ML19305A702
| ML19305A702 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/31/1979 |
| From: | Hebdon F, Novak T NRC - NRC THREE MILE ISLAND TASK FORCE, Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001240590 | |
| Download: ML19305A702 (63) | |
Text
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i NUCLE AR REGUL ATORY COMMISSION O
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IN THE MATTER OF:
THREE MILE ISLAND INTERVIE?T OF THC:1AS M.
NOVAK
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P00R~0RGN?L
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Place - Bethesda, Maryland
)
l Date -
Tuesday, 31 July 1979 Pages 1 - 63 4
1 1
l l
O
.eiepree :
'202'347 3700
)
l ACE - FEDERAL REPORTER 5. INC.
Official Reporters 8001240 444 Ncrth Cccitcl Street j
Washingten. D.C. 2CC01 l
(
NATIONWIDE COVERAGE DAILY
1 1
CR6242 UNITED. STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION
- - - - - - - - - - - - - - - -x 4
In the Matter of:
5 TIIREE MILE ISLAND 6
- - - - - - - - - - - - - - - -x 7
8 I_NTERVIEW OF TIIOMAS M.
NOVAK 9
Room 405 10 6935 Arlington Road Bethesda, Maryland Tuesday, 31 July 1979 12 1:40 p.m.
13 PRESENT FOR NRC:
14 FRED IIEBDON DAVID EVANS, ESQ.
15 WAYNE LANNING 16 i
,1 1
18 19.
I 20 i
21 0
22 23 24 Ace-Federat Reporters, Inc.
25
CR 6242 HOFFMAN t-5 mte 1 1
PROCEEDINGS 2
(1:40 p.m.)
3 MR. HEBDON:
Wuuld you stand and raise your right 4
_ hand, please.
5 (Witness sworn.)
6 MR. HEBDON:
Have you read and do you understand 7
the witness notification I've just given to you?
l 8
MR. NOVAK:
Yes, I do.
9 MR. HEBDON:
Would you please state your name?
10 i MR. NOVAK:
Thomas Michael Novak.
II MR. HEBDON:
What's your current occupation?
12 MR. NOVAK:
I'm an employee of the Nuclear Regulatory
)
13 Commission in the position of Chief of the Reactor Systems 14 Branch.
15 MR. HEBDON:
What was your position on January 10th, !
i 16 1978?
I 17 MR. NOVAK:
Same position.
l 18 MR. HEBDON:
How many people reported to you?
I 19 I MR. NOVAK:
Approximately 15.
6 i
MR. HEBDON:
To whom do you report?
20 l I
21 MR. NOVAK:
As of what date?
l l
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22 :l MP. HEBDON:
As of January 10th, '778.
23 MR. NOVAK:
Denwood Ross is my immediate supervisor.
2d MR. HEBDON:
What was his position?
Ace-Federal Heoorters, Inc. p 25 l i
MR. NOVAK:
Assistant Director, Reactor Safety, t
4 I
i l
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3 1
MR. IIEBDON:
Did Sanford Israel work for you on 2
January 10th, 1978?
3 MR. NOVAK:
Yes, he did.
q V
4 MR. IIEBDON:
Would you describe your employment 5
history, including positions held at the NRC?
6 MR. NOVAK:
Do you want me to describe them now 7
from my date of employment, as opposed to submitting my 8
professional qualifications?
9 MR. IIEBDON:
Just aIrief summary of your professional!
I 10 ?
qualifica tions.
1 II MR. NOVAK:
I took employment with the Nuclear 12 Regulatory Commission in November 1968.
I have held positions 13 in various departments within the regulatory body.
In March I4 of 1973, I was assigned to my present position as Chief of the 15 Reactor Systems Branch.
4 I
16 Prior to October 1968, I was employed by the U.S.
I7 Navy at a marine engineering lab at Ar napolis, Maryland,doing-l l
18 basically heat transfe'. related R&D work.
I had employment l
19 there for four years.
20 Previous to that, I worked for the Bettis Atomic i
3 21 Power Laboratory for a period of six years doing work in r(,,)
22 reactor thermohydraulic design.
23 I graduated from Rutgers University in 1958,- and I 24 l also have a master's degree from Catholic University.
Ace-Ferteral Heoorters, Inc.
l 25 l MR. IIEBDON:
Okay.
Calling attention to your memo l
^
li 1
mta 3 4
.1 dated January 10th, 1978, did you write that memo?
2 MR. NOVAK:
No, I did not write the memo.
3 MR. HEBDON:
Did you sign the memo?
,(J 4
MR. NOVAK:
Yes, I did sign the memo.
5 MR. HEBDON:
What did you do before signing it?
Did 6
you review the contents of i t?
Did you discuss it with anyone?
7 Or did you simply sign it?
8 MR. NOVAK:
I reviewed a pencil draft of the memo.
9 I first saw the memo as a draf t.
I spent a few minutes looking l
10 !
at it and I approved it for final typing.
Andthenwhenitwasj 11 in that state I signed it.
4 12 I had no discussions relating to the memo and its
()-
13 contents prior to its publication, none of any substance.
I i
14 may have mentioned to Mr. Israel, who was the originator, that 15 I thought it was an okay memo and that I approved it for final l
I 16 typing.
l 17 MR. HEBDON:
Is that a normal function of your job, 18 to prepare such a memo?
I 19 MR. NOVAK:
Well, I don't know what you mean by l
I 20 I
" prepare such a memo".
l I
I I
21 MR. HEBDON:
To sign such a memo.
Is that type of l
()
22 ] memo a normal function of your position?
'l MR. NOVAK:
Yes, it would be one of the positions.
23 J I
24 lj Whether or not I would do it exactly in the way I did, if I Ao-FMerat Rmorten, lnc. {
25 would participate in the final presentation of the memo, i
l i
i
mts 4 5
4
-1 depends on ' the ciiginator of the memo, the substance of the 2
memo an'd so forth.
All memos of that nature -- I may treat 3
one memo different from another one.
And I've related to you q
c V
i 4
specifically how that memo was treated.
5 MR. HEBDON:
Did you consider the content of that 6
memo to be of particular significance?
7 MR. NOVAK:
Ne, I did not.
What do you mean by 8
"particular"?
I felt it was significant enough that. it should
}
9 be brought into our review process, and that's why' I approved i
10 i it.
It was a review reminder.
l I think we're talking about a memo, but I've yet to 12 see about what you're talking.
So maybe we ought to be sure 13 we're talking about the same memo.
I4 MR. IIEBDON:
(IIands document to witness.)
i 15 MR. NOVAK:
Yes, in this case I read it, I thought it l
was a basis for going forward with it as a review reminder.
l 16 l
I7' MR. IIEBDON:
What did you have in mind should be 18 done with the memo?
i I9 I MR. NOVAK:
It should be provided to every reviewer l 20 in the branch, and he should incorporate the substance of the 21 memo as necessary and as applicable to any case he was going
)
22 l to review, a case being any operating or CP application.
23 MR. IIEBDON:
That he would review in the future or 24 l that he was in the process of reviewing, or that he had i
Aca me,.i neuorrers, inc. p 25 '
reviewed in the past?
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1 MR. NOVAK:
If it was possible to put it into the 2
process, go ahead and do it.
It turned out I had no discussions I
3i with any. specific reviewer as to whether he should implement it
'. (_s) 1 4
at that time or not.
In fact, there were no discussions prior 5
to.TMI-2 incidenturelated to that memo by any member of the 6
staff and myself, my staff.
7 MR. HEBDON:
What corrective actions did you have 8
in mind for the CP applications that were to be reviewed?
9 MR. NOVAK:
Well, I didn't really have -- the memo i
-I i
i 10 1 was intended to be what I would call first investiga'ory.
11 When I signed it, it was a memo that suggested we perhaps 12 should be looking into this area to better understand the basis 4
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13 for the spe cific design configuration, and.after we had obtainedabetterunderstanding,subsequentdecisionswouldbel 14
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i 16 So I really hadn'.t thought about what would be the l
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I 17 outcome of the memo, only to the point that it was a memo that l 18 I supported for including in the review process.
l i
MR.- EVANS:
Let me interrupt here.
You said that l
19 l l
20 l you generally -- the level of discussions necessary depends 21 on each memo, including the content and from whom you received i
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22 the memo.
How did Mr. Israel figure in that decision?
When 23 you received memos from him, you generally believed the matters 24 were important?
l Am FMerM Hnerters, td.
25 '
MR. NOVAK:
Well, let me say it this way.
I regard I
mta 6 7
1 Mr. Israel as a very senior engineer.
I trust his judgment.
2 So if he suggests a technical issue, I would generally go 3l along with him.
In other words, I trust his judgment and I js 4
don' t specifically try to make an independent judgment.
So if 5
a more junior person would have suggested an area like this, 6
I might have suggested that it be discussed with a section 7
leader.
But since Mr. Israel also serves as a section leader, 8
I didn't see a need to have a real technical discussion.
9 So when I say it varies, it depends upon who writes 10 '
it and the impact.
I did not recognize the impacts to be 11 large on the review process.
In other other words, one of the 12 thoughts in mind was, we operate under standard review plans,
()
13 and within the f ramework or the intent of the standard review 14 plan, did I think this area of investigation was permissible 15 within our own charter.
In my mind, the answer was yes, so l
l 16 we went ahead with it.
17 And I also informed Mr. Ross, by sending him a copy l
18 of the memo, that we intended to look into this area as part 19 l of our review process.
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20 i MR. HEBDON:
Did you consider formally incorporating ;
i i
21 the contents or the intent of the memo in the standard review l
()
22 l plan?
I 23I MR. NOVAK:
Not at that time.
I think in all fair-24 it would depend on what the review would bring out.
If
- ness, Au-Fecal Recorters, lrc.,
25 l the review suggested an area, then perhaps a modification of I
mto'7 8
1 the standard review plan was warranted.
Basically, what I f
mean by standard review plan, I felt that the concern or the 2
area that was being suggested for further review was in the 3
(_/
4 general framework of our area of responsibility.
So while I 5,
didn't go into any specific standard review plan to see if it 6
fell under that umbrella, I felt that in general we had the 7
freedom to pursue this area within the general guidelines of 8
the standard review plan.
I 9
MR. HEBDON:
Did you consider the possibility of I
10 '
conducting more extensive consideration or review of this 11 issue without actually having it related to a specific case,
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12 doing it more on a generic basis?
