ML20198H099

Investigation Rept 3-96-047 on 961220.No Noncompliance Noted.Major Areas Investigated:Allegations Re Alleged Deliberate Failure to Follow Procedures Required by TSs

ML20198H099
Person / Time
Site:	Clinton
Issue date:	12/20/1996
From:	Paul R, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198H056	List: IA-97-299, Investigation Rept 3-96-047 on 961220.No Noncompliance Noted.Major Areas Investigated:Allegations Re Alleged Deliberate Failure to Follow Procedures Required by TSs ML20198H050 ML20198H065 ML20198H099
References
FOIA-97-299 3-96-047, 3-96-47, NUDOCS 9709080109
Download: ML20198H099 (38)

Text

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CASE No. 3-96-047 p" "%,,,

1

! ' i l United States Nuclear Regulatory Commission i,...i. . ,/

Report of Investigation CLINTON NUCLEAR POWER PLANT Alleged Deliberate Failure to Follow Procedures Roquired by Technical Specifications Office of Investigations

• Reported by 01: RIII

,'n 9709080109 970905 / i i

h'(1):?ll' /& f

Title:

CLINTON NUCLEAR POWER PLANT ALLEGED DELIBERATE FAILURE TO FOLLOW PROCEDURES REQUIRED BY TECHNICAL SPECIFICATIONS Licensee: Case No.: 3 96 047 Illinois Power Company Report Date: December 20, 1996 P. 0 Box 678 Clinton, IL 61727 Control Office: 01:RIII Docket Number: 50 461 Status: CLOSED Reported by: Reviewed and Approved by:

dAAf Y. Nit A Hhrold G. Walker Special Agent' Richard C. Paul Director' Office of Investigations Office of Investigations Field-0ffice, Region-III Field Office, Region III-h pWARNING \

This Reppi t of li,v stigati an onsistsofkpages. 'throug

6. vit 1 l sexhibits' Q throug 29 _ . Itig has not been rev ewe. purs antj to t e t10 CFR ub5ection2 90(a1 exenLptio(; norihas a iy e mpt aterial een deleted Do not di minite. tNace nn th& Publ ic D ume Roam dr discuss theicontients bf this refort/outside NRC with6ut duthotitt the

. aos 1 a ofgfal of\this reportY Treat FFICIA( 35E ONQ f Y

SYNOPSIS This investigation was initiated by the Nuclear Regulatory Commission, Office of Investigations, Region Ill, on September 9, 1996, to determine whether reactor operators at the Clinton Power Station (CPS) deliberately failed to follow plant operating procedures related to actions taken to isolate the B reactor recirculation loop in an attempt to keep the unit in power operation.

Based on the evidence developed during the investigation. it is concluded that '

the Assistant Director for Plant Operations, the Shift Supervisor the Recirculation System Engineer and the Shift Technical Advisor mutually agreed to deliberately violate procedures required by Technical Specification S.4.1.

to maintain power operation.

Case No. 3 96 047 1

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l O TABLE OF CONTENTS Page 1

d Y N 0P S I S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

LIST OF INTERVIEWEES................................................... 5 7

DETAILS OF INVESTIGATION...............................................

Appl i cabl e Regul a t i on s . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 7

Pur >ose o f Investi gati ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Bac(ground........................................................ 7 Coordination with Regional Staf f. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Coordination with Regional Counse1............................... 7 Review of Docum?ntation.......................................... 8 Allegation (Alleged Deliberate Failure to Follow Procedures Required by Technical Speci fications) . . . . . . . . . . . . . 10 E v i de n ce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Agent ' s Ana l ys i s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 Conclusion. . . . . . . . . ..................................... 32 SUPPLEMENTAL I NFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 LIST OF EXHIBITS...................................................... 35 Case No. 3 96 047 3

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LIST OF INTERVIEWEES Exhibit

, 3ROTHERTON, Matthew, (A) Reactor Operator, CPS................... 23 CAMERON. Keith. Reactor Recirculation System Engineer, CPS. . . . . . . 19 CONNELL, Wil fred, Vice President CPS. . . . . . . . . . . . . . . . . . . . . . . . . . . 26 EARL, John, Shift Supervisor, CPS................................ 8 H0 DEL , David, Shi f t Technical Advisor, CPS. . . . . . . . . . . . . . . . . . . . . . 25 MILLER, Michael, NRC Senior Resident Inspector, CPS. . . . . . . . . . . . . . 28 MORGENSTERN, Roger, Plant Manager, CPS........................... 22 MOSLEY, Gary, Assistant Director of Plant Operation, CPS. . . . . . . . . 16 PERRYHAN, Fred. Reactor Operator (stand by) CPS.................. 27 RIPPY, L. Randy, Line Assistant Shift Supervisor, CPS............ 20 SHEFFIELD Kenneth. (B) Reactor Operator. CPS.................... 24 SHELTON David. Bulk Power 0perator. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ST0EDTER, Karl a , NRC Resident Inspector, CPS. . . . . . . . . . . . . . . . . . . . . 29 Case No. 3 96 047 5

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DETAILS OF INVESTIGATION Apolicable Requ1ations

1. Technical Smcification (TS) 5.4.1: states that written procedures shall be establis1ed, implemented, and maintained covering the activities recommended in Regulatory Guide (RG) 1.33. Revision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Appendix A, Section 4, states that " Instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared, as appropriate for the following systems:"

a. " Nuclear Steam Supply System (Vessel and Recirculating System)"

2. 10 CFR 50.5: Deliberate Misconduct

3. 18, U.S.C. 372: Conspiracy to commit offense or to defraud United States Purpose of Investiaation This investigation was initiated by the Nuclear Regulatory Commission. Office of Investigations, Region III, on September 9,1996, to determine whether reactor operators at the Clinton Power Station (CPS) deliberately failed to follow plant operating procedures related to actions taken to isolate the B reactor recirculation-loop in an attempt to keep the unit in power operation (Exhibit 1).

Backaround On September 9,19 6, an emergency Allegation Review Board (ARB) was convened wherein actions taken by reactor operators at CPS on September 5, 1996 to isolate the reactor recirculation loop "B" were examined. At this board, 01:RIII was asked to initiate an investigation to determine whether reactor operators at CPS deliberately failed to follow plant operating procedures related to their actions taken to isolate the B reactor recirculation (RR) loop.

Coordination with Reaional Staff On September 9,1996, the RIII ARB set a high priority for the investigation based on the level of management involved.

Hironori PETERSON, NRC RIII Resident Inspector and James R. ROT 0N NRC RIII Resident Inspectnr assisted 01:RIII throughout the investigation

[oordination with the Reaional Counsel On September 9, 1996. Bruce BERSON, Regional Counsel, RIII, was present during the ARB and agreed that if plant operating procedures were violated, that would constitute a violation of technical specifications and NRC regulations.

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Review of Documentation

CPS procedure No. 1005.14 was reviewed. This procedure contains a step No.

, 8.1.11.4 which states " If a specific order of pei forming the procedure is ,

s- required, use an asterisk (*) at the beginning of the section to annotate that

the steps are to be performed in the sequence that they are written (Exhibit 2)

! CPS procedure No. 3302.01. *0.2.4 " Idle RR Loop - solatina" was reviewed.

Step 8.2.4.4 states that

• Prior to isolating CRD Seal Injection Flow, allow 2

the idle loop to Normal conditions Cooldown to < 250 degree Fahrenheit, j Emeraency Conditions cooldown to < 250 degrees Fahrenheit; or in the event the i RR seals are failed, loop depressurized to drywell pressure (Exhibit 3).

AGENTS NOTE: The two documents indicated above are the basis for the

implementation of the procedures leading to loo) isolation. The asterisk found '

cn CPS procedure No. 3302.01. *8.2.4 dictates t1e sequential performance l required for Loop isolation.

~

i A review of an Illinois Power Company Presentation on " Evaluation and Action i P bn in Response to Reactor Recirculation Pump Seal Failure Event", dated Septanber 23, 1996 and presented to the NRC Region III on September 23, 1996 was conducted. The presentation revealed an Illinois Power finding that

"Hanagement did not properly establish, enforce or set example for procedural *

compliance" including "out of sequence procedure step performance" (Exhibit l

4).

A review of the " Critique of the Unusual Event due to exceeding Technical 4

Specification !.imits for Reactor Coolant Leakage on September 5,1996"

!- prepared by IP. was conducted. The critique revealed that at 2110 (9:10 p.m.) '

on September 5,1996, a " Notification of Unusual Event" was declared due to 4

exceeding 5 gpm leakage into the drywell floor drain system. This occurred while performing an isolation of the B reactor recirculation loop due to indications of increased seal degradation on the B reactor recirculation pump.

The critiaue further states that "while waitina for the B recirculation 1000 4

to cool down to less than 250 decrees in order to comDlete the isolation steos

- Der the operatina procedure. indicated floor drain leakaae raised from

approximately 4.7 callons aer minute to 5.51 aallons Der minute. This exceeded the limits of Tec inical Soecification 3.4.5 of 5 callons per minute

! unidentified leakaae.- A four hour action statement was then entered to restore leakaae to within limits and it was also made to perform the emeroency

isolation steos in the operatina procedure which shuts the suction valve orior to 250 decrees and keeps the CRD in.iection to the seal lined up" (Exhibit 5) i

-A chronology of events was provided in the critique revealed that at 2030 (on September 5, 1996) (8:30 p.m.) 1833 F075B was shut, in an attempt to raise the cooldown rate of the recirculation loop. It was thought that this would force more cold CRD water into the loop. Floor drain rate was approximately 4.7 gpm

! (Exhibit 5 p. 2),

j AGENT'S NOTE: Valve IB33 F075B is step 8.2.4.5 of CPS No. 8.2.4.. Step .

8.2.4.4 of CPS No. 8.2.4 specifically states that prior to isolating control Case No. 3 96 047 8

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4.

rod drive (CRD) Seal Injection Flow, allow the idle to cooldown to < 250 degrees Fahrenheit.

u j ,

A review of the Reactor Coolant System Operational Leakage 3.4.5 Procedure

indicates that 5 com unidentified leakaae reauires a leakaae rate reduction to within limits in four (4) hours or verify that the source of the unidentified '

leakaae increase is not service sensitive type 304 or tvDe 316 austenitic 4-stainless steel-within four (4) hours (Exhibit 6).

