Records Facil,it es Branch (7)Ol6 2hil

NUCLEAR REGULATORY COMMISSION

IN THE PAATTER OF:

CAROLINA POifL'8 AID LXGIiT COMPANY

(Shearon Harris nuclear Power Plant/Units l, 2, 3 and 4)

Docket Hos. 50-40050-40l50-40250-403

Raleigh, cnorth Carolina

Date -2 Ilarch l979 2897 2979

~ «, "7

Telephone:(202) 3474700

»03 icoogq

ACE - FEDERALREPORTERS, INC.

OfjzcialReponen

444 North Capitol StreetWashington, D.C. 20001

NATIONWIDECOVERAGF. - DAILY

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CR 2608NBBloom

NEI andon1~lade ion

wb UNXTHD STATES OP AiWRXCA

NUCLEAR REGULATORY COM14XSSXOH

2897

~8 40 W W W W W W W W W W W \0 W W W W M OO

Xn the matter of:CAROLXaiA PQHER ZDD LXGdT COMPANY

(Shearon Harris Nuclear Power Plant,Units 1, 2, 3 and. 4)

Docket .4oso 50-40050 401

0 50-40250-403

,.0)

'f0

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Courtroom '2~

Pedaral Building,310 New dern Avenue,Raleiga, dortn Carolina

Priday, L4arch 2, 1979'hehearing in the above-entitled Matter was

reconvened, pursuant to adjournment, at 9:00 a.m.

aEPORE~

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XVAN N, SllXTH, Esto, Chairman,Atomic Safety and Licensing 3aoard,

DRo J. VENH LEEDS, Esp., Member.

GLENN Oo SRXGHT g 14ember o

APPlNSQQlCES a

20On behalf of the Applicants

GEORGE P, TRONSRXDGE, Hsg.,,and JOHif H. O'NEXLT,JR,,Esp o f Shaw < P ittman, Potts and Trowbridge I1800 H Street, No N., Washington, D. C, 20036o

BXCHiMJ3 E. JONES, Esto, Associate General Counsel,Carolina Power and Light Company.

0,

fk

k,

2899

On behalf of the NRC Regulatory Staff:EDHXN Zo BEXS> Esq„ Office of the Executive

Legal Director, Washington, D Co

On behalf of the Attorney General of NorthCarolina'EHNXS

P HXL'RSg Esq and DAVXD GOROOi4t EsqOffice of the Attorney General, Raleign,North. Carolina.

On behalf of the Conservation Council and NakeEnvironment, Xnc.

8 THOIiAS So ERtA'N, Esq., Mater Tower Court,115 N. Morgan Street, Raleigh, North Carolina27602o

10 ADDXTXONAXs APPEP~CE

On behalf of the Conservation Council anZ HakeEnviroament, Xnc.

14

Ao XARKXN KXRKtCM, Esqo< Water Tower Courtt115 No Morgan Street, Raleigh, North Carolina27602o

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Wi~

2BSS

CONTENTS

\ $3@,

Xhnited A earanca SMtemenh ofa

Mart~ Coleman Smith 2902

'* %Dresses DiÃGC'h CRd$ $ EsliÃ80t RsoÃ0$ 1 BoozlX

'5

e t 7.A.

'mrard Wilber(

Prancis 8o Long)'ugh Ci Dance )'(Resumed)

2929 2938

29082921 2923

296R

XIRIBhe ~EVi

'I2:

AHSX N18+1o "Selection and Trainiag 2961 2961

of Nuclear Peter P1ant PersonnX".'"

:15

I.'0

'.IS

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4

2900

RB/ebl. P ROCEEDXMGSCHAXRMAN SMXTHt He have a new appeaxance

fox'ounsel

fox Xntexvenorso

12'3

18

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23

Mould you introduce yourself, six?

MRo KXRKKQlc My name is Larkin Kirlanano X'm an.

attorney in Raleigho

CHAXKQQT SMXTHc Are there any preliminaxy matters

befox'e we proceed with the testimony?

MRo KXRKMAHe X have )ust been given a notice thatMro Martin Caleman Smith would like to make a limited appeax"

ance statement

CHAXRMAN SMXTHc Under our procedures that we'eusing hexep we'e inviting members of the public to submit

written limited appeaxance statements because the purpose

of this hearing is not. a broad~ general construction permit

hearing Xt is xather narrowo Me are without authority to

receive limited appearances on matters autside the issues ta

„ be heardo

Therefore~ we axe asking that, you submit a wxitten

statement in wxitingo Xf the written statement appears to be

related to the issues sufficiently, then we would give you

an opportunity to make that statement orally, a statement on

that subject mattero

Xf you have writing materials, do @halo Xf you

don', X411 pxovide some for you '" Then we will consider your

2901

statement.

MR. SMITHS' have it written.

CHRISM SMITHS'f you will pass it on up we'l4 take a look at it,

MR GORGOMa limo Chairman, have you finalized

arrangements for Tuesday2

CHAXBYM4 SMITHS'he Clexk is at a conference

and as soon as recess comes X'll talk to himo

DRo IBEDSs ftfhile the Chairman is reading that

y0 letter, Mr. Reis< let me inquire, have you made contact wi45"

the authors of the Board Notification document, Board Exhibit

82

MRo REISs Not yet. One of our members went hack

to Hashington, Mr. Schwencex, who is a section chief in

]5 Opexating Reactox's, and he was instructed —or, x'ather, a

branch chief in Operating Reactors, He was ihstructed to get

in touch with Che people in X&E Headguar ers in ifashington to

take care of that.

He will he hex'e on Tuesday and when X am in the

office on Monday X expect to find out. X cannot, tell you nowo

DRo LEEDS'hank you

CHAIRMAN SMITH: Mr Smith, I have read your

23statement and a substantial part of it does relat'e, X think

indixectly at least, to the issues Chat we are hearing so X

am going to let you make ito But X am going to ask,

t

yQ WRB eb3

2

3

' 4

however, that you eliminate or state only very briefly the

aspects relating to the financing which is beyond our

jurisdiction at this hearingo

So you can either read or just mal e your oral

2902

statement along those lines.

HR. SMITH: X'd like to read it.CHAXBHAM SHXTH: The portion about CNXP is beyond

the issues that we are hearing hereo

$ 0

LXMXTED APPEAKLNCE STATEMENT OP HARTIN COLEMAN

SMITHS'EMBERS KUDZU ALLIANCE

MR. SMITHS My name is Martin Coleman Smith. Il2 live at Number 8, Maiden Lane, Raleigh, North Carolina,

X am a member of the Kudzu Alliance, but I repre-

14 sent myself today only as a concerned citizen speaking my own

35 mind X am concerned about Carolina Power and Light Company's

16 ability to safely manage any nuclear powex generating

facility because, as an organization, CP&L is chiefly intereste

~8 in making. a profit fx'om its operation.

A profit uudcing logic would instruct a business to

20 invest only what is absolutely necessary in order to return

2'J the greatest px'ofit margin to the business o

22 The production of a safe and reliable nuclear

powex generating station requires in today's real terms a

monmnenta1 investment of money and energy. A company such as

CP&L~ driven by a px'ofit motive, quite naturally would wish

Waa eb4

2,

2903t

not to spend money and.would aggressively engage in strategy

to spend as little as is necessary to do what it considers.

What is necessary for the safe operation of

nuclear powe- plants is a fundamental inquiry at a management

hearing such as this The very definition of safety in. the.

nuclear industxy.is notably shaken by the discrediting of theW I

Rasmussen Report, formerly the source of information for

30

operational safety and, performance standardso

In. genera3.< no proof exists today of nuclear

safety ovex'he entire life of an operational facilityo Radio

active contamination of the power plant- itself staaNily

33 wox'seas over its life cycle Deterioration of the best

matexials increases over timeo

37

3S

20

Even as we assumble today, reports of pipe cracks,

mechanical failure and human error throughout the world incLL-

cate a- greatex probabi3.ity of failure within the nuclear cycle.

Consider the steady rise in cost of repaixs and a management

albatross. of immense weight is throMn around the neck of any-.

one daring to stick theirs out+

Safety systems simply cost a great deal and

pressures exist in today'- spasmodic economy th'at might force

a company Co hurriedly accept materials of. lesser quaU.ty fora particular system Only the most financially secure organi-

P

zations can afford the expenditures requiied in the design>

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2904

NRB eb5

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construction> aad maintenance of a nuclear power plaat.

So in good. economic consideration, a utilitycompany is going to cut avery dollar corner aad moaey edge itcan to assure a better return for its investment, And the

'oxe that utility sciraps on the system, the less safe that

system actually is, Secure long-xaage economic planning ia

this case may supercede the ultimate safety of the facility,Let us compaxe for clarity privately™rua nuclear

facilities to government or. military facilities. These

fo systems often produce operational data that suggest the safety

and reliability of nuclear powex generating stationso This

data, coupled with private industry's owa information, pro

vides operational guidelines for the care aad maintenance

of such facilitieso

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f9

P.o

25

The Navy for eacample, on their nucleax" systems,

villbuild for quality whatever the cost, but. X don't believe

CPSL could or would go for that particular construction

program because they are interested in making a profit+The cost of this technology that CPsL is seekiag

is entirely out of hand aad I doa't believe that'CPSL can

easily finaace it. Prom their oxigiaal cost. estimate of Ql~l

billion for the Shearon Harris project we observed a rapid

cost overrun of literally billions of dol3.ars+ money which at~~s time CPGX is not, positively assured of being able to

recover< which would. affect the company's total operationo

2905

Xn distxess, CPsX would not abandon their pet

6

tschnologyo, A, sound and comprahens9.ye logic would be fox'th-

coming from the utility as to why the consumer should be

'harged moxe for the cost of this mismanagement.

X'm not exactly certain which part you would likefox'e to leave out

7'HAXRMAHSMITH! X think possibly it would be'

easier for. you to make- your entire statement, and we'l dis

regard the aspacts which are not relevant.' understand youx

20 'oint now about financing relating to management.

NRo. SMITHS's you are aware, constxuction work

23

2627'n

progress. laws, or CHIP, provides fox the inclusion in the

'ate base of' public utility company's cost during con-

st'ruction of'ower generating facilities< be they conventionaI..

plant design or fac9.lities of a more advanced technologyo

The following is a paragraph taken from a brief-

ing paper, for a, PORC proceeding on CMXP prepared by Ms.

-'arolina 8o. Smith< Department HEN, Office of Consumer Affairs,head econcmistg and I Quotes-

20

22

Xn November< 1974, the Pederal Power

Commission (FPCp naw PZRC) issued a, Notice of Pro-

posed Rulemaking in which it proposed allowing allutility compares under its Jurisdiction to in«

elude CNXP in rate base for'he purpose of setting

wholesale "ates (Docket Moo BM 75-13} o After

2906

~ MRS ebi

2

receiving extensive oral, and written comment an both.

sides of the issue~ in November 1976, the Commission

.'issued Order Noo 555> disallowing the inclusion 'of

CifXP in, rate base except for constructiou of pollu-

7

tion consol facilities and fuel conversion facilitisso

Xn additionp the Commission indicated

that- it would allow the, inc3.usion of CNXP in rate

(0

base< on a case hy case-basis, upon a showing of

'severe financial difficultywhich cannot be oVmx

wise a3.1eviated without materially increasing the

cost of electricity to consumerso ™

CPGX is or will,be applying for CNXPo

The: issue is claar to me-o CPSL caxuiot manage the

'ost of its program without the inclusion of CNXP in its'ate, base, thus shifting the burden af construction cost,

17'8

premature1y to the consumero

Xs CP@L in "severe financial'ifficu1ty"? Is this.

f9 eleventh hour bid for credib 1e management? Has every means

20= oE alternate fi'nancing bean thorough1y examQmd? Xs CPM

'in financial distress?

,Xf so> then I suggest that, it is more a result

of an internal management dilemma than from forces external

to the company itselfo

25 As this may well bs the casa, tAen X submit in

2907

light of the aforementioned trends and actualities that this

Boarcl assembled today impose with its authority the strictest

possible restrictions oa Cax'oliaa Bmer and Light'Company's

nucleax coastructioa pro)set as much a test of CPsX's manage-

ment capabilities than anything else, and tKat'if CP83~ cannot

hear up to the rigors of a nuclear program geax'ed towards

safety, then. it be ordered to cease in its activities and

redirect its eaergisso

Thank youo

CSAXRHM SNXTHs Thank you, Hxo Smitho

Any other prelimiaaxy mathemP

(Mo respoaseo)

All right, thea we'e ready for Panel 3

HRo BEXSs Mro Chairman< X think you were asking

Hz'o Hi1ber some cp18stions p aad you 'asked him .ho spend some

time and he told me he spent hhree or four hours'ast evening,

studying the testimony pxefiled, and. would Like to-- X don'

know whether he would like to> but he is ava;U.able to resume

the stand

CBAXRMM SHXTHs Hro Milbero

HONARD HXXLBHR

resumed the stand and~ having been pxeviously duly swora, was

examined and testified further as followss

CHALKED<>M SHXTHs While Hr N9.lber is gettiag

2908.

~HRB eb9

G

ready~ Dr Leeds inquired as to whether the Office of the

Executive ~gal D~ector has had any success in contacting

Che authors of the report to the Qoardo

Thatis already been covered, X guess.

&Qto HEXSs As X reported to Dr. Leeds, @hen

Mro Schwencer vent back, who is a future +itness, to Mashingto

X asked him to start looking into those matters> since X

thought they could be better handled in person by someone in

Nashington< and X haven't had a chance to eocamine further

FORGER EZANXNATXOH BY THB BOARD

e;

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BY DRo XsBBDSs

Please proceed+ Hro Nilber

A, My understanding @as X was going to review the

panel's testixaony to see if there vas something Mat would

pump right out and hit me,

g That,'s correct,

A X did review Panel 1's testy, which is afterthe fact X guess< and X have no comments on that onei

X did not reviser Panel 2 because X believe thatvas enCirely constructiono

X reviewed Panel 3 and X do have some comments

that may or may not be import3nt, but X would offer them foryour consideration

2909

~ HRB eb10:

l

3

4

X talked about trying to correlate the non-

compliances and I did try< and I had trouble correlating itr

and X believe I found out whyo

The testimony extends to, X believe, September

30th, 1978~ and the exhibit goes to August, 1978,'o there

may be some of the testimony that is not there I couldn'

make the numbers )ibe at allQ Share are we in the hestimony2 Page 322

A Page 31 ~

32

$ 8

Page 31?

Y8so

So the mshibit that's attached to itI Chink you renumbered those exhibits so I'm gust,

going to say'that the exhibit that addresses the summary

of inspectionso Xt used to be Exhibit 1~

Q Okay, NRC Staff exhibits which vere marked-

achually listed as Staff Exhibit 1, do we have a number on

~that2

CHAIRMAN SMZTHs Xt's Staff Exhibit 12o

THE NXTHESSe Xf you'l look at the heading on

that it says Cha history is from July< 1975< to August< 1978o

That may be the reason why X couldn't correlate numbers

23

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25

2910

I~~ WRBlwbl ~

I z

BY DR LEEDS:

Well which way do you come upP Do you come up

with more printed on page 3l, or lessP

I came up, I believe, with less. That''hy I- was having problems.

Yes, that. would give you problems.

A'here's another facet of this printout which is:that. some of these items of non-compliances are the same

10

events that are, cited against. both units. So I believe, in

looking. at those, tables, those have probably been combined

1?

and are counted as one item. But I can't tell that because

I don'. have. the, full range

I read the. content of these items as they'e'rinted out in the computer. printout and have no strong

comments on- them; exc pt it's interesting that the last two,

I, believe it i;s, for the docket numbers for 324 and 325,

]7 it' a common, item, read to- me as their being almost identi«

20

cal, and they occurred about a month apart.

I'm just offering that. as information.

These are on page 26. They'e documented,.in the

inspection report 78-15 and 78-17. I don't have the inspection

reports, so I can't give you any more than the details that

are here.

e I believe one of the statements says the,.man was

not dressed in accordance with the requirements as posted, and,

2911

wb2 the other says that. he did not follow the procedures establish d

for use of protective clothing.

, GOkay.

That's 78-17; is that right7

The report number, yes.

And 78-152

Yes.

]0

Okay. Thank you, sir.twould you please continue.

In the reportable events, the way I read this

testimony, there are two areas where I believe these are

addressed. One is on page 32 where there's a tabulation

of the events, and then later on in the testimony —and Imay have trouble finding it, —there are several pages where

they talk abou the specific systems, I believe the HPCI

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system, the diesel generators, and I believe there are one

ox two others-. Relief valves I believe is in there.

I would offer that there is another input to

LERs, a cause. code that's called "Personnel error" that Ibelieve would be an index to management. And I don't see

this trend described in the testimony anywhere: i it going

up, is it going down. And that's available from the computers.

I don'thave it, but you can address the computer and ask

them for personnel errors versus docket number.

Okay.

2912

wb3

t

In other words, the materials that you reviewed,

the staff exhibits and'the testimony, does no't have that

listed? —or you couldn'- find it?That,'s right.Okay.

And it would be helpful, then, for us to have it,it would be a good indicator of management performance?

$ 0

I think so.

Okay.

Now suppose we got it. What would we look forwhen we got it?

Just. what they'e presenting here: trends.

Okay.

And I premise that on the idea that a single

17

20

licensee probably is reasonably consistent in his reporting.

Some people may say it's a personnel error, others may

attribute it to an equipment failure. It depends on how they

view the item. But I think a licensee would be consistent

in what he considers a personnel error. Therefore the trend

would reflect his plant.

On page 53 af the testimony there-is. discussion

of the training facility, the simulator. And here I don'

see any evaluation of what this —any HRC evaluation of this

facility. I don'tknow if they'e looked at it or not: is itgood, bad, indifferent; does it address the training

2913

requirements that I believe- are set forth in —where is itP-Part 55, 10 CFR Part 55.

So you would think there ought to be an evaluation

of,. its effectiveness in training personnel'

Yes. It may be very good. I don't know anything

about it except that it exists here.\

Q Fine.

That's all I have on that panel.

I read the, I believe you call it Panel 4, the

Mi'ner, Haass, Schwencer.

Q Yes.

E~d in there they talk about —once again, much

of that is on construction. But if you go to page 19, they

talk about the organizational structure to operate a plant.What I couldn't find here —and it may be her'e:-

I just don't understand it. I believe one of'r. Cantrell's

concerns was the long hours that may have been evidenced

by an understaffing or a. small staff. I cbn't see in here a

review that addresses the question of understaffing. Maybe

they don't do it; I don't know. If this was a concew

expressed earlier, I don't see it addressed here and I don'

know if- it's addressed anywhere else or not.

Q So it's not addressed one way oz another: over,

under; it's just omitted, you couldn't find itPA I don't see it here.

2914

wb5 Okay.

A Now maybe X don't understand the words:. X read

them two or three times. But, they do talk about qualifications,

training program, they talk about the structure., And it may

be that, they are evaluating the size of the staff and the

organizational structure; X'm not sure.

0 But you found nothing in there that talks about

any evaluation of what they'e doing now as compared to what

g they think they might do in the futu"e?

fo X'm sorry?

There's no evaluation of what they'e doing now,

Og

what CPsL is doing now as a lead-in to what they might do inthe future, and there's nothing here that indicates what

Wey might do in the future?

You mean such as staff build-up? Xs this what

you'e—Yes.

iS No,' don'0 see it here. Xt may be somewhere inhere. X believe that was in some of the Panel l testimony.

Heren't there some statements on staff build-up thexe?

At least in the construction. X don'0 recall the

operation.

Those are all the comments X have.

Okay, sir.

2915

3 'I

Mt me ask you about one of those reports, those

inspection repoxtso X pu1led one of those inspection reports

and Xem surprised X didnot get both of them becaus

both of them cixc3ed in red, and X evidently have the latteroneo X have 50-324/78 17

X wouM 1$3oa to sort of read to you~ 'if X can find

Sold it gust a secondo

(Pause j

10

X am reading from page X-2 of the Region IX report

number 50-325/78-2,7 and 50-324/78-X,7, which is an inspection "

report xeviewed by Hx Dance and which he signed off on the

2lst of August, 1978,

Xt. says in Section Sc

The inspectors observed an 'in'dividual

te

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20

2l

in Unit 2 HPCX room on Ju1y 18 without the Proper

protaehive clothingoAs designated at the point of

entry, shoe coverse glovesr and PaPer coveralls

were mguired for inspection active:es ~ The in-

dividuaL did not have covexallso

Also on July 18, 1978, three indivi-

duals vexe observed morning in Unit 2 feadpump

room without wearing their proper protective cloth

kg~ As posted< plastic shoe covexs were xe-

cpxixad, and the worhaxs vere observed wading in

water with paper shoe covexso

IoNRB eh2 From that, do you have any comment about. that

particular'cbm< the: severity of it< or anything Like that2

A I'm not sure whether it is an expression of the

attitude of ~We workers or a problem with'the radiation con-

Crolo Was there a radiation control man in the- area who

permitted'' don't knew whether Wey had a'inin stationed

there or noto X don,'t kaov that detail and X don'= believe

you mentioned itHog it was not'sntionQd in the rsporto

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.$ 8

A One <ray that The- man has haen dixicbsd by

written word to suit out for a specific job, aud this could

be monitored hy id'adiation control or migM. not he< and X

den~t. know that facto.

9,' Helly in the response fxtxl ML"o Bchnks to Mre Reillyg

Mr Banks is the manager of Nuclear Generatiou for: Carolina Power and Xighto On page 2 of. his Letter of the

20th of September> it states thats

"The auxiXiary operator in Unit Zoo 2

BPCX room not wearing protective clothing"8esig-

20 nated-by the posted dress requirements was'oun-

soled hy the oporatkng su~isor on the importance

of conform9wg to racU.ation control techniques

Contract workers in Unit No,' reactor

feedpmap zan were seen wearing paper shoe covers

in a contaminated area which required plastic shoe

2917

~-%Q eb3j.3

coverso The plant manager infozms6 the contact

personnel's geneza1 supsrintanieat of the Mport--

anca of the contract voxfcex.'s confo ming. to

1b '6

: Rnd MRSQamkon fl,so '

I cpm't. see anything in them that, there Was a

radiation man on the spot,o Should the@a have besnow

'fO

f'2

f3

f5

17

f8

2G

fls MHB1NEL/we 1. 1 2918.'o

we'e got some information, but we don'. have

- enough information to make a determination7

A If you want an opinion, X believe the unit.operator'hould

have known about his reauirements The contract.

people I believe have a training program prior to placing

them in there, but I believe the'nit operato'r should have

been very aware of his requirements.

9 -'So it's more serious than on the part of the

con~mact personnel o

)0 As far as the attitude of Uhe pexsonnel, yes.

Xs there anything else, sir?

No.'Xt.

seemed like I had anot¹r one that involves

radiation control, and X just fox he life of me can't seem

to find the right number

I'm not an expert on radiation control anyway,

but.- as I say. -the words. on these two items seem to be very

similar.

Q Yes. bell, X.'m sure that Hro Dance and Nr. Long

can addxess that for us, when we get. to it.Thank you, lM. Nilber.

Yes. I think I volunteered a task for them, then.

I- appreciate your taking your time at night to

read dx's. I, too, have read Wings at night, and I can

understand how blea~-eyed one can get. I appreciate you

wel 2 2919,

'3 taking the time to read it, especially this fine computer

printout stuff where they squeeze the size of the print,

down to about half normal.

Thank you, sir.= MR. REXS: Mr. Chairman, may X ask one question

of Mro Nilber?

CHAXBMAN SMXTH: Excuse me, Mr, Reis, X'll get

8 right back to you.

$ 0

{The Board conferring.)

X'hink it might be helpful to all the 'participantsif we have some idea of what our schedule this morning will

f4

Prom the Board's. point of view, we can stay'nsession as late as 12r00'. But is there anybody else.

essential to this proceeding who has a problem that would

requ re earlier adjournm nt?

i8

20

(No response.)

Nell, then, let's plan on—VOXCE PRON THE AUDXENCE: Ne need to get out of

the motel a few minutes earlier, before 12:00. X was

assuming we were going to get out at 11:00 and left the

stuff in the room.

CHAXRMAN SMXTH: X'm sorry, sir, X don'

recognize you

HR BHXS'hat's Mr. Cantre3.1o

wel3'920CHAXBtGQ~ SMXTH: Oh, you'r. Cantrell.

Nell, when the time comes, if you have to leave

go ahead, and don'0 worry about the request that you be here.

MR. REXS: Can X ask my witnesses one question

off'the record'P

(Discussion off the record.)

MRo R XS: Nell, X think most of my witnesses

have not taken their things out of their rooms, so X think

we would'ave to break around 11,30 p Mro Chairmano The

announcement yesterday was 11:00.

CHAXHERN &D~3: Okay, that's fine. Did we state,

11:00 yesterday'R.

REXSa Yes, you did. Or at the beginning of

the week:. you stated it, or'at som time you stated llc00 ~

X have one question of i~h.-Wilber, if X,may.

REDXRECT EXhtlXNATXON

17 3Y f4R; BEXS:

Mr.„Nilb r, X know you put away the testimony,

bu" looking at Mr. lfinor, Haass and Schwencer's testimony on

page 19

(Doc~~ nt handed to the witnesso}

What page was thatP

Page 19. Looking at the sentence that begins

the seventh line from the bottom, starting with the words,

"At the operating license stage," is there an indication—

wel 4

do you find an indication there that the Staff will look

a5 the adequacy of the staff of CPGL to zun Shearon Harzis2

:I Q3

oz numbers o

You mean adeouacy foz numbers, or q>mlifications?

Adequacy of the operating staff itself, adequacy

As X mentioned, their review may be performed

under the tenn organization stzuctuze.

Does it say that it will provide an adequate.

organizational azrangement and operating staff, on the fourth

line from the bottom2

MR. RHZS: That's all X have.

CiZAXRNM SIXTH're there any further questions2

HR. iCZKQQBs Yes, lM. Chairman.

I%CROSS EXMZNATZOM

BY NRo RZMB>$-

17 Mr. Wilbez, X didn't hear your™testimony yesterday~

$8 but X understand that you testified tha the figures on

19 page 32 of the phase 3 statement about 3zunswick-1 and

Brunswick-2'ere okay.

Mould you please'l'azify "„ust what you meant by

okay?

Z'm sorzy, Z lost rou.

This 's the Panel 3 statement on page 32,

Brunswick r portable events fzom 1975 through Septen&er 12,

wel 5 2922

1978 are. su~rimed as follows.

1IIR. TROITBBIDGI: Nz, Chairman, we weren't able

to- hear the question.

THE')ITNESS: This is panel -»-- what?

Bl MRo ZXPMP2l:

Q. On panel 3a

And what- page?

Page 32 o

All right how, I'm sorry, what did vou say

10 about it.?

Ny-'nderstanding is that you testified that these

13

figures are okay. Would you clarify whether when you say

okay you me~ that they'e correct, or whether you mean thatthis is an acceptable level of, reportable events?

I believe I meant that they were an expected

trend. They are based on licensing date.

X can'0 vouch for the numbers. XC's «ot my

testimonyo.

2Q

21

bhat is the trend that you see in these numbers'?

S'?$ 8xat is the trend that you see in these numbers?

Bnmswick-l, the plant that I was most familiarwiCh, Che 1'censing date I believe was September &< 19?6.

I believe fuel loading started —I'm sorry —criticalitywas on October 8, 1976, and X see a low'rend in 1976

2923

primarily because the licensing occurred "'n the latter part

of the year„ a higher number in 1977 when they were in the

process of doing their startup testing; and then a sma3.1

reduction in 1978

And I understand that. tha"'s a 75 percent. That

only covers 75 p @cent of 1978.

The 1978 figure?

Prom the heading there it does.

Are you saying, then, that for the full year 1978

one would expect. a figure of 100, is that right?

Zf you want an extrapolation.

NR KIRKMAH."Thank you very much.

PQRTHER EZ29iZNATIOH BY THE BOARD

BY DRo LEEDS

Excuse me<,Hr. STD;lber, let me hop hacl in here

for a second. I have found among my papers thatoDer'eport,

and it's Region IX report number 50-325, 78-15, and

'50, 324, 78-15, which was signed off on the 26'f July 1978

by Mr. P. J. Kelloggo Actually somebody signed it for him,

and X can 't read the signature.

But I'm reading from page 1-4s

"On June 20, 1978 the inspector observed work

in progress on ele mtion 117 foot level on Unit number

2. The work consisted of the p3.acement of new fuel

racks into the sp nt fuel poo3.. This area was roped

off and posted as a radiation control area. The

sign at the entrance to the work area stated that

the minimum protective requirements were coveralls,....- shoe covers and gloves. There were three mainten-

ance persorwel engaged, in this work iaNo were dressed

in accordance with dress requirements as stated on

the sign at the entrance to the radiation control

area. The QA observer inside the radiation controlarea was dressed in street clothes with shoe covers

and gloves only. Nhen questioned about the difference

dress, the inspector was informed it was standard

practica for inspectors in a radiation control zone

who were observers only not. to wear full minimum

protective clothing "

And then it goes on to talk about regulatory

guides ~

I seem to remember having read the response ofCarolina Power 6 Light. to that, and I don't seem to find ithere, but maybe my memory is pooro

But that 78-15 number, that's those two adiation

, control—I would like tc hear that part about the QR—

did you say it was a QA—

Q QA inspector for CPGL, as X understand it. May

X show you thisP

292S

(Document handed to the witness.)

I don't know if you said he vas doing it. according

to procedure or according to custom.