()
13 MR. NOVAK:
No, I did not.
14 MR. HEBDON:
Were any plants reviewed subsequent to 15 the memo to which it would have applied?
l i
16 MR. NOVAK:
Well, as I recall, there were two B&W 17 plants that were possible candidates.
One was the Midland i
18 operating license application.
And I ' m no t s ure, but I think I
19 '
possibly I might have thought also that the Belfond plant j
i l
20 l application for an operating license was also a candidate.
I 21 may be wrong in that Belfont was a very early OL app: aation, l
.(-)
22 q so it may not have reached that process.
But to my recollec-s.
23 tion, there was probably only one candidate B&W plant that we were currently reviewing, and that was the Midland application.!
24 I is A&FMaM HnWfm. Inc.
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25 l MR. HEBDON:
Do yoc know if any actions were taken l
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9 I
on the Midland application?
2 MR. NOVAK:
All I have found out, the information I i
3l have is only subsequent to the Three Mile Island event itself, nO 4l in discussions with Mr. Scott Newberry, who was the assigned 5
reviewer to the Midland application, and Mr. Jerry Mazetis, 6
who is his section leader.
I had some brief discussions with 7
them out of interest as to whether or not a question had been 8
developed based on that memo.
9 Their recollection at first was they thought they l
had developed the question.
They went back and looked at the l
10 '
1 11 i
questions that did go out.
It so happened that Midland was a l
1 12 plant that we had assigned for assistance with the Idaho EG&G pQ 13 people, who have a technical assistance contract with us.
Id They were assisting us in that specific case review.
And from 15 my brief discussions with Mr. Newberry, he indicated that he 16 i
did not find that a question relating to the memo in the l
I round one questions -- his recollection was that he and l
17 l
18 Mr. Mazetis probably had concluded that they would ask it as
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19 l part of their second round of questions.
i 1
l 20 l I don't know much more than that at this time.
1 2I l
MR. IIEBDON:
Would it have been a normal procedure j
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22 ll for them to ask that as part of the round two questions rather l
4 23 l than asking it as a Q-1?
j i
24 l MR. NOVAK:
It would have gone in at the earliest
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Ace-Federal Hmorters, Inc, j 25 ;
opportunity.
It more likely should have gone in round one.
I i
i i
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It may have been that the round one questions had already been 2
asked when the review reminder was published.
I don't know.
3 It's my understanding that when we provided assistance mate-4 rial to the EG&G people assisting in our review that we gave l
5 them copies of the standard review plans that we utilized and 6
we gave them copies of other branch review reminders.
7 I dor.'t know whether or not this specific review
~
8 reminder was in that list of supporting information.
9 MR. HEBDON:
But they actually developed the Q-1 i
l 10 '
questions?
11 MR. NOVAK:
The original Q-1s were developed, when l
12 we had a potential conflict of interest suggested to us by the
()
13 OELD group, because it came to our attention that EG&G had at 14 some earlier time,;another area of the EG&G company had done i
15 some meteorological work for Consumers Power, who was the I
16 applicant in this case.
And the legal advice we received was l
t 17 that it would be to our benefit to remove the possibility of I
i 18 conflict of interest by not using them as a reviewer in this I
19 I case.
20 i So we went back and did sort of a re-review of what 21
' work they had done and our own 0-1s and provided them as the
()
22 i Q-1s.
So in effect, our decision was not to utilize EG&G in l
23 the Midland case as part of the review team.
24 MR. HEBDON:
So the questions were actually sent out l Au Federal Reporters, Inc.
25 by us, then, based on the initial work that was done by EG&G?
4 i
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MR..NOVAK:
Right. To my knowledge, based only on 2
some preliminary discussions from Mr. Newberry, he did not i
3 gg find'a quettu, which could be associated with the concern V
i 4
that the review-reminder was suggesting.
5
.MR. HEBDON:
By your understanding of the intent of 6
the memo, if a question could have been developed before the 7
Q-1s were sent out, then it should have been?
8 MR. NOVAK:
That's right, and it would have been.
9 MR. HEBDON:
But you don' t know the date that the I
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Q-1s were sent yet?
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MR. NOVAK:
No, I don't have that information.
I II I
I2 MR. HEBDON:
Okay.
Did anyone in the Reactor Systems O.Q 13 Branch raise any additional concerns as a result of the memo?
14 MR. NOVAK:
Not to my knowledge, not to me personally,.
i 15 MR. HEBDON:
Was the matter referred to anyone in e
I 16 DOR?
17 MR. NOVAK:
No, it was not.
l 18 MR. HEBDON:
Do you know why not?
i I9 !
MR. NOVAK:
I can only give you my own personal l
20 At the time I did not recognize the memo to have reason.
2I the significance we now can associate with it.
It.was a memo 22 that I just judged to be something we wanted to add to our 23 review process, and although I never did specifically think
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24 l about DOR in deciding on what distribution it should have, I i Ace-Feceral Reporters, Inc.
l 25 just decided that it would be sufficient-to provide it to all f
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'l members of the branch and to my immediate supervisor, letting 2
him know what we planned to do.
3 MR. HEBDON:
Then the actions that are contained in 4'
the memo recommended for OL review and procedure review, you 5
didn' t feel that that was necessary on the operating plants?
6 MR. NOVAK:
Well, we don't traditionally review 7
operating procedures.
I didn't spend that much time on the d
memo.. I of course now have spent a lot more time reviewing 8
9 the substance of the memo.
I 10 !
We have never really been -- we don't incorporate
{
II emergency procedures as part of our review.
We have had 12 opportunities to read copies for information.
We have made 13 decisions based on knowledge that we obtained through meetings, 14 just. procedures from selected plants, let's say.
15 I guess the point was that whatever was in the memo j
l 16 I felt would go on through the normal review process and as I7 the review proceeded, if there was a need to become more i
18 specific with regards.to an emergency procedure, we would have 1
I9 pursued it.
But I did not give it that much thought: at the 20 l time I' signed the memo.
21 MR. HEBDON:
Who would normally review emergency l
/T
..g 22l procedures as part of the licensing process?
23 l
}-
MR. NOVAK:
It depends on what you mean by review.
24
-i Of course, now we ' know that as far as the technical evaluation,;
Ace.rece,.i see 4rm, inc.,
25 l the suitability of the procedure to properly mitigate the i
l l
mta 12.
13 1
accident, no' member on the staff really reviews it.
It's my 2
understanding that I&E traditionally review the procedures, 3
one, to see that these procedures'indeed did exist at the site;
' (~l l
4 and, two, they may have -- and this is my own personal 5
understanding --' have reviewed the procedures to see that they 6
were correct in the sense that if valve designations were 7
included, indeed the valve designations were correct.
8 It's also my understanding that the-operating license 9
branch used -- in fact, this was generally our source of the 10 !
procedure, if-we wanted one, was to ask the operating license l
11 branch for one.
And it's my understanding that they use these l 12 as a basis for either developing examinations for operators e~
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13 or testing operators' awareness of the procedure.
So it was a 14 base of information that they did not really review for techni-15 cal adequacy.
16 MR. HEBDON:
With the hindsight from the TMI-2 l
t 17 accident, what significance do you assign to that memo?
I i
18 MR. NOVAK:
Well, I think it certainly pointed out I
19 i an area that we did not consider in the sense of our reviews.
l l
20 It suggested then the need to carefully look at what an opera - l 21 tor would do in the event he saw certain information displayed
-(-s-)
22 l to him and what possible actions he might take.
23 Obviously,.I think in the total view, the memo, if 24,. implemented in its totality, could indeed have prevented the Aw-FMeraI Retmrters Inc..
I 25 l Three Mile Island accident.
I l,
mta-13 14 I
MR. HEBDON:
You mentioned the idea of what the
- 2 j
operator would do.
Prior to the Three Mile Island accident, 3
p, was there any consideration given by your reviewers to such V
4 things as what the operator would do when faced with certcin 5
indications?
6 MR. NOVAK:
Generally, no.
We don' t -- what we 7
have traditionally looked at is how early in an accident is 8
an operator required to take an action.
By that I mean, if 9
we review systems and we realize that an operator action is l
10 !
necessary,ourreviewshaveconcentratedontheamountoftimef II that should be available to an operator to take an action.
12 We really don't get intt even the specifics of the action, 13 4
but only to agree that af ter so many minutes -- and let's use i
I4 ten minutes as an example -- it may then be assumed that an 15 operator could take a corrective action.
I 16 This is one area that we have included in terms of I7 operator actions in our review process.
There have been occasions, at least one, where in looking at the design for
[
18 performing manual actions, we reviewed or had available to I9 I us the procedures that identified the number of steps that the !
O d
i 21 operator would have to follow.
And this review then suggested 22 the complexity of the manual actions and suggested to us that i
.23 l there perhaps should be some automatic backup action to the Ace-Federat Reporters, Inc, h,l 24 operator.
25 !
i In this sense, this is the way we have been
_, _ _ _. ~ -,...., _.. ~,..,, - _., _.....
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' associated with operator actions and procedures.
2 MR. HEBDON:
Do you know if anyone else within the 3
NRC does review the plant designs and the various scenarios.to,
I, )
I 4
try and decide what the operator would do when confronted with 5
a specific set of conditions?
6 MR. NOVAK:
I know of no one on the staff who has 7
that responsibility.
8 MR. HEBDON:
I'd like to go on to discuss the 9
incident that occurred at Davis-Besse on September 24, 1977.
i i
10 !
MR. EVANS:
Could I interrupt just for a minute?
11 Fred, for purposes of the record, I want to make it lear that 12 the memo we have been talking about up to this point is a memo
()
13 dated January 10th, 1978.
It's a note to RSB members from I
14 T.M. Novak, subject, loop seals and pressurizer surge line.
15 It's signed by Thomas M. Novak, Chief, Reactor Systems Branch. i i
16 And I think this is the same memo that Mr. Novak has earlier l
i 17 identified.
l l
18 Now you can go on.
I 19 MR. HEBDON:
Fine.
20 ;
Prior to March 28th, 1979, which is really the area l
i 21 that we're trying to focus on in this particular grcup, what l
l
'(-)
22 g; knowledge did you have concerning the incident that occurred I
23 at Davis-Besse on September 24, 1977?
24 MR. NOVAK:
Well, there have been at least two Ace-Federal Heoorters, Inc.,
25j incidents that people have talked about with regards to l
1
mto 15' 16 i
Davis-Besse.
