ML21236A271

NRC-2021-000086 - Resp 1 - Final, Agency Records Subject to the Request Are Enclosed

ML21236A271
Person / Time
Site:	Watts Bar
Issue date:	08/24/2021
From:	NRC/OCIO
To:
Shared Package
ML21236A268	List: ML21236A270 ML21236A271 NRC-2021-0000, NRC-2021-000086 - Request for the Report of Investigation (ROI) from the Office of Investigations (Oi)'S Investigation, OI-2-2016-042
References
FOIA, NRC-2021-000086
Download: ML21236A271 (248)

Text

8P'rtCIJld:. 1::191! 8NL'f -OI INVESTIGATION INFORMATION

Title:

WATTS BAR NUCLEAR PLANT SUBMISSION OF INCOMPLETE AND INACCURATE INFORMATION BY SITE MANAGEMENT REGARDING WATTS BAR UNIT 1 START-UP EVENT AND VIOLATIONS OF PLANT PROCEDURES BY LICENSEE EMPLOYEES Licensee: Case No.: 2-2016-042 Tennessee Valley Authority Report Date: May 17, 2019 1260 Nuclear Plant Road Spring City, TN 37381 Control Office: OI:RII Docket No.: 05000390 Status: CLOSED 05000391 Allegations: Rll-2015-A-0214 RU-2016-A-0032 Rll-2016-A-:()134 Rll-2016-A-O 169 Rll-2017-A-0014 ons ons Field Office, Region II Field Office, Region I (b)(?)(C)

Iga ans Field Offlte, Region II WARNING IN THE PUBLIC DOCU IZED AND/OR H6T FeR f'tJBLle eIeete0URE WFfl I8lff A:f'f'R0¥Jtd: 0F SPECiAL AGEN I IN CMRGE, OFFICI!: o" 1101!:STIGffl IOl~S. "l!eI01* II 8P'P'ICIAL 1::191!! 8P~LY - 01 INVESTIGATION INFORMATION Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION SYNOPSIS This investigation was initiated by the U.S. Nuclear Regul!atory Commission (NRC), Office of Investigations (01), Region II (RII), on August 15, 2016, to determine whether TVA employees deliberately violated the following NRC regulations at Watts Bar Nuclear Plant, Unit 1 (WBN 1):

Allegation No. 1 Watts Bar senior managers deliberately took actions which placed Watts Bar senior managers either directly or through the Outage Control Center, as the de facto directors of the licensed activities of the control room operators. This represents a violation of 10 CFR 55.3 which requires that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator which includes directing the licensed activities of licensed operators.

Allegation No. 2 During the Unit 1 start-up from 1RFO13 on October 20,2015, the Standby Main Feed-water Pump was used to feed the S/Gs in order to perform a valve PMT in parallel with unit start-up even after the plant was taken into Mode 2.

Allegation No. 3 Failure to follow the NPG-SPP-1.2, Administration of Site Technical Procedures when making a change to W BN1 . 1-GO-1 Start-Up from Cold Shutdown to Hot Standby (drawing the bubble) by the l(b)(7)(C) Ion November 9, 2015.

Allegation No. 4 Watts Bar failed to follow Plant Operating Procedure 1-GO-1 when Unit 1 was transitioned from Mode 5 to Mode 4 without normal let-down in service and continued with 1-GO-1 start-up activities on November 11, 2015.

Allegation No. 5 Submission of incomplete and inaccurate information by TVA Managers on December 14, 2015, to !(b)(7)(C) Iregarding the details surrounding the WBN1 start-up on November 11, 2015.

Allegation No. 6 Submission of incomplete and inaccurate information by TVA Managers to the NRC in response to NRC questions concerning the November 11, 2015 RHR event as documented in Shift Order 15-50 and presented to the NRC during a site visit on January 6, 2016.

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Case No. 2-2016-042

6FFlel,-L U9E 6f4LY O1 INVESTIGATION INFORMATION Allegation No. 7 Submission of incomplete and inaccurate information by TVA Managers to 0 1during interviews on December 18, 2015.

Allegation No. 8 Submission of incomplete and inaccurate information by TVA Managers in a Level 2 evaluation associated with Condition Report (CR) 11 21520 on January 20, 2016.

Allegation No. 9:

Submission of incomplete and inaccurate information by TVA Managers to the NRC during the February 2, 2016 meeting with the NRC.

Allegation No. 10 Submission of incomplete and inaccurate information by a Senior TVA Executive to the NRC as documented in the March 23, 2016, Special Review Team Report.

Allegation No. 11 Submission of incomplete and inaccurate information by Senior TVA Executives to NRC Senior Executives on March 13, and 15, 2016.

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Case No. 2-2016-042

6FFlel,-L U9E 6f4LY O1 INVESTIGATION INFORMATION TABLE OF CONTENTS Page(s)

SYNOPSIS ..... ............................................................................................................................ 1 TESTIMONIAL EVIDENCE ...................................................... .. ................................................. 5 DETAILS OF INVESTIGATIO N .......................................................... ........ .................................9 Applicable Regulations ................................................................................................... 9 Purpose of Investigation .... .... ........................................... ................ .............................. 9 Coordination with N RC Staff .......... ................................................................................ 10 Coordination with Department of Justice (DOJ) .................................................... .. ....... 10 Background .................................................................. ................................................. 11 Allegation No.1 ...... ........................................... .......... ...... .......... ............................... .... 23 Applicable regulations ........................................................................................ 23 Documentary Evidence ....................................................... .. .............................23 Testimony ....................................................................................................... .... 24 Agent's Analysis .................................................................................................73 Conclusion .................................................................................................. ........82 Allegation No. 2 .................................................................................................... ..........83 Applicable regulations ........................................................................................83 Documentary Evidence ....................................................... ...............................83 Testimony .......................................................................................................... 83 Agent's Analysis ................................................................................................87 Conclusion ......................................................... .................................................89 Allegation No. 3 ... .. ............................... ............................................................... .......... 90 Applicable regulations ......................................... ........ ........ .. .............................90 Documentary Evidence ................................... .. ...... ................ .. ......................... 90 Testimony ...... ....................................................................................................90 Agent's Analysis ................................................................................................94 Conclusion .......... ................................... ........ ..................................................... 95 Allegation No. 4 ............................................................................................................. 96 Applicable regulations ........................................................................................96 Documentary Evidence ........................................... ................ ...........................96 Testimony .......................................................................................................... 97 Agent's Analysis ....................................... .......................................................115 Conclusion ....................................................................................................... 117 Allegation No. 5 ................................................................................................... ........ 11 8 Applicable regulations ......................................................................................11 8 Documentary Evidence ....................................................................................11 8 Testimony .........................................................................................................11 9 Agent's Analysis ..............................................................................................122 Conclusion ....................................................................................................... 124

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Case No. 2-2016-042

6FFlel,-L U9E 6f4LY O1 INVESTIGATION INFORMATION Allegation No . 6: ..........................................................................................................125 Applicable Regulations ....................................................................................125 Documentary Evidence ....................................................................................125 Testimony .........................................................................................................126 Agent's Analysis ..............................................................................................149 Conclusion .......................................................................................................158 Allegation No. 7 ........................................................ ...................................................159 Applicable Regulations .......................................................................... .......... 159 Documentary Evidence ....................................................................................159 Testimony ....... .. ................................................................................................ 159 Agent's Analysis ..............................................................................................163 Conclusion ..... ................................................... ...............................................167 Allegations No. 8 and No. 9 .........................................................................................168 Applicable Regulations .................. ........................................... .......................168 Documentary Evidence ....................................................................... ............. 168 Testimony .. ....... .. ..................................................... ......................................... 169 Agent's Analysis ..............................................................................................198 Conclusion ........................................................................................................208 Allegation No. 10 and No. 11 .......................................................................................209 Applicable Regulations ....................................................................................209 Documentary Evidence ....................................................... .. ...........................209 Testimony ........................................................................................................211 Agent's Analysis .... ......................................... ........................ .. .......................223 Conclusion ........................................................ ................ ............................... 231 SUPPLEMENTAL INFORMATION ............. ............................................................................233 LIST OF EXHIBITS .................................................................................................................235 Documentary Evidence .......................................................... ............ .........................235 Testimony .............. ........................................................................................ .............. 241 l~ef Fef't 1-UBUe 01 aete1'Uf'tE Wlf l 1euf )fl(fifif'te1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPNESTIOMIOPJS, REO IOPJ II 6 f'f'le l,-L U91! 6f4LY O1 INVESTIGATION INFORMATION 4

Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION TESTIMONIAL EVIDENCE Exhibit(s) l(b)(?)(C) I Shift Manager, TVA, Watts Bar ..................................T-46a, T-46b, T-46c I(b)(?)(C) ITVA, Watts Bar ..... ..... ...................................T-43a, T-43b (b)(7)(C)

ITVA, Watts Bar ........... .... T-73 (b)(?)(C) f eactor Operator. TVA, Watts Bar ...........................T-01a, T-01 b, T-01c (b)(7)(C)

I TVA, .................. T-0?a, T-07b, T-O?c, T-0?d (b)(7)(C)

ITVA ................................. .................T-60a, T-60b (b)(?)(C)

ITVA ...... ........ ........T-66 (b)(7)(C) 1... .....................................................T-74 (b)(7)(C)

ITVA, Watts Bar ................................ .................T-O0a, T-00b (b)(7)(C) IReactor Operator, TVA, WBN ......................................................T-23a, T-23b ITVA, WBN ................................................ ........T-35 i---------------------,

(b)(7)(C)

\I----------------..----_,

(b)(7)(C) I TVA, Watts Bar ...................T-11 (b)(7)(C) I TVA, Watts Bar ........................ T-25a, T-25b

============::::::;------1

!(b)(7)(C) ITVA, Watts Bar................................ ...................T-69

=:;===========::::::::.....____:,

l(b)(7)(C)

_____,,1..........................................T-51

===================;~----'

l(b)(?)(C) ITVA, Watts Bar. .................... T-47a, 47b

======,-----------_,

l(b)(?)(C) !Reactor Operator, TVA, Watts Bar .............................................................T-76 l(b)(?)(C)  !TVA, Watts Bar ........................... .. ...T-44

~,(b=)(?== )(C=)==========::::;I- T-VA - ,- W

- a__.

tts Bar ..................................................T-36

.l (b::.

)(l::.

)(C -----1 TVA, .....................................T-67

:.)-=--=--=--=--=--=--=--=----_-_-_-_-_-_ -_-_-_-_-_-_-....

l(b)(?)(C)

===========::::::;--'

ITVA ............................ ........ ................ ...........T-61 l(b)(7)(C) j TVA Watts Bar ... ..... ... ... ....... ... ... .... ... ... .... ...T-20

=.===========::::::::..I__

============:::::...

l(b)(7)(Cl NRC Region II ....................... .... ...... .. .. ........ .... .T-52 (b_)(?_)(C_) _ _ _ _ _ _ _ _ _ _ _ _I...................................... .........................T-29 l(b)(7)(C) !senior Reactor Operator, TVA, Watts Bar ........................................T-05a, T-05b

-=====--. ...

l(b_l(7_l(C_l _ _ _ __.l Unit Supervisor, TVA, Watts Bar, .................................. .... ....T-13a, T-1 3b

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Case No. 2-201 6-042

6 FFlel,-L U9E 614LY 01 INVESTIGATION INFORMATION (b)(?)(C) Unit Supervisor, TVA, Watts Bar ..................................................... T-38, T-38b (b)(?)(C)

TVA, Watts Bar ...................................T-18, T-31

===========-=--=..---------

l(b)(?)(C) l(b)(7)(C)

IReactor Operator TVA, Watts Bar ...................... T-02a , T-02b, T-02c, T-02d ITVA, Watts Bar ............................................ T-70 (b)(?)(C) Shift Manager, TVA, WBN, ..........................T-22a, T-22b, T-22c, T-22d , T-22e Unit Supervisor, TVA, Watts Bar ................................................................. T-45 l(b)(?)(C)

-=====.---------------- ITVA, Watts Bar ................................ ........ T-24 1(b)(7)(C) I Senior Reactor Operator, TVA Watts Bar .......................................................... T-12

=l =)= = = = = = = = - = - - = - . - - - - - - - - - - - - - - - - ' I TVA......................... ........ T-64 (b=)(7=)(C l(b)(7)(C) IReactor Operator, TVA, Watts Bar .................................... T-15a, T-15b l(b)(7)(C) ITVA, Watts Bar .............................. T-30 (b)(7)(C) ISenior Reactor Operator, TVA, Watts Bar ............................................. T-14 (b)(?)(C) I NRC ..................................................... T-53 (b)(?)(C)

ISenior Reactor Operator, TVA. Watts Bar .............................................. T-09 (b)(7)(C) Unit Supervisor, TVA, Watts Bar ............. ........................................................ T-10 Shift Manager, TVA WBN ...................... ............................. ........................... T-14 (b)(?)(C)

ITVA, Watts Bar ................................. T-49a, T-49b, T-49c l(b)(7)(C) INRC ...................................................................T-03

=======.----------

1( b)(7)(C) I Unit Supervisor, TVA, Watts Bar ............................................................. T-68

=.====::;"'

(b)(?)(C) Senior Reactor Operator, TVA, WBN ........................................................ T-28 (b)(7)(C) TVA ........................ T-65

';:::::;;::::;::======::::::;--------------'

!(b)(7)(C) ITVA, Watts Bar ................................................................ T-48

,!::::::::::;::=====,----

~========i...-_

1(b)(?)(C)

I Unit Supervisor, TVA, Watts Bar......... T-27a, T-27b, T-27c, T-27d , T-27e l(b_)(7_)(C_) _ _ _ _ _ _ _ _ _ __,l ................................................................. .. T-77 REDDINGER, Dennis, Unit Supervisor, TVA, Watts Bar .........T-40a, T-40b, T-40c, T-40d , T-40e l(b)(?)(C) IShift Manager, TVA, Watts Bar ............................................................ T-32 l(b)(?)(C) IReactor Operator, TVA, Watt Bar .................................................T- 16a, T-16b

!(b)(?)(C) IReactor Operator, TVA, Watts Bar ....................................................................... T-72 l(b)(?)(C) ITVA ........................................................ T-62 I4ef fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1)1(L efi

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Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION l(b)(?)(C) I Reactor Operator, TVA, Watts Bar ................... .................................... T-75 l(b_)(7_l(_

.... Cl_ _ _ _ _ _ _ _ _ _ _ _ _ ____.l TVA, Watts Bar.....T-17a, T-17b, T-17c, T- 17d, T-17e l(b)(7)(C) ITVA, Watts Bar .................................. ........T-19

===============---.

l(b)(?)(C) I TVA BFN ..... .. .................................... T-63

!===========:::::;-----'

.l(=

b)(?

=)::;:::

(C=) ===:--------! TVA, Watts Bar.. .............. T-21a, T-21b, T-21c, T-21d

=-l(b=)(l==)(_

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_, Manager, TVA, Watts Bar ..................................................... T-34a, T-34b

!(b)(?)(C) I Unit Supervisor, TVA, Watts Bar ............................................ .. ...... ..... T-71

':=======-------

1( b)(7)(C)  !TVA, Watts Bar ............................................................ T-33

=!

(b=)(7=)(= c)= = = = = = = = = = = - - - - - - - - - - - - . , TVA, Watts Bar ............ T-42a, T-42b l (b)(?)(C) ~ RC, Region 11 .... T-50

'.======================------,l l(b_)(?_)(C_) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ TVA ..... ..T-78

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Case No. 2-2016-042

6FFlel,-L U9E 6f4LY OI INVESTIGATION INFORMATION THI S PAGE LEFT BLANK INTENTIONALLY

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Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION DETAILS OF INVESTIGATION Applicable Regulations 10 CFR 50.5: Deliberate Misconduct (2015 and 2016 Editions) 10 CFR 50.7: Employee Protection 10 CFR 50.9: Completeness and Accuracy of Information 10 CFR 50: Appendix B, Criterion V and Criterion VI 10 CFR 55.3: License requirements 18 USC 1001: False Statements 18 USC 371: Conspiracy to Defraud the Nuclear Regulatory Commission 18 USC 1505: Obstruction of Federal Agency Proceedings 18 USC 1519: Destruction, alteration, orfalsification of records in Federal investigations 42 USC 2273: (Atomic Energy Act): Unlicensed Operation of a Nuclear Facility Purpose of Investigation This investigation was initiated by the U.S. Nuclear Regulatory Commission (NRC), Office of Investigations (01), Region II RII on August 15, 2016, following contact by Assistant United States Attorney (AUSA) (b)(7)(C) , United States Attorney's Office (USAO) for the Eastern District of Tennessee, w o a requested that 01 provide investigative expertise to an on-going criminal investigation relative to TVA personnel at WBN. The AUSA also requested 0 1 to arrange and coordinate NRC technical assistance in support of the investigation. During the course of the investigation, 0 1obtained information from the USAO related to the potential NRC violations. The information was reviewed by!(b)(7)(C)  !, NRC RI I, who confirmed that the information did not represent an immediate security or safety concern.

Additionally, the USAO expressed a commitment that future information collected during the course of this investigation would be reviewed by the NRC. Specifically, this investigation was initiated to determine whether TVA managers and employees deliberately provided incomplete and inaccurate information to the NRC regarding WBN1 heat-up event on November 11, 2015, (Shift Order, RI I-2016-A-0134 ). During the investigation, 0 1identified additional potential violations associated with previously closed allegations as outlined under (RII-2015-A-0220, and Rll-2015-0214) which were incorporated into this investigation. In particular, the concern related to the failure to follow procedures relative to the use of the Stand-By Main Feed Water Pump and 1-GO-1 performing plant start-up without normal let-down in service. Additionally, 0 1 identified allegations regarding the failure to implement procedure change to 1-GO-1 start-up from cold shutdown to hot standby (Drawing the Bubble) and failure to follow 1-GO-1 after the change was implemented, which are outlined under allegations (Rll-2016-A-0169, and Rll-2017-0014 ), and also incorporated into this investigation. To that end, allegation Rll-2016-A-0169 was opened to capture issues associated with changing of the plant operating procedure during the start-up of WBN Unit 1 in November 2015.

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Case No. 2-2016-042

6FFle l,-L U9E 614LY 0I INVESTIGATION INFORMATION Furthermore, 0 1initiated allegation Rll-2017-A-0014 to document allegations/concerns identified as part of this joint investigation that were found not to have immediate safety or security concerns.

• Deliberate violation of licensing requirements to perform the function of a licensed reactor operator and a senior reactor operator without being authorized, and/or licensed by the NRC to perform such function.

• Deliberate submission of incomplete and inaccurate information to the NRC in a written response on December 14, 2015.

• Deliberate submission of incomplete and inaccurate Information to NRC during a January 6, 2016, "drop-in."

• Deliberate submission of incomplete and inaccurate information to the NRC in the form of a Level 2 Corrective Action Program (CAP) evaluation, as part of Condition Report (CR) 1121520.

• Deliberate submission of incomplete and inaccurate information to the NRC during a February 2, 2016, "drop-in" meeting with NRC officials.

• Deliberate submission of incomplete and inaccurate information (Special Review Team Report) by a TVA manager to NRC.

Coordination with NRC Staff On December 16, 2015, a RII ARB requested that 01 initiate an Assist to Staff (2-2016-015F) to obtain information from WBN personnel regarding a WBN 1 event on November 11, 2015. 0 1 was requested to include additional concerns considered potential deliberate violations of 10 CFR 50 Appendix Band 50.5 by TVA personnel. Beginning with the Assist to Staff and throughout this investigation, !(b)(7)(C) I, NRC, Region II (Rll)!(b)(7)(C) Iwas consulted and provided technical expertise on a full-time basis since Apni 201 /.

In mid-January 2016, 01 coordinated multiple meetings between 0 1, RII , HQ, and TVA-OIG regarding receipt of several allegations associated with TVA officials. On February 22, 2016, NRC and TVA-OIG held a teleconference to discuss TVA-OIG's interim findings regarding a chilled work environment, potential wrong-doing and other safety concerns associated with the events of November 11, 2015. Also, 01:HQ and TVA-OIG coordinated an agreement which cleared a path for TVA-OIG to provide allegation information to the NRC for analysis and consideration. In addition, since April 2018, 0 1has briefed representatives from OGC, OE and RII on the status of the investigation and possible violations.

Coordination with Department of Justice (DOJ)

On July 29, 2016, AUSA !(b)(7)(C) l USAO Eastern District of Tennessee (EDTN) contacted 01 requesting investigative support and information regarding an on-going criminal investigation before the USAO-EDTN relative to TVA personnel who potentially engaged in wrong-doing. As mentioned, the AUSA requested that 0 1arrange for NRC technical assistance in support of the USAO's efforts to determine whether TVA personnel provided false information SPECIAL AGEl<I I IIQ CHARGE, OFFICE OF ll<I V~~TIGATIOl<I~. l"!~GIOl<l 11 6f'f'lel,-L U9!! 6I4LY 0I INVESTIGATION INFORMATION 10 Case No. 2-2016-042

6FFlel,-L U9E 6f4LY O1 INVESTIGATION INFORMATION to the NRC regarding the events surrounding the heat-up on November 11 , 2015. The USAO sought clarification on whether the heat-up was done in an unsafe manner when primary let-down was not available (and assumed available per procedure) as excess let-down did not have adequate capacity to control pressurizer level(s). Additionally, the USAO requested the NRC determine whether the RHR system was operated outside of procedural bounds to compensate for the out of service primary let-down on November 11 , 2015.

The initial information that the USAO had reviewed indicated that the Main Control Room (MCR) licensed operators were pressured to adhere to the heat-up schedule when they were ordered to proceed with reactor heat-up and use RHR let-down, even though the licensed operators felt uncomfortable followin mana ement's direction in this matter. Therefore, on August 4, 2016, 01, met with AUSA (b)(7)(C) who advised that based on the initial review of the information provided by TVA-OIG, it was the USAO's determination that the matter warranted further investigative actions in order to establish whether criminal charges should be recommended.

Then based upon the USAO's request, as well as the determination that a specific indication of wrong-doing existed, 01 self-initiated this investigation to determine whether TVA personnel deliberately violated regulations to include providing incomplete and inaccurate information to the NRC regarding the WBN1 heat-up evolution.

Background

As to Allegation No. 1 Watts Bar Managers deliberately took actions which placed Watts Bar senior managers either directly or through the Outage Control Center (OCC), as the de facto directors of the licensed activities of the control room operators. This represents a violation of 10 CFR 55.3 which requires that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator which includes directing the licensed activities of licensed operators.

Beginning in September 2015, Watts Bar senior managers took specific actions to influence the work environment prior to the 2015 fall re-fueling outage. WBN management established a work environment, and reinforced a mindset among licensed operators, whereby raising concerns about or opposing WBN senior management's direction regarding plant operating schedules was unacceptable. This positioned WBN senior managers either directly or through the OCC, as the de facto directors of the licensed activities of the licensed control room operators. The use of disciplinary and other adverse actions affected the mindset and actions of the Reactor Operators (RO) and the Senior Reactor Operators (SRO). This included the assigning or reassigning of operations staff duties and positions based on their willingness to yield to and or support OCC/management direction. Intimidation suppressed the questioning of the authority and direction of WB management by the ROs and the SROs. These actions facilitated WBN senior management usurping the authority of SROs responsible for directing the l~OT FOR 1-UBUe 01 aet01'Uf'tE W IT I IOUf )fl(fifif't01~*)1(t OF 9PEOIAL AOEPH IPJ O1IAROE, OFFICE OF IP NEe!TI O>'<TI O r e! , REOION II 6 f'f'le l,-L U91! 6f4LY O1 INVESTIGATION INFORMATION 11 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION licensed activities of licensed operators, effectively performing the function of an operator and a senior operator contrary to 10 CFR. § 55.3.

Overt acts furthering this ob* ective were: intimidation of o erators during the September 2015 offsite leadership meeting; (b)(?)(C) directin the removal of l(b)(?)(C) I l{b)(?)(C) !from site by security; removal of Unit Supervisor (b)(?)(C) from watch during the October 2015 WBN1 outage; requesting OCC management to verify they were in control as reflected in the us,e of the SOD/SOM checklist; removal of US !(b)(?)(C) I from watch in Janua 2016* (b)(?)(C) failure to use the Adverse Em~lor e Action Program; and (b)(7)(C) intimidation of SR (b)(7)(C) by pressuring !pJ(7 (CJ !to finish a Work Order review.

0 1identified events that indicated the environment was clearly having an effect on the actions of operations personnel to include licensed operators. Events include: the use of the standby main feed-water pump during startup; improperly changing of the Unit 1 startup procedure 1-GO-1 to expedite startup; licensed operators logging that the OCC was directing activities of the MCR operators in December 2015; and the events and violations that occurred on November 11 , 2015.

As to Allegation No. 2 During the Unit 1 startup from 1RFO13 on October 20, 2015, the Standby Main Feed-water Pump was used to feed the S/Gs in order to perform a va lve PMT in parallel with unit start-up even after the plant was taken into Mode 2.

On October 21 , 2015, WBN 1 Shift Manager (SM) ~b)(?)(C) ho concert j ith l(b)(?)(CJ I l(b)(7)(C) I directed RO _(b)(?)(C) _ to use the Standby Main Feed-water Pump (SBMFP) instead of the procedurally required Auxiliary Feed-water Pump (AFWP) during the reactor startup from Mode 3 to Mode 2. This was done to enable engineering to perform missed testing and inspections of feed-water valves in containment that are normally done in Mode 5 without delaying plant start-up. !/bl/7)/Cl I initially refused and stated it was not safe to perform the reactor startup using the SBMFP. In response to his push back he was challen~ed to "show me somewhere where it says that we cannot do this procedurally." !(bl/7)/C I ::ilso responded that Operations will not be the hold-up of the outage and we will not delay the startup. When asked about the safety component, !fb)(?lfC\ I res~onded "we're going to be careful." Additionally, radiation protection employeetb~ * ,c, I llb}l?]Ql I voiced worker safety concerns about the performance of this testing and inspection to the OCC during a reactor startup. !/bl/7l/C) I had the RP tech removed from the site by security when he continued to push back against !/b}/7\/Cl Iand the OCC.

As to Allegation No. 3 Failure to follow the NPG-SPP-1.2, Administration of Site Technical Procedures when making a change to WBN1 , 1-GO-1 Start-Up from Cold Shutdown to Hot Standby (drawing the bubble) by the l(b)(7)(C) Ion November 9, 2015.

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 12 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On November 9, 2015, Unit 1 was performing a plant start-up using 1-GO-1 following a forced outage. The plant hit a point in the start-up where they were to "draw a bubble" in the pressurizer. The procedure required the plant to be heated up to at least 135°F before going any further but the plant needed to remain near 100°F due to work that was ongoing on the head. The OCC requested Unit Supervisor (b)(7)(C) to dr

• the pressurizer with the current plant conditions. b 7 c showed SM (b)(7)(C) the rocedure rohibition to the re uested action and communicated it to t e (b)(7)(C) b 7 was the OCC Operations representative, and directed c _ __.

Is b 7 c to initiate a change to plant operating procedure 1-GO-1 to compel the Unit 1 operators to continue with the scheduled plant start-up activities with RCS temperature below 135°F. The change was made as a "Minor/Editorial" change not in accordance with TVA procedures but was approved for use by llbl(7l/Cl I When concerns were raised by the Operators about the validity of the procedure change, !tb)[?l/C) I responded with "the people who fire people with licenses said to do it."

As to Allegation No. 4 Watts Bar failed to follow Plant Operating Procedure 1-GO-1 when Unit 1 was transitioned from Mode 5 to Mode 4 without normal let-down in service and continued with 1-GO-1 start- up activities on November 11, 2015.

On November 10, 2015, SM !(b)(?)(C) !held a crew meeting and "berated the crew saying that we were not pushing hard enough on this outage to move the plant fo ard and were weak." This was reportedly after l(bl(?l/C) I received a scolding from the (b)(?)(C) l(bl(?)(C) Ithe day prior on the same topic. At this time, WBN1 was in the...._p-ro-ce_s_s_o_ st,....arting up the plant from a forced outage. The plant was in Mode 5 and making preparation to go to Mode 4 following the steps of 1-GO-1, Unit Startup From Cold Shutdown To Hot Standby, when a leak required repair on 1-FCV-62-70, Normal Let-down Flow Control Valve. This required the normal let-down system to he removed from service and excess let-down was placed in service Planned repairs overnight from November 10, 2015 to November 11 , 2015, were not completed and Normal Let-down was not available as expected to continue with the plant start-up. With the normal let-down system out of service, WBN1 was relying on excess let-down and RHR let-down to control pressurizer l,evel.

On November 11, 2015, WBN made the decision to continue start-up activities of 1-GO-1 and transition the plant to Mode 4 without normal let-down in service. The licensed operators watch standing for Unit 1 indicated they did not agree with the decision because it would require the removal of the RHR s stem from service and it was roviding both inventorfu and tem erature control for the RCS. (b)(7)(C) compelled SM I blUJ[Cl the RHR system be remove rom service agams e JU gement and concerns of the control 1 to direct room operators. RHR was subsequently taken out of service to perform testing on 1-SI-0-905 (Primary Pressure Boundary Isolation Valve Leak Test Residual Heat Removal Return Valves -

this test could not be performed while RHR was in service). Due to charging and increases in RCS temperature without RHR in service, PZR level began to rise uncontrollably. The

,~e, FeR 1-UBUe 01aeteaURE WITI Ieu, )l(flf1Re1~1>'<L eF SPECIAL Ae~n l~J GI lpA,lilGe, QFFIGe QF IW.'lsieTIQ,£\+IO~Ha, ~-cI0~1 II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 13 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Operators attempts to control temperature were unsuccessful which resulted in the level in the pressurizer (PZR) rising to 80 percent.

To mitigate the event, the Operators opened the RHR inlet valves, 1-FCV-74-1 and 1-FCV-74-2 (RHR suction from RCS Loop 4 HL), to allow RHR let-down to be placed back into service and regain control of PZR level. These actions were performed outside of the requirements of plant operating procedures. (See NCV 050003

• to Use Approved Procedures to Place RHR Let-do

• U1 Outa e - 60 MIN (b)(?)(C) U date to the (b)(?)(C) b 7C rvice). The (b)(7)(C) sent an email with subject and others which included updated details of plant operational schedule for the day. Included in this schedule was information detailing that pressurizer (PZR) level was at 80 percent and the scheduled testing and heat-up were delayed until normal let-down was brought back into service.

As to Allegation No. 5 Submission of iocaroolete and ioaccm~te information by TVA Managers on December 14, 2015, tol(b)(l)(C) j egarding the details surrounding the WBN1 start-up on November 11, 2015.

On Noyem~ 23, 2015, Concern Individual (Cl) RO !(b)(7)(C)  ! contacted NRC !(b)(?) I l(b)(7)(C) j at WBN with concerns that the WBN 1 heat-up performed on November 11, 2015, was done in an unsafe manner. According to the Cl, the primary let-down was not available (and assumed available per procedure) and excess let-down did not have the adequate capacity to control pressurizer level. Additionally, the Residual Heat Removal (RHR) System was operated outside of procedural bounds to compensate for the out of service primary let-down, and annunciator alarm response procedures were not followed. Lastly, the Cl stated that the Main Control Room (MCR) was ordered to proceed with reactor heat-up and use RHR let-down even though the licensed operators felt uncomfortable.

On December 4, 2015, TVA Senior Executives had a drop-in meeting with !(b)(7)(C)

!(b)(7)(C)  ! In this meeting, i(b)/7)/C i conveyed to TVA to pay .....

a.,..,.

tte_n....,.t-,o-n..,..to_ __

operations department issues as WBN2 moved into fuel load, low power testing and power ascension testing. Issues in terms of operations behaviors as well as the health of Corrective Action Program (CAP), including the need for NRC to prompt TVA for CAP usage/rigor for WBN2, were also discussed.

On December 8, 2015, information was presented at an NRC RII ARB. At the time, the safety significance was considered to be low, and it was determined that NRC technical staff would review information to determine if a violation occurred without disclosing the issue to the licensee. Although the events in question took place over a federal holiday (Veterans Days) without the NRC resident inspectors on site, the inspectors identified that TVA made no entries in the plant operating logs or in the CAP about the events.

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 14 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On December 11, 2015, a follow-up ARB was conducted; at which time, the safety significance was elevated to high, due to inspection discoveries and numerous unanswered questions related to how and why the licensed operators o erated the plant including the RHR system during recent start-up. The ARB instructed (b)(?)(C) o re uest information from the licensee surrounding the plant start-up of November 11 , 2015. (b)(?)(C) specifically asked the Operations on-Shift Manager !(bl0(Cl I "Why were the RHR inlet valves cycled?" This and other questions were articulated to TVA so as not to f ingerprint the source of NRC information.

Onl(b)(7)(C) I e-mailed accurate information to !{b)(7)(C)

!(b)(l)(C) I concerning the cycling of the RHR inlet valves on November 11, 2015. The e-mail explained that pressurizer level increased, and it became necessary to place RHR let-down back in service to lower pressurizer level. b c subsequently initiated Condition Report (CR) 1114975 to document (b)(?)(C) concerns and the licensee's responses. Information concerning the loss of control of pressurizer level was not included in the condition report and was not entered into t he CAP as required by NPG-SPP-22.301 , Condition Report Initiation.

On !rbl(7}1C} Isent emails to !(b)(7)(C) !and l(b)(?)(C)

!(b)(7)(CJ !which contained incomplete and inaccurate information concernjna the RHR iolet valves cyc[jnq on November 11, 2015 l1b1m1c1 Isent an ema il to the KbJ(7)(C) !which contained both the accurate information indicating the RHR inlet valves were cycled to manage pressurizer level but also included the inaccurate information concerning the RHR inlet valves cycling received from

!lb)/7l(Cl I He noted that this was to be included in response to the NRC (mt questions and was intended forl(b)(?)(C) Ito present this information to NRC executives.

• On December 14, 2015, in res onse to the NRC's questions, !/b)(?)(Cl Iand !lb)/7)/C} I met in the NRC resident office with (b)(?)(C) and provided TVA's written response to the questions.

This response did not contain information about the loss of control of pressurizer level, but rather the response contained an alternate reason for opening the RHR inlet valves on November 11, 2015, as 'This was done to allow the repair of a valve inside containme nt on the normal let-down line (1-FCV-62-70)." Following the meeting with [(b)(7)(C) l sent an email to WBN Senior Reactor Operators with accurate information regarding the events on November 11, 2015.

As to Allegation No. 6 Submission of incomplete and inaccurate information by TVA Managers to the NRC in response to NRC questions concerning the November 11 , 2015, RHR event as documented in Shift Order 15-50 and presented to the NRC during a site visit in January 6, 2016.

On December 16, 2015, RII held an emergency ARB; at which time, the convening members requested 0 1:RII perform an Assist to Staff (2-2016-015F) which would encompass interviewing the Cl and licensed operators with RII technical assistance to obtain information regarding the

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF

~1-ECIAL AeEPH IPJ 0 1lii!ROE, OFFIGE OF ltWEGTIOMlmJG, AEOlmJ II 6 f'f'le l,-L U9!! 614LY 01 INVESTIGATION INFORMATION 15 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION WBN 1 event on November 11, 2015. This was a continuation of the response to the allegation previously brought to !(b}(7)(C) I On December 16, 2015, TVA !(b)(7J(C) !interviewed the Control Room Supervisor Dennis REDINGER on shift re the events of November 11, 2015. He provided his notes of the interview t (b)(7)(C) and they were forwarded to !{b)[7lfCl I on December 17, 2015. b 7 c was present for the interview when it was documented that REDINGER expressed that using excess let-down to manage pressurizer level made the crew uneasy, but Operations tries to get things done to support the plant.

) C) sent a document titled '1(b)(7)(C) I' to !fb}U)/C} I c ' to TVA Senior Management including !lblf7l[Cl I and (b)(7)(C) c ' to Watts Bar Managiement including ,_(b__)(?__)(_C)_ _ _ ___,

c , b 7 c and !rb}U)/C} I The '1(b)(7)(C)  !"described how the loss of control of pressurizer level was unexpected because operators believed that based on their training the excess let-down system could handle changing plant conditions.

On December 18, 2015 !lbl/7}/CI I approved Shift Order 15-50.

On January 6, 2016, !(b)(?)(C) Iaccompanied b a NRC officials, conducted a site visit at WBN which included attendance by the (b)(7)(C)

(b)(7)(C) unng this meeting, the Watts Bar managers jointly made a presentation to the NRC that included information about the events of November 11, 2015. TVA presented information that placed responsibility for the events of November 11 , 2015, on poor operator fundamentals, lack of conservative decision-making, and failure to follow internal rules of the licensed operators. The contents of Shift Order 15-50 were questioned NRC, and the content validity affirmed by

![bl(l)[Cl I ;:ind !fb)(71iC1 I On December 18, 2015, !fb)[7)[Cl Iapproved Shift Order 15-50. The Shift Order was developed in response to the November 11 , 2015, heat-up, with the intent that "The guidance will be used for making plant decisions during degrading conditions." The Shift Order attached the (b)(7)(C) which indicated that on November 11 , 2015, members of the MCR operating crew , not expect the uncontrolled level rise in the pressurizer because they thought they would be able to get 50-60 GPM from excess let-down which would stabilize RCS inventory.

The Shift Order attributes these errors in assumption and plant knowledge by the crew as the foundation for the events of November 11, 2015. The Sh ift Order presents the operators as the sole cause for the events of November 11, 2015.

As to Allegation No. 7 Submission of incomplete and inaccurate information by TVA Managers to 0 1during interviews on December 18, 2015.

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEOIAL ,a,QDH l~J GI lpA,lilGE, 9Fifiiil'uiil Qfiii l~IHlii~Tl<.AIIO!>IS, PFGIOM II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 16 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On December 18, 2015, 0 1conducted interviews of WBN employees associated with the events of November 11 , 2015.

!/b)(l)/Cl Imade statements during his 0 1interview under oath that no operators said that they were uncomfortable at any time, includin~ the discussions of whether excess let-down would work the way it is supposed to work. !rb mrci Ifurther denied that anyone brought up anything associated with being forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all about the circumstance and decision-making process.

!(b)(7)(C) I during his 01 interview under oath discussed with 0 1 his motivations for proceeding with the start-up activities, crews concerns, and who made the decision to move forward.

!(h)Q){Cl I later made contradictive statements concerning the testimony he provided 01.

Later on the !(b)(?)(C) Iand !/bl(l)/Cl Iexchanged emails discussing their 0 1 interviews. T his included details on information that was either withheld and

/or misrepresented to 0 1which specifically ointed to senior management's role in making the decisions on November 11 , 2015, and his (b)(7)(C) fear of retaliation if challenging management's decisions.

As to Allegation No. 8 Submission of incomplete and inaccurate information by TVA Managers in a Level 2 evaluation associated with Condition Report (CR) 1121520 on January 20, 2016. In January 2016, as part of CR 1121520, TVA performed a Level 2 Cause evaluation to address the specifics of procedure use and adherence associated with GO-1, SOl-74.01 (RHR) and NPG-SPP-01.2.1 ,

Interim Administration of Site Technical Programs and Procedure for WBN 1 and 2.

On !(b)(7)(C) !emailed notes generated during interviews I f o erators and mana] ers about the events of November 11 , 2015, to !(bl(7l(C) I!(b)Q)(C) I 7

(b)(7) !(b)(7l(Cl I l{b)(7)(C) I I and !(b)(7)(C) among others. These notes indicated that the OCC had knowledge of and was directly involved in the decision to take the RHR system out of service for testing . It also indicated that operators were questioning the capability of the plant to be operated in that configuration.

On !(b)(?)(C) I sent emails to !(bl(7l(Cl I!(b)(7l(Cl I and rriiiaJ which contained the written statement of REDINGER concerning the events of November 11, 2015. REDINGER's statement indicated that the OCC was informed that the MCR staff was concerned about the heat-up and capacity of the excess let-down system at low pressure if the RHR system was taken out of service for testing .

sent emails to IIlillII which contained the written statement of

..,_____......,_c_o-n _ce_r-ni,....

n-g ""'

th,....e- ev__,,

ents of November 11, 2015. !fb)/7}(Cl I statement indicated that the OCC direction was to remove RHR from service and allow RCS to heat up once 1-SI-0-905 was complete and the OCC was informed of the crew's concerns with taking RHR out of service for testing.

,~e, 1-eR 1-uBue 01aeteauRE WITI 1eu, >'<flflRe'~'>'<t e1-srcc1AL AGDH l~J GI hO.RGE , OFFIOE OF ltWEOTIOMIOP40, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 17 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION On l(b)(7)(C) lsent a draft copy of the Level 2 produced during the weekend to

!!bl/J /cj I ;:ind 116\W/c\ I requesting feedback stating, "...  !(b....

)(7)__(__ C)_______________.

!(b)(7)(C)  !". The apparent cause implicated both the OCC and MCR directly in the cause of the event.

On l(b)(7)(C) Iduring a teleconference between /g?i7lr!/'b/(7l(Cl Level 2 Cause A nalysis was discussed. Later that day, 7 I

directed information be and !(b)(l)(C) I the removed from the Safety Culture Analysis for CR 1121520, which indicated that the OCC was directly involved in decision making on November 11, 2015.

On !(b)(7)(C) !as part of CR 1121520, ~ !(bl(7l(Cl I  !/bll7l[C} I;:incl !rb)U)[Cl I participated m the generation of the finalized Level 2 evaluation for CR 1121520. The final evaluation indicates that the decision to remove RHR from service and continue plant h eat-up on excess let-down was not recognized or challenged by the OCC on November 11, 2015. The final evaluation attributes errors in assumption and knowledge of plant response and capabilities of the control room operators as the cause of the evolution and its outcome. Information identifying the OCC and management involvement in the events of November 11 , 2015, are not included in the final report. Additionally, information detailing that there was no plant operating procedure for the use of excess let-down to control pressurizer level following isolation of the RHR let-down was removed prior to approval of the final evaluation.

As to Allegation No. 9 Submission of incomplete and inaccurate information by TVA Managers to the NRC during the February 2, 2016, meeting with the NRC.

On February 2, 2016, TVA's!(b)(7)(C)

!lblU}(Cl I ;:inrl llbll7l/C} I mad....e- a-p-re_s_e_n.,..ta...,.,ti,...o_n ..,..to_,,.,.th-e"""N....R~C,,.......w....h....ic....h....,i-nc-.1-ud....e-d.,...i,....n....fo-rm

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placed sole responsibility for the events of Nov 11, 2015, on the control room Operators. The presentation specifically cites a lack of conservative decision making and risk review by the Operators; and that the decision was not recognized or challenged by the OCC.

As to Allegation No. 1O Submission of incomplete and inaccurate information by a Senior TVA Executive to the NRC as documented in the March 23, 2016, TVA Special Review Team Report.

On February 24, 2016, TVA OIG briefed Region II management on a summary of information they had gathered during investigative interviews regarding the work environment at WBN. TVA OIG informed RII that the information had also been briefed to TVA management on multiple occasions.

On February 24, 2016, NRC informed TVA that the NRC had received information from TVA OIG that gave the NRC concern for the health of the working environment at WBN, specifically

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 18 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION in the Operations department. The NRC informed TVA that it had entered these issues into the NRC allegation program.

sent an email to (b)(7)(C) statin (b)(7)(C) Shortly afterward, (b)(7) sent an email to (b (7)(C and others which included details of the Problem, Objectives and Key Activities of a team which would come to be known as the TVA Special Review Team (SRT). \

(b)(5)

On (b)(7)(C) sent l(b)(7)(C) Ihis thoughts/guidance regarding a meeting (b)(7)(C) I was scheduled to have with Hb\(l)(C on the following Monday (!(b)(7)(C) D.

(b)(7)(C identified success of the meeting would be to gain an agreement from !(bl/7HC for the I NRC to delay taking an hi hly visible action against TVA and to first allow TVA to address the TVA OIG concerns. (b)(7)(C) ecommendations included: countering parts of TVA OIG's message; attempting to "delink" the need for NRC actio ** milestones* and offering additional meetings with RII management. On (b)(l)(C) sent (b)(7)(C) an email containing the SRT's preliminary conclusions.

(b)(5)

The next day (b)(7) reinforced the purpose for the SRT in an email sent to (b)(?)(C)

I l(b)(7)(C and the members of the SRT which identified that, in part, the projec ....t""""w"'"a'"-s-to_ m..,...

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additional regulatory engagement.

On (b)(7)(C)

(b)(7)(C) __. and (b)(7)(C)

,......,,,..__ _. and..,_-------....-~~ ~- : - - - --:-::=-==-=-""'"'."""-:-:-::~-On~(~b)-;::- (7)r-(Cr-

) -:-:----r--1 ard - -004 *.,..r..= ,J..U;i.lo,l,o to the SRT members an (b)(l)(C) On (b)(7)(C)

!(b)(7)(C) !sent an email to detailin the differences between the report and the SRT initial conclusions as being (b)(7)(C) !rb)(l)/Cl I sent ~ n email on (b)(?)(C) which suggested information to be completely removedTronilhe SRT report.

(b)(7) approve some of the changes for information removal.

sent an email to (b)(l)(C) b 7 c and ......................., which detailed a strategy to present the differences to the NRC between the ECP and SRT report conclusions.

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 19 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On l(b)(7)(C) lthe SRT report Revision 21, to members of the SRTI (b)(5)

Agent's Note: Keeping with the chronological order of the report additional information concerning Allegation No. 10 is delineated following Allegation No. 11.

As to Allegation No. 11 Submission of incomplete and inaccurate information by Senior TVA Executives to NRC Senior Executives on March 13 and March 15, 2016.

On March 11, 2016, the NRC completed an initial review of the information provided by TVA OIG associated with their investigation into the work environment at WBN and made a decision to issue a Chilled Work Environment Letter CEL to TVA. NRC (b)(7)(C)

!{b)(7)(C) I and NRC (b)(7)(C) held a teleconference with lrbl'7l/Cl I~nd (b)(7) in which they conveyed that the NRC had issues w ith the safety culture in the Operations department of WBN and were plannin to issue a CEL no later than T uesday, March 15, 2016. Afterwards, (b)(7)(C) ent an email to b (7) C)  !(b)(7)(C} I and !(b)(7)(C) Iwith Revision 21 of the SRT report an detailing that the report will need to be changed in response to the NRC issuing the CEL.

On (b)(?)(C) exchan ed emails with b on how to a roach a personal conversation with NRC (b)(?)(C) aimed at changing the proposed re~g,..,..u,,..,a:-T'o

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This included communicating that TVA was "not surprised" with the NRC conclusion of a degraded work environment because two independent TVA internal reports had been completed last week which reached the same conclusion as NRC. One of those reports was the SRT report, the ECP report was the other.

On l(b)(7)(C) l ltblCZ)/Ql I c;alled llbll7l/Ql I at his residence to discuss the regulatory response to TVA concerming the work environment at W BN.

On March 14, 2016, l(bl(7}(C l sent an email which informed NRC leadership that the timeline for issuance of the CEL may be delayed until after the March 22, 2016 public meeting.

O n !(b)(?)(C) I a significantly revised SRT report, Revision 22, to members of the SRT, which changed multiple report conclusions, removed information that conflicted with the ECP report, and added information that made the report align w ith t he information provided by the NRC on March 11, 2016.

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 20 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On !(b)(?)(C) l I

!(b)(?)(C) anrl ilblmrc I had a teleconference with lrbl(7)(C) I that discussed delaying the CEL and discussed the same information provided to lrbl{7)1Cl I on March 13, 2016.

~ ~(b""")(7)

.--(C_) _ _ _ _ _ _ __,.d an email exchange with . ,_Hb..,. 7)(.....

)(.. C). __ __,

-~~~~----~~~_ in_w_h_ic

....h..,the two discussed the effects of the calls during the weekend with b 7 c and (b)(?)(C) They discussed that the issuance of the CEL will be delayed until after the Marc , public meeting. In addition, they discussed that ilb}m(Q) I and ~ are making a visit to Washington, DC on March 17, 2016, to meet with the NRC Commissioners and possibly discuss the WBN work environment issue. On

.,uw;1J.w.L.i...u-'-4016, l1bll7l(Cl I sent NRC Closed Session Talking Points to and (b)(?)(Cl which contains what ilb}Ul[Q\ I desc[ibed as the initial thoughts of (b)(7) on the messages hat need to be conveyed to the NRC. l(b)(?)(C) ] replied with a concern that the talking points say the SRT did things that they did not, and the tact was risky. He also was questioning the point that l/bl{7)/Cl I was still in the process of revising the ECP report.

Continuation of Allegation 10 On !(b)(7)(C) Iforwarded :,::! C)===._ _ _ _ _ _ __.! email with the copy (b=)(?=)(=

of ECP Report NEC-16-0047 attached to l[b\17\[Cl On !(b)(7)(C) Ireplied to an email from ltbl/7)(C) Iconcerning the conclusion of the ECP report which identified l[b)(7)[Cl I and ltbl(7}(C) I as the cause of a chilled work environment in Operations. llb)/7)[Cl I presented his own wording of the conclusion which absolved himself of responsibility and classified the issue as a communication gap which others filled with their own perception. On !(b)(?)(C) !sent the SRT report and ECP reports to the NRC in which the SRT report documented that:

1. The SRT was assembled by TVA Senior Management in response to a series of issues at Watts Bar Nuclear Plant dated from the fall of 2015 through February 2016.

2. The SRT was established by TVA Nuclear Senior Management after recognizing the serious implications if a concern input into the Watts Bar's Employee Concern Program staff in January 2016 was substantiated.

3. (b)(5) 4.

On !(b)(7)(C) Iapproved and sent TVA's CEL response to the NRC which discussed the SRT report and ECP report. It documented information including:

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 21 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - O1 INVESTIGATION INFORMATION

1. The SRT and ECP investigations were independent investigations initiated in response to the receipt of degraded work environment concerns.

2. The SRT was established in March 2016 to perform a review of culture surveys ,

personnel comments and statements, communications, quality assurance reports, outside organization , and regulatory reports in order to develop prompt and near-term actions to address the degradation in the work environment and correct the behaviors that were most likely driving the degradation .

,~e,= FeR fi'UBLl6 Dl96L69URE 'l'VITI ISUT >'<fi'fi'RS'"'>'<L eF OPEO IAL AOEPdf IPd 0 1IAROE , OFFIOE OF IPd~'EOT IOATIOPdO, REO IOPd 11 6 ffleliltt USE 614 LY O1 INVESTIGATION INFORMATION 22 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No.1 Watts Bar senior managers deliberately took actions which placed Watts Bar senior managers either directly or through the Outage Control Center, as the de facto directors of the licensed activities of the control room operators. This represents a violation of 10 CFR 55.3 which requires that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator which includes directing the licensed activities of licensed operators.

Applicable regulations 10 CFR 55.3: License requirements 10 CFR 50.5: Deliberate misconduct 10 CFR 50.7: Employee Protection Documentary Evidence Draft Analysis No Pocket Veto W Enclosures (A 1-E1)

All !(bJ(?)(CJ I F.mail Statements (A 1-E2)

(b)(?)(C) (b)(?)(C)

Email e questing hourly outage updates (A 1-E3)

Email S,ends !(b)(7)(C) ISOD SOM Checklists (A1-E4)

Email hbl(7l(Cl I sends out Checklist (A 1-E5)

Email RE U1 Outage - 1930 Dayshift Hourly Update (A 1-E6)

Email PMMC R Observation (A1-E?)

EA-17-022 Confirmatory Order ML17208A647 (A1-E8)

EA-17-022 Confirmatory Order ML17208A596 (A1-E9)

IR 050002016013 ML17069A133 (A1 -E10)

Email (b)(7)(C) llb)(7)(C) IOn crew logging By OCC Direction (A1-E11)

Email I

!(b)(7)(C) Stop Logging by OCC direction (A1-E12)

Email Email!(b)(?)(C)

!(b)(?)(C)

II told shift to stop logging by OCC direction (A1-E13) l!(b)(7)(C) ! email MCR Observation (A1-E14)

SPECIAL AGEl<I I ilQ CHARGE, OFFICE OF ll<IV~~TIGATIOl<I~. l"!~GIOl<l 11 6 f'f'le l,-L U9!! 614LY Of INVESTIGATION INFORMATION 23 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Testimony Interview of ... l(b_l(_?l(_C_) _ _ _ __,I Shift Manager

!(b)(?)(C) I Shift Manager at WBN was interviewed by TVA OIG on February 17, 2016, wherein he rovided the followin information in substance. ilh}(ZJ/Q) I has been employed (b)(?)(C) ...byTV s and b 7 c He is a licensed SRO and became a SM in (b)(?)(C) c stated that "our outages delve into chaos" and stated that re-fueling outages have been planned for 18 months prior to the start of the outage and include a comprehensive review of potential safety issues. However, by the end of the outage, the OCC has put so many things on the operators that they the o erators are literally just winging it and making decisions in knowledge space.

b 7 c explained that this means that the operators are relying on their individual knowledge to determine whether something is safe or not which is where most errors can happen. !rbl{?)[C} I stated that the original plan which was developed in a calm safety conscious manner is thrown out because of the desire to move forward and it is chaos. During the last re-fueling outage (October 2015), ilb)(Z}/Q) I was actually sent pictures by email of marked up whiteboard drawings from the OCC showing how they wanted him to proceed (Exhibit T-32).

!rb1111rc1 I testified that there was an off-site meeting *ust before the fall of 2015 re-fueling outage. !rb1r11rc1 Ithought that b 7 c and lib}(7\/C} I were in attendance. According to b 7 c ~ u . i . . . i told him after the meeting, about comments made by i[b1[7}(C1 I and b 7 c at the meeting. Specifically, !/bl{7)/C1 Iwas told that !rb\(7l[C\ I stated something like, "If anyone does not think we are ready for this outage then they can get up and leave." Reportedly, !ib1(7)[C\ I told the group that the SRO's were not going to be able to use their "~~~~tlo! er" during the outage. When asked during the interview, what !lb}{7)/C} I thought b c was saying in regard to the veto comment.

![bl{7)/C} I said that i[bl(?)(C} I was sayin] that the SRO's could not stop evolutions during the

~ f the SRO's thought it necessary. I b1(7)[C} I said that the comment made by l!.!2lillLQLJ is still in the back of his mind now and he thinks about that comment as he makes decisions in the MCR (Exhibit T-32).

Interview of l(b)(?)(C) ISenior Reactor Operator

!(b)(?)(C) I SRO at WBN was interviewed by TVA OIG on February 24, 2016, wherein he provided the following information in substance.

!rbl/7\[C} I confirmed that he was present at a pre-outage offsite meeting held at the Springbrook Country Club in Niota, Tennessee. According to !{bl(7l(Cl I the meeting started out talking about the upcoming outage which was scheduled to last 30 days. lrbl{?)[Cl I and

!lb}/7}[Cl I were !{b)(?)(C) l The statement was made that by a show of hands is there anyone here that thinks we cannot make the 30-day outage and if you raise your hand then you can leave. i[b}(7l[C\ Ihad the feeling like if you walked out the door then you could leave the company. Specifically lrb}(?\/Cl Ifelt like he would be fired if he raised his hand

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 24 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION saying he disagreed that they could make a 30-day timeline. He did not feel he could say let's talk about this and the comment set the tone of the meeting which was "inputs neither required nor desired" (Exhibit T-09). !ib)(?)IC} Istated that toward the end of the meeting that day, clickers were passed out to everyone to use in anonymously answerinZI around ten questions that had been put up on a screen. One of the questions was what !/b)/7/Cl I had asked earlier about do you think we can ~et the outage done in 30 days. While no one had raised their hand in front of !(b)/7\(Cl Iand IP)ll)<C) I earlier, there were now around 40 percent of the attendees saying no they did not think they could do it within 30 days. !(bl(7)/Cl Istated that there is a problem if you cannot raise your hand because you are afraid of the repercussions (Exhibit T-09).

In the original opening statements at the offsite with llb}U)/Q} I I~nd !(b)(7l(Cl !fb}(7}/C} I stated that another incident happened regarding (b)(?)(C) SRO at WBN. Specifically, ITfilmD raised his hand and said that we have a history w ere we o not meet the schedule because it keeps changing and what are we going to do different this time. l!b)/7}/Cl Ithen stood up, dug his heels in and went at ffiillnD by saying that is not the attitude they want. !(b)(7)/C\ Ithen said, "SROs are losing their pocket veto." l!b)(l)(Q) Istated that he felt that !lb)(l)(Q) I meant by that comment that Operations is going to follow the schedule and not point out something that will not work. Either Operators will follow the schedule or face backlash. !lb)(7)/Cl Istated that llbl(?)(C) I pocket veto comment was made in front of everyone at the meeting. !lbll?l<Cl I stated that he was l ro~rz~ruT ised by the comments about the pocket veto because he has gotten 1

the impression that b C is not a fan of Operations. He believes llbl(l)/Cl I feeling is do what

~ e told to do or hit the door. l[b\ffi(C) ] stated that when !lbl0(Cl I got done chewing up ll.!illZlIJ at the meeting there were no more questions, and everyone kept their opinions to themselves (Exhibit T-09).

llbl/7)/Cl I heard l!bl/7)/C) I later make a snide comment to IIiillZIT:1 saying "that did not go the way you thought." llb)(l)/Cl Istated it was a "jab" at l(b)(?}(C I He stated that morale was not high when they left the meeting. !lb}/7)/C) I was on the team that did the Appendix R Root Cause Analysis which took thirty days. According to !(b)(?)(C) I the team put in a lot of work.

He stated that some of the team members even slept over in the training center to get it done.

The team came up with what they thought was the root cause and one of the things in there was the nuclear safety culture at the site. Specifically, llb}(l)/Cl Istated that not having a good nuclear safety culture was in the summary as a contributing cause to the inadequacies in the fire protect' owever, "it got squashed" by management. !lb}(7}/Q} I stated that the team lead, (b)(?)(C) presented it the management committee and then came back and said he had been irec e o remove the safety culture ~ortion. !(b)/7}/Cl I stated "we had to take the actual words nuclear safety culture out." !lb){?)IC I recommended talking to !(b)(?)(C) I who has been on several other root cause analysis teams and has had things like this taken out by management before. As part of their analysis the root cause team made up of several people work a minimum of 10 to 12-hour days for 5 days a week and sometimes on weekends on this one issue. They have pulled and reviewed hundreds of documents not readily available as well as conducting interviews. The team meets and come up with their conclusions based on the information and to have management just suddenly clhange it because they do not like what

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 25 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION it says is frustrating. !(b)f?)(Cl Istated it has come down to "when we have a root cause, it is kind of like j ust tell us what you want us to say and skip the 30-day part" (Exhibit T-09).

Interview ofl(b)(7)(C) IUnit Supervisor I

!(b)(7)(C) US at WBN was interviewed by TVA OIG on February 18, 2016, wherein he provided the following information in substance.

!rb}/7}(C} I stated that he has been a us for (b)(?)(C) years. Hj(~tm~n t is career at TVA in l(b)(7)(C) !and received his license In (b)(7)(C) b 7 c stated that he was not in attendance at an offsite meeting before the re-fueling outirr~d)~s, fall but was aware of the events that transpired. lfb}/7\/C} ] stated that his coworker, b c told him the !(b)(7)(C) said, I "SROs do not have a pocket veto." !rbl(J)(Cl I stated to him the statement means he cannot push back and say no even when it comes to a safety concern. l!b)(7)!Cl I stated that he went through the hiring process to become an Operations Lead Instructor. lfbl/7\IQ} I stated that he applied, interviewed, was offered the position, and accepted the position in!(b)(7)(C) !but was told he could not leave his current osition. !(b\(7)/Cl I stated that his boss at that time was !(b)(7)(C) I who reported to (b)(7)(C) and then b c . l/b\(7)/C} I could not remember who t he Site VP was at that time. b 7 c and (b)(7)(C) old !(bl(7l/Cl I that he "could not go" to the training department. l/b\/7jlQ) I stated hi, received an email stating he could j oin the training department in approximately _(b)(7)(C) _, after the completion of WBN2. ilb}/7\IC} I agreed to forward a copy of the email to the interviewing agents. The position closed just before the first of this year, so !rb}/7\IQ} I 110 longer has the ability to move into that position. lfb}(7}[Q} I stated that he believes !(bl/7\(C} I and lrbl(7HC Ifound out about the position because Operations Training is under Operations, so it is still in the same chain of command (Exhibit T-1 0).

l/b\17)/C} I stated that at the time he was told he could not go to training he did not push back or cause any problems because he did not want to make any waves, he did not know he had any recourse and he th't.~aht WBN2 would go on line and he could move to training. lfb\17\/Q} I stated that (b)(7)(C) or~b)(7)(C) lin training were told by Operations that lrb}l?)rci I could not go.

b 7 c stated that he was mad about not being able to leave but did not discuss his feelings

• h anyone at TVA, just with !(b)(7)(C) I l/b}(7}[Cl I stated that he has been in shift work for lbJ(7JICJ ears and was tired of working shift work. lfb\(7}/Q} I stated his background is in training with (b)(7)(C) and he thought that going back to training would be the most beneficial for 1mse an t e est way to contribute to TVA. l/b}(7}/Q} I stated that thirhlr~}~~~iT was at the same base salary rate, but he would no longer receive the shift differential. stated a new training position recently opened at WBN and l!b)(7)[Ql I has applied for the position as an Operations Instructor. However, lfb\17\[Q} I stated that the reputation at WBN is that the only way out is to leave the company. i(bl(7}/C} I stated that he did not tell any of his supervisors that he applied for another training position but stated they will find out because training works for Operations (Exhibit T- 10).

l!b}0[C} I stated that the problem at WBN is "bull~ enior management." !rb}0[Q} I stated that he started to see this after !(bl(?)(C\ I and ~ were moved into their positions, but it really began with !lb\/71/Cl I !lb\(7)/Cl Istated that at the re-fueling outage in 2012 he was

,~e, fieR 1-UBUe 01aeteaURE W ITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 26 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION promised his Qual card prior to the start of the outage but following the outage he did not get it, and nobody could tell him why. !(bl(7)/Cl Ithinks the reason he did not get the Qual card is because he pushed back on the OCC and they missed the schedule by approximately a week.

hblmrc1 I stated that he will still push back if there is a safety issue, but he still thinks twice about it. !lbl/7)/C} I stated that the staffing at WBN is low and is only getting worse with more people leaving, and there is no current SRO class. llb)(Z)IC} I stated that since the OIG began investigating it is giving people some hope because at least someone has noticed what is going on. [ii)im1c1 I stated that in the last two weeks he has received two blue chips, but prior to that he had not received a blue chip in at least two years. !/b)0CC) I stated that it is like they are trying to bribe us. !/bl/7\(Cl I stated that !/bl(?)(C} I is not really visible to the SROs, but he interfaces more with the unions. llbl(l)IC} lis torn between how he feels and towing the party line. !lblU)/C) I stated that llb)U)IC) Iwants to do the right thing, but he is afraid for his job too and could be gone tomorrow (Exhibit T-10).

Interview ofl(b)(?)(C) li6l(7)(C) lat WBN was interviewed by TVA OIG on A pnl 15, 2016, wherein he provided the following information in substance.

11,1r11c1 (b_

)(7_)(C_l _ _ _ _...,! (Exhibit T-11).

coordinated all the Ops SI activities during the outage wh1ich b 7 C described as ver sensitive work and incredibl im ortant. Toward the backend of the outage, !/bl/7\/Cl 1 came to l!b)U)IC) I And said he (b)(7)(C) had been sent home. !!bl(7}/Cl I was not detailed about what had happened but said that he had a problem wjth how they were settjna up on an SI. !lbl(7)/Cl I believes that !lb1(7}/C} Iwas tr ; inQ to 9et the l(b)(7)(C) ] to see his point about how it was being done and !lblCl /Cl was not getting it (Exhibit T- 11 ).

!/bl/7\(C) I knew eve~ one was stressed. llb)U)(Cl I told llb)U)(C} Ithalr~~}~;grt not have been vem respectful of l 17\(C)  ! and he !(b)(7)(C)  ! sent me home. stated that

!1bl)1c1 I was "physically shaking" and he is a very strong person. !lb)(l)/C} I stated that he and

!lbl(7}(Ql I have done things on shift that would rattle anyone, and !lb}mlCl Iwould not be rattled. However, "this was the first time I ever saw him practically in tears." llb){7}[C) I stated that what happened with !lb}/7}/C} I being sent away was the "first time I have ever seen anything like it." l1b1m1c1 I stated that no one talked to him about !/b)(7)/Cl  ! leaving or how it would impact the work. Since there were only four SROs doing the work, the loss of one of them was a large impact. !/b\17l/C} Iwas not given the chance to do a turnover and the situation resulted in

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 27 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION the SI group missing a whole day of work during the outage in doinU Sis because they had to figure out where they were at because the information had been in blf7lfCl I head (Exhibit T-11 ).

I According to !(b)(7)(C) there was a more professional way to have done this. At the conclusion of the outage, there was a lesson learned meeting with all the leads. It was not a big deal but rather just a think tank to critique and figure out how they could do things better. !lblm(Cl I was at the front of the room writing down ideas. After about the second or third whiteboard, l!b}/7}/C\ I spoke up and said he knew this was a hard subject, but they needed to look at how the deal with confrontations especially if they lead to sending someone home and losing a day.

(b)(?)(C) stated that he made it very generic and clear that he was talking in generalities.

(b)(7)(C) brought the topic up in a professional manner. ilbJ(l)<Ql I was not aware that had come in and was standing in the back of the room. !fbl(7)(Cl I then s.....

po....,_e....u

_p_ a_n....- 1 ....,.can you provide me any specifics" to which llb)(7l/Cl I replied that he would s_a,..,

prefer not to in front of everyone. !fbl(7)fC} I then said , "No, I want you to tell me the specific incident you are referrin to." When ilbJ(Z}IC} Idid not say anything, !rblf7lfCl I stated, "you're talking about (b)(?)(C) do you know what he said" and then he !(b)(?){C) Isaid something about telling the story like he (b (?)(C was a victim. !/b\(7)/C\ I was very angry after !rbl[7lfCl I comments but kept his cool. b 7 c did not say another word for the remainder of the meeting. He knew that anything that came out of his mouth would be shot down (Exhibit T-11 ).

ilbJ(7}/Q} I recalls !rbl(7)[Cl I saying, "the fix here is not sending him home - we have to fix the human part and the human part is Operations." llb\(7}/C) I took this to mean that ilbJ(l)IC) I represented Operations and that Leadership could not control !fbl(?lfCl I who could go to the occ and speak his mind !(b)UJ(C) 1said i,~~kc, 7 eds to fix the problem." Because of what happened with !fbl(7)/Cl I at this meeting, does not s~~fi~t f j t meetings a~fu~l~~e. He stated that he will not talk anymore because "I like m *ob." b 7 c stated that if b 7 C 1 cannot even listen to constructive criticism then he (b)(?)(C) does not feel like bringing anything up. ilb\(7)/C\ I stated that every time !fblf7l(Cl I walks in a room , "my hair stands on end" (Exhibit T-11).

(b)(?)(C) . l/b){Z}fG) + isEjyears old and stated that he has never .,.w,,u....w..l.l.l.l.i.u...1.1.1..1..""'-lld.-~u.i..1...~ him. The recent personnel move where b (?)(C) "pissed everyone off." He stated that (b)(?)(C) is an SRO and has told him that everyone in Operations is mad. was in the offsite meeting held before the 2015 re-fueling outage. During the meetin,{g\blf?)(C} !heard ![bl(l)!Cl I make the "pocket veto" comment in front of everyone in the room. llb}r7 ! __ . was basically telling everyone that we will not have anyone vetoing work on the schedule. Later at the same meeting, !<bl(?l(Cl I came u~ to llbJ{7}/C} I rind asked him "how can we stop the pocket vetoes?" llb}!7}/C} I believes !rblCTJfC I r~s rsf Xtg how can we fiet people to be less likely to reject the work when it comes up.

b 71c told !fblf?l[Cl that they should give the schedule to the Shift Manjgi~ ~ ~ol review ahead of time, so they were aware of what could be an issue (Exhibit T-1 1). stated the term "pocket veto" sounds bad esr ciallrri if r ople did not have the benefit of discussing it further like he did with !lbll7)(Cl !lbl/7 Cl stated tha~(b)(?)(C) !brought up the pocket

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 28 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION veto statement during his meeting with the SROs. (b)(?)(C) explained to the SRO's

!(b)(?)(C) !interpretation of the comment. At the mee Ing, one of the SROs told !.... (b-)(7-)(-C)- --.

that his explanation was not how the SROs heard it. Also, at the beginning of the re-fueling

..,.........,..~ffsite meeting, !lbl/7}/Cl I started talking about the outage being done in thirty days.

(b)(7)(C) then spoke up and sai1<~;;ac~u !guys do not want to execute the plan you can leave. I do not want you on my team ." stated that nobody wants to raise their hand and say anything different than !(b)(?)(C) I !lb)(7)(C) I stated that since the investigation has started it appears management is backing off. He stated it may possibly be too much although he does think the Shift Managers, though less experienced, will do the right thing. lrblWCQl I was a Shift Manager for!(b)(?)(C) !years but stated it was between the period with the old school hardened Shift Managers and the new less experienced Shift Managers. !fbl{Z)rc1 I does not remember feeling the pressure or going through what the current Operators have experienced.

He stated it was the worst he had ever seen at WBN in regard to morale before the situation came to light (Exhibit T-11 ).

Back in l(b)(?)(C) I was working in the Unit 2 OCC as the Operations Representative when the OCC wanted to do sweeps and vents on the RCS with one RCP.

They were trying to get sweeps and vents done for discovery and do rod control testing.

lrbvzfrc, I stated that the sweeps and vents evolution is one of the most dangerous evolutions that Operations performs because of the otential for lifting a PORV (power operated relief valve). lrb}(7\(Q\ I stated that (b)(7)(C) was questioning why we were doing sweeps and vents. l/bl{7)/Cl l recalled that (b)(?)(C) was also in the OCC and at some point, they were told that they were no longer going to do the rod control testing. !fb\(7)(Q) I then said why do not we wait to do the sweeps and vents later because it is a complex infrequently performed task/evolution (CIFTE) (Exhibit T-11 ).

After raisin the issue there was a conference call with (b)(7)(C)

- - ~ ~ - , -........----r----:--:--~~~

b7c During this call, b c explained to them that he was concerned about what the were doing (a CIFTE) if they were only going to gain twelve hours on the schedule (b)(7)(C) had backed out the numbers). !lb}/7\!Ql I recalls

!(b)(?)(C) Isaying 't~) ~ you just do not understand the schedule." !(b)(7l(C) hhen said they needed to go forwar with sweeps and vents for discovery at which time !(b\(7)/Cl I stated that it was too risky and that a PORV could be lifted and cost the guals of a crew. !ibl(Z)/Cl Iwas then told that they had already talked to l/b}/7\(Cl Iand l/bl(Z)!Cl ) who were in agreement to do it.

!lbl(?l(Cl I Also expressed his concern to (b)(7)(C) , who told llb)WCC) I that it was llbll7l/C\ ] decision to do the evolution because b 7 c trusted his operators to do it.

The swee~....._.,""-L.............,,volution were done the next (b)(7)(C) December 20th and the Unit 0 erator, (b)(l)(C) lifted a PORV. !lbl(7)/Ql I sta e a e vented to (b)(7)(C) and b7c and basically said I told you so. !lbl(Z)!C) I ~tated "I was livid" an poorlifilillI} he was set-up." A little while after his conversation with (b)(?)(CJ and b C !Cb)(7)CQ) I was in the restroom stall when he heard someone he believes to e (b)(?)(C) talking on a cell phone.

The person (possibly (b)(7)(C) stated "we need to gBt the son of a bitch out of the OCC. They are holding up work." stated that he told i(bl(7)(C} l that it sounded like they were trying to get him !(b)(?J(C) I out of the OCC (Exhibit T-11 ).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 29 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION ilb)/7}/Q) I Also later told ECP about this incident. According to !(b)(7)(C) what happened to ~ I

(/bl(l)/Cl I a few weeks later does not make sense. The discrepj ~~b,~~ l hy it took them so long to taken ilb\(7)/C) I off watch does not add up. llb1(7)/C} I believes and llb\(7)/C) I push the managers in the OCC who then put pressure on the operating crews. When l/b\(7)/Cl l or

(/bl/7l[C} I would come in to the OCC, they would point out management deficiencies and rearrange priorities. ilh}l7l/Q} I stated that the OCC is manned because the WBN2 startup is now being treated as an outage. (b)(7)(C) is in the OCC running things now as far as Oper *

• ncerned . ..................._. stated that the Employee Concern investigation was touted as a (b)(7)(C) loternal jnyr tigation and something that he set up. This was brought up during the nffll"!'l'TP'l?!""l'1r7fff\ (b)(?)(C) and the SROs (Exhibit T-11 ).

Interview ofl(b)(7)(C) lsen ior Reactor Operator I

!(b)(7)(C SRO at WBN was interviewed by TVA OIG on February 22, 2016, wherein he provided the following information in substance.

(b)(7)(C)

(b)(7)(C) __,!(Exhibit T-12).

When asked during this interview if he heard ilb}U}IQ} I rnake any statements at an off-site meeting having to do with a "veto." ~ responded that, "He did hear llbl17l[Cl I make a statement." ~ described said that he attended an off-site meeting held before the fall 2015 re-fueling outage. He believes it was in late August 2015. The off-site meeting was held at a country club in Niota, TN. ~ estimated that around a hundred people were in attendance.

I The purpose of the meeting, according to !(b)(7)(C was "team alignment" since they were about three weeks out from the outage (Exhibit T-12).

(/bl(l)/C\ I opened the meeting by saying to the group, "Is there anybody in this room that does not believe we can do a 30-day outage? If there is, they need to leave now." ffiillziD said that this was the 51 st re-fueling outage he has been involved in and he is a firm believer that it is possible to do a good short outage. However, this is the first time he has ever heard a statement like that. ~ and others around him took that statement to mean "you will leave the company" rather than just leave the room. That one statement at the beginning of the meeting set the tone for the entire meeting and everyone was immediately subdued. ~

added that he had a conversation before the li~,~~i~J with llb}/7/f~ I who was working as the l(b)(7)(C) I lat that time. b 7 c had told tdl/Cl that he was going to ask a question during the meeting so that l!blm/Cl l could answer it and highlight all the good th~

he l(b)(7)(C) j had done in preparation for the outage. ~ explained to the agents that WW had mentored (/bl/7)/Cl I (Exh1ibit T- 12).

,~e, FeR 1-UBUe 01aeteaURE WFfl 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 30 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION At one point during the me * , the group was asked if they had any questions. So!(b) raised his hand and said, ' (~(7) what have we done to help ensure that our schedule 1s e er 6)(~{ I than it has ever been before . (b)(7)(C) added to the question, "We all know that the ast schedules have not been in the best quality and downright dangerous at times." (b)(7)(C) started to answer the question but was interrupted by !/b)(7\!Cl I !lb1(7\/Cl I then pro....

ce__e__

d.....

ed- ,- - '

I according to !(b)(7)(C to talk for the next 10 minutes about how that question should not have been asked. During the talk by !(b)(7l(C) 1lrb\/7l/Cl I said , "Operators will no longer be able to use I

their pocket veto. They will be made to follow the schedule". !(b)(7)(C) sat straight UP. in his chair when that comment was madeJ(b)(7)(C) !stated that he has been in this business to,O,ears ... . ....J~)(7)(C) and had never been talked to like that. He has held a license for over half his life and lknows the responsibilities of having a license (Exhibit T-12).

Shortly after iralt~S tr at, !rb\(?)fCl I ended his speech and walked out into the audience a l!rn[ ~nj of the walls. b 7 c worked his way around and through the crowd until he got behind b 7 c Once he got behind b 7 c !lb1!71fCl I said to Rfilillfil] "That did not go the way you thought it was going to go did it?" (b)(7)(C) eplied back to ~ "Once you started, it went exactly the way I thought it would".!(b)(7)(C) ~old the agents that he did not think anyone heard that comment, but he thinks just about everyone heard the veto comment (Exhibit T-12).

!(b)(7)(C) !took the veto comment to mean that ops (operations will do what management wants them to do no matter what the license holder thinks. (b)(7)(C) said this was the first time in his career that he ever heard a mana er make such a comment.l(b)(7)(C) ~tated that he did not challenge the comment because (b)(7)(C) elt that if he challenged the comment he would have been fired on the spot. The .agent asked b 7 C hat he thou ht about lrb)(7}(C) I r.omment to him in the audience. (b)(7)(C) said that b 7 c wanted (b)(7)(C) to know thatl(b)(7)(C) ~hould have just listened and shut 1s mouth. (b)(7)(C) told the agen s a e has never been talked to like that in his career. (b)(7)(C) has never eard operators talked about like that either. j(b)(?)(C) !said that the rest of the mee mg,t ~ ~t~ ed quiet. On the next break he andirb)/?){Ql !spoke.

(b)(7)(C) 7 told (b)(7)(C) that b1 1C "flamr~R~~yr" (b)(7)(C)

(b)(7)(C) thinks b 7 c felt challenged by b 7 c explained to the agents uestion. b 7 c wanted the meeting to be a top down directive meeting and not an exchange. (b)(7)(C) believes that is why !lb}(7\fC) I interrupted i/b}l7l!Cl Ianswer (Exhibit T-12).

!(b)(l)(C) !stated that the problem at WBN is the Senior Management. To (b)(7)(C anyone above the position of Superintendent knows what is going on at WBN. (b)(7)(C) sj~d)(t~~ w oblem is not limited to Operations. He says it has infected to all groups. Accor mg o b 7 C !rb1mrc1 I and

!!bl(l)(C\ I surround themselves with "Yes Men" and "Yes Women". The facts are unim ortant I

to them. The agents asked for an example of a "Yes Women". !(b)(7)(C) said (b)(7)(C) was a "Yes Women". He stated that mana ement likes these people because they will not challenge them or bother them with facts. (b)(7)(C) said that !1b1mrc1 ] veto comment has made its way to the Control Room . The license holders know what he said (Exhibit T-12).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 31 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview on....(b_lrl_)(_C)_ _ _ _, Shift Manager

!(bl(7l(C) I SM at WBN, was interviewed by TVA OIG on February 10, 2016, wherein he provided the following information in substance.

!(b)(?)(C) !started with TVA in !(b)(7)(Cl l He started in Operations and became a SRO in l(b)(7)(C) I* He became a Shift Manager in ~(b)(7l(C) I !rb}/7}fC} I said that there are times when things do not get logged. He said that nobody gets punished for not updating the logs. He added that if you do not update the logs or record things correctly you open yourself up to negative feedback. The b7 c about the !rbl(7)(Cl I removal from watch matteL !rb}/7l(C} Isaid that (b)(?)(C) was working oversight in the Control Room ilb\U}(Ql I was the Shift Manager. (b)(7)(C) as workin~ too ilb)U)fCI I and

!rb1mrci Iobserved the alarm go off. The crew sta 1Ize t e plant. lrt{rrnc} Icontacted

!rbl(7)(Cl Iand told him what happened. !fbl(7l/Cl Ialso advised the rest of the duty team.

!lbl(?)/Cl I told !lblmrc} I what all happened and who all was involved. !rb}(?)(Cl I:cisked if thin%s were stable. ifbl(7)(Cl Itold him that they were. !fblf7l(Cl Ialso thinks that he called f b)(7)(C) l

!(bl(?_C) I but he is not 100 percent sure. He did a duty call too. ilb\(7)/Cl I said that a duty call is a standard thin to do. He thou ht that the followin eo le were on the duty call:

(b}(7)(C) FNU LNU (Duty Engineer),

FNU LNU CC (Exhibit T-34a).

On this call. !lblf7lfCl I informed all what happened and what they did in response to what happened. l1b1m1c1 I said that they talked about individuals in the Control Room, but only in terms of discussing what happened. There was no talk of ~unishment, anyone getting1removed from watch or anything like that. The call was to inform. !rb 171/Cl I said that someone, he thinks an engineer, downloaded information from the shift so that they all could see exactly what happened. !(b){7)(C) I said that this information was given to various rreople that night. After that, the shift ended , and everyone went home. The next da~, !rbl(7}/C I came back to work as normal. Sometime during the shift, !(bl(l)/Cl Ir.ontacted !tb 7)/Cl Iand told !lb)(l)(Cl Ito remove !fbl(7lrCl I from his duties. !(bl(7)(Cl I told !rblr7l(Cl I that ilblf?l/Cl I made the call to do it after !rbl/7l(Cl I reviewed the data that had been downloaded. !iblf7)/C\ I said that lrb\U}(Ql I did not act fast enough. To !(b)(7)(Cl I bein~ removed from your duties means that you cannot operate any ~ anels on Unit 1 or Unit 2 . !rb mrcl I said that until !rblr7}(Cl I was placed back on watch ; !U?lfC\ I could not do his duties. !lb}l?)(Cl I said that he did not have a mroblem with ilb\(7}/Q} I being removed from watch if it was only going to be for a couple of days.

I b)/7l(C) I said that actually disreualifr ng !rb)(l)(Cl I would have been an overreaction. !(b)(7)(C) I asked !rbll?)(Cl I about !lb}(?) l remediation . !rb}/7l/Cl I said it was to be determined (Exhibit T-34a).

!/blmfCl Iasked if lrbrnrc1 Iwas ftoin~ to be removed from watch. llblmrc1 Isaid to l1filillILI "nothing at this time" . b)(Z) 1 I also asked the same question to lw1rc1 I about

~ He was told basically the same tr~~Br&~ott ing at this time). !(b)(7}(Cl ! then went to

!rb}W!Cl I and notified him of the decision. 7 was there and asked !(b}WrCl I if i/blU)(C} I was beinri removed from watch, !fb}(7)(Cl I said, "Not to my knowledge". !rb}U)(Cl I also told

!rb}/7lfCl that nothing had happened to !rblr7l/C} I either. The days rolled along , and lrbl(?)!C}

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 32 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION had not been remediated. l/b)/7}/C) Iasked l/b)(7)/C) Iwhat needed to be done to get llb)/7}/C) I remediated. l/b}/7l(C) Idid not have an answer. l/b}(7)/C) I would ask l/b}/7)/C) Iand l/b)/7}/Cl I would ask l!b){7)(C} I !lb}(?)(C) I recalled one time when he asked !lb}/7\(C} Iabout llb}{7}1C} I

!/bl(7}/Cl Isaid something about 3 days off. l/b\(7)/Cl Itold l/bl/7HCl I that !lbl(7)/Cl Idisagreed with 3 days off. !/b)(l)/Cl Irelied back to ilbl/7l(Cl I that l/b\(7)/Cl Ifigured l/bl(l)/C) Iwould disagree. !lb}ll)IC} I told the .agents that he believes if someone is negligent or overtl~ makes an error, then he is fine with discipline. !fbl(7l/Cl I did not think this was the case with llbl})(Cl I

!(bl(7}/Cl I hracticed before the incident happened. The situation with lfbl(7}/Cl I kept dragging along. !lb}/ 1c1 I kept asking l/b}(7)fQl Iwhen he could get lrbJl7l/Ql I back. He never got a definitive answer from !/blf7l/C) I A few weeks after the incident, lfbl[7l/Cl Igot an email for the Operations Secretary that said llbl/71/Ql I and (b)(7)(C) would be moved to !(b)(7)(Cl ltor their remediation . This was the first he heard of ................~ needing to be remediated (Exhibit T-34a).

IIiillZi((J replied back with an email to !(bl(7}/Cl I and the Operations Secretary asking when IIiillZi((J was going to get them both back. l/blCZ}fC} Irecalled that lfblr71rc1 I replied back that they were going to be remediated that week and be back on Friday. l/bl{l)/Cl Itold the agents that the remediation never happened. The two men ended up having to talk with !(b)(7)(C) I but there was no real remediation. !(b)(7)(C)  ! who had been off work the last few darer asked either !/b)(l)(Cl l or one of the other Shift Manamers when he came back why i(b)/7) l l needed to be remediated. He was then told that b}(7)1C} I had been taken off watch. !lb){l)[Ql I told the agents that it is very unusual for someone to get removed from watch for an event that took place many weeks earlier. !lblCZ}fQ} I stated there was no reason to disqualify !rblm/Cl I and "I cannot think of a good reason why they would do it unless they had a problem, but I do not know wh( . Accordinfu to !(b)(7)(C) I the evolution that day was briefed pro erl . In addition,

!lbl(l)/C} _stated that L l/7l(C} I instructions that day were clear and he (b)(l)(C) knows because "I was standing right there and heard him". l/bl/7HCl I is one of the to~ r ur and is leaned on heavily in Operations. While there have been some problems, lfbl/7\S stated "if you are on the field all the time then you'll be there when the fumble happens" (Exhibit T-34a).

l/bll7l/Cl I said that his coworkers told l/b)(7l/Cl I a story about something that !{b\17l/Cl I said to a group at an off-site last year. It was an off-site meeting leading up to the last Unit 1 re-fueling

~ !fbl/71/Cl I thinks it was in August 2015. There were a few SRO's at this meeting.

lailiZfil.J told the r ou~ that at the upcoming outage the SRO's were no Ion er oing to have their veto cards. ]blm ¢1 I told the agents that Dennis REDINGER or (b)(7)(C) heard the comment. !/bl(l)/Cl Iexplained to the agents that what llbl(7)/Cl I was saying was that at the upcoming outage the SRO's were not going to be able to slow or stop work. The SROs felt that they were going to be pushed to do things that they would not have done in the past and would not be able to say no that they were not ready for an evolution. l/bl(7)/Cl I stated that he told his SROs that it was not going to happen on his crew. lrb1mrc1 I said that his coworkers could be uncomfortable standing up to manafement. He has no problem doing it though but feels that a lot of people are intimidated. !rbl/7}/C 7 said that management applies so much more pressure on Unit 2 items and Unit 1 outages. To give the agents an example of management pressure in the Control Room, !rbll7l/Cl I told of an incident that happened after the re-fueling outage when they had work that had to be done on equipment that was located in containment. The

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 33 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION personnel felt like the Work Orders had not been reviewed. The work could not be done until we reviewed the Work Orders (Exhibit T-34a).

!lbl(l)(Cl I told !/b}(7)(C) I that they (Control Room) were going to review the Work Orders before doing the work. !(b)/7\(Cl I wanted !(bl(l)(C\ Ito "keep moving". They were not going to keep moving until the Work Orders were reviewed. It was done for plant safety. !rb)(7)1Ql I gave the Work Orders to b c She is a licensed SRO. She was workin in the Control Room at the time. b 7 c

!(b)(7)(C) I p~la_..c....e"-:

d~ - - -o-u"."'t "o - f:-:t"."'he

"_ w_a_y-=-in--:-:-

th-e-:c=-o- n""'tr

.'-o-:-

1-=R-o-o m

- , -s o~ sh~e_ c_o_u-=-ld-:--:

d-o -:-:

th_e_ _,

Work Order review. !(bl(7\(C) I kept calling the Control Room asking if she was done yet.

!(b)(?)(Cl I wanted to know how much longer (Exhibit T-34a).

Finally, !(bl(7\/Cl I came into the MCR and sat in a chair. !/b)(?)(C\ Iknew exactly what he was doing. He was pressuring !(b)U)IC} I to finish the Work Order review. !(blUl(Cl Imade sure that he moved his position so that he was between !(bl(7)/CJ I ,md lrb\(7}/CJ I !(b)(7)/Cl Itold the agents that management pressure has completely stopped since the agents showed up on site.

According to !(b)(7)(C) I management now gives them all the time they need. !rb)(7)/Cl I relayed another incident to the agents that happened last fall on Unit 2. It had to do with a certain procedure (RVLIS Calibration) and comments made by !(b\{7)/Cl I This procedure tells the site what the level is inside the reactor. If the procedure was followed from page 1 until the end, then it would have taken a week to complete the procedu re. The procedure had to be done at a certain time/sequence because the plant conditions had to be a certain way in order to do the procedure. The site just could not do the procedure anytime they wanted to do it (Exhibit T-34a).