>Tell, there's the vrhole report.

(witness reviewing document.)

Those tvo documents vere obtained by the Board

from the Public Doc~~ t Room in downtown Washington, 1700~ ~

something or other H Street

Can I speak from experience on thisV

Sure

As an inspector X have done this type thing on1

the basis that I vas not handling —~rhere the people thatvere doing the actual work had to wear coveralls, but Icould go in with a smock. Hhere they had to strip down and

maybe put a double covering on, I v s not going into the

specific work area. I vas on the periphery, still vi&inthe zoneo Nov, I'm talking about my m~erienceo They

had a special work permit for observation only. I don'

know of that exists here or not.

But from experience, I'e been in this situation.I thought it vas all right I vasn't climbing on the

equipment..

I don't know what they had her . Evidently they~ ver cited for it, and he vas evidently ~der the same

protect'on the other peop3.~: vere.

wel 92926

ea So, again, we don't have enough information.

Nell, I'm sure if there were two radiation work

permits the Licensee would have informed you on the—Q ~ Wall, as I say, I do not have the letter respondin

from the Applicant. I just asked the people there to pullth files on those inspection reports, and X did not

persona3.1y pull the files. I.'m not sure I would have pulled

their responses either if they'd been put somewhexe else and

--.not readily available.

30 But should Hr. Dance and Hr. Long, when they go

back to Atlanta complete this one so we'l have both sides

of the picture thexeP

PER, REXS: They will endeavor to do soo

DR. LEEDS: TharJc you, sir.CIVISM SMITH: A-e there any further cpzestions

of Mxo Wilberl

17

TS

MR REISE The Stafx has no further questions.

MR. KXKCK~2l: Ho, Mr. Chairman.

CHAXKItBt SHITH: Thank you, Nr. Wilber.

(Nitness excused.)

Ne'll take two breaks this morning. I have to

'consult with the Clerk about nearing space ne..t week, so thatMr., Gordon is apprised. So let's take a 10-minute break.

{Recess. }

2927

'Jh

Madelon~lws 1NELc4 mpbl 2

MR.'EXS: Mr. Maixman, do 'you want. Mr..

Bxownlee up chexe now, or when it's more appropriate for his-

CHAXMAH ShlXTH: Whenever he wants to come up.

But X have no questions for him=until we have covered the

Panel 3 testimony.

MR. REXS: The only reason X ask is it's a strain,and'. he's been sitting up there for' full day. And if. you

could call him gust when you want him—9

f0

CHMKCKN SMXTH: As a mattex'f fact, X reallydoubt, considering the earlier-testimony, that we'l have

f2

, anything for him.

MR. REXS: But you'd like him to remain?

f4

CHAXRMAN SMXTH: But he should be availabl'e

in case a, auestion does come up. So he doesn't even have

to go up there at. all, if he's available.

MR. REXS: X don't se'e him at. the moment., but he

f9

20

was told not to leave, so he'l be right back.

CHAXRÃAN SMXTH: Okay. That's fine.Mr. Gordon-

51R. REXSs One othex matter.

'22,

23

You also asked about cpxestions for CPsL from

the ShaM. X take it X can gather from my staf , and ask

if you want them. submitted in written orm for the Board to

ask.

CHAXRGM SMXYH: X'm sorry'

29282'R REIS: When our Panel 2, I believe, was on

the stand, or Panel 1, you asked whether the Staff had any

questions of CP6L on their testimony and asked the panel

particularly to supply questions. Did you wish those to be

supplied to you in written form or o be supplied to me to

asks

CHAIBMAH SMXTH: Whatever suits your purposes.

fo

MR REXS: Okay

CHAIRMAN SMITH: Whatever is better for you.

MR. REIS: Pine.

CHAIRMAN SMITH: If you feel, Nr. Reis, that inthe exercise of your responsibilities you can't support such

a question, okay, then gust submit it to us.

MR. RZIS: Right. Okay.

X will gather them and have them available

certainly when we start again by Tuesday, in any event.

CHAIRMAN SMITH: All right. Wank you.

Ne're going to accept the hospitality of the

19 Utilities Commission. They 5ust can't assure us of having

20 suitable hearing space here next week except for the

Grand Jury room. We will start out Tuesday morning in the

Grand Jury room on the 8th floor, and X haven't seen it, but

Mr. Woody, the clerk, advises that it is large enough that

this'many people could probably fit in, but not comfortably.

So if members of the Staff or CP&L officials are

2929

not essential to that, they may wan to consider sldpping

that session or not. watching it, because some deference must

be made to the opportunity for the pub'ic to, at least in a

repxesentative fashion, to be in and ce~inly a'y member of

the pxess would have to be considered. But this is only fox

the sessi'on Tuesday morning.

0?cay. Any preliminary matters'P

{No response.)

CI&XRMAN SMXTH: Mr. Erwin, as I stated, has

asked that. the oxder of cross-exam9.nation be changed so that

he may examine this panel upon the tramscript.

Did you understand that to be the caseT

MR. ZXKQIAN: Yes, sir.CHAIR~ SMITH! — So we'1l come to Mr. Gordon.

MR. REXS: I'l ask Panel 3 to ascend the stand.

~ihereupon,'17

PRANCXS iXo LONG

IB

HUGH Ce„DANCE

20 resumed the stand as witnesses on behalf of the Regulatory

Commission Staff, and, having been previously duly sworn,

were exandned and testified further as follows:

DXRECT EZ2QII'NATION

BY MR REXS.

X aslc them if they have a piece of testimo'ny

2930

~ mph 4 t prepared titled, at. the top Panel IXX, Testimony. of Long and-

DanceP

3 (Witness Dance) Yes, I do.

Have you pregared the answers in this testimony''

Did you prepare the anmmrs 9.n this testimonyP

We did,. in conjunction with our staff. We'e

sponsor9ng the testimony.

Do you have any additions or corrections to be

'

t0

made'o this testimony at th9.s timeV

Yes, I do. X have several additions and

correc-'7

'j8

tions.

The first is on page 11. The answer to the firstquestion, 'delete the word "No." Insert the sentence, "We

'do have operational. 9.ssues at Brunswick wh9.ch have not. been

resolved."

CHAXBMAN SKETH: Excuse me.

X. think many people wi3.1 want Co copy this down

verbatim in the testimony.

WXTNESS DANCE: "We do have operat9onal i's'sues

20'at Brunswick which have .not been resolved."

CHAXEQQLN SMXTHc Yes, sir.WITNESS DANCE: And in the second line of the

25

same answer, delete the second sentence beginning w9.th

"Ne have no..."I

CKMRYdLN SMXTH: That sentence is deletecD

II

2931,

mpb5 WITNESS DANCE: Yes, sir.HR. KIRKllAN: Will you repeat that? T&ich

sentence is d'eleted?

WITNESS DANCE: "We have no act9ve issues with.

'the program."

HR. KIRMIAN: All right.

CHAIRMAN SMITH: Yes, sir.WXTMESS DANCE: At the end of the answer, insert

the following:

IO "Reg9on II completed in January, 1979, a

thorough operat9ons QA inspection at Brunsvrick.

Eleven items of apparent non-compliance were

ident9.fied primarily in programmatic areas.

Cop9es of th9s inspection have been provided

at Chis hear9ng.. ~"

HR. BRIGHT: Primarily vrhat?

WITNESS DANCE: "...in programmatic areas."

Hake that read "Cop9es of this inspection report,"

f9 would youp please o20''ll start again at that last sentence we were

working on ~

22 "Copies of @les inspection report have

been provided at this hear9ng, and Hr. Kellogg

and Ruhlman have given verbal test9mony. We

expect the issues ident9fied will be addressed

2932

mpb6 1 and corrected. I understand CPSL's xesponse

is being made a part of this record."

CHAIRMAN SMITH: "X understand~7

WITNESS DMCE: "X undexstand".

CHAIRMAN SMXTH: Well, this is a continuation of

a question addressed to you, or to the —it seems to me it'a- continuation of an oxiginal question addressed to the

panel'.

12

16

20

22

23

So if that is the case, and X W~ it is,-orould

you mind amending it to say "X, Dance,understand"2'ITNESS

DANCE: That would be fine.

MR. BRIGHT: Qn behalf of CPS'

WXKIESS DANCE: "...is being made a paxt of

this xecord."

"Reinspection vill be perfoxmed by XGE

to assure corrective iction has been completed,

or has been taken."

On page 3.4, in the second paragraph, in the

fifth line of that paragraph, aftex the word "identified",

delete the vord8 "only Cm", and insert "one item ox non-

compliance and five ~

At the end of that paragraph insert:"A thorough inspection of the QA program

conducted in January, 1979, identified eleven

items of non«compliance, and it, was discussed

2933

earlier."

MR. BRXGHT: You talk much faster Chan X can

m'ite, Mr. Dance.

"A thorough inspection of the QA pxogram..."

NIL.ESS DANCE: "...conducted in January,

1979, identified eleven items of non-compliance",

and it +as discussed ear3.ier."

CHAIRMAN SMITH: You mean "testified about".

Is that what you'e referring to in the testim'ony?

10 MXTNESS DANCE: Yes, sir, I do mean that.

CHAIRMAN SMXTH: tte3.1, can you say "~as the

subject of the testimony of Messers. Kellog and RuhImam"2

HIKKSS DANCE: Yes, sir, I'd 1Q:e to make that

the case.

On page 15, the second paragraph, after the

word "Brunsvick", insert the sentence —that's the second

line in the second paragraph:

18

39

20

"The QA inspection of january, 1979,

identified 27 programmatic matters requixi'ng

'. correction."

22

23

MRe BRXGHT- 252

WITNESS MME: 27~

NR~ BRXGHT: 27 ~ .

CHAXHV~ SMITH: "...27 programmatic matters..."

There was something befoxe.

2934

NXTNESS DANCE: "...yrogxammatic matters recpxirin

correction."

Delete the woxd "However"; insert "Add9tionally".

On page 30, the first answer, the first line,aftex "Brunswick" insert "Unit. 1 and 2 combined".

On page 39, in the fi'rst paragraph, in the th9rd

8

1in'e, in the parenthesis, the number "2 inspectors in 1978",

cha'nge that to "3 9nspections. in 1978"; three.

CHMRHAN SMXTH: That's two correct9.ons.

$ 0

'l2

NXTNESS DANCE: Yes. "3 inspections in 1978~

should be the yaxenthesis.

Now the fix'st two paragraphs on page 39 do not

go with th'e qmstion where they are. 'They go at, the end

of question four on yaga 40.

MR. KXRIQZKN: Hay 'X ask, ax'e these the paragx'aphs

that start "Since that. time"P

i7

38

19

3cnow" .

NXTNESS MNCE: "Since that. time" and "X do not

That would make the answer four with three

20

22

separate paragraphs..

On page 41, in the first answer, insert after

the'third line, the third line ending with "and", insert:

"additionally their commitment to..."On page. 59, in the f9.rst anmser «--

CHAXRMAN SNXTH: What page are'wo on now7

2936

mpblD

2

omitted and not consecutively used. And we will vexify the

numbers when we come back, if we need to come back, over the

3 . weekend.

If we need to come back, why, we'l make that

correction, oz we'l make the correction in any" c'ase.

CEhXRQZ SMXTH: X tQLt.nk it'8 certain Chat, you'lbe coming b'ack.

(Laughter.)

MR. GORDON: Mr Chairman, do they have'he

information to finish out the year of '78 available? X

meaa, they go up through August. I mean, looking at. Che

txends. Xo the information available to finish out charts

on'0'nd 32, is what I wondered, if they could geC th'at

'information.'HAIRMANSMXTH: Axe you requesting that infoxma-

I7

IS

Cion frcaa the Staff?

MR. CORM': Yes, sir. I thix8e it would be

beneficial to see how the entixe year looks rather than

gust through August

20 MR. O'NEXXXc Mr. Chaixman, that infoxmation isprovided in the prefiled testimony of the Applicant, on

page 61 of the testimony of Messers. Mcouffy and Banke, fox

Mr. Goxdon's information. X'm sure the Staff might want tocheck that out. That's page 61.

MR. GQRBOH: Thank you, sir.

MPB/ebl4s mphil

W

p>2»

2937

NXTHESS QAMCSs tfe can provide that infoxmationoJ

Na may not ha able Co provide it on computer pekah outs~ but,

ve can provide the numbers.

CHhXRMM SMXTHc Gentlemen, you'lX recall our

discussion ~

t 7

HR REXSa kh; Chairman> X've been informed that

these are the corxect anmrerso Xf X may< X thought X might

"„8'BAXRNMBNXTHc All right,BY NR. BBXSe

~ 'I 0%'I

10 O'eatlemen> if you vere asked We cgmitions nest-ltbat axe set out herein< Mould you give Me answers as aor

x.'ected P

(Witness Dance) Yes<' vouldo

(tIitness Long) Yes~ ~

Okay

fci;:h

1.7"'.

~ ~

addressed

give them

; Region XX

encl vouM you give tham, except. foi. the. questionst

to you< one or the other~ indivMua11y~ vrould you

as @all individually as ccel2. as She 'p'ositian of

of the X@3 staff of 8RCP

20''i,

(Nitness Dance) Yes< X mould

{Nitness Long) Yea ~ X would

NRi BBXSa That's all X have'

I

?3,'Panel XXKtostimony follcers, @ah"inspsctioa . - =-.

findings -report.)

25:"

Panel III - Long and Dance

g. Nr. Long, can you give us your position with NRC, your contact with

CP8L in the course of your work, and what that contact was or is?

A. Presently, I am Chief Reactor Operations and Nuclear Support Branch,

Region II,Atlanta, Georgia. Initially I was an inspector at H. B. Robinson

during the construction phase; then later I was Chief, Reactor Construction

Brancn for both Robinson and Brunswick. Subsequently, I have been involved

with both facilities during operations and testing. I am presently cognizant

of both, and responsible for implementing the IE operations inspection

program and enforcement policy.

g. Mr. Long, nas your experience centered around CP&L's construction or

operations of nuclear facilities, or both?

A. Both, as stated above, by virtue of having held different positions at

different times in IE. I have supervised IE inspectors in construction

and operations.

g. Mr. Dance, can you give us your position with NRC, your contact with

CPKL in the course of your work, and what tnat contact was?

A. Presently, I am Chief, Reactor Projects Section No. 1, Reactor Operations

and Nuclear Support Branch, Region II in Atlanta, Georgia. In this position

I supervise the principal inspectors "for Brunswick and Robinson.

Gentlemen. does operations include the start-up of new facilities—and can

you give us the dividing line of where inspectors of operations take over

from inspectors of construction?

A. Yes. Startup and startup testing follow issuance of an Operating

license (O.L.). We inspect startup testing and operations and have

inspection programs for these activities. About 12 months prior to the estimated

O.L. date, we initiate a preop test program in preparation for O.L. issuance.

This is parallel but independent of the continuing construction inspection

program. Different people are involved. We take over all inspection program

responsibility when the O.L. is issued.

Q. What do you think of CP8L's present overall corporate managerial abilityor capability to run a quality assurance/quality control program in the

operation of nuclear facilities?

A. We are satisfied that CPSL has both the ability and the capability

to run a QA/QC program for operations.

Q. What do you think of CP8L's present managerial ability or capability

at specific nuclear facilities to run a QA/QC program in the operation of

those facilities?

- 3-

A. Based on experience at both HBR and Brunswick, there is no question in

our mind that CP&L does have the ability and capability.

Have any inspections of operations, as contrasted with construction,

yet taken place at Shearon Harris'

A. No - operations related inspections or management meetings related to

operations will not be planned until approximately 12-16 months prior to the

estimated O.L. date.

g. What CP&L facilities have had operations inspections?

A. Robinson and Brunswick 1 and 2.

g. When is Shearon Harris scheduled to begin operations?

A. The current fuel loading date estimates for Units 1-4 are June 1, 1983,

June 1, 1985, June 1, 1989, and June 1, 1987, respectively.

g. Do you have any facts indicating any present need of CP&L to improve

its technical ability in order to properly operate Shearon Harris'

A. No. Me expect the present three operating units of CPEL will provide a

nucleus for the expansion of the technical staff required for the operation

of Shearon Harris.

g. Do you have any facts indicating any present need of CPSL to improve

its managerial capability or capacity in order to properly operate Shea«n Ha«is

A. No. Our observation has been that CP8L managerial capability and

capacity are continuing to be broadened and improved.

g. Generally, how are CPSL's gA activities organized?

A. gA activities for CPSL and their existing nuclear plants is governed

by three gA organizations, each with independent missions but all charged

with providing gA services. These organizations are the plant gA organization,

the Operations gA Section(based in the corporate .office and reporting to

Department Manager, Generation), and the Corporate gA Audit Section.

The Corporate gA Audit Section performs audits of activities at the corporate

office and at the Brunswick and Robinson facilities. Audit findings and

resolutions thereto are reported to the CP8L chief operating officer.

The Operations QA Section performs audits at the Robinson and Brunswick

facilities approximately twelve times yearly at each facility. Audit findings

are identified to the Department Manager, Generation and tu the

plant manager. Personnel in this section are assigned to specialty areas of

audit, responsibility, (such as maintenance, health physics, or operations),

and they conduct pre-planned audits in accordance with established CPSL

plans and procedures. The Operational QA section also reviews NRC cor-

respondence to further identify problem areas and track NRC-unresolved

items.

The plant QA organizations at Robinson and Brunswick are similar.1

They perform both QA and QC functions in accordance with policies established

in the Plant Quality Assurance Manual. The plant QA supervisor reports

to the plant manager and has a communications link to the Manager, Operations

QA Section. The Bru'nswick plant QA staff has a supervisor and six personnel

assigned; the Robinson plant QA staff has a supervisor and four personnel

assigned. In addition to the routine QA/QC functions in areas such as

maintenance, activities, procurement, and design modification; the Plant QA

group performs audits at the request of plant supervision or management. Itprovides mohthly reports of all outstanding items (e.g., NRC, corporate or

pl ant identi fied) to the pl ant manager. The Pl ant QA group i s audi ted by

both the Operations QA Section and the Corporate QA Audit Section.

-6-

g. Can you give a history of CPEL's running of such quality assurance

programs at both the corporate level and at plant sites?

A. The HBR plant is an older plant. The construction under a turnkey

contract took place before 10 CFR 50 Appendix B was placed in effect.

All gA related functions were delegated to the turnkey 'contractor,C

Westinghouse. The O.L. was issued in 1970, the same year Appendix B

became effective. This regulation was slow in being implemented for

operating plants, Robinson being no exception. Almost two

years were required to put a gA program into effect at Robinson which could

be considered adequate. This was typical of most operating plants in that

time frame. CP8L did take the initiative incidentally, on gA Program development

and assigned key management individuals to Americal Nuclear Standards Institute

(ANSI) working groups developing the nuclear standards for gA programs.

Brunswick was essentially constructed under a construction gA program.

Testing and operations gA programs were reviewed and accepted by NRC and IE

inspections were conducted, aimed specifically at plant and corporate

implementation of the programs. There were instances where inspections

revealed less than desirable involvement of corporate management and

discussions were held with the licensees'anagement on this subject.

Q. Has there been any trend in CP&L's managerial involvement in QA/QC

program at its operating nuclear plants?

A. Yes. CP&L management has increased its involvement in operating plant

QA. It has developed detailed QA administrative controls. The CP&L Cor orate

ualit Assurance Pro ram - Part 2&3 originally issued Oecember 19, 1974, has

undergone numerous revisions since that time. Facility administrative

procedures relating to QA for both Robinson and Brunswick have undergone

revision and refinement. In 1974 the Robinson Plant QA organization was

created to supplement the Corporate QA organization which existed since

1972. A similar plant QA organization was also created for the Brunswick

facility. Further, there has been a decrease in the number of noncompliances

and the number of repeated reportable events over the past four years.

What was the effect of these changes?

A. There has been an increased involvement by QA personnel in plant activities

and an increase in the level of procedural/administrative guidance relating

to QA. The scope and frequency of Corporate QA audits has increased. Examples

of where audits have helped were the identification of a substandard tracking

system of followup items at Robinson and of incomplete surveillance testing of

Brunswick. Corrective action was taken in both instances.

g. What is the basis of your answer?

A. I&E inspections related to plant operations and in the gA/QC areas at

Brunswick and Robinson dating from September 1974. The initial inspection

revealed 20 discrepancies at the first Brunswick unit to be licensed (1974)

and the initial inspection of operations gA on the second Brunswick unit to

be licensed revealed only 2 discrepancies. The initial inspection of

Robinson gA for operations (1975) revealed 13 discrepancies. Recent inspections

of on-going gA activities revealed one discrepancy at Robinson and no

discrepancies at Brunswick.

g. Has CPSL's managerial ability to run such programs evolved, and if so

in what way and over what period of time?

A. We have observed a continual upgrading of management involvement over the

years. CP8L management today represents an impressive record of continuity

and accumulated man-years of experience. CP8L management is heavily involved

and committed to safe nuclear plant operations. We have observed the evolution

of gA from the time when it was essentially non-existent to the present where

it is a major management tool. The staffing of the gA organizations above

is a clear indicator of the evolution.

g. Can you give us the specific factors both positive and negative, on

which you bas'ed the prior answers on CP8L's managerial ability?

- 9-

A. CPSL management ability in nuclear QA activities has steadily improved

over the years. As stated previously, CPKL was slow, as were most licensees,

in implementing the QA program for operations at their first facility.

We are aware of the early determination by CPEL to get involved

in QA. They were very active in ANSI work groups who developed the principal

QA standards for QA program auditing and qualifications of QA personnel.

CP&L impresses us as a conservative management organization, tough in deaTfng

with the issues that tend to create an expansion of manpower requirements.

Nevertheless, significant increases in staffing of vital positions

and realignment of key management personnel partially in response

to NRC concerns are important factors in forming these opinions.

They are strong defenders of their position; however, they have made

decisions which demonstrated an awareness of safety issues and have met

comnitments promptly once decisions were made. We have been working

directly with CP8L management at all levels for more than ten years.

Q. Does CP8L have sufficient QA/QC personnel presently employed to properly

monitor operations?

A. Yes. Plant QA organizations accomplish audits of all aspects of plant

activity and the Corporate Operations QA Section accomplishes about 12

audits per year at each facility. Corporate QA Audi ts Section audits are

accomplished about 2 times per year at each facility, and at the Corporate

Office additional audits may be performed upon request by corporate or site

management. QC surveillance of plant activities, such as at a maintenance

procedure "hold point," are accomplished as required by plant procedures.

- 10-

Are they properly trained'

A. Yes. Inspection of training activities at Brunswick and Robinson,

including QA/QC personnel, revealed no discrepancies in the past two years.

Q. What trends have you'een in CP8L's attitude to QA/QC?

A. CP8L has demonstrated strong involvement and comnitment to QA/QC at

all levels of their organization and at both the Robinson and Brunswick

facilities. Implementation of QA/QC controls over the conduct of main-

tenance at Brunswick has shown little improvement.

Q. Please give details.

A. CP&L has increased the scope of administrative controls relating to

QA/QC. The utility has reorganized and expand plant staff QA organizations

at both Robinson and Brunswick and has increased the scope of these organization's

audit/surveillance activities. The utility has been responsive to NRC findings

in the QA/QC area, when corrective action was required. No evidence of signifi-can't programmatic weakness in the CP&L QA/QC organization has been observed.

Significant improvements in the conduct of maintenance at Robinson have been

observed by I&E inspectors. No maintenance related noncompliance has

resulted from the past two annual maintenance inspections.

- 11-

Although improvements in maintenance admini'stration have occurred at

Brunswick (refinement in administrative procedures for maintenance) the

plant has received five NRC citations for noncompliance with these controls

in the past two years. The most recent annual inspection of maintenance,

in December 1977, includes one of these citations.

Q. Do you have any facts indicating any present need for CPSL to improve

its QA/QC programs or the implementation of those programs in order to

properly operate S-H?

.A. No. Let me explain that we are continually pursuing the QA/QC management

type systems for improvement. We have no active issues with the program.

Implementation of the program has often resulted in a slower timetable than

we would like. We recognize that plant and corporate management must

establish priorities. Whenever these priorities differ from the NRC's,

it is our intent to seriously pursue these with CP&L.

Can you give us a brief outline of i8E's activities in regard to

operations management and quality control at the Robinson nuclear plant?

A. Operating License No. DPR-23 was issued for Robinson on July 31, 1970.

Overall some 150 inspections pertaining to operations have been conducted.

This includes 30 inspections and one corporate meeting since September 1,

1977 when the testimony for the 1977 Harris Construction Permit Hearing was

written.

- 12-

The IE Regional Office conducted an initial management inspection of

administrative controls affecting quality and operations at Robinson in

1971. The first in-depth inspection of the CP8L gA program supporting plant

operations was in July 1975. This was subsequent to the ismance of the

CP&L DA program topical report (The CPAL ~Cor orate ~ualit Assurance

~pro ram - Part 2 and 3) dated December 19, 1974. This inspection revealed

13 discrepancies, most of which were linked to program weaknesses.

CP8L was responsive to these findings and most were resolved within

three months.

In December 1972 and again in December 1974 meetings with CP&L management were

held pertaining to operation of Robinson. The AEC was critical of the slowness

in developing a gA program and repetition of similar items of noncompliance.

A sugary of these meetings is in Appendix E. Subsequently, management

performance has followed a continually strengthening pattern similar to the

chronology of gA discussed in the next section.

gA activit'es at Robinson are inspected several times a y'ear, similar to

IE inspections at Brunswick. On-going inspections have revealed that mo«

discrepancies are centered in the areas of maintenance, training, design

changes and modifications, and document/records control. In the three years

that gA activities have been followed, improvement in performance is noted in

that the number of discrepancies identified by IEE inspectors has decreased.

No evidence of overall programmatic weakness has been pinpointed for Robinson.

-13-

Today we consider the management staff at Robinson to be experienced, as

evidenced by the fact that many group supervisors have been assigned at the

plant since 1969; qualified, as required by American National Standard

Institute, code ANSI N18.1, "Selection and Training of Nuclear Power

Plant Personnel," and technical specifications; and responsive to NRC

concerns as evidenced by the December 1977 boron injection tank thermocouple

failure investigation and the current upgrading of facility procedures and

administrative controls.

Can you give us a brief outline of I&E's activities in regard to

operations management and quality control at the Brunswick facilities'

A. Operating License No. DPR-62 was issued for Brunswick 2 on December 27,

1974 and Operating License No. OPR-71 was issued for Brunswick 1 on September 8,

1976. Overall about 110 inspections pertaining to operation, including pre-

operational testing, of Unit 2 and about 80 inspections pertaining to operations

of Unit 1 have been conducted. This includes 31 joint inspections and one

corporate meeting since September 1, 1977 when the tes'timony for the 1977

Harris Construction Permit Hearing was written. Since September 1976 all

but two inspections have pertained to activities of both units.

The IE Regional Office conducted the first comprehensive inspection of the

CPSL gA program necessary to support operation several months prior to the

operating license issue for Unit 2 (the first of the Brunswick units to be

-14-

licensed). This i'nspection was in September 1974. This inspection identified

20 unresolved items with at least one item in each area inspected. The

program was found to be "fragmented" and failing to fully meet FSAR com-

mitments. The inspection report stated that the inspectors "did not

see those management controls that are necessary to assure ... that the plant

will be operated safely and in compliance with license requirements."

A reinspection was held in December 1974, which confirmed numerous program-

matic changes to the Brunswick program and resolved most of the initialNRC findings in gA. The program was found to be acceptable by the time the

Unit 2 license was issued. A similar in-depth inspection of gA in June

1976, prior to licensing of Brunswick Unit 1, identified only two dis-

crepancies. This indicated the evolution of an improved and acceptable

gA program for operations.

Brunswick management in the years from late 1974 to early 1977 had numerous

operating problems and issues. The significant upgrading of the gA program in

late 1974, the starting up of two units in 1975 and 1976, the many repetitive

reportable occurrences and noncompliances, and the loss of four senior plant

management personnel due to resignations are examples. In February 1976

following an off-gas explosion, NRC management met with CP8L management to

discuss our concerns of their operation including the timeliness, the quality,

-15-

and history of reportable occurrence reports and to reemphasize requirements

to follow emergency instructions. Shortly, thereafter management moves were

made at the corporate and plant levels. In the fall of 1976 recognizing the

need for additional training of supervisors, a short training course on

BWR operations was conducted onsite. In January 1977 Region II confirmed

management qualification met ANSI N18.7 and technical specification requirements.

Continued upgrading of personnel training, qualifications, and responsiveness

to NRC concerns has been demonstrated. Today we consider the management staff

at Brunswick to be qualified and continually being strengthened by the in-

house SRO training. Supervisory staff turnover has been minimal since

January 1977. One superintendent was transferred to Robinson as Plant

Manager in November, 1977.

In sum, no significant gA program weakn'esses have been identified in the on-

going inspection of gA at Brunswick. However, implementation of maintenance

administrative controls has been an area of weakness, as evidenced by

continued IE findings of noncompliance in this area.

g. In addition to looking specifically at operations management and quality

control at Robinson and Brunswick, did you look at any other areas of

operations at these plants to gauge CP8L's managerial ability'

- 16-

A. Yes, we looked at how CP8L handled problems involving radiation protection,

security and inservice inspections. We also looked at CPSL's Licensee Events

Reports, and tneir noncompliance record.

g. What did you find as to radiation protection at Robinson?

