
7 A Eight.
8 Q Now, which of these eleven are not mem'bers of 9 some union? If you can give me the job category.
10 A The watch engineer, the watch supervisor, and 11 the shift technical advisor.
12 0 Can you give me the job categories of the 13 eight who are members of the union?
14 A Sure. Two reactor operators and three equip-15 ment operators. I'm sorry, four equipment operators.
16 An IIP tech and a rad chem tech.
17 Q I missed the last two. I'm sorry.
18 A An llP tech, health physics technician; and a 19 rad chem technician.
20 Could I refer to the technical specifications?
21 Q Sure.
_, 22 (Mr. Zeugin ~ provides the witnese with a paper writing.)
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j t O- (Continuing). Let me make sure I --- ,
1 2 MR. ZEUGIN: , Let him check that. -
3 V "%
WITNi:SS.SCALICE: .
The rad chem tech,would not s
4 lb'* o' required. s .
5 .BY MR. MILLER: n (Co'tinuing) 6 'O So, ar6 you saying now the minimum size.would 7 lie t'en?
8 A Uh-huh. Even though we plan to put them on 9 Dshift, it's not. required by technical specifications.
10 0 Okay. ' So , the minimum size of any shift,
)
11 excluding security, would be ten-persons, seven of which 12 would be members of the unionL -
13 A Yes. .
14 Q Now, 'let me make sure we are understanding 15 one another,'Mr. Scalice. My question' assumes that the 16 plant is in operatio .
17 A .I'm not counting security. And there' are 18 supervisors in security.that are LILCO personnel.
< 19 Q- Right. I'm excluding security for'r'ight now.
20 So,,.I'm assuming the plant is operating and you have made 21 that assumption, correct?
x_ > 22 A That's corf,ect. The minimum possible that would k
l ~
26 N f-() 1- be on shift.
2 Q That's night or day?
3 A That's highly unlikely, though.
4 Q Night or day, twenty-four hours a. day, any 5 time?
6 -A No. It's on the 12 to 8 shift would be the 7 minimum time, the way I look at it.
8 Q So, you.have given me, though, the minimum 9 number of persons that could be on site at any time, p
10 night or day?
t 11 Is that correct?
12 A - That's correct.
13 Q And you were talking about the midnight to 14 8 a.m. shift?
15 A That's correct.
16 Q You keep mentioning security. Is the security 17 force unionized?
18 A Not the same union. They are unionized.
19 Mr. Scalice, would you look at a copy, if you Q
) 20 have it, of the'information you provided to New York 21 State and the County in discovery?
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22 At the top of the page it says, "Non-Union c .-
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el 1 Manpower-Available-to Bring Plant.to Cold Shutdown and 2-Maintain It In That' Condition."
'3'
.Do'you see-on the'first page,~~Mr. Scalice,
. 4 -
there'is a-listing at the~ bottom of'various job categories -
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=and the numbers?
'4 A' Ye's . That's correct.
7 Q' You say there are presently twenty non-union-8
^
.LILCO employees who are licensed senior reactor operators,
[~ and you give'th'e job titles?'
10 A Yes.
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.Q. -Did you prepare this'. list?-
, 12l IAI Yes.
13 .g - Now, you gave me a' category for your minimum I4 shift. .You saidithere would be a shift technical-advisor.' .
151 'g..
,That'.s right.
16 Q: Which. category does :that! correspon'd . to : in)
I7
- your' discovery list?
[
-A .He is presently not a licensed individual.
'O' Q- ..And'the reactor operators,..did they appear
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'O- 1 on-this' list?
'21-A1 The' reactor operators I was talking about are A,
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ithe nuclear system station operator and nuclear station-4 A. -t, .L g.
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'2 .Q -Okay. -So,'looking-at the listLof"non-union
- :x 3: employees,.Mr. Scalice, you provided in discovery, the
i-
.4 : only ones thatfwould be on-site during this minimum 5- shift,'.12,to18 a.m.:shi'ft, would be one watch engineer, 6 and one watch supervisor; is that correct?-
. ; 7.: A -On:the~ absolute minimum occasion, yes.
8 Just-for clarification, at the present time.
- 9- .Q Which.are you' referring to now?
