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special feature
Nuclear Regulatory Commission Inspector General Interviews re: Davis-Besse


The following documents were obtained by UCS via a Freedom of Information Act request of the Nuclear Regulatory Commission. The documents are the transcripts and summaries of interviews conducted by the NRC's Inspector General and FirstEnergy managers and staff about the events leading up to the decision in late 2001 not to require the Davis-Besse nuclear plant to be shut down for safety reasons.

All of the documents are listed below in chronological order followed by key excerpts identified by UCS staff. Each document can be fully viewed and/or downloaded in PDF format by clicking on the highlighted title.

Interview Contents:

05/15/2002   Transcript of OIG interview with NRC Davis-Besse Project Manager (32 pages)

OIG: What was your recollection of the NRC vote on November 28th? Staffer: "Most of the staff felt that the risk-based argument was strong enough to allow them to run till February. There were two individuals who didn’t feel it was... They were really concerned because they said, You really don’t know what’s inside, underneath the reactor. It’s basically a guessing game as to where it is." (P9, L3-13)

"Once they took everything off you could see there was a lot of brown rust. A lot of people said that was a surprise. They were expecting this white blanket of boron crystals and didn’t see that." (P11, L18 - L22)

OIG: "Was Region III involved with the Bulletin and how Davis-Besse was responding?" Staffer: "No, I don’t think we - - at least I didn’t have any contact with the Region. I don’t recall. You know, looking at the e-mails and correspondence, I don’t think the Region was involved with it." (P23, L25 – P24, L6)

05/16/2002 Transcript of OIG interview with NRC staffer who authored Bulletin 2001-01 (48 pages)

"When they [D C Cook] did inspect [in January 2002], they did a pretty comprehensive inspection. They really didn’t find anything." (P7, L5 – L7)

"Davis-Besse resisted all the way. They did not want to come down by December 31st." (P8, L3 – L4)

"In Davis-Besse - - there - - there were a whole series of meetings with Davis-Besse. Okay. And they - - some late at night actually and they - - they basically fought and clawed every inch of the way." (P8, L21 – L24)

"We also looked at some videotapes that they had taken at previous head inspections and - - and saw what I consider to be unexplained boric acid deposits on top of the head, okay, and which was never explained." (P9, L1 – L5)

"But, this [the high uncertainty about the risk numbers] was the basis for - - for my vote to shut Davis-Besse down and make it look. Okay. That and the fact that every - - they were the last of the B&W plants to look." (P11, L5 – L8)

"But again, at a meeting like that with your boss and your boss’ boss’ boss presiding, it takes something to raise your hand and say I think, you know, should shut them down and then you pose the question as to why you think - - the way you think. Okay. And I mean I don’t have to explain that further, you know. It – it – I felt strongly enough about this that I thought they should be shut down." (P12, L24 – L8)

"I know Jack [Strosnider] reluctantly voted to let them operate." (P13, L19 – L20)

"Given the track record of the B&W reactors [with regard to CRDM nozzle cracking and leaking], okay, these numbers [the Davis-Besse core damage risk numbers by the NRC staff] to me were virtually meaningless." (P14, L17 – L19)

"And also a lot of people lose sight of the fact that in the PRA you have – as – as opposed to a deterministic analysis, you actually need more information. Okay. And they really didn’t – we did not have sufficient information which is really why wanted these guys to shut down and look." (P16, L4 – L10)

OIG: Why wouldn’t a licensee want to get an order issued to it? Staffer: "Well, they could, but they’d get a black eye. Okay. Might even affect their financial rating." (P23, L7 – L9)

OIG: The licensee came in late November and offered compensatory measures. Staffer: "Well, one should put compensatory measures in quotes on that. Okay. I mean are they really compensatory? As I recall, no." (P24, L7 – L9)

"It [compensatory measures] was window dressing. Okay. Well, he said we’re going to do this, we’re going to do that, but what’s the net effect of it? Essentially nothing." (P25, L7 – L9)

"I believe that there were very few of the Commissioners’ assistants that would want an order issued. Okay. It’s just not – it’s – how many orders have been issued in this agency and for what? Okay. There – there’s all kinds of fallout." (P28, L12 – L16)

