ML20134K479
| ML20134K479 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/08/1995 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20134K135 | List: |
| References | |
| FOIA-96-351 NUDOCS 9702140046 | |
| Download: ML20134K479 (115) | |
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ATTACHMENT 12 UNITED STATES NUCLEAR REGULATORY COMMISSION
(. .: RZGION 1 In re: PUBLIC SERVICE ELECTRIC AND GAS CO.
VINCENT POLIZZI An Enforcement Conference was held before Loretta B. Devery, Registered Professional Reporter and Notary Public, at the offices of the United States Nuclear kegulatory Commission, Region 1, 475 Allendale Road, King of Prussia, Pennsylvania, on Wednesday, February 8, 1995, commencing at 3:15 P.M.
l PRESENT:
WAYNE LANNING JOHN WHITE KARLA SMITH, ESQ.
DANIEL HOLODY SCOTT BARBER LENNY OLSHAN MARN SATORIUS MARK J. WETTERHAHN, ESQ.
WILLIAM BRIGGS, ESQ.
VINCENT POLIZZI ALL POINTS REPORTING 723 Erlen Road Norristown, PA 19401 (610) 272-6731 m t 9702140046 970211 '
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ONEILL96-351 PDR __
ALL POINTS REPORTING (610) 272-6731 /
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l 1 1 l l 2 MR. WHITE: This is an enforcement 3 conference to discuss O.I. findings relative to 4 harassment and intimidation issues that our Office 5 of Investigations has investigated and believe it I
6 has substantiated information that supports H and I 7 occurred on December 3rd, 1992.
8 The purpose of this enforcement ;
9 conference is to assure that you understand the :
10 agency's investigative findings relative to this 11 matter and to solicit from you any other i
12 information, mitigating circumstances, background, 13 errors in the Commission's view on this particular ,
14 event that you can bring to our attention that will 15 help us in coming to an accurate assessment and !
16 evaluation of this matter relative to any potential 17 enforcement that we may take.
18 Relative to the matter itself, 19 specifically on December 3rd, 1992, two SRG 20 engineers attempted to process a safety issue in !
21 accordance with station procedures by submitting an 22 incident report to the General Manager of Salem 23 Operations and to you, Mr. Polizzi, Operations 24 Manager at the time. The incident report questioned ALL POINTS REPORTING (610) 272-6731 I
1
> 1 l
l 1 1 the safety related qualification of commercial grade I
2 air pressure set point regulators which control 3 service water flow to containment fan cooling units.
4 In conversation with the SRG engineers, 5 the General Manager, with your cooperation and 6 advice, told the individuals to get out of his t
7 office and threatened to have them removed from the -
8 site, an action that was interpreted by the SRG 9 engineers as harassing and intimidated. Upon 10 deliberation, the General Manager wrote a letter to i
4 11 the General Mar ger of Quality Assurance and Nuclear 12 Safety Review to have them removed.
13 Subsequently, further apparent 14 discriminating action was directed against the 15 individuals when the General Manager of Quality i 16 Assurance / Nuclear Safety Review deliberated and took 17 action to reprimand and counsel the SRG engineers 18 relative to the submittal of the information and the 19 handling of the situation.
i 20 In conclusion, the Office of
. 21 Investigations appears to support the finding they 22 were harassed and intimidated by various actions 23 directly taken by these former Salem managers, 24 including yourself.
i l
ALL POINTS REPORTING (610) 272-6731 i l
a 4
1 1 With that being said, I'd like to i
2 identify the NRC representatives today. Dan Holody, 3 who is a representative with the Region 1 as 4 Enforcement Coordinator. Karla Smith, Regional t
5 Counsel. Scott Barber, Project Engineer, Division l
l 6 of Reactor Projects, Section 2A. Myself, John j 7 White, Section Chief, Division of Reactor Projects, 8 Section 2A. Mr. Wayne Lanning, Deputy Director, o
9 Division of Reactor Projects. Mr. Mark Satorius, 10 Office of Enforcement. And Mr. Leonard Olshan, 11 project manager, Office of Nuclear Reactor 12 Regulation. And if you would identify yourselves
- 13 for the the record, please. i A
14 MR. BRIGGS: Sure. I'm Bill Briggs, 15 and I'm an attorney representing Mr. Polizzi here l 16 today.
17 MR. POLIZZI: Vince Polizzi, PSE&G. ;
18 MR. WETTERHAHN: I'm Mark Wetterhahn [
l 19 with the law firm of Winston and Strawn.
J 20 MR. WHITE: And we understand and l
21 you'll confirm, Mr. Polizzi, that Mr. Wetterhahn is 22 here with your consent?
23 MR. POLIZZI: Yes, sir, that's right. l 24 MR. WHITE: With that being the case, i l
l l
ALL POINTS REPORTING (610) 272-6731 !
I 1 we'll open it to you for discussion.
2 MR. HOLODY: John, before you start, I 3 just want to go over our spiel. You were in on the 4 conference in the morning and went through it with 5 the utility. But just so you understand our 6 process, we have this O.I. finding that John 7 articulated the findings. We also have the 8 investigation that was done by the utility, and this 9 is basically the third piece of the puzzle. We want 10 to hear from you today regarding these issues, give 11 you an opportunity to present your views on this 12 matter, because we have a decision to make regarding 13 appropriate enforcement, whether.we should take 14 enforcement with respect to you as an individual and 15 what that action should be if we decide to do so.
16 And I'll talk at the er 1 of this meeting on what the 17 options are with respect to what they might be.
18 MR. WHITE: Also one other point in 19 that we are in receipt of the information that you 20 provided to Miss Karla Smith relative to a 21 Memorandum in Support of Mr. Vincent J. Polizzi and 22 a Declaration of Vincent J. Polizzi. We will 23 incorporate this as an attachment to the transcript.
24 MR. BRIGGS: Thank you, Mr. White.
ALL POINTS REPORTING (610) 272-6731
r 1 1 That's the only procedural point, I wanted to make-t 2 sure that you had that. And if I could just briefly 3 say what we would like to do. First of all, we'd 4 like to thank all of you for giving us the
- 5 opportunity to explain what happened, and 6 particularly what happened on December 3rd and with 7 regard to the letter dated December the 4th insofar 8 as Mr. Polizzi is concerned. I don't plan to say 9 very much, but I want Mr. Polizzi to tell you all i 10 what happened from the mcment he first got involved 11 with this incident until the last moment that he had ,
- 12 anything to do with it. And we welcome, we plead i
13 for any questions you may have, any concerns you may 14 have, any comments you may have. l l
15 We've obviously not seen the O.I. l 2
16 report, so I can't comment on everything that's in l
< 17 that report except what I have seen. We've not seen
- 18 all'of the company's report. There are holes in 19 what we have seen. And we can comment on those 4
20 things that we know about. And please ask us if you 21 have any questions.
22 Vince, do you have any introductory 23 comments that you'd like to make before we get into 24 the heart of why we're here?
ALL POINTS REPORTING (610) 272-6731
7
? 1 MR. POLIZZI: Just briefly, Bill, thank f
2 you. I certainly ditto what Bill says in having the 3 opportunity to come before this group today and 4 explain at least my perception of what occurred. I 5 have to tell you that it is an embarrassing 6 experience, and frankly painful for me. And I say 7 that with a lot of humblen<ess.
8 It is again a significant reminder of 9 the event that took place that I'm not particularly 1
10 proud of. It was a significant life lesson for me 11 as well as my family as we lived through the last i
12 two years under the focus as a principal in this 13 investigation.
. 14 I will tell you that my actions that 15 day of December 3rd were inappropriate, they were 16 unprofessional, and not consistent with the way I
. 17 normally behave. And I would clearly understand how 18 the people would feel by my emotional reaction to a 19 hostile environment, i' you will, 20 intimidation / harassment.
21 In my intensity to try to get to the 22 heart of the matter of what the concern was and 23 assure that the incident report as presented to me 24 was as complete and accurate as possible before my ALL POINTS REPORTING (610) 272-6731 1
- - - _=- . _ _ - - . - ._ --
2 1 senior made a decision on the operability of the fan i
2 coolants, I essentially los't my temper. And I'm not 3 sure I can fully explain why I l o's t my temper. But !
4 certainly I did lose my temper and I became less 5 than objective. I allowed something that should 6 have been manageable clearly at my level to escalate 7 to higher levels, and that was wrong, that was a 8 mistake.
9 Having said that, I take full 10 responsibility. I think you would understar.d that.
11 But it's equally important for me to tell you that I 12 did not, emphatically did not deliberately violate 13 any NRC regulation. I would not do that, nor would 14 I suppress the submittal of an incident report, 15 especially the safety significance of this incident ;
I I
16 report. With that, again I'm prepared to answer any i
17 questions. I hope I can fill in the blanks that you 18 may have.
19 MR. BRIGGS: Why don't you start by 20 telling the ladies and gentlemen how you first 21 became aware of the fact that Bert Williams had a 22 concern about the CFC unit and walk them through the 23 events that led up to the meeting in your office on i
24 December the 3rd, 1992?
I ALL POINTS REPORTING (610) 272-6731 !
? 1 MR. POLIZZI: Essentially the first I ,
2 connection I had with the issue was via a message ,
3 that apparently was left for me. Bert had either 4 been there -- and I will use Bert and Paul, if 5 that's okay, in my discussion -- had either been 6 there or spoke to my secretary on the phone and 7 iterated a concern that was left.
8 When I returned to my office, I noticed 9 this amongst other messages that I had. And 10 appreciating the significance of this one because of 11 a concern to the fan cooling units would affect both 12 units, I contacted Bert. We had a very pleasant, 13 professional discussion. I think I understood what !
14 the issues were, what his concerns were as he (
15 verbally told them to me over the ph ne. We also i
16 agreed on a course of action.
17 I guess what I'm saying is that we were 18 tot' ally aligned. There was no confusion. There was i l
19 no conflict. And I had some actions to take. And 20 those actions were to contact the technical people, 21 our own technical department, headed by Mike 22 Morroni, as well as our engineering organization, 23 ENPB, Jay Bailey.
24 So after I hung up with Bert, I took ALL POINTS REPORTING (610) 272-6731 i
2 1 those steps. I contacted both Jay and Mike, which
(
2 order I'm not sure, and exprocced the concern that I 3 understood and asked for their help in sorting out 4 the issue.
5 The two issues at the time were the 6 configuration of the regulator associated with the ;
7 containment fan cooling units, i.e., the tubing 8 connections, if you will, and the qualification of 9 the regulators, were they qualified, seismically, 10 environmentally and so forth to meet their intended 11 function for all accident situations.
12 So with that charter, I had assurance 13 from Mike and Jay that they would go ahead and do 14 that. And nothing else was done at that point.
15 MR. WHITE: May I ask a question?
16 MR. POLIZZ1: Yes.
17 MR. WHITE: Relative to the matter that 18 we bring to your attention, the configuration 19 problem and the qualification problem, was that in 20 your estimate a significant issue?
21 MR. POLIZZI: Yes, it could be. It 22 could be.
23 MR. WHITE: The manner in which they 24 brought it to your. attention, is that usual? Was ALL POINTS REPORTING (610) 272-6731 4
11 2 1 that the usual way that you'd be apprised of things
(
2 that were coming down as an incident report?
3 MR. POLIZZI: Let me explain that. No, 3
4 it is not the usual method. The usual method in the 5 lion's share of incident reports, which are in fact 6 generated by Operations, would go directly to the 7 Senior IJuclear Shift Supervisor. I can't give you a 8 number, John, but essentially 99 percent of the 9 incident reports would go directly to the Senior 10 Nucletir Shirt Supervisor.
11 However, it was a clearly understood ,
12 policy that issues where there was some engineering 13 ambiguity, that those issues would typically come to 14 the Operations management. They could come through 15 myself, they could come through my operating f
! 16 engineers. This really is not articulated or at P
17 variance with NAP-n. You will not find that this 18 detail is net in there.
l 19 But in the interest of trying to solve 20 the probler. as expeditiously as possible, not burden a
21 the Senior Nuclear Shift Supervisor with conducting 22 unnecessary phone calls and so on and so forth, this 23 was the process, if you will, that we would operate 24 under for these engineering type issues. And there i
ALL POINTS REPORTING (610) 272-6731
3 1 is certainly history of operating this way before 2 the event, and I'm sure subsequent to the event, but 3 nothing that I could put my finger on subsequent to 4 that.
5 MR. WHITE: So this is commonly 6 understood, this manner that they would bring this 7 to your attention, was certainly acceptable both to 8 them and to you, you were aware of that?
9 MR. POLIZZI: Yes, sir. And speaking, 10 speaking to the Senior to support that, a gentleman 11 by the name of Marios Kafantaras, it is my 12 understanding, and the sequence is a little unclear, 13 but it was my understanding that they had been down 14 to see Marios at some time and voiced a concern, as 15 they had to me by the message, and he suggested that '
16 they come and see me.
17 Now I know that from the point that I 18 had spoken to Marios sometime I believe after I 19 spoke to Bert, but before I ultimately had the i 1
20 second meeting with Bert, or the first meeting with 21 Bert, if you will. So it was understood, and this 22 was a practice that I believe was understood by Mike 23 Morroni as well.
24 MR. WHITE: As you discussed this ALL POINTS REPORTING (610) 272-6731
=_ . ... . .- .- . _.
a, 3 1 originally initially with Mr. Williams, did you
(
2 understand it and did they understand it to be a 3 concern that had the potential, if it was declared 4 inoperable, to require a plant shutdown? j 5 MR. POLIZZI: Yes, I believe so. It 6 was clear. The next step in the sequence, people 7 are taking some actions based on the direction that 8 we had laid out. Mike Morroni calls me back and we 9 have a discussion about his findings. We spend the 10 lion's share of our discussion on the qualification 11 of the regulators, essentially that Mike was 12 satisfied that the qualification as documented in 13 the FSAR would support the adequacy, at least at 14 this point in time. He did not see a variance with 15 what the FSAR was suggesting as far as the 16 qualifications and the fact that these may not be 17 purchase safety related components. However, there 18 was'more work to do there. So that was one piece.
19 The second piece was dealing with the 20 configuration, and we had a discussion regarding the 21 surveillance testing of the fan cooling units.
22 Recall now that if you were to go out and run the 23 surveillance on the fan cooling units before, during 24 or after the event, the concern as presented would ALL POINTS REPORTING (610) 272-6731
14 3 1 be totally subdued. Containment fan cooling units i
2 would in fact pass their surveillance, and 3 historically they had.
4 So Mike and I, at least from the 5 judgment that we had and aligned to, is that the 6 configuration issue was also not an immediate 7 operability concern. I understood also from Mike 8 that he had been in contact with Engineering, but I 9 I can't give you any details on the sequence of 10 that, namely Jay Bailey.
11 I called Jay after I hung up with Mike 12 and asked his opinion and what he had found, because ,
I 13 I wanted to bring this thing to closure.
14 Possibly two hours, two and a half 15 hours had gone by. Jay supported Mike's conclusion I 16 that the FSAR was consistent, but we needed to
- 17 really do some additional checking and get back to 18 the original procurement documents to really nail 19 this. But at this point in time, he was satisfied 20 with where we were and he was assigning one of his 21 engineers, Harry Blum, to go further with this 22 analysis.
23 MR. LANNING: Let me understand your 24 description of operability there. You said that the i
ALL POINTS REPORTING (610) 272-6731
, 1. 1 coolant surveillance test would mask it?
{
2 MR. POLIZZI: Not mask it in any way, f 3 shape or form, it would be totally subdued to the 1
4 surveillance.
