ML20129H985
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l[N RE: GEORGIA POWER COMPANY 3
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9 10 l
i 11 Enforcement Conference before the Nuclear 12 Regulatory Commission, before Forrest M.
- Brown, 13 Certified Court Reporter and Notary Public, at 101 14 Marietta Tower, Suite 2900, Atlanta,, Georgia, on the i
15 19th day of September, 1991, commencing at the hour 16 of 12:30 p.m.
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BROWN REPORTING, INC.
24 1100 SPRING STREET, SUITE 750 ATLANTA, GEORGIA 30309 25
( 4 0 4-)- 876-8979 1]
I, 9611040164 960827 PDR FOIA KOHN95-211 PDR
7- +g-1 1
2 IN RE: GEORGIA POWER COMPANY 3
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9 10 t
11 Enforcement Conference before the Nuclear 12 Regulatory Commission, before Forrest M.
- Brown, 13 Certified Court Reporter and Notary Public, at 101 14 Marietta Tower, Suite 2900, Atlanta,, Georgia, on the
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L 15-19th day of September, 1991, commencing at the' hour 16 of 12:30 p.m.
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20 21 22 23
/1 A
BROWN REPORTING, INC.
Q 24 1100 SPRING STREET, SUITE 750
/
ATLANTA, GEORGIA 30309 25
( 4 0 4 -)- 876-8979 i]
l 9611040164 960827 PDR FOIA KOHN95-211 PDR_
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3 MR. EBNETER:
This is an Enforcement 4
Conference of-the NRC with the Georgia Power i
5 Company, licensedLof the NRC, with regard to the 4'
1 6
Vogtle generating station.
The subject of the f
7 conference is the set of those activities that were
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r-8 performed during the outage in October 1988 a t' the 9
station.
Specifically, those activities on October i
10 12th and 13th, with some. follow-up activities i
j' 11' related thereto.
t' 12 The conference is being held pursuant to 13 10 CFR 2, Appendix C.
The purpose of the conference i
14 is, one, to provide Georgia Power the opportunity to 15 place any additional information on the record that i
16 you feel is pertinent to the issues'and, two, the 17 NRC staff can get additional information-that we 18 think we may need for the informed decision on any e
19 enforcement.
20 The conference is being transcribed.
And i.
21 if you so request, you will be provided a copy of i
22 the transcript when it becomes available.
It is i
23 provided to you, we will put it in the public i
24 document to you, at the time that we place the i
25 enforcement-to you.
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1 Maybe I should-speak loudly, by.the.way, 2
so this gentleman can hear you and I, and identify 2
i 3-yourselves, particularly the people who don't have a 4
name, so it makes his job a little easier.
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1 1
5 You do have a copy of the agenda and I A
6-believe the court reporter has a copy.
Major issues 7
to be discussed are the results of the NRC office of 8
investigation report document case No. 2-90-001, 4
9 dated March'26, 1991.
That report concluded that 10 the actions of Georgia Power Company SRO assistant 11 general manager for operations are potential willful ~
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12 violations of the Vogtle plant tech specs.
In 13-relation to_that, there were certain management 1
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14 actions that were related to that, and thus going to 15 be a major topic on June 3rd, 1991.
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16 Mr. Sniezek sent you a Notice of 17 Enforcement and Demand for Information.
We have i
18 received your response, and we have reviewed it and 19 have developed some information that we would like i
20 the answers to.
And with.that, Mr. Sniezek, we wil.
j 21 open the conference.
1 22 MR. SNIEZEK:
Good afternoon, gentlemen'.
23 I'm Jim Sniezek.
I appreciate your attendance hera 1
24 today.
We are here to specifically discuss the 4
i 25 events surrounding the October 12th and 13, 1988, i
l a
4 a
,-.a
4 1
1 violation of technical specifications.
This 2
violation occurred during the valve manipulations to 3
inject hydrogen peroxide for the intended purpose of 4
cleaning the reactor coolant system.
5 Your August 29 response to our June 3rd 6
demand for information letter provided significant 7
insight to this matter, outside of the specifics l
8 concerning this event, based on the responses from 9
the company and the three individuals, I have a deep 10 concern for the manner in which the plant is 11 operated.
My particular area of concern involves 12 command and control.
13 After simulating the information you 14 provided, and I did review all of it, I was 15 wondering what the role of the shift supervisor and 16 operations superintendent on shift was in assuring 17 safe operation.
During the event in question, the 18 operations superintendent on shift seemed to be 19 deeply involved in diesel problems, while sadly 20 neglecting the rest of the plant.
I would like to 21 discuss some of these concerns during this 22 conference.
As you are aware, we interviewed Mr.
23-Kitchens this morning.
At the present, we don't 24 believe it will be necessary to interview the 25 remaining individuals involved with the chemical i
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e 5
l' injection.
'2 I understand that you have a 30 minute 3
. opening statement that you would like to.make.
I 4
would ask that~you limit your. presentation to that 5
time, since we have thoroughly reviewed the 6
information you submitted and,have numerous 7
questions.
For.our part, we will save all our 8
questions until you-have completed your remarks.
9-
.With that, please proceed.
10 MR.. MCDONALD:
I'd like to make a few 11 comments.
When we received notice of this l
12 Enforcement Conference our understanding of this 13 event in June was'quite different from the 14 conclusions that were contained in your letter.
We 15 reviewed the issue again in depth, and our 16 conclusions are still at odds with the contents of 17 that letter.
i 18 In providing you the response to the 1
19 demand for information, we attempted to address it 20 as completely and thoroughly as possible.
I've been 21 assured since it was a broad effort involving a 22 lot of people, I've been assured that the important 23 relevant information is in our response, i
24 Let me ask this question at this point.
l 25 Does Georgia Power have all the material informatio..
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1 available to us and in our hands, as you know it, 2
that the NRC will use in making a determination of 3
enforcement on this matter?
4 MR. SNIEZEK:
I personally don't know 5
whether you will or not.
6 MR. MCDONALD:
I'm sure you are aware of 7
some of the sources of information which we have not 8
had available to us, and it's pretty hard without us 9
reviewing those to assure that there are accuracies 10 or inaccuracies in that information.
11 MR. EBNETER:
Let me comment.
12 MR. SNIEZEK:
Let me comment on that i
13 first.
As far as the decision on this specific 14 matter, in my review of everything that you provided 15 us in your response, Mr. Kitchens' response, and the 16 responses of Mr. Cash and Mr. Boles, I saw nothing 17 that then covered the types of issues that we were 18 concerned about in developing the letter that I sent 19 you, the demand for information, fairly well laid 20 out the issues of concern, and I'm not aware of any 21 other information that I'm using in order to make a 22 decision in this case.
23 I'm aware that this stemmed originally 24 from investigation from our office of 25 investigations, and I'm aware that in the interviewr
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1 that not all, most of them, that there was a 2
company representative present, and I haven't used 3
anything beyond the office of investigation report 4
plus the information you've provided and the three 5
individuals provided and so far I don't intend to, j
6 But'the issues that were of concern to me, you have 7
definitely covered and your response to us was to 4
5 8
have Mr. Kitchens, Mr. Boles and Mr. Cash.
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MR. MCDONALD:
Can we be assured that if 10 something should come up from another source, which 11 only you are privy to, that we would be made aware 12 of that information if it had a material effect upon 13 your actions in this enforcement?
14 MR. SNIEZEK:
There's no, question in my i
15 mind that if I am the deciding official in this i
16 case, that I will use no information in my decision I
17 that would be material to the case that you would 18 not be aware of.
I don't play that way.
I play it 19 straight up, and if there is some information that 20 would bear on my decision and you have not had an 21 opportunity to respond to it, I think that would be 22 inappropriate.
23 MR. MCDONALD:
I understand you, you have 24 that reputation for fairness.
There are some l
25 possible legalities that we're referring to here and L--
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your good faith was never in question.
It was a 2
matter of are we going to have all the information, 3
and I think you've answered this question.
4 Another question, it is our understanding 5
in this Pmforcement Conference that it's intended to 6
bring it's intended to bring closure on all the
'7 mid loop matters.
Is this a correct understanding?
8 MR. SNIEZEK:
Let me give you my 9
understand.
My understanding is that I am -- we 10 intend to bring closure to everything that we had in 11 the demand for information which was sent to us.
If 12 there's something else on a separate mid loop matter 13 underway by the staff that's not in even in our 14 discussion process at this time.
15 When you say all, I don't know if.I can 16 respond to that other than the manner in which I 17 just did.
I'm not aware of any other issue that is 18 ongoing.
So maybe I don't understand your complete h
19 question.
You've got to be a little more detailed 20 in it.
21 MR. MCDONALD:
Well, again, there's been 22 some interactions with other cases, and parts of 23' which we haven't had available to us all the 24 information that we know exists possibly exists 25 out there, and I'm just trying to get a feel for
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.1 that.
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2 MR. SNIEZEK:
As far as I would know, and 3
I will ask any senior manager here that knows 4
differently, correct me, as far as the October 12th, 5
13th lith, 12th, 13th situation is concerned and i
6 our actions set forth that we were. contemplating in 7
our June 3rd letter to the utility and to the 8
individuals, as far as this case is concerned 9
relative to those to that time frame in the chemical 10 addition issue, I'm not aware of any other issue.
11 That does not mean to say if there's an 12
. ongoing investigation, for example, in another case 13 if information comes up, that we would not use that l
14 information.
But at this time, I'm not aware of any 15 other information that would bear on our decision'in 16 this instant case.
Obviously, we know what we know 17 as of the time we know it, and if new information 18 comes up, I wouldn't say that we would not reopen 19 the issue.
20 MR. MCDONALD:
Okay.
Then that would go 21 back to what you said, if new information came out 22 that was material that you were going to judge the 23 case on, we would be told about it.
24-MR. SNIEZEK:
Right.
We may make a 25 decision on this case today,. figuratively speaking,
10 1
and ' wo weeks from now find out more information 2
thLc would tell us our decision was wrong.
And I 3
cannot preclude that possibility.
4 MR. MCDONALD:
I understand.
Thank you.
5 I appreciate your straightforward response.
2 6
MR. SNIEZEK:
Let me interrupt, is there t
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any other senior manager sitting at this table that i
8 has different information?
9 MR. EBNETER:
No.
You ought to be clear, I
10 now OI has issued a report which is not available to 1
11 you.
You do not have that report and you will not 4
12 get that by agency policy.
13 MR. SNIEZEK:
That's my impression of 14 what Mr. Mcdonald was referring to in his first 15 question.
16 MR. MCDONALD:
Yes, sir.
17 MR. EBNETER:
That's not available.
18 MR. MCDONALD:
When I say if you have a 19 report, OI report, we have been provided attorney 20 we have been provided copies of those depositions 21 and things like that, haven't we?
22 MR. DOMBY:
The depositions, not the 23 reports.
24 MR. MCDONALD:
May I confer with my 25 attorney just a minute, please?
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(Discussion ensued off the record.)
i 2.
MR. MCDONALD:
I think it's clear.
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3 MR. SNIEZEK:
Let me mention something.
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4 The importance of this Enforcement Conference is to l
5 determine what you know,-the company and the i
6 individuals know about this incident, not 7
necessarily what we know,.now, in fairness we're to 8
arrive at a decision based on information that you 9
didn't have and were to take enforcement action-in 10 order for you to appropriately respond to that 11 enforcement action, you should have information 12 which is germane to your response to make sure you 13 could respond appropriately.
14 MR. MCDONALD:
But such relevant 15 information is usually brought out prior to the 16 enforcement being taken, is it not?
17 MR. LIEBERMAN:
Well, at the time the 18 enforcement is taken.
19 MR. MCDONALD:
So this is an Enforcement 20 Conference, if there were any information like that~
21 available now, you would have it, would you bring it 22 forward to the table that you knew we didn't know 23 about?
24 MR. SNIEZEK:
If there was information or.
25
'which I was basing a decision, and I knew you didn'-
a 12 1
know about it, at the time or before I we issued 2
any enforcement action, you should be provided that 4
3 information so you could respond.
I cannot ask you l
4 to respond to information that you don't know the 5
facts about.
i 6.
MR. MCDONALD:
All right.
I think I 7
think we're 8
MR. SNIEZEK:
Very simple, I'm not here 9
to play a game with anybody.
It's to make a 10 decision based on safety, based on compliance, with 11 the facts on the table, and proceed from there.
12 MR. MCDONALD:
I recognize that, and I 13 concur with you.
As you are well aware, this has i
14 been a long-drawn-out process and I would like to 15 get some feel if we are going to be able to close it 16 off.
It's gone on so long.
We all want to close it 17 out.
18 MR. SNIEZEK:
I definitely want to close 19 out the action that we have before us today, that's 20 the valve manipulations associated with the chemical 21 injection in mid October, and get it behind us, but 22 as I say, if new information comes up even after we 23 make the decision, you re-look at something, that's 24 the way 25 MR. MCDONALD:
Well, let me go on.
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1 appreciate your patience in trying to answer some of 2
.these hard questions.
3 I would like to say that it's unfortunate 4
that we're here today to address this matter of 4
5
_ voluntary interest and tech spec, LCOs and immediate 6
action statement.
We have a continuing regulatory 7
environment where definitive regulatory position 8
involving such things as cascading tech specs, 9
planned-entries into LCOs, definition of immediate l
3 10 action have not been f ormal-ly established.
And l
-11 where there are varied industry practices and 12 informal regulatory interpretations.
13 I am sure you would agree with me, I hope 14 you would agree with me, that enfor, cement action 15 should not be used as a substitute for formalized 16 grounds.
We're prepared to respond to your
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17 questions and continue with our presentation.
18 MR. SNIEZEK:
Okay, but before we get 19 into that, and I-mentioned we would not interrupt 20 but I don't think your formal 30 minutes hasn't 21 started yet, right?.
First and foremost, I 22 personally and NRC holds the utility totally and 23 completely responsible for the safety of operations
,1, 24 in compliance with the tech specs, notwithstanding 25 whether or not there's guidance from the NRC on w..
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1 is safe or what the tech specs may say, and I would 2
hope we'might reach agreement right up front first 3
on that.
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Secondly, if we have any interpretations.
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out which cause confusion, I would hold the utility 6
management responsible for immediately seeking 7
clarification of it, if there's a' question on 8
interpretation on any guidance that we would have 9
put out.
10 Thirdly, I will be quite frank'in the 11 beginning, since you brought it up,. Pat, I.wasn't 12 going to' mention it, but a great deal of your 13 response to our June 3rd le'tter talked about various 14 interpretations, none of which, and I viewed them 15 all, d o_ I believe is germane to this case.
16 MR. MCDONALD:
Well, let us continue with 17 our presentation.
We believe and we have a 18 fundamental ground rule of safety that supersedes 19 any goal or what have you but let's us proceed on 20 this.
'21 MR. SNIEZEK:
That's fine.
22 MR. McCOY:
Thank you, Pat.
I will try 23 and move through this quickly.
I have set this up 24 to be.less than 30 minutes.
These are the topics 25 that I intend to cover.
In addition, I will be I
15 1
happy to address the issue on demand and control, 2
Jim, that you brought up.
3 First, I would like to summarize the 4
conclusions that we have reached after carefully 5
reviewing this event.
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First, there was no deliberate or willful 7
tech spec violation which occurred.
The tech spec 8
interpretation was made in good faith with 9
regulatory compliance as the objective.
10 Second, enforcement for a tech spec
.11 violation is unwarranted in this case.
Voluntary 12 entry was consistent with existing regulatory 13 guidance and practice in 1988.
Although operators 14 mistakenly placed the plant in a condition which was 0:
15 not fully analyzed, a tech spec violation did not 16 occur.
And most importantly, better industry 17 guidance was and still is needed in this area.
18 Third, this event had minimal safety 19 significance.
Appropriate review and administrative 20 control was exercised during this event.
The 21 appropriateness was confirmed subsequently by 22 Westinghouse analysis.
This was not a common 23 practice, by this I mean entry into an immediate 24 action statement as Skip has discussed in his 25 meeting this morning.
Entry into tech spec LCOs
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I with immediate allowed outage time was. limited to 2-this unique case.
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3 At this time, I would11ike to clearly 4
state that there is no evidence of which we are i
5 aware that the operators had either, one, a 1
6 deliberate intent to violate the tech specs or, two, j '
7 a careless disregard for tech spec requirements.
8 Regarding the actions of the night shift g
9-on October lith and 12th, 1988, the' senior licensed
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10 operators were unaware that the tech spec was a
.11 applicable at the time that they authorized the-I 12
. openings of valves No. 176 and 177.
Based on their t
13 training and guidance at the time, these operators 14 did not know and should not have known that-the tech 15 spec was applicable.
Specifically no definition of i
16 loops not filled had been provided and in retrospect C
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17 it is clear many operators thought this meant above 1
18 the top of the loops.
Also, the procedures in use 4
19 did not recognize or provide guidance regarding this 20 issue.
i 21 Regarding the activities of the day shift 22 on October 12 and 13, 1988, the operations manager 23 exercised reasoned judgment and good faith.
He 24 first placed the evolution on hold and then 25 concluded or then conducted a careful and open 4
17 1
review of the tech spec, its basis and the FSAR.
2 The tech spec basis stated an intent to prevent an 3'
uncontrolled boron dilution.
4 The operations manager reviewed the FSAR 5
and concluded that the planned evolution had been-6 analyzed and that 15 minutes was available for the
-7 specified operator action and that appropriate 8
administrative controls would prevent uncontrolled 9
boron dilution.
RHe consulted with others, including 10 a more experienced operations manager.
The
-11 operations manager's knowledge and experience 12 supported his interpretation of the tech spec.
No 13' one on shift raised a concern about the evolution.
I 14 The operations manager was not motivated 15 by scheduler or economic benefits.
Specifically the 16.
actions he took extended the outage schedule and 17 cost additional money.
Independent, after the fact 18 reviews by the in-site manager, the plant general 19 manager, the corporate office, and the plant review 20 board confirmed the reasonableness of the 21 interpretation at the time.
22 In 1988' interpretation was consistent 23 with guidance available in 1988.
The voluntary 24 entry into a tech spec LCO requiring immediate 25 action is an evolving industry issue over which
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reasonable minds can differ.
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2 For example, in 1982, January 1982, NRC 3
guidance available to the industry regarding-l 1
4 standard tech specs stated, the NRC endorses 5
voluntary entry into the action statement conditions 6
and has structured the tech spec to permit the 7
licensee to exercise judgment within the-latitude
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8 permitted by the action statement language in the 9
' tech specs.
