ML20203L885
| ML20203L885 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/22/1986 |
| From: | Herbein J GEORGIA POWER CO., Atomic Safety and Licensing Board Panel, PENNSYLVANIA ELECTRIC CO. |
| To: | |
| References | |
| CON-#386-527 86-519-02-SP, 86-519-2-SP, LRP, NUDOCS 8609020028 | |
| Download: ML20203L885 (17) | |
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NWM COWitbruhut.rtGW Herbein Ex. 1.0 00LKETED USNRC UNITED STATES OF AMERICA 16 AUS 29 P2!49 UUCLEAR REGULATORY COMMISSION LEFORE THE PRESIDING BOARD OFF;cE or SEOst iAs,
DOCKETING.s.sn>y;c7' BRANCH
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In the Matter of
)
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INQUIRY INTO THREE MILE ISLAND )
Docket No. LRP UNIT 2 LEAK RATE DATA
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FALS!FICATION
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Prepared Direct Testimony of JOHN G.
HERBEIN My name is John G.
Herbein.
I am presently employed by Pennsylvania Electric Company ("Penelec") as Vice President, Station Operations.
In that position, I am responsible for operation of eleven generating facilities with a total capacity of over 6500 MW.
These facilities include eight coal-fired and three hydroelectric stations.
The facilities are operated and maintained by more than 1200 personnel.
I.
Education And Employment History I graduated from the Naval Academy with a B.S.
in Naval Science and Engineering in 1960.
I spent the next seven years in the Navy, where I served on four destroyers as ASW officer, weapons officer and chief engineer.
While in the 8609020028 860822 PDR ADOCK 05000320 T
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Navy, I attended the Naval Nuclear Power School, and qualified as Nuclear Engineer Officer of the Watch.
My last eighteen months in tha Navy I served as Chief Engineering Officer of the USS Moale and later the USS Gaynard.
As Chief Engineering Officer, I was responsible for the main propulsion plant, all electrical and auxiliary equipment associated with the ship's main engines and propulsion system, and administration of the 100-man engineering department aboard ship.
Following my release from the Navy in May~1967, I worked at the Yankee Atomic-Power Plant as an assistant to the Operations Supervisor.
My responsibilities were to assist the Operations Supervisor in the supervision and administration of the operations department.
In September 1967, I joined Metropolitan Edison Com-pany and was assigned for three years to the Saxton Nuclear Reactor in Saxton, Pennsylvania.
I obtained a senior reactor operator's license in June 1968, and from August 1968, until May 1970, I was assigned as the Saxton Supervisor of Opera-l
~
tions.
In that position, I was responsible for all operating functions and power generation of the 30 MWT Saxton l
l experimental reactor, which generated approximately 3.5 MW of electrical power.
In May 1970, I was assigned as Supervisor of Reactor' Plant Services at Saxton.
In this capacity, I was j
l responsible for the maintenance and nuclear engineering i
L activities required to support the operating unit. I l
In September 1970, I was transferred by Metropolitan Edison to Three Mile Island as Station Engineer for Unit 1.
At TMI-1, I was responsible for all the engineering disciplines, including radiation protection, nuclear engineering and training.
These disciplines supported the operations and maintenance activities associated with TMI-1.
In January 1973, I became the TMI-1 Assistant Superintendent.
In this capacity, I was directly responsible for the operations, maintenance, engineering and administrative activities associated with TMI-1.
In September 1974, I became Station Superintendent responsible for the' management of TMI Units 1 and 2.
In 1975, I was promoted to Manager of Nuclear Opera-tions, and was stationed in Reading, Pennsylvania.
In this capacity I was the manager responsible for the operation of TMI Unita 1 and 2.
In the fall of 1976, I was named Manager of Generation Operations for Metropolitan Edison, and in this capacity I assumed additional responsibility for all coal-l fired, hydro-power and combustion turbine power stations for l
Metropolitan Edison.
In June of 1977, I was named Vice Presi-l dent of Generation for Metropolitan Edison.
I continued in l
that capacity until the accident at Three Mile Island, Unit 2, which occurred in March of 1979.
II.
Purpose Of Testimony In this proceeding, I seek complete resolution of all l
allegations that I was in any way involved in or aware of leak l
rate testing improprieties, and I wish to remove any and all restrictions concerning my employment in the nuclear field.
The purpose of my testimony, therefore, is to explain that I had no involvement in, awareness of or conscious tolerance of leak rate testing improprieties.
To that end, my testimeny addresses my duties and responsibilities as Vice President-Generation between February 1978 and March 1979, the management structure of TMI-2, and my lack of knowledge concerning alleged.
leak rate testing difficulties and improprieties at TMI-2.
III.