~
10 A At the present' time.
11' .O -Are you1 referring to-yourg list --
s12 A- Yes. ,
13 -Q~ -- that was_provided during discovery?
14 A- There are additional people that are going'--
15 - in management that are going for licenses =right now.
.. s 116- Q ;But as of now,.this is the list?
.17 A Rig'ht. But they will be' finished at around
-- 18 '
. February..
4 il9 t..
0 Would you look.at your affidavit, Mr. Scalice,
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. that you prepared?
-21 -A (The witness is complying'.)
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M 22 ' Q Looking at the second page of your affidavit,
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i you._have'a' listing;of the operational conditions. There Jf~M) w 2 --are.four different' conditions there, correct?
3 ;A. Yes, four.
4 . Q' lAnd do-you have a' copy of-the tech spec we 5 have' been referring tio?
6 A= Hold on a second.so-I can find it.
7? Q- .ThereJis a.Tdble 6.2.2-1.
28 A- That's correct.
, 1 9 ;O Could'you tell me how:.the.four operational 10 -conditions in your affidavit correspond to the five,~-it q_w
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, fil- would' appear to be, operationaliconditions of_the:. tentacle.
12 ' specifications'inithis table?'
13 A'- _ Condition 'l 'is, power 'op,eration.- . Condition'2i 14 Lis start-up, .which was .not discussed. Condition 3 is Thot shutdown.- Condition 4 is. cold shutdown. ~ Condition 5-
~
~15
' 16 - is refueling.
'" 17 .
Q' .Why' is start-up. not in your af fida'vit?
It 'wasn' t pertinent to trie ' affidavit.
1 18 s A 19 LI-coul'd have,' defined-it, defined it as the mode switch and
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.i start-up.
. 1 21- Q Okay. Now, I want.to ask about the mode switch.
f) Could you'tell:me alllthe' various positions of the mode
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2: .A~ Those are -- they are. shutdown, refuel, start-up,
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. ;4 thing. And'run.
5 0 . So , four different positions?
6 A 'That's correct.
7 'O Shutdown, refueling,. start-up, hot shutdown --
8 A Hot standby.
- 9. O Hot' standby and run?
10 A. That's correct.
.- en
- ( ) .
11 Q The -- excuse'me.
12 A The difference between hot and cold shutdown or-13 . shutdown,.it's still shutdown.
14 0 .Now,'for each-of the.five conditions listed in 15 ; the. tech specs, could you tell me what position the mode' 16 switch would be~in?.
17 A Yes.' Condition 5 would be refuel. Condition 4 18 - would be shutdown. Condition 3 would be shutdown.
19 Condition-2 would be start-up. Condition 1 would be'run.
20 -Q~ And right after, in your affidavit, Mr. Scalice, 21 'where you have listed these operational conditions you have
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( ,/ 22 a listing of the steps involved in this sequence of --
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3'- ' '"' MA ' ' It 's - a summary!, y~e s .
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?4- ll ' .Q , iAndjyou-prepared this: listing? '
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5' A That's correct.
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6 0- Could you tell me who performs each step in l7 cthis sequence? I'm looking for the operator involved
, s 8
and any operators that would'be - .well, I'm looking for 91 the people that would be involved 'in this step.
10' A Under what-scenario?
Q].
@wr . jj -Q :Under the scenario of bringing the, plant to'
- 12 - cole shutdown.
.13 ' A With eleven people or~ ten-people?'-
' 14 : Q! Yes. Let's go with the small shift,'as of now, L15 ten people.-
16 - A Sure. . Reactor. power is reduced by-lowering 17 ;the recirc. flow.- That would be the NSO, which would be *
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18 one of the reactor operators. Main steam is the line.
19' with the rad waste steam generator. That would be the NSO,
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r dps>yi- 20 Nuclear Station Operator, which is one of the reactor operato rs,
. 21 as indicated.
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~( x): 22 Just for clarification, these are technical
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' specific lto lour cplant. but .they."are- .'not' unlike 'other plants. .
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d$.ffeienttermsorithe.dp5cific. titles'that-eachutility
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5 may[ cal'1"a' reactor operator.- He'may be' called-a controli r
-Operator.- He may be: called,.a control' board operator.
