ML20205F688
| ML20205F688 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/15/1986 |
| From: | Geoffrey Miller GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20205F665 | List: |
| References | |
| LRP, NUDOCS 8608190290 | |
| Download: ML20205F688 (23) | |
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N UNITED STATES OF AMERICA CC:.
NUCLEAR REGULATORY COMMISSION Before the Presiding Board
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In the Matter of
)
) Docket No. LRP INQUIRY INTO THREE MILE ISLAND
)
UNIT 2 LEAK RATE DATA FALSIFICATION)
TESTIMONY OF GARY P. MILLER My name is Gary P. Miller.
I am employed by Metropolitan Edison Company as Director, Generation Operations.
1.
Education and employment.
I graduated from the United States Merchant Marine Academy in 1963 with a B.S. degree.
Upon l
graduation, I served for about a year in the Merchant Marine, principally as a licensed Third Assistant I
j Engineer on steam and motor vessels.
I then went to work at Newport News Shipbuilding and Drydock Corporation where I remained for about eight years; I i
was involved there in (a) management and execution of test programs for nuclear vessels and (b) management i
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'O of nuclear vessel construction.
In early 1973, I joined GPU Service Corporation as Test Superintendent J
for Three Mile Island Unit 1.
In September 1974, when Unit 1 began commercial operations, I moved to Metropolitan Edison Company as TMI Unit 2 Superinten-j dent.
In mid-1977, I became Station Superintendent i
as well.
Thus on February 2, 1978, which is the beginning of the period that is the subject of the Commission's attention in this proceeding, I held two titles:
I was TMI Station Superintendent, and I also served as TMI Unit 2 Superintendent.
In late 1978, I relinquished the title of TMI Unit 2 Superintendent but retained the position of Station Superintendent.
In March 1979, I became Station Manager.
I continued as Station Manager through March 28, 1979, which is the end of the period that is the subject of the Commission's inquiry in this proceeding.
2.
Reporting responsibilities.
l Persons in three principal operating positions reported to me in my capacity as Station Superinten-dent.
They were the Unit 1 Superintendent, the Unit i
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2 Superintendent and the Site Maintenance Superinten-dent, who was responsible for maintenance at both Units.
During 1978, James O'Hanlon served as Unit 1 Superintendent.
Near the end of 1978, I believe, James Seelinger replaced him and served in that posi-tion through the end of the period in question.
During 1978, of course, I held the title of Unit 2 Superintendent.
In late 1977 or early 1978, the Company had hired Joseph Logan to prepare to assume the Unit 2 Superintendent's position.
He obtained an NRC operator's license in the fall of 1978, as I recall, and thereafter he was present in Unit 2 familiarizing himself further with the Unit and getting to know the staff.
Toward the end of 1978, Mr. Logan formally assumed the Unit 2 Superinten-dent's position, and I relinquished it. Although I was nominally the Unit 2 Superintendent until late 1978, when Mr. Logan took over, I tended to deal principally with Station matters.
As a result, I depended on Mr. Seelinger to supervise day-to-day operations of Unit 2 during most of 1978.
During that time Mr. Seelinger was the Unit 2 Technical 1
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Support Superintendent.
He was being groomed to become a Unit Superintendent.
Mr. Seelinger was, as a practical matter, the principal Unit 2 manager during this time frame.
He substantially discharged the responsibilities of Unit 2 Superintendent.
Mr. Seelinger, for example, represented Unit 2 during 1978 in the morning telephone conference calls on Unit status, which I discuss below, while Mr.
O'Hanlon, the Unit 1 Superintendent, represented Unit 1.
The third position that reported to me in my role as Station Superintendent -- Site Maintenance Superintendent -- was held by Daniel Shovlin through-out the period in question.
When I became Station Manager in March 1979, the three principal positions reporting to me remained the same.
