ML20147E844
| ML20147E844 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 05/01/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 NUDOCS 8801210229 | |
| Download: ML20147E844 (46) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION 1
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IN THE MATTER OF:
DOCKET NO:
INVESTIGATIVE
- INTERVIEW OP DON K. CRONEBERGER'
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NAT10hWIDE CO 9' 7
CR22943.1 1
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
OFFICE OF INVESTIGATION 4
5 GPUN Headquarters 100 Interpace Parkway 6
Parsippany, New Jersey 7
The Investigative Interview convened at 1: 35 p.m.,
8 Richard A. Matakas, presiding.
9 PRESENT:
10 DON K. CRONEBERGER, Interviewee 11 RICHARD A.
MATAKAS, Investigator Region I 12 Nuclear Regulatory Commission King of Prussia, Pennsylvania 13 ROBERT G.
LA GRANGE 14 Section Leader EQ Branch 15 Office of Nuclear Reactor Regulation 16 17 18 19 20 21 i
22 23 24 w.
n m tre.
25
CR22943.1 BRT 2
I EE2SEEE1EEE 2
MR. MATAKAS:
The date is May 1, 1985 and the 3
time is l:35.
Present for this int erview are myself, 4
Richard A. Matakas, investigator, USNRC; Bob LaGrange, 5
section leader in the NRC EQ branch, Office of Nuclear 6
Reactor Regulation; and Mr. Don Croneberger, director, 7
engineering and design, GPUN.
8 The purpose of this interview is to discuss 9
facts and circumstances leading to GPUN submittals to the 10 NRC involving the environmental qualification of 11 electrical equipment at TMI Unit 1.
12 Mr. Croneberger, do you have any objection to providing 13 this information under oath?
14 THE WITNESS:
No.
15 Whereupon, 16 DON C. CRONEBERGER 17 was called as a witness and, having been first duly sworn, 18 was examined and testified as follows:
19 EXAMINATION l
20 BY MR. MATAKAS:
21 Q
For the record, will you state your full name 22 and business address, please?
23 A
Don K. Croneberg er; 100 Interpace Parkway, P
24 Parsippany, New J ers ey 07054.
t 25 Q
And what extension can we reach you at?
3RT 3
1 A
2031.
2 O
Mr. Croneberger, we are going to be talking 3
first about some internal audits conducted by GPUN.
I 4
would like to introduce some documents into the record.
5 The first one I would like to show you is what has been 6
identified as GPUN interoffice memorandum dated June 25, 7
1981, letter number QA/4161, and attached to it is 8
internal audit 81-02.
9 Would you take a look at that?
I ask you if you 10 recognize it.
Do you recognize that document, sir?
11 A
Y es, I do.
12 Q
I asked for the response from Tech runctions to 13 QA, and that couldn't be located.
But what I do have is 14 QA's response back to Tech Functions regarding the Tech 15 Functions response, and that is identified by interof fice 16 memorandum dated June 25, 1981, lett er number QA-4186, th e 17 subject of which is 81-02 audit, and it 's addressed to 18 yourself.
Take a look at that.
19 Do you recognize receiving that particular document in 20 this particular time frame, June 1981, as a response from 21 QA back to Tech Functions?
22 A
Yes, I do'.
23 Q
The third document is Tech Functions' revis ed 24 response dat ed August 21, 1981, letter number is EP&I, 25 81/0176, and it is from Mr. Maus to Mr. Stromberg.
t BRT l
4 1
Do you recognize that as Tech Functions' revised 2
response to 81-02?
3 A
Yes, I do.
4 Q
And the last document for right-now that I wotid 5
like to show you is dat ed April 4, 1984.
The subject is 6
"Open Audit Findings, 81-0 2 audit. "
It's from Mr. Guimond 7
to Mr. Stromberg.
8 Take a look at that.
9 Do you recognize that document, sir?
10 A
I recognize tihe document, although I'm not sure 11 exactly when I saw the document.
12 Q
Would it have been in the 1984 time period?
13 A
Yes.
14 Q
Did you have any input into the request for the 15 audit to QA7 16 A
In 19817 17 0
Yes.
i 18 A
No.
19 Q
Were you aware that the audit was going to be 20 conduct ed ?
l 21 A
Yes, I was.
22 Q
I notice that there were 11 deficiencies not ed 23 in the audit and that you signed for the proposed 24 corrective action for findings 1, 3 -- signed for, I don't 25 Knos if you want to call it "acceptance" or "acknowledgment"
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-BRT 1
of the audits -- for 1, 3,
and 11.
Why did you sign for 2
those three and Mr. Maus for the remaining?
Was there any 3
particular reason?
4 A-I believe -- and this was same long time ago --
5 at that time, included in my organization, was a group 6
which was responsible for procedures and standards.
That 7
function, near this time frame, was reassigned to the 8
engineering services department.
9 I believe my signature was intended to convey the fact 10 that Maus, himself, could not take the responsibility for 11 getting the procedure in place; that I would have to get 12 this other group to develop the procedure.
13 Q
Specifically audits 1 and 3, they appear to be 14 more of a programmatic type --
15 A
Yes, my recollection was those were 16 programmatics, which required the development of l
17 procedural guidelines.
I l
18 Q
What is Tech Functions' responsibility to 19 correct audit findings?
In other words, is there a l
20 procedure that tells you you have to do X, Y, and Z by a l
21 certain amount of time during the 1981 time period?
22 A
To my knowledge, no such guidance existed.
23 Q
Is there one today?
24 A*
I believe there is; yes.
25 Q
Wac there any type of understanding?
In other 4
BRT 6
1 words, what's the purpose of the audit?
If i+ id ent ifi es 2
deficiencies and makes recommendations, was there any type 3
of unddrstanding that these would be corrected or --
4 A
Normally, the signature on the finding conveyed 5
a commitment within a month to either correct the finding 6
or propose a plan by which the finding would be closed out.
7 Q
And what did you do in this particular area, 8
particularly for findings 1 and 3?
9 A
Tried to get start ed the development of what 10 eventually became procedure EP-301.
11 Q
When did that procedure finally come out?
I 12 noticed the proposed date on it is September -- I think 13 September 1, 19817 14 A
I'm not certain.
I could check.
I know I 15 signed that out on behalf of Mr. Wilson and I'm really not 16 sure of the year; whether that was '81 or '82.
l 17 0
Was that engineering procedure, was that already 18 being generated at the time of this audit?
19 A
I'm not certain.
I 'm not certain.
20 Q
Then you wouldn't be certain if it was generated 21 because of the audit; is that corr ect?
22 A
I'm not certain.
23 0
Were you aware that some of the audit 24 deficiencies remained open in 19027 l
25 A
I believe I was awares in 1982, that some of the
7 CRT 1
deficiencies were still not closed out.
2 Q
Were you aware that some of the deficiencies 3
were st'ill not closed out in 19837 4
A To,pmy knowledge, no.
5 Q
okay.
What gave you indication that these 1
6 f.eficiencies had been closed out in 1983?
7 A
My recollection of the absence of any 8
interaction with QA.
9 0
I notice in the initial response from Tech 10 Punctions to QA on the audit, that audit finding number 1 11 was not addressed.
That finding is:
"No evidence of 12 management direction to correlate the efforts of 13 intersectional effort in establishing the master list and 14 qualification documentation file."
15 Was there any reason for that?
i 16 A
None that I am aware of, other than I believe 17 the background of that response was from Maus, and he may 18 have considered that not to have been his area of l
19 responsibility.
l 20
- Q You didn't have any contact with QA, or
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l 21 discussions with QA that t, hat not be addressed?
i 22 A
Not to my knowledge.
I 23 Q
Was there any concern that that particular 24 finding was too critical of management?
Was there any 25 concern on your part that audit finding number 1 was too i
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2 A
No.
3 Q
Subs equent to the audit, did you attend any 4
meeting's with QA concerning the audit findings?
5 A
Subs equent to the audit?
I'm certain I did, 6
although I suspect that was primarily in the April-May 7
time frame of 1984.
8 0
You don't recall attending any meetings bnck in 9
1982, 1983?
10 A
I know I attended meetings relative to that 11 audit finding.
I do not remember meetings subsequent to 12 that until the 1984 time frame.
13 o
Did you have any contact with QA individuals, 14 either Mr. Guimont., Mr. Stromberg, Mr. Bader, and Alatary, 15 anybody on that level, who advised you that they did not 16 feel that the audit findings were closed out -- being 17 satisfactorily closed out?
18 A
clearly that was an issue in 1984.
I do know 19 prior to 1984 that some of the specific technical issues i
20 were not considered closed out, and I suspect that was 21 maybe some discussion with Matt Stromberg.
I didn't get 22 the impression from that that the open issues -- and I 23 really forget what the open issues were -- were things 24 that were easily corrected.
25 one that comes to mind that was involved was
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documentation on the ASCO valve issue, where I couldn't 2
determine how we could get drawings correct ed when the 3
drawings didn't exist during April.
I recall that as 4
being an open issue.
5 0
In what time period?
6 A
Probably' prior to the April-Hay time frame of 7
1934.
And I suspect, with that recollection, there were 8
probably some discussions with someone like Matt Stromberg.
9 0
During the '82 '83 time period, did OA' tell you 10 that they were not satisfied with the documentat ion in the 11 files, the docuisent.ation to qualify ir.dividual components?
12 A
Not explicitly.
13 Q
Woulo you clarify that, please?
"Explicitly"?