"Well, we had private discussions and I got the impression that an order would never be issued." (P29, L12 – L14)

OIG: "Are you aware of any attempts by the licensee to influence the Commission’s decisions at all?" Staffer: "Yes." (P32, L6 – L10)

"I don’t know if REDACTED showed you a picture of the head with – with the boric acid flowing out of these weep holes or not [i.e., the infamous red photo]. Okay. If I would have seen that and the color of some of that stuff involved, okay, yes, it – it would have been a different result." (P39, L3 – L8)

"Oh, hell yes, they [FirstEnergy] knew that [chipping away boric acid with a crow bar, and rust-colored boric acid on the reactor head]. They didn’t tell us though." (P40, L7 – L8)

05/16/2002 Transcript of OIG interview with Unknown, NRC OGC (48 pages)

05/16/2002 Transcript of OIG interview with Larry Chandler, NRC OGC (20 pages)

Basis for order – "…it was not satisfactory to go beyond that date [December 31, 2001] and so an order was a necessary vehicle to do that." (P5, L21 – P6, L2)

"…yes, the significance of the date [December 31, 2001] was clearly the issue." (P8, L1 – L2)

"I understand there was briefings held here and/or in Washington with Senator Voinovich’s staff." (P14, L11 – L12)

05/20/2002 Summary of OIG interview with NRC Region II staffer (2 pages)

"…said that with the findings at Oconee it became obvious the industry’s efforts related to vessel head inspections were inadequate." (P1, 2nd para.)

"…stated that NRC does not have the tools to conduct proper inspections of the reactor vessel head for leaks around the control rod drive mechanism (CRDM) penetration. While he noted that visual examination of the vessel head was possible, he stated that NRC personnel do not have the required qualifications under the American Society of Mechanical Engineers (ASME) code." (P1, 4th para.)

"Based on his experience, REDACTED concluded that it would have been unlikely for an RI [resident inspector] to have identified the vessel head degradation at Davis-Besse." (P2, 1st para.)

05/28/2002 Transcript of OIG interview with NRC Region III Deputy Regional Administrator Jim Caldwell (18 pages)

"But beyond that, I don’t think, that I didn’t have any involvement, Davis-Besse’s justification or otherwise. That was pretty much between the headquarters and the licensee." (P8, L3 – L6)

"I have heard since that there were some folks in headquarters that didn’t necessarily agree, but I don’t know that there were anybody in this region that didn’t agree." (P13, L6 – L9)

05/29/2002 Transcript of OIG interview with NRC Senior Resident (8 pages)

05/29/2002 Transcript of OIG interview with NRC Region III staffer (15 pages)

"First, the NRC has a very, very strong position. I was surprised at that, that we had such a strong position initially, And the, and it seemed like we were proceeding down that path as an agency. And so then when we, whem we kind of backed off as an agency, I was then again surprised by that because of the strong position we had taken initially." (P11, L10 – L19)

06/03/2002 Transcript of OIG interview with Jim Beall, Technical Assistant to Commissioner McGaffigan (32 pages)

"I expected that the order would not end up being issued. But I never opposed it being issued if the staff remained on its course, and the licensee did not oblige them in some manner or another." (P17, L20 – L24)

"There was something about Davis-Besse involving Voinovich. It could - - it may even have been in the same timeframe. Could it possibly be that they were trying the TAs with one arrow and Voinovich with the other to try to get attention? I don’t know." (P24, L9 – L14)

"But there was a letter - - maybe even what I’m thinking of is a letter that Voinovich wrote, forwarding his concerns or the concerns of his utility to the staff, or the chairman, and there had to be an answer." (P24, L25 – P25, L4)

06/03/2002 Transcript of OIG interview with Brian McCabe, Technical Assistant to Commissioner Merrifield (28 pages)

"Other plants, like the Surry and North Anna plants, that made the decision [to shut down for CRDM nozzle inspections] even though they didn’t have refuel outage, they were going to shut those plants down." (P5, L17 – L20)

