ML20198R151
| ML20198R151 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/05/1997 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20198Q977 | List: |
| References | |
| NUDOCS 9711130168 | |
| Download: ML20198R151 (70) | |
Text
--
I 1
UNITED STATES OF AMERICA lf 2
NUCLEAR REGULATORY COMMISSION i
?
I j
3
+++++
b 4
OFFICE OF INVESTIGATIONS 5
INTERVIEW 6
x 7
IN THE MATTER OP:
8 INTERVIEW OF
- Docket No.
4 9
ALFRED J. CAYIA
- (not assigned) 10 11
x 12 Wednesday, March 5, 1997 13 C.
14 Point Beach Nuclear Plant 15 Site Boundary Control Center 16 Two Rivers, Wisconsin 17 18 The above-en'.itled interview was conducted at 19 9:30 a.m.
20 21 BEFORE:
22 RICHARD L. DEVITTO Investigator 23 24 25 9711130168 971112 EXHlBIT /[
PDR ADOCK 05000266 NEAL R. GROSS 0
PDR COURT REPORTERS AND MNSCRSERS PAGE
/ OF 70 P/GE(S) 1833 MHoDE ISLAND AVE., N.W.
CMXQ 3H4433 WASHINGTON. D.C. E100H701 (202) 334-4433 SMElO.3m9V.0084 a
.i 1
ALSO PRESENT:
.6 k
- i. a 3
-MR. TONY MCHURTRAY, 4
Point.aach Nuclear Regalatory Commission 5
Senior Resident inspector 6
7 8
MR. JOHN O'NEILL, 9
Shaw Pittman Potts & Trowbridge 4
10 2300 N Street, N.W.
11 Washington, D.C.
20037 12 (202) 663-8148 13 14 15 16 17 18 19 20 21 22 23 24 25
,NEAL R. GROSS CoVRT REPORTERS AND TRANSCRIBERS 1823 MHODE ISLAND AVE., N.W.
M 3844433 WASHING 10N, D.C. 3000H701
$m2) 3344433
}
6 o'
J 1
JMDX1 1
2 KITHEBB 3 03 1
+
-/
3 ALFM.D J. CAYIA 4
Examination by Mr. DeVitto 7
9 5
Examination by Mr. McMurtray 55 6
Examination by Mr. O'Neill 55 7
}
e s
10
?
11 12 I
?
12 EXHIBITS IDENTIFIED 4
14 A
11 15 B
37 16 17 i
18 19
.s 20 21 22 23' 24
(
2s NEAL R. GROS 5 COURT REPORTERS AND TRANSCRISERS 1 ails RHODE ISLAND AVE N.W.
M as44433 WASHINGTON. D.C. 3D01b4701 (302) 234 4433
._ -.._ l:1 _.
(I t
1 P-R-0 C-E-E-D-I-N-0-8 l
2 (9:30 a.m.)
I i
1 3
INVESTIGATOR DEVITTO:
Good morning.
For the 4
record, this is an interview of Alfred J. Cayin, who is 5
currently employed by Wisconsin Electric at the Point 6
BeRch Nuclear Plant, Two Rivers, Wisconsin as the plant 7
manager.
8 The location of the interview is at the Site 9
Boundary Center at the Point Beach Nuclear Plant, Two 10 Rivers, Wisconsin.
11 Present at this interview and representing the 12 U.S. Nuclear Regulatory Commiss, ion is Special Agent 13 Richard L. DeVitto of the Office of Investigations Chicago
,(,i
~~
14 Field Office, and Point Beach Nuclear Regulatory CommissionSeniokResidentInspectorTonyMcMurtray.
15 16 Rcpresenting Wisconsin Electric is John O'Neill, of the 17 firm of Shaw Pittman Potts & Trowbridge out of Washington, 18 D.C.
19 As agreed, this interview is being 20 electronically recorded by Ron LeGrand of LeGrand Services 21 and will later be transcribed.
22 The subject matter of this interview concerns 23 Wisconsin Electric's February 20, 1997 written request to 24 the NRC requesting enforcement discretion regarding 25 service water and component cooling water requirements at HEAL R. GROS 5 COURT REPORTERS AND TM.NScRIBERS
- 1323 RHODE ISLAND AVE., N.W.
(302) 2H4433 WASHINGTON, D.c. 3000H701
$102) 2H4433 NI
{
1 the Point Be:Ch NuSICar Planto 1 and 2.
2 Mr. Cayic, would you plcOco ctand and we'll 3
give you the oat at this point?
i-
{
4 Whereupon, 5
ALFRED J. CAYIA, s
was called as a witness herein, after having been first 7
previously sworn, was examined and testified as follows:
e INVEsTI ETOR DEVITTO:
Mr. O'Neill, would you 9
please state the nature of your representation here today?
10 MR. O'NEILL:
I represent Mr. Cayla 11 individually, and Wisconsin Electric Power Company.
12 INVESTIGATOR DEVITTO:
Mr. Cayla, with the 13 knowledge that Mr. O'Neill represents both the company and i
~
14 yourself, are you comfortable with that representation 1
15 today?
16 MR. CAYIA:
Yes, I am.
17 INVESTIGATOR DEVITTO:
Okay, thank you.
Mr.
18 O'Neill, you mentioned untlier that you had a document for 19 us that you wanted to. introduce?
I'think it san something 20 we asked for yesterday.in our transcription.
21 MR O'JtEILL:
Doring the interview of Mr.
22 Douglas Johnson yesterday, you asked him if there were any 23 drafts of the letter that was submitted to the NRC on 24 February 20, 1997 requesting an enforcement discretion.
25 Yesterday, Mr. Johnson and Mr. Malanowski searched the
-NEALR. GROSS COURT REPORTERS AND TRANSCNSERS 1833 MH00E ISLAND AVE. N.W.
M 3K4438
- fASHINGToN, D.C. NocH701 9043344433 3
. - _ _ =
m--
q I
computcr filco and d;tcrain:d that tha criginal draft th t
!t 2
Mr. Malanowski had referred to in his interview, that he 3
had drafted in the evening of February 19, 1997, was on 4
the system and he printed a copy of that draft that he 5
recalls as the draf t that he put on the system on February 5
19, 1997 at 10:15 p.m.,
and I have a copy of that draft 7
with me today, which you requested and I will submit to a
you and I suggest it be marked as Exhibit c for these 9
interviews.
10, It is a draft, we marked it for information 11 only.
As originally drafted, it was what was then taken 12 by Ms. Flentje and later Mr. Johnson, which eventually 13 became the letter of the 20th.
so I submit that to you 14 now.
15 INVESTIGATOR DEVITTO:
Okay.
We'll mark this 16 as Exhibit C.
Is this our copy?
17 MR. O'NEILL:
Yes, it is.
1B INVESTIGATOR DEVITTO:
Oh, okay fine, thank 19 you.
Mr. McMurtray, would you want to examine this before 20 we get going here?
Why don't we go off the record and 21 we'll have Mr. McMurtray examine the document.
22 (Whereupon, an off the record 23 discussion was had.)
24 INVESTIGATOR DEVITTO:
Back on the record.
25 EXAMINATION NEAL R. GROSS COURT REPORTERS AND T1%NBCR18EA9 1323 RHODE ISLAND AVE., N.W.
(302) 334 4433 WASHINGTON, D.C. 3000H701 (302) 334-4433
{
1 INVESTIGATOR DEVITTO:
Sir, would y;u p10000
[
2 Ototo ysur scme fcr th3 rocord?
l 3
MA. CAYIA:
My name is Alfred J. Cayla.
4 INVESTIGATOR DEVITTO:
And how do you spell l
l 5
Cayia?
6 MR. CAYIA:
C-a-y-i-a.
7 INVESTIGATOR DEVIT20:
Okay.
And your date of 8
birth?
9 MR. CAYIA:
My date of birth is 10 INVESTIGATOR DEVITTO:
And your Social 11 Security Number?
12 MR. CAYIA:
My Social Security Number is g 23 @
14 INVESTIGATOR DEVITTO:
And where do you 15 currently live?'-
16 MR CAYIA:
I live in 17 INVESTIGATOR DEVITTO:
Could we have the 18 address please?
19 MR. CAYIA:
I live at 20 INVESTIGATOR DEVITTO:
And is there a phone 21 you could be reached at there?
'Ny phone number is @
22 MR. CAYIA:
Yes.
h 23 24 INVESTIGATOR DEVITIO:
Thank you.
Can you 25 please state for the record any formal education or NEAL R. GROS 5 COURT REPORTERS ANDTMANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
g pot) 3344433 4ASHINGToN, D.C. 30006 3701 (302) 3H4433
~
-~~
- 4 r
(
1 profccolon21 c0rtific;tc0 Cr trcining th t you po;0cO?
2 MR. CAYIA:
Yes.
- 7. have a Bachelor of Science
?
3 degree from the United States Naval Academy in Annapolis, 4
I graduated from there in 1974.
I have a 5
Masters of Business Administration from New Hampshire a
5 College.
That degree was earned in 7
Also in 1987, I was licensed as a Senior 8
Reactor Operator by the United States Nuclear Regulatory 9
commission.
And I believe that's probably the sum of, 10 other than short courses and other things, other smaller 11 certificates that I've earned, those are the significant 12 educational certificates or licenses.that I've held.
13 INVESTIGATOR DEVITTO:
Okay.
Where are you 14 currently employed?
15 MR. 'CAYIA.
I'm employed by Wisconsin Electric 16 Power Company at the Point Beach Nuclear Plant.
17
. INVESTIGATOR DEVITTO:
Okay, and your current i
18 title and position that you occupy?
I I
19 MR. CAYIA:
I am the Plant Manager for Point 20 Beach.
I 21 JNVESTIGATOR DEVITTO:
Can you give'us just a i
22 brief summation of your duties as plant manager?
I l
23 MR. CAYIA:
Yes.
I have overall 24 responsibility for the day to day operation of the 25 facility.
The functional areas that are under my
-NFA1 R. GROSS l
coORT REPoMRS ANDTRANSCRIBERS l
saa3 RHoDE ISLAND AVE., N.W, pur) 2344433 WASHIN3 ton, D.C. 2000W01
-4202) 234 4433 Ir I
. ~.
I rocpon0ibility inslud3 operctions, Mainten nca, H;olth 2
Phyaic], Chenictry, th3 Production Plcnning Orgcniccticn 3
and the site Engineering organization.
4 INVESTIGATOR DEVITTO:
What about any 5
oversight over licensing?
~
6 MR CAYIA:
I do not.have any direct oversight 7
responsibilities over licensing.
8 INVESTIGATOR DEVITTO:
And how long have you s
been in the position of plant manager?
10 MR. CAYIA:
I assumed the plant ir.anager 11 position on, I believe it was August let of '96.
It was l2 either August ist or July 1st, I'm not sure exactly which 13 month it was.
i 14 INVESTIGATOR DEVITTO:
Okay.
And previous to 15 that, what posit' ions did you occupy?
16 MR. CAYIA:
Previous to that, I was the 17 production manager for the Point Beach Nuclear Plant.
18 INVESTIGATOR DEVITTO:
Okay.
Did you indicate 19 what year you started with Wisconsin Electric?
E 20 MR. CAYIA:
I did not.
21 INVEST.TGATOR DEVITTO:
Okay.
22 MR. CAYIA:
I started with Wisconsin Electric 23 on January 17th of 1994.
24 INVESTIGATOR DEVITTO:
And in what position 25 was that?
NEAL R. GROSS coOMT REPORTERS ANDTRANSCRIBERS tats RHODE ISLAND AVE., N.W.
905 334 4433 WASHINGTON, D.C. 3DOOH701 9 02) 384 4433
_ _. =
I 1
MR. CAYIA:
I w;D tha production man:g:r Ot 2
th0t point in time.
- O' 3
INVESTIGATOR DEVITTO:
How about any previous 1
4 experience in the nuclear field?
5 MR. CAYIA:
Previous to my employment with 6
Wisconsin Electric, I was employed by Maine Yankee Atomic 7
Power Company.
8 INVESTIGATOR DEVITTO:
And in what type of a 9
role?
10 MR. CAYIA:
My last position with Maine Yankee 11 was,as the Operatione Manager for Mainc Yankee Atomic 12 Power Company.
13 INVESTIGATOR DEVITTO:
Do you have any 14 experience in licensing in your past.
4 15 MR'.'CAYIA:
'Yes, I do have soma experience in 16 licensing in my past.
17 INVESTIGATOR DEVITTO:
Okay.
And who would 18 that have been with?
19 MR. CAYIA:
With Maine Yankee Atomic Power 20 Company.
