ML20199C966

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Transcript of 951129 Interview of G Halnon in Crystal River, Florida Re OI Rept 2-94-036.Pp 1-134.W/Certificate of Svc. Title Page Encl.Birth Date & Social Security Number Deleted
ML20199C966
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 11/29/1995
From:
NRC OFFICE OF INVESTIGATIONS (OI)
To:
Shared Package
ML20199C716 List:
References
FOIA-97-313 2-94-036, 2-94-36, NUDOCS 9711200212
Download: ML20199C966 (136)


Text

. . . _. - - . - - - -.

Sffici.01 Transcript of Prococdings  ;

NUCLEA.R REGULATORY COMMISSION

Title:

In the matter of Interview of -

Gregory Halnon Docket Number: 2-94-036 ,

f Location: Crystal River, Florida Date: November 29,1995 k

Work Order No.: NRC-429 Pages 1-134 Y

NE\L R. GROSS AND CO.,1 'C.

Court Reporters ar.1 Traascribers

,9 _03 1323 i(hode Island Avenue, N.M. EXHIBIT N -

Washington, D.C. 20005 / OF (36 PAGE(S)

PAGE -

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p LleM97-313 PDR ,( q yo f

1 UNITED STATES OF AMERICA

t.  ;

2' NUCLEAR REGULATORY, COMMISSION i 3' +++++

4 OFFICE OF INVESTIGATIONS i

5 INTERVIEW '..'.-

6 --------- ,------------------------x i i

7 IN THE MATTER OF: i 8 INTERVIEW OF  : Docket No.

  • i 9 GREGORY HALNON  : 2-94 J6 t

, 10  :

11 ----------------------------------x 12 Wednesday, November 29, 1995 13 14 Crystal River Plant  ;

15 Administration Building .

r 16 15760 W. Power Line Street 17 Crystal River, Florida .

18 19 The above-entitled interview was conducted at 20 21 10:38 a.m.

BEFORE:

23 JAMES D,.DOCKERY_ ~ Senior Investigator .

24 ,

JIM VORSE" Senior Investigator 25 CURT RAPP Reactor Engineer f g Wpsaldus h&uthi^1 g/NW,W '

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2 1 APPEARANCES:  !

t 2 On Behalf of the Nuclear Regulatory Commission I 3- JAMES DOCKERY, Senior Investigator -

4 Region II= NRC Office of Investigations S 401 Marietta Street [

t 6 Atlanta, Georgia 30323 l 7 JAMES VORSE, Senior Investigator [

8 Region II NRC Office of Investigations t 9 401 Marietta Street 10 Atlanta, Georgia 30323 i 11 CURT RAPP, Reactor Engineer 12 Region II NRC

]

13 401 Marietta Street 14 Atlanta, Georgia 30323

! 15 16 On Behalf of the Interviewee, Gregory Italnon 17 MORRIS " SANDY" WEINBERG, JR., ESQUIRE 18 Corporate Counsel - Florida Power Corporation 19 101 East Kennedy Boulevard, Suite 3140 I 20 Tampa, Florida 33602 21 DANIEL STENGER,- ESQUIRE 22 Corporate Counsel --Florida Power Corporation ,

23 1400 L Street, .N.W. [

24 Washington,- D.C.__20005-3502  ;

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3 1 P-R-0-C-E-E-D-I-N-G-S 2 MR. DOCKERY: For the record, today's date is 3 November 29th, 1995. The time is approximately 10:38 a.m.

4 My name is James D. Dockery. I'm a Senior 5 Investigator with the NRC Office of Investigations.

6 During this proceeding, which will be recorded 7 for transcription, the NRC Office of Investigat.ons will 8 conduct an interview of Mr. Greg Halnon. This interview 9 pertains to OI Investigation Number 2-94-036. The 10 location of the interview is the Administrative Building 11 at the Crystal River Nuclear Plant.

12 There are others in attendance during this 13 interview. And I will ask them to identify themselves and 0

14 their affiliation, starting with Mr. Rapp.

15 MR. RAPP: My name is Curt Rapp, R-A-P-P. I am 16 a reactor inspector with Region II, NRC, in Atlar.ta, 17 Georgia, 18 MR. VORSE: My name is Jim Vorse. I'm a Senior 19 Investigator with the NRC'a Office of Investigations, 20 Region II, Atlanta, Georgia.

21 MR. STENGER: Dan Stenger, attorney with Winston 22 and Strawn in Washington, D.C.

23 MR. WEINBERG: And Sandy Weinberg with Zuckerman 24 Spaeder in Tampa. And for the record, both Mr. Stenger 25 and I represent the company.

4 1 MR. DOCKERY: Mr. Halnon, would you raise your 2 right hand, please.

3 THE WITNESS: (Complies.)

4 Whereupon, 5 GREGORY HOWARD HALNON, 6 having first been duly sworn by the Investigator, was 7 examined and testified as follows:

~

8 MR. DOCKERY: Thcnk you.

9 DIRECT EXAMINATION 10 MR. DOCKERY: Would you please state your full 11 name.

12 THE WITNESS: It's Gregory Howard Halnon, H-A-L-13 N-0-N.

14 MR. DOCKERY: And would you state your date of 15 birth and Social Security number.

16 THE WITNESS: Date of birth is 17 Social Security number is

~

18 MR. DOCKERY: Mr. Halnon, before we went on the 19 record here Mr. Vorse and I identified ourselves to you as 20 investigators with the NRC Office of Investigation. Is 21 that correct?

22 THE WITNESS: That's correct.

23 MR. DOCKERY: And also, I gave you a copy of the 24 verbiage contained in Title 18, Section 1001, of the 25 United States Code with pertains to statements made durin;1

i

?

5 ,

1 this proceeding and the necessity that they be made 2 truthf911y.-  !

l 3 THE WITNESS: I understand that. j 4 MR. DOCKERY: You understand that?'

-5 THE' WITNESS: Yes, I do.

6 MR. DOCKERt Okay. Would you please provide us 7 - with what your position is and a little bit of your 8 . background educationally and experience-wise, please. -

9. THE WITNESS: My-position right now is the 10 manager of nuclear plant operations. My background is I 11 have a Bachelor of Science in Engineering from the 12 University of Central Florida. Graduated i '/ C/

13 The same year I was employed by Florida Power as 14 an engineer. I worked in fossil engineering for about 15 nine months -- or eight -- well, actui Jy, six months.

16 And moved into nuclear engineering.

- 17 Moved up-here on-site as a plant engineer in 18 1983. Was a plant engineer through 1985-1986 time frame, ,

sn Y And

19. at which time I went into an fT9TA- training program.

20 was an STA for a few years.

21 After several years as being an STA I went into 22 the SRO program, Attained my SRO in 1989. Worked 23 approximately 13 months-as an assistant shift supervisor, 24 -

After:that, I inoved - to the Operations 25- administrativa staff for about six months. And in the r

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-6 i 1 early '90's-I took over the plant engineering group as the 2 manager of System Engineering. I was there for 3 approximately two and a half, three years, at which time I 4 went back to get my SRO the second time and was asked to 5 take over the. Operations Department-December of 1993. And 6 I've been in that-capacity since December of 1993.

7 MR. DOCXERY: As I'm sure you're aware,.the time 8 period that we're interested in is the late '93 '94 time 9 period during which time if I understand you were in-the

10. same-position continuously.

11 THE-WITNESS: I was -- I took over plant 12 oper. 'lons in 1993, December 20th, about that time frame.

13 The six to seven, eight mcnths before -- prior to that I Q

14 was in SRO training. So I was in the training department.

15. I was pretty much out of circulation still studying for my 16 SRO.

17 MR. DOCKERY: Okay. As you're also aware, what 18 we're concerned with are certain incidents related to what 19 we refer to as Curve 8 and makeup tank evolutions.

20 THE WITNESS: Uh-huh.

21 MR. DOCKERY: Can you.go back'in time and tell 22- us when you first became aware that Curve B was . causing-23 some sort of consternation.or was a problem for certain 24 people within Operations?

25 THE WITNESS: I found out fairly quickly after I f

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1 took the job. It was probably early in 1994 that -- l 2 probably in the January time frame that I understood there 3 were some issues with the curve and the way it responded. l 4 MR. DOCKERY: Do you recall who brought it to  ;

l 5 your-attention and how? }

6 THE WITNESS: I don't recall who brought it to my 7 attention. I know that I had assigned at the time a peer 8 evaluator,.which was a sort of an administrative assistant  !

9 -to myself, to look into it. It was not a burning issue at 10 the time. And there was meetings going on between 11 Operations and Engineering and he was' involved with that. j 12 He was ensuring Operations' interests were maintained at 13 these meetings. Any specifics I really don't recall.  :

0 14 MR. DOCKERY: Who was the individual that you 15 assigned to that?

16 THE WITNESS: It was Ernie Gallion, who was our i

17 peer evaluator at the time. It was just prior to the 18 outage, so we-were all gearing up for the refueling outage

19. that we were having early in that year.

20 MR WEINBERG: You need to speak up just a i 21 little bit.- Okay?

22 THE WITNESS: Okay, t

23 MR. DOCKERY: --We can go off the record.

24 (Whereupon, a brief recess was taken, after which 25 the following proceedings were hadi).

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1 HR. DOCKERY: - Okay. We just rearranged some i

2 microphones to get a better pick-up here. j 3 And I need to remind you, Mr. Halnon, that you i 4 continue to be under oath. [

5 THE WITNESS: I understand. t 6 MR. WEINBERG . Buc what he had just said was 7 that he htd idenLified Ernie Gallion. I guess it's like ,

8 G-A-L-L-I-0-N, or something'like that. f 9 THE WITNESS: G-A-L-L-I-0-N. Correct.  !

10 MR. WEINBERG: As the peer evaluator -- -!

11 THE WITNESS: Right.

t 12 MR. WEINBERG: -- that he assigned to look into 13 this issue, t

-Q 14 THE WITNESS: He was working many administrative

- 15 projects. This was just one of the many that he was doing 16 to -- you know, to_ ensure that Operations was involved in 17 it. He wasn't a formal contact, if that's-what you're ,

18 questioning. f 19 MR. DOCKERY: What was the concern on the part ,

20 of the operators with relation to Curve 8, 21 THE WITNESS - The big _ concern was-the need to 22 keep high hydrogen concentration in the RCS. In order to 23 -do that with the. design-that we had we had to maintain a 24 .high pressure-of hydrogen in_the makeup tank, which put us 25 close- to the - curve and alarm set -point .

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9 1 The operators were not comfortable operating that 2 close to an alarm set point.

3 MR. DOCKERY: Do you know -- How did this 4 problem come to light? In other words, was there some t

5 test run?

6 THE WITNESS: There was the SP-630 run during the 7 outage. That was just a continuation of the concern. The 8 operators plotted the data during that time -- during that 9 surveillance procedure and --

10 MR. WEINBERG: Dut that was a little later.

11 THE WITNESS: That was several months later after 12 this. And there was a concern before that whether it was 13 a specific -- you know, the curve was not conservative. I 14 don't recall. I don't remember that.

15 MR. DOCKERY: Had the hydrogen pressure -- Had 16 something changed in that figure? Was there -- Had it 17 been altered or revised?

18 THE WITNESS: Well, the need to keep higher cc's 19 per kg hydrogen in the RCS necessitated that, a higher 20 hydrogen pressure.

21 MR. DOCKERY: What pressure was that, do you 22 recall?

23 THE WITNESS: I don't recall. It's a variable 24 pressure curve. It depends where the level is.

25 MR. DOCKERY: Was there a target pressure?

10 1 THE WITNESS: Not at that time, I don't believe.

2 MR. DOCKERY: Did there come to be a target 3 pressure?

4 THE WITNESS: There came -- We communicated to S the shift supervisor, and then it was indicated on the 6 shift supervisor turnover sheet later in the year. It 7 evolved from keeping it to a certain pressure. I think it 8 was around 18 or 19 pounds. It was calculated by 9 Chemistry as being what we needed to maintain it as high 10 as possible. And that was, I believe, the guidance given 11 to them later in the year. And now we're talking into the 12 June-July time frame.

13 MR. DOCKERY: Was there a figure recommended or 14 even mandated by management of what hydrogen pressure 15 should be maintained?

16 THE WITNESS: I don't recall any figure, per se.

17 I recall that we were targeting cc's per kg hydrogen, not 18 so much pressure in the makeup tank. And we were --

19 MR. DOCKERY: I may misstate some of the 20 technical things because I --

21 THE WITNESS: Well, Curt can keep us honest here.

22 Are you following what I'm saying as far as -- Our target 23 was the cc's per kg, not so much hydrogen concentration.

24 Because there's another variable. And that's hydrogen 25 purity. If the hydrogen purity is low, then the pressure L

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11 1 -- you're going to have a real high pressure and it [;

2 wouldn't make a big difference. So there would be a  ;

r 3 purity issue there, too. A high purity, you wouldn't have 4 to keep such a high concentration.  ;

. . 1 5 MR. WEINEERG: Well, what he was asking you, I .

G think, what he thought-he was asking you before, was there  !

7 a target cc per kg for hydrogen.

8 THE WITNESS: We were trying to keep it above-25 4 9 cc's per kg. ,

10 MR. WEINBERG: All right.

11 MR. DOCKERY: Thanks. That was my question.

12 THE WITNESS: Okay.

13 MR. RAPP How did this 25 kg's per cc (sic)  !

14 value come about?  :

15 THE WITNESS: cc's per kg? Yeah.

16 MR. RAPP Okay. i l

17 THE WITNESS: Yeah. That came out of the new -- 7 18 I think it's -- And I'm not real versed on the chemistry 19 aspect side of this. But it was -- I believe it's out of 20 the new EPRI water guideline, chemistry guidelines for .

21- reactor -- nuclear reactor PWR's.

22 And I think in the past we were operating off the l

23 .old B&W chemistry guidelines which'was 15 cc's.per kg.  ;

4 24 And we didn't have any problem maintaining that at lower <i 25 pressures. ,

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12 f 1 When the new chemistry guidelines came out from 2 EPRI, I believe that 't was either a concern, finding, 3 whatever INPO calls it, where we were not meeting the EPRI 4 guidelines. And -- Over a year or so how -- I don't 5 recall, you know, when it was first mentioned by INPO.

6 And I know that there was some -- a lot of t

7 discussion in the Chemistry department how we were going )

8- to get there. But it essentially involved that we were ,

9 going to try and meet the 25 cc's per kg, which was the T 10 new guidance.

11 MR. RAPP: When did that issue first surface? ,

t 12 THE WITNESS: Oh, I don't know. That was going 13 on for a couple years, I think.

14 MR. RAPP: Would that have been the time in 15 which you were in charge of Systems Engineering?  ;

16 THE WITNESS: It may have been that. Yeah. I 17 think that we did have some time in there that I was 18 involved in the INPO discussions on that. ,

19 MR. RAPP: Do you remember attending any  !

20 meetings where this particular issue was discussed?

21 THE WITNESS: A management meeting. I remember a-22 ' Pat Beard meeting that we had once where we were 23 discussing the INPO findings. And it was decided that we 24 were going to try to meet the 25 cc's per kg. And it was 25 somewhat under the -- We had a concern on the-technical t

f 13 ,

i i side whether or.not our design could handle that or how we 2 were going to do that.

3 I don't recall all the chings that -- since I 4 wasn't in the mainstream of the chemistry issue.  !

5- Chemistry was under Ops at the t4me. And it was a q t

6 Chemistry and Ops issue at that time how we were going to

~

7 get.there. And I wasn't really involved with that.

8 'You know, we did have projects in system 9 engineering based on the -- I believe it was an NRC i

10 bulletin or an IEN, or something that talked about the l 11 hydrogen binding of the makeup pumps. And-that's what 12 started this whole ball rolling as far as the makeup tank 13 pressure versus the gas binding of the makeup pumps.

14 MR. RAPP: During that meeting how was it

15. presented -- was it presented that achieving this 25 cc's i 16 per kg may not be possible or may require plant 17 modifications to meet that? ,

18 THE-WITNESS: I don't think it was that detailed.

19 I -- And you're asking me to remember, you know, four or 20 five years ago. I don't recall. I just recall that we

. 21 did have some discunsions on it.

L 22 MR. DOCKERY: Let me interject something. I 23 should have mentioned this sooner. Mr. Halnon, if at any 24- time you want to refer to-any-documentation you have or 25; that we may have, feel free to do so.

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14 1 THE WITNESS: If.I'm not sure of what I'm saying, .

t 2 I'll do that.

3 MR. RAPP: The involvement then to go to this 25 4 cc's per kg, you became involved with it more or less when 5 the issue on Curve 8 came up.

6 THE WITNESS: Yeah, It was like a wrap-up. It l 7 was like, you know, there-was concern when I first took (

8 the group over. We looked into it. The outage with the  ;

9 problems they had during the outage with the makeup pumps 10 and then the surveillance procedure that they did raised 11 the concern a little bit more. And it was sort of a wrap-12 up to culminate in what happened on the 4th and 5th.

13 MR. RAPP: You said you assigned Ernie Gallion  !

O 14 to look into this issue. And what capacity was Mr.

15 Gallion in?

16 THE WITNESS: Well, let me refer to something.

17 The reason I say -- And I only recall this because I have 18 a turnover one day from Ernie to me when he was filling in 19 fer me. He was giving me a turnover of some projects.

20 And one-of the turnover items was that he -- One 21 of the line items was that he mentioned -- It's going to 22 take me a second to find this, so you'll have to bear with  :

23 me, 24 January 17th. One of the action items was 25 _ forwarded, Bruce's - -

which is Bruce Willms, concerns to I

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1 Pat Hinman, he'll get the answers back System Engineering, At W 2 to me. And this is makeup 2N2 concerns.  ;

3 And that -- That's all I remember. I don't ,

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4 recall anything'else, except what I read here. So I'm 5 saying, you know, I was aware of it in January, that we  !

6 had some issues and that the operators, grassroots l 7 operators were meeting with the engineers to discuss it. f t

8 MR. RAPP Did Carl Bergstrom come to you 9 sometime in July and ask that Walt Neuman become involved 10 in this issue?

11 THE WITNESS: There was a time during the summer .

12 when I believe'some off-shift help was solicited. I don't

-13 recall if it was Carl or not. I know that some off-shift  :

14 help was solicited and we assigned Walt Neuman to help 15 represent Operation's concerns on the committees and l 16 meetings that were going on with Engineering. I don't  ;

17 recall if Carl asked me for that or not. I don't remember l 18 assigning WMit to-that.

19 MR. RAPP: But did Walt Neuman and Ernie Gallion ,

20 work together or work parallel or --

21 THE WITliESS: Well, Ernie -- Soon after this 22 Ernie-went on shift as a shift supervisor during the .

23' outage knd stayed on shift. So all that Ernie was doing 24- here was assuring that the r ight people were getting 25 invrived, which is all I did.

He was filling in for me, ,

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i so this is what he did, make sure that-the right people  !

2 were getting involved in it.  !

3 And so after Ernie went on shift, I mean, there 4 was no -- I don't think there was any formal turnover from .

5 Ernie to Walt, if that's what you're asking.

6 MR. RAPP Okay. So Walt Neuman more or less i 7 picked'up where --

8 THE WITNESS: Walt had been aware of the issue  !

9 for quite a number of years because he was involved as an 10 OTA, which was our operations technical advisor back in 11 the' development of the comments for the calculations going 12 back and forth between Gilbert Associates and us. So ho 13 was aware of the issue.- He wasn't coming into it cold.

0 14 MR. RAPP: So he more or less picked up for 15 Ernie Gallion then in that capacity.

16 THE WITNESS: Pretty much.

17 MR RAPP: Okay. .

18 MR. WEINBERG: Just for the record, what -- can 19 you just explain who Walt Neuman is and what his job is?

20 THE WITNESS: Walt Neuman is one of our 21 op rations engineers.

22 MR. WEINBERG: Okay.

23 THE WITNESS: Walt Neuman is one of the 24 operations engineers that works in Operations. He works 25 as an STA.

i

17 1 MR. RAPP: Works as a what?

