ML19308C393
| ML19308C393 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/26/1979 |
| From: | Hanauer S, Parler W, Scinto J NRC - NRC THREE MILE ISLAND TASK FORCE, Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001230363 | |
| Download: ML19308C393 (75) | |
Text
.
J O
NUCLE AR REGUL ATO RY COMMISSION l
i j
l 1
i IN THE MATTER CF:
.i TIIREE MILE ISLAND SPECIAL INQUIRY DEPOSITION DEPOSITION OF: STEPHEN H. HANAUER (CCMT mVED)
.i 3
Place -
BETHESDA, MD.
Date -
l WEDNESDAY, SEPT. 26, 1979 Pages 185 -258 i
4 O
if-(
o r
(202)347 3700 t
i
/
ACE FEDERAL REPORTERS,INC.
OfficialReporters M4 North Capitol Street 8 0 012g pp Washington, D.C. 20001 NATIONWIDE COVERAGE DAILY
~
,n,
3 185 UNITED STATES OF AMERICA O
1 NUCLEAR REGULATORY COMMISSION l
i 3
8
)
x In the Matter of:
THREE MILE ISLAND 6
SPECIAL INTERVIEWS I
8 9
DEPOSITION OF STEPHEN H.
HANATTER 10 Room P822A 11 Phillips Building 7920 Norfolk Avenue 12 Bethesda, Maryland O
is weame aev seste eer 28 1979 9:00 a.m.
14 APPEARANCES:
15 For the NRC:
16 WILLIAM PARLER 17 JOSEPH SCINTO WAYNE LANNING 18 TOM COX PETER SICILIA 19 CHARLES 0. MILLER Members, Special Inquiry Group 20 For the Witness:
21 PAT DIXON, Office of the General Counsel, NRC 23
~24 Ace-Fotterd Reporters, Inc.
25 i
t
1 l
i.
i i
}
186 J
l l
eb 1
C O N_.T E N_ T.S I
i-l j
21 Witness Examination I
i I
l f
3l S tephen H. Hanauer 187 f
h f
(Continued) i t
41 1
l I
5, Exhibit For Identification i
i
[
i 6'
1149 Page 7 of NUREG 0050, 211 l
i l '.
l l
7j l
February 1976 BI I
9l I
i t
r i
i 10 !
l 1
i I
I 11 :
l I
i f
I 13 I
14 l
4 i
15 16 1
l 17 I'
l
~ 13,
-j
~
' 19 '.
l 20 1
21
\\
22
[
23
~
QJ 2,
Ace Federal Reporters, Inc.
125
..n..
187 l
l I
MPB/cb1 I
PEQQEEglEgg l
(/;.
\\-
2 MR. SCINTO:
Good morning.
This is a continuation 3 !
of the deposition of Dr. Stephen Hanauer.
i
(
4 Whereupon, 5
STEPHEN H. HANAUER l
l 6!
resumed the stand and, having been previously duly sworn, was l
7 examined and testified further as follows:
8 EXAMINATION (Continued) 9!
BY MR. SCINIO :
i 10 l Q
Dr. Hanauer, last night when we concluded we were 11 l discussing a document which has been marked 1148.
As we 12 !
discussed yesterday, it is a. document which is basically a j
i
()
13 compilation of more than one document, and I think you iden-14 tified the first seven pages of the document as--
Well, let 15 me not try to paraphrase it.
16 The first seven pages of this document you charac-17 !
terized as what?
I 18 A
The first seven pages of this document were trans-19, mitted to Chairman Hendrie in Pennsylvania and discussed by 20 him with the Governor of Pennsylvania.
21 Q
Okay, fine.
Thank you.
()
22 Now basically were these first seven pages --
23 A
I want to clear the record.
I want to say that l
l
( )t 24 over again.
l Ace-Federd Reporters, Inc.
l 25 Q
Sure.
Please do.
I i
l f
188 f i
MPB/eb2 1
A The first seven pages were transmitted from the 4'
("N f
'l Incident Response Center to Chairman Hendrie for the purpose 2
l 3i lof his using them to discuss evacuation with the Governor of O
-4 Pennsylvania.
I have to say it that way because I don't know 5
myself what he did with it.
6 O
Fine.
Thank you.
That helps.
i 7
A Off the record, j
8 (Discussion off the record.)
l 9,
MR. SCINTO:
Back on the record.
I 10 BY MR. SCINTO:
l 11 Q
THen am I correct in assuming that basically the i
12 first seven pages you have identified were the product of the
()
13 group you work with?
14 A
No.
15 Q
Okay.
16 A
They are based on our group's product and in many
-17 cases, they are verbatim our group's product, but in other la respects they were changed.
19 Our group's product is contained in this. document, 20 as best I can now -reproduce, on the pages that start with K 21 and end with W in Exhibit 1148, these letters being in the
()
22 lower left-hand corner of each page.
23 I have to say that this is based largely on my
()
24 recommendation almost six months ago, but this is the best Ace Feder:J Reporters, Inc.
25 Ehat I can now reconstruct.
f i
1
189 i
.MPB/eb3 1
It will be observed that pages 1 through 7, which l
r' l
\\ >3 are identified in the lef t-hand corner as A through G, are in 2
l e
3 some respect identical, page for page, with the pages I iden-
,O -
\\#
4 tified as the Task Force's work product.
5 Q
Fine.
Okay.
6' Now to whom was your Task Force's work product 7
delivered?
8 A
A small group of Commissioners.
It was seen first 9
and discussed with Commissioner Gilinsky.
Part of the work 10 product at that point was a table on a blackboard which was 11 never reduced to writing, which was an earlier version of parts l
12 '
of pages B, C,
and D, and was of course much abbreviated and
()
13 was in fact rather a working draft.
14 This was discussed with Commissioner Gi.linsky 15 early on the morning of --
16 Q
If you're referring to the Sunday morning I _ think 17 We've identified that as April the 1st.
18 A
-- April 1st.
Somewhat later either the blackboard 19 version or a written version was discussed with Commissioner 20 Ahearn.
And a little later in the morning they were discussed 21 with a larger group of Commissioners, and the taped record
()
22 will show just who was there at that time.
I don't want to 23 trust my recollection.
)
24 Q
Fine.
! Ace Federd Reporte,s, Inc.
23 I'm going to ask you a few questions for the l
I i
190 1
MPB/eb4 1
purpose of identifying timing on this one.
i
-/w A-)
2 Can you --
l 3'
A I have to say my timing is very vague.
I'd been O
4 working for a long time by that time.
5; Q
Okay.
Fine.
But I'll ask you a few questions and i
6l perhaps that may help identify timing.
7 When you talked to Commissioner Gilinsky before you a
talked to the others, was it your impression at that time that 9
Chairman Hendrie had already left?
10 A
I don't know.
11 Q
Okay.
12 Were you --
()
13 A
I do know when it was, and Chairman Hendrie's 14 movements presumably can be timed in other ways.
15 Q
Yes.
Okay.
16 A
Commissioner Gilinsky came in first, very early 17 in the morning, between 6 :00 and 7 :00.
My recollection is that 18 I owed him a draf t by 7:00 or 8:00 in the morning, and my 19 notes don' t tell me which one it is.
20 I recall that he came in first, before the~ deadline 21 and I didn' t have anything for him.
And he went somewhere (Oj 22 else in the building and did something else.
23 He then came in an hour or so later, between 7:00 l
IJ' 24 and 8:00, and. that was our first discussion.
Am.Fewd Reorwrs, lm.
i 25 Q
I was laughing, and' the record can show it.
I l
l l
l I
l I
191 i
1 0
B' MPB/eb5 I
want to tell you you may enjoy looking at Dr. Mattson's depo-()
2 sition who remembers giving you a deadline of 6:00 in the 3 !
- morning.
(~jT l
1
~
4 (Laughter.)
5 But they correspond.
t 6i A
That may well be so.
7 Q
Perhaps Commissioner Gilinsky gave him a deadline 8
of 6 :00 but he didn't tell you.
We'll see.
9 A
No, he told me a time.
I'm just having trouble 10 remembering exactly when it was.
Il Q
I understand.
Okay.
12 '
This is again for the purpose of trying to put
()
13 some timing.
Were you aware at any time on the morning of 14 April 1st that Dr. Budnitz made a presentation to the Commis-15 sioners?
16 A
No.
17 Q
Okay.
So trying to time it that way is not going 18 to be very useful.
Okay.
19 Now did you have on that morning any understanding i
20 that your product, the product of your Task Force, would be 21 worked on and a different product prepared -- I'm sorry, the
(
22 product of your Task Force would be worked on and a product 22 in the f6rm of the first seven pages of Exhibit 1148 would be
()
24 prepared from-that?
Am FWwd Rummrs, inc.
25 A
I wasn't surprised when it happened.
Our product
-w
192 MPB/ob6 I
had a lot of detail in it which was not suitable to send to 2
i
. 3 Q
Did you have any awareness of who would be prepar-l ing or who did prepare the first seven pages of Exhibit 1148 4
5 from the product of your Task Force?
j i
6 A
My recollection is that Commissioner Gilinsky told f l
7' me he did.
8 Q
Is that a recollection at about that time, or is 9l that as a result of something you heard subsequently since 1
10 '
the investigations which are going on?
II A
On April 2nd --
12 Q
Fine.
That's contemporaneous.
OV 13 A
No, let me be as clear as I can.
I d-Off the record.
15 (Discussion off the record.)
16 MR. SCINTO:
Back on the record.
t 17 THE WITNESS:
When-I came in the evening of April l
l 1
18 2nd I was handed a copy of Exhibit 1 48, pages A through G, 19 with a message -- I don't know whether it was oral or written --
20 that this had been transmitted to Pennsylvania and that l
21 Commissioner Gilinsky would like my comments on it.
22 And the pages in Exhibit 1148 identified H, I and 23 J were the comments which I sent to Commissioner Gilinsky.
O'v 24 And it was from this exchange that I got the impression that Ace Federal Reporters, Inc.
25 Commissioner Gilinsky had condensed our work product into those-N
193 )
MPB/eb7 1
seven pages to send to Pennsylvania.
f f
I k/
2 BY MR. SCINTO:
3 0
Fine.
t
,_s(
4 At any time during the course of your work on the
)
i i
Si criteria that are contained in Exhibit 1148 did anyone tell I
i I
i 6l you or intimate to you that such plans, such criteria had been ;
l!
i 7
requested of the NRC by the Governor of Pennsylvania?
i 8
A Not that I recall.
The intimation was that the f
9l Commission needed to be prepared for eventualities, that they f
10 l wanted it thought through in advance so they would be in a 11 l position to make these decisions if needed.
12 l Q
Okay.
([i 13 I'd like to ask a similar question:
14 Did anyone at any time during the course of your 15 work, did anyone tell you or intimate to you that these plans 16 or criteria had been requested or suggested by the White l
17 House staff?
18 '
A No, not that I remember.
19 l Of f the record.
I 20 (Discussion off the record.)
21 MR. SCINTO :
Back on the record.
(
)
22
- BY MR. SCINTO:
I l
l 23 Q
What time, approximately, did you -- on Sunday lll 24 morning, what time, approximately, did you comolete work on Awfewd Reporters, lm.
25 this?
i l
c 194 f
I MPB/eb8 I
A The first draft, including the blackboard, was done s
i i
2 about 7:00 in the morning.
l 3
Q Okay.
l 7_
i
(
)
4 A
The discussions I have described took place in the 5
next hour or two, and a number of revisions were made and a f
I 6!
typewritten product was given to Commissioner Gilinsky and l
7ll others mid-morning.
l 8
0 What time did you leave the Incident Response 9
Center on Sunday?
What time did you go home?
l 1
10 l A
About two o' clock in the afternoon.
l I
II Q
Did you undertake any other activities in connec-I I2 tion with the Incident Response on that Sunday?
I
,o
(_)
13 A
I have no recollection of any, and my notes don't 14 contain any.
15 Q
Okay.