If the incident on the date-you quote in 2
September was the incident where there was -- where the plant i
,f-)
3l was operating at relatively low power, 9 or 10 percent, as I Gr 4
recall, and there was a transient initiated which resulted in 5
the power-operated relief valve opening, closing, and even-6 tually staying open for several minutes, followed by a rupture 7
of the quench tank and a blowdown in containment -- is that 8
the --
9 MR. HEBDON:
Yes, that's the incident, j
10 '
MR. NOVAK:
Okay.
I was familiar with it at the i
11 time.
We had a member of the staff, my staff, participate in l
12 a trip to the site with other members of the Division of
(")%
13 Systems Safety.
We studied the event.
It's my recollection x_
la that a trip report was prepared related to the event.
It was 15 -
-- the staff did, in my mind at least, put in a certain amount j l
16 of time in the review of the incident.
We did have a member l
17 in the branch participate in that review.
j l
18 MR. HEBDON:
Who was that person?
I i
19 MR. NOVAK:
Jerry Mazetis.
l l
20 MR. HEBDON:
It's your recollection that he did 21 prepare a trip report?
Q 22 MR. NOVAK:
Yes.
It was my recollection he
(,j 23 {l 1
coordinated some -- a variety of reviewers.
We had an 24 {. interdisciplinary review group participate, A*rens anonni. inc. '
and Jerry acting - ;
i 25 also being a section leader, coordinated the review to a I
i t
a
mts 16-17 1
certain degree.
And zus I recall, he was responsible for 2
preparing a trip rep ~ ort.
3 MR. EVANS:- Could we obtain a copy of that report?
4' MR. NOVAK:
Oh, sure, yes.
It's public information.
5 MR. HEBDON:
How did you acquire the information 6
about une event?
How did you become aware of it in the first 7
place?
8 MR. NOVAK:
Well, my recollection is we would 9
probably. have received one of these preliminary notifications l
t 10 '
from I&E.
I don't know if we had a licensing event report.
11 I don't recollect exactly how we were informed of it.
But we l
L i
12 knew about the incident.
I think we knew about it early enough
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(,j 13 that the trip was arranged within a few weeks of the event, so 4
14 it was done in a reasonably timely fashion.
15 MR. HEBDON:
Do you recall attending any sor t of a i
}
16 briefing by I&E or any other group prior to the trip to the 17 site?
18 MR. NOVAK:
I don't recall any.
There may have been !
19 1 one.
I recall a meeting.
It's my recollection that the 20 {
meeting that I recall was one that followed the trip.
So when i
21 the people returned, we had a meeting wherein additional j
(m
.22 ' members of the staff were informed on what was learned from es_
23 the trip.
24 MR. HEBDON:
Okay.
What would have been your j
A& FMeral Remners, Inc. '
I 25 responsibility cn: your function with respect to the analysis E
mto 17' 18
~
1 of that particular incident?
2 MR. NOVAK:
Well,-the incident, of course -- it's a 3
unique incident, so let's just broaden it and say. we do
(~)'
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4 review inadvertent power-operated relief valve openings as an 5
anticipated transient.
So let's assume it's our responsibility 6
to review a. transient which results in a power-operated relief 7
valve opening.
8 So from that point of view, our review of the 9
incident would at least be to conclude that the criteria that l
10 I we set forth to be acceptable consequences of that incident i
11 were not violated.
In other words, no fuel damage occurred l
i 12 as a consequence of that incident.
()
13 MR. HEBDON:
What did you do with the information 14 as it relates to the specific incident?
15 MR. NOVAK:
Well, I don't recall exactly whether l
16 there was anything specifically done in terms of modifying 17 requirements on the plant.
My general recollection is that 18 we didn't do anything about the event, because from a Reactor i
19 i Systems Branch point of view it was acceptable.
It did not 20 j have unacceptable consequences.
21 MR. HEBDON:
With the exception of the one. report
(_~-)
22 q that you referred to that Mr. Mazetis prepared, did you see L
'l 23 { or discuss any reports produced as a result of the investiga-24 !
tion or analysis of the incident?
Ace reu i nnmem. inc. !
i 25 l MR. NOVAK:
I only recall that it's my understanding I
I t
-mto 181 19 1
I recall that the licensee may have submitted a report which 2
supported his basis.that there was no~ fuel damage.
So whether
.3 it was an I&E report'or a report prepared by the licensee,
('-)
that may have been the only other piece of information I 4
5 recall related to the incident.
6 MR. HEBDON:
Do you recall any analysis of those 7
reports?
8 MR. NOVAK:
No, I don't.
9 MR. HEBDON:
Concerning some of the specifics of the l
10 !
incident itself, did you realize at the time that steam formed 11 in the reactor coolant system during the transient?
12 MR. NOVAK:
I do not have any recollection of
[m!
13 recognizing that fact.
~J 14 MR. HEBDON:
If you had recognized that, would it 15 have been of concern?
Would it have been an issue that would i
16 have been significant to you?
17 MR. NOVAK:
Well, it's hard to say.
Having a void I
I 18 by itself is not an unacceptable consequence.
If the void I,
I l
19 1 collapsed ibecause the plant was repressurized, that would have 20 l been an acceptable consequence.
I 21 We do analyze transients where, even though there's I
(')
22 l no fuel damage, there may be some voids in the reactor coolant l
x-23 ' system generated during the transient itself.
So from that 24 point of view, having a void form that was there but subse-Ace Fecerof Fleporters, Inc. l 25
'quently collapsed due to repressurization or cooling of the-l i
e 4
-n
-m gy
mt@ 19 20.
I steam would not by itself suggest a strong concern.
It would 2
depend on how the plant behaved at the void.
3 MR. HEBDON:
Did you realize at that time that the rs t
t
)
4
. pressurizer level increased while the leak was continuing?
-5 MR. NOVAK:
I don't recall whether I knew that or 6
not.
7 MR. HEBDON:
If you had realized that the steam 8
formation was causing the pressurizer level to go up while 9
there was still a leak from the plant, would that have caused j
10 !
you any. concern?
11 MR. NOVAK:
Say that again?
l 12 MR. HEBDON:
If you had realized at the time that
(')
13 the steam formation in the primary was causing the pressurizer
~
14 level to increase while the leak continued, would that have I
15 caused you any concern?
i i
16 MR. NOVAK:
It probably would have.
But I'm using 1
17 a lot of the knowledge and reference to the Three Mile' Island l
18 incident.
I don't recall us ever studying small breaks i
19 specifically in the steam space of the reactor coolant system. l I,
20 l A variety of small breaks were studied and I don' t know j
l I
21 specifically whether or not -- it's very difficult to actually j
()
22 model the lt.*el in the pressurizer.
But I don't know speci-23 fically what significance we would attach to a rising pres-l 24 surizer water level with a small break.
Aw.rew e num mes,inc.
25 It would be difficult today to say what we would have
21
. mte.20-
~ l
~done. 'Our judgments-now are flavored with the Three Mile 2
Island accident.
3, 3
MR. HEBDON:
Did you realize that the operator
. k._)7 4
secured the high-pressure injection pumps before they iden-5 tified or isolated the leak?
6 MR. NOVAK:
I would say that the staff knew it at 7
the time.
We had reasonable -- I think one of the purposes 8
of the trip was to identify all of the actions that the 9
operator took.
So in my judgment, that information was known
.I H) '
to the staff.
I don' t recall that information right now.
II MR. HEBDON:
Do you know of any specific individual 12 who knew of that!or is that just your hypothesis that somebody 13 must have known?
Id MR. NOVAK:
We did try to investigate the scenario 15 to know what the operator did do, to know the sequence of 16 events.
I would expect that what we know would be. reflected I7 in the trip report, the substance of our knowledge.
l MR. HEBDON:
Would that have caused you any concern l U3
~
l 4
I9 if you had known that the o. arator did secure the HPI before 1
20 f identifying the leak?
21 MR. NOVAK:
Not necessarily.
It would have to
(
22
. depend, again -- if the action he took -- and again, we would 23
. have to. recognize that we were not that close to operator
.24 actions. -This is an action, if indeed he took action to keep
,. Ace-Fedefal Reporters, Inc.
25 the pressurizer water,-the pressurizer fro'm going solid, in l
i 1
r
me 211 22 1
his judgment, it would have seemed to us to be an action that '
2 had some merit.
3 Since we were also concerned about pressurizer water 7sb 4
levels or the plant going water solid -- so to say it depends, 5
I'm saying that we could understand why he might secure the 6
high-pressure pumps.
I don't know specifically the level of 7
concern that knowledge would have created in our minds.
8 MR. HEBDON:
Okay.
9 MR. LANNING:
Does the Reactor Systems Branch have l
i 10 '
the responsibility for reviewing LOCA analysis?
l 11 MR. NOVAK:
Yes.
12 MR. HEBDON:
Did any or all events that occurred at
()
13 Davis-Besse during that incident raise any concerns in your 14 mind with respect to the accident analyses or the operator 15 training or the adequacy of the plant procedures?
i 16 MR. NOVAK:
No, they did not.
Did you consider at all what would have l 17 MR. HEBDON:
I 18 happened if the plant had been at a higher power level or had i
19 !
had a greater power history?
i l
20 i MR. NOVAK:
I don't' recall any discussions as to f
i I
21 what the potential consequences mig.t have been from higher
.( )
22 power.
I would not have been surprised if there was some l
discussion about that point, be cause it.would have been an 23 24 important consideration.-
I just don't recall those discus-
- A&FMasl Rewrrers, lrm.
I 25 '
sions.
l
N mte 22-23 z
1 MR. : HEBDON :
Do you normally assess what-if type 2
analyses of transients or of incidents that' occur?
~
3 MR. NOVAK:
Yes, we do.
f';
l
'~'
4 MR. HEBDON:
So you would have expected that sort of 5
an analysis to be done for this particular case?
6 MR. NOVAK:
Well, analyses.
Let's say we would 7
have considered whether the transient would have been of a 8
similar nature if it had been initiated from a higher power 9
level.
Our judgment must have been that the transient was i
10 '
acceptable, would have been acceptable if initiated at a higher:
11 power level; the point being, is that inadvertent opening of 12 a power-operated relief valve is traditionally analyzed from
()
13 100 percent power.
So the fact of a power-operated relief 14 valve being open and you initiate that sort of event from 15 100 percent power; our analysis that the applicant is required i i
16 to submit supports that there is no fuel damage.