"It’s just that if we, as a regulatory body, are going to put a significant regulatory action out, like an order, it has to be clearly laid out what the basis for that order was." (P6, L19 – L22)

"If you look at 1A, the staff on page ten of the draft order says that one reason they believe Davis-Besse should shut down on December 31st is it’s highly probable that Davis-Besse is currently experiencing pressure boundary leakage, and is operating in violation of its tech specs, and you’ll find that on page ten of the draft order." (P9, L4 – L11)

OIG: "To your knowledge, were any commissioners - - did they have a particular interest in this matter [CRDM nozzle cracking and the proposed shut down order for Davis-Besse]?" McCabe: "I don’t think so. … None of the commissioner really stepped up and engaged formally." (P16, L10 – L24)

"I just don’t recall him [Senator Voinovich] actually engaging. He may have been engaged, but I don’t recall that engagement. He certainly did call. His staff did call me." (P23, L18 – L23)

"Did it [Voinovich’s interest] play any role in the decisions or the concerns, or anything like that? Absolutely not." (P24, L16 – L28)

06/06/2002 Transcript of OIG interview with NRC Director of NRR, Sam Collins (49 pages)

OIG: Why was the draft shut down order prepared? Collins: "Well, it really is a contingency." (P5, L3 – L4)

OIG: "Do you think the staff got to the position where it could make that argument [for issuing the shut down order]?" Collins: "Well, I think the direct answer to that is yes." (P7, L23 – P8, L2)

OIG: "So absent the information that was provided to staff on November 28 by the licensee … the staff was prepared to go forward with the order?" Collins: "That’s correct." (P8, L19 – P9, L1)

"The majority of the plants, however, I think took the right action, even though was in the midst of a cycle, to shut down and make that inspection." (P11, L7 – L10)

"He [Brian Sheron] did indicate to me that there were certain members of the staff that were, my words would be uneasy with the decision [on November 28th to set aside the shut down order], that they tried to reach a consensus with the staff that included all levels of the staff which I think there’s some argument to me made on whether you want to do that or not. … I do believe there were a few members who were not exactly in the same place as the majority which is we’ve made the right decision under these circumstances. … And Brian, I believe - - it may have been Jack - - I believe one of them had the forethought to say, well, does that mean that you object to us going ahead. …" Additional discussion of reaching consensus. (P19, L16 – P20, L8)

"We told them that, if necessary, we would order the plants to shut down." (P27, L1 – L2)

"I believe I also had a direct conversation with Mr. Saunders." (P27, L13 – L14)

"I think there were still members of the staff who would say that if we felt they had leaks in September, they should have been shutting down in September." (P31, L8 – L10)

"And our argument [for the shut down order] was based on the potential consequences that we felt like the agency’s position was to come to a conservative, what we felt like was a conservative conclusion that we had to know by the end of the year and the commission supported that." (P31, L23 – P32, L2)

"I got the impression that there was congressional interest in this. I believe I might have heard tangentially that at least one congressman was interested in this. Voinovich." (P34, L21 – L24)

"I think we had basis to draw that line in the sand. Can’t argue with the date. But I think we had to draw that line in the sand." (P49, L14 – L16)

08/15/2002 Summary of OIG interview with Framatome (2 pages)

On the afternoon of October 10, 2001, REDACTED said FENOC personnel were also preparing for a meeting with a U.S. Congressional staff in Washington, D.C. that evening. REDACTED stated that he did not know the name of the Congressional staffer nor did he know who the staffer represented. He … thought that the Congressman represented was from Ohio. He said he believed the meeting was arranged at the request of FENOC." (P1, 3rd para.)