A. From January 1975 through October 6, 1978, 14 inspections by ihe I8E

Radiation Support Section were made at Robinson, resulting in 21 noncompliance

items being cited. Other program weaknesses have been identified and clas-

sified as open or unresolved items. The following problem areas were

considered significant because of repetition or tneir potential impact on

the radiation protection program:

a. Radiation Ex osure Control

There were two instances where workers exceeded the radiation exposure

limits specified in 10 CFR 20.101; once in 1975 and once in 1978.

Eacn overexposure resulted from administrative errors, and appropriate

corrective action appears to have been taken. During the 1978 refueling

outage, 'difficulties in maintaining exposure .as low as reasonably achievable

(ALARA) were noted. Some improvements have been made, and a formal ALARA

program is currently being considered by CP8L.

- 17-

b. Internal Ex osure Control and Evaluation

Examples of concerns in this area have included minimal air sampling

associated with steam generator maintenance, inadequate surveys of

respirator contamination, and a questionable whole body counting

program. Improvements have been made. The Environmental and Radiation

Control Supervisor directed an upgrading of the air sampling program

in March, 1978. More care and attention has been applied to respirator

surveys. A procedure specifying whole body counting criteria was

issued in July, 1978, and the purchase and installation of an on-site

whole body counter is planned.

c. Job-Related Health Ph sics Controls

During the 1978 refueling outage, IE inspectors identified some

radiation work permits (RWP) that were not functioning as intended to

provide timely job-related radiation protec ion information and to

.insure the understanding and use of that information. As a result of

re-instruction of both preparers and users of RWP's, and a continuing

internal evaluation of effectiveness, significant improvements appear

to have been made in this important aspect of the-radiation protection

program.

-18-

d. Postin Labelin and Control of Radiolo ical Areas

During 1977 and 1978, five noncompliance items have been cited involving

improper posting or controls over radiation and high radiation areas,

and failure to label radioactive material containers. Corrective actions

have been taken. The problems of labeling containers and posting

radiation areas appear to have been resolved. The long term effectiveness

of high radiation area controls, which depends upon individual attentive-

ness, cannot be fully evaluated at this time, but will continue to be

inspected periodically under the continuing IE inspection program.

g. 'rlhat was found as to radiation protection at the Brunswick facilities?

A. A review of radiation support inspections from mid-1976 through October 6,

1978 was made. During this period of time 13 inspections were made, resulting

in 14 items of noncompliance. Additional problems have been identified as

the result of LER's from the licensee and unresolved items or open items

identified by the inspectors. In addition to these problems, a major problem

area is presently being negotiated between CPSL and NRR regarding the

operability of the Off-Gas System.

Major areas identified which could adversely influence the radiation

protection program are:

-19-

A. Postin Label in and Control

Failure to post and control high radiation areas per the Technical

Specifications were twice cited in 1976. The failure to control high

radiation areas was cited again in 1978. The licensee's response to

this item was received in November 1978. The action proposed by

CP&L to control the high radiation areas appears reasonable. However

the fact'that additional examples were identified approximately

two months after the latest citation seems to indicate that adequate

corrective actions were not immediately taken.

B. Testin of Effluent Monitors

In 1975 three citations were made concerning the failure to perform

tests of effluent monitors as required by the Environmental Technical

Specifications. In 1978 it also was noted that the corporate quality

assurance group had identified that functional tests of effluent

monitors had not been performed as required. Actions taken will be

reviewed during continuing IE inspections.

The Off-Gas system is presently noi operable due to hydrogen ignition

problems. Discussions and correspondence have been taking place

between CP8L and NRR concerning corrective actions and the time frame

for such actions. CPSL has projected that approximately 8 years will

-20-

be required to make the system operable. NRR is presently considering

Technical Specification revisions until such time as the system is

operable. This is on-going. In the interim, the inoperability of the

system could have an adverse effect on radioactive gaseous releases

depending on fuel integrity.

D. Control of Abnormal Situations

A traveling incore probe was retracted through the shield, resulting

in an unidentified and uncontrolled high radiation area. This single

event resulted in four citations in 1976 involving failure to follow procedures,'

failure to perform surveys, and failure to maintain survey records.

Subsequently, a deviation was cited because the licensee did not take

all corrective actions as stated in his reply. Additionally,

a management meeting was held with CPEL on this matter.'his was a

significant problem area at that time.

g. In what way do you believe these past radiation protection experiences

of CP8L reflect on its capability to operate Shearon Harris?

A. Based on the operating history of ihe Brunswick facility the principal

concern about CP&L's ability to construct and operate the Harris facilityin the areas of radiation prote0tion and radioactive waste management is

-21-

the ability to maintain an adequate staff in the Environmental and Radiation

Control group (E&RC). Under the organization at Brunswick and H. B. Robinson,

the E&RC group is responsible for radiation protection (dosimetry, contamina-

tion and exposure control, respiratory protection program, survey instrument

calibration, etc.), chemistry, radiochemistry, radioactive effluent control

and records and radiological and nonradiological environmental monitoring

(sample collection, some sample analysis, etc.). The work of the E&RC

group is carried out by Radiation Control and Test technicians (RC&T

technicians).

RC&T technicians are classified in one of four levels - Level III (basically

a learner position), Level II, Level I (fully qualified and 'capable of handling

independent project-type assignments), and foremen. Foremen are assigned to

supervise functional areas such as health physics or radiochemistry. The

present Brunswick organization includes four foremen, one of whom is assigned

to a crew which normally works at Brunswick but which is also available to

provide additional manpower to H. B. Robinson during outages. One position

is presently vacant.

Since the startup of the Brunswick facility, there has been an attrition of

both RC&T technicians and foremen. While some of these people have gone to

other offices in CP&L, others have left the utility. Foremen generally have

been promoted from the technician levels Replacements for the technician

positions have been hired but generally are at the Level III whereas losses

of technicians are occurring at the Level I or Level II. The ne't effect

-22-

has been to lower the overall capability of the technicians, both in training

and experience.

The E&RC group formerly had two professionals on the staff (one health physicist,

one chemist). The auo individuals who fi1'ied these positions have left;one was reassigned to the corporate office, the other left the company.

The only professional presently in the EERC group (other than the EMC

supervisor) is a recent college graduate employed at the 0unior Engineer

level. Again, this has resulted in a decrease in the level of training

and experience at the plant level.

In considering the capability of CPRL to operate the Harris facility it is

necessary to consider the ability to adequately staff Harris without further

reducing the ability to perform the responsibilities at Brunswick and

H. B. Robinson. The ESRC group responsibilities at Harris will begin with

the preoperational test program with chemistry control and system flushing and

testing and will continue on through preoperational testing and startup with

increasing responsibilities for chemistry, radiochemistry, health physics

and environmental monitoring. As the responsibilities grow with one

unit, they wi11 begin on subsequent units. This will impose an increasing

workload with expanding responsibilities. The ESRC group will need to be

staffed to cover this workload over a period of years; the use of overtime

to provide coverage will solve short-term problems but cannot be looked

upon as an alternative for adequate staffing, both in terms of number of

people and experience, for a situation which will cover a period of years.

S

-23-g. Are Brunswick and Robinson presently adequately staffed in the area of

radiation protection?

A.Yes.'.

In view of your staffing observations do you believe CPSL capable of

managing Shearon Harris?

A. Based on the results of radiation protection inspections at both the H.B.

Robinson and Brunswick Steam Electric Plants, it appears that Carolina

Power and Light Company is capable of operating an additional nuclear

generating station in accordance with the regulations and without creating

a hazard to the public health and safety.

g. What was found as to security at Robinson?

A. From April 1976 through June 1978, four security inspections have been

conducted at Robinson. These inspections resulted in three items of non-

compliance (two infractions and one deficiency). There were no repeat

items of noncompliance.

The most recent inspections have indicated significant improvements.

Based on ihe above information and in the opinion of security inspectors,

Robinson is considered an average plant when measured against all other

Region II facilities and the I&E Inspection Program.

-24-

What was found as to security at Brunswick?

A. In 1975 a civil penalty was assessed against CPKL for noncompliance

with security requirements at Brunswick. From March 1976 through September

1978, seven security inspections have been conducted at Brunswick. These

inspections resulted in sixteen items of noncompliance (eleven infractions

and five deficiencies). Two of the items, both infractions, were repeatil'tems of noncompliance.

Based on the above information and in the opinions of inspectors who have

been involved in recent security inspections, Brunswick can be said to be

average when measured against other Region II facilities and the overall

I8E Inspection Program. The differences between the numbers of non-

compliance items identified at Brunswick and the number identified

at Robinson are due to the greater complexity of the Brunswick'security

system.

g. Why was the civil penalty assessed against CP8L in 1975?

A. A $ 5000 civil penalty was associated with four items of noncompliance

at Brunswick found during an inspection. These items were in the area

of plant security for failure- to implement access control requirements.

The security inspection, which resulted in tne civil penalty, was

requested by the principal inspector whose'equest was based upon his

inspection activities indicating apparent weaknesses in Brunswicks imple-

mentation of the security plan. The civi 1 penalty was originally assessed

-25-

at $7000 and CP8L's original position denied some items of noncompliance.

The final resolution assessed the penalty of $ 5000 which CP8L paid in

February of 1976.

Q. How many times had similar instances occurred?

A. During three separate inspections Brunswick received noncompliances in

security areas pertaining to access control and a meeting between CPEL

and NRC was held on this matter prior to the inspection that resulted in

the civil penalty.

Q. How does this reflect on CP8L's QA/QC program and the capability and

responsibility of its management?

A. The recurring items of noncompliance involving the security program

reflected upon management's apparent inability to take corrective action.

In general the civil penalty appeared to be more related to the management

program than the QA/QC program. As we have indicated, CPSL's security

record has improved since 1975.

-26-

g. How do you assess this area today?

A. We consider CPSL to be committed to meeting security requirements.

today.

0. What did examinations of CP8L's inservice inspection programs at Robinson

show?

A. Inservice inspection nondestructive testing of the Robinson facilityvessel, piping and piping components has been contracted to Westinghouse.

The inspection activities are coordinated by Carolina Power and Light (CP&L)

inservice inspection coordinators at the corporate office and site level.

The CPEL gA Department conducts audits, does surveillance inspections, and

reviews the inspection data and results using personnel that are qualified

either Level II or Level III for the nondestructive test method under review.

-27-

NRC Region II inspectors review the inservice inspection program, procedures

and results. The NRC review includes both the inspection activities by

Westinghouse and the control/surveillance activities by CP8L.

CP8L has shown a high level of concern for proper implementation of the

inservice inspection requirements and CP8L management has been responsive

to inspection findings by both CPSL and NRC audits and inspections.

g. What did the examinations of inservice inspection at Brunseick show?

A. Inservice inspection nondestructive testing of the Brunswick facilityvessel, piping, and piping components has been contracted to Southwest

Research Institute (SWRI). The inspection activities are coordinated by

Carolina Power and Light (CPSl ) Inservice Inspection Coordinators at the

corporate and site level. The CP&L gA Department conducts audits, does

surveillance inspections, and reviews the inspection data and results using

personnel thai are qualified as either Level II or Level III for the

nondestructive test method under review.

NRC Region II inspectors review the inservice inspection program. procedures,

and results. The NRC review includes both the inspection activities by

SWRI and the control/surveillance activities by CPSL.

- 28-

CP&L has shown a high level of concern for proper implementation of the inservice

inspection requirements and CP&L management has been responsive to inspection

findings by both CP&L and NRC audits and inspections.

g. What has an examination of reportable occurrences and enforcement actions

at Robinson shown?

A. H. B. Robinson reportable occurrence and enforcement history from

January 1, 1975 through August 31, 1978, can be summarized as follows:

a. Reportable Occurrences (licensee event reports)

Total

1975

20

1976

19

1977

32

1978(Thru August)

18

b. Enforcement,(noncompliances and deviations)

1975 1976 1977 1978(Thru August)

Violations

Infractions

Deficiencies

Deviations

0

23

-29-

As shown in the table noncompliances have decreased from a high in 1975,

and have been relatively stable in the past three years. A detailed review

of the licensee event reports and noncompliance from September 1977 through

August 1978 indicate that H. B. Robinson management has implemented changes

in facility operation and administrative controls which provide improved

compliance with NRC regulations. Specifically, corrective actions taken

for licensee event reports and noncompliances have been directed to

permanent corrective measures necessary to prevent recurrences. These

corrective measures include: comprehensive revision to plant operating

procedures and administrative controls, indoctrination and training of

personnel in identified problem areas, and investigations of occurrences

for generic potential.

Improved procedural controls and personnel performance is reflected by the

fact that licensee event reports caused by personnel or procedural error

have decreased from ten in 1977 to four in 1978.

A potential weakness in managements implementation of the requirements. in

the radiation control area has been identified due to the fact that there

have been eleven noncompliances in the .radiation control area during the

past twelve months. NRC inspection efforts have been modified to focus

attention on the radiological controls areas in order to identify and

correct specific weaknesses.

-30-

Significant reportable occurrences during the past year include a failure

of boron injection tank thermowell and a plant battery fire. Robinson

management's immediate and long-term corrective actions were responsive.

Investigation and evaluation of the boron injection tank event resulted

in replacement of the boron injection tank. The evaluation of the battery

fire included a request for ven'dor assessment of the occurrence to determine

potential generic significance.

g. What is the enforcement history at Brunswick?

A.. Brunswick enforcement history for 1975 through September 30, 1978, as

categorized into violations, infractions, deficiencies or deviations can

be summarized as follows:

~Cate or@

Viol ati on

Infracti on

Deficiency

Deviation

1975

31

1976

20

1977 1978

0 0

17 13

5 7

3 1

A civil penalty, previously discussed, was imposed for security infraction in

1975 ~ A significant improvement can be seen from the 1975-1976 period. During

- 31-

the past year (October 1, 1977 through September 30, 1978) there have been

27 items of noncompliance - 18 infractions and 9 deficiencies. The general

areas of noncompliance are listed below:

Areas of Noncom liance Infractions Deficiencies

Security

Radiation Protection

Environmental

Administrative and Procedural 3

'runswickmanagement has been responsive in addressing and initiatingcorrective actions for identified enforcement items.

g. Are there any trends ascertainable from examining CP8L's noncompliance

history?

A. Yes, noncompliances have been decreasing.

g. What do Brunswick's reportable events show?

-32-

A. Brunswick reportable events for 1975 through September 12, 1978, are

summarized as follows:

Year 'runswick 1 Brunswick 2

1975 172

1976 13 166

1977 117 69

1978 74 68

A marked improvement is noted from the 1975-1976 period when numerous

malfunctions of the HPCI, RCIC and diesel generators were recorded as

described in the 1977 testimony. During 1978, over 20 percent of the

reportable events have involved containment radiation or o>magen air

sampling monitors primarily due to moisture in the sensing lines. A

modification has been recently completed to help alleviate this problem.

Brunswick still has a problem of water accumulation on the floor in some

safety-related areas. In the past year, at least three reportable events

have been directly attributed to this problem. ISE is currently pursuing

this matter with CPSL.

-33-

Are the licensee event report's on LER's and noncompliances disclosed

summarized in any NRC record?

A. Yes, they are put on a computer in NRC headquarters. Me submit a

computer printout of all CP&L's LER's and reported noncompliances for the

Robinson, Brunswick and Shearon Harris facilities as exhibits 1, 2, and

3 in this proceeding. A few words have been deleted from the noncompliance

reports for security reasons.

Let us now talk of how CPSL presently handles problems in the operation of

its nuclear facilities that might affect the public health and safety—

both as to their procedures and what they actually do.

(}. How does CP8L deal with safety-related problems and incidents that

arise in operations?

A. They are identified ana followed by a limiting condition for operation

(LCO) sheet (Brunswick) and trouble ticket.

g. Is there any program?

A. Yes'n addition to a corrective maintenance trouble ticket, they are

identified and tracked to completion and reviewed by maintaining an LCO

status described in plant procedures.

l}. Who identifies the various types of problems?

A. Any operating person can identify a problem. The problem is then

reported to and reviewed by the appropriate senior staff and/or the Plant

Nuclear Safety Committee.

g. What are their qualifications?

A. The American National Standard, 8N18.1 governing "Selection and Training

of Nuclear Power Plant Personnel," describes the qualification of the plant

staff. In general, this standard requires a minimum of academic training

and nuclear or power plant experience for each position, depending upon its

authority.

g. Is action taken to correct such problems in a timely fashion'?

A. Problems related to safety that keep the plant from operating are given

immediate attention. Some problems which have a lesser safety significance

are handled less expeditiously. An example of this latter type is the

accumulation of water in safety-related areas which has been a chronic

problem and still exists'

-35-

(}. Do the CPSL people who handle problems have the authority and ability

to correct them?

A. They have the authority to correct problems and can request corporate

assistance if beyond their ability or manpower.

g. Do they take such action?

A. Yes. However, in some cases action could be more timely.

What checks does CPEL have to see that action is timely taken to

correct problems, and that such action corrects the problems?

A. Action to correct problems is tracked in a number of different ways

but must generally appear on an outstanding items list with periodic reviews

of due dates. Repetition of certain items may indicate that the solution

was ineffective.

g. Do these checks work'?

A. In our opinion, yes. Infrequently, we have found items not properly

tracked.

-36-

g. What is the basis of your foregoing answers to questions on problems

and incipient problems?

A. It is based on inspection findings at Brunswick and Robinson. The HPCI

delta temperature isolation circuit modification was a case where action

was not taken promptly.

g. Is a program necessary now to deal with problems and incipient problems

in the operation of the Shearon Harris facility?

A. An operational program is not yet necessary to deal with problems at

Shearon Harris. Some two to three years prior to expected fuel loading is

the normal time for a heavy involvement of operational personnel. Training

of operating personnel should be well underway prior to the initiation

of preoperational. testing.

(}. Does CP8L, in your opinion, have the ability and responsibility to formulate

such a program for S-H when it would be needed?

A. Yes.

g. When would that be?

-37-

A. We would expect to see their program for handling operational problems

in effect at the start of preoperational testing - some one to two years

prior to fuel loading.

Q. On the basis of the latest inspection reports, does CP&L have enough

QA/QC people in their licensed nuclear plants and at corporate headquarters?

A. We have no present questions of the adequacy of the size of CP&L's QA/QC

staff. It is consistent with their units in operation, and NRC requirements.

Q. What is the level of their training?

A. We consider the personnel to be adequately trained and that they were

selected based on varied backgrounds and experience.

Q. What is their motivation?

A. This is beyond the scope of our inspection program. However, personnel

involvement in our opinions, is consistent with the QA/QC program.

Q. Do you know of any other opinions in the Atlanta office of NRC on the

competence, reliability or motivation of CP&L to conduct a QA/QC program

either in the operation of its licensed facilities or the future Shearon

Harris?

- 38-

A. We have surveyed our professional staff in the operations, material

safety and security branches in Region II for such opinions.

Please give all such opinions?

A. We have included these opinions in Appendix A. Broken down into

areas of concern, the following specific comments are taken from the

surveys:

l. In the area of environmental protection during the period January 1976

through June 1978, four inspections at Brunswick resulted in nine items

of noncompliance, two infractions and seven deficiencies. One of the

infractions and four of the deficiencies were identified in January 1976.

One inspection at Harris was conducted in April 1978.

Comment: "Review of above history confirms poor management control

in the area of environmental protection. Seme-4mpvevemea4

indicated-~n-0978. Efforts to improve management control

during the period 1977-1978, were reflected in the decreased

number of enforcement items identified in the subject area."

-39-

Since that time plant management has changed at both

facilities, and I have been favorably impressed by bothA

present managers, during recent inspections (2 inspectors in

1978). Ny earlier concerns are no longer operative.

I do not know if these improvements result from a

deliberate management policy of CPEL or if they are a

fortunate by-product of promoting younger men, who matured in

the nuclear power environment to positions of increased

responsibility."

2. Pertaining to Emergency Planning, two inspections were performed at

Robinson and two at Brunswick during 1977 - 1978.

Comment: "H. B. Robinson's Emergency Plan does not contain all the

elements required by an applicant - 10 CFR 50, Appendix E.

An action item was submitted for a review of their plan, stillwaiting for an answer."

3. In the area of operations for the period September 1974 through

December 1976.

Comment: "Capable, but will only meet the minimum requirements - don'

take that extra step that most other utilities take."

4. In the area of operations with two inspections at Robinson and three at

Brunswick from 1975 to 1978.

Comment: "In my early inspection of CPEL plants (3 inspectors in 1975)

I formed a strong impression or opinion that plant management

was giving only lip service to the concepts of having and

adhering to adequate procedures and to putting safety ahead

of short-term production goals.

5. In the area of Operations at Robinson prior to 1975.

Comment: "In that I requested an enforcement conference in

December 1974, it is clear that in my judgement CPSL

management was not sufficiently responsive to NRC concerns.

However, I do not equate this with an inability to operate

a nuclear facility."

The inspector added verbally that he had no overall management issues

since 1974.

6. In the area of Brunswick supervisory activities during an inspection

of January 1977:

Covalent: "Although Brunswick supervisory personnel met ANSI N18. 1-

1971 qualification requirements, it is the inspector's

opinion that staff training could be increased and that a

deeper involvement in day-to-day activities is merited."

g. How did you weigh these opinions in formulating your foregoing opinions?

A. I have noted these comments and see no significantly new views. The

view is expressed that although their management ability is'not questioned,

their ability and commitment in maintaining a highly qualified staff is and

do more than the minimum required was questioned.

g. Do their facts support opinions contrary to yours?

A. The opinions expressed are based on inspection findings and deal

primarily with the time to correct identified conditions and the

qualifications of personnel. We have considered these positions in our

testimony and conclude that CP8L's reliability is acceptable and is

improving.

-42-

Q. On what facts do you maintain your opinion?

A. It is based on CPEL's continually improving management stability and

involvement, the QA/QC program, the trend in decreasing enforcement items, and

periodic involvement with management.

4

Q. Does CP8L presently have a program to identify incipient problems in

operations, including start-up operations, before they develop?

A. CPSL performs periodic tests, QA audits, preventative maintenance and

inservice inspections on a routine schedule at operating plants. They also

review circulars and bulletins issued by the NRC and evaluate those applicable

to their facilities. Corrective action is taken where problems are identified.

Who has the responsibilities for identifying these matters in various

phases of the operations of Shearon Harris?

A. This is not yet required at Shearon Harris. At operating plants,

problems are identified and followed by maintenance trouble tickets. Once

identified and reported, the licensee's supervisors and/or higher plant

management has the responsibility for evaluating the matter.

-43-

g. Do the persons at the operating plants have the qualifications to do

this job?

A. Problems of a major nature are referred to the site engineering staff

for evaluation. Corporate engineering assistance can also be requested.

Consultants can also be called in. CP&L does have the means to evaluate

identified problems. gualifications of plant staff and nondestructive

testing personnel are routinely checked to issue that they are qualified.

g. Do they have the authority to deal with these matters?

A. Matters which are safety-related are reviewed by the Plant Nuclear Safety

Committee (PNSC). They do have the authority to make the necessary decisions.

g. Do they do it and does the CP&L program work?

A. Yes, we routinely confirm that the PNSC reviews safety-related matters.

Examples are'reportable occurrences, plant modifications, and noncompliances.

g. Does CP&L have a method of checking and seeing that these incipient

problems are dealt with?

44

A. Yes. CP8L QA reviews all periodic tests and maintenance requests to see

that the work has been completed and that there are no indicated problems

at Brunswick. At Robinson QA audits the periodic tests and reviews the

maintenance requests. This program seems to be working.

Q. Does CP8L encourage employees to identify problems or incipient problems

in operation of its nuclear facilities that might impact on the public health

and safety?

A.. Any employee can initiate corrective maintenance by filling out the

appropriate sections of a trouble ticket and forwarding it to the shift foreman.

Also all employees are encouraged to identify any safety problems and report

them to a designated staff member.

Q. Does it work?

A. In our opinion, yes.

Q. Does it reward employees who report problems?

A. No.

- 45-

g. Is such a program or are such rewards necessary?

A. A program is required; immediate'ewards are not necessary. People

who do a good job are eventually rewarded through such means as promotions.

g. Nr. Dance, look at item (2)(a) on page ll of the testimony you formerly

gave in this proceeding following transcript page 2076. Can you add anything

to what Nr. Bryant testified to?

A. Ho.

g. Nr. Dance, now going to item (2)(b) on page ll of your former testimony,.

can you add anything to Nr. Bryant's testimony?

A. No.

g. Gentlemen, as to item (2)(c) on page ll of your former testimony, can you

tell me when the incidents recounted there transpired and what happened?

-46-

A. The reactor coolant pump (RCP) seal failed on May 1, 1975. The number 1

seal failure on a Westinghouse RCP in itself is not a serious problem.

However, due to operator error and lack of a procedure covering failure of

the No. 1 seal, total failure of the seals and thermal barrier labyrinth

occurred. The RCP had been shutdown with an indicated seal failure and

subsequently restarted without isolating the pump seal supply. CP8L

upgraded their response procedure following this event.

Fuel densification was first identified at Robinson in June of 1972 from

core flux maps. At the time this was followed as a generic problem for

all PWR fuel. As corrective action, a modified fuel design was installed

during the spring 1973 refueling outage and more conservative operating

limits were imposed.

Steam generator tube sheet/cladding separation problems occurred on May 27,

1971. Investigation revealed that a primary to secondary system leakage

in two steam generators was caused by the tube sheet cladding being pulled

loose by the divider plate. Westinghouse reviewed the generic aspects.

The damaged cladding was cut out and replaced by weld overlay and the plant

returned to normal operations on August 20, 1971.

-47-

g. Has CPSL in the past experienced a hsgh turnover rate in the upper and

middle management of its operating nuclear facilities?

A. Robinson has been in operation since 1970 and has been relatively

stable. Brunswick had units starting up in 1975 and 1976, and had a

higher turnover than might be expected. In the past year both facilities

have been relatively stable.

g. What is middle and upper management at the facilities?

A. For Brunswick refer to the organization chart shown as Appendix C. I

have considered upper management to include the Plant Manager and the two

Superintendent positions. Middle management was considered to be the six

positions with "Supervisor" in the job title.

g. What is a high turnover rate?

A. This is an arbitrary term. In this instance we considered the replacement

turnover of greater than one per year per position to be high.

g. Did the turnover of upper management at Brunswick and Robinson result

in better or worse management?

-48-

A. No organization likes to lose progressive experienced personnel. However,

if you compare the management organizations of 1975 to the present, there

is no question in my mind that the overall management control is better.

It is better because of the additional experience gained in operating the

plant, the emphasis placed upon additional training, and the refinements

made in administrative procedures. Let me note'ere that the change in

job positions since January 1976 were required by the resignation of four

staff members and the reassignment wi thin CPEL of others.

(}. Why do you say so'7

A. As we formerly indicated, in May 1975 and February 1976, the management

of NRC Region II met with CP8L management and were critical of CPSL's

past operational performance at Brunswick. A similar meeting had been

held in December 1974 in IE Headquarters for Robinson.

Shortly after these meetings several management moves at the plant and

corporate level developed. About this same time renewed interest was shown'

-49-

in staff training at Brunswick. In the fall of 1976, a short supervisory

course of BWR operation was undertaken. By March of 1977, two of the nine

plant staff in training for SROs were plant supervisors. This training

has continued to the present. The above coupled with a more refined and

developed QA/QC program has resulted in an improved management.

Q. What is its present turnover rate for upper and middle management at

Brunswick and Robinson?

A. Since January 1977 the turnover rate at both plants has been stable.

At Brunswick one superintendent was transferred (ll/77) to Robinson as

Plant Manager and a second maintenance supervisor was added when the

maintenance responsibilities were split. The vacancies created were filledfrom within the Brunswick organization. The outgoing Robinson plant manager

was transferred to other corporate responsibilities.

Q. What was the effect of the former high turnover rate on CP8L QA and on

management capability?

A. This is a complex question. Any loss of experience during a program

expansion is always felt. An IE inspection conducted in January 1977 con-.

firmed that personnel met the required qualifications. In the long term,

however, management moves accompanied by the recognition of increased

training requirements have resulted in a more informed staff.

-50-

What caused this former high turnover rate'?

A. We don't know. We have heard speculation of long hours, low pay scale,

and location.

Q. Are those causes there now?

A. Our inspectors observe that plant management personnel often work more

than eight-hour days and on some weekends. We haven't noted a current

abnormal problem. Noroever, management stability now exists.

Q. In tne 19/6-1977 period did the people in the middle and upper management

positions at the CPEL operating plants meet the requirements for those

posi tions?

A. Yes, they met the requirements defined in American National Standard

Institute code H18.1 and the facility Technical Specifications.

Q. Do they now?

A. Yes.

Q. Besides requirements for those positions, are there also "desirable" or

"recommended" qualifications for these positions'

-51-

A. Yes, the current Brunswick Technical Specifications lists eight job

positions where a Senior Reactor Operator License is desirable and one

position where a Reactor Operator License is desirable. The Robinson

Technical Specifications do not. include such a category.

Q. What were they'?

A. The above nine positions are identified in the Brunswick organization

chart shown as Appendix C.

Q. How do you interpret "desirable" or "recommended" in that context?

A. As a recommendation but not as a requirement..

Q. Did upper and middle management people of CP8L at its operating plants

have these recommended or desirable qualifications?

A. An IE inspection conducted in January 1977 confirmed that only one of

nine supervisory positions identified as "SRO License Desirable" had an SRO

License for Brunswick.

Q. Do they now'?

P

A. Of the eight positsons currently identified as SRO "License Desirable,"

one currently holds an SRO license.

