ML20115A395
| ML20115A395 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/17/1984 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20115A397 | List: |
| References | |
| FOIA-84-633, RTR-NUREG-0680, RTR-NUREG-680 NUDOCS 8412060631 | |
| Download: ML20115A395 (9) | |
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' UNITS 0 571,735 N'JCLE :.R 3 3G8."_ ATC3Y CO.'.1s,.11SSION
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v July 17, 1984 NOTE T0:
- T. Murley, RI G. Cunningham, ELD E. Case,.NRR D. Eisenhut, DL, NRR J. Axelrad, IE G. Lainas, DL, NRR J. Stolz,-DL, NRR J. VanVliet, DL,-NRR J.lGoldberg, ELD J. Lieberman, ELD J. Gutierrez, RI William T. Russell, DD/DHFS FROM:
TMI:1 RESTART SER (NUREG-0680) SUPPLEMENT 5 - MAN
SUBJECT:
01's last investigation report (Change in Operator's Testimony conc 16, 1984. A revised write up
-0541 HPI actuation) was received by NRR on July for Section 11 of the Draft SSER is enclosed.
fied by OI's
.No issues related to GPUN management integrity were identi Investigation.
You'r concurrence in this revised write up will be assumed unless a 18, 1984.
The SSER must be released for
. response is received by COB, July 20, 1984, to meet the Commission's printing by 3:00 p.m., Friday, July Ordered scheduled for. Staff and Party comments.
'[M(.
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.d.C]iamT. Russell,DeputyDirector Will Division of Human Factors Safety
Enclosure:
As stated t
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l11.0 CHANGE OF OPERATOR TESTIMONY.
11.1. Background During the NRC staff's review of the GPU v. B&W lawsuit record, it was-de-of W. H. Zewe (former THI-2 Shif t -
- termined that the trial testimony (former THI-2 CRO) differed significantly Supervisor) an'd E. R. Frederick
.from previous statements made by.Zewe, Frederick, and C. C. Faust (former THI-2 CRO)(concerning the issue of whether or not full-flow HPI) had been manually initiated on the morning of the accident when the last two reactor coolant pumps were shut down (at 0541'on March 28, injection
-1979)..
-During the first days and months following the accident, Zewe, F'aust and
- Frederick were repeatedly interviewed by the NRC and GPU investigators in order-to' develop an understanding of the accident and a documented sequence of events (SOE).. Appearing before the Plant. Operating Review Committee (PORC) in mid-May 1979, the operators-insisted that full-flow HPI was man-At the ually. initiated when the reactor coolant pumps were secured at 0541.
trial, Zewe testified that the PORC modified the SOE to' include-this event Faust)
. based on the agreement of all three operators (Zewe, Frederick, and 2759-2763).
(Zewe at Trial Tr.Zewe discussed the countdown that was performed as Frederick on May 25, 1979, secured the reactor coolant pumps and Faust, initiated HPI (B&W 5000CC).
In addition, during separate interviews before NRC investigators, Faust and Zewe stated that HPI was* manually actuated when the reactor coolant. pumps wereAt a me secured (B&W 5006AA and B&W 271 at 30, respectively).
15, 1979, Zewe stated Adv.isory Committee on Reactor Safeguards (ACRS) on July secured (Zewe at Trial Test. 2756).
~
GPU's Annotated Sequence of Events dated February 6,1981-(GPU 2079) contains the following entry at time 0541:37: "The operator manually initiated' the Safety Injection portion of Engineered Safety Feature trains A and B to sup-The references provided ply additional cooling water to the reactor core."for this entry we operating staff and the PORC SOE' review meeting, (2) TMI staff interview con
-ducted-by Met-Ed/GPU with E. Frederick, dated March 20 and April 6, 1979, a 23, 1979.
(3) TMI staff interview conductM by NRC with Frederick, dated A GPU 2079 at 8, 41, 42.
see IE Bulletin 79-05A; IE Investigative list HPI actuation on or about 0541 (l Yesearch Institute's " Analysis of TMI Report, NUREG-0600; the Electric Powe Unit 2 Accident;" the Rogovin Report, "TMI Report to the Commissioners and to the Public;"'B&W's " Annotated Sequence of Events;" and B&W's " Final Report of the TMI-2' Occurrence").