17 What's difficult to analyze at this time is the I
i 18 relationship that the operator played in securing these pumps. !
19 !
I think it's fair to say we really didn't concentrate much l
20 time reviewing the specific actions, and indeed, whether his j.
l 21 actions could have been so improper as to suggest the need for j
(;
22l changes.
23 I don't recall that any changes were made.
I've i
24 been told since that the licensee did add an indicator of some A&FMmt Humners,1v.,
25 sort to the power-operated relief valve to show indication.
i l
l 1
=
mte 23 24 I
It--was my understanding when the incident occurred that there 2
was no indication available to him as to PORV position.
He 3
subsequently had a position indicator.
-s v
4 But this is information that I recall since Three l
5 Mile Island accident.
6 MR. HEBDON:
One of the other things that the 7
operator did, that the licensee did, was that he redesigned 8
the valve so that it would fail shut on loss of control power.
9 MR. NOVAK:
I'm not aware of that.
l 10 !
MR. HEBDON:
Okay.
Did you consider any of the i
events that occurred during this incident to have generic l
Il 12 implications to other plants?
, g) 13
(,
MR. NOVAK:
Well, in the broad sense, I'm sure we l
14 did, in the sense that we recognized that Davis-Besse was a l
15 plant that had characteristics similar to other B&W plants, i
i 16 The fact that we found the event in that sense acceptable meant 17 that we tought it was an acceptable event, I'm sure, if it 18 would have happened to other plants..
19 l We did not recognize anything unique to suggest that 20 i this event would be intolerable to a diff,erent plant.
>l 21 MR. EVANS:
Let me be clear that your definition of
()
22 l an acceptable.trancient is one where there's no fuel damage.
23 MR. NOVAK:
That's correct.
24 MR. EVANS: And if your analysis of the Davis-Besse
' Ace Federal Heoorters, Inc.
i 25 incident showed.that there was no fuel damage, then you would
smta 24 25 g
not draw generic conclusions from the accident?
2 MR. NOVAK:
Well, we analyzed the event.
The i
3 l operator took certairs actions that we were aware of when we f)
i 4
reviewed the event.
We did not review'the event to sort of 5
conjure up, suppost the operator had done something different.
6 What we looked at was that the event occurred, the operator 7
took certain actions, and in our judgment the consequences of 8
that event were acceptable.
9 I dbn' t think we just -- the way you phrased the j
l 10 !
question would suggest, well, if that event was acceptable, then i
11 we leave it alone.
No, I think we did more than that.
But we 12 did not uncover any portion of that event which suggested to f'T 13 us at the time of the event that there should be an additional j d
14 analysis or some safety concern of generic consideration that 15 should be raised.
3 1
16 Perhaps if you asked your question a little i
i 17 Jifferently, I can answer.
But I think I've got the substance I 13
't your question.
I think I've tried to answer it.
19 j MR. EVANS:
You did get my question.
l 1
i I
20 i MR. LANNING:
Whel. you say you do an analysis, just 3
I i
i 21,. exactly what do you mean by an analysis?
j l
()
MR. NOVAK:
We ourselves do not perform the analysis, 22 23' but as I recall, if you have an event if this nature, then 24 the applicant must provide an analysis that shows he did not A&Fenal Hnwrters Inc. !
25 violate a safety limit.
This is in support of his ability to l
l I
mta 25 26 1
restart the plant. -So he must. demonstrate to you that that 2
event is within the events that are traditionally analyzed in 3
chapter 15 of the FSAR.
/~'h I
\\_/
4 So cur analysis was, in effect, a review of his 5
analysis to suggest that there was no fuel damage as a result 6
of that event.
7 MR. HEBDON:
But the fact that the pressurizer level 8
increased due to the steam voiding in the primary, that would 9F not be an issue that would trigger an analysis?
I l
i 10 !
MR. NOVAK:
I don't recall any major discussions -
11 that I'm aware of with regard to that specific phenomenon.
I l
l 12 think, taking it separately, that behavior would not be --
I l( )
13 would not suggest a new phenomenon to us.
I think we could 14 understand why there would be a rise in level, if indeed you 15 have a steam space small break.
So the initial swell in the i
i 16 pressurizer, for example, would not be a behavior that we would' 17 not have been able to understand from a thermohydraulic point 18 of view.
I
.I 19 l MR. HEBDON:
Did you have any awareness or any l
I 20 !
perception ofthelevelofknowledge.oftheoperatorsconcern-l r
l 21 ing the status of the plant during the incident?
For example, [
[)
22 i do you have.any feeling for whether or not they realized that s-c 1
23 the. reactor system pressure was approaching saturation pres-24 !, sure?
t I
Ace-Fateral Remtrers. Inc.
25 l MR. NOVAK:
I don't recall any knowledge.
l l
1
mto 26 27 1
MR. HEBDON:
Did you attend a briefing by 2
~ Jerry Mazetis concerning his trip to Davis-Besse following the 3
September 24th incident.
f-U 4
MR. NOVAK:
I think that's the meeting or briefing S
I do recall.
6 MR. HEBDON:
Okay.
What do you recall concerning the 7
content of the briefing?
8 MR. NOVAK:
I would only recall that it was basically
'9 a discussion of how the event occurred, the equipment that had 10 '
failed, some of the end products of the event, of the fact j
II that there was a large amount of debris in the containment 12 sump.
I think what I recall from the discussion are more of
()
13 the equipment malfunctions and the end product of the event.
14 There were some things that were observed in containment e
15 following the event.
There was'some debris.
There was some i
16 insulation mater 2al that was torn off from one of the steam 17 generators in the proximity of the quench tank.
And I recall I
i 18 some discussions about those kinds of things.
1 19 MR. HEEDON:
De you recall any discussion of the i
20 dynamic effects of vapor formation in the reactor coolant i
21 system?
.()
22 MR. NOVAK:
No, I don't.
23 MR. HEBDON:
Do you recall any discussion of the 24 what-if's of possibly having the event occur at higher power A&FemW Remrters, lm.,
25 l levels or with more power history or with additional failures?
l, i
mts 27 28 1
MR. NOVAK:
I don't recall any specific discussions,-
2 but there may have been some.
i
'3 I MR. HEBDON:
What actions were taken as a result of r~)
l k./
i 4'
the briefing?
5 MR. NOVAK:
I don't know all'the actions.
As far 6
as I recall, in terms of the Reactor Systems Branch, we did 7
.ot take any sube'.yuent actions.
There was no change in our 8
review process that I can recall which came about as a conse-9 quence of the Davis-Besse incident.
l 10 '
MR. HEBDON:
Do you know if anyone else did anything i
11 as a result of the meeting?
I i
12 MR. NOVAK:
I don't know.
. ()
13 MR. HEBDON:
Did anyone else give a presentation at i
14 the mceting?
15 MR. NOVAK:
Well, there were discussions, and I l
l 16 would imagine that other participants who made the trip n
17 discussed certain areas in their own expertise.
I don't i
18 recall anyone else specifically.
l 1
19 l MR. HEBDON:
Did anyone prepare a written report at i
'20 i the meeting?
l I
e-6 21 MR. NOVAK:
Of the meeting?
I don't know.
I) 22 MR. HEBDON:
Do you know if there were any other
\\_/
23 l subsequent meetings concerning that particular incident, either 24 I that you attended or that you know of?
Ace-Fedtral Reporters, Inc.
25 '
MR NOVAK I don't recall any.
l
mto 28 29 l
1 1
MR. HEBDON:
Did you ever discuss this incident or 2
.any of the issues raised by this incident by Joseph J. Kelly I
31 or Bert Dunn or any other employee of B&W7 7
- -(s j
l 4
MR. NOVAK:
No, not to my knowledge.
5 MR. HEBDON:
Were you aware of their concerns about 6
the September 24, 1977, incident?
7 MR. NOVAK:
No, I wasn't.
'8 MR. EVANS:
Did you have any contact at all with 9
3&W regarding the incident?
I 10 MR. NOVAK:
I don't know if we did or didn't.
We may; I
li have.
But I don't know.
To be honest, I can't recall whether l 12 anyone had discussions with B&W.
We visited the site and I
()
13 did not participate in the site visit, and I don't know to the 14 extent that anyone had discussions with B&W.
l}Eb'lkTN
- 15 MR. EW*MM:
What is your perception of the relation-i 16 ship between the I&E regions and NRR, either.as it specifically 17 relates to this incident or in general?
18 MR. NOVAK:
I really don't have any specific comments!
t 19 l We don't normally deal with the regional offices.in my 20 activity.
Our dealings are usually with the headquarters, and ;
21 so I don' t have any specific comments regarding your question.
( )
22 MR. HEBDON:
Would you have found it unusual for a 23 technical type person in one of the regional offices to contact 24 f you directly?
Ace-Metal Heoorters. Inc. ;
25 '
MR.'NOVAK:
No, I have had occasion where'they have l-.[
\\
mte 29 30 I
called.
I don't know.
There must have been some occasions 2
prior to Three Mile Island.- Generally the discussions were of, 3
in the nature of, I have this concern, I'm wondering if you're
(_.s\\
\\
U 4
the right person to be talking to.
Generally you come away 5
from a discussion like that -- well', if you want to follow it 6
up, you should follow your norm,1 channel.
}
7 If there was some information that that person 8
conveyed to me that I thought w1s something we should have 9
looked at, then I would have generally -- I guess I would say I
10 '
L.at the concern would be something beyond which we would, say,j lI traditionally review.
Or we may have known about it and would i
12 conclude that it was not a concern that required an action by
(
13 our branch.
14 But if this gentleman felt that it was something 15 which should be pursued, then I suggested to him that he should !
I l
16 follow his normal channels for making his concern known.
I 17 guess they' re not that of ten that I can specifically tell you I
18 how we hanaled one of these.
But generally, people may call 19 and they're not sure you're the right person to be talking to.
r 20 l If you are, you may understand their concern.
You may tell l
21 them how you're handling it.
l
)
22 It may not be consistent with what they think is the 23 answer.
So you may then suggest to them, if you feel your j
24 l concerns merit further attention, J
you should follow then.. up Ace Federal Reporters, Inc,l 25 l through your own channel.
It's very difficult for us to deal
~!
1 i
.mts 30 31 1
individually with regional people.
I think we probably_ deal 2
more efficiently through the headquarters organization.
If I
3' there was a concern from a region, I guess I assumed that it 4
should go through the region to the headquarters, and if it's 5
something that headquarters feels should be pursued they would 6
make it officially known tr NRR.
