ML18353A304
| ML18353A304 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/11/1976 |
| From: | ACE Federal Reporters |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18353A304 (351) | |
Text
Records Facilities Branch (2) 016 Phil i, ~
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: 4~sj THHiMSSEH VIZ LET AUTHOMTY r ~
Ma~Ret Hos. 50-259
{Browna Perry 51uclear Plant., 26Q Units 1 ancI 2.)
place - Huatavilla< A2.abama pate ll August 1976 P age s335 492 4~4'i JMx -a ~
~ Telephone'.
(Code 202) 547-6222 ACE - FEDERAL REPORTERS,liVC.
Official Reporters 415 Second Street, N.E.
Washington, D. C. 20002 HATIONWIDE COVERAGE
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20
A CO?TTENK'S NXTiCEBSZS QZRZCT CROSS iMDXPNCT MCROBS BOABD Villi;Goal Z Qadi>gz 34K 343 38n A QBil't ) 389 H. Z. Green )
Sack, R. Calhoun )
JCBn L ~" Xngll76Z88n)
Norman C. &Ioseley) 405 423 453 CEGGS'2.QG w i~JDxpDy)
Fx'Rn¹~8 a7 ~ Long)
TH.111am C. BeMle)
ZQB6pQ V o 7'7QiBbac12 Bcn i%>> CcLQC A. Z. Gxesn )
Jack R. Calhoun
'oWB? Xu ~ Zzlg:lQXGQD H;.HZBXTS XDZNTXPXPD Xi~I EVXDBizTCE Hcna
QHQT19@11 'f~XLL", "co@ Moz21ing 6"-e a'"Q gent..emen.
The hearing zoom vill please co-.a to oraez.
This morning fee are starting the eviQentiaL~
oo "o d f this Dzoc -sQing
'C ox'eliminavg matters or a'ot3.o~a g
Do we have any befo'"e 'r;. get unQe~~zayP (Ho response.)
he p.r none a 313. right ~ Do 4'e hN9 8'~ cpeni ng stateLqeE sp TVA'?
MP.. POi'1ELL: X think q Nr~ Chair1QPn g that 813.
ihree parties Qesire to make an opening statement. But With ihe Hoax'Q'a r~ewnission, X believe 'that ve ~.-ould Qesire each to put on our opening siatement inm; Qiatelv gzioz eo putting on our testimony~, so that Nr. Garner woulQ go first anQ then be followed by h's prepared testimony.
C'umP>M ~XLLY, X5 that . okay with you?
?~cR. GAK~IHR: I'hah's ~":ine.
C1i;KXÃ843 BEXLLY: Vgen, the first orDer of 63'$3.news g X belie~Jc p .0'Quid be TV3'7 1H. POViPLL: 21o, sir. X think.K~. Garner is ruing -"izst:.rith his opening statement anQ ken his Qic ct
337 case. He does have prepared testimony.
And chen YVA z~o~~ld go mich its open.'pg statement and.ox'epared testimony', folloved by the:egul tory 8 afx's opening statement and prepared testimony, ~zilch cross-a~maine-tion zo3.loving iruac.diately after each p= sentation of pre-pared testimony.
CHBXK~h>$ FCe,ZLXY: This i ~~hat the parties ag eed to l-9.. PQLfELL: Qes, sir.
CfP.XRV21 BHZLLY: " 'inc.
Hr ~ Garner P LB. CARER: Hy prepared testimony. -- wd in a
\
.little awhile I vill put 't in the record. Zt wi11 b brief and i,t vill pe brief for this reason:
P.long the lirie ve agreed to agree on agreed statement of facts. And this will be fom~.d in the TVA test~~~ny in the form of some charts. And vie sax no point in p'~tting it in my testimony or putting in a restatement of facts cold also pQtt2ng it in their 488t~hony i Ne are trying to avoid burdening the record, and that' vhy.
Mov part of my testimony xmas going to be a snort-hand zendon oz the,W~ .normal occnzrences. And Me. Pove8.1 of TVi~ ~>qd Z >roziied together 'on that, and 9.t develops that
33S most o. their that th:r>bnail discussion, chat shorthand rendicion of abnormal occurrences vias substantiall~~ agree-able ta <no in most things., and ~re co@,:u develop 'it on cross-e"cp~Aination ~
And as the Board knovrs, in Contention 3, ~i'e stip-ulated that X ~'1011M confine Ting case to C. 0 "s-QP~R~aining the NBC witnesses.
No>~r, b'."iefly, X would like +o say this to the Board. X J"noir the Board is mni3iar with this cas., but :
goulo, respectfully call ' to thei- attention. The Parley matte~,,the opinion handed down hy the Xiicensing Board in that case on the 24'ch d~y of March, 2.9"/6, and this ~ias a case >chere the Board re'tera'ced that a Board hias the obliga-tion and the author'ty to a~lore issues o8 sp ciao: concern that. have arisen during its deliberations, even though these iaatters have not been placed in controversy by the oait:ies.
be QÃpect things like this to Qr>ace during cross em~~.'.nation from the facts, and so. X respectrvlly Qz'av. Me Board s attent~ on ~co that opinion+
Now what it seems to me ve really have involved h re today is 'a matter ox opinion on what the Xnspection i and nidor ment program means and a matter oi opinion oq shat the si Qni'ficance of. an abnormal occllvrence is ~ And it is .
I'vxv13.y easy, X think, for the parties to run over and to de-cide @ha is really the Board's runo'on.
339 The Chaixll4~6 0'Z ~Mals Bov&d is an Bt>> orn'=v Bnd he has been in,tach-""inding *situations.
Dr coÃan participat6 "n ~9 ¹ OY'Brat~ on vL. cIIG famous Brook Haven RaI3ort, so ha L~o~;8 the problerls ox 3.irccle things.
Ea>Q X BI- not as ia3a~liaz EIith ~ha ok':.Br gantlm:Bn
bacicgzound Bs 1 BTA Dz' CGvan 8 ~ Dr~ Co+MR ~<BS onG OZ tIIe Boa-d lac'fiioezs n the oz'3.g" n81 Bz'Gitns Fe'Fiy opBrat3.ng per&it Caso e And hc c.~ressed some opinions &ere.
Mors it seen to m"- the-" what va a~e going'ta.,rund here i - ~ARBt you 1!13.gh ca11 . N3.AQQ Questions ox 3.aif Bnd 2 act ~
Zmd we have =B fact-finding body Bs lIe3.1 as a crzasi-1=gal comauna1. ~4)a 't see!Ils to ma Mxat you Bze going to have to Bssul'18 thG position ox %That ~iM ccR11 the rcasonablc IIlan in common 1rvr and apply your conmon sensh and your e;e>arience
'co erhat these things IIlaan.
i'd .chat 'cestimony is going ta say: Ne11, somo-i3cdy had ."iloxQ BbnoiIHB1 occurrencGs" tII~I tv8 dich Nell, so vhatP:2 somebody had 28 "rrxcLs, parhaps it doesntt px'ovB that 3.t 3.8 good to 3.8t GOIABbcdp dx'3.vB Brou71d he a1as hc'd 25 vJzecfis ~
I RQQ H is go*ng to say ve did our /oh Bald vfe Bra going to do ou- job.
And something . want to emphasize v>3.A =esaact.
to he "nspectioB. Bnd EnZo cGTAGnt peop1e in Atlanta is this
That Qo matter how good a JQD they Qo ~ un 'ss they have the autho'y ~o cal.ry th ough on this i2 the J p remind Litem in Bethesda or Washington and nothing happens J then &48~ h lve not accomplished their purpose and that is p t of inspr cti on and enforcement ~
And l Con t thing that it is s
unhea d o f for censing boards to bring things to the Commission's attention where they thi~ attention. should he dra:rn to these things.
Certainly the Appeal Board Goes cuite a bit, p'ayticularl~~ in thG case of MPLC e And: am going to reserve the rest of @hat X .have to say foe'y closing statement.
CHAXKRAN XCHXLLV,: Nhat Qo you plan to do ne.":t, AH. GABÃHR: To introduce my short, prepa ed testimony.. There are some things Z ~rant to cia"i'bout the TVA's testimony.
Z thin3c fir. Touztellotte and Nr. Po;dwell might have Some cfuestions +
CHAXB5~M. HHXLLY: Will you he svozn's .a. vitness, then. X think you will have to use the microphone and the tab2.e et up over there.
341 bazbG PTJlezeuponp F<XL LXZJ4 E. Q>KiZR
..ras oakley as a .m.tness qn behalf oX the Xntezvez.or Pzc 8-V axe"b'av'in@ been zizst duly miorn, "<as e".mai<~=.8 and tea "i Aed as .f012.ONS Tlirt ffiTNPSS: T. have here t>zo pages entitled "Prepared Tes-'irony o Kil3.iam H. Garner" the"'a." pzepaze8 by wee
'I e
X vou3.P. l~"J:e +o oF+er i4 in evidence at:rlxis tibiae.
ZW is short: 'f, 'me Board;.'ish s t:o zead .me ~ukl 'eescimnay iQEO elle record+
CDB.Y&KN REXLLT: He have read xt: 'so it ia not.
n'ec"=ssa >I ..s faz as ve axe concerned.
Do the o he= parties ~ash that-. it he rea8 into the xecorQV'iR.
PGWELL: Not W licensee.
'I KR. VQUP. KLLOTTP.: Ve would. waive the eading.
CKtZBNM'T RZZLXaY"- Does anybody hpve an Qbgect3.csz "s9 then to t2:e admission oz Nr. Qazrer's direc" CestiacnyP 20
?1 HB. POÃBLL: Rio cbjection.
CiaQKB"~ BEXLLY: Btax<'2 0 O'IG &Os GQ Qb .BC~-9.on ~
2'3 amer's testimony ia ad-mi..t~c'.4 in evidence, ~o be iz:corgoraMQ in the tz~scr<p~ a"
342 UNITED STATES OF AFRICA NUCLBLR. REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Natter of
)
NESSEE VALLEY~ AUTiiGtu.TY )
) .Docket Nos. 5O 259 (Brogans Ferry Nuclear Plant 50-260 Units 1 and 2) )
PREPAREO TESTDfONY OF MXLLXAFI E. GARNER
Pre ared Test,imonv of Ni13iam E. Garner-The Tennessee Valley Aut,hority, the Nuclear Regulat,ory Commission Staff, 4
and ';iilliam E. Garner, have previously entered into an agreement and st;ipulation in regard t,o this hearing. It. was agreed that. the" TVA, the Staff; and the Intervenor, would prepare an agreed statement of facts for Stipulated Contention 2. 't was further agreed th"t Intervenor's dire'ct case on, Stipulated Contention 2,would consist, 1
of Interve'nor's argument on the significance of the agreed statement of facts and the IE Inspection Report',s discussed in paragraphs 3 and 4..of the agreement between.
the parties.
1 All parties have agreed t;o accept Appendix 1.and, Appendix 2 of the Prepared Testimony of the Tennessee Valley Authority as an agreed statement of facts, In connection with Appendix 2 Intervenor states at this time that, the Browns Ferry Nuclear Plant, Units 1, and 2, are both Boiling '~ater Reactors. The following nuclear plant's're oressurized water reactors: Arkansas Nuclear 1, Beaver Valley .1, Calvert Cliffs',.
J
~
1, Calvert Cliffs 2', Cook 1, Kewaunee, Millstone 2, North Anna 1, North Anna 2, North Anna.3; Pr'airie Island 1, Prairie Island 2, Salem '1, Salem 2,,St. Lucie 1, Three NiLe Island 1, Three, Nile island. 2, Zion 2,. Turkey Point 3, Robinson 2, Zion 1, Connecticut Yankee, Indian Point',, Indian Point'2,,Palisade, Oconee 1, Oconee 2,
.ry 1, Surry 2, Point Beach 1, Point Beach 2, San Gnofee 1, Oconee 3, Turkey Point 4, Su g"in i" a'h 4l Rancho Seco, Yankee Rowe, Ginna, Ft . Calhoun. Ft,. St. gh temperature gas cooled nuclear. react, or.
In Appendi'x 4 of its Prepared Testimony the TVA.discusses the r~solution 'or status of start up and operational reportable occurrences. 'In appendix 5 of its O prepared testimony 4he TVA discusses 't.he resolution or status of 10 CFR 50.55 (e)
I construct.'on reportab'e def'ciencies. Since in most inst,ances Appendix g and Appendix' present. a fair summation of th occurro.nces, Counsel for the'TVA and the. Int,ervenor agreed that. it would be redundant and wasteful for the '*
Xntervenor to also present a short, hand rendition of each occurrence.
The par..'ave ai z-....i '..h: t the Staff wi3l present witnesses on Stipulated Contention 3.
Rather than present. argument; on Stipulated Contention 2 at this time, intervenor wil3 reserve his argument for oral argument at the conclusion of the hearing and "or his proposed findings of fact and conclusions of law.
UNITED STATES OF AMERICA Before the Atomic Safety and Licensing Board NUCLEAR RFZiULil'lGRY CGcfl'(ISSIGN In 'the Hat.ter of )
.)
Tennessee Valley Authority ) Docket Nos. 50-259
) 50-260 Browns Ferry Nuclear Plant )
(Units and 2) 1 )
CERTIFICATE OF SERVICE I hereby certify that I, have served copies of the following on the following by de"osi ing them in the United States mail, first class, postage repaid:
Prepared Testimony of Nilliam E. Garner Secretary Genera1 Counsel U. S. Nuclear Regulatory Commission Tennessee Vallev Authority
':i'ashington, D. C. 20555 629 New Sprankle Building Knoxville, Tennessee 37919 Th"mas ~~. Reilly, Esq., Chairman Atmkc Safety and Licensing Board Executive Legal Jirector U. S. Nuclear Regulatory Commissioi 'U. S. Nuclear Regulatcry Comaission
- ash'ngton, 3. C. 20555 4bshington, 3. C. 20555 Dr. Frederick .".. Co;;an Atomic Safety and Licensing Appeal mard 22 Bro'nels Lan e U. S. Nuclear Regulatory Commission Be lport, New York 33713 '</ashington, i). C. 20555 Nr. Frederick J, Shon Atomic Sa ety and Licensing Board U. S. Nuclear Regulatory Commission
'~'ashington, D. C. 20555 This 6th day of August, 1976.
William E. Garner Intervenor orc-se
3~33 l4R. GZK~iHR: Z ha';.e furnished U~e ra@or" er cop>>es.
CH j~ 'f GaV FQb XLw~ ~ Sk e Ye"e ready oz cross e3'chIlina-tion 2 TVBUr Poisell 2 ER. PO~T8L<<.. Yes, sir. X have just a few bxef plies t2.ons to as'z NE ~ Garner e caos'-zzwxra~TXnm BP NR. PONHM Nz. Ganmr, do you have any education in engineer-
$ 0 ing, such as nuclear engineering or civil engineering, mechanical engineering or electrica" engineexing2 l2 have no forBlal engineering courses ~
Do you have any experience 'n the field of en'-
gineaxing, such as el ctrical, civil, nuclear, mechanical engineering2 P,
Ho.
Do you have any ezperienca in working at an oper-E 18 ati>xg nuclear plant2 No.
20 Do you h'ave any m~erience 'n ~uorking in the cons-"'"uction of a nuclear p3.ant'?
22 Zo.
- g. Are you familia-" <rishi Regulatory Guide 1.16 erititled, "Reporting of Operating Xnfo~m>ation,"'.thin AppenQi:c A, Techn cal Specifications, sir2
3/~a\
X c 'Q c~&ia. e 0- the fact t11a~ t?'eze "s such a . - g-ulatione Ar.d in .--ocr propared testurcny, you have listed several pressurized v te reactors which ";rare gleaned from append9.z XX of YVA's prepared testimony in he proc eding.
Does your listing of pressurized eater reactors in your pre-oared test lmonp'nclude al 1 of 'tie pr6spul ized Pater zeac~ors in <21at Appends 'X2 X am not c ztain of'hat, Nr. Poivell. X believe does~ Quite fzmQcly, my purpose in doing this was to get a comparison from the charts on those that had m~y or more abnoxm@1 occurxences than Brains Fez~. Go X dzev a"c least 4'leis that far ~
ThRQti you o Xt is your contention, Mz. Garner, that Brans Perry Units l and 2 have had an unusually large nulp58r of abnormal occuzrenc s. And it "s your conc ntion that. this demonstrates Qhat TVA pe sonnel me incompeta. t. Xf me assume that, the contention as "o the unusually lm~e number of abnormal occurrences is correct, is it your conclusion hat the incompetence of TVA personnel is the only conclu>>
sion that can he dravm from those numbers of occuzrencas2 Xt mould Qep nd on the occur ence. XC might he General Electric's personnel or the vendor's personnel, but 'eztainly tDd.s is TVA s u3.timafe response~ ili"y.
Xs it not possible to concluae that a first rate (Jua ity assurance program cou3.Q z'GSQlt 3.n QB.sco: exing many events that ÃoulQ Ve resorb eQ as re?ol.talel occur l ncesP Hhac. X KfoQM call a first ~
ate quality assurance might result in that There aze plants in the tW~les in XZ to i' many.
s pre pared testimony
'I 1 at AppenQi>:
had reporter% sero abno~a l QCGQr rences XS it not possible to conoMe that the p" ant that repozteQ no occurrences at al3. could have done every-thing perfectly anQ just. nothing went vrongP hat s possible i Oil 'che other h&~Q ) it UoUM 58 possible co conclQQe that they waxen' looking for abnormal occurrences, or that they weren ' repo"ti ng th~~.
bK. POÃELL: X have no further questions, Nr.
Chcd MQan i CM XRbQN HEX ."MRC Staf f2 ICz . Tourtellotte?
BY HR XOQRTHX LQTTZ:
g., Do you recal 1 a conversation that we had, you and X, mahout your looki ng into these various matters and do you recall the time Mhen X offared to you to provide the Staf f at you disposal for inquiry into these various matters2 Do you recall that 2 a
You I1a."e to ctefine various matters H . Zourte 1 lot t Q, Do you zecal3. the convezsati on that you ana X had A~ileze X to 8 you that if yoQ haQ aPPj members of the Staf f that
you wanted to talk tc Rout this case 'chat would he3.p you in Qiscove+~ that X )TGQ3.6 sec tha c those Sta ff meIp3)ebs ve '
,bros lt tc Scot sbo) o p Qr.'d X be liav in response you said that that s 'a matter of fact ~iouldn t be ne= asa p, that if. you want 1 to ta33c. to the Staf that you could come to Hashington, 0 ~ C ~ 'P Do you zeHlQMieà that conversation?
Yes, i rammaber it.
And sabstanzially, that.'s the tu.nd of conversation V
"re had; mncng other things' think conversation should be taken in contez ir'.'zurich"~clou filed an objection to almost everything I asked you on rrritten interzog"tories. So there is always there was some don>t in my mind before and soma doubt in my.. mind-,
especially after that, at tha time of .the qu s.cioning, that yourpeople would have ansvezad had th~ been, even iz you had made them availab3.e.
But X did offer to mal".e all those witnesses avail-M~le to you; Qidn't 2?
ile3.l, once again, you w9.11 have to 'ctaH.ne avail-able. Lhat's the phrase you use.
hat is the phrase X users 3: believe you can ask them any hing you vant to.
X don't he3'eve you went on to say they x<ou3d answer all mJJ questionso Gubseauent3y, though, you didn't really ask me
to present ~:.hose vritnesses to you; did yog7 No I~SR. TOUM~~HOTL-"". X kcvfe Qo other cguestions.
CHiAZB&ie~ZV BEXX:LY= H.". Ga~er, Lh ~ Board has a coup1e. of cfuestions BCABD L'r~XNATXGN BY CHM.H'~1M BHXL~~Y:
- g. Du ing Mr. Pcae3.1',. examination, he mentioned your 5 ~cgrounC and e::pertise in certain engineering areas. And one of your answers @as that you had no fozza3..braining in &e areas 'a3"at ke spQci fied the engineering areas g ~
AnC X was >rondering if you haQ, any informal train-ing or e~erienc. in those engineering areas'o.
M.l r> gilta BY MR. SHOB:
Fir. Garner, your testimony see@is to consistent here primari1y of tbo things one <a a revers n1 o f the e"..ipulation. 3rd in view of the testimony of TVA's testimony.
And dxen you h ve a cen ral paragraph beginning:
A3.1 par ties have agreed to accept Z~ppenclix 1 c;Gld appendix' ~ ~
Xn .v'x'ch yo'" point. out. that there a-e a number 'of
~coors inaludad in Appendiz 2 that a e pre surise6 bo3.ler
- g. Xs iT. your position that t'le BzoHns Perzp plant should be rmpared against solely hoilincq ~eater reactors as far as abnorrual occurrence record is concernedy they vouldn't stack up substantially differently when compared against, a rai:." oS: pressurized and boiling cwater r-actorsT X vouM h'ave to go to my notes to answer Mat question fully. Z~d. I intend to reach it. On cross-ezaeina-tion>> But there are so~.e si'~uaJ~'ions in which tt.ey do not stack up ei t3le ':1'n Ne order iD chic?1 'lVrr. has pre-Qenl ed 'thGBli Q, They seel'o s ack up clearly in a middle >ray in a nlrb)ex'f 't11e situations that TVA outQ nes ~
Xo Mere any other reason for your having listed the pressurized eater reactors separately'o; J Qst, SQ 'ould lay a. basis for drawling a distinction on cross-ezamnation bet~seen chose BNR and ~J:ose NOR reactors.
l see+, Thank you ~
CHZXKQC4 BRXLLS: Mani". you, Nr. Gainer.
l>e have no&ing mo-e.
2kn~~thing based on the Board's ques~ons?
(h'o = sponse. j
('Ãi&aess e-cusec'. )
CELCXRlGxN R=ZX~Z: Ha@ in the order tha'c you agree%
349 to.g Krould the licensee then Qe 1MÃtP NR. POHCY~>>-: Yes,, s'=r that:s correct.
Nx'hai "vane Z Qa have a brief opening st - em~mt There are pro nuclear un~ts at Grosso Pervq Nuclea Pla>>t tha cannot operate, have not b en p rmltted to mag:e vary zaxch progress toward operation for the concern that op-eration may adversely affect the right of th Intervenor in
'613.9 pro~~~edkngo 4
'Set, X think 'z ere look at these contention 'nd Me lock at the stature of this proceed'ng right nav, Z begin to vender 'f it is not a sort of a strange proceedixig.
'I Stipulated Contention 2 a'leges that VVA pex-sonnel are not cc yetont to install'e fire-xelate'd medi' f:creations at, Brcwns Ferry because TV@ has had,an unusually large number oz abnozmal occurrences. The Xntervenor relies t¹ buclear d i. P on Lhe abnormal occurrence reports by Safety Zn ozraation Center, or 'HSXC, at 0&. Ridge.
~
41) 3:rant "'o note here that the Board in its Juno l0, 3.976 order zegazding disco>zery ruled that'the specific ab-nozmal occur ences listed hy NSZC are rea3.ly irrelevant to adjudicating the vaLidi.ty or" Contention 2, that it is only the total nvM~er o+ occurrences in ~rnpar9.son to the expezi~mce at other facilities. that 3.s in issue on Contention 2.
X th'nk that TVA's prepared testimony, which me'ill put on shortly, she:rs conclusively that Bzoirns Pertly has
350 barb15 not had an unusually l.zge nulnber 'of abnormal occurrences as alleged by ~a= Zntervenor. Testimony ~rill also shcw that the mere total nuiher of occur-ences is"by no m ans a cri-terion by vhich to judge the competence of the personnel at Brogans Perry, nor for that matter', any other 'nuclear plant.
By contrast, the intervenor's prepared testimony and, in fact, non, the intervenor has completed his d'rect case, consists of about a page and a half and reaches no conclus'ons, offe s no opinion, offers no ex~ert witnesses.
Xt does state that his azgumsnt on Conten ion 2 vill be made Qux'ing his closing axgument. Of cou-se, a partv is entitled to make a closing axgum=nt, hut X poin out that a closing argument is not testimony under oath. Xt is not subject to cross-e:;anination. Xt seems to me that ab-sent that sort of testimony and looking at the intervenor's
'i6 direct case, it seems rather clear that the intervenor has j7 failed to carry his burden of moving forward on the conten-tions~
Xn fact, if the Xntervenor's prepared testimony tells anyth'ng at all, it can only be that there simply is .
no merit o the contention.
Contention 3 alleges that. the NRC Xnspection and Surveillance px'ogram is not adequate to insure that TVA satisfactorily completes the work zeguimd to restore Brogans g5 Fez~ after the fire.
35l barb"6 he Xnt rvenor nas no direct case on Content'on 3.
/
Xndeed, he has presented no basis for the contention, pre-sents no 4'ritnesses ~ no tes'cxliiony z but %ill merely Cross-Gx-MAine the NRC i~itnes se s ~
Thus, it seems to me it 's a strang sort of proceeding and tha'the. Xntervenor ~zith essentially no, effoi%,
- rith essentially no cas ~ no evidence; in short, really 'mi~b nothing, the Xntevenor is able to keep Brooms Perry from onerating.
Zi. hearing 9.8 held 3'rhere there is a genuine issue of material fact. Xn this'roceed:ng X think we hav. a hear-ing 9.n the absence of any such factual issue.
Under these circumstances, X think the Xnt=r-venor's cross-examination of the witnesses that vrould .follow should be rather limited. X think certain cros5-examination by TM: and MHC has of necess9.ty been l9mited due to the es-
~
7 sential absence o'ny d'rect case on the part of the Xnter-venor.
Lest anyone think that X blame this all on 20 X do'not. X don't th9.v3; that F~ . Garner can the'ntervenor, really be faulted. X think i~lr. Garner 9.s just usipg the pro'cedur s th- ax ava9.lable to anyone. X think the fault lies in a regulato y scheme that vill p ~it the intervenor 24 or anyone under those circumstances to effectively halt a prcject vith no greater ef'fort than has been put forth here.
352 barbl7 That conclude s my opening stat ment, and with that, X would like to call a panel of wi:tnesses. X would like to call Kr. Jack R. Ca3.ho~, as X call your name, if you will come .orchard to .the witness table and rema'.".. stand-ing 'Ix'. H. J. Green, Nr. Ben A. Gant, Ãr. John L.
Xngersen.
CSAXE4~1Z~R MXLLY: Qontlemen, will you each give your nam s and raise youx right naMs and X vill swear you a11 in, axter each of you give me your names.
Nhereupon, BEN A. GANT H J QBEEH JACK R CALHOUN JOaaN L XNGHRSHN vere called as witnesses on behalf of the Applicant anD,
'l7 having been first duly sworn, were examin 8 and testified as follows:
ZR. POIKLL: Nr,. Chairman, copies of the quali-fications of the testimony of these witnesses have previously been supplied to the reporter as has the prepaxed testimony of Tennessee V'alley Authority.
23 DXRECT EZ924XIVATXOi~$
BY MR.POiKLL:
Hr. Calhoun, would you please sf.ate your name and
353 barb18 {~fitness Calhoun) Sack R. Calhoun, 70? Mney Building, Chattanooga, Tunnel ssee~
- g. Do you have ~'fi h yGQ a copy of .a docmn nt entit3.ed, "The Qualificatiors of 8acR R. Calhoun'"
Are "here any corrections "o be madel
No correct" ons.
Are the statements in the document true'P hey axe.
20 Do you adopt, the docmnent as your tostimony in this proceeding' Zes g Z do>>
Nx. Green, mould you please state your name and 2-': Business address?
(Witness Green) Hy name is H. J. Creen. Hy bus<<
iness address is the Tennessee Valley Authority, Brims Perry Nuclear Plant, Post Office Box 2000, Decatur, Alabama.
- g. Do you have a copy of a document ent'itled, "Quali-fications of H. ~T. Green?"
22 Are there any correc"ions to be made in thai docu-0 ~ have one minor correction. Xn the Xn the last line of the third paragraph, the 710rd semester is mlsspe13.ed't should he s<<e-m-e-s-tm-r.
354 Are th. s-'a..amenti in that QoczaapP zruo~
EQSy GEO ~
Da you adoot. the aocument. as youx mesc"mony.kn itis proc eding?
K T. cRo.
3$
355
~'
Gant, would ~you please state your name and.
bu"'-iness address? ~ ~
{bitne s Gant'Ly "name is Ben 3,. Gant. Ply business
's II address enness~ Valley Authority, Haztsville Nuclear Plant, ~ia'"tsville, Tennessee.
- g. Do vou .have a copy od H~~ document enti"'"ied "Qualifications of Ben A. Gant" ?
Z do.
Are there any corrections. to be made?
yes, there's one.
Zn the bottom paragraph, the next to the last line of this paragraph, it says Z am currently 'Assis'nt Construc-tion Superintendent. 'L>at should be changed to Z am currently Cons ruction Engineer.
Q. Are the statements in that -document true";
'hey are ~
Do you adopt. the docmilent as pour. testimonj- in
~ 5 this proc-eding?
Z dor s'r.
l g, i>)r. ngwersen,:souM you please state your name and business address?
(Witness Znysersen) Fly name is John X>. Znprersen.
IIy business address is Tennessee Valley Authority, 727
~ Edney Build"'ng, Chattanooga, Tennessee.
9, Do you have a copy of the document entitled
3SG
'QR3.ifications of John La Xngversen Are ~2ieze any corrects.ons to he made2 Hog sir ~
Are the statements in the document truest Q. Do you adopt &e document as your testimony in this proceeding'P
- 2. , Yes, siz, X do.
r
. I&. POBBLL: Hr. Ci airman, X move that the quad.ifi-cati.ons ox 8'ohn X. Xng:rersen, ~ oak R. Ca1houn, H. Z. Green, arid Ben A. Gant 'he iricozpozated into the record as if read.
CBAXK4KC REXLLY: Wy obggctionaP MH. GAMIER: Mo objections.'R.
TOURTZXZOTTE: ~a1o objections.
CHMRGQf MXXXZ: M,1 right,, those four documents,
.che qualifications of these four'gent:lem~n, wi11 he incorporat into the record as if read..
(Ooannents foLXov.)
21
alifi'cations of John L. In ersen g'ame is John .L. Ingwersen- My business addrc.".s is Tennessee V:il li:y Authority,, 727 F~hicy Building, Chattanooga, Tenncs"cc. I (jm employed H
by the Tennessee Valley Authority as a nuclear engineer in the Reactor Fhgineering Staff, Nuclear Generation Branch, Division of Power Production.
I have been continuously employed. by the Tennessee Valley Authority since 1971. Prior to that time I served for five years in the United States Navy. I graduated from the Navy's Nuclear Submarine Training Program and"the Nuclear Power Training School. I qualified as Engineer Officer of the Watch on the Bai'nbridge prototype and Officer of the Deck on'he submarine ~illback and nuclear submarine Simon Bolivar.
I received the Bachelor of Science degree in Electrical engineering in 1964 and a Masters of nuclear engineering in 1971 from the University of Missouri at Columbia.
I am presently responsible for the Division of Power Production's coordination and preparation of Environmental Reports snd Statements, Preliminary, and Final Safety Analysis Reports. In this capacity, I supervise a unit that has participated in these activities on all of TVA's nuclear plants. I am also responsible for coordinating the Division of Power. Production's Radioactive Waste Management Program.
I have analyzed the materials from the Nuclear Safety Information Center regarding matters raised in stipulated Contention 2 in the Browns Ferry Nuclear Plant proceeding, and supervised preparation of the tables and graphs in TVA's prepared testimony.
Qualifications of Jack R. Calhoun lQ name is Jack R. Calhoun. Hy business address is Tennessee Valley Authority,, 702 Edney Building, Chattanooga, Tennessee. I am employed by the Tennessee Valley Authority as the Chief of the Nuclear Generation Branch, Division of Power Production.
I have been continuously employed by the*Tennessee Valley Authority since l949. Prior to that time I served for eight years in the United States Navy. Part of that time I was an ELectrical Officer and was qualified as Engineering Officer-of-the Watch at'ea on both ships.
I received the Bachelor. of Science degree in electrical
'I engineering from Tennessee Technological University in 1949. During this period I was the Executive Officer and. Electronics Officer of the U.S. Naval Reserve ELectronics Warfare Company located at Cookeville, Tennessee.'
began my employment with TVA in 1949 as a student in the steam generating plant operator training program at the Watts Bar Steam Plant and later became an instructor in that program. I was transferred to the Johnsonville Steam Plant in 1952 as a unit operator and later assumed the position of an electrical engineer.. In 1954 I was placed in charge of all electrical maintenance at the Johnsonville plant..
ln 1958 I became assistant plant superintendent at the 1,500-MW Shawnee Steam Plant at Paducah, Kentucky.
In 1960 I became superintendent of the Experimental Gas>>Cooled Reactor (EGCR) at Oak Ridge, Tennessee. During this period,I attended the Oak Ridge School of'eactor Technolbgy. In 1961 I spent five months at the Berkeley Nuclear Pover Station 'in Bristol, England, assisting in the startup of that reactor. While at Berkeley I completed the rea'ctor operator training course on a nuclear plant simulator used to train all reactor operators for the Central Electricity Generating Board.
In 1963 I vas appointed assistant Prospect Manager of the Experimental Gas-Cooled Reactor and was responsible for assisting 'the prospect manager in all phases of technical and, operational vork.,"'rom 1963 to 1966 I vas a member (for reactor operation) of a panel created by an agreement betveen the United Kingdom Atomic Energy Authority and the United States Atomic Energy Commission to exchange information on gss-cooled, reactors. As a member of this panel, I tvice traveled to England to investigate and to observe the operation of the British Advanced Gas-Cooled Reactor in preparation for the startup of EGCR.
From February 1966 to February 1968, I held the position of Assistant. to the Chief, Pcnrer Plant Maintenance Branch, Division of Pover Production in TVA. I assisted in the engineering and coordination of the electrical and mechanical maintenance of all TVA steam and hydro plants. I was also responsible for the operation and maintenance planning relating to future TVA nuclear paver plants.
From February 1968 to July 1971, I held the position of Plant X
Superintendent of the Brovns Ferry Nuclear Plant in Athens, Alabama.
From July 1971 to April 1974, I vas nuclear operations coordina-tor; and in April 1974 my title vas changed to Chief, Nuclear Generation Branch. In this position I am responsible for and in charge of staffing, startup testing, and operations of all TVA nuclear pover plants, including the Brovns Ferry Nuclear Plant, units 1 and 2. I sm also responsible for the coordination of the restoration and modifications activities, including fire protection improvements, of the Brogans Ferry Nuclear Plant, units 1 and 2, folloving the March 22, 1975, iire.
I'm presently a member of the Advisory Council at Pennsylvania State. University (advisor to the Nuclear Engineering Department) and serve as Vice Chairman, Reactor Operations Division, American Nuclear Society.
ualification of H. J. Green Hy name is H. J. Green. My business address is Tennessee Va3.l<:y Authority, Drowns Ferry Nuclear Plant, P.O. Box 2COO, 9fcatur ALabama. I am employed by the Tennessee Valley Authority a Nuclear Plant Superintendent of the Browns Ferry Nuclear Plant.
I have been continuously employed by the Tennessee Valley Authority since 3961. Prior to that time, I served for eight years as a commissioned officer in the United States Navy. I graduated from the Navy Nuclear Submarine Training Program and the Advanced Nuclear Power Training School. I qualified as Senior Reactor Operator on the US
'I Naval Submarin Nuclear Prototype at Nest Milton, New York and also served facility as an instructor. At the time of my discharge, I was r't that reactor control offtc.r on the nuclear parer auhnarlne USS ~Ski ack.
I received the Bachelor of Science, Degree in engineering from the US Naval Academy in Annapolis, &dryland in 1953. Prior to entering the Naval Academy,. I studied engineering for four semesters r
at David and Elkins College and two semisters of engineering at Vest Virginia University.
I began my employment with TVA in 1961 as Assistant to the
.Superintendent of the Experimental Gas Cooled Reactor (EGCR) at Oak Ridge, Tennessee. In 1963, I was appointed superintendent of that prospect. For two years, 3966-1968, I served as Assistant Superintendent of Gallatin Steam Plant, a four-unit coal fired generating, station located at Gallatin, Tennessee.
From October 1968 to July 1971' held, position of Assistant Plant Superintendent of the Browns Ferry Nuclear PLant in Athens, Alabama. During this period, I attended the boiling water reactor teduiology school, conduct d r
by the General Electric Company and successfully completed the 12-week training
program at the boiling water reactor simulatog located in Morris, Illinois, fn .July l~J)l, I was appointed the position of Plant Superintendent of the hrowns Yerry fhiclcar Plant and have held that position since. En this capacity, i am rcsponsibl>> for the safe operation and maintenance of the facility.
alifications oi'en A. Gant My name is Ben A. Gant. My business address is Tennessee Valley Authority, Hartsville Nuclear Plants, Hartsville, Tennessee.
i am employed by t;he Tennessee Valley Authority as a Construction Engineer, Vivisinn of Construct;inn.
I received a Bachelor of Engineering degree in electrical engineering from Vanderbilt University in 1949. From 1949 until 1952 I vas employed by the Factory Insurance Association as an inspector.
In 1952 I Joined TVA as an electrical engineer in the Division of Construction at Kirigston Steam Plant. I resigned this position in 1956 for employment as .a senior engineer vith the U.S. Fire Protection Engineering
'Service in Kansas City, Missouri. I resigned this position in 1958 and re3oined TVA as an electrical engineer in the Division of Construction at e
i >
. the Gallatin Steam Plant.
With the exception of one year in the Procurement and Specification Section, Electrical. Design Branch, Division of Design, I have been continuously employed in the Division of Construction. I have served as an electrical t
4 engineer, principal assistant to the Electrical Engineer, Electrical Engineering Unit Supervisor, Construction Engineer (Electrical), Assistant Construction Engineer,, and, Construction Engineer. Total TVA service includes the initial construction,, checkout, and initial operation of 13 coal-fired units and nine and one-half years involvement in the construction, checkout, and preoperational testing of the nuclear units at Browns. Ferry.
'->I am currently Assistant Construction Superintendent for TVA's Hartsville Nuclear Plants.
357 SZ hR. POvtBLL:
1 Hr. Calhoun, Qo you have a copy of the docs ant ent9.t2.ed "Prepaxek'eseieony of Tennessee Va3.3.ey Zuthority"'P
($B.tness Calhoun) Zes, X Qo.
Was this ctoaument prepared hy you personally anrl unC~m your Qizect3.on anQ supervisionP Xt 'fas ~
.Do you have any correoticns to make in the'ocument2 Yesg X clos
'Xf you ~~ill please tuxn to page 4, the ninth line frod the top please g chat?ge the number IG to 15 ~
iform,
't if you wiII turn to Appendic 3 MR. GRKlHR: Mould you repeat that, I4r. Calhoun?
Sateen to 152 SS CB~GUH: Change the nuncle- "16" to "15."
~n to the page MNat's entitleQ "appendix 3."
This is the page that's 3mzeQ9.ately following the graphs.
-'~. XOmh~~: Mx.,"hairman, X +culm live
~
just for a moment to apo" ogive for the rather 'upt poor gQRXLt of the graphs thai .show up in AppenO~ 3 as fax as the print.-
ing is concexneC.
Xt occurred to ms radar late that it might he easier to grasp this material iX ee hacL a graph, anQ ve put them together hwwiedly; anQ they QMn't reproduce very ~rell.
But maybe chere is enough, there to be useful.
HXT'ASS CiVMOUN: Count to the sixth g aph. That graph is en'-i'ed '"Construction Errors, 2Ql Others." Delete the vbrd "Zrzozs."
Count on to the tenth graph. The t9tle of this
'graph i "Staztup Errors, All Othe s." Delete the vore "Errors."
Count to, the fifteenth graph. The title of this one is "Operating Errors, All Others." Delete the awry Brzbzso 20 Xn the twentieth graph, and 9.t happens to ha tha last one, the title 9.s "Operating Errors, All Others (Annual Average)." Delete the word "Hzrors."
23- That completes the corrections.
SZ MR~ PO~~
5r. Calhoun, Qo you. adopt th9.s preps'ed testimony as your testimony in this proc ecting?
(Hit~ss Calhoun) Yes, X Qo.
Mr. Gant, Qo you have a, copy of the "Prepared Testimony of Tennessee Valley Authority"2
'I
. (Witness Qantj Yes, X hate.
Did you participate in the preparation of this
. Yes'izg X did ~
Do you have any corrections to he m'ade2 Pg,
359 Do you adopt this as your -testimony in Mis pzo-Ceeding2 Yes.
51r Green, do you have a copy o che "Prepared Testimony of Tennessee Vai.leg authority' (witness Green) .
X Qo.
Bid.you parcicipato in the preparation of the X:did.
Q. Oo you have any corrections to he madel'gC.<Vi' Do you adopt this as: your testimony in this pro-ccedingP I
X doe 9, Ilr. Zngweraen,.do you have a copy of the I "Prepared Test.kmony 08 gennessee Valley Authority (Nit+ass Xngwersen) Yes, sir, I do.
OicL you participate in the preparation of this eshimony?
X Big.
Da you have any corrections to he 'made2 No, sir.
Do you adopt this as your testimony in this pro-cescLLLQP X doe
360 MR. POTE~~= Hr; Chairman, X r~ove chat &e document entitl=,Q "Prepared. K'est~mo;xy of T nnessee Va3.ley Au&ority" ba aamitteQ into evidence anC Lout:d into the record as if QeaGo CBMKCQV REXLGT: ZMp ob ject'ions>
MR. GABBER: Ho ob)actions'R.
TOQRTLLLOTZHo ~ sections.
Q~ppj g Qpg+I~ 2+8 Prepare/ Qes+xsRonp 0 f Tennessee Valley Authority wi31 he incorporated into the record as if rea6.-
~ {DocLKGnt,follovTso)
IB P.O
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety snd Licensing Board In the Matter of ,)
)
TENNESSEE VALLEY AUTHORITY ) ~ Docket Nos. 50-259
) 50-260 (Brovns Ferry Nuclear Plant units l and 2) )
PREPARED TESTIMONY OF TENNESSEE VALLEY AUTHORITY
Analysis of Nuclear Safety Information Center Data Stipulated Contention 2 states that:
'ntervenor contends that TVA personnel are not technically qualified and competent to satisfactorily complete the work required to restore Browns Ferry units 1 and 2 after the fire damage or to satisfactori~ complete the design modifications on Browns Ferry units 1 and 2 necessary to provide adequate protection against the functional damage of both redundant components of engineered safe-guards equipment from postulated future fires as evidenced by:
A. TVA has experienced, an unusually large number of abnormal occurrences at Brovns Ferry Huclear Plant units 1 snd 2.
s By letter of April 23, 1976, Intervenor identified. the "safety
.related occurrences" as those safety<<related occurrences specified. in Appendix A of Intervenor's Perfected. Petition for Leave to Intervene and Occurrences in Nuc1ear Power Plants as Re rted in 1 74 and that vill be specified in Safet Related Occurrences in Huclear Power Plants as Re orted
~fn i 75 shen that document is'ublished. Appendix A oi Intervenor's Perfected Petition cites the safety-related occurrences as reported by the Nuclear Safety Information Center (HSIC) 'of the Oak Ridge National Laboratozy (ORNL) for the years 1967 through 1974.
Thus the basis set forth by the Intervenor in paragraph A of contention 2 in support of that contention consists of "safety<<related occurrences" at Browns Ferry Nuclear Plant; Units 1 snd 2, which are reported in the folloving documents:
- 1. Safe -Related Occurrences in Nuclear Facilities as-Re rted in 1 6 end 1 68, ORHL-NSIC- July 1970 )
p
- 2. Safet -Related Occurrences i'n Nuclear Facilities As
- 3. Safet -Related Occurrences in Nuclear Facilities As
- 4. Safet -Related Occurrences in Nuclear Facilities As Safet -Related Occurrences in Nuclear Facilities As
- 6. Annotated, Biblio a h of Safet -Related 0 currences
.in Nuclear Power Plants As Re rted in 1 73, ORHI~HSIC-114 November 197 7.'afet -Related Occurrences in Nuclear Power Plants As
- 8. Safet -Related Occurrences in Nuclear Power Plants As Re orted in 1 not yet published Ve have reviewed these documents and specifically each of the events's reported occurring at units 1 and 2'f the Browns Ferry Nuclear Plant. It should be noted that no Browns Ferry events are shown. in NSIC-69, HSIC-87, NSIC>>91, or HSIC-106. All those events'shown in HSIC-109 are prcoperational events.
In order to compare the number of reportable occurrences at Browns Ferry with other nuclear plants, a contract was negotiated with the Nuclear Safety Information Center (NSIC) for a computer printout for all U.S. nuclear plants. HSIC subsequently provided'bout 4,000 pages of materiel summarizing each plant's, reportable occurrences during construc-tion, startup, and operation phases. The printouts are further broken down into categories. The description of how these printouts were obtained are gontained in Appendix l. m This material has been previously supplied to the parties and the Licensing Board.
Using the NSIC data, TVA has tabulated the number of occurrences for (a) construction, (b) startup, and (c) operational periods. Because the operational period is of varying time frames for different, plants, another tabulation giving annual averages of occurrences for each plant II 1
is included. These summaries are included as Appendix 2.
The Construction Abnorma1 Occurrence (A.O.) Summary table in Appendix 2 shows that Browns Ferry unit 1 had. a total of 12 occurrences, while 25 units had as many or more. Unit 2 had a total of 14 occurrences, while 18 units had as many or more. The table lists a total of ll2 units.
Thus, Browns Ferry has not had an unusually large number of occurrences during construction as alleged by the Intervenor, but rather, compares favorably with other reactors.
The Operating A.O. Summary table giving the annual averages II shows that Browns Ferry unit 1 had a total of 26 occurrences'n an annual average basis, while 33 units had as many or more. Unit 2 had 9 occurrences on an annual average basis, while 50 units had as many or more. The table lists a tota1 of 53 units. Thus, Browns Ferry has not had an unusually large number of occurrences during operation, as alleged by the Intervenor, but rather compares favorably with other reactors.
The Startup A.O. Sumasry table shows that Browns Ferry unit 1 has a total of 120 occurrences, with one unit having more. Unit 2 has a total of 53 occurrences, with 13 units having more. The table lists a total of 49 units. The table reflects that Browns Ferry compares favorably with other plants in all categories. except for the "Testing" and "Other" categories for unit 1.
'3
"Testing" during the initial year of operation includes startup testing and testing during surveillance. Xt is expected that most pntcntiai problems vill be discovered during testing and not in operation. The experience gained on unit 1 msy be responsible for the much improved unit 2 performance. There are, hovever, a number of occurrences which stem from a single generic problem that is, one component in several systems is malfunctioning causing numerous reportable occurrences. One I
example of this is the problem vith Barton instrument svitches. The drift of the setpoint on the Barton switches resulted in some 16 reportable occurrences. Overall, setpoint drift on these and other instruments V
accounted for 23 of the 61 testing occurrences on unit 1. This setpoint drift results in a setting that auld be slightly higher or lover than that specified. A beneficial result of setpoint drift on Barton svitches has been a modification of the svitches to correct setpoint drift. These modified svitches are nov installed at Brogans Perry and. have essentially eliminated this problem.
"Other" includes sll those events,not included in the prior categories. This category includes some 18 HSIC listings covering fish impingement on the intake screens and. abnonas1 temperatures in Wheeler reservoir (primarily from solar heating). Considering these factors, unit 1 had considerab+ fever occurrences than the total listed.
. Appendix 3 presents the data on reportable occurrences in the form of graphs. Appendix 4 gives a brief summary of the resolution or status of each startup and operating occurrence, vhile Appendix 5 gives the resolution or status of construction occurrences.
It must be realized that the total number of reportable occurrences on s plant does not provide s criterion for Judging the competence of personnel to construct or operate a plant/ Of primary importance is the safety significance of an occurrence. For example, there have been on+ tvo events at Browns Ferry which are classified as having real safety significance.
/
This Judgment is reached using the Interim Criteria as'et forth in Appendix A to NUREG-0090-2, "Report to Congress on Abnormal Occurrences" (October-December 1975). The two events sre the March 22, 1975, fire (Accession Number 101444 ) and the failure of level svitches vhich actuate high-pressure core inJection suction transfer from. condensate storage to the='suppression pool upon high level in the suppression pool (Accession Number 85324).
S
'/
Other important factors vhich demonstrate that the total number of. occurrences reported is not a proper criterion are the requirements of'echnical specifications and the interpretation of those requirements I
by the licensee. Thus, requirements in'echnical specifications msy vary greatly from plant to<< plant, and the exercise of Judgment as to what must
/
be reported vill obviously vary from individual to individual.
However, even if it is'assumed that the total number of occurrences ss reflected in the NSIC materials is a proper criterion for Judging competence, Brovns Ferry compares favorably with other plants.
The NSIC occurrences on Browns Ferry report many events involving minor equipment malfunctions, setpoints drifting out of calibration, impingement of fish on intake screens, and river temperatures exceeding, s given standard. The data demonstrates that Intervenor's statement that 5
TVA "has experienced an unusually large number of 'abnormal occurrences't the Brogans Ferry plant" is misleading and not indicative of any lack of technical qualifications or competency of TVA personnel to install fire related modifications or to operate the units.
~AndIx I OAK RIDGE NATIONAL LABORATORY OPChATCO aV UNION CARBIDE CORPORATION NUCLEAR OIVISION tost orrIcc eox v OAK hlooc, TENIIcsscc )lese HUCI.EAR SAFETY IHFORMATIOH CENTER
~ IS' 5) iSII ) ))5)
PTS ~ IS<4 ~ ) )15) July 22, 1976 ~ ISA ~ ~ ) 5 ~
PV5 ~ I ~ ~ 51 II ) 5 ~ '51 Si))
John Ingwexsen Tennessee Valley Authority 727 Edney Bldg.
Chattanooga, Tenn.
Dear John:
Licensee Event Reports In accordance with TVA Contract Number 77P84-140417, the Nuclear Safety Information Center is in the pxocess of supplying you with literature searches of our computer files on licensee event reports (formerly known as abnormal occurrences) submitted by nuclear power plant facilities. The formats of the
~" searches are in accordance with youx instructions to Ray Scott in your tele-phone conversation with him on July 7.
h description of the NSIC computer printouts is attached for your informa-tion. Note that 6 paxts of each category are in accordance with your verbal instructions to Ray Scott.
If you have any questions) feel fxee to caU. me.
Sincerely yours, R . L. Scott.
~ Nuclear Safety Informa'tion Center RLS: pg Attachments
Descriation of'SIC Comtuter Printouts on I'uclear Power Plant Licensee Event Re~orts
'She computer printouts (searches) on Huclear Power Plant Licensee Event Reports (formerly known as Abnormal Occurrence Reports) were obtained from the Huclear Safety Information Center (HSIC) computer files.
~
The HSIC computer files contain document descriptions developed during the past 33 years covering many types of safety information. One type of document consists of copies of a11 licensee event reports. They are received C
from the Nuclear Re~atory Commi'ssion by routine distribution and are processed Jato the computer file by HSIC The searches that were provided to TVA contain information on all types of events experienced at nuclear power plants, and this information was limited
'. ~
to that reported to the Nuclear Regulatory Commission (formerly AEC) during the period Jan, 1~ 197~uly 3.5~ 1976'he citations appearing in the printouts contain aU. events reported to HRC, in accordance with requirements. Xn addition, some citations are descriptions of events which were not required to be reported by the licensee. These descriptions and a sma11 number 'of miscellaneous items may also appear in the printouts but efforts to negate them could have affected the completeness of coverage,.
The information in the printouts was divided into three categories; i<e, ~ (1) construction events, (2) events during the first year after a
(2) plant receives its operating lfcense (startup}, end. (3} events vhich occur during the perfod year after the operating license is issued through o July 15, l976.