The four principal operating positions that reported to me in my capacity as Unit 2 Superinten-dent were the Superintendent Technical Support, Supervisor of Operations, Supervisor of Maintenance and Supervisor of Radiation Protection and Chemistry.
These jobs were held during 1978 by Mr. Seelinger,
O.
James Floyd, Richard Sieglitz and nichard Dubiel respectively.
When Mr. Seelinger went to Unit 1 in late 1978, he was replaced as Unit 2 Superintendent Technical Support by George Kunder.
Messrs. Floyd, Sieglitz and Dubiel retained their 1978 positions through March 28, 1979.
With respect to my reporting responsibilities, I reported while I was Station Superintendent to Lawrence Lawyer.
His office was located in Reading, Pennsylvania at the Metropolitan Edison Company corporate headquarters, and his title was Manager of Generation Operations.
He was responsible for both fossil and nuclear operations for Metropolitan Edison Company.
He reported to Jack Herbein, who was Vice President - Generation for the Company and also located in Reading.
When I became Station Manager, I thereafter reported directly to Jack Herbein.
3.
Responsibilities as Station Superintendent and Station Manager.
During the period February 1978 through the end of March 1979, I was responsible for the approximately 500 people employed at the TMI site.
About 100 of them were supervisory personnel.
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usually worked six days a week, sometimes seven, and on the average about 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> a week, carrying out my job assignments.
Typically, I would spend most of the time from 9 a.m. to 5 p.m., Monday through Friday, in meetings of one kind or another.
I have estimated before, and I continue to believe, that I spent from 20% to 40%
of my time during 1978 and early 1979 away from the Island, principally in meetings at Reading on a host of subjects:
long-term planning, generation manage-ment, relationships with our GPU sister companies, labor matters, career development, Company finances, to name a few.
I tried to attend on every occasion that I could, entrance and exit interviews with NRC inspectors.
I typically attended Babcock & Wilcox User Group meetings, which were usually held twice a year.
I atten.ded all meetings of the General Of fice Review Board, and they required substantial prepara-tion.
I held a meeting of department heads from both Units each week.
I attended meetings of the Shift Supervisors, Shift Foremen and Maintenance Foremen.
These three groups met separately, on a monthly basis as I recall.
I met with, and often conducted tours i
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of the Station for, members of the management of my Company and its sister companies and of Babcock &
Wilcox Corporation, which manufactured the Unit 1 and 2 reactors.
I also led tours for union officials and local community groups.
In addition, I held meetings constantly with Metropolitan Edison Company and GPU Service Company personnel in connection with the sub-jects that are discussed below and many that are not.
I estimate that I spent about 30% of my time during 1978 and early 1979 dealing with personnel matters.
Whenever an existing position became avail-able at TMI or a new position was recommended, I would have to justify the refilling or establishment of the position with my superiors.
I would also have to participate in or approve of the hiring decisions,
that were eventually made.
Where supervisory positions were involved, I would usually interview the candidates personally.
I was the person primarily responsible for dealing with the labor union that represented the non-supervisory employees at the site.
When a grievance procedure was not resolved between the union and the supervisor who was immediately affected, I would get involved, either
participating in the second level meeting or discussing the matter with the supervisor who was to participate.
I also held " mutual problems" meetings with the union representatives several times a year.
I reviewed the annual performance evaluations of all of the roughly 100 supervisory employees at the site, and I was responsible for performing in the first instance the employee evaluations of those supervi-sors who reported directly to me.
I had to defend all of these evaluations with my superiors.
I participated in a manpower assessment program during the period designed to identify the career goals of our supervisors and help them develop plans to achieve those goals.
I was also responsible for the preparation of the annual budget recommendation for Station operations.
This required me to review the budget proposals of persons who reported to me, make such revisions as I thought were necessary and forward the Station's proposals to my supervisor.
This process began in earnest in August of each year looking toward the development of a budget for the following calendar year.
It required a thorough review of l
9-maintenance, construction, and staffing needs for each Unit.
