ML20215D805

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Transcript of 861007 Hearing in Bethesda,Md Re Inquiry Into TMI-2 Leak Rate Data Falsification.Pp 3,007-3,141
ML20215D805
Person / Time
Site: Crane 
Issue date: 10/07/1986
From:
Atomic Safety and Licensing Board Panel
To:
References
CON-#486-1208 LRP, NUDOCS 8610140303
Download: ML20215D805 (150)


Text

ORLG NAL UN11ED STATES O

1 NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:

DOCKET NO: LRP INQUIRY INTO THREE MILE ISLAND UNIT 2 - LEAK RATE DATA FALSIFICATION o,

LOCATION:

BETHESDA, MARYLAND PAGES: 3007 - 3141 DATE:

TUESDAY, OCTOBER 7, 1986

/), b ACE-FEDERAL REPORTERS, INC.

Official Reporters 444 North Capitol Street Washington, D.C. 20001

' 1v,ioia r 0: e s i o o.'

4 i os Apoci a r.oo NATRON TDE coVERACE

CR28397.0 RT/dnw 3007 1

UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

- - - - - - - - - - - - - - - - -x 5

In the Matter of:

Docket No. LRP 6

INQUIRY INTO THREE MILE ISLAND UNIT 2 - LEAK RATE DATA FALSIFICATION 7

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~*

8 9

Nuclear Regulatory Commission Fifth Floor Hearing Room 10 East West Towers 4350 EastJWest Highway 11 Bethesda, Maryland 12 Tuesday, October 7, 1986 7~,

'( )

13 The hearing in the above-entitled matter convene 6'at 74 9 00 5

16 BEFORE:

17 JUDGE JAMES L.

KELLEY, Chairman Atomic Safety and Licensing Board 18 U.S.

Nuclear Regulatory Commission Washington, D.

C.

19 JUDGE JAMES H.

CARPENTER, Member Atomic Safety and Licensing Board 20 U.S. Nuclear Regulatory Commission

-Washington, D.

C.

JUDGE'GLENN O.

BRIGHT, Member 22 Atomic Safety and Licensing Board U.S.

Nuclear Regulatory Commission 23 Washington, D.

C.

24 O

25 l'

ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336 4 646

3008 h--1 APPEARANCES:

2 On behalf of GPU Nuclear Corporation:

3 ERNEST L.

BLAKE, JR.,

ESQ.

JOHN N. NASSIKAS III, ESQ.

4 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.

C.

20036 5

On behalf of the Employees:

HARRY H. VOIGT, ESQ.

7 MICHAEL McBRIDE, ESQ.

LeBoeuf, Lamb, Leiby & MacRae 8

1333 New Hampshire Avenue, N.W.

Suite 1100 9

Washington, D.

C.

20036 10 On behalf of Jack Herbein:

JAMES B.

BURNS, ESQ.

yy Isham, Lincoln & Beale Three First National Plaza 12 Chicago, Illinois 60602 13 CHRISTOPHER W.

FLYNN, ESQ.

Isham, Lincoln & Beale

~

14 1150 Connecticut Avenue, N.W.

Washington, D.

C.

20036 15 On behalf of Gary P.

Miller:

16 MICHAEL W.

MAUPIN, ESQ.

17 M.

CHRISTINA HENSLEY, ESQ.

Hunton & Williams 707 East Main Street 18 Richmond, Virginia 23221 19 On behalf of Former Metropolitan Edison Employees:

SMTIH B.

GEPHART,'ESQ.

21 Killian & Gephart 217-218 Pine Street 22 Box 886 Harrisburg, Pennsylvania 17108 23 On behalf of the NRC Staff:

24 p()s JACK R.

GOLDBERG, ESQ.

MARY E.

WAGUER, ESQ.

25 U.S.

Nuclear Regulatory Commission Washington, D.

C.

20555 ACE. FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coverage 800-336 4646

3009 h-1 CONTENTS WITNESS EXAMINATION 3

Theodore F.

Illjes by Mr..Gephart 3010 4

by the Board 3013 5

William T. Conaway, II by Mr. McBride 3096 6

by the Board 3099 7

RECESS:

8 9

10 LAY-IN -

PREPARED STATEMENT OF ILLJES, Follows Page 3010.

11 LAY-IN - PREPARED STATEMENT OF CONAWAY, Follows Page 3097.

12 13 14 15 16 17 18 19 20 21 22 23 24 O

25 ACE-FEDERAL REPORTERS, INC.

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PROCEEDINGS 2

(Discussion off the record.)

3 JUDGE KELLEY:

Mr. 111jes is with us this morning; 4

correct?

5 Whereupon, 6

THEODORE F.

ILLJES 7

was called as a witness and, having first been duly sworn, 8

was examined and testified as follows:

9 EXAMINATION 10 BY MR. GEPHART:

4 11 Q

Mr. Illjes, you have before you a five-page

()

12 document entitled " Prepared Statement of Theodore F.

Illjes"?

13 A

Yes, sir.

14 Q

That's your prepared statement, sir?

15 A

Yes, sir.

16 Q

Are there any additions or corrections you would 17 like to make at this time?

18 A

No.

19 Q

Would you like the statement bound in the record i

20 as your statement?

21 A

Yes, sir.

22 JUDGE KELLEY:

Fine.

Your statement will be bound 23 in the record at this point.

24 (The document follows:)

25 l

ACE-FEDERAL REPORTERS, INC.

202 347-3ht)

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION

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BEFORE THE PRESIDING BOARD

)

In the Matter of

)

)

INQUIRY INTO THREE MILE ISLAND

)

Docket No. LRP UNIT 2 LEAK RATE DATA

)

FALSIFICATION

)

)

PREPARED STATEMENT OF THEODORE F.

ILLJES My name is Theodore F.

Illjes.

I live in Hershey, Pennsylvania.

I began working for Metropolitan Edison Company in 1971, and am still employed at TMI-2 by GPU Nuclear

()

Corporation.

I became a Control Room Operator (CRO) at Three Mile Island Unit 2 in 1976 and at the present time I am a shift Supervisor.

Between March 1978 and March 1979 I was assigned to "B"

shift.

My shift supervisor was Joseph Chwastyk, my foreman was William Conaway, and my fellow CRO's were Charles Mell and John Kidwell.

I graduated f rom high school in 1961.

I attended Colorado State University for two years.

I worked briefly for the Forest Service, then spent seven years and three months.in the Navy Nuclear Submarine Program.

In 1971, I was hired by Met Ed.

I first went to work at the Crawford Coal Station in Middletown, Pennsylvania.

I spent a few months there, then O

i went to Three Mile Island.

I began at Unit 1 as an auxiliary (3

(_ >

operator, and moved to Unit 2 in CRO training in 1975.

I was a CRO in Unit 2 until late 1979, when I became a radioactive waste shift foreman.

Six months later, I went back to the Control Room as a shift foreman, and later was promoted to the position of shift supervisor.

CRO's generally ran the plant under the direct supervision of a shift foreman.

The CRO's on my shift and I would usually take turns performing the various responsibilities required.

One of us would log in and control the panel while the other would do the switching and tagging, run surveillances, and do paperwork.

During some shifts we had a third CRO or a trainee who would help out.

Performing leak rate tests was part of the CROs' responsibilities.

At least one leak rate test was usually, but' not always, run every shift.

I do not remember, now, the specific procedures required to conduct leak rate tests.

I do recall that I did not rely on l

l the leak rate test as the only indicator of leakage.

It would appear, now, that the leak rate test procedures I followed were not always in strict compliance with the requirements imposed on us, in that I usually discarded test.

l results showing unidentified leakage greater than one ijpm.

l l

These tests were discarded if the test was invalid, once the I

result leak was identified and corrected or a satisfactory test i

obtained.

During 1978 and 1979, I thought it sufficient to

)

J l

l l - _

obtain at least one leak rate test result below one gpm during

()

a 72-hour period.

Once that result was obtained, the 72-hour clock would start again from that point.

If we had not gotten a satisfactory leak rate test result during a seventy-two hour period, I-would have shut the plant down, or recommended that it be done.

I always avoided adding water during leak rate tests, if possible, because that could affect the results.

If water had to be added for some reason during the hour-long test we would note it in the CRO log and on the computer sheet.

Sometimes, inadvertently, this was not done.

I was not aware of anyone ever deliberately adding water to manipulate the leak rate test.

I am certain that I did not know before the accident that the leak rate test could be affected by adding hydrogen to the

\\-

makeup tank.

I do not recall ever discussing this matter with my shift supervisor, Mr. Chwastyk.

I also do not recall h

participating in an experiment to determine the effect of

[-

adding hydrogen during a leak rate test.

I believe that when f

Mr. Chwastyk performed his experiment he did not involve me or l

all of the members of my shift.

I am aware that my shift foreman, William Conaway, has no recollection of this event.

My fellow CRO,I Charles Mell, also does not recall witnessing a hydrogen experiment or being told to avoid adding hydrogen i

during tests.

I am certain, however, that I did not add hydrogen to manipulate leak rate tests.

If it was added while I was performing a test it was presumably because the system O -

needed it.

I believe we logged hydrogen additions when we were

,,)

not too busy with other matters, but a lack of communication between the auxiliary operators and the control room could have resulted in a failure to log the additions.

My failure to understand the makeup tank's problems is shown by the fact that I signed only one test where I received an alleged benefit because of an error in the system in calculating a water addition.

In my opinion, I have been unfairly accused of improper conduct, despite the almost total lack of evidence to support the accusations.

I did not have the motivation or inclination in 1978 or 1979 to manipulate leak rate tests.

I have also been accused of performing leak rate tests knowing that the result would be meaningless, because the test iO relied on a faulty transmitter.

I do not recall a problem with a fluctuating transmitter, and I do not recall discussions about the use of this transmitter as a way to falsify tests.

I think it would have been obvious to me that you could change the result of a leak rate test by switching transmitters during the test, but I never did this.

I could, however, have missed the fact that an oscillating transmitter was reading.to the computer, and failed to see that the numbers on the computer printout did not match the strip chart.

In summary, the allegations made about the performance of leak rate tests at TMI-2 do not fairly apply to me, except that I did discard leak rate tests with over 1 gpm of unidentified

[

(

_4_

We discarded those tests because we did not believe leakage.

(m) the results, which were inconsistent with our perception of actual leakage.

We did not discard those tests because we were trying to deceive the NRC, and we would not have operated TMI-2 if we thought we were doing so in an unsafe manner.

My license is very important to me.

I believe that my diligent performance of my duties, particularly since the TMI-2 accident, should lead to the conclusion that I have learned valuable lessons from this experience.

I am aware of the absolute necessity for strict compliance with the technical specifications and plant procedures.

I believe that I should be permitted to retain my license without sanctions of any kind.

I can assure the Board that if I am exonerated, I will give the Commission and my employer no cause to regret that decision. ;

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THE WITNESS:

Thank you.

2 JUDGE KELLEY:

Mr. Illjes, I have a short 3

statement that I'm reading into the record to the witnesses 4

as they appear just to provide you with some context for our 5

questions to you.

6 The Board has been charged by the Commission to 7

determine the extent of involvement of individual employees 8

at TMI-2 in '78 and '79, in leak rate test falsification and 9

other-improper practices in leak rate testing.

This is your 10 opportunity to state on the record your recollections and 11 perceptions about your involvement in leak rate testing at

(

12 that time, and to rebut any adverse statements about you by 13 other employees or investigators with.which you disagree.

f 14 We have reviewed your prefiled testimony and 15 considered itein the light of the record that has already 16 been developed in this proceeding. lie will have questions t,

17 for you based on your testimony and upon your prior 18 statements that are already in the record.

We may also have 19 questions based on statements of other employees at TMI-2 20 that they have made about you or about matters you were 1

21 involved in, either previously or in connection with prepared 22 testimony for this case.

23 We may also have questions about assessments that j

24 investigators and technical experts have made about your 25 participation in leak rate activities.

I

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As I think you know, there are extensive studies 2-of TMI-2 leak rate procedures and practices that have already 3

been placed in the record, one by Mr. Stier that was 4

conducted for GPU Nuclear, and another study by the NRC 5

Staff.

6 The Stier study includes analyses of every leak 7

rate test conducted at TMI-2 that was retained, that is to 8

say, that was not thrown away; and the NRC study includes 9

analyses of every retained test during the last six months of 10 operation.

11 The Board has already heard extensive technical

)

12 testimony on leak rate testing questions, including testimony 13 elicited by your counsel on numerous particular tests.

In 14 these circumstances, the Board does not propose to review 15 with you each test which the investigative studies indicate 16 you were involved in one way or another.

Those studies have 17 been available to you through counsel and you were free to la discuss particular tests in your prepared testimony, if you 19 chose to do so.

20 We may ask you questions about particular tests, 21 tests that have special significance, apparently, for your 22 participation.

But apart from that, the ar.alyses of all the 23 !

tests, whether or not they are addressed here, will be 24 considered in light of the entire record, including your gg V

25 testimony today.

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With that, I forgot to introduce myself.

My name 2

is Kelley.

On my right is Judge Glen Bright, and on my left, 3

Judge James Carpenter.

Judge Carpenter will begin with some 4

questions for you.

5 EXAMINATION BY THE BOARD 6

BY JUDGE CARPENTER:

7 Q

Good morning, Mr. Illjes.

8 A

Good morning, sir.

9 Q

Looking at your prefiled statement, it says at the 10 present time you are a shift supervisor?

11 A

That's correct.

p).

(_.

12 Q

Are you still licensed by the Commission?

13 A

Yes, sir.

14 Q

What license do you hold?

15 A

A license in the Unit 2 facility at Three Mile 16 Island; that is a senior reactor operator's license.

17 Q

So you now have a senior reactor operator's 18 license?

19 A

Yes, sir.

It is, restricted to cold shutdown.

20 Q

I see.

We are going to focus this morning on the 21 time period 1978 to 1979, so with every question I won't say 22 "in 1978 or 1979," but it is implicit in each and every 23 question.

l 24 In 1978-1979, did you hold an operator's license?

25 A

Yes, sir.

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Q In contrast to a senior operator's license?

2 A

I held a control room operator -- reactor 3

operator's license.

4 Q

As I read the license, it says:

"In manipulating 5

the controls of the above facility, or facilities, the 6

licensee shall observe the operating procedures and other 7

conditions specified in the facility license."

1 8

Would you agree with me that that's an accurate 9

statement of what appears on your license?

10 A

Yes, sir.

11 Q

Now I would like to turn to this leak rate

()

12 surveillance test.

You should be aware that the Board is 13 very conscious that there were many, many other duties that 14 you had to carry out and the fact that we only ask questions 15 about the leak rate test does not mean we are not conscious 16 of the fact that this isn't the only thing you did for eight 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> when you were in the control room.

We are very much 18 aware of that.

This was one item in a series of items that 19 you were responsible for.

l 20 l I would like to get some feel for the leak rate i

21 '

test situation.

Did you consider the leak rate surveillance 22 ;

test as what I'll call a routine administrative task rather 23 than a -- something that was essential to the safe operation 24 i of the plant?

Do you see the distinction, first of all?

Os s

l 25 1 A

I believe -- excuse me -- it was an operation that ACE-FEDERAL REPORTERS, INC.

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was considered quite cumbersome and the difficulty it took to 2

perform it was an interference with other operations which 3

were required at the time.

4 Q

That, I think, speaks more to the mechanics.

I 5

was trying to get some feel for what you thought the 6

significance of the test was.

Was it more just paperwork or 7

was it something you needed to do as a licensed operator?

8 A

Well, the way I considered it now and the way I 9

considered it then -- then, I would have to say it was 10 something we, or I considered as you had to -- something you 11 had to take care of.

I would say my feeling.of it, at the

()

12 time, was it was an administrative requirement.

It had to be 13 taken care of and at the time the importance -- I didn't 14 place the importance on it that I should have.

15 Q

Do you think it might have been different if you 16 hadn't run it so routinely?

Under the technical 17 specification requirement you only had to run one every 72 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />.

Do you think it might have been different if it 19 wasn't so regular?

20 A

I can't say.

21 Q

Was the leak rate test required by the technical 22 specifications?

23 A

Yes, sir.

24 Q

So it did fall under the conditions of your g-)

V 25 license?

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1 A

Yes, sir.

2 Q

Did you conduct other surveillance tests that were 3

not required by the technical specifications?

4 A

Yes, sir.

5 Q

In your mind, once again in the time frame 6

1978-1979, what was, in your mind, the significance of a 7

surveillance test being either in the technical 8

specifications or not in the technical specifications?

There 9

were two kinds of tests, one covered by your license and many 10 others not covered by your license.

11 A

For me to remember back then it would be difficult f3

(_/

12 to say.

I would say now I considered the ones that were 13 technical specification-oriented or required would be more 14 important.

I can't say what I thought back then because I 15 don't remember.

16 Q

Well, if you had the feeling that you have today 17 then, do you think you would remember?

Were you taught that 18 the things required by technical specifications should be 7

19,

viewed differently?

Once'again, talking about on-the-job l

20 training in '78 and '79?

21 A

I can't -- I would say there was more importance 22li

.placed on surveillances that were required by technical I

23 !

specifications.

24 Q

Well, given that, on what basis did you conclude 25 that the technical specification requirements for ACE-FEDERAL REPORTERS, INC.

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measurements of unidentified leakage were not essential for 2

safe plant operation?

d 3

A The surveillance was something that we were 4

required to do, but I'd say the tool we were given to do it 5

with was a difficult thing to get an answer that made sense.

6 And it was, I guess you could call it irritating or -- I 7

don't remember exactly how I felt about it, but it was 8

something that you did quite often.

We did -- there was 9

usually one on -- we used the computer to take the 10 surveillance and we punched in the numbers on the computer.

11 It tied up the computer for a certain period of time.

()

12 Q

Well, you say it was difficult to get a 13 satisfactory result, and I think it's natural that that 14 should be a point of irritation.

So you did find the test a 15 little irritating?

16 A

Yes, sir.

17 Q

I don't think your attitude is any different than 18 other people whom we talked to about the situation.

While 19 you found it difficult to use this tool, would you say that 20 the tool had deficiencies?

21 A

Yes, sir.

22 Q

It was less than a perfect tool?

l 23 A

I'd say it was.

24,

Q Why didn't you ever file an exception or a s

I 25 '

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1 that in your eyes the test was deficient?

2 A

I believe it had to do with the means by which we 3

did the surveillance.

It was something that you didn't have 4

-- in other words -- when we did a surveillance, we had a i

5 procedure that went step by step.

In other words, open such 6

and such valve and line up such and such system and it was a 7

sign-off thing.

If you didn't meet a certain acceptance 8

criteria, then you could put in an exception or deficiency 9

sheet.

10 The leak rate was a routine thing and it didn't 11 have a -- say, a surveillance printout in which you took and

)

12 got a procedure and then went over and signed it step by 13 step, performed something on a computer.

I believe we should 14 have used the exception and deficiency sheets, but we 15 didn't.

I really don't have a reason why, except that it was 16 a different method of doing a surveillance.

17 Q

Let me be sure I understand.

It is my impression 18 from what you just said, and from the record to this point, 19 that this surveillance test was mechanically different in 20 that what you got was a piece of paper from the computer 21 printout and it didn't have exception and deficiency boxes on 22 it; is that the essence?

23 l A

Well, there was no procedure that we used.

It was 24 a routine thing.

There was a leak rate procedure that was 3

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was something that we did so often we weren't -

we didn't 2

have to go to the procedure file drawer and pull it out.

3 Q

Plus all you had to do was punch the button on the 4

computer?

5 A

Right.

6 Q

Instead of getting the procedure out and following 7

it.

Is that fair?

8 A

There were certain steps written on the computer 9

sheet which you would add -- take into account for water 10 added'or water.taken away, but it was very brief.

11 Q

In your mind, and this is entirely hypothetical,

()

12 do you think if that computer sheet had had satisfactory, 13 exception, deficiency boxes on it, the way the other cover 14 sheets for surveillance tests had, that you might have 15 utilized that?

16 A

Well, I think if I was made more aware of the --

17 say, the importance of the test and that it was important to 18 meet certain criteria of the test, it would have meant a lot 19 more to me and I would have been more diligent in taking care h

20 of meeting the requirements of the test, including an 21 exception and deficiency sheet.

22 Q

Well, this is what I keep puzzling about.

If I 23 wanted to indicate to somebody that I thought the test was 24 important, vis-a-vis something I thought was useful, 25 desirable, that might be the basis for deciding which test to ACE-FEDERAL REPORTERS, INC.

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put in the technical specifications and which tests not to.

2 Does that the seem logical?

From a safety point of view and 3

in terms of this regulated activity, the tests that were 4

thought essential for safe operation were put in the 5

technical specifications, as I understand it.

So, what I'm 6

puzzled about is, given that the technical specification 7

existed, how did you feel that it was an unimportant test?

8 A

Like I said, it was -- I have to admit, it was a 4

9 paperwork requirement.

I would say I treated it as such.

10 But, we had other indications which would give us 11 information, good information of leakage, even though we were

()

12 required to do a leak rate.

But we had radiation monitors 13 and level indicators and there were many other methods by 14 which we could detect leakage.

15 Q

Would you say the radiation monitors would give 16 you a quantitative estimate of the leakage?

If you look at 17 the radiation monitor, you could say, oh, the leak is half a 18 gallon a minute?

19 A

No, sir.

I don't think we were set up to do that, 20 then.

21 Q

Was there any other procedure that would give you 22 a quantitative estimate of unidentified leakage?