In his opening statement at the trial on November 1, 1982, R. B. Fisk, the attorney for B&W, emphasized the GPU SOE conclusion that HPI had been init
_Had it remained on, he argued, core damage would not have ated at 0541.
11-1 NUREG-0680
Thus, Fisk concluded that Met-Ed was negligent by turning off the occurred.
Fisk further argued that the " mystery man," who turned the pumps HPI pumps.
off, could not have been a B&W employee; thus, B&W was not responsible for the core damage.
Fisk at Trial Test. 159.
During the trial, the testimony of Zewe and Frederick changed from their Zewe testified that he remembered only previous accounts of HPI actuation.one manual full-flow actuation of HPI, w Trial Test. 2170).
Frederick testified that HPI could not have been actuated at full flow at 0541 (Frederick at Trial Test. 3499).
Frederick's testimony was based on his understanding of the effect on makeup tank (MUT) level when HPI is initiated.
Frederick's expert testimony on this subject was sub-Thus, because of sequently eroded under cross-examination by B&W attorneys.
the importance of this issue to the trial, EDS Nuclear, Inc., was contracted to perform an analysis designed to determine whether HPI actuation occurred at The results TMI-2 at or about 0541 (0I Testimony Change Ex. 36 at 18).
The EDS of the EDS analysis were presented at the trial by J. H. Holderness.
analysis concluded that full HPI injection at or about'0541 did not occur (Holderness at Trial Test. 5636).*
Following the lawsuit settlement, GPU contracted B&W to perform an independ-ent analysis of this issue.
The B&W report entitled " Response to GPUN Questions Concerning HPI Actuation at TMI-2 About 5:41 a.m.' on March 28, 1979," was forwarded to H. R. Denton (NRR) by E. Blake (Counsel for GPUN) by letter dated September 15, 1983.
The 8&W analysis concluded that the reactor coolant system (RCS) experienced a significant cooldown during the period 0534 The evaluation concluded that, during the period 0534 to 0540, the to 0605.
cooldown was most likely caused by a combination of emergency feedwater (EFW) flow and partial HPI flow and that between 0540 to 0605 the cooldown wasT caused primarily as a result of EFW flow.
HPI actuation did not occur at the time the last two reactor coolant pumps were tripped (0541).
B&W Analysis at 54.
With the assistance of EG&G Idaho, the staff independently evaluated the possibility of HPI actuation at 0541 and performed a review of the EDS and On the basis of these analyses, it is the staff's conclusion B&W analyses.
that actuation of HPI immediately after the last reactor coolant pumps were tripped at 0541 is extremely unlikely.
The analyses showed that RCS cooldown occurred between 0534 and 060$ and that partial actuation of HPI for a short However, it is period (about 6 minutes), beginning about 0534, was possible.
not possible to conclusively affirm or reject limited HPI actuation i ately before 0541.
The results of the staff's evaluation are consistent dated April 24, 1984.
with the sequence of events described in NUREG-0600.
In a letter dated August 23, 1983, from E. Blake (Counsel for GPUN) to H. R. Denton (NRR) the licensee forwarded a brief prepared by the law firm of Because of the time constraints placed upon EDS to perform
- NRR staff note:
the analysis, EDS examined makeup tank level behavior around 0541 to The determine if the response exhibited characteristics of HPI actuation.
EDS report did not address actuation at any other time, and it did not examine other data which might be affected by HPI actuation.
11-2 NUREG-0680
~
Scholer, Fiennan, Hayes, and Handler (Kaye-Scholer). The brief en-
.Kaye, titled, " Memorandum on the 5:41 HPI Actuation ' Mystery Man' Issue," provided Xaye-Scholer's analysis of the key documents associated with the HPI actu-ation issue and the rationale for why the trial testimony of Zewe and Frederick-differed from accounts they had provided during earlier testimony, Following the September 1983 publication of depositions, and interviews.
NUREG-1020, the licensee provided its response to the public version of the 14, 1983, from H. Dieckamp (GPU) to the document-in a letter dated October With respect to the staff concerns regarding the 0541 HPI NRC Comissioners.
actuation issue, the licens_ee's position may be summarized as follows:
"The official GPU chronology of the accident sequence was comp-fled with i
(1) the assistance of a reputable technical consulting firm, and was based on extensive analysis of the accident data as well as the statements made by Met-Ed personnel to NRC and GPU investigators.