It required decisions as to whether particular jobs should be done by Station personnel or by outside contractors.
The formal recommendation and defense of our budget proposals were the subject of a great deal of preparation, including the rehearsal of our presentations to management.
I had pressing and constant demands on me from my subordinates for additional personnel, maintenance work, and equipment, and I had a limited number of dollars allotted me by my management for expenditure on those items.
I spent a great deal of time resolving that particular dilemma in innumerable different contexts.
I spent a significant amount of time dealing with plant engineering, maintenance, quality assurance, training, industrial safety, health physics and security matters.
I was the Station Emergency Director and, among other things, was i
responsible for directing emergency drills.
More specifically, I recall clearly that I spent a substantial amount of time during the last few months of 1978 involved in planning for the Unit 1
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outage that began in mid-February 1979.
This was a period of intensive pre-outage activity, involving the identification of maintenance and construction work that should be performed during the outage, the decision for each significant task whether to use Metropolitan Edison personnel or outside contractors, the allocation of personnel between Unit 1 for its outage needs and Unit 2 for its operational needs, the scheduling of the work required and meetings with the union to discuss the allocation of personnel.
I also recall that during 1978, Unit 2, which had received its operating license in February, had not yet achieved commercial operation.
As a result, GPU Service Corporation personnel were present at the site carrying out the start-up and test program for Unit 2.
My operating and maintenance personnel supported the Service Corporation activities, and so Unit 1 operations and Unit 2 test requirements competed for the attention of the same people.
I spent a good deal of time resolving questions of priorities posed by these competing needs.
I gave considerable attention in October 1978 to preparations for a meeting of the Metropolitan Edison
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Company and GPU Service Corporation generation managements scheduled for October 26.
The purpose of the meeting was to reach agreement on the tasks remaining to be completed at Unit 2 and to determine which had to be completed before commercial operation and which could be completed thereafter.
In addition to all of the meetings I have men-tioned, I dealt with a large volume of correspondence
-- e.g. contracts, requisitions, Company memoranda, site-related NRC correspondence, audit results --
that required attention each day.
As a rule I dealt with this correspondence prior to normal business hours in the morning and after normal business hours in the evening.
I do not mean to suggest by this enumeration of my responsibilities that I did not pay attention to operating matt,ers.
I did.
But I had to limit such attention to those matters that involved safety or unit availability, and I necessarily depended on my subordinates to bring such problems to my attention.
I simply was not in a position independently to seek out such problems.
r e.
4.
Knowledge of Unit operating matters.
Insofar as operation of the Units was concerned, I relied, as I have said, principally on the Unit Superintendent in Unit 1 and, in connection with Unit 2, on Jim Seelinger through late 1978 and on Joe Logan thereafter.
I kept abreast of the daily status of the Units primarily through two mechanisms.
First, each morning the Shift Supervisor of the 11 p.m.-to-7 a.m.
shift would leave a copy of a Plant Daily Status Report (PDSR) at my office, deliver it to the Unit Superintendents and telecopy it to Reading where, as I recall, it would be distributed to Messrs. Herbein and Lawyer.
I have learned in connection with leak rate investigations of recent years that there were probably attached to my copies of the PDSR's certain
" turnover" notes by which the outgoing Shift Supervisor advised his replacement about the status of the Units.
I do not recall seeing these turnover sheets, but I believe, based on my review of certain documents during the Stier Unit 2 leak rate investigation, that I would have received them.
On those days when I was at the Island I would try to
review the PDSR each morning.
My customary practice was to review the important plant parameters, including unidentified leak rate.
I would also look at the comments on the right side of the one-Unit form or at the bottom of the two-Unit form that was adopted later, because I would have expected any special problems to be addressed there.
The second mechanism for staying abreast of the status of the Units was a morning conference call.
Typic. ally, those conference calls occurred at about 8:15 a.m. and involved me, the Unit 1 Superintendent, the Unit 2 Superintendent, (or, during 1978, Jim Seelinger) and, prior to my becoming Station Manager, Mr. Lawyer.