There was a point when a conference call s eld to d's uss t e rocedure. (b)(?)(C) ecalled that following peo ~,....;,..._.,.......,....,., call: _(b_)(?_)(_C_ ) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ and FNU LNU (OCC). ,__,......--,-,_..,.~found that there were some Unit 2 data points that were outside of the ranges Iste In t e procedure. There would have to have been several Work Orders done on it. We discussed that fact that if we had to redo the entire procedure/test it would take a week. During the phone call, !(b}(7\(Cl I made a statement about the site needing to take a look at the procedure to make sure that the data was really required by the site's licensing docs. He then said that the site did not have to meet the procedure as written as long 1,~(

as the site can justif it. (b)(7)(C) exi:>ressed to ......,""'"""'.......w.u.~e !lb}!?}{CJ Dwas bothere l~t lb) ................__, comments. l1fi1m1c) I told (b)(7)(C) that they were not going to do what b 7 c said. While !(bl(l)/CJ I does not feel that b 7 c was saying flat out not to do a procedure, that is what !lb\(7)/C\ I believes !(b)(7)(C) I heard. Rather, !!bl<?XQl Isaid Hbl{7)/C\ I was saying if we can find a way not to do this, then let's do it. !(b}(?}(QJ I does believe it was perceived pressure to the people in on the phone call and the fact that he (b)(?)(C) can still remember this one telephone call out of all the calls he receives says a lot about it. w u . i . ~ ~

told the agents that management is looking for the fastest way to do something. There is constant pressure. !(b\(l)(Ci I was asked about pressure and health challenges. !(b\(7\!C\ I said that healthy challenges are supposed to be professional, with no screaming or name calling. He said they are just healthy exchanges (Exhibit T-34a).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY QI INVESTIGATION INFORMATION 34 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb}/7}/C\ I said there is a lot of mistrust of management on the site as far as Operations. Many in Operations are intimidated. He added that some people will challenge, but mostffieople do not think the* will be heard. The agents asked why people would be intimidated. i!b) re} I replied that the 1Jil(7\/Cl I incident is just one example. The agents asked !(b\(7)/C\ I about the Overtime Form having to do with SRO's that recently went into effect. !lb}/7}/C} Icommented that that was a !!b)(Z)/C) I screw job. i/b)(Z)(Q) I was interviewed by Employee Concerns but stated it was not as detailed an interview as this one. Rather, he stated the interviewer had a scripted list of questions. He alloweci !(b\(7}!C\ I to elaborate if he needed to, but the interviewer did not ask a

~ ecific questions l!b}U)(C) I recalls he was asked to rate the managers. He gave ll.lillruQlJ a 2 out of 5 anci !lb\17\[Cl I a 3 out of 5. !(blr7\[Cl Ireviewed a copy of a letter re~arding the N/A of procedures. lrb}r7\/C\ I stated that he got the letter in an email from libl)!Q) I last week. He is not aware of who wrote it. He stated the first statement in the letter about Ops developin~ a willingness to deviate from procedure to get stuff done is an incorrect statement. i(b\/7}/C} stated he will not sign the letter based on the first two paragraphs and the other Shift Manarrers are in agreement. He feels if he signed it then he would be agreeing to what it said. !lblr7 Cl Ifeels it is a self-serving letter to take the pressure off management and reinforce the perception that it is all the crews' fault (Exhibit T-34a).

Interview ofl{b)(7)(C)

!(b)(7)(C)  ! at WBN, was interviewed by TVA OIG on June 14, 2016, wherein he provided the following information in substances.

(b)(7)(C)

(b...,

)(7...,

)(C__)_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _l(Exhibit T-35).

At Waterford, !(b}/7}/Cl I was !(bl[7l(Cl I peer at somelffi~~7rt a d at other times !(blf7}/C} I was his boss. The two men went to SRO class together. 1 c1 did not finish the class, so he had to

~ to the next class to finish. He and !(blr7\(C} I both got their SRO licenses. !rb}(?)(C\ I and lailiZfil.J ended up both working in the Main Control Room (MCR), but on different shifts. At that point in their careers at Waterford, the two did not w each other. b 7 C evenJ~~~Wc~ r t on to become (b)(?)(C)

. er an4/~r~w T1 Then b 7 C became into the (b)(7)(C) became the (b)(?)(C) Their rela ions 1p soure a a manager meeting at Waterford. T here was an issue or problem that

!(b)/7\(Cl !

meeting.

ar:ir~k~er to blame on !(b)(?)(Cl ! department. !(b\(7\(C) ! verbalized this to those at the did not stand for it because lrb)/7)/C) I was wrong. lrb)/7}/C) I was trying to deflect blame off him. lrblf7}(C} I chewed out !lb}f?}!C} I in front l~f}gl~~r) one at the meeting. After that, !/b\(7}/C} I stopped talking to !ib}r7\/C\ I !(b}(7)(C} I said that b c is the ty e of erson to

~ rudge and that is what !lbl(7)1C\ I did !lb}[Z)ICl I eventually became the (b)(7)(C) lli2lLZ..l(QLJ advised that he realized that !rb\(7l(Cl I promotion would not be good':'-f-:-"o--r ,.b..7"!'"'!"'

C __s... o he seeked employment elsewhere. Shortly after !(b)(7)(C) I

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 35 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION r r11c1 (b..._

)(7.....

)(c....) _ _ _ _ __,Kcxhibit T-35).

ilb\/7\/C} I said that by all accounts !(b\{l)(C\ I ran Operations. ilb\(7)/C\ I did not have any commercial nuclear experience. !{bl(Z}/Q\ I never had a license and the WBN licensed guys all knew this, so they came to !rb\(7\[C} I instead of !rb1mrc1 I with their operational questions I

and issues. According to !(b)(?)(C) the MCR guys all knew !rb\{7}[Cl I dipl.J,,,L...........,..,,,'-""I.L.l'-,

commercial nuclear experience. lr61mrc1 I vividly remembers the day that (b)(?)(C) told him that thj tl~~re !getting a new b 7 c and the guy's name was =~......... n that same day, b 7 c1 was talking with (b)(?)(C) and !rb\{7l{Cl I about the new guy

~ ilb\(7)/Ql I said that he told all three of them that in 2 years lrWD<Ql I will ruin this plant.

l!!iliZlli1.J told them all to mark his word. ilb\(7\/C} I told them how bad !(b\(7\(C\ I was as a manager.

!rb=}(1=1rc=1-.I told the three men that thP. !(b\!7l(Cl I hire would be a very bad thing for TVA (Exhibit T-35).

After !(bl(l)(Cl I ~rrived, !tbl(7}(Q) I did ......,........,.......,.,....,rformance evaluation. !(b)(7)(C) ! like always,

~ ry good evaluation. !lbl/7\/Q\ I told (b)(l)(C) that his evaluation put him as a top performer.

l!!iliZlli1.J said that TVA wa\ d positions like his position. b1

~~ffi rj organization then. WBN did away with all the "Assistant" was moved to Engineering. He received the same pay, but now his new pay scale was limited more than his old a scale in his former position.

!(b\(7\/Cl I wanted to go to (b)(?)(C) He made this fact known to his supervisors to include b c c knew that he was not qoing to get to go to that job even though he was very qualified for the job. He said that !{bll7)/Q\ was not going to let ilbl(7}/Cl I get something that !lbl(7l(Cl I wanted. b 7 c let !tbl/7)(Cl I know that !lb\(7)/Cl I was working behind the scenes to get the (b)(?)(C) 'ob for !lb)(7)(C) I The mosition was vacant at the time. Only one person needed to approv:,c..1au.c..u.w=..c:1.1.1.U-1.1, at was !lb\(7)_C} I !(b}(7l(Cl I would not approve the move. !(b\(7)/Cl I said the (b)(?)(C) was a direct report to !rb\/7}/Cl I ilbl(l)rC} I did not get the job. i/blf7lrCl I was told that b c made the decision (Exhibit T-35).

!lbl(l)(Cl I then said that under l(b)(7)(Cl !lbl(7)(Cl I I changed. !(b)(7l/Cl I knew that in order for him to survive !lb1(7)/Ql I that kbl(7)1Ql I had to do what he was told !lb}UI/Ql I told !(b)(?)(C) khat

!rbl/7){C} I "went to the dark side". irbH?l/Cl I said that after the Chilled Work Environment Letter

~CWEL) was issued, !(b1(7)/Cl I came to !lb\(7\/Cl I and said to~\b),)(C) ! "you were ri~ ht about I bl/7)/Cl I !(b\(7\/Cl I said that !(b)(Z}(C) I was referring to !(b\(7)( r ediction that !(bU/C) I would ruin WBN in 2 years. ilb\(7)/Cl I said that !(b\(7)/Cl I is smarter than !(bl(J(C\ I !rb\(7)/Cl I said that ilbl/7l[C\ I is a squirmy guy much like an eel and is hard to pin down. ilb}(7}(Cl I discussed that he was at the off-site meetir~/ ~: ~hj counttc; club just before the Fall 2015 re-fueling outage.

ilb}/71/C} I recalls hearin] b 7 c or !lb}/Ll I or both of them talk about how the o erators no longer had their veto. _b1mrc1 I said all of those in attendance knew exactly what !rb){ re\ 1 I and !(b)(l)(C) !meant when they said that (Exhibit T-35).

!lbl(?)(Cl I went on further to say that !(b\(J)(C\ I is a smart guy, but i[b\(7l(C} I does not know the plant. !(b){7\(Cl I said that !(b\!7HC) I is not good technically. !(b\(7l[Cl I is a lot like b 7 c I

according to i{bl(7\(C\ I !(b)(7)(C) according to !(b)(7)(C) is more technical than b 7 c I and

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 36 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 01 INVESTIGATION INFORMATION ilb)/7)/C\ I llb\17}/C\ Isays that !lb}(?}/C\ !just makes bad technical decisions. ifb\(?}(C} Isaid that llbl(l)/Cl I is a hard worker who does what he is told to do. !lblf7}(C\ I said that it ended up being the perfect storm when !(b)(7)(C) ilb}/7)/C)I I and irb)(7)/C) I all three were together and managing people and trying to run the plant. !lbl/7\fC} I is very familiar with the forced outage in the late fall of 2015. He was one of the guys that tried to find the leak after the rod dropped. He added that they did not want to initially shut down. The rod could no!(~~ lR~llr up. So, they shut down to recover the rod and find/fix the leak. ilb\f7l/C\ I said that b 7 c is doing nothing but laughing at the NRC's CWEL. According to !(b)(7)(Cl !is making so much money at TVA the CWEL is nothing to him. As a matter of fact, to him it was just the cost of doing business (Exhibit T-35).

Interviews of!(b)(7)(C) !Senior Reactor Operator

!(b)(7)(C) I SRO at WBN, was interviewed on February 10, 2016, and September 29, 2016, by 01, TVA OIG, and AUSA !(b)(7)(C) IUS Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

On October 19, 2015, ilbl(?}(C\ I was working as the WBN 1 (b)(l)(C) He recalled that they had a pretty heavy schedule. The:t had a number of tests to o. ne of the tests called for that day was the Terry Turbine Test. !!him1c1 I explained that conducting the test that day was challenging. The reason it was challenging had to do with the ptant conditions that day.

The Terry Test was going to put a big load on the plant that day. !rbf(7)/Cl I said that the last time they did this particular test one of his coworkers had issues with the test. It did not qo perfect. The person responsible for the test when it went bad was !(b)(7)(C) J ended up getting disqualified over the incident. !lb}f7l/C\ I kne._w_t-ha_t_t-h e- si,...te-,-ha_d_,_no_t_ ....

performed this test well the last time they tried it. So, this time. i!b}m1c1 I talked to l(b)(7)(C) to get some insight (Exhibit T-13a).

ilb)(7)/C) I obtained what he called trigger values. They were going to give him a guide, so he would knq.~ o sto~ the test. This would help prevent making a mistake like what happened to ~ !lbJIN Cl I said that the Shift Manager, !(b)(7)(C) l wanted the crew to also do another task that same shift. The task had to do with the reactor trip breakers.

The goal of that particular job was to make sure all the rods moved. So, in !/b\(7}/Cl I mind, there were two important jobs that were on the plate that day for the shift to do. The surveillance crew came into the Control Room and got with i!b)l?)IQ} I :=md his coworkers in the Control Room so that they could set up the conditions needed to run the Terry Turbine test.

!lbll7}fCl I testified that his focus was on the Terry Turbine Test because everyone was there for this test. As they were starting the Terry Turbine Test, ilb){7l/Q) I r.ame up to

!lb}/7\fCl I and asked when they were going to begin the job with the reactor trip breakers.

!rbl!7l/C) I told i(b)/?)fC} I that he was only focusing on the Terry Turbine Test. He did not want to take his focus off of that and onto the reactor trip breakers (Exhibit T-13a).

Throughout the Terry Turbine Test, lrb1mrc1 I kept asking !lb}f7}fCl I why he had not started the reactor trip breakers job. He asked around three or four times and !/b\f7[C, I kept giving the same response. !ib\17}/C\ I did not want to mess with the reactor trip breakers

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY QI INVESTIGATION INFORMATION 37 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION job because doin[ so would add two forms of reactivity to the core. He told the agents that this was a "No- No". bl(?)(Cl I stated that basically there were two reasons he would not do it:

(1) his entire focus was on the challenging Terry Turbine test and the second test woulld take too much of his focus away and (2) adding two forms of reactivity to the reactor was not

~e rmitted to do at that power level. When asked during this interview wh[c !lb)(7}/C) Ikept pushing b\17}/C) I on the reactor trip breakers, ilb)(?)IC) I said that, !lb)/71 ) Idoes not have a lot of experience. Couple that with the pressure from the OCC and this is what happens.

!lb\17)/C) !just did not have what was needed to stop the OCC pressure." !lbl(7l/Cl I reported that, "OCC now is directing the shift managers and they are telling them what to do" (Exhibit T-13a).

!lb)U)/Q} I said that the problem with management and the OCC directing the actions in the control room is that the ones doing the directing are not licensed. Some may have had an active license at some point, but the skill set needed in the control room now versus a few years ago is different. As far as working in the control room, l(bl(l)(C) I said skills atrophy if not used. The ones pushing now just do not have the skill set to do the pushing. lrbl{l)(C) I stated that they will say stuff like "but when I was an operator we would do six things at a time."

!lb)l?}IQ\ I stated that things have changed (Exhibit T-13a).

!rb}{l)(Cl I said that now at WBN the OCC and management's main thrust is to push their agenda. Their agenda is the schedule. Shift managers now just carry the message to their people in the control room. !lbl{7lrCl I told the agents that he and his crews successfully conducted the Terry Turbine Test. However, lrbl(?)fC} I did not do what !lb\(7}/C) Iwanted him to do reactor trip breakers . When the shift ended. !lb)(?)IC) I asked to meet with b7c in private. (b)(7)(C) old !lbl(7)(Cl I that !/b)(7}/Cl Iwas being relieved of his unit supervisor duties. told lrb)/7\/C} I that !(b}(7}/C) I "was just not pushing hard enough." !rbl{?)(Cl I told the a ents that !rbl{?)(Cl Iwas somewhat relieved when b7c

• b7c was just too tired of being in that seat. lib)r7l/C) I (b)(7)(C) He said that throughout his career both at TVA and !(b)(7)(C)  !.

he has made a great deal of decisions based off his gut feeling. He stated that sometimes there may not be a technical basis for not doin something but just a gut feeling that something shouldn't be done. Accordin to b c his ut feelin has worked well. He added that a gut feeling worked (b)(7)(C) He stated that TVA is concerned about a profit. stated that the profit motive is what is disappointin~ to him about TVA nuclear. !lb)U)IC) I told the agents that the shift that followed !(bl/LlCl I shift went ahead and did the reactor trip breakers job and moved the rods. It ended up being a big problem. They did the action without two protections in place I

because two of the w otective circuits were in bypass.,(b)(7)(C) was the shift manager. It was a huge mistake. !lb}(7l Cl I stated that he was not happy that it happened by any means, but he did feel vindicated that he had insisted on focusing on just one of the tests (Exhibit T-13a).

l(bl(?l/Cl I said that what happened with the bypassed circuits was in the control room toward the end of the outage the instrument maintenance (MIG) guys did all of their work. They should have been doing it well before the last week of the outar . A lot of tags were covering the instrument panels in the control room . This contributed to l l/7\/Cl I c:rew not seeing the

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 38 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION lights on letting them know that two safety circuits were out of service. !lb}/7\/C\ I told the agents that the issue with !(b)(7)(C) fhas contributed greatly to the atmosphere in o: erations. !lb)(?}/C} I said to the agents that the site all saw what happened to .... l(b-}/7-)/-C}--I

!(@7)(C) I who described !lbl/7\(C\ I as one of the smartest guys, said "you send him home because he has the guts to say now is not the time to do it." Operations got the message (Exhibit T-13a).

!rb)/7}/C} I said that the site is too Mode driven now. !lb}(7}/C\ I thinks that the managers must have money directly deposited into their bank accounts each time they change Modes. !lb\17}/C\ I said that the current leadership st~le at WBN has created an atmosphere where nobody can tell their boss the truth. !lb]71/C\ I thinks that one thing TVA can do to fix the problem at WBN is to hire one guy whose only job is to tell management the truth. !lb\17}/Cl I said that after !lbl/7\/C\ Igot removed from watch !lb\(7)/C\ I told

!lb}/7\(C} Ithat the !lb\/7}/C\ Ithing sent the wrong llublic relations message to the troops.

!lb\(7)/C} I agreed. !/b)l7)/C} I does not think I b}/7\(C} I style of leadership works at WBN. !lb\(7\/C\ I is a bully. He tries to use his physical size and loud voice to get what he wants (Exhibit T-13a).

!(bl/7\(C} I said to the agents that he has had a lot of unpleasant supervisors during his long career. l\b)(7)(Cl I is the only supervisor he has ever that he would describe as "abusive."

!lb)/7}/C) I said that standing up to !lb\(7)/Q} I comes at a cost. !rb}/7)/Ql I stated that he is not having fun now and neither are his coworkers. He stated, "a couple of years ago we had some guys who were all fired up and now they are ju:st trying to withstand the beatings."

!lb}(?)/C} I said that they have made some mistakes in the control room. He said that it does not matter how bad a boss !lb\(7\/C\ I is or anyone else is. The mistakes that have been made in the control room are just screw ups. !{bl/7\/C} I hopes that TVA management will be more realistic in the future with the schedule. One simple way to cut down on the mistakes is to let the smart people have the right amount of time to think (Exhibit T-13a ).

!(b\(7)/C)  ! stated that !(b)(?)(C)  ! is damaged goods and believes that manar ement had a lot on him. He believes this was part of the issue on November 11, 2015. !lb}(7)/C _ I recalls feeling bad for the crew whe n he came in on November 11 , 2015 because they looked shell shocked. !lbH7\IC} I is not aware of whethed (b)(7)(C) !was in the OCC. He stated 7 et the Shift Managers do their job. According to Hb)g)(C) I (b)(7)(C) but has never been on a plant like WBN. !lb}mrc} I hrought up t e 1ncI ent invo vin b 7 c ho was taken off watch several weeks after a tri breaker incident. s1/,ecifically recalls telling (b)(?)(C) that you cannot punish b 7 c

!/b)/7}/C) I weeks later. !/b){)/C) I stated that ...................... is a bully. According to b 7 c the way it works is if management cannot get something done then they j ust wait for another shift. It is shopping for SROs. !lb}m/Cl I ex~lained that safety of the plant is his

!(b)(?)(C) I overriding concern. !/b}(?)(C} stated, "I go to work with a pit in stomach about what are those guys going to ask me to do" (Exhibit T-13b).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 39 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview ofl(b)(?)(C) lshift Manager

!(b)(7)(C) l SM at WBN , was interviewed by TVA OIG on February 17, 2016, wherein he provided the following information substance.

(b)(7)(C) (b)(7) lib\17}/Q) I has worked at Wl,,IILl.~i:.u.....u.i,~ rs and was earned his operator license in (C) He became a Shift Mana er (b)(7)(C) ears a o. llb\17j/Q) I reviousl worked as an b c t (b)(7)(C) advised that (b)(7)(C) was wo ~~,nffi ~sl the (b)(7)(C) during the most recent re-ue mg ou a e in a 2015. 1b 7 c was his Shift Manager. b c stated that his crew (including (b)(7)(C) did very well at the beginning of the outage. He stated that shutting a

~lant down is scripted and the entire crew prepped and implemented the shutdown well. In fact, bl/7}/Cl I crew set a record for shutting it down. !rblt7l(Cl Istated that the main control room staff was recognized with blue chips and position recognition. lib)(7)/Q) Istated that ltbl/7}/Cl I did excellent (Exhibit T-14 ).

After the midpoint of the outage, there is no longer a script because of the emergent issues coming up. He stated that it is not as easy coming out of an outage as they start to restore systems. At this point, ltb)(7l(Cl I stated that we started having issues where there were multiple priorities (between 4-8) per shift. lib\(7)/Q\ I advised that it was hard to schedule maintenance with the emergent issues coming. While the Shift Manager is responsible for all everything in the plant and making sure that everything is done safely, his primary focus is on the safety of the people. In contrast, the Unit Supervisor's main responsibility to making sure the plant equipment is safe (Exhibit T-14).

lrb)mlQ\ I stated that there can be a planned schedule, but things change. These emergent issues can push the schedule out or hold things up. As the outage was about halfway through, l(bl(7)(C) Isat down with l(bl(l)/Cl I in the office next to the main control room and asked how he !(b)(?)(C) Iwas doing. lib)U)/Q} Ihad seen !/b}[Zl/C) I appear frustrated with keepin up with the number of scheduled activities as well as thin snot on the schedule. !rblt7)(Cl 1 told !(b)/7}/Cl Ithat he was tired, and ltb)[?l/C) Iasked if he (b)(?)(C) wanted to be relieved.

l!b\(7)/Q\ I said he was good, so lib\(7)/Q} !left it open with him. _ __. stated that he told l(bl(7)/Cl I to let him know if he needed someone to cover for him for a day or two. lrb}{7)(Q) stated that part of his job is behavior observation, but ltbl[7l(Cl I was fine. l(bl/7l(Cl Istated that this conversation happened about three weeks into the outage (Exhibit T-14).

About a week later, there had been a few incidents where Operations was not ready to do an evolution on the schedule when it came time for it to be done. There had been a few incidents where critical path activities were scheduled and the crew (not ((b\(7)/Cl I in particular) was not ready. l!b}/7\/C\ I recalls that there was an incident where they were supposed to start a I

reactor coolant pump (RCP).. According to !(b)(7)(C) the operators should be looking to see if everything was ready to do the action and not holding up the evolution. However, in this incident the operators had not yet walked down the pump even though they knew about it at the beginning of the day, so Operations held up critical path in the outage for 6 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. lib\(7)/C) I stated that the OCC was definitely upset because it should not have happened. ltbl(7)/Cl I stated

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 40 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION that it was "not~ specifically but the main control room staff' who held things up. However,

(/bl(l)(Cl Iasked (/bl(7}/Cl I about it and why it happened when they knew the evolution was cominp- llb\(7)/C\ I told l/b\(7)/C\ Ithat the had several other things goinn on. llb\/7)/C} Itold l/b)(l)/C I to let him know so he (b)(?)(C) could move people around. b\(7)/Q\ I told him that if he !(b)(7)(C) Idid not understand the priorities then to let him know. l/b)/7\IC\ Itold him that they could arrange the personnel to work the right priorities but not put off priorities while waiting on the right personnel (Exhibit T-14).

lrb}/7\!Q\ I stated that there were a couple of other instances where they were not ready and he

!(b)(?)(C) Iwould talk to llb)(l)IC) I llbl/7\lCl Iwould tell him that they needed to do a different priority because stuff changes. l/b\(7)/Q\ Iadmitted that there could have been communication issu,~~f ~~Sa!ding which was the actual priority. Operations knew the rod testing was coming up, but b 7 c stated that they were not ready. Specifically, there had been no briefing and no set up of the conditions for the rod testing. Likewise, the support items to do rod testing were not ready ~ At the end of shift when they were relieved, things were still not aligned for the test.

llb\(?)(D] pulled ((b}l7)/Cl I to the side and talked with him again. He told (/b}(7}1Cl I that he seemed tired , frustrated, and overwhelmed. He told llb}(7}(C\ I that he would no longer be sitting desk as the Unit Su ervisor. llb\!7\/C\ I stated that he was replaced with another SRO,

((b)(7)(C) U ut that he (b)(7)(C) would stay in the control room. llb){7)!C\ I stated that H6j(!j(cj :J was non- confrontational when told of the change (Exhibit T-14 ).

Before he made the change with !(b)(7)(C) I (/bl/7}/Cl I told (/b\(7)/Cl Ithat he thought

!rb}01Ql I was tired and having a hard time juggling all the balls in the air. He also recalls telling llb\(7)/G} Ithat llb\(7)/Q\ I seemed overwhelmed with the number of things they had to keep track of and that he (b)(?)(C) wanted to move !(b)(7)(C) j into Hbl!7l1C\ I position.

According to !(blm(C) I c stated to do what he needed do but that they needed to

~ )( k ':br (C) I in the control room though because he (b)(?)(C) was valuable.

only talked with llbll7l(C1 Iabout moving b 7 c (Exhibit T-14).

llb\(7}/Q} Irloes not feel that ilb}(?l/Cl I was lazy but was overwhelmed. !lb)(7)/Cl I would sometimes be looking at the second or third priorities and not realize what should come first.

When asked if it was his job as Shift Manager to make sure that the Unit Supervisor was working on the rtght priority_ llb\17}/Q} I stated that it was, and he tried to redirect him . ... , b. .,)a,. . .)1C""")....,

stated that l/b\(7}/Cl I would tell !(bl/71/Cl Ithat they were doing thin s to et ready and llb}(?)IQ) I would be doing multil/~,:~~~gr5 at once. Accordin to b 7 c llb}(7}/Qi I was not focusing in the ri ht areas. denied that b 7 c disagreed with what the priorities were and he (b)(?)(Cl does not recall !(b}(?l(Ql I challenging his as to what were the correct priorities. , cannot recall what llb}(7}!Q\ I was working on but stated the number one thing that day was the rod testing. Everyone in the OCC and in the management chain was frustrated about the delayed rod testing because it was a critical path activity.

llb}W/C} I stated that llb}(7}/C} I is very conservative. He checks, double checks and triple checks himself. (/bl(?)(Cl I believes (fbl(7}1C[ I seems scared to mess up or do the wrong thing. He described l(bl(7}(Cl I as slow and not moving ahead. He believes ..,.((b..,..}CZ...,lf,...Cl.___ __,

could not handle the number of things coming at him (Exhibit T-14 ).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY QI INVESTIGATION INFORMATION 41 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION According to !(b)(7)(C) I !(bl(7)(C} Iwas good with having a plan and working the plan.

However, when the plan changed, and he had to react to the changes, !(bl(l)(Cl I "was not as good at keeping up with what needed to be done." !{b}W{Ql I stated that sometimes priorities change midshift. After the change, the crew asked b c why he was up there being the main supervisor. !{b}{7)(Q} I stated that he did tell (b)(?)(C) that they swapped because l{b\{7\{C\ I seemed overwhelmed. l(b){7\(C) Istated that there is a documentation srestem for coaching. It is called the Electronic Performance Observation Program (EPOP). !lb){?) l I stated that this is where they put in all the coaching. It is to document any type of observation or coaching. It is used by first line supervisors and above. lrwmrc1 I has to put in at least three observations a month. He stated that this is a management expectation. He does not believe it is very user friendly. He does not recall if he put in anything about !(b}(7}/Q} I lrb)W{Cl I stated that some people get upset about getting "EPOP'ed" (Exhibit T-14)

!{b\{7){C) Ibelieves the entries are electronically timestamped but there is a place to write a narrative. He stated that he sometimes will save up several to write at one time so the date in the narrati! {~)(~~t ~e different than the time stamp. EPOP is searchable by observer name, date, etc. recommended speaking with!(b)(?)(C) Iwho is responsible for EPOP.

l{b}(?}{Ql I stated that the amount of work going on at WBN right now is insane. !(b}{7}/Ql I stated that there are days that it can get overwhelming for him but on the whole, he can keep up. He does believe the SROs are having a hard time (Exhibit T-14).

The Operations personnel are not as experienced. He !(b)(?)(C) Iis either 6th or 7th in seniority of the SROs. The majority of SROs came from the Navy and the sheer number of activities at WBN compared to the Navy is astronomical. !ib){l){Q} I stated that there were a lot of activities on Unit 1 and now they have added in Unit 2. He stated that the number of activities from Unit 2 coming to the schedule is mind blowing. !~l~l\Cl !stated that outages on Unit 1 are planned for 18 months. It is refined, and they know w a o expect. Only when they go in and loolk at the equipment does emergent issues come up. In contrast, Unit 2 is not in an outage but rather is a start-up. The schedule for Unit 2 is at best two weeks out because they cannot really plan when a piece of equipment is turning over. As a result, there are days that the crews come iin and do not know what they are doing in advance (Exhibit T-14).

llb}{7)1Ql Istated that one of the things that he and the other Shift Managers are facing right now (February 2016) is that there are requirements by law (ca lled tech specs) as to how they must operate the plant. He gave the example of having to have both trains of RHR fully operable. If they want to take one out of service, then they can have one train of RHR and 2 Steam Generators (SGs) operable. There are four SGs total but right now there is one out of service and two which have issues with meeting the required narrow range level tech spec requirement for determining water level. This means there is only one SG available, so they do not have the required 2 SGs to go with the one train of RHR to meet the tech specs (Exhibit T-14).

When explained to the OCC, they wanted to know why the operators cannot determine water level with the wide range. While it is possible to determine the water, level using the wide range, l{b}(7}{Ql I stated that it is not acceptable based on the tech specs which say the narrow range levels must be used. !(b}(7)/Cl Iadvised "I get push back and I have to explain why I

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 42 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION cannot do it." He stated this is "the fight my licensees are doing several times a day." When he was working in Nebraska, lrbl(7l(Cl I did not see this much pressure. !(bl(7}(Cl I stated that they constantly must justify why something is not ok. He said it is like they are put on the stand and have to say why we cannot go around it or wh we cannot do it this way. Most of the t ime, is ettin pushback from the (b)(7)(C) but he does not know where he (the (b)(?)(C) is getting is pressure from. Every Shift Manager has complained, and the push back stops for a day or two, but it starts back a day or two later (Exhibit T-14 ).

l!b}/7}/C\ I stated that the operators' licenses are with the N RC and not TVA. His job is the health and safety of the public. However, the SROs and Shiftl/~~}~~gr s are constantly put on the defensive as to why they cannot get something done. stated that the operators are constantly saying it is not worth the risk because of what can break. Operations personnel should be the ones operating the plant. !(bl/7\(Cl Istated that the operators' pushback is slowing production. He stated that p,eople will bring things forward and then ju,~~ffii

~~ p. He stated there was a time when if the Shift Managers said no then that was it. 1 1 thinks it is dangerous because people now have different thresholds. llb)U)IC} I believes there has been a dramatic positive chanJ1iB in both !rbl{l)/Cl I and !rbl[7)/C1 I demeanors in the last couple of months. Before that, lrti 17}/C} I was very demanding, directive and results oriented. Likewise, l/bl(7l/C\ I stated that b 7 c has high standards, is demanding, and holds people accountable.

l/b}(7}/Q} I believes (b)(?)(C} is looking to advance and just does what his bosses want him to do (Exhibit T-14).

l/b\(7}/C\ I recalled an incident where a RCP was started on his shift and everything went well.

l/b}/7\/Q} I stated that they were to start a second RCP, but it was getting close to the end of shift.

It was around 3:30/4:00 p.m. and turnover was due to start at 5:30/6:00 p.m. !rbl/7l(Cl I stated they needed to move the pump. He talked to the crew and asked if they wanted to do the 2nd RCP. There were benefits as well as risks. He stated that one SRO and one RO on the crew were for it and one SRO and one RO was against it, so it was split down the middle. He told the crew that he appreciated the feedback and to ive him 10 minutes to think and make a decision.

He decided to do it and calle (b)(7)(C) left him a voicemail that he intended to start the next RCP. He also called (b)(7)(C) and told him of his !{b)(?)(C) I decision. !(b)(7)(C) I said that he supported =~_, 100 percent. l/b\(7)/C\ I stated the OCC wanted it done but that did not enter into his decision (Exhibit T-14).

llb}(Z}/Q} I then went up and told the crew what he had decided and that he did not think the risk outweighs doing it. He told the operators that if they disagreed then they could document it in the lo s. He then said it was the end of the update and for everyone to get ready. At this point, b 7 Cl a roached him. ilb)(7}!Q} Iwas acting as additional oversight in the control room. b 7 c said that he wisheci l/b\(7l/C} I had talked with him before making the decision to start the second RCP that day. !/b)aJ!Cl I said that he thou ht lrb\(7\/Q} I was making a mistake because by starting the RCP it looked like he (b)(7)(C) com letel disregarded the operators' concerns. !lbl[7)1Cl Itold him that he appreciated his (b)(?)(C) feedback but ther were moving forward. l!b\ffi/C\ I and !lbl(7)/C) Ithen got b C on the phone. !(blU}/Cl .

explained his concerns and said it was the wrong message to send. He said the operators who were strongly against the move would take out of all this that the OCC pushed him !(b)(7)(C) I

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 43 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION and it was done for schedule r essure. ilb\17)/C) i stated that !(b}/7\(C\ Iand !/b)(l)(C\ Iwere gettinfl louder because !lbl(?)/C I was not getting his point across so !lbl[?\/Cl ! left to go talk to ilb\/ IC\ Iin person. !lbl/7}/C} Ithen told his crew that he wanted to know who thought he was pushed into making the decision to move forward and two people raised their hands. He then told the crew to stand down that the were not goin I to start the um . The two people who raised their hands were (b)(?)(C) and (b)(?)(C) (RO). He then talked to them individually. He told w.1.11.1..11..-'.1-.1 that no one had pushed him, and that the decision was made on his own with no coercion. She was apologetic and said that she did not want to be seen as a troublemaker. He told her not to apologize and that is she is supposed to bring up concerns. He had a similar conversation with l1b\/?HC\ I !lbl/7\/C\ Istated he could understand the perception that he was being pushed into moving forward (Exhibit T-14).

Interview ofl(b)(?)(C) !Reactor Operator I

!(b)(7)(Cl RO at WBN, was interviewed by TVA OIG on March 21, 2016, wherein he provided the following information in substance.

(b)

!(b\/7\/C\ I has been employed at WBN for about ~2) years. In 2010, he became licensed.

I According to !(b)(7)(C) in 2012, 14 out of 17 reactor operators went to the NRC about similar issues. The issue that the reactor operators had back then had to do with "when does pushing back become insubordination". There were also safety conscious work environment issues brought to the NRC's attention. The NRC contacted TVA management about the allegations.

TVA management put together a presentation for the NRC in an attempt to mitigate the issue.

llb\(7)/C\ I recalled that he even had a conversation with (b)(?)(C) about the issue. l1b}(?)/Cl I said that there really was no resolution to the issue. b sa1 t at everyone just moved on and the issue was not resolved (Exhibit T-36).

!(b\Ul(C\ Isaid that things at WBN are now worse than they were back then. He said that everything they do in the control room revolves around adherence to the schedule. The direction from the OCC to the control room is out of hand. There are more managers i1n the OCC during an outage than there l~~~ii t lators in the control room. The control room personnel just get overwhelmed. b said that it was not that way until recently. The OCC has not always been staffed with so many people. Years back, there were ~~r~c~Jerators,.,.i.n,,,.,.,..,..--_, .,.

the control room than managers in the OCC. During the re-fueling outage, 71 heard !(b)(?)(C)

(b)(7)(C) and !/b\/?l/Cl I all make the comment that "operations would not be e reason we O no ma e the schedule". !(b)(?)(C\ ! said that such a statement ca, (~/n:reibi taken one way by the licensed operators. Schedule adherence is the top priority. b 7 said the shift managers at WBN are fearful that they will be fired if they do not stay on schedule (Exhibit T-36).

As an example. ilbl/7\/C\ I said that (b)(?)(C) was working as a Unit Supervisor during the re-fueling outage. b 7 c was deemed to be movin too slow, so he was "sent to the minors" by the shift manager. He was replaced by (b)(?)(C) . !lbl/7l/C\ I said that the current management at WBN refuses to admit that this schedulinr r essure exists. !(b}(?\(C\ I said he has gone to Employee Concerns about this issue. !(b\(7)/C said that an operator's

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 44 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION career path is rewarded if you are viewed as someone that will do what the OCC says to do. If you are viewel1b$t~~I OCC .as someone that pushes back, then you are labeled as not being a team player. said that he hears the same things out of the OCC and management. All he hears is "do it because I said do", "this is critical path" and "we are too far behind". !lb}(7}(C} I said the slai7bi r{i~~ l perators have for the OCC and management pushing the Operators is "leg humping". ,)d.ld.~Klol.&..~~~e of leg humping. He said during the last re-fueling outage, management made (b)(7)(C) stand in the Control Room during the big evolutions and give the OCC a secon y secon update as to what specific steps they were on with the evolution (Exhibit T-36).

!lb)(?)(C} Isaid that management has created an environment where it feels like a game of tug-a-rope between management/OCC and the control room. ilbl(?)rc1 I said that such a dynamic is very bad for a nuclear plant. He added that they all should be pulling on the same side of the rope. !rb)/7l(C) Icontinued by sayih~,;~gt lj st October a few operators were disciplined for the Source Range Bypass incident. b 1 said that management did not discipline everyone.

They only disciplined a few people. He said that there is such a staffing problem in the control room that management could not discipline everyone because they could not staff the control room properly then (Exhibit T-36).

!(bl/7\(C} I said that he had been told that management is saying that the issues out at WBN are the result of accountability. !rbJ(?)/Q) I i:,aid that he is personally insulted l r]~~c}h j statement. It has nothing to do with accountability, and everything to do with denial. b c said that out of 70 operators, 5 of them have problems with being held accountable. l(bl(?)(Ql I said he has never heard one manager say to him or anyone else the statement "I was wrong". l(b)UHC) I said that WBN management will never face reality and admit that they messed up. They care more about not admitting fault than they do about fixing the problems (Exhibit T-36).

!lblU)(C} Isaid that all he hears from this management team is that the workers are bad. The common denominator in all of this, according to !(bJ~l(C) I is the mana ement team. i(b\(7)iC) I told l(b)(7)(C) !that he laughed when they replaced fo{irnc1 I with (b)(7)(C) because the site made a video somewhat reoently and there was a segment on the video of b 7 c The

~articular segment had to do with the phrase "this is what good looks like". They used b}(7}(C} ] as the example on the video of what good looks like. ((bl(7}(Cl I said it has gotten so bad that the OCC now "SRO shops". He explained that during outages when the OCC wants to do something the OCC wi ll call the Control Room and "shop around" for an SRO who will agree to do what the OCC wants the operators to do (the action to take). !lbl[7)(C} I said that there are two phones in the control room. One number is 3441 and the other is 3874. !/b1(7l(Cl I said that the OCC will call one phone and tell the SRO who answers the phone what they want to do. If that SRO does not agree, then the OCC will wait a few minutes and call the other phone hoping a different SRO will answer the phone (Exhibit T-36).

!lb)/7)(C1 Isaid that the OCC will also wait until the end of the shift and do the same thing. That way if the OCC gets a "No" on both phones at the end of the shift, the OCC can call back to both phones at the beginning of the next shift and try it all again. !(b)!7}(C} I said that the lines and boundaries that at one time existed between the OCC/Management and the control room have

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 45 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION been erased. There are no boundaries now. !lb}/7}/Cl I said that it is obvious that a safety conscious work environment does not exist at WBN . He said that one cannot exist if management simply does not listen, !(b)U)IC} I said the "coact i~g/~jh" at the site only revolves around negative things. It only involves negative feedback. b 7 c never hears anything positive, only negative. The management team at WBN has created an "us vs. them" environment (Exhibit T-36).

!lb}/7l/C} I said that you have a problem when 70 license holders all say that there is a big problem at WBN having to do with a safety conscious work environment. !!b}m1c1 I said that this

~ ment group will never admit to the truth for it would be the kiss of death for their careers.

~ said that he has known !lb)/7}/C} I for a long time and personally likes llb}ll)IC} I

,b-}17-}/Q_l ...,I ~dded that as far as accountability goes, l(b}(7)/C}

--, I has been a poor performer for at least one year (Exhibit T-36) .

!lbl(l)/C} Isaid that !rb}(?}/C} I best skill is telling people that they suck. !rb}!7)1C} I is also good at telling people how not to suck. Bottom line problem at WBN is that when something happens, management comes up with a story. The story is not accurate. It is not honest. It is a story that they hope satisfies the regulator and does not make them look bad. The problem with doing that is it does not allow you to learn from the mistakes. !lb}(?)IC} I said that he can think of 2 ways to stop TVA from making up their own version of reality. One way is for the NRC to instruct TVA

~ oing business that way. The other way is to remove TVA upper level managers.

~ said that one good thing has happened because of all of this. He said that it has really brought everyone in the control room together (Exhibit T-36).

Interview of !(b)(7)(C) IReactor Operator

!(b)(7)(C) I RO at WBN was interviewed on April 16, 2019, by 01 and TVA OIG wherein he provided the following information in substance.

We [Unit 1 MCR operators] started the standby main feed pump on Unit 1 with the intention to pump forward with it through check valves that are locate,d inside the polar crane wall of the reactor building to satisfy check valve testing that was required prior to start up. The testing required containment entry and would not be possible after reactor start-up. The SBMFP was started and pumped forward [feeding steam generators] with it while the unit was in Mode 3.

While that was going on, preparations in the reactor startup was in progress. While we were pumping forward with the standby main feed pump, the unit did transition from Mode 3, to Mode 2 before reactor start up, I do not believe it was critical yet, but it was transitioned, right there at the edge from Mode 3 to Mode 2. After we entered Mode 2, we shut down the standby main feed pump (Exhibit T-15b, p. 7).

!lbl(7}/C} I identifierl llb)l7HC I and !lbl/7}/Cl Ias providing direction to use the SBMFP for the testing. He discussed his pushing back on the operation on the basis that it was not the most controllable method of feeding the steam generators. In response to lrwmrc) I

@ush back he was challenged to prove the operation could not be procedurally performed.

b}l7}/Cl Iexplained he had a discussion with llbl/7}(Cl Ito pause the startup for the

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 46 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION testing and !rb)f7)(Cl I replied to the effect that that start-up cannot be stooped for the test and OPS will not be the hold up with starting up the unit. !(blf7}(Cl I continued that him and

!{b)/7\{Ql Idiscussed the responsibilities of lfb}U}!Cl I being the Senior License Holder on site and his ability to hold UR any activitr he wants regard ing the operation of the plant.

!(bl(7)(C) Ithen asked !(blmrc) a question to the effect of why do you come to work?

i{b1{7)/C} I responded "To feed mn family" where !tb1(7)!Cl I replied that he did also.

!fb)t7j(Cl I took that to mean !rb)t7jil Idid not feel he had the environment above him to go say they could not perform the testing in parallel and needed to delay the start-up.

(Exhibit T-15b, pp. 11-24).

Interviews of !(b)(7)(C)  ! Senior Reactor Operator I

!(b)(7)(C) SRO at WBN was interviewed on January 16, 2016, and September 19, 2016, by 0 1, TVA OIG, and AUSA!{b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

!{bll7}(C} I has been em lo ed at WBN torl~6/7) lyears and has been an SRO fo (b)(?)(C)

He reports to (b)(7)(C) Shift Manager at WBN. * .';';:;;.:-:-:::--n::-::~ ,-~***~1 room fo (b)(?)(C) on November 11 , 2015, as an (b)(?)(C)

~ o that the other operators could focus on the plant as it was coming out of the maintenance outage. The Unit Supervisor that day was Dennis REDINGER. At one point, REDINGER had to leave for the day so l!bl((\!Q) I relieved him for a couple of hours (Exhibit T-05a).

i{bl{?)!Cl I ;:)dvised that it was a frustrating day for him and the other operators ("us") because they had come out of a re-fueling outage and went into an unplanned maintenance outage.

Things were fixed, and they were projectinffi u~ through the Modes when they ran into some sticking points procedurally. According to b)((/C) I the General Operating Procedures (GO) are infrequently used so you need to be slow and methodical with heating up. In the GO procedures, there are notes, cautions, and warnings placed at various points in the procedures.

Procedurally, there was a caution in the procedure (GO-1) that said do not move forward drawing a bubble in the pressurizer while you are cold and to wait until a certain temperature.

According to !(b)(7)(C) I the operators did not want to heat-up but drawing a bubble is a milestone and a big step to moving forward so the Outage Control Center (OCC) said to do it (Exhibit T-05a).

Hb)/7\{Ql Ithen showed the procedure to (b)(7)(C) Shift Manager. !fb}/7lfQl I agreed with l{b)l7){Q\ I that they should not do it and commurnca e I back to the OCC. The decision was made to revise the procedure, so they could move forward. According to !(b)(7)(C) I this is not a common thing, but the OCC must have felt they found a safe alternative. lfbl/7}/Cl I though did not believe that and told !(b)(7)(C) !that "I just want to communicate to you verbally that I am disagreeing with this procedure" and "I said who with an NRC license is saying this is ok" (Exhibit T-05a)

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~*)1(t eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 47 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION At this point, !(bl/7\(Q\ I said "the people who fire people with licenses said to do this." llb)/7}/Q) stated that !/b\{7)(C} I did not name anyone but there are not many people above the shift manager. llb)(?)IC) I believes he was talking about the !(b)(7)(C) !and !(b)(7)(C) llb)(7)16i I stated "I was pissed off after this comment because my NRG licens._ e....,s- so

-m- et....h....in- ""

l'm proud of. It is an agreement between me and the NRG not TVA. I own my license." (b)(7)(C) stated that for the other people in the organization who have milestones to meet to get out of an outage to be able to make decisions on how to run the plant when they do not have a license is making decisions overriding the license holders is not right. Soon after this conversation with

!(bl0(Cl I REDINGER came back and relieverl l1wmcci" I At that point, the operators moved forward and did as instructed even though "the whole team was against it" (Exhibit T-05a).

I According to l(b)(7)(Cl there are three let-down systems (normal let-down, RHR let-down, and excess let-down). Both the normal let-down and RHR let-down were tagged out and they were only using the excess let-down, so they did not have the ability to remove water from the RGT, so the water went up. They discussed it as a crew and decided that if the J:)ressurizer got up to around 80 percent then they needed to do something to protect the plant. llb)U)IQ) I stated that this is what ultimately happened. After it was over, !(b\(7}{Ql I came in the control room .

llb)(?)/C) I stated "I am the person tha~lbl(7){~~ ~ ugged in the control room." According to ""~(b"""l(7""l("" c)----.I

!(b}{7)(Cl Ithanked them for protecting e plant that day. llb\17)/Ql Ibelieves that ~b\(7)fCi j may not have known the details, but he was aware of the position they were in and what they had to do to get out of it. llbll7\(Q) I stated that the things that happened that day would not have been news to !(b\(7\{C\ I 8 couple of weeks later (Exhibit T-05a).

llb)!?)(Ql I became aware a few weeks after the event that NRG was asking questions. llb)!?)IQ) was never interviewed by the NRC. He believes it is because his name was not on the logs since he was the extra person that day and not the licensed holders assigned that day.

llb)/7}/Q) I told the NRC resident that he was there but no one ever called him for an interview.

He does know that REDINGER was interviewed. REDINGER told him that the NRC questions were mainly about procedure and why they took the action they took as well as about the logs.

llb)l?)/C) I does not believe there was any intentional wrong-doing regarding the logs but rather they were not detailed because there was so much going on that day (Exhibit T-05a).

llb)l?)/C) I :::idvised that operators cannot just walk out of a control room because they do not agree with what is happening. He stated that legal action could be taken against you for leaving your post. He stated that if you say no that ou will not do something then either you will get 6

told to do it or you are being relieved. lib)(?){ _ I stated "I said no, and they changed the procedure and could safely move on, but I still said I do not agree with this" and "I absolutely believed they would fire me if I did not do it." llb}/7}/C) Ibelieves there is a chilled work environment in Operations and the operators are in fear for their jobs. While he is not aware of anyone who has been fired for pushing back, llb}f7)/Q) I knows there are SROs who have gotten negative performance reviews for not being viewed as a team player and not pushing to get out of an outage. Likewise, he stated that operators are being dis ualified or sent home for a few days for making mistakes. ICW?)IQ) I stated that he came from (b)(7)(C) nd the first step when someone made a mistake was not to send them home (Exhibit T-05a).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 48 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7}/Q) I stated that both !(b)(7)(C) land l(b)(7)(C) I were given five days off for an incident which occurred about three weeks before the November 11, 2015 event. !"""(b""" )(7""")("C) has over 30 years with TVA. He was the reactor operator ,Yhen the source range instruments were bypassed during the re-fueling outage. According to ~)(7)(Cl I l(b)(7)(C) !that day but did not even set foot in the control due to his other duties. Regardless, he was the person held accountable since j(b)(?)(C) I b 7 c and he was sent home. believes the current culture has been built at WBN by (b)(7)(C) and (b)(7)(C) and has dropped down to the department managers. ...................._. stated it has gotten worse in the past six months.

l(bl(?l(C} I believes the pace that management wants them to keep is too fast and they need to slow down. The OCC is in chaos all the time with trying to figure out how they can get ahead by one hour. ilb)U)[Ql I is not sure what is driving this push to meet milestones but believes it is either bragging rights or money. He knows there is similar time crunches in other industries but does not believe it should be happening that way in nuclear. According to !(b)(7l(C) there is I "always an emphasis on safety but we go right up to the line where we are pushing the envelope and we need to slow down" (Exhibit T-05a) ilbl/7}/C) I stated that a Unit Supervisor. lrbl(7)(C1 I. who is also a licensed SRO was removed from his duties for not pushing hard enough. !(b)(?)/C} I was in the control room one day focusing on some tasks involving the Auxiliary Feed System when it was communicated through the Shift ManaITer that management wanted him to do some parallel work on the rod control system. llbl[7}(C_ I continued to focus his efforts on the Aux Feed System which according to lcbl/7)/Q) I was the right thin~ to do when he was relieved of hi i s for not pushing hard enough. According to !(b)(7)(Cl I Om1c1 I was re Iaced by (b)(7)(C)

Rliwl7who is known to be willing to move at a faster pace. l(bl(7)(Cl knowledge among the operators and the crews knew about it happening before the 1

_ removal Is common November 11, 2015 incident (Exhibit T-05a).

llb)U)(C) I stated that there is currently a lot of scrutinr over Operations due to several events (one event happened on the day that lrbl(?)/C} was relieved by!(b)(7)7. (b)(?)(C) believes all the events have occurred due to how hard Operations is being pu~ ue o ese incidents, Operations is currentlz under an "Operations Excellence Plan" due to four things that have recently happened. l<bHZ)(C I described these four things as (1) a nuclear instrument issue (2) the November 11,2015, incident, (3) a few minor clearance issues, and (4) a Unit 2 pressure transient that resulted in the lifting of a relief valve. Being under an Operations Excellence Plan means there are observers in the control room 24/7 including Quality Assurance, the !(b)(7)(C) I l(b)(?)(C) l and other members of the management team . l<bJmrc1 I stated "I think the pace we have tried to keep is faster than the pace we can handle and the answer from management is not to slow down but bring more people in to watch" (Exhibit T-05a) ilb}U)/Ql I stated that many of his friends and peers have been disqualified. He explained that being disqualified means that man;7tement has pulled some of your qualifications and you are limited by what jobs you can do. l1bl VQl I stated that you are at the mercf of management as to how long you are disqualified and when you get to come off of it i/bl(7}fQl knows that REDINGER was disqualified for the November 11, 2015, event even though REDINGER was

,~e, FeR 1-UBUe 01 aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 49 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION against trying to heat-uQ using the excess let-down. When asked how he knew that REDINGER was against doing it, !rb[ 7lfC) fstated that he heard him. !lblf?)fCl I advised that an SRO was recently disqualified, and the operators believe it is for oin against management. This happened around this past Christmas (2015). (b)(?)(C) had been the SRO on Unit 2 when they lifted a relief valve. He was not disqualified after this incident and instead continued working doing the same duties for three more weeks when one night he told management that he did not believe he could safely execute a scheduled activity they wanted done on Unit 2 and they needed to wait. Two hours later, !lbl(l)/Cl Iwas told he was relieved of his post and was

~~:~~ t iqualified because of the incident which happened three weeks ago. According to b7c the message that the other operators got from this happening was he pushed back against management and got disqualified (Exhibit T-0Sa).

!fbll?l(Cl I does believe that this idea of getting out of outage faster is an industry wide idea. He has friends at other plants who he recently saw at INPO who feel they are also being pushed.

SpecificallYi a guy who works for Robinson Power Plant said it was pretty bad at their site as well. lrb)U}icl I stated that !rbl(?)/Cl I strikes him as a person who is out for his career. He appears to be a very arrogant person. llbl/7\/Ql I believes that !lb\(7)!Cl Itries to be a eople person but then will blindside eo le. recommended speaking with (b)(?)(C) a female SRO at WBN, (b)(?)(C) There was a meeting t e previous week with the SROs, Operations Management, and ~::!:!:::=::::.' It was supposed to be a pep talk but "he asked us are any of you afraid right now?" llbl/7\(Q) I stood up and said that yes, she was afraid for her job right now (Exhibit T-05a).

llbl!7l(Ql I stated that llbl(7}(Ql I did not really address it. Rather, he went on to say that he expects 100 percent from everyone 100 percent of the time. lrblf?lfCl I stated that he recorded

{audjo) the i;neeting and will try to get the OIG a copy of it. He also recommended speaking with l(b)(?)(C) j a Reactor Operator (ROs). l(b)(?)(C lis very vocal and has developed a reputation as a complainer but some of his points are valid. After the meeting with the SROs, a similar meeting was held with the ROs. b)(7)(C) had said he was going to try to record it. l/bl(7)fCl I described his shift manager, (b)(?)(C) as a nice guy but a company man who is destined for Corporate. He also thinks (b)(?)(C) and !(b)(7)(C) Iwill try to protect management. Likewise, he does not feel the shift managers will be truthful because they all want to move up. !rb1mc1 I stated that !tbl(7)fCl Ihas on ly been in ~ ition for a short time.

He replaced (b)(?)(C lrblf7lfCl I described !(b)(7) (! as "an ass" and *~ u ." He stated that (b)(?)(C) rough 1b)f7l(CJ to WBN frRm SON When llh}(7l/Q\ I hecame (b)(?)(C)

(b)(?)(C) uddenly showe up to be thet b)(?)(C) f(Exhibit T-0Sa). ,____ _ __,

l!bl(7}!Cl I stated that their working schedule changed around four times before Christmas and there is no flexibility. This caused a lot of turmoil for his family due to having to constantly change plans. lrbl(?}fCl I stated that he made (b)(?)(C) last year between base, overtime, shift differentials, and some other things but he does no ink it is worth it. He said it is upsetting because he hasl(b)(?)(C) Iand they are livil7b} /~ ;ht r dream house in their dream area. He stated that pay is always a frustrating issue with C continually seeming to try to make them give more unpaid time to the company and ask for more days (he now works 4 -12s but it is about to go to 5-12s). !fb)(?)(Cl Istated he would provide an email with his concerns about pay issues.

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 50 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7}/Q) I feels that a big part of the problem is Unit 2 and the push to get it built. He stated that the feeling is come hell or high water they are going to get it started up. llbl/7)/Cl I stated that "it used to be that we were the last line of defense and now it seems like we are the only line of defense" but "when we push back it falls on deaf ears" (Exhibit T-05a).

When discussing November 11 , 2015. llb)(?)IC) I was "r un shy" that day because there had been issues in the da s before November 11, 2015. ilb)(Z)IQ I said that on November 9, 2015, (b)(7)(C) Unit 1 Supervisor (REDINGER) and the unit was working toward moving out of an outage . .......................... recalls the OCC requested the MCR to draw a bubble in the pressurizer without the temperature being achieved as required by approved plant operating procedures. llb)(?)IC) I recalls that he showed llb)/7)/Cl I the procedure that did not allow for them to draw the bubble cold . lrb}U)!C\ I took the procedure to the OCC. Shortly after that somehow the procedure got changed on the fl] to allow for drawing the bubble cold. rcb)/7)(C) I does not know who in the OCC got lrb)!7l/Cl _ to have the procedure changed, but ilb)l7}(C) I does know that it got changed just so they could draw the bubble (Exhibit T-05b).

llb)/7}/C) I said that it was during the procedure chanw '.! !ib)/7)/C) I asked l(b)(Z)(C) Iwho with an NRC license said that doing this was a good idea. b)/7}/C) I replied back that the people who fire people with an NRC license said do it. l<bl(Z)/C) I took this to mean the people in the OCC were saying to do it. ilb)/7}/C) I stated that it pissed him !(b)(7)(C) Ioff and it was ufusettinr that someone would actually say that. ilb)l7}/C1 I intimated that it was not his call. Ir {7)/C) then told the interviewers that management and the OCC were the ones who drove the entiire outage. He added that the OCC was supposed to be in place to support the outage, not drive it (Exhibit T-05b).

l<b}m/C) I then told the interviewers abO.LJJ:..atli.Oll:LeL.UlCILO.eJCLthat happened around November 11 ,

2015. He said that after turnover one (b)(l)(C) called for a meeting with control room personnel. At this meeting, b C erate t e crew saying that we were not pushin~ hard enough on this outage to move the plant forward and were weak. l<blU}ICJ Isaid that lrblr7 Cl I had just gotten chewed out by someone, so lrb)/7}/C) I decided to chew out the crew after he got chewed out. lrb)/7)/Cl Itold the interviewers that after that butt chewing session lrb)/7}/Cl I learned that ilblU}IC\ I had been scolded by the plant manager for not moving the plant fast enough, hence the reason for llb)(7}/Cl I chewing out the crew (Exhibit T-05b).

Interviews of l(b)(l)(C) I Reactor Operator

!(b)(7)(C) I RO at WBN was interviewed on January 27, 2016, and September 19, 2016, by 0 1, TVA OIG, and AUSAHb)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

lrb)(l)/C) I was licensed in (b)(7)(C) and worked on in the MCR on November 11, 2015.

lrb)/7}/Cl I explained that he was (b)(7)(C) and did not have a lot of experience. ,... (b.....

)(7--)(C

- )----.

did recall that after the rod dropped (days prior to November 11 , 2015); l1b\(Z)lc} I got e crew together and chewed the crew out for not doing enough to get them back online. So, when November 11, 2015, rolled around, l(b)(7)(C) ~ id as he was instructed. He took RHR out of

,~ef FeR 1-UBUe 01aeteaURE Wlf l 1euf )l(flf1Re1~1>'<L eF SPECIAL AOEIQI IIQ CHAl":O~. OP'P'IC~ OP' llhE~fleM1em~. fiii!:EOleN II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 51 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION service. He said they had no blueprint to go off of since it was such an unusual alignment.

!lbl{7)/Cl I stated that the excess let-down was in place when the RHR was taken out and he was under the impression that it would take water out to keep the plant from going solid.

!(bl(7}/Cl I does not know why the decision was made not to wait for the normal let-down system but stated the operators did not wait because "we were being pushed by the OCC (Outage Control Center)." llb}fZ)/Q\ I stated that this was his first time dealing with an OCC as an Operator. His understanding of the OCC was that they were the people who understood what was happening and it was theirj ob to come up with a plan. He now believes they are there to push and get the work done. lrQUJ(Ql I stated that he should have never taken the RHR out with that situation, but it was his first outage and the shift manager that day had a lot of experience and he said to do it (Exhibit T-23a)(T-23b).

Interview of!(b)(?)(C) l Senior Reactor Operator

!(bl(7)(C) I SRO at WBN, was interviewed by TVA OIG on February 03, 2016, wherein she provided the following information in substance.

llb)l?}(Q\ I stated that in January 2016 she ran into !(b)(?)(C)  !. The tw~ alked by text before she got there at which time !(bl/7l/Cl I had told her that he had a bad~ nd been removed from watch the previous (b)(?)(C)  !!b)l?}!C} I told her that he had been removed from watch for the PORV lift which had appened the Saturday before Christmas. (b)(7)(C) had been taken off watch the day after the incident, but nothing had been said to b 7 c at the time (Exhibit T-28).

l!b}/7\!C} Iasked !/bl/7}/Cl I how this had happened. He told her about how he had gone to the Shift Manager and told him that there were not the right peo~le in the control room to do the "sweeps and vents" activity which was on the schedule. !lbll[/Cl Itold !lbl(l)/Cl Ithat about two hours later he was told that he could not stand watch because of the PORV lift event from December (Exhibit T-28).

!!b)/7\!C} I was working !(b)(l)(C) !th j ~~k l(ol January 12, 2016) when she was told that they were going to do the evolution on b c This was the same evolution that the revious night's crew had been unable to do because of inadequate staffing. According to b 7 c there was a mixed crew on the day shift and she was not aware of whether everyone had been through just in time trainin . Her Shiftl~~~g,gr on this temr orary crew was !(b)(7)(C) I (she typically is under (b)(7)(C) . - asked l!b}/7\tC: Iif she was comfortable doing it and she said she nee e time to ook into it. llb}/7\!C) I then gave llb)/7\!C) Ithe time and a couple of hours later after reading the procedures and talking to people she said she was good with going ahead. l!b}/7)/Cl I stated that her specialty isl(b)(7)(C) I during an outage (Exhibit T-28).

After briefing several times, l!b}/7)/Cl I advised that they then went ahead with starting up one RCP. It was done in two steps. Everything went smoothly, and it was done safely. A short time later. !!blU)!C} I stated that suddenly the OCC or someone else said let's do another one.

!(bl/7\/Cl I stated that she was kind of like "what the hell?" !lbl/7)/Cl Iadvised that a plan had

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 52 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION been in place for a week with all the pre-calculations and because one worked they suddenly wanted to start up another RCP. About a half hour to an hour later b 7 c was asked to come to the briefiniS room for the second start up since she was (b)(7)(C) The entire evolution was briefed. !lb\(7)1 _ Ithen spoke up stating that there was no contingency plan. She also asked a lot questions including what are we gaining by doing this. She stated the Shift Manager said that we want to get out of solid. !rb)(7)1C} Ithen said if we try to do this and lift a PORV then we will be in solid much longer (Exhibit T-28).

!rb}l7\!C\ I wanted to look at the risk versus benefit. She said that if they did this then they would be beating the schedule by about two hours. However, i(blmrc) I stated there was no need to rush and be changing plans. According to !(bl(7)(Cl I ilb)(Z}IC} I listened to her but was not in agreement. She stated that a reactor operator challenged her in a good way that the crew had just done it, so it made sense to use the same crew. After some discussion, the meeting broke and !lb}(Z)IC\ I said he was going to think about it. !lb\17\IC\ I then saw !lb)l7}1C} I on the phone and about ten minutes later they again met around the horseshoe. !lb}(7}/C} I said it was pretty formal. At this time, l1b\{7}/C) I started out by saying this is my decision and my decision alone and that they were going to start the reactor coolant pump. ilb\(7}/C\ I thought that saying it was his decision alone was an unusual thing to say. When she found out they were going to move forward, ilb}U}IC} I stated that she was honestly in shock because most of the people there had sided with l1b)(7}!C\ Ithat they were not comfortable moving forward with the second pump (Exhibit T-28).

!lb}(Z}IC} I remembered beinfi upset but stated that she is l(b)(7)(C) I

!(b)(7)(C) l However, !lb}UC) I did ask for a contingency plan for how to deal with the filter, so she started researching it. She stated at this point her relief was already there and ilb}!7)[Cl I was still on the phone. At this point, !rb)l7}fC} I came back to the group and asked if anyone thought this was not his decision. !lbJU}{C} I stated that she said yes, I do. He then asked if anyone has a problem starting this RCP and l/bl/7\/C\ Iagain said yes, I do. l/bl/7\[C\ Ithen said end of brief that we are not doing it. l/b}(?)IC} Ifelt like she was in a weird position having to do this because it was done in public. llb\!7\IC} !felt very uncomfortable (Exhibit T-28).

!rbl(7}/C} I then took her aside at the end of the shift. He said he wanted her to know that it really was his decision. lrb\17}/Cl Itold him that she believed him but the position he has been in has been bulldozed for so long that she felt like he had given up the fight. He said he understood and appreciated it (Exhibit T-28).

!rb)(7}/C} I stated that she went home and was pissed. It had been a rough day starting out with what happened to (b)(7)(C) . She then ~ot an email about a mandatory meeting at 7:30 a.m. the next day with the (b)(?)(C) l/bU/C) I was happy about the meeting because she had a lot to ~av about the f°nstant pushing going on. !lb}(]\IC} I stated that she was already upset aboutib)(?)(C) _who had been taken off watch 3 weeks and 3 days prior but was doing stuff like vacuuminf the control room rather than bein~ remediated. Shes . was stu~id because l/bl(l)(Cl is a workhorse. She knew that l/bll(Ql I had gone to (b)(?)(C)

!(b)(?(C) I but nothing had changed. !lb\(7}1Cl I had even gone to !(b)(7)(C) Iand said the

,~e, FeR 1-UBtte 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 53 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION deal with !lbl/7}/C} I was bullshit. She told him that !lbl(l)/Cl I had tried a hard evolution and you are killing him. She then told !lbl/7}(Cl Ithat !lbl(7}!Cl I may never come back the same (Exhibit T-28).

(b)(7)(C) was thinking on the drive in that she was going to tell the !(b)(7)(C) what she thought even though she was worried about losing her career.

She stated, "we are a number to them." She stated that management has no idea what the operators do, what are the individual skill sets and who is smart. She stated that it is "probable the more you do the more chance of an error" (Exhibit T-28).

During the l(b)(?)(C) Imeeting thatl(b)(?)(C) ~sked if anyone there was afraid, and

!rblU}rci I replied "yes, I'm afraid." ilbl(Z)IQJ I was immediately interrupted b~ two SROs.

!lbl(7}/Cl Ithen came back to !lbl(?)/Cl Iand asked why she was afraid. lr@111c1 Itold him that the stuff she is catching should not be getting to her since she is the last barrier. She is worried about missing it and how she will be punished because of it. She stated that no one wants to tell because they are afraid to raise the issue. She stated that she has been part of cover-ups where things are kept at the operators' level because they are afraid of repercussions. She clarified to the agents that she does not mean cover-ups in the sense of falsifications but rather that if they realize a coworker missed something on a work order then they'll fix it for them (Exhibit T-28).

!lbl/7)/Cl I stated that the respect for the Shift Managers h.as gone done so the OCC is just bulldozing right through them now. In October 2015, the common saying was "is it because you do not want to do it or is it the law?" ilb\(7)/Q) I stated that sometimes it is not black and white, but it is stupid. She stated that this pushing results in the operators putting themselves in risky situations since they are made to do stuff they are not comfortable with. !rblCT){Ql I stated "I am afraid because something big can go wrong" with the way things currently are happeni1n9 . She stated "we are letting them push and get to us" which causes mistakes. According to !(bX7)(C) I management claims they are giving us (the operators) time but that is not what is happening.

Rather, management says it is perception but that is BS (Exhibit T-28).

In November 2015. irb)U}/Ql I ~tated they were trying to startup after the forced outage and the pushing got so bad that she was ready to leave. She was meticulously reviewing the work orders when she realized that they had not met all the criteria . She stated management wanted to start up the nuclear reactor and they began pushing her. She was an~ifr because she was bein~ p ushed to sign a work order that gotten missed. She stated that !lb J(C) Iand

!/b}(?H~l I were the ones doing the pushing and asking what she needed. She stated that their tone was basically implying why aren't you going faster. She stated they did offer help, but it was stressful. She felt like* they were pushing her to sign the work order but "I did not, I refused to sign it the way it was written (Exhibit T-28).

!lbl/71/C} I recommended speaking with another SRO, !(b)(?){C} I l1bl/7l{Cl I described

!lbl(l)/Cl I as perfect for the main control room because of his knowled e and ability to see 1

the big picture but also because "he has balls" and will say no. As a result. ]bl(7)/QJ I felt like he

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY QI INVESTIGATION INFORMATION 54 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION was a good person to be a unit supervisor during the outage. She stated that ... l,b.,..}!_.?l(.,..C.._}_ __.

had early in the outage had a need violation , but she still felt like he was a good choice (Exhibit T-28).

!(bl{7)/C\ I heard that !!bl(7l!C) Iwas removed from the controls during the last outage by his Shift Manager, !(b)(7)(C) l because he said refused to do rod testing because he wanted the whole control room focused on the Terry Turbine test. Th e perception is that he was removed for the pushback because he wanted to do the testing in series rather than in parallel.

According to !rbl(7)(Cl I lrtrn1c1 I is doing parallel tasks all the time so if he said not then there was a reason (Exhibit T-28).

Interview of!(b)(?)(C) I Senior Reactor Operator. Unit Supervisor

!(b)(7)(C) I US at WBN, was interviewed by TVA OIG on , March 3, 2016, wherein he provided the following information in substance l(b)(7)(C) Itold the a ents that on February 24, 2016, Hbl(7l(Cl I!rb\(7)/Q\ Iand !rb\(7)/C\ I met with all SRO's on (b)(7)(C) T he theme of the meeting was that management was letting the SRO's know that management would back the SRO's in the event the SRO's sto ed work or slowed down work for safety reasons. The meeting started a (bl(7l(CJ and ended at (b)(7)(Cl During the meeting, !lbl/7\IC} I and !/b\17l!Cl ! let the group know that investigated issues relating to retaliation and concluded that there was no retaliation. !(b)(7l(Cl Isaid that !!b)(7l!C) I and

!(b)(7)(C) !stood up front and were holding some type of victory celebration (Exhibit T-68).

!lbl!7l(C} Iwent on further to explain to the group that !lbl(7}(C} Iwas supposed to have been removed from watch weeks earlier, but was not due to a communications error. !lb)U)fC) I stated he was caught by surprise when he called the Shift Manager to tell him good job for stojj~ng the evolution. The Shift Manager told !lb}(7}(Cl Ithat it was not him but rather was lrb)/J_. l 1,-lll"IIIIW!il_,........ then stated wait a minute I thought he was removed from watch standing. (b)(7)(C) confirmed to the agents that ilbl!7l!C} Isaid it was a conversation between him and the Shift Mana er when !!b)(7l(Cl Ifirst became aware of !lbl/71/Cl I involvement and that he (b)(7)(C) was still watch standing. !!bl(7)/Cl Ithen said that he contacted (b)(7)(C) and b 7 c to have them remove !(bl!7l/C} Ifrom watch (Exhibit T-68).

!(bl!7l(C} Itold the SROs that he realized they had a communication error once he realized that l<b}(7}!Cl I was still watch standing. !(bl!7l(Cl I told the group of SRO's that !!bl(7}!C} I was surprised that l!bl/7)/Q\ I was watch standing that night (Exhibit T-68).

The af ents asked (b)(7)(C) what his impressions were of that story given to the SRO's by l!b)U)!Q I (b)(7)(C) said that he knew that ifbl(7)!C) I was telling the SRO's what the "story is going to be" about that articular incident. (b)(7)(C) knew that it did not add up because how on earth would b c not have known C had been watch standing for three weeks. l(bl(7}!C} I is the (b)(7)(C) and that is his job (Exhibit T-68).

,~e, 1-eR 1-uBue 01aeteauREw1T1 1eu, >'<flflRe'~'>'<t e1-SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 55 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION The agents asked l(b)(?)(C) I if he was involved in the !(bl{7}[Cl Iwatch removal incident last year. He said that he was working on the Unit 2 side that day b 7 c was on Unit 1. !(b)(7J(C) !was the Shift Manager. !lb)(l)(Q) I came up to (b)(?)(C) and asked him to move to Unit 1 because he !(b)(7)(C) Ifelt that !(bl/7l(C} I had not been executing as well as he could have been and was not looking ahead (Exhibit T-68).

(b)(?)(C) stated that he was not aware that on the day that !lbl/7}/C} I was removed that he (b)(7)(C) was being asked to do the Terry Turbine test as well as move the rods at the same time. (b (7)(C) stated that gou cannot do those two activities at the same tiime and

!(b)(7)(C) Iwould have expected !lbl(7}/C_ I to stop (Exhibit T-68).

When asked

• ms could be scheduled to be done at the same time when they are not supposed to, (b)(7)(C) stated that if there is any clear schedule, the OCC will throw things at the wall and see what sticks. He stated that activities will not always get reviewed so if they are trying to be proactive or if the schedule is behind and needing to get caught up then i~~.u..,i._,

up in a position where they are taking shots on oal which is not good (Exhibit T-68). (b)(7)(C) stated that the SROs are trying to unionize. (b)(?)(C) is not for joining a union based on his revious work experience bu ad a comment that recently concerned him. S ecifically, b 7 c was talkin with (b)(7)(C) and !(b)(7)(C) Iwhen he (b)(7)(C) said he was going to take (b)(7)(C) Qual Card away because b 7 could not have one of his shift managers organizing the others to join the union. (b)(7)(C) ,statedJ b.af !rb}W/Cl I also said that unionizing the SROs will make him (b)(7)(C) uit. l(b)(?)(C) told the agents what l/b}(7}/Cl I said because !(b)(?)(C) !knows what b is doing is wrong (Exhibit T-68).

Interview of l(b)(7)(C)

!(b)(?)(C) Iwas interviewed by TVA OIG on February 8, 2016, wherein he provided the following information in substance.

(b)(7)(C) started workin at TVA in O erations (b)(?)(C)

(b)(7)(C) b 7 c in s e opera ors are scare s I ess or eIr JO s. e ee s econ ro room personne are scared to s eak u . i!b}(?)/C} I stated he has heard that a Unit Supervisor was taken off watch by the (b)(7)(C) for raising a concern, but it was said it was for something (a lifted valve) t ed three weeks before. i!b}l7}!C) Ifeels that what happened to this operator is "total bullshit" and "they sent a message to the entire operations department - cross me" (Exhibit T-69).

irbll7}!Ql I ~tated that he has never seen anyone disqualified weeks after an event. Rather, an operator would be taken off the day of or the day after the event. They would then be promptly remediated and returned. According to !(b)(?)(Cl I once the operator was allowed to assume watch the next week he had already made too many operational decisions to take him off watch (Exhibit T-69).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 56 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview of !(b)(7)(C)

!(b)(7)(C) I was interviewed by TVA OIG on January 20, 2016, wherein he provided the following information in substance.

!fblU)(Cl I I stated that the current management of !(bl(7l(Cl and !/blU}ICl I is very different from former management. He stated there is pressure to move things forward. T hey have usually decided a course of action before a meeting and just want the groups to ratify the decision they have already made. They basically say stuff like "this is what we are oin to do, does anyone want to speak out against that" and no one does. Accordin to b 7 c "we do not have the environment where we can push back" (Exh1ibit T-70). b 7 , stated the SROs are esr cially uncomfortable going against management on control room decision. Recently, SRO!(b(7)(Cl I told management he could not do a required action on the reactor coolant pump (RCP) because he did not have enough trained people. Management backed off but the very next morninm !/bl!7}/Cl I was disqualified for a previous event that had happened over three weeks ago. !/bl(]) C} I believes he was being punished for not doing what management wanted on the RCP (Exhibit T-70).

Interview of l(b)(7)(C) !Unit Supervisor

!(b)(?)(C) I US, was interviewed by TVA OIG on February 8, 2016, wherein he provided the following information in substance.

(b)(7)(C) is licensed. He is a Senior Re~ .gr.,!i.meLallQ.[~ J:il..U......~ obtained his license in (b)(7)(C) He has been with TVA since (b)(?)(C) was as~ he recalled working on January 11 , 2016. He said he worked that (b)(7)( He was working ibl(7l or both Unit 1 and Unit 2. !(b)(7)(CJ Iwas the Unit Supervisor t a (b)(7)(C) was e Shift Manager. After he was told he was being taken off watch, b state t at he was to put in the narrative logs that he was taken off watch for raising a safety issue. (b)(7)(C) stated that he and !(bl/7lfCl Itold !(bl(7lfCl Ito take a walk and calm down rather'""t,- ha_n_w

_ r..,.,it,_e_ __,

anything because there was no reason to poke the bear. The agents asked !lbl/7\!Cl I why he thought !lb}(Z)(Cl I had been removed from watch. (b)(7)(C) said that to him it was a messa e "to et on board or we will get you out of the way." (b)(7)(C) blamed ,..!lb-l(7....l/.....

Cl- ---,

(b)(7)(C) said nobody in Operations will stand up to him. The message to Operatiions is to get on the team or else (Exhibit T-71 ).

mi(~?~(er

!(b)(7)(C) lalso recalls lrbll7HC I telling him on January 11, 2016, that !!bl/7\/Cl I had said on a phone call that he b 7 (C) told do it and "do not give me any of that nuclear safety bullshit." (b)(7)(C) stated that b 7 C said !lbl{7l/Cl I had called him back later to apologize. b c believes the attitude at WBN is "to not do anything to jeopardize the schedule" is the root of the roblem. The pressure is to "make the published date." This ressure is from the top. (b)(7)(C) believe the SROs are in fear of losing their jobs.

(b)(7)(C) said that they do just about anything to stay on the published schedule and do not do anything to jeopardize the schedule is the answer the operators get most of the time. They move required maintenance out of the way just to stay on schedule. The problem is that certain

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 57 Case No. 2-2016-042

6FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION maintenance must be done at certain times. They end up either changing the procedure to match what t ry want to do based off plant conditions or not doing the maintenance at all.

@l(7)(C) _stated that management will get engineers to sign off on anything and the engineers are in the same spot as the operators and do not want to make waves (Exhibit T-71).

!(b)(7)(C) !said t1e people pushing to move forward and stay on the published schedule do not have a license. (b)(?)(C) l thinks that !rb}(?)(C) I is the problem because he used to have a license and feel as though he knows it all even though he was never licensed at WBN.

Furthermore, ifb)mrc1 I has never been an SRO at a commercial plant and the OCC managers only have SRO certifications. He stated that very few of these people hold a license but are trying to run the plant and make decisions over the licensed personnel (Exhibit T-71 ).

Interviews of l(b)(7)(C) I, Shift Manager

.....,....._____,, SM at WBN was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA

""--'...;.__ __. US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

Agent's Note: In his initial interview with 01 on December 18, 2015, !rb)(l)(C) I failed to provide the same level of detail and specifics as he provided in subsequent interviews.

On December 18, 2015 irb\{7){C) I was interviewed by 0 1concernin the events o;-f_ ____,

November 11 2015 and rovided the followin information. was in the (b)(?)(C) from (b)(7)(C) power plants, DOE facilities, en ineerin firms. b 7 c has been licensed since (b)(7){C) and a Shift Manager since (b)(7)(C) explained the plant had removed normal let- own from se

• he night previous to the shift that he took over on the b 7 c vember 11 , 2015.

!~:

At 7l we had heated up to enter Mode 4 which is 200 degrees. At (b)(l)(CJ e secured both tra RHR to allow the RCS to continue heating up. The plan for November 11, 20 15 was to heat-up and pressurize RCS and enter Mode 3 at some point during that day or that night. The normal let-down system for CVCS was out of service for repair to a leaking valve and they had placed the alternate let-down system, excess let-down, in service for let-down capabilities.

Other than that, all the other plant conditions were normal as to be expected for Mode 5 and Mode 4 (Exhibit T-22a, pp. 4- 11 ).

ifbl(l){Cl I discussed that nobody raised any concerns nor did any of the crew have any questions or concerns about trying to do a heat-up on excess let-down. !rb)/7\(C) I explained that the crew discussed the fact that they had not done it before and were willing to start it and see how it went. i{b\{7)/Cl I stated he thought they had enough excess let-down flow to be able to control pressurizer level on excess let-down. When asked about the crew's reaction to planned events of the day, ifbll7lfC\ I stated he did not remember any big push back from the crew. However, ilb)/7\/Cl I remembered being a little bit anxious continuing the start-up activities with only excess let-down because he had never done it like that before and was not 100 percent sure that it was going to go the way that he anticipated it to. ilbl/7\/C\ I reasoned that he did not challenge the path to move forward because he had no basis for saying it would SPECIAL AGEl<.J I 11<.J CHARGE , OFFICE OF ll'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 59 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

!/b}/7}/C} Iand !lb\/7\/C\ I At which time, !lb}/7}/C} I asked llb)/7}/C) I if ..,.!lb...,)(7'i=c;:)

)r= ===:::!..,_-.

should be removed from watch until they found out the answers to the questions. llb\/?l(C\

said "Yes." lrb)(Z)/Ql I stated that he was glad he had been in the meeting and heard the conversation because he realized it was not a punitive thing but rather just a conservative measure until the NRC was comfortable. llb}(7\IC1 I also believes it was to position themselves to look better to the NRC. lrb)(Z)/Cl I said this was normal and he would have done the same thing. llb\/7)/Cl I went back to his regular work control job and was able to fill in the next time he was asked for help in watch standing. llb\(7)/C\ I said he was never remediated. lrblmcci I never heard lrblWCC} I or ICbl!7)CC) Italk about taking anyone else off watch because "the buck stops with me !(b)(?)(C) I (Exhibit T-22c).

On September 6, 2016, lrb)UJCQl I was interviewed by AUSA i(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, TVA OIG and 01 wherein he provided the following information. Although lfb}(7)/C1 I asserted that he was not worried about raisin issues to the OCC, !lb)(7)/C1 I was certainly not comfortable about challen in the (b (7)(C) and !(b)(?)(CJ !about Qlant decisions . ...,b_.__

7-c~~""" e'"'"

m-p~h-a s~iz _e_d~t-:-h_a_t o_n ...ce the first engineering test was over, he called l/b)(7}/C) Ito inquire how much longer before the valve (normal let-down was in-service. According to !(b)(7)(C) I !rblU}/Cl I told him the valve would be ready soon. b 7 c said the schedule called for WBN1 to proceed to Mode 3.

llbl/7)/C) I stated there were no procedures in place about what to do or not to do when heating up using excess let-down. !1b1mrc1 I said there was nothing in writing saying it cannot be done. llli1m1c1 I disclosed that he was uneasy about proceeding partly due to the fact that he had no experience heating up using excess let-down. iibl[7)(Cl ] stressed that WBN1 was not at full pressure, but ilb){7}(fa I 8dmitted he had no idea how using the excess let-down would affect the pressurizer level. Likewise, ifb}/7)/Cl I was unable to estimate how much inventory (water) they expected to get out using excess let-down, no numbers were discussed (Exhibit T-22d).

ilbl/7)[Cl I stated that he knew there were ways to control the plant if excess let-down did not work and if the plant did what he was "afraid" it would do. ilb)/7}/Cl I explained that the procedures are not written for every step (scenario). ilb)/7)/C) I stated that he knew how to recover the plant if excess let-down did not work and understood that the pressurizer level will go up during heat-up. !lb)r7)(C} I stated that the first step for heat-up was to remove the RHR.

Once the RHR was removed, the tem[)erature in the RCS would increase. !lb)(7}/C) I stated that prior to removing the RHR . !fblU}rcf I set some trigger values to ensure they took action.

At th'

• t, nobody could put their finger on why they should not heat-up. According to if he did not have contingencies then he would have been more concerned.

stated that the licensed operators were not overly experienced and once it was discussed none of them had an opinion one way or the other except ilbl/7)/Cl I ilbl/7)/Cl I stated that no one else said it was not a good idea which caused l1oimrc1 Ito start doubting himself because he seemed to be the only one that was uneasy. In regard to .._b'"""'." 7.._,c..........___ _,

ilbl(7}/Cl I testified that ilbl/71/Cl I basically said something to the effect that, "He (b)(7)(C) felt !lbl(7)/C1 I pain but we have a schedule." !lb\(7)/Cl I confirmed that he set a trigger value of 80 percent pressurizer level where they were to open the PORV to control the rate of heat-up.

They then took the RHR out of service and the pressure quickly got to 79 percent which was

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 60 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION faster than they anticipated. !ib)Cl)!C) I said the rate of heat-up is what "killed" us because it out ran the excess let-down system which is what !ib)f7l(Cl I suspected was going to happen.

At this point, REDINGER opened the RHR inlet valves and the pressure level went down (Exhibit T-22d).

A ent's Note: Testimon from the other control room operators (REDINGER, (b)(7)(C) b7 c and !(b)(7)(C) Ion shift during the November 11 , 2015, events contra 1cts b statement that none of the other operators had an opinion on removing RHR from service.

Once the normal let-down got fixed they reconfigured everything and moved on. lrbl(7)fCl said that they should have just waited until the normal let-down was fixed. About ten minutes after they opened the relief valve and recovered, !rbl{7l/Cl I came in the MCR and thanked everyone for not letting the plant get out of control. !(b}(7l(Cl I said it was clear that !(bl(7)/C) had been in the OCC watching the event on the monitors and knew what had just happened.

!(blfZ)(Cl I said the event was not logged and no CRs were written. !rbl(7l1Cl I admitted that he did not check the logs and acknowledged that they made mistakes. !(bl(7j/Cl I could not recall who the Unit Supervisor was on the day of the event, but confirmed that later that afternoon, he sent an email to the other Shift Managers telling them, "Do not try to heat-up the plant using excess let-down." The comment on the email about not letting anyone talk you into it was made because it was not his idea to proceed with the heat-up without normal let down in service. lrbl/7l(Cl I does not believe anyone in the OCC would have put the plant at risk on purpose. However, the lack of experience, knowledge, and schedule pressure all happened because they were trying to see how fast they can get back to making money. lrwrncI I expressed that everyone knew what he was doing, why he was doing it and what he had to do to recover the plant. !rbl(7)(Cl I stated that at the time all these "smart people" were saying it is "ok" to do it and he !(b)(7)(C) I was the only one saying "no" so he talked himself into thinking it was alright because everyone else felt it was alright (Exhibit T-22d).

On April 3, 2017, !(bl(7l(Cl I was interviewed b TVA OIG and rovided the followin information !(b)(7)(Cl I said that he recalled ll.:b4 7~ C~ - - - - - - - - - - - - - . . . . . . . 1

!(b)(7)(C) Ior (b}(7)(C} telling him to do it on November 11 , 2015. He said that e could not remem er w ic one it was, but he did recall it was the person in the (b)(7)(C) osition. !(bl(7)!C) I also said that during the same conversation he was informed that ......,......,..____, and i!bJ[Z)/Q} I wanted it done or were for it. !lbl(7liCl I said that he let others in the OCC know that he was not in favor of doing it and did not want to do it. !lbli7l(Ql I said that the OCC knew how he felt. !(bl/7}/Q) Itold the agents that he could not remember exactly who all he told in the OCC, but he did know it was more than j ust !rb)/7l1Cl I lrbl/7)/Q) I added that he has a family to feed (Exhibit T-22e).

Interviews of !(b)(7)(C) IUnit Supervisor

!(b)(7)(C) I US at WBN was interviewed on multiple occasions by TVA OIG wherein he provided the following information in substance.

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 61 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)

!/b}/7}/C} I has been a licensed SRO for abou ~~1 years. He was asked what the problem was at WBN. He stated the problem was the people m charge of the plant. !lbl[?l/Cl I said that the Shift Managers are no longer making Control Room decisions. Shift Managers are just a ~ass through from the OGG/Management to the people working in the Control Room. ilbl/7 Cl dictates what he wants done and !lbl/7l[Cl I dictates what he wants done. Nobody will say 'that is not a good idea." The Shift Managers have stopped pushing back (Exhibit T-27a).

