ML19308C549
| ML19308C549 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear, Crane |
| Issue date: | 11/27/1979 |
| From: | Creswell J, Rueter D ARKANSAS POWER & LIGHT CO., NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001280578 | |
| Download: ML19308C549 (43) | |
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Transcript of Proceedings NUCLEAR REGULATORY COMMISSION TMI SPECIAL INQUIRY GROUP INTERVIEW 0F DON RUETER l
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PLACE:
Little Rock, Arkansas DATE:
Tuesday, November 27, 1979 (THIS TRANSCRIPT WAS PREPARED FROM A TAPE RECORDING. )
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ACE FEDERALREPORTERS,INC.
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TMI SPECIAL' INQUIRY GROUP l
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Little Rock, Arkansas i:
8 Tuesday, November 27, 1979 9
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VOICE:
Okay, we can get started.
It's November l
2 27th, 1979, and it's 11:05.
We're in the conference room on l
3 the eight floor of the Arkansas Power & Light offices in r-,
4 Little Rock, Arkansas.
'~
5 This is an interview with Don Rueter?
6 VOI CE t Rue ter.
7 VOICE:
Rueter.
I ts R-u-e-t-e-r.
He's director, 8
technical and environmental services, Arkansas Power &
9 Light.
Present also is Stephen Riggs of the law firm of 10 House, Holmes & Jewell, representing Arkansas Power &
.1i Light.
12 For the TMI - NRC Special Inquiry Group is 13 James Creswell and Frederick Hur.
Q Don, we've given you a copy of a document entitled 14 (a')
15 "NRC Special Inquiry Group Witness Notification."
Have you 16 read tne document?
17 b^Jin VOICE:
Yes, I have.
Q VOICE:
Do you understand the informa tion 18 19 contained in the document?
20 b ainn VOI CE:
Yes.
21 Q
VOICE 2 Okay.
If you would start out giving us a 22 brief history of your nuclear-related educational 23 experience, for the record.
24 hh VOICE:
Okay.
I have a bachelor of science degree 25 in nuclear engineering f rom the University of Missouri at
l l
l8633 01 02 3
NRCmte 1
Raleigh. I've been with Arkansas Power & Light Company since 2
1971, which is the year I graduated f rom college.
My 3
experienc here has been almost entirely in the nuclear 4
field, working first on nuclear steam supply system design 5
review, then moving into the licensing area, which I worked 6
in f rom 1972 until 1977, at which point I was promoted to my 7
present position.
8 I still have responsibilities for licensing.
I 9
also have responsibilities for quality assurance, nuclear 10 f uel management, and chemical and environmental, li metallurgical programs for the company.
12 VOICE:
Okay.
Jim?
13 Q
VOICE:
Don, could you briefly describe what your 14 responsibilities are in your present posi tion ?
)
15 O
VOICE:
Okay.
I'm responsible for all interface 16 with the Nuclear Regula tory Commission, the Washington 17 office.
The plant staff is still responsible f or the 18 interface with I&E and the resident inspector.
Tha t's 19 through our licensing section.
20 The licensing section also has some 21 responsibilities for interf ace w! th other f ederal ano state 22 agencies for the permitting of nuclear and fossil fuel power 23 plants.
I he*te responsibility for the quality assurance 24 programs of Arkansas Power & Light Company, for the 25 procurement, design, review, of nuclear fuel following the l
l
$6330103 4
NRQn te 1
opera tion of the. f uel rods in the core, storage and disposal 2
of the fuel, ul timately.
3 Also, I have responsibilities for the 4~
environmental monitoring programs at our nuclear and fossil
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5 power plant sites, and other special technical services to 6
all of our power plants in the areas of chemistry, 7-metallurgy, welding, radiochemistry, and those types of 8
areas.
h VOICE:
I see.
Who do you report to, Don?-
9' 10 VOI CE:
I re por t to Bill Cavanaugh, who is vice 11 president, generation and construction.
12 h
VOICE:
And how long have you served in your 13 present posi tion?
14 h
VOI CE:
Two years.
h
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15 VOICE:
Two yeara.
So tha t would put it back in 16 1977?
17 F)
VOICE.
Tha t's right.
h 18 VOICE:
Now, discussing certain ma tt rs with 19 Mr. Cavanaugh, he indicated that you were aware of an event 20 tha t took place back in 1974 with the f ailure.of the 21 power operated relief valve.
Is that correct', or did I i
22 misinterpret something?
23 A
VOICE.
I m aware of that.
24 bM VOICE:
This is Jim Creswell speaking.
l- -
25 Apparently I misunderstood what Mr. Cavanaugh
(
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l
8633 01 04 5
NRCa te I
said, another individual was more f amiliar with the power 2
opera ted relief valve problem.
Basically, what Mr. Rueter l
3 was involved with was the pressurizer level probl em s.
So 4
could you briefly describe what your involvement has been in l
~
5 that particular area?
6 VOICE:
Well, with my responsibilities in the area 7
of licensing and also looking at the design of the nuclear l
8 steam supply system at tha t time frame, I was involved with 9
working with the plant staff and B&W in resolving the 10 problems tha t occurred in poder power ascension program, 11 When we began losing indication of the pressurizer level 12 following trips from high power level s.
h 13 VOICE:
Okay.
Don, who did you usually deal with 14 at B&W in the discussion of these problems?
(
15 VOICE:
Back in tha t time frame it was the project 16 manager at B&W.
I believe the pe r son - there were two 17 dif f erent people that were in that time f rame that I 18 recall.
There'd be Hal Baker and Dick Govers.
h 19 VOI CE :
Okay.
Now, when we say "this time frame,"
20 tha t is like back August of '74 to well into 1975?
21 VOICE:
That's right.
h VOI CE:
Well, when did you first become aware, 22 23 Don, that there was some problems with the pressurizer level 24 a t ANO-l ?
25 dwipit VOICE:
It was during the power ascension testing
$633101 05~
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program that I became aware of it.