23 A

The leak rate procedure itself had a manual 24 performance in it.

It was a lengthy thing.

25 Q

Lengthy --

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A A lengthy procedure.

2 Q

Did you ever do a manual calculation?

3 A

I don't recall specifically doing a manual 4

calculation but it's possible that I did.

4 5

Q Was it your perception that much of the problems 6

with the leak rate tests were somewhat associated with the 7

computer?

{

8 A

Yes, sir.

9 Q

Did you.ever consider doing one manual calculation 10 to see if you would-get the same answer as the computer had?

i 11 A

Like I said, it's possible that I did a manual

'( )

12 calculation but I don't recall specifically right now.

t 13 Q

What we are, in particular, perplexed by, is why 14 there was never any operator who documented that there was a 15 deficiency in this test in writing to the point that the i

-16 technical support group would have to pay attention.

For 17 example, if you had a computer printout and a manual 18 calculation and they didn't give the same answer, I would 19 think somebody would have to resolve that deficiency.

You I-20 could have taken the source of irritation away.

21 A

I believe there was a method -- I don't know how 22 far along it was -- to take care of the problem that was in 23 the calculation in the computer.

We had a computer engineer i

24 who, I believe, was working on it at the time.

25 Q

You say a computer engineer --

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A He changed the numbers around a couple of times 2

but I don't believe that helped us any.

3 Q

You say a computer engineer?

4 A

I think his name was Fels.

5 Q

Was he also a mechanical engineer?

Electrical 6

engineer?

7 A

I'm not sure, sir.

8 Q

Or someone simply trained in computer utilization?

9 A

I don't know his training, sir.

10 Q

You made the assumption that he was going to solve 11 your problem, though?

'( )

12 A

He was the one that took care of the calculation 13 in the computer, to my recollection.

14 Q

Would you say that, in the time period '78 and 15 perhaps to a greater extent in '79, with the passage of time, 16 that you developed a certain amount of cynicism or 17 hypocritical attitude towards this test?

On page 5 of your 18 prefiled, the top of the page you testified:

"We discarded 19 l those tests because we did not believe the results."

Would 20 it be fair to say that's a little bit cynical, a little 1

I 21 hypocritical, you did the tests but you didn't believe them?

22 A

I don't know if you would call it cynicism or 23 hypocritical, but if the level is going down and you had a 24 negative leak rate, the level being an indicator of the water 25,

in the reactor coolant system and the leak rate if it's p

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negative, the makeup tank level ought to -- in other words, 2

if you didn't have any leakage, the makeup tank level should 3

stay a straight line.

4 Q

Yes.

5 A

Or you should have -- you know -- the water 6

inventory should have stayed the same.

7 Q

Well, that's a good point.

Would you turn in 8

those books there in front of you, or in the copies of the 9

NRR test, would you turn to test 123, please.

There are four 10 pages with the numbering 123 in the upper right corner.

11 A

Yes, sir, I have it.

()

12 Q

Please take a moment to look them over.

13 I beg your pardon,.my eye skipped.

I would really 14 Jike to start with test 147, which should be in the same 15 book.

They are in numerical order.

We'll.come back to 123 16 in a minute.

17 A

Dated 3/14/79?

18 Q

That's correct.

19 I think you have looked through it?

20 A

Yes, sir.

21 Q

First of all, first page, bottom left-hand corner, 22 is that your signature?

23 A

Yes, it is.

24 Q

As we sit here, looking at these pieces of paper 25 with your signature on them, is it fair to say that by ACE-FEDERAL REPORTERS, INC.

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signing it you are taking responsibility for having either 2

conducted all the test or most of the test or at least 3

reviewed the test and in your opinion it is satisfactory to 4

you?

Is that what the signature represents?

You signed off 5

on it?

6 A

I would say that's the way I feel about it today.

7 Then, it was:

I performed the test.

I did the test or I was 8

the one that took it off the computer and signed the 9

paperwork.

10 Q

So that you were responsible for the accuracy of 11 the test?

()

12 A

Well, there was sometimes more than one person 13 involved in the test.

14 Q

That is what I'm trying to get a feel for.

They 15 didn't sign the piece of paper.

16 A

No, it could have been done half on this shift and 17 half on the last shift or it could have been done by another 18 operator and I just happened to be there when it printed out.

19 Q

If all you had to do was tear it off the computer r

20 and give it to somebody, why would you bother to sign it?

21 A

I don't have a reason.

In other words, we looked 22 l at it, it was -- the test was complete --

23 l Q

So the implication is that you did look at the

(

24 test and accept it?

25,

A Well, sure we want to look -- if the test looks l

ACE-FEDER.AL REPORTERS, INC.

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abnormal and, say, there's something -- abnormal, also, if 2

you refer to the makeup tank or drain tank or say there would 3

be leakage, we would want to do something about it.

4 Q

A few minutes ago you happened to raise the issue 5

of negative leak rate test results and this happens to be an 6

example, so I thought it would follow along pretty well.

7 Turning over to the strip chart --

8 JUDGE KELLEY:

Can I just ask one thing?

9 JUDGE CARPENTER:

Yes.

10 BY JUDGE KELLEY:

11 Q

If you signed this test when it came out of the O(_)

12 computer, does that tell us at a minimum that you did the 13 calculations that the computer asked you about?

For example, 14 water additions?

15 A

Not necessarily.

16 Q

It doesn't even mean that?

17 A

I would say I normally did that.

In other words, 18 somebody could have entered -- let's see, when the 19 calculation was done you entered the water additions in.

n 20 Q

At the end of the test?

21 A

But it could have been printed and sat there and 22 somebody entered the amount of water and it might have sat 23 there and didn't get signed and somebody else signed it.

24 There was no requirement to say:

We started the test and 25 finished the test so we have to sign it.

We were never told ACE-FEDERAL REPORTERS, INC.

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that we had to do the whole test in its entirety and, by 2

signing it, that we were saying the test is accurate.

I 3

never was told that.

4 Q

But you are saying that you were not, by signing 5

it, in your opinion at that time, certifying the accuracy of 6

the test?

7 A

I would say it was my responsibility, if I signed 8

a piece of paper, that I had a certain responsibility to 9

assure that the test was -- met requirements and it was my 10 responsibility.

Although I have to say that there were some 11 things that were left that should have been done that we

()

12 didn't take care of.

In other words --

]

13 Q

All I'm trying to do is nail down what the 14 signature means.

I suppose it can mean everything from --

15 A

When you sign your name to -- I forget how many 16 times a day, maybe today I sign my name 50 times a day, up to 17 50 times a day on different piecee of paperwork.

And I don't 18 know how many times I signed my name back then, but it was 19,

often.

Now you want to look at certain things, certain 20 things that are required to meet the requirements of a 21 l

procedure.

But back then I would say I should have been a 22 little more diligent in looking at some of the requirements 23 in meeting, particularly in this leak rate.

I 24 Q

What I'm trying to nail down, when I first looked 25 at a sheet like this and I understood generally what it was ACE-FEDERAL REPORTERS, INC.

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and I saw a signature next to the word " operator," I thought 2

it meant:

Okay, this is the guy who ran the test and he's 3

certifying it, saying, I ran this test and I think it's 4

okay.

To the best of my knowledge it's an accurate test.

5 Now, as I understand it, you are saying that maybe 6

someone else did portions of the test and you may have come 7

on and signed it as operator, not having done all of the 8

steps; is that correct?

9 A

Yes, sir.

10 Q

But even if you didn't do all the steps, let's 11 suppose somebody else did a water addition and suppose you O)'

(_

12 are the surveillance operator, and somebody else is on the 13 panel and the water addition is done by somebody else; I 14 assume that the operator, when he signs it, would find out 15 whether or not such an addition was made and included in the 16 calculation.

Is that fair?

17 l A

He should have.

But it got busy.

And it's l

18 I possible that he might have forgot to add it in, but then 19 your calculations would have been way off.

20 Q

I got the impression this morning that at least on 21 some occasions in your experience -- I don't know that we are 22 describing this particular test -- but do I understand you 23 !

correctly to say that there might have been occasions when l

24 you would have just simply have signed it just to get a s

25 signature on it without doing any review of the numbers or ACE-FEDERAL REPORTERS, INC.

202-347 37m Nanonwide Coserage 80lL336-6646

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look at the makeup strip chart or anything else; just put 2

your name on it and file it, if it said less than 1 gallon 3

per minute?

4 A

I would say there were times that I did that; yes, 5

sir.

6 BY JUDGE CARPENTER:

7 Q

Mr. Illjes, if you turn now to the strip chart 8

record, would you say even by glancing at the record that 9

you, as an experienced operator, would say that there was a 10 substantial leakage occurring?

11 A

Yes, sir.

Each vertical upward trend is water n(,)

12 addition and the slope downward is the indication of water 13 leakage.

14 Q

In the middle of this time interval that's marked 15 off, marked as leak rate test 147 just a little bit to the 16 right of the center of the page, in the middle of that there 17 are sharp, vertical movements of the pen on the strip chart 18 recorder that, apparently, are associated with water 19 additions?

20 A

Yes, sir.

That's correct.

21 Q

The procedure says, as I read it, that water 22 additions should be avoided.

It does not prohibit them, but 23,

says they should be avoided.

Why do you think the procedure 1

24 writer encourages you but does not unequivocally prohibit the 25 addition of water?

Why would the procedure writer think it ACE-FEDERAL REPORTERS, INC.

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was undesirable?

2 A

Well, he would like to keep the plant at steady 3

state in order to get a leak rate.

I don't know all the 4

software of the computer, but apparently it calculates 5

between two intervals and the more intervals that_you -- more 6

changes that you put into it, it has some effect.

I'm not 7

familiar with what effect it has.

8 Q

Isn't there always the possibility that you might make an error in entering the amount of water added, to the 9

4 10 computer.

So, if you make water additions then you've got an 11 additional responsibility --

N 12 A

That's correct.

13 Q

-- to faithfully tell the computer what you did?

14 A

You had to ask the man on the panel if he added 15 any water.

16 Q

Did that thought occur to you at the time?

We are 17 straining your memory -- if I make a water addition in the 18 middle of the test then I have to tell the computer that I 19 did it and I have to do it accurately?

20 A

I don't recall any specific thoughts of --

21 Q

Was there any reason, since you seem to be 22 conscious of the fact that the procedure, and common sense, 23 suggest that you must have steady state to get a leak rate 24 test with a sensitivity of less than a gallon per minute, in 25 terms of that being an accurate reflection, I'm mystified ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Cos erage 800-3?6-6646

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why, if you -- and it seems that others were aware of the 2

requirement for steady state -- why, in performing the leak 3

rate test, you didn't look at the water level, add enough 4

water so you could be reasonably confident you wouldn't have 5

to add it during the hour, and then run the test?

6 A

Well, the water requirements were for -- one would 7

be for inventory; another requirement is for boron.

If the 8

rods were close to being out and T av started dropping off 9

and power started peeling off, you would have to do something 10 about it, which meant putting water in.

11 Q

My point is, why didn't you get the rods in

()

12 position, by adding water, where you were reasonably 13 confident that for 60 minutes you weren't going to have to 14 add water?

15 A

I agree.

That's the way it should have been done, 16 but I don't remember the specific instances.

It was not an 17 atmosphere where you could say that you would have an hcur of 10 steady state.

There was always something going on.

That's 19 the way I remember ~it.

20 Q

But of course that's the frustration, that's my 21 point.

If you notice you have to run this thing every shift, 22 you can't get steady state, which the procedure calls for all 23 the time, but people went right ahead and ran it every shift, 24 l right square in the face of the procedure's precaution:

. g-)g

\\.

?

25 l Ensure steady state and then run the test --

i o

ace-FEDERAL REPORTERS, INC.

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4 1

A I agree.

That's the'way it should have been done.

2 Q

The procedure says you run this test and run it 3

under steady state.

It's just a mystery to me how anybody 4

could misinterpret those simple instructions.

5 A

The word was "should."

And they define those 6

.words for.us now.

Thei didn't back then.

7 Q

But, as a licensed operator --

8 A

But "should" now is defined like:

It's okay, but 9

don't do it if you don't have to do it.

10 Q

Can you imagine getting a valid leak rate test 11 when you didn't have steady state?

I) 12 A

I have to say that leak rate test was -- I would 13 say it was hard -- it was something that was difficult to 14 believe.

15 Q

Or something difficult to do?

16 A

It interfered with some other things, I would 17 say.

But it was not difficult to do.

It was difficult l

18 getting the results that were required.

I j

19 Q

That never made you feel that maybe you where l

20 doing it the wrong time?

21 A

I don't know if I felt that way.

I don't recall 22 feeling that way.

l 23 Q

Turning back to the test, apparently you agree 24 with me, just eyeballing this from just a quick inspection, 25 it's pretty clear that there was a substantial gross ACE-FEDERAL REPORTERS, INC.

202 347 3N1)

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leakage?

Water level kept continually going down, 2

replenished by water additions, continued to go down at a 3

fairly substantial rate, several gallons per minute?

4 A

Yes, sir, s

5 Q

And I think you told me that you, as an operator, 6

were usually pretty confident that there wasn't a substantial 7

-- of the order 1 gallon per minute -- unidentified leakage, 8

primarily because you were aware of the water level in the 9

makeup tank.

You looked at the strip chart recorder.

As

(

10 part of your activities, you kept an eye on the water level.

11 A

We were aware that there was leakage.

There was O

ts/

12 leakage into the drain tank from --

13 Q

No.

But my point is that you and others have 14 said:

This leak rate test was a "no, never mind," because 15 other indications indicated that there wasn't a big 16 unidentified leak.

And it would seem to me that the primary 17 source of those other indications would be your eyeball 18 inspection of the makeup tank level.

If it was horizontal, 19 no matter what the test showed, you would feel that there 20 really wasn't a leak?

21 A

I'm saying you had other indications besides the 22 makeup tank.

You are saying identified and unidentified?

23 i Q

Right.

24 A

Oh, you could identify the leakage through the

\\'

25 drain tank.

ACE-FEDERAL REPORTERS, INC.

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Q Yes.

Which one did you put more faith in?'

2 A

Which one?

As far as the visual versus the 3

-calculation?

4 Q

Yes.

This general notion that there wasn't "a big 5

leak and you knew it --

6 A

I'm not saying -- we knew we had leakage.

But we 7

didn't know we had -- we had difficulty calculating and 8

getting a number because of the method used.

9 Q

okay.

10 A

The method'used with the leak rate calculation.

11 Q

Well, turning back to the first page of this

()

12 test --

13 BY JUDGE KELLEY:

14 Q

Can you just ask this question:

Did you or did 15 you not put any reliance on the strip chart of the makeup 16 tank in order to give you some indication of unidentified i

17 leakage in the plant?

18 A

Yes, sir.

19 Q

You did?

20 A

Yes.

There's good -- there's reliance there that 21 you can use that as a tool.

22 Q

You would look at that?

23 A

Yes.

24 JUDGE KELLEY:

All right.

25 BY JUDGE CARPENTER:

1 ACE-FEDERAL REPORTERS, INC.

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Q Turn back to the first page of this group marked 2

147.

I read that the gross leak rate was minus 6.7 gallons 3

per minute.

I refuse to believe that anybody knew that leak 4

rate to five significant figures, which is a surprising 5

number.

And the total identified leakage, if I read this 6

correctly, is minus 6.4 producing a result for net 7

unidentified leakage of minus

.24.

Just looking at that now, 8

could that have any possible relationship to actual plant 9

conditions?

10 A

It doesn't, by looking at the strip chart; no.

11 Q

But how about just looking at the numbers?

()

12 A

It doesn't look like a real number.

13 Q

What?

14 A

No.

It doesn't look like a real number.

15 Q

Well, in the context of realizing you had a lot of 16 things to do and so on -- but this seemed to me to'just be, 17 if you were ever going to say Look, there's an error --

18 A

We knew --

19 Q

There's a reason to question the test, 6 gallons a i

20 minute past the threshold?

21 A

We did question the test.

I 22 l Q

But you didn't question it enough to refuse to 23 sign it?

24 A

That's true.

The importance of the leak rate was 25

-- there was no emphasis placed on it, except satisfying it.

ACE-FEDERAL REPORTERS, INC.

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And that was the wrong emphasis.

2 Q

Well, you see, that's the problem we have.

The 3

technical specifications that you were responsible for seeing 4-were met, and the tool you were given, is this particular

-5 leak rate test.

It would seen on the face of it that not 6

only you didn't use the tool, you felt there were problems 7

with the tool, but you even were willing to say that, I know 8

I'm within the technical specification based on a test that 9'

gives minus 6 gallons a minute?

I question that you could 10 feel in your own mind that you knew what the leak rate was, 11 when you are telling me that it was minus 6 gallons a O

. (_j 12 minute.

13 Do you see the problem we have?

14 A

I have~a problem with it too.

15 Q

okay.

Would you say that turning in this leak 16 rate test was a violation of procedures?

i 17 A

In my -- now, I do.

Back then I don't think I 18 did.

i 19 Q

Well, I'm trying to see if you agree; this is your

{

20 chance.

We are face to face.

I look at this and I tend to l

21 say:

Look, this is a dead flat violation of procedure.

And 22 today as you look at the papers, could you see that one could 23 come to a different conclusion?

This is not a matter of f

24 memory; it's a matter of what you see in the pieces of O

25 paper.

4 t

ACE-FEDERAL REPORTERS, INC.

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1 A

That's just what I stated.

I see that there's a 2

' problem now.

I don't agree with it.

And I interpret the 3

tech spec completely different today as compared to then.

4 Q

Fair enough.

Thank you very much.

5 BY JUDGE KELLEY:

6 Q

One more question about this test 147.

You and 7

Judge Carpenter were talking earlier, this is a time when 8

apparently there's a fairly high amount of leakage going on, 9

judging by the numerous water additions and the slope of the 10 trace.

But this is a test where 500 gallons, quite a bit of 11 water, was added during the test; correct?

As a matter of

()

12 fact, 600 gallons were added and 500 gallons were put in the 13 calculation; is that correct?

14 MR. MC BRIDE:

Excuse me, Judge Kelley, could you 15 provide us with a record reference for the 600?

16 JUDGE KELLEY:

Looking at the strip chart, water 17 additions of 390 and 210; I add them up and get 600.

18 MR. MC BRIDE:

I think that's the effect of the 19 addition and not the amount that was added, Judge Kelley.

20 MS. WAGNER:

If you look at the log, I think that 21 will tell you the actual amounts added and the strip chart, 22 l as you recall, will reflect a larger amount.

23 JUDGE KELLEY:

It's not important to my question 24 anyway.

That's not what I'm after.

The actual amounts added O

25 were what, according to the log?

ACE-FEDERAL REPORTERS, INC.

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MS. WAGNER:

300 and 200.

2 MR. MC BRIDE:

At 1230 they added 300 and 1250 3

they added 200 for a total of 500.

4 JUDGE KELLEY:

Okay.

300 and 200 were actually 5

added.

I guess it was the makeup tank level indicator that 6

registered 290 and 310.

7 MR. MC BRIDE:

Apparently so.

8 JUDGE KELLEY:

Again, that is not critical to my 9

question.

10 BY JUDGE KELLEY:

4 11 Q

My question is this:

Why was it added at all

()

12 during that test?

4 13 A

I can only give you reasons why it possibly could 14 have been added.

I can't tell you.

15 Q

Well, looking at the chart now, is there an 16 operational rearon, totally unrelated to a leak rate test, 17 that necessitated the addition of the water?

18 A

The leakage was out of the relief valve on top of 19 the pressurizer.

20 Q

Okay.

21 A

Which tended to concentrate boric acid, which made 22 the concentration of boric acid in the reactor coolant system 1

23 >

more concentrated.

24 Q

Okay, O

t 25 l A

Which caused the rods to move out of the core.

ACE-FEDERAL REPORTERS, INC.

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Q Right.

Right.

2 A

When you got out a certain -- when the rods came 3

all the way out, the temperature would start to decrease to 4

maintain the same power level because of your negative 5

temperature coefficient.

At that time we had to borate -- or 6

deborate the RCS, by adding demineralized water.

7 Q

From the makeup tank?

8 A

It was 'added from the demineralized water system 9

through the makeup tank; yes, sir.

10 Q

And my question --

11 A

That would be one reason.

()

12 Q

You referred earlier to a rod control problem.

13 A

The other reason --

14 Q

I.et me ask you this, I'm just looking at this 15 chart and thinking of a simplified concept of makeup tanks.

16 I thought makeup tanks made up water needed in the main 17 system; isn't that correct?

18 A

Well, it's the place where we make up to.

19 Q

Is what would have been wrong, looking at the 20 slope of that makeup tank trace, even granting it is fairly 21 steep and there was a fairly high leakage problem, 22 apparently, at the beginning of the leak rate test it was up 23 just above 70; correct?

70 inches in the makeup tank?

24 A

Yes, sir.

O 25 Q

If you drew sort of a rough line up that slope and ACE-FEDERAL REPORTERS, INC.

202-%-47-37110 Nalionwidt C0% cf age 8 TID 33WM

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(^}BRT 28397.0 K-3039 1

projected it downwards, as has been done a couple of other 2

places on this strip chart, where would you come out, 3

approximately?

4 A-Probably under 60.

5 Q

Between 50 and 60?

6 A

I don't know if I would want to put a line on that 7

indication and say you could go from a pretty wide band 8

there --

9 Q

But if you look at the trend all the way across 10 the chart, I mean, are you suggesting that the trend would 11 take you under 50?