10 Second example, in 1987 view of the NRC j
11 Region 5 administrator stated that voluntary entry j
12 into tech spec 3.0.3 was appropriate on occasions.
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13 Specifically he stated Region 5 contends that 14 intentional entry into LCO 3.0.3 for o.perational a
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15 convenience should not be made except under i
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16 extremely unusual circumstances where a detailed i
j review by the licensee has concluded that no 17 a
18 reduction in safety will result.
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19 The third example, voluntary entry into 20 tech spec LCOs which use the word "shall" is allowed 21 by the NRC and other tech specs.
For. example, the 22 containment isolation valves shall be operable with 23 one or more containment valves inoperable, restore 24 the inoperable valves within four hours.
There ara 25 many other examples of these types.
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- Now, I'.d like to address the safety 4
2 significance of this specific event.
The October
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3 12th, 1988 entry into tech spec 3.4.1.4.2 had 4
minimal safety consequences.
The entry was made I
5 under appropriate administrative controls.
The 1989 6
Westinghouse analysis confirmed that short duration 7
opening of the RMWST valves is not a safety issue.
8 In February 1990, a tech spec amendment 9
was approved based in part on lack of adverse safety 10 impact.
11 In August 1991, Westinghouse performed an 12 analysis of the actual effect of this specific 13 October 1988 evolution.
Specifically with the boron 14 concentration that was available on, October 12th, 15 that is, 774 PPM when valves opened,'over 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 16 of flow would have been necessary to reach-
-17 criticality, nine hours from the time a high flux 18 alarm was received in the control room.
You will 19 recall that administrative controls were established 20 limiting the flow time to five minutes.
21 Importantly, this was an isolated evolution, there 22 was no broad application of this interpretation.
23 I would now like to discuss some things 24 which contributed to this event in our opinion.
25 First, the outage planning process and review i
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process included insufficient operations review to
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identify potential tech spec issues and to point i
3 these out to the shift operators.
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Second, there was insufficient guidance 1
5 and training regarding the loops not filled 6
condition of mode S.
Specifically the top of the 7
hot leg-was considered loops not filled without j
8 consideration of the water displaced from steam l
9 generator tubes.
i 10 There was no' clear guidance concerning i
11 voluntary entry into. tech spec with immediate as an 12 allowed outage time, either from the NRC or Georgia i
13 Power Company.
There were ambiguities-in the FSAR 1
14 analysis resulting from incomplete revisions to the 15 FSAR.
This led the operations manager to an 16 erroneous conclusion regarding prior analysis of l
17
. boron dilution action.
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And finally, the tech spec interpretation s
19-was too narrow.
The process of tech spec 20 interpretation was too narrow.
That is, available I
21 expertise was not effectively utilized to obtain the 22 best interpretations.
p 23 Georgia Power Company has since taken i
24 extensive and effectivei. corrective actions to i
25 strengthen these weak areas.
First, with regard to f
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1 outage planning, our process has matured 2
significantly since the first refueling in 1988.
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Vogtle procedure 29537-C, revision five, defines a 4
multi-discipline process for review of outage 5
activities.
Licensed SROs are now working in the 6
outage planning group full-time.
7 There is also greater operations 8
department review of subtasks assigned for the 9
outage.
Compliance with tech specs is a focus now 10' in this planning process.
Special consideration to 11 configurations resulting in reduced RCS coolant 12 inventory including many improved procedures, 13 equipment and training have been implemented in this 14 area.
15 Greater attention to risk management 16 during outage conditions has become a standard 17 practice at Vogtle.
The ILT that followed the March 18 1990 event identified outage planning as a 19 weaknees.
Subsequent Georgia Power improvements 20 have been noted in the December 1991 SALP report.
21 Next, regarding the loops not filled 22 guides.
February 1389 Unit 2 violation, a February 23 1989 Unit 2 violation on a related event led to 24 significant enhancements in this area.
First, a 25 February 22nd, 1989, tech spec interpretation from
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the operations manager specifically addressed tech 2
spec 3.4.1.4. loops filled condition.
3 Second, early in'1989,-shift briefings 4
and operations reading books contained entries 5
addressing the RMWST valves and their required 6
positions during mode 5B and 6.
Also, other 7
procedures including.-- I'm sorry, that was out of 8
order.
Also, other procedures including the Vogtle 9
12,006-C were revised to add precautions regarding 10 RMWST valve operations.
i 11 Guidance available to operators 12 concerning water levels and reduced inventories of 13 the RCS has also significantly evolvud since the
-l 14 October 1998 or 1988 time frame.
Plant data 15 books have been revised several times to add 16 pictorials and details concerning RCS water level 17 information for the operators.
Training is now 18 provided specifically concerning the loops not 19 filled condition.
20 In March, on March 30th, 1990, further 21 clarification was provided to the operations 22 department based on additional analysis from 23 Westinghouse regarding the inventory assumed and 24 regarding loops not filled.
This has now also been e
25 included in the training program and in the
1 23 3
5 1
procedures.
During re-qualification training, 2
operators receive specific training on revised 3
procedure 12,006-C regarding the opening of the 4
RMWST discharge valves and tech spec interpretations 1
4 5
of loops not filled.
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Regarding voluntary entry in the tech 7
' specs, on October 2nd, 1989, a corporate policy from 8
myself providing overall guidance on this issue was 9
issued.
Specifically, it stated in part, voluntary 1J entry into an LCO which expressly prohibits a given 11 condition and requires immediate corrective action 12
.should not be made.
13 On August 15th, 1991, after we-became 14 aware of recent internal NRC positions, a memorandum 15 from the Vogtle general plant manager advised 16 operators that the NRC does not endorse voluntary 17 entry in the LCOs which do not have a specific 18 allowed outage time.
Specifically his memo stated, i
19 Georgia Power Company has recently become aware of 20 an NRC position that tech spec LCOs and their 21 associated action statements which do not provide a 22 specific LCO action time, often referred to by the 23 NRC as an allowed outage time or AOT, should not ba 24 voluntarily entered except as expressly provided : n 25 the associated surveillance requirements.
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Regarding the FSAR accident analysis, the 2
boron evolution accident has been re-analyzed by l
3 Westinghouse in November of 1989.
This supported j
4 the tech spec change to specifically allow opening 5
of the RMWST valves for short periods.
The FSAR is 6
scheduled for further clarification in the next 7
annual update in 1992.
8 Regarding the tech spec interpretation 9
process, this is governed by Vogtle procedure i
10 10,000-C which has been revised significantly since 11 October of 1988.
It specifically incorporated l
12 comments of the NRC special team inspection of 13 August 1990.
14 Key points in the improvements are that 15 interpretations may be made by the line responsible 16 supervision, that is, the shift superintendent, 17 operations superintendent, and the manager of 18 operations.
Concurrence must now be obtained from 19 the technical support manager.
The technical 20 support manager must obtained any appropriate j
21 licensing support and/or NRC consultation.
Current 22 technical the current technical support manager 23 is also a licensed SRO.
24 Corporate licensing support plays a more 25 extensive role than in October of 1988.
They bring i
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L 25 to bear research capability and shared planning 1
2 experience in the industry outside of_.that available
'3-at the plant.-
Communications with the NRC on these 4
types of issues have also significantly improved.
5 The final approval is always obtained from the 6
manager of' operations.
7 Finally, regarding Georgia Power's 8
overall assurance of tech spec compliance, operator 9
training strongly emphasized tech spec compliance, l
10 Re-qualification training addresses plant 11 modifications,. procedure changes, significant 12 operating experience, and this includes significant 13 interpretation and events.
14 Vogtle procedure 10,000,C clearly assigns
'15
. specific responsibility to' operations personnel to 16 ensure compliance with applicable regulations.
The o
17 operations department management places emphasis on 18 safety and compliance as primary concerns.
It 19 encourages a questioning approach to operation of 20
.the plant.
It encourages access to management and 21 discussion of the issues to obtain the benefit of 22 experience and perspective and it emphasizes 23 teamwork.
The department managers are tasked to a
24 routinely observe activities and compliance with j
25
~ procedures and regulations.
i i
t 26 l
j l
1 A pisitive discipline policy is j
l 2
effectively used for individual accountability, that 3
is, in terms of compliance with technical 4
specifications and procedures.
And more 5
importantly, management expects a compliance 6
oriented safety culture, and this is frequently and 7
clearly communicated by line management including 8
- myself, t
9 I would now be ready to respond to any 10 questions you might have.
11 MR. HAIRSTON:
I would like you to l
12 clarify what you said on this bullet right here.
13 MR. McCOY:
Back on the initial.
George 14 asked that I go back and talk about this last item 15 where it says entry into tech spec LCO with 16 immediate allowed outage time was limited to this i
17 unique case.
This is another example that is l
l 18 similar to this case that Skip Kitchens talked about i
19 this morning, on the entry of the DIRPI system to do 20 troubleshooting, but other than that, and what I had 21 in mind with this statement is that this particular 22 type of statement or interpretation has not been 23 applied broadly or in other cases.
I i
24 MR. SNIEZEK:
We've got quite a few 4
25 prepared questions, some of which you addressed in
27 j
1 your statement.-
I commend you, that was only'about 2
20 minutes, well within the 30 minute _ time frame, I
3 but before we do that, I think we would like to 4
cover questions that your presentation itself may j
5 have raised that we didn't have before and I would 6
like to start out with that.
7 The point that you just clarified and f
8 that Mr. Kitchens discussed, what you are really 9
talking about in that last bullet on your first j
10 slide, I believe is voluntary entry into tech spec I
11 action statements.
You have involuntary entry into 12 many tech spec actions statements, that just puts I
13 you in there.
I j
14 MR. McCOY:
That's true, voluntary entry i
15 into action statements.
d 16 MR. SNIEZEK:
Based on the discussion we 17 had with Mr. Kitchens this morning, my own view is 18 that there's very little similarity or commonality i
19 between that 1987 situation and the situation we're 20 talking about today, but reasonable people could 21 differ on that.
To me that was more of a plant put 22 in that condition and you stayed in it a little 23 longer then, so you really are talking a little more 24 about what the word "immediate" means versus entry 1
25
'into the action statement.
That's my understanding
-. ~
)
28 i
1 of the issue.
1 i
4 2
.MR.
McCOY:
Jim, I think to give you my i
q 3
perspective on that, I can see how a person in his 4
' position could have interpreted that in retrospect 4
5 as being a voluntary decision made in advance to
{
)
6 entering into the statement.
7 MR. SNIEZEK:
I am not debating.
I just 8
want to make sure we have a common understanding as i
9 we discussed here.
That was my only purpose for i
j 10 bringing that issue up.
i i
11 Regarding your interpretation, your 12 fourth slide, you said, the operations manager first 13 placed the evolution on hold and then conducted a l
14 careful and open review of the tech spec basis and i
15 FSAR.
Can you explain to me what you mean by the 1
16 word "open,' open review?
4 17 MR. KITCHENS:
Yes.
He had other people i
a 18 who were involved in the review with him, j.
j specifically the deputy operations manager, and the 19 20 shift superintendent.
These were both the key 21 people involved in making that determination.
22 In addition, a large number of other 23 people knew that this was being reviewed and if they 24 had any input concerning having an opportunity to 25 bring that forward, including the people on shift.
1 i
- - - ~, -
1 2
4 i
4
)
29 2
1 and.all of the people at the normal outage being-4 2
involved.
i
{
'3 MR. SNIEZEK:
To the best of your j
4 knowledge, or knowledge-of any people representing a
5 the utility, did anybody bring-forward a concern i
6 regarding what was happening, other than the initial 7
concerns that Mr. Hopkins and Mr. Gasser brought j
i 8
forward at the start of the issue?
j 9
MR. McCOY:
To my~ knowledge, no 'one 10-brought forward a concern with that issue, and I i
1 11 4:uld like to take this opportunity, because I think 12 it may have been mischaracterized, to what 13 specifically the shift supervisor, the oncoming 14 shift supervisor, what his concern was, and Jeff 15 Gasser was the oncoming shift supervisor.
16 Jeff, would you explain what your 17 concerns were when you came on the shift?
18 MR. GASSER:
Yes, sir.
I am Jeff Gasser 19 and I was the unit shift supervisor on the day shift 20 on the day of October 12th, and when I came in and 21 realized and saw that the valves had initially been 22' opened to fill the chem add pot and realized that 23 the planned activity was to inject those chemicals, 24 I recognized that we were in the loops not filled 25 condition and looked-up the tech spec action.
i 30 j
1 After seeing that it required immediate l
2 closure, I thought about
' based on my training and i
i i
3 knowledge of the evolution and the accident that the l
4' tech spec action was based on, I came to a j
5 conclusion in'my own mind that we could open those 6
valves momentarily to inject the chemicals and I l
I 7
felt that was a safe thing to do and was in-
)
l 8
compliance with the tech specs.
However, due to the 9
questioning attitude that we try to foster on shift, 10 I wanted to make sure that my supervisors agreed 0
i 11 with that, and I also wanted to get further i
12
. clarification on what would be an appropriate time 13 to comply with the immediate action.
i 14 So I felt that it was.the safe thing to 4
15 do, I felt it was correct and in compliance.
I 16 didn't have I didn't have a concern that it would 17 not be in compliance, but I wanted to verify that 18 and get further guidance.
4_
19 MR. EBNETER:
Can I ask you a question?
's 20 MR. KITCHENS:
Yes, sir.
s 21 MR. EBNETER:
What training did you get 22 that nobody else got that enabled you to determine 1,
23 that the loops were not filled?
1 j
24 MR. GASSER:
I can't put my finger on any i
25 specific training.
I believe it was my a
i i
. _._ _. _ _ _ _ ~. _
4 31 1
understanding of where that tech spec is and the 2
bases of the tech spec being that being the 3
source of heatsink to the RCS, that if you don't 4
have any water in the steam generator tubes and I 5
felt that the steam generators couldn't be used as a 6
heatsink and, therefore, that put us in the loops 4
7 not filled condition.
8' MR. McCOY:
I think it's appropriate for i
j l
9 me to comment that Jeff has distinguished himself at 10 Vogtle as being one of the most perceptive SROs 11 particularly in the area of accident analysis and 12
.that sort of thing.
He's recognized as an expert in 13 the area.
14 MR. SNIEZEK:
On that same page on that 15 slide, third bullet, you said, the' tech spec basis 16 stated an intent to prevent an uncontrolled boron 17 dilution.
'By making that statement, are you trying 4
18 to differentiate between a controlled boron dilution l
19 and an uncontrolled boron dilution?
20 MR. McCOY:
That word " uncontrolled" l
21 boron dilution is my understanding that that word i
i 22 was important in the operation manager's mind when 23 he made that interpretation.
That's the reason that i
j 24 I underlined that.
25 MR. SNIEZEK:
So you put it in the 4
i a
J J
h 4
r 32 1
context of the operations manager's understanding?
2 MR. McCOY:
That's correct, i
4 3
MR. SNIEZEK:
Not your own personal 4
understanding?
l 5
MR. McCOY:
That is correct.
i j
6 MR. SNIEZEK:
Okay.
On the next slide, 7
you discuss the January 1982 guidance, NRC 8
guidance.
I completely agree with what you say 9
there as f ar as it goes.
But you leave out a very
)
10 important sentence.
11 MR. McCOY:
When was that 12 MR. SNIEZEK:
The following sentence to 13 your quote here says, the tech spec also restricts 14 facility operation in the specified grade and mode W
15 of operation to the limited period of time 16 designated in the related technical specifications, i
17 which in this case was the immediate.
1 18 I don't think there's any question that 19 the NRC endorsed voluntary entry into action 1
20 statements under certain conditions, but was also 21 limited to the time frame that was specified in the 22 technical specifications, and in this case, it was 23 time frame used the word "immediate."
I just 24 wanted to make that point so we don't misunderstand.
25 MR. McCOY:
There's two issues here that
33 1
we've discussed and one of the issues has to do with 5
2 the fact that you start with the assumption that 3
voluntary entry into action statements is allowed 4
and that judgment should be_used in doing that.
And 5
that was the purpose for referencing this because in
]
6 this case his mindset is, as I can reconstruct it, 7
was that he was voluntarily entering a tech spec 8
action statement after considering the consequences
]
9 and exercising judgment.
t 10 MR. SNIBZEK:
And the second phase would
)
11 be the focus-on what immediate means?
12 MR. McCOY:
That's correct.
4 13 MR. SNIEZEK:
All right.
On your slide 1
14 I don't know which number it is.
4
(
15 MR. McCOY:
Just give the me the title of l
16 it.
i
~
17 MR. SNIEZEK:
Corrective i
18 action / enhancement.
4 19 MR. McCOY:
The one on outage planning, 4
20 is that 21 MR. SNIEZEK:
No, voluntary tech spec I
22 entry.
1 23 MR. McCOY:
Voluntary tech spec entry.
~
24 Okay.
j 25 MR. SNIEZEK:
You indicate that on 1
i
-n
.. -.. _.-. - - - - ~ -. -. -. - -.. -..
a 34 1
October 2nd, 1989, you issued guidance.
Why did it 2
take one year to issue guidance when the~ problem was 3
. identified in October of 1988?
Why-did-it take the
~
4 company that long to-issue guidance?
5 MR. KITCHENS:
This guidance was' issued 6
'specifically after it was brought to my attention by 7,
the licensing manager, and it was brought to his 8
attention by the tech support' manager at the plant, 9.
when in preparing a tech spec change, someone i
10 questioned whether or not the original 11 interpretation had been made properly.
And so it l
1 12 did not get brought to the licensing department's i
13-attention initially and did not get brought to my j
i 14.
attention.
15 MR. SNIEZEK:
Do you consider that an 16 acceptable length of time when there's an 17.
interpretation question on the part of the 18 operations staff, a year to wait for the company i
19 interpretation?
20 MR. McCOY:
No, I don't.
I think we have 21 strengthened that process, as I say, in another 22 slide now, and an interpretation of this
- 23 significance, I feel confident now would be brought 24 to my attention by the plant manager.
25 MR. SNIEZEK:
On your last slide, overall l
~ ___
I i
35-iu 1
assurance of tech spec compliance, the first bullet i
i 2
you say that operator training' emphasizes tech spec
.3 compliance.