7 MR. HEBDON:
Why
.o you feel that it would be 8
difficult to deal directly with the regions?
t 9
MR. NOVAK:
Well, one, we don't work with them on a t
10 !
daily 1 basis.
We don' t have access to them.
We don't have Il access to them.
We don't meet with them.
I don't know what l
12 they do, so to speak.
I know they're there.
I guess it's n(,)
13 my judgment to treat the regional I&E people as basically 14 people who are inspectors, and I'm not so sure that they are 15 in tune with all of the work that is going on at NRR on a 1
16 subject.
i 17 So from that point of view, I would think it's a l
18 little more difficult for us to do it.
It could be done.
It 19 l isn't very efficient, is what I'm saying.
l l
I 20 )
MR. HEBDON:
Do you feel that NRR is particularly i
21 well attuned to the concerns that they have?
22 ly (m,)
i-MR. NOVAK:
I don't know.
I think it would be l
23 j difficult for me to decide whether NRR -- as I've said before, i
i 24 I I have had a few phone calls and we've probably ended up in em FMeal Regmrters, inc.
25 i effect recognizing the concern, making sure that we understood 1 I
i 1
I e
I n.
mt131 32 I
it, and then asking the fellow -- it may be -- I' don't recall 2
any specific actions that I took from an.v specific discussion 3
with a regional I&E inspector, although I wanted to make sure (3_)
4
- that I didn't want to cut his concern off.
So I would suggest 5
that if he didn't believe that the answer I gave him was 6
satisfactory, he should by all means pursue it through his 7
normal channels.
8 MR. HEBDON:
But for that concern to reach you, he 9
would have to take some action on his part to request that it 10 '
be forwarded to you?
There was no routine flow of information 11 back and forth?
l I2 MR. NOVAK:
That's correct, that's right.
I think
- ()
13 what I needed was some formal representation of concern that 14 in my mind then should come through.
I don't really think that 15 I ever thought about whether it should be a regional office i
i 16 concern or it should go through headquarters.
Implicitly, l
17 I must have thought it would go from region to headquarters, 18 and then there would be a decision yes or no to pass that i
l9 concern on over to NRR.
l 4
MR. HEBDON:
Okay.
I'd like to go on and discuss f
20 f 21 the Michelson report.
Excuse me.
r~g 22 MR. LANNING:
Before we leave Davis-Besse, if the
(,j 23 transient at Davis-Besse had resulted in exceeding the safety 24 1, limit,:how would it have been handled differently?
Ace Fedetaf Reorters, Inc. '
25 l MR. NOVAK:
Well, the design would have had to have I
i
33 7;nts 32 1
been modified.
Now, I'm not going to say -- let's assume that 2
the event was handled unacceptably and there was some fuel 3
damage.
Then there would have to be an analysis made of a V.
4 revised design, which could have been procedures for this case.
5 I'm not going to say that equipment modifications would have 6
had to have been necessary.
But certainly we would have had 7
to see a-reanalysis to support why, a revised chapter 15 8
analysis, in a sense, that would suggest, now, if this event 9
did occur again, there would be no fuel damage.
10 !
MR. HEBDON:
When you refer to a safety limit, what f
11 sort of thing are you talking about?
What kind of order of 12 magnitude are we talking about?
What are examples of the 13 kinds of things that would constitute safety limit?
14 MR. NOVAK:
If a calculated departure from nuclear i
15 boiling ratio should go below a value which has a 5 percent 16 chance of resulting in fuel failure, it's one safety
- limit, I
17 would be probably the one that would be challenged most by f
I f
18 this event.
19 !
That suggests, then, thatifyourlocalheatfluxes-y l
20 !
and this is a statistical evaluation -- were comparable to i
21 those that had been demonstrated from tests to be sufficient tol
)
22 cause clad overheating, that would be a safety limit.
You 23 would be in violation of a safety limit.
24 MR. HEBDON:
The fact that the reactor coolant system; AceJ ederal Reporters, Inc. ;
25' pressure approached saturation pressure, how close is that?
mto 33 34 1
MR. NOVAK:
There is no safety limit.
There's a 2
safety limit that the reactor coolant pressure should not 3
exceed 2750 psi.
/'N j
')
l 4-MR. HEBDON:
But nothing on the low side?
5 MR. NOVAK:
There is nothing on the low side..
6 MR. EVANS:
You mentioned before that you thought i
the operator at Davis-Besse acted properly by trying to prevent l 7
8 the system from going solid.
9 MR. NOVAK:
I'm assuming that the reason they did j
i l
lo s cut back was that that was in the back of their minds, that, l
11 given the level was going up in'the pressurizer, and assuming I
12 that they felt the system was solid all over, the reason they
()
13 would cut back is not to have the pressurizer go solid and have 14 liquid relieved to the safety, since that's been a concern and i
15 Operators are trained in that sense to prevent the system from,
l 16 going water-solid following ECCS actuation.
I G.vA N.S 17 MR. EB999N:
This is in spite of the fact that you
}
18 recognize there can be voids in the reactor coolant system?
{
i 19 MR. NOVAK:
When you say when we recognize --
l l
20.
MR. EVANS:
You've discussed this before as part of I
21 the accident.
-fD l 22 MR. NOVAK:
I said that it wouldn't surprise me in s_L 23 some of the scenarios that we have reviewed that there would 24 !
befsome voids in the system that result as a consequence, but AwFeast Rnertets, lrc.
j 25 l that those voids are analyzed and considered.
And traditionally l
mto 34-
'35 i
- you have an.ECCS system or any other engineered safety' feature
-2 syst'em, that. is capable' -- the system is capable then of miti-
~
./~1.
3 gatingLthe consequences, even though there may be a void'in l
'V 4
the system.
5 A void by itself does not necessarily result in 6
unacceptable consequences.
It depends on how large the void 7
is and a number of other things.
8 MR. HEBDON:
Would you claborate on the differences 9
between safety limits and limiting conditions for operation?
I 10 1 MR. NOVAK:
Limiting conditions for operation, these 11 are traditional terms in the technical specifications.
The 12 number of ECCS pumps that are operating, for example, is a A)-
I 13 limiting condition of operation.
The amount of equipment 14 that could be had for maintenance, for example, is one of the 15 limiting conditions for operation.
MR. HEBDON:
Is the limiting condition for operations
~
17 synonymous with margins for safety?
I-18 MR. NOVAK:
I don't know.
To me, I just haven't l
19 thought about it.
I don't have an answer to that question.
20 MR. LANNING: ' Are you primarily concerned with
.f ~
21 safety limits in your licensing activities, or do you also
()
2 [ focus on maintaining margins, operating margins for safety? -
2 1
23 MR. NOVAK:
Both.
Obviously, we're concerned about-24 safety limits and we're concerned about the margins that exist i
I Aa-reasi nnerm, ine.
25 to violating the safety limits -- equally;important.
4 1
mta 35 36 1
MR. LANNING:
Equally addressed?
2 MR. NOVAK:
No, not equally, obviously.
But of i
3 I more importance is that a safety limit is not violated.
The 7.()
4 fact that you don't violate a safety limit means that you 5
won't have fuel damage.
Now, there's certainly an important 6
consideration, but of less magnitude, to know what the margin 7
is to violating that safety limit. How far away you are from a i
8 safety limit is not as important as whether you have crossed
[
9 that safety limit or not.
10 '
MR. LANNING:
So you think that there's proper l
Il emphasis being placed on not exceeding safety limits, as 12 opposed to not exceeding limiting conditions for operations?
~r 13 MR. NOVAK:
Again, they ' re not the same.
14 MR. LANNING:
I know they're not the same.
e5 MR. NOVAK:
I think you have to pay attention to i
16 both.
The limiting conditions to operation is a measure of 17 the availability, in my mind, of certain systems to be availa- !
18 ble in the event of an accident.
A safety limit are those I
19 criteria which you set forth which you feel should not be 20 violated in the event of an accident or a transient.
So j
l 21 they're separable and they're different.
-l
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?2 :
But you are also talking about margins to safety 4
23 limits, which are neither limiting conditions of operation nor 24 l
a safety limit.
t Ace Federat Heoorters, Inc.,
25l MR. LANNING:
Okay.
I guess I don't understand why
.l 1
mta 36 37 l
1 evaluate margins, safety-margins, how they come into play.
2 MR. NOVAK:
Well, safety margins, they're qualitative 1
3 I in nature.
You review analytical dodes.
You ' judge that the 4
codes are generally conservative.
You may ask for an experi-5 ment where an evaluation is done both on a best estimate 6
analysis as well as a conservative design basis analysis, and 7
this is a measure of the margin, it's one ingredient in the 8
margins that can be summed up when you finally do an analysis 9
to see if indeed you have violated the safety limit.
I 10 1 MR. HEBDON:
You mentioned a few minutes ago about i
11 the fact that the operator action to prevent the system from j
12 going solid, that you considered that to be an appropriate
()
13 action.
What are the problems associated with a plant going 14 solid?
15 MR. NOVAK:
Well, it depends, of course.
If a plant ;
i 16 is hot, then brittle fracture of the pressure vessel is not a t
17 concern.
But on certain plants where you have a very high i
18 head charging pump, it would permit you -- the plant would go i
19 1 to pressure in excess of the safety valves and it would result i i
I 20 !
in liquid relief to the safety valves.
These safety valves 4
21 are not traditionallV designed to relieve the liquid.
So
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there is a question, after they have relieved, whether indeed I
they would close.
And if they didn't close, then you would 23 l i
have generated a loss of coolant accident.
l 24 Aasec i namnm. irw.
25 MR. HEBDON:
Why, then, aren't the valves either l,
I
mta 37 38
~1 designed so that they can pass liquid without damage or the 2
pumps designed with a sufficiently low shutoff head so that 3
they won't lift the relief valves?
4 MR. NOVAK:
Let's just start with the safety valves.
5 The safety valves are designed to ASME code requirements which 6
require, basically, that they have certain steam-relieving 7
capacity.
If you do an analysis which shows that, for the 8
range of anticipated transients for which these valves have 9
to operate, there is only steam relief, then there is less 10 !
reason to pursue how the valves would operate in the event of liquid reliefs.
]
Il 12 Now, there were certain accidents of smaller, less 13 likely probability, for which we have calculated that at least 14 a two-phased mixture or perhaps even a solid liquid fluid 15 stream would exist for things like steam line break.