1 The nuclear power plant units incLuded fn each of the three categories ere es follows!
(1)'onstruction! A11 units are included.vhich experienced some phase 1
of construction anytime during the perfod Jen. 1~ 1970 through July 15, 1976.
The information for each unit covers the perfod from the time the construction
.permit vas issued or Jan. 1, 1970, vhfchever vas later, until the date en operating lice'nse vas issued or July 15, 1976~ vhfchever cene first.
(2) Startups All units are included vhich experienced startup testing during the period. Jan, ly 197~uly 15I 1976, Startup hss been deffned, for.
j yujeses used here,,es the period from the dsy the operating license vas received to 1 year later. If an operating license vas received after Jane 1, 3.969 ~ so that soie startup experfence occurred fn 1970,'then the 4
unfed vas 'included in this category end, the ful1 year of stertup information,
~ ~ ~ lf ALL'units (3) Operations vhfch experienced operation during the perfod Jan. 1, 197DiTuly 3.5, 1976, are included, The period of time considered for each unft vas from 1 year after receiving an operating license or Jan. 1, 1970, vhichever came later, untfl July 15~ 1976+
..Mfthfn each category (Construction, Startupo and Operation), the information fi further I 4 subdivided fnto 6 parts as
~
follovs!..
g
Construction Events (01) Testings Events which were discovered by testing. Twelve keywords vere used for retrieval! Test> Bench'est>> Component; Test, Control Rod Drive; Test, Leak; Test, Leak Location; Test>> Leak Rateg Test>> Nondestructive; Test,
$ 9.ant Response; Test>> Preoperational)
Test>> Pressure Vessel; Test, System Operability; and Testing, (02) Design Errors! Events or faQures that vere the result of design errors, (03) Personnel Errors< Events resulting from;operator or administrator errors.
'(04) Installation'rrorsi Events oaused by erroneous installation of 4
equipment>> instruments>>
etc'05)
Fabrication Errorst resulting, from mistakes in fabrication 0 Events of equipment, etc, (06) A11 Other Events<
- '&eludes all other failures=not included in parts 1 through 5. ~ ~
t~ ~
~
Testing: Events discovered by testing, . Keywords used are as in
.;(01) u der Construction Events, (02) Equipment FaQ.ures! Events attributable to equipment failures (not
~ some other reason such as design error>> etc,) ~ Keywords used were Failure, Component; Failure>> Equipment)*FaQure>> FatigueJ Failure, Fuel Element;
Failure, Instrument~ FaQure, Pipe; Failure~ Pressure Vessel; Failure, Scram Mechanism~ and Failure~ Tubing, (03) Personnel Errors: Events caused by personnel errors. Ke~nrds used vere Failure, Operator Errors and Failure~ Maintenance Error.
((A) Procedure Errozst Events resulting from incomplete or defective procedures ~
(05) Instrument Setpoint Driftt Events involving instrument setpoint drift, Usually the drifts mereLy exceeded T, S, limits; also usually dis<<
covered during testing consequently appearing in part (Ol) above.
(06) JQ1 other events involving faQures ~
- All'parts are the same as under Startua Events.
It should be noted that if a citation appears in part (Ol), it vould not appear in any subsequent parts even though it msy be indexed to 2 or more parts.
Lihevfso, if it appears in part (02) it @&1 not appear in any subsequent part, etc ~ ~ >> 0
A dix 2 Construe.son AO S~~e Construction Design Administrative or All Plant Start Date Testing Errors Operator Errors Installation Fabrication Others Arkansas Huclear 12/06/68 8 5 16 Nuclear 2
'rkansas 12/06/72 2 3 2 7 Beaver Valley 1 6/26/To 6 1 4 12 Beaver Valley 2 5/o6/74 1 2 Bellefonte 1 12/24/74 3 4 Bellefonte 2 12/24/T4 2 2 IBig Rock Point 1 Browns Ferry 1 5/lo/67 5 5 12 Browns Ferry 2 5/10/67 5 5 2 1 Browns Ferry 3 7/31/68 3 6 3 2 15 Brunswick 1 2/oT/To 5 "2 3 4 15 Brunswick 2 2/o7/To 4 1 4 4 13 Calvert Cliffs 1 7/o7/69 10 5 3 4 8 6 36 Calvert Cliffs -2 7/07/69 8 3 ~
7 5 8 4 35 Catawba 1 8/07/T5 1 1 Comanche Peak 1 12/01/74 1 2 Comanche Peak 2 l2/ol/74 1 1 Cook 1 . 3/25/69 7 2 2 1 14 Cook 2 3/25/69 6 1 1 1 11 Cooper 6/o6/68 2, 1 3 Crystal River 3 9/25/68 2 4 1 1 9 Davis-Besse 1 9/10/70 2 4 5 1 12 Diablo Canyon 1 ~
6/14/68 1 1 2 2 1 8 Diablo
-Fsrley Canyon 2 3/71 3.
'2 1 2 6 1 8/16/72 3 1O Parley 2 8/16/72 2 2 7 Fermi 2 9/26/72 1 1 2 Fitzpatrick 5/20/70 2 2 11 Ft. Calhoun 6/oT/68 1 1 Grand Gulf 1 5/74 4 2 1 7 Grand Gulf 2 5/74 4 1 1 6 Hatch 1 9/30/69 1 1 10 Hatch 2 2/29/72 1 C Indian 'Point 3 8/13/69 2 3 Kewaunee 8/o6/68 8 3', 14 Lasalle 1 9/10/73 2 Lssalle 2 9/10/73 2 2
+This appears to be some post-O.L. construction activities.
(t Construe-Eon AO Summa Page 2 r
k Construct f.on . Design Administrative or All Plant ~ Start Date Testing Errors Operator Errors Installation Fabrication Others Total Limerick 1 5/73 1 2 Limerick 2 5/73 1 1 McGuire McGuire 2 i 2/28/73 2/28/73 4
3 2
2 3
3 9
8 Midland 1 ia/15/72 2 3 Midland 2 12/15/72 2 1 6 Millstone 2 12/ll/70 3 1 3 20 Millstone 3 , V/oi/V4 1 1 North Anna 1 1/VO 3 5 4 13 North Anna 2 i/vo 4 5 4 14 North Anna 3 7/72 1 7 3 12 North Anna 4 7/72 '5 1 7 Oconee 1 11/o6/67 1 Palisades 3/14/67 1 1 Peach Bottom 2 1/ 31/68 1 3 5 Peach Bottom 3 1/31/68 2 1 5 8 Perry 1 lo/74 1 1 Prairie Island 1 6/25/68 9 3 3 3 19 Prairie Island 2 6/as/68 9 1 3 3 1 17 Rancho Secho 1 10/11/68 3 1 4 Salem 1 1/68 11 3 3 3 2 Salem 2 1/68 .2 3 2 4 12 St. Lucie 1 7/01/70 13. 3' '2 7 31 Sequoyah 1 , 5/av/vo 3 1- 3 4 19 Sequoyah 2 '5/2V/Vo .3 6 1 2 3 17 Shorehsm 1 9/Va 1 1 1 2 2 7 Summer 1 4/12/v3 1 1 2 Surry 3 .12/20/74 4 1 5 Surry 4 ia/20/74 4 1 5 Susquehanna 1 'll/73 2 2 1 5 Susquehanna 2 il/73 2 2 1
'Three Mile Island 1 5/18/68 3 2 '28 Three Mile Island 2 a/69 5 1 23 TroJan 2/o8/Vl Turkey Point 4 4/12/67 1 1 Watts Bar 1 i/23/V3 .2 1 1 6 Watts Bar 2 . i/23/v3 2 1 1 6.
Zion 1 12/26/68 1 1 2 Arnold 1 6/22/70 4 2 6 15 Wpps 2 3l19l73 1 1 3
<Ape-ructi~- eG S~~e"v Ca~a The folloving plants vere su~eyed but nc A.O:'s vera <<scov +4= ir cc"struction 'n the period considered:
Bailly Indian Point 2 <ued Cities 2 Bryon 1 Maine ankea San Onofre 1 Bryon 2 Millstone 1 San Onofre 2 Catavba 2 Mcntec allo 'urkey Point 3 Dresden 3 Sine Mile Pci..t 2 Vermc~t Yankee Forked River Oconee 2 Vogtle 1 Ft. St. Vrain Oconee 3 Vogtle 2 H. B. Robinson 2 Perry 2 Waterford 3 Harris 1 Pilgrim 1 Wpps 1 Harris 2 Point Beach 1 Vyps 4 Harris 3 Point Beach 2 Zimmer 1 Harris 4 Quad Cities 1 Zion 2 I
<<-~re are no construction occurrences indicated by BASIC prior to 1973 since reporting requirements for the construction "st'age vere not prosiulgated until the latter part of 1972. As-.a consequence, of this, many units vere*'reported by HSIC
'to have very fev or no construction occurrences. Sixteen units in the NSIC listing receiving Operating Licenses in 1973 or earlier fell into this category. %here are 6 other units that have been under construction for one year or less and have reported. very fev or no occurrences.
JLI:PBA
.8/3/76
- 0 Plant Arkansas Nuclear 1
'tartTesting Occurrences 5
A.O.
Equipment Failures 9
Personnel Errors Procedural
~
Errors
.0 Setpoin:
D."ifts All Ot;hers Tots Calvert Cliffs 1 18 28. 23
~
37 Pilgrim 1 32 12 10
~ 64 Brunswick 2 36 13 p7 64 17 Robinson 2 4 33 152 2
Dresden 2 7 15 3 9 Dr'esden 3 6 2 30 2 8 4 Quad Cities 1 4 9 2 9 24 Quad Cities 2 10 2 4 19 Zion 1 16 40 13 5 10 Zion 2 Indian Point 2 23 1
11 2
ll4 ~
8 7
37 53 Palisades 6 14 7 Oconee 1 4 3 2 2 28 Oconee 2 3 8 9 4 1 8 24 Oconee 3 16 7 7 1 Beaver Valley 1 3 9. 40 St. Lucie 1 2 3 8 9 2 Turkey Point 3 16 14 18 10 1 68 Turkey Point 4 3 2 27 .
Hatch 1 1 12 22 37 26 10 3 Cook 1 23 15 91 15 7 2 '26 Arnold 55, =9 73
- 8. 1 13 Oyster Creek 1 3 '. 3 86 Maine Yankee 6 7 2 3 Three Mile Island 1 18 8 9 21 14 Cooper Nine Mile Point 1 46 1
ll 10 8
10 3.
29 7
79 76 Millstone 1 8 20 2 11 MiU.stone 2 Prairie Island 1 27 13.
14 1
3 1
3 '7 3 33 74 Prairie Island 4 1 20 2 11 5 "1 Pt. Calhoun 1 16 3 8 25 Peach Bottom 2 13 36 44 1 Peach Bottom 3 11 58 46 23 4 2 Tro)an 12 87 7 9 6 1 28 Pitzpatrick 67 15 8 4 5
Indian Point 3 3 4 13 107 Ft. St. Vrain 6 3 10 7 3 13 30
Stertu- A.O. Summa Page 2 Testing Eq,uipment Personnel Procedural Setuoint All Plant Occum ences Failures Errors Errors Drifts Others Total Ginna 1 2 12 Rancho Seco 11 10 6 5 43 Brogans Ferry 1. 61 5 7 7 4o 12o Brovns Ferry 2 22 12 5 14 Vermont Yankee 17 6 .
5 1 13 42 Surry 1 7 2 5 2 13 29 Surry 2 5 2 3 16 26 Point Beach 1 1 2 5. 1 9 Point 1 1 Kevaunee Beach 2 6 ll ~
5 '1 3 26
iO A'diz 2 eratin A.o. Summa Testing equipment Personnel Procedural Setpoint AU.
Plant Date Occurrences Failures . Errors L'ro+8 Drifts Others Total
'2 Arkansas Nuclear "1 5/21/75 .6 11 2 37 58 Calvert Cliffs 1 . 7/31/75 5 15 6 1 7 34 Pilgrim 1 6/o8/73 77 '4 27 4 28 148 Brunsvick 2 i2/27/V4 23 ,7 21 105 Robinson 2 7/31/Vi 36 50 19 38 143 Dresden 1 1/01/70 .
36 43 14 3 19 115 Dresden 2 1/ol/vo 118 85 25 7 48 284 Dresden 3 1/12/72 7 6 4o 192
@tad Cities .1 10/01/72 55 30 17 5 4o 147 hexad Cities 2 3/31/73 51 39 14 ~
2 33 139 Zion 1 4/o6/74 '46 21 14 5 17 lo4 Zion 2 ll/14/74 42. 24. 6.
2' 10 82
'onnecticut Yankee 1/01/70 18 7'4 24 73 Indian Point 1 1/ol/70 15 34 1 19 83
..Indian Point 2 10/19/72 37 . 14 2 27 113 Big Rock Point. 1/01/70 48'. 9 5' 36 119 Palisades 3/21/V2 38 32 18. .43 138 Lacrosse 1/ol/Vo 10 51 14 4 15" 94 Oconee 1 2/o6/74 18 9 24 30 85 Oconee 2 10/06/74 24 10' '20 4 25 83 Oconee 3 v/i9/v5 7 5 2 12 .31 Turkey Point 3 v/i9/v3 10 10 1' 17 '49 Turkey Point 4 4/io/74 7 9 7. 9 36 Hatch 1 8/06/75 15 15 1 4 8o Cook 1 io/25/75. 19 12. 4 35 Arnold 2/22/75 81 7 2 , 8 110 Oyster Creek 1 4/09/70 120 37 21 51 .
233 Maine Yankee 9/15/73 18 12 3 .1 12 46 Three Mile Island. 1 4/19/75 23 9 10 8 30 8o Cooper 1/18/75 36 .
17 9 13 75
'Nine Mile Point 1 8/22/vo 45 32 ...14 1 22 114 Millstone 1 10/07/vl 54 51 12 5 48 170 Monticello 9/08/71
- 63 37 20 1 37 159 Prairie Island 1 8/o9/74 27 13 8 3 25 76 Prairie Island 2 10/29/75 5 5 14 26 Pt. Calhoun 5/24/74 34 13 6 3 18 74 Humboldt Bay l/Ol/70 17 '7'6 9 3 12 58 Peach Bottom 2 8/08/74 . 62 11 1 32 172 Peach Bottom 3 V/o2/V5 36 37 3 18 94
eratin A.O. Summ P88Pe 2 Testing Eq,uipment Personnel Procedural Setpcint All Date Occurrences Failures Errors Errors Dri ts Others Total Fitzpatrick 10/17/75 15 5 2 6. 28 Ft. St. Vrain 12/21/74 16 17 8 3 30 74 Ginna 9/19/70 43 37 9 8 19 116 Rancho Seco 8/16/75 6 3 1 16 Ssn Onofre 1 .1/01/70 20 12 1 38 Brovns Ferry 1 6/26/74 12 17 52 Brovns Ferry 2 6/28/75 2 7 9 Vermont Yankee Surry Surry 1
2 Point Beach 1 2/28/73 5/25/73 1/29/74 10/05/71 56 21 14 24 21 37 28 19 10
'17
'5 11 4
3 2
26 33 20 20
'0117 U3 74
'oint Beach 2 ll/16/72 23 7 9 13 53 Kevaunee 12/21/74 21 12 4. 2 39 Yankee Rove 1/01/70 18 6 19 67-Fermi 1 and Peach Bottom 1 excluded because of decommissioning.
~A~.dix 2 eratin A.o. Summa Annual Aver es )
Avera e Occurrences Per Year Months in Testing Equipment Personnel Procedural Setpoint All Plant Operation Occurrences Failures Errors Errors Dri fts Others Total Arkansas 1 13 10.2 1.8 .
1.8 34.2 53.5 Calvert Pilgrim Cliffs 1 1
ll 37 5~5 5.4 25.0 16.4 8.8 6.5 3.9 1.1 1.3 7.6 9.1 37.0 48.1 Brunsvick 2 . 18 36.o 15. 3 4.7 14.0 70. 0 Robinson 2 59 70 3 10. 2 3.9 7.7 29.1 Dresden 1 78 5.5 6.6 2.2 0.5 2.9 17.7 Dresden 2 18.2 13'1 3.8 1.1 0.2 7.4 43.8 Dresden 3 54 20.7 10.0 1.6 1.3 0.2 8.9 42.7 Quad Cities 1 14.7 8.o =
4.5 l.3. 10.7 39.2 Qmd Cities 2 39 15.7 12.0 4.3 o.6 10.2 42.8 2o.4 6.2 2.2 7.6 46.1 Zion 1 Zion 2 27 20 25 2
- 9.3 14.4 ';6 6.o 49.2 2.8 3.4- 1.1 0.3. 3.7 11.3 Connecticut Yankee Indian Point 1 78 78 ~ 2.3 52. '.2 0.2 2.9 12.8 3o.8 Indian Point 2 44 10."1 9io 3.8 0.5 7.4 Big Rock Point 78 7,4 3.2 1.4 o.8 5+ 5 18.3 4.2 1.6 10.1 Palisades Lacrosse 51 78 8.9 1.5 '.87+ 5 2.2 o.6 2.3 32 3 14.4 Oconee 1 29 7.4 3+7 9.9 1.6 12.4 35.0 Oconee 2 22 13. 1 5.4 10.9 2.2 13.6 45.2 Oconee 3 7.6 5.4 5.4 2.2 13.1 33 7 Turkey Point 3 35 3.8 3.4 0.3 5.8 16.7 Turkey Point 3.1 4.o 3.1 1.8 4.o 16.o Hatch 1 4 27 ll 49.1 16.4 16.4 1.1-
'.4 87.4 Cook 1 8 28.5 18.o .6.o 52 5 Arnold 16 6o.8 -5.2 9.0 l. 5" 6.o 82.5 Oyster Creek .1 75 19.2 5.9 -
o.6'.4 8.2 37 3 Maine Yankee 34 6.4 "
4.2 1.0 4.2 16.2 Three Mile Island 1 14 19.7. 7~7 8.6 6.8 25 7 68.5 Cooper 17 25.4 12.0 6.4 9.2 53.0 Nine- Mile Point 1 70 7-7 5.5 0.2 3.'8 19.6 Millstone 1 57 ll.4 10.7. 2 5 4.1 1.0 0.2 0.2 10.1 35.7 Monticello 58 13.0 7.6 7.6 32 7
Ooeratin A.O. S~a~ Annual Avera es)
~Pe e 2 Avera e Occurrences Per Year Months in Testing Equipment Personnel Procedural Setpoint All Operation Occurrences Failures Errors Errors Drifts Others Prairie Island 1 23 14.1 6.8 4.2 1.6 13 0 39.7 Prairie Island, 2 8 7.5 7e 5 3.0 21.0 39.0 Ft. Calhoun 25 . 16.3 6.2 2.9 8.6 35.4 Humboldt Bay 78'3 2.6 2.6 1.4 0.5 1.8 8.9 Peach Bottom 2 32e 3 34.4 5~7 0.52 16.7 89.6 Peach Bottom 3 12 36.0 37.0 3.0 18.0 94 '
Fitzpatri,ck 8 22.5 7e5 3.0 42.0 Ft. St. Vrain 18 10.7 ll.3 5' 2.0 9.0'0.0 49.3 Ginna . 69 7e5 6.4 1.6 1;4 3.3 20.2 Rancho Seco . 10 -7 2 3.6'.8 1.2 1.2 6.0 19.2 San Gnome 1 78 3.1 ~
0.2 Q.S 5.9 Brovns Ferry 1 e 24 55 5~5 6.0 0.5 8.5 26.0 Brovns Ferry 2 12 2e0 7.0 9.0 Vermont Yankee 40 16.8 6.3 3.0 1.2 7.8 35.1 Surzy 1 37 6.8 12.0 5-5 1.0 0.6 10.7 36.6 Surry 2. 29 5.8 11.6 2.1 O.S 0.4 8.3 29.0 Point Beach 1 57 5.0 4,0 2.3 4.2 15.5 Point Beach 2 43 6.4 2.0 2.5 0.3 3.6 14.8 Kevaunee 19 13. 3 7.6 2.5 , 1.3 24.7
. Yankee Rove 78 3.2 2.8 0 9 0.5 2.9 10.3
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APPENDIX 4 RESOLUTION OF STATUS OR STARTUP AND OPERATIONAL JKlPOATABfZ 0CCUHRENCES AI"h0-73-.l 3 ACCN. No.. 81504 8186<<- The first and third abnormal occurrences experienced at Browns Ferry Nuclear Plant after unit 1 received an operating license concerned limit switches on the refueling platform, which are a part of the refueling interlocks and actuate as the refueling platform is moved over the reactor'ore. The problem with the refueling interlock switches stem from a lack of parallelism between the rails upon which the refueling bridge travels and the cern plate located on the refueling floor adjacent to the refueling platform rails. This caused the switches to move out of'adjustment on two separate occasions. 'ibis has been corrected on unit 1. The condition is eliminated in the construction of units 2 811d 3o BFAO-73-2 ACCN No. 81584 Duririg the initial fuel loading period, it was found and reported that the high voltage leads were disconnected in seven of eight IRM channel drawers. This resulted from the use of an inapplicable surveillance procedure. Iri preparing for plant operation, an instruction applicable to an operating plant was written. Because of the conditions existing at this stage of startup, a portion of the procedure had been omitted in application because sufficient neutrons were not
.present to perform the overlap between the low frequency and high frequency IBM amplifiers'. A portion of the instruction had required the leads to be discon-nected. The portion of'he instructions relating to reconnecting the leads was omitted. The surveillance instruction was amended when the condition was found.
This condition was probably not recognized as being abnormal by the instrument, technicians performing IBM calibration work because during the prestartup period,
~
the high voltage leads had been purpose+ left disconnected. BFAO-73-4 ACCN. No. 83261
'fhe fourth plant abnormal occurrence was discovered during a surveillance test following modification to secondary containment doors where the damper'ontrol system for the standby gas treatment system failed to limit the refueling floor vacuum to lj2 inch of water. The problem was found to be a combination of
. pressure switch setpoints and time responses of the modulating dampers, and has been corrected. BFAO 73 5) 73 10) 73 13) 73 15) 73 22) 73 26) 73 27) 73 33> 73 40) 73 41)
-'73-44, 46, 52, 1 (ACCN. No. 83217, 84019, 84214,.84496, 84876, 85322, 85323 85570 85737 8706 87070 87072 88368 8836 During a routine surveillance test, it was found that the setpoint had drifted on a main steam"line high flow switch. This is the only occurrence where a setpoint has drifted on a Barton switch Model 278. By far, the greatest number of abnormal
-2>>
occurrences have been caused by setpoint drift on Barton differential pressure switches. Fourteen occurrences can be attributed to this cause, all discovered during surveillance testing. The precise cause of these drifts has not been determined. h"ide from the setpoint drift, the switch ha" in each case operated propert,y and no disarrangement found. Instrument. engineer" 'f'rom outside the planl. have been brought Jn to evaluate our procedures and calibration techniques. On November 23, 1973, the vendor's field representative wa" at the plant. He provided a.new type of locking device for the switches which are being installed at the time of surveillance testing. See BFAO 74-10. BFAO-73-6 28 32 ACCN. No. 83216 85324 8558 Three abnormal occurrences were experienced on the Robertshaw HPCI condensate header low level switch. During construction the contacts on these switches had been changed from 1/4 ampere 250-V dc to 1/2 ampere 250-V dc. With the assistance of the vendor representative, it was determined that the 1/2-ampere contacts were not compatible with,the trip mechanism. Specifically, the new switch required a greater travel and greater pressure by the mechanism to operate the switches. The original type of switch has been installed and arc suppr'essors instaU.ed around the 'switch load to prevent contact arcing. BFAO-73-7 ACCN. No. 83 70 One abnormal occurrence has been experienced with a GE/MAC 555 flow transmitter in the core spray test loop. It was found that the transmitter was offset by approximate+ 2-1/2 percent. Following recalibration, no further difficulties have been experienced. BFAO-73-8 ACCN. No. 84014 On September 4', 1973,- a gear in the drive train of the HPCI steam supp+ valve failed. The cause was due to improper assembly either during manufacture or construction. Since we replaced the failed gear,'he valve has operated satisfactorily. BFAO-7 - 2 ACCN.. No. 84018 Several abnormal occurrences were reported as a result of a fuse failure in the HPCI it inverter power supply. InitiaLly, was believed that the failure was due to the inverter design in that a 125-V dc system had been modified to operate on a 250-V dc supply. It was observed on October 19, 1973, that the reactor vessel low water level alarm came in just before the fuse blew. On investigation, a wiring error was discovered. When the reactor vessel low level alarm actuated, a negative 140<<V dc voltage was superimposed on the HPCI auto-actuation logic circuit which shared common power supply feeder with the HPCI inverter. The wiring was corrected and this problem has not recurred. BFAO-73-11 ACCN. No. 841 5 h On September 10, 1973, during initial startup testing at 150 psig, the HPCI failed to reach rated flow and speed during' simulated automatic initiat'ion. Inspection of the flow controller revealed
~ l a "cocked" amplifier plug-in caused
-3" by a missisg anchor nut. To prevent recurrence, "Zocktite" retaining compound has been installed on all similar GE/MAC controller receptacle, fastener nuts.
BFAO-73-12 ACCN. No. 84012 On September 12, during plant cooldown, the suppression chamber vacuum breakers i'ailed to operate at a negative 1/2 inch of water. Vacuum breakers were manual+ operated by the operator at -0.6 inch of water. The instrument isolation valves had been left in the shut condition because they did not appear on the drawing from which the plant valve checklists were made. The checklist has been revised to require that each instrument be inspected and certified as aligned and operable as a part of the system alignment procedure. BFAO-73-14 ACCN. No. 844 3 One relief valve specified to operate at 1,090- 11 lbs., had, during the startup test period, been found to operate at 1,064> 1,068, 1,072, and 1,073 lbs. The test engineer had passed the valves because the error was in the conservative direction. One other valve specified to operate at 1,100 +-ll lbs., had, in fact, unacceptable
- tested at 1,103, 1,108, 1,113, and 1,114 lbs. The test engineer's comments indicated that this was satisfactory since'n no case did the valve operate more than three lbs. above specified limits and it was since another valve had tested low'. 'he technical specification has been amended to accom-modate these valves and the valves were changed out prior to commercial operation.
DFAO-73-16 24 ACCN. No. 84552 85321 On September 27, 1973, one stack gas monitor pump failed. Initial attempts to start the standby, pump were not successful because of a blown fuse. When the fuse was replaced, the. s'tandby pump operated satisfactorily. At this time, it was recognized that both sample pumps were fed from a common power supply through a common fuse. Failure of'he first pump had been accompanied by the fuse blowing which rendered the second pump inoperable. Both pumps again failed
.on, October 15 when it was found the motors had burned out due to low voltage by line drop. Subsequent corrective action has been the replacement of 'aused both sample pump motors with motors rewound using class H insulation. The power supply cables have been rerun using larger conductors and the power and control circuits have been divided including the fuses to the pump selector switch.
BFAO-7 -17 ACCN. No. 84553 On September 27, 1973, it was found that the instrument sensing lines between 'he flow. orifice and the RCIC turbine steam line high flow switch were reversed. This occurrence was caused by a drawing, error. Because of the location, it was not discovered until the RCIC turbine was operated on nuclear steam; that is, auxiliary steam used during preoperational testing followed a different flow path. This has been corrected. Drawing review and physical inspection has determined that this condition does not exist in any other critical system application.
4 During st,artup testing, a fuse failed in the HPCI inverter power supply. The fuse wa" replaced and the HPCI was operable within one minute. 8FAO-73-1'CCN. No. 84670 On October 1, 1973, a brass worm gear failed in the oper>ator of a reactor water
<<le>u>up ystem isolation valve. The valve itself operated weal,h normal freedom, and a replacement gear of the same type operates satisfactorily.
AFAO-73-20 ACCN. $ 1o. 84746 On October 3, 1973, control rod drive 54-27 was valved out with the control rod in the fully withdrawn condition. The purpose was to permit replacement of a leaking scram outlet valve seat which was contributing td excessively high temperatures in the control rod drive. 'While this'od was inoperable, it was discovered that control rod,26-55, which was in a fully withdrawn condition, could not= be moved with normal control 'rod drive pressure. Control rod 26-55 was subsequently inserted by r'aising its operating pressure and control rod 54-27 was valved in and inserted after the maintenance work was completed. In reviewing the situation, it was determined that a violation had occurred since the plant operator did not know with certainty at the time of the occur-rence that the operable control rods were sufficient to make the core subcritical in the most reactive condition during the operating cycle with the strongest operable rod fully withdrawn as is required by the technical specifications. Subsequent study has shown that the plant did not indeed meet this requirement, but plant instructions have been amended to specify that inoperable rods shall be inserted unless the plant nuclear engineer can certi+ taat shutdown margin requirements are met. BFAO-73-21 - Unit l. ACCN. No. 84875 During routine surveillance testing, a drywell pressure switch was found out of tolerance. The switch was thoroughly inspected and operated to determine the cause of the setpoint drift. The switches were recalibrated and operated several times to assure repeatability. Functional testing frequency was increased to once every two weeks until three consecutive tests proved satisfactory performance. BFAO-73-23 31 ACCN. No.. 84877 77083 85736) A repetitive source of reportable occurrences has been setpoint drift of the Barksdale vacuum switches installed on the turbine condenser. Replacement switches of-the same type were instal1ed, the calibration technique was changed, and surveillance frequency was accelerated to once per week until reliability had been demonstrated. BFAO-73-25 ACCN. No. 84761 On October 5, 1973, during startup testing, the HPCI was isolated due to failure nf the inner rupture disc diaphragm. It was determined from the appearance of ~ the diaphragm, that failure had been caused by repeated flexing "'caused by vacuum inside the turbine discharge piping. Rupture discs with,vacuum supports were installed.
BFAO-7 - 0 ACCN. No. 85 02 Approximately l,400 gallons of unanalyzed liquid radwaste were released to the river on October 19, 1973. While a batch of waste from the waste sample tanks wa 'eing discharged, the floor. drain sample tank" were placed on recycle for sampling. The 3-way valve used to recycle the contents of the floor drain sample tank was inadvertently placed in the discharge rather than recycle posi- . tion. 'lhe radwaste discharge monitor was in service during the release, and showed no increase in counts above normal background.'he activity of 2.077 x 10-11 uCi/ml at the stoplogs after dilution is well within the license limits. Procedures have been changed to prohibit recycling of a sample tank during a release from another tank. BFAO-73-34 - Unit 1 ACCN. No. 85566 The RCIC and HPCI systems were inoperable during loss of plant ac electrical power. The simultaneous loss of'ower to both instrumentation and control buses allowed two of the three relays, that operate on high reactor water level, to deenergize, satisfying the two out of three logic that causes tripping of the HPCI, RCIC, and reactor feedwater turbines. Immediately after the occurrence, the control schemes of the HPCI and RCIC tripping logic were evaluated and a design change initiated. The manual reset components of the tripping logic have been removed, thereby eliminating operator action following a "loss of return to" sequence of power to the tripping relays. To reduce the possibility of a simultaneous loss of'ower to the relays, the power source to one of the relays has been changed to the,250-U station batt'ery through an inverter. BFAO-73-35 ACCN. No. 8574 tI Upon the recommendations of the General Electric Company and with the authoriza-tion of the TVA Division of Design, a plant modification was mad in August 1973 which eliminated high water level initiation of h1SIV closure when not in the "run" mode. It was not recognized that this modification created a condi-tion contrary to material contained in the FSAR and Technical Specifications. - When the condition was recognized onNovember 13, 1973, reactor load was reduced and the MSIV's shut. In the generic sense, safety was never )eopardized since the modification had been thoroughly revi.ewed and detailed transient analysis performed prior to issuance of the various documents authorizing the modifica-tion.. This same modification has been incorporated in other operating BWR's. The technical specification and the FSAR have been amended to reflect the "as built" plant condition. The cover sheets for TVA Engineering Change Notices have been modified to require indication whether FSAR or technical specification revision is required by the proposed change. BFAO-73-36 ACCN. No. 85750 At 10:00 a.m., November 14, 1973, the HPCI inverter power supply fuse failed.. The fu"e was'mmediately replaced making the system operable. The fuse blew again at 10:45 a.m. The fuse was again replaced making the system operable.
At the time of the occurrence, plant personnel were conducting a surveillance test to check the newly installed 1/4-ampere switches on the HPCI condensate hen<i<:r. A high voltage spike was experienced when the conte<:I,s in this instru-menl;<l,ior< were opene<l, thun <ieenergizing l'e relay whicl<< <:tuaten on con<lens<<te hen<i<.r low prcssure. 'I'h.in relay is a pari, of the l1PC1 1<<l:1<<: u<<i i.". on the same 250-V <l<: bun as the invert<:r circuit'. f)urging the briei; inl,erval between fu"c failure and replacement, all remaining safety system" vere available. After l,he -econd failure, all work on Surveillance Instruction 4.2.B-26 was terminated until the problem was corrected. A spike suppressor was placed across the coil of the relay. Wen tested several times, the suppressor greatly reduced the spike experienced when the relay was deenergized and fuse failure did not occur. BFAO-7 -37 - Unit 1 ACCN. No. 8573 During routine surveillance testing, core spray pump discharge pressure switches were found out of tolerance. The switches were recalibrated and functionally tested several times to assure repeatability.'o problem was observed during the testing. An accelerated testing frequency of once every two weeks was established until three consecutive tests proved satisfactory performance. BFAO-73<<38 ACCN. No. 85738 At approximately 3:00 a.m., November 15, 1973, following the initiation of the loss of 25-percent reactor power, the RCIC system failed to operate when manually initiated. The steam supply -valve would not open. The HPCI system was then manually initiated to restore vessel water level to normal. Upon initial actuation, HPCI isolated and tripped. The HPCI steam leak temperature high
'larm was present at this, time. The isolation circuit was immediately reset and HPCI functioned satisfactorily to restore reactor vessel water level.
Reactor water level did not decrease to the automatic initiation level of the. HPCI and RCIC. The RCIC steam supp~ valve failed to open because a movable contact of the dc eontactox was hung on the arcing horn. No apparent cause of the HPCI system isolation was determined. Safe shutdown of the reactor was not affected because all remaining safety systems were available. HPCI operated satisfactorily after the isolation circuit was reset. The con-tactor on the RCIC steam supply valve was repaired to give suff'icient clearance between the arcing horn and the movable contact. The valve was successfliLly operated several times. Extensive eff'ort has been exerted to determine the exact cause of the HPCI isolation. Each area that will cause an isolation has been investigated. Calibration switches was verif'ied and found acceptable. of'll HPCI steam line space temperature The steam line differential pressure switches were satisf'actorily tested. Investigation during HPCI
-operation showed that the turbine exhaust diaphragm was not ruptured.
'eating due to loss of reactor building ventilation was investigated and no significant rise in temperature was observed with the ventilation off for a period of 45 minutes. It is possible that shock waves or vibration initiated the isolation since the isolation occurred concurrent with a main steam relief valve open. Special testing in an effort to recxeate as many as possible of the conditions present at the time of the occurrence failed to reveal the cause of the 'isolation. During this test, HPCI was manually
. initiated twice and was operated during a r'elief valve operation; At no time during this test was an isolation experienced;
"7-BFAO 73 1i2 Following; a planned scram from 25-percent, power required by -tartup testing, relief valve operated to reduce reactor pressure. At this time the HPCI suction va3ves realigned from the condensate storage tank to the torus. Sub-:
sequcnl, manually initiated relief valve actuations were. followed by HPCI suct5or> valve transfer. Level "witch actuations are believed to be caused by wave action accompanying the release of reactor steam from the relief valves through the relief valve discharge pipes, which are submerged in the torus water. This condition was repeatable on subsequent relief valve tests. Il. is possible that torus vibration, not water level fluctuations, induced level sensor actuation. %he transfer of the HPCI suction from the condensate storage tank (CST) to the torus had no adverse safety implications. The torus high level transfer of the HPCI suction prevents transfer of an excess of condensate water to the torus and maintains a minimum air volume above torus water (see BFNP FSAR, Appendix A, Section 3.7.A/4.7.A Bases). Since the HPCI is designed to perform its intended function without condensate supply (see BFNP FSAR, Section 6.2.ll, Safety Design Bases 11), and since the HPCI suction aligns automatically to the torus on CST low level, there was no degradation of safety. Although the transfer of the HPCI suction to the torus does not have adverse safety implications, it is operation~ undesirable because of the possibility of injecting torus. corrosion inhibitors into the reactor vessel. A modification was performed on the level sensor network to prevent actuation due to wave propagation resulting from relief valve operation. BFAO-73-4 - Unit 1 ACCN. No. 87076 Significant. vibration was noted in the torus and torus ring header upon opening relief valves during. startup testing. Extensive testing and modification were performed in the torus area. BFAO-73-44 During startup testing, a main steam line high flow pressure switch was found indicating incorrectly, caused by a leaking bellow. A replacement switch was installed, calibrated, functionally tested, and placed in service. BFAO-73-45 ACCN. No. 87071 During routine daily instrument checks, two core spray."sparger to reactor pressure vessel differential pressure indicating switches were observed downscale. An analysis determined that the location of the components required that a water leg offset, exceeding the capability of the instru-ment, had to be set into the switch adjustment. Snubbers were installed in the sensing lines and the sen'sing.lines were reversed. This" solved the problem. BFAO-73-47 ACCN. No. 87241 During an outage, a preoperational test was being conducted on unit 2. In the 'performance of the test, it was discovered that diesel generator A which serves both units 1 and 2 could not start and accelerate residual heat removal pump 2A. The pump motor would trip on overcurrent.
The voltage regulator had failed on the diesel generator permitting the generator output voltage to drop and not recover during the start of the 2,000 horsepower RHR pump. The voltage regulator was replaced and .tests performed to assure proper operation of the diesel generator. 'erc Rfi'h<h73->IU hCCN. No. 88126) The HPCI turbine failed to reach rated speed and flow during routine sur-veillance testing. The control valve came open on initiation but returned immediately to the closed position. An investigation revealed that a resistor had failed in the 48-V dc power supply to the EGN governor control box. The governor was unable to give the control valve a proper signal. %he resistor box was replaced and a surveillance test was performed to demonstrate operability. The turbine performed satisfactorily. BFA0>>73-4 ACCH. No. 88120 A seal leakage alarm indicated that the be11ows was leaking on the r'eactor main steam relief valve.- 2xe suspected causes are a failed pressure switch, leaking pilot valve be13.ows or bellows thread leakage. %he relief valve was removed and replaced. 01'AO-73-50 hCCN. No. '88367 l)icsel generator C failed to start during scheduled maintenance testing. A loose terminal connection was found in start circuit numbex 1. For testing purposes, a redundant start circuit had been disconnected. Under normal operating condition a failure of one redundant circuit would not prevent the die"el generator from starting. The loose connection was reterminated and the start circuit was functionally tested satisfactorily. BFAO-73-51 ACCN. No. 8811 During surveillance testing, the inboard drywell floor drain isolation valve failed to close. The valve did not operate due to the failure of a pilot solenoid valve. Lhe solenoid valve was replaced and tested satisfactorily. BFAO-73-52 During surveillance testing, a recirculation pump A d/p indicating switch was found to operate outside the technical specification limit. The Barton switch was recelebrated and returned to service. Increased surveillance was. initiated on the switch until the reliability of the switch was confirmed; See BFAO 7l~ 10. BPAO-74-2 ACCN. No. 88118 M Two main steam inboard isolation valves closing time was found out of'olerance during surveillance 'testing. FCV-1-26 and FCV-1-51 closed in 5.3 and 6.2 seconds, respectively. A single ad)ustment of the autoponent flow control valves. restored the closing time to acceptable limits.
BFAO-74-3 ACCN. No. 88 70 Two pressure switches in the LPCI break detection system were found valved nut following an outage. The switche" were returned to "ervice. In addition, all other instruments that were isolated during the outage were checked and found in ::ervice. Instructions were revised to include additional controls requiring certification of proper instrument alignment following maintenance work. BFAO-74-4 1 21 ACCN. No. 88371 8 316 434 These occurrences all involved the inability of'he air starter motors to start their diesel generators. The. cause in each case resulted from excess rust and moisture gumming'p the air starter vanes and not allowing them to turn freely. In each case the air start motors were cleaned and reinstalled or replaced. Modifications have been completed to eliminate moisture condensation in the air system.'FAO-74-5 ACCN. No. 88117 During surveillance testing, the shaft seal packing of SLC pump 1B was found leaking excessively. %he packing was replaced and the pump tested satisfactory. BFAO-74-6 ACCN. No. 88116 Nadioactive material was released to the unit 2 reactor building floor drain sump. Samples of the two unit 2 reactor building floor drain sumps were col-lected and activity above the maximum permissible concentration was found in the west floor drain sump. 'Jhe sump was decontaminated until clean. Modifica-tions were completed to prevent leakage between the unit 1 and unit 2 backwash system.'
BFAO-74-7 (ACCN. No. 88758) The grounding of a motor lead, two defective resistors in the EGM governor control box and the incorrect gain setting on the flow controller caused the
)IPCI pump to fail. during the performance of STI 15. Repairs were made to the motor and governor control b'ox and the gain was read)usted on the fl'ow controller.
STC 15 was completed satisfactorily. BFAO-74-8 (ACCN. No. 88757) A radiation monitor was removed from service for more than one hour during surveillance testing without providing additional monitoring. The procedure being followed was found adequate, but the personnel did 'not pioperly observe " the precautions. The, personnel received further training and the radiation monitors were tagged with caution signs to prevent recur'rance.. BFA0<<74-9 (ACCN. No. 89167) A main steam line relief valve failed to reseat following automatic actuation during a reactor isolation. The valve was replaced. The cause of this failure was a nut-keeper had become wedged against the valve stem.' modification to the nut-keeper arrangement was performed on all the main steamline Target Rock safety/relief valves to prevent recurrence. BFAO-74>>10 (ACCN. No. 89168) Two main steamline high flow switches were found out of tolerance. The switches were read)usted and the setpoint. lowered to compensate for, the switch drift. Refer to BFA0-.73-5, 73-10 '3-13, 73-15, 73-22, 73<<26, 73-27, 73-33,. 73-40, 73-41, 73 44" 73 46~ 73 52'4 '1 II 4/18/74 - A detailed study indicated that the ma5or cause of the drifting problem was interpretation and'pplication of the surveillance instruction. Two other contributing causes were identified. One was the calibration technique and one was 'instrument vibration. A retraining program was initiated for the instrument personnel and a modification was performed to add a switch;locking device to prevent recurrence of the problem. BFAO-74-11 (ACCN. No. 89152} During surveillance testing, the check light failed to go out when the vacuum breaker'valve was'perated. The cause of the problem was a sticking actuating plunger on the limit switch. The switch was replaced and the vacuum breaker valve operated satisfactorily. .BFAO-74-12 (ACCN. No. 89345) A main steemline outboard isolation valve closing time was found to be too fast during testing. The cause of this problem was an oil leak in a line to the dash-pot oil reservoir. The line was repaired and the reservoir refilled. The valve operated satisfactorily. As a precaution, the remaining seven isolation valve dashpots and piping were inspected; No indication of leakage was found.
BFAO-74-14 (ACCN. No. 89510) Following a planned reactor scram and subsequent reactor isolation, the HPCI pump was reported as tripping for uncertain reasons. Followup testing and calibration testing could not reveal any problems and the pump ran satisfactorily. BFAO-74-15 (ACCN. No. 89509) The rod sequence control system was automatically removed from operation at 26 percent thermal power and remained inoperable for 40 minutes. The turbine first-stage pressure switches misadjusted caused, this problem. New setpoints were determined with the feedwater heaters in service. The pressure switches were read)usted'to the new valves to clear the problem. BFAO-74-16 (ACCN. No. 89508) The HPCI turbine failed to reach rated speed arid flow during surveillance testing. The apparent cause was a malfunction in the EGM governor control box. The control box was replaced and the system tested satisfactorily. (ACCN. No. 89505) 'FAO-74-17 The vacuum breaker valve check light failed to come on to indicate the valve was closed. The cause of this problem was misalignment of the check light limit switch. The conduit supporting the limit switch had vibrated loose. Necessary repairs were done. The check light limit switches on the remaining valves were inspected. One other switch'as loose. After repairing the switches, all vacuum breaker valves were tested satisfactorily. BFAO-74-18 (ACCN. No. 89662) The RCIC failed to reach rated flow within the specified time during surveillance testing. A faulty 'transient, voltage suppressor in the EGM box was the cause of this problem. The EGM box was replaced and calibrated. The RCIC was retested satisfactorily.. BFAO-74-19 (ACCN. No. 89660) The removal of diesel generator "A" from service for a period of five hours with-out testing the other generators and the emergency core cooling systems was a violation of the technical 'specification. A detailed discussion of the technical specification was'onducted with operations personnel to prevent recurrence. BFAO-74-20 (ACCN. No. 89751) .The group "C" rods could be selected when group "A" and "B" sequence rods were fully withdrawn and the reactor was below 30 percent power. The premature permissive was caused by, an integrated circuit failure in the sequence logic board of the. rod sequence control system. The logic board was replaced and the instructions were changed to specifically require that no rods be moved except for SCRAM while the RSCS was inoperable.
'FAO-74-22 (ACCN. No. 90417)
The HPCI system was damaged by water hammer in the steam line. The steam pipe was visually inspected and all 'welds were liquid penetrant checked and selected welds were ultrasonically checked. Five pipe welds were radiographed. Other testing was done. The extensive inspection proved the piping to be sound. Repairs were made to the associated hardware and the system tested .satisfactorily. The operational instructions were modified to minimize large accumulations of water in the steamline. BFAO-74-23 (ACCN. No. 90641) The failure of the HPCl to reach rated flow in the specified time was caused by a defective transistor in tlie EGM governor control box and a defective potentiometer in the combined ramp generator and signal converter. Both defective assemblies were replaced. BFAO-74-24 (ACCN. No. 90626) The cause of this failure was due to a tornado. BFAO-74-25 (ACCN. No. 91673) The cause of the HPCI'system failure was not determined. A power supply fuse blown but no cause could be determined. The fuse was replaced and the was'ound system tested satisfactorily. BFAO-74-26 (ACCN. No, 91157) The main steamline relief valve was disas'sembled and inspected. The cause of the malfunction was determined to be a leaking pilot seat and a burr on the second-stage stem insert guide sleeve. BFAO-74-27 (ACCN. No. 92067) The cause of this problem was a design error. Testing and measurements proved the valve capable of proper operation. at BFNP. The testing permitted the vendor to upgrade the pressure temperature'atings of these valves.. BFAD-74-28 (ACCN. No. 92065) The torus spray valve problem was caused by the valve operator being separated f'rom the valve stem. The bonnet and motor operator were. replaced and the valve tested satisfactorily. BFAO-74-29 (ACCN. No. 92077) The cause of the RHR pump shutdown was disconnection of a relay armature tensioning spring. The spring was reconnected and the surveillance testing completed. An inspection of all similar relays was conducted.'wo other relays were found to have disconnected springs and were repaired.
BFAO-74-30 (ACCN. No. 92064) The RBCCW supply valve failed to open because a strainer in the water supply line to the valve diaphragm was plugged. The strainer was replaced. The frequency of strainer changes has been increased to prevent recurrence. BFAO-74-31 (ACCN. No. 92171) Pifteen of the sixteen pipe hangers on the torus support ring were found failed following startup testing. The cause of the hanger failures was contributed to a deficient design. Larger hangers were installed in accordance with design directions. A thorough inspection of the torus was conducted and minor 'repairs made to the" torus catwalk. BFAO-74-32 (ACCN. No. 92074) Failure to monitor the gaseous effluent from unit 2 turbine roof exhausts was caused by two radiation monitors which were assembled incorrectly by the manufacturer. All other radiation monitors of this type were inspected and found correctly assembled. Instructions have been revised to verify correct assembly. prior to installation. BFAO-74-33 (ACCN. No. 92172) The refueling zone to SGTS crosstie damper failed to open during a routine surveillance test., The damper failed to open because of. dried grease in a solenoid pilot valve. The solenoid valve was replaced and the damper tested satisfactorily. BFAO-74-34 (ACCN. No. 92073) The short in the HPCX pump discharge valve motor was caused by a badly burned commutator. The motor was replaced and the valve returned to service. BFAO-74-35 (ACCN. No. 92447) Followingan HPCI isolation, the HPCI inboard containment isolation valve could not be reopened. The cause of this problem was as a result of improperly sized drive gears. Replacement of the valve operator and motor resolved the problem. BFAO-74-36 (ACCN. No. 92446) The ~ater spill was caused by inadequate procedures. A thorough sampling of all'ossible affected areas was conducted by Health Physics. Analysis of all
,samples reveal'ed that no contamination resulted from the spill. A temporary pump was used to pump the w'ater into a unit 2, drain which connected with.radwaste.'
written procedure was prepared and the work completed satisfactorily. BFAO-74-37 (ACCN. No. 92607) The failure of this switch to operate was caused by misadjustment of the switch. o The switch was read/usted and the instrument tested satisfactorily. An accelerated
,testing frequency was initiated to prevent recurrence.
BFAO-74-38 (ACCN. No. 92634) The main steam outboard isolation valve closed to fast because of a seal leaking in the dashpot. A new seal was installed in the dashpot cylinder and the valve tested within specification. BFAO-74-39 (ACCN. No. 93735) The HPCI turbine did not: start because an oil relay valve piston was sticking. The relay valve was repaired and the HPCI turbine was started six times with no further problems. BFAO-74-40 (ACCN. No. 93736) The radiation monitor was inadvertently. left out oC service because the higlr voltage switch was turned off. The high voltage switch was turned on and the instrument returned to service. The procedure was modified to require verification of instrument operation prior to leaving the area. BFAO-74-41 A defective relay prevented 'two core spray pumps from starting during surveillance testing. The relay was repaired and the system tested satisfactorily. BFAO-74<<42 (ACCN. No. 94180) The. HPCX turbine did not start because an oil relay valve piston was not seating properly. The valve was repaired and a thorough cleaning of the oil system was performed. The turbine was tested satisfactorily. BFAO-74-43 (ACCN. No. 94599) The maximum average planar linear heat generation rate was calculated to be out of'specification. The cause of this problem was an error in judgment. An adjustment to the rod pattern brought the HAPLHGR curve within tolerance. The responsible engineers were instructed to maintain a more conservative margin between actual and limiting valves of MAPLHGR. BFAO>>74-1 - Unit 2 (ACCN. No. 94870) The seismic restraints were found to be inoperative because the manufacturer failed to lubricate the restraints during assembly. New restraints were installed and QA certifications were available to assure they were lubricated. BFAO-74-2 - Unit 2 (ACCN. No. 94946) The downscale indication on the steamflow differential pressure switch .was caused by several sensing linee. The lines were reconnected properly and the instrument performed satisfactorily.