Would you talk a little bit more about 4
what you really.mean by that?
i a
i 5
MR. McCOY:
Okay.
One of the things that
)
6 we' emphasis to all our operators, and particularly J
7
. licensed operators, is the importance of ensuring 1
8 that they comply with regulations and specifically 1
9-the tech specs i the things that they deal with day 10 in and day out the most.
{
11 We believe that our success in operating 1
12 these plants safely, and for public acceptance, i
l 13 depends very strongly.on our ability to interpret 14 and comply with tech specs, and we depend on the j
i
. 15 operators on shift to be able to do that, or to stop I
16 and ask for guidance if they have a question.
And 17 we emphasize that over and over, and I've done'it L
18 many times personally in meeting with the operations 3
19 groups.
l 20 MR. SNIEZEK:
Then I want to jump down to i
21 the last bullet on that slide, that you expect v
22 compliance oriented safety culture.
I'm not sure 23 what that means.
I i
4 24 MR. McCOY:
Okay, well, let me try and 25 expand on that, i
2 i-4 36 1
The purpose of our plant is - to. generate 2~
electricity, but in doing so we feel that our number 3
one thought at all times has to be-on the safety of 4
the plant.and, secondly, on regulatory-compliance.
'5 Regulatory compliance assists us in many-cases.in 6
operating the plant safely,.but regardless it is an 7
obligation that.we accept when we accept the license 8
to operate the plant.
'And I have communicated that 9,
clearly many times, I think it is essential and that 10 is a fundamental message that'every'one of my 11 operators I think will repeat back to you, at_any
' 12 time.
That's how strongly I feel about it.
1 13 MR. SNIEZEK:
.That's whether or not 14 something is covered by.the tech specs,-even if the 15
-issue isn't addressed in the tech specs or if it's 16' wrong in the tech-specs, safety comes first, is'that 17 the message?
18 MR. McCOY:
Yes, that's the message.
19 MR. SNIEZEK:
Those are-all the questions 20 I have on the presentation.
Ask~any follow-up.
21 MR. EBNETER:
I don't have any.
1 22 MR. PARTLOW:
None other.
23 MR. LIEBERMAN:
I have some on the fourth
- 24 slide, the one with the action of the night shift o r.
25 October lith and 12th.
--. ~... - -
I 1
37 j
1 MR. McCOY:
Okay, I have.it.
c 2
MR. LIEBERMAN:
The second bullet 4
3 involving training guidance, do you accept J-4 responsibility that the company should provide that 4
5 training guidance?
I' 6
MR. McCOY:
Yes, I do.
I also feel that j;
7 there is an obligation on the part of the regulator s
8 to make guidance clear when there is evidence that
{
9 9
it is not clear, but I accept fully my 4
10
' responsibility to making clear regardless.
j 11 MR. LIEBERMAN:
Okay, on the next slide, j
12
. actions of the day shift of October 12th, 13th.
The 13 next to the last bullet, is talking about the
+
14 operation. manager was not motivated,by schedule or i
i 15 economic benefits, I believe you made a comment that j
16 the delay in chemical addition did have some cost to 17 the company?
18 MR. McCOY:
Yes.
19 MR. LIEBERMAN:
Could you give me some 20 estimate as to the type cost it was?
21 MR. McCOY:
Well, what I had in mind by J
22 that is when he placed the evolution on hold, that 4
}
23 evolution is on critical path, that is, it affected 1
24 the overall outage time.
The outage of a nuclear 25 unit in our system costs the, customers and the 4
4 J
, -. = - - - - -... - - - - - -
I 4
7 i
38 3
1 1
company approximately a quarter of a million dollars 2
per day and i.
3 MR. REPKA:
He's got the figures right 4
there for you.
5 MR. McCOY:
This is submitted in'our --
i b
i 6
you want to quote the exact place?
1 I
1 7
MR. REPKA:
This is Attachment 3 to
)
8 Appendix 2 of,the company's response to demand for j
i 9
information.
j 10 MR. PARTLOW:
Ask a related quest' ion, I 11 realize that you answered our question about costs 12 and schedules by saying, clearly we took the penalty I.
13 by doing the chemical addition and, therefore, there 14 were no costs or schedule implications.
?
15 Let me ask it another way, suppose it 4
16 were given that you~were going to carry out chemical 17 cleaning, and taking the given at that time, you 18 said, by golly, we can't do it now the way we were j.
19 going to do it, we need another way, would that i
20 delay, informally, speculative, would that delay i
j-21 have been hours, days, or weeks to the outage?
22 MR. McCOY:
Jim, I can't give you a 1
23 definite answer to that.
I think there would have 24 been several alternatives and I think there may hava I
5H5
'been different times depending on different i
3
-~
j 39 1
1 alternatives.
2 MR. PARTLOW:
Okay.
)
L 3
MR. LIEBERMAN:
If I could continue, on i
4 the slide that refers to institutional weaknesses 5
identified.
On the last bullet is tech spec i
6 interpretation process too narrow.
e 7
Would you go over again what was too i
8 narrow about the interpretation?
i 9
MR. McCOY:
What I meant by that comment 10 was that where time is available, I believe, and j-11 we've now communicated this clearly to our 12 operations people, that time.should be taken to get i
13 sufficient-perspective brought to the issue that you J
}
14 are comfortable that there's not other available 15 information that would be germane and could help you a
{
16 make the decision..
And that includes consulting 17 with the NRC, which we do frequently now when we 18 have a question in this regard, if it's not if it 19 does not appear to be clear to us, and consulting 20 with more experienced operators and managers.
I 21 However, I should make clear that we all 22 recognize that the operator in the plant holding the 23 license at certain times has to make interpretations
{
24 on the spot.
That's his licensing responsibility.
i
)
25 But when he has the time available, we think that he 1
..~.. _. _.~
i 40 I
1 should use all the resources available to him and we
]
2 tried to communicate.that to.everybody.
I believe i-3 we do a much better job of~that today than we did in 4
1988.
5 MR. LIEBERMAN:
So in this type of a 6
case, in hindsight, time was available applying 7
today's standards.
i l
8 MR. McCOY:
That's right.
I think more
{
9 people could have brought to bea'r on that-issue.
1 j
10 MR. LIEBERMAN:
One'last question, that 11 is on.the slide voluntary tech spec entry'having to j
i 12 do with your policy October 2nd, as well as the 13 August 15th, 1991 memorandum, using-the phrase 14 "should not be made."
Does "should nota mean shall 1
l 15 not or what does "should not mean"?
l 16 MR. McCOY:
I'd like to read you a couple
~17 of things-in there.
First, let me say that i
18 recognize that this was made in, I believe, 1989, at 19 the time that this was under review, and since that 20 time there has been further information that we've 9
i 21 become privy to, and so our position has now-been 4-
{
22 restated by the general manager, as I've said, 23 further.
But at that time, I think the-memo that I 24 put out, my recollection is that it recapped a lot J
25
'of the reasons there and a conclusion that we
- i I
~
i I
41 i
i reached was not a regulatory black and white kind of 2
issue.
3 It was an issue that basically and 4
there's I won't read all of this, but there is a 5
two-page memo and there's a large discussion and a i
6 background on the history of this and various 7
interpretations that have been made in the industry, 1
1 8
and based on that, the conclusion we reached was 9
that you should not go into this because there was a 1
10 possibility that you could get into an unanalyzed 11 condition as occurred in this particular event.
And 1
12 it was a policy guidance memo.
That's the way I J
13 would characterize that to the plant manager.
14 MR. LIEBERMAN:
When I read the memo, and 15 it went through the history, as you said, and I got i
16 down to the bottom line, should not be made, in the 3
17 past it hasn't been done frequently as you point 18 out 19 MR. McCOY:
Right.
j 20 MR. LIEBERMAN:
relative to me.
So I
)
21 said to myself, what guidance is the company telling 22 me.
l 23 MR. McCOY:
Well, what I did in that 24 memo, is I tried to characterize actually my 25
' licensing engineer, Jack Stringfellow, prepared that
42 1
memo and he went over it with me in detail and 2
discussed his sources of information.
And what I 3
was trying te do was provide the plant manager with 4
a better understanding of the iesue.
5 I trust the plant manager's judgment in 6
circumstances such as this, assuming that he has all 7.
the information that I was trying to provide him 8
with the best information I could.
u 9
MR. LIEBERMAN:
Okay.
10 MR. EBNETER:
I have one question.
On 11 the slide you don't have to pull it out, 12 institutional weakness identified, you have listed-4 13 at least five items, and in your response I think 14 you just listed causes.
15 MR. McCOY:
Right.
16 MR. EBNETER:
None of them speak directly 17 to that this was really management weaknesses.
18 MR. McCOY:
Right.
19 MR. EBNETER:
Do you in retrospect 20 consider that the weak, my word " weak," management 21 set the operators up for this sort of situation?
22 MR. McCOY:
Yes, I do.
And let me 23 comment on that to some degree.
My previous job 24 before coming to Georgia Power shortly before this 25 event in 1988, I had worked at Info as the vision i
4
43 1
director as the operations director which was 2
specifically responsible for evaluating the 3
performance of the operations area.in all plants in' 4
the U.S.,
specifically related to the risk those 5
plants incurred in their operations of a before 6
damaging event or, the terms that we used, reactor 7
safety.
That was my day-to-day job for several 8
years.
9 When I came to Vogtle, one of the first 10 things that I looked at was what is the culture that 11 exists, what is the character, what is the training 12 of the people in regards to that.
I have worked 13 with our people at the plant over the last three 14 years to improve that culture, to s,trengthen the 15 management, to strengthen the training and 16 understanding of the people in that area.
And I 17 think that we have made significant progress in this 18 area.
19 We have recently had evaluation in this 20 area by Info that resulted in no findings in the 21 operations area, that is, been made available for 22 your residents review.
From my experience at Info 23 that is very unusual.
24 So the answer to your question is that :
25 do believe there were some institutional weaknesses
1 h
l-44 1
in our.own management and I.do believe that there 3
i l
2 were some institutional weaknesses in the NRC's 3'
guidance history that tended.to set up some of the-4 4
' people that were involved in this.
l 5
MR. HAYES:
I have.a couple of questions, i
6 Mr.- McCoy.
I'm a little unclear on your slide 7
entitled actions of the night shift on October 11, i.
8 12, 1988, the last bullet, f.
9 MR. McCOY:
- Okay, t
3 10 MR. HAYES:
Based on their training and l.
11 guidance time, these operators did not know, and 12 should not have known, that the tech spec was 13 applicable.
14 How do you reconcile Jeff's statement 15 that he recognized that a I think we may have a 16 problem here?
Is Jeff the exceptional SRO that you 17 had there or --
~18 MR. McCOY:
Let me give you a little 19 history on this event, on this issue of loops not 20 filled.
The traditional way that you went into an 21 outage and drained down the loops was to just drain 22 from the system and not worry about the steam 23 generators.
24 One of the things that happened when you 25
'did that is the steam generators burped, there was a
l 4
45 i
t i;
I word we used to-use, and that was like when you turn
-2 a' Coke bottle upside down and it's full of water, it 3
splashes, burps and the water comes out.
a 4
Along the time that Vogtle was t
5 approaching its first refueling outage, a practice 6
that had been developed, I believe at Pointe Beach
?
is my recollection, of injecting nitrogen in through l
i 8
a vent into the loop that would prevent this 9
occurrence had been developed.
10 I don't think prior to that time that'a i
j 11 lot of thought had been given to that particular 12 issue.
This is from what I can get from reading and j
j
_13 my own recollection of things at the time, and in 4
j 14 particular, as Skip pointed out this morning, this 15 particular event was related to boron dilution which l
16-is talking about volumes of water, not flow through a
17 the loops.
And if your mindset is thinking about i
l
_18 volumes of water, the volume of water involved i
19 inside the tubes in comparison to the rest of the 1
20 water that's in a loops filled and reactor filled 21 condition is relatively small.
22 So what I meant which by that or the i
23 conclusion that I would draw from that is that there i
24 wasn't anything that would step out and catch 25 somebody's attention, that injecting nitrogen to r
).
i
i 46 i
i prevent.this problem would result in, quote, loops 2
not filled, particularly since l' oops not filled had 3
never been defined anywhere that we're able to 4
I think if an operator, if any of our
-5 operators had really been stopped and asked the 6
question and asked some leading questions like would 7.
this affect flow through the loop if the steam 8
generator tubes weren't filled, and does the loops 9
not filled condition have to do with the decay 10 removal, they would all have come to that 11 conclusion, but we did not put that in our training 12 program, nor did we put anything in our procedures 13' to alert it to them, and I think that it was easy to 14 fall into, and the facts really substantiate it as 15 best we can determine a lot of people felt that that 16 meant topping the loops, the loops not filled.
And 17 if you don't think a-lot about it, I think you can 18 reach that conclusion.
That's all I meant.
19 MR. SNIEZEK:
Pat, I want to clarify 20 something in my mind.
When I heard you talk about 21 that bullet, when you say these operators did not 22 know, should not have known, I interpret in my own 23 mind, saying, these operators did not know, and it 24 is not surprising that they did not know.
25 MR. McCOY:
That's exactly right.
.. ~. ~.
...~.
y l
1 47 1
MR. SNIEZEK:
They should have known but 2.
it's not~ surprising that they did not know..
]
3 MR. McCOY:
They should have known, but I 1
1 j
4
-accept responsibility for them not knowing.
That's x
5 what-I.am saying, i
}~
6 MR. HAYES:
All right.
I have one other j
7 question, Mr. McCoy.
You mentioned about five 3
l 8
minutes ago that you had a review with Mr.,
I I
9
~believe, Stringfellow J
j 10 MR. McCOY:
Yes.
1 11 MR. HAYES:
pertaining to the letter 12 or your interpretation, when did that occur.
4 4
13 MR.1 KITCHENS:
Prior to me signing the 1
14 letter when it was brought to me for signature.
}
15' MR, HAYES:
I see..
So Mr.- Stringfellow 16 then you met with'him?
i 17 MR. McCOY:
That's my recollection.
18 That's typically what I do when one of my staff 19 prepares a position or something like that, I-call i
4 20 them in and question them and be sure that I
]
21 understand the implications of what they've said.
l 22 My recollection is that I did call Jack in and 23 discuss that with him before I signed-the letter.
24 MR. HAYES:
All right.
Was there any 25 discussion with anyone on your staff in the licensee L
i
i 48 3
1 staff concerning this issue prior to the letter 2
hitting your desk and your phone call'to Jack?
~
3 MR. McCOY:
I'm sure there was, but I 4
'have no knowledge, personal knowledge of it.
5 MR. HAYES:
What I'm trying to get to, 6
did you have'any initial briefing by someone on this 4
6 7
particular-concern?
8 MR. McCOY:
I don't recollect that, but 9
-let me say that I talk about so many things on a j
)
10 daily basis that are going on at the plant, and this 4
11-is three years ago, if somebody had mentioned to me l
12 somewhere in that process that, hey, we have a 1
13 concern about this or whatever, I probably would not t
14 recollect that.
15 MR. DOMBY:
Do you understand the time 16 frame, Mr. Hayes?
17 MR. HAYES:
My understanding of his i
18 response was the time he signed the initial 19 corporate letter at Plant Vogtle.
20 MR. DOMBY:
In October of 1989, right.
I 21 MR. MAYES:
Uh-huh, that's the one that 22 I'm referring to, not the subsequent memorandum that 23 you signed.
t 4
i 24 MR. McCOY:
I don't have any recollection e
25 of prior discussions about that, but as I say,
- f. t 1
4
O 49 1
wouldn't surprise me at all at some point that 2
somebody didn't mention that to me.
3 MR. SNIEZEK:
Does anybody at the table 4
have any further questions on the presentation?
5 MR. PARTLOW:
No.
6 MR. SNIEZEK:
We don't have any further 7
questions on the presentation, so I would like to 8
start out with questions that your submittal, your A
9 response to us, as well as 10 MR. McCOY:
Gentlemen, something was 11 pointed out to me, just so that I'm absolutely 12 correct on the record'here, there were some actions l
13 going on which prompted this, and that was that in i
14 September, we were processing a tec,h spec change on 15 this same subject.so, you know, I would expect that 16 that would have been discussed at that same time.
17 Now, I don't remember the exact sequence 18 of those things, but getting back to your discussion 19 did I have other discussions?
All licensed I
20 correspondence that goes out regarding Vogtle, I 21 personally get involved with apd if I don't, it goes 22 up in our organization.
i d
23 At that time, I was there, and so if that 24 came to me, if the tech spec change request came 25
'before the interpretation, you know, I'm sure I
p.
50 2
1 would have discussed'something about it at that 2
time'.
l 3
MR. SNIEZEK:
That's September '897 i
.4 MR. McCOY:
Yeah, but I don't have any t
j' 5
clear recollection of it so I'm sorry, for 6
interrupting you.
Go ahead.
).
7 MR. SNIEZEK:
I would like to start in on l
8 questions that were raised in our minds and we 9
wanted clarification on based on our review of your i
i 10 very' detailed response to our June 3rd request for 11 information, and likewise some of the issues raised I
}-
12 by the response of Mr. Kitchens, Mr. Cash and Mr.
13 Boles raised some questions also, so let me start.
14 On Page 8 of your response, you indicated 15 that Mr. Hopkins recognized the possibility that i
16 loops were in a not filled condition and Mr.. Gasser ii 17 was apparently the only other licensed individual to 18 do so.
19 On Page 15 of your response, you 20 indicated that a citation of February 1989 21 demonstrates that operators don't understand loops 22 not filled.
23 MR. McCOY:
Let me be sure that I'm 24 getting what you are talking about in context.
The 25 first reference you_made was Page 8.
-. ~-.. -...-
.- ~
l l
l r
51 l
1 MR. SNIEZEK:
Page 8.
I 2
MR. McCOY:
And that's the paragraph that i
3 since the chemical addition remained performed, is l
4 that where you are reading from?
l 5
MR. 'SNIEZEK:
No. I was just 6
MR. McCOY:
I thought you were quoting 7
from the 8
MR. SNIEZEK:
I will have to go back, no, 9
I was 10 MR. McCOY:
If you would look, well, I 11 will let you find it, but I think in'the second 12 paragraph, there's a discussion of Hopkins and 13 Gasser and how they came to be concerned.