$ ' Transcribed conversations between Electric Supply Service Coordinators (load dis)atchers) and Clinton Power Station during the week of September 2,1996 (Ex11 bit 12) were reviewed. The conversations revealed the following:

i On Monday, September 2, 1996 the transcripts revealed that CPS was 4 experiencing a leak and that a decision was to be made about when to shut down j and fix the " recirculation field". It was also reported that the Baldwin

, fossil plant was experiencing problems (Exhibit 12),

On Tuesday, September 3, 1996, the leakage was reported to be 3.68 gpm. At i this time, all three Baldwin units were reported as on line (Exhibit 12).

4

! On Thursday, September 5, 1996, at 17:10:52 (5:10:52 p.m.) RIPPY notified load i dispatcher Terry ENGLE that at 6:00 p.m., they were going to" start down".

l At 19:01:26 (7:01:26 p.m.), RIPPY notified the load dispatcher that they (CPS) l an unexplained leakage and that at 5 gpm, they would be forced to shut down in l j

accordance with a management decision (Exhibit 12).

At 22:03:14 (10:03:14 p.m.) RIPPY notified the load dispatcher that there was

an increased leakage rate which if not corrected in (4) four hours, they may be obliged to shut down. RIPPY indicated that it would be four (4) fours i before that decision would be made (Exhibit 12),

1 At 01:03:25 (1:03:25 a.m.) the shift sunrvisor at CPS notified the load dispatcher Duane FORCE that they would >e shutting down (Exhibit 12).

A memo to E.P. BADER from Gary McC0Y of Nuclear Financial Services and M.J.

WALTHER dated August 14, 1996, at the request of MORGENSTERN, the plant

manager, indicated a financial recommendation regarding Single Loop j Operations. The memo provided two options:(1) Continue to o>erate in single

' loop at 68% until RF 6 (refueling outage 6) (10/13/96) (2) liave a 5 day outage to replace the seal and then operate at 100% power until RF 6. The financial

• recommendation was, if the seal fails from 8/13/96 to 9/23/96. replace the seal during a five day outage. If the seal fails from 9/24/96 to 10/13/96, j operate in single loop until RF 6 (Exhibit 13: Exhibit 20, pp. 26 28, 30).

i AGENT'S NOTE: The' seal failed on September 5,1996 which would have fit into option I which was to replace the seal during a five day outage and not continue in single loop.

By memo from J.R. RGTON, Jr. Senior Resident Inspector, Zion Nuclear .

F Generating Station, to 01:RIII dated October 2, 1996, ROT 0N indicated that he and Karla ST0EDTER attended a CPS meeting on or about August 29, 1996. The Case No. 3 96 047 9 s

a

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meeting dealt with various issues associated with the degrading conditions of the "B" reactor recirculation pump seals. During that meeting according to ROTON, it was mentioned that a load dispatcher had contacted Clinton to determine the condition of the plant. According to ROT 0N, his impression of '

the meeting was that the load dispatcher was attempting to determine the availability of CPS. ROT 0N also indicated that it was his impression that the load dispatcher seemed to indicate that CPS staying on line would be a desirable condition (Exhibit 14).

By memorandum for the record, dated September 10, 1996, R. ROT 0N stated that Gary MOSLEY, the Assistant Director for Operations, during a meeting requested by CPS walked through the procedural steps and thought process used when securing the B RR pump during the evening of September 5,1996. HOSLEY, according to ROTON stated that the decision to isolate control rod drive seal injection to the "B" RR pump was made in order to determine if there was any leakage past the "B" RR pump suction and discharge valves. According to ROTON, H0SLEY stated that he and the Shift Supervisor (EARL) recognized and accepted that this action could cause further degradation of the "B" RR pump seal. However, HOSLEY and EARL determined between themselves, that the potential safety consequences of this action were acceptable (Exhibit 15).

Alledation No. 1: ALLEGED DELIBERATE FAILURE TO FOLLOW PROCEDURES REQUIRED BY TECHNICAL SPECIFICATIONS Evidence Interview of SHELTON (Exhibit 11)

SHELTON, a bulk power coordinator with Illinois Power (IP) indicated that his job requires him to make a load forecast for the next day by conferring with all the power plants to see what's available, what's broken, and how long will it take to fix it. Every morning at 8:00 a.m.. he indicated that he initiates a conference call with all the power plants and talks to the operation managers to glean information from them on the availability of the units, and provides them with what the anticipated load is going to be tomorrow, the next few days, cnd a seven day forecast. He provides a market analysis as to what's going on, and the costs on the interconnected system where he can buy or sell to re) lace power, or procure more economical power. SHELTON stated however, that le has no operational control over any power plant. SHELTON further indicated that on September 5,1996, all the plants were on line (Exhibit 11, pp. 5 9; pp. 13 14.17: Exhibit 12: Exhibit 14).

The load dispatchers, according to SHELTON, would have had numerous conversations with the plant as they were going through this process of

" coming down" (Exhibit 11, p. 18).

SHELTON indicated on September 5, 1995, he had a conference call with Pat

[0'BRIEN), a CPS supervisor, and was trying to pin CPS down as to when they were going to conduct the loop isolation and when they would be back. SHELTON further indicated that during his call to CPS which was the second call to CPS following the routine 8:00 conference call, he learned what the leakage rate was, what the lir.its were, when they thought things needed to be taken care of Case No. 3 96 047 10

and what needed to be done. SHELTON in turn gave them information back on the cost of displaced power. (Exhibit 11, pp. 20 23).

, According to SHELTON, CPS provides schedules made up in advance, how things were going to go and their plan. The second conference call, according to SHELTON was to further clarify if there's any changes. CPS's plan, according to SHELTON, was to come down that evening, go into isolate the pump, go into single loop operation, and then come back up on power to some level. According to SHELTON, the discussion was how much power CPS could generate after they had gone into the single loop operation. According to SHELTON, CPS thought they could produce 30, 40 megawatts more than what he originally was told in the first call in the morning (Exhibit 11, pp.24 26).

SHELTON indicated that as a result of the CPS shutdown IP bought a considerable amount of power on September 6,1996 (Exhibit 11, p.26).

I Interview of Wilfred CONNELL (Exhibit 26)

CONNELL, Vice President of IP with the s)ecific responsibility of CPS, was asked if he had any conversations with tie Plant Manager (MORGENSTERN) or the Assistant Director of Operations (AD0). HOSLEY regarding the anticipated isolation of the RR loop on September 5,1996. He indicated that he was on site that day (September 5,1996), but denied any significant meetings or private meetings with MOSLEY or MORGENSTERN regarding the loop shutdown.

CONNELL also denied that he was involved in any briefings of the individuals who were going to conduct the procedure. CONNELL further denied that he was under any pressure to maintain the reactor in single loop operation and not shut down (Exhibit 26, pp. 4 6).

CONNELL responded that he didn't discuss with MORGENSTERN or others the necessity of maintaining the reactor in single loop so as not to shut down and to continue to provide power (Exhibit 26, p. 7).

I CONNELL indicated that the crew working the shift under John EARL the shift

, supervisor, was res>onsible for the performance of procedures out of sequence (Exhibit 4, p.5: Ex11 bit 26, p. 7).

CONNELL, further, related that he was aware of discussions around the site for a couple of weeks about whether CPS would go to a single loop or not. However, on the night of September 5,1996, CONNELL stated that he was in St. Louis (MO). He indicated that he received a call from the CPS security people at about 9:45 p.m. advising him that they were in an " unusual event". CONNELL stated that he promptly called the shift supervisor, John EARL. EARL told CONNELL he had exceeded a five gallon leakage requirement and therefore he was in an unusual event status. CONNELL recalled that he told EARL. "if that leak does not get down, does not decrease, then I guess we're out of here". CONNELL stated that the meaning was clear, that the plant was going to come down, and EARL replied "yes, sir" (Exhibit 26, p. 8 9).

CONNELL further stated that there was no role for " dispatch" in decision making in this plant, with respect to CPS, CONNELL stated "The decision making is really made tsy the management of the plant." In the mid eighties, according Case No. 3-96 047 11

to CONNELL, there was a clear decision that CPS would operate as CPS wished to operate and that "we would manage the rest of the system in order to accommodate what the power demands were".. and "that's how we've run this plant really since we became operational" (Exhibit 26, p.11). .

CONNELL stated that the dispatcher is involved in knowing what the status of the plant is, "It's clearly important for him to know if this plant is in some sort of difficulty with respect to producing power, but he's not a decision maker in this whole process. Decisions rest with the management of this plant. That's a ten year old decision and I know of no case where we've done it any other way." (Exhibit 26, p. 11-12).

Interview of EARL (Exhibit 8)

EARL, the CPS shift su>ervisor responsible for the shut down and isolation of recirculation system (.1RS) loop "B" on September 5.1996, stated that he was notified.. prior to beginning his shift, that plant management had made a decision to shut down and isolate the "B" reactor recirculation (RR) loop due to seal leakage (Exhibit 8, pp. 5 7).

EARL stated that he conducted a crew brief at approximately 3:06 p.m. wherein EARL explained to his crew that during the shift they would be isolating the RR pump, and evaluating the leakage (Exhibit 8, pp. 810).

EARL indicated that at approximately 5:30 p.m., a pre evolution briefing to the whole crew was conducted by L. Randy RIPPY, the line assistant shift supervisor. Among those identified by EARL as being present were: MOSLEY, ADO:

two reactor operators (Matt BROTHERTON (A) and Ken SHEFFIELD (B)): David H0 DEL, the shift technical advisor (STA): and Keith CAMERON, the RRS engineer (Exhibit 8, pp.-9 13: Exhibit 5).

At the brief, according to EARL. HOSLEY brought in a 3 aper with management expectations for the loop shut down and isolation. EARL indicated that during

.the brief, several procedures were discussed including the normal RR operating procedure which, according to EARL, basically indicates step by step actions on how to shut the pump down and how to isolate the pump (Exhibit 8. pp. 13 16: Exhibit 9)

According to EARL, the pre evolution brief lasted until 6:00 p.m. and at 6:05 p.m., power was then lowered in order to get the control rods in the correct configuration to shut the RR pump down (Exhibit 8. p. 18).