4 l
16 A
I have a note at 3:15 Sunday morning, I discussed 17 with the people in the Incident Response Center some questions i
i 18 about whether the accumulator should be isolated.
My recol-i I9 lection is that there was a colloquy between the Incident l
20 Response Center and the NRC people at the site on this subject.
2I And my advice was asked and I gave it.
22 And my best reconstruction is that I advised that 23 the accumulators probably weren't needed and could be valved i
h 24 off, even though this was a tech spec violation.
Au-FWeal Reporters. Inc.
{
25 That's the only other activity I either recall or f
I i
195
{
l i
- MPB/eb9 1
have in.my notes.
(
2 Q
On that Sunday morning were there conversations in 3
your presence concerning either oxygen concentration in the 4
gas-bubble, flammability of the gas bubble, whether the pri-l i
5 mary system integrity could be maintained if there had been i
6; detonation of the gas bubble?
I 7
A In that period, Saturday night, Sunday, Sunday 8
night, the bubble was very much in everybody's mind.
I can't 9
tell you whether it was Saturday. night, Sunday morning, or i
10 Sunday night, there were all kinds of conversations in all the i 1
11 corridors about the size of the bubble, how was this being 12 !
measured, what might be in it, what might happen to it, what
()
13 pressures might result.
14 I had no substantive part in any of these discus-15 sions because I was busy working on the other assignment and 16 I cannot organize any particular recollections.
17 Q
Okay.
18 Do you recall any discussions which struck you as 19 particularly significant that you can still recall?
20 A
Yes, but I can't recall much about it.,
I remember 21 being told some pounds per square inch values for (a),
)
22 burning and (b), detonation of the hydrogen in the bubble, i
I 23 and I remember that they were sufficiently borderline that it f ()
24 wasn' t obvious that the vessel would remain intact but it also i
! ' Ace #ederal Repo,ters, Inc.
25 wasn' t obvious that the vessel would f ail, l
i I
i i
l
196 l l
MPB/ebl0 1 And I cannot reconstruct whether that was for burn-
=A,d 2I ing or detonation, but I think it was for burning.
In other i
i l
i 3 I words my recollections of the substance of those conversations,
)
4 are very vague.
{
l 5
Q Fine.
I understand.
l 6
I'm going to be asking a number of related questions I
7 right now, just seeing if they modify your recollection.
8 Do you recall any of such conversations at which 9
any of the Commissioners were present?
10 A
No, quite the contrary, my recollection is that
{
11 these conversations were not with the Commissioners.
12 Q
Do you recall any such conversations which'aopeared
()
13 to be conversations principally among senior members of the 14 Staff?
15 A
Yes, but they are quite general.
There were various 16 participants.
l 17 Q
No, I'm thinking of one in which it would be ex-18 clusively senior members of the Staff, very senior members.
19 And I mean by that ' Division Directors, some of the -- Assistant 20 Directors and above only.
21 A
Well, there were senior managers in many of these i
/'T i
t y 22 discussions --
23 Q
Right.
()
24 A
-- but I remember nothing that I would characterize
! Ace Federal Reporters, Inc.
25 as a meeting of the senior Staff to discuss this question.
i
i 197 i
MPB/ebil 1
Q Fine.
Thank you.
That's a better way of phrasing (E'l 2
the question I had in mind.
Okay.
I i
3 Were you aware on Sunday morning that there had been!
(
4 a meeting, perhaps not one that you attended, that there had 5
been a meeting that could be characterized as a meeting of 6!
the senior Staff to discuss this problem?
l I
l l
7 A
No.
8 Q
You were not aware of a meeting between Dr. Mattson, 9
Dr. Budnitz, Dr. Murley and Dr. Levine?
10 g A
No.
I i
11 Off the record.
i 12 (Discussion of f the record.)
()
13 MR. SCINTO:
Back on the record.
- 2 14 BY MR. SCINTO:
15 Q
Dr. Hanauer, during the course of your work were 16 you personally given direction or instructions by any of the 17 Commissioners, you, personally?
18 A
Only during the discussions of our work product on l
19 Sunday morning where some changes were mutually' agreed on.
20 Q
And you've previously identified various people?
21 A
Yes, we' ve already gone though that.
()
22 Q
Fine.
Okay.
23 I'd like to ask you briefly, during the course of i
I
(~h i.j 24 your_ work did you observe or feel a sense of inter-office l 4*Fewo n.pomn. ine.
25 rivalry among various components of the NRC in their work?
f 1
l
198 l
l MPB/ebl2 1
A Absolutely not.
I was impressed then and remain b) 2 impressed with the feeling that the various components of the j
i 3
Staff seemed to be working exceptionally well together.
I 4
This was also true of my contacts with the people l
l 5
at the site where it really didn' t seem to matter what office I
6 they normally worked for.
I got calls from people in I&E and.l l
7 NRR principally, and Research, and there were also, if I i
I' 8
recall correctly, a couple of people up there from Standards.
9 And everybody seemed to be working on the same team, i
10 Q
During the course of your work were there senior II officials in the Emergency Management area of the Incident 12 Response Center who seemed to be generally supervising the A!s) 13 work going on at the agency?
Id A
There was always somebody in charge, and you always 15 knew who it was.
This supervision was not always exercised 16 in the sense that subgroups of the people in this area would 17 confer on problems and decide what to do.
This was sometimes 18 not referred to the person nominally in charge.
But we always 19 knew who was the acting supervisor.
20 Q
Okay.
21 In connection with the work you performed in de-i O'd 22 veloping criteria for protective actions, did you have the 23
. impression that--
Strike that line of questioning.
Let me 24 build some background for it first.
lAc.F.ewein.conrs,inc.
25 In reviewing the tapes of the telephone conversations i
^
199 l
MPB/ebl3 1
at the IRC I was struck by the repeated use of words indicating, (O
m/
2
' suggesting an NRC responsibility to undertake evacuation or i
3 to notify the public, words such as "We ought to be moving l
O 4
people," or "We should evacuate people," or "We should tell 5
them to take shelter. "
l i
6l I'd like to ask you, during the course of your work j i
7 did you have a belief, a feeling, an impression that if the l
8 NRC had recommended evacuation to the Governor that the 9
Governor was. going to act on it?
10 A
The subject never came up.
My work on evacuation 11 was on such a different context that I just didn' t think about 12,
that ques tion.
()
13 Q
Okay.
14 Now I'd like to ask you some hypotheticals and I'm 15 going to set up some hypotheticals and I'm going to ask you 16 some questions about them.
After I've finished the questions 17 I'm going to ask, I am then going to ask you what do you think 18 about the desirability of the hypothetical situations I'm 19 posing.
Okay?
20 First I'd like you to suppose that it was the NRC's 21 function in the event of an accident to direct the operator
( )s 22 to take specific steps in order to mitigate an accident.
23 And I'd also like you to suppose that we had avail-()
24 able to the NRC all of the information available to the licensee, j Ace Feder'3 Repo,ters, Inc.
I 25 such things as remote readouts of any and all needed
-r
..._m
,-y
-..---g
200
- MPB/ebl4 1
ins trumen ts.
I'd like you to suppose those two conditions.
2l Now I'd like to ask:
As we are presently organized, i
3 are we capable of adequately assessing all of that information c~).
i 4
and promptly determining what specific steps an operator should take?
l i
l E
6i A
In some circumstances, yes; in most circumstances, l
7 no, because we do not have in the NRC the intimate knowledge 8
of the plant necessary to make specific operating instructions.
9 We don't know which valves to turn in the same way that an 1
10 operator in the plant or practically anybody on the plant staff t i
II knows intimately which valves to turn.
12 On the other hand, for us to say in a more general
()
13 way those instrument readings show that you have exceeded 14 saturation temperature in your primary system and you should 15 not, therefore, shut off the high pressure injection, at that 16 level we do have the competence and the knowledge to give l
17 operating instructions at that level.
18 Q
Okay.
19 Now I'd like to change it slightly, change our role 20 slightly.
07 21 How about if our role were not to direct the opera-()
22 tor as to specific steps?
In fact your answer that you've 23 j us t given may answer this ques tion, but I want to ask it any-I
()
^
24 way.
Let.me go back.
. Ac..F.e.ro neoorters, Inc.
25 How about if our role dere not to direct the
. ~
201 i
l MPB/ebl5 1
operator to take specific steps but to serve as a principal
/~T 1
k-2 technical advisor to the licensee's operator and to the l
3 utility's management?
And again assuming we had all the infor-j i
4 mation we wanted, are we presently organized -- are we i
5 capable of adequately assessing this information and advising i
6, the operator and the utility management on what steps to follow?
I 7l A
Well, yes, at the level of over-all evaluation i
8 which I illustrated in the answer to the previous question.
9 Fur thermore, it's my impression that that's what we 10 were doing during the Three bEle Island accident.
11 Now this doesn' t mean that I have any special know-12 l
_ ledge of exactly what our interface was with the '.anagement,
()
13 but we were studying technical alternatives and giving our 14 best advice in pretty much that flavor to the NRC people at 15 the site.
16 Now whetner they in fact served as a technical 17 advisor to the licensee's staff I don' t know, but the things 18 we were studying and the advice we gave would have fit this 1
19
-role very nicely.
20 Q
Okay.
21 I would like to go back to my own assumption that
()
22 we had all the information we needed in order to carry out 23 these two jobs, the job of either directly taking over or
() _
acting as principal technical advisor to the control room --
24
' Am Feder:3 Reporters, Inc.
25 to the operator.
1 1
f 202 i
MPB/ebl6 I
Now I'd like to ask what kinds of information would
(\\~/'T l
i 2
we need?
Would we need, for example, like remote readout of i
3 all the instruments, selected instruments?
Could we select I
4 them in advance?
Or are we talking the kinds of information 5l 5
you can get over a phone?
I i
6 A
Well, my experience in getting information over the l 7'
phone demonstrates to me that that's inadequate.
8 Furthermore, the readouts of instruments are not 9
sufficient.
We need the readouts of a selected number, not I
10 every instrument in the plant.
There are far too many.
II A large fraction of this can be pre-selected, but 12 some would have to be selected on the basis of what was 13 actually going on, and therefore, some flexibility is needed Id in what information is to be tr-mitted.
15 We also need what I will characterize as operational 16 information:
the aspects of the valves, what's running, 17 what's not running, what operators have done and are doing.
18 An obvious example is the unexplained radioactivity releases 19 which apparen 'v cre unexplained and for sure were unex-20 plained at the time when nobody had a complete picture of who 21 was doing what in the plant.
(
22 So that the instrument readings are the start and 23 not the finish of-the information.
24 There is also the necessity for a detailed know-Ace-Federd Reporters, Inc.
25 ledge of the plant configuration which was also not available I
l
203 I
MPB/ebl7 I
in Bethesda and which was the subject of an enormous amount
( -)-
I 2
of telephone calling and transmitting of documents and dredgingt i
3 of documents out of the files.
In order to have sufficient l
[h 4
information to make decisions of the kinds we are talking 5
about, one has to have an intimate detailed knowledge of the 6
plant which is, in general, not available in Bethesda or to i
7 the NRC, although the resident inspector probably has more of 8
it than anybody else.
9 Furthermore, some of this knowledge is not in the 10 licensing documents and is not generally exchanged between the 11 licensee and the NRC, and had to be provided on an ad Pac 12 basis when we needed it.
_)
13 So that even though our role was somewhat less than 14 the roles you now project, we didn' t have enough information.
15 0
All right.
16 Now to change assumptions again, suppose our role, 17 rather than deciding or advising how to run the plant, was 18 one in which it was the NRC's responsibility to decide on the 19 need for protective action in the event of a reactor accident.
20 That is, the NRC would order local officials to take various 21 protective actions.
It's an assumption.
A
't,)
22 Suppose we have all the systems information that 23 we need.
(,
24 A
Please define " systems information."
Ace-Federd Reporte,s, Inc.