8

-52-

g. Is CPSL taking any steps to have its people meet these "desirable"

qual ificati ons?

A. In addition to the licensed SRO, one supervisor has completed the in-plant

training equivalent for an SRO license and three others are currently taking

this training. This is the same training provided for those desiring an

SRO license but not taking the NRC examination. It is not planned to have

these supervisors take the NRC SRO License examination.

Do you believe that it affected CP&L's operation of its licensed facilities

that its management people did not have these "desirable" qualifications,

and if so —how and why'?

A. There may have been a slight decrease in efficiency of facility operation

based on management decisions. During this period management must lean

more heavily on the licensed operating staff. We don't believe plant safety

was affected.

(}. Do you believe the extent to which CP8L management people have this train-

ing or these qualifications today affects CP8L's operations, and if so —how

and why?

-63-

A. Any increase in staff training increases the versatility of management.

The staff and management have another one or two years of experience and

therefore, decisions will reflect this experience. Operation is improved

as the record here indicates.

g. Why would a Senior Reactor Operator's license or Reactor Operator's

license be desirable for upper or middle management?

A. The theory is that management with a licensed operator's background

has knowledge of system operation and the requirements of nuclear operation.

Overall, we believe in this theory. However, there is equivalent training

and experience which can compensate for SRO qualifications.

Is CP&L presently taking any steps that would lead to a greater per-

centage of their upper and middle management having SRO's or RO's when

Shearon Harris is started up?

A. We are not aware of CP&L's plans for Shearon Harris but currently there

are 14 SRO's and 12 RO's at Robinson and 27 SRO's and 13 RO's at Brunswick.

This is indicative that CP&L is aware of their expanding licensed require-

ments of multiplant operation. CP&L has in operation a PWR simulator at

the Harris facility and Robinson personnel are actively taking training.

N

g. When the Brunswick units were started up—did CPSL managerial employees work

"extended work weeks"?

A. Our inspector became aware of extended work weeks .during the preoperational

testing of Unit 2 and the preoperational testing and startup of Unit l.

l}. What do you mean by "extended work weeks?

A. This phrase has been arbitrarily used to describe regularly occurring

work weeks of greater than 50 hours or six days.

g. When and over how long did these extended work weeks take place?

A. We have been informed by our inspector that these conditions existed'I

from mid 1974 to late 1976.

g. How long for any individual employee'

A. For some management personnel approximately the same period of time.

g. What caused this general condition of extended work weeks'?

A. CP&L did not fully recognize the personnel demands of a startup program. It is

recognized that there will be periods during a startup program when extended

work weeks wi ll be required.

- 55-

Q. What could CPSL have done to prevent it?

A. Additional staff would have helped.

Q. Has CPSL recognized this as a problem?

A. Yes, in our opinion. Based on our awareness of the reorganization of line

responsibility in three instances and the affect on the plant staff of retraining

requirements, we would say this matter is continually before them.

Q. Have extended work weeks generally gone away?

A. By our observations, apparently so on a routine basis.

Q. Why?

A. Two-fold: first, the demand of the startup program has been terminated

and second, additional staff has been added.

Q. Did this condition ever exist at Robinson?

A. We are not aware of this condition existing at Robinson.

Q. Is CPSL now properly staffed at its licensed facilities?

A. Yes. We consider Brunswick and Robinson to be properly staffed.

-56-

g. Would you expect CPRL to encounter the same problem of "extended work

weeks" for uppe'r and middle management officials in the start-up of the

Shearon Harris units?

A. Yes, but only to a limited degree. Based on the Brunswick experience

we would expect CPSL management to be more fully aware of the requirements of

a start-up program and would factor in overtime vs experience of personnel.

g. Nr. Dance, at page 14 of your former testimony following Tr. 2076, itstates that the HPCI was inoperable 18 times in 1977. Is that so?

A. No. I would like to correct an error on page 14 of the original testimony.

The HPCI was inoperable 18 times in 1975 and 5 times in 1977 for Unit 2.

Unit 1 was inoperable 8 times in 1977.

g. Gentlemen, what is the HPCI and what is its function?

A. It is the High Pressure Coolant Injection System, and it is that portion

of the emergency core cooling system provided ta cope with small breaks in

the reactor coolant system when the reactor is at pressure. It is dependent

upon steam from the reactor to drive a turbine.

g. Why was it inoperable so many times?

A. Primarily because of a circuit designed to isolate the HPCI in the event

of steam leaks. false indications of a steam leak was provided by a high

differential temperature between the HPCI room inlet and outlet ventilation.

This condition was most prevalent in cold weather and would cause a spurious

isolation of the HPCI.

g. Was this condition ever remedied —if so how and when?

A. Changes to this circuit were approved by NRR on April 28, 1977, and the

circuit was modified by July 4, 1977, after being brought to the attention

of CP8L by an NRC inspector during an inspection of June 6-10, 1977.

g. What could CPRL have done to prevent this condition prior to that time?

A. A more vigorous pursuit of a technical specification amendment change

and modifying the circuit was appropriate.

g. Hr. Dance, on page 14 of your former testimony you report the RCIC was

inoperable 16 times in 1975, 13 times in 1976, and 4 times in 1977.

A. Yes.

g. Gentlemen, what is the RCIC and what is its function?

- 58-

A. The Reactor Core Isolation Cooling System, and it removes decay heat from

the reactor and provides makeup water to the core in the event of reactor

isolation.

g. Why was it inoperable so many times?

A. Primarily from the same type of delta temperature isolation circuit as

the HPCI, and also from overspeed trip problems.

g. Was tnis condition ever remedied, and if so —how and when?

A. Modifications to the electro-hvdraulic governor were made during the

spring 1976 outage. Improvement in switch setting and taking advantage of

permissible allowances had corrected the bulk of this problem by mid-1977.

g. What could CPEL have done to correct this condition prior to that time?

A. CP8L could have recognized the problem and evaluated it earlier.

g. When did CPSL first uncover ih'e condition'?

A. During July of 1975 in the review of the startup program.

-59-

Q. When was it first reported?

A. In reportable occurrence No. 75-125 dated December 3..1975 and No.75-106

dated October 31, 1975 for turbine overspeed.

Q. When did CP8L start correcting the condition?

A. In October 1975, following the numerous isolations occurring from the

delta temperature isolations and from the overspeed trips during the start-

up program, the NRC inspector pursued increased testing of the RCIC untilreliable performance was achieved. It should also be noted that during this

period, redundant. equipment was successfully tested as required by the

facility technical specifications.

Q. Are there still failures of this system?

A. By 1977 the RCIC system failures had become random type malfunctions.

There have been random RCIC system failures reported this year - three

on Unit 1 and three on Unit 2.

2-13-78 - overspeed (Unit 1)

4-21-78 - auxiliary oil pump failure (Unit 1)

5-27-78 - CST section valve failure to open (Unit 1)

3-06-78 - steam inlet valve failure to open (Unit 2)

3-28-78 - injection valve failure to open (Unit 2)

9-04-78 — steam leak isolation - faulty relay (Unit 2)

-60-

q. What was the trend of continuing similar,plant malfunctions at Brunswick

in the period 1975-1977?

A. They have been decreasing.

What is the trend since September 1977?

A. The trend is stable with random failures.

g. How many times has the HPCI been inoperable since September 1977?

A. There have been two HPCI system failures reported on Unit 1 and four on

Unit 2 since September 1977. The last reported failure was on June 2, 1978.

Have there been any fai lures of relief valves or diesel generators

since September 1977?

A. There has been one relief valve, failure on Unit 1 since September .

1977. No failures have occurred on Unit 2;

There have been two diesel generator failures on Unit 1 and one failure

on Unit 2 since September 1977. The last failure was on February 13, 1978.

-61-

Q. Do these repetitive malfunctions show anything as to CPSL's QA/QC

program or its managerial ability or responsibility'

A. Yes. It indicated that corrective action taken did not always correct

the root cause of the malfunction. It also suggests that full management

attention may not have been focused on the problem. However, management

demonstrated its ability and responsibility when it took steps to improve

these conditions. The trend in repetitive occurrences of HPCI, RCIC, and

relief valve malfunctions has decreased. Therefore,.we believe that manage-

ment attention has developed a continually improving staff.

Oid a problem regarding the need to keep a bulkhead door closed to prevent

common flooding of pumps ever come to your attention?

A. Yes. Bulkhead doors are on the two entry ways to the HPCI room and serve

to separate the two redundant RHR system rooms. Our interest is in maintaining

the doors closed to prevent an inadvertent flooding of both rooms and in

providing a barrier for the HPCI Fire Protection System.

-62-

g. Is this an NRC requirement?

A. It is not a technical specification requirement. However, water-

tight compartments housing the ECCS redundant equipment is discussed in the

FSAR as a means to prevent conmon flooding. This commitment in the FSAR

constitutes a commitment to maintain compartment integrity. IE Headquarters

felt it was not necessary to incor'porate this requirement into the technical

specifications as Brunswick agreed to control the doors administratively.

g. Has CPSL taken action to remedy this condition'?

A. Yes. Signs were installed in December 1976 to inform workers to keep

the doors closed. Additionally, each shift was required to confirm the doors were

c'losed. Alarm indications are being installed. In February 1977 plant

personnel were instructed in the requirement to maintain these doors

closed.

Did any instance arise when CPSL put the wrong type of oil in diesel

generators?

A. Yes, on October 2, 1975, waste diesel fuel oil was inadvertently added to

the lube oil reservoirs of No. 2 and No. 1 diesels. CP8L discovered the

error during the addition of fuel oil to No. 2 Diesel Generator. In event of

emergency. the diesel generators provide electrical power for safeguard

equipment.

- 63-

Q. What action did CP&L take to correct this condition?

A. The fuel oil was replaced immediately in diesel generator No. 2. However,

CP&L did not check the oil on diesel generator Nos. 1, 3 and 4 until

questioned by the inspector. No. 1 diesel was found to contain slightly

degraded oil which was replaced. The oil in diesel generators Nos. 3 and 4

was found to be proper.

Q. How do these two items involving the bulkhead'oors and the diesel

generator oil, reflect on CP&L's QA/QC program and its managerial capability

or responsibility?

A. They are examples of how a more involved management might improve

conditions. Personnel errors may be minimized by more actively involved manage-

ment together with trained personnel and a program of administrative control.

Q. Mr. Dance, at page 13 of your formet testimony it states: "Many plant

malfunctions have occurred more than once indicating that corrective actions

and corporate resources may not have been as timely, thorough, or effective

as it should have been." When did these things happen, and what are you

referring to?

-64-

A. During the period January 1, 1975, through August 31, 1977. Typically,

I was referring to the High Pressure Coolant Injection System, Reactor Core

Isolation Cooling System, and water tight doors in the reactor building basement.

When were things not timely?

A. Two examples are: (1) correction of Reactor Core Isolation Cooling System

Turbine overspeed trip problem identified during the Unit 2 startup test program

in July 1975,were not actively pursuea until October 1976. (2) Continued

inoperability of the High Pressure Coolant Injection system indicated that

a more thorough and timely investigation should have been pursued.

g. When were they not thorough?

A. The above are two examples of when problems were not thoroughly reviewed

initially. Once attention has been focused on an issue, the review has-

generally been thorough.

g. When were they not effective?

A. An instance of this was the administrative controls of the plant to keep

the water-tight doors of the HPCI room closed.

- 65-

g. What resources should have been applied in specific instances, that were

not?

A. In the case of the HPCI and RCIC the only additional resources needed was

to pursue the matter more timely. For the RCIC there was a delay from July

when it was identified until October for the correction. For the HPCI there

was a two-month delay after approval of circuit by NRR until it was incorporated.

g. How does CPSL now handle the concerns of the NRC on health and safety

---matters in operation both at the corporate and plant levels.

A. At Robinson, identified NRC concerns are incorporated into a master

list which is maintained and distributed to plant management by the Plant

guality Assurance Supervisor. This list includes NRC noncompliances, unresolved

items, open items and appropriate comnents and comnitments. In addition, the

Master List contains Corporate guality Assurance Audit findings and appropriate

coranents. Items on the Plant Master List are flagged if overdue to the plant

manager. Selected items from the list are reviewed in the monthly PNSC meeting.t

A similar tracking system is employed at Brunswick.

g. Are they timely handled?

A. Items of concern are processed in most instances in a timely manner con-

sistent with the level of safety.

-66-

g. Who handles these concerns?

A. Plant management as well as corporate management.

(}. What is their ability?

A. As we stated, plant management meets the requirements of the American

National Standard'nstitute code ANSI N18.1. Plant and Corporate management

ability is adequate to handle NRC concerns.

g. Do they audit that action to see that it was taken and was correct?

A. Yes, as we stated, selected corrective actions are audited by either the

.Plant gA Group, the Operational gA Section or Corporate gA Section.

g. Can you detail instances where CP&L has taken action to meet safety

concerns of NRC, even though not required by NRC regulation?

-67-

A. (a) During a current Robinson inspection the inspector expressed concern

that, no temporary instructions existed to place a safety related

pump (that had been declared inoperable) in service under potential

or emergency conditions. This pump was not required to be operable

by the technical specifications. During a followup inspection, the

inspector found that a temporary administrative instruction has been

implemented addressing the operation of the above pump when and if needed.

(b) Robinson currently is performing a complete review of technical

specifications to identify nuclear and interpretive areas with

intent of amending technical specifications to correct deficiencies.

The weaknesses of several areas of the technical specifications

have been discussed on several inspections.

(c) Both plants have established a comprehensive process for review of

IE circulars to insure that possible generic applicability to their

facility is identified and corrected.

,The above examples are typical of the responsiveness of Robinson management

to NRC concerns. In general, the current principal inspectors feel that

CP&I is responsive to NRC safety concerns regardless of the regulatory basis.

-68-

Q. Do you believe CP&L applies sufficient resources to deal with the health

and safety concerns of the NRC?

A. Yes, when there is a clear health and safety concern. In marginal

cases, CP&L has been slow in applying resources. However, there has been

continued improvement in plant management training, reduced repetitious

occurrences, and trends in LER's and noncompliances.

Q. Does CP&L presently have enough management personnel and QA/QC personnel

to run Brunswick, Robinson and Shearon Harris?

A. In our view, yes, but let us explain. Though not a requirement, during

October 1978, a third SRO (a supervisor) on the operating shifts at Brunswick

has been staffed by CP&L. We believe this to be a prudent move for a two-unit

facility such as Brunswick. As for Shearon Harris, additional personnel willbe required in time. Otherwise CP&L has sufficient management personnel to

operate these units.

Q. Do you have any remaining concerns on the ability and responsibility

of CP&L to manage and operate Shearon Harris after it is built?

A. No.

-69-

Q. What is the basis of your answer?

A. CPSL has demonstrated their ability to manage and operate nuclear plants.

Overall trends indicate continued improvement.

Q. .Is CPEL presently properly using its resources in seeing that its nuclear

facilities are operated safely?

Q. Yes.

Q. Oo you have any cause to presently believe that CPSL will not operate Shearon

Harris consistent with the public health and safety once it is constructed?

A. No.

Q. Gentlemen, will you please sum up your conclusions on CPSL's nuclear

operations?

A. It can be seen that the management of the Robinson and Brunswick facilities

has evolved over the years. Many personnel presently involved in the planning

stages for the Harris project and operation of Robinson and Brunswick have

been involved in nuclear power plant operations from the earliest days. One

of the first power demonstration reactors, the CVTR, was operated for the AEC

-70-

I'y

the Carolina-Virginia Nuclear Power Associates (CVNPA), a cooperative

group of which CPSL was a member. This fact demonstrates that CPSL was

one of the earliest utilities to commit to nuclear power.

The management organization charged with construction and operation of the

Robinson facility came in part from the CVNPA/CVTR staff. Robinson was

essentially constructed prior to the advent of 10 CFR 50 Appendix B. However,

CPSL was fully aware of the limitations and capabilities of their existing

staff to construct, test and startup a nuclear plant. This was one of the

reasons Westinghouse was given a turnkey contract for the project. Unquestion-

ably, at that time Westinghouse had the experience and technical capabilities

few others had.

Later when the Brunswick project was conceived, CPSL elected to take on a

greater share of the responsibility for construction and full responsibility

for testing and startup. This was made possible by a major expansion in the

technical staff and the associated training of the staff. To accomplish the

testing, startup and operation of the first Brunswick Unit, CPSL leaned heavily

on their experienced personnel from the Robinson Plant and contractor's engineers.

Our inspectors expressed concern regarding the adequacy of staffing of both Robinson

and Brunswick. This was not unusual in that most utilities rely heavily on

experienced personnel from an operating plant to start up and operate a new

plant. Although Robinson and Brunswick utilize different basic technologies

-71-

(PWR versus BWR), the net result is that during Brunswick testing, startup

and operation, CPSL enjoyed a distinct advantage compared to similar experience

at Robinson.

The Harris project represents a major increase in CP&L's commitment to

nuclear power. Obviously this implies an equal increase in their commitment

to full compliance with NRC requirements and the inherent safe operation of

all their nuclear facilities. CPEL also plans even greater direct involvement

in this project to the extent of managing the construction and the overall

gA program for construction. CP8L commitment to safe operations is further

evidenced in provisions for training and qualifying operating personnel at

the training center located on the Harris site.

The operations portion of this testimony contains considerable evidence of

weaknesses in the various management controls involved in areas where we

have inspected. Only adverse findings are customarily highlighted in the

IE inspection reports from which this testimony was derived. This is due

to the fact that emphasis is placed on that which is of concern to the

Commission.

In the sections relating to radiological and security experience, IE

concerns are identified. We have indeed had continuing concern in these and

other areas. Reinspections and enforcement meetings with licensee management

have thoroughly stressed these concerns over and above the routine notice of

-72-

violations. Major organizational changes have been made and training programs

have been intensified. In many instances these were in recognition of IE

concerns brought to the attention of top licensee management. We believe

overall, that CP8L management has been responsive to concerns registered

by our inspectors. As stated in earlier testimony, CPSL management is toughs

They have always stood firmly behind their established positions and strongly

defended their actions. It must be made clear, however, that on substantive

issues their debate was for the purpose of developing a clear understanding

of the problems as IE sees them. This is certainly not a bad policy. Once

a decision was made and final IE positions were stated, CP8L has cooperated

fully in final resolution.

i+ "I0u

+eye+

uWTED STATEr

NUCLEAR REGULATORY COMIINSSlON APPENDIX AREGION ll

i0l MARIETTASTREET. N.WATI.ANTA,GEORGIA 30303

SSINS 400, 401. 402. 4031F

fIlENORANQUIrl FOR: Fu l Facility and Naterials Safety Bl anCh Staff Reg'oi, IISafeguards Branch Staff, REgion IIReactor Operations and NucLear Suppor. Branch Staff Regio. II

FROM: F. J. Long, Chief, Reactor Operations and Nu Leai SupportBranch, Region II

SUBJ ECT INSPECTION FINDINGS AT SHEARON HARRIS NUCLEAR FLAN RNO

OTHER COL FACILITIES

As you may be a~a e, the Commission has renanded rhe Harl. is proceedin"=back to the Hear'.ng Board on the basis that the Board may have beenmisl.ed by the tes.imony of staff witnesses.

Region II is presently preparing test imony for the remanded hearin=. Itis very important that the testimony presented to the Board accurateL>reflects the findings of our inspection and the professional judgenentsOf thOSe Vha haVe perfOrmed inSpeCtiOnS Of CPLL faCilitieS. -The teStimO".vill include discussions of our inspection findings not only at Harris,but also at Brunswick and Robinson. Qe have also been directe" toprovide testimony relating to the abilitv of CPSL management to mana"»a'.L those activities associated with tie construction and future ooeiat.o-of Harris.

Each of you is requested to provide to your supervisor in ~-iting .iOctober 16 1978 the answers to the followina:

2.

3.

Have you ever performed an ins Ection or investiaatioiCPLL co-porate offices, Robjnsoi Brunswick~ or Harris'g. BSw/r. ~ ~~i ~~~r'z.s.+.If the ansver to 1 is yes did tgIe inSPectiO legit ade"uate'.iand accurately I'leet your ir sce tion (or investigation)finding ~ ~~ ~ WaM~» '~l Ii ~~~ 4 a

If the answer is no, please oesclibe.1If the answer to 1 is yes, dn you have ani elide.-ce i clod'n-

your professional judgement, that would ref Le:t favora: '..adversely on the capat iliti of CPKL manaI3erient to construct oi~in the future~ opel ate Harris"

If the answer is yes, please describe.

~~ ~~x»c 4'»

j~ 78

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5.

l C-Please discuss any matters relating to the CPCL managementor facilities not encompassed by the above questions thatmight be beneficial to the Board in arriving at theirdeci s'I oil,

Have you formed an opinion concerning CPLL s capabilityto construct and operate Harris? If so what is youropinion".

I want to stress the fact that you may appear before the Board totestify if you so desire. If you should so choose~ pLease adviseyour supervisor promptLy.

This special request for information should not be construed as anattempt to obtain information either in support of, or in oppositionto Licensing the faciLity but rather to present complete and factualtestimony to the Board ir. an area which the Board has expressed conce n.You may answer the qu stions in the space below. Please sign yourresponses'.

J. LongChief~ Reactor Operations

and Nuclear Support Brancl

1

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UNITEO sTATES

NUCLFAR REGULATORY COMMISSIONREGION II

iOI IjjIARIETTASTREET N.WATLANTA GEORGIA XQ03

r

SSINS 400, 401, 402, 403/F

lIEHORANDUI1 FOR: Fuel FaCility an" Hate. ialS Sa'ety BranCh Staff, Regip.. IISafeguarCS BranCh Sta f, RegiOn IIRea:tor Operations and Nuclear Suppor: Branch Sta'' Region II

F ROI': F. J. Long, Chief, Rea:tor Operations and Nu.lear Su."."„".tBranch, Region II

SVBJ ECT: INSPECTION FINDINGS AT SHEARON HARRIS NUCLEAR PLAN: A'iDOTHER CPgL FACILITIES

As you IIIay be a«a e, the Co~-."'ss'.On has renande":he Harris procee"'.n":back to the Hear in" Boar" on the cas'3 that the Board Iray have beIIIisled by <rle ,es.inony ". staf. s;-.tnesses.

Region II is presently preparing testimony ~or the renanded hearir „-. Itis very important that the teS:inOny Presented to the Board accuratel>reflects the fin"ings of our inspectio~ and the professional judgenentsOf tt OSe idho have Per ~ Orj d inSPeCtiOnS Of CPCL faeil iticS. The teSti

include discussio~s of G4~ inspection findings not or ly at Harrisjbu. also at Brunswick an" Robinson. Qe have also been directe" t"prov'.Oe teS. irO..y rel a.'..g tO the ab'l '. y 0: CPgL nanagenent tO'na a„!a'.'. thOSe a: t.vitieS aSSOCiated».th t"e:OnSTIu-tiO". and iutuje O"e at.O"

Harris. l

Eath Of yOu iS regueSted tO pIOV'Oe .. vO4 Su e ViSOr in I. ',in"October 16, 19?S, t he answer s to t he fol l ov ing '.

2.

~ i S us 4Have ypu ever perfOrne" an isa "e:t inveS.iga:it~Cp)L corporate offices Rc :nso-, r4nsiick or Harris"

(

the at Sudor t 1 iS VeS I O the inSC et t i O" repOrt a" e=4a . e ~ ~

d's", fjtPeS,'-32 j2S 53j~-/l'Si-3P~2O/~385/7r i.-6u -~ rl»- 7u SO- m i/ q l-a.

If the an'dej'S nO please de": r'lee ~

~ ~If the answer to 1 is yes dr vou have a s evide 'r I ~ 4

yau r < as oirslaajaudaar rraas, t aorousd roflrr'. r ~ s s: '. ~

If the answer i: yes, pl ea~r desc~ ihe.

4

5.

Please discuss any laat ters relating to tne erik v"~~ .....or facilities not encompassed by the above questions thatmight 'be benefice~ to the Board in arriyi~g at, their~A

'ave

you formed an o inion co~rning CP L's capabilityto construct and operate Harris. If so, vhat is youropinion?

I vent to stress the fact that you may appear before the Board totestify if you so desire. If you should so choose, please adviseyour supervisor promptly.

This special request for information should not be construed as antt apt to obtain information either in support of~ or in oppositiona e

to Licensing the facility but rather to present complete and ac. L

testimony to the Boar" ir. an area which the Board has expreSsed corce -.You may ansver the qu s.ions in the space below. PLease sign yourresponses.

~ ~~

~lg ~ y~ W% 0

F. J. LongChief Reactor Operations

and Nuclear Suppot t Branch

~ ~

8~~ 8C'ufts~si 0

soe4 ~

UNITEp STATES

afIUCLEAH REGULATORY COMMISSION"hEGtON II

%03 A8AAIETTASThEET N.WATLANTA.GEOAGIA 30303

SSINS 400, 401, 402 i 403/F

%KORANDUH FOR: Fuel FaCility and RaterialS Sa ety BrarCh Staff/ Re I.e Saf eguards Biancl Sta'f, Re-".".o . II

Reactor Operations and Nuclear Supoor: Branc~ Sta", Re"-'0 IIFROIf!: F. J. Long, Chief, Reactoi Opt~at ionc and Nu.'.ea Suc.-" t

B~anch, Region IISUBJECT: INSPECTION FINDINGS AT SHEARON HARRIS NUCLEA0 PLAN AN".

OTHER CPCL FACILITIES

Is you ofay be aia t, the Comf.'.ssion has renande" t9ie Harris p o:ee= -":back to the Hear'.ng Board on the bas's tha: the Board tfay have b!.-misleC by the test ii'one of staff vitnesses.

Region II is presently preparing testimony fo the renanded hea"'.-=.is very iIspol tan: that the testimony pl ese~ted to the Board accuia:e. ~

re<leCtS the findingS Of Our inSpeCtiOn and the prOfeSSiOnal judge e .Sof those who have perforf9fed inspections of CPCL facilities. The tes.'-:-.t'l! include discussions of our inspection findings not or ly a. Hao is,

Bruns8cick and Rob.nso .. Ne have also been diiec.edP ode testimony re!at'ng to the ab'i~tv of CPCL ~nagefffent tC na aa'.. TIIOSe a:tiVitieS aSSOCiated 8sith t<t COnStiuttinr an" f~t re OCt-a..."-o Haiti s

Sac ~ o'ou is requested to provide tc you suet visor 9 a . "- .- ~

0CtObe 16, 1978, the anSverS tO the fpllO ing:

Have you ever ptr fOillltd an 19sseC tt, inf O+ invesos 1 Qao >tee'C Q g/coCL co»Co»etc offices, ooc , 8»r sef:s» o» oe 's gg ~

2 ~ If the ans8ctr to 1 is its, d'd ~ ~t inst cetic" revert adt=~a t. ~

~ nC ~ scot»eeir ref te-t vorr ~ \c»::io» (9 fores.'9 ~:'0». y'~nds nor

the answer is noi ol tarot dt ~ . + 8 tt ~

If the anSvtr tO 0 IS ye'r 8O hast a~ tvidt t ~ ~ ~ 4 'yOui PrOftSSiOnal judatit~t, tha'puld it~le;t <ain a:. ~ ~ PP~OveiSt ly On the Capat i lit. nf CPLL ~anaat~i"t tO CO9 Sti~tt

t ht fut urer opt r at t Hair i s"

If the ansvti is yes, bleaunt't".~it't.

4. PLease discuss any chatters reLating to the CPCL management tor facilities not encoapassed by the above questions thatnight be beneficial 'to the Board in arriving at theirdec i sl on ~

yi ~~Ed, 4-tS. Have you folded an opinion concerning CP!l's capabiLity

to construct and operate Harris? If so, ~hat is your ~~op inion?

I sant to stress the fact that you oay aooear before the Board t ~ tctdvv.ltestify ii you so desire. It you should so choose, oiease advise ~your supervisor proeptly. ]c

AC+This Special request for inforaation should not be construed as an ~atteapt to obtain information either in support of or in oppositio"to Licens~ng the facility but rather to present complete and fac. altestiaony to the Boat d in an area which the Board has expressed conceYou aay answer the questions in the space below'. PLease sign yourresponses ~

~ ~ v MO

F. J ~ l.ongChief~ reactor Operations

and Nuclear Support Bra :".

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QNITEP STATES

NUCLEAR REGULATORY COMMISSIONREGION II

TOI MARIETTASTREET N WATLANTA GEORGIA 30303

SSINS 400, 4,01, 402, 403/F

IIEIIIORANDUN FOR: Fuel FaCility and Nate-iaiS Sa'e'. ~ Bt arCh Staff,Re"'afeouardSBranCR Sta'f, Rec Or II

Reactor Operations and Nuclea~ Supror. Branc'ta",FROID: F. J. LOng, Chief, ReaCtOr Operat iOnS and Nu '.ea S4CC".".

Branch, Reoion IISUBJECT: INSPECTION FINDINGS AT SHEARON HARRIS NUCLEAII PLAN

OTHER CPCL FACILITIES

As you ma) e 1e ~~ Co~ . Sc:or hat re~.ae.das" the Harris pe'o ee ~

back tO the Hear ng BOar" Or the baS'S tha: the BOard ma. have bee-misled "y the testi~o~i of staff I itnesses.

eReg''Or Il iS preSentl> preOaring teSt impni 'O the remande" hearin".is very important that the testimony preser ted to the Board accul ate. ~

reflects the findings of our inSpeCtiOn and the profeSSiOnal judgene .sOf thOSe vhO have perfOrmed inSpe:tiOnS Of CPLL faCilitieS. The teSti-=-

inClude discussionS Of Our InSpeetion findings no't Onlv at Ha salSO a: BrunSI isa and RO"''nSO".. We have a lSO bee< direCte" tC

P = ~ 'de tes.fmo"y rela:'.ng to the ab'litv o'OLL managemer.t t ma a=ef e .r Ot aa ~ a ~a: .. hOSe a. 11v'. '. IeS aSSO: i at ed i'. th tI e:OnSt rust iOr an 4 ~ t e Qp.