I believe the first
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2 ind'ication we had that this, as I'm recalling here, was 3
after about the 40-percent power level, the trip f rom 40 l
r 4
percent, that indicated that we might have a problem with 5
level indica tion being lost. at higher power levels, trips 6
f rom higher power levels.
7 And we started looking into it at tha t point in 8
time, as I recall.
h VOICE:
Okay.
About when would that have'b'een, 9
10 Ron -- Do n.
I'm sorry.
.11 VOICE:
'That would have been in early f all of 12 1974.
We were in our power ascension testing program.
-13 h
VOICE:
Okay.
Now, was it an operational
!4 characteristic thac you observed here in the testing program 15 or. was it some sort of communication problem, that B&W had 16 pointed the problem out initially?
I7 h
VOI CE:
It was an operational characteristic that 18 was found during that testing program.
~
19 VOICE:
Atter a 40 percent reactor ~ trip?
20 VOICE:
Tha t's right.
h VOICE:
Could you briefly describe how the~ problem 21 22 was identified and how it was conveyed to B&W?
23 VOICE ' As I recall, the problem was identified by
~
24-reviewing the records of the pressurizer level following 25 that reactor trip and subsequent trips, where the level
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I633-.01_06 7
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I f ell lower than was expec ted and was set forth in the 2
a cceptance criteria in the test procedures.
3 h
. VOICE: - Did that 40 percent trip violate some sort 4
of acceptance criteria?
5-M 4-VOI CE:
I don't recall exac tly whether it violated 6
an acceptance criteria or whether it was real marginal.
It 7
was suf ficient that it got us to start looking into why the 8
problem was there.
h VOICE:
There was a concern, anyway.
9
_10 VOICE:
Right.
h VOI CE:
So somebody on the plant sta'ff was 1I 12 reviewing the prersurizer level charts or something like 13 that, reactimeter traces, to identif y the problem?
The 14 operators identified it?
I'm trying to get 'a handle f or how
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15 something like that gets identified.
16 M
VOI CE:
Well, something like that would be 17 identified as part of any testing-program at the plant in 18-reviewing the results of the tests as compared to acceptance j
19 criteria.
20 VOI CE:
Okay.
So it would be the test engineer 21 would.do it, would recognize it?
-22.
h VOICE:
It could be the test engineer.
It could l
23-be the operator perf orming the, test as he's running down the l'
24 checklist.. Someone that.would be involved with performing h
25:
the tests would identify it.-
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VOICE:
Well, how did you get involved?
2
$4u;the, VOICE:
I got involved because of my.
3 responsibilities with - I was serving in quite a bit of the (3
4 interface with B&W at the time.
When I say I was in the A.)
5 licensing, my primary responsibilities at that time were in o
the licensing area, I had other responsibilities in 7
coordinating work with B&W on the nuclear steam supply 8
system and that sort of thing.
kI VOICE:
Well, I guess what I'm trying to get, did 9
10 somebody call you up on the telephone or did somebody send 11 you a memo?
Let's see, were you down at the site?
12 M
VOICE:
No, I was here in Li ttle Rock.
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13' h
VOICE:
How did you find out about it?
14 b<4D/A VOICE:
I don't recall exactly.
It would have
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15 either been by -- most likely by a letter or some 16 correspondence from the plant staff.
h 17 VOICE:
Who would normally send that letter to 18 you?
19
[wf4 VOICE:
It would normally be coming f rom the plant 20 manager to the -- I gue ss, back at. that time f rame, also to 21 Bill Cavanaugh.
h VOICE:
Okay.
Would it have been like 22 23 Mr. Anderson sent you a memo that says:
Hey, we've got a 24
-problem here?
hd r'
25 VOICE:
It may have been by that mechanism, or it L)Y z
8633:01 08 9
NRCm te l_
may have been the results of a test working group review of 2
test results, or some thing like that.
h 3
VOI CE:
Wha t is the test.orking group?
,n 4
WI4 VOICE:
Test working group was the group that had 5
been established during the testing program, that reviews 6
the results of all testing that's performed.
h 7
VOICE:
Did you have the impre ssion that they had 8
looked a t this thing before they sent it up to you?
haft) 9 VOICE:
I don't really recall back then whether 10 they had looked at it before I was notified of it or not.
h
. 11 VOICE:
So once you found out about this. thing, 12' wha t did you do?
13 M
VOICE:
Well, I - I'm trying to recall f rom five 14 years ago, but what I was involved with was looking at what O
is
-- tetxtao to B " ebo"t ~ net co"to be ceustao the 16 pressurizer level to be dropping, seeing if they had had the 17 problem on previous units, since we were not the first unit 18 of this design to be started ups comparitig -- you know, 19 getting B&W to start looking at the traces on our 20 pressurizer level and other parameters, compared to trips at 21 other units, ge tting them to start looking at that sort of 22 thing; and letting us know where the diff erences - what 23 diff erences existed between the plants that might be 24' contributing to it and was tthere something that was N
25 diff erent about ANO that should be corrected.
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$633'01 ~ 09 10 NRCmte i
VOICE:
Was B&W cooperative?
2 bre.
VOICE:
Yes.
3 h
VOICE:
Okay.
Who'd you talk to at B&W about q
4 that?
Wa s i t still tho se two guys, Baker and Govers?
5 deud*
VOICE:
That's right.
h VOICE:
Did.you ever talk to anybody like Bob 6
7 Winks?
[@
VOICE:
I don't know if I talked to him 8
9 specifically, but I know that he, from looking at a report 10 that B&W prepared, that he was involved in preparing it.
I 11 don't recall having direct communication with him.
Q VOICE:
You mentioned that you wanted to get B&W 12 13 started looking at your plant's response compared to other 14 plants.
What, af ter they'd done this comparison, wha t did O
is it show?