EARL stated that section 8.2.4 for idle recirculation loop isolation was entered into by shutting the reactor water clean up isolation valve 1G33F106 (Exhibit 6. p. 6: Exhibit 8. p. 22).

EARL identified each step in the isolatior of the "B" RR loop isolation until reaching step 8.2.4.4. He identified step 8.2.4.4 as a step which does not perform any actions and .is a condition for a later step, identified as 8.2.4.6 (Exhibit 8' p. 24).

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AGENT'S NOTE: CPS procedure No. 1005.14 states " If a specific order of performing the procedure is required, use an asterisk (*) at the beginning of the section to annotate that the steps are to be performed in the sequence

' that they :,re written. There are (8) steps in the loop isolation procedure 8.2.4.1 8 (Exhibit 2: Exhibit 3, p. 17).

EARL acknowledged that it is a requirement that the procedure be performed sequentially as indit.ated by an asterisk on the procedure. The asterisk.

according to EARL, is telling the operators using the procedure that it's required to perform the procedure in sequence (Exhibit 8, p. 25).

AGENT'S NOTE: EARL acknowledged the requirement to conduct the procedure in sequence, however step 8.2.4.4 was not performed in sequence.

4 While monitoring the loop for cool down, it was estimated, according to EARL, that it would take six to eight hours to cool down to 250 degrees Fahrenheit F (as required by step 8.2.4.4). EARL further indicated that he discussed with

CAMERON (RRS Engineer) serforming step 8.2.4.5, (closing the seal st3ging

! shutoff valve 1B33 F0753) thereby forcing more water (approximately 1 gpm) into the loop to assist in cooling down the RRS. Following discussions with i' CAMERON, it was EARL's understanding that he could perform step 8.2.4.5 and 1

still meet the step of 8.2.4.4 (Exhibit 8 pp. 28 30: Exhibit 27, p. 10 12).

! EARL further described his conversation with CAMERON, in that CAMERON, according to EARL, indicated that the valve (IB33 F075B) if closed would not l damage the RRS. EARL further stated that before he went ahead with shutting the 1833 F075B valve, he discussed his intended action with MOSLEY (Exhibit 8

p. 30).

EARL indicated that his reason for wanting to shut the valve (1833 F075B, step 8.2,4.5 prior to completing the cooldown required by step 8.2.4.4) was he

" thought" that was his next action to perform and "the fact that we would be able to get the loop isolated in a more timely fashion". The goal, according to EARL was to shut down and isolate the source of leakage to continue to operate the plant" EARL denied there was any outside mctivating force that caused him to cool the reactor down in a faster manner than the (6) six hours he was told it would require. At 8:30 p.m., the 1B33F075B valve was closed wi!.h the loop temperature at 511 degrees Fahrenheit (Exhibit 5, pp. 310:

Exhibit 6, p.6: Exhibit 8, pp. 31 34).

AGENT'S NOTE: EARL'S suggestion that he " thought" step 8.2.4.5 was his next action to perform is in direct conflict with his earlier acknowledgement that it is a requirement that the procedure be performed sequentially (Exhibit 8,

p. 25).

. EARL related that at 20:55 (8:55 p.m.), the dry well floor drain leakage rate-exceeded the technical specification limit of five gallor.s per minute which causes " notification of unusual event". EARL commenced making the proper notifications for entering the emergency plan which is to contact the state, contact the NRC, and contact security. EARL, after a consultation with MOSLEY.

Case No. 3 96 047 13

i made the decision that they had exceeded the technical specification limit for i leakage and were in " emergency procedures for the emergency plan". EARL

indicated that they now met the "if" condition of step 8.2.4.3 and that the i IB33F023B valve was closed at 9.30 p.m. (Exhibit 8, pp. 34 37

Exhibit 7).

l EARL related that when the leak rate went above (5) five gallons per minute,

. they had a (4) four hour limit to get leakage below (5) five gpm or shut down.

2 EARL further stated that they were attem) ting to get seal leakage below the technical specification before the four 1ours expired to continue to operate

! with the loop isolated (Exhibit 8, p. 52).

. According to EARL, at 2159 (9:59 p.m.), the IC11 F026 (B) CRD injection valve i was shut (procedure step 8.2.4.6). there was a decrease of the seal pressures and at about 2217 (10:17p.m.), a seal cooler outlet temperature alarm sounded, i followed at approximately 2222 (10:22 p.m.) by a rapid decrease in seai

, pressures from the 900's to readings in the 200's, in seconds. Drywell l pressure began rising, which was relieved by pumping it into the suparession ,

i pool in containment. The floor drain began to rise which meant to EARL that

now the seal had failed. The floor drain rate got up to (8) eight gpm and the l computer screen went white which, according to EARL, means the computer is not 4 reliable. AT 22:30 (10:30 p.m.), EARL did not know what the actual leakage rate was, but according to EARL, the floor drain leak rate was determined by

the STA'to have peaked at 'd gpm and was decreasing (Exhibit 8, pp. 53 58).

l EARL indicated that at the time he was relieved, there was about an hour and 20 minutes left to 90 on the four hour action requirement for getting leakage down below five gallons per minute. EARL stated that following his shift, the s

j leak eventually stabilized at about ten gpm (Exhibit 8. pp.58 59).

EARL further stated that looking back on the events and what hap >ened, he realized that bad decisions may have been made but that he' felt le was going through and evaluating and using the pre >er individuals input in order to arrive at the decisions (Exhibit 8, p. 65).

Interview of MOSLEY (Exhibit 16)

MOSLEY, the Assistant Director of Operations (AD0), whose primary duties are to supervise and provide guidarce to the shift supervisors, was the highest IP corporatt 'maloyee present in the reactor control room during the isolation of the RR l' 3 on September 5, 1996. Regarding the execution of the procedure to isolat .he RR loop "B", and his role in the decision making process related to the implementation of the procedures, MOSLEY related the following..

(Exhibit 16, p. 5 6).

MOSLEY stated that the load dispatcher had asked whether or not CPS was going to shut down Friday night (September 6) so that the load dispatcher could plan for the weekend. According to MOSLEY, this was discussed at CPS with the plant manager, MORGENSTERN and other directors on (Thursday) September 5, 1996 (Exhibit 16. p. 7: Exhibit 11, p. 20).

Case No. 3 96 047 14

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l MOSLEY said that guidelines to help the Shift Supervisor (SS) in his decision

! making were developed after consultation with MORGENSTERN. MOSLEY said that he arepared "guidelinss for reactor recirculation loop isolation and RF leacage evaluation" for MORGENSTERN'S approval and MORGENSTERN, according to MOSLEY, agreed with the o ?ection being given t.0 the SS. (Exhibit 9: Exhibit 16, p. 7 8).

AGENT *S NOTE: The guidelines arepred by MOSLEY read in part, "This is to be used as a tml for decisions )y Operations Management and is not intended to conflict or override CPS procedures or Tech Specs." (Exhibit 9).

MOSLEY related that he was in the control room at 5:30 p.m. to monitor the pre job brief, which was completed at 6:00 p.m., and which he considered to be very extensive and covering the procedures that were going to be involved. The crew, according to MOSLEY, seemed to be very comfortable with what they were going to be doing and what was expected of them. Once the brief was over, MOSLEY completed a self-assessment to document that the briefing had gone on in a self assessment report form (Exhibit 16, pp. 10-11: Exhibit 17).

AGENT"S NOTE: The self assessment card prepared by MOSLEY indicated that he considered the pre evolution brief to have been "very good" (Exhibit 17)

J MOSLEY stated that at 18:05 (6:05 p.m.) power reduction began, and was completed at 19:44 (7:44 p.m.) MOSLEY stated that he was standing outside the " horseshoe" section of the control room where he could look inside and monitor what was going on when the pump was shut off (Exhibit 16, p 13 14).

MOSLEY stated that the leak rate was approximately 3.9 gpm at the time of the pre job brief and that at 5.0 gam unidentified leakage, the technical specification requires that leacage be restored to within the limit within a four hour time period (Exhibit 7: Exhibit 16, p 14).

HOSLEY further indicated that they were doing a normal loo) shut and isolation and attempting to cool it down to less than 250 degrees Fa1renheit (step 8.2.4.4) when MOSLEY agreed that the next step, 8.2.4.5 was an aapropriate step to help cool the loop down. Mosley said that the reason be1ind that decision was to drive what little bit of flow that was going out of the staging line, to help cool that loop off. MOSLEY said that they had 500+

degree water which had to be cooled down within a four period. MOSLEY indicated that the decision to go forward to 8.2.4.5 without allowing it to cool down to 250 degrees Fahrenheit was a combined decision between himself, the shift suaervisv(EARL) and the system engineer (CAMERON). (Exhibit 16,

p. 19 20: Ex1ibit 27, p. 10-71).

AGEdT"5 NOTE: MOSLEY, upon responding "we've got to cool down within a four hour perico" attempted to clarify his comment by adding "Not in a four hour period, but we've got to cool it down in the night and ambient temperature is going to take a real long period of time, I felt it was appropriate to shut the (1833 F075B) 75B to help cool the loop off". This was performed out of sequence from the procedure. Actions related to the 1833-F075B valve are found in both step 8.2.4.3 and step 8.2.4.5 of CPS No. 3302.01, *8.2.4 (Idle RR loop

- Isolating). Step 8.2.4.3 directs the valve to be closed only in the event Case No. 3 96-047 15

i of an emergency condition (system / seal leak). (This was before the leakage rate increased to above 5 gpm). Step 8.2.4.5 which called for the closing of Seal Staging Shutoff Valve IB33 F075B. was to be performed following the loop cooldown to <250 degrees Fahrenheit. According to the shift supervisor EARL, the closing of this valve would force approximately 1 gpm into the 500+ degree Fahrenheit water in the loor, which has a ca)acity of several thousand gallons.

(Exhibit 8, 29: Exhibit 16, pp. 19 20: Exhiait 18, pp. 1 2).