After I became Station Manager, Mr.
Herbein participated in these calls when he was available instead of Mr. Lawyer.
We customarily spoke from conference telephones in our respective offices.
As I recall, it was the practice of each Unit Superintendent to visit the control room of his Unit each morning before this conference call, and the Superintendents would usually take the lead during the call in describing Unit conditions.
As I have said, I tried to review the PDSR each morning before the conference calls.
I may also have looked at the turnover sheets when they were attached.
I clearly remember, however, that I relied principally on the morning conference call, rather than the PDSR or the turnover sheets, as my principal day-by-day source of information on the status of the Units.
In addition, I tried to visit the control rooms from time to time.
I recall that I had a goal of doing so about once a week, but I am confident that I failed to make it that frequently.
During the 1978-1979 period, I did not regularly attend meetings involving plant operations.
I did not attend plan-of-the-day meetings, which were daily meetings involving detailed consideration of such things as maintenance, engineering, operating and surveillance matters.
I attended meetings of the Plant Operations Review Committee rarely, if at all, during this period.
During 1978 I attended Shift Supervisors', Shift Foremen's and Maintenance Fore-men's meetings; those meetings were held monthly, as I recall, and dealt principally with staffing and 4
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maintenance matters and occasionally with an I
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operating matter.
I did let it be known to the Shift Supervisors that my door was always open to them to discuss problems.
From time to time, a Shift Super-visor would avail himself of that opportunity.
As I recall, however, such meetings almost invariably involved personnel matters.
On matters of plant operations I would have expected, and my subordinates knew I would have expected, that they proceed through normal channels.
My office was outside the security fence at Three Mile Island precisely so that Unit employees would deal with their Unit managements and not come directly to me on routine matters involving the operation of the Station.
5.
Knowledge of leak rate problems.
I had some familiarity during 1978 and early 1979 with the Unit 2 Technical Specifications.
I had held a license at one time for Unit 1 and, in that connection, had been required to become thoroughly familiar with the Unit 1 Technical Specifications.
l In addition, I was involved in the process of developing the Technical Specifications for TMI Unit 2.
We were not permitted to use Unit 1-type I
s Technical Specifications; instead, we were required to use an NRC " standard" form of Technical Specifica-tions for Babcock & Wilcox plants.
As a result of my experience with Technical Specification development and my responsibilities for Unit 2, I had some familiarity with Technical Specification 3.4.6.2.
I knew prior to March 28, 1979, that permissible unidentified leakage was one gallon per minute.
I believe I knew that the permissible identified leakage was ten gallons per minute and that pressure boundary leakage was not permitted.
I knew that the Units had different leak rate surveillance require-ments.
I knew that the Unit 2 Technical Specifica-tions required that an acceptable unidentified leak rate be obtained every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
I do not recall having had occasion during the period in question to focus on the de, tailed implications of the 72-hour requirement and to determine precisely what obliga-i tions it imposed.
I do recall that the practice was instituted at Unit 1 of performing a leak rate test at least once per shift, and I recall that that prac-tice was carried over to the operation of Unit 2.
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cannot testify with certainty that I knew prior to March 28, 1979 much more detail than I have recited.
Since March 28, 1979, I have given a good deal of attention to Licensee Event Report 78-62/IT which was submitted by the Company to NRC on October 19, 1978.
The LER involved a failure to obtain a satis-factory leak rate result within the time required by the Unit 2 Technical Specifications and a failure to enter the action statement.
I have testified before, and it remains true, that I have no recollection of that episode.
I believe that Jim Seelinger, in per-forming the Unit 2 Superintendent's responsibilities, would have taken charge of and resolved that matter.
I have no doubt, however, that he and I would have discussed the violation and the LER.
We worked closely together, and I am confident that he would have advised me about a matter of this significance.