~
6-In our- case, he -is._ a nuclear _ station operator 7l g .~o r'a nuclear system station operator. It's.a. man that 91 has:a license'to manipulate the' control.
. .' 10 'Q.
. .Okay. Let me gotback for a second. In the U(]- .
11 ' first' step in yotir affidavit, : you say . the' NSO ' would .
12 Perform.that; and that means what? - '
13 A A reactor operator..
Y And the:second: step?
.y Q
~15 A Reactor operator.
.g Q Okay. Go ahead, plea ~se.
17 A Reactor operator.
~ 18 Q 'Could'you match the --
~ 19 ; ,
A C.
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- j - - 20 0' -- steps.~
21, A A reactor. operator for D. Reactor operator Combination of a reactor operator and equipment
'22 ; for E.
a t.
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_EE________i___..___.
t 33 1 operator for F. Reactor operator for G. Reactor operator 2 for1H Reactor operat r forLI. Reactor operator for J.
3 Reac' tor operator for K. Reactor operator for L. Reactor 4 operator for M. Reactor operator for N. And O is not a 5 step; it's continuing', the's'ame.
6 Q And when you are telling me, Mc. Scalice, that 7 a reactor operator, you are saying one person would perform 8 this step?
9 A One or two.
- 10 Q If it was two,.would it be two reactor operators?
11 A That's true. Manipulations of controls is 12 done only by licensed reactor operators.-
13 Q Does any step listed in your affidavit require 14 more than two persons to perform the step?
15 A These steps could be performed by one or two 16 individuals. Some of the auxiliaries may be aligned in 17 the field but they can be done by the control room basically.
18 Q I gather, Mr. Scalice, that -- well, the 19 individuals you have mentioned, these reactor operators, 20 in one case, the equipment operator, they are union' people, 21 correct?
) 22 A That's correct.
l-34
') 1 Q And your affidavit states you believe these 2- steps could be. performed by non-union management level 3 PeoP l e in the absence of the union people?
4 'A*
'That's correct.- I can perform those steps.
5 O Looking again at your discovery list, can you 6 tell.me, Mr. Scalice, what does the compliance engineer 7 do? What is his job task?
8 A The compliance engineer maintains the records 9 of technical specifications to ensure that they are 10 complying with them.
11 O Would that person be involved in the steps 12 needed to bring the plant to cold shutdown?
13 A Would he need to be? No.
14 Q Would he be able to?
15 A Yes. All of these people are senior reactor 16 operators. Anyone of those senior reactor operators 17 has the ability to manipulate the controls. They are 18 licensed, and as a matter of fact they are senior ~ licensed 19 above the reactor operator category.
20 Q Could you tell me, Mr. Scalice, what the duties 21 of the rad chem tech person is? What those duties would 22 be?
35
~
1 A As Ilsaid, the rad chem tech is not required v
2 as of yet by tec6nical specification but his duties might 3 be to perform water chemistry.
4 .Q What about the health physics tech? What are 5 his job duties?
6 A Health physics, radiation protection activities.
7 Q During the transition to cold shutdown, Mr.
8 Scalice, what would his duties be?
9 A The health physics technician?
10 Q Yes.
s 11 A Wouldn't be necessary.
12 Q And going back to the rac. chem tech, if you 13 had one on board at Shoreham during the transition to 14 cold shutdown, what would the duties of a rad chem tech 15 be?
16 A Under normal conditions, whatever he was 17 assigned by his manager on the day shift.
18 Q He wouldn't be necessary to bring the plant 19 to cold shutdown?
20 A No. The reason these people are there is for 21 other evolutionsi 22 Q I'm sorry.
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-What does that mean?
-- 3 _.A Is,when you are. operating the plant and you 4- .: wanted to take a water chemistry check, you would have
~
f5: them doing water ~ chemistry. checks. If you were going to 6- .process a system,1 rad-waste systems, you may take some 7 chemical analysis.
1B- And you certainly don't have to do'that during, 9 you know, the process of.taking it down to cold shutdown'.
10 f -Q The eleventh paragraph of your affidavit, Mr . :
L("
.' 11 .Scalice, says: Once the reactor comes off the cold shut-
.12 down'it can be maintained in that condition indefinitely 13 Eby management level plant' staff employees alone if'
- 14 necessary..