14 What doer that mean?
15 A
I mentioned the fact that diere was a concern on 16 the auditor, that we not repeat by buying a part again 17 which was the same as the original construction versus the 1
18 replacement.
Tha*. was the kind of issue that I recall 19 that exi s t ed.
But I viewed it, at that ti me, as not being 20 related to whr.t's the. e being unqualifiedt it was 21 something that had to be corrected to make sure that 22 subsequently we didn't do something to the plant which 23 would geopardize the qualification.
24 0
Which QA auditor are we talkir.g about, who you 25 had these discussions with?
i 4
10 BRT 1
A Probably Matt stromberg.
2 O
Did you have any specific respu".sibilitlen 3
relating to the Envi ronmental Qualification program?
4 A
The recognition that we needed to set up a 5
function to address Environmental Qualification.
As I 6
remember, it was raised in 1981.
7 In 1981 it was deci.ded that that function would be in 8
the engineering and design department and within the 9
electrical power and instrumentation section, we call it.
10 So, in 1981 it was decided there would be a functional 11 responsibility assigned for EQ within that section and at 12 that time Maus was assigned as being supervisor of that 13 function.
14 O
G ett ing ba ck t o, specifically, audit findings 1 15 and 3, according to the April 4th memo, April 4, 1984 memo, 16 both audit findings 1 and 3 were still considered as open, 17 according to Mr. Guimond, who was t.he lead auditor on 18 audit 81-02.
19 Why did they stay open so long; do you know?
s 20 A
Again, undoubtedly they stayed open longer than 21 required; but a version of EP-031 was issued prior to 1984, 22 and when that EP-031 was issued, I had assumed that that 23 was the basis for closing out finding number 1 and, I 24 believe, number 3.
25 Q
I would like to show you a letter.
It is to
11 BRT 1
yourself, "Proposed Corrective Action to Audit 01-02";
2 that's the subject of the letter.
And it's a letter from 3
Mr. Guimond.
4 I would like to ask you if you have ever seen the 5
letter before.
6 (Discussion of f the record. )
7 BY MR. MATAKAS:
8 Q
Did you recognize that document?
9 A
Yes, I do.
That in itself may be mirleading.
10 This document was brought to my at tention, I believe, in 11 something like the May '84 tire frame.
12 Q
okay.
I want to show you ar other document also, 13 and we'll talk about both of them.
The second document I 14 would like to show you, the subject is "Eme~gency l
15 Proc edu r e-0 31, equipment, enviro'nmental qualification."
16 It is to yourself.
It was from, again, Mr. Guimond.
It 17 starts out:
"Per our agreement I am forwarding to you our 18 comunents on EP-031 for your disposition and corrective 19 action."
And under general comments, it states "The 20 procedure does not address nor reference all of the 21 implementing procedures needed to assure all," emphasis 22 added, "the requirements of the bulletin is being met.. "
23 Do you recognize that docussent?
24 A
No, I do not.
25 Q
Okay.
Let's talk a lit tle bit about the
12 BRT 1
document which is entitled -- or the subj ect of which is 2
' "Engf.neering Proc edure 0 31. "
3 Do you remember any procedure with Mr. Guimond where 4
you discussed -- where you wanted him to look over 5
Engineering Procedure-031, and review it for acceptance?
6 A
I had no direct discussion with Mr. Guimond, to 7
my knowledge.
8 C
Did you have it with any of his supervisors, to 9
have him look over that procedure?
10 A
Procedure EP-031 was initially released under my 11 signature in Mr. Wilson's absence.
12 I do recall in that time frame that there was an 13 outstanding issue with the QA department, where they were 14 not catisfied with that procedure.'
15 I do remember that pending resolution of those comments 16 I would not sign that procedure off.
17 Now, who within QA generated those comments to that 18 procedure when it was going through the sign-off process, 19 I'm not sure.
20 Q
Did you ever sign off that procedure?
21 A
I did.
22 Q
Do you have any idea why these two documents 23 were never officially brought to your attention or sent to 24 you?
25 A
No, I do not.
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13 BRT 1
-Q I should rephrase that:
Why they were not 2
officially put into the GPUN system?
3 A
I do not.
4 Q
And you were never informed by QA that, in their 5
opinion, Engineering Procedure 031 did not satisfy the 6
audit findings in 81-02, specifically audit 1 -- audit 7
finding number 1 and audit finding number 37 8
A No, to the contrary my understanding before my 9
signature was applied was that the comments from the QA 10 department were resolved.
11 Q
And who lef t you with that impression?
12 A
Mr. Maus and/or Mr. Flynn.
Flynn would have 13 been the one who was handling the procedures.
14 Q
I notice at the close-out date on audit finding 15 3,
it is closed out by Mr. Magitz on 6/29/1984.
And 16 that's the same for audit finding number 1 and the same 17 for audit finding number 11.
l 18 Does this document ever come back to you *to let you i
19 know when it is closed out?
And I'm talking about " this 20 document," the actual audit finding nonconformance sheet?
21 A
To my knowledge,, no.
22 Q
Did you ever tell Mr. Maus that this procedure 23 was acceptable for the close-out of audit finding number 17 24 And I'm talking about Engineering Procedure 0317 25 A
I believe not, although I just don't recall.
I l
14' BRT 1
could have, I just don't recall.
2 O
Do you have any responsibility to incorporate or 3
follow audit recommendations?
4 A
Would you repeat the question?
5 Q
Do you have any responsibility -- and I say "you,"
6 I mean Tech'nical Functions -- to address the 7
recommendations that are made in an audit?
I notice on 8
page 10 of 10 there's three recommendations that were made?
9 A
Today the procedure would require at least a 10 memorandum addressing a recommendation.
That requirement 11 would not have existed today, so it would have been up to 12 the audited organization to determine whether to respond 13 or not or how to follow a recommendation.
I 14 0
Do you mean -- what didn't exist back in 19817 l
15 A
That approach did not exist.
In 1981 it would 16 have been up to the recipient of the audit to determine 17 what action if any he was supposed to take relative to 18 recommendations.
19 Q
Okay.
Regarding the recommendations that are 20 noted on page 10 of 10, instead of reading that into the 21 record -- I have done that several times -- if you would 22 look at those audit recommendations as shown on page 10 of 23 10 in audit 81-02, did you consciously make a decision to l
24 follow or not to follow those three recommendations?
25 A
There was a conscious decision to try to push
15 BRT 1
getting the procedure in place.
There was, on my part, no 2
conscious decision to address or not address it ens 2 and 3.
3 0
Once that procedure was in place, did you have a 4
responsibility to find out if that procedure has been 5
accepted by QA7 6
A The normal approach on procedures which involved 7
interfaces with other div.isions would be to get for them 8
the opportunity to review the draf t procedure and provide t
9 comments; and our process of resolving comments is 10 incorporated in that process.
11 Up until we made use of the new corporate procedure 12 system, acceptance by OA would have been inferred from 13 their providing comments and a satisfactory resolution of 14 the outstanding comments.
15 Q
Okay.
That's what I'm getting at.
The two i
16 documents that I showed you were reviewed by the audit 17 team leader -- and, by the way, those were dat ed August 10 1982 which, in effect, finds Engineering Procedure 031 19 unacceptable to resolve audit findings 1 and 3.
And at 20 the same time, there was a document generated which stat es 21 essentially the same as the April 4, 1984 document that 22 you have looked at here, that states:
Audit findings 1, 3, 23 5-A and 6 -A and portions of 11 are unacceptable.
24 What 7 'm trying to get at is where was the breakdown?
25 And the reason for this is:
Would it be fair to say that t
a
16 BRT 1
these audit findings were addressing the programmatic 2
problems of documentation and management direction in the 3
Environmental Qualification program?
Would that be fair 4
to say?
Those particular audit findings?
5 A
Hy interpretation of those audit findings and 6
the focus on the procedure was primarily to assure that 7
the various responsibilities were assigned and the 8
interfaces between groups were assigned.
The procedure, 9
as written, also at tempted -- attempt ed to define 10 documentation requirements.
But the main focus was to 11 understand who was responsible for doing what.
12 O
okay.
Then who was responsible for audit 13 findings 1 and 3?
Who was responsible for assuring that 14 those audit findings were corrected?
15 A
I took on the responsibility by signing that 16 finding of 1981, and was driving to get the procedure in l
17 place.
So I would say I was responsible for trying to 18 close out those findings.
19 Q
okay.
.Then what information did you have which 20 would lead you to believe that those audit findings were, i
21 in fact, closed out?
22 A
The only evidence that I can recall being aware 23 of was a QA concurrence on the resolution of comments for 24 EP-0 31, prior to my signing that document in 1982 or 1983.
25 Q
Would you have those on file?
BRT 17 1
.A I would have to check with Mr. Flytn.
He could 2
have those on file.
3 MR. MATAKAS:
Let 's go off the record for a 4
second.
5 (Discussion off the record. )
6 BY MR. MATAKAS:
7 Q
Before we went off the record we were talking 8
about Engineering Procedure 031, and a -- when this 9
procedure was adopted.
You have indicated that there was 10 a sign-off sheet where it has to be accepted -- an 11 accepted procelure by various sections or departments 12 within the GPUN organization; is that correct?
13 A
Yes.
An opportunity to review and provide 14 comments.' And by commenting, require resolution of 15 comments prior to a document being issued.
16 o
okay.
What was the purpose of engineering 17 procedure 0317 18 A
The purpose of Engineering Procedure 031 was to 19 define responsibilities for performing work required by 20 the EQ issue, and to provide some guidance on 4
21 documentation requirements.
22 Q
I know we talked about this before.