[lu2x VOICE:
As I recall, there were a couple 16 17 differences in the response of the secondary system, the 18' steam system, as far as wha t pressure the secondary side of 19 the steam generators was maintained at following a reactor 20 trip, which of course depends upon the response of the main 21 steam saf eties, the turbine bypass system and the f eedwater 22 system.
23 Also, there's a difference in where the level taps 24 are located, the level range on our pressurizer versus O
25 earlier units.
O
8633 01 10 11 f
NRCate
-l VOICE:
Why wa s tha t, Don?
-2
[kt8vX VOICE:
That was a change that was made by B&W in 3
the manuf acture of our pressurizer that narrowed the range r~s 4
from 400, I believe it was in the older units, to I think
_ij 5
ours is 320-inch range.
h VOICE:
Well, why did they do that?
6 7
kdg.
VOICE:
Well, as I recall, they did it in the 8
f actory, with concurrence f rom their design people that 9
there was no problem with making the change.
They felt that 10 range was adequate, and it was probably something in the
.Il manuf acturing process that made it appropriate to make that 12 change.
13 VOICE:
Do you know what that was, what tha t 14 problem in the manuf ac turing process was?
(
')
15
[ut2hc VOICE:
No, I'm not familiar with that.
We looked 16 into it to see if it was a problem for us and found that 17 having the narrower range did not cause a problem in the 18 response of our plant compared to other plants.
So you 19 know, that was not a contributor to or did not cause a 20 significant safety problem or anything.
So at that point it 21 wouldn't be pursued.
h 22 VOICE:
Now, Don, you're manager of OA or you have 23 some responsibilities for the QA program at Arkansas Power &
24 Light, maybe total responsibilities?
rn 25 d.
VOICE:
The manager of quality assurance reports u
l s633 01.11 12 NRCate 1-to me.
2 VOICE:
Administrative 1y, okay.
Let me ask you 3
this, just general philosophy.
You have a component tha t (3
4 you're going to install in your reactor system.
The y
5 vendor's going to supply you the component.
And he's going 6
to change.the design of it.
7
. I s tha t the sort of thing that your QA department 8
would be interested in?
9
/) d VOICE:
They would be interested in it from the 10
. standpoint of seeing that the change was properiy documented
.11 and approved before it was made.
h VOICE:
Well, did you guys do that in this 12.
13 instance when this level tap was changed?
14 448n.
VOICE:
I don't recall that we did, since we
_O Is otoa't - t ~outo essume a t.
siace ~e oida't kao it es 16 any different f rom previous units until we got into this i
17 testing program.
16 VOICE:
So the correspondence indicates and the 19 s ta temen t 1 that you're making indicate that Arkansas Power &
20 Light wasn't aware - when I say Arkansas Power & Light, 21 those individuals primarily responsible for nuclear 22 operations were not aware that a design change had been made 23 to this component.
kg VOICE:
Tha t's - I can't disagree with that.
24 25 VOICE:
Well, let me ask you this, Don.
Did you A
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8633 01'12 13 NRQate i
ever go up to B&W Lynchburg af ter this issue had come up and 2
conduct any-kind of audit to check out the paperwork, the 3.
reviews and so 'f orth, tha t had been done?
4' b
VOI CE:
No, I never did.
Back then I did not have U_n S
the responsibilities for quality assurance.
h VOICE:.-Did somebody else?
To your knowledge, was 6-7 that ever done?
/ued4 VOICE:
I don't believe so.
8 9
VOICE:
Okay.
Well, we were to the point there in 10 the chronology where you had a 40 percent reactor trip.
.I l There was a problem with the r ;eptance criteria or somebody 12 had a concern about the pressurizer level going too low.
13 And you probably got a communication, written communication 14 f rom the plant superintendent, documenting this concern and f) 15 asking that, say, you look into it furthers and, further, a
16 that you had discussions with either Baker or Govers about l'
what's the reason we got this problem.
18 And yet, the movemen t of the level taps really 19 wasn't pursued too deeply.
In other words, you don't know 20 even to this day why those level taps were moved?
21-VOICE:
Why they were changed f rom the earlier 22
. plants, you mean?
23 VOICE:
Yes.
k VOICE:
No.
24 25 VOICE:
hell, you got a problem here.
So how do
8633.01 l3 14 NRCmte l
you go about correcting it?
O
/ cocha VOICE:
The problem with loss of level indication?
2 h
VOICE:
Yes.
3
.O 4
VOI CE:
Well, the studies that 'were done by B&W Q
5 showed that the level was remaining in the pressurizer, by 6
looking at the pressures in the reactor coolant system as 7
compared to the temperature in the pressurizer versus the l
-8 reactor coolant system hot legs and this sort of thing.
And 9
the studies also showed that the response of the reactor 10 coolant system pressure and the pressurizer level was very
.11 dependent on the response of the secondary system.
So the 12 main corrections that were made were in the controlling the 13 secondary pre ssure in the steam generators, changing the set 14 points on the main steam safe ties and the turbine bypass
( );
15 system.
(
VOICE:
Le t me ask you this, Don.
These safety 16 17 valves, they have a history of blow back setting such that 18 they don't reset at the right pre ssure.
They let pressure 19 go down too far.
Y. >r bypass valves can hang open on you IM) and blow down _ the secondary side.
There are feedwater 21 malfunctions.
Maybe if you get too much auxiliary 22 feedwater, that can lower the secondary side temperatures 23 and pressures, lower than you would want.
24 Do the fixes adequately address that sort of
(~y 25 thing?
Can you withstand a -- withstand.a malf unction in
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8633 01 14 15 NRCm te ~
l those pieces of equipment and still maintain level?
2 k4(cha VOICE:
I don't know that a malf unction such as 3
that would be -- would allow you to maintain level in.the
. (~3 4
pressurizer on our unit, or whether i t would be diff erent 5
f or any otiwr unit.
(h 6
VOI CE:
You mean it's a generic problem, so --
7 M
VOI CE:
Well, I'm not saying it's a generic 8
problem.
The plant is responsive to the conditions in the 9
secondary side of the plant.