My 14 un'derstanding is, as Jeff just discussed a few 15 minutes ago, that.he was the one that brought that 16 up first with the off going shift supervisor and 17 then with his direct supervisor, Mr. Hopkins.
l 18 MR. SNIEZEK:
This is in your footnote 19-seven on the bottom, where you state, in contrast to 20 Mr. Boles and Cash, Mr. Hopkins recognized the 21 possibility that.the RCS was in the loops not filled 22 condition, and Mr. Gasser, who is apparently the 23 only 21cenced individual to do so, concluded that 24 the.RCS was in a loops not filled condition, et P
25
. cetera.
That's what I am referring to there.
l-52 i
i 1
MR. McCOY:
All right.
Mr. Gasser, who 2
was apparently the only licensed individual to do l
3 so, concluded that the RCS was in a loops not filed 4
condition because primary water had been displayed l
5 in the steam generated tubes.
6 MR. SNIEZEK:
So that told me that Mr.
7 Gasser definitely recognized it and Mr. Hopkins 8
possibly recognized it.
9 MR. KITCHENS:
Mr. Gasser brought it to 10 the attention 11 MR. SNIEZEK:
I understand.
t 12 MR. McCOY:
Once he brought it to the 13 attention of Mr. Boles, it raised a question in his 14 mind and he went back and made a late entry in his 15 log.
16 MR. SNIEZEK:
I understand that, I am not 17 going down that line at all.
i i
18 MR. McCOY:
Okay.
Well, I will let you 19 go.
20 MR. SNIEZEK:
I am not going down that 21 line at all.
22 MR. McCOY:
All right.
Now, Page 15 you indicated l
24 that a citation of February '89 demonstrated our 25 operators. don't understand loops not filled.
t
J 53 f
1 MR. McCOY:
Where are you?
I 2.
MR. SNIEZEK:
I think that's footnote 3
14.
You had a lot of good information in the 4
footnotes.-
I 5
MR. McCOY:
Let me read this footnote.
6 MR. SNIEZEK:
Okay, go ahead.
3 7
MR. McCOY:
Then we will discuss it.
4 8
Significantly the Vogtle operators' general lack of 9
understanding of the loops not f'illed and the loops s
j 10 filled conditions was observed by the NRC in 1989 t
11 when it reviewed a Vogtle licensee event report 3
12 associated where the February '89 Vogtle Unit 2 13 violation of this tecir spec.
Have I read enough?
14 MR. SNIEZEK:
Right.
15 MR. McCOY:
See the inspections reports, 16 I won't read the number.
That. violation occurred 17 when the Unit 2 operators who believed that filling
)
18 the RCS above the loops, above the loops up to the i
19 reactor vessel plant constituted loops not or 20 loops filled, released a clearance from the RMWST 21 discharge valves, opened the valves and 5
22 left them open for four hours in the RCS loops not 23 filled condition.
24 MR. SNIEZEK:
Okay.
25 MR. McCOY:
Okay, now what's the
c i
i l-54 4
'l l
1 question?
i 2
MR. SNIEZEK:
I am going to get my -- I j
3 didn't understand, can you explain how this issue of i
4 confusion in eho operators' mind'about loops not 5
filled in October '88 would ever have arisen four l
l 6
months later and the utility has still not taken 7
action to clarify what it meant to the operators?
8 MR. McCOY:
Well, Jim, I have to do this 9
by inference of what I have read of the statements 10 of the people involved and I want you to understand 1
11 it's in that, you know, we're looking back two to 12 three years now of what people's thinking was.
I 13 I believe that the people that were i
l 14 involved at the time of this first event'were 15 thinking of this evolution in a restricted sense in 1
(
16 terms of this refueling evolution, and that the plan i.
17 was to get a tech spec change processed before the t
18.
next refueling evolution.
I 19 Clearly, in hindsight, the issue of loops 20
'not filled was a contribution that should have been j
21 picked up at that time and aggressive action taken 4
1 22 to remedy, but it wasn't.
It wasn't that action 23 wasn't taken until the second time that this issue, i
24 somewhat unrelated, but in the same issue about 1
i 25 loops not filled came up.
And at that time it was i
i.
i 1
l 55 i
{
F 1
clear and that's when corrective action was taken, i
4 i
2-Now, I don't try and defend that or 3
justify it.
That's just my understanding of how it 4
happened.
5 MR. SNIEZEK:
But there is really'no 6
rationale why the questions raised at least four 7
months later still haven't been resolved for 8
clarification of the operators?
9 MR. McCOY:
No, not in my mind.
10 MR. KITCHENS:
I would like to be able to 11 answer that a little bit.
I'm Skip Kitchens.
I l
12 During the first refueling outage of Unit i
13 1 in 1988 when this came up about the tech spec 14 interpretation, I wasn't really aware of a
'i 15 controversy about. people not ~ understanding what 16 loops not filled meant because when it was brought 17 to my attention, I agreed that the loops were not 18 filled at that time and that's the way we did our 19 interpretation.
So I didn't put any emphasis on 20 correcting a problem associated with operator 21 knowledge.
22 In the February 1989 event, I believe it
-23 was February 1989, on Unit 2,
I talked to the shift 24 supervisor involved.
That was a completely 1
25 different event.
That was one where we released a
- -. ~.... _... -..
56 s.
1 clearance and intended to leave the valves unlocked 2
and.not under clearance, not for the purpose of i
3 adding chemicals for a short time, but they left 1
4 them.open for several hours as I recall.
5 When I talked to the shift supervisors 6
involved, I found out that.at least one and maybe 7
others didn't understand that not having water in 8
the tubes constituted loops not filled', and that's
]-
9 when I put out a tech spec interpretation and had
.i 10 everyone read it and we changed some procedures.
1 1
11 MR. MCDONALD:
That's Exhibit 16.
3 12 MR. SNIEZEK:
I have a related question.
l 13 which I will get now.
The unit cool down to 4
1 i
14 shutdown procedure 12006-C, the limitation 2.2.7 1
2 15 references technical specification 3.4.1.4.2 while t
16 in mode 5 loops not filled.
I 17 MR. McCOY:
Is that section 2.2.7, is 18 that what you are saying?
19 MR. SNIEZEK:
2.2.7, that's correct, i
20 limitation.
I recognize that does not pertain to p
J j
21 the chemical addition, but again it is using the 22 terms " loops not filled."
The question I have, i
23 today, how confident are you that you don't have j
24 terms in your procedures that your operators don't 25 clearly understand what they mean?
What have you 4
i
l 1
57 4
l 1
done to assure that that condition doesn't exist?
t 2
MR. McCOY:
Let me say, first of all, 3
that I'm completely confident that they understand 4
.the loops filled and loops not filled.
5 MR. SNIEZEK:
I'm not worried about that 6
one.
7 MR. McCOY:
Okay, but the broader 8
question I understand you are.asking is what things 9
do we do to ensure that operators understand the 10 technical language and procedures and regulations, i
s 11 et cetera, that they have to live by.
Is that i
12 adequate rephrasing?
13 MR. SNIEZEK:
That's right.
14 MR. McCOY:
The thing that I think I 15
-relied the most on is the thorough training of our i
16 operators and their ability to recognize if there is I
17 any question or concern about what something means i
i 18 and to ask for interpretation when that happens.
l 19 I don't think that I mean we do our 20 best and we've got all kind of guidelines on how you j
21 prepare procedures and things.like that, and we have 22 all kind of guidelines on training, job task 23 analysis and analyzing what people need to know, but 24 I' don't think that my real confidence that the t
25 people understand _comes from that as much as it does i
1 I
s,,,-.-e
+
- - ~.
i E
58 1
my confidence now that the people at the plant feel 3
'l 2
- a. strong responsibility for this and will ask 3
questions and feel free to ask questions wherever
'4 there's a concern.
5 MR. SNIEZEK:
On Page 8 of_your response, j
6 you indicated that I will paraphrase as I ask 7
this, indicated that pursuant-to the schedule the 8
reactor coolant system could not be opened.until 9
chemical cleaning was complete.
Yet on Page 21, you I
10-indicated that Mr. Kitchens' decision to proceed 11 lengthened the schedule.
12 We talked about this a little bit up to 13 this point, but who had the authority to eliminate 14 chemical cleaning from the schedule?
15 MR. McCOY:
The operations manager really 16 controls the day-to-day direction of the activities i
17 in the plant.
On this particular outage schedule, 18 both the general manager at the plant and myself had i
19 reviewed and concurred in what activities we were 20 planning to do, and I can remember specifically 21 spending most of the day in the plant manager's 22 office going through activities and what they meant 23 and why we were doing them in this series and that 24 sort of thing.
But that does not mean that when you 25 get into the outage and something comes up or
59 1
something'has to be changed that they have to call 2
me to get my approval to' change it or whatever.
3 Now, I had told the plant manager before 4
we started that I wanted to review and approve the 5
outage schedule, the activities in that.
But once 6
you get into it, as you know, you discover things, f
7 you run into problems, there's equipment that you
{
8 open up that'needs work, and the operations manager l'
9 clearly has the authority to modify that schedule, l
10 and he's in the best position to do that hour by 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />.
[
12 I would fully expect him to discuss with 1
13 the general manager significant changes and why they l
14 were being made but clearly he has the authority to j
j 15 change that schedule.
i L
16 MR. SNIEZEK:
I understand.
Let me ask i
17 you a hypothetical and_usually I don't-like to ask i.
I 18 hypothetical questions, but I will break my own
)
l:
19 rule:
Let me assume that a decision was made not to
- 20 do the chemical cleaning.
Would Mr. Kitchens 1
21 himself have the authority to make that decision or j
22 would'someone in the organization have to concur j.
23 with that?
In my mind it's a fairly significant 24 step.
25 MR. McCOY:
Let me say I think Skip made
_: :o e
b i
60 I
i the point this morning, and I completely concur with 2
him, this particular evolution was not of great i
c
[
3 importance in this particular refueling.
We had 4
some of the lowest radiation levels of any plant in
- j' 5
the industry at that time in our plant.
And the i
j 6
exposure at that time was, as I recall, if not the 7
lowest PWR in the industry, one of the lowest.
8 There was a lot of doubt in our mind.as i
9 to whether this was a worthwhile evolution, however, 10~
my recollection is that the chemistry manager felt 4
11 that this is something we ought to do, we'ought to l
12 see what.happens in our plant, and that it's
}
13 something that we need to get in the habit of doing l.
14 as the plant matures and radiation levels go up.
i 15 It's the first time kind of thing, this-l 16 evolution had not been going on for a long period of l..
time in the industry.
It had been developing.
And 17 l
18 I would not have felt uncomfortable at-all if Skip I
j-19 had made the decision, based on he had run into a f[
20 problem of this, to not do the chemical addition and u
21 proceed on.
i I
22 MR. SNIEZEK:
Was the cost benefit
{
{
23 know you submitted a cost benefit analysis for the i
i 24
-chemical cleaning, was there a cost benefit analysis i
i 25 prepared before this decision was made?
d I -
g f-61 1
MR. McCOY:
Not to my knowledge, and if 2
it had been, Jim, it would have been a wild stab 3
because I don't think anybody had a good idea of how 4
much radiation exposure we would save by doing that 5
in this particular situation.
6 MR. SNIEZEK:
I think one of the issues 7
that is brought here, I'm ad-libbing a little bit, I 1
8 think anything you can do within reason to reduce i
9 exposure to people is a very prudent thing to do.
i 10 MR. McCOY:
I'll ad-lib a little.
j i
11 MR. SNIEZEK:
I'm not sure that I would i
12 agree that a decision not to chemical clean that 13 that wouldn't have been weighed pretty heavily 14 including senior management involvement in that 15 decision.
16 MR. McCOY:
I will-ad-lib a little' bit 17 back to you and tell you that right now, Vogtle Unit 18 1
19 (Discussion ensued off the record.)
20 MR. McCOY:
Let me say that I think you 21 might find this of interest as an aside.
We're in i 22 refueling outage, just entered a refueling outage at 23 Vogtle this week, and presently we are about a day 24 and a half or two days behind, and the reason is 25 that we're doing clean-up of the RCS system, and w-
.~ _..___.-_ _._. _ _.. _ _
62 a
5 1
tried a new technique-that has been' developed which 2
is a_ double ~ shock of the system now, and it resulted i
j 3
in a much larger release of activity, and we made 4'
_the decision to continue clean-up and keeping RCS-i F
5 pumps running even though that's a critical path, 6
and right now we've used up about two days of l
7 critical path time in order to reduce radiation i
8 exposure.
l 9
I say that just for the point that we
(
10 take radiation exposure very serious.
That's-one of j,
11 our overall plant goals and we keep that in balance i
12 with all of our other activities.
[
o l
13 MR. SNIEZEK:
I understand.
And that, l
3
}
14 before I started was a hypothetical question, and it 15 is one that, as I say, I was ad-libbing, I do think 16 that would involve' senior management careful 17 overview if a decision was made not to do it, even 18 though you indicated that Mr. Kitchens did have that 19 authority.
20 MR. McCOY:
You do understand the 21 difference in the physical things that were going on 22 at that time?
23 MR. SNIEZEK:
I am trying to understand 24 that, that's correct.
25 There was some discussion of this issue i
4 63 i
t 1
this morning, and I think you did-address it 2
somewhat-in your response.
I just want to make sure l
3 that we have a clear understanding.
t' 4
On Page 17 and again on Page-35 of your 5
response, it was indicated that chemical cleaning 6
procedure was only prepared, approved and reviewed i
7 by the HB chem department, and it did not address i
4-8 reactor coolant water level.
9 Can you explain why it wasn't approved by
{
10 operations, the PRB, and approved by the plant 11 manager?
s i
12 MR. McCOY:
The procedure I have a
t 13 looked at these procedures in-preparing our
{
14 submittal.
I looked through them and I tried to i
5 15' read them in detail, but I looked through them and p
j-16 the gist I got of this procedure was this was an i
17 overall' guidance procedure on the chemical l
18 strategies to be followed during the outage, and 19 that is really within the domain of the chemistry
[
20 manager at the plant to develop that.
21-As I think has already been pointed out, j
22 there are other procedures that specifically govern 23 the. operations of the valves and chemical addition,
,i i
24 and clearly'in retrospect this particular 2
25 coordination of activities was not properly reviewed
,-c e-
)
64 1
by operations, but I think that the place that would j
j 2
have come up properly.is.in the review of the outage f
3 activities.and their sequence and schedule, not in 4
the chemical strategy for the outage.
I 5
MR. SNIEZEK:
I'm not questioning the 6
chemical strategy, but this was the chemical 7
cleaning procedure?
8 MR. McCOY:
Right.
9 MR. SNIEZEK:
And did you actually have a 10 have a procedure by which you did this evolution in 11 October 1988?
12 MR. McCOY:
There is an operations 13 procedure that specifically addressed and I would 14 like to get one of the people that',s more familiar 15-with that to quote it for you, if you would like 16 you,-but I know that there's an operations system 17 procedure that is a procedure that if someone tells 18 you to make chemical addition, if you are an 19 operator, you go to that procedure, and that's what 20 you follow, not the chemistry procedure.
The 21 chemistry procedure is just one that would be used i
22 to say, in this outage we are going to do a chemical 23 addition at this point.
24 MR. SNIEZEK:
It's my understanding that 25 it was done as a functional test.
A functional tes*
- -... - _ ~...... - -. -.. -.
c-e i
65
.1 form was used to-reach the value clearance, and in 2
my impression that bypasses the required review 3
process for procedures.
4 MR. McCOY:
What you are referring to is 5
the procedure that was in effect at the time in 1968 6
that allowed valves that are under a tagged 7
condition to be operated for functional testing.
8 MR. SNIEZEK:
Right.
9 MR. McCOY:
And the procedure allowed 10 that.
You can debate whether or not that was good 11 Practice.
We've since changed that procedure, but-i 12 that was in my mind the proper way to operate those 13 valves at that time, for the operators to follow the 14 procedure to use a functional test since the valves 15 did-have a clearance on them.
That's the reason 16 that they did it.
17 MR. SNIEZEK:
You really weren't doing a 18 functional test, you were injecting chemicals?
19 MR. McCOY:
No, but the procedure though 20 specifically allowed you to do that for other 21 activities other than functional test.
It was 22 called a functional test form, but if you look into 23 the procedure somebody pull that.
24 MR..AJLUNI:
We have it here, it is 25 Exhibit 6.
._.m._.
_, _ _. _... _ _. ~.. _. _ _.
- _ - _. _ _ ~ _
Q 4
1 3
66 l-1 MR. McCOY:
If you like, I can get Mark l
2 to read it.
1' 3
MR. AJLUNI:
I can explain it.
Mark 4
Aj1 uni.
5 Essentially it was a means of providing
]
6 administering controls.on components and, you know, 7
we used the terminology functional tests, but it was I
8 an operations tool for establishing administrative 9
controls on it.
10 MR. McCOY:
You know the point is here, I 11 think I want to be sure that we're really clear on 12 this, our review of this shows that the operations 13 people clearly followed approved and allowed 14
-administrative procedures doing this evolution.
We 15 looked at that specifically.
16 MR. AJLUNI:
One other thing, that 17 procedure for administrative controls is a class i
18 review board procedure and is reviewed and signed by '
19 higher levels of control, administrative control.
- 20L That's Exhibit 7 in your book.
21 MR. SNIEZEK:
Did you have a procedure 22 for chemical injection in 1988?
23 MR. McCOY:
Yes.
24 MR. SNIEZEK, Why wasn't that procedure 25 used?
67 1
1 MR. McCOY:
It was.
.That's exactly what 2
I am saying.
I-guess I am not communicating.
Let 3
me'try-again.
If'you are an operator and you are 4
told to make a chemical addition, you would refer to 5
the operations department system.
6 MR. AJLUNI:
The procedure is 13,007, it 7
is Exhibit 7 in the handout and it's VTS control and
~8
.it's operations department, I 9
MR. McCOY:
That's the procedure that was 10 followed.
11 MR. AJLUNI:
This is the procedure that 12 was followed.
13 MR. SNIEZEK:
Does that procedure address 14 loops not filled condition.
15 MR. McCOY:
No, sir, it did not.
It did 16 not address it one way or the other is my 17 understanding.
18 MR. SNIEZEK:
So let me put it in my 19 words to make sure I understand it.
The functional 20 test process was used as administrative process 21 whenever you were going to go on release clearance; 22 is that correct, the process?
23 MR. AJLUNI:
If you felt you were going 24 to release it for some short period or some duration 25 but you had a reason to reinstate the administrative !