5 MR. LANNING: What do you mean subdued?
6 MR. POLIZZI: You could nct tell, if 7 you were to pull the surveillance procedure out and 8 run the surveillance procedure, they would be 9 catisfactory. The surveillance would single it out.
10 MR. SATORIUS: The surveillance wasn't 11 testing these components?
12 MR. POLIZZI: The surveillance 13 function, the overall functionality of the fan 14 cooling unit, the functionality being a shift in the' 15 service water flow, the containment fan cooling 4
16 units that are normally operating in a non-safety 17 mode send 700 gallons through your coils. In an 18 accident environment, the service water flow 19 increases to 25 hundred gallons per minute, and that 20 essentially is the function of these regulators to 21 allow the valving to change accordingly.
1 22 Notwithstanding the configuration or l 23 the qualification, the surveillance would still show i
24 that functionality the fan cooling units would j I
ALL POINTS REPORTING (610) 272-6731
]
4 1 continue to be operable by tech specs.
(
2 MR. BRIGGS: You're saying regardless 3 of how they were configured, the maintenance test 4 indicated that they were functional?
5 MR. POLIZZI: Right.
6 MR. HOLODY: Would that have been true 7 even in the harsh environment?
8 MR. POLIZZI: I can't answer that 9 exactly because it's really speculation. The point 10 was, at this time, we had reasonable assurances that 11 the containment fan cooling units had indeed passed 12 their surveillances. We had not completed a 13 walkdown yet of the configuration from that .
l 14 perspective. We had not completed an audit trail of 15 the documentation to support the qualification. So l
16 there was reasonable assurance that if we take some )
1 17 steps that we needed to go further that we could 18 have a very positive outlook on this.
19 I guess what I'm suggesting is that 20 there was a greater than 50 percent chance that we 21 would not have an operability concern. And what I 22 want to suggest is that -- and please don't think 23 that there was any fear or reservation on my part to 24 shut down those units. It is not an easy decision ALL POINTS REPORTING (610) 272-6731 4
1, 4 1 or a quick decision to shut down both units at the i
2 same time, it's a challenge. But in no way, shape 3 or form was that an influence on the decision as far 4 as were these fan cool units okay for the immediate 5 period of time.
6 MR. LANNING: I'm still somewhat --
7 help me understand the process you're going through.
- 8 You are in effect evaluating operability of a system 9 without a vehicle that would point you in that i
10 direction. This is what you meant by these 11 unwritten procedures that you could handle an 12 engineering issue with, is that what you meant?
13 MR. POLIZZI: Let me see if I can sort 14 that out for you. Because of the ambiguity in l
15 certain events, incident reports in this case,
- 16 reading the information at face value would not help 17 you make a % cision. Because you cannot really tell 18 if the engineering concerns as documented would 19 indeed make the containment fan cooling units 4
20 inoperable. And all I'm suggesting is that 21 surveillance tests would demonstrate per the tech 22 specs only that they were operable.
23 So you really need some further 24 technical understanding of just what influence, ALL POINTS REPORTING (610) 272-6731
. c.
4 1 1.e., would these things operate in various
(
2 conditions, seismic conditions, environmental 3 conditions to continue to be functional. But at 4 this point in time, they were functional.
5 MR. LANNING: What vehicle are you 6 using at this time that the documents concern?
7 MR. BRIGGS: Was there a piece of paper 8 filed, is that what you're asking?
9 MR. POLIZZI: At this point in time, 10 there was essentially no piece of paper.
11 MR. LANNING: Do you normally do this 12 kind of operability determination without a piece of 4
13 paper?
14 MR. POLIZZI: The operability 4
15 determination was triggered from the concern, in 16 other words. There is no doubt that we would need a 17 piece of paper to document our conclusions. First 13 of all document the concern and kind of document
- 19 where we are. We would not leave it up in the air 20 that this was just we have a concern and somebody's 21 working on it. We would have to bring it to 22 closure. And that was the -- unfortunately it 23 didn't work out this way -- but that was the 24 intention of taking the actions that I took, to go ALL POINTS REPORTING (610) 272-6731 i
4 1 ahead and get the necessary information so that we i
2 can in fact add this to the concern and just see 3 where we are.
4 MR. LANNING: So as I understand what 5 you're telling me in this case, an incident report 6 normally includes enough information in it that 7 stands alone for the Senior Nuclear Shift Operator 8 to ascertain operability; is that what you're 9 telling me?
10 MR. POLIZZI: Yes, yes, that was always 11 our intention.
12 MR. LANNING: And these incident 13 reports are generated by anybody in the plant?
14 MR. POLIZZI: They could be generated 15 by anybody, anybody at all.
16 MR. HOLODY: You're saying if an 27 individual had a concern regarding the operability 18 of a component, when that individual documents the 19 concern, was that individual expected to also 20 document an operaoility determination?
21 MR. POLIZZI: No, not at all.
22 MR. SATORIUS: Or enough information 23 such that one piece of paper can be used by itself 24 to come to a conclusion on operability?
I ALL POINTS REPORTING (610) 272-6731
4 1 MR. POLIZZI: That's correct.
I 2 MR. SATORIUS: Let me ask you a 3 different way. What I'm hearing:you say is you're 4 saying if an aux operator fs out wandering around 5 and sees a component that he knows how it operates 6 but he doesn't know technically from an engineering 7 standpoint how it's put together, he sees what he 8 thinks is a concern, what I'm hearing you say is 9 that you would expect him to write out an incident 10 report and do enough research to come to an :
5 11 operability concern to give it to the shift 12 supervisor so the shift supervisor can make a call? ,
13 MR. POLIZZI: No. Let me clarify that.
- 14 The expectation is not that everyone would have the 15 knowledge to go ahead and write the details. That's J
16 an important peint, I'm glad you asked that. That 4
17' is the very reason for having the engineering folks 18 involved in this, Morroni and Bailey. The 19 insistence, if you will, which I explained to you in .
20 that meeting was only to document what we had ,
21 learned from experience, if you will. If we had --
22 there's nothing wrong -- let's put it this way, !
23 there's nothing wrong with anybody taking an 24 incident report as written, and the person may be
+
ALL POINTS REPORTING (610) 272-6731 .
-t
5 1 uninformed or unfamiliar with what they're
( l 2 generating, to hand it to the senior. l
(
3 The actions to follow up and document 4 ultimately what I was asking to be documented would 5 have been done by the Senior Nuclear Shift 6 Supervisor. What was done by myself, or could have 7 been done by the operating engineers, was just a 8 policy to head things off to the point of speeding 9 the process up and not having the senior have to get 10 involved with calling other managers or potentially 11 going through the chain of command to get to those 12 managers. I can call up just about anybody in my 13 position as Operations and people will respond, and 14 they did.
15 MR. HOLODY: Did you expect these two I
16 individuals should have had that engineering 17 evaluation as part of this incident report, they 18 should have documented that before they gave it to 19 you or brought it to Operations?
20 MR. POLIZZI: I have to tell you that 21 that was my expectation, or what my -- what's the 22 word I'm trying to use -- when they came to my 23 office, I was expecting that information to be 24 already documented on the incident report. As a ALL POINTS REPORTING (610) 272-6731 1
5 1 matter of fact, I wasn't sure why they were in my
(
2 office.
3 MR. HOLODY: Is that because you would 4 have -- because it would have made your life easier 5 or because that's just the way the process worked?
4 6 MR. POLIZZI: I'm not sure, make my 7 life easier?
i 8 MR. HOLODY: If they walked in with an 9 incident report that says okay, here's a problem, 10 the regulators, there may be a qualification issue 11 or they're not configured properly, okay. Just as 12 if an aux operator was walking through the plant or 13 an engineer happened to have a drawing and was 14 walking through to run down a system and he saw 15 these pipes weren't the way they were supposed to 16 be, but he didn't know the impact of that so he 17 documents that on an incident report. Pipes aren't 18 configured the way they're supposed to be on the 19 drawing, but I haven't been able to ascertain what 20 the impact of that is.
21 When he provided that information to 22 you, is there, from your past experience on incident 23 reports, would you have expected that they would 24 have already done the operability determination l
l l
ALL POINTS REPORTING (610) 272-6731
b 5 1 before they gave it to you, or was there some ,
f 2 procedure that required them to have the operability t
3 determiaation done before they gave it to you, or l
I 4 was it it would make your life easier if you couAd
- 5 tell this component is or is not operable?
6 MR. POLIZZ1: Well I wouldn't .
7 characterize it as making it easier. I think the 8 documentation -- and I'll say this was incidental to 9 the whole issue. The key point was that we had the
+
10 information, and I was aware that Bert and Paul'had 11 the same data that I had from the conversations that t
12 we had with Mike Morroni.
1 13 So that it was almost an automatic, if 14 you will, these were informed people, that in order s 15 to make this thing accurate, in order to make the 16 decision possible by the senior an informed 17 decision, there had to be nome kind of 18 documentation.
1 19 And we have to be really careful of 20 what I'm asking for on that incident repcrt. I'm j 21 not asking for any operability determination. That 22 was never a point of disagreement. Maybe there was 23 miscommunication. But that was never a point of 24 disagreement at all. My understanding -- my ALL POINTS REPORTING (610) 272-6731 l
5- 1 expectation was only that we put down what we had i
2 learned from Mike and what we had learned from Jay.
3 The decision as far as operability would be made by 4 my senior.
5 MR. LANNING: But the process --
6 MR. HOLODY: What did you expect them 7 to put down there? You were looking for Bert 8 Williams or Paul Craig or both to write something on 9 that incident report that had been communicated from 10 Mike Morroni and Jay?
11 MX. PLLIZZI: Yes.
12 MR. H 'J LO D Y : And that was communicated 13 to both cf t h e r '.
14 MR. POLIZZI: To my knowledge, Bert and 15 Paul had the same information that I received from 16 Mike, yes.
17 MR. HOLODY: And they were reluctant to 18 do that; is that correct?
19 MR. POLIZZI: Yes, sir.
20 MR. HOLODY: So given the fact that 21 they were reluctant, could you have just allowed 22 them then to go to the senior?
23 MR. POLIZZI: Yes, I could.
24 MR. HOLODY: The senior could have then ALL POINTS REPORTING (610) 272-6731
5 5 1 accepted that incident report, could he have? i
(
2 MR. POLIZZI: Yes.
3 MR. HOLODY: Could the senior then, I 4 presume would have then proceeded to give it to you?
5 MR. POLIZZI: He may not have given it 6 to me. He could have, but he certainly would have l 7 called me or my operating engineers.
8 MR. HOLODY: At which time, an 9 operability determination would have been made by 6
10 who, the senior, by you or by Mike Morroni. But 11 you're saying you had the information that says it 12 looks operable at this time?
13 MR. POLIZZI: That's right.
i 14 MR. HOLODY: Who would have signed that 15 piece of paper that said -- and put, you know, 16 put -- basically held them responsible for that 17 call? Who would that have been? Would that have 18 been you? Would that have been the senior?
19 MR. POLIZZI: It would be the senior.
20 However, the senior would not do that without having 21 this additional information to make a decision.
22 Because the narration by the initiator was strictly 23 an identification of a potential problem. So again, 24 getting back to the engineering issue, the i
ALL POINTS REPORTING (610) 272-6731
6 1 Operations people are most equipped and most
(
2 knowledgeable to make a determination of operability 3 when it's a visible, physical type of thing that you l
4 can observe or compli.*.nce with the tech spec l 1
5 surveillance. !
6 If you're out of that space, you really l
7 need help. And the suggestion would have been I 8 would have written it on there for him, or he could 9 have written it on there if he'd wanted to speak to 10 the engineers personally, that the qualification has 11 been found acceptable based on a reference in the 12 FSAR per configuration is acceptable at this point 13 in time based on the adequacy of the weekly and 14 monthly surveillance tests.
l 15 MR. HOLODY: How difficult would that 16 have been?
17 MR. POLIZZI: Very easy, very easy, 18 unfortunately.
19 MR. WHITE: These are Safety Review 20 Group engineers who are operating -- should be l
21 operating, by design, independent of the line 22 organization?
23 MR. POLIZZI: Yes, sir.
24 MR. WHITE: They go into the plant and ALL POINTS REPORTING (610) 272-6731
l l
l 6 1 they identify a situation which configuration is
(
2 different than as described in the FSAR, which is a 3 problem, and they identify that the components in 4 this configuration --
4 5 MR. POLIZZI: The qualification, I'm 6 sorry.
7 MR. WHITE: The qualification of the a components in this configuration may or may not be 9 qualified because they're different than as 10 specified. Both are legitimate concerns.
11 MR. POLIZZI: They are.
4 They identified this in an 12 MR. WHITE:
13 incident report. As you say, their normal process, 14 just do that much, bring it to the Senior Nuclear 15 Shift Supervisor and the thing would have been 16 processed in accordance with the normal process.
17 Because this is one of those one 18 percent events that they felt compelled to discuss 19 in advance and let you know what was coming down and f
20 give you some sort of a courtesy information, you 21 were contacted in advance of this. Notwithstanding 22 that, it's their finding, they are not licensed 23 operators. In fact operability determinations are 24 within the sphere of licensed personnel. So they ALL POINTS REPORTING (610) 272-6731
h Y l l
l 6 1 really have no business even making a conjecture l I j 2 about operability. ,
l 3 MR. POLIZZI: John, if I may, you're 4 absolutely right. And appreciate that I've gone ;
5 through this in my mind many, many times and what I l
6 would have done differently. And although my 7 intentions were genuine to make the incident report j 8 complete, it did not have to escalate into a blow-up 9 to the event that it was. They could have done 10 exactly as they had and submitted that incident 11 report to the senior.
12 What I'm suggesting is that we would ;
i 13 have subsequently documented the information that we 14 had learned. We, I mean myself, and we would have ,
J 15 proceeded, so I will not take an offense that that 16 was -- I was wrong in my insistence on asking them 17 to document the information. It was -- it was a 18 cimple request.
19 MR. WHITE: Have you ever done that 20 before? Have you ever asked them to document 1 l
21 something on an incident report different than -- l l
22 MR. POLIZZI: Not to the SRG. I will l 23 have to tell you that in the past, engineering i 24 issues would normally come to the station kind of ALL POINTS REPORTING (610) 272-6731 i
6 1 with a group, if you will, that there's some piece l
2 that Engineering needs to talk to the station 1
3 management about. Now just as we would need the
]
4 engineering people to help us with the technical, 5 the operations and station organization have some 6 pieces that they need to bring on the table too.
! 7 So there certainly have been precedents 8 in history where incident reports have been brought 9 over. There are issues where there are precedents, i
, 10 where issues have been brought over by Engineering 11 and Licensing which ultimately lead, after many 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of discussion, a documentation of the concern.
13 And then that incident report is in some cases hand 14 carried by myself to the Senior Nuclear Shift 15 Supervisor.
16 So I guess to answer your question, 17 John, yes, there had been situations where others 18 had provided more detail, but in this case with SRG, 19 I can't answer that.
20 MR. WHITE: In those cases that you 21 described, those are all groups, organizations, that 22 are different than the i.ndependent safety evaluation 23 group activity.
24 MR. POLIZZI: I would say yes.
ALL POINTS REPORTING (610) 272-6731
I 6 1 Licensing and Engineering predominantly.
l l
2 MR. WilITE : If I understand correctly, I 3 you never had before, relative to your SRG finding 4 or SRG initiated incident report, required them to 5 document anything other than what their initial i
6 finding was; is that correct?