O~ Ifa

rnt 4

Oc .Ope~

2.

yO~ iS reaueSted tO prOVide tC iO '4pe~iiSC~ 'n ~- .'"= ". ~

16, 197S, the anSIferS tO the fOl lO«.nO:

JOHave you ever oe, toroe an t~n"r:'r inves..oa: c .'y/

or Harris"CPCL coroorate oti tees R~t''av! !. or tta ~ s

If the anSver .tO 1 iS yeS, dad the inSneetiO revert ade= a e.,~ n accurate! rl't!e't you st'I:: to (o tnves'. 'oa'.:o

=:" y&SIf t>e a<sr»s nc pleasf de': r'te.

If t he answee'o 1 I s ye' dt vo~ have a s +o Ide eu 'I: ~ 4ypur prOfeSSIOnal )udOemen'., that VOuld ref lent, fasp at 's~ dve<sel y on the capat i l it i of CPLl manaot ~en', to cons'.r4,',

the future, Operate Harris"

It tne an' t" yes, o!ease oesc tie. yard

4. Please discuss any matte-s relating to the CPRL manage e..Or faCilitieS nOt enCOmoaSSed by the abOve QuestiOns t'a:might be benef'cial to the Boar" in arriving a; the~rde:ision.

Have you formed an opi '. P cor:e. r ino CPLL ':- :aoabi l it yto construct and ope~ate Ha'~i. ? I'c, rhat ~ s yourOD inlo<

I vant tO StreSS the fa:ttestify if you so desire.youl SuDe. WiSor Prom

that yOu may appear be'Or e the BOar"If vOu ShOuld SO ChOOSe, DleaSe adv'Se

This "special reques; forattempt to obtair. informato licensing the fat flit>testimony tc the Boa " irYou may a" s e tr e ues.iresponses.

information should not be const rued ascion eithe~ in supDOrt Ofp Or in ODDC'S''

but rather to present comple.e and fa.a" area i.~ic" the Boa~d has ea ~esse"

5 i ~ 'ie soa.e be'.Oa ~ Pleaso s.. r

~ op

= .a ~

~

'.

J. LongChief, Reat tor Oper'a. iO .S

and N c l ea Sup."" ~ t Br a-:

ky~~ ~i4

gcwl4 ~

~~ S~~

~~rwrt,w~~ ~Md'.FkacJfdt'M~ ~PS ~ .2 ~

/n ~j; M>g /X>H~~AP /gA~~: AkcayaZ/ eVW~g jdp / >~~~

«3"

4. Please discuss, any matters relating to the CPEL manage e™'.

or facilities not encompassed by the above ouestio~s t a:might be bene<iCial tO the BOard in arriving at the~rdec i si one

5. Have you folded an opinion concerr in". CPLL's capabilitytO COnStrutt and Operate HarriS'? Jf SO, ~hat iS yOuropinion

I ~ant to stress the fact that you may appear before the Board:testify if you so desire. If you should so choose, please adviseyour supervisor promptly.

This special request for information should not be construed as a"atteapt to obtain information either in support of, or in oppositio.to licensing the facility but rather to present complete and fac. altestimony tc the Board in an area which the Snare has expressed co.:e-..You may answe~ the "ues:io"s in the spa e below'. Please sio~ yoresponses

F. J ~ LongChief, Reactor Operations

and Nuclear Support Bra":.

~g% IQ00~4 0

no: r

C'ocket

No. 50-324

LINITEO STATES

NUCLEAR REGULATORY COMMISS)ON

aEGIOM lIJSO RSACHTRKC STREET, 11. W, SUITE 010

ATLANTA,CKORCIA 00000

'ebruary 14," 1977

'E2SRANDUM

FOR: H. C. Dance, Chief, Reactor Pro5ects Section Ho. 1,Reactor Operate.oas aad Nuclear Support Branch

FROM: R. H. chessman, Reactor Inspector, Reactor Pro5ectsSection No. 1, Reactor Operations and NuclearSupport Branch

SUBJECT: INSPECTOR EVALUATION OF BRUNSGCR PLANT SUPERVISORACTIVITIES

During the veek of January 17-21, 1977, I participated in aa inspectionof .the Brunsvick Plaat supervisory activities. This inspection, docu-mented ia Details III of Inspection Report No. 50-324/77-3, ms toprovide aa appraisal of senior site staff (10 positions) qualificationsaad iavoLvement in plant activities. This evaluation supplementscomments noted ia the Inspection Report and includes caaueats verballymade directly to corporate managsment on January 21, 1977.

1. Su erviso Involvement In-Plant

h survey vas made of the BamIvick guardhouse computer records forthe period of January 3-16, 1977, to make an estimate of the timespent in the plant (vice in the administration building or else-vhere) for the 10 senior supervisory persoanel. The guardhousecceputer records every use of individual "key cards" vhen aaindividual eaters or leaves the restricted area of the plant; hencean estimate 'of aa indivtduaLIc "in-plant togae" may be made for theperiod of time under coasideratioa.

Of the four aost senior supervisory personnel (Plant Nanager ~

Operatioas-Maintenance Superintendent, Tcchnica1-hdmiaistrativeSuperintendent, aad Qh Supervisor) too had not bcea in the plantduring this tvo-veek period. Of the other senior supervisors, taohad been in the pLant once and one had been in the plant t0riccduring this period. Hone of these supervisors vas avay fnm thefacility (vacation, etc.) for +or'e than oae day during, this period.

CONT'ICT: k H. Vessmaa221-6068

H. C. Dance 4c

The licensee holds daily planning meetings to discuss plant activitiesbut the tvo individuals vho hsd not.been in the plant at all duringthis period did not attend all of these meetiags nor do they revievoperator logs, according to the licensee.

2. Trai and Lification

h11 ths supervisory personnel meet Technical Specificatioa and kHSI818.1 - 1971 qualification requirements. However, several statisticsvere determined from training and personnel records revieved duringthis inspsc tion:

a. Host trainiag records did not reflect recent training received.

b. The site training coordinator has ao formal WR training (buthas nuclear navy experience).

c. Only tvo f the 10 senior supervisors have BWR training, otherthaa a 3 our supervisor's shozt course given M November-Deceaaber 1976.

d. Only four of the 10 senior supervisors have nuclear navy orformal {college) nuclear-re1ated education.

Pour of the 10 senior supervisors have no record of receiviagQh. training, other than a short introduction given ia the 36-hour supervisor' course.

f. Three of the four most seaior supervisors ca-site have onlybeen oa-sit» about seven months. Due to the scheduling ofdrills, they have participated in only one f.'xe drill aad inno emergency plan drills.

g. Mna of the senior supervisory positions are identified as"SRD License desirable" in Pigurc 6.2»3 (Plant Staff Orgsnixa-tioa) of tha Technical Specifications. Only ewe of thesesupervisors has a SRO licensee aact the licensee stated thatthere vere no immediate plans for others to obtain a SROlicensee

3. Personnel Turnover

There has been considerable turnover of supervisory personnel inthe past year. Except foz the Qk, Supervisor, khabniatrativeSupervisor, aad Training Coordinator, all of the top ten supezvtsorylmanage eat positions on the site have had at least three occupants.

g,. C. Dance

The inspector discussed three outstanding surveillance reports viththe cognizant supervisors. hn effort vae made to determine thesupervisor's knoMledgc of the surveillance discrepancy and thecorrective action to be taken. It is the inspector's opinion thatthese cogni'sant supervisors vere not familiar vith thc discrepancyoi the corrective action.

5. Anal sis of Licensee Event Re orts ER's

The inspector revieved taro IZR's to detezadne the level of super-visor involvement in the activities leading to the particular eventand the supervisory analysis of that event.

a. Field Change FECP 1503A "Dryvell 8» 02 Analyzer CoolerChange to CAC System," resulting in LER 76-157.

This field change vas made to the Dryvcll I 02 Analyzer Coolerin accordance vith licensee modification procedures. Tofacilitate the modification the drainpot solenoid valves veredisconnected (not covered by thc Iodification procedure)~ hfailure to reconnect these solenoid valves resulted in aninoperative Analyzer at pover requiring the submission of aLER. The licensee's corrective action focused on: (1) insuP~reviev bodies verify adequate checkout steps are in modifi-cation packages; and (2) revising the procedure for processingaodif ica tions.

It is the inspector's opinion that the licensee failed to takeadequate corrective action in that no steps vere taken toinstruct craft personnel concerning changes to a modificationprocedure. Changes to an approved modification procedure thatare not documented and revievsd may result in this type ofequipment casualty.

b. Modification to Transformer Taps on Startup and EmergencyTransformers, resulting in LER 76-153.

This modification vas made in accordance vith licensee modi-fication procedures. Changing the transformer t'aps requiresde-enargixing the transformer output which, in turn, de-encrgiscs ths Unit 2 air compressor. The loss of air resultedin deflating the boot (vhich had a previously unkncam leak) on

H. C. Deface

the spent fuel pool gate resulting in a low spent fuel poollevel. The corrective action, as described in IZL 76-153,focused on the spent fuel pool leaking boot seal and a pro-posed fuel pool level alarm.

Xt is the inspector's opinion that the licensee failed tofully analyse the event's cause. The transformer was securedvt.thout consideration for loads served by that transformer.The modification procedure provides no direction concerningtransformer loads, and no corrective action vas taken concerninginsuring appropriate detaQ. in aodif ication procedures.

6. Zns tor Evaluation

Although Brunsvick supervisory personnel meet hHSI H18.l - 1971qualification requirements, it is the inspector's opinion thatstaff training could be increased and that a deeper imrolvement inday-to-day plant activities is merited. This opinion ms discussedvith CPSL management subsequent to the inspection- Specificallyrecommended are:

- increase level of BQR technical training- encourage more inplant time

- obtain "SRQ-level" training for a greater percentage of thesupervisory staf f

» increase supervisor attention to plant activities, Qd audits,and analysis of licensee events

- stabilise personnel turnover

7Qk. H. Seaman, Reactor InspectorReactor Projects Section Ho. 1

Reactor Operations and NuclearSupport Branch

cc: F. S. CantrallH. A. Qilber

1)~ ~ ~ 0

~g8 RKgIIci~4 0

e jl nO

go+r~

4 sk g y 4

UNITED STATES

NUCLEAR REGULATORY COMIVIISSION

REGION II101 MARIETTASTREET, N.W.ATLANTA,GEORGIA 30303

October 13, 1978

SSINS: 261/U, 324/U, 325/U400, 401, 402, 403/U

MEMORANDUM FOR: F.. J. Long, Chief, Reactor Operations and Nuclear'upport Branch, RII

THRU:

FROM:

W. B. Kenna, Chief, Safeguards Branch, RII

F. P. Gillespie, Chief, Security and Investigation Section,Safeguards Branch, RII

SUBJECT: INSPECTION FINDINGS AT CP&L FACILITIES

Discussions with the Security Section relative to your memo requesting theanswer to five questions resulted in the following:

QuestionNumber Tobin Moore Davis Besecker ~Hennesse McGufre Fuckkn

No Yes

Yes

No

Yes

Yes

No

Yes

Yes

No

No Yes

Yes

No

Yes

Yes

No

NoOpinion

NoOpinion

NoOpinion

NoOpinion

NoOpinion

NoOpinion

NoOpinion

..J Tobin

c~D.. oorei( r,'"'~ c-.K. H. Besecker

(

R. J. Hennessey.

C. Lk )avis//

I

i'. McGuire

x IM. Fuchko

e 00 >t>(,~( ~

C

~IItI'-gg »

~ 0 ~ ~ ~

~ c.I+Uh»TEO STATES

IVUC L E AR REGULATORY C OI>'IMIS S IO'EGION»

101 MARIETTASTREET N Ve

aTLah:Ta GEoRG>a 30303

SSI~S ~DO, 4".~, Ls;. 403/-

F c(

McMOR«"iD"v P F (>0 l F a c '. ', i: I a n„" Ma . (SafeouarCS BranC- StallReac:or p«era.ions an"

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04 Please discuss any ma:ters relating to the (PAL mana".»-»-t

or facili;ies not enconoassed b> the above oue-tions:;a.might be henef'.c'.a! to the Board in arriving a: the~rde

isio:i'ave

yO -~ Or+ed a." Opinipn CO.Cernin"„;PE':-:aOabil it y

to cons:- =; an" ope-ate Harri:.~ I. s;, ihat is yourop in ion'

want to stress t ie ',a:teSt i y i f yOu SO Oesi r»your super vi sor pro-...": l y

that yOu may aOOear be'ore tre BOard :I'. ~ou should so chooser olease advise

This spec'. a l reques: '.-rattempt to obtain ir.'.ormtO liCenSing the fatilitteStimOny ." the B"a-"„ iYou may ans »- !>erespo .ses.

irforr ation should nota. io". e'. ther in supporty " . rather to present

ihich the Boa.'=".s i" the s a.e bo lo-.

ns.rue asof, or ir. oooosi

ono le.» and facha s expressedPlease s'.gn yo

a~ ~ ~

..al

F. J. LongChi ef ~ Reac t.".-. Coerations

an" Nuclear Su-port Bra"t~

p

~ q ~ +~~ +~/ i~Q 4hWe m LA3 ~~Q'lQ ~ m„~,~( 4 ~ soir(eche oM

~z p~A

4o v

le NICE,c~

~4

~ ~ ~ 0 ~

gygTED STATES

NUCLEAR REGULATORY CCANllSSIONAEGION II

TOl NAIIIETTASTREETII'TILT*.GEORGIA %303

SSINS 400, 401, 402, 403/F

l%%NAND& FOR: Fuel Facility and materia(s Safety Branch Staff Re""Safequards Branch Staff~ Region IIReaCtOr OPerat iOnS and 'NuC(ear SuDDOrt .BranCI Sta", Re".-0- II

FRY!: F. J. Long,.Chief, Reactor Ooerat ions and Nu.'.ea Su-c"-.branch, Region II

SUBJ ECT: INSPECTION FIN(IINGS AT SHEARQN HARRIS NUCLEAR PLAN> AqOTHER CPCL FACILITIES

As you IIay he aia r, the COIII~-'ssion has reIIIanded .he Harris D~ocee".-.:.back to the Hearing Board on the bas~s tIIat tIIe Board ~ay have beeIIIiS(ed by the testimony of Staff vitneSses.

RegiOr II iS DreSently preparing teStiIIIOny fOr the reaanded hearin . I:is very ieportar . that the testiIIony presented to the Board accurate'. ~

fl he findings of our inspection and the professiona( judgeIIIe"tsl i i s. The testi~:".of those who have performed inspections of CPSL faci(lt e .

xi l'inC(ude diSCuSSiOnS Of Our inSpeCtiOn findingS nOt only at Har" lS p

b~t a(so at Brunswick and Robinson. Qe have also been directed t"D<C ~ ide testimony relating to the abi(lty Of CPCL aonageIIIent Zo ala~a„e

future ODe a. ~-'hOSe at.ivitieS assoCiated vith the ConStruCtlo0 Harris

Eac" 0< you ls reouested to provide to your smervlsor in ~ ~itin=October 16, 1975, the answer s to the fo((ning:

Nave you ever performed an insrection or investigatio~c'PSLcorporate offices, Roblnso~, Irunsvi k, or Ha«is"

2. If the answer to 1 is yes, did tIle inspectio retort adequate. ~

and aCCurate(r reflett yOur inSDeCtipr (0 inVeStiga ~ IOI'~f lndingS~

If the anseer l s nop p(ease desc r'babes

the aosaer to 0 la yes~ dc you have anl evidence l~c(ud'nQyOur prOfeSSiOnat ~udoraent, that eOu(d ref(crt favCra(( ~ C<

adverse(y,on the capat'I (ltl of CPCL +Sna4~>t to construct c" +

in the future, ooerateHarrlS'f

the answer iS yes, p(ease deSCribe.

Pl discuss any Nat ters relating to the Ch CPCL ea aoe~eease i ei ~ iona ~ ~,ai

or facilities not encomoassed by the above aue..'ightbe benef.cial to the Board in arr iving a: the~r

decision ~

5. Nave you or«'eformed an Op inf~r COr Ce+i „n (PL'L ' . aOabi l it y

to co>struct and operate Na r'." li s"~ «na'. s your

OP in iOP

~ lgpg ~ ~ eBpaFA ~ J'

~ C S reSS the fa:t that YO~ i a~ aOOea OeI vant lease a"vtest i p i yoi So deSire 1f ~ Ou Shoul" SC Chocaep O .

your suoe. v i sor orolhot iii.This SOeCial reoueSt fOr inf Or~at On

att8hpt to obtair in oteat ior e ~ tner

to licensin" the fat'.l':y out ratnetestinony tc the Boa~" n a area «~

YOU aay ans«er the Uea: i. S i~

response S ~

Shoul" nOt be CO Strue" aS

in SUOOOr. Of Or >r OOO

to O eSen. Co+5'. e e a<v at .a'.

the Board ha. eac esse"

scace be!o ~ . Please s'-" vc

J ~ i.ongChic', Reactc.

and N cleaOoeratio"s

5uosato Brae ~ ~

~,

~a 1tcv+c'4 0LINIir.u STATES

NUCLEAR REGULATORY COMMISSIONREGION II

10'I MARIETTASTR'EET NV'TLANTA.GEORGIA 30303

)0 a

« ~ « ~ «

SSINS 400, ~01, 402, 403/F

lIENOR N"'v = OR Fuel FaC'.lity and Naterials Sa'et, BranCh Staff Re-,I--Safeouards Branc" Sta"., R. eton IIReaC!OI OperatiOns and NuClear Supppr! B~anCI Sta", 0f-.-'0-

FRO~: J- Long, Chief, Reactor Op«ra! io... ard Iguc'.ea 5Jcc!--Branch, Region II

SljBJ ECT! INSPECTIO i FINDINGS AT SHEARON HARRI5 NiJCLEA0 Pl AN

OTHER CP5L FACIl. ITIES

As you I a: ."e a-a f, th. Cor..'ss',on has renand«d the Harris Drocee"I i"!back !0 !".« II«a '"" Boa-" cn tI f cas'5 !ha! tne Board nay have bee-IriS'ed ". !"e !«S!i-»i O< Staff I:tnesSeS.

Re" oi 5 ver>re''e -s

hO5«

IS DreS«ntly Drepar.n" !eStiI"Oni fO- the reranded 'Ieai- Or:a ! tha! t."e teS,ice.-.y DreSe~te„" ~ !C the Boar" aCCu a:e'. ~

!Ie find-.ngs of ou. insoec.ion and t". e professional judge-e-:shave perfprmed inSDeetiOnS Of CPLL faCilitieS. The teS!'"

4 e discussions of our inspe"tior. findings not only a. Har 's,a. B. unstick and R "'. son. kle have also beer directe" t"

!«5!'~o"» rela!'no !o !h« a"ility of C>EL nanage~er . to "..a-a=fa!!IVi!iec aSSO!iate" -'!h t. e COnS!ru! ~ iC n an" fu.--e OCf a.

1n

~ scp r ~ 4«e ~

a'.O'a P f ~ 5

~r~ ~

~ r

Ea--r r «r0

v 5 . e u«5 e tO Drov1of t I J 54 « ~.SCt la > ~

16, 197B, the ans~e 5 tc t+e folio

2.

m4Have yO4 ev«r perfOrned an -eC! 'O-. inieS! 'pat .:"CPgL o pirate of f '.ce5«Coins r J«SIIi k «cr Ha"r ~ 5

lf t~e a .Sv tc 1 is ves, "'~ Insrec! >c" <e.cr. ade Ja!aCC Jratf'., re~let: yOJ! inspet!:O" (Cr invest'3a! 'On.

4 qnAqrr~r

t rLe apt +«r I: n-, -I ei'.f dr:.: <>De.

3 I. he ag ~ f+ IO 1 I< vf< dr v04 hair a" ~

your prof e.'ond', Iud'«+«'. '.ha'I vc'u'tf le:idver 5 ~ '. I, Or the Capd'. > I ~! i O$ CPLL ~dnaar

the'utur«opera! 0 Hd

t 4~ fa~~rd ~ ~

to co~<! '4:! po

t n«an'ryg«

t

PL d'scuss any matters relating to to the CPSL managener tease 1

f ilities not encompassed by the above questions that ;-lpor ac1 1t1esmight be beneficial to the Board in a'n rrivin" at the~rdec 1 51 oh

5. c abil ityHave you orme d ah OpihiOr COnCerrlhg CPQLrs ap1S Ulto construct na d oper'a.e Harris? If so @hat 1s you

OP 1 hiph.

s ress the fact that you may appear befo e the Board toI ~ant to stress t e

hould so choose, please adviseteS.ify if yOu SO deSire. If yOu ShOu SO

your super vi sor prompt l y.

for informatior. should not be construed as arThis speciaL request or in of r in oppositio.atteript to obtain in.orma.ion e'oneither in support o p o

nd fact alin" the facility but rather to present COmpLete anBoa . 4i r th Board has expressed corce--.

l PLYou may ar s~er the questions i> the space be o~. ereSPOhSeS ~

+ ~ ~ ~ 4 o

F. J. LongChief~ Reactor Operations

~ i ~ «Col««~re Re s««

j Q / g

UNITEO STATES

L REGULATORY COMMISSIONREGION II

101 MARIETTA STREE T N AATLANTA GEORGIA 30303

+ ~ ~ e~SSINS 400, 401, 402, 403/~

MEMORANDUM. rOR I Fuel Facilit> an„" Rlate ials Sa'e:. Brar.cl Staff, Re=':.Safeouards Branc" Sta'', Re"io~ IIReactor Operations and Nuclear Su bor; Bra Sta'', re"..".. iI

FROY: F. J. Long, Cl..ief, Reactor Opera..on; and Nut.ea Sv:cc".Branch~ Reqio . I I

SUBJECT: INSPECTION FINDINGS AT SMEARDIi HARRIS ql,'CLEAs P'NOTHER CPCL FACILITIES

AS yOu ma> ."e a«a -, the CO~- ~ SS.On ha: ~ e-argo" the HarbaCk tO the Hea.'."" BOar" On t» OaS'S t<a. t .e BOard ma; havemiSled by the:eS:i~p» Of Staff «'tneSSeS.

Red.O" II iS oreSen. l> pI'eOarin" tc S: irIO i '- the renande" heais very importar: that the test imor > prese~ted .: the Board accv a:e.reflects the findings of our inspection and the prpfessional judge e-of those IIho have performed inspections of CPCL facilities. The .es.«''.'. inalvde diSCuSSip"S Of Ovr inSpeCt~O findingS nOt Ort. a:

Ha"'lsoa. Brutes«'ca ard Ro 'nso . Qe «ale als" bee" d're:te"pr".'de teStimO"7 rela..n" TO the a"'l'ti O'OAL mahage~e"t t: ~a-3=a.. those a::ivitieS aSSOCiated «'th t "e:OPStrutt O- an": e O.".o~ Harris ~

Sr

a ~ ~

~ ~4

Octooe~ 16 1W78 the ansverS to the fOl lO 'ng:

+4Have ypu ever pe.f prmed an iPS-.r: t.«pr in'.eST igat ~e-

2. If the anS«rr tC 1 iS ve S, d = t«r nSreet ~ ."- ret C rt ade=Jaand accvra'.r; v ref le:'„, vovr inscr.. I or (." "ves't 'aat'oP ~

f inAy~ ~ ~

I the arlS«rr 1S nC~ C'l eahr dr': ibe

3. If the anS«er tO 1 iS yeS, de VOv haVeyOvr prOfeSSiOna'. Ivdar~r~t, that «Ovid re'lrrt fa~('rent . ~

adver srl y oI the capat > l I t i of CPtsL mariaot~r: to const rain thr future, Ocrratr Harr la"

If the anS«Pr 'lb yes+ pleai< deSCr lt r ~

5.

Please discuss any matters re lating to tht CPEL manage~e-!or facilities not encompassed by the above ques! ions tha!might be benef ~cial to the Boat d in arr iving a! theirdecision.

Have you formed ar opinion concerninq CP|'L's caoabilityto construct and operate Harris? If so, aha! is youropinio~"

I van! to str'ess !ht fact that you may appear befort the Board tcteStify if yOu SO deSire. If yOu ShOuld SO ChOOSe, pleaSe adviSeyour super i i sor promo! l y.

This special request for informat ionatteapt to obt air ir format ion eithertp liCenSing tht fatility but rathertestimony,." the Board in an area ~~'iYou may ansre~ !<e ques! io"s i~ the sr esponse's ~

should not bt construed as a~

in suppor! of~ or in opposi! iotO preSent COmplete ar d fae..at

the Board has exp~esse" .o"=e" .cate belo . Please sigr y- "

~ ~ % ~

F. J. LongChief, Reactor Opera!ious

and Nuclear Supper! Bra":

4. Please discuss any matters relating to the CPLL manage>ertor facilities not encompassed by the above questions thatmight be beneficial to the Board in arriving at theirdecision.

5. Have you formed an opinion concerning CPKL's capabilityto construct and operate Harris? If so, what is youropinion?

I want to stress the fact that you may appear before the Board ttestify if you so desire. If you should so choose, please adviseyour super visor promptly.

This special request for information should not be construed as a.attempt to obtain information either in support of~ or in oppositio-to licensing t'e facility but rather to present complete and fac. altestimony to the Boar" in an area which the Board has expressed =o":eYou may answer the ques.ions in the space below. Please s'.gn youresponses'

~

F. J ~ LongChief, Reactor Operations

and Nuclear Support Bra":-

O~ (AS 4~es~<clC

Q2 $ QS,

Q~ ioo sH s.—. A,~ Mvssu.e.p To ~> l~ %ger

Q~~p~ AN Kb'EQCATEI-i'a~~ W L N ( o u,

W Co~~~w

Qo — 5'gp 4usmK9. Qs) yksoMK.

is+ ~ICy~'o~ 0

~y ~

~ ra

g!+tee+

UNITEO STATES

NUCLEAR REGULATORY COMMISSIONREGION II

i01 MARIETTA STREET N.WATLANTA GEORGIA 30303

SSINS 400, 401, 402, 403/F

HKRORANDUM FOR: Fuel Facility and Materials Safety Brarch Staff~ Re".-. IISafeguards Branch Staff, Region IIReactoI'perations and Nuclear Suooor: Branc'ta"., Re"'a II

FROI ~: F. J. Long, Chief, Reactor Operations and Nu. lea Sz"c"Branch, Region Il

SUBJ ECT: INSPECTION FINDINGS AT SHEARON HARRIS NUCLEA0 PLANT 4'a

OTHER CPLL FACILITIES

AS yau may be ara t, the COmmiSSiOn haS remanded the HarriS proCte"baCk tO the HeaI'ing BOat" an the OaSiS tha. the BOard may haVe beermiSled by the teStirIany O< Staff vitneSSeS.

Regia> II is prtsentl> preparing test imany fo the r Emanded hta~ing.is very importar. that the testimony pI'eSerte" ta tht Board accurate. ~

rtflects the findings af our inspection and the professional judgerIe"tSof those vho have performed inspections of CPCL facilities. The ttstiI":".vil'. include discussions of ouI inSPection findings not only a: Harris,b~t also a. Brunsvick and Ratinson. Qe have also been dirt:tedpr"vide testimony relating to the abilit v of CIILL managemert to rIa a=e

thOSe aetiVitieS aSSOCiated vith t>e CanStrustian and <~t~~e ace a:.:-of Harris.

Eac o'ou is requested to provide tc >a~ sect visorOctober 16 1978, the ansvers to the fat loving:

Have you ever peIfOrmtd an ins."ectior. or inves.iga:ieCPCL corporate afficts, Roti .st ~, Brq~svi k a+ Ha~~'.s".

,2. If tht ansvtr to 1 is yts, did tIe inspectit" reart adequate. ~

and accurately reflect yaur ir spe tiara <a invest iqat o~>f indinas"

If the anSrer iS nap

attache

deS +.43. If tht ansver to 1 is yes, dc'ou have ana eaidt"ct, ~ "c'.u-'"".

your professional )udqtient, that vould reflect faae~at'. ~ cradversely on the capat'liti of CPCL manaoe~r"t to co~stru . c'~g

in the futur t~ ootr at e Har r i A"

!f the ansvrr iS ytS, Pltaar dtic~ite.

Please discuss any «atters relating to the CPCL ma~age ert ~/~~~or facilities not encompassed by the above questions that py«ight be beneficial to the Board, in arriving at theirdecision.

5. Have yov corned an opinion concernina Coal.'c caoatcitity /j/gg& 'o

construct and operate Harl is? If so, vhat is youropinion?

I ~ant to stress the fact that you may appear before the Board tctestify if you so desire. If you should so choose, please adviseyour supervisor promptLy.

This special request for information should not be construed as aratte«pt to obtain information either in support of, or in oppositioto licensing the facility but rather to present complete and fac. altesti«ony to the Board in an area which the Board has expressed corce".You «ay answer the questionS in the Space below', Please sign

you'esponses'

~ ~ ~ ~ \ 0

F ~ J ~ LongChief, Reactor Dperations

and Nuclea~ Suppor t Brar c~

4. Please discuss any 'matters relating to the CPCL manage~crtor facilities not encompassed by the above questions thatmight be beneficial to the Board in arriving at theirdecision.