()

12 A

No.

But I'd say it would probably take you -- you 13 would be there at 60.

14 Q

All right.

Let's say between 50 and 60; is that 15 fair?

16 A

Yes, sir.

17 Q

All right.

Let's suppose it is 50.

Isn't that 18 plenty of water for purposes of rod control?

50 is a lot of 19 water, right, 50 inches of water in the makeup tank?

20 A

50 inches -- you have to take the overall volume 21 of the RCS, which was, I think when we were hot was somewhere 22 around 60-some thousand gallons.

So you needed enough water 23 to change the concentration of 60,000 gallons, which was --

24 l the only place you had to add that was into the makeup tank.

25 f Q

My point is this, the tank at 60 or between 60 and ACE-FEDERAL REPORTERS, INC.

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50 is over half full; right?

2 A

Yes.

3 Q

Okay.

I'm going to run a leak rate test and I'm 4

thinking:

Well, the procedure tells me not to add water when 1

5 I'm running a leak rate test.

It doesn't say I can't, but it 6

says it's not advisable.

Why can't I, perfectly prudently 7

and safely, wait until the leak rate test is over before 8

adding the water?

9 A

I believe we had an administrative requirement 10 which allowed us to go -- I think the minimum was 60 inches.

11 Q

What was the basis of that administrative

()

12 requirement; do you know?

13 A

I think it had something to do with so you had 14 enough time to run over -- if you had a leak somewhere you 15 had enough time to go over and start a makeup pump or allow 16 for volume changes during a trip.

17 Q

But just looking at this chart, these water 18 additions are pretty rapid.

You decide to put in 500 gallons 19 and, zoom, it almost goes straight up in a very, very short 20 period of time?

21 A

But a temperature change due to a sudden power 22 ;

change can have a certain amount of effect on the pressurizer i

23 which will -- in other words, you are putting a makeup pump 24

-- I'm not sure of the numbers, but I think it was somewhere 25 '

around 400 gallons a minute.

3 ACE-FEDERAL REPORTERS, INC.

202 347 3700 Nationw ute Coserage M1t k 3.16-fM6

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Q Right.

Okay.

2 A

Somewhere around there.

And that could go right 3

into the RCS out of the makeup tank.

4 Q

400 gallons a minute.

You can put it back in the 5

makeup tank at 400 gallons a minute too, can't you?

6 A

No, sir.

7 Q

Well, how fast can you put it in?

Look at these 8

slopes here.

Maybe that's a rough approximation but it looks 9

pretty fast to me.

These water additions are almost straight 10 up on the time line.

11 A

You'd have to get the chart increments and see how I )

12 many minutes, but I think you could --

13 Q

Well, look at the 500 -- excuse me, I guess it 14 was, according to the log, a 300-gallon addition during that 15 leak rate test, which would have taken place, according to 16 the strip chart, a little before 12:30.

17 A

So you had, say, 500 gallons, say it took 10 18 minutes, there's 50 gallons a minute; is that right?

Let's 19 see, 500 gallons, 10 minutes -- yes.

So you have 50 gallons 20 a minute there.

21 Q

Is that your recollection of the rate of addition, 22 50 gallons a minute?

23 A

You could -- you had a means of controlling the 24 addition.

You could make it 50 gallons a minute.

I think 25 the pressure on the demineralized water system was somewhere ACE-FEDERAL REPORTERS, INC.

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around 150 pounds.

2 Q

Are you saying if it could go out of the makeup 3

tank at the rate of 400 per minute and you could only get it 4

in at 50 a minute, then in case of some emergency you needed 5

to have a lot of water in there so it wouldn't go down too 6

fast?

7 A

Until you got to line up another tank.

8 Q

Other than the makeup tank as a source of feed 9

water?

Is that what it's called?

10 A

Right.

11 Q

It just strikes me, as a nontechnical layman, that

()

12 you are looking at a tank with an awful lot of water in it.

13 If you say you can't let the tank go below 60 inches, it 14 strikes me as wearing a belt and suspenders, too, against who 15 knows what problem, when you have another procedure that says 16 don't add water during a makeup tank.

I just don't see why 17 you can't wait.

I don't fully grasp it, I guess.

18 MR. MC BRIDE:

Judge Kelley, I know these are 19 difficult matters for people who aren't technically oriented.

20 JUDGE KELLEY:

We try.

21 MR. MC BRIDE:

I know you do.

You are trying very i

22 l hard.

I just want to suggest to you if you back through it l

23 one more time if you ask him about the problem of 24 concentration of boron as opposed to strictly just volume of 25 water.

If he can explain that to you one more time it might i

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help you understand that this isn't just a volume problem, 2

although volume has something to do with it.

3 JUDGE KELLEY:

I'm happy to listen.

Do you I

4 understand?

5 THE WITNESS:

I explained the' process in which you 4

6 dilute -- you take 600 gallons and, I don't know if you 7

understand by what percent you would dilute 60-some thousand

{

8 gallons.

9 BY JUDGE KELLEY:

l 10 Q

Not very much?

~

11 A

Right.

So it takes a lot of water in order to

)

f, ( )

12 dilute 60,000 gallons.

13 Q

Well, this phenomenon of fluctuations in the boron-14 concentration is fairly common, isn't it?

l 15 A

Yes.

We were doing it all the time.

It was -- in i

16 other words, you bleed -- say you put salt in a tea i

17 kettle --

\\

18 Q

Feed and bleed; is that designed to alter the 1

19 boron concentration?

Is that what that's all about?

i 20 A

We were trying to maintain the boron concentration 21 approximately the same.

We would use maybe one or two ppm; I i

[

22 think we were at maybe 8 or 9 ppa at the time of the

{-

23 accident, I don't remember the exact concentration.

But --

i l

I 24 Q

I have been looking at some of these feed and 25 bleed charts and I see these little blips on the, strip chart; I

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1 I don't see dramatic changes in the makeup tank.

Maybe that 2

happens.

Is there a time when you have literally emptied the 3

makeup tank in order to get the correct boron concentration?

4 A

No.

5 Q

What's your typical addition to affect boron 6

concentration out of the. makeup tank?

7 A

Maybe 3-to 400 gallons; sometimes 150 gallons.

8 You know, I'm looking.

9 Q

If it's in the range of levels of 50 gallons, then 10 what's the concern about keeping this thing above 60 inches, 11 or at 60 inches?

()

12 A

You would try to put as much as possible so you 13 didn't have to do it all the time.

In other words, you had 14 other things you wanted to look at._

You didn't want to be 15 involved in making additions to the water tank all the time.

J 16 That's the way I'd take it.

You had big additions so you i

8

~

17 only had to do the additions once or twice a shift.

18 Q

Well, but are you saying, then, that you wouldn't 19 think a leak rate test is sufficiently significant to i

l 20 counterbalance the convenience of periodic -- your regular, I

21 periodic additions of water to the makeup tank?

i l

22 A

I don't know if I know what you mean.

l 23 Q

Well, I thought you were suggesting that the i

24 operators would periodically during a shift add a lot of g-

\\J 25 water to the makeup tank?

Maybe you can make your point l

l t

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again.

I'm not sure I'm with you.

2 A

We added water because of a leak and that water 3

was directly.-- what went out we had to put back in.

4 Q

I understand that.

But you were talking about 5

frequency of addition of water to the makeup tank, I thought.

6 A

Right.

Well, some shifts might have put in, you 7

know, 150 gallons five or six times a shift and some shifts 8

might have put in, you know, 4-or 500 gallons twice a 9

shift.

Is that what you mean?

10 Q

What did your shift do?

What did your shift tend 11 to do?

()

12 A

I guess I would have to look at the strip chart.

13 It might have varied between operators or what time available 14 there was.

I don't think there was any set amount.

15 0

I would think under either procedure it would be 16 perfectly simple to avoid adding water during the leak rate 17 test.

If you were adding small amounto frequently you could 18 just skip it once and it didn't matter.

If you were adding 19 large amounts less frequently you could fit a leak rate test l

20 in between the additions, could you not?

21 A

Yes.

That probably could have been done.

22 JUDGE KELLEY:

Let's take a break.

10 minutes.

I 23 j (Recess.)

l 24 '

JUDGE KELLEY:

Back on the record.

I 25 DY JUDGE CARPENTER:

1 ACE-FEDERAL. REPORTERS, INC.

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1 Q

Mr. Illjes, one final question with respect to 2

test 147, which shows a remarkable gross leak rate of minus 6 3

gallons a minute.

Did you have~any indications, direct 4

instructions or inferences that you could draw from 5

attitudes, by either your foreman or your shift supervisor, 6

that if you got a leak rate test which had unidentified leak 7

rate less than 1 gallon per minute that you should submit it 8

whether it was negative or not?

9 A

I don't recall whether or not -- what you are 10 saying -- in other words, when I got a negative leak rate --

11 I know if I got a negative leak rate, positive leak rate, I

)

12 did the test -- in other words, now I'd sign it and turn it 13 in as " performed by."

14 Q

Did you feel any pressure to get test results less 15 than 1 gallon per minute?

16 A

I couldn't differentiate from one -- there were a 17 lot of other pressurca besides the leak rate.

I don't 18 recall.

In other words, such as what I discussed before, the 19 water inventory, that was important; the boron concentration 20 was important because you had to stay within a certain 21 control rod band.

I know that's difficult for you to 22,

understand.

23 Q

No, it's not.

I assure you it is not in the 24 !

least.

What's mysterious to me is accepting minus 6 gallons O

i 25 I per minute as believable.

That's what's mysterious to me.

ACE-FEDERAL REPORTERS, INC.

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You know, in a day, since water is not a 2

compressible fluid, I imagine the reactor vessel and all the 3

piping expanding by something over 7000 gallons, or 10 4

percent.

It seems surprising that you would expect steel 5

vessels.to expand by 10 percent.

That's the only way you can 6

accommodate minus 6 gallons.

7 MR. MC BRIDE:

Excuse me, Judge Carpenter, I'm not 8

sure I follow the calculation.

9 JUDGE CARPENTER:

There are 1400-and-some-odd 10 minutes in a day, 6 times 1400 is the number, approximately, 11 7000.

6 gallons per minute of water was coming from

()

12 someplace in order to produce a negative leak rate; negative 13 leak rates mean positive water addition.

Water was 14 spontaneously appearing in the system.

Isn't that correct?

15 THE WITNESS:

Well, I don't believe it was 16 spontaneously appearing in the system.

You might run this 17 the next time and get a positive 6 gallons a minute.

18 BY JUDGE CARPENTER:

19 Q

Yes, if you put the water addition in correctly.

20 Would you agree the reason a large negative number 21 appeared as described in the NRR note on the strip chart is 22 because the water addition was added, not as an addition but 23 as a subtraction?

24 A

What are you saying?

In other words, we entered gg v

25 the water --

ACE-FEDERAL REPORTERS, INC.

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1 Q

Turn over the strip chart --

2 A

We entered -- there's 500 gallons; right?

That 3

was entered as operator-caused changes.

4 Q

Right.

5 A

And the log says that we added 500 gallons.

6 Q

Right.

Look at the strip chart, in the bottom 7

right-hand side.

There are notes that were added by the NRR 8

reviewer.

That reviewer tells us that the 500 gallon 9

addition was entered in the computer, not as an addition but 10 as a deletion.

Isn't that what it says, the last sentence?

11 A

Okay.

Yes.

That was entered in the drain tank.

()

12 It was entered in the wrong place.

You are right.

13 Q

Yes.

It took you one minute to find that, and yet 14 at the time you signed this you didn't take the one minute to 15 find it.

Is that a fair statement?

16 A

That's probably a fair statement.

But the number l

17 of leak rates that we did perform and the accuracy that we 18 were getting, it was difficult.

I know there's no 19 justification for it in your mind --

20 Q

But for the reason, if you put a water addition in 21 as a deletion, it's not the test, it's not the 22 instrumentation, it's the operator who is causing the 23 inaccuracy in this particular case.

Isn't that a fair 24 statement?

There were a lot of inaccurate tests for a lot of s

I 25 different reasons.

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A Right.

2 Q

This happens to be blatantly -- I'm trying to get 3

at the point that you, and I get the impression others, were 4

rather free to sign results that gave substantial indications 5

of negative leak rates without pausing to say:

This can't be 6

a valid test.

A big negative number can't be physically 7

real.

8 A

I would say now we sign tests which are either --

9 in other words, we don't have to meet the acceptance criteria 10 but we still sign the test.

There are notations, like an 11 exception and deficiency.

O(_j 12 Q

Yes.

13 A

What this is saying is -- I don't recall at the 14 time exactly what was -- why I would have signed it.

But 15 looking at it now --

16 Q

That's why I asked you whether there was any 17 pressure from your supervisors to some way or other get some 18 numbers less than 1 gallon per minute, even though it might 19 be negative, and put it in the file.

20 A

I --

21 Q

That's a possible motivation.

22 A

In other words, did I feel I was going to lose my 23 job if I didn't -- is that what you are saying?

24 Q

Well, perhaps not that drastic but at least lead 25 to some review of your performance.

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A I don't recall any.

2 JUDGE CARPENTER:

Thank you.

I accept that.

3 I would like to turn now to some other tests.

4 BY JUDGE CARPENTER:

5 Q

In that same book up a little bit more than 6

halfway towards the front, would you find test number.120, 7

please.

8 A

120?

9 Q

Yes.

The test was performed by Mr. Cooper and 10 signed by Mr. Adams, dated 2/15/79.

Do you see it?

11 A

Yes, sir.

(O

_)

12 Q

We spent some time with Mr. Cooper, looking at 13 this test.

Your counsel is bringing up a clearer copy of the 14 strip chart record which is useful.

There seems to be some 15 disagreement between Mr. Cooper and Mr. Adams about this 16 test.

But, particularly on that clear copy, you'll see that 17 Mr. Adams made a notation, we think -- at least that's the 18 Implication.

We haven't had a chance to talk to Mr. Adams 19 yet.

But, be that as it may, the evidence today indicates 1

20 that approximately in the middle of this test, 30 minutes 21 into the test --

22 A

What's the time of the beginning?

1 i

23 Q

2026 and it runs to 2126.

24 JUDGE KELLEY:

That's the time on the strip l

25 chart.

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BY JUDGE CARPENTER:

2 Q-If you look at the strip chart in your notebook --

-3 JUDGE KELLEY:

I don't know if it will become 4

significant but the evidence indicates that the real time 5

beginning was about an hour.and a half earlier, by logLtime.

6 That's not the correct time.

It may not matter for your 7

purposes but we went through that yesterday, it's an hour and 8

a half off.

9 THE WITNESS:

2026 to 2126, 2/15/79.

10 (Discussion off the record.)

11 JUDGE CARPENTER:

It's a side point.

The strip

()

12 chart at this time was apparently -- strip chart times, as 13 indicated in the preprinted numbers on the bottom of the 14 chart, apparently were not coincident with real time.

15 MR. MC BRIDE:

If you could just give us a

~16 moment.

The pages have gotten out of order here in the book I

17 and he's confused between the test and the strip chart and I

i 18 that sort of thing.

If you'll just give me a moment I'll get l

19_

things back in order here.

I 20 -

JUDGE KELLEY:

Off the record.

21 (Discussion off the record.)

22 BY JUDGE CARPENTER:

23 Q

As you look at the strip chart record that's 24 identified as test 120 --

25 A

Yes, sir.

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Q

-- you see the time interval that is-marked off 2

with two vertical lines and labeled " leak rate test 120"?

3 A

Yes, sir.

4 Q

In the middle of that 60-minute interval there's a 5

vertical offset in the slope of the makeup tank level strip 6

chart record.

7 A

Yes, sir.

8 Q

Looking at that offset, it's somewhere between two 9

chart divisions and three chart divisions; probably a central 10 tendency, 2-1/2.

11 A

That's close, on my copy, anyhow.

()

12 Q

Which would correspond to 2.5, would be 75 13 gallons, 30 gallons per division?

14 A

30 gallons per percent, you say?

15 Q

Per division; i don't know if this is a percentage 16 scale, I thought it was a height scale.

17 A

Okay.

18 Q

Looking at that whole record, do you see similar 19 vertical offsets anyplace, as opposed to brief changes in 20 water level indication that essentially return to -- close to 21 the original value?

What I'm saying, I think I see what I 22 call squiggles, rather than a persistent offset.

23 A

Well, there might be one there where the chart is 24 marked at, it looks like 6:00 p.m.,

on the bottom.

Where it 25 crosses that line it takes an up slope there.

And then ACE-FEDERAL REPORTERS, INC.

1 202 347-3700 Nationwide Umcrage MA34tM6

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there's also a change there where the chart is level, i

2 Q

Why don't you take a piece of paper and use it as 3

a straight edge.

Okay.

4 Q

Go over to 6:00 p.m.,

if that's where.you think we 5

should look.

From 4:00 p.m.

to 8:00 p.m.,

on that record, do 6

you see an offset of 12-1/2 divisions that's persistent?

For 7

an hour or two?

8 A

Well, there's one there, say from 4:00 p.m.

to --

9 let's see, what, 4:00 -- 4:30, 4:45; a different slope I

10 there.

Then I'd say you have a different slope, let's see, 11 from 5:00 until just before 6:00.

Then you have maybe

()

12 another average slope between 6:00 and 8:00.

13 Q

I'm not looking at slopes, I'm looking at offsets.

14 A

That's what I'm saying.

Or offsets.

15 Then it looks like sometime from about 3:00 to 16 4:00, it looks like it is straight across.

I don't know what 17 it is before then.

18 Q

Do you have something to draw with?

Pencil or 19 pen?

If you use your straight edge, draw a line through the 20 interval 4:00 p.m.

to 8:00 p.m.

21 A

4:00 to 8:00 p.m.

22 Q

Parallel with the strip chart record.

23 A

4:00 to 8:00 p.m.

]

24 Q

Maybe with a slope that's pretty close to the O

25 '

slope of the solid line that occurs 7:00 p.m.

to 11:00 p.m.,

i ACE-FEDERAL REPORTERS, INC.

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strip chart time.

2 A

Which times are you going by?

Are you going by 3

the ones --

4 Q

I said strip chart time just for convenience.

5 A

sRight.

From 7:00 to --

6 Q

A solid, straight line.

It has obviously been 7

added.

8 A

Okay.

I see what you are talking about.

9 Q

To my eye, there really isn't a big difference in 10 the slope over strip chart time 4:00 to 8:00; would you 11 agree?

()

12 A

I don't know.

I find it difficult to draw a 13 straight line on a strip chart that's wiggling around like 14 that.

But the general slope from 4:00 -- well, right there i

15 around 4:00 it does change.

16 Q

I certainly agree.

17 A

In other words, 4:00 to about -- and depending on 18 where you put your straight edge on that line, you can change 19 the outcome if you connect that line.

20 0

I'm not going to analyze from 3:00 to 4:00, for 21 the moment.

We'd have to go back to previous tests, which 22 taken us further, I think, than where we want to go.

23 A

Maybe if you just --

24 Q

What I wanted to ask was, does that offset that 25 occurs in the middle of leak rate test 120 look to your eye ACE-FEDERAL REPORTERS, INC.

202-347-)?t si Narnivinide Cmcrge Mk)WrM6

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differently than what I take to be these temporary five-to 2

10-minute excursions of the pen, essentially up and down?

3 The point being that they are cyclical, in terms of five or 4

10 minutes,.vis-a-vis the offset that occurs at the middle of 5

leak rate test 120, which is a persistent offset for more 6

than an hour?

7 A

From when to when was the last part?

8 Q

From the middle of leak rate test 120 --

9 A

All right.

10 Q

-- where it shows hydrogen addition?

11 A

Yes.

()

12 Q

It persists, to my eye, as a persistent, not 13 change in slope but a persistent offset, persistent change in 14 the inventory over a period.well exceeding an hour.

Is that 15 different from other things that you see in this strip 16 chart?

There are, certainly, two division changes in the 17 indicated level that are not persistent for an hour or so.

18 Is that a fair description of it?

19 A

You are saying there's an up trend in the period 20 of, say, 20 -- well, let's use the strip chart time of about 21 1015 to about 1045?

22 A

Right.

23 Q

And then there's a persistent --

24 A

In other words, a slope difference between the 25 line from --

ACE-FEDERAL REPORTERS, INC.

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Q Not a slope change but an offset.

2 A

Offset.

3 Q

There's a change in the inventory by roughly 75 4

gallons that persists for more than an hour.

What I'm asking 5

you is, is that a fair way to read that chart?

6 A

There's a change.

7 Q

Do you see any other thing that looks like that?

2 8

A Not on this chart, no, sir.

9 Q

If we turn now to test 123, where, by chance, you 10 were both the CRO on the panel and you also carried out the 11 test; we don't have any confusion about operator action with

()

12 respect to test 123.

First of all, looking at the strip 13 chart for 123, have you had a chance to look at the test?

14 I'll give you a minute.

15 MR. MC BRIDE:

Can I just make sure the pages are 16 in the right order?

17 JUDGE CARPENTER:

All right.

Thank you.

18 MR. MC BRIDE:

Yes.

All right.

19 BY JUDGE CARPENTER:

20 Q

First a general question:

When the procedure 21 calls for steady state, after the test was completed did you 22 routinely look at the strip chart to see if the slope looks 23 smooth over the 60 minutes?

24 A

I don't recall.

25 '

Q Wouldn't that be a useful way of seeing whether or ACE-FEDERAL REPORTERS, INC.

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not steady state had prevailed?

2~

A It would be.

3 Q

But you were never taught to do that?