2 MR. DOCKERY: STA, shift technical advisor.

3 MR. RAPP: When -- How involved were you with 4 this issue when Walt Neuman and Carl Bergstrom were 5 talking with Engineering? Were you updated daily on it 6 or --

7 THE WITNESS: I don't think I was updated daily  :

8 on it. I was -- I really don't recall my daily 9 involvement, if there was any daily involvement. I have 10 many things going on. This was just one of them that I 11 was making sure that the right people were involved with 12 it.

13 MR. DOCKERY: To come at that another way, Mr.

14 Halnon, as a manager what was your expectation of how this 15 issue would be resolved?

16 THE WITNESS: Well, the expectation I have is 17 that the people who know most about it are going to get 18 involved and solve it. And the people who know most about 19 it are people who have the concern and the engineers. And 20 that's -- From my understanding, that's who was involved.

21 My discussions with the operators who were 22 involved, you know, often said, yeah, we're talking with 23 each other. There was a couple times I know that after 24 the outage when SP-630 issued and the makeup pump gas, 25 what they prenumed was gas binding or what the operators

18 1 presumed was -- could be cavitation. .

2 I recall sitting down with Pat Hinman one tinie 3 personally and asking Pat whether or not he was getting 4 the support he needed from Ops to solve the issue and 5 expressing my conceyn over the difference of opinion, if 6 you would, on wersus.whether Y it was cavitation or whether 7 it was improper venting of the makeup pump.

8 Are you all aware of that -- familiar with that 9 issue, the SP-630.

10 And I recall, you know, sitting in Pat's office 11 and talking with him about it for a length of time and 12 discussing, making sure that the people who knew most 13 about the subject were working on it. And I came away 14 from that satisfied that that was what would happen.

15 MR DOCKERY: Mr. Halnon, you stated you had 16 previously been in charge of Systems Engineering?

17 THE WITNESS: In 1990. Late 1990 and 1991.

18 MR. DOCKERY: And you have an engineering -- You 19 are a degreed enginee-'

20 THE WITNESS: Yes, sir.

21 MR. DOCKERY: All right. Are we safe in 22 assuming that you had a pretty fair understanding of the 23 issues involved from both sides?

24 THE WITNESS: On a big picture view, Big picture 25 viewpoint, yes. I had no detailed knowledge of what was

4 19 1 going into the cale or I had some cursory knowledge of the 2 comments and problems they had with the calculation. ,

3 But nothing that was as detailed as what a system 4 engineer working on the project would have.

5 MR. DOCKERY: Was there some degree of friction 6 between Engineering and Operation, those people involved ,

7 in Engineering and Operations over this issue?

8 THE WITNESS: I don't know if I'd call it

~

9 friction more than I would call it just a difference of 10 opinion. And the engineers were having a hard time il convincing the operators of their technica) view. And the 12 operators were having a hard time, or at least in their 13 ..ind , feeling that the engineers were listening to their 24 part of it.

15 So there was a difference of opinion and they 16 were trying to work it out. And that's why I was trying 17 to make sure that the right people were involved in it.

18 But again, the people -- You know, there's lots 19 of things going on and lots of important things going on.

20 This was one of those projects that was ongoing. And it 21 was a high priority project, but it was certainly not the 22 only project we had going on at that time.

23 MR. DOCKERY: But it was high priority, in your 24 opinion.

25 THE WITNESS: It was a fairly high priority. I g w '*

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20 1 took my time to sit down with the system engineer to make 2 sure that the right people were involved in it.

3 MR. DOCKERY: Did you become aware that some 4 data was collected during the July time frame in order to 5 support Operation's contentions regarding Curve 87 6 THE WITNESS: I didn't -- I was aware that there 7 was some data taken. I was not aware until in the fall of 8 1994 that that was taken.

9 MR. DOCKERY: Did -- You directly supervised at 10 that time Mr. Bergstrom. Is that correct?

11 THE WITNESS: Carl was a shif t supervisor up 12 until approximately August. And then in August, some time 13 frame, I promoted him to manager of support, what he's --

14 his capacity right now, which you all are probably aware 15 of. So he was in a transitional period at that time.

16 Either way, he was direct report to me.

17 MR. DOCKERY: Okay. Did he make you aware of 10 his request to Mr. Willms to collect some data or plot 19 some data during what we've been told was a routine 20 evolution?

21 THE WITNESS: No. I was not aware that he had 22 requested data to be taken.

23 MR. RAPP: Were you aware of the July 19th 24 meeting between Bruce Willms and Carl Bergstrom and Pat 25 Hinman from Engineering?

i 21

+

1 THE WITNESS: Not-until after I was -- Well, 2 again, after the fall of 19 -- Well, no. Actually, it was 3 not until July that I was aware that Carl was involved in 4 that meeting. ,

5 MR. DOCKERY: July of 1995? -

6- THE WITNESS: '95, right. That's when I called j 7 Carl.  :

8 MR. WEINBERG: Well, did you --

9 THE WITNESS: Well, and I'm going to assume that 10 you've-got some of this information already. . You-know, il Mark Van Sicklen finally handed me the -- he gave me the i

12 folder with some curve information on it that was taken 1

13 back in the July 22nd time frame of '94. And, you know, 14 it had Carl's handwriting on it, i 15 So I immediately called Carl and asked him about 1C it. And that's when Carl told me that, yeah, he was 17 handed the data and it was technical information and he l i

18 didn't know how to reduce it, so he turned it over to the 19 system engineer back last year sometime.

20 And that was when I became aware that he was 21 involved in it. Up until that point I didn't -- except 22 for conversational type things, I didn't know Carl had any ,

- 23 involvement-in it at all.

24 MR. DOCKERY: It was not then an assignment that 25 you had placed.or levied on him?

1 w= y

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i 22 1 THE WITNESS: I don't recall. It may have been 2 something that I asked him to look into once or he mes 3 have been tilling in for me one day and, you know, he got 4 into it. I don't believe it was a formal assignment where 5 I wrote something down to assign it to him. But just by 6 fact that he t'as in management and i: Operations he was 7 probably involved in it in some capacity.

8 MR. WEINBERG: Did you know that Systems 9 Engineering was meeting with the operations side during 10 that time period, during July with regard to the issue?

11 THE WITNESS: I know now. If I knew then, I can 12 only assume that I -- I guess I probably shouldn't assume.

13 But, you know, I know the ducumentation clearly shows that 14 they were meeting at the time.

15 And my expectation at the time was that the right 16 people were involved with it. So if they were holding 17 meetings on the subject, that doesn't surprise me.

18 MR. RAPP: One of the things that has come out 19 during our discussions here is that Engineering viewed 20 this curve 8 issue as a lower priority item.

21 Did -- Was there an understanding of the 22 significance, safety significance of Curve 8?

23 THE WITNESS: On whose part, the Operations or 24 the Engineering?

25 MR. RAPP: Operations and Engineering.

s_...-__ ._ _ . . _ . _ _ _ _ _ . . _ ____._._ _._ _ ._ .. . _ . . . _._ _ ..

1 23

-1: -TiiE - WITNESS : -That's kind of a. tough question

.2 because what we know'now is different'than what we knew 3 'back then. . Curve 8, if I put myself.in'that-time frame, 4 was an operating curve.- And-typically your operating 5,' curves aren't design basis limits.

6 Now we know it was a design basis limit. So we 7.-might be more inclined now to say, yeah, it was a little 8 bit more safety significant than we thought back~then.

9- There was no operating margin whatsoever.

10 Putting myself back at that time frame -- Did we.

11 realize the safety significance of the issue. Is that _,

12 what you're asking?

13 MR. RAPP: How did --

14 THE WITNESS: You know, we have a lut of safety 15 signi'icant issues out there that we deal with. And --

16 MR. RAPP: But the basis of this curve was to 17 protect the safety system, correct?

18 THE WITNESS: Correct.

19 MR. RAPP Did enginaering understand that was 20 the basis for Curve 87 21 . T.!E - WITNESS : I would only be guessing if they 22 understood that.

23 EMR.1RAPPs Well, you said'you've had some-24 discussions with2 Pat Hinman1and other folks from 25 Enginaaring.

k 1

24 1 Did they present you with that understanding or 2 .come:-- did you come away with that they knew this was a 3- safety significant issue?

4 THE WITNSSS: .I guess I can -- You know, all I ,

5 can say is I-didn't.come away feeling that it-wasn't. I 6 don't know if I had that direct conversation, now, you 7 know this is a safety significant f3 sue, and point at 8 their face and say that.

9 MR. RAPP Did you --

10 THE WITNESS: I think that we under -- I think --

11 I felt that everybody understood that this was an issue

- 12 that needed to get resolved and that it was a very complex 13 issue and we needed the right people involved.

14 MF RAPP: Did you view it as a safety 15 significan'. issue?

16- THE WITNESS: It was -- Sure it was a safety 17 significant isnue.

18 MR. RAPP: And safety significant in what 19 respect?

20 THE WITNESS: Well --

21 MR. RAPP: I mean, nobody knew it was a design 22 basis limit back then, so --

23' THE WITNESS: We knew that the calculation was 24- there to protect the makeup pumps on an HPI-actuation.

25 And'that -- We dealt with that a lot-in the simulator.

r+-c-r--.. -

- + - vu,- ,-r,., e ,w.. - -y -- .,.y r- ,,-r g -

1 15 1 Tie are aware of work-aro nds at the time, ,

-2 operator work-arounds. And;this was_one of those. And_we 3' knew we_had to get it resolved.

4 MR. RAPP: Work-arounds in what regard?

5 THE WITNESS: Well, the fact that when the 6 operators have to take action or do something to -- during 7 the transient _that they wouldn't normally have to do or 8 the design didn't originally -- 64.dn't originally' assume  ;

9 that.

10 And we're talking now that they felt-like that 11 the operators would have to go isolate'the makeup tank or-12 do something sometime in the future past large break LOCA 13 that would -- And knowing that, that was something we had 14 to change our procedures to mak* it happen or, you know, 15 remember to make it happen. A lot of little issues like 16 that that would nag at the_ operators, because it's 17 different than what t. hey trained on.

18 MR. DOCKERY: Mr. Halnon, with regard to the 19- f act that it was learned t'.at Curve 8 was a design basis 20 curve or design basis ramifications, whatever, is it fair 21 to say that that was unknown up until a certain point by 22 the people involved?

23' THE WITNESS: -I-think thatis fair. I don't think

~

24 that it.was_widely--- if anybody realized, at least in 25 ' Operations, that that curve was the design limit.

A

=i- - -.-  % , , - -. -,,

26 1 MR. DOCKERY: Was -- Is it fair to say that 2 there was some surorise to learn that?

3 THE WITNESS: I think there was some surprise, 4 yes. Certainly on my part when I learned that there was 5 no operating margin built into the curve. That's not 6 normal. Operators aren't used to operating like that.

7 MR DOCKERY: Do you recall when that discovery 8 was made, approximately?

9 THE WITNESS: I don't recall when. I know it was 10 sometime after the July -- I mean, the September -- We're 11 talking about September, right, before the test?

12 MR. DOCKERY: I believe we have other testimony 13 that it was actually sometime in November.

0 14 THE WITNESS: Yeah.

15 MR. DOCKERY: We'll use that as -- So that would 16 indicate to me that starting -- Refresh my memory. When 17 was the issue of Curve 8 first brought up with Systems 18 Engineering, to your recollection?

19 THE WITNESS: I don't recall. It was even before 20 I took over as manager.

21 MR. DOCKERY: Okay, 22 THE WITNESS: I mean, as far as the makeup pump 23 issue with the bulletin. I think the bulletin came out in 24 '88, if I'm not mistaken.

25 MR. DOCKERY: I'm just --

27 1 MR. WEINBERG: See, there are issues that are 2 bleeding together here.

3 MR. DOCKERY: Yeah.

4 MR. NEINEERG: When you say the Curve 8 issue, I 5 believe what Greg is talking about is the hydrogen issue 6 that was sort of on people's minds.

7 MR. DOCKERY: I'll clarify it. The Curve 8 8 issue that I'm referring to is the concern by Operations, 9 by individuals within Operations about the validity of 10 Curve 8. That was raised -- I believe you said that you 11 had tasked Systems Engineering through Mr. Gallion to look 12 at the issue.

13 When did that first occur?

O 14 THE WITNESS: The only thing I have in my 15 recollection is this action item here that said -- proves 16 to me that in January right af ter I took the job we were 17 discussing it. It was an issue that we were working on.

18 MR. WEINBERG: Was the issue just -- Because 19 this memo, now that we're referring to it, says Bruce 20 Willms, makeup tank H2 concerns or hydrogen concerns.

21 Then it says, forward Bruce's concerns to Pat Hinman.

22 He'll get the answers back from them.

23 Was that concern whether the Curve 8 was valid, 24 or was that concern about -- as a result of the hydrogen-25 requirements that you all were getting close to the curve?

N 28 1 -I(E WITNESS:- I don't think you1can-separateLthe i 2- two.

3 .MR. WEINBERG:. 'Okay.:

4 --THE' WITNESS: I:think that that's ---I-think that 5.:if-the operators saw a -- during their bleed -- system

. 6' bleeds for normal operation, if they'saw tracking the 7 curve - ;the plant- tracking the curve exactly or at least 8 conservatively, I don't think there would have been an--

9 issue.

4 10 MR. WEINBERG: Okay. So in response to Mr.

11- Dockery's question then, _the earliest -- on your watch the 12', earliest indication youLhave in your' record of the -- sort 13 of the validity issue would be this January 17th, 1994,

, to 14 memo.

15 THE WITNESS: Correct. That's correct.

16 MR. WEINBERG: Because you didn't take over 17 until a few weeks before, .I guess.

18 THE WITNESS: Well, I took over in the Christmas 19 holidays of '93. We had an immediate EOP inspection, so 20 we were working with the NRC on that. I don't know if

'21 Curt was involved in-that. But, you know, we had some J

22 ~ significant issues as to-EOP issues.with things coming

,23 out.

24 :Thistmay be the first time we got our breath. I 25 don't know.

n.-

l l

>w 29--

1 MR,=-DOCKERY: Okay. We sort of have a1 time

-_- 2 frame then that I'm looking__for. Between January _of 1994 13- and certainly we'll use September of 1994,-is it correct

-4: to say-that Systems Engineering had been looking at Curve 5 8 at the_ behest of Operations?

6 THE WITNESS: I think that's accurate, I think n

7- the operators were not-letting it rest. I think they were

.8 using a good questioning attitude and they were not 9 accepting explanations they knew or felt weren't correct 10 or weren't accurate and they were pushing hard to get

-11 details, 12 MR, DOCKERY: Okay. Mr. Halnon, I'd like to ask 13 'you to -- using both your experienc.e and expertise as a e

14 former manager of Systems Engineering and in your current 15 position, would it have been your expectation that during 16- Engineering's analysis of Curve 8, their consideration of 17 Curve 8 that they would have discovered that it was a 18 design basis curve during that approximately eight and a 19 half month period of time?

20 THE WITNESS: Let me give you my opinion. Okay.

21 I think that if -- prior to this if you went up and asked 22 the person who did the calculation and the design engineer 23- who did the calculation, and I'm not even aware who did 24 that, and asked them, is this the design limit, they would 25 have said yes, because I think the problem is that when it I

  • i 30 1- got translated from the design world into1the, if you-21 - will, the plant'world, ILdon't think that information was 3- translated.

4- But I think, yes, there were -- I think that the 5 : guy calculating it would say, yes, this is a. design. limit.

6 That's my opinion.

7 MR. DOCKERY: . Would you -- ,

8 THE WITNESS - Because it was -- When you look at 9 the calculation and you look atLthe assumptions going into 10 it, which, you know, I don't have any~ detailed knowledge, il but'from what I understand from people telling me is that

.12 there -- you know, you start two feet above the pump 13 suction and you press it up.

b.

14 Never heard anyone say, and then you add this

<- 15- much margin for operations. You know, they just 11 6 calculated it on up. And they didn't provide any margin 17 in it.

. 18 So I think that the people actually doing the calculation and any of the details knew it was a design 4

19 20 limit. I don't think that was translated to the plant.

.21 MR. DOCKERY: Should it have been?

22 THE WITNESS: Well, of course it should have 23 been.-

12 4 MR. WEINBERG: But the original question was,-

25 did'you'think-that the Systems engineer that was looking

,- -- .#. = .,,t -,,.3 ,- 6-m, , , .s - ,.-.r, ..

7 .- r .c&-.n

~

31 1 at this in 1994 should have figured out in those seven or 2 eight months that there were design limits on this curve?

3 THE WITNESS: Should he have?

4 MR. WEINBERG: I think that's what you asked.

5 THE WITNESS: I would -- I think in hindsight, 6 yeah. I would say certainly. I don't know what the 7 context of -- what was in his mind at the time. Maybe he 8 felt like it was a design limit and didn't realize 9 operating procedures didn't have design limits in it. Or 10 maybe he didn't know it was a design limit.

11 But whatever the case may be,'it wasn't known in 12 my mind by the operators that it was a design limit.

13 MR. STENGER: It may be a preliminary question 14 as to whether Greg knows what makes the Curve 8 design 15 basis limit.

16 MR. DOCKERY: Certainly, it's --

17 MR. STENGER: Do you understand why the curve is 18 considered a design basis limit, for what accident 19 scenarios?

20 THE WITNESS: Do I understand why?

21 MR. STENGER: Yeah.

22 THE WITNESS: I guess it depends how detailed you 23 want me to get. I can go into the details, but from what 24 I understand, the curve is -- you start with a 25 hypothetical two-foot column of water above the pump, l

32 1 suction _ eye and you press'that up until you 9 a level in

_ -. 2 - the makeup tank-and a pressure.

- And that's whe'e the 13 pressure limit came from.

-4 -And that was with the original one. Now, I know 55 there's'been a lot of iteration since then. There's even 6 a-new issue with velocity head that gets into extremely 7 detailed. And I haven't -- You know, it takes hours and 8 hou'.s to reduce what somebod/ has done on those things, so 9- I don't have the knowledge on it.

10 MR. RAPP When -- Excuse me. When it was 11 identified that Curve 8 was a design basis limit, did-12 anyone inform you or did you find out through meetings or 13 other mechanisms what particular accident scenario that-14- limit was -- that was a limit for?

15 THE WITNESS: I think it was always -- I think it 16 was thought of, at least by myself, that it was the large 17 break LOCA issue, whether you were going to have rapid 18 draw-down of all the tanks. And so it was a worst case boundiR 19 Tor.L .g Waccident which is our large break LOCA.

20 And that certainly would be the timing limit, 21 anyway, because everything happened so much more quickly, 22 -quickly in a large break LOCA.-

23 MR. RAPP: The.information we've received here 24 is that. Engineering explained the differences between the 25 actual plant' response and Curve 8 by saying that Curve 6-

33 1 - was-generated based-on a large break-LOCA scenario, and- -

2 that the response during a large break LOCA would be ,

'3 different than it would be during a makeup tank draw-down.

4' From an engineering standpoint, do you accept d

5' that type of explanation?

.- 6 THE WITNESS: That was explained to me that way.

7 From an Engineering standpoint _I thought that it made 8 sense. Certainly the' dynamics of the system would be 9 different on a large break LOCA with a thousand GPM coming

-10 out of the tank or a thousand GPM flowing through the 11 mr.keup system versus an 80 GPM bleed.

12 And without doing detailed calculations myself, I 13 felt that was'a plausible explanation.

14 MR. RAPPt Did the physical laws of gas and 15 liquid behaviors change between normal operations and a 16 LOCA . situation?