.15 Could'you tell me, or describe to me, what is IdL necessary'to maintain-the reactor in cold shutdown?
17 A- Sure. I will place the' residual heat removal 18 system'in service ~in the shutdown cooling mode of operation.
l : 19. Q Is that it?
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.20 - A Well, that's the1 main thrust of maintaining 21- the plant.in col'd-shutdown condition. Other controls f%
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maintaining = reactor. water ledel;is of little significance,-
2;
~3 Las thereushould be no variable.-
4 0 And what personnel would be required to maintain 5 ~the' react'or in cold shutdown for an indefinite period?
6 A We have the. ability to bring additional people 7 on within this category, so it's still the licensed 8 people. If you are running controls associated with the' 9 reactor, then you need licensed people in the control 10 room that manipulate those controls.
' C\./
s 11 Q So, you'are saying that some of the twenty
- 12. persons listed in'the discovery document you provided --
13 A 'Will be in the control. room.
14 0 -- and would be'able to maintain.the reactor 151 in. cold shutdown indefinitely?
'14 A All of those persons could do that function. ,
-17 By the way, let~me add something for clarification.
4 Tho' RIIR system is not the only system operating.
~19 If you want me to go through all the systems operating, W
[ (,) 20 ~ I will. To have the RIIR system operating, you need the
, a.- , 21 service water system and other auxiliaries in the plant
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T Q Mr. Scalice, let me ask a. question'and'see if
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- I'm looking now at this Table-l3 ; ;6.2.2-1 of the tech specs. Conditions l4 and S are cold 4( shutdown; is that correct?-
5 A. And_ refueling. Condition 4 is cold' shutdown.
6 Condition'S is refueling.
Q And according to the tech spec you.would need 3 a minimum of.three persons.for'those. stages, correct?
9 A~ .That's correc6.
10 0 Under those operational conditions. Now, are
. A) '
i 11 you saying that LILCO could have a minimum of three people
.12 on duty at all times indefinitely in the event of a 13 strike?
M .A Absolutely.
15 0 And those three persons would come from the 14 list of 20 persons that are listed in this document ,
- 17 entitled "Non-Union Manpower Available to Bring Plant to Cold Shutdown?"
M 19 A That, and other additional people if necessary.
lh 20) Only two of those are licensed people out of that three.
21 Q What other additional people were you referring 1
n l . \,) 22 to?
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2 available. Only,two' licenses are required during
, -3 Condition 4 and 5; the' watch engineer is a license category and
~
, 4 the reactor operator. :We,would perhaps put a watch
=5 . supervisor in that position.
4 The other job is not 'in a licensed ' category.
y' So, if we took anyone of'these we-could put them in that' 3- position also in the field if necessary, or.SDA or 9 = management.
10 Q Itow many personnel would be necessary t'o do '
D' n a refueling. operation?
.12 A I would need another -- I would have to refer 4< , : 13 exactly to the' specific ----depending on what the extent
'u of the refueling operation,would be. If'you are just 15 saying moving fuel, I-would-need a man in the' control room,
- g- I need somebody on the refueling deck who is an SRO and 17 - Probably people doing mechanical functions which can still
' Is come out of the management ranks.
. 19 0 !!ow many people would you -need to do the 20 mechanical functions you refer to?
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, 21 A .It would depend on the extent of what the
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- 22 functions Wore. Just to change fuel around, it would take
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) .I a' man up onithe deck which-is the SRO controlling any of 2 the activities,' the person. operating the refueling bridge, 3 another person verifying the refuel moves, communication 4 with.the control room which then takes into the fact 5 that there will be somebody at the control panel monitor-6 ing the activity moves.
7 Any time you move fuel it's core alteration and a in accordance with the tech specs requires somebody to 9 be monitoring both at the refueling bridge which is on p_
10 our elevation 175 feet and the control room, verifying
'/
11 that the moves have all been correctly categorized on 12 refueling tagboards.