25 Q
Information about the reactor, how it's working, l
m.
i i
204 '
MPB/ebl8
'I about the releases from the plant.
i O
n the eecond he1f of my suestion 1 ehink mevbe 2
3 you'11 see the distinction, but if not, then ask me.
l s
b Suppose we had all the systems information we needed.
4 What kind of information would be need to make an assessment S
of the effectiveness and the risks of taking the protective 6,
i action?
l 7
Now if you need more definition of " systems" I'm 8
willing to give you....
9 10 A
This is outside my expertise, but I will answer the I
jj question as best I can.
You first need to know more than I know about the 12 13 technology of evacuation, how long it takes as a function of 34 things like population density, what kind of a risk it entails 15 in a general way, and what kinds of experiences have been 16 accumulated.
17 You would then have to have some local knowledge as 18 to the actual population density, road and other transportation 19 availability, fraction of the population without transportation available, the shelter situation, and so on.
20 S
you would have to have both a general knowledge 21 22 of what can be done with evacuation and what the penalties are 23 in terms of risks, and also a specific knowledge of the area (7
24 involved.
%, il
' Ace Feder :$ Reporters, Inc, 25 Q
Okay.
i 205 i
I
'4PB/ebl9 This may De going beyond what you feel you can talk
'\\
2 about but I think, for example, in this response you just i
i 3!
indicated that what sounded like a lot of local information i
4 would be needed.
Is that correct?
l 5
A That's what I intended to imply.
I 6l Q
Okay.
I 7
Does that suggest to you that there is inherently 8l some sort of a dichotomy in the information needed to make the i
9!
judgments?
On the one hand, you need the local information l
10 '
and on the other hand you need knowledge about the reactor 11 i
systems.
I 12 l Is that kind of information to be found in any one o
)
13 group, or does that necessarily imply two different kinds of s
Id people?
15 A
I think it implies close cooperation between two 16 different kinds of people.
I7 Q
Now what I'd like you to do is to generally comment 18 as to your feelings as to the advisability or desirability of lo i
the three roles I outlined for the NRC.
t l
I 20 The first one was in the event of an emergency to 21 direct the operators to take specific steps to mitigate the I
22 l
accident.
That was one role.
23 The second role was to act as principal technical l
l 24 advisor to the operator and to management in connection with Am Merd Remnen. Inc.
I 25 their response to the accident.
l I
l
206 l
MPB/eb 20 1
The third is to decide on the need for protective J
2; actions.
I 3,
A One at a time.
I-I i
l l
l 4i Q
Please.
i 5;
A With regard to the first, I don't think the NRC has I.
6, or can have the detailed information and understanding of the 7
plant necessary to direct the operator to close a certain valve, '
i f
8 although there could be exceptions to this, and one would have I
9 to decide ad hoc whether one had suf ficient detailed information l I
10 for some particular direction.
f, i
11 With regard to the second, that's my view of ideally i
l 5
12 what c _r role should be.
- I
(
13 With regard to the third, I don' t think we can do it 14 ourselves, but I think we are a necessary component.
I think 15 that there is a group which knows most about the plant and 16 what's going on, and what releases are taking place, and that 17 is not the Nuclear Regulatory Commission.
I 18 I think there is a group which knows in detail the 19 local situation, population density and distribution, and so on,1 I
i 20 i and that that's not the Nuclear Regulatory Commission.
I i
21 But I think the NRC is appropriately a third compo-22 nent in the group that makes that decision because they know l
23 most about how to put these two things together and what the lll 24 considerations should be.
Aa Feerel Recorters, tx.
l 25 Q
Who did you have in mind would be the group who knew i
2J7 l
t i
\\
MPB/eb21 1
most about what's going on, releases at the plant, et cetera?
('}
2 A
That has to be the licensee's organization augmented i 3
as appropriate.
Their knowledge is first-hand; our knowledge j
Cl) 4 is second-hand.
l 5
Part of the augmentt : ion might be such things as the 6
NRC or DOE airplanes gathering information.
That would be part 1
i 7 ! of the systems information you described.
8 Q
Okay.
9 In connection with this second role, this one of 10 serving as a principal technical advisor which you characterized 11 in your belief as the ideal role of the agency, I think in the 12 course of our discussions you also identified a need -- in
()
13 order to carry it out well a need for significant improvement Id in the availability of information to the NRC.
Is that right?
15 A
Yes, sir.
1 16 Q
Okay.
l 17 Now I'd --
18 A
Particularly the NRC in Bethesda.
I have only second -.
19 hand knowledge of what the NRC in Pennsylvania knew, and I 20 wouldn ' t want to comment on that.
21 Q
Fine.
I understand.
()
22 Now you participated as you described in connection
.23 -with - the Commission's response to the T. tree Mile Island acci-()
24 den t.
You testified that you had participated in the Commission's i
l Am-FwwW Reorwrs, lm j
25 review of the Browns Ferry accident.
You've had some background l 1
1
\\
L_
l 208 MPB/cb22
.1 in the way in which ' the Commission looked at the character of I')
I k/
2 accidents that have happened, major accidents that we have seen l 3
so far that have happened, and the Commission's response to V'
4 them.
5 Indeed, if we were to get the capability that you 6, say would be desirable to fulfill this position as technical i
7 advisor, would it be -- would this help the over-all l
8 by the utility, would it be -- would this help the over-all 9
response by the utility, the Commission?
Would it help the 10 over-all response for most of the serious accidents that you 11 envision are likely to occur?
12 '
A I hope so, and I have to believe it would although
(,)
13 the evidence is scanty.
I see both at Browns Ferry and at 14 Three Mile Island missed opportunities, at times characterized 15 by hours rather than minutes or seconds.
16 At Browns Ferry there were additional sources of 17 water that nobody thought of.
At Three Mile Island there were 18 things that could have been done at T equals one hour or two 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> that would have greatly changed the course of events.
20 In fact, the events proceeded the way they did and were more 21 severe t_an they need to have been.
()
22 On the other hand they could have been much more 23 severe, and a number of things were done right.
Otherwise we
()
24 would have had core meltdown, and we didn' t.
Am-FWw:A Roorwes, lx, 25 I can't help but think, subject to future
208-A i
FB/cb23 1
confirmation by experience, that if we had better information 2
and were better organized to give this advice in the one to ten 3
hour time frame, and if we were more willing to be more fore-(^;
k#
ful with it that things might
, improved.
4 I
5 I also observe a great danger in this.
I observe l
i 6*
that in some of our early bulletins we told all licensees to j
k 7
do things which we later decided were in the direction of de-l 1
I s
creasing safety, and we had to rescind them.
There's a real 9
danger that we'd do this at T equals one hour also, and there-1 l
t 10 fore, a proper humility of approach is required.
j i
11 But my experience in these two accidents tells me 12 we are almost overpowered by our unwillingness to tell the I
em
(
)
13 operator to do anything in derogation of his ultimate respon-14 sibility for the safety of the plant.
I think we should be a 15 little less scrupulous, and I think also we should be a little 16 less polite when we finally decide to give a piece of advice.
i 17 Q
Would you characterize it as being a little bit more ;
18 confident in our own technical capability?
Do you believe il~
19 that that's a component of it?
20 A
No, I don' t think that's a component.
I think it's 21 an unwillingness to intervene and thus become responsible for b ')
22 Che plant safety in a way in which, without giving the advice, i
23 we have the illusion that we would not be responsible.
lll 24 Q
This sense of responsibility rather than a lack Am FWest Reporars, inc.
l 25 of confidence in our own --
l 1
209 j
MPB/cb24 1
.A I think so.
O)
\\-
2 Q
Okay.
i 3'
Dr. Hanauer, in your response, the kind of picture
()
4 of time frame for response is somewhat longer than the classic l
1 l
5 picture of the large-break LOCA accident sequence, is it not?
6 A
It is.
There is very little the operator on the i
7 spot can do to help or hurt a large-break LOCA.
The accident 8
is over in a small number of minutes.
There is essentially 9
nothing that can be done usefully or harmfully from Washington 10 in a matter of minutes, 11 Q
I'm trying to push at the point of do you personally 12 picture that the non-trivial accidents that we'll have will be
(_N) 13 more -- that there will be a significant -- wrong word -- they 14 would be more likely to occur in a slower time sequence than 15 the classical t cture of the large-break LOCA?
16 A
Oh, certainly.
I think the Browns Ferrys and the 17 Three Mile Islands are demonstrably much more likely than the 18 large LOCAs, 19 Furthermore, as I said, there isn't much you can do 20 about a large LOCA and there's a whole lot you can do about 21 Browns Ferry or Three Mile Island.
( )-
22 Q
I gather then from this that you think it's suffi-23 ciently likely that it's worthwhile to get the capability?
. (,)
24 A
Yes, sir.
Ace. Federal Reporters, tric.
25 0
Okay.
t
210 i
l MPS/eb25 1l A
I testified yesterday that I expect to see more 2l l;
l severe accidents.
I don't expect them to be just like Three 3ll Mile Island, but I don ' t expect them to be large LOCAs either.
i h
30 BU3 4
Q Dr. Hanauer, you have indicated your familiarity 5
with the report on the Browns Ferry fire, which is a NUREG l
i t
6j number, 0050 dated February 1976.
Is that correct?
j 1
7 A
I was its principal author and I was Chairman of 8
the Special Review Group.
9 Q
Dr. Hanauer, I'd like to direct your attention to 10 i a passage on page 7 in the middle of the page.
I will read i
11 the passage into the record, and I will direct your attention 12 to i t, and I will ask you to comment on one aspect about it.
At
,.( )
13 page 7, the middle of the page, there is a passage which is 14 the first paragraph of a subsection numbered 1.6.6. "Recommenda-15 tions for the NRC" is the title of that subsection.
16 The first paragraph reads:
1 17 "The NRC must also consider the Browns 18 Ferry lessons for improving its policies, proce-19 dures and criteria.
The NRC is responsible for 20 insuring the health and safety of the public."
21 Am I reading it incorrectly?
(,)
22 A
Please read it correctly.
In fact, let's just put I
23 it in the record right from the printed page.
()
24 0
Yes.
Well, let's make a copy of the printed page.
Aa-Fen : Reporters, tm t
i 25 A
Yes.
Fine.
l i
i
l 211 MPB/eb26 1
Of f the record.
2 (Discussion off the record.)
l 3
MR. SCINTO:
Back on the record.
l C) i 4
(Whereupon, the document '
5 referred to was marked 6
as Exhibit '_149 for 7
identification.)
8 MR. SCINTO:
We've decided rather than trying to 9
read that paragraph into the record, to make a copy of page 10 7 of NUREG 0050 and have it marked as Exhibit 1149.
11 BY MR. SCINTO:
12 Q
Dr. Hanauer, I'd like to direct your attention to l
()
13 the first full paragraph of Secti.on 1.6.6 on page 7.
Would 14 you characterize that paragraph as suggesting that the NRC 15 should not become closely involved in the licensee's emergency 16 response operations?
17 A
That's what that paragraph says.
I'd like a moment, 18 please.
It's said better in another place.
19 (Pause.)
1 I
20 0
I think it's around 59.
21 (Witness reviewing document.)
()
22 A
I think this should be read in connection with 23 Section 6.1.1 on page 52.
Why don't we add this page to Exhibit l ()
24 11497
- Ace Feders Reporters, Inc.
25 A
Well, let's add it, and give it another number, call 1
- 99
212 l
MPB/eb27 1
it 1149-A.
i
/~N i
\\_)
2 A
All right.
i 1
3 Off the record.
4 (Discussion off the record.)
k' l
5 MR. SCINTO:
Back on the record.
On further consideration it's so simi 1 6
THE WITNESS:
i 7
lar that it's not worth marking as a separate paragraph.
8 BY MR. SCINTO:
9 Q
Fine.
10 A
You've correctly characterized that paragraph and 11 in particular, the sentence which says:
12 "If the NRC were to become too closely
(~')
13 involved in the licensee's operations, this might 14 have an adverse effect on the licensee's view of 15 his safety responsibilities."