- 17 THE WITNESS: Well, some do and some don't. When

- 18 you start talking about velocity heads, obviously there 19 would be some difference = - some differences. When you 20 talk about!the partial pressures snd the -- how fact the 21 partial pressures equalize in the tank, yeah, there would

- 22 be some difference.

23 Talking about temperatures equalizing and valves f

24 closing up on an ES~ actuation versus a normal operation

- 25 when valves don't_close, and so the temperature v-e- r, -. .--7 , ,

34 1 equalizations would be different, yes. There would be 2 some' dynamic differences in.the tank.

-. 3 -- And-again, from.a -- in my standpoint, listening.

J 4 to the engineers or listening to whoever was explaining 5 this to me, 4 seemed plausible.and I only-had to probably

'6 make the assumption that they had looked into all-the 7 dynamics of it and came up with that conclusion.

8 MR. RAPP: Did they provide any calculations or 9- modeling, simulation modeling to support their positions?

10- THE WITNESS: They didn't present any to me, no.

11 MR. DOCKERY: Mr. Halnen, the Curve 8 that 12 existed in July of 1994 is not the same Curve 8 that 13 exists today. Is that correct?

14 ~THE WITNESS: That's corrsct.

15 MR. DOCKERY: Were the concerns of the operators 16 identified with this issue justified in your mind?

1 17 THE WITNESS: You know, I-guess you'll have to

18. back up a little bit and say before the July -- or the 19 September 5th time frame or afterwards?

20 MR. DOCKERY: Well, I guess perhaps both. If 21 you make a distinction,.then we'd have to address them 22 both.

N 23 THE WITNESS: Okay.

24 -MR. WEINBERG: Well, maybe the first question j( 25' ought to be, did you believe in July 1994 that the

+

_ s ,,--.-y... -.-,w

35 1 concerns-of the operators =were valid or justified.

2 MR. DOCKERY: That's what --

3 MR. WEINBERG: In other words, putting himself 4- in that. situation.

5' THE WITNESS: I'd-have to say yes because 1 6- didn't squash the time that I was allowing the operators 7 to spend on it with the engineers. I was paying them the 8 . time to meet with the engineers and I even met-with the 9 engineers myself. So I felt like, yeah, they were valid 10 concerns and that we should continue to work on it.

11 If I didn't feel they were valid' concerns, my --

12 I would probably try to divert the operators and engineers 13 to do something else, would not spend their time-on it.

14 Because, again, there was a lot of issues we had to 15 resolve.

16 MR, DOCKERY: Well, I think we've pretty well 17 established that you telt they were valid concerns and 18 they were of some significance, 19 At what point in your mind was it fair to say 20 those operators were correct?

21 Did -- First of all, did you ever' reach.that i 7

22 conclusion?

23 THE WITNESS: Again, because I never saw -- I 24' have never seen, even now, and again, I'm not into the 25 ' details because I have assigned the details to somebody

l 36 1 else, a dynamic model that would have emulated the drain-2 down of the tank on a large break LOCA.

3 I recognize that there is a difference in the 4 curve back then when you bled the system under a normal 5 system bleed, and that the. points did not track the curve.

6 .There was some thought afterwards that there was -- that iev$ Ae ny ,

7 was just a TOGA 14 of points and it was a pre-existing LOCA 8 condition that you had to have. And wherever it went 9 afterwards, okay. That was the thought out there.

10 I don't think it was clea*. for a while what 11 exactly we were looking at and how it related to a large 12 break LOCA versus a normal system operatian.

13 When you look at just simply a P1-V1 equals P2-V2 14 relationship, well, certainly from a very simplistic view, 15 you would say, well, it should be the same. But then you 16 start dealing with all the different variables, the 17 volumes and the variable pressures and the partial 18 pressures and the temperatures and the difference in 19 velocity head.

20 When you add in all these other complex variables 21 in a P1-V1 equals P2-V2 relationship, it probably is not 22 valid or certainly it may be too simplistic for the margin 23 we were asking the operators to operate the thing into.

24 So I rambled. I don't recall the original 25 question. But, yeah, I think that the comments were f

37 1- valid. =I think we'needed to run it down. I think the 2 operators'-concerns _were valid. I think the engineers e 3 were addressing-them and they were_providing what I felt 4 were-plausible. technical reasons for what'the oparators-5 were seeing. And I don't-think the operators were 6 accepting them.

-7 MR. RAPP: Why didn't the operators accept what 8 Engineering told them?

9 THE WITNESS: I don't think the operators - _And.

10 I'm_specifically talking probably about Mark Van Sicklen 11 and Bruce' Willms, the operators that w'ere mostly involved.

12 I don't believe that they came to the same 13 understanding the Engineering people did, whether it was a 14 communication issue or whatever. But the Engineering 15 would give them an explanation and the operators would 16 critique it and say -- You know, and which was good. I 17 mean, you want them to be questioning things coming up 18 from Engineering. You want them to question it.

19- So I just don't feel like they were-accepting 20 some of the things they were saying, or finding some 21 issues out there that -- Like I recall one, is that we 22- talked about the volume of gas and-how that would, you 23 know, affect the drain-down.

24 Of course, the volume-assumed.in the calculation 25 above the water would affect the calculation, and hence,

- . - . .. . . ~ . .- - . - - . .

.- . . ~. . - . , .- - .. _ - - - -. -. .- -.- . -- . . - . .

38 1: the curve.

1 2 The1 operator looked-.at the calculation, I

,3 assigned ---I mean, Mark Van-Sicklen looked at the.

-4 calculation andLsaid, hey, they didn't take into

5 consideration the shortLruns-of pipe that were coming into 6 .it. There's also1 gas in there up to the first isolation 7 . valve.

8 MR.-DOCKERY: Well, let me stop you there'for a

-9 second, if I may. -Engineering did not take into account 10 physical aspects of this plant in responding to a stated 11 concern.

12 MR. WEINBERG: That's wnat Van Sicklen told him.

Okay.

13 MR. DOCKERY:

14 THE WITNESS: And I would even put that -- The 15 Engineering, I believe, assumed it was negligible. And 16 that's often done during calculations, you assume 17 negligible affect, especially when you're talking about L18 long runs of half-inch pipe that has'a negligible volume. ,

- 19 _Okay.

- 20 Well, that was another comment that.-Mark threw 21 back on them, saying, hey, you guys didn't take this into

. 22 consideration.-Land I don't recall the outcome of that, if 23 theyl redid the-calculations and.put the volumes-in or not

- 24 But'that was just an-example of how they would 25 set up,1you know, the calculation for review. And the t

e -.v, .m,. ,..

39 1J' operators would critique it and look'at it, and say, hey, 2-- here's some-more.for-you.- And that was going back and 3 :forth.

4- MR. DOCKERY: I'm going to make an observation 5 -here'or an' assertion. And if you like, I'll afford'you-6 the opportunity to take exception to it and explain why 7 you-do. Engineering _was wrong.

8 THE WITNESS: In what respect?

9- MR. DOCKERY: If Engineering had been correct, 30 would this plant be operating with a different curve 8 11 today?

-12 It's not the curve that they said was 13 conservative and valid in mid -- well, let's say in

-14 September of 1994. Granted, they were still working on-.

15 it, but the same curve does not exist today.

16 What, to your knowledge, happened between the 17 time they said we believe this curve is conservative and 18 valid and the time when a new Curve 8 went into effect?

19 THE WITNEOS: Let me ask both -- answer both your

20. questions. The assertion that Engineering was wrong, I 21 believe there were some aspects of the calculation that 22 was incorrect.

23 Was it --

24 MR. DOCKERY: Can you amplify on-that?

25 THE WITNESS: Well, okay. Was it negligence or l

i 40 1 was it the f act that they were bad engineers, or something 2 to that effect, I don't think that's the case. I think --

3 MR. DOCKERY: I didn't mean to make a value.

4 judgment. That's not --

5 . THE WITNESS: Right. But I_think the case-is 6 that what we have is a complex set of variables and a -

7 . complex set of conditions that are set up,.and also a 8 complex operations of a system that you have to add all 9 these-things into the equations.

+

10 And I don't think all those things -- I think 11 .there was a iterative process of adding those things into 12 the equation. I think it was an iterative process, both 13 on the Engineering part of recognizing what needed to go ,

14 in there and it was an iterative process on the. Operations 15 piece, every time they reviewed-it they may have come up 16 with a new, oh, what about this, what about that.

17 So was Engineering wrong? I think they -- Yeah.

18 In some cases Engineering was wrong. Was Operations 19 wrong? Yes. In some cases the Operators didn't give a 20 full' good _ review of it either, because they -- otherwise, 21 why did we take so long then -- how come we had so many 22 iterations of the same calculation. -

23 So.it's on both sides of the boat here.

24 . Engineering relied on Operations to provide those-25 operations input. ' Operations relies on Engineering to do v -,c c.,- - , 1 --

w . -

41-1 the technical pieco of it. .And the connection of those

-2 has_to be made.- Ar d if it was made properly,- then we 3: wouldn't --

4 MR. DOCK 3RY: We've got a problem here because 5 we have to somehow define what transpired between 6--Operations first saying, I think we have a problem with

~

7 Curve 8,-and the fact that eventually Curve 8 had to be 8 changed. That's something we have to grapple with and we 9- have to 'omehow define what now you're referring to as

~

10 sort of a give and take where maybe one side or the other

11. was.nolding back.

12 THE WITNESS: No, not holding back. I --

13 MR. DOCKERY: Okay.

14 THE WITNESS: -- deny that.

15 MR. DOCKERY: Okay.

16 THE WITNESS: I would say they were learning more 17 about each other's piece of the &ction here. And each 18 iterative process got a little bit more-detailed.

19 And again. even now we've found another -- I 20 mean,-after the NRC review of the -- we found another 21 thing that could be. thought of as maybe we should have 22 taken that more -- you know, closer-scrutiny and better

-23L consideration on the velocity head in certain areas. And 24 I'm not sure of all the details on that.

25 But even now we're learning more about this. And

- -42 1 it's just -- ItLillustrates the complexity of-the issue.

2: And'this iterative process, whether it=was correct or not,-

3 took place in each other -- each department learning more 4 _about what the other department needed to do a -- get a 5 valuable -- I mean, a quality curve out.

6 MR. RAPP: I'm a little bit confused _here about 7~ the process you just described. You said that Operations 8 did some sort of reviewLand then fed back to Engineering 9 the results of Engineering's work, or something of that

10. nature.

11 THE WITNESS: Well, that was the iterative 12 process I'm talking about. There was several meetings and 13 I can't -- don't have personal-knowledge of when or where

.c 14 they took place. But I know that the concern was raised 15 and the calculations were done, or answers to concerns 16 were given. Those concerns and/or answers were reviewed-17 by the operators involved and those operators would come 18 back with different concerns and/or other questions. And 19 that's the iterative process I'm talking about that took 20 place over the year.

21- And the letter that was sent out by the 22 Engineering is just another example of that iterative 23 . process. I mean, we're sending this to you, here's what 24- we plan to do.

-25 -Do you have the letter from Jerry Campbell?

t 4 i k

43

1. MR. WEINBERG: Yes. Talking about1the September l 2: 2nd. ,

3- MR._ DOCKERY: (Nods affirmatively.)

4 THE. WITNESS: Yeah. This is going to Bruce, t- 5 who's my boss, sayinb, you know, here's our -- what_we're-6 going to do, this is what it's going to take. He's giving 7 us an opportunity to respond to it, and we did. We were 8 in the process of it.

9 MR. DOCKERY: What-response did you anticipate 10 to that memorandum?

.11 THE WITNESS: As from an Ope $ations standpoint?.

12_ MR. DOCKERY: Yeah. From your department or 13 those under'you responding to.it.

14 ~ MR. WEINBERG: And what --

11 MR. DOCKERY: Feel free to review it if you 16 haven't and would like to.

17- MR. WEINBERG: You mean in the-normal course of

-18 this --

'19 MR. DOCKERY: Right.

20 MR. WBINBERG: -- evolution then to happen, what

'2._ would you have' expected the response from -- the normal 22 . response from. Operations to a memo like this.

23- THE WITNESS: .ILwould have1 expected that we_would 24 have come back and say -- because they gave us several 25 options.in here. And that we would come back with either-1 3

. . - , , .- , g.-.--.- m., r , , , , , ,-.,,-re-. , . - m.- , .,e.

44 l' a preferred option and/or comments on -- like, maybe we 2 need to do_something a little bit different, here's-3 -another idea.

4 You know, Pat Hinman was' talking to the 5 operators. He didn't shun them. He spent a lot of his

'6 personal time with them trying to get their concerns and

7. answer the questions. He had a lot of projects he was 8 doing that with.

9 He was -- So, you know, there was not -- None of 10 this should have been a surprise to the Operations 11 department. -You know, certainly when I read it, I didn't 12 have any major hard spots with it.

13 And_I asked my engineering contact in operations 14 to run it down, are we satisfied with this, you know, will 15 this solve the issue once and for all. And that was what 16 I wanted to come back, say either yes or no this won't, we 17 need to do something else, or, yes, we believe this will 18 solve the issue.

19 MR. WEINBERG: Just so the record is clear, he's 20 referring to some notes that he wrote on the top of this 21 memo-which says, Ken, are we satisfied this will_ solve the 22 issue.

23 And you_just might identify who Ken is and what 24- you.mean by.that.

25 THE WITNESS: Ken Vogel is the supervisor of

45 1 Operations-~ engineering:that works -- .

2.; ' MR, DOCKERY :_

Could you spell that l'ast.name, 3 please.

4 THE WITNESS:' V-O-G-E-L. And Walt Neuman worked S' -for him. That's going through~the chain of command to get ,

6 up to the people who-were involved with it.

7- MR.-DOCKERY: You might not have any knowledge 8 of this, but to the extent you may, do you_know if anybody 9_ in Engineering during their considerations of this Curve 8 10 issue, did they actually pull the calculation it was based  !

11 upon and review that calculation?

12 THE WITNESS: I don't have any specific knowledge 13 of that, no.

'14 MR. DOCKERY: Are you aware that Dave Fields did 15 obtain the calculation and review it?

16 THE WITNESS: I'm aware now that he had a copy of 17 the calculation. I'm not sure when he reviewed it and/or 18;- when he got it.

19- MR. DOCKERY: According to his testimony to us, 20 it was somewhere around September -- immediately after he. ,

21 -became aware or was made aware of that September.2nd memo, 22 .and which we assume to be -- or I would take to be 23 September the 4th, I believe.

24 THE WITNESS: 'I do-recall the STA that.was on 25 duty that night,--or one of -- not that night, but the i

46 1- night'before or -- his name is Harvey Liles.

2- MR. WEINBERG: Harvey --

3 THE WITNESS: Liles, L-I-L-E-S. When all this 4---stuff kind of blew up, you know, over the time, and I

-5 don't recall when he talked to me, but I did ask him of 6 his involvement. He was asked if he had any knowledge'of 7 the test that was going on on'this night.

8 He said the only thing he. recalls of that time-9 ' frame was that -- whether it was Dave-or the shift, or

-10 whoever, asked him to get a copy of the calc. And Harvey, 11- being'an engineer, also, knew where to ao to get the cale 12- and got --

obtained the calc for them.

13 So that kind of-corroboratea what1he said, that, 14- yeah, he received the calc somewhere around that time ,

15 frame. What.you said kind of keyed my memory about it.

16 And I . don' t know -what rev that . calc was either.

17 I don't know.

18 MR. DOCKERY: I couldn't-tell you.

19 THE WITNESS: Yeah. I don't -- Because I don't 20 even know what rev we're on, I'm-sure, which rev.

-21 ~ MR . DOCKERY: We were given to believe by Mr.

22 Fields that it was whatever was appropriate to Curve 8 23 that was in:effect at that time.

24 THE WITNESS: 'That a You know, we have to assume L25 that the file was up to date and Harvey got the right-calc

1 n.

, 47-n.

1 --- on': it .

2 MR. DOCKERY:. Well, he testified'that based on? .

3 reviewing the calculation he felt that there were clearly 4 some assumptions :b2 that calculation that were probably- f,

+

S : incorrect.

6 Do you have:any knowledge or-feel for that?

THE WITNESS: Right now, because I've heard a lot _

7 8 of discussions about it, I recall that there was --

9 MR . : DOCKERY :: Perfect hindsight.

10 THE WITNESS: Yeah. And I recall that some of 11 _the. references to procedures were old references, like

. 12 AP-380 was referenced, which was the old ES procedure.

13' Whether that affected the technical content of  :

- 14 the calc, I don't know.

15 MR WEINBERG: Prior to September 5th or 16 ' September 4th, for that matter,.of 1994 --

17 THE WITNESS: That weekend. Let's call it Labor 18 Day =1994.

19- MRi WEINBERG: Prior to.that weekend did -- or 20- during that weekend di'd Mr. Fields or anybody from his 21 crew; call you to discuss the calculations?

22. -THE WITNESS: No. No.

23 MR. WEINBERG: Or to ask for. permission to do a ,

. c 24~ test or-an evolution?-

- 25' THE WITNESS:

No, >I had received -- I don't r

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-48 l- recall any-phone calls during that time-frame.  !

m 2; MR. RAPP:- If Mr; Fields had. elected-to call.  ;

a  :

3 y'ou, what time-would that phone call have come in?

4 THE WITNESS: 'Well, I get called in the middle of 5 .the night.a lot.- I say a lot. Maybe once or twice a week 6 from the midnight shif ter if he's got a concern and/oria

'~

7 problem. .And I_ encourage that. I tell them, you know, I

- 8 .can go back to sleep,--but the plant operates all the time.

9- I've~ encouraged over the years'to have the guys:

10 beep me at the house if they want to talk to me. I, you 11 know, encourage that over and over again su) that they 12 don't have any problem calling me, 13 They-were on midnight shift. They could have-14 called me in the morning. They could have called me when 15 they came in around 11:00 o' clock at night. You know, 16 they never seem to be shy about calling-me.

17 But they are courteous. I mean, if it's not a

-18 real' critical concern, they11 wait in the morning and/or 19 just catch me when they can.- So, you'know, they don't 20 call me frivolously and wake me up. But they -- You know,

21 if there's a concern, they call.

'22 MR..WEINBERG: If not you, who could they have 23 called to ask for help from that would be superior to.

124 them?-

25 THE WITNESS: Well, the shift manager was on-4 4

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. . ~ . . . - . . . - . . . - . . - .. _- . . . - . _ - . . - . - -. . . . -

49  :

i 1; site.f'l'm not sure it was recognized that:he was superior ,

2 'to thettat1the time,Lbut he certainly was a-member of 3 management that was there as'a resource if-they felt like 4 they needed anotherLresource.

5 MR.'WEINBERG: Do you'know who that was then, 6 though?

7 THE WITNESS: I've heard a couple. And I think 8' ' it was Bill' Marshall _was one night.

  • 9 MR. WEINBERG: Would he be'someone that had any.

10 dif ficulty communicating with the supervisors or 11- operators?

12 THE WITNESS: Well, I took over Bill Marshall's 13 job. Bill-was in_my job beforehand for six years. -So he 14 knew the operators better than I did. <

c 15- MR. DOCKERY:- Mr. Halnon, what did Mr. Fields, 16 Mr. Weiss, and their shift do wrong on the night of 17- September.the 5th, 1994?

18 THE WITNESS: What they did wrong, from 19 Operations standards, was that they violated OP-103B, 20 Curve 8. It-clearly _ stated it was a maximum hydrogen 21 pressure and that there was an acceptable and unacceptable

-l.

22 side-of the curve.

23- :They allowed it-to go to the unacceptable side.

24 Land:in doing that the.'AR, annunciator response procedure 25'iwas-not' complied-with in a timely fashion.

4 1

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1 50 I

.1 -- That_didn't concern me as much as the violation.

2 ' of'the curve. ,

'3 MR. DOCKERY:- At what point --'When in time was .

4 a consensus reached that they had not performed up_to.