BFAO-74-3 - Unit 2 (ACCN. No. 95106) The RHR pressure switch was inoperative because t:he contacts were wedged between the bellows plunger and the adju'stment nut. A new switch was installed and tested satisfactorily. BFAO-74-44 (ACCN. No. 95108). The recirculation jet pump riser differential pressure problem was caused by malfunctioning switch contact. The switch contacts were replaced and the instrument was recalibrated. BFAO-74-4 Unit 2 (ACCN. No. 95107) The HPCI isolation was due to spurious spiking of pressure which caused actuation of the differential pressure switch measuring steam flow.'nubbers were added to the instrument sensing lines and a three second delay time was added to the logic circuits. BFAO-74-5 - Unit 2 (ACCN. No. 95039) The HPCI exhaust line rupture disc failure was attributed to water in the turbine exhaust line. A solenoid operated drain valve had failed in the turbine exhaust drain pot. The solenoid valve and the rupture disc were replaced and the .HPCI turbine tested satisfactorily. BFAO-74-6 - Unit 2 (ACCN. No. 95040) The cause of the HPCI injection valve failure was not determined. The tachometer printed circuit board in the EGM unit of the RCIC was defective. The HPCI valve and the RCIC EGM unit were repaired and post maintenance testing 'was satisfactory. BFAO-74-7 and BFAO-74-10 - Unit 2 (ACCN. No. 95136) Foreign particles had. caused the poppets to both valves to become wedged in the valve bodies. The valves were repaired and the lines were flushed with steam. The valves were leak tested and the closing time adjusted. Surveillance test frequency was increased to monitor the above situation. BFAO-74-8 Unit 2 (ACCN. No. 95137) The failure of the RCIC pump suction valves was caused by,a defective torque switch. The torque switch was replaced and the valve tested satisfactorily. BFAO-74-9 - Unit 2 (ACCN. No. 95119) The cause of the two light circuit failures was determined to be corrosion on an operating plunger and a misaligned switch. All limit switches were cleaned and adjusted on the torus-to-drywall vacuum breaker valves. All valves 'tested satisfactorily. '0
BFAO-74-45 (ACCN. No. 95138) The RCIC turbine tripped on overspeed because the combined ramp generator and signal converter and EGM control box were out, of calibration. The instruments were recalibrated and the RCIC turbine tested satisfactorily. BFAO-74-11 - Unit 2 (ACCN. No. 95135) The core spray pump room fans failed to operate because of a loose power connection. The power connection was reterminated. BFAO-74-12 - Unit 2 and BFAO-74-54 - Unit 1 (ACCN. No. 96456) The outboard isolation valve on the main steamline failed to close in the specified time because of a low oil level in the dashpot cylinder. Oil was added to the dashpot cylinder and the timing was ad)usted. The valve tested satisfactorily. BFAO-74-46 (ACCN. No. 95429) The misad)ustment of the APRM flow bias SCRAM setting. was caused by personnel not following the proper written procedure. All instrument personnel were instructed to follow the written procedure. 'FAO-74-13 - Unit 2 (ACCN. No. 9555?) The problem'with the count/inoperative circuit was attributed to thermal drift. The thermal drift was caused by the cabinets being open during adjustment. The proper adjustments were made and the surveillance instruction was revised to set the ad)ustment in the conservative direction.
~g74 47 (ACCN. No. 95591)
The BPCI failed to start due to the failure of the auxiliary oil pump to start. The movable contact of the oil pump motor contactor was defective. The contactors were cleaned and aligned. BFAO-'4-14 - Unit 2 (ACCN ~ No. 95889) The drywell sump pump primary containment isolation valve failed to close because of un inoperative solenoid operated valve that controls the air supply to the isolation valve. The solenoid valve was changed and the isolation valve tested satisfactorily. BFAO-74<<48 (ACCN. No. 95882) The cracked pipe nipples in the RHR seal water line was caused by vibration. Heavier pipe nipples were installed and tested satisfactory.. A pipe support was added to reduce the vibration. BFAO-74-49 (ACCN. No. 95884) 1 The stainless steel pipe failure was due to the line being improperly supported. Vibration caused the pipe to crack. The pipe was repaired. and hanger modifications were made to adequately support the pipe.
BFAO-74-50 (ACCN. No. 95888) The cause of the excessive time between samples was that a sample pump had failed. The pump failure was not discovered until the ulloted time harl almost expired. Before another sample pump could be installed, the specified time had expired. The chemical analysis of the delayed sample proved satisfactory. l BFAO-74-51 (ACCN. No. 95601) The HPCI invezter failure was caused by a defective capacitor which blew a fuse. The inverter unit was replaced. BFAO-74-15 Un'it 2 (ACCN. No. 95902) The ventilation systems operating longer than specified without :adiation monitoring was caused because of the elevator being out of service and the substitute radiation monitor could not be installed. The spare radiation monitor has been moved to
'refuel floor and another spare ordered for a back-up for the spare.
BFAO-74-16 & 74-17 - Unit 2 (ACCN. No. 95906, 96455) The flooding from the gland seal steam condenser covered the gland seal condenser hotwell pump and a solenoid. This caused the HPCI system to be .inoperable. .The gasket was replaced, the pump motor was dried and the solenoid switch checked. The HPCI was tested and returned to normal. 1 BFAO-74-52 (ACCN. No. 96351) 8' broken yoke weld was discovered on the RHR loop one torus spray valve. The corrective action included adding heavier weld to the broken yoke and rotating the yoke;so'he strong 'axis was in the vertical plane. Design determined that the predominant vibration was in the vertical plane.
'FAO-74-53 (ACCN. No. 96559)
All twelve position indications for the drywell to torus vacuum breaker valves were lost. The. cause was .a blown fuse. A ground caused the fuse to blow. The one light thatwas shozted was disconnected and'ower restored to the other eleven. A temporary 'light was installed for the twelfth valve to indicate its = position. BFAO-74-18 - Unit 2 (ACCN; No. 96469) During surveillance testing during a unit outage, the relief valve on 2B standby liquid contzol pump opened at a pressure less than required by the technical specifications due to foreign material on the valve 'seat. The relief valve was flushed and bench tested, reinstalled and tested to the required specification. BFAO-74-19 - Unit 2 (ACCN. No. 96478) During an outage inspection a 2-inch stainless steel equalizing line was found cracked in the drywell. Vibration during operation of the RHR system in the shut-down cooling mode caused the pipe to fatigue at the toe of a fillet weld where the line joined to a valve body. Following an evaluation, the system was modified to eliminate the valve bypass line piping.
BFAO-74-20 - Unit 2 (ACCN. No 96470) During the first inspection performed on piping shock arrestors since nuclear heatup on unit 2, eleven arrestors were found to have low oil levels. The loss of oil was caused by damaged seals, improper alignment of oil cylindyrs, and damaged O-rings. These factors were attributed to poor workmanship. during the fabrication and installation of the arrestors. The defects were corrected and the arrestors were returned to service. BFAO-74-21 - Unit 2 (ACCN. No. 96471) During testing of the offgas HEPA filters assembly, abnormal performance results revealed that the filters were missing and the DOP sample lines were partially plugged. This was due to inadequate procedures during construction and testing prior to startup. The unit had operated an equivalent of 300 full power hours prior to th d iscovery, however there were no.airborne .release rates exceeded during unit 2 operation.
BFAO-74-21 - Unit 2 (ACCN. No. 96471'. (Continued) Following installation of the filters, baseline data was taken on the filter efficiency for comparisons. Additionally, to prevent the same thing from occuring on unit 3, verification of filter installation will be documented in the preoperational test of the off-gas system. BFAO-74-22 '- Unit 2 (ACCN. No. 97060) During operation at 26/ power, a low feedwater flow switch actuated premature~ and caused the recirculation pumps to run back. The run back caused the power to drop to seventeen percent. The runback occurred before performing the surveillance test to verify RSCS operability. Recirculation flow was increased to raise the power level back above the twenty percent point. The'instrumentation was read)usted to give more margin between the RSCS enforcement: and the recirculation pump runback. BFAO-74-23 - Unit 2 (ACCN. No. 97124) During the pexfoxmance of surveillance testing of the main steam isolation valves, main steam line "B" outboard isolation valve FCV-1-27 closed in 5.4 seconds as opposed to the 3 to 5 second. requirement of the technics1 specifications. Following an ad5ustment to the auto-ponent flow control valve the MSIV returned,, to its required closure time. BFAO 5 - Unit 1 (ACCN. No. 97117) The maximum linear heat'eneration specification was exceeded because of an unexpected variation in the LHGR between TIP runs. Technical personnel have been cautioned to maintain sufficierit margin to core operating limits. BFAO-74-24 - Unit 2 (ACCN. No. 97073) During an inspection following the operation of the HPCI pump, water was found in the gland steam hotwell motor. The water came from a blown head gasket on the gland steam condenser. Following dryout of the motor and replacement of" the gasket, the HPCI system was 'returned to service. Following the failure, an was initiated to determine the cause of'he over pressurization. 'nvestigation The HPCI system was removed from service because of a blown head gasket on the gland steam condenser. The head gasket was replaced. and the setpoint of the steam condenser safety valve was lowered, from 150.psig to 85 psig to prevent future over'pressurization of the head. gasket. BFA0>>74-25 - Unit 2 (ACCN. No. 97490) During surveillance testing of the SLC system, pump 2B failed to deliver designed flow. Investigation revealed that the seats of the pump inlet and outlet valves were pitted, preventing proper seating and,'therefore, low'low. The v'alve seats were lapped and the pump returned,-to service fol1owing performance testing.
4 ~
/
BFAO-74-56 - Unit 1 (ACCN. Ho. 97737) During surveiX3.ance testing, the RCXC turbine tripped, on overspeed due to misalignment of the control valve linkage. Slow response of the valve due to the binding of the linkage allowed the turbine to averspeed. The linkage was realigned and the RCIC turbine was started to verify operability. BFAO-74-26 - Unit 2 (ACCN. No. 97817) . While the reactor was operating at 372 MWt, the HPCZ power supply inverter fuse blew as a result of electrical fatigue rendering the HPCX turbine inoperable. The fuse was replaced restoring the system to service. BFA0>>74-27 - Unit 2 (ACCH. Ho. 97724) During surveillance testing, core spray infection valve FCV-75-53 failed to open due to being, Jammed in the closed position.,The cause of this condition was misadgustment of a limit switch. The switch was read)usted and the valve tested satisfactorily. BFAO-74-57 << Unit 1 (ACCH. Ho. 97736)
't During a routine inspection of piping shock arrestors~ three arrestors were found with a low amount of oil in the cylinder and one arrestor was found with the piston rod tom out of the pipe clevis. The low oil levels were caused by defective or worn 0-rings and. seals.. The arrestor piston rod failure was caused by a canbination of XnrproZmr installation and normal pipe vibration., All four arrestors were repaired and returned to. se'rvice.
BFAO-74-2 - Unit 2 (ACCN. Ho. 97%7) During startup testing of the main steam relief valves with reactor at 75 percent power, one of the relief valves failed to reseat following manual operations. The maloperation of'he 'relief valve was attributed to excessive pilot valve leakage..The relief valve was replaced with a new one. BFAO-74-58 - Unit 1 (ACCN. No. 97796) During reactor operation, the main stack gas radiation monitoring system was removed from service for a period longer than allowed by the technical spe'cifications to repair damage to the system caused. by excessive moisture in the sampling system. The moisture buildup was caused, by infection of demineralized water into the system by an inadvertent valve operation. Following dryout and cleanup, the system was returned to service. Administrative controls were implemented to prevent further inadvertant operation of She demineralized water valve. BFAO-74-30 - Unit 2 (ACCN. No, 98567) Following a reactor scram, main steam relief valve PCV-1-.4 stuck open. fo1lowing a manual operation. Reactor pressure fell to 450 pounds before the
BFAO-74-59 - Unit 1 (ACCN. No. 98568) During surveillance testing of the secondary containment system, wo dampers failed to operate. The failures were caused by sticking soleru;.i.l operators. The solenoids were replaced and the dampers operated satisfactor'.ly. Administrative procedures were revised to require periodic exes '.!si.ng of the solenoids to'revent sticking due to 'non-usage. BFAO-74-60 - Unit 1 (ACCN. No. 98704) During reactor operation, the offgas radiation monitor was inn.>c .:~'~le. An 0-ring in the sample flow rotometer failed causing an incrcas~ ."l.ow rate and a corresponding indicated activity increase of the offga.. a"-.etio'n
,monitor due to an increase ofshort-lived radionuclides. Fo.'.1~'.,":~ replacement of the O-ring, the monitor was returned to service.
BFAO-74-61 - Unit 1 (ACCN. No. 98712) A modification was performed without proper review and authori r,>on. The modification consisted. of installing dampening pins in the;vin steam line high flow pressure switch snubbers at the time the snubbc.. .~ere added to the pressure switches. It was recognized that the authoriz-~ ii>>i to install the snubbers had not provided for dampening pins and ':,h"4 a separate safet review would be re uired. The administrative control.". os:! modifications have been refined since that error to preclude future occurrence . A safety review of the dampening pins revealed no adverse effect:: bo the, and safety of the public could have been caused by the mr>>"ification 'ealth and the pins were left in the snubbers to improve performance. BFAO-75-3. - Unit 2 (ACCN.. No. 99199) The RCIC pump failed to operate during a SCRAM due to an open resistor in the resistor box which provides DC power to the EGM control box. 'e EGM could not provide a closing signal to the control valve resulting in an overspeed. trip. The resistor was replaced and the RCIC tested satisfactori+ during surveillance testing. BFAO-75-2 - Unit 2 The RCIC pump tripped while operating at a steady state. The o.cz 'peed tappet . nut had, rotated to the point it disengaged with the head lever cai "ing the turbine to trip. The overspeed tappet nut was realigned and 1'nkage setscrews were checked for tightness and the RCIC pump was returned. to sery'e. BFAO-75-3 - Unit 2 Main steamline relief valve PCV-1-4 operated spurious during normal reactor pressure due to a leak in both the second stage and'pilot stage valves. The relief valve was replaced and post maintenance testing completed satisfactorily. Refer to: BFAO-74 Unit 2, BFAO-74 Unit 2, BFAO 74 Unit 1, BFAO-74 Unit 1, BFAO-73 Unit 1; BFAO-73 Unit 1 for previous failures of this nature.
valve reseated. The valve was disassembled and the pilot stage disc seat surface was found to be wire drawn. The valve along with 3 others with similar problems were replaced. BFAO-74-31 - Unit 2 (ACCN. No. 98571) Following a reactor scram the HPCI pump i.solated during an auto-initiation. The pump was immediately restarted manu~ and performed satisfactorily. The isolation was caused by spurious operation of the excessive steam flow pressure switches. The spurious operation was caused by transient pressure sQkes encountered during auto-starts of the pump. Later modifications
,added short time delay to this protective feature to preclude unnecessary future isolations.
BFAO-74-32 - Unit 2 (ACCN. No. 98572) During, shutdown operations, flow could not be established in shul;:lown cooling loop 2. The no flow condition was caused by the disc of valve l~"/-74-66 being disconnected from the valve steam and stuck in the valv>> se:.r,. The tack welds between the disc and the steam guide ring had broken allowing the disc to unscrew from the steam. The valve was reassembled using a stronger weld between the parts to prevent further occurrence. BFAO-74-33 & BFAO-74-34 - Unit 2 (ACCN. No. 98158) During reactor operation at 594 MW; two main steam relief valves were declared inoperable due to bellows leakage alarms and. the unit was immediately ~ shut down to investigate the problems. Upon disassembly it was discovered that the, alarms were being caused by shorted alaxm cables near the relief valves. The cables had become pinched between pipe insulation and the steam, pipes during previous maintenance. The cables were repaired.: During the time the alarms were in the relief valves were stil1 fully operable both manu~ and automatically. BFAO-74-35 - Unit 2 (ACCN. No. 98573) During surveillance testing, RHR valve FCV-74.-66 failed 'to open. .Set screws missing from the yoke nut's upper bearing locknut allowed the locknut to become loose and unscrew. This allowed the yoke nut to move downward while the valve was attempting to open. The yoke nut. moving downward locked the
'operator and damaged the locknut, upper bearings, yoke nut key, and yoke nut.
The valve was repaired, reassembled, tested, and. returned to service. BFAO-74-36 - Unit 2 (ACCN. No. 98522) During reactor operation, drywell air sampling monitor RM-90-256 was removed
,fro'm service for 16 hours to dry out moisture that had gathered due to failure "of the two moisture-preventing light bulbs. Following the dry out and bulb replacement, the monitor was returned. to service.
BFAO-75-4 - Unit 2 Four shock arrestors were found low on oil during a routine inspection. Two arrestors had a nick in the sealing surface and two had wrong seals. The cause of these problems was attributed to poor workmanship during a previous rebuild operation of the shock arrestors. Refer to 'BFAO-74-57 - Unit 1, and BFAO-74-20 - Unit 2 for previous failures of this nature. BFAO-75-3. - Units 1 and 2 (ACCN. No. 99666) 'mproper time setting on the RHRSW pump Dl start sequence time delay relay TDl-1 'as caused. by an inadvertent moving of the ad)ustment know. The relay was recalibrated and the surveiLlance instruction revised to show an as found and an as left timing setting. BFAO-75-5 - Units 1 and 2 (ACCN. No. 99691) During the performance oi' batt'ery discharge surveillance instruction, control power was inadvertently removed from 4-kV shutdown board D, " rendering the EECW, core spray, and RHR pumps on that board inoperable. The instruction did not contain a step for transferring the 250V DC power supply to the 4kV shutdown board D emergency control bus prior to the test. Control voltage was restored to the emergency bus as soon as it was discovered missing. The battery discharge surveillance instruction has been changed to include a step to transfer the 250V DC power supply to the emergency bus. BFAO-75<<2 - Unit 2 (ACCN. No. 99707) A leak was discovered in a 3/4-inch test line during functiona3. leak test . of the core spray loop ZZ. The leak resulted from a crack in a socket weld to test valve 75-591. Vibration had.caused metal fatigue. The crack was ground. out and rewelded. Additional support was provided to inhibit vibration. BFAO-75 Unit 2 (ACCN. No. 100339) During unit operation, 120V control power was lost to the .RCZC flow controller, the suppression pool. level indicator, and. the drywell pressure indicator due to a selector switch in a 4kV shutdown board being in the off position. The cause of the switch being in the off position was not determined, but was apparently due to manual manipulation. The 'switch was returned to its normally operating position and, a surveillance test was"performed on the RCIC . satis factorily. BFAO-75-3 - Unit 1 (ACCN. No. 100362) Main steamline relief valve PCV-1-4 relieved prematurely. The cause of this problem was pilot valve leakage. PCV-1-4 was replaced. PCV-1-5 was also replaced due to previous irratic tailpipe temperatures. 'Ihe remainder of
'the relief valves were tested and replaced because of pilot valve leakage.
Refer to BFAO-74 Unit 2 BFAO-74 Unit 2, BFAO-74-26 Unit 1, BFAO-74 Unit 1, BFAO-7349 - Unit 1, BFAO-73 Unit' for previous . failures of this nature. E S
BFAO-75-4 - Unit 1 (ACCN. No. 101146) During surveillance testing the drywell oxygen concentration was'ound to be greater than the allowable 4 percent. The increase in concentration was attributed, to eventual mixing of air which had been retaineo in stagnant areas of the drywell at the time of inerting 4 days prior. To svoi<l substantial increases over the 4 percent limit, more frequent monitoring was initiated. BFAO-75-5 - Units 1 and 2 (ACCN. No. 101404) The'number of licensed. senior operators on shift was one less I.Iia<< required. The problem was caused by a scheduling error. The problem ha" b.c n <lisrussed with each shift engineer and the license held by each person vill. I~c posted on the duty schedule. BFAO-75-6 - Units 1 and 2 (ACCN. No. 101444) 1 During operation, a cable tray fire cause'd the loss, of several emergency core cooling systems on each unit. Extensive redesign and testing programs were performed on both units to preclude the results of a future similar occurrence. I BFAO-75-7 - Unit 1 (ACCN. No. 102267) The LPCI infection valve, FCV-74-2, was found inoperative due to the motor vibrating loose from the valve operator. The motor'as replaced by a spare and an inspection of motor operated valves required in the LPCE mode'as performed in units 1 and 2. BFAO-75 Unit 2 (ACCN. No. 103071) During routine surveillance inspectors, the manual drive water supply valve for CRD 50-15 was found in the open position instead of the closed position as required by the technical specifications. The reason for the valve being open was not detexmined. The valve was returned to the closed position. BFAO-75-8 - Units 1 and 2 (ACCN. No. 103104) During routine surveillance testing, diesel generator "A" failed to start due to rust and o~ grit in the air starters. The starters were replaced. A modification has 'been approved to improve the monitoring of the lubricator oil-levels; to ease the filling of oil lubricator reservoirs; and to add blowdown valves on the airline strainers to help eliminate moisture'n the air supp+. Refer to BFAO-73 Unit 1, BFAO-73 Unit 1, BFAO-74 Unit 1, BFAO-74 Unit 1, BFAO-74 Unit 1, BFAO-74 Unit 1 for previous failures of this nature. = BFAO-7 - - Unit 1 (ACCN. No. 103469) During cleanup activities, SRM's 1A and lB were inadvertently removed from service. A craftsman unplugged. the cable connectors to the two SEM's without authorisation while vacuuming and cleaning the drywell penetration in which the cables were located; The two connectors were reterminated immediate~ and administrative controls. were improved to prevent further occurrences.
<<25 BFAO-75-8 - Unit 2 (ACCN. No. 103636)
The reactor water level decreased 17 inches during a functional test due to the HlfB pump pumping water from the vessel to the torus through the minimum flow line. A scram resulted and in the sequence of events the I.PCl injection valve isolated and the minimum flow valve opened allowing the reactor level to decrease. .This event occurred as a result of a progression of steps consisterit with the present plant configuration required for the fire restoration activity. All operators were made aware of problems which avery occur during the functional testing. The second stage stem which broke during testing of a main oteomline. relief valve was due to having been drilled and pinned twice. 'll>e 'rilling resulted in galling and,overstress of the stem when the lock nut was removed. All main steam relief valves will be modified to, incorporate a new type locking device on the second stage. stem.. DFAO-75<<10 - Units 1 and. 2 (ACCN. No. 106647) An RHRSN, pump suppiying water to an EECW header did not .have a diesel generator power supp~ available automaticaHg because of'a violation of a work instruction. Following the discovery a pump was placed in service immediately which had diesel generator power available automatically. Retraining classes were conducted for personnel who can initiate work activities to stress the importance of observing all precautions and requirements of the work instructions. BFAO-76-1 - Unit '2 (ACCN No. 110318) Three design deficiencies were reported as follows: DDR-222 - The demineralized water system piping to the drywell was found to have class M inboard isolation valves several feet from the drywell penetration. A
'class "D" hand valve that is seisnd.cally qualified has been added outboard of the present outboard check valve. DDR-223 - During an analysis of the unit 3 steamlines in the determination of'he effects oi'ubstituting two Crosby relief valves for two Target Rock main steam relief valves, it'as found that during relief valve operation sections of the discharge lines were overstressed. Snubbers have been added to each main steam discharge line to correct this problem. DDR-225 - The drawing revision relief'alve necessitated by design change ECN L1140 which modifies the standby liquid control pump discharge relief valve piping specified schedule 40 pipe instead of'chedule 80 pipe. The SLC pump discharge piping modif'cation
'i11 be changed to schedule 80 pipe. BFAO-76-1 - Unit '1 and BFAO-76-2 - Unit 2 (ACCN. No. 110319) During surveillance testing, diesel generator "D" failed to respond property to the signal from the electrical governor due to low oil in the hydraulic actuator. Oil was added to the actuator and the diesel generator tested satisfactorily. The oil levels were inspected and found, satisfactory in all diesel generator hydraulic actuators;'
BFAO-76-2 <<Unit 1 (ACCN. No. '11037) During an investigation of the lZCI selection logic of the ltllR system, ~ design deficiency was found. A sin<!le component failure in the ICf loop selection 1 lol<c could possibly rr.'suit in four RllR pump discharges flowiru; l,o ~i broken linc causing runout of the pumps. This would be a potential l:hrenl. to lon>! term containment cooling. Adequate RHB pump protection against operation in excess of design runout has been provided and demonstrated for units 1 and 2. Refer to t,he final report on DDR-224 dated May 24, 1976, to Mr. N. C. Moseley, Director, Office of Inspection and. Enforcement, U.S. NRC, Atlanta, Georgia. BFAO-76-3 - Unit 1 This was not a reportable occurrence. BFAO-76-4 - Unit 1 (ACCN. No. 113198) The-.RCIC pump discharge valve would not operate due to a GE type SBM switch failure. The switch was replaced and a'eplacement program initiated on other SDM switches with similar defects. BFAO-76-3 - Unit 2 During RMCS retesting, five reed relay failures were discovered. Focus of the failures would permit the sequential selection and withdrawal of adjacent control rods when in the REFUEL. mode. One failure would allow two control rods to be withdrawn simultaneously in. all but.the SHUTDOW mode of operation. 1 To correct this problem, a voltage monitoring circuit will be added to the RSCS and a rod withdrawal prohibit circuit will be added to the RMCS on a11 units. The defective relays were replaced and proper circuit functions verified. BFAO-76-5 - Unit 1 (ACCN. No. 1I3954) During modification work in unit 1 drywell, welding slag fell on and ignited some breathing air hose. The fire was extinguished and. the drywell cleaned. in accordance with BF MMI 1.1-B. Sob orientation classes have been initiated. to train new foreman. Fire w'atches have been established. at all welding sites except where determined unnecessary'. BFRO-76-4 - Unit 2 and BFRO-76-6 << Unit 1 (ACCN. No. ll4201) RPV stabilizer bearing blocks are insta1led, 90 degrees from the intended orientation. Corrective action will be to insta11, new shims with increased . contact surface to meet the intent of the original design.
-27>>
BFRO-76-5 - Unit 2 HCU 30-31 was found incapable of being scrammed due to two valves being. in thc closed position. The interim technica1 specifications required the two valves to be open at a11 times. This problem was caused by personnel error. BFRO-76-7 - Unit 1 Alarm lights indicated water leakage by the accumulator pistons on HCRU 34-43, 46-07, and 58-35. Each HCU was removed from service and the 0-rings replaced. BFRO-76-1 - Unit 3 A blade guide assembly was being removed from the reactor as part of the fuel loading operation. During the removal, the blade. guide handle was broken and the blade guide dropped from three feet above the upper core plate back into the incore position. The blade guide handle was broken due to a malfunction in the telescoping grapple boom. All pieces of the boom and guide assembly were accounted for and the surrounding fuel assemblies, adjacent LPRM detector, and the fuel support pieces inspected. No evidence of'amage was observed..
APPFNDIX 5 BROWNS FHRRY NUCLEAR PLANT PHSOL)ITION OR STATUS OF 10 CFR 50.55(e) I 0!)NSTRUCTION RHPORTABLH DHFICI)',NCIHS ACCN. NO. 111395 UNIT 2 June 2, 1976 Use of improper schedule pipe in standby liquid control sos '2 . Final report dated June 2, 1976. Cause Design Error. Mhile exiri.2!ing documents associated with a change i:! the standby liquid control syste'2 an engineer discovered that schedule 40 pipe was referenced for the pump 2)i,scharge relief valve piping instead of schedule 80 pipe. No other e. mrs were found; The schedule 40 pipe was replaced with schedule 80 p')In. Drawings were corrected. UNIT 2 March 30, 1976 Failure of weld between the yoke <<nd motor mounting plat>> f:2 FCV's 74-58 and 74-72. Interim report dated March 30, 1976. 'Meld fai'v!..1. caused by vibration. Fix developed based on consultants'ecommendation (SwRI) ~ ACCN. NO. 94997 UNII 2 July 26, 1974 Loss of suction.to core spray pumps during preoperational testing. Final report dated July 26, 1974 'ause - Valve Failure. Dur!og pi operational tests, loss of suction in the common inlet line to 2 core spray pumps oc'curred twice'rom a maloperation of a normally open, manually operated butterfly valve in the line. Vibration of the disc on t)2e s'!aft caused keyway damage and allowed the disc to close part way. The vat.vo was rebuilt with modification to strengthen the disc-to-shaft joint. The modifications were made to all valves in this service.
ACCN. NO. 94999 July 16, 1974
'NIT 2 potential desi~ deficiencies involving the fuel handling grapple and the malfunction of the refueling platform hoist brake. Pinal report dated July 16, 1974. Cause Fabrication and Installation Errors. When the 10-inch section of the fuel handling grapple stuck in the 12-inch section, the grapple was parred while over the reactor vessel. Two sections fell onto the grappel stops breaking off some. There was improper clearances between moving parts. Jarring should not have been done over the reactor vessel. The electro-mechanical brake on the refueling platform main hoist'motor was found to be inoperable. The electric power leads to the brake coil were 'pinched in a conduit fitting causing a short.
The wires were replaced. ACCN. NO. 94243 UNIT 2 July 16, 1974 Operation with unrecovered steamline parts. Final report and safety evaluation dated July 16, 1974. Cause - Operator Error. During testing, auxiliary boiler steam was inadvertently introduced into the main steam line. The MSIV's were closed and steamline plugs were installed in the steamlines. One "of the plugs was blown out into the pressure vessel damaging 2 plugs., A careful search found 37 missing parts, leaving 6 parts unaccounted for. The control rods were removed and a washer was found. Analysis indicated a part could prevent with-drawal of a rod but not the 'insertion of one. Parts are thought to have been thrown out of the pressure vessel.
UNIT 2 .June 14, 1974 .
Possible design, deficiency in torus spray header supports. Pinal report dated June 14, 1974. See BPA0-7431W. ACCN NO ~ 89156 UNIT 2 Pebruary 26, 1974 Failure of the valve operator mechanism of FCV-74-73 in the RHR system. Final report dated February 26, 1974 'ause - Installation Error. During Preopera-tional testing, a valve operator in the RHR system failed mechanically. The locking nut failed to secure the .stem nut allowing the stem nut to rise up the valve steam without actuating the. valve. Staking of the threads of the locking nut was not done properly allowing the nut to move. Corrective measures were. staking of the threads through each of the 2 wrench holes of the locking nut. ACCN. NO. 89339 UNIT 2 February 25,= 1974 Failure of the operator for valve PCV-68-3 in the recirculation loop'. Final report dated Februar'y 25, 1974. Cause - Pabrication Frror. During preopera-tional testing, a valve in one recirculation loop failed to open completely .when the control switch was put in the open position. Neither would it close. The motor pinion had slipped along the motor shaft sufficiently to disengage the oinion from the gear train. Also, the pinion struck and broke the tripper spring of the hand wheel clutch mechanism. The set screw which secures the motor pinion was loose. It had not been tightened properly during installation. The valve operater was repaired.
ACCN. NO. 88768 UNIT 2 February 7, 1974 Failure of conductor 09 in electrical penetration FF. Final report dated February 7, 1974. One of 9 connectors in electrical penetrarfon RF failed. The connector had 35 pins of No. 8 AWG size and rating of 600 vac. The cable half of the connector failed. Intense Arcs had developed between some of the female receptacles and the bulkhead. Under ideal conditions the clearance was 1/16 inch. However, when the backing ring was tightened, the clearance was reduced. Also any contamination in this area increases the liklihood of breakdown. All cable end receptacles h'ave been replaced with ones having more clearance. UNIT 2 January 4, 1974 Design deficiency in control logic of the HPCI and RCIC systems. Final report dated January 4, 1974. See BFA0-7334W. ACCN. NO. 85746 UNIT 2 November 26, 1973 Manufacturing defects in'control rods. See TVA response to RO Bulletin No. 73-5 dated November 26, 1973. Of the 219 control rods inspected for manufacturing defects, 34 wexe rejected. There were 185 rods installed, 93 of which required minor corrections of defects. These rodd-needed to have 102 corrections made. Fighteen of the rejected rods were corrected on site, The remainder were returned to the vendor. ACCN. NO. 77082 . UNIT 2 October 29, 1973 Inverted control rod absorber tubes. Final report dated, October 29, 1973. All control rods were x-ray inspected for proper tube orientation. Of the 378 assemblies, inspected, 132 had one or more absorber tubes inverted. On an average the assemblies had 56 of the 84 tubes inverted. All absorbex tubes were placed in the proper position. ACCN; NO. 77081 UNITS '1 AND 2 October 15, 1973 Design deficiency in drywell cooling systems. Final report dated Octobex 15, 1973. Dux'ing the 'initial nuclear heatup of unit 1, Temperature readings in the top of the drywell reached 170 P., which exceeds limits. The heatup was discontinued, The cooling-air supply and return systems were modified to change the flow patterns. After .the changes, temperatures were below the 135 P., average limit except for one thermocouple, with the reactor vessel at 550P, Performance of unit 1 was observed during the early operating period before these changes were incorporated into units 2 and 3 ~
ACCN. NO. 86066 UNIT 1 July 30, 1973 Failure of FCM speed control and governor for RCIC turb5ne. Final report dated July 30, 1973. During the cold functional test program, the operator observed no indication of turbine speed although the RCXC pump was delivering 550'pm. A resistor in the electronic governor unit had burned out. Kt was replaced. Then an electrical ground fault developed at a diode from failure of the MICA washer that insulated the diode from the chassis. The gross<1 was removed. Next a thyrector in the governor unit aborted out. It was replaced. The RCIC turbine was then tested successfully. ACCN. NO. 82695 UNIT I July 18, 1973 Failure of HPCI level switches LS-73-56A and LS-73-56JJ ou the condensate ring header. Final report submitted on July '18,, 1973. During testing the two level switches which transfer the HPCI suction from the condensate ring header to the torus were found to-.have badly burned contacts. They had failed'n the closed condition. The switches were Robertshaw model 83481 levelac level switches rated at 1/4 amp at 250 vdc. They were undersized;, Switches rated at 1/2 amp were installed. 4 ACCN NO. 84880 UNIT I July 9, 1973 Coupling and gasket failures in the MJRSM and FFCW system.'. J anal report dated July 9, 1973. Several failures of equipment in the RHRSN and J'.HCV systems occurred when pumps were started that supplied water to these systems. Failures included an orifice gasket and 3 different dresser coupl5ngs. Equipment damaged: a "relief valve, building-to-pipe seal, and a pipe hanger. During standby, air entered the discharge piping of the pumps, and when the pumps were started, a water hammer resulted. Modifications ware made to keep t>>e pipes filled with water supplied from the raw-service-watez'ystem. ACCN. NO.. 84881'NIT I .July 6, 1973 Failure of RBCCM flow s'witches FIS<<68-53 and FIS-68-66. Final report dated July '6, 1973. Glass graduated flow tubes and glass observation windows on 2 reactor building closed cooling water system flow switches were found to be broken 2 days after the integrated leakage rate test of the primary containment. The glass observation windows imploded when the containment pressure was increased to 49 psig. The flow tubes were broken by a water hammer during refilling of the RBCCV system. The observation windows'were xemoved and the glass flow tubes were replaced with metal ones.
ACCN+ NO. 84824 llllZZ 2 May 4, 1973 Alleged noncompliance vith respect to maintainance of records of corrective actions on conditions adverse to quality. Final report dated May 4, 1973, in response to OZ&g inspection report. ACCN. NO. 81871 UU11 1 April 23, 1973 Portions of the SGTS and CRD systems were not designed to seismic Class I standards. Final report dated April 23, 1973. Analyses were performed for the supports on 2-inch, schedule 160 and larger piping, HCU anchors, and the scram volume tank mountings to determine their capability to vithstand earthquake loadings. Additional restraints were added where necessary in order to conform with seismic Class I requirements, ACCN. NO. 81880 UNZZ 1 March 19, 1973 Alleged failure to report design deficiencies as required by 10 CFR 50.55(e) and'ailure to document test results in accordance with 10 CPR 50 Appendix ST Pinal report dated March 19, 1973. Problem was the potential for entry of suppression-pool water into the HPCI tail pipe, vhich could result in pressure transients due to steam condensation at the rapidly changing .steam-water inter-face. Testing shoved there vas a problem, and TVA vas cited for failure to report. A second deficiency was failure to .record and report problem and design change to correct water-hammer in the HPCI and RCIC turbine>>exhaust line. ACCN. NO. 79004 UNIT 1 Pebruary 13, 1973 FJ.ectrical cable separation not maintained as described in FSAR, in that safety I channels designated Division and Division II are not separated in factory wired panels involving the reactor protection system. Pinal report dated February 13, 1973. All viring was reexandnated and an evaluation performed to ensure that cable separation criteria was not violated.
HR P0>fBL'L: Chairman g cLLe prepared testxIQony is 'thez length/ ~ X thought 't would he helpful if X could ask M-. Calho~~ to give us just a very brief suamary of it.. Xt shouldn't ta1ce more than 3 or 4 minutes.
.CERXRMM REXXZY: That should he helpful.
BY iMR PONBRXZ~: Hr. Calhoun, vouM you summari"e PR, s p'ep>>ed {N3 toss Calhoun) Yes o contends thatc upon the abnormal occurrence reports published by the Nuclear Safety Xnfoxmation Center, Chat TVA has earp~ienced an un-usually large amber of ahnozrml occurrences on Units 1 and 2 ac Browses Perry Xt.'s my opinion CE>e number of abnormal occurrences for these un'.ts at Bro~ws Perry is not unusual when a com-parison is made with the other plants and other utilities.
'I Xt. muslh be zea3.ized that. the tota1 number oK repor8-r ab'to occurrences does noC, provide a criterion for judging the competence of personnel to construct or operate a nuclear plan .
Por exwnple, cut, of all We reports made on Brows Perry, only two are c assified as hav'ng real safety significance under current BRC guidelines.
.One of these events ~ms. the exch 1922 -<<or the March 22, 1975,'ire, and the other:ras the discovery during
362 ta'Sting Qr'a c tNo Revel 8-:r3.tch - s >rara inopma-iva Tha. oparat'va smitchas woulrl have prevent:ed the proper operation o tha high-pressure pump that had haan called upon to operate automatically during an emergency. However, this pUmp +as haclmd up by two oCher systems w;hich were operating properly.'e har ~portent factors %thatch ER~~QQtzata that' QQ total numhaz of report is not a.prop r criterion rx'a: Wa difference in testing and reporting ecpxiraments p~aaM on each plant hy 8RC. This difference, plus ~~~a Q.ffaranca n tazpxetation of the requirements of the operator, can lea6 to a large variance in Cha n~~ az of each plant 8 evan if it is assumaC reports'owavaz, that the total num-ber of accurzancas is tha proper criterion for.judging comp-0ence, Bro~s'erry co~ares favorably with other plants. Xn response to Hz. Garner's contention, ea aslced the Euc3eaz Safoty Xnforrnation Canter at, Oak RiAge to provide us with computer pzintouts of the abnormal occurrences reported by all the nuclear plants. This printout pzovMed hy NSXC .at Oak Ridge amounted to 'about 4000 pages of occurrences ze<< pozeea durincr Wa construction/ startup and operatXon phases. cedures'~ The pzintouts ware fulmar broken cxomx into cate-gories such as equipment failures, GeHciancias detached during tasting, personnel errors an8 Qaficienc@as in >sxitten pro-Tha result of this co+pa=ison can be sunna-ized as
f0110MB Por l he const~>ction phase g x'lp'ound that Unit' at Brogans Perry had a total of twelve occurrences. Out of 112 plants in the United States, 25 had as many or more occurrences during this p riod. Unit 2 at Brooms Perry had 3.4 occL"ences, w~i3.e 18 other plants had as ma?~y or Kore Therefore, X must conclude that Bro".ms Perry did 5~ not have an unusually large number of abnozmaX occurrences during We construction phase. During the operating phase, the comparison shoes that Unit 1 ht Bzovns Perry had an average of 26 occurrences
\ t E
on an annual basis. Out of 53 reactors at other uti'lities, 33 had as many oz maze.
. Unit 2 had an avo-age of 9 occurrences on an annual" basis. Out of'3 x'eactors, 50 had as many ox ~reccuzzences Curing the operating phase.
Therefore, Brogans Perry has not had an unusual numb'f abnozma3. occurrences rXuzing this pha,se. The othe major p&wse is tho occuzcences during tho star@up of nuclear eqaX~i ent. Unit.l M-d a total of 120 occurrences during this p-ziod. Onih of =. total of 49 units, one oyez plant had more ~ l20'. Unit 2 at Brains P~ had 53 occurrences. W~ irteen
~
plants had more. I, ~
A Qe ailea ana1ysis of Unit 1 occurrences shows that approximatelv half of them vere reports on deficiencies discovered during the formal testing period. Xt is my opinion this nQRoer " 8 indicative of a good test program% g because the purpose of testing is to pili out equipment: and operating c"eficiencies o they xnan'e corrected before the plant is placecL in cc3GQercial operation~ Xncluded in the 120 total occurrences during'his pha e are 41 re'ports on a single proh3em involving iast~en-Cation set points and non-nuclear envw< oamental occurrences 30 concerning the River. Xn fact, only 14 of the~e P 120 occurrence" stere caused by personnel or procedural errors.
- Xf these factors are ta~:en into considqration, l3 the tas imony ~zilL sho~r. that Browne Perry campares favorably
'c with othir plants during the st~up phase..
)5 Xn my opinion, BrownePerry Nuclear Plant has not l6 had an unusuallyC large number of abnormal occurrences.
~what ccxmpletes the summary.
78 C 1 MR. -0%8LL: .~hat completes the presentation of our prepared test~~~~ ~w. Chapman.. 20 CHRXRlGQf, MXLM: Cross-exam'.nation, Mr. Garners MR. GIBER: Tes, sir. X'm in sort of an avkwa-6 position with this tab3.e. CHRXKRN BHXLLY: That. micxophone vill slip out of its holder. 25
~E. GIBER: T t's just leave it in there.
X will try to ma1-.e 'chis s~~ple by addressing ques-Cions to in X3.vi CQals Pl&re X WiQJZ X Rnoul 'Nhickl in6iviQQal vill be Wa proper person to answer the question. Othezw9.se, X Ui1 l alMress QQest9.ons to the panel QM g Whoever can ansi'ler 9:h g an~de~ CROSS-EZhMXHATXOH BV MR+ GAPER: First of all, X have a fee questions for .Bz. $ 0 CaM~oun. You,are presently the Ch9.ef of the Nuclear- Genera-t9on Branch, Division of Power Production, for the Tennesse Valley Authority. 07<tness Calhoun) Yes, sir. Does dmt entail supervision of construction or Just Operation of nuclear plants2 Xt entails the supervision of operations ance maint.,nance. Xt Goes not. involve the supervision of con-struction. Q. Mov, what are the cr9teria for the selection of 20 Chief of the Nuclear Generation Branch2 Xs th9.s a, written szaHl$ .nation? Ho, sir, it is not.
- g. He13., beer +me you selects? Mould you describe the selection process for Ke2 25
366 The selection process is'ased on a job aescription. Zt 'is preparea hy the D'rector of Power ProR~ction for GVA.. Hovl; Con"t reca 1 exactly 'shat the job description savs. gut soMe of th thine 8 ig includes i G~ g Qeliev at ~ least 10 years experience in a principal supervisory position r in TVA's nuclear or fossil plants. Xt says thar. a Qegree in enginee=ing is desirable, an8 it says that the person being consiaereX for the job'must
~ ~
s & meet the qualifications for the so-called Engirsem-in-Charge
~
ihat's prescribed hy the NRC. All right, sir.
~iIov, X believe you served eight years in the F~avy prior to the time you went to vsork for Tennessee Valley h
AQGlozity~ A5 K Les, sir. g, Dial any of your cbxties on th USS Oklahoma City or the USS Saratoga involve nuclear pcwer2 ~ f7 Xt ¹~c" not, sir. cG
- g. Hov, you also have a BacheLor of Science degree 9n electrical engineering zrora Tennessee Tech. Did you take any nucJ.ear 'physics courses vhen you vent to T nnessee Tecn2 X Cia not.
- g. Did you talkee any nuclear engineering courses vshen you 94~re at Tennessee Tech'5 Q98 not
~Tour, you ~rare. superintendent of che =::perimental GasKool GQ Reactor a c Oak Ridge ~ :is that. a aif aren'ype of reactor from the Brogans Perty reactor?
Zesg sirg it is~;
- g. You attended the Oak Ridge School of Reactor
. Technology. Did. &at involve leaning ha'z to run h reactor I ox engineering courses or physics courses, just briefly? Xt. involves basic engineering and= physics courses.
- t ~~oesn't involve dse pra~cical aspects.
Q.. Boiz 'ong did you go there? Approximately three months. Did. they give you a final eral'iiiration? E'fe took >reeklv ezams. X aidn't take me final 6"RlQ i Oh, you dMn't take th final w:am. Ho p sire
. All right Sou went to she Kerf-clay Huclear Power Station in Bristol, England. Nhat kind of reactor was that?
. &at:is a ga's-cooled reactor.
2~d you were Plant. Superintendent of the Brooms Perry nuclear Plant from February 1968 to July 1971, and all of that p riod sras during construction prior to the time i+. went into cperat'on. Zt %'Qs ~
368 ou ve been responsible for tne coord3.nation Qf ti e zestorat'on and modifications activities havep G2r
-- at. 3. and 2.
lIow, you also 3.ist yourself as a maaSer of the
- 6. Mvisozy Cauncel at Penn State. Oo you go up there pericdicall 7
I I and give hhen advice? And, if so, to who'o you give advice? 8 T go up there every year, about the mon h of I 9 October, and X g've advice to the Dean o+ the Engineering go I College and the Head of the ~~Iuclear Engineering Department. j Ho': long do you stay up th re? Approximately three days, two to three days. Q, Z.nd you spend .'l3 of this t~>>. talking .to the
~ l Dean of the Engineering School ard Bead of the Huclear Rngi-neer'ng Department?
Tal?:ing to his swxf and Ae Bean, yes, s'z. j7. Do you advise them ozally or in ~initing. Both. this group is a group oP. approximately six people. 20 X'm one of the siz p op"e. Q, Mo>>a, you vreze in England ~zorking on sone zeactor. Do you knosl whether or not they used light water reactors 1 Ro the Brooms Perry reactor in England or not? England does not use i hat type reactor ~ c'Q Do you J".now why hey don "c?
369 DQI 8" rg X Qo noa ~ I/ere yQU, "here 'Then they haQ the Wingscaj. accicIeltt? Ho 0" r X have a fe- c{uestions for i~2'. XngÃersen'.. You served five y=ars in the Un'it. Q StateQ: Davy.
,l p ~
Opqtness >ngwerseny Yes'xr ~
- g. Pa.6 yo ~ graduatect fzom.the Navy's I4uclear Sub-4 ~
marine Traipsing Program anQ the Mucleax'. over "~'~ii3.'ng Gci;oo
'OK'! long QiQ that progrc~iil last?
B.
" ' The fonaal school was six months. The prototype
.- training vi~~s about <<even zollths.
Q. 2 >2 the>t %as to learn about nuclear sQbmazines? Basically, yes, sir. Q. 0'id, you get. your Bachelox and. your Mast ~s at t'le" University of <missouri?
'Zes, s r.
$ 7 Xt st tes ¹re in your ctuaUfications you are presently responsible for the Division of Poder Production s I coori nation anct preparation of Znvironm'ental Reports and. Sta"mnents., Dict you h=-lp prepare the Bro!ms Perry Environ-ntal Report? I Yes p sir ~ 9, 2kt that time did the then Atomic Znergy Commission PA l also prepare HnvizorÃental Reports on TVP'ower plants? -.4
't Pn Environ!nental Report? Hog sir ~
369 Dog sirg Z 80 Riot~ Mere you there;A~en the~ haQ the "~7inQscale accident? Hog QBZ ~ I have a fez e{vestions for Kr. XngNersen'. Sou servers five y=ars in the Un>.C~Q Stately Davy. (7'fitness Zngrlersen) Yes g s-"r ~ Pz.o. you graduateQ from the Navy's Nuclear Suh-marine Traipsing Program ana the Ãuc3.eax- Po'a"-r '"~'riiing School. Hors long c~ iQ chat progzcUA 3.ast? Th= fonaal school ~ras six months. The prototype tzaining UQS about Seven 2'051ths ~
'at was to learn about nuclear si&maxines?
Basically, yes, sir. 9 OM you get your Bachelor and your Hasters at the".University of t4issouri? Yes, sir. V Xt sites here in your gua3,ifications you aze k pr sently responsible for the Divis'on of Poser Production's coordination and preparation of Pnvirom.eatal Reports and. Sta"<nants. Did you help prepare the Bror~as Perry Environ-mental Report? Yes g At chat time aicX the then Acmic Energy~ Coxnission al"o pr. pare Hnvizonmental Reports on TVA power p3ants? An Envi.ronmental Report? ~os sxri
370 I nLeant to sav environmental Statement. Hop s re Mon, you analys:ed the material xzom the Huclear Safety Xnformation Center and you supervised prepaz tion of the tables and graphs.
>1ov, dia you have anything to do with the prepara-tion of the nazz'at've descr'pt-'on of the abnormal occurrences that follcATG the graphs ~%ppexld3::c 4 axld 52 Th a- pzecedes it.'2 The narrative'".,
Q, Ho. X'm sozz. Did, you have anything to do with preparing Zppencliz 4 and 5? iX'ppendix 4 and 5. Appendi-. 4, X had some input . there, yes, siz. Coordination, basically. Al3. right. X call your attent=:on to Appendix 2, Construction AO Smeary. 7'Jere you in the courtroom zQ>en we <vere discussing pressurized water reactors and boiling mater reactors with . the Board? This morning? Yes ~ Yes, sir. Rl3. right Not~, over in your narrative testimony, page 3, paragraph 2, it states:
"The Construction Abnormal Occurrence (A.O.)
'Surmnazy table in Zppanaiz 2 shows that Bzo~rns Perry Un t 1 hate a tot a 01 12 occur ences g ~ikkilc 2S unxts ba8. as Blany or mo. 6 ~ Unit 2 haQ a to col of 14 occurrences, czhile 3.8 units had as many or more."
B&ct you said "Thus, Brogans Pexzy has not had an unusually large nu>fez of occurrences Curing consiruciion as all. ged hy the Intervenor, hut rather compares favorably 'arith other zeactors." Ax'e you hasing your thought that yC;u dian't have a large mwlber on howl they coatpare Edith other reactors axed not. gus) taken Dy itself' (The panel conferring'.) K )Vould you repeat Chat., pleaseV
- g. Wlell, <re Qzdn I t. hi.ie bqi one nuc3. CL ar reacior in the. Unite8 States let.'s just say ve 8Mn't have anything but Brooms Perry and 2 and you had no~~ing to compare 3.
then "o- you could still looR at. some numbers and say "Me had, a large nur~Aez or small numbez.'" chill zightg
~a7ov, aze you familiar aith which of these reactors in Z.ppencfi:r. 2 aze ~i-hat are callea Boiling Mater Reactors ance
<<hich aze calleD Pressurized Hater Beactozs'? Yesg sir~
37 bl.b 10 Did you do a study -- during the course of doing 2 this gdid you breast, t "his do'8n and Qo some fig~u:es on, Just Boilirg Hater Peactors as compared to Pressurized plater I Q R actors2 Hot:mile we a~ere preparing this testimony.
- 0. Have you done it subsegQent to that?
Yes, sir. All right. Xf X 'Ms to te11 you that your testimony says Brogans Perry 1 had 12 abnormal occu-zences and 25'ad as many oz more, c~hen you compare them with Boiling Water Reactors, 12 not considering Pressurized Efater Reactors, did. you discover . 03 that only six had as many or more'han 12 (Ritness zeading document.) 15 X Mon't quarrel wraith that. And vere t~;o of these not Brogans Perry 2 '- vere two of i2i se five not Broils Perry 2 and W4w".x',8 "erzy 32 That 8 correct e Al1 z3.ght ~ Let's ta!m a laos at Brooms Pe~~ 2. Xf you thro~rs the PP<Rs and BPBs together, Szo~ms Perry 2 had 14 occurrences and only 18 had as many or more. Now, if you confine that to 3NRs, hoer many had as many or more than Pro>ms Perry 2, if you know2
373 221X'88 ~ AQC". >riYS OXi8 OX 'J OGL+ BEGS}AS BX'Z'V 3P TQBQ 8 GOX'X'PC
374 All right. Xet us go Gown to Ppage 3, Paragraph 3, an@ you staie Chat in the operating table Brooms Perry 1 had 26 occurrences while 33 units had as many or more. How, we confine that to boiling water reactors, ho:r many ha8 as maxly or more? This is on the operating smranary2 Operating surmnary,. Unit 1, correct%'es? 10 That would be from the annua3. average table. Yes2 13 X count 3.5.