.21 INVESTIGATOR DEVITTO:
And what type of role 22 was that?
23 MR CAYIA:
I was for some period of time was 24 the, initially the acting licensing section head for Maine 25 Yankee.
NEAL R. GROSS COURT REPORTERS AND TRANSCR$ERS f
1323 Ril ODE ISLAhD AVE., N.W.
002) 2M4433 WASHINGTON, D.c. 20005 3701 (202) 2344 433
1 INVESTIGATOR DEVITTO:
OkOy.
Who d3 you
.t 2
currcntly rcport to in th3 man:g; ment hicrcrchy?
.O.
l.
3 MR. CAYIA:
I currently report to Mr. Scott 4
Patulski, who is the Site Vice President for Point Beach.
5 (Whereupon said document, Exhibit 6
A was marked for identification.)
7 INVESTIGATOR DEVITTO:
What I'd like to do at 8
this time, Mr. Cayla, is call your attention to a document 9
we have marked as Exhibit A.
And if you would just care 10 to look at that please.
It's an enforcement discretion 11 for the record, which was dated February 20, 1997.
12 (Pause.)
13 MR. CAYIA:
This apptars to be the fax that we C,.
14 transmitted to the agency on the afternoon of February 15 20th.
16 INVESTIGATOR DEVITTO:
When did you first see 17 this document, if you can recall?
18 MR. CAY 16.:
I first saw thic document, let's 19 see, the 20th was I believe Thursday.
I saw the document 20 some time af ter lunch on Thursday.
It was, I'd come back 21 to my office and the document, a draf t, mot this, but it 22 was an early version of this, was on my chair.
23 INVESTIGATOR DEVITTO:
Okay.
So it would have 24 been sometime on the 20th afternoon, are'you saying?
25 MR. CAYIA:
I believe it was sometime after NEAL R. GROSS COURT REPORTERS AND TRANSCRl6ER$
ist3 RHoDE ISLAND AVE., N.W.
902) a344433 WASHINGToll, D.c. aD00H701 902) a34 4433 9 hMS-am *
.M9
$w g --
_W-*'**4
-'W e
W
ij h
1 lunch time,?tha cftornoon of Fcbrutry 20th.
{'
2 INVESTIGMOR DEVITTO:
Now, Mr. O'N3111
(},1
[
-3 provided me a' document here, which apparently.is an e
[
4 earlier virsion whish we have marked as Exhibit C on 5-February 19th.
Are you f amiliar with that document also?
[
6 MR. CAYIA:
If Mr..D'Neill Indicated earlier 7
that this was the first draft of the document and I can a
say that I did not see this partienlar document beenuse I 9
would have Temembered.
My name is en here signing it, 10 that I never saw, I don't Talieve I saw a version where I 11.
was the signatory on the document.
So I don't believe-I 12 saw this particular document.
13 INVESTIGATOR DEVITTO:
Is there any particular C
14 reanon why you were put down here as the_ potential _-signer 15 of the document, as opposed to the 20th document which is 16 signed by Mr. Johnson?
17 MR._CAYIA:
I would not know the, answer to i
18 that:/ question.
19 INVE&TIGATOR DEVITTO:
Okay.
So this' is 20 something that licensing would -have done on their own?
-21 MR. CAYIA:
I,.if Mr. Malanowski drafted that 22 document, then I would have to say that Mr. Malanowski put 23-that on there, last I don't know why.
24 INVESTIGATOR DEVITTO:
Okay.
Is it protocol 25 that you generally sign off on these types of documents or NEAL R. GROSS cCURT REPORTERS ANDTRANSCNSERS 1sts RHCDE ISLAND AVE., N.W.
ger)as444a mAsHINGTON, D.C. ED053m1 (s;q 334 4433 N,
m.
.m f
1 nSt?
lI 2
MR. CAYIA:
Currently. bb' position of
\\
l 3
Wisconsin Electric is that correspenaer.ce going to the 4
Nuclear Regulatory Commission is signed either by Mr.
5 Johnson, or I believe in some cases Mr. ratulski, as site 6
Vice President, or Mr. Grig as the Chief Nuclear Officer, 7
may also sign documents. It depends on the type of l
8 document.
9 INVESTIGATOR DEVITIO:
Okay.
This particular 10 document, again we're referring to Exhibit A, the one on 11 the 20th, did you contribute in any way to this document, 12 as far as providing any kind of resourciit or any kind of 13 institutional knowledge or any kinc* of oversight or
}
C 14 insight?
15 MR.'CAYIA:
"I did provide comments to that 16 document, as did other members of our staff during the 17 development as w" went through the draft and revision 18 process.
19 INVESTIGATOR DEVITTO:
If you could recall 20 approximately when you got going on the preparation of 21 this notice of enforcement discretion?
When would this 22 process have started?
23 MR. CAYIA:
The process started sometime on 24 the, I believe it was sometime on Wednesday the 19th of 25 February.
-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 2344 433 WASHINGTON, D.C. s00063701 (302) 234 4433
_E h*,-
.m
INVESTIGATOR DEVITTO:
OkGy.
W0ro you-in any I
t 2
kind of lcnd rolo or providing cny evorcight to thio I
3 particular action?
4 MR. CAYIA:
I was in a lead role in providing 5
oversight for the action as the, I'm also, as plant 6
manager, the chair of the inanager supervisory staff, which 7
is the on site review committee.
8 During the course of the day on the 19th, 9
there were, I recollect, some discussions that different 10 individuals had relative, -and primarily some of the senior 11 staff at the plant, as to the efforts to correct the 12 problem with the IP11 alpha component cooling water pump.
13 And discussions started relative to if we, our first 14 priority was to correct the problem with the IP11 alpha 15 component cool'ing water' pump, within the limiting
~
16 condition for operation time period in the technical 17 specifications, so that we could stay in conformance with 18 the tech specs.
13 our repair activities, we actually had two i
20 activities going on.
The repair activities were focusing 21 on the component cooling water pump.
Sometime on I 22 believe it was the 19th, discussions started probably 4
23 early in the morning, as to 4that we should do, or what 24 would-be the safest course of action in the event that the 25 repairs were unsuccessful.
So I was taking advice from NEAL R. GROS 5 COURT REPORTERS AND TRANSCRIBERS
/
1323 RHoDE ISLAND AVE., N.W.
652)2344433 WASHINGTON, D.C. 300053701 4302) 2364433 4
4 6
7 3 -
f I
come of our ccnier ctoff membero, our duty cnd en11
+
2 superintendents who are also, act as my surrogates in my
'0, 3
absence, to decide what the safest course of-action was 4
for the facility to stay in conformance with our technical.
5 specifications and focus on completing the necessary 6
repairs for the component cooling water pump.
7 INVESTIGATOR DEVITTO:
Okay.
And again, you 8
mentioned this all was taking place or started on the 19th 9
or --
10 MR. CAYIA:
It was, those discussions were 11 probably in progress early the morning of the 19th.
Some 12 discussions may have started late the afternoon of the 13 18th.
I don't specifically recollect.
C.
14 INVESTIGATOR DEVITTO:
Was this some type of 15 working group th'at you were dealing with at this point, or 16 an ad hoc group or --
17 MR. CAYIA:
Well, there was no formal 18 committee or ad hoc working group.
The way we do our day
~
19 to day business at the facility, we have a morning nesting 20 where the leadership of the primary functions meet to 21 receive status of activities that are ongoing with the 22 units, and ensure that we stay focused on the priorities 23 for the day.
24 So we start out with the meeting where we 25 bring the line organization and support organization NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
(202) 2M4433 WASHINGTON, D.C. 200064701 cm:0 234 4433
_ _... ~ ~ ~
~~
_ii..-
1 tog 3th;r.
That 10 o formal me3 ting th;t we havo cnd we t
2 typically, we r:coivo ctetuo, varify that tho work JG l,
3 activities as directed by the operations organization and 4
supported by maintenance and engineering, have the right l j, E
focus, and we basically follow that plan for the rest of 6
the day. _And we repeat that meeting every morning.
7 so if there is no formal committee as such, 8
but there is a clear line organization reporting 9
relationship beneath me, that together we direct the 10 activities that go on at the station during the day.
11 INVESTIGATOR DEVITTO:
Is this generally 12 referred to as your 6:45 meeting?
13 MR CAYIA:
This is our 6:45 plant status C.,
14 update meeting.
15 INVE'STIGATOR DEVITTO:
How many people are 16 generally in attendance, do you know?
17 MR. CAYIA:
It depends.
It ranges anywhere 18 from I would say a minimum of 15 to, yesterday we probably 19 had 35 people in the meeting.
It depends on what's going 20 on, what other off site meetings we may be conducting, but 21 there's generally representation from all the line i
22 organization that support the control -- plant activities.
23 INVESTIGATOR DEVI7TO:
So.is this a mandatory 24 meeting that your supervisors and staff people need to 25 attend or --
-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1823 RMODE ISLAND AVE., N.W.
902)2344433
. WASHINGTON, D.C. 20005 3701 (202) 2344433 w
m f
1 MR. CAYIA: _ No, - it 10 not.
2 INVESTIGATOR DEVITTO:
Okay.
It's kind of an O
3
-- type situation, depending on the issues?
4 MR. CAYIA:
Well, it really depends on what l
5 other activities are going on.
I don't always attend r
6-myself.
I may have a meeting in Milwaukee or*an off site 7
meeting that is higher priority, I will go to that.
had a
that's the same for some of my group heads.
We generally 9
if feasible, they will have nome representation there, 10 somebody in their organization, but generally either I'm t
11 there or my duty and call superintendent who is my 12 surrogate if I'm not on site.
13 INVESTIGATOR DEVITTO:
Is there a
~
C>,
14 representative from licensing that generally attends?
15 MR.'bAYIA:
There is at times a representative 16 from our Regulatory services Group.
That sometimes would 17 be the manager of the group, other times it may be one of 18 the individuals that works in Regulatory Services Group.
19 I would say generally they're represented, but not all on 20 days necessarily.
21 INVESTIGATOR DEVITTO:
Calling your attention 22 to the meeting on the 19th, can you recall some of the 23 participants at that meeting?
24 MR. CAYIA:
Sure.
The morning of, let's see, 25 the 19th, that's Wednesday morning the 19th at 6t45.
NEALR. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 rho 0E ISLAND AVE., N.W.
(302) 334-4433
%ASHINGToN, D.C. 30006 4701 (202) 234 4433
)
1 l
~' - -
r w
=
1j 1
That'o o littlo moro difficult.
My gunoo lo I wno 1
2 probably th;ro, but I have, relative to this particular
/
3 issue, have clearer recollection on the 20th, because of 4
the issue that was raised.
But on the morning of the 5
19th, since we have this meeting virtually every day of 6
the week, I cannot give you an exact list of participants.
7 Typically, most of the group heads would be there; the S
shift supervisor, I do not recollect who the shif t 9
supervisor was there for that day, but the day shift shift l
10 supervisor starts the meeting-and leads the meeting, and 11 presents the plant status.
12 But as far as the other participants on the 13 morning of the 19th, I don't have an exact recollection.
i 14 INVESTIGATOR DEVITTO:
Okay.
Do you remember 15 on the 19th, if'any insties cropped up relative to the 16 operability of the component cooling water system and 17 especially the valves being in overtorqued position?
'18 MR..CAYIA:
On the morning of the 19th, I do 19 not believe and I have no recollection that any issue with 20 the component cooling water valve surfaced.
21 INVESTIGATOR DEVITTO:
Okay.
Just one other 22 question relative to this Exhibit A document again, the 23 NOED or notice of enforcement discretion, do you generally i.
24 have any type of a concurrence or signature page that goes 25 along with this document to indicate that you've signed MEALR. GROSS COURT REPORTERS ANDTRANSCRIBERS 1823 RHODE BLAND AVE., N.W.
(202) 236 4433 WASHINGTON, D.C. 3000H701
$102) 234-4433 M**"W9-@'t*-@+Mbe.
W-4& em -
__ w q g
New N _
-4 w
- e + 1 -4NT-'
e
gg 1
off en it, cinco ycu cro not tho oign:r of racerd?
2' MR. CAYIA:
No.
3 INVESTIGATOR DEVITTO:
You don't --
4 MR. CAYIA:
I don't, no.
For this particular 8 -
5 document, and as it was developed, there was no supporting 6
document that would have, where I was required to nign off 7
on this document.
8 INVESTIGATOR DEVITTO:
Okay.
Ist me ask you 9
as far as a plant policy, is,there a plant policy as far 10 as concurrence pages on documents such as this?
11 MR. CAYIA:
As they are developed?