HOSLEY was asked the following question "Can you describe to me another i situation where a procedure which apparently requires to be done in sequence has been done out of-sequence, other than the one we're discussing now ? Is this commonplace?", H0SLEY responded "No, its not commonplace. It is the intent for the operators to do the steps in order. However, if you look at 8.2.4.4 that is not i.ecessarily an action statement step. It's an information step" (Exhibit 16, p.-22).

H0SLEY further indicated that it had been their intention to wait until it cooled down, so they waited approximately a half hour and saw that the cool down rate was "very, very, very Onall" and he feit they weren't getting anywhere in cooling down. HOSLEY indicated that he felt it was an appropriate thing to do instead of sitting there and waiting for ambient conditions (Exhibit 16, pp. 24 25).

H0SLEY further indicated that after discussions with the shift supervisor i.nd the system engineer that shutting "that valve" would help cool it down. He stated "We felt-that was the appropriate thing .to do and that's what we did".

(Exhibit 16, p. 28).

MOSLEY denied that there was any pressure on him from anybody in management or otherwise to stay in single loop operation so that the plant would not go down (Exhibit 16, p. 28).

H0SLEY indicated that later that evening, he discussed with EARL the declaration of an unusual event and making the appropriate notifications. '

MOSLEY said that he personally called HORGENSTERN to let him know that the leakage had gone over the tech spec limit of 5.0 gpm, (Action 'A' of Technical S>ecification (TS) 3.4.5 was entered which required restoring leakage to less t1an 5 gpm within four hours. TS 3.4.5 requires that if leakage is not restored within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period, the plant must be shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.) which occurred at 2055 (8:55 p.m.). According to MOSLEY, EARL was also making required notifications. HOSLEY stated that he suggested to EARL that they were no longer in a normal loop isolation condition: and that 8.2.4.3 of CPS 3302.01 now applied. HOSLEY at this point considered the status of the event as an emergency condition. At 2130 (9:30 p.m.), according to MOSLEY, with leakage exceeding 5.0 gpm, because he wanted to get the leak isolated more rapidly. He felt it appropriate to re enter the procedure a.t step 8.2.4.3 (Exhibit 3 p. 18: Exhibit 6, p. 26 28: Exhibit 7: Exhibit 16, pp. 31 33 :

Exhibit 18, pp. 1 2).

At 2130 (9:30 p.m.), according to MOSLEY, step 8.2.4.3 was entered and the crew continued through the procedure, stopping at 8.2.4.6. MOSLEY stated that they were no longer in a normal cool down condition and they were in what he Case No. 3 96 047 16

l categorized as an emergency condition for 8.2.4.3 and not an emergency condition-for 8.2.4.4.(Exhibit 3, 7 17: Exhibit 16, pp. 33 34).

~ AGENT'S NOTE: Even though MOSLEY stated that he considered CPS to be in an

! emergency condition as they re entered the loop isolating procedure at l -8.2.4.3, and continued through the procedure, stopping at 8.2.4.6., he didn't l consider they were in an emergency condition for step 8.2.4.4 which recuires a cooldown to 250 degrees Fahrenheit, whether in normal or emergency concitions. l MOSLEY' indicated that the seal had not catastrophically failed-because the loop had.not depressurized to dry well pressure, therefore it was not a catastrophic failure. The seals according to MOSLEY..were degraded but were

.still providing some sealing force. Therefore, MOSLEY did not feel it was necessary to cooldown to < 250 degrees Fahrenheit (Exhibit 16, pp. 26 37).

At 2159 (9:59 3.m.), the loo) temperature, according to MOSLEY, was just under 500 degrees Fairenheit and t1e leakage rate was between 6 (six) and 7 (seven) gpm when Control Rod Drive (CRD) IC11F026 8 valve (step 8.2.4.6) was closed.

' MOSLEY stated that he discussed with EARL whether or not they should go ahead and shut the CRD 1C11F026 Bravo valve and EARL agreed. MOSLEY stated that he also talked with the system engineer-(CAMERON) about what he was going to do.

CAMERON allegedly told MOSLEY that he (CAMERON) didn't feel that by closing the valve it would cause a major problem at the seal (Exhibit 16, pp. 37 41).

AGENT'S NOTE: This step was performed contrary to procedure. The procedure-stated that prior to isolating CRD Injection Flow, certain conditions had to be met. The conditions were that the loop was to be cooled down to less than ,

-250 degrees Fahrenheit, or, if-the RR seals were failed, that the-loop was to -

be depressurized to approximately drywell pressure (Exhibit 18, p. 2-3).

MOSLEY stated that when he suggested that step 8.2.4.6 be performed. EARL said he wanted to take the time to review the cautions in the procedure. Following EARL *S review, MOSLEY and EARL both felt that they "could live with these-consequences" because the seal is- already degraded, the pum) is off and it's not going to be restarted before the seal is replaced (Exhi)it 16, p. 39).

AGENT'S NOTE: The caution panel on orocedure 8.2.4 states, in part, that seal damage will occur at 250 degrees Fa1renheit and that securing CRD injection to a RR pump which has been secured and isolated due to a seal leak will cause an increase in drywell airborne activity as the loop depre:surizes to atmosphere through the seal.

MOSLEY indicated that he discussed shutting the valve with the system' engineer

-(CAMERON) prior to shutting the valve, CAMERON indicated he did not feel that it would cause a major failure or a problem with the seal. CAMERON, according 1

, to MOSLEY, based this upon his experience with the seals and looking at seal failures in the industry (Exhibit 16, p. 40).

MOSLEY acknowledged that he accepted the fact that there could potentially be air borne activity or further degradation of the seal by shutting the seal injection flow (Exhibit.16, p. 40).

Case No. 3 96 047- 17 I

On September 10, 1996. MOSLEY stated to NRC inspectors that the decision to isolate control rod drive injection to the B RR pump was made in order to determine if there was any leakage past the B reactor recirculation pump suction and discharae valves. Further. MOSLEY stated that he and the SS (EARL) recognized and accepted that this action could cause further degradation of the B reactor recirculation pump seal and that the potential safety consequences of this action were acceptable (Exhibit 15).

Interview of CAMERON (Exhibit 19)

CAMERON, an IP plant engineer responsible for the reactor recirculation system stated that he is the " technical owner of the system". CAMERON said that if there's a question of technical nature or even of some material condition then he would be consulted (Exhibit 19, p. 6).

On September 5. 1996, CAMERON said he " stayed over" to be of service to the shift that was going into the single loop evolution. CAMERON indicated that the seal performed normally until April 9 (1996) when the seals began to show =

signs of degradation (Exhibit 19, p. 6 7).

CAMERON said he was present at the shift brief on September 5, 1996 to answer questions and provide cautions. CAMERON said that he relayed historical data l

l from 1988 when there was a similar leakage rate. CAMERON. stated that he also advised that he didn't feel that the seal would catastrophically fail (Exhibit 19, pp.8 9).

CAMERON stated that "we tried to wait for the loop to cool down or to depressurize. It did not depressurize. It was also not cooling down."

According to CAMERON, MOSLEY and EARL did talk to him about shutting the 1B33-F075B valve (step 8.2.4.5) to try to cool the loop down and he was asked whether there would be an adverse effect on the seal. CAMERON said he did not feel that it would challenge the seal. By shutting the valve, according to CAMERON, more cooling water is forced into the seal and CAMERON didn't think it would hurt the seal (Exhibit 19, pp.16-17, 2122).

CAMERON related, however, that there was no reason why the cool down wasn't allowed to take six hours and he didn't recall why there was a push to try to accelerate the cooling process. CAMERON said that he was remiss in not focusing on the actual details of the procedure (Exhibit 19 pp. 22 23).

Interview of RIPPY (Exhibit 20)

RIPPY, related that he received his senior reactor operator's license in January.1990 and is an assistant shift supervisor with IP whose duties are to direct the activities of the operating crew, orimarily the reactor operators and indirectly the field operators. on Septem)er 5,1996, he said he was assigned to the second shift (swing shift) as the line assistant supervisor, and the shift supervisor was EARL (Exhibit 20, pp. 4 6, 13).

RIPPY recounted that he performed the pre-evolution briefing at roughly 5:30 x m., assigning certain elements of the brief to other members of the crew, rit stating that overall, he (RIPPY) gave the brief. RIPPY said that he gave a Case No. 3 96 047 18

l .-

copy of the RR procedure and unit power changes procedure to the B reactor operator (Kevin SHEFFIELD)-for him to review and summarize for the crew. RIPPY indicated that he was generally aware that the seal in the RR B loop was s degrading and it had been degrading for quite some time. The discussions during the brief, according to RIPPY, involved a normal evolution and what they would do if it went abnormally. Emergency procedures were covered, i.e,.

loss of coolant flow, reactor scram and reactor coolant leakage.The seals were stressed and according to RIPPY, there was a good chance there would be a failure . According to RIPPY, SHEFFIELD was assigned to brief CPS 3302.01, which was described by RIPPY as the main procedure for conducting single loop operation. SHEFFIELD, according to RIPPY, conducted a thorough brief, reading from the procedure and summarizing the steps (Exhibit 20, pp. 6 12, 14).

RIPPY, indicated that his only previous experience in isolating a loo) was as a ' senior reactor operator (SRO) trainee in an evolution where he "ups11fted the pump and both seals were degraded and they blew out". RIPPY said that he then stepped back and "let the real reactor operator take over" (Exhibit 20, pp. 6 7).

RIPPY stated that his position in the control room ir near the center, with his desk looking toward the "P680" control panel where the reactor controls are located (Exhibit 20, p 12-13).

RIPPY related that the control rod insertion went smoothly, and the leakage was (4) four gpm.-The limit that would cause concern would be (5) five gpm '

which RIPPY described "would require us to reduce that leakage within four hours or. shut down" (Exhibit 20, p. 13, 15).

RIPPY related that an asterisk located by the-loop isolating procedure (*8.2.4) indicates that the steps that follow are to be performed in sequential order (Exhibit 2: Exhibit 3, p. 17: Exhibit 20, p 17).