It's my 16 recollection that we have given credit, because of the unlike-17 liness of that event, that there is no need to be concerned 18 about compounding the consideration of the safety valve i
l 19 l sticking open.
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l 21 it 'has a frequency of at least once in the lifetime of the
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22 plant,.you're then unnecessarily. challenging the closing 23
. capability of the safety valve to close after relieving water.
24
[
So it's tha't kind of judgment that suggests to you that it's 6
'. Ace Federal Reporrets. inc.
25 unwise to challenge the safety valves relieving liquid-I l
i E
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unnecessarily.
2 You may find it an acceptable scenario for a very 3I unlikely event, like a large steam line bree.k.
l V) t 4
MR. HEBDON:
Would that be inadvisable of the valves 5
were designed to. relieve water?
6 MR. NOVAK:
If the valves were designed to relieve 7
water and you had the same reliability whether it was reliev-8 ing water or steam, then there would really be no reason to 9
worry about the valve closing.
}
l 10 !
MR. HEBDON:
Would it be that hard to design them 11 in that way?
12 MR. NOVAK:
I don't know.
()
13 MR. HEBDON:
Why, then -- apparently there is some i
14 difficulty associated with that.
Why, then, don't they simply 15 use HPI pumps that have a shutoff head below the relief point i
16
.of the relief valves, safety valves?
I 17 MR. NOVAK:
Again, this is going back into design.
18 The staff does not design.the plants.
We don't know why a i
19 1 specific shutoff head is suggested.
There.are certain criteria 20 the staff has set forth, and if a design meets it, the specific 21 pump characteristics that are selected, as long as they are
.(
)-
22 adequate, is acceptable to us.
-23 Designs have changed in time, where safety injection
[
24 I pumps on 'certain plants do not have the capability of pres-Ace-Ferteret Reportets, Inc. I r.
25 surizing the system to the safety valve set point.
In the.
l l
i l
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case of Davis-Besse, these pumps are also charging pumps, 2
which traditionally must be able to provide makeup to the 3
plant while it's operating.
And I have not been that close f-U 4
to pump design.
But then it doesn't surprise me that before 5
the shutoff head of the pump is reached, you may be reaching 6
a safety valve set point at the same time.
In other words, 7
to provide an adequate capacity of makeup at 2250 psi would 8
still result in some delivery of water at 2500 psi.
9 These pumps may also be used at times for hydro 10 I testing.
So there may be another reason why they have a cer-11 tain head characteristic.
12 MR. HEBDON:
Is tnere some advantage to using them
()
13 for all these different purposes?
14 MR. NOVAK:
I would suggest there's an advantage only 15 because it results in less equipment if you have designs i
16 which permit a multiplicity of functions to be accomplished.
I 17 Obviously, the capital costs must be less.
I don't know.
18 MR. HEBDON:
Is it more of a cost consideration or I
i 19' is it more of a safety consideration to be able to have I
20 multiple function equipment?
21 MR. NOVAK:
I kould guess it's a cost consideration, n.
()
22 We have had some indication lately that the reliability, however, 23 may be improved'if the equipment is routinely used for both 24 normal and safety functions, and in systems that are just i
A<*Fufers Reoorters, Inc.
25 '
dedicated safety functions may not have as high a reliability
!l
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as a ' system that performs both a. normal startup and cooldown
~
- 2 function as well as being available for the safety function.
3 So it's not clear that you gain nothing by using equipment for j ie-7 4
normal operations, as opposed to having a dedicated system.
5 1
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MR. HEBDON:
Let's go on to the Michelson Report.
2 Mainly what I'm trying. to get at is what you knew prior to the 3
TMI accident, prior to March 28th of this year -- specifically,
,_s J
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prior to that date, what knowledge did you have concerning the 5
Michelson report?
6 MR. NOVAK:
I did not know of its existence.
7 MR. HEBDON:
Are you now familiar with the Michelson 8
Report?
9 MR. NOVAK:
I am aware of it.
I have not studied it.
10 MR. HEBDON:
Are you aware of how it arrived at the 11 Staff prior to March 28th?
12 MR. NOVAK:
I have been told, since the Three Mile
()
13 Accident, that it was made -- it's called a report, a draft of 14 some concerns that were passed on from Mr. Ebersole to, I think, 15 Mr. Israel.
I've become aware of that since the Three Mi.e 16 Island accident.
17 MR. HEBDON :
Would you find if very unusual that a 18 member of the ACRS would pass material directly to a member of 19 your staf f without your knowledge?
20 MR. NOVAK:
In general, yes.
It depends to a large 21
' degree on the person, his experience.
I think most people
()
22 would generally inform me of information that they have 23
. specifically received from the ACRS members.
24 MR. HEBDON:
Would you have expected Dr. Ebersole
' Ace Federal Reporters, Inc.
25 to have informed you that he had provided this material to one L
I' s
v
jl' 2 43 1
. of your subordinates?
2 MR. NOVAK :
No, I don't think I would have expected 3
him to.
Specifis --Aly, he may take time to tell me that he has
,,()
4 passed on some information.
I think he probably would have 5
assumed that the information was being distributed to people
-6 who should have an interest in it or who would have an interest 7
in the information.
8 MR. HEBDON:
Are you familiar with the concern raised 9
in that particular report doout the operators being misled by 10 pressurizer level?
11 MR. NOVAK :
No, I'm not.
12 MR. HEBDON :
You have not read the report?
()
13 MR. NOVAK:
I have not read the report in that detail, 14 that I can say dhat I'm familiar with that concern.
15 MR. HEBDON:
If the report had been formally submitted 16 to NRR for review by the ACRS, what sort of actions would have 17 happened?
What would have been done with the report?
4 18 MR. NOVAK:
We would have studied the report.
We 19 l would have determined if there was a basis for us changing any 20 of our review requirr'ments, any need for any actions to be 21 taken on operating plants.
I think I would have put the report I'T 22 sort of in context as.a minority opinion.
\\_)
)
-23 Somebody writes an opinion which suggests something 24 that may be different in the Staff's view or an area that we Ace-Federal Reporters, Inc.
25 have not traditionally reviewed.
And 'I think we would have
ji'3 44 1
reviewed it and studied it.
And if there were things that we 2
could have adopted that we would have pursued, I would assume 3
3
~that we would have gone through our R C and decided whether or 4
not any action is needed to be taken.
5 But certainly a formal response to the report would 6
have been prepared.
7 MR. HEBDON:
Based on your knowledge of the content 8
of the report, what specific conclusions do you think the 9
Staff would have reached concerning the report?
10 MR. NOVAK :
I can't say since I really haven' t studied 11 it.
I don't think I can make a judgment on that.
3 12 MR. EVANS:
Before that report got to the R C though,
()
13 your branch, and specifically you, would have to take some sort 14 of position on it, or would you pass it on and evaluate it?
15 MR. NOVAK:
No, we would make recommendations.
I 16 would be -- at least in the concurre. ce chain of those recommen-3 17 dations -- and they would eventually be forwarded to the R C at 18 the Division Director's level.
19 MR. EVANS:
Now, this is what I don't understand.
20 Your initial impression is that that report deals with a minor-21 ity opinion.
~T 22 MR. NOVAK:
I'm using that as an analogy, ar an (V
23 example only.
2,4 MR. EVANS:
As being different from standard Staff AwFeder:;l Reporters, Inc.
25 beliefs ?
jl 4 45 1
MR. NOVAK:
Yes, I'm assuming that the reason a 2
report is prepared is because there are some elements of what 3
the report is suggesting, which is different than what is
,m 4
considered to be an acceptable basis for issuing a license to 5
operate the plant, for example.
6 Without studying the report, I'm suggesting that the 7
report identified perhaps some weaknesses in design or some weaknesses in our review.
And as such then, I don't mean to 8
9 give it a flavor as a minority report, which we have to argue 10 down; I'm only suggesting that it would be treated perhaps a -
11 little differently than an ACRS report.
The ACRS has obviously 12 a stronger advisory role, but if the report was just submitted
()
13 to the Staff for information, then it would take on a different 14 substance or dif ferent flavor.
And I don't mean to suggest that 15 we would be out to disprove what the report was suggesting; I'm 16 just saying that it would have been reviewed in the sense of 17 identifying where the report -- where we are consistent with 18 the report in our review process, where our review process pp differs from what the report might be auggesting; and.we might 20 give reasons for either agreeing or disag.eeing with any 21 specific recommendations or concerns of the report.
+
22 I think that's probably the way I would have envision-
)
23.
ed the report being treated.
24 MR. EVANS :. And attached with your recommendations,
. Ace Federet Reporters, Inc.
3 25 it wouldJ have then -gone up to the R C?
ji 5 46 1
MR. NOVAK:
That's what I would conclude, yes.
2 If, for example, our recommendation would have con-3 cluded that there was merit to changing something, we would have
(_.s) 4 gone through R C to get support for changing our position.
3 5
Also, I think we would have gone through R C to sup-6 port the present position if, indeed, we did not find a basis 7
for changing it based on our review of the report.
3 The R C issues -- opinions that things 8
MR._ EVANS:
9 are fine 'as they are, and there's no need for further attention?
10 MR. NOVAK:
I'm sorry?
11 MR. EVANS :
It was my understanding from what you 12 just responded that if you believed the present system is 13 adequate, even in light of this Ebersole report, that you would 3
14 have then gone to the R C for, in some sense, a stamp on the 15 s tatus - quo, that you' re currently doing is adequate?
.l 16 MR. NOVAK:
That could have been.
If we judged the 3
l 17 report to be of that nature, that it merited R C, there 's a 18 certain amount of speculation in what I'm suggesting we would 19 have done.
But if we had endeavored to study the report, and if 20 it had the substance that I'm assuming it had, then we probably l
3 21 would have gone through R C to at least let them have an 22
_ opportunity to reflect any comments they would have on what we 23 generally concluded are the findings on the report.
24 MR. EVANS :
I just wasn't aware that the R C would Ate-Federd Reporters, Inc.
25 issued that kind of ~ decision, that the status quo was adequate,
I
jl 6 47
,1
~ even in light of this report.
2 Have you ever done that before?
3 MR. NOVAK :
I think what I'm saying is the. Division k
3 4
Director may decide that he wants to bring to R C a recommenda-5 tion that he 's making, that in light of the report he can find 6
no basis for change.
7 Now, I wouldn't find that totally outside the bounds 3
8 of what R C could do.