'5 1 standard?

6- THE WITNESS: I first -- I don't recall.when I 7 first became aware of the test. I do recall --

8 MR. DOCKERY: Do you recall generally at all, 9 Mr. Halnon?

10 THE WITNESS: Well, I know'that that week after 11 the test INPO was at the EOF, so I.was -- they were 12 evaluating our simulator performance on two shifts down 13 there. So I was highly involved in that. So I was 14 bouncing back and forth between the plant and the EOF, 15 And if I was at the plant for any period of time, it was 16 to pick up paperwork and/or return phone calls, whatever.

17 I know that sometime during either that week or 18 ' the weekend or sometime.before= Monday, the following week 19 I received a copy of the graph that was done. And whether

' 20 it was in E-Mail I received it or if it was on my -- 7 21 thought -- My recollection was that I received some kind ,

22 of E-Mail from Rob Weiss alerting me that, hey, here's 23 . some data, interesting stuff.

12 4 And there was some -- I recall in the E-Mail 25 there was some kind of correspondence that Rob felt like

^

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51 l

1 it might be a, if you will, volatile issue, I might take i

2 some heat over it,-or something to that effect.

3 I received a -- I wasn't back in the office until ,

4 the following Monday. And I don't recall when my  ;

5 recollection of when it changed from where I thought it 6 was when I saw the graph, was some kind of data that Rob 7 had extrapolated on a computer, because he was really good 8 on computers, to where this was real data!

9 But what alerted me and got me cc.1cerned was an 10 E-Mail from Phil Saltsman to Rob, which I read Monday, and 11 it said something to the effect, from the data that you 12 experimentally arrived at, And that word experimentally 13 keyed me. And I didn't rend that until that afternoon.

14 Rob had already gone home.

15 So I was concerned about it Mcoday afternoon, the 16 following -- the Monday af ter, the wee t af ter.

17 MR. DOCKERY: So I want to make sure I 18 understand. It would be approxinately the 12th or 13th of 19 September?

20 THE WITNESS: Yeah, Whatever that Monday is. I 21 think it's the 13th, 22 MR. DOCKERY: I think you're right.

23 THd WITNESS: Because the 4th was -- The 5th was 24 the Monday -- Something like that. Yeah.

25- And so when I came in the next morning, that's

52 j l' when me and Bruce went head to head. And he had talked i

2 with System Engineering the night before. I think that's 3 at Kelly's Gym where, I guess, they were lifting weights j 4 together oc something.

4 5 And he became quite --  :

6 MR WEINBERG: System engineer. You mean 7 Saltsman?

8- THE WITNESS: Phil Saltsman, right. And he came 9 in highly concerned about it. I came in with an inkling 10 of I saw something resterday afternoon I wanted to .'ook 11 into, ,

12 And we started that process of that week of 13 getting the information and having the management review 14 committee, and -- Well, I'm sure you're familiar with the 15 turn of events from there.

16 MR. DOCKERY: I don't know -- For lack of a 17 b:tter way of wording this, at what point did Mr. Fields 18 ana Mr. Weiss -- at what point were they perceived as 19 being in trouble?

20 THE WITNESS: It was probably very early in that 21 week or early 7tesday, as soon as they started from me 22 getting questioned about what they did and how they 23 performed it'.

24 They're'very -- You know, people are very 25 ' perceptive. They_ realize when you-ask questions on how.

1 t

l 53 1 did you do that, did you have a procedure, and why did you l 2 do that, those types of things, those types of questions 3 are going to lead them to believe that they're being I

4 scrutinized for something that they did rather than the 5 focus is getting now away from the data and the focus was 6 more on how we got the data.

7 MR. DOCKE"Y It's human nature when somebody's a confronted that way to justify their action, that they try 9 to do just that.

10 What do you recall about how either Mr. Fields or 11 Mr. Weiss tried to justify what they had done?

12 MR WEINBERG Are you -- Just so it's -- I know 13 that there was a lot going on and I know more than you.

14 Are you asking him -- Because I've talked to 15 Bruce about it --

I mean, to Greg about it.

16 Are you asking him first or do you want him to 17 detail sort of how he went about this, did he talk to 18 Weiss and/or Fields before the management review committee 19 and what they told him, and then what happened in the 20 management review committee?

21 And is that -- Or do you want it all sort of 22 huddled together?

23 MR. DOCKERY: We can cer',ainly get into that.

24 But I'm -- In this question what I was really trying to 25 get at, what was their first defense.

.- =. _ . - - - - - - - . .-

54 1 MR. 'WEINBERG: Okay. Well, that's when you 2 first went and talked to them then, I guess.

3 MR. DOCKERY: What did they first come up with 4 as a justification for their actions.

5 MR. VORSE: And when.

6 THE WITNESS: To recall specifically which 7 conversation revealed which information, I don't recollect 8 because I -- They were in the control room area and I 9 recall talking to them outside the control room area, 10 then coming back to my office, and going back and forth 11 several times.

12 Because Bruce was in an NGRC subcommittee 13 meeting, which is our general review committee. And he 14 would come out and ask me some questions during breaks.

15 And, oh, that's good questions, Bruce, let me run up and 16 see -- and ask them to answer those. So he was thinking 17 about it and thinking of questions. I was thinking of 18 questions.

19 And I would say that Bruce was -- I think his 20 concern and awareness of tne seriousness of the issue was 21 on a higher peak than mine. You know, I'll admit that I 22 was not as quick as I should have been in hindsight of 23 reaching the same level of concern that Bruce did. But I 24 did reach it fairly quickly because he was pushing me 25 hard.

w , --

r-- - ~,

55 1 As far as Rob's --

2 MR. DOCKERY: Bruce is who? I'm sorry.

3 THE WITNESS: Bruce Hickle. I'm sorry. The 4 plant manager. ,

5 MR DOCKERY: Oh, okay.

6 THE WITNESS: As far as when Rob -- And what they [

7 said to me initially, they -- what they had said to me 8 culminated in what they wrote down as a chronology of the 9 event for the management review committee.

10 Sometime during those two or three days before 11 the management review committee I aske'd them to supply me 22 with a write-up of what they did, which is common 13 practice. And when something happens significantly, ask 14 the people involved to write it up.

15 This is what they supplied to me. And this was 16 what I believe they told me at the time. And I don't 17 believe they told me anything different than thin.

18 MR. DOCKERY: Okay. So that's more to the point 19 that I was trying to reach than their -- What they told 20 you initially and what they stuck with as their rationale 21 for what they had done was consistent. Is that fair?

22 THE WITNESS: Yes. F.gnt. And it was consistent 23 with what they wrote down hert 24 MR, WEINBERG: And what he's referring to is 25 this document that's entitled OP-103B, Curve B (sic),

56 1 Verification 9/5/94.

2 THE WITNESS: Curve 8, really.

3 MR. WEINBERGi Oh, Curve 8, Verifica. tion 9/5/94.

4 MR. DOCKERY: Perhaps now we can get into the --

5 what Mr. Weinberg touched on. What led up to the 6 management review panel?

7 THE WITNESS: Druce had -- you know, had 8 originally in his plans he was going to go out of town 9 sometime during that week, the week in question, the 9/13 10 time frame. I mean, that was the Monday or so. So 11 sometime during that week he was going out of town. It 12 was going to be after the NGRC. I believe it was an INPO 13 plant managers conference, or something.

0 14 So -- And that added to our -- his pushing real 15 hard to get information. He was in and out of the NGRC 16 committee meetings. He was pushing hard to get the 17 information so that he could feel comfortable leaving 18 town.

19 It came to a point sometime during that -- before 20 he was to leave town that he canceled his trip because it 21 was evident to him that he needed some more time to get to 22 the bottom of this.

23 And as soon as he canceled his trip things calmed 24 down a little bit and we discussed how we were going to go 25 about finding out all the details that we needed to find

.57 1 out so that we could assure ourselves that the operators 2 were-safe.

3 And that's when Bruce decided then, you know, it 4 was not proceduralized to do this or.anything. He decided S to have a management review committee come in. We picked

-6 some key individuals in the organization, asked them to 7 sit on a -- you know, a round table discussion with the 8 operators, Dave and Rob, to discuss-what had gone on and 9 to cross-check our standards and make sure that we -- me 10 and Bruce just weren't flying.off the handle.

11 And that's basically how the sequence of events 12 came up to the management review committee.

13 MR. VORSE: I'm sorry to interrupt.

14 THE WITNESS: No problem.

15 MR. VORSE: Can you kind of describe the 16 atmosphere of this management review panel when you sat 17 Mr. -- Did you sit them down together or did you --

18 THE WITNESS: No. They were separate.

19 MR. VORSE: Both together?

20 THE WITNESS: No. They were separate.

21 -MR. VORSE: Single. Separate. When you asked 22 them to explain the events, did you ask them to tell the 23 whole story or did you specifica11yf focus on the September 24 Sth evolution?-

25 .THE WITNESS: Jim, I don't recall the specific

\

58 1 line of questioning. I think we focused on this write-up, 2 would be my guess, because this was -- I asked them to 3 write this up specifically for the management review 4 committee. Because I said, we're going to need something

\

5 to speak from. So I asked them to write this up.

6 So I believe we spoke from this and we went over 7 the bullets on this thing.

8 MR. WEINDERG: Right.

9 MR. VORSE: They indicated to us -- Excuse me.

10 They indicated to us that that was a very uncomfortable 11 session for them, that it was not hostile, but certainly 12 uncomfortable.

13 THE WITNESS: Again, it comes back to the other 14 Jim's. It's human nature to feel uncomfortable. They 15 were obviously being called in under a -- on an issue that 16 called their performance into question. And that's a very 17 personal issue with people and, sure, it's going to be 18 uncomfortable. It was uncomfortable for all of us.

19 MR. RAPP: It's fairly common knowledge that Mr.

20 Fields ad been questioned before on a couple 21 of issues.

22 Did his involvement make it --

amplify the 23 concern?

24 THE WITNESS: Dave 'ad a history of a temper. I 25 don't think that was any secret. That it wasn't hard to

59 1 light him off and get him quite irate on issues.

2 Yet, this management review committee, he handled 3 himself very well. He was very professional. There was 4 no personal attacks. It was looking at the facts. i 5 There was nothing -- You know,f 6 6

s 7 , I

~

8 think we stuck pretty much to the standards and the issue 9 at hand as far as the technical aspect of the curve and 10 the perform nce of the test itself.

11 The same thing with Rob. Rob is very fairly 12 even-tempered. I don't think I ever recall seeing Rob 13 mad. And he handled himcelf very professionally. A very 1

14 calm demeanor. And both of them did a real good job of

15 it.

16 I was proud of both of them when they came out of

' 17 it that -- the way they handled the questions.

18 MR. DOCKERY: I'm sorry. I missed something.

19 Csn you just tell me what the date was of that? I missed 20 that.

21 THE WITNESS: The review committee?

22 MR. DOCKERY: Yes.

23- THE WITNESS: Thursday, I think, of -- I think it )

24 was Thursday of that week.

25 MR. WEINBERG: I mean, the date the documents i

I 60 1 indicate is September the 15th of '94.

2 MR DOCKERY: Okay.

3 MR VORSE: Mr. Halnon, you say that you were 4 proud of these two gentlemen in their professional l 5 demeanor and everything.

[

6 Dut how about their explanation, how did you feel 7 about their reasoning for doing what they did and did you ,

8- feel that they had not violated any procedures?

9 THE WITNESS: No. I held fast that they violated 10 the procedure. They had, in their mind, how they 11 justified it, which was not very -- you know, real far off .

12 the wall. But there definitely was an error in judgment.  ;

13 And of course, we made that clear to them during

- 14 -- af ter Bruce reviewed the results of the committee with 15 them the day -- I think-it was the day after, that we felt

- 16 like it was an error in judgment. And we felt like they

-17 acknowledged that it was an error in judgment.

19 They -- You know, their judgment was that the i

19 shift supervisor had the authority to violate the curve.

20 And it was made_quite clear to them that that's not the 21 case, nor is it in the procedures anywhere that gives them-22 that authority. That was -- Their error in judgment was 23 -in_the fact that they felt like they had the authority to 24 violate the curve.

25 . MR. DOCKERY: What disciplinary action was

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i 61 1 contemplated or followed through with at that time?

2 THE WITNESS: At that time, based on the way they 3 responded in the management review committee and -- we 4 felt like and it was out of the recommendations of the 5 management review committee to verbally reprimand or 6 counsel Rob and Dave as to the reasons for operating 7 procedures and curves and what authority you have and what 8 authority they didn't have, and what authority they needed 9 to go to the plant manager or other management off-site if 10 they have questions.

11 We felt like that, based on the results of that 12 counseling and their responses to that, that that would be 13 all that was necessary from that standpoint. We had some 14 significant lessons learned out of the who1.e issue and 15 some follow-up things with the rest of the operators to 16 make sure that -- you know, that this authority is 17 understood.

18 But we fcit like the verbal counseling that Bruce 19 and I was a part of was all that we really needed to do.

20 MR. DOCKERY: How about the other operators on 21 that shift, was there any disciplinary action taken 22 towards them?

23 THE WITNESS: Well, we focused highly on the 24 supervisor because we hold them accountable for the 25 operation -- safe operation of the plant and the

62 1 application of management standards.

2 The operators, we felt like, need to be 3 supervised. And we were relying on those supervisors to 4 supervine.

5 MR. DOCKERY: Were you privy to any discussions 6 where more drastic disciplinary action was discussed at 7 that time?

8 THE WITNESS: Well, from wh4ch ctastopoint? I 9 mean, there was -- One thing in human nature, also, is 10 that people get pretty pissed off and say some things they 11 probably don't really meas 4.

12 There was probably some comments made when all 13 the facts weren't out that -- you know, to the effect that 14 if I find out somebody did something or other, they might 15 get fired, or something to that effect. I can't deny that 16 those might have been said by other people. I know I 17 didn't because I'm not a -- I didn't get -- I don't recall 18 myself getting, if you will, just completely irate about 19 the whole thing.

20 But I specifically remember Pat Beard talking --

21 I don't know if he said Fields in general or 'just, Fields, 22 that -- you know, and I don't recall when he said this.

23 But -- And it wasn't a threat to Dave. It was just saying 24 that, you know, if we find out that there is a blatant 25 something or other, you know, he may get fired. And

63 1 that's just the end point of a disciplinary process. l 2 MR. DOCKERY: Well, was it - -

3 THE WITNESS: But those were not orders to me or  !

4 were not threats. They were just comments kind of I S enveloping the whole issue.  ;

6 MR. WEINBERG: This would be before the ,

i 7 management review committee findings?  ;

8 THE WITNESS: No. No. This would-be'afterwards. ,

9 MR. STENGER: I'm sorry, Greg. Was Dave present 10 during that discussion?

11 THE WITNESS: No. These are management 12' discussions behind closed doors that we discuss people, 13 performance. I mean, that happens. We discuss -- That's 14 what management's for, is to coastantly monitor the 15 performance of the people. And if we have issues or 16 problems with people, we look at' options.

17 MR. DOCKERi Is it fair to say then that you 18 weren't privy to any conversation where the possibility

-19 that Mr. Fields and/or Mr. Weiss would be terminated was 20 discussed seriously or, you know, in a rational manner?

21 THE WITNESS: No, not -- Right. It was not - - I 22 think that's correct. And if I could reiterate your +

23 words : it is that they were not -- it was not a serious 24 -plan. . It-was not an established plan to work this way.

25 We felt like-the counseling was all that was necessary.

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t 64 i lt obviously their performance evaluations would reflect 2 their performance during the year and that would be part 3 of it. So that was going to be a piece of it.

l 4 They should have expected that. I expect that if l

5 I mess up. I expect it to be, you know, in my performance e 6 evaluation, regardless if I'm reprimanded or not. I mean, 7 that's -- The infamous E-Mail. )

8 MR DOCKERY: Yes. Which the only thing I want i i

9 to ask about it is my reading of this would indicate to me 10 that - - Well, let's clarify what it is.

11 THE WITNESS: Yeah.

12 MR. DOCKERY: It's titled To D. Fields from G.

13 Halnon, Subject, Journal 8/18 --

14 THE WITNESS: It should be 9/18.

15 MR. DOCKERY: It should -- Okay. Date 09-18-94.

16 Time 4:21 p.m. To star Journal. Now, I would t6ke that -

17 - Correct me if I'm wrong. But does that electronically 18 send it to the shift or the people under you?

19 THE WITNESS: It sends it to all of Operations.

20 MR. DOCKERY: Okay.

21 MR. WEINBERG So there may be 20 different 22 - copies of this printing'out to different people.

23 -THE WITNESS: Yeah.

. 24 MR. WEINBERG: I'm looking at one to --

25 THE WITNESS: To Connie 30uage_.

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1 MR WEINBERG: -- to Connie wee 5;r.-  !

2 MR.-DOCKERY: I dee.

3 MR. WEINBERG: So the same -- This is just a ,

4 journal --

5 MR. DOCKERY: I have Fieldr', a copy of the one 6 that was sent to Fields.

7 MR. WEINBERG: Right. It goes-to everybody.

8~ THE WITNESS: - So Dave printed that one out.

9 Connie' printed this one out. I probably have one in my i 10 book that says'to G. Halnon because I printed it out.  !

11 Part of the -- I'll explain. You want me to 12 explain the memo, why it's -- ,

13- MR. DOCKERY: Well, I may not want to go into as-

- . {

J 14 much detail as you do.

15 THE WITNESS: Okay. Jo ahead and ask your i 16 question ther..  ;

1*/ MR. DOCKERY: My reading of it is that as of 18 this date, the 18th of September, this wouldn't indicate 19 to me that it. anticipated very' drastic action against Mr.

20 Fields or Mr. Weiss.

21 THE WITNES'il Well, this was not the personal 22 memo to Dave or Rob.

23 - MR. DOCKERY:- I understand.

I 24 THE WITNESS: This was._a memo to all of operations. - And for me.to explain this a little, I'll get

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66 1 into the detail of why it seemingly shows it in not as 2 serious of a mode as what we took it that week before.

3 I'm seeing that's what we're leading up to, so I'll be --

4 I know. You're saying, go ahead, go ahead.

5 If you look at the operations department, we 6 changed leaders beginning of the year. We had an EOP 7 inspection that became -- found some significant issues.

8 We had an enforcement conference. We had a successful 9 outage that we all worked very hard in.

10 We had -- I had just-introduced the human 11 performance plan for improvement, which included some 12 teamwork issues and human performance tools, which we were 13 rwally starting to focus on human performance ab ut this 0

14 time frame.

15 We just had an INPO evaluation on the simulator 16 which was successful, that they came back and said we did 17 a fine job.

18 All these things added to improving Operations' 19 department. We were on the upswing. And this test 20 happened -- All the operators know immediately when one-21 sixth of their family, if you will, the crew -- this was 22 one crew out of six -- was being called on the carpet for 23 an issue that they did, that probably most of the 24 operators had a concern over, too, because they were 25 having to work under the same curve requirements.

,,., --- - - n

67 1 Whether they said it was okay to do that or not, 2 that's immaterial. The point is that this was a 3 tremendous black mark that made the morale of the 4 operations department go down very fast.

5 I still had to operate a nuclear power plant and 6 maintain safe operation, regardless of the external thir.gs 7 going on.

8 This memo was an effort to show these things, 9 that, hey, we've got some significant issues here, but 10 we've got, also, with it the things that happened that 11 were good, the questioning attitude, the not accepting 12 seemingly incomplete answers. We've done well. You know, 13 we've got to look at this, learn some lessons, and go on.

14 And this was trying to salvage that piece of 15 that. And it was to all the operations. It was an action 16 out of the manager;c.t review committee, I believe it was 17 the management review committee, either that or Bruce 18 asked me to go off and get something to all the shifts 19 showing -- telling them that -- You know, we wanted to 20 calm the rumor mill.