~
12 INVESTIGATOR DEVITTO:
Yes.
13 MR. CAYIA:
The, and de're talking about 14 correspondence with the agency?
15 INV STIGATOR DEVITTO:
This :nay be somewhat 16 unusual.
I don't know how many NOED's you've become 17 involved in.
18 MR. CAYIA:
Oh, for NOED's?
19 INVESTIGATOR DEVITTO:
Yes.
20 MR. CAYIA: -Actually, this is I believe the 21 first4 TOED that I've personally become involved in.
It's 22 the first one that I've personally become involved with 23 since I have worked for Wisconsin Electric.
24 INVESTIGATOR DEVITTO:
Well, let tne rephrase 25 it.
What about any correspondence, and this being NEALR. GROSS count nerontens Anoinescasens 1323 nH00e ISLAND AVE., N.W.
9 02) 2344433 WASHN3 TON, D.c. sDOOM701 9 02) 2344433 u._
_.__. c.._...
}
1 cerro pond:nco to tho'NRC, 10 thoro o policy?
?
L 2 MR. CAYIA:
I cm not cw2ro of cny particulcr policy that would require where, let's say me for yxample 3
4 o:: other particular disciplines might sign off on a 5
docament.
I'm not aware of one.
6 INVESTIGATOR VEVITTO:
Okay..Another question 7
-- that would be, what about a retention and destruction 8
type of policy relative'to draft do iments, notes that 9
were used to produce draf t documents?
In there anything 10 on file with Wisconsin Electric or with the Point Beach
-e4 11 that covers that?
12 MR. CAYIA:
I am not aware of a policy that 13 govern:: the disposition of' draft documents as a document C.
_ 14 goes through the development process.
If there is a 15 policy, I'm not aware od it.
16 INVESTIGATOR DEVITTO:
Okay.
I,et's move on then, on k.he 19th you had your staff meeting or you had 17 18 your 6:45 meeting --
19 MR -CAYIA:
Right.
~
20 INVESTIGATOR DEVITTO:
-- and there obviously,
-21 there were mome discussions.you mentioned, relative to 22 this course of enforcement discretion?
23
-MR. CAYIA:
Well, on the 19th --
24 INVESTIGATOR DEVITTO:
Was there'any casual 1
25 talk or --
-NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHoDE lSLAND AVE., N.W.
$02) 234-4433 WASHtNGTON, D.C. 30005 3701 9 02) 234 4433 M*h6e W
- N N g _
M
.@N
3 1
MR. CAYIA:
-- thoro w 0, yao, I can rccolloct; p
8 2
some_ casual talk from come members of the staff, li f
3 recommending that we seek enforcement discretion from the
-4 agency.- I can tell ycu that when that first came up, I 5
was not in favor of that..And it seemed to me that it L
-6 was, it potentially detracted our focus-from our efforts 7
to correct the problem and fix the component cooling water 8
pump.
-9 And the say it was initially characterized by 10 some members of the station staff -was, why don't you dust 11 go ask the agency to give us more time.
And my initial-12 view was, why and what is the basis for that.
We then
. 13 during the 19th, started some discussions, different 14 people had come to me and at that point in time, we startedtolookbardat, because it became, it was-15
- 16 becoming more clear that we, well, initially we thought we 17 would make the-repairs in the needed-time.
That was another reason why it did not make sense to =ne personally, 18 19 to approach the agency,.because it appeared to me that we 20 would be able to stay in conformance with the technical
-21 specifications.
22 When we raalized that that appeared to not be 23 feasible, and that feedback was comincj from both the main
- 34
-- engineering organizations, and then we started to look 25 at where was the plant in the safest condition.
And at NEAL R. GROSS count neomnS AND TRANSCNSER8 1323 RHODE ISLAND A% N.W.
(EXQ 3344433 iMASHINGTON, D.c. 3000HM1 poig 2344433
=
-OO 69h
_ _, g gm p g
- q e
es:p gw
,i..
!i 1
that point in time, wa ctorted looking very hnrd ct both is J
-2 tha technical cpecifications, wa colicited input from our
.}
l 3
operations leadership from senior -- operators, as to E
4 where did it make sense to place the plant while we a
f
's completed the repairs.
6 so during the day on the 19th, probably by 7
late morning, those discussions where underway with a
various members of the staff.
It wasn't until I bezlieve 9
after lunch, af ter noon time on the 19th, where we started 10 to pull together a working group to assess both the pros 11 and. cons for either maintaining the plant in its curre'nt 12 condition, or complying with the technical specifications, 13 which'would have required us to cool down the plant on a 14-single component cooling water train.
15 so those discussions were underway the late 16 morning afternoon of Wednesday the 19th.
But at that i
17 point in time, we had not formally requestad or even la ' decided to request enforcement discretion.
19 INVESTIGATOR DEVITTO:
Can you recall who was 20 part of that --
21
-MR. CAYIA:
I tan recall some of the 22 individuals.
The operations representative was the 23 Assistant Operations Manager, Carl Grey.
Fritzy Flentje 24 was providing support from -- services.
Doug Johnson was 25 observing and participating.in those discussions.
Let's NEAL R. GROSS
/
COURTMEPoRTERS ANDTRANSCNSERS
~ 1325 MHotA ISLAND AVE., N.W.
get asemas WAsHNrf0N, D.C. 300064m1 (300 2344433 e
mei.-men m.
p. e T' -- ~ ~ -- - - - -
23 i
1 000, I belicyo that Mainten*_nca wna repra00nted by Dred p
li 2-Fromm.
I'm trying to remember'the faces.
I don't
- i. -V 3
remember the specifics.
We subsequently did have a staff i
4-meeting on the 19th, and I could go back and get.some i'
s exact names, but I don't remember all the names that 6
participated in the formal on site review committee
- 1 meeting, but we were relying heavily on Mr. Grey's a
operations experience to assess the plant conditions.
9 In fact, we had had,our working group meetings
~
(
10 down la the basement of the technical support center, in a V
11 room where we had up on a white board the pros and cone 4
12 from a safety standpoint, of maintainingthe plant in the condition it was in, which was basically with reactical 13 d
14 and system added temperature of approximately 380 degrees, 15 1100 pounds in pressure, steaming both steam generators, 16 and the safeguards emergency safety systems enabled.
That 17 was the plant condition where we had taken-the plant and -
18 we were assessing from a safety basis, whether it made m
19 sense to keep the plant there or to take the plant to cold !
20 shutdown at that point in time.
21 so those, Carl-Grey had the lead on that, and r
22 had,-when we polled our working group meeting together 23 before we dialogued with the agency, we had, when we were 24 working from a white board layout ~that Carl had put up Nere,relativetotheprosandconsofstayinginthe
- 25' NEAL R. GROSS COURT REPORTERS AND TRANTNBERS i
1323 RHODE SLAND A'4., N.W.
gos) as4 4433
-W%SHINGTON,0.4. 20053mt; 5 02)1s4 4433 1
24 1
condition w3'r0 in, cnd th2 prco cnd cano of cooling tho 2
unit down to cold shutdown.
3-INVESTIGATOR DEVITTO:
Again, now this is p,
4 referring strictly to the 19th, was there any question u
5 ever entertained or ever brought up on the 19th, relative 6
to the condition of the component cooling system and the-7 cross connect valves, as far as this overtorqued position 8
9 MR. CAYIA:
No, to best of my knowledge that 10, never came up, and in fact, as part of the white board, 1
11 one of the things that we he.4 and Carl had put up on the white board, was the ccW cross connect capability [
So 12 13 there was on the 19th, there was, if there-was any 14 discussion relative to the condition of the ccw cross 15 connects, I was not aware of any.
I do not remember 16 anyone throughout the course of the 19th, discussing that.
17 During the 6:45 meeting on the 19th, we did 18 discuss the condition of the plant, the condition of the, 19 the status of the repair efforts on both the component 20 cooling water and the service water pump.
.Those were 21 clearly discussed.
And we may have even,..near the tail
.s-22 and of that meeting or during that meeting, even reli'ef 23 from the agency may have been brought up by somebody.
I 24 don't know exactly, I don't recollect.
But there was, 25 those discussions were ongoing, but any potential issue NEAL R. GROSS COURT REPORTERS AND1RANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
$102) 2344433 WASHINGTON, D.C. 20006 3701 (302) 2M 4433
1 with tha valvoo being chut hard, that wao not diccucosd en
<:e 2
the 19th.--
!gt)
}-
3
. INVESTIGATOR DEVITTO:
Who made the ultimate 4
decision, who.would have been probably reached on the 19th y
5 because that's the date of the teleconference later in the 6
day at the NRC, who would have made the ultimate decision i
7 to go' forward with this notice of enforcement discretion?
c
-8 MR. CAYIAt The ultimate decision to request 9
enforcement diceretion was reached after careful 10 discussion with the key leadership people including the
~
'+
11 assistant office manager, that this was the basis for the 12 discussion.
I did have-a number of discussions with Doug 13 Johnson and others, relative to the wisdom of requesting 14 enforcement. discretion.
I had those discussions because I 15 have always-taken, reviewed requesting enforcement discretion as an action that is not taken very lightly.
16 17 it's taken very seriously.
It's taken very seriously by is myself.-
19 There have been a number of instances in the
.20 past when I may have considered that, I don't. recollect 21 ever requesting one before.
In fact, on numerous occasions, maybe mot necessarily at--my current capacity, 22 23-but I.han previously. shut down an operating reactor to 24 stay in compliance with the technical specifications, as 25 opposed to requesting enforcement discretion.
HEALR. GROS $
COURT REPORTERS ANDTRANSCPU8ERS San RHODE ISLAND AVE., N W.
9D2) 234 4432
-WASHINGTON, D.C. 33006 3701 9 02) 334 4433 W w~-*+weno= men veem - - -
. ee n
-we
. eer-o +
-o *womew
, - ~ ~ - -
)
26 1
During~the courco of tho doy on th3 19th, Y
3):
there were, -as those discussions ensued, I was initially 2
3 reluctant to request enforcement discretion.
But as we 4-looked at the condition of the plant, the conflict in two.
9; different paragr'aphs of the came tocht,ical specification, 5
4 6
one aspect of the technical specification would have 7
required us to stay above 350 degrees.
8 Another aspect related to component cooling 9
water of the same technical specification, would have 10 required us to take the plant to a cold shutdown i.
11 condition.
There was, it became more obvious that there 12 was a disconnect.
And in fact,. as sie went tihrough this 13 process later, Mr. McMurtray and I had some discussions on 14 the 21st, relative to the disconnect in the technical 15 specifications.
We both had looked at standardized 16 technical specifications and realized that the apparent 17 disconnect appeared not only with the Point Beach 18 technical specifications, but also potentially in the improved standardized technical specifications.
19 20 We had some discussions that there were some 21 recognition in the-industry that this disc.nnect may exkst 22 and may, in fact, the NEI organization may,actually be, 23 I'm ont aware of this, but I've heard that they're having 9
24 dialor,,ue on this particular issue.
So we had this 25 disconnect between maintaining the plant above 350 degrees MEAL R. GROSS e
counTneomms ANoTamscamens tan MHoC4 BLAND AVE., N.W.
(IIDE) 334 4438
-WASHINGTON, D.C. 3DDDH701
@D2)3344433 w
4 1
Cnd tha compon:nt cooling watcr iccuo, W3 did hava o
+
2 diccuccion with cvarybody that wac cn our working group 3
representing operations,~ Maintenance and Engineering, 4
Licensing, on whether or not we should request enforcement 5
discretion.
It was the recommendation of the group, to 6
me, that we request that.-enforcement discretion.
7 Prior to having the conference call with the 8
agency where we re,tuested that enforcement discretion, we 9
reviewed the pros ar.d cons of requesting enforcement 10 discretion to allow us to atoy in the existing plant 3,
11 cos.ditien, or to cool down the plant.
And when we 12 reviewed that and Carl had had it up on the white board, 13 it was clear and I did have discussions with Doug Johnson, 14 and it became clear that, and I can say that initially I 15 don't believe either one of us, we did not, our preferred 16 course of action was to repair the pump.
We did not, our 17 preferred course of action was not to request enforcement 18 disctetion.
19 INVESTIGATOR DEVITTO:
You enantioned ' Carl,
,c20 what's Carl's last name?
21 MR. CAYIA:
Ca'! Grey.
22 INVESTIGATOR DEVITTO:
Okay.