C' 4
1 68 1
control, you would use a functional test.
If you
~2 felt you were going to release it, you would just 3
simply release the clearance.
4 MR. SNIEZEK:
But the actual injection 5
was done using a plant review board review procedure 6
for chemical?
7 MR. KITCHENS:
No, sir.
The actual 8
injection was done using an operations department 9
approved procedure which is RCS chemical injection, 10 and this is the procedure that manipulated the 11 tech spec required the valves that were listed.
l 12 MR. SNIEZEK:
That PRB or plant manager l
13 approval.
14 MR. AJLUNI:
This particular one did not, 15 the one that I etated before did.
16 MR. McCOY:
The operations department 17 procedure is my understanding is that those require 18 operations department managers approval and if they 19 affected activities, this is at that time, that he 20 gets those reviews that are applicable for any 21 interfaces.
22 MR. AJLUNI:
Perhaps just as a general 23 clarification so you will understand, we had a 24 chemistry general procedure for overall controlled 25 actions of the chemistry department.
That doesn't i
a 69
.1 really list specific details of how to open valves 2
or do things.
3.
-MR.
SNIEZEK:-
That was only for the i
4 chemistry department.
5 MR. AJLUNI:
That procedure followed out 6
another chemistry procedure that actually gave the 7
chemistry technicians instructions on how to put the 8
peroxide in, and then those procedures referenced 9
the operations procedure which actually manipulated
]
10 the final valves that opened and injected the 11 chemicals into the reactor.
So it's a chamber of 12 you know, it's several interdepartmental procedures.
13 MR. EBNETER:
Functional tests in the 14 area could best be performed after you performed 15 maintenance on the component, not to do it, that's 16 where the confusion is coming in.
You are using it 17 for something it wasn't intended to be used for.
18 MR. McCCI:
Well, there was a provision, 19 I believe, in that procedure to allow you to use it 20 for other things.
Mark, can you read the words that 21 existed?
22 MR. AJLUNI:
Well, the words that existed 23 at the time 24 MR. McCOY:
I asked that same question is 25 the reason that I think I remembered that.
l-4 70 1
MR. SNIEZEK:
Let me discuss a few things 2
while he's11ooking that up and we will come back to 3-that.
4 MR. McCOY:
Okay.
5 MR. SNIEZEK:
One of the concerns that 6
were raised inimy mind is that it appeared.tci me you 7
had quite a few procedures that were called 8
departmental procedures and, therefore, they didn't 9
-require review.by the parties, PRB or by the plant 10 manager.-
I got the' impression'by reading the i
11 response that that contributed to confusion in this 12 overall situation.
13 The concern I have is what is the status 14 today and who does an integrated re, view of 15 integrated safety of operations today.
I can't 16 change what happened in 1988, and neither can you, 17 that's history.
But I'm wondering if it's better 18 today or worse today or how do you know that you 19 don't have similar condition out there waiting to
-20 bite you the next time you do an evolution that's 21 unique.
That's the thrust of my question.
22 MR. McCOY:
Jim, let me first start by 23 saying that my understanding, because this process 24 that was used to review the procedures that were 25 developed at Vogtle was different from the process'
\\
c.
4 a
71 1
that I had used previously somewhat, so I questioned 2
why that was the case.
My understanding was that l
3 this was an evolving licensing issue that today the 4
requirements.on interdepartment reviews and PRB 5
reviews are different than they were in earlier l-6 licenses.
7 Now, that's just by way of background to 4
8 this particular issue.
Part of the reason for that f
9 is the large volume of procedures that has evolved i
10 in the later plants as compared to earlier plants 11 and the practicality, if you will, of having PRB 12 review every procedure which used to be the 13 practice.
14 MR. AJLUNI:
I can -- let me elaborate.
15 MR. McCOY:
Okay.
I would like to ask 16 some of our people that are more familiar with the 17 review process what things we've done to strengthen 18 that to address that particular issue.
Is that what i 19 you were going to respond?
20 MR. AJLUNI:
No.
I was going to discuss 21 the issues of clearances.
22 MR. McCOY:
Let's hold that.
Skip, wouli 23 you want to comment on this?
24 MR. KITCHENS:
On the interdepartmenta'.
25 reviews, I believe-that last year, 1990, around
____ -~
~ _. -
- o i
72 1
August as a. result of an inspection,.we looked at 2
our procedures very closely, our approval process t
3 and everything, and determined that we did need to
-4 strengthen the interdepartmental reviews some of cur 5
procedures that didn't at that time get 6
interdepartmental reviews.
7 We have some better guidance out to our 8
people.
There are people who are writing review 9
procedures as to which procedures to get other 10 departments' advice and comments and concurrence on 11 before doing that.
But there are in accordance i
12 with our administrative procedures and our tech 13 specs there is a tier of procedures whereby some 14 procedures go to the plant manager for approval, 15 some go to the plant manager and the plant review 16 board, some can get department head review.
17 Our intention in our new and approved 18 program to try and get better interdepartmental 19 reviews was to strengthen these that only go to the 20 departmental manager for approval to get reviews by 21 other departments or other disciplines first, and we 22 have been.doing that for several months now.
23 MR. McCOY:
This might be a good time to 24 address the fact that your general comment that one 25 of the things that bothered me a little bit when I
73 r
1 first got involved in the Mobile Plant, took 2
responsibility for it, was the level of reviews of 3
the PRB, members PRB, and although our tech specs 4
allow lower level members of the staff to be 5
represented and to actually make the decisions on i
6 the PRB we have since elevated back up to the 7
department manager level'and the assistant general j
8 managers, and the reasoning is that we feel that'now 9
we're out of the start'-up phase and all the huge 10 bulk of test procedures and that sort of thing, that 11 it is something that is practical, and we get the 12 perspective and experience of more senior managers i
13 into the review process of the PRB.
4 l
14 So that's another example where we 15 strengthened the review of the procedures and 16 events, et cetera.
17 MR. SNIEZEK:
Is there anything more you 18 wanted to add regarding that specific procedure?
19 MR. McCOY:
If you want to go back.
20 MR. AJLUNI:
If you wanted just a 21 clarification on the functional test, at the time, 22 and I will read you the definitinr, it says, a test 23 of the component or subsystem to verify the 4
24 satisfactory operation of the component after a 4
25 component or subsystem has been placed in a 1
d
74 1
configuration that assures plant equipment and 2
personnel safety.
3 MR. McCOY:
There's another reference 4
somewhere to my recollection that basically says 5
that you can't use the functional test and procedure i
6 for other purposes but 7
MR. AJLUNI:
Well, essentially the 8
functional test was a means of releasing components 9
that were under clearance, but you would have 10 administrative control in doing so.
And if you 11 actually look at the actual clearance sheet itself, 12 you know that this clearance was not issued for i
4 13 maintenance purposes.
It's in the name of the shift 14 supervisor, as are all clearances, but.it clearly 15 states there was to be no maintenance activities and 16 the purpose, of course, was to initiate ULP 12,006 17 requirements.
i 18 MR. SNIEZEK:
I understand that.
Let me 19 tell you what my focus is.
It's very clear in my 20 mind that occasionally where you have to do 4
21 maintenance or surveillance or whatever, you may 22 have to tag out the systems or portions of systems.
23 Obviously, to know whether they are operational 24 again afterwards, you've got to reniove the tags 25 before you~can test them.
And that definition 3
~.. _.. _. _ _
i
[
75 1
1
.that's what that procedure is for.
1 2
In this case, you had a chem addition pot
)
3 essentially tagged-out, there was no maintenance, 4
you were going to do an operational evolution, and i
d 5
that does not sound on-the surface, at least, that's
(
l 6
what that was designed for.
That's why I raised the 7
question of whether it was a means of bypassing a
}
8 rigorous' review and approval process and, therefore, i
9 that's the thrust of the concern..
1 s
10 MR. AJLUNI:
I would say that that's not 11 really the case.
You shouldn't really get hung up 12 in the word " functional test."
This procedure could i
13 have said, you know, administrative release, you 14 know, and the words would.have been essentially the 15 same.
16 1dR. SNIEZEK:
I understand that.
17 MR. AJLUNI:
This process is the same.
18 MR. McCOY:
Let me ask Jeff to address 19 that.
Jeff was a shift superintendent for this 20 period.
Jeff, what's your recollection of what was 21 allowed.under functional tests with regard to 22 clearances?
23 MR. GASSER:
Basically, like Mark said, 24 the words " functional tests" are words that you 25 don't want to get hung up on because functional test
i i
76 t
i j-1 was_ simply the administrative method by which we i
)
2 removed clearance tags from specific hold points
{
.3 that were covered on a clearance.
And that provided-l 4
that form functional test form provided the i
L 5
method for getting approval from the subclearance i-6 holders for us to remove thor,a tags and manipulate i
7 those valves as necessary as directed by whatever J
8 procedure, whether it was a test procedure.or an 9
operational procedure, that was the form that was 10 used to allow manipulation of those valves under i
11 conditions when you knew you were going to rehang 12 the clearance for further work for further 13 administrative procedures.
14 MR. AJLUNI:
One other t,hing just to give 15 you a little bit of the history, I was i
16 superintendent of operations at the plant, 1n the 17 past a shift supervisor, and during the construction 18 phase this procedure does not have this in here.
We i
19 ran into a real problem during the construction 20 phase, with CAT or construction acceptance testing, 21 things like breakers and, you know, where you really 22 have the systems connected up but you know, and 23 somebody generated the word " functional tests" and 24
.the procedure was changed to 3-?'.e that in there.
25 It was the terminology that kind of gr -
?
77
\\
1 out of the construction phase into the operations 2
phase.
And.you know, maybe the word " functional 3
test" isn't quite the right word to use because it 4
might imply something different, but the way that it 5
was actually thought of was an extra administrative 6
control.
1 7
MR. SNIEZEK:
I understand that clearly i
8 and Mr. McCoy indicated that he thought there was 4
9 another situation where it allowed it to be used for 10 other things also, but I'm just saying the I
11 definition that you just read, I understand the 4
12 difference in actual practice versus the specific i
13 wording. hat was in there, but that's what triggered 14 the question in our mind.
15 MR. LIEBERMAN:
Jim, could I seek one 16 clarification about procedures?
Did you say that 17 the actual chemical addition was being followed 18 under 13,007-1 which I think was group 12.
19 MR. AJLUNI:
The actual opening of the 20 valves?
21 MR. LIEBERMAN:
I noticed in step 4.7, it i
22 refers to having at least one reactor cooling pump J
23 in operation while chemicals were being added.
It i
24 wasn't clear to me how that step could have been i
25 followed in the mode you were in.
1 i
78 1
MR. AJLUNI:
This procedure that was 2
written is the normal RCS chemical addition 3
procedure.
It's used really at -
.it's really used 4
at various power levels.
As specifically written, 5
it assumes that the loop, the,yalvesCthiti.we'rea" i
j 6
talk 4agrabouA.aresopen and in-their-normalg y 7
configurationg 8
That was the reason why the functional i
9 test was needed because the actual plant condition 10 was slightly off normal, being a fed loop and 11 MR. LIEBERMAN:
So you couldn't use this
{
12 procedure?
13 MR. AJLUNI:
Verbatim-~ compliance with 14 this preceddreawas not you waren'.t able to do it, i
15 because.theLapacific-plant was not in the-actual
>+
)
16 configuratiomrthepprocedure was. truly: written for, 17 but it was a very good guidance and had everything i
18 clearly the people on shift knew exactly what needed i
19 to be done.
20 MR. SNIEZEK:
Did you use a temporary 1
21 change process to your procedures in order to 22 execute that.
23 MR. AJLUNI:
No, sir.
24 MR. SNIEZEK:
I assume you have 25 alleviated procedures in the temporary change
t 4
79 1
process approved by the shifts?
I don't know 2
whether it's in your plant.
1 3
MR. AJLUNI:
That's correct.
4 MR. SNIEZEK:
You did not use that?
4 5
MR. AJLUNI:
No.
It wasn't the actual i.
6 chemical manipulation part, the evolution part was a 7
very sim'le evolution, s
j 8
MR. SNIEZEK:
But the initial conditions 9
are as important to anything else, do you agree with 10 that, and these were not your initial conditions f
11 that would satisfy that procedure?
[
12 MR. AJLUNI:
Not exactly.
)
13 MR. SNIEZEK:
In addition, the procedure 4
14 allows 10 minutes for chemical addition.
I i
15 understand in reality you limited it to five 1
i 16 minutes.
How was that five minutes limited?
What 17 was the administrative controls that limited it to s
l 18 five minutes, was it just word of mouth or something i
19 in writing?
j 20 MR. AJLUNI:
I think Jeff knows.
21 MR. GASSER:-
I don't have the procedure 22 in front of me, but the 10 minutes, I believe, was 23 added to the procedure in order to assure that the 1
24 chemicals were injected.
As Mark said, this 25
' procedure is written for the,most part providing 1
l-i
80 1
chemicals at power, where having a little bit more 2
water injected wasn't in issue.
3 When this came up for us to add the 4
chemicals in the condition we were in, because we 5
were concerned with the amount of water that was 6
added, it was determined that the chemicals could be 7
injected and the valves opened only five minutes, so 8
we felt that there was no need to add any more 9
unborated water than was absolutely necessary.
10 MR. AJLUNI:
One additional thing, the 11 pressure of the reactor coolant system was very 12 low.
The delta P for the injection was very 13 concentrated, was very high, whereas at power with 14 the reactor pressure without the delta P 15 MR. McCOY:
Jim, I detected something 16 else in your question maybe that we didn't hit 17 there.
I thought you were asking what 18 administrative controls were used to ensure that the 19 they only stayed open five minutes.
20 MR. LIEBERMAN:
That was the second part 21 of it.
22 MR. McCOY:
The administrative controls 23 that I understand were used were they had 24 communications with the people at the location where 25 they were operating the valves.
They were
1-81 t
1
. communicating directly with the control room, and l
2 the control room was timing and logging the
[
3 evolution to ensure they didn't stay open for I
a i
i l
4 greater than five minutes, and the logs reflect in t,
'5 every case when the valve was opened and when it was i
6 closed.
7 MR. LIEBERMAN:
Okay.
j 8
MR. HAYES:
Was.that for each evolution i-i 9
five minutes, Mr. McCoy?
i R10 MR. McCOY:
Yes,'less than five minutes.
1 i
11-MR. HAYES:
Five or less?
12 MR. McCOY:
Yes.
1 13 MR. SNIEZEK:
I will ask for any more I
1 *.
questions and-then we are going to take a short 15 break.
i 16 I am going to ask an unfair question.
17 Have you read tech spec 3.4.1.4.2 on the basis?
18 MR. McCOY:
Yes.
19 MR. SNIEZEK:
Based on that reading, I am 20 going to ask you to put yourself in the 1988 time 21 frame, in October.
That's why it's an unfair 22 question.
Do you believe that it only places 23 administrative controls on the valves and it is l
24 not --
25 MR. DOMBY:
Is that a present tense
~
1 l
82 i
1 question?
2 MR. SNIEZEK:
No.
That's putting it in i
3 the 1988 time frame knowing what was known.
That's 9
4 why I say it an unfair question.
But you come in 1
5 cold in 1988, you pick up these technical i
6 specifications and read them, forget we're going to 7
have this discussion, if you can.
Do you believe a 8
fair reading of these technical specifications and 9
the basis indicates that it only places 4
10 administrative controls on the opening and it does l
11 permit intentionally opening those valves?
J.
12 MR. McCOY:
I believe that based on what
,1 13 I knew in 1988 that there would have been a 14 significant doubt in my mind whether the word 15 "immediate" would be interpreted as an allowed 16 outage time, and that you would have to look at the 17 partice1ar bases for the tech spec in question and 18 what the intent of the word "immediate" was at that 19 time before making a decision.
20 I think that the guidance that was out 21 and all the discussions that I had heard in the 22 industry about what immediate meant and why it was i
23 used, that I would have had to look at it in that i
24 light and ask that question before I made the 25 decision, and I don't know which decision I would l'
1
83 J
1 have made.
2 MR. SNIEZEK:
That's why I asked.
I know i
3 whenever you read a tech spec you read the basis, i
4 that's why I said including reading the basis and 5
the tech specs.
How would you have interpreted that 1
6 after you had read the tech spec and the basis?
7 MR. McCOY:
Well, I would go one step 8
further.
I would look at the FSAR analysis and 9
looking at what was in the FSAR analysis, and i
10 knowing now well, it's hard to say what I would 11 have found at that time, because as I understand it, 12 in 1985, Westinghouse had done an analysis of this 13 event, and it was in the FSAR, and subsequently it 14 was removed and parts of it stayed there.
15 That's what I meant by the incomplete 16 revision.
But clearly if you do a quick back of the 17 envelope type calculation as Skip described this 18 morning, you can clearly reach a conclusion quickly 19 that there is no safety significance involved in 20 opening those valves for five minutes in this 21 condition.
Any operator who has gone through the 22 training program regarding reactivity and boron can 23 make that kind of a calculation.
l 24 So, Jim, it's I don't want to give you 25 a direct answer on that because I'm not sure of what
l i
84 4
'l I would have concluded at this time.
i 2.
MR. SNIEZEK:
Well, you are succeeding in i
1 j
3-not giving me a direct answer, but let me read you 4
what it says in the barsis again.
The locking closed l
l 5
of the required valves in mode 5, loops not filled, 6
precludes the possibility of uncontrolled boron 7
dilution of the reactor cooling system.
This action.
J 8
prevents flow to the RCS of unborated water by 9
closing flow paths from sources of unborated water.
l 10 These limitations are consistent with the initial i
1 11 conditions assumed, the boron dilution accident 12 safety analysis.
Very important words.
i 13 I know it's an unfair question.
14 MR. McCOY:
But there's.more words out L
j 15 there you've got to consider and I think you would i,
16 have to do that before yor acue a decision.
1 17 MR. SNIEZEK:
Let me ask you from a j
18 compliance standpoint, you answered from a safety 19 standpoint.
You gave me an answer from a safety 20 standpoint.
I want an answer from a compliance tech i
3 21 spec standpoint.
I 22 MR. McCOY:
I don't believe it's a clear l
23 issue at that time in my owu mind.
24 MR. Sniezek:
Okay.
I won't press you 25-any further.
Do you have a question?
85 1
MR. EBNETER:
Break time.
2 (A recess was taken.)