If those conditions in the 10 secondary side of the plant goes into an off-normal type of 11-situation, be it excessive blowback on a saf ety valve or a 12 stuck-open turbine bypass valve or excessive feedwater flow, 13 whatever it is, you ge t into a cooldown transient on the 14 reactor coolant system, which, of course, is going to shrink
- ( ).
15 the volume of water in the primary system on any BWR.
And 16 you know, if it shrinks it enough, you're going to lose 17 level totally in the pressurizer and go into automatically 18 actua te your high pressure injection system to compensate 19 for it.
20 So I don't think it's a -- I wouldn't call it a 21 generic _ problem, because the automatic systems are there to 22 compensate for that rapid shrinkage in the reactor coolant 23 system.
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24
' VOICE:
In other words, what you're saying is 25 you've got a saf ety system there you can call on to operate i
e g
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0633 01 ~15' 16 NRCa te I
during a reactor' trip?
2'
/bou222 VOICE:
Well, it'd be a reactor trip with other 3
off-normal c anditions.
If you have a reactor trip where r$
4 things - are f unctioning -properly, i t wouldn't be called on.
V 5-VOICE:
Have you ever looked at the design 6
requirements f or the pressurizer that B&W set up, to see 7
whether your particular experience that you were having at 8
ANO is in conformance with those design requirements?
/buitst VOICE:
We asked B&W to look at that, and in their 9
10 report on the evaluation of the situation they did address
.11 t ha t, the eff ects on the stress analysis and other 12 parameters relative to the design of the NSSS.
(h)
VOICE:
I gue ss wha t I'm asking, though, Don, is, 13 14 you have some sort of design requirement for the pressurizer
()
15 that assumes certain temperature drops and certain 16 performance of the pre ssurizer when it's designed.
Have 17 you, in your QA capacity, ever gone in to verify or have 18 someone verif y that your operating experience does show that 19 those design assumptions are accurate?
b VOI CE:
I don' t -- I haven' t had anybody in my OA
.20 21 section do that.
That's the function of the te sting 22 program, to see that the plant is performing as it was 23 designed and as i t's expec ted.
The acceptance criteria are 24 based on expected performance of the plant, and that's what
(~1 25 the testing program's designed to show, that the system is C/
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8633 01 16 17 NR Cm te.
1 performing as expected.
2 VOI CE:
So whenever you lost pressurizer level 3.
Indication, that pointed out that there was a design 4
deficiency?
p 5
M VOICE:
Not necessarily a design -- they pointed 6'
out that there was some thing that was dif ferent f rom what 7
was expected.
Whether it was a design deficiency or a 8
problem with indication -- you know, when it first would 9
occur you wouldn't know whether it was an instrumentation 10 problem or a design deficiency or an unusual response in
.11 another part of the plant that caused it or wha t might have 12<
been the cause of it.
So that's when you start 13 investigating it.
f VOICE:
In other words, you use a term " abnormal I4 O
is reso ase some here e se 1" the syste "het's co tao over 16 to me is the design is only supposed to cover perfect 17 condi tion s.
.18 all4 VOICE:
No, that's not --
h 19 VOICE:
There isn't any latitude in it for an 20 abnormal situation, like a saf ety relief valve staying open 21 too long.
If that's an incorrect characterization, please 22 correct me.
h 23 VOI CE:
Yeah, that's not what I'm getting a t 24 there.- The whole NSSS system is designed to take normal 25
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operating conditions, transients, when things are working v
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$633.01'17 18
'NRCmte I
correctly, and of f-normal conditions are -- I call them that 2
-- where things, components, may. fail, or things may not 3
perf orm the way they're supposed to.
And the plant is
- r^g _
4 designed to accommodate those things.
The effect of a L.)
5 component f ailure is going to vary de pending on which 6
component you're f ailing.
(h
. VOICE:
Yes.
But basically, are you telling me 7
8 that you should be able to meet those acceptance criteria 9
which would define the design that covers those off-normal 10 conditions or abnormal conditions?
.1 i VOICE:
Well, the acceptance criteria would be 12 based on a set of assumptions in de termining -- you know, 13 when you're designing a test program, you have certain 14 initial conditions for the test and certain assumptions that
(])
15 are made in the calculations that are done prior to a test gyl 16 to determine acceptance criteria.
If those assumptions are 17 changed by changing the initial conditions or something that 18 goes wrong during a test, then that can be the cause of not 19 mee ting the acceptance criteria.
20 And it may mean the need to either repeat a test 21 or show, through different calculations, that if we change 22 our assumptions, what should the acceptance -- new 23 acceptance criteria be.
h)
VOICE:
So you change the assumptions --
24 ffucdft VOICE:
The acce ptance cri teria --
25
(~j).
f l
'8633:02 01 19 NRCmte 1
(
VOICE:
-- in the design calculation, i s tha t wha t 2
you're saying?
M VOICE:
3 No -
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VOICE:
What assumptions are you changing?
gS 4
V 5
jfa,jpg VOICE:
I'm talking about the assumptions that go 6
into calculating acce ptance criteria for a test.
(h VOICE:
Shouldn't they bound the design with 7-8 a ssumptions?
h st VOICE:
We d, they would bound them to a certain 19 10 ex ten t.
You wouldn't want them to bound them to the point 11 that you're having a -- I'm talking test philosophy here.
12
< You wouldn't want to have a -- what do you call it --
13 destructive type of test to prove that some acceptance 14 criteria could be met.
()
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VOI CE:
No, let's not -- let's not --
15
/k(6$7 VOICE?
I mean, you have to make certain 16 17 a ssumptions that go into a test program, that you meet these 18 initial conditions, so that you can have a starting point 19 f rom which to do your calculations of where you're going to 20 end up, where you're going to pred'ct that the system will 21 end up.