@11 right. 4 Now, while ue are on the average, annual average Cable,you took the number of months that the reactor was in 17 operation and you came up with an annual average figure, anQ you show that Bzowns Fm~ 1 was, in operation for 24 months, an6 Bzowns Ferry 2 was in operation for 12 months.
Da you laxcw how much Covn-time those two units haQ Curing that 24-month pezio8 an6 that 12-month pezioCP 22 He could not compu"e that. 0 But is it we11, te11 me how long Browns Ferry 2 haQ been in co~ercial operation at the time of the fire2 Xt was approximately for three months.
37S Oh, gust a minute; it vas tvo to three months. All right. Cou2.8 you tell me how long Brovns Perzy 1 had heen in corm~ezcial oparat9.on, appxozimaiely, at the time oZ the inarch 22 Hze2 Xt vas approximately six months. A2.1 xight, sir. SLL1 right, X am going to Qigress anQ ask Hz. Cant-a zeQ questions. 30 Now, from 1949 to '52 you vere employed hy We Factory": insurance Association as an inspector; vhat vere you inspecting2 Xn8ustrial hazards, risJm. Q . Here you inspecting in6ustzia1 hazards an@ t risks ai nucleax pove- plants2 A No ~ Di6 you take any nuclear physics courses Ho, six. DM you ~he any nucleax engineering courses at Uandexbilt2 Ho sx,r All right, sir. 2c3 All right, Hr. Greeny ho+ QM the Navy Nuclear 2b Submarine Training Program that you vent. to hov long Qil it
376 (Idr. Green.) Which part of the training are you r.ferring to? The Navy Nuclear Submarine Training Program? A X went to six months, Advanced Nuclear Power Training School, in New London; and that was followed by a period of time at Hest Hilton, New York, which was training on a subuarina reactor, prototype; and the Czaining program there was of three months'uration. Did you talce any nuclear physics courses at, We Naval Academy? Same nuclear physics was included in Che physics couzses X took at. the Naval Academy. Can you remember one semester? t;fo No. X would prefer to rely on my advanced nuclea power training for the nuclear physics courses X took. That -was si, months for one and three months for the other2
'es, to my recollection that is right.
0 And you succeeded Mx Calhoun as the superintendent< plant superintendent, for the nuclear plants? true>> All right.
,Now, as X recall, Ib.. Green, there was a
similar fire to the March 22 fire, two days earlier), involving a candle; is that correct? . Xt was much smaller. Zt was a much sma3.1or fire, hut it was the same type fire? This is true. Xn the sense that it. was caused by a candle? This is true. Now, did not management of the plant have a meeting after tl:at fire and discuss it? This is tzue.'iov) vere you pxesent at Ale meetxGg? No, X was not. Q X don't mean to invade your privacy, hut, con-sistent with invasion of privacy, could you tell me why you vere not at the meeting? Bt that meeting? X was away from the plant on company bu89ness ~ Rhea d9.d you return to the plant? I returned sometime on Priday) the 21st. 2Q1 r9ght. Did the Assistant Superintendent bring the problem up with youP Yes) sire
%mt was your reaction?
378 W the time the fire had been reported but very little was Jmown about'it, and there was conflicting information as to vhat actually transpired. Some of the plant supe~ision thought it,was located in the unit 3 area of theplant structure; one plant supervisor thought it had to Qo with an acetylene torch; the type of fire and location was not kno~m," and the Assistant Superintendent had assigned people to investigate and find out what happened. And ab that time the results of investigation were not hack. 0 Nell, in a'situation Xi1ce this, would it be out of the ordinacy to ) summon people up to your office and find.'out what happened, zather than going through a gzeat length> of time2 X did not. You and IIr. Ca3.houn, the day of. the fire, discussed. Nhethez or not to use water on the fxxe2 hXR. POORLY:. Nr. Chairman, X object to the question. X don't think it is relevant. to ouz prepared testimony or to the contention on the number of abnormal occurrences.
ÃR. GABNER: This is one of the ahnoa~
23 occurrences they discuss in their testimony. L1R.- POVTELL: Nay X remind the Board that, sir, 2Q you have already.. ruled that the specifics of any abno~l
37eJ occurrence are not relaiive to adjudicating the merits .of Contention Mo. 2, hut, rather, the total number af abnormal occurrences as compared with othe plants, is >he way Contention 2 should be adjudicate'd. CH3ZKRH R~XLTY: i~u. Powel3., now you bring that
~
up, the fact is X thinker it yas in response to a motion by TVA in opposition to having .'o produce all of the details 8 'n 'all these abnormal occurrences; but beyond that, in TV@'s dire t testimonv here and "t, has been stated several times 10 this morning that the. total number is not very important X am quoting now from direct'estimony: "0 primary importanc $ 2 's the safety significance of an occurrence." $ 3 X this'he door is a bit open to explore this
- a little bit. further. X overrule your objection.
BY M ~ CABER: '1G All right, Rr. Creen, if you had to .do it. over again, wouM you use watez. - early on2. (Mr. l re~~.) fiie No'You would not2 'Xf you had that sane tomorrow you would not. use vrater2 That's all, you answered the question. CBAXK~QN HHXXTV: X didn't hear an answer to. 23 Was there an anom to your qaestion2 t'K GiQK~TER He said no Has that. not correct2
380 NXTNESS GBHEN: X think you changed the question when you repeated it hector. to me after X said "no" this
'arly OQ bit?
CHAXRMiQP BEZXZ.Y: Nell, ace can get the reporter to read the question. (PBlercupoxL g the reporter read froRL the record g as requested.) 8 MR. PGHELL: blr. Reil3y, X would suggest, the witness is ent9.tied Co ac~3.ain a yes-or-no anmcer. CHtkXK%27 RBXLXY: Not only i5xat, hut X think the last version of the question was not specifically answered; and X would like Co have the witness address that question, 23 please. 24 9ETHESS GBEKt:, K'hmQc you, Mr. Cha9.rman. At this time X Jhow that early application of water i.s the way to stop a fire Ln the cab3.es. Now, the question was asked "would X, in the timeframe when X was at $ 8 hhe plant7" At that time X mould not have, because we had Two things involved: One, was the fire; and the other was controlling the plant, using effect ical circuitry involved in the fire. Bt that time X had to make a decision, and the decision was that the safo shutdown of the plant using the control wiring whfch went through the fixe area vas more significant than the monetary damage of the fire.
jzbG Xt. has been pointed out, and X will agree that the longer a fize bux'Qs g the more damage it 9.8 going to Qo ~ Hut, at the'time '~hen eve frere 'crying to stabs.iz the reactors, had ve not used water to that time 0 X wouM not, use it.- (2VDKKM REXLLYz Co U>ead. SY HR 6~4ER: 0 '13. right, K".. Green, mould you tell me +hat mpezience you.have had in fighting oz in making dec9.sions zelat9ve to xire fighting prior to the March 22, 1975 fire?
$ 0 A (Iw. Green.) Six, my en ixe car er has been 9.n decision-'aking.
Relative to fire-fighting? X wa.ll lead up to your answer, Nr. Garnex. Very mell? 15 X have never actually. fought a large fire befoze, but my naval training started may back befoxe, as X put in.my qualifications, as an ~ld.sted man in the navy +here
>re had fire-f9.gh~4g. 77hen X vaunt to the Haval Academy X studied damage control, fire-fighting. Ny shipboard experienc hot3> on surface ships and in submarines, included fire-f9.ghting and contxol.
And X do not. claim to he a professional fireman 0 or a professional fire-fighter, hut X think X have a broad background in and professional training and experience tovards ) handling casualty s9 tu@t9.ons ~
382 B3.1 right, Mr. Green. after the advice of the xire chief was Zina11y taken.and the fire vaa put out, a11 water aircu3.ating pumps, both primary and emergency vere running and you have been quoted as saying "M. that point we Bidn'C Jmov what the he11 ve were going Co have Co 8o". Eszplain what you meant? Ohg yes@ sir~ X vas slisquoteda Hisquote8 hy vho, and explain hov you vera 16isquot8AX? A That happened to he a quote Chat. appeared in r the Readers'igest, and Che man who vrote the article vas questioning me intonse1y on vhy ve had ctevoted so much energy and effort to cooli .g the suppx'ession chamber. Bad, as you probably don'C Jmov >>>> hut nuc1ear orien¹Q people vi11 this is a heac, sink Chat ve vere using to put decay heat in. And a1though ve vere not near a Xindt, good operating practice.dictatecL ve line up cooling to incxease ox maintain abiLity to use this as a heat sin!c. And X kept trying to explain to this man ve wanted'o he reacLy for any eventua1ity, and he had read some of the ZPC testimony in P~ where it saicL if it hacL gone to the boiling point it woi~M just he ventage off; and he saicL, "uel3., you Qi.dn'C need to cLo thisP"
383 X kept saying, "8 11, tre wanted Co he ready for anything that happened." Fina).1y, in desparation, because we O'Qn'- know what the he11 was going to happen; and Huis was really in che fire scene that X was MI:ing about. Ks he wrote.jt, he connecteQ it to an event that transpired 1a er in the afternoon~ FW. SHOD: Excuse me for a moment, l&. Garne . X would'1i!ce a little clarification. X hei'eve you Qo have a specification that the pool c~~ go top Qo you2 NXTHESS GHENT: Yes, sir, IM. SHOH: You vere ~ing ho stay he1ow that2 NXTHESS GREEN: Yes. lined we Bid get to speci"i-cation limits. KR. SHOM: How we11 will the suppression poo1 perform its vapor function if the temperature gets too high2 NXTBHSS GRSEM: X am sure you realize the con-cern of the over-temperature is to lose pump suction? BR SBOM." Yes2 But X am asking about th other aspect, nov2 NXTNESS GBEEH: Qhich2 tCR. SHON: Suppose the temperature was too high, then how we3.1 wouM it perform its vapor suppression function ~ if 'HQt vere ever necded2 NXThESS GREEN: Xt crould X don'. Mow her to
384 jxbll he quanticativr= -- bu it vouM obviously as it. heat@4 up, it would lose its condensing ability compa=e6 to rector steam; if it got, to 2l2, it xrouM he ineffective completely, X hD3.eve. MRa SHOD ~ KYLE DieanHhil&y of course g if you axe using that vater for cooling, you Con't vant the caps to vapor-loc1c7 rVmZSS Gasp@: This is true. 2'1R>> SHOLEM ~ ~Ahank you a BY HR GAKDR Q All right, Hr.. Gz'mn, the press conference on March 24, 2.975, folloving the fixe, you vere quotcxk as saying, "The shutdovn is a tragic thing. X say it's an inexcusable thing."
%mt Oi6 you mean by it. being "inexcusable"?
{Yir. Green.) That %as a reflection of my own 17 personal emotions at, that t~4 , an6 +as not based on any results of investigation into the cause of the fire.
. And it vas just zemorso tMt We plant. +as in that condition.
You must @member, ~s vas right after the fires X haC been at the plant continuously; X vas tire aaQ 23 sad.. You said it vas an e~x'ession of "remorse"; 25 Mr. Gre~~, rernors usually has connotations of guilt feelings.
gzhl2 Did you Rel guilty about the fireP Dic. hat bring on your rmnozse, because you felt guilty abut the fire happeningV X was certainly conscious Mat X had been trusted by TK and the people bf th3.8 country v9.61 818 overall responsQmlity for that plant; and at that t9me the plant +as not ab" e to perfon".. its intended function. This is a pretty heavy burden to.carry. tushy d9xl you feel "esponsible for:the fire, X didn't say X felt responsible for the fire. X felt responsible for Qe entire plant. Pall, why Qidn't you feel. responsible for'the fire." if you vere plant supezintendent2
- m. PamS~T.: nr. Res~ly, X think this line 7
16 has gone far enough. CHAXHEQA MXLX~Y: Yes, objection sustained. YR. GEQKER: Can X have five miuutes2 CHAXK&27 MXLLY: Certainly. Let' take l0 20 (Recess.) CEGHRI'%at iKXLM: The hearing room vil3. please Colfle to Ordead' Nz. Carne-, proceeds MR. QARHHR: X believe Mr. Calhoun wanted to
386 correct something? VlXThTESS CALHOUN: Yes, sir, X mould 3.il;e to make a correction to &e'test'~~ny concerning Lhe time that-the units >sere in operation, in commerciaX operation before the fire. He looked, this up anQ it was about 8 months fax unit 1, and 1 lnozlth for unit 2. BY HR GABNER Eight, amnths for unit 1, end 1 month for unit 2'?. {Hr. Ca1houn.) Yes, sir. 0 So tzhen ve look at, annua1 averages in months in opmation and we see Brains Perry 1 come out at 24 months, and Brows Perry 2 coming up for 12 months, ve've either had some Conan-time or ve'ra running hack into start;up testing; pren t veP (Nr. Xngversen.) Yes, sM, that is correct. Ance X ¹lieve that ve arbitrari1y put. start-up from..the time the operating permit t as grantek, is, that right; is %at corrects Ne had to Craw an arbitrary line) P>norma2. occurrences are reportable an6 begin at the Cate the O.L. issues; ve starters start-up as of tImt tdxm; yes. 2Ql right, sir. X vi13. as'". th9.s m~estion to tho'panel. RP.. SHQH: Xf you are going to 3.mva the point
about the total ember of months, X would like Co ask a cpxestioQ ~
" PER. CiQBKR: Certainly.
MR. SHOM: By chang9ng the total monks in operation by a facto= of about one and a half in the case ox Ro. 2, and about 2 in the case of Mo. 1, is that the number that you used in the denominator to get your total numbers? And does it, not change all those?
.TilXTNESS XHKiVVSEH: He used the months in operation as the denominator.
2K. SHOR: That's what X thoughv.. Fe13., does this not change all the figures in the table? MXTlKSS X8$PRSEH: Ho, sir, we used the same thing for all plants, whether they were operating or not operating; we have no way of knowing how long each unit was Gown. Ccaamezoial operation Goes not. have anyWing eo Qo abnoxma3. reports are not submitied during Qovn-times. fat. SHOD: What you are saying is. your ocouxren 9s used as the denominator, not this so-oal3ed operatiug time, gust the length of operation in toto; and Chat is the same for all reactors; and that same basis for comparison was used for all x'eactors? HXTHE88 XHIKRSEB: Tes, sir. MR. SHOH: Thank you.
388 DR. CGA%AM: X vamped to he sure X understood CI'Le printout material 'f'3e received a X tM.rQ: the way ~De stax'M-Qp period Was ta!zen to be the first yeai" afc.e>> yoQ received the operating 3.icense; and then tho operating period was taken co he a11 time after this first year;y is that cozzectP NXTNESS ZNGWZBSHM: Yes, six. DR. CGA: That is the basis on vihich Cha events per y~~cY 0 'peration %7~~ dete~neOP 5TVZMBS XhlGVHRBEH: Yes, si-. M. COIGN: Thank yon. CHRTRPZZI HEXLLY: Nr. Garnez? SL~ i~A~ QMCKR A11 right, if on March 22nd, a workman had succeeded in putting olxt the fire QQD.cklvg snuff~<g it ont Mick rags or a f1ashlight or thei- hands, Mould this have been considered a serious occurrence, oz a safety-related occurrencef (Mr. Calhoun.) Mr. Garner> X would have to @Cess Qs to What wM MQQ16 have 'done Axe thzLt, particnlar case X vouM surmise ncaa it probab3y ~muM not have h~si consMe=-ed to he one, hec..use those penetx'ations at that time vse Bid not classify them as a part oK We critica1 plane system, so fax as the plant operation forces vere concerned. EK. GAKKH: That's a11 the question. X have,
389 j~~b16 af the panel. 2 liR. TOURMLLOTZE: The Staff has. no questions Kr. Chairman. CEAXKQM~ BEXLLY: Does the Licensee have any redizect2 NR. PONrLL: Re have no redirect, Hr. Cha~n. RXTHESS CRBHH: F~. Chaixman2 CHAXRLCVH RBXLLY: Fir. CreenV
'I NXKlESS GM88: X would li3ce to make a coxrec<<
a0 tion to 805te of the testimony X gave i~Me Garners in one of
&e ear3.y que tions.
CKKXBK8f HHXLL~: AX3. right, please2
'l3 SfZTMESS GBEEH: linen he +as asH.ng concerning my haokgro~~ and e-perience, X told him X had had six mouths' training in the leavy Po'mr School, which 9.s truest and then X said X had a three-month progzam of submarine prototype training.
X r
~rould like to correct that.: I had six months'raining on submarine prototypes.
20 CBAXRKN HELLY: Thank.you, Nx. Green. BOARD EZRMXNATXOH BY .DR~ CO~V'0: X will address this to the pool as a whole, d whoever sees fit to ann-er these the questions X have may Og 80 sot
390 jxbl7 in looking ah the details of the so-called akhloxsB1 or 7>>=portable events g X noticed that during the star>> up period there 7'7as a considezpMG M~un4>> of diff9.cu3.ty arith the emergency generators; mad I am curious to Jmev whether Vis,Ias an unusual u~ount of difficulty and, parti.cularly, whether you vere able to resolve the difficulties satisfactorily; and vheKber. you do or do not. fee3. at: present that. yom posi tion with xegara to the emergenc~ generators is satisfactory'P {The'anel conferring.3
.{tL.." Gz en.) Z wi3.1 attempt to anm~er your 47uesMOD I sir a X,mould really like X think ve have reached a QUo~o X th9.ak you 'lmovz there is a good bit of judgment Bx +hat is coiled an "abnormal" occurrence. Our license at.
that CxlsGg and 4+e p~ of xt that %'ie xepo ted undez'ost a
't8 often, said any fa9.lure of a component of an engineered safety feature, safety system, that causes or threatens to
- 20. '~use the feature to be incapable of perfoming its intende8.
function. 2tnd in the judgment., X v~wul4 3.Qce to give you an ezBRpl e Suppose you felt. 3t vas very portant for you
~4 co be here tcQayg and you had to cQM by autoHlobilcs 8eilg
391 ma>(e sure ~'"ou voulrZ he here < you haQ ~o augogogiles if" one ZaileQ p you ~KPQ Gsiolhez ~
~~TGN'g CFliS RQX'Sling p One Pu'CQMQiDile faileQ'Q you,can in the oUxez.
2tRQ X coQM .BR+g UB2,l j vaS your atCGRQsnce i~~re ChreaceneQP Aal. you could m@3:e a decision, ml3., no,
~wasn't~~; because i: had 100-percent. zeQuaQancy in my 1 transportation.
Or you could make -che ocher decision, an8 say, ye ', ry ahren~lence was Rreat~eQg because one oZ ay aucamo>> biles failei. BELD iZ you ~)iQQM look 2 or 8ZRQple aC the nuI her of the occurred"es on diesel generato=s that haQ to Qo x~9;th an air not..or 2'ailuze of .che start.<<up machine. Bach dieae2. genezacoz has two start.'ng motors. Each is capable o8 s~car~cing ChaC. diesel generator. HONE UB QM LRVG repeaCSQ instQZLC88 OS one 8 r Kocor failing 'co s'mQz~~ Hove v6 wouM choo8$ 'ho reports it. thre"CenM
~'
aa .~Ms piece,o8 safecy equi~ient to pez ona its intended <unction; but 95 never caused ic ta fail it8 iB'G~MEQQQ fQncU.cl? ~ AaQ in -~hat. ezample she air momtor pzoMer, has heed 803.veQ Xt r&pi3.z8ct Goze GKQOZ'e igxL changes Co filter out, She Biz' ~as'c. particles thai:cere being cazrieu eo;:he aiz motor, @hat.-have-you; and ii: z qadi eR neer
- jrb19 s uM and '~la'c is Just, OQG c~"~~pie <<~ %f scape. Lensed several cypes 'oz problems vi&D diesel genera'cors g and g cf course p all c.hrough the sQvzt Qp period UG lMve COMS.Qi?86 Co 4885 our d" esel generators on 8'e same schedule as me did when we we e ope ating, and as i:he recent submit.teal oz repox~M~le occurrences x>ill indicate, hhe record 3.oo!".s 1ihe MG ve solved our problems 0'~~c
~
you~ X GTR vre3 1 aKrar& g -Of cruz'seg of this i0 redundancy in the earlie paW of your reply; the la"'ter part was priv~rily what X was inta essed in. X would 3.idee to ash you, also, a question, a
'$3 similar ques~won, about. the HPCX systam, which X nociced did se~~a to give a considerable amount, of problem during the start.-up perioQV Xh did.
Pwd ~he same problem X had viW.regard to the generators'hs principal problem vr96x HPCX has been solved; and X Wli3.3. go into decail if you 12.RGP Mo, X think thais, answers it, hut &ah was a po9.nt:rhich obviously was giving you some difficulty; and ii has been, X taRe iS, possible to rectify that7 Zesty sir
- 0) DR. CO~8M%: Shank you very much.
393 BY NR SHO'H".
~~elieve N3zp~g Qreshioxl is +oz R ~ CR" holBi UouM re Gr you co page 5 'Of your protect testimony; you MGion th ze, and you said again in you= oraL "esti~ny this morning, tha-'he totM~ neer of zeportM~le occ~~~xences does not, provide a criterion Zor juding the competence 08 personnel to consa rucC Qr operate a plant~
an@ you saM, "Oz primary importance is the QQZGty significMce 08 an occurrence Hovg in your tp~itten 'IO testimony you sages-'eX oz at. least. mentioned a criteria in >TURKIC-0090-2, "..Report, to Congress on Mono~1 Occurrences"; and you said .on1y t~~~ events hav occurred at. Brows Perry. ZTovg Wig GGNlds zather Spall g But g co sy-muzzy, these I criteria foz reporting aze rather on the serious side+ DiQ you Chink of comparing Bzovms Perry's 27 record that. ~y, vi-ch the record of other reactors, in general so that ww could see tha'" 2, although it's admit:tedly sraall as a standi apical nm>er, it might; indeed he an unusually 18 ge Q~er P Qo othe- ~~tallahions usually have NmP (Eisa CQ15oune) X QGl not sure X can ansi'~~ Mat, Xt, smuM he difficult for us to maIce a comparison hacwxse tm don'< know enough &out the full.8etails, Z an afraid, about other plants, to make as good a comparison as
394 jzb23. Gicl on Bzowns Per ye Do you h~~ve any 3.6ea hp;J many total inciQQnts of this sork'hat sa~3.sfy. the cr2.terian of NiUBBG-0090-.2, or aze re@ox KGB xn that eporg ~ say< g th3.B.'0, 3.t comes out 3 cpÃP~terly is it coÃ~lon foz 'a.hat report "2: you zeal it and I presume you Co to 3@clu8e a Qo"'en reports fzcm 50 reactors, or 2 .reports Prom 50 reactors7$ have the ze~rt keze CO get itq if you WOQMP (sf'.mess Zngvezsen getting document.} Z.'O' recalls the last 'tHO QQartezsg Bo xeports have been ma6e to Congress.. Whatever there 9.S'P Prom all. Hxo reactors. Prom the 50 or 60, there's hsen none at, allV Yhey are ~ly tzeateQ Dos'7 as abnormal occurrences, which Qxe vore ~~ lies. Of course, there azen't m ny pzoMcms time. Cpm up in nuclear plants that. really threaten safety in using the criteria. So it is entirely possible that the 2 Qzovns Fez~ ha8 might represent a substantial total of all or a substantial fraction of the total of all.the 50 or 100 reactors 23 PossiMy. X5 8 possxMG>> No@, you'e got to rcwezhez, though, one of those
395 jrh22 our o~m ju8pmnC. these c~i"a out. before MRC staweX ~ . zeporCing Co Congress. The only one Chat has eve= been ze orte8 on BrovTiM Pcz~ is w+G Zi "Q -The GeconQ, one x'Eas olid oi~i 3lxCgiient~- X realise you may not he able Co answer this no)7 blkC X UoU16 like~ hoUGverg for yov. Co Slake some eHoxi" Co mar this <<yxestion i" not aom aC scne C:ice in D~e comse of Che hearings'P C'fHL~KQiB 3EXXZPZ Bo 5'I have an:ansi'sexs l0 77XMi;SS VZHOGN: Maybe aloha c~q Qo it. nom. 77"TRESS XtIK'KPSBM: EHJBZG DG90-2 Qoesn'C have eely lisCcR in ic, owe~ She oCher hooks axo in She ca- ~ Z 8o recal~ a s~~ er of Chem listeQ; Z crm~M say on Che orQer of,@hot" 8 or so,,X believe. That, was probably.for a 3 Co a 6-monCh period. BZ: MR SBOH
'I7
- a. ~+xzQc if xt xmuM he possxh3e for you Co geC this in"oxmatioa on She.~cor8 at, someCime CoQay2 Xag ~~san.) The only difficulty s~e have on this, these axe zeporteC for Che year '75, X believe; huh Co co bach bayorG Chat is really mpossible. Ne QMn'C look iso 'HhaC possM~ iliCy+ ~8e %lane.eC a.he 9ztfozmcLtxong iC, 3QBC UasP>> 0 availatl e>> Ãe vere ~able. Co come ~p ~j.th Oq 25
g rh23 Nhat we QiQ, we went hac! and lookeQ at all of ours cQ>tX SGunQ opeg you know, it woulQn 't fall Qown in 1975 Pine. ~t's Qo "h=c. X swuM like to get an idea o - ho~r Brogans Perry ets. up wiA the things you yourself 1 con89.Qer important'n page 4 of your test~~ ony am '..a little hit con~ernscL aboLYt the f~~QBKn~tal reasoning ~ %at leQ you C to mate a statement. 2'ou discuss the setpoint Qrift pzohlaa, anQ ti~at l0 everybody knows, is something that happens at'al3. plants. You saiQ, "A beneficial result oR setpoint Qrift on Barton siiitches has he n a mo4iXication ox the switches to coirect setpoint drift." The reasoning 88~~ to ~~ a little c9. clxlax X:: can't see +here that's been heneHcia3.7 A (A. Calhoun.j The point was the fact that we Uence reporting the setpo9.nt ctrifts: alerteQ us anQ BRC 18 howl t04t ve sTxouM tee. Coc~uctive action on these Rzitcheso XnQ the best I recall it:fas a generic problem with several PAR's. Anck w9Ãh concanmate8 effort in a sQc~nth perioQ
- ee have solveQ ue problem. That Mas what wee consÃereQ the "beneficial result.
Z ee. Xt solved, the pxoblemP Yes Ps3 L~ connection With a cuesta.OG you answers
jzb24 Carnsr 'chis morning p a~iv Gx'eez?~ you Uere Qiscussixlg a fire that occvzreQ somewhat, earl 'r Rat migh~c to some peopLe: halva appeared to he a c'arming o" so'.~e sort ~~8 you say it
@as not imaNately Qe~erminei where De fire had ham., anQ.
Chat it 789.gh'G hBVB been ill IDli4 3~ Hoà is ic pos83Mc to RBow R cia>y or so after a fire vs ou" @haze it was'P 0 (Ew> . Green.) 2 tJxa time of We fire there vas a broad distinction within tice plant oZ Mose areas 10 @here vere still micr construction and'nder tke zesponsibili" ox:me coastn1ction 2'ozces Qs comparea to that part of the pl'ant cohich was in operation under the z"-sponsibi~7" y of the opezatiÃg forces ~ ATLlK 9.t.wc..s repoztect ip the Rory.ng supezvisozs maetirig almost es a z~~or hha8 they had heazQ there hact- been some tyoe of fire; an8 I say vitZzout ezcuso, hut it has" noh ha n a formally-Oocmaented Ding, since in substance ic @as
~
a ~~- ll Plm-<<~ tive moz'car on 0Ae job coa3.6 pat i"c out.g amR thaC was Me end ef it 20 Xntorest +as shawm Eo the event "x~here +as 3.tP"
""-hah +as i'2" anQ 9.t aws determined that amoung the 22 supe'."v" sory people 8MQQQ2ng th9.s meeting Got ep'olx9'h /cL'.oi73.edg:
'4a 8'Uxowfp Qhouc xf 23 AQQ g put cfQxce co~cMXyy the responsibility was 'assicp~M to .";-inQ ovt, about it. Moor, at the same time,
398 we did not, as bh. Garner suggests we should -.- and Z agree-had given immediate, urgent atter~",ion to find the Qe~~s"'1s. Your answer 2.eads us on to a question which has bothered IQe person812y about the Broils Perry ¹reg <rTel 1 g Q1EQst ever since or before T. heard about it~ Z noticed, that you mention unit 3 and the careful distinction hetwe n areas of construction and areas whcih are not under construction. X am perhaps no phrasing this question exactly, hut to what e:".tent do you th~4 c the fact that there rsas a construct'on job going on in a plant there at least c~~in structural features and perhaps safety features were shared by the plants under construction. To %<hat mn"ent Go you thine this sharing was at the root of the Brogans P. wry fire' A The amount of active.CJJ in progress c~~a921X.y contributed or was a part of this background leading to Mxe 6:xe. I am a little concerned with the whole idea and QRs Carly in the gBxxe vhexL X first heard cQDout Brans Pe~~, of running a reactor vh9.le, so to spealr., somebody is building another right nexh door, mnning in am'ut, drilling, cutting cables, running around with tinsnips and things'C the present t~~ if the Brogans Perx~ ~~ its
399 go back into opezat3.on p to What QKtent Ai12. the saiL1e s3:tv ation 2 still ezistP n A - The same 'it~~tionv9.3.1 not erist is We c3 constnctiong it is cciolete on all thzee mitsp the Korean. construction chas'e. Ks pou Jmolz, unit 3 has been gzantaC a licen e now to go to 1 pezcut paver;.anl we aze heze asking Xoz authozisation to zion 1 CQQ. 2~ But it vill be no7elp aQQ it Ãi11 a2>Taps 58 on ouz zeactozs 8239ilar to any plant p cont3.nual KotR3$ ication g QnC
've have xeevalMteQ ouz position antX pQtp X thinkp vszv stringent. nunmezs on the people who can he pex"oxni~ng mo89.chica
.'tion vora't one time, the amo~~ t OS supazvision xe~ eel Zoz
'Bhese people): an2 this 3.8aQs poli 2Qto the pz'ocGBQzes they
'I must ~olio"z to Qo the wozhp the antImz9.sations to Qo any activity on a certain day. Aa6 .
Thank.pou. X thirds that's all CHMK%9l RE~l'"Y: Do era have anything fuzthez of this witness panel? (Bo xesponse.)
, MR. PO:-lELL: Xf 9.t mould be satisfactoxp,
\
Mr.-'eally, p chaps'aftex We luncheon xecess we couM have the paneX, co@i back to answer We question on the o&e'x abnozma1 occlizx ncesV 2'HAXR~1 RPiXLT: iMX Zight. othem'e the panel is then ezclisect.
400 (~~<t>ess pMe3 K:cusGQ o ) CMYPL'LW RHZT~LY. Hho has @he net WQ.tnssS oz mitaessesP Xs it the Peg Staff? TOUR~XMZTE: Yes 2K. CUTCHXM: Ye~~, sir, Mx. Chai~n. etc have a statGRentg and HLGXL we 'NoulQ be prepareQ to call ouz first witness. CBRXKMT 3 XLLY: All right. MR. CUTCBDil: I x'-only liTce in an attempt to bring things a 19ttle hack into perspective in my opening statement g nol'7 that the other part>> es have gone firstg oQxQ I will first give a brief na=zative of how this hearing came ho he heM, the Staff'8 views of the issues that 'are before this BQMG a 'sQMaQ' f '@hat the Staff 8 testilIIonp'i g ll showy GQQ the Staff 8 conclusion Gs to what the BoazQ muBt fin@ haseG on this evMence. Bo&~s units 1 an8 2 of the Brows Perry L3uc3.ear Plant as has been testified to here this morning ha8 of course receivers ~dzeir opwating liconses and vere operating at full paver. when the b&mch 22, 3.975 fire occurred. The Nuclear BegLXatorJ CoImission iIIQQiatelp began its thze -element zevi w pzogz~ which as will he set fort'h in the Safety Evaluat9on Report, to be introduced,'ater, cons~nte8 of an Office of Xnspection and Enforcement investi-fire, V gation of the events surzounQjng the the Office 0'=
401 3 zb29 Huclear Reactor Pagulation's review to as@Me that the plant I had been put'into a safe confirm:ation, and that the uel cou3d Qe safely Mtovedg and thaE= the plant cQL~XQ QQ zestozedg and modified, wiAout.infringing on safety. And of course there was a spec al review group
'Btxiclt was appointed to loo1c into the zize protection lessons that could he leB5."Red fzQRL the BzcR~s f Ferry xxe ~
Also, shortly after ~We fire,t the Tennessee Va13.ey Authority submitted its plan for evaluation, zepai-, and return to service ox the Brogans Pe~~g units 1 and 2. This p2:an ovez Me cou"oe of.son.e 16 months has been amended.'about
-46 t~es to Bate;
'J3 Of course, the Point Committee, as has be~
'pointed out, also performed a revimz of the circ~stances s~~zounding the fire ~
Last October the Huc2.ear Regu3,atozy Comnission issued, pM~ lic notice o the proposed operating license
'JS BE8%xGEents to allow BzcNhl8 Pei~J units 1 and 2 to return to power. Mz. Garner was She only one who in zesponse to thah 20 notice pe~~tioned for leave to intervene; and he was achnitted as QQ intervenor ~
By stipulation of the parties, the issues to he
- Q decided in this h aring we~'e agreed to he as defined by three contentions set forth in a Board order. The .Xncezvenor has 4
since withdrawn Contation No. 1, following a 0'une 3.6 letter
402 xrom Xi'H~-Pirl to the Tennessee Valley Authority ~which agre&
>ha c Hle intent Qf its. recQIDEendations on liTQich Contention 1 vms based had Jo~~n acr..
T2a Xntervenor modified Contention No. 2 to state that the TVA is incompetent to restore aced modify Hzovas Ferry Units 1 and 2, as evidenced by the fact that it has Gzperienced a large nQ~Mer of Pbnoxmal Qc~ences at thos% Units.
.. The on1y issues to he decide% hy this Board are arose framed hy Contention 2 as modified and hy Contention 3, >which states that the Nuc1ear Recmlatory Commission Xnspection
- and Surve~>lance Program for Bro~mis Pe~ units 1 and 2 is insufficient to assure that the restoration and modificatio have been adegv tely performed to assure continued protection of'he aub3.'c heaM~ and safety. V The Staff crill present vimesses to sponsor the Staf 's zmiMen testimony, and its Safety Evaluation Report, and the Ciao Supplements vhich have heen submitted to the Boa=6 m6 previously served on the parties. X @91,1 introduce and examine Nr. Thomas Mambach, soho vile. sponsor the Safety Evaluation and its Supplement. These aonnaents pxesant the resu3ts of the Staff's review Qs?8 its conc3.Qsion Q~t the m08ification GER restoration of Units 1 ance 2 has been completed in a fashion to assure eontinue9. prote~~9on of tQ~e public hea1.th and. safety.
submivt~3 '-o 8he Boa "6 abc': sozvaQ on the paries soma five or END TMK MBB a~8
ct Ocl Tagore 4 I Their 4'1zxa ten tesi "mony .7ill go to ContentioSls 2 barbl1 old 3 Their tcs. imony E'Zi1 1 descxiQB the Xl~uclQar Piegulatory Co:" YJ.ssion inspection px.o4ram in general and as i ~ ap~l ed to
~
Broils "e ry Uni ts " and ? during +me restorat> on and mode CQ ..Qn Their testimony also will ezp1ain the 8taffs as-sessment of BT3,'s performance in restoring an> modifying Units~ ~ 1 and 2. The Staf f ~ s eviden e t'7il1 demonst ate,that the restoration and modification of BroI7ns Perry Unit 1 and 2
.;~as and :s adequate to provide reasonable assurailce that the units .Can be -eturned to operation eithaut endangering. the health. and safety of the public, that TV'. was and is com'-
patent to modify and restore compliance and that the ihspec-ion and enforcem nt, inspection and suzveillance program t
. eras and is adequate to reason>~3.y assure that the modifica-.
tion and Festorati on Vere property pe fOHiled ~ 4'e believe that at the conclusion of our case the Board can make the findings necessary to allo~7 these units to return to operation. The z cord w5.11 shcw clears.y after inntroduction ox &e Staff's evidence that. the TVA +as and is competent to zestore and modify the t3zovns Per~ Units 1 and 2 and that the 'BRC inspect.'.~on and suzvei13.ance program its aI'ld is adequate to reasonably assure that the yublic health cxnd safety I'7il1 continue to De protected, That concludes my opening statement, Y~ 'haizDian. 1
X 6IQ Fio>l a.eBQy ' CBZ" the Sta "f 't'D.tness>> CHAXB~LMC RHZLZ "Z." Phank you, ER. Cu'rahu~~.. Go ahead>> BR. CiJTCHXN: Ã. have switchea the oral =, ERr. Ch "immr . X M.11 tQ. n LNae Rl3.ke over to i%$ X'>> SQL~ Kl EQ>> iSNXTB Z ~fo1218 lxke. to ". QwrQQQCB bio 883.f >> Ky name is Barry Smith. X was not present at the opening o2 these p:oceeQi3','1g8>> X wou~Q ~Me ro ca~> t- "he at'>Q?"" No: ÃoMlev g Vx'>> Pzc41c9.8 a7>> Xsong fifx' Chaz'les ~ >> NQi".pPy a~~a i'L7 ~ s'~2.11i4~<l C>> 883.dl~~ >> CKM8 KXYY: Dill these gentlemen i8eati.:y Qemge'2~i~~s hy narar in the posit'.on they a.-b at, at the tabi.e ~or tive reporters" KlMsvgQDq NORK43 C NOSETFT CHiNMS E. ?CUBPHY PBKCCZS Z. 'XQNG MZii ZAN C. SEXQLL were callaQ a= ~t9.tn-sacs on x behalf o= ~e Hvclear Regu3.a'-ozy Ccrc'scion Sf:aCz anQ, having bean Bizst Qvly s:.iorn; >>mete ex-eQ and testi iea as zollows DXBECT H'DlH'Ei~ArZZOR 52'"ER. Si41Z'ZH: K~ 24ose3.e)>> p JGQ have Qei.oz'8 6 coov 02 0, 'ocQlDsnt
406 en'i~leQ, "doorman C. Koseley. 2 ofessional Qualifications, Region ZZ Qf fice of Znspect . on BnQ Eik'i.orceHtent; U o S a PegQla-tory Cmiwiissioa'2" . This document consists of: ~":ro pages. Did you prepare "-his .6ocumeni=P t
<Witness Noseley) Yes, i ctid. ~l
- 0. Are the e any dition~'r corrections to- this 0" ccrc>XAentP There are none.
'g. Nri,iiuGA'ly. you have Before you a Bocviment con-.
s" shing of two pages entit3.ed, ".Statement oC Qualifications of Charles '. Nxuphy, Office oP. Xnspection an<7 Enforcement, Recjxon XXo DiQ you prepare mi" documents (Hitness Murphy) Z QiQ. Do you ha're any aQQitions or cor ectiors to &e QocURh~Dt 8 P Ho, 7. cto not.
- g. 8r. Long, you have befo2.'e you a statement ante.tied,
"{)ualificacicns Statem. nt of Francis J. Long-" which con-sists of c"To pages ~ 09.8 you prepare this tXQCGTi1ent+
'{@itness X or.g) Yes', X. aid.,
Are there any changes ":o &is documentP No. Lkr. Sei83.e, you have hefore you a s0atement anti'=leQ, "Stat~~ent of Qualifi ati,ons oz William C. Seidle," cons" sting of "our Dw'8$ Di8 you prepare this stateMn<2
407 (Ni <ness Heille} '~es sir ~ Are <<:here ~ay, edDi~ions or correc'..'.onset
.'Q g Gi.ri PTCUM QOQ please Elaine
'those'QG a
Xn ordex'o reflecl 8 recent prcEO "on end 6 i mould
'I L.xansfer .ho another region, liLe to aiba'tie the -ollcvina chang80 i On age ~,'the fzzst x.r , ny bus ness M. ss '
k 613. Rymx Pl"-.=.o Dr9.ve, Zmlkngton, 5'ezao 76011. On page 4, I'ould li!ce to ale~ he <o3.loviag paragon'mph Zn Juli~ g l976 g X >kans proTAO's'98 zo Chisx )Cons'crtlcc ion anG Zng'neer3.ng SupporL Branch, Region XV, K-..liagton, Te.~as. 'this b "Gp~w'1 has the respons" J3ilitv Zoz &ie insLecti on OC c~ ll nuclea pox'er plants assigned to the region ~vni 'ho provi6e enginoerina. a~aport to '~ice Operate.ons Branch and Cons'cructions Branch Gs recfues'3Qo That c~~p>.etes 0\/ mc8iZlcaicioQ, Co this QQBlii9.ca ons szRLÃQBQK>> Mr. Se.'.Ql, 's your qua3.izication no.v true ance accu."aCe to tee has~ o~ porn belie<9 8 .. Long, 9.s giaour cael'Zicatiox statement. t-we ard accurate to Gh h="t oC porn helieZP
408 (t'Ti tness Long j Zes ~
- g. Nr ~ iMUrphy g is -~our. cfual.L xx ca Cion statcFilen'c true ana accurate >o the hest oz you- belie 2 (Ditziness rru~hy) yes Nr. Mosel y, is your qualixication statement true md accurate to '-he hest or your belief'?
(kli~uess Haseley} ~Les, it is. 'I
&1R. SMOOTH: .'1=. Chairman, i <rsouM move "hat the professional- st 'ceo'.ents of: quali".icaUons o 71essrs.
basely, Nuzphv, ~ong and SqMle be admitted as evidence 'n this pzopeeding. CIBZRM BEXXZY: AM you mant them incorporateQ in the record, as if zeai2 MR. SNXTH: Yes, as if x'ead.
~ CHAXRtBH REXLLV.: Any objections2 H ~ Garners FR GMHHR No.
CPAXSNAH BELLY,:,&le. Pawe112 IP~. PO>VLL: Ro .objec"ion. CHAXZCL~ZC HEX'he px'Ofess9.onal gMliH,CBtions of. these four ~witnesses is adau.tteQ in ev Qence anQ shal2. he incox~oratad in the t "anscripC as ir r ai. 23 ~ e& (Documents follow.)
\~
24 25.
II STATEMENT OF QUALIFICATIONS OF WILLIAM C S.IDLE Ny name is William C. Seidle. My business address is 230 Peachtree Street, Suite 818, Peachtree Center, Atlanta, Georgia, 30333. I am employed by the United States Nuclear Regulatory"Commission, Office of'nspection end Enforcement, as Chief, Reactor Pro)ect S ction 1. I graduated from Washington State University in 1953 vith a Bachelor of Science degree in Agricultura1 Science. In September, 1955, I joined, the General Electric Company at the Hanford. Atomic Operation, Richland, Washington as a Technical Graduate. During the next 2-1/2 years I completed. a 6-month health ph~ sics train-ing program, qualified as a shift supervisor in the radiation monitor-ing progrem for 8 Hanford production reactors,,in ~hich I super~ised 6-7 technicians, and qualified as a Supplemental Superviso=, Reactor Operations in -hich I directed. the shift activities of 6-7 operators in the rqfueling of ny of the 8 Hanford reactors. In Nay, 1958, I transferred to the 50 ~HI General Electric est Reactor (GETR) located at the Vallecitos Atomic Laboratory, Please on, California to fillone of four shift supervisory positions in reactor operations. I participated in the preoperational testing and initial startup of the G~TR end, for the next 3 years, directed and supervised the operation of the reactor and associated. equipment, during 'an 8-hour
~ p shift, in accordance with AEC license requirements. I was licensed 'by the AEC as a Reactor Operator and Senior Reactor Operator on the GETR. In August, 1961, I was assigned. to the position of Supplementa3. Opexations Supervisor where, in addition to shift relief work, I 'became very involveL in the loading and shipment of spent reactor fuel. I was also in charge of the training of customers and General Electric Company personnel for GETR operator licenses. In December, 1963, I. was promoted to Reactor Operations Analyst for the GETR. In this position, I investigated and analyzed. the performance of. ~,'eactor systems and. methods of operation and, recommended corxective action, wh re appropriate, for safer reactor operation'. I also assured, through routine audits, compliance with license requirements. In September, 1965, I was promoted to l4anager, Reactor Operations. I managed some 40 employees including reactor supervisors, operators, engineers and. administrative personnel. I was responsible for the operation of the reactor and its test facilities, the performance of irradiations related to isotope production and for directing the safe use, occupancy and upkeep of the reactor plant and. related properties. In July, 1966, I )oined the U. S. Atomic Energy Commission as Reactor Insp ctor. I '-as principal inspector on several research, training and,
C I test facilities and -... several power reactors under construction, ncluchng Turkey Point 3 and I
-'~d Oconee 1 and 2.
In April, 1969, I -~~ promoted. to Senior Reactor Inspector and, in tiu.s position, supervis d -' activities of 6-7 reactor inspectors invo ved in the inspection o he construction, preoperational testing and/o operation debases of several reactors including the BONUS f cility in Puerto Rico, SVOR (sodium cooled) Oconee 1, 2 and 3, H. B.. Robinson. and, Turkey Point 3 and 4. In October, 1972, I vas promoted to Chief, Reactor Operations Branch. This branch had. th responsibility for the inspection of all operating,
~
research, t st and:raining reactors
~
and. those po- er reactors xn commercial operation. In March, 1974, I vas reassigned to the position of Chief, Facilxt es Test and Startup B~mch. This branch had. the responsibility fox t~e inspection of all =over reactors during preoperational testing anc. init~al startupo In November, 1975, -he Test and Startup Branch was combi" d m.tn J tn Reac or Operations and Nuclear Support Branch and I was, eassign~ to mJ. current position c=. Chi f, Reactor Prospects Section l.'his sect zn xs responsible for t- 'nspection of one PWB, Sequoyah, an@ a~ ~;i> = xn Region II inclu '."..- 3"owns Ferry 1, 2 and 3, during the Preoperational
~,. ~, testing, pover ascension testing and commercial operation phases. Several operating research and training reactors are also assigned to this section i'or inspection.
ualification Statement of Francis J. Lon Chief, Reactor Operations and Nuclear Support Branch NRC Region IX Office of Inspection and Enforcement Atlanta, Georgia I graduated from Auburn University in June 1949 in Electrical Engineering, and entered the Navy as a Communications Officer servi'ng in this capacity until 1952. I have been engaged in nuclear related activities continuously since 1952. ~aly initial emerience in nuclear areas (1952-1955) was in the Nuclear Weapons pxogram of the Navy where I was the custodian of Nuclear weapons and responsible for their operational readiness In 1955 I left the Navy and accepted a position as a Nuclear Engineer with the Uestinghouse Electric Corp., Bettis Atomic Power Laboxatoxy. Mestinghouse was the prime contractor operating the laboratoxy for the Navy and the Atomic Eneigy Commssion. .The Bettis laooratory was charged with development of the Nuclear Submarine Nautilus and the Shippingport Nuclear Po-er Station. I was involved briefly in reactor control system design for the Nautilus and in 1956 began work in the design of nuclear control and monitoring ssysstem-em fox the Shippingport Nuclear Plant. This worIc late progressed from design to pzocuxement, construction, installation, testing and
~ ~<<"inn of the slant. Xn addition I was involved in refueling~ major modifications and updating of the facility.
X left Vestinghouse to goin the AEC Division of Compliance in T7ashington D.C. in 1963 ~here I was assigned inspection responsibility for various xesearch and power reactors. Xn mid 1964, I was assigned to the AEC (NRC) Region XX
rvisor of ins p ection office in Atlanta as an inspector and. later as a supervi C activi.ties. I have been associated with the construct on, testing and I operations of a significant number of nuclear power plants. Hy present responsibilities include indirect supervision of 24 tasting and operations inspectors.
STATEMENT OF QUALIFICATIONS OF CHARLES E. MURPHY OFFICE. OF INSPECTION AND ENFORCEMENT, REGION II My name is Charles E. Murphy. My business address is 230 Peachtree Street, N. M. p Suite 818, Peachtree Center Building, Atlanta, Georgia 30303 I am employed by the United States Nuclear Regulatory Commission, Office of Inspection and Enforcement as Chief of the Reactor Construction and Engineering Suppoxt Branch. I graduated from Auburn University in Auburn, Alabama, in 1948 with the degree of Bachelor of Science in Electrical Engineering. I also attended the Dxexel Institute of Technology graduate extension school in Baltimore, Maryland, majoring in Engineering Management. I am a registered professional engineer in Alabama and Georgia and a member of the National Society of Professional Engineexs. Until 1955, I was employed by the Tennessee Valley Authority, first in engineering design and later in the construction and test of fossi1-fueled steam electric and hydroelectric generating stations. My final position was as the Electrical Engineering Supervisor for the Hiwassee Area Projects.
.From the end of 1955 until 1957, I was Electrical Engineering Supervisor for Uhl, Hall and Rich, Consulting Engineers, on the St. Lawrence Seaway's Long Sault Dam.
In l957, I )oined the Westinghouse Electric Corporation and after attending their nuclear power training school, I assisted in the testing of the. aircradt carrier prototype reactor plant in Idaho'. i suhshqhently was ~ I O
~ Q Charles E. Murphy Q the Vestinghouse representative on the aircraft carrier Enterprise and was responsible for the inspection of construction and testing activities for two of the carrier's eight reactors. In 1960, I )oined the Martin-Marietta Corporation, Baltimore, Maryland. My initial assignment was as manager of the preoperational and operational test programs for the PM-1 Nuclear Power Plant. As collateral assignment my section was responsible for the preparation of all the plant procedures and manuals and for the training of the plant operating crew. Subsequently, I was manager of advanced power systems studies. In 1969, I )oined the U. S. Nuclear Regulatory Commission (at that time the ~ t U. S. Atomic Energy Commission) as Reactor Inspector in the Test and Operations Unit. In September 1972, I was appointed first as: the Acting Chief and subsequently as Chief of'the Facilities Test and Startup Branch. This branch has the responsibility for the inspection of all power reactors during their
.testing and initial operations.
On March 18, 1974, I was appointed to the position of Chief of the Reactor P>> 4 ~ >>Pg>>>>>>>>rl T>>>>4>>n>>v4>> >> C' >>>> ~ 1>>>>>>l ~4>> t >>>>L t,>>r ~ 4>>>> >> tt,41'.a for-the inspection of all facets of an applicant's design, procurement and construction activities and of the development and implementation of his Quality Assurance Pxogram in these areas.
I hg
~ /" I II
~+ NORMAN C. MOSELEY PROFESSIONAL UALIFICATIONS REGION II - OFFICE OF INSPECTION AND ENFORCEMENT U. S. NUCLEAR REGULATORY COMMISSION
+ name is Norman C. Moseley. I am the Director of Region II, U. S. Nuclear Regulatory Commission, Atlanta, Georgia. I am responsible for the implementation of the Inspection and Enforcement program for all NRC licensed activities in the southeastern portion of the United States.
I have a Bachelor of Science degree from Georgia Institute of Technology. Immediately following graduation from college, I served about 3-1/2 years in the U. S. Navy as a Line Officer at sea and ashore. In 1956 I was employed by E. I. duPont de Nemours and Company at the Savannah River Plant (SRP). During the first two years at SRP I worked I as an Industrial Engineer doing standard industrial engineering tasks. In mid-1958 I transferred to the Reactor Operations Department as a Shift Supervisor. In this capacity I supervised five men in all facets of operation o7 a targe proaucz>o>> nuclear'eactui'. ~>> i~os J 1'Io> plUllv4~U to Senior Shift Supervisor. In this capacity I was directly responsible for all aspects of operation of the reactor and all associated facilities during my shift.