16 My testimony a few minutes ago is less in this 17 direction. than this report which was written three, three and a 18 half years ago.
Reviewing now Browns Ferry and Three Mile 19 Island and other events, I know feel as I said that we should 20 be less scrupulous about this question and that the immediate 21 attention to public health and safety in an actual event with
()
22 the potential for. public hazard should override this general 23 consideration.
()
24 MR. SCINTO: _Thank you.
I m.Feder;J Reporters, Inc.
A 25 Mr. Miller, it's yours.
i 213 l
THE WITN"SS:
Let's take a short break.
l MPB/eb28
()
(Recess.;
2 e
i MR. SCINTO:
On the record.
3 At this point I would like to insure that the
- s 4
l Reporter incorporates into the transcript of this deposition
{
5 6l f today a copy of Exhibit 1148.
This exhibit we discussed 1
1 at some length.
It is a xeroxed copy of a typewritten docu-j 7
ment.
The exhibit has a number--
Dr. Hanauer points out tha t g
there are some pages of it that are handwritten.
9 4
The document has on it a number of handwritten 10 11 comments.
With respect to the handwritten notes written by 12 Dr. Hanauer contemporaneous to the production of the document to which Dr. Hanauer has testified in his deposition, let the
()
13 record be very clear that Dr. Hanauer was not asked and 14 Dr. Hanauer is making no representation concerning the other 15 handwritten notations contained on this document, whether as 16 17 to their accuracy, their authenticity, or where they came from; anything about those other handwritten notations.
18 19 BY MR. SCINTO:
20 Q
Is there anything you'd like to add, Dr. Hanauer, to that?
21 O
27 A
No.
\\~J l
MR. MILLER:
This will be questioning by Mr. Charles !
23 l (~)
24 O. Miller, j
RAco FMwel Rumners, Inc.
}
25 BY MR. MILLER:
i l
214 i
MPB/eb29 1
Q Dr. Hanauer, I have had an opportunity to read your l O'
testimony before the Presidential Commission and, indeed, l
2I I
I 3!
countless other documents some of which had your name asso-l
/~T l
%..)
4 ciated with it.
And I'm going to hope not to repeat things j
I 5
but it is necessary here this morning to try to expand on some 61 of this material that you have testified to before.
7 A
Off the record.
8 (Discussion off the record. )
-i 9
MR. MILLER:
Back on the record.
10 BY MR. MILLER:
11 Q
The area that I intend to cover can generally be 12 described as certain safety, engineering and management aspects
()
13 of the NRC operations which obviously gets into the operations 14 of utilities. and contractors such as Met Ed and B&W.
15 I'm sure as you were informed before, don't hesi-16 tate to stop me and ask me to clarify any of the questions as 17 they may arise.
I ' d be happy to do so.
18 First let's get to a few items which were raised i
19 in the Presidential Commission testimony.
I recall you comment 4 20 ing on page 11, to be exact, that --
21 A
I'm going to insist on having a copy of that testi-()
22 mony in front of me.
I 23 of f the record.
! ()
24
'(Discussion off che record. )
! Ace-Federst Reporters, Inc.
25 MR. MILLER:
On the record.
l
i 215 i
LPB/cb30 1
THE NITNESS:
It's not immediately available and t
O s
2 we'll ao without.
I 3
BY MR. MILLER:
O 4
0 I'll withdraw the question and try another:
5 Dr. Hanauer, you were at one time a member of the 6
ACRS, were you not?
7 A
Yes.
8 Q
And that period of time was when?
9 A
It's a matter of record in yesterday's transcript --
10 0
All right.
11 A
-- in some detail.
12 ;
Q Forgive me if I--
Please stop me if I go into i
()
13 anything that was covered because I was6't able to sit through 14 all of it yesterday.
15 But I'm interested in at the time you were there 16 what the qualifications were to be a member of the ACRS.
17 A
The members were appointed by the Commission on the 18
- recommendation of the ACRS members, and while I was a member, 19 Ehe selection was made essentially completely by the ACRS 20 members. and re.
- ified by the Commission.
In fact, no formal 21 statement of qualifications existed that I know about.
()
22 The qualifications that were considered most impor-23 tant by the committee members in their discussions were over-(3
\\
L
(_j 24 all a quality which, for lack of a better word, I will call l Aa m., i n co,tm. inc.
~
25 wisdom, judgment that could be depended on, and in particular,
-n-e
i 216
}
i I
MPB/cb31 technical judgment that could be depended on.
2l Something over half the members had personal, de-l 3l tailed knowledge of some area of technology directly relevant f
4 to reactor safety, but this was not true in all cases.
For S
example, Harold Mangelsdorf, who was at that time board 6l chairman of Crown Central Petroleum and had held responsible i
7 technical management positions in various aspects of the 8
petroleum industry, was chosen for his good technical judgment 264 9
and experience in large industrial enterprises involving 10 significant hazards.
And he was in fact an exceedingly produc-11 l
tive and respected ACRS member.
I 12 The members were drawn, about one-third each, from 13 academic life, from the national laboratories, and from in-Id dustrial positions.
We 'had a lot of trouble with this last 15 one because a large fraction of those who would be competent 16 would have conflicts of interest, and so we had a tendency to I7 pick consultants, retired people, and people like 18 Mr. Mangelsdorf who were widely knowledgeable but not inti-mately knowledgeable in nuclear technology.
20 We went to some pains to keep this balance and not 21 overload the committee with any one type of member.
We were O
V 22 also at some pains to preserve a broad range of technical 23 interests.
q) 24 i
Were any of the l eople during your time with the Q
. Ace Federal Reporters, Inc.
25 ACRS, could they be classified as human factors technology
B 217
-MPB/ob32 1
background?
k 2
A No.
3 Q
Could any of the people be classified as having l
r~)
1
(_/
4l a safety management background?
l 5
A Not in the narrow sense although a large number of 6
the members, myself included, had been responsible for what I i
7' would say, rather more broadly, is safety design, the design of 8
safety systems, safety and hazards analysis of nuclear power i
9 plants.
10 Q
Referring to the " safeguards" portion of the title 11 of ACRS, was it the feeling -- well, let's say was it your 12 feeling that safeguards as exercised within the context of
()
13 ACRS would include techniques beyond those emanating from 14 engineering and scientific disciplines?
15 A
The meaning of the " safeguards" in the committee's 16 title is disjoint with the use of that word today.
The systems 17 we now call engineered safety features were in earlier times 18 called engineered safeguards, and " safeguards" meant then what 19
" safety" means today.
And the committee gave essentially no 20 attention to what is called " safeguards" today.
21 I therefore need some more clarification of your ex
(
)
22 question.
sm-23 0
I believe you've answered it satisfactorily from
()
24 what I was trying to get at.
Ace-Federd Reporters, Inc.
25 I would add, based on what you've just said, or
{
4
1 218 i
!MPB/cb33 1
ask, based on what you've just said:
i
()
2j Is there any o ther difference in how the ACRS f
l
)
3 operates today, other than what you just mentioned in terms of (O
N 4 i
" safeguards" versus " safety"?
5 A
Oh, yes.
The operation of the committee has been i
I, i
6!
transformed by the Government in the Sunshine Act and the 7 I Advisory Committee Act.
8 Off the record.
9 (Discussion off the record. )
10 l THE WITNESS:
On the record.
11 !
The meetings were closed then; they are open now.
i 3
I i
12 The basic character of the committee's mission and delibera-
{
()
13 tions and product is unchanged.
It's operating methods are 14 substantially diffz rent as a result of these statutory changes.
15 BY MR. MILLER:
16 0
Would you say the scope of their activity has changed 17 in any manner over the past six, seven years?
18 A
Yes, it has.
The Congress has given them responsi-19 bilities for annual reports to Congress in two areas, one i
20 related to safety research and one related to budget review
'l 21 which they did not have in my time.
'( )
22 The committee'in my time spent a great deal of effort l
-23 and time on considerations related to safety research but
()
24' reported to the Commission and not directly to Congress as is
- Am-Feder) Repo,ters, tric.
~25 now the case.
t
219 MPB/eb34 1
Q Thank you.
C) i 2
Dr. Hanauer, from some of your writings I sense that 3
the term
" failure modes and effects analysis," you are f,\\
s V
4 rather familiar with that, are you not?
5 A
Yes, I am.
t I
Si Q
In your mind do you distinguish between a " failure 7
modes and ef fects analysis," and the " hazard modes and effects r
8; analysis"?
9!
A No.
10 Q
Reflecting upon the NRC licensing process, could 11 you summarize in what phases FMEAs, to use your term, are 12 l applied throughout the entire life cycle, beginning before
)
13 contruction permits are granted all the way through into the 14 operational cycle?
15 A
I already have in writing to the Kemeny Commission 16 and will furnish that for the record.
17 The usage is not very wide-spread.
18 0
I would apprecidte it if you will supply fo r ~the 19 record reference to that, i
i 20 A
I will so so, 21 The usage is not wide-spread.
It's fairly widely
()
22 used 'by the licensees in their own design and evaluation 23 process.
We find this rather too detailed for a large fraction
()
24 of our work and so we require that it be done but not that it
- A:o Feders Reporters, Inc.
- 25 be furnished for our review in many cases.
l 220 MPB/ob35 1
In other cases it is done and used in the design l
2 process without our intervention or review.
And in some few i
3 cases which I have set forth in this piece of paper I will fur- !
4 nish for the record and which I don't have on me, we actually i
5 use it as part of our review.
6l Q
Let me define a hazard integration analysis as dis-7li tince from an FMEA as being where a product from an FMEA are l
8 taken to simulator, mockups, actual hardware, and evaluated 9
for their intersystem effects.
10 With that definition, are hazard integration analyses 11 conducted at all in the process we've been discussing?
12 l A
Yes.
A substantial part of Chapter 15 of the Safety O
V 13 Analysis Report submitted by the applicant contains analyses Id o f.these sorts.
15 In this case I have somewhat broadened your use of 16 the word " simulators" to include elaborate computer codes which 17 predict the course and consequences of various accident se-18 quences.
The degree to which systems' interactions are in-19 cluded in that is currently the subject of research.
20 We are just now finishing phase one of a three-21 quarters of a million dollar contract at Sandia Labs in which D
_Q 22 they have represented one particular reactor in a series of 23 fault trees and event trees, and looked through accident se-(v
()
24 quences and cut sets of these fault trees to determine whether Ace-Federst Reporters, Inc.
)
25 systems'- interactions can play a role in the areas where they
i 221 l
l MPB/eb36 1
can, and the degree to which these interactions are considered !
C) 2 in our licensing process.
i 3'
The results of this work are not yet available.
()
4!
0 Well, in the design and development of a nuclear f
5!
power plant, to what extent are some of these -- what I'll l
l 6;
describe as " paper analyses" validated by an actual mockup 7
system hardware simulator, actual hardware type testing?
8 A
Well, we don't have any major accidents induced for 9
this purpose o f validation.
A validation therefore has to be 10 less than complete.
i I
11 We have an extensive experimental program and the 12 l industry has a complementary, with an "e," extensive experi-i
,m
(_)
13 mental program to provide the necessary validation of the com-14 puter models which are used.
But this is done through scale 15 model testing, through separate effects testing, through full-16 scale but incomplete sequence testing.
17 Q
Has sneak circuit analysis been applied in any nuclear 18 power plant development system that you know of so far?
19 A
Yes.
In an unregulated production facility owned 20 and operated by the Department of Energy it was applied some 21 years ago..
They had a scram. failure.
We are now in the process
()
22 of doing a sneak circuit analysis on one of our systems.
.23 0
Is.this by requirement of the NRC or is this some-esC 24 thing the --
w.peoere nepon.cs, Inc.
25 A
We're paying for it ourselves as an experiment.
j i
i r-v
222 i
MPB/eb37 1
Q Is there any particular format for FMEAs that has j
)
2 been required by NRC of any licensees or contractors?