Then it was 23 a procedure that was initiated specifically to resolve 24 those audit deficiencies?
That's what I ' m not clear on.
25 What I'm getting at now, because QA gets this procedure,
BRT la 1
and they sign off on it for procedure, is that 2
necessarily -- does that necessarily mean that it resolves 3
audit findings 1 and 3 in internal audit 0202?
or are 4
they just accepting it as a procedure as it stands on its 5
own?
6 A
T'o my knowledge, their sign-of f would not 7
necessarily state that closes out an audit finding.
8 O
Then would it be your responsibility to see if 9
in fact it does close out the audit finding, and not that 10 it 's an accepted procedure?
It's one thing to close out 11 an audit finding; it's another thing that it's an accepted 12 proc edure?
13 A
As I remember, and I believe this is included in b
14 the one memorandum that was sent back, we had a commitment 15 to issue EP-031 as a vehicle for closing out the one --
16 audit finding 1, I believe.
17 Q
That's correct.
In your revised response dated
)
18 August 21st -- the revised response dated August 21, 1981, 19 it states:
"As proposed corrective action, Engineering 20 Procedure 031 is scheduled to be issued 9/1/81."
And 21 that's the proposed corrective action.
And it is found 22 accepted by Magitz.
23 But that 's propos ed corrective action.
And the same 24 thing with audit finding number 3.
However, it says --
25 there's a note at the bottom of the ~eorrective action.
It
{
19' BRT 1
says:
"Original corrective action was accept ed in error. "
2 I don't know what that means.
Could you shed any light on 3
that7 4
A No, I could not.
5 Q
In any event, corporate procedure 1000-ADM-7317.01 6
was issued.'
I don't know if that means in place of 7
Engineering Procedure 031 8
A There was a major rewrite of EP-031 which I 9
personally was involved with, in the April-May time frame 10 of 1984.
11 Among other things, I believe that then got into the 12 corporate numbering system.
13 The attempt in that rewrit e was to address many things 14 that were bcing identified as deficiencies in the program.
15 I suspect what was issued in that April-May time frame 16 is that number, which is a revision to the original EP-031.
17 Q
The ADM number, 1000-ADM --
18 A
Yes.
19 Q
Obviously there was a breakdown somewhere.
We 20 have documented in 1984, we have an attempt to document in 21 1982, that that procedure was not -- didn't satisfy the 22 requirements to close out those audit findings.
23 Can you tell me what happened ?
Why they were lef t open?
24 Do you have any idea now, in retrospect?
You have talked 25 sbout it.
You said you have seen the document that was
20' BRT-1 intended to go to you from Mr. Guimond?
2 A
One of the documents I did see in the 84 '85 3
time frame.
The other one I do not recall having seen.
4 This one I recall having seen.
This one I do not.
5 Q
And "this one" is -- the subject is audit 81-02, 6
and states'"audit findings 1 and 3, 5-A, 6 -A,,
10, and 7
several of the subparts on finding 11, were considered 8
open by OA."
9 A
And this was brought to my attention concurrent 10 with the attempt to revis e EP-031, and we wanted to be 11 sure that, in fact, in the revision that any outstanding QA 12 concerns were taken care of.
13 Q
This was the purpoce for the rewrite of --
14 A
No, the rewrite was primarily to address the 15 many. concerns that had cropped up as a result of the NRO AC audits.
17 o
And you don't recall this other document, the 18 subject of which is engineering procedure 031, requesting 19 that QA look at that doemnent and provide comments?
20 A
I do not recall seeing that memorandum.
21 0
Do you recall during this time frame, in 1982.
22 asking them to review the document and provide comments?
23 A
I personally would not have.
But that would 24 have been an automatic part of the review process for a 25 proc edure.
e e
a
21 BRT 1
BY HR. LA GRANGE:
2 Q
But you did not see the letter you have stated 3
you have seen, before 1984 and 1905 period?
4 A
No.
That's right.
5 Q
I mean, you were not aware of this back in 1982?
6 A
No, I wa~s not.
7 BY MR. MATAKAS:
8 O
And the same with the subject of document EP-0317 9
A That y do not recall having seen, until you have 10 shown it to me now.
11 Q
Okay.
If the natural scheme of things would 12 have been for QA to review that procedure, would you have 13 suspect ed that they'd provide you with a writt en review 14 documec.ing their review of the procedure?
15 A
Y es, I would.
16 Q
Did you ever get anything like that?
17 A
I believe I physically saw written comments on 18 the procedure prior to my signing it off in 1982 or 1983; l
19 whenever that sign-off occurred.
20 0
And that is the document that you will get us?
l 21 A
That was the one that I indicat ed should be in l
l 22 the file with the procedures.
23 Q
I notice that the audit team leader was 24 Mr. Guimond.
Mr. Guimond reviewed the initial Tech 25 Functiocs response.
But I noticed in the revised response
22 BRT 1
where the proposed corrective actions were found 2
acceptable, that was done by Mr. Magitz.
3 Do you know why that was?
4 A
No, and I forger what the time frame was.
I 5
know Mr. Guimond was out 6
Q 19847 7
A 1984.
I know nothing beyond that.
8 0
The proposed corrective action, the letterhead 9
is dated August 19817 10 A
I have no understanding of that.
11 MR. MATAKAS:
Dob, do you have any questions 12 regarding the audits?
13 MR. LA GRANGE:
No.
14 BY MR. MATAKAS:
15 Q
Did you review the December 10, 1982 NRC SER, 16 transmitting the PRC/TER7 17 A
Can I see the document?
18 Q
It's two volumes --
19 A
I did not resisw that in detailt no.
20 Q
Are y eware of what the deficiencies were all 21 about, generally?
22 A
In general terms I was aware of come 23 d efici encies.
I did not have those summarized.
I was 24 just informed of bits and pieces of that document.
25 Q
Okay.
What was your understanding of the
/
T 23' BRT 1
1 deficiencies?
Were they documentation, or were they i
- 2 deficiencies that were directed at components or i
3 documentation to qualify components?
What was your I
4 understanding of the deficiencies?
5 A
My understanding was the deficiencies were in 6
documentati'on.
l l
7 Q
What acticn did you' take to make sure -- or what 8
action did you take to address the deficiencies, as a l
9 manager, in your position?
10 A
Again, the actions taken were to set up a 11 functional group responsible for that area which did not i
12 occur when the initial submittals were being made, and t o 13 provide resources to that group to try to help address the l
14 problems.
l l
15 Q
And that group being?
16 A
The then EQ subsection under EP&I.
l 17 Q
That would have been headed by Mr. Maus?,
i 18 A
That is correct.
19 Q
Was it ever indicat ed to you that QA was having 20 problems getting the EQ section to follow recommendations?
21 A
I knew there were problems between the EQ 42 section and QA.
It was not clear to me specifically what 23 the nature of the problems were.
24 Q
Who was making you aware of those problems?
i 25 A
Primarily Mr. Stromberg.
l 4
24 BRT 1
'O Nhat was the general gist that he was informing 2
you about?
What was the heart of the problem, is what I'm 3
getting at?
4 A
Quit e candidly, our discussions were more in the 5
context of the personalities on both sides and their 6
inability to come to terms on issues, rather than the 7
issues themselves.
8 Q
And those individuals being whom?
9 A
Maus and Guimond.
10 Q
Did Dr. Long ever have any conversation with you 11 regarding the Environment &1 Qualification program?
12 A
In what time frame?
13 Q
Any time frame.
1984, mainly.
14 A
In the April-hay time frame, Dr. Long was 15 involved in discussions; yes.
16 Q
And why was it escalated to his level?
or why 17 did he get involved in it?
How did he come about to be 18 involved in the area of EQ ?
19 A
At that time frame, we were trying to upgrade 20 our files on EQ comments, and QA had retained an outside 21 consultant to help review the files which engineering was 22 upgrading.
And to the extent there were programmatic I
l 23 issues -- I shouldn't say that, not programmatic issues.
24 There were meet ' ans relative to what the status of the 25 file development in primarily the second quart er of 1984
,m
25 BRT 1
were, and the results of the QA review, Dr. Long did sit 2
in on some of the review meetings.
3 Q
Did you ever receive any direction from Dr. Long 4'
to follow or not to follow QA recommendations?
5 A
To my knowledge, no.
6 BY MR. LA GRANGE:
7 Q
Did you say that QA had retained an outside 8
consultant to assist in the review of the files?
9 A
Yes.
10 0
In what time frame was that, again?
11 A
I want to say May-June-July time frame.
12 O
of 19847 13 A
1984.
14 MR. HATAKAS:
Let's take a break for a second.
15 (Discussion of f the record. )
16 BY MR. MATAKAS:
i 17 Q
The two documents that I showed you that I have 18 identified as being from Mr. Guimond, written to yourself 19 back in 1982, one essentially addressing the inadequacies t'
20 of Engineering Procedure 031 and the second addressing the 21 open audit it ems of audit 81-02, if you would have 22 received those documents would you have taken any action 23 on them?
Would that have noted an of ficini position from 24 QA on the audit findings?
25 A
Yes.
It would have required my action.
26 BRT 1
'O What would you have done?
2
_A What I would have done in 1982 would have been 3
to info'rm the t echnical supervisor and the then procedures 4
manager to review those comments and resolve them.
5 0
So it would have been Mr. Flynn and Mr. Maus?
6 A
And Maus; yes.
7 0
Did anyone ever indicate to you -- and I'm 8
talking about anyone, mainly Mr. Doucher, Mr. Maus, or 9
Mr. chisholm -- that they were requesting assistance for 10 the EQ program in order to satisfy it?