21 Okay. We had taken our disciplinary action 22 against Dave and Rob. We counseled them. We got 23 satisfactory acceptable answers and responses from them 24 during the counseling session. We allowed Dave to go back 25 on shift. And we wanted to put it behind us. We learned

68 1 -some things from it and we wanted to go on.- And that's --

2 MR. DOCKERY: Maybe to simplify, I personally 3 have~no problem with this memo. [

4 THE WITNESS: Oh, forget everything I said then. p 5 MR..DOCKERY: But if either of my colleagues do, 6 certainly we can explore it. .

7 THE WITNESS: Well,-that was a question that had  ;

8 been asked-to me from several people. And I know that 9 Dave,-he had this framed in his office because he was

- 10 looking-at-it, well, you know, if this is what you.

11 thought, then why rre we in trouble. Well, at the time 12 that's what we r*,ought.

13 MR. RAPP: Let me expand on t.as just a little

+  :

li bit. This thing came out 9/18.

15 THE WITNESS: So that was the Sunday after the 16 tvanagement review committee.

17 MR. RAPP Okay. And basically it says, you  ;

18 pursued an issue and you got it resolved and everything, 19 but your process may not have been the best approach.

20 When all of a sudden did Mr. Fields and Mr. Weiss 21 become -- their actions become more suspect or more 22 egregious?

23 MR. DOCKERY: Or-when did they fall-from grace?

24 THE. WITNESS: ' I think that the next, if you will, .

milestone was when Dave came off shift.

25 Rob was already i

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69 1 off shift on a pre-planned rotation to be the EOP 2 coordinator. So that -- He was already off shift. It was 3 not really an issue with Rob. <

4 There was another violation of tech specs caused S by Dave's shift in the time frame between this management 6 review committee and when he came off shift. It wasn't a 7 real significant one, but it showed another administrative 8 error. We were concerned about that.

9 Druce monitored the shift at the simulator and 10 felt, again, comfortable that they were operating the.

11 plant safely. They had good communication, good human 12 performance. Dave had good command and control. Rob was 13 a good assistant shift supervisor. So we continued to be 14 comfortable with them on shift, even though Rob was off 15 shift rotated out. But he still had an active license.

16 The arriouncement that the first -- that Jim Vorse 17 from OI was coming down the first time, I believe -- I 18 don't know if I'm correct in saying that. It was a couple 19 weeks. I think he gave us a couple weeks notice, maybe a 20 week's notice, something to that effect.

21 I had never been through an OI investigation 22 before. I heard about the one in 1985 and I heard that it 23 was stressful on people. You know, it puts us in the same 24 light as what we put Dave and Rob in when we took the 25 management review committee. So it's a highly stressful

L t

70 f 1 thing to know that you're going to come in and get [

2 questioned.

3 So Bruce -- he was -- had gone through the 1985  ;

4 OI investigation. He knew some aspects of it, even though  :

5 this has been nothing like they described Dack in 1985.

6 But he knew it was stressful on individuals.

7 So that, you know, he came and asked me, he said, ,

8 this is what could happen. Do you think it's okay for

. 9 Dave to continue to operate the plant and rotate shifts 10 when he's got to prepare for all this, you know, these -

11 questions. And he's certainly going to be one of the ,

12 focus of the investigations.

13 And I concurred. I said, yeah,-I don't think 14 -that would be a good thing. And so we told Dave that 15 because of the OI investigation and allowing him time to 16 prepare for it, that we were going to take him off shift v 17 and allow him to work on the administrative shift as a 18 supervisor, same title, same pay, and ask him to -- You 19 know, he was going to rotate off anyway at the end ot the 20 year as a planned rotation and we just accelerated it a 21 month. I covered his spot'with some overtime to allow him 22- time to-focus-on the OI investigation rather_'than 23- operating-the plant.

24 That's what happened. The_ schedule was changed

-25 and he was told he was off shift.

3 F

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71 1 Now, you'd have to be a shift supervisor to 2 understand that moving from a pocition of running the 3 nuclear power plant to a position of administrative 4 assistant sort of could be construed as a demotion, even 5 though it wasn't. He kept the same title. He kept the 6 same pay. He was even supervis i 49 people. So it was not 7 a demotion, although constre- t its, if you will, change 8 in resoonsibilities.

9 MR. WEINBERG: And I think what they were asking 10 you, maybe, is tracking after that all the -- you know, 11 what happened that led up to ultimately, from your 12 perspective -- but I think they asked you --

13 THE WITNESS: Oh, okay. Yeah, I guess I never 14 did answer your question, did I.

15 MR. DOCKERY: It's kind of broad based, but 16 eventually that'e what it's intended to get to --

17 THE WITNESS: Yeah.

18 MR. DOCKERY: -- the point at which the two of 19 them f ell f rom Grace.

20 THE WITNESS: Oh, I'm just going to continue to 21 work milestones. Sometimes when I -- Or significant in 22 my mind that things changed, perceptions changed.

23 MR. VORSE: C""ld I -- Before you get started on 24 that --

25 THE WITNESS: Sure.

e - -

yn- 5

  • i l

i f

72 1 MR. VORSE -- did you -- We come on down and' i

2 you removed, you know, them-from their license -- Well --  !

3 THE WITNESS: Removed them from shift. I didn't 4 restrict their license or anything.

5 MR. WEINBERG: Weisc was already off shift.

G MR. VORSEs- No. Weiss was already off shift.

7 Rob's -- [

S MR. WEINBERG: No, Fields was going-off shift in 9 a month, and-he can explain that. But he took him off on 10 December lat. ,

11 MR. VORSE: Did you -- Besides us coming down 12 anil C at it would be very adversarial, and et cetera, did 13 yo2 get ny feedback from the NRC's regional people being 14 upset Yaout this thing or making a big issue of it?

15 THE WITNESS: Well, we -- I think we knew, Jim,

  • that they -- that you were coming down ht their request, 16 17 and that it was their -- it was_their way of investigating 18 this certain incident.rather than just sending inspectors 19 down like they normally would do.

20 Beyond that, I don't recall. And we've had Ke.ref M 21 discussions with them, you know, throughout, -Terry Landis 22 and Ellis. Juud I don't know -- I've never personally 23 talked to.Stu,-but I know that he was being briefed.

24- And I -- We had heard that_it had gone real high 25 jinto the:NRC and that there was a high level of concern l

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73  ;

1 all the way up to the Commissioners or Jim Taylor, ,

2 whoever. You know, at a high level of management that 3 there was some concern there.- {

4 So; yeah. We knew that it was a hot issue, if i

5 you would, 6 MR. VORSE: Did Chernobyl ever -- Did that word ,

-7 Chernobyl ever come down to you?  :

8 THE WITNESS: Yeah. I mean, that -- ,

9 MR. VORSE: Did that come down from NRC to you?

.t

- 10 'THE WITNESS: Actually, that came from all over.

11- I.mean, there was people -- When you hear unauthorized 12 test, the first thing you think of is Chernobyl. So --

Would that be the first thing that  !

13 MR. DOCKERY:

14 you would think of?

15 THE WITNESS: I didn't think of that. I think .

16 Paul Fleming hit me with that first thing. But we didn't 17 look at that as being as significant as Chernobyl from a ,

18 technical standpoint. Maybe a standard standpoint where 19 you had a violation of procedures, which there was 20 probably a host of violations in procedures in Russia. I 21 don't know.

22 I didn't make the connection myself, no.

23 MR. VORSE: I'm sorry. I interrupted your train of thought and where you,were going to get started on --

25 THE WITNESS: Well, we-were talking about --

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74 I 1 MR.=VORSE: - - step by step how Mr. Fields and 2 Mr. Weiss, you know, ended up being terminated.  ;

3 THE WITNESS: Yeah. We were talking milestones. (

4 And I think the next thing that came up besides the-OI l 5 investigation was Pat Beard wrote a letter -- I_can't 6 remember which came first. I think Pat Beard wrote a f 7 letter to the Region discussing the incident and the -

8 disciplinary actions and what we felt about it. ,

9 And that was an effort to have open communication ,

10 with Stu and make sure that he, you know, realized what .

And we allowed Dave to read that before 11 our position was.

12 it went up because it had some statements about him in it, +

l 13 obviously.

14 And that was not a good meeting. Dave was very, e 15 very -- I don't want to say irate. But he was adversarial 16 about that letter going up, that he felt like it was not s

17 accurate and that the things that were in it were not what  ;

18 he felt. It was just a disagreement, ,

19 And then I believe --

20 MR. DOCKERY: Let me stop you. Keep the train

- 21 of thought, but I want to clarify something here. Was --

22 When you say he disagreed with the content of the letter,  :

23 was-he maintaining at that point that ha-had not conducted 24 a test or that what he had done was within his purview, or 25 what did he.take exception to?

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75 1 Tl!E WITNESS: Seemed like he took more exception 2 to the issues afte* the test than he did the test itself.

3 But I don't recall specifically what he was in 4 disagreement with as far as line items.

4 5 He -- I think he -- In it -- In that letter it 6 had some issues about his disciplinary action. And I 7 think he disagreed with some of those things that were in 8 there as far as being taken off shift. He looked at --

9 You know, they were actions we took. They weren't 10 necessarily all disciplinary, but they were actions we 11 took, 12 And I don't recall if this was in December or 13 January, or whenever. But there were some line items 14 about Dave himself. And I don't recall which pieces he 15 disagreed with. I just know he came away with a general 16 disagreement of the letter.

17 And I think that caused him to write another 18 letter himself. And I don't think I ever received or read 19 a copy of that letter. But I understand from other people 20 that that letter gave his view and kind of -- Maybe didn't 21 counter the letter. But again, I don't know what the 22 content -- I know some pieces of the letter, but I never 23 really read a copy -- you know, cover-to-cover a copy of 24 it.

25 MR. DOCKERY: The purpose of my question was to

76 1 see to the extent you know was he consistent in his 2 protestation from the time of the meeting you referred to 3 through the contents of his letter?

4 THE WITNESS: Well, since I'm not really sure of S the content of his letter, only the impressions -- I think 6- I got Pat's impr ,ssions and maybe Bruce's. I didn't 7 really read it myself. I'm not sure what he talked about.

8 MR. DOCKERY: But --

9 THE WITNESS: Whether he was coraistent, I dcn't 10 know.

11 MR. DOCKERY: You'd have no way of knowing that.

12 Go ahead with what you were discussing.

13 THE WITNESS: Well, I would say that meeting 14 with Pat was another milestone that gave Pat, you know, 15 another --

16 MR. WEINBERG: This is the meeting with Pat 17 Beard.

18 THE WITNESS: Right. When Pat was allowing Dave 19 to read the letter that Pat wrote. That was another 20 milestone in, if you will, Dave falling from grace, 21- because he was very adversarial during that and becoming 22 increasingly more adversarial in discussions with me, 23 although, you know, we usually had pretty civil 24 discussions about it.

25 The writing of his letter did not set well with

?

i 77 1- management. When I say management, I'm talking about the i 2 people, you know, Pat, Gary, Bruce, myself.- Not knowing  !

3 what-was-in the letter, I'm not sure why it didn't set 4 well. I just know that it probably countered what Pat 5 said.

6- And I don't know if that in itself had any major 7 - impact on our perception of Dave. But it -- We + tit like l 8 it showed another error in judgment. We don't know how it 9 was received by the NRC. You know, we can only assume 10 that they objectively looked at it like they do in Pat's 4 11 letter.

12 And I think it was just a ramp from there. You >

13 know, Dave seemed to get increasingly more closed in,

- 14 closed mouth about the whole issue, especially when -- the 15 more sessions he had with his lawyers and stuff. I think 16 he was getting some advice from them. It was becoming 17 more -- increasingly more difficult to talk to him about ,

18 the whole issue. Not that he was holding things back.

19 It's.just that -- You know, it's just discussions didn't ,

20 really turn out to be focusing on facts. It usually 21 . focused on performance, you know, performance evaluations 22- and him personally, and stuff like that.

23 MR. WEINBERG If I could -- Before you get to 24 the September 4th-issue, in going through this, Greg, .

- 25 you'vefgiven me -- and I don't know if you all got this or

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e 78 1 not -- a copy of a memo from Fields to you dated March 2 15th, '95, about your performance appraisal of him.

3 THE WITNESS: Correct.

4 MR. VORSE: We don't have that.

5 MR. WEINBERG: Okay. We will make you a copy of G it.

7 MR. RAPP: I don't recall seeing it.

8

~

MR. DOC '"Y : That answered the question I was 9 just about to raise, though.

10 MR. WEINBERG: Right.

11 MR. DOCKERY: And that was, who does his -- who 12 did Fields' performance evaluation.

13 MR. WEINBERG: .ir.d Greg can comment on that.

14 Did you do his evaluation?

15 THE WITNESS: I did the performance evaluation.

16 MR. WEINBERG: And was it a low -- Was it a --

17 considered to be a low evalua' ion?

18 THE WITNESS: It was! It 19 was -- We have five levels which start with marginal 20 performance, some standards achieved, consistently meets 21 standards, exceptional performance, and highest 22 performance.

23 People who normally do well in their job and --

14 or at least meet the standards get a middle-of-the-road a what we call CMS, consistently meets standards.

%1

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  • 19 8

2 3, , ,

4 , _

5 MR. WEINBERG: And I take it that that was 6 considered by him or anyone else in operations to be a --

7 that if he were in school, a S prade. '

~

8 ThE WITNESS: A yenh.

9 MR. VORSE: A $?

10 MR. WEINBERG: A $16 11 MR. VORSE: Did anyone --

12 THE WITNESS: Wait. Let me give you a little bit 13 more, you know, information. Anyone with a marginal 14 performance, which would be the lowest, would be 15 c nsideration -- you'd be asking the question, why is he 16 still working here.

17 So, you know, some standards achieved is given to ,

18 people who have some significant performance problems.

19 MR. VORSE: Did anyone tell you how to write 20 that up or how to grade it, or did you do that on your own 21 volition?

22 THE WITNESS: I had given -- Earlier, beginning 23 of the year sometime, I had given a blank performance 24 evaluation to all the shift supervisors to show the

/ 25 categories they'll be rated in. And it had six x

f

' l5

.5 80 1 . categories.- Some-of.them were in leadership. Some -- You

2. know,-they:were just general' categories with some.

3 expectations.

4 4 And*I graded each individual shift supervisor'and 5 anyone reporting to me under:those certain things. I  ;

'6 mean, Dave:got the same type of' evaluation the other' shift -

7 supervisors got.-

8 MR. VORSE:. But did anyone tell you to'--

9 THE WITNESS: No. I -- Nobody told me that -

10 MR. VORSE: -- grade it a certain way?

11 THE WITNESS:= Nobody told me to put certain 12_-things on there. Bruce, as my next level supervisor, 13 approved the evaluation or concurred with it. That's the 14 only'other level that gets it. It's a two-level 15 evaluation.

l 16 And I did discuss it with Bruce beforehand to

, 17 make sure he-realized ~that I was giving him that grade.

18 And Bruce thought it was appropriate, e-19 MR. VORSE: Did you de the evaluation of Weiss?

20 THE WITN2SS: No.

i ' 21 MR. VORSE: Who did that?

22 THE. WITNESS: Dave Fields did that because Dave

' 23 was the supervisor.- Dave gave'it to me and I recall 24 . sending it back saying, youLdidn't. mention anything 25;-negative - I'm saying negative -- you know, anything

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81 1 about the performance of the makeup tank. You need to put 2 something in there about that.

3 I may have been giving the key to the hen house 4 to the fox, but I was testing him a little bit to see 5 where he was at with it.

6 And he came back with some words and I concurred 7 with the words he put in there as his next level 8 supervisor, just as Bruce concurred with the words I put

~

9 in Dave's.

And the next thing that was under my control was

~

10 11 the amount of raise that each individual would get. So I 12 had -- The way it works is the supervisor does the

.3 evaluation and I figure out what the raise is.

14 MR. WEINBERG: Did you lower the evaluation of 15 Weiss from --

16 THE WITNESS : t 18 19 /'

20 21 MR. VORSE:

22 THE WITNESS:

23 24 MR. WEINBERG:

25 THE WITNESS:

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1 2 M 3 MR WEINBERG: Did Fields -- I'm sorry, But I 4 know the answer, so I can do it quicker.

5

'(

6 ,'

7 THE WITNESS:( $

8 MR. WEINBERG: Did he write you a memo about it?

9 THE WITNESS: Yes. He wrote me this memo. It 10 was after he reviewed it and had time to think about it, 11 and to put in writing his .houghts.

12 MR. WEINBERG: And did that create any problem?

13 I mean, was this some of the problems that you were 14 talking about that developed in 1995?

15 THE WITNESS: Well, you can -- At this point he 16 mailed me this. At this point I don't think he -- He 17 didn't talk to me in personal -- in person about this at l 18 all.

19 _

20 21

22 23 i

24 25 7

C 7 MM

I 83:  !

l' -MR. DOCKERY: After the event of September the 2 Sth or even previous.--

3- THE WITNES?: This was'1995 time-frame.

4 -Previously me_and Dave had a fairly good working  ;

5 . relationship.'

6 MR. WEINBERG: Let me take a -- I mean, you may 7 want to --

8 MR. DOCKERY: Let's go off the record.

9. (Whereupon, a recess was taken from 12:23 p.m. to 10 5:08 p.m., after which the following proceedings were 11 -had:)

12 MR DOCKERY: We're back on the record. The 13 time is approximately 5:08 p.m.

14 This is a continuation of this morning and early

. 15 afternoon's interview of Mr. Greg Halnon. Mr. Halnon had 16 personal business riat was necessary for him to attend to.

17 And he has returned.

d 18 And:I will remind you, Mr. Halnon, that you 19 continue to be under oath here today.

20 THE WITNESS: I understand.

21' MR. DOCKERY: When we quit earlier, we were f

. 22 discussing the -- your performance appraisal of Mr.

23 Fields. And I really only have one' question regarding 24 -that_that wasn't answered on the record.

- 25' MR. WEINBERG: -And if you need it, we'll give t

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84~

you a copy.of-it.- I-just don't have it'here, the actual -

2 appraisal itself. - If you wrnt that af terwards, we can get 3 you a copy of that. ,

4 Do you all.want --

5- FW. DOCKERY: Down the road, I think, it'would 6 be helpful to have that.

7 MR , HEINBERG: Okay.

8- MR. DOCKERY: Your -- The fact that you were the- -

Sf rating official on Mr. Fields' appraisal, that was in the 10 - ordinary course of things, right?

11 THE WITNESS. Correct. That was -- Right. The 12 direct supervisor does the personnel evaluation.

13 MR. DOCKERY: Curt, do you want to address the 14 ' technical questions that you have now?

15 .MR. RAPP: Sure. If you're finished with the 16 previous-question.

17 MR. WEINBERG: I think -- Yeah. I mean, I think 18 that in fairness we're sort of in the middle of his

- 19 question about what happened. And --

20 MR. DOCKERY: Oh, you want to --

21 MR. WEINBERG: As to Weiss and Fields. He 22 hadn't-gotten to explaining basically that it became an 23-_ issue of integrity in July of 1995. And if you want him 24 .to, he'can' explain why it was ultimately that Weiss and 25 -Fields were terminated.

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85'-

1~ 101. DOCKERY: -I forgot we were leading'up-to.

2 that. - You're exactly-right.

3 THE WITNESS: - Yeah. We were going through the 4 milestones of, in'your words, how did he fall out of S' grace.

6 MR. DOCKERY: That's -- You're exactly right.

7 Continue.

8 THE WITNESS: And I was talking how it was an  !

It was a building thing. Interactions 9- 'i terative process.

10 slowly de5raded from the professional performance during 11 the MRO to personal -- feeling of personal attacks.

12' We promoted an SRO, Garrett Hebb, out from under 13 -- he had been working for Dave. And I promoted Garrett 14 to a manager's spot that Dave would be reporting to. He 15 took that very personal like that was another slam. And 16 another discussion that didn't go very well.