3 A
No, we don't specify formats unless they are essen- !
(.)
4 tial to the safety review, but let the licensee choose his i
5 own.
6 Q
From your knowledge has there been a tendency among 1
7l the licensees or contractors to use any particular format for 8
9 A
I don't know.
10 Q
Are you familiar with the NSAE format for FMEAs--
11 I'll let it go at that.
12 A
No.
()
13 Q
Are there any formats for FMEAs, to your knowledge, 14 that have been released by IEEE or any other professional 15 society?
a 16 A
I don't know.
17 Q
Do you have any --
-18 A
I would add something to that answer.
19 Q
Certainly.
a 20 A
It has never appeared to me that the format was of 21 any importance.
If this is not true, then I still haven' t
()
22 paid any attention to them.
23 Q
Do you recall in your experience with FMEAs that
)
24 any of them had a column which basically asked for the symptoms
. Aes FederG Reporters, Inc.
25 of the failure anticipatory to or complementary, again with
- ~.
-l l
223 B/cb38' I
an "e,"
to the mode and effect of the failure?
i 2
A No, I don't recall the heads of any columns of any 3
FMEA.
t f\\
(_/
I 4
Q Do you have any personal familiarity with the 5j American Society of Safety Engineers?
i 6!
A None.
I l
7' Q
How about the National Society of -- National i
8 Safety Management Association?
9 A
None.
10 Q
Systems Safety Society?
11 l A
None.
12 !
Q Are you aware of any NRC personnel who might be
'( )
13 members of those societies?
1 14 A
No.
i
)
15 Q
I show you a document here that I'm not going to 16
. question you on beyond just asking you if you've ever seen it.
I I
17 And I'll identify it as Mil. Standard 882-A, entitled " Military 18 Standard, Systems Safety Program Requirements," carrying the 19 date of 28 June 1977.
20 (Displaying document) 21 A
No.
()
22
-Q Similarly, do you have any knowledge or have you 23 ever seen a document which I'll identify as NASA Safety Manual,
()
24 Volume 3, Systems Safety, NHB 1700.1 (V3)?
Am.Fap3 Remnws, Mc.
25 A
I may_ have seen that.
Let me scan it.
i l
1
224 MPB/cb39 1
(Document handed to the witness.)
1 l
2 A
I may have seen this.
In my review of the Browns i
i 3
Ferry accident I discussed with some NASA people some of their
(
4 safety techniques, and they sent me some of their documentation 5
and that might be one of them.
6 Q
Here again I'd like to read something on the record l
l 7l to avoid the trouble of going and xeroxing this.
I want to I
8' read a paragraph from 10 CFR Part 50, specifically Section i
9, 50.2, Subsection (u).
It reads as follows:
10 A
Excuse me.
I want to have it in front of me.
50.2
'l wha t?
12 :i Q
(u).
It's
" Design Bases."
?
()
13 A
All right.
14 0
"' Design bases' means that information 15 which identifies the specific functions to be per-16 formed by a structure, system or component of a 17 facility, and the specific values or ranges of values 18 chosen for controlling parameters as reference 19 bounds for design.
These values may be (1) res-20 traints-derived from generally accepted ' state of the 21 art' practices for achieving functional goals or (O_)
22 (2),-requirements derived from analysis (based on 23 calculations and/or experiments) of the effects of a
()
24 postulated accident for which a structure, system or
- AmJerJ Rgertm. toc.
25 component must meet its functional goals."
225 1
MPB/eb40 1 My question, Dr. ::anauer, with reference to this l
/~~
(_)
I 2
as you wish bears upon seeing the term " design basis accident" 3l in much of the correspondence associated with TMI 2.
(")T l
i 4
Could-you give us your understanding or definition 5
of " design basis" as used in the phrase " design basis acci-6 dent"?
7 A
The design basis accident, as I understand it, is 8
a sequence of events prescribed as the foundation for the 9
safety evaluation of the plant.
For each design basis accident; I
l 10 '
there are established criteria for plant performance.
For the !
11 most severe, these criteria are the guidelines of 10 CFR Part 12 100, siting requirements, and expressed in terms of doses to O)
's 13 a hypothetical person under prescribed conditions.
14 The anaysis of these design basis accidents and the 15 comparison of the results of these analysis with the acceptance i
16 criteria then provides the basis for the safety acceptability 17 or not of the plant.
The course and consequences of these 18 event sequences depends on the performance of various systems 19 and structures and the design basis of these systems and 20 structures in the sense of the paragraph that you read is 21 therefore the conditions which arise from this sequence of O
22 evenes.
23 And the required functional capability of these p-A_j 24 systems and structures is the capability which is needed to Ace-Federd Reporters, Inc.
a 25 maintain the course of events within the acceptance criteria.
I L-
I 226 !,
I MPB/ob41 The paragraph which you read therefore tells us to l
/ ]'.
i tN.
2 take from the detailed and over-all description of the design 1
I 3
basis accidents the conditions under which the given system
{
(1).
or structure has to perform, which then become the design i
4 5
bases for the particular system or structure.
i 6!
Q Who chooses the design basis accidents?
7 A
The Commission.
The general principles are embodied '
8 in the regulations, principally in the general design.riteria, t
9; 10 CFR 50, Appendix A, and in some other places.
I 10 For example, the design criteria for emergency II core cooling systems are given in 50.46 and in 10 CFR 50, 12 Appendix K.
These are elaborated in the standard format and r~'3 (j
13 content for Safety Analysis Reports and in the Standard Review I4 Plans, and some of them are discussed.in more detail in Regula-15 tory Guides.
0 Q
So can I conclude from that that as a timing matter, I7 for a. given facility, whatever the regulations, Reg. Guides, I8 Standard Review Plans and so forth which are applicable to I9 that facility are going to determine which design basis acci-20 dents are applied from a timing sense?
2I A
That's right, except that this is one of the best
)
22 delineated and most stereotyped parts of our review.
And i
23 Chapter 15 of the' standard format and content tells in deteil
~
m l
24 which applicants to analyze, and a good bit about what has to i AceJederal Reporters, Inc.
25 be assumed.
l t
I 227 I
i MPB/eb42 1
Q Well, to zero in on that just a little bit, if a 2
licensee's application was being considered ten years ago, it 3
would be the regulations and SRPs or thei: equivalent that 4
were in existence ten years ago that would at that time define 5
the design basis accident as distinguished from in 1979, if 6;
someone came forth with an application they would have certain i
7' things applied there.
Is that correct?
8 A
That's not correct.
In particular with regard to 9
the regulations that's not correct.
10 Every plant--
I'm not qualified to practica law i
11 so what I'm giving is my technical understanding of the re-l 12 !
quirements.
()
13 Every plant has to be in compliance with the regula-14 tions at all times, so that all plants have to be in compliance 15 with the regulations as they now stand.
16 Now some of these regulations, for example 50.46, 17 when they are established or changed include clauses relating 18
.to how they are to be applied to reactors previously approved 19 under different regulations.
but all reactors have to comply 20 with all regulations at all times, is my understanding.
21 This situation is not the same with respect to
()
22 Guides, Standard Review Plans and Standard Format and Content.
23 The applicability of these is decided, first of all based on j ()
24 the regulations where it is explicitly or implicitly stated l Ace Federd Reporters, Inc.
i 25 and secondly, by the regulatory requirements review committee 1
l l
l
. a a
,n-
1 228 l
i MPB/cb43 1
which decides, for each new requirement not specified in the i
e x I
(
)
l 2
regulations, how it is to be applied to existing plants that 3'
were approved without regard to that particular requirement.
i l
4 Q
To what extent, if any. did the design basis acci-
-s l
5 dent concept influence the occurrence of and response to the l
}
t i
i 6:
events at TMI 2?
j 7
A Directly, not at all; indirectly, quite substan-8 tially.
Because of their technical difficulty and because ^ hey 9
are the areas of principal coraroversy and because of the idea 10 that they provide an envelope for lesser events, the Staff has II l tended to concentrate on the most severe design basis acci-i 12 dents.
(.l/
13 Since resources are finite, this has led the Staff
/'
I4 to neglect the lesser accidents.
The result is that the 15 sequence of events which occurred at Three Mile Island had not 16 been considered very much, although it had been considered bu 4 17 in nominal ways with respdct to the licensing of Three Mile 18 Island and other plants.
19 There is, for example, an analysis of small breaks, 20 small breaches in the primary system, and of course the stick-21 ing open of the power-operated relief valve at Three Mile
(_)
22 Island is such a small breach.
23 However, a substantial number of the factors which j
i 1
l j
24 were present at Three Mile Islan'd were not included in the l
l AwFMud Reorms, lm.
I 25 analysis.
So that one has to say that the events of Three Mile i I
L
229 l
\\
(PB/cb44 1
Island, which in some respects have had consequences more
(
2l severe than the most severe design basis accident, were not l
3lj enveloped by the design basis accident analyses, and it is now 7_
(~
4 necessary for us to reconsider how we are going to use the l
l Si design basis accidents in our work.
I I
I 6 !
O In use of the term " accident" in NRC jargon, that i
7 is, the commor. usage of it in NRC, does it include damage to 81 f acilities as well as adverse effects to the health and safety l
l i
9l of people?
10 -
A The context I'm using it in doesn't include any of 11 those niceties.
I use the term " design basis accident" 12 !
O Excuse me.
My question concentrated solely on the O
ia term eccident.-
14 A
I know, and I'm trying to answer it.
15 My use of the term " design basis accident" in this 16 testimony makes no such distinctions at all, but includes the 17 whole panoply of event sequences which are used in the safety 18 design basis of the plants.
19 I have a personal prejudice against the hair-20 splitting that goes on about whether any particular event is 21 an accident _ or whether it should be described by some other
()
22 word, and I meant no such distinctions when I used the term.
-23 O
So I can' :onclude then from that that when you say
(,)
24
" accident" it could indeed not involve injury to persons or,
, Am-Federal Reporters. Inc.
25 for that matter, to their health -- an adverse health effect
t 230 j i
@B/ob45-1 and it could still be an accident.
2 A
That's correct.
Q Thank you, i
3l
()
i i
4 In what manner, if at all, are safety requirements 5
issued by NRC structured so as to assist the utility in, to j
i 6
use their term, saving a shutdown?
This is of course in addi-f I
7' tion to the requirements being promulgated to protect against 8
physical injury to people or property.
9 A
This consideration comes in primarily in insuiing i
10 that actions which we want performed are not so inordinately l
11 expensive that there will be a strong impulse tu slight them.
12 If they are essential and if they're expensive, we require
()
13 them, but if they can be done in a less expensive way, we will j
l 14 be strongly inclined toward slanting our regulations in that 15 direction.
16 For example, we believe that it's very important to 17 provide frequent periodic tests of reactor protection systems 18 and we have now, over a large number of years, required that 19 the systems be designed in such a way that the tests can be 20 performed while the reactor is in operation without interrupt-21 ing operation.
()
22 Now in principle, we wouldn' t have to have this 23 requirement and if the licensee we$e so stupid as to design 1
()
24 his plant so that he had to shut it down every two weeks to Am FWwW Reo,wrs, lm.
25 test his protection system, the public would still be protected.;
1 1
231j MPB/ob46 1
But this is so large a cost and so stupid a design that we have,
('T l
\\/
2 required that the system be testable without interrupting I
3 operation.
_7_
So that these considerations do enter in somewhat of l 4
5 a secondary way.
3 6!
To summarize, if we want actions done that take a I
7:
Icng time or need to be done frequently we will sometimes re-l i
9; quire that they be doable without interrupting operation and i
91 thus get into somewhat the area of saving the shutdown.
I 4.062 to Q
Which safety requirements, if any, are aimed at 11 j mitigating the effects of unpredictable hazards and indeed 12 !
those hazards whose probabilities are extremely small?
j
(/
13 A
That's very difficult to answer explicitly.
Our 14 whole concept of defense in depth and safety margin is intended 15 as providing against the unknown and the unforeseen.