Duties And Responsibilities Between February 1978 and March 1979, I was Vice Pres-ident-Generation for Metropolitan Edison.
I was responsible for the overall operation, maintenance, administration, quality assurance, and related technical engineering support activities l
associated with the generating stations owned and operated by Metropolitan Edison.
The stations included one two-unit l
l nuclear station, two multi-unit coal-fired stations, one hydro-electric station, and fourteen combustion turbines which had a total capacity of 2576 MW.
In addition, Metropolitan Edison j
was a partial owner of a coal-fired station operated by Penelec.
In carrying out my duties and responsibilities, I was j
involved in the following activities:
interaction with the five managers who reported to me l
to keep apprised of their functional activities, priority concerns and initiatives; plant inspections and visits;
- i i
annual budget preparation, tracking and perforraance; rate case development, including preparation and presentation of generation testimony, responses to discovery requests, and appearances before the Pennsylvania Public Utilities Commission; license and permit applications to the Pennsylvania Department of Environmental Recources regarding air and water emission limits for power stations; reviewing NRC inspection reports and related responses and meetings with the NRC on various issues; meetings with executives and managers of sister companies in the GPU system; meetings with representatives of various manufacturers and suppliers; personnel related issues, including recruiting efforts, interviews, promotions and reorganizations; community relations activities, including a community action committee designed to promote better communica-tion between Metropolitan Edison customers and Company management, public speaking engagements, and television interviews; and membership in the Edison Electric Institute Prime Movers and its Nuclear Power Subcommittee.
IV.
Management Structure of TMI-2 I generally kept abreast of activities at TMI-2 by relying on the chain of command to keep me apprised of opera-l tions at TMI-2.
Additionally, several formal review committees were established outside the direct chain of command to assure an objective, independent review of plant activities and to provide management with a broad overview and perspective of plant operation, maintenance, safety-related and technical issues.
I relied on the chain of command and the cognizant i __,
formal review committees to bring issues requiring my input end decisions to my attention.
When a problem requiring my input s
was brought to my attention, I became directly involved in the problem to the degree a satisfactory resolution required.
In addition to the above, about every 4-6 weeks, I would visit TMI Units 1 and 2.
The purpose of my visits was to
-meet with station. management on current issues of concern, such as station performance, personnel vacancies and budget develop-ment and compliance.
Additionally, although I did not engage in the direct supervision of employees when I visited, I would periodically speak with them to indicate that upper management was interested in and supportive of them, and to indicate that the corporate organization in Reading was concerned abo t activities at TMI.
A.
Chain Of Command s
In describing the chain of command, I will generally l
restrict myself to describing the chain relevant to leak rate l
testing and plant operations.
The control room operators
("CROs") performed the majority of routine, day to day operat-l t
ing tasks.
Operations personnel were assigned to five operat-ing shifts, and each shift had'a Shift Foreman in charge.
TMI Unit 1 and Unit 2 Shift Foremen reported to the Shift Super-visors who were in charge of Shift Foremen at both units.
The Shift Supervisors reported in turn to the Supervisors of Opera-tions for Units 1 and 2.
The Unit 2 Supervisor of Operations, j i l
l
the Superintendent-Technical Support and the Supervisor of Maintenance reported to the Unit 2 Superintendent.
The Unit 2 Superintendent reported to the TMI Station Superintendent, the highest level of management stationed on the Island itself.
The Station Superintendent reported to the Manager of Genera-tion Operations in Reading, Pennsylvania.
He in turn reported to me, the Vice President-Generation, also in Reading.
After March 5, 1979, the chain of comnand was reorganized, and the Station Superintendent became Station Manager and began reporting directly to me.
In addition to the Manager of Generation Operations, the Manager of Generation Administra-tion, the Manager of Generation Engineering, the Manager of Quality Assurance and Training and the Manager of Maintenance also reported to me.
An organizational chart is attached as Herbein Exhibit 1.1.
On a day-to-day basis, I received information through the managerial structure, primarily from the Managers listed j
above who reported to me.
For example, if the reactor would l
trip or if there was a problem that would limit the full power level achievable by Unit 2, I would be made aware of it by the Manager of Generation Operations or the Manager of Generation Engineering.
l l
Additionally, there was a significant amount of licensing information that we were required to transmit to the r
NRC.
I signed the transmittal letters after ascertaining that i
the underlying documents were accurate and complete, and had passed through the proper review channels.
I had a number of reliable, competent managers.
I relied on them to manage their departments and keep me apprised of developments requiring my input and decisions.
B.
Rormal Review Committees There were four such groups relevatz.t to this inquiry:
(1) the General Office Review Board (GORB), (2) the Plant Operations Review Committee (PORC), (3) the Generation Review Committee (GRC) and (4) the Quality Assurance Department (QA).