4 A

Well, now that seems obvious.

I don't --

5 Q

Yes.

I realize.

But I'm asking you, at that 6

time, no part of the training said one of the best ways td>

7 be sure that you are complying with the requirements of this 8

procedure is to look at the strip chart at the end of the l

9 test to see if somebody else did something?

You might see it 10 there; power change, a water addition, they would all be 11 reflected in changes in the slope, wouldn't they?

But you

()

12 were not trained to do that?

13 A

I don't rdcall any specific training, but that 14 seems obvious.

I would say I probably knew it then.

15 If you change power, or say you change average temperature or you change, well, there's a number of things 16 17 that you could change that --

18 Q

But don't any of those changes invalidate the 19 test?

20 A

As far as trying to keep the leak rate test as i

21 steady state, yes.

You should keep it at steady state.

22 That's what I feel now.

We are very particular as far as 23 running leak rates now.

I can't say -- I don't exactly l

24 remember what I thought back then, but I would have to say

~

25 that I knew if you had a change in the makeup tank you would 4

i -

ACE-FEDERAL REPORTERS, INC.

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want to know why and it was probably one of us looking at 2

it.

3 I mean, we usually had it rolled out of the 4

compartment that it was sitting in.

If there was a change 5

that you could see easily, 5, 6 -- well, we sat at a desk, 6

you could turn around and you could see a change.

7 Q

I can see it in the picture of the control room 8

there and visualize you sitting at that desk with the strip 9

chart recorder right in back of you, the far desk.

But you 10 didn't routinely say:

Well, if there is a real change in 11 slope during the 60 minutes, that invalidates the test?

()

12 A

We didn't study the chart, no.

13 Q

There's no need to study it carefully --

14 A

I'm saying from a change that you are showing on 15 number 123, we vould have not picked that out.

In other 16 words, you are showing leak rate test 123.and there's --

17 Q

I'm not showing it.

Thi8 18 a strip chart record 18 made by you right there, as far as I can tell.

Do you have I

19 any quarrel with that?

This is not a synthetic record.

It 20 has been presented to us as a Xerox copy of the original.

i 21 A

I was there.

I signed it.

22 Q

Right.

It's not mine.

It's yours.

You say that 23 "I'm showing"?

24 A

No.

What I'm saying is a small change in slope we 25 did not sit there and analyze it.

ACE-FEDERAL REPORTERS, INC.

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'Q But isn't it true-that it's a little bit of a 2

challenge to measure to 1 gallon per minute?

It's two 3

divisions over 60 minutes.

It's not an easy thing to do.

4 A

That's correct.

5 Q

So it takes a certain amount of care.

6 A

But I think we were trained -- you mentioned 7

training -- in other places that were more important to us at 8

the time.

9 Q

I don't deny that there are many other things that 10 are at least equally important, but I am perplexed about the 11 neglect of this test.

Apparently you got no feel in your

()

12 training that this was a thing that's going to be useful, 13 it's in the' tech specs, but it's not easy to do.

That was 14 missing in the training.

15 A

I would have been -- I mean, this is aftersight --

i 16 I don't specifically recall any questions on my examination 17 from the NRC as far as -- I don't remember getting any l

l 18 training at all on the leak rate except what I had to learn 19

.by myself.

20 Q

That's certainly in agreement with the record to 21 date.

You are not the only person.

l 22 Turning away from that, I spent some time reading 23 all the answers you gave to all the questions people have 1

l 24 asked you, which are part of our record.

At a slightly 1O 25 different perspective, I look at test 120, at the moment I'm I

ACE-FEDERAL REPORTERS, INC.

202-347-37m Nationwide Coverage R3336-6646

-()

28397.0 k/ BRT 3060 1

going to. accept that as being an indication that hydrogen was 2

added during the leak rate test and because of the 3

peculiarities of the instrumentation that you happen to have 4

at TMI-2, unexpectedly or surprisingly, but nevertheless, in 5

fact, it produced an offset in the makeup tank level.

Accept 6

test 120 as a demonstration of that for the moment.

Whether 7

that turns out ultimately to be our conclusion, I'm not 8

speaking to that at the moment.

But given that as a premise, 9

if I were to find that 120 was a fingerprint for a hydrogen 10 addition and I look at test 123, this is your chance to point S

11 out to me any differences between the offset in 123 versus

()

12 the offset in 120.

13 Just eyeballing it, I see oscillations, I see 14 bumps.

I don't quite understand why this differential 15 pressure transmitter is so nervous, but that's beside the 16 point.

But I don't see, by and large, hour-long, 17 two-hour-long offsets.

I see up movement of the pen followed 18 by, a few minutes later, down movement of the pen; up 19 movement of the pen -- but no regularity, no truly cyclical 20 nature but just sort of up and down, up and down -- a 21 i wandering more than a true oscillation.

Except for this time 22 interval that starts about 10 minutes before the end of the 23 test and persists for an hour or so and its persistence is 24 terminated, apparently, by a water addition -- large vertical V

25 offset.

So that that looks to me very much like what I see ACE-FEDERAL REPORTERS, INC.

i 202-347-3700 Nationwide Coserage 8m-3346M6

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28397.0 k-BRT 3061 1

in test 120.

Is that a fair statement?

2

'A Looks like another squiggle to me.

You say the 3

slope changed --

4 Q

I beg your pardon?

5 A

There is, not a change in the slope but the slope 6

does move up there, yes.

7 Q

Let's -- that's a persistent decrease with time --

8 well, let's let rate of decrease be called the slope?

9 A

Okay.

10 Q

And a persistent change in level be an offset, for 11 definition of terms.

()

12 A

All right.

13 Q

Isn't it true that after this offset, which took 14 place over a time interval of roughly 7 minutes, that that 15 offset was persistent?

16 A

You are saying 7 minutes in leak rate 123?

17 Q

Yes.

r 18 A

The offset --

19 Q

In the large divisions on a time scale of 15 20 minutes, roughly half the interval are roughly 7 minutes, 21 maybe even 6.

22 A

I'm not good at sitting here looking at charts and 23 analyzing.

24 Q

Well, if the whole interval is 15, it looks like O

25 it's roughly half, 15 divided by two is roughly 7?

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1 A

Okay.

2 Q

And then that water level indication change is 3

persistent with time for an hour or so, just like it was in 4

test 120.

5 A

Yes, sir.

6 Q

If we had just looked at these two pieces of strip 7

chart and I asked you, are they similar, do they show 8

something that's associated with a leak rate test, what do 9

you think your response would be?

10 A

Is that what you are_saying?

I didn't do the 11 analyzing but --

7-)

(_,

12 Q

Well, I spent not a great deal of time looking at 13 these tests, but just sometime, just eyeball -- these seem to 14 be time-persistent offsets?

15 A

Well, one is fairly level and then the other one 16 is a drop and then an increase.

17 Q

Which one is the drop and then increase?

18 A

It's one in 123.

The time -- I think you call it 19 the offset drops down a little and then offsets, where the 20 one in leak rate 120 has a gradual increase over a period of 21 half an hour.

22 Q

I certainly agree with your characterization.

The 23 rate at which the onset appears is different.

24 If I look through these strip chart records, I see 25 these ups and downs, ups and downs -- but only very rarely do ACE-FEDERAL REPORTERS, INC.

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I see an "up" that's persistent, that you can't identify as 2

being a water addition, something to change the inventory 3

other than as the note which has been added to the bottom of 4

this page, says there's a hydrogen addition at 0500.

L 5

You didn't log it because you were the control 6

room operator.and it says "not logged in the control room 7

operator's log."

I'm just reading the note underneath it.

8 A

I see-the note.

9 MR. MC BRIDE:

Judge Carpenter, could we have an 10 understanding what the question is?

I'm sorry.

I have been 11 looking at strip charts here.

()

12 JUDGE CARPENTER:

I'm seeing if he agrees with the 4

13 NRR review which is summarized on the graph.

This is his 14 chance to agree with it or disagree with it.

15 MR. MC BRIDE:

Could we precisely have an 16 understanding of what the question is?

I 17 JUDGE CARPENTER:

I said, according to NRR's 18 reviews there was a hydrogen addition at 0500, and it goes on 19 to say it wasn't logged in the CRO's log, which Mr. Illjes 20 was responsible for.

21 MR. MC BRIDE:

Could I ask whether it's at all i

22 your intention to imply in the question that he was f

23 necessarily the one to have added it, or whether it was even 24 added in the control room?

.(

25 JUDGE CARPENTER:

No.

It's pretty clear, it says 1

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it was logged in the AO's log.

He couldn't have.

2 MR. MC BRIDE:

Okay.

3 BY JUDGE CARPENTER:

4 Q

Do you agree it wasn't logged in your log?

5 A

It doesn't show that I can see in the log that I 6

had on -- this is 3/17?

2/17; February 17th.

7 Q

Did the AOs ever add hydrogen without instructions 8

from the control room?

Did chemistry call and tell them to 9

add it?

10 A

I don't specifically recall.

They basically, if 11 we asked them to add hydrogen it was whenever they got to O) 12 it.

Or, in other words they -- it was -- they had to do a s_

13 valve line-up.

I think they probably had to go outside and 14 put on a hydrogen tank.

We had them delivered in bottles, 15 and had to go in the plant and do a valve alignment to add it 16 to the makeup tank.

17 Q

Did you normally log the times when you reques+ed 18 a hydrogen addition?

19 A

If I did something I tried to log it.

I would say 20 there's not everything got logged that should have been 21 logged.

22 Q

Yes.

But normally would you have logged the 23 hydrogen addition?

Is there any reason you wouldn't?

24 A

Well, there are a lot of things we did that didn't 25 get logged, but we didn't think it was necessary to log.

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Q Well, let's don't talk about everything.

Let's 2

talk about hydrogen additions.

3 A

It's hard for me to differentiate whether or not I 4

logged hydrogen or would log hydrogen as something that was 5

necessary to log.

I agree now we should log stuff like that.

6 Q

Well, we have the logs so I guess I could look and 7

see if you did tend to log hydrogen or not.

You just don't 8

remember whether you did?

9 A

No, sir.

10 Q

Would you have actively said:

Well, I told him to 11 add hydrogen but it's really not necessary to log them?

A)

(_

12 A

Would somebody have said that?

13 Q

Would you have thought that to yourself?

14 A

Well, it probably would have been, you know, 15 called down to the aux operator.

It might be sometime during 16 the shift that he added hydrogen.

It's a possibility that he 17 got busy and never called me so I didn't log it.

18 Q

You only logged it when he told you he had added 19 it rather than at the time you requested it?

20 A

I would say that's the way I ran things, as far as 21 I recall.

22 Q

What I wanted your help with, if I look at test 23 120 and test 123, I certainly agree with you about the rate

(

24 at which this offset appeared.

The magnitude is roughly l

(

25 comparable to 2 versus 2.5, and the time persistence seems i

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similar.

Do you think I should hesitate to conclude that 2

they were probably caused by the same mechanism?

Are there 3

other things that you are aware of that could cause 4

persistent offsets?

5 A

There are things that could.

Somebody could 6

change a set point in a pressurizer level, or T av.

7 Q

If we wanted to find out whether that had occurrec 8

here, could we do that?

9 A

It would be difficult.

10 Q

So in your mind this is not an unusual pattern for 11 the slope to take, in the sense of relatively rapid offset

()

12 which, in terms of~the 1 gallon per minute limit, is 13 substantial?-

14 A

I would say our mind was more attuned between 15

~ somewhere around 85 and 60; that was the band we were to keep 16 it in, not small changes.

We weren't tuned in to real small 17 changes.

18 Q

Isn't that the whole point?

The leak rate tests, 19 you have to be sure that the change isn't bigger than two 20 divisions in an hour, and that's pretty challenging?

21 A

But I mentioned before there should be a reason 22 for the change.

If you had an inventory change, like you 23 change T av, or you change pressurizer level, you change 24 power level -- I --

f.,g U

25 Q

Well, it's your view today looking at these two ACE-FEDERAL REPORTERS, INC.

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pieces of paper which are in front of us --

2 A

I'm saying I think I know what you are getting to, 3

but --

4 Q

Well, the implication is, and I think test 120 has 5

influenced some people's thinking.

I was trying to see 6

whether you agreed with it.

If you accept 120 as being a 7

perturbation of the level sensing system, looks like at an 8

increase in hydrogen pressure --

9 A

I agree.

10 Q

-- then you might look at 123 and say it looks 11 very similar?

()

12 A

It looks similar.

13 Q

Or do you think this Board ought to view this --

14 these two patterns, which occur within two days of each 15 other, as being a happenstance, simple coincidence?

16 A

I haven't any explanation.

17 Q

I haven't studied every one of these strip charts, 18 but this kind of pattern is not -- I don't see it on many of 19 them.

So I get the feeling at the moment, and it's 20 tentative, that this is not an ordinary thing during a shift 21 for there to be that kind of offset.

Is that your i

22 impression?

Your recollection?

The water additions are i

23 distinctive offsets --

24 A

I'd have to say it again:

We were not tuned in to

\\

25

-- in other words, you had that much strip chart sitting out ACE-FEDERAL REPORTERS, INC.

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in front of you.

That's what you could see from the desk, 2

maybe that much.

(Indicating.)

3 Q

When you pull the recorder out how much could you 4

see?

5 A

You could see quite a bit more but you'd have to 6

go up to the panel and look like this.

(Indicating).

7 Q

But if water level and inventory leaks are 8

important, I would think you would periodically eyeball it to 9

see what the situation was.

10 A

We did.

11 Q

It wasn't invisible?

)

12 A

No, sir.

13 Q

I'm trying to get the bottom line here.

The 14 inference has been drawn, it's almost what we'd call 15 circumstantial, that 120 and 123 are so similar that one 16 might conclude that they were caused by the same thing, same 17 mechanisms.

That there isn't an alternate explanation.

I 18 guess you could make a 60, 75-gallon water addition.

It 19 doesn't seem to be very common.

You'd wait until you needed 20 more water until you would bother to do it.

Is that fair?

21 '

A Yes.

That doesn't look like the normal water 22 addition; no, sir.

23 Q

Well, I say, I tried to give you the perspective, 24 I think, others have taken, and I can't avoid, having been g-

~'

25 exposed to test 120 yesterday and test 123 this morning, of ACE-FEDERAL REPORTERS, INC.

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looking at them and seeing gross similarities which tend to.

2 make me wonder whether they weren't caused by the same 3

thing.

Can you tell me why I'm wrong?

4 A

I don't have an explanation.

5 JUDGE CARPENTER:

Okay.

Thank you very much.

6 JUDGE KELLEY:

I have a question or two of 7

Mr. Illjes.

8 BY JUDGE KELLEY:

9 Q

In this case the record indicates there had been a 10 hydrogen addition by one of the auxiliary operators during 11 one of the leak rate tests.

Could you give me a little

()

12 fuller idea of the extent to which you as the panel operator 13 could control their activities, particularly with reference 14 to timing?

15 A

It would be calling him, depending on where he was 16 in the plant.

He had care of three levels of auxiliary 17 building and three levels of fuel handling building, to the 18 place where it was sort of a lunch room, break room.

You 19 know, you could call him there or page him on the telephone.

20 Then --

l 21 Q

But -- I'm sorry.

Go ahead.

22 A

Then you could call him and, if you needed 23 something done right away, depending on where he had to go, 24 it would maybe take him maybe five to 15 minutes to get ready 7-I

(_/

25 to go in.

If it was a contaminated area it would take him a ACE-FEDERAL REPORTERS, INC.

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areas.

3 Q

These auxiliary operators, as I understand it, 4

they were subordinate to the control room panel operator in P

5 the sense that you could call up and tell them to do things 6

and they are supposed to do it; is that right?

7 A

Yes, sir.

You requested that they would do 1

8 something, or you could give them certain things to do at the 9

beginning of the shift, have them take care of it during the-10 shift; or you could call them up at any time and ask them to 11' do something that was required.

()

12 Q

Well, I assume when you call somebody, as a matter 13

-of courtesy, you would ask them.

But as a matter of the 14 chain of command, you could tell them; right?

15 A

It wasn't exactly so -- you call it a chain of~

16 command.

I tried not to -- if you told somebody you got a 17 different response out of them versus if you asked somebody.

I 18 Q

Well, I understand that, too.

But what I'm after, i

19 I mean they wouldn't say to you:

Well, Illjes, I don't feel 20 like it so go away.

You wouldn't get that kind of response, 21 would you?

i 22 A

I got that response now and then.

(Laughing.)

h i

23 Q

Who were they subordinate to, if not the control 24 room operator?

25 A

They were.

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Q All right.

Now, let's suppose that it was 2

significant.to you that something be done at a particular i

3 time, whatever it might be.

Let's take hydrogen.

Suppose 4

you wanted to add hydrogen, not on the dot but around 5:00.

5 If you told an auxiliary operator at 4:30, I want you to add 6

hydrogen to the makeup tank right around 5:00, if you give i

7 him a half-hour lead time would they then proceed to do that?

8 A

If you wanted it done at 5:00 and you asked to 9

have it done at 5:00?

10 Q

Half an hour in advance you ask him.

11 A'

It's possible -- yes, they could probably have it'

(

12 done at 5:00 for you.

13 Q

Okay.

14 JUDGE CARPENTER:

Mr. Illjes and Mr. McBride,'the 15 Board would like you to look at II-B of the Stier. report, t-16 current GPU system employees assessment of involvement in 17 leak r' ate testing, in the volume that begins with the letter 18 H as a tab, letter Z in the second tab as tab I.

19 MR. MC BRIDE:

I think I know what you are 20 directing our attention to, Judge Carpenter.

We have an 21 organization by client here.

We have a book.

I think we 22 have the assessment of Mr. Stier of Mr. Illjes.

23 JUDGE CARPENTER:

As long as you understand the 24 document I'm referring to.

25 MR. MC BRIDE:

Is that what you want to direct his ACE-FEDERAL REPORTERS, INC.

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attention to?

2 JUDGE CARPENTER:

Yes.

3 MR. MC BRIDE:

Okay.

4 JUDGE CARPENTER:

It's the summary part of the 5

information compiled by Mr. Stier's volume 2.

We would like 6

for you to review pages 9 through 13.

We'll give you five 7

minutes to do it.

8 JUDGE KELLEY:

We'll take a stretch break of five 9

minutes.

Don't go too far.

We'll resume here at 5 after 10 11:00 and quit at 11:30 for lunch.

11 (Recess.)

f3

(,/

12 BY JUDGE CARPENTER:

13 Q

Mr. Illjes, have you had a chance to review those 14 pages that we were talking about before the break?

15 A

Yes, sir.

16 Q

Do you have any comment that you would like to 17 make?

18 A

No, sir.

19 Q

I would like to paraphrase those several pages.

20 Is it fair to say that the essence of those is that, 21 apparently, Mr. Chwastyk felt that he became aware that the 22 hydrogen addition might have some effect on the water level 23 indicator and, therefore, on the leak rate test; and that he 24 thought he got that information from you?

O 25 A

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it from me.

2 Q

And it was your position then, and I want to ask 3

you, is it your position today, that you had no recollection 4

of any conversation with him where hydrogen was the subject 5

of the conversation?

6 A

No, sir.

Joe -- Joe Chwastyk is the kind of 7

person, when he comes into the room he can do things on his 8

own, he doesn't have to tell us to do certain things.

He 9

could very well have told the aux operator to do whatever he 10 wanted him to do.

If he had a question about something, he 11 could take it upon himself to do something in the control

. ()

12 room that he wanted to do.

13 Q

How would you describe your working relationship 14 with him in the time frame, particularly 1979?

15 A

Well, Joe was, I would say -- could be very

.16 demanding.

When he wanted something, he got it.

I would say 17 he kept some things to himself.

I would say:

Be more 18 specific as far as what you want to know.

19 Q

I was curious to know what stuck out in your mind, 20 without probing you everywhere, just today thinking back to 21 1979 what kind of relationship you had?

22 A

Well, I made an effort to, you know, do what he 23 expected.

He set up -- he told us what he wanted and if you 24 didn't do what he wanted, you got -- you knew about it.

O 25 MR. MC BRIDE

Excuse me, Judge Carpenter, I think ACE-FEDERAL REPORTERS, INC.

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the witness may have been about to say something further in 2

response to your prior question.

I wonder if we could just 3

inquire whether he had anything more to say.

4 JUDGE CARPENTER:

That's fine.

Do you want to 5

restate the question for me?

f 6

MR. MC BRIDE:

He started to say, "to be more 7

specific," and then you asked another question.

I wonder if 8

he has anything further he wanted to say.

9 THE WITNESS:

Can he read that back?

10 MR. MC BRIDE:

I think we have lost it.

I thought 11 he might have had something more he wanted to say but

()

12 evidently he doesn't.

13 BY JUDGE CARPENTER:

14 Q

Is that correct?

You don't feel I cut you off at 15 a useful point?

16 A

It's hard to think back.

I think we all -- we got 17 along with Joe.

He was not somebody that you -- was going to 18 be on your case all the time.

He was all right to work for.

19 Q

You didn't have any feelings that he was negative l

20 about your work performance?

21 A

No, sir.

22 Q

I wonder if you would help us further by turning 23 to test 124, please.

Mr. McBride, would you look at his book

(

24 and make sure the cards haven't been shuffled.

We need to 25 look at 124 and 125.

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MR. MC BRIDE:

Just to be clear, we've got tests 2

124 and 125, I believe, in front of us, although the copy of 3

124 doesn't have a number of -- what I believe to be 124 4

doesn't have a number in the upper right-hand corner because 5

of the way it was reproduced.