RIPPY, when reciting the procedural steps associated with 3302.01, *8.2.4 stated that step 8,2.4.4 was not a procedure step. He described it as "more of a note". RIPPY'S reasoning was that 8.2.4.4 was "not telling you to do

- anything". He further stated that "It's saying before you can do the step.

which follows, you're to meet certain conditions". According to RIPPY, the procedure step "says arior to isolating CPD injection flow, cool down to less than 250 degrees" (Ex11 bit 20. p. 20).

RIPPY acknowledged that at this point, they were in a " normal condition".- and further stated they attempted to cool down to less than 250 degrees. However, according to RIPPY, it was not cooling down to less than 250 degrees. RIPPY was also unable to recall how long they waited for the loop to cool down to

<250 degrees Fahrenheit and further, he was unable to recall if anybody had indicated how long it was going to take to cool down to 250 degrees Fahrenheit. RIPPY stated that they would be watching for a trend which could

( be established in five minutes or an hour (Exhibit 20, p. 20 21).

AGENT'S NOTE: It was estimated, according to EARL, that it would take six to eight hours to cool down to 250 degrees Fahrenheit (Exhibit 8, pp. 28 30). At 2030 (8:30 a.m.). The loop temperature was around 530 degrees Fahrenheit and Case No. 3 96 047 19

had only decreased about 10 degrees Fahrenheit. The Shift Technical Advisor (STA) or one of the Reactor Operator's-(RO) performed a quick calculation and estimated that the time it would take to reach cool down would be about 6 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (Exhibit 6, p. 27; Exhibit 27, p. 10 11). .

RIPPY related that he did not make the decision to bypass procedure step 8.2.4.4.-According to RIPPY, EARL directed RIPPY to go on to the next step.

RIPPY said that he did not question EARL because after EARL explained what he wanted done, it made sense to RIPPY. RIPPY referred to the decision as

" operating judgement" RIPPY related that this situation was not discussed in l the pre evolution brief. RIPPY related that he didn't recall any operators questioning step 8.2.4.4 being bypassed (Exhibit 20, pp. 21 23, 25).

AGENT'S NOTE: In an attempt to increase the recirculation loop cooldown be forcing CRD water into the loop. This was performed out of sequence from the procedure. It was to be performed only in event of an emergency condition (system / seal leak). This was before the leakage rate increased (Exhibit 18.

p.2).

AT 21:30 (9:30 p.m.) RIPPY indicated they entered step 8.2.4.3 of CPS 3302.01. This was a fairly simple call, according to RIPPY, because the leakage was at five gpm and they. were "under a four hour clock" and "in an unusual event". RIPPY further stated that they made the transition to call it an emergency condition. They then shut the 1B33 F0238 valve. RIPPY said that since the 75B valve had previously been closed. they.were at 8.2.4.4 again.

RIPPY said that the emergency condition described in 8.2.4.4 applied. RIPPY stated that they held at 8.2.4.4, trying to cool down (Exhibit 20,- pp. 29 31).

RIPPY acknowledged that at 21:59 (9:59 p.m.), the decision was made to go ahead and shut the CRD injection flow because the leak was not getting better (Exhibit 20..p.33).

AGENT'S NOTE: This step was performed contrary to procedure. The procedure l stated that prior to isolating CRD Injection Flow, certain conditions had to be met. The conditions were that the loop was to be cooled down to less than 250 degrees Fahrenheit, or, if the RR seals had failed, that the loop was to be depressurized to approximately drywell pressure (Exhibit 18, p. 3).

RIPPY referred to 4001.01, reactor coolant leakage, step 4.6, and stated that "It's directing me to attempt to locate and isolate the leakage, and we were attempting to isolate it." (Exhibit 20, p. 34).

. RIPPY said he was instructed by EARL to shut the CRD injection flow. (step 8.2.4.6 of 3302.01, *8.2.4) (Exhibit 3 p. 17: Exhibit 20, pp. 35 36).

RIPPY responded to the question of whether there was any pressures brought

.forth by management toward him or the shift supervisor to keep that reactor running as much as possible without shutting it down by saying "no pressures whatsoever" (Exhibit 20, p. 37).

Case No. 3 96-047 20

i Interview of MORGENSTERN. Exhibit 20 MORGENSTERN, the CPS plant manager, whose duties include the management of the operations, maintenance, radiation protection and outage functions at the plant, reports to Wilfred CONNELL, the site-vice president of CPS.

MORGENSTERN stated that he had been the plant manager at CPS since early 1994 (Exhibit 21, pp. 5 6).

MORGENSTERN stated that the seal in the recirculation pump, B seal, had been degrading over a period of time and it was reaching a point where it was resulting in leakage -into the dry well floor drain system (Exhibit 21. pp. 6-7).

HORGENSTERN stated that on or about September 5,19%, he met with Kevin MOORE,_the director of operations who was acting in his stead, indicated that the seal had continued to degrade. MOORE, according to MORGENSTERN, indicated that a four (4) gpm floor drain rate had been set as a point in time in which action would be taken to isolate the seal (Exhibit 21, p.7-9).

On September 5, 1996, at an 8:00 a.m. meeting, MORGENSTERN said it was annour.ced that at 6:00 p.m. that day, they would commence transitioning the plant into a single loop configuration. HORGENSTERN said that he conferred-with MOSLEY on at least two occasions that day to inquire.as to the readiness of the crew, and to ensure a thorough and proper briefing and understanding of what they were going to do (Exhibit 21, pp. 8 10).

HORGENSTERN stated that he discussed the contents of the brief with MOSLEY and was comfortable with MOSLEY'S description of the content and how it would be conducted (Exhibit 21, p. 10).

MORGENSTERN stated that about 9:00 p.m., he received a phone call from MOSLEY informing him of the status of the isolation process. According to MORGENSTERN, MOSLEY informed him that the pump had been secured and the leakage had increased above (5) five gallons per minute and that in accordance with technical specifications, it was appro:riate to call an " unusual event".

MOSLEY, according to MORGENSTERN, informed lim that the steps to isolate the loo) had not been completed. MORGENSTERN said that he then drove to the plant.

(Ex1ibit 21. p. 11-12).

MORGENSTERN stated that when the leakage reaches (5) five gallons a minute, technical-specifications require that you isolate that leak wichin four hours or otherwise proceed-into a shut down (Exhibit 21, p.12).

MORGENSTERN related that upon arriving at the )lant (2208,10:08 p.m.), he walked into the control room area H0SLEY saw lim and they then stepped out

-, for a discussion. MOSLEY, according to MORGENSTERN, brought him up to speed on where they were at that time. The leakage rate was approximately five and a

. half (gpm) but' not over -six. MORGENSTERN said that following the shift -he participated in a post shift meeting for about 15 or 20 minutes, both to hear and contribute, and that he remained at the plant until after 1:00 a.m. the next day (September 6, 1996). (Exhibit 18. p. 3: Exhibit 21, pp. 13 15).

Case No. 3 96 047 21

MORGENSTERN stated upon questioning that he expected the 3rocedures in CPS 3302.01 to be carried out in sequence, due to the asteris(. However.

MORGENSTERN also related that 8.2.4.4 is a caution, not specifying action, and that executing step 8.2.4.5 without having first reached 250 degrees Fahrenheit was permissible (Exhibit 21, p.17 20).

AGENT'S NOTE: This response by MORGENSTERN is in direct contradiction to his statement that the steps n.re to be carried out in sequence.

MORGENSTERN stated "the decision on whether to keep the plan in single loop or shut the plant down is ours, always has been ours", and further denied that any pressures came to bear on him to maintain single loop operation (Exhibit 20, pp. 28 30).

Interview of BROTHERTON. (Exhibit 23)

BROTHERTON was the "A" reactor operator (RO) at CPS on September 5,1996 under EARL, the SS (Exhibit 23, pp. 4,5 and 8).

BROTHERTON acknowledged that prior to executing the procedure, there were two briefs, one by EARL and the other brief wherein RIPPY was the main participant with others including himself conducted portions of the briefing (Exhibit 23, pp. 6 7).

According to BROTHERTON, the purpose of the evolution that evening was to transition from 100 percent power operation to single loop operation with the B loop isolated. This was BROTHERTON'S first time to isolate the loop other than in training (Exnibit 93, p. 8).

BROTHERTON, as the A operator was stationed and was specifically monitoring the standby information panel as his primary duties (Exhibit 23, pp. 8-9).

BR0fHERTON also stated that he was aware of the fact that this was a scheduled and previously organized activity, some of which had been coordinated with the load dispatcher. For a normal scheduled activity, according to BROTHERTON, there is coordination with the dispatcher. BROTHERTON further indicated that normal weekly down powers would be coordinated with the dispatcher to let him know what kind of load reduction he can expect (Exhibit 23, pp.10-12).

AGENT'S NOTE Conversations between the Electric Supply Service Coordinators and CPS were revealed in the transcripts of ta)ed conversations during the week of September 2,1996. On Thursday, Septem3er 5,1996, conversations between RIPPY and the coordinators, revealed that the discussions revolved around the timeline for the evolution and down power activity. At 19:01:26 (7:01:26 p.m.), The coordinator wanted to know "what was the reason we're unloading Clinton", RIPPY responded that there was unexplained leakage in the drywell, and they would be forced to shut down at 5 gom. Conversations between CPS and the coordinators were continuous throughout tie evening (Exhibit 12.

pp. 4 5).

BROTHERTON ackr,0wledged that when doing the procedure, he had a copy of the

• procedure at his desk. He also related that at step 8.2.4.4, they were Case No. 3-96-047 22

-.y waiting for.the loo) to cool down to less than 250 degrees and the leakage at this time was not a>ove 5 gpm. BROTHERTON further related that they were at 511 degrees when they went to step 8.2.4.5, not <250 degrees Fahrenheit before

. . shutting the 1833 F075B valve of step 8.2.4.5 (Exhibit 23, pp.1518).

BROTHERTON acknowledged that he was responsible for shutting the valve identified as 1833 F075B and indicated there was a discussion as to what would aid in the loop cool down. He indicated that the thinking was that if they shut 1B33 F0758, it would force the RD injection down through the loop, which would aid in the cool _down, which according to BROTHERTON, seemed to make sense. BROTHERTON further said that he closed the valve because he was directed to by RIPPY and he did not voice concern about shutting the valve before the cool down to 250 degrees had occurred, and he didn't believe he was violating any procedure (Exhibit 23, p.19 22).