The agents then asked !lbl/7}/Cl I what happened recently with (b)(?)(C) etting removed from duty. l[bl[7l(Cl !said the initial event occurred at the end of (b)(?)(C) when he was working in the Control Room as the Unit Supervisor just like normal. He had been in the Control Room serving in that cabacity j ust about every day since the maintenance outage. He even had conversations with ilblU)I l I in the Control Room prior to that day. On that particular day, they were going to do an evolution called Sweeps and Vents. They were starting up a reactor coolant pump. There are 4 reactor coolant pumps. Sweeps and Vents is a slow methodical procedure because when you start the procedure the pressure in the plant can vary widely.

This means that the people in the Control Room must watch the pressure while they are engaged in the process. Before the~ did the evolution that day they went to the simulator in the Training Center and practiced. !lb}(?) Cl I explained that if the pressure gets too high then that is a bad thing and the Control Room personnel must react. If it gets too low, they must react as well. The pressure must stay between two levels during the evolution. If the pressure gets too high, a relief valve opens up as a safety. The opening of the relief valve during the evolution is not a good thing (Exhibit T-27a).

The operator for the evolution was (b)(?)(C) During the evolution, the pressure got too hit and the relief valve opened. b 7 c was removed from his duties for the mistake.

lrb 7)(C) I had no problem with being removed for the mistake. !(b)v){C) Iwas not r moved.

ilbl/7}/Cl I even asked if he was removed as well and was told no. ~b)(?)(C) _ Shift Manager told him that

• removed. !lbl/71/C) Iwas in the Control Room when it happened as well as (b)(?)(C) . The action taken on !lbl/7)rc1 Idid not ha en immediately. An hour or so later, b 7 c walked up to where !rbl/7l[Cl I and (b)(7)(C) were located in the Control Room and told ilbl/71/Cl I That is when !lb)(7)(C} I aske I e was being removed as well. llbl/7\/C} I recalled that he said to i(b\U)IC} I "what about me." HblU}/C} I replied something like "you are fine." !lbll7l/Cl I said that was the end of that and everyone finished the shift and went home. For the next three weeks, i(bl/7)(Cl I continued working as normal in the Control Room. Ever~one saw him working to include l1b}l7l/C} I l1b11rnc1 Ieven had conversations with !1bjj}rc1 Iin the Control Room. !lbl/7l[Cl Iand !lbl/71/Cl Iknew he was working in the Control Room. He had conversations with them as well (Exhibit T-27a).

About three weeks later things changed. !fbl/7l/Cl I was working in the Control Room as usual.

He was working on Unit 1 and Unit 2 was starting a reactor coolant pump (the same thing he and llb}/7}/Cl I did three weeks ago). lrbl(7}/Cl I was asked to go to Unit 2 and serve as the Unit Supervisor on the reactor coolant pump start up. He did as instructed and of note two reactor operators called in sick that day so in order to have the control room staffed, two of the SROs had to serve as reactor operators. ilbl/7}/Cl Itook survey of the situation and realized that they did not have the correct staffing personnel in place to start the reactor coolant pump. He told

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 62 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION

~ nts that starting the reactor coolant pump was in the schedule/plan for that day. SM I.OillZl!QJ then communicated the concern up the chain of command. !(bill)(C\ I would later learn that !{b\{7HC I spoke to !!b}l?}!C} I and l<bll?}{Q} I ~bout the issue (Exhibit T-27a).

!lbl/?){C I then communicated the concern up the chain of command. !rbl{7)/C\ I would later learn that !(bH?XC> I spoke to !!bll?}!Ql I and !rb}(7}(Q} I ~bout the issue. It was during a conference call that !ib!(!XC> I r:alled from the Control Room. After the call ended, !lbl/7HC I walked back to where

!lb\/7\(C\ I was located. !(b\/7\(C) I asked !\bH7l{C> I something to the effect of "what did they say?"

!lb)(7HC I replied, "You are not oing to like this." !(b\(7}(C I toln !!b)UJ/Ql I that lrb}m1c1 I was relieved of his duties. b 7 C was angry and reQ_lied, "Arelh~ru\[~t ing kidding me." He also said, "I bring up an issue and I get removed ." !lb\(71/2C\ I told b 7 , that l!b\(l)(Cl I was going to record what happened in the Control Room's narrative log. He told !rb\(7HC I he was going to write in the log that he brought up a concern and was removed (Exhibit T-27a).

!lbl(7)(Cl I said to !rbl/7HC I that it sure was odd that they waited three weeks to remove him.

!ibl{7)/CJ I said that nobody realized that !{b\17\(Cl I had been watch standing. !lb\(7)(C\ I said that that was not true because everyone had seen him on the job at work in the Control Room. On site after the incident, people from all sorts of departments engaged l<b}{Z)/Q} I in conversations about the event. !rb\17)/C} ] told everyone that he was relieved from watch due to the relief valve event. He told everyone the "company line." He told the agents that he wanted to tell everyone the truth but was afraid to do so for fear of it getting back to management. He reasoned if they did this to him they would do anything. He wanted off their radar and he wanted to be thought of by management as a team player, so he stuck to the party line (Exhibit T-27a).

!(b)(7\(Cl I was asked if it was possible that his removal from watch standing on (b)(7)(C) was done in an attempt to get him out of the way so the site could do the p anne evo u I0n that night. !lb\(7)/Cl I resQ_onded that based off the timeline of events that night that it was very possible that !(b)(7)/C} ] was removed from watch standing for that very reason. !(b\(7)/Cl I said that his removal from watch standing happened well before WBN management gave up trying to get the evolution done that night. !!b\(7)/Cl I knows this to be true because !lb\(7)/C\ I was removed from watch, then later that ni ht !rb)(7\(Cl I listened in on a conference call that took place between b c (b)(?)(C)  !(b)(7)(Cl I and !rb)U}/Ql I No one knew !rb\(7)/C\ I was listening exceQt for w...i.~'--' On t Is call, !(b)(7)(C) lwas questioning

!ibl(?l{Cl I about the crew composition. !rb\(7)/Cl I said that during this call the site still had not given up on getting !lb}(7HC I to do the evolution. Finally, !rb}{Z)/Q} I recalled that it becam e a_Q.Qarent to everyone toward the end of the call that the evolution was not going to happen.

lrfu1rc1 I then decided on the call that they were going to not do the evolution (Exhibit T-27c).

!(b)(7)(C) ! was questioned regarding his interview with (b)(7)(C) as part of the Special R v* w Team (SRT) report. lrb\(7)(Ql I stated the following: =~'--' was shown a picture of (b)(7)(C) and stated that he remembered the interview whicl,L...¥l=..u.w,ld in the Shift Manager's conference room . !(bl/7HCl I was under the impres * (b)(?)(C} was interviewing everyone on shift that evening. He recalls bein candid with (b)(?)(C) because he thought it was confidential. !lb\/7}/Ci I believes that (b)(?}(C) told him it was confidential. !(bl/7\!Cl I was not I

aware that !(b)(7)(C) provided the notes from his !(b)(7)(C) Iinterview which identified l... rb-l/7-)(-Cl__,l

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 63 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION as making the statements to b c  !(b)(7)(C) I or !(b)(?)(CJ I. !(b)/7}(C} I stated that this was not "okay." b 7 c advised that he told the truth about how he felt because the tone of the interview was that it would be confidential. !!bl/7)/Cl I feels that management knowing what he said could have hurt him in his career (Exhibit T-27d).

Interview ofl(b)(7)(C) IReactor Operator

!(b)(7)(C) I RO at WBN, was interviewed by TVA OIG on February 10, 2016, wherein he provided the following information in substance.

!lb)(l)(C) I was asked to tell the agents about when he wa:s removed from watch in !(b)(l)(C)

!(b)(7)(C) Isaid that he was in the Control Room working. They were conducting an action (starting a pump). During the action, lrbl/7\(C\ I did not respond swiftly enough when the conditions changed which resulted in a relief valve (PORV) being activated/opened. llbl/7l(Cl I recalled that the incident happened just before Christmas. It was the next day that !(bl(7)/C} I told him that he was removed from watch (Exhibit T-72).

He was asked why !(b)(7)(Cl I was removed from watch !(b)(?)(C) !as llbl{l)(Cl I was removed from watch. !(bl/7l/Cl I said that was obvious. The perception from people in the control room is that he pushed back and was magically disqualified. lrbl(7)/C) I told the agents that he is not afraid to push back. He is protected by the union. A rievance process is available for him. He said that the SRO's do not have protection. b 7 c said that the pushing that is being done now is wrong . Pushing like management does now causes mistakes to happen. This new push, according to !(b)(7)(C) I all has to do with getting Unit 2 online. !/b)/7l!C} I said that no matter how hard he is pushed, he will not do anything that is unsafe. He said he will walk out of the Control Room before he does something unsafe because he is getting pushed. !(bl(?)(Cl I added that if the OCC or management wants him to do something that he thinks is stupid, but still safe, then he will do it. Again, he added that he had union protection (Exhibit T-72).

Interview of !(b)(?)(C) l(b)(7)(C) Iat WBN, was interviewed on February 29, 2016, by TVA OIG wherein he provided the following information in substance.

((bJ(?)(Cl I stated that during the outage, (b)(7)(C) would come into the shop and not talk to anyone. According to _b- :- 7 "".c_ _-:---~~~

and glare at people and did not talk, he just stared at people. b 7 stated adding to the schedule pressure during the outage was the statement made by !(b}(7}(C} I before the outage.

lrbl{?)[Ql I said that lrb}U}(QL Itold a large group meeting offsite just before the outage started that if anyone did not think they could do the schedule in 30 days then they needed to leave (Exhibit T-73).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 64 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

~.........., described the intimidation at WBN was horrible. !lb\(7)/C) Iex lained that (b)(7)(C) is a (b)(7)(C)

(b)(7)(C) Allegedly, (b)(7)(C) and stopped it (Exhibit T-73).

Interviews ofl(b)(7)(C)

(b)(?)(C) at WBN, was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA (b)(7)(C) US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

(b)(7)(C) b stated there were basically three options: (1) stay in Mode 5 and wait until the normal let-down was back in service or (2) heat-up to Mode 4 and stay on RHR or (3) do option 2 and then take RHR out of service and the cooling mechanism would be the main steam dump. The decision was made to go with option no. 3 (Exhibit T-21a).

!lblCD(C) I recalled in the re-fueling outage that SRO !(b)(7)(C) l slowed down for four hours to review a package b,efore they moved forward with heating up. He knows she felt pressure because all eyes were on her. !lbl(l)IC) Ihelieves that the issues hapQening at WBN are because !/bl(7)/Cl I and !lb}(7l(Cl Iare holding people accountable now. !fblm[Cl Istated this is the first time in the Operations organization where they have been held accountable to this degree ilb\ffi/CJ Istated that there are a lot of individuals who feel because they work here they have some privilege with not doing the work. !/b)(l)/C) Ibelieves that people are angry now because they are being held accountable (Exhibit T-21a).

When discussing the removal and disqualification of !(b)(l)(C) I on January 11 , 2016, !lbl(l)(C) discussed that the investigation (done by (b)(7)(C) a s part of the l~~~biint this matter took approximately a week and a half at which Ime I was etermined that clear direction to the UO in this case to reduce charge. As a result, the decision was made in 1had not given discussions with !(b)(7)(C)  ! that !(b)(l)(C) ! should also be disqualified. However, !(b)(7)(C)  !

stated that he failed to communicate with ilb)(?)IQ) I that ilb)(J)IQ) I was disqualified because they had a lot going on due to the RHR event (Exhibit T-21a).

According to !(b)(7)(Cl Illbl(7HC I raised the concern and did not say it was the operators. They discussed who was currently in the control room and !lbl/7)/C) Irealized that there was not an effective staff to be successful at starting the RCP. !1b1mrc1 Icalled !(b}(D(Cl I and told him the situation and ilb)/7)/C) I re uested that ilbl/7)/C) I send him the mannin sheet, so he knew who was on dutfl. When I }(7)/Cl

!lbl(l)/Cl Icallerl !!b}/7 Cl 6 Igot the sheet, he saw that b 7 c was working .

I back and told him that !/b}U)/Cl I was working. !lb)(l)/C) I said, "I thought we had taken him out of rotation earlier." !lb)(7l/C) Iadmitted he had made a mistake and had not pulled !lb)/7)/C} I from watch standing. !lb)(l)/Cl Ithen said, "We cannot leave him

,~o, FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L OF

.319~CIAL AeEl~T II~ Cl lil<ROE, OFFICE OF ltWE8TIOMIOP40, AEOIOP* II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 65 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION in there to make an error and move him." !lbl(7)/Cl Ithen contacted lrblr7HC I with the news, so he could tell lrbJ/7}/Cl I !(b)(l)(C I replied that "oh ou've got to be kidding." i(blr7l(C) Istated that the whole thing is "obviously poor timing." !rb)!?l(C_ 3 I AStimated that he goes into the control room 4 to 5 times a week. He is aware that l/b)U)IC) I was conducting his licensed duties during the time between the events. lrb)r7l!C) Istated that being taken off watch is not disciplinary, but it is also not fun (Exhibit T-21a).

When discuss communication on the night of January 11, 2016, !/b\(7)/Cl Icould not recall l!b}/7}/C\ I saying, "Do not give me any of that nuclear safety bullshit." However, he does recall lrb)l?l(C} Iusing inappropriate language and telling !(b)(?}(C I something to the effect that basically he was "chickenshit" for not moving forward (Exhibit T-21 b).

lrbll7)(C) I was asked by the agents about all the talk the agents have been hearing about pushing. l/b)(7)/C) Istated, "That pushing is common and I have had much worse." In his opinion, operations are not doing well because there are some fundamental areas with operators' performance and they have failed to correct the low-level behaviors. Some examples of these include communications, responses, and board monitoring. l/bl/7)/Cl I believes the only recent event that could -even remotely be associated with pushing would be the RHR event because the whole OCC team was pushing to move forward (Exhibit T-21b).

According to !(b)(?)(Cl I Operations knows the knowledge level is lower than it should be, and that management needs to be in an oversight role to make sure the people who do the actions understand what they need to do. While these oversight managers may not have an active license or be a license holder, they have the required knowledge from past experience to make decisions and assist in what happens in Operations. llbl/7)/C) I believes it is inappropriate for someone to sa that l(bl/71/Cl ] should not be involved in the control room decisions since he is the (b)(?)(C) , who !(b}U)(Cl Ibelieves is very knowledgeable (Exhibit T-21 b).

l/bl(l)rCJ Iconfirmed that !lb)/7}/Cl I is an inactive license holder but was basically telling the Shift Manager, a licensed holder, that he was a "chickenshit" for not moving forward with something he (the licensed holder) felt was not safe. The operators have the license and responsibility to the site and the public. l/b\(7}/C) I stated, "If they absolutely feel it is unsafe, they need to stop." When asked what if the shift managers do not know whether it is "absolutely unsafe" but they are uncomfortable doing it. llblr7)/C) ] replied that there would be a discussion about the differing opinions and the Shift Manager has the ultimate decision l!b\(7}/Q\ Ifeels like the Shift Managers now will tell him if they are not comfortable with something (Exhibit T-21b).

lrbl/7)(Cl Istated the level of management involvement and the need for justification is determined by the length of the delay. l/blm1c1 Isaid anything that is going to be off by three hours needs to be justified to (b)(7)(C) do-es not think there is anything wrong with having to prove why you cannot pe orm a sc e uled action (Exhibit T-21b).

When discussing the events of November 11 , 2015, l(bl/?)(Cl Iidentified had been talking to l/bl/7l(Cl I on a regular basis that day about what was h.appening. In addition , llb)(Z)(Cl I

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 66 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION would have been in the OCC frequently that day. !lb\(7}/Cl I stated that !rbl/7}/C\ I was for movi~i forward that day, but the decision was made by !rb}/71/C} I !lb}l7}/C} Istated that he and lrb ?l/Q) I were good with moving forward that day because they thought they could do it safely. He stated that everyone was good with moving forward in the beginning about November 11, 2015, but now say how bad the decision was. There have been "a lot of Monday morning quarterbacks" about this issue lrb)/7)/C) I<foes feel like there was a lot of miscommunication. It was clear to !/bl(l)/Cl Ithat day that the decision was made by

!lbl/7}/Cl I who was the shift manager (Exhibit T-21c).

ilb}l7}/Cl Idiscussed that durin] outages i{bl{7)/C\ Iwanted to know minute by minute what was aoing on. In the OCC, i(b)/7)1Cl  ! and !/b)(l)(C) ! were part of the Senior Leadersh ip Team.

i/b)U)( J I stated that information to lrb)(Z)/CJ I would go through him (b (?)(C) while decisions went from (b)(?)(C) to !/b\(7)1C\ I i{b}(7)/C} I would then go to b c with the decision. b 7 c said that there was discussion in the OCC to remove RHR and allow the heat-up to begin. ilb}l7}fC} Isaid that they had many discussions about that in the OCC and in the main control room with ifbl{7)/C\ I !(bl/7}/C\ I questioned hbl(7)(Cl Iabout what was going to happen to the pressurizer level if they took the action. !/bll7\/C\ I had multiple conversations with a few people about that and these conversations took place over the course of a few hours. ilb\(7)/C\ Isaid that the Shift Manger's crew also asked that same question.

ilbll7}1C\ I recalled interacting with the Shift Manager and the Unit Supervisor that day (Exhibit T-21d).

!lblU}/Cl I said that on November 11 , 2015, !rblm/Cl I and !/blmrc1 I both were involved in the decision and both knew exactly what was going on. lrbJ/7)/C) Istated that both ilb)(Z)/C) I and !rbl/7}/Cl I were in favor of removing the RHR system. ilbl/71/C\ Isaid that he spoke to ilbl(7)/Cl I about it and his crew, but the idea was not !/bl(7)1C\ I idea. !/bl/7l1Cl Iwas asked if ilb\171/C\ I told !/bl(7)1Cl Ito instruct !lbl/7}/C} I to take the action. ilbl(l)IC} Isaid that !rbl/7}1Cl I did not tell !/b\/71/C\ I to tell !lb\17}/C} I to do it. !lb\17}/Cl I said it came about after the conversations in the OCC after which the OCC came to the conclusion to do it and ilb}(l)IC\ Icommunicated that to ilbl/7}1C} I ilb\/7llC} Istated that he !(b)(7)(C) Iwent to the control room and told !/bl[7\IC\ I that "this is the path that we would like to go down because we feel it is appropriate" (Exhibit T-21 d).

Interview of l(b)(?)(C)

!(b)(7)(C) l at WBN was interviewed on May 26, 2016, by TVA OIG wherein he provided the following information in substance.

!lb}/71/C} I was hired by TVA in j(b)(7)(C) ~ ilb\(7)/C\ I advised that he worked l(b)(?)(C) I (b)(?)(C)

(b)(7)(C) J(Exhibit T-33) .

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 67 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION During the interview !lb}/7}/C} I was asked about an offsite meeting prior to the re-fueling outage in October 2015, !lbl/7}/C) I recalled said there were over a hundred people at the meeting contends that WBN was notorious for not following previous outage schedules. He had not even been in an outage at WBN before and he knew people did not want to work on a schedule. !lb}CZ}(Cl I stated that he had never heard the term "pocket veto" until he got to TVA. !(bl/71/C} I testified that he first heard the term, "pocket veto" while working in the OCC in July 2015. At the offsite meeting, l/bl/7}(C} I believes it was !lbl/71/Cl I who said it in the context of we (TVA) were going to follow the schedule and there are "no pocket vetoes." !lbl(7}/Cl I stated that pocket veto meant a group of people determining they were not going to follow the schedule (Exhibit T-33).

!lbl(?)/Cl I stated that all this was happening at a period of poor operations where there were some serious mistakes. lrb)(7)!CJ I believes the operator fundamentals were not right and it led to people becoming uncomfortable with a new standard. l/bl(7)/C) I stated that he knows what a good operator is because he was an operator. He stated that the best people are not making these mistakes. !lb}CZ}/Cl I does not have a high opinion of the operators he has seen at WBN.

He described them as on the lower scale (Exhibit T-33).

Interviews of !(b)(7)(C) l(b)(7)(C) l at WBN was interviewed on multiple occasions by TVA OIG, wherein he provided the following information in substance.

(b)(7)(C) advised that he is not a licensed operator. b 7 c was shown an email sent by b 7 c on November 11, 2015 at the conclusion of b 7 c shift in the Control Room . The bod of the email stated ' (b)(7)(C)

......,......,.....__ _ _ _ _ _ _ _ _ _ ____, ..._.........,........_____. rea e emaI o Imse en commented that he had never seen the email before. He said based off the email a CR should have been written that day. !lbl/71/C) I said that he did not know who !lbl(7l/C) I was talking about in the email when he said not to let anyone talk you into removing RHR from service without the normal let down in service. !lb}/71/C} I was asked if he recalled speaking with

!lb}/7l(Cl I on November 11 , 2015. !lbl/7l(C} I could not recall any specific conversations with

!lb}(7l(Cl Ithat day (Exhibit T-00b).

!(b)(7)(C) ~old the agents that being on schedule at a nuclear p1ant is the safest place to be.

He was asked what they do when they get ahead of schedule. !Lb)mrc1 I said that they change or modify: the schedule then. He added that the OCC has critical path scheduling responsibility. l1b]n1c1 I told the agents that the November outage did not go well. He blamed it on complacency on the part of the leadership team. He said they all had a false sense of security:. i(b)/7\(C) I was asked about the pocket veto comment made at the offsite meeting. !lb}/7l1C[ I said he made the comment and !lbl(7}(Cl I did not. !lb}/7}(Cl I said he was "crystal" clear to the group about the comment. He has since heard that some people took the comment the wrong way, but that was not his intent (Exhibit T-00b).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 68 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7)/C\ Itold the group that everyone was going to follow the schedule. He said that they could not have one group doing one thing and another group doing something else. !rb\{7\[C\

wanted to remove barriers preventing them from having a successful outage. He also said that he never asked anyone to leave. He told the agents that nobody from ECP asked him about the pocket veto comment. He added that his ECP interview for the Phase 2 portion of the ECP investi ation was not much of an interview. The man who interviewed him just asked b7c to comment on the Phase 1 results. i{b)[7){C\ I said that the guy who interviewed him was a former detective. !lbl/7\{Cl I remembered the guy telling !fbl{7)/Cl I that he was not going to ask him any questions. !/bl{7)/Ql I said the senior leadership team at Watts Bar met on more than one occasion. They came up with a formula (Performance= Behavior +

Results . !(b\(7)(CJ I said that it was not an initiative that WBN came up with on their own.

b c  !(b)(7)(C) I and !lb)[ZKQ) I were all on board. !/b)U)CQ) I added that WBN's performance just was not where it needed to be. They were lagging in many areas and towards the bottom quartile in most measures. !lb)f7)/Cl I said that the lagging performance was a concern because Unit 2 was coming online (Exhibit T-00b).

With re ard to !(b)(7)(C) l on January 11 , 2016, !lb\/7HC\ Iwas asked if he got mad at (b)(7)(C) and had him removed from watch standing. l!bl(Z}/Ql I said that he did not get mad and had im removed from watch standing. !lbl/71/Cl I was asked if !lb)/7\/Cl Ithought being removed from watch standing was an adverse employment action. !lbl/71/Cl I said he did not think it was. !lb}l?)(Q} I continued by saying that !lb}mrc, I was working in December of 2015 when a relief valve was lifted. !lb)/7\ICL ] said that when the event took place both !lbl/7\/C\ I and the OAC d(b)(7)(C)  !) were removed from watch standing (Exhibit T-00c).

The decision to remove !fbl/7HC) I from watch back in December 2015, was made b (b)(7)(C) ifbl!7\/C} I It was made pending an investigation into the incident. According to .._b...,7........,.c_____.

!fbl{7)/C\ Iwas on leave when the event happened. !lbl/7}/C\ Itold !lb\{7)/C\ I that both men had been removed from watch standing and were to be remediated. !lb\(7)/C\ I said that

![blf7)/Cl I returned !lblf7)/C\ Ito watch, but not ifb\{7)/Cl I !fb}f7)/C) Ireturned from leave and told !rb)(7)fCl Ithat neither !rb)/71/C) I or !(bl{7){C\ I had been remediated. ifb)[7\{Cl I told

!lbl{7){C) Ito find out why and what we needed to do (Exhibit T-00c).

!ibJf7)fC\ Icame back to !ibJ!7\fCl I and told !fblf7)fC\ I that !!blf7)/C} Italked to

!(bl/7\fCl I l1b){7)/C\ Isaid that both men needed to be remediated. !rb\/7)/Ql Isaid that both men were responsible. !lb\(7)/Q\ I said that the three-way communication in the control room could have been better. l(b)(7)(C) I according to l(b)(7)(C) I must not have seen to it that !!b\{7}!C\ Iand !(b\/7)/C) I were remediated. On Januar 11 2016 b said he was at home when he got a call from the (b)(7)(C) told !lb}W<Ql I that "ops" was not moving the plant and they were falling back on schedule. b 7 c said that this type of phone call is common. He is supposed to be kept in the loop. ifb\!7l{Cl Isaid that the night crew was supposed to start a reactor coolant pump. !(b\(7)/C) Icontinued by saying that !(b)(7)(C) !was the Shift Manager.l(b)(7)(C) !said he did not feel comfortable moving the plant with the staff at hand (Exhibit T-00c).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 69 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION ilbl/7}/C\ I said that around 0100 on January 12, 2016, !(b)(i'.)!Cl Il<bl/7\/C I and ._(b...,J({

..,..l...,

(C,,..

l ..,.,..__,,

spoke on the p hone. Durin the call. !(b)(7)(C) l

!challenged fib}m1c1 l(bl/7)/C) Itold (b)(?)(C) to sto . ilb\(7)/Cl I told (b)({)(C) that the Shift Managers makes the call. told (bl(7HCl that !(b\(7)/Cl Isupported the decision. When that call ended, ilbl(7\(C\ Icalled (b)({)(C) and coached him on CHALLENGING the Shift Manager. !lb117l[Cl I told the agents that (b)({)(C) should not have done that to i!bl/7\/C) I lrb)(7)fC) I then called i!b)(7)!C) I

~::!!:::::!:==l congratulated lrw1uc) I for not moving the plant forward. It was during this call that

.......,..........,_.....l learned that !rb\/7l/C\ l was watch standing (Exhibit T-00c}.

!lbl/7\(Cl I hung up with !(bl'7HC I and talked immediately with both !lbl{l)/C} Iand .... llb"'"'\17...,ll....

Cl_ ___,

llbl/7\/Cl Iwas not clear to the agents if he talked to each man separately or did the three have a conference call. ilb}U}IC} Iasked both men if i!b}U)(Cl I had been remediated.

!lbll7l/Cl I told the agents that lrbll7l(Cl Iand lrbl(7)/Cl I did not know if he had been remediated. l/bl/7l(Cl Ithen told them that l/b\(7}/C\ I needed to be removed from watch.

The next (b)({)(C) or !rbll7l(Cl Italked to !rblf7l/Cl Iand explained to ilb}(?){Cl Ithat it was their fau t Ex 1bit T-0Oc.

Interview of !(b)({)(C)

!(b)({)(C) lat WBN was interviewed by 0 1and TVA OIG on May 16, 2017, wherein she provided the following information in substance.

In discussing whit ilb)U)IC) I did not engage in the adverse action process as required by TVA rnrocedures. !(b)(7)_C) ,! hlrfiv:di d that it was more the philosophy around his thoughts.

_bl!?l/Cl Istated that b 7 c would review and question the situation. llbl(7}/Cl I stated for some reason ifbl(D(Cl I had a philosophy debate about the program not signing the action (Exhibit T-30, pp. 16-17).

Interview ofi(b)({)(C)

(b)({)(C) was interviewed by TVA OIG on July 14, 2016, wherein he provided the following information in substance.

b7c is convinced based on what he heard throut the interviews that management took l~b)(7lfC) !off watch for raising a safety concern. b){?)(C\ I stated the event for which I b1(7l Cl j was alleITTedly removed took place three weeks prior to when he was actuallt taken I management had looked into the situation and said that bl/7}/C\ I off. According to j})(7)(C) had done a fine tb and the fault was with the reactor operator. kwrnc1 weeks later !lbl/7) Cl I is taken off watch which "makes absolutely no sense whatsoever." In I stated that a few addition, !lbl(7}/Cl I thinks the statement that !lbl/7}/C\ Ij ust forgot to tell anyone that !lbl(7}/C\

was to be taken off is ridiculous. In addition, l1b1mrc1 I stated that SROs are at a premium at WBN right now so there would be no reason take him off three weeks after an event in which he was found to have no fault. llb\(7}/Cl I believes !lb\(7}/Cl Iwas taken off watch that night

,~e, FeR 1-UBUe 01 aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH ltJ 0 1h0tROE , OFFIOE OF ltWESTIOMIOtJO, REOIOtJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 70 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION because he was the main one objecting to them not moving forward with the crew on site.

llbl(l)(Cl I believes that management perceived llbl(7)(Cl I as the roadblock to keeping the Shift Manager, !(b)(?)(C) I from agreeing to do it. !fb}U)!C} I stated it was a Unit 2 sweep and vent which is nothing more than a test which could have been done later. llbl(7}!Cl I stated that in their interviews, both llb){l)/C) I;:incl llbl(7}(C) I used the exact same words satiin~ "we wanted to rotec (bl(7l(Cl rom making another mistake. It appeared obvious to Ir m l Ithat llb}{7)/Cl 7 and b 7 c had rehearsed their stories (Exhibit T-29).

!!b}!7}!C\ I believes that management will continue to stand by their story that !rb)U}fC\ I was removed due to the earlier incident because they are still in protection Mode. He stated that what happened to llbl(Z)/Ql I is "serious l&H (Intimidation and Harassment)" and it would be really bad if the NRC believed someone was retaliated against and faced an adverse action for raising a safet concern. He stated that TVA will not admit they violated the code of re~ulations and (/b)(7}/C} 1

_ removal from watch would be considered an adverse action by TVA. l!b_?l!Cl I stated that they did interview llbl(7}/Cl I about this incident and it was obvious that he had been told what had happened before he met with the ECP investigators. llbl(7}/Cl I believes that llb}{7)/Cl I is the motivator behind some of the irrational decisions and made it very hard to not go off the schedule. !lbl!7\!Cl I stated that the "operators told us time and time again that meeting schedule was more important than safety (Exhibit T-29).

Interview of!(b)(?)(C) l(b)(?)(C) I was interviewed by TVA OIG on May 20, 2016, wherein he provided the following information in substance.

I l(b)(?)(C) has been involved io the nuclear power industry siocellblf7l/Cl l(b)(?)(C)

I I

He has done consulting work at numerous nuclear plants across the United States. His area of expertise centers on safety culture and safety conscious work environment (Exhibit T-77).

(b)(7)(C) told the investigator that TVA never thought that they would get a Chilled Letter. He said t a RC Region II is the most lenient region in the NRC. He said that this is common knowledge in the nuclear industry.fb)l7)(Cl !said that he does not think that TVA has any special connection or relationship with anyone at the NRC. He said that TVA has gotten by this far because Region II is so lenient (Exhibit T-77).

I l(b)(7)(C) said that !lb)(?l/Cl I is arrogant.~ said that the nuclear industry is small. He said TVA knew what they were getting when they hired llbl/7}(C} I (Exhibit T-77).

I I l(b)(7)(C) then said that he recalled that !(b)(7)(C) toldl(bJ(7)(Cl labout how the site treated (b)(?)(C after he I

made a safety related decision not to move the plant. !(b)(7)(C tol tbJ(7Jtci hat (b)(7)(C went to I I

!(b)(7)(C) after !lb){7)(C) had been removed from watch and told (b)(7)(C) that many eo le on the site think the site onl removed (bl(7l<C> because (bl(7l(Cl raised a safety concern (bl(7)(Ci hen I

went back to (b)(?)(C) and asked (b)(7)(C) if (b)(7)(C came to !(b)(7)(C) and told (b)(7)(C) that many on the site think the site removed (b)(7)(C from watch because he raised a safety concern.

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 71 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ITiwfl r )(?)(C). ~.,.,..,...... (b)(7)

I

!(b)(7)(C) confirmed to~ that did 1 tell !(b)(7)(C) I that (C) then asked (b)(7)(C) what he I

and the site did after they were told this information by !(b)(7)(C) !(b)(7)(C) ! told (b)(7) that they did not do anything (Exhibit T-77).

l(b)(7)(C) !was asked if TVA wanted ~ o fix their problem. He said that TVA wanted to fix it themselves. He said that TVA was working on "their fix" while l~br) land !{b)(7)(C) were still doing I interviews (Exhibit T-77). C Interview of l(b)(?)(C) l(b)(7)(C) !for TVA, was interviewed by TVA OIG on September 04, 2018, wherein he provided the following information in substance.

!first became awa e of the RHR issue at WBN wh: n he rece*Ived a call around ~

~::::.~::from (b)(7)(C) According to !(b)(7)(C) I ~b)(7)(C) _said that he

~~---,.......J and b 7 c were having a conference call with the NRC at l(b)(7)(C) !that bout the RHR issue at WBN and he needed ![b)(7)/Cl I to contact the lant to find out

-w..,_a,..,...a...a happened. !lbl[7l[Cl I then called the plant and talked to (b)(?)(C) and a few other ~eople (names unknown). ilb\(7)/Cl I stated that what struck him when he called

![b)/7}rct I about the RHR issue was that" ou could feel the hesitation" and it was like "oh shit." !lbl/71/Cl Ithen proceeded to b7c the technical aspects and about how the (b)(7)(C) workers didn't do it and th (b)(7)(C) got talked into moving ahead on excess letdown ot go well (Exhibit T-78).

lrbJWCQl I eventually came to understand that on 11 /11 /15 there was a lot of disagreement on when normal letdown would be back. The (b)(?)(C) crew came on and "thef talked the crew into moving forward on excess letdown. en as ed who "they" were, !lb}(7_Cl Istated the management team who at that time was "very pushy about getting things done." ilb}(7}CQl I further stated that if an o erator wasn't fast enough then he would be replaced with someone else. According to b 7 c he was aware of all this because the operators at the plant told him what was going on. II.M.lwu..>.l..__...1 stated that the operators felt like if they didn't do the heat up on 11 /11 /15 then they would be retaliated against. According to !(b)(7)(C) I "it got a little extreme at WBN" and usually management will push but not that much (Exhibit T-78).

!rb1mrc1 I I believes the l(b)(?)(C) did the right thing by not goinf forward but that the !(b)(7)(C) on 11 /11 /15 was either pushed or made to believe it was ok. ![bl()[Cl I is not surprised that none of the operators were disciplined because it was not their decision and they were made to do it. Regardless, it was not a conservative decision either way whether the operators decided to go forward or got talked into it ilbl/7)/C\ I discussed that the OCC can "highly recommend ,

push, influence, kick" but they cannot direct or make an operator do something. It is ok for the OCC to provide technical information to the Shift Manager so they can decide what to do but it is wrong for the OCC to mislead a Shift Manager (Exhibit T-78).

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 72 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Agent's Analysis In summary, 01 determined that the events surrounding the control of plant operations at WBN indicates that licensee management established a work environment, and reinforced a mindset among licensed operators, whereby raising concerns about or opposing WBN senior management's direction regarding plant operating schedules was unacceptable. This positioned WBN senior managers either directly or through the Outage Control Center (OCC),

as the de facto directors of the licensed activities of the licensed control room operators.

The use of disciplinary and other adverse actions affected the mindset and actions of the Reactor Operators and the Senior Reactor Operators. This included the assigning or reassigning of operations staff duties and positions based on their willingness to yield to and or support OCC/management direction. Intimidation suppressed the questioning of the authority and direction of WB management by the Reactor Operators and the Senior Reactor Operators.

These actions facilitated WBN senior management usurping the authority of Senior Reactor Operators responsible for directing the licensed activities of licensed operators, effectively performing the function of an operator and a senior operator contrary to 10 C.F.R. § 55.3.

OFFS/TE MEETING On September 4, 2015, !rb}(7}<C} I and !/b)(7)/Cl Iexhibited intimidating behaviors during a pre-outage meeting held off-site from Watts Bar. The audience for this 1/b~~~~( !included Senior Reactor O~erators (SROs) working at WBN1 and was presided over by and

!/bl(l)/C} sharing primary speaking rolls. The purpose of this meeting was to prepare for a scheduled re-fueling outaae that was set to occur in October 2015. Accounts vary as to which speaker, (b)(7)(C) or !(b)(l)(C) I specifically voiced each statement but it was clear that they were presen mg Jointly. During the beginning of the meeting either !lb}/7}/C} I or !rb)/7}(Cl I made the statement to the effect that if you do not think we [WB] can complete the outage in 30 days you can leave now because they did not want you on their team. This was received by some operators to mean you can leave the company not j ust the meeting or potentially suffer some repercussions for speaking out against management (Exhibit T-32)(T-09)(T- 11 )(T-12)(T-73).

During the same meeting, it was reported that !/b)/7)/Ql I and !/b}(l)IC} Ifurther intimidated those present which caused the SROs to believe that retaliatory r ersonnel actions were likely if the SROs resisted the instructions of!/b)[7)/Cl I and !lbl/7}/Cl  !/b)l7)/C} I and !rb)/7}/Cl I told the SROs that their decisions would be driven by the schedule they were given and that they would not have the authority to "veto" scheduled plant activities. Testimonial evidence indicates that the intent of the "No More Pocket Veto" discussion was to limit the authority for decision making of the licensed control room operators as it related to plant operations and transfer it to the OCC/Management under the banner of "following the schedule." This was echoed in ECP Report NEC-16-00047/127. When discussing this issue, !/bl/7)/Cl I described his interpretation of a 'pocket veto' in that 'pocket veto' meant a group of people determining they were not going to follow the schedule (Exhibit A 1-E1 )(Exhibit T-9)(Exhibit T-10)(Exhibit T-11)(Exhibit T-12)

(Exhibit T-34a)(Exhibit T-32}(Exhibit T-35)(Exhibit T-00b)(Exhibit T-33).

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 73 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION REMOVAL OF !ib)(l\lC) i AS UNIT SUPERVISOR On October 19, 2015, the Shift Manager, l(bl(7l(Cl l with the consent of the (b)(?)(C)

!(b)(7)(C) I removed the WBN 1 Unit Supervisor (b)(7)(C) from his ~osition because he, "was just not pushing hard enough." This action was taken after l/b}/[Cl I refused to conduct parallel tasks that would add two forms of reactivity to the reactor at once. Hb){Z)/C} I described that everyone in the OCC and in the management chain was frustrated about the delayed rod testing because it was a critical path activity.

l/b}/7}/C} I was replaced by l/b\(7)/C} I who stated that he was not aware that on the day that l/b}/7}/C} I was removed that he (b)(?)(C) was being asked to do the Terry Turbine test as well as move the rods at the same time. (b)(?)(C) stated that you cannot do those two activities at the same time and !(b)(7)(C) Iwould have expected l/b}/7}/Cl Ito stop. Other operators viewed the replacement as a response for not pushing hard enough and pushing back against performing the two operations simultaneously (Exhibit T-05)(T-28)(T-36)

(T-02b, pp. 35-36)(T-25a).

USE OF THE SBMFP DURING STARTUP (See Allegation 2 for additional details)

On October 21, 2015, Shift Managed(b)(?)(C) L with the assistance of b 7 c l(b)(7)(C) !directed Reactor Operator (b)(7)(C) to improperly use the Standby Main Feed-water Pump (SBMFP) instead of the procedurally required Auxiliary Feed-water (AFW) Pump during the reactor startup from Mode 3 to Mode 2 . This was done to enable engineering to perform missed testing and inspections of Feed-water valves in containment without delaying plant start-up. l/bl/7}/Cl Itestified that he initially refused and exw essed to (b)(7)(C) it was not safe to perform the reactor startup using the SBMFP.

l/b}) l/C} Irespon e t at Operations will not be the hold-up of the outage and we will not delay the startup. When challenged about the safety component, l/bl/7l/C} I responded, "We are going to be careful." Fearing that if he did not agree to proceed they would have been replaced and label as not a team player, l/bl/7}(C} I proceeded as directed (Exhibit T-15a)

(ExhibitT-15b, p. 7, pp. 11-24).

The performance of the feed water test/inspection at this point in the reactor start-u~ re uired a lower containment entry while the plant was in Mode 2 . Radiation protection tech Ir mu I 6 voiced worker safety concerns about the performance of the associated testing and inspection to the OCC during a reactor startup because it was normally performed in Mode 5. After becoming adamant and animated about his concerns, l(b)(?)(C) Ihad (b)(7)(C) removed from the site by security. Following the event l/b}/7}/Cl I had members oft e present write statements concerning what happened (Exhibit A 1-E2).

DRAWING THE BUBBLE (See Allegation 3 for additional details)

During the forced outage in November 2015, WBN management took additional actions to reinforce/exercise their control over the licensed operators. To that end, on November 9, 2015, WBN1 was performing a plant start-up using 1-GO-1 following a forced outage. The plant was

,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 74 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 01 INVESTIGATION INFORMATION unable to "draw a bubble" in the pressurizer due to a procedr ral restriction on required plant temperature. As reported, Unit Supervisor l(b)(?)(C) refused to draw the bubble in the pressurizer with the current lant conditions after bein re uested to do so by the OCC.

In response, (b)(?)(C) directed one of his subordinate procedure writers ( b 7 c ) to initiate an improper change to plant operating procedure 1-GO-1 to remove the restriction and compel the operators to continue with the scheduled plant activities (drawing a bubble in the pressurizert When concerns were raised by the operators about the validity of the procedure change, SM l b)(!)/Cl I responded , "The people who fire people with licenses said to do it." This demonstrates that final decision making was being based outside the control of the licensed operators (Exhibit T-01 c)

(Exhibit T-05a)(Exhibit T-05b ).

It was reported that the next day followin~ the delays from not proceeding with drawing the bubble prior to the procedure change, l(b\)}IC} I called a crew meeting where he berated the crew and told them, "They were not pushing hard enoufrh on this outage to move the plant forward and were weak." This was reportedly after lrbl/7 Cl I received a scolding from the llbl{7}/Cl Ithe day prior on the same topic (Exhibit T-05b)(Exhibit T-23b).

EVENTS OF NOVEMBER 11, 2015 (See Allegation 4 for additional details)

On November 11, 2015, WBN management demonstrated their control when they compelled SM llbl(?)/C} I to instruct the licensed operators to continue start-up activities of 1-GO-1 after transition of the plant to Mode 4 without normal let-down iin service. The licensed operators watch standing for Unit 1 indicated they did not agree with the decision because it would require the removal of the RHR system from service and it was providing both inventory and

~ ture control for the RCS. The evidence shows that with the endorsement of both lllil!ZllilJ and !(b)(7)(C)  ! llbl(7)/Cl Icompelled llbll7l{Cl Ito direct the RHR system removed from service against the judgement and concerns of the control room operators. RHR was subsequently taken out of service to perform 1-Sl-0-905 (Primary Pressure Boundary Isolation Valve Leak Test Residual Heat Removal Return Valves). Due to charging and increases in RCS temperature without RHR in service, PZR level began to rise uncontrollably. Operator attempts to control temperature were unsuccessful which resulted in the level in the pressurizer (PZR) rising to 80 percent at which time the operators took actions outside of procedural requirements to stop the level increase (Exhibit T-22b)(Exhibit T-22c)(Exhibit T-22d}

(Exhibit T-22e)(Exhibit T-21a}(Exhibit T-21c)(Exhibit T-21d}(Exhibit T-21d)(Exhibit T-33)

(Exhibit T-00a, pp. 12-16, pp. 31-33)(Exhibit T-00b).

SOD/SOM CHECKLIST On November 11 , 2015, ilb\(7)/C) I sent multiple e-mails displaying his expectations that management in the OCC would be controlling plant operations. This was specifically aimed to solidify his involvement and management's control over plant operations even after the loss of control of pressurizer level event.

,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY 01 INVESTIGATION INFORMATION 75 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION o E-mail to the (b)(7)(C) occ requesting ~~---~

them to send status (Exhibit A 1-E3).

.......---~-- and management members of the detailed hourly status updates on plant o E-mail to the !(b)(7)(C) Icontaining the SOD/SOM Checklist.

i!bl(Z)/Cl I sent the SOD/SOM Checklist to OCC managers effectively implementing the process. This checklist required OCC Directors/Managers to review various aspects of the plant situation including two which showcase his proclivities for the roll of the OCC in plant operations (Exhibit A 1-E4)

(Exhibit A1-E5):

• 1) ARE YOU DRIVING OR RIDING?

• 2) ARE YOU IN CONTROL?

0

,.__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (Exhibit A1 -E6)

UNIT SUPERVISOR REMOVED FROM WA TCHSTANDING DUTIES Unit Supervisor!(b)(7)(C) lwas removed from watch standing duties following a January 11, 2016, incident where he pushed back against performini a §lant operation he felt the crew was not pro erl staffed to perform. On January 11, 2016, . bll7 _Cl I raised concerns to his Shift Manager (b (7) C) when he decided not to perform a scheduled plant o eration (sweeps and vents he believed the crew was not ro erl re ared to erform. b 7 c informed the (b)(7)(C) and (b)(7)(C) on a teleconference where .................... replied with what has been quoted by others as "Do not give me any of that nuclear safety bullshit." When discuss communication on the night of January 11 , 2016, !/b)(7)(Cl Icould not recall !/b)(7\!C1 Isaying "do not give me any of that nuclear safety bullshit." However, he does recall i/b)(7)!C} I using inappropriate language and telling l(b)(7)(C) I something to the effect that basicall~ he was a "chickenshit" for not moving forward.

!/bl(7)/C} Ion the direction of !(b)(7)(C I directed the removal of !lbl(7l!Cl Ifrom watch standing duties under the auspices of a previous uncompleted remediation (T-21a, b, c, d)(Exhibit T-27a, b, c, d).

Management's stated reasoning for ilblf7)(C} I removal was the unplanned lifting of a Unit 2 PORV during an evolution he supervised on December 19, 2015, (almost a month prior) even though the other operator involved in the PORV lift was removed from watch standing immediately following the incident pending upgrade. Additionally, a formal observation was being conducted during the evolution found no fault on the part of !lb\/7)/Cl I (Exhibit A 1-E?).

ilb)U)/Cl I I said the decision to remove !(b)(7)(C) from watch standing duties, was made by him. During the discussion about the shift not wanting to perform swee~? and vents, !!b\(7)/Cl stated he sent an email about the crew composition (at 9:47 p.m.) to i(bl }fCl I and immediately called !!bl(7}!Cl I During that call, !lbl/7}(Cl I and ilbl/7}(Cl Idiscussed that

!/bl/7\/Cl Iwas on the crew working as the Unit Supervisor. !!bl(l)!Cl Itold i!b\{7)/Cl Ito "move

,~e, 1-eR 1-uBue 01aeteauREw1T1 1eu, >'<flflRe'~'>'<t e1-SPECIAL AOEPH IPJ Cl lii!ROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 76 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION him." !lbl/7\/C} Icontacted !lbl/7\!Cl Iand informed him that !fbl/7\/Cl I was being taken off watch. lrbl{?)/Cl Iresponded that he did not agree with the action because too much time had rnone by. !lb){Z)!C) Iintimated to !(b\(7\(C) Ithat the decision was not !(b)(?)(C) I but

_bl/7\/Cl I !ibl/7l(Cl I said that they could not leave him in there to make an error.

!lbl/?l/C} Istated he called Hbl(l)/C I and instructed him to tell !lbl/7l(Cl Ithat he was being "removed from watch standinf because of the events on December 19, 2015, when the PORV lift occurred but never told lrt>lIC} I which caused !(b}/7}/Cl I to continue to stand watch (Exhibit T-00B)(T-21a, b, c, d). Manar ement's stated reasoning strains credulity by the follow-u~ actions of TVA managers. !lb}(7}(f Istated that !/bl/7}/C} I and he did not know !rb}(7}(Ql objected and he was removed many hours after the~ had decided not to move the ~lant. In a previous interview during the ECP investigation !rb)j}(C} I stated that after !(bl/7}(C I was removed from watch standing, !lbl/7l/Cl Icontacted the Shift Manager (b)(?)(C) a ain and asked him to move forward, however the Shift Manager still refused and b had to call !rb}/7\!Ql I back and tell him that the Shift Manager still would not move forward (Exhibit T-29)(T-21a, b, c, d). Additionally, !(b)(?)(C) I the investigator ] erforming the ECP investigation concerning the work environment at Watts Bar, believed that I blf7l/C} I was removed from his watch for raising a safety concern and what happened to !lbl/7}/Ql I was a serious intimidation and harassment issue (Exhibit T-29). Various operators took the events as an indication of how you will be treated if you fail to deliver on OGG/Management's requests: SRO l(b)(?)(C) !advised that an SRO was recently disqualified, and the operators believe it is for om a ainst management. This happened around this past Christmas (2015). (b)(7)(C) had been the SRO on Unit 2 when they lifted a relief valve. He was not disqualified after this incident and instead continued working doing the same duties for three more weeks when one night he told management that he did not believe he could safely execute a scheduled activity they wanted done on Unit 2 and they needed to wait. Two hours later, !lb)U)/Cl I was told he was relieved of his post and was being dis ualified because of the incident which happened three weeks ago. Accordin to E b7 c the message that the other operators got from this happening was !lb}(?l_Q} 1 I pushed back against management and got disqualified (Exhibit T-05a). SRO l,wnrc1 I discussed during her interview that !rb}f?l!C} I then began listing out the events that had happened from October to now in the control room and stated that the o erators needed to get back to the fundamentals . !lb}/7}/C} I then told the story of (b)(?)(C) who was a Shift Manager when !lb1m1c1 I had been a !(b)(?)(C) I (b)(7)(C) and he !(b)(?)(C) I went on to tell a stoti about how he learned how important and powerful the Shift Manager is. !lb}f7Hf I then stated that they would stand behind Operations and if you say no then we'll say no. !!b}ffi!C} I stated that this did not really go over well after what had happened two nights ago with !lbl(7l(C} I

                         ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 77 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Likewise, !lbl/71/Cl Icomments at the meeting came across as false because it was a total change over from the way things normally went so it did not seem sincere (Exhibit T-28). SRO !lbl/71/C) I rliscussed during his interview that SRO !(b)(7)(C) Itold management he could not do a required action on the reactor coolant pump (RCP) because he did not have enough trained people. Management backed off but the very next (b)(7)(C) was disqualified for a previous event that had happened over three weeks ago. ........................ believes he was being punished for not doing what management wanted on the RCP (Exhibit T-70). SRO was asked why he thought lrblW[Ql I had been removed from watch. (b)(7)(C) said that to him it was a messa e "to et on board or we will get you out of the way". (b)(7)(C) blamed !lbl/7)/Cl I (b)(7)(C) said nobody in Operations will stand up to """"'"""""""'------' The message to Operations is to get on the team or else (Exhibit T-71). SRO stated he has heard that a Unit Supervisor was taken off watch by the (b)(?)(C) for raising a concern, but it was sa1id it was for something (a lifted valve) that had happened three weeks before. !rb}/7\[C} Ifeels that what happened to this operator is "total bullshit" and "they sent a message to the entire operations department

     - cross me." !lb)l7HCl              Istated that he has never seen anyone disqualified weeks after an event. Rather, an operator would be taken off the day of or the day_ after the event.

They would then be promptly remediated and returned . According to Ubl(7)(C) I once the operator was allowed to assume watch the next week he had already made too many operational decisions to take him off watch. He stated "it is a crock of shit" if management comes back and says what happened to the operator that was disqualified was considered coaching and is covered under the CR (Exhibit T-69). SRO ilbl/7l/Cl I said that after ilbl/7l/Cl I was removed from watch . _!/b. . _l7/..,.)/.... Cl____..... told llb)/71/Cl Ithat the !lb)/71/Cl Ithing sent the wrong public relations message to the troops. ilb\[7)/C\ I :=igreed. !rb}[Zl[C\ I does not think i[b}U}/Q\ I style of leadership works at WBN. ilbll7l/Cl I is a bully. He tries to use his physical size and loud voice to get what he wants (Exhibit T-13b). RO !lbl/71/Cl I was asked why ilbl{7)/Cl I was removed from watch weeks later rather than the same day as !lbl/71/Cl I was removed from watch. !lbl(l)/Cl I said that was obvious. The perception from people in the control room is that ![b\!7\/C} I pushed back and was magically disqualified (Exhibit T-72). SM ilb}!7\IC\ I ::isked if he was goinri to be removed from watch. lrb\/7)(C} I said to b7c nothing at this time. !lb)l[<C) Ialso asked the same question to !lb)l?HC) I about c He was told basically the same thing fnothing at this tir~\1 \(b)l\/Cl I was asked why people would be intimidated. i/bl/7)/Cl replied that the b 7 C incident is just one example (Exhibit T-34a).

                  ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY             OI INVESTIGATION INFORMATION 78 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION US !(b1{71fC1 Iexplained that !(b1(7)/Cl I explained to a group of operators that !lbl(7l{C) was supposed to have been removed from watch weeks earlier than he was but was not due to a communications error. !(bl(7}(C) I stated he was caught by surprise when he called the Shift Manager to tell him good job for stopping the evolution. The Shift Manager told llb}fZ\!Q} I that it was not him but it was (b)(7)(C) then stated wait a minute I thought he was removed from watc standing. (b)(7)(C) confirmed to the agents that !(b)(7}/Cl I said it was a conversation between him and the Shift Mana er when lrbJUJIQl I first became aware of llb}UJIQ} I involvement and that he (b)(7)(C) was still watch standing. !(bl(7l(Cl Ithen said that he contacted b 7 and !/bl(l)(Cl Ito have them remove lrblmrc} Ifrom watch. ..,.!tb"""lr7"'"1r"c.",. . 1- ..... told the SROs that he realized they had a communication error once he realized that

           !rb)(7)/Cl I was still watch standing. !(bl[7)(Cl             I told the group of SRO's that !lb)(?lfC) was sur rised that !/b)(7lfCl I was watch standing that night. The agents asked (b)(?)(C)      what his impressions were of the story given to the SRO's by ..,.!lb-lf7__){_Cl-----.
           ,___ __. said that he knew that b c                          was telling the SRO's what the "story is going to be" about that particular incident. (b)(?)(C)                 knew that it did not add up because how on earth would llb\(7)/C}                 I no ave nown l(b}(Z)/Ql I had been watch standing for three weeks? !(bl/7)/Cl             I is the Plant Manager and that is his job (Exhibit T-68).

l(b){7)(Cl IFAILURE TO FOLL ow CONFIRMATORY ORDER Review of EA-17-022 CONFIRMATORY ORDER (ML17208A647) was in line with the actions examined during the 0 1investigation. This was issued to TVA (Jul 21, 2017) based on the failure of WBN to implement actions designed to protect employees that raise safety issues and ensure an environment conducive to raising concerns is maintained. The motivating violation which resulted in the ORDER documented that from November 2014 to August 2016, !(b)(?)(C)  ! !(b)(?)(C) l disregarded the requirements of NRC Confirmatory Order Modifying License, (EA-09-009,203) dated December 22, 2009, (ML093510993) by not fully implementing TVA's Adverse Employment Action Procedure. SP.ecificall ro ram re uirements including those designated as the specific responsibility of (b)(?)(C) were not carried out. T his procedure was put in place to ensure adverse emp oymen ac ions comport to employee protection regulations and actions are taken to prevent any potentially chilling effect they might have on the workforce (Exhibit A1-E8)(Exhibit A1 -E9)(Exhibit A1-E10, p. 8, pp. 22-29). !(b)(?)(C) ltNTIMIDA TION OF SRO i(b)(?)(C) To give the agents an example of management pressure in the Control Room, SM lrbl(7)/Cl I told of an incident that happened after the re-fueling outage when they had work that had to be done on equipment that was located in containment. The personnel felt like the Work Orders had not been reviewed. The work could not be done until we reviewed the Work Orders (Exhibit T-34a). lrb){7l(Cl Itold !(bl(7l[Cl I that they (Control before doing the work. !lbl(7}/Cl ti~~~) I wanted b 7 c 1 ere going to review the Work Orders to "keep moving." They were not going to

                         ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 79 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION keep moving until the Work Orders were reviewed. It was done for plant safety. !lb)(7)/C) I gave the Work Orders to (b)(7)(C) a licensed SRO. She was workin in the Control Room at the time. b 7) c !lb)(l)(Cl I 12...l.... ac ....e._d..,.. rbl_ C_ l -r-o_u_t _o_ f t_h_e_w_a_y_i_n -th_e_C _o_n_t_ro_l __ R_o_o_m_, _s_ o _s-h-e c-ou_l_d _d_o_th_e_ W _ o_rk---- 0-rd- er review. i(hl<7}(Cl I kept calling the Control Room asking if she was done yet. !{b)!7J<Cl I wanted to know how much longer (Exhibit T-34a). Finally !(b)(7)(C) I came into the Control Room and sat in a chair. ilb)(l)/C} Iknew exactly what he was doing. He was pressuring l(b)U}fC) Ito finish the Work Order review l(b)U}fC) I made sure that he moved his position so that he was between !(bl(7)(C) Iand !lb)(7l<Cl I !lbl(7l<Cl I told the agents that management ressure has completely stopped since the [TVA OIG]agents showed up on site. According to b c management now gives them all the time they need (Exhibit T-34a). MGR OPERA TORS LOGGING "BY OCC DIRECTION" sent an emai l to !(b)(7)(C)  ! !(b)(7)(C) I and r::-:-:~~-i-d;:-- is_c_u-s s-:-in_g_ a-re_c_e-n7t 'M

                                                         ;"".;:::                                                I C~R~ an-d~ OCC observation. l1bjf7)/Cl noted that the observation says, 1(b)(7)(C)                                                                                 r* He also pointed out that they were still getting comments that Ops feels like the OCC gets to tell them what to do. He included that while reading the logs Monday that the SRO logged - "!(b)(?)(C)                                                             I"

!(b)(7)(C) !subsequently sent an email to the SMs requesting them to have a discussion with th etr. SROs t o a dd ress th e Ioggmg issue. H ewant e d th em t o d.ISCUSS th at OIoerafions ooerat es the plant. He included the role of the OCC as '1(b)(7)(C) (b)(?)(C) birnrci I"

'bl/7\/Cl           I later replied to llb\(7)/Cl I informing him "l(b)(7)(C)                                                                     I (b)(7)(C)  f' (Exhibit A1-E11) (Exhibit A1-E12) (Exhibit A1-E13)(Exhibit A1-E14).

!(blf7)(C\ I was a former licensed SRO and !(blf7)!C) I held an SRO certification establishing they understood the role and responsibilities of the SRO. 0 1determined that !rb}{7)(Cl and I !(b){7\(C\ I took actions, gave directions, and espoused beliefs that indicated they wanted plant managers to take actions that undermined the independent authority and decision making of the licensed operators in the main control room. In making this determination, 0 1examined the licensee's actions and the resulting effects. The multiple events described above demonstrated senior management wanted more control over the decisions made by licensed operators and there were multiple events where licensed operators received a message that there would be potential consequences for not executing management's decisions/plans. On multiple occasions WBN management influenced the decisions of licensed operators to operate the plant in a manner which the operators initially

                                ,~o, FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L OF SPECIAL AOEPH IPJ 0 1h0tROE , OFFICE OF IIW E!:lTIOMl!:m!:l, liii!:EalOI~ II 6 f'f'le l,-L U9!! 614LY                Of INVESTIGATION INFORMATION 80 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION voiced valid concerns about. The following questions were examined to establish the applicability of the events: Would the responsible licensed operators have made a different decision without CCC/Management interference? In each instance Of determined that without the influence of management the licensed operators would have made a different decision concerning the operation of the plant. Why did licensed operators proceed in the face of their concerns? It became an expectation that if an operator could not prove the operation was prohibited or unsafe then they were expected to proceed. A fear of retaliation was an additional motivating factor. What were potential motivating factors for management? Meeting schedule and saving time were clear motivators in the actions of management. As described in detail above , 01 determined that!(b)!7)(Cl l ~nd lfb}(7)!C) ldeliberately established a mechanism for non-licensed managers to effectively perform the function of a senior operator to direct the licensed activities of licensed operators. Overt acts furthering this ob;ective were: intimidation of operators during the September 2015 offsite leadership meeting; l(bl 7l!Cl I directing the removal of RPT !lbl/D/Cl Ifrom site by security; removal of US l!b)/7)/C\ I from watch during the October 2015 Unit 1 outage; requesting OCC management to verify they were in control as reflected in the use of the SOD/SOM checklist; removal of US l/b)!7l!C l from watch in January 2016; !(b)(7)(C) !failure to use the Adverse Em~loRee Action Program; and l/blf7lfCl I intimidation of SRO !(b)(7)(C) by I pressuring l!b f7l Cl Ito finish a Work Order review. 01 identified events that indicated the environment was clearly having an effect on the actions of operations personnel to include licensed operators. Events include: the use of the standby main feed-water pump during startup; improperly changing of the Unit 1 startup procedure 1-GO-1 to expedite startup; and licensed operators logging that the OCC was directing activities of the MCR operators in December 2015. As defined in 10 CFR 55.4, a senior operator is any individual licensed under Part 55 to manipulate the controls of a facili\b and to direct the licensed activities of licensed operators. 0 1 concludes that the actions of !lb\(7)1 ) I ancl !lb)(7)/C) I deliberately circumvented the requirements of 10 CFR 55.3 which requires that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator. Additionally, the deliberate actions of !!bl!7l/C) l and l/b\/7\fC\ Idirectly impacted the ability of licensed operators and senior operators to carry out their legal duties to operate the plant in I4ef FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1)1(L eF

            ~f!IECIAL AeElff 114 0 1lii!ROE, OFFICE OF IW,'EeTIEs,£\+IO~Ha, ~ liiiC.10~1II 6 f'f'le l,-L U9!! 614LY  O1 INVESTIGATION INFORMATION 81 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - O1 INVESTIGATION INFORMATION accordance with their licenses. By extension, the deliberate actions of !(b}(7}(C} I and !(b}(?)/C} contributed , in part, to additional NRC violations associated with operations of the plant. This was specifically demonstrated by the events and violations that occurred on November 11, 2015. Conclusion allegations in this report, 01 concluded that !lb}l7)(Cl I and !lbl/7\IC} 1 Based on the evidence developed during this investigation, includin additional substantiated deliberately took actions which placed Watts Bar senior managers either directly or through the OCC , as the de facto directors of the licensed activities of the control room operators. This represents a violation of 10 CFR 55.3 which requires that a person must be authorized by a license issued by the Commission to perform the function of an operator or a senior operator which includes directing the licensed activities of licensed operators.

                  ,~e,= FeR fi'UBLl6 Dl96L69URE 'l'VITI ISUT >'<fi'fi'RS'"'>'<L eF OP EGhAtL ;A1GDli l~j GI 1,0,ncc, QFFIQ [ QF I W'  iT I C0TIOWi , ~liiiC.IObl II 6 ffleliltt USE 614LY      O1 INVESTIGATION INFORMATION 82 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 2 During the Unit 1 start-up from 1RFO13 on October 20,2015, the Standby Main Feed-water Pump was used to feed the S/Gs in order to perform a valve PMT in parallel with unit start-up even after the plant was taken into Mode 2. Applicable regulations 10 CFR 50: Appendix B, CR V, Instructions, Procedures, and Drawings 10 CFR 50.59: Changes, tests and experiments 10 CFR 50.5: Deliberate misconduct Documentary Evidence WBN Plant Operating Logs from October 21 , 2015 (Exhibit A2-E1) WBN Plant Dataware from October 21 , 2015 (Exhibit A2-E2) Official record copy of 1-GO-2 Revision 6 used during start-up in October 2015 (Exhibit A2-E3) 3-OT-STG-003A, Revision 12, Main Feed-water System December 21, 2012 (Student Training Guide) (Exhibit A2-E4) Analysis of the Use of the Standby Main Feed Water Pump during start-up (Exhibit A2-E5) Draft Apparent Violation for Use of SBMFP during Unit Startup (Exhibit A2-E6) Testimony Interviews of l(b)(?)(C) IReactor Operator !(b)(7)(C) I RO at WBN, was interviewed on March 07, 2016 and April 16, 2019, by 01 and TVA OIG wherein he provided the following information in substance. At the end of the re-fueling outage in the Fall of 2015, Hb)/71/C) I was working the same night as the Source Range Bypass issue where they went critical (October 20, 2015). That night, !(b}U}/Cl I stated they ran the Unit 1 Standby Main Feed-water Pump (SBMFP) during the reactor startup from Mode 3 to Mode 2. By procedure they should have been using the Aux Feed-water to control steam generator level rather than the Main Feed-water pump. !/b}(7}/C} Istated he was "ok" with the Tech Specs aspect of it but when you do a reactor startup you have to maintain stable temperature (RCS) (Exhibit T-15a)(Exhibit T-15b, pp. 6-8). The Main Feed-water pump is not designed to control steam generator water level during a reactor startup (in the source range). According to !(b)(7)(C) I this situation was not done the right way because there was a PMT (Post Maintenance Test) on feed-water check valves that was supposed to be done in Mode 4 or Mode 5. It kept getting pushed back to be done

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY    OI INVESTIGATION INFORMATION 83 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION later. !lbl/7}/Cl I stated that they could not use the Aux Feed-water because of the PMT. He stated it could have been done in Mode 4 or 5 wjth 1dtra sonics, but they had already taken out scaffolding. !lb)(7)/C} I stated thad (b)(?)(C) Jwas there along with Shift Manager (b)(7)(C) and !(bl(7)(C)  !. Around midshift, !lbll7)1Cl I told

            ......,.......,.___ __. and llbl{7)/Cl      I that the PMT needed to be done now. The PMT could not be done later due to radiation amounts and the PMT had to be done. !lbl/7)/C}                                   I told
            !lbl(7)/Cl           Ithat they could not do this during the reactor startup and !lbl17l/C)                   I said we must.
            !lbl/7)/Cl               I asked why but did not receive a good answer. At this point, !lb\17)/Cl                        Itold ilb}/7}/C\           I that he did not feel safe and that this was not a safe thing to do. i(blUJIQ)                       I said they needed to delay the startup and then do the PMT. According to !(b)(7){C)                                    I
            !lbl/7\/Cl           I refused saying "Ops will not be the hold-u? of this outage" and "we will not delay the startuQ of this outage." When asked about how i!bli7\rC)                           I handled the issue regarding safety, !lbial/Cl                 I stated that llbl/7l/Cl       Isaid, "we're going to be careful. " !lbl/7l/Cl stated that !lb)(?)/Cl I also said they did not need to do it and heard !lbl/7}(Cl                          Ic.omments as well (Exhibit T-15a)(Exhibit T -15b, pp. 9-11 , pp. 22-24 ).

In regard to this situation, !lbH7l/Cl Istated he pushed back as hard as he ever pushed back on anything he had ever done. In response to his push back he was challenl ed to "show me somewhere where it sa~s that we cannot do this procedurally." !/bl/7}/Cl has been (b)(?)(C) ....licensed forD ears. !lbl(7)/C I believes this happened due tojjressure from the OCC. He stated that core nuclear fundamentals were then disregarded by ilb}(7 IC} I He stated that the OCC is in control of the control room when it should be the Shift Manager. llbl/7l/Cl I stated the calls should be made on the o t r ' knowledge, skill, and ex erience but it is not like that now. !/b}(?}(C) I was told b (b)(?)(C) that it was their call (b)(7)(C) and (b)(7)(C) Re ortedly !/bl/7){C I then told !lbl/7\/Cl I that if it went bad then they (b)(?)(C) and (b)(?)(C) would take the blame. !lbl/7l/Cl I stated that he could not believe b c comment because he !(b)(7)(C) Idid not care who took the fall o r who would be the scapegoat if it did not work (Exhibit T-15a)(Exhibit T-15b, p. 12, p. 14,

p. 15, pp. 24-25).

            !lbl/71/Cl               I ended up doing it because he received a direct order from !(b)(7)(C) ~o proceed.

He believes anb oITerator would have agreed with that the should have delayed the startup. !/bl 7\/C_ Istated that he was (b)(7)(C) not the OAC. He stated that if he had said he was not omfl , en they would have gotten someone else. In addition, b}(l)(C} I stated that he would have been labeled as not being a team player. llbll7)/Cl I stated that even now if questioned about this incident management would spin it in a way that will say it was "ok." Because he is part of the union, irb)U}rc1 I is not afraid of management firing him. He stated that the SROs are afraid for their jobs. !rbl(7)/Cl I stated that the management in place now does not want to hear bad news (Exhibit T-15a)(Exhibit T-15b, pp. 21-30).

             !lbl/7}/Cl              I advised that the evolution went forward using the SBMFP and the operators did a good job and were able to control it even though it was not designed that way. He stated that he did not believe they were breaking any rules or commitments to the NRC. When asked what could have happened had they not been able to control it, !lbl/7l/Cl                               I stated that the risk
                                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 84 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION was in over-cooling the RCS and causing a reactivity transient. !(b)(7)(Cl I stated that not everything they do is black and white and at times they operate in the gray area. He further stated that there are not procedures for everything. According to !(b)(7)(C) I the operators are tasked with making judgment calls and are trained to operate the plant safely. That is their number one job (Exhibit T-15a)(Exhibit T-15b, pp. 20-29). Interview of!(b)(?)(C) l(b)(7)(C) !at WBN, was interviewed on July 13, 2017, by TVA OIG wherein he provided the following information in substance. !rb)W(Ql I has been working in the nuclear industry since l(b)(7)(C) !and has worked the majority of career at WBN. He was working as a !(b)(7)(C) jin the fall of 2015 at WBN. Around 0200 hours, he took a phone call from the OCC. The caller was (b (7) C) a RP em~ oyee who was assigned to the OCC to cover the (b)(7)(C) during the outage. (b)(?)(C) told lrb}W } I that the OCC needed RP (along with engineering o make a power entry to ins~ect \ ipinf . The OCC wanted the piping checked for leaks. It was auxiliary feed water piping. IOmrc group was needed to provide coverage for the engineers. The engineers check for leaks and RP handles the RP issue~ ~~ iated with making a power entry. During the telephone call, lrb)(?)(C\ I questi 7 (blf ){C) as to why the OCC wanted the "leak" checked while they were in Mode 1. He told (b)(?)(C) hat the OCC should have inspected the piping in Mode 3. When he asked !lb}WIQ} Iwhat difference it made to check the pipes in Mode 1 versus Mode 3, !lb}WIC\ said that it is much safer to check the piping in Mode 3 rather than Mode 1 (Exhibit T-24 ). lrbl/7\(C\ I added that in Mode 1 the control rods are pulled. Exposure to additional and unnecessary dose is greater in Mode 1 than in Mode 3. l(b}WCC) I told the agents that it was obvious what was going on. The OCC wanted to save 4-'6 hours on the schedule. The OCC put schedule over safety. That is why the OCC wanted power entry made in Mode 1 to check the pipe for leaks rather than Mode 3. llh}WIQ} Iwas not satisfied with his telephone conversation with tbl(7J(Cl The two spoke to one another rofessionally. Neither yelled or used 1 profanity during the call. When the call ended, !ib)(7)fC} _ decided to go to the OCC. He wanted to voice his concern (Exhibit T-24 ). Upon arrivi11~ in the OCC, !lb}/7)/Cj Iwalked to t1e main table. He went there because that is where llb}/7}/C I was located. _(b)(7)(C) _ and !(b)(7)(C) !were beside llb}<Z)(C} !lbl/7\(Q\ I said that others were in the OCC at various desk and j ust standin around. ilb}/7\IQ\ believes they all probably overheard the conversation. llb}U}(C} Itold b 7 c "Are you wantinli to make a power entry to inspect the piping in Mode 1?" ..................___. replied back,

"{ es." !b)(7}/C} I then said, "Well that is just stupid and why are we doinJ this?" llh)/7\IC} I told 11 imrci       Ithat the OCC should have done this in Mode 3. llblU}(Cl _then told llbll7)(Cl Ito leave the OCC and go outside to take a smoke break for a few minutes. llhl(Z}IC\ I did just that.

He left the OCC and went outside for ten or so minutes. He then came back to the OCC where he and llb}WIC} I continued their conversation (Exhibit T-24).

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 85 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7}/Q) I continued the talk right where he left off. ilb)(7)(C) Itold ilb\(7)/Cl Ithat they should not be doing this in Mode 1 and should have done it in Mode 3. libl/7\/Cl Ithen hollered out, "call security." A few minutes later, WBN security came into the OCC and escorted ilb)/7\IC} I out of the protected area and to his vehicle. Somewhere along the way, Security took his badge. Just as he was getting in his vehicle, he heard over the security guards radio that someone wanted to know if he was still on site. The security guard replied that ilb\17)/Q\ Iwas in his vehicle and then ilb)(ZJIC) I heard the same person direct the security guard to "have him come back in if he wants" (Exhibit T-24). l/bl/7\/Cl Ithen was given his badge back and he reentered the protected area. As he was walking back into the building he was met by l(b)(?)(C) I She took him into a room where she apologized. He thought that someone else was with her. It was not ilb)U)IQ} I She said that the OCC should have done a better job of explaining their plan. She said they should have done a better job communicating why they were having to do it this way. He apologized for his outburst. At this point in the interview, the agents asked ltb}U)IQ} I if he used profanity or threatened anyone in the OCC. He said he did not and did not holler or yell, but admitted he was not happy that the OCC wanted to check for the leak in Mode 1 rather than Mode 3. He said that his displeasure was obvious to everyone in the OCC (Exhibit T-24). ilb)(7)1Ql I noted to the agents that it is his job to "protect" the workers and figured t,,i.,,,u,, ,_-.., i(b}UJ(C} Ijust got sick of him and called security. After he and (b)(?)(C) talked, (b)(?)(C) walked with l/bl/71/Cl Iback to the OCC where he met witlh b 7 c b 7c basically said the same thing to him as !(b)(7)(C) Idid. (b)(7)(C) then walked with irb)(7)/C} I back to his department where she explained to those aroun w at the OCC's plan was as it relates to checking for the leak. libl/7l/Cl I said that the power entry was made later in the shift and the piping was inspected that sh ift. When asked what happened next, b 7 c said that nothing happened and that was the end of the story. According to b ?)(C he and l/bl/7l/C} Iare social with one another and as far as he knows nothing ever came of the incident. The agents asked ilb\(7)/C} Iif the incident has caused him to not speak up or not be as vocal i(b\(7}/Ql I res onded, "No because he has over!(b)(7)(C) !in the nuclear industry and is!(b)(7)(C) I (bH7l(Cl " He could easily see how others may have seen or heard what happened to him (escorted off the site) and these people may be somewhat unwilling to raise issues (Exhibit T-24 ). Interviews of!(b)(7)(C) IUnit Supervisor

  !(b)(l)(C)   I US at WBN was interviewed on October 16, 2017, and April 26, 2019, by 0 1and TVA OIG wherein he provided the following information in substance.

l/bl/7\/C} I stated that he worked the fall 2015 re-fueling outage at WBN. lib}/7l/C} I said he remembered a standby feed water pump issue during this outage. llb}U}IC} I could not recall all the s ecifics of the issue but remembered the issue and that there was a lot of heartache over it. b 7 c recalled being talked to about it and remembered that Hbl/?HC I was also asked about it. i/b)01Cl I recollection was that both he and i/blU)fC I let it be known that doing what they wanted to do was not the right thing to do. l/b)(?)/C} I was also involved in the discussion in the MCR about the feed water pump. He also recalled l/b\(7)/Cl I heing

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY    QI INVESTIGATION INFORMATION 86 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION involved. According to !(b)(7)(C) lrb....,JCZ....)[.,..C.._)_ _...,I was not happy about what the MCR was 1.... being asked to do (Exhibit T-38a).

!{bJl7}(Cl I also said that (b)(7)(C)                Engineering, ended up having to go inside containment to do a local observation. b 7 c           said that there was also a "dose issue" involved. l{b}l7}{Cl I stated that the reactor was critical, and they do not put people into the critical area. lrb)(Z)/Q) I testified that he was not surprised in the least that TVA received a chilled letter from the NRC.

He said the OCC got too caught up in making megawatts and money instead of electricity being a by-product of running a safe plant. He said this came into conflict with the number one goal of those in the MCR. The MCR's first goal is to protect the core (Exhibit T-38a).

!rb)U}/C) I rliscussed that there was pressure to complete the test to be able to continue with the reactor start-u . (b)(7)(CJ       was directing the operations and assigned !{bl{l){Cl I to help supervise b C                     b7C             discussed that !ibl{7lfCl                I was voicing his concerns with performin the test but could not recall the exact dialog between !~b)(7i (~~ land
!rbll7}{Cl       1

_ !rbl/7l{Cl I discussed that even though he is cognizan o e change in requirements associated with use of the SBMFP during start-up he did not believe they were in violation using it on October 20-21, 2015 (Exhibit T-38b, pp. 5-18). Interviews of!{b)(7)(C) I and!(b)(7)(C) !(b)(7)(C) l Shift Mana er* b 7 c Unit Supervisor; ...

                                                                                              !(b_)(7_)(C_)_ _ __

Reactor Operator; and (b)(7)(C) Reactor Operator; were interviewed between April 12 and April 26, 2019 by 01 and TVA OIG. The interviews did not provide any additional relevant information outside the interviewee's inability to remember significant details of the issue in question (Exhibit T-27e)(Exhibit T-46c)(Exhibit T-75)(Exhibit T-76). Agent's Analysis In summary, the evidence obtained by 01 during this investigation indicates that on October 21, 2015, WBN1 int,entionally used the Standby Main Feed-water Pump (SBMFP) to supply feed-water during a reactor startup into Mode 2 contrary to the unit operating license and operating procedures. This was done to facilitate the performance of plant testing and continue unit start-up. On October 20, 2015, WBN1 was performing a plant startup IAW 1-GO-2, Reactor Startup, following a re-fueling outage. At 2345, while in Mode 3, the SBMFP was started IAW 1-SOl-2&3.01 section 5.9. This was performed in preparation to enable engineering to perform testing and inspection of feed-water valves in containment. While this testing and inspection was taking place WBN 1 commenced a reactor startup (Exhibit A2-E1, pp. 76-83)(Exhibit A2-E2)(Exhibit A2-E3, p. 19).

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJO, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                      OI INVESTIGATION INFORMATION 87 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Based on log entries and plant data , the following activities/events took place on October 21 , 2015 (Exhibit A2-E11, pp. 78-83)(Exhibit A2-E12)(Exhibit A2-E3, p. 19):

• 0100 - IAW 1-SOl-2&3.01 section 5.5 feed pump pressure up stream of check valves 1-CKV-3-669 AND 1-CKV-3-678 was established to allow SYS ENG walkdown activities
• 0101, all shutdown banks were withdrawn IAW 1-GO-2, Reactor Startup
• 0320 - W ithdrew all control banks IAW 1-GO-2 , Reactor Startup, and 1-PET-201, Initial Criticality and Low Power Physics Testing
• 0346 - Unit 1 in Mode 2
• 0357 - Operators commenced dilution of U1 RCS to critical
• 0510 - The SBMFP was secured and secondary side returned to modified long cycle Use of the SBMFP during the 1-GO-2 startup of WBN 1 was performed over the objection of MCR operator !(bl/7l!Ql I The operator initially refused and stated it was not safe to perform the reactor startup using the SBMFP but was eventually given direction to proceed with the plant operation by the Shift Manager (b)(?)(C) During this investigation, 01 determined that 1-GO-2 has no allowance or procedura gu1 ance for use of the SBMFP during reactor startup. 1-GO-2 prerequisites specifically require the Auxiliary Feed-water Pumps be used to maintain SG levels. No procedure changes were processed, or special procedures approved to facilitate the use of the SBMFP while performing a reactor start-up. 0 1established that specific changes were made in years prior to GO-2, Reactor Startup, to prevent the SBMFP from being used during normal plant start-up and shutdown. Additionally, system design documents were correspondingly changed to identify that the SBMFP was not to be used during normal startup and shutdown (Exhibit A2-E5, pp. 1-5)(Exhibit T-15).

All licensed operators receive training on these 1-GO-2 requirements and procedures. Senior Reactor Operators are also charged with knowing the basis behind such procedures and actions. Operator training identifies that the SBMFP was not to be used during normal startup and shutdown (Exhibit A2-E4, p. 167). The evidence obtained throughout this investigation indicates that the use of the SBMFP represented a violation of NRC requirements. 10 CFR Appendix B, CR V, Instructions, Procedures, and Drawings states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. 1-GO-2, Section 4, Prerequisites, [8] states "MAINTAIN SG levels on program with AFW pumps." 1-GO-2 purposefully does not have any allowances for use of the Standby Main Feed Pump (SBMFP) to feed steam generators during reactor startup. Use of the SBMFP on October 21 , 2015, to feed SG's while performing a normal reactor startup was not consistent with the requirements of 1-GO-2 for Reactor Startup (Exhibit A2-E6). Based on the interviews and totality of the evidence, 01 found insufficient evidence to conclude that any of the individuals involved engaged in deliberate misconduct.

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF ai-ECIAL AeEPH IPJ Cl lii!ROE, OFFIGE OF ltWEGTIOMlmJG, AEOlmJ II 6 f'f'le l,-L U9!! 614LY  OI INVESTIGATION INFORMATION 88 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - O1 INVESTIGATION INFORMATION Conclusion Based on the evidence developed during this investigation, 01 substantiated that the motor driven Standby Main Feed-water Pump was used to feed the S/Gs in order to perform a valve PMT in parallel with unit startup even after the plant was taken into Mode 2. Further, 01 determined that this action represented potential violations of NRC requirements but 01 did not substantiate any willful act associated with this allegation .

                ,~e,= FeR fi'UBLl6 Dl96L69URE 'l'VITI ISUT >'<fi'fi'RS'"'>'<L eF CPEGl:Oib ,0.GENi l~I GI l,0,Rfs liii , Qliilii lCliii Qlii I W' i ~T l 'cTI OWi , ~liii'c lOl>l 11 6 ffleliltt USE 614 LY          O1 INVESTIGATION INFORMATION 89 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 3 Failure to follow the NPG-SPP-1.2, Administration of Site Technical Procedures when making a change to WBN1. 1-GO-1 Start-Up from Cold Shutdown to Hot Standby (drawing the bubble) by the l(b)(?)(C) jon November 9, 2015. Applicable regulations 10 CFR 50: Appendix B, CR V, Instructions, Procedures, and Drawings 10 CFR 50: Appendix B, CR VI, Document Control 10 CFR 50.59: Changes, tests and experiments 10 CFR 50.5: Deliberate misconduct Documentary Evidence IOutage Update Sent b) (b)(?)(C) Email l(b)(?)(C) Email ..... Outage Update Sent b) ._ ____ (A3-E 1) (A3-E2) 1-GO-1, Unit Startup from Cold Shutdown To Hot Standby, Revision 3 05222015 (A3-E3) 1-GO-1, Unit Startup from Cold Shutdown To Hot Standby, Revision 4 11092015 (A3-E4) Copy of 1-GO-1 from 11/9/2015 (A3-E5) Emaill(b)(?)(C) 11-G0-1 Sent byl(b)(?)(C) on!(b)(?)(C)  !(A3-E7) .....__ _ _ _ ___,J Email !(b)(?)(C) I1-GO-1 Revision 4, Sent byl(b)(?)(C) Ion !(b)(?)(C) l(A3-E8) NPG-SPP-1.2, Administration of Site Technical Procedures, Revision 12 09112015 (A3-E9) Analysis of change to 1-GO-1 (A3-E 10) Draft Apparent Violation (A3-E11) Testimony Interviews ofl(b)(7)(C) I Shift Manager,l(b)(?)(C)  ! and OCC Operations Representative !(b)(7)(C) I Shift Manager, !(b)(?)(C) I and OCC Operations Representative at WBN was interviewed on October 16, 2016, and March 29, 2017, by 0 1, TVA OIG, and AUSA!(b)(?)(C) IUS Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance on this issue. Agent's Note: As identified in the excerpts below, and further detailed in the documentation of the interviews, !rb)(7l!Cl Ifailed to provide the same level of detail and specifics in all the interviews at times appearing contradictory in nature.