22 And those then -- you take your calculations of 23 where you predict it will end Lp, and the errors that might 24 be -- the errors that might be present in your calculation l
l rg 25 due to round-off or whatever type of errors you might put Qi
. ~.,
8633 02:02 20 NRCmte i
into it and the instrumentation errors and this sort of 2
thing, and_ you put an acceptance band on that predicted 3
- value.
And that's where you're expecting the plant to come
< g~$
4 out to, is somewhere within that rcnge of values that you
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5-
. have predic ted.
6 Now, if you -- those are based on a set of initial 7
assumptions as to where the plant's going to start from when 8
it goes into this transient and what's going to happen while 9
it's going through the transient.
If something diff erent 10 happens during the transient, then that final calculated
.11 prediction for that specific test may not be met, because 12 some thing ha ppened in there that was in one of the 4
13 assumptions going into that calculation of the test 14 r e sul ts.
, ()
15 You may not be outside the design calculation, but 16 you're outside what was used in calculating where you're 17 going to end up from that test.
(p 18 VOICE:
But if the component is adequately 19 designed for these abnormal situations, it should be able to 20 sustain one of these transients --
21 (d4 VOICE:
Sure.
22'
(
VOICE:
-- without creating a problem --
23 M
VOICE:
Tha t's right.
24
()
VOICE:
-- like not giving the operator an (s
25 indication of where the inventory is in the reactor
. (_)
f c
l
1633 02 03~
21
' N R Cm t.i i
coolant _ system.
/hou2Tr VOICE:
But if you want to design a test that's 2
3 going to accommodate any possible f ailure that. tight go on, 4
you're going to have an awful big acceptance criteria band
,g 3
~
5 on the end --
(h VOICE:
We ll --
o
/84cff VOICE:
-- if it's within the design parameters of
/
,2 8
the system.
9
()
VOICE:
Having some knowledge of how this testing so i s conducted, it's conducted under very controlled
.I l conditions.
12
/
u.MA VOICE:
That's right.
()
VOI CE All right.
Not under abnormal 13 14 condi tion s.
Conditions can, as you and I both know, can be I
(^T 15 very much worse than the conditions we mock up on the w/
16 tests.
So that's an argument for the f act that the test 17 results provide favorable type of results.
18 For instance, the level that you start off with in 19 the pressurizer is very -- is specified in the test 20 procedure.
And it's chosen such that it should be very 21 close to a perfect operating type of level.
And I would l
22 imagine that when the test is conducted, a great deal of 23 pains are taken to keep it at that particular level.
For 24 instance, if you're starting off with a level too low, all
-25 right, at the start of the test -- which is allowed by the
(~)
- x. >
8633102 04-22
~
NRCm te :
1
~ operating band -- but if you started off with a low level in 2
t he re, then you're going to see a lower level at the 3-completion --
4 VOICE: ' Tha t's right.
p h
VOICE:
-- or at some poin t in the tran sien t.
5 6
Okay.
7 Let me ask you this:
At any point during your 8
review of this whole subject, did the question ever arise in 9
your m'ind that that pressurizer might not be adequately 10 sized to deal with these transients?
/$rveg VOICE:
I don't know if I ever questioned whether
.I l 12 it was adequately sized.
13 (39 VOICE:
When I say " adequately sized," I'm talking 14 about having a liquid volume --
fi 15
[uctra VOICE:
I know what you mean by " adequately uJ 16 sized."
The liquid volume such that you didn't lose 17 level in the pre ssurizer when you had these transients.
I 18 know I questioned whether the design of the system was such 19 that it was, you know, did not - questioned whether it 20 involved an unreviewed safety question of any type, be it 21_
lack of information to the operators because they didn't 22 have a level indication for a period of time following a 23 tri p, or wha tever.
24 I would have looked at it f rom that standpoints
(-)
25 Did it involve an unreviewed safety question, and what were t,i 4
@633 02'05 23 NRCmte
_1 the problems associated with the thing?
And that's the way 2
I would have been looking at it.
I don't recall whether I 3
ever brought in the question in my mind, was it adequately 4
sized.
It may have entered my mind, but you know, I'm p%)
5 trying to think back to five years ago.
h VOICE:
You never questioned that, at least in 6
-. 7 writing?
8
/8mbg VOICE:
Not tha t I recall, the size of it.
9 VOICE:
Well, what did Arkansas Power & Light wind 10 up doing to correct these problems?
.11 M
VOICE:
Well, as I indicated before, the 12 correction to it was in the change in the control on the 13 secondary side pressure, to change the set points on the 14 safety valves and the turbine bypass system.
{}
15 VOICE:
Well, what about - was there ever any 16 decision made and implemented to instruct the o pe ra tors to 17 initiate high pre ssure injection?
I8 M
VOICE:
When the problem initially came out, the 19 plant decided that that was what they were going to do to 20 keep the pressuri7er level on scale, for the operators - to 21 have them manually initiate high pressure injection af ter 22 any reactor trip.
23 VOICE:
How did -- excuse me.
Let me interrupt
?4 you.
h How did they come up with that idea?
25 bq i
8633 02 06-24 NRCate 1.
VOICE:
Well, the normal way to make up 2
pressurizer level is to initiate high pressure injection if 3
it falls off scale.
It's like responding to a loss of 4
inventory in the reactor coolant system.
5 VOICE:
You say the normal way. is.to actuate a 6
saf ety system to recover level?
7 VOICE:
Well, if it's -- you know, they were 8
losing it off-scale at the time and it would be a normal 9
reaction on an operator's par t to think of a loss of reactor 10 coolant inventory, by whatever means it is, and the response
.11 12 VOICE:
That could be a LOCA, for. instance?
M VOICE:
It could be, yeah.
It could be a loss of 13 14 pre ssure in the system or something is causing it to 15 decrease, or rapid cooldown or whatever might be causing 16 it.
17 VOICE:
LOCAs and rapid cooldowns are very similar 18 in their response in the plant parameters, aren't they?
19-VOI CE:
I'm not an operator, but I would presume 20 that they. would be very similar as f ar as the response of 21 the pre ssurizer.