7 MR. POLIZZI: I just want to -- I want t 8 to be careful, John, as far as requiring it. I 9 think that's a little strong. I can understand how 10 people would read that into it and I would probably ;
11 say the same thing looking back. I was insisting 7
12 that the incident report be accurate and complete. ,
13 And there were some pr'ocedural, as I would !
14 characterize them, some procedural differences that 15 this was not their responsibility, and it is. And I ,
16 think I've sugge:ted that it is not their 17 responsibility in the final analysis. And if that 18 was the only issue, maybe it would not have 19 escalated. But again, I'm not taking a defense that 20 way. I was wrong.
21 We got into some technical arguments as 22 well about how people felt. And at the time -- and 23 I can only take you back to the time -- that was 24 much more important to me than tne procedural piece.
I ALL POINTS REPORTING (610) 272-6731 l
s.
7 1 When I mentioned that the documentation of this data L
2 was incidental, not that it's insignificant, just 3 that relative to the concern of the real safety 4 aspects, whether they were inoperable or operable, 5 that's where we focused most of our attention, and 6 that's really what created most of the emotion I'm 7 sorry to say.
8 MR. HOLODY: Did you discuss the -- you 9 said you were --
you were led to believe that Bert 10 Williams and Paul Craig were aware of the 11 information that had been researched by Mike 12 Morroni?
13 MR. POLIZZI: Yes, sir.
l 14 MR. HOLODY: Where did you get that --
15 where did you get that belief from?
16 MR. POLIZZI: From Michael, Mike 17 Morroni.
10 MR. HOLODY: Did you question Bert and 19 Paul on that?
20 MR. POLIZZI: Never had a specific do 21 you understand, but let me say this, the 22 conversation that we were having was clearly giving 23 me the implications that they had the data.
24 MR. BRIGGS: Can I clarify for the ALL POINTS REPORTING (610) 272-6731
M W 1
7 1 record? We have moved now from telephone f .
2 conversations and Morroni and Bailey out chasing 3 down qualifications and configuration issues to Bert 4 and Paul showing up in your office?
5 MR. POLIZZI: Yes, we have.
j 6 MR. BRIGGS: And now you're in a 1
J 7 face-to-face meeting with Bert and Paul, and maybe 8 you can describe what happened in that meeting to 9 give some context to some of the -- to the i
10 discuss >:n that we're having.
l 11 MR. POLIZZ1: May I do that?
1 12 MS. SMITH: Sure.
i 4
13 MR. POLIZZI: I think I was suggesting
]
i 1 14 that when I hung up with Mike, it was shortly i
15 thereafter that Bert and Paul showed up at my j i
a l 16 office. I was a little bit surprised on why they 1
17 were really there, considering the fact that we had 18 received this information, understood their concern.
19 The expectation was that they would be satisfied and 20 they would give the incident report to the senior. !
i
! 21 Nonetheless, they were there.
t 22 And I stood up from my desk and I said, !
4 23 I think, something to the effect, I think we got 24 some good news, guys. It looks like things are kind ALL POINTS REPORTING (610) 272-6731 4
1 i
I 7 1 of sorting themselves out here at least for the
'I And I used the term I 2 moment, not an immediate issue.
f 3 we need to document what we know on this itcident l l
4 report. And Bert sugaested that that wasn't his I
4 5 job. i 6 That's true. As I sit here today, it's 7 not necessarily his job to do that. But it was a f
8 simple request to include the information that we 9 had. And I went into a discussion what I've done [
10 here for you, that this is the way we've done it in 11 the past, we really need to make it complete, we 12 need to be accurate so the senior can make an 13 informed decision. We were talking about a 14 significant consideration here or consequence, or I
- 15 wanted to be sure we had it all. Went back and l
- 16 forth, and I'm being brief, but Bert basically i
17 suggested that if he had to write anything, he would i 18 have to say they're inoperable. That struck me as
- 19 odd.
20 MR. HOLODY: Did he say why?
21 MR. POLIZZI: No, sir.
22 MR. HOLODY: Did you ask him why?
s 23 MR. POLIZZI: Yes, I did. And this is 24 an important piece. Even though we were talking ALL POINTS REPORTING (610) 272-6731 i
7 1 about a difference of opinion, I really could never f 2 get an explanation of why Bert felt that they were 3 inoperable. He could not or would not tell me. So 4 he keeps going back to the fact that it's not his 5 job. And yeah, that's true, it's not his job to 6 make determination of operability, that's our job.
7 It's not what I was asking.
8 But we've moved from that to something 9 that is suggesting to him that they're inoperable.
10 And my read and my understanding is that we have the 11 engineering people, and I used those words, we have 12 the engineering people telling us that they're 13 operable.
14 MR. HOLODY: You told him that?
15 MR. POLIZZI: Yes, sir.
16 MR. HOLODY: And he took issue with 17 that?
18 MR. POLIZZI: He took issue with that 19 to the point of view that he took only the issue not 20 that I really have some more information, you 21 haven't heard the whole story. It really kind of 22 became a circular argument where we were once again 23 talking about who should document it and what the 24 procedure is.
ALL POINTS REPORTING (610) 272-6731
Ac b l
7 1 Now at this time, please appreciate l
(
2 that -- and I could have ended it there, I could i
3 have said okay, we agree to disagree, agreeably, and 4 let's go give this to the senior and we'll maren ;
5 forward. L'a t it didn't happen that way. I was l
6 persistent that we needed to get this information on 7 the incident report. And we really didn't solve 8 anything.
4 9 MR. BARBER: Do you know why -- do you ;
10 know why today -- I know you didn't know at the' 11 time -- but do you know why today about the way he 8 l 12 responded the way he did, do you understand why he i
13 did that?
14 MR. POLIZZI: Responded that if he had l 15 to write anything, they would be inoperable?
16 MR. BARBER: Inoperable.
17 MR. POLIZZI: No, sir.
18 MR. BARBER: You don't. How long have 19 you been licensed?
20 MR. POLIZZI: My license is inactive.
21 I was licensed through 1985.
22 MR. BARBER: Through '85. Did you get 23 any training on the TMI 2 accident?
24 MR. POLIZZI: Yes, I believe so.
ALL POINTS REPORTING (610) 272-6731
i l-8 1 MR. BARBER: Specifically independent I(
2 safety engineering function?
4 3 MR. POLIZZI: I don't have any 4 recollection of that specifically. l 5 MR. BARBER: So you don't have any
- 6 recollection of why the independent safety a
, 7 engineering group function was initiated and why 8 they were --
why they were designed as a part of the i 9 TMI --
the lessons learned from the TMI accident to
, 10 be a totally independent group?
11 MR. POLIZZI: No, I didn't make that 4
12 association, no.
13 MR. B AR BE'R : Do you think that Bert may 14 have, based on his comment? .
1 15 MR. POLIZZI: I couldn't speculate on 16 what he was thinking about. That's not where my 17 head was, and I think I've said that. I really l 18 thought we were talking about the technical aspects 19 and that he may have had some additional 20 information, but that's what happened anyway.
21 MR. HOLODY: So am I wrong to assume, 22 and I recognize looking back in hindsight this is --
23 you've had a 107 of time to reflect upon this and 24 we're looking back tra years to this event, but ALL POINTS REPORTING (610) 272-6731
~~ l i
8 1 could you have taken this report -- or you couldn't
( ,
2 have taken it, could you nave said okay, I don't i 3 need an operability determination or I don't need 4 for you to put this additional information on there ,
5, from Mike Morroni and the other individual, just l 6 take it down and give it to the senior, and then 7 when the senior gets it, the senior will then call 8 you to discuss it and say we have to make an 9 operability determination, at which time you could 10 go down there and you could sign it? Or you could 11 have called the other individuals, Mike and Jay, and 12 had them come down, Iacause they're the ones that 13 provided you the irformation and they could have 14 signed it, could that have occurred?
15 MR. POLIZZI: Yes, it could have.
16 MR. LANNING: In fact, isn't that your 17 position? Isn't the process that you're using to 18 get additional information enhanced or contrary to 19 your existing procedures?
20 MR. POLIZZI: Does it enhance? I'm not 21 sure. i 22 MR. LANNING: Your desire to make the 23 incident report more complete in going and getting 24 additional information and relaying that on to try i
ALL POINTS REPORTING (610) 272-6731
=
so 8 1 to improve the IR, and you indicated that
(
2 documentation was incidental to this, and you also 3 indicated that you were doing thils because you were 4 trying to relieve the senior operator of the burden 5 of making additional phone calls, but isn't that 6 your process, isn't that the way the system is 7 supposed to work?
8 MR. POLIZZI: Yes, that's the way now.
9 MR. LANNING: So wouldn't you agree 10 that you violated your own procedures in what you 11 were doing to process this information?
12 MR. POLIZZI: I wouldn't go so far as 13 to say that. The NAP-6 lays out clearly and for 14 obvious reasons, and I think it's accurate there's 15 no reason to think otherwise, that any documentation 16 of a concern should go to the onduty Senior Nuclear 17 Shift Supervisor. It wouldn't be appropriate to 18 send it to me, it wouldn't be appropriate to send it 19 to anybody actually who's not there 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
20 But I'm trying to emphasize the point 21 that in the area of these engineering issues, where ]
l 22 there was a sense of ambiguity about a decision that 23 could be made, we clearly tried to provide as much 24 information as possible so that the senior could I
l ALL POINTS REPORTING (610) 272-6731
l 8 1 make an informed decision.
(
2 MR. LANNING: Is that part of your 3 existing procedures?
4 MR. POLIZZI: Part of the existirm us 5 being today, I would not know that.
6 MR. LANNING: Well in 1992, did you 7 have procedures that said make the engineering 8 aspects on the IR as clear as possible prior to 9 submitting it to -- -
10 MR. POLIZZI: Yes, sir. The NAP-6 does 11 suggest that the information should be as complete 12 and accurate as possible. ;
33 MR. LANNING: But that gets us back to 14 the auxiliary operator to document the engineering 15 aspects prior to submitting an IR. I would contend 16 that that's not part of your process, that the idea i 17 is to get that deficiency known to Operations and l 18 then send additional requests to Engineering or 19 whomever to get the additional information to make 20 the operability determination. i l
21 MR. POLIZZI: There's one subtle 22 difference that I'd like to bring you back to. It 23 was clear to me tnat both Bert and Paul --
and I'll 24 only say Bert, because I have that from Morroni --
ALL POINTS REPORTING (610) 272-6731 1
8 1 understood the information that I had. I don't know i
(
2 if they had more information, but they at least had 3 what I had.
4 So there's kind of a subtle difference 5 between an aux operator coming up to me and saying 6 there's an incident report and me saying well we've 7 got to document something on this. That's not the 8 case here. I wouldn't have expected them to do 9 anything. And that's the whole basis for the 10 actions we took frot 10 or so in the morning on.
11 MR. WHITE: But isn't that an 12 unreasonable -- and I'm not one to put words in your 13 mouth here, Mr. Polizzi, but again, if they are 14 operating, and I'm assuming that you recognize that 9
15 they're operating as independent safety evaluation l 16 group members, SRG, independent of the line 17 organization, if they are identifying a potential 18 safety significant event in the field and they're 19 documenting that in an incident report, regardless 20 of your desire to try to make this incident report 21 to be opened and closed in one swoop, that their 22 process and the way they understand the process and 23 the way they understood NAP-6 is that we document --
24 we make the finding, we document. Operations then ALL POINTS REPORTING (610) 272-6731 li
>= 4 --a . -- a*,
4 . .
4 9 1 has the responsibility to determine whether or not I
!(
2 the issue requires some operability determination or 3 what that decision making is. Is that a reasonable 4 expectation on your part, do you think, to insist?
5 MR. POLIZZI: I will not argue that 6 point. And I freely admit that my judgment was 7 wrong.
! 8 MR. WHITE: So in your paper here, you i
9 identified these disagreements. First there was a 10 procedural d is a g re eraen t and' that procedural 11 disagreement was -- well you tell me what was the 12 procedural disagreement?
13 MR. POLIZZI: The procedural l
) 14 disagrerement was really who the incident report I 15 should go to and the fact that we needed to l
l 16 basically make it as complete as possible, which is !
l 17 in the NAP, that it should be detailed. Now I 18 never, ever made the connection that they were
! 19 operating -- and maybe this was a shortcoming -- but 20 that there was anything different about this 21 incident report because they were an independent 22 SRG. That never, ever crossed my mind.
23 This was one incident report of 900 or
~
24 a thousand that we get in any given year. I never ALL POINTS REPORTING (610) 272-6731
9 1 put any significance to the submittee, if you will,
(
2 or the initiator. It could have been anybody that 3 initiated this. And if they'had the data that I 4 thought they had, it was a simple process just to 5 document that and we'll give it to the senior and 6 we'll go from there. That's what I'm trying to say, 7 John.
8 MR. WHITE: So if I understand you 9 correctly, what you're saying is you didn't make 10 that connection?
11 MR. POLIZZI: I did not. I did not 12 make that connection, regretfully.
13 MR. WHITE: Do you recognize that --
14 it's a question that Scott Barber asked earlier --
15 do you recognize what that entails, what that 16 requires, what the independent safety evaluation i
17 group function entails today as opposed to what you 18 understood back in 1992, do you have a different 19 perspective?
20 MR. POLIZZI: I have a different 21 perception of the regulation and how my behavior 22 related to that. I can't say that I have a 23 different perception on the independence of safety 24 review any different than I had then. I had an ALL POINTS REPORTING (610) 272-6731
9 1 appreciation for it then and I have the same
(
2 appreciation for it now.
3 MR. WHITE: You also discussed the 4 technical disagreement. And I take it the technical 5 disagreement is much of what we discussed here. And 6 that is you became frustrated with them because it 7 was clear in your mind, based upon the research that 8 Mike Morroni and others had done, that there wasn't 9 an immediate operability problem from your 10 perception. You had some reasonable assurance of 11 that and you were frustrated because they didn't see 12 it that way, they would not admit that, they would 13 not document that as such on their incident report 14 that they were creating.
15 MR. POLIZZI: It's okay to disagree.
16 That wasn't my point of contention. The issue was 17 that I really didn't know what they were disagreeing 18 with. I just knew that there was a disagreement.
19 And again that gets back to the errors that were 20 made that day. I should have just said okay, we 21 agree to disagree here. I don't know why, but let's 22 go ahead and process this thing. And if you feel 23 uncomfortable with it, we can talk more about it.
24 MR. WHITE: But as I read your ALL POINTS REPORTING (610) 272-6731
9 1 statement here, on page 6 you say that "I became i f 2 increasingly fructrated with the conversation. I 3 wanted to know why Bert disagreed to the operability 4 conclusions that Jay, Mike and I reached, yet he 5 either could not or would not tell me."
6 MR. POLIZZI: That's right.
7 MR. WHITE: So your frustration was 8 that he may disagree, but he did not provide you any 9 reason why he would not sign on to the incident 10 report with this conclusion that your engineering 11 group had come to?
12 MR. POLIZZI: Yes, that is correct. i 13 MR. HOLODY: And Operations could have I
14 done that?
15 MR. POLIZZI: Operations could have 16 done that.
17' MR. HOLODY: Operations could have 18 signed on to the incident report, instead af trying 19 to encourage or entice or get him to agree, you 20 could have simply stated okay, that's not your 21 responsibility to even put that kind of information 22 down that would reflect upon an operability 23 determination, and you knew, you had calls with this 24 individual, you didn't know that he had calls with ALL POINTS REPORTING (610) 272-6731
! 9 1 the individual, so you could have just documented or
!' (
2 you could have gotten the senior or gotten Mike and ;
3 Jay to come down and do it, you could have done 4 that?
5 MR. POLIZZI: Yes, I could. And it l
6 would have been the right thing to do. l 7 MR. HOLODY: But it never dawned on you 8 at that time, or did it? Did it dawn on you that 9 that was an alternative?