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 90 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7)/C\ Idiscussed that he could not recall any procedure changes during the November 2015 outage or the fall re-fueling outage. He added that they cannot change procedure outside of the plant's design. !lb}U)(C\ I said that editorial changes do not require a 50.59. !lb}{?)IC} I said that he could not think of a time where they skirted a 50.59 by calling it an editorial change. !lbl/7\[C} I was asked about procedure changes. He stated that they sometimes do procedure changes to cut time like when they look to see if they can do a surveillance in another Mode. He said that 50.59 evaluations get screened out. He added that they have missed some though on Unit 2. He said they got a violation from the NRC for it too (Exhibit T-17d). During subsequent discussion about the November 9, 2015, procedure change to 1-GO-1 for drawing the bubble in the pressurizer !lb\/7\/Cl I was asked if he recalled changing a procedure during the November 2015 outage. !lb)U}[C} I said that he could not remember such a change, but added it was over one year ago. After prompting, !lb\(7\[C\ I said he did recall somethin about the chan2e to 1-G0-1 to allow d~ ; ~the l ubble in the eressurizer. AUSA (b)(7)(C) old !rb\U}(C} I that in October 2016, asked !(bJmrcI Ithat exact same question and ilb\(7)/Cl Itestified that he ha no een involved in any type of procedure change. ilb1(7)/C\ I r.ommented that he had just forgotten . !lbl(7)/C\ I recalled that he was looking ahead in the schedule and noticed a sticking point with the temperature and the procedure for drawing the bubble. !(b)/7\(Cl I stated that he got System Engineering involved and talked to Operations to reach a resolution to make sure it was not a hold-up to the schedule by re-defining or re-classifying a portion of the procedure. !rb}mlC) Istated that it still ended up causing a delay in the schedule (Exhibit T-17e). !lb}/7\/C) I stated that after the problem was identified, !(b)(?)(C) WBN, asked what was happening and !(b)(7J(Cl Iexpla...in_e_d_t_h_e _s-itu_a_t-io_n_, a_n_d_t_o-ld_ __. !lb){?)(C) Ithat the procedure had been defined too narrowly and relayed that he was working with Engineering to get it corrected. !(b\(7HCl I said that !(b\(7Jic\ I was displeased based on a statement he made that !(b\/?)(C) I was not able to recall. !rb)(7)(C\ I stated that shortly after his conversation with b C (b)(7 (C) at WBN, came in and was belittling b 7 c b7c explaiined that the procedure does not have to be written the way it is written and told him that they were working through it with Operations and Engineering. !rbJ/7}/C) I stated that lrwwcL I pitched a fit and threw the procedure paperwork down and basically had a tem: er tantrum. !ibJ{?)/C\ I stated that ~ then asked ilb}(?)(C\ I a question that !ib}(?)/c\ I could not recall, but he does remeniE'er that at the time he thought the question was intended to humiliate !rb)l7}[C} I ""'!b1""'Ja"'"'1rc"""1-..,I stated that a little while later he was called by someone either from the Control Room or Work Control and was told that the Control Room was okay with moving forward after speaking with Engineering (Exhibit T-17e). During the interview !rblm(Q) I stated that he did not believe that the procedure change was an intent change and argued that it was a minor editorial change based on delta T. !/b)(7)(Cl I stated that the change to the [_)rocedure occurred prior to his conversation with ![b}{?)[Cl I !lb)UJ!Cl Istated that l<b)(7)(C) ] fit was thrown shortly before they moved ahead in the schedule which was hours after !lbl(?)/C\ I initially identified the issue an1r ~t:~gj d the procedure. !/b)(?\(Cl I stated that after his unpleasant public interaction with b 7 c some

                                  ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 91 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION rueo1] le (NFI) thought that !(b)(l)(C) I was being directed by l/b)(7)(C) Ito violate the procedure. bl(?) Cl I stated that is not how he viewed the interaction because he had been looking at it for hours before the conversation with i{b){?)(C) I ::ind ltb)U)/Ql I !lb)U)/Ql I stated that !(b)(7)(Cl I and !lb117l(Cl I had zero influence on !lblU)(Cl I changing the procedure, ilb\(7l(Cl I was waiting on the Control Room and Engineering to agree to move forward. According to !(b)(7)(Cl I no one directed his efforts for the procedure change. !tb)(Z)IC) I stated that during the previous two years they became a prove to me why it cannot be done organization and got pushed all the way against what can be done safely. !(bl(7\/C\ I believes that the events of November 9 and November 11, 2015, are probably examples of that mindset (Exhibit T-17e). Interviews of !(b)(7)(C) l Senior Reactor Operator !(b)(7)(C) I SRO at WBN was interviewed on January 16, 2016, and September 19, 2016, by 0 1, TVA OIG, and AUSA!(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee , wherein he provided the following information in substance. i{b)/7}/C} I said that on November 9, 2015,l(b)(?)(C) !WBN1 Unit Sur ervisor (REDINGER) and the unit was working toward moving out of an outage. !(bl/7l(C I recalls the OCC requested the MCR to draw a bubble in the pressurizer without the temperature being achieved as required by approved plant operating procedures. He described that there was a caution in the procedure (1-GO-1) that said do not move forward drawing a bubble in the pressurizer while you are cold and to wait until a certain temperature. According to !(bl(7)(Cl the operators did not want to heat-up but drawing a bubble is a milestone and a bi ste to moving forward so the OCC said to do it. !tb)U)IC) I then showed the procedure to (b)(7)(C) !(bl(7)(Cl I Shift Manager. !tb)U)IC} I ::igreed with i(b}m!Ql I that they should not do it and communicated it back to the OCC. The decision was made to revise the procedure, so they could move forward. According to ~ this is not a common thing, but the OCC must have felt they found a safe alternative. ~ id not believe that and told !lbJ(?)/CJ I that "I just want to communicate to you verbally that I am disagreeing with this procedure" and "I said who with an NRC license is saying this is ok" (Exhibit T-05a)(Exhibit T-05b). At this point, !(bl/7l(C\ I said "the people who fire people with licenses said to do this." !fbl(7l(Cl stated that !(b\(7)/C\ I did not name anyone but there are not mant ~eo~le above the shift manager. llb)(Z)IC) I believes he was talking about llb)/7}/Ql I and b rnc I llb)(7}/C) I stated, "He was pissed off' after this comment because he is proud of his NRC license. !(b)(Z)IC) I stressed that the license is an agreement between him and the NRC not TVA !rb)U)(C) I stated that is was not right to have decision making, which overrides the license holders, made by the other non-licensed people in the organization who have milestones to meet to get out of an outage. Soon after this conversation with !(b)(7)(C) I REDINGER returned to the control room and took back the watch from llb)(7}/r.) I At that point, the operators moved forward and did as instructed even though "the whole team was against it" (Exhibit T-05a)(Exhibit T-05b). 14ef FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1)1(L eF

             ~P'ECIAL AeElff 114 0 1lii!ROE, OFFICE OF IW,'EeTl,A.+IO~Ha, ~ liiiC.10~1II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 92 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 01 INVESTIGATION INFORMATION Interviews of !(b)(7)(C)

!(b)(7)(C)                                            !at WBN, was interviewed on June 9, 2017, and January 25, 2019, by TVA OIG wherein he provided the following information in substance.

lfb}U}(Q} I was asked about one specific procedure change that he was a part of which occurred on November 9, 2015. The investigator told ilb}/7}(C} I that the procedure had to do with drawing a bubble. The investigator also told !rbll7lfCl I that the procedure was processed with !lb}(?)CQ} I and the procedure change was listed as a minor editorial change. ilbll7l/C) I said that he did not have to remember that particular rirocedure changes to be able to tell the investigator that nobody pressured or madP. ilbll7ll/i I do something that he thought was not right. i(b}U}[Q} I said that neither j(b}U}/Q} I nor ilbl/7l(Cl Iwould ever try to pressure lrbl/7l(Cl I He did say that he takes into account the data and the information that people give to him as well as the data points he collects himself when he makes procedure changes (Exhibit T-42a). ilb}l7l/Ql Iwas asked if he was qualified, as specified in TPD-PWG, to be a !(b)(7)(C) I 11filill[Jin November 2015. lrb1(7)fCl I said that he was pretty sure he was. He was then asked what his responsibilities were when reviewing a procedure change to a quality related operating procedure like 1-GO-1. He replied that he verified if the changes were technically correct. He said he would go through the Independent Quality Review (IQR) checklist. He added that there were a lot of things that he goes through when reviewing a procedure change. ilb}(?)[Q} I was then shown the procedure change from November 9, 2015. ilb}l7l/Q} I was then asked why the 1-GO-1 procedure change was being performed. He discussed that he thought it was a semantics issue with the word "raise." He was then asked what effect did the change to the 1-GO-1 , 5.2.1 step 8 on November 9, 2015 have on the implementation of the procedure. He replied that he did not think it had any effect. He was then asked if the procedure change on November 9, 2015, met the definition of a minor editorial change. He said that it prob.ably did not. Although he is unsure, he did not think it impacted the intent of the procedure, which was to warm up the RCS between 135 degrees and 160 degrees (Exhibit T-42b). Interview of !(b)(?)(C)  ! Reactor Operator (b)(l)(C) Oat WBN, was interviewed on September 29, 2016, by 0 1, TVA OIG, and AUSA (b)(?)(C) US Attorney's Office for the Eastern District of Tennessee, wherein he provided the allowing information in substance. !(b)(7)(C) I stated that when he came into work on November 9, 2015, the plant was still in Mode 5. He believed the plant would be farther along when he came in and MCR and the OCC wanted to draw a bubble on the ressurizer but not heat-up. According to!{b)(7)(C) IOCC had directed another operator (b)(7)(C) with less experience to draw the bubble. To that end. !(b)(7)(C) I and (b)(7)(C) decided to go to WBN2 and ask another operator (NFI) to see if it was even possible (Exhibit T-01c). !(b)(?)(C) Istated this was a unique forced outage and this was the only time he had ever seen a forced outage that went all the way up to Mode 5 because most forced outages are in

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEGl,A.b Ae~n l~J GI I:1'.lil!u  , gfiiifiii l 'u  gfiii I W.< iT l t;;;0TI O~ l i , l-.liiiC.I01>1 I1 6 f'f'le l,-L U9!! 614LY      QI INVESTIGATION INFORMATION 93 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Mode 3. To recover the plant with a single crew was rare and not his crew's s ecialt so when he heard about drawing the bubble he did not think it made sense. As (b)(7)(C) was talking to the WBN2 o erator NFI he was cut off bg !tb}/7}/C} I and told the decision had alread been made. (b)(?)(C) believes !(b}(?)(C_ I thought he was arguing. At that point, (b)(7)(CJ stated they were in Mode 5 and holding (Exhibit T-01 c). According to !(b)(7l(C) I they had gone through the procedure and were doing something like chan in heat-u to initiate which would let them go ahead before it reached the required heat-up. b c stated that he asked l(b)(7)(Cl !about drawing the bubble procedure and that is when he (b)(?)(C) realized the procedure had been changed. !(b)(7)(C) Ibelieves the procedure was changed on November 9, 2015, and the nightshift drew the bubble that night (Exhibit T-01 c). I Agent's Note: !(b)(7)(C) !(b)(7)(C) U(b)(7)(C) !andl !(bl(7)(C) I are mentioned during testimony but not directly implicated in allegation no. 3. Available testimony does not provide any relevant information concerning this allegation. Agent's Analysis In summary, the evidence obtained during the investigation leads 0 1to conclude that on November 9, 2015, !rbH7}(C} I deliberately failed to implement the procedure change requirements of NPG-SPP-1 .2, Administration of Site Technical Procedures, Revision 12 when he approved an unauthorized change to plant operating procedure 1-GO-1 Revision 3. On November 9, 2015, WBN1 was heating up following an unplanned outage to fix a reactor coolant system (RCS) leak on the top of a rod drive mechanism. Work was ongoing on the reactor head and RCS temperature was being controlled to approximately 110°F. The control room operators reached step 5.2.1 [8] in 1-GO-1, Unit Startup from Cold Shutdown to Hot Standby, Revision 3, which required that RCS temperature be raised to between 135°F and 160°F before proceeding in the procedure to draw a steam bubble in the pressurizer. !rb}(7)(C) I testified that control room operators were requested to continue with the procedure with reactor temperature below 135°F but the MCR did not continue (Exhibit T-05a)(Exhibit T-05b )(Exhibit A3-E1 )(Exhibit A3-E2)(Exhibit A3-E3, p. 27). In response, !(b)(7)(C) I using his subordinate !{b)(?)(C) I implemented a change to 1-GO-1 , Unit Startup from Cold Shutdown to Hot Standby, Revision 3. 1-GO-1 which is an operating procedure that fell under the scope of NPG-SPP-1.2, Administration of Site Technical Procedures, Revision 12. !(b}ffi(C} Ir.hange allowed the continuation with 1-GO-1 to draw a steam bubble in the pressurizer without reactor coolant temperature being raised to at least 135°F. This was done to compel WBN1 operators to continue with the scheduled plant start-up activities after the operators identified doing so would be a violation of 1-GO-1 . The intent of making the procedure change was to avoid raising temperature as evinced by plant operators not initiating a plant heat-up and actually reducing plant temperature after drawing a bubble in the pressurizer in an attempt to keep reactor coolant system temperature kept near 100°F.

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 94 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7)/C\ I classified and processed this as a "minor editorial change" as defined in NPG-SPP-1.2, Section 3.2 .11 Minor/Editorial Changes. NPG-SPP-1.2, Administration of Site Technical Procedures, Revision 12, Section 3.2.11 Minor/Editorial Changes, states: Minor changes shall not change the intent of the procedure or alter the technical content or sequence of procedural steps. The procedure revision to allow drawing a bubble below 135°F changed the int,ent of the procedure, technical content and altered the sequence of steps of the procedure (Exhibit T-17d)(Exhibit T-17e)(Exhibit A3-E4, p. 27)(Exhibit A3-E5)(Exhibit A3-E6)(Exhibit A3-E7)(Exhibit A3-E8)(Exhibit A3-E9, pp. 23-24 )(Exhibit A3-E10). As described in detail in Exhibit A3-E10 and A3-E11 , 0 1finds that the evidence supports that this procedure revision was made without meeting the required procedure change/review requirements of NPG-SPP-01.2 for this type of change which would have required a significantly more detailed review and approval including : Engineering/technical reviews; 50.59 reviews; Operating Experience reviews; licensing compliance reviews; Plant O~erating Review Committee reviews; and training reviews. The deliberate failure by ilbU/C) I to follow NPG-SPP-1.2, Administration of Site Technical Procedures, Revision 12, for implementing document control requirements when he approved the change to 1-GO-1 constituted a violation of multiple NRC requirements including: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings: Criterion VI, Document Control; and Technical Specifications, Section 5.7.1 Procedures (Exhibit A3-E10)(Exhibit A3-E1 1). !lb)/7\[Cl I was an off-shift Shift Manager licensed as a Senior Reactor Operator and, in his position as the!(b)(7l(C) !he is responsible for implementing and enforcing the requirements of NPG-SPP-01 .2. Considering his position, experience, and information obtained during interviews, 0 1determined it was not implausible that he did not understand the requirements of NPG-SPP-01 .2 and the obvious implications of the change he requested and approved. Therefore, 01 concludes that i[b\(7)/C\ Ideliberately approved an improperly made change to the Unit 1 operating procedure 1-GO-1 , which incorporated a change to step 5.2.1 [8] which required operators to only initiate raising temperature to between 135°°F and 160F before proceeding with drawing a pressurizer bubble. Conclusion Based on the evidence developed during this investigation, 01 substantiated thatl(b)(?)(C) !(b)/7\(C\ I deliberately failed to implement the procedure change requirements of NPG-SPP-1.2, Administration of Site Technical Procedures, Revision 12. Specifically, on November 9, 2015, !(b){7)(C) I used his subordinate, !(b)(7)(C) I to initiate a change to a plant operating procedure 1-GO-1 Start-Up from Cold Shutdown to Hot Standby in a manner which intentionally subverted the required review and approval process for such a change. !/b\(7)/C) I subsequently approved the changed procedure for use in operation of the plant.

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEGl,A.b Ae~n l~J GI 1:1'.lil:(sliiii, gfiiifiiil'uiil gfiii IW:<aiTlt;;;0TIO~li , 1-.liiit;;; IOM II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 95 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 4 Watts Bar failed to follow Plant Operating Procedure 1-GO-1 when Unit 1 was transitioned from Mode 5 to Mode 4 without normal let-down in service and continued with 1-GO-1 start-up activities on November 11, 2015. Applicable regulations 10 CFR 50: Appendix B, CR V, Instructions, Procedures, and Drawings 10 CFR 50.59: Changes, Tests and Experiments 10 CFR 50.5: Deliberate Misconduct Documentary Evidence 1-GO-1 from November 11, 2015 pages 27-60 (A4-E 1) Clearance Tagout 1-TO-2015-0046 - Clearance 1-62-0584-FO (A4-E2) 1-GO-1 , Unit Startup From Cold Shutdown To Hot Standby Revision 0004, Effective Date November 09, 2015 (A4-E3) eves Charging and Let-down Valve Checklist 1-62.01-1V (A4-E4) WBN Plant Logs from November 11, 2015 (A4-E5) Email!(b)(7)(C) !Sent by,._! (b)_(7)_(C_) _ ___.! (A4-E6) Email l(b)(7)(C) !Sent by !(b)(7)(C)  !(A4-E7) Emaill(b)(7)(C) !Dennis REDINGER Sent by !(b)(?)(C) I (A4-E8) Email.-l(b-)(7-)-(-C)_ _ __,I PDF Interview Notes Sent byl(b)(?)(C) I(A4-E9) Email. Emai l exchange between !lb\(7)/C\ I ;:ind !lb\/7\/C) I (A4-E10) Draft Apparent Violation Failure to Follow 1-GO-1 (A4-E11) Conduct of Operations OPDP-1 Rev. 0029 (A4-E12) eves Charging and Let-down Power Checklist 1-62.01-1P (A4-E13) NPG-SPP-01.2 Rev. 0012 -Administration of Site Technical Procedures (A4-E14) WO117339526 P/T limits from November 11, 2015 (A4-E 15) Email!(b)(?)(C) ~ ent by!(b)(/)(C) (A4-E16) -----

                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEC IAL AGDH IPJ 0 1h0tRGE , OFFIOE OF ltWESTIOMIOPJS, REOleN II 6 f'f'le l,-L U9!! 614LY   OI INVESTIGATION INFORMATION 96 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Testimony Interviews of l(b)(7)(C) IReactor Operator l....(....irr...ii...i............I l us (bb)rl(cC) RO at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA following information in substance. Attorney's Office for the Eastern District of Tennessee, wherein he provided the l!b}/7}/C\ I has worked as a RO, at WBN since~ On November 11 , 2015, libl0CCJ Iwas working on WBN2 and had walked over to the WBN1 side of the MCR to offer assistance as WBN1 was working through a maintenance (forced) outage. According to !(b)(7)(C) I when he arrived at the WBN1 side of the MCR, the RO (NFI) was in the process of using the RHR let-down as the method of controlling the RCS level. That condition, lead !rbl/7}/cl Ito begin asking questions of the RO and proceed to walk the board in an effort to understand the situation . l/b}(7}/C} I said that he soon realized the RHR temperatures were higher than normal which caused him concern. At that point, l/b)(7l(Cl Iraised his concerns to the SRO's. l/bl(7}/C\ observed there were alarms and temperatures that were abnormal as he discussed his observations and expressed his concerns on what he thought needed to be done. According to

!(b)(7)(C) I the RO's had agreed with !/bl/7)/C}                           I observation and indicated to !/b}(7l!Cl Ithat they had voiced similar concerns but were overruled by "those above them." !(b){?l!Ql I explained that the RO's discussed how could they get out of the situation and utilize RCS cooling (Exhibit T-02a, pp. 4-12).
!/bl(7)(Cl                 I stated that as he walked into the MCR, they were starting to align RHR let-down and the suction valves from RCS were already opened which lead him to ask questions. l/bl/7)/Cl I recalled that r(b)(7}(C)                                                Ion duty and the us, REDINGER, was running the procedures. )(b)(7)(Cl Itestified that he clearly voiced his concerns related to the reason the suction valves from RCS were opened and the high-pressure alarm. Accordin to b 7 c                                                he told SM !/b}(7}/C}                        ! "I (b)(7)(C)    said this is not the right thing to do he (b)(7)(C)           would not really answer me." b 7 c                                 acknowledged that he was full of suggestions to ...b............

C.___. which were more than !/blf7)(C) I cared to hear. Eventually, l/b)(7)fC} I directed the heat-up to stop as the temperature approached 235F (Exhibit T-02a, pp. 11-19). Additionally, !/b}(7}/Q) I stated the let-down system was in service with RHR pumps on RCS cooling Mode while normal let down was tagged for maintenance. llblU}!Q\ ] testified that he was not part of the decision-making process to secure normal let-down on WBN1 and was not present inside the OCC during the period in question. Likewise, !/blf7)fCl I stated that he was not assigned to WBN1 on November 11, 2015, but on his own accord decided to walk over from WBN2 to offer his assistance with the evolution. !/bl(7l/Cl I described the MCR as "hectic." In particular, the operators were uncomfortable relative to the RHR temperatures and the rise in the pressurizer. When asked if there was "command and control" from the shift manager and the SRO's regarding the activities, !/b)(7}/Cl I said, There were some disagreements as to should we be doing this that the SROs expressed." !lb)(7l/Cl I stated that it was not a proactive environment but rather a reactive one as operators were simply trying to get a handle on what was going on with the plant. When asked how did the let-down system impact (challenge) the

                                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AGDH l~J GI hO.RGE, OFFICE OF l~J~'ESTIGMIO~JS, REGlmJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 97 Case No. 2-2016-042

6FFle l,-L U9E 614LY 0I INVESTIGATION INFORMATION operators, !lb}Cl)/Cl I responded , "The biggest challenge was not being able to control the pressurizer level on the heat-up." Specifically, the ressurizer level rose from 40 percent to nearly 80 percent before any action was taken. b 7 C suggested that the excess let-down is limited relative to its design and only suitable in certain plant conditions. Also, the secondary side had nothing to offer to cool the plant down and when the heat-up was sto%ped all the steam generator atmospheric dumps were opened and the steam was dumped. !/b)(7 Cl I stressed the pressurizer level was in a dangerous place without the ability of normal let-down. !lb}f?lfCl I said, "Had they stayed within the bounds of the GO procedure they would not have had any concerns with the (heat-up)" (Exhibit T-02b, pp. 9-15, pp. 17-23).

!lb}l?l/C}   I stated that at the end of the shift, !(b)(7)(C)                     I verbally thanked !lbl/7}/C} Ifor getting "loud." Although !lbl(l)(Cl             I never articulated that he was confused or did not understand the procedure, !rb}l?l/Cl Iquestioned !lb}l?}fC}                  Iabout the capacity of the excess let-down system and em~hasized he should have waited for the normal let-down to return to service. Accordinf to !(b)(7)((\    I!lb1(7}fCl                          !

Itold !(b)(7)(C) "That he was doing what he was told to do." !lb)(7)/C1 said that under the current management at WBN the main concern was reaching the next milestone. !lb}(l)/C} Isugf ested that bonuses and promotions are all tied to milestones which causes some risk. !fbll7l(C_ Iadded that the OCC placed WBN at risk on November 11, 2015, as MCR did what the OCC wanted. It was the MCR that recovered and stabilized the plant. When asked what could have happened, !rbl/71fQl I stated they could have released radioactive water outside of the reactor coolant piping (the reactor coolant system boundary). Furthermore,

!lb1/7lfCl Iimplied a component could have failed given the higher water temperatures and pressures. Additionally, there was potential environmental damage as the plant would have been less safe because one less barrier was available. He stated that this is probably the second worst thing that could happen next to releasing the radioactive materials into the environment (Exhibit T-02b, pp. 25-28) (T-02c).

Interviews of l(b)(?)(C) IShift Manager ,.......___.....,SM at WBN was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA .......,_________, US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. Agent's Note: In his initial interview with 01 on December 18, 2015, !rb}mrc1 I failed to provide the same level of detail and specifics as he provided in subsequent interviews. On December 18, 2015 !lb){l)(Cl I was interviewed by 0 1concerning the events of November 11 , 2015, and rovided the followin information. !fblf?)fC) Iwas in the l(b)(?)(C) I (b)(?)(C) in many differe~ ear power plants, DOE facilities, en ineering firms. b 7 c has been licensed since (bl'.7) and a Shift Manager since (b)(?)(C) explained the plant ha~-"-Lll'd normal let-down rom service the night previous to e s I t at he took over on the (b)(?)(C) of November 11, 2015. At~ we had heated up to enter Mode 4 which is 200 degrees. (bH 7)(Cl e secured both tra~ RHR to allow the RCS to continue heating up. The plan for November 11 , 2015 was to heat-up and pressurize RCS and enter Mode 3 at some point during that day or that night. The normal let-down system for CVCS was out of service for repair to a leaking valve and they had

                         ,~e, fieR 1-UBUe 01 aet eaURE WITI 1e u, )l(flf1Re1~1>'<L efi
               ~P  G l :O.la .A/e  ~IT l~I GH.A.pil'5 1ia, g fiiifiiil G  g fiii IW,< eTI C.A.:: 1 g ~1. , pillia'51g~1 II 6f'f'lel,-L U9!! 614LY              QI INVESTIGATION INFORMATION 98 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION placed the alternate let-down system, excess let-down, in service for let-down capabilities. Other than that, all the other plant conditions were normall as to be expected for Mode 5 and Mode 4 (Exhibit T-22a, pp. 4-1 1). ilbl/7\/C} I discussed that nobody raised any concerns nor did any of the crew have any questions or concerns about trying to do a heat-up on excess let-down. i!b){7l!Q) I explained that the crew discussed the fact that they had not done it before and were willing to start it and see how it went. !(b\(7\(C\ I stated he thought they had enough excess let-down flow to be able to control pressurizer level on excess let-down. When asked about the crew's reaction to planned events of the day, !(b)(7)/C} I stated he did not remember any big push back from the crew. However, !(b}(7\(C} I remembered being a little bit anxious continuing the start-up activities with only excess let-down because he had never done it like that before and was not 100 percent sure that it was going to go the way that he anticipated it to. !rbl/7}/Cl I reasoned that he did not challenge the path to move forward because he had no basis for saying it would not work. When asked about influences on his decision concerning schedule pressure or any information coming from outside the control room that might have unduly influenced him in his decision he stated he did not remember any specific undo pressure (Exhibit T-22a, pp. 15-19, pp. 2 1-40, pp. 43-56). On January 19, 2016, ilb}(7}/Cl I was interviewed b TVA OIG and provided the following information ilb}IZ)!C} I explained that on the (b)(?)(C) of November 11, 2015, WBN1 was at Mode 5. WBN1 had just reassembled the reac or an he temperature was less than 200 degrees. OCC directed the MCR to move to Mode 4 which would have kept the site on schedule. The operating crew moved to Mode 4 as planned and as instructed. !tb)(?)IC) further explained that around 0940 hours, all pre-requisites to move to Mode 4 had been handled. !(bl/7}/Cl I instructed the MCR to go to 210 deg rees and maintain that temperature which placed the plant into Mode 4. According to !(b)(7)(C) I the OCC told W illiam !(b)(7)(C) I OPS OCC representative, to inform !(b}(7\(C\ Ito go to Mode 3 and take the tem~erature up to 350 degrees. ifb}WfCl I further explained that around (b)(7)( the OCC directed Wmrc1 Ito take RHR out of service, and then move to Mode 3. b 7 c testified that he informed !(b\(7)(Cl Ithat he was uncomfortable moving to Mode 3 and that they needed to stam where they were and wait for the let-down system to come back into service in a few hours. Ji}U){Ql I said he mentioned to !(bl(7)/C} Ithat the OCC was pushinrri too hard. According to !(b)(7)(Cl I !(b\(7}/C} Iwas also uncomfortable with the decision. !/bH7 Cl I explained that the OCC was pushing too hard and wanted to stay on schedule (Exhibit T-22b). !/b\17\IC} I said that ilb}(7)IC} I raised !(bl(Z}IC} I concerns to the OCC and recalled that ilb)U}{C) I gathered everyone around a table and told them of ilb)(?)IC\ I r.oncern . !(b}/7\/Cl I stated that !(bl(?l/C} I also told them that they were pushing the operators too hard and he wanted it to stop. According to !(bl~fc~ I the OCC dismissed the concern and instructed !lbl(?)!C) I to move to Mode 3. 1(rnc) I said that he would have pushed back harder on November 11, 2015, but he was worried that he would be somehow reprimanded for not getting on board with the decision to move to Mode 3. His actions in the MCR were heavily influenced by his fear of losing his job (Exhibit T-22b).

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lii!ROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         O1 INVESTIGATION INFORMATION 99 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION On July 20, 2016, !(b}/7l(C\ I was interviewed by TVA OIG and provided the following information. !(bl(7l(Cl I advised that there was no discussion on November 11, 2015, that it might be possible to get 70gpm using the excess let-down !/b\(7}/C\ I stated, "I do not think ~ou could ever get 70gpm out of excess let-down." If someone had said 70gpm was possible, b\(7\(C)  ! stated that the conditions would have to be "absolutely perfect" at full w essure to ever get close to that and even then, it would be a "slim chance." Regardless !lb}/l/C\ I stated in the MCR tha* b)(7)(C) !'no one had the number 70gpm on our brain anywhere." !(b\/7l[C\ I stated that no one said that night that they knew the heat-up using excess let-down could be done. Rather, everyone said that they did not know how it would react and they (licensed operators) knew they had "stuff' they could do if it went wrong. l(b\/7l(C} I stated that the "bi~ u~s" were saying "go" and the operators had actions in their back pocket ![bl/7l[C\ 0 to use if it failed. J2 lU I stated that no one in the MCR wanted to move forward. I is not aware of whether any of the other uys talked to !/b\f7l[Cl I About a month later when the NRC brought up the issue. !tb)(l)IC) 1 _ was in ![b\(7)/Cl Ioffice with !(bl/7l[Cl I and !(b)U}[C\ I At which time, !tbl(?l[Cl I asked ![blf?}(Cl I if !(b\/7l/Cl I should be removed from watch until they found out the answers to the questions. !tbl[7)/Cl said "Yes." !!b\(7)(Cl I stated that he was glad he had been in the meeting and heard the conversation because he realized it was not a punitive thing but rather just a conservative measure until the NRC was comfortable. !lbl/7l[Cl I also believes it was to position themselves to look better to the NRC. !(b\(7}/Cl I said this was normal and he would have done the same thing. !lb)(Z)/Ql I went back to his regular work control job and was able to fill in the next time he was asked for help in watch standin~. !lbl[7l!Cl I said he was never remediated. !(bl/7l(C\ I never heard !!b\/7l(C\ I or !fb]}(Cl I talk about taking anyone else off watch because "the buck stops with me !(b)(?)(C) I(Exhibit T-22c). On September 6, 2016, !(blf7l(Cl I was interviewed by A USA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, TVA OIG and 01 wherein he provided the following information. Although !(b\(7\(C\ I asserted that he was not worried about raisin issues to the OCC, khiaJiCl I was certain!~ not comfortable about challengin the Ml7J(Cl !(b)(7)(CJ I about plant decisions. b c emphasized that once the first engineenng est was over, he called ![bl/7ltCl I to inquire how much longer before the valve (normal let-down) was in-service. According to !(b)(7)(Cl I ![b\/7l[Cl I told him the valve would be ready soon. !rblt7l(C} I said the schedule called for WBN1 to proceed to Mode 3. !(b\(7\tC\ I stated there were no procedures in place about what to do or not to do when heating up usinffi excess let-down, !lb)/7}/C\ I said there was nothing in writing saying it cannot be done. 1$ll7}(Cl I disclosed that he was uneasy about w oceedin9 partly due to the fact that he had no experience heati11; up using excess let-down. I b)Q)(C) _ stressed that WBN1 was not at full pressure, but !lb)W/C I admitted he had no idea how using the excess let-down would affect the pressurizer level. Likewise, !(b\/7l[Cl I was unable to estimate how much inventory (water) they ,expected to get out using excess let-down, no numbers were discussed (Exhibit T-22d). !fb\/7l[Cl I stated that he knew there were ways to control the plant if excess let-down did not work and if the plant did what he was "afraid" it would do. ![bJ(7\/Cl I explained that the procedures are not written for every step (scenario). !tbl[?l[Cl I stated that he knew how to

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        0I INVESTIGATION INFORMATION 100 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION recover the plant if excess let-down did not work and understood that the pressurizer level will go up during heat-up. !fblf?l!Cl I stated that the first step for heat-up was to remove the RHR. Once the RHR was removed , the temQerature in the RCS would increase. !lb\(7)/C) I stated that prior to removing the RHR, !fb){7){Cf I set some trigger values to ensure they took action. At this oint, nobody could put their finger on why they should not heat-up. According to b c if he did not have contingencies then he would have been more concerned . b 7 c stated that the licensed operators were not overly experienced and once it was discussed none of them had an opinion one way or the other except !(bl(7}/Cl I !(b}(7}!Cl I stated that no one else said it was not a good idea which causer! l1b\m1c1 I to start doubting himself because he seemed to be the only one that was uneasy. In regard to b 7 c 111111 !lb}(7}/Ql I testified that !lblf71(Cl I basically said something to the effect that""'.,,:,H  :':":-e, ... (b)(7..

                                                                                                                                                   )(C'"')- - - .

felt !lblll)/C) I pain but we have a schedule." !lb)U)!Q) I confirmed that he set a trigger value of 80 percent pressurizer level where they were to open the PORV to control the rate of heat-up. They then took the RHR out of service and the pressure quickly got to 79 percent which was faster than they anticipated. !ib}f711Ql I said the rate of heat-up is what "killed" us because it out-ran the excess let-down system which is what !(b}l7l(Cl I suspected was going to happen. At this point, REDINGER opened the RHR inlet valves and the pressure level went down (Exhibit T-22d). A ent's Note: Testimon from the other control room operators (REDINGER, (b)(7)(C) , b7c and !(b)(7)(C) I on shift during the November 11, 2015 events contradicts b 7 c statement that none of the other operators had an opinion on removing RHR from service. Once the normal let-down got fixed they reconfigured everything and moved on. !/bl!7l(C} said that they should have just waited until the normal let-down was fixed. About ten minutes after they opened the relief valve and recovered, !(bl/7l(Cl I came in the MCR and thanked everyone for not letting the plant get out of control. !(bl(7l!Cl I said it was clear that !(bl(7}(Cl had been in the OCC watching the event on the monitors and knew what had just happened. !(bl!7l(Cl I said the event was not logged and no CRs were written. !fbl!7l/Cl I admitted that he did not check the logs and acknowledged that they made mistakes. !(bl(7l!C) I could not recall who the Unit Supervisor was on the day of the event, but confirmed that later that afternoon, he sent an email to the other Shift Managers telling them , *t...._ (b....,

                                                                                                                 )(7......)(_.

C)_ _ _ _ ____, !(b)(7)(C)  !" The comment on the email about not letting anyone talk you into it was made because it was not his idea to proceed with the heat-up without normal let-down in service. !(bl/7l(Cl I does not believe anyone in the OCC would have put the plant at risk on purpose. However, the lack of experience, knowledge, and schedule pressure all happened because they were trying to see how fast they can get back to making money. !lb)U)/Cl I expressed that everyone knew what he was doing, why he was doing it and what he had to do to recover the plant. !lbl!7l/Cl I stated that at the time all these "smart people" were saying it is "ok" to do it and he !(b)(7)(C) Iwas the only one saying "no" so he talked himself into thinking it was alright because everyone else felt it was alright (Exhibit T-22d). On April 3, 2017, !(bl/7l(Cl I was interviewed by TVA OIG and provided the following information !lbll7l/Ql I said that he recalled ,....!(b__)(7__l(.......c.......) _ _ _ _ _ _ _ _ _ _ _ ___.

                          ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       OI INVESTIGATION INFORMATION 101 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION !(b)(7)(C) Ior l(b)(7)(C) Itelling him to do it on November 11 , 2015. He said that he could not remember which one it was, but he did recall it was the person in the (b)(7)(C) osition. !rb)(7)/C) I ;:ilso said that during the same conversation he was informed that 7 c and !lb)(7}(C) I wanted it done or were for it. !(bl(7}1Cl I said that he let others in the OCC know that he was not in favor of doing it and did not want to do it. lrb)/7\IQ) I said that the OCC knew how he felt. !(b)U)IQ) I told the agents that he could not remember exactly who all he told in the OCC, but he did know it was more than just !(b)(7}/C) I !lb)(7}/C} I added that he has a family to feed (Exhibit T-22e). Interviews of Dennis REDINGER, Unit Supervisor REDINGER, US at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA

!(b)(7)(C)    I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

On November 18, 2015, REDINGER was interviewed by 0 1and discussed that he spent six years in the Navy and worked at multiple licensees including sixteen years at Comanch e Peake where he was an STA and SRO. He came to TVA in 2009 and was licensed in 201 1. REDINGER discussed that the MCR operators did not know what the capabilities of the excess let-down system would be at the temperature and pressure they were operating at on November 11, 2015. REDINGER expressed there was a lack of knowledge among the operators and discussed that the response to their concerns from the OCC was the OCC understood the concern, but they were okay with proceeding forward . REDINGER stated that he wished he pushed back harder but at the time he felt like they did not have enough basis to say they were not going to continue. He expressed that at the time he felt that !lb}/71/C) I was not totally committed to the idea either, but he tried to convey to us that the OCC wanted us to move forward with it and !(b\17)/C} I was willing to try it (Exhibit T-40a, pp. 7-8, 17-38). On January 19, 2016, REDINGER was interviewed by TVA OIG and explained that he was the WBN1 Unit Supervisor on November 11, 2015 and reported to !/b)(l)(Cl I REDINGER stated that since it was scheduled, the OCC decided to use the Excess Let-down System instead of waiting on the normal let-down system. He discussed use of the Excess Let-down S stem rather than waiting on the normal one with licensed operators (b)(?)(CJ

!fbl{?l(Cl                                     Dand no one was comfortable~ w""'       1,,.....,,,.,.

o.,.,, in"""' g"""'1,.....,,.,.u""'e.....,,. o""'c~on cerns regarding the ability to maintain inventory control and the pressurizer. While they did not have enough information that day to tell the OCC that it absolutely would not work, no one felt like it was worth the risk. They discussed it with !lb)U}/Cl I who also agreed that he did not think it was a good idea !tb)CT)(Ql I told them that he was going to tell the OCC that he was not comfortable with the plan to use the excess let-down system. !(bl/7}/Cl I later came back and told the control room that it had been decided to go ahead and move forward so they did. They took out the RHR system and began monitoring the heat-up while trying to maintain temperature and inventory control (Exhibit T-40b). On February 10, 2016, REDII NGER was interviewed by TVA OIG. When discussing the Shift Order, REDINGER was asked to comment on each of the answers to the questions contained

                      ,~e, FeR 1-UBUe 01aeteaURE WIT! ,eu, )l(flf1Re1~1>'<L eF S P  G l :O.la .A:e~n l~J GI lpl),lile, OFFICE OF 1~*~'[TIGMIOP40, REOIOP* II 6 f'f'le l,-L U9!! 614LY           O1 INVESTIGATION INFORMATION 102 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION on the Question and Answer page of the shift order. Regarding the answer given to question number three, REDINGER said that generally that was the information that he provided, but he does not think the he provided the 50-60gpm number. REDINGER said he was not sure where the 50-60gpm number came from and recalls he gave his answers to the questions to I He added that the entire answer (the whole paragraph) was what he told !(b}(7)(C) lfbfjfcl b 7 c I except for the 50-60gpm part. REDINGER said that he did not give that number to He does not know who did or where it came from (Exhibit T-40c). On March 07, 2016, REDINGER was interviewed by TVA OIG REDINGER stated the shift order was written by !(b\(?lfCl I;:ind (b)(?)(C) He (REDINGER) was initially briefed about the shift order by Shift Manager (b)(?)(C) which is the first time that he saw the 50-60gpm number and thought something did not look right. He still does not know where the number 50-60gpm came from . At the time, REDINGER thought the shift order was written to give the operators OE (operating experience) but now he believes it could have been to get everyone on the same page. REDINGER still has no knowledge of where the 50-60gpm in the shift order came from. He was interviewed by Employee Concerns Program (ECP) line by line about the shift order when he realized the statement looked like the information he had written except for the 50-60gpm number. After the interview with ECP, REDINGER ran into !lb)l7}(Q\ I ::ind asked him where the 50- 60gpm came from and !(b)/7\(Cl Idid not re Iy. Discussing the December 15, 2015, email chain between REDINGER and !(b)(7)(C) 7 REDINGER reviewed the email and confirmed that the actions they took to recover the plant were the operator's actions but how they got there in the first place was not the operators' decision. He stated that they were under schedule pressure to move forward. REDINGER confirmed there was a disconnect in what was said in the email versus what was said in the shift order. Specifically, REDINGER stated that the shift order makes it look like the control room made the decision to move forward where the email shows that that was not the case at all (Exhibit T-40d, pp. 1-10). On September 06, 2016, REDINGER was interviewed by TVA OIG, 01, and AUSA. REDINGER advised that using excess let-down had not been done very often. In the situation on November 11, 2015, neither REDINGER nor the other operators had done it before. He stated the excess let-down flow design says 40gpm. He also had heard during training that they had gotten 70gpm using excess let-down. This information came from older guys who had experience in the plant. However, all of these numbers were at full pressure. According to REDINGER, he and the other operators knew they would not get 70gpm and were pretty sure they would not get 40gpm given the temperature and pressure at which they were operating at that time. They were concerned that what they actually got would not be enough to heat-up. REDINGER stated that they could not say it would not work but he and the other operators had an uneasy feeling. REDINGER and the three reactor operators on crew discussed their concerns as a group. REDINGER then talked with the l(b)(7)(C) !(b)(?)(C) Iwho also did not feel good about heating u_p_u_s.,....in_g....,.th

                                                                               ,....e_ e

_x_c_e_ss--,- le.,.... t-....,. do_w _n-."""'E

                                                                                                                      = v-e_ry_o_ne was in agreement so REDINGER and !(bl[?)(Cl              Imet with !(hl/7\!C) I ::ind ex~ressed the crew's concerns. During the discussion with REDINGER and l(b)(?)(C)                              l lfbl(?)(Cl          I did not challenge them and appeared to be taking information from them. REDINGER does not think

'1bll7\(C) I said one way or another whether he agreed with them. REDINGER was asked if he or the crew thought at the time they could get 50-60gpm from excess let down. REDINGER

                  ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 103 Case No. 2-2016-042

OFFICIAL USE ONLY - OI INVESTIGATION INFORMATION said that he did not think they could get 50-60gpm from excess let down. He said that nobody on the crew thought they could get 50-60gpm from excess let down. He stated that while 40gpm design and 70gpm pre-op testing was discussed at some point, the operators all knew not to expect those numbers because it was at 340Ibs of pressure rather than the normal pressure of 2,225Ibs. He stated that 40gpm and 70gpm would have only been at normal pressure and were not numbers for that day. The operators did not know what the actual numbers would be with the plant conditions at that time (Exhibit T-40e). Interviews of !(b)(7)(C)  ! Reactor Operator !(b)(7)(C) I RO at WBN was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA Slabbekorn, US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. l(b)(7)(C) !had been licensed for five years at Watts Bar. He was the operator at the controls on dayshift of November 11 , 2015. !(b)(7)(C) !stated " ... I think there were different theories about whether excess let-down would be enough with RHR let-down out of service. And some people thought it would . We did not think it would, but it did not." When asked to clarify who thought it would work he continued, "OCC. The people directing us to go ahead and start the heat-up for let-down of the line. They believed against us that excess let-down would be sufficient to counter the heat-up and most of our -- not all of the excess let-down is supposed to be" (Exhibit T-01b, p. 8, pp. 13-14). (b)(7)(C) was against movin forward without the let-down system and took his concern to (b)(7)(C) . According to (b)(7)(C) everyone in the MCR with a license was against moving ahead.!(b)(7)(Cl !conveyed the concern to the OCC. OCC said to move ahead. At some point while all this was going on, a comment was made to the effect that "everyone who has a license says no but the people who can fire the licensed people say do it." The license holders are being pushed to do more than they can. If the pushing does not work out, then the license holders get blamed. The OCC's push to get closer to Mode 3 that day did not work out. The excess let-down system co~ld not do the jo~. The temperature rose and those in the MCR could not get the inventory out. ~b)(?)(C) Jtold TVA OIG that he did not tell the 01 the whole stor during the interview. He did not tell the NRC about TVA management pressure. (b)(7)(C) was told by the TVA lawyer prior to the interview not to expand on his answers.

------.----..i..;.;;  fe;.;..;

lt...i;;.;..; re~ssure from the TVA lawyer not to tell the NRC about the front-end issues. (b)(7)(C) did not want TVA to think that he was not a team player. He said that around the same time that he was interviewed by the NRG. TVA issued a shift order which explained what happened on November 11 , 2015. l(b)(7)(C) lread the shift order and found it to be factually incorrect. He said that the shift order really did not describe the facts which took place on November 11 , 2015. It is his opinion that TVA generated the shift order, so the NRC could read it (Exhibit T-01a pp. 1-3). In an interview follow-up email on January 27, 2016,l(b)(?)(C) !provided clarification on information provided in the shift order. Commentin on the answer to the question "Did the crew expect the condition that occurred." (b)(7)(C) responded, "This is backwards. The

                        ~40f FOR PUQbl 01 bQYRI! W IT I IQYT ,A,PPRQVAb Q~
              ~ P  G I Ala .A/e  ~IT       l~I Gl::slARt;;;F, QFiFilCF QFi l~IHF~Tlt;;;ATIQ~I ~, REGION II 6 f'f'le llllft U~f! 6I4Li - OI INVESTIGATION INFORMATION 104 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION crew did expect level to rise because we did not expect 50-60gpm from excess let-down at that pressure. That was a main argument we used against the plan." When commenting on the listed actions taken, specifically, "Oversight watches have been established in the MCR." l(b)(7)(C) I commented 'The people who pushed us into it [November 11 ,2015 event] were in the MCR around the clock for about a month [afterwards] to make sure we did not decide to go and do anything that foolish again" (Exhibit T-01a, pp. 14-15). did not think the crew could get enough water out because excess let-down is -...-----T....---........ es,gne or 20gpm but could not prove it and he felt the OCC had been looking at it closely and crunchin the numbers based on !rblf7lfCl I statements concerning capabilities of excess let-down. (b)(7)(C that he and the crew knew they would not get 50gpm out of it. However, since (b)(?J(C) could not research it at the moment, he felt the people outside the control room were helping the crew research it. Where it [shift order] said the crew thought they should be able to get 50 to 60gpm on excess let-down but in reality, the o erators were arguing against it because they did not think it was ossible. No one talked to (b)(?)(C) for information on the shift order. However, (b)(7)(C) does not recall anyone in the control room talking about how they could get 50 to 60gpm out of it if they were not at full pressure. They all felt like excess let-down would not work but they did not know the severity or how fast it would all happen (Exhibit T-01c). Interviews of i(b)(7)(Cl IReactor Operator

!(bl(7)(C)   I RO at WBN was interviewed on January 27, 2016, and September 19, 2016, by 0 1, TVA OIG, and AUSA !(b)(7l(Cl                I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

ifbl{?)(Cl I was licensed in (b)(?)(C) and worked on in the MCR on November 11, 2015.

!lblU)(Cl I explained that he was (b)(7)(C)                  and did not have a lot of experience. ,...!

(b-)(7-)(C _J_I did recall that after the rod dropped days prior to November 11, 2015): ilb\(7)!Ci I got the crew together and chewed the crew out for not doing enough to get them back online. So, when November 11, 2015, rolled around!(b)(7)(C) ~ id as he was instructed. He took RHR out of service. He said they had no blueprint to go off of since it was such an unusual alignment.

!lbl<7l(C\ I stated that the excess let-down was in place when the RHR was taken out and he was under the impression that it would take water out to keep the plant from going solid.
!lbl/7\(Cl I does not know why the decision was made not to wait for the normal let-down system but stated the operators did not wait because "we were being pushed by the OCC (Outage Control Center)." llb)/7}/Q) I stated that this was his first time dealing with an OCC as an Operator. His understanding of the OCC was that they were the people who understood what was happening and it was their job to come up with a plan. He now believes they are there to push and get the work done. lrb\mrci I stated that he should have never taken the RHR out with that situation, but it was his first outage and the shift manager that day had a lot of experience and he said to do it (Exhibit T-23a)(Exhibit T-23b).
                          ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEOIAL AOEPH IPJ 0 1hO.RGE, OFFIOE OF IW.'EeTIQ,A.+IO~le , RGIQ~I II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 105 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews of Hb)(7)(C) IReactor Operator !(bl(7l(Cl I RO at WBN was interviewed on January 28, 2016, and September 29, 2016, by 0 1, TVA OIG, and AUSA !(bl(7l(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. l/b}(7}/C} I had been a Reactor Operator for (bJ(7l ears at Watts Bar and worked on November 11 2015 in the MCR. 7c was serving as a RO that day on the,..!(b-)(-7)-(C-) - ...., (b)(7)(C) REQINGER w13s the Unit Supervisor and Todd (b)(?)(C) was the Operator at Control (OAC). f b)(?)(C) jdiscussed the events that appene on ovember 11, 2015, were only one example where the MCR operators expressed concerns but were told to proceed regardless. On November 11 , 2015, there was pressure being felt in the MCR from the OCC to move from Mode 5 to Mode 4. llb}/7}/C} I stated that l/b}/7}/c} I appeared to be under pressure to move the unit. Since the normal let-down system was out of service, the plant had to rely on the excess let-down system. Licensed Operators voiced their concerns with the plan to move ahead using the excess let-down system. l/b}/7}/Ql I was not for the idea. l/b}/7}/Ql I r,ommunicated the concerns the MCR personnel had with the plan , but the OCC decided on a plan to proceed with the heat-uJ?_. l/b}/'5/C} I stated, "I felt like it was a very bad idea to proceed on." The agents asked llbX7}1C} I why he did not voice his concern stronger and louder. He said that he was afraid of being relieved. He said he was afraid of not being viewed as a team player. !lb}!7}/C) I explained to the agents that neither he nor his colleagues in the MCR that day could point to a rule or a procedure to support their position not to proceed using the excess let-down system. They all just knew it was a bad idea based off their training and experience. llb)(7}/Ql I !.aid that all the OCC had to do was wait a few hours and the normal let-down system would be available. According to !(b)(7)(C) I the work had already been done and they were j ust waiting on the paperwork and clearances to put the normal let-down back in service. lrb)/7}/Cl I suggested that the OCC would not wait and wanted to stay on schedule no matter what. l/b}!7}/Cl I recalled saying out loud "this is stupid" when l/b1/7}!Cl I told them that the OCC said to proceed (Exhibit T-16a ). Interviews of !(b)(?)(C) l Senior Reactor Operator I !(b)(7)(C) SRO at WBN was interviewed on January 16, 2016, and September 19, 2016, by 01, TVA OIG, and AUSA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. l/b)l?)/Ql I had been a SRO for ib)(7) ears at Watts Bar, and on November 11 , 2015, he was working as the (b)(7)(C) and in the control room for (b)(7)(C) b7c focus on the plant as it was coming out of the maintenance outa~e. At one point, REDINGER had to leave so l/b)(?)/Cl I relieved him for a couple of hours. Om,ci I told the interviewers about another incident that happened around November 11, 2015. He said that after turnover one ~b)(?)(C/ I called for a meeting with control room personnel. At this meeting, lrb)U)/ l berated the crew saying that we were not pushinffi hard enough on this outage to move the plant forward and were weak. llb}/7\/Q) I said that JJ}!7}/C) I had just gotten chewed out by someone, so rqe;p FeR 1-UBUe 01aeteaURE WITI Ieu, )l(flf1Re1~1>'<L eF 1'1-ECIAL AeEIH 11q Cl IA~eE , OPPICE er llhEaTIeM1e1q(5, l"!~C!IIOlq II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 106 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilbl/71/C\ I decided to chew out the crew after he ~ot chewed out. lrblmrc1 Itold the interviewers that after that butt chewing session !lb 71/Cl ! learned that !lb\/71/Cl I had been scolded by the plant manager for not moving the plant fast enough, hence the reason for

!lbl(l)(C\  ] chewing out the crew (Exhibit T-05b).
!(b}mrc1 I said that he talked to everyone on the Unit 1 side in the main control room that day about heating up without normal let-down being available . None of them thout t it was a good idea. REDINGER was part of that conversation. !lb)U)IC} Icould not recall if !lb (7)/Cl                     I was a part of that specific conversation but he does know that lfb)U)fQl                I recognized that the operators were uncomfortable about heating up. According to !(b)(7)(C)                   I in this instance standing down waiting for normal let-down would have been textbook but would not have gotten them out of the outage fast enourn h. ilb\(Z)!Q\ Isaid that wlhen he saw the "50gpm" answer given in the statement put together by b)(?)(Cl           I !(b)(7)(C)    I and !(b)(7)(C)     I  he could not figure out where that number came from. When he read the number "50" on the document he told his peers that the number "50" was just silly. He added to the interviewers that he did not tell anyone on November 11 , 2015, that he thought they could get that out of excess let-down. The number was totally unrealistic. Speaking of the plant mana:Eer, !ib}(?)!C\ I said on November 11 ,

2015, after the control room personnel stabilized the plant 11 }(?)IQ} I came into the control room and congratulated ever,ane. !lb)U)IC) I recalled !lbl/7}!Cl I saying, "We put you guys in a bad place today." !lbl!7l/Cl gave ilb}m1c1 I a bear hug (Exhibit T-05a) (Exhibit T-05b). Interview of !(b)(7)(C) I, Senior Reactor Operator !(b)(?)(C) I SRO at WBN was interviewed on January 27, 2016, by TVA OIG wherein he provided the following information in substance. On November 11 2015 (b)(?)(C) was workin in the WBN1 as a (b)(7)(C) (b)(7)(C) did not realize theT was a problem with the unit that day until they were fully involved in t~e problem !(b)(?)(C) . stated that he became aware of the issue during the recovery phase. _(b)(?)(C) I said in the past Management did not challenge the more conservative path if in fact that path was deemed by the MCR to be the best path to take. Nowadays, management questions the Shift Managers when the Shift Managers state that they are going to take the conservative path. In the past, WBN's default position was the conservative position because that is the safest position. !(b)(7)(C) Icredits the change to !lbl{?)/Cl I ~nd !/b\(7)/C\ I (Exhibit T-41 ). Interview ofl(b)(7)(C) !(b){7)(C) !at WBN was interviewed on February 09, 2016, by TVA OIG wherein he provided the following information in substance. lrb1mrc} Irliscussed that he was in the Control Room waiting on a briefing about a job he was going to do (taking the RHR out of service), but it was not 100% certain that they were going to do the job. While he was waiting , someone from the OCC came into the Control Room to talk

                      ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 107 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION with !(b\(7\(C\ I llb\(7)/Q\ Isaid this person was !rb\(7\/Cl Ior !lbl(7l(Cl I Althou[ h he cannot say for certain, !lb\[7\/Cl Ifeels strongly that it was more like!~ !rb1r111c1 Ithan !rbl[7l[C _ I This OCC person spoke to !lbl/7\IC\ I in close iliroximity to l(b\/7\IC I llbJ/7\/C\ Icould hear what the person was saying. The ~erson wanted lrb\17 Cl I to speed u~ the heat up rate. libl/7l1Cl I did not want to do it. !(b\(7 C\ I said it was a bad idea. !(b\(7 Cl I brought ufrti}~~)~Crar that the Normal Let Down was tagged out. lcwnrc1 I told the agents that it was clear to that !lb\(7)/Q\ I was "adamant" about the fact that he did not want to do it. !lbl{7){G) I thought Redinger may have been in the conversation as well. !(b\17\/Ql I then had to leave the location for his briefing. !rbl/7\!Q\ I rlid his briefing with !(b)(7)(C) !said to !lb}m!Ql I that the work probably wasn't g!l~~iJi,~ 1appen but they would go ahead and brief for it just in case. After the pre-job ~~;~;/~?*i hovered around the AUO area in the Control Room. Then an hour or so later, was told to take the actions necessary to take the RHR out of service (Exhibit T-20). Interviews ofl(b)(7)(C) (b)(7)(C) at WBN, was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA b 7 c US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. l(b\17\/Q\ I was interviewed by TVA OIG on February 2, 2016, and discussed that on November 11, 2015, he was working. !lb\(7j(C\ I!';tated that he remembers that day fairly well because the normal let-down system was not in service. He was in the OCC working with the OCC team but cannot recall who else was present with him and remembers they were trying to determine what the plan was moving forward. !rbl/7l/Cl I does remembers having several conversations with (b)(7)(C) stated there were basically three options: (1) stay in Mode 5 and wait until t e normal let- own was back in service or (2) heat-up to Mode 4 and stay on RHR or (3) do option 2 and then take RHR out of service and the cooling mechanism would be the main steam dumps. The decision was made to go with option #3. !lb\(7\/Cl I stated that he attended all of the OCC meetings that ~biW~ar~where they discussed the options. He does not remember any real push back on movin . !lbl(l)(Cl I advised that it is important to stay on schedule because the unit is important to the fleet. He stated that there is a balance between schedule and safety and any delay on getting the unit back online meant TVA must purchase power. He stated this is no different than all other utilities. !rb)(7)(Cl Istated that they were originally supposed to move to Mode 4 around 6 a.m. or 7a.m. but the OCC wanted to analyze it some more. According to !(b)(7l(Cl I we all had concerns because of not having the let-down available. !rb1mrc1 I stated that they had to convince l(bl!n(C) l in OCC because all delays or changes in schedule had to be approved by !lbl(Z){Ci I i"::,b==\17:::}(C==l==-. stated that they were already delayed so the OCC team came up with a plan for llb)U)!C\ approval that decided what to do after the delay (Exhibit T-21a). llb\17\(Q\ I was interviewed by TVA OIG on February 10, 2016, and did not recall anyone in particular being concerned with moving forward with heating up the plant on November 11 , 2015. While he did not specifically recall either !lbl(l)(C\ I or REDINGER telling him they were uncomfortable or that they did not want to take the RHR out of service, he did admit there was some pushback with operators asking questions about the effect of doing this without normal

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         O1 INVESTIGATION INFORMATION 108 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION let-down. In addition, !(bl/7l(Cl Isaid "he did have some healthy challenges with !lbl(l){Cl I in the control room" about this issue. However, !lbl/7}/Cl Istated "I did not get off [sic from] these conversations that they were uncomfortable with this." He further clarified that they did not tell him at any time of the day that they did not want to do it. !lbl(7l/Cl Iwas asked about pushing rnressure) which he stated that pushing is common and "I have had much worse." In Umrci I opinion, operations are not doing well because there are some fundamental areas with operators' performance and they have failed to correct the low-level behaviors. Some examples of these include communications, responses, and board monitoring. !(b)/7}/Cl I believes the only recent event that could even remotely be associated with pushing would be the RHR event because the whole OCC team was pushing to move forward. Other issues like the source range instrument bypass and the PORV lift are only due to operator error and level of knowledge issues. According to !(b)(7J(C) I Operations knows the knowledge level is lower than it should be, and that management needs to be in an oversight role to make sure the people who do the actions understand what they need to do. While these oversight managers may not have an active license or be a license holder, they have the required knowledg e from past experience to make decisions and assist in what ha ens in Operations. !(bll7l(Cl I believes it is inappropriate for someone to sa that should not be involved in the control room decisions since he is the (b)(7)(C) and is very knowledgeable (Exhibit T-21 b). !lblU){C} I was interviewed by TVA OIG on June 30, 2016 and recalled having a conversation with !(b\(7\IC\ I in the control room and that !lb)(l)(Cl I challenged him but was "okay with moving forward after our conversation." This conversation ha~ ened at the horseshoe by the unit supervisor's desk while there were other hleople around. ]?)(C} I::ilso believes the unit supervisor (REDINGER) was there as well. !(bJ?)(Q) Istated that their concern was about the effect moving forward and heating up would have on the plant with the normal let-down out of service. He stated that at no time did either !/b}(7l(C) I or REDINGER say they did not want to do it nor did anyone seem adamant about anything. If they had, !lb)(l)(Cl I would have sto~ped and tried to understand why. He does not recall any other conversations with !(bl/7/C) I and knew there were challenges from the crew about what did the effect of the temperature rise on pressure level. !lbl(7l(C\ Itestified he did not feel anyone was uncomfortable but rather more concerned about whether they were technically doing the right thing. !lbl/7}/Cl I had been talking to !lbll7\(Cl I on a regular basis that day about what was happening. In addition, !rbll7HCl Iwould have been in the OCC frequently that day. !lbl(7}/C} I stated that !(b}(7}/Cl I was for moving forward that day, but the decision was made by !(b)(7l(Cl I !/b1(7)fC} I stated that he and !/bl(?)(Cl Iwere good with moving forward that day because they thought they could do it safely. He stated that everyone was good with moving forward in the beginning but now say how bad the decision was. There have been "a lot of Monday morning f uarterb*a cks" about this issue. !(bl(7l(C) Idoes feel like there was a lot of miscommunication. Jblm(C} Isuggested that the decision was made by !rblffi(Cl I who was the shift manager (Exhibit T-21c). !lbl(l)(C} Iwas interviewed by TVA OIG, 0 1and an AUSA on January 19, 2017, and said that during outapes !(b)(l)(Cl Iwanted to know minute by minute what was ~oing on. In the OCC, !(bl/7l(C\  ::ind !(blr7l(Cl I were part of the Senior Leadership T earn. !lbl(7 Cl Istated that

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AGDH l~J GI hO.RGE, OFFICE OF l~J~'ESTIGMIO~JS, REGlmJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 109 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION information to !rb}(?)(C) I would r o through him !(b)(?)(C) Iwhile decisions went from !(bl(?)/Cl I to l!bl(!)(Cl I !(bl/7}/C Iwould then go to the Shift Manager with the decision. l!bl/7\/C} Isaid that there was discussion in the OCC to remove RHR and allow the heat-up to begin. !lbl/7l(C} Isaid that they had man~ discussions about that in the OCC and in the main control room with the Shift Manager. !lbl(71]l I questioned !(b1(7)/Cl Iabout what was going to happen to the pressurizer level if they took the action. !lb)(?)IC} I had multiple conversations with a few people about that and these conversations took place over the course of a few hours. !lblf7)(Cl !said that the Shift Manger's crew also asked that same question !lb}f7)(Cl I recalled interacting with the Shift Manager and the Unit Supervisor that da{ !ib}U}!C} Ir.ould not recall who else he spoke with in the control room about heating up. !(bl 7}/Cl I estimated 30 percent that day was spent in the main control room and 70 percent of his time was in the OCC (Exhibit T-21d). !lb)(7}/Cl Isaid that they had a lot of conversations in the OCC that day about removing RHR and whether there were any tech specs or restrictions. !lblf7)/Cl Isaid that in the end they could not find any restrictions against doin? it, !ibl(7}/Cl I said that engineering was consulted too. !(blf7)/Cl I said engineering told !lb}mfcl I and the others that excess let-down could handle it. !{b\l?){C} I was asked who from engineering gave him that bit of information. !(bl(?)/Cl Isaid he could not remember who it was that told him that. When asked if there was a gallon per minute (gpm) figure that engineering said could handle it, !rb1(7)(Cl I replied that 20gpm is what he recalled from the system description. !rb)(Z)(Cl I added that no restrictions were located so they decided to do it. !lbl/7}/Cl Isaid that there was discussion in the OCC to remove RHR and allow the heat-up to begin. !fblm/Cl I said that they had many discussions about that in the OCC and in the MCR with !lb)(Z)(Cl I lrbimrq I said he did remember talking with !lbl/7)(Cl I in the main control room and the OCC about removing RHR. ,,b ....-l/7-lr-cl- - , did speak with !lbl/71/Cl I too about the issue, but !lbl(?)(C) I could not recall exactly what each other said. !lbl/7}/Cl I said that !lbl(?)/Cl I and !(bl(7}/Cl I both were involved in the decision and both knew exactly what was going on. !rb}(?)/Cl Istated that both ,..!lb4:}/7~lf::;:C:!:::}:::::::::!-, and !(blf7)/Cl I were in favor of removing the RHR !(bl(7}/Cl Isaid that he spoke to !rblf7l/Cl about it and his crew, but the idea was not !ibl(?)(C} I idea. !lbl(?)(C} Iwas asked by the interviewers if !lb}(l)/Cl I told !lbl/7}/Cl Ito instruct !lbl/7}/Cl I to take the action. !/bH7}/Cl said that !lbll?)/C) I did not tell llb}U}/Cl Ito tell !lb}(Z)!C} I to do it. !{b}U)IC} I said it came about after the conversations in the OCC after which the OCC came to the conclusion do it and !lblf7)/Cl Icommunicated that to !/blf7}/Cl I !rbl/7HCl I stated that he !(b)(7)(C) I went to the control room and told !lb}U)IC} I that "this is the path that we would like to go down because we feel it is appropriate". The interviewers asked !lb1(7)fCl Ito define "we". !(bl/7l(Cl Isaid, "we" were the OCC. !lbl(l)/C} Iwas asked by the interviewers if using excess let down was the safest plan. !lb\(Z)!C} I said using excess let down was not the safest plan and it would have been safer to wait for normal let down to come back in service. !lbl/7)/Cl I said that they concluded thatl(b)(?)(C) !that they could get 20gpm out of excess let-down (Exhibit T-21d).

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY             O1 INVESTIGATION INFORMATION 110 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews of l(b)(?)(C) He described that at 06:00 a.m., on November 11, 2015, it was identified that the repa;i r of the normal let-down valve had not yet been completed. !{bl(7\[Cl I briefed the OCC that this would did not have the let-down capacity. b c om~~~tfT significantly hinder the heat-up rate and they would not be performing a normal heat-up per the schedule. He stated it would take a much longer time to slowly heat-up because we figured that they could heat-up the plant at a rate of 75 degrees per hour using the normal let-down system, but the excess let-down system was limited. flh)U)fCl I figured that by using the excess let- * - at a rate of 10 degrees per hour. !(bl(7)/Cl I stated that (b)(7)(C)

  !(b)(?)(C)                          !at WBN and he made the......,_.e_c....Is....1o

_n_t.,...o...,....e_e_p_g_o.,.. m_g_w

                                                                                                                    ...,1.,...

t ..,t,,.-- e_s_c...e.....,..u....e....., and start heating up with what we had in place and not wait for the next one [normal let-down] knowing there would be a schedule delay to critical path (Exhibit T-18, pp. 8-12, p. 15)(T-31). Interview of l(b)(?)(C)

  !!h)Ul[Ql     I stated the decision to forge ahead that (b)(7)(C) using the excess let-down system was a team decision. !(b\(7\(CJ             Ithinks that if he , no ink the plan of using the excess let-down system would work then they would not have tried it. He stated that going to the excess let-down system is not a normal thing and not the preferred method. According to lfbl~lf cl     I there was a good amount of discussion about whether or not it could be done.

b c I continued by explaining that sometimes decisions are made outside of the OCC. He stated that it could have been either the !!hlU)!C} I or ((b)U)fC} I because the OCC sometimes relies on them. ((bl/7l{C\ I said that he did not make the decision and he does not believe that !{bl(7\(Cl Ior !(b}(7\[Cl Iwould have made the decision either (Exhibit T-19 ). Interviews of!(b)(?)(C) IShift Manager

 !(b)(7)(C) !Shift Manag er and SRO at W BN, was interviewed on multiple occasions by 01, TVA OIG, and AUSA !(b)(?)(C)           I  US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

(b)(?)(C) was licensed in ~ and has been a Shift Manager since ~ When (b)(?)(C) arrived at wor on November 1o,'201 5, for the (b)(?)(C) there were two major things that were on the schedule for the !lbJ/7}/Cl rto get done: or o do on the Let-Down System so the night crew needed to take the Let-Down flow path out of service; and 2) Heat-up the plant (move from Mode 5 to Mode 4). !(b}(7}(C I decided to do only the first th ing. He told the agents that in his mind the let-down,trr~~eT was out of service, so he did not want to heat-up the plant without it being in service. b 7 c explained that the concern in heating up had to do with water

                       ,~ef FeR 1-UBtle 01aeteaURE Wlf l 1euf )l(flf1Re1~1>'<L eF SPECIAL AOEIQI !IQ CHAl":O~. OP'P'IC~ OP' llhE~fleMIem~. ~EOleN II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 111 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION management. He explained that water expanded a lot when it heats up, so you must either drain water or not heat-up. !{b)(?}(C I did not think it was a good idea to heat-u with the let-down system out of service and recalled !lb)U){C) I suggested they could just wait. (b)(?J(C) could not recall who he talked to in the OCC about his decision not to heat-up the plan , u e did talk to someone. He recalled talking to the OCC about the let-down system being out of service. They had a good discussion about it and that was it. (b)(?)(C) ecalled telling the OCC that he wanted to stay in Mode 5 because they only had excess e - own. According to !(b)(7)(Cl with low I pressure and low temperature the expectation was to only get around 15 to 30gpm using the excess let-down. Specifically, he remembers discussing this with the OCC that night and telling them that the reason they had to stay in Mode 5 was because of the inability of excess let-down to do more than 15 to 30gpm (Exhibit T-46a)(Exhibit T-46b). Interviews ofl(b)(?)(C) IOCC Operations Representative !(b)(7J(C) I Shift Manager, l(b)(?)(C) Jand OCC Operations Representative at WBN, was interviewed on December 18, 2 15, January 19, 2016, February 4, 2016, and October 3, 2017, by 01, TVA OIG and AUSA !(bl(7)(C)  ! US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. (b)(?)(C) On November 11, 2015, !lb\(7)/Cl Iworked as t e b7 c perat,ons epresen at,ve whereby he coordinated with several ent,ities associated with the operation department to ensure there was the proper support for the outage. !(bl(Z)IC} I said that he clearly remembers that on November 11 , 2015, the maintenance work was not finished when it was decided to transition into Mode 4. !lb}CZ}/Cl Itestified that he remembered looking into whether the transition without let-down would affect the procedure. !(bl/7}(C} I stated that he asked himself and others (NFI) in the MCR, "Is it some type of violation, is it something we are forbidden from doing and there had been quite a bit of talk in operations about that very fact." !ibl/7}/Cl Iadmitted that he cannot remember if he talked face-to-face with !(b)(7)(Cl I or whether it was by email about moving forward. Also, !lbl0/Cl I admitted that he spoke quite a bit with !(b)(7)(C) I Shift Manager of WBN1 about not only heating up without normal let down, but the other things that were going on that day (Exhibit T-17a, pp. 2-9, pp. 11-17). When asked if !lb\(7)/C) I had conversations with !lb\(7)/C) I throughout the day ilb\(7)/C) responded, "Yes, I would say, on average, probably -- and this is not just that day, it would be any day you could call the shift manager anywhere from ten to thirty times, depending on what was going on." !lb)(?)/C) I !':tated that he had no prior experience in a start up without normal let-down being available. In fact, reflecting over his career he could not recall anytime where he remembers taking an action with only excess let-down. !lbl/71/Cl I suggested that !lb}(?}(Cl I was also inexperienced with this condition , so they had some conversations about whether this was "okay" and !ib}CZ}/Cl I indicated that he shared with him what he had found. !lb}/7)/C} I

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         01 INVESTIGATION INFORMATION 112 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION testified that they discussed their understanding of the system and the opinions from operators that had joined their conversation. l/bl//l(Cl I admitted that, "We did make what I think we will all a[ ree in hindsight, was a poor decision that should be determined that it was not illegal." !/bl(7} Cl I stressed that they made a decision that they believed might have to move slow, but that it would be controllable. l/bl(?l/Cl I argued that the~ believed that they could safely transition into Mode four for excess let-down. !rbl(7}!Cl stated that his clearest memory of the day was making sure the rest of the OCC erha s not the entire OCC but the critical members of the staff, the two managers and then (b)(?)(C) were explained the plan of how to proceed forward (ExhibitT-17a, pp. 19-24). !/bl(7}/Cl Itestified that he told !{b)(7)(C) I that he wanted llb)/71/Ql Ito understand that this was not a normal heat-up activity that they were would go in slow and cautious. ilblU)!Cl acknowledged that a lot of people had access to the plant data and they knew the heat-up limits, and he wanted to make sure that this was not goin~ to be a standard evolution. Additionally, l/bl/71/Cl I reportedly told the OCC and !rb)/7 Cl I that it is not going to be the normal heat-up they were accustomed too, and they may have to stall out at some point and just sit. According to !(b)(7)(C) I no one appeared to have any problem with the plan and there were not any additional challenges regarding the decision to proceed forward. Ultimately, !/blf7)/Cl I stated that they ended up transitioning into Mode four and at a certain point noticed the pressure riser level was coming up but the MCR got it stabilized. !lbl(Z)/C) Itestified that his initial assumption at that time of recovery was that the MCR just turned off the RHR, so it probably took them a while toJfret a little bit of heat to be able to control the level. lrbll7l/Cl I recalled a conversation with lrb mrc1 I whereby !/b1m1c1 Itold Kbl~)(C)  ! "Hey, it looks like you all are managing this okay," ancl l<blr7l1Cl ) responded to l(b)(7l(C j "Here is what friggin' happened" which lead to a discussion detailing how the MCR actions had to put RHR let-down in service. !/bl/7l(Cl I stated that he shared information with key OCC people but cannot remember if he did that in the update format or once again during an informal discussion around the table. Regardless, l/b)(7}/Cl Iacknowledged that he spread the information with a wide audience as to what had happened. !(bl(7}[Cl I suggests that before the end of shift the normal let-down system was back in service or were just about to come back in service (Exhibit T-17a, pp. 25-32, pp. 34-45). l/bl/7l/Cl Iwas interviewed by TVA OIG on January 19, 2016. On November 11 , 2015, l/bl(Z)/Cl I role was to serve as the liaison between the MCR and the OCC. The issue that they all faced that day was whether it was acce7ctable to enter into Mode 4 without the availability of the normal let-down ssstem. !(b)(7[Cl  ! said that both he and !/b)(7)(Cl  ! were not comfortable with doing it. !lb)(7}/C_ Isaid that doing what the OCC wanted done that day resulted in WBN1 moving into unfamiliar territory. What ended up happening was that the excess let-down system did not have the ca~acity to do the job. When asked who made up the OCC core team on November 11 , 2015, !lbl/7 /Cl I said that !lbl0(Cl Iand !/bl(7}/Cl I were there. !lb)/7)/Cl I said he could be mistaken but he thought ilblr7l/Cl I was seated in the engineer's chair at the OCC that day. !/blf7)/C) I also thought that j(b)(?)(C) j was in the OCC. !/bl(7}/Cl Iridded that they made a poor decision that day. !(b)(7)/C) Isaid that he and !/bl/71/C) I had telephone conversations that day about the decision. !/bl/71/Cl I was fully aware that !/blf7)/C) I was not for the decision. According to !(b)(7)(C) I the decision placed

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 113 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION the operators in a position where they had to take actions in an area where there were no established procedures. l(bl(7)/Cl I said that he sat the OCC staff down in the OCC and told them that "we are uncomfortable." !/b)(7)(Q) Itold the OCC staff that "we need to proceed with caution." He also said he told them that they do not need to put any undue pressure on the operators. (/b)/7l(Cl I could not recall who was sitting there in the OCC when he made these statements. ilb)l7)(Q) I was asked wh~ the OCC did not wait a few more hours for the normal let-down system to return to service. lib /7)/Cl Isaid that waiting a few hours would have jeopardized meeting the next milestone. !(b)(l)(C) I said the bottom line that dak was that the OCC made a decision based on a business need. In this case, according to l(b)(7 Cl l "we" got out of balance. That balance being between running a business (money) and safety (Exhibit T-17b). !(bl/7)/C) I was asked what happened when the site realized that their plan was not working, l/b)/7)/C) I said that he updated the OCC, and then l/bl/7)/Cl I was forced to do something to counter the mistake. There was no procedure in place for the actions (lbl/7}/Ql Itook. llbl/7l/C) I did not think that there was log kept that day in the OCC or the MCR. He added that "we just whiffed on this one". llb)(Z}/Cl Isaid that they just forgot to make the log entries. He said it was not a cover up, a month or so after the incident, the NRC came onsite and interviewed numerous people concerning the incident. llbl/7)/Cl I advised that the NRC focused a lot of their questions on finding out if the operators acted correctly. There were also a lot of questions about the logs (Exhibit T-17b). The agents asked llb}ffi/Cl I what is going on at WBN that has resulted in the OIG and the NRC showing up, lfb)/7)/Q) I responded that the current desire of WBN management to meet the milestone and to "go, go, ~o, ~o." The OCC cared more about reaching the next milestone than they did about safety. lib /7)/C Isaid that the reactor operators are getting pushed "too hard" by the management team. llbl/7)/C) I does not think that his colleagues feel comfortable expressing an opinion different than that of management. lrb)/7l(C) I concluded the interview by saying that it bothers him a lot that the current WBN management team could not wait a few hours for the let-down system to come back into service ( Exhibit T-17b). ilb)U}(Ql I was interviewed by TVA OIG on February 4, 2016. ilb}/7)/Q) Iadvised that he had learned a lot more since his original interview and is currentlt on the Root Cause team looking into the November 11 , 2015 incident. The additional things @m1c1 I has learned is the result of him talking to others at the site. On the (b)(7)(C) of November 11, 2015, ilb)/7}(Ql I did go into the OCC and meet with the OCC staf . e stated that ltb)/71/Cl I was at the table as was llbl/7)/C) I who was sitting where the engineering person usuall sat. He added that he is *ust about sun~ !ib)(7}1Q\ I was there. He was mistaken that (b)(7)(C) as it was llbl/7)/Cl I At this meeting in the OCC, ...b~7 ...;...;. c.,__"""""___ d~ id~n-o_t _s_ pe-c~if~ic-a~lly- te~ll-th~e~ O~C~C~s-t....._ aff that he was uncomfortable with heating up using the excess let down nor did he tell them that ilb)(7)/C) I was uncomfortable. llb)(7)1¢i I implied that he and lfb\(7)/C) I shared the same level of comfort, that while it was not something they preferred that they thoug ht it wou ld be "ok" to start in Mode 4 as long as they proceed slow and stayed in control. rrwnrcf I testified that does not recall telling the OCC staff not to push the operators. In hindsight, (/bl/71/Cl Iwishes he had done a better job expressing his and llb)/7)/Cl I concerns. !/b}0/Cl Inow realizes

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     OI INVESTIGATION INFORMATION 114 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION that he did not recognize l/b)/7}/C) Iconcern. Likewise, the interviews conducted for the root cause have shown that he underestimated the crew's level of concern that day. l!bl(7)/Cl I stated that an ~(b)(7)(C) Ihas given a statement that he was up in the MGR on November 11, 2015, when he observed an interaction between l/b}l7l/C} I and a senior manager in which lrbl/7}/Cl I told the senior manager that they were uncomfortable. According to !(b)(7)(C) I lfb}Ul{Q} I did not recognize the senior manager, so l/b}l7l/C} I and his team pulled the control room access records. To the end, l(bl(7)/Cl I believes the senior manager was either l(bl(7)/C} Ior l(b}/7}/C} Iwho were both in the control room at different times that day. !rb)U)fQl I stated, "My gut tells me that this was management pressure outside the OCC." In addition to the managers being in the control room, llbl/7)/Cl I stated there were constant phones calls to the control room about what they were going to do (Exhibit T-17c). Agent's Analysis In summary, the 01 investigation found evidence to conclude that while WBN1 was in the process of starting up the plant in November 2015, SM !fb)(Z}fC} I deliberately failed to follow Unit Start-up procedure 1-GO-1 when he authorized WBN1 to transition from Mode 5 to Mode 4 without normal let-down in service and subsequently continue with start-up activities. On November 10, 2015, WB N1 was in Mode 5 and making preparation to transition to Mode 4 in accordance with 1-GO-1, Unit Startup from Cold Shutdown To Hot Standby, when a previously identified leak on 1-FCV-62-70, Normal Let-down Flow Control Valve was determined to need a more extensive repair than originally anticipated. This required the normal let-down system to be removed from service for repairs and the excess let-down system was placed in service. Clearance 1-62-0584-FO was put in place establishing an isolation boundary for the valve repairs. Tags were placed ~0000 on November 11, 2015 and were not restored to normal until ~1600 on November 11 , 2015 (Exhibit A4-E1 , pp. 13, 14) (A4-E2). Procedure 1-GO Unit Startup From Cold Shutdown To Hot Standby Revision 0004, step 5.3 [22] requires 1-GO-1, Appendix B, Mode 5 to Mode 4 Review and Approval be completed before progressing on to Mode 4. Appendix B Mode 5-To-Mode 4 Review and Approval step [3] requires to ENSURE Checklist 1 COMPLETE for entry into Mode 4 . Checklist 1- System Alignment Verification Step B requires 1-SOl-62.01 eves-CHARG ING AND LET-DOWN ATT-1P & ATT-1V be performed (Exhibit A4-E3, p. 48, p. 93, and p. 113). Clearance 1-62-0584-FO invalidated the previously performed Checklist 1 for SOl-62 in that (Exhibit A4-E2)(Exhibit A4-E4, p. 9, p. 16).

• Valve 62-70 was required to be OPERABLE but was out of service
• Valve 62-1235 was tagged OPEN when its required position was CLOSED
• Valve 62-718 was tagged CLOSED when its position was required to be OPEN

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     QI INVESTIGATION INFORMATION 115 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION The investigation identified that !(b)(l)(C) Iwas aware the planned repairs scheduled overnight from November 10, 2015 to November 11, 2015, were not completed and Normal Let-down was not available as expected to continue with the plant startup. The OCC made the decision to continue with 1-GO-1 and transition the lant to Mode 4 without normal let-down in service. On November 11, 2015, at 09:38 a.m., (b)(7)(C) Shift Manager granted permission for WBN1 to proceed with transition from o e o ode 4. 1-GO-1 Section 5.3 Step [22] was initialed by !lb\(7}/Cl I as complete without comment or exception when the system alignment requirements were not met. At 09:54 a.m., WBN1 entered Mode 4. Following entry into Mode 4

         *                                           *    *      *uonal start-up activities IAW 1-GO-1 . As reported b he sent an email at b 7 c       . with sub*ect b c and others which included details of plant operational schedule for the day .

...,__...--.......-m....,.,......1s_s_c,,_,... edule were activities to continue with the steps in 1-GO-1 and perform plant testing. Specifically, operators were to remove the RHR system from service to perform testing in conjunction with a continued plant heat-up. These were scheduled to be performed before normal let-down was returned to service (Exhibit T-42b)(Exhibit T-21 a)(Exhibit A4-E1, pp. 13-14) (Exhibit A4-E5, p. 5)(Exhibit A4-E6). As indicated in the testimonial evidence, none of the licensed operators watch standing for WBN1 indicated they voiced support for the decision to continue with 1-GO-1 and remove the RHR system from service before having Normal Let-down returned to service. To the contrar , most indicated the voiced concerns with the plan. (b)(5) (b)(5) (b)(?)(C)

                                         !(b)(7)(C)

Based on testimonial evidence, 01 finds that !(bl(Z}[Ql Icompelled !lbl(Z}[Ql I to direct the RHR system be removed from service against the judgement and concerns of the licensed

                                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      OI INVESTIGATION INFORMATION 116 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION control room operators. T he RHR system was providing both inventory and temperature control for the RCS when it was removed from service. Due to charging and increases in RCS temperature, pressurizer (PZR) level began to rise uncontrollably. Operator attempts to control temperature and level were unsuccessful which resulted in the PZR level rising to 80 percent. In response, the MCR licensed operators placed RHR let-down back into service to regain control of PZR level. These actions were performed outside of the requirements of plant operating procedures resulting in a previously documented NRC violation 05000390/2016001-05 (Exhibit T-21d, pp. 6-?)(Exhibit T-22d, pp 3-4). On December 18, 2015, 0 1condue ed jnteryjews of WfN em~lor es associated with the events of November 11, 2015. Later that (b)(7)(C) and !rb (7)/Cl Iexchanged emails discussing their 0 1 interviews which included details on information that was either withheld or failed to be honestly represented to 0 1and NRC Inspectors. Specifically, !rbl/7l(Cl I wrote, "What they [NRC] will not know is it was not a site decision it was really a senior management decision and the fact that we have now been conditioned to not challenge current site management poor decisions for fear of retaliation. I am seriously considering re-interviewing and expressing my actual feelings about the current culture and daring them to retaliate against me" (Exhibit A4-E10). 0 1identified throughout the investigation that Watts Bar had been operating in an environment with a wide spread, eroded understanding and application of the requirements of procedural compliance. Furthermore, although it is understood that !/bl(7HCl I actions were influenced by his fear of retaliation from Watts Bar mana~ement, the totality of evidence shows 0 1that while performing the duties as Shift Manager. ibl(?)/Ql I deliberately failed to follow Plant Operating Procedure 1-GO-1 when he authorized WBN1 to transition from Mode 5 to Mode 4 without normal let-down in service and subsequently continue with 1-GO-1 start-up activities. These actions represented deliberate violations of multiple NRC requirements including 10 CFR Appendix B, CR V, Instructions, Procedures, and Drawings and Technical Specification for Watts Bar Unit 1 (Exhibit A4-E11, pp. 1-8). !(bl(l)(Cl I was a licensed Senior Reactor Operator with direct responsibility for proper plant operation. Based on his training and experience, ilb}U}(Ql I had the requisite background and expectation to have understood the requirements of procedural compliance and as a licensed Senior Reactor Operator he was responsible for understanding/mitigating the frotentiall consequences of not adhering to them. Additionally, as the Shift Manager. ilb\ )IQ\ I had the authority and responsibility to ensure plant operating procedures were followed. Conclusion Based on the evidence developed during this investigation, 0 1substantiated thatl(b)(7)(C) I !(b)(?)(C) I Shift Manager deliberately failed to follow Plant Operating Procedure 1-GO-1 when he authorized WBN 1 to transition from Mode 5 to Mode 4 without normal let-down in service and subsequently continued with 1-GO-1 start-up activities.

                   ,~ef FeR 1-UBUe 01aeteaURE Wlf l 1euf )l(flf1Re1~1>'<L eF SPECIAL A(!;l!!IQT IIQ Cl l"<fii.teE, eJFFle E er ltWESTI01RtiflOP40, REGIOP* II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 117 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 5: Subml~ iOQ : f ; ; olete and inaccurate information by TVA Managers on December 14, 2015, to the (b)(7)(C) Iregarding the details surrounding the WBN1 start-up on Novem er 1 , . Applicable regulations 10 CFR 50.5: Deliberate misconduct 10 CFR 50.9: Completeness and accuracy of information Documentary Evidence Email (b)(?)(C) NRC Question Email from !(bl(7)/Cl Ito !lb\/71/C\ I (A5-E1) Email Attachments: l(b)(7)(C) IFrom ilb)l7}/Q) I (A5-E2) Email ____ -------;::::==::::::.....-.. . I. (A5-E3) ___. i(b)(Z)/Q) I RHR question from l(b)(7)(C) CR 1114975 (A5-E4) Emaill(b)(7)(C) ifrom l(b)(?)(C) I(A5-E5) ~E~m~a~il .... l(b_)(7_)(_Cl_.,..,..,...,,,....,,,..,,,.,...._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __,I Email chain from l(b)(7)(C)  !(A5-E6) Email!(b)(7)(C) lwithl(b)(7)(C) notes from !(b)(7)(C) l{A5-E7) TVA initial response to NRC (b)(?) uestions (A5-E8) (C) Analysis of response to NR Questions (A5-E9) WBN Plant Logs from November 11, 2015 (A5-E10) Email (b)(7)(C)  !(b\(7)/Cl Iemail to SROs (A5-E11) Email,____ _ ____. Read while poo'ing from .... l(b_)(7_)(C_l _ _ _ _ _!(A5-E12) 50.9 Info t~ RAFT AV Information (A5-E13)

                             ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                 OI INVESTIGATION INFORMATION 11 8 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Testimony Interview of !(b)(7)(C) (b)(7)(C) was interviewed on August 22, 2016, by Assistant United States Attorney (AUSA) Bart .._......_.....__. U.S Attorney's Office for the Eastern District of Tennessee and TVA OIG wherein he provided the following information in substance. l!b}/7}/C\ I was (b)(7)(C) the initial concern associated with the events of November 11, 2015, from (b)(7)(CJ WB Reactor Operator. !/blr7l<Cl Iexplained that he put the information into the NRC allegation program for agency action. llbl/7)/C} I testified that NRC Region II management instructed him to obtain more information by a "soft pull." llb}U}IC} I elaborated that he wanted to be discreet and inspected the allegation while he continued to interact with l(b}(7l(Cl I in an attempt to obtain more information about what happened on November 11 , 2015. On December 11, 2015, the NRC decided to stop trying to gather information throu h the "soft ull" which lead llbl/7)(Cl Ito di~ecUy ask auestjons to WBY: management (b)(7)(C) and _(b)(l)(C) _). Specifically, on December 11, 2015, b c who was at his home when NRC RI I instructed him to directly ask site manaflement about the events of November 11, 2015, drove back to WBN in an attempt to locate bl/7)/Q} I or llbl/7}/C\ I When llbl(7}1C} I got to the site, he could not find them and recalled that he stayed at WBN waiting to ~ear (caUback) from either l<b1111rc1 I or libl(7l(Cl I After waiting for a while llb}U}/Cl I approached _(b)(7)(C) ] Shift Manager on duty and asked llbl/7)/Cl ] uestions about the November 11, 2015, event. Shortly after having the conversation with b 7 c l<b)<l)(C} I called llbl/7)/C) I wherein llb}/7)/Cl Idisclosed the rnuestions he had asked 7C Approximately 15 minutes after endin& ,~~~jll with b)(7)(C) I llbl/7)/Cl I received a call from llbl(7)(Cl I llbl(?)(Cl I told that he had spoken with l(b){7)(C) l and that l(b)(7)(C) I, ~ a)~ r t ng to get the answers to l(b)(7)(C) l questions. The next day, llbl(?)(Cl Icalled b 7 C to inform him that they (TVA) were running down the answers. On December 14, 2015, l/bl<7l[C1 I provided l/bl/7}/Cl Iwith a two-page document (response) to the questions (Exhibit AS-EB). Also. llbl{7}1C} I learned that daR that a Condition Report (CR) had just been written about the event. llb}/7)/Cl I !'laid that l(bl/7} Cl Iwas not on site the entire day on November 11, 2015, and probably had to consult with others in order to come up with the response as well as the CR (Exhibit T-03, pp. 6-9). Interviews of l(b)(?)(C) l Shift Manager !(b)(7)(C) I SM at WBN was interviewed on February 10, 2016 by TVA OIG and by 0 1and TVA OIG on February 23, 2017, wherein he provided the following information in substance. l(bl/71/Cl Ifirst heard of the November 11, 2015, incident when !(b)(7)(C) I asked l(bl(?)/Cl I questions about the event. kb}01C\ I was not workin that da~, so he had no firsthand knowledge of the event. After llbl<z)/Cl I spoke to b 7 c llb}(LJC) Ic:ontacted (b)(l)(C) Shift Manager, and l(bl{7)/Cl I to let them know about ...................... questions. b C did some

                         ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF i P  G l :O.la .A:e~n l~J GI lpl),lile, OFFICE OF 1~*~'[TIGMIOP40, REOIOP* II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 119 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION research, so he could f et ilb\17)/C\ I the answers. !/b}/7}/C} ! looked at the logs from that day. According to !(bl(7l(Cl _ the logs are a running history of what happens with the units. When ilbl/7\/Q\ !finished his research , he reported his work by email (Exhibit A5-E3) and orally to i(b\/7\(C\ I !/b\(7\/C\ Itold the agents that when he was doing his research he realized that there was going to be a problem because there was not a lot of information in the logs. The events that transpired were not documented in the logs (Exhibit T-34a, pp.1-11 ). !lb}/7l/C} I testified that he was working the (b)(7) shift on December 11 , 2015, when ilb\(7)/Cl I asked about the RHR and its operability. ......,.......,......., recalled examining graphs from the computer monitoring system whereby it showed the isolation valves for RHR had been cycled several times after RHR was secured_ !lb}{7l/Ql I was asked the reason for cyc/;~g,~~e valve to which irb)Q\(C) I told !(b)(7)(C) "I do not have any idea." llb)U){C) I P,Xw essed to 1 1that he would be glad to "look into it." After finishing his shift turnover, !/b\17lS} I began investigating the event and described his first ste~ was to review the graph (data) related to the pressure and tem~erature. Additionally, !lbl(7)1( Ireviewed the procedures reffiarding RHR and heating up. ilb}fZ) Cl I purposely did not consult with anyone from the crew. I111111c, I said, "I do not really see why these were c~cled." Likewise, there was no reference of the evolution in the logs. After several hours, lrti 7)/Q} I concluded that he must be missing something in the procedure and asked himself, "What is goinl on?" ((b\(7)/Cl I established who was working in MCR on November 11, 2015, and notified (b)(7)(C) I was also workinri overtime on Unit 2 on the night ltb\(7)/C} I was investigating the event. To that end, !lb\17)/Q) called llb\{7)/C} I over and asked him for insight. According to ~ffi~C) I !(b1(7)(Cl I revealed that excess let-down was in service not normal let-down. Until Ir LI l I disclosed wlhat was going on, !/b}ffilCl I did not realize that excess let-down was in service. llb}/7\/Cl I disclosed that the reactor heating up in low temperature was going to outrun excess let-down because it is not designed for that. Based on his review, ilbl(7)/Cl Idetermined that the unit was heating up just fine and at around 220 degrees and reached the point where they would've taken RHR out of service and allowed system heat-up using normal let-down to maintain volume of the RCS. However, because excess let-down could not keep up, the pressurizer level lhad increased requiring them to open the isolation valves for the RHR system to allow them to use RHR let-down as an alternative to the normal let-down system (Exhibit T-34b, pp. 2-14 ). !(b)(7)(Cl I explained that after determinina the action to lower pressurizer level, he examined what was done to the RHR pump. !(b\17)/ I determined they never exceeded anything that would have affected operability. In fact Hb\17)/C} I stated the highest temperature was around 235 degrees or right around there and gained controL !lb)(7}/Cl I stated that he reviewed the logs which did not have any entries of this activity. !/b}f7l/C} I articulated that excess let-down is designed to maintain level but not to heat-up, however, there is nothing in the procedure which specifically prohibits the action. !lb}/7}/C} !testified that the system is designed between 20gpm and 30gpm, and just enough to maintain water balance but not designed to heat-up. After several hours of R&trn to figure out what was going on, ilbk7)(C) I emailecl ilbXWCI I what he had discovered. b rz Cl I reported that he never reviewed any of the information that was

~rovided to the NRC by ilb}(7)(C}             I ilbll7)/Cl I stated that he spoke (telephonically) with bl(l)(Cl     Iduring their normal (b)(7)(C) telephone call. !(b\(7)/Cl Istated that during the

!(b)(7)(C) !call he disclosed what tie a ound and asked what was going on. !lb}/71/Cl I testified

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 120 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION that he provided !(b)(7)/Cl Ithe information he disclosed and suggested that !/b)(l)/Cl needed to talk to the "f uys, who are [sic] here and go talk to the NRC and see what we (TVA) need to do." l(b\U}/C} stated after this point he did not have any further involvement with the situation (Exhibit T-34b, pp. 16-24 ). Interviews of !(b)(7)(C) (b)(?)(C) at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA b c US Attorney's Office for the Eastern District Tennessee, wherein he provided the following information in substance. When discussing the events of November 11, 2015, lrblW[Ql I made the following statements:

           That very night we came in and I remember the crew saying, yes, we got up to near 80 percent and we had to put RHR /et-down. That was the words. I had to put RHR let-down in. I said that was a great, great, great thought. Put RHR let-down in, reduce level, and then we came in and finished the startup or wherever we were going that night (Exhibit T-07a, p. 49)."
           "I'm remembering back so, I mean, from what I remember it was simply -- This discussion would not have even been brought up again unless somebody had asked a question because when we came in that night what was relayed to me is 80 percent.