13 0 When you just said, Mr. Scalice, that you 14 would need another person in the control room, you are 15 talking about a person in addition to the two persons 16 required by the tech spec to be in the control room; is 17 that correct?
la A No. I mean another person up on the refueling 19 bridge is an SRO, to stand in the control room could be
! 20 that man. The tech spec stated that.
21 "All core alterations shall be observed and n
, 22 directly supervised by either a licensed senior reactor
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c 2 !to fuel, handling no other concurrent responsibilities 3 .during this operation."
4 .Q Let's try it again, Mr. Scalice. During cold-
.5- shutdown - <let's.go back to refueling.. The tech specs-6- .says you are going.to have a minimum of three. people --
7 A 'Two of which are licensed.'
s 0 -- two of~which are licensed, and you say you.
9 will add a' reactor operator on the refueling bridge?
. 10 A Ye s'. -
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12 A As in accordance with. technical specifications.
. '33 O Now, did you also say you would have to add a
. y' person to the' control room --
15 A No . .
g Q -- or is that control room function, it could 17 be' ultimately performed by one of the people listed in
- is Jthe tech specs?
19 A Yes. .!!e can be assisted by any of those
,. 16 -
20 other personnel if necessary.
i v
21 .O The other personnel is the personnel from h, 22 the list you provided to the County during discovery?
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Mr. Scalice, let me ask you, during the' recentic O.
a e 3 1 strike did theTsecurity force:go on strike?f A
g; < :4: A. No,:they.did not.
~ 15 O L Was - that considered by the security ~ force?.!
3_ .
-3 6 -
.A 'No, fit was not..
7 'Q. It was not?.
8- ' A; f(The' witness nodded in the. negative'.). '
1 O
7 LQ -There'is a: statement in the' statement.of.
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material facts which says that'-- it-talks"about the n'- - it ' .recently expired contracts with LILCO's unions and;how 12 : they. contained no strike clauses.- :
s
,' 13
?. Do you know; do the new contracts with the .
'" ' 14 ' unions contain no' strike clauses?
o
.15 A: -I'm' told -- I'm not s'r'e.- u .I-haven't seen.them. >'
t 16 Q;, You are told they do?
17 A . Ye s .- ,
18
-Q Are.those. clauses -- do.you'have any knowledge s
Y whether those clauses are essentially the same-as the
~
' d38 no' strike ~ clauses contained in the previous contracts?
21 A That would only be'an assumption on my part,
, . 1 22 but;-I assumeJit is. I have not seen the contract wording
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- 1. ~as of'yet..in booklet form.
2 O Mr. Scalice, are you familiar with the proposed 3 : license conditions?
4 .A Yes.-
5 .0 And I think-you were here during the pcior-6 - deposition. There were' questions regarding this language 7 - of conducting other' operations?
~
-8 A .- Yes.'
- 9' O Can you tell me,,I'm looking at the
- Item 2 in
. 10 - - the' proposed license condition,.what other operations are
')
' -'11 assumed in'this provision?
.12 A I don't think there is any basic assumption-J 13 of what;those might be. I mea'n, there was no particular-
. 14 statement'of fact categorized in any fashion..
15 In other words, we'did not come up.with a list.
16 of them, but they.would cover.a wide range of things that.
117 possibly can be done.
. 18 Q Give'me an example'of the range of things that-19 could be performed?
.A Q - 20 A Aside from refueling, I changed nuclear 21 instrumentation which is in the' refueling mode and it I
V. 22 . would be work inside'the' reactor vessel of any sort:possibly,
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So,.what you are saying is that when this
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x s -: -2 language.was put'into the proposed. license condition, 3~
there was~no exhaustive list.that had been put together?
4 .A That's correct..
5 0- 'Was there any list put together to your -
6 knowledge setting forth what these other conditions would
.7 be?
8 A only verbalized, as I'm saying to you.right 9- now. We might;do'some internal vessel work which are 10 parts of normal refueling outages. ,
- 11 Q Is it your understanding, or is it fair to say that this language.to conduct such other operations
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- 12 13 is anything
- that LILCO would want to conduct so long as 14 . the' staff approved it?
15 A That'.s correct.
16 Q Mr. Scalice, looking at the. tech specs again, 17 I'm having the same trouble keeping track of the papers 18 here,.could you tell me what is'the status -- I'm looking 19' at the tech spec that was attached to your August 17,
- 20 1984 letter from Mr. Zeugin.