23 MR. CAYIA:
When we looked at the safety basis
,24 for complying with the existing plant conditions and 25 either complying with the tech specs or requesting
-NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
1202) 234 4433
- WASHINGTON, D.C. 200054m1 (202) 284 4433
. -.: ~
l l
28 lI 1
cnfere: ment diceretien, from a nucloor omfoty atendpoint
's 22 it was clear to the working group and they made that
-3' recommendation to me and I solicited Doug's advice,-it was l
lj.
4 clear that the right thing to do was to request 1
5-enforcement discretion from the agency.
6 So they made that recomendation to me.
That 7
recomrundation was also, we did subsequently have a formal 8
on site review committee meeting, and it was the, and the 9
way we typically do business is that our on site review 10 committee seconsnends to either myself as the plant manager 11 or my surrogate, whoever is acting in my stead, on what to' 12 do on safe':y issues.
I do not,make those decisions 13 unilaterally.
14 So it was the collective recommendation of 25 initially the working group, and subsequently the managers 16-supervisory staff or on site review committee, to formally 17 request enforcement discretion from the Nuclear Regulatory 18 Commission.
19 INVESTIGATOR DEVITTO:
Let me ask you, based 20 on what you, the answers you just gave, did you in fact 21 concur with this --
22 MR. CAYIA:
Yes.
23 INVESTIGATOR DEVITTO:
24 MR. CAYIA:
Yes, I did.
25 INVESTIGATOR DEVITTO:
You did?
Okay.
NEAL R. GROSS COURT REPORTERS AND TRANSCREERS
'isn RHODE ISLAND AVE., N.W.
M 384 448B AMASHINGTON, D.C. 30005 3701 9 03) 234 4423
f
-1 Calling y:ur ottontion clco to Fcbruary 19th, lotor'in tha l! -
.2 day crsund 4:00 or comewhoro in that croc, did you havo t
-3 occasion to place a call to the Nkc,,or were-you 4
privileged-in being involved-in a conversation with the 5
NRC relative to this enforcement discretion?
6 MR. CAYIA: -Jes, we did place a. conference 7
call to the Nuclear Regulatory Commission to Region III, 8
to request an enforcement discretion.
9
. INVESTIGATOR DEVITTO:
Nhat role did you play 10 in that teleconference?
11 MR. CAYIA:
I would have to say that you would 12 characterize my role as spokesperson for., Point Beach 13 during the conduct of that conference ca n.
As I'd been 14 involved in the discussions and there were other people 15 that did some ta'1 king, but I probably did the bulk of the
~
16 dialogue with the agency.
17 INVESTIGATOR DEVITTO:.Do you recall who from 18 Wisconsin Electric was present or on board for that call?
19 MR. CAYIA:
I know that Doug Johnson was 20 present, Carl Grey was present, I believe Fritzy FlentJe 21 was present, Terry Sullivan, who is one of our, an advisor 22 to the President was present.
Brad Fromm, I don't
-23 recollect whether 2 rad was present.-
-24 I-know he was present in the'aubsequent staff 25 meeting, but, and I believe John Jaeckle was present as a
-NEAL R. GROSS M N AND N M 1323 RHODE ELAND AVE., N.W.
M 3344433
-9 WASHINGTON, D.C. 20006 3701 (met) 334 4433 8
___d
m_
1 rcpro ntotiva'from cur ccfoty cvaluttion grcup.
I'm 2
pretty sure he was there.
I know he had participated with l
3 Carl in the assessment of the condition and he was present i
e 4
during the MSS meeting.
Actually, Harv Hanneman was also 5
on the phone from Milwaukee, because we were looking at 6
the situation from a probablistic safety assessment 7
benefit also.
8 But I don't, I know as a minimum those folks 9
were there.
Addition people, I can't recollect at this 10 time.
2 11 INVESTIGATOR DEVITTO:
Do you know 12 approximately how long the call lasted, the length of the 13 call?
[
14 MR. CAYIA:
I would have to say it was, it 15 could be anywhere from 15 to 30 minutes.
I didn't keep 16 track of the exact time, I don't recall.
17 INVESTIGATOR DEVITTO:
And the express purpose 18 of that call was -just seek this enforcement discretion?
19 MR. CAYIA:
We discussed, that was the first 20 time, we had discussed earlier in the day I had mentioned 21 to representatives of the agency, that there was a high 22 probability that we would request' enforcement discretion, 23 but we were still working through that process.
I 24 mentioned that to John Hanneman from NRR, when he was on 25 site.
I believe at some point, I don't know, either
-NEAL R. GROSS COURT REPoMRS ANDTRANSONSERS 1323 RHoDE ndLAND AVE., N.W.
poq 2344433
-WASHING 7oN D.C. 300063701 9 02) 334 4433
,t.
.v-f 1
my:Gif or on3 of cy ctoff, informed tho racid:nto co thSt
- 2 thsy were cwaro that we were considering this.-
it may C
]
3 have been me.
- 7. don't remember exactly.
t --
4
.Let's see, exactly what was the question f
5 again?
6
'INVESTIGA'IOR DEVIT10:
If that was the express 7
purpose of the call.
t 8
MR. CAYIA:
That was, we wanted to open a 9
dialogue and discuss anforcement diseration, and to seek 10 this discretion from the agency.
11 INVESTIGATOR DEVITTO:
Do you recall making 12 any commitments at that time, relative to the operability 13 of the CCW cross connect valves?
14 MR. CAYIA. During the course of the 15 conference call, we were asked by Region III personnel, 16 what compensatory measu as we believed we had or could put 17 in place.
so we were specifically the term that was used, 18 and this is during the course of the call, Region III 19 focused us on the agency's procedure, I believe it's 9900, 20 for notice of enforcement discretion.
21 Mr. Jack Grobe I-believe, had the lead for the 22 agency in Region III,-and in fact -we walked, Region III 23 walked us through different aspects of the part 9900.
24 They initially directed us toward a part of the procedure 25 that was, would provide the basis for enforcement NEAL R. GROSS countneomns AnoTnemensEns M nHODE ISUWO AVE., N.W.
i gast)asedes 4 WASHINGTON. D.c. 2000WD1 A sD44433 l
gg 1
dicerotion-undar.tha current plcnt c:nditicn.
.P And then there were a number of things that i
3 had to happen.
One of the things in that list was i
4 compensatory measures.
And so at that point in time, we
's
~
5-discussed some compensatory measures that we were willing 6
and able to put in place.
Those were subsequently amended 7
at the subsequent on. vite review committee meeting.
8 INVESTIGNIOR DEVITTO:
Okay.
But my original 9
question was, did you make any commitments relative to the 10 cross connect system, reliability or operability?
11 MR. CAYIA:
What we, what I remember us saying 12 was that we would put, we had as a compensatory measure, e
13 we had the capability of cross connecting component 14 cooling water.
We, as part of the compensatory measure, 15 what I described during the conference call, were two 16 aspects of that.
Is that I would require the ope ations 17 crews to review the abnormal operating procedure and that 18-I would require the auxiliary operators in the field to go
~
.1 19 to the component cooling water system and to locate the 20- valves that would have to be operated if the abnormal 21 operating procedure avere Amplemented.
1 22 The intent of that was to ensure that as each 23 of tha crews came on, they had a discussion and first off 24 reviewed the procedure, just to refresh their memories, 25 and then required their field operator and the PAB, to go
- NEAL R. GROSS f
courG REPOGRS AND TRMSCNSERS 1323 RHODE ISLAND AVE., N.W.
pog z u dea 3 MASHINGTON, D.C. 32054m1 gcE) 334 4433 J- :. -.. --
w-i 1
out and locato tho valvoc.
Co that in tha cv0nt tho i
5 2
c::ntrol room chose to implement the abnormal operating 3
procedure, the auxiliary operator would know where the i
4 location of the valves was.
}'
5 so we described that the plant had the 6
capability to cross connect-the component cooling water, 7
and the commitment that was inherent in the coaipensatory 8
action, was to review the procedure upon taking the shift, 9
and to locate the valves in the field.
10 INVESTIGATOR DEVITTO:
At that time, at the
~
11 time of that teleconference, Mr. Cayin, did you have any 12 specific knowledge as to when those valves were actually 13_
opened last?
14 MR. CAYIA:
I hr.d no specific knowledge at 15 that point in time,i to when those valves had been 16 opened last.
17 INVESTIGATOR DEVITTO:
Okay.
So you had this t.
18 conversation and I take it your next reaction would have 19 been to have this NOED formalized?
20 MR. CAYIA: Actually, there were subsequent 21 things that occurred.
22-INVESTIGATOR DEVITTO:
Okay.
23 MR. CAYIA:
One of the things that, when we 24 were going through 9900 with Region III that I realized, I 25 wasn't previously aware that we had not done, was to have NEAL R. GROSS coum REromsRs AND TRMSCRSERS 1323 MHODE ISLAND AVE., N.W.
M 3344433
.4NASHINGTON, D.C. 3000H701 9 02) 334-4433 y
l' a formal mesting of tha en cito rovicw committoo.
And co 2
we concluded-that conference. call and the agency had not 0
=
3 given us any indication as to whether or not there would
-e 4
enforcement discretion gi.ven.
5 We then convened, and I was asked to have an 6
on site review committee meeting and then subsequently to 7
page Mr. Grobe.
We then pulled together an on site review 8
committee meeting, which included additional participants.
9 We tied',in om Malanowski from Milwaukee, we also had Mary 10 Hanneman who is one of our, plays one of our lead roles in 11 safety assessments.
He was on the phone from Milwaukee.
12 And so we had.a formal on site review 13 committee meeting, manager supervisory staff.
And there C
14 are, the full attendance would be described on the record 15 of that meeting.
There were at that point in time, we 16 also ensured that there were resident inspectors present' 17 with us.
In fact, during the conference call, the is original conference call, I believe that there was at 19 least one resident, I believe Mr. Louden was present down 20 in the room with us when we were dialouging with the 21 agency.
22 so we had the staff meeting, and we then the 23 manager staff recommended that I formally request 24 enforcement discretion from the agency.
I subsequently 25 paged Mr. Grobe.
We had a discussion and I also indicated
+14EAL R. GROSS
(
COURT REPORTERS AND TRANSCNSERS 1ast AriODE ISLAND AVE., N.W.
(BGE) 3844433
-4mSHINGToN, D.C. 3DOOH701 (sIE) 2344435
=
--w
1-to hin that I had additionnl compen:ctory meccuroa, jO 2
INVESTIGATOR DEVITTO:
When was this?
- 3-MR. CAYIA This was the evening of the 19th, t
4 at approximately 6:00 p.m. in the evening.
During the s.
5 manager supervisory staff ineating, additional compensatory
-I measures that'we had not originally _ discussed during the-6 7
initial phone call with the agency were recommended by the 8
manager staff, and when I had discussion with Mr. Orobe, I 9
discussed the meeting, I relayed to him that I was, 10 actually I was personally pleased with the quality of that
~
11 meeting.
We had a very good discussion, we had good 12 dialogue.
Wehadadditionalcompensatorhmeasuresinthat 13 even with the broader. audience, there was concurrence by 14 the manager supervisory staff that recommended that we
~:
15' formally request notice of enforcement discretion.
16 I convened those additional compensatory 17 measures to Mr. Grobe over the phone.
I:then formally 18 requested notice of enforcement discretion, and he 19 verbally gave the enforcement discretion, and he
.20 reiterated I believe, that we needed to formally request 21 in writing, what we had requested verbally, and that the 22 requi ement by 9900 I-believe was 114 hours0.00132 days <br />0.0317 hours <br />1.884921e-4 weeks <br />4.3377e-5 months <br />.
I.in'dicated,
23 to him that we, at that time 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would have been past 24 normal working hours, and I committed to Mr. Orobe that we I
25 would target to get the letter by close of business or by NEAL R. GROSS CoOE REPOMER. AND WNSCREDE tan RHODE BLAND AVE., N.W.
(IDE) 234 4433 WASHINGTON, Ec. 3D005 37D1 Omt) 23M433
.v-------
l l
'i 1
1600 --
2 INVESTIGATOR DEVITTO:
On th2 --
q d
t 3
MR. CAYIA:
-- on the subsequent day, on the 1
I 4
20th.
f 5
INVESTIGATOR DEVITTO:
The 20th.
Okay.
j 6
MR. CAYIA:
So those were the commitments I 7
made to Mr. Grobe.
The only people that participated in 8
that phone call, were Mr. Grobe and myself.
~
9 TNVESTIGATOR'DEVITIO:
I see.
When did you 10 actually become aware that there may have been a problem 11 with the CCW valves?
12 MR. CAYIA:
.I first became aware, well that 13 evening, we put the compensatory measures in place.
The
.C a
14 next morning at the 6:45 meeting on the 20th, I became 15 aware of that there was potentially a problem with the CCW
~
16 cross connect valves.