Is it the test that was 6

performed on February 19, 1979, at 1:17, according to the 7

computer time?

8 JUDGE CARPENTER:

That's correct.

9 MR. MC BRIDE:

Okay.

He has them both.

Just so 10 he knows, as this book is arranged, there are several sheets 11 of paper here, logs and strip charts as well as the two

()

12 tests.

13 JUDGE CARPENTER:

125 follows it, does it?

14 MR. MC BRIDE:

Yes, sir.

We've got that one here 15 reproduced so he can see the number in the upper right-hand 16 corner, that's the test at 2/19/79, at 1:36 in the morning.

17 BY JUDGE CARPENTER:

18 Q

So these two tests were conducted within a half 19 hour2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> of each other.

First of all, looking at the computer 20 printout page for 124, whose is that operator's signature; is 21 that your signature?

22 A

No, sir.

23 Q

Whose is that?

l 24 A

John Kidwell.

C) l 25 Q

And who approved it?

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A William Conaway.

2 Q

Turn to 125.

Who was the operator's signature?

3 A

That's John Mell, or Chuck Mell, as he was known.

4 Q

Who approved it?

5 A

William Conaway.

6 Q

Was it common that two leak rate tests were run 7

within 30 minutes of each other by two different operators?

8 We have had abundant testimony that "an individual" was 9

responsible for surveillance tests for eight hours when he 10 had that responsibility and carried out the surveillance 11 test.

()

12 A

I'm not sure when, but I think I ran two, one 13 day.

Got two that passed, one right after the other.

14 Q.

Yes.

But did you run one.and then somebody else 15 30 minutes later run one?- That's what I'm talking about.

16 Not the repetitiveness of the test but that different people 17 ran it.

18 A

It's -- yes, it's possible that different people 2

19 would run it.

20 Q

Why the jumping around?

21 A

Well, there's three people in the control room.

22 Q

Yes.

23 A

One guy helps the other.

24 Q

So it doesn't seem anomalous to you?

))

25 A

No.

l 1

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JUDGE CARPENTER:

Thank you.

2 MS. WAGNER:

Could we ask the witness to take 3

another look at the operator's signature on test 125?

4 JUDGE KELLEY:

Okay.

5 THE WITNESS:

The last name looks like "Mell."

6 I'm not sure.

The first name looks like " John."

7 MR. MC BRIDE:

Perhaps the best thing to do is to 8

wait.

-9 MS. WAGNER:

He could compare it to 124.

10 MR. MC BRIDE:

Perhaps the best thing to do is 11 wait until we have Mr. Kidwell and Mr. Mell here and find out (O

_)

12 from them.

They'll be here later this week.

13 BY JUDGE CARPENTER:

14 Q

In any event, you don't recognize either of those 15 as your signature?

16 A

That might be John Kidwell's.

Both are the same.

17 The " John" looks very similar to the second " John."

18 Q

Well, in the summary statement in the Stier report 19 that you read during the break, reference is made to 20 Mr. Chwastyk's going in the control room and making some 21 observations, and then making note of that.

Isn't that 22 correct?

23 A

Yes, sir.

Wrote it --

24 Q

That he got a good leak rate test with 5 to 6 C)s 25 pounds hydrogen overpressure?

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A That's what it says.

2 Q

We've had some testimony that you normally kept 3

the hydrogen pressure between 15 and 25 pounds per square 4

inch on the gauge; is that coincident with your memory?

5 A

I don't recall what we.kept it at.

6 Q

All right.

I'll let Mr. Chwastyk help me with 7

that.

8 In-looking at Mr. Chwastyk's note and looking at 4

9 test 124 and at 125, if you turn to, in my book, the last 10 strip chart before test 126 -- thumb through those papers.

11 Do you see the last strip chart in this group?

It says

-().

12 124-125 in the upper right-hand corner.

So we can look at 13 both tests.

They are fairly clearly marked on that strip 14 chart.

15 It appears that it is test 125 that corresponds to 16 a time when perhaps a hydrogen addition was made.

Do you 17 agree with that?

When he says that a good leak rate was 18 obtained with a certain hydrogen. pressure, do you think he's 19 talking about test 124 or 125 or do you have an opinion?

20 A

I don't know which test he was talking about here, 21 no.

I don't recall the test he was talking about.

22 Q

All right.

I think we'll probably let him help us 1

23 with that.

I was just wondering if you could tell by looking 24 at these which one he was talking about.

Wouldn't you think 25 a hydrogen addition, if it produced any effect, would produce i

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a positive offset?

2 A

I didn't become aware of the effect on the makeup 3

tank caused by hydrogen addition until after the accident.

4 Q

I won't challenge you to remember that particular 5

day, but based on the strip chart records that are in front 6

of us and the signatures on the computer page, would you say 7

it's likely that you were involved in these two tests?

8 A

It's possible I was there in the control room but 9

it is also possible that Joe Chwastyk was.

He is the type of 10 person that can go out and, you know, he'll take it upon d

11 himself, if he's got some question in his mind he'll go try

)

12 something, whether it's with something like this or another 13 perturbation in the system.

14

-Q Apparently it's your-testimony that you might 15 nearly run the test, nearly finish it, and then if somebody 16 tore the test off the computer they might sign it even if you i

17 had carried out the manipulations?

18 A

You are saying is that possible?

19 Q

Yes.

20 A

If I -- say that again?

If I punch the 21 information into the computer --

22 Q

Right.

23 A

-- somebody else could have signed it?

a 24 Q

Right.

O 25 A

That's possible.

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JUDGE CARPENTER:

Thank you very much.

2 BY JUDGE BRIGHT:

3 0

Just a couple of short questions, Mr. Illjes.

4 First, let me ask you:

Do you have any disagreement with 5

your previous statements that are in the record?

6 A

I don't recall them all.

7 Q

Well, none of us can do that.

But basically have 8

you --

9 A

No, I don't.

10 Q

Do you think you trod the primrose path in 11 anything you said previously at an earlier hearing?

12 A

No.

13 0

One thing I'm curious about.

You say you got very 14 little training insofar as specifically leak rate testing is 15 concerned.

And summing up everything I've heard this 16 morning, you basically viewed running those tests as some 17 kind of bureaucratic, or whatever, requirement that, say, the 18 company or the NRC or whoever didn't like a messy plant or 19 something like that.

Did anybody ever tell you what the 20 basic safety reasons for running those tests was, back when 21 you were running them?

22 A

I don't recall but now I know.

It has to do with 23 a certain --

24 Q

I'm sure you do.

25 A

Yes.

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Q At the time did you have -- did you really think 2

about it in those terms, the implications to safety?

3 A

I think we were conscious of safety, if you had a 4

fuel element. failure that the effects from leakage would have 5

an effect on people.

But I think we were confident enough by 6

the controls that were in place, such as samples taken from 7

the reactor coolant system, samples taken of.the atmosphere 8

in the reactor building, and monitors that were in our 9

release points, there was available information to assure 10 that we were protecting the public.

This is from a 11 perception now in 1986.

But I'm saying I think I felt that f}

(_j 12 way back then.

13 Q

Were you aware that the basic reason you were 14 making such minute determinations -- if you get a fission 15 break in a hole, you are going to know it?

16 A

Yes, sir.

17 Q

No doubt about that.

Everything in the plant is 18 going to tell you all about it.

But if you just develop a 1 19 gallon per minute unidentified leak somewhere, you won't 20 necessarily find it out any other way.

That's my 21 understanding of the testimony that has been presented so 22 far.

That's what you relied on, on the tests you were doing, 23 to tell you.

i 24 Were you aware of the technical basis for this, j

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you can get a crack and a leak in, say, one of your main 2

coolant pipes?

And if it is small enough that the leakage 3

from it is no greater than a certain amount, then you have 4

time to find it and do something about it before it develops 5

into a running crack and you have your loss of coolant 6

accident?

7 A

Well, I believe we had leaks identlfied but the 8

means that were in place to quantify the difference between 9

identified and unidentified were vague.

But I believe most 10 of the leaks, at least the leaks that were known then, were 11 not any different from the leaks known after the accident.

()

12 We kept the system pressurized for quite a while 13 after the accident.

14 Q

Well, my question is really were you aware of why 15 that requirement was in there?

And I get the sense that you 16 had some ideas about it but you weren't fully cognizant of 17 the technical reasons.

18 A

I really can't give you an answer as far as 19 what --

20 Q

This is no slur on you.

Everybody else says they 21 didn't have the foggiest.

22 A

That's why I say I don't recall.

I'd have to look 23 back in training records but I don't recall any specific 24 training on leak rates or the implications.

I knew the Os i

25 l specification, that we had a requirement.

l ACE-FEDERAL REPORTERS, INC.

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Q Fine.

Now let me ask you about the infamous LER.

2 78-62, I guess it is, where Mr. Haverkamp, the NRC inspector, 3

ran across a higher than 1 gallon per minute leak rate test 4

lying on someone's desk and all sorts of perturbations 5

occurred and an LER has been submitted to the NHC as a result 6

of that.

7 According to what the LER said, the -- there was 8

going to be -- there were going to be a lot of changes made, 9

such as following the tech-specs, which had not been done 10 before that time and making-sure that, under the conditions 11 set forth in the tech specs that you would enter the action

-()

12 statement, that sort of thing.

13 My question is:

We have heard testimony that the 14 LER was circulated, or at least a memorandum which contained 15 essentially the actions that were to be carried out.

And' 16 there was a check-off sheet which, I don't know about you 17 specifically, but everybody says:

I guess I must have read 18 the thing because I signed off on it.

And I guess the first 19 part is:

Do you recall ever seeing this, telling you how to 20 operate in the future?

t 21 A

I don't specifically recall it.

As you say, I'm 22 probably one of the persons that initialed it.

If I recall i

23 correctly, it had -- it was in a pile of material which, when 24 we would get time to read, we read it.

For all I know, it 25 might have been some of us that signed it after the l

i ACE-FEDERAL REPORTERS, INC.

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accident.

I don't know.

2 Q

True.

Did you ever get any intelligence, any 3

information from your shift foreman which said:

Hey, 4

fellows, we are going to make these changes, so do them?

5 A

I don't recall any.

6 Q

Did you ever get any information or intelligence 7

from your shift supervisor that says:

Fellows, shape up, we 8

are going to follow these procedures?

9 A

No, sir.

I don't recall it.

I don't recall a 10 change from the way we operated in interpreting the leak 11 rate.

()

12 JUDGE BRIGHT:

Thank you very much, Mr. Illjes.

13 JUDGE KELLEY:

We have come up to the time we need 14 to break.

We would like to see counsel for the employees for 15 a moment right after this.

We'll be back here at 1:30.

16 We'll have a few things after lunch, Mr. Illjes, i

17 but I don't think it will take very long.

18 (Whereupon, at 11:30 a.m.,

the hearing was 19 recessed, to be reconvened at 1:30 p.m.

this same day.)

20 21 22 23 24

()

1 25 ACE-FEDERAL REPORTERS, INC.

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AFTERNOON SESSION (1:30 p.m. )

2 Whereupon, 3

THEODORE F.

ILLJES 4

resumed the stand and, having been previously duly sworn, was 5

examined and testified further as follows:

6 JUDGE KELLEY:

We are back on the record.

In a 7

moment we have a few follow-up questions from the parties 8

that we'll put to Mr. Illjes.

9 I have a procedural matter that the Board thinks 10 ought to be raised at this point and addressed.

11 The parties will recall that, earlier in this

()

12 case,_right up toward the beginning, we had a motion for 13 Mrs. Aamodt to disqualify all counsel on one ground or 14 another, and one of the grounds urged was that the counsel 15 for the numerous employees, in representing numerous 16 employees as their title implies, would run into conflicts 17 and that that was not an acceptable situation.

18 Without restating all of that, we denied the 19 motion in a memorandum and order July 16, and in that regard 20 we said this, "In conclusion" -- we said at page 8:

"In 21 conclusion, this case involves multiple representation where-22 potential conflicts exist among the numerous employees but no 23 actual conflict has surfaced.

Counsel for the numerous 24 employees believe that they can represent their clients 73 V

25 without conflict.

We accept their judgment at this ACE-FEDERAL REPORTERS, INC.

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1-juncture.

Counsel further state that, 'If an actual conflict 2

arlses in this proceeding we will discuss it with the a

3 affected employees and either withdraw or secure their 4

consent to our continued representation.'"

5 We have had several instances already in the case 6

where the testimony of one witness will diverge from the 7

testimony of another.

We have not felt obliged at each

-8 instance to intervene and ask the witness whether he is aware 9

of potential or actual conflicts; whether he waives such 10 conflicts.and so on.

It does seem to us, in the case of this 11 particular witness, Mr. Illjes, there is a divergence between

()

12 his testimony on the knowledge of the hydrogen effect, I'll 13 call it, and a statement that Mr. Chwastyk has made in the

-14 past and we anticipate he'll make again; and therefore it 15 prompts us to inquire in this-particular situation of the 16 witness and of counsel, also, whether this potential 17 conflict, at least, has been considered and taken into 18 account.

19 EXAMINATION BY THE BOARD (Continued) 20 BY JUDGE KELLEY:

21 Q

Mr. Illjes, first, you are aware that your counsel 22 represents not only you but 20-plus other employees, former 23 employees at TMI-2; correct?

24 A

Correct.

O 25 Q

Are you aware of the fact that, in so doing, there-4 ACE-FEDERAL REPORTERS, INC.

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1 is at least a potential for conflict in their representation, 2-in the sense that in representing'you, your recollection may 3

be to a cer'tain effect and somebody else's recollection may-4 be different?

Are you aware of that possibility, at least?

5' A

I don't think it's a conflict.

It's just I don't 6

recall something that he does -- thinks he recalls.

7 Q

There are different shadings one can.put on this.

e i

8 But-it is, it seems to us, at least potentially the case that 9

your recollection may be different from some other person i

10 also in the case.

You are aware of that?

11 A

Yes.

(

12

-Q Do you' appreciate the' fact that when counsel.are 13 representing you and another-person, for example, i

14 Mr. Chwastyk, if his recollection varies from yours, that 15 they then have to make judgments about how to advise you and 16 that they may be affected by the fact that they represent.not

[

17 just you but Chwastyk and other people, too?- Conaway --

18' A

Yes.

i 19 l

Q Are you aware of that fact?

i 20 A

Yes, sir.

l 21 Q

In light of those circumstances, have you 22 discussed with your counsel whether they should represent you 23 or not in light of those circumstances?

t 4

l 24 A

Yes, I have.

25 Q

Is it agreeable with you that they continue to 7

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1 represent you, notwithstanding those possibilities?

2 A

Yes.

3 JUDGE KELLEY:

Counsel, do you want to elaborate 4

at all on these points?

I'm not suggesting you need to.

5 MR. MC BRIDE:

Judge Kelley,_the matter has been 6

discussed with Mr. Illjes.

It has also been discussed with 7

Mr. Chwastyk.

I have no objection to the Board putting the 8

same questions to Mr. Chwastyk when he is here on Friday and 9

I believe that covers the matter.

We believe that at all 10 times we have carried out our professional responsibilities 11 throughout the 6-1/2 years that we have represented these

()

12 gentlemen and I believe our judgment was borne out by Judge 13 Rambeau's order, by the Board's rule of July 16th, and we 14 continue at all times to feel obliged to comply with the Code 15 of Professional Responsibilities with respect to these 16 matters and we believe we have done so.

17 JUDGE KELLEY:

The Board in raising the question 18 is not implying that you have not lived up to your 19 responsibilities.

20 MR. MC BRIDE:

I understand that.

21 JUDGE KELLEY:

We simply see surfacing here on the 22 record a potential conflict or actual conflict, at least 23 potentially, in the testimony.

And it seemed appropriate for 24 us on the record to have asked about the matter.

25 MR. MC BRIDE:

I agree with that.

I think it has ACE-FEDERAL REPORTERS, INC.

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1 been satisfactorily resolved.

I think we have an obligation 2

to the Board as officers of the Board and we feel that we 3

have carried out those responsibilities.

4 JUDGE KELLEY:

Thank you.

We may raise it again 5

in some other circumstance, to obtain the witness' view in 6

the circumstance as it may arise.

I think I have already l

7 indicated, I'll indicate again, that there are, sort of

'8 subtle gradations of potential and actual conflicts.

I have 9

already said, I'll say again, we haven't raised this matter 10 every single. time something like that may have been f

11 foreshadowed-in the testimony but we've raised it here for

()

12 the reasons stated.

We may raise it again.

And I think we 13 are satisfied with the disposition of it in this case.

14 MR. MC BRIDE:

I appreciate that.

I think the 15 Board should feel -- should not feel reluctant to raise the

[

16 matter if the Board has a concern.

We'll be happy to discuss i

17 it with you.

If you feel the necessity to raise it with the 18 witnesses, that's your privilege and I would expect you to do 19 so.

20 JUDGE KELLEY:

Fine.

We have a few follow-ups.

21 BY JUDGE CARPENTER:

22 Q

Mr. Illjes, we have some follow-up questions 23 submitted by counsel for the numerous employees.

24 The first reads:

When was NRR test 147 performed?

O 25 A

It's dated 3/14/1979.

I take it, it is 1205.

ACE-FEDERAL REPORTERS, INC.

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Q I couldn't hear you.

2 A

3/14/1979, 1205.

3 Q

During the time period in which NRR test 147 was 4

performed, was the rate of identified leakage higher, lower, 5

or the same as in the fall of 1978, if you remember?

6 A

Well, the closer we got to the day or the time of 7

the accident, the leak rate was much higher.

So there were 8

many more times in which we had to add water to the makeup 9

tank.

Much more concern and difficulty in having to take 10 time out to maintain the rods within the normal bands of 11 control rod insertion.

()

12 Q

This is a series of small questions that perhaps 13 most appropriately could be answered with small answers.

The 14 question was high, low or the same.

I think you answered 15 high?

16 A

Right.

17 Q

Did the leakage that occurred in March 1979 cause 18 boron to concentrate in the reactor coolant system?

19 A

The leakage in 1979?

20 Q

Yes.

Right, March of

'79, cause boron to 21 concentrate in the reactor coolant system?

22 A

Yes, it did.

But it specifically concentrated in 23 the pressurizer and we had a certain -- I know you want a yes l

24 or no answer, but there's more to it than yes and no, I 25 feel.

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Q Go right ahead.

2 A

What we had to do was more or less put the 3

pressurizer on recire with the reactor coolant system, by 4

maintaining the spray valve open.

5 Q

The question reads, next question reads:

What 6

effect did concentration on boron have on the rod position?

7 I agree with you it is important to make the 8

distinction between the accumulation of boron in the 9

pressurizer and a change in concentration in the part of the 10 reactor where the rods were.

11 A

The pressurizer was the location in which the

()

12 boron was concentrated because that's where the relief valve 13 flow path was.

So that's -- that would be the hottest place 1

14 in the reactor coolant system and that's where, as the leak 15 came off the top of the pressurizer through the -- the water 16 level would decrease in the pressurizer and concentrate.

It 17 wouldn't necessarily -- I shouldn't say " decrease" because 18 there's a level control that maintains the same level.

But 1

19 the water would drop out of the makeup tank and by boiling 20 off in the pressurizer, it would concentrate in the 21 pressurizer.

22 To prevent -- if we let that go for a period of 23 time and-you had an outsurge in the pressurizer, all of a 24 sudden you'd have a large higher concentration of borated 25 water going to the reactor coolant system, and there were a ACE-FEDERAL REPORTERS, INC.

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i (V[28397.0 BRT 3092 u..

1 couple of instances when we learned the hard way, when all of 2

a sudden we lost --

3 Q

Do you understand the cause of those outsurges?

4 Was it the density of the water in the pressurizer got 4

5-sufficiently high to cause it to fall?

G A

'No, sir.

It would just be a change in power or a 7

bump someplace in the system, or, periodically, we recirced 8

the pressurizer by opening the spray valve.

What this 9

allowed is the concentration to equalize between the 10 pressurizer and the reactor coolant system; but the initial

.11 outsurge,.when you put the spray valve on, caused that higher Ik

.12 concentration of borated water to move in the reactor coolant 13 system and the rods would come out to compensate for-the 14 higher concentration and sometimes there was not enough 15 control rod or reactivity left in the control. rod to 16 compensate for the higher concentration of boron which went 17 into the reactor coolant system, and I take.it you understand 18 the rest of what happens when you run out of control rod.

19 Q

To be sure the record is clear, the question l

20 reads:

Did the leakage occurring in March of '79 cause boron 21 to concentrate in the reactor coolant system?

22 A

Yes.

1 23 Q

What effect did concentration of boron have on rod i

24 position?

l 25 MR. MC BRIDE:

I think, Judge Carpenter, that he I

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just answered the question.

2 BY JUDGE CARPENTER:

3 Q

I would like to make it clear.

As there was an 4

accumulation of boron in the prersurizer because of the loss 5

of water, would that have an effect.on the rod position?

6 A

Yes.

7 Q

Even though the boron was still in the 8

pressurizer?

9 A

Because we -- you always had a certain amount of 10 recirc through the spray valve, and I believe there were 11 times in which we -- I forget the time interval, but we

()

12 opened the spray valve every so often to equalize the 13 concentration between the pressurizer and reactor coolant 14 system.

15 Q

Clearly, when you open the spray valve it moved a 16 lot of boron out of the pressurizer back into the primary 17 circulating system; that would have affected the rods.