Since it 16 is by definition unknown and unforeseen, it is impossible to 17 be explicit about how any given provision protects against 18 any given unknown sequence of; events.
-1 19 This is behind our defense in depth requirements, 20 our redundancy requirements which are of ten criticized by 21 design engineers as inconsistent.
And Ehis accusation is true,
( s) 22 they are inconsistent.
s 23 As a rather trite example, we require that the l j-)-
s P P ng of a reactor be designed with large margins to withstand ii 24 q_
Me Fedwj Rgemrs, loc.
25 the design basis earthquake, but we require the containment of 1
i 1
i
232 i
MPB/cb47 1
the reactor to withstand SEnultaneously the design basis earth-
/~T
()
2 quake and the pipe break, which ought to be impossible.
l 3
The reason for this is that we know that neither
)
4 materials nor people are perfect and we provide this added I
5; margin in spite of the fact that we don' t know how such a i
6 combination of events could occur in any explicit way.
However,;
~
I 7'
experience has told us that neither the seismic design of the pi ing nor the design of the containment is without mistakes 8
P 9
and flaws, and we therefore take a good deal of comfort from 10 ;
this inconsistency.
And this provides, in a way which is not 11 l entirely explicit, against such contingencies as were embodied i
12 l in your question.
r~s 13 Q
Does NRC, as a matter of practice, define design
( '.
14 goals that must be met in a numerical fashion?
15 A
Yes and'no.
Yes, the design goals for, for example, 16 containment pressure capability are defined although the number,
I 17 isn' t given in the regulations because what's given in the 13 j regulations is, to revert to o previous question, a design i
19 '
basis accident or sequence of accidents and a determined margin 20t in the capability of the containment, structural margin.
21 '
We do not have a design basis goal or numerical
()
22 goals for reliability or other probabilistic quantities with a 23 small _nudber of exceptions.
The two exceptions which come to
()
24 mind are the meteorology to be used in dose calculations for l A F.omi n orwn w.
q l
25 design basis accidents which is taken at the fifth percentile, l
1 1
i 233 l
MPS/cb48 1
and a guideline for excluding very low probability external j
(s s) 2 events which' is taken at 10-7 per reactor year calculated l
3 conservatively, or 10-6 per reactor year calculated realis-(
4 tically.
I 5
Q The fif th percentile refers to what?
t 6;
A That the meteorology will be worse than that used l
7 in the calculation no more than 5 percent of the time.
l 8
0 All right.
9:
To what extent do design requirements as reflected l
10 in NRC regulations or other documents extend into the sof tware 11 !
that precedes company's or follows the making or release of i
12,
drawings?
Or to perhaps phrase it a little more generally,
()
13 when NRC talks about design requirements, how much of the paper 14 that accomplishes -- that accompanies a basic design are we 15 really talking about -- are you really talking about?
16 A
Of course there's an enormous amount of paper that 17 goes with.an actual design.
We review a small fraction of it.
13 [ Our principal reviews are directed toward the design approaches p
i li j' and toward the safety analysis calculations.
20 For example, for the emergency core cooling system 21 evaluation there is a series of ext sative computer codes which
(_s) 22 are called evaluation models and which have been approved, j
l 23 one by one, by.the S taff, in some cases I'm sorry to say FORTRAN, 24 line by FORTRAN line, but in any case there are voluminous A>Few3 Rgeners, Inc.
l 25 technical reports on the equations used, the values of the
[
i
t 234 l'
MPB/ob49 1
parameters, the comaarison of results with experiments, the
('d) 2 numerical methods, and we have a substantial enterprise in-3 volved in the review and approval of those evaluation models
)
4 for each plant.
l I
l 5
And in that case, for each reload in some cases, we i
t i
i 6:
receive a technical report showing the plant-specific assump-l l
7' tions used, the fuel distributions and so on, and that's what 8
changes with each reload, certifying that the approved model 9l was used and where there are options, which options were used, 10 and giving sufficient dete.1 in the results to show that the i
11 evaluation is satisf actory.
I? l Now that's all what you might call sof tware.
(")x
(_
13 We also review some aspects of the design.
Perhaps 14 the most detail we go into is in the instrumentation and 15 control and electrical systems where we review the piping and 16 instrument diagrams, the elementary diagrams of some of the l
17-most important systems, and actually confirm, jointly with l
I I3 Inspection and Enforcement, such things as the adequacy of 19 !-
channel separation and safety division, separation of wiring 20 l' and equipment.
21 Q
Would you -- When I say "you" now I mean the NRC
()
22 complex -- have any occasion to review procurement specifica-
-23
-tions that might govern the acquisition of components by l-(~N i
(_)
24 either'a utility or a major contractor?
l
' Ace-Federal Reporters, Inc.
25 A
Almost never.
The only exception I can think of is i
i l
l
235 !
l l
MPB/eb50 1
that sometimes when we review the environmental qualifications
~
(~)N 2l the paper we get is a piece of the procurement specification.
l
\\-
3 Q
Similarly, how about acceptance test specifications
()
4 on a given component?
5 A
We review some test programs but not the detailed i
6 specifications unless there is some particular question.
j i
l 7
We do review, and our Inspection and Enforcement
~
8 of fice is physically present at the moet important plant 9
acceptance tests.
And caring construction, the most important 10 tests are reviewed by our inspectors, some of the concrete II testing, for example.
12 ;
There is also the testing reviewed by the ASME code
()
13 people.
14 Q
How and by whom is the line drawn between so-called 15 safety systems and non-safety systems?
L6 A
The best written reference for that is in the 17 Standard Review Plans, and that was one of the principal efforts 13 in developing the Standard Review Plans, was to delineate as i
19 t well as we could what was cafety related, the scope of the 20 j review, and the acceptance criteria, which was not part of your i
21 question.
, ()
22 Q
I call your attention to a document I have here 23 which may very well not be the latest one, but for purposes of l
l
! ()
24 my question I thi..A it might be adequate.
This is NUREG-75/087, f Am 4 m > 3 R gorwes,lm.
l 25 the Standard Review Plan for the Review of Safety Analysis l
i i
f' l
236 l
i MPB/cb51 1'
Reports for Nuclear Power Plants, the LWR edition dated
(~n
)
>k/
2<
September 1975.
l 3i I wonder if you could amplify your previous response,.
()
! Doctor, by referencing any particular chapter headings or all 4'
I.
5 chapter headings as could be --
f 6!
A It's in every section, and if you like, we can look i
i 7j at an example.
I i
8 ~
Q No, it's not necessary.
j 9;
A It's one of the most important parts of that docu-j
~
i 10 l ment, and the only way it can be done is essentially item by i
l i
i 11 !
item.
l 1: ;
Q For our purposes here, just identifying it in that l
l' t
,r m
(_,)
13 way is sufficient.
t 14 But the next question is who draws this line between 15 safety and non-safety systems?
16 A
A large fraction of it is lost in the sense of time.
t 17 It was only written down and ratified in the writing of the 13 Standard Review Plan in the 1975 era.
1; l The Standard Review Plan was reviewed by various j
l 20 [ components of the NRC and accepted by the Director of the 21 l Office of Nuclear Reactor Regulation.
That's its cache t.
()
22 A large number of these decisions have been mdde l
23 one by one in case reviews quite a long time ago.
l
(
(b) 24 Q
I take it then from your answer that the review --
l Am FMeal Reporurs. IN.
l the distinction between the safety and the non-safety l 25 excuse me, l
l
237 i
i MPB/eb52 1
system might be done by any of a number of organizations within l t
Ot
\\_/
2 NRC, just as this Standard Review Plan reflects the activities I
4 i
-3 of many different organizations --
I 4
A That's not what I intended to imply.
5!
Q Perhaps you can clarify it.
t 6,
A The organization is the Of fice of Nuclear Reactor i
7 Regulation and its various predecessors.
Most of the work was
)
8 done by what was then called the Deputy Directorate for Technical Review of what was then called the Directorate of j
9j 10 Licensing which was the predecessor.
11 1 This work was going on at the time the NRC was t
12 ! being -- the AEC was being transformed into the NRC, and it was ll
()
13 the Of fice of Nuclear Reactor Regulation and in particular, 14 the Division of Systems Safety that produced this document.
15 Now a lot of these decisions were made in a particu-16 lar licensing context and were participated in by the ACRS, for '
17 example.
13 Q
But fundamentally today the decision is made within 19,
NRR as distinct from, say, Research or I&E7 l
20 A
Absolutely.
21 There'are some areas when new standards are being 22 developed where the Office of Standard Development participates '
f ()
23 in these decisions.
()
24 Q
And I take it--
May I assume that in terms of Ace-Federal Reporters, Inc.
25 approving that choice it follows the normal procedures within
238 i i
NOB.cb53 1
NRC which would be NRR as influenced by the Executive Director i
2 of Operations, the Commission, and ACRS as the case may be f
i 3
if it ever comes up?
(
4 A
That's correct.
The usual vehicle would be a 5, Standard Review Plan change which, if it was major, would bc l
l
\\
6l reviewed by the Regulatory Requirements Review Committee and i
7 the ACRS.
8 Q
My next question, Dr. Hanauer, is aimed at trying 9
to explore to what extent various. parties have been exposed to 10 l what I will call a safety awareness or attitude development j
11 l program.
I appreciate this might sound a little bit primitive i
12 l for an agency such as NRC, but bear with me, and if you feel 4
()
13 that the answer is positive or negative, be it what it may.
14 My quest in--
I'll address it first to the NRC 15 Commissioners:
16 Are you aware of any specific programs aimed at the 17 NRC Commissioners that would improve or increase.their nuclear 13 l safety awareness or attitude towards nuclear safety?
i 19 0 A
I hardly know how to answer such a question.
Every L
i i
20 time I address the Commissioners I hope I am improving their 21 nuclear safety awareness.
Their whole lives are dedicated to
()
22 nuclear safety awareness.
And that's the only answer I know l
l 23 how to give.
()
24 0-What about the supervisors within the Nuclear Ace Feders Reporters. Inc.
25 Regulatory Commission?
And I'm not limiting this to --
239 MPB/cb54 1
A I'm going to have to ask you to define " nuclear l
)
2 [ safety awareness."
m 3
Q All right.
/b t
1 A
That's what these people work on all the time, so I 4l I
S' must be missing something in the question.
i6' O
Well, I had a feeling that might arise, so I tried l
7l to get out of it when I asked the question tc begin with, t
Let'sl 8
There is within the safety managemont field--
9' say there are within the safety management field specific i
10 techniques that people use to create an awareness of safety j
li t among people at all levels of an organization.
Some people I
l 12 l call it " sa fe ty promo tion. "
,~
13 A ridiculous example which I don't particularly
( j 14 encourage is putting up a safety poster.
But it's a matter of 15 trying to insure that people understand totally their obliga-l 16 tions relative to safety, 17 Now I prefaced my remarks earlier by saying I'm not l
18 !
implying in any sense of the word that NRC does not have an i
i II 19 :! awful lot of this as the normal course of events.
My question O
20 l is aimed at whether any specific programs are identified to i
21 increase or improve the sa.fety awareness of the parties I 22 started to mention.
f i,
23 The Commissioners were first.
The second group I i
l 5
lll 24 mentioned were what I'll call the supervisory pecole.
If I Aa Few3 Recorurs. f x.
25 had to pick a grade level I'd say above GS-13 or whatever; I i
240 ;
MPB/cb55 1
don't know.
EJ 2
A Well, let me try and answer it, and it won' t be a 3<
direct answer.
l 4l The pioneering ef fort in this direction was by Theos i
I 5;
Thompson.
He was a pioneer in this field.
He was director of I
l 6:
one of the first nuclear engineering programs.
He has a long-7 time pioneer member of the Advisory Committee on Reactor i
I 8
Safeguards.
And at the time of his death he was a Commissioner.!
l 96 He devised, starting in 1965 at MIT, a series of 10 l short courses which goes on every year.