11 A
No.
No.
12 BY MR. LA GRANGE:
13 o
was there ever any discussion about hiring 14 consultants to help them at any time?
15 A
No, th er e wa s not.
16 Now, please understand, there was a consultant hired 17 initially and their contract ran out, I would estimate, 1
18 sometime in 1981, which was then EDS.
j 19 It was af ter the termination of EDS that we set up the 20 functional group, or about the time EDS was supposed to be 21 finished; under Maus.
And. my answer really applies af ter F
22 that time.
23 Q
So, between Mr. Haus and -- let's talk strictly
(
24 THI-1, not Oyster Creek -- and Mr. Boucher taking over 25 that responsibility up until, let's say, the NRC audit in l
1
27 BRT 1
March 1984, you do not recall any discussion of going 2
outside for assistance in the EQ program?
3 A
No, I do not.
4 Q
What about inside?
In other words, from within 5
the organization, adding more resources?
6 A
There was no such discussion.
7 Q
okay.
I would like to show you two other 8
documents.
These are GPUN letters to NRR.
The subj ect. is 9
"Environmental Qualification of Electrical Equipment.,
10 THI-1."
11 The first document is dat ed May 20, 1983, let t er number 12 5211-83-157: the second document is dated February 10, 13 1984, letter number 5211-04-2038.
14 I ask you to take a look at them and tell me if you 15 recognize those documents?
16 A
Yes.
I recognize both documents.
17 Q
Did you have any input into either document?
I 18 A
I had no input to either document, although I 19 believe on the first document I would have reviewed that 20 prior to its having been issued.
21 Q
The May 20th document?
22 A
The May 20 document.
4 23 Q
I have attached -- attached to these documents, 24 I have the review sheets, I believe?
25 A
Yes.
In fact my signature is on one of the I
(
28 CRT 1
review sheets for this document.
2 Q
on the February 10 it's signed, for Tech 3
Functions, by Mr. Maus?
4 A
I recall this.
I do not recall if I saw this 5
before it was issued.
6 0
Okay.
Do you know what these documents were a 7
response to?
8 A
I know what the documents were in response to; 9
yes.
10 Q
okay.
The May 20th was in response to 50.49:
11 and --
12 A
This was to close out the TER, I think.
13 Q
As a result of an NRR request on the October 5th 14 meeting?
4 15 A
Yes.
16 Q
You say you didn't review the February 10th 17 document before -- you don't recall reviewing it before it 18 was submitted?
19 A
That's correct.
20 Q
okay.
Specifically, the sentences that I have 21 outlined in green.
Basically what it boils down to is the 22 statements in both these documents state that GPUN's 23 position that they are in compliance with 10 CFR 50.49, 24 the one document it refers to, DOR guidelines -- the point 25 being that both 10 CPR 50.49 and the DOR guidelines
BRT 1
require auditable and document ed files to support.
2 qualification?
3 A
Yes.
4 o
With what you have lesrned in subsequent audits, 5
or audits subsequent to these two documents, do the audits 6
and inspections support, those stat ements?
7 A
Clearly the audits the NRC conducted in -- I 8
want to say March, June, July --
9 Q
March, I think.
10 A
indicat ed that the files were not auditable 11 as the rule -- they interpreted the rules to require.
12 Q
And, in fact, the 1981 internal audit s r.a t ed 13 essentially the same thing.
Do you disagree with that?
l 14 A
No.
15 Q
At th e time t. hat you reviewed the May 20th 16 document, and your subsequent review of the February 10th 17 document Liter it was submitt ed, did you recognize those 18 statements as being false statements?
l 19 A
1 did not recognize this as being a false 20 s ta t ement.
I got involved when this one -- probably in 21 the April-May time frame,, hen we were trying to upgrade w
22 the files.
23 Q
April 19847 24 A
1984.
25 Q
Af t er the UCS petition had come out ?
S
30 CRT 1
'A Yes.
2 Q
The documents that you stated that you did not 3
become involved with, you were referring to the FWbruary 4
10, 1984 document which you became involved with after the 5
UCS petition came out?
6 A
Yes.
7 Q
And on the May 20th document, you did have a 8
review function on that document?
9 A
Yes.
10 Q
on the May 20th submittal, you obviously signed 11 as final approver for Tech Functions.
Did you talk with 12 anybody about this document before signing it?
13 A
I'm certain I would have to talk with saaebody l
14 before signing it; yes.
13 Q
Who would that have been?
16 A
Probably it would have been either Chisholm or 17 Maus and the licensing engineer, which would have been 18 Harding.
19 Q
Do you remenber any specific conversation in 20 this case?
21 A
No, I do not.
22 Q
Rave you talked to Mr. Maus about either of l
l 23 these statements since this time?
24 A
No, I have not.
25 Q
why was Mr. Maus relieved from his position?
31 BRT 1
1 A
Hr. Maus was both from a management standpoint 2
responsible for this function;, and it was clear he did not l
3 do an a*dequate job -
i 4
5 1
7 l
8 t,
b i
1 12 o
was he disagreeing or agreeing with the findings?
13 A
Disagreeing.
14 O
In your opinion, do you feel that he felt that 15 he had the files in order and thought that the i
16 qualification was there?
l 17 A
Y es, sir.
l l
18 O
Why is Mr. Wilson now signing correspondence to i
19 WRR regarding the environmental qualification programs do i
20 you know?
21 A
I really don't know.
l 22 MR. MATAKAS:
Do you have any further questions?
23 MR. LA GRANGE:
Yes.
24 BY MR. LA GRANGE:
25 0
Are you aware of any audit by OA and Tech 679p W
BRT 32 1
Functions of the EQ files, possibly around the summer of '837 2
.A No, I ' m not.
3 BY MR. MATAXAS:
4 Q
Let me add a little bit to this, on March 8, 5
1984, Mr. Maus met with the NRC and had indicated -- this 6
was a transcribed meeting -- and indicated that QA had 7
recently looked at the EQ files, and in our conversation 8
with him he mentioned he thought it was in the summer of 9
1983.
And there's -- I have asked for all the audits and 10 there's no audit for that time period.
11 I was wondering -- and he didn't call it an audit.
He 12 called it a look-see, or a review, or something like that.
13 I was wondering if you were aware of what he was talking 14 about?
?
15 A
That could have occurred.
I just wasn't aware 16 of it.
18 Q
Did you ever get any feedback, either verbal or 19 written, from Mr. Maus or anyone else, characterizing the 20 meetings in Bethesda on October 5, 1983, or March 8, 1984 i
21 where the TDR deficiencies were discussed?
22 A
I did not recall any a3 scific discussions with j
i 23 Mr. Maus.
One of the meetings -- and I believe it might
[
24 have been the -- I'm sorry, on both those cases:
No.
25 There was a meeting that deTit with the Ucs petition, 3
i y
,w--
+ -. - -
33 BRT 1
where one of the other participants did talk to me about 2
the EO aspects of the discussion.
3 BY MR. MATAKAS:
4 Q
I don't understand that.
5 A
As I remember. there were some discussions --
6 I'm not too sure whether it was with NRR or the 7
commissioners -- relative to EFW, which included the EQ 8
issue, and I did get feedback from the one mechanical 9
engineer who was down there.
10 Q
Feedback in regard to what?
11 A
Negative perception as to the effectiveness of 12 the EQ discussion.
13 BY HR. LA GRANGE:
14 Q
That engineer was not directly associated with 15 the EQ program?
16 A
No, no.
It was just an observation.
l 17 BY MR. MATAKAS:
18 Q
I would just like to go over a f ew things.
I'm 19 really concerned -- I don't know if you can see my concern 20 or not -- about the review function on both these 21 documents and the -- essentially the 1981 internal audit, 22 finding the same programmatic problems and making 23 recommendations to resolve then that were found in later 24 NRC audits and inspections, and FRC inspect ion review, 25 whatever you want to call it.
And we have the two
34 BRT i
i documents in 1982 that were draft ed, which would have went 2
to you.
They were addressed to you.
And you say you 3
don't -- have never reviewed those documents nor were the 4
contents brought to your attention; is that correct?
5 A
With the exception --
6 NR. MATAKAS:
Why don't we take he a one--minute 7
break here.
8 (Dir.cussion off the record. )
9 MR. MATAKAS:
We went off the record there 4
r 10 because one of the individuals that work for i
11 Mr. Croneberger had brought some documents over that we 12 wanted to take a look at.
13 BY HR. MATAKAS:
14 0
What we were talking about is the concern we 15 have with the false statements and the documents that we r
i 16 have in our possession that may have averted -- could have 17 possibly averted these statements and brought the problem 18 to light much earlier.
I i
19 I would like to ask you again, just to make sure I have 20 these covered, those two documents, prior to 1984, or the L
21 contents of those documents, were never brought to your f
22 attention?
i 23 A
To my knowledge that is correct.
i 24 Q
And you don't recall asking anyone from QA 25 specifically to review Engineering Procedure 031 as it i
I i
35 BRT 4
1 would pertain to audit 81-02?
2 A
That is correct.
3 Q
Do you have any idea where this may have fallen 4
through the cracks?
In other words, these audit it ems 5
staying open for three years, and in the interim 6
statements being made that the files are qualified?
7 A
It's my impression, in retrospect, that the 8
issuance of EP-031 -- and the original issue was 10/2/81 9
did close out the finding.
And I'm not aware until the 10 major effort in '83 that that was not interpreted to be l
11 the case.