Would 18 you say also there was kind of a dribble back out of the 19 pressurizer?

20 A

I think there was a certain flow rate so you 21 wouldn't shock the valve.

I forget the --

i 22 Q

I see.

This is all in the context of NRR test 23 147.

The next question ist Had demineralized water not been 24 added to the makeup tank to make up for the water loss 25 through the code safety valve, would the rod position have i

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moved out of the permissible bands, if you know?

2 A

What happens, it would move -- the rods would go 3

all the way out, which -- you can go to 100 percent 4

withdrawal of the rods.

That is not really out of the band.

5 But you lose control of your -- there's other controlling 6

functions which the rods cause, such as power level, such as 7

average temperature and it is all integrated into one 8

system.

9 Q

I understand.

But, specifically with respect to 10 test 147, do you know that that situation prevailed?

How can 11 we, in looking at the papers that are before us, know that

/~

12 that situation prevailed?

I certainly agree with you that 13 it's a possibility.

14 A

I don't recall any other reason for doing it.

We 15 were adding demineralized water.

If we were adding just 16 water to makeup, we would have added water from a bleed tank 17 which you keep at the same concentration; somewhere close to l

18 the reactor coolant system, boron concentration.

I 19 Q

so, is it a safe generalization that when 1

20 demineralized water was added it is for the purpose of 21 adjusting boron concentration?

22 A

Yes, sir.

23 Q

Concerning NRR test 147, if you entered 500 24 gallons into the computer but did so on the wrong line of the fs 25 computer sheet, did you mistakenly enter the water addition ACE-FEDERAL REPORTERS, INC.

202 347 3?io Nationwide Coserage RO-3%6M6

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1 or deliberately alter the leak rate test?

2 A

I mistakenly put it in the wrong place, sir.

3 Q

With respect to NRR test 123.

Would you turn to 4

that?

5 The question reads:

With respect to NRR test 123, 6

with any other leak rate test that you performed, did you 7

ever add hydrogen to affect a leak rate test?

8 A

No, sir.

I did not add hydrogen to affect a leak 9

rate test.

10 Q

Do you recall whether you knew that, during NRR 11 test 123 --

O.

(_)

12 A

No, sir.

I did.not.

I stated before that I did 13 not become aware of the effect of hydrogen --

14 Q

I didn't finish the question.

It was a comma.

15 I'm sorry.

16 Q

Do you recall whether you knew that, during NRR 17 test 123, you knew that the auxiliary operator was adding 18 hydrogen to the makeup tank; if you remember?

19 A

No, sir.

I don't recall the specifics at all of 20 that day or of the auxiliary operator adding hydrogen.

21 JUDGE CARPENTER:

Thank you.

Any other follow-up 22 questions?

23 MR. MC BRIDE:

Not from us, sir.

24 MS. WAGNER:

Not from the Staff.

25 JUDGE KELLEY:

Mr. Illjes, that brings us to the ACE-FEDERAL REPORTERS, INC.

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conclusion of our questioning process.

We appreciate your 2

- coming down and your attentiveness to questions, your 3

responses.

Thank you very much.

You are. excused.

4 (The witness stood down.)

5 MR. MC BRIDE:

Would you lik'e-the next witness?

6 JUDGE KELLEY:

Why don't we take a short break --

7 about 20 minutes.

8 (Recess.)

9 JUDGE KELLEY:

Mr. Conaway.

Good afternoon,_my 10 name is Kelley.

On my right is Judge Bright, on my left is 11 Judge Carpenter.

()

12 Whereupon, 13 WILLIAM T.

CONAWAY, II 14 was called as a witness and, having first been duly sworn, 15 was examined and testified as follows:

l 16 EXAMINATION l

17 MR. PK: BRIDE:

I 18 Q

Sir, would you please state your full name?

i l

19 A

William Theodore Conaway, II.

20 Q

Do you have before you a seven-page document 21 bearing the caption of this proceeding and bearing the title 22

" Prepared Statement of William T.

Conaway, II"?

I 23 A

Yes, sir.

1 l

24 Q

At this time do you have any additions or 25 corrections you wish to make to that statement?

I

(

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A No, sir.

2 Q

Do you adopt that statement as your prepared 3

testimony in this proceeding?

4 A

Yes, I do.

5 Q

Just before we went on the record, Mr. Conaway, 6

did you have the opportunity to review a three-page 7

single-spaced document which appears to be a report by Mr.

R.

8 Keith Christopher, of an interview conducted with you on 9

November 8, 1985?

10 A

Yes, sir, I did.

11 Q

Did you also have an opportunity during that break

(,,g 4

i 12 to review your attorney's notes of the same interview?

13 A

Yes, sir.

14 MR. MC BRIDE:

Thank you, Judge Kelley.

15 JUDGE KELLEY:

Thank you.

The prepared statement 16 will be bound into the record at this point.

17 (The document follows :)

18 l

l 19 20 21 22 23 24 l

(1) 25 i

ACE-FEDERAL REPORTERS, INC.

202-347-37(U Nationwide Coserage 8M33M486

s 9e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN BEFORE THE PRESIDING BOARD

)

In the Matter of

)

)

INQUIRY INTO THREE MILE ISLAND

)

Docket No. LRP UNIT 2 LEAK RATE DATA

)

)

FALSIFICATION

)

PREPARED STATEMENT OF WILLIAM T. CONAWAY, II II.

I reside in My name is William T. Conaway, Wrightsville, Pennsylvania.

I am currently employed by GPU

{~')

Nuclear as the Radioactive Waste Support Manager at Three Mile Island Unit 2.

I no longer hold an NRC license.

for Metropolitan Edison Company in 1973.

I I began working was an auxiliary operator at Unit i until I was promoted to a Control Room Operator (CRO) at Unit 2 in 1975 and later licensed.

In 1978, I was promoted to Shift Foreman.

My Shift I supervised CRO's Ted Illjes and Supervisor was Joe Chwastyk.

John Kidwell.

At the time of the accident at Unit 2, I was a Shift Foreman.

I was to supervise the people on my As a Shift Foreman, I was responsible for the shift shift.

In the control room, foremen's log and for the general paperwork that came through j

there.

I also spent a lot of time out of the control room and g

4

(~\\

although I cannot state precisely just how much

~

in the plant, of my time was spent in the plant.

As a shift foreman, I did in general directly supervise the auxiliary operators not Usually the control room operators gave instructions c

(AO's).

4 to the AO's.

I do not recall attending very many shift foremen meetings.

They were held at Unit i regularly, but I did not always know when they were being held.

In any event, it was I do not not mandatory to attend if you were not on shift.

recall any discussion of leak rate testing or invalid leak rate tests at any shift foremen meeting.

I understand that I was required, as a shift foreman, to (G^)

ensure that all surveillance testing, including leak rate testing, was conducted in compliance with tlRC regulations.

Although I approved the results of leak rate tests, I do not recall specifically exercising direct supervisory control over the tests.

In fact, there were many times that surveillance tests were begun or completed without my specific knowledge at that time.

I expected the CRO's on my shift to comply with the plant procedures for all testing including leak rate testing, look and owing to the confidence I had in my CRO's I did not over their shoulders while they ran the test.

We used the leak rate test to demonstrate that the plant was operating within the limiting conditions for operation for reactor coolant system leakage.

However, we verified that the limiting conditions for

(

plant was operating within the _. _ _.

Ph( 'l We did not have a operation by reviewing the plant parameters.

itself.

The Operations lot of faith in the leak rate test in general had little confidence in the validity of Department A lot of the tests were not valid.

For the leak rate test.

Often the example, we got a lot of high negative leak rates.

leak rate did not agree with the actual leakage we determined by reviewing other plant parameters.

We reviewed and relied on the makeup tank level to determine RCS leakage.

In retrospect, we relied too heavily on the makeup tank level.

We also used the containment radiation monitor and the containment sump inventory and discharge to ensure that there was no safety concern that must be O

addressed.

~/

I am not as familiar today with the technical specifications and administrative procedures governing the leak rate test as I was in 1978-79.

It has been a very long time required to have an understanding of these since I was requirements.

However, I feel they did not prohibit the Nor addition of water to the system during a leak rate test.

did they prohibit feed and bleed operations.

We were primarily concerned with the safe operation of I

Unit 2 in 1978-79.

We were not as concerned with the administrative requirement of demonstrating that the plant was limiting conditions for operation for RCS operating within the leakage.

We regarded the actual plant safety as more important

\\

than the leak rate tests, the pieces of paper, that were often i

invalid.,

r e.7 y

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("T I do not recall any specific pressure to throw away leak

()

rates above 1 gpm or to avoid entering the action statement, I was shut down for refueling before the even when Unit to recall feeling pressure from management accident.

Nor do I get a good leak test, that is, one showing less than-1 gpm of unidentified leakage, even when a lot of time had passed since the last good test.

to avoid adding water to the RCS during leak We attempted rate tests.

But we did if it was necessary to change the boron level.

We used concentration in the RCS or to maintain the MUT to determine just how much water to add to a calculation sheet We would then send the system for boron concentration changes.

to the Ops Engineer for his review.

[')

the calculation sheet log Usually, we logged water additions but we did not v

I did not generally question the CRO's on hydrogen additions.

my shift about operator changes to the system during a leak However, if I had known rate test when I approved the test.

that water had been added during a test yet had not been accounted for, I would not have approved the test.

leak aware of any practice to add water during a I was not rate test and not account for it in order to affect the test Nor did anyone ever discuss with me unlogged water result.

additions.

We added hydrogen to the MUT to maintain a certain pressure There were two valve operators to add hydrogen located band.

\\-

near the MUT

rip chart.

Usually, the CRO at the panel opened

(~}

4

jV For a period of time, the valve these to add hydrogen.

in the and a bottle of hydrogen operators did not work, In that case, the auxiliary building was used to add hydrogen.

an AO to actually add the hydrogen.

CRO had to request recall discussing with anyone prior to the I do not leak rate accident hydrogen additions to the MUT to affect there are several tests run by my shift tests.

I was told that l

involving allegations of hydrogen additions to affect the But I was never aware of the use of hydrogen results.

Moreover, I am additions to influence leak rate tests.

the technical experts disagree in their overall informed that analysis of those tests.

I am informed that Joe Chwastyk indicated that he learned

()

of the effect of hydrogen additions on leak rate tests prior to to add hydrogen to the accident and instructed the shift not I am informed that he did so after a the MUT during the tests.

to his attention and he conducted an experiment CRO brought it I do not know that Joe had any to investigate it.

However, knowledge of the effect prior to the accident or that he the tests.

Joe could instructed us not to add hydrogen during but I just do not recall any.

I have conducted an experiment 1979 experimental am informed that I approved the February 19, test Joe recorded the results of that leak rate test and that I have no recollection of being in his notes.

However, involved in that test, and I do not recall any discussion by O'

the CRO's of the effect of hydrogen additions on leak rate 5-

o it to my attention as far as I Nobody ever brought y

tests.

know, with the exception of Marty Cooper, after the accident.

never approved the use of hydrogen additions to influence I

leak rate tests and I never myself used hydrogen for that purpose.

Apparently, I approved a test on February 19, 1979, recorded the results in my log, and later crossed the results I assume I I do not recall crossing the results out but out.

I do not recall that did so because the entry was incorrect.

it had anything to do with the experimental test Joe ran on that day.

recall any knowledge of a problem with one of the I do not MUT level transmitters in 1978-79.

I understand now that there

()

was a problem but this understanding is based on knowledge I I am informed that there have acquired since the accident.

were two work requests in December 1978 that I signed that are But I do not recall signing for a defective level transmitter.

them.

Nor do I recall discussing a bad level transmitter with to use it.

I was the CRO's on my shift or instructing them not not aware of any practice to switch the bad level transmitter in order to get a good to the computer during a leak rate test 2

test, that is, a test below 1 gpm.

In fact, I do not understand how switching the level transmitter could influence I never overheard any discussion among the the leak rate test.

Unit 2 operators regarding the switching of the level I am informed that there transmitter to influence the test. '

4

4 e

m in which the bad level

(_)

were several tests run by my shift I was not aware of any practice transmitter was used.

However, to use that transmitter to get good leak rate tests.

In conclusion, I did not participate in or have knowledge of any leak rate test falsification, and I ask the Presiding in such Board to exonerate me of any alleged involvement I have been in the nuclear industry for thirteen

-practices.

I would also like to put years and would like to stay here.

the issue of TMI-2 leak rate testing behind me.

At the same time, I have learned a lot from the leak rate test investigations and have come to appreciate the value of conservatism in the interpretation of and compliance with I will continue to

(}

procedures and regulatory requirements.

apply these lessons in the future.

-7

-(') 28397.0 s/ BRT 3098 1

JUDGE KELLEY:

I have a short statement that I'll 2

read to you, Mr. Conaway, as sort of an introduction to our 3

questioning process, for context of what we are doing.

4 The Board has been charged by the Commission to 5

determine the extent of involvement of individual employees 6

of TMI-2 in 1978 and '79 in leak rate test falsification and 7

other improper practices in leak rate testing.

This is your 8

opportunity to state on the record your recollections and 9

perceptions about your involvement in leak rate testing at 10 that time, and to rebut any adverse statements about you by 11 other employees or investigators with which you disagree.

O)

(_

12 We have reviewed your prefiled testimony and we 13 have considered it in light of the record that has already 14 been developed in this proceeding.

We will have some 15 questions for you based on your prefiled testimony and upon 16 any prior statements that are already in the record.

We may 17 also have questions based on statements of other employees at 18 TMI-2 that they have made about you or about matters in which 2

19 you might also have been involved and we also may have some 20 questions and assessments that technical investigators have 21 made about your participation in leak rate activities.

22 l As you may know, there are extensive studies of 23 TMI-2 leak rate procedures already in the record, one by 24 Mr. Stier, done for GPU Nuclear, and another study by the NRR 25 staff.

The Stier study includes an analysis of every leak ACE-FEDERAL REPORTERS, INC.

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1 rate test conducted at TMI that was retained, that is not 2

thrown away.

The NRC study includes analyses of every 3

retained test during the last six months of operation.

4 The Board has already heard extensive technical 5

testimony on leak rate testing questions, including testimony 6

elicited by your counsel on numerous particular tests.

In 7

these circumstances the Board does not propose to review with 8

you each and every test in which the investigative studies 9

indicate you may have been involved.

Those were available to 10 you through counsel and you were free to discuss particular 11 tests in your prepared testimony if you chose to do so.

()

12 We may ask you a few questions about a few 13 particular tests, but apart from that the analyses of tests, 14 whether or not we speak about them here, are in the record 15 and will be considered in light of the entire record, 16 including your testimony here today.

With that I'll turn to 17 Judge Bright.

18 EXAMINATION BY THE BOARD 19,

BY JUDGE BRIGHT:

20 Q

Mr. Conaway, the three-page statement from OI that 21 you said you read during the break?

22 A

Yes, sir.

23 Q

Do you have any disagreement with 24 l Mr. Christopher's reporting of their interview with you?

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25 A

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here.

One statement that he made was that I was a licensed 2

' operator on Unit 2 for approximately 2-1/2 years.

I'm not 3

sure that that's totally correct.

I was assigned as a CRO, I 4

think, for approximately that period of time, but I was not 5

licensed for that entire period of time.

6 Q

Just a moment, Mr. McBride, do you have that that

.7 you can let the witness have?

Because I would like to get my 8

copy back so I can correct it.

9 MR. MC BRIDE:' Yes, sir.

I a: about to bring it 10 to you.

11 BY JUDGE BRIGHT:

A(_)

12 Q

If you can point out where that was, we can amend 13 it right here.

14 A

First paragraph, first page, about the third line 15 up from the bottom:

"He was a licensed operator on TMI-2 for 16 approximately 2-1/2 years."

I don't think I was licensed for 17 that entire period of time.

18 Q

How would you care to rephrase that?

Would you 19 rather have something besides 2-1/2 years in there?

20 A

Just eliminate the word " licensed."

I was an 21 operator for approximately that period of time, or I was a 22 control room operator for that period of time.

23 Q

If we delete " licensed," would that be a true 24 statement, then?

g-)

(_/

25 A

I think so.

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JUDGE KELLEY:

Is it that you were a trainee part 2

of the time?

3 THE WITNESS:

Trainee is probably the more correct 4

term.

I was in the first class of CROs to be assigned to 5

Unit 2.

We also acted as auxiliary operators during the 6

initial part of the time we were assigned there.

Then we 7

were in training for the CRO function.

8 JUDGE BRIGHT:

So we could substitute " operator 9

trainee" for " licensed operator"?

Would that satisfy you?

10 THE WITNESS:

Well, that I don't think describes 11 it either, since for part of that time I was licensed.

()

12 MR. MC BRIDE:

I would suggest, Judge Bright, it 13 might be easiest if you just substitute the word " assigned" 14 for " licensed."

15 JUDGE KELLEY:

I think the colloquy here in 16 transcript will clear it up in any case.

17 MR. MC BRIDE:

Certainly.

18 BY JUDGE KELLEY:

19 Q

Were you licensed most of the time, that 2-1/2 20 years?

21 A

I don't think so.

I think the majority of the 22 time I was not licensed during that time period.

23 JUDGE CARPENTER:

Do you remember the date at 24 which you received your licence?

25 THE WITNESS:

No, sir.

I don't recall.

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BY JUDGE BRIGHT:

j 2

Q Do you think this is a big thing?

3 A

Pardon me?

4-Q Do you think this is a big thing?

Because I 5

don't.

6 A

Whether I was licensed or not during that time 7

period?

No, sir.

8 Q

All right.

I certainly agree with Judge Kelley, 9

that what we have been saying about it should have clarified j

5 10 it.

11 Is there anything else?

()

12 A

Just that I would like to state that I think the 13 notes from my attorney that I reviewed during the time of the 14 interview were more complete than the report that was 15 submitted.

16 Q

Unfortunately, we don't have access to your 17 attorney's notes.

18 MR. GEPHART:

Judge Bright, I would indicate that 19 the notes that I took of the same interview are Q and A 20 notes; every question, every answer.

21 BY JUDGE BRIGHT:

22 Q

Do you find any conflicts between this and --

23 MR. GEPHART:

The three-page document that i

24 apparently was produced by Mr. Christopher, I believe, are I

i 25 Mr. Christopher's perceptions of the total interview.

I l

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don't find conflicts so much as I find omissions.

2 JUDGE BRIGHT:

If you think that's vitally 3

important, I would be only too happy for you to fill in the 4

omissions.

You don't have to today, because I don't intend 5

to use this, f

6 MR. GEPHART:

Fine.

I didn't know where you were 7

going with this document.

T 8

JUDGE BRIGHT:

No, I merely wanted -- it's in the 9

record but it's only an interview report.

I wnnted to make 10 sure that there was nothing wrong with it when I'm looking 11 through the book.

That was the only thing I wanted.

()

12 MR. GEPHART:

Okay.

13 JUDGE BRIGHT:

All right with you, Mr. conaway?

14 THE WITNESS:

Yes, sir.

15 BY JUDGE BRIGHT:

16 Q

All right.

With that behind us, I have a few 17 questions here.

I think we can leave out an awful lot that 18 you put into your prefiled testimony and in your previous 19 statements and just get right down to it.

20 First, could you state in your own words what was 21 your opinion of the value of the leak rate test that you were 22 doing?

23 MR. MC BRIDE:

Again, Judge Bright, I take it your 24 questions relate to the time period in question, that is, O

i f

25 prior to March 28, 1979?

i r

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JUDGE BRIGHT:

That is exactly right.

2 BY JUDGE BRIGHT:

3 Q

What were you thinking at that time?

4 A

Well, I think it was my opinion at the time that 5

it was more -- more an administrative matter and, because of 6

the quantity of what appeared to be erroneous results, we 7

didn't view it as having a great deal of validity in actually 8

determining the leak rate from the system as we viewed it.

9 Q

Does this say that you had little faith in the 10 results that you were obtaining from the leak rate tests?

11 A

That's correct.

()

12 Q

And that, therefore, they really weren't doing you 13 much good, just causing grief?

Larger or lesser grief, it 14 doesn't have to be agony.

15 A

Yes.

I think that's a correct statement, that we 16 viewed them as a problem to get an acceptable -- what we 17 considered at the time an acceptable leak rate.

Of course, 18 the ones that we considered unacceptable or invalid we threw 19 away.

I would certainly not do that today, but that was the i

20 l action that we took at the time.

21 Q

Well, let me ask you what I asked everybody else.

22 During your training, formal or on the job or whatever i

l 23 i respect, was it ever brought out to you, the technical reason I

24 for having a leak rate test which would measure the thing to O

25 whether it was less than 1 gallon per minute leakage, ACE-FEDERAL REPORTERS, INC.

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unidentified leakage?

2 A

No, sir.

I don't recall ever getting anyl training 3

on a leak rate.

4 Q'

So the safety implications of doing a leak rate 5

test of that kind were never really explained to you, I 6

gather?

7 A

That's correct.

8 Q

Going on, this is a subjective sort of question.

9 You state that you were unaware of any manipulation of LRTs.

10 I assume that this includes all of the shifts, not just your 11 own, that you were not aware of anyone in the plant

()

12 manipulating leak rate tests?

13 A

That's correct.

I was not aware, more 14 specifically, of any manipulation on my shift.

And there 15 would be little opportunity for me to know exactly what was 16 done on the other shifts.

But there was never a time period 17 where I heard anything that would lead me to believe that l

18 there was any manipulation of leak rate tests going on prior l

19 to the accident.

l 20 Q

This has been a little puzzling to me as this has 21 gone on.