22 The - I don't recall what your question was now, 23 that I was trying to answer.
24 VOICE:
Well, let me go on.
You mentioned the 25 plant had decided to do this,'okay.
Does that mean
--4..c.
G633 02 07 25 NRCm te l
Mr. Anderson or --
2 VOICE:
Well, i t would have been - it would have 3
been the plant staff and the operations staff doing this,
.j )
and this was -- you know, we looked at_ it and questioned it 4'
\\J 5
with B&W as to whether we should initiate high-pressure 6
injection on these transients.
And it was felt that tha t 7
was not an appropriate -- not a nece ssary thing to do for 8
Just a normal reactor trip or something of this nature, 9
because the time f rame for the operator to initiate high 10:
pressure injection, as compared to when you bottom out on
.1 1 -
pressurizer level and start recovery -- you know, a short 12 delay in how soon they initiate high pre ssure injec tion, the 13 system might already be recovering and come back up, and it 14 wouldn't make any difference whether you start high pressure
(~T 15 injection or not.
N._/
16 And if we got to a point where the pressurizer 17 level did. decrease ano drop out of the pressurizer 18 completely, that at that point you would rapidly go to the 19 pre ssure associated _with the hottest fluid, the ho ttest 20 water lef t in the system, which would be in the hot leg.
21 You'd drop below the set point for automatic HpI injection, 22 for actuation, and it would start automatically.
So it was 23 not necessary for the operator to take some precautionary 24 type of measures before it was really needed.
25
()
VOICE:
Yes.
Well, lot me ask you this.
And
)
l I^
8633 02 08 26 1
-NRCmte.
.1 I'll stop you at that - point. -You were talking about 2
(Inaudible.) the pressurizer.
You reach saturation 3
conditions in the reactor coolant system.
Your heat removal n
4 capacity through the steam generators is aff ected because of 5
the presence of boiling.
Your reactor coolant pump 6
operation is affected because you're operating in saturated 1
7 conditions.
8 When this issue was initially brought up and 9
reviewed, were there any special instructions or any -
10 yeah, any instruc tions given to the plant to train the
.11 operators to recognize these di.ff erent conditions and to 12 give them instructions as to what to do when it happened?
13 VOICE:
I think, as I understand, you're going to 14 the plant to talk to them.
I think you've got to - as f ar-(]
15
-as whether specific instructions got to the operators 16 through the training program is something I think you'd have 17 to - -
h VOICE:
To your knowledge..
18 19 g
VOICE:
- talk to them.
To my knowledge, I 20 really wouldn't know - back then whe ther the instructions got
-21 down to the operators or not.
22 VOICE:
Did you ever recommend that they have any 23 training or procedure revisions be implemented to address 24 t hese conditions?
25 uj14 VOICE:
We - as I recall, we concurred with v]
g
8633 02 09-27-
'NRCmte l-B&W's recommendation that they not initiate, manually
+
2 initiate high pre ssure injection on reactor trip, and tha t 3
-- for the reasons that were presented by B&W.
h VOICE:
What were the reasons, Don?
4 5-b VOI CE:
Well, as I've gone through just a minute 6
ago about the f act that if the pressure -- if the liquid 7
stays in the pressurizer, you're not going to get to the set 8
poin t on the high pressure injection, where you need it.
9 anyway, and it's going to start, until you drop that 10 pressure down below the set point.
That's when you need to 11 start initiating high pressure injection, it comes on 12 automatically.
13 Just a recollection of what I recall from that 14 time.
But as f ar as - there you'd be ge tting into a 15 response of an ECCS actuation, and the operators would be 16 responding in the same way they would to any ECCS 17 actuation.
They would respond according to their emergency 18 procedures.
19 VOI CE:
In o the r words, they would use che same 20 procedure for a rapid cooldown transient resulting in the 21 voiding of the pressurizer that they would for a LOCA?
[tufR VOICE:
I don't believe so.
I would imagine they 22 23 would have.dif ferent emergency procedures, because there's 24 other parameters you're looking at besides pressurizer to 25
'Jetermine whe ther you've got a LOCA or rapid cooldown or l
L
1633 02 10'.
28 NRCm te 1
wha t you have going on.
2 VOICE:
Well, how can you tell the difference?
3 VOICE:.Well, there are other parameters that are 4
involved in i t.
The response of the reactor building S
temperature and pressure.
6-VOI CE:
Wha t if the operator doesn't look at tha t 7
What if --- you know, in the initial phases there's a 8
small break and the pressure's not building up too much.
h VOICE:
Well, I'm not intimately f amiliar with the 9
10 emergency procedures to know all the di.fferent symptoms the
.II operator's looking for to determine what type of emergency 12 situa tion he has.
I know the operator procedures have in 13 them the symptoms to be looking for, and if you get these 14 various symptoms together, then you have one type of
(]
15 emergency and not another.
16 VOI CE:
Well, in your review of this and the 17-recommendations tha t you would have made, would they have 18 been without going in and looking at those types of 19 c on sidera tion s, the ones that we were just discussing, what 20 the operator sees and how he can diff erentiate between one 21 of these rapid cooldown transients and a LOCA, what actions 22 he would 'take?
23 VOI CE:
Well, I don't know that I would have g
24 specifically looked at that myself.
That sort of thing 25 might have been looked at by the plant safety committee or u-
G633 02'.11 -
29 NRCmte I
tha t' sort of thing.
h_
VOI CE:
Somebody else besides you?
2 3'
VOICE:
Tha t's right.
4 VOICE: -But to your knowledge, that type of review 5
- to your knowledge, that type of review wasn' t done?
~
6 V'
2:
Not to my knowledge, a specific 7
documentary review.
It may have been part of a plant safety 8
review conmittee meeting or the plant staff's review of the 9
si tua tion.
10 VOICE:
Are you a member of any of the safety
.11 review boards here?
b VOICE:
I am a member of the safety review 12 13 commi tt ee.
'I4 VOICE:
That's a corporate office f unction?