12 Q
And then the individual audit findings --
13 specifically there were three areas in subsections of 14 audit number 11 -- were you aware that-they had remained I
15 open?
16 A
Would you show me ths ones you rifer to?
17 MR. MATAKAS:
Sure.
Let's take % break and I'll l
18 get them out.
{
19 (Discussion off the record.)
20 BY MR. MATAKAS:
l 21 Q
The April 4th memo essentially states findings 22 11.4, 11.8, and 11.14 A and B are open as of this time.
I 23 A
I do know that in the time frame of April 1984 24 it was brought to my attention that there was concern 25 about the acceptability of the B&W files which we were
36 j
BRT l
I relying upon.
This deals with finding 11.8.
And I was l
2 involved with sending an engineer plus a QA auditor down 3
to Lynehburg to review those files, prior to one of the NRR 4
audits.
5 The other two items I am unaware of.
3 Q
Back when you signed for audit finding number 11, 7
did you assign someone to correct those deficiencies?
8 A
Maus and Chisholm.
9 Q
Did he ever indicat e to you that it had been 10 correct ed ?
11 A
I'm unsure.
12 O
Was it around this time that the document that 13 we had previously talked about, the letter to you from i
14 Mr. Guimond back in August of 1984, that this let ter was l
15 brought to your att ention?
1 16 A
Yes, that is correct.
17 Q
It has the same findings that were open:
11.4, 18 11.8, 11.14.
19 Who brought this to your attention?
20 A
Either Mr. Kazanas or Mr. Stromberg.
i 21 Q
Why would they bring it to your att ention?
22 A
I believe they brought it to my attention 23 because of the activities I had under way to, in a major 24 way, revis e EP-031.
And I also issued, via memorandum, 25 more detailed guidance on how the file should be i
.___y
37 BRT I
structured.
2 And it was in support of that, in my recollection, that 3
they gave me that menotandum.
4 Q
I have a nemorandum dated June 29, 1984, from 5
yourself to Mr. chisholm.
Is this the memorandum that you 1
6 are talking about?-
7 A
Yes, it is.
8 O
Did you ever writ e any other memoranda regarding 9
documentation of the EO files, back in '82 '837 10 A
No, I didn' 11 MR. MATAKAS:
I would like to take a break just 12 to look over these documents that have been brought in, 13 and.then we'll go back on the record and discuss esem.
14 (Discussion off the record.)
l 15 itR. MATAKAS:
While we vere off the record we 16 were reviewing documents that pertain to Engineering 17 Procedure 031, which is also known as procedure 18 1000-ADM-7317.01, and we have been looking at comments on 19 revisions back to late 1983.
I have a memorandum from 20 Mr. Guimond, dat ed December 6, 1983, which lists several 21 comments where he feels procedure is not ad equat e and i'
22 considers it to be an open item.
23 BY MR. MATAKAS:
24 0
I would like to you go ahead, Mr. Croneberger, 25 and discuss that.
l
38' TRT 1
A These comments were identified to me as all 2
being resolved as it related strictly to the EQ issue, but 3
not resolved as it related to certain issues on 4
classification of hardware or software, which related to 5
the IE Bulletin dealing with the Salem ATWS event.
6 I subseq'uently had discussions with Mr. Kazanas 7
concerning that the Salem ATWS event should be decoupled 8
from EO, and my discussions with Mr. Kazanas were detailed 9
in the subsequent memorandum from him to me, dated 10 December 30, 1983.
11 As a result of that communication I did sign of f the 12 proc edut e, which was 1000 ADM-7317.01, revision 0, both in 13 concurring and because of Mr. Wilson's absence; I signed l
14 off that procedure to issue it.
15 This is a date which is different than I refl ect ed in 16 my earlier comments.
17 O
And the date is January 18, 19847 18 A
Yes.
19 0
When did you think you signed it before7 20 A
I thought I said
'83.
21 O
We have asked Mr. Flynn to bring over earlier 22 comments as they pertain to Engineering Procedure 031, so,
/
23 until be brings those documents over concerning the 24 1981-1982 time frame, let's go ahead and take another 25 break.
39 BRT 1
(Discussion off the record.)
2 HR. MATAKAS:
We have reviewed the earliest file 3
on Engineering Procedure 031, and we have an int eroffice 4
memorandum, GPUN s ervice, dated January 23, 1981, which 5
indicat es that - a note on the bottom of this document 6
I believe that's your handwriting, Mr. Croneberger --
7 where you refer to a procedure that is needed for i
l 8
controlling review approval and record-keeping on 9
Environmental Qualification documentation.
l 10 BY MR. KATAKAS:
11 Q
So this, evidently, kickei off the procedure; is 12 that correct?
l 13 A
Yes.
"h.e original memorandum to me was l
14 generated by an electrical engineer who was involved with 15 EQ activities, expressing concern, and as a result of his 16 concerns I so advised the procedures group, i
17 Q
But we h. ave no -- nothing in any of the files l
18 which indicate that the procedure was accepted by QA; is l
19 that correct?
20 A
The only relevant correspondence I see here is 21 that from the QA emgineering manager in November 1981, 22 that he apparently was satisfied with the responses to his 23 comments on EP-031.
24 O
And he reserved the right for a final review 25 when it was issued 7 i
f
40 BRT 1
A Yes.
2 O
But there's no indication that this, in fact,
3 resolved the audit comments in 81-027 4
A No, sir.
5 O
Then we talked about this earlier in the 6
intcrview and you had mentioned that you had thought that 7
QA had signed off on the procedure, in eff ect giving their 8
blessing that it did resolve the audit comments; is that 9
correct?
You had thought that that happen ed?
f 10 A
I had thought that had been the case; yes.
11 Q
I think you mentioned that Mr. Maus, maybe, had 12 informed you of that?
13 A
He may have.
14 MR. MATAKAS:
Do you have anything else?
15 BY MR. LA GRANGE:
16 Q
Prior to the NRC's first audit on March 20-21, 17 1984, did you ever personally icok at EQ documentation or 18 discuss with Mr. Maus or Mr. Chisholm or Mr. Boucher the l
19 appropriate documentation that should be in those files in 20 order to demonstrate qualification?
21 A
I did not personally look at any of the files; l
22 and my understanding of what should have been in the files 1
t, 23 would have been that which was conveyed in the procedure 24 which was issued in January of
'84.
l 25 l
l t
41 CRT 1
BY MR. MATAKAS:
2 O
January of '84?
3 A
That was that version, fairly official version 4
which I had signed out for Mr. Wilson.
5 O
But that was not accepted until June 1984 as 6
closing out those audit items.
Wh[isthat?
Is that 7
because it didn't come out in final form until 8
approximately the June time period?
9 A
No.
It came out in January.
It was apparent, 10 after I became aware of the NRR concerns on the files, 11 that that procedure was very inadequate, and that was in 12 the April-May time frame.
So, as a result of that I 13 personally became very involved with preparing a revision 14 to that procedure, which was finally issued in, I believe, 15 July -- June I think it was.
j 16 O
June 1984?
l 17 A
Y es.
i 18 Q
And tha t 's wha t clos ed out 19 A
As far as I was concerned, that addressed the NRR l
20 concerns; and QA had indicat ed at that time that that l
21 addressed the concerns of the OA audit, the old QA audit.
22 0
81+027
/
23 A
Y es.
l 24 0
But you were not aware that this audit, 81-02, 1
l 25 had remained open during all this time period?
l l
BRT-42 1
A No, I did not..
2 BY MR. LA G RANGE :
3 Q
With regard to the May 20, '03 response to 50.49, 4
saying that the equipment is qualified in accordance with 5
the DOR guidelines, what would you have thought was in the 6
files at that time to support the qualification of the 7
equipment?
8 A
I thought that appropriate test documentation or 9
analysis existed in the files for the items of equipment 10 which were id enti fied.
11 Q
Why did you think that at the time?
12 A
I'm sure the impression was conveyed to me by 13 Mr. Maus and/or Mr. Chisholm that such documentation 14 existed.
i 15 BY MR. MATAKAS:
16 Q
Oh, one question I had on the February 10 17 submittal, there are statements in the attachment 2 to th e 18 February 10 submittal, such as the ASCO solenoids, stating 19 they would be replaced in June 19G5.
20 HR. LA GRANGE:
'84.
21 BY HR. MATAKAS:
22 Q
'84.
And in a couple of other areas they are i
23 talking about work to be done in the future.
24 Is that consistent with your knowledge of the 25 requirements of 50.497 Is that consistent with your l
l
-aw-e n
,---n--
--r s...,_,
--a
-g
43 BRT 1
knowledge of 50.49 allowing you to make a statement that 2
you are qualified, and at the same tin 4 make the statement 3
that you realize that. some things are not qualified and 4
you can replace them in the future -- with qualified 5
solenoids, in this case?
6 A
Again, I was unaware -- I was unaware of this 7
letter until the April-May time frame.
Certainly I was 8
aware at that time, as we identified deficiencies, that 9
they had to be corrected or JIOs put is place --
10 Q
JCOs?
11 A
JCos -- prior to being able to make this kind of 12 a stat ement.
But I'm not in a position to really draw any 13 conclusions from the February 10 letter, which I hadn't 14 seen.
15 BY HR. LA GRANGE:
\\
l 16 Q
Prior to the NRC's first audit on May 20-21, 17 1984, did you spend very much time interfacing with l
l 18 Mr. Chisholm or Mr. Maus?
or were you very involved in 19 the EQ effort?