The specific inclusion of an HPI actuation at 0541 was predicated solely on the statements made by two of the. control room operators present at the time and was so identified in the chronology." Dieckamp letter 'at 21.
"The evidence adduced at trial was not a change in position' by GPU (2) management but a reflection of further technical study in order to refute the now disproven, spurious trial argument raised by B&W's counsel."
Id at 23.
The licensee used these statements and its counsel's brief, in part, to (3) argue that "when measured against the development of objective facts from detailed technical analyses and from the accident data, the fact t
that two of the operators' earlier recollections of manual actuation was
~
incorrect is fully understandable.." _Id. 25.
While the staff considered the statements made by the licensee in-its August 23 and October 14, 1983, submittals, neither fully answered.the staff's management integrity concerns expressed in the limited distribution version 4
of NUREG-1020.
These issues were specifically identified as follows:
In Section 10.7 of NUREG-1020LD:
whether the control room operators who had made pre-(1) vious statements concerning the 0541 HPI actuation had misrepresented the facts either when they originally said that such an action occurred or when they later said that such an actuation had not
, occurred if the latter, whether any improper influence was (2) brought to bear on the control room operators in connection with their testimony at trial i
whether licensee's reversal of position concerning an (3) actuation of HPI at 0541 was improperly motivated by financial considerations arising from the GPU v. B&W l
lawsuit t-11-3 NUREG-0680 i
Vw e
,(4) whether.the licensee:had an' obligation'to report and failed to report to the NRC the modification in its chronology of-theLaccident sequence
- The' staff recognized that possible explanations for. GPU's reversal of position on =the question of.a 0541 manual HPI initiation could include the c
difficulty.of recall in.a stressful situation with a reasonable, honestNevertheless, the
' effort at presenting the facts or wrongful conduct.
d ified above 1 believed that an attempt to find answers to the questions i ent
- should be undertaken.
Thus, in.a memorandum from H. R. Denton (NRR) to
'B. B.' Hayes (OI), the: staff requested that 01 investigate the.mattersNovember 7
- discussed in questions I through 3 above.
is discussed in 128-29. ;A more comprehensive background on this issue Sections 3.1 and 10.7'of NUREG-1020LD.
11.2 Investigation Results The OI. investigation ' developed testimony corroborating' th'e fact Jthat the control room personnel:at the time of the accident * (Zewe, Faust and Frederick) insisted on-including a manual HPI actuation at 0541 in the.GPU According to T. L. Van Witbeck, one of.the principal sequence of events.
authors of GPU's " Annotated Sequence of Events" (GPU Ex. 2079), the operators "were adament with regard to the initiation of safety injection on-or about this particular time.... The operators insisted that they had done this We had no information which supported that and I frankly was
-at that time.
in charge'of the~ accident assessment side and I said all right, we cannot I
-prove it and we cannot disprove it, we will put it in;-and we put it in.OI Te
- felt they were incorrect at the time."
According to R. C. Arnold, "the technical people that were looking at the objective data were generally of the opinion that the actuation had not
- However,
- occurred, that the operators were in error in their recollection."
be taken out of JArnold further explained that this one issue should not context, there were a number of issues where the recollection of operators were different from the technical-people that were performing the analyses from objective data.
OI Testimony Change Ex. 26 at-15.
The law firm of Kaye-Scholer was retained by GPU to represent GPU in its suit
. J.'Lieberman of the law firm Bishop, Lieberman and Cook, and Kaye-Scholer. for all trial matters (0I Testimony against B&W.
D.LKlingsberg, a partner in the law firm of Kaye-Scholer, was in charge of Id. at 4).
Klingsberg made the decisions on strategy and the lawsuit (iit consultation with either GPU or Lieberman (Id. at 6).
tactics witho
- F.'Schiemann was the THI-2 Shift Foreman at the time of the accid However, he was not' involved in the review of the SOE or other matters involving the 0541 HPI actuation, thus, no interview of Schierann was conducted by 01.