08/20/2002 Transcript of OIG interview with Probabalistic Safety Assessment Branch staffer (152 pages)

"…but I had reached a conclusion that it wasn’t sufficient to make a good probabilistic decision at that point, that we didn’t know enough to really be risk-informed yet." (P5, L8 – L11)

"I did review their [FENOC’s] analysis and I pointed out to them in a meeting that what they had just said to the ACRS, for instance, about having 0.8 leakers in their plant, was not what their model said. Their model said they found 5.3 already and fixed them, and they hadn’t found any." (P10, L19 – L24)

"And they [FENOC] were also having a problem with what they were telling the ACRS about their model, demonstrating they really didn’t understand what they had in their model." (P11, L1 – L4)

"Unfortunately, most of the e-mails are, you know, already deleted, because I swept them up for Gunter’s FOIA in March." (P18, L1 – L3)

OIG: "After reviewing the licensee’s PRA submission, I get the sense that the staff lost confidence in its accuracy and value?" Staffer: "Well, we never - - I don’t think we ever gained confidence in it." (P20, L20 – L24)

"And that’s my belief, it was not sufficient at that time [November 2001]. We’re still struggling to get sufficient information together to make a reliable conclusion." (P21, L1 – L4)

"There’s a tendency to start believing that what you have - - what you can see, is all there is and to just manipulate what you’ve been able to cobble together as a model and say, what does that tell me? And not ask the question, what am I missing? Because I don’t know enough to put it in the model." (P33, L10 – L15)

I’ve got something in my cubicle over there right now where there’s a study of NRR to see if there’s a risk-informed culture at NRR, and the study was there isn’t one." (P33, L19 – L22)

OIG: "Was there a good handle on what risk would be reduced by not - - by accepting each one of those compensatory measures?" Staffer: "No." (P34, L19 – L23)

"I think I expressed [during the staff meeting on November 28th], you know, my own opinion, that it didn’t look like they [the compensatory measures] would really have much affect." (P36, L9 – L10)

"When Brian asked for a show of hands [during the November 28th staff meeting], and three of us said that we did not think that we should accept that." (P38, L4 – L6)

"I didn’t even take what happened as a vote. I took it as sort of an indication from Brian of where he thought people stood. … I was a little surprised, I guess it was the next day, when it turned out we weren’t issuing orders." (P38, L2 – L11)

"My sense of the compensatory measures was that they were largely window dressing." (P46, L24 – L25)

"I was a little surprised when REDACTED said, you know, they weren’t issuing orders. And I said, you know, who made that decision? When did they make that decision? And the answer was the sort of that I was there, but I didn’t recognize the decision was being made. I think the decision was probably made before that." (P51, L17 – L23)

[On the real decision-making process] "My impression is that there is a telephone call type of negotiation, if not a drop-in negotiation that goes on at upper levels, that may or may not involve the commissioners or the EDO, or Sam Collins, the Office Director." (P52, L2 – L6)

"We - - especially if we do something that we know will not make a licensee happy,. The joke is that, you know, they will have - - we’ll be getting questions from the Commissioners’ Tech Assistant in the morning on this, because there will be a very quick, you know, push back that may go through the various commissioners or the EDO’s office. And then we see it from their tech assistants, asking us questions that obviously came from the licensee." (P52, L21 – P53, L4)

"I had said in a public meeting [in November 2001] that their projection of having 3.5 [CRDM nozzle] leakers still in the plant would be reasonably consistent with what we’d expect from the other plants. We found that looking at the other plants, the statistics would come out to expecting something like 1 to 3 leakers at Davis-Besse, and about a 50/50 chance of having a circ crack at Davis-Besse. When they finally did the inspections, they had about four leakers and a small circ crack, so I mean, they weren’t different from the expectations." (P62, L1 – L12)

"I think what really went on with Davis-Besse is almost like what Dave Lockbaum [sic] said in his report. I think that the NRC does a lot of negotiation in which there’s a fairly strong element of bluff." (P74, L6 – L8)

"Since then [the November 28th meeting where he opposed not issuing the shut dow order], Brian has tried to bully me a little bit, saying since I didn’t issue a differing professional view, that I must have agreed with him and we had a fairly touchy exchange in his office about that, so he - - I basically didn’t back down and told him he needed to be very careful how he represented by position, and he left it there." (P112. L24 – P113, L5)

Lengthy discussion of broken differing professional view process at NRC. (P113, L8 – L23)