These were aimed pri-11 1 marily at industry people so that the guy working for GE or an l l
12 !
architect-engineer or a utility would have an integrated
.m
(,)
13 picture of reactor safety into which his job of designing pump 14 casings or performing nuclear core calculations could be re-15 lated in a safety context in a way that might not ordinarily 16 happen in his supervisory -- his ordinary supervision.
l 17 This program has reached some thousands of people.
13 j There are now similar programs at Northwestern University and ii l
i 19 d Georgia Tech, and one or two others.
Our people also attend l
a i
20 l these courses.
They are particularly suited for younger 21 technical staff members who are, in the same way as in industry, i
I em 22 put to work on some particular problem and might not have a
,j i
23 good understanding of their over-all safety significance.
i lll 24 We have no--
Strike that.
l Am FMerd Reporters, tm
}
25 We also have in-house a variety of educational I
241 l
l MPB/eb56 1
ventures, courses of one type or another.
The Of fice of Research I
(
2 is right now running a series of lectures to enlighten their l
3 technical specialists about some aspects of reactor safety to
(
4 give them a better over-all context.
t 5
We have a whole series of courses run by Inspection
{
6 and Enforcement which are primarily technically oriented to f
I I
train inspectors but which have a pretty good component of this '
i 7
8 sort of thing, and which staff members from other offices 9
attend.
i 10 Q
We' re zeroing in on precisely the nature of my 11 l question right now.
12 ;
A Yes.
Let me finish my answer, please.
()
13 0
Oh, I'm sorry.
14
'A For managers and for Commissioners we have no formal 15 programs along these lines.
I've seen a few Branch chiefs 16 at one or another of these activities which, because of my 17 educational background, I have a higher likelihood of being i
13 {
involved with than most of the people around here.
19 :
I don' t know of any explicit programs
'for managers 20 or Commissioners but the day to day discussions at that level 21 a're concerned with reactor safety and have a tendency to be in 22 the sam'e context that you' re talking about, and it doesn't
()
23 seem to be as necessary although --
(",jT 24 The direct answer is I know of no such programs Ace-Fedef!! Reporters, Inc.
25 explicitly used by Commissioners and higher management levels.
l 242 MPB/eb57 1
O Do you know--
Perhaps you've answered this and I l
_j 2l missed this, but do you know as a matter of fact that people 3'
from utilities like Met Ed are attending these kinds of courses i
4 in 1979?
+
l 5
A Yes, sir, I do know this explicitly.
6' Q
How about contractors like B&W7 7l A
Yes, sir.
l 8
Q Within --
9 A
The ones that they attend are typically the ones at I
10 l universities.
i i
l 11 i They also have in-house activities I'm less well j
12 l informed about.
I 13 0
Well, I guess maybe I ought to ask you this directly:l
'-)
l 14 Is there a nuclear safety course by that sort of 15 title given anywhere today?
i 16 A
Yes.
As a matter of fact I teach several.
I teach l
I 17 '
a nuclear safety course in an academic context at Catholic I
i 13 il University.
I taught it previously at the University of j
li a
19 il Tennessee.
It's taught at a large number of universities for, i
20 i typically, graduate credit.
I 21 There are these nuclear safety short courses that I l
l ll) 22 described taught at a number of universities that last typically l 23 one or two weeks.
I'm going Thursday and Friday to teach one 1
24 of them.
Ace + w1 Roorurs, Inc.
j 25 l
Q Do you know any source close by that I can go to to I
243 J
I GB/cb58 1
get a summary of those courses?
7,'
/
'ws' 2j A
I have them in my files and will furnish them for I
3' the record.
(
)
4 Q
I would appreciate it very much.
i 5
A The cummary will be examples rather than complete.
i 6!
MR. MILLER:
Off the record a minute.
i 7'
(Discussion off the record.)
i 8
THE WITNESS:
Back on the record.
I 9
It would be easy for me to submit for the record a i
10 f summary of two academic courses I have taught, one at the i
11 f University of Tennessee and one at the Catholic University of 12 ; America, and brief summaries of the three one-week type courses
()
13 that I' ve participated in at three dif ferent universities.
14 Is that the kind of information you want?
15 MR. MILLER:
It certainly is, and it would be most i
16 helpful to our inquiry.
l i
17 THE WITNESS:
I'll submit it for the record.
l l
i3 BY MR. MILLER:
1 19 Q
Do you know of any specific ef fort that's been t
20 '
undertaken by anyone to try to alert our distinguished members 21 of Congress in nuclear safety matters in the same safety
,g()
22 awareness attitude in the education sense?
j 23 A
I've been at various colloquia at which distinguished i
ew()
24 members of Congress have been attendees or panel members.
We AwfMwd Reporurs, W.
l 25 brief members of their staffs quite regularly on safety matters.
244 I
I don't know of any organized courses of the type j
MPB/cb59 1
(s k-)
2 you describe that are attended by distinguished members of i
3 Congress.
4 Q
Has any program been implemented, in the old days I
i 5
by AEC or currently NRC's auspices, or anybody for that matter, to try to enlighten the public on the basics of nuclear safety?
6 7
A There's a large number of such efforts under various 8
auspices.
They have varying degrees of partisanship.
There are of course a number of efforts supported o
10,
and performed by the antinuclear community.
There are a 11 l number of efforts supported and performed by the nuclear l
12 community.
Westinghouse, for example, has a big lecture program I
()
13 that goes out into the communities and addresses the League 14 of Women Voters, and so on.
15 All the utilities have programs of this sort.
They 16 are, to some extent, suspect as partisan.
17 The American Nuclear Society has a program they are la very proud of.
I find it rather partisan also.
19 There's a good bit of this sort of thing under all I
20 kinds of different auspices.
21 Q
My next question --
If 22 A
I have to say one more thing.
23 0
I'm sorry.
()
24 A
The Nuclear Regulatory Commission has a Public Am-Fewd Recturs.1x.
1 25
-Information Program and you should obtain the' details of it I
245 iPS/cb60 1
from the people who are in charge of it.
l 2;
Q My next question I'm almost hesitant to ask, but I'm 3
going to do it anyhow.
And if you don't understand the 7( )
~'
4 phraseology or you think it's a ridiculous question, please 5
feel free to tell me so.
I 6!
I would like to know who the chief safety of ficer is !
7 o f N RC.
I 83 A
The Chairman of the Nuclear Regulatory Commission.
j 9
Q Who is the most responsible--
Excuse me, strike j
l 10 l tha t.
II l Who is the person most responsible for decisions Il j related to safety as influenced by NRC activity?
n()
13 A
The ultimate responsibility for decisions is with 14 the Commission.
The day to day decisions are of course mdde by 15 the Staff.
16 The actual licenses are signed by the Director of i
17 the Division of Project Management.
The amendments are signed 13 q by the Director of the Division of Operating Reactors.
l~
h l
19 '
The major decisions as to what requirements shall be !
i 20 imposed are signed by the Director of the Office of Standards l
21 Development or the Office of Nuclear Reactor Regulation, r'(,s 22 depending on who has the jurisdiction.
The decision is made or l l
23 ratified by the Regulatory Requirements Review Committee.
How-r~,
i
()
24 ever, the individual reviewer or the individual project manager l Am4Wwd Annners, inc.
25 has considerable latitude in making decisions on individual I
l i
246 l l
MPB/eb61 1l cases, subject to appeal.
\\
2 There is an appeal procedure within the Staf f whereby
.I I
3I either a reviewer or a utility can appeal to successively
(
)
4' higher levels of management and be heard.
So that the deci-i l
Sj sion responsibility ultimately is as I have stated, but if i
6!
there is not controversy, the decision can be made at a much 71 lower level.
i 8
Q Well, I was seeking or course identity, theidentityl l
9 if at all possible of the officer, person, if you want to name 10 it that way, most responsible for the decisions.
11 l A
Well, I'm trying to tell you that that question is, 12 l in your words, ridiculous.
l es I )
13 '
Q All right.
Let me ask another one just like it.
t, 14 Who or what office is most responsible for advice 15 relative to safety matters?
16 A
I don't understand.
17 Q
Are you familiar, in management terminology, with i
15 y the distinction between line functions and decision functions j
it 19 l and Staff functions, meaning advisory functions?
20 '
A Yes, I am.
21 Q.
My question is aimed at the Staff functions in the k
22 advisory sense.
I would like to identify if we can that office 23 which is most responsible for advisory functions relative to l
i
)
24 safety within NRC.
s__
Aa-Fewd Reporters. lN.
f 25 A
The decisions are made as I described.
Most of these!
r
~
247 MP3/eb62 1
people who have decisions -- or organizations who have the
,m i
sj 2
decision responsibility don' t have any substantial advisory 3I organizations.
O s
/
The principal advisory organization to the Commission--
' ' ~ '
4 i
t 5
There are three.
l There is first of all the statutory Advisory 6
i 7' Committee on Reactor Safeguards, whose advice is formally 1
1 rendered to the Commission but which is in f act mostly to the i
8 I
I' 9
senior NRR staf f and doesn't need direct Commission interven-10 I tion.
l 11 l The Commission is also advised by an internal group l
12, called the Office of Plans and Evaluation--
Let's get that l
l (c) 13 title correct.
This is the Office of Policy Evaluation which 14 serves in a direct advisory capacity to the Commission.
15 And of course the third component is the entirety i
16 of the Staff which in many ways serves as advisors to the I
i 17 Commission besides its decision function for those things that 13llhavebeendelegatedtoit.
ll 19 i Now within the line organizations of the Staff there :
l i
20:
is a much less formalized advisory function, although some of j
i i
21 the principal Staff officers have subordinates whose title 22 is advisor in one way or another.
I serve, for example, as i
(l l
23 technical advisor to the Director of Regulation and then to i
I ll) 24 the Executive Director for Operations, but this function is A&Fue ai Remners, tre.
25 much less formalized than the ones I have described.
I i
248
{sB/eb63 1
O At any time prior to TMI 2, going back even into
/~'l 2j your recollection of AEC activities, was any consideration ever s,
3l given to establishing a Staff safety office in addition to the rs I
4 safety tasks which obviously are assigned to all organizational.
Sl segments, virtually all of them at least?
l t
l l
6:
A Your question seems simplistic to me.
The function l
l 7'
of the whole Staff is safety.
And when I think of a Staff i
8 safety office I think of an of fice ancillary to a staff or 91 organizations whose prime function is something else.
I think t
i i
10 j the Staff is the safety office of the nuclear enterprise.
c ll i The explicit answer is I don't know of any.
i 12 Q
Has safety technology ever been applied within NRC
()
13 as a technical specialty other than as related to certain 14 aspects of, say, reactor design and safety, or others?
I'm 15 sure there are many more that you could name than I could.
16 A
Your question implies a restricted definition of 17 l safety technology which I ought to know before I answer the i
15 l question.
t 19 4i Q
All right.
Let me expand on that.
I 20 Safety technology as I'm thinking of it is the body i
21 of knowledge which can be applied across many -- or across
( 3 22 the. lines of many endeavors such as not only nuclear activity l
ts 23 '
but transportation, construction of railroads, driving a car.
j l
24 Does that help clarify my meaning of safety and 9
A* wmi neporte,s. inc.
j 25 technology?
l U
i 249 j
1 A
Well, we think that's what we do although we don' t MPB/eb64 (q
i 2
have very many people whose title is safety engineer or whose
'w 3
academic degree is safety engineer.
We do have some.
So we
\\
4 think that's what we do although it is directed toward a i
5 particular segment o f technology.
6i O
Well, I can be more specific:
i, 7
Are you aware of any job titles or assignments that 8
are not nuclear safety peculiar, if I may put it that way, and I
r 9
yet are clearly related to the safety technology as we have j
l 10 l just defined it?
t 1
II l A
No, we' re pretty much functionally organized, but 12 :
my old job as Technical Advisor to the Executive Director for l
13 Operations could have that kind of a title, and there are a
(,,)
14 number o f o thers.
We just don't use that word.