In Nay 1964 I joined the Atomic Energy Commission, Division of Compliance as a Reactor Inspector. As a Reactor Inspector I inspected test, research, and power reactors in all phases i.e., construction, preoperational testing, startup testing, and normal operation. In October 1967 I was promoted to Senior Reactor Inspector and my job responsibility became supervision of Reactor Inspectors performing all types of inspection. Later, when the organization changed to specialize inspection attention based on the status of facilities, 5 became Chief, Reactor Testing and Startup Branch. In April 1973, I was promoted to my present position.
xi 09 BY 2i'?. KITH= Q. Do -"oU have be~ore voQ ribes i7RC Sca"f Response ';.0 Zn>>ekvepQr s Conben83cns 2 anQ 37
',:?itness Xoseley) res,. Z Qc.
i'~ ".8 'cl'is i 88< i ony prepareQ i v21Qez'o~~ svspezvisicn2
'des r i< rza DiQ you Qirecily prepare certain portions ef 'ci.is ies&9loxL"F2 Ves g X Q3.Qe CoulQ yci please iQe'.>8izy Nose sections2 I preparGQ Gt'e XntroQUc'M~'on p he Bechicn I, 0-'-e all.
Ajproach ~o HHC Program; ZZ, Office of Xnspect.ion i. mt.'Q Hn-(.., foz'cepientg KHQ ZZg Bialys" 8 of PerfoxHlK4lce~
~-"r. Hoseley, "..re ~he" any adQivions or correq-
'"'ons c whoso d'or-'ions of ~e
\
'"essay vhi h you Qireatly i, ~9 R&eQV Q~
Yes; Nore "re .everal minor correnions. Co %le ycU p3 ec'se g ve zlxose On 2:, the =".izsi >>age ox Ne restMiony, the firs" lhner che 71ozQs "poztz.ons of che N~C Szazf" shoQlQ DG Qele~eQ so that tsar. l're ncrvr zeaQs, "This ces"irony Qeals
~ i
'N2 (w1 XnsQ Gc'Lion w ~ ~
'Zze nm:+ correction is on nape iii, me seventh'
bazb7 lane Zzon the top, the l~.ne begins, "Construction." The nezt turd should be "were" ra"her than "was" so that the line WPGUld noH read ~ o.eConstructicn Ã3re prepared bv ox'nder tne supevI-ision QC C+E ~ j'(urphp." The nezt corre tion is on page 82, the 3.2th line xroii the top, I the lin -;which beains, "...reportable events is coQtai Md in Section and " t should be VXXX rather than The Qi~lal corx'ect" QD. is on page 85 ) tile paragraph 2 ~
'We xouz'th lizle domal q should read ~ Use is attributable to one or both of the N~o--" rather thm~ "i"."
That coplpletes the correct" ons Hz. iLuxphy, would you identify those portions which you direct3y prepared or >sere pxepared under your supemrision2 (Mitness Hurphy) Yes. X prepared ox they were prepared undex wy super-vis'on, XXX, "Pollcwup of Construction Type Deficiencies Xdenei5:ied During the nvestigation; V(a), Restorat9.on and Reconstruction; VXX(a), Construction. Aze there any additions ox corrections'o. those portions ~ There are. vlauld you please so s> ate then'P Or. page l6, the seventh> line in pnragrax>n 6, the las Mozd "bul-he.d" should he deleted and the word
pene t.x'pvi. Gn 2zLscr(.eQ ~ F>>Q the sev'en'th paragraph. next, to '-he las:- line. 3Ã4ging .'inspe~c ion z.epor'to i the i'zozd 're sAQQM Be de ".84. ~Z g zeGQing ...inspec'tien reports, and ~ x~pec~ ing ..the penetzahionso ~ ~ ~ PQge 3.9 g paragraph 3.3 g She second line the g ~~7oFc 's should he Eseleted and the iform 'as should be inserhede The sword "correcting" shovl8 he changed ~o "cozzec"~d." T~ ine vrm~ld read, then, ...'aha" -~~iM me excepi.ion of the rmta3. bulkheads, TUB. has corrected...." On I.> page 3l e:ccuse a>e, 33 me paragraph lo should he reidentified as lo-A. PXLQ Qn page 4S ~ i.he Cirsh paragraph i KEG Qpte should be changed ~o roan May 7, 3.967 iHay 9th, 1967, zaMer ghan May 9th, l962 axe +1 eze any'ther addi~ions or corzectionsP PBeze Qze none
- p. Mr. X ong , would you please iden"i zy "hose s ct,ions
~~'hich <iere prepared directly hy your or under your supezvi-sion P (Nitness Long3 Yes, sir.. Section XV, Pollowup of Eonhard~rare Deficiencies Zr. naif.'.ed during ~he nvestiga ion; Section V(bj Opeza-ciox l SaP0'-~r Dux 'ng Restora "ion. and Seccion UXX(c) Op ra- "tions Xnspect." ons Pr-"oz wo ~h~ Pi.~e
12 Are there any additions cr corrections to those
~ec ~ionG'P 4'oulr3 you please oo staCe them?
XQ 88ction V(b) on page 35, X Mould 3.itce to n sert the phrase on line five, after the nord "inspection," "time but xrequent inspections," "-o that that line vould new read this sentence %fouls RQX'j read I This permitted a re-g Duction in 'he amount of. MLC on-site inspection Cime hut 2e'quent inspections continued with emphasis on maintaining 1 3n 'Raise Sg'o "age ~ IN CHi~XKTK"7 PwXLL": X am so~~ +hat page, E~w..LongP
~rfZFaiESQ KGMQ: Page 35( paragraph l7 ~
CKRXP"GM MX3~Y: The iifth line from .che hot omV X s;one('~ iZ you vculd repeat that zor ua. NXTN.SG XOi~lG: one Q.ve t dovr xrom the top, after 5 'word inspection o CHAXBSN BHXLLV: That i.s line 5 of parag=aph 172'X
ÃHSS XO'7G: Yes, Sir.
CHAX1UNN R XXZY,: ~Ãould you givo it co us again, pleaSQP RXTMZSS 0?CQ: Xt, should read, "... on-site inspections time but ~refluent inspections continlked," et ce& CH>XSAM ML~~5Z: Z>>a& you.
lsX~~SHSS hCsG: Z)lsop on. page 36 =n parag aph . 8, it should read, the "'-e:~~ 3: ~st p~., it should zeaQ, ?~~o=-e thcan 156 rnandays, ", ins "xaQ of 13'3 2hc!t ."' j 'ust 8."i"."iply up-da"'ng the effort fron "=.he earlier draft. Those Qze the 0 ly CNLztngGS X ha<je H:a Seiole p ~'lox~Zd Qou id8n'Li) y those sections of the teston!Ovy which ~rare prepared directly 'r you or olere prepared under your psupezvisionP (7'Yitness Seidle), les p sir. Xn zeforenci Lo the table of contents associated v9.th this testimony p V (c} Preoperational Retesti3lg p VX p Operational Quality Assm'ance; VXX(b) Preoperahional Testing R'.2Q Cgerating Readiness p and VZXlp Reportable uvenl 5 ~ Ere there any additions or cozwec~ions to those pod Ons that you have 3'Qst 'eQti f3.eGV Yes, sir. Could you please. so state themP On page 39 of the testimonyp the first paragraph nu~"~~-er 25, the first line, the m'aber 23 should be changed to 33, so that it nor reads, "...has spent 33 maydays...." On the second line, stri/ce the swords "as of May 21, l976." rhe sentence new ends with "orogzam." Pi~re lines, the sewe paragraph, change 29 to 96, so that mould read, results of 96 completed preoperation-
1 barb11
- you '"-'-11 -U "n new co page l3s p~~ grap} 10 0 Lhe seconc 1xneI ."i '.shou1d nG',~ read .'f . Gpo" tei~ "ilrou>>c"h
.July 1976 And fg~e 1ast 1>> ne of a<e paragraph shou1Q refIer to "Tah1e 8-X."
X+ you wi 13. -neis turn ' page 78 paragraph 26; the f2.zst 1 "I ne > the Lvw~&er 199 Ghou18 5e ~A lgeG to 203
'at \
co~iloleti~~ tQle c~xa>lges
- g. Mr. %0801ey, c20 you have before you a cloclment en-i:kt ed tfRC Staff Respon:;e to Boar@ Question?
(Wl.tness >'1os Glcy) Yes " X do o Doss 3.t coP$ 3.8t Gx tf'70 Pages? D1ct you PÃ8PBre 'c33x.s response? Yes, X d<Q. Are there any aM>>t>>.oem or corr. Cticns to that response? There are none. 1n ', 5m. 25ose3.ey, is &:s rLacvsaent ent't1e8, "NPC Staff Pespon e to Content>>ons 2 and 3, and MRC Staff. Response to Board Qaestion" true anc~ acou-ate to the best of Tour be-1ie>'? As x>>e have corrected it >lere today; yes, i.t 3,s. Q. H=.'71uzohy, in voj~r seat>>ons of NRC Staff Response 24 to Znter>>renor Contentions 2 an@ 3.as correcter', are they true Og and accurate to i~aM BBG c of your b61 j.ex
{K> Gness NQzpQ'r } ves thev aze, zlz. ~o~~~ir xn z<gazd ~"o yo<z sect=one ox M~~C Staf J: BespoM8 >io intervenor Contentions "- auld 3, are Qley nolf as co'ecCGQ
~
q tzl~e nd acct.ate to 'Ul~ beast 0 voQZ Ae ef2 (M3. c neBS Xsong) Res a Zlz. Seidle, in z gard to your sections o= BRC Gt".~f"B sponse to Zntervenoz. Contentions 2 and 3, aze they
'g&QQ anQ Gccllzate to 'e ~inst oz your be 3.3.ex g as cozz'ecteQY
(".fitness Seidlej They aze ~ ZiXR o S&ZXTH: i"" . Chaise~, I modem that '-he NRC Sta 'f- Response to Xni:emonoz Coitenkions 2 anQ 3 and the MRC Staff Pesponse o Boa Q Qms-'2on be admitted as evidence and $ 4 , boULQ into the ZGCOXQ as 3. Z ~ cad ~ CHRXRMAP. REXXLY: Bwy objection, Hz. Caznez? NR. G>K3BR: One cpxa tidied objection. Xn the fizsh 'pc~~agza>~h Qf LTRC Sta ff Response 50 the Boas.d QUGstiGxl
".On page 2.8 of the Prehea-ing Con.ezence
~ P I
traYlsczipt Dr o g Covian ~xgllireQ Qs 'a 0 $7he&cz cx ccTilpazi son oz TV9.'s perfonnance zecorQ ~7ith thah C of oCher utilities in zeca.".t vears cou>Q be made." 22
~
Pod X v7ouM like soma&ing in ~re recorQ e".ac<1y as to ~we way the auest9.on was ask Q, if you have it. BlL'i YQQ 9'Fv Z zecak~ hM cA18s "t S.on' Qon t vhilll" "18 c OKeQ 'o'c3 Q it he QCne t b<C he asl"ed 1G. it }3e done ~
CHBZPZ'Ex+2'E BZ 'X: X c oxl t Lave that prehearing v-'- Qp~scr3-pt before Kie r:Lgn i nere o Does aQipone else ~ GM673P.." X am no='oing i=o press aha aajection rp'AS.S 'cise ~ JQD'C'. %fan ~88 to Call 4 to the BoiDXQ 8 Q'"- tentiosi ~ CE'&F.iiGi RHiLL'Zz:,OR,ayo Ne vil3. check the record. Erie have ref ex'ence to page 2. ~ 88 CPA check " t fQz that
\
GtQ~er Ch~~ ~ha~:, Qo you have any objec'.ionV clR. QPDHBR: 1Eo obj ection. P CERXRM% HEXLLY: Any obj ction by TVM iP.. POKE: Ho ohj =ction> 2'hai~i. RQ. CHRZNL~2T REXXLY: Al" right, then. Rhesus 'aso Staff Documents siill be ircorpozated wiuiin the zecorcZ as if "cad and a-e admitted as evidenc- on hehaif of "he Stair~. (DOCU&ients Zolloif ) M 23 26
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 O.L. 50-260 O.L. (Browns Ferry Nuclear Plant, Units 1 and 2) NRC STAFF RESPONSE TO BOARD UESTION On page 18 of the Prehearing Conference Transcript, Dr. Cowan inquired as to whether a comparison of TVA's performance record with that of other utilities in recent years could be made. IE does not compare performance records of utilities because an adequate basis does not exist to make such a comparison. Over the years IE has spent considerable effort in attempting to develop a mechanism to object-ively rate licensee performance. These efforts have all proven unsuccess-ful. One can generate lists and numbers of items of noncompliance by severity, numbers of reportable events by category, or other statistical data. These data, however, are not too meaningful primarily because license conditions vary from facility to facility. A particular occurrence can be noncompliance at one facility and not at another because of the specific wording of the Technical Specifications. In a similar way, an occurrence could be report-able at one facility and not at another. Further, some licensees in an attempt to meet the spirit as well as the letter of requirements, report any
~ ~ event which is in the grey area of reportability. In addition, the phase a reactor facility is in strongly affects the number of reportable events. Early in the operating phase we expect more reportable events than later in life. A second reason why data on noncompliance and reportable events is difficult to compare is that regulation and license changes which occur I make the historical data base questionable. Failure to have a basis for making comparisons of a licensee's performance others is not a severe handicap. The important comparison is how 'gainst a licensee does in meeting the regulatory requirements. This comparison IE makes, and it is this which is the end product of IE's efforts. IE must have a continuing assurance that the licensee is adequately meeting regulatory requirements and is operating safely to allow it to continue to operate. To make a recommendation to issue a license, IE must believe that the prospective licensee is prepared to meet regulatory requirements and can operate s'afely. Neither of these is based on expectations that there will be no items of noncompliance or reportable events. As is discussed in detail in the NRC Inspection and Enforcement testimony, TVA has had noncompliances which caused Region II to escalate NRC enforcement practices and there have been a number of reportable events. The performance record of TVA at Browns Ferry, however, does not indicate to Region II an inability to perform safely, a lack of technical qualifications or lack of competence.
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of Docket Nos. 50-259 O.L. 50-260 O.L TENNESSEE VALLEY AUTHORITY (Browns Ferry Nuclear Plant, Units l and 2) NRC Staff Res onse to Intervenor Contentions 2 and 3 Sco e of Testimon
- 1. This portion of the NRC staff testimony deals with Inspection and Enforcement (IE) activities. IE's mission is to inspect, to determine that licensees meet license and regulatory requirements as well as commitments in their Safety Analysis Reports. IE takes enforcement action as necessary to obtain corrective action for specific or programmatic deficiencies. These IE activities
interface with the the Office of Nuclear Reactor Regulation (NRR) whose mission is to evaluate the adequacy of licensee proposals and upon approval, promulgate licenses, including specific license conditions, amendments and Technical Specifications. A very simplified version of the relationship of the two NRC offices is that NRR evaluates what licensees propose, commit, or are required to do whereas IE inspects to determine that licensees do what they are required or committed to do and take enforcement action if needed.
- 2. This testimony provides in the first two sections, some of the philosophy upon which the NRC (IE) program is based. The second section also describes how the IE program is structured and why.
These sections were prepared by or under the supervision of Norman C. Moseley. The next two sections address the IE followup of specific hardware and program (non-hardware) deficiencies identified in the IE Investigation Report of the March 22, 1975 fire. These two sections were prepared respectively by or under supervision of the supervisory personnel responsible for the inspection activities, Messrs. C. E. Murphy and P. J. Long.
- 3. Sections describing inspections after the fire and inspections prior to the fire are separated by a section describing the evo-lution of operational QA requirements and the IE inspection program.
This order emphasizes the continuing changes in NRC requirements on TVA, in the TVA implementation of their program and in the IE
inspection program. Knowledge of these changes is necessary to understand what was inspected and how, during the reconstruction and during original construction. The operational QA section and the subsections addressing Preoperational Testing were prepared by I or under the supervision of W. C. Seidle. The subsection dis-cussing Restoration and Reconstruction and that discussing original Construction was prepared by or under the supervision of C. E. Murphy. The subsection on Operational Safety During Restoration and that on Operations Inspections Prior to the Fire were prepared by or under the supervision of F. J. Long. A Reportable Event analysis was prepared by or under the supervision of W. C. Seidle. These individuals are the supervisors of the individuals who performed the actual inspections. The final section draws together facts and conclusions contained elsewhere in the testimony to support IE conclusions concerning the contentions. This section was prepared by or under the supervision of N. C. Moseley. A Table of Contents follows:
TABLE OF CONTENTS NRC RESPONSE TO INTERVENOR CONTENTIONS 2 AND 3
~Pa e Introductiono ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 1 I. Overall Approach of NRC Program (N. C. Moseley).................... 3 II. Office of Inspection and Enforcement (N. C. Moseley)............... 4 III.'ollowup of Construction Type Deficiencies Identified During the Investigation. (C. E. Murphy) ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ . ~ ~ ~ .. ...
~ ~ ~ ~ ~ ~ ~ .... 13 IV. Followup of Nonhardware Deficiencies Identified During the Investigation (F. J. Long)......................................... 20 V. Inspections After Fire-............................................ 27
- a. Restoration and Reconstruction (C. E. Murphy)................. 27
- b. Operational Safety During Restoration (F. J. Long)............ 34 C ~ Preoperational Retesting (W. C. Seidle). ..........;.......... 38 VI. Operational Quality Assurance (W. C. Seidle)...................... 41
~Pa e VII. Inspections Prior to Fire.......................................... 48 aO Construction (C. E. Murphy) ~ ~ ~ ~ ~ ~ ~ ~ . ~........................ 48
- b. Preoperational Testing and Operating Readiness (W. C. Seidle). 61 C~ Operations Inspection Prior to Fire (F. J. Long).............. 67 VIII. Reportable Events (W. C. Seidle) ~ ~ ~ . .. ~ . ..................... 71 IX. Analysis of Performance (N. C. Moseley),......................,.... 82
INTRODUCTION
- 1. This testimony addresses the Intervenor's contentions 2 and 3 without breaking them down into separate sections. This is done because it is our opinion that the factual basis for determining technical qualifications of the licensee is intertwined with the contention challenging the ability of the Nuclear Regulatory Commission to adequately inspect'.the activities of the licensee. Therefore, the testimony treats the factual determinations of the technical qualifications of the licensee along with the Inspection and Enforcmeent program and its evaluation of TVA.
- 2. This testimony will show that in the past, fire prevention and protection were not given sufficient attention either by TVA or NRC. With this exception, the testimony will show that the NRC (IE) inspection program has been adequate. The basic mission of NRC, which is the protection of the health and safety of the public, has been accomplished on a continuing basis. Although TVA has been cited for items of noncompliance and a number of reportable events have occurred, IE evaluation of these items, individually and collectively has demonstrated that neither a lack of technical qualifications or competence of TVA exists. A demonstrated lack of either competence or technical qualifications by any licensee at any point in time would necessitate immediate action by IE to get either immediate correction or suspension of the activity.
- 3. Deficiencies in the NRC fire prevention and protection program have been corrected. This exception is not demonstrative of IE's inability J
to inspect, or perform its enforcement function. The upgrading of TVA's fire prevention and protection program is discussed in the Safety Evaluation Report and the adequacy of the implementation of TVA's fire prevention and protection program is discussed in this testimony.
I.. OVERALL APPROACH OF NRC PROGRAM
- l. An important foundation element of the NRC's total licensing program is the licensee's obligation to design, construct, and operate a facility which meets the NRC's regulatory requirements.
- 2. To meet the NRC's regulatory requirements, licensees must develop and put into operation a pyramid control system which at the bottom assures, through detailed inspections and tests, that all safety significant actions are properly done. These detailed verification activities require up to 100% inspection by the field quality control personnel of a multitude of individual actions. These programs provide the basis for accept/reject decisions on specific equipment, instrumentation, technician or operator actions and procedures.
- 3. Moving up the pyramid, licensees must have a quality assurance program including an audit which oversees and tests the adequacy of the performance of the detailed quality control tests and These programs provide feedback to the lower 1
level in the form of specifying changes in training, modifica-tion of procedures, upgrading or improving testing methods or equipment, requalification methods if required, and other programmatic improvements. Such feedback assures and enhances the reliability of the program as a whole which in turn assures and verifies that all actions which are of safety significance have been and will be properly carried out.
~ C 4. At the top of the pyramid, the licensee's management must J provide adequate organizational independence and manpower for its quality assurance and quality control programs and provide policy guidance to all components of the licensee's organization which requires and assures quality performance in all safety aspects of the construction and operation of his reactor facility.
- 5. Another basic element of the NRC program, which is important as background, is the defense in depth concept which employs multiple barriers and redundancy in equipment and operating
'I options. This approach assures that even if 100% quality is P
not always achieved equipment may malfunction and people may 5 ~ j ( not always do what is expected there will nevertheless be adequate protection of the public. So, although the goal is fautless performance, the safety of the public is not dependent on such perfection. II. Office of Ins ection and Enforcement General
- 1. The Office of Inspection and Enforcement (IE) is charged by the NRC to provide assurance through direct inspection that the licensees'erformance meets NRC's regulatory requirements
(and licensee commitments). Considering the extensive licensee control programs referred to above, the IE program may be viewed as the apex. of the pyramid which provides overall assurance of adequate quality in the construction and operation. of nuclear facilities. The object of the IE program is to assure that the licensee's program is actually performing its function of assurance that the NRC regulatory requirements are being met. The IE program is a selective audit, not a 100% verification of all phases of the licensee's program. Inspection of hardware, observation of tests, review of procedures and all other inspection activities are aimed not toward approval of individual components, actions, or procedures, but rather are aimed at evaluating whether or not-..the licensee's control systems are working. Whenever deficiencies are identified the IE program requires licensee action to prevent recurrence as well as correction of the specific deficiency. If results of a single inspection or a sequence of inspections indicate deterioration in the performance of the licensee's program in several areas, IE requires the licensee to examine his program in depth and upgrade the degree of control exercised at the higher level of the control system pyramid to assure that such deterioration is checked and the program as a whole returns to a satisfactory level of quality. Examples of this will be presented later in the testimony.
Sam lin Nature of IE Pro ram
- 2. The IE inspection program is really a Quality Assurance (QA) program as opposed to Quality Control (QC). It is not intended to duplicate the licensee program and does not perform a redundant independent review of every accept/reject determination.
Rather, it is a regulatory program aimed at determining, by spot checking and sampling, whether or not the licensee is in fact providing adequate assurance of quality in the construction and operation of his facility.
- 3. By spot checking and sampling, a much larger percentage of the licensee's control program and procedures is independently reviewed than would be the case if our review were limited to checking the individual quality actions; i.e., the detailed accept/reject actions. It is more effective to assure program performance than to concentrate on individual details. Then, if the licensee's program works properly, the licensee's quality assurance and quality control personnel will identify and correctly control the details of a wide range of activities.
If the licensee's program is not working properly, enforcement action is taken. Enforcement is discussed later in this testimony.
- 4. It is important to note that review of a procedure is a review of exactly how a job or action is to be done. A procedure
~ C contains prerequisites, criteria as to exactly what is acceptable and the detailed steps of how to accomplish the activity. Impor-tant procedures contain signatures of the people who actually do the work. So, reviewing a procedure accomplishes a great deal in terms of knowing that an <<ctivity is to be done properly or has been done properly. Similarly, our review of the licensee control program (pyramid) enables us to determine how and under what criteria the various quality assurance and quality control determinations are made within the licensee's organization. We can, therefore, design our spot checking and sampling programs to test the perfor-mance of various key steps. The IE audit or sample program is not a statistical random sample. The specific areas reviewed in detail ~
'> are selected from those considered to be the most important from nuclear safety standpoint. By specific spot checking and sampling a
review of QC actions we can, therefore, test whether a licensee's QA program is really working. Our review of the overall program gives considerable'onfidence that our spot check and sampling review provides an accurate assessment of the licensee's performance in meeting regulatory requirements. This, as indicated above, is the goal of our IE program.
- 5. Inspection of implementation of the licensee's QA/QC program is a key element in the determination of its adequacy. This inspection activity, still a non-random sample, involves observing that actual work activities are in accordance with procedures, license
requirements, technical specifications, plans and code require-ments. Inspectors question craftsmen and operators to determine
\
if they know and are adhering to applicable limits and requirements. The inspectors observe operating instruments and recorder charts to determine that operations are being conducted within regulatory requirements. They observe instruments being calibrated. Obser-vations are made as equipment is started up, shutdown or otherwise changed in operating mode. These observations and individual discussions with and questioning of,.people actually doing the work provide the basis for the determination of how well" the licensee is actually implementing his QA/QC program or management control system. ~ C 6. In inspecting the Browns Ferry restoration activities, Region II R used the IE inspection program for construction and preoperational testing with modifications indicated by the safety significance of the restoration work. The sample size was increased in some cases. Examples of sample size increases are inspection of penetration sealing, fire protection activities, and direct observations of work activities. Hi hli hts of the S ecific Ins ection Pro ram
- 7. The IE inspection program is dynamic in that over the years it has progressed from an undefined program relying on the professional
experience and judgement of qualified inspectors. These inspectors had 5-10 years of experience in one or more of the areas of design, construction, startup, testing and operation of USAEC owned and contractor'perated facilities, or military facilities prior to joining the Commission. Beginning, in 1968, inspection procedures were developed and issued for use. These procedures were based primarily on the collective experience of the inspection force and, even today continue to be improved, refined, and upgraded. The procedures bring a disciplined approach to the inspection effort, but inspector experience, knowledge, and training are important in that mature informed )udgment.:is an important factor in the inspec-tion process. Further, the IE inspection program requires each a.
< inspector to allocate 20% of his inspection onsite time to looking into his choice of licensee safety related activities. In this way, if his experience indicates that there may be a problem in a certain activity, he has time to pursue it to his satisfaction.
8.. Inspections at each site are made by individuals with training and experience in the particular area in which each inspects. Most inspections involve several inspectors each with a different area of expertise. Each Regional office is staffed with engineers (inspectors) trained and experienced in the major engineering disciplines (Mechanical, Electrical, Nuclear, Chemical, Metallur-gical, etc.)
- 9. In addition to the inspection program aimed at evaluating licensee performance in planned activities, the IE program also includes in depth review of licensee preformance in unscheduled events. These events, sometimes called Abnormal or Safety Related Reportable Occurrences or Unusual Events, are reviewed by inspectors on a sample basis to determine if Safety Limits, Limiting Conditions for Operation, or other Technical Specification Limits were exceeded.
Further, the inspectors evaluate whether equipment, people, and procedures did their job during and subsequent to the event. Inspectors also evaluate the effectiveness of the licensee's followup, review, and 'corrective action. The inspector's review of these events begins upon receipt of notification of the event by the licensee. The inspector asks questions by telephone or if the event is of sufficient significance he goes to the site with appropriate backup inspectors in the engineering, disciplines related to the specific problem. Onsite followup involves things such as discussion with the people who were actually involved in the event, review of instrument charts for the time in question, visual inspection of damaged equipment, observation of nondestructive or destructive tests, reading all related logbooks, review of engineering evaluations and calculations made by the licensee and performing independent calculations. Samples may be taken for independent analysis. Pro rammatic Feedback
- 10. Feedback from the inspection process works on two levels. First, when an inspector, based on his knowledge or experience, determines that the specific regulatory requirements (license or technical
'specifications) are not resulting in an adequate performance (equip-ment, component, or operation) he makes recommendations for improve-ments. These recommendations are considered by appropriate Office of Nuclear Reactor Regulation (NRR) engineers and, if appropriate, become the basis of upgraded regulatory requirements.
ll. The inspector also feeds back his recommendations for improvements in the IE inspection program, Regulatory Guides, Codes and Standards. These recommendations are considered by the responsible NRC group or individual and as appropriate, are contained in revisions to the program and documents. In this way, each individual inspector contributes to the continuing improvements of the NRC program. Enforcement
- 12. The IE enforcement program is not intended to be punitive in nature.
It is specifically aimed to obtain prompt corrective action by licensees of the deficiencies, broad and specific, which are identified through direct inspection. In the enforcement letter from the Region, the items of noncompliance are specified and corrective action is requested for the specific items in addition to action to preclude repetition In taking action to preclude repetition, the licensee corrects the program deficiency which allowed the specific noncom-pliance to occur. This program action must include correcting other like items, if they exist. Por example, if the inspector identified failure of the licensee to perform a nondestructive test on certain components, the licensee would be required to determine if the. testing had been done on other like components and if not, perform it on all. In followup the IE inspectors verify that both the specific and program actions are completed. If a deterioration in the licensee performance is perceived, IE field supervisors, frequently including the Regional Director meet with top level licensee management to discuss the IE concerns. These meetings are intended to focus licensee management attention on the IE concerns and to get licensee action started on resolution. These meetings are followed by higher level enforcement actions when the meetings do not result in the desired improvement. l3. The IE enforcement program complements the sampling or audit inspection philosophy. By assuring that licensee program upgrading results from specific noncompliances identified by the inspector, continued reliance can be placed on the validity of IE's inspections which place heavy emphasis on evaluation of licensee's quality assurance programs. III. Followu of Construction e Deficiencies Identified Durin The Investi ation
- 1. Facts developed during the course of the investigation of the Browns Ferry fire and the events leading to the fire revealed numerous noncompliances, and areas of concern. These are described in the report of the investigation. (Ref. Inves-tigation Report No. 50-259/75-1). Inspections of the restora-tion activities subsequent to the fire indicate that those items related to cleanup, modification and reconstruction have been resolved to the satisfaction of the Office of Inspection and Enforcement.
- 2. Five deficiences specifically relating to plant construction were identified during the investigation. (Of these deficiencies only the two related to the penetrations had safety significance as far as the fire was concerned.) These deficiencies were:
Penetration seals had not been completed. Cables had been installed in cable trays in excess of that permitted by TVA design criteria. The physical location of the fire barriers in the penetration did not conform to the approved design drawings. Metal plates installed during construction under the breakout glass in the C02 system manual crank stations had not been removed. Power cable supplying two of the 480 volt shutdown boards were routed in a common tray in violation of the separations criteria.
- 3. The significance of these items and the action to correct them are discussed below.
- 4. As discussed in the investigation report, the immediate cause of the fire was the ignition of polyurethane which had been used as a cable penetration sealing material. The electrical penetrations in the cable spreading room had not been inspected since their inspection was not specifically required by the IE inspection program and their potential effect on plant safety was not fully appreciated. The investigation revealed that many of the seals had not been completed during construction; the integrity of others had been violated Subsequent to their completion. The polyurethane would be exposed in either case contributing to the cause of the fire.
- 5. TVA's restoration plans required the removal of the polyurethane and the substitution of ablative and fire retardant type
materials as sealant materials (Silicone RTV Foam, Cerafelt, Cerafibre, Cera Form and Marinite). Region II has verified, by inspecting a large sample, as documented in the inspection reports 1/ that the polyurethane has been removed from Units 1 and 2 and the penetrations resealed in accordance with approved drawings and using approved materials. Additionally, the penetrations and cable are required to be coated with a flame retardant compound. (Flamemastic). A series of tests were conducted by TVA on a mockup of a completed penetration to verify that the penetration would successfully block the spread of fire. A pressure differential was maintained across the penetration during the tests to duplicate the conditions that would exist during plant operations. A gas fed heat source of several hundred thousand btu/hour capacity was applied to the cable on the positive pressure side of the penetration. The insulation on the cables on this side was destroyed without the fire penetrating the barrier. Region II observed the conduct of these tests. As further protection TVA is installing fire extinguishing systems utilizing water as the extinguishing agent. 1/ Reference IE Inspection Report Nos. 50-259/76-6, 50-259/76-8, 50-259/76-11, and 50-259/76-14
- 6. The investigation of the fire areas revealed that penetration seals had not been properly completed prior to the operation of Units l and 2 nor had they been maintained subsequent to operation. The sheet type polyurethane used in certain of the penetrations had not been specifically approved by the TVA design department. Additionally, the investigation revealed that the steel plate bulkhead which is a part of the bulkhead had not been located midway between the faces of the wall which is common to the cable spreading room and the reactor building.
- 7. TVA's procedures require that each step in the rework of the pene'trations be inspected by personnel independent of those doing the work and that these inspections be documented.
Region II inspectors, as documented in the inspection reports have been observing the work in progress, auditing the licensee's inspection" reports, and are inspecting the penetrations to their completion. 2/ subsequent
- 8. The location of the steel plate bulkheads in the penetration have not been changed to conform to the original design. The "as constructed" location made detection of leaks more difficult and contributed to the difficulty of the initial fire fighting 2/ See footnote 1 efforts. Location of the bulkhead midway between the faces of the wall as specified by design would have required a reach of only 10 inches to examine and seal the penetration. Location of the bulkhead as constructed required a twenty inch reach.
Adding to the difficulty of reaching the penetrations in the bulkhead was the fact that the cable trays spacing restricts the free wall opening area between trays to about five inches. Thus a person attempting to examine or seal a penetration would have difficulty observing what he was doing. The same would be true of anyone attempting to extinguish a fire in the penetration. Although the sheet polyurethane had not been specifically approved, it was the same generic type of material that had been approved and all of the polyurethane used in the penetrations was flammable. As a result of design changes, the penetration sealing and fire proofing materials have been changed and polyurethane is no longer used.
- 9. Since polyurethane is no longer being used in the penetrations, its previous use no longer impacts on plant safety. Additionally, the penetrations now contain fire retardant materials, and the leak detecting methods used by TVA do not now depend upon a flame; therefore, the position of the steel plate in the penetration is no longer critical since these other measures have been taken to preclude a fire from involving that area of the penetration.
- 10. During the investigation it was determined that in one instance cable supplying power to two of the 480 volt shutdown boards were routed in a common tray in violation of the separations criteria. This routing error had not been detected by the IE inspectors since these particular cables had not been selected for inspection as a part of the inspection sample. The failure of these two cables did not have a significant effect on the operation of the plant since both of the shutdown boards had alternate sources of power. As discussed in the Safety Evaluation Report, the most significant cause of the loss of redundant equipment was associated with failures of their power sources which were caused by short circuits to breaker indication lamp circuits leading from the control circuits of Reactor Motor Operated Valve (MOV) boards. These lamp circuits have been removed. These circuits had been installed as shown on the design drawings. The IE inspection program does not include an examination of the adequacy of plant design.
IJ
- 11. In two cases cable had been installed'n cable trays slightly in excess of that permitted by the TVA design criteria. TVA's criteria are based upon the trays being level full when cables occupied 60% of the tray volume. Where additional fillcould be obtained by dressing the cable in the tray, it has been TVA's practice to permit the installation of cable to the level full loading. The installation of the excess cable had little if any effect on the plant operation during the fire since the trays did not contain cables of redundant systems and, as previously stated, the principal cause of the loss of redundant systems was the failure of the indicating lamp cables.
- 12. Metal plates had been installed during construction under the breakout glass in the C02 system manual crank stations to protect personnel from the inadvertent release of C02 Although the installation of the plates caused a slight delay in the release of the C02 in the cable spreading room, the effect on the fire and on plant operation was insignificant.
- 13. The inspection activities conducted since the fire have verified that, with the exception of the metal bulkheads, TVA is correct-ing the construction type deficiencies identified during the IE investigation of the fire. The location of the steel bulkheads no longer adversely affects plant safety and their relocation is not necessary.
IV. Followu of Non-Hardware Deficiencies Identified Durin Investi ation
- l. In the Investigation Report of the Browns Ferry fire, certain deficiencies in management administrative control systems for control of safety related activities were identified. These deficiencies included failure to provide approved written and reviewed procedures for safety related repair work, failure to adhere to prescribed emergency procedures for initiating alarms and delegation of responsibility, failure to promptly identify and correct conditions adverse .to quality, failure to conduct inspections to verify conformance to drawings, failure to assure independence of inspectors, and failure to conduct appropriate audits. Other concerns were related to inadequacies in the implementation of the TVA and State of Alabama Radiation Emergency Plans.
- 2. Inspections, which have been performed on a continuing basis since the fire, have been directed towards verification of improvements in management systems with particular emphasis on those related to operational safety. NRC concerns previously defined have been resolved to the satisfaction of NRC.
- 3. The licensee's approach to resolution of weaknesses in the management administrative control systems has been to strengthen the review process for procedures governing all safety related activities with emphasis on maintenance, indoctrination and training of individuals performing safety related activities or supervising such activities, and followup of corrective actions on identified weaknesses in the control systems. The identifying of safety related systems and activities is now formalized to the extent that all planned activities are being and will continue to be evaluated for safety significance and the determination of the need for procedural control prior to commencing the activity. Procedural changes were reviewed by the IE inspectors and discussions with the inspectors revealed that greater indepth reviews are now being performed by the licensee prior to initiating work under new or revised piocedures.
(See Inspection Report No. 50-259/76-13). These reviews include a more thorough determination of the possible inter-actions between systems and identification of sensitive areas that could be affected by activities in progress. In addition, new procedures will require a review by the QA supervisor to assure that activities which are planned and which may have an effect on safety, are clearly supported by approved instructions necessary to performance of the activities prior to commencing work.
- 4. One of the NRC concerns was the timely identification and correction of conditions which could be adverse to quality.
The NRC relies heavily on the thorough implementation by the licensee of this 10 CFR 50 Appendix B requirement combined with IE verification of implementation by direct inspections. Revisions have been made to improve and strengthen licensee administrative procedures for documenting conditions adverse to quality and the ultimate corrective actions.
- 5. These procedures control both onsite and corporate responsi-bilities in this area. Our inspectors have also verified by direct review and by discussions with cognizant licensee personnel, that plant administrative instructions for reporting of conditions adverse to quality, have in fact been thoroughly reviewed, upgraded and incorporated in the employee training program.
- 6. With regard to the licensee's program of audits to measure the effectiveness of the management systems, licensee requirements have been broadened to include some areas not previously determined to be safety related either by the licensee or NRC.
This is especially evident in those areas associated with fire protection, fire fighting and associated training to enhance capabilities in these areas. (See Inspection Report No. 50-259/76-9)
- 7. Certain of the NRC identified items of noncompliance or other concerns were related to failure of the licensee to adhere to
Emergency Procedures in effect at the time of the fire. Our inspectors have observed that the licensee has taken appropriate action to assure greater emphasis on emergency procedures. (See Inspection Report No. 50-259/76-13) New employees now will receive fire safety orientation and participate in periodic fire drills to assure the proper actions to be taken in case of fire. In addition, the licensee has more clearly defined procedures for both delegating on scene fire fighting responsibilities and the assuming of responsibility by in-dividuals including the evacuation of personnel, making reports, and obtaining of offsite assistance when necessary.
- 8. Other NRC areas of concern were related to inadequacies in the implementation of the TVA and State of Alabama Radiation Emergency Plans. Our inspectors have subsequently verified that TVA and the State of Alabama have taken actions to assure effective implementation of the emergency plans. (See Inspection Report No. 50-259/76-9) To test the effectiveness of implementa-tion of the state plan, an exercise was conducted by the state of Alabama'ith full participation from all principal off-site agencies. The inspectors have also witnessed and evaluated an emergency exercise conducted by the licensee in accordance with the Technical Specifications. (See Inspection Report No.
50-259/76-13) ~ ') 23~
- 9. To obtain an independent evaluation of the adequacy of the Brown's Perry fire protection systems, IE engaged an outside consultant to accompany our inspectors onsite. The consultant participated directly in inspections with IE inspectors, performing a review of selected licensee procedures and instruc-tions, conducting extensive discussions with key licensee personnel, and making direct observations of selected safety related plant areas. The consultant identified areas where improvements could be made in the physical arrangements of fire protection systems and particularly, in the area of training for fire protection and other onsite personnel. The recommendations of the consultant have been incorporated in the Staff's Safety Evaluation Report for Brown's Perry.
Conclusions
- 10. There was no general breakdown in the TVA management control systems prior to the March 22, 1975 fire. Although problems 1
were identified which demonstrated inadequacies and omissions in the management systems for control of safety related activities, fires were not generally recognized as a major safety issue. The licensee had responded adequately to all non-fire related concerns called to his attention by IE before the fire. We have no reason therefore, to believe that the licensee's response to fire related concerns would be other than adequate. ll. When the investigation findings related to the fire were weighed against the circumstances surrounding the incident, IE could in no way conclude that TVA was incapable of operating the plants safely. In that a completely safe shutdown of the facility was obtained under the most adverse conditions, i.e., loss of control of automatic safety systems, the knowledge and abilities of the plant operating personnel were well demonstrated.
- 12. On May 5, 1976, TVA notified the Region II office that a fire occurred in the drywell of Unit 1 on May 4, when molten metal from a burning (flame cutting) operation ignited air hoses in the near vicinity of the work. This fire was reported for information, not being clearly reportable under the terms of e
the license. Region II inspectors were sent to the site to examine circumstances associated with this fire. In addition to reviewing details of this specific fire, the inspectors reviewed construction records for the period subsequent to the March 22, 1975, cable fire and identified seven other minor fires involving ignition of waste materials during flame cutting or welding operations. Inspection Report Nos. 50-259/76-12 and 50-259/76-13 discuss these fires. The fires were judged by the inspectors to be of very little significance
and presented no threat to plant safety. Four of the minor fires had previously been identified by the inspectors and were discussed in IE Report No. 50-259/75-15.
- 13. The latter of the total of eight fires (May '4, 1976) was the only one having any significance and of any concern to IE.
One item of noncompliance was identified during the inspection relating to this fire, and IE deemed it necessary to meet with licensee management to discuss possible weaknesses in the TVA control systems which permitted work to be performed contrary to work procedures which were in effect. Subsequent to this meeting, corrective actions were taken by the licensee to preclude problems of this type and these corrective measures were verified by IE inspectors. (See Inspection Report No. 50-259/76-13)
- 14. The March 22, 1975 fire has in no way reduced IE confidence in the ability of TVA to design, modify, test or operate the Browns Ferry facilities. This also reflects the IE Position regarding the several other minor construction fires discussed above.
>>26-
V. Ins ections After Fire
- a. Restoration and Reconstruction Back round
- 1. As a result of the fire in the electrical cable penetra-tion area of Unit 1 reactor building on March 22, 1975, approximately 1600 electrical cables and several hundred feet of electrical cable trays and conduit were damaged.
Soot containing chlorides contaminated the structural surfaces; the inside and outside of cabinets, cubicles, racks and panels; and electrical motors, pumps, exposed piping cable in trays, and instrumentation in the Unit 1 reactor building and in some areas in the Unit 2 reactor building.
- 2. Following the fire, Region II initiated an inspection program utilizing experienced inspectors from the region's construction branch to inspect the plant restoration activities including the QA program for the control of these activities. As will be discussed later (Ref.
Section Vll.a.), Appendix B to 10 CFR 50 became effective about midway through the construction of Browns Ferry. TVA's QA program for construction was acceptable by the standards of that period but would not be by today' standards. The QA program for operations was not designed to control the types of activities required for the plant restoration. TVA, therefore, implemented a program that drew upon both the construction QA program and the opera-tions QA program to control the restoration activities. Particular emphasis was placed by IE on the implementation of this program. Sco e of Construction Ins ection Effort
- 3. The objective of the inspection program was to verify that restoration was accomplished in accordance with the TVA Restoration Plan and that commitments made by TVA and the requirements, regarding construction work, placed on TVA by the NRC were met. To accomplish this, it was neces-sary to determine by inspection that the soot contaminated equipment, structures, and components were replaced, repaired or restored to their original operating condition; fire damaged trays, conduit, and electrical cables were identified, repaired or replaced; and records of the QA inspection and restoration activities verified that work performed and licensee QA inspection effort were adequate.
These inspections are documented in the IE inspection reports. +3 3/ Reference IE Inspection Report Nos. 50-2S9/75-7, 50-259/75-10, SO-259/75-11, 50-259/75-13, 50-2S9/75-18, 50-259/76-2, 50-259/76-4, 50-259/76-6, 50-259/76-10, 50-259/76-11, 50-259/76-14 Level of Ins ection Effort
- 4. One or more experienced inspectors from the reactor construction branch were on site 2-3 days of every week for the first 8 months followng the fire. The inspection effort was then reduced to 2-3 days every other week.
Beginning in May 1976, the inspection effort was increased to provide coverage every week. Approximately 135 mandays of inspection effort have been spent as of May 21, 1976, in following the construction related restoration activi-ties to date. The initial inspections concentrated on verifying that TVA had established an acceptable gA/gC C'rganization, work; restoration and had developed approved procedures 4/ for ~ 5. Following this, inspections were directed toward following cleanup of structures and removal and cleanup of components and equipment including cable, conduit and trays. from all elevations of the Unit 1 reactor building and identification of contaminated areas in the Unit 2 reactor building. 5/ 4/ Reference IE Inspection Report Nos. 50-259/75-5, 50-259/75-7, 50 259/75 9~ 50 259/75 10~ 50 259/75 13~ 50 259/75 18~ 50 259/76 2>> 50-259/76-4, 50-259/76-10 5/ Reference IE Inspection Report Nos. 50-259/75-5, 50>>259/75-7, 50-259/75-10, 50-259/75-11, 50-259/75-13, 50-259/76-2, 50-259/76-4, 50-259/76-6, 50-259/76-10, 50-259/76-11
- 6. Later inspections involved following the removal, replace-ment and splicing of electrical cables. Throughout the entire program, inspectors observed work performance and made extensive reviews of work plans, QA plans, and QC records of all work. 6/
Si nificant Findin s Durban Restoration Activities
- 7. The first construction inspection of TVA's program plans and their implementation for restoration of Units 1 and 2 was conducted from April 30 to May 2, 1975. (Ref. Report No. 50-259/75-7). This inspection revealed that the cleaning and refurbishing of circuit breakers and motor contxollers were in progress but without QC inspections or identified testing prior to reinstallation. The inspection also revealed that an incorrectly identified electrical pumper had been installed, that electricians were installing cables without QC inspections and that debris was being removed from the bottoms of control panels without proper protection provided to the equipment.
In a telephone conversation between NRC (Mr. Moseley) and TVA (Mr. J. E. Gilleland) on May 2, 1975, TVA agreed to 6/ Reference IE Inspection Report Nos. 50-259/75-10, 50-259/75-11, 50-259/75-13, 50-259/75-18, 50-259/76-2, 50-259/76-4, 50-259/76-10, 50-259/76-11, 50-259/76-14 halt the restoration activities pending completion of modifications to the TVA QA/QC program and related procedures for accomplishing complete control of the restoration activities. (Ref. Letter Moseley to Gilleland, dated May 2, 1975). The modifications to the QA/QC program, were completed on May 7, 1975, and Region II concurred that restoration activities could be resumed. (Ref. Ltr. Moseley to Gilleland dated May 7, 1975).
- 8. During the construction inspection conducted on February 9-ll and February 24-March 1, 1976, it was determined that the TVA audit schedules were not being updated at the required frequency. (Ref. Report No. 50-259/76-4). This inspection also revealed one instance where a cable was installed in Unit 2 in violation of the minimum bend radius requirements. Both of these noncompliances were subsequently corrected by TVA. (Ref. Ltr. Gilleland to Moseley dated April 2, 1976). Neither of these non-compliances are considered to be of immediate safety significance. The failure to adhere to the audit schedule did not result in any activity not being audited. The requirements relating to cable bend'adii are sufficiently conservative that the cable was not damaged.
- 9. During the inspection conducted on June 19, 1976, several cable trays were observed that were filled above the level of the tray side rails and thus possibly did not comply with TVA's acceptance criterion which limits tray fill to 60% of the tray volume based on the cross section of the cables in the tray. TVA has advised IE:II that they have analyzed each of these trays and have deter-mined that no safety-related tray exceeds the acceptance criterion.
Conclusion
- 10. IE's inspections of TVA's initial restoration activities indicated that the management controls based upon the QA program which had been established for restoration were not effective. When this matter was brought to the attention of TVA's management, work was immediately stopped. Prior to the resumption of work, a separate QA/QC organization was established for control of the restoration activities. The management of this organi-a zation was appointed from the Office of Power Quality Assurance and Audit Staff. Inspection procedures with identified hold points were developed and inspectors were assigned to inspect all restoration work. After the restoration activities were resumed, work was not permitted to proceed beyond the hold points prior to inspection.
- 10. The two noncompliances identified during the Pebruary 1976 inspections are considered to be isolated occurrences without direct safety significance and, as stated above, were corrected by TVA.
- 11. In summary, TVA has completed the restoration activities, IE has inspected the restoration work. These inspections have verified that TVA's upgraded . . . QA program has been effective in controlling the plant restoration, that identified discrepancies have been corrected and that restoration has been accomplished in accordance wit;h the restoration plan and that special commitments and the requirements have been met.
I
- b. 0 erational Safet Durin Restoration Back round
- 12. At the time of the March 22, 1975 fire, both Units 1 and 2 were in commercial operation at nominal full power. Shortly after commencement of the fire both units were shutdown and have remained in the cold shutdown status since then. Puel was removed from both reactors in early July 1975. The initial IE post-fire inspection 'effort involved the dispatch of three inspectors from Region II on the evening of March 22, 1975.
Immediately upon arrival at the site they began a review and verification of the safety of the shutdown facility. Sco e of 0 erations Ins ection Effort
- 13. Concurrent with the IE fire investigation effort there was an interim special inspection program established which assigned inspectors on a rotation schedule so that each week inspectors were onsite to inspect operations relative to maintaining the reactors in a safe cold shutdown status.
- 14. Early inspection activities concentrated on the licensee's restoration of component operability and the establishing of configurations that would assure reliability of redundant systems to supply reactor make-up water and core cooling
-34
capability. Temporary procedures were developed for operating the systems in .their modified out of normal configurations. These activities were inspected in-depth by the inspectors.
- 15. TVA developed and submitted to NRC, a Safety Analysis Report (SAR) to describe the post-accident facility. After NRC review and evaluation, Temporary Technical Specifications were issued as a license amendment on May 9, 1975. The new SAR and the Temporary Technical Specifications provided the inspectors with more definitive criteria on which to base their inspections.
- 16. A decision was later made to unload the fuel from both reactors.
Consequently another SAR was prepared and NRC issued another license amendment on June 13, 1975, to authorize fuel removal and storage. This new amendment established Interim Technical Specifications to cover planned operations. Inspectors verified that systems configurations and surveillance testing required by the Interim Technical Specifications were implemented.
- 17. NRC inspections included on-site review and observation of fuel removal and storage. With the fuel in the storage pools, fewer systems were required to be operational to assure the safe storage of fuel. This permitted a reduction in the amount of NRC on-site inspections continued with emphasis on maintaining the fuel in safe storage. Other inspections included non-fire related modifications, surveillance testing, instrument calibration, radiation protection," physical security, procedure review, record review, training organization and administration, fuel channel inspection and drilling, fire prevention, procurement and followup of reportable occurences and IE Bulletins.
- 18. More than 134 mandays on operational inspector on-site inspection time was spent during the post-fire period to verify the continuing safety of the plant in its interim shutdown configura-tion and conformance to regulatory requirements.
Si nificant Findin s Durin Ins ections
- 19. During the post fire period, Region II inspectors found that regulatory requirements were being met, with respect to activities associated with fuel handling, fuel storage shutdown operations, and modifications which were not related to fire recovery. There were 5 items of noricompliance identified concerning, (1) performance of modification work with drawings which lacked final approval; (2) failure to f6llow a .radiation control procedure; (3) failure to post information on radiation safety as required by NRC regulations; (4) procedure not adhered to and (5) an item on physical security. The correc-tive actions were reviewed by the inspectors and the items were found to have been brought in compliance with regulatory requirements.
- 20. In the numerous discussions with plant management during onsite and corporate inspections during recovery operations, the inspectors found the licensee to be responsive to their comments (Rpt. Nos.: 259/75-14, 260/75-13; 259/75-19, 260/75-18; 259/75-15, 260/75-14'59/76-1, 260/76-1; 259/76-3, 260/76-3; 259/76-7, 260/76-7; 259/76-12, 260/76-12; 259/76-13, 260/76-13). Numerous improvements have been made, particularly in the management control systems and in document control.