15 voice:
Right.
16 VOICE:
How long have you been a member of that?
17 VOICE:
I believe about three years.
h 18 VOICE:
So that would put us back in 1976.
19 Were you a member of any type of safety review 20 commi ttee in 1974, 1975?
k$7 VOI CE:
No.
21 22 VOI CE:
To your knowledge, did anybody ever make a 23 statement that they f elt that this pressurizer level thing, 24 problem, was a significant deficiency and ought to be 25 reported to the NRC?
8633 02 12 30 NRCmte
- l' VOICE:
My recollec tion - I ' don't know if anyone 2
ever.specifically came out and said that it should be 3
reported or what.
But I know any time something like this 7w 4
comes up we look into whether it's something that should be
'd 5
reported to the NRC.
Significant deficiency wouldn't apply 6
at this time, because we had an operating license.
We'd be 7
looking more at unreviewed safety questions and reportable 8
o ccu rrenc e, tha t sort of thing.
9 I'm sure that these sort. of things were looked at 10 for that.
(h VOICE:
Did you participate in that review?
II hhA6ba 12 VOI CE:
As part of determining what the impact of 13 this loss of level indication was and what the resolution of 14 i t would be, I was involved in it.
I didn't -- in my
( IS capacity in the licensing area, I would have looked a t any 16 design changes f rom a licensing standpoint, unreviewed 17 saf e ty question standpoin t, that sort of thing. Bu t -- b) VOICE: Did you ever discuss this matter with 18 19 anyone, the ma tter of whether this was a reportable item? 20 And specifically, who'd you talk to? hrujht-21 VOICE: I don't recall back then who specifically 22 I would have talked to if I did. At the time I'm sure we 23 talked abou t it, and it would have been myself and the plant - 24 - ' staff people, the members of the plant staff talking about {N 25 i t.. w) i + ~ w
f330213. 31 DNRCmte I 'h VOICE: Who would that normally be? 2 b VOI CE: The plant manager, assistant plant manager 3 back then. Someone of that nature. k ~ VOICE: Do you know who makes the ultimate r^3 4 , C! ~. 5 decision whether something like that is reported? kD/) VOICE: A reportable occurrence? 6 7 VOICES A reportable occurrence.or a significant 8 deficiency. 9 VOICE: Well, it can - the way - I don't recall 10 exactly how it was done back then. Normally, if it was a .11 clear-cut reportable item, the plant staf f would make that 12 determination and then just let us know in Little Rock and 13 then file the re ports. They would be the initial 14 notification to the region, regional of fice, and we would O 15 generate the follow-up report in 14 or 30 days, whatever was 16 required. 17 If an item carae up that was clearly not 18 re por table, then they would make that decision and they 19 would drop it, among the plant staff. 20 If it was a questionable item as to whether it was 21 reportable or not reportable, tha t sort of thing, I -22 sometimes got involved in discussions with the plant staf f 23 on those back in that time frame, to determine whether we 24 should report it. 25 I know our current policy is if it's questionable, e
8433 02:14: 32 . NRQn te 1- 'we'll-discu ss it with the resident inspector and ge t his-2 opinion on whether we.should report it, or I'll go ahead and 3' report its this sort of thing. p 4 VOICE: In other words, you can have a ' discussion V-5 with-the resident inspector and make a decision as to o whether or not it would be reported to the NRC or not? 7 VOICE: Well, sometimes - h VOICE: Formally reported. 8 h VOICE: Right. Sometimes we'll inform him of 9 10 things,.just to keep them a ppraised of what's going on at 1I the plan t. h . VOICES-And you would consider that notification 12 13 in some instances? h oc VOICE: I would -- that would ba - not be the -l4 0 is tormei tor = or aottriceti n nere it's a documented tata9-16 you know, where we'd transmit a letter or something of that 17 nature. 18 VOICES-Well, how would you classify this 19 pressurizer level issue? [M VOI CE: How would I cla ssify it? 20 h VOICE: Yeah. Is it one of those, you know, on 21 .22 the borderline type of things? - 23.- h VOICE: When it first came up, it warranted 24 investigation to determine whether there was a problem in . 25-the design.and operation of.the plant.. The ultimate \\,. ) - l d
l-b I
- 8633 02LI5; 33' NRCmte
.I - resolution - you know. the problem has been corrected since l. 2 t hat time. The ultimate resolution in changing the l-3 operation of the secondary side of the_ plant to eliminate .q 4 -the problem -- those are the kinds of things you look fur in V 5 _ the test program. 6 We correc ted the si tuation, and it would not fall 7 into the reportable -- re portable i tem at the time. We -8' looked at it, and I would -imagine it's discussed as part of 9-the startup report, the resul ts of the testing. h VOI CE:.Did you have any responsibilities 10 1I regarding the startup test report? 12 VOICE: At that point in time, it would have been l-13. the responsibility for_ review of it in the general office 14 and transmittal to the NRC. ( IS~ VOICE: One thing I noticed in reviewing that 16 startup test report was the 40 percent reactor trip and I 17 believe the 100 percent reactor trip were reported in 18 tnere. But there was one that happened at 75 percent power, 19 where you lost indication for 45 seconds, that I don't 20 recollect was reported in tha t startup test report. 21 VOICE: I haven't looked at the startup test 22 report in a long time. I don't recall specifically what's 23 in - _h VOICE: But you wouldn't have had the primary 24. 25 responsib'ility for the startup test report?