We put in RHR let-down. We reduced pressurizer level (Exhibit T-07a, p. 49). " l[b}m[Ql I said that to his recollection when he left work on the ~b: )(C) ~ f November 11 , 2015, things were still "ok". When he returned on the afternoon o ovem er 11, 2015, things were no longer "ok" and he was told they had to put the R HR let-down back in service. He stated that he did not ask if they used a procedure. When !fb\(7)/Cl I found out, it did not seem to be a problem because when it was over it was portrayed in a positive Ii ht with everyone happy and high-fiving that l~~~l~b~1ing was stable . According to b 7 c December 11 , 2015, a Friday night, called llb}U}/C} Iand told hi""m""":t~h....at~~~ had talked to !(b\(7)/C) Iabout some questions !lb\(7)/Cl I had about the RHR event. !lb)r7l/Cl I told !fbl(Z)(C) Ithat !(b)(?l/C) Ihad the questions. The next thing !/b}(?}/Cl Idid was contact l[b\/7\[Q} I to get the questions. According to !(bl(7)(Cl I l[b\/7\[Q\ I had already started to track down some of the answers. !lbl(7}(C} ] said he went to W BN on Saturday December 12, 2015, and took the work already started by !/b}(?lfCl Ito continued trying to get the answers for llb)/7)/Q\ I llb)/7)/Q) I stated at that time he wrote CR's as well (Exhibit T-07b)(Exhibit T-07d). Interviews of !(b)(?)(C) l(b)(7)(C)  ! at WBN, was interviewed on February 09, 2016, and June 21, 2018, by 0 1, TVA OIG, and AUSA !(bl0(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      0I INVESTIGATION INFORMATION 121 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION ilb\(7)CQ) I stated that on !(b)(?)(C) I ilb}[Z)!Ql I contacted !lbl/7}/C} I and asked 1/b}{l)/Cl I about the events of November 11, 2015. That phone call led to ilbl/7l[C} Iand l/b)/7\!Ql Igetting together the next day to have a conversation with lrb)l7}!C) I ilbl/7}/C) Iasked lrbrnrc1 I to explain the questions llbl!7)1Ql I had surrounding the November 11, 2015. i(b)l7)CQ) I explained his questions and based off that conversation, !lbl/7l/Cl Iwrote a Condition Report (CR) (Exhibit T-43a). I According to !(b)(7)(C) during a conference call on l(b)(?)(C) l lrbl{l)CQ) Itold him that he alrl~~d}TI ~ ew that the valves were opened to reduce pressurizer level. lrb)01Ql I 1 indicated that b 7 c alread] knew information rior to notif ing TVA, and it was only when l!b){Z)!C) I informed ifbl/7l(Cl _ on (b)(?)(C) that TVA became aware of the concern(s) surrounding the events of November 11 , 2015. When asked if i/b)[Z)[Ql I already knew the purpose of the c~ valves, then wh did the response not include the reasons for opening the valves, l!lillilW responded, "He (b)(?)(C) did not write this .. .and perhaps the answers in question number three were for additional information associated with different conditions of the valves." Conversely_ lrb){Z)!Q) Isuggested that llb){l)!Cl I had about a month to evaluate the event and had the necessary information. Again, when challenged during the interview, if ilb)U}(Q) I a\~:i~~&j ~ad the information, then what was the reason it was not included in the written response, said, "We were trying to gather our initial thoughts in preparation of corrective actions and the subsequent condition report (CR)(Exhibit T-43b)." ilbl/7l/Cl Istated that he did not challenge the context of the response given that ilbl/7l/Cl I had about a month to examine the event and he understood the system. According to !(bl(7)(Cl I ilb)!7)!Q) I did not disclose how he knew the reason the valves were opened but offered that perhaps ilbl/7l/Cl I obtained the information by interviewing the operators and by doing his own research. lrb)01Cl I claimed that the written response was not discussed or presented to the NRC in any manner other than when it was presented to !lb)U}IQ) I in the NRC resident office. Also, the written response Exhibit A5-E8) was simply internal discussions which happen to be shared with the NRC (b)(?){C) during their meeting lrb)U}/Ql I stressed that the statements were not discussed in subsequent assessments (Apparent Cause, Root Cause Analysis, and CAP) because it was not material as to the concern about the increase of the pressurizer level. ilb\[7)/C) I claimed that he personally did not provide the response to ilb)U)/C) I but stipulates that he was present and suggests that the answers were generated by !lb}(7)/Cl I (Exhibit T-43b ). Agent's Analysis In summary, the evidence obtained during this investigation proves that !lb\(7)/Cl I and ilbl(7}/C} l deliberately provided false information on December 14 2015 to the NRC. The false information was supplied subsequent to an official request from (b)(7)(C) regarding information from TVA surrounding WBN1 plant start-up on November 11 , 2 On December 11, 2015, l(b)(7)(C) !asked WBN's Operations on-duty Shift Manager l(b)(?)(C) questions concerning plant operation including, "Why were the RHR inlet valves cycled?" in reference to the activities on November 11, 2015. The 01 investigation confirmed that the

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF
              -'l9~CIAL AOl!:fqf 11q Cl IA~eE, OPPICE er ll hE~T l eATl er  r, , REOleN II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 122 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ~ rom (b)(7)(C) was communicated throu hout WBN management to include (b)(7)(C) li!illlliQLJ b7C ((bl{7l(C} 1 l and lrbl/7l/Cl _ The evidence established that on (b)(7)(C) !(b)(7)(C) !e-mailed accurate information to ilbl(?}(Ql I regardini the reason for the cycling of the RHR inlet valves that had occurred on November 11 , 2015. _b\(7)/Cl I e-mail exw essed a level of sur rise on the art of b 7 C whereb ((b)(7){C) ! disclosed to !(b) 7l(C) I' (b)(?)(C) " irbl!7\(Q) I email continued documenting that pressurizer level increased and it became necessary to place RHR let-down back in service to lower pressurizer level. "!(b)(7)(C) I b7 C (b)(7)(C) " Condition Report 1114975 was subsequently initiated to document (b)(?)(C) concerns and TVA's responses. Information concerning the loss of control of pressurizer level was not included in the CR and was not entered into the Corrective Action Program as required (Exhibit T-34a)(Exhibit A5-E1) (Exhibit A5-E2)(Exhibit A5-E3)(Exhibit A5-E4 ). On (b)(?)(C) irb}(l)(C} Isent an email to himself containing a drafted response to questions raised by (b)(7)(C) concerning the o eration of the RHR system during the November 2015 maintenance outage titled '!(b)(7l(C_ 7 f'. The drafted response did not contain information concerning the loss of control of pressurizer level. ((bl{?)/Cl I subse uentl sent an email to !(b)(?}/Cl I containing an altered version of '1(b)(7)(C) I (b)(7)(C) ' which not only failed to include the loss of control of pressurizer level as the accurate reason the RHR valves were cycled, but now contained false information about the reason the RHR inlet valves were c cled on November 11 , 2015. l<bl(7)<Cl I also sent an email to ((b)(7}(Cl Iwith ' (b)(?J(C) ' attached which contained the false information about the reason the 1n e va ves were cycled on November 11 , 2015. l1b1mrc1 I sent an email to !(b)(?)(C) I which contained the accurate (truthful) information indicating the RHR inlet valves were cycled to manage pressurizer level but also included the false information about the reason the RHR inlet valves were cycled, that was received from JIMol,l.ol.lo,I_ _____. !lb}(l)/C} I noted that the inaccurate information was to be included in response to (b)(7)(C) questions. It was intended for !(b)(7)(C) !to present this information to NRC executives (Exhibit A5-E1) (Exhibit A5-E2)(Exhibit A5-E3)(Exhibit A5-E4)(Exhibit A5-E5)(Exhibit A5-E6)(Exhibit A5-E7). On December 14, 2015, in relcx7) t,o l(b)(?)(C) !insp ection activities and follow-up questions, lrbl/7l(Cl I and ilb\(7)/C\ Imet b 7) c in the NRC ((bl(!)(C) !office and provided a written response. This response did not contain information about the loss of control of pressurizer level but rather provided an alternate reason for opening the RHR inlet valves on November 11, 2015. The response stated the reason the valves were opened as "This was done to allow the repair of a valve inside containment on the normal let-down line ~1-FCV-62-70)." On December

14. 2015. !lb)(7}rC) I sent a copy of the email sent to !(b)(l)(C) ho lum1c1 Iand his su ervisor d(b)(7)(CJ b. This email also included a request to hold a meeting with the llbl(l)ICl the delivery of this information to !(b)(7)(CJ !(Exhibit T-43b, p. 3)(Exhibit A5-E6)(Exhibit A5-E8, p.

1_ to plan 2). During the investigation, 0 1conducted a detailed review of the written answers provided on December 14, 2015 to l(b)(?)(C) lin response to the questions. This analysis highlighted

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF
             ~ P  G I Ala .A/e  ~IT l~I GI lpA,lilGE, QFFIQ[ QF IW.'EeTIG,Ai+IQ~Je, AEGlml II 6 f'f'le l,-L U9!! 614LY           OI INVESTIGATION INFORMATION 123 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION significant disparities in how the various questions were answered providing clear examples of how the responses were incomplete and inaccurate. Using control room logs and plant data records, 01 developed evidence that confirmed the cycling of the RHR inlet valves was not to allow for the repair of 1-FCV-62-70. The repairs of 1-FCV-62-70 had been ongoing prior to the specified valve cycling and field work was completed (1147) on the valve prior to opening the RHR inlet valves (1419). The valves were verified to have been opened to arrest a rising pressurizer level (Exhibit A5-E9)(A5-E10). Following the meeting with!(b)(?)(C) Isent an email to WBN Senior Reactor Operators demonstrating that he understood the truth of the events of November 11, 2015 (Exhibit A5-E11 ): (b)(?)(C) Addjtjonallv o~ !(b)(?)(C) Isent (b)(?)(C)

 !(b)(?)(C)             j an email which included many rea._s_o_n_s -w-:-h-y ~b~ ~-...,.-:b-e-:-:-lie_v_e"""'d:--:-
                                                                                                              . h-e_w_a_.s failing TVA and would understand being fired. One such example was his actions surrounding the investigation into the events of November 11 , 2015. He included the excerpt below seemingly indicating his actions following November 11, 2015, were a "cover-up" (Exhibit A5-E1 2):

l(b)(?)(C) In totality, the evidence establishes to 0 1that !(b}(7)/C} Iand !(b}(7}(Cl Ideliberately provided incomplete and inaccurate information to NRC !(b)(?)(C) Iabout the reason the RHR inlet valves were cycled. This information was material because had TVA senior managers conve~ complete and accurate information to the NRC during the December 14, 2015, meeting with ~ (llifil[] the NRC would have conducted additional and/or more timely reviews into the November 11, 2015 heat-up event. It would have also affected NRC reviews into TVA's cause analysis and corrective actions (Exhibit A5-E13). Conclusion ce develo ed durin this investi ation, 01 substantiated that TVA managers, (b)(7)(C) and (b)(?)(C) deliberately submitted incomplete and inaccurate information to the NRC. Specifically, on December 14, 2015, !(b}(?}(C} I and

  !lbl(?}[Cl Ideliberately provided a written response to !(b)(?)(C) ~ hich did not contain information about the loss of control of pressurizer level as the reason for opening the RHR valves during the start-up of Unit 1, but rather reported that the reason the valves were opened was to allow for the repair of a valve associated with normal let down.
                            ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 124 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 6: Submission of incomplete and inaccurate information by TVA Managers to the NRC in response to NRC questions concerning the November 11 , 2015, RHR event as documented in Shift Order 15-50 and presented to the NRC during a site visit in January 6, 2016. Applicable Regulations 10 CFR 50.5: Deliberate Misconduct 10 CFR 50.9: Completeness and Accuracy of Information Documentary Evidence Email (b)(7)(C) REDINGER interview notes sent by ... l(b_)(7)_(C_l_ _ __,kA6-E1) Email Updated questions sent by !lbl(Z)ICl I (A6-E2) Email (b)(?)(C) sent by !(b\17\/C\ I (A6-E3) Email ~ ent by !lb}f7}1Gl I (A6-E4) Email *1(b)(7)(C) t*, exchange between !fb)U)fC} I ancl !lb}WIGl I (A6-E5) Shift Order 15-50 (A6-E6) Analysis of Procedures and Training with attachments (A6-E7) Emai I (b)(?)(C) (b)(?) WBN U1 1100 Ma int Outage in !lb\CZl(Cl I and !/b}/71/Cl I (A6-E8) (C) Emai I  !(b)(?l(C) I Outage Update Reply !lb}!7}[C} I (A6-E9) Emai I EmaiI

                    !fb}f7\(Cl
                                    !(bl(?}(C}       I sent Outage Lesson Learned (A6-E10)

I to !lbl!ZlrGl _ _.I RHR statement (A6-E11) EmaiI (b)(?) REDINGER statement to !lblWIQl (C) I (A6-E 12) EmaiI IIfilillil Level 2 interview notes given to management (A6-E13) Emai I (b)(?)(C) Iemail on shift order (A6-E14) Allegation 2015-A-0214 Attachment 4 (A6-E15) Emaij (b)(?)(C) sentyj(b)(7)(C l(A6-E16) l(b)(?)(C) ISlides 1/6/16(A6-E 17) Draft Apparent Violation for 010616 meeting (A6-E18)

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                      O1 INVESTIGATION INFORMATION 125 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Testimony Interviews of !(b)(?)(C) !Reactor Operator l....(....irr...ii...i............I l us (bb)rl(cC) RO at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA following information in substance. Attorney's Office for the Eastern District of Tennessee, wherein he provided the l!b}/7}/C\ I has worked as a RO, at WBN since~ On November 11, 2015, libl0CCJ I was working on WBN2 and had walked over to the WBN1 side of the MCR to offer assistance as WBN1 was working through a maintenance (forced) outage. According to !(b)(7)(C) I when he arrived at the WBN1 side of the MCR, the RO (NFI) was in the process of using the RHR let-down as the method of controlling the RCS level. That condition, lead !rbl/7}/cl Ito begin asking questions of the RO and proceed to walk the board in an effort to understand the situation . l/b}(7}/C} I said that he soon realized the RHR temperatures were higher than normal which caused him concern. At that point, l/b)(?l(Cl Iraised his concerns to the SRO's. l/bl(7}/C\ observed there were alarms and temperatures that were abnormal as he discussed his observations and expressed his concerns on what he thought needed to be done. According to

!(b)(7)(C)                  I the RO's had agreed with !/bl/7)/C}          I observation and indicated to !/b}(7l!Cl Ithat they had voiced similar concerns but were overruled by "those above them." l(b\(7)/C} I explained that the RO's discussed how could they get out of the situation and utilize RCS cooling (Exhibit T-02a, pp. 4-12).
!/bl(7)(Cl                 I stated that as he walked into the MCR, they were starting to align RHR let-down and the suction valves from RCS were alread opened which lead him to ask questions. l/bl/7)/Cl I recalled that b c                                                       on duty and the US, REDINGER, was running the procedures. b                                   testified that he clearly voiced his concerns related to the reason the suction valves from RCS were o ened and the high-pressure alarm. Accordin to b 7 c                                                he told SM !/b}(7}/C}                        ! "I (b)(?)(C)    said this is not the right thing to do he (b)(?)(C)           would not really answer me." b 7 c                                 acknowledged that he was full of suggestions to ...b............

C.___. which were more than !/blf?)(C) I cared to hear. Eventually, l/b)(7)fC} I directed the heat-up to stop as the temperature approached 235F (Exhibit T-02a, pp. 11-19). Additionally, !/b}(7}/Q) I stated the let-down system was in service with RHR pumps on RCS cooling Mode while normal let down was tagged for maintenance. llblU}!Q\ ] testified that he was not part of the decision-making process to secure normal let-down on WBN1 and was not present inside the OCC during the period in question. Likewise, !fbl(l)fCl I stated that he was not assigned to WBN1 on November 11 , 2015, but on his own accord decided to walk over from WBN2 to offer his assistance with the evolution. !/bl(7)/C\ I described the MCR as "hectic." In particular, the operators were uncomfortable relative to the RHR temperatures and the rise in the pressurizer. When asked if there was "command and control" from the shift manager and the SRO's regarding the activities, !/b)(7}/C) I said there were some disagreements as to should we be doing this that the SROs expressed. !/bl(7}/Cl I stated that it was not a proactive environment but rather a reactive one as operators were simply trying to get a handle on what was going on with the plant. When asked how did the let-down system impact (challenge) the

                                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH ltJ 0 1h0tROE , OFFIOE OF ltWESTIOMIOtJO, REOIOtJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 126 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION operators, !(b\(7\(C\ I responded , "The biggest challenge was not being able to control the pressurizer level on the heat-up." Specifically, the furessurizer level rose from 40 percent to nearly 80 percent before any action was taken. 11 (7)/C} I suggested that the excess let-down is limited relative to its design and only suitable in certain plant conditions. Also, the secondary side had nothing to offer to cool the plant down and when the heat-up was stok&ed all the steam generator atmospheric dumps were opened and the steam was dumped. llb)Ul I stressed the pressurizer level was in a dangerous place without the ability of normal let-down. !rb}/7\/Cl I said, "Had they stayed within the bounds of the GO procedure they would not have had any concerns with the (heat-up)" (Exhibit T-02b, pp. 9-15, pp. 17-23). !lblU}IC) I stated that at the end of the shift, !(b)(7)(C) I verbally thanked !lb}U)IC) Ifor getting "loud." Althou h (b)(?)(C) never articulated that he was confused or did not understand the procedure, b 7 c questioned !lbl!7\[Cl I about the capacity of the excess let-down system and em~hasized he should have waited for the normal let-down to return to service. Accordinf to !(bl(7)(Q I !rbl{7)[Cl Itold !(b)(7)(Cl ! "That he was doing what he was told to do." !rbl{7}[Cl said that under the current management at WBN the main concern was reaching the next milestone. ilb)U)/Ql I sugf ested that bonuses and promotions are all tied to milestones which causes some risk. !lb}/7}rC I::idded that the OCC placed WBN at risk on November 11, 2015, as MCR did what the OCC wanted. It was the MCR that recovered and stabilized the plant. When asked what could have happened, ilbl(l)IC) I stated they could have released radioactive water outside of the reactor coolant piping (the reactor coolant system boundary). Furthermore, !rb1mrc) I implied a component could have failed given the higher water temperatures and pressures. Additionally, there were potential environmental damage as the plant would have been less safe because one less barrier was available. He stated that this is probably the second worst thing that could happen next to releasing the radioactive materials into the environment (Exhibit T-02b, pp. 25-28) (Exhibit T-02c). Interviews of!(b)(l)(C) l Shift Manager l iIT....i1...i.__.ll (bb)m(Cc) .._j..... SM at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. Agent's Note: In his initial interview with 01 on December 18, 2015, ![bl(7)[C\ I failed to provide the same level of detail and specifics as he provided in subsequent interviews. On December 18, 2015, !rb\(7}/C) I was interviewed by 0 1C9.fil..!llilllliUD~~~.QL_ __ November 11, 2015, and rovided the followin information. (b)(?)(C)

                            ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 127 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION heat-up and pressurize RCS and enter Mode 3 at some point during that day or that night. The normal let-down system for CVCS was out of service for repair to a leaking valve and they had placed the alternate let-down system, excess let-down, in service for let-down capabilities. Other than that, all the other plant conditions were normal as to be expected for Mode 5 and Mode 4 (Exhibit T-22a, pp. 4-11). !/blll)/Cl I discussed that nobody raised any concerns nor did any of the crew have any questions or concerns about trying to do a heat-up on excess let-down. !/b)ll)(Cl I explained that the crew discussed the fact that they had not done it before and were willing to start it and see how it went. !/b}/7}/Cl I stated he thought they had enough excess let-down flow to be able to control pressurizer level on excess let-down. When asked about the crew's reaction to planned events of the day, !lb}U}{Cl I stated he did not remember any big push back from the crew. However, kbl/7}(C} I remembered being a little bit anxious continuing the start-up activities with only excess let-down because he had never done it like that before and was not one hundred percent sure that it was going to go the way that he anticipated it to. kb}(7}/Cl I reasoned that he did not challenge the path to move forward because he had no basis for saying it would not work. When asked about influences on his decision concerning schedule pressure or any information coming from outside the control room that might have unduly influenced him in his decision he stated he did not remember any specific undo pressure (Exhibit T-22a, pp. 15-19, pp. 21-40, pp. 43-56). On January 19, 2016, !/bl(7}/C} I was interviel'=u...u.11..JiVA OIG and provided the following information !/b}m/C} I explained that on the (b)(?)(C) of November 11 , 2015, WBN1 was at Mode 5. WBN1 had just reassembled the reac or an he temperature was less than 200 degrees. OCC directed the MCR to move to Mode 4 which would have kept the site on schedule. The operating crew moved to Mode 4 as planned and as instructed. !/bl(7}/C) I further explained that aroundllb;~~ ~ours, all prerequisites to move to Mode 4 had been handled. !{b}(?}(C} I instructe e MCR to go to 210 deg rees and maintain that temperature which placed the plant into Mode 4. According to !(b)(7)(C) I the OCC told J(b)(?)(C) I OPS OCC representative, to inform !rb}ll)/C} I to go to Mode 3 and take the tem~erature up to 350 degrees. !/b)(7)/Cl I further explained that around 1300, the OCC directed Wr11rc} I to take RHR out of service, and then move to Mode 3. !/bl(7}/C) I testified that he informed !/bl<7l/C} I that he was uncomfortable moving to Mode 3 and that they needed to stay where the~ were and wait for the let-down sf tern to come back into service in a few hours. ilblf7]Cl I said he mentioned to i1b}(fc1 I that the OCC was pushin~ too hard. According to !(b)(7)(C) I!/bl/7}(C} Iwas also uncomfortable with the decision. !/bl/7]C} I explained that the OCC was pushing too hard and wanted to stay on schedule (Exhibit T-22b). !/bl(7l1Cl I said that !lbl/?j(Cl I raised !/blll)IC} I concerns to the OCC and recalled that !(b)U)(Q} I gathered evemone around a table and told them of !/b)ffi(Cl I concern. llbll7)/Cl I stated that llbl /Cl I r1lso told them that they were pushing the operators too hard and he wanted it to stop. According to !(b)(7i1CJ I the OCC dismissed the concern and instructed !lb}/7l/C} I to move to Mode 3. b}/7}/C} I said that he would have pushed back harder on November 11, 2015, but he was worried that he would be somehow reprimanded for

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY           O1 INVESTIGATION INFORMATION 128 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION not getting on board with the decision to move to Mode 3. His actions in the MCR were heavily influenced by his fear of losing his job (Exhibit T-22b ). On July 20, 2016, !{b\17l{C\ I was interviewed by TVA OIG and provided the following information !rb}/7}/Cl I advised that there was no discussion on November 11 , 2015, that it might be possible to get 70gpm using the excess let-down !ibl(7)/Cl I stated, "I do not think you could ever get 70gpm out of excess let-down." If someone had said 70gpm was possible, kb}(Z}/Cl I stated that the conditions would have to be "absolutely perfect" at full ~ essure to ever get close to that and even then, it would be a "slim chance." Regardless. l!bl(Zirci I I stated in the MCR thatj(b)(7)(C) "no one had the number 70gpm on our brain anywhere." !/bl(7}/C\ I stated that no one said that night that they knew the heat-up using excess let-down could be done. Rather, everyone said that they did not know how it would react and they (licensed operators) knew they had "stuff' they could do if it went wrong. !/b}(7}/C} I stated that the "big gu: s" were saying "go" and the operators had actions in their back pocket to use if it failed. ITbii'7}/C} I stated that no one in the MCR wanted to move forward. !/bl/7l/C\ I is not aware of whether any of the other guys talked to !/b\{7l{C' I About a month later when the NRC brought up the issue, !tbl(Z}{Cl J was in !lb\[7l{Cl Ioffice with llb)(l)(C) Iand !(b)(l)(C) I At which time, ilbl{l)/Cl I asked !(b)(l)(C) I if !tb)(l)(C) I should be removed from watch until they found out the answers to the questions. !{b\(7)fC\ I said "Yes." !/bl(7)fC} I stated that he was glad he had been in the meeting and heard the conversation because he realized it was not a punitive thing but rather just a conservative measure until the NRC was comfortable. !(bl/7\/C) I also believes it was to position themselves to look better to the NRC. !rbl(7}/Cl I said this was normal and he would have done the same thing. !lb\(7)/Gl I went back to his regular work control job and was able to fill in the next time he was asked for help in watch standing. !(bl(Z}/C\ I said he was never remediated. !(b}/7l/Cl I never heard !(b)l7\/Cl I or !1bim1c1 I talk about taking anyone else off watch because "the buck stops with me !{b)(7)(C) I(Exhibit T-22c). On September 6, 2016, !(b)/7}(Cl I was interviewed by AUSA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, TVA OIG and 0 1wherein he provided the following information. Although !/b)(7\/Cl I asserted that he was not worried ab,~ ~ = ~*= ~ ~ ~ OCC, !lb)U)(C} I was certainly not comfortable about challen...,i_n..,_th_e. -(b...l(7_l(_C)- --:-~-"."'-:"'---- and !(b)(7)(C) !about ~lant decisions. b 7 c emphasized that once the first engineering test was over, he called Ub\{7}/Cl Ito inquire how much longer before the valve (normal let-down was in-service. According to !(b)(?)(Cl I!rbl(l)/Cl Itold him the valve would be ready soon. b 7 c said the schedule called for WBN1 to proceed to Mode 3. !(bl/7\/C\ I stated there were no procedures in place about what to do or not to do when heating up using excess let-down. !lblll)(Q) I said there was nothing in writing saying it cannot be done. (lli1m1c1 I disclosed that he was uneasy about proceeding partly due to the fact that he had no experience heating up using excess let-down. 1/iilm!Cl ] stressed that WBN1 was not at full pressure, but lrb)l7lrci I admitted he had no idea how using the excess let-down would affect the pressurizer level. Likewise, !/bl(7}/Cl I was unable to estimate how much inventory (water) they expected to get out using excess let-down, no numbers were discussed (Exhibit T-22d).

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AGDH IPJ 0 1h0tRGE , OFFIOE OF ltWESTIOMIOPJS, REOleN II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 129 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7)/C\ I stated that he knew there were ways to control the plant if excess let-down did not work and if the plant did what he was "afraid" it would do. !lbl/7\/Cl I explained that the procedures are not written for every step (scenario). !tb1(7)/C) I stated that he knew how to recover the plant if excess let-down did not work and understood that the pressurizer level will go up during heat-up. !/b\(7)/C\ I stated that the first step for heat-up was to remove the RHR. Once the RHR was removed, the temQerature in the RCS would increase. !/b\(7)/C) I stated that prior to removing the RHR, !/bJmrci I set some trigger values to ensure they took action. At this oint, nobody could put their finger on why they should not heat-up. According to b c if he did not have contingencies then he would have been more concerned . ........'"""""--' stated that the licensed operators were not overly experienced and once it was discussed none of them had an opinion one way or the other except !lbl/7\/Q\ I !lb)(7l(C\ I stated that no one else said it was not a good idea which caused !tb\(Z)[Ql Ito start doubting himself because he seemed to be the only one that was uneasy. In regard to .._b_..7 ........,, c _______ !lbl(7\/Cl I testified that !lbl(l)[Cl I basically said something to the effect that, "He (b)(7)(C) felt ilb)(l)/Cl I pain but we have a schedule." !rb)(7)[Cl I confirmed that he set a trigger value of 80 percent pressurizer level where they were to open the PORV to control the rate of heat-up. They then took the RHR out of service and the pressure quickly got to 79 percent which was faster than they anticipated. !tb)(l)tC) I said the rate of heat-up is what "killed" us because it out-ran the excess let-down system which is what ilb)/7\{Cl I suspected was going to happen. At this point, REDINGER opened the RHR inlet valves and the pressure level went down (Exhibit T-22d).

            ~ =.:.:..= "'-:..T:**estimon from the other control room operators (REDINGER, i.,;.....;...;._;'""."."'"--,......11:.*...,b i,i,i,ioj 7,_c......._. and !(b)(7)(C) ! on shift during the November 11, 2015, events contradicts b 7 c                                         statement that none of the other operators had an opinion on removing RHR from service.

Once the normal let-down got fixed they reconfigured everything and moved on. !lbl(7\/C\ said that they should have just waited until the normal let-down was fixed. About ten minutes after they opened the relief valve and recovered, !rblmrc\ I came in the MGR and thanked everyone for not letting the plant get out of control. !lbl[7\[Cl I said it was clear that !rb\[7)[Cl had been in the OCC watching the event on the monitors and knew what had just happened. !lbl(7)[C\ I said the event was not logged and no CRs were written. i{b\/7\/C\ I admitted that he did not check the logs and acknowledged that they made mistakes. !lb\[7)[C\ I could not recall who the Unit Supervisor was on the day of the event, but confirmed that later that afternoon, he sent an email to the other Shift Managers telling them, '1(b)(7)(C) I !(b)(7)(C) I" The comment on the email about not letting anyone talk you into it was made because it was not his idea to proceed with the heat-up without normal let down in service. llb\/7)/Cl I does not believe anyone in the OCC would have put the plant at risk on purpose. However, the lack of experience, knowledge, and schedule pressure all happened because they were trying to see how fast they can get back to making money !/b)(7l/Cl I expressed that everyone knew what he was doing, why he was doing it and what he had to do to recover the plant. !lb)/7)/C\ I stated that at the time all these "smart people" were saying it is "ok" to do it and he !(b)(7)(C) I was the only one saying "no" so he talked himself into thinking it was alright because everyone else felt it was alright (Exhibit T-22d).

                                   ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                         O1 INVESTIGATION INFORMATION 130 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On April 3, 2017, !rbl{7l!Cl Iwas interviewed b TVA OIG and rovided the followin information ilb\17)/C\ I said that he recalled (b)(7)(C) !(b)(7)(C) I or (b)(7)(Cl telling him to do it on November 11, 2015. He said that he could not remember which one it was, but he did recall it was the person in the (b){7)(C) osition. ilb\(7}/Q\  !;:ilso said that during the same conversation he was informed that b 7 c and !(b}/7\(C) I wanted it done or were for it. !lb\(7)/C) I said that he let others in the OCC know that he was not in favor of doing it and did not want to do it. i/bl[Z)[Q} I said that the OCC knew how he felt. ilb)0/Cl I told the agents that he could not remember exactly who all he told in the OCC, but he did know it was more than just !rb)(7}{C} I lrb}(7}!Cl I added that he has a family to feed (Exhibit T-22e). Interview of Dennis REDINGER. Unit Supervisor REDINGER, US at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA

!(b)(7)(C)   I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

On November 18, 2015, REDINGER was interviewed by 0 1and discussed that he spent six years in the Navy and worked at multiple licensees including 16 years at Comanche Peake where he was an STA and SRO. He came to TVA in 2009 and was licensed in 2011. REDINGER discussed that the MCR operators did not know what the capabilities of the excess let-down system would be at the temperature and pressure they were operating at on November 11, 2015. REDINGER expressed there was a lack of knowledge among the operators and discussed that the response to their concerns from the OCC was the OCC understood the concern, but they were okay with proceeding forward. REDINGER stated that he wished he pushed back harder but at the time he felt like they did not have enough basis to say they were not going to continue. He expressed that at the time he felt that !(b)(7}/C} I was not totally committed to the idea either, but he tried to convey to us that the OCC wanted us to move forward with it and !lb}/7\(C} I was willing to try it (Exhibit T-40a, pp. 7-8, pp. 17-38). On January 19, 2016, REDINGER was interviewed by TVA OIG and explained that he was the WBN1 Unit Supervisor on November 11 , 2015 and reported to !rbl(7}(C} I REDINGER stated that since it was scheduled, the OCC decided to use the Excess Let-down System instead of waiting on the normal let-down system. He discussed use of the Excess Let-down S stem rather than waiting on the normal one with licensed operators ( (b)(7)(C) !(b)(7)(C) ~ and no one was comfortable._w _ 1-t ~ o-1n_g_1-t _ u _e_ -t o_c_,oncerns regarding the ability to maintain inventory control and the pressurizer. While they did not have enough information that day to tell the OCC that it absolutely would not work, no one felt like it was worth the risk. They discussed it with !(b}W<Cl I who also agreed that he did not think it was a good idea ilb\(7)/Ql I told them that he was going to tell the OCC that he was not comfortable with the plan to use the excess let-down system. !(b}(l)(C) I later came back and told the control room that it had been decided to go ahead and move forward so they did. They took out the RHR system and began monitoring the heat-up while trying to maintain temperature and inventory control (Exhibit T-40b).

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 131 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On February 10, 2016, REDINGER was interviewed by TVA OIG. When discussing the Shift Order, REDINGER was asked to comment on each of the answers to the questions contained on the Question and Answer page of the shift order. Regarding the answer given to question number three, REDINGER said that generally that was the information that he provided, but he does not think the he provided the 50-60gpm number. REDINGER said he was not sure where the 50-60gpm number came from and recalls he gave his answers to the questions to I He added that the entire answer (the whole paragraph) was what he told !lb)/7}(C} lfblfrlfc; b7c Iexcept for the 50-60gpm part. REDINGER said that he did not give that number to He does not know who did or where it came from (Exhibit T-40c). On March 07, 2016, REDINGER was interviewed by TVA OIG REDINGER stated the shift order was written by !lb}l?)<C) I::ind (b)(l)(C) . He (REDINGER) was initially briefed about the shift order by Shift Manager (b)(7)(C) which is the first time that he saw the 50-60gpm number and thought something I no oo right. He still does not know where the number 50-60gpm came from. At the time, REDINGER thought the shift order was written to give the operators OE (operating experience) but now he believes it could have been to get everyone on the same page. REDINGER still has no knowledge of where the 50-60gpm in the shift order came from. He was interviewed by Employee Concerns Program (ECP) line by line about the shift order when he realized the statement looked like the information he had written except for the 50-60gpm number. After the interview with ECP, REDINGER ran into ilb\17)/C\ I ::ind asked him where the 50- 60gpm came from and !(b){?)(Cl Idid not re] ly. Discussing the December 15, 2015, email chain between REDINGER and !(b)(7)(C) REDINGER reviewed the email and confirmed that the actions they took to recover the plant were the operator's actions but how they got there in the first place was not the operators' decision. He stated that they were under schedule pressure to move forward. REDINGER confirmed there was a disconnect in what was said in the email versus what was said in the shift order. Specifically, REDINGER stated that the shift order makes it look like the control room made the decision to move forward where the email shows that that was not the case at all (Exhibit T-40d, pp. 1-10). On September 06, 2016, REDINGER was interviewed by TVA OIG, 0 1, and AUSA. REDINGER advised that using excess let-down had not been done very often. In the situation on November 11, 2015, neither REDINGER nor the other operators had done it before. He stated the excess let-down flow design says 40gpm. He also had heard during training that they had gotten 70gpm using excess let-down. This information came from older guys who had experience in the plant. However, all of these numbers were at full pressure. According to REDINGER, he and the other operators knew they would not get 70gpm and were pretty sure they would not get 40gpm given the temperature and pressure at which they were operating at that time. They were concerned that what they actually got would not be enough to heat-up. REDINGER stated that they could not say it would not work but he and the other operators had an uneasy feeling. REDINGER and the three reactor operators on crew discussed their concerns as a group. REDINGER then talked with the !(b)(7)(C) I !(b)(?)(C)  !, who also did not feel good about heating up usinTI the excess let-down. Everyone was in agreement so REDINGER and !(b)(7)(C) !met with !rb 7l!Cl l and expressed the crew's concerns. During the discussion with REDINGER and l(b)(7)(C) !did not

                   ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      OI INVESTIGATION INFORMATION 132 Case No. 2-2016-042

OFFICl)lltt us~ Ol~LY -O1 INVESTIGATION INFORMATION challen e them and appeared to be taking information from them. REDINGER does not think (b)(7)(C) said one way or another whether he agreed with them . REDINGER was asked if he or the crew thought at the time they could get 50-60gpm from excess let down. REDINGER said that he did not think they could get 50-60gpm from excess let down. He said that nobody on the crew thought they could get 50-60gpm from excess let down. He stated that while 40gpm design and 70gpm pre-op testing was discussed at some point, the operators all knew not to expect those numbers because it was at 340Ibs of pressure rather than the normal pressure of 2,225Ibs. He stated that 40gpm and 70gpm would have only been at normal pressure and were not numbers for that day. The operators did not know what the actual numbers would be with the plant conditions at that time (Exhibit T-40e). Interviews of !(b)(7)(C) I Reactor Operator 1- (b_)(7_)(_Cl_ _ __, RO at WBN was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA

....(b....
       )(7...)(__

C)____ US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following inform*~::~~::~;::::~ for[lyears ot Watts Bar He was thel.... (b-)(7-l(-Cl----. b7c of November 11, 2~ . l(b)(?)(C) !stated " ... I think there we re different theories about whether excess let-down would be enough with RHR let-down out of service. And some people thought it would. We did not think it would, but it did not." W hen asked to clarify who thought it would work he continued, "OCC. The people directing us to go ahead and start the heat-up for let-down of the line. They believed against us that excess let-down would be sufficient to counter the heat-up and most of our -- not all of the excess let-down is supposed to be" (Exhibit T-01b, p. 8, pp. 13-14). (b)(l)(C) was against movin forward without the let-down system and took his concern to (b)(?)(C) According to (b)(?)(C) everyone in the MCR with a license was against moving ahead. !(bl(7)(C) !conveyed the concern to the OCC. OCC said to move ahead. At some point while all this was going on, a comment was made to the effect that "everyone who has a license says no but the people who can fire the licensed people say do it." The license holders are being pushed to do more than they can. If the pushing does not work out, then the license holders get blamed. The OCC's push to get closer to Mode 3 that day did not work out. The excess let-down system could not do the job. The temperature rose and those in the MCR could not get the inventory out. l(b)(7)(C) Itold TVA OIG that he did not tell the 0 1the whole sto during the interview. He did not tell the NRC about TVA management pressure. (b)(?)(C) was told by the TVA lawyer prior to the interview not to expand on his answers . .___ __,,_ _ _~~~sure from the TVA lawyer not to tell the NRC about the front-end issues. (b)(7)(C) did not want TVA to think that he was not a team player. He said that around the same time that he was interviewed by the NRC , TVA is~ued a shift order which explained what happened on November 11, 2015. !(b)(7)(C) Jread the shift order and found it to be factually incorrect. He said that the shift order really did not describe the facts which took place on November 11 , 2015. It is his opinion that TVA generated the shift order, so the NRC could read it (Exhibit T-01a, pp. 1-3). i<JO I FOR PUBLIC Ol~CLO~U~P! vv l I MOUT Al'l'~OVAL efi aP G l :O.la .A/e ~ IT l~I GH.A.pil'51ia, gfiiifiii l G gfiii I W,< aT I C.A.Tl g~1., pillia'51g~1 II OFFICIAL llili. O~*b¥ O1 INVESTIGATION INFORMATION 133 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION In an interview follow-up email on January 27, 2016,!(b)(?)(C) Iprovided clarification on information provided in the shift order. c mmentjna on the answer to the question "Did the 1 crew expect the condition that occurred." (b)(7)(C) Iresponded, "This is backwards. The crew did expect level to rise because we did not expect 50-60gpm from excess let-down at that pressure. That was a main argument we used against the plan." When commenting on the listed actions taken, specifically, "Oversight watches have been established in the MCR."

    !(b)(7)(C)         I commented 'The people who pushed us into it [November 11,2015 event] were in the MCR around the clock for about a month [afterwards] to make sure we did not decide to go and do anything that foolish again" (Exhibit T-01 a, pp. 14-15).

did not think the crew could get enough water out because excess let-down is

     ~ ~ ~ ~-l'ffl'gpm but could not prove it and he felt the OCC had been looking at it closely and crunchin the numbers based on !/b)(7l/Cl              Istatements concerning capabilities of excess let-down. (b)(7)(C)              stated that he and the crew knew they would not get 50gpm out of it.

However, since (b)(7J(C) could not research it at the moment, he felt the people outside the control room were helping the crew research it. Where it [shift order] said the crew thought they should be able to get 50 to 60gpm on excess let-down but, the operators were arguing against it because they did not think it was ossible. No one talked to !(b)(7)(Cl !for information on the shift order. However, (b)(?)(C) does not recall anyone in the control room talking about how they could get 50 to 60gpm out of it if they were not at full pressure. They all felt like excess let-down would not work but they did not know the severity or how fast it would all happen (Exhibit T-01c). Interviews of!(b)(7)(C)  !, Reactor Operator

     !(bl(l)(C) I RO at WBN was interviewed on January 27, 2016, and September 19, 2016, by 0 1, TVA OIG, and AUSA !(b)(7)(C)             I US Attorney's Office for the Eastern District of Tennessee wherein he provided the following information in substance !/bl(?)(Cl I was licensed in (b)(?)(C)

(b)(7J(CJ orked on in the MCR on November 11 , 2015. !lb}[l)!C) I explained that he was (b)(7)(C) (b)(7)(C) and did not have a lot of experience. !/bl(l)(Cl I stated that the excess let-down was in place when the RHR was taken out and he was under the impression that it would take water out to keep the plant from going solid. !/bl(?)(Cl I does not know why the decision was made not to wait for the normal let-down system but stated the o~erators did not wait because "we were being pushed by the OCC (Outage Control Center)." lr\mrci I stated that this was his first time dealing with an OCC as an Operator. His understanding of the OCC was that they we re the people who understood what was happening and it was their job to come up with a plan. He now believes they are there to push and get the work done. (b)(7)(C) stated that he should have never taken the RHR out with that situation, but it was Is irs outage and the sh ift manager that day had a lot of experience and he said to do it (Exhibit T-23a)(Exhibit T-23b). Interviews of l(b)(?)(C) l Reactor Operator

     !(b)(l)(C) I RO at WBN was interviewed on January 28, 2016, and September 29, 2016, by 0 1, TVA OIG, and AUSA !(b)(7)(C)             I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

rqo;p FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L OF SPECIAL AOl!!l~T 11q Cl l"<RetE, OFFICE OF ltWE8TIGMIO~J, REGIO~I II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 134 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b) ..,,...,.,,....,,...---, (7) l(bl(l)(Cl I had been a Reactor Operator fo c ears at Watts Bar and worked on November 11, 2015, in the MCR. 111,1,11,1.....,.__, was serving as a RO that day on the second~ lant side controlling the steam generator loads, REDINGER was the Unit Supervisor an~ (b)(7)(C) was the Operator at Control (OAC). !rbl(7l(Cl I discussed the events that appene on ovember 11, 2015, were only one example where the MCR operators expressed concerns but were told to proceed regardless. On November 11, 2015, there was pressure bein~ felt in the MCR from the OCC to move from Mode 5 to Mode 4. !rbl/7}[Cl I stated that !lb}m ) I appeared to be under pressure to move the unit. Since the normal let-down system was out of service, the plant had to rely on the excess let-down system. Licensed Operators voiced their concerns with the plan to move ahead using the excess let-down system. !rb)U)/C\ I was not for the idea. !lbJmrcJ I r,ommunicated the concerns the MCR ersonnel had with the plan, but the OCC decided on a plan to proceed with the heat-u~. !/bl[? /Cl I stated, "I felt like it was a very bad idea to proceed on." The agents asked lrb ?}[Cl I why he did 3 not voice his concern stronger and louder. He said that he was afraid of being relieved. He said he was afraid of not being viewed as a team player. !rbl(Jl[Cl Iexplained to the agents that neither he nor his colleagues in the MCR that day could point to a rule or a procedure to support their position not to proceed using the excess let-down system. They all just knew it was a bad idea based off their training and experience. !/bl(l)/Cl I said that all the OCC had to do was wait a few hours and the normal let-down system would be available. According to !(b)(7)(C) I the work had already been done and they were j ust waiting on the paperwork and clearances to put the normal let-down back in service. !rbl(7}/Cl I su~gested that the OCC would not wait and wanted to stay on schedule no matter what. ![b}Ul(Q I recalled saying out loud "this is stupid" when !rbJ(Z)<CJ I told them that the OCC said to proceed (Exhibit T-16a). Interviews of!(b)(7)(C) I, Senior Reactor Operator I !(b)(l)(C) SRO at WBN was interviewed on January 16, 2016, and September 19, 2016, by 01, TVA OIG, and AUSA !(b)(?)(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the folio

• g information in substance.

(b) (7) !rbJU}fC) I had been a SRO fo rci ears at Watts Bar, and on November 11 , 2015, he was working as the (b)(7)(C) and in the control room for !(b)(7)(C) I (b)(7)(C) so the other operators could focus on the plant as it was coming ou o e main enance ou age. At one point, REDINGER had to leave so !lb\(7)/C} I relieved him for a couple of hours. !rb1mrci I said that he talked to everyone on the Unit 1 side in the main control room that day about heating up without normal let down being available. None* of them thought it was a good idea. REDINGER was part of that conversation. !lb}U}/Q} I could not recall if !rbl(l)(Cl I was a part of that specific conversation but he does know that !(bl[7l/Cl I recognized that the operators were uncomfortable about heating up. According to !fb)(7)(C) in I this instance standing down waiting for normal let-down would have been textbook but would not have gotten them out of the outage fast enough. !lb}(?)(C} I said that when he saw the "50gpm" answer given in the statement put together by !(b)(l)(Cl  ! lfbl(l)(C) l and !(b-

                                                                                                           ..... )(7-l(C

_l_ he could not figure out where that number came from. When he read the number "50" on the document he told his peers that the number "50" was just silly. He added to the interviewers

                                ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 135 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION that he did not tell anyone on November 11, 2015, that he thought they could get that out of excess let down. The number was totally unrealistic. Speaking of the plant manaffier, !(bl(7l[C\ said on November 11, 2015, after the control room personnel stabilized the plant I )17}/Cl I came into the control room and congratulated everyone. (bl(?)(C) recalled !lbl(7)/Cl I saying, "We put you guys in a bad place today." !/b\r7l(Cl I gave (b)(7)(C) a bear hug (Exhibit T-05a) (T-05b). Interview of !(b)(?)(C) l Senior Reactor Operator !(b)(7)(C) I SRO at WBN was interviewed on January 27, 2016, by TVA OIG wherein he provided the following information in substance. was workin in the WBN 1 as a b c

,_(b_)(?_)(_C_
             ) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _____.did not realize there was a problem with the unit that day until they were fully involved in the ob em

!(b)(?)(C) Istated that he became aware of the issue during the recovery phase. (b)(?)(C) said in the past Management did not challenge the more conservative path if in fact that path was deemed by the MCR to be the best path to take. Nowadays, management questions the Shift Managers when the Shift Managers state that they are going to take the conservative path. In the past, WBN's default position was the conservative position because that is the safest position. !(bl(7l(Cl !credits the change to !lb\(7)/Cl I .:ind !/bl[7\/C\ I (Exhibit T-41). Interviews ofilb)(7)(C) !(b)(7)(C) d at WBN, was interviewed on multiple occasions by 01, TVA OIG, and AOSA !(blfll(Cl I O Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

!lblQ)(Ql        I was interviewed by TVA OIG on February 2, 2016, and discussed that on November 11, 2015, he was working. !rb\(7l[C\                 I stated that he remembers that day fairly well because the normal let down system was not in service. He was in the OCC working with the OCC team but cannot recall who else was present with him and remembers they were trying to determine what the ~Ian was movin~ forward. !rbl/7\/C}                    I does remembers having several conversations with IC\m1Ql               I !(b}(7 /Cl I stated there were basically three options: (1) stay in Mode 5 and wait until the normal let-down was back in service or (2) heat-up to Mode 4 and stay on RHR or (3) do option 2 and then take RHR out of service and the cooling mechanism would be the main steam dumps. The decision was made to go with o tion number three.
!(bl(l)(Cl       Istated that he attended all of the OCC meetings that (b)(7)(C) where they discussed the options. He does not remember any real push back on moving orward. !{bl(7l(Cl                            I ::idvised that it is important to stay on schedule because the unit is important to the fleet. He stated that there is a balance between schedule and safety and any delay on getting the unit back online meant TVA must purchase power. He stated this is no different than all other utilities.
!1b1m1c1         I stated that they were originally supposed to move to Mode 4 around 6 a.m. or 7a.m.,

but the OCC wanted to analyze it some more. According to !(b)(l)(C) I we all had concerns because of not having the let-down available. !(blr7l/Cl Istated that they had to convince

                         ,~ef 1-eR: 1-uBue 01aeteauR:E W lf l ,euf >'<flflR:e'~'>'<t e1-SPEc 1At AC:iEIQT IIQ Cl l"<R:t9E, OFFIGE OF ,~*~'EeTl'5sA.+10~1~, PFGIOM II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 136 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION li~;i;l)~l \ in OCC because all delays or changes in schedule had to be approved by

                  !lbl(7}/Cl       I stated that they were already delayed so the OCC team came up with a plan for !lb)U}/C}            I ~pproval that decided what to do after the delay (Exhibit T-21 a).

!/bl/7\/C} Iwas interviewed by TVA OIG on February 10, 2016, and did not recall anyone in particular being concerned with moving forward with heating up the ~lant on November 11, 2015. While h e did not specifically recall either ilbl/7}/C I or REDINGER telling him they were uncomfortable or that they did not want to take the RHR out of service, he did admit there was some pushback with o~erators asking questions about the effect of doing this without normal let-down. In addition, !lb_7l/C) Isaid "he did have some healthy challenges with i/b\(7)/Ql I in the control room" about this issue. However, ifb\(7}(C} Istated "I did not get off (sic from] these conversations that they were uncomfortable with this." He further clarified that they did not tell him at any time of the day that they did not want to do it. !/bl/7\(Cl I was asked about kfshing (pressure) which he stated that pushing is common and "I have had much worse." In i(b_l(C} I opinion, operations are not doingi well because there are some fundamental areas with operators' performance and they have failed to correct the low-level behaviors. Some examples of these include communications, responses, and board monitoring. !(b}(7)/C) I believes the only recent event that could even remotely be associated with pushing would be the RHR event because the whole OCC team was pushing to move forward . Other issues like the source range instrument bypass and the PORV lift are only due to operator error and level of knowledge issues. According to !(b)(?)(C) I Operations knows the knowledge level is lower than it should be, and that management needs to be in an oversight role to make sure the people who do the actions understand what they need to do. While these oversight managers may not have an active license or be a license holder, they have the required knowled~e from past experience to make decisions and assist in what happens in Operations. !(bl[Z) l I believes it is inappropriate for someone to sa that !/bl[Z)/Cl I should not be involved in the control room decisions since he is the (b)(7)(C) and is very knowledgeable (Exhibit T-21 b). ilbl{7)(Cl Iwas interviewed by TVA OIG on June 30, 2016 and recalled having a conversation with !/b\/7}/Cl I in the control room and that !lbl/7}(Cl I challenged him but was "okay with moving forward after our conversation." This conversation ham~ened at the horseshoe by the unit supervisor's desk while there were other ~eo§le around. bl7lfCl I~lso believes the unit supervisor (REDINGER) was there as well. lumr l Istated that their concern was about the effect moving forward and heating up would have on the plant with the normal let-down out of service. He stated that at no time did either ilbl(7l/Cl I or REDINGER say they did not want to do it nor did anyone seem adamant about anything. If they had, !/b}(7l!Cl I would have sto~ped and tried to understand why. He does not recall any other conversations with ilblr7]c1 I and knew there were challenR;es from the crew about what did the effect of the temperature rise on pressure level. !(bl[Z) l I testified he did not feel anyone was uncomfortable but rather more concerned about whether they were technically doing the right thing. !(b}/7}1Cl I had been talking to !lbl/7\(Cl I on a regular basis that day about what was hap~ening . In addition, !lb\!7)/C} I would have been in the OCC frequently that day. i(blm Cl Istated that !(bl[Z)/C\ Iwas for moving forward that day, but the decision was made by !lb\(7)/Cl I !/b}(7}/Cl I stated that he and !lbl(7}(Cl Iwere good with moving forward that

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 137 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION day because they thought they could do it safely. He stated that everyone was good with moving forward in the beginning but now say how bad the decision was. There have been "a lot of Monday morning quarterbacks" about this issue. l{b)U}{C} Idoes feel like there was a lot of miscommunication. [(bl(l)(Cl Isuggested that the decision was made by llbl{7l(Cl I who was the shift manager (Exhibit T-21c). !(bl(7)/Cl I was interviewed by TVA OIG, 0 1and an AUSA on January 19, 2017, and said that during outages !/b\(7)/C\ Iwanted to know minute by minute what was g-0ing on. In the OCC, l{b}m!Q I ::incl !{b)UJIQl I were part of the Senior Leadershi Team. l{b}m7c1 Istated that information to l(b\(7)/Cl I would go through him (b)(l)(C) while decisions went from !/bl(7)(C\ Ito !/bl{7\/C\ I l(b\/7\fci I would then go to the Shift Manager with the decision. llbll7)(Q) Isaid that there was discussion in the OCC to remove RHR and allow the heat-up to begin. !rbl/7\(C\ Isaid that they had many discussions about that in the OCC and in the main control room with the Shift Manager. !/bl/7\(Cl I questioned l(b\(7)/C\ Iabout what was going to happen to the pressurizer level if they took the action. lrb\(7)/C\ I had multiple conversations with a few people about that and these conversations took place over the course of a few hours. !/b\r7l(C\  ! said that the Shift Manger's crew also asked that same question !(b\(l)(C\ I recalled interacting with the Shift Manager and the Unit Supervisor that day. llb)U}{Ql Ir.ould not recall who else he spoke with in the control room about heating up. !(bll/l/Cl Iestimated 30 percent that day was spent in the main control room and 70 percent of his time was in the OCC (Exhibit T-21d). !(blUJ(C\ I said that they had a lot of conversations in the OCC that day about removing RHR and whether there were any tech specs or restrictions. llb)(?}{C) Isaid that in the end they could not find any restrictions against doing it, l/b\(7\/C\ I said that engineering was consulted too. l(b\fl)(C) I said engineering told !(b\(7\[C) Iand the others that excess let down could handle it. i(b\(l)(C) Iwas asked who from engineering gave him that bit of information. !/b\U}(C) Isaid he could not remember who it was that told him that. When asked if th ere was a gallon per minute (gpm) figure that engineering said could handle it, !rb\(7)(C\ I replied that 20gpm is what he recalled from the system description. i(b\(l)(C) Iadded that no restrictions were located so they decided to do it. !/b\(7)/C) Isaid that there was discussion in the OCC to remove RHR and allow the heat-up to begin. l{b\(7}/Q} I said that they had many discussions about that in the OCC and in the MCR with !!b\(7)(C) I lrb\(7)(Cl Isaid he did remember talking with l(bl(l)(Cl I in the main control room and the OCC about removing RHR. ,...!/b-1(7....l_(Q_) - - , did speak with l{b}(Z)IQ} I too about the issue, but llb)l7}(Ql Icould not recall exactly what each other said. !(bll7l(Cl I said that !(bl(l)(Cl I and !rbl(l)!Cl I both were involved in the decision and both knew exactly what was going on . !rb\(7)/C) Istated that both l..,./b"::l~}f f7 =Cl= ===-.... anct lrb}/7\!Q} I were in favor of removing the RHR llb)U)IQ\ Isaid that he spoke to l{b}Wlr.) about it and his crew, but the idea was not !/b)/7\/Cl I idea. !(b)(7l(C} Iwas asked b_y the interviewers if ilb)mrc1 Itold lrb)m/Cl Ito instruct !rb)m(Cl I to take the action. !/blm(Cl said that lib)(7)(Cl I did not tell llb}(l)(Q} I to tell l{b)(7){Q\ I to do it l{b}(?){Q} Isaid it came about after the conversations in the OCC after which the OCC came to the conclusion do it and l/b}(l)(Cl Icommunicated that to !/bl(7J(C) I !(b\(7)/C) Istated that he !(b)(7)(C) I went to the control room and told !(bl{7l(Cl Ithat "this is the path that we would like to go down because we feel it is appropriate". The interviewers asked l/bl(7l/Cl Ito define "we".

                         ,~o, FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L OF SPEC IAL AGDH IPJ 0 1h0tRGE , OFFIOE OF ltWESTIOMIOPJS, REOION II 6 f'f'le l,-L U9!! 614LY            0I INVESTIGATION INFORMATION 138 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7)/C\ Isaid, "we" were the OCC. l(bl(7l(C) twas aslked by the interviewers if using excess let down was the safest plan. !lbl(7)(Cl rsaid using excess let down was not the safest plan and it would have been safer to wait for normal let down to come back in service. !lb1(7)/C} I said that they concluded that!(b)(7)(C) !that they could get 20gpm out of excess let down (Exhibit T-21d). Interview ofl(b)(7)(C) l(b)(7)(C) !at WBN was interviewed on multiple occasions by 0 1and TVA OIG wherein he provided the following information in substance. He described that at 06:00 a.m., on November 11, 2015, it was identified that the repair of the normal let-down valve had not yet been completed. !(b\(7lfCl I briefed the OCC that this would significantly hinder the heat-up rate and they would not be performing a normal heat-up per the schedule. He stated it would take o ru~~~ti~T a much longer time to slowly heat-up because we did not have the let-down capacity. b C figured that they could heat-up the plant at a rate of 75 deflrees per hour using the normal let-down system, but the excess let-down system was limited. bl(7)/Cl I figured that by using the excess let-down system, they could heat-up the plant

~ta rate of 1octearees per ~our. !lb\(7)/C\ I stated that !(b)(7)(C)                                        I (b)(l)(C)                          at WBN and he made the decision to keep going with the schedule and start heating up with what we had in place and not wait for the next one [normal let-down]

knowing there would be a schedule delay to critical path (Exhibit T-18, pp. 8-12, 15) (Exhibit T-31). Interview of !(b)(7)(C) l(b)(7)(C) Iat WBN was interviewed by TVA OIG on January 27, 2016, wherein he provided the following information in substance.

!(b)(7)/C\    I stated the decision to forge ahead that (b)(l)(C) using the excess let-down system was a team decision. !lb\(7)/Cl           Ithinks that if he did not think the plan of using the excess let-down system would work then they would not have tried it. He stated that going to the excess let-down system is not a normal thing and not the preferred method. According to l~bflfcl       I there was a good amount of discussion about whether or not it could be done.

b7c I continued by explaining that sometimes decisions are made outside of the OCC. He stated that it could have been either the !rb\(7)/C\ I or !rb)(7lfC\ Ibecause the OCC sometimes relies on them. l(bl~~Cl !said that he did not make the decision and he does not believe that !rb\(7)/Cl I Ior I/bl Cl would have made the decision either (Exhibit T-19 ). Interviews of !(b)(7)(C) l Shift Manager b 7 c SM and SRO at WBN, was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA b c US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

                      ,~e, FeR 1-UBUe 01aeteaURE WIT! ,eu, )l(flf1Re1~1>'<L eF

31-ECIAL AOEPH IPJ GI h"1RGE, QFF I C Oli l~IHFSIIGAIIO!>I S REGION II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 139 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)(l)(C) was licensed in 1~~;7

                                 ) land has b at work on November 10 2015, for the (b)(7)(C)

• Manager since 7) l~~: ! I When !(b)(l)(C) arrived there were two maJor things that were on the schedule for the (b)(7)(C) o get done: 1) Work to do on the Let Down System so the night crew needed to a e e et Down flow path out of service: 2) Heat-up the plant (move from Mode 5 to Mode 4).!(b)(7)(C) ! decided to do only the first thing. He told the agents that in his mind the let-down s stem was out of service, so he did not want to heat-up the plant without it being in service. (b)(?)(C) explained that the concern in heating up had to do with water management. He exp amed that water expanded a lot when it heats up, so you must either drain water or not heat-up. (b)(7l(C) did not think it was a good idea to heat-u with the let-down system out of service and reca e 7 c suggested they could just wait. (b)(?)(C) could not recall who he talked to in the OCC about his decision not to heat-up the plan , u e did talk to someone. He recalled talking to the OCC about the let-down system being out of service. They had a good discussion about it and that was it. (b)(7)(C) ecalled telling the OCC that he wanted to stay in Mode 5 because they only had excess e - own. According to !(b)(7)(Cl with low I pressure and low temperature the expectation was to only get around 15 to 30gpm using the excess let-down. Specifically, he remembers discussing this with the OCC that night and telling them that the reason they had to stay in Mode 5 was because of the inability of excess let-down to do more than 15 to 30gpm (Exhibit T-46a)(Exhibit T-46b).

Interviews of i(b)(7)(Cl I Shift Manager, l(b)(?)(C) l and OCC Operations Representative !(bl(7)(C) I Shift Manager, l(b)(?)(C) I, and OCC Operations Representative at WBN, was interviewed on December 18, 2015, Janua~ 19, 2016, February 4, 2016, and October 3, 2017, by 01, TVA OIG and AUSA !(bl(?)]l  ! US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. b7 C *oined TVA in (b)(?)(C) (b)(?)(C) (b)(7)(C) On November 11, 2015, b 7 c worked as the (b)(7)(C) OCC Operations Representative whereby he coordinated with several entities assoc1a e with the operation department to ensure there was the proper support for the outage. !lb}l7l/Cl I said that he clearly remembers that on November 11 , 2015, the maintenance work was not finished when it was decided to transition into Mode 4. ilb)U}/C} Itestified that he remembered looking into whether the transition without let-down would affect the procedure. !lbl/7\ICl I stated that he asked himself and others (NFI) in the MCR, "Is it some type of violation, is it something we are forbidden from doing and there had been quite a bit of talk in operations about that very fact." !(b}l?l/Cl I admitted that he cannot remember if he talked face-to-face with !(b)(7)(C) I or whether it was by email about moving forward. Also, i1b1m1c1 I admitted that he spoke quite a bit with !(bl(?)(Cl I Shift Manager of WBN1 about not only heating up without normal let down, but the other things that were going on that day (Exhibit T-17a, pp. 2-9, pp. 11-17).

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 140 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION When asked if !lbl(l)/Cl I had conversations with !lbl/71/Cl I throughout the day, !(bl/7l!Cl responded, "Yes, I would say, on average, probably -- and this is not just that day, it would be any day you could call the shift manager anywhere from ten to 30 times, depending on what was going on." !lbl(l)/Cl I !'.tated that he had no prior experience in a start up without normal let-down being available. In fact, reflecting over his career he could not recall anytime where he remembers taking an action with only excess let-down. !(bl(7)(Cl I suggested that !(b)f?l!Cl I was also inexperienced with this condition, so they had some conversations about whether this was "okay" and lib)(Z)/Q) I indicated that he shared with him what he had found . !fb)(7)1Ql I testified that they discussed their understanding of the system and the opinions from operators that had joined their conversation. !lbll7l/Cl I::idmitted that, "We did make what I think we will all a[ ree in hindsight, was a poor decision that should be determined that it was not illegal." !(bl(?) C} I stressed that they made a decision that they believed might have to move really slow, but that it would be controllable. !(bl/7}/Cl I::irflued that they believed that they could safely transition into Mode four for excess let-down. bl(7}(Cl I stated that his clearest memory of the day was making sure the rest of the OCC (perha s not the entire OCC but the critical members of the staff, the two managers and then (b)(?)(C) were explained the plan of how to proceed forward (Exhibit T-17a, pp. 19-24). !/bl/7}/C} Itestified that he told !(b)(?)(C) I that he wanted !lbl(7}/Cl Ito understand that this was not a normal heat-up activity that they were would go in slow and cautious. l<b}/7\/C\ acknowledged that a lot of people had access to the plant data and they knew the heat-up limits, and he wanted to make sure that this was not goin~ to be a standard evolution. Additionally_ lfb\!7}(Ql I reportedly told the OCC and lfb)O Q\ I that it is not going to be the normal heat-up they were accustomed too, and they may have to stall out at some point and just sit. According to !(b)(?)(C) I no one appeared to have any problem with the plan and there were not any additional challenges regarding the decision to proceed forward. Ultimately, ilblU}(C} I stated that they ended up transitioning into Mode four and at a certain point noticed the pressure riser level was coming up but the MCR got it stabilized. !lbl(7}1Cl Itestified that his initial assumption at that time of recovery was that the MCR just turned off the RHR, so it probably took them a while to ~et a little bit of heat to be able to control the level. !(bl{l)/Cl I recalled a conversation with lr617\(C\ I whereby Hb}(7\/Cl I told l(b)w(C) I "Hey, it looks like you all are managing this okay," and !(b\(7)/Cl  ! responded to !(bl(7)(C _ I "Here is what friggin' happened" which lead to a discussion detailing how the MCR actions had to put RHR let-down in service. l<b}!7\!Ql I stated that he shared information with key OCC people but cannot remember if he did that in the update format or once again during an informal discussion around the table. Regardless, !rbl!?l/Cl I;;icknowledged that he spread the information with a wide audience as to what had happened. ilb}U}(Q\ I suggests that before the end of shift the normal let-down system was back in service or were just about to come back in service (Exhibit T-17a, pp. 25-32, pp. 34-45). !/bl/7l/Cl I was interviewed by TVA OIG on January 19, 2016. On November 11 , 2015, !lb}/7l(Cl I role was to serve as the liaison between the MCR and the OCC. The issue that they all faced that day was whether it was accew able to enter into Mode 4 without the availability of the normal let-down system. !(b}/7[Cl I said that both he and !ib}/7}{Cl I were

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 141 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION not comfortable with doing it. !lb\/7}/C\ Isaid that doing what the OCC wanted done that day resulted in WBN1 moving into unfamiliar territory. What ended up happening was that the excess let-down system did not have the ca~acity to do the job. When asked who made up the OCC core team on November 11, 2015, !lb\/7 /Cl I said that !lb\/7\/C\ Iand !lb\CZ}IC} I were there. !lb}(l)/C} I said he could be mistaken but he thought b 7 C was seated in the engineer's chair at the OCC that day. !ibl(l)!Cl I ;:ilso thought that (b)(7)(C) was in the OCC. !lb}/7}/C} I added that they made a poor decision that day. b 7 c said that he and !rb)/7l/Cl I had telephone conversations that day about the decision. !lblCZ}/Cl I was fully aware that !!b}(7)[C\ I was not for the decision. According to l(bl(7)(C) I the decision placed the operators in a position where they had to take actions in an area where there were no established procedures. !lbl/7}/Cl I said that he sat the OCC staff down in the OCC and told them that "we are uncomfortable." !lbl/D[C} I told the OCC staff that "we need to proceed with caution." He also said he told them that they do not need to put any undue pressure on the operators. !lbl/7}/Cl I could not recall who was sitting there in the OCC when he made these statements. !lb}CZ}/Ql Iwas asked wh~ the OCC did not wait a few more hours for the normal let-down system to return to service. !lb {7)/C\ I said that waiting a few hours would have jeopardized meeting the next milestone. !lb}U}(Cl I said the bottom line that day was that the OCC made a decision based on a business need. In this particular case, according to l(bl(?)(Cl I "we" got out of balance. That balance being between running a business (money) and safety (Exhibit T-17b). !lbl/7\/Cl I was asked what happened when the site realized that their plan was not working, llb}CZ}/Cl I said that he updated the OCC, and then !lbll7}fCl I was forced to do something to counter the mistake. There was no procedure in place for the actions !lbl(?)/Cl I took. !lbl(7}/Cl I did not think that there was log kept that day in the OCC or the MCR. He added that "we just whiffed on this one". !lbl/7}/C} I said that they just forgot to make the log entries. He said it was not a cover up, a month or so after the incident, the NRC came onsite and interviewed numerous people concerning the incident. !lbl/7}/Cl I advised that the NRC focused a lot of their questions on finding out if the operators acted correctly. There were also a lot of questions about the logs (Exhibit T-17b). The agents asked ilbJ(?\!Cl I what is going on at WBN that has resulted in the OIG and the NRC showing up, irb}(l)fC\ I responded that the current desire of WBN management to meet the milestone and to "go, go, ~o, go." The OCC cared more about reaching the next milestone than they did about safety. 116 dHCl I said that the reactor operators are getting pushed "too hard" by the management team. !rb}(l)/C} I does not think that his colleagues feel comfortable expressing an opinion different than that of management. !lb117}fC\ I concluded the interview by saying that it bothers him a lot that the current WBN management team could not wait a few hours for the let-down system to come back into service (Exhibit T-1 ?b). (b)(?)(C) as interviewed by TVA OIG on February 4, 2016.!(b)(?)(C) !advised that he had earne a o more since his original interview and is current!~ on the Root Cause team looking into the November 11, 2015 incident. The additional things [bl(7)/C} I has learned is the result of him talking to others at the site. On thel(b)(?)(C) lot November 11, 2015, !rbl/7}/Cl I did go into the OCC and meet with the OCC staff. He stated that !lbl(l)/C) I was at the table as was

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 142 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilbl/7l/C\ I who was sitting where the engineering person usuall sat. He added th,t he js just about sure !lbl/7lfC1 I was there. He was mistaken that (b)(7)(C) was the _(b)(7)(C) l as it was !lb)/7)/Ql I At this meeting in the OCC, ..............._..., did not specifically tell the OCC staff that he was uncomfortable w ith heatin~ up using the excess let down nor did he tell them that !lbl/7\fC} I was uncomfortable. !lb}f7l/C I implied that he and !lblf7lfC1 I shared the same level of comfort, that while it was not something they preferred that thet thouf ht it would be "ok" to start in Mode 4 as long as they proceed slow and stayed in control. _blf7\fC_ Itestified that does not recall telling the OCC staff not to push the operators. In hindswht, i[b}/7\IC\ Iwishes he had done a better job exw essing his and !!blffilQl I concerns. !!bU(Ql I now realizes that he did not recognize !rbD}(C\ Iconcern. Likewise, the interviews conducted for the root cause have shown that he underestimated the crew's level of concern that day. ilb\17}/C\ I stated that an l(b)(7)(C) Ihas given a statement that he was up in the MCR on November 11, 2015, when he observed an interaction between i[b\17l/Cl I and a senior manager in which !lbl/7}/C\ Itold the senior manager that they were uncomfortable. According to !(bl(l)(Cl I I

                                                  !(b)(l)(C) did not recognize the senior manager, so

!!blf7l!C\ I and his team pul led the control room access records. To the end, !rblf7l!C\ I believes the senior manager was either !fb}/7\/C} Ior !fbl/71/C} I who were both in the control room at different times that day. !!b)(7)/C) I stated, "My gut tells me that this was management pressure outside the OCC." In addition to the managers being in the control room, i[blf7lfC\ I stated there were constant phones calls to the control room about what they were going to do (Exhibit T-17c). Interviews of l(b)(l)(C} l(b)(7)(C) l at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA !(bl(l)(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. When discussing the events of November 11, 2015 !!b)(7)[Ql I made the following statements (Exhibit T-07a, pp. 72-75): During questioning about the events of November 11 , 2015:

                 "Did anybody either, you know, before when you're planning to do this, during, or after this bring any concerns to you concerning about doing this? I do not want to do this or -"

MR. !lblf7lfCl I No.

                 "Did any operators or anyone come to you to say I was uncomfortable doing this and was told to do this anyway type of stuff?"

MR. i!b}UJ!Q) I Oh, oh. No, sir.

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      OI INVESTIGATION INFORMATION 143 Case No. 2-2016-042

6FFle l,-L U9E 614LY 0I INVESTIGATION INFORMATION Prior to ending the interview !(b)(l){Cl Iadded the following when asked if there was anything else he want to add, clarify, add to, or expand on?

                     "Nobody brought up anything of I feel uncomfortable at any time, including the discussions of will excess let-down work the way it is supposed to work."
                     "Nobody brought up anything that I was forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all."

!(b)(7l(C} Iwas asked by the agents what his role was with the Shift Order that was generated concerning the November 11, 2015 event. He said that !(b)(?)(C) Iin the Shift Order. He said !(b)(?)(C) I The December 18, 2015, Shift Order was written by !rbl(?l(Cl Iwith some help. He thinks that the narrative on page three was written by !(bl/7}/Cl I The timeline was written by !(bl/7l/Cl I The flow chart was generated by !(b)(7)(C) I !rbl(l)[Cl Iand !(blmrcl I !fbl(7lfCl J said he got the information for the timeline off the logs or from the site's Dataware Program. !rblmrc, Isaid that when he was interviewed by 01 in December of 2015, about the November 11 , 2015, incident !rb)(7)(Cl Igave the NRC this Shift Order. !lb\(7}/C\ I was asked by the agents where the answers came from to the uestion and Answer portion of the Shift Order. !rb}(?J[Cl I said that they came from (b)(7)(C) !(b)(?)(C) ! and Dennis REDINGER. He added that he was 98 percent sure mo._s...,... t -c a _m_ e...,.fr_o_m___, REDINGER. He is not aware of the other crew members bein_g interviewed. He then said that !(bl/7l[Cl Ihelped REDINGER. !rblr7l[Cl Iinsinuated that !/blm(Cl Iand REDINGER worked together to come up with many of the answers (Exhibit T-07b).

!rbl/7\(Cl       Isaid that Shift Orders are used to communicate to departments on lessons learned.

He said that Shift Orders were not leQal records and were not maintained in the corrective action program. According to !(b)(?)(Cl I Shift Orders were not something that the site handed over to the NRC. He did say that since the site g,enerated Shift Orders then the Shift Orders would all be available for the NRC to review if they wanted to review them. !(b}U}(Cl said that he did not think he brought the Shift Order to the 0 1interview on December 18, 2015. He said he did not recall providing Shift Order 15-50 to th,e NRC interviewers. !(bl/7l[Cl Iwas asked to look at the third guestion in Shift Order 15-50 which asked if the crew expected the condition that occurred. l~)r?lfCl Ireviewed the question and the answer then stated that the answer provided to the question had to do with what the crew actually thought at the ti me (November 11 , 2015). !(b\(7)/Q} I said that it was his understanding that the crew thought that on November 11, 2015. !rbl(7}/Cl Isaid that the "50-60" number is what the crew thought that day. !fbl[7l(Cl Isaid that !/bl(Z}(Cl Igave !fb)U)/Cl Ithe numbers, but it was !(bl/7\[Cl I understanding that !(b}l7)(C) I and REDI NGER spoke to the NRC and then the number came to !(b)(7)(Cl  ! !(bl(7)(Cl  ! stated that !(bl/7)(Cl fgot the numbers from REDINGER who was the Unit Supervisor on November 11, 2015. He said that !(blm(Cl Igave him the 50-60 number (Exhibit T-07d).

              -'l9 ~CIAL AO ~l<IT 11<1 CHAl":O~. OP'P'IC~ OP' ll<I V~~TIOATIOl<I~. l":~C'.!1 10 I<1 11 6f'f'lel,-L U9!! 6I4LY          0I INVESTIGATION INFORMATION 144 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview of l(b)(7)(C) l(b)(?)(C) Iat WBN, was interviewed by TVA OIG on January 4, 2016, wherein he provided the following information in substance. lib\17}/Q) I discussed the origins of shift order 15-50 describing that most of the answers came from REDINGER. The agents asked l/bl/7}/C\ Iwhere he got the answer of about 50-60 gpm from. He said that he got that from REDINGER. He added that the answer of 50-60 gpm is based off normal operating pressure. The agents asked l!b}m/Q) Iif they were operating at normal operating pressure. He said no, but he added that he wrote that paragraph based on discussions with REDINGER. l/b}/7}/C} I said that it was his understanding that 50-60 gpm was the capacity for Excess Let Down. He said that the mistake in the answer is that at the time they were not in "normal" (Exhibit T-44 ). Interview of l(b)(7)(C) l Sen ior Reactor Operator l(b)(7)(C) l sRO at WBN, was interviewed by TVA OIG on February 22, 2016, wherein he provided the following information in substance. l(b)(?)(C) lwas shown a copy of the shift order dated December 18, 2015, which referred to events which occurred on November 11 , 2015. He stated that the 50-60gpm number makes no sense and is not even possible with pressure only being 3501bs. He stated that excess let-down is only designed for around 20 to 25gpm at full pressure of around 22001bs. He does not think people in the control room would think they would be able to get that number, so he does not know why it is written like that. He stated, "I cannot equate my knowledge to this". He stated at full pressure you may be abl*e to get a little more than 20-.25gpm but not 50 to 60gpm. (b)(7)(C) stated he has never seen excess let down put in at less than full pressure (Exhibit T-1 Interview of!(b)(7)(C) I Unit Supervisor

  !(b)(7)(C)   I Unit Supervisor and SRO at WBN, was interviewed by TVA OIG on May 10, 2017, wherein he provided the following information in substance.
  !lb}(Z}/C}  I stated that he knows that at normal pressure, excess let-down is designed for 20gpm.

He assumed that was common knowledge. He said that 40 to 70gpm is not reasonable at all at normal operating pressure that the numbers "did not waslh at all" (Exhibit T-45). Interview of!(b)(7)(C) I Shift Manager

  !(b)(7)(C)   I former Shift Manager and SRO at WBN, was interviewed on February 23, 2017, by 0 1 and TVA OIG wherein he provided the following information in substance.

l!b}0/Ql I was asked about the content of Shift Order 15-50 and commented on the statement from the shift order "This is based on trainings the crew thought they should have been able to get 50 to 60gpm of excess let-down which they would have stabilized RCS inventory. However,

                        ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 145 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION since RCS pressure was left in normal operating pressure they were unable to achieve the expected flow." !(bl(7lfCl Iexplained that based on his training and experience he would not have expected 50-60gpm from excess let-down or have expected to be able to maintain level in the pressurizer (Exhibit T-34b, pp. 35-37). Interview of !(b)(7)(C) l atWBN .,,.._~___.., at WBN, was interviewed on August 22, 2016, by TVA OIG, and AUSA c US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

!rblU)(C) I discussed that on January 6, 2016, the NRC and TVA met at Watts Bar. i[b)U)CC:) I said I

the reason for the meeting was that the NRC, to include !(b)(7)(C) did not feel like TVA "got it" as it related to the November 11, 2015 event. i[b)Ul(Ql I said that the NRC was not satisfied with the actions taken by TVA. llb}(Z)ICl I said that the NRC did not think TVA had their hands around the issue. !rbl[7}(C} Iattended the meetin as well as his mana ement from Region II. !(b)(7)(C) I (b)(7)(C) and others from TVA attended. b7 c summarized TVA's version as to what happened on November 11 , 2015. ilbl(?)[Cl I said that !(b}(7l/Cl Iwas still telling the samj ,: i~fr&i j bout the event as they were in the middle of December 2015. After ilb\(7)/C) I spoke, chal'.~i~t]~~ !rb}l7)/Ql I that the 50-60gpm number listed in the Shift Order was incorrect. 1told the group that it was way too high. l[bl/7\[Q} I had looked into the numbers and they were incorrect. Even after llbHZ}(Q} I spoke up telling the group that the numbers were from TVA at the meeting backed off the number. kb~~~ffj' t either l1b1m1c1 I nor anyone else explained that !(bl(7)/Cl I did "chime" in and tell the NRC that under normal operating pressure and temperature the numbers (50-60gpm) could work. That replied bothered irb)UlfQl I because everyone knew on November 11, 2015 that they were not working anywhere near normal pressure and temperature. The Shift Order which contained 50-60gpm was written almost a month after the event (Exhibit T-03). Interview of !(b)(7)(C) I NRC Region II (b)(7)(C) NRC Region II, was interviewed on December 14, 2016, by 01, TVA OIG, and AUSA ......._..._.....____, US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. ~ ~~~.u.1.1.l,Wj=.!..Ql,.;Ll.l.~U.J.1.......i.u.~~= ~.i...w;;JJ,,Kl.4....WLQJ..l~ = - L J . ~ ~ - J  !(b)(7)(C) ---~~---~-------~------------;;. . from TVA attended a meeting with the NRC. b 7 c reca lled that the meeting and does not recall irbll7l/Ql I having an exchange with (b)(7)(C) nd several others did speak during bout the accuracy of the information. (b)(7)(C) suggested what really caused 1m o ou TVA's reasons for the event was that TVA d1 not recognize the level of involvement by the OCC and lack of corrective action. TVA's explanation was contrary to what NRC had established from th,.. e...,,,....,.,..,......., allegation, the Assist to Staff, and the inspector's follow-up work, which made it clear to !(b){7)(C) that the NRC had more information about the matter than TVA. Nevertheless, l/b)l?l/C! testified

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 146 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION that l(b)(l)!C) I was extremely adamant that he knew exactly what had occurred and that the (operators) crews are always transparent with him on matters. According to !(b)(l)(C l(b)(?l/C) I insisted that the cause of the November 11, 2015, event was reflective of the information contained in the presentation given to the NRC. Specifically, the information contained on slide twenty-three is what ilbl(7)/C) I ;:ind TVA said happened (Exhibit T-50). (b)(?)(C) advised he is not familiar with the shift order document as resented to b c during his interview, but Hb)(7)(C l 8dvised that he is aware that (b)(7)(C) had a co and there were some discussions surrounding the information contain therein. Additional! , (b)(7)(C) inferred tha * *

• e accuracy of the information. To that end, b 7 c deferred to (b)(7)(C) or guidance as they are better situated to address XI itT-50).

Interview of l(b)(7)(C) l NRC Reg ion II (b)(7)(C) NRC Region II , was interviewed on December 14, 2016, by 01, TVA OIG and AUSA ................,_____. US Attorney's Office for the Eastern District of Tennessee, wherein she provided the following information in substance. l/b)/7)/C) l 8tated that lfbl(7) re I had previously expressed to TVA prior the January 6, 2016, meeting and again during the meeting what NRC's concerns where and based on TVA's position, that nobody really understood what had happened. Likewise !{b)(7l(C) I recalled that TVA discussed the control ro~~ ~~Jsf the conduct of the operators and the important of adhering to plant procedures. b 7 c explained that the NRC had already established information through the allegation and inspection process which served as the baseline of NRC's position. During the meeting, lib)U)(Ql I confirmed that TVA reported information to the NRC as outlined in their presentation package (slides). !{b)/7)/C) I remember that while there were several TVA representatives in attendance it was K~;7)/C) I b 7 c  !(b)(?)(C) I who primarily briefed the NRC. When asked if lib)(7}1 recalled (b)(?)(C) challenging TVA on particular point, she said that !lbl(7}/C) ! "pushed to open the dialogue" but does not recall a specific point of contention. l/b)(7l/C) ! !'.tressed that prior to the meeting, it was her understanding that the NRC had some information that was not setting well and thus the reason for the drop-in meeting. l(b)(7)(C) l 8tated that she thought there was a need to go to Watts Bar and have a discussion with TVA which had already conducted an Apparent Cause review. Although the NRC had not fully vetted the allegations at the time of the meeting, l(b)/7)(Cl I explained that she attended the meeting to find out from TVA if TVA understood the factors that led TVA to use excess let-down on November 11 , 2015. lrb)f7l/Cl I recalled that TVA officials told the NRC that the November 11, 2105, event did not meet TVA management's expectations relative to conduct of operations, but nobody from TVA mentioned anything about OCC influencing the MCR on November 11, 2015 (Exhibit T-51 ). Interview of !(b)(?)(C) lat WBN l(b)(7}(C} Iat WBN was interviewed on May 26, 2016, by TVA OIG wherein he provided the following information in substance.