15 MR. MILLER:
Off the record.
l 16 (Discussion off the record.)
i 17 MR. MILLER:
Back on the record, please.
l' 1
I3 BY MR. MILLER:
ll Hj Q
Going back just one more time to AEC, was there any i d
20 particular organizational segment there where you would find 21 people more active in accident prevention than perhaps some
./+()
22 other part of the organization?
l 23 A
Yes.
l Q
What would that be?
9' 24 Aa-Merc4 Rgoners, lnc.
l 25 A
I ' m try to describe it.
i
I 250 i
d I
MPB/eb65
.1 There were a number of segments of the old AEC that p/
were particularly involved in accident protection -
prevention. l s-2 4
3 There was, for example, the Division of Operational Safety 1
("T i
k##
4 whose purview was AEC facilities and that dealt both with 5
prevention and mitigation and whose goals was not only protection i
6!
of the health and safety of the public but maintenance of the i
7' AEC mission and prevention of interruption of the mission as 8
well as injury of the AEC people.
9; Since the NRC has no facilities we don't have that I
i 10 function.
j 11 f There was also the various development divisions of I
I 12 ! the AEC.
There was Reactor Development and Fusion Development
}
f) 13 and Physical Research, and all kinds of development activities V
14 now in the Department of Energy.
And as part of their develop-15 ment programs they had safety considerations and accident 16 prevention as important factors.
17 Q
Okay.
Just a couple or three more here, la ll On uthe subject of quality assurance do you -- and I 19 il might say astdefined most broadly in the SRPs.
Is this where 20 one would find safety programming extending both through the 21 design and development phases on into operations?
..I 7
22 For example, as I read the SRP we referred to l
/
t 23 earlier, at least the outline of it,only in ' Chapter 15 I be-('a
()
24 lieve it was--
Correction, it was only in Chapter 17 did I see i Am-Fmw3 Roorurs, ls f
25 anything that sort of tied together the safety activities j
i-l i
I
251'
@B/cb66 -
1 during design and construction and safety activities during
[']
N/
2 the operations phase.
3 Is my impression incorrect here?
If so, please l
O~/'
4 refine it.
5 A
Yes, it is.
The whole stated Review Plan is a plan i
I 6,
of how license applications are reviewed.
Now the license i
7 application has to present the design of the facility, the 8
Safety Analysis which shows that the design meets the safety 9
criteria of the facility, and the licensee's capability to 10 design and operate the facility.
11 !
Now the quality assurance program is something the 12 '
licensee has to do to show that he is capable of designing and
,~m N) 13 operating the facility safely.
And so in a certain chapter 14 of the Safety Analysis Report which he submits he has to 15 describe his quality assurance program which ensures that all 4
16 of the other things in his Safety Analysis come true.
17 And the chapter in the Standard Review Plan tells IS the NRC reviewers how to review that chapter in his Safety
~
19 lll Analysis Report.
I 20 '
Now the purpose of his quality assurance program, 21 as I say, is to make all the other things he does come true, f%
(,)
22 to assure that the plant is designed as he says it's going to 23 oe designed, to insure that the Safety Analysis is done
(
24 correctly, and
- hat the assumptions made in it come true in AwFmv0 Rworws, lm.
25 the design and operation of the plant, to assure that the i.
252 f
MPB/eb67 1
operating organization which he sets forth as technically and j
)
managerially adequate to operate his plant will in f act do what {
2 he says it will do and maintain through the life of the plant 3
/~}
a correct and adequate set of actions to make that part of the l
/
4 1
5 analysis come true.
l So that although it is in only one chapter that you 6
see how the Staff is going to review the description in the y
I Safety Analysis Report of the quality assurance organization, 8
the function is needed throughout all of the things that the 9
10 '
applicant does.
11 i 0
If we think of safety management now, that is those l
12 tasks which a licensee takes to guarantee to implement an 13 effective safety program, are these not -- do these not fall
(
14 basically within the purview of a
quality assurance program?
15 A
No, sir, not in my opinion.
16 Q
Thank you.
- 7 A
The safety functions have to be performed by the i3 ) applicant's line management and the quality assurance program I
~
19 ;l during plant operations is a separate audit function to make I
20 i sure that they do it, to detect any slackness or errors and 21 report them to the company management so they can be corrected.
[)
22 Quality assurance does not by itself do anything v
23 except to insure that somebody whose line responsibility is to
()
24 do something does it correctly.
Ace-Federal Reporters, Inc.
'5 25
'O Dr. Hanauer, I' assume you're reasonably familiar l
i l
i 253 l
MPB/eb68 1
with Part 21 of the regulations that deals with the reporting
(%
\\
2 of safety deficiencies to the NRC?
i 31 A
Yes.
[. #
4 Q
In your opinion, does.this part in any way inhibit j
l' 5
the reporting of human-error type information by the licensee?
I 6!
A No.
My experience, which is quite limited, is that i
7!
it enhances it, that the people who are taxed by Part 21 8
with this new responsibility are taking it very seriously.
9 0
It is true, however, that the people you are refer-10 ring to who are taxed are really the managers of the activity.
II A
That's right.
And I've seen some evidence, which is 12 l hard to quantify -- it's the way people talk in conversations --
13 that this has made these managers more aware of their respon-14 sibility to find out and report this sort of. thing, which 15 perhaps in some organizations they might rather not have known 16 about before.
17 Q
Now I think my question really is aimed at the worker,,
13 take a control room operator or somebody who works out in the I9 plant, maintenance or what-have-you.
20 What incentives under existing NRC rules or any 21 other does he have for going in and admitting that he made a 22 mistake?
.23 A
He has some incentive.
His incentive is the require-24 ment to -- is his responsibility to protect the public and his Am-Federst Reporters, Inc.
25 responsibility to be truthful to the NRC inspector.
i 254 MPB/cb69 1
The operator in the control room does not have a it-2 Part 21 responsibility directly, as I unders tand it.
He has t
3 two strong disincentives to report his mistake.
One is that he c
'v' 4
may get disciplined in his company and the other is that he may s
i 5
become disciplined by the Nuclear Regulatory Commission, which I
i 6!
has occurred.
7 This has to be counterbalanced by strong disciplinary :
i 8
measures in his company and by activity by NRC inspectors to I
9 overcome these disincentives as well as by his own moral I
10 j character.
i 11 i Q
Has any program, to your knowledge, ever been sug-l 12 gested to allow at least anonymity and perhaps immunity from
/
l 13 censure by either the company or NRC in trade for more open 14 revelation pf errors that people might make?
15 A
Yes, there have been such proposals and they haven' t 16 worked out very well.
On at least one occasion we received 17 derogatory information under a promise of anonymity which we I
13 {were not able to keep.
I il
~
19 5j On at least one other occasion--
On several other i
l 20 occasions people who have spoken up have been fired.
l 21 On one occasion we have suspended a construction
}
i h
22 permit in order to investigate such an occurrence.
In this f
23 particular case it went to arbitration under the employment f
1 l
(/,j 24 agreement with the company.
The person was reinstated before
~
Ace Feder:$ Reporters, Inc.
25 we got around, in our ponderous process, to deciding whether
t l
255 '
FIPB/eb70 1
we could or should do anything.
/
- 1
(,/
2 Our writ doesd' t run to the employment security of I
3l these people.
We cannot guarantee them immunity, and our
.?
l N
4' record has not been very good.
We have preserved--
I was going v'
1 5
to say we have preserved anonymity but I don' t think that's I
6 quite right.
7 We have received communications whose sources we l
3' don't know and investigated them and found them to be true.
9j I don't know what our record is in preserving anonymity, excep t f l
10 l I do know one case where we were forced to disclose the name.
11 j Q
Do you feel that a program, if it could be worked j
t 12 out -- and I'm not minimizing the difficulties in doing so --
> [~'}
13 but do you fee 1 a program that would encourage more open dis-va 14 cussion of human errors, while at the same time protecting 15 certainly anonymity and at least some degree of immunity from 16 censure, do you feel such a program would be desirable within I7 NRC today?
l 13 A
I think it's strongly desirable to promote more open i
1 190 discussion.
I think it would have to be on the basis of 20 '
anonymity and not on protection.
I have seen protection programs 21 in which false or true confessions were made in order to preserve P
22 employment and I don't want any part of it.
4 23 MR. DIXON:
Off the record.
l l
24 (Discussion off the record.)
l l Ace r c3 Reporters, loc.
I 25 MR. DIXON:
Back on the record.
i
t 256 l
l MPB/eb71 1
BY MR. MILLER:
(~'1 l
k-2
-Q Let me ask you my final question, Dr. Hanauer.
3 Are there any observations you'd care to make re-4 O
s 4
garding safety engineering and management practices at NRC 5
or, for that matter, at utilities or contractors that you think l I
i.
6 would fall under the heading of safety engineering and manage-7-
ment lessons learned from TMI 2?
8 A
I think there are several.
I have already testified 9
at some length to some of them.
10 I think that a substantial improvement is required 11 in the management of the industry; that the idea of what the I,
12 ' NRC requires as what's safe enough is not satisfactory; that
'(
13 the partial abdication of industry responsibility for safety 14 in some organizations is not satisfactory.
And I'm encouraged 15 by some signs of change in attitude which is nice, and actual 16 functioning which is a whole lot more important in some compo-17 nents of the industry.
13 An obvious example is the operating training and 19 i certification initiative being spearheaded by the Electric 20 Power Research Institute.
21 A second area in which we have to do a lot better
/'5-(,;
22 is in defining safety goals.
Relevant to this is some discussion,
.23 yesterday of quantitative probabilistic safety goals, a very (n_)
24 difficult area, in discussions today of design basis accidents Ace-Feder2 Reporters, Inc.
25 and the bo. derline between safety related and non-safety related ;
I I
l
257 i
i MPB/eb72 1l equipment, about which a great deal has been said here and
\\j 2
elsewhere.
3 Another area I think is very important is that the
,(
NRC should take its own medicine as far as quality assurance 4
5, is concerned, and that the NRC product should be subject to the,
6i same kind of quality assurance audit that the industry we 7
regulate is subject to, or an equivalent at least.
i 8l Those are the major ones.
l 9l Q
Thank you.
I i
i 10 j hm. MILLER:
Off the record just for a minute.
I 11 l (Discussion off the record.)
j I
i 12 MR. SCINTO:
Back on the record.
"h 13 BY MR. SCINTO:
14 Q
Dr. Hanauer, you've been asked just now, and before 15 by Mr.Parler, and I'm giving you a general opportunity to make 16 some additional comments.
17 I'd like to ask you at this point if during the l
I 13 !
course of your thought process anything else comes to your l
ll
.l -
19 j mind that you think would be of value to the inquiry or that l
i i
20 i you would like to make known to the Special Inquiry Group, I
21 '
please don' t hesitate to call me and we'll arrange for that a
22 information to come to us in any way it's convenient to you.
(
23 A
I'll keep it in mind.
l
,7
( )
24 Q
Please do.
' AceMederd Reporters, Inc.
25 MR. MILLER:
I believe we would also like to ask
258 MPB/eb73 1
this gentleman here if he would care to ask any questions at 2
this time.
I 3l MR. DIXON:
No, I have no questions.
g L:
i 4j MR. MILLER:
In conclusion then let me say this is V
i 5
an on-going investigation and although the questions have been,
i 6'
completed today, we may need to bring you back for further 7;
depositions, Dr. Hanauer.
We will, however, make every effort i
i 8;
to avoid having to do so.
+
i l
1 9'
We will now recess this deposition rather than 10 terminate it, and I want to thank you very much for your time.
11 i I know it's been very trying during your busy hours.
12 (Whereupon, at 12:00 noon, the taking cf the
\\_)
13 l deposition was recessed. )
f o
l 14 l
i 15 l i
i I
l 16 l I
i I
- 71 l
iap 1
4 19,i 20 t
21 22 l
k 23l l
l I
I
(~~
\\
24 f AceIFederd Reporters, Inc.
25 i
,