Corrective actions on both licensee identified and NRC identi-fied concerns have been accomplished on a timely basis. Conclusions
- 21. Our inspectors report that TVA has kept them well informed and has provided continuing assurances and given prompt attention to concerns brought to the attention of TVA management by the
~ inspectors. Operating personnel as well as plant management have demonstrated clearly an awareness of plant safety both immediate and long term. We have identified no areas of concern relating to safety in the operations segment of the plant during the restoration that would be contrary to the position that TVA can operate the plant safely following completion of restoration.
- c. Preo erational Retestin
- 22. The preoperational retest program is performed to verify by actual system operation that all restoration work on fire damaged electrical cables and equipment has been correctly performed. This is accomplished by identifying those portions of the systems that were inoperable as a result of cable damage and verifying through system retest of the damaged portions that the systems operate in the same manner as required before the fire.
- 23. Performance of surveillance instructions in conjunction with the retest procedures demonstrates that plant systems have been properly restored and are in the same readiness condition to operate that existed prior to the fire.
~Sco a
- 24. The Region II inspection program for Browns Ferry 1 and 2 during this phase is similiar to what would be done prior to issuance of the initial operating license for any facility.
The purpose of the program is to verify that surveillance instructions and preoperational retests have been satisfactorily performed prior to fuel loading and startup. In addition, special emphasis is being placed on the review and witnessing of the preoperational retest procedures for the high-pressure fire protection system and C02 system.
- 25. The Region II office has spent 23 mandays of inspections directed toward the retest program as of May 21, 1976. This inspection effort, to date has included the revie~ of 19 preoperational retest procedures, the review of the test results of 29 completed preoperational retest procedures, and the witnessing of portions of 10 preoperational retests. The total retest program involves 96 preoperational retest procedures.
Si nificant Findin s Durin Prep erational Retesti Ins ections
- 26. The review of retest procedures has not identified any areas of concern to IE. The retest procedures generally consist of surveillance instructions and portions of the original preoperational tests, all of which had been previously reviewed, approved and successfully performed. Based on the results of inspections performed, Region II concludes that operation of Unit 1 and 2 can be resumed safely.
- 27. The reviews of the preoperational retest results have not revealed any areas of concern to IE. Test results reviewed have indicated no testing deficiencies, and indicate that systems and components tested have met the stated acceptance criteria.
- 28. Witnessing of preoperational retests has shown that the tests were performed as required by procedure, test prerequisites were met, crew actions have been observed to be correct, and
'imely, and all data was collected, analyzed and compared to stated acceptance criteria.
Conclusion
- 29. TVA has satisfactorily demonstrated that the systems are operational in the manner established by current requirements.
The retest program and its implementation were thorough and have clearly demonstrated the adequacy of the design, the installation and the operability of those systems which have been completed.
- 30. The IE inspection program which included the review of all preoperational retests has assured that all testing has been completed and that stated requirements were met as defined in "Plan for Evaluation, Repair and Return to Service of Browns Ferry Units 1 and 2 (March 22, l975 Fire)" Part ZI, Section C.
VI. 0 erational ualit Assurance Prelicensin Unit 1
- l. In November 1971, TVA issued the "Browns Ferry Nuclear Plant, Operational Quality Assurance Manual," (OQAM) that defined TVA's corporate requirements for implementing Appendix B to 10 CFR 50. It was the responsibility of the Plant Manager to implement these requirements. The methods for implementing the OQAM requirements were normally defined in plant administra-tive procedures (Standard Practice Manual).
- 2. Until late 1973, inspections of QA Programs for Operation at newly licensed facilities were based on the criteria established in Appendix B and Industry Standard ANSI N18.7-1972, Administra-4 tive Controls and Quality Assurance for the Operation of Nuclear Power Plants. In the case of Browns Ferry 1, the following inspections of the operational QA program were performed:
- a. The BF principal inspector reviewed the OQAM for conformance to 10 CFR 50, Appendix B requirements. Review and evalua-tion of the OQAM was based on the inspector's and IE:II's understanding and interpretation of Appendix B requirements.
Several areas of concern were identified by the inspector and transmitted to IE:HQs for evaluation. These and other areas of concern were eventually acted on and corrective actions implemented by TVA.
- b. Plant procedures were reviewed to determine that OQAM requirements would be implemented at the site. TVA provided IE:II with a cross-reference of OQAM requirements to related implementing procedures.
C~ Additionally, the Browns Ferry overall system of procedures was inspected. At this point in time, Appendix A to Safety Guide 33 (Regulatory Guide 1.33) was used un-officially for inspection guidance for determining what plant procedures were required. Although QA/QC procedures are not uniquely identified in Appendix A to Safety Guide 33, certain procedures discussed therein, are, in fact, QA/QC procedures. For example, the administrative pro-cedures for: (1) procedure review and approval, (2) equipment control, and (3) maintenance controls, with inspection requirements that'now are'onsistent come under the heading of Quality Assurance. Several deficiencies were identified: (1) plant procedures had not been developed for all activities identified in Appendix A to Safety Guide 33, (2) policy with regard to usage and periodic review and updating of procedures was not formally established, and (3) the scope and content of certain plant procedures were found to be inadequate. These discrepancies were corrected prior to licensing of Unit 1. Prelicensin Unit 2
- 3. In November 1973, a series of Regulatory conferences were held with industry re'presentatives to provide appropriate guidance on quality assurance requirements during the operations phase of nuclear power plants. The guidance covered information discussed in Rules and Regulations, Regulatory Guides and available Industry Standards, and was issued as WASH 1284.
Subsequent inspections of QA Programs for Operation at newly licensed facilities were based on the guidance provided in WASH 1284. During these conferences, it was announced that a prelicensing inspection of each plant's operational QA program would be performed approximately 90 days prior to the anti-cipated date of licensing.
- 4. The operational'.QA program at Browns Ferry was inspected during April 1974, prior to licensing of Unit 2. The major purpose of the inspection was to determine if FSAR commitments made in Section D.4," Operational QA Program Plan," had been implemented. This was done in two steps:
- a. First, the BF Operational Quality Assurance Manual (OQAM) was reviewed to determine if TVA had established corporate policy or requirements that would assure that FSAR commit-ments would be satisfied.
- b. Second, the BF Standard Practices Manual (SPM) and other documents appropriate for implementation of the OQAM policy and requirements were reviewed to determine if the OQAM had been implemented by responsible organizations.
- 5. The inspection resulted in the identification of nineteen (19) areas where the QA program for operations, as described in the FSAR, had not been adequately implemented. These discrepancies were resolved prior to licensing of Unit 2.
- 6. It 'should be noted that this inspection took place six (6) months after the November 1973 QA conference. IE policy at that time, was not to inspect to guidance contained in industry
'tandards unless the applicant had clear commitments to those standards defined in the FSAR.
- 7. At the time Unit 2 was licensed there was not an onsite QA organization as specified in the WASH 1284. TVA had no commit-ment for an onsite QA organization at that time. However, TVA was in the process of establishing an onsite QA organization.
An onsite QA organization was in-fact, established subsequent to licensing of Unit 2. Prelicensin Unit 3
- 8. It has been IE policy to upgrade the QA program at multiple unit sites prior to licensing of each sucessive unit. This
-44<<
upgrading has been based on experience gained and the availa-bility of new guidance relative to QA for operating plants. The QA program inspected for prelicensing of Unit 3 at Browns Ferry would be equally applicable to Units 1 and 2.
- 9. Subsequent to the QA conferences, specific procedures for IE inspection of QA Programs for Opexation at newly licensed facilities detailing the scope and depth were initially developed and issued in June 1974. These procedures wexe based on the criteria established in 10 CFR 50, Appendix B and information discussed in available Regulatory Guides and Industry Standards,
- 10. The procedures for inspection of QA 'Programs for Operation at newly licensed facilities were revised and Mplemented in April 1975. They reflect experience gained through use of the previous issues and advances in Regulatory requirements and Industry Standards and are being continuously updated to reflect new criteria.
ll. September 1975, TVA submitted Amendment No. 62 to the FSAR. Admendment No. 62 describes the Browns Ferry Operations QA Progxam and TVA's position on QA relative to NRC endorsed guidance contained in:
- a. Guidance on Quality Assurance Requirements during the Operation Phase of Nuclear Po~er Plants (Orange Book) dated October 26, 1973 (WASH 1284)
- b. Guidance on Quality Assurance Requirements during the Construction Phase of Nuclear Power Plants (Green Book) dated May 10, 1974 (WASH 1309)
- c. Guidance of Quality Assurance Requirements during the Design and Procurement Phase of Nuclear Power Plants (Gray Book) dated May 24, 1974 (Rev. 1) (WASH 1283)
- 12. In October 1975, the Operational QA Program for Browne Perry 3 was inspected in accordance with IE inspection procedures using TVA commitments contained in Amendment No. 62 to the PSAR as acceptance criteria. Browns Perry's QA Program for Operations was found to conform to these commitments with three exceptions relative'o Plant Training, QA Audits and Material Procurement (IE Inspection Report 50-296/75-12).
These discrepancies were subsequently resolved (IE Inspection Reports 50-296/76-2 and 76-7). Conclusion
- 13. The inspection of Operations QA at Browns Perry prior to the licensing of Units 1, 2 and 3 respectively. i11ustrates the development and evolution of improved operations QA techniques in the nuclear industry: Prior to Licensing of Unit 1, the application of Appendix B to 10 CFR 50 to operating plants was not clearly understood or defined. TVA and NRC were on a learning curve and QA was implemented and inspected to the extent that it was understood at the time. In the interim between licensing of Units 1 and 2, work on industry standards progressed significantly and the nature of operations QA became better understood. The Operations QA conference was held and consequently, greater implementation by licensees and inspection by IE of Operations QA were improved. After Unit 2 was licensed TVA was required to better define their QA commit-ments (Amendment 62 to the FSAR). NRC had better defined what is expected in an operations QA program and subsequently by the inspection procedures. Consequently the prelicensing QA for Operations inspection conducted for Unit 3 was in greater depth and more comprehensive than previous inspections.
- 14. Therefore, NRC concludes that the Browns Ferry QA Program for Operations has been progressively strengthened from prelicens-ing of Unit 1 to the present time and that the Browns Ferry Nuclear Units can continue to be operated safely within the framework of their existing operations QA program.
VII. Ins ections Prior To Fire
- a. Construction
'I Back round
- 1. TVA was granted permits by the Commission on May 9, 1962, to construct two boiling water reactors on the Browns Ferry site. This summary includes the construction inspection effort which began shortly after issuance of the construction permit and terminated with fuel loading for each unit.
~ Sco e of Construction Ins ection Effort
- 2. The objective of the inspection effort was to determine, by inspections utilizing sampling techniques, that the plant was constructed according to commitments made in the PSAR and in correspondence with Licensing. This objective was reached by 1
examination of management controls, quality assurance and quality control manuals, procedures and records, and observations of work in progress. Work in progress was examined by experienced engineers for quality of workmanship, conformance to control procedures and conformance to codes. Records were examined to verify that purchased equipment met the quality specified and to verify that quality control systems were implemented throughout construction. Level of Ins ection Effort
- 3. After issuance of the Provisional Construction Permits, inspectors performed inspections of TVA's design and pro-curement offices in Knoxville, equipment vendors facilities, and construction activities at the site. In addition to the scheduled inspection efforts, the inspectors met frequently with the TVA management to discuss construction activities.
- 4. Site inspections included detailed inspection of selected examples of the following activities:
Site excavation Concrete in Class 1 structures such as reactor buildings and control bays. Welding of drywell and torus plating, primary pressure boundary piping and other Class 1 piping systems.
.- Installation t
of Reactor Pressure Vessel. Installation of Reactor Internals Installation of electrical cables, panels, conduits, trays, switchgear, battery systems, diesel generating systems, and normal and emergency service. Installation of instrument components, panels and racks, and control system.
- Installation of Class 1 mechanical components.
- 5. The IE construction inspection program was completed in conformance with internal instructions and procedures.
Accomplishment of this program involved 18 experienced in-spectors who conducted 55 independent inspections utilizing approximately 350 mandays of inspection effort. Enf orcement Summar
- 6. During the construction inspections prior to the fire 22 items of noncompliance were identified. These items, together with corrective actions taken, are listed in Table VII-1. None of the items of noncompliance involved the cable spreading room, cable penetrations nor violation of cable separations criteria.
Based upon the items themselves together with corrective actions taken, and our analyses as documented in Table Vll-l, none of the items of noncompliance are considered to have safety significance.
- 7. A large percentage of the items of noncompliance were violations of Appendix B to 10 CFR 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," which had been made a requirement at Browns Ferry midway through construction. A review of construction inspection records shows that the number of noncompliances decreased as personnel were trained and became more familiar with Appendix B. Additionally,=as documented in Table 1, the items of noncompliance do not'eveal any generic type deficiencies or any trends or patterns of noncompliance that would be indicative of a breakdown in TVA's Quality Assurance Program.
Conclusion
- 8. The construction inspections revealed that those items selected for detailed inspection were constructed according to specifications, that TVA's QA program was effective in preventing repetitive types of deficiencies and gave reasonable assurance that the plant was constructed in accordance with applicable requirements and with TVA's commitments. Electrical penetrations in the cable spreading room were not a part of the inspection program during the period prior to the fire. The licensee as documented in the inspection reports and related correspondence was responsive to citations, and all items of noncompliance were resolved to the satisfaction of IE.
., 52-,.
Browns Per Units 1 and 2 Noncom liance Items Identified Durin Plant Construction Activit and Dis osition Date and Re ort Reference
- a. Concrete
- 1. Tests of concx'ete compressive stx'ength Pebruary 6-9, 1968 not being made according to code pro- 50-259/68-1 visions. The method used, however, was determined to give conservative results.
- 2. Time expended placing one batch of con- July 10-12, 1968 crete in intake structure excessive. 50-259/68-3 This was determined to have been an isolated case and controls to preclude repetition were instituted.
TABLE VII-I
- 3. Electrical cable inadvertently embedded January 13-17, 1969 in concrete. The volume of void was an 50-259/69-2 insignificant fraction of total concrete mass ~
- b. Weldin Flame CuttM and Nondestructive Examination
- 1. Coated weld rods were not protected to February 6-9, 1968 preclude absorbing excessive moisture. 50-259/68-1 Action was taken to preclude repetition.
The quality of the welds was not in question in this case. Weld quality was determined by nondestructive examination and by pres-sure testing. These examinations and tests would have revealed any defective welds.
- 2. Flame cutting of drywell penetration not June 4, 1968 accomplished according to designs and 50-259/68-2 specifications.- Action was taken repetition.
to'reclude Although weld quality could have been adversely affected by the
)oint preparation, testing following completion of the welding confirmed the weld integrity.
TABLE VII'ONTINUED) 3a. A welding procedure used in the drywell July 10-12, 1968 assembly contained unauthorized 'changes. 50-259/68-3
- b. A special weld process was used in making April 3-6, 1973 a weld on the Unit 2 core spray line 50-260/73-3 without having a .qualified procedure.
These items represent isolated events and corrective actions were taken to preclude repetition. Although the quality of the welds was not in question, any defects in them would have been detected by required tests. 4~ TVA reported to NRC (then the:AEC) that November 18-21, 1968 a contractors'mployee had falsified the 50-259/68-6 radiographic records for the drywell by substituting falsely identified film for welds which were not radiographed. All welds were reradiographed=- to assure that no weld defects existed. TABLE VII-I CONTINUED
- 5. A 1-inch stainless steel pipe drywell July 10-12, 1968 penetration had not been protected from weld 50-259/68-3 splatter and the attachment welds for some of the penetrations exhibited slight weld undercutting. The weld splatter was removed. Required testing confirmed the weld integrity.
- 6. The sizing and shimming of penetrameters Sept. 9 Oct. 2, 1970,
,for radiographs of the recirculating line 50-259/70-7 did not comply with applicable codes.
The quality of the welds was not in question. Required tests, however, would have revealed any weld defects. The radiography procedures were revised to preclude repetition.
- 7. Welder qualification requirements were not October 3-6, 1972 being adhered to in that welders were per- 50-259/72-9 mitted.to have a weld regect rate in excess of procedure requirements. Rejected welds were being repaired and retested. The procedure was revised to better define refec-tion rate.
TABLE VII-I (CONTINUED
- 8. The experience of two technicians and one Sept. 9 Oct. 2, 1970 engineer did not meet the requirements for NDE 50-259/70-7 certification. The ability of the individuals to .perform NDE examinations was not'questioned.
Additionally, welds examined by them received other required tests. A training program was instituted to preclude further noncompliances.
- c. Pi in Valves Vessels and Mechanical E ui ment
- 1. The General Electric Company rejected the TVA February 17-19, 1969 reactor vessel pedestal design on the basis of 50-259/69-3 seismic design criteria. This item was referred to Licensing for resolution. GE subsequently accepted the TVA's design.
- 2. Misalignments of individual control rod drive March 11, 1969 hydraulic lines 'through the drywell penetra- 50-259/69-4 tions were detected. Correction was made by bending the lines to obtain proper alignment.
Lines were tested to detect flaws after realignment. TABLE VII-I CONTINUED)
- 3. A through wall defect was found in the April 8-11, 1969 parent metal of an electrical penetration 50-259/69-5 in the drywell. The defective section of penetration piping was removed and a new section was welded onto the stub and the complete 'assembly tested.
- 4. The Reactor Cleanup Regenerative Heat Ex- June 24-27, 1969 changer, the Reactor Cleanup Non-regenerative 50-259/69-8 Heat Exchanger, the HPCI system pumps and tur-bines, and the RHR heat exchangers for Unit 1 were installed prior to receipt of QA documen-tation at the site. The documentation was subsequently transmitted to the site.
- 5. Main Steam Line Isolation Valves weld prepara- June 8 and July 11, 1972 tions were not according to code and minimum 50-259/72-4 wall thickness requirements were not met.
Purther,information and analyses were provided by TVA and the valves were deter-mined to be acceptable. TABLE VII-I CONTINUED
- 6. Pressure and leak rate testing of the drywell Sep. 16-19, 1968 did not meet requirements. The require- 50-259/68-5 ments were met on subsequent tests.
- 7. RHR System pipe hanger designs, modifications May 15-18, 1973 and installations were not being controlled. 50-260/73-4 All of the deficiencies were corrected.
- 8. The procedure for baseline inspection of the Apr. 30 and June 10, 197 ~
reactor vessel did not meet code requirements 50-260/74-5 and the tests were not properly documented. The procedure was corrected, the vessel was reexamined and measurements documented.
- d. Instrumentation and Electrical E ui ment Cable Cable Su ort S stems
- 1. The location of redundant safeguards systems May 18-21, 1971 control equipment and the routing of sensor 50-259/71-4 and TABLE VII-I (CONTINUED) lines serving redundant systems appeared to June 20-23, 1972 violate separations criteria. The 50-259/72-6 deficiencies were corrected to conform to separations criteria.
- 2. Certification that essential control equipment May 18-21, 1971 would perform during and following the design 50-259/71-4 seismic event was not available. Cer-tifications were subsequently received.
- e. Audits and Re orts
- 1. TVA issued a procedure in October 1972 re- Jan. 30 Feb. 2, 1973 quiring the reporting of conditions adverse 50-260/73-1 to quality. The procedure had not been M-plemented. TVA took corrective action to require adherence to the procedure require-ments.
- 2. Audits were not being conducted on a.six Oct. 3-6, 1972 month cycle as required by procedure. TVA 50-259/72-9 took corrective actions to require adherence to the procedure schedule, assigned additional personnel to perform audits and increased the depth of audits.
TABLE VII-I (CONTINUED)
- b. Prep erational Testin and 0 exational Readiness Ins ection Back round
- 1. The preopexational test pxogram inspection is initiated about 18 months before the estimated OL issue date. It includes activities related to the operational preparedness of the plant and overlaps the latter stages of the construction inspection program. Initial phases of startup testing in-spection overlap the latter phases of the preopexational inspection program. Preoperational inspections are essential- ~
ly complete at the time of OL issue.
- 2. The objectives of the preoperational testing and operational preparedness inspection program are to verify through direct observation, discussions with personnel, and review of facility documents that:
Systems and components important to the safety of the plant are fully tested to demonstrate that design requirements are satisfied. Management controls and procedures necessary for the operation of the facility are developed and implemented. Sco e of Prep erational Ins ection Effort
- 3. Preoperational testing and operational preparedness inspections at Browns Ferry for compliance with FSAR commitments and 10 CFR 50 requirements included the following:
- a. Review of preoperational test procedures for adequacy.
- b. Witnessing of preoperational tests.
- c. Review of test results after completion of tests.
- d. Review of administrative controls and quality assurance governing the conduct of preoperational testing and facility. operation.
- e. Review of health physics programs, radiological and environmental protection program, waste management, emergency plans and procedures. and physical security.
- f. Reviews relating to establishing the operations quality assurance program.
- g. Review of document control and licensee audits.
- h. Followup of IM Bulletins.
Review of startup test procedures. Review of operating procedures and the surveillance testing program and procedures.
- 4. Region II inspectors spent approximately 200 mandays on-site inspecting the preoperational testing of Units 1 and 2 between May 18, 1971 and June 28, 1974 (June 28, 1974 is the date of OL issue on Unit 2).
Si nificant Findin s Duri Preo erational Testi
- 5. During this period, 13 items of noncompliance were identified on Unit 1 and 3 items on Unit 2. These items dealt with per-forming tests without properly approved or adequate procedures, inadequate documentation of test data, inadequate test control and performance of tests not in conformance with procedure.
The corrective actions were reviewed by the inspectors and were determine to have brought the items into compliance with regulatory requirements. (IE Rpt. Nos.: 259/71-9; 259/72-1; 259/72-2; 259/72-3; 259/72-5; 259/72>>6 259/72-7; 259/72-8; 259/72-10; 259/72-11; 259/72-12; 259/73-3; 259/73-6; 259/73-9; 259/73-14; RO:II letters to TVA dated February 26, 1973, April 6, 1973 and July 16, 1973; 260/73-10; 260/73-13; 260/74-8)
- 6. The single most significant item occurring during the preopera-tional test phase was the complete interruption of preopera-tional testing on Unit 1 by the licensee for about 4 months commencing in May 1972. This interruption was made to re-I evaluate and upgrade major aspects of the overall preopera-tional test program. IE concerns prior to the preoperational testing interruption included:
Failure of the planned test program to fully meet the recommendations of the NRC Guide for the Planning of Preoperational Test Programs (December 1970). Conduct of the preoperational testing without approved procedures, and test procedures containing insufficient instructions to obtain desired test data. Additional inadequacies in the preoperational test program identified in March 1972 dealing with quality assurance, records and test control.
- 7. On May 4, 1972, Region II representatives met with TVA manage-ment to discuss concerns relating to the quality assurance and preoperational test programs. Preoperational testing was subsequently discontinued. TVA's"written response dated 6/5/72 entitled "Proposed Modifications to BFNP Preoperational Test Program in Consideration of AEC Compliance Concerns" described TVA actions:
Reorganization of the test program to provide control of testing from beginning to end. Addition of detailed pre-requisites to preoperational test procedures Issuance of more detailed test instructions Upgrading of test acceptance criteria Assurances that PSAR and other safety commitments were met
- 8. IE inspections over the ensuing months verified resolution of previously identified noncompliance items and areas of concern Preoperational testing was resumed during the fall of 1972.
It should be pointed out that although this particular area was considered significant at'he time it had no bearing on the March 22, 1975 fire, because it concerned administrative controls associated with the preoperational testing program rather than the actual testing of hardware. The NRC required and obtained resolution of all items of noncompliance relating to preoperational testing prior to OL issue. Conclusion
- 9. The NRC preoperational testing and operational readiness inspections revealed testing deficiencies on both units, all
of which wexe adequately resolved prior to operating license issuance. Based on the number of noncompliance items, fewer deficiencies were identified on Unit. 2 than on Unit l. Upon completion of the preoperational testing program for each unit, a recommendation for issuance of an operating license was made by the region. Recommendations fox issuance of the operating licenses denoted satisfaction by the inspectors and regional supervision, with all aspects of the preoperational testing and operational readiness program. Management systems for control of safety related plant testing were judged to be entirely adequate and in full compliance with NRC requirements in effect at that time.
- c. 0 erations Prior to Pire Back round
- 1. TVA was granted an operating license by the Commission for Unit 1 on 6/26/73 and for Unit 2 on 6/29/74. Initial fuel loading for each unit began shortly after receiving the opezating license. This summary includes startup testing which began with fuel loading and then proceeded to initial criticality and power ascension, followed by commercial operation. Inspections up to the date of the fire, March 22, 1975, are included.
Sco e of 0 erations Ins ection Effort
- 2. The ob)ectives of the inspection program during the startup phase was to verify that the systems important to safety were tested under operating and transient conditions to demonstrate that the systems performed as designed, and to verify that QA and other management controls were implemented as required.
Inspections duxing the operating phase, which actually overlaps the startup phase, are designed to confirm that the management control program is effective and that the facility is being operated safely and in conformance with regulatory requirements.
- 3. After issuance of the operating licenses, inspectors were at the site to witness portions of the initial fuel loading for each reactor. Inspectors were also onsite to witness initial criticality of each reactor. The continuing IE inspections effort included witnessing portions of 6 startup tests on Unit 1 and 5 startup tests on Unit 2. Test results and re-ports were reviewed at various steps in the power asccension phase. Inspectors reviewed results of 13 different tests on Unit 1 and 16 on Unit 2. Inspection activities, besides those directly related to the startup testing, which began with receipt of the operating license included the following, most of which are the areas normally covered during the operating phase:
- a. Conformance to the Technical Specifications
- b. Operator performance of licensed activities
- c. Implementation of procedures in the Operational Quality
- d. Assurance program
- e. Review of surveillance testing required by the Technical Specifications
- g. Review of operating procedures
- h. Review of maintenance activities including the preventive maintenance program
- i. .Review of document control Review of the activities of the Plant Operations Review Committee and the Nuclear Safety Review Board
- k. Review of operating records
- 1. Followup on reportable occurrences
- m. Followup on responses to ZGE Bulletins
- n. Followup on corrective actions taken on noncompliance items
- o. Review of the operating organisation and administration
- p. Review of physical security
- q. Review of the radiation protection program
- r. Review of the nonradiological environmental program
- s. Review of emergency planning
- t. Review of training
- u. Review of the licensee's review and audit program
- 4. The total man-days spent inspecting at the site during the first year that Unit 1 was licensed was 87 with some of that effort being spent on preoperational inspection of Unit 2.
Prom the end of this period, which is also the time Unit 2 was licensed, until the date of the cable fire, March 22, 1975, another 50 man-days of site inspection time was spent on Units 1 and 2.
- 5. During the first year of Unit 1 operation, there were 35 items of noncompliance identified, with 14 more noncompliance items being identified during the following 9 month period before operation was terminated by the fire. Unit 2 experienced 17 items of noncompliance during this same 9 month period. Of these identified during this 9 month period, 11 applied to both units. (Note that the IE recordkeeping system counts a single item of noncompliance twice if it applies to both units.)
The history of noncompliance did not include any items related to the March 22, 1975 fire. The bulk of noncompliance items, particularly in the first year of Unit 1 operation, related to problems with document control, equipment testing and inopera-bility, procedure and interpretation. The corrective action on each item was reviewed by an inspector and was found to have brought each item in compliance with regulatory require-
,ments.1/
Conclusion
- 6. The inspection results showed a marked decrease in the number of noncompliance items being identified during the latter period of operation prior to the fire. This can be attributed in part, to encountering and solving startup problems with a new plant. The inspectors noted that the licensee had imple-mented corrective actions on a timely basis and was responsive to the inspectors'oncerns. NRC concluded that TVA management was adequately involved in the conduct of operations and that the plant was being operated in compliance with identified NRC requirements. The NRC had no basis for questioning the licensee's ability to operate and maintain the plant in a safe condition.
1/ Report Nos. 259/73-10, 259/73-12, 259/73-13, 259/73-14, 259/73-15, 259/73<<16,"259'/74-..1, 259/74-2, 259/74-3, 259/74-4, 259/74-5, 259/74-6, 259/74-8, 259/74-10, 260/74-9, 260/74-11, 259/74-9, 260/74-15, 260/75-1, 259/75-2, 259/76-3, 260/76-3, 260/75-2, 259/75-4, 260/75-4, 259/75-15, 260/75'-14 VIII. Re ortable Event Anal sis Introduction
- 1. The reporting requirements for the occurrences that are set forth by Appendices A and B of the Technical Specifications are the bases for the reportable events that are analyzed in this section. Appendix A specifications relate to health and safety and Appendix B specifications relate to environmental impact.
) 2. The term "abnormal occurrences" was used, in the past, to designate any unscheduled or unanticipated operational event
~, U that was reportable under the requirements of Appendix A specifications. These occurrences included events having significance from the standpoint of public health or safety and events reported for the purpose of performances evaluation of trends. The term "reportable occurrence" has replaced the original "abnormal occurrence" for this definition and the term "abnormal occurrence" is now limited to events that are determined by the NRC, to be significant from the standpoint of public health or safety.
- 3. Items of noncompliance are sometimes identified by the licensee in some of the event reports and these are evaluated by NRC as part of the internal inspection program. An item of noncompliance is defined as a failure to comply with regulatory requirements.
- 4. Since the above definitions for Appendix A Technical Specifi-cations reporting requirements were not implemented until late 1975, the majority of the events in this evaluation have been designated "abnormal occurrences" even though they may have had no significance from the standpoint of public health or safety.
General Evaluation of Environmental Events
- 5. Ninety-three environmental events have been reported. These events were related to fish impingement on the intake screens or water temperature of Wheeler Reservoir.
- 6. The number of reports relating to fish impingement has been reduced because of change in the reporting requirements defined in the Appendix B environmental technical specifica-tions. Improvements were made in the intake structure that reduced the intake water velocity and included a diverter flume that directs the fish away from the intake screens.
- 7. The .temperature reporting requirements are misleading in that, for approximately 25 days/year, the ambient temperatures of Wheeler Reservoir are greater than the specified maximum.
These reports will be reduced when the closed cycle cooling system (cooling towers) is put in service.
- 8. These events do not relate to nuclear safety. Furthermore, these events do not reflect on the competence of the licensee to modify or operate the facility. It should be noted that appropriate corrective action has been taken to reduce the fish kill; but, because this matter is site related, further study and possible corrective action may be required.
General Evaluation of Reactor Events
- 9. The most significant reportable event was the fire of March 22, 1975, which went considerably beyond typical fires in that it affected engineered safety features. The IE investigation of this fire is documented in IE Investigation Report Nos.
50-259/75-1 and 50-260/75-1.
- 10. The majority of the 203 reportable reactor events for both units, about 52%, reported up to April 1976 were caused by component failures. About 15% of the events were related to design errors and a like quantity (15%) were related to personnel errors. The fourth category of note is defective procedures which made up 10% of the events. The remaining 8%
include items where the cause was not clearly identified or the cause was external. See Table I. ll. It should be noted that the time frame considered in this evaluation was during the preoperational and power ascension test program when proof testing was underway to demonstrate feasibility of procedures and to identify components or
, systems that could not meet the defined requirements. There-fore, it was expected that there would be a larger number of component failures during a rigorous testing phase of plant operation. Over 40X of the events were determined during document review, prooftesting or surveillance testing. Also, it was expected that the test program would uncover design errors and deficiencies in procedures.
,j/
- 12. The initial 6 months of operation of Unit 2 showed only about one half the total reportable events as the initial 6 months of operation of Unit 1. In'his period, significantly less total numbers were attributed to defective procedures and component failure.
Evaluation of Desi n Errors
- 13. The category of Design Errors shows a marked reduction as the testing program progressed for each unit. One half, 15 of 31, of the events were identified either during the routine surveillance program or during the startup tests. This supports the concept of a rigorous test program.
Evaluation of Defective Procedures
- 14. The procedural problems were related to procedures and check lists during maintenance and return to service after maintenance, ad-I ministrative procedures, and operating procedures with approxi-mately 1/3 in each of these groups. The number of events was much less for Unit 2 because the same procedures were used for both units.
Evaluation of Personnel Errors
- 15. Of the 31 occurrences reported, 22 were caused by non-operating personnel such as licensee instrumentation, maintenance or construction personnel and vendor personnel.
- 16. In a comparison of personnel errors for Unit 1 and Unit 2, there was evidence that the number of events'as reduced for the second unit. This indicated the favorable impact of additional training and experience, and the improvements in procedures which more clearly defined areas that could lead to personnel errors.
Evaluation of Com onent Failures
- 17. Of the 106 occurrences reported as component failures, 38 were associated with the Emergency Core Cooling System, 36 were associated with the Primary Coolant System and the remainder were associated with miscellaneous safety related systems or auxiliary systems.
~ 75
- 18. The 38 component failures for the Emergency Core Cooling System were categorized as follows:
a ~ Calibration or Setpoint Drift
- b. Valves or Valve operators ce Switches, Instruments or Controls
- d. Miscellaneous
- 19. The 36 for the Primary Coolant System were categorized as follows:
- a. Calibration or Setpoint Drift
- b. Valves or Valve Operators 22
- c. Switches, Instruments or Controls
- d. Miscellaneous
- 20. Five of the valve failures were related to the fact that the MSIV's closed faster than allowable; however, this fast closure did not alter the valves'ffectiveness in isolating the main steam lines. There were several instances where a leaking pilot valve caused the relief valves to either operate prematurely or fail to reseat as expected; these failures did not impair the primary function of the relief valves to relieve excessive primary system pressure. Many of the valve operator failures were related to locking nuts that were not securely fastened and this resulted in valve operator motion without actual valve motion.
- 21. Fifteen occurrences were 'related to a setpoint drift problem on equipment provided by one manufacturer. All of these events occurred between August 1973 and February 1974. The licensee had initiated corrective action that included in-stallation of locking devices on the equipment, increased surveillance frequency and application of more conservative settings on the equipment. No events have been reported since February 1974. This problem was not limited to the Browns Ferry Unit; it was a generic problem and the solution applied to all affected units.
Conclusions
- 22. The fact that the ma)ority of the reportable occurrences were related to component failures is expected, because the units were in a testing phase during most of the reporting period examined. The reporting period was not long enough to establish a trend; However, there was a marked reduction in the reportable component failures for Unit 1 during the first quarter of 1975, before the fire, wherein the rate dropped from approxi-mately 35 per year to 4 per year since only one of the two reported items occurred prior to the fire in 1975.
- 23. The fact that the setpoint drift problem has not been the subject of required reports since February 1974 indicates that the licensee's actions have been effective.
- 24. No objective evidence is available to substantiate the cause of the major reduction in reported component failures for the first six months of operation of Unit 2 as compared to Unit l.
This would be expected due to corrections made by TVA on possible component defects in Unit 2 based on actual problems experienced on Unit l.
- 25. The reduction of reportable events in the categories of "component failure," "design errors" and "defective procedures," that
\
occurred during the progress of the test program, demonstrates the merits of a rigorous test program at the outset of operation to identify and correct potential problems before there is a significant event from the standpoint of public health or safety.
- 26. Five of the 199 events have been identified to involve D
in-operability of more than one emergency cooling system at the same time. The most notable of these events is the March 22, 1975, fire where several of the emergency cooling systems were put out of service at various times during the fire (see IE Investigation Report Nos. 50-259/75-1 and 50-260/75-1) and the licensee demonstrated that he cauld still maintain the core in a safe condition. One event involved concurrent inoperability of the High Pressure Coolant Injection System (HPCIS) and one division of the Core Spray System; at this time the licensee initiated a reactor shutdown as required. The three remaining events involved the HPCIS and the Reactor Core Isolation Cooling System (RCICS); in each instance, the licensee initiated appropriate shutdown action. The remainder of the events reviewed did not involve concurrent inoperability of redundant emergency core cooling systems and therefore, effective core cooling and safe shutdown of the reactor was always possible. Tabulation of LER's for Browns Fer Units 1 & 2 Unit No. 1 O.L. Date 6/26/73 Year Defective Component Personnel Design External Not Other Total Procedure Failure Error Error Ident 1973 38 64 (6 mos.) 1974 33 64 1975* 10 1976* 16 75 18 21 5 143 Unit No. 2 - 0, L. Date 6/29/74 Year Defective Component Personnel Design External Not Other Total Procedure Failure Error Error Ident 1973 1974 22 TABLE VIII I 1975* 2 1976* 1 31 10 60
- Units have not operated since March 22, 1975, fire and Modified Technical Specifications have been in effect much of this time.
TABLE VIII 1 (con'd) IZ. Anal sis of Performance
- a. TVA (1) The jointly held conclusion of Region II inspectors and supervision is that the March 22, 1975, fire had broad causes. They are: (1) failure of TVA to recognize the nuclear safety significance of the penetration sealing work being performed, and (2) failure of the NRC, TVA and the entire industry to fully recognize the extent of the potential for damage from an electrical fire. It is believed that had either of these not existed, actions would have been taken which would either have precluded the fire or dramatically reduced the consequences. A detailed analysis of "safety related occurrences" or reportable events is contained in Section VII of this testimony. The resolution of "construction anomalies" is discussed in Section III of this testimony. The items of noncompliance (called violations in contention 2) were evaluated individually and collectively by Region II as they occurred. Prior to the fire in two cases Region II considered that collective inspection results warranted direct pursuit with higher level TVA management. The first management meeting (Report 259/72-3) resulted in TVA discontinuing preoperational testing at Unit 1 for several months until corrective action had been accomplished.
On January 30, 1974, (Report 259/74-2) a Region II Branch
>>82-
Chief met with TVA to discuss the need for more complete details in event reports and to discuss TVA's interpreta-tion of equipment operability. Since this interpretation would effect continuing decisions by TVA it was belived impoxtant that a clear understanding be established. Subsequent actions by TVA confirmed that the meeting accomplished its mission. As a result of the fixe investigation, IE wrote an enforcement letter expressing concern fox the management control system weaknesses which allowed the items of noncompliance and areas of concern. Here again; TVA has been responsive as is discussed in this testimony (see Section III and Section IV of this 'testimony). A further occurrence has transpired where IE believed it necessary to pursue a matter ex-peditiously with TVA management. This involved the lack 4 of adequate control of modifications subsequent to the fire (see Section V.a). The immediate action letter which Region II sent to TVA resulted in prompt effective action. (2) Notwithstanding the fact that items of noncompliance should not occur, and management systems should be effectively established and implemented, considering the two broad causes discussed in the opening paragraph of this section, the collective performance at Browns Perry does not establish a lack of competence or technical
qualifications. Certainly, the goal of the regulatory program is no items of noncompliance and minimum reportable events. The defense in depth concept, however, anticipates that everything will not be perfect. Accordingly, the safety of the public is not dependent on perfect per-formance either by people, equipment, or management systems ~
- b. NRC Ins ection and Surveillance (1) The deviation from original construction requirements (Section III) did not contribute significantly to either the cause or extent of the damage from the fire. Neither were they key in the lack of functional performance of redundant engineered safeguards during the March 22, 1975, fixe. The IE fire related inspection program prior to the fire consisted primarily of limited review of fire prevention/protection as it related to emergency planning as a whole. Likewise, it has been stated that NRC (as well as TVA and the entire industry) failed, prior to the fire, to fully recognize the extent of the potential for damage from an electrical fire. Both of these deficiencies have been recognized and are being remedied. The IE inspection program has been modified to include fire prevention/protection items outlined in IE Bulletins 75-04 and 75-04A, These bulletins were specifically based on
-S4-
lessons learned from the Browns Ferry fire. The inspec-tion of fire prevention/protection at Browns Ferry since the fire was also based on commitments made by TVA in the restoration plan. Further improvements in the IE in-spection program will follow as more specific codes and requirements are developed. Accordingly, deficiencies which did exist in the IE inspection in the area of fire prevention/protection are being corrected on a continuing basis. (2) Although not a deviation from original construction requirements, the uncontrolled use of flammable materials was most significant in the March 22, 1975, fire. This use is attributable to one or both if the two broad causes of, the fire discussed above, not to basic de-ficiencies in the IE inspection program. If the IE inspection program had identified all deviations from the original AEC construction requirements, the course of the fire would not have been significantly different. In summary, it is believed that the basic deficiencies have been identified and have been addressed with continuing improvements underway. PER. SNXTH: Nr. Chairman, Hr. iloseley has pre-pakeQ a snort SUKilarv 0'" the tes ~lmong Uh3.cA he coulQ gxve at this ci~ci.e ~ CHAXBi&21 REXiL": That v-ouM he helpful. 57X1%SSS hQSZLB~'r. Chairat~a, our testimony Qeals 4'lith the Xnsp Bct3.on anQ EXLforc~~pient or X~~ as ve a-.e called activit'es: .XB's mission, . s .=o inspect to 8etexRin th' l"c'eeds fee license QnQ egulato~ rccjuiz'e ments as;rail co~~a'hncnts in the'r Safety B.nalsy~s Reports. i0 XH takes enforca~ent act9 on as necessarv 'to QB ta" n corrective acticn for spec9.fic ok progrc'".>Aatic defic iencies
.p These'XE activies int"relace arith the Of"ice "of Hucm~ar Reactor Regu2.ation, NRR as it is callect, ~>hose mis-s on "'s to evaluate the acteguacy of licensee proposals mrs upon approval promulgate licenses, including specific license conritions, amer~enis, md Technical'pecif=cations.
A very simplifiecx version of relationship of the two hRC offices is that NBR evaluates what license s propose, 20 ca+it or are required to Qo whereas XE inspects to determine
~hat l"censees Qo 'What Chef're reguireQ ox'QNQlittetR to ciao 7
and tate enf orment action f needed i Our testimonv provides in the fir'st two sections st:- Qf 1 98 philo'30phv Uon KQlich the HRC/XP inspection program is Basec~ 1
cal8 The second sacc::on a."so describes hoar tha XB program 's structured and why. ve '>est i>.iad earlier > Z prap~~aa Ukase sections The next tvo sections address the i8 ."ollowrup
~
on specific hare~mare end -' or program vhici are nonhard~zare de."iciancias, identified in date iH invastiga-'-ion report of-'he Horch 22, 1975 -ire.
'9.'hase Ceo sections >rare prepared respectively bJ, o" uncar ~he sup zvision, of up rvisozp personnel responsi-hlo "or that part"cga.az insp ction activity; Nassra Long and
~ahxzphy i Sections describing inspections Qatar the fixe zing inspacticns p"ior to the lira a a separated by a section Qa-scribing th. avoluation of operational QB. reqmiramen'ca and the X inspection program. This ozdor emphasi"as Qi e continuing changes in the MAC xeguir ments on TV@ in the TVA implem ntation of "meir program'and in the XE inspect'on progzwn. Knowledge of Geese c. anges is necessary, ve halieve," to undo 'nd +ha was inspactec. and how during the reconstzuction and during original construction. Tha operational QA section and the subsections addressing preojarational tasting vera prepared by or under the supervision of %~i Seidle ~ The subsection discussing RestorQG2.on and
~'.econstrnct" an ~~>ld t3Mt'iscussing &B ar" gina" Canst uc 3.an ~iere pre~."-x~8 j3v 0- v3lc~e"'ac sate~'-"~as o~ bc~. Hnrpny.
2he QU33sectxan an Qperav~ one.~. Safety Dur3.ng the Hesi;aratian and that an.Operations Xnspections Prior ta t&ie 2 'ze o'ere preparect bv or uncover 'H7B superdxs~ on of ljlr~ Lang ~ A ReQi~x'G~~le Zvent analysis was pre&areQ >y or l'4".Ger '818 84per<zisian af SLY i Gei818 o The f3.nal section of our testimony Bra:rs together facts mQ canc" usions Gontaine8 elselvh e in the test" many to support ~ canglgsions cancermng the contentions. 2nd as Z previously te t'fied, X prepared'+at section. How. our te. timaxy aQQresses the Zntmmei~ar Can- I tentidns
~
N 2 and 3 ~without hzeal:ing them into sepa"ate "-actions. aliis is Bane because in aur op'nion the factual basis for determining tcchnical gnelificatians of the lic 'lsee is in-teri:asineQ writ'I 5>e contention challenging the ability of the Huclear Regulatory Commission ta aaequatelv inspect the acth.vit3.4"s 02 Mvle licensee ~
'2b~refare, th testimony treats the factual c~ete3md.nations of the i ecLinxca3. Qualificat3.0ns of the li
, c~~nsee cRlong witll t¹ ih"pection and enforcement program in its evchlnati 0"l az TVA.
~'his testimony will shor that 'n U e past, fi e pr vention mQ protection "'ere nat given sufficient attention,
harbl7 either by TVA or L3K. Kith e:.:caption, testimony vi2.1 sham T31B~ he Ht4CQZF inspection progzap:. has. been adequate o The ~DQSic immission of Bldg lsl i@2'. 3. - "ihe protection qf the hea3.th and safety of the public has "een accomplished an a continuing basis. A%2:c lou(Yh TVA has been cited for it~~Ls of non-corn pliance and a number of Reportable Ev nt have 'occurred, ZE evaluation of these items individua3.3y .and collectively has demons recited that reiAez a lack of technical qualifications or corap tence of TUB. exists. demonstrGti~d lack ox competence oz 'cecnn3.cal qua'lifications by a 1'censee at any point in time would necessitate immediate action ay XE .ho get either immediate correction ox'uspension 0>> that activity.
$ 5 Deficiencie in. the i3K fire prevention and pro-tection program have been corrected. Th's ezception 1
is not demonstxai:ive of:" 's inability to inspect or perform 3.>
struction and Engineering Support Branch, Pegion VT.
9, BM nhat was your position in Region XX, Mr.
Sei'Qle?
Xn Region XX X Uas Q Section Chief in Operations ~
MR. STG:TH:, &Jr. Chairman, ve have .a copy of the p ehearing conference transcript Gated Thursday, capri'l '2.,
2.976. inc page l8, line 20, if X may read it2 CKPXK~0 BZXLLY: Yes; the Board has a copy neer,
Thani.". voui I ~'Tcu~ d appreciate 3.t 3. f poll K'lould read it,in.
AH. SR~ZTH: Line 20 begins this is Dr. Ccruan speaking.
"And X think it, would be appropriate for something to be said ~out ho~~ the Tl7A con@3.iance 8 record compares with the records of o"he- pc'.e'er A
reactor companies recent years.
'10 ZAz?d p a" sop of course, we would be in-ter sted in some con>ment about the seriousness and the nature of the departures. from approved design which have been refe=red to 'n some of the document already."
He believe that the'NRC Staff Response to Board Question addresses as best. we can the first par of that question relat'ng to comparison of other utilities. Our tes imony goes into a great deal of evalua-tion of the seriousness of the nat use of deficiencies from 20 approved design. CE~2ZHl1tK KBZLLY: All right. T. think the tran-script quote w" 1" more accurately reflect what the Board's guest i'as ~ 24 Than';~ you, Hr. Garner.
423 CFiPXB"~MT iKZLL~Z: note <ha~ ~~"ere Was a aues~ion iLlPlediatelp'9;.Ore i i1cRC.g Cco g r'hich X sQppQse We recQrQ "-:yil~. disclose tRe SSP. s".>pplemeni has ar"Cress d ahere Dz o Col".an sd3.8: Ne ~so'QM Nc~t ho~ch Me pr3ri ice 'ho abc ress theLQ selves ~o ~he s "a us of i:he NPC response to me five ongges- 'biens aMP'4 ilave heen 15acLe hp i:he RGB.sozp CcFuB2.'c'e on Reac'Woz SrÃecp ' 'cZlei rece~P le'Item a Tha~ vi1l come mlt laher, X assm.eP EIR. SIXTH: That. mould he in .che sUgp3.emend., ShiCh Kfe vil3. enCe~ into <31e recta. Yir. Chai3aian~ N~e ~WC StaS'f:ziulosses are av@il-able for cross-ezvJAinahicD ~ CHZXiMKR P~XT~Y". Thank you, Nr. Smith. Cross-ezamina~ion, Nr. Ga~ner? Qg~.fLR dies CROSS-EXiMXNATXO27 BY'K, GKMT~R: Sei63.e, vou have a- bachelor of. Science degree
" n r2gricQlc~CQrQ3. scxenc82 k
(K~i ts:ess Seiale) Yes g sir ~ Fred 0:ashingi:on 8"ace University. Red X eton't; see any col~ega training beyond Ma~. Xs "'his.corzectV L That.' cQrzecka Xn othe= iorcis - /on shl36ieQ 'what lee call. 'I
agr-" culturQP 788 ~ Hcnr, two years aftex you gzaduated, you 'joined the General Electric Company.-as a technical graduate and you studied heal~4 physics for six months; is that correct' esp s3.4 ~ Q. And had you had any practical or and it says here that you directed shift activities of six or seven operators in he refueling of iny of the eigh" Hanford reactors ~ Mhen you frere studying agriculture and farming, did you ta3re any nuclear physics courses2 No g six'r any mechanical engineering courseP One oz takeo courses, shop-type courses. Shop-type courses, things that would help you on th x Rrm2 Yes, g 8iz' ' Di.d you have any electrical engineezing ccurses2 .-.Q Lwop&u4 t c' I 'lf~ngmm4 ~a+ ~ iA ' '+44'ng . g, ~;'LQ new ~ .w 404 ~
'es 2 No, sir.
93 Sall righty si; ~
'I l&. i.'oseley: your prepared testimony says you have a Bachelor of cience degree from Georgia Tech and it does
425 barb22 Hot sc~y r8nckt it "s xnP ()fitness 2;ose1ey) The Qearee ." 8 i';g".ustrial 1QP&clgGNGnt aPQ technicz~1 R.- pects Qf 3.'".c"Us i:zi a.'al.lr~agGIPentu Yes. How 't says.". ro11oir3.nq ~a6vatio. from Geo g3.a Tecil g you se~wPQQ Abcut 3 QllQ a BQ12 years i' Ale Uo 8 ~ Davy as a Line Officer. DiQ you i%ave any engineering Cuties' 0>> 1 ~ilQQ never R~~si~aGQ Rs RP engii¹ering oi'- icer
'I GKi Q. ship o AnQ t3!en vou <rent to:cork Zo:" auPont uu at the SBYB.PJlvh BLver P2.cvtlh o
?'Ix'ong you p grRQQateQ trod Auburn in electri ca1
. engineering, and tLen ycu vent tO rior'n the nuci'ear ~weapons.
prcgraa~ BQQ "t seiys that you beg~~ 'Vox'I ing 3 l the Qesign o'uclear contro1 and nonitox'ing sfsterns for the Si1ippincpgort QQQ16Rr' 'elt ~ Dict that invo1ve rBQ3.Rt3.CQ r".Cni toring at Shippingport P (Bigness. Xong) Ves, sir; hoch rauiat9.on anQ h nuc1ear core nmnitoring. The other erweri~~ce was in che iHa<ry 3.n the weapons Pz'ogranw. Nmr, Pw. Huzphy, how 3.os Qi6 you attend Drezel
.. 22 Zn"-ti'cute ok Technology ~
(fitness Nuzphv) receive~+ 41 hours ox gx'P$ 3,uate credit at night. 1~7hat targe oP: reactors eve-a thav vitn Sntemrise2 A
P es'Uz'i .6 UR'r reactors Pressurized:~a'can, for F.st'nghon'e. f iso'sl r you ~rlozir'ec' oz ~~ez+Mn Hemi Gt'C~~ '@ziti:. you vent (:o ~roric fox HRC in '697 X worked for Martin-Marietta. j: also worked for BBcMe3 CGzpore L3.OD s Q pi fez'shU3".g + c ~ i L'IrMM ~DO i Xt. 4'HLs ~'n l os- il-firen plant 8esign X el - o voz1"eQ for the Pectera3. Power Commission in systenm m.alyses. But they Qo not Qiz-ect 3.y relate to my morR. with NRC.