! 10 MR. POLIZZI: Let me say this, there's 11 another piece in the memo that --
it's there. I 12 reached that point. I reached the point where I was 10 3 13 willing to do that. And I asked for the incident ,
l 14 report. I asked for it in a derogatory way. The 4
15 language 1 used was improper. But I asked for the i
16 incident report. And I was going to document what I ,
4 i
17 knew and end it.
18 I want you to appreciate that I was l 1
1 19 concerned that the two SRG engineers for some reason l 20 were at variance with what others were saying. That i
l 21 bothered me. That is not the way we would operate. l i
22 We look to have concensus. Everybody may not be one i
- l 23 hundred percent, but normally we would strive for i i
24 concensus, no matter who that is, irrespective of l
ALL POINTS REPORTING (610) 272-6731
10 1 levels or position or organization. And I was
(
2 failing. And I made some other mistakes which 3 really failed. But that's neither here nor there 4 now. I know where I am.
5 But I did ask for the incident report.
6 And to answer your question directly, I was prepared 7 to do that. Bert would not give me the incident 8 report. And even at that point I could have said 9 okay, please take it to the senior, because that was 10 his response, I have to take it to the senior. So 11 it went through a number of levels or iterations of 12 frustration.
13 My perception now was that there was 14 something I didn't understand. Perceiving it maybe 15 a stubbornness, but I don't want to put a 16 characterization on it. We weren't communicating, 17 and that was clear, and I wasn't helping the 18 situation.
19 MR. HOLODY: What was the time frame?
20 Give me an idea from when they first came into your 21 office with the report after having seen the senior 22 to when the meeting with Mr. Vondra concluded and 23 they were --
they left the site. How long was that?
24 Was that 10 minutes? Was that an hour and a half?
ALL POINTS REPORTING (610) 272-6731
10 1 MR. POLIZZ1: My recollection is that
(' 2 it was about 10 minutes, 10, 15 minutes in my 3 office, the walk down to Cal's office, I spent about 4 10 minutes with him before they came in, and than 5 about 10 minutes, 15 minutes in his office. So the 6 whole affair could have been from the first time 7 they arrived at my doorstep, 45 minutes, certainly 8 less than an hour.
9 MR. HOLODY: This is in the afternoon?
10 MR. POLIZZI: This is right around the 11 12:00, little after 12:00 time frame.
12 MR. HOLODY: Was this a particularly 13 busy day or was it a routinely busy day or was it a 14 busy, busy day?
15 MR. POLIZZI: It was a busy day.
16 Thursdays are busy because we have our SORC 17 committee meeting.
18 MR. SATORIUS: Were both units 19 operating?
20 MR. POLIZZI: They were both operating, 21 as I recall. So it's really half a day that you 22 have to get your things done. So from that point of 23 view, it's a busy day. The General Manager was kind 24 of involved with all kinds of other things, clearly ALL POINTS REPORTING (610) 272-6731
L_ e _Aa_-. u 4 ._m # 4 . - _ a_o, . -_ m a -++ a t
10 1 with the IMPO evaluation exit coming up with the
(
2 executives in Newark. So he was a little bit l t
3 distracted with that. So yes, I would say. !
4 MR. WHITE: So moving on now from this l 5 point --
6 MR. POLIZZI: Well'at the point I guess 7 I'm where I do ask for the incident report, give me l 8 the blank thing so I could do it. Shortly after ,
9 that, I mean almost in the next breath after, Bert 10 says no, we have to give it to the senior, according i t
11 to the procedures.
12 Paul makes a comment. That's real}y !
13 the only comment that I recall Paul making. And he i
14 says we cannot give it to you because you don't 15 follow procedures. Regretfully that was the straw 16 that broke the camel's back. At that point I 17 stopped, I called the General Manager and I got him 18 on the phone and said that I was having a problem I 19 really couldn't get through and I would like you to 20 be part of this.
21 I even suggested something to the 22 effect that they were going to have to talk to the 23 General Manager. You're going to have to explain 24 this to the General Manager. I believe those were ALL POINTS REPORTING (610) 272-6731
- l l
,J O 1 my words. Cal said okay, come right down.
(. !
2 I got off the phone, we walked out of 3 my office. I was walking rapidly. If you're 4 looking for some of the details, Jay Bailey was 5 outside my office, I don't know why he was there, 6 for some other reason to see me, which he never did ;
7 see me about, and I don't know why. But --
so he 8 comes, he asks if he can come. I said come on, you 9 might as well come. :le was a principal in doing 10 some of this work. He comes with me and we go down ;
i 11 to Cal's office. And I'm upset. I won't deny that 12 I'm upset.
13 I go into Cal's office, and I needed 14 that time to calm down and certainly to bring him up 15 to speed. He has no knowledge of this now. Two 16 hours of work and he needs to understand where we :
17 are before he can deal with the issue. I brief him 18 on where we are, what we had learned, who had done 19 what. And again, I took about 10, 15 minutes.
20 MR. WHITE: This is the first time Cal 1 21 is aware of this problem is when you bring it to his 22 attention at that time?
23 MR. POLIZZI: To the best of my 24 knowledge, it was the first time. There was no i
ALL POINTS REPORTING (610) 272-6731 :
l l
. ~ ._. .- _ . - .
}
10 1 other way he would get this. And this was atypical.
(
2 I didn't walk down an.d bring issues to the General 3 Manager. -
4 He said okay. Before he asked the ,
5 gentlemen to come in, he starts looking at the NAPS 6 and looks at the procedures and kind of researches 7 his memory on NAP-6, the DEF process. I think NAP-D [
t 8 I think, and he asked them to come in. ,
9 I don't have a great deal to say really 10 about the nature of the conversation that took 11 place, who started talking and so forth. But it was 12 very similar to the conversation that took place in l
13 my office, basically dealing with the incident 14 report, who should get it, documentation, the ,
15 same --
16 MR. LANNING: Was operability discussed 17 between you and Vondra?
18 MR. POLIZZI: Yes, it was. Yes, it 19 was.
20 MR. LANNING: In what context was it 21 discussed?
22 MR. POLIZZI: Based on the information 23 that we had learned strictly to the points of the 24 immediate operability from configuration and ALL POINTS REPORTING (610) 272-6731
11 1 qualification. So I believe Cal was aware of all
(
2 those issues. And in the discussion that he was 3 having in his meeting with Bert, it was clear that 4 he had a sense of what the concerns were.
5 MR. LANNING: This was based on what 6 you had told him based on your conversations with 7 other folks; is that right?
i 8 MR. POLIZZI: Yes, sir. Yes, sir.
9 MR. LANNING: Would you say he had a 30 fair understanding of the total issue before 11 Wil]iams and Craig walked into the room?
12 MR. POLIZZI: I would say yes.
13 MR. BARBER: Did you discuss the fact 14 that you were angry with Williams and Craig and your 15 demeanor in your office, or was it strictly the 16 presentation of the issue?
17 MR. POLIZZI: No, it was obvious that I 18 was angry, I was upset.
19 MR. BRIGGS: Did you discuss that was 20 the question.
21 MR. POLIZZI: Did I discuss that? No, 22 I don't think I did. I don't think I did.
23 MR. WHITE: When you were meeting with 24 Williams and Craig as this escalated, were they on ALL POINTS REPORTING (610) 272-6731
s.
i 11 1 the defensive, do you think, at that point so-that 1 i
(
2 they would be on the defensive when they met with 3 Cal?
4 MR. POLIZZI: No. As a matter of fact, -
5 as I suggested, Paul was very quiet, didn't say 6 much. And Bert was calm. I mean he did not lose 7 his composure. He stuck to the story. Although I 8 never knew what the story was, if there was one, but 9 he was calm. But I will tell you that I don't think 10 there was any doubt in their mind that I was 11 agitated.
12 MR. LANNING: Weren't they correct in 13 saying that they could not give you the IR, that 14 they had to give it to the Senior Reactor Operator?
15 Isn't that by your procedure?
16 MR. POLIZZI: They are not -- ,
17 MR. LANNING: Yes or no would be fine.
18 MR. POLIZZI: Repeat the question, 19 please.
20 MR. LANNING: Were they not correct 21 when they said they could not give you the incident 22 report, that they had to give it to the Senior 23 Reactor Operator?
24 MR. POLIZZI: They are essentially ,
ALL POINTS REPORTING (610) 272-6731
11 1 correct.
k 2 MR. LANNING: And isn't that by your 3 procedures?
4 MR. POLIZZI: Yes, sir. That's one of 5 the procedures, yes. If I may though, there is no 6 appreciable difference between the senior and the 7 Operations management, the operating engineers or 8 myself. If you look at the form --
and I'm not 9 making a big issue out of this, please don't get me 10 wrong, I answered the question yes --
it says Senior 11 Nuclear Shift Supervisor / Ops Manager. Although the 12 narration in the procedure doesn't say that they 13 should give it to the ops Manager. So I had never 14 been in this situation before where people would not 15 look at me or my operating engineers as they would 16 to the Senior Nuclear Shift Supervisor. But I can 17 tell you that very few ever came to me, very, very 18 few or even through me. Just a point of ,
19 clarification. I did not at the time see the major 20 distinction between myself and the senior. )
l 21 MR. SATORIUS: Was your license active 1
22 at that time?
23 MR. POLIZZI: No, it was not.
24 MR. SATORIUS: So you were not --
you l
ALL POINTS REPORTING (610) 272-6731
11 1 had no license responsibilities such that you could
(
2 make the determination?
3 MR. POLIZZI: That's correct. The 4 determination would have to be made by the licensed 5 operator.
6 MR. LANNING: So the discussion in 7 Vondra's office was primarily directed as who should 8 receive the IR?
9 MR. POLIZZI: Who should receive the 10 incident report. The nature of the concern was 11 generally discussed. The majority of the 12 conversation surrounded the use of the DEF process, 13 the discrepancy or def'iciency evaluation form. That 14 may be a vehicle. And Cal was trying to bring this 15 to closure. As a matter of fact, after I finished 16 briefing him, I got the impression that this was 17 going to be easy to unscrew.
18 MR. WHITE: Did Cal see it your way?
19 MR. POLIZZI: I believe he did. ,
20 MR. WHITE: Did he agree with your :
l 21 perception of the issue? l l
22 MR. POLIZZI: I believe he did. From -
l 23 the point of view, John, that he had the 24 information, he knew that I had the information from ALL POINTS REPOhfING (610) 272-6731
i I
il 1 Bailey and Morroni. And in the meeting to support
-(
2 that, Jay didn't say very much, but Jay was in the 3 meeting, if you will, supported the conclusion that 4 he had given me regarding the information of t._
1 5 FSAR, that yes, he had looked at it and he didn't 6 have any immediate concern about this, and he was 7 doing some additional work and that type of thing.
8 So the conversation really went back and forth that 9 way.
10 MR. WHITE: It started off calm?
12 11 MR. POLIZZI: It was all very calm, t 12 very calm, trying to reach some concensus on how we 13 could resolve this. Let's understand what the 14 problem was. But it escalated.
15 MR. WHITF: Why?
16 MR. POLIZZI: It's hard for me to 17 articulate really why it escalated, just like it's 18 difficult for me to sit here and say hey, what 19 happened in my office that I couldn't manage this.
20 There seemed to be a reluctance about accepting the 21 operability determination that was essentially being 22 made by station management in cooperation with --
23 MR. WHITE: Was it the same type of ,
i 24 frustration that you felt toward Williams because ALL POINTS REPORTING (610) 272-6731 i
d b t
they did not readily sign on to your assessment, Cal !
12 1 '
(
2 had the same --
l 3 MR. POLIZZI: Essent:ially , yes. Again, 4 there was a point where the language would suggest 5 that, that there was an insistence that this had to 6 go to the senior. That a declaration of 4
7 inoperability would have to be made and the tech 8 specs accordingly applied, i.e., a potential unit
- 9 shutdown under 303. And Bert clearly expressed an l l
10 affirmative to those comments by Cal to the extent 11 of the conversation would that make you happy. Bert i
12 said yes. So that's where we were. Very similar to l
a 13 where we were in my office then.
14 MR. SATORIUS: Which you are l 4 15 essentially faced with both units have to be shut i
16 down? !
a l 1/ MR. POLIZZI: Yeah, if you made the 18 determination that they were inoperable. But 19 remember, we were not there. The station had 4
20 decided that they were not inoperable at this point.
21 The issue was --
22 MR. WHITE: But up to this point, the
- 23 station had not documented the operability i
24 determination?
ALL POINTS REPORTING (610) 272-6731 l
f 12 1 MR. POLIZZI: We had not even seen the
(
2 incident report to make that documentation. The 3 concern was why did you guys -- why did you folks ,
4 feel that they're inoperable, can you tell us.
5 Besides that, it has to go to the senior. And 6 again, that was wrong, that was wrong to make that I
7 same insistence down there.
8 MR. LANNING: Did they say to Vondra 9 that they thought it was inoperable, or had you l 10 communicated the fact they thought it was inoperable 11 to Vondra?
12 MR. POLIZZI: I said very little in the 13 meeting.
14 MR. LANNING: Before the meeting?
15 MR. POLIZZI: Yes, yes. Cal understood 16 that we were making a statement that we believed 17 they were operable, the SRG engineers believed that 18 they were inoperable. And that's from the statement 19 1 had from Bert.
20 MR. SATORIUS: Any kind of history as 21 far as confrontations between Operations and SRGT 22 MR. POLIZZI: I can't tell you that 23 there were conflicts. I have no knowledge of that.
24 There are clearly some personality differences from i f
ALL POINTS REPORTING (610) 272-6731
12 1 time to time. But as an organization, as a
(
2 department, I am not privy to a confrontational 3 environment that existed between SRG as a group and 4 Operations as a group.
5 MR. (LChM : So that statement that 6 PSE&G made this morning that there was a 7 confrontational environment that may have 8 contributed to this, you don't agree with that?
9 MR. POLIZZI: I do not agree with that.
10 MR. HOLODY: The issue of doing a 11 deficiency report versus an incident report, when 12 did that first come up?
13 MR. POLIZZI: In Cal's office.
14 Actually before we met with the people.
15 MR. HOLODY: That was discussed between 16 you and Cal?
17 MR. POLIZZI: It was. Cal initiated 18 the-discussion. It never even dawned on me, quite 19 honestly, the use of a DEF. But appreciate that Cal 20 was understanding the problems we were having with 21 processing this incident report and he was looking 22 for another solution. And thus he targeted the DEF, 23 which would not have been inappropriate any more l
24 than the incident report is nct inappropriate. l l
l ALL POINTS REPORTING (610) 272-6731 l
I
12 1 They're both adequate vehicles.
Is 2 MR. HOLODY: But didn't that require --
3 the deficiency report did not require an operability 4 determination; is that correct?
5 MR. POLIZZI: No, that's not. The 6 deficiency report' process is very much linked with 7 the incident report process. " hen that procedure 8 was originally generated in cur engineering group, 9 it was recognized that we did not have this 10 connection, that if somebody in Engineering 11 identified a problem, what do you do with that. And 12 maybe there was an appreciation that what you have
, 13 found could be an operability /reportability concern, 14 i.e., the tech specs. So that document was 15 basically linked to the incident report, that you 16 would have to do an initial review of the 17 information.