20 h
My primary involvement was to assure that we had 21 some awareness of what was going on out in inc :s t ry, via 22 organizations such as AIF; and to assure that to the-23 extent there were meetings or seminars on the EQ subject, 24 people such as Haus had the opportunity to attend.
And 25 then to get some report back on what the meeting content
22943.1 44 BRT 1
was.
2 BY MR. MATAKAS:
3 Q
Mr. Croneberger, is there anything you would 4
like to say, any stat ement you would like to make before 5
we conclude this interview?
6 A
No.
7 O
Have you appeared here today voluntarily?
8 A
Yes.
l 9
O Have any threats been made or have any prunises 10 been made to you?
11 A
No.
12 MR. HATAKAS:
Okay.
The time is 15:38.
"hi s 13 will conclude the interview.
14 (Whereupon, at 3:40 p.m., th e interview was 15 concluded.)
16 1
17 i
18 19 r
l 20 l
i 21 l
22 5
23 24 25 l
O CERTIFICATE OF OFFICIAL REPORTER This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: INVESTIGATIVE INTERVIEW OF:
g DON K. CRONEBERGER DOCKET NO.:
PLACE:
PARSIPPANY, NEW JERSEY DATE:
WEDNESDAY, MAY 1, 1985 were held as herein appears, and that this is the original l
transcript thereof for the file of the United States Nuclear Regulatory Commission.
l t
'A s.,
(sigt) v'
'IftdM[
s (TYPEp)
Joel Breitner Official Reporter Ace-Federal Reoorters, Inc.
Reporter 's Af fillat2.on
i (U/
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/~- - P GPU Nuclear Corporation NggIgf I/* (
Post Off.ce Bon 480 J
Route 441 Soutn
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'e'cw". Pe nnsyh a nia i 7M -
717 944-762:
TELEX 84 2356 W'.ter s Duett Dial hamte-February 10, 1984 5211-84-2038 Office of Nuclear Reactor Regulation Attn:
J. F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U. S. Rrlear Regulatory Commission 3,,.4,..,,,,
n.
r..
.e. c.e
Dear Sir:
Tnree Mile Island Nrlear Station, Unit 1 (TM1-1)
Operating License No. DPF-30 Docket No. 50-289 Environmental Qualification of Electrical EgJipment On October 5,1983 re; resentatives of GDUN anc tK met to discuss outstan:ing items of the fF.C SER/TER catec Decenber 10, 1982 0, the suoject.
By letter catec October 17, 1983 GPJN con.itter to provice a restlution of eat-ite-an c-.i'.'e."..'.'c-*..'.- '.. -.
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l EQUIPMENT QUALIFICATION DEFICIENCIES (Categories I.B II.A and II.B)
TER Deficiencies Equipment Description 1 2 3 4 5 6 7A 7B 7C 70 7E 8 9 10 11 12 13 14 15 16 1
Limitorque MVA SMB xxx Motor valve op.
2 Limitorque MYA SMB2 xxxx 3
Limitorque MVS SMB3 xxx 6
Limitorque MYA SMB000 xxx 7
Limitorque MVO SMB000 xxxx 10 Limitorque MVA SBJ xxxx x
11 Limitorque MVA SMB0 xxxx x
14 Limitorque MVA SMB00 xxxx x
15 Limitorque MVA SMB000 xxxx x
26 ASCO Sol. Val LB8210C94 x
Solenoid valve 28 ASCO Sol. Val 8300C68G xx 29 ASCO Sol. Val 8300C68G xx 32 ASCO Sol. Yal LB83146 xx 45 Westinghouse Frame 182T xxx x
Motor 46 Westinghouse HP700 xxx x
49 Westinghouse HP250 xxx x
50 L'estinghouse HP350 xxx x
51 Westinghouse HP450 xxx x x x x x x 53 Victoreen x
Display Rad monitor 57 Static "0" Ring xx x
x x x x Press switch 60 Bailey RP1211C x
F/P Transd.
66 NAMCO D2400X x
Lat. switch 67 NAMCO D1200G2 x
xx 71 Fisher Gov. 304 x
a 7S Fcxber EllGH2 xx x trans x
79 Foxbore EllAM x
x 51 Fcxecro EllGMSAEl xx x
92 Fcxooro E13DMX x
96 GEMS LS800 x
Level switet 106 Kerite cable x
107 Continental wire x
108 Raychem cable splice x
109 GE penetration F01 xx xx 111 GE terminal block EB25 x
114 Conax connector SA1000 xx 115 Conax connector PLl432 xx 116 GE Thyrector CR2095100DJA x
118 Limitorque MYA SMB000 xxxx 119 Licitorque MVA SMB00C xxx 120 Limitorque FNA SMB000 xxxx
l QUALIFICATION DEFICIENCIES
SUMMARY
- CATEGORIES IB, IIA. IIB Total t of NRC requirement Deficiencies NRC Requirement Deficiencies Deficiencies =120 1
Documentation 20 7E steam exposure 2
2 Similarity 30 8 spray 1
3 Aging evaluation 24 9 submergence 0
4 Qualified life 21 10 radiation 1
5 Aging program 0
11 test sequence 2
6 Aging simulation 5
12 test failure 0
7A Peak temperature 5
13 function test 0
7B Peak pressure 2
14 instrument accuracy 0 7C Duration 2
15 duration margin 2
70 Profile envelope 3
16 margins 0
l i
Attachment II 1
Equipment Qualification Deficiencies / Resolution (Categories 1.0, II. A, and 11.8)
[
I.
Specific A. Limitoroue Motor Operators o When necessary GPUN has performed a plant walkdown of Limitorque motor for model and serial number (for those required for hot shutdown).
o GOUN has qualified in containment Limitorque operators required to be qualified for hot shutdown for high temperature / radiation including limit switches, brakes, notors, and lubrication, o GPUN central file contains all correspondence and test reports required to document qualification.
O SCEW sheets will be revised to refle0t additional information in the uodate schedule for submittal in the fall of 1984,
- 1. TER Itecs 1, 3, 118-120 [WDG V-3; DHV-l&2; CAY-13; MUV-2; WDLV-303).
Limitoroue models SMB/SMS-3, SMB-000/SMS-00 are shown to be similar to mocels tested / age analyzed / qualified life in Limitorque Ger.eric Report 8005S Section 4.1.4.
- 2. TER Iter 2 [AHV-1)
LimitorcJe mocel SMB-2 is shown to be similar to models testecea;e analy:e:/oualifiec life in Limitoroue Generic Report B0058 Section 4.1.4 Din; noter brake mocel 6-71010-6 is cualifie by similarit, tc n:cel 6-63309-50 wnich was tes:ec as cescribec in test reo:::
63019E ' -62232-01).
Both mocels are constructe: of similar esterials an; rate for accroximately the same torcues ou: ciffer only la size.
- 3. TEF Itens 657 [CFV-2&3; CAV-1, 2, 3 &4; ICV-2)
Limiteroue model SMS-000 is shown to be similar to mocels l
teste:/ age analyzed /oualifiec life in Limitorque generi: reper:
B0255.
Ork-253 which are recuired te f unction in a LOC; are locatec in the Intermeciate Bldg. (rild environment for LOCc) an0 are cualified for a harsh environment.
These CF valves will be tnerefore delete from the Master List.
1 l
4 l
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-2
- 4. TER Items 10, 11, 14 & 15 [FWV-5; EFV-2; FWV-92; & EFV-1)
Limitorque models SB-3/SMB-0/SMS-00/SMS-000 are shown to be similar to models tested / age analyzed / qualified life in Limitorque generic report B0058. Limitorque has developed a thermal lag analysis which shows that the operator will operate through the Intemediate Bldg. MSLB temerature spike of 3260F.
B. ASCO Solenoid Valves h j o There are no ASCO solenoid valves recuired to be qualified f l//
inside containment.
[
o GPUN central file contains all correspondence and test reports required to document qualification.
o SCEW sheets will be revised to reflect additional information in the update scht.1uled for submittal in the fall of 1984,
As described in GPUN letter dated August 2, 1982 (82-163) GDUN has removed the EFW 1atch signal from the EW control valves.
There-fore this solenoid is no longer required to be qualifiec an0 was celeted fror the Master List but the SCEWS were not removed.
Inis will be acco@lished in the fall 1984 update.
F."J-161 ;
.I (SV 1&O) MSV-13/
m AS'O solencics will ba reciace: witn cualified ASCO solenci:s rv
~'
3;m 198L.
Tneref ore, ASCO oJalif1:atiCn test reDOTts A006735 a ~.:
A052167E/TF apply.
C westinomouse Motors m
- 1. TEP ltens 45, 4, 49, 50 &f51 (MJ:-4; M P -1; B55-1; DrF-1, E :-2)
'V gu
. Motorettes (stators) testin; incluce: silicon ru::ber insulatec f},it s /,t leac wires.
Aging analysis on the assently showed a 40 years
'i life ex ectancy.
s, f.-
- c. Bearing Analysis sno ec that tne bearincs could witnstan a i,
LCCAMELS (ref. GDUN calculation 110lX-5350-000 anc GoJN me : R.
y' W Scragg to D. Slear catec 5/14/81).
10
- . M ter Lucrication (Exxon Terisstic 32) is controlle: witnin the preventive maintenance crxram anc is rate 5 by Exxon at a racia-tio-le.el Of 106 ra:s wit; a ' lash Deint of 410;r.
(T91s lucricant is not use: on MS -4 w91cn nas sealec Dsarings.)
i
- d. Qualification of lead splices is controlled within the correc-
/
tive ma.ntenance program by GPUN procedure 1420-Y-15.