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 147 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

!lbl{7)/Cl I described that he was working on November 11, 2015. He was in the OCC for part of the time. !!bl{Z}!Cl I was aware that the normal let-down was out of service and that the excess let down had been placed in service. He also knew that there was some heatinrc ul that was going to be done within the boundaries of pressurizer level. It appeared to !(bl/7}];} that the operators underestimated what the excess let-down would let them do. llbl(Z)IQ) I did not know the operators were uncomfortable moving ahead after l/b)l?HC}                    I got the call from the NRC on December 11 saying that they had a concern. It was over the next several days that it was discovered that there were questions over how they (the operators) did not use the procedure.
!lb}{7)/Cl I stated that it was after this that he heard that some operators said they were uncomfortable. !lbH7l!C} I was aware they placed RHR let-down in service. Likewise , he knew the day of the incident that the control room had to take action to lower pressure when they got to 80 percent pressure level. He does not know how he knew this information but believes he may have read it off a status board somewhere (Exhibit T-33).

Interviews of !(b)(7)(C) !at WBN !(b)(7)(C) !at WBN was interviewed on December 18, 2015, and March 26, 2016, by 01 and TVA OIG wherein he provided the following information in substance.

!(b}/7l/C}      l indicated that he was briefed on normal let-down system repairs not being1 completed as scheduled and continuing plant start-up whiile normal let-down was not in service on November 11, 2015. !rbl/7}/C)                I described the content of the discussions including the potential heat-up rates and there being no need for just-in-time training for use of the excess let-down system. !!b\ffi/Ql             I identified that as of the December 18, 2015, interview, additional oversi[ ht had been established for the control room with specific written guidance created by
!(b}!7l/C         I He also noted that they were putting out a standing order to re-emphasize conservative decision making. He had not seen that standing order at the time of the interview but planned to review the shift order that afternoon and check it for its content. He committed to get copies to the SRI (Exhibit T-00a, pp. 12-16, pp. 31 -33).
!lb}(7}1Cl      I .:idvised that he is not a licensed operator. !!b}{l)(Cl         Iadmitted that he was working at WBN on November 11 , 2015, and suflriested that he was present at various locations within the plant to include the OCC. lrb f<c1                  I remembers that he walked into the OCC around midday on the November 11, 2015, where he learned that there had been a pressurizer level issue which was remedied . llb)(?)IQ)               I could not recall the exact way he learned that there had been a pressurizer level issue but believes that someone [NFI] in the OCC began talking to him about what had happened in the MCR. !/bl(l)!C}                         I said that the MCR was able to stabilize things (recovl/~)~~~r r t). !rb){7)(C)                I said that !(b}U}(C) I was working that day as well and remembers seeing                         in the OCC (Exhibit T-00b).

When discussing the telephone call with l!blUJCQl I on December 11, 2015, lfbl(7}fCl l contends that at the end of the call he still was not sure what event llb)/7\IQ) I was talking about. lrbl!7}(Cl l did not learn that !lbl/7}/Cl I was talking about the November 11 , 2015, event until the

                         ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      OI INVESTIGATION INFORMATION 148 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION next day. !{b}/7)(C} Idirected !{b}/7)/C} Iand !{b\(7}/C} Ito contact the Shift Managers, and through those conversations !{b\(71/C} I learned that !(bl/7\[Cl I questions were about the November 11, 2015 event. l(b)(Z)(C} I;:idmitted that he did go into the MCR that day after the pressurizer level had normalized and spoke with !(b\!7l[Cl I !(b\(71/Cl Idenied that he hu~~ed an one in the MCR. !lbl(7l/C} I may have shook hands, but he did not hug anyone. lfb} C} 1 said that i(b}U)(C} I informed him what happened but said everything was fine now (Exhibit T-00b ). i(blffi(Q\ I realized after !rb)U)fC\ I called that there had been a mistake on November 11 , 2015. !(bl/7l/C} I said that a question came up about whether or not they had fol:~~~(~}p ocedure that day. That, according to l(b)(7)(C) I was the original discussion point with 1!(b)(?)(Ql I told the agents that they did not have a procedure to cover the actions that were taken to recover the plant that day . !ib}f7lfCl I was shown a copy of the Shift Order dated December 18, 2015. !{bl(l)/Cl I said that he had not seen this particular Shift Order before. !fbl!7l[Cl I does not know who wrote the Shift Order and he did not tell !{bl!7l[Cl I to write it. He does not know where the figures concerning excess let-down capacity contained in the Shift Order came from but explained that Shift Orders are supposed to be used to provide guidance to the crews. They are written as guidance tools (Exhibit T-00b ). Agent's Analysis In summary, based on the evidence developed during this investigation 0 1finds that !fbl{7l(Ql I deliberately submitted incomplete and inaccurate information in Shift Order 15-50 regarding the events of November 11 , 2015. Specifically, information documented in the shift order contained false information to support the fictitious narrative that inadequacies of the control room operators were solely to blame for the events of November 11, 2015. Fu1rther, on I January 6, 2016, !(b)(7)(C) accl(~h~~iel b:z'. a group of NRC officials, conducted a site visit at WBN which was attended by b 7 c  !(bH7l(Ci I !(b)(7){C) I !{bl{7)(Cl I I

                                                                                                           !(b)(7)(C) and !(b- ....)(7-)(C-) --.

During this meeting, TVA management discussed the contents of Shift Order 15-50 and presented (as described below) additional information that was incomplete and inaccurate reinforcing that the MCR operators bore sole res onsibilit for the events of November 11 , 2015. On December 16, 2015, bl 7 (C rovided notes from his interview of the REDINGER to which was forwarded to b on December 17, 2015. !(b}(7}/C} Iwas present for (b)(7)(C) interview of REDINGER on December 16, 2015. During the interview it was documente that REDINGER expressed use of excess let-down to manage pressurizer level made the crew to be uneasy, but Operations tries to get things done to support the plant (Exhibit A6-E1, p. 3). .,,..,...;,.,.;.,......---t on (b)(7)(C) b7C sent an email subject ' (b)(7)(C) to Wl.!.l,aUl.lil:..,_____, with the attachment' (b)(7)(C) " The attachment containe t e o owing question and answer which place responsI 11y and gave reason on how the MCR operators came to perform the operations on November 11 , 2015 (Exhibit A6-E2):

*1(b)(7)(C)
                                ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AGDH l~J GI hO.RGE, OFFICE OF l~J~'ESTIGMIO~JS, REGlmJ II 6 f'f'le l,-L U9!! 614LY          QI INVESTIGATION INFORMATION 149 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION (b)(7)(C) llb)(7)(C) I" On (b)(?)(C) sent a document titled '.__ contained the questions swers s furthered this by sending " b 7 c "to !(b)(?)(C) I and l ltb}(l)(C} I also r,:-:-:,,::-1,-,,,,..,.,.,,=---'I a separate occasion to Watts Bar Management includingl(b)(7)(C) ......_......._._ __, b)(7)(Cl I and !lb\(7)/Cl I (Exhibit A6-E3)(Exhibit A6-E4). On December 18, 2015, 0 1conducted interviews of Watts Bar employees associated with the events of November 11, 201 b7 c and ltb}(7)1C} I both gave testimony consistent with information contained in the ' (b)(?)(C) ' that ran counter to information received in previous allegations that alleged the Shift Manager was directed to proceed on November 11 , 2015, against the recommendations of the control room operators. Agent's Note: !lb\(7)/C) I brought a copy of thel(b)(7)(C) Ito his December 18, 2015, 01 interview, and referred to it during questioning. ltbl(?l(C} Imade the following statements during his interview which failed to acknowledge that he was aware of any apprehension of the MCR operators on November 11 , 2015 (Exhibit T-07a, pp. 72-75): During questioning about the events of November 11 , 2015:

                       "Did anybody either, you know, before when you're planning to do this, during, or after this bring any concerns to you concerning about doing this. I do not want to do this or-"

MR. ltb)(7)(C) I No.

                       "did any operators or anyone come to you to say I was uncomfortable doing this and was told to do this anyway type of stuff?"

MR. !lb}r7)/Cl I Oh, oh. No, sir. Prior to ending the interview llb}(7)/C} Iadded the following when asked if there was anything else he want to add, clarify, add to, or expand on?

                          ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         O1 INVESTIGATION INFORMATION 150 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION "Nobody brought up anything of I feel uncomfortable at any time, including the discussions of will excess let-down work the way it is supposed to work."

                     "Nobody brought up anything that I was forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all."

!lbl/7l/Cl I made the following statements during his 01 interview and took responsibility for the decision to remove the RHR system from service and heat-up on excess let-down. He did not discuss other MCR operators objecting to the plan or that anyone else was pressuring him to proceed (Exhibit T-22a, pp. 20-21, pp. 37-40, p. 55):

          "We [Crew] discussed the fact that we had not done it before and we were willing to start it and see how it went. I thought we had enough excess let-down flow to be able to control pressurizer level on excess let-down."
          "I do not remember any big push back from them [Crew]."
          "Our operators are pretty good about forcefully pushing back if they felt strongly."
          "I did not [offer alternatives] because I did expect that we would be able to control pressurizer level with excess let-down. I was not correct."
          "I have control of the plant and I could have very well said I'm absolutely not heating up without normal let-down in service."
          "Well, I did not -- the reason that I did not challenge it more is because I had no basis for saying this will not work." When asked if anyone conveyed any schedule pressure or any information coming from outside the control room that might have unduly influenced him in doing this, !/bl(?l(Cl    I replied "I do not remember  anib sr ecific undo w essure."

Following the 01 interviews on December 18, 2015, !/bl IC I and !(bl ?)IC} I exchanged emails discussing their interviews which contradicted some of the information

          !(bl(7)(Cl     I provided during his interview (Exhibit A6-E5).
          !rb}(7}[Q}     I wrote - "Obviously we discussed your crews actions in my interview. I expressed that the actions the on-shift crew took were appropriate, and in no way represented a violation of our PU&A standards. I portrayed that we made a flawed risk informed decision to continue into Mode 4, and that put you on the spot to have to make a decision on how you could stop and place the plant in a safe condition."
          "Do not know how this part will turn out, as I used the term "we made a bad decision" -

meaning the OCC and management team - but could not remember who was in the OCC with me that day."

          "Bottom line, I believe that little can be done to crew personnel by the NRC about the
                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEOIAL AOEPH IPJ 0 1hO.RGE, OFFIOE OF IW.'EeTIQ,A.+IO~le , RliiiGIQ~I II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 151 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION actions taken in response to the event. On the other hand, I may need you to give me odd jobs for cash if they head-hunt for why the organization put you in this position."

         !lbl/7}/Cl      I wrote in reply - "I also believe that the overall impression will be that we, as a site, did make a bad decision based on schedule pressure. What they [NRC] will not know is it was not a site decision it was really a SR management decision and the fact that we have now been conditioned to not challenge current site management poor decisions for fear of retaliation. I am seriously considering re-interviewing and expressing my actual feelings about the current culture and daring them to retaliate against me".

During his interview by 0 1on December 18, 2015, ilb)U)/Ql I discussed an impending shift order. He noted its purpose was to re-emphasize conservative decision making. Although he had not seen that standing order at the time of the interview he stated that he planned to review the shift order that afternoon and check it for its content. He committed to provide copies to the SRI. During a subsequent interview by TVA OIG a few weeks later. !lbl(7}/C) Itestified he did not recognize Shift Order 15-50 and did not know who wrote it (Exhibit T-00a, pp. 12-16, pp. 31-33) (Exhibit T-00b, pp. 1-2). On December 18, 2015, !(b)(?)(C) !Shift Order 15-50. The Shift Order was developed in response to the November 11, 2015, heat-up, with the intent that, "The guidance will be used for making plant decisions during degrading conditions." The Shift Order attached the !(bl(?l(Cl !which indicated that on November 11 , 2015, members of the MCR operating crew did not expect the uncontrolled level rise in the pressurizer because they thought they would be able to get 50-60gpm from excess let-down which would stabilize RCS inventory. The Shift Order also attributes these errors in assumption and plant knowledge as the foundation for the events of November 11, 2015. The Shift Order presented the operators as the sole cause for the events of November 11 , 2015, and does not include any information or discussion on the involvement of the OCC or Watts Bar management in that decision (Exhibit A6-E6). 01 finds that information contained in operator training and system design documents did not support the statements contained in the Shift Order. Based on a review of operator training and system design, 0 1concludes that there was no plausible basis identified for the narratiive about the operators having a gross "misconception" about the ability of the excess let-down and how the plant operates. All licensed operators are required to have knowledge of the engineering concept of the relationship of valve position to flow rate and back pressure and specifically the relationship between let-down flow and RCS pressure. 01 finds it is not plausible that no one on the crew of licensed operators would understand its application as it related to the operation of the Excess Let-down system. The review also established that the operators would have known the system could not operate in the manner described in the Shift Order (Exhibit A6-E7). The procedure for establishing Excess Let-down, SOI 62.01, provides evidence that the operators would have known they would not have expected 50-60 GPM. The procedure states that the design flowrate is 20GPM and cautions that you could get up to 50GPM depending on plant conditions (Exhibit A6-E7, p. 56).

                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi aP  C l ,A.b Ae~H l~J GI hO.ROE, OFFIOE OF ltWEem eMIer4::,, 1iii!:EaI01q II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 152 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION CAUTION Excess letdown design flow is 20 gpm. Preop W-2.1 determined that 1-FCV-62-56, eves EXCESS LETDOWN FLOW CONTROL, can pas.sup to 50 gpm (depending on RCS pressure and 1-HIC-62-56A output), which pould cause higher than designed excess letdown and CCS temperature. Operator training specifically indicates that the design excess let-down flow capacity is 20GPM and cautions against the possibility of getting higher than design temperatures (Exhibit A6-E7, p. 125, p. 442). Although excess letdown design flow is 20 gpm, pre-operational testing determined that 1-FCV-62-56 can pass up to 50 gpm, depending on RCS pressure and controller output. This could cause higher than designed excess letdown and CCS temperature. Based on this, when placing excess letdown in service, maximum temperature is 206°F. II. Presentation Excess Letdown Objective 1 Provides a means of letdown when normal letdown is not available. Capacity of excess letdown (20 gpm ) is sufficient to compensate for RCP seal water flow into RCS and maintain PZR level. Excess letdown flow travels through the seal water return filter and back to the suction of the CCPs. plant event was not solely the main control room operators. Sched! ~e)f sent out by the OCC to Watts Bar managers including; !(b)(7)(C) I b7c tt'rt Information gathered during the investigation provided further evidence that the cause of the operations were and !(b)(7)(C) I which detailed the planned removal of the RHR system from service before returning the normal let-down line to service. Updates to the outage schedule following the event indicated the delay and need to wait for normal let-down to return to service (Exhibit A6-E8)(Exhibit A6-E9)

                 ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1hO.RGE, OFFICE OF IW.'EeTIQ,A.+IO~le , lxlGIQ~I II 6 f'f'le l,-L U9!! 614LY    OI INVESTIGATION INFORMATION 153 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION I In an e-mail !lb}(7)/C) (b)(?)(C) sent to all Shift Mana ers on (b)(7)(C) __, (Exhibit A6-E10) . he stated he was Subseq uent interviews of the licensed operators listed below, also failed to corroborate the assertions contained in the shift order and provided additional contradictory information. In conflict with the information provided in shift order, interviews and evidence gathered showed that members of the crew did not have a misconception about the capabilities of the excess let-down system and did not think they would be able to get 50-60 GPM from excess let-down. The interviews also established that the operators did not support taking the RHR system out of service. !lb}/7)/C) I stated during several interviews and i1ncluded in his written statement about the events of November 11 , 2015, that even though he voiced his concerns to the OCC, the OCC directed the control room operators to remove RHR from service and allow RCS to heat-up. !lb)(7}/Cl I stated that no one said that night that they knew the heat up using excess let-down could be done and that no one in the control room wanted to move forward. (Exhibit A6-E11 )(Exhibit T-22b)(Exhibit T-22c)(Exhibit T-22d)(ExhibitT-22e). REDINGER stated during several interviews and included in his written statement about the events of November 11, 2015, that none of the control room operators had a good feel about how much excess let-down flow the crew would get at low pressure and that the crew was not sure what the capabilities of excess let-down would be during the plant conditions on November 11, 2015. He stated that he did not provide the 50-60gpm number to !lb\17)/C\ I which was included in the shift order. While they did not have enough information that day to tell the OCC that it absolutely would not work, no one felt like it was worth the risk. REDINGER explained that none of the MCR operators were comfortable performing the plant operation and raised their concerns to the SM and to the OCC. After discussions with the OCC, !lbl(?)/Cl I came back and told the control room that it had been decided to go ahead and move forward (Exhibit A6-E1 2, p. 2)(Exhibit T-40a, pp 17-38)(Exhibit T-40b, pp. 1-2)(Exhibit T-40c, p. 1) (Exhibit T-40d, pp 1-2, pp. 4-10)(Exhibit T-40e, pp.1-3). !(b)(7)(C) !described during his interviews that all of the license holders in the control room on November 11 , 2015, were against moving ahead. He explained that the OCC directed the removal of the RHR system and was providing reassurance to the MCR operators that use of the excess let-down system would work for the heat-up. In respect to the information iin the shift order he identified that the crew did expect PZR level to rise because they did not expect 50-60gpm from excess let-down at that pressure. He explained that this was a main argument used against the plan, but the crew was pushed hard by the OCC. He stated the shift order portrayed the operating crew as deciding to take the actions of November 11 , 2015, on their own but they were not willing participants, and, did what they had to do to not damage the plant (Exhibit A6-E13, pp. 9-10)(Exhibit A6-E14)(Exhibit T-01b, pp. 13-14)(Exhibit T-01a, pp. 2-3, pp. 14-15)(Exhibit T-01c). !lb)(7}/Cl I described during his interviews that there was pressure being felt in the Control Room from the OCC to move from Mode 5 to Mode 4. He discussed that licensed Operators voiced their concerns with the plan to move ahead using the Excess Let-Down System and l{b)/7}/C) I was not for the idea. Although !lb)(7)/C} I communicated to the OCC the concerns the Control

                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      QI INVESTIGATION INFORMATION 154 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Room personnel had with the plan, the OCC decided on a plan to proceed with the heat-up. I (/bl(l)/Cl I stated, "I felt like it was a very very bad idea to proceed on." !(b)(7)(C stated the operators all just knew it was a bad idea based off their training and experience. ilb)!7)(C} I recalled saying out loud "this is stupid" when (/bl(7)/Cl I told them that the OCC said to proceed (Exhibit T-16a) (/bl(7)[Cl I P.Xplained the people involved did not provide details of the event for the Shift Order. He stated that it appeared on the Shift Order that the person who wrote it was trying to make the event look like it had been a planned thing that was well thought out and controlled (Exhibit T-02c). I !(b)(?)(C) described during his interviews that he talked to everyone on the Unit 1 side in the main control room that day about heatinf up without normal let-down being available. None of them thought it was a good idea. !rbJ!7)rc I said that when he saw the "50gpm" answer given in the statement he could not figure out where that number came from. When he read the number "50" on the document he told his peers that the number "50" was just silly. He added to the interviewers that he did not tell anyone on November 11 , 2015, that he thought they could get that out of excess let-down. The number was totally unrealistic. Speaking of the plant manaw ~r, !lb)(?}IQ} I said on November 11, 2015, after the control room personnel stabilized the mlant b\(7)/C) I r,ame into the control room and congratulated everyone. ilb\(7)/C) I recalled bl(l)(Cl I saying, "we put you guys in a bad place today". (/bl(7}[Cl Igave ilb}l7}1C} Ia bear hug (Exhibit T-05a)(Exhibit T-05b). On the (b)(?)(C) of January 6, 2016, NRC's (/bl(l)(Cl I received supplemental information to allegation -A-214 that was submitted by !iblaJ[Cl I This information addressed the content of Shift Order 15-50 and the events of November 11 , 2015. !/b}(Z)IC) I documented a conversation with (/b\(71/C\ I where they discussed operator push-back to the OCC and information being promulgated associated with the plant operations that day. He inclu,ded excerpts from the shift order and made annotations where he believed they were inaccurate. He noted that neither he nor the other three MCR operators he had talked with had been briefed on its content. He highlighted disagreement with the 50-60gpm number and commented that operators were specifically pushing back because they needed all normal let-down orifices open to keep up with pressurizer level increase (Exhibit A6-E15). On January 6, 2016, Region II NRC Senior Managers conducted a site visit at Watts Bar. which was attended b~ Watts Bar senior managers including !(b)(7)(C) I I !(b)(7)(Cl and ilb 7}/Ql I During this meeting, the Watts Bar managers jointly made a presentation to NRC officials that included information about the events of November 11, 2015.

                                \fr In addition to the slides provided to the NRC, discussions occurred using additional Back-up Slides TVA had pre&~,~~               the meeting. Included was a discussion of the content of Shift Order 15-50 which              6    specifically questioned the TVA assertion that the crew expected 50 - 60 GPM from excess let-down based on their training . Even after !rb\(7)/Q) I spoke up telling the group that the numbers were wrong, neither !lb)(?)lC}              Inor anyone else from TVA at the meeting backed off the number (Exhibit T-03, p. 8)(Exhibit A6-E16, p. 1, p. 24 )(Exhibit A6-E17).

The following "insights" were presented by TVA in slide twenty-three to the NRC during the January 6, 2016, meeting associated with the Nov 11, 2015 event (Exhibit A6-E16, p. 1, p. 24):

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 155 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

• Operator fundamentals - Conservative decision making
• Procedures o Did not follow our rules o Procedures were not in hand o Deviate from procedures without proper authorizations The information Watts Bar managers presented to the NRC placed accountability for the events of November 11 , 2015, solely on the lack of conservative decision making by the MCR operators and various procedural issues. Neither slide twenty-three, nor TVA senior managers during the meeting, discussed the roll the OCC and TVA Management had in the decision to remove RHR from service, the questioning attitude demonstrated by the MCR staff to the OCC, and that MRC operators questioned the capability of excess let-down to control pressurizer level. During the meeting TVA presented actions taken in response to the events of November 11, 2015, which comports to the issue being exclusive to the actions of the MCR operators. These actions included the !lbl/7l/Cl Iand !lb)/7l(Cl I performing paired observations with Shift Managers and a shift order implemented to reinforce standards and expectations for conduct of evolution briefings. Nevertheless, NRC's !rblr7HC Itestified that

!rbl{?)(Cl Iwas extremely adamant that he knew exactly what had occurred and that the (operators) crews are always transparent with him on matters. According to !(b)(7)(C) insisted that the cause of the November 11, 2015, event was reflective of the._1_nf,..o-rm - at...1o_n_ ____. contained in the presentation given to the NRC. Specifically, the information contained on slide twenty-three is what !/bl(7}/Cl I and TVA said happened (Exhibit T-50) (Exhibit A6-E16, p. 1, p.24). Evidence obtained during the investigation identified that l(b)(7)(Cl I I

                                                                                            !(b)(7l(C) !(bl(7l(Cl and !(bl/7l(Cl         Iall had additional information that was withheld or misrepresented to the NRC during the January 6, 2015 meeting.
           !rbl(7}/C}       Iwas (b)(?)(C) an e-mail sent on l(b)(l)(C)                          I  between l/blr7l(C}

and !(bl/7l/Cl I in which b 7 c places direct responsibility for the decision to emceed on Nov 11, 2015, on the OCC and management, not the crew. !(bl(l)(Cl I [ b)(7)(C) I and !/bl{7)/Cl Iall had knowledge of and were described as supportive of the decision to remove RHR from service before normal let-down was operational. I

           !(bl(l)(Cl !(bH7l(Cl        I anrl !/b)U)fC\      Iwere all involved wl,)J*~-...,....,,....._..""""'""""'.......,.......,......__,

November 11, 2015, and were party to an e-mail sent on ._(b_)(_?J(..... C_J ____________. (b)(7)(C) from the l(b)(7)(C) lwith subject ' (b)(7)(C) (b)(7)(C) ' to Watts Bar managers. This email contained details ""' o.-...-=- e..,...,.,,n""' 1,....,......,p= an

                                                                                                                                 = --~

opera 1onal schedule for the day, including activities to remove the RHR system from service and perform a plant heat-up before normal let-down was returned to service.

           !rb1mrc1 I reply to this email demonstrates his level of involvement in the activities on November 11, 2015. !(b)(7)(Cl                I in his 01 interview on December 18, 2015, stated that the OCC had discussions of those activities and he was knowledgeable of the same (Exhibit A6-E5, pp. 1-2) (Exhibit A6-E8, p. 1)(Exhibit A6-E9, p. 1)(Exhibit T-200a ,
                         ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         O1 INVESTIGATION INFORMATION 156 Case No. 2-2016-042

6FFlel,-L U9E 6f4LY O1 INVESTIGATION INFORMATION pp. 12-16). During an interview, !(b)(?)(C) !stated that there was discussion in the OCC to remove RHR and allow the heat-up to begin. !(b)/7)/Cl Isaid that they had many discussions about that in the OCC and in the main control room with the Shift Manager. !(b)(?)(C) said that ilb\(7)/Ql I and ilb\(7}/Ql I hoth were involved in the decision and both knew exactly what was going on_ ilb}(l)(C) Istated that both !/b1(7l(Cl I and i(b){7)/C} I were in favor of removing the RHR system (Exhibit T-21d, pp. 6-7). TVA's information, presented at the January 6, 2016, meeting and as documented in the Shift Order, were determined by 01 to be incomplete and inaccurate. Specifically, as previously annotated, the control room operators did not corroborate the assertions in the shift order that the crew did not expect the condition that occurred or based on training the crew thought they should have been able to get 50-60gpm from excess let-down which would have stabilized RCS inventory. No operators indicated this was true and most operators made statements directly contradicting this assertion. Operators indicated they expressed reservations about the risks of proceeding and they were directed by OCC to proceed with the removal of the RHR system from service. MCR Operators expressed that they did not have any misconception about the capabilities of the excess let-down system at low RCS pressure. Therefore, based on the evidence, 01 determined that TVA's information, presented at the January 6, 2016, meeting and documented in the Shift Order was deliberately not complete and accurate in all material respects. Specifically: (Exhibit A6-E18) TVA MCR operators understood, via their experience and training, the capability of excess let-down and raised questions to the OCC. MCR operators demonstrated an element of conservative decision-making when they raised risk concerns to the OCC regarding the abillity to control pressurizer level once RHR let-down was secured. The OCC was aware of MCR operator's concerns . TVA management was aware of, and supportive of, the OCC 'plan of the day' to proceed with the plant heat-up, while securing RHR let-down and continuing on excess let-down. This information was known to some or all TVA management attendees at the on-site January 6, 2016, meeting with Region II NRC Senior Managers. The information conveyed to NRC at the January 6, 2016, site meeting was material because the NRC staff would have conducted additional and/or more timely safety reviews into the November 11, 2015, evolution and the NRC would have conducted additional reviews into TVA's apparent and root cause analyses including reviews of corrective actions, had TVA senior managers conveyed complete and accurate information to the NRC. The information contained in Shift Order 15-50 was material because it was directly addressin the subject of an alleg.ation under review by the NRC. The shift order included the ' (b)(7)(C) ' which was referred to by !(b)[7)(Cl I during his interview

                  ,~ef Fef't 1-UBUe OI aete1'Uf'tE Wlf l Ieuf )fl(fifif'te1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPNESTIOMIOPJS, REO IOPJ II 6 f'f'le l,-L U91! 6f4LY          O1 INVESTIGATION INFORMATION 157 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - O1 INVESTIGATION INFORMATION with 01 on December 18, 2015. Additionally, this information directly impacted the disposition of allegations being reviewed by the NRC. Conclusion Based on the evidence develo } ed during this investigation, 01 substantiated that !(b)(7)(C) I !(b)(7)(Cl !(b)(7)(C) I and !(b)(7)1C) I deliberately presented incomplete and inaccurate information concerning the November 11 , 2015 RHR event as documented in Shift Order 15-50 and presented to the NRC during a site visit on January 6, 2016.

                     ,~e,= FeR fi'UBLl6 Dl96L69URE 'l'VITI ,eu,= >'<fi'fi'RS'"'>'<L eF OPEO IAL AOEPdf !Pd 0 1IAROE , OFFIOE OF IPd~'EOT IOATIOPdO, REO IOPd 11 6 ffleliltt USE 614 LY     O1 INVESTIGATION INFORMATION 158 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 7 Submission of incomplete and inaccurate information by TVA Managers to 0 1during interviews on December 18, 2015. Applicable Regulations 10 CFR 50.5: Deliberate Misconduct 10 CFR 50.9: Completeness and Accuracy of Information Documentary Evidence Emaill(b)(?)(C) I Dennis REDINGER interview notes sent by !(b)(7)(C) I(A7-E1) Email .__ ____..., Email exchange between !fbl(7JfCl I and !fbl(7JfC} I (A7-E2) Testimony Interviews of!(b)(l)(C) IShift Manager i-l(b.b.,):..)(_Cc)__.....,I SM at WBN was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA ....(...iIT....i(.._.j_______,! US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. Agent's Note: In his initial interview with 01 on December 18, 2015, !/blf7)fCl I failed to provide the same level of detail and specifics as he provided in subsequent interviews. On December 18, 2015_ lrb)W/Cl I was interviewed by 0 1concernin the events of November 11 2015 and rovided the followin information. b 7 c (b)(7)(C) in many different nuclear power plants, DOE facilities, en ineering firms. II.W,lj,,j~---' has been licensed since (b)(?) nd a Shift Manager since!(b)(7)tc1 I b7c explained the plant had removed normal let- own rom service the night previous to the shift that he took over on the (b)(?)(C) of ovember 11, 2015. A~ e had heated up to enter Mode 4 which is 200 degrees. A (b)(7JtC) e secured both traTn's"orRHR to allow the RCS to continue heating up. The plan for ovember 11, 2015 was to heat-up and pressurize RCS and enter Mode 3 at some point during that day or that night. The normal let-down system for CVCS was out of service for repair to a leaking valve and they had placed the alternate let-down system, excess let-down, in service for let-down capabilities. Other than that, all the other plant conditions were normal as to be expected for Mode 5 and Mode 4 (Exhibit T-22a, pp. 4-11 ). !fblf7)fC} I discussed that nobody raised any concerns nor did any of the crew have any questions or concerns about trying to do a heat-up on excess let-down. lfbl/7\fQl I explained that the crew discussed the fact that they had not done it before and were willing to start it and

                                  ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF SPEC IAL AGDH l~J GI hO.RGE , OFFIOE OF ltWESTIOMIOP40, REOIOPJ II 6 f'f'le l,-L U9!! 614LY    OI INVESTIGATION INFORMATION 159 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION see how it went. !(bl/7}/Cl I stated he thought they had enough excess let-down flow to be able to control pressurizer level on excess let-down. When asked about the crew's reaction to planned events of the day, !lb}U}IC} I stated he did not remember any big push back from the crew. However, !/bl/7}/Cl I remembered being a little bit anxious continuing the start-up activities with only excess let-down because he had never done it like that before and was not one hundred percent sure that it was going to go the way that he anticipated it to. !lbl(Z)IC} I reasoned that he did not challenge the path to move forward because he had no basis for saying it would not work. When asked about influences on his decision concerning schedule pressure or any information coming from outside the control room that might have unduly influenced him in his decision he stated he did not remember any specific undo pressure (Exhibit T-22a, pp. 15- 19, pp. 21-40, pp. 43-56). On January 19, 2016, !/bl/7}/Cl I was interviewed b TVA OIG and provided the following information !(bl/7)/Cl I explained that on the (b)(?)(C) of November 11, 2015, WBN1 was at Mode 5. WBN1 had just reassembled the reactor and the temperature was less than 200 degrees. OCC directed the MCR to move to Mode 4 which would have kept the site on schedule. The operating crew moved to Mode 4 as planned and as instructed. !(bl/7}(C) further explained that aroun (bJ(?XC) ours, all prerequisites to move to Mode 4 had been handled. !(bl(7)/Cl I instructe e MCR to go to 210 deg rees and maintain that tern erature which placed the plant into Mode 4. According to !(b)(7)(C) I the OCC told ._(b_)(?_)(_Cl_ _ _ _...., OPS OCC representative, to inform !lb}l7)/C1 I to go to........,........,3 and take the tem~erature up to 350 degrees. !lbl(l)/Cl Ifurther explained that around ibH7HCl he OCC directed l@WQl Ito take RHR out of service, and then move to Mode 3. b testified that he informed !lb)/7)/C) I that he was uncomfortable moving to Mode 3 and that they needed to stay where they were and wait for the let-down system to come back into service in a few hours. !(bl17]Cl I said he mentioned to !/bl(7XCl Ithat the OCC was pushing too hard. According to !(b)(7)(C) I !lbl/7}/Cl I was also uncomfortable with the decision. !lbl/7]Cl I explained that the OCC was pushing too hard and wanted to stay on schedule (Exhibit T-22b). !/bl(7)/Cl I said that !/bl(7)/Cl I raised !/b)(7}/Cl I concerns to the OCC and recalled that !(b\(7)/Cl I gathered everyone around a table and told them of !lbl!7l/Cl I concern. 1/blU}/Cl I stated that llb)m/Cl I::ilso told them that they were pushing the operators too hard and he wanted it to stop. According to !(b)(7jlCl I the OCC dismissed the concern and instructed !(b)(l)(C) I to move to Mode 3. ibrnrc) I said that he would have pushed back harder on November 11, 2015, but he was worried that he would be somehow reprimanded for not getting on board with the decision to move to Mode 3. His actions in the MCR were heavily influenced by his fear of losing his job (Exhibit T-22b ). On July 20, 2016, !lbl/7)/Cl I was interviewed by TVA OIG and provided the following information !lb)fD/Cl I advised that there was no discussion on November 11 , 2015, that it might be possible to get 70gpm using the excess let-down !lb)/7}/C) I stated, "I do not think you could ever get 70gpm out of excess let-down." If someone had said 70gpm was possible, kbl{7)/Cl I stated that the conditions would have to be "absolutely perfect" at full pressure to ever get close to that and even then, it would be a "slim chance." Regardless, !/bl/7}(Cl I

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 160 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION stated in the MCR thatl(b)(?)(C) l"no one had the number 70gpm on our brain anywhere." !lbl{7)/Cl I stated that no one said that night that they knew the heat-up using excess let-down could be done. Rather, everyone said that they did not know how it would react and they (licensed operators) knew they had "stuff' they could do if it went wrong. !lblCZ}/Cl I stated that the "big gu ys" were saying "go" and the operators had actions in their back pocket to use if it failed. 1/b\[l)IC) I stated that no one in the MCR wanted to move forward. !/b)/7l/Cl I is not aware of whether any of the other guys talked to !ibl/7}/C) I About a month later when the NRC brought up the issue, !/bl(7}/Cl J was in !iblCZ}/Cl Ioffice with l!b)/7}/C\ Iand !rb\U)(Ql I At which time, l/b){D/Ql I askecl l!b)U)/Q} I if l!b)!7JIQ) I should be removed from watch until they found out the answers to the questions. !/bl(7)/Cl said "Yes." !/b)/71/Cl I stated that he was glad he had been in the meeting and heard the conversation because he realized it was not a punitive thing but rather just a conservative measure until the NRC was comfortable. !/bl(7)/Cl I also believes it was to position themselves to look better to the NRC. !(bl/7l/Cl I said this was normal and he would have done the same thing . !/blCZ}/Ql I went back to his regular work control job and was able to fill in the next time he was asked for help in watch standing. !(b}CZ}/Cl I said he was never remediated. !/b\(7)/Cl I never heard !/b}(7)/Cl I or !/W?}(C) Italk about taking anyone else off watch because "the buck stops with me !(b)(?)(C) I (Exhibit T-22c). On September 6, 2016, !/bl(l)(C) I was interviewed by AUSA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, TVA OIG and 0 1wherein he provided the following information. Although!(b)(7)(C) jasserted that he was not worried ab~.i....u.!u..i . w.

                                                                                                        * .Lld...L
                                                                                                                 * =!.l,<£.~   .I.Ll.y OCC, !/b}CZ}/Cl       I was certainly not comfortable about challenging the (b)(?)(C)                                                 ,

and!(b)(?)(C) !about Qlant decisions. (b)(?)(C) emp as1ze t at once the first engineering test was over, he called Kbl/7}/C} Ito inquire ow much longer before the valve (normal let-down) was in-service. According to !(b)(7)(C) I !/b}CZ}/Cl I told him the valve would be ready soon. [rb}CZ}/C} I said the schedule called for WBN 1 to proceed to Mode 3. !/b}Ul(Cl I stated there were no procedures in place about what to do or not to do when heating up using excess let-down, l/b}/7l/Cl I said there was nothing in writing saying it cannot be done. l/b1mrci I disclosed that he was uneasy about proceeding partly due to the fact that he had no experience heating up using excess let-down. !/b)(?l/C} ] stressed that WBN1 was not at full pressure, but l/b)/7\rci I :::idmitted he had no idea how using the excess let-down would affect the pressurizer level. Likewise, !(b}{7)/C} Iwas unable to estimate how much inventory (water) they expected to get out using excess let-down, no numbers were discussed (Exhibit T-22d). !/b}(7)/Cl I stated that he knew there were ways to control the 1ant if excess let-down did not work and if the plant did what he was "afraid" it would do. !ib){Z)/ l 2 I explained that the procedures are not written for every step (scenario). !/b}/7)/Ql I stated that he knew how to recover the plant if excess let-down did not work and understood that the pressurizer level will go up during heat-up. !ib)(l)(C) I stated that the first step for heat-up was to remove the RHR. Once the RHR was removed, the temr erature in the RCS would increase. !ibl/7\/Cl I stated that prior to removing the RHR, lrb}U}/C I set some trigger values to ensure they took action. At this point, nobody could put their finger on why they should not heat-up. According to !(b)(7)(C) I if he did not have contingencies then he would have been more concerned.

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJO, REOIOPJ II 6 f'f'le l,-L U9!! 614LY           O1 INVESTIGATION INFORMATION 161 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb}/7}/C\ I stated that the licensed operators were not overly experienced and once it was discussed none of them had an opinion one way or the other exce12t !lb}/7\!C} I i{b\/7\{C} I stated that no one else said it was not a good idea which caused l16im1c1 I to start doubting himself because he seemed to be the only one that was uneasy. In regard to ...b_..7........ c _ _ ___ !lb}/7\[C} I testified that i{b1{7)/C} I basically said something to the effect that, "He (b)(7)(C) felt !fbl/7)/Ql I pain but we have a schedule." !lb)Ul/Ql I confirmed that he set a trigger value of 80 percent pressurizer level where they were to open the PORV to control the rate of heat-up. They then took the RHR out of service and the pressure quickly got to 79 percent which was faster than they anticipated. ilb)U)CC) I said the rate of heat-up is what "killed" us because it out-ran the excess let-down system which is what !/bl{l)/Cl I suspected was going to happen. At this point, REDINGER opened the RHR inlet valves and the pressure level went down (Exhibit T-22d). A ent's Note: Testimon from the other control room operators (REDINGER, (b)(7)(C) b c and !(b)(7)(C) I on shift during the November 11 , 2015, events con ra 1c s b c statement that none of the other operators had an opinion on removing RHR from service. Once the normal let-down got fixed they reconfigured everything and moved on. !lb}(7)/C} said that they should have just waited until the normal let-down was fixed. About ten minutes after they opened the relief valve and recovered. ilb\U)(Q\ I came in the MCR and thanked everyone for not letting the plant get out of control. !lbl/7l[Cl I said it was clear that !rb1(7)/Cl had been in the OCC watching the event on the monitors and knew what had just happened. ilbl{l)/Q\ I said the event was not logged and no CRs were written. ilb\(7)/Q) I admitted that he did not check the logs and acknowledged that they made mistakes. !lb}/71/C\ I could not recall who the Unit Supervisor was on the day of the event, but confirmed that later that afternoon, he sent an email to the other Shift Managers telling them, "Do not try to heat-up the plant using excess let-down." The comment on the email about not letting anyone talk you into it was made because it was not his idea to proceed with the heat-up without normal let down in service. !rb\(7)/Cl I does not believe anyone in the OCC would have put the plant at risk on purpose. However, the lack of experience, knowledge, and schedule pressure all happened because they were trying to see how fast they can get back to making money. ilbl(?)/Q} I expressed that everyone knew what he was doing, why he was doing it and what he had to do to recover the plant. !lb\/7l[Cl I stated that at the time all these "smart people" were saying it is "ok" to do it and he !(b)(l)(C) I was the only one saying "no" so he talked himself into thinking it was alright because everyone else felt it was alright (Exhibit T-22d). On April 3, 2017, ilb\(7)/Q\ I was interviewed b TVA OIG and rovided the followin said that he recalled (b) 7)(C) or (b)(7)(C)

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

a I was

                                                               ~..wa~=..LJ.l,j.....i..i.tl.lJ'-' no remem er w 1c one I was, but osition. !lbl(7}/C}   I also said that telling during the same conversation he was informed that .................__. and ilbl(7)/Cl I wanted it done or were for it. !lb\(7)/Cl                 I said that he let others in the OCC know that he was not in favor of doing it and did not want to do it. !lbl/7\/C\                          I said that the OCC knew how he felt. !/b\/7}/C} Itold the
                                ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY              O1 INVESTIGATION INFORMATION 162 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION agents that he could not remember exactly who all he told in the OCC, but he did know it was more than just !lbl(l)/Cl I !(bl/7}(Cl I added that he has a family to feed (Exhibit T-22e). Interviews of l(b)(7)(C) (b)(7)(C) at WBN was interviewed on multiple occasions by the NRC, TVA OIG, and A SA ,.._..;..,...;;...______, US Attorney's Office for the Eastern District of Tennessee, where he provided the following information in substance. During questioning about the events of November 11 , 2015, !lbll7l/Cl I made the following statements (T-07a, pp. 72-75): During questioning about the events of November 11, 2015:

          "Did anybody either, you know, before when you're planning to do this, during, or after this bring any concerns to you concerning about doing this. I do not want to do this or -

MR. l(bl(7)(Cl  ! No.

          "Did any operators or anyone come to you to say I was uncomfortable doing this and was told to do this anyway type of stuff?"

MR. l/b)(l)/C) I Oh, oh. No, sir. Prior to ending the interview l/bl(l)/Cl I::ldded the following when asked if there was anything else he want to add, clarify, add to, or expand on?

          "Nobody brought up anything of I feel uncomfortable at any time, including the discussions of will excess let-down work the way it is supposed to work."
          "Nobody brought up anything that I was forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all."

Agent's Analysis In summary, based on the evidence developed during this investigation, 01 substantiated that !rbJ/7\(C) Iand llb)/7\/C) I deliberately provided incomplete and inaccurate informatiion durin interviews by 0 1 regarding the events of November 11, 2015. On December 16, 2015, (b)(7)(C) (b)(l)(C) provided notes to llb){?)/CJ Ifrom his interview of the Control Room Supervisor Dennis REDIN ER) on shift during the events of November 11, 2015, which was forwarded to l(bl(7lfCl Ion December 17, 2015. !iblf7)fC} Iwas present for the interview on December 16. During the interview it was documented that REDINGER expressed that using excess let-down to manage pressurizer level made the crew uneasy, but Ops tries to get things done to support the plant (Exhibit A7-E1 ).

                     ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEOIAL AOEPH IPJ 0 1hO.RGE, OFFIOE OF IW.'EeTIQ,A.+IO~le , REGIQ~I II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 163 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On December 18, 2015, 0 1conducted interviews of Watts Bar employees associated with the events of November 11, 2015. !lb)(Z)/C) I and !lb)(Z)/C) I both gave incomplete and inaccurate testimony that ran counter to the information being reviewed through an Assist to Staff (2-2016-015F b 0 1and RII inspectors as part of an allegation that alleged the Shift Manager (b)(7)(C was directed to proceed on November 11 , 2015, against the recommendations of the control room operators. During questioning by 0 1about the events of November 11, 2015. i/b)U)/Ql I was asked about his knowledge of any concerns expressed by main control room licensed operators. !lbl(7\(Cl Idid not acknowledge having any knowledge that any licensed oherator ex ressed concerns or that any were uncomfortable concerning the plant operations. lumrci 1 emphasized at the end of his 0 1interview "Nobody brought up anything of I feel uncomfortable at any time, including the discussions of will excess let-down work the way it is supposed to work" and "Nobody brought up anything that I was forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all." !(b\(7)(Cl Ifailed to ~rovide that during a December 16, 2015, internal licensee interview of REDINGER, that !(b {?)(Cl Iwas present for, where REDINGER discussed that using the excess let-down to manage pressurizer level caused the crew to be uneasy (Exhibit T-07a, pp. 72-75)(Exhibit A7-E1 ). l!b)(7)/C\ Imade the following statements during his 0 1interview on December 18, 2015, which failed to acknowledge that he was aware of any apprehension of the MCR operators on November 11, 2015 (Exhibit T-07a, pp. 72-75): During questioning about the events of November 11 , 2015:

                  "Did anybody either, you know, before when you're planning to do this, during, or after this bring any concerns to you concerning about doing this. I do not want to do this or-"

MR. !lb\(7l(C\ I No.

                  "did any operators or anyone come to you to say I was uncomfortable doing this and was told to do this anyway type of stuff?"

MR. !(bl(7l(C\ I Oh, oh. No, sir. Prior to ending the interview llb)/7\rc, I::idded the following when asked if there was anything else he want to add, clarify, add to, or expand on?

                  "Nobody brought up anything of I feel uncomfortable at any time, including the discussions of will excess let-down work the way it is supposed to work ."
                  "Nobody brought up anything that I was forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all."
                     ,~e, fieR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L efi SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 164 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION During his December 18, 2015 0 1interview about the events of November 11 , 2015, l(bl{7l(Cl testified under oath about his motivations for proceeding with the start-up activities, crew feeling, and who made the decision to move forward. !(bl(7l/Cl I provided information that in totality made it appear that he was independently exercising his authority as the Shift Manager to make decisions on November 11, 2015, without objection by the other licensed operators on watch in the main control room and without any undue external influence (Exhibit T-22a, pp. 20-21 , p. 37, p 40, pp. 55-56): l(b)(?l(Cl I made the following statements during his 0 1interview and took responsibility for the decision to remove the RHR system from service and heat-up on excess let-down. He did not discuss other MCR licensed operators objecting to the plan or that anyone else was pressuring him to proceed (Exhibit T-22a, pp. 20-21 , pp. 37-40, p.55):

          "We[Crew] discussed the fact that we had not done it before and we were willing to start it and see how it went. I thought we had enough excess let-down flow to be able to control pressurizer level on excess let-down."
          "I do not remember any big push back from them [Crew]."
          "Our operators are pretty good about forcefully pushing back if they felt strongly."
          "I did not [offer alternatives] because I did expect that we would be able to control pressurizer level with excess let-down. I was not correct."
          "I have control of the plant and I could have very well said I'm absolutely not heating up without normal let-down in service."
          "Well, I did not -- the reason that I did not challenge it more is because I had no basis for saying this will not work."

When asked if anyone conveyed any schedule pressure or any information coming from outside the control room that might have unduly influenced him in doing this. l(bl/7l(Cl I replied "I do not remember any specific undo pressure." Following the 0 1interviews of December 18, 2015. l(bl/7l(Cl I and llblr7l(Cl Iexchanged emails that!(b)(7)(C) !discussing their testimony which contradicted some of the information ilb}Q){C} I provided to 0 1during his interview. This included details on information that was either withheld or failed to be honestly represented to the NRC. l(bll7l(Cl I wrote - "What they [NRC] won't know is it was not a site decision it was really a SR management decision. and the fact that we have now been conditioned to not challenge current site management poor decisions for fear of retaliation. I am seriously considering re-interviewing and expressing my actual feelings about the current culture and daring them to retaliate against me" (Exhibit A7-E2).

                     ,~e, FeR 1-UBUe 0 1aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF ai-ECIAL AeEPH IPJ Ol lii!ROE, OFFIGE OF ltWEGTIOMlmJG, AEOlmJ II 6 f'f'le l,-L U9!! 614LY   OI INVESTIGATION INFORMATION 165 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION ilbl/7l/C\ I also contradicted his statements in subsequent internal interviews and interviews with TVA OIG without TVA OGC present. On multiple occasions following his 0 1 interview, !!bl/7\/C) I provided additional information to TVA which was excluded from and in some examples contradicted his testimony to 0 1:

          !{b)(Z)(C)     I said he mentioned to !/b)(Z)/C} Ithat the OCC was pushing too hard.
          !lbl/7\/Cl     I stated that ilbl(7)/C\ Ialso said he was uncomfortable with the decision.

ilbl(7)/Cl I explained to the investigators that he thought the OCC was pushing too hard to stay on schedule. The OCC wanted to meet the schedule and not go over the scheduled time for the outame. According to !(b)(?)(C) I the occ dismissed the concern and instructed !lbl/7 _C\ I and the Control Room to move to Mode 3. llb}U)!C} I said that he would have pushed back harder on November 11, 2015, but he was worried that he would be somehow reprimanded for not getting on board with the decision to move to Mode 3. His actions in the Control Room were heavily influenced by his fear of losing his j ob (Exhibit T-22b ).

          !lbl(7)/Cl     I stated that no one in the control room wanted to move forward . He is not aware of whether any of the other "guys" [operators] talked to !!b}(Z)/C)             I (Exhibit T-22c).
          !!b\(Z)!C)     I stressed that Unit 1 was not at full pressure, but !rb)l7)!Q} I admitted he had no idea how using the excess let-down would affect the pressurizer level. Likewise,
          !lbl(?)(Cl     I was unable to estimate how much inventory (wate2 they expected to get out using excess let-down and no numbers were discussed. !lb){?)/ ) ] P.Xpressed that everyone knew what he was doing, why he was doing it and what he had to do to recover the plant. ifbl(?)(C\          I stated that at the time all these "smart people" were saying it is "ok" to do it and he !(b)(7)(C)          Iwas the only one saying "no" so he talked himself into thinking it was alright because everyone else felt it was alright (Exhibit T-22d).

Based on the evidence develo ed during this investigation, 01 substantiated that both !(b)(7)(C) !!b}U)!C) Iand (b)(7)(C) deliberately provided incomplete and inaccurate information to 01 during interviews on December 18, 2015. This information was material because the information provided was used in the disposition of concerns in the allegation process and directly affected the direction of NRC actions associated with an open 0 1Assist to Staff. Additionally, the NRC would have conducted additional safety reviews and investigations into the November 11, 2015, evolution and additional reviews into TVA's corrective actions, had ilb}U}{C) I and ilb)W!Ql I provided complete and accurate information regarding the events of November 11, 2015.

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAi Ot;, liiMT l~I CHO~t;,lii, OFiFilClii OFi l~IHliiaTl'-sA.+IO~Ha, ~-c10~I 11 6 f'f'le l,-L U9!! 6I4LY        0I INVESTIGATION INFORMATION 166 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - O1 INVESTIGATION INFORMATION Conclusion Based on the evidence developed during this investigation, 01 substantiated that both !(bl(?l(Cl Iand !(b)(?)(Cl I deliberately provided incomplete and inaccurate information to investigators during 01 interviews on December 18, 2015.

                 ,~e,= FeR fi'UBLl6 Dl96L69URE 'l'VITI ISUT >'<fi'fi'RS'"'>'<L eF OPEO IAL AOEPdf IPd 0 1IAROE , OFFIOE OF IPd~'EOT IOATIOPdO, REO IOPd 11 6 ffleliltt USE 614 LY    O1 INVESTIGATION INFORMATION 167 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegations No. 8 and No. 9 Allegation No. 8: Submission of incomplete and inaccurate information by TVA Managers in a Level 2 evaluation associated with Condition Report (CR) 1121520 on January 20, 2016. Allegation No. 9: Submission of incomplete and inaccurate information by TVA Managers to the NRC during the February 2, 2016, meeting with the NRC. Applicable Regulations 10 CFR 50.5: Deliberate Misconduct 10 CFR 50.9: Completeness and Accuracy of Information Documentary Evidence CR 1121520 Level 2 Rev O with attachments 160210984 Final (A8-E1) Email (b)(7)(C) (b)(7J<C) Level 2 interview notes (A8-E2) Email lci(7) to lrb)(7\(Cl I (A8-E3) Email (b)(7)(C) REDINGER (A8-E4) Email REDINGER January statement to !(b)(l\(C) I& l~~,(7) I(A8-E5) Email REDINGER statement to !(bl(?){Cl l (A8-E6) Email lrbl{7l(Cl l to (b)(?)(C) I RHR statement to i~~~n (A8-E7) Email (b)(7)(C) (A8-E8) Email ......,.......,._.l Input to Level 2 (A8-E9) Email ~cii7J o lrblU)rc1 I & l(blt7lrcl I Level 2 are we right (A8-E10)

                                       !to !(b)(7)(C)                              l(SCA) (A8-E11)
                                                                                       ~~r)

Email l(b)(7){C) Email Safety Culture Analysis CR 1121520-1.18.16 to lrbl{?l{Cl l (A8-E12) Email llblffi(Cl I changes X1 to remove OCC (A8-E1 Email ~ci?> response it is fixed (A8-E 14) Email (b)(7)(CJ (b_)(?_)(C_)_ _ _ _ _ _ _ _ _ _ _____,I (A8-E15) to l__ Email l(b\/7l(C\ I sends out schedule update reply to llb\(7)/C) I (A8-E16) Email llblt7lrCl I requesting hourly outage updates (A8-E17)

                 ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                    O1 INVESTIGATION INFORMATION 168 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Email!(b)(7)(C) U(bl(7lfCl Ioutage update reply to !ibl(l)(Cl I (A8-E1 8) Email l(b)(?)(C) IEmail chain between !lb}(Z)fC) I ~nd !.._(b_,..)(7__)(..,_C__) _ _ _ _ _ ___,!(A8-E19) CR 1127691 Rev O Root Cause Analysis with Attachments 20160219 (A8-E20) Email l(b)(?)(C) !Feb 2 TVA meeting summaries (A9-E 1) Emaiil(b)(?)(C) lrbl0(Cl I l=lbout slides for meeting (A9-E2) Feb 02 16 Drop in Notes !(bl(7\!C\ I (A9-E3) Emai!(b)(7)(C) ll(b)(7)(C) Ito ,(b"""" -------------,1 (A9-E4)

                                                                    ....)(7-)(C,....
                                                                                 )

Testimony Interviews of!(b)(?)(C) IShift Manager r ~b.,.llZ.,l~,_ cl.........,I SM at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA .._(b..,.lfr__l(....,ci_____.l US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. Agent's Note: In his initial interview with 01 on December 18, 2015, !(b\!7\(C\ I failed to provide the same level of detail and specifics as he provided in subsequent interviews .

                                              ........__.......____.I was interviewed by 0 1concernin          the events of
                                                                                     *  *

• b7C n many differe~ ear power plants, DOE facilities en ineering firms. b c has been licensed since (bH7) and a Shift Manager since (b)(7)(C) explained the plant had removed normal let-down ram service the night previous to the shift that he took over on the (b)(7l(C) of November 11 , 2015.

A (bl(7l(C) e had heated up to enter Mode 4 which is 200 degrees. (b)(7HCJ e secured both trains o RHR to allow the RCS to continue heating up. The plan for ovember 11 , 20 15, was to heat-up and pressurize RCS and enter Mode 3 at some point during that day or that night. The normal let-down system for CVCS was out of service for repair to a leaking valve and they had placed the alternate let-down system, excess let-down, in service for let-down capabilities. Other than that, all the other plant conditions were normal as to be expected for Mode 5 and Mode 4 (Exhibit T-22a, pp. 4-11 ). !rbl(7)(C\ I discussed that nobody raised any concerns nor did any of the crew have any questions or concerns about trying to do a heat-up on excess let-down. l(bl/7l!Cl I explained that the crew discussed the f act that they had not done it before and were willing to start it and see how it went. lrb\(7l!Cl I stated he thought they had enough excess let-down flow to be able to control pressurizer level on excess let-down. W hen asked about the crew's reaction to planned events of the day bl/7\IC} I stated he did not remember any big push back from the crew. However, !rbl(?)(Cl _ remembered being a little bit anxious continuing the start-up activities with only excess let-down because he had never done it like that before and was not 140T FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1)1(L OF 1'1-ECIAL AOElff 114 Cl IAROE, OFFICE OF II WE1'f l OM1 O 1 1' , REO I OI II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 169 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION 100 percent sure that it was going to go the way that he anticipated it to. !lb\[7)/C\ I reasoned that he did not challenge the* path to move forward because he had no basis for saying it would not work. When asked about influences on his decision concerning schedule pressure or any information coming from outside the control room that might have unduly influenced him in his decision he stated he did not remember any specific undo pressure (Exhibit T-22a, pp. 15-19, pp. 21 -40, pp. 43-56). On January 19, 2016, !lb\17\/Cl I was intervie~l...l,LlL......, VA OIG and provided the following information !lb}m1c1 I explained that on the (bJ(7)(CJ of November 11 , 2015, WBN1 was at Mode 5. WBN1 had just reassembled the reactor and the temperature was less than 200 degrees. OCC directed the MCR to move to Mode 4 which would have kept the site on schedule. The operating crew moved to Mode 4 as planned and as instructed. l1bJU)/(;) further exr:>lained that around 0940 hours, all prerequisites to move to Mode 4 had been handled. !lbl/7\/Cl I instructed the MCR to go to 210 deg rees and maintain that tern erature which placed the plant into Mode 4. According to !(b)(7)(Cl I the OCC told (b)(7)(C) , OPS OCC representative, to inform !lbl!7l(C\ I to go to Mode 3 and take the em~era ure up o 350 degrees. !lb)!7l/Cl Ifurther explained that around 1300, the OCC directed !U7llC} Ito take RHR out of service, and then move to Mode 3. hWZlCQ} I testified that he informed !lblf7)1Cl I that he was uncomfortable moving to Mode 3 and that they needed to stay where the'{ were and wait for the let-down st stem to come back into service in a few hours. !lb}U)(Q} I said he mentioned to !lb\i[Q} I that the OCC was pushin~ too hard. According to !(b)(7)(C) I  !(b)/71/Cl Iwas also uncomfortable with the decision. !(b)r7]c1 I explained that the OCC was pushing too hard and wanted to stay on schedule (Exhibit T-22b). !lbl/7llC} I said that !lbl[l)ICl I raised !(b)/7}/Cl I concerns to the OCC and recalled that !lblf7)(Cl I gathered everrione around a table and told them of !lbl!7l(C} I concern. !(blf7)/C} I stated that !fb}r[ic} Ialso told them that they were pushing the operators too hard and he wanted it to stop. According to !(b)(7/f ~ I the OCC dismissed the concern and instructed !lbl(7}1Cl I to move to Mode 3. bU !C} I said that he would have pushed back harder on November 11, 2015, but he was worried that he would be somehow reprimanded for not getting on board with the decision to move to Mode 3. His actions in the MCR were heavily influenced by his fear of losing his job (Exhibit T-22b ). On July 20, 2016, !lbll7}1C} I was interviewed by TVA OIG and provided the following information. !lbl{l)IC} I 8dvised that there was no discussion on November 11 , 2015, that it might be possible to get 70gpm using the excess let-down. !lblf7)1C} I stated, "I do not think ~ou could ever get 70gpm out of excess let-down." If someone had said 70gpm was possible, b}Q){Q} I stated that the conditions would have to be "absolutely perfect" at full pressure to ever get close to that and even then, it would be a "slim chance." Regardless. !lb}/7llC} I stated in the MCR tha* b)(7)(CJ ! "no one had the number 70gpm on our brain anywhere." !lbl{l)/C} I stated that no one said that night that they knew the heat-up using excess let-down could be done. Rather, everyone said that they did not know how it would react and they (licensed operators) knew they had "stuff' they could do if it went wrong. !rbl/71/Cl I stated that the "biu Wuks" were saying "go" and the operators had actions in their back pocket to use if it failed. _b_7} C} I stated that no one in the MCR wanted to move forward.

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       QI INVESTIGATION INFORMATION 170 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 0I INVESTIGATION INFORMATION ilbl/7)/C\ I is not aware of whether any of the other guys talked to !lb\(7)/C\ I About a month later when the NRC brought up the issue, !ibX7l/C} J was in !rb\(7l/Cl Ioffice with lrb)l7)(Ql Iand llblWIQl I At which time, llb}(?}IQ) I asked lrb}!7)(Q) I if ... l1b... l!7'::!:ll~Q=l=:::!........, should be removed from watch until they found out the answers to the questions. !lbl(7)(Cl said "Yes." !rbl(7\(C} I stated that he was glad he had been in the meeting and heard the conversation because he realized it was not a punitive thing but rather just a conservative measure until the NRC was comfortable. !lbll7l[Cl I also believes it was to position themselves to look better to the NRC. llb)/7l(Cl I said this was normal and he would have done the same thing. !ib}(?)/Ql I went back to his regular work control job and was able to fill in the next time he was asked for help in watch standing. !rbll7l/C} I said he was never remediated. lrb)(?)(C\ I never heard l(bll?)(Cl I or !ibi(7HCl Italk about taking anyone else off watch because "the buck stops with me !{b)(7J(C) I (Exhibit T-22c). On September 6, 2016, llb}Cl)(C\ I was interviewed by AUSA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, TVA OIG and 01 wherein he provided the following information. Although lrb}l7l(Cl I asserted that he was not worried about raisin issues to the OCC, !(b}l7l(C\ I was certainly not comfortable about challen in the (b)(7)(C) and !(b)(7)(C) !about Qlant decisions. !;::~:;:~'.:::-_ e_m_p-,-- as....,,z _e_d,,_t:--;-h-a,- t o_n

                                                                                                                                          ....ce the first engineering test was over, he called itb}(7\/C\                  Ito inquire how much longer before the valve (normal let-down) was in-service. According to !(b)(7)(C)                       I !(bl/7l(C\       Itold him the valve would be ready soon. [!b)(7)/Ql               I said the schedule called for WBN1 to proceed to Mode 3.

lrb}(7\(C} I stated there were no procedures in place about what to do or not to do when heating up using excess let-down, l/b}U}(C\ I said there was nothing in writing saying it cannot be done. !/6)17)1Ql I disclosed that he was uneasy about proceeding partly due to the fact that he had no experience heating up using excess let-down. !(b\!7}(C} ] stressed that WBN1 was not at full pressure, but !lb}{7)/cl I r3dmitted he had no idea how using the excess let-down would affect the pressurizer level. Likewise, !(b}/7\(C} I was unable to estimate how much inventory (water) they expected to get out using excess let-down, no numbers were discussed (Exhibit T-22d). l/bl(l)(C} I stated that he knew there were ways to control the plant if excess let-down did not work and if the plant did what he was "afraid" it would do. i(b}/7)/Cl I explained that the procedures are not written for every step (scenario). llb\(7)(C\ I stated that he knew how to recover the plant if excess let-down did not work and understood that the pressurizer level will go up during heat-up. !(b)(7}/C) I stated that the first step for heat-up was to remove the RHR. Once the RHR was removed, the tem12erature in the RCS would increase. !lb\(7)/C\ I stated that prior to removing the RHR, !(bl/7lrcf I set some trigger values to ensure they took action . At th'

• t, nobody could put their finger on why they should not heat-up. According to if he did not hav*e contingencies then he would have been more concerned.

stated that the licensed operators were not overly experienced and once it was discussed none of them had an opinion one way or the other exce t b c stated that no one else said it was not a good idea which caused (b)(?)(C)

                                                                                     ............---.----~-:--~

to start doubting himself because he seemed to be the only one that was uneasy. In regard to b C !(bl(7)/C\ Itestified that !lb\(7)(C} I basically said something to the effect that..., ~.. H~e....,,,(.. b)("7) (C~)- - , felt l/bll7l(Cl I pain but we have a schedule." l/b\{7)(Cl I confirmed that he set a trigger value

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        0I INVESTIGATION INFORMATION 171 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION of 80 percent pressurizer level where they were to open the PORV to control the rate of heat-up. They then took the RHR out of service and the pressure quickly got to 79 percent which was faster than they anticipated. !lb)(7}/C} I said the rate of heat-up is what "killed" us because it out-ran the excess let-down system which is what !(b)/7}/C} I suspected was going to happen. At this point, REDINGER opened the RHR inlet valves and the pressure level went down (Exhibit T-22d). A ent's Note: Testimon from the other control room operators (REDINGER, (b)(7)(C) b c and l{b)(7}(C) Ion shift during the November 11 , 20*1s, events contradicts b 7 c statement that none of the other operators had an opinion on removing RHR from service. Once the normal let-down got fixed they reconfigured everything and moved on. !/b\{l)(Cl said that they should have just waited until the normal let-down was fixed. About ten minutes after they opened the relief valve and recovered, !rb}(7}(C} I came in the MGR and thanked everyone for not letting the plant get out of control. !rb\{l)(C) I said it was clear that !rb}(7}<C} had been in the OCC watching the event on the monitors and knew what had just happened. ilb\17)/Cl I said the event was not logged and no CRs were written. ilb}l7\/C} I admitted that he did not check the logs and acknowledged that they made mistakes. !lb}/7}/Cl I could not recall who the Unit Supervisor was on the day of the event, but confirmed that later that afternoon, he sent an email to the other Shift Managers telling them, "Do not try to heat-up the plant using excess let-down." The comment on the email about not letting anyone talk you into it was made because it was not his idea to proceed with the heat-up without normal let down in service. !lb}(Z)[C} I does not believe anyone in the OCC would have put the plant at risk on purpose. However, the lack of experience, knowledge, and schedule pressure all ha~pened because they were trying to .see how fast they can get back to making money. !(bl/71/C I expressed that everyone knew what he was doing, why he was doing it and what he had to do to recover the plant. !(b}(7)/C} I stated that at the time all these "smart people" were saying it is "ok" to do it and he !(b)(7)(C) I was the only one saying "no" so he talked himself into thinking it was alright because everyone else felt it was alright (Exhibit T-22d). On April 3, 2017, !lb117\IC} I was interviewed b TVA OIG and rovided the followin iotocmatjon l(bJm(cJ Isaid that he recalled (b)(7J(C) l(b)(7)(C) Ior (b)(7)(C) telling him to do it on November 11 , 2015. i-i.w..=~.Ll,!,!,.~~w1.1d not remember which one it was, but he did recall it was the person in the (b)(?)(C) osition. !(b}/7}/C} I also said that during the same conversation he was informed that 7 and !(b)(?)(C) Iwanted it done or were for it. !/b}l7\/C} I said that he let others in the OCC know that Ile was not in favor of doing it and did not want to do it. !cb)/7\(C} I said that the OCC knew how he felt. !rb1(7)/C) Itold the agents that he could not remember exactly who all he told in the OCC, but he did know it was more than just !lb\(7)/C} I !lb}(Z}[C} I added that he has a family to feed (Exhibit T-22e).

                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          OI INVESTIGATION INFORMATION 172 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews of Dennis REDINGER. Unit Supervisor REDINGER, US at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA !(b)(l)(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. On November 18, 2015, REDINGER was interviewed by 0 1and discussed that he spent six years in the Navy and worked at multiple licensees including 16 years at Comanche Peake where he was an STA and SRO. He came to TVA in 2009 and was licensed in 2011 . REDINGER discussed that the MCR operators did not know what the capabilities of the excess let-down system would be at the temperature and pressure they were operating at on November 11, 2015. REDINGER expressed there was a lack of knowledge among the operators and discussed that the response to their concerns from the OCC was the OCC understood the concern, but they were okay with proceeding forward. REDI NGER stated that he wished he pushed back harder but at the time he felt like they did not have enou h basis to say they were not going to continue. He expressed that at the time he felt that (b)(?)(C) was not totally committed to the idea either, but he tried to convey to us that the OCC wanted us to move forward with it and !(b\/7\!Cl I was willing to try it (Exhibit T-40a, pp. 7-8, pp.17-38). On January 19, 2016, REDINGER was interviewed by TVA OIG and explained that he was the WBN1 Unit Supervisor on November 11 , 2015 and reported to !lb}(7}!Cl I REDINGER stated that since it was scheduled, the OCC decided to use the Excess Let-down System instead of waiting on the normal let-down system. He discussed use of the Excess Let-down System rather than waitin on the normal one with licensed operators 0(b)(7)(C) I (b)(7J(CJ and no one was comfortable with doing it due to concerns regar mg t e a 11ty to maintain inventory control and the pressurizer. While they did not have enough information that day to tell the OCC that it absolutely would not work, no one felt like it was worth the risk. Thei discussed it with !tb\(7)/Cl l who also agreed that he did not think it was a good idea !rb}/7l(C Itold them that he was going to tell the OCC that he was not comfortable with the plan to use the excess let-down system. lrb}l7\!Cl  ! later came back and told the control room that it had been decided to go ahead and move forward so they did. They took out the RHR system and began monitoring the heat-up while trying to maintain temperature and inventory control (Exhibit T-40b). On February 10, 2016, REDINGER was interviewed by TVA OIG. When discussing the Shift Order, REDINGER was asked to comment on each of the answers to the questions contained on the Question and Answer page of the shift order. Regarding the answer given to question number three, REDINGER said that generally that was the information that he provided, but he does not think the he provided the 50-60gpm number. REDINGER said he was not sure where the 50-60gpm number came from and recalls he gave his answers to the questions to . He added that the entire answer (the whole paragraph) was what he told

             , except for the 50-60gpm part. REDINGER said that he did not give that number to
             . He does not know who did or where it came from (Exhibit T-40c).
                  ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJO, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     OI INVESTIGATION INFORMATION 173 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION On March 07, 2016, REDINGER was interviewed by TVA OIG REDINGER stated the shift order was written by !/b)(l)/C) Iand ltnfci the shift order by Shift Manager b (7 C I He (REDINGER) was initially briefed about j which is the first time that he saw the 50-60gpm number and thought something did not look right. He still does not know where the number 50-60gpm came from. At the time, REDINGER thought the shift order was written to g ive the operators OE (operating experience) but now he believes it could have been to get everyone on the same page. REDINGER still has no knowledge of where the 50-60gpm in the shift order came from. He was interviewed by Employee Concerns Program (ECP) line by line about the shift order when he realized the statement looked like the information he had written except for the 50-60gpm number. After the interview with ECP, REDINGER ran into !lbl/7\/Cl I And asked him where the 50- 60gpm came from and !/bl/7l/Cl Idid not re Iy. Discussing the December 15, 2015, email chain between REDINGER and !(bl(7J(Cl 7 REDINGER reviewed the email and confirmed that the actions they took to recover the plant were the operator's actions but how they got there in the first place was not the operators' decision. He stated that they were under schedule pressure to move forward. REDINGER confirmed there was a disconnect in what was said in the email versus what was said in the shift order. Specifically, REDINGER stated that the shift order makes it look like the control room made the decision to move forward where the email shows that that was not the case at all (Exhibit T-40d, pp. 1-10). On September 06, 2016, REDINGER was interviewed by TVA OIG, 01, and AUSA. REDINGER advised that using excess let-down had not been done very often. In the situation on November 11, 2015, neither REDINGER nor the other operators had done it before. He stated the excess let-down flow design says 40gpm. He also had heard during training that they had gotten 70gpm using excess let-down. This information came from older guys who had experience in the plant. However, all of these numbers were at full pressure. According to REDINGER, he and the other operators knew they would not get 70gpm and were pretty sure they would not get 40gpm given the temperature and pressure at which they were operating at that time. They were concerned that what they actually got would not be enough to heat-up. REDINGER stated that they could not say it would not work but he and the other operators had an uneasy feeling. RED INGER and the three reactor operators on crew discussed their concerns as a group. REDINGER then talked with the ~b)(7)(C) !(b)(7)(C) l who also did not feel good about heating u.... p_u_s-in_g_t-he- ex _c_e_s_s_le-t-- d-o_w_n___E_v_e_ry......, one was in agreement so REDINGER and !(b)(7)(C) !met with !lbll7l/Cl I And ex~ressed the crew's concerns. During the discussion with REDINGER and l{b)(7l(C) j, !/bl/?)(Cl I did not challenge them and appeared to be taking information from them. REDINGER does not think !lb\(7)/Cl I said one way or another whether he agreed with them. REDINGER was asked if he or the crew thought at the time they could get 50-60gpm from excess let down. REDINGER said that he did not think they could get 50-60gpm from excess let down. He said that nobody on the crew thought they could get 50-60gpm from excess let down. He stated that while 40gpm design and 70gpm pre-op testing was discussed at some point, the operators all knew not to expect those numbers because it was at 340Ibs of pressure rather than the normal pressure of 2,225Ibs. He stated that 40gpm and 70gpm would have only been at normal pressure and were not numbers for that day. The operators did not know what the actual numbers would be with the plant conditions at that time (Exhibit T-40e).

                  ,~e, FeR 1-UBUe 01 aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY  O1 INVESTIGATION INFORMATION 174 Case No. 2-2016-042

6 FFlel,-L U9!! O14L'11 01 INVESTIGATION INFORMATION Interviews of l(b)(7)(C) I Reactor Operator (b)(?)(C) RO at WBN was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA (b)(7)(C) US Attorney's Office for the Eastern District of Tennessee, wherein he provided the o owing in ormation in substance. !(b)(7)(C) Ihad been licensed fo~ ears at Watts Bar. He was the !(b)(?)(C) !rbl{l)(C)  ! of November 11 , 2015. !(b)(7)(C)  ! stated " ... I thin

                                                                                                      '"'k_t,...

h-e r_e_w_e-re_ _. different theories about whether excess let-down would be enough with RHR let-down out of service. And some people thought it would. We did not think it would, but it did not." When asked to clarify who thought it would work he continued, "OCC. The people directing us to go ahead and start the heat-up for let-down of the line. They believed against us that excess let-down would be sufficient to counter the heat-up and most of our -- not all of the excess let-down is supposed to be" (Exhibit T-01b, p. 8, pp. 13-14). (b)(?)(C) was against moving forward without the let-down system and took his concern to b 7 c Accordin to !(b)(7)(C) I everyone in the MCR with a license was against moving ahead. (b)(7)(C) conveyed the concern to the OCC. OCC said to move ahead. At some point while all this was going on, a comment was made to the effect that "everyone who has a license says no but the people who can fire the licensed people say do it." The license holders are being pushed to do more than they can. If the pushing does not work out, then the license holders get blamed. The OCC's push to get closer to Mode 3 that day did not work out. The excess let-down system could not do the job. The temperature rose and those in the MCR could not get the inventory out. !(b)(7)(C) Itold TVA OIG that he did not tell the 0 1the whole sto during the interview. He did not tell the NRC about TVA management pressure. (b)(7)(C) was told by the TVA lawyer prior to the interview not to expand on his answers.

'-------.-,-,,..-,--.........................,sure from the TVA lawyer not to tell the NRC about the front-end issues. (b)(7)(C)                            did not want TVA to think that he was not a team player. He said that around the same time that he was interviewed by the NRC, TVA issued a shift order which explained what happened on November 11, 2015. l(b)(7)(C)                                  Iread the shift order and found it to be factually incorrect. He said that the shift order really did not describe the facts which took place on November 11, 2015. It is his opinion that TVA generated the shift order, so the NRC could read it (Exhibit T-01a, pp. 1-3).

In an interview follow-up email on January 27, 2016, !(b)(7)(C) !provided clarification on information provided in the shift order. Commentin on the answer to the question "Did the crew expect the condition that occurred." (b)(7)(C) responded, "This is backwards. The crew did expect level to rise because we did not expect 50-60gpm from excess let-down at that pressure. That was a main argument we used against the plan." When commenting on the listed actions taken, specifically, "Oversight watches have been established in the MCR." !(b)(?)(C) I commented "The people who pushed us into it [November 11 , 2015 event] were in the MCR around the clock for about a month [afterwards] to make sure we did not decide to go and do anything that foolish again" (Exhibit T-01 a, pp. 14-15). tW f FOR PUBLIC DIOCLOOURE Wlfl IOUf il!PPR01~*,1tt OF SPECIAL AGDH l~J GI hO.RGE, OFFIOE OF ltWEOTIOMIOP40, REOIOPJ II e rne1itct U9!! O14L t 01 INVESTIGATION INFORMATION 175 Case No. 2-2016-042

6FFle l,-L U9E 614LY OI INVESTIGATION INFORMATION l(b)(?)(C) !did not think the crew could get enough water out because excess let-down is designed for 20gpm but could not proµ;,..~L.11,LU.1.i..~lt the OCC had been looking at it closely and crunchin the numbers based on (b)(?)(C) tatements concerning capabilities of excess let-down . (b)(7)(C) stated that e an t e crew knew they would not get 50gpm out of it. However, since (b)(7)(C) could not research it at the moment, he felt the people outside the control room were helping the crew research it. Where it [shift order] said the crew thought they should be able to get 50 to 60gpm on excess let-down but, the OP.erators were ar uing against it because they did not think it was ossible. No one talked to (b)(7)(C) for information on the shift order. However, (b)(?)(C) does not recall anyone in the control room talking about how they could get 50 to 60gpm out of it if they were not at full pressure. They all felt like excess let-down would not work but they did not know the severity or how fast it would all happen (Exhibit T-01c). Interviews ofl(b)(7)(C) I Reactor Operator !(b)(7)(C) I RO at WBN was interviewed on January 27, 2016, and September 19, 2016, by 01, TVA OIG, and AUSA !(b)(7l(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. lfb)/7\fC) I was licensed in b 7 C and worked on in the MCR on November 11 , 2015. i/b)CZl(Cl I explained that he was b 7 c and did not have a lot of experience. l1bl(7l/Cl I !stated that the excess let-down was in place when the RHR was taken out and he was under the impression that it would take water out to keep the plant from going solid. l(b)(l)(C) I does not know why the decision was made not to wait for the original let-down system but stated the operators did not wait because "we were being pushed by the OCC (Outage Control Center)." (b)(7)(C) stated that this was his first time dealing with an OCC as an Operator. His un ers an ing of the OCC was that they were the people who understood what was happening and it was theirj ob to come up with a plan. He now believes they are there to push and get the work done .. ilb mrci I stated that he should have never taken the RHR out with that situation, but it was his first outage and the shift manager that day had a lot of experience and he said to do it (Exhibit T-23a)(Exhibit T-23b). Interviews ofl(b)(?)(C) IReactor Operator

!(b)(7}(Cl  I RO at WBN was interviewed on January 28, 2016, and September 29, 2016, by 01, TVA OIG, and AUSA !(b)(7)(C)             I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

(b)

!(bl/7\(C) I had been a Reactor Operator fo ' l ears at Watts Bar and worked on 7

November 11, 2015, in the MCR. was serving as a RO that day on the!(b)(7)(C) J l (b)(?)(C) l REDINGER was the Unit Supervisor and Todd (b)(7)(C) !was the !(b)(?)(C) I  !/bl(7l(C) Idiscussed the events that happened on November 11 , 2015, were only one example where the MCR operators expressed concerns but were told to proceed regardless. On November 11, 2015, there was pressure being felt in the MCR from the OCC to move from Mode 5 to Mode 4. l(b\(7)/C) I stated that

            -'l9 ~CIAL AO ~l<IT 11<1 CHAl":0~ , OP'P'IC~ OP' ll<I V~~TIOATIOl<I~. l":~C'.!1 10 1<1 11 6f'f'lel,-L U9!! 614LY       Of INVESTIGATION INFORMATION 176 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilbl/7}/C\ I appeared to be under pressure to move the unit. Since the normal let-down system was out of service, the plant had to rely on the excess let-down system. Licensed Operators voiced their concerns with the plan to move ahead using the excess let-down system.

!lbl(7)/Cl I was not for the idea. !lb\/7\(Ql          I communicated the concerns the MCR ersonnel had with the plan, but the OCC decided on a plan to proceed with the heat-u !lb\(7 _C\ I stated, "I felt like it was a very bad idea to proceed on." The agents asked ilb)/7)/Q)                 1 1 why he did not voice his concern stronger and louder. He said that he was afraid of being relieved. He said he was afraid of not being viewed as a team player. !lb\{7)/C\ I explained to the agents that neither he nor his colleagues in the MCR that day could point to a rule or a procedure to support their position not to proceed using the excess let-down system. They all just knew it was a bad idea based off their training and experience. !lb\/7l/Cl I said that all the OCC had to do was wait a few hours and the normal let-down system would be available. According to !(b)(l)(C)                       I the work had already been done and the)'. were j ust waiting on the paperwork and clearances to put the normal let-down back in service. !lbl(7}/Cl I su~gested that the OCC would not wait and wanted to stay on schedule no matter what. !lb}(Z)/C                I recalled saying out loud "this is stupid" when !ib}/7l/Cl 7 told them that the OCC said to proceed (Exhibit T-16a).

Interviews of jtb)(7)(C) ~ Senior Reactor Operator I

!(b)(7)(C) SRO at WBN was interviewed on January 16, 2016, and September 19, 2016, by 0 1, TVA OIG, and AUSA !(b)(7)(Cl                 I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

(b)(7) ilb\(7)/C) I had been a SRO for ici ears at Watts Bar, and on November 11 , 2015, he was working as the (b)(7)(C) and in the control room fod (bl/7l(C) !(b)(7)(C) Jocus on the plant as it was coming out of the maintenance outa~e. At one point, REDINGER had to leave so !lb}(7)/Cl I relieved him for a couple of hours. llmrc) I said that he talked to everyone on the Unit 1 side in the main control room that day about heating up without normal let down being available. None of them thout t it was a good idea. REDINGER was part of that conversation. !lb\(7)/C) Icould not recall if !rb ll)(C} I was a part of that specific conversation but he does know that !lbl(Z)IC} I recognized that the operators were uncomfortable about heating up. According to I

!(b)(7)(C) in this instance standing down waiting for normal let-down would have been textbook but would not have gotten them out of the outage fast enoufih. !lbl(7)/Ql I said that when he saw the "50g~m" answer given in the statement put together by _b)(?)(Cl                    I !(b)(7)(C)   I and
!(b)(l)(C)    he could not figure out where that number came from. When he read the number "50" on the document he told his peers that the number "50" was just silly. He added to the interviewers that he did not tell anyone on November 11 , 2015, that he thought they could get that out of excess let down. The number was totally unrealistic. Speaking of the plant manager, i/bll7)/Cl I said on November 11 , 2015, after the control room personnel stabilized the plant ilbl(?)/Cl      I r.ame into the control room and congratulated eve~ one. ilbl/7l/Ql I recalled
!lbl/7}/Cl      I saying, "We put you guys in a bad place today." !ib] l!C\ Igave !lb\/7}(C\ Ia bear hug (Exhibit T-05a)(ExhibitT-05b).

140T FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1)1(L OF

              !,1-ECIAL AOElff 114 Cl IAROE, OFFICE OF               II WE!:lTI OMI O r  !:l , REOION II 6 f'f'le l,-L U9!! 614LY       QI INVESTIGATION INFORMATION 177 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews l(b)(7J(C)  ! Reactor Operator l__(...iIT....it....i....____.lI (bbJCT)(cCJ RO at WBN was interviewed on multiple occasions by 01, TVA OIG, and AUSA US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. (b)(7) l/b}(?}/C} I has worked as a RO, at WBN since (Cl On November 11, 2015, llbl/7}/C} Iwas working on WBN2 and had walked over to the WBN1 side of the MCR to offer assistance as WBN1 was working through a maintenance (forced) outage. According to !(bl(!)(Cl I when he arrived at the WBN1 side of the MCR, the RO (NFI) was in the process of usin the RHR let-down as the method of controlling the RCS level. That condition, lead b 7 c to begin asking questions of the RO and proceed to walk the board in an effort to understand the situation. !(b}/7}/Cl I said that he soon realized the RHR temperatures were higher than normal which caused him concern. At that point, l/b}/71/Cl Iraised his concerns to the SRO's. l/b)/7}/C} observed there were alarms and temperatures that were abnormal as he discussed his observations and expressed his concerns on what he thought needed to be done. According to

!(b)(?l(C)                I     the RO's had agreed with !/b}m1c1         I observation and indicated to !ib}(?}/C} Ithat they had voiced similar concerns but were overruled by "those above them." !lbl(7)/C} I explained that the RO's discussed how could they get out of the situation and utilize RCS cooling (Exhibit T-02a, pp. 4-12).

l/bl/7\[C} I stated that as he walked into the MCR, they were starting to align RHR let-down and the suction valves from RCS were alread opened which lead him to ask questions. lrb}/7)/Q) I recalled that b 7 C on duty and the US, REDINGER, was running the procedures. b 7 c testified that he clearly voiced his concerns related to the reason the suction valves from RCS were opened and the high-pressure alarm. Accordin to b 7 c he told SM l/bl[7)/Cl I "I (b)(7)(C) said this is not the right thing to do he (b)(7)(C) would not really answer me." b 7 c acknowledged that he was full of suggestions to .._b........_C.____. which were more than !/b)(7}/C) I cared to hear. Eventually, lfbl/7lfC} I directed the heat-up to stop as the temperature approached 235F (Exhibit T-02a, pp. 11-19). Additionally_ ilb\U)/C} I stated the let-down system was in service with RHR umps on RCS cooling Mode while normal let down was tagged for maintenance. l/blr7}/C} 1testified that he was not part of the decision-making process to secure normal let-down on WBN1 and was not present inside the OCC during the period in question. Likewise, !lbJU)IC) I stated that he was not assigned to WBN1 on November 11 , 2015, but on his. own accord decided to walk over from WBN2 to offer his assistance with the evolution. l/b}(7)/C) I described the MCR as "hectic." In particular, the operators were uncomfortable relative to the RHR temperatures and the rise in the pressurizer. When asked if there was "command and control" from the shift managIer and the SRO's regarding the activities, llb}/7}/Cl I said there were some disagreements as to should we be doing this that the SROs expressed. !lb)/7)(Q) I stated that it was not a proactive environment but rather a reactive one as operators were simply trying to get a handle on what was going on with the plant. When asked how did the let-down system impact (challenge) the operators, l/b}(7)/Cl I responded, "The biggest challenge was not being able to control the pressurizer level on the heat-up." Specifically, the pressurizer level rose from 40 percent to

                                      ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 178 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION nearly 80 percent before any action was taken. !rb}/7}/C} I suggested that the excess let-down is limited relative to its design and only suitable in certain plant conditions. Also, the secondary side had nothing to offer to cool the plant down and when the heat-up was sto%ped all the steam generator atmospheric dumps were opened and the steam was dumped. !lb\(7 Cl I stressed the pressurizer level was in a dangerous place without the ability of normal let-down. !lb}/7}/C} I said, "Had they stayed within the bounds of the GO procedure they would not have had any concerns with the (heat-up)" (Exhibit T-02b, pp. 9-1 5, pp. 17-23). l!b}/7}/C\ I stated that at the end of the shift, !(~ (7)(C) I verbally thanked l1b1mcc1 Ifor getting "loud." Although l(b}(Z)(C) I never articulate that he was confused or did not understand the procedure, lfb}mrcl I questioned !(bl/7\(Cl I about the capacity of the excess let-down system and emphasized he should've waited for the normal let-down to return to service. Accordinf to

!(b)(7)(C)   I!rb}/7}(C}                         !