18 So I offer this, if the same 19 information was documented on the DEF as on the 20 incident report, the review would have had to be l
21 very timely by the next individual supervisory l l
22 indivi, dual, that I think if you look at the form --
23 I don't have it in front of me -- but would do the 1
24 initial assessment. They would essentially come up ALL POINTS REPORTING (610) 272-6731
i i
12 1 with the same information that we had, at least i '
2 initially. And by that information, clearly could i 3 reach the conclusion that we'did not have an 4 operability /reportability concern which would never i trigger even a notification to the station. I 5
6 MR. HOLODY: Could this have l 7 occurred -- since I'm not familiar with the 8 deficiency report, if it was documented on a 9 deficiency report, could somebody have then, in 13 10 terms of dispositioning that report, written it 11 down, evaluate the FSAR, determine the impact of the i
12 commercial grade aspects of the regulators on 13 operability to the component, determine the impacts 14 of the configuration on the operability of the i 15 component and complete that within three weeks?
16 Would that have been acceptable to disposition that 17 deficiency report?
18 MR. POLIZZI-. Not in my mind. And I'd 19 like to cite the actions that I took on a lot less 20 information on a note and then on a verbal from 21 Bert. So I didn't find it in the way I conducted a 22 the operations at the station that something like 23 this should sit for a period of three weeks without 4
24 an initial assessment of where we were. And my time ALL POINTS REPORTING (610) 272-6731 D'
33 1 clock was to have a disposition, whatever that
(
2 disposition may be, bi the end of the day. I did 3 not want to go home that day without reaching some 4 conclusion, some concensus on where we were. So 5 that's --
6 MR. WHITE: But the DEF was offered as 7 a mechanism to resolve this situation with Williams 8 and Craig. But again back to the original finding, 9 configuration is different than the FSAR describes, 10 components are commercial grade and not qualified as 11 safety related, at least that's what the 12 documentation would indicate that Craig and Williams 13 were aware ot, what's the proper vehicle for that 14 type of finding? Is it an incident report or DEF?
15 MR. POLIZZI: I'll say again either 16 vehicle is appropriate. The DEF allows you to go 17 through a certain amount of initial investigation, 18 very similar to the incident report that you have to 19 do to reach the operability /reportability 20 determination.
21 MR. WHITE: Then what's the difference?
22 MR. POLIZZI: Essentially there is 23 none.
24 MR. WHITE: So it's immaterial what ALL POINTS REPORTING (610) 272-6731
l 1
l
\
13 1 paper you use; is that right?
I 2 MR. POLIZZI: It is immaterial.
3 MR. HOLODY: But isn't -- help me out 4 here. If somebody gives you an incident report, are 5 you going to go home that day without an operability 6 determination?
4 7 MR. POLIZZI: In this particular case, 8 clearly no.
9 MR. HOLODY: In any other case, would 10 you?
11 MR. POLIZZI: It depends on the nature 12 of the extensiveness of what has to be done, the 1
13 reviews, the involvement. I 14 MR. HOLODY: If somebody raises an 15 issue that calls into question the operability of a i
16 component? I 1
17 MR. POLIZZI: It would be worked -- let l 18 me put it this way, it would be worked on a 19 continuum. Peonle would basically work on that 20 thing past normal quitting time until we had some 21 reasonable assurance of where we were. There are no 22 gaps when it comes to operability. There are none.
23 I wouldn't accept that.
24 MR. HOLODY: So when you fill out a ALL POINTS REPORTING (610) 272-6731
i l
l 13 1 deficiency report, are you saying that whether it's ,
I
(
2 SRG or QA or Engineering, Maintenance, whoever fills 3 out the deficiency report, is Ops brought into the 4 cycle immediately? I 5 MR. POLIZZI: They're brought into the 6 cycle once that initial evaluation is done. And 7 there's a certain amount of prudency that is 8 necessary here. You can't document something and 9 let it sit in a basket. You have to have the same 10 appreciation that there could have been an 11 operability question. And that is clearly on the 12 DEF form, to get that timely input and awareness 13 from the station level.
14 If there is no need to make that 15 contact, then there is a priority in the procedure 16 that the items can be ultimately dispositioned. But 17 up to that initial assessment, it needs to operate 18 in the same fashion as far as getting to at least an 19 initial assessment of where you are and making that 20 operability /reportability connection i.e., tech 21 specs. So they're really one and the same document 22 in many ways.
23 MR. BRIGGS: What was Bert's reaction 24 to this distinction between a DEF and an IR in Cal's 4
ALL POINTS REPORTING (610) 272-6731
~ - ^ ^ ^ '
l
! i 13 1 office?
l 2 MR. POLIZZI: Bert seemed to be 3 reluctant to file the DEF. And the only thing I !
4 could offer was that he suggested that it took too 5 long, and that's really about the extent of.
6 MR. SATORIUS: Isn't that the 7 justification?
8 MR. HOLODY: What's the difference?
9 You just told me there's no difference between these 10 two documents. So if you want to fill out an 11 incident report or a deficiency report, if there's 12 an operability issue that comes into question, we 33 got to act on it. And you're already aware of it, ,
14 whether you call it a DEF or an IR, you're going to 15 have to nake that decision fairly quick, if what 16 you're telling me is just -- if what you just told 17 me is true. So what would have been the difference 18 in the two documents? And if he was reluctant to 19 call it a DEF or an IR or call it whatever you want, 20 here's a piece of paper that has a difference to it.
21 MR. POLIZZI: I'm not sure if there was 22 a question here, but I think it's a key point to 23 clear it up, because you suggested some. thing to the i
24 effect that it would take long. What I'm saying is ALL POINTS REPORTING (610) 272-6731 '
l l
- - -______--_0
13 1 that that's not the process. The DEF process
(
2 requires up to a point that that disposition 3 continue to where you have made an operability /
14 4 reportability assessment. At that point in time, if 5 you say yes, operable / inoperable tech spec 6 significance and/or reportability, it immediately 7 triggers a response to the station immediately.
8 That's the procedural basis.
9 MR. BARBER: Isn't the difference 10 between the IR and the DEF who it goes to first? I 11 mean in an IR, you've got a summary statement or 12 description of what the problem is, and then the 13 nest block is a description or a signature area l 14 where the Senior Nuclear Shift Supervisor makes a 15 judgment about operability, whereas in a DEF, 16 instead of necessarily coming to the shift first, it 17 goes to Engineering, Engineering does their thing, 18 going through, looking at the FSAR, looking at all 19 the background documentation, all the documentation 20 and they've got a chance to null all this over, and 21 then, based on that, write an informed decision, if 22 you will, that will go to the shift and it's just a 23 matter of, a not a rubber stamp, but a concurrence, i
24 if you will, in Engineering's position. Isn't that ALL POINTS REPORTING (610) 272-6731
14 1 really the true difference here?
i t
2 So in one case you may have something, !
3 if it's written up on a DEF,'it may in fact be in f l
4 process for a day or two or three or a week. In the j 5 case of an incident report, by the way the process 6 works, it has to go to the shift after you've l 7 finished your problem statement.
8 MR. POLIZZI: You're right on the 9 pathways. The incident report is strictly a station 10 document, not something that's used outside the Il station. The DEF process is predominantly a 12 document used by Engineering.
13 However, I'm not sure I agree that the 14 DEP would languish for a day or three days or a week 15 before people would disposition the operability or 16 tech spec concern on something that would be 17 associated with an operability or safety related 18 component. If that's the case, that's the 19 shortcoming of an individual or whatever.
20 The process would drive you strictly to i
21 go ahead and at least make that determination. And 22 then from there, based on what you find, if it is 23 inappropriate and it's a tech spec related type of 24 issue, the station is notified and an incident ALL POINTS REPORTING (610) 272-G731
14 1 report is generated. So the PCF never really stands l
2 alone. If it connects with the station, the 3 incident report would be generated and we would 4 basically take the ection right then and there.
5 Because you would have the initiation, 6 the initiator would have completed what the concern 7 was and there would be some initial assessment. So 8 I guess we agree. But the only dise.greement I would ,
9 have is that there isn't any delay in a ,o u r e 10 performance of the DEF process any more than the 11 incident report up to the point of 12 operability /reportability. .
13 MR. HOLODY: So when the DEF was i l
14 offered as an alternativo during this meeting, what l 15 was envisioned would have happened? If Bert 16 Williams had said great, that's a good idea, I'll 17 write a DEF instead of an IR, what would have then 18 happened? What did you envision would have i
19 happened?
20 MR. POLIZZI: The only difference there 21 is that the disposition would be done, the initial 22 assessment would be done by somebody else. By the process, it would not be Bert Williams or Paul j 23 l
I 24 Craig. It would be done by the Engineering l
- l ALL POINTS REPORTING (610) 272-6731
14 1 disciplines.
(
2 So they would essentially complete that 3 section of the DEF and then bring that to the i
4 station if we had a problem. But in this case, they 5 would not be. So it probably would not have come to 6 the station at that point in time. So the key 7 difference is who really would have documented the 8 information that we had learned through verbal 9 conversations. The same information that I was --
P 10 that we needed probably wouldn't be as detailed, the 11 same information that would be utilized on the 12 MR. HOLODY: So instead of Operations 13 being held accountable for documenting that, they 14 got input from Engineering and then documented that 15 on an incident report?
16 MR. POLIZZI: It would essentially be 17' attached.
i 18 MR. HOLODY: Engineering would have 19 been responsible for documenting itself, is that 20 what you're saying, on the deficiency report?
21 MR. POLIZZI: Right.
22 MR. HOLODY: That the component was 23 operable, and then that after been provided to Ops 24 and said here was a problem and it's being resolved?
I ALL POINTS REPORTING (610) 272-6731 f A--
14 1 MR. POLIZZI: Well I said yes, but what
(
2 I'm offering here may have not even made it to the 3 station at that point in time, because there was no 4 immediate declaration of inoperability.
5 MR. BRIGGS: Just to be clear, you're 6 not the person arguing for a DEF as opposed to an 7 IR, this is a discussion that you're observing?
8 MR. POLIZZI: No, right. And as I 9 said, this was just a vehicle that Cal was trying to 1
10 use to bring closure to this. It had nothing to do 11 with, you know, process or how long it should take 12 or anything like that. If this was adequate to 13 those fellows, fine. But it was not an issue to me. l 14 The incident report was fine. But I cannot just 15 have that incident report not reflect the l 16 information that we had on an engineering issue, 17 that is ambiguous.
15 18 MR. HOLODY: So you were essentially 19 mute on this issue? 3 20 MR. POLIZZI: Yes.
21 MR. HOLODY: Cal raised the issue and 22 you offered no comment on that?
23 MR. POLIZZI: I offered no comment.
24 Just like I offered here, it was it's a no, never ALL POINTS REPORTING (610) 272-6731 I
15 1 mind to me on which document you use. The results
(
2 would have been the same. l 3 MR. BRIGGS: Why don't you bring us to 4 closure on this meeting that's going on with Cal and 5 you and Bert and Paul and Jay Bailey?
6 MR. POLIZZI: I think we've talked 7 about where we were and the frustration's building.
8 At one point, which is as we get to the end, Bert 9 suggested that if we did not accept this as is, he 10 would have to write a Safety Quality Concern on Mr.
11 Vondra. And I have to tell you, and this was an 12 argument this morning -- I shouldn't say argument, 13 but there were some words on this this morning, but 14 I want to say for the record my perception was clear 15 on what the safety concern was going to be. I can't 16 read Bert's mind, but all I can suggest is that I I
17 believe it was directed personally to Cal. It !
l 18 wasn't an iteration that it was the third possible 19 vehicle that could be used to document this concern.
20 It was to him directly that he did not have 21 whatever, the safety consciousness to go forward 22 with this.
23 That got Cal very upset. He reacted i 24 immediately to it. And just like me in my office, I
ALL POINTS REPORTING (610) 272-6731
15 1 I'm sure it was a spur of the moment decision. As a
(
2 matter of fact, I'm convinced it's a spur of the 3 moment decision. And he suggested that Bert knew 4 just what he was d o .i ng , go ahead and write what you 5 have to write and please get out of my office. He 6 went a little further, but essentially that was it.
7 Get out of my office. The meeting essentially 8 ended.
9 MR. BRIGGS: There was a statement in 10 the letter of enforcement --
invitation to this-11 enforcement conference that I believe Mr. White read 12 at the outset of this session and at the outset of 13 the session this morning that says that it was with 14 your cooperation and advice that Cal told Bert and 15 Paul to get out of the office. Would you comment on 16 that statement?
17 MR. POLIZZI: I really don't know what 18 to say about that. As I suggested, it was -- I i
19 think it was a shock to everybody. It certainly was 20 a shock to me. There was nothing that would -- they 21 were -- emotions were tense, if you will. But until 22 the point where Bert suggested he had to write a 23 safety concern, and there was no indication that 24 this was going to happen, and it came out, it just i
ALL POINTS REPORTING (610) 272-6731
15 1 blurted out of Cal's mouth.
(' 2 MR. BRIGGS: Was it with your 3 cooperation and advice?
4 MR. POLIZZI: No. I was surprised by 5 it as much as anybody. And clearly -- and I did 6 notice that in the letter. It was not by my advice 7 or my cooperation.
8 MR. BARBER: Did you later show support 9 by agreeing to draft the letter that naid that these 10 two engineers should have no further 11 responsibilities related to Salem operations?
12 MR. POLIZZI: I will answer that by 13 saying no. Now, I had'no intention of writing the 14 letter or discussion of writing the letter. The 15 letter came later on that day to me, go ahead and do 16 this and document this thing. And I essentially did 17 that at the request of Cal. However, you may say --
18 MR. BARBER: Did you agree with what 4
19 the sentiment though -- I mean he was saying I want 20 you to draft a letter and send it to Larry Reiter 21 that says something to the effect that the behavior 22 in ny office earlier today was really aberrant, I 23 really don't want them to have anymore to do with 24 the Salem operations. Did you offer anything by way ALL POINTS REPORTING (610) 272-6731
l l
15 1 of a rebutta3 to that or did you refute the need to
- (
2 do that in any way, shape or form?
3 MR. POLIZZI: Not at that point. I 4 MR. BRIGGS: Let's talk about what 5 point in time, where were you when this discussion 6 is going on about this letter?
7 MR. POLIZZI: At home. At home. Over 8 the phone. There was a sense of urgency to get it 9 out because Cal was going to be away on Friday at 10 the IMPO exit meeting and he was planning on 11 vacation the following week. So he really wanted to i
12 have it tomorrow. And he suggested that I have it 13 there tomorrow when he got back from Newark.
14 So I drafted the letter that night. To 5
15 answer your question, I think we both had some 16 confidence concerns. I will suggest that. However, 17 I didn't think it was my role at my level in the
- 18 station to be suggesting that somebody else be 19 removed in another department, notwithstanding 20 safety review. It could be anybody, it's not your 21 prerogative to be making these statements.
22 MS. SMITH: So did Cal tell you to put 23 that part in the letter about removing Craig and 24 Williams from the site?
ALL POINTS REPORTING (630) 272-6731
15 1 MR. POLIZZI: Yes, he did. Yes, he .
(
2 did.
3 MS. SMITH: That wa s.n ' t at your !
i 4 initiative?
5 MR. POLIZZI: The content of the letter 6 was essentially cal's desires. I drafted that 7 letter, I handed that letter from a typed version --
8 excuse me, typed version that I had at home to Cal'r, 9 secretary that morning, on Friday, December 4th.
16 10 Asked her not to make any copies of it. Please type 11 it and give it directly to me. She typed it and I 12 held that letter till the evening of -- that Friday ,
13 evening when Cal returned.
14 He basically reviewed the letter, made !
15 no changes to the letter and signed it and gave it 16 back to me with the request to go ahead and issue ,
17~ this on Monday morning. And we could talk from 18 there. Are there any questions up to that point?
19 MS. SMITH: Did you tell him you had a 20 problem with putting that in the letter or that ,
l 21 being included in the letter?