OFP-2 was analyzed in hestinghouse Report dated 1/81.for motor insulation life analysis which envelopes the thernal lag peak for the Intermediate Bldg. of 326cF.
Similarity for the above listed motors is established by Westinghouse report WCAP 8754 Rev.1 Section 2.
D. Victoreen Radiation Monitors
- 1. TER Item 53 [RM-A2; A5, A6]
These radiation monitors (RM-A2, S&6) are indicators of LOCA and are located outside containment (subject to a mild environnent).
They are not recuired for a main steam line or feedwater line break.
These SCEW sheets will be celeted.
E. Static 0 Rino Pressure Switch
/(
- 1. TER Item 57 [FW Iso. Press Switch (600-607))
/
^
These switches will be replaced prior to June 1984 by a qualifiec pressure switen.
No justification for continued operati0n is lequired since the plant will not go critical prior to restart an0 therefore no nuclear heat will be generated.
F. Bailey E/F Converters
- 1. TER Ite-60 [MSV-4]
T e AD *" s a re n0: reavire: fer License: (not) snuto:vn an: are there+cre not recaire: te De cualifier.
Press.re contr:1 is mai taine: in hot shutco.m via the MS sa'et) valses.
G. NSVCO Limit Switemes
- 1. TEF Iter 66 & 67 [ AGV-6: MSV-13]
Uncer LOC an; MSLE suf ficient flow is pr:vice: to tne OTS3's ty a single noter crive Erh DJn.
(See GPUN letter cate: 3/22/53).
The stean ariven Een pump is only recuire: for station blackcut wnien coes not produce a harsn environment. Failure of tne limit switen (MSV-6) with MSV-6 open may result in initially overf ee:in; the OrSG's w'ich could be recured in9eciately (manually) base: o-oualifie: EFe flo anc OTSG level instrumentation.
Tnerefore tne 0 > syste will function and the 00erater will not be misle.
Failure c' the limit s iten (MSV-13.' res.its in tne inatility ::
moniter valve position an: nay result i-lif tin; relief s out i
because of qualified D:W flow and OTSG level this will not mislead j
3.
the operator.
These switches will be deleted from the Master List.
H. Fisher Limit Switch
- 1. TER Item 71 [MSV-4)
The valve position indication for the atmospheric durp valves will be deleted from the Master List (see discussion of item F).
I. Foxboro Transmitters
GPUN possesses original purchase orders which are part of the QA file which refers back to a plant tag number or vendor letters which are part of the EQ file.
GPUN calculations were baseo on a B&W evaluation of Class 1E In Containnent Controls and Instrumen-tation (77-11207001-00) dated 7/81, which is cart of GPUN central file.
The Ell series transmitters were purchased prior to 1974 and were qualified by DDR Guicelires which do not require sequence testing.
The time duration listec in the SCEWS indicates qualification for 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> which exceeds the 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> (104 sec.) of the profile (Items 78 6 81).
Item 79 is located in the Aux. Bldg. and is not subject to as severe an environment.
- 2. TER itec 93 [RS E; rie,)
The utility rep;rt (Wyle 45592-4/Macel E13 DMv.) on Fcx0erc trans-mitters cc unents the qJalification of this transnitter.
C. GERS Li-!: Switch
- 1. TER Item 98 [WDL LS-ll6)
The Reactor Builcing Sunc Level instrunent has been upgrace; in accorcance with NUREG 0737 Item II.F.1 and cualification will be cocunentec in a revision to tne SCEw sheets in fall 1984 Cons e-ouently, the limit switch of item 96 will be celeted.
II.
Generic A. Kerite Cable
- 1. TER Item 106 GDJN n;s in ce tral file tne Origiral Sill Of vaterials w-ir-co:uments the acclicable test report for the Kerite Cable.
5 I.-
B. Continental Cable
- 1. TER Item 107 GPUN has in central file a letter from the vendor which establishes similarity between the cable tested and that installed at THI-1.
The lots are traceable through purchase orders which are part of our QA files.
C. Ray Chem Cable Solice
- 1. TOR Item 108 GPUN has reviewed the applicable Ray Chem Test Reports and deter-mined that it is applicable to the splices at THI-l because the material composition is the same for all Raychem splices.
D. GE Penetration
- 1. TER Item 109 GDUN had reevaluated the penetrations installed at THI-1 and have dettemined that they are all above flood level; and that the hyperlon paint is innune to caustic spray.
GPUN has also performe0 an aging analysis on the penetrations.
/
- 1. TER Iten 111 GPUN has determinec that these terminal blocks were teste: tc AM:
110-11004 Dace 3.
The SCEh sneets will ce revisec tc refle:: t r.i t change.
F. Conaw Conne:ters
- 1. TER Item 114 & 115 GDUN has revievied the Conax Connectors anc determined that they are pressure seal modules cescribed in PL-14-BL anc IPS 409 an: 325.
G. GE Tnyrectors
- 1. TER Item 116 The GE inyre::crs have been replaced by General Semi Conca::ct Ei Polar Transien: Voltace Suppressors (Square D) (which are QJall-fled).
A new SCEW sneet will be sent in our fall 1994 sub-ittal.
i i
e Equipment Qualification Deficiencies / Resolution I
(Category 11.C)
I.
Qualified Life A. Limitoroue Motor Operators TER Items 5, 17-22, 24 [BS-V-1, 2, 3; DH-V-3, 4, 5, 6, 7; HU-V-12, 14, 16, 36, 37; NS-V-35)
Qualified life is established in Limitorque Generic Report B0058.
B. ASCO Solenoid Valves TER Item 33, 36, 39, 40 [SV/AHV-1A; SV/CAV-2, 5, 189; SV/ ICV-6; SV/HUV-3,26; SV/WDL-V304, V334, V535)
The qualified life, based upon an Arrhenius Analysis, is shown on tne SCEW sheets.
C. Static 0 Rino Switches TER Item 56 [PS-672 through 675)
The cualifiec life is established by the cdlculations listed On tne SCEh sheets.
The basis for these calculations is an Arrnenius Analysis.
C. Souare D Switches TER Items SS & 59 [PS-253, 284, 286, 287, 289, 290, 480 (765);
Ine M.PS 480 (745) (Item 56) will be replaceo Oy cualifiec pressare swit:hes by June 1984 All other PS liste; at ve are non cualif e:
for 40 years cue to material replacement which will be reflecte: in our fall 1984 suomittal.
E. Nace: Snac Locks Switeres TER Items 63, 64, 69 [(LS4, LSB) AHV-1A; (LSA, LSB) CAV-2; (LSB, 33)
ICV-3; (LS4, LSB), HU-V-3,18, 20, 26; (LSA, LSB) KDL-V304, V534, V5352 The material evaluation fcr a 40 year life of Buna N is corre:: Dase:
upon ar Arrnenius Analysis.
The conflicting temperature cata in tne TED coes not inclu0e an Arrhenius Ar.alysis and tnerefore canno te evaluate 0.
F. Micro Switches TER Item 72 ((LSA, LSB) CAV-19, 20, 189; (LSA, LSB) WDG-V4]
Same resolution as E above.
II. Replacement Schedule The replacement schedule for all environmentally qualified equipment at TMI-l is included in the computerized Preventive Maintenance Schedule or Licensing Action Item List (for transmitters).
The replacement schedule is not included on the SCEW sheets.
The SCEW sheets specify qualified life on sub components or materials only when that life is less than the plant design life of 40 years.
I I
l i
,. Eauipment Qualification Deficiencies / Resolution (Category IV) 1.
Generic This documentation was not requested by the Franklin Research Corporation f rom G3UN in any of their requests for documentation. GPUN has provided all of the documentation requested as documented in GPUN letters dated March 2,1982 (E&L: 4062/82-052), March 24,1982 (5211-82-067) and June 25, 1982 (5211-82-155).
All documentation is contained in the (PUN central file.
II.
Specific A. Ross Solenoid Valves TER Item 42 [SV/HJV-16, 20]
See I above.
B. GE Motors TER Item 44 [( A, B, C) HU-P-2, 3)
The TER states that these motors are considered to be qualifiec.
C. GE Motcrs TEP Item 47 [(A, B, C) AH-E-1)
See I above.
C. Res990Jnt Dressure Ira"snitters TER Iter 76 [(Pil, 2) RC3A, 6)
The SCEW sheets will be revised to list specific (instead of surr.sr> )
cualification reports ano change the cualifiec life from 40 to 10 years.
Revise: sneets are s:nedaled for a fall of '6 suonittal.
E. Barton D/P Transmitters TER Item 77 [Drb FI-S-77, 75, 79)
These flo switches are for the EFh pumo recirculation line.
Per our discussion in G0JN letter catec Feoruary 4, 1983, the valves are nc.
lo:Re0 o;e..
Iberefere, these s. itches.ill be celete: fic-ins Master List ir the f all of 1934 submittsl.
r-
.p.
F. Bailey Level Transmitters j
TOR Items 85, 88 [(LT1, 2, 3) RCl; (LT4) SPlA, B]
Report is on file at the NSSS vendor, B&W.
G. Bailey Level Transmitters TER Item 87 [(851) DPT1, 2; BS3-LT; BS5-LT]
- 1. FRC disagrees with GPUN's analysis that this display instrunenta-tion need not be environmentally qualified. FRC did not have the documentation necessary to make this conclusion.
- 2. See I above.