The GORB was an advisory group that reported directly to the President of Metropolitan Edison.
The GORB's reports would allow the President, who was not involved in the day-to-day operational activities of the station, to look at the broad perspective of maintaining nuclear safety and appropriate radi-ation protection.
The PORC was an advisory group that reported to the Unit Superintendent.
The PORC was required by the technical specifications of TMI-2 to review procedure changes and plant modifications, as well as activities directly affecting the nuclear safety of the operating unit.
The GRC was a group organized to provide an indepen-dent review and audit of activities important to nuclear safe-ty, which included procedure changes, plant modifications and violations of regulations. -
The QA organization audited and inspected safety related activities, including operations, maintenance, engineering and licensing, to ensure compliance with procedures developed by the functional groups.
V.
Lack of Awarenees of Alleged Reactor Coolant Inventory Balance Testing Problems It is my understanding, from the voluminous record generated by the various leak rate investigations, that the bases for an allegation that I may have had some awareness of leak rate testing problems at TMI-2 are:
(1) the allegation by the U.S..pttorney that I may have been involved in a conference call concerning leak rate testing problems and (2) the presence of my signature on a transmittal letter submitting a leak rate test-related licensee event report ("LER").
A.
The U.S.
Attorney's Telephone Con.versation Allegation I am now familiar with the U.S. Attorney's statement relating to the sentencing proceedings in U.S. v. Metropolitan Edison Company that contains, in part, the following:
A shift supervisor would testify that as a result of the October 18, 1978 NRC inspection a conference telephone call was made from the shift supervisor's office in the Unit 2 con-trol room.
Present in the shift supervisor's office and parties to the conversation were the Superintendent of Technical Support, the i
Supervisor of Operations, and two shift super-visors.
The call was made to either TMI's Station Superintendent or Metropolitan Edison's Vice-President for Generation, or both.
The Station Superintendent and/or the l
Vice-President for Generation were briefed on l
l l l
{
the situation at TMI Unit 2 concerning the leak rate test.
During the conversation the operations personnel alerted the Station Superintendent and/cr Vice-President for Generation that because of the numerous " bad" leak rate tests obtained at Unit 2, the NRC's interpretatior. of the leak rate technical specifications would result in repeated shut-down of the facility.
I never participated in any such conversation.
If I had, I am certain that I would remember such a conversation and I would have initiated action to underetand and correct the problem.
Beyond what is stated above, I do not know the basis i
for the U.S. Attorney's statement.
I further note that the U.S. Attorney's version of the anticipated testimony oi the shift supervisor was far from conclusive concerning my alleged involvement in the phone call.
In fact, the best argument made was that it was "either" ne, "or" TMI's Station Superintendent, "or both" that were involved.
Moreover, I think it important to observe that I was not a party to the sentencing proceedings, did not participate in the plea agreement bargaining process, and had no opportun-ity to rebut the argument of the U.S. Attorney.
B.
Licensee Event Report 78-62/1T I am presently aware that, in the fall of 1978, I signed the transmittal letter covering LER 78-62/1T. */
I
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The numbering system used for LERs reflects that this LER was the sixty-second (62nd) LER in calendar year 1978.,
e presently have no independent recollection of the LER or the events surrounding it.
Therefore, in this section I will discuss the general procedure for filing LERs, to the best of j
my recollection, that was in place during 1978-79.
When an incident occurred, there were fairly detailed guidelines within the TMI-2 technical specifications for the licensee to follow with regard to reportinc certain information within pr'eset time frames.
Typically, when an event was out-side of a technical specification or a limiting condition of operation, station management at TMI, with assistance from the licensing group in Reading, would prepare and submit a " prompt report" within the required time frame, which was usually 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The PORC was responsible'for reviewing prompt reports.
The PORC would thoroughly review an event to determine whether, in fact, it met the criteria of the technical specifications for prompt reporting.
The PORC also would review the planned follow-up action to determine if it properly addressed the problem.
Additionally, the PORC would monitor follow-up action to assure that the planned follow-up action was actually carried out.
Generally, at.come time after the prompt report of the incident, the technical specification required a follow-up report.
This report was typically handled by corporate licens-ing personnel with assistance from TMI personnel.
The licens-ing personnel would then interact with various generation,
department heads in Reading and the appropriate personnel at TMI to further develop the follow-up report.
After various reviews, reports were brought to me for signature.
I reviewed the reports to ascertain that they were responsive to the reporting requirements and that they had the licensing group's recommendation that I should approve them.
I would sign reports and return them to the licensing group, who would then make final distribution.