I told !(b)(7)(C) "That he was doing what he was told to do." lfbl/71/C} said that under the current management at WBN the main concern was reaching the next milestone. lrbl(Z)(C} I sug ested that bonuses and promotions are all tied to milestones which causes some 1 risk. !lb)(Z)(C} _ added that the OCC placed WBN at risk on November 11, 2015, as MCR did what the OCC wanted. It was the MCR that recovered and stabilized the plant. When asked what could have happened. llb}/7}/Cl I stated they could have released radioactive water outside of the reactor coolant piping (the reactor coolant system boundary). Furthermore. !rbl(7}(C} I implied a component could've failed given the higher water temperatures and pressures. Additionally, there were potential environmental damage as the plant would have been less safe because one less barrier was available. He stated that this is probably the second worst thing that could happen next to releasing the radioactive materials into the environment (Exhibit T-02b, pp. 25-28) (Exhibit T-02c). Interview of !(b)(7)(C)  !, Senior Reactor Operator !(b)(7)(C) l SRO at WBN was interviewed on January 27, 2016, by TVA OIG wherein he provided the following information in substance. On November 11, 2015, b 7 c was workin in the WBN 1 as a (b)(7)(C) (b)(7)(C) did not realize there was a problem with the unit that day until they were fully involved in t~e problem l(b)(7)(C) l stated that he became aware of the issue during the recovery phase. ~b)(7)(C) I said in the past Management did not challenge the more conservative path if in fact that path was deemed by the MCR to be the best path to take. Nowadays, management questions the Shift Managers when the Shift Managers state that they are going to take the conservative path. In the past, WBN's default position was the conservative position because that is the safest position. !(b)(7)(C) Icredits the change to lrbl(7)(Cl I and !lbl(7lfC} I (Exhibit T-41 ).

                         ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 179 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews of !(b)(7)(C) (b)(7)(C) ,-- at WBN, was interviewed on multiple occasions by 0 1, TVA OIG, and AUSA ..__......._____. US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

!/blll)/Cl     I was interviewed by TVA OIG on February 2, 2016, and discussed that on November 11, 2015, he was working. !ib)f7lfC)                I stated that he remembers that day fairly well because the normal let down system was not in service. He was in the OCC working with the OCC team but cannot recall who else was present with him and remembers they were trying to determine what the plan was moving forward. lrb1m1c1                   I does remembers having several conversations with !(b)(7)(C)                         1stated there were basically three options: (1) stay in Mode 5 and wait until the normal let-down was back in service or (2) heat-up to Mode 4 and stay on RHR or (3) do option 2 and then take RHR out of service and the cooling mechanism would be the main steam dumps. T he decision was made to go with o tion number three.
!/b}f7)/C\     I stated that he attended all of the OCC meetings that (b)(7)(C) where they discussed the options. He does not remember any real push back on moving orward. !/b\(7)/C\                     I::idvised that it is important to stay on schedule because the unit is important to the fleet. He stated that there is a balance between schedule and safety and any delay on getting the unit back online meant TVA must purchase power. He stated this is no different than all other utilities.
!/b}f7)/C\      Istated that they were originally supposed to move to Mode 4 around 6 a.m . or 7a.m.,

but the OCC wanted to analyze it some more. According to !(b)(7)(C) I we all had concerns because of not having the let-down available. !!b}U)[Q} Istated that they had to convince Ifblnfcl I in occ because all delays or changes in schedule had to be approved by b7 c !ib}fl}(Cl Istated that they were already delayed so the OCC team came up with a plan for !(b\/7}/Cl I approval that decided what to do after the delay (Exhibit T-21 a).

!ib}Ul(C}      Iwas interviewed by TVA OIG on February 10, 2016, and did not recall anyone in particular being concerned with moving forward with heating up the ~lant on November 11, 2015. While he did not specifically recall either !/blll)fC               I or REDINGER telling him they were uncomfortable or that they did not want to take the RHR out of service, he did admit there was some pushback with o fre rators asking questions about the effect of doing this without normal let-down. In addition. !lb (7)/Cl            Isaid "he did have some healthy challenges with !/b)(?)fC)       I in the control room" about this issue. However, !/b)/7)/C} Istated "I did not get off [sic from] these conversations that they were uncomfortable with this." He further clarified that they did not tell him at any time of the day that they dlid not want to do it. !/bl/7}/C)         Iwas asked about ushing (ressure) which he stated that pushing is common and "I have had much 1

worse." In !rb\l )/Cl _ opinion, operations are not doing well because there are some fundamental areas with operators' performance and they have failed to correct the low-level behaviors. Some examples of these include communications, responses, and board monitoring. ilb\(7}/C\ Ibelieves the only recent event that could even remotely be associated with pushing would be the R HR event because the whole OCC team was pushing to move forward. Other issues like the source range instrument bypass and the PORV lift are only due to operator error and level of knowledge issues. According to !(bl(7)(C) I Operations knows the knowledge level is lower than it should be, and that management needs to be in an oversight

                           ,~o, fiOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1RO1~1>'<L Ofi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IP WE!:ffl OMI O r  !3 , REOION II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 180 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION role to make sure the people who do the actions understand what they need to do. While these oversight managers may not have an active license or be a license holder, they have the required knowled~e from past experience to make decisions and assist in what happens in Operations. l/b)(7}]l Ibelieves it is inappropriate for someone to say that !(b\(7)/C} I should not be involved in the control room decisions since he is the Plant Manager and is very knowledgeable (Exhibit T-21 b). !(bl/7l(Cl Iwas interviewed by TVA OIG on June 30, 2016 and recalled having a conversation with !!blU)(Ql I in the control room and that !lblffi/Ql I challenged him but was "okay with moving forward after our conversation." This conversation ha~ ened at the horseshoe by the unit supervisor's desk while there were other &ieo 1e around. Jil(Cl Ialso believes the unit supervisor (REDINGER) was there as well 11 mu2 I!';tated that their concern was about the effect moving forward and heating up would have on the plant with the normal let-down out of service. He stated that at no time did either !(b)(7)(C) I or REDINGER say they did not want to do it nor did anyone seem adamant about anything. If they had, !(b\(7)/C) I would have sto,ri%ed and tried to understand why. He does not recall any other conversations with !(bl(] l I and knew there were challen r s from the crew about what did the effect of the temperature rise on pressure level. l/bl(7) l 2 I testified he did not feel anyone was uncomfortable but rather more concerned about whether they were technically doing the right thing. !/bl/7}(Cl I had been talking to !(bl(?)(C) I on a regular basis that day about what was hap~ening . In addition, llbll?HQl I would have been in the OCC frequently that day. !(bl(7) Cl Istated that !lb)/7}(Cl Iwas for movinff forward that day, but the decision was made by !(b)(?)(C} I !/b)/7\/C} I stated that he and !/bU(Ql Iwere good with moving forward that day because they thought they could do it safely. He stated that everyone was good with moving forward in the beginning but now say how bad the decision was. There have been "a lot of Monday morning f uarterb*acks" about this issue. !/b}(l)(C} Idoes feel like there was a lot of miscommunication. Jb\(7)/C} Isuggested that the decision was made by llbl(l)(C} I who was the shift manager (Exhibit T-21c). !(bl(l}(C} Iwas interviewed by TVA OIG, 0 1and an AUSA on January 19, 2017, and said that during outages ilb)(7)(C) Iwanted to know minute by minute what was Ji-0ing on. In the OCC, l!blr7)( _ l ,mrl !lbl(7}/Ql I were part of the Senior Leadershi Team. !lblr7 Cl I stated that information to !(b)(l)(Cl I would r o through him (b)(7)(C) while decisions went from !(b)(7}(C} I to !rbl(7)(Q) I !(b1(7}(C Iwould then go to the Shift Manager with the decision. llb\(7)/Cl I said that there was discussion in the OCC to remove RHR and allow the heat-up to begin. !(b)/7\(Cl I said that they had man~ discussions about that in the OCC and in the main control room with the Shift Manager. !(b\(7 C) Iquestioned !/b)(7l(Ql Iabout what was going to happen to the pressurizer level if they took the action. lth1!7l1Ql Ihad multiple conversations with a few people about that and these conversations took place over the course of a few hours. !(b10(Cl !said that the Shift Manger's crew also asked that same question. ilbl0(C} I recalled interacting with the Shift Manager and the Unit Supervisor that daf llb}W/Ql I r.ould not recall who else he spoke with in the control room about heating up. !(b) 7}(C) I estimated 30 percent that day was spent in the main control room and 70 percent of his time was in the OCC (Exhibit T-21d).

                         ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 181 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION ilb)/7)/C\ Isaid that they had a lot of conversations in the OCC that day about removing RHR and whether there were any tech specs or restrictions. !lbl(7)(Cl I said that in the end they could not find any restrictions against doing it, !lb1(7)1Ql I said that engineering was consulted too. !lb\(7}/C\ Isaid engineering told !lb\(7)[C\ Iand the others that excess let down could handle it. i<b}(7\fC\ Iwas asked who from engineering gave him that bit of information. ilblUl/Ql Isaid he could not remember who it was that told him that. When asked if there was a gallon per minute (gpm) figure that engineering said could handle it, ifblf7\(Cl I replied that 20gpm is what he recalled from the system description. i{b)(l)(C\ I::idded that no restrictions were located so they decided to do it. !!b\(7)/Cl I said that there was discussion in the OCC to remove RHR and allow the heat-up to begin. !iblf?lfCl I said that they had many discussions about that in the OCC and in the MCR with ifbl(7)fC\ I !fbl(7\/C\ I said he did remember talking with !ih}(Zl/Ql I in the main control room and the OCC about removing RHR. ,,b ....-)[7-l[-Ql-..... did speak with !/b)(7)/Cl I too about the issue, but !lbJ/7}(Cl I could not recall exactly what each other said. !/b\(7)/C\ I said that !lb)f7)(C\ Ianci ifbl[7)/Cl I both were involved in the decision and both knew exactly what was going on . ifb}(D(Cl I stated that both ifbl(7)fCl and !rbl(7)(Cl I were in favor of removing the RHR. !lbl(7)/C} Isaid that he spoke t'""o"l:lr~bl::::17:::}rc=,==--. about it and his crew, but the idea was not !fb\(7){C\ I idea. ifb\(7)(C\ Iwas asked b}' the interviewers if i/b)(l)/Ql I told ilbJl7\/C\ Ito instruct !lb\17\/Ql I to take the action. ilhHrnci said that !/b}(7}(Cl I did not tell !lb\(7}/Cl Ito tell !ibl/7}/Cl I to do it. !(b\//}(C} Isaid it came about after the conversations in the OCC after which the OCC came to the conclusion do it and ilh)Ul/Ql Icommunicated that to ilh)U\!Gl I l1brn1c1 Istated that he !(b)(7)(C) I went to the control room and told !ibl/7l[C\ I that "this is the path that we would like to go down because we feel it is appropriate". The interviewers asked !lb}{7)/Cl Ito define "we". ilbll7\IC\ Isaid, "we" were the OCC. ilbll7\IC\ I was asked by the interviewers if using excess let down was the safest plan . !lb)l7)/Cl Isaid using excess let down was not the safest plan and it would have been safer

• r normal let down to come back in service. ilbl(7}/Cl I said that they concluded that (b)(?)(C) that they could get 20gpm out of excess let down (Exhibit T-21d).

Interview of !(b)(?)(C) l(b)(7)(C) I at WBN was interviewed on multiple occasions by 0 1and TVA OIG wherein he provided the following information in substance. He described that at 06:00 a .m., on November 11, 2015, it was identified that the repa'ir of the normal let-down valve had not yet been completed. !/b){l)/Cl I briefed the OCC that this would significantly hinder the heat-up rate and they would not be performing a normal heat-up per the schedule. He stated it would take did not have the let-down capacity. b 7 om~(~(~fT a much longer time to slowly heat-up because we figured that they could heat-up the plant at a rate of 75 deflrees per hour using the normal let-down system, but the excess let-down system was limited. bl/?}(Cl I figured that by using the excess let-, owo system they cmJ!d heat-up the olaot o at a rate of 1 degrees per ~our. !lb\(7)/Cl I stated that (b){7)(C) I l(b)(?)(C) at WBN and he made the decision to keep going with the schedule and start heating up with what we had in place and not wait for the next one [normal let-down] knowing there would be a schedule delay to critical path (Exhibit T-18, pp. 8-12, p. 15)(T-31).

                     ,~o, fiOR 1-UBUe 01aetoaURE W ITI IOUT )l(flf1RO1~1>'<L Ofi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IP NE!:ffl OMI O r  !3 , REOION II 6 f'f'le l,-L U9!! 614LY            01 INVESTIGATION INFORMATION 182 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview of l(b)(7)(C)

 !/blll)/Cl      I stated the decision to forge ahead that (b)(?)(C) using the excess let-down system was a team decision. !ib}(7)/Cl               Ithinks that if he I no ink the plan of using the excess let-down system would work then they would not have tried it. He stated that going to the excess let-down system is not a normal thing and not the preferred method. According to lfbl~lfcl         I there was a good amount of discussion about whether or not it could be done.

b Q j continued by explaining that sometimes decisions are made outside of the OCC. He stated that it could have been either the l/b}(7}/C} I or l/b)(7l1Cl I because the OCC sometimes relies on them. !(b}W(Cl I said that he did not make the decision and he does not believe that l/bl/7l1Cl Ior !/b)/7}/Cl I would have made the decision either (Exhibit T-19 ). Interviews of l(b)(7)(C) IShift Manager j(b)(7)(Cl j SM and SRO at WBN, was interviewed on multiple occasions by 01, TVA OIG, and AUSA j(b)(?)(C) j US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. (b)(?)(C) as licensed in l(~i7l land has been a Shift Manager since a wor on November 10, 2015, for the (b)(7)(C) l~~f: I When !(b)(?)(C) !arrived there were two maJor things that were on the schedule for the!(b)(7)(C) ~o get done: or o do on the Let-Down System so the night crew needed to take the Let-Down flow path out of service: 2) Heat-up the plant (move from Mode 5 to Mode 4). {b)(?)(C) ecided to do only the first thing . He told the agents that in his mind the let-down s stem was ou of service, so he did not want to heat-up the plant without it being in service. (b)(?)(C) explained that the concern in heating up had to do with water management. He explaine t at water expanded a lot when it heats up, so you must either drain water or not heat-up. (b)(?)(C) did not think it was a good idea to heat-up with the let-down system out of I service an reca led !ibl/7}/Cl I suggested they could just wait.j(b)(?~C) could not recall who he talked to in the OCC about his decision not to heat-up the plant, ut he did talk to someone. He recalled talking to the OCC about the let-down system being out of service. They had a good discussion about it and that was it. !(b)(?)(C) !recalled telling the OCC that he wanted to stay in Mode 5 because they only had excess let-down. According to !(b)(7)(C) j with low pressure and low temperature the expectation was to only get around 15 to 30gpm using the excess let-down. Specifically, he remembers discussing this with the OCC that night and telling them that the reason they had to stay in Mode 5 was because of the inability of excess let-down to do more than 15 to 30gpm (Exhibit T-46a)(Exhibit T-46b). Interviews ofl(b)(?)(C) I OCC Operations Representative

 !(b)(7)(C)      I Shift Manager, !(b)(?)(C)                                I and OCC Operations Representative at WBN, was interviewed on December 18, 2015, January 19, 2016,
                         ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 183 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION February 4, 2016, and October 3, 2017, by 01, TVA OIG and AUSA !(b)(7l(C)  ! US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. was interviewed b 01 on December 18 2015. b 'oined TVA in (b)(?)(C) ~~~- perat~10-ns =-----:-' Representative :'T"""'"'.whereby On November 11, 2015, b worked as the (b)(7)(C) he coordinated with several entities associa e wI the operation department to ensure there was the proper support for the outage. !rbl{7)/Cl I said that he clearly remembers that on November 11, 2015, the maintenance work was not finished when it was decided to transition into Mode 4. ilb)(7}/Ql Itestified that he remembered looking into whether the transition without let-down would affect the procedure. !rbl(7lfC) I stated that he asked himself and others (NFI) in the MCR, "Is it some type of violation, is it something we are forbidden from doing and there had been quite a bit of talk in operations about that very fact." !rbl(7l(Cl Iadmitted that he cannot remember if he talked face-to-face with !(b)(7)(C) I or whether it was by email about moving forward. Also, !fblr7l(Cl I admitted that he spoke quite a bit with !(b)(7)(C) I Shift Manager of WBN1 about not only heating up without normal let down, but the other things that were going on that day (Exhibit T-17a, pp. 2-9, pp. 11-17). When asked if !(blr7l(Cl I had conversations with !(bl(7l(Ql I throughout the day, !rb)/7)(Cl responded, "Yes, I would say, on average, probably -- and this is not just that day, it would be any day you could call the shift manager anywhere from ten to 30 times, depending on what was going on." !rb)(?l/Cl I stated that he had no prior experience in a start up without normal let-down being available. In fact, reflecting over his career he could not recall anytime where he remembers taking an action with only excess let-down. !rb)f7l(Cl I suggested that !(blr7l(C) I was also inexperienced with this condition, so they had some conversations about whether this was "okay" and !ibl(?)/Cl I indicated that he shared with him what he had found. !/bl(7)(Cl I testified that they discussed their understanding of the system and the opinions from operators that had joined their conversation. !(b)(7)/C} I ::idmitted that, "We did make what I think we will all agree in hindsight, was a poor decision that should be determined that it was not illegal." !rblr7lfCl I stressed that they made a decision that they believed might have to move really slow, but that it would be controllable. !(b)/7HCl Iargued that they believed that they could safely transition into Mode four for excess let-down. k6lm,c) I stated that his clearest memory of the day was making sure the rest of the OCC (perha s not the entire OCC but the critical members of the staff, the two managers and then (b)(?)(C) were explained the plan of how to proceed forward (Exhibit T-17a, pp. 19-24). !(blmtCl I testified that he told !(b)(7)(C) I that he wanted lrb1mrc1 I to understand that this was not a normal heat-up activity that they were would go in slow and cautious. !(b)(7)(C) acknowledged that a lot of people had access to the plant data and they knew th'"'" e-i"h""" ea....,t;-u

                                                                                                                      -- p_ __,

limits, and he wanted to make sure that this was not going to be a standard evolution. Additionally, !(blr7l/Cl I reportedly told the OCC and !(bl(7]Cl I that it is not going to be the normal heat-up they were accustomed too, and they may have to stall out at some point and

                      ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 184 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION just sit. According to !(b)(7)(C) I no one appeared to have any problem with the plan and there were not any additional challenges regarding the decision to proceed forward. Ultimately, !!bl/7\/C) I stated that they ended up transitioning into Mode 4 and at a certain point noticed the pressure riser level was coming up but the MCR got it stabilized. !(b}(7l/C} Itestified that his initial assumption at that time of recovery was that the MCR just turned off the RHR, so it probably took them a while to ~et a little bit of heat to be able to control the level. !rbl/7l{Cl I recalled a conversation with !lb m<Cl I whereby !(bl(7l<Cl Itold&b)(7)(C)  ! "Hey, it looks like you all are managing this okay," and !(b)(7}<C} !responded to !(b) )(C) I "Here is what friggin' happened" which lead to a discussion detailing how the MCR actions had to put RHR let-down in service. !lbl/7)/C} I stated that he shared information with key OCC people but cannot remember if he did that in the update format or once again during an informal discussion around the table. Regardless, i!b\(7)/C) Ir.icknowledged that he spread the information with a wide audience as to what had happened. !lb}(7}(C} I suggests that before the end of shift the normal let-down system was back in service or were just about to come back in service (Exhibit T-17a, pp. 25-32, pp. 34-45). !(bl{?)(C} I was interviewed by TVA OIG on January 19, 2016. On November 11, 2015, l!b)ll){C\ I role was to serve as the liaison between the MCR and the OCC. The issue that they all faced that day was whether it was acce7ctable to enter into Mode 4 without the availability of the normal let-down s stem. ![bl[7l Cl I said that both he and !lb1[71/C} I were not comfortable with doing it. ltb)(l)t J 6 I said that doing what the OCC wanted done that day resulted in WBN1 moving into unfamiliar territory. What ended up happening was that the excess let-down system did not have the ca~acity to do the job. When asked who made up the OCC core team on November 11, 2015. ilb)/7 irn I said that ilbl(Z)IC) I and !rb)(?){C) I were there. !/b}/7}(Cl I said he could be mistaken but he thought !/b)/7}/Cl I was seated in the engineer's chair at the OCC that day. !/bl(7)/Cl I ::ilso thought thatl{b)(?j'C) !was in the OCC. !(bl{7)/Cl I added that they made a poor decision that day. jbJ(7)/C} Isaid that he and !/bl{7)/Cl I had telephone conversations that day about the decision. !(bl/7)/Cl I was fully aware that !lbl/7\[Cl I was not for the decision. According to !(b)(7)(C) I the decision placed the operators in a position where they had to take actions in an area where there were no established procedures. !(bl/71/Cl I said that he sat the OCC staff down in the OCC and told them that "we are uncomfortable." ilb}ll)[Cl I told the OCC staff that "we need to proceed with caution." He also said he told them that they do not need to put any undue pressure on the operators. !(bl/7)/Cl I could not recall who was sitting there in the OCC when he made these statements. ilb}(7)/Ql I was asked wh~ the OCC did not wait a few more hours for the normal let-down system to return to service. !lb ill/Cl Isaid that waiting a few hours would have jeopardized meeting the next milestone. !/bl(?)/Cl I said the bottom line that day was that the OCC made a decision based on a business need. In this particular case, according to !(b)(7)(Cl I "we" got out of balance. That balance being between running a business (money) and safety (Exhibit T-17b). !/b}(7}(Cl I was asked what happened when the site realized that their plan was not working, !lb){7l(Cl I said that he updated the OCC, and then !(blCZl[Cl I was forced to do something to counter the mistake. There was no procedure in place for the actions !(b}{7l(C} Itook. !lbl(?)(C} Idid not think that there was log kept that day in the OCC or the MCR. He added that

                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 185 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION "we just whiffed on this one". l!bl/7}(Cl I said that they just forgot to make the log entries. He said it was not a cover up, a month or so after the incident, the NRC came onsite and interviewed numerous people concerning the incident. llb)(?}IC) I advised that the NRC focused a lot of their questions on finding out if the operators acted correctly. There were also a lot of questions about the logs (Exhibit T-17b). The agents asked l!bl(7lfCl I what is going on at WBN that has resulted in the OIG and the NRC showing up, libl(7l/C) I responded that the current desire of WBN management to meet the milestone and to "go, go, ~o, ~o." The OCC cared more about reaching the next milestone than they did about safety. lib 7HC I said that the reactor operators are getting pushed "too hard" by the management team. lfbl(7)(Cl I does not think that his colleagues feel comfortable expressing an opinion different than that of management. !lb}U}(Q\ I concluded the interview by saying that it bothers him a lot that the current WBN management team could not wait a few hours for the let-down system to come back into service (Exhibit T-1?b). l!blf7l(Cl I was interviewed by TVA OIG on February 4, 2016. lfbl(7lfCl I advised that he had learned a lot more since his original interview and is current!~ on the Root Cause team looking into the November 11 , 2015 incident. The additional things U/7\IC} I has learned is the result of him talking to others at the site. On the!(b)(?)(C) lot November 11 , 2015, !(bl'7l(Cl I did go into the OCC and meet with the OCC staff. He stated that !(b)(7)(C) !was at the table as was !lb}U}{C} I who was sitting where the engineering person usuall sat. He added that he is *ust about sun~ lrb)(7)/Cl I was there. He was mistaken that b 7 c was the (b)(7)(C) , as it was lrbl(7)[C) I At this meeting in the OCC, c did not specifically tell the OCC staff that he was uncomfortable with heatin~ up using the excess let down nor did he tell them that l!bl(7}(C} I was uncomfortable. llb)(l)(C I implied that he and !fb\(7)/Cl I shared the same level of comfort, that while it was not something they preferred that thet thout t it would be "ok" to start in Mode 4 as long as they proceed slow and stayed in control. _b}'7l(C_ I testified that does not recall telling the occ staff not to push the operators. In hindswht, l(bl(7l(Cl l wishes he had done a better job exw essing his and ((b)(7)(C) I concerns. ((bl )(C) I now realizes that he did not recognize l!b)])/Cl Iconcern. Likewise, the interviews conducted for the root cause have shown that he underestimated the crew's level of concern that day. l/b)(7l/C) I stated that an !(b)(?)(C) I has given a statement that he was up in the MCR on November 11, 2015, when he observed an interaction between ltb}!7HCl I and a senior manager in which !(bl(?)/Cl Itold the senior manager that they were uncomfortable. According to !(b)(7)(C) I !lb)/7)/Q} I did not recognize the senior manager, so !(bl'7l!Cl I and his team pulled the control room access records. To the end, ltb\(7)/Cl I believes the senior manager was either l!bl/7}/Cl I or l!b\(7)/Cl I who were both in the control room at different times that day. l/b}(7}[Ql I stated, "My gut tells me that this was management pressure outside the OCC." In addition to the managers being in the control room, lib}(7)(Cl I stated there were constant phones calls to the control room about what they were going to do (Exhibit T-17c). Interviews of l(b)(?)(C) l(b_)(_ (C_) _ _ _ _ _ _ _ _ _ _ ___,lat WBN was interviewed on multiple occasions by 01, 7)_

                     ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 186 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION TVA OIG, and AUSA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. During questioning about the events of November 11 , 2015, !lbl(7l(Cl I made the following statements (Exhibit T-07a, pp. 72-75): During questioning about the events of November 11, 2015:

                   "Did anybody either, you know, before when you're planning to do this, during, or after this bring any concerns to you concerning about doing this. I do not want to do this or- "

MR. !/b\(7\(C\  ! No.

                   "did any operators or anyone come to you to say I was uncomfortable doing this and was told to do this anyway type of stuff?"

MR. !lb}[Z)IQ} I Oh, oh. No, sir. Prior to ending the interview !!bl/7\/Cl I added the following when asked if there was anything else he want to add, clarify, add to, or expand on?

                   "Nobody brought up anything of I feel uncomfortable at any time, including the discussions of will excess let-down work the way it is supposed to work ."
                   "Nobody brought up anything that I was forced, coerced, or pushed into any kind of corner whatsoever or attempted to hide anything at all."
![bl{?)[Cl     Iwas asked by the agents what his role was with the Shift Order that was generated concerning the November 11 1 2015 event. He said that !(b)(7)(C)                                          !in the Shift Order. He said !(b)(7)(C)           I The December 18, 2015, Shift Order was written by
!lb}[Z)/C)     Iwith some help. He thinks that the narrative on page 3 was written b *,-!lb-}17--}/_C_}- - .

The timeline was written by !(b\(7\(Cl I The flow chart was generated by (b)(7)(C) and !lb\(7}/C\ I !(b\/7l/Cl Isaid he got the information for the timeline off"Tl""'e,.......,,.o=g.s,,......,,.o.,,...r=ro=m=--' the site's Dataware Program. !fb}(?)[Ql I said that when he was interviewed by 01 in December 2015 about the November 11 , 2015, incident !fbl/7l(Cl Igave the NRC thiis Shift Order. !lbll7l/Cl Iwas asked by the agents where the answers came from to the Question and Answer portion of the Shift Order. !lh)(Z)!C} I said that they came from !(b)(?)(C) I !(b)(?)(C) land Dennis REDINGER. He added that he was 98 percent sure most came from REDINGER. He is not aware of the other crew members being interviewed. He then said that

!!b)U)!Q} I helped REDINGER. !lb}(?)!Q}             Iinsinuated that ilb}m/C} I and REDINGER worked together to come up with many of the answers (Exhibit T-07b).
!(bl(?)(Cl     I said that Shift Orders are used to communicate to departments on lessons learned.

He said that Shift Orders were not legal records and were not maintained in the corrective

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 187 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION action program. According to !(b)(7)(C) I Shift Orders were not something that the site handed over to the NRC. He did say that since the site g*enerated Shift Orders then the Shift Orders would all be available for the NRC to review if they wanted to review them. !lb\17)/C} said that he did not think he brought the Shift Order to the 0 1interview on December 18, 2015. He said he did not recall providing Shift Order 15-50 to the NRC interviewers. ilbl/7l(Cl Iwas asked to look at the third ~uestion in Shift Order 15-50 which asked if the crew expected the condition that occurred. l11m1c1 Ireviewed the question and the answer then stated that the answer provided to the ~uestion had to do with what the crew actually thought at the time (November 11 , 2015). I 61m1c1 I said that it was his understanding that the crew thought that on November 11, 2015. llbl(7}/Cl Isaid that the "50-60" number is what the crew thought that day. l/bl/7)(Cl Isaid that ilbl(l)ICl Igave !lbl/7)(Cl Ithe numbers, but it was llb\(7)/Ql I understanding that !/blUJ/Ql Iand REDINGER spoke to the NRC and then the number came to ilbl/7}/Cl I llbl{7)/Cl Istated that llbl{7)/Cl Igot the numbers from REDINGER who was the Unit Supervisor on November 11, 2015. He said that llbl(7l/Cl Igave him the 50-60 number (Exhibit T-07d). Interview ofl(b)(7)(C) l(b)(?)(C) l at WBN, was interviewed by TVA OIG on January 4, 2016, wherein he provided the following information in substance. ilbl/71[Cl I discussed the origins of shift order 15-50 describing that most of the answers came from REDINGER. The agents asked i/b\(7)/C} Iwhere he got the answer of about 50-60 gpm from. He said that he got that from REDINGER. He added that the answer of 50-60 gpm is based off normal operating pressure. The agents asked !/bl[7l/C} Iif they were operating at normal operating pressure. He said no, but he added that he wrote that paragraph based on discussions with REDINGER. !lbl/7}(C} Isaid that it was his understanding that 50-60 gpm was the capacity for Excess Let-Down. He said that the mistake in the answer is that at the time they were not in "normal" (Exhibit T-44). Interview of j(b)(l)(C) I, Senior Reactor Operator I !(b)(7)(C SRO at WBN, was interviewed by TVA OIG on February 22, 2016, wherein he provided the following information in substance. llliRiiIJ was shown a copy of the shift order dated December 18, 2015, which referred to events which occurred on November 11 , 2015. He stated that the 50-60gpm number makes no sense and is not even possible with pressure only being 350Ibs. He stated that excess let-down is only designed for around 20 to 25gpm at full pressure of around 2200Ibs. He does not think people in the control room would think they would be able to get that number so he does not know why it is written like that. He stated, "I cannot equate my knowledge to this". He stated at full pressure you may be able to get a little more than 20-25gpm but not 50 to 60gpm. !(b)(7)(CJ stated he has never seen excess let down put in at less than full pressure (Exhibit T-12). Interview ofl(b)(7J(C) I Unit Supervisor

                      ,~o, FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L OF 319~CIAL AeErqf 11q Cl lil<ROE, OFFICE OF ltWESTIOMIOP40, AEOIOP* II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 188 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

    !(b)(7)(C)     I Unit Supervisor and SRO at WBN, was interviewed by TVA OIG on May 10, 2017, wherein he provided the following information in substance.

ilbl/7\/C} I stated that he knows that at normal pressure, excess let-down is designed for 20gpm. He assumed that was common knowledge. He said that 40 to 70gpm is not reasonable at all at normal operating pressure that the numbers "did not wash at all" (Exhibit T-45). Interview of l(b)(?)(C) l Shift Manager

    !(b)(7)(C)     I former-SM and SRO at WBN, was interviewed on February 23, 2017, by 01 and TVA OIG wherein he provided the following information in substance.
    !lb)(?\/Cl    I was asked about the content of Shift Order 15-50 and commented on the statement from the shift order "This is based on trainings the crew thought they should have been able to get 50 to 60gpm of excess let-down which they would have stabilized RCS inventory. However, since RCS pressure was left in normal operating pressure they were unable to achieve the expected flow." !/b\(7)/Cl Iexplained that based on his training and experience he would not have expected 50-60gpm from excess let-down or have expected to be able to maintain level in the pressurizer (Exhibit T-34b, pp. 35-37).

Interview of !(b}(?)(C) l(b)(?)(C) !at WBN, was interviewed on June 6, 2016, by TVA OIG wherein he provided the following information in substance. (b)(7) (b)(7)(C) stated the Level 2 evaluation had no management sponsor. Both (CJ and l(b)(7)(C) I b7c were on the team doing the Level 2 evaluation. There was some question re arding who the Shift Managers felt were making the decisions. To get to the information , (b)(?)(C) nd !/bl/7\/C} I interviewed the Shift Managers. Some were in person and some by p one. ilbl(7}(C} I kept the notes. The Shift Managers they i~

• wed all said they would not hesitate to bring up issues and that no one pressured them . (bX7xc, id not think it was unusual to have him and !/bl(7l/Cl I do the interviews because e new the root cause would dig deeper (Exhibit T-48, p.4 ).

Interview of l(b)(?)(C) l(b)(?)(C) !at WBN , was interviewed on February 9 , 2016, by TVA OIG and on June 21 , 2018, by TVA OIG, 01 and AUSA !(b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

  !(b)(7)(C)     Iwas asked about the Level 2 evaluation and said the goal of the team was to find out why the events of November 11 , 2015 occurred. He added that they wanted to see what caused the operators to get to where they ended up. The team was able to figure out what happened. It is detailed in the team's final report. The agents asked !/b)/7)/Ql I who it was that I4ef fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1)1(L efi 3191!:CIAL A~Elff 114 0 1lii!ROE, OFFICE OF l~J~u<EeTl ,ll.+IO~Ha, i..liiiC.10~1 II 6 f'f'le l,-L U9!! 614LY      O1 INVESTIGATION INFORMATION 189 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION made the decision to proceed that day (November 11, 2015). ilb\(7)/Q\ I said it was agreed upon by the Operators and the OCC. The agents asked !tbl(7)/Cl I if TVA learned at an time that the Operators were reluctant to take the actions that day. !lb}U}(C\ I said that (b)(7)(C) during their investigation, was told that operators were reluctant, but the Operators did not have a good reason not to do it !lb)l7}/C} I said the Operators should have spoken up. (Exhibit T-43a). ilb\17}/Q\ I testified about the Level 2 evaluation and revealed some individuals had received the I source information (notes). According to !(b)(7)(C) there are no restrictions in place on sharing information about Level 2 evaluation information. When asked if he had discussed the information and how to report the matter to their internal or external stakeholders, !rb}!?HC} I denied there was any organized effort in their communication. ilb\17}/Q} I suggested there were about ten (10) people on the email of which six (Yr\~r~ Fart of the Level 2 evaluation. i(b)U)(C) I admitted he was a "little" surprised to notice that b 7 c and !rbl(7}!Cl I were on the email. I ilb)[Z)/Q) I explained that he took the position that they !(b)(?)(C) and !(b)(7)(C) Ihad access to whatever they wanted without restrictions. ilb\(7)/C) !suggested that he was not aware of the request (email) from !fblWfC) I and/or !rbl(7}1C) Ifor specific information. ilb}UJIQl Isaid that during the drop-in meetings in January and February 2016, TVA informed the NRC RII officials that the actions. lffi~:~~T did expect the level increase and that at 79 percent the operators took declared during the interview, that the reason the OCC did not recognize the issue was there was nothing indicating that normal let-down needed to be restored before Mode 4. The plant did not need it until Mode 3, with no restrictions and it was not on OCCs ~ nt items list. When asked if it was not required that RHR system be up and operational, lllillZl1QLl stated that in Mode 4, RCS and RHR can either be used below 235 degrees as cited in the technical specifications. When asked about the statement that the MCR crew did not fully understand the expected plant response and proceeded, !rbll71/C) I suggested that although he was not dismissing the factor of schedule ~ressure, he denied it was a contributing cause. ilb)[Z)/Q\ Iadmitted that after he spoke with !/b)!7l(C) Ion Friday night about the NRC questions and concerns, !rb)(?)!C) Ialong with !(bl(7)(C) Ispoke (telephonically) with !(b)(?l(Cl Ion Saturday to clarify the concern and to ensure they understood the NRC's questions about the evolution on November 11 , 2015. !ib}(l)/C\ I suggested that the valve was not opened by accident. ilb\(7)/C\ I asserted that !(b)(7l(C) I made the decision on November 11 , 2015, as he had discussions with his colleagues and the OCC, and eventually made the final decision despite concerns from the operators about moving forward , as he felt he did not have a good reason not to proceed forward (Exhibit T-43b). Interviews of !(b)(?)(C) !(b)(7)(C) !at WBN, was interviewed on February 22, 2016, and April 03, 2017, by TVA OIG wherein he provided the following information in substance. When discussing the Level 2 evaluation, tbJ(?JtCJ said that he and his team were given a very short timetable to conduct the Level 2 evaluation. The Level 2 evaluation took place ri~ around the December 0 1interviews at WBN. It was during t tion that ~ and his team initially interviewed !!bl(7)(C} I According to (b)(7)(C) had alread been interviewed by the NRC. l(b)(7)(C) f aid that !(b}(?)(C\ I was in erv1ewe y 1m, ....(b_J(?_)(_C)_ _ ___,

                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   O1 INVESTIGATION INFORMATION 190 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

    !(b)(?)(C)             I and l(b)(?)(C)            I all at the same time in l(b)(?)(C)                            !office. lrb}f?}(C}          I told (b)(?)(C)              nd others that he was not comfortable pushing back in the control room that day.

epor edly ilb)l?)!C) I admitted that he did not feel he could push back without concrete evidence. !(b}C7)/C} I mentioned approximately five events that took place before November 11, 2015, which tended to cause him to feel like he could not push back to management. (b)(?)(C) tated that the interview team did not ask !lb)(7)!C} I to give them any specifics on w Ic Ive events he was talking about (Exhibit T-25a).

    !(b)(?)(C)                    I Level 2 Team took their notes from lrb)UJfC}                        I interview and compared them with notes taken during !/b}C7)<C}                              I0 1interview. (b)(7)(C) could not recall how or who produced what was said duringj(b}fZ)fC}                               I 0 1interview. (b)(?) did know that !(b)(?)(C)                     I Level 2 Team compared what ilb}U[Gl                            I told the Level 2 Team against what was said to the NRC. (b)(?)(C) old the agents that it was apparent to him that !/b}f7}(C}                                 I told Level 2 Team much more , an w at l/b){7}/Cl              I told the NRC. At this point, tbl(7l(C) entioned that !(b)(?)(C) may have provided the notes from the                                 m erview, but IIiillfilJ.... w....

a..... s'""" n-o _ t 1_0_0_p_e-rc_e_n_t -s u_r_e_ Regardless,fbX7XCJ !stated that!{b}[7l(Cl !came and talked to the team to compare notes. Based on this comparison, it was obvious that l/b}{7)(C} I had not told 01 what he had told

   !(b)(7)(C) !Rather, ilb}/7\/C}                    I had given~              more information (Exhibit T-25a).

The piece that Hbl/?lfC} I added when l/bl(7}/C} I team interviewed him was termed by ~ to the agents as "Safety Cultu I e". To (b)(7l(Cl this "Safety Culture Piece" was som~ new to the Level 2 evaluation s {bll7XCJ a It needed to be explored further. (b)(7)(C) provided this newly acquired information to (b)(?)(C) and l(bl(7)(C) !sai a (bf(7l nd ilb}mrci I interyjewed each Shl'ft Manager and asked them about the Safety Culture Iece brought up by l(b)(?)(Cl . thought that !(b}/7l(C} I and lbJl7J interviewed each Shift Manager alone (!(b)(7)(C) !and the individual Shift Manager . He is not sure if they were interviewed in person, on the phone or a combination of both. (b)(7)(C) stated that the Shift Managers gave the answers you would expect if a Senior Manager an your direct boss asked you the questions. he S ift Managers said there were no issues. Other than !lb)(7)/C} I and the Shift Managers, tbH?l(Cl said that no other operators were interviewed concerning the Safety Culture Piece as pa o e Level 2 evaluation (Exhibit T-25a). (b)(7) I l(b)(?)(C) was interviewed concerning an email between (Cl nd !/b)(7l(Cl I about the content of the Level 2 evaluation into the events of November 11, 2 . After reading the email (b)(7)(C) believes ilb}U}(C) I was telling IIfil[I to remove that the OCC had directed the operators ecause the Main Control Room (MCR) is the o _ .......-i.ho can make cisions and this way it

    ~,......,......,....._........,_..,lame was on the MCR. (b)(7)(C) is not sure wh (bH?XCJ ould have sent this to
,.,,...,..,.,...,..,....,...--.,....,... stated that !lb}UJIC} I was no on the Level 2 or oo ause team. According to (b)(7)(C) one of the reasons the team exists is to prove or disprove what happened. T hey would information up on a board and then put evidence down in order to narrow down the causes. He does not thin (b)(7)(C)                               hould have been able to just change something, but he can see why lrbl/7}/Cl I woul                         ave one it because they could not have it written that the OCC stepped out of their role and had e ual responsibility with the Shift Manager who has the ultimate say in the control room. (b)(7)(C) is aware that the NRC gets the root cause reports (Exhibit T-25b).
                                          ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAi AGF!>II l!>I GHO~'-li , Qfiiifiiil'uiil Qfiii IW.'EeTIQ,Q;+IO~JS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         OI INVESTIGATION INFORMATION 191 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews of l(b)(?)(C)

           !(b)(?)(C)                                                    lat WBN was interviewed on February 23, 2016, February 25, 2016, and September 26, 2018, by TVA OIG and 0 1wherein he provided the following information in substance.
            !lbl/7}(C} I said that the group doing the Level 2 evaluation into the RHR had generated a draft report and the draft report had been given to !!b\[7)/Ql I and !lb)01Q}             I sometime over the three-day weekend of January 16-18, 2016. irb}(7}!C\ I said [lli[l] provided the draft report to..,..,.,,,,,..,,..__,
           !lb}Q)(Cl      I ~nd !(bl(?l!Cl I lrb}l7}(Q} I said that there was a telephone call that Monday !(b)(?)(C)          I between (b)(?)(C)                 nd !lb\U)(Ql      I The three of them went over the draft report. Based (b)(?)(C) _  offJhisca *; * * * *

• got off the phone with some action items, one was to interview the other Shift Managers. !lb}!7l(ci I told the agents that he believes the int rviews of the Shift Manag~ rs were done on that Monday. The interviews were conducted b bJ(7ltC) and !/bl!7l/Cl I !fbl/7\JCl I recalled that he let the group know that he thought they s ake sure to ask the other Shift Managers the same questions that had been asked of !/b\(7}/Ql I !/b\17\/Ql I said that a Level 2 evaluation normally has a 30-day timetable. They had a seven-day timetable. He recalled that they began the evaluation on Monday and found out on Wednesday that they had to be done by the following Monday. He does not know who made that decision (Exhibit T-47b).

I

            !(bl/7l(Cl I was asked if l(b)(?)(C) significant changes to the Level 2 evaluation report on his own or at the direction of someone else. He stated that he could not recall .......,....._..__

(b)(?)(C) b7c ____ made any significant changes to the Level 2 evaluation report. He added that if (b)(7)( b7 c direction of someone else. The agents explained to 111,Ul.1-_. that the Level 2 Team (b)(?)(C) was a member) worked on the Level 2 evaluation during the Martin Luther King weekend in 2016. The Level 2 Team's conclusion at the end of the weekend was that both the MCR and the OCC shared blame for November 11, 2015, but then someone removed the OCC from blame. irbl(l)(C} I stated that he was there that weekend working on the Level 2 evaluation and to the best of his recollection at the conclusion of that weekend the Level 2 Team was in agreement that both the OCC and the MCR were at fault. He stated that the Team, based off what they had found, did not believe it was only the fault of the operators. !(bll7l(C} I stated that the Level 2 Team knew that the OCC was at fault as well. As a matter of fact, !(b}(?\/Cl I stated that at no time did the Level 2 Team think that the OCC did not have culpability. !lb)(Z}IQ} I stated that on Monday, Martin Luther King Day, there was not a lot of work being done on the report except for some to-do items from a conference call the

           !(b)(7)(C)                                   l  had in the (b)(7)(C) One of those actions was to interview the other Shift Managers. He could not reme~~ffl"ll. other items. !lb)[Z)IQ) I stated that at the time of the Level 2 evaluation he was the (b)(7)(C)                                             He stated that he was also a b)(7 C)                                                                       e stated that he received the in ervIew no es con uc e y e eve                        earn, so he knew what the Team was finding. He added again that the Team never thought that the OCC was without fault in the November 11, 2015 event (Exhibit T-47c).
                                   ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF l~J~'ESTIGMIO~JS, AEGlmJ II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 192 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interviews of l(b)(?)(C) l(b)(?)(C) l was interviewed on September 26, 2016, and September 27, 2018, by TVA OIG and 01 wherein he provided the following information in substance. l/b}<?}/C} I was on the team that was ut to ether b TVA to examine issues having to do with the November 11 2015 event. (b)(7)(C) and l/b)/7}/C} I all participated. l/b}/7}/C} I examined th~e~(b~l(,;,.:.7l~(Cj_

                               ) _ _ _ _...Jle:::.1;le
                                                     ~m~ en~t""'
                                                              . ..lllijiillilil"'-~a~n~d..!.h1.1.:is:l..tl:.:=e:.i::

a.l.l. m:..:w

.;o~r~k::::;

ed ~ o.l.l. n .l.lth~e~L

                                                                                                                                                      =el~v:.:::e::..

I =- 2-. (b () C) (b)(7)(C) stated that they interviewed the SRO:s and Shift Manager. In regard to what happened on November 11 , 2015, 1/b}U}(C} I believes it was common operator error because the people working that day had the knowledge as SROs that it would not work. He does not know why then they would have tried to go ahead with the hkal~~fi have been schedule pressure, but he does not know. b

                                                                                                      °r          that day. He stated that it could believes the Shift Manager did not want to tell the people that he would not run it [perform the heat up]. He stated that there were several conversations about possible schedule pressure and the safety culture. He discussed several people telling him that they were worried about retaliation, but the team was unable to find any direct evidence that retaliation had occurred. However, the perception from those interviewed was that if I push back it will hurt me. lCb\/7\(Cl I wrote up his portion which related to the l(b)(7)(C)                       !aspect which was put into the final report (Exhibit T-60a).

lrbl(7}(Cl I vaguely recalled working on the project over the Martin Luther King weekend in 2016. He stated that he has no recollection of changing anything in the Level 2 evaluation report on Monday [January 18, 2015] (MLK Day). He recalls that the Team had collected data reflecting that the OCC had a role in what happened on November 11 , 2015. He does remember the Level 2 Team discussing the OCC's role and culpability. It was clear to !/bl/?}(Cl I that on November 11, 2015, there was "stuff oin on between the OCC and the MCC." l/bl/?}(C} I recalled that he b c in the Level 2 evaluation. He added that all the Team members had arts to do. b 7 c does not know who removed the OCC from the final report. He said that (b)(?)(C) because removing the OCC from the final report was a very big deal. =~_, did say that the section he handled and wrote u ot toned down. He stated what he wrote it up was written "strong." He said "they" (b)(?)(C) so it was not as "stron ." llblm<Cl I was rovided with a copy of the Level 2 eva uatton report emailed out on (b)(7)(C) This version of the Level 2 evaluation report had the OCC and the MCR blamed equally. b 7 c read one sentence out loud which stated, "OCC and MCR displayed a lack of conservative decision making". He then stated that "yep, that is what happened." He then discussed that he was really surprised that a high-level change like removing the OCC had been made. He said that this was the first he heard of it because when he was done with the assignment, he went back to Chattanooga. He did say he emailed someone from the Level 2 Team later in the week of January 18, 2016 to see how the Level 2 evaluation had been received. He thought that the email response indicated everything was fine with the reception (Exhibit T-60b ).

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY             O1 INVESTIGATION INFORMATION 193 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview of !(b)(?)(C) l(b)(?)(C) !at Watts Bar was interviewed on March 22, 2019, by TVA OIG wherein he provided the following information in substance. lib\17}/Q) I was listed as the l(b)(7)(C) !tor the Level 2 evaluation into the RHR o eration on November 11, 2015. The ag= ............ owed llb}(?l/Cl I an email sent on (b)(?)(C) at approximately (b)(7)(C) fro ibJ(7l(Cl o !!bl(7)/C} I and l/b\(7)/Cl I The agents asked .......,......,.__, to explain the emai . .................__. d that the Level 2 team was working on the Level 2 evaluation report over the Martin Luther King (MLK) holiday weekend. libli7l/Cl I said that he and (bH7l(Cl ere not there for the MLK weekend with the Level 2 team. lib)(Z)/C) I could not reca w ere he was, but he was not at the site because he went away for MLK weekend. The agents showed llbl[?l/Cl Ian email dated (b)(7)(C) at approximately (b)(7)(C) between l~c7) nd llbl[7}/Cl I The agents asked w.1.11.1..ii,,,1,i.-,1,to explain the email. said, "it is re ning," referring to the email between (b)(7J(Cl nd l/b\(7)/Cl I llbl/7}/C} Icontinued that b c and !lbimrcl I would have been in the on November 11, 2015, and the direction would have been coming from them. llbl(?)/r;) I said that lib\/7\/C\ I was the !(b)(?)(C) (b)(?)(C) and "it is surprising to me that someone at that level would have been looking at this." _ _ _ _ also said, "I probably should just shut my mouth" (Exhibit T-49c). The agents asked llbll?l/Cl I what his role on the Level 2 team was. llbl(7)/Cl Iadvised that his role was not to validate the facts. He took what was in the Level 2 evaluation report at face value because of the high-level individuals working on it. lrb)U}IQ) I took what the Level 2 team generated and put it together administratively to meet the constructs of what a Level 2

                  .    .                         b7 C
.......,..........,__, could not recall if (b)(?)(C)                          in the Level 2 evaluation report. He is not required to be involved in al t e eve 2 eva uatIon interviews, and he did not participate in the all the Level 2 evaluation interviews that took place. llbll7l(Cl Iadvised that "it would upset me if things not true are in the Level 2." llbl/7l/C} Isaid this would upset him because he has integrity. If he knew false information was in the Level 2 evaluation re ort he would have said to take his name off of it. The agents asked llbl(7)/C} Iwhat (b)(7)(C)                                        and llbl(7)/C} I role on the Level 2 team was. kfomrcl I said evaluation "hit the street" as soon as possible.
                                                                   !(,;~/i~,61 1 1 as carrY,in      e a o ave the Level 2 was the (b)(?)(C)              at the time, anrl lib\17\/C} I had the "largest breadth of experience." libl/7\IC) I un ers oo                      e sensitivity to the NRC questions, and he was going to get the Level 2 evaluation report to the NRC, so the NRC's questions could be answered. l1Wn1c1 I said that lb)(?) 'was on the team." llb\17\IQJ I said that he usually does Level 2's, but that !(b)(7)(C)                         ~ and b 7              do not usually do Level 2's.

lrb}l7}(Q) ) P.Xpressed to the agents hts frustration with the fact that so many high-level people were on the Level 2 evaluation. The agents askerl lib\(7)/C\ I where the words "not recognized" and "did not challenge," in the Level 2 evaluation report came from. llb}/7l/Cl I said he did not know where these words came from. (Exhibit T-49c).

                              ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY         01 INVESTIGATION INFORMATION 194 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview of!(b)(?)(C) INRC Region II (b)(?)(C) NRC Region II, was interviewed on December 13, 2016, by 01, TVA-OIG and AUSA b 7 c US Attorney's Office for the Eastern District of Tennessee, wherein she provided the following information in substance. l/b)U}/Cl I was present for the February 2, 2016, drop-in meeting in Atlanta, Georgia between NRC and TVA personnel. While she knows that other eo le were there from TVA, she only recalls l{bl(7)(Cl Jlrb)U)/Cl I and (b)(?)(C) She knew (b)(?) before the meetin because he used to work at NRC. S ecificall , (b)(?)(C) b7 c The February 2, 2016, meeting was the

                                                     .......,......,._ _. (Exhibit T-52).

does not recall how the Februar 2 2016 meetin came about because she had *ust

                                         ,e I no as or t e mee mg. n t_                       e_   _.,___ _ _ _ _-=-_,,

wee ~ ~ - -w .u,as given a pre-briefing of the November incident by (b)(?)(C)

              .., This briefing consisted of her being made aware or-rc~~=r-===-n:-:~1""1"7"<---

had and how TVA was handling the matter (Exhibit T-52). l/bl/7l/C\ I was shown copies of a PowerPoint dated February 2, 2016 and prepared by TVA. She reviewed the PowerPoint and stated it "looks familiar" as to the one they were presented with at the February 2, 2016 meeting. She recalled that most of the discussion was iven b):'. lfbl/7}/Cl I and l/bl(7}/Cl I l/bl(7}/Cl I rloes not recall anyone in the room challenging b 7 c l@7)(C) I or anyone else about the accuracy of what was in the PowerPoint or what was being discussed. She said that TVA made the presentation as a unified front. She said that no TVA person corrected or amended anyth ing said by l(b\(7)(C} I or l(b\(7\(Cl I (Exhibit T-52). l/b)U}IC) I reviewed Slide 6 in the December 2, 2016, PowerPoint and stated that it was what was presented at the meeting. She further stated that the TVA presenters stuck to the messages on the slide and while her background is not technical, she may have missed some of the nuances of what was being said, she has no recollection of them talking about anything different than what was on the slides. l/b}Q}(Cl I stated that no one from TVA has ever told her that what the NRC had been told regarding the RHR incident had changed. Likewise, no one at TVA has ever indicated at any time that what happened on November 11, 2015, was anyone's decision except the MCR crews as shown on Slide 6 of the February 2, 2016 presentation. If changes had needed to be made based on information provided at the drop-in meeting, a phone call would have worked but ald?Yz~,~~lges made to something at a public meeting would have needed to be in writing. stated that no one ever said anything was different even though there were numerous opportunities to tell the NRC if anything had changed. (Exhibit T-52). Interview ofl(b)(7)(C) I NRC Region II ... ) _ _ _ _ _ _ _ _ _ ___.I NRC Region II, was interviewed on December 14, 2016, !(b_)(?_)(_C_

                          ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi aP  G l :O.la Ae~n l~J GI lpl),li\Qlsi, OFFICE OF I~*~'[TIGMIOP40, REOIOP* II 6 f'f'le l,-L U9!! 614LY              OI INVESTIGATION INFORMATION 195 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION by 01, TVA OIG and AUSA !(b)(7)(Cl I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. During his interview with the AUSA,~ was allowed to review TVA's February 2, 2016 presentation. When asked if TVA reported the information to the NRC as detailed in the presentation, b c esponded that TVA briefed the NRC directly from the presentation as noted. (b)(7)(C) recalled that TVA cited several factors as the causes of the RHR event. !(bl(ZHC ! could no reca I who all was in attendance from TVA. Specifically, there was an unantiicipated pressurizer level increase, the MCR crew displayed a lack of conservative decision making and their decision was not recognized or challenged by the OCC. Upon hearing these factors, (b)(?)(C) expressed that he was surprised to learn that OCC did not challenge the decision. onversely, (b)(7)(C) xplained that TVA was not confronted about OCC's role since the Root Cause Analysis A) was apparently in-progress. According to !(b)(7)(C) khere were no dissenting voices from TVA about the facts of the presentation and the NRC did not argue back any of the points (b)(?)(C) testified that TVA has not suggested, nor have they communicated a need to correct ear Ier s atements relative to the factors involved in the November 11 , 2015 event. To that end, (b)(7)(C) affirmed that TVA as of the date of this interview has not chan ed their positioned nor amen ed information as provided in their presentation to the NRC. (b)(?)(C) said that the NRC inspection report relative to the event, dated April 2016, in part cited t at operators may have received undue influence and/or direction from outside the MCR during the event. Likewise, TVA did not formally contest the NRC's results to (b)(?)(C) r to a:t NRC official, that there was undue influence because of a fear of reprisa . ough !(b\(7 Ql I impression was that TVA generally addressed the event in their presentations the information centered on multiple evolutions with the primary driver being the removal of RHR (Exh ibit T-50). Interview of !(b)(7)(C) INRC Region II (b)(7)(C) NRC Region II, was interviewed on December 14, 2016, by 01, TVA OIG and AUSA .......,....._...___, US Attorney's Office for the Eastern District of Tennessee, wherein she provided the following information in substance.

 !(bl(Z)(Cl I testified that she attended the second drop-in meeting on February 2, 2016. She recalled that TVA generally followed and spoke to the NRC from the prepared presentation slides. Her overall impression was that TVA was owning the concerns. Specifically, !(b\(7\(C) I said that she felt that there was more sense of ownership than what TVA had expressed during the January meeting. !(b}(l\(C) I stated that TVA did not communicate any concerns relative to schedule pressure or the undue influence over the operators.!(b)(7)(C) !explained that TVA proceed to highlight that they had chartered a Root Cause Analysis (RCA), established super crews in the Main Control Room (MCR) and were preparing to conduct a third-party review.
 !rb}!7l[C} I ~dmitted that she believed TVA had taken ownership to address the concerns.

Although she has not read the final RCA report, she reached that conclusion primarily on TVA's pledge to the NRC that they were committed in correcting the problem(s) (Exhibit T-51 ).

                        ,~e, fieR 1-UBUe 01aeteaURE WITI Ieu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   OI INVESTIGATION INFORMATION 196 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Interview of !(b)(7)(C) l at WBN !(b)(7)(C) !at WBN was interviewed on May 26, 2016, by TVA OIG wherein he provided the following information in substance. lfb}CT}(C} I described that he was working on November 11 , 2015. He was in the OCC for part of the time. ilb}(7l!Cl I was aware that the normal let-down was out of service and that the excess let down had been placed in service. He also knew that there was some heatin~ uf that was going to be done within the boundaries of pressurizer level. It appeared to lrb}!7} } that the operators underestimated what the excess let-down would let them do. ilb}(7l/Cl I did not know the operators were uncomfortable moving ahead after ilbl/7}/Cl Igot the call from the NRC on December 11 , 2015, saying that they had a concern. It was over the next several days that it was discovered that there were questions over how they (the operators) did not use the procedure. ilbl/7l/Cl I stated that it was after this that he heard that some operators said they were uncomfortable. !lbl/7l/Cl I was aware they placed RHIR let-down in service. Likewise, he knew the day of the incident that the control room had to take action to lower pressure when they got to 80 percent pressure level. He does not know how he knew this information but believes he may have read it off a status board somewhere (Exhibit T-33). Interviews of l(b)(?)(Cl l atWBN !(b)(7)(C) l at WBN was interviewed on December 18, 2015, and March 26, 2016, by 0 1and TVA OIG wherein he provided the following information in substance. ilbJmrc, I indicated that he was briefed on normal let-down system repairs not being1 completed as scheduled and continuing plant start-up while normal let-down was not in service on November 11, 2015. irbl/7}/Cl I described the content of the discussions including the potential heat-up rates and there being no need for just-in-time training for use of the excess let-down system. ilb\{7)/Cl I identified that as of the December 18, 2015, interview additional oversipht had been established for the control room with specific written guidance created by irbl/7l(C I He also noted that they were putting out a standing order to re-emphasize conservative decision making. He had not seen that standing order at the time of the interview but planned to review the shift order that afternoon and check it for its content. He committed to get copies to the SRI. Exhibit T-00a, pp. 12-16, pp. 31-33). ilbl{l)(Cl I advised that lhe is not a licensed operator. b 7 c admitted that he was working at WBN on November 11, 2015, and suggested that he was present at various locations within the plant to include the OCC. ilb}/7}/Cl I remembers that he walked into the OCC around midday on the November 11 , 2015, where he learned that there had been a pressurizer level issue which was remedied. lfb}!7}(C} I could not recall the exact way he learned that there had been a pressurizer level issue but believes that someone [NFI] in the OCC began talking to him about what had happened in the MCR. ilb)(7l/C) I said that the MCR was able to stabilize things (recover the ~ (b\(7}/C} I said that irb)Ul(C} I was working that day as well and remembers seeing ~ in the OCC (Exhibit T-00b).

                      ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 197 Case No. 2-2016-042

6 FFlel,-L U9E 614LY 01 INVESTIGATION INFORMATION When discussing the telephone call with ilb)(?)(C} Ion December 11 , 2015, !/b)/7)/C\ I contends that at the end of the call he still was not sure what event !fblf7l/C} I was talking about. i!bl/7\/Q} I did not learn that l!b)(?){C) I was talkinl about the November 11, 2015, event until the next day. lfb\f7)/Cl Idirected lfbl/7\/Cl Iand fblf7}(C) Ito contact the Shift Managers, and through those conversations !fb\(7)/C} I learned that !fb)/7\(Cl I questions were about the November 11, 2015 event. i{bl(Z)/Ql I~dmitted that he did go into the MCR that day after the pressurizer level had normalized and spoke with !(b\17\(C) I !fbl/7}/C) Idenied that he hu~med an one in the MCR. !lbl/71/Cl I may have shook hands, but he did not hug anyone. i!b}) C) 1 said that i!b\ffi!Ql Iinformed him what happened but said everything was fine now (Exhibit T-00b). ilblU}{C) I realized after l!bl/7)(Q} Icalled that there was a mistake that day ilb)U)fC} Isaid that a question came up about whether or not they had followedlrki~~~dr e that day. That, according to !(b)(7)(C) I was the original discussion point with ,  !(bl/7l/C) I told the agents that thel'. did not have a procedure to cover the actions that were taken to recover the ffilant that day. !rblf?l/Cl I was shown a copy of the Shift Order dated December 18, 2015. blfZ)fC\ I said that he had not seen this particular Shift Order before. !rb)fZ)/Cl I does not know who wrote the Shift Or,der and he did not tell ilb\(7)/Ql I to write it. He does not know where the figures (gpm) concerning excess let-down capacity contained in the Shift Order came from but explained that Shift Orders are supposed to be used to provide guidance to the crews. They are written as guidance tools (Exhibit T-00b). Interview of l(b)(?)(C) was interviewed on February 4 , 2019, by 01, TVA ~ - . a- n--,-,..,..,.R'T'T(,b,..,.)("7)--

                                     "' (C,.,..
                                            )- --,,- ro-m--.,,--e...,..,,~ Attorney's Office for the Eastern District of Tennessee, wherein he provi e t e o owing information in substance.

~ explained the purpose of the February 2016, drop in-meeting was to meet with NRC RII management to discuss performance issues associated with the plant. In addition, it was also a recognition going back to the comments from (b)(7)(C) nd!(b)(7)(C) Ion December 18 2015, that TVA had not demonstrate a thorough understanding of the RHR event. ~ stated that it was important for !rbl(7)/C\ I to discus~ N performance in light of the series of events that occurred throughout the fall of 2015~ ex lained that his involvement was similar to the January 6, 2016, drop-in meeting, wherein (b)(7) reviewed the slides and addressed "holes" by conducting a walk throu h in !fb117lfC) Ioffice. (b)(7) asserted that the site prepared the presentation and they rovided (b)(l) a copy for awareness of what was going to be said and to offer any feedback. (b)(?)(C prov, e some insight on whether the information was complete and responsive to the issues. !(b)(7)(C) !testified that he doesn't recall anything in the presentation that stood out as not credible (Exhibit T-62, pp. 59-61). Agent's Analysis In summary, the 01 investigation revealed that on January 20, 2016, TVA completed a Level 2

                           ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEC IAL AGDH IPJ 0 1h0tRGE , OFFIOE OF ltWESTIOMIOPJS, REOleN II 6 f'f'le l,-L U9!! 614LY                           01 INVESTIGATION INFORMATION 198 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION evaluation report as part of Condition Report (CR) 1121520 to, in part, revier )~~jecr of the November 11, 2015, heat-!~[( ~(nf r controlled pressurizer water level rise. b 7 C

!(bl(7l(C)          I !(b)(7)(C)        I b 7 c !(b)(7)(Cl                     I and~            articipated in the generation and finalization of the Level 2 evaluation report which fa'tfea"-ro include complete and accurate information concernin the ev                         f November 11 , 2015. During the completion of the Level 2 evaluation re ort                        and (bl(?J team (b)(5) n e               ,     , b                                          c...___,

(b)(?)(C) and b 7 c made a presentation to NRC RII Executives which included the e I era e y incomplete and inaccurate information contained in the Level 2 cause evaluation report for CR 1121520. On January 11, 2016, TVA WBN began a Level 2 evaluation, for condition report (CR) number 1121520 to address the specifics of procedure use and adherence associated with 1-GO-1, SOl-74.01 (RHR) and NPG-SPP-01 .2 .1, Interim Administration of Site Technical Programs and Procedure for WBN 1 and 2. In part, the team was to review as ects of the November 11 2015 heat-u and uncontrolled ressurizer water level rise. (b)(?)(C) (b)(7)(C) and the Team Members were indicated as follows (Exhibit A8-E 1, p. 1 ): (b)(7)(C)

!(bl(?)(Cl       I a member of the analysis team, discussed that a Level 2 evaluation normally has a 30-day timetable for completion, but this evaluation had a seven-day timetable. This established a projected completion date of January 18, 2016 (Exhibit T-47b). By Friday, January 15, 2016, he cause evaluation team had com iled conclusions and be an draftin their findin s.                                                                    (bJ(5) r::O~n--r::-b":":"7
                                                                                         ~ C:----~rr::-=~r---:,=----.---___,J document via email that summarized the work and findings of the team. The at                                                                 ent documented that the involvement of the OCC and the abi lity for the licensed o erators to make independent decisions were amon the issues that required more evaluation. lbl(?J(Cl orwarded this email to !(bl/7\(Cl I On (b)(?)(C)                                                    emailed b 7 c
!(b)(7)(C)         I !(b)(7)(C)        I  b 7c        ........................ b 7 c            an"':

d1 : ~ ~~~....

                                                                                                             .,- no - :t:-

e-s _g_e-n e _r_a-:- te-:d:--:during interviews of operators and managers about the events of November 11, 2015. These notes (b)(5)

                             ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                OI INVESTIGATION INFORMATION 199 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)(5), (b)(?)(C) l(b)(?)(C) On !(b)(7)(C) l REDINGER sent an email containing his written statement concernin the events of November 11, 2015, to lrbl/7l(Cl  ! Iwhich was forwarded on to !(b)(7)(C) .._b..,.)7...._C..____. l(b)l7J(C) ~ nd !lb)(?)/C) I REDINGER's statement indicated that the OCC was informed that the MCR staff was concerned about the heat-up and capacity of the excess let-down system at low pressure if the RHR system was taken out of service for testing (Exhibit A8-E4) (Exhibit A8-E5)(Exhibit A8-E6). On j(b)(?)(C) l !tbl(7)/C) I sent an email containing his written statement concerning the events of November 11, 2015, to !rb)(Z)(Cl Iwhich was forwarded on to~ nd !tbl(l)(C) I

    !lblUJ{C}                           Istatement indicated that the OCC direction was to remove R~ om service and allow RCS to heat-up once 1-Sl-0-905 was complete. His statement also detailed that he had several conversations with the operations representative in the OCC !(b)(?)(Cl                                                    l and informed him of the crew's concerns with taking RHR out of service for testing (Exhibit A8-E7)

(Exhibit A8-E8). (b)(7) On b 7 c I

                                                      !tbl(7)(Cl sent an email to (Cl                and !!bl/7}/C} I with attachment (b)(?)(C)                               ' which was his (b)(?)(C)                              section input into the report. This included a determination that procedures did not exist for the use of excess let-down to control pressurizer level following isolation of the RHR let-down. It also included that the plant simulator verified that excess let-down could not be effectively used for this purpose which was consistent with plant design (Exhibit A8-E9).

On !(b)(?)(C) r::-!!b-:-:e}d~1/""'cj.--.......j -w.... h-,c,- h-re_q_u_e-,st.... e..,. d"" Isent a draft Level 2 evaluation re art to !tb){l)(C) I and th_e_m-,-,_ to eva Iuate for " (b)(7)(C) (b)(?)(C) I (b)(5) w..11,,j~,____. described that on the (b)(?)(C) of January 18, 2016, (b)(7)(C) and ...............,,_,__ _, held a telephone call and discussed the draft Level 2 evaluation report. Based off this call, (b)(?)(C) got off the phone with some action items Exhibit A8-E10, p. 1, pp. 7-13)(Exhibit T-47b). (b)(7) On (b)(?)(C) hours, (Cl emailed the Safet Culture Analysis (SCA) for the Level 2 evaluation to (b)(?)(C) and b c emailed this document to lrb)l7l(Cl I on b 7 c on the email. lb)(7J(Cl oted "Read new Culture aspects". (b)(5)

                                               ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY               O1 INVESTIGATION INFORMATION 200 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION I re lied to the SCA email a few minutes after receivin it, at (b)(l)(C) with " (b)(l)(C) _ )_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Exhibit A8-E13) _(b_)(7_l(C (Exhibit A8-E14 )(Exhibit A8-E1 , p. 24).

• Draft SCA Aspect X.11 (Challenge Assumptions). The SCA IIfilIZJ emails to !lb)(l)/C) I and !lb}[7)!Ql I says "!(bl(7)(Cl I Ii')(ll(CI .

(b)(5), (b)(7)(C)

                            ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        O1 INVESTIGATION INFORMATION 201 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)(5) (b)(5)

       *    (b)(5)
       *     (b)(5), (b)(?)(C)

I !(b)(7)(Cl !(b)(7)(C) I !(b)(7l(Cl I !(bl(7)(C) I I

                                                                  !(b)(7)(Cl an~ were all identified as havi known information that was not consistent with the final re ort conclusions.

(b)(5)

                            ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        OI INVESTIGATION INFORMATION 202 Case No. 2-2016-042

6FFlel,-L U9E 6f4LY OI INVESTIGATION INFORMATION (b)(5), (b)(7)(C) Based on interviews conducted durin this investi ation the MCR o erators on shift on November 11, 2015, indicated (b)(5)

                      ,~ef Fef't 1-UBUe 01 aete1'Uf'tE Wlf l 1euf )fl(fifif'te1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPNESTIOMIOPJS, REO IOPJ II 6 f'f'le l,-L U91! 6f4LY OI INVESTIGATION INFORMATION 203 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION that they were directed by OCC to proceed with the removal of the RHR system from service. The MCR operators expressed that they did not have any misconception about the capabilities of the excess let-down system at low RCS pressure. The interviews also established that the operators did not support taking the RHR system out of service as detailed in the following: (b)(5}, (b)(?)(C)

       !(b)(7)(C)
                      ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY O1 INVESTIGATION INFORMATION 204 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)(5), (b)(7)(C) 01 determined that the information documented in the final Level 2 evaluation was deliberately not complete and accurate in all material respects. The Level 2 evaluation contained information that was in direct conflict with accounts of the actual events and failed to contain all known relevant information concerning the event. !(b)(7)(C) I I !(b)(7)(C) and !/bl(7}/Cl Iwere all determined to have participated in the generation of the finalized Level 2 evaluation, and at the time the report was generated had knowledge of the true events and information that was not included in the report.

1) (b)(5) 2)

3) On February 2, 2016, TVA attended a "drop-in" non-public meeting at the Region II regional office to discuss the status of WBN U2, which was ~ by Watts Bar senior managers l I includin~!(b)(7)(C !(b)(7)(Cl !(b)(7)(Cl I I

                                                    !(b)(7)(Cl an !b)(TJ(CJ During this meeting, Watts Bar senior managers jointly made a presentation to NR o 1c1als that included information about the
                           ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      OI INVESTIGATION INFORMATION 205 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION events of November 11, 2015. Included in this presentation was information from the Level 2 evaluation (Apparent Cause), associated with the November 11 , 2015, heat-up and uncontrolled pressurizer water level rise (Exhibit A9-E1, pp. 1-24 )(Exhibit A9-E2, p. 1): (b)(5) The presentation specifically cites the apparent cause analysis (level 2 evaluation). The presentation includes a lack of conservative decision making and risk review by the MCR crew as a cause while falsely stating that the decision was not recognized or challenged by the OCC. These statements in the apparent cause analysis were investigated in Allegation No. 8 and determined to not be complete and accurate in all material respects. T his presentation also included a statement assigning a contributing cause that the MCR crew did not fully understand the expected plant response and proceeded in the face of uncertainty, but no additional information was included to indicate that members of the OCC also did not fully understand the expected response with securing RHR while on excess let-down (Exhibit A9-E1, p. 10)(Exhibit A9-E3, p. 6). I As previously established !(b)(7)(C) !(b)(7)(C) I I

                                                     !(b)(7)(C) and rrfilrrJ all had prior knowledge that contradicted the information being provided during this brief to the NRC. Based on the information reviewed and interviews conducted 0 1determined that the information provided to the NRC in the meeting was deliberately not complete and accurate in all material respects.
                 ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF l~J~'ESTIGMIO~JS, AEGlmJ II 6 f'f'le l,-L U9!! 614LY       OI INVESTIGATION INFORMATION 206 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION

              ) _ _ _ _ _ _....,! and (b)(?)(C)
._l(b_)(?_)(_C_                                           were cognizant of the truth of the following:
            *    (b)(5) l(b)(4)                                                                                          !which documented information that was excluded from, or contradicted the information in, the Level 2 evaluation report and February 2, 2016, drop-in presentation. The report specifically identified that the OCC had knowledge of and made the decision to proceed with start-up activities on November 11, 2015. The report clearly demonstrates that the OCC was at least equally culpable in the deficiencies that caused the events as summarized in the report excerpt below and various other locations in the report (Exhibit A8-E20, pp. 12-13, pp. 85- 97, pp.101I-119):

(b)(5), (b)(?)(C) Once the need was determined to remove RHR from service to maintain the outage schedule, the shift manager questioned that action and wanted to wait until normal let-down was returned to service prior to removal of RHR. Interviews and statements provided by other MCR staff indicated that the operating crew had communicated concerns to the shift manager with removing RHR from service and heating up with normal eves let-down removed from service. Further interviews with dayshift OCC personnel did not indicate that the OCC, as a whole, was cognizant of the MCR staff's concerns related to moving forward with the removal of RHR. The operation's OCC representative had several phone conversations with the shift manager that (b)(7)(C) ut did not recall a specific challenge or concern being communicated related to this propose evolution."

                                 ,~e, FeR 1-UBUe 01 aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY  O1 INVESTIGATION INFORMATION 207 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - O1 INVESTIGATION INFORMATION Conclusion Based on the evidence develo ed during this investi ation, 01 substantiated that !(b)(7)(C) (b)(?)(C) nd b Cl deliberately submitted incomplete and maccura e in orma I0n in a eve eva uation report associated with Condition Report (CR) 1121520 on January 20, 2016. 1 Based on the evidence deve10 ed during this investigation, 01 also substantiated that !(b)(7)(C) I l(b)(?)(C) ~ and !!bJU)/Cl . deliberately provided incomplete and inaccurate information to the NRG during t e February 2, 2016, meeting with the NRC.

                ,~e,= FeR fi'UBLl6 Dl96L69URE 'l'VITI ISUT >'<fi'fi'RS'"'>'<L eF OPEO IAL AOEPdf IPd 0 1IAROE , OFFIOE OF IPd~'EOT IOATIOPdO, REO IOPd 11 6 ffleliltt USE 614 LY       O1 INVESTIGATION INFORMATION 208 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Allegation No. 10 and No. 11 Allegation No. 10: Submission of incomplete and inaccurate information by a Senior TVA Executive to the NRC as documented in the March 23, 2016, Special Review Team Report. Allegation No. 11: Submission of incomplete and inaccurate information by Senior TVA Executives to NRC Senior Executives on March 13, and 15, 2016. Applicable Regulations 10 CFR 50.5: Deliberate Misconduct 10 CFR 50.9: Completeness and Accuracy of Information Documentary Evidence (b)(7)(C) Emai Initial call with TVA OIG (A10-E1) Emai Initial call with TVA OIG Summary (A1 0-E2) Emai (b)(7) SRT Purpose (A 10-E3)

                    *~

Emai (b)(7)(C) (b)(7) ~o l(b)(7)(C) IMeeting discussion points Emai l(b)(7)(C) Iand l(b)(7)(C) IMeeting prep (A10-E5) Emai (b)(7) to ltblCZl(Ql l (FW_ preliminary conclusions)( A 10-E6) (C) Emai message to SRT on minimi zing regulatory engagement (A 10-E7) Emai Final Investigation Report ECP(A10-E8) Emai (b)(7)(C) labout content of SRT report and ECP report (A10-E9) Emai (b)(7)(C) !Difference Reconciliation (A 1O-E10) EmaiI (b)(7)(C) Emergency ARB discussion (A10-E 11) EmaiI 03:09 call with TVA OIG (A10-E12) Emai I Communication to EDO on WBN Path Forward (A10-E13)

Ema,

    .,             Emergency ARB Notesl(b)(?)(C)                  _.....,IR11 EICS (A10-E14)

EmaiI Emergency ARB Summary (A10-E15) Ema,., Emergency ARB Input Form C3-6 (A10-E16) Ema,*1(b)(7)(C) Changes to SRT report (A10-E1 7)

                   ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEC IAL AGDH IPJ 0 1h0tRGE , OFFIOE OF ltWESTIOMI0'4!3, REOleN II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 209 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Email !(b)(7)(C) IChanges to SRT report (A10-E18) Email l(b)(7)(C) ISRT Report R15 sent out by~ (A10-E19) Email!(b)(?)(C) l Rev 21 SRT report (A10-E20) Ol's Analysis: Review of changes to SRT reports Revisions 21 and 22 (A 10-E21) Copy of the SRT report (A 10-E22) Email l(b)(7)(C) l to !(b)(7)(C) l an (~(?) (A 10-E23) Email !{bl(7l(Cl l(b't' r,;: )(7~)(*' C)..._.._......_._ _ _ _,j_ a-nd.,...,,.

                                                          !16""'

ll(bW)7

                                                              )(7"""l/"""c1----1_{A10-E24)
                                                                                                  !(b)(?)(C)  l!(b)(7)(C) I (b)(?)(C)

---

;:::==========-=--------,

Email !(b)(7)(C)

                                                                                 ,.,,..,.,,,,,.,..,,.,...------------,j (A10-E25)

Ito l(b)(7)(C) Email !(b)(l)(C) ~o !(b)(?)(C) jand l(b)(?)(C) IFinal Investigation Report A 10-E26) Email !(b)(7}(C) !Comments on ECP (A 10-E27) Email !.... (b-)(7-)(C_)_ _ _ _ _ _j ECP report about investigation into SVP causing CWE (A10 E28) Email llbJ[lJICJ ISRT report to NRC final approval date (A10-E29) Email _________ to ltb)(?)IC) I revised SRT report (A10-E30) ML16113A228 Response to CEL (A 10-E31) Email!(b)(7)(C) IDiscussion of CWE with !(b)(l)(C) I llb)(?)IC\ Iand llb}(7l/C I (A11-E1) Email!(b)(7)(C) !on call with TVA on CEL (A11 -E2) Email!(b)(?)(C) lon changing SRT in light of CEL (A11 -E3) Copy of the ._l (b__ )(C__) _

                             )(?___        __,l Notes (A11-E4)

Email l(b)(7)(C) !initial thoughts to !rb\17l/Cl I on call with !....(b_)(7_)(C_) _ _....l(A11-ES) Email _ _to llb)(?)IQ) I on message ideas (A11-E6) Email l(b)(7)(C) l !rbl/7l/Cl I email about weekend call with ,,b-1!7 .... -llC_l_l {A 11-E?) Emaill(b)(7)(C) pn change in issuance of CEL (A 11-E8) Email_ j SRT draft report Revision 22 (A11-E9) Copy of llbl/7l/Cl I Notes regarding the call with llbl/D(Cl I on March 15, 2016 (A11-E 10)

                                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                      O1 INVESTIGATION INFORMATION 210 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Testimony Interview of j(b)(7)(C) (b)(7J(C) was interviewed on February 4. 2019. by 0 1, TVA OIG and AUSA ......,__,......_. US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. Regarding the ECP complaint about the work environment at WBNJ(b)(?)(C !suggested that he was familiar that ECP conducted an investigation into a concern (16-00047) that was raised on January 12, 2016. (b)(7) recognized that he met with !/bl/7l(Cl I and other TVA executives to discuss the concern an recalled that he was invited, in part, due to a parallel concern raised to the ECP about a TVA attorney potentially interfering during the 0 1interviews conducted on December 18. 2015. !(b)(7)(C !claimed he was brought in and was ri f on the concerns so that he could provide guidance on the regulatory impact. Additionally (b)(l)(C) had access to resources that he could ask to help facilitate one or either of these investigations~(b)(7)(C) ~aid he wor~ rrange the portion of the investigation related to the chilled work environment issue. ~ relayed that ECP kept him updated by ema il and by telephone on the status of the investigation associated with ECP concern 16-0047 (Exhibit T-62, pp. 43-48). ITbli7ntestified that the ECP investi ation was conducted in a cou le of phases. be inning with ~ led by TVA contractors (b)(l)(C) and (b)(7)(C) & (b)(7)(C) who commenced the initial set of interviews on February 1. 2016. and then moved forward with a broader set of interviews. Accordin to (b)(7)(C) b February 5, 2016. a briefing brought the issue ....._ ________,.,.............*.... b7c and WBN b 7 c th.at there were concerns with the WBN recalled that there were specific issues about the work environment. Although (b)(7)(C doesn*t recall if there were any s12ecifics related to the operations. he stated there were attributions to !lb\(7)/C) I and !(b)m,ci Iwhich became a arent during their first week of the two-week investigation. l(b)(l)(C) I reported that ~ & (b)(l)(C) prepared a series of drafts which were issued on March 1. 201 ~ r ECP prepared their own executive summary. !(b)(7)(C) !suggested that while ECP was finalizing their summary, there were some revisions made to the original investi ative report. The investigation identified that there was a concern with !lbl{l)(Cl I and ,..b.....7 c.____. relative to the work environment. !(b)(?)(C) !explained that there were a number of conversations with ECP from the beginning of the investigation all the way until the ECP report and the SRT report were sent to the NRC on March 24, 2016 (b)(?)(C) recognized that ECP was have difficulty with some characterizations of the issues and that P needed to be independent in their conclusions about !rb}/7lfQl I and lrb\17)/Q\ I and th

• work environment. In fact, the SRT was pending on the completion of ECP report, and (b)(?) xplained that he would perirodically inquire when the ECP report was to be completed. (C) stated that he had conversations with ECP and ECP was aware that there was some internal debate about the phrasing of the conclusions (Exhibit T-62. pp. 49-54).

Durin the interview (b)(?)(C) resented with an email dated (b)(7)(C) sent to r::(b-:-:)(,;;- 7)~ (C~) - - - - - \ . . ._ ___,J_ __.__ _ _ _ I

                                                                             --,and !(b)(7)(C) w__h__e__r...,

e'"'"(b-)(7_) ___w- ro_. te. "in reference

                                            ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJO, REOIOPJ II 6 f'f'le l,-L U9!! 614LY      OI INVESTIGATION INFORMATION 211 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION to a question the NRC would never ask, did they (NRC) give us (TVA) the Unit 2 license before we were ready to run the second unit." l(b)(7)(C !said that throughout the course of the past eight years, TVA has been working on completing WBN2 and during TVA's interactions with NRC regional, headquarters and commissioners it has been communicated that the completion of WBN2 was a "big deal" for TVA to demonstrate that WBN2 could be completed safely and start up. Likewise, it was a "big deal" to the NRC that they could actually complete the licensing in a timely manner. l(b)(7) Iopined that the license was issued on October 22, 2015, and that was the day or day after the source range issue was identified where [(tiW}'7commented to !(bl/7\[Cl I that he should notify the Region about the discovery of the event(Exfiil5it T-62, pp.63-66). !(b)(?) !stated that the NRC made the decision to issue the operating license and the NRC would not come out and say, "We (NRC) think we shouldn't have given you (TVA) a license." Instead, the NRC will remain in process and if the NRC has concerns about the ability of the MCR or a chilled work environment, then the NRC will use their allegation and/or investigation process. !(b)(?)(C !stressed that the NRC has all the "tools" it needs to get at a concern about whether TVA was ready to operate WBN2 . (b)(7) cknowledged that he led the SRT and the SRT was chartered during a meeting on e ruary 5, 2016, that discussed emergent concerns at WBN. Subsequently, on February 6 , 2016, lrb2l?}IC} I drafted an action plan on how to address the emer ent concerns as noted from th (bJ(7)(CJ i[bl(?)(Cl I investigation briefing. According to (b)(?) the purpose was to establish a ,me me for completing the ECP investigation report, establish themes from TVA-OIG inve i i n, evaluate historical results, and establish leadership and organizational focus. (b)(?)(C) confirmed that !(bl(7)(Cl I action Ian was formulated on February 6, 2016, and the SRT was c artered on February 26, 2016. (b)(7)(C) claimed that by February 29, 2016, the NRC was aware that the SRT was being put to ether. Specifically, [(EWi7revealed that during a meeting at WBN, TVA shared with NRC's (b)(7)(C) hat a team

~          was being assembled (Exhibit T-62, pp. 67-73).

Accordin to~ he recalled a conversation with!(b)(7)(C) Iand from his notes recalled that (b)(?)(C) expressed his thoughts, "TVA-OIG phone call to talk to NRC staff, 01 did not et sati

• more stuff." Subsequent to that conversation, on February 23, 2016, (b)(7)( spoke with (b)(?)(C) where he shared that TVA-OIG did contact 01 and there was a call between TVA-OIG, 0 1, EICS and OE which appeared to emphasize how did TVA-OIG challenge TVA management with the issues (ECP and potential concerns about work environment). During the discussion (b)(7)(C) disclosed that he was visiting WBN which lead to a sens~ ificant confusion 15emg in roduced and will need some additional focus to sort out. ~ discussed that once TVA took on board the underl ing concern, then TVA would figure out how to address the work environment issue. In (b)(7)(C) opinion, TVA was not confused but needed clarification of exactly what the ~ n was and who at the NRC understood what it was. To that end, on February 25, 2016, ~ stated that he had a conversation with (b)(7)(C) who shared that TVA OIG, and 0 1 had communicated some concerns to the NRC about TVA. (b)(7)(C said that .-l (b--,

                                                                                                         )(7,-
                                                                                                             )(C
                                                                                                               .,,_)--,

indicated that there were concerns beyond the normal Reactor Oversight Pro ram (ROP} green and white findings that TVA was going to have to speak too. According to (b)(7)(C he took from this interaction there were conversations occurring within the NRC on how to manage the concerns within allegation space (Exhibit T-62, pp. 74-76).

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPEOIAL AOEPH IPJ 0 1h0tROE , OFFIOE OF IPWESTIOMIOPJO, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     OI INVESTIGATION INFORMATION 212 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A t's Note: The testimony quoted above is, in part, recalled from personal notes that referenced during questioning. Copies of tlhose notes were not provided to the uring the interview.