17 INVESTIGATOR DEVITTO:
And how did you become 18 aware of that?
19 MR. CAYIA:
At that morning meeting, at some
.20 point -during the course of the meeting, Mr..Eric Ziller 21 mentioned that those valves were he believed, shut.in the 22 past and may have been shut, I don't remember his exact 23 language, that they had been shut hard in the past to stop 24 a problem with cross leakage through the valves.
At that
}
25 point in time, I thanked Mr. Ziller for raising that
-MEAL R. GROSS COURT REPORTERS.*.ND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234 4433 WASHINGTON, D.C. 200064701 M 2344433
-a_
g g
L.
1 locuo, cnd I cck d hin to writo o cendition rsport to 2
document his recollection of the issue.
j-6 L,
3 I also asked at that point in time, if there 3
4 was anybody else that was aware of this.
Mr. Rob Harvey 5
was present in the meeting and he said yes, he was because 6
he thought in his early working days, which he thought, he 7
said something about the early 80's, that he thought he 8
had shut the valves.'
9 Now there may have been ot.hers, I don't know, 10 but he thought that.
And so that to me, there were then
~
11 two people and it just reaffirmed to me to document this 12 condition in the condition report.
So that's when I first 13 became aware that there was an lasue.
14 INVESTIGATOR DEVITIO:
That would have been at 15 f.he 6:45 --
16 MR. CAYIA:
6:45 on the 20th.
17 (Whereupon said document, 18 E.xhibit B was marked Cor 19 identification.)
20
-1NVESTIGATOR DEVITIO:
Okay.
What I have to 21 have you look at at 'this time, Mr. Cayia, is Exhibit B, is 22 a condition report.
Can p u examine that report please?
.23 MR. CAYIA: -Sure, I'd be glad to.
24 (Pause.)
25 Okay.
I looked at this.
MEAL R. GROSS count neromnS AND TRANSCNSENS 1333 nHODE ISLAND AVE., N.W.
-430s) 3344433 WASHINGTON, D.C. 2000H701
$102) 2344433
1 INVESTIGATOR DEVITTO:
Okay.
H2vo you COON 0
2 thtt rcport prior?
);
3 MR. CAYIA:
Yes.
This appears to be a s
j 4
condition report that I have seen previously.
5 INVESTIGATOR DEVITTO:
Is that the condition 6
that you referred to Tecently, as far as being brought up 7
by Mr. Ziller?
f 8
MR. CAYIA:
No, it is not.
9 INVESTIGATOR DEVITTO:
It is not?
Not brought up-.in this manner.- It i
11 was, at the morning of the 6:45, Mr. Ziller sa scribed an 12 occurrence that had happened in the past, that his belief l
- 13. that the valves may have been shut herd to stop cross p
- b 14 leakage between the two systems.
That's about the way it j
15 was characterize'd.
I'm sure those are not the exact 16 words, but that's the manner in which it was b
17 characterized, which is different in my view, and very d
18 different from the reaction that I had when I first read 19 this condition report.
20 INVESTIGATOR DEVITTO:
Who completed that 21 condition report?
22 MR. CAYIA:
Hell, the name of the initiator la 23 Mr. Eric Ziller.
.I am assuming that Mr. Ziller created 24 this condition report.
25 INVESTIGATOR DEVITTO:
You don't know?
HEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ICLAND AVE., NM.
por)as444aa
. wAsHounON, RC. 300063M1 9 02) 234 4433 g
~~
w
,p
1 MR. CAYIA:
Cut I do not know cxtetly, hio
,l0 2
signature is not on here, there's a typed name.
3 INVEST? GATOR DEVITTO:
Is that the way these 4
reports are generally completed, or is that extraordinary 5
or different?
6 MR. CAYIA:
If you look at our condition 7
reports that come in, there are generally two means for 8
condition reports.
Some are typed on the computer system, 9
some are handwritten.
We encourage our people to submit 10 these in any manner.
We don't have a requirement for 11 typed or handwritten.
It's more important to document the 12 condition, and then to assess it.
13 We have also made it very clear to our C.~
14 employees, that we just want them to write down what they 15 believe or what they know.
That doesn't necessarily mean 16 that sometimes we found out that an individual's 17 perception is maybe not accurate.
What we, what's more 18 important is that we document what the -employee believes, 19 so that it can be followed up and assessed.
20 And so,.the morning of, at the 6:45 meeting on 21 the 20th, Mr. Ziller commented and it-was basically a 22 comment that was offered up in the meeting, and that's why 23 this was different information then I'was personally aware 24 of, and I asked that he document whatever he knew on a 25 condition report.
NEAL R. GROSS CoURTREPoRTIRS ANDTRANSCRIBERS
^
135 RHODE ISLAND AVE., N.W.
(202)154 4433 WASHINGTON, D.C. 3000bWD1 (202) 234 4433 l
l t.)
m-1 INVESTIGATOR DEVITTO:
Whon did you Octually I
2 see that report the first time?
O 3
MR. CAYIA:
The first time that I would have 4
saw that report was sometime on the morning of Friday, 5
February 21st.
i 6
INVESTIGATOR DEVITTO:
Were you shocked by the 7
contents of the report or the particular --
8 MR. CAYIA:
I'm not sure I would use the word
- )
shocked.'. I was surprised at the Janguage, and I had a 10 different personal reaction than what was described at the 11 6:45 meeting the day before.
12 INVESTIGATOR DEVITTO:
Are you being' critical 13 of his style of reporting that, or exactly what?
No, no.
I just, it was not 15 characterized th'e same way, and even though it was 16 indicated on here that the valves were considered to be 17 operable, which is the same belief that I had previously, 18 it warranted additional and prompt engineering follow up 19 to attempt to ascertain and assess the actual conditions.
,20 And at that point,in time, I had requested of engineering 21 that we do a formal eperability assessment to assess the 22 condition of the valves and also to assess whether in fact 20 the valves could be in fact opened at that point.in time.
24 There was at least question, this did draw on the question 25 of whether or not the valves could ultimately be opened.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
(202) 2864433 1NASHINGToN, D.c. 30006 3701 1l20@ 234 4433 m
1 TNVESTIGATOR DEVIT10:
Okcy.
At that time 2
that you bec me cwsro of thio conditien report, which was 3
sometime on the 21st, any particular time of day, can you 4
recall?
s MR. CAYIA:
- Well,
'.t might have, it was the s
morning.' I don't romenbar exactly when I typically pick 7
up a package of condition reports.
I don't necessarily 1
e read them right away, it depends on what else is going on.
l 9
our normal process for condition reports is that we have a 10 10:00 meeting where line groups and support groups review ig 11 the condition reports that have been dropped into the 12 system for the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, to do two primary 13 things.
14 First, to assign ownership or make sure it's 15 clear as to who owns the resolution, and the second is to 16 assess-the significance of that.
This is, you know, when 17 this came up on the morning, 6:45 on the 20th, everybody
.-4 la in = the room heard the issue that Eric raised.
one of the 19 things we've been working very hard is to encourage our 20 people to document these things in condition reports.
I --
21 know that that was a pretty full meeting, a lot of our 22 group-heads were there, members of.the operations staff 23 were there, current operations staf f.
I know that Mr.
24 Keller was there and heard that this was raised.
25 And so, typically what happens is, what MEAL R. GROSS coum MeromRs ANDTWGCMS5m 13s3 RHoDE SLAND AVE., N.W.
I W14 B64433 WAMNGToN, D.C. 30DH701 500) 3b44433
}
1 happen-d the n:xt day 10, I 1cft tha mesting co did most 2
peoplo with, mont of tha group h00d3 will tche a copy of
- C.
3 the condition reports.
If the residents are there, they 4
will take a copy of the condition reports, and then it 5
gets reviewed formally at the 10:00 meeting.
6 So sometime I can may between 6:45 and 7
sometime shortly after the ten, I either, and I don't a
recollect exactly, I either read this myself or somebcdy 9
brought it to my' attention, that hey, this.is something I 10 ought to be aware of, and that we ought to do something.
11 And the something we ought to do, was to start the formal 12 operability assessment, and sometime that morning I did 13 have a discussion with someone that I wanted the valves 14 radiographed, to assess the internr.1 condition of the 4
i 15 valves.
16 INVESTIGATOR DEVITTO:
Did you notify the NRC 17 of this condition report?
18 MR. CAYIA:
It depends on what you mean by 19
- notify, because --
20 INVESTIGATOR DEVITTO:
Did you have any 21 discussions with anybody from the NRC, relative to this 22 condition?
23 MR. CAYIA:
I don't specifically recollect whetherIhadanyspecificdircussionsth.atmorning.
I do 24 25 not, or the station does not rely on me to notify the NEAL R. GROS 5 f
COURT MEPoRTERS AND TRANSCMSERS 1
13lt3 FJ:DDE ISLAND AVE., N W.
(304 3364433 WASHINGTON D.C. 30005 3m1 FCE) 3344433
,,----c,--.---m
- - ~
~-,_.,,.--w.
--.,,,,n,,
,,,ir-----,.
.. - ~.. - - -
1 cg:ney, oither on cito er off cito of cv ry cinglo 2., condition rcport'th:t comeo in.
I da havo rcutins h
3 discussions with Region III personnel, where at tinies I do 4
discuss condition reports.
I generally discuss examples 5
of those that are ongoing, but one of the things that I 6
personally rely on, and we have a pretty, we've been, 1
we're a pretty open environment with the agency, we have 8
daily discussions with the agency and Regi.in III, and our 9
residenh inspectors are generally present at our 6:45 10 meetings, and I know they participate in a variety of 11 meetings during the day and I knew that, at least at this 12 point in time, that the agency was aware that the 13 condition was raised, and the agency had access to the 14 condition reports just like I did.
15 INV$871 GATOR DEVITTO:
How was the agency 16 aware of it then?
17 MR. CAYIA:
Well, the agency was initially 18 aware because I believe at the 6:45 on Thursday morning, 19 there was a resident inspector in the 6:45 meeting who 20 heard Mr. Eiller raise the issue and I'm assuming heard me 21 ask him to write a condition report.
22 INVESTIGATOR DEVITTO:
Okay, but in the 23 context of this NOED here, did you feel that this did in 24 some way affect your commitment here?
25 MR. CAYIA:
On Friday morning, after I became NEAL R. GROSS COURT REPONERS AND TRANSCfWBERS 1323 RHODE ISLAND AVE., N.W.
M 394 4433 WASHINGTON. D.c. sD00H70: '
(302) 3344433 e
M
- y l
1 twaro of tha Icngungs and tha daccription in thio
(
4 2
condition report, I became aware and had subsequent
.s 3.
discussions recognizing that one of the things that we had j
4 agreed to do in this NORD request, was to provide an s
5 update on the status of our repair efforts at 1400 on 4
6 Friday.
7 I was aware that we would have to clarify the j
s situation, relative to the compensatory action, and j
l --
p relative to the capability that was described in this i
10 letter.
The capability 'that's described in this letter is l
{
11 consistent with the language that's described in the final 1
l 12 safety analysis report, and that there is cross connect.
13 capability for abnormal conditions.
14 So that was something I felt that during the 15 2:00 meeting, we'needed'to clarify and discuss and put l
16 some additional language in the letter relative to that.
17 aut it did not in my view, change the original-safety is basic for maintaining the plant in the condition above 350 19 degrees to conduct the repair of the conqponent cooling
^
t 20 water pump.
21 INVESTIGATOR DEVITTO:
Okay.
So the fact that 22 Mr. Zi11er reported that they had been overtorqued, that 23 didn't change your feelings --
No..When he reported it on the
.(
25 20th. 2 hnew that these.ere gate va1 es.
1 had had NEAL R. GROSS L
coum REPOMRS AND WNSCNSERS 1833 RHODE ISLAND AVE., N.W.
SDS3364433 WAgMINGTON, D.C. s0005 N01 905 3944433
,e-.4
......,_....=, _,
- - - +.
n,-..---,.n-~,...+.
~ e,,. n,,_, -<---
n
,m
-,--m,-~c,,
- - -, ~ -.. - - - - - - -.. ~ - - - ~ ~ - +
~
-r--
- ~ ~ ~ + -
~ ~ ~ ' ' ' ~ ~
}
1 perconal cxperienca with having_to uco o whcol wr0nch cn a u
2 gato volvo to provida icoletion in th3 pact.
That 3
experience also indicated to me that valves that had been 4
4 torque shut using a wheel wrench, could be opened.