I do not believe, however, that I was aware during the time period in question that the control room operators in Unit 2 were having significant difficulty achieving the acceptable leak rate sur-veillance test results required by Unit 2 Technical l
Specification 4.4.6.2.d.
I knew from my experience i
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in the development of the Unit 2 Technical Specifica-tions that surveillance generally would be more difficult for Unit 2 than for Unit 1, in terms of the number and frequency of surveillance requirements and the nature of those requirements.
As part of this, I knew that acceptable leak rate test results would be more difficult to achieve under the Unit 2 Technical Specifications than they had been for Unit 1; the Unit 1 Technical Specification permitted us to take credit in designing our leak rate test procedure for a.5 gpm evaporative loss, but the Unit 2 Technical Specification did not.
I thought, however, that acceptable leak rates could be consistently obtained under the Unit 2 Technical Specification, and I was never advised prior to March 28, 1979 that that was not the case.
In the years since the leak rate difficulties came to light, I have had occasion to review care-fully the PDSR's for the period October 1, 1978 l
through March 28, 1979.
I now know that from time to time during that period the same unidentified leak rate result, sometimes carried out to four decimal places, was carried forward for three or four l
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consecutive days.
Had I compared the leak rate results on the PDSR's for neveral days at a time, j
they might well have raised a question in my mind and caused me to inquire further.
I do not believe, however, that I ever carried out such a comparison.
In short, I simply did not realize that such repeti-tive results were being recorded.
As I have said, I depended primarily on the morning conference call as a means of identifying operational problems.
I do not believe that the subject of continuing leak rate surveillance difficulties was ever discussed during those calls, and I do not believe that anyone ever advised me about such difficulties on any other occa-sion.
I am also aware of the statement by the United States Attorney for the Middle of District of Pennsylvania to the effect that I may have been a party to a telephone call in October 1978, made from the Unit 2 Shif t Supervisor's of fice, in which the difficulty of obtaining acceptable leak rate results l
was allegedly discussed.
I do not recall partici-pating in or being aware of such a conversation.
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Furthermore, I did not know that unacceptable leak rate surveillance test results were being discarded.
I have testified before that this is something I would have expected to have been brought to my attention.
I do not recall, however, that that was ever done.
In my view, the discarding of leak rate tests on the scale on which it was apparently done was improper, and I would not have condoned it.
Finally, I did not know of any manipulation of data or other improper efforts to influence leak rate test results at Unit 2.
I can say categorically that I would not have condoned such conduct.
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l August 15, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Presiding Board In the Matter of
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) Docket No. LRP INQUIRY INTO THREE MILE ISLAND
)
UNIT 2 LEAK RATE DATA FALSIFICATION
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CERTIFICATE OF SERVICE I certify that copies of Testimony of Gary P. Miller were served upon the following persons by deposit in the U.S. Mail, first class, postage prepaid, addressed to them at their addresses set out below, today:
Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTENTION:
Chief, Docketing and Service Section l
Administrative Judge James L. Kelley Chairman l
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
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Administrative Judge Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ernest L. Blake, Jr., Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Jack R. Goldberg, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Co:mmission Washington, D.C. 20555 Harry H. Voigt, Esq.
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Suite 1100 Washington, D.C. 20036 Smith B. Gephart, Esq.
Killian & Gephart 216-218 Pine Street P.O. Box 886 Harrisburg, Pennsylvania 17108 James B. Burns, Esq.
Isham, Lincoln & Beale 3 First National Plaza Suite 5200 l
Chicago, Illinois 60602 l
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Ms. Marjorie M. Aamodt Mr. Norman O. Aamodt Box 652 Lake Placid, New York 12946 Ms. Marjorie M. Aamodt Mr. Norman O. Aamodt 200 North Church Street Parkesburg, Pennsylvania 19365 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 lA, b-Michael W. Maupin, Counsel for Gary P. Miller Dated:
August 15, 1986 I
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