17 I tried to do this the correct way and talk to 18 Dave beforehand before I made the official announcement i-19 that we were reorganizing and that Garrett was promote 20 going to be promoted to a higher position.

21 I sat down with Dave the day before the 22 . announcement, explained to him the reasons and why it was 23 done. Jmd it was another one of these meetings where he 3

24 got up and essentially stormed out of my office.

25 The next, if you will, milestone would be the D-g '

-try'- F *+--s -4g-,y 9 4 -y ase, +e  % ,- e

86 1- week of the scheduled enforcement conferences for the 2 operators where we found out about the__ test on the 4th.

3 Bruce had -- Well, Gerald Williams, the lawyer --

4 -corporate-lawyer at the time,~had mentioned at the end of L5 one of'the meetings that we were having to prepare for the 6 . enforcement conference, that he had heard from the 7 personal lawyers of the operators that they felt liPC this 8 could have been done the night before, also.

9 It struck us all by surprise. And the next day I 10 offered my help to Gerald if he needed it, and he said he 11 wanted to get back to the lawyers one more time, and that 12 he'd give me a call if he needed the help.

13 I took the next day off, so I wasn't there to 14 help him. But Bruce helped him and had called me in 15 Orlando. That's where I went. Took my family to Orlando.

16 Bruce called me and asked me to call Rob Weiss and ask him 17 the same question.

. 18 MR. DOCKERY: Identify Bruce for us.

19 THE WITNESS: Bruce Hickle. Okay. I'm sorry.

20 We're working with two Bruces here. I'll try to be more 12 1 ' consistent.

22 Bruce had told me on the phone that he had talked 23 to1 Dave Fields and Dave said, yes, that they had done it 224 .the night before. And so Bruce had asked me to call Rob 25 independently to get - .ask the same questions-that Bruce J

. - - - , , _ . . y c. , , _ . ,

~~

j 87 1 asked Dave and find out what Rob said.

2 I did that, called long distance from Orlando to 3 Rob. Rob gave me pretty much the same story that Dave 4 gave Bruce, that a test was done the day before and that E they hadn't disclosed that specifically earlier, hadn't 6 been asked, didn't seem significant, words like that.

7 So I called Bruce back and explained to him what 8 I heard. And then that's when Pat Beard kind of took over 9 from the standpoint of being personally involved. Pat was 10 trying to stay a step back, keep back as an independent 11 management person, you know, the ultimate authority. And 12 he got very much involved at this point.

13 And there was a lot of activity the next couple 14 three days. And, you know, I don't know how much people 15 have gone into as far as the details. But essentially it 16 was another emotional outcry from upper management, my 17 God, what are we going to do with these guys now, they've 18 disclosed some information that we didn't know, they 19 should have told us before, you know, what's going on 20 here.

' 21 There was some, you know, off the cuff, well, we 22 should discharge them. You know, then cooler heads 23 prevailed and said, no, we need to investigate it, we need 24 to make sure we do a good investigation. And that's when i% l e.,

25 Dan Peel and Jerry Carter came in as our independent V

i l

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. . - - . .. . . . . . ~ - . . . . . . . . . - . - - ~ . -

88  ;

1- internal stuff. Dave DeMontfort was on the team, Vic 2 _Hernandez.

3 And that's when all the information came out.

4- Then we waited, of course, for the final results of that 5- report. And they acted on that.

G So that was essentially the -- you know, the 7 downfall.

8 MR. VORSE: Let me ask you something, Mr.

9 Halnon..

10 THE WITNESS: Sure.

11 MR. VORSE: You sat through all our interviews.

12 THE WITNESS: Except for Mark's, right.

13 MR. VORSE: And you've had a lot of dialogue 14 with Mr. Fields and Mr. Weiss, I'm sure, subsequent to the 15 Sth of September incident.

16 Do you feel that they purposely did not tell you 17 about the 4th for some -- whatever reason?

18 THE WITNESS: I think it got to that point. Yes.

19' I think there was-a point when, in my opinion, there was a 20 conscious decision on their part not to bring focus back 21 onto the 4th because they felt like it would just 22 complicate the whole matter.

23 And whether they did not recognize the 24 significance of'doing it twice or-they didn't feel like it

25. was -- You know, that they did it, so they did it, so, you J

. - .- ~ ,, . , . . ~ , - . -

89 ll know, they're in trouble for doing it, whether they did it-2 twice, once, a hundred times,.they did it,Lthat type of 3' thing. I don't know what their justification was.

4 But that week that I called Rob and find out --

5 asked him about it and asked him pointed, and he gave me 6 very pointed specific answers to the questions I gave --

7 asked him, I felt like, yeah, there-was a reason they 8 didn't tell me.

9 And whether they justified it in their own minds 10 like they had done the test in the first place, that it 11 was okay now to do that or not, I don't know.

12 MR. VORSE: Do you -- Did this cause you to 13 doubt the integrity of these individuals?

14 Tile WITNESS: Up until that point I had -- I 15 didn't really doubt the integrity as far as did I know 16 everything about what happened.

17 And after that point, yes, ! felt like there were 18 some things that I did not know that I should have and-19 that they had opportunities to tell me and should have_and 20 knew they should have.

21 So I did have some doubt in their integrity after 22 that wondering'if I had the full story even then.

23 MR. VORSE: Knowing what you know now, would you 24 want them ever back on your shift or under your 25 supervision?

wr y--- , + = - -

i 90 r 1- THE WITNESS: No. Not that -- Not operating a

2. . nuclear power plant, no.

3- MR. VORSE: Why is that?

1 4 THE WITNESS: I-have to go home at night just 5 ~ like you have to go home at night. Rest assured that this  :

6 potentially dangerous beast is in the hands of people that 7 you can trust, that will follow the rules, follow the 8 procedures, and notify you off-site it there's a problem 9- with it.

10 And I don't have that assurance with those.

11 Knowing that they had done this once, I don't.

12- MR. RAPP: You said that there were certain 13 responses that. Rob Weiss gave you that made -- that led 14 you to this conclusion.

15 What responses were there? What were his 16 responses?

17- THE WITNESS: The first question I asked him is 18 what I -- I asked him if the test was performed the night 19 before. And he said the evolution that they did was 20 performed the night before.

21 The next question led to, was it done in the.same

. 22 manner. - And I'added the caveat, the same contingencies, 23- the-came pre-job briefings, and the same precautions that c 24. you talked about-that you-took on the 5th. And he said

. yes.

i e < ,,s , , - - - . _ , - - - - .., m-

91 1 He said the only difference was, if I recall his 2 statement, was that the data was scattered, it wandered 3 around, and it didn't -- wasn't like they thought they 4 should get. And so they went back and -- and this was Rob S talking, he said they went back and thought about it and 6 they -- and I'm thinking they is the Mark Van Sicklen --

, and convinced him that the temperatures needed to 8 stabilize after the hydrogen add and they lad to come back 9 and do it again. And they waited that period of time. In 10 other words, they modified their test the next night to 11 come in and do 2c.

12 MR. RAPP: When did Mark Van Sicklen come up --

13. As far as you understand, when did he come up with this 14 idea that the temperatures needed to be allowed to 15 stabilize?

16 THE WITNESS: I don't know. I can only assume 17 it's between the two tests because one test they didn't --

18 the 4th they said they didn't let it stabilize and the 5th 19 they said they did. So --

20 MR. RAPP: Well, it becomes kind of important in 21 the fact that the operators contend that both of these 22 tests were spontaneous, that they didn't contrive somehow 23 to run two tests.

24 And so the question becomes, if they discussed 25 this temperature stabilization issue immediately after the

92 1 4th, the testLof the 4th and got back= data and;said; well,- ,

2 -we'll have:to do{thisfagain on-the^5th,_that-brings - - -

f 3 that' kind of overrules or overrides the issue about the

-4 operators being spontaneous with this thing. o 5 If they~ waited until the evening of the 5th to 6 discuss;it, then the spontaneity issue becomes kind of 7- relevant.

8 THE WITNESS: I can't deny or substantiate when-S' - they would have done it.- 1-can say that on a shift it

10 -would be relatively difficult;to do two complete _

. 11 evolutions like this on one shift because of the impact to i'

12 the reactor physics. You're putting a lot of different 13 borated water or non-borated water. It's either demin --

14 You're changing.the wrong concentration and you have to 15 let the reactor equalize out with your rods _and what not.

On-ndkd 16 We run er. red'cd here~at the plant. So our --

N so unless they put on

17 The chem material is totally boron, 18 -_

the -- put in the exact same boron add.in the makeup tank 19 to fill it up all the way and then they-bleed it all the 20 way down, they've got to bring it back up to a reasonable 2:L - level, unless'they have the-exact same boron concentration 22 of water, then they're changing the reactor physics around 23 a little bit.

24- And it's not unusual -to- do that . They do feeds

- 25 and bleeds-all the time to-change reactor physics. But t

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w --

93 1 you've got to let it equalize. It takes -- From an add to 2 the makeup tank it takes 30 or 40 minutes to see that 3 effect. -And then the effect is quite a while.

4 So it would be tough to be able to do this twice 5 without overlapping onto another shift. And so, you know, 6 that kind of says, well, you know, they could have come in 7 the night -- the next night and decided to let it 8 equalize, or they could have decided, why did we get this 9 data scatter, and like i-hat.

10 You know, from an engineering standpoint, putting 11 myself in their position, if I did an evolution and 12 expected to see certain data and didn't get it, I wouldn't 13 let it rest until the next night. I'd be thinking about 14 it, immediately trying to find out why it didn't do that.

15 MR. RAPP: Well, it's not --

16 THE WITNESS: But that's just me personally, 17 but --

18 MR. RAPP: Well, that's not to say that Mark Van 19 Sicklen or somebody wasn't thinking about that. It's just 20 that it warn't --

21 THE WITNESS: Right.

22 MR. RAPP: -- discussed or put forward to any 23 other members of his group.

24 THE WITNESS: Yeah. And I say Mark. You know, 25 he's just one of the many that -- It could have been the

94

-1 whole; shift. It could have been just him. It could have 2 been just somebody else.

3 MR. STENGER ~ How about-another way to ask that 4 question. Would they have seen the data scatter at the 5 time of performing the test on the 4th?

6 TLE WITNESS: They were plotting it as they went.

7' I understand. I don't -- Either that or they got it 8 immediately off the REDAS, which is our flight recorder, 9 if you will.

10 Yeah. The data reduction should not have taken 11 very long. I mean, we saw that with the July 2end graphs 12 of, you know, where they plotted it by hand as they went 13 down. So that was an immediate feedback. -

14 MR. WEINBERG: Did you ask Rob at that time, 15 Weiss, why he had not given you the data that they plotted 16 from the 4th back in September of 1994?

17 THE WITNESS: I didn't ask them that. I asked

18 him why he hadn't told us about the 4th.

4 19 MR. WEINBERG: And what did he say?

20 THE WITNESS: Or-I asked him also why he didn't or y 21 tell a-44e about the 4th, because I sat in his deposition, 22 also. And he stated something to the effect of, well, ho

'23 one, they didn't ask and, two, they'ge' didn't feel like it 12 4 was'significant since the focus was on the data on the 5th 25 and that's what-we were focusing on.

I i

- - - , - - ~~ ,. - - ,

95 1 And, you know, I don't remember anything else he 2 said, but that was the two things that came.to my mind.

3 MR. VOkSE: Has it been established that there 4 was, in fact, no one stationed down in the Aux Building 5 with anti C gear on the evolution on the 4th of September, 6 '94?

7 THE WITNESS: I understand from discussions that 8 the Aux Building operator was not stationed, that he was 9 notified that there was something going on, that they may 10 be telling him to go vent the makeup tank. I understand 11 he -- And I know this third or fourth-hand, that he did 12 not have a pre-job briefing in the control room.

13 MR. WEINBERG: And there was no -- What's his 14 name. Atkinson was not on duty that night, so there 15 wasn't that extra operator that they could have or did 16 send down.

17 MR. RAPP: Oh, extra licensed operator.

18 MR. WEINBERG: Extra licensed operator.

19 MR. RAPP: Just as a kind of follow-on to that, 20 is it routine or normal during a hydrogen add to have the 21 control room call down to the Aux Building operator and 22 say, we may be calling you to vent the makeup tank?

23 THE WITNESS: I think that would be the normal 24 thing that they would do if they were doing a feed on the 25 system, thinking that -- anticipating that the systems guy

96' 1 wouldn't be involved in something at a certain time, that

'2 he wouldn't_be able:to go bleed"the pressure off..

3 MR'. RAPP:- So-it's not --

4 THE WITNESS: It's not---

5 MR..RAPP: It's not routine to have'someone  ;

6 dress out and stand by the --

7_ THE WITNESS: Well, not at that time-it wasn't, 8- no.

9 MR. RAPP: All right. Okay. Well,- can it --

10 One other thing, too. This was brought up earlier.

11 Can the makeup tank vent valve be operated from

'12 the control room?

13 THE WITNESS: I believe we keep it' isolated.

14 There is a vent valve up there, but we keep it isolated 115 for Appendix R concern.

16 MR. RAPP: Okay. So someone has --

V

- 17 THE WITNESS: So we have to do it manually. You 18 .have to go and open a manual valve. then you can vent it-i 19 from the-control room.

20 MR. RAPP: Okay. Thank you. Moving on then,-I 21 guess,-when did -- There are some statements that_ Mark Van 22- Sicklen:made that-he had talked to you about other

- 23 evolutionsibefore this whole thing came out and-prior to 24 the, what, July '95, whatever.

25 THE WITNESS: Yes.

2

.._y ., -

97 1 MR. RAPP: What further action 1did you_take on l

those stat'ements-by Mr. Van Sicklen?--

~

2-l' 3 THE' WITNESS Well; it took a while for me to get 4 enough information out of Mark to be able to do any 5 reasonable investigation-into that. It started off of, 6 and besides, other shifts have done this. And, you know, 7 okay, what can you give me.

8 And, you know, initially he balked at it and 9 said, hey, I don't want to get everybody else in trouble, 10 you know, let's get this worked out with this evolution 11 and the standards will be set, and blah, blah, blah.

12 And, you know, Mark was the Union steward, so we -

13 had conversations pretty much every day. 1.nd most of our-14 conversations would contain some element of the makeup 15 tank. You know, a lot of other things, Union issues, 16 grievances, stuff like that.

17 So it came up several times over a period of a 18 sn.all time frame. And I pressed him. You know, I need --

19 if you want me to look into it, I need to get -- you need 20 to be more specific. I said, you mentioned it twice, 21 three times, tell me more about it.

- Because, you know, it 22 would be like shooting in the dark for me to spend my time 23 and go back in the logs and try to find one evolution in 24 ten years.

25 But he finally gave me a date to look at, which n

98 1 was the late July time frame. And I went back and looked 2 at that. I looked at the -- took out the shift 3 supervisor's log and looked a couple weeks before that 4 date and a couple weeks after-that date and that week.

5 And there was some makeup tenk evolutions, which included 6 a large feed and a large bleed with hydrogen addition.

7 And it happened three or four times that week.

8 And then -- So I looked into that to find out 9 why. I looked at the logs. And it was very clearly 10 logged in the shift supervisor's log book that those 11 evolutions were for the purpose of bringing the cc's per 12 kg of hydrogen in the RCS up to a new equilibritm.

13 Hence, those were authorized evolutions for the 14 purpose of operating a nuclear power plant. And those 15 bleeds and feeds were within procedure. The information 16 that was logged was on the acceptable side of the curve.

17 They -- You know,.it was obvious that they took data 18 during the bleeds and feeds because the shift supervisor 19 log had we were at this pressure in this level and we bled 20 down to this pressure in this level, and here's the new 21 cc's per kg. And the'next day cc's per kg is here, we 22 need to do it again. And it's very clearly logged.

23 And those were the evolutions that he was 24 referring to. Then I explained to him they were 25 authorized. I made comments to the lawyers, I think,

1 99

1 during'one of these 01 - I mean, the investigative;- .Not 2 : investigative. I'm getting my people mixed up now. =No

-3 offense.

4 During the enforcement conference prep meetings 5 that we wereihaving I made mention that -- because they 6 : mentioned it I made mention that the -- you know,-there 7 was some talk about these evolutions being done in the.

8 past. They' asked me to provide a little memo to Pat _on-9 what-I found. I gave that to him, basically what I just 10 told yeu, was that I found authorized evolutions. Sure, 11 they.took data, but that's okay. That 's prudent . - That's 12 good operations, taking data.

13 If they didn't take data, we may have-had-to do 14- it six or seven more times because we didn't have a good 15 trend of what we were doing. And that's what I found.

16 MR. RAPP: When this issue of additional test 17 first came up, did you contact anybody above you like  ;

18 Bruce- Hickle or Gary Boldt and say - that, hey,-we've got 4

19 this potential here for other tests?

20 THE WITNESS: There were some concerns about 21 evolutions in the plant that had been done in the many '

22 past years, whether they were similar to doing things 23- without a procedure and taking data. You know, a lot of 24 things were_-- Anything_that somebody-did to take data

~25 came into question because_ suddenly they connected doing O __ _ _ , _ -.-_--__.____u_u__.-

100 1 something-in a plant, taking data with unauthorized tests.

2 And, you know, I can't deny that there probably

-3 hasn't been some things in the past may have hinged on the 4 fringes.

5 MR. WEINBERG: But what he asked you was -- The 6 specific question is --

7 THE WITNESS: The makeup tank issue?

8 MR. WEINBERG: No. The specific question was, 9 when Van Sicklen raised this issue with you as to other 10 possible evolutions, as you were looking into that did you 11 discuss that question with Bruce Hickle or anybody else in 12 management?

13 THE WITNESS: Yeah. Well, that's what I was 14 getting to. Yeah. They -- Bruce and Gary and Pat were i

15 aware of these types of, you know, things in the past that 16 may have occurred.

17 And Pat asked me to look into them. And from the 18 standpoint of who did them and whatnot, you know, back in

( 19 1985, it would be kind of difficult. The standards have 20 changed. The procedures have changed.

21 But in particular there's one person I talked to.

- !2 And the procedures were not violated, but, you know, you 23 might question nowadays if that was a real prudent thing 24 to do without a procedure.

25 MR. RAPP: Let me refocus the question then.

2 4

101 1 When this -- Mark Van Sicklen brought this up about other 2 makeup tank evolutions, did you contact Bruce Hickle or 3 Gary Boldt or Pat Beard and say, there may be other makeup 4 . tank evolutions that are out there thac we need to look 5 at?

6 THE WITNESS: I don't recall specifically going 7 after and telling him about that. I think it was -- I was 8 keeping the discussion between me and Mark until I got 9 more information. And then when I found them authorized, 10 I didn't let it drop from the standpoint of my knowledge, 11 but I didn't see any purpose in pursuing it further until 12 I brought up the comment.

13 And this was all during that time frame. I 14 brought up the comment during the enforcement conference 15 prep meeting. And so that would be the first time I may 16 have put it on the table. But I'd also said I had already 27 looked into it.

18 MR. WEINBERG: Could I ask one question while 19 you're doing that?

20 MR. DOCKERY: Sure.

21 MR. WEINBERG: You had mentioned something about 22 when you went to pursue the July evolution that Van 23 Sicklen told you about, you-had mentioned that you looked 24 at the shift supervisor log and that the bleed and feed 25 was recorded in that log.

102 1 THE WITNESS: Yeah. The supervisor's.

2 MR. WEINBERG: You've also looked now at the 3 shift supervisor log that was maintained by Dave Fields 4 with regard to September 4th and September 5th?