I was s
also aware, and this factored into my consideration of 6
this when it was first discussed the afternoon of the 19th 7
and Mr. Grey discussed it, that I was aware that in the e
second half of 1996, we had actually, we had come to-the realisaylonsometimeearlierin'96,thatwehadnot 9
10 proceduralised language that was in the final safety.
11 analysis. report.
And that we did not have in place, a 12 procedure to actually cross connect the' component cooling 13 water systems.
.14 so I was aware that operations had, since it 15 was described as an abnormal condition that would be, or a 16 capability that would be used in an abnormal condition, 17 or, I also view that as a casualty response type function.
18 The organization created an abnormal operating procedure 19 for this crosh connect capability.
This was a change to-20 our procedure.
We did not have this procedaral-guidance 21 in place.
When we do that, we train our operating crews 22-en the procedure, and we then put the procedure in place.
23 so I was, part of the,.at least my thought proc'ess'for viewing this as a viable capability of the 24 25 station is that I was aware that in the not too distant NEAL R. GROSS coum nemmmt AND TRANSCNsERS
/
1883 MH00E SLAND AVE., N.W.
peg as44433 WAaHINGTON D.C. 3D005 3701 (B0@ 3544433
_ m.m a ae empe eee e
,moe e
.ew.,
,.-..---_-__-A------
j 1
prt, we had d;voloped o proc dural guidanco cnd train d j
2 cll cf th3 operating craw 3, cnd during that prococo, nono 3
of the operators, many of whom have been here for a long ll time, raised any issues or concerns with the viability of 4
5 the procedure that had just been put in phce.
6 So when I had the discussions on Wednesday 7
afternoon, I believe, I had no reason to believe that we s
did not have the capability to cross connect.
9 INVESTIGATOR DEVITTO:
Did you have any conversationsonthe21stwithsanybodyfromtheNRC 10 11 relative to this --
12 MR. CAYIA:
During the, I don't specifically 13 recollect whether or not, I'd had some discussions, I
(
14 typically have discussions during the daytime with Region 15 III personnel. '-
16 INVESTIGATOR DEVITTO:
What about Region III 17 Headquarters, did you have occasion to talk to anybody on 18 the telephone relative to this?
19 MR. CAYIA:
I don't remember right now, whethekornotIhaddiscussionsduringtheday.
its had, 20 21 basically we were, I was planning on, during the 1400 22 conference call, raising the issue and clarifying that we 23 had some, when the condition -report had surfaced in the 24 system, that we were taking some additional actions to 25 verify that the valves were still capable of being opened, HEAL R. GROSS couw m*omas ANowwsem0m:
13s3 MHoDE ISLAND AVE, N.W.
quig as+44as wAmmeGToN, D.c. 3DOOWO1 (304 3D44438
_U
.....r- - -
lI, 1
but tho initio1, even tho initici operchility os11 that
!I I
2 wao licted on thic conditicn rcport, indicated that, no 3
required by our process, that the valves were believed to 4
be operable by a currently licensed senior reactor 5
operator.
6 so the Antent on the afternoon of the, at the 7
1400 conference call, which was to be a status update.
8 INVESTIGATOR DEVITTO:
This was on the 21st?
9 MR. CAYIA:
On the 21st.
Was to make the 10 agency aware that we were taking additional actions to.
il verify that the valves were in fact capable of being 12 opened.. It had been called into question.
Some people 13 believed that the valves were capable of being opened.
In (i
~
14 fact, most people believed that the valves were still 15 capableofbein[ opened.'
16 I know that I believe that the valves were 17 capable of being opened.
But we were going through the-18 formal operability process and the plan was to discuss
~
19 that at the 1400 status update with the agency.
It was 20 viewed as a, in my mind, as a status update because it, 21 even if thesh valves were not even in the original design 22 of the plant, it would not have changed the original 23 safety basis for why we requested the notice of 24 enforcement discretion in the first place.
25 The, fundamental reason for requesting the NEALIt. Gross COURT MEPoRTERS AND TMANSCMitpl8 1883 MHODE ISLAND AVE, N.W.
SOE)leM418 1NASHINGTON, D.C. M3701 gos) 344433 w
e
1 cnforcencnt dicerction criginally, both vorb211y cnd 2
cubscqucntly in writing, w23 ttet it wao cofor to maintain C*'
3 reactical in system above 330 degreer Because by 4
maintaining it in that condition, we actually maintained 5
three different and redundant decaying removal mechanisms l
j.
6 to follow, which was in compliance with, I think it's 7
15-3-3-A of the toch specs, to cool down the plant and a
follow the other tech spec, would have taken us to a 9
single decaying removal mechanism and that was the i
l t
10 fundamental safety basis.
l 3
l 11 whether or not these cross connect valves were i
l 12 either in the original design basis in th's plant or not,
~
l 13 would not have changed, I do not believe, the basis by
)
7 14 which the enforcement discretion was requested.
g 15 INV2STIGATOR DEVITTO:
Let me ask you a 1
16 question about Mr. Eiller.
Is he a competent individual, 17 in your eyes?
(
18 MR. CAYIA:
Mr. 2111er is a competent l
19 individual.
He has been around for a long period of time, a
20-I don't know exactly how long.
I know that he, in former g.
21 years, was a shift supervisor at the station.
He has a
.I 22 lot of operating' experience.
He also has, his primary 1
{
23 role right mow is, he's in our production planning group.
24 He serves as a shift outage coordinator and he does'brief 25 us virtually every morning at our 6:45 meeting on the WEAL R. GROSS COURT REPORTERS AND1MANSCRSUt3
, 18B3 P6400E ISLAND AVE., N.W.
900) 3344433 6 L A. 3000 H m1 M 8844433
~
p.
. *, _ -* * * * ' ' ~
r
. +
r e
,p.,,y
-r, c.....y..,
m-w
---v
-c.,,,,,,r.,.,-,..y.,,-y,,,
,,--.,,--c
{
1 cefoty ctetus of tha plcnt in hio rolo co o chift outcg3 Ll 2
coordinator.
3 so he is one ef many people at the station i
4 that do a good job for us.
As far as, you know, 5
competent-that's a pretty subjective term, but in my 5
view, and if you were to look at his performance 7
appraisals, he performs a needed function for us and e
per*orms well.
There are sometimes when he may not live 9
up to all of our expectations, but then a lot of us are 10 like that, but it's, you know, it*'s something that, he is 11 one of the people that we rely on on a daily basis.
12 INVESTIGhTOR DEVITTO:
Would you consider him 13 to be an outspoken type individual?
14 MR. CAYIA:
1,et me just say this.
I've had a.
15 number of occasions when Mr. Eiller has given me what I 16 would call a lecture.
He has, there were some things that 17 happened here, and this is not unusual, I've had a number 18 of employees that have come to me in the three years that 19 I've been here, where things happened in the pasa or were to them'or by other people that they're noc happy with.
20 21 so there are times when Eric,.and I know he's 22 still not happy with the fact that he's not a shift 23 supervisor anymore.
I don't, that's something he's talked 24 to me on numerous occasions about.
So he, you know, Eric 25 will speak his mind.
He is hard working.
I see Eric as NEAL R. GROS 5 COURT REPORTERS AND TRANSCMSERS 1833 MH00E ELAND AVE., N.W.
- M B44433
-4WASHWsToN, D.C. aKc43701 M stedets
_ _ =
'1
_ _ _ _ = __
me w
d:dicated to thic fccility, h3'o be:n hara o 1cng time, 1
2 and ha han o let of perocn.il prid3.
And g:n0rolly, ho 10 f'h) 3 trying to do the right thing.
4 There are times where also the station is i
5 going through a significant culture change, and we at J'
6 times have culture clashes because there are some folks at the station that would like things to be the way they were 7
8 15 to 20 years ago.
But that's not atypical for what's 9
going on in society today, especially the 90's.
But Eric 10 can be outspoken, yes.
4 11 INVESTIGATOR DEVITTO:
I just have one last 12 question for you, Mr. Cayla, before 1 turn it over to Mr.
13 McMurtray if he has some follow up here.
(. )
14 Do you know what.the disposition of this 15 commission repo(t is currently, what is the condition of 16 those valves?
17 MR. CAYIA:
I can tell you, sure, I'll tell 18 you what we did.
We, after myself and engineering.and 19 operations became aware of this, we -- task engineering to 20 perform a formal operability assessment on these valves, 21 to ascertain the capability to cross connect the component 22 cooling water system.
23
-Me had radiographs that were conducted on 24 those valves.
That's probably the first thing that
)
happened, and Jeff Polacheck who is one of our site QA 25
-NEAL R. GROSS count REpomRS AND MN9CNSERS 1833 MH00E BLAND AVE., N.W.
M 3B4443 StASHWGTON, D.C. SDOOH701 '
(3012) 3344433 n -. -..,.
~~
~{
peoplo, cetually c me to me perccnolly citer h3'd cocn tha 1
2 rcdiogrcpho, cnd ha told me two thing 3.
Ha caid, firct off he said, I have to tell you, he says, I'm actually 3
quite pleased because he said these are some of the best 4
5 radiographs we've ever been able to shoot. Eometimes when 6
you shoot valves, sometimes you get a good shot, aometimes 1
7 the quality is not as good.
8 These particular valves, the quality of the 9
radiograph itself was quite good.
Jeff said to me, in 10 words that were essentially, and this is almost a quote, 11 he said, the valves look brand new.
I said, well, what 12 can you see and he said, I asked'him, is the stem 13
- strength, one of the potentia 1' failure mechanisms that I (1
thought was possible, was that the stem in being pushed 14 15 down, would be bent.
He said, no, the stem is perfectly 16 straight.
To me, that increased my belief that the valves 17 were operable and could be opened.
That was really 18 consistent with my experience with gate valves.
19 The other thing I asked him about 20 specifically, was the stem to valve disc interface, where 21 the stem attaches to the disc, the potential for that to 22 break.
He said, no, we can actually see that pretty 23 clearly and there's, he says, there's no evidence of I
24 cracking, which he thought they'd see.
He said, it looks 25 like the valves look brand new.
So to me, that increased NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE FSLAND AVE., N.W.
M 2344433 WASHINC' ton. D.c. 2t00H701 Gim) 2344433 W--
-
- N988 6
- +-M
~..
x j
1 the confid:nca immedictoly in my perconal cind cnd w:0 i
2 part of tho bacio for tha fernal operability determination 3
that-engineerir.g was working on.
1 4
And I had some discussions with the engineering staff as to what types of things were they 5
5 planning on pursuing to assess the condition of these 7
valves.
8 Those included removal of three studs from.
9 each valve body, one at a time and replacing them with the 10 new studs so that those studs could be mondestruct'ively 11 examined.
And that gets to one of the things these, in-this condition report, it says,nomething to the fact that, 12 where is that, body to bonnet bolts were stretched.
The 13 14 feedback that came back after those stude were I
~
15 nondestructively examined, was the studs looked brand new, that there was no evidence that they had been ever exposed 16 17 to any stress that would cause you to question that durability, so that was another thing.
it 19 We have, this is a ten inch gate valve.
There 20 are other ten inch gate valves in this system, some of which have motor operated valves. Je have as a result of 21 22 our Mot program, we have some pretty good data on those 23 valves and one of the things that was relayed to me
~ 24 personally and was also a factor in the operability 25 determination is that the reported data on those valves, WEAL R. GROSS cour eeomen AwotanuscReens
- 333 MH00E ISLAND AVE., N.W.
M sbHus 4AmsHINGTON, D.c. Es064701 pos) ash 433 T,_
1 on the motor operated v21v 0, 10 that wh:n tha motcr 2
torqu:3 thea chut into tha cost, it tekco cbout one half of the force to remove the valve from its seat, which says 3
4 that the valve is, it's easier to open it, there's less
(
6 5
force applied than is generally applied in the shut I
6 direction.
That was factored in.
i t
7 They also did a weak link analysis to see what l
would break, in the avant it was -- that was factored in 8
9 to the overall operability determination.
Jtngineering 10 concluded in a written operability determination, that based on all the non-intrusive activities that they were 11 12 able to. conduct, that the valves were operable.
That 13 formed the basis for us, we then felt a strong need to 14 demonstrate that we could cycle the valves opened, to 15 verify, that wasi the last thing that needed to happen to 16 verify and put this condition report to bed.
17 So a group of people worked and staff oubsequently approved the 5059,and PBTP which is our test 18
'~
19 procedure, to cycle those valves opened one at a time.
We 20 cycled the first valve opened yesterday morning.
The 21 valve was able to be opened and was able to be struck 22 shut.
We were unsuccessful in opening the second valve 23 yesterday afternoon.