3 MR. EBNETER:
Before we.get started, the 4
court recorder has indicated he cannot hear me or 5
Mr. Sniezek and for the benefit of everybody, we 6
need to speak up, so the record gets complete.
7 All right.
We will restart now, and 8
continue with Jim Sniezek.
9 MR. SNIEZEK:
Have you read Mr. Boles' i
~
10 and Mr. Cash's response?
11-MR. McCOY:
Yes, I have.
12 MR. SNIEZEK:
In light of their 13 responses, and I want to highlight a few things that i
14 they indicated in their responses, specifically, on I
15 Mr. Boles' response, he indicated that the shift 4
16 briefing at turnover would have been the first 17 instance that he knew his responsibilities as shift 18 supervisors included overall responsibility for the 19 chemical cleaning evolution.
20 MR. McCOY:
Can I address these as you go 21 along?
I think that you misinterpreted that one I 22 listed this morning when you had that conversation 23 on that and I wanted to speak up at that time?
24 MR. SNIEZEK:
Okay.
25 MR. M c C O Y-:
What he is referring to here,
i 86 1
-and I checked between the two conferences here, what j
2 he was referring to was when he came~on' watch at the 3
beginning of his shift, this was the first time that 4
he' knew that he would have the specific-5 responsibility on his shift for adding chemicals.
6 I think the way you characterized that 7
this morning, or the way it came across to me, was 8
that you felt that that meant that he didn't realize 9
that he was responsible for this until the shift 10 briefing after his shift and that's not what he o
11 intended.
l 12 I don't think this is unusual, by the 13 way, on small evolutions like that, when a shift 14 supervisor comes in to relieve the shift may be the 15 first time he knows he's going to do~some particular 16 evolution.
Is that 17-MR. SNIEZEK:
That's fine.
Let me go i
18 back a little bit.
j 19 You also indicated that he did not attend 20 planning meetings since he was on shift consisting 21 of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> work days.
22 MR. McCOY:
Right.
23 MR. SNIEZEK:
I'm not sure what my view 24 of that is, and I'm not sure what planning meetings
,25 he was referring to.
I don't know if it was the
87 4
4 1
outage planning meetings.
2 MR. McCOY:
Why is that, where is that 3
statement?
I don't know what the_ context is.
i 4
MR. SNIEZEK:
First page of his response, i
5 the first paragraph.
6 MR. McCOY:
.The first page, the first 7
paragraph.
What he says is let me read you the I
8 statement and the whole statement.
I was aware that l
9 substantial planning had gone into the scheduling of 4
10 activities to be performed in the outage including i
11 interdisciplinary meetings to review the tasks to be 12 performed during the outage.
I did not attend these 13 meetings since for the most part I was on shift, 4
14 consisting of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> workday.
My understanding of 15 the task to be performed was derived principally 16 from my training and knowledge of the procedures.
17 So I think the way that I see that, Jim, 18 is that what he was trying to say is that he would 4
~
19 not have been expected to participate in these broad 4
20 kind of meetings that did the outage planning, that i
21 he was a shift employee working regular shift, and 4
22 that that was not something that he would normally 23 do.
And that is the case, our shift people don't 24 normally attend the big planning evolution type 25 meetings.
I 1
l i
A 4
88 4
1 MR. SNIEZEK:
Okay.
I'll accept that i
i 2
explanation.
3 Let me go to Page 4 of his response where j
4 he said, lack of awareness of tech spec
)
5 applicability was caused by my experience or lack of 6
guidance, and that I had an imprecise understanding l
7 of the term "midloop" and " loops'not filled."
I 8
also did not fully appreciate the actual condition j
4 l
9 of the reactor coolant system that the addition of i
l 10 nitrogen in the primary side of the steam generators j
i j
11 placed the unit in a loops not filled condition.
[
12 On Page 5 he went on to say --
13 MR. McCOY:
Mr.'Sniezek, did you read 4
{
14 that correctly?
I'm trying to find it and the 4
L 15 sentence starts l
16 MR. SNIEZEK:
That was paraphrased.
17 MR. McCOY:
Well, the sentence'has some i
i 18 other words in it.
I 19 MR. SNIEZEK:
Let me go back.
It's in 1
20 the second full paragraph on Page 4.
In hindsight 21 that lack of awareness was caused by..
22 MR. McCOY:
Yes, that's the part that you 23 left out.
i 24 MR. SNIEZEK:
And I had an imprecise 25 understanding of midloop?
a e
.i
89 1
MR. McCOY:
Right.
Inexperienced, lack 2
of guidance in that I had b
yeah.
3 MR. SNIEZEK:.
He was not aware or either 4
did not appreciate that, I don't think I took 5
anything out of context.
6 MR. DOMBY:
Mr. Sniezek, Mr. Boles and 7
Mr. Cash obviously.aren't here, but I do think it's, 8
if not inappropriate, it's certainly unfair to just 4
9 pick fragments of sentences out of context and 10 ascribe to these. statements something that, you i
11 know, may not have been attributed to them.
12-MR. SNIEZEK:
First off, I don't think 13 they are taken out of context, and I asked if their 14 whole response was read, and I am highlighting a 15 couple of specific things in here that raised real i
16 questions in my mind.
i 17-But on Page 5, I'm paraphrasing here 18 because it's quite a lengthy statement, but he i
19 indicated he either did not know that nitrogen had 20 been added to the steam generators during his shift, 21 or he did not recognize its significance.
He went 1-22 on to say that he did not understand the steam 23 generator draining evolution.
24 MR. McCOY:
Let me read this paragraph.
25 MR. SNIEZEK:
It is the first full 4
I
4 i
j t
90 t
l-i i
1
. paragraph-where he talks about a good portion of i
i l-2 that.
3 MR. SNIEZEK:
I'do not celieve that I am 4~
taking.anything out of context.
5
.MR.
McCOY:
Let me go back.
I want to 6
try to put this in. context.-
i i
7 When I read the submittal, Jim, at the 8
_ bottom of Page 4,
he starts out by basically stating j
9 that he doesn't recall how he did thic evolution, i
j 10 that he doesn't recall personally giving the 4
i 11 instructions or whatever.
2 12 So this whole discussion, he says, is I
j 13 based on my historic method of supervising m3 crew j-
- 14 and considering that another licensed operator was 1
15 tasked with the' actual addition of the chemicals.
I i
l 16 believe that my shift probably discussed the planned 17 addition of nitrogen peroxide once midloop evolution 4
d
~
18 was reached and that a functional test under d
' 19 specific clearance would be the method of addition.
20 I honestly doubt that I instructed the 21 specific valve and manipulation activities to be 22 performed by the other SRO.
23 MR. SNIEZEK:
You understand, I'm not 24 questioning.that aspect at all.
It's the next 1
25 paragraph.
. _. ~.
i 91 1
MR. McCOY:
All right.
Yeah, but what I 2
am saying is, he doesn't really remember, that's 4
3 what he is saying, any of the details.
4 MR. SNIEZEK:
That's fine.
5 MR. McCOY:
He went back and he looked at 6
the logs and he tried to speculate on what his 7
mindset might have been or his thinking, and that's 8
the context that this paragraph that your 9
paraphrasing is written under, not something that he 10 directly remembers.
4 11 Now, you know, how germane that is to the 4
12 point you are trying to make, I think we can find-13 out, but 14 MR. SNIEZEK:
My point is, and let me go 15 right to the heart of it.
16 MR. McCOY:
Okay.
17 MR. SNIEZEK:
I would note that the' shift 18 supervisor's log, which was him.
l 19 MR. McCOY:
Right, it was.
20 MR. SNIEZEK:
For my night shift did not 21 indicate that nitrogen had been aided to the steam 22 generators.
This detail I now know is logged in the 23 unit control log and by the reactor operator on i
4 24 shift.
25 MR. McCOY:
Right.
.. ~
2.
k 92 j
1-MR. SNIEZEK:
If I missed the initiation
[
2 implementation of this activity, it may be because
)
3 primary responsibility was assumed by the reactor 4
operator _as evidenced by the log entries.
5 The other possibility is that I simply
'6 did not recognize the significance of the nitrogen j
7 addition.
Indeed, after the event, I talked with f
8 the individual who initiated the procedure 13,005 9
which governs the addition of nitrogen to facilitate l
t-10 draining of the steam generators.
This provided me s
11 with an understanding of the mechanics of RCS 12 draining-beyond the knowledge I possessed in October 13 of 1988.
i 14 This indicates to me tha.t the shift 4
15 supervisor was not aware that a steam that 16 nitrogen was being added, that the primary' system j
17 was being drained, and that he did not understand i
18 the mechanics of draining the renctor coolant 19 system.
Now, that's what that tells me.
Does it 20 tell you something different?
j 21 MR. McCOY:
Jim, it raises a question,
{
22 but it doesn't tell me that and I think the reason 23 clearly is that he is speculating two years later as i
1 24 to what his mindset was at that time, i
25 Now, you_know, I certainly expect the 4
I i
i.
t T
93 t
4
]
1 unit shift supervisor to know.the activities that 2
are going on.in the' plant on his shift, and my l4 3
understanding-of this particular operator's
)
4 practices, and so forth, indicate that he does 5
operate that way, and I think he's stated that in f
6 his statement further on.
But while I can l
7 understand your concern in reading that paragraph, 1
i 8
and I'm not sure that it's clear that that is the i
9 case, and he did not know about them.
4 10 MR. SNIEZEK:
Okay.
Let me call to your 11 attention one of your exhibits, Exhibit 32, on l
12 conduct of operations.
-The functions on the on
{
13 shift ~ operations supervisor called here, I want to a
j.
14 highlight a few of them.
Maintain a broad 4
j 15 perspective of operational conditions affecting the j
16 safety of the plant as a matter of highest priority i
i 17 at all times.
]
j 18 MR. McCOY:
Right.
i 19 MR. SNIEZEK:
Does not become involved in l
i 20 any single operation that distracts him when j
}
21 multiple operations are required in the control i
{
22 room.
And it goes on to talk about emergency
]
23 conditions, also.
Ensures that shift activities are i
4 24 conducted in a manner that keeps personnel radiation,
4 25 exposures as low as reasonably achievable.
Tours
- i b
i i
~ -. -..-... -
i 94 i
1-plant areas on a routine basis noting conditions of i
2 the plant and equipment and monitoring rounds 3
performance.
\\
4 Under shift supervisor, authorizes 1
5 maintenance and/or testing activities to be 6
performed on the assigned unit and ensures plant i
7 conditions are suitable for performing such 4
)
8 activities.
Maintains status of equipment, and 9-determines operability of equipment upon return to 10 service.
Explains plans, procedures and safety
}
11 precautions to shift operating personnel prior to j
12 infrequent or unusual activities.
Tours' plant areas 13 on a routine basis noting conditions of the plant i
14 and equipment and'monitoringfrounds performance.
i 15 Based on what Mr. Cash and Mr. Boles.
i
[
16 wrote in their submittals, do you believe they t
i 17 fulfilled these, their functions?
i 18 MR. McCOY:
Yes, I do.
I'd like to 19 discuss this.
Can I take a moment and address this l
20 command and control issue that and I'll address j
21 this, I think, in that context if you will bear with f
22 me.
1' 23 MR. SNIEZEK:
Okay.
4
{
24 MR. McCOY:
First of all, at the Vogtle
. Plant, we have an extra SRO on shift above and 25 1
J G
3 4
95
.i 1
beyond the technical specifications.
In the
}
2 language that you've heard much discussion about 3
over the past 10 years or so,- we have a person that 4
functions as a shift manager, and he holds an SRO l
5
- license, e
j 6
At the time of this event, he was called 1
1 7
an on shift operations supervisor.
Today he's 8
called a shift superintendent.
That level as this 9
is defined in the procedure, and that's what this i
10 procedure is trying to say, is the senior plant 11 person on shift on back shifts and weekends, and so 12 forth, and he has overall responsibility for the
)
13 plant's operation including becoming the emergency i
14 director in the emergency conditions.
R 15 The shift supervisor, the unit shift i
16 supervisor is the person that typically is the 17 senior licensed person on most units, single units 18 and a lot of dual unit plants.
He is the person 19 that is intimately involved with and should be 20 following on a real time basis evolutions on his l
21 unit.
22 The unit shift superintendent, formerly 23 called the OSOS, his perspective should be on major 24 activities and problems that face the overall 25 plant.
The big picture.
And that's what that is i
j l
4 n2
--e-ea k
aA R-a--A-+*
w n
4-
,4 2
A 4
m-m A
e,,
M 96 1
trying to say.
2 Now, I'd like to focus on that shift 3
superintendent for a minute and his competence.
4 First this morning, the impression 5
MR. SNIEZEK:
Is that Mr. Cash you are 6
6 referring to now?
7 MR. McCOY:
That's Cash, that's correct, 8
he was the OSOS.
9 This morning I got the impression that 10 your feeling was that he was diverted from his 11 primary j ob by this diesel issue.
Let me read you 12 I went back at the break and read what he had 13 said.
He said, my recollectica is that my shift was 14 concerned with personnel accountability in the aux 15 building due to a potential exposure'to workers, and i
16 the health, physics and chemistry personnel were 2
17 contacted to monitor radiation levels and prepare 18 for the evolution.
4 19 My personal attention between midnight I
20 and shift turnover on my shift relative to the keep l
21 warm heater of the diesel generator is more 22 memorable than the hydrogen peroxide addition 4
23 because of during restoration of a clearance, the 24 heater was not refilled with water prior to being 25 re-energized and it was damaged as a result.
I
. = -. - - -. -. -. -.. -
o 1
s 97 4
i l
{
1 spent several. hours at the diesel generator in i
l 2
making plans to replace the damaged heater including i
3 locating a spare.
4 I also recall difficulties encountered in 5
pulling the pressurizer manway that required my l
6 involvement or requiring my involvement.
7 The details of the hydrogen peroxide 8
addition were peripheral to my primary attention, to 4
9 the diesel generator and the draining of the
\\
j 10 midloop.
1 I-11 What he is trying to say, as I read that,
]
12 is that he had main evolutions going on, many things 13 that were important that occurred on that shift.
14 The particular activity of adding chemicals was a 15-relatively minor scheduled activity that he was i
16 comfortable that the shift supervisor would j
17 supervise.
And I don't think that that is 18 indicative of a breakdown in my expectations of the
}
19 shift superintendent or OSOS.
i l
20 MR. SNIEZEK:
Who on shift was 21 responsible for the overall picture in making sure 22 all operations are coordinated then.
23 MR. McCOY:
For the entire plant, both 24 units, maintenance, HV, et cetera?
i l
25 MR. SNIEZEK:
Right.
i e
]i 98 1
MR. McCOY:
It is the unit superintendent A
2 now, formerly called the OSOS or the shift 3
superintendent.
I'm sorry.
4 l.
4 MR. SNIEZEK:
Would you expect Mr. Cash l
5 or Mr. Boles would you expect the shift 6
supervisor to be aware of the draining operation of f
7 the reactor cooling system?
8 MR. McCOY:
Yes.
And I would expect him l
9 to be aware of that on a real time basis as it was j
10 occurring.
11 MR. SNIEZEK:
I'm not convinced in my_own l
12 mind that there was anyone on shift at that time 2
13 that had the total picture of what was going on at j
14 Plant Vogtle based on the submittalp.
15 MR. McCOY:
Let me say that.I don't reach
\\
16 that conclusion to start with.
I think that there 1-i 17 are some things in the submittals that raise red i
j 18 flags and I think that's what you are reacting to.
19 MR. SNIEZEK:
That's my reaction, that's j
[
l2 0 correct.
21 MR. McCOY:
However, the activities that 22 the shift
]
that the OSOS was involved in from my 1
23 perspective, and I think now you understand what we 24 hold him responsible for, and that's what this 25 procedure tries to say, that you can see that he was i
-- ~.-
4-i i
99 I
4 1
involved in.what.he felt was the right thing, and I i
1 2
can't see any. basis to second judge-that.
H 3
Now, the unit shift supervisor, Mr. Boles j
4 in this case, he had another SRO, a shift support 5
supervisor, who he assigned to go do the actual 6
chemical addition evolution that's remotely l
7
' controlled from the control room.
In his mind, at B
the start of the shift, I don't think that he
^
]
9 thought that this was a significant operation.
He
)
j 10 thought it was a relatively routine chemical i
[
11-addition.
He had not made the connection of being 12 in loops not filled, and to him it was that's a very 13 minor evolution to put chemicals in a pot.
I 1
i 14 Now, I realize that on his shift they i
15 didn't actually add the chemicals, they just put 16 them in a pot.
So it doesn't surprise me that he 4
17 wasn't intimately involved in that, that he told the 4
18 support shift supervisor to go and follow the 4
19.
procedure and get the chemicals added to the 20 chemical addition pot.
i' 21 The issue on adding nitrogen to the loop 5
22 and observing what's going on with the draining down s
23 and the interaction between those two things, I feel 4
24 that he should have been personally involved in 25 that.
He does indicate that he was involved in the 1
3 1
100 1
draining evolution which the adding nitrogen is a 2
part of that evolution, but it appears from reading 3
his 4
MR. SNIEZEK:
Who is that you are talking 5
about now?
6 MR. KITCHENS:
Boles.
7 MR. SNIEZEK:
It's my impression he 8
wasn't aware that that was going on, based on his 9
statement.
10 MR. McCOY:
Let me try and 11 MR. SNIEZEK:
I don't want to have a 12 false impression.
13 MR. AJLUNI:
May I interject, if you go 14 and look at the shift log that was actually written 15 down in the shift supervisor's log and the reactor 16 operator's log, while you don't actually see the 17 words in Mr. Boles' log which is the shift 18 supervisor's log concerning the RCS draining, you 19 clearly see it in the reactor operator's log.
20 These individuals are in close proximity 21 to each other.
They are both in the control room.
l 22 It seems very hard to believe that Mr. Boles would 23 not know these things were going on, you know, that 24 the RO was doing these things and making log 25 entries.
This is a pretty big evolution from the
.1
101 1
standpoint of draining the reactor cooling system.
2 MR. SNIEZEK:
That's exactly why I am 3
raising the issue, it is a big 4
MR. AJLUNI:
He doesn't exactly remember 5
it in the submittal is contrary to what's in the log 6
is what I am trying to say.
7 MR. McCOY:
Let me make something clear 8
here.
The issue of command and control was not an 9
issue that we were attempting to address in this 10 submittal.