5. Have you formed an opinion concerning CPEL's capabilityto construct and operate Harris? If so, what is youropinion"

I want to stress the fact that you may appear before the Board totestify if you so desire. If you should so choose, please adviseyour supervisor promptly.

This special, request for information should not be construed as anattempt to obtain information either in support of, or in oppositio"to licensing the facility but rather to present complete and fac. altestimony to the Boar" in an area which the Board has expresse" conce" .You may answe~ the questions in the space below. Please sign yourresponses.

~ ~ I 0

F. J ~ LongChief, Reactor Operations

and Nuclear Support Bra

iso atCgpt rr uNITED sTATESNUCLEAR REGULATORY COMMISSION

REGION IIt0i MARIETt a STREE t N y%

ATLANTA GEORGIA 30303

o ~ o ~ ~

SSINS 400, 43"., 402, 403/r

IIENORANDUv FOR: 0Fuel Facility and Ka:a ial'< Sa'e.. B~a-c~ Staff, e=Safeouard~. Bran(a Sta'', Re" on IIReactor Operations and Nuc lea. Supoor: B a c Sta'', =a-. ~ :>

F ROY: F. J. LOnO, Chief, Rea(tOr Operat',On anp )ti:.aa Sw-„((-.Branch, Reoio.. II

SUBJECT: INSPECTION; F INDIHiiS AT SHEARON HAR01 S h LEAt @LAN 4

OTHER CPLL FACILITIES

AS yOu mai ."e a a.o, the CO~-ISS.Or "a: e-a-doO 3 "e Ha"'S " O:ac" -=e.ao~baCk tn the Hea '"." BOa~d O»» CaS'5 ."a. t "e Bpao" ~a ~ I,ave toe

miSled "y toe:esti-Oni C~ Staff v .nesses.

oo mao ~ ~Regip" 11 '5 preSe".tl) preparin„"teS: i~p .. 'O the rema~me„ heais veri importar. tI at the testimony pr eser ted tc the Boar" a'ccu"ate.re~le(ts the findin9S Of Our inSpe(tipn and the prOfeSSiOna'. judge-e-of those vho have DerfOI'med insDeCtiOnS Of CPLL fa(ilities. The teS(

include discussior 5 of our lnspec,'c findinos not or ly at Hart : aIs= at Bru~sa i and Robi~so~. we ~ave also bee~ dire:te"r~c. de testimo-y rela. "= to the at''.'.t ~ nt CPS'anage~eat '." ~a-ao

0 0 Qf 4 o ~ o arthOSe a(tiv .ieS aSSO(iate" vith t+e COnS.ru..i. an - . eH

I »~

5o

a

~ s4

0::opeP t ~yO~ ~ 5 reguosted tO DrOvide t i SJ t' SC ~ a . ~ ~

16, 1978, the ar svers to t ie follov n=t

Have you eve r DerfOrmed an inS".eC. inn Or ir veS: i9a. in"CPLL CO(OOra:e OffiCeS, Roti-Sn", BrurSVi k, Co Ha

2. If t he ansveo t( 1 i 5 yes did t iie instiec '. i c'ennr 5 ade„-~a ~ ! . ~

in ~ i a ~ ~ oah a((ura, el y retie I your inspe:t Ior (o inves'. i9a. 'o"f ind~ no'~gI< the ansvr< 15 r c, ol ease dt'5: ribe.

3. If 'I he ansve< tO 1 I 5 ye~ dn you have ar i e. i dc ": e, ~

your DrOfess IonJ I )udOe~e~'., that vOuld I et lt f aio aW Padver Set y On the (apat i l I t i Of CPf L manaOe~r"'p (Ons'~:

'nthe future OI crate Har r i ~"

If the ansver Is yes, please descrihe.

4. PleaSe diSCuSS any matterS relating tO the CPEL manage~crtor facilities not encompassed by the above auestions tea'.might be beneficial to the Board in ar r iving at theirdecision.

5. Have you formed an opia ion concerr in@ CPEL 's capabilitytO COnStrust and operate Harry." If sc, shat iS yOuropinion

I want tO StreSS the faCt that yOu may appear befOre the BOard tCteStify if yOu SO deSire. If yOu Shpuld SO ChOOSe, O(eaSe adv Seyour superv'isor promptly.

This special request for informationatteapt tO Obtain in'Ormat i On eitherto licensing the facility but rathertestioony to the Boar" in an area uhiYOu may anSve the ZueS: iO~S i . the Sresponses'hould

not be construed as a

suopof . of or in opoos .'oto present complete and fat..a',Ch the BOard haS expreSSed CO,Ce".ca:e below'. Please sior yo~~

F. J. l.ongChief, Reactor Operations

and Nuclear Support Bra"c~

(g% IIIgIgiC

P ~

uNITEO STATES

NUCLEAR REGULATORY COMMISSIONREGION II

iOI MARIETTASTREETN,i'TLANTA,GEORGIA 30303

SSINS 400, 401, 402, 403/F

MEMORANDUM FOR: Fuel Facility an" materi ai s Sa'et, Brarch Staf f, Re"'=.Safeguards Branch Sta'f, Re"ion 11Reactor Operations and Nuc lear Supoor: Branci Sta", Re"' II

FRON: F. J. Long, Chief, Reactor Operat-'.Ons an> Nu ea SJ-„ccBranch~ Region II

SUBJECT: INSPECTION FINDINGS AT SKEARON HARRIS NUCLEAII PLANOTHER CP&L FACILITIES

As you may he aia e tiie Com~'.Ss',on 'IaS remanded the Harris proceed'":back to the Hear'.ng Board on the has's tha. the Board may have beemisleC by the testiriony of staff I itnesses.

Reg'.Or II iS preSently prebaIing tEStimOny fa~ the renanae" nearing.is veI'y impoItant that the testimony prese te" to the Boat " accuIate. ~

reflects the findings of our inspection and the professional judgene-tsof those who have performed inspections of cP&L facilities. The testi>c"

include discussions of our inspect'on finCinas not or ly a. Ha "'s,b '. also at Brunswick and Robinson. Qe have also heen dire:ted :=

de testimony rela.'.ng to .he a"il':v of CP&L IIIanageme-. to ma-a"ea'.; thOSe aCtivitieS aSSOCiated ~ith t>e COnStruetio an" : "e ape-a..o-o Hat'ris ~

fa of you is reauested to provide tc io " s~."e ~ iscOc.ober 16, 1978, the answers to the folloi'ng:

Have you ever perforrieo an ir sre::ic o inves: ga:'."- ."

CPLL corporate offices, Rc." "..."", Br~"si.icL, c~ Ha

2. the anSver tO 1 iS veS, C O t» 'nSte:t 0" re."Cr. a co~ate. ~

anC accurately reflect your inst et t io" (c invest'gat o"!findinas" — AJ~ ~If the anS~er iS nO, please dr,:~ ~ tr.If the answer to 1 is yes, dr vo hair anl e ~ Idr™ce,your profess iona l judaeIIient ~ t ha! cauld re' I': . < ave~at l ~

adversely on the capahilit ~ cf C>&l ~anaze ~"'. to cons'.ructfuture/ operate Ha~ r i —AA—

If the answer is yes, please de"" it r.

4. Please discuss any matters relating to the CPEL mar age~etcor facilities not encompassed by the above oues.ions thatmight be beneficial to the Board in arrivino at theirdecisi,on.

5. Have you formed an opinion concerning CPSL's capabilityto construct and operate Harri ? If so, what is your ~oopinion?

I want to stress the fact that you may appear before the Board tctestify if you so desire. If you should so choose, please adviseyour supervisor promptly.

This special request for information should not be construed as a..atte)apt to obtain information either in support of, or in oppositio.to licensing the fac~ lity but rather to present complete and fac. altestimony to the Boar" in an area which the Board has expressedYou may answer the questions in the Space below. Please sigr youresponses.

\~ ~ ~ 0

F. J. LongChief, Reactor Operations

and Nuclear Support Brans

~ v

l74. Please discuss any matters relatino to the CPCL managemert

or facilities not encompassed by the above ques:ions thatmight be beneficial to the Board in arriving at theirdecision.

5. Have you formed an opinion concerning CPSL's capabilityto construct and operate Harris? If so, ~hat is youropinion.

I ~ant to stress the fact that you may appear before the Board t"testify if you so desire. If you should so choose, please adviseyour supervisor promptly.

This specia l request for information should not be construed as anattempt to obtain information either in support of, or in oppositio .

to licensing the facility but rathe to present complete and fac. altestimony to the Board in an area which the Board has expressed conce -.You may answer the questions in the space belo~. Please sign you~responses.

~ ~ \ ~ 0

F. S. LongChief Reactor Operations

and Nuclear Suppor Bra":.

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ROUTING AND TRANSIIITTALSTN'

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For OeelenceFor CommasFor Ya» tnfoTTnatka

No&afld RCNllter Convecea5on

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4. Please discuss any matters relating to the CPCL managemertor facilities not encompassed by the above questions thatmight be beneficiaL to the Board in arriving at theirdecision

5. Have you formed an opinion concerning CPLL's capabilityto construct and operate Harris'? If so, what is youropinion'

I want to stress the fact that you may appear before the Board totestify if you so desire. If you should so choose please adviseyour supervisor promptly.

This special request for information should not be construed as anattempt to obtain informa.ion either in support of or in oppositiorto licensing the facility but rather to present complete and fact altestimony to the Board in an area which the Board has expressed conce -.You may answer the questions in the space belo~. PLease sign yourresponses.

o~F. J. LongChief, Reactor Operations

and Nuclear Support Branch

I:~«C B 'k.

Afew4 «Ccsw ~~~ ~, J

giVce ~ Chsa. OP~// 78

1@a k<Cy4~

0

~ ~ ~ ~ ~

uNITEO STATES

NUCLEAR REGULATORY COhtM!SSIOMREGION II

10> MARIETTa STREET.N WATLANTA.GEORGIA 30303

SSINS 400, 401 402, 403/F

REHORANDU"! FOR: Fu l Facility an" f"acerials Sa'ety B. anch Staff, Re„"1or. IISafeguards Branch Sta'f, Region IIReactor Operatior s ar d Nuclear Suppor. Branch Staff, Reo'o.. II—

F ROTI!: F. J. Long, Ch1ef, Reactor Operations an" Nu Lea Supp r:Branch~ Region

SUBJECT: INSPECTION F IND INGS AT SHEAPON HARRIS NUC'AR PLAN: AN"OTHER CPgL FACIl ITIES

As you may be a a e, t"e Con"-'ssIOn haS r»branded the Harris or ocee"'n=:-back to the Hear'.ng B"a-" on th» aS'S t". at the Boatd may have beemisLed by .ne z.e-sti". "~'q o'taff I-:tnesses.

Region II is prese"..I y preparin" .»s; 1mb ., for the remanded heat in". I:iS Very impOrtant tha: the teSt 1.-.Ony preSe~ted tO the BOa " aCCurate're lec.s the findings of our inspect ion and the professional judgerIentSof those who have performed inspections of CPgt. facilities. The testim=-viLL include discussio~s of our 1nspection find'.ngs not onLy at Harris,b~t also at Brunswick an" Rob'.nson. Me I ave also been dire: .ed t"pro~id» teS:impny I ela;:ng tO tI.e a"1L1ty Of CpgL manag»~e"t to rIa"ageall those a t ivi .ies associated P,th the construction an" futuI e ooe a: .o-0 Harris ~

Eath Of you 'IS reou»steC 'tO prOV Oe C vp '+ 54» O'ISCr 1n»~It1no hiOctobe~ 16 1978, the answers to the foL'.Ovina:

2.

Have you ever perform»" an ins".ection or 1nvest gat1OCPCL COrOOrate OffiC»S, RO."'."Sb", Bru Sa iCkt Or Harr1S"

pcsIf the anSs er tO 1 iS yeS, di" t~e inSbeetio" rewrt ade 4ate.-and accurately reflect yo4~ insbectio» (or investigatio~)f indincs"

pcsI f the O'Isser i 5 noq c . ease 0». ~: r 1be

3. I f the answer to 1 15 yes de vo4 have aI'> e 'I dr e

yOur prOfeSSiOnal judqehe~', tha'. VOuld ref let'. favC a: '. ~

aclversel 7 On the capa. I l I t 1 C" CpgL >anaoe~r» to cons' 40in the future~ Operate Harri~5ec. a~~~~ +e S.If the ansver is yes, please descr ihr.

4. PLease discuss any matters relating to the CPCL managemertor facilities not encompassed by the above auestions that

irmight be beneficial to the Board in arriving at thedeci slono 5g g f)Qy

5. Have you formed an opinion concerning CF'81.'s capabilityto construct and operate Harris? Ef so, uhat is yourop inion?

SI sant to stress the fact that you may aopear before t ehe Board totestify if you so desire. ?f you should so choose, pLease adviseyour supervisor promptly.

This special request for information should not be construed as arattempt to obtain information either in support of, or in oppositiont Licensing the faci lity but rather to present compLete and factualtestimony to . e oar„to the Boar„"in an area uhic". the Board has expressed conce 'You may answer the qu stions in the space below'. Please sign yourresponses'

~

~ ~,~ e ~

F. J. LongChief Reactor Operations

and Nuclear Support Branch

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4 . Please discuss any matters relating to the CPEL manage+crtor facilities not encompassed by the above questions thatmight be beneficial to the Board in arriving at theirdecision.

5. Have you formed an opinion concerning CPEL's capabilityto construct and operate Harris? If so, what is youropinion'?

I want to stress the fact that you may appear before the Board tctestify if you so desire. If you should so choose, please adviseyour supervisor promptl.y.

This special request for information should not be construed as a .

attempt to obtain information either in support of, or in oppositio-and fac. alt licensing the faci lity but rather to present complete a

testimony o et th Boar" in an area which the Board has expressed co-:e" .You may answer the questions in the space below. Please sign you,responses.

~ ~ ~ ~ % 0r

F ~ J. LongCh~ef, Reactor Operations

and Nuclear Support Brancr

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UNITED ST AT E S

NUCLEAR REGULATORY COMMISSREGION II

101 MARIET'1ASTREE'1 N V»

ATLANTA GEORGIA 30303

J, cc>. i4d4~5~&w~~

~ d ~ d ~

SSI.". 43D, 4'3"., 43', 403/F

IlEHORANQJ~ <QR:. Fut! Fa: i l it i. bnd Na tSanto ards Brar.c Sta''Reactor Ope»atior.s and

id ~ S~'~ . B a:'taf<, Rt- -.-

, Rt" o IINuc lea Su"=or: Bra- Sta'', t". -„- II

F ROt': F . J . Long, Cr.i ef, Rta:to 0"t«at io~» ano Nu: .ta 5~=-. -.-;Branch, RegiCn II

SUBJECT: INSPECTION FINDINGS AT SHEARON HARPIS NUCLEA0 PLAN A'»'.

OTHER CPEL FACI» ITIES

As you IIIa) ".e a«a.d, theCon-'ack

to the Hea in" Boa» or tIIIiSled by .he teS. i-OnI O~ Sta

SSidr. has re-andt» the Ha««'.S D«OCdd".":ht DaSES t~at t~t 9"a«" «a) . avt

»itnessts.P

~ d

~ ~d

Reg O~ II iS pr eSen:l) preOaring .eSt i'd~) 'O the rena"Oe" hea""g.i s ver) iIIIportar . that the test i»IIony Dr ese~t t " '. 0 the Boar" ac cu at e, ~

re'ects the findingS Cf Our inSpection and the p«OfeSSiona! judge«t-O'hOSe irhO have Delfd!+ed inSDettiOnS Of CP6L faC ilit ieS. The tes .

inCludt diSCuSSiO S Of Our inSDeet'O findingS nC: Or l ~ a: Ha" .

O: al SO a. B u~Sl.iCa and RO '.r SOn.. Qt I ave alSC tee~ "free.t"teS: ir»O" y rel a. ng tO t he atl l ~ '. » Of CP6L rIa«iaat~t% - «a-bod

a.. thOSt actii.tieS aSSOC'ated «1th t"t COnStruct ~ 0 bn"Ha«riS ~

Ea--o'ce

yO4 ~ S reoutSted tO PrOvide EC i ~ Su."t ~ SC«

1b, 1978, t he a"seers tc the ~o'. to« ~g:

HbVt )Du eVtr ptrfo!r»td an ir S;rc. 1C»«o! ir»~ts ~ ~ gap )»yPc 3

2. If the bnS»rr« tO 1 IS vt"., " '. »nSC t. '.'".-bI. a Curb'. ti r rtf

lee�'.

404r'~SC'>0 ':0 (C4 ihd» «

«t« Cr'entt r ~ ~ oa ~

/C4

I t«t bt sar«1s no, ctea'r dr .: « tt ~

3.' f t hr bhS»rt« t 0 1 'I S ytPP r d( «O4 hbVryou'«ofrs. onb.'udor~r '., tha'. ioutd !tftrcadverSrly Or tht Carat » t I:» C'P6< ~bnbor "":ih thr futu! t«OC»trbt t Hbrr» q" Pro

If thr bh'r P 1 S ytS« Dl tbi» dt .: \t.l',

~ f b ~«b»

tO COn<'r

P

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3»

4. PleaSe d~SCuSS any matterS relating tO the CPCL mahage~e-tor facilities not encompassed by the above auestions t"atmight be beneficial to the BoarC in arr iving a. their +/~de" 1 51 oh

5. Have yOu fOr~ed an Opirio. COnter in" CPEL'S Caoabil ityto cor struct and opera.o. Harri." I< sc, i~a.;s your+ODinipr +g didt4tSC +r~~ Jc Alp Ir~rj4P~~

WS&&y4P~rI sant tO StreSS the fact that yOu may appea. be'Ore the BOard t:teStify if yOu SO deSire. If yOu ShOuld SO ChOOSe, DleaSe adviSeyour Super vi SOr pr Ompt l y.

ThiS SpeCial requeSt fpr ihfOrmat'O". ShOuld nOt be COhStrued aS a

attelLpt to obtain in'ot mati on either in supDort of~ or in ODDos):'io"to licensing the facility but rather to present complete and fact alteStimOny tC the BOar" i~ a" area v>iC" the BCard haS exoreSSed CO.C»" .YOu may ahS~e< the aueSt iC~S in t<e SCa:e belO». PleaSe S'gr y=responses.

F. J. Long .

Chief Reactor Operationsand N Clear SuppOrt Bra

ta+ +1(v(i0

LINITEDSTATES

NUCLEAR REGULATORV COMMISSIONREGION II

101 MARIE TT A ST RE E 1 N Vi

ATLANTA GI ORGIA 30303

~ ~ ~ ~

SSI.'i". 400, 4'3', 432, 403/F

IIEIIlORAN«i" r Q0 . Fup, Faeili.i and Aa'p ta '

Saf eo" ar . B'3 ~ St a q RpReac!Cr Ooe atiors an" Nu. lpa

p! ~ B a«c Staff, Rp: ~ ! ~

IIS""por 'ra- ~ S 3"

F ROY: F ~ J ~ Lon r C tef r Rf 3" to 0 pra! Or'1 NJ..pa'JBran h Rp« Ion I t

SUBJECT: INSPECTION FINDINGS AT SHEAROIi HARRIS NUCLEA0 PLAkOTHER CPCL FACILITIES

AS ypu may .p a«3 r, tee Con 'Ss-or «at rp a Coo !hp HarriSbaCk tO the Hea "" Bnar" Or !Ie tate !«a! !"e Boar" ~a ~ haVe ~ep-'IIis e e 'es'I « i C Sta I ntssp(

Reg''0 Il is presently preparin" tes! ino«i '0 thp renar"e"I S very iIIIpor ~ ar. that the t eSE ...".IO."y pr eSe«t e" ! = the BOarefleCtS the findingS Of Our inSpeCtion and the prpfeSSipnaof thoSe Irho have perfOrIted insopctionS Of CPCL facil'ties.

'dp 'S Jssinrs Of Our tnspe t tnr f in inQS nnt 0at S" a. 8-u«S» 'C I and RO>'«SO . SIp «ave a l Sn t ee« "'r e

0 c-'de tps! t~c-. re,'a! "" '.0 !hp a."'' ! t c" CPC'a aop~t"a...hCSp at! Ii ! ies aSSO:iate'" ~. ! I: t "e COnS! r<C! in" an"

'arris,

hear ( ~

ac Jra! p.judgene"The tp(a. Ha" .

~ ~ 03' 'Ig\

V ~

~ +4

0 ooeyoJ is reoutsted to prov~de ." i" SJ"p" ~ is '" ~

16, 1978, the ar s~prs to the fc'. to~ nc:~

~

Have you ever per forrIpd an I"SC e:! '."-CPCL COrOOrate Off iCp(, RC. """., Br J"Si

in+ p(t

~ ~ «S ~ ~ «r s4

r Harr.r,

2. If 'the ansvt r to 1 is Ytsr d Sttan" a:0 Jratelv refit:!f in" n" ~"

~ ~ e.c rt adp. a ~

(! 'a ~ ~ 0« I

I'«p answer is nC, Ctpa.p dr ''tr.3. If the ansvtr to 1 IS yp'r rn~ hai+

yOur prOfeSSiOna'udot~p '., tha! «nu'dadvtr Stl y Or t hp Catboat t l i 1, n~ (PC'. ~anain the fut ur t OEItr at p Har ' (

~iidt p ™re r l p t ~al «ra

JO ~ «%

to Cons'rut ' r

If the ansve 1 6 ytsr Please de ~:r it'r ~

4. Please discuss any matte s relatino '.o the CPEL ma;aoeor facilities not encompassed bv the above ouections t.a:eight be benef'.Cial tO the Boar" in arr iv'n" a. theirdec>sion ~

5. Have vou for~ed an opin~on co~:orr in'CPCL's capabilityto Cpr Strutt and Operate Harry." lf SC, what iS yOurOpiniOn",

I ~art tC StreSS the fatt that yOu may aOOea'e'Ore the SOard '.

test '.'i i ~ yo so desire. 1f iou should so cnocse, please a"vyo 'upe v i sor promptly.

Thi s spec i a! t eguest for informatattempt to oL".air ir'of ma: ior e'.tto Licensin" the fac'.lity but rattestimony '.." the Board ir a" areaYOu may a S~e. the „ueSt iO. S

respor,ses.

ior. should not be construed as aher ir. supoo : of, or ir popes . " ~

he~ to present comr lete and fa= .a,v>it+ the Boa~" has exp'eSSe"

re scace belo . Please s'o- v „ ~

J . l.ongChief, Reactor Qperatio"s

and N~clea~ Suppc~t 8ra":

~C.III'<

%p+ 0

0 ~ t ~ ~

UNITED STATES

NUCLEAR R EGULATORY COMMISSIONREGION II

101 MARIETTASTREET H W

ATLANTA GEORGIA 30303

S SINS Cits 401 w 4~2/ 403/ F

NENORANDUN FOR: Fuel Facility and Nate ials Sa'e:'rarch Staff, Re".'=. IISafeguards Branch Sta«, Reg'on IIReactor Operations and Nuclear Suppor: Branct'ta", Reg'0- II

FROM: F. J. Long, Chief, Reactor Ooerat '.ons anC Nu.'.ea S~G:".Branch, Region II

SUBJECT: INSPECTION FINDINGS AT SHEARON HARRIS NUCLEAR PLANT AN

OTHER CPEL FACILITIES

As you may be a~a -., the CorIm'ss'.On has remanded .he Har.. is orocee" -":back to the Hear ing Boar" on the Lasis tha. the Board may have bee-.misled by the tes:ivory of staff ~'.tnesses.

Reg.pn II iS preSently preparing tEStimOny fpr the remanded hearingeis very important that the testimony presented to the Board accurate'...reflects the find1ngs of our inspection and the professional judgeme-.sof .hose IIho have performed inspections of CPSL facilities. The test'-3".Isi l 'nCl ude diSCuSS iOOS Of Our inSpeCtiO . f indingS nOt Or ly a. Har- S,

also at Brunswick and Robinson. Qe have also been dire:tedpr" ~ ide teStimOny rela.'.ng tO the ab'i.v Of CpSL management e.".ma a"eal: thOSe attivi.ieS aSSOCiated with t<e COnStruttiOr an" f~t "e O"e a.'."-O'arris.Eac- o'ou is r eI3uested to provide tc you supe visorOttpber 16, 1978, the anSIIerS tO the fO(lO~'ng:

Have you evet" performed a ifh "eetiOI„ Or inveS:igat'.0CPSL COrpOrate OffiCeS RO". ieiSO- Bru~SVitk, Or HarriS"

2. If the anaeee ta 1 iS eeS, tt a the inane:'.fe" ee "ee: a."e=aa .. ~ y+sand accurately reflect your Inscectior <o investsgat.o )f indsno!,"

I'he ans«er is no, please de .: Ite.

3. If the anSver tO 1 iS yeS, dC'Ou haVe an. e~ide"Cep ~ ".your professional judgement, that would reflect f ave~at '.

adversely on the capahiliti nf CFIRE manaar~o-'. to coI s:rin the future, operate Harri~"

~ 4»'»'

~ '1

e'f

the answer is yes@ pleas,I'e~0~ it e.

w34

PLease discuss any matte s relating to the CPEL manage~crtor facilities not encompassed by the above ouestions thatmight be beneficial to the Board in arriving at the~rdecision.

5. Have you formed an opinion concerning CPEL's capabilityto constru t and operate Harri~.? If so, wha. is youropinion".

I want to stress the fact that you may appear be.ore the Board tctestify if you so desire. If you should so choose, please adviseyour super vi sor prompt l y.

This special request for information should not be construed as arattempt to obtain information either in support of~ or in oppositio-.to licensing the facility but rather to present complete and fac. altestimony to the Soar" in an area which the Board has expressed co =e" .You may answer the questions in the space below. Please sigr yo"responses.

~ ~ ~ ~

F ~ J. LongChief Reactor Operations

and Nuclear Support Brac:.=

++ "ICu~C

r%p

0~f

UNIT E p STATES

NUCLEAR REGULATORY COMWSSIONREGION II

ioi MARIETTASTREET N AATLANTA GEORGIA 30303

30 p

SSINS 400, 401, 402, 403/F

RENORANDUN FOR: Fuel Facility and NlatePials Sa'e. ~ Bra,.ch Staff, Rea" ~

Safeauards Brar.c» Sta'f, Rea o~ IIReactor Operations and Nuclear Suppor: 9 anc'ta", »".'I

FRON: F. J. Lon" Ch:ef Reactor 0"erat ion: an" N~:;ea S —:".-:Branch Reaior. II

SUBJECT�

'NSPECTION FINDINGS AT SHEARON HARRIS NUCLEAo >LAN A'i:OTHER C>CL FACILITIES

AS yOu may pe a>a -.. ~ I e CO~-'SS'Or, ha: re" anaed:he Ha iS " O ee„"'-":back tc the Hea"'.~" Boa»" or. t"e tas's t~at tre B>ard ".a; nave bee"miSled "y the teSt i.-on. Of Staff I itneSSeS.

Reai5refoc

a.4

iar II is presently preoaring testimon; fo- the rer..ar."ed <ea '."". ™Very impOrtar'. that the teStimOny preSe~teC to the BOar" aCCurate". ~

lects the findings of our insoection and the professiona'. judae~e".sthose Idaho have performed inspect''ons of CPSL facilities. The test'-=-.

include discussior s of our inspect'on find'.ngs not o. ly a. Hap 's,alSO at Brur SWiCk and ROb'. SOO. Qe haVe a lSC been dire:te"

;'Ce teStimOny retatin" tO the at'lity O< C>CL ~a~aae~e.".t tC ~a-a=pse a:1 'vi ~ ies asso:iatod '.: r t <0 corst ruct -'. ar.„" ~

3 e: 33 .:-Harr~s ~

Ea: o~ you is reauestec to provide tc y" P s~te 'iscp '- . ".-. ". ~

0:.ooe 16, 1978, the answers to t "e 'allo»'n":

Have ou ever perfor'me„"an i~see.. 3'OP or inde 'aa: ~ -.-CPLL corporate offic» ~ , R". '"sc , Br~"spick, » Ha

pe p ~ asap

e 5 ~ ~ Qa ~ ~

If the answer to 1 is ye ~ c'c ' nspe, '. I

and accurately ref let. J 5 ~'.'0 ( 'findina."

3.

I'he answer i no, clea'.e de . 'tr'.f

If the anSier tO 1 iS ve', dr io~ haip a» ~

your prOf eSS ipna l judas>e t p 't ha'aul C

adver Set y On t he Cdpat ~ l I t ~ O< CPS'a<ain the future, Operate Ha« >4"

bey ~ e ~ P,o ~ P w pg~ 4ag hP) ~ hP

to cor str

If the answer is, yes~ pleasr de .." ~ l I .

5.

Please discuss any matters relating to the CPLL managemertor facilities not encompassed by the above questions .'a:might be beneficial to the Board in arriving at theirde" i sion.

Have you formed an opinion con erning CPLL's capabilityto construct and operate Harris'? If so, ~hat is youropin'ion:

I sant to stress the fact that you may appear before the Board tctestify if you so desire. lf you should so choose, please adviseyour supervisor promptly.