~                stated then there was a comment from !(bJ(7HC) ! "you guys (TVA) want to pull rods, how do you get there?" Rlwnrecalled that it referred to the actual start-up of WBN2 which at the time was loaded withfi:i"er"'but not started up and that l<blf7XC) I had expressed his concern that if TVA had this problem between senior management and shift operators, how was TVA going to get through that so WBN2 can o erate safel and reliabl . Converse! on Februar 25 2016 durin a meetin between (b)(7J(C) b7c                                                                                  and (b)(7)(C they came to the decision to assemble an "independent t: am" whose talent could guide and pull TVA together to clear TVA from the issue. According to~b)(7)(C)                              ~ecognized TVA had a challenge at the site with regards to senior leadership, all the way down to the MCR. Moreover, this was not having the normal NRC oversight, which TVA would be aware of stemming back to Ol's interviews in December 2015 which were also getting some traction with the TVA-Board of Directors. Somehow TVA needed additional focus to come up with a plan to address "whatever" the issue were. i(b)(7) !stated that he had a conversation with llb)(7}/Q) I about who would lead the Special Review Team (SRT), and to the extent that there were underlying concerns about the senior executives on the site. According to !(b)(l)(C)                             !suggested that it sounded like a role fo (b)(7)(C                    f r              r                                o i* w "firmed u " which included                   (C)

(b)(l)(C) nd others (NFI). From there, (b)(7)( escn e ow e was organize an ow (b)(7)(C) sketched out the team and a problem statement that read, "Do we have a chilled wo en ironment in operations or on the site." ~ testified that from his point of view this would take a series of inputs to draw a conclusion on that problem statement. This included: inputs from ECP; any information obtained from TVA-OIG; work that WBN already had done at that point; RCA of the November 11 , 2015 event; information from INPO; and personnel statements obtained at that point (Exhibit T-62, pp. 76-87). ~ testified that the intention of the SRT was for the review not to be a supplemental investigation, as there were already ones being performed by ECP and TVA OIG. Also, the ,.....,....,.....,as not to be an interview-based campaign, but rather a review from a site's perspective. (b)(?)(C) xplained that in terms of organizing the activity, on February 26, 2015, TVA had !(b)(7)(C) come up and be briefed in !/b)(7l(Cl l office.!(b)(l)(C) !described that a "bubble" chart illustrated to l!bl!7HC! how the SRT was approaching the issues. Although!(b)(7) ldid nl/t :R~nf a lot of time with libll7HC I oing over the chart, the approach was indeed conveyed to b 7 c After the meeting, (b)(7)(C stated that he sat down with the SRT members and brought them up to speed on the reason they were there. !(b)(l)(C) !stated the reason was to review a series of inputs and to draw a conclusion about the chilled work environment. Regarding or anizing the work, the SRT report is structured into sections of bins of information. According to (b)(7) the SRT members fed their information directly to l(b)(7)(C) Iagreed that he certainly had a lot of work with those inputs from the standpoint of having different authors. l(lii17)lsaid he was mindful not to have the report look like it was written by different people an~ sure that the report "spoke

                              ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     OI INVESTIGATION INFORMATION 213 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION with consistency." l'ftiWllargued that he would have commented back on issues of consistency of expression, suc~ ny and all" when it was really "some and a few." This work was being developed up until the week of March 4 , 2016 (Exhibit T-62, pp. 87-92).

~~~he interview, (b)(7) was asked if the SRT members were aware that (b)(7)(C)                                     blamed (b)(7)(C responded, "I do not know." (b)(7)(C) rgued that he likely would no ave, could have a degree of independence an come to their own conclusion. (b)(7)(C said that by I° (b)(7)(C) and IIJol.ll..1..11.W"-----' and if that information had been conveyed to (b)(?)(C) in their meeting, I           that they March 11, 2016 the N RC had decided to issue th-.,__- ..w.a.,.,., the conclusions of this team were largely mute. (b)(7)(C) stated the he doesn't know if (b)(l)(C)                                  I told !{b)(7)(C) that !(b)(7)(C)   Ihad I

informed the NRC (b)(7)(C) that !(b)(7)(C) was responsible for the situation. Furthermore, ..,,.(b"""' )(7""'J("c) stated that he was not aw~ y specific changes made to the SRT final conclusions wit ou the members' awareness. ~ suggested that he did not know when the ECP report was finalized, but believed the report was completed in late March 2016. When asked if the SRT members were aware that their work was ultimately going to be provided to the NRC, (b)(7)(C) claimed that until March 6, 2016, he did not know that the SRT report would be provide o e NRC, until the NRC requested a copy of the SRT report. Nevertheless, !(b)(7)(C !suggested that the SRT members were experienced enough to understand that the SRT report could be subject to NRC inspections. ll'EWnclaimed that despite having the inputs, part of the tasking of the SRT would have been to 'norori'ly answer the question, "Is there a chille..,_..............., environment?" but also propose actions to address whatever was identified. (b)(?)(C) suggested that possible actions could range from communication and training to changing ou people and positions. !(b)(7)(C) !stated that one of the in~ the SRT was the completed ECP rel ~rt, l hich was not completed until ~ arch 20, 2016. (b)(?) admitted that he often engaged with lbll 7l !{b)(l)(C) J about the progress o he ECP report (Exhibit T-62, pp. 94-106). ~ stressed that keeping ECP independent, such that !ibl(7l(Cl !was not under the direction from the SRT to alter the ECP report, was obviously important to the health of the ECP. When asked if~ knew of any efforts to link the reports and their findings together as to comparing them in'cl'ra1rrorm to ensure the reports lined up,rowi7 res onded, "No, there was no effort to make .. .to get her (ECP) report line up with an y concl'u"sTo'n I ( (b)(7) wanted to draw." !(b)(7) ~estified, 'That did not occur, when she !(b)(7)(C) Icompeted the ECP report and settled on the degraded term there were no ind ication of changes other than word terminology." b (7 C stated that on Rb)(7)(C) l there was a teleconference with !/bl{Z)/Cl I at the request of (b)(7 (C) ~RC Rli and j(b\UHc l for the RUr ose of informing !ib)UlfQ) I (TVA) that the NRC had decided to issue a CEL. According to (b)(?)(C) did not give TVA the date that the CEL was going to issued, but 'li!!:!:!=::!!::li!::!::::5..'and b did reveal in detail the basis for taking action relative to concerns. Likewise, (b)(?)(C) suggested that the CEL was being issued because the NRC had sufficient evidence o a significantly degraded work environment (Exhibit T-62, pp. 108-110). testified that !/bl/7}(Cl I and !(bl(7}(C! had discussed with them that the NRC had "binned" u,i.;.\-.,.1 in ervIews, which caused them to discuss an extensive list of comments attributed to the people who were interviewed. Furthermore. !tblIT}IQ) I and (b)(?)(C) iscussed that the bins dealt with management's direction of operations including commen *s that the OCC was directing the shift

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          OI INVESTIGATION INFORMATION 214 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION managers. They also mentioned a concern relative to production over safety and that management was trying to "skim" over the rules. Lastl , there were comments relative to the "willingness to raise concerns" for fear of retaliation. (b)(7) commented that the discussion in essence provided the rationale for issuing the CEL. (C) estified that an issuance date was not disclosed to TVA durin this meeting which led to a series of conversations about the CEL. f(ii'iITTflstated that he and id not challenge the basis of the CEL as described by ~ anci l!b\(7}/Ql I Further, (b)(7) testified that on March 12, 2016, he provided ilb}(7l(Cl I information about the framing o a 1scussion with llbl/7l/C} l about the timing of the CEL issuance and advice on possible leadership changes at WBN. !(b)(7)(C) !recognized that the NRC process acknowledges the degree to which TVA accepts that there is a chilling effect as a factor on whether or not to issue a CEL. !(b)(7)(C !stated that the NRC has discretion relative to issuance and timing of the matter and TVA is allowed to attempt to persuade the NRC that they actually understand the breadth of the concern. (b)(7)(C) rticulated that his input to !rbl/7}/C} I was about the leadership changes that, if TVA ma e mIg t suggest to the NRC that TVA actually grasped the concerns (Exhibit T-62, pp. 111-113). @ml w;:is asked who decided to call (b)(7)(C) ~ and I decided together." I on Sunday, March 13, 2016, w \(7) responded, Converse y, b 7 c as questioned as tot e reason for contacting llb}l7l/C} I after already having discussed the matter with (b)(?)(C) responded, "It is not out of the role of the CNO to have a relationship with (b)(7 (C) .. it is part of his job scope." Under questioning, !(b)(7) ~tated, "The purpose for the telephone call was to look at the timing of the CEL and to allow TVA to make leadership changes in an orderly fashion which reinforced both underlying issues related to workforce concerns and the chilled work environment." Additionally, ~ indicated that the purpose of the telephone call was also to communicate WBN performance issues, which had shown a series of challenges, so the timing of TVA taking actions did not look like TVA was "firing" people because the NRC told us to and had issued a CEL. (b)(7)(C) stated that was a sensitive point of view for both the industry and the NRCJ(b)(7)(C) !explained t at during a telephone call with the NRC, TVA informed the NRC that they would do all that's required but requested for TVA to take action first. ITEwn acknowledged that he and lrbl/7}/C} I had already established that lrbll7l(Cl I was problematit'ounhat fact was not communicated to !lbl/7l!C} I When asked if!(b)(7)(C !normally gives advice on how to handle the (b)(7)(C) responded, "Normally no, it is in my job scoQ_e to do that though." b 7 c asserted that the information he provided llb}(7}/Cl Ito convey to l1fur1irc1 I was that ......,........,........, was not surprised by NRC's conclusions because two independent TVA internal reports (ECP and SRT) had also reached the same conclusion. Likewise, a similar communication was made to l!b}l7}(C) Iand !(bl(?HC !that the TVA reports had reached the same conclusion and it was also communicated to l!bl(?}(C} I that TVA was not arguing the conclusion whether it was the right regulatory action (Exhibit T-62, pp.114-124). ~ explained that TVA requested a delay of 30 days from irbJr7llQl I to allow the leadership changes which ilb)IZ)(C) I denied. b 7 c acknowledged that there were no adverse changes (actions) related to management. (b)(?)(C) recommendation to llbl/7}/Cl I about !lbl/7}/Cl I was not accepted by i!bl(7)/C\ J Specifically, (b)(7)(C indicated that his advice to b c o March 12, 2016, and on March 17, 2016, to b C !lbl(7)/Cl l and (b)(?)(C) was about trying to figure out the right "thing to do" for the site as the site was transitioning from a single to

                                ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 215 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION two units. Although l~~,(7) ~ id not argue with !(b)f7)(C) I about !(b)f7)fC) I promotion, he now recognizes it was perhaps a missed opportunity to do the right thing versus doing the thin that would have been a bit more to the point of what TVA was communicating to the NRC. (b)(?)(C) provided ~ t to the TVA executives and asserted that it was their decision to leave b 7 c in place. ~ was asked if there were any changes made to the SRT report between March 23, 2016, when !lb)/7\!C) I was told that she would receive a co of the SRT report and when the SRT report was mailed to !rb)(Z)(C) Ion March 24, 2016. (b)(?)(C) responded, "A change to get the clarity relative to the consistent usage of degraded may have occurred after the public meeting, if there were other changes, I do not recall what those were." !{b)(?)(C) !stressed that when the SRT report was mailed it entered the NRC's process and suggested that when TVA announced at the public meeting that the SRT report was finished, the SRT report was finished to the extent of needing some "clean-ups" (Exhibit T-62, pp. 126-135). ~ argued that the changes to the SRT report were similar to any other licensing document, ~ are changes from one revision to another, you make clear that you archive the revision on a certain date. (b)(7) implied that he had not been managing the SRT report in that manner. Furthermore, (b}(7)(C stated that at the time of the public meeting, the SRT report was finished and upon returning to TVA's office in Chattanoo~ , there were some changes which !(b)(?)(C) I "felt" were appropriate to make. When asked if ~ instructed anyone to archive the changes after the public meeting,!(b)(?)(C !responded, "I do not recall with specifics once it is si ned ... I let the administrative staff manage the entry into BSL (TVA document system)." (b)(7)(C) contends that he had no idea on how the BSL process works relative to archiving revisions to documents. Also, (b)(?)(C) oted that he left that task to his administrative staff to address and for them to make e necessary entries into BSL. ~ was asked if he ever communicated to the SRT team that the purpose of the SRT was ~ ent additional regulatory actions, (b)(7)(C) responded, "I do not recall telling them that was the purpose" (Exhibit T-62, pp. 7- 0). !(b)(?) !testified that during the February 29, 2016, meeting with!(b}(?)(C) !wanted to know more information about overall plant performance and certainly about the circumstances of November 11, 2015 event. When asked what b 7 did at that oint to ensure that the findings were accurately communicated to the NRC, (b)(7) responded, (b)(7)(C discussed in terms of communications, through my SRT report, to my way of looking at it, in the context of how all the other conversations I had with senior leaders, and I make reference I think it is in gaps that there were concerns attributed to the site senior leaders that was a communication that we were acknowledging that there is a problem at the site front office. When challenged during th...,____ interview that the reference was "pretty" vague, !(b)(f) lsaid, "To an outsider, absolutely." (b)(?)(C) professed that the SRT report was an internal report that would potentially have been reviewed b the NRC and the purpose was not fundamentally a communication vehicle to the NRC." (b)(7)( stressed that when he presented his recommendations to !(b)f7\(C) I related to !(b)(7}(C) and (b)(?)(C) suggested that he had no concerns that he had not been clear to It -62, p. 142). did not recommend terminati b C he acknowledged the ~Ian was to move i>i!b~ 7 ~c::::;~ to a senior site osition. Also, (b)(?) said he recommended that i(b}(7)/C} I he transferred from the site. (b)(7)(C) xplained that the ECP concerns were raised on

                        ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 216 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION January 12, 2016, and the first interviews occurred on February 1, 2016, and the planning for the February 2, 2016, drop-in meeting would have had its "roots" somewhere between January 6, 2016, and February 2, 2016. (bl(7)(C) indicated that the senior executives were aware of the ECP concerns, and it was proper for b 7 c and !lb}(7}(C} Ito address issues to the NRC about their site. Although TVA concluded from the ECP investigation that there was information that l/b\/7)/Q) I and Ub)UJ(Q) I were the foundation of the chilled work enviro.~ ~... !(b)(l) !denied that !(bl/7)/Cl I and !lb)(71(C} I had provided false information to the NRC. (b)(7)(C) testified that he never had the view that the OCC had a role or that individuals were covering up for anything (Exhibit T-62, pp. 143-147). !(b)(ll !explained that !(bl/7}/Cl I had alread disclosed the ersonnel moves he wanted to make regarding b c (b)(7)(C) and (b)(7)(C) who were the (b)(7)(C) on t e site. (b)(7) s a e a some o commen s o ............................ in support of retaining w.:..u...i..::.:.1.....1 would send a essage about performance improvement and expressed that accountability remained a priority. Also, having a !ibl0/Cl l at WBN with improved people skills would send a strong message that a healthy work environment is a I pr iority. Additionally,!(b)(7)(C stated that his comments regarding !(b)(7)(C) I was for [bl/7)/Q I to be reassigned to the corporate office in a general mana er osition which was probably necessary for coaching with a corporate executive mentor. (b)(7)(C) stressed that the change would also send a strong mes~ the WBN employees that TVA would not tolerate sub-standard management behaviors. (b)(7)(C) suggested the reassignments of !lb)(Z)/C\ I and

!(bl(7)(Cl      l were not viewed as adverse emp oyment actiion. When asked if ~                                             did anything between February 29, 2016, and March 12, 2016, to determine whether or not the information that !/b)(Z)[C) I and !lb)(?l/Ql                 I had provided the NRC on February 2, 2016, was false, (b)(7)(C) res onded, "I did not, in large part because I was focused on getting the SRT work organize ."

(b)(7)(C offered that if that question was posed, he I/bl(?)/C) I would have gone back and reflected on whether the slides communicated what came out of the apparent cause. !(b)(7)(C) stated that I his involvement on the creation of the apparent cause and root cause were limited, as!(b)(7)(C lis a consumer of that information. (b)(7)(C) testified that l(b)(?)(Cl I or !lbl(?)/Cl I never acknowled ed to!(b)(7)(C !that they a made a false statement to the NRC on February 2, 2016. Likewise, (b)(7)(C stated that he never asked them if they had provided false information (Exhibit T-62, pp. 149-160). Interview of!(b)(7)(C)

!(b)(7)(C)                                                                                                             !was interviewed on March                     8, 2017, by TVA OIG wherein he provided the following information in substance.

l/b}U)IQ) I was a member of the SRT. When discussing the SRT, l/bl/7)/Cl I described the purpose of the SRT was to "pull" together the facts and deliverables which would be reported out. !lb\(7)/Cl I said he struggled with the outcome butl(b)(7) lhad a vision about what he wanted to

• he SRT report llb)U)fQl I stated that each team member worked on a "piece" but (b)(7)(C) was the final editor on the SRT report. The SRT report was used rnwe as a feeder into the March meeting with the NRC. It was used to develop a PowerPoint for (b)(7)(C)

                                  ,~e, FeR 1-UBUe 01aeteaURE WITI                   1eu,  )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY        QI INVESTIGATION INFORMATION 217 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION to use for the NRC. !(b}(?l/C} I stated that at this point WBN management knew that WBN would be getting a chilled work environment letter (CWEL)(Exhibit T-63).

  !lb}(l)(C}     I believes the ECP report was an addendum to the SRT report. According to
  !(b)(7)(C)      l the ECP re art went throu h a number of different revisions. !(bl(7lrCl                       I stated that he knows the (b)(7) C)                                                was gettin~ unbelievable pressure from
  !(b)(?)(C)         ! to "word engineer" the report. b 7 c                        told 1$1(7\IC}      Ithat she was getting pressure to make changes, but she did not SP.ecif who was pressuring her. However, it was apparent to hi, that she j as gr:~i_ng r shed by (b)(?)(C)                            as well as others. He knows that she spoke with l(b)(?)(C)            _ and (bJ(7) as well (Exhibit T-63).

ilh)Ql{Q) I stated that i/h\(7\/C) I original re~ort r laced the blame on b C but it was

  ~ so that !(b)/7l(C) ! role was downplaY.ed. lrti m,c                             ! believes (b)(7)(C)       is wh l!lillZlLQU has frotten throu h thi                 use he d(b)(?)(C)       I really wanted to shield b c According to b)(7)(C)             I (b)(?)(C)       never felt like it was an issue with management but rather that this whole issue was because of one guy (Exhibit T-63).

ilh\17)/Ql I was aware that Hb)/7)/Q) I read the ECP report before it was final. ilblU}IQ) I stated

  !(blf7)(Cl I was like a "loose cannon" and he (b)(7)(C)                kept asking to see the Phase I and Phase II (b)(?)(C) nd l1bl(7}(C}        I ECP investigations. b                     believes that !lbl/7\(C}             I may have sen           , everythin~ , but he is not sure. Regardless, lrh)(Z)IQJ                    I stated that ilblW/Cl I got a copy (Exhibit T-63). lrbrn(C)               I was asked about whether there was a difference in the ECP report and the SRT report. He stated the original ECP report was more accurat'f-'i!Ju.w..i"'Wl.ltained significantly more information and documentation due to the interviews w hereas (b)(?)(CJ SRT )

conclusions were "really watered down." However, lrbl(?l/Cl I stated that, although the ECP report was allegedly finalized by the first week of March 2016, there was a lot of "word engineerinr on the ECP report in the last two weeks before the March 22, 2016, meeting with the NRC. _b\{7)(Cl I was concerned all along that they would get to the NRC and the reports would not be aligned (Exhibit T-63). Interview of l(b)(7)(C)

  !(b)(7)(C)                                                                             I was interviewed on January 11 , 2019, by TVA OIG wherein she provided the following information in substance.

According to l(b)(7)(C) l (b)(?)(C) assigned ilb)/7\IQ) Ito the SRT at the last minute. explained that she was asked to be on the SRT due to !rbl/7j(Cl I role. !lblr7l(Cl I advised t hat the SRT divided up the work.

  !rbl/7l<Cl      I was told that HR had to be on the team, so !(bl(7}/Cl                    Iwas put on the team.

ilb)U)IQ) I role on the SRT was to look for "clues" from 2014 to the present time to determine if there were any trends that indicated when the culture at WBN turned "south." !(bl/7l(C) I reviewed all available data, including the 2C meetings. !(bl(?)(Cl Iadvised that Operations did not have any. According to l(b)0(C) I she reviewed the data, and then documented the positives and negatives represented by the data from her reviews (Exhibit T-66).

                          ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY            01 INVESTIGATION INFORMATION 218 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION Agent's note: "2C" meetings (Compliments and Concerns) allow site management to discuss important messages with and receive in-person feedback from employees. !lbl(l)(Cl Iexplained that the SRT was only focused on the negatives, which bothered 1/bl(l)(C\ l Accordin to b 7 c the SRT wanted to frame l/b\(7lfC\ lfor what was going on. In addition, advised that she felt like the SRT was set up to blame it all on !lb}U){C} I ilb\/7}(C) I stated, "I did not want to sign the report at the end." In addition, l(blf7\fCl Icommented "I was pressured to sign it" and believed that the SRT had an agenda. !(bl(l)!Cl Iadvised that they were only looking to prove !lblmrc1 I did it. She did not want to sign the report because she did not believe in the methodology used to generate the report. Accordin to b 7 c toward the end of the SRT after the CEL was issued, l(b)(7)(C) I told c that b c I had a Ian to promote !(b)(7)(C) and this would hel~ save face for ilb)(7}fQl I ......._.........._.____. advised tha (b)(7)(C) told her that the plan to promotP. lrt>J/7\ l I was "brilliant." (Exhibit T-66) !ib}/7\(C\ Iexplained that she was not pre~ared at all to be on the SRT. One mornin - in____..., February 2016 at approximate! 7:45 a.m., lili\(7)(C\ lreceived a telephone call from (b)(7)(C) !(b\!7\(C\ Iadvised that (bJ(7)(CJ told her that (b)(7)(C) was going to be at a meeting at WBN for the SRT committee. ..................___, advised tha ibJ{7XC) old her to drop everything and to get to the SRT meeting at WBN because there neede o ea HR presence. At this SRT meeting, !(bl(l)(C\ lrecalled !(b)(7)(C) !was drawing bubbles on a board. !(bl(7)/Cl I8dvised that she thought the SRT product was an internal product for TVA. In addition, !lbl(f)(C\ Iexplained that she thought it was for !(b\[7)(C\ I According to !(bl(7J(C) I the purpose of the SRT was to see if there was only a CWE in Operations at WBN or if all of WBN had a CWE issue (Exhibit T-66). !rb}/7\IC} Icommented that she questioned and was bothered by the thought process and methodology of the SRT. l(b)(7)/C) l advised that the SRT had a hypothesis, and then the SRT would just try to find data to prove its hypothesis. According to K@7)(C) I the SRT's hypothesis was that ilb}U)(C} I was at fault, and he is the one to blame. According to (b (7)(C) wrote the SRT report and would totally change the meaning of certain things. In addition, b exR_lained that ~ would "cherr " ick what to include in the report, and he would "spin stuff." ld;im1c) Icommented that (b)(7) anted to blame l{b)(7l(C) I and l(bl(7l(Cl Icame to this conclusion based on what (b)(7) was writing in the SRT report (Exhibit T-66). Interview of l(b)(7)(C) !(b)(7)(C) I was interviewed on June 28, 2016, by TVA OIG wherein he provided the following information in substance. (b) !lb\17\(C} Istated he has been involved with the nuclear business for almost ,n ears. He retired from the NRC (b)(7)(C) b c They focused on the 2015 timeframe because this is when the precursors/drivers of the chilled work environment began occurring. He als0j....(b_)(_ 7)(_C_) _ _

                      ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY             OI INVESTIGATION INFORMATION 219 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION l(b)(?)(C) lwhen they had a lot of work environment issues in Construction. There were also some issues in operations in 2015 which lead to his involvement with the SRT (Exhibit T-64 ). According to !(b)(?)(C) l the SRT was created because there were concerns from ECP and the TVA OIG related to the operations department, and TVA wanted to understand what occurred. l(b)(7)(C) lsaid the SRT began the review to avoid receiving a CEL from the NRC, however, within three weeks they realized that the NRC had already obtained the data (about problems in operations). Once TVA realized the NRC was stepping in, they elevated the process to an RCA in order to determine the root cause. !(blmrc} Isaid once they started digging, they realized it was not limited to operations but was in other areas as well. lf~\(7)/Ql I stated he did not agree with everything in the SRT report and the RCA. He also stated there were confirmed problems within the operations, but they did not realize how big they were (Exhibit T-64). Interview of l(b)(l)(C) l(b)(7)(C) lwas interviewed on May 5, 2017, by TVA OIG wherein she provided the following information in substance. l(b)(l)(C) ~tated that "no one in management pushed her or interfered on the ECP report." She was asked if she knew of any TVA investigation or report that was conducted to determine if an~ form of retaliation took place at WBN , ~b)(?)(C} Iresponded, she knew that fbl(7) and li6im1c1 I had looked into it because their investigation "bumped into" that issue. b 7 c stated that the scope of their investigation was not to look into retaliation but to look into one specific allegation that ECP received about a chilled work environment. She added that she knows of no TVA investigation that was done that looked solely into whether or not retaliation had occurred at WBN. !(b[7}/C) Itold the investigators that her understanding of the purpose of the SRT was that it was to take action based off the findings of the ECP report (Exhibit T-61 ). Interview of ...l(b_)(_7l(_c_) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____.

!(b)(7J(CJ                                                                    l was interviewed on May 11, 2016, by TVA OIG wherein he provided the following information in substance.

has been workin at TVA for about l(b)(7)(C) l Although r b)(?)(C) I he has pretty much traveled among the different nuclear sIt es wor mg on various mspec I0n escalations since he started with TVA. Before coming to TVA, !(b}(7)(Cl I worked as an l(b)(l)(C) l  !(blUHCl I stated that management had interfered with the SRT report. It is his understanding that it was changed a day or two before it was finalized. He stated the change was not 180 degrees but rather around 80 to 90 degrees. He is aware of this due to discussions with people who were on the team who were "pissed" at the changes and managements' interference (Exhibit T-65).

                            ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     OI INVESTIGATION INFORMATION 220 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION According to !(b)(7)(C) I TVA management will not change their position about what happened at WBN no matter what evidence the TVA OIG presented. He stated, "do not annoy the pig" and insinuated it is much like a survival Mode. !lb)R\/C) I stated that TVA management believes the TVA OIG wants "retribution." In regard to retaliation, ... l(b-lCZ-l/-Cl___l recalled being told that the TVA OGC had said that if any part (even one thing out of a hundred) were true then the court could hold them liable for all of it and they would have to pay out money. As a result, !(bl/7)/Cl I believes the TVA OGC was pushing not to have anyone admit anything (Exhibit T-65). Interview of l(b}(7)(C) l(b)(?)(C) I was interviewed on January 8, 2019, by 0 1and TVA OIG wherein he provided the following information in substance. i(blCZl[Ql Iwas provided two e-mail strings concerning the archiving of the SRT report before sending to the NRC. After reading this email string, !/blCZl[Cl Iwas asked if it is a common practice in TVA Licensing to "fiddle" j;t~ ~~llrt dates in TVA's document system. ilbl{?)/C\ I stated that it was not common at all. b 7 c was asked if it was normal in Licensing at TVA to change rellli~;~,~~lisions to match what TVA tells the NRC . i[bl(l)(C} I said it was not a common practice. said that he made the change as Rbirninstructed. He added that he was only doing as he was instructed. ![bl/7l[Cl Isaid that t'Fiarwas the first and only time he did anything like that. !rbl/7l[Cl Idiscussed that at the time of this email i/b}(7l1Cl Idid not read the email carefully enough. kb)(7}/Q) I said that he did not think he was the person that did the final archiving of the report (Exhibit T-74 ). Interview of!(b)(?)(C) INuclear Regulatory Commission l(b)(7)(C) INRC was interviewed by OIG and AUSA l (b)(7)(C) I US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance.

          ..,..,..--,--.,,,..,...-....,,...-,....-- and replaced (b)(?)(C)                                               Due to Brown s erry Nucl ear Plant Column IV status, b 7 c                                  was in the habit of meeting or speaking by telephone with (b)(?)(C)                     on a monthly basis, if not more frequently, and continued this practice with
           ..................._. to discuss Browns Ferry performance (Exhibit T-53).

When questio m 1f he knew ,,.,. (b.,..,

                                                                )(?""")('"'"

C), -------,stated that he has known.... (b....

                                                                                                                                   )(?-)(....,.

C).... or (b)(7)(C) a .. rox4matef * *** *

• ears. b c was an NRC employee and i(bl(7)/C\ I wor e closel with (b)(7)(C when b 7 was at Region II. (b)(?)(C) current! (b)(?)(C) b7c (b)(?J(C) is currently the TVA VP for Licensing and Regulatory Affairs. While workin at t e ,!(b)(7)(C) ~ id oversee TVA's restart process at Browns Ferry Unit 1. During (b)(7)(C) final two years with the NRC,RSWnwas the Director of the Fuel Facility Inspection Division at NRC Region II. lrb)(Z}(Q} Irl~ believe that~ had interactions/activities with TVA during those last two years at the NRC, and

                                           ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF aP  G l :O.la .A/e  ~IT l~I GH.A.pil'51ia , gfiiifiii l G  gfiii I W,< aT I C.A.:: 1 g~1., pillia'51g~1 II 6 f'f'le l,-L U9!! 614LY                OI INVESTIGATION INFORMATION 221 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION lrb}/7}/C} l does not believe there is any conflict with ~ moving from the NRC to TVA (Exhibit T-53). Whe tioned about stated (b)(?)(CJ at WBN and came from ~ -t'i:i77iir~-------~:------:~~~...--:---:-::-;;:::-:::-:--~:--:-:-:---:---'and before that was 7)(C) brought Wol.ll..!~_. to WBN, probably due to his track record/success in previous roles and extensive nuclear experience with other utilities and sites. When asked about !(b)(7)(C) I llb}/7}/C} l related he did not have much interaction wit h him. l!b}/7}/C\ I knew he was the WBN!(b)(?)(C) I l(b)(7)!C} I stated he did not have any discussions with llbl<7}/Cl I regarding llb}/7\!Cl Ior l!bl(?)!Cl I performance (Exhibit T-53). !rb}U}!C) I was asked about TVA's progress toward implementing the fleet wide Confirmatory Order which had been issued by the NRC to TVA in 2009. llb}<7}/Cl I was asked specifically about implementation of steps to prevent retaliatory employment actions at WBN circa 2014-2016. l/bl/71/Cl I stated that he could not recall specific details about TVA's efforts to comply with and implement the Confirmatory Order. lrbi/7HC} I stated that targeted NRC inspections during the 2014-2016 timeframe should have checked for problems regarding the Confirmato!}'. Order, and if any problems were spotted, then the NRC should have addressed them. llb}(7}icl I stated that the NRC would not have issued an operating license to WBN2 if the NRC had not felt comfortable that the Confirmatory Order was implemented. It is plausible to have open items and issue the licensee, as long as the licensee is addressing the open matters and there is progress to complete the work. l/bl{7)/Cl I stated that the license was issued for WBN2 which means that the NRC felt that TVA actions met the threshold to operate the plant safely. The standard is "reasonable assurance of adequate protection" to operate the plant safely. l/b}/7)/C) I conceded that the NRC was aware that WBN needed to improve the overall safety culture, but the NRC felt that TVA met the threshold necessary to issue an operating license for WBN2. l(b\(7)/Cl I stated that the NRC labored with this question and discussed whether to issue t he operating license. l/b)/7)/Cl I stated that the NRC does rely on TVA's responses to RFl's (Request for Information) and other statements made by the licensee but that the NRC also conducts its independent analysis and data gathering to make its decisions (Exhibit T-53). l/bl{7)(C} l was asked about a telephone conversation between himself and ~ and l(bl(l)(Cl I on (b)(?)(C) Initially, l/b}(7}/C} l claimed not to recall any conversation around that time. ~~==: state that TVA never asked him to intervene and delay the issuance of the CEL. lrbl{7)/Cl I was asked specifically whether he took any actions in regard to the issuance of the CEL and l!b}(7)!Cl I denied taking any such actions. Fb}(l)(Cl I denied asking anyone to delay, refrain edit or otherwise change their planned course of action. llb)U}!C} I was shown an e-mail from (b)(7)(C) dated!(b)(7){C) I which stated that the Region II staff intended to issue the CEL on arch 15, 2017. !rb1(7}/Cl I was asked if he knew why the CEL letter was not issued until after the public meeting which was held on March 22, 2017. llb\(7)/C} I stated he had no knowledge about any reasons for delay. Later in the interview, l!bl/7}!Cl Idid recall one or more unspecified conversations with l/b}(?)(Cl l where the CEL was discussed. l/bl(7}/C} I then recalled that l<bl!7}/Cl I had intimated that a delay in issuance of the CEL would assist TVA because TVA was planning to make personnel changes in the leadership at WBN and if the

                   ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 222 Case No. 2-2016-042

6 FFlel,-L U9E 614LY O1 INVESTIGATION INFORMATION CEL were issued after those changes, then the new leaders would not be seen as im~osed bf the NRC. l(bl/7l/Cl I stated he told l(bl//l/Cl I the Region will issue the CEL and that lrt(mrci agreed with Region II that there was a solid basis to issue the letter. !rb\U)(C} I or SHEA also informed him at some point that TVA would address the chilled work environment by an independent third-party assessment. l/b1/7l!Cl I recalled discussin~ the results and that the independent assessment differed from the TVA OIG resu Its. i/b\(l)rc ! later informed ilb\(7)/C} that their internal review differed and identified there were conflicts with WBN leaders and team members. l/bl(7)/Cl I did not receive any documents and was unsure what Region II was given. He knew Region II was working the issue. ilbl(?)(Ql I was asked again whether he took any actions with resftct to delaying, changing, refraining or otherwise affecting the issuance of the CWEL and l/b}(?l C\ I stated that he took no such actions (Exhibit T-53). Interview of !(bl(7l(C) [ ennessee Valley Authority (b)(7)(C) TVA, was interviewed by OIG and AUSA (b)(7}(C) US Attorney's Office for the Eastern District of Tennessee, wherein he provided the following information in substance. Durinrr discussion about the content of the !(b)(7)(C) l call with i/b)U)(C\ ! and !(b)(7)(C ! l/bl(7)/C I was referring to his notes taken that day and described that i/bl/7HC Iprimaril was doing the talking, which is why his name is underlined in his notes. l!bl/7l/Cl I stated that (b)(7)(C) nd lrb1m1c1 I discussed the results of the NRC's review that they had done regarding the November 11, 2015, events, as well as some of their comments about what they believe their actions were going to be in r,e~ ulatory space including the use of a chilled work environment letter as a regulatory tool. !lb))/Cl I discussed that it was a one-way conversation with the NRC describing what they had found and what they were planning to do, a fairly standard regulatory interaction (Exhibit T-67, pp 1, pp. 18-20). Agent's Analysis In summary, on February 24, 2016, Region II Senior Executives communicated to TVA Senior Executives that the NRC had received concerns about the health of the working environment in the Operations department at WBN. TVA empaneled what would be named the Special Review Team (SRT) which created a re ort with the ur ose to influence the NRC in their response to the concerns. TVA (b)(?)(C) deliberately misrepresented the timing, impetus, and motivation for the SRT to the NRC on multiple occasions and provided misleading information concerning the activities of the SRT to NRC Executives with the purpose to influence the NRC management's actions in response to work environment issues at WBN. When TVA was informed a CEL was to be issued, l(b)(7)(C) I deliberately communicated incomplete and inaccurate information concerning the report status, report content, and misrepresented the independence between SRT and ECP investigations (Report NEC 0047 & 00127), to l/bl(7)/C\ I This information was communicated by ~ to the NRC!(b)(7)(C)  ! in an attempt to delay and/or prevent issuance of the CEL. ~

                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 223 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION subsequently deliberately manipulated the SRT report to match the information communicated to NRC senior executives. On February 24, 2016, NRC Region II management and staff received a brief from TVA OIG which described significant information that TVA OIG had gathered i~l~~~Zl tr eir interviews into work environ~ ncerns at WBN. Following the briefing, NRC's and !!bl(]}(Cl called l/bl/7l/C} I and (b)(7) to inform them that the NRC was in communication with TVA OIG and 01 was reviewing In ormation that gave the NRC concerns about the health of the work environment in the Operations Department at WBN. As a response to the NRC receiving this information from TVA OIG, on February 26, 2016, (b)(?)(C) assembled a team which would come to be known as the SRT. The team was informe a e NRC had entered concerns into their Allegation Process that may result in a possible CEL, Confirmatory Action Letter (CAL) or other vehicle. One objective of the team was to prepare to communicate TVA actions to the NRC in a manner that convinced the NRC that no further regulatory action was needed above "normal." Furthermore, the "Key Activities" of the team were described in a February 26, 2016 email,

    *

• u *

!(b)(7)(C) ! !(b)(7)(Cl I b )c and (b)(7)(C) were included (Exhibit A10-E 1)(Exhibit A10-E2)(Exhibit A 10-E3)(Exhibit T-50)(Exhibit -52 . During his 01 interview on February 4, 2019,l\~,(7) !presented a different account of the ur ose of the SRT that is not corroborated by the evidence obtained during this investigation. (b)(?)(C) described that the SRT was to take a series of inputs to draw a conclusion on whether a c I e work environment existed in operations or on site. These inputs included: information from ECP; any information obtained from TVA-OIG; work that WBN had already done at that point; RCA of the November 11, 2015, event; information from I NPO; and personnel statements I obtained at that point.j(b)(7)(C) explained that the intention of the SRT was not to be a supplemental investiga~ there was already one being performed by ECP and TVA OIG. During his 0 1interview, (b)(?) was asked if he ever communicated to the SRT that the purpose of SRT was to prevent a d1tional regulatory actions, ~ responded, "I do not recall telling them that was its purpose." (b)(?)(C su gested if it was received as that was the purpose that would not have been his intent. (b)(?)(C asserted that the SRT report was an internal report that would potentially have been revIewe y the NRC, but its purpose was not fundamentally a communication vehicle to the NRC (Exhibit T-62, pp. 84-87, pp. 137-142). On (b)(?)(C) ':!Tr:-=m?<1 ,..........,..........._......,_....,.........,........,.""'-'-'.....,.,._,,,_,_....,,._,d..J.o. eeting (b)(7 was sc e u e to ave w1 ................... !-=::::"'l'lt=rl"!'r!r.::-r:::-:::"==:-:::--i-:::-::i=~i::-:!provided suggestions to !(b)(?)(C) ! aimed at trying to influence~ =-='m o agreeing o e ay e NRC in takin actions against TVA and to first allow TVA to a ress the work environment concerns. (b)(7) included recommendations to help achieve those ends including: provide a countering message to parts of TVA OIG 's message to the NRC; make a case to delink the need for NRC action from specific WBN2 milestones; and offer additional meetings with Region II Management (Exhibit A 10-E4)(Exhibit A 10-E5).

                         ,~o, fiOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1RO1~1>'<L Ofi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IP WE!:ffl OMI O r  !=' , REOION II 6 f'f'le l,-L U9!! 614LY       O1 INVESTIGATION INFORMATION 224 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)(5) (b)(?)(C) reinforced the purpose for the SRT in a !(b)(?)(C)  ! email sent to!,_(b_)(?_)(C _)_ _ _ __ and the members of the SRT which identified that , in part, the purpose of the project was _ o_m_in- 1mize additional regulatory engagementJ(b)(?)(C) !also highlighted that the NRC has requested the ECP and SRT reports (Exhibit A 10-E7). On !(b)(?)(C) l b7c ort NEC-16-0047 in an - *

• ed

 'l(b)(7)(C)                            !' to (b)(?)(C)                              nd (b)(?)(C)           whic     ~h~~"-1 forwarded to the SRT members an ( )(7)( )                            t e next ay. On (b)(?)(C)                      ,_(b_) _ _...,

sent an email to ......,~----'-1.LW.1.w.Y the differences in the ECP Report and SRT initial condusjons as bying ' (b)(?)(C) . In an email from !(b)(7)(C) Ito !(b)(?l(C) I ""!(b""""

                                                                                                                      )r1""')("""'

c1- - .

!(b)(?)(C)              J  and b 7 c             b)(7)(C)     addressed the interaction with the NRC and how the NRC would receive the report. This email demonstrates to 0 1that the NRC response was a factor in the writing of the report when !(b)(7)(C)                    Idetailed a strategy to present the differences between the two report conclusions to the NRC (Exhibit A10-E8, pp. 1-46)(Exhibit A10-E9)

(Exhibit A10-E10). On March 8, 2016, NRC RII staff completed a review of TVA OIG interviews provided to the NRC on March 2, 2016. An emergency ARB was convened on March 9, 2016, to discuss the information found in the review designated as concerns three to six of allegation Rll-2016-A-0032. The ARB assigned actions to conduct a phone call with TVA to make them aware of NRC's concerns and provide specifics as necessary. Further action was assigned to follow-up with a chilling effect letter to request information on TVA's actions in response to the NRC's concerns. The Watts Bar issues were discussed t hroughout NRC management up to the EDO's Office (Exhibit A 10-E 11 )(A1O-E12)(A1O-E13)(A10-E14)(A1O-E15)(A10-E16). On !(b)(7)(C) I, !ibl(7)(Cl Ian~ exchanged emails which coordinated changing content of the SRT report which inc~ e complete removal of some information from the report. Information was removed which identified that several root cause and apparent cause analyses from late 2015 had been reviewed. I (b)(5), (b)(7)(C) I (b)(?) On !(b)(7)(C) I at /C} I sent a draft co of the SRT re ort Revision 21 to members of the

                        ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF aP  G l :O.la .AeQe~n l~J GI lpl),li\Qlsi, OFFICE OF 1~*~'[TIGMIOP40, REOIOP* II 6 f'f'le l,-L U9!! 614LY            O1 INVESTIGATION INFORMATION 225 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION (b)(5)

                                           !ibl(7l/Cl I and !{bl{?HC Iheld a teleconference with !/b)(?l{Cl I and ~                                   in whic.......,r-r--    ey__,...o....o_w_e_, up on their !(b)(?)(C)                       Itelephone call to convey that the NRC had issues with the safety culture in the Operations department at WBN and that the N~C had decided to issue a CEL the following week (week of March 14, 2016). Afterwards, [ b)(7)(C)                                                                  I emailed NRC staff and management informing them of the call and the goal of issuing the CEL NLT Tuesda:t of the followi                              ee . Subsequently at~                   hours (b)(?)(C sent an emaill to l(b)(?)(C)              I !(b)(?)(C) I and (b)(7)(C)             , with Revision 2ft>nfi'e SR repo attached and detailed that the SRT report will need to be changed in response to the issuance of the CEL (Exhibit A 11-E1 )(Exhibit A 11-E2)(Exhibit A 11-E3)(Exhibit A 11-E4, p. 4).
 ;:::.:..:.i;..;,;~,;..._......,...._ _ _ _____,._ _ ____,_ _ _......,..._.....,....,.......,...........,..,.,..,1~ ......,.......,,.........,emails with b7c                  on how to approach a personal conversation with the ._______, aimed at changing the proposed regulatory response communicated to TVA on March 11 , 2016. This included actions aimed to avoid issuance of the CEL in the near term by commu i tin "a set of moves that could catch ltbJ(Z)fC)                              I ::ittention enough to cause him to pause." (b)(?)(C) utlined talking points for the conversation where !/bl/7}(C) I was to convey that two independent TVA internal reports (SRT and ECP) had been completed the week prior which reached the same conclusions as the NRC. It was further detailed that the TVA internal reports each incllud.~                                                          e_..,

d,,,....,,.----, themes of the similar six "bins of issues" !tb)(7)(C\ Iused in his discussion with !/b)/7)/Cl Iandl(b)(?)(C) on l(b)(?)(C) l and the two TVA internal reports both reached the same conclusion as the NRC regarding chilled environment in the Operations department. !/bl(J)/Cl I was to request from !(b)/7)/C) J to allow TVA to come to Region II on March 22, 2016 and explain in both open and closed session the details of their conclusions and immediate actions, A reyjew of

!/bl/7l/Cl I notes from the discussion between !rb)(J)/Cl I ~md !/bl(l)/Cl Ion l(b)(7)(C)                                                             l indicated these to ics were discussed as recommended and !/b)(l)/Ql I highlighted that the SRT report was led by (b)(?)(C and ltb\(7)/C)                             I During the call with !(b)(?)(C) 11/brn/c) I specifically requested a short delay in the issuance of the CEL and possibly a different regulatory "footprint" from the NRC (Exhibit A11-E5)(Exhibit A 11 -E6)(Exhibit A 11-E4, pp. 10-19).

On the morning of!(b)(l)(C) !sent an email to NRC executives and management informing them the timeline for issuance of the CEL may be delayed until after the

~ 22 2016 pubijc meeting. !fb}/?l/C\ I sent a revised s ~ ; ~e[ l rt (Revision 22) to the SRT at
~                 onl (b)(?)(C)                 ] On lib)(?)(C)                 j !(b)(7)(C)  I 1b 7 c and !{b)//){C! had a ieieconference where ![bl[7}[Cl I discussed deiavio~ the CEL. Emails between ![b}!7l[Cl                                                                 Iand l(b)(7)(C)                                                                           Jo~(b)(7)(C)                  Idiscussed the weekend
                                      ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY             O1 INVESTIGATION INFORMATION 226 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION I call between !lbl(7)/C} I and !(b)(7)(C) the follow-up call on !(b)(7)(C) Iand the resultant delay in issuance of the CEL (Exhibit A 11-E?)(Exhibit A 11-EB 1)(Exhibit A 11-E4, p. 5) (Exhibit A 11-E9)(Exhibit A 11-E10). During his 01 interview (b)(7)(CJ testified under oath that the information he provided !lbl/7}/Cl I for his discussion with 11,1,1,11au...i.i----1 included that l<b}/7)/Cl I was not surprised by NRC's conclusions because two independent TVA internal reports (ECP and SRT(j~~)~C~j ached the same conclusions. Likewise, a similar communication was made to and i(bl(7HCl !that the TVA reports had reached the same conclusion and at that point TVA communicated to ilb)(?)fCl I that TVA was not arguing the conclusion or the right regulatory action (Exhibit T-62, pp. 114-124). Based on the evidence 0 1finds that~ deliberately provided incomplete and inaccurate information to b 7 c for the purpose of providing to !/bl(l)/C} Iduring a conference call on (b)(7J(C) 01 found insufficient evidence to prove that !lb}/7}/C} I was aware the information was incomplete and inaccurate when he spoke to !/bl(7)/Cl I 01 determined (b)(7)(C) falsely indicated that the SRT report was completed and reached a conclusion regarding existence of a chilled environment in Operations. This is based on the content and si nificance of changes made to the SRT report after communicating with the NRC on (b)(7)(C) I !(b)(7)(C) An analysis by 0 1of the SRT reports revision 21 from March 11 , 20- 6-, a_n_d.,..r_e_v"'" 1s.,.. io-n-.!22 from March 14, 2016, revealed significant changes in the report content and conclusions to make it correspond with the information provided b the NRC on March 11 , 2016, and the information provided to NRC executives on (b)(7)(C) Information specifically addressing the "6 bins" discussed by (b)(7)(C) during the (b)(7)(C) conversation with TVA, as documented by !(b)(7)(C) I was initially used to replace existing in ormation in the SRT report. Conclusions and language contradictory to the NRC assessment of the work environment was removed or changed to agree with the NRC conclusion. In one specific instance a differentiating aspect between the SRT and the ECP report was changed to a concurring aspect. The SRT report findings were changed after communicating with !lbl(7)/Cl I The evidence shows that the changes were made to align the SRT content with the information rovided to the NRC as well as the information the NRC had provided to TVA on (b)(7)(C) (Exhibit A10-E21, pp. 1-12). Additionally, Ol's investigation concluded thad(b)(?) !also deliberately provided incomplete and inaccurate information to !/b)/7)/Q} I when he asserted that two independent TVA internal reports had been completed and reached the same conclusion as the NRC. Ol's review of the evidence concluded that the ECP report was not completed when it was communicated to the NRC that it was done; additionally, the SRT and the ECP re: orts were not independent as presented to the NRC. The in~ tion revealed that !ib)/7\/G} I shared ECP investigation information with ~ and other TVA senior executives from the start of the ECP Chilled Work Environment investigation. Moreover, 01 determined thad(b)(7) !was the lead of the SRT and the primary author of the SRT report. (b)(7)(C) was included on distribution of information pertaining to the ECP jnyestjaation i Glu mg its planning, approach, and findings as the investigation was performed. l(b)(?)(C) Jwas involved in the initiation and performance of both the ECP and SRT investigations. Further, draft ECP reports were sent to the SRT members during its investigation and there were specific actions taken to identify and address

                       ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY             OI INVESTIGATION INFORMATION 227 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION differences in the reports. !(bl/7l(Cl Iindicated in her interview that the purpose of the SRT was to take action based off the findings of the ECP report. Review of the SRT report found multiple references to information contained in the ECP report and a section which specifically reviewed and included the ECP report information as part of the SRT report. Multiple other sections of the SRT report include ECP report references and information used in its analysis (Exhibit A10-E3)(Exhibit A10-E6)(Exhibit A10-E8, pp. 1-46)(Exhibit A10-E9) (Exhibit A10-E20)(Exhibit T-61 )(Exhibit A10-E22, p. 15, pp. 17-25, p. 35, p. 37, pp. 41-42)(Exhibit A 10-E23, pp. 1-12)(Exhibit A 10-E24, pp. 1-8)(Exhibit A 10-E25, pp. 1-51 )(Exhibit A 10-E26, pp 1-45). On j(b)(/JIC) I liblr)(CJ Ilibll/111:1 I and Ml7l(CI exchanged emails contain Closed Session Talking Points which ................___, described as the initial thoughts of (b)(7) on I~ NRf the messa es that needed to be conveyed to the NRC during a March 22, 2016 mee Ing. (b)(7)(C) replied with a concern that the talking points said that the SRT did things that they 1 no an the tact was risky. He also was questioning the point that !(bl/7}/C} I was still in the process of revising the ECP report (Exhibit A 10-E27). On !(b)(7)(C) I ilb}/7}/C} I replied to an email from ilb}(7)/C} I r.1ddressing a conversation they had concerning the conclusion she was documel ,~l~i~~ r er reJ}0rt of the work completed in ECP report NEC-16-0047. The ECP report identified 7 and lrtil!7l/Cl l as the source of a chilled work environment in Operations. !lb\17}/C} I presented his own wording of what the conclusion should say which absolved him of responsibility and classified the issue as a communication gap which others filled with their own perception (Exhibit A 10-E28). (b)(7)(C) directed !(bl(7l/Cl Iand!{b)(7)(C) I (b)(7 to archive the previous signed revision(Rev 0) of the SRT report and replace with a revise ev 1), fully understanding that the NRC was informed that the report was completed during the public meeting on March 22, 2016, and was not going to be informed of changes made following the meeting. (b)(7)(C) stated, "a Rev 1 from today will be credible that we were done when we talked to them." b 7 c *

• port and having it properly archived with (b)( )(C) at TVA (Exhibit T-74)(Exhibit A10-E29)(Exhibit A10-E30). During his 0 1interview, (b)(7) was asked if he instructed anyone to archive changes after the meeting, wiWnrespon e , ao not r~:w.-_,

with specifics once its signed I let the administrative staff m~ he entry of the BSL." (b)(?)(C) contends that he has no idea on how the BSL process works relative to archiving revisions o documents. FurthermoreJ(b)(7)(C) !noted that he left that task to administrative staff to address and make the necessary entries into BSL. (Exhibit T-62, pp. 136-138) On (b)(7)(C) sent the SRT report to the NRC. (b)(5) was not established as

                       ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY            OI INVESTIGATION INFORMATION 228 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION documented in the report but rather established as a direct response to the NRC communicating receipt of information from TVA OIG and entering issues into their Allegation Program on February 24, 2016. This is further supported by the evidence that TVA was also briefed by TVA OIG on the issues shared with the NRC and did not take any additional action until the NRC became involved. The report falsely presents the SRT efforts as self-initiated actions taken by TVA executives to address the work environment issues at WBN that were already ongoing at the time the NRC informed TVA senior management that the NRC was planning to begin looking into it (Exhibit A10-E22, pp. 6-8)(Exhibit A10-E3)(Exhibit A10-E9)(Exhibit A10-E4). (b)(5) i.--:--~-,.11 Kev,ew ot me report aoes not point to any actual review that was done to specifically investigate whether any retaliation was associated with the actions of management. Questioning of TVA by TVA OIG confirmed that no investigation of such a type had been performed. Additionally, review of NEC-016-00127 does not support the statement that\ ------- (b)(5) I On April 22, 2016, (~(7) approved and sent TVA's response to the CEL to the NRC which discussed the SR repo and ECP report. It documented that the SRT and ECP investigations were independent investigations initiated in response to the receipt of degraded work environment concerns. It describes that in order to ensure the independence of the teams and their reviews and assessments, team members were selected from outside the WBN organization for the initial assessments. Based on the evidence gathered during this investigation, 01 determined that the ECP investigation and SRT were not independent of each other by participants or in report content. The identification of those involved in the two investigations and reports failed to include the activities of !(b)(7)(C)  ! NEC-016-00127, which is an executive summary of the investigation NEC-16-047 which she had oversight of and led the editing of the original report. As before, the SRT was being presented as one of two independent investigation teams commissioned by TVA management following TVA's receipt of concerns that a degraded work environment existed within the WBN Operations Department (Exhibit A10-E31, p. 4). The testimony from!(b)(?) !and team members indicates that the report was authored by (b)(?)(C) and that team members had difficulties with the outcomes. The evidence established tha e SRT had a direction to develop a report with the explicit purpose to influence the NRC and not as an independent investigation as presented to the NRC (Exhibit T-66, pp. 4-5) (Exhibit T-62, pp. 87-92)(Exhibit T-63, p. 2)(Exhibit T-64, pp. 1-2)(Exhibit T-65, p. 1, p. 3). 0 1determined that (b)(7) deliberately provided !lb}(7}/Cl I information to be communicated to NRC (b)(7)(C) t,~~~ incomplete and inaccurate in an attempt to delay and/or prevent the issuance of a CEL. (b)(?)(CJ provided false information that the SRT and ECP reports were

                     ,~e, FeR 1-UBUe 01aeteaURE WITI ,eu, )l(flf1Re1~1>'<L eF
             ~1-ECIAL AeElff 114 Cl IAROE, OFFICE OF ltWESTIOMIOPJS, REOIOtJ II 6 f'f'le l,-L U9!! 614LY  OI INVESTIGATION INFORMATION 229 Case No. 2-2016-042

6FFlel,-L U9E 6f4LY O1 INVESTIGATION INFORMATION completed and misrepresented the SRT and ECP efforts as independent investigations.l(b)(?)(C) falsely indicated that the SRT report had reached the same conclusions as the ECP report and further falsely indicated that both the ECP and SRT reports reached the same conclusions as the NRC review. The evidence shows 0 1that b~(?)(C) !deliberately provided t he NRC information as part,:,,:.i..--...., SRT re ort that was incom e e ana inaccurate in some res ect material to the NRC. (b)(5) e con ents o t e report were eliberately changed to match the information provided by NRC senior executives after communicating to the NRC that the SRT report agreed with the NRC's conclusions. Agent's Note: The issues of purpose and timing of the SRT report are material for two reasons:

1) The NRC allegations manual specifically calls out licensee actions in these situations to be weighted heavily in the determination of whether to issue a CEL. TVA was communicating to the NRC that they were cognizant of the situation, were responding appropriately, and were taking the correct actions to address the situation. Any acknowledgement that TVA's actions were reactionary to the NRC call would have undermined any possible narrative that they were taking timely and appropriate actions in responding to this issue. Because TVA OIG informed the NRC that TVA OIG had already discussed these issues with TVA, this would have encouraged the NRC to take additional actions (i.e. issue a CEL).

a. 5.2.j.6(a)(2) Situations That Warrant CEL Issuance Licensee's Remedial Actions in Response to Negative SCWE Trends or an Event.

The staff should place greater weight on this factor than those articulated albove. Of interest is whether the staff views the licensee's remedial actions to be timely and appropriate and to have a likelihood of success in enhancing the SCWE and negating any prior chilling effect.

2) Some of the Key Activities provided at the beginning of the SRT established a predisposition for what the report should accomplish with respect to the NRC which shows it was purposed for influencing the regulator and not as an independent investigation. Also, it shows that the information and conclusion presented should be l~OT FOR 1-UBUe 01 aet01'Uf'tE W IT I IOUT Afifif't01~1AL OF

           ~1-ECIAL AOElff I r Cl IA~OE, OFFl6 E OF lr WEe!TI OATI O r  e! , ~EOIOr  II 6 f'f'lel,-L U91! 6f4LY    O1 INVESTIGATION INFORMATION 230 Case No. 2-2016-042

6 FFleliltL USE 6'4 LY - 01 INVESTIGATION INFORMATION met with additional scrutiny and considered in the appropriate context as the team is being directed on what their find ings/analysis needed to accomplish. Conclusion Based on the evidence developed during this investigation, 01 substantiated that l(b)(l)(C) !(b)(7)(C) trVA, deliberately provided incomplete and!l-.i-na_c_c_u-ra-te_ _, information to the NRC in the Special Review Team Report. Based on the evidence develo ed durin this investigation, 01 also substantiated thatl (b)(7)(C) (b)(7)(C) t TVA deliberate! rovided incomplete and inaccurate information to ,.,_(b"""')(...:. 7)(.:...C.:...

                                                ) --r.:--:-:=~--__,_ _ _ _ _ _ ____,TVA, with the purpose of being conveyed to the (b)(l)(C)                           o attempt to influence the NRC's decision in taking a regulatory action.
                    ,~e,= FeR fi'UBLl6 Dl96L69URE \!V ITI ISUT >'<fi'fi'RS'"'>'<L eF OPEO IAL AOEPdf IPd 0 1IAROE , OFFIOE OF IPd~'EOT IOATIOPdO, REO IOPd 11 6 ffleliltt USE 614 LY                  01 INVESTIGATION INFORMATION 231 Case No. 2-2016-042

6FFlel,-L U9E 6f4LY OI INVESTIGATION INFORMATION THI S PAGE LEFT BLANK INTENTIONALLY

              ,~ef Fef't 1-UBUe 01 aete1'Uf'tE Wlf l 1euf )fl(fifif'te1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPNESTIOMIOPJS, REO IOPJ II 6 f'f'le l,-L U91! 6f4LY  OI INVESTIGATION INFORMATION 232 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION SUPPLEMENTAL INFORMATION On July 5, 2018, 0 1 briefed (b)(?)(C) Assistant Section Chief, Environmental Crimes Section, U.S. Depart - en~t-o..,....,.u

                              ':-m                - s"'l"t1,..

ce--i"I~ -,_ . 1400 New York Avenue, N.W. Washington, DC 20005, on the status of this investigation. On February 6, 2019, 0 1 apprised !(b)(7)(C) lon the investigation. l(b)(?)(C) Iadvised that before a decision is made on whether prosecution of these matters is warranted, 0 1 would provide the Report of Investigation to DOJ for review after the compilation and analysis of the evidence was completed . On May 17, 2019, 01 advised !(b)(l)(C) I the Report of Investigation was completed and available for review. To date, DOJ has not rendered an official decision relative to the prosecutorial merit of this investigation. A decision from DOJ is anticipated in the near future and will be reported under a separate cover.

                  ,~of FOR 1-UBUe 01aetoaURE Wlf l IOUf )l(flf1R01~1>'<L OF SPECIAL AGEIQI IIQ CH)!<fii.teE, OFFICE OF ltWEeTIG,A.+IO~Je, ~-c10~1II 6 f'f'le l,-L U9!! 614LY                    OI INVESTIGATION INFORMATION 233 Case No. 2-2016-042

6FFlel,-L U9E 6f4LY OI INVESTIGATION INFORMATION THI S PAGE LEFT BLANK INTENTIONALLY

              ,~ef Fef't 1-UBUe 01 aete1'Uf'tE Wlf l 1euf )fl(fifif'te1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPNESTIOMIOPJS, REO IOPJ II 6 f'f'le l,-L U91! 6f4LY  OI INVESTIGATION INFORMATION 234 Case No. 2-2016-042

6FFle l,-L U9E 614LY OI INVESTIGATION INFORMATION LIST OF EXHIBITS Documentary Evidence Nos. Description A1-E1 Analysis No Pocket Veto W Enclosures (123 pages) A1-E2 All l(bl/7HC I Email Statements (1 1 pages) A 1-E3 Email (b)(7)(C)  ::::_~requesting hourly outage updates (2 pages) A1-E4 Email _.............._ sends lrb}f7l(C} I SOD SOM Checklists (2 pages) A1 -E5 Email llbl(7)/Cl I sends out Checklist (2 pages) A1-E6 Email RE U1 Outage - 1930 Dayshift Hourly Update (2 pages) A1-E7 Email_ _ _ ___.PM MCR Observation (1 page) A1-E8 EA-17-022 Confirmatory Order ML17208A647 (29 pages) A1-E9 EA-17-022 Confirmatory Order ML17208A596 (4 pages) A 1-E10 IR 050002016013 ML17069A133 (34 pages) A1-E11 Email (b)(?)(C) I (b)(?)(C) on crew logging By OCC Direction (4 pages) A 1-E12 Email l(b)(Zl(C) IStop Logging by OCC direction (1 page) A 1-E13 Email l(b}r7l(C} I- I told shift to stop logging by OCC direction (1 page) A1-E14 Email l,... (b-)(7,..

                             )(..,..

C)_ _ __,,lemail MCR Observation (5 pages) A2-E1 WBN Plant Operating Logs from October 2 1, 2015 (140 pages) A2-E2 WBN Plant Dataware from October 21 , 2015 (Electronic Database) A2-E3 Official record copy of 1-GO-2 Revision 6 used during start-up in October 2015 (86 Pages) A2-E4 3-OT-STG-003A, Revision 12, Main Feedwater System (Student Training Guide) (242 pages) A2-E5 ANALYSIS OF THE USE OF THE STANDBY w Attachments (1099 pages) A2-E6 Draft Apparent Violation SBMFP Use (6 pages) A3-E1 Emaill(b)(7)(C) !Outage Update Sent b) (b)(7)(C) (2 pages) A3-E2 Email._ _ _ _ _ _____._ Outage Update Sent b)

                                                                        ----         (2 pages)
               ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAi AGE!>II l!>I CHABGE OFFICE OF IMVESIIGAIIOMS, PFGIOl>l 11 6f'f'lel,-L U9!! 614LY          O1 INVESTIGATION INFORMATION 235 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A3-E3 Copy of 1-GO-1 from 11/9/2015 (34 pages) A3-E4 1-GO-1, Unit Startup from Cold Shutdown To Hot Standby, Rev 3 (125 pages) A3-E5 1-GO-1, Unit Startup from Cold Shutdown To Hot Standby, Rev 4 (125 pages) A3-E6 Procedure Change copy WorkFlow Name: WBN 1-GO-1 Rev. 0004 20151109135818 (5 pages) A3-E7 Emai (b)(7)(C) 1-GO-1 Sent by ..... J(C_) _ _ ____,I on l(b)(7)(C) l(b)_(7_ page A3-E8 Emai 1-GO-1 Revision 4, Sent by l._ (b_)(7_)(C_l _ ____,lon .... l(b_)(?_)(C_J_ _...., llb)(7l(C> ( 1 page) A3-E9 NPG-SPP-1.2, Administration of Site Technical Procedures, Revision 12 (56 pages) A3-E1 0 Analysis of change to 1-GO-1 (63 pages) A3-E11 Draft Apparent Violation (6 pages) A4-E1 1-GO-1 from 11 15 pages 27-60 (34 pages) A4-E2 Clearance Tagout 1-TO-2015-0046 - Clearance 1-62-0584-FO (6 pages) A4-E3 1-GO-1 , Unit Startup From Cold Shutdown To Hot Standby Revision 0004 Effective Date 11/09/15 (125 pages) A4-E4 eves Charging and Letdown Valve Checklist 1-62.01-1V (19 pages) A4-E5 WBN Plant Logs from November 11 , 2015 A4-E6 Email !(b)(7)(C) pages) ISent byl(b)(?)(C) I(2 A4-E7 Email !(b)(7)(C) U(b)(7)(C) ISent byl(b)(7)(C)

              !(bl!?)!Cl               I (3 pages)

A4-E8 Email !(b)(?)(C) !Sent by (b)(?)(C) l"'" rb"""

                   )rz"'"'

HC .,..,:)==:==;l-:-: (2:-p-a-g-es

                                                    --:)_ _ _ _ _ _ _ _ _ _ ___,

A4-E9 Email !(b)(7)(C) jPDF Interview Notes Sent by !(b)(?)(C)  !(10 pages) A4-E10 Email !(b)(7)(C) !My interview, email exchange between !lb\(7}/C\ I and

              !(b)/7\/Cl             I (2 pages)

A4-E11 Draft Apparent Violation Failure to Follow 1-GO-1 (8 Pages) A4-E12 Conduct of Operations OPDP-1 Rev. 0029 (76 pages) A4-E13 eves Charging and Letdown Power Checklist 1-62.01-1 P (2 pages)

                    ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF
        -'l9~CIAL AeErqf 11q Cl IAfi.teE, eFFle E eF IIW E!:ffl OMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY                  OI INVESTIGATION INFORMATION 236 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A4-E14 NPG-SPP-01 .2 Rev. 0012 -Administration of Site Technical Procedures (56 pages) A4-E15 WO117339526 PIT limits from November 11 , 2015 (75 pages) A4-E16 Email l(b)(?)(C) !Sent b~ (b)(?)(C)

            !(b){7)/Cl  j (2 pages)

A5-E1 Email l(b)(7)(C) INRC Question Email from llb)(7)/Q} Ito llb}(Z)/Q} I (5 pages) A5-E2 Email l(b)(?)(C) I From ltb}(Z)rq I (5 pages) A5-E3 Email !(b)(?)(C) IRHR question from l(b)(?)(C) 1(5 pages) A5-E4 CR 1114975 (66 pages) A5-E5 Email l(b)(7)(C) Ifroml(b)(7)(C) I(2 pages) A5-E6 (b)(?)(C) Emaill chain from (b)(7)(C) (3 pages) A5-E7 Email (b)(7)(C) (b)(7)(C) from.___ _ ____. (3 pages) A5-E8 TVA initial responsel(b)(?)(C) !questions (3 pages) A5-E9 I Analysis of response l(b)(7)(C) Questions A5-E10 WBN Plant Logs from November 11 , 2015 (9 pages) A5-E11 lrb)(7)1C} IAmail to SROs (3 pages) A5-E12 Emaill(b)(?)(C) !Read while poo'ing from!._ (b__

                                                                      )(?__
                                                                          )(C_)_ _ _ __,1(2 pages)

A5-E13 50.9 Info to SRI DRAFT AV Information (5 pages) A6-E1 Emai!l(b)(?)(C) IREDINGER interview notes sent by !...(b_)(?_)(C_)_ _ __.1(3 pages) A6-E2 Email!(b)(?)(C) !Updated questions sent by !rb}/7l(C) I(2 pages) A6-E3 Email l(b)(?)(C) Isent bv!(b)(l)(C) I(4 pages) A6-E4 Email sent by l(b}/7l(C} I (6 pages)

                     ;::::.::.:;.===-=--=--=.-----

A6-E5 Email !(b)(7)(C) IMy interview, email exchange between l!b}U}IC} I ;:ind

            !(b)(7)/C}      I (2 pages)

A6-E6 Shift Order 15-50 (7 pages)

                ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY     O1 INVESTIGATION INFORMATION 237 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A6-E7 Analysis of Procedures and Training W Attachments (993 pages) A6-E8 Email !(b)(l)(C) IWBN U1 11 00 Maint Outage !fbJ(Z)!Cl I and l,WWC} I (2 pages) A6-E9 Email !(b)(7)(C) IOutage Update Reply !rb)/7}(C) I (2 pages) A6-E10 Email !(b)(7)(C) Isent Outage Lesson Learned (1 page) A6-E11 Email !(b)(7)(C) jto !(b)(7)(C) !RHR Statement (3 pages) A6-E12 Email!(b)(7)(C) IREDINGER Statement to !rbl/7l/C} I(2 pages) A6-E13 Email!(b)(7)(C) I Level 2 interview notes given to management (10 pages) A6-E14 Email ,..!(b-)(7-)(-C)_ _ _ _ _ _ _ _!email on shift order (2 pages) A6-E15 Allegation 2015-A-0214 Attachment 4 (8 pages) A6-E16 Email!(b)(?)(C)

            !(b)(?)(C)              ISent B~(b)(?)(C) j(24 pages)

A6-E17  !(b)(7)(C) ISlides 1-6-16 (17 pages) A6-E18 Draft Apparent Violation for 010616 meeting (8 pages) A7-E1  !(b)(7)(C) !Dennis REDINGER interview notes sent by .... l(b_)(?_)(C_l _ _____.1 (3 pages) A7-E2  !...(b_)(7_)(C_J_ __.I Email exchange between !fbl{7)/Ql I and !lbl!7)!Cl I (2 pages) A8-E1 CR 11 21520 Lvl 2 Rev O with attachments 160210984 Final (34 pages) A8-E2  !(b)(?)(C) ILevel 2 interview notes (10 pages) A8-E3  !(b)(?)(C) !l.(fil[) to l/b)(?)(C) I (!(b)(?)(C) ~ A8-E4 20160115 1717 Fwd_ Stement - Dennis REDINGER (1 page) A8-E5 (b)(?)(C) IREDINGER January statement to !(b_ ....)(?_)(C_)_ _ ____,! (2 pages) A8-E6 l

            ....._ _ _ __, REDINGER Statementto !(b)(7)(C)                                 !(1 page)

A8-E7  !(b)(?)(C) jto l(b)(7)(C) IRHR Statement to~ 3 pages) A8-E8 l(b)(7)(C) I(1 page) A8-E9  !(b)(?)(C)  ! Input to Lvl 2 (2 pages) A8-E10  !(b)(7)(C) l to l(b)(?)(C) ILvl 2 are we right (14 pages) A8-E1 1 ...

           !(b_)(7_)(C_) _ _ _ _ _ho !(b)(?)(C)                                                      I(Safety Culture Analysis) (1 1 pages)
                     ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY              O1 INVESTIGATION INFORMATION 238 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A8-E12 A8-E13  !._)(7_)(C_)_ _ _ _ _....,l changes X1 to remove OCC (1 page) (b_ A8-E14  !(b)(7)(C) Iresponse it is fixed (1 page) A8-E15  !(b)(7)(C) 1to!(b)(7)(C) I(CR 1121520 Report)(48 pages) A8-E16  !(b)(?)(C) Isends out schedule Update reply l(b)(?)(C) I(2 pages) A8-E17  !(b)(7)(C) Irequesting hourly outage updates (2 pages) A8-E18  !(b)(7)(C) IOutage Update Reply!{b)(?)(C) 1(2 pages) A8-E19  !(b)(7)(C) !Email chain between !{b)(?)(C) Iand !lb)/7\/C} ll(b)(?)(C) I(2 pages) A8-E20 CR1127691 Rev O Root Cause Analysis with Attachments 20160219 (212 pages) A9-E1  !(b)(?)(C) !Feb 2 TVA meeting summaries (24 pages) A9-E2 l(b)(?)(C) !about slides for meeting (1 page) A9-E3 Feb 02 16 Drop in Notes !lb}/7)/C\ I (14 pages) A9-E4 l(b)(?)(C) !tol(b-

                                                 .....)(7-)(C-) - - - - - - - - - - - 1 (1 page)

A10-E1 Email (b)(?)(C) Initial call with TVA OIG (2 pages) A10-E2 Email Initial call with TVA OIG Summary (1 page) A10-E3 Email.___ ____,~ SRT Purpose (4 pages) A10-E4 Emai!l(b)(?)(C) Itol(b)(7)(C) IMeeting discussion points (3 pages) A10-E5 Email l(b-)(?-)(C

                        ..... _) _ _ _ _ _ _ and l(b)(?)(C)  I                         !Meeting prep (2 pages)

A10-E6 Email !(b)(?)(C) Ito l(b)(7)(C) t(2 pages) A10-E7 Email l(b)(7)(C) Imessage to SRT on minimizing regulatory engagement (2 pages) A10-E8 Emaill(b)(7)(C) !Final Investigation Report (46 pages) A10-E9 Email !(b)(7)(C) labout content of SRT report and ECP report (1 page)

                 ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF St-ECIAL AeEIH 114 0 I lii!ROE, OFFIGE OF ltWEGTIOMIO~JG, AEOlmJ II 6 f'f'le l,-L U9!! 614LY          OI INVESTIGATION INFORMATION 239 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A10-E10 Email l(b)(7)(C) !Freeman Difference Reconciliation (1 page) A10-E11 Emaiil(b)(?)(C) IEmergency ARB discussion (2 pages) A10-E12 Email (b)(?)(C) all with TVA OIG (2 pages) A10-E13 Email (b)(?)(C) Comms to EDO on WB Path Forward (1 page) A10-E14 Email Emergency ARB Notes!(b)(?)(C)  !(1 page) A10-E15 Email Emergency ARB Summary (1 page) A10-E16 Email Emergency ARB ARB Input Form C3-6 (6 pages) A10-E17 Email!(bl(7)(Cl (Changes to SRT report (2 pages) A10-E18 Email !(b)(?)(C) Ichanges to SRT Report (2 pages) A10-E19 Email!(b)(l)(C) !SRT Report R15 sent out byl(b)(?) 1(57 pages) A10-E20 Emaiij(b)(?)(C) !Rev 21 SRT Report (58 pages) A10-E21 CHANGES FROM REVISION 21 TO REVISION 22 TO FINAL OF SRT REPORT w attachments (244 pages) A10-E22 Special review Team Report - Blue Report NRC Copy ( 112 pages) A10-E23 Email l(b)(?)(C) Ito (b)(7)(C) (12 pages) A10-E24 Email (b)(?)(C) To (b)(?)(C) (b_)(7_)(C_)_ _ _ _ _ _ _ _ _ _ _ ___. (8 pages) Email (b)(?)(C) to ..,,.l (b.,..,,

                                                                       )(7"""
                                                                           )(C.,,.,.)- - - - - - - - - - - ,

A10-E25 and (b)(?)(C) (51 pages) A10-E26 Email (b)(?)(C) nd (b)(?)(C) (Final Investigation Report)(45 pages) A10-E27 Email!(b)(l)(C) !comments on ECP report for meeting talking points (4 pages) A10-E28 Email !/blf7)(Cl !wording ECP report about investigation into SVP Causing CWE (2 pages) A10-E29 Emaillibll/l!CI ISRT report to NRC final approval date (1 page) A10-E30 Email-*_ _ _ _ _ _ __to !(bl{l)IC) I Revise SRT report (1 page) A10-E31 ML16113A228 Response to CEL (38 pages) A11-E1 Email !(b)(?)(C) !Discussion of CWE with .... l (b_)(l_)(C_l _ ___,land li~l(?) 1(4 pages) A11-E2 Email !(b)(7)(C) Ion Call with TVA on CEL (3 pages)

                 ,~o, FOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L OF SPECIAL AGEPH IPJ 0 1h0tROE , OFFICE OF IIW E!:lTIOMl!:m!:l, liii!:EalOI~ II 6 f'f'le l,-L U9!! 614LY    O1 INVESTIGATION INFORMATION 240 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION A11-E3 Email l(b)(7)(C) 1(1 page) A11-E4 l(b)(7)(C) I- Notes ( 19 pages) A11-E5 Email l(b)(?)(C) Ito !lbl(7)!Cl pages) A11-E6

                      --------to Em a iI (b)(?)(C)                                    tbJ(TJ(Cl   on l(b)(7)(C)         k3 pages)               ~

A11-E7 Email (b)(?)(C) Email about weekend call withliR_J(2 pages) A11-E8 Email ,..,l(b"""'

                           )(J""")("""'

C)- - - - - - . ! on change in issuance of CEL (1 page) A11-E9 Emailj(b)(7)(C) ISRT Draft Report Revision 22 14-2016 (55 pages) (b)(?) A11-10 (C) Notes on call with !(bl(7)/Cl I March 15 2016 (2 pages) Testimony Nos Description T-00a Transcript of interview with l(b)(7)(C) Idated December 18, 2015 (43 pages) T-00b TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl I dated April 26, 2016 (8 pages) T-01a TVA OIG Report of Investigative Activity of interview with .... l(b_)(7_)(C _l _ ___,I, dated January 19, 2016 (15 pages) T-01 b Transcript of interview with_l (b_)(7_)(C_l _ _ _~ dated December 18, 2015 (47 pages) T-01c TVA OIG Report of Investigative Activity of interview with .._! (b.....

                                                                                                       )(J___                 l
                                                                                                            )(C""'"')_ _ _ _ dated September 29, 2016 (5 pages)

T-02a Transcript of interview with !(bl(7)(Cl I dated December 17, 2015 (75 pages) T-02b Transcript of interview with !(bl(7)(Cl I dated December 18, 2015 (40 pages) T-02c TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl I dated January 20, 2016 (4 pages) T-02d Transcript of interview with !(b)(7)(CJ I dated February 1, 2016 (56 pages) T-03 TVA OIG Report of Investigative Activity of interview with !(bl(7)(Cl I dated August 22, 2016 (9 pages)

                 ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY              O1 INVESTIGATION INFORMATION 241 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION T-05a TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated January 16, 2016 (5 pages) T-05b TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated September 29, 2016 (3 pages) T-07a Transcript of interview with ..._! (b..._ ......l_ ___,! dated December 18, 2015 (75 pages)

                                               )(7_)(C T-07b        TVA OIG Report of Investigative Activity of interview with !.._         (b..._
                                                                                       )(7..._.
                                                                                            )(C _.)_     _,! dated February 01, 2016 (36 pages)

T-07c TVA OIG Report of Investigative Activity of interview with !.._ (b..._

                                                                                       )(7..._.
                                                                                            )(C _.)_     _.I dated February 11, 2016 (41 pages)

T-07d TVA OIG Report of Investigative Activity of interview with !..., (b....

                                                                                       )(7...
                                                                                            )(C _.l_     _.l dated May 1, 2017 (4 pages)

T-09 TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl Idated February 24, 2016 (3 pages) T-10 TVA OIG Report of Investigative Activity of interview with !(b)(?)(C) I dated February 18, 2016 (3 pages) T-11 TVA OIG Report of Investigative Activity of interview with lrhlW[Gl Idated April 15, 2016 (4 pages) T-12 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C dated I February 22, 2016 (3 pages) T-13a TVA OIG Report of Investigative Activity of interview with !..., (b... l(C...,l_ _.....l dated

                                                                                       )(7....,

February 10, 2016 (4 pages) T-13b TVA OIG Report of Investigative Activity of interview with !..., (b... )(C...,l_ _.....l dated

                                                                                       )(7....,

September 29, 2016 (3 pages) T-14 TVA OIG Report of Investigative Activity of interview with !(b)(?)(Cl Idated February 17, 2016 (6 pages) T-15a TVA OIG Report of Investigative Activity of interview with !..., (b...,

                                                                                       ){D      C)_ __.....I dated
                                                                                          ....(....

March 7, 2016 (3 pages) T-15b Transcript of 0 1interview of !(b)(7)(C) I dated April 16, 2019 (39 pages) T-16a TVA OIG Report of Investigative Activity of interview with !(b)(?)(Cl Idated January 28, 2.016 (4 pages) T-16b TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated September 29, 2016 (3 pages)

              ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   OI INVESTIGATION INFORMATION 242 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION T-17a Transcript of interview with !(b)(7)(C) I dated December 18, 2015 (50 pages) T-17b TVA OIG Report of Investigative Activity of interview with !(b)(?)(C) Idated January 19, 2016 (2 pages) T-17c TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated February 4, 2016 (4 pages) T-17d TVA OIG Report of Investigative Activity of interview with !(b)(?)(C) I dated October 3, 2016 (4 pages) T-17e TVA OIG Report of Investigative Activity of interview with !(b){7l(C) Idated March 29, 2017 (5 pages) T-18 Transcript of interview with !(bl(?)(Cl I dated December 18, 2015 (33 pages) T-1 9 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated January 27, 2017 (3 pages) T-20 TVA OIG Report of Investigative Activity of interview with !(bl(7)(Cl I dated February 9, 2016 (2 pages) T-21a TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated February 2, 2016 (6 pages) T-21b TVA OIG Report of Investigative Activity of interview with !(bl(?)(Cl I dated February 10, 2016 (6 pages) T-21c TVA OIG Report of Investigative Activity of interview with !(bl(?)(C) I dated June 30, 2016 (5 pages) T-21d TVA OIG Report of Investigative Activity of interview with !(bl(?)(Cl I dated January 19, 2017 (19 pages) T-22a Transcript of interview with !{b)(7)(C) I dated December 18, 2015 (71 pages) T-22b TVA OIG Report of Investigative Activity of interview with !(bl(J)(Cl Idated January 19, 2016 (3 pages) T-22c TVA OIG Report of Investigative Activity of interview with !(bl(7)(C) Idated July 20, 2016 (3 pages) T-22d TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated September 6, 2016 (5 pages) T-22e TVA OIG Report of Investigative Activity of interview with !{b)(7)(C) Idated April 03, 2017 (2 pages)

              ,~e, FeR 1-UBUe 01 aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   OI INVESTIGATION INFORMATION 243 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION T-23a TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated January 27, 2016 (2 pages) T-23b TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated September 29, 2016 (2 pages) T-24 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated July 13, 2017 (3 pages) T-25a TVA OIG Report of Investigative Activity of interview with (b)(l)(C) dated February 22, 2016 (943 pages) T-25b TVA OIG Report of Investigative Activity of interview with _ _ ____, dated April 3, 2017 (3 pages) T-27a TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl I dated February 02, 2016 (8 pages) T-27b TVA OIG Report of Investigative Activity of interview with !(bl(7)(Cl I dated February 04, 2016 (2 pages) T-27c TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated July 19, 2016 (1 page) T-27d TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated January 14, 2019 (1 page) T-27e Transcript of 01 interview of !(b)(7)(Cl I dated April 16, 2019 (10 pages) T-28 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated February 03, 2016 (7 pages) T-29 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated July 14, 2016 (5 pages) T-30 Transcript of 01 interview of!(b)(7)(Cl Idated May 16, 2017 (26 pages) T-31 TVA OIG Report of Investigative Activity of interview with !(bl(7)(Cl I dated January 28, 2017 (3 pages) T-32 TVA OIG Report of Investigative Activity of interview with !_ (b.... l(C.....) _ _.....I dated

                                                                             )(7...,

February 17, 2016 (4 pages) T-33 TVA OIG Report of Investigative Activity of interview with !(bl(7l(C} Idated May 26, 2016 (7 pages)

              ,~e, fieR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L efi SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   O1 INVESTIGATION INFORMATION 244 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION T-34a TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated February 10, 2016 (6 pages) T-34b Transcript of interview with !(b)(7)(C) Idated February 23, 2017 (64 pages) T-35 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated June 14, 2017 (3 pages) T-36 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) Idated March 21, 2016 (4 pages) T-38 TVA OIG Report of Investigative Activity of interview with !(bl(l)(Cl Idated October 16, 2017 (1 page) T-38b Transcript of 0 1interview of !(b)(7)(C) I dated April 26, 2019 (30 pages) T-40a Transcript of interview with REDDINGER, dated December 18, 2015 (59 pages) T-40b TVA OIG Report of Investigative Activity of interview with REDDINGER, dated January 19, 2016 (3 pages) T-40c TVA OIG Report of Investigative Activity of interview with REDDINGER, dated February 10, 2016 (2 pages) T-40d TVA OIG Report of Investigative Activity of interview with REDDINGER, dated March 07, 2016 (10 pages) T-40e TVA OIG Report of Investigative Activity of interview with REDDINGER, dated September 6, 2016 (4 pages) T-41 TVA OIG Report of Investigative Activity of interview with j(b)(7)(C) l dated September 27, 2016 (2 pages) T-42a TVA OIG Report of Investigative Activity of interview with !.._(b.. _)(7..,.)(C_.,)_ _____,! dated June 09, 2017 (3 pages) T-42b TVA OIG Report of Investigative Activity of interview with !.._(b.... )(C...,)_ _____,! dated

                                                                                )(7...,

February 25, 2019 (4 pages) T-43a TVA OIG Report of Investigative Activity of interview with J(b)(?)(C) !dated February 09, 2016 (38 pages) T-43b NRC Interview Report of interview with !(bl{7)(Cl Idated June 21, 2018 (5 pages) T-44 TVA OIG Report of Investigative Activity of interview with !(bl(7l(C) I dated February 4, 2016 (4 pages) T-45 TVA OIG Report of Investigative Activity of interview with !(b)(?)(C) I dated May 10, 2017 (2 pages)

              ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   O1 INVESTIGATION INFORMATION 245 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION T-46a I TVA OIG Report of Investigative Activity of interview with !(b)(7}(C) dated September 29, 2016 (2 pages) T-46b I TVA OIG Report of Investigative Activity of interview with !(b)(7}(C) dated February 3, 2016 (6 pages) T-46c Transcript of 0 1interview of!(b)(7)(Cl Idated April 12, 2019 (22 pages) T-47a TVA OIG Report of Investigative Activity of interview with (b)(?)(C) dated February 23, 2016 (3 pages) T-47b TVA OIG Report of Investigative Activity of interview with ..___ _ ___, dated February 23, 2016 (3 pages) T-48 TVA OIG Report of Investigative Activity of interview with l(b)(?)(C) Idated June 6, 2016 (5 pages) T-49a TVA OIG Report of Investigative Activity of interview with (b)(?)(C) dated February 10, 2016 (2 pages) T-49b TVA OIG Report of Investigative Activity of interview with dated February 10, 2016 (206 pages) T-49c TVA OIG Report of Investigative Activity of interview with ,___ _ _...., dated March 22, 2019 (5 pages) T-50 NRC Interview Report of interview with l1~r) I* dated December 14, 2016 (4 pages) T-51 NRC Interview Report of interview with !(b)(7)(C) Idated December 14, 2016 (2 pages) T-52 l(b_)(?_)(C_)_ __,l dated TVA OIG Report of Investigative Activity of interview with .... December 13, 2016 (3 pages) T-53 OIG Memorandum of Interview of !(b)(7)(C) Idated June 22, 2017 (5 pages) T-60a TVA OIG Report of Investigative Activity of interview with (b)(?)(C) dated September 26, 2016 (2 pages) T-60b TVA OIG Report of Investigative Activity of interview with ,___ ___, dated September 27, 2018 (2 pages) T-61 TVA OIG Report of Investigative Activity of interview with l(b)(?)(C) l dated May 5, 2017 (1 page) T-62 Transcript of interview with (b)(?)(C) dated February 4, 2019 (165 pages)

                 ,~o, fiOR 1-UBUe 01aetoaURE WITI IOUT )l(flf1R01~1>'<L Ofi aP  G I Ab Ae~n l~J GI hO.RGE, OFFIOE OF ltWESTIOMIOPJS, ~EOION II 6 f'f'le l,-L U9!! 614LY OI INVESTIGATION INFORMATION 246 Case No. 2-2016-042

6 FFlel,-L U9E 614LY OI INVESTIGATION INFORMATION T-63 TVA OIG Report of Investigative Activity of interview with !(b)(7)(C) I dated March 8, 2017 (6 pages) T-64 TVA OIG Interview with !(b)(l)(C) I dated June 28, 2016 (2 pages) T-65 TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl Idated May 11, 2016 (4 pages) T-66 TVA OIG Report of Investigative Activity of interview with !(b)(?)(C) I dated January 11 , 2019 (5 pages) T-67 Transcript of interview with !(b)(7)(C) I dated August 1, 2018 (97 pages) T-68 TVA OIG Report of Investigative Activity of interview with l(b)(7)(C) Idated March 03, 2016 (4 pages) T-69 TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl I dated February 08, 2016 (8 pages) T-70 TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl I dated January 20, 2016 (3 pages) T-71 TVA OIG Report of Investigative Activity of interview with llb\(7)/Ql I dated February 08, 2016 (10 pages) T-72 TVA OIG Report of Investigative Activity of interview with !(b)(7l(Cl I dated February 10, 2016 (3 pages) T-73 TVA OIG Report of Investigative Activity of interview with !(bl{?l(C) Idated February 29, 2016 (5 pages) T-74 TVA OIG Report of Investigative Activity of interview with !(b)(l)(C) Idated January 08, 2019 (5 pages) T-75 Transcript of 01 interview of !(b)(7)(Cl I dated April 12, 2019 (8 pages) T-76 Transcript of 01 interview of !(b)(7)(C) I dated April 12, 2019 (11 pages) T-77 TVA OIG Report of Investigative Activity of interview withllbll7XC> ldated May 20, 2016 (4 pages) T-78 TVA OIG Report of Investigative Activity of interview with !(b)(7)(Cl I dated September 04, 2018 (4 pages)

              ,~e, FeR 1-UBUe 01aeteaURE WITI 1eu, )l(flf1Re1~1>'<L eF SPECIAL AOEPH IPJ Cl lAROE, OFFICE OF IPWESTIOMIOPJS, REOIOPJ II 6 f'f'le l,-L U9!! 614LY   O1 INVESTIGATION INFORMATION 247 Case No. 2-2016-042}}