11-4 NUREG-0680-i
.9-d by W. G. Kuhns and H. M. Dieckamp, they had According to testimony presente Kuhns had no involve-little involvement in the actual conduct of the trial.
ment in the trial up to the point of possible settlement and was not aware at that time of any change in testimony by the operators (0I Testimony Change Ex. 41 at 6,-8).
Dieckamp stated that his main source of information during He received cop.ies of the transcripts, but the trial was the New York Times.
Arnold stated that he did not read them (OI Testimony Change Ex. 27. at 10).
was not directly involved in any of the trial strategy although he did pro-vide comments on the draft complaint against B&W and did serve as a principal He was not involved in the selection of Frederick witness 'during the trial.
as an expert witness and he was not-involved in the preparation of eitherO Frederick or Zewe for their testimony.
46.
P. R. Clark. testified that he had no involvement in the litigation effort H. D. Hukill stated that he against B&W (0I Testimony Change Ex. 28 at 5).had no respons discussions with any of the control room personnel regarding their testimony (01 Testimony Change Ex. 43 at 1).
~
R. C. Seltzer, also a partner with Kaye-Scholer and A. Mac Donald, an Asso-Seltzer ciate with Kaye-Scholer, worked with Klingsberg on the litigation.
stated that he became aware of the 0541 HPI actuation during the pretrial Seltzer depositions of the operators (0I Testimony Change Ex. 3 Klingsberg represented
. preparation of each of the other operators (Id.).-Zewe at his de their depositions and assisted Klingsberg durino Zewe's deposition (0I TestimonyChangeEx.36at9andEx.39at7,8).
D. E. Taylor, President of Taylor Associates, Inc., a firm specializing in 2
On at least two technical litigation support was retained by Kaye-Scholer.
occasions, Taylor and Mac Donald met with Zewe, Faust, Schiemann, and Frederick in an attempt to assemble the best collective recollection the operators had of the events (0I Testimony Change Ex. 38 at 16).
According to Klingsberg, Selzer, and Taylor, the issue of H opening remarks at the trial (OI Testimony Change Ex. 36 at 7, Ex. 37 at 7
^
and Ex. 38 at 19).
Kaye-Scholer's attorneys had no discussions with GPU before the trial regarding a position on the 0541 actuation (OI Testimony Change Ex. 37 at 21). ' After Fisk raised the issue of the " mystery man,"
f Klingsberg contacted Lieberman and Arnold to obtain engineering assistance l
Engineering assistance was from GPU-(OI Testimony Change Ex. 36 at 18, 19).
requested in order to perform an analysis to determine whether or not there had been an actuation of HPI at 0541 based on recorded plant data rather than' L
According to operators' recollecticns (0I Testimony Change Ex. 37 at 22).
l Klingsberg, this work was initiated by T. G. Broughton with the assistance of some other individuals in Parsippany, New Jersey (01 Testimony Change Ex. 36
(
Seltz.er stated that Broughton's study concluded that full. manual actuation of HPI at 0541 was not possible (01 Testimony Change Ex. 37 at. 23).
at 18, 19).
L L
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11-5 NUREG-0680
-. ~ - -... -,.., -.
Klingsberg participated in preparing Zewe for his trial testimony.
Klingsberg did not recall what studies or data, if any, were shown to Zewe
-during his trial preparation but he believed that Mac Donald went over the detailed facts regarding the HPI actuation at 0541 with Zewe.
Klingsberg did not believe that Broughton's analysis was discussed with Zewe because no results had been reached before Zewe took the stand.
01 Testimony Change Ex.
During Zewe's interview-with OI on May 10, 1984, Zewe stated 36 at 20, 21.
that after Fisk raised the " mystery man" argument, the preparation for his trial testimony became quite extensive.
Zewe recalled Mac Donald and Taylor
. presenting his charts involving MUT levels and other data and being asked to evaluate whether or not HPI had actuated at 0541.
Zewe stated that as a result of his-trial preparation, he was " totally convinced" that HPI had not OI Testimony Change Ex. 21 at 45, 55.
Zewe stated been actuated at 0541.
that he had not been interviewed by anyone in GPU management with regard to i
his deposition or trial testimony (Id.. at 52, 53).
Frederick was selected by Kaye-Scholer's attorneys to testify as to why there had not been an HPI actuation at 0541 to the best of h.is recollection and to provide expert testimony as to why the performance of the MUT level at 0541 was inconsistent with HPI actuation (0I Testimony Change Ex. 37 at 24).