There seems to be quite good evidence, and in fact 1

j 22 some mea culpas, about leak rate manipulations.

And they 23 seem to be sort of scattered around tho plant, that a 24 significant number of people knew that there was some sort of g-v 25 hanky-panky going on.

I am just wondering if you had any i'

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kind of explanation, how come you never heard anything about 2

any of this?

3 JUDGE KELLEY:

May I ask the witness whether he 4

knows what the phrase " mea culpa" means?

5 THE WITNESS:

Not specifically.

I have heard the 6

term before and I have an idea.

7 JUDGE KELLEY:

Literally it means "through my 8

fault."

It means, "I'm sorry" or "I confess"; fair enough?

9 Various people have said, to investigators, yes, I 10 manipulated leak rate tests.

I'm sorry I did it..

That's the 11 context.

()

12 THE WITNESS:

An explanation that I have for 13 possibly not knowing what was totally going on is, first off, 14 I don't live in an area where a lot of the other operators 15 live.

I don't -- I didn't spend a lot of time socializing 16 with the other operators from other shifts, therefore there 17 was not a great deal of time that we would spend in a social 18 atmosphere discussing the plant or things that were done at 19 the plant.

20 As far as the time that I spent at the plant, 21 normally you would come on shift in time to take a turnover; 22 !

you would be interested in learning about any conditions that l

23 would have some effect on your shift or the general, overall i

l 24 plant conditions, and the operator that you were relieving s

25 was interested in getting that information imparted in a i

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reasonable amount of time so that he could leave.

Therefore, 2

there were not very many social discussions, or discussions 3

about particular things that went on with regard to 4

independent shifts.

5 As I recall, in general there were things that one 6

shift did in different ways from another shift.

It's as 7

though each shift had its own independent personality and it 8

was driven by the people that were on that particular shift.

9 A lot of those independent matters were not transmitted along 10 to other shifts unless they had some specific effect on the 11 other shift.

()

12 MR. MC BRIDE:

Judge Bright, might I just ask the 13 witness to pull the microphone a little closer to him.

14 JUDGE BRIGHT:

Yes.

These mikes are not the most 15 sensitive instruments in the world.

16 BY JUDGE BRIGHT:-

f 17 Q

Let me ask you this:

If there had been 18 manipulation on your shift, would you really have discovered 19 it?

By that I mean, did you actively try to validate these 20 tests and do things such as looking at water inputs and 21 outflows and whatever else you need to validate the test?

Or 22 were you more inclined to accept the bottom line if it was 23 what we call a good leak rate test?

24-A I was more inclined to accept the bottom line.

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indication or that kind of thing to specifically validate 2

tests that were performed.

I think that the only way that I 3

would have known of manipulation, perhaps, is if I would have 4

heard it in a discussion:

We found -- you know, as someone 5

would say -- we found a method of getting a good test, and 6

discuss it in that manner.

There was no indication that I 7

had that that was the case.

8 Q

Just for the record, did you ever have occasion to 9

enter a D or E, exception or -- what's the other word --

10 MR. MC BRIDE:

Deficiency.

11 BY JUDGE BRIGHT:

)

12 Q

-- or deficiency, in a leak rate test?

13 A

No, sir.

I don't think -- in fact I'm almost 14 positive that during that time period we never entered an E&D 15 sheet on a leak rate test.

In retrospect it is something i

16 that we, obviously, should have done.

But at that particular 17 time I don't think it was ever done.

18 Q

Was it your understanding that this was the 19 accepted procedure at the plant for all shifts?

20 A

For the leak rate test?

Yes, I think that's the 21 case.

22 !

Q Did you ever have occasion to enter the action 23 statement?

24 A

No, sir.

I don't believe we ever entered the 25 action statement.

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Q On that particular vein, I have asked this of 2

other people, the procedures in the tech spec as it is 3

written, and further clarified by the NRC, I understand, says 4

that if you have a bad leak rate test, over 1 gallon per 5

minute, then you have four hours to start shutting the 6

reactor down; four hours in which you either find out that 7

the test was invalid or demonstrate in some way that you 8

really don't have a leak rate that is that high.

9 Did you ever find yourself in that position?

Like 10 you come on shift, 30 minutes into the shift you run a leak 11 rate test.

It turns out to be a bummer.

Okay?

()

12 Now, you've got 6-1/2 hours left on that shift; is 13 that correct?

14 A

Approximately; yes, sir.

15 Q

Okay.

So then I presume the first thing you would 16 do would be to run another leak rate test.

Would that be 17 your reaction?

18 A

Yes, sir.

19 Q

Was there ever a time, an incident where something 20 like that actually happened?

21 A

Yes.

I can't think of a specific instance, but I 22 do recall that that was -- that, especially early on with 23 doing leak rates, that that was -- that we had operators that 24 did go and look for leaks and try to identify leakage.

I

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identify leakage.

2 I think that, as time went on, that we probably 3

got away from that practice and the specifics because our 4

feelings for the plant's operation, we thought, dictated that 5

the leak rate was invalid on its own and from that we tended 6

to get away from the specific identification of leaks every 7

time we did a leak rate that was bad.

8 Q

On discarding leak rate tests, did everyone on 9

your shift have the authority to invalidate a leak rate test 10 for good reason?

Let's put it that way.

11 A

Yes.

I think everyone on my shift, whether it.was

(_)

12 an assumed case or however it came to be, I think everyone on 13 shift at one time or another probably discarded a leak rate.

14 Q

So it wasn't a standard practice for them to go to 15 you if they had a leak rate test that was over 1 gallon per 16 minute, to go to you and work with you to see whether the 17 test was invalid or not?

18 A

No, sir, I did not --

19 Q

They would do it on their own?

20 A

I did not have, always, the final word.

Quite 21 often I did not even see the test.

22 Q

Did you ever have a test, that you can recall, 23 where you actually went to Mr. Chwastyk with it to see what 24 he thought about it?

25 j A

I can't recall a specific case where I took a test I

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.to Mr. Chwastyk and discussed it.

He was in the control room 2

quite often.

I'm sure he was aware of the tests and what was 3

going on, but I don't know that we had any specific 4

discussions about any one test.

I don't recall any -- any 5

specific discussions.

6 Q

Well, I wonder.

You state somewhere in your 7

testimony that you were out in the plant a lot and 8

Mr. Chwastyk was probably in the control room more than you 9

were.

Anyway, he was in there quite a bit and you would not 10 be there.

11 A

Yes, sir.

()

12 Q

Okay.

In a situation like that, and the CRO, 13 perhaps, felt that he needed to talk to somebody about a 14 test, would they feel free to go to him with this?

15 A

Yes, sir.

Absolutely.

Yes.

16 Q

Speaking of Mr. Chwastyk, there has been some --

17 well, I guess he has made the statement that he ran an 18 experiment, let's say, to determine what the effect of adding 19 hydrogen to the makeup tank had on leak rate test results.

20 You know nothing about these tests?

Or were you aware of 21 them?

22 A

I was --

23 Q

Or it, whichever the case may be?

24 A

I was not aware at the time of any tests that he 25 ran to determine hydrogen effect on a leak rate test.

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course, since the accident I have been made auare of it 2

several times.

But prior to that I have no recollection of

~

3 ever being informed that he ran a test or informed of the 4

effect that hydrogen had on a leak rate.

5 Q

And I believe he also recalls specifically that he 6

ordered the control room people not to add hydrogen during a 7

leak rate test.

Do you know anything about that?

Were you 8

aware of it?

9 A

No, sir.

As I stated before, I don't have any 10 recollection of him performing the test or informing us of 11 the experiment or any results of any experiment or giving us

<^i

(,/

12 any prohibitions against hydrogen addition during the leak 13 rate.

14 Q

Well, let me ask you this, if he had done 4

15 something like that, if he had come down in the control room 16 and you happened to be out in the plant, would he have issued 17 that kind of blanket order without informing you about it, in 18 your opinion?

Would you think he might?

4 19 A

It would be very possible that he would tell the 20 CRO something that he didn't make a specific point of telling 21 me.

In general we tried to keep each other informed but it 22 was -- it would not be unusual for him to do something and 23 just forget to tell me.

24 Q

Chain of command is not the strong point, I 25 presume, back in those days?

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'l A

Particularly for Joe.

Joe is a very strong 2

individual and he knew exactly what he wanted.

If he wanted 3'

something from someone, you know, he would not necessarily 4

use the' chain of command to make sure that that person knew

~

5 or to get what he wanted.

6 Q

What were your personal relations with 7

Mr. Chwastyk?

How.did you get along?

Would you say you 8

worked well together?

~

9 A

I think that'we worked fairly well together.

I i

10

.didn't have any real social ties-with him.

We would seem to 11 function fairly well as a shift, and to function well as.a

, ()

12 shift it means that everyone, usually, has to do his part to 13 make the shift run smoothly and to get the work i.

14 accomplished.

As far as Joe was concerned, when he wanted 15 something, that's what he wanted.

And I made an effort to i

16 get done what he wanted done.

17 I could talk with him if I needed to.

There was 1

18 not much in the way of discussing things with Joe.

You could 19 possibly tend to point out an item that perhaps you disagreed 20 with but he would very quickly make his desires known unless 21 it was -- you had an extremely strong point for not doing it 22.

his way or for not performing whatever it was.

You know, he 23 let you know that he wanted done what he wanted done.

24

.Q You say in your previous statement that you 25 haven't discussed this business of either the -- him doing 4

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the hydrogen experiment or telling the control room crew not 2

to add hydrogen, or whatever -- you have never discussed this 3

with him?

4 A

That's correct.

5 Q

Is there any particular reason?

6 A

No.

I think that possibly it was a matter of 7

timing in that the time when it came out as far as testimony 8

was concerned, we were really instructed not to discuss our 9

testimony with others.

So, from that point of view it was --

10 I never made an effort to go talk to him.

11 He left the plant a couple of years ago and I (O

,j 12 haven't seen him since, so there would be no opportunity for 13 me to discuss it with him.

14 Q

Was this advice against discussing testimony with 15 other people, was it your counsel that was giving you this 16 advice?

17 MR. MC BRIDE:

Excuse me, Judge Bright, but I feel 18 it incumbent upon me to advise the witness that he is either 19 free to disclose or not disclose attorney-client l

20 communications.

21 JUDGE BRIGHT:

I'll agree with that.

22 BY JUDGE BRIGHT:

23 Q

Let me put it a little differently.

l 24 Did GPU have any policy along those lines that you s

25 are aware of?

6 P

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A I don't recall any specific policy that they had 2

about us discussing testimony.

3 Q

One.other thing.

.Are you familiar with LER78-62?

4 A

I have been instructed about an LER.

I don't 5

recall the number.

Since the accident, regarding other 6

testimony that I have given, specifically're' calling that from

~

J.

7 before the accident I did not.

'8 Q

So the LER, which was back in October of

'78, 9

having to do with higher than allowable leak rates, you 10 really -- you_ don't think that you ever heard of it'or saw it 11 back in those days?

()

12 A

No.

Based on, again, information I have seen 13 since then.

I have seen the LER and seen evidence that my 14 initials were on it, which indicated that I,- in fact, did 15 read it.

So I was aware of it back at that time but I don't 16 recall being aware of it other than through previous 17 testimony.

18 Q

Was there ever any advice or any passing down of 19 the word from on high?

Did your shift supervisor make sure 20 that you were aware of this, so that you could make sure that 21 the CRos were aware of this?

It involved a change in the way 22 '

you were doing business, and a rather important one, I 23 think.

I'm surprised that so few people seemed to have heard 24 about it.

(

25 A

I don't recall ever getting any instruction from ACE-FEDERAL REPORTERS, INC.

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the shift supervisor or from anyone regarding the LER.

The 2

probable mechanism that was used to make us aware of it was 3

it was included in required reading that was passed along 4

from shift to shift that you were required to go through at 5

any particular time.

And that was the normal method for 6

acknowledging that you had gone through the required reading i

7 by initialing a block that was available.

But as far as a 8

specific instruction or reiteration of that LER, I don't 9

recall at all.

10 JUDGE BRIGHT:

Well, thank you, Mr. Conaway.

I 11 appreciate your candor.

)

12 THE WITNESS:

Yes, sir.

13-BY JUDGE CARPENTER:

14 Q

Mr. Conaway, following along the inquiry that 15 Judge Bright was just making, LERs were simply put in the 16 flood of paper, as it were, that were required reading?

Just 17 put one item amongst, perhaps, tens, fifties, hundreds of 18 items to be read?

19 A

As I recall, that was the way the information was 20 passed along, through a required reading list or book.

21 Q

I presume you couldn't keep up, you read every day 22 what came in that day so they must have accumulated for a 23 while; isn't that correct?

That you would pick up the book 24 and maybe you'd have a fair amount to do at one time?

25 A

That's probably the case; yes, sir.

ACE-FEDERAL REPORTERS, INC.

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Q Did you have any feeling that an LER might be 2

different from many of the other documents that you were 3

looking at?

4 A

I don't recall that I had any strong feeling one 5

way or-the other.

6 Q

In your mind at that time, what was distinctive 7

about LERs, if anything?

8 A

I really don't recall if they were distinctive.

9 Q

I'm asking in the sense, as a matter of 10 information,.the Boards get all the LERs from particular 11 plants that they are Involved in in a licensing proceeding

()

12 and I'm under the impression that they are only involved in 13 things that occur in a plant that have safety significance.

14 They are never aware of other things that go on in the plant 15 that I never cee.

I don't learn about turbine problems.

I 16 learn about safety problems.

But apparently that notion 17 about LERs, these are the pieces of paper that speak to what

.18 somebody thinks is a safety consideration, wasn't really 19 obvious in '78 and '79?

20 A

No, sir.

I don't think so.

21 Q

I guess it's pointless to belabor it, but it seems 22 surprising because that's what the tech specs are all about.

23 What is identified by somebody as a safety consideration, and 24 other things are not identified as safety regulations, and 25 LERs are only written about things that are in the tech ACE-FEDERAL REPORTERS, INC.

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specs, I understand.

So it would be a natural, inherent way, 2

that somehow these are things that deal with safety.

But I 3

accept your statement that at that time it didn't look that 4

way.

5 A

I don't recall.

6 Q

Thank you.

7 I have one other very small item.

It's on page 3 8

of your prefiled.

Do you have it there?

9 In the first full paragraph of the page, the 10 second sentence reads:

11 "In retrospect, we relied too heavily on the

)

12 makeup tank level."

Why do you feel that way, in 13 retrospect?

What's wrong with makeup tank level?

If you've 14 got a leak the level goes down, doesn't it?

15 A

Yes, sir.

As the level goes down, of course, you 16 can generalize the slope of the decrease and come out with an 17 assumed leak rate.

18 Q

Assumed or approximate?

19 _

A An approximate leak rate.

Of course, to meet the 1

20 technical specification an approximate leak rate wasn't what 21 they were looking for.

They were looking for specific 22 identification of identified and unidentified leakage.

That, 23 the leak rate test, was, at that time, our only real 24 methodology of getting that specific number, that hard g-(./

1 25 number.

We felt, at the time, that we could look at the ACE-FEDERAL REPORTERS, INC.

202-347 3700 Nationwide Coserage

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makeup tank level and get a good feel for the leakage of the 2

plant with the scatter of results we were getting on the leak 3

rate.

I think we came to rely on the makeup tank as being 4

more characteristic of what the plant was doing, while it 5

wasn't the methodology that we should have been using to come 6

up with the actual hard data.

7 Q

I'm trying to somehow refine your thought here.

8 That seems very reasonable, very professional, to look at the 9

makeup tank level and have some notion, although it might be 10 approximate, of what the leak rate was.

That seems very 11 reasonable.

What I don't understand is when the computer

/~T

(_)

12 told you something that you knew wasn't true, why didn't you 13 challenge the computer?

This is what perplexes me.

If the

~14 evidence was nobody ever looked at the strip chart there's no 15 reason for them to question what the computer has done.

16 I have used computers for many years.

I usually 17 do a back-of-the-envelope calculation.

If the computer 18 doesn't tell me what my calculation tells me, I usually tell 19 the programmer, let's take a look at it again.

I'm not going 20 to be at the mercy of the computer.

I use the computer to 21 assist me.

I'm not the computer.

You say you were aware of 22 what the computer says approximately, and yet the computer 23 tells you it's minus 6, minus 8 -- can you accept it?

That's 24 what's curious here.

O 25 I don't think you relied too heavily on the makeup ACE-FEDERAL REPORTERS, INC.

202 347-3NO Nationwide Cos erage 8(6336-(M6

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tank level.

I think it's more that you didn't question the 2

computer results, which, as you say, would have been your 3

quantitative result.

4 A

In retrospect I think that's true.

5 Q

Did you have any pressure from anybody to not-6 question these things?

7 A

I don't recall any pressure from anyone 8

specifically to throw away leak rates or to accept leak rates 9

that looked strange.

Here again, I think I, for my part, 10 didn't spend enough time looking at the leak rate and trying 11 to figure out what the computer was trying to tell me or --

)

12 was it real?

And then, to go beyond that, I didn't pursue 13 the issue.

14 I know at one point in time there was a change to 15 the computer to do some-rounding-off.

Perhaps that in my

.1 <6 mind made everything okay, that someone elue was looking at 17 it.

And because I didn't' understand the computer and the 18

-methodology it used to come up with the leak rate I didn't i

19 feel that I knew enough to challenge the computer.

20 Q

But you knew what the leak rate was, 21-approximately, looking at the strip chart, 22 A

Yes, I wish --

23 Q

One gallon per minute is two divisions in an 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

If it says minus 8, hey, the slope should be positive 25 instead of negative.

It's pretty clear that that could not ACE-FEDERAL REPORTERS, INC.

202-347-3700 Nationwide Coscrage Suk336-6646

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have happened in that hour, that water appeared in the 2-system.

3 A

I do recall --

4 Q

It seems there's a low threshold for challenging 5

the computer?

6 A

I do recall looking at negative numbers and 7

saying, you know:

How can we be making water?

But I didn't 8

go forward with a challenge, I guess.

I don't know why.

I 9

should have.

You know, today, I know that.

10 Q

Well, some people said they thought they should 11 have been more forceful about this issue.

Do you feel that

()

12 you just had so much press of other business that you never 13 got an hour to spend reflecting on this?

14 A

It was definitely a time when we were all very 15 busy.

You know, that's an excuse that I could offer. hit was 16 a matter that somehow, for some reason, we got into looking 17 at the leak rate test as having a different importance as 18 other surveillances that we looked at a little harder and 19 followed procedural guidelines for Es and Ds.

20 Q

If you had to run every one of these leak rate 21 tests with a manual calculation, do you think you would have i

22 been so tolerant of big negative numbers, if you spent some 23 minutes on the calculation?

24 A

I don't think so.

O 25 Q

Is it fair to say that it's because the computer l

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1 made it easy that it never got to be a sufficient irritant to 2

cause action?

3 A

That's a possibility.

4 Q

Vis-a-vis a manual calculation?

5 A

That's a possibility.

6 Q

I just get that impression that it was, punch the 7

machine to see what it does, rather than any investment.

In 8

many surveillances people did have to, actually, hands-on do i

4 9

the surveillance?

10 A

Yes.

Yes.

11 Q

And became sort of identified with that:

This is

)

12 my surveillance and I'll stand by the result.

I get the 13 impression that is not true of this at all.

That's something 14 that that machine over there did on command, but the 15 individual doesn't have any responsibility for the results.

16 There wasn't anybody you could just pick up the 17 phone and call and say:

Look, we've got a problem over 18 here?

Or anybody you could start a piece of paper towards?

19 A

Looking at it now, I'm sure we could have gone to i

20 the office engineer or ops engineer, or the supervisor of ops l

21 or even the Unit 2 superintendent.

It was not a situation 22 where those people were not available to us.

There was no 23 closed-door policy.

24 Q

Did you have to go up that chain in order to get 25 to the technical support group?

L ACE-FEDERAL REPORTERS, INC.

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1 A

I-think at that time I probably felt that I had to 2

go up the chain and that as long as my supervisor knew of the i

3 problem I'was not required'to. pursue it beyond that.

It was 4

basically stopped there.

5 I think -- you know, I've thought about this over 6

the last'several years; it has bothered me -- and I think at i

7 the time, based ~on my Navy experience and a strict adherence 1

8 to the chain of command perhaps, at that time, that was an 9

influence that I have let dictate my actions perhaps too 10 strongly.

11 JUDGE CARPENTER:

I think you've made the I

12 situation clear.

Thank you.

l 13 JUDGE KELLEY:

I just have a couple of points, 14 Mr. Conaway.

15 BY JUDGE KELLEY:

16 Q

I would like to understand a little better than I 17 do the path that an LER would follow from whoever wrote it in 18 operations or wherever, down to what I gather was a 19 three-ring notebook in the control room; is that right?

Is 20 that where it would come to rest?

21 A

I think so, yes, t

l 22 Q

From your perspective, did you have anything to do l

23 with its getting into the control room and getting into the 24 book?

L ()

25 A

No, sir, i

L ACE-FEDERAL REPORTERS, INC.

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Q How did that work; do you recall?

2 A

I'm not really sure how it worked.

The way it 3

works today is the licensing department is responsible for 4

generating responses to the NRC.

5 Q

Yes.

6 A

But that response is at least drafted by the 7

affected department.

It, of course, gets refined and then 8

reviewed by several departments before it is sent off and 9

then it's filtered on down through the chain of command from 10 the, I guess the director's office through the various 11 department managers and is handled that way today.