I think it was raised inadvertently by 11 some of the comments that were made in the 12 submittals by these individual operators.
13 I'm not sure that we fully addressed this 14 issue, and if this is a significant issue of the 15 Enforcement Conference, I think that we may need to 16 do some more research into this.
But I would like 17 to continue my statement at some point about this 18 command and control because obviously, Jim, that is 19 of extreme importance to me and I have to have a 20 high confidence level that the command and control 21 through the operations chain for the safety of the 22 plant is clearly understood and carried out by our 23 operators.
I do believe that.
24 I think that our procedures are very 25 clear on the responsibilities of the people.
I have l
l
3 i
102 i
i i
talked to the operators in our routine meetings 2
about'their responsibilities.
I have never sensed, 3
and I've attended a number of their re-qual j
4-sessions,_ et cetera, I'have never sensed any sense 5
of. difference between my expectations and what those 6
shift supervisors think my expectations are.
7 I-believe that this particular event 8
that's described here by Mr. Boles, that example of 9
.that nitrogen addition, is not representative of 10 normal involvement of shift supervisors at our 11 plant.
And if I felt that that was, I would be 12 extremely disturbed by this, but I don't think it 13 is.
I think it's really a part of his trying to 14 recreate why he didn't put a log entry,in his. log 15 about this evolution, not remembering anything about 16 it two years later.
But that's speculation on my 17 part.
18 MR. SNIEZEK:
I understand.
Well, let me 19 say this:
When I read the responses, I thought 20 my personal concern shifted from my original concern 22 to one of command and control during the time of 22 this evolution.
That's one of the reasons I 23 personally decided to come to this Enforcement 24 Conference.
It's the first Enforcement Conference q
25 I've been to in many, many years.
That's the
i I:
103 I
)
1 significance of it in my mind.
A'part of that was 2
precipitated by this potential command and control 3
concerns raised in my mind.
4 So if you think you can research that a i
5 little bit to assure yourselves there was good 6
command and control, because I -
by reading the i
7 responses,.I came away with three impressions.
8 The operations superintendent or 9
supervisor on shift, whatever the title was of Mr.
10 Cash, was primarily concerned with the diesel 11 generator issue and spent a lot of time there, 12 didn't have the total picture of the plant.-
13 I had a concern that the shift supervisor 14 was not even aware that draining of the reactor 15 coolant system was occurring and nitrogen was being 16 added.
17 My third concern was, I'm not don't 18 recall exactly where I looked, that the reactor 19 operator, where he knew that nitrogen was being 20 added in the system drained, wasn't aware that that 21 chemical addition was going on.
22 Those were the three things that really 23 triggered my concern on the whole command and 24 control and integrated operations.
25 MR. DOMBY:
Mr. Sniezek, in all fairness, I
-.~...n
_~. -. - - -
-.. - ~ ~. -
- i..
l 3
i 104 i
1 these individuals..were trying to recall their 2
understanding and knowledge of the events.
They i-l 3
were not asked how you delegated assignments, what l
4 you did.
What we.do know is that on the hydrogen 5
peroxide event, the addition, on this shift it was if
.6 specifically delegated to an SRO.
That is not i
7 improper delegation.
8 I t ink
--.I know I understand where.your 9
question is coming from and how you derived that, 10 but these individuals were obviously narrowly 11 addressing one issue.
12 MR. SNIEZEK:
You are obfuscating the 13 issue.
I didn't raise a question on hydrogen 14 peroxide addition.
I said the shif,t supervisor was 15 aware of that, but apparently the RO wasn't, and 16 there was no RO responded, I didn't ask for any 17 response from any ROs.
I don't recall why I came up 18 with that, being quite frank with you.
19 It raised a question in my mind, they did 20 a good job, they gave us a lot of material, when I 21 read the responses, it raised a question in my 22 mind.
Mr. McCoy said he was going to address that 23 question.
That's acceptable to me, but that's one 24 of the reasons I came to this Enforcement Conference 25 because I had a very serious command and control
4 105 L
i 4
1
. question raised, and I recognize you are not asked i
2 to address that, coming into this conference, nor 3
were the operators asked to address.that who we 4
wrote to, but when I got the response, it hit me 5
like a ton of bricks.
l 6
MR. McCOY:
What I can do in this l
7 interchange is only address to you generically how I 8
have confidence that we do have solid command and 9
control through our operations area, and I'll be 10 happy to expand on that and answer any questions 4
i 11 about that.
i 12 What I can't do here is go back to these
+
individuals and question them further about what 13 14 they actually were doing.
I can onA, speculate in 15 the same way you are 16 MR. SNIEZEK:
I understand, I understand.
17 MR. McCOY:
about these, so I think I 18 need to just stop on tr.at part and focus on the 19 other.
20 MR. HAYES:
Let me, Mr. McCoy, if I 21 could 22 MR. McCOY:
Okay, they were pointing out 23 that the RO log specifically has the nitrogen 24 addition logged, et cetera.
It was my understanding 25
.that your concern was that the shift supervisor
-...i l
4 106 I
i didn't-indicate'that he was involved in that.
i p
2 MR..SNIEZEK:
In fact, from'the shift 1
3 supervisor's response that.he'seemed to disavow 4
knowledge, there's no question the reactor operator 5
had it.
There's no question.
6 MR. DOMBY:
It' disavowed recollection of i
i 7
his involvement.
]
i 8
MR. SNIEZEK:
I understand, I understand, 9
but it's an issue that you said you were going to 4
10 take a look at.
1 i
11 MR. McCOY:
Yeah.
5 12 MR. HAYES:
The one thing that. struck me u
13 in listening to the discussion between you and Jim
[
14 was that you had indicated in the command and i
15 control area that there were certain procedures and 4
16 Jim has read some of those into the record, and you 17 have on many occasions stressed your expectations of 18 your staff's performance.
But I haven't heard how 19 you assure that the procedures are executed, and 20 it's more important. form me to see the execution as 4
1 21 opposed to it's written in the book and I tell them 22 every time.
23 What do you do to make sure your staff is 24 doing what you ask them to do in conformance with 25 the procedures that you've enunciated.
When you get
i 107 4
1 back to Jim,. I would like to see that exposed a 2
little bit.
3 MR. McCOY:
I'm glad you asked that, 4
4 because that really is a key point that I missed in 5
describing this.
6 MR. HAYES:
It's the guts.
7 MR. McCOY:
That's right.
And one of the 8
things that I do, and George Hairston and Pat 9
Mcdonald do, is that when we go to the plant, and we 10 go to the plant routinely
> I typically go about l
11 every other week and spend about two days at the 12
. plant as a typical thing.
When we go to the plant, 13 we typically go to the control room and spend time 14 observing the evolutions going on in the control 15 room.
16 One of the things that we look at, and I 17 can recollect several times that George and Pat and 18 I have had conversations about the command and i
19 control issue at Vc7tle, what do we need to do to-20 strengthen that, and so forth, directly.
21 The other thing is that we go to the 22 simulator and watch these same crews perform in mora 23 demanding circumstances.
You can pick up a lot of 24 things about how crews work together, what the rea.
,25 command and control features.are, and so forth, if
4 108 1
you watch these evolutions in the simulator that put 2
people under more pressure, and so forth, and I 3
routinely go there and watch the crews.
l 4
We have changed a number of things since 5
'88 in the way that these evolutions are handled and 6
the way our people perform.
I again, I was quite 7
proud during this recent inflow evaluation that our 3
8 crews performed in the simulator under observation 9
under emergency procedures with no comments, no 4
10 adverse comments.
I am quite proud of that, I-think 11 that is one of the essential elements of safety in a 4
12 plant is that the operating crews can handle adverse 13 evolutions well.
14 Pat thinks that I might ought to point 15 out, because everybody here is not as familiar as we 16 are with this hydrogen addition evolution, this is 17 not a big thing.
What it involves is hooking up a 18 gas bottle to a vent valve and opening the valve.
19 And it's not a big complex evolution.
The 3
20 importance of it is its effect on this loop filled 21 issue.
22 MR. AJLUNI:
Hydrogen, you meant 23 nitrogen?
24 MR. McCOY:
What did I say?
25 MR. AJLUNI:
You said hydrogen.
i I
_. ~... _. _. _.... _. -.. _.. _.... _ _ _. -.. _.. _.. _ _ _ _......
q..-
i 109 1
i j.
1 MR. McCOY:
I meant nitrogen addition.
i j.
2
.You understand the point, the point is that this is iC 3-not something the. evolution in'.itself is not a 4
big thing that you would expect the-shift supervisor 5
.to be personally directing or involved with.-
-6 The thing you would expect is for him to 7
be. aware of that and.its effect on the loops filled 8
condition.
9 MR. SNIEZEK:
No, that's not even my 10 concern.
11 MR. McCOY:
Okay.
12 MR. SNIEZEK:
My concern is his knowledge 13 and degree of knowledge at that time on October 14 12th, I think that's the right date, 1988 was that 15 shift supervisor aware that the reactor coolant 16 system was being drained, that there was being a i
17 change in volume in that reactor coolant system, an 18 intentional decrease in volume and evolution.
Based 19 on the submittal, I'm not sure that he was..
That's
-20 the issue.
21 MR. McCOY:
I understand that concern.
22 MR. SNIEZEK:
I understand hooking up the 23 nitrogen bottle is a nickel / dime operation.
24
' Draining.the reactor coolant reactor system is not a 25 nickel / dime situation.
. ~ _,
e O
110 1
MR. McCOY:
I didn't get the impression 2
that he was not aware that the reactor coolant 3
system was being drained.
4 4
MR. SNIEZEK:
I mean the nitrogen isn't d
5 significant from a loops not filled operation.
It's 6
the amount of volume of inventory of water in the 7
8 That's my concern.
And I could have a 9
false concern here and that's what I understand you 10 are going to address.
11 MR. DOMBY:
Mr. Sniezek, I believe he was 12 asked basically the question you just asked, was he 13 aware in his OI interview was he aware of the 14 evolution of drain down to midloop and the answer is 15 a definitive yes.
He was well aware of the overall
)
i 16 evolution of drain down in midloop.
17 MR. SNIEZEK:
I'm asking the question 18 based on his responses to the NRC, I understand 19 that.
Mr. McCoy said he was going to go back and i
20 check out the command and control issue.
I would 21 accept that as a yes.
22 MR. MCDONALD:
Can we talk a minute 23 here?
24 MR. SNIEZEK:
Sure.
25 (Discussion ensued off the record.)
111 1
MR. McCOY:
It is hard to pick up from 2
this submittal exactly what' Boles, the shift 3
supervisor, knew or did not know, what he was aware 4
of,~but let me tell.you what I would draw from.this, 5
if you look on the first page in the third 6
paragraph, where he b'egins with the second sentence, 7.
that says 8
MR. SNIEZEK:
This isn't the letter?
9 MR. McCOY:
This is his submittal-10-response to demand for information from Boles.
j 11 MR. SNIEZEK:
Where_are you, again?.
)
12 MR. McCOY:
I'm on the front page_, first 13 page, in the response, which begins at the third 14 paragraph which begins on the night shift.
15 MR. SNIEZEK:
Right.
16 MR. McCOY:
It is the third paragraph, 17-not the second.
And he says, from my review of the 18 logs and recollection the drain down of the RCS had 19 been halted during the day shift in order to assure 20 level verification.
On assuming the shift on 21 briefing during turnover focusing on activities to 22 be-performed that shift assuredly was held as was 23 the standard practice.
4 24 While I was aware that chemical cleaning 25 in the RCS had been planned and scheduled for the i
i
1 i
a 112 l
1 1
outage, this briefing would have been the'first j
2 instance that I knew about my specific j
3 responsibilities.
}
4
.That's the thing I read before and I 5 -
won't go on through that.
But clearly he was aware
)
6' from that of the draining evolution.
Now, what he i
7 doesn't address to my recollection is that during 1
8 his shift well, let's see.-
That during his shift t
j.
9-that they continued draining the RCS and that they I'
i 10 did the nitrogen addition. *He doesn't say anything 11 in his submittal about whether he did or didn't know 4
i 12 that.
He said he speculates that.because his leg 4
13 didn't have he's trying to say why his log didn't 14 have an entry on the nitrogen.
I 15 MR. SNIEZEK:
I'm not an expert, maybe i
i 16-I'm wrong, the nitrogen addition is simultaneous
)
4.
17 with drain down?
i s
18 MR. McCOY:
That's correct.
There are p
19
~two evolutions going on together.
20-MR. SNIEZEK:
In your Exhibit 14 1
21 MR. McCOY:
No.
i
[
22 MR. AJLUNI:
That's not accurate.
They 23
-injected the nitrogen and then they started the 24 drain down, the two evolutions were not 1
25 simultaneotts.
113 1
MR. SNIEZEK:
Well, at 1:50 a.m.
on 2
October the 12th, based on your Exhibit 14, nitrogen 1
3 injected at about 3:30 a.m.
water level was at 189120.
5 MR. AJLUNI:
Right.
If you look at the 6
RO log I don't have it, I'm sorry, it's i
4 7
exhibit l
8 MR. EBNETER:
Could I suggest something?
4 9
You should go back and submit for the record your 10 review of what this command and control situation i
11 is.
12 MR. McCOY:
Specifically regarding the 13 shift supervisor.
14 MR. EBNETER:
The entire shift conduct.
15 MR. SNIEZEK:
The reactor operator 16 knowledge of the operations going on, the shift 17 supervisor and the OSOS knowledge of operations 18 going on during this time frame.
19 MR. EBNETER:
And we would check that by 20 October lat.
21 MR. SNIEZEK:
Because like I said, I 22 don't want to make any decisions on false 23-impressions.
24 MR. EBNETER:
Does October let satisfy 25 you?
I I
. ~ _
114 1
MR. HAIRSTON:
I don't have any knowledge 2
of where these people are but it sounds fair to me.
3 MR. EBNETER:
If you have a problem with 4
that, call me back.
5 MR. McCOY:
All right.
We will do that.
6 M.R.
SNIEZEK:
We could debate this issue 7
all' day.
l 8
MR. HAIRSTON:
You asked for shift 9'
supervisor and RO.
10 MR. SNIEZEK:
And OSOS.
11 MR. HAIRSTON:
You asked for all three of 12 them.
13 MR. SNIEZEK:
I was primarily concerned 14 with the OSOS and the shift supervisor but there's 15 also a minor issue on the RO, too.
It's really the 16 integrated operations who knew what was going on, 17 the command and control of that facility at that 18 time.
t 19 MR. HAIRSTON:
Would it be interesting to 20 you for us to tell you what we've done from '88 to 21 now?
22 MR. EBNETER:
That's one of the things i
23 you should address if you see you made some actions 1
24 to correct things.
25 MR. HAIRSTON:
We.didn't try to address
e e
n i
115 1
that in the submittal, but there's quite a bit we 2
can tell you.
3-MR. SNIEZEK:
I agree with that, but it's 4
one to me, that was the level of significance to
)
5 me, that_ raised as high as greater than the 6
elevation.
7 MR. EBNETER:
Let's go on, we all 8
understand it.
9 MR. S N I E Z E K':
I have one final question.
10 In preparing the utility response to the NRC, your 11 August 29th response, in any way was the utility 1
12 response and that of Mr. Cash and Mr. Boles 13 coordinated and Kitchens coordinated, the three 14 individuals.
1 15 MR. McCOY:
The counsel that reviewed the 16 submittals for all of these individuals was the same 17 counsel.
I have no knowledge of any coordination or 18 any changes being made as a result of the 19 submittals.
20 I prepared the submittal.
I gave 21 guidance.
I reviewed drafts in several stages and 3
22 personally rewrote a good deal of what was in the 23 submittal, reviewed all of the attachments on the 24 company's submittal, and that represents the events 25 and the facts, to the best of my knowledge.
And I
. o.
4 l
i ic 116 4
3 1
did not review the submittals of the other people H
2-until after the company. submittal was made, s
3 MR. EBNETER:
Mr. Domby.
j 4
MR. SNIEZEK:
Let me ask another t
5 question.
Did anyone.in this room from the utility 6
know of any changes that'were made to the responses 7
of the three individuals based on the utility 8
. response?
9 MR. McCOY:
I do not.
10 MR. SNIEZEK:
By silence I take it that 11 no one in the utility is aware of any.
-12 MR. DOMBY:
Counsel is well aware'of the
'13 different responses being prepared, but Georgia 14 Power did not have access to all of,the responses.
15 MR. SNIEZEK:
I understand, I understand, j
16 I don't have any further questions.
17 MR. McCOY:
I don't.
18 MR. EBNETER:
I don't have, my questions 19 will be answered when you 20 MR. PARTLOW:
I have a couple.
Earlier i
21' in talking to Mr. Kitchens, I indicated Page 20 of 22 the utility response, that I read it, that one of 23 the old Georgia Power management team, Mr. Marsh, 24 who is no longer with Georgia Power, appears to me 25 to have broken ranks with that solid front that we i
n.-.
w
.m,.
-em--
ry
1 117 3
1 did the right thing on October 12th, and you were i
2 going to recalibrate me on that response.
l 3
MR. McCOY:
Response, okay, well, my 4
understanding of'that is not disavowed or disagreed, i
5 he just simply couldn't recollect the specifics of 4
6 the conversatf.on, but what I recall is that he said 7
that he had complete faith that if Skip Kitchens I
4 8
said that that did take place, that it took place,
-9 number one.
10 And secondly, that he said that the only 11 thing that he can speculate from from now being 12 asked about it, is that perhaps he used the 15 13 minute immediate interpretation based on the use of 14 that in emergency operating procedures.
But I 15 didn't get the feeling at all, Jim, that he had.
16 MR. PARTLOW:
I'm keying on his ending 17 up, it's not a good idea to open those valves, that 18 seems to be what he is saying there.
19 MR. McCOY:
Yeah.
Right, well, you know 20 a number of people have said that subsequent to then 21 including Walter.
22 MR. PARTLOW:
Let me get to something 23 else if I may.
You described over the pages three 24 years you've worked to improve the culture at 25 Vogtle.
118 i
1 MR. McCOY:
Right.
j 2
MR. PARTLOW:
The utility and Mr.
i 3
Kitchens has presented this morning'a picture that, 4
let me oversimplify, shows that throughout the ranks
}
[
5 there that there's a certain reverence for complying 1
6 with regulatory requirements.
7 In April 1990, we asked you to come in 8
and see us.