. Frederick was selected to provide the expert testimony because he was partic-ularly articulate and was familiar with teaching nuclear power plant functions (Id. at 29).
During his trial preparation, Seltzer recalled that Frederick wirked with GPU technical personnel (Broughton's analysis group) in preparing for his expert testimony.
However, Seltzer stated that he believes Frederick was already convinced that the 0541 HPI actuation did not occur and.that his work with the GPU technical personnel reinforced that belief.
.Id. at 23-25.
During his trial testimony, Frederick stated that he recalled only one full, manual HPI actuation on the morning of the accident and that occurred about the time the site emergency was declared (0650).
Frederick also testified that on the bases of his review of the charts depicting what was happening with MUT level on the morning of the accident and his knowledge of how the MUT level reacted when HPI was actuated, HPI was not actuated at 0541 on the In making this assertion, Frederick relied on data r
morning of the accident.that showed a decreasing MUT level at 0541, which would Frederick said that if HPI had been were actuated according to Frederick.
actuated, a check valve in the MUT suction line would have shut and precluded any further level drop in the MUT.
He stated that he had seen the MUT level OI Testimony Change stop decreasing on initiation of HPI on many occasions.
l I
at 19.
During cross-examination by Fisk, Frederick was questioned concerning an t
l analysis performed by B&W, which showed that MUT level was also decreasing between 0718 and 0725.
This period included the manual actuation of HPI at l.
Frederick refused to 0720 that was confirmed.by the control room computer.
accept the B&W analysis as being correct because he believed it was im-l B&W agreed to possible to have a declining MUT level and HPI actuation.
provide the reactimeter data on which its analysis was based to allow GPU to l
As a result, Frederick did not testify L
l perform its own analysis of the data.
further on this issue.
OI Testimony Change at 20.
According to Frederick, he had no contact or interviews with GPU management during the time between The 01 his deposition and the trial (0I Testimony Change Ex. 20 at 80).
j l
i 11-6 NUREG-0680
/
investigation identifies contradictory testimony and statements by Frederick concerning his involvement in the inclusion of HPI actuation at. 0541 in the licensee's SOE.
The staff's position on this matter is discussed in Section 11.3.
See_OI Testimony Change at 4.
When Fisk cross-examined Frederick on the MUT level at 0720, which contradicted Frederick's explanation of how the system reacted during HPI actuation, Kaye-Scholer decided that it would no longer be sufficient to rely on GPU's internal expertise, thus, EDS Nuclear, Inc., was contracted to perform a study Seltzer could not recall the detaffs of the of the 0541 HPI actuation.
arrangement but believed that Kaye-Scholer must have gotten clearance from GPU OI Testimony Change management to contract for the study because of the cost.
Klingsberg stated that he made the decision to bring in EDS to perform at 24.
the independent analysis (0I Testimony Change Ex. 36 at 17, 18).
J. H.
Holderness, an employee of EDS, presented the results of the EDS analysis at the trial on January 3, 1983.
No further testimony by the operators concerning HPI actuation at 0541 occurred.
24, 1983, 12 weeks after the The lawsuit was settled out of court on January As a result, the issue of HPI actuation at 0541 was not resolv-trail began.
ed before the trial was terminated.
As discussed in Section 11.1, following the trial, Klingsberg authored a document entitled, " Memorandum on the 0541 Actuation Mystery Man Issue,"
According to Klingsberg, he prepared the document at dated August 16, 1983.
the request of Lieberman.
The purpose of the memorandum was to summarize the This was one of testimony regarding the HPI actuation / mystery man issue.
several memoranda that were prepared to respond to inquiries from various OI Testimony Change'Ex.
parties and individuals regarding issues in the trial.This document was s 36 at 67, 68.
Shaw-Pittman on August 23, 1983.
A corrected copy of the document was sent 25, 1983.
As submitted, there was no indication in by Shaw-Pittman on August the original cover letter regarding whether or not the document was being During Arnold's interview with OI on May sent to the NRC on behalf of GPUN.