BROTHERTON indicated that he considered step 8.2.4.4 of CPS 3002.01 as confusing and in need of interpretation. According to BROTHERTON, most of the procedures require some degree of interpretation (Exhibit 23, p. 22 23 and 25).

BROTHERTON denied that during the briefing for the event, his assertion that 8,2.4.4 had to be interpreted was addressed (Exhibit 23, p. 32).

Brotherton denied that by attempting to cool down the reactor loop to 250 degrees, they were attempting to avoid going into the technical specification requiring a shutdown should they fail to identify and slow the leak to under 5 '

-gpm within (4) four hours (E), bit 7: Exhibit 23, p. 33).

Interview of SHEFFIELD. Exhibit 24 SHEFFIELD, the "B" reactor operator on the night of September 5, 1996 working under EARL, indicated that he was 3 resent at a brief by EARL where he was told that they would be shutting down t1e RR pump, loop B. SHEFFIELD also said:that he attended the are-evolution brief conducted by RIPPY, and briefed by others.

SHEFFIELD said t1at he conducted the brief on the RR o>erating procedure, and the Shift Technical Advisor (STA) Dave H0 DEL briefed a) normal reactor coolant flow. abnormal reactor coolant-leakage and a reactor scram (Exhibit 24, p. 6-8).

SHEFFIELD said that he briefed that they were going to try to go into-procedure and normally shut down-for the shutdown procedure._ SHEFFIELD

. identified the section that he briefed as procedure 3302.01 sections 8.2.1 and 8.2.4 and 8.2.3. SHEFFIELD also indicated that this procedure is asterisked and the asterisk means the steps are to be done in sequence (Exhibit 24, pp.

8 9, 23).

SHEFFIELD stated that he did not have procedure 8.2.4 to read from when he briefed it, and-this was=one-of the:first briefs that he had given on an-evolution such as this. SHEFFIELD recalled that the A man (BROTHERTON) had reviewed the procedure, and it would be steps that BROTHERTON would be doing.

SHEFFIELD said that basically what he said was that BROTHERTON would be doing those steps (Exhibit 24. pp. 9 11).

Case No. 3-96-047 23

AGENT'S NOTE: See BROTHERTON'S comments that this was his first time to isolate a loop since training, and this was SHEFFIELD's first time to be l involved in isolating a loop, and RIPPY's only previous experience was an unsuccessful evolution while he was a trainee. The three individuals most directly responsible for manipulating the reactor controls to go into single loop had no previous experience since training and RIPPY's experience was an unsuccessful attempt to isolate the loop. SHEFFIELO who stated that it was his responsibility to brief 8.2.4 stated that he had a copy of the procedure at the time of the brief, but did read from it instead he relied on BROTHERTON having briefed the procedure.

SHEFFIELD identified who had responsibility for each step of 8.2.4. He stated that step one (1) would be performed by the A man. Hatt BROTHERTON, and that step two (2) would also be performed by BROTHERTON and that step three (3) was an "if then" which would be performed by BROTHERTON. Step 4 (8.2.4.4),

however, according to SHEFFIELD was not anyone's responsibility but stated that "we would all be watching it cool down". SHEFFIELD eventually stated that.

it would be RIPPY who would indicate that they were at the condition of less than 250 degrees and to go on (Exhibit 24, pp. 11-12).

AGENT'S NOTE: SHEFFIELD's statement that RIPPY would be the person to state that they were at the condition of less than 250 degrees and to go on reveals that he understands the procedural step 8.2.4.4 means to cool down to 250 degrees before continuing to the next procedural step. -

SHEFFIELD acknowledged that both he and BROTHERTON did have a copy of the procedure at their desk (Exhibit 24, pp. 13 14).

SHEFFIELD denied that he was aware of any requests by IP to keep the reactor in single loop operation if at all possible. However, SHEFFIELD stated that he knew if everything went right that's where they were headed (Exhibit 24, p.

17).

SHEFFIELD stated "we looked at step four and step four looked to us like it only applied to the 26 valve,1C11F026B" [ step 8.2.4.6]. SHEFFIELD stated that "that night, step five can be performed while waiting at step four". SHEFFIELD acknowledged that he did not question doing step (5) five before reaching 250 degrees Fahrenheit SHEFFIELD, when asked who told them to that step five (5) could be performed while waiting at step four (4) responded " I don't know if we were told that or if we interpreted it that way and went ahead with it."

(Exhibit 24, pp. 24-27).

SHEFFIELD stated that if the section is asterisked, then you are suppose to follow it in order, and he acknowledged that he considered step four of 8.2.4 a procedure step (Exhibit 24 pp. 32-33).

SHEFFIELD stated that he did not question the decision by the SS to perform step five (5) without having first allowed the loop to cool down to 250

• degrees Fahrenheit (Exhibit 24, p.34).

Case No. 3 96 047 24

._ . . __N

i t

L -Interview of H0 DEL (Exhibit 25).

.H0 DEL, the Shift Technical Advisor (STA), indicated that his duties were to protect the nublic and to keep an eye'on whats going on in the control room.

and to make sure that the control room is operating within the boundaries of the technical specifications and procedures (Exhibit 25, pp. 4 5),

1 H0 DEL stated that if he were to see something that was not being ooerated within those boundaries, he would stop the activity or at least raise his voice and say that he didn't think this is something that should be done.

However he said that in his years of experience he never had to stop an activity because he thought it was unsafe or not within the bounds of

-procedure-(Exhibit 25, pp. 5 6).

-HODEL indicated that on Seatember 5, 1996, at 3:00 p.m., he was present at a briefing held by EARL to tie operating crew which was going to be particiaating in the isolation of loop B, which he had never before performed.

He furtler related that he personally covered "off normal" procedures during the pre evolution briefed by RIPPY, According to H0 DEL, they were going to go to single loop because leakage was increasing and they had a limit that was set a (4) four gallons a minute at which time they were to go into single loop..It was determined, according to H0 DEL, that at 1800 (6:00 p.m.), they were going to go to single locp (Exhibit 25, pp. 6 7, 910).

I H0 DEL stated that he would normally position himself behind the "A" man or behind the line assistant shift supervisor (RIPPY), where he had access to all-  !

the panels and had no obst uction and could hear discussions (Exhibit 25, p.

-12,15).

H0 DEL related that whenever there was a decision being made in this procedure, there would be a long discussion which would include the line Gary MOSLEY, the SS (EARL). and himself (HODEL) talking about the ste)s as they went'along.

H0 DEL recalled that EARL agonized over the decision to slut the 1C11 F026B

[ step 8.2.4.6] valve prior to allowing the loop to cool down to 250 degrees Fahrenheit. H0 DEL said that it was a tough decision because-it's a procedure-step and EARL didn't want to violato a procedure step to do that. H0 DEL stated that they also discussed the 1B22 F075B [ step 5) valve. H0 DEL later said he did not know what EARL was agonizing over (Exhibit 25, pp. 16,17, 19-20, 27-28).

AGENT'S NOTE: There are two occasions when the *8.2.4 procedures required a cool down to <250 degrees Fahrenheit. In a " normal condition", step 8.2.4.4 requires a cool down to <250 degrees Fahrenheit before proceeding to step 8.2.4.5. The cool down addressed by H0 DEL was not conducted in accordance with procedure *8.2.4. during the initial attempt to isolate loop B. Furthermore. A cooldown to <250 degrees Fahrenheit was also required following closure of. #

1B33 F0758 after establishing the "IF" statement of step 8.2.4.3 which states

" loop suction isolation is required due to an emergency condition (system / seal leak). The "THEN" statement reads to shut 1833 F075B. This valve had already been closed out of sequence in ste) 8.2.4.5 as previously indicated. The cool down statement of 8.2.4.4 states t1at under emergency conditions, cooldown to

< 250 degrees Fahrenheit before proceeding to step Case No'. 3 96 047 25

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8.2.4,6 and the closing of valve IC11 F0268. According to EARL, they were in - i an emergency condition which caused then to re enter the procedure at step 8.2.4.3 (Exhibit 3, p. 17: Exhibit.7: Exhibit 8, pp. 36 37).

H0 DEL stated that he specifically remembered EARL saying not to close the "26" (IC11 F0268) valve, and then waiting and discussing it at length with CAMERON and himself. H0 DEL said that he (HODEL) was looking for advice from CAMERON (SE). H00EL stated that it was his (HODEL'S) decision following a discussion with CAMERON wherein it was discussed that there would be more damage to the seal, if they did not wait for the cool down to shut the 26 valve and less damage if they did wait to <250 degrees. H00EL stated that he determined that it was okay, because the seals were going to be replaced anyway and he didn't think with further degradation they would have a problem in the dry well ,

(Exhibit 25, p. 17-18)

H0 DEL, when asked why they did not wait for the tem >eratures to cool down to

<250 degrees stated "I think that we were greater tlan five gallons per minute at that time, and at that time, we had four. hours to shut down. Unless the leakage was reduced to less than five gallons per minute, we would be in a shut down situation"-(Exhibit 25, p. 18).

AGEU'S NOTE: H0 DEL, whose stated duties were to protect the aublic and to keep an eye on what's going on in the control room - and to ma(e sure that the control room is operating within the boundaries of the technical specifications and procedures, accepts responsibility for directing EARL not to operate in accordance with written procedures.

Interview of PERRYMAN (Exhibit 27)

PERRYMAN, a reactor operator was called to be an extra reactor operator on EARL's shift on September 5, 1996. PERRYMAN related that he was present during the time that 3302.01, *8.2.4 was performed but he performed no action.

PERRYMAN stated that he observed the pump being shut down and the closure .of

. the discharge valve (Exhibit 27.-pp. 3 9).

PERRYMAN related that after the discharge valve was shut (step 8.2.4.3) They agreed that 8.2.4.4 did apply, that they needed to cool down the loop.

PERRYMAN indicated that he performed a calculation to determine how fast they were cooling down, to give an estimate of at what time they would be at that point. His calculations indicated it would require about (6) hours at which time, MOSLEY calculated it himself, arriving at 6.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (Exhibit 27, p.10-11).