5 THE WITNESS: Correct.

6 MR. WEINBERG: Did Dave Fields record the 7 evolution that he did in that log?

8 THE WITNESS: Ns, he did not.

9 MR. WEINBERG: Should he have?

10 THE WITNESS: In the -- There's two things here.

11 A normal bleed and feed of the RCS would not nonnally be 12 logged in the shift supervisor log book.

13 MR. WEINBERG: Oh, but it was in the July one.

14 THE WITNESS: It was because it was a special 15 evolution and for the purpose of bringing cc's per kg up.

16 And the shifter felt at that time it was prudent to log it 17 and I agreed with that. And I think that -- I think most 18 shifters would have done that, because it was a special 19 evolution.

20 And special evolutions on shift are typically 21 logged as a narrative in the shift supervisor's logbook.

22 If, in fact, the test was being done on the 4th 23 and 5th and it was for the purpose of validating the 24 curve, I would expect that to be logged in the shift 25 supervisor logbook, especially if it caused a problem I

1

. __--___-______-.-_______---_--_____-___-_-_-__-_-____--_m

. _ ~ _ _ . - _ _ _ _ __ ._ _ . . _ _ _ _ . _ _ _ _ _ . . _ _ _ _ , _ _ _ _

103 1 report.to be written, which are logged in the shift supervisor's logbook.

~

2 So it met the'same -- if you will, 3 the same threshold of importance.

4 MR. WEINBERG: Do you know why he didn't put it 5 in the logbook?

6 THE WITNESS: No, I do not.

7 MR, WEINBERG: Did you ever ask him?

8 THE WITNESS: No, I did not. I don't recall 9 asking that question.

10 MR. WEINBERG: You know-what I'm talking about.

11 THE WITNESS: Yeah.

12 MR. RAPP: During some earlier discussions, 13 interviews, whatever, people have told us that the 25 cc's 14 per kg.was being pushed pretty hard.

15 Would that be an accurate statement?

.16 THE WITNESS: I would say yeah. Yeah. I would 17 say it's fairly accurate. The way it was being pushed was 18 we have a morning meeting at which time management, 19 myself, Bruce Hickle, Pat Beard when he'~s on site, Gary 20 Boldt, the other managers that were in the' plant, looked 21- at our plan of the day. And it has on there the value of 22 cc's per kg hydrogen.

23 And when it tended to get a little bit low, then-24 comments'were made such that, you know, we would be asked 25 to increase it. And it it stayed low, then those comments

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1104 1 would get a little bit more terse _and a little bit more 2- demanding, and hence,-resulted in the perception that,-you 3 know, because it was being_ brought up at this meeting ,

4 every day that it's a high visibility issue that needed to 5 get resolved from the standpoint of getting cc's per kg 6 . up .

~7 So pushing pretty hard? I'd say_it goes through 8- waves. But-I think that those waves were there sometimes 9 when it was a high priority for the day.

10 MR. DOCKERY: Mr. Halnon, in that same regard, 11 -were there certain shifts that were ro'utinely noted as 12 being beneath the desired cc's per kilogram figure? ,

13 THE WITNESS: I think -- I don't think there's 14 any one shift that you could point-out. I think at times-15 the perception was that when Dave Fields' shift came on, 16 you could see it turn down a little bit because, you know, 17 they were c little bit less comfortable with it and they 18 would let pressure come down.

19 But it also -- You would see other shifts 20- happening -- If there was.some significant evolutions 21 going on in the control room at the time, say a diesel 22 test or a different surveillance procedure, an'ES testing, 23- they might give themselves some more margin because I know 24 -they wouldn't-be able to keep the same. level of attention 25 on it as they would_because there's another evolution

105 1 going on.

2' - So I don't know if you could say that there was 3 one or two shifts that didn't do a -- didn't keep it up as 4 high. But -- Bccause it was variable. Certain things 5 would be going on and, you know, if the plant -- if you 6 had to deurease power in the plant, that would do it.

7 So I don't think it was really shift specific. I 8 think sometimes the perception was, but --

9 MR. RAPP: Was Chemistry pushing this issue 10 pretty hard?

11 THE WITNESS: Chemistry was working with us.

12 They would do the sampling and they would let us know if 13 it was getting low. And they would show us the trends.

14 And they would be doing the purity testing and they would 15 recommend vent and fill the tank with new hydrogen if the 16 purity was getting low, They had their limits that they 17 were looking at. So they were in a support role.

18 MR. RAPP: But -- Well, okay. Let me ask it 19 this way. Was this raising to the 25 cc's per kg done at 20 chemistry's request, that chemistry came up and said, 21 we've got a significant plant problem here that can only 22 be solved by going to 25 cc's per kg?

23 THE WITNESS: No. I think the feeling was that 24 we really didn't have the major oxygen carryover problem 25 and a corrosion problem and an oxygen problem in the RCS, ,

- ..__ - ..~.- .. -- - . . _ - . . . - . . . . - - , - . _ . - . - .

106 .

1 and'that-the higher levels of hydrogen, although gave us-2 more margin and were good, maybe weren't technically.

3 necessary at CR-3. But we didn't have good justification

4. not to.

5 MR.'RAPP: Are you aware of what the basis for 6 this 25 cc's per kg came-from?

7 THE WITNESS - My understanding may be a little 8 bit cursory, but I understand it's to control oxygen in-9 the RCS, which in turn controls corrosion, which in turn 10 . controls the radiation level throughout the plant because 11 -of the corrode release.

12 MR. RAPP: Would it surprise you if I told you 13 that the basis for the 25 cc's per kg came from an EPRI

.a.

+ 14 study of stress corrosion cracking in reverse U hend 15 material?

16 THE WITNESS: No, it wouldn't surprise me.

17 MR. RAPP: Would that be applicable to Crystal 18 River?

19- THE WITNESS: Define what you meant by U bend.

20 I mean, we have stress corrosion and cracking issues at 21 CR-3, yes.

22 MR. :RAPP : Do you have reverse U bend material?

23 THE WITNESS: I don't know what reverse U bend

^

--24 material;'is.

25 MR..RAPP: Well --

l l

107 1 THE WITNESS: I'm not ,a materials engineer.

2 MR. RAPP: Okay. I ' n. sorry. Material that's 3 shaped in the form of the reverse U bend. Like in ,

4 Westinghouse steam generators.

5 THE WITN8SS: I'm B&W grown here. Do we have 6 bent material in the plant?

7 MR. RAPP Right.

8 THE WITNESS: Sure. And we have rolled material 9 in the plant, sure, in our OTSG's, the rolled tubes.

10 MR. RAPP: But your steam geqerators do not 11 have --

'2

. THE WITNESS: We don't have --

13 MR. RAPP: -- Westinghouse type U bends?

14 THE WITNESS: No. We do not have the U bend 15 steam generators.

16 MR. RAPP: So then basically we've gotten down 17 here to a technical issue that says we don't have an 28 oxygen problem, okay, corrosion problem. The basis for 19 the 25 cc's per kg apparently is not applicable to Crystal 20 River. Okay.

21 So why all of a sudden now does this 25 cc's per 22 kg become a driving factor? Why all --

23 MR. STENGER: Curt, with all due respect, you're 24 leaping to some conclusions there. I'm not sure there's 25 any kind of study or technical basis that concluded this p ,,ar. - . _ . . - . , - . .. .,

- - -- . . - _ ~ - . - . - - . - - - - . _ _ _ _ - -

108 1 was not a problem at CR-3, 2 THE WITNESS: That -- Yeah, I'm not sure.

3 You're getting beyond me from the standpoint of the 4 chemistry area.

5 I'm not sure what the U bend -- reverse U bend 6 study said and how that -- There may be some applicability 7 to CR-3 in different materials and/or different 8 configurations that could be surmised from that. I don't 9 know if EPRI took that study and translated it into a 10 generic water chemistry guideline that we were following.

11 So, you know, you're getting beyond me on why 12 from a chemistry and engineering standpoint we wanted 25 13 cc's per kg. I don't know the exact reason for that.

14 MR. RAPP: Were you ever present when these type 15 of technical issues with the 25 cc's per kg, achieving 16 that goal was discussed?

17 THE WITNESS: Early on, I believe, when I was a 18 systems engineering manager, I think I -- when we were 19 doing the INPO report critiques for Pat Beard, I believe 20 Stu Robinson was -- had discussed that with Pat. Stu was 21 our chemistry manager at the time. And Stu's an engineer, 22 also.

23 I don't ticall much more than the fact that the 24 discussions took place and that Stu was resistant in 25 saying we don't need to go there, we don't have an oxygen y , ---+--#- p,m--- - , .

1 b

109 l I problem. l 2 The same thing happened with zeolite in the RCS. ,

3 As far as that kind of chemistry-control, you know, Stu j i

4 was saying we don't have a problem, let's not worry A?out  !

.. t 5 it. But I don't know --

6 MR. WEINBERG: Stu who? What's his name? l 1

7 THE WITNESS: Stu Robinson.-  !

1 i

8 MR. WEINBERG: All right.

9 THE WITNESS: I don't know what transpired in the ,

10 EPRI guidelines. And from what I remember, all I was ,

11 tasked with doing was meeting =the EPRI guidelines.

12~ MR. RAPP During these discussions then to go l 13 to this upper limit, correct me if I'm wrong, but it seems '

-14 that someone had expressed that it wasn't necessary to do 15 this.

16 MR, WEINBERG: That's what he just said.

17' MR. RAPP Okay. All right. I just wanted to ,

18 make sure I was right about that.

19 MR. WEINBERG He just said that --

20 MR. RAPP: Okay. .

21 MR. WEINBERG: -- this guy Stu Robinson 22L indicated that he didn't think there was an oxygen 23 problem.

-24 MR. RAPP: . Problem. Okay. How was that 25 - - received?- How was that descending opinion received?

. _ . . _ _. - . . - , - _ . _ . - _ _ _ _ . _ . _ . . . . _ . _ . _ . . . _ . . . . _ . - _ __...___---.-_...______._._J

I 110 1 THE WITNESS: I don't recall in this one. We're 2 talking back in the early '90's, I think that we're l 3 talking now. And I'm not sure what transpired between 4 when the comment was first made to -- And I don't even 5 remember which year's INPO report it was in. I don't know 6 how it transpired.

7 And I never saw the EPRI document that imposed it 8 that was what we were being asked to follow. So, you 9 know, I guess I made the assumption that it was applicable 10 to CR-3 and the Chemist ry department was tasked with 11 ensuring that the cc's per kg are at 25, in turn, you 12 know, came over to operations to maintain pressure in the 13 makeup tank.

14 MR. WEINBERG: Well, was this INPO report a 15 report that was done that pointed out that at Crystal 16 River, among other things, that you all weren't 17 maintaining the 25 cc's?

od lice 18 THE WITNESS: We were an oubiow.g f 19 MR. WEINBERG: That you were a what?

ouHWAd We were an outlew in the indust ry.

20 THE WITNESS:

21 We hadn't -- We had a B&W water chemistry manual which 22 imposed a 15 cc's per kg and the industry -- most of che 23 industry had gone to the 25, why not you.

24 MR. WEINBERG: So the recommendation was from 25 INPO that you do it?

111 1 7 4E WITNESS: I don't know the specific  !

1 2 recommendation. I believe it led us to that point, yes.

3 And those INPO recommendations get a very high level of 4 management reviec you know, up to Pat Beard. So --

4 5 MR. STENGER: Are you familiar with the INPO 6 recommendations at the time?

7- THE WITNESS: I believe it came in the Chemistry 8= area. And we typically take the INPO recommendations into 9 our respective areas that they look at. And so I guess 10 the answer to the question is, no, I'm not familiar with 11 the wording of that. I've probably read it at one time, 12 but I can't say that I'm familiar with what it says right 13 now.

14 MR. RAPP: Some of the discussions have said 15 that from the working level that they tried to bring 16 forward the technical engineering challenges in achieving 17 this 25 cc's per kg, and that basically it came back down 18 to them that this is what Pat Beard wants, you give it to 19 him, I don't want to hear any more comments or questions 20 about this.

21 Is that generally consistent with the directions

- 22 you-were receiving?

' 23- THE WITNESS: I would-say that, yes, it was what V But I don't think that there was ever

, = 24' Pat Beard desirek.

25 a closed door to hearing discussion about, you know, L-

. 12 1 difficulty with it.

2 Matter of fact, I know one document I saw 3 somewhere in Pat Beard's staff meeting minutes that he 4 entertained a meeting of the engineers to talk about the 5 hydrogen issue. And this was early in '94, I think. So 6 Pat was aware of the problems and knew -- and sort of in 7 the same way I was, was making sure that it was getting a worked on.

9 But in the meantime it was achievable to maintain 10 25 cc's per kg, so his expectation was that we achieved it 11 and maintained it. And that, you know, from my feeling, 12 that's the way I felt about it, that the expectation was 13 there and that we were tasked with going out and 14 mainte.ining 25 cc's to the best of our ability.

15 MR. RAPP: Were there any -- Evidently there are 16 senior management meetings where all the department heads 17 or managers get together and discuss the ungoing 18 activities or ongoing issues that are significant to their 19 particular areas.

20 Was there any kind of meetings where these 21 operator concerns were discussed, Curve 8 and the high 22 hydrogen pressure?

23 YllE WITNESS: I believe that the meetings in the 24 morning when ec's por kg hydrogen was brought up, I 25 believe that the concerns were raised at least once. I

113 1 mean, they may not have baen over and over raised because 2 I think everyone was aware of some of the -- most of the 3 issues. ,

4 If there was any specific meeting, I don't 5 recall.

6 MR. RAPP: Was there any kind of meeting where 7 Gary Boldt or Pat Beard may have been in attendance where 8 this 25 cc's per kg and the operator concerns were brought 9 forward that you know of?

10 THE WITNESS: I know that there was a 11 presentation at one of Pa;'s staff meetings early in '94.

12 I'm not sure -- I didn't typically go to Pat's staff 13 meetings, so I'm not sure what the content was of that 14 staff meeting and what the presentation was.

15 MR. RAPP: And who would have gone to that staff 16 meeting?

17 THE WITNESS: Well, it's the director .nd --

18 which was my director, Bruce Hickle. And, you know, it 19 was only if he was there during the day. But Pat -- It's 20 Pat Beard's staff, which was the directors, Gary Boldt, 21 and Pat.

22 MR. RAPP: There was a memo that I've seen --

23 and I don't have a copy of it with me, unfortunately, but 24 it was either written to or by Dave Jones, who you told me 25 earlier worked for you at some point.

114 1 Basically, this memo goes into some assignment of 2 responsibilities for resolving these operator concerns to 3 Ernie Gallion.

4 Do you recall this E-Mail, this memo that --

5 THE WITNESS: No. I don't recall that. I do 6 bave -- Let's see if I have the E-Mail from Dave --

7 MR. WEINBERG: About which issue?

8 MP. RAPP: Curve 8. The operators' concerns 9 with Curve 8. I believe it was a speed letter. It's not 10 an interplant memo.

11 MR. WEINBERG: Well, do you think it's this one?

12 THE WITNESS: No. That's not it.

13 MR. RAPP: No. Huh-uh. That's not it.

14 THE WITNESS: I know which one I'm looking for.

15 I may or may not have it. I recall a memo from Dave 16 Jones, an E-Mail discussing a meeting and/or -- you know, 17 yc. guys need to get together and talk about this.

18 I think -- Is that the same one you might be 19 thinking of? I don't know. I don't remember the 20 specifics of it.

21 MR. DOCKERY: There's a July 19th, 1994, meeting 22 set up by Dave Jones, attended by Mr. Van Sicklen, Mr.

23 Willms, Mr. Hinman, Carl Bergstrom, and Steve Roe.

24 MR. WEINBERG: That's the one that Carl 25 Bergstrom testified about today.

115 1 MR. DOCKERY: Is chat --

2 MR. RAPP: That -- This E-Mail probably would 3 have been earlier than that because it made some 4 assignments to Ernie Gallion, who was, I think, over in 5 the operations engineering area at that time.

6 MR. WEINBERG: And we had some -- That's the 7 meeting that -- The one you just referred to that 8 Bergstrom found the reference to in his log today.

9 THE WITNESS: I'm not sure if I have that or not, 10 Curt.

11 MR. RAPP: Okay.

12 THE WITNESS: I think I know which one you're 13 talking about. Dave was working for me, you know, as 14 another -- Here it is right here. No. I'm sorry.

15 That's from Terry Austin. That's a different -- It's too 16 Dave Jones. Here's one on July 18th. It says, to Pat 17 from Dave, a meeting scheduled 7/19, across from the 18 control room to allow operations, Bruce Willms, Mark Van 19 Sicklen, Steve Roe and Engineering Pat Hinman, Terry 20 Austin to review problem report 94-149, corrective action 21 plan concerning remaining concerns on the makeup tank.

22 MR. WEINBERG: Is that what you're talking 23 about?

24 MR. RAPP: No. It's --

25 MR. WEINBERG: I.think what you're talking about

l 116  !

1 is this one right here, the 5/14/94 letter. i 2 THE WITNESS: Oh, okay. I don't know if I have 3 that one. I was -- Sometimes I was copied on these things 4 and sometimes I wasn't.

5 But Dave was assigned --

6 MR. WEINBERG Well, I think you may be able to 7 do this from Pat Hinman's. Just take a look at that.

8 THE WITNESS: Dave was another one -- he was a 9 capacity where if I wasn't around, he was the primary 10 person who filled in for me. I don't know where I was at 11 the time. But Dave was probably taske'd with taking the -- '

12 setting up the meeting or getting the right people 13 together.

14 I told you earlier that I was --

15 MR. WEINBERG: So he would have written a memo 16 right before that. You see that? Jones would have 17 written that 5/14/94 memo that this was in response to.

18 MR. RAPP: It may have been in that time frame.

19 I can't recall.

20 THE WITNESS: Anyway, Dave -- I told you earlier 23 that I was -- my involvement was trying to make sure the 22 right people were involved, to get meetings going, make 23 sure the people were talking to each other.

24 And then this was another -- You know, Dave was 25 another person that was a tool for mine to make sure --

i i

- 117  !

1 Dave, maka sure these people are getting involved and

'2 . ensure that - - ensure that they talk about all the issues j

-3 and make sure the right people are there.

4 Now, Dave's personal involvement in the makeup 5 tank issue before the test I. don't believe was anything It was just making sure -- Again, more of 6 more than that.

7 an instrument for me to -- my delegation. ,

3 8 MR. WEINBERG: What was his role then?

-9 THE WITNESS: He-was the administrative chift-10 supervisor, which he took care of all the procedures and j 11 administrative issues for the Ops. The same position that 12 Dave Fields rotated into in December. They were slated to 13 swap in January of '95 anyway. ,

14 MR. RAPP: That's all the questions I have.

15 Thank you.

16 MR. DOCKERY: Mr. Vorse, do you have anything?

17- MR.-VORSE: I don't have anything else.

18 MR. DOCKERY: Okay. I'll try and be brief here, ,

19 Mr. Halnon. It's especially important to us from your 20 perspective as a manager that we get yoitr opinion on this.

- 21 Based on testimony we've-heard-previously and 22 quite a bit today, I've sort of reached the conclusion- ,

23 -that part of the problem here may-have-been a--- stemmed 24 -

from. personality conflicts.

25 I know it's -- one of the hardest things to do-I 1

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118 1 sometimes is to make disparaging remarks about colleagues, 2 friends, co-workers that you have some esteem and like 3 for.

4 But is my observation correct? Is part of the 5 problem here a personality conflict or an ego conflict or 6 a conflict between disciplines? .

7 THE WITNESS: Yes. A couple of personalities 8 come into play. One is -- And we'll start with Dave 9 Fields, who was looked upon as a supervisor that stood up 10 f or hic people, who was very strong. He stood behind his 11 people, took responsibility for what they did. Whether or 12 not it was his fault or not, he was very accountable for 13 his people and for their actions.

o 14 But ts was not, if you will, deep into details of 15 issues. He allowed his operators to do that.