21 A Yes.
Q V 22' O I'm looking at -- there is a Tech Spec 6.0, i.
L _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ _ . _ _ _ . _ .______________._____.___l
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!1) [Adm'inistrative Contro'1,.and attached to that.is this tablei ,
f ,72: thati welhave bee'n? referri ng to; ' 6.-2.-2--l.
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4 Now',-.could youltell me,'what.'is the: status of .
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f4: this'. tech ~ spec? Is it approved?-
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L5 ~A Is it approved?, No._ Ws haven'.t completed l
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6' c proof; and ' review '.yet. This-is~a proof'and review' copy.-
7.
- 7. ,
7 It's'the metho'd:of operation;that_the Commission uses to -
s 3' not',to.l finalize ' tech . spec's in total ---
9: _
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.. 10 A' Until.some short time prior to closingiout
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11; all unclosed. items. This particular onelhas been around<
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.12 .for?a-lbng time.-
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I- 13 .O' Could' you; tell me, ha's this p'. articular tech 3
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14 : ; spec- been revised? :
[- 15 A. Chapter 6'is the~ administrative. control section,
- 16 ' , andswhen_.you change organizations of any. kind, if.you.
change' personnel.or you move division' people around, it
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k k'- ' 19 - Q My ques'tiori -is,- has this tech' spec ever ~ been-e.
$ 20 revised to;your knowledge?
f, 21 A Yes.-
22 O It-has been revised?
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1 A It has been revised, to my knowledge, yes.
2 Q Has it been revised since the County and State 3 were provided copies?
4 A No.
5 Q So, this is still the tech spec that LILCO is 6 working with?
7 A That's correct.
8 MR. MILLER: Let's go off the record.
9 (An off-the-record discussion ensues.)
10 MR. MILLER: I have no further questions. But 11 I would just like to make sure on the record that, Mr.
12 Zeugin, you understand our request regarding the documenta-13 tion that Mr. Stergakos referred to in his deposition, and 14 although Mr. McMurray said that he would like it provided 15 before Tuesday when trial begins, we would like that 16 document provided no later than Monday morning, in light 17 of the fact the trial begins on Tuesday.
18 And if there are any problems in that regard, 19 I would like to know because it is a matter which we would 20 have to consider taking to the Board.
21 MR. ZEUGIN: The only hesitation I have, I have N
22 not seen the documents that Mr. Stergakos has referred to.
47 1 I have no idea what their shape is. I will give them to 2 you. They may be totally meaningles's in the current 3 condition they are in. I'm not sure if you want someone 4 scratching on the back of an envelope as compared to him 5 putting it down in an orderly fashion so I can read it to 6 understand what he has done.
7 That's the only problem I have. I do not know 8 what shape these documents are in. But I will check and 9 do the best I can and get back with you and tell you what 10 I find.
11 MR. MILLER: If you would inform us as soon as 12 possible, and if we don' t hear from you we will expect 13 to have them Monday morning.
14 I have no further questions.
15 (Whereupon, at 12:45 p.m., the taking of 16 the deposition was concluded.)
17 18 19 ,
20 21 jg g JOllN A. SCALICE 22 bgg pA ,
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~ } CERTIFICATE OF' COURT REPORTER-
. .. . c . . m .. .>
2-
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3- f hfi- ' b J
,I., NYRTLE[H. TRAYLOR, Court Reporter, do hereby 4 ' certify that I; reported 'in' Stenomask the deposition of
- t. , ,
-5 John A. Scalice.-
4 '6' I further certify that said transcript contains
'7- a true and correct- transcription of the answers given to 8 the questions herein asked.
9 I further certify that said transcription was 10 done either by me or under my supervision. *
"< 11: I further certify that I have no interest,
.12 . financial or otherwise, in .the outcome lof this litigation.
13 Given under my hand this 24th day of August, 14 1984.
15
'w W n,/J. % Aet) 37 OyrtleH. Traylor #
Notary Public-'in.and for 18 the State'of Virginia at Large 19 (W) .
~
N My Commission Expires:
~ 21
,es June 1, 1985 b ,)s 22