PERRYMAN indicated that he discussed with EARL that the procedural step (8.2.4.5) which closes the "75 valve", could be accomplished. PERRYMAN ,

further stated that if you shut the 75 valve (step 8.2.4.5), the one (1) gpm that usually goes out through that line, would go into aid in cooling the seal and also in cooling the loop itself. PERRYMAN reosoned that this step (8.2.4.5) was-appropriate because the step proceeding it (step 8.2.4.4) directed the RO not to isolate the CRD injection flow prior to reaching 250 Case No. 3 96 047 26 l

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degrees Fahrenheit. PERRYMAN reasoned that executing step 8.3.4.5, which is shutting the 1B33 F075B valve, would not violate step 8.2.4.4 (Exhibit 3, p.

17: Exhibit 27, pp. 11 12).

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PERRYMAN stated that at that tim, it was considered an unidentified leak, so they had four hours to identify the leak or stop it. At the end of four hours, if the leak could neither be identified nor reduced to under (5) gpm a shutdown statement would be entered. PERRYMAN acknowledged that if they were to wait (6) six hours for the loop to cool down to 250 degrees, then they would be into the technical specification requiring a mandatory shutdown (Exhibit 27, p. 14 15).

PERRYMAN did not believe he was conducting this procedure out of sequence,  ;

- because he indicated that he believed that the step (8.2.4.4) applies to step 8.2.4.6 (Exhibit 27, p. 25).

PERRYMAN stated that EARL directed RIPPY, who directed the A man to perform ste) 8.2.4.5 out of sequence and the A man apparently had no objections (Ex1ibit 27, p. 26).

Regarding the closing of the 1C11 F026A valve (step 8.2.4.6), PERRYMAN stated that he did not agree with closing that valve prior to cooling down to 250 degrees Fahrenheit and voiced his disapproval to EARL. PERRYMAN felt that closing that valve prior to reaching 250 degrees Fahrenheit would over stress the seal and probably blow the seal. PERRYMAN felt that EARL was going to allow the loop to cool down in accordance with PERRYMAN's observation.

However, PERRYMAN said that when EARL step >ed off to speak to MOSLEY. he (PERRYMAN) told BROTHERTON the A man what ne felt was an agreement by EARL with him to throttle back, keep everything cool, keep the seal cuoi and get out of the leakage rate. According to PERRYMAN, BROTHERTON responded "okay".

PERRYMAN, then left for lunch, thinking the loop was isolated and they were waiting for things to cool down (Exhibit 27, pp. 30-31, 34-36).

PERRYMAN indicated that once he left the control room to eat lunch, there was a decision to shut the "26" valve as opposed to his discussion and understanding with EARL. PERRYMAN stated that upon_ returning to the control room, the seal- temperature had risen, exceeding the seal cavity temperature alarm (Exhibit 27, pp. 36-37).

AGENT'S NOTE: the decision not to allow the loop temperature to cool down to

<250 degrees Fahrenheit prior to closing the 1C 11-F026B valve was the second violation of conducting procedure *8.2.4 out of sequence.

Interview of MILLER (Exhibit 28)

MILLER, the NRC Senior Resident Inspector (SRI) at CPS, indicated that he was present in the CPS control room during the shift supervised by EARL on

. September 5, 1996. MILLER stated that he was present in the control room

-because the plant was experiencing leakage on the B RR loop seal. The plant was planning to reduce power and isolate the B loop into what would be considered single-loop operation, maintaining the plant at approximately 70 percent power (Exhibit 28, pp. 4 5).

Case No. 3-96-047 27

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HILLER, who attended the briefing, stated that CAMERON told the crew that he did not expect to.see any problems with that seal during this event and he gave the crew a sense that although there was potential for problems, CAMERON did not believe there would be any problems (Exhibit 28. p. 6).

MILLER stated that he observed what he described as surprise oy the RO upon determining that it was necessary for the loop temperature to get down to <250

' degree Fahrenheit. PERRYMAN, according to HILLER, calculated that it would require somewhere in excess of (6) hours before the loop would cool enough to meet-the procedural requirements (Exhibit 28, p. 9 10).

MILLER related that there was an attempt to increase the cool down, through a seal staging line which can divert (1) one gallon of water away from the seal

-and back to the equipment -(step 8.2.4.5). According to MILLER, the action of directing (1) one gpm into the loop was, from an engineering standpoint, like waving-a fan at it. MILLER observed that they did shut the IB33-F075A valve at which time the seal leakage at the RR pump went from less than (4) four gpm to greater that (5) gpm. This amount of leakage now put them in the technical specification statement which directs the operators to identify the leakage in four hours or.~ enter a shut down statement (Exhibit 7: Exhibit 28, pp. 10-11).

At (5) five gpm, CPS was required to report to the NRC that they've entered an-unusual event, they then considered it an emergency and re entered the procedure at step 8.2.4.3. The operators again failed to cool down to 250 degrees Fahrenheit in accordance with step 8.2.4.4. (Exhibit 28, pp. 12 15).

AGENT'S NOTE: The unusual event report was conducted by H0 DEL at 2110.

MILLER stated that he did not have a copy of the procedure in hand, and his main concern was the seal. MILLER stated that CAMERON was questioned about what would happen to the seal when the loop temperature was exposed to

- tem 3eratures in the high 400s. CAMERON responded that the 0 rings in the seal paccage were the concern in that they had been exposed to 600 degrees for-several hours and had not failed (Exhibit 28, p. 17).

MILLER resaonded that he was unaware that the R0s were not going by procedure.

MILLER emplasized that his concern was 'with the seal. Exhibit 28, pp.1819).

. MILLER stated that he became aware of the procedural-violation the next day _ i (Exhibit-28, p.'23).

. MILLER stated that he called STOEDTER and upon her arrival, showed her the-

- temperatures on the seal (Exhibit 28, p.19 20).

Interview of STOEDTER Exhibit 29)

STOEDTER, an NRC resident inspector at CPS acknowledged that she was present in the CPS control room as a result of a 10:15 p.m. phone call from MILLER, requesting relief, as he had been on duty since 6:00 a.m. that morning. The Case No. 3 96 047 28

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CPS R0s had already isolated the loop prior to her arrival. ST0EDTER observed that MORGENSTERN was present in the control room upon her arrival. (Exhibit 29, p. 5 9).

- ST0EDTER was asked if she was aware of anyone in the control room that evening, discussing any concerns. ST0EDTER responded that the only concern she could recall was voiced to her in irt,trviews conducted after the event occurred. ST0EDTER identified PERRYHAN as having stated that when the crew had discussed shutting the CR0 seal injection valve (8.2.4.6), that he PERRYHAN had indicated maybe'they should consider throttling that valve instead of fully shutting it (Exhibit 29, p. 10 ell).

STOEDTER was asked when it was that she first learned tha' there had been a procedural violation, during the isolation of the B loop? ST0EDTER responded that it was not until the following day [ Sept. 6, 1996] that she noticed an asterisk next to *8.2.4 in the procedures and became aware there had been a procedural violation (Exhibit 29, p. 11 12).

Acent's Analysis A review of the testimony indicated that H0SLEY, EARL, CAMERON and H0 DEL were fully aware that the *8.2.4 procedure required that each step be performed sequentially. During the events of the evening of September 5,1996, these four individuals all agreed to violate procedure *8.2.4 by failing to wait for the RR feedwater to cool down to <250 degrees Fahrenheit as required by step 8.2.4.4 before proceeding to close the 75 B valve (step 8.2.4.5). Later during the event, these individuals-made the same decision and ignored the-procedural requirement to wait for-the required cooldown to <250 degrees Fahrenheit.

Although there were discussions between CPS and the Bulk Power Coordinators, the testimony did not indicate that this was a motivating factor for the procedural violations.

-According to SHELTON, an Illinois Power Bulk Power Coordinator, the plan on September 5, 1996 was for CPS to come down in >ower that evening, and isolate the pump, go into single loo) operation, and tien come back up to power at some level. According to SHE_ TON, the discussion between his office and the CPS was how much power CPS could generate after they had gone into the single loop. operation. According to SHELTON, CPS thought they could produce 30, 40 megawatts more than what he originally was told in the first call in the morning of September 5, 1996.

HOSLEY, the AD0 at CPS, stated that the load dispatcher had asked whether or not CPS was going to shut down Friday night (September 6) so that the load

, dispatcher could plan for the weekend. According to MOSLEY, this was discussed at CPS with the plant manager, Roger HORGENSTERN and other directors on

. (Thursday) September 5, 1996.

The shift briefing and pre evolution briefing, which took place on the afternoon of December 5, 1996, were attended by the operating crew and briefed by members of that crew. They all knew that they were going to isolate the B Case No. 3 96 047 29 a

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reactor recirculation loop, in accordance wit , ,ocedure No. 3302.01. The reactor operators consisted of an A reactor operator (BROTHERTON): and a B reactor operator (SHEFFIELD), both of whom hold a valid NRC license. The supervisors wre the Assistant Line Shift Supervisor (RIPPY) and Shift ,

Supervisor EARL. Also in attendance were the Assistant Director of Operations MOSLEY, backup Reactor Operator PERRYMAN, a System Engineer (CAMERON), and a Shift Technical Advisor (HODEL). There were other assorted individuals in attendance, including the NRC Senior Reactor Inspector.

Regarding CPS procedure No. 3302,01, *8.2.4, Idle RR Loop Isolating, is to be performed in the sequence as written. EARL. the Shift Supervisor acknowledaed that it is a reauirement that the orocedure be oerformed seouentially as indicated by an asterisk on the procedure. CPS No. 1005.14 Rev 4. page 9 paragraph 8.1.11.4 states that if a s)ecific order of aerforming the procedure is required, use an asterisk (*) at tie beginning of t1e section to annotate that the steps are to be performed in the sequence that they are written.

H0SLEY stated that the leak rate was acoroximately 3.9 apm at the time of the pre .iob brief and advised that at 5.0 com unidentified flow rate. the technical specification reauires that leakace be restored to within the limit within a four hour time period CPS RCS Operational Leakage Procedure 3.4.5 states that RCS Operational.

Leakage shall be limited to less than (5) gam unidentified leakage. If unidentified leakage is not within limits tie required action is to reduce leakage to within limits in 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or commence shutdown of the plant.