22 MR. BRIGGS: You mean on the 3rd, that 23 evening when he was asked to write the letter, is 24 that the time frame?
l ALL POINTS REPORTING (610) 272-6731
16 1 MS. SMITH: Right. Right.
(
2 MR. POLIZZI: I have no recollection of 3 taking issue with anything specific in the letter.
4 The direction he was giving me, although I thought 5 it was again not my responsibility to be suggesting 6 that people be taken out of the station, it's not my 7 station, Cal's the General Manager. We may have had 8 that discussion. I don't recall ever challenging 9 him prior to him signing that letter.
10 However, upon reflection that weekend, 11 I clearly had reservations about sending the letter.
12 This was a sensitive issue. And it was really what 13 I would characterize a Human Resources type of 14 issue. This was not our responsibility.
15 It's one thing to comment on maybe a !
16 matrixed employee's performance, but it's another 17 thing to tell another manager in another group that 18 you want his people taken away. So I had some 19 serious concerns about that. Never once did I even 20 dream that the letter could be construed anything 21 more than an internal document.
22 MS. SMITH: Did you share those 23 concerns with anyone?
24 MR. POLIZZI: I shared those concerns ALL POINTS REPORTING (610) 272-6731
-- ._ _m _
l 16 1 with Cal the following Monday.
I 2 ,
MR. BARBER: What date would that have 3 been?
4 MR. BRIGGS: The 14th.
5 MR. POLIZZI: The 14th. He returns 6 from vacation and I basically give him the folder i
7 back with a single copy that he had signed that ;
8 Friday night before, the week before, and I said I 9 didn't send it out, I wanted you to have a chance to 10 rethink this. Cool off, consider it. And I didn't 11 feel comfortable, as a sidestream issue, with you 12 not being here if we were going to issue this thing.
13 Again, this was an issue between two General 14 Managers, Mr. Reiter and Mr. Vondra. I didn't need 15 to be in the middle of this thing. So I held that ,
I 4
16 and expressed that to him on that Monday morning. l l
l 17 And Cal acknowledged it, I understand, I know where 18 you are. And he was going to take the action to l l
19 give it to his management before he forwarded the 20 letter.
21 MR. WHITE: His management would be?
22 MR. POLIZZI: Would be Stan LaBruna.
23 He said he would let Stan see it before he 24 dispositioned the letter.
ALL POINTS REPORTING (610) 272-6731
16 1 MR. HOLODY: Had you discussed the fact k
2 that you drafted this letter with anybody? f 3 MR. POLIZZI: The letter was discussed.
4 MR. HOLODY: Prior to the 14th?
5 MR. POLIZZI:- Yes, sir. The letter was 6 discussed at that manager's meeting we had on Friday 7 night.
8 MR. BRIGGS: December the 4th?
9 MR. POLIZZI: December the 4th, that 10 Friday evening, Cal had asked us to gather.
11 MR. HOLODY: Who was in attendance at 12 that?
13 MR. POLIZZI: It was the station 14 managers, Morroni, Bailey -- excuse me, Morroni, 15 Mark Shedlock, Terry Selmer, myself. I believe it 16 was at least those, but strictly the managers of the 17 station.
18 And we were there for him to debrief us 19 on the IMPO exit. And at that meeting the contents 20 of the letter were shared. I admit that. I did not 21 see the sharing of that information being sensitive to the exclusion of the station managers. I had no l 22 23 idea that this information and no perception that 24 this information would go any place else. It would ALL POINTS REPORTING (610) 272-6731
d '
36 1 have to stay with the station managers. It was, I k I didn't take it 2 think, it was a significant issue.
3 lightly, I'll tell you that. There were some 4 comments. >
5 MR. BARBER: Who exactly shared the 6 information? Did Cal share it or did you decide to 7 share it?
8 MR. POLIZZI: It was really shared 9 before Cal was there. Cal signed it in their 10 presence. And it was a general understanding of 11 what he was doing. I mean it wasn't that he was --
12 my impression he was not unaware that I had shared 13 this with them where they didn't know what was in 14 this thing. It was at that level of the management, 15 station management, it was understood.
16 MR. WHITE: Was there any discussion 17 going on after you shared it?
18 MR. POLIZZI: Yes, there was. One of 19 the Salem managers expressed some sensitivity, along 20 the same line that this was not really our 21 responsibility, and that was the same type of 22 reflection I had that weekend, this was not 23 something that we should potentially --
24 MR. WHITE: Again, this was before the ALL POINTS REPORTING (610) 272-6731
l i 16 1 letter was actually issued; is that right?
( ;
2 MR. POLIZZI: That is correct. This 3 was December 4th.
4 MR. SATORIUS: And it was done in the 5 meeting before Mr. Vondra showed up?
, 6 MR. POLIZZI: It was done before and 7 Cal came in.
i 8 MR. SATORIUS: What was your motivation 9 to shere it with everyone?
10 MR. POLIZZI: I had no particular i
11 motivation to do that.
12 MR. SATORIUS: What compelled you?
I
! 13 MR. POLIZZI: There was a lot of rumors
, s
[
14 flying, and I wasn't privy to all of the rumors. ;
i 17 And people were talking about it, including the i 15 ;
16 managers in that room. It seemed legitimate, if you a
1 '
17 will, to share where we were going with this thing 18 so that they understood, rather than have rumor 1 19 information. People were already talking about~
20 information.
21 MR. BARBER: How would people know 22 about it, because it sounded like you were given 23 direction, I'm assuming on a Thursday night, which 1
24 was December 3rd, to draft a letter. You did that, ALL POINTS REPORTING (610) 272-6731
37 1 you gave it to, I assume, a confidential secretary
(
2 the next mornint. mysteriously the information 3 is known by other managers?
4 MR. POLIZZI: I don't know what they 5 specifically knew. But a lot of people had heard 6 wind of what really took place in Cal's office about 7 people being thrown offsite. And from there I'm 8 only speculating of what people were imagining was ,
9 going to happen to these individuals. But there was 10 word that it was bad things and so on and so forth.
11 And I can't give you levels of detail.
12 MR. HOLODY: Where did you hear that ,
13 from?
14 MR. POLIZZI: I actually heard it from 15 the managers. I mean they were talking about that.
16 MR. HOLODY: So when there was rumor 17 that they were hearing, was that rumor that 18 something occurred in Cal Vondra's office yesterday 19 afternoon, or was it I understand that Cal Vondra 20 has prepared a letter or has signed a letter that 21 requests that these individuals be removed from the 22 site?
I 23 MR. POLIZZI: It was the former, yeah.
24 Because the letter hadn't been signed yet.
ALL POINTS REPORTING (610) 272-6731
37 1 MR. HOLODY: So you were not aware of l
(
2 anybody being aware of this letter being prepared?
3 MR. POLIZZI: No, outside of the p 4 secretary.
5 MR. BRIGGS: was it common to share 6 sensitive information among the managers of this 7 sort or type? >
8 MR. POLIZZI: Yes, it would be very 9 common. That's why I really didn't give it really a ,
10 second thought about sharing it with these folks. ,
11 MR. BRIGGS: Did you expect it to be i
12 broadcast to the rumor mill?
13 MR. POLIZZI: No, I did not. If it 14 did, there were some things --
15 MR. SATORIUS: Was there an SRG at this 16 meeting of managers or the SRG line?
l 17 MR. PO7,I Z Z I : I am not sure if --
I'm 18 pretty sure nobody from SRG was there. The QA 19 Manager could have been there, I'm not sure. That i
20 would have been Bill Schultz. But I can't confirm ;
4 21 that.
22 MR. HOLODY: Was there a discussion 23 about the two SRG engineers being out of line?
24 MR. POLIZZI: At that meeting?
ALL POINTS REPORTING (610) 272-6731
17 1 MR. HOLODY: Yes.
k MR. POLIZZI: I don't have any -- I 2
3 really don't have any recollection for the level of 4 detail that was discussed. However, at that point 5 in time, as I look back, there was still a level of 6 concern. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> had gone by. And there 7 was a sense of what was -- what happened yesterday, 8 what happened yesterday. And at least back in that 9 period of time, outside of being unprofessional and 10 inappropriate, I had no sense that I had necessarily 11 done anything wrong to the extent of regulation.
12 So we were concerned about their 13 potential lack of understanding of the procedures, 14 the policy that we had as far as engineering issues, 15 potentially having some further documentation so we 16 could make an informed decision. Those type of --
17 those types of discussions.
18 MR. HOLODY: Was there any reaction 19 from the other individuals after this letter was 20 shared with them?
21 MR. POLIZZI: Yeah, there was some 22 strong reactions on some of them. As I said, one of 23 the managers felt that the letter was very 24 sensitive, and I agree with that. One of the ALL POINTS REPORTING (610) 272-6731
17 1 managers also suggested that he agreed with the
(
2 letter. He understood what was in there. j l
3 MR. HOLODY: Did anybody suggest that 4 this is really too strong of an action for what went 5 on? I presume you discussed what went on also?
6 MR. POLIZZI: Yeah.
7 MR. HOLODY: Was there any of that 8 sentiment?
9 MR. POLIZZI: Well one of the managers 10 did suggest that this is strong and it's very 11 sensitive.
12 MR. HOLODY: Anybody say it shouldn't
. 13 have been sent?
l 14 MR. POLIZZI: I don't recall that.
15 MR. BARBER: Did anybody suggest tnat 16 by doing this, this would be either a direct or 17 indirect violation of employee discrimination, 50.7, 18 or could be harassment and/or intimidation of any 19 sort?
20 MR. POLIZZI: No, not at all. The 21 regulatory aspect never even came up till months 22 later that that was a potential issue. I'm 23 painfully aware of that now, but it was never 24 discussed at that meeting. Nothing in December, ALL POINTS REPORTING (610) 272-6731
P 17 1 nothing in January. It wasn't until the February
(
2 time frame, after the investigation or after my 3 interview, that there was some sense that this could .
4 be a regulatory concern.
5 MR. BARBER: As a part of your process 6 and as a part of receiving the concern initially, 7 did you feel compelled to satisfy Bert Williams?
8 Did you feel that you had to satisfy him that your 9 operability decision was a firm position and that ;
10 you wanted -- you felt compelled to convince him of 11 that fact?
12 MR. POLIZZI: As I said before, I 13 didn't really want to convince anybody per se. I 14 was striving to gain concensus on the issue. I
- 15 truly, truly did not want Bert and Paul to leave i
16 with what I believe their understanding to be that 18 17 the tan cooling units were inoperable. I did not 18 want that. And that's what continued my insistence l t
19 that we need to solve this, explain to me why you 20 feel different than our engineering people. So yes. I 21 MR. SATORIUS: And the reason you felt 22 that was because it required plant shutdown?
i 23 MR. POLIZZI: No.
24 MR. SATORIUS: Why did you feel that --
ALL POINTS REPORTING (610) 272-6731
18 1 why did you feel that it was important that they --
( that you separated with them not feeling that they 2
I 3 were inoperable? You said that was important.
4 MR. POLIZZI: That was important.
5 MR. SATORIUS: Why?
- 6 MR. POLIZZI
- Well essentially I had 7 two Safety Review Group engineers who are 8 knowledgeable people that were at variance to the 9 conclusions that management as well as the technical 10 folks were reaching. It's not a subtle point for 11 two people to feel that way.
12 MR. SATORIUS: So let the procedure do
, 13 what it's supposed to do and let the shift 14 supervisor figure it out.
15 MR. POLIZZI: I agree. Yeah, that was I 16 an error on my part.
17 MR. LANNING: If you were to ask the 18 managers that were in that meeting, how would you 19 think they would explain the reasons why these'two 20 individuals were being ordered offsite?
21 MR. POLIZZI: The managers at the 22 December 4th meeting?
23 MR. LANNING: Yes.
24 MR. POLIZZl: I don't know.
ALL POINTS REPORTING (610) 272-6731
18 1 MR. LANNING: What took place in the
(
2 oiscussion that one reasonable person would draw a 3 conclusion as to why they were being removed fron 4 the site or asked to be removed from the site?
5 MR. POLIZZI: I could only give you 6 reclly my sense of it. Maybe that's reasonable or 7 maybe it's not. There was clearly a concern about 8 the confidence in these individuals. First they 9 could not articulate why they had a technical 10 difference of opinion. And there was an expectation 11 that these people should know that.
12 So we felt uncomfortable that there was 13 some confusion on their part on the procedural 14 aspects. And there was also some concern about why 15 they felt they were inoperable and couldn't tell us 4
So it was essentially -- and I'm not 16 that.
17' suggesting that this is proper --
but there was a i
18 confidence loss in their ability to continue to l 19 perform independently as their role would suggest.
20 MR. WHITE: That confidence loss was 21 based upon the fact that they simply did not agree 22 with your assessment relative to signing on to that 23 IR with this engineering evaluation about the 24 inoperability?
ALL POINTS REPORTING (610) 272-6731
~
28 1 MR. POLIZZI: It was a little bit more f
2 than that, John. It was their insistence on the --
3 and please, please understand this, their insistence 4 on the distinction that the incident report had to 5 go to the senior and the senior only. I have to 6 tell you as I look back then I found that a little 7 odd, that they would make such a strong distinction B regarding that procedure. But that's what it says.
9 MR. LANNING: Isn't that what your 10 plant procedures call for?
11 MR. POLIZZI: The plant procedures call 12 it to give it to the senior.
13 MR. LANNING: So why is there any 14 confusion in your mind about that?
15 MR. POLIZZI: I do not make a big 16 distinction when management is on the property. And 17 we had been involved in this issue that the document i 18 could only go to the Nuclear -- the Senior Nuclear 19 Shift Supervisor. That's all I'm trying to say.
20 All right?
21 MR. WHITE: But the operability call 22 has to be made by a licensed individual.
f 23 MR. POLIZZI: The operability call 24 would be made by the licensed individual.
ALL POINTS REPORTING (610) 272-6731 l
18 1 MR. WHITE: And you were not a licensed i
(
2 individual? ,
t 3 MR. POLIZZI: No, I was not. f 4 MR. LANNING: Wouldn't the people in 5 that room agree that it wasn't the role or the 6 responsibility of either of those individuals to 7 make?
8 MR. POLIZZI: The managers on December 9 4th?
10 MR. LANNING: Wouldn't the managers in 11 that managers' meeting agree that these two 12 individuals probably could not make an operability 13 decision?
14 MR. POLIZZI: That was never a ,
15 contention.
16 MR. LANNING: Well if they're 17 contending that the confidence level was called into l
18 question, that doesn't seem too surprising to me, if j 19 the expectation is that they shouldn't be me.ing a 20 determination in the first place, why is there a l 4
l 21 decrease in confidence?
22 MR. POLIZZI: The decrease in 23 confidence really stems from their, as I suggested 24 before, as we proceeded at the time, their
, ALL POINTS REPORTING (610) 272-6731
l 18 1 insistence on the procedural aspects, the inability
( I 2 to agree with what the technical assessment was 3 and/or articulate their disagreement. That's what 4 we perceived at the time. As I looked back, it was 5 an error in judgment on my p art and maybe others.
6 When I look at this, there was plenty of ways to end 7 this in an amiable way.
8 MR. BARBER: If they had been allowed 9 to submit the incident report to the Senior Nuclear 10 Shift Supervisor, the Shift Supervisor had received 11 it, if he had taken the information you had, and say 12 you had documented that and appended that to the 13 incident report, and they had said it's operable 14 based on the appended information, if the Safety 15 Review Group engineers disagreed at that point, what 16 would have happened then? I mean the operability 17 decision is made, it stands. What's the process 18 from there on if there's still a disagreement?