"I think what Lockbaum [sic] has brought up [in a UCS letter to Rep. Markey dated July 2002 regarding Chairman Meserve’s June 28, 2002, response to the Congressman] are actually misrepresentations and misunderstandings, and we pretty well wrote up a good response as to why." (P112, L2 – L5)

"I was pretty sure that it [FENOC’s information] was, you know, inaccurate and incomplete, and that was the reason my decision was to recommend that they not approve operation on the basis of that information, or anything else we had beyond the 31st of December." (P131, L21 – L25)

[Regarding impression from viewing videotapes of reactor vessel head] "I just came away with the impression that it was pretty hard to tell if you had leakage coming out of a nozzle." (P149, L16 – L18)

[OIG: If you had been shown the "red photo" in November 2001, would it have caused you to take any different action?] Staffer: "Okay. I don’t think it would have caused me to take any different action than I already took. And the actions I took were not effective, so I think the net effect on me wouldn’t have gone beyond me." (P150, L21 – L25)

08/22/2002 Transcript of OIG interview with NRC headquarters staffer (13 pages)

Regarding the videotapes of the as-found conditions from the 2000 refueling outage: "I’m told that they are highly enlightening." (P4, L1 – L2)

"What we were told [by FENOC on October 3, 2001] was, based on my notes, is that they did 100 percent inspection of the head [during the 2000 refueling outage]." (P5, L11 – L12)

08/22/2002 Transcript of OIG interview with NRC headquarters manager Jack Strosnider (87 pages)

"We [FENOC] can show that we can drive the core damage frequency down by a factor of 10 or something like that [with a dedicated operator for ECCS switchover]." (P10, L18 – L20)

"I said earlier, from the Licensee said, ‘I think we can probably show a factor of 10 reduction,’ and my recollection is that was pretty much we assumed when we went forward with the analysis." (P13, L9 – L13)

OIG: "If you received those two commitment alone [temperature reduction and rescheduled outage time], would you have been able to make the decision "I feel comfortable allowing them to go."?" Strosnider: "No." (P15, L14 – L18)

OIG: "If it had been solely on time and temperature, you wouldn’t have reached the decision to continue on with it?" Strosnider: "Right." (P25, L14 – L17)

OIG: [On the November 28th meeting] "You have REDACTED who is the lead for this whole effort, say ‘I don’t feel comfortable.’ You have REDACTED who has been working on this issue, say he’s not comfortable. And then you have somebody over on the risk side, REDACTED, say the risk numbers don’t add up. Yet, you reach a decision [to shelf the shut down order.]" (P26, L18 – L24)

"We have orders written - - I’m sure you’ve looked at them - - and they are basically written against the quantitative - - you know, the integrated decision-making process of Reg Guide 1.174." (P29, L12 – L16)

"Then you can look at it [all other B&W plants reporting CRDM nozzle cracks] and you can say did those cracks that were found, did they have margin? And what was found all had significant margin. … I don’t expect that I’m going to see anything significantly different [at Davis-Besse] than what’s been found with an additional six weeks." (P46, L11 – L18)

"If we had issued the order, it certainly would, on one hand, say, yeah, you’re a strong regulator." (P55, L5 – L7)

OIG: Is high likelihood of CRDM nozzle leakage, without absolute proof, sufficient basis for a shut down order? Strosnider: "And my answer would be, yes, it’s enough." (P58, L22 – L23)

OIG: Then why didn’t you issue the order? Strosnider: "And I think you have to look at risk-informed regulation." (P59, L9 – L10)

"It was driven by risk-informed decision-making, in my mind." (P61, L1 – L2)

"And what you see is a consequence at Davis-Besse that, well, wait a minute, this degradation led to another type of degradation, which we didn’t anticipate." (P68, L10 – L12)

"And I got a call from Sam Collins, who said, ‘I understand you’re going to be moving into a new role. I want to make sure you’re aware that we’re preparing a shutdown order for Davis-Besse.’" (P34, L14 – L18)

"And I was shocked [by Sam Collins’ call] (P35, L11)

09/03/2002 Transcript of OIG interview with NRR manager John Zwolinski (72 pages)