This special request for information should not be construed as arattempt to obtain information either in support of, or in oppositio-to licensing the facility but rather to present complete and fac. altestimony to the Soar" in an area which the Board has expressed o ce".You may answer the questions in the space belo~. Please s'-gr- yo~responses.

\\

~ ~ ~ w or

F. J ~ LongChief, Reactor Operations

and Nuclear Support Br a"="

%as 1t0~0

'

~ ~ t ~ ~

UNITED STATESNUCLEAfIREGULATORY COMMISSION

REGION I I

10i MARIETTASTREET N.NlATLANTA.GEORGIa 30303

SSINS <00, CD>, <02, 403JF

HEIORANDUN FOR: Fuel Facility and materials Sa'et ~ Branch Staff, Re"Safeguards Branch Sta' Re"ion IIReactor Operations and Nuclear Suopor: B arc Sta", Re".'0-

FROM: F. J . Long, Chief, Reactor Ooerat '.ons an" Nut tea S~oc""tBranch, Reoion II

SUBJECT: INSPECTION FINDINGS AT SHEARQN HARRIS Nl' EA0 >LAN >'iOTHER COL FACILITIES

As you may be a«a e, the Connission has remand!" the Hai is~oceed'aCk

tO the Hearirg BOar Or. the baSSS tha: the BOard mai have bee-miSled by the teStiI Ony Of Staff witneSSeS.

Regio~ II is presentLy preparing testimony for the renande" iearing.is veiy importar. that the testimony presented tc the Boar" accurate'. ~

reflects the findings of our inspection and the professional judgene"tsof those who have performed irspections of CPLL facilities. The tes:i""".«I I incLude discussions of our inspection findings not or ly a. Ha."'s,t: alSO a. BrunSWiCk and RObinSOn. We haVe alSO bee~ dire:te"provide tes.imony ielating to the abiL'ty of CpgL managemer'. t naPaa'.', .hose activities associateo «ith the construct ic- an" ' e 0 e a:':-of Harris.

Eac o~ you is r eGuested to provide tc yo " supeiisc'ctober16, 1978, the answers to the following:

Have yOu ever perfOrmed an inS.!Ctio Or inieSt.gat-CP8L corporate offices, Roti sc , Bier swicI, or Ha

2. If the answ!r to 1 is Yes did t'ie instiect i."" e."ert ade=~ate. ~

and accuI ately reflect your ir spec'.'or (c~ ."ves. ga. o".'.findinos"

If the afiSver i'G DleaS! deS:iibe.

3. If the answer to 1 is yes, dn you have a~ ~ ! ice e au +9your prOfeSsional Iudaement, that wOuld re'Le I fai." at '. ~

adversely on the capatiliti of CPEL manaoe~~"; to cons.ru..tirl the future ooerat! Hairier"

If the answer is yes~ plea~~ descrit!.

—4. Please discuss any matters relating to the CPLL managemert

or facilities not encompassed by the above questions that

might be beneficial to The Board in arriving at theirdecision.

5. Have you formed an opinion concerning CPEL's capabilityto construct and operate Harris? If so, what is your

opinion'

I want to stress the fact that you may appear before the Board t"testify if you so desire. If you should so choose, please advise

your supervisor promptly.

This special request for information should not be construed as ar

attempt to obtain information either in support of~ or in oppositioto licensing the facility but rather to present complete and fac: a(

teStimpny tO the BOar" in an area whiCh the BOard haS expreSSed COrCe-

You may answer the questions in the space below. Please sign your

responses.

\~ ~ I 0

F. J. LongChief, Reactor Operations

and Nuclear Support Bra. =

APPENDIX B .1

Management Meeting Summary - Brunswick 1 and 2

DateReport No.Unit No.

PurposeLocation Attendance

5/15/73(73-s)Unit No. 2

Second CorporateManagementMeetingRaleigh, N.C.

CPL - Jones,Utley, Bessac,Haivc )

Thompson'anks,

Tucker,Hollovell,and RovlesAEC " Moseley,Parker, Kiddand Murphy

AEC discussed interfacewithin the coamissionand special emphasiswas made on RO's concernfor gA., The inspectionprogram during theprcoperational andstartup phases vas alsodiscussed. CPI discussedtheir organization andplans for the preopcra-tional test program

4/25/75 Second CorporateUait No. 1 Management

MeetingBruasvick Plant

CPL - Bessac,HollovellNRC - Lewis,Cantrelland Parker

NRC discussed inspec-tion program relatedto construction verifi-cation tests, preopera-tional tests and startuptests. The QA Programinspections for prcopera-tional testing andoperations vere alsodiscussed

5/13/75 Enforceaeat(7s-s) ConferenceUnit No. 2 Region II

CPL - Jones,Hollovcll,Wyllie 8 BanksNRC - Mosley,Seidle, Long,Keaaay Lewisand Cantrell

NRC discussed RII concernover COL's managementapparent iaeffectivenessin taking appropriatecorrective action topreclude several securityrelated noncomplianceitems identified to date.COL's response indicatedcorrective action vouldbe taken promptly. Anenforcement letter vassent to CPSL from Hg.

Appendix C.1

ll/ll/75(75-1S)Unit No. 2

Third ManagementRaleigh, N.C.

CPL - Jones,Utley, Bessac,Furr, Hollowell,Loflin, Banks,Howie, McGovern,Morgan and MenscerNRC - Long andCantrell

This was a general reviewof plant operations fromthe time of issuance ofBrunswick 2 operatinglicense

2/20/76Unit No. 2

3/17/77Memo Danceto LongBrunswickNos. 1 and 2Robinson

CorporateManagementMeetingRaleigh, N.C.

MaintenanceControlSupervisoryTurnoverBrunswick Plant

CPL - Jones,Utley, Bessac,Hollowell,Loflin and BanksNRC - Seidle,Cantrell andJenkins

CPL - Tollison,and BanksNRC - Long,Vance, Cantrelland Epps

Meeting was held todiscuss ISE concernsregarding plant opera-tions for 1975 andearly 1976. Followingitems discussed:Reportable occurrencehistory, quality oflicensee reports,timeliness of licenseereports, managementreview of operatingexperiences, enforcementhistory, requirementto follow emergencyinstructions, TIP with-drawn behind shield, andcircumstances surroundingstack filter houseexplosions. (Meeting wasresult of Inspection 76-02)

A general discussion onCP&L's maintenancecontrols and turnoverfrequency of supervisorypersonnel. COL reiteratedtheir responsiveness toour concerns and detailedaction which had beentaken to resolve theseconcerns

1/11/78261/78-02325/78-03324/78-03

To discussspecific currentissues and topresent NRC's

CPL - Jones, Furr,Banks, McManus,Chiangi, McGovern,Tollison and

Issues discussed involvedthe following: enforce-ment history, licenseereported events, staffing

t'

hppendiz C. 1 &3&

BrunswickHos. 1 and 2Robinson

program ob-jective andimplementation.Region II Office

StarkeyHRC - O'Reilly,Thompson, Long,Dance, SutherlandGibson, Jenkins,hnnast, Sullivanand Hinkley

and safety performance,emergency planningprocedural and adminis-trative controls, andspecific occurrencesas a result of personnelerrors and the licenseesresponsiveness toevaluation and correctionof equipment malfunctions.The need for proceduraland administrative controlsand strict adherence byoperating personnel tosuch procedures wasstressed.

Appendix C.2

3/17/77Memo Danceto Long.BrunswickNo. 1 and 2Robinson

MaintenanceControlSupervisoryTurnover forall COLfacilities.Brunswick Plant

CPL - Tollisonand BanksNRC - Long,Dance, Cantrelland Epps

the public that plantsoperated safely and infull compliance withAEC require«ents .and that subsequentinspections atH. B. Robinson will beai«ed at a determinationof whether or not «ajori«prove«eats are made.

h general discussionof COL's «aintenancecontrols and turnoverfrequency of super-visory personnel.COL reiterated theirresponsiveness to ourconcerns and detailedaction which had been'taken to resolve theseconcerns.

1/11/78261/78"02325/78-03324/78-03BrunswickNo. 1 and 2Robinson

To discussspecific currentissues and topresent NRC'sprogram objec-tive andi«pie«entation.Region II Office

CPL - Jones,Furr, Banks,McManus, Chiangi,McGovern, Tollisonand StarkeyNRC - O'Reilly,Thompson, Long,Dance, SutherlandGibson, Jenkins,Annast, Sullivanand Hinkley

Issues discussed involvedthe following: enforce-«ent history, licenseereported events, staffingand safety perfor«ance,e«ergency planning,procedural and adminis-tive controls, andspecific occurrencesas a result of personnelerrors and the licenseesresponsiveness toevaluation and correctionof equip«ent «alfunctions.The need for proceduraland administrativecontrols and strictadherence by operatingpersonnel to suchprocedures was stressed.

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(APPENOIX C

~l4-~ ii~'n/COtlDUGT OF OPEfNTIOHS CHAPT

4

~ ~

SOL - Senior Reactor Operator LicenseOL - Reactor Operator I icense

PlantHana .er

~ ~

Fnvizonmental & RadiationControl Supervisor

LOperatingSupezvi.sor LRnpfnaerinj }}A

S»pczvisor SupervisorHaintenanceSupervisor

Adminis trativcSupervisor

Radiation Control &

Test Foreman\

S~'.n d'orHnp<ncczfnp"

Senior,Hn

inccr=np'mezgcncy

ConditionSOL

Emergency Coordinator l Shift Foreman(Sbif t Foreman)

Control Operatoz

Instrumentation& ControlForeman

Hccbanic-Fozeman

Training StoresCoo zdina t or: o reman

Shift FireGri,ade OL

Control OperatorUnit }}t2

AuxiliaryOperatorUniL j}p

Control Operator~ tUnit f)1

huxiliaryOperator1Jni t Ill

(l)Unit Pl personnel arc indicated forclarity only and are not.a part oftbc e specifications,

Figure 6.2-2 .

APPENCIX C

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2947

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f~eQ We traW~iag faci3.949.eso X'h nigh" he that:sa ~+o

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aa ve~X,p OY can X gash Lnqui=.e OZ a qvaI,icy aaamance pa@sea

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cuasec7 it viQl hMo He's auiCa'imgreoseQ, 3.ice may others

~<ho have he@a ':~,.eo But X de% aot estd hex specifical1y if

CHcYZRKM SMXTH8

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2948

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2949

CHAZRMBM GI4XTS: 'Zhax'a aga~c, X'3,l ~~ve thaC ho

JQQX pxofe889 one%3. QQdglRGnto

HR. BP>GP.; Xt; was my uadezs~~diag~ and corxech

me '2 X'm wzong, Chat. Mere 4o a dix~=r=zexLce between %he

gert'aud 'the s w Reason *X Ke T a.censing ~amwaz; ard

csxt'x,P cat~ on 04 Q. KcRULQg ~ac3,X, ~jo C'zdiQQZQ.JJ ~8

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rwztiaalaz k~rd o" Wiuqo

~tX2?~~,SS LOWCz 89.s gob voa3A he ingle, He doesn',l.icensG re% Qpc~aarQFs g ei Weze HG c~RL?RiQGQ and ~~pecans

cx'" incog QzogxQQLp KQe gilQ19.~+XcR~M.Qn ?3z'ocx'zL~Rg~MRS Box'fWing, K".d his "econmmxdaL-.ons ~~e pvC inta Mxa system Qn

3.icsnsiKlgo 3M ~'' ~SING Rlp QndQXQ~63.ng 'WcLG 4G had ~C CQQG

o:. Kaput. Qn the cmhification Qf the teaming -"acikityo

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tfR. O'NBXX:L: Thank you, t1~. C»airman.

iR. O'HHXZZ:

9 5-BYltlemexl g on page 6 of your prefiled tes t imony

th(. first paragraph or the answer, the las" s(..ntence, you

state &at'"CPf;L did taLe the initiative , incidental-

ly , on QA P -ogram development . .. . "

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',Vculd you please give some e:samples of CPGX 's

in't'ative in d1is area?

(W tness Xong) X could mention at least two

examples that X'm pe sonally a~are oi. CP~~ was involved

Qn Ufo of Jle ma/or g X would say the very 'iilportal1t standards

in the Ã-45 group on quality assarance. Pa1d the two that X'm

xamiliar;~ith is one standard on the prccess ox" auditinc, ~Me

qual" ty assur51nce re ui eMnts Zor nuclear p3.ant audits o

They'e part icipated fram the very beginning OZ <he work

group functions on Diat standard. 2nd it has been published

and, o" cou-se, has been used.

'-0

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%~'. e two standards are 8~45 ~ 2 ~ 12 g audits g and

M-45.2.23 on personnel, auditor qualifications.

-:~er very active in Bose smdards. kzd ~JIose

Z knoa they

standards

They also participated zrorI the hag nning in

J1e standard on auditor qualixkcaticn For nuclear power

are vG y good5 atld ve y important standards X knGv that

2951

Nnen you taD~ about 'N'tandards X believe

there are o"he s, but X'm not particularly fami1i.ar with them.

0

you'e referring to the American Nuclea—

ANsSZ o

—Stand- "ds Xnstitute, or ANSX.

"4r. Long, do X understand that you al'o served

on those commi"tees which developed those standards'P

Zes, 've served on those, and others.

And a"e you aware of any 'ndividuals at CPSL

who se~cd on those committees also'

know that i~ir. Banks has been active on thosei

the two working g"oups that X mentioned.

And in working with Nr. Banks on those committees

were you able to form any professional j dgments with

respect to his qualifications and professional e'cpertise in

the area of quality assurance and management controls at.

nuclear powerplants''d

say &fr. Banks d"'d a veer fine, commendable

job. And X think Me product spoke for the group. X don'

believe X would go too far in, you know, est~acing the

contributions of any one individual. Bu" X do know tnat

Hr. Banks has been ertruaely active and ccoperative ~

St~adard development is a pretty difficult thing.

You have to coro"'der the needs of the industry sometimes. And

Ijb3

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2952

many times Yaere is a pressure to push, or t~~ to obtain

s"anda ds in the 8i ection of your company interest But I

have never seen any selfishness by any member, so far as that

goes ~

l4"-. ~ong, I believe that the QA program as ve

I ~

g'p

Q

.'.now xt now seas develope", or adopted officially in June 3.970

as Bppendi- B to 10 CPR Part 50. Goes Chat date agree with

your recollecticn?

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ad CPsSs.v developed a QA prcgrc~H1 for BrunsMickI

even prior to '"he eauirement to develop such a program in

3.970; do you zeca3.1?

I don't reca'1 any.'n 19'?0 Brunswic1. was in

pretty early construction.

Q So you don't recall ~whether or not there had been

an earlier development f a QA program?

I lcno<s of very few. There s~ere many management

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contro3. programs that -.vere similar to QA prcg. ams. But IRnov of no QZ program at Bransvie2- at that time.

Gentlemen, on page 28 of your prefiled tes~~ ony

you ve summari Zed the numbers of &8 non complichlceQ and

deviations for the Robinson plant from January 1, 1975

through Bugust 31; 3.97S. And for those years you note, in

the table at the bottom of the page, Chat .'~e Rob'nson plant

had no vio3.ations.

2953

Ha the Robinson plant ever had a violation in

its histo~'?

Q 3rd ix we look at those numbers„ sir, we note

that the numbers of 'foxcement infractions, deficiencies

and deviations have decreased in ab'solute numbers. Xsn'0

it aloo true that during this period of time—

CHAZKCM SM:TH: .. don't third'ou'e stating

that tes'-imony correctly.

sorry g repeat the puss ti<lla please ~

'Z YP. OeHE LL

G Qn the bottom of page 28, in the table you'lnote the numb rs of Enforcement infractions, defi"iencies

and deviations h~ve generally decreased 'n absolute number's

s'nce Me first yeux, l975. Spacifica3.ly,. i my tabulation

is "ight, it goes from 38, 13, 19, <o 13.

s.sn't it also true that during chis period of

the nurhezs o+ inspections and 'nspectox days spent

at +~he Robinson plant have increased'

(Hi ne s Dance) As Z lco!c at the table X see

that the nurXers have decreased f=om the yeax '75, but the

other thxee years are in the same ba3.lpark.

But the answer to your question, Ha-e the inspec-

t"vns increased and the 'ntensity of our inspections, theI

answer is 1~8

2954

Ill'.,'!

\'fr

ID~d also 4»e .re~~lations and rec~ir~ments against !

which inspections are L-ado have increased?r

YesoI

i~zLd dUr9.ng this .Hule frame scLLLG 02 thQ sig41ificant I

addi tional reQQicrGLLLents inc3.Qdad SGCM'i y prcgrM>s g adds.ts onal

r"t rknieal p=e'ZieatiOnS, XBi pregrarIL, fire proteetiOn'rogram,araong o»ezs, which increased the n mher of Gqu9.re™

LL>ants again". ':Reich yoa ver 'nspecting?

II~ rC tj

'I I

II

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A . Yes.

Similarly, iZ ve look on page 30, 4".G Gnxorc~vaent

history for the 3rQQBUic34. plant is sch~~'arx~wed e

~ Q C~~bi3i~QM Si$XTH: ~ 'ILL sorz'y„bQt ~'LL e needed

that this tostimmy is going to he in Hle record at a place

@here a lat= wlanation may not he .vailLabla..

You've character'"ed tL:is testimony -n page 2S

~r>

IrI J'

~

,I

as being Qn FhMclQte decrease i'D &8 sQQ QZ &8 inJ.ractions

deficiencies and deviations. i v>ender 'x yov'r going to he

doing trle GaLLLe thing on page 30 BeeaQse i P~lt Rt this

place ized the record

O'IIEXLI' Z'm noa as'"ng S"e sane IJnestion as

to that pages

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IL

CKXiKSMI SMXTB". Nell, tinn, at this place int."LG "x'ecord xt is ~~se —at ~east i didn't acd it Qp< hQt it

tis pzobab2.y t "ue ~1at infractions, de iciencies and deviations )I

-.shen abc.ed zp, 'L1a='you have a total in Msolute nmabers that

~ ~

wh6

g I

has decreased. But. &e wrA.tnass pointed out &at since 1976

they have been rather love3.. Siad the pcs.nt Ch 4 X'm concerned

nbout is that in'ct'one in '76, '77 and '78 havo not

'decreased in absolute numbers, hecauae 3.978 is thro'ugh

August and i~ you vere to extend that 46m'oughout the balance

oi the year it wou36 he X2 deficiencies or inf actions.

X'e gust afraid that th question and ~NorviMout that ohse~~at9.on at that point may not he the eaap2ete

picture +

X'm sozzy to interrupt you en that.~>d RPJHoom;-iNELandon Zls

)5

s9

2956

Z +l2'~;-.tc vouz o~sezvatior. sakes ."he

zecozQ clea. p s» u

Cp-.7+>,~g.; Q.~~-,.-i:;s potlz gg,- s'c"" og. "gags '~ecL212icglly

cozzecz.

7~'1 lilPi 0 Pct+G uO g e Poxv ~ 02: cli3Z '""'&2.QP

Xn ~i-..e -."='.=.rs l975 ~zQ 3.976,. '~~ose nu.,mezs would

ie s 0 lolv ~0 i~"..2 ".. 2 Qp h.'"iÃdc'il SG a~eGL) G3. 0 z l9)6, is dna+

po-'= cozzec"7 U"12.< l i:iiQ 220~ recel.ve Gxl DOG Ptiklg liceDsey

G.'ie"Peg ~'-~j-1 QG'0'=:Md~ez 0+ " PQ(

< ~~~recoE3.22BPPli p.'~LB+ s QQ~ Z Ti".MQ

"s . rn."'gh- azgu "=ha~ 022e or 0'4~0. 512'a Z 6 1~.:9'" t0 Ci~a~ C.'4 Ste

zecorco

3i.s~ d~"-P G6 CO Fileke SQZG 3.t. S QQCGZS ~ GOCL tdla'L.

foz ."975 "+ose «mnbezs aze Zoz U22' '" G'oneo Poz l976 .they

Lm>»a oe;":0'~x'-. 2 12@ me.'.3. 54G -'=:.—,.;"- "a~ Uv.'t .. receivers

cxFc, ooezH'lls ' cezasey 4'Jhic42 'Plc~s 12 Sep 58Ehez 1976 o

T;TGll '2'hP~ AQUI™e cozzec'~o D"28 Z ' .~G'oeat

BlV S ~ie M'- ~~Her o ~o ~~hei='2ez "0's l00 ve"'CG22-'orreci: or 99

pezcell i co. Zec' ~ .~208 822reo

~.„-:Gss g ~tUS. yy~~~.<. ~o u'>)~."" '-.2e poir.-'a&>EG.'.': "Gi ~~ asF 2LS CFt'. S83.022 4

Ho:i'o'" ~ 'us~ ~ 5 l receive ei i QD'c."'ilpliel208 pr3.0z

'"0 recexvLJ-g +~6 oyez@'h-"."24 lxcePsGP

taje J

2951

it s . ossible"- That" s ivy ycu'r~ 99 ~erceni sure";

Tha+'s zi„-jli.

Q Lcok:Lnc". agaz.n a+ &6 ca< egory or v. ola ixons for1.975-76< 1977-18,, '.4 s ro'=a" 'la~ tj!e"e has notl j.e~n a

v» claCion QDrivg 't.'IQSe yea-'so

Has '=1e Brunswick p3.~~a-'- . ve received a vio at,'on'?

y»aso o

A'ain, C~urina Cilis period -1": t:ime ~<he numbers oZ

'sp casions an8 m~~hou s o.=. inspection 'ave increaseQ'2

Tha i cor-'"Gcilo

Z~Q. si uit.a' yy Zor Bobincon '&e ~ eguirailents

against uhich -x..=- p'lan~s are inspecCed slave inc easeQP

TP a'i s correc4~o

C~n''= en:en, pe=haps i 2.l a. Cress -"lis ho:~w. Long

x'rsvp g because o his experience in;;orking lziM t:he St~ndarQs

Co5~'h ~se ~

Zs i"':":air '-o ay dna" g nerai~y s.candards tha~

a" 8 BGop e8.. f >=hQ RPz ice~ 1 Ha~iozlal 8'cQQQarQH Inset-"'+uLe have

a t o~ -'~rvaC~ ~ie o3.QSV

iJR., PXXS: l4r. Chairln=n, Z o"jec.'o '.'rat aues"ion,

u;.'ess he deceives +ha~ he mea:ls i y conserva~iv-, vm.". s" the

:fiMesc %<an'hS ilc o o o

. ~i+ i —,+8~@~ ~'.QT?$ . ~ you U~„cers-ana ~]pal" jle Fieans

.~y '.T':" s Usa(1 ."= conceat: .which ~ s e'-:.«d .w adoe" zg

295S

3'I-'"."X~~>~S." Zi626: J. in'c l~~ei" i4is CUes~~ipn

O;sec. n ahab th' i".Rlzdards GIld tO 08 Ripre res'crick'.Ever 4+R'5

t'>e reellirc~m~at= ."Gnd -p he zn ~<le-conserva~ive or 'co~rards

safe~y d'rec53.onP

.B?9"" 3. - Gorrec'c g sacro

(~i' Bss X~cng) J. )4~07'I Ol: lt'Bz'y cas88 '.~~ilere X

persoMlly Pel c. «1IRG ~sly g hU.~ 'c.1lere are soFs 8'~Fzda'Uds one

las a 0 RPPZGC3.ai e c..76 'EDZCCGSS i'1liCl ShclndQrQQ

develo'. Qdo 0("casions,.-'y

'le vFo'".1( groUps 'c»"=9's~l'ze9 r pz'".e

Qv co?TKP" '"Qee coD~". I:de 't . h~ Sc.a lpga, P~ a ~ nog co~ser PPR~v~~

encQg1lo X ve seeIl 'Qlac.o

B>le Rt lens" my e'.~erienca on several ';;pr. ing

grol'Ps and sU13coM c Gees 1-as +~Gen c2lai tt:ey ~end '~o 4c8

consK".vai 3.ve 31} par- icQlarly l Rose 2~R'i Cer8 't.leaf. tend 80

KQnage'Qsna> XAKca-3.oxlsg Qi alit'y RssUrancey RQd3p&3 1)rocesseg<

QQRli '.caci Qns g i2 Ri sort: of b3 .Igo

n :.e only goin .. v .s my~g ""c escablis1l th -e isdiat ~Ilere is a margin of safety builds in, generally, ho

s~i "LBR's kala~ ai B de i&loped Hit L""l Ile ndclePr indUst-'o

All ~ le 8+Rndards in '~se ~ e adoQ'Gee Rs Rccepi Dle

have NHC Concur nce, or —.Gy are g=neral"y ndorsed hy

cne cf Ne Ireg ~3@id s. So T. ';Ipuld say '-? v.~ "'Ii;.ere .""G=e 's a

I"c"- g:-I B.". Or . GSS . lan ConSGZVR "iVG -GS"-iOX'el"eve i le

2959

"~>3C ilas mwde up for "ila~ by added re~ala"orv gui::e, tipula-c,": on.

Out in general X vJoulct agree Hlac She 84andaLQs

tend ~ o be in ~h: cc''r.serva've vireo'cion. ilavc. a, 'i)ays

prolQo'ced 'Ra't Piiyself g anG mos'c people I ve ~(lor.ii3c'. i'?it4 oaveo

~dl:..'"..0 V3'..ii,'C S Very +'e g S3.ro TQ 3:t p ga ~ n goes

to che Reg Gu'Des —2 'lieve yo l stat c'ch"P..they do have

margin of safe+y |3zil'- inta i:net'7

;~ey never dele-'e any"hing, or =a =:y 8 lateS i.andaZQS o 5'.ney moscly aalu 'co ~m:-:mo

Cnc-:. of i';:e reas 'n v¹ci. yo''ali l.his "o be

'car'cicularly i'-"X >Inderstand yore'nswerer ~"."o aues'cions

back, was 'n t~e ar: a of aualificahions and n>anagem nt.

COiltrOlo

"ell, i"'ri llave 'co acirait "'+ah mos~ of vy e3merience

iles been in '8 s.i all(larGs . Blat',eQ in fac'4 p '7<os i

K~i5 $8 —. s cn cual3. v assurance ou" d say ar - Hianagemenc

stand~~dc, bee=use they deal 'i'�"~ managemen.. programs.

7'iould soli' hate ~Ha s tru'~ fo. gene ally allOf 'thai o

0 Zo-z, ape=1=.'"al. y -'urning c= t'>e reaui ea.encs " rQual f:casions Q: sen': r plaza l:.Qnagemenc, cecslnical

'sp c .'ca'-ions or,"o!3> me Robinson and .'be,"rullswicJ: plan'.s

a=a basec. on .~~.e p";,":.: Sgandaz+~s foxed in Hl3.l-l97l. Z

believe t+i2'c s ~our 'Gs(.2.TAQny QQ . age

2960

'bio-' O. 3~KG ~M o Dc ~CB to PQd "GSG ~C SQSC-"f CS

Of ~~<OU gQS St XG11 CL? C;-at e

ff,tg ~~Qc c» (w l I Cl4aM & 1'4 o

C.'d.,3Z-'it S~'i'.T~- h3.S Ls = !SZ"'RG.B + 1 197 1 ~ Sd1lBF-"can

«3a='.=.onal ScanfAa'Fels g 8=-1 t~on eaxQ 'Prat~" ng of Hvclca:: Pona.—

Pl'at P'sonne".2

1&o 0 '1H «GSp s2.x a Z ~olLQv(s junat ~o~ i w s

mais a nizabar o: plac s "'n tn= recorD.

'"HAZE~'L~i HUZTH: Na3.1, 'j;:St ".Vr cc.regle'"'e;,aSS <7e'll

alopt anQ accQpt vnac "ntQ Gv;~+Rnca as a .Goc z(R ezh*RH.to

X'll s!: N . l ong ',: ha'll ta1:a a co!< a'.-. '-'r6 ma!:a seize

that ""lQ'"8 ~ali'.."lg &~0Qt t "6 sam8 CocUza~nto

gQc QF<cnt >*ancQcl to K".9 i'H.'~less oan81 e )

v'C''i 7~SS D~+~lCZ YGS ~ VG '17OQ 0 SRj thZtt ~31 ant

n: -.ag m. nt mssts KiSZ-018.1. Pleas —:hat porn qzcstion2

BY -'~~v " O'H~.~M

dHi&t463." ~~ 8 tech'.heal s~c8c~ fteat ~ ons

Op llOQQ 'i@<~'. Qs fQ< Q}FJ Jog'7 nSQn an@ p~~~s>7 j.Q, Q ants

ror !-.aalifi.cat.'~."ns of "~e >oo n'ne ~Os''1ons i.n @he plant

st af +

('pi.'t.tn'= 88 'nc8) X m sUi~ -5c-t 8 cox'-'Gct o 'Z g Qst

IMP "l+'eG tG loots(, QQ a z'Pz™Grencae

(-'US(~ o )

H Ci"a: «lan g ".7lsV.e L1=' lcQk-"ng at

-.ra=.(>rance- '=or cia..i.f~cat" on "~p"~t BoaÃQ c:„'81~~'.i.'~ nLzber!