I don't have examples though that I can 9
easily quote you.
It could be that the decision is that the 10 status quo is okay -- for example, no backfit requirements on 11 something.
12 MR. HEBDON:
Does the ACRS normally, during their
()
13 course of business, transmit reports to the Staff formally for 14 review?
15 MR. NOVAK:
No.
16 MR. HEBDON:
Do you have any idea why the report was 17 transmitted to Mr. Israel in such an informal manner?
18 MR. NOVAK:
No, I don't know.
I can only speculate 19 that -- it's my understanding now that there was a B&W plant 20 under review at the time the committee was considering a B&W 21 plant, and perhaps this was an opportunity for Mr. Ebersole I ')
22 to pass on this information because it was' timely.
I really
\\s 23 don't have any. other comment to make on that.
24 MR. HEBDON :
I'd like to go on to the question that Ace-FederrA Reporters, Inc.
l 25 was asked by._ Dr. ' Ebersole in the course of ' the ACRS review of
jl-7 48 1
the Pebble Springs plant.
'2 Again, we ' re trying to focus on prior to TMI.
Prior
_q to March 28th,1979, what knowledge did you have concerning the 3
LQ 4
question raised by Dr. Ebersole of the ACRS concerning small 5
break LOCA analyses?
The question uas raised in the specific 6
context of the Pebble Springs review.
7 MR. NOVAK:
Well, my recollection is that when the 8
committee was considering the Pebble Springs application that a 9
set of questions was prepared by either Mr. Ebersole or someone 10 at the time when the subcommittee was considering the applica-11 tion.
I did not study the questions except to note that it was 12 my understanding that these questions perhaps -- at least some
()
13 of them -- went beyond what the Staff would normally require in 14 its re' 16w process -- for example, more than a single failure 15 being applied to an accident.
16 The questions, as I recall, were transmitted from the 17 committee through the Division of Project Management to the 18 Applicant.
The. Staff really did not, in that sense, do anything 19 with reviewing the questions.
They transmitted them through the 20 applicant.
21-When the responses were filed, there was some review
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22 of the responses by the Staff, just to know, indeed, what the 23 Applicant was able to respond to, how well he could respond to l
j 24 the questions.
And we wanted to basically be aware of the Am FMwd Reonm, lm.
25 information that was being placed on the docket.
And that's my j
jl E 49 1
recollection.
2 It was my recollection that the Applicant could not 3
give complete answers to all of the questions.
Some of the-4 information was not available at that time, but I do recall that 5
we were surprised at the amount of information the Applicant 6
was able to provide.
7 So in that sense, that was one of the points I recall, 8
that we felt that the Applicant made certainly an honest attempt 9
to be as responsive as he could in the time permitted.
10 MR. HEBDON:
Do you recall a particular question, 11 numbe r 6 ?
One part of that question addresses the issue of how 12 the operator would interpret pressurized level during this type
()
13 of an event.
14 MR. NOVAK:
I don't recall any parts.
I spent 15 little time reviewing the questions or the the responses.
Most 16 of it was done at levels below me -- Mr. Israel or Mr. Mizetis 17 would be the section leader, and were the reviewers.
18 MR. HEBDON:
Do you know which reviewer reviewed the 19 -
responses?
20 MR. NOVAK:
I don' t know.
It's my recollection that 21 Mr. Mizetis -- that the Pebble Springs application was assigned
(}
22 to Mr. Mizetis' section.
However, I do know that Mr. Israel 23 did attend some subcommittee meetings.
It may have been that 24 there was' sone generic discussions that he was more familiar Ace #ederal Reporters, Inc, 25 with, or what; but my recollection is that the Pebble Springs
s--
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2 MR. HEBDON:
Was there a meeting held within NRR to 3
decide what, short of a review, to conduct with respect to the D
4 response to the questions?
5 MR. NOVAK:
I recall perhaps a meeting with 6
Mr. Vassallo, in a sense to decided how responsive or what 7
position the Staff could take with regard to the responces to 8
questions.
I think it was only a meeting, as I recall -- or 9
what I do recall is that the meeting was to decide what official 10 position we could take with regard to these responses in the 11 sense of agreeing or disagreeing with the analyses.
12 MR. HEBDON:
What was the decision?
What was con-13 cluded as a result of that meeting?
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"p,P}g 18 with the answer if the Applicant said it was something we had 19 no independent way of judging the validity of his answer. Since 20 the analysis was not provided in any detail, we could not review 21 his work.
If he gave the results of his work, we were in a
)
22 situation where we could not either agree or disagree with the 23 accuracy.
It would not be that obvious that the answer is 24 wrong, or it would not be that obvious that the answer was Ace Federal Reporters, Inc.
25 corre ct.
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51 1
MR. HEBDON:
Did you feel you had any responsibility 2
to perform such an independent analysis?
3 MR. NOVAK :
I think the answer was no, since these
-]
i 4
questions were generally generated by the subcommittee.
And as 5
I recall -- I don't know if they were done by a consultant to 6
the subcommittee or not, but we really had, more or less, a 7
hands off policy with regard to the questions.
We had an 8
interest in knowing what technical information was obtained 9
because of these questions, but the answers -- we really did 10 not feel that we had a responsibility to follow through to the as 11 same detail -- if we had originate d the questions ourselves.
A 12 MR. HEBDON:
Do you know if any sort of a summary
()
13 was prepared of that meeting?
14 MR. NOVAK:
What meeting?
15 MR. HEBDON:
The meeting to discuss the Staff's 3
16 position.
4 17 MR. NOVAK :
I'm not aware of any.
18 MR. HEBDON:
Do you have any other questions in that a
- 19 q area?
20 (No response.)
21 MR. EVANS:
Let me just ask one question:
If the
)
22 Staff had been asked to respond to those questions or, to com-23 ment upon the responses of the Applicant, would the responses 24 have been that this is outside the normal questions that are Ace Federd Reporters, Inc.
25 usually asked?
52 gjl 11 1
MR. NOVAK :
That could have been an answer. to some,
J.
2 but it's difficult to say.
You'd have to study the response to 3
make a judgment as to what you could say about the response.
In
-)
4 other words, how' familiar are you with the details of the analy-5 sis that may have been performed in order to prepare the J
6 response?
17 So, it's not clear exactly what you could say.
If 8
you studied them, you might be able to say more in one area than 9
another.
10 MR. EVANS :
But your initial reaction, I'm getting, 11 is that when you first saw these questions propounded to the 12 Applicant, your rcaction was, "Those are tough questions to 3
13 pose, unusual questions."
14 MR. NOVAK:
I would say that's generally my recollec-1 15 tion, that these were questions beyond what we considered to be 16 design basis requirements.
17 MR. HEBDON:
Do you recall attending the ACRS full 18 committee meeting in January 1978 when these questions were 19 [ discussed?
l
-20 MR. NOVAK :
I don't recall being there, but I may have
-21 been.
)
22 MR. HEBDON:
Do you recall any discussion between A
23 Dr. Ebersole and PR&E concerning the question of how the operator p
24 would interpret pressurizer level.during these types of f,, Am-F, der t Reporters, Inc.
l
' 25 transients ?
-~.
jl 12-53 1
MR. NOVAK :
No, I don't recall the discussions.
2 MR. HEBDON :
Do you recall any -- his discussion of 3
the fact that the simulators that would be used to train the
(,_,)
4 operators would not accurately model these particular types of 5
6 MR. NOVAK :
No, I don't recall those discussions.
7 MR. HEBDON :
Okay.
8 Were you at a meeting on July 3rd, this year, with 9
Mr. DeYoung and Mr. Parler,here at Arlington Road, concerning 10 some questions about the Davis-Besse incident?
l II MR. NOVAK :
I was here.
I don't if, specifically, 12 that was the date.
But, yes, I did attend a meeting with p}
13 Mr. DeYoung where we did discuss this memo, relating to the q
14 pressurizer loop seal.
15 MR. HEBDON:
Do you recall making any sort of state-16 ment to the effect that there other memos or other significant 17 issues associated with the Davis-Besse incident that were more 18 significant than the issues that had been raised to date?
19 MR. NOVAK:
Well, I think_in the discussion I pointed j
20 out what we considered -- what we were looking for were issues 21 that we felt were important.-- for example, the amount of 1
(ts[]
22 debris that was in containment following the blowdown, l
23 specifically in the containment sump.
We were concerned about j
24 the fact that large pieces of insulation hnd been blown off
' Ace Federst Reporters, Inc.
25 one of the steam generators, and we were concerned about the
jl 13 54 1
ability, should this plant have had to go into a recirculation 2
mode in the event of a loss of coolant accident, whether there 3
would be an overabundance of debris that would preclude water
,_s I'~')
4 entering the containment sump without a large pressure drop, 5
with perhaps pump cavitation as a result.
6 MR. HEBDON:
Were there memos exchanged at the time 7
of the incident con.erning these various issues?
8 MR. NOVAK :
I don' t know i f the re we re memos.
I know 9
we had discussions between Mr. Mizetis and myself, and also 10 between the Licensee, where we after the far:t tried to find out 11 the chemical structure of the deposits in the sump and the 12 amount of it, for examp3e.
()
13 MR. EVANS:
Do you consider this accumulation of 14 debris in the sump to in some ways foreshadow the problem with 15 the pump pumps at Three Mile Island 27 16 MR. NOVAK:
The sump ptmps at Three Mile Island 2 17 are there only for normal operation.
We were concerned -- our 18 review responsibility is primarily with the adequacy of the 19 l emergency cooling system, and we were concentrating on whether 20 the design of the sump and the amount of material tha t was 21 determined to be debris from a rupture of the quench tank (m) 22 suggested to us that it was a point that we were looking at 23 to determine whether, indeed, there was the need to pursue 24 further the adequacy of the sump design.
Ace Feder:4 Reporters, Inc.
25 By comparison, the sump pumps on Three Mile Island 2
- ~,,,
jl 14 55 1
are used for normal operation, and we don' t even review them as end t8 2
part of our review.
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24 Ace Federal Reporters, Inc.
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CR 6242 HOFFMAN 56 t-9 mte 1 1
I have no comparison.
2 MR. HEBDON:
Do you know of any other precursor 3'
events that are relevant to the accident at TMI?
O(-
'\\
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4 MR.'NOVAK:
There was an event at Three Mile Island 2 5
that I was informed about by Mr. Silver, and he sent a memo to 6
me.