"I remember the full ET [Executive Team] buying into the order philosophically." (P4, L8 – L9)

"I never felt we had enough technical basis to shut the plant down." (P5, L8 – L9)

"In other words, if these six [B&W plants] have been inspected and you found cracking, then can I not hypothesize that the seventh [B&W plant , Davis-Besse] would have it? So with that hypothesis, that’s the meat of what the order actually was containing at that time, was we were basing it on information from other plants, not on any knowledge of Davis-Besse, or of the head." (P6, L11 – L17)

"We then, in the dialogue with Davis-Besse, had additional information, and we began applying risk insights using Reg Guide 1.174. And are they meeting - - we’re essentially using the five criteria of 1.174, and we’re asking where are they at?" (P8, L2 – L6)

"Would the licensee want to challenge us in court, and where would that go? My reading was, the licensee could push back if our sole basis for this order is predicated on other licensees, not on them." (P10, L2 – L6)

[After OIG showed him Jack Strosnider’s e-mail dated November 8, 2001, about his conversation with Guy Campbell regarding high likelihood of CRDM nozzle leakage] "In this room right now, that would be enough for me to start pushing on that order, saying that somebody warned you of the seventh plant." (P13, L12 – L14)

"I mean, somebody has to wake up and see things here, when you’re talking to the licensee." [in reference to Jack Strosnider’s call with Guy Campbell about leaking CRDM nozzles] (P13, L23 – L25)

[Again, referring to the November 8th e-mail about the conversation between Jack Strosnider and Guy Campbell] "I would have extracted information such as this, and that would have gone in the order, in the basis along with the ammunition of other B&W facilities, and we’d add to that acknowledgement that based on, what the basing is phrased on, that they feel they may have a leak. It’s kind of like that breaks your back. That essentially says they’re guilty, and gee, it may even be leaking." (P14, L4 – L10)

"My impression of how Dominion handled North Anna and Surry was a licensee that understood the phenomena, and were sensitive to where their plants where, had not performed these inspections before ever, and they were going to go in. And look, it sounded to me like they were going to do the right thing. And they chose to do what they did, which was viewed by the staff, I think, as positive." (P54, L9 – L16)

OIG: "And would you say that Davis-Besse didn’t choose to do the right thing?" Zwolinski: "Confronted with the evidence that we had, other like plants, and so on and so forth, I would say that they did not choose to do the right thing, regardless of how everything has turned out." (P54, L19 – L25)

OIG: "How did it [the shut down order] make it all the way up the chain then [if it lacked proper technical basis]?" Zwolinski: "My view is that we have had - - we have a senior management team that’s very capable, but we may not be as robust as we were one day before. Sam Collins has an inspection background, not a licensing background. Jon Johnson, the same. Bill Borchardt, the same. So three of the four executive team members really don’t know much about licensing." (P60, L16 – L25)

[On defending against licensee’s contesting an order] "If I’m in a hearing, I’ll write ten, twelve, fifteen pages, maybe twenty pages of additional materials to fully explain, cross every T, dot every I, as to why the action we’re taking is the right action to take." (P64, L19 – L23)

"I mean, Davis-Besse is announcing we’re getting ready to start our plant in December, and this and that. How can this agency have faith, trust, and confidence we’ve got the right anything from that facility? I mean, this kind of thing shakes me one hundred percent. I mean, you simply can’t work that way with a regulator." (P67, L14 – L20)

09/09/2002 Transcript of OIG interview with NRC Director of NRR, Sam Collins (84 pages)

"At this point [November 21, 2001] we didn’t have enough information from Davis-Besse to substantiate their operation beyond December 31st." (P9, L16 – L18)

OIG: "According to Brian Sheron, he was directed by you to contact FirstEnergy to see if FENOC could commit to anything other than continuing at full power until March 31st when it was regularly scheduled to shut down." Collins: "Right." (P12, L8 – L13)

"The decision-making process that we’re in was both a technical and a risk-informed decision-making process. And we were using Reg Guide 1.174 as guidance to the risk-informed decision-making portion." (P15, L10 – L13)