It was in Tom Brody's office.-
I know I
h 9
that Mr. Hairston, Mr. McCoy and Mr. Mcdonald were i
i j
10 there.
I know it was at least Jim Sniezek, and I i
11 can't remember whether Ben was there or not and we l
12 we spoke only in generalities not specifics of
/
13 events, but we gave to you our general impression 14 that we didn't see that reverence for regulatory 15 compliance with tech specs at Plant Vogtle.
That 16 was more, that perhaps we saw in cases an 17 irreverence for that.
18 I remember most vividly Mr. Hairston's 19 response of surprise, dismay, it's the first time 20 I've heard about this, I've got to go back and find 21 out what's going on.
22 My question is, did you go back and what 23 did you find out?
Did you find that reverence for 24 regulatory requirements or did you find that there 25 was anything to our general concern that brought you
+
F 119 i
}~
'l to Washington to.see us.
2 MR. McCOY:
.Well, let me say,.first-of 3
all, that we took that meeting extremely serious.
j 4.
That just_ hit right at the heart;of the thing I was f
5 saying before I believe very strongly in.
And as a 4
6 result of that, we went back to the plant and the 7
~ plant manager,-and I met with all employees at the 1
8
. plant, and we met.with the operations people, and we l
9 talked about exactly what had been said in that 10 meeting, what the perception was.
11 We also did a lot of soul searching about 12 how that perception ha'd arrived and'how much of that 13 was perception and how much of it was real 14 problems.
And we concluded there were some of both.
15 MR. PARTLOW:
Okay.
1 16
.MR.
McCOY:
And.the plant manager at that 17 time was very frank in his conversations with all j
the employees and he took some responsibility for 18 3
19 it, -for the perception that some of the actual 20 and we talked about how important it was for us to 21 comply with' regulations and for-people to have a 22 high' competence that Vogtle Plant was running in 23 compliance with all regulations, and that would 24 never ba something to be questioned that's
(
25 importance to us, and we try to communicate that to p
4 t
a
120 1
people..
2 We talked about specifically why it was 3
important and'why we had an obligation to keep-the 4
resident inspector-fully informed of what was going.
5 on.
It was not sufficient just to let him discover 6
things,'that we had to be proactive, and if there 7
was anything we thought he ought to know about we 8
took it to him.
And so we took that meeting very
{
9 seriously.
i 1
10 There have been a number of feedback 3
11 processes, I guess, since that time, that have 12 indicated to me that we have changed significantly 13 both in the actual practices that we have and of the 14 perception that people have of us.
15 Specifically, I think that the licensed 16 operators at the plant and the management in the 17 plant was taken aback by that.
That was a 18 significant blow to their own perception of 19 themselves,-and they took that very seriously, and I 20 have since that time, have a different attitude 21 about compliance.
It has to do more with this thing 22 we talked about earlier about not hesitating to seek
23
. advice.
24 You know, quite frankly Vogtle was a new 25 plant, with a lot of young people in very
-w y
---r m
r v-T
-e-----
I 121 J
1 responsible. positions.
They did some great things, 2
they had short startups and some other things that 3
they were proud of what they did, and I think that 4
they tended to not recognize how wonderful they 5
might be, and I think that has changed as the plant 6
has matured.
The other thing 7
MR. HAIRSTON:
I wanted to add one thing, 8
you alluded to me being surprised and I was, but I 9
took it just as serious as Ken and, you know, we can 10 stand here all day and tell you how we think we've 11 improved and we are going to submit for the record 12 some of the issues that really take the concern you 13 had up here and it drops on down in the organization 14 in 1988.
But I guess I was a little bit surprised 15 when I walked into this meeting and the senior 16-resident wasn't here, because he doesn't know 17 anything about what happened in '88 but he knows 18 what's going on down there now to some degree.
He's 19 in a lot of our meetings, I go by and talk to him.
20 And I asked the questions on the very 21 thing that you put us on the carpet for in 22 Washington, not only did I take it serious then, I 23 take it serious now.
It's not something that Stu 24 will tell you I call him every two or three months j
25 and just ask him, how we doing, have you heard any
j 122 1
complaints.
I think Pat feels the same way.
I have 2
not forgotten that May '90 meeting.
I hope I never 3
have to go to a meeting like that again.
4 MR. McCOY:
I guess to finish up what I 5
was going to say, there have been a number of 6
feedbacks both in verbal and written communications 7
with the NRC that have reinforced to me that we are 8
making good progress in this area.
9 I've talked to the folks both in NRC and 10 in the region on a number of occasions about whether 11 that-perception still exists and whether we're 12 making progress and the indications that I've got 13 have been consistently we're making progress.
14 MR. MCDONALD:
May I say,something about 15 it?
I think the thing you said, Jim, about the l
16 attitude toward compliance, and that's what you 17 said, is that we were surprised because we had 18 watched for compliance very closely.
What we were 19 surprised by we had been so close to it that we 20 hadn't seen perception that the outward conduct of 21 business was giving at the plant.
The outward 22 conduct of business was giving one possible of 23 error.
24 And in order to give the proper 25 perception, you can say, I comply with all the ru'-
~._
4 123 t
1 everyday, but if stand up and pronounce too loudly, 2
you doubt my sincerity, and you doubt my sincerity 3
if you, when you come around the corner, then I go 4
the other way and those sort of things.
5 So what we attempted to do is to say that 6
in compliance with regulations attitude toward 7
safety has to be associated with the humble 8
recognition of the task we're given and the 9
recognition the.t we always have to work as a team 10 among ourselves as well as with the commission.
12 So I think that that sense of humility is 12 what we went back and tried to instill on people, 13 and as well as the fundamental ground rule about how 14 you approach safety compliance was one.
15 MR. EBNETER:
You found neither angels or 16 devils, you found human beings.
I have no further 17 questions.
18 MR. LIEBERMAN:
I have one question, 19 probably a simple question, but I think it's truly a 4 20 fundamental question.
We've just heard about 21 improvements being made in professionalism and 22 attitudes and things of chat sort, and I clearly 23 understand and recognize your position is that there 24 was certainly not a willful violation that occurred 25 back in 1988, but does the company accept that a
124 l'
violation occurred concerning the tech spec in 2-1988?-
3 MR. McCOY:
Our position is that at the 4
time'in 1988 that it'is not clear that a violation 5
occurred, that that is subject to' interpretation, 6
and that if you ask that question of reasonable 7
people that work in this industry, other license 8
operators, people within the NRC, that you would get 9
varying answers, or would have in 1988.
10 MR. LIEBERMAN:
- So the position of the 11 company does not accept this violation?
12 MR. McCOY:
That's correct.
13 MR. SNIEZEK:
Let me ask a question, Mr.
14 McCoy, it's an unfair question.
Do you accept the 15-fact that a violation occurred in 1988?
16 MR. McCOY:
I accept the fact that based 17 on the guidance that we're aware of now, that we did 4
18 not do what the NRC intended in that particular 19-situation, and that we will not do that now, we've 20 put out clear guidance to that effect.
21 MR. SNIEZEK:
I'm not sure I want to put l
)
22 that in my own words.
I 23 MR. McCOY:
Well, I will try again, if a
24 that's i
25 MR. HAYES:
That's a yes or no.
i
125 1
MR. EBNETER:
We understand..
Any more 2
questions.
Vince, you got any questions?
3 MR.. HAYES:
No.
The staff have any 4.
questions, relevant questions?
5 MR. MATTHEWS:
Yes.
I do have'one.
It 6
does pass that test.
David Matthews, the Office of 7
Nuclear Regulation.
8 There's an apparent conflict that has 9
come to my attention and I need you to help resolve 10 it if you see it the way I do.
In Mr. Kitchens' 11 statement this morning and his concluding remarks, 12 and I bel mye you've stated it a couple of times in l'3 the graphs, the corporate position paper that was 14 developed in the end of
'89.
15 MR. McCOY:
It was in late October of 16
'89.
17 MR. MATTHEWS:
October of '89 was 18 referred to.by Mr. Kitchens, and I think you just 19 inferred that it forms your basis for saying the 20 company has given instructions that wouldn't permit 21 such an entry could be made into that tech spec at 22 this point in time.
23 MR. McCOY:
That was the first step and, 24 as was pointed out, that was a should statement.
25 MR. MATTHEWS:
Yes.
i i
j
126 1
MR. McCOY:
Subsequent to that time, a 2
stronger statement has been put out based on further 3
interpretations that we've gotten from the NRC and 4
that was put out by the plant general manager in i
5 August of this year.
6 MR. MATTHEWS:
Okay.
I thought it also 7
said should.
8 MR. McCOY:
Well, to me it was a stronger l
9 statement, but maybe I'm not clear.
10 MR. MATTHEWS:
Either way, I inferred 11 from your statements, and you tell me if I am wrong, 12 in your view now, such an entry would be prohibited 13 by your plant guidance procedures policy?
14 MR. McCOY:
Yes.
15 MR. MATTHEWS:
Okay.
16 MR. SNIEZEK:
Let me build on that a 17 little bit.
I personally from the safety standpoint 18 always have a concern when we have an absolute under 19 no circumstances.
I would envision that if safety 20 was an issue, even though you have corporate i
21 guidance that says should, if in the immediate 22 judgment of the shift supervisor or the reactor i
23 operator or the OSOS or whatever they are called 2 4-today, it was necessary for safety to enter 25 immediate action statement that would not be
4 127 1
prohibited by your guidance.today?
2 MR. McCOY:
You are absolutely right, and 3
it's easy sometimes to forget to put that caveat 4
on.
We have to put that on everything, and I agree 5
with you.
6 MR. SNIEZEK:
And I would assume you know 7
there's a difference between real safety need and an 8
operational expedience or convenience, and there are 9
no charades or games being played in that arena.
10 And that's what's covered id the training of your 11 staff.
12 MR. MATTHEWS:
And my question wouldn't 13 have applied to anything other than that.
The 14 contradiction that I am dealing with is that I have 15 reviewed the transcripts of the plant review board 16 members testimony to the OI, which I believe you 17 have available to you as well, and in my reading of 18 those transcripts, that same wording was used as a 19 justification for not reporting the entry as being a 20 violation of tech specs.
21 Okay.
Namely the "should" being not 22 prohibiting, therefore, with some flexibility in it.
23 was used as the justification for saying such an 24 entry was not expressly prohibited, therefore, it 25 was not a violation-of the tech specs, therefore, i
l,.
1 4
128 j
1
. was not reportable..
4 2
MR. McCOY:
That's
.3 MR. MATTHEWS:
I'd like you to respond to i
4 what'I see as a potential conflict.
5 MR. McCOY:
We are referring to the words j
6 in the tech specs?
7 MR. MATTHEWS:
I was referring to the 8
word in the corporate guidance memo and how it was 4
9-being utilized in interpreting whether or not the j
10 tech specs had been violated when the plant review
}
11 board considered the issue in September.
12 MR. McCOY:
I have not read the 13 transcripts of this discussion that you're talking i
14 about.
I really feel uncomfortable.in responding to 15' that having no knowledge in that context.
1 16 MR. SNIEZEK:
Could I ask in addition'to 17-what Mr. Ebneter said that you respond to that also, x
18 because it's very important that no one in the 19 company that we talk out of both sides of our 20 mouth.
The same way with the NRC, we talk very 21 straight, and if in one case it's a clear company 22 position, no one should use it to argue against 23 reasonable decision making, so if you could look at 24 that I think that would be very worthwhile.
25 MR. HAIRSTON:
What you want us to submit
+
7_,_
7
.__.____m.__
}
l
+
4 129 i
1 on the record is'what our policy is on operational i
2 entry into immediate action statements vis-a-vis
'3 what the code allows under an emergency condition?
i i
j 4
MR. SNIEZEK:
Uh-uh, no, no.
5 MR. EBNETER:
Dave, I think you are
]
6 asking for a conflict.
t 1
7 MR. MATTHEWS:
I will try.to explain it, 8
everybody help me if I need it.
It appears based on i
i 9
what I heard this morning from Mr. Kitchens and what 10 I. heard from you today, that your corporate policy 4
11 has been expressed in a September November 1989 4
i 12 memo from.you, and as reinforced by a more recent 13 memo from the plant manager.
-l 14 Is it, if the situation were to occur 15 again such as happened in 1988, okay, that such an 16 entry, namely a voluntary entry into an action 4
17 statement that has an immediate effect wouldn't be i
18 done provided, of course, that there were some, not 19 an overriding safety issue, that you evaluated okay, l
20 and yet at the same time the fact that that 21 corporate policy statement uses the word "should" j
22 instead of "shall" as I understood it was the basis
. :23 for the plant review board in 1989 deciding that 4
24 this issue was not reportable to the NRC because it 25 did not expressly prohibit such an entry.
o 130 1
So I think Mr. Sniezek stated it well.
2 There's an appearance that may be the same guidance 3
is being put to two different ends that are 4
contradictory.
5 MR. LIEBERMAN:
For example, in your 6
training programs what are you training your people 7
on the meaning of that document?
8 MR. McCOY:
We train our people based on i
9 the guidance that is available today that proper 10 interpretation of that text is that it would be a 11 violation to enter an immediate action statement 12 voluntarily.
13 MR. EBNETER:
Let me tell you what I 14 heard and you can modify it, what we can expect in 15 response to Mr. Matthews' question is you will 16 submit a clarification of your guidance on voluntary 17 and voluntary entry into action statements and the 18 use and meaning of the words "should" and "shall."
19 MR. MATTHEWS:
And how they were used and 20 viewed during the time that the plant review board 21 made their deliberations on not reporting to the NRC 22 on the 1988 entry.
23 MR. McCOY:
Well, let me go back and just 24 be cure, did you read that whole memo?
25 MR. MATTHEWS:
Yes, I did.
e i
131 1
MR. McCOY:
Okay.
You know in there it 1
i 2
gave a history and it specifically' discussed in the 3
discussion that a reasonable person based on all of 1
1 4
that would not necessarily conclude that you could 5
not enter a statement.
I think you have to take it 6
into that context in what the PRB decided back in 7
'89.
Today I don't think they would have that 8
interpretation at all.
9 MR. MATTHEWS:
The factor that I'm 10 bringing to this discussion that you said you 11 weren't familiar with yet and you needed to review, 12 was my reading of the transcripts of the 13 deliberation, excuse me, of the representations by 14 people who were involved in that deliberation as to 15 how they reached their conclusion that.it was not 16 reportable.
17 MR. SNIEZEK:
This is during their OI?
18 MR. MATTHEWS:
Yeah.
19 MR. HAIRSTON:
Stu, would you say it one 20 more time and, Mark, would you write this down, 21 because you said something and Dave added?
22 MR. EBNETER:
Dave modified it so I added 23 to it.
24 MR. HAIRSTON:
We get it one more time.
J 25 MR. SNIEZEK:
Let me ask something else, 4
4 e
e a
i 132 1
be done, put it in the transcript.
Dave Matthews 2
will write it out.
Dave, would you please write out i
3 exactly the question and we will give it to the 4
licensee and we will give it to the reporter to put 5
in the transcript?
6 MR. MATTHEWS:
I will do that.
7 MR. SNIEZEK:
So there's no question of 8
talking about back and forth.
4 9
MR. HAIRSTON:
You want this by October 4
10 lat.
l 11 MR. EBNETER:
To the extent you can do 12 it.
13,
MR. SNIEZEK:
Is there any other 14 questions from the staff?
15 MR. EBNETER:
All right.
Thank you.
No 16 more staff questions.
17 Would you like to make a short summary?
18 MR. McCOY:
It's been a long time since I J
19 gave the conclusions at the beginning and let me I
20 summarize very shortly and leave you with our l
21 thoughts on this.
22 First, first there was no deliberate or 23 willful violation.
Tech spec interpretation was 24 made in good faith and with reasoned judgment at t.". -
25 time in 1988.
Therefore, individual enforcement
s -
-y 4
1 i
,4 133 i
i 1
action is unwarranted.
4 2
Second,.a tech spec violation issued to-i 3
Georgia Power, it's inappropriate based on the tech 4-spec that the' tech spec entry was consistent with i
5 the existing guidance and practice in the industry 6
in-1988.
Also, voluntary entry into LCOs was and is 7
an evolving and generic issue.
This is more-8 appropriately addressed in generic guidance or 9
correspondence ~to the. industry.
10 Third, the October 1988 incident was 11 demonstrated to have no significant safety or-12 regulatory impact based on the administrative 13 controls and reviews that were done at the time.
14 This was clearly confirmed by subsequent 15 Westinghouse analysis which you've bean provided.
16 And lastly, as we have~ described, this 17 was an isolated event, not a broad issue.
18 Last, Georgia Power has made significant 19 enhancements that comprehensively address the 20 institutional weaknesses highlighted by the October 21 1988 incident.
That summarizes our conclusions from 22 our review.
23 MR. EBNETER:
Okay.
Dave will look at 24 the statement I would like to get that in before we 25
' leave.
But we want to thank you, appreciate y'all
1 134
{
1 coming in.
You did an extensive amount of work on 2
the response and we appreciate that.
There was a 3
lot of information.
4 in response to Mr. Sniezek's concern on 5
command and control, we understand that you will 6
submit review of the conditions that existed in 7
October of 1988 as it is today, and you will submit 8
this review for the record by October 1st of 1991 as 9
a supplemental response to the demand for 10 information.
If you have trouble meeting that 11 response, you should contact me as soon as you can 12 make the determination for a more appropriate date.
13 Dave.
14 MR. MATTHEWS:
Secondly,,would you submit 15 a clarification of your guidance on voluntary entry 16 into tech spec action statements and the use/ meaning 17 of the word "should" and "shall" and how they were 18 used by the PRB as a justification for not reporting 19 the 1988 incident during their deliberations that 20 culminated in a decision during November 1989, 21 period, question mark.
22 MR. HAIRSTON:
Could we have a Xerox copy 23 of that?
24.
MR. McCOY:
We would like to copy that, 25 be sure we get it exact.
-.. _=
. /
\\
- O t
135 1
MR. EBNETER:
A copy of the transcript 2
will be made available to you if you so request and 3
we will put that in the public document room when we 4
iesue the enforcement action if any is issued.
5 That's the end of the conference.
6 i
7 (Conference concluded at 3:45 p.m.)
8 9
j 10 11 l
12 13
~14 15 16 17 18 l
19 20 21 22 i
i 23 6
24 25