If I had any concerns or questions about a follow-up report, I would bring them to the attention of the licensing group, who would then attempt to resolve them to my satisfaction.
Although presumably the above described review procedures were followed in preparing the LER, it recently was brought to my attention during an interview with Mr. Stier's staff that the final version of the LER contained some inaccurate statements which may have been misleading to me and the NRC.
The inaccuracies are thoroughly examined by Mr. Stier in his report, and I will not'specifically address them here.
I note, however, that the LER would not have given me any reason to believe that the' problem was anything other than an isolated incident that had been corrected.
The established review and follow-up procedures should have brought the true nature and extent of the problems to my attention and the attention of the NRC.
Apparently, due to the inaccuracies in
-the LER and lack of appropriate follow-up,. this never occurred.
In fact, as I am now aware, in January of 1979, the NRC -
~
notified me that LER 78-62/lT had been selected for on-site follow-up. that an NRC inspector verified that the relevant reporting requirements had been met, that appropriate corrective action had been taken, that the event was reviewed by the licensee as required by the technical specifications and that continued operation of the facility was conducted in conformance with technical specification limits.
(Testimony of Donald Haverkamp, Exhibit E, at 10-11)
VI.
Concluding Remarks.
I emphatically state that I was not aware of, did not participate in, and did not consciously tolerate inproprieties associated with leak rate testing at TMI-2.
Although the LER indicated TMI-2's failure to respond to a leak rate test outside the acceptable limits, I was never made aware of the following ongoing problems:
1) that CROs were having trouble obtaining leak rate test results within acceptable limits; 2) that.CROs were documenting leak rate test results within acceptable limits without regard to the validity of the results; 3) that CROs or others were discarding or failing to document unsatisfactory tests; 4) that CROs were manipulating test results; and 5) that Operations Department personnel were not taking apprcpriate action after unsatisfactory test results.
I'had no ceason to believe that these problems were occurring.
Neither my Managers, the Metropolitan Edison formal l
l l !
A review committees, nor the NRC brought them to my attention.
In fact, I had every reason to believe that no such problems were being encountered.
In February of 1979, I had a routine corporate management meeting with the llRC at the Region I Office in King of Prussia, Pennsylvania.
The purpose of the meeting was to discuss the NRC's Office of Inspection and Enforcement's inspection program and Metropolitan Edison's organization, management controls, previous enforcement actions, operational status, plant and programs.
There was no indication from the NRC at that meeting that there were problems with leak rate testing at Unit 2.
These problems shculd have been identified to me by either the managerial structure or the formal review committees.
Neither structure identified these problems.
I do not believe that any failure of the managerial and committee structures was due to any dereliction of duty on my part.
While in hindsight certain mechanisms or procedures might have been instituted to avoid this communication breakdown, I had no reason, at the time, to believe such measures were necessary.
i However, I recognize that as the Vice President-Generation I l
l must accept ultimate responsibility.
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00f.gE1E0 USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIg s 29 P2:49 0FFICE OF SRd *"I-00LKElthG A SEPVIC
)
BRAN In the Matter of
)
)
Docket No. LRP INQUIRY INTO THREE MILE ISLAND
)
ASLBP No. 86-519-02 SP UNIT 2 LEAK RATE DATA
)
FALSIFICATION
)
)
CERTIFICATE OF SERVICE I hereby certify that I have served copies of the attached " Prepared Testimony of John G.
Herbein" by deposit in the United State.s mail, first class, postage prepaid, to the following persor.s this 22nd day of August, 1986:
Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge James L.
Kelly, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 l
Administrative Judge Glenn O. Bright l
Atomic Safety and Licensing Board Panel l
U.S.
Nuclear Regulatory Commission Washington, DC 20555 l
Administrative Judge Jerry R.
Kline l
Atomic Safety and Licencing Board Panel l
U.S. Nuclear Regulatory Commission l
Washington, DC 20555 l
Jack R.
Goldberg, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, DC 20555 l
l i
l I
l 1
i Ernest L. Blake, Jr., Esq.
Shaw, Pittman, Potts & Trowbridge 3800 M Street, N.W.
Esshington, DC 20036 Michael W. Maupin, Esq.
Hunton & Williams P.O.
Box 1535 Richmond, VA 23212 Ms. Marjorie M. Aamodt 200 Nortn Church Street Parkesburg, PA 19365 Ms. Marjorie M. Aamodt P.O.
Box 652 Lake Placid, NY 12946 Harry H. Voigt LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave.,
N.W.
Washington, DC 20036 Smith B.
Gephart, Esq.
Killiam & Gephart 216-218 Pine Street Box 886 Harrisburg, PA 17108 N
Christopher W'.
Flynn August 22, 1986
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