19 MR. POLIZZI: The recourse would be for 20 them really to escalate the issue through their 21 management and then --
22 MR. BARBER: Would they -- could they 19 23 write a Safety and Quality Concern, fill out a 24 Safety and Quality Concern form at that point?
ALL POINTS REPORTING (610) 272-6731
19 1 MR. POLIZZI: They could, they could ,
(
2 always write one. They could always write one. ;
i 3 There's no prohibition.
4 MR. BARBER: But then you have on the 5 record an operability decision signed by the Senior t 6 Nuclear Shift Supervisor with supporting ,
l 7 documentation that'e available for scrutiny?
8 MR. POLIZZI: That's not necessarily i 9 bad, but I don't want to speak out. ,
10 MR. BARBER: I'm not implying it's bad 11 or good, I'm making a statement of fact. That would 12 have beeri what could have happened had they gone to 13 the Senior Nuclear Shift Supervisor, that is 14 correct?
15 MR. POLIZZI: I guess that's a 16 possibility, yes. That's not inconsistent with what 17 I suggested. I was really trying to win their 18 understanding as far as getting concensus on this 19 thing.
20 MR. WHITE: Excuse me here. Off the 21 record.
22 (Brief recess.)
23 MR. WHITE: Mr. Polizzi, can you resume 24 your discussion now starting with the December 16th, ALL POINTS REPORTING (610) 272-6731
' - ^
39 1 1992 meeting between yourself, Cal Vondra and Mr.
k l 2 Reiter?
3 MR. POLIZZI: Sure. There were other 4 individuals at that meeting, John, besides myself 5 and those two gentlemen. Essentially Larry was 6 there to.-- and I don't particularly know what 7 brought him there, but essentially it was an attempt 8 to try to characterize the nature of the 9 confrontation that I had had and Cal had had with 10 the Safety Review Engineers.
11 At that meeting, I'll be honest, I 12 think that there was an initial conclusion, and
. 13 maybe in hindsight Larry was correct here, about a 14 defense of their behavior on the December 3rd event.
15 And that I and Cal had just misunderstood their 16 intentions and really had miscommunicated the whole 17 thing.
18 Essentially there was a little bit of a 19 disagreement in that, and because heretofore t h'e r e 20 really had been no discussion, at least from my 21 perspective of any of the events, in any detail, 22 that had taken place on December 3rd, so my 23 involvement really junps from the December 3rd event 24 to the letter writing on December 4th and then there ALL POINTS REPORTING (610) 272-6731
- ' + - - - -- - - - - -
19 1 is a gap of a week and the letter to Cal and then 2
2 the meeting on December 16th.
1 3 So there's really a period of 12 days 4 or so that I have no contact with anybody regarding 5 this issue. And it sounded like the meeting was 6 already a solution and conclusions and some --
a 7 conclusion reached. And I don't know if there 8 really was a solution discussed, but I had not had a 9 chance to air things out. But that's what we 10 ultimately did at that meeting.
11 It was a chance for both sides, and 12 from that perspective it was positive to talk about 13 the perspective that I had talked about, the 14 perspective that Cal had, so generally a station 15 perspective of the events of that day. And that was 16 casentially the contents of that meeting.
17- MS. SMITH: Was the December 4th memo 18 discussed at that meeting?
19 MR. POLIZZI: I don't recall. I really 20 don't.
21 MS. SMITH: Or shown around? Didn't 22 you say that before?
23 MR. POLIZZI: Shown around?
24 MS. SMITH: The December 4th memo.
ALL POINTS REPORTING (610) 272-6731
1 i
14 1 MR. POLIZZI: Was that shown at the .
k '
2 December 16th meeting?
3 MS. SMITH: Right.
4 MR. POLIZZI: I don't recall, honestly.
5 MR. WHITE: Do you know if Mr. Reiter 6 was aware of that memo on December 16th? ,
7 MR. POLIZZI: I do not know for sure, 8 no. After I gave the letter to Cal on the 14th, 9 that's really the last accountability that I have t
10 with that letter. I don't know what took place 3 after that, j 11 12 MR. WHITE: Was the purpose of the 13 meeting to discuss whether or not these individuals l 1
14 should be removed from site, or was it to discuss 15 their inappropriate --
what you and Mr. Vondra 16 perceived as their inappropriate behavior in the 17 earlier meetings? What was the real purpose of that 18 meeting?
19 MR. POLIZZI: I don't know what the 20 actual purpose of the meeting was, John. My 21 attendance at the meeting at the time was, my 22 impression, was to do that very thing, to understand 23 what took place and go forth from there.
24 MR. WHITE: Who called the meeting, do i
ALL POINTS REPORTING (610) 272-6731 l
1
39 1 you recall?
(
2 MR. POLIZZI: I would have to suggest 3 Cal, but I do not know for sure who called that j 4 meeting. So that was my impression at the time.
5 MR. WHITE: All right, so nothing was 6 really resolved at the meeting I take it?
7 MR. POLIZZI: No, sir.
8 MR. WHITE: Cal had a position, Larry 9 Reiter had a different position relative to the 10 performance of those SRG engineers and an impasse !
11 was reached at that point, was that your 12 recollection?
13 MR. POLIZZI: I don't recall it to be i 14 that strong, that there was an agreement or j 15 disagreement reached on what should be done with 16 these individuals. It really was more of an 17 understanding of the events, kind o; a factfinding 18 of what took place on December 3rd and so forth.
19 MR. WHITE: Do you recall if Cal Vondra 20 was still insisting that these individuals be 21 prohibited from having any further activities at the 22 Salem?
23 MR. POLIZZI: No, I do not. 1 i
24 MR. WHITE: Please continue. f ALL POINTS REPORTING (610) 272-6731
39 1 MR. POLIZZI: Really at this point in l
2 time, I have no further contact with this event 3 until the February 3rd when I'm involved in the 4 company's investigation and interviewed on that 5 date. So there's really nothing subsequent to that 6 period that I can offer.
7 MR. WHITE: When was the issue itself 20 8 finally resolved from your standpoint?
9 MR. POLIZZI: From my perspective?
10 MR. WHITE: This incident report I'take 11 it, it was never filed?
12 MR. POLIZZI: To the best of my 13 knowledge, that incident report was never filed.
14 MR. WHITE: But the issues that were 15 identified in the incident report, when were they 16 resolved?
17 MR. POLIZZI: I don't know that. I was 18 not involved in that.
19 MR. BRIGGS: At any point in time 20 during this process really beginning on the meeting 21 with the managers on December the 4th through the 22 institution of the task force and your interview on 23 February 3rd, did anyone ever discuss with you the 24 50.7 implications of that conflict en December the ALL POINTS REPORTING (610) 272-6731
20 1 3rd that you and then you and Cal had had with Bert
(' 2 Williams and Paul Craig?
3 MR. POLIZZI: No. There was no 4 indication whatsoever that this was a 50.7 or 50.5 5 or any regulation at all.
6 MR. WHITE: You were made first aware 7 of that during the investigation, during the 8 licensee's investigation?
9 MR. POLIZZI: It was subsequent to 10 February 3rd. I can't give you the exact date, but 11 cubsequent to that.
12 MR. HOLODY: Looking back, what you 13 know now of 50.7, did 'you cause the licensee to 14 violate 50.7?
15 MR. POLIZZI: I say yes. I think my 16 actions were, as I said before, created that hostile 17 environment for them. And in the broadest 18 application of 50.7, although unknowingly and not 19 deliberately, I could have put my company in that 20 jeopardy.
21 MR. BRIGGS: Did you create this 22 atmosphere of harassment and intimidation that you 23 admit existed? Did you create it because they 24 wanted to file an incident report?
ALL POINTS REPORTING (610) 272-6731
. . ~ _ .. . - _.
20 1 MR. POLIZZI: No, absolutely not.
(
2 MR. BRIGGS: Was it in retaliation for t
3 filing an incident report or to chill them from 4 filing an incident report?
5 MR. POLIZZI: No, absolutely not. It l
6 never even entered my mind. We process a lot of i
7 incident reports at Salem. And I think if you look 3
8 at the record, the numbers were quite high during my 9 tenure. I'd like to consider myself as lowering the 10 bar as far as people's threshold for reporting.
11 Again, close to a thousand a year.
la MR. HOLODY: So what was it for that 13 you created this hostile environment? Why did you l
~
4 14 do that?
l 15 MR. POLIZZI: I made some mistakes in ;
)
i 3
16 my insistence on trying to get an incident report 17 clearly and accurately documented to make an 18 operability decision. I basically erred in my i 19 judgment on my expectation of what others shoul'd do. !
20 I clearly didn't consider the implications of what 21 my responsibilities were, that although I had been a 22 accustomed to others in this situation essentially 23 agreeing to how we handle engineering type of 24 issues, it was wrong on my part to do that.
1 ALL POINTS REPORTING
~
(610) 272-6731 l
20 1 One of the key factors was, and I l
2 really want to say this again, that I wasn't sure 3 what we were disagreeing about. That was the 4 thinking at the time, as I look back. Really what 5 was their concern, what information did they have 6 that I didn't have that would cause them to think 7 that they were inoperable.
8 MR. WHITE: Once you came to the 9 realization though that they weren't going to sign 10 off on this after the first instance, what caused 11 you to drive on? What was your deliberate intent 12 that caused them to or want them to sign on to this 13 incident report with this evaluation or assessment?
14 MR. POLIZZI: Again, the intent was to 15 insure that I had all the information and I had it 16 down there accurately.
17 MR. WHITE: But you could have gotten 18 that through others, it wasn't necessary for them to 19 become part of that.
20 MR. POLIZZ1: Yes, I had that 21 information. And as I said before, there clearly 22 was a point that, notwithstanding my intention to 23 get that information documented, I asked for the 24 incident report. And they would not give it to me.
ALL POINTS REPORTING (610) 272-6731
20 1 So from my perspective at the time, although the
( hostile environment was created, and I don't deny 2
3 that, in no way was I trying to suppress this 4 incident report. I wanted that incident report, I 5 asked for that incident report. .
6 MR. WHITE: If they had given you that 7 incident report, what would you have done with it?
8 MR. POLIZZI: I would have written on 9 there exactly what I knew from Morroni and Bailey 10 and walked it down to the senior. <
11 MR. WHITE: Then what would have 12 happened to it?
13 MR. POLIZZI: We would have talked 14 about it, the senior would have signed that and made 15 his determination and signed it.
16 MR. WHITE: Would he have made that ,
17 determination independent of you?
18 MR. POLIZZ1: He would make the 19 determination. What he had on the incident report, 20 it should stand alone. It should not need my 21 embellishment of the issue. So what was written 4
22 should be adequate for him to make a determination. j l
23 MR. BARBER: Are you permitted, as the 24 Operations Manager, to provide background ALL POINTS REPORTING (610) 272-6731 l l
20 1 information, whether by memo, through some other
( form, either typed or handwritten, to add 2 i 3 information to the content of the incident report, 4 and based on that, allow the shift supervisor to 5 make a decision?
6 MR. POLIZZI: Yes.
i 7 MR. BARBER: Did you consider doing 8 that? ,
9 MR. POLIZZI: At the time, I did not 10 consider doing that. Only in the final analysis, as 11 I suggest that when I asked for the incident report, 1
12 that that was my intention ultimately to do that.
13 MR. WHITE: After this event, was Mr. ;
14 Williams or Craig still involved in SRG activities ,
15 pertaining to Salem? Were they still doing 16 evaluations of Salem? I 17 MR. POLIZZI: Yes, to the best of my i 18 knowledge, there was no change in their status. l 19 MR. WHITE: Your treatment and Mr.
4 20 Vondra's treatment of Mr. Williams and Craig during 21 your meeting with them and Mr. Vondra's meeting with 4
22 them, could that have had the potential, in your 23 estimate, to cause a chilling effect relative to SRG 24 involvement in Salem?
ALL POINTS REPORTING (610) 272-6731 {
i
1 1 1 MR. POLIZZI: I would say yes. How
( 2 great, how extensive, I put myself in the position 3 of Bert and Paul. In the presence of a senior 4 manager talking to then the way the meuting was 5 being conducted, I think any human being would feel 6 a little bit nervous about that type of submittal.
7 MR. WHITE: When was it that you came s
8 to the conclusion that your behavior, your i
9 performance was inappropriate relative to this 10 occurrence?
11 MR. POLIZZI: As a matter of fact, I I
12 came to that realization before the investigation l
13 began, in my own mind, that it was inappropriate to 14 behave that way, notwithstanding any regulation. It 15 was not what --
1 16 MR. HOLODY: Before the investigation 17 began, before you even had any knowledge that they 18 were going to do an investigation?
19 MR. POLIZZI: Yes, sir. Appreciate, 20 before I --
before all of that. Now there was some 21 holiday time in there, so I understand that that 22 could have delayed certain things. But by the 23 January time frame, a month had gone by. I didn't 24 think that this was a minor issue, as I suggested, I I
ALL POINTS REPORTING (610) 272-6731 l
I 1 thought it was a fairly. sensitive issue and a
(
2 significant one. And I really didn't see anything 3 happening, in which case it was time to end this.
4 If there was hostility, if these 5 fellows felt that I intimidated them, and I think 6 they would have felt that, I needed to say look, I'm 7 sorry. I lost my temper. I got in your way. I 8 miscommunicated. Maybe we were both 9 miscommunicating that day. Let's insure that 10 doesn't happen again. That's where I was.
11 MR. HOLODY: Did you do that?
12 MR. WHITE: Did that ever take place?
13 MR. POLIZZI: No, sir, it did not.
14 Again, I was asked not to have any contact with the 15 individuals.
16 MR. HOLODY: By?
17 MR. WHITE: By whom?
18 MR. POLIZZI: By Senior -- excuse me, 19 by the CNO, Steve Miltenberger.
20 MR. WHITE: Steve Miltenberger asked 21 you to not ha'e any contact with those individuals?
22 MR. POLIZZI: Yes.
23 MR. WHITE: Not even to explain your 24 behavior or apologize or whatever?
ALL POINTS REPORTING (610) 272-6731
e t ee l 1 1 MR. POLIZZI: Yes, sir, because I had
(
2 said I was prepared to apologize, I'm sorry for what !
3 I did. e 4 MR. BARBER: When did he do that from a 5 timing standpoint?
6 MR. POLIZZI: Again, it's hard for me 7 to put a time frame on it. I know how I felt in mid 8 January about getting beyond this. And if I had 9 lost my temper, we could still work things out.
10 That could have been very coincident with the t
i 11 investigation, and maybe for reasons for that, he 12 chose not to have me talk to them. So it's hard for 13 me to give you a date.
14 MR. BARBER: I guess I'm trying to 15 understand just from a sequence standpoint, did you 16 decide after you were told not to make contact with 1
17 them that you should in fact make contact and i
18 apologize, or did you in fact recognize that you had 19 done something wrong, feel like I want to make ;
I 20 contact and then subsequent to that --
l l
21 MR. POLIZZI: I certainly, I personally 22 felt that I wanted to make contact with them prior 23 to.
24 MR. BARBER: Prior to being told not l
i ALL POINTS REPORTING (610) 272-6731 i
)
I 1 to?
f 2 MR. POLIZZI: Right.
3 MR. BARBER: Why did.you not make 4 contact?
5 MR. POLIZZI: It was close to the --
6 well let me put it this way, I don't recall the 7 vehicle that got me involved with Steve, why I would 8 talk to Steve about this. But he had said do not -
9 talk to them. So what I was feeling by the time I 10 communicated that to him, maybe the investigation 11 was going down, I don't know at that point in time. .