CH~ZPCVZt SIXTH: Hl j1184, gGCGin g KCc.i+'L'to

z L13.nk WRU NQQ3dR l3e Boas. ~3. '~n" 03.4 ' o

«~») ~na~~ 8 Bca 1 ~M 5.'0 ~do

('le docQKBn 5 3. ze" x'GQ 'cQ Was

Ruad" .ec Bop i(EeniiZicafion as

Hoazd ~zh.&x i. 3.2 BnQ "'Fas

'-eceive8 .-'." evidence. )

O'-'- .'K<o 0'.;~XLL:

'L~o Dance, -.erbaPS Z can haXP ~rouo K ~3. Pou CQ".'n

iO Page 507

~ i"~;..e';s i ance) i-" is co@„"oct; f''r th Brunswick>

2wlC Z:d ~ QOl~ing . Q'" 'a.ile ROQinSGn -"RC."« 1 -"t:go

(~av~e

YGG) is iil >Qin RGCH specs o

HGU g QP. '&3 +A of Page 5" „IQll nQtec clnQ '~is~z7olS VSS ~i3:3 QQ t 0 Jest ~3 8aV ltd" s'~~o Plo3GSPBn ~ala'i: "%8

B=unslrick 4:echnica2. speci"-icaCJ'.Ons list eight 'job pos3. "Qns

Gzc @ding tn'8 shp x . 'cosi ion Un' ii6 O'CBza& iver/ SQpe1. v3.Box

+ha="e seniQr .-.eaotor apaxato-"'s ~ic nse is Residua'hie

Again., Co c3.ar."f~g <le recora, Deere is no

o.BOUT ~51~n~ iil 3'3'7SZ ."LLBol POX' SsHO 3. CRnse POP 'icse .Obsg

"8 'l C CO~ ~C "+

ZGQg ™~hRi. is CQ''ec'ho

1 ~9 c.e '3 nQ'" 8"1 anllOt:F53.Gll i.nai. SB~JS ~cGSG

jobs —='n t=he >ac<zi,".al speci:ica<ior.s —snouie. indica "e

~ ~

2962

SBO aasi~~~la, '"'Blah cozz~c~P

~L'EG3."is xs no'c Gn BQQOCc=i iQn ili~~ZGP

Xn elle K~PS -H"'8ol

'I'J"-t.'- C.O—ecb

gH~"y~Z~» ~>F::~zH: ~a"-ii 'i]as a vega~">vs7 n'bore isno'~P

O'MEZ::~: '..'There is not.3" HPi, O'NZZ.~L:

3~1Cs p'OQ Q<3$ ~ Z'«'~""hQZ 9~ 'c =a'i. paÃagZQpaN CIlai 'i 1G

RODinson C C 41iCal SDBC LPiCai".3.ODG C.O 110- 8 CQ 51c Bn

SRO ) S CiBS3 'lQ~ i ',n tllG SSItl3 Q 'hg S~MJ OZ'GS3 53 GnS QC ++6

RCA3.~%soll '01BPt. R i Ri.'

Z'c cess no i o

3 "a '„IoI3 ~va3:e oz ~I'cIler ~.icc~nsea "Ibices Rises

3.il LP 8 '"GChn" Cil.2. SpGCi ~2.CR'Canons f'r ~'im - op pkanc nianagemenx

pos j.i."oils Bi~b4ila. ~ 319 QnGS ai 3509inson Qn(z BzU'Nick an

SHO 86si aQ."a~ iil 'i9+OSG i Gc&ica1 SPBCi iCBc.ionSP

Hop Z BIi". nota

n ECHOES ~ Qll Viol'GQ Vii'a3E ConC8. Cl C2 Qn'i i 3 "A~ 43l8 faC c.

Chat: the Robinson technical spcciZ'ica~io™s Qo no~ inclllda

one SBO Qssirab'<.S eahagOZy in 'ChOSa c.ag e::g'L1C pOS'ihiOnsf

'Ql;8 coIlcGXQ Tais'c.o iii~p QQQ 'iJG cvK~PX'ch86

4118 S 8 UQ

Z'm;"a""'.ing w~'ut. Robinson, si-..io, Z ha.-e noc.

2963

Q i a%3 you ever 'coFi'@ended I change to t~Ae technical

specixicat cns oi tl - Robinson plant because t here <A'Ps not

included in the ".ec.";.nical specifications an SiRO desirable

xndication o 'ose ™:ave eight plant management positions P

i~~ o 'ong g ',a/e .'..Lhat you a-e concw~-"r~~e in

+Nese ms'=-s as "ugion XZ's position aIQ you." ae. sonal

po - 2.43.onP

- s Long) " e, sicko

CH3'. KP21 8"fX:.H l'ouie you repeat the c~uestion

d f bexo~e %as't 'M BPQo. a.~z+

L2 1~)i1ez upon, +"e RSQQX ~ez reafd x'owl the record@

«ervur sted )

BZ iso O'MERI~~

Dance, 2 believe that you testified yesterday

o- "~e day be"Gre tha" ™~he 'aZozm '=ion anQ the technical

p=oblaws at Brunscric!c that;rexe.included in vc.u— 'I~77

les"ia ny primarily caw frGIn the principal inspec to". at.

Qlan7 g s~M y i~aLKt.'.~A

:."IiLoess Dance) That's correct.

DER '» ~eke ~ t ~flat could Ulc~ ude +die 1n xoxMat~on

t'1's fou11d on —;braces 56 through 6b o" your pzex:. ~ ec:

les-:imony; ~he same problem areas vere di"cussed in 1977 in

your testimony r

t '-'."= an ou".gro:."K~. o z!>at, yes.

29Ci4

1~&o 0" 3="..t:L:p~". !.w. Chairman, Z oe3.ieve me ~~ill

reserve our cross»e...amination on these i".Gchnical problems

'o" 1'- Cart-~il Vie cave n~~ Zuza3lex'uestions o." '4 l"8

panel o

Cd~i: 'AH 824XTH".Yir. H-cd.np are you o';~pared to

begin yo -x'"oss-e:.amination'7

F~R " Zc'.vx~3: 74 "o ChaixÃaBn p" " it K.x'G c.g ~ eeable

coital ixe oaxties ano the Boa 0p I rroulc ore=er not to, but

can o

C:5;&Bl&Z~ Si4:TH: 'Pell, K>ler 's ro problem. hhat

~'18 'o ' Ue Only have Qhou " l~ Putts lext OZ hearing

time -- me -:7ill hegin our ezaminati n cz '~le panel, and then

e -izst " ng Yz~?GQ Ue ~esl3EQG ' 'e Gal 'ze 'i'7ill ta.cGp'oux'ross-G

a~."ationp nQ then tUce ours '~ apollo'ring that again.

Ãzo 0'HL"ZLL." "::cuse me, p.M, Chai~anp did Z

urwRers~-and you to change .che time xcr the heazi ng 0" Qm

l2:OG o'clo !c r7»ic+ vou announcea Ga=li r'P

CHA:K~~ SHEATH: ZGso l" 30 7'"e 'rl "l a ")oM~n

Qs *vQVo

PZAl4ZM.5.'ZM~ SY ~EZBOBRO

~'=~> P>'T S.'C.~iI

&~~. o '0!lgp 'yaS QteZGS c ed Ln t le anS%'Gs. to tntHavG ~rou ever recedent-' a oh~~.ge for Hobinson

teen s ocs "e ause tneze -;zas no —auota ™~ SPADO ~lcszz ule—Quote ~'CS:L'a ". Qns p ailQ ~amour anSHGZ i@a - Zloo «tH".a UQQ18 pe

%63. > 02965

''le poin+ OP. 2:econ- nding a chancre in i:..ch specs o-" a

non-b: nding .spec";"icai.ion;which was '.;eing ia»o„' sory"ray?

3"OQld Gh..=-xe ".e an'J QQ3z c ix xa.7 Hola'~.2 To?3 ac co~ilisrl

anything''a'3~el 4:e >O12 RQQ: ass 3.ncj (~ll2t ~o ze oz

' ~~i~ Loncf

7 9 'Li23.lr2. ~i4$ . ~„-'QesGiorl Was pili wo B ~ o'ong g wasn

Bn8".?eZP CL ti'.~ G1188~~'i Qn p

$ 0 X3.QQG~ EZ CUSHY iQ9 ~

~2 ne"'"'o'z'r3 e SQch R eGCYKia"H3ai 3.orl PQ pUt

Qes2.z~~ 'eo 3. -~de a xecor i enda:cion, ii bo;12.d:be co gilt520 eauired.

44 'ie".1 p iii a Lo",Njg (ale Boazd VieUs '1GQx'384&onyt

~-.'3eginrling at p ces 2:F80, line 4, an'nd'ag at. ~ == '"op of

c..i 83. We3.1 g .i -.i. no~ go3 ilg ho ask yor3 to cori'~K" on it nor'1 p

3 US i MRG no" es of " 'i bQa'. Ãe Fee'R Q ii as a z'Q.~-.volitant co+i: i."-nh on yon pa="", and .-';o: 8-. ze;=:.sor i ~sou'-'d

lire, du=ines ol2=-" =-cess ove3: -~we;reciter>d, *i- yor ';v-i i read

rQ '1OQz Ges~~~ilorl'j orl '~la'+ poipP. and 'c.1en ':li~dn vi~ dies'3!tie n&tweek '.~o'~ii yov. '=e' vs i<. -~ou'=.e ™a"..isfied ail:n +.=e "'~st-'wony,

if you -want v add 'o or delete or zo""'.Py 2.'~ in ~"ly 4'ay'P

BSCBUSe ~'le QO 'e '.~lc't ~OUZ OPSeZVai'nS ar.e ~vgo='~a0o

(~7~ <w~~ . i w ) =.a, .' ~

(tF-,-:nesQ D=nce) COG~4. le r illa' 1XPPe3. ~

296o

pi.eas67

liat s '?4QOp beginning;I'Kh ~'.ne 4 —and ~~ox Itey

arrant to go h c/i beforep to ~~G part preceding it. But this3.s 0 spec2.f.' iR;.."Gr s o Zt ends at K;Q top ox'483.p tine 3o

Centiemen, I m interestedp cz! parr-„2 oP. ~joe

testxiwonv p in vo" ~ QrocedQres .; l pzepar:L3c zoz constzUction

pezm t heazi gs )BL"re Goes cons3.dezat3.on 'tl'Teen startQp and

collsc 'ction seQaratep as hev%79en a constzUcgion ge" IR„.,Q

p cceed" ng pic~ an Qpe'"at3.ng 3.icense pzoceeQingP

MI,~jp "Qnder 0 18: egG" Qt3.onsp at 3easc 10 'C "2 50a 34 n

5f (Q,) (6) y ~he PSi-2 aha|.1 2nc~~Qde G pre3.&id.narj'1 an 'rRppl cant s organisationp era"ning oz personne" and conduct

o". opezat'onso

So at Least at the construction pe@nit stage

proceeding t|leze is some vie(Iing OZ ~e Applicant" s program

xor beg2zd)3.Qg o~erationsp xsn" t there) !3LZP

(~Pi'pess ~cng) Yes o

Yiadelon ~ls $ 8

Q BQQ Hle perking p~cpleg z'oCNiHxsCQQQing M&

face. @ha~ 9C's a const~"89on pemd.C pzoceeu9ng, 'She opera@in@

people are responsible for hhaC aspect o" 9CP

Les.

So pa~~- input into She const'mcmon.~snnih

h'ea=9ng with respect Co operation was at 3:.aasC somewhat

1a+m6 to foui; .;ozma3. du+Xesf

That"s correct, yes, si .

On pac„e 4 of your tA sthzony ~roe anmmr Me firstquestion, "Do you have any facts indicah9ng any present nee6

...", you answer'K ve~ opac9.f9.cal..v„You say "No." Huh

t'.en aha -"o13.osr9 zg sentence 9.n Mat ansamr:

0'~ obsezyra83 cn has been a31BC CP ccXi

manager9.a3. capabi19.ty and capac'ty are con-

t,"'nuing to he hroadeae8 and inmrove8."

hve 1 ~' WGC 9.8 the Rzp2.QVGCAcnq 3. a

" 8 no't

consiGCGnC v9.'Ll "no q because Me cpRQ849on 9.8 As tP~~ e G

passen@. neecR.

Mow "s you conclusion as +m Cae yr~senh mae6

dep'ending ~n &e observation oP. imp-ovsmentP

X+ '=. an ohsmvntion ~~hex~ es 1cok '=or and

an~cipaCG ~M)z:QvF~t » s'FQ re aQQX'Gsf39.Rig '4%8 pzBs~~C cocci

'Cion

":.TTM7 9cRB of Me p80pie Qbv9.ouse e p MQ present

Mznag8HLGQC x"y n&'h lM present or ava9.2.4:Me 84 hhQR 4~g anct

mpb2 ..'~,'»,. v 've considered Cleat

I QVess Dp QQGStion is 'WisI

Zs QQQX cheer no depc.nant Zion QM obsGzv8,

tion ~Mat thoy"ze cont~ning —that M~:e capab9.3i?;y and

capaci~ are continu".zgto he broadened and improvecD

Xeo, sir.Qn page 6 oZ g~om testimony, where yea state that:"'Shore vere instances whem m~ spections

revea3.6d 3.080 Klan desi''aMG involve&.'za

coxporace iRBzlag8218nt and GU.SCQssicns MBzs

he3.Q ';zi$.a &e licensees'anagement on &isBlkbgect

3,ze -mose ~stances, to @ocr Mme, dge, are they

~ Q

covered in the t stimmy nov —tet ze say in She hearingII

zecortD

('~~. ~ess Cmice) Pleat a~ you re8~~g to'P

Q Z'm referring to ~~"oar answer on page 6, the

beginning of ~e &ird 19-e fram the bott'e Xast

sentence on Uhe page o

fÃ9Pz~ess Xeng) Those rmMers s~utd he sgelm~d

oGt in vJGrivlRs inspection redo

tsar

and 'I n genera1 ~pere

they vere signai=icant or invo1ved non~omp1iances "Nay would

he included in "+e 8iq~x~s |.'or ~Me tot@1.

9 7'IS.L2.g Z gQ68$ HPJ ClXQSCXCn is$

Dces Mis hearing record cn r~d ifML+KIRQ in

~ pS ~~ ~

mpb3 your judgment t~e instances you referred to on the bottom o8

page G.

I'm n t asJcing Jou to specifically pcint thea

out. The quest=-'on "s directed toward whether ve have a

complete record or not

I;.~ould say that they are i2 c'used L~ the record.

Of this proceeding Chis rGKp&d proceed&lgT

:ndirectly, not spec9.H.cd.ly. X ~n!c the record

has considered Mesc 'n preparation of the pr sent —thislatest tea%mony, a" l of &ose factors have been considered.

(8'"sess Dance) %le do have a summary of m'anage»

R~Mlt meetingsi

NXTHPZS QMCE: Do va no@2

bR. M~ Xs: Yes. Xt is At cEuesnt B to this

i5 .'testimony, there is a summary of manaqexaont meetings.

BY CHBZKCQl SMKTH:

37 9, And you'e not eferring to any instances vhich

haven 'een summary" edthere%'O

<Hi&cess Iong) Ão, sir.Cx 3.i;sted; they'e not smmnar9.zed.

Xt's not something that P~n't been identifiedo" semnari~d w 'one say or another.

Fe'l, let me he more specific:

Are Chose inatances on the hetCcm of page 6, are

2970

mpb4

2

they the same ae the meetings —Are the meetLngs referred

to in 2tppendices B.l and B.2 the same as the discussions

eferzed to on the bottom of page 6'?

S9z, they would be ixwluded. The statmaent @as

more general. Xt +as contended to imply that ve have brought,~ par"icularly this area of QA, those matters are brought to

managmmnt attend."'on generally somewhat beyond the routLne

inspec'tion'exit Q~tozv9ev p ocess, and Chat's +hat that vaa

contended' get ac oss, to corporate management.

Q QJtay.

Row~ do you believe that you have brought to the

attention of the Poard all of the sign9.ficanC McMences

referred to in Cha b'ot~ of page 6V

: believe ms hara.

17

18

('~" tness Dance) Yea s9.~

('V hn Long) Tha

That mrna your LntenhLonP

v@s~ OLro

19 Q You have no recommendations to us along that

20 line to &~ice of furthez2

2"=

Ha~~ ve have to depend upon your advice. Hmr

tPAs is 3,mportant. Ne have to depend upon your -.">QvLce.

Pe believe —one of the " asena ve brought the

3.ates'nspect"on results +as ve felt that +as pretty

comprehensi ge and a 'ority thorough @va

curxent a" so. Bwd;>e fe1t mat had to be 9n the record for

'Chat xeason. K.at vms Che on3y outstaz.doing issue'hat ve had.

iwghte X thX1Lk that "wc s Qpp:cQpriateo

kMe DMlcGP{'H,Cnemis

Dancej Ne have ManQZied all ibams

+hi.ch ve Chint are pertly~>ent to the issue, and as xa as I'.cnow all of'hese Ancldences referred to at the bottom of

page 6 have '"een included.

8.094 On page 9, the page hegdns vith an 'answer', and,

iQ RicLMcvg do~i +~~0 B~VGZ;Ls Ch9 8 8Cat65lentc

"Cp~<" ~rasoes ue as a consent~'ve

management o.-.@~~9.sation, tough 3.n dealing

H9PA Hle issues Chat Cend to create

66+RLRl89.on of manccb&r recplirQRBnts a

carChe om 6am you state.

"They are at on@ dofenders of the9.r

posi tie'no ~ o

But you go on to says

aevezg they have FMde

".0 declan.on which demonstrated an avaze-

22

ness o'afety issuos and have rcet eamnlt-

~ent 8 pzQHQtgy once dcf89.on@ ~~i ~>Q ~

'cw

X'm partiau3.az1y Mtezested 3.n your statement

that says that they are a conservative zznagement organ].g@-

tion, tough ~~. dea3.Rag with the issu s which ~6 to create

IL

mpb6 an e~aPRQGion oi LLLRQPover reQQ2.z'QKBQtae

'Ts ™Mais a GgpkM68m pe Rap8 for 88/3.Ting that

the+ cLz'e rather ~~ght~H stGQP

(~~Loess Xang) 3: mould saj'Qlat that ~8 a rather

tvpica» feeling or an exgzeasion o8 management c~ncern in'ader mrna. The very at andar8 oz concezn that Coy have 9.8

~ 'one vhex~y they Geest @mt oz'gan'sationallp they must 'e>cpan8

'numerH,cally &e people to do a gob, an6 this has ""eon 'oneOP.''.the

pretty universal concerns OZ al3. licensees or n'any

Z<cen~~ses„ a+ ~6aGty SD the Graa oC QKp Because v~~

ERef93KLtelp'gÃali~~p assurance zeQuirGiMQts have reau2468

expansion of am+2. Xt g neceSSar J ancL Vi3Lv 'Pi coal n

Zn other words, ve fe3t 3.~Ra they must, 2m

cenvince6 anrl asourred xzcn the9.r uncaezatanciing ance LQCBr-

pret tion of recpliramanCs Mat carta'.n thhnga a e ~cteack

P7

n~asaazy. ~Md 2: Pan't rea3.1y disaarae iud.Qh 8.C. X th~'i" I vere employ~~g people X meuM want to aalce 8'ure'hat,

FP

X 'understoocL the zacp~<reamnhs am% honestly couM evan.use

tLle man~~ver needs to de .hhe gob

Q So i vouXQ 88LP +~t, +cur GQ~MN4v~ <BLen~ Mo Kng~

'Ls ~diat iC 9.3 not a GQphcELLM for 8 sore UQZGvozv&XG ~tQ3

s BRactl'p 7'ihat pcu %sante'

'.".ha+'a mlitt X xaam.

Q Hogg Shout pcu y 1M'Qzice'P Did% <pou ~ vQre pu

~3.ac+Mng no~ polite 3.m~gs than you migs hme u'ao'd

mbh7 among your colleagues hack .~t the of"iced

(TrFitness Dance) Ho. X'd go along with what

Hx' LQZLg said a

Bave either of you caressed this thought inother texH18 d

jk~itneas I;ong) Ffe3.1, one thing: When you'em eting vi~W management, I have to say the meet~~ags are very

candid, particular'.y "when the matter is enforcament. And

ve have soma pretty good meetings —9.t gets pretty h'ot attimes —hut va hav never had any pxob3.6m with an ahsence

o professiona'iam and cooperative attitudes between people.

ARQ '|Quid expect meetings par»icul~~ly WIhen

the result o a meeting might result in expansion or drasticch'ang'e in procedures or the +ay of Going business. So

l

those meetings could be —Prom hath sides of th'e fence Z

'Kink they eftm ~e very tough in presenting positions,

'debating the issues, and at some point,„of course —X

@on't say that +We Ca~~ssion altmys vz~~s out, hut ve feelXilce vs hzLve hewl vex'p'irm in cur positions and olhsn the

. 'decision an various matters o8 enforcament have been debated

by the MPZ, va've had no f~Wer prohl m in resolution

Th .t 9.~'t quite my question 7%v cpxestion was

a narrover ane about have you azprossed the idea about

ugh in dealing riliQl the issues Chat tend to cr~™sate an

e'"pansion of manpover reqciremants, have you emp essed that

2974

mpb8 idea in other tems, zo - candid terna LLS you mightstate2's

o Dance P

(Pitmeas Dance) Zf I may add, ch, y are an

'oz'ganication Chai s net @each to agzee 'o a combed.t ant that'

going t'o ~.G inc@eased p opia unless 9A can he showa that

Mex'G is Q zegQXGCQ~ TQQQxzPIRsnt o~~ '818LG is a need e': m so@'xy, I don't th&dc ~you 11nde=stand my

'~~stion+

7"g question +as a a3zrg.';er, one. 3r.d any time that

~ IJ 'I ash, a guestioLL oz anybody asks a cuestion in t"Lis hea-ing

'+&at'ou Ch~yjc zequfzes gute@ G1Lpganagion p "you ze going

to Itive Chas cpgoz~un it/'o

3Q z ght ncaa 1'QGstion 98 mlxch ROFQ QcLRX'cKf

Save you geni.Roman ~~zest this term, this

hhmzght that CPGZ ~~pr sacs us as a conse~tiv management.

ozgani" Moa tough in deakiL".g <8th the issues 4h=t hend toP

'c>mme e 9anaiou o+ >anPavar z~~ementso has~ you expressed

'%hi,s in moxa candid MxmsV A;xd than you can ~plain. 'utI

~us4 te11 me iZ Mat 's the case.j

3. (NX eels hong) X hh zQc M. Dance's Point, X

~ +gzL

X 'boQ16 Qg GG 'lfith t'.Lani and Ma 8 not Bn U lxslQLl

posi ~on p Co 5B coILce Qed'hout

~g t44'ii'

l

4 ~

l1

'Zkiv~ isn 4 LLOYD cPxest9.on at a3,le

BZ DRi X "DS:

a9t 24 tQ'A 8xpc ess UIQt the Chait!MQ is

mpb9 ~erg'to ask, i~ X may, An my Southern manner, 'ay Texas

'3 Back at Che o8~ice you must discuss CPS', and

7

you may not use words ~~ e "conservative management", and

you might use die "orant words, "Cough in dealing viCh them",

you might. use sinn'ther ph-ases. And Z th9nlc Che Chai~is'as!cing:

C

Save you ever expressed Chat thought using

d'fferent words when you veren'C ~v'iong Zonally, recognim-

(0 ing, for ezwple, Chat if you and X vere speaking on the

~ 4

street discussing +Wings om mould uf e an entirely d'.Merent

~~gurge ChKDl ~w''gould use ~hen ~ Nzite things ~ ~d X

<imuld e ~t that you md.ght have used a cKfferent phrase, isthat right'

(Nihresa ~~ng3 I'e used the word "cautious",

end aG

MadelonWRBXAON ~7flvs

pG

over cautious p and ~ ~

24

' v ~ ~ ~

1 c

!

Zoom/+biMade 3.on

2e 1

'«f

1

II

«W 4 fI«'4«slI

«.y «.1I"

~ «

2976

9 Mell, what does the word "conservat9ve" ~~en2

A Z >A xQc it ames Chat Way don't 3."Ne Co act

too abrupt y o- "us@ e~ve3y xi& the Corm9.s89.on's aos9.&eq'I

lay down and die, as Wa4 terna 9.s amer. Xn Pact, ve expectI

tbera to arne X~ 'Key have a pos9.49.on ~e 'ool" +or the

Q gQRQnt because Kc Itive k!8~~ 'strong 9.Q %3xhy CR88s ~ 3gd

ve fee3. l9.te this Xu consezvatkvep and iZ Chsy XMe they are

not w9.l3.ing Co go hLind3y or help3essly into a situal"on* . '1 ~ ~ «

~ »

Mat v9.13. pena--'"e %em over the 3.ong ha@3.r Wet 9.t'3 beyond

the actual rectukzmmnts. K». B~ce p-Mead Cant out.

X$E QMsr NQrdsq we have to CabatAl1 „Qp@yy spent

x) 50Ã clearly Chat nfl«XQ ~~5 Q z~Mz'GEsnt g Chc"lt Bort OZ Ch&g»

«

'I„8 ~ It

".n'V

BY CBrMHEGQl SMXT'I

Q What 9.s happen9.ng hera is, X'm aching cuest9.ems

=e3.ated Co language that's heing used 9.v. descr&9.ng Che9.r.

con$ 8rvat9.GAB ~ i'd I I 3.CORMg for l'Qnguag@ Gxld yc)Q x'6 g9.vying

zs angers Chat e:rp3.aim %e 'dea. wh9.ch 9.s impor~t, 9.t's11 ~

more ~~rtant +ban 8:e 3.mguage, X'I aure. Pack you'*XX hams

a chanc to do Chat. But I'm ceeR9.ng words, lanenzago.

Hav you ever said "Soy, they'xo t'ght Wth a

:,!)

.') ')

l~

3, (N9.meso Xong) We3.X, the management prerogat9.ves,

for CCCRQD3.G PDGre are CaTO tp088 oh Q<43,9.ty 3iaE!hgQRGZlC

Q X Rl sor~~j 3 hut you gGEhtXQRsn are Riot Ming

raspons9.ve to my cn:.esMon. X:at'o 3.et 9.t go,md loo'c et She

~ «1

11

2977

wb2 ,transcript befoxe you'cme, and then X'XL ask the question

again nest 'V88k s

X'm loc1ing for expressions Mat you have used,

acids Mat you nave used or that in She ~cm'se of you3.

employment you have hoard used which describe +Me" conservative

management raZeE'Wad to in you'll'es~~.ny. X'R not OSIt9Jhg

at &i,s time for aa addition@|. expJanet9.on. Ybu 4'avedebat chance.

.p,I

X +ant voids.

So you insider @mt. Mayhe you e~ geO, some

heLp fTcGQ coGQ861 %ho DLLgM Qxp3 Gin +NG dix'ection of ny

gusstiozd.ng.

f'PA~HKQS Si4X9,'H~ Xt~s about the time f>aLO He

:5 Xno dontally, Z don't @ant to put -- i'cuM'not'he fair for me to put words 1ihe "tight arith c ha&" into

your sd.nds. But cto you understand vhat X mean'P

~ ~

NZTMBBS DMCE: Ka mi3,1 address it, sir.CHiHÃ4DH SNXYH: Xt ia no@ the time Me had indi-

gp. cRCGQ ~w voQM ad)ourn

NR. REXS: Me. Chairman, X incg6red about gettingWQ person %he os''Mfits oz'%ho Gppzoves %1ec4" f8LWXitiesg

x'eihlXyJ it 0 a ipiesVon of Approving these ZccilBmes'o AQQ

Z've been informed —hs's Qre only one in the Atkmta

offic ~who :';as .".caked at Wia -- tha'- ~e'a go'ag to Secpxoy@h

29'78

ae=C ~reek to ta~=e a group of ~nspac',;ox's v9.th him to educate

thm up Sera at Mguoyah. 3ml this hm been pXauae8 2oz

soma the aaP. ha'XL hs up 5.e2.'e a13. week.

I'e '."uethez'eea 9.zfonzea Mat, ves, .he'as

approveQ —"c C3. "ed" X con't think Ls the xgh'ox'6—G'hat they're 8oxmg. Ze's m~o2.'sase8 viM the PacLX~C).ea at

Sheazoa Haxxis a@6 has ce~ %fied sevm'a2, people, aacCor

operatora +ho have gone thxough the faci2XCJ, ccE'&Zial them

I)1 ~,,I

a4i!

/ iI s

II~ \

~ I

.n, i! ~

lf

~s reactor eperamra> raMez Chan the Sac'XX4y XhneXP..

Xt xou7.6 he a great harden'+o hz'ng h.~ hex'q efCh

4hZ'hort moCies.

~~ 7KK7 S~LKH." Aai if ve iuurrmpt h9c C ip to

Seguoyah our „"-opukariCJ might even»-

-..-: i;OI ~

i8',i~ ~

g aj

~ Ilki

~CP «MX8. --he worse tham it ia.C>MZRKH SNXTH: Me see ao nee6 m< Chat. X '&'iak

ve can xaach it +his +ay:

Eow about aa affMavS.t suj.miMedP . Ne'Xl zeoysa

tha record to accept his aZHQavit. Zf «t pi. seats any

+9 I

IIl)

nov IjI)II

a669.hiemal pzob3.cps ~re'Xl @wry about it than. But vhea he

comes hach xrcm his C=ip-

YR. MXG: He also vii3. have people tea iZyii!!.g

ggcoggs on ~$.3 mat~~~ @~t veelg

caz'e of "t~

g l~

4y

2979

nine o'cloak ~a=-sc"ay morning, anQ ve vill he in ~she Gx'aunts

Juzy reom on @ha eigh41> f3.oo .

(MRSZ'SQQF Gh 3. i35 8 N ~dl8 hCCLMg in 458

above-ant:itched amCCer was x'ecessed, ~o zecozivcine

at 9."00 a.a., aesctay, 6 perch 1979 '

lO