- 9. But yml 8idn't. roric in Qi.e nuclear peve.. pa~a of
~me e" eatxic mori~2'o g '3.Q no't a Zlll right a X guess &is question trculc~ he 'to:"L.. Hosekey. Sec"3,on l, page l, i:
"XL"s mission is to inspect, to determine the 3.icen8868 TGee'c 13.cense %16 regulatovl 'rBQg,re nl nts es ":Ml2. as comnitanents in the - Safety Analysis Pepori".s. "
X mou3.6 l33<e "'o 3'nut the difference between a Z'8g'Di1.GQQn't anQ 6 CQliG92.tXtl&il'tp B, (Bitness Ho'eley) She basic 8ifference between a requirement. and a commi&cont. is .~ca~ a c mal.Ment, mey be chan~eQ hy "che licensee zzihNOU'- prior approval of the Com-
~ ~
KXSS3.C's ~
427 barb24 Do they 1'loti fy you Tvilon they charlge it?
>To'f Q. i Qrehand ~
They 'j u st ciao it Q11Q Xn solne cases af tern'ra@de A3.1 'gh' Over on page 2 g Sect3.on XXXg Ppx'R-5 gz'ap l "Deficienci s in. the NRC fire prevention and protection pzcgram hav been corrected. This 6Acsption is noc demonstx'ative of XE 5 inability to inspect, ur perform its enforcement function." Mly 3.8D t it demons tra ive That is pzesuDLLng it is omething it should have been doing and Qidn't. B. Ãe don't feel that l it is demonstrative because indeed, NRC did not have the xequirerrients, or 'chey had v-~~ fee requirements on che fire p-event'on and fixe pxoteccion
$ 7 CkEXBK~ BZXLLY: Ãr. Gamer, the scateiaent Jou made in that statement about;rhat .they said about not re-83eccing, et cetera, what page see e you referring to?
NR. QABHER: Section 3, page 2~ arabic 2.
$ fXTNHSS Pd3SEXZY: Nay X he~p, H3.. Chaimaan2 Xt
'3 is. arabic 2, the arabic number 3. CMZHl1M BE:LLZ: Thar 4 you. BY MH. GABMR: ZU 3 11 ig?lt: K>> ~ Hose 3.ey ~ '- Qn page 7i paragraph 4
cozL4inUGQ 'G tl page 6g yd'8 Qave a statement
'Kxe O'Deci fic Crees Fevieti'MQ in 38tai 1 ci5
're 867.ected }:rcTl1 close considered to be '@he most important from a nuclear saZe=y standpoint."
Ba~r Qo you go about aete~mining that in advance, what is a nuclear safety prcblawV (l'V.:.tnes Moseley) Ue13.., ~ie determine Lhis on the Basis of the 5%ipoztance 08 'Ne pMiticulaz piece 'of its 8QKLpmen'roceclvx8 g or ac'won Bnl x'e7.ationsM.p co saf 8 operation o the p7.ant a R.ll right. i2 Over on page 7.1, Section 12 at the bottcm of the page g vou ski Q ~
"The ZZ en-orcement prdg=am is not intended i".0 he punit'e in natux'8~
Hov, I understand you don'" -;wane. to just go out and punish som&ody o he punishing somebody. But here today
'l'ae heaz' grMt Qea~ about the a neory OP. punishment for crit'eing baclc, in vogue.
20 And Qo you not get better results L you are I mean, you are a inspector, and ti.ey are the Licensee. .Do 22 you have to get tonga sometimes on them2 23 Yes, s$ ,x. 8e do take enforqem'nt actions and ve 7.es~ sam penaatias that cen be orders. Nhat.see are saying 2r. ~~.ere's ti.at the object. of our enxo'cement program is to get
barh26 Q3.XBC'CLVC, c Cc-XOQo AQQ 4~@~ QXl.'. f SiiG. + c~B iHGC2':iOFC8 2..i "CGZ1liS
- 0) QZ 4
t~C i~ ZO3:C9~7sGrP 2S " 8 ZG~Q2.Ã6 J "0 gQ i YaV't. QM' QCC ~ V8 AC (.LOP>> ~ T'pg
]13 15
'l7, "Q
2f 23 Arl ai Oj
430 bl' Begin 5 3 ll: 3.ght'( Sir
"."lR. Ski:f: X'on't kr~w e~uite who to c'.iree this mxestio to P r .aps the HBC 8'ca&2 should an s;"er
~~
Zt isa'a cl~ar to me ehe+&er HRC "las 3.n the past fXQGQ an organization ti at neglects to confro:an co ir's regu-la t3.ons e 'o:s Qoe one Peaera agency go ~>out treating a q=.cation li!ce that with vnother PGQGral agen y'?:tould BRC under any circumstances tacitness -inc TVZ;7 perhaps the can answer tha c ~ 10 Zes, sir, let m attempt co. I TVA is treater% in very respect jusc like
. any other licens.e by P>RC.
KR. SHOM: Thaw". you. I guess Mat puts it 43 Muntly. ~ MB. 'OURTELLO~~'ZH: Thac 8 Got to sav < hac. in the even'c ve sbouM see 2i"c to levy i(ines Mat TVA. may not Cafes M3.til sovereign immunity ) +which is a llatter, as I zar "ys I 3mov )
; that jiasn't been litigated yet, in the courts.
't ~ But) as illgicateQ hy 2/L ~ 'iMose ey .s r" sponse( per sou day i'ight come to that. Pte certa'nly hope not.
CKAX<BZg EZl3'Xy. 9'jlank vs,. guess ( c Ken) QGZUQ n 'c l Gnslfer o 43.tness QRO counsel , there has ne':er Lc.en the ~i1BC oz KC, its predeoesso age icy) has QGU'Qr zi ?Gc. a sister Rgeilc~l ) SL(3ll ~ 4TQ Ba)) ( l3.ke Og
4'R TOURT&.4X:OTHE" Pot tc 1py kncvrle8ge J. kQQ r oZ
'no oth r, Federal ajenct>- xrhich has .upose8 en'"-orcament ac-:ivi-ties n the Trav QJ a Kine on another Pete al agency o B, mav have taken place, hut to my Rno-'rleQge i hasn ~c CEAZKP2~ H>> irLL<: TharQc you.
MR. PGK: f~r.. Kw. Chai=man, in are instance the Atomic Pne=gy Co~mission Qi6 p"..opose a c'vil penalty against AS it happened it Vras p ultimate'ly vic'Eel:,alton g')ui the
<0 K~iC 8" Q in <act propose to fine TVA 8'i one ' ~see C&XZRP&~l BEXX,T Z: (Cell, now that you"ve b'.ought it up, die1F13. c.eZend on the'gzouncEs that it haQ sovex'eign irzr~unityP
&iud. PG~$ 8i7: RIo, ve Qic" not. THe QeferQed or the xactual basis <or the in2'zaction.~ ~
CPLURWig r~~XoLY: Thanou ~
ÃR. CZZ~I~i"R:, ~
o put that in coat ~t, th re sras a time when the gencp'.Qil'not ~
- Qo envix'onmental impact state-ments on "VA as they Qi<'..on privately o>rneQ organizations.
~ %OUR'EZi0~: M~ aC Goesn'C: have anything to with the conte ~t oP. that guesm.onpad, J'o
".".i~c.. answer.
- 22. hexe :ras a period o~'time when "."e vozkei unCer what +as I~no<ra as .Lhe 2.cad aoercy concept, and TVL did make I
2jJ envizonnental statements, or perhaps t~vo, which we simply x'e-vie'z.ed and subsequent to an agreement bet"careen the agencies
'332 and Ou."sx writ to i=he CEQ guidelines i ha t ~<'2as the aQjcs%3C'r 7 ,>le SQve 8 Qr,a GhallQoned s the agre&ant ~rHt TVA Uould .Qe lecid Qg essay +or x ucu". 8 plan'c s CLB.XHL~JSaM RE3:XZg Y: Ai z~gh~ ~
But Yx~ Garner s coMtevt Goes go "Qvo the GODlGUhat unusual prohlex;s of equi-;ting a sister ager.cy. CsCMP X understanc'. in the Bar." sville pzo-ceGQ3.rig:.ighrt 'DoT'7 they ze 1" tiga" 3.rig v/he+her HRC c~~ go illto i:he reed ."".or purer question where Pv2. is concerned. C~~ZPrMXq MZT 7: ~ P" ale gent3.emev. Thats you.
~ret's get back to cross-ezaeina'cion.
BY HR GP>ÃHP: On page 16 s. be3.ieve this Mould I he R.. l~su~hy the last pa"agraph, you talR, about how the "as constn~cted" location n~acle detection ox leaI:s moz'Qi-"83.cult. (N3:LQSQS Mul."PQV) MI".RQ 9 COZc.eCt g Sir ~ 5l ~forlGerii?g if you '+Quid e'cpl63 n 'N.iy ii RQQG 3 t
?7LQi.e 6i xicultg
~
and czplRing 3.f you vfill g ~Why t lis vas xlot caught hy Qe XZ "953)ec Pi~in o I'l aasr~e- your last auest3.on first. The con-st:action anomaly was not detected hy the HRC inspectors in ?1 t:".at De NM inspection program 69a, not include the inspec-
" ion of these penetrations.
The rusher '=o yom>> 8izst @tie tion, as ~o why it made the detectio. o- the leaks mx'e difficult aaQ contributed 20
bl+ 4 2 vp ghe d2.fz2cu~t~J o~ ilute -'n"~ -"al "-2<e z<.gal i. ng g vcu < WTou3AR Lieve to visiialise i ne cons'ucc3.0 L of 'me DGn 'a a. ibn K>Q i'vail R)84?8 -n >i3<8 cable 80 rea6ing K'pop~
~ r ~C OZ Oui 18 nP is SL2.gllU, . Qn~&' Zoot 'vhi'~k o Tne 0>> 2ginal 08 ign Ozavivg kac1 a st891 . bulkhead sho'bn at i Q8 BL9.6'Nay poi Dc.
of 'this open'ng:n 'c218 wall, halfway ha~creen the cabLe spzea6-ing zoom and the reacto-r building. 'his zrould have put the
. Openings that @8=8 heing,seale8 apprp2'9xa. ely lO inches hack into &8 vail )oy 8318 T1ay of 528 coQs'r&uction oC C+a.e QeneG~a Cion g vskicn 2.8 only a Gnox'C a Fi s zeac 1~
The loca. cion as constzucte<2 tras bact: >>othm l0 incQes ance .QQQX'ef Qze rectIi Gd a consi8ez'at'le Peach in Mc28z 23 to qiCher detect a'psci2ic paint or air~low or air leakage anQ also to Give 2 ngu2.01 NSE>> PQZ'Hl~x co21p 'QQQing 'canis Wjas, the zach CMt tn8 pl%jsica3. a rang&iten'l of the QK'a j >7RQ sQ K&at 'L218I".G >ras oni.y about, 5 inches of'3.8a= sbace b~N~a~'>x c.~18 tray an8.M8
'clay above 2.c. g i",erich vcr~ 1 a3.so" not only leal. Cb c".ifZicnlty js "n x'Sac 1ing but Qi ficu3.ty "n ohsex"s~ing e All z5.o'h< .
Ho~r, as Z unQerstand it, Che 3:=" insp chion oxogram Goes not,inclul"8 an ezamination of adeauacy of plant Cesign.
~
That.'s "n RR. What. States a-e m ~~$ .oa 2 ~J>48s i~1labmmV gV Region 2 inc3vctes Cne states east. ox'he mu l
<%)isa j sc j p'~ j amp:> t inc3 Ques Virginia g I'Test +-'rg~n-"a i those south of j hose sta'g es p puerto pico an@ t' Cana3 Hone "I Ncev con ~
t h~ve azar gn the Canal Zone p Qo they'P J2 Z.'etua13.y, tnere is one 'n the Ca=a'ona. X'- 's a x.loating barge type reacto>> ~ Do you InI of any nuclear pox'zer plant in Region Q ~ in an>J other region for that matter < 7]here the operator also functions RG an Grch2.tect eng3.net'LQC Sees their ovid constructionP D~~ e'Rom r Company has a situation very simi3.ar to TUA's. They do very much oz their architect-engineering srcri-. 12 They have their om. construction forces, their o~m. design i3 forces. They ao re2y on th nuclear yst m supplier to Supply 15 Th y 8on't go out anQ get someone li1".e Bechtel'P E7o, the: Qo not. They and PTA are the only ones that you, know fUnction o2'hat tha c Kvay? Th t's corre"t. 20 Kow, ove on. page 19. section 12 of the prepared 2'I testimony, paragraph 12,.you make a statement that the insh~llation of the plates ~ias a construction anomaly that causeQ'a slight delay in Z rel ase of the CO> in.-the cable spreaaing racm but that ti ~ effect on the fire an6 on plant ope ation Kfas ins AjQi ice nt~
TA?c4 C S "(ReC3 'Q3 ~N aft '11e aot .) tnac I C WRS 3 n>> 8'n3.f icalYc '.:, coulrJ. have 'Seen Qionikicax} p coul@8 t 3.'i p
+ <<cf mica v3.$ QBlxÃie tllat ic li!igITt PK<JG hoeIl LilL'e l asM Mz. Calhaai while ago, suppose a man 2KRQ, LlRGQ a'eely
~
put out the fire o Ne coull say it vas an insignificant eve'1ti Bll righ'c, IW. Long, on page 20, ron~an z>feral ZV, you state'Xn the Xnvestigation Report of ti1e.Browns Perry "ire, c rtain.de iciencies in management ac~.-. miriscrat~ve cert ol systems for control o safe~y zela e6 acti@ tie vere identified 53 j'ann t tI1ese I3een ident> fi@+ earlierp B. {Witness Long } TI16 Lest reason t pez~wps t par'cXLCQ3.a ly those zelatei to fires: was the ahsence of stat 'ments in our inspec ion program to cover these particular areas. The general elements of these deficiencies are generally related'o the quality assurance program aspects tI1at vere picked up later and vera not adeauatel'y inspectel 20 or thorough'.y inspected Curing this period prior to the fire. All right. 22 X'm going to cue hack to 21'. Ru=phy. BmcL I will ask you> K< K>rplxy in Ãa h of l974, QiLt you drafc an internal mmorandam to Pr. Z. 6. Davis at AEC Ra8quarters 22 oxl tpe clevelopYRen'x gui fZGlines for the iQs eel 3 ation of
les anp ca+le sngpo ~
- 1. ~~it~ gpm~p (iqitn~'ss 2i'QZ'Phag) X ~3.44 NG r %~hat fRiQ voc k
~i>vQ to snyp DQG 'a" lv'~ CLOUT in3.ti el calg t 8 ins'~llaticl pLQS 1&1$ 8'(; Bzcdns Pezzv an - othe-"':
sP rexoxeneec 3ro~rns 5'erxy azz'. several other plants I1B " Biw~'QozaKKGUQ 798 czar/QL" B"'RYQoraLMUB baBLcally ~8Rs seM3.Qg tke escablisl<DQexit 0
~
VGA.6ance recv" L8iRents
~
fQz'he QualLT
~ ~
j~ of icosi:allatior s, to" Qe iq8~ them sucn th- h ~hey rrcn 4 he cmrcon to all licensee.". ad% '~hat the 3.nspectors con. 6 oe:mL)"-
"ng to 'c he Me guiQGnce zecgxiz@~enl s C~Bt he 1 licensee Yras cozeitt88 to Qr vas zo~ireQ co con+on@ o As to Bro~rns Pez3:y spacifical3.y, are ha<"'dentifieQ .'ri2 ha8 Qb"aine'eso3.u'cion of some areas where cable mega>>
xati Qns v3. @hi P panels >RQ Rot r388n to 'Nnc t ve QPQGrstoc4 sGpRLatiGns czitez:ia %ex'8 ~
~
9 ZaQ K>at @as hezoze tice fizaP
. That vas before the f~~e, yes This is a contivring and ha, hen a. continuing eHort-,- tU~.Gjhone conve="sations ax.6 sou+ correspondence idiom heady":azters A, regv.latory prickle is in draft form and is PzcsBnt&J on Py Qe& foL EQy cQERlents I
2'hat's two yeaL-s -- we3.1, longer than two years aHg+L you 6 QZt86
437 n Rctuallyg d. =2zvG ha<2 thosG'~~rlf'c s on ~ly Desk, for seve al KQiPQs because ~;7ani 8Q '=f ~~[. rovie?78{2 by 'c.hose ec 3- . nica" specialists U1 er Ky supervision l heir sUQervisors c g g an8 Kyselz to 'Na: e sQze tzlat 'L'78 h- 6 achieved th8?7 3i 4 K[e 'a7ere see;ling in Kris ax'ea i Q Pill "ght NO~7, .as you kno~7, K-. Murphy, there:7as a Pire on yea .ch ~.0. You c'-ai e involvecL;7ith ~he HPC's investigation of [.hat fire4,Ienc". in';.visJGD ~CA of:ic"als g Hho Gppa. entlv zai186 to appreciate che significance of that earlier. fixe, especial1y on March 20
'ot; Q-c~, they react when you interviewed th~ about Me March .20. Eire'P i~8. 82X""8: &U~. Chairman, X'obzect. X Con.t ...
tb68 this line of auestion'.ng is relevant to the Staff's ~~esti-mony on the contention. CKKXPJB2l HEXLXY: Objection overzu3.eQ.
'[
~,4 "fXTLLL'S NVBPB '.3i11 you plea~a zes<ate'he qaes-tion, Nr. Garner'P PR. QABHH1%: ll might.
BY 2& QKRHHR:
'Zou heacLeR the MlC 9.nvestigation into the Bzawas Perry size for the XE.
(Blindness K~> phy3 'Zhat's correct.
%Aced 70u inde'ic~+7eQ, TVA of:icials, who appax'ently
xa."; 'c.'o apprec2.ate e4 e '8" gnzf 3.cance oz '. 2 arcn 20:3.re 2.vtervie'iveQ TVR, offic3.alsg yes ~
- 0. if j'okl G2.~~q ho'A'if3. they react > o xilissing the'significance of that JIarch 20 fire? ZhQC v B~ t.h CQa J.>
zire, before tho c nile igniteQ &e polycra~.dna. The people that ma ~iterviet>eO "lo statea that they >'i vere a.rare of the fi'c)i6 noi a tach -part icolar sigmficanc co it/ because it r.as not in an area that they felt coaM cavse a saze y problem. Th fire va recor¹cf in X Jmlieve the 'shift snpex-visor's log and +as cH.scussed aC a staff meeting. g, All right. r, CHM BI%'3 B3XMZ BzcQse Ee G,)r inter/Bc cixlg here
Ãz' HQrphy @ i<G:8 p'011 'QMe co cls Ger ca3.zl that Che<J ~
3cnen the location of &et March 20 fireP BXKKGB M~JRPHZ:. Th re ve e individuals that lcnev
'he location oz the fir that >re iatezviewedt yes, sir.
MR. SHOR: Ãa've discussed, this now several times
'n several different >rays. Zn t share was that fire, and what material was hnrnin9P i'7as there a hara-8 to the safety equip-KentP v7XHKSG F~UR~EZ:
'I The fire vms in the smne cable spreading zoo~a. Xt rs s baak from Bm penetrations themselves.
There .rMS Qo '(19.n6 fanning. XC Res Qither CeSris 0Ã poly-azethane ~chat was ezposecL. C~
a39 bit lO MR Gi'.OH 8 t7> it Ilies ne'c polyure cs? Bne HiBt 'NG 9 z,s88 to stus"..f .i:s..e <"-118tr~~"-.ion vith or any'.ng lit;8 that'P XT~&i.,rg KUR>7HZ Xt 7Qs pro BMy he 5-G 'h 'cype
-'3 that had been removed,. NC 12.6 not spec9.Zically i68Etlz)
~%
y4
- s Being at tachGQ to anything iiR. GHQH: Bzl8 the sourcG of ignitioil MRS 11ot a f1M'8 QS88 Qs a "eak I ~~t~i"P is '&at corr~ct?
ETZT~T"SB i<OZh~BZ. "X believe that it was. X believe a canP18 was the source, hilt it i~as not close to. he pene-s0 txation " cself e HR. SHCN: X see. Phaak you.. 8"~ KR Q~'fBR: s3 Over on page 29, &. Murphy, of the prepared testi-
~
. 14
~wisy p yo11 say in the first 8 months zo3.lofti ng tea "'8 you in-,.pectad ok th8 site 2 to 3 days every feei . Then you re-35 c~ucei ii to 2 .co 3 c".Bys every other wee'Jc, and then began in May 1976 the 8""zort vzas increasei to provide covexage every X~eek..
CO1116 you t811 me if there was B reason for in-creasing the coverage in ~Lay oz 193'67 itness JLf~iphy) s he inspection applieQ corr. SponLc1. to the roric in progress, anD ~ie vsere striving to i?lspec< the installs ions as 8'ep 'Here beiYLg ' BG L.he WOE v.'as being p~~~f ozIAecL~ Kv>Q au~ing the short periapt o time @hen late ha6
iCDO the reduce" 3.nspeci3.on ef zozt g tLG constz'.ct3.0n Qfxozis vere either QupliccLiive of 'J~ai vfhich 'we llcvi inspec i ed oz v'78ze less ll right+ Over on'age 30; they see> to be having a lot o
-- Z believe that is in >w. ?~oseley's testimony. 'roblems (Pi+~esp bioseley) Xt is in:ay testimony.
X'2.l he g" ~Q t ~et I . 'lloseley aa,."-.~'ez "'le gv. st. on. Nr. I)ose2.ey ca2.led '"='e. t"illela138 an 81>y 2, l975, and KVB agreed Co halt th = siozacion activi;ies.pending cora-pletion of Eodif cc~ti oils to ~ale TVZi Q3gQC p:. cg'-'+BED 7.'m svonc~ering, 1<as this the nozT3al pzi cedure, Ha.
.'~oseley 2 Did you call i.~".e assistant manager on snot waiters nornally, oz r-;ou2.a you have dealt with the pars'on in charge
- i4, of 'econstzuction, oz someone at the p2ant2 3t's no'c abnomml, &ir. Garner. X zea2.lv don'
$ 6 REGS 21Qd.to respond to your Quesiiono l7. feel free to go to:whatever level 7 fee3. " need
'o in oraer io Biscuits a particular problem I have ai hand.
Zo to a fairly high P. 11, lovel2'i AAQ yolk "el' it zasn't
&is case it. was necessary to go necessa ~ to go to Kr. Gilleland t3 causa 't'as that big a pro231 a. Xt ~ras because of the PGecl for speed~
'Iles, sir. X appreciate the speeding o" thai.
R2.2. z" ghtg 4'~~ Long g ovei; QD page 35 g paragraph 16>>
Alt 32 2'he 2rs'entence says 0, '3, decision @as 'at. =- made -'o u;"lca.". H.e ."" 81 I fry both reactors." 3.'d like <to izolr wnv apparently there -:~as an earlier decision made Qot to unload it and it was.changed. (~8~tness Long) < thinlc there vas sort of a join-'grees>ent ant". Concern raga'<<Qi ng the cczip3.icat ions of 'the enozHious amount Of Ivozl~ 3.Q'rogress ~ AQQ g obv3.ous" y g vlxch th 'fue3. in there the plant would be: "or all pzactical pux-posesg an operating plant@ requiring the QQZHlal BQlcunt of f A of the core and all of th backup safety systems l3'onitoring I 32 as ix thQ plant v-x'8 2.Q operat3.on I Rid it eras concluded that the most practical ap-
'p oach to getting the largest c<3<lount of reconstruction Pork done i<lould Le to re'Dove,the fuel I'(;at ~4-ld be the Dos t aQsolutel" sa fP cond .on Q. ~Pno prepared U3, MRC S"af response to,the Board's 18 question2 "la that you,'m. Hosel J... ~ yI sir.
~
'9 (7/iCQ ..s Moseley) Yes, "I
g. Xn here you tell over the years ho+ you spent ",.
"'.co~sMezable effort in attempting to .develop a mechanism to 22 05$ 8ctive2.y rate 13.censee performance RPL8 they ve all'roved 23 unsuccess fQl a
~ I 2 <<8 Do you oxt of get a feel ".:.hen'ome~,':,'."'I~g .is I:ong2 25 QTe 1, ouz "oasis foz comparisori is ~s-.. Ompaze each
bltl3 licGQ G Rga" n - t A3.s l censG rGQUirQEl'nts rata r tnan cQIQ-Par'et%~en Q" 13 ~" 88 0: e QGVPSGGn zac".l;C~~~'& ~ Di Q yoU z'GP2.acG 5~x Davi s as >lG8~2 Q RGg." on -'XP eve Gh QiQ this happGnt APProii339atG3.y 3.973 p I Leliev"s.i Q. Do yoU 3'er.=-U.',a zeavranomo that 24=. P. l.. So-'rer.. haG Rac~Q tLG 3.nsQGctioj1 of ~egion T3 %>~Pp't1GR~)@parte>s 1 969 anQ GiigKGssGQ concern ovQ co1gil=3.ons not satisxactor cpzitG a v>8G spread of xlQclGRr plant elec'crical j'ollnQ, cab"G installations?
~GS p si ~
p X TB f~liliar viYQ tlxat~
~ '"Z hali vG after you cate Qovn to Region ZX you l3, "npportei Hr. Bo:nr's posi ion.
~
ZGSp Sir. 3,5 Could yon tall us R lit'c3.G about that,, plGRSG? Zt, was a m~moranjm'ha? T. think 's in table sam. 17 ccLtegoM1 'as t11G onG t lcht &Ma blQrphy wP h otG in l974 ~ Xt %as I E
~n lo a realest by an .nsp.cto for development. of s'ndards RnQ acc.ptanca crii..eria to be usG8 in "'he inspection G'ffort.
~
right.' 'll Do*you recall being intarv3G>red hy 'chG Union of
'. Cancarn=Q Scientists ahab 'chG Brogans PGxzy firG episeZG?
MP..'=S~I=XH: X object. on MG grovnQS that an;. 23 iatezvic~i~ tsoulda t be zG3.evan to this proceed,in'. CHZlXAI~N RBZ+~LY: ." don'-c. 3zotr yet. The objection Og ee
DD~ i G. Qvcr3Y'el g $ Uk)g Qct Ko c~ .- oUD8 a~ion Isaac F 0:Ll VQU GZC<QN9 " 0 l I ~~i% i yOD chere PBV3 1g c~ ge-hi:ing UA to
*'roblem accep~ guali-y con'--.O3.P
{Witness Koseley) Z don'h recall m 't".ing such a saba"emend to l:h~al. Oil voc..l cU.scues ~VX @cali'cp conhrolP
"~P. SNXTH: Hr. Chairman, X abject. to ibis 3.il e of Ques'c3.oP"~g : ion'5 belie-"e it.'s relevanc. T¹ "n?
veer lMG noc shoVIP lxoff it is relevant, 40 l his pzoceeQ" Qg He hasn'4 ..il ntifiel when che 9.n'-ernie-'r too1>> P3.RC8 o Hc'ash 'i spic" N&o 59 c.al1cel Co I 7'Snab c MG pe'"ol r
'h'c"z i rel les to this "estwony or his stipulatel con- I'nl Centiol( xn 'vh3.ch &Jxo'anner sc~3.8 Qe ccQs g03.ng to rely QQ toscimony ana in""p= -'-.'.on =eports, ~~ le s he says the Union 4
of Concernel Scientists "'s -~ark'irg for HRC. l
, CMZR1~~4$ PZXXXY X don'0, fo3.low that objection.
Zt's q" brome izitgre tqto th3.s Bow~l to see 3.fTVA hRQ BQ48 l" ffi QX:Q'r. <regs'tive ~ ~ 8.'bcp iCOD
~ ~
CowlBrcRS cplcR13.5y ~ control ~
'Z think it. shou16 he ~~ lorel.
I 'c I The q 09)ectioxl is~ ove.zQ3.66+ J'Z
>iR. QMMER:
ey>>qgoj e yoll Qs sB+3.ng ~his 3.$ in, QQocation Liar+8 a I rec.3.i"=e the hast. of repor"ers are not right scme-, t-"-O'QS QXK. CUtrn in'.'rGC'C QUO'c eS '.QPO BirGCc g'UOCGQ g blXt. 'I Bt
sure you rem~~her "he interview with then>. NR. SMITH: P~. Chai+a=n, could a'-e !caow where the Xntervenor is reading from? CHAIR!U'.7 Rt;X3~LX: ~lr. Garner, could you he more ,~cpecific? GiQNER' ER zeadincJ xro16 page 11 of a pRTBphlet ezltit3ed Brolly s Ferry The RegQ1atozy Pai1uze CEGGS>PZKM REXLL2': Who published that doc@ment? HP.. GRAPHER: The Union of.Concerne8., Scienti ts of Cemxidge, Nassachus tts. CSiXXBKQf BEXLT~Y: Do you.have a page number on that? MR. GBR'KR: Res, sir, page 11. HR.<< TOURTELLOTTH: The copy that we'have is un-nurahered. CBAXBlKH RHIX,L~i: Maybe the eleventh page. EGL TOURTHMOTTZ-
* ~
Do&8 ~R bering start at the pref'ace?'.. 51R. GAHNER: .Ne11, let's see. Xt's Under Section Ho., Zim, 3.0, "Qh, D'efic encies 3"=loved hy ABC." lI HR; VOURTZLLOTTE: X have
'I the page nose.
MB ~ Q~3%ER: 026y DP g'QQ Qg~~s.jL'R
'Hozman Noseley, a sixperior in Region XX HBC Peadquazter -
Inspection, in a separate interview]
aBer t¹ f":re said, "@LAIC, cuit'andidly,. i'ryil1g to zeal quali "y control acorn ~F7s throac,: lEK~~ "ng i'" Ul Fi".uch r883.stance Die~ you say thatP {M2.tDess s."toseley) HOs Sir@ X believe X >1QS CO1Q-g ev lv E2.Sunder'jooQ " '1 h t 3. 1'aM"J3.e F~ Re'ii( Giscu s the changing character o" TV>'s quality assurance pxogram. ae a2.'scussed th3.s in i:Gw~s that Mis +as not uniaue to TV&, that other utilities vere in a learning curve si;huation as far as application of QR/QC as ve had defined it. in Appendix B. That s not to say Chat 'Ga " l ties L~1clUQing TVJig s
~
die, noc snort about quality control prior to A@pens~~~ B-being pron'ulgated. The poinc X'm trying to m1:e is that .chis was a c".if-"erenow conce'ot o he @@alii y program~ And. you'e had a problem w9.th m~ice a few companies in interpreting this.
<<7e have problems writh u~~l3.ties zoom time to time; y88g sire
. Long, >reze you 3.ntervieved. by the Union oZ f~
Conc rned SCientists7 sK (t'ai EGGS 'ong) PGS g S3.r. s CPB~XPJDH BZXLT.Y: K-. Carner, apparently you'e going co go 'nto the sa line vH.th this wiitness. X notice C4 i+'s a couple oP. minutes.. before l o'lock. X". llligM. be an
446 I I l I ppD~'cc+F~ av8 'c~>>> 'cG QKGaN 6 1.Rial ~S ~DZC~Qa -"L ~M Gl2 86-"6 O~ Q~ ~joU3." 1 'l8 ~ 7sm~iC Paar b9 al3. x'igb'=- Q c3 L JXi. GM~3ilR: Su=a. CBA~R~GQ/ PZ".L~~: Los.'s h:~oak foz ~unch and he back ar. 2:3.5. ('L'HLGFOQQOQ g al'.2 458 p aL".~ g
'ihQ J~~GRZ'3.Hg 3.P ah@
4 I a<< ave'equi"tract marcel was r cesgeg., lg .=.eaonvo-..e a':: pl~d 2 ~ 15 p o B1 c1ll.s san~'RQ } i) Ice. > t6 i t7 >
Hi ~
ALE r i ght g 83.z'e Gve on'age 71 g azlQ this'.8 a genera3. gczQstion 'th8 ITIK QseQ to 'Qse a phrase Safety r83.Q.'KGB characteristics" aa8 +hen X sam the "abno~~~l occarrences" aDQ llGKf tLGy CQXX Gh&ha ~ iceQ$ 88 OHSMG An6 HRC seams to have aQopte8 the positi.on Cha any abnonm1 occurrence cou28 he a safety =83ateQ occmrezLce. HssQDG>> a13.yg 9.G cQQ3.8 havG hol l connotai 3.oQs g Qo yoQ agree v'L'ch MatP Hot, S'IL a tx'est ictive GQ?lse TRt a the FRC sxaS =eOrgani.@86 Part Of Ma x'80ÃgRQ3.xa'c9.QB 2.Qvo3vQC cd"Da93x coElRi&lents to Congress %8?Gx'eb's CQ, 4 cfQQrs Qz"y'3B828 MB vQQ3Q 3.8gort csrtaJQ safPty rBlateQ cccmances, and W "safety ze3.ateP it was those types of occu""~maes that cooLQ ~pact, on hhe hea3.M an6 safety of the pcs 3.9e, arQ he ei her a thzea'- to the hea3.m axle sassy oP. the pub3.ic or ha8 a @os.entia3; For heing a the~~- ~ to the hea'Lth an8 safe~ of the'AM>a. Certainly Weae have been ver fee in nmiher. Th. Se sex- Zahe3.sQ "vapozMXe occarrencas" X beg yoax pRFctolh 'bxLoa~iM3. QccDzx'Qncss ~ M.3. Other events Mat a-8 of interest Co the CQiQB." ss" o~s for pQK'pQ880 cP trent QZLa3ys9.9 ~~cL so oQg axG
refer a 'o as "ranozhaMe oacurzenc s"-. cerha9nlj, if th~~~e is an ~nstv~~a~ driZ> I I probe.can. On an inst,,-maanQ, in my judgwenc, Dais does not 'havG t an '1XiRC.Qia49 tZLrGPC 40 &8 hea2:Hl c496 BafGCy Of. thG Pubic X dxazofozs eel Dac 6~is Qistinction cerMinlp is proper ~ Bah couM you say .cais generally: iZ yoa have an accunvzlahian of small problems, t2mt a license caused. ai~~hez willfullyor some other vayt vouldn'0 you say Dai i8
/
is a sign of something'P VGS g siX'a
Ã8 ax'G contxILUal ly'n 'tQEQ 83.sr'oic this o 249.8 is 419 tx'enQ anal5$ 8is Glib. Z aLLL talÃixbag about e X2 '58 888 ev98enca of,instant. ~~ifc problems, for hample, thah involve Vxa same inszxusnsnC over an8 over again are cexihainly are going co call his o MG cL'Mention of MB licenseeg BRQ a c assuage ourselves it~t, appropx9.aha'O3.1ov-up action is Oaten.
0 Hell; I vras Chin"mg more about, this tidng noh'ong ago +hexa they haQ, th~ eporteG one H.re, Cha inspQOCor %as the~@ anQ Qley c~i scovarsC QnG Zxz'0 Gnl Men yoLL checkeQ anQ in something liRe 20 oui of 30 instances out of a Kiva=ir~ per'io6, Mey h 4 haB th'e fixe vahchman Going valGiag they mrna all-'~ll 5:iÃ68 SORshcGy s pas ce paper has1%65 g Con a". ~&686 genial 23TQ9.caCions QiscQx'5 youP-P3.FGt of a3.3. t ~ C5~c +Le ~Scorch ShoQM poxzi~ ou~.
450 here roe-e not 20 fires>> The niobe "20", i believe .you are referring Dere to those particu1ar ca Ies '~pere implementation Q fa cLiMS.Qg p~aQit %was iUae (Recision 0 f 1 >e foreman to not require a f2re match, >Mch if certain criteria are mat, he ~des Got rGQQirGQ to R% present>> Ho@, with regard to the e9.got fizes, ye', sir", this is of concern to Us. There vere some 3,300 cutting permits issued since the fire in Y~arch, 1975; some eight fires seri ca>>eQ to om at ention, that yr beche ax<are of. On fo3.lorn-up of T these fires iC baa noteQ t'mt in a3most a3.1 cases they Sere tzivia1 in natu-e. Q -, , Peopie that pZay viCh matches sometimes start JQig fires~ 8on t UxeyP EBS g $ 9.p.>> Xn A1abama w. have what me ca3.1 the point system and you can 1ose yoa= iriver's license in A3.abinu if the ZaQgo 6 ches Co Qo it or it's Gone aatolatica11y on an ac~mu3.ation of mm3.1 violations, hacau e it's a sign of scmeWings you get so many points AX that's it. ycvQ bQy that theow+ on xQcMents 'POQ3.IX at ZLzLc1ear po~ivcr pXcztt82 Tss>> sir>> Z aovM 19Re to make one convent, if Z my, to Huis partieu1ar subject of Me eight fires'
CPZzXBi~'LM I~ZXZY: 60 ahead 7'7XxxxMS SEZDZZ:. Thai:, in fact, fire vzatches m son~a cases [rare present vh~~~ the fires started," and, 'of course, that 9.s, the reason +or having he xi~ watch= You iamiediate3y
~t2.ngu2.sh tne .faxe o 8o Z th~~ 'hat What should be- so noted.
EE MR, MBIF~R: 21r. Long, f1 . TouWe2.1otte they cpxote you, Mr. Xong, as saying ~~5 the TVA's plant superintenc>ent at-Protons Perry was not QA-oriented. Bid you say that oz GGKGthing sxIKLlarP (Mr.'Long.) 2: WQDc Z said something simi~> z.. a to that X don't honestly remmnhex the specific x"ops.. But X do remember the subject. FTe ~hiero tarring about Nould you e3.ahozate on what you meant hy thatV Yes, X c;auld liam to. By our def9.n9.tion, by tais time this. vouch ha -about a year amR a ha2.2 ago, in Chat, general timefzame vere vorhing very hnrd across the hoard X am ta33cing
'i~
about all o2 our licensees at operating plants to develop a'orv acute cvd~~eness 08 the IlLLsskon 8 8Ãpectations in the nanagment system for cruality assurance progr~s.' do rBKKlLoer Gzp3.axning our philGsophy son>e detail io the gent2.em~~ on th telephone, and ve did
QxscQBs th9.8 ~ Hie HHC ph" losopkv onxte. GF~tenskve Lp 85dv i. QPL programs g az?Q ~'did TlTe Gva" liatQQ 9.tL82.vMURX 22.censee X 89.Q not "n any Nay~ Qs Z i.Ccats.3.4 say Qnyth>> ng that m'ght he constm~e8 as saying Bmt TV'as not parZoxu'ag or that i.t O'Q not have contxo~'eB systems.
Ãe haQ vzith9n our orgcd.sat an an interpretation or cte89nitions o what a QA-orient'~stem vouM he; an@ X thin3: Cbrit almost across the '-.boa@8, the xulk acceptance o2 the MRC's vers~on ox the Qh progzats was stil3. pe.te cteve1op-mental, anQ <n sort oZ a development stage.
TV& %as corcB9.n3. j no 69.Hex'Gnt fx'ozl anyone e3.se. X believe Z probabiy couXa have made oz vonlQ have IBatRB the same g 89XL~ 3.ar g statement abolxt cQ.3. OG OUR" 2.9.censees "at that po9.nt in time. MR. C~RR: I helieve that's a2.L X have For yon gentlemen. CKtXBMAM REX: Shank you, Ãr. Garner.
%Vs?
EiR. POMMEL>: Me can cM'1 our wr3.tnesses hacL, Re. Chal&~> and respond to the question on abnozma1 22 dccnxzences o CHL~ZKGYi'I BSVMZ0 DQ yon Rave Qnv cxosGp'zam~nat9.on oP. me 1TRC2 AR. PGNBT.L: H::erne me. Ho, Z Ron't have any
"53 cross BXMLLBacion 8m'?
II+ CEiXZPZNSV REXXLV: iMy redirect, E~. KR. SENEX"~%: Mo redirect, szz. (T- e Boa- 8 conferring.) CHAXRMN RGZLM". Hz. Shon has some cpxestions. SORBP HZÃ8X77RTXI3 FYZ MR. SBGi~7. Z hs2.ieve ~M. S idle dM the analysis at the end of Lhe testimony of She events tbzt occurzed2 (EW. Seidle). Yes, siz. 0 PZso in response to EC". Caner's cpmstions you di cmse8 analysis of the sozt of data; and the cpxestion is first of all, hog's Qo you neigh. the seziousness of whether to consider a mmabez of abnormal occurrences 's unusua12 One of %V@'s witnesses said there vere different degrees'f seziousnessg ho'a cd you >wight ~6s aM evaluate i t2 Do you cepaza "e these into v~ious categozies2 A11 reportable accuses are eportel in Qccozctance tlith technical specificationse Someg obviouslyg aze nore important than others.. Ne taE".e a ver conservative approach. Oaz threshold is ve~ low with regard. to the rep titious nature of the reportable occurrences. Xf me see txorids that are negative in natv~e, eve call those to the ~aviate attention
oZ the l"c nsee anQ other c3tili ies usually through meetings with atili y "epresentativea >>- at a level ox management ~share policy can he iaaf an8 trends iu'aQ aro1>>Q c7GSt'o Single Ou'c a 83Pgleg reportage occ~~- ~ence and say "this is mare si.gnificant than anou.ox", 3.G rat 1er 8 ff3.cnlc>> Zf it. in~.-o3.v s angineme8 safety features; we 60 it 800ne cc h1OS8 Systems that 5"@~gate RQQ PreVent an acciQent from occurring, obviously when repo~~le occurrences come in associated with these systems, are o2 immediate concern+ The s cond pazi: of this cpmshion Z wmtel to bring up is if imea~2 you zollov these a&yses and r2o in@eel call them 0 the Gtc ention of those ox)Grating the plants c g has your am=rience been that. VVR has had more such calls, mox-9nciQents t6 call Wmn on, Mean other util9.tlesV
.A Ãith raga'o my preset, kaawle@ge, no.
'9 Are they about average, or whacP Have you any evaluation ah al1P You a 8 sp aking in Series Qf averages Qh ch is difficult to Qo.
But X think one cols 6 say yes, they aze average. 0 TLley .80 not preset an outstanQing ZrcHpxency for such a x'egainm31t oi having things CR3.luau (co their at'hentiQBP
(Ni"a PLQsplc~~ ~ ) CoQ l Q 7 aQZRress th') BP Z ~~ in'.G RQXG SpeC9.f9C Z'eSpQV~G to
~JQQZ'fQGBd.onp x;h 9.8 Rp ~ GcoX3.Qct9.OQ we hav8 only f29.scQGssR re@st"'~9.ozl of zepoztab3.9 QvGQcs Ys9.4h K% regards the va>ve dr5.~t problem. Kyat Ls i".he ou3.y 69.=cass9.or; that, to my haoe-ledge 48 have otic: %9.tb Valve drift o= se'ego~%. Qr9.ftP 10 Q On page 33 of the Staff's cesti-ivy, paz'ag ape.
3.lg ~G Qeconl ssntence Lccldsg 'QGBG < xspG t9ons kxave A 'i? v"'r'9Ã9.ed Chat TUB's QA proar~~ has been ef:ective M contxoll~ g the pLant zestoxat~ch," aud zowie matar9.a3 X sion't go into. X not'ca there 9.s an a29.ps~, that ~8 three ~ Cot8 8 .QQ2.ZV9.K?g GCBletb2.ng t'RS 566K CX9EQ" nard there f HJXBt vZQS 813X9$MtCQP iHQt 'Mas Lt yoQ GLLgbc REV8 588XL W+Qt 57 say bet you Q~dn't? That is a cypogzaph9ca3 error, which ve sh6uM have ca3.1ed to yowl. attaat9on easier. ~g
'A 'Mr. Murphy.) As yon react that X thine you refO'LLA i2t8 Viol .Qpgraded g GRQ 89ZlCG th3.8 LS piRrt of RL4%8y EK>QM Gay UlG CEZ'68 'CLOts VQZCL QR9ntent9QRQ3.~
0 XC 9.8 QL'V. ~QQZG'~d~ig p ~id tbsp 9.8 $ %8t fLOR your tost~on- dmt Wa location of these stee1 p3.ate hvXI&eado, Wa ones that mere mislocated bo ha@9.n u9.t3x, may
ha~7a coa~ihated i.o the seriousness o - this fire and. have ao;c Beea changed g i "Mt location is Sti13 the Gpxe? (lL>..i~w>-"pixy.) '~~~i 1ocatioa is shi11 the sere. XC " 9 voar positioa "t is Lot aecessavJ to shi ft 931at is correct~ six X .. Thaaxc yon. CFMXKGQ". M~ZXZT".. Mr. Sm>> th, ve xecomqise the Sl afx Safety. Eva2QRtioa is aot ia evidence@ aad RR+56 "t is 'tive to he in eve ace'P FAR. Sl&TH: M the conclusion of this paae1's testimoz.y, Kc. Cutchia ';:i3.1 place the PBS aad Supp1emeaCs into evideace~
~(~Qgggg Pg1'~yP nghat s after this paae1 ~i11 he finished with its testis:onym 5hZ Si&~TB: Ves CBAiMCiQf RBXLLT: Ne have questions in connector saith t:mt on um~eso1ved items or item that vera aaxeso1ved avast PebXUBXJJ ~
lB. SlGTBc Any matter xegardiag the Safetjj Zza3.ysis Ragout or Supplements, the Project Maaager mill he spoaso=iag the ia&o6uctioa of the SEB, and he shouM he ab1e ho answer aay quest2oas as to that. CKQBlhh9 MXLTT: Pine, ve vile. defer tham. Thaat yoa, ~re imve ao fu ther cpzestioas 'of this
4S7 panel~ Does anyone else havo furcher cquesti ons of CQis pan83.7 {Ho response j CBRXliED'8 MiLXY: Thex'e axe none. Thank you, gentlemen, you a- e ~xcused. (Piness pane1 excused.) HR. CGTCHXIQ: 2L~. Chaizm~, X ca3.1 'P~mmas to V.,'an>ace come foxvazd. Whereupon, TEOMRS V ~ Ã2893MH ma called as a +itness on h hald of Regula.atoxy S~ff and, h ving been first duly svoxn, was ~ amimd and testified OXBECT BZKMXHATXOP. 32 SIR CGTCHXaa7:
ÃouM you state your name. and business address for Me'ecord, a2..
as'9 Thomas V. Hambaoh. Business address is Mashingtan~ D C 20555 0 Rould you scahe your job Cit3e and give a brief 6%pl an@lion cf your QuhieoP 23 X ~~ Pzojeah Manager, Brogans Ferry Nuclear Pl~~, Unics 2. ana 2, in the Office of huclear Regula49on. Z ~ zesponsible for Ks sa".ecy, zevie~ of operations, and
any HtQ83.zications px'Qpose'3;Coz'he facil" 5 iGs a I have ~~ LPGA h~+8 a thee cage cyg8"r .itteÃL
' C, enti'B.ect "Thomas V. Efa~mach, PzoGSgsio~~~ 'OCUme'nt QualizicaUans". Um'8 ..~~8se cpzali ic-tions gzcpareQ by youP Les, they ~re@8.
8~8 &Gz'8 any cozzeca ions yo'Q E Irish i o'4~JcGP HOo Zs &8 document t~e.and ac~~"at to the hest. oE you'd'CQQ7g2.@Qge QQQ hQ3.iegP XC i' Does i8 compÃ9.sG you= 'cest2%1ODy as to youz cgza3.ificationsP Zes, it BOGS. MR. CUTC=Xil: Nr. Cha~n, X voulck ash the &Ir.. Tf~~ach's qaa3.ifica~ons he adau.tteQ in eve.dence and ho~~ in the zecozQ as i< reaG.. NB. GhÃRBR: . Shat xras thatP The qaalificationsP CBAXKCSf BEXXZT:
~
Di.d the SOaXQ get anotheZ' ccgy oZ this raeent2yP KR. CUTCBQC: These: vexe sezvaQ in counaction A vi Ql cxtxa copies
~
a %@cion %f8 Eavepr X havel a CEQBuM REM<- Se coul.6 us8 an eztea copy (E<~. Cucchin d9.s~~ibuting 8ocum~~cs.) M~B~$27 BZXZZ~Z: Hhtre you ofZexeR the Px'of8s-siona1 q~a~iHcatioasP
LG. CUTCEXi~l X have 3 x ~ X have as'. 2 r Bat ctiG<J Be RLH c'i 58 G piQ hoi2QQ " 3.QCQ ci".9 zecozQ e CBpZKVQT REXLXY: B~~y objection, Tlap (The Qommonc Zol1avss:) 43
TIIO:IAS V. 1"RII!AC)I 0)')'ICE OF NUC!.I!AII RI.ACTA)( RI;GUI.ATION UNIT):D STAT)IS XUCI,I!AI'. RL'GUI.ATORY CO.'".IISS ION PROF):SS TONAL UAI I I' CAT TONS h)y name is 'l'homas Y. l"ambach. I am a Project i~)anager for Operating Reactors in thc Division of Operating Reactors, Office of Nuclear Reactor I(cgulation, of th" Nuclear Regulator>'o.'niissio>>. In this position I am thc principa) co>>tact vit)i each licensee of my assigned nuclear plants. for all lice>>'si>>g <<ctivitics, su"h as lice>>.,e amcndmcnts involving I h changes to Technical Specifications, approvals of facility modifications, and c)inngcs invo]vcd wit)i mccting nc~; or ) cviscd NRC rcquircmcnts. I hold .". L'ache}or of I!lcctrical )inI',inccring dcgrcc from i~larqucttc University. I al o cnrollc<l in post-graduate study at thc U>>ivcrsity of I)'isconsin ii> l)ilv:aukcc complcti>>g a course in Transform )Icthods of Linear S>stem Anal>'sis. I have had a total of 19 yc,.rs of professional experience. For tao >'ears after receiving m> bachelor's dcgrce, I served in the U.S. Yavy as an )'.nginccring .officer on board the U.S .S . Union (A)~K-106) as Llectrical Officer and as hain Propul ion Assistant. For. tcn years I Was employed by a nuclear reactor manufacturer, Allis Chalmers,'Ianufacturing Corporation. I In their employ I ~iorked first as an analyst in thc.ai>aloguc computer
~ I performing nuclear poi'er plant acc dent, transient, and conti ol 'acility analyses for tho Experimental Gas Cooled Reactor and the Fzperimental Lo>>
Pressure Process llcat Reactor. Then I became an operations engineer ..nd
2 pa>.ticipatcd in the start-up testing and>>'riting of onerating proc durcs for the Vnivcrsity of. lfaryland Rcscarch Reactor, thc Swedish Test Reactor (R-2), and the Dutcli Test Reactor. These duties I included supervision of the operating crews as the rcprcscntativc of the vendor for start-up and testing and thc writing of thc test reports. I was thon assi.gncd as project cnginccr for the LaCrosscl3oiling I )'later I'eactor where I was responsible for. thc clcctrical and instrumentation design coordination bctwccn Allis Chalmers and Sargcnt and Lundy, thc Architect and ) ngin<<cring firm for that project. I also was thc operations reprcsentativc on thc project rcsponsiblc For writins operating procedures, prcopcrational tests, and start-up tests. I then became thc Test'Supervisor Y at the LaCrossc l)oiling t"atcr Reactor in charge of pcr.orming thc prc-operational and start-up tests. Finally, I >>as appointed Operations Supervisor at LAC)!'AR in charge oF thc'Al]is Chalmers'nd Vtilit>'perating personnel until thc SO day>>arrant> run was completed and thc rcactqr>>as turned over to the Vti lity. I next >>'or);cd for a consultant firm,'.'Nuclear Associates Intcrna ional. In their cmplo>, T>>as project engineer for a contract involving installation, -:- of a process cnr)niter foi core performance monitoring of 'a boiling water reactor. I was responsible for the writing of functional speci.fications,
~ ~ J of thc b.d pac)'ages including cquipmcnt specifications, solicitat
~ ~, ~
'reparation of bidq, and selection of thc successful bidder.