We bad a staff meeting. late 24 yesterday afternoon to document that and to pureue the 25 next course of action.
HEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 rho 0E ISLAND AVE., N.W.
(202) 234 4433 WASHINGTON, D.c. IMX63701 (202) 234-4433
=... _ _. _.......
{
1 We cre, engin cring hac be:n rcqu00ted to 2
calicit cupport 3 rom tha valva vendar, in tha fcrm of 3
advice and a field service rep to, one assumption is that 1
4 others may have had trouble opening these types of valves 5
in the past, and that the sospany that made the valve, 6
designed the valve, could give us advice on how to open 4
7 the valve best.
i a
That's underway right now.
We are continuing
- \\
9 the pursuant of that.
Engineering is also, we did make a
., i 10 four hour report to the agency of this condition yesterday t
i 11 afternoon, and we're now doing some parallel paths, say i
i :'
12 okay, we don't have this featur,e as described in the final t
13 safety analysis report.
We're looking at the implications 14 of that following the report.
15 Two possible paths.
One, we could open the r
16 valve.
The component cooling water syrstem also has, there 17 is another part of the system where we could actually 18 cross connect component cooling water on the discharge
. r 19 side, related to the heat exchangers.
It's a little bit 20 more conplicated than the two velve situation that we 21 currently-have proceduralized.
But engineering is s
.22 assessing that capability, the fact that the suction crose
'1 connect valve can be opened, actually makes that other a
capability very viable and we're assessing that right now 25 to useertain whether or not the language in the FSAR is NEAL R. GROSS o00RTMEPORTWW AND TRANSCRSUIS
-188B RHODE BLAND AVE N.W.
90%3944433
-edASHINGToN, DA 300063701 4I05 ab4 4488
.......-. r - - --~ = --- --
=w,-.
we,..,v w-,-,-,.sw w--~~-,-vw
.--,w-v,,,=,
.y,,-ew-,v.
...<wvy
--,,.,w,rw-,-c.v,.
...,,...,,,-.--.,r-ii.,,-*e-*-r e y,r ww-v v -
,-w---
e
.i------w-,*-*~w-
v
~
i3 2
1 ctill in icet c:pablo cf being complicd with.
W3 haven't 2
rocch:d that conclucien et thic point in time, but t:o cro 3
assessing it.
j 4
apt we are continuing the pursuit of the 5
resolution of this valve, either to leave it in its 6
present condition, but the preference of engineering and 7
operations and myself, is to restore the valve to fully 8
operable status, which may include opening the valve.
But we stopped it last night because without additional advice 10 from the vendor, we did not, operations and angineering in i
11 accordance with the procedure that we designed and 12 approved, we could not violate the procedure so we stopped V
13 the effort, and to regroup.
so that's where we're at
()
14 today.
)
I 15 INVisTIGATOR DEVITTO:
Okay.
16 EXAMINATION 17 MR. MCMURTRAY:
A couple things.
First of 18 all, on these subsequent issues,-the discussion with Jeff i
19-Polacheck and -- do you remember, as far as with the 20 stude, do you remember when those took place?
21 MR. CAYIA:
The discussion with Jeff 22 Polacheck, I think it took us, I'd asked that the valves 23 be radiographed as soon as possible.
That either 24 happened, it was no early than 1cte Friday, but it may 25 have been on saturday.
NEAL R. GROSS COURT REPORTWW AND TIENSCfUSOW 1833 RHODE ISLAND AVE., N.W.
m anweaa twAaHWNRON, D.C. sD0DE 8701 90g)3&H438
~~'
,-. ~..,.-......,..
1 MR. MCMURTRAY:
Aro you tolking about acct,
}
2 juct acct tve h -~
3 MR. CAYIA:
Yeah, it would have been the 21st 4
or the 23nd, I believe, when we actually got, we'd have to 5
go back, we could figure out exactly when the radiographs 6
were shot, but it --
7 MR. MCMURTRAY:
Okay, but it was after the 5
21st of when you had the discussion with the agency over 9
the --
10 MR. CAYIA:
That's correct.
11 MR. MCMURTRAY:
Okay.
Do you know who was 12 present from engineering on the initial MSS meeting prior 13 to the initial NOED call on the 19th?
14 MR. CAYIA:
Well, the commission meeting was, justtoclarifyhwasnotaformalMSSmeeting.
15 16 MR. MCMURTRAY:
Okay.
4 17 MR. CAYIA:
It was, the formal MSS meeting 18 actually took place after the initial dialogue with the 19 agency.
20 MR. MOIURTRAY:
Okay.
21 MR. CAYIA: -And we realized that we weren't 22 reallp, we didn't start looking at the agency's procedure i
23 until we got into the conference call, and if lr looked at 24 it before, I would have had a formal staff meeting, but we (T
25 realized that, in fact, at the end of that conference NEAL R. GRO55 COURT REPoMTERS AND TMANSCRIBERS 1823 RHoDE ISLAND AVE, N.W.
4300) 334 4433 WASHINGTON, D.C. MIDOH701 (302) 3344433
=
--r-----
I call, we could not fermally rcquoct tho NotD.
Th:t'o^why 2
I h:d to ferm311y rcqu3st it from Ocek Gr:be in o privcto 3
dialogue later, because Mss had not fully supported it.
4 so that's, I'd have to go back and look Tony.
Etngineering i
5 had been involved during the day, but I don't know who 6
exactly was present.
I just don't know.
,7 MR. MC3fURTRAY:
Was there any engineering a
representation do you remember, on the initial NoED call 9
to the region?
10 MR. CAYIA:
I don't remember specifically, but 11 I believe Brad Fromm was there and even though he's in 12 maintenance, he also conserved the engiheering function
- 13 because he was until very recently, was a site engineering 14 manager.
But as far as who was involved on that call, I'd 15 have to go back'and look.
16 MR. NCMURTRAY:
Okay.
Do you remember at all, 17 who might have been in the subsequent MSS meeting Is representing engineering?
~
j 19 MR. CAYIA:
I know Fromm was definitely there.
20 I'd have to go look and see who was there.
I don't 21 remember all the people that were on the phone call from 22 Milwaukee.
I'd have to go back and look at the attendees, 23 Tony.
I just don't rememu r right now.
24 MR. MCMURTRAY:
That's fine.
Was Carl Gray 25 the ops representative in that formal mms menting --
NEAL R. GROSS count atromns AND TRMSCNSEnt saas rho 0E BLAND AVE., N.W.
(IDE) 3944433 9mbHE'. TON D.C. 30000 37C1 (30s) 394 4433
- i*!
-e -
e<m g.,,,,,_.4_
ll 1
MR. CAYIA:
I belicvo h3 COO.
l j 2
MR.-MCMURTRAY:
Okcy.
All right.
Do you know 3
if, now on the, now we're going to the 20th, Thursday the 4
20th, you did a review on this. _Are you aware of any of 5
your staff members or anyone who reviewed the NORD, the 6
written NOED, prior to it being, to it going to the 7
agency?
8 MR. CAYIA:
I know that I was asked to review 9
it by Doug.
I do not know who else Doug asked to have the 10 letter reviewed.
I asked one additional person to review 11 the letter, and that was Terry sullivan, because Terry 12 sullivan had participated both in the, he was there and 13 listened to the dialogue, both during the initial 14 conference call and during the formal MSS meeting, and 15 also since he wis not directly involved in the conference 16 call, he to me, was a very, and he's an experienced 17 industry official, he was a very good person for me to 18 have review the letter because I felt he could be very 19 objective.
20 And so I don't Ismember exactly which draft.
21 It. mas not an early draf t,.it was probably a near final 22 draft and in fact, Terry did have some comments that were 23 provided to Doug,-as we formalized and finalized the 24 letter.
25 MR. MCMURTRAY:
Okay.
44EAL R. GROSS CoVRT REPoFTTERS AND TRANSCRIBERS taas RHoDE ISLAND AVE., N.W.
90E) 334 4433 WASHMGTbN, D.C. 300064701 (302) 234 4433
~
+
.lI' 1
HR. CAYIA:
So I don't know, Doug'htd C:k d me 1
l 2
to ravicw thJ 10ttcr cnd'I did.
I d:n't know if, I hava l
3 no knowledge as to if he had asked anyone else to review t
4 the letter.
I just don't know.
I 5
MR. MCMURTRAY:
Okay.
When you asked Eric 6
Ziller to write the condition report from the 6:45 meeting 7
on the 20th, can you go through a little bit of what your 8
thought process was wh'en you asked him to write that CR 9
for whatever he described that morning?
10 MR. CAYIA:
Oh,,sure.
He raised the issue and 11 what went through my thought process is that, okay, this 12 is a condition where we had cross leakage and I knew this 13 was a gate valve, and what went through my head as I said 14 okay, this isn't that unusual, I ha"e done this before.
I 15 know that we use wheel wrenches here.
Sometimes people 16 call them persuaders, some people have less glamorous 17 names for them.
18 But they're an assist device, especially for a 19 larger gate valve, it helps ensure that the seating 20 surfaces are good, to make sure, because sometimes they're 21 used for when we isolate for danger tag purposes,1so that 22 when you're going to open a system up, you want good 23 isoint3 n.
.In this case, it was for cross leakage.
It's
,24 bar cally the same issue, going from one part of the 25 system to another.
9 NEAL R. GROSS COURT REPORTERS ANDTRANSCRibERS 3323 RHoDE SLAND AVE., N.W.
(202) 2344433 WASHINGTON, D.C, 200053701 9 02) 2344433
- ~~
1
-what. went-thrcugh my he:d 10, using-o whool 2
wrcach er o percund r to provida Cood isolotien 10 n t en 3
unusual situation with a large power plant valve, 4
particularly a gate valve.
And so, but, one of the things l'
5 that I've, and I think you've seen, I've also been trying 6
to, we've gone through a very interesting process since 7
about August of '96, where before August, we didn't write e
a lot of condition reports.
One of the behaviors I've s
worked hard to model, especially,in our 5:45 meeting, is
.10 to always encourage the writing of condition reports.
In
_.. 4 o
11 some cases, when someone will, and I think you've seen me 12 do this, in some cases when someone will.. raise an issue, I 13 will ank, have we written a condition report.
'(.y 14 And it's kind of a way to encourage and give 15 people permission.
I've had to do that a lot less in the 16 last few months and instead of asking if, because I O 17 this na being a little bit more positive, instead of 18 asking has one been written, I'll ask, would you write 19 one.
That's kind of whw I did with Eric, some cases 20 when I do that at the meetings, the answer is, it's 21 already written, which,that's real positive.
In this 22 case, when Eric raised it I guess I kind of folt that it 23 probably hadn't been written yet, and I wanted it 24 documented so I asked if he'd write it. 'And I think,
-)
25 because I know Chuck was there, it was --MR. O'NEILL:
You MEALL GROSS count Moronnms ANDTMSCMSERS
/
'uss RM MLAND AVE., N.W.
gotasseass WASHINGTON, D.C. 3000H701 M 3844433
~ ~"
____m__.__
i 1
ccid Chuck.
Who do you me:n?
2 MR. CAYIA:
Chuck X211cr.
I*didn't CCy it in 3
a way such that, you know, I was being critical of Eric.
4 4
I said it in a way that was very positive and supportive 5
of Eric because I really wanted the condition report 6
documented, so that we could put it into the system and 7
assess it, -just like we're trying to assen.s a number of 8
things.
9 I'll also tell you that I did take some 10 subsequent action because I got wind from the rumor mill 11 in the organization, that there were some people that 12 weren't happy that Eric raised that issue.
It's just the 13 old culture new culture stuff.
I personally was pretty
(*)
14 happy that he Qaised it, and in fact, if you look at the 15 weekend night orders, one of the things we wrote in there 16 wao that, bact':.se I figured some of it might be coming 17 from operations, we put a specific thing in the weekend 18 night orders for the, it would have been, those were 19 written the evening of the 21st, or I think they were the 20 evening' of the 21st, what we wanted -- for the weekend.
21 We discussed the CC% cross connect in there, and we 22 actually put in there that we were thrilled that the issue 23 had been raised, because that's the behavior we want te 24 model.
)
25 So you know, I asked Eric to write it, to NEAL R. GROSS coVRT REPORTERS AND1RANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 2344433 4ASHINGToN. D.C. 30005 3701 (202) 2344433
y 1
document it.
I remember ccking, does cnybody olco know l
2 cnything about thic, beesuso thic w:0 liko, thio 10 a 3
little bit different.
Rob was standing at the door and he i
4 4
said, yeah, I know something about this, and I remember 5
something.
And what my thought process was, is that okay, 6
they've been torqued shut using a wheel wrench, that's not 7
necessarily unusual.