12 But clearly I wanted to clear the air. I did not 13 like this confrontation, if there was one.
14 MR. HOLODY. Did you tell that to Steve 15 or anybody else?
16 MR. POLIZZI: Yes.
17 MR. HOLODY: That you wanted to 18 a pol og i z e to those individuals?
19 MR. POLIZ3I: Yes, I did.
20 MR. HOLODY: And you were told not to?
21 MR. POLIZZI: Yes, sir. Recall your 22 question, John, about did the individuals continue 23 in their role, and they did. And we would continue 24 to have SORC meetings. And an SRG would be there ALL POINTS REPORTING (610) 272-6731
4 1 1 and partake as if nothing had ever happened.
(
2 MR. WHITE: Did you continue to have l
1 3 transactions with these individuals after this 4 event?
5 MR. POLIZZI: Yes.
6 MR. WHITE: On a professional basis 7 relative to their findings?
8 MR. POLIZZI: Yes.
9 MR. WHITE: Did you perceive, Mr.
10 Polizzi, any deliberateness in your attitude and the 11 behavior that you displayed with these individuals 12 in terms of trying to convince them to agree or sign ;
I
, 13 on with the concensus of opinion relative to 14 resolution of that issue? !
I 15 MR. POLIZZI: Not to sway them in any 2
16 way. So the answer is no. I was looking for l
1 17 concensus and an understanding of what information '
18 they may have had so we could reach some technical 19 agreement on what we had, or at least an l 20 understanding of why we were different.
21 MR. WHITE: Are there other situations 22 that you've been involved in where you just can't 23 reach concensus, not necessarily with this, but just
. 24 in dealing with other people, line managers, people ALL POINTS REPORTING (610) 272-6731
d 2 1 that work with you all the time, people come to k
- 2 concensus?
3 MR. POLIZZI: Relative to incident j i
[ 4 reports or subjects, no, never had that occur.
1 5 MR. WHITE: So this was sort of an i
1 l 6 anomaly then?
7 MR. POLIZZI: This was an isolated 8 case.
J 9 MR. LANNING: As far as you know, the 10 IR was never formally processed or filed; is that 11 right?
12 MR. POLIZZI: That is correct. ,
)
13 MR. LANNING: So you would probably
- 14 agree then that really, as part of the actions that 15 you took, had the ultimate impact of that IR never
, 16 seeing the right process, not being submitted to the 17 Senior Nuclear Shift Supervisor?
18 MR. POLIZZI: I think that's correct, 19 yes. There was an understanding on my part that the 20 issue was not dropped, however. I still had the 21 assurance Mike was continuing to do his efforts in l
22 Engineering, Jay had substantiated that in the i
)
I 23 meeting with Cal, and Cal had directed Mike to ,
1 24 follow up on the configuration issue. So from the ,
ALL POINTS REPORTING (610) 272-6731
2 1 point of view of closure, there was a reasonable
(
2 assurance that that was going to take place. But 4
f 3 no, that incident report was not filed as a result 4 of our involvement. i 5 MR. WHITE: What's your understanding i !
6 of your -- of your standing with PSE&G right now? i 7 MR. POLIZZI: It's an unknown right 8 now. The compr.ny completed its report, obviously, 9 and provided what I felt to be significant 10 discipline. I've accepted that discipline.
11 Joe Hagan talked about a number of i
12 pieces this morning. They're all significant. But 13 in addition to what he spoke of, there was certainly i 14 merit increases. There were none for the calendar
! 15 year 1993. I do not know what the status is yet for 16 1994. That will be due out in April.
17 My performance appraisal clearly I
- 18 reflected the poor performance on my part. And on 19 top of that, I am routinely providing 20 self-assessments on my behavior and my performance 21 to my management since the event. But the piece 22 that not necesaarily would be captured is the 23 unknown as far as what the future -- I think the 1 24 future is very uncertain for me at this point with ALL POINTS REPORTING (610) 272-6731
~ . - - - - - -.
i I
4 2 1 Public Service Electric and Gas. 7
(' MR. BRIGGS: There was some question ;
2 3 this morning about whether you had volunteered for 4 this ARC job, and could you explain exactly what --
5 MR. POLIZZI: Let me explain that, yes.
I 6 Again, in the late January, February time frame, 7 coincidentally, a request had come down for 8 interested parties to sign up for a potential 9 assignment with the Advanced Reactor Corporation.
10 Now the ARC organization is located in Palo Alto, ,
11 California. There'are two branches of ARC, as you 12 probably know, the Westinghouse branch, the AP-600 13 in Monroeville, near Pittsburgh, and the GE branch 14 in San Jose, California.
15 From the initial information I was l
, 16 curious about these assignments. This was the 17 advanced reactor project work. This was the future l 18 of nuclear power I had been in the station for 19 many years. In Ops almost four. I w- arious.
20 Now that didn't necessarily align with my family 21 situation. But I put my name down on that list.
22 Subsequent to that, I sold my home in 23 the February-March time frame and had began
.24 negotiations to sign a contract and did sign one ALL POINTS REPORTING (610) 272-6731
I 2 1 with a local contractor to move across town. No
{
2 particular change. So outside of putting my name 3 down on this potential assignment with many other 4 people to learn more information about it, and there 5 really wasn't any information to learn about it, the 6 next time I hear about ARC is in April when I 7 receive my disciplinary letter that says that your 8 next assignment will be with the Advanced Reactor 9 Corpor ,' ion.
10 Now at this point I was involved in #
11 building a home. My wife was involved with school.
12 She had one more full year to complete in the 13 Philadelphia area. So it was involuntary. From my 14 part there was no -- and I think Joe said it --
15 there was no chance of no, this is not what I wtat, 16 this is what you will do.
17 MR. SATORIUS: How big was the list of 18 people that put in for ARC, or do you know?
19 MR. POLIZZI: I really do not know, 20 sir. I really do not know. Now putting in was not 21 r:ecessarily --
l 22 MR. SATORIUS: I understand. I ;
23 understand.
24 MR. POLIZZI: I was curious about it.
i l
ALL POINTS REPORTING (610) 272-6731
)
i
e eA J - , . _
, l l
2 1 If you don't even get a chance to, you need to put
(
2 it down to see what it's all about and make some 3 decisions about it. And clearly my wife and I had j 4 talked about it and said long before April that it's 5 probably not in our interests right now, and we 6 moved forward with the sale of the house and so on 7 and so forth. So I never really gave it another 8 thought until it came up in April.
3 9 MR. WHITE: Are you currently a member 10 of the PSE&G Nuclear Business Unit?
11 MR. POLIZZI: Yes, sir.
12 MR. WHITE: Are you considered on their ,
13 rolls?
14 MR. POLIZZI: Yes, sir. I'm in the 15 engineering organization.
16 MR. BRIGGS: What effect did this event 17 have on your career at PSE&G?
18 MR. POLIZZI: Clearly, the total 19 derailment of my career. I had clearly been groomed 20 and told that I would be the, you know, within the 21 succession for General Manager at either Hope Creek 22 or Salem Station and beyond. And this event clearly 23 has removed me, as you heard from Joe, from any 1
24 succession plans. And the future is clearly l
L !
ALL POINTS REPORTING (610) 272-6731 l
.a.
1 1 uncertain. So significant, significant impact.
(
2 MR. WHITE: Who's your immediate 3 supervisor?
4 MR. POLIZZI: My immediate supervisor 5 is Stanley LaBruna, who is in Engineering.
6 MS. SMITH: Just so I understand, when 7 you said you were in the process of building a home, 8 I take it that was in the Philadelphia area?
9 MR. POLIZZI: Yes, ma'am. It was about 10 a mile away from my existing home.
11 MS. SMITH: Previous home?
12 MR. POLIZZI: Yes. It was in the --
13 and there was some confusion over that, I know, as 14 I've read some of the testimony on the way that went 15 down. But'I assure you that I did not sell my home 16 in anticipation of moving to Pittsburgh.
l 17 MR. WHITE: Is there anything else, Mr.
18 Polizzi, that you would like to discuss?
19 MR. POLIZZI: I think the only thing I 20 really would say again, it kind of mirrors my 21 opening remarks, this has been a remarkably humbling 22 experience for me. I've worked in the nuclear 23 business five years in the Navy, 15 years now, 13
+
24 years, and nothing like this had ever happened.
ALL POINTS REPORTING (610) 272-6731 l
l
- i I
3 1 On the contrary, it really was a very, ,
( l 2 very good career ar) a happy one for me and I 3 enjoyed what I was doing.
4 I admit my culpability fully. My 5 actions were not proper. I have learned the lessons 6 from that mistake, and they will never happen again.
7 I assure you of that. I am committed to that. I 8 have a greater appreciation I would like to cay of 9 the 50.7 or the regulatory applications. And I r
10 would like to think -- I know there was some 11 discussion that others have learned from this, so 12 that is a iositive from that respect. Because it's 13 a very, very uncomfortable situation to have been be 14 in.
15 We've talked about the discipline, and 16 I won't go into that again, but it was significant, 17 as I think you would agree. I would also ask that 18 you review my entire career, as I suggest. This to 19 me was an isolated case. And as we look back, there 20 are many other pathways that would have been easy to 21 take and not bring us to this point.
22 Sc as sorry as I was, I'm even sorrier 23 today that it has expanded to this involvement in 24 everybody's focus. I'm very eager to put this ALL POINTS REPORTING (610) 272-6731
- 3 1 behind me. I'd like it to be. Although I accept k
2 responsibility, I feel the punishment has been, as I 3 said, significant, and I've learned from that. I'd 4 like to go forward and demonstrate what I was able 5 to demonstrate for many, many years until this. ;
I 6 So with that, I will thank you for ,
7 listening, and I hope I've cleared up questions and 8 filled in the blanks that you may have.
9 MR. WHITE: Dan, do you have a closing 10 statement?
11 MR. HOLODY: Yeah, just to summarize. ,
s 12 We consider these serious issues, harassment and 13 intimidation, any potential willful violations of 14 our requirements. And that's why we had this 15 conference with you as an individual, and have had 16 the scheduled conferences with other individuals 17 with respect to this event.
28 We will take what was in our O.I.
19 investigation, what was in the PSE&G investigation 20 and what you provided to us today as part of this 21 conference, the information, and we'll make a 22 decision on what, if any, enforcement we think is 23 appropriate with respect to an individual.
24 Our options are basically do nothing.
ALL POINTS REPORTING (610) 272-6731
3 1 We can issue a letter of reprimand. We can issue a
( 2 notice of violation. We can issue a civil penalty 3 to an individual. We can issue an order that could 4 somehow restrict your involvement in nuclear related 5 activities. Whatever action we do take, we'll 6 apprise you of that action. We try to get these 7 things out within 30 days. These tend to take a 8 little bit longer sometimes. Coordination efforts 9 are a little bit more. But we will be in touch with 10 you once we've decided on a course of action.
11 MR. WHITE: Mr. Polizzi, we understand 12 that this is an unpleasant experience, and we 13 appreciate your cooper'ation with us and coming and 14 meeting with us today. Thank you very much.
15 MR. POLIZZI: Thank you.
16 MR. HOLODY: This concludes the 17 conference.
18 (Proceedings closed.)
19 ---
20 21 22 23 24 ALL POINTS REPORTING (610) 272-6731
3
( CERTIFICATION I, Loretta B. Devery, do hereby certify that the testimony and proceedings in the foregoing matter, taken on February 8, 1995, are contained fully and accurately in the stenographic notes taken by me and that it is a true and correct transcript of the same.
.- .)
1,ORETTA B.
c.- $1 . L4 . -
DEVERY, R e f l
it i .- 1 f
Lo.~ . : i I l My w :. . ,, _.
- 1 J
The foregoing certification of this )
transcript does not apply to any reproduction of the same by any means unless under the direct control and/or supervision of the certifying reporter.
a
.i ALL POINTS REPORTING (610) 272-6731
/
\b
j'8 % UNITED STATES i NUCLEAR REGULATORY COMMISSION
< n 0,,
l :EGloN i 475 ALLENDALE ROAD
% ,. g,a KING oF PRUSSIA, PENNSYLVANIA 19406 1415 April 11, 1995 IA 95-010 Mr. Vincent Polizzi HOME ADDRESS DELETED UNDER 2.790 4
SUBJECT:
LETTER OF REPRIMAND (ENFORCEMENT CONFERENCE (NRC 01 INVESTIGATION 1-93-021R))
Dear Mr. Polizzi:
On February 8,1995, the NRC conducted an enforcement conference with you in the l Region I office in King of Prussia, Pennsylvania, to discuss the circumstances 1 associated with your potential harassment and intimidation (H&I) of two Public Service Electric and Gas (PSE&G) Safety-Review Group (SRG) engineers. The conference was based on the finding of an NRC investigation by the Office of Investigations (01) which concluded that you took action that involved H&I against two SRG engineers who were engaged in protected activities. A copy of the 01 synopsis of the investigation was forwarded to you on January 11, 1995.
On December 3,1992, two SRG engineers attempted to process a safety issue, in accordance with station procedures, by submitting an incident report (IR) to you.
The IR questioned whether the safety-related qualification of commercial grade air supply pressure setpoint regulators, which control service water flow to the safety-related containment fan cooling units, were qualified seismically, configured properly, and classified properly ss safety-related components.
Subsequently, during discussions with the two SRG engineers, you attempted to either convince the SRG engineers that an IR was not warranted, or have them incorporate information into the IR, which you believed existed, to demonstrate that the components were operable. Subsequently, you prepared a memorandum, for the General Manager-Salem Operations' (GM-50) signature, which was signed by the GM-50 on December 4,1992, requesting that the two SRG engineers be removed from the site.
At the enforcement conference, you admitted that you harassed and intimidated these two individuals by your actions on December 3,1992, including the creation of a hostile work environment, and you caused PSE&G to violate 10 CFR 50.7 by your actions in this matter, although you contend that you did not do so deliberately. Notwithstanding, your actions contributed to a chilling effect for i the SRG engineers and staff. Previously, in an internal memorandum to the then Chief Nuclear Officer on April 29, 1993, you admitted that your behavior on !
December 3,1992 was inappropriate and unprofessional, and effectively created a hostile environment which was rightfully perceived to be a form of intimidation that could jeopardize the independence of the safety review group.
)lP/RJdisjO ~ & '
i Mr. Vincent Polizzi 2 As a senior employee at a nuclear power plant, in particular, u the then Operations Manager, you were placed in a position where your performance was expected to be above reproach. This includes appropriate resolution of all potential safety concerns as well as professional treatment of all individuals who raise those concerns. ,Your actions in December 1992, did not adhere to these standards and were particularly significant since you set a poor example not only for those you supervised, but also for individuals of other organizations with whom you interfaced.
Accordingly, I have given serious consideration as to what specific action should be taken against you. I have decided, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, that this letter of reprimand is sufficient since (1) although you drafted the December 4,1992 memorandum at the GM-SO's direction to request that the two SRG engineers be removed from any involvement in Salem Station, you subsequently did not send the memorandum after the GM-50 signed it on December 4,1992, but held the memorandum until the GM-S0 returned from vacation, thereby providing him an opportunity to reconsider his decision in this matter; (2) PSE&G took prompt disciplinary action, after its own internal investigation at the time, which included removing you from involvement with the Salem Station, as well as requiring you to develop an improvement plan, and make a presentation on the events to your peers and management; and (3) you appeared candid and remorseful with the NRC during the enforcement conference during which you admitted that you contributed to a violation of 10 CFR 50.7 at the facility. However, any similar conduct on your part in the future could result in significant enforcement action against you.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room with your address deleted.
In addition, a copy of this Letter of Reprimand is also being provided to the President and Chief Executive Officer of PSE&G.
Sincerely, N
Thomas T. Martin Regional Administrator
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