16 Okay. Now, add in another personality with Rob, ,

17 Rob was very easy to get alonc with, very easygoing, more

~

18 the philosopher type. He liked to bounce things back and 19 forth. He liked to think into detail. A very detailed 20 person. Vary good questioning attitude.

21 And you add Mark Van Sicklen into this and Mark, 22 again, also had a good questioning attitude, very bright 23 person. And he was absolutely relentless and does not 24 like to admit that he's wrong or does not like to step 25 down from an issue if he has -- if he feels he's right.

l 119 i 1 Add in another personality, Pat Hinman, another 2 very easy-to-get-along with person. In my opinion, 3 technically competent. Not aggressive. Very 4 accommodating, wanted to help operations. Me and Pat, you 5 know, have worked *.ogether for a little while. I didn't 6 know Pat real well, but I know tnat he was a very 7 accommodating person who wanted to help people out.

8 In my opinion, I think that it was a situation 9 where Dave didn't want to let it rest because his 10 operators didn't want to let it rest. So he stood up and 11 said, hey, you know, this is an important issue. And, you 12 know, maybe he didn't understand everything that was going

17. on from a technical standpoint, but le knew his operators 14 were worked up about it, so he was going to stay -- stand 15 up and stand stiff.

16 MR. DOCKERY: Can I interject a ques

  • 4 on here?

17 THE WITNESS: Sure.

18 MR. DOCKERY: I want you to keep your train of 19 thought.

20 Up until the incidence of the 4th and 5th and 21 shortly thereafter did you as a manager identify Mr.

22 Fields as one of the authors, so to speak, of this problem 23 with Curve 8?

24 THE WITNESS: No. Not at all. It was solely in 25 Mark Van Sicklen's level. Mark was the flag carrier, if

- _. - - _ _ . = . - _ _ . - .. . . .. .-

1:10 1 you will. I don't recall personally, and I may have had 2 some cursory discussions, but I don't recall any 3 discussions with Dave Fields about the makeup tank issue 4 before the test. I believe it was all with Mark.

5 MR. DOCKERY: Did any of these individuals have 6 anything personal, other than perhaps ego gratification, 7 to gain by jeopardizing their careers by pressing this 8 operability issue as it related to Curve 87 9 THE WITNESS: I don't think that Mark had 10 anything to gain or lose. I think he -- this is just il Mark's personality. I think he didn't want to back down 12 because he didn't -- he had an issue that he thought was 13 right. And he's done this on other issues. And being the 14 Union steward, it was a natural for him. He worked very 15 hard on making his point and was relentless on getting it.

16 As far as Dave, Dave left earlier in his career, 17 left Engineering pretty much under duress. Had a real 18 hard spot with organization at the time. Went to 19 Operations essentially because he had an SRO and they put 20 him in operations. Dave was a valuable employee and he 21 was smart, but people didn't really like to work with him.

22 You know, he was rash. He was rough around the edges.

23 His temper was unpredictable.

24 Not that he would fly off the handle every day.

25 But if you went -- If you had to go to Dave with an issue

121 1 that you knew would be a conflict, you better -- you know, 2 some people probably avoided it rather than going to him.

3 They may have waited until the next shifter came on or 4 something to that effect.

5 So, you know, I think coupled with Dave's feeling 6 of accountability for his operators he didn't back down 7 because Mark wasn't backing down because of his 8 personality that, you know, he was right and he was going

.9 to prove it one way or another.

10 And Pat, coupled with his accommodating attitude 11 was trying real hard to acco modate it. And it's like, 12 you know, he wanted to give, give, give. And 7 think all 13 Mark wanted to do was take, take, take.

14 MR. DOCKERY: Pat, you're referring to Pat 15 Hinman.

16 THE WITNESS: Pat Hinman. Right.

17 MR. DOCKERY: We have multiples of the same 18 names involved here.

19 THE WITNESS: Yeah. I'm sorry, I told you I'd 20 try to stop that, but --

21 MR. DOCKERY: I think you sort of touched there 22 on perhaps what I refer to as an inter-disciplinary 23 conflict, that being a conflict between Operations and 24 Engineering.

25 Now, that -- such a conflict has been alluded to

122 ,

l 1 by many of the operators that we've discussed this issue l l

2 with.  !

3 I'll also tell you that based on a substantial  ;

4 body of-their testimony the September 2nd memorandum l 5 caused certain of the operators to feel -- to throw up I

6 their hands, basically, and say, we've lost, this issue is 7 lost, we -- we're not going to get satisfaction, which the j 8- implication there being that based on that they decided to  ;

9 _take matters inco their own hands in what turns out to be l

- 10 an unfortunate manner.

11- From your management perspect'ive is that a  !

- 12 correct characterization of what was going on and can you l 13 amplify on it?

, {

14 THE WITNESS: As far as throwing up your hands 15 and saying we lost, I can see where that would be the 16 perception of some of the operators who were intimately i 17 involved with it. And -- ,

18 MR. WEINBERG: You mean Mr. Van Sicklen?

19 THE WITNESS: Van Sicklen. And there was other 20 operators, Bruce Willms, that were intimately involved.

21 People that turned over to Mark and took his position, you

- 22 know, the chief's position. They were all interested in 23 -it. Maybe not as personally _ interested as Mark was, I

24' I think they'saw this memo saying that, hey, you 25 know, this is -- the_ issue's going to get closed out and i

i 4

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I 123 1 =we haven't heard answers to all of our questions that we [

2 except yet.  !

3 And I think there was an element of that we need 4 to do something and we need to take it and do it now. '

5 And, you know, they didn't get-the memo directly. I mean, l 6 they got it through me_saying, hey, let's make some 7 7 comments on this. 1 8 I think it went through Carl. Carl took it and, 9 okay, this is -- you know, we've got to make some comments 10 on this because this letter is going to be issued and a

11 we're going to resolve this issue. And, you know, we're ,

i 12 willing to take these comments back, but we need to get 13 them.

0 14 I don't think we ever got those comments. I 15 think we got the comments in the form of a test on the 4th 16 and 5th.

17 MR WEINBERG: Just so it's clear, they didn't 18 just get this out of the blue. Somebody from management,

- 19 you and/or Bergstrom, brought it to them and told them, I 20 think you said, to -- if you.want to comment, comment --

21 THE WITNESS: Correct. l 22 MR. WEINBERG: -- and then we'll pass ---then

23. we'll take action.

24 THE WITNESS: Right. And you can read it. They 25 received the memo of 9/2. I don't have that chronology.

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124 i 1 But.the first thing in that chronology is thatLyou l 91L W i 2 received the memo of 4112. And they didn't just receive l 1

3 it out of the blue. We gave it to them, asked them for 4 =oomments. f 5 MR. WEINBERG: You're talking about --

6 THE WITNESS: That thing Rob wrote up for them.

7 Right. The first statement. Bruce Hickle proposes f 8 closing all issues. Well, I don't know if P. hat's I

9 accurate. But they.certainly had an option for closing

- 10 the issues.

11 MR. DOCKERY: Would you --

i 32 THE WITNESS: And Operationn mar.agement asked A 13 shift if they had any continuing concerns with the issue. ,

O 14 Operations management.

15 MR WEINBERG: That's you all.

16 THE WITNESS: That 's Bruce, me. Carl, and Dave.

17 MR. WEINBERG: Was it your expnctation that the 18 way that they would address it would be to do some 19 evolutions without telling you?

20 THE WITNESS: Absolutely not. I expected them to 21

~

come to me and say, you know, if it was that strong, and  !

- 22 say, this is ridiculous and this is why. Or something 23 even-more civil-like, hey, let's sit-down and. talk about 24 it.

25 MR WEINBERG: Did they do that?

4 t

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125 1 THE WITNESS: No.

2 MR STENGER: Did you ever invite anyone with 3 concerns to come to you directly?

4 THE WITNEGS: I probably did. You know, these 5 journals I did, I was not routine with them. It might 6 have been maybe once every two weeks or so I sent out 7 these journals, which is basically a brain dump of things 8 in my notebook and stuff.

9 MR. STENGER: You may want to mention this one 10 right here.

11 THE WITNESS: And so I may have done that. This 12 was August 9th, ongoing discucsion of the issue of H2 13 pressure in makeup tank. Talked to Mark to understand the 14 concerns. This is an excerpt out of one of my journals.

Juvg ($A' 15 I discussed this with Bruce and Gerry campbell 16 and we're working to resolve the questions. It is 17 important. And Bruce has asked if anyone has a concern, 18 please write it down and send it to me.

19 So apparently I was very specific at one point 20 about it.

21 MR. DOCKERY: I have a copy of it.

22 MR. RAPP: This was prior to the September 2nd 23 letter.

24 THE WITNESS: This was in August, yeah.

25 MR. RAPP: When this September 2nd letter was

= - _. - - - . . - - . - -.. . -

126 1 delivered to them by Carl Bergstrom, was there any -- did 2 you leave any instructions with Carl Bergstrom that, hey, 3 if these folks have problems, they ought to come see me 4 personally about it and let's get this ironed out right 5 away before there is any further engineering action to 6 take place?

7 THE WITNESS: I don't think it was that specific, 8 Curt. I think it was implied by Carl, get some comments, 9 make Lure that Dave Fields' shift is happy with this,

-10 they're the ones that have been carrying the flag from 11 there, they're the ones most intimately involved. Make l~ sure that, you know, they agree with these and help us 13 pick an option.

14 You know, they made a --

15 MR. WEINBERG: So there was a choice in the 16 memo.

17 THE WITNESS: Right. The Engineering made 18 recommendations and it's our job to provide them the 19 information which recommendation we would like.

20 MR. RAPP: The way it's been characterized in 21 this memo is that it was brought up to the control room 22 right after they took the shift, I think, on the 3rd, it'd 23 be like midnight of the 3rd, right? Or midnight of the 24 2nd.

25 Anyways, it was ..rought up to the control room

127 1 and given to them and said, hey, Engineering will close 2 this thing out unless you've got some more data or some 3 more information to give them. And that's the tone or the 4 context in which this memorandum was delivered to them.

5 THE WITNESS: I think that's the way they 6 understcod it. But you also have to understand that these 7 things that were going to close the issues out were not 8 things that were going to happen overnight. They were 9 modifications that were going to be -- would take a long 10 time to write, design.

11 There were other issues there that -- 1 mean, 12 they just -- And they're not snap of the finger type 13 conclusions to the problems. They're all issues that are 14 goins. to have to take continuing Operations' input to 15 implement.

16 MR. RAPP: How often do plant modifications get 17 proposed and approved and then later canceled due to other 19 prioritied?

19 MR. S~ENGER: You're referring to a particular 20 modification?

21 MR, RAPP: General.

22 THE WITNESS: It happens. I don't know how 23 frequent, I mean, there's always an ongoing assessment of 14 both necessity, economic viability, safety issues having 25 to do with modifications. And as issues change, the

.-p.o . , , ,,,.n- .- - , ., , - , -

128 1 priorities change and sometimes they get canceled. Or 2 we've had some even come back later on and be re-initiated 3 because the concern either wasn't fixed by a modification 4 or a work request or something.

e 5 So it happens. I mean, that's part of the 6 ongoing assessment that we do.

7 MR. RAPP: Were the plant modifications 8 recommended in the September 2nd memo, were they scheduled 9 or prioritized or approved in some manner?

10 THE WITNESS: Okay. Let me look at the memo and 11 see if I can -- -

12 MR. WEINBERG: What was that question?

13 MR. LAPP: The plant modifications laid out or 14 given in the September 2nd memo, were they approved or 15 prioritized or budgeted?

16 THE WITNESS: I think they had all been discussed 17 at one time. I don't think that any of them had been 18 beyond the discussion phase. And what you see here, then 19 obviously there's going to be some background information 20 going into the memo.

21 But at this point I don't believe that any of 22 these were actually scheduled. I think they were 23 proposed, put on the plate and said, let's make sure that 24 these things are viable and we can do it.

25 MR. WEINBERG: In other words, you mean by the

. . . . .- -. _ - _ . _ - _ ~ - . - _. - -. - _ - - . _ -

129 1 fact that it wasn't going to happen overnight?

2 - THE WITNESS: Sure. You can change the set point 3 overnight, valve, regulator. But it takes a modification 4 package and an operations sign-off in order to get that to 5 happen. Bruce has to approve the modification for it to 6 happen. And that takes -- That could take ten days to 7 three weeks to two months, depending on the complexity of 8 the calculation going into the set point.

9 The restoration of the hand wheel MUV-64, that 10 can only be done during an outage. That can't even --

11 couldn't even have been done yet. So'it's not like there 12 was soae urgency on the 4th and 5th to prove this memo 13 wrong or to prove that this stuff wasn't going to happen.

14 So, you know, that was my point earlier, that 15 this stuff wasn't going to happen overnight. It wasn't 16 like if they didn't do something just then, you know, the 17 whole issue was lost . That's ridiculous to think that.

18 MR. WEINBERG: Beyond the discussion with 19 yourself or '<ith Engineering or other management 20 individuals, was there other avenues or other options that 21 either Mr. Fields or Mr. Van Sicklen or whomever could 22 have used to pursue this issue and make-sure that it 23- stayed active and was pursued?

24 THE WITNESS: Well, there's several avenues. The 25 problem report is one. I think the ultimate avenue would 4

_ . , . ._. _ - - . - _ . - . _ _ . _ . _ _ _ _ _ _ . _ . _ _ . _ - _ . - - - _ _ _ _ - . _ . _ . . _ _ . = .

i 130 l 1 be -- at least within our own management ranks would be  !,

2 the employees concerns program.

i 3 And my. understanding is that Mark and/or Bruce i 4 Willms had draf ted an employees concern on the issue, but 5 had not_ issued it because they felt like it would be-not  ;

6 being a team player, not -- you know, it would be more of 7 an'under-the-table type way of getting it solved rather 8 than working on top of the table with Engineering. So 9 they-didn't issue that.

I 10 They could have. And I think they always felt -

11 they could have, but they opted not to. ,

12 So, yeah. There's -- And that's the ultimate 13 way. There's other ways, obviously, through discussions 14 and other -- the problem report, pre-cursory card and --

15 ' MR. WEINBERG: And you excluded from your 16 ' question talking-to Greg or Hickle or Boldt or Beard in  ;

17 going up the ladder.  ;

18 MR. RAPP: Management chain.

19 THE WITNESS: Like I said earlier, Mark was very 20 relentless. He had talked to us all about it. I mean, he i 21 -- No one person would have separated the makeup tank from 22 Mark Van Sicklen's name because Mark was very bulldoggish, ,

23. if you will, on'the issue.

24 MR. RAPP: Let me pick up on something_that 25 Sandy said then. Was it well known or well established

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111

'1 within the operations staff or working organization that 2 they did have essentially what we refer to as an open door 3 policy, that they could go to the manager above their 1 4 supervisor and discuss any issue that they had, or was it, 5 hey, you've got to go through the chain of command, if 6' you've got a problem, you've got to bring it up to your )

l 7 shif t supervisor who_ brings it up to the shif t manager who 8 brings it up to me, and I'll decide whether it needs to go 9 further than-that?

-10 THE WITNESS: I think we had the opposite 11- problem. think that we had people coming -- When I 12- first took the job, I found that people were coming to me '

13 solely and not using the chain of command to resolve C

14 issues, not only technical issues, but personnel issues 15 and stuff, and I was overwhelmed with it, r 16~ There was an effort by me to push, if you will, 17- to work through the chain of command en issues, although I t 18 don't think I ever closed the door or felt like I closed L 19 the door on anybody coming straight to me.

20 And I don't think there was any pointed statement 21 saying, you know, don't come to me for this or don't come 22 to me for that.- There may have been some encouragement to 23 work through your supervisor if you had a problem. That ,

24 was _out of just pure survival for me because I was 25- supervising 85 people directly and that was impossible to ,

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132 1 do.

2 MR. RAPP: Okay. That's all the questions I  ;

3 have.

-4 MR. DOCKERY: Mr. Halnon, you testified earlier 5 that in your opinion the- 25 cc's of hydrogen per kilogram 6 which was desired was achievable.  ;

7 THE WITNESS: Yes. I 8 MR. DOCKERY: We're obviously given to_believe -

9 that presented some problems for certain members of the_ '

-10 Operations drepartment.

11 Did yru s scr.ae during the course of this problem 12 over Curve 8 that perhaps the Operations people felt that 13 that was being adhered to a little bit too rigidly?

14 THE WITNESS: I felt like -- I mean, I felt like 15 that -- Let me rephrase your question to see if it's your 16 question.

17 Did you -- Youre asking if we felt like -- or if 18 the operators felt like t:he 15 cc's per kg, even though 19 achievable, was --

20 MR. DOCKERY: lLeing shoved down their throats.

21 THE WITNESS: Okay. That's_a good way of putting

  • 22L it. I think there were some people that thought that. I  ;

12 3 think that they had an ongoing concern with the 24 conservativeness'of the curve. And they would raise that 25= concern and they were still_being asked to keep the

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--. . . .=_. . - . .- . . _- -

133 1 operating point of the curve er the tank very close to 2 that curve.

3 And even though, I think, they all felt like 4 things were going on in the background or in the 5 engineering world to resolve the issues, it was still 6 there and they had to deal with it every morning when they 7 came in.

8 MR. DOCKERYr Do you think there was a 9 perception on their part that Engineering was the entity 10 that was forcing it down their throat. so-to speak?

11 THE WITNESS: No. I don't think -- I don't think 12 that's the case. I think it was " management."

13 MR. DOCKERY: I don't have anything else.

14 Mr. Halnon, we want to afford you the opportunity 15 if you have any --

16 MR. STENGER: I do have a couple things if 17 that's all right.

18 (Whereupon, a brief recess was taken, after which 19 the following proceedings were had:)

20 MR. DOCKERY: I'll remind you, Mr. Halnen, you 21 continue to be under oath here.

22 While we were off the record there was some 23 exchange of documents, study of some documents, and we 24 don't need to go into them again right now.

25 Mr. Halnon, we're at the conclusion of this

, )

i T

134 l And I'd like to afford you the opportunity if I

1 interview.

2 you want to make any further statements or if there's ,

.3 anythit'.g we haven't brought up that you'd like to address.

THE WITNESS: I have no other statements to make.

4 '

5 MR. DOCKERY: Okay. I'd like to point out that, ,

6 as indicated by Mr. Weinberg at the beginning of this l 7 transcript, the attorneys present here today represent the  :

8 company, represent Florida Power. They don't necessarily

-i 9 represent your interests. And you do have the absolute j

- 10 right, if you wish, to speak to us outside their presence.

11 Do you understand that?

12 THF WITNESS: I understand that. There's no need 13 for that. .

14 MR. DOCKERY: Okay. If there's nothing else --

15 Or, Mr. Weinberg?

16 MR. WEINBERG: Yes. We just want an opportunity [

17 -- or Mr. Halnon, actually, wants an opportunity to read 18 and sign it before it ventures off into wherever it goes.

19 MR. DOCKERY: And we acknowledge that request 20, and we'll handle that.

21 - With that we'll go off the record.

22 (Whereupon, the proceedings were concluded at 23= 6'221 p.m.) 1 2 4 -- *****

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1 CERTIFICATE 3 2 This is to certify that the attached prseeedings 3 tefore the United States Nuclear Regulatory Commission in 4 the matter of:

5 Name of Proceeding: Interview of Gregory Halnon .,

6 Docket Number (s): 2-94-036 7 Place of Proceeding: Crystal River, Florida 8

9 were held as herein appears, and that this is the original

[ 10 transcript thereof for the file of the United States i

11 Nuclear legulatory Commission taken by me and, thereafter g 12 reduced to typewriting by me or under the direction of the 13 court reporting company, and that "he transcript is a true 14 and accurate record of the foregcing proceedings.

15 16 n%/- Y r2N t 17 S. May u

18 Official Reporter r

19 Neal R. Gross and Co., Inc.

20 21 22 23 24 25 9

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