He transmitted some information to me that I subsequently 7
passed on to Mr. Israel for information.
It was an event i
8 where I think, as I recall now, there was a pilot-operated 9
relief valve opening.
4 i
Do you know approximately when the event!
10 '
MR. HEBDON:
11 occurred?
12 MR. h0VAK:
No, I don't.
Just to say that it was
,O(,)
13 before Three Mile Island, and not too much earlier than the 14 accident itself.
It may have been January of '79.
15 MR. HEBDON:
January of '797 l
l 16 MR. NOVAK:
I'm not sure of the date.
Doyourecallanyofthedetailsofthef 17 MR. HEBDON:
l 18 event?
19 l MR. NOVAK:
No.
I have talked to Mr. Silver and 20 he informed me that, since he was the project manager for l
21 Three Mile, that he became aware of it.
From his description
()
22 of the event, I thought there would be interest in our branch 23 knowing more about it.
He obtained for me a copy of a report 24 l that the applicant was submitting to Inspection & Enforcement.
,c.r --,, --, s.
25
.It was a 33-page report, and at the time that I received it I p
i
4 mts 2 57 9
i did~not feel that it was in my best interest -- I shouldn't 2
use my time at this time to review it or look at it.
So'I 3.
passed it on immediately to Mr. Israel in the sense of assign- )s.
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4 ing it to one of his people and, time permitting, to go ahead 5
and look at the report, if only for information.
l' 6
It was my recollection that Inspection & Enforcement 7
was not looking for any assistance in the review of that event, 4
8 and I did not assign any priority to the review of the event.
4 9
I just thought it would be something that we could, in some l
10 1 time frame, read and become more familiar with.
j i
11 MR. HEBDON:
How did you feel that that particular 12 event was a precursor of the TMI accident?
()
13 MR. NOVAK:
Well, all I'm saying about that is that 14 it was another event where you had a power-operated relief 15 valve blowdown.
That's the only relationship I'm drawing to 16 it.
17 MR. HEBDON:
The power-operated relief valve failed 18 '
open?
1 l
19 MR. NOVAK:
I think there was an electrical short or 20 something which caused the valve to open.
That's my recollec-21 tion.
(
k 22-MR. HEBDON:
Do you have any additional information 23 that might be relevant to our inquiry into the events surround-24' ing the accident at TMI?
Acz.Fedetel Reporters, Inc.
-- 25 MR.'NOVAK:
None that I'm aware of.
1
Cta 3-58 1
MR. '!EB DON :
Okay.
2 MR. EVANS:
Can I just ask you, you're not aware of 3
precursors at any other plants other than Davis-Besse and that
~~
A 4
one you've mentioned at Three Mile Island 2; is that correct?
5 MR. EVANS:
That's correct.
6 MR. HEBDON:
Any other questions?
7 MR. EVANS:
No.
8 MR. HEBDON:
Wayne?
9 MR. LANNING:
I want to talk a little bit about 10 !
safety grade and non-safety grade equipment.
On March 16th, 1
II
'79, a memorandum to Vassallo from Tedesco, naming you as a 12 contact, and concerning -- the subject is board notification
-( )
13 of recent issue on non-safety grade equipment.
14 What's been the staff practice or position with 15 regard to giving credit for non-safety grade equipment to i
16 mitigate transients?
17 MR. NOVAK:
Well, traditionally, for accidents we 18 have not made it a policy to give credit for non-safety grade i
19 equipment in our review of BWRs.
Specifically, with the 20 Shoreham plant, at least I became more aware that in the event 21 of certain transients the use of non-safety grade' equipment, (q
22 j.
credit was taken for it in mitigating the course of the 23 '
And we studied the problem generically with 24 General Electric for a period of over a year.
t Ace Federal Reporters; inc.,
- 25 l We thought that we had sufficient basis t.o know that
.l I
Cto 4 59 i
pressurized water reactors did not use non-safety grade 2
equipment, certainly not to the aame extent that the boiling
~
3 water reactors did.
However, we felt that this was an issue V
4 that there was a need for at least the generation of a board 5
notification, which is effectively the memo you're referring 6
to.
7 MR. LANNING:
Was there any one piece of equipment 8
in BWRs that you were addressing this toward?
9 MR. NOVAK:
Not one, but certainly what we considered l
l 10 to be one of the more important ones was what we called a level:
11 trip in the BWR, giving -- you had a feedwater malfnnction l
12 transient and you had a rising level.
This trip, this level
[~)
13 signal initiated subsequent actions which resulted in turbine e
ss 14 trip, reactor trip and feedwater isolation.
So it was in the 15 chain of events which were intended to mitigate the course of 16 that transient.
17 MR. LANNING:
What prompted this memorandum?
Was l
18 there any event preceding this memorandum that resulted in the l I
19 '
board notification?
20.
MR. NOVAK:
I don't recall any specific events.
I.
21 Operating events is what I'm assuming you're referring to.
f ()T 22 We've had several discussions with General Electric, with A~
23 certain utilities, applicants for OLs as well as cps, and it I.
I 24 i was our judgment that we had. to at least make the boards aware
, Ace Ferier:4 Reporters, Inc.
25 '
of the concern that the staff had at that time.
It was I
i r
i
cto 5 60 i
basically a policy that we thought we were following, 'an 2
Of fice t,Z Nuclear Reactor Regulation policy, which suggested 3
the basis from which you would decide that a board notification
(}.
t 4
was necessary.
5 We believed that we reached that plateau suggesting 6
that there was a basis for board notification.
7 MR. HEBDON:
Are you aware that when the board 8
notification went to OELD from Vassallo, that he included 9
l 10 !
MR. NOVAK:
That may have been, because I think as j
11 we got nearer the point of deciding that a board notification l
12 should be prepared, we were aware that at least some equipment,
(
13 but not to the same extent, with PWRs may be used, with some 14 PWRs, and we may have generalized the statement to include all 15 board, all boards, both PWR and BWR.
16 MR. LANNING:
So in general practice you do not give 17 credit for non-safety grade equipment to mitigate transients?
I 18 MR. NOVAK:
You can't say that we don't give credit, i l
I 19 l since we did determine that there were plants operating for l
20 i which credit is allowed in the sense that the analysis had l'
q 21 been submitted.
It was in this sense perhaps a change in what
'b 22 l the policy should be.
J 23 ll There's a question as tc whether it is as well known 24 to all members of the staff, to the degree to which non-safety l
Ace-FMml Reortm, Inc.
l 25 l grade equipment was being used in mitigating transients in l
i
mts 6 61 I
boiling water reactors.
2 MR. LANNING:
So'this memorandum, in effect, insti-3l gated a change in philosophy?
fqV 4l MR. NOVAK:
It didn't instigate a change.
It was 5
suggesting that there may be a change.
It identified that the 6
staff would be reviewing whether or not what the policy should 7
be for plants under review --
8 MR. LANNING:
Under review?
9 MR. NOVAK:
That's correct.
l IO '
MR. LANNING:
In looking at overpressure protection l
U during startup of PWRs,.ihat role does the pressurizer rel'ief 12 valve play in providing protection to the system?
13 MR. NOVAK:
Only after the staff required that these I4 certain modifications be made.
The power-operated relief valve would not automatically open.
The staff in the last 15 I
16 two years has required that certain design modifications be 17 made to preclude the challenges or the likelihood of violations 18 of Appendix G in the event of solid water startups or cool-19 I downs.
20 l What has generally happened as'a result of this is l
21 that the power-operated relief valve has been given a dual 22 mode set point, such that it could be set to relief the 23 pressures in the range of 500 to 600 psi, as well as relieving 24 i i
pressures in the range of 2250 psi.
Ace Federal Reporters, Inc, l
'25 MR. LANNING:
Is this dual range relief valve l
l
l
- 1m ts -
62 1
considered safety-grade equipment?
2 MR. NOVAK:
Yes.
The modifications to it would 1
require that it electrically be designed to meet single 3
j-.
-kJ 4
failure.
The valve itself is a seismic category one valve.
5 in terms of its pressure-retaining capability.
It would not 6
be required, however,.to operate following an earthquake.
We 7
concluded that the likelihood of having to design for over-8 pressure transients during startups as a result of an earth-9 quake of magnitude equivalent to that of the design basis I
10 '
earthquake was not necessary.
{
11 MR. LANNING:
Is the pressurizer level indicator l
12
.normally safety grade equipment?
i O) 13 MR. NOVAK:
I don't have any specific knowledge.
In
(_
14 our review of transients and accidents, we 've never relied or 15 had to consider a pressurizer level indication.
It's my i
j '.
16 understanding that they are not safety grade equipment, since 17 there is no specific transient, no specific accident that 18 requires control through the pressurizer level instrument.
i 19 MR. LANNING:
Let me ask you a philosophical question'.
s 20 Do you feel that there's been too much emphasis being placed
_ l pe,ded ?
21 on design bases lasting approach, as opposed to operational rm
. (_,)
22 transients and margins to safety type approach?
23 MR. NOVAK:
In_ hindsight, yes, I think we've probably 24 !
concentrated too much on the very_unlikely hut potentially i-ke-rems nnerm. sne.
very serious accidents, and have not spent enough time looking l 25
}
1 I
i i
atY 8 63 1
at the. variety of more likely events which, if combined with 2
.the proper failures, could result in consequences at least as 3'
serious as the design basis accidents.
)
4 MR. LANNING:
Why do you think we focus so much on 5
the design basis accident?
6 MR. NOVAK:
Well, it was traditional for us to think 7
that if we' considered these design basis accidents, they 8
represented an envelope of events such that we recognized you 9
could not study an infinite variety of transients or accidents, i
10 !
so you would have to identify what you considered to be an j
II acceptable bound to certain accidents.
So that in a sense, 12 if you could identify and, through the use of proper assump-(3 13 tions, divine very unlikely events and still have those 1
14 protected, then it was reasonable to assume that the more l
15 likely events, although more frequent and possibly of a differ i I
16 ent nature than. the ones that you traditionally analyzed, wouldl l
I7 not result in consequences more serious than the ones that are !
18 used as design basis accidents.
19 l MR. HEBDON:
Any other questions?
20 l MR. EVANS:
No.
l 21 MR. HEBDON:
Thank you very much.
That concludes l
rs
().
e. 722 l the interview.
23 (Whereupon, 'a t -3 : 25 p.m., the interview was concluded )
24 Ace Ferietal Reporters, Inc. I 25
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