8 My past experience says, okay, the valves can 9
be opened, the cross connect capability is not threatened, 10 there's an issue that needs to be resolved, and 2 also, as 11 I was sitting there thinking about it, I said ah, okay, 2 12 was consciously aware, and in fact I revisited this 13 several times during the day in my own head, that we had, 14 I had the assistant ops manager involved in this the day is before.
I was dware that in the last half of '96, we had is developed the procedural guidance, we had trained all the 17 operators and put the procedural steps to open these is valves in the procedure, none of the operators.
That 19 issue was never raised.
20 To me, as part of my thought process, that 21 provided additional assurance and supported' my personal 22 experience that those valves, there was Jao dovbt in my 23 mind that we could open those valves, and that the cross 24-connect capability was a viable and normal / casualty 25 response function,
- NEAL R. GROSS couw neromans Awonwecmeens last nMoDE 18LANo AVE., N.W.
+
pogabe.4438 N. D.C. 310064m1 904 3344438 t
-~
w
_
~ ~... ~
....--no - -
1 MR. MCMURTRAY:
Th3 iCCu] that you C;w hOro j
2 though, wa3 that Eric had ctctcd that th;y wero terqutd 3
hard, is that --
8 4
MR. CAYIA:
Yes.
But even that, for a power 5
plant gm.te valve, especially large gate valves, torquing 6
them hard with a wheel wrench, even at that point in time, 7
that didn't strike me as being that unusual.
In fact, did 8
not cause me to have a concern.
9 MR. MOtURTRAY:
Okay.
10 MR. CAYIA: -Now the thing that, this is 11 different.
12 MR. O'NEILL:
And when you hay this, you': e 13 referring to --
14 MR. CAYIA:
The condition report, Exhibit B, 15 is different.
16 MR. MCMURTRAY:
Okay.
And the last thing I 17 have is, on the morning of the 21st, Friday morning, were 18 you present do you know,.at the 6:45 meeting?
19 MR. CAYIA:
I would have to say I believe I 20 probably was.
21 MR. MCMURTRAY: Okay.
You don't remember 22 though if this condition report at all w s discussed at 23 that uneeting?
24 MR. CAYIA:
I don't remember if it was 25 specifically discussed.
I'm sure, I dun't believe it was, i
- NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1823 MHoDC ISLAND AVE., N.W.
$102) 3344433 WASHINGTON, D.C. s00064701 M 3D+4433
1 MR. MCMURTRAY:
Okcy.
g 1
i 2
MR. CAYIA:
I d3 beliCv3 that I prob bly 3
walked out of the meeting with the package that contained 4
that condition report.
5 MR. MCMURTRAY:
The only reason I ask that --
6 MR. CAYIA:
Because I typically do.
7 MR. MCMURTRAY:
.In the past, significant 8
condition reports have been discussed at the morning l
9 meeting by -- services and I was wondering if this one --
10 MR..EAYIA:
Ycah, sometimes they have been.
11 One of the things that, we kind of shifted.
We went 12 through, we realized back maybe two months ago, that one 13 of our problems, we didn't have enough line ownership with 14 our condition reporting process.
If you remember, the 15 first thing we did is right after the morning meeting, wo 16 deliberately retrained all of our line managers.
We 17 basically forced the line to review the condition reports, 18 primarily so that we knew what was going on, but also to 19 get ownership.
20' We then shifted over to a more appropriate 21 group, and that's : sow our 10:00 meeting, where both --
22 services personnel and the line, representatives of the 23 line and this engineering functions, review the package, 24 the entire package together.
And we have shifted to s
{'
25 relying on that meeting as the form at which those
- NEAL R. GROS 5 COURT REPORTERS AND TRANSCRSERS last RHoDE ISLAND AVE., N.W.
gas)as444aa WAeHMGToN, D.C. 3D0063701 ts0R) st44433
._.~.
1 diccu Oion3 tCko plcca.
1'-
2 MR. MCMURTRAY:
Cara you prCocnt Ct that 10:00 l
3 a.m. meeting?
l 4
MR. CAYIA:
No, I was not.
5 MR. MCNURTRAY:
Okay.
That's all I've got.
6 MR. O'NEIE:
I do have a couple, just things 7
that I think might complete the record, if you don't mind.
8 INVESTIG) TOR DEVITTO:
No, go ahead.
9 XXAMINATION 10 MR. O'NEIE:
Just to give a feel, Mr. Cayla, 11' of how many condition reports monthly does Point Beach 12 generate?
13 MR. CAYIA:
Well, monthly, it's, I don't know
(\\
14 the exact number, but I know we're running at a rate in 15 excess of 3,500 a year, roughly.
And a typical day 16 is anywhere from ten to 30 to 40 condition reports a 17 day.
18 MR. O'NEI E:
Mr. Cayla, can you generate 19 power at hot standby or at 380 degrees?
20 MR. CAYIAi 'I do not generate any power here.
21,In fact, I use more power.
22 MR. O'NEIE:
Is there any economic motive for 23 remainino at hot standby rather than going to cold 24 shutdown?
25 MR. CAYIA:
I don't believe there is.
In NEAL R. GROS $
COURT REPoMTERS AND TI%NSCRIBERS 13p RHODE ISLAND A\\T N.W.
(304) 3344433 WASHINGTON, D.C. 30006 3701 (302) 3344433
+
j 2
fcet, ctcying in the conditicn we havo be:n, which we'ro 2
curr:ntly in, we uno moro, tha -- cooling pumps cro 3
running, and we une a lot more electricity than if we were 4
in cold shutdown.
And if you look at it from up here, it 1
5 ecanomic sense, we would, it costs um more money to stay 6
in this condition than if tre were to take the plant to a
}
7 cold shutdown condition.
It's more expensive.
7 8
MR. O'NEILL:
Turning to Friday the 21st, i
9 prior to your 1400 telephone call with Regicn III, did you 10 have any meetings at which the condition of the CCW cross 4
11 connect valves were discussed at which an NRC resident was 12 present?
13 MR CAYIA:
I do not know.
I don't remember 14 if, you know, there were, as the organization became 15 aware, there were different discussions with different 16 individuals within engineering.
I don't know if, I don't 17 believe I was in a meeting where this was discussed, our is plan all along had been to have the 2:00 meeting to 19 discuss it.
20 I believ<t there were xesidents thet were 21 planning on being and %sre at the 2:00 meeting because we i
22 had agreed when we had on Wednesday, 'we had agreed that we
~
23 would just review the stintus at the 2:00 meeting.
The 24 NOED didn't expire until midnight, but if there were
)
25 discussions, there may have been discussions, but I'm not HEAL R. GROSS COURT REPNtfDIS AND TRANSCNSERS
/
Smits PH00E ISLAND AVE.. N W.
M as44433
-4 WASHINGTON D.C. 30006 4701 Stor,234443S 4 *+ - g 94<m.4m
-e. % w -
_p w ee www e
+me em
++w
.a
1 perconally tw ro Cf any.
j 2
INVESTIGATOR DEVITTO:
20 that Cll?
3 MR. O'NEILL:
Yes.
4
. INVESTIGATOR DEVITIO:
Okay.
Mr. Cayia, have 5
I or any other NRC representative here threatened you in 6
any manner or offered you any rewards for this statement?
7 MR. CAYIA:
Absolute 3 not.
8 INVESTIGATOR DEVI""ro Have you given this 9
statement freely and voluritarily?
10 MR. CAYIA:
Yes, I have.
11 INVESTIGATOR DEVITTO:
Okay.
Thank you.
12 (Whereupon, the interview 13 concluded at 11:17 a.m.)
..}
14 5
15 16 17 18 19 20 21 22 23 24 25
.1C NEAL R. GROSS COURT HEPORTERS AND TMNSrJUBERS 1323 RHODE ISLAND AVE., N.W.
. (202) D44433 WASHINGTON. D.C. 200064701 (202) D4 4433
~~~
5 i
CERTIFICATE l
This is to certify that the attached proceedings before tha United states-Nuclear Regulatory Commission in the matter of Name of Proceeding: INTERVIEW OF ALFRED J. CAYIA Docket Number MARCH 5, 1997 Place of Proceeding: TWO RIVERS, WISCON3IN
-o i
l were held as herein appears, and that;this is the original transcript thereof for the file of the United states Nuclear Regulatory Ctraaission taken by me and, thereafter reduced to
(.)
typewriting by me or under the direction of the court
~
reporting compan'y, and that the transcript is a true and accurate record of the foregoing proceedings.
/RON 14 GRAND Official Reporter
_1 Neal R. Gross and Co., Inc.
E
'i NG NEAL R. GROSS
-countknokrus ANDTRANSCRIBMS ARD RHODEISIAND AVDfUE,NW
-(202)234 4433
- WASHINOTUN,D.C. 20005 1
002)2M403 l
1n l
STATEMENT OF 2 Yf A CIVEN ON. MAFdCdM
/YYf v
i TO NRC CPEC%L AGENT RICHARD L. DEVRTO, AT1NE MA a a Y b Ab a s e P4.,.t r.
1 PAoE LsNE RECOMMENDED Ho.
No..ConnEcnon W
'S on *Tle "
sts$4
" e s*1' "
n.
"ma m w "
saia u m.:,~ r a "
[
_ int A-A we aaa*
a n's a
" Z > Ta "
'TJ
- t 6 m.n a >>e*.e~"
onho f a A n.a a e e r **
3d
, _s-
- s u wrJY a -oIs..et*" asea
- T n a h> a l ~ n im.at "
ir?
's a
" kW i wo **
,, s as
" u ns' s 11 na * *
~6
'1 'n 1
nra i sto t "
si ne's
" tlnlde "
"e V 16
- soG as,rn An a A s 14ss.u nssu
~
4
\\1 ni'e.
H wnMn sm a Nio nan **
- 1. L
- 1. s
" _ tr">..*f"L'Ye "
rMe:o e s',:,% J "
k 31 1 a,
+
C rs.C*
Jnia es & uv"
- 1,.'i LY l O 81 a'et >* Q Q n $Ob d t$0.4 I
Yh$e
- Y b be41 *= * - M O*sll [4 $ "
1%
T
% > m.y 4, V
,u k g
" G ggy e s "
()
1 S, 1$. s */
h*t A ft'en nn n la.n'f' s u s TI hr B'T A
~n) n 5 &
~
^
- F#d aN d A /
~
is 2/
'8 4Fav" ~
1Elmd % STkmM 2M3 FM ##
onu
- ar4 v "
2.#'
//
Si Acah.ne.*i i ## dtie " Of. d# "
Lb 1 *4 4
~
gg et gf j e* g a
- g gy 4
[
'A, '">
-JL i
" A. w m v "
(/12 e
' d et V "
"A P 15"
~
nM a.I mA A F
- 4
s/ t 24 6Vaet a tt a ( deP'n *#
M 9h
- o ba.V T) d 14
"(Ab4V" V
2Cl 1o.
M 57..M "
J.it '
- 526 3 1 V **
nn ei s <l 1,/ w L. "
o ic e
~n j/,,,~, ;a,,_,, n A'
- 'NA la% d 3 N " O Lt 9
' be A nYa b n,e **
'3 4
- 1 4 h k,11 so
- une't. " 'n.s o a A d "
't 4 isisA
- Tunnenerse" a l.a. n u.a.
u #+ **
- A[ Ol /M AM A,et dDJ 'd
d id #
II AM And O d.> "
'K o
- n n a.kr. W M "
aas n nu JdikeA "
dTes 4
42sme" T d a c'#'
" SeJ "
~
isi L
u Lea. l
ts ic t n udbsi" AJT hl.
""T' b P A ni aL N d LE.P_.
A
- O 67 8
- 4) (
6
" /. einly **
- o tie
" Mdv a
N( dn A*N bl9]nN4" tI nt'd U fn POCRA.D t
- 4/ rt./z.
LA /stran, dits a
h /, p /r "
At t o
-5 A.o rea.1% n an/, A~ =n,v4%iiru " a sie o' two trTin /
n A 4t14$ ou **
I 4t
<TQ A 9 b h 4 6,o a st~ "
0nio ilo si 14'W ~ && na L J Li.e " G"3eI " ~Aes svshe "
l 0
t%
%"'~
nG s A L
- J s i.e
" 21 s k "
IO ID fd f TA 4* M M ilsiL
- &M f==== Ta5 $ M. "
lONATU n
a ut t IdW I(
3
(\\
s,
~
W e
- me=e w'-
w=$ *@@
e MM m
O a 4 69 W"-
,ee w ee. e m e e gum a ow=*
5