The procedure required that at step 8.2.4.4 of nrocedure *8.2.4 the loop be allowed to cooldown to <250 degrees Fahrenheit before proceeding to step 8.2.4.5.- However, after allowing approximately 20-30 minutes-for the cooldown, EARL was advised by PERRYMAN and MOSLEY that the required cooldown would require a total of (6) six hours, which would put CPS into a Technical Specification requiring shutdown.

MOSLEY further indicated that they were doing a normal loop isolation and attempting to cool the loop down to less than 250 degrees Fahrenheit (step l 8.2.4.4) when H0SLEY agreed that the next step. 8.2.4.5 was an a)propriate

-step to help cool the loop down. Mosley said that the reason belind that decision was to drive what little bit of flow that was going out the staging line - to hel) cool that loop off. MOSLEY said that they had 500+ dearee water that had to 3e cooled down within a four period. MOSLEY indicated that the decision to ao forward to 8.2.4.5 without allowino it to cool down to 250 decrees Fahrenheit was a combined decision between himself. the shift

-supervisor (EARL) and the system enaineer (CAMERON).

PERRYMAN, a. standby reactor operator advised EARL that to cool the loop down faster, the )rocedure did_ not preclude the closure of the seal staging valve.

1833-F075B w1ich would direct approximately (1)-one gallon of water into the loop B to help in cooling it down. This was a direct violation of the procedure being advocated by PERRYMAN. Accordingly, H0 DEL, the Shift Technical Advisor whose purpose was to make sure that the control room is operating Case No. 3 96 047 30

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l within the )oundaries of the technical specifications, recalled that EARL l agonized over the decision to shut the valve, stating that it was a tough i

decision for EARL, because it was a procedure step and EARL didn't want to

. violate a procedure step. H0 DEL related that whenever there was a decision beina made in this procedure. there would be a lona discussion which would include the ling. Gary MOSLEY. the shift supervisor (EARL). and himself (HODEL) talkina about the steDs as they went alona. H0 DEL recalled that EARL agonized over the decision to shut the 1C11 F0268 fsteo 8.2.4 61 valve orior to allowing the 1000 to cool down to 250 decrees Fahrenheit. H0 DEL stated that the_y also discussed the 1822.F0758 fsteo 51 valve. H0 DEL later during the interview stated that he did not know what EARL was agonizing over. H0 DEL stated that he specifically remembered EARL saying not to close the "26" (1C11 F0268) valve, and then waiting and discussing it at length with CAMERON and himself. H0 DEL said that he (HODEL) was lookina for advice from CAMERON (SE). H0 DEL stated that it was his (H0 DEL'S) decision followina a discussion with CAMERON wherein it was discussed that there would be more damaae to the seal. if they did not wait for the cool down to shut the 26 valve and less damaae if they did wait to <250 decrees. H0 DEL stated that he determined that it was okay. because the seals were coina to be replaced anyway and he didn't think with further dearadation they would have a problem in the dry well.

At 2159 (9:59 a.m.), the loop temperature, according to MOSLEY, was just under 500 degrees Fa1renheit and the leakage rate was between 6 (six) and 7 (seven) gpm when Control Rod Drive (CRD) IC11F026 B valve (step 8.2.4.6) was closed.

MOSLEY stated that he discussed with EARL whether or not they should go ahead and shut the CRD 1C11F026 Bravo valve and EARL agreed. MOSLEY stated that he also talked with the system engineer (CAMERON) about what he was going to do.

CAMERON allegedly told MOSLEY that he (CAMERON) didn't feel that by closing the valve, it would cause a major problem at the seal.

With an unidentified leakage of (5) five gpm or more, or total leakage not within limits, an action requirement 3.4.5 required the reduction of leakage within limits in (4) four hours below the limit or action was required to shut down the plant within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Earl indicated that at the time he was relieved, there was about an hour and 20 minutes left to ao on the four hour action reauirement ior cettina down below five callons per minute. EARL stated that following his shift. the leak eventually stabilized at about ten gpm.

EARL further described his conversation with CAMERON in that CAMERON.

accordina to EARL. indicated that the valve (1833 F0758) if closed would not damaae the RRS. EARL further stated that before he went ahead with shuttina the 1833 F075B valve. he discussed his intended action with MOSLEY.

EARL indicated that his reason for wanting to shut the valve (1833-F075B. step 8.2.4.5 prior to completing the cooldown required by step 8.2.4.4) was he

" thought" that was his next action to perform and "the fact that we would be able to get the loop isolated in a more timely fashion". The coal . accordina to EARL was to shut down and isolate the source of leakage to continue to operate the plant".

CAMERON stated that "we tried to wait for the loop to cool down or to depressurize. It did not depressurize. It was also not cooling down."

Case No. 3 96-047 31 1

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i p l According to CAMERON. MOSLEY and EARL did talk to him about shutting.the 1B33-L F075B valve (step 8.2.4.5) to try to cool -the -loop down and he was asked L whether there would be an adverse effect on the seal. CAMERON said he did not feel- that it would challenge thi seal. By shutting the valve, according-to -

CAMERON, you're forcing more cooling water down into the seal and CAMERON-didn't think it would hurt the seal (Exhibit 19, pp.1617, 2122).

' CAMERON related however that there was no reason why the cool down wasn't allowed to take six hours and he didn't recall why there was a push to try to accelerate the cooling process. CAMERON said that he was remiss in not focusing on the actual steps of- the procedure (Exhibit 19, p. 23).  :

Testimony indicated that HOSLEY, EARL, CAMERON, and_H0 DEL all had some responsibilities and participation in the decision to violate CPS procedures.

All concurred with the decision not to wait until the recirculation loop cooled to <250 degrees Fahrenheit and proceeded to close the 75 8 valve, in violation of procedures.

The deliberate violations by MOSLEY, EARL, CAMERON and H0 DEL were an effort to reduce leakage to a rate less than 5 GPM to avoid a technical- specification which would require a reactor shutdown.

Conclusion -

Based on the evidence developd during the investigation, it is concluded that the Assi: tant Director for' Plant Operations Gary MOSLEY: the Shift ,

Supervisor. John EARL: the Recirculation System Engineer, CAMERON: and the Shift Technical Advisor. Dave H00EL, mutually agreed to deliberately violate procedures required by Technical Spccification 5.4.1. to maintain power

. operation.

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Case No.- 3 96 047 32 i

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SUPPLEMENTAL INFORMATION On December 12. 1996. William P. SELLERS Esq., Senior Legal Advisor for Regulatory Enforcement, General Litigation and Legal Advice Section Criminal Division, U.S. Department of Justice Washington, D.C., was apprised of the results of the investigation. Mr. SELLERS advised that, in his view, the case did not warrant prosecution and rendered an oral declination.

J Case No. 3-96-047 33

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LIST 0F EXHIBITS Exhibit No. Descriotion

-1 Investigation Status Record 3-96 047, dated september 9, 1996.

2- CPS procedure No. 1005.14, stating that procedural steps are to be performed in the sequence they are written whan an asterisk is at the beginning of the section, undated.

-3 CPS procedure No. 3302.01, *8.2.4 " Idle RR Loon Isolatina",

dated February 25, 1996 4 Hanagement Meeting Illinois Power Company, NRC Region III, dated September 23, 1996.

5. Copy of " Critique.0P 96 0005", Critique of Unusual Event due to exceeding Technical Specification Limits for Reactor Coolant Lc'kage on September 5.- 1996, dated September 6, 1996.

6 Copy of letter to Mr. A.B. (Bill) BEACH from Wilfred CONNELL i regarding " Assessment Results and Action Plan in Response to Event i Involving "B" Reactor-Recirculation Pump Seal Failure and Associated NRC Confirmatory Action letter", Dated September 16, 1996.

7 Reactor Coolant System Operational Leakage 3.4.5 Procedure, undated.

8 Transcript of Interview with EARL, dated September 13, 1996.

9 Copy of " Guideline for RR B Loo) Isolation and RF Leakage Evaluation", undated, bearing t1e typed name of Gary J. H0SLEY.

10 Reactor Recirculation and Flow Control System chart signed by John- ,

P._ EARL and dated September 13. 1996.

11 Transcript of Interview with 5HELTON, dated October 29, 1996.

12 Transcript of conversations between Electric Su) ply Service 4 Coordinators and Clinton Power Station during tie week-of

. September 2, 1996.

13- A memo to E.P. Bader from Gary McCoy of Nuclear Financial Services and M.J. Walther indicating a financial recommendation regarding -l Single Loop Operations dated August 14, 1996.

14 A memo from J.R. ROTON.- Jr., Senior Resident Inspector, Zion Nuclear Generating Station, to OI:RIII dated October 2,1996 Case No. 3 96 047- .35

i i 15 Memorandum for the record from R. ROT 0N, Senior Resident Inspector. Zion Nuclear Generating Station, dated September 10, 1996.

16 Transcript of interview with Gary MOSLEY, dated September 13, 1996.

17 Copy of Operations Self-Assessment Task Card prepared by G.

HOSLEY, dated September 5. 1996. _

i 18 Copy of ' Chronology of 9/5/96 Clinton Event" prepared by NRC, undated.

19 Transcript of interview with Keith CAMERON, dated October 29, 1996.

20 Transcript of interview with L. Randy RIPPY, dated September 13, 1996.

21 Copy of CPS No. 4001.01, Reactor Coolant Leakage, dated May 19, 1995.

22 Transcript of interview with R. MORGENSTERN, dated September 13, 1996.

23 Transcript of interview with M. BROTHERTON, dated October 29, 1996.

24 Transcript of interview with Kenneth Sheffield, dated October 29, 1996.

25 Transcript of interview with David H0 DEL, dated October 29, 1996.

26 Transcript of interview with Wilfred CONNELL, dated October 29, 1996.

27 Transcript of interview with Fred PERRYMAN, dated October 29, 1996.

28 Transcript of interview with the NRC's CPS Senior Resident Inspector Michael MILLER, dated November 6, 1996.

29 Transcript of interview with the NRC's CPS Resident Inspector Karla STOEDTER, dated November 6,1996.

Case No. 3 96-047 36 I

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