"We did not have the basis to shut the plant down." (P18, L25 – P19, L1)

OIG: "Are you saying that on the 21st of November it was the staff’s position that it did not have a regulatory basis to issue an order?" Collins: "I think it would be my position that at that time I didn’t have the basis to sign an order, but we knew that there was more information forthcoming in order for us to make that decision." (P19, L13 – P19, L21)

"I wouldn’t put undue emphasis on the order because Davis-Besse would shut that plant down without the order." (P21, L8 – L10)

OIG: "…we’re still basically almost negotiating information." Collins: "You used the word ‘negotiating.’ I wouldn’t use that word." OIG: "Those are words given to me by the staff." (P34, L17 – L25)

"We were in a process of hearing from the staff that they were having difficulty getting information from the licensee. That’s the basis of the Brian Sheron calls. That’s the basis of myself talking to the organization to be sure that they knew that we were going to make decisions and we were going to make decisions based on the information that they presented to us." (P35, L15 – L22)

"I would submit, although I wasn’t in the room when the decisions [on November 28th] were made, when the consensus came, but the compensatory measures are not that significant." (P41, L6 – L 9)

"All of those types of things [compensatory measures], that’s nice to have and it may be enough to move some people to from one place to another, but when you get right down to what impact is on risk and significance, it’s not that great." (P41, L17-21)

"The Reg Guide 1.174 decision-making that included those mitigating actions is really, to me, just a way of ensuring we didn’t miss anything in saying if this plant were to continue to operate." (P41, L25 – P42, L4)

"That’s the whole purpose of the Bulletin [2001-01] because we suspected that there were plants that have [CRDM nozzle] leaks." (P51, L6 – L8)

"Everybody knows that the plants potentially have leaks. If they didn’t, we wouldn’t issue the Bulletin." (P51, L11 – L13)

"And that’s why we came up with the December 31 date was to provide a date that was prudent for us to come to a regulatory decision and for licensees to provide the bases for which they could continue to operate." (P53, L7 – L11)

"That’s why we didn’t let them operate until the end of the cycle." (P53, L25 – P54, L2)

"It’s arguable, but there’s an argument to make that forcing a licensee into an unplanned outage early has risk associated with it that you had to balance against that plant operating for the extra 45 days when they can plan the outage, plan the work, do it correctly." (P66, L16 – L21)

OIG: "When you say external [interest expressed to Chairman Meserve], what was your impression it was external?" Collins: "My impression, we were talking about elected officials." (P70, L22 – L25)

"All that aside, they [Dominion] made what we believe is a prudent decision and for that I think they would be remembered as a licensee who tries to do the right thing." (P74, L16 – L19)

09/12/2002 Summary of OIG interview with Framatome staffer (2 pages)

"FENOC was preparing to brief representatives of U.S. legislators that evening [October 10, 2001]." (P1, 3rd para.)

"FENOC met with the staffers to educate those individuals that had a vested interest in the future of the Davis-Besse plant. He confirmed that representatives of Senators Voinovich and Inhofe were present, as well as a representative of the office of a U.S. Congressman for the local district in Ohio where the plant is located." (P1, 4th para.)

"He said they also noted that FENOC was prepared to contest a shutdown order if issued." (P1, 5th para.)

09/23/2002 Summary of OIG interview with FENOC VP Guy Campbell (2 pages)

"Campbell said FENOC personnel met with Congressional representatives on the afternoon of October 11, 2001. He said FENOC staff first met with Senate representatives (Andrew Wheeler, Marty Hall, and one other individual). He said FENOC personnel then met with Congressman Gilmore (%th District, Ohio) and his staff. … Campbell said he would not be surprised if Senator Voinovich (R, Ohio) telephoned NRC Chairman Richard Meserve a day or two after FENOC’s meetings on Capitol Hill." (P2, 1st para.)

09/23/2002 Summary of OIG interview with FENOC employee Dale Miller   (1 page)

09/23/2002 Summary of OIG interview with FENOC employee Steve Moffitt   (2 pages)

02/14/2003 NRC response letter to UCS FOIA request (1 page)

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