Arnold recalled 31, 1984, he was questioned regarding this document.
receiving a copy of the document, but did not recall having any in document.
decided and perhaps even initiated the idea of having Kaye-Scholer set forth the background on the HPI actuation and what they had done to support 'he testimony that was presented on behalf of the company at the GPU v. B&W trial.
Arnold said the document was not 01 Testimony Change Ex. 26 at 36, 43, 45.
sent to the NRC to notify it of an official change in position by the company.
Instead, Arnold believes that there were a number of inquiries outside of the NRC regarding the " mystery man" issue and that it would be desirable for the l
attorneys who had represented the company in the lawsuit to tell the NRC i
"here is what took place, as we understood it."
Id. at 43.
l 11.3 Staff Findino On the bases of the EDS and B&W analyses and its own analysis, the staff The difference between the l
finds-that HPI actuation at 0541 did not occur.
li'censee's SOE and the staff's chronology of the accident, with respect to l
the HPI at 0541, was known to the staff at the time the SOE was submitted, as i
I
/
11-7 NUREG-0680 L
e
.(
was the basis for;its inclusion (i.e., operators' recollections of events).
The fact that the-licensee at some later-time refutes the operators' recol-lections does not impose a reporting requirement on-the licensee because NRC
. as already aware of the difference and concluded that it was not material.
w The staff finds that the operators' earlier statements, which led to the inclusion of HPI actuation at 0541 in the licensee's Sequence of Events, were However, on the basis of the OI investigation, the staff does not incorrect.
find any evidence of intentional misrepresentation of'the facts by these operators concerning HPI actuation at 0541.
The staff finds that Frederick and Zewe did change their trial testimony Faust did not tes.tify at trial anc
.concerning HPI actuation at 0541.
maintained, during his 01 interview, that his recollection that HPI actuation at 0541 had occurred.
However, on the basis of a subsequent analysis, Faust stated that his recollection may be wrong.
No evidence was developed by OI that would indicate any improper' activity or coercion by GPUN or Kaye-Scholer with respect to operators' change in testi-In fact, little or no contact many concerning HPI actuation at 0541.
occurred between the operators and GPU or GPUN management concerning issues Preparation of witnesses was the responsibility of involved in the trial.
Presentation of technical data to a prospective witness, which Kaye-Scholer.
differs.from his earlier statements or recollections, is not improper and is not a form of coercion.
The OI investigation identified conflicting testimony and statements by L
Frederick concerning his involvement in the inclusion of HPI actuation at Whether Frederick was silent and never 0541 in the licensee's SOE.
challenged the inclusion of HPI actuation at 0541, as he testified during the OI investigation and trial, or whether he insisted on including HPI actu-ation at 0541, as circumstantial evidence and testimony of others indicates, cannot be resolved on the basis of the evidence developed by OI. However, the staff finds that resolution of this issue is not material to a TMI-1 This restart-decision because Frederick is not a licensed operator at TMI-1.
matter is being handled separately from TMI-1 restart.
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UNkTED STATES
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NUCLEAR REGULATORY COMMISSION o
y WASHINGTON, D. C. 20555 I-
/
July 20,1984 y
l MEMORANDUM FOR:
Edson G. Case, Deputy Director l
Office of Nuclear Reactor Regulation FROM:
William T. Russell, Deputy Director Division of Human Factors Safety l
Office of Nuclear Reactor Regulation
SUBJECT:
MANAGEMENT REVIEW 0F NUREG-0680, SUPPLEMENT 5 -- TMI-1 RESTART This memorandum is to document management concurrences in the subject SSER.
I have personally obtained concurrence from the following involved staff and offices:
l telephoneconversationwithJ.Murray(forCummingham)and 1
l ELD I
J. Gray and J. Goldberg RI
- telephone conversati6n with J. Gutierrez (for T. Murley) 1
~ '
IE L(/
telephone conversation with J. Axelrad and W. Haass and l
discussion with R. DeYoung NRR/DL
- memorandum from Eisenhut plus telephone conversation with J. Van Vliet and D. Eisenhut NRR/DHFS - discussion with H. Thompson All authors of this SER concur and agree with the final product.
There are no known differing professional opinions on any matter raised in this SSER.
hhm&
William T. Russell, Deputy Director Division of Human Factors Safety Office of Nuclear Reactor Regulation i
/
______-_ ___-