H. Rosemount Temoerature Transmitter TER Items 90, 91 [(TE2, 3) RC4A, B: (TEl, 2, 3, 4) RC5A, B]
- 2. The cualified life on the SCEW sheets will be changeo from 40 to 10
- years, J. Stanwick Terminal Blocks TER Item 113 [Connon Item)
Qualification is base: uoor a report that is croprietary to the Dew Power Co.
Only sur.ary inf omatier is availatie to GDUN.
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February 10, 1984 5211-B4-2038 Of fice of Nuclear Reactor Regulation Attn:
J. F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U. S. Nuclear Regulatcry Ccm-ission C. ~.:.:.e Mc
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Dear Sir:
Three Mile Islano Nrlear Station, Unit 1 (TMI-1)
Operating License No. DPF-SO Docket No. 50-289 Environ. ental Qualification of Electrical Ep.fipnen:
On 0:tober 5,1983 representatives of GouN anc NT met to discuss outstan:ing ite s of the fE SE./TER cate: Dec e.-c e r 10,1952 n tre sucject.
By le:ter cate: October 17 1983 GPUN c m.i:te: to trovice a resciution o' ea - !te-an c 0.'s *s.* ".. - *. 4 ^. '. ". -. o.*..i n..'a..
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717 944 7621 TELEX 84 2356 Writer"s Due:t Dial Numter Mry 20,1983 5211-83-157 Office of Nuclear Reactor Regulation Atto: Harold A. Denton, Director U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Environ:nental Qualification of Electrical Equipment (10 CFR 50.49)
In accordanca with 10 CFR 50.49(g) and h'RC letter dated March 30, 1983, CPUS is supplying the following infor=ation to identify the electrical equipment 1mportant to safety within the scope of Section 50.49(g) that is already qualified, and to submit schedules for environmental qualification or replacem nt of the re=aining equipment that is important to safety as defined in 10 CFR 50.49(b).
(1) Safety Related Electrical Equipment GPUN letter dated August 28, 1981 (L1L 238) in response to IES79-01B lists all the safety related electrical equipment which is required to be and which is already qualified.
The additional information we submitted in our letters dated May 3, 1982 (5211-82-101) and May 16, 1983 (5211-83-076) (hTFIG 0737 items), support our conclusions that the components listed are qualified in accordance with DOR Cuidelines dated November, 1979.
Your letter dated December 10, 1982, contained TMI-1 TER vhich indicated some apparent equipment qualification discrepancies.
In our letter dated March 21, 1983 (5211-83-054) we requested a meeting to resolve these apparent discrepancies.
We would like to reiterate that request at this time.
In the event any valid discrepancies result f rom this meeting, we vill reselve them on a schedule consistent with the requirements of 10 CTR 50.49(g).
(2) Non Safety Related Electrical Equipment GPU'i letter dated July 21, 1982 (5211-83-170) in response to IE Notice 79-::,
and PID dated Dece:ber 14, 1981 Section P concerning interaction of safety
(
and non-safety systems indicate that failure of non-safety syste.s durin; the design basis accidents vill not result in an adverse effeet on safety equipe.ent.
GV Ns;les' Cup:f aM is a 5.:s cry c' the Ge ere'c : :.c e s 0 : t r 's t -
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Mr. Harold A. Denton 2
5211-83-157
/
(3)
Certain Post Accident Monitoring Equipment (R.G.2.97 Rev. 2)
Enclosed is a list of post accident monitoring instrumentation that is already environmentally qualified.
GPUN letter dated April 15, 1982 concerning emergency response facilities discusses GPUN ef forts through the B&W Owners to respond to Reg. Guide 1.97 guidelines.
This effort is currently scheduled for completion mid Cycle 5.
When this effort is complete, we will qualify or replace the remaining post accident monitor-ing equipment on a schedule consistent with requirements of 10 CFR 50.49(g).
Sincerely, H.D.bukill rector, TMI-1 HDH:LWH:vj f Enclosure cc:
J. Allen J. Stolz J. Van Vliet
?
TMI-1 Post Accident Instrumentation (Environmentally Qualified) 4 Regulatory Guide 1.97. Rev. 2 ITEM CAT.
TYPE ENVIRONMENTAL QUALIFICATION RCS Ifot leg 19 0 Temp 1
8 NUREG 0737 Item II.F.1 2
RCS Cold Leg 11,0 Temp 1
B NUREG 0737 Item II.F.1 l
RCS Pressure 1
C NUREG 0737 Item II.F.2 sheets 12 and 13*
Core Exit Temp (Incore T/C) 1 8
NLREG 0737 II.F.2 sheet 1 thru 11*
Saturation Monttor i
B NUREG 0737 II.F.2 sheets 12 and 13*
R.U. Sump level 2
8 NUREG 0737 Item II.F. sheets 15 thru 18*
R.B. Pressure 1
B NUREG 0737 II.F.1 RB 11 Concentrati n' 1
C NUREG 0737 Item II.F.1 sheets 1 thru 12*
2 DU Fxchanger Outlet Temp 2
D NUREG 0737 Item II.F.2 Dil Removal Flow /LPI Flow 2
D NUREG 0737 Item II.F.2 PORV/ Safety Valve Position 2
D MUREG 0737 Item II.D.3 sheets 1 thru 9*
Pressurizer Level 1
D MUREG 0737 Item II.D.3 S/G Level 1
D NUREG 0737 Item II.F.2 S/G Pressure 2
D NUREG 0737 Item II.F.1 i
ErW Flow 1
D MUREG 0737 Item II.E.1.2 sheets 1 thur 6*
HUI level 2
0 NUREG 0737 Item II.F.1 j
R.H. liigh Range Radiation 1
E NUREG 0737 Item II.F.1 sheets 13 and 14*
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- See GPUN Letter dated May 20, 1983. (83-128 )
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,0ffice of Nuclear Reactor Regulation N ' #^,,," ' ' *..,
' Attn:
Harold A. Denton, Director U. S. Nuclear Regulatory Co dssion dt Washington, D.C.
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Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1) se.
c A "8-P-Operating I.icense No. DPR-50 51114 rt.12,.
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Docke, No. 50-289 est.33.Parsio.
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Environmental Qualification of Electrical Equipment tiaro-Tet.175 x
x (10 CTF. 50.49) tita-Trt.16.
AA nfroca-Parsip, usi-Tri 67 in accordance vi:h 10 CTR 50.49(g) and NRC letter dated March 30, 1982, ;7'J.
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is supplying the following information to identify the electrical equipne.:
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IOpCItan: CO safety Vithin the scope of Sec:1on 50.49(g) tha: is a' ready qualified, and te submit schedules for environ:en:a1 qualificati:n or
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[j' replace:en: of the rer.aining equipment :ha: is 1:per: ant te safe:y as x
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de fined in 10 CFR 50. 49(b).
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Safety Related Tlectrical Ecu1prent
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werewar* r OF'JS le::er da:ed Augus: 26, 195'. (1.lL 236) in respense :c lEl 70-11.a:
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all the safety rela:ed ele::ri:a1 equip =en: which :.s required :: be an;..
is alreadv qualified.
The additional inf ormation we sub:i::ed :.n eur.e :.
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M da:ed May 3, 198: (5211-82-101) and May 16, 1953 (5:11-83-076) (NL'7,E; : - ' '
items), support our conclusions : hat the components listec are qualifie:
a aiu.rrt.127 a;1-umm.
accordance vi:h DOR Cuidelines dated Sever.ber, 1979.
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'1"".Ci r r+ li t f i Your le::er da:e: -)ece=ber 10,19E;, contained n!!-l TE7 whi:P :.r:::::t:
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m o-: r i. i a sore apparer; equip:ent qualification discrepancies.
eur le::er :: a.
March 21, 196 3 (5211-83-051.) we reques:ed a =ee:in; :c reselve :~..ese a:.:m in.....
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discrepancies.
We would like tc rei: era:e :ha: re ues; a: :his :1 e.
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- he even: any valid discrepancies resul: fro: this nee:ing, ve.. '; res:. 1 T,,',l.,*]'l ng,
- het on a s:nedule censis:en: vi:h :he require ents :f 1: ~77 i:
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Ncn Safe:. F.e:ated Ele::ri:a'. I:uirre-:
l GF'JN le::er da:ed J.d:. 21. 195: (1:11-53-172) it res70.se :e : I ::-' :(
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2.0.Smd and FI:/ da:ed Le:et:er l'., 195' Se::1o: ? con: err.in; in: era : rn :f sa::-
ad and non-saf e:y s: s:e.s indica:e : hat failure ef n:n-safe:y sys:e-s d.rr-4-.- :he design basis a::idents vill not resui: ir at a: arse effe:: :: safe:
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V Nr. Harold A. Denten 5211-8}-157 (3)
Certain Post Accident Monitoring Equipment ( R. C. I.9 7 Re v. 2)
Enclosed is a list of post accident monitoring instrumentation that is already environmentally qualified.
GPUN letter dated April 15, 1982 concerning emergency response f acilities discusses GPUS ef forts through the B&W Owners to respond to Rag. Guide 1.97 guidelines.
This effort is currently scheduled for completion mid Cycle 5.
k* hen this effort is complete, we will qualify or replace r.he remaining post a"cident monitor-ing equipment on a schedule consistent with requirements of 10 CTR 50.49(g).
Sincerely, H. D. lukill Director, TMI-1 HDB:LWH:vj f Enclosure cc:
J. Allen J. St'12 J. Van Vlie; i
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lHI-I Post Accident Instnanentation (Environmentally Qualified)
Regulatory Galde 1.97, Rev. 2
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'U. S. Nuclear Regulatory Con ission "lashington, D. C.
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