<~
In 197~, I acccptcd a position ..s Reactor )!ngincer with the Regulatt:ry staff of thc Atomic Lncrg> Co>zr~ssipn. In this and subsequent positions,"
~
~
I managed thc safety rcvici~s of poi"cr and. research reactors. In this capacity I have been the Project ~!anagcr responsible for the safety review of the operation and modification of the following facilities:
~
Oyster. Creek (1970 - 1974), R. E. Ginna {1972 - present), Zion {1974 1975), Droit'ns Perry (1975 - present), and v irious research reactors'. ~ ~
\~
jrplA
~hM~RCB X L~QA~ X'l ~77 L~~'~G "lo<v ~)ree Pomme rx"s, the first af these is enti~leQ "Sa-eely Evaluation, Report R-late8 to Op-~ation o+ Breams Pe~ Unihs 1 anQ 2 Po13.teeing the 5Tarch 22, 1975 Pire," Qate8 i~larch 1976.
The second Qocnnant is Supplmment Mo. 1 to Kle Sa~.GR y HvalM&n Report Caters aTQQ8 1976) cLKL 'die Chirk is Supp3.e'en 'Ão. 2, M the Safety r~aluata.on Report, .dated ZG1v 1976 0
'7 ~G these QQQKGGRcs pxeoarQcL 30+ yolx or RQQ r your Q~~ectioQP Yes g 'h&.ey vere Are Mere any . corrections x~i~ch you cowish to
~
bwve vade M .hhsm'P A Mo. Pwo these 8ocmnmxts true and accurate to tho hes8 or" your Knowledge anQ be3.ieH'ELGy arei Ee they comprd.se yome teseimony in th9.s hearingP
\
They Qo. lK.- CUTCHXMs Mz. Chai~an, X vou18 ash that. the Sagely Evaluation Report and its Svpplement So. 1 and Ho. 2 be achni&eQ into ev9aenca and, since they are faily thin Qomnen~s, thar they he hoan8 into tLe zecnzQ as 9;Z red. He have saz2icient copies to supply &e reporter..
CaBZiX~R>1 KZLiY: key o"jeeeior, Mr. Qa ner2' MR~ GMCiER." Ho ob ject,ion
""CGiGZB?JRV, BHTXZV.. "Any cbjechion, Hz. Powrei17 NR. PQ~~XL: tTo obgecW2.oa.
~XR~ ~
7 BHXLLY: Very ve3.X. TAB SCBXZ SQf GCy Z<icK3.%BC" OXL RBpOX5 V~ '& Su@pl.emanta 3. a>~Q 2 are a~~tteQ iz evi.Qeaaa aeQ z~i13. he 3.':lcozpoEQCGQ ~>> MP'ecords ~ t~+8 QccQKc'F ~ f011057 ) i9.
Neo CUTCiZÃ: H'" a Cha" zF(ale p Z ~EL'Q i".Uz'CL38r
&~6:St3.0338 o ""ha witches's avaiiaMe 'for Ule BoarQ's cjlM)stxons a 1 CKP.XBVZ>T RHXZiTV: Ric. Gazz cr, 'rou3.ck boa 3.92ce to 'ross-msa~~neP a RlxxKUte'o loof" ovQr h9.8 QQakiZ<>>
cationse QLR. TOO'~HZLYO:. <<2: Pw. ChaixT~anp cia.+ant to Fake, sQ 8 the cross~ezc~'Qxzlatiol3 xs 2.9JD" tel to the scop8 oz tile contentions 7 is tea; coz'x'GctP ~ axLQ. Q'i13 Dot pzLctÃGpass
~me conten=ion -.which ih was'.agree not to Litigate.
CEAXLQ~~l llEZXsLY "cue lxzLVc 9.t to %3B col3tmtions &at axB iQ isw>G hGzee 15c..TOURTELX07.'2E: Zl e Board. is ceztv<nXy fzaa to ash cfUes ciolls as they serac>> H.t o CROSS-EMMXMt&~ZOM
'BY FiR>> GAMER:
0 Mhac RMQ o~ nuckear reactors Mais Chalmers 2~iaztQZ actori Tlg Co poration GLBt~GP Bo Bing crater reactors, research, m6 test zeactorso How many hoi3.i'ater-zeictors 69.6 they mRe, pGTf~~ GactorsP TBXQQo
Do you, knower E'Bly they got out of Heat business' pzesw~m they ~reren't ma2cing money. Gi-P X 'dxiQR they Ãeze ixot RRRing Money M.1 right. As Z x'eca3.1 COD SER and the Supplmn~~t~, you haQ a finding that it was not necessaiy to cd an enviromnenta3. sta~ent on Bzomcs Perry L and 2r is that core-ctP Z he2ieve that ~ras in Bupolemen 2, yes, six. 2Q.1 right ~ Are you'QQLQiaz Pith a case iB, the 0 S CGQLt of Appea1s for the District of Columbia > 74-1385 Resources Defense Counci3. 'atural MR.,cUTCHLM: 2L. Chaizman, i wou~d object to this 3.inc of questio~4g. X a>a not amaze of irhere it 3.s going. X don't believe it is zeXavant. CKQlPJGT KXLLV. Bave you completed your question yet? HR. GZAF~EP.: Ho, as a matter of fact, X haven'. CHihiHi~QB MXLLY: Xat's complete the question ZiX'st+ P3t. COBBER: X appreciate the Boarcl letting me finish my question. BZ 2%, CAHBBR. ver us Qaited States Nuc2.ear Regulato~
CGPDP2'~isionp U1sited Otc~tes 02 REQBr" ca PGGDQnQents V&zpoQ'L 7, "?."88 Nu .<ea:" Pov7er Cozpoz..tion s.ezvG. or there P7aS a CN'ipanioxi case p Ã0 ~ 74 l 5 8 6 5 t1s8$ 5 cas -s v7ere c~eciGSQ J
- 23. g uly l 9 7 6 "p '1'.ch 'l'jas not too Kanv days ae'o s'3. Z underGQQnd it. these cas s sag~':.in i'=:vidual licensing cases you no 7 have to discuss the ultimate ~mstc disposal pxoblem. ~Zhe~r are not going to lot J188 3ust %alt Over 2. ance. -
ay 'e ll Kvo rz'sp about "Pat late>'" So as a result oz thisp are you all going to do an environri3 at@3. statement ir connection c7i'ch th's licensino 1MttezP sE64 CPZCH 8: 'L~o Cha2.rsMxl p X Would repeat, LRv objection. Z do not helf.eve ~Us s question is x late8 ho the contentions in issue. PR IB~sTBP.: Xt 8 a +~%%7 E)atteà p i'G 'was decidca uuly 2lstp '1976. L'ayho he mil3. ans~p7er that guestion Zor my iso...-"tion OE" Me zecoz87 CKMEBRM BEXXZZ". Per'haps. But in any event, mith regaled to this vitnessp Z see noting in h's professional qua3.3Ãicarions t'1at would cjive h9.".l1 Re bac>ig ourd lA ans('7ex'lis guestions Xt is a > egal 'fQssjte'ou are as,~i2.ng bK. GAMER: ifell, other than the ~act there'
a fiQQing in the SHR that an ER is Qot Qecessa:y, P3ikX=drP~7 RGZX:i"" Net'l, 3.f you want to lanai=" factua 'ar c
\
you: auestion to that las a.'3out the finc~:: Qg, have no pxoblem lrith it; "ut the incxaduction a'vt +he ca 8, aQQ vrihetheir he read it or no'=, i thi2lk 's inapprop1 ate l0 I this paztioulaz'@itness
'l Question oH the MH. CABIPBR:
x'Gcox'Q 7f Stan BBC Staff mourn'ns;re the Counsel Z i'rouM he gla6 'i 0 K'Ji tMLca~'r the cp28s cion ~ blP.. CUTCHXH: l~. Chairman, X still do Qo"- 888 t 18 relationship to tIle content3 on 5L ~ QRFQ82 Las zais88 r GQG as far as hFzC Staff haviQg R Ziilal Rnsvez at the malnent as far as i am amaze this @hole question of the impac of the68 thoro cases on decisions tIlat have bGGQ pz'Gviously Rac~es " 8 still lÃ288z'onsict 't" on in th CORIQission ":S X au Qot a~raze of a final decision as to the g 7 3Rpact of thxs case ~ CKAZPJGBI BHZ~Y! Z Mill susta2.n 'chG Ob38ction ~ But Goes that 8:mlana"ion suit you, Ih. Qy"-Qez'2
!LR. C~JHB: X thin3c it's an annex'o my Qczestion 'hey haven't decidGQ.
CPDXRN~>>4 3-ZLOTY: ÃGil, i:hen, you'e got your,, anseex' P&. QKK~ER: Do y'all plan "o appeal tha oas82'N. CUTCHXif: to lay RnowiGQge, ~Mat Qeeision has
j~+2Q not >set been 'abide
? SHGÃ: Z iK'~ ghc. have zeal." siÃzLQsz's'~co8 P~ ansPlek i a 4 '"Ule ea' xe "
~
s'i 0 PZ a Gaknek S gUSS'~3.QD D-"8 Ul"Qezsz .n you to say there >'sas Q nega."xve c".eclcRat3 on Bs co t~'IB g l.n '2%3.6 case Kh~0 i' ~76$ nee888: 9.$ f a 'fake of SiIpple~sL.en@ 22 7j 2Z CGTCZXlI i ! el~eve '<he "...i.bness sa~6 Sum'@lenient 2. KEPT" BJ.Lz'IESS s SLOYD'Client 1 g,page 27 y secCS.on KR GEON: J.hank VOQa I t:IR CTHE R: isTo fuka-her Cfues'CiOBS a CE~ZKw90 BBXLL"~: i'Ix'a Po<'7ellg cross ezBIAMRcxonP i'. PONHLL: J. LMve xlo QQestxonsq s" L" ~ PRe CUTCHXM e y slave Qo xeQ" rect g iM.z' BO~ ZKHVH3T 0% 3> DR COVVZT: Xn keying ih SHR, my attention was callers to a'r. enc3.os"".e 3o. 1, ~~hic~i. shove8 the out;standing i.ssues x~i'.h aegaeon .to Srowns Fek~ Nuclear Plant 1 and 2, numbering
~ f Gzom 1 to 10, tvhich vere st'll u~esolveQ..
I IUoiz, ~n keying the Svpplaxents X notice that son- oz go~boos evan al1 oi 'hase wa: a aakan nn in oonsida=soils 8 '"ail..anQ 6'sposoQ o<. " van"'eQ zo ask a couple" of questions, oII, voml6 he sidhe"i.ez all o" these have been resolved; and
jzb23. ] 3. f not g s'which ones are sc3.11 OUtstanding Bed the, o:" coUrse, n:ore ~portantlv, ~she"ner the ca.Oaf f 3 8 BQY3.$ iied v7i i h tlute: eso3.Q93;on of these points oy tI:e Applicant? 3,3.80'n 'e Baf et'valGRtion Report Ue have a 3.etter of the Zadvisorv CQFiM~ f ctee on i?eactoz Sa GgQards 7'lith a nKY3)er of concerns 8" pressed bg hat Coz'ldittee p and Z Chink these also were addressed in Re Sxspplrments to the SHR. Z Cgin~ xt ivoQ3d help che Board and che record for the Sta"-" to g've a lit'tl omaha~~ of the statns in regard to these atters '=hat they are .:aced mitn in vriCing
~~
l'18 rGQQired PTilKa619enCG to the technical specifications should this be permit ced2 CBAXRNMI M~XLM': X reckon ve have se>seal qu stions there. Zs 'chis the vlitness the appropriate one to ans';Mr those @Desi ionsP
&43. CUTCBZM: He is the appropria e sitness to the question, as Z mQcrstand it, regarding resolution,
.'nswer OC opKD it8iQS g ~pcs p s" r o 213 CHRXK~~>2% 3ZXX~Y: Ve~ ve3.3..
PH> $ 7XTHES8: A.'2. the open 3C:ebs Rat There
$ .denciziec: in the original SEA have been resolved to our
'gati faction. T.".ep are .addressed in Supplement l. And then 2c3 one its.'., ~Q:ich sias buried over to Supplemenc 2, raga=ding
468 The i1C}7S i'ms are also ctiscussed in Supplement 1 . Zxppend~ '= 8 < Bach 0 the 'a":~s a "G ader- SGBGr and tten t,he S'Fipple."Pena "seas scnb to Yne DCRb e P ve Z covered all of 'cheo>xtstand ng 'cmsP
~
H~Z DB. COA~+21.
~>he only OH>Br .ulought. aha'c occurs to me is do joQ Rave 3.tellus @ha~~ P.- B zesexvGD for &le first SQQc~~404n p=riod, 0- xor a later shu~do~e, period'P
'I
'ZLleze are "tells cQrzi azQ 2.6QDG3.f3.Bd xn 548 SER to ha iamLemented prior Co rata'o operation.
There are none reseed for he second ouzagBP
@or there 'is oQB it~ wiheze QQG ~&36Penca'c ioil coQld t B li";Ltez t23an i BG 9 rsvp revi BUi 'lg OQcage r HLRC s a21B cL~BSBl pump; additional high pressu-B fir isa're Qiese3. pump.
O'I3~ "n CbQ 3.nterM tPG)r have CODS'trQCCJ.On PQGl'DS Qt the SX~B
- Ihich are connected to tbei". ant9.1 Me@ get che d t Gsel pumps Zs '~ha@ M'G Staff s p. oxess3.0nal conclUsion MGSG i'gems twas are 'r3ostponed co 'che second OU'iage RPQ be pos'tpoDBQ, safelvP C
Zes, s'r, t>at is cshah lie have concluded in the'uR M'1K SFON: VQQ sale. Cbe ACES items 7'Iere addressecl ixL +ppendx~' r SQpplement 1 p Z hei" Bve it RctQal 1 ~J 3.3 3,n Sec+ion
Ay~ g Ppzlon Ke~ yon are correct 3.0 '.~~'j'QR~zs and ~ng tha c thG reco',T..u 8DQR~ Losl fo. seoaxate caale spreaji:.r roe.:s is Qot heing 3zplementec".-, anQ StGPZ 809s not +8128'i 8 sle~essary to iQlPle'7sens tha'-,. 2.s that cozrGcts Klat is correct j ~ 82.r ~ CQU1Q yon give Us a " 3.t'c le his moz8 aE)Gilt tha CPVOlX SP2.6 i.n the report 2.t 3.SQ ' ~rorth 2.tg ho>7 KLC s " 0 %foz+~ll 3PP J T'e p'zpose of the separate cable sprea8ing rAGPi.B %Ms to protect thG z'eQUQQant 82.v2.sions'zoRc: ho'Ul h..ing involve8 in a single events a single firer @here both con18 be Qislablel J3y the si"lgle s.ire+
- n the case o+ Bromns Per~~ cue +oui@ accept--
vali, i >~auld say in Axe case of any operating alant in order to meet that objective we -:7ocxld listen to all proposals to try to arrive at the best solution. And. what TUB. ha" proposed as'hat;ras ar ived at through the revisions o" their restoration program, modification program, and -how >re feel that the reiu3.t o" the combinations of measnres heing taken 61 80 proviles aQGcp2ate protection o Z see ~ This is just a matter of clariZica~ion: in Ri tacllzsnt 3g 0 ig3.M3. GHRg pages 4 an8 5 I th8ze 3.8 a Oi-cnssio>> of reao-;mnenclations an8 one recommendation was chat
410 CQQ J QS Qon3 Q QQ Q BQ Q }~v if j Q g% passeg B
'Gest.g QnQ Feze Z 2:ate i.i: ~jQL~ BMn f08 caQ2.es dred vd.'l.3.
no~'cass XK~i~" ~cescQP
-'.s Cat zigkCP Con M Lcno~'l 3.f 'an SPY Or~la'c Z t:zasn 8 s<.ed ~o hbe SHE.
Dicey. Hoi~ p 9.D R " Bss nega<3.ve fash3.on- aQGSB are '~o 6 nec B s sar 3.:"."g cab'.es 'cl2at %/i11 pass ~20se ~es~sp Uonld no'c". r'".no'.~T xz @net ~don"-fK pass o ~ noh. ' See i Q ".8+~r&DT R~~X~Z Ttle Boar 6 Ilas no XQ'nez t3" gilesCions ciR CUTC23~i1: Z MOQ3.8 po9.ni. otic Gs a f0510Ã-on Uo D "i SQQn "s Gal:.49.ozLRL Q22es <<:t.o31 5213.8 Vox'62.ng z'Bgal."Ging comparison tt3.th the spec'a s~2uKy gzoLp,s z.econmenQ'e.i='aeons ~ \ <<~ Cia't 9%8 R I PTlgove frock 'N" 8 vozni22g s gQ888ions 3;c 2.8
~3 j aQQ~Bssed in Supplement ~So. t, page 25, Appends~ D 'ach of 2:he sp ciaX revii~r groups recommendations 3.s add=essed.-
le. SHOR: Thanlt: you. CHMK&27 3HiTXZ ~ Do t~e h"-.ve any fwvtt2er ries:anions of rill xi<ness? {xilO XBSPOTkSQi ) CH~'Tc5278 HHZT'"2: X hear none. 24 "ban!c you very 222nch.
471 (&fitness e Ko~~sQQ a )
+~Qsxnessp cent lc."'e:Fc MR OURTZLLGXTZ: Fir. C+~aizii?an, Z >~7oulQ Rite to TQc~LG a YAOtkon Bc tLRG t3Zie p pnQ. spepJc to 'K=at motion ~
CLSRXBk~KL'7 RL'sXSQZ e AQ3 rkg&its i~A POI~IELL Z gQGSH 'NQ bave s~L~ ~ 811ov. s auestion barging over Crom chis morning. FR. T'GUMEXXS"TE: I a~a sorry.
&JR. PGE7ZLL: So iE ~~e couM recall the TV3.
'<'1itVesses to the 9l" tress tQQ" eP CKXXKGQE Tc" XT XsY ~ Five g gentlemen'Ml voU retd co the witness stan', pleaseP LFnereupon, GHEE'LACK BEh A. GK~.CT H Z i%. CMHOHT ZOiiB L XHCVKBSKN aces pr viovsly uolv slsorn, arere fnrther ez~mineQ and &>~~her f 2R test i&.GG~ Gs fo3.lolls
?3 PURTiiBB DXBECT EZbs~IDERTXOÃ BZ i~fR~ DUN>MiR:
Z i'll direct my qnestions to the panel
472
-'zh26 1 general3y O. Ep&e 'che s6<~&3)ezs og the panel zevipBT8Q infozzp
/
'Cion vhich is zespQns ve <Q tee Boc7~Q ' Ques 3.o conce 'ning I
/
cQL~:%prison oE a~noz~TQ 'ccurrences zsi~ozc CQ 50 Coilg. eGs ~~c ei. the HRC'S ne<I1 zepOX"~iong GCQ8MP (lL. Calhoun.) Ses, ne have. 7fi.a.c cKocumnts QiQ you revic':rc'L 7'7e r - vQ.Qvl - ct Chx'Ge c3oc&%18nts en@.3.t3.ME L Sport to Congress on ZX. orna'l Occuzzcnces" mac~ these three c'ocuments are those that mme the zepoz s xoz the year l975, January to June 1975, October to Dec=mer l975, ani July to Septemb r l975. Aze there any speci fic iQenti+icct'<ion nQHlbezs anc if so, iQeacify then> fo~ Qe purpose of the recozQp vill reaQ 'the Specific nQQQ)ezs off The January to June l975 .HUBEQ 75/090; July to September l975 is HQKG 0090-lg: an@ he October to December l975 Qon~zealc., NUBHG 0090-2. Thank yo'Qe Hhat <~ere the results o - your l on pag' rovicv2'ah2.e 3 of the MJB 6 75/090 indicatec" t>~4 til ze i<ere th e single abrozma3. Occurrences, one reocurz3ng D~ nowell occurrence, an6 three generic problems zepo~&eQ ~o Cohgzess in l975. O. L~ other wozQS, isel3., Jlez twas only/one of these I
473 reports that had zepozts to Congress," cha other -N-o did not nave any. Of M>ase 3.v. OQD ca seen Ave pJ.RHs vs ~paz3.ancad im~ividual events considered to ha reportable nndar - the NUB"6 guidelines, and these ~ive plants tiara ona each, Brooms Parry. H. B. Robinson, D esdan, and Q13ad-Cities. Z Q83.iava yoU 1 Qnt ionad ganex'icP
%'as iNPiC hM also Blade a cal agozv 3.n 'che zapozt called "Generic Problems", and chey list three generic problem~
and ches '.nvolva generic aua. tions concerning tha design o material oz &zaa plans o ox three generic problems vh>> ch 3.nvolva ' plants I ona o f these 17 plants 3.ncL1ldas Bzo'AQs Parry Okay. Bhan ctuescioned yon have indicated five plants mperianced individ1 al occvzzancas; you also indicated Brodns Parry '1'ias ona oz those 7'Tas the incidanc involved, n~hat @as the incident invo3ve82 The incident, involved at Bzo~ras Perry vas the Koch 22nd fire. TL1antc <on ~ 7'shat do 'voQ conclQde iron yoQz revi61'7 02 thesa dccLGMnt s 7 VT ll. base'd on this docurn nt 3. conclude that
l~ Vd Brahmins Perry has not had an unusuall~ h'gh nmv>er oz GkL10. mal occurrences p Kihich vFou 'xn priv %ay reflect Gn'VA
' 2iersonne ' s ceckn)ical ccrc.".Qe'cence~
~E. DGW~YR: 2hank ~~ou ve~ n~uch.
F~. Chain@an, no more questions. CHZ~X'KP~T BHXLLT: lid. Garners K%. 61-"3BZR: PIo questions. CHPXB'&~7 BEXLLZ: Have the other parties any questions af these ziitnesses? (Flo response.) Cji+~XB89$ iRHXMY: Than.'~ doug gentlemen@ you are Bzcused OVitness pan 1, ~cused.i CHRXP~Q&T BEXLZ Z..Kr Tou~eellotteP
&E. TOURTHLLGZPE: Mr. Chairman, X recogni"e that, according i:o bi-. Garner's opening statement, that he intends at least to bring his evidence together and enclose i:t in argv~aient> and by some means establish his case in that.
ZQShion ~ Ho'i'Tev'Qz g it seems i o Die that i'L Tilight QG ezpegitious and appropriate at this tive to >nake a motion which ~i-. Garner may answer and amerce his closing argument at t the :a~me tinge, and perhaps ve c~n each resolution o - one or bio sissue. in this case. Yhe Rlotion X *iish to ERke is a NO'Cion to iC
c 0 d3.sD I ss ECz ~ Garner s pGtxt 3.on a KYJ the Gason g L~RSLca1 J.y; that Z c.% IQRRing that:Llotion "s c hat E'L:", Garner QRS failed to m Gt the burden of going foz~razd -;rith his cas Z believe thRc R revieiJ of the Gv" cadence that Iles b88n put hex:ore th8 Board here tolayp boi"h by 73zi Garner,~ by the Applicant ~~6 by the NRC Stc> ff clearly indicates that K'"~ Garner lRs failed to go zo 7azd vich hi - CRBGg, s c" the HRC .requires," and has failed to elicit any information on cross>>ezamination which vould in any way ten8 to supi~oz~ the case that he has col":chedo To begin .with, bh-.. Garner's case sta "ted m>t today hy citing a zecenc Parley decision to the e feat that the'Board has the authori"y to look into matters among the p~~~ ties. Certainly: me have no not'ontroverted issue vi.th the decision in that case.
'Eotlever, it simp3.y Qoesn't apply here. Roreovez his Goes not provide an adequat substitllte for the
.Xnt~wvenoz to meet his burden of going forward. 74ovr, ~that Mz. Garner is asking the Board to Qo, it seem to me, is to do that which ne has failed to Qo: he SGGRS to have the Boarcl i RRG his case fow~larca ~ Hz. Garner then vaunt on the stand and under c oss-examination by the applicant, TK4, &aonstrated ~2m he Goes no have the expertise to
\
make R technical judgment in this case: that he is going to make his case implicitly
476 thzoUgh 1ogical gzo~>~~As r 28 also in(lical86 that the V nQGU39r 0-'ccurrences DzovQs t!18 " coPlpetealcB of Tv& J 'however p
'e also saiQ that a he Qifxezent abno.iTilal ocQzzrences aze SUsceptiM8 t3 Qifferenl intezpzetationsp Cep8DQing uooxl th89.z. natuzep or the nature of those abnormal. occurrences.
TV% then s'4ppoztGQ th8iz posit'on '3'ffering
- vicnesses who in 'effect saiQ that the Mnomml occurrences ezgezieiMSQ O'" BzGKls 'Fez3."y "Tere just BJDout average this is the sam= test~~ .ony that was elicited both by 5Ir. Garner and by this .Car<i of '=he 1~BC witnesses.
of
~ ~
&fr Calhovn t'~ho sumilazise<X the test935ony TM. hy saying that the n~~ er of abnozmal occurrences is not unusua1p that there vera oner h~i.'o significmt abno~wwnl occurzences. anQ ee just heard testimony to the effect..
that this is not w~~usua3. @hen you consiQer the bros scope, oz the broaQ nuvkez ox p3.ants in operation. Th zesvlts of the comparison >ze e e ~lain'n detail by TVA," and the cross-examination hy Yu. Garner 'faileQ to establish either that the witnesses uoze professional wagualifieQ or tha'he abnormal occurrences vere in any ziay substantially different from those 8:qoerienceQ at, plants in oth z pa-ts of tho VniteQ States. Zt seems as though one ox the objectives of
-L~. Garner 'n his cross-ezamination csa.". also that abnormal
477 occur"nncos sFere calculated ill such a siay tl?Rt tt~~e 03 operac'on was not properly considered, IFhich by elaborate ezcuse Ke e" Rborat3.osl of Questions Qp be "card Nas shobn 10t t o JDG cbe case i
' - bort Ggarding TV& ~ s witnesses I'Ir Garner failed co refute chat tbe number of ab~ozm occurrences l at BrosFns Perry was unacceptable, and his cross-ez~~I.ination fRiled to Glici any information which might he construed s offer"ng 'o.obat378 ev"6".GIlce 3n support of his caseg and thQreby provkding R bu den o2: go2.11g O'Fan 77itt1 Gv3.dence ~
V7itI1 .&G MRC witnesses ve Rga3.n had documents ~bat wer placed into Gvidenco to shoe <<Mat the abnozmal occurrences ezperien ed at Bzowns "erry vere not unusual; aga" n czoss~B3camination on tI1G profGssioilal 'ilalixicatioI18 ~ if indeed Kz. Gaoler was see'.zing to disqualify those ~Fitnesses that cross-G":amination failed. ItA~)reover Hle cross GzcRinat2.on failed to s elicit any information that Mould SI~ow that the inspection program does not protect puhl3.C Ilealt?2 and saf ety ~ Then ~FG coze co the safety evaluation which, again, Nr. Garner ha8, no ser"ous ctuestion with; and, indeed, I dol2 t hei " eve it could be '-'Said that tIlere .,:5'Fas any effective cross.-ezamination by M~. Garner oz: -t¹ safe-y Gvalua'on ze'"ozt o- its suppl<ments. Ve have gone: H en, into Conclusion R, Nr.
6'iarDGr Peithe " prociUCGQ nQr Gl3.ci'i.eQ ev" 681lce 'i o SQppoz'c S Casey Dg I 3 S' SZ KO'Dg < S QCLQ$ ]GAG ll C ?CC ~ C Ca08S no'c set OUt 2~ac'i s q hQt ." c .'. merel'j~ R DarzPU'."78 Qx hot'7 he ivP. nQGP. ~o proce@'..<z this case; at most:, his tes-'--:~mony s Gferences, < bable:~~hie'1 all os. the iestiaohv "n he ca 8 ~ I l.3MiCGC89 "S OZ QUGStiOQGQle Va1118 in GVa 'ating c?Q J
~ H CQp~g39~cBxxcy 05: TVi ~
L1Q i s c 11y GiBili g 1 he ZQ'i:Qicv81"or has z.ai3Pr3
.co Glici.~ probative 3z ozma~io11 to <he conc:zary on cross-
~aPlinagi Q11 Sinice <<18 has ".ail'o Dree't 'hhe QQ~".8811 'f.
gong for:sar8,;<18 Staff vo11ld ma".8 a motion tha.c his pe53.73.QD z'8 <t3.GL13.$ 888 g axle 'c!1at the BoarO Blate %~8 QpM'opr3.ave
'dt}4g. in this casa, as 't can 8o, siace a pralla facie case has heeil illa'y hot TK Q1i(" tQG 8's.a ff aQ8 that 818 g ~
i p'low.c he a" lovea co opera~a, or that. We aaWorisation of che BOP re he grailt88 to al lo@1 the p" QBS tio operate ~ X mign"= also aM aha~ ~ais motion "OuM s38 6%8'8 ho:ih to vl.Livs.ately disPose of. ihe ca'"8 or. the 1".Grics,- aQQ also vioU3.8 i>e IQRQGg altexnat3vel j'g CRa'c is% 'c+8 evGQi ( MG Board i-ould c'.Gc'QG not to dispose o~ the enquire casa o11 'ts
~s~exihs l3y a mo'=ion to 8isnliss, thai= i,c should at. leas~c vMce ihG apprapr" ace findings tha.c in the cix'cps.tances operation Ji3 o~ 1:be plant ca11 DG authorised, ~orthwitn.
479 t Tair87 barbl rule on thai CBQT@K7 BZXLLZ: But until ~we just
'ar from so -'hat Ne are cer" a'nly not b>z Carner ilz. Ga"ner understands go>.ng
'a~38 ~~8 to (terStanQ (gnat you are Day. ng r ~en r ~<nQ eSSeroe O f yOur E
motion to 8ismiss is baseQ upon the alleged' ai" ll~8 of the I Xnt zvenor to meet 218 burden of going forward with his case, as thQ lic811888 hc s Eet is BvzPen of proof c418 the Staff has nade its case; that 's, &at the Xnte~enox has failef3 to='PtzoQUcQ evict631ce that NOU Q overcome the pz~ "Aa -aciS case es~ ~l~sh88 by the licensee and that establisheQ by the Hl:C Staff;zi. h regar8 to Xntervenor's contentions7 Xs that Me gist of your argmaentP NR. TOUTcTELLOTTE Yes . CFRXTQc!>27 M~"XLXY: 'Q. ~ Garners HR. GENER: X ma going to re~ponQ Lo that arQ X will respond to it b iefly.
'l7 Xt is interesting to m that at this 'ate Gate, the i~kRC counsel is all of a suMen getting interested in a'ly petition to inte vene Was finaliz86 lat8 because took them three voe1cs to answerer a letter of mine'etting Qetai ls 'on th" s thing~
Once again it vas late because they serve a three>> 23 year olc". Cer"':".icat list.. Zwd several +eel:s bac'k, i~3r. Powell and " reached 2g substantial agreement on hov ve could speed up the hearing.
liQQ Rod lze had Lo pxcd them. Zed ac 'chat time i~"r. Tom ~3.1octe I agreed .~1at ic mou" d not h= necessary =or'" e:*nrem~"-nor "=-o put on a case in rQ1ation ~o @he thi d CQntenticn 58cN~pve,sis testi'NQn j CQQ18 DG Qev81Gped oz1 cross 8'aQPiU.v*ationo Vle we e going to have an agreed stacement of faces t cn Contention 2. ~L. Pove12. agre d on pare.of 't and Y~r. ~Ã~~Mler Who is QQI he e today agreed Qn
~ .
par i" of ' g Dut he could nat agree on a11 of i". Xn o=da 'o not hu=den the xecozd, "n order to noc Qc L'Bdundancp ox'ds." zloc 'i:0 consume Nore t't Lle g X scFJ no h point. in repeating what 61at tesiilriony said, because X sti11 bi.rd- that Lba'c factua1 st.atement on each one of -'hese oc-currencesr a-e susceptible, to di"-fer'ng intezpz talion".- Pad Z tt19QMi '&ac is 'this Boa. d s perogative ~+18 Doc Hx' 5'omhe13.ott 's pexogativa.
&md if he rea1ly van'cs to get on xH.th Mis busi-xiess, ~L. Pa~cell and I have agreed that at the conciusion of -this evidentiary hoaxing today, .Mat ~sit'Zin five ca1endar Gags ~ere ail.3. exchange progosad findings OP. fact and proposed findings of 1alf ~
So far as X Rnovr, HRC hasn't zeached a decision on chal=. Bui if Mev'ea1ly;rane to get on vriD the case, they ca~ make a Cormitmen- OZ.'~J>aC naia. PMQ Z c~'ll x.ot- goxng to d"- gnx fy K~ < Yourte116t'ce 8 Z -ea1ly don'5 1a:ow hoM to describe it I am not going to
digaiZy it further by responding to h's ~~~~~ent on the mo-tvoOn o Thai ~!'OQ CHAREZM~Y: Hell Nr. Garner Qo yov want to give us a clos'ng statement in ~he 2'oxen of: a sunnaim~ of
%1hixt you think'QUr cross-ezc~'99 nation deve3 op-"d as ).Qr 8$
vou- contentions are concerned: lyha- your cross-ex~~ina=..ion tended to prove? EiP.. ~K:00HR::. ~a sure you don ".'aint me to go back and review evezything that was said. CHAZBE~"2~7 RPZLLY: Onlv as brief"y oz vs xnten-83.vely as you e7ish to do it) allot at all i2 you g %Pish i.o do it not at all. EK o CARlER! You aze R 'crial at i.orney g
'n Rdpiain istrativie judge, and your previous ezpezience makes you C
mained to find xacts, and Dz. Cowan and the other gentle-emen are both @rained scientists. And X simply think that i~lr. Tourtellotte wants you to consider tne page and a ha3.f'hat X put in explaining 3$Ns nd PNRs and he knows, just 1ike Dave Pcr~;-ell kn w, that we >raze taLMng about Me facts are he=oxe this Board, a<nether X put them in ox they nut them in. Zn Pily opinion- 331 RYE Tourtellotte 8 testimonyJ he hv~ag himse2.+. Give a bureaucrat enough paper and he is c~'03.ng to . uzn out 85 pages o
882 hn8.: thinlz -this Board has <o look - t <!1is eii o2.e zecozQs 698 3.t ctoes."1 t ~lFYJG cz~vthxng to 8Q %" 3. 21 Ele saying el l the BK<qle e3L'gs o~rex Ggai xl ~ Ane. T. a>> nol: going to take up vou al2.'8 time by elBQoxQt*ng QD 3.5 ~ CLQRZK&24 iiHXZZZ: 2'hen it is yoor position that the z'eel'1 Qpealcs for itse3.x'ilQ yoQx'ese 3.8 GOGQUQRelv oxl the zecox'clP HR. GBR~AER: B~ght.; i~e" l, vheH.ex .t. pa~ iC on there or rot, i" is'on the xecoxQ. And Nr. Touzcellotte QQgh'o RQov l.hat does%'t Hl61M Rl1y Qii~exexice hGH ir. cfets OQ the x'Scorch~ llR. TGUK'HXXGTTH: Px. Chaixmnn l ~could 3.ike to jv.ot say a cajole O2: thiz gs. OM is hx'ieC3$ 'o x'espQQQ to ~he QisoQssioQ Qf ei.-Xy Qe.~.ays wrhich m<sses the issue here. ~he ssl'~ isx? t crhether th.xe i<ere =-arly Qe3.ays in the pxoceeding. The glxesMczl " 8 E'li1ether. Mle ZQtozvexlox EXQs gcQe ~xoxwax'0 5'i'.s ev".c~ence oz not Th second thing is that Z recognized and X tzied to"get recognition in my ra~iaxks earlier Qa'- ve had this agreed stat~went O2 .=acts, bvt this agreed statement. o Zacts is 83.mp~v Mat. 4W2e ~N"--i: appears in ~z's te i+on@. And 's hat in cLIQ oa itself 8oesn Got Prove any'i~i@ That is; the -"irst thing Zt t20esn 't Dzove Gnp'653,Qg~ o
\ '7 AQnoa.lpga occur ences if E'ce can sg ange i h" ng fEQHl this hearing g .'L4 3.Q than'. M~noi.~ila3. Gccvz'rences in nu~u5ers Goes not per se Grove KYjBlingo Then;aha~ a-e:re left withe H are Left. 4i-'4 We fach tha'- either Nr. Garner mus" caine in an" prove something
'k~iUR them or on cross K~cbitl.nation he must prove sod cBLng <~i'm,them. Ax?Q aha< X said '8RQ that given that tc&leg he hasn'5 done any of'har. inc ~hat the final business Mahout if' rras interested in speed X l7ould agree 4o what, he and ".ir. Po;<el~~ agreed to; if he srill pull out.th t stipulation @here Nr. Pouell agreed to the 'cive-Gay for indings: he trill fa>Q -'hat my signature also appears on it.. X also agreed to thaa Sable ~ hing that 5~& ~ PGwell agreed 'to and X agreed "o eve~thing that both of those part"'es ag eed to, 40 speed on these proceedings ~ CHUi.P2PZT BEXLLY: X Con't recall the Staff agreeing to five day submissions. NR. GibYiPR: He agreed for Hr. Power and X ho agre~> which divas noble of him. CHAXPZiU1 3EXLTY: X don'i. have i" right in front of me, but as X recall, the Si:aff Bid not endeavor k~R. TOURTBT.T;~i'E: X have to mv left a copy of
.heat stipulation ~8.ich in the left. side bears Nr. Garner's signature md on th right s:de hears Hr. Powell's signature.
.~id u'zde~weath Kr. Garner's signa'cure is one az ~~ps p.
'"QurGQ2,10'4'i G~
i.~Z. CZ lw~JPR: L6.=.~v Z reQd fraN your c'QpyP M~~ er l2 under procedures says: 'Ureter Xntervenor 'ad PEA agree aha propos'd indings af face and conclusions of 2.am ~id.ll he ~i" ed five d ~ys ef e th z cord is clasede CHZ~X%~~21 R" XLLZ. Hell, what. is my =.ecallectian. T1Mc is Uh88 X 9'Rs Qferr~ ng QQ X c1" dn t UL".~3 Qil the Staff had agreed 8a a five-Gay p=riad af filing. MR. TOURTZLLOZTE: Xf there is any question, it w~ certainly incended mat the B~aff aould do vhht-ever the other parties dido 2nd @~i'rankly, X intend to file canine earlier tJxan <ive days, if Mat is necessary. CHAXRKQT HEX~7 Y: The reason tha~ X guesrian is that the Staff usually does have a kanger -'ima ta file its f"ndings ~ NR. TCURTBLLOTTE: 'rate don't intend to tme lo ger. ;Te intend to do it quicker. 5$ . GhBHZP.: X would like to r'ebut one ching he seido Vhe zGRsan chey Rgreed 'to 'Hle stan'G3lellw af facts ua short; as it +as is"because 'cheir attorney, Mr. caner 'ha is conveniently'hsenc t..Bay would not-'hjjee ta
485 bazh7 any fuzthe agreed state>rent of "acts. A~a Nr. Podell and X s c~cc'7 ilo GGBS 6 " n hG and 'eing rcQGQQ M'L ze gaizd3.P g aP22Q Ba1 occurz'ences ~ CtRXi81t9l K+ZLXZ 'e13. g X 888 no pazticul&~ proQ 1ciQ Pith the agz . ed fata 8TilBQt of facts or an%'oint 3.n puz-si~" ng that azgu7i'cent fOrth' iM agreed RtateEBnt of acts f can covoz all or part of the facts 3.r.volving a ~articula case and maybe 3USL Q sHla11 part But in any event, Nr. Poi7e11, Bo you have any closing statemeetP HiR,'QViZMr-." Zes, siz;- Z do. TVh. supports Hxe- Staff's motion to dismiss, oz 3.n the alternative, the ar.otion for authori"ation for&wit'2 for the'lant. to l3 pezm'tted to operate. X th't Dk Z would lDie 'i 0 clazi xp'. couple 0'f things ~ I have had it has been t,iy es~erience on this case that Nz. Garner, particularly ox late, has been vary cooperative in getting together ~it+ the stipulation and aazemaent and mov3.ng cl28 CQSG fO wardo But it has also been my experience that the Regulator+ Staff has Queen Gcfua3.lp's cooperative 3.n Hlov3.ng the case ~ O~7a o. And X c"on't xecali having had to rea2.1y pzcd the Regulatory'taf or t32e Staff lawyers to move foz;sard 2<3 on the p oceed9.ng Z thincc we are ice~zing at Fir. Garner's prepared
486 te. timony -:shirk income='a'=as hy reference rhe agreecl state-
'Trent Of facts Which is 3'Dpeliciz l GBd cbpQen8iz 2 Of TUiX s pFGpm~"GQ te$ iKQny o 1
i~&c". Z th9.lsd. xt:Ls obvious Chat >Mose RppenQices 80 nowivg lroze than 8escrihe hear 2lSCX categorizeQ. ahno~ma2. Occurrence reports anQ also lists in a tahu3.ar form the l nmabers Of occurrences at each p3.ant. J. ti'nk me Staff is exactly correct hj'aying th81C 83M BvBze listixlg of those nJNSers in M16 Of i'".sel'roves nothing as to the confMenc of any utility. Or plant 0~war Gr Ope tor in the tat)les Oxl the contrarJJ g Klere, hM hepn no factual Gvi dence< no Opinion offers at al3. tvhich mouM support the as' smllption that is implicit ..n Contention 2 that nothing more that nothing'more than Fixe numb r of occuzrhi'ces is a cri-
'erion <<Or judging dze confiQence.
N the contra~, both..t>e Staf~'s testhnony
~
On anQ TVs Ges'-imony points out clear3.y'.WaC that is not a proper \ c"iterion for juaging confidence. vou 300k in M . Garner's direct case, you can find no facts which create a genuine issue of material fact. K Q X can fina no argument, no conclus'ons, no expert opinion Ch<lt 7'109M support Contentions 2 c~QQ 3e Z appears to lie thaw ve c~~not s 's" ae the requirement'-. v~inr the rules oz practice a>at the Xn ervenor
-"87 bara9 here NQVQ fozURrQ %7ith his 33uzclen.
One could approach Uu.s hea ing vii.h the at itude QQ ~x, l nGQGG, c e ante venor IDovecL zozk~MrQ g ~he ~ VP>> Gn8 the St~:"- cvouM have nothing to "o at all'.until h moves Zoz-ver ~ ~AIQ rebuttal is ~ecTQxzcQ ~ Hca'78vsr p there have 586xt thouscQQs g Rt leRS'n
'cho part of TVAp literally thousands o:~ m~~.hours invested in this hear'ing in analyzing ~~is HSC: material, in jrepezing this tes t2.alon J" O'.9 sure che sallM is true for the Regula-corjj Sea% '
So rather than uait on rebut al; <<he 0'calf anQ 4 TVZ~ have come in anQ ~r'th a rather impressive ~mount of evi-c?ence and testimony, in my opin" on, which establishes clea ly that there is W~so3.utel'J no merit whatsoever to the Xnter-venor 8 contcnti Gn 8 ~ Given that, X Con't see ~shy ve neeQ to continue to
~ ~
invest that monpomer into moving on and. Grafting those finding of ~~acts ani conclusions oK lax when they can be so. easily stpPeQ here cn the raco 8 as iD Tourt813.otte has stateQ t an~ you, ~>~z. ghai~a CHRXR~JM RET.LLY: Thawed you, Mr. Powell. Let s tr0%6 Q 10 .minute recess 23 (Pece s.) HQAg I 25
C~ TPJ'cj))T P~TLL The heazipp~~oom ~gill please OGBle ~ to orQ&ze pL~ a 'uztello'r te: eolith regard to 'ciie Staf f " s mot3.on P~i si??iss < dphil G'the BQM.o sees nothing in t le rules that Ucuad prohibit the QBLMZ< act 3.on p 'Ne find that there aze Nany t:~ca~'.ical P facts <<5 this no'.z +air3.y lengthy zecozc; and some of the~~ are s)-~~ptible to varying intezozetations. The Intervenor shou~ d have +)8 ODY:ozt~<<" ' to 0 ex'is inte MGtations -"n t)he fozN of proposed findings~
~ale Qisli.CG attempt" ng to zel'lJ on oux'8$ 0r its as
'o all the pzecise cletai3.s no@ on the record that may or may not hear on the content3.onse. f
~
'Zhe proposed findings submission schedule that the parties have xeferred to vill assist in seei..g that any delay vill net he substantial The last point X would li1:e to mention is that Chere is a recent case in the D. C. Circuit Court of Appeals in which Chiex Judge Bamelon mote the opinion. Xt's the case of iKGschl336an against HECT A 8 s c h 1 i 21 a Qg aga3nst DRC, in .:rhich Chief Judge Baselon gave some opinions that cast doubt on <whether RQ intervenor Rctua11y ever has any burden of going 2'ozvzard in our MRC licensing proceedings.
t".'G eon't g've any opinions on just how faz we thin.". Chief Judge 3a~elon intended to go miih that line, hut
.-..e Qo think that anv hasty action on th part o2 a licensing
yl 80 boarcl m~ granting a sulmary Qispositio>> in a case such as chis x'".ere vie have an "-viclentiary record no-;i comp'tetep lie 4%0 thiÃicc that Pigb'i 3."Lvite Some vazvinc'i 'L 5'~~.c.pre c ~BY~iODs 'chat
~
might hav. the eventua3 e +eat of. Outting hack on sane of the zuies thac xse novi operace under," aid iie Ron't thirc yie >-:ou3.cL necessclzi>y '.fane c 0 invice hat type 02 glPAR:i 02 Rl acc'oi1 c ~ 7 I 80 o'e ze go2 Dg to QM'y the llloGiol'l ~or sU~MBazy Ol CiMilissala The BoaZQ BOGS ccianC a3te Cene-"it 02 i lie Oa~~la>>. l PZOPOGelR fic ELQi Klgs CO he SQMitteQ hy 'CL'le PGZ 2 GS ~ Do ~.-ou have any ca3.embar elates thac lioral in with K>le 8'cipu t.ation'D 4 che 5 ccavGP PA POLKLT.. Be+ore yie get to thcctp 5M~. Chaizlhanp X think the a.otion chas macle in the a3.teznative, the alterna-t2ve heing authori=ation for the m~ its to operate j.z the Dwot2.on to Q2.GB2.ss 'r'ieze clen2.CQ $ 0 that '818 Un'c ts coUM proc886 on< hc~'Ting haQ establish68 the eviQentiary record nONe {'She BomQ con&rzing.} CBMK~KVB BHXLUZ: Wel2.: ~re see the difference, or zathe he Gistino"ion, that you ma3:e in the moi=ion for a1-Eeznative relic~. Ne think it's a distinction Mihhout a Qiffezexlce~ Ne yiculc" - ather LYtcQc.e a cteciQion havixlg co 'to T'iitk ice sv.2e operation OZ She p'tan haseQ upon the reoozc3. tha" noes ezist '. 'L'>6 'io authorize operation noep again hased, upon 1 some Xiii 0:0 a Gu.c"P="y actionp ~.18 cion t thinlc Kfoulct Jive Kiell
clgQ a5iise8. eke 6<: a Cher QO an CVc.tea CiOn Qf >..he ".~Q. 'QrQ af ter SL;Mp. i88ion C '~le PrOPQSGQ "
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is 'o SLL+A3.'t fLPQings T'D.~chin S GayH of the close 0: &19 hea'> xng g so it MOQ16 Qe Qays. ):rc'K zowig or the 16'& ~ l IIP.. GBZ'.BR: 2hai 8 th agr c-,:ert- -hai= the Zntervenok anQ '.CVih have. X -soul@ la3<e to get. it into M~e reco~Q if yo~c're, nnjnn 'ro iai n s]8. P.n i:hg+ aalu'&(giant
&B,. TOUPEE=LXiQZTP.s T. mpect. to Pile ray findings on Friday 'he 13i-.h.
CEL~KZP'82? REX'.7~'Zi Priday the 13chP iK. G2GcHZRz Pie haVe no objections to yo;~x .~iling yes on Friday the 13th.
'KKXBVi~27 PY"ZlZ': How, shall me consider che sevrice by mail and the effect that night have~ Bill that.
eR>entR things thee QQy87 MR. POTW~LLs Z am going to, when min are ready, QDQ X Kfpect, P7A ~7i12. he axQa3.ng Or ZriQap g,fe re going i 0 6 1 ~:er thm1 to Ãr. Garner and co th Sheafà and 'co ti~e Ctmi~n and. bw~. Shon in Washing on on that. Bay, the day'ha'hey re zeacLyg %7hich vzil3. probablv J3e Pri8c~p So we 'H-" 11 Gelivei= thea personally. CKVBY'4'> REiLL~'" They ~sill he delivered on Friday? KR, PClKEL: Ves, sir. CHLZM&~T 3L'IiZZ: Do you wan'c Or. Coven'8 aMressr
il gg pQ)QQT~ ~ X coq't j;roar th~~;re'll sent' passenger hack 'co ~~'.e~rr Yor?s. CC)g'PgT ~Zoll DRve Zap BC'328S s ~ X ft Qie 88 fing2xnQS Can he fil 8 on Pziday, 'chis mil3. make i~ possible'p obably foi= che Boax'6 to consiOex them in U~e n:.L ~m~z. MR. 2OTTHLL: Perhaps X cou3A get arith Dx. Co~ran 1fte?- l're BQ3 onz'D Bwl 88$ z Ghetto s B Qea. R)y 'helecopiel.; he cQQse X 'el OUzs ~irill be sQZ:.iciently shoz'6 'a"hat Ue can telecopy i.h to h~>a. CDAHR':Wf BH. L'E". * ~ X=';ron't really present ~~~y pic t ical pzodl&il D>ecBU se Ue have copiK s in the Qff-"c col '.'re 3.l 58 'L>QFking in the off'.ce lfxl:13, Dx~ Cowan in Bethesda~ 71ell, ihen, both TVP and ~we Staff xi.2.l have fin6-ings in the hmas o. he BoaxQ hy c3ose of business'Pzic.'ay the 13thP HR. TGURTZLLOTTE: 'jres. CRKXEBX 3'"XiZY: And, iM. Gaznex., in V.e mai3. on P'-iday the l3th? 5P.. CPBQfZH: That.' days, isn't itP CHM>BIB'EXT~Y: Zes, that's xight. X don'c vane to cLlt. yoQ off on -he ~i'2~ l MR. GZZ~MP.s II . Pol;ell lrill halre nz- $4$ tia~ony no Phr +TQp<1 J~)14%
+O3.lowing i&nday, o~ the fifth aay.
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492 h1'~ 5 him. MR. i? Gv7EX X': v9.11 sei18 sQFieoM co p3.cubi leap PzoiA CR~QGZ'p QQQ 7'M Vl3.11 Leg ec~py 'i t'-o tj,e G~zz so that. 4 Qc~"i'G 3.K i.QC S&~~iG i=ay K".. Ga=re=- has it, reechy. ! . Q 'JOAN 11 C<i~3.%&'0 M>XX:XZ ~ ZI abc voa very rnxch Q8501858K1g 80 'ZB hM'8 Hsing'PZ~2iei". 0~383.5v~SQP (Ho z'- Gpoz.sa. } I. A11 rigid~, zaia hear'r.g 9.s tenn:na'-ei (:".nereupon, <<c 3:"0 p.m., "..he hea~'ag 9.n the i0 GDGvc. GExc2.'HGQ 8?P'ttez 77c~s Q~alcQXP8Q~~
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