/~N

(_)

12 Q

My concern is this:

An LER may have something 13 useful to tell operators in the way of safe operation of the 14 plant.

Does everybody get a copy of the LER, or does a copy 15 just come to the control room and then end up in a book?

16 A

I really don't know the answer to that today 17 because I am not tied into the control room and its operation 18 today.

19 Q

Okay.

Sure.

You are working in rad waste, was 20 that?

21 A

Yes, sir.

In 1979 I think it was the policy for 22 just the LER to show up in the book.

I don't recall that 23 everyone got their individual copy.

I don't think so.

24 Q

Do you remember how it would get in the book?

25 A

No, sir.

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Q For example, the copy that was going to end up in 2

the book, would that go to the shift supervisor who would 3

turn around and put it in the book?

Or would it go to you?

4 How did it get there?

It has to get there somehow.

Maybe 5

you don't recall -- I'm just trying to trace it.

6 A

I don't recall.

I assume that an ops clerk put it 7

in the book but I'm not sure.

I don't really recall that.

8 Q

Did you, at that time, have any responsibility as 9

far as you understood it for seeing to it that CROs under you 10 read and understood LERs?

11 A

As I saw it, it was my responsibility to see that

(,

12 they read not only the LERs, but the required reading in 13 general.

14 Q

How would you ensure that they had done that?

15 A

I don't recall specifically how I did it.

I would 16 assume that I would, in my review of the book, if I noticed 17 that they had not signed the required reading, that I'd say 18 something to them.

19 Q

So that the sign-off sheet technique was there to 20 check on whether people had read it; is that right?

21,

A Yes, sir.

22 Q

Or at least one would have an indication.

Are you 23 aware, do you have any sense of whether -- let me phrase that 24 differently.

25 When you saw that someone had initialed next to ACE-FEDERAL REPORTERS, INC.

202-347 3700 Nationwide Cos erage 800-336-6M6

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his.name in the sign-off, on the sign-off sheet for a 2

particular document, did you feel confident at that time that 3

the person had in fact read it and understood it?

4 A

Yes, sir, I did.

5 Q

Did you have any sense, conversely, that, say, 6

some CROs might just initial the thing and march on without i.

7 reading it?

8 A

No.

I wasn't aware of that.

9 Q

But, apart from the sign-off sheet technique, 10 which was a way of telling you -- at least it had been 11

-initialed -- were there any other methods that you employed

(

12 to satisfy yourself.that CROs under you were keeping current 13 on safety developments, whether in LERs or in some other 14 form?

15 A

I don't believe so, sir.

16 Q

Were there ever times, for example, some 17' significant procedural change, where you would sit down with h

18 the CRos and just tell them face to face about this?

Hold a 7'

19 meeting, so to speak?

20 A

There may have been, depending on the procedure, 21 the evolution or the change.

But I don't specifically recall f

22 doing that.

We quite often had discussions about things that 23 went on in the plant but I don't specifically recall going 24 through LERs or other items of required reading, including 25 procedures or that kind of thing.

1 l

l ACE-FEDERAL REPORTERS, INC.

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I~S 28397.0 k-BRT 3127 1-Q Was there any -- I'll put it this way first -- any 2

regular time set aside, whether once a week, once a month, to 3

go over recent developments of general interest with the 4

CROs?

5 A

No, sir.

6 Q

I think of a sort of homey and I'm sure inaccurate 7

analogy.

Do you ever watch " Hill Street Blues" on TV?

8 A

Yes, sir.

9 Q

They start the shift.

The desk sergeant, whatever 10 he is called, spends about five or 10 minutes a day sort of 11 giving people the word, what's going on, what to look out n()

12 for.

It is a general get-together of everybody involved so 13 that they all know what's going on.

Is there any analogy, 14 however crude, to what you would do with the CROs?

15 A

We did have a shift briefing.

16 Q

Maybe that's what I'm searching for.

A shift 17 briefing.

18 A

At the beginning of each shift where we not only 19 discussed with the CRos but also the auxiliary operators, 20 what work was planned for that day and, you know, whatever 21 items were to be put out.

Usually a review of the turnover 22 notes from the other shift or specific evolutions that we 23 knew were to occur on that shift.

We would go over that kind 24 of thing.

gg V

25 Q

This would be at the beginning of the shift?

ACE-FEDERAL REPORTERS, INC.

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A Yes, sir.

2 Q

Typically five or 10 minutes or what?

3 A

I think that we began it a half hour after the 4

shift commenced and it took as long as it took.

There was no 5

set, specific time.

6 Q

So you would come on shift.

The first half hour 7

you would check out the usual things you would check out and 8

then have this get-together for however long it would take?

9 A

Yes, sir.

10 Q

Weuld that have been an occasion, from time to 11 time, to talk about something like a recent LER or not?

I'm 12 not trying to put words in your mouth.

13 A

That may have been but I don't recall any specific 14 instance where that was done.

15 Q

It just strikes me that this particular LER had to 16 do -- and I'm speaking very generally and not trying to be 17 too precise -- but there was a widely prevailing view among 18 operators, shift foremen, that under the tech specs all that 19 was really required was one leak rate test under a gallon a 20 minute per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and that as long as you had that, if you 21 had other leak rate tests showing more than a gallon a 22 minute, they could effectively be disregarded,,that you 23 p weren't required to go into the action statement.

Then that l

l.

24 LER came along reflecting an NRC view that that was an s

l I

incorrect interpretation and that the 72-hour rule, as it was l

25 ACE-FEDERAL REPORTERS, INC.

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then widely understood, was not correct, and that if you got 2

a leak rate test showing leakage in excess of a gallon, there 3

wasn't any obvious basis for invalidating it and the search 4

for leakage didn't solve the problem -- let's say a second 5

test is run, you got the same reading -- then you are in the 6

action statement according to the NRC.

And that's my brief, 7l very general understanding of that difference of 8

interpretation.

9 It strikes me that that's a pretty important, 10 substantial difference in the marching order at a plant where 11 they were having one awful time getting leak rates under 1.

()

12 Is that fair?

It's a long statement, I realize.

But does 13 that strike you as fair?

14 A

That's probably a fair statement.

15 Q

So at these shift meetings, why wouldn't it be 16 appropriate to, at the shift meeting, to say:

Our idea about 17 the 72-hour rule turns out to be wrong.

If you get a leak 18 rate test in excess of a gallon per minute and if you can't 19 explain it on a leakage basis or invalidate it, into the 20 action statement we go?

That would have been qu*te a 21 surprise to a lot of people, I think, wouldn't it?

22 A

That would have been a change in interpretation.

I 23 l That's something they weren't aware of.

24 Q

In the course of your working at TMI, do you 25 recall ever going into the action statement because of 4

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leakage?

2 A

No, sir.

3 Q

That's why I say it strikes me as a rather 4

significant development and I am just exploring with you 5

whether, in some form or another, this would have been 6

brought to the attention of the operators.

I gather you 7

don't recall discussing that particular LER with the 8

operators in the context of one of these daily shift 9

meetings?

10 A

No, sir.

11 Q

One other question.

On page four of your

()

12 testimony you are speaking about water additions and you say 13 you generally try to avoid adding water during leak rate 14 tests.

I am paraphrasing.

But you indicate that you would 15 add water to maintain the makeup tank level.

16 Could you explain that a little bit?

Do you mean i

17 some particular level in the makeup tank?

18 A

As I recall, there was a general band that we 19 maintained the makeup tank level within and I -- I feel that, i

20 you know, for purposes of maintaining the tank in the band or 21 just --

22,

Q Do you recall what the band was?

23 l A

No, sir, I don't.

24 Q

Do you recall whether this was a procedural 25 requirement?

Or, put it differently, did it flow from the ACE-FEDERAL REPORTERS, INC.

202 347-3Xu)

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BRT 3131-1 tech specs, as far as you knew?

2 A

I don't recall.

3 Q

I was just thumbing through a number.of tests that 4

you were involved in and I will say that, the prior witness, 5

M r..

Illjes, he was recalling, too.

I don't think he was 6

stating that it was that clear in his mind, but I think he 7

recalled an administrative requirement -- he characterized it 8

as an administrative requirement -- that you keep the makeup 9

tank at 60 inches.

10 MR. MC BRIDE:

Judge Kelley, I believe he said 11 they were to keep the makeup tank at between 60 and 85

()

12 inches.

The minimum was 60 inches.

13 JUDGE KELLEY:

Could be.

I don't recall that.

It 14 says what it says.

Okay.

15 BY JUDGE KELLEY:

16 Q

Do you disagree with that?

Or you just don't 17 recall what the range was or what the minimum was?

18 A

I don't recall what the minimum was or the range.

19 I just don't.

20 Q

Okay.

What would be the reason for maintaining 21 the makeup tank at, let's say, 60?

22 l A

I don't recall specifically what the reasons were 1

23 for maintaining it at a given level.

I would assume it had j

24 to do with providing enough makeup water in the case of a l

25 shutdown to get -- to allow the makeup tanks to provide water l

ACE-FEDERAL REPORTERS, INC.

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for a time period so that they didn't starve of water until 2

other sources of water could be obtained.

3 Q

Are you envisioning some kind of emergency 4

situation?

5 A

Shutdown.

You know, an automatic shutdown, for 6

instance, is what I was specifically thinking about.

As far 7

as normal evolutions, you know, the tank could have been 8

maintained at some other level.

9 Q

Just looking at these evolutions, whether they are 10 feed and bleed or water additions, you can look at strip 11 charts until your eyes go numb, but in any event, you see

()

12 additions of 50, 100, 200, maybe 300 gallons.

But I don't 13 recall seeing anything on the order of 1500 to 2000 gallons 14 at any one time from this makeup tank.

So I'm just wondering 15

-- and the context of my question really is simply this:

The 16 instructions for leak rate tests, they don't prohibit the 17 addition of water during a leak rate test but there's a 18 cautionary statement saying:

Avoid it if possible.

I'm 19 reading these strip charts and seeing all this water going in 20 l during leak rate tests and asking myself why.

And then if i

21 ~

the answer is, well, I wanted to maintain it as 60, then I'm 22 i saying, well, why?

Why 60?

Why do you need 60?

And that's 23 really the thrust of my question.

24 ;

I saw one test here, of yours, number 9, NRR test

(

25ll number 9, where the trace is kind of erratic but -- you can ACE-FEDERAL REPORTERS, INC.

t 202-347-3W0 Nationwide Cmenage MXL334646

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take a look at that.

Have you got NRR test number 9?

The 2

NRR note says the test is invalid and that unstable plant 3

conditions prevailed, start up and plant progress -- still 4

and all, the makeup tank is dipping down below 50, even below 5

40 at one point -- more than one point -- so it didn't seem 6

to have been -- assuming the makeup tank recorder at that 7

time was accurate, it doesn't seem to have been an invariable 8

rule that you always had 60 to 85 in the makeup tank.

9 Does that indicate that it dipped down to the 40 10 range a couple of times?

It seems to, to me.

11 A

Yes, sir.

n

(_)

12 Q

And, again, I'm assuming the level indicator there 13 is accurate.

I don't know that to be true.

I'm just 14 assuming to be true.

But I'm searching for a really 15-compelling reason why the makeup tank had to be maintained at 16 60 and above.

There may be some such reason but I'm not sure 17 that that I've really grasped it yet.

18 A

And I don't recall what the band was and the 19 specific reason for it.

20 Q

Would it appear to you, just looking at it today 21

-- let's suppose the makeup tank level was at 70 and dropping 22 at, oh, 10 inches an hour.

Even more than that, 15 inches an l

23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />.

So it would go down to 55 during an hour leak rate j

24 l unless you add water.

Can you think of any good reasonable

(

i 25 l why there would be any real concern about letting the level l

Ii ACE-FEDERAL REPORTERS, INC.

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of the makeup tank drop to, say, 55?

2 A

No, sir.

I can't think of any.

3 JUDGE KELLEY:

Do you have follow-up questions?

4 MR. MC BRIDE:

Yes, I also appreciate it if the 5

Board would indulge us --

6 JUDGE KELLEY:

Why don't we take a little break.

7 Let's take 10 minutes.

8 (Recess. )

9 JUDGE KELLEY:

We have some follow-up questions, 10 which Judge Bright will put.

11 BY JUDGE BRIGHT:

( )-

I 12 Q

We have a question here from the Staff, 13 Mr. Conaway.

Your counsel has stated that the three-page OI 14 interview report has some " omissions."

Is it your testimony 3

15 that the interview report is accurate as far as it goes but 16 that the report may have omitted references to certain 17 exchanges or subjects?

18 A

Yes, sir.

I think that's the case.

I think the-19 interviewer was looking for a scope of information, and 20 during the interview we went, possibly, beyond that scope.

21 And his report reflects basically the information that he was 22 looking for and it is accurate to that point.

23 The one item in particular that it did leave out 24 was a statement that I made regarding my feelings as far as 25 Ted's honesty and his integrity; that I felt that, you know, ACE-FEDERAL REPORTERS, INC.

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1 there was never a reason for me to question Ted.

I think, of 2

the CROs that I'had, I think I knew Ted the best in that we 3

did have a similar interest in gardening and, you know, in 4

every aspect of my dealings with Ted I never had a reason to 5

question nis honesty or integrity.

6 Q

This is at least touched upon here, isn't it?

Or 7

in your prefiled testimony.

8 f tS. WAGNER:

It is touched on in the report on 9

page 3, I believe the last paragraph towards the bottom.

10 BY JUDGE BRIGHT:

11 Q

You felt that Ted Illjes was a very trustworthy w

12 individual and was a good operator.

Well, that's a high 13 praise, Mr. Conaway.

14 A

I think I went beyond that in what was indicated 15 in the question and answer form.

16 Q

You get the overeffusive recommendation, you 17 immediately wonder.

18 (Laughing.)

19 I think that ansutre Lt.

20 I don't suppose u;c i's any particular order in 21 these, except on the page.

22 MR. MC BRIDE:

That's correct, sir.

23 BY JUDGE BRIGHT:

24 Q

We'll start out with:

Turning your attention to O

25 the LER78-62, dated November 1978, page 2, Stier volume V(C)

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tab 29, is it a fact that it states --

2 MR. MC BRIDE:

May I interject, Judge Bright, the 3

copy in the Stier volume just referred to is a~1ittle 4

difficult to read.

I also have here, as I noted for the 5

Board yesterday, in tab 30, the version that was circulated 6

to the control room.

I believe that the sentence you are 7

about to read is essentially the same in both versions.

The 8

LER is tab 29.

The version they saw is tab 30.

Perhaps 9

you'll want him to refer to both, just to be able to read 10 it.

11 JUDGE BRIGHT: That sounds reasonable.

O)

(_

12 BY JUDGE BRIGHT:

13 Q

"Since all leakage from the RCS is processed 14 through the rad waste treatment system, this event did not 15 affect the health and safety of the public."

Is that what 16

.the LER says, in part?

17 A

Yes, sir.

18 MS. WAGNER:

Could it be clarified?

Is he 19 referring to the LER, or is he referring to the tab 30 --

l 20 MR. MC BRIDE:

He's reading the LER, tab 29.

21 THE WITNESS:

I just read tab 30.

I'm about --

22 MS. WAGNER:

You said they were essentially the 23 same but your question was "doesn't the LER state."

24 THE WITNESS:

Could you reread the statement, 25 please?

l ACE-FEDERAL REPORTERS, INC.

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-1 BY JUDGE BRIGHT:

2 Q

"Since all leakage from the RCSiis processed 3

through the rad waste treatment system, this event did not 4

affect the health and safety of the public."

'S A

Okay.

It's a verbatim match.-

6 Q

Then might-it.have been the case that you and 7

other operators and supervisors did not believe that the LER 8

.had safety significance because of that statement?

9' A-That could have been the case.

I don't recall now 10 because~I don't recall the, you know, the LER at the time.

11 That is'one possibility for not putting a great deal of

. ()

12 significance on it.

I -- as I said, since I didn't remember

- 13 the LER, it's difficult to.say what the impression was at the 14 time.

s-l 15 Q

Please describe your best --

16 JUDGE KELLEY:

Could I interject with a question 17 here, a follow-up on the question we just heard?

1-18 BY JUDGE KELLEY:

19 Q

The sentence -- and I don't have it in front of me 20

-- to the effect that since the leakage was processed through 21 the rad waste system this didn't affect public health and

'22 safety, does that strike you -- it doesn't me, frankly -- as 23 a candid assessment of the safety significance of the 24 matter?

This is my reaction.

I may be wrong.

I wouldn't O.

25 care at all about where the water went.

That's not my ACE-FEDERAL REPORTERS, INC.

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concern.

I assume the water may be radioactive and if I took 2

a bath in it it might be harmful to my health and safety.

My 3

concern would be with the leakage.

And if the leakage were 4

at 2.6, or whatever -- one of them was over 2 -- I'd be 5

concerned about pipes breaking, not radiation'from water.

6 Am I -- is my concern misplaced in this context?

7 A

I guess I'm not really sure, based on, you know, 8

what may have been the opinions or the ideas that we had at 9

the time.

I don't think that we felt we had any -- any 10 problems of leakage through a primary boundary which would 11 indicate to me concern of pipe breaks and cracks and that

()

12 sort of thing.

I think, perhaps, we were more concerned 13 about what was going to happen to the water.

14 You know, I don't think that we had a good or a 15 real concern about damaged pipes or bad piping, particularly 16 since the plant was very new.

17 Q

Wasn't the leak rate test designed to detect leaks 18 from, among other things, piping?

19 A

Yes, sir.

20 Q

Safety grade piping?

21 A

Yes, sir.

4 22 Q

Such that if some of that piping failed, you could 23 have a major accident?

24 A

Yes, sir.

O 25 Q

And, again, I thought the test was aimed at cracks ACE-FEDERAL REPORTERS, INC.

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in. pipes and not, particularly, with radiation dangers from 2

water.

Am I wrong about that?

3 A

I think there's really both concerns.

The 4

radioactive water that spills on the floor is a safety 5

concern for the personnel that have to operate and get into 6

the plant areas, in addition-to the safety concern that you 7

have from pipe breaks and failures.

8 Q

Well, I just never understood it in that light.

I 9

thought this leak rate test was about cracks and leakage and 10 secondarily, if at all, about immediate radiation hazards as 11 a result of leakage.

Maybe I'm wrong.

()

12 If I'm right and that is what this test is all 13 about, then I would think if anything, if I read the LER, I 14 would probably chuckle and say how easy it is to pull the 15 wool over the NRC's eyes, by diverting their attention to 16 radiation hazards and blinking the fact that you are talking 17 about cracks in pipes.

Is my slant on this wrong?

18 A

No, I don't think so.

19 By JUDGE BRIGHT:

20 Q

Please describe your best recollection of your 21 conversation with Mr. Illjes following his interview about 22 l Mr. Chwastyk's hydrogen experiment.

23li A

That refers to the time period after I think Ted l

24 had been questioned regarding the experiment to determine 25~

hydrogen's effect on leak rate.

One day he called me up and 4

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1

-- to ask if he-could come down and see me.

He was very 2

upset.

I could just tell.from his tone of voice and the fact 3

that he said he thought he was going crazy because he was 4

supposed to have had taken part in this test'or been very 5

aware of the test or the results and I really didn't know 6

what he wanted to talk about other than that.

And when he 7

came down he just expressed a real concern that he couldn't 1

8 remember anything about the test, couldn't remember anything 9

about the results, and was curious as to whether I knew about 10 the test or the results.

He was very upset.

The only thing 11 I could tell him was that I had no recollection of the tests

()

12 or the results or anything that Chwastyk had imparted to us 13-in that regard.

So he was extremely concerned that 14 Mr. Chwastyk had indicated that he was aware, took part in 15 the test, and yet he couldn't remember it.

16 Q

How was NRR test 147 performed?

When was it 17 performed?

l 18 MR. MC BRIDE:

Judge Bright, I think you may have 19 the piece of paper in front of you which were my follow-up 20 questions for Mr. Illjes, and I did not intend --

I 21 (Discussion off the record. )

22 JUDGE KELLEY:

Anything else from counsel?

23 MR. MC BRIDE:

Yes.

One other thing, if we 24 could.

No.

Nothing.

O 25 JUDGE KELLEY:

Mr. Conaway, that completes this ACE-FEDERAL REPORTERS, INC.

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' process with you.

We. appreciate your coming down, your 2

attention to questions and the responsiveness of your 3

answers.

4 Thank you very much, you are excused.

5 (The witness stood down. )

l

-6 (Discussion off the record.)

7 MR. BLAKE:

The company's records indicate he was

+

8 licensed as an RO on October 19, 1977.

9 JUDGE KELLEY:

All right.

Thank you.

10 (Whereupon, at 4:15 p.m.,

the hearing was i

11 adjourned, to reconvene at 10:00 a.m.,

on October 8, 1986.)

12 13 14 15 16 17 18 19 i

20 21 22' 23 4

i O 24 25 1

i ACE-FEDERAL REPORTERS, INC.

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CERTIFICATE OF OFFICIAL REPORTER uJ This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:

NAME OF PROCEEDING:

INQUIRY INTO THREE MILE ISLAND UNIT 2 - LEAK RATE DATA FALSIFICATION i

DOCKET NO.:

LRP PLACE:

Bethesda, Maryland O

DATE:

Tuesday, October 7, 1986 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.

(sigt)

(TYPED JOEL BREITNER official Reporter ACE-FEDERAL REPORTERS, INC.

Reporter's Affiliation O

.