K633'02-16 34 NRCate -l VOICE: Not for preparation of it. h 2 VOICE: Would you have reviewed it?' k& 3 VOI CE: I'm trying to remember what position I n 4-held back in 1974. I would probably, in the licensing (f 5-capacity, have looked at it to see that it met what was 6 called for in. the NRC requirement f or submittal of the 7 re por t, and prepared it for formal transmi ttal to the NRC. h VOICE: Did you have' ~any responsibili ties in 8 9 regard to response to IE Bulletin 79-05? b dp 10 VOI CE: Yes. h 11 VOICE: I'd like for you to take a look at this 12 response here that's contained in NUREG-0560. See if you're 13 f amiliar with tha t. 14 - VOICE: Let me flip this thing while he's - i ) 15 (Gap in recording. ) h 16 VOI CE: This is our response to one of the items 17 in the 79-05 bulletin. 18 7 VOICE: Okay. h VOI CE: You cite that you had two trips from 100 19 20 percent power, one in December of 1974 and one in May of 21 1975, where you lost pressurizer level indication. But 22 apparently this trip from '75 percent power, which is 23 ref erred to in a piece of correspondence that Mr. Cavanaugh 24. wrote - he said you also had one at 75 percent power, you 25' lost it for about 45 seconds -- was there some reason why v 2 g r-e
7 E633IO2 I7 35 NRCmte I you wouldn't have reported that? hkA6dh VOICES. I'm sure it was - just probably overlooked 2 3 at the time. I wouldn' t know any intentional reason of - (~N, 4 . leaving something like th?t out. 's ). . ()) VOICE: Okay. How did you go about reviewing this o 6 information to reply to this question? 7 VOICE: That particular item? ( VOICE: Yeah. 8 9 M VOI CE: Well, that - a lot ' of that material was-10 prepared by the plant staff and by the licensing section. 11 And I would 'not have -- my review of i t, my personal review, 12 would not have been to go back and verify that the 13 information, all the files had been looked up and this sort 14 of thing. I would be questioning the people who prepared it (} 15 to make sure that they had covered everything tha t wa s 16 required, and I'd be looking to see that the question had f)' 17 been answered. ()) VOICE: You were reluctant to question it because 18 19 45b4 VOICE: No, I wouldn't be reluctant to question 20 21 the responses in there, if I felt there was material taht 22 was not included that was appropriate and this sort of 23 t hi ng.. I'm sure when I was reading this I didn't recollect 24' the trip at 75' percent powe r. If I had, I would have seen (T 25 ~ G' 6 I --e c = y rmy v w r y w-
8633 03.01 '36 ~ NRCmte 'l that.it was included--in there. f) VOICE: Another statement in here is Following 2 -3 investigation, we determined that RCS T-av following the 4-reactor trip was slightly lower than design. -} ~/ 5 What does that mean? /fcogif 6 VOICE: Well, that would mean that the controls 7 established by the integra ted control system, I would 8 imagine, take the average temperature down slightly lower 9 than what it's designed to go to. And that can be done 10 either'by -- primarily by the response of the secondary i .11 system to cool it a degree or two more than it-was designed 12 for. 13 I don't recall -- remember seeing tha t. I don't 14 know if it was two degrees or what, that we were below it _(]) 15 one or two degrees. ()) 16 VOICE: But does that imply that you had a design 17 deficiency? [4t6740 VOI CE: No. That implies tha t the control systems 18 19 need - to be further tuned to make them -- to get them to 20 control-the parameters in the plant the way they're designed 21 to be controlled. I t's not a deficiency in the design. The 22 . system-i s there and i t can do i t. (f 23 VOICE: But it's outside design? You experienced 24 conditions outside the design? 25 VOICE: Well, the statement there says that it v t t_ -
E633.03.02 37 ~NRCmte l' was a couple degrees below the design value. A couple 2 degrees there can cause, of course, a change, a reduction in 3 the volume that's available, and this sort of things and 4 this was a way of correcting it, was to get that back in 5 line with where it should have been by further tuning the 6 control system. 7-(Pause.) 8 VOICE: Let's g-of f the record just a minute. - 9. VOICE: Okay. 10 (Discu ssion of f the record. ) ()) VOICE: What I'm going to show you now is Figure .11 12 4-6 f rom the FSAR, which is entitled Pre ssurizer Outline." 13 Would you take a look at it for a few minutes? I4 h VOICE: Okay. ([ ) 15 (Pause.) (f VOICE: We've asked Mr. Cavanaugh to verify that 16 17 that's the. figure that's in his FSAR, which is a control-18 copy of it. And he finds that that is the one. 19 In your personal judgment, does that accurately 20 show the location of the low level tap? 21 (Pause.) 22 /UlJI4 VOICE: Without having the specific drawing, the 23 a s-built drawing of the pressurizer, I don't know whe ther
- 24 this drawing, looking at. it -- there's no amendment date on
/) 25 i t, so it appears that it would have been submi tted as \\J l
8633'03 03 38 NRCa te i part of the FSAR prior to operation, and hence prior to the ~ '2 problems being discovered in the power ascension testing 3-program. And I don't recall exactly where.the -- I know our (~) level ' tap is higher than on other uni ts. I don't know 4 v S whether this actually shows where the older units are or 6 ours. (h) 7 VOI CE: Mr. Cavanaugh has made the statement in 8 one of his communications that, I believe, those heaters -- 9' those taps are higher than the heaters. i 10 / VOICE: Okay. Well, if that's the case, then this .l l drawing would be incorrect. 12 ( VOICE: Now I'm going to show you Table 74 to 7-11 13 out of the FSAR, entitled "Information Readouts Available to 14 the Operator to Monitor Conditions in the Reactor,. Reactor (]) 15 Coolant System, and in the Containment." And in particular, 16 I direct your a ttention to the comments on pressurizer 17 level. 18 (Pause.) [h VOICE:
- Okay, 19 20
() VOICE: Tha t document indicates that the range of 21 the pressurizer level instrumentation is zero to 400 22 i nc he s. In your prof essional judgment, is that correct? rM, 23 VOICE: No. The range on our pressurizer level is l 24 zero to 320 inches. 25 (Pause.) '(^) v l l
D633.03 04 39 NRCm te i VOICE: Now I'm going to show you an excerpt from 2 an inspec tion' report, Inspection Report No. 50-31374-14. 3 And this is an inspection report filed by a fq. 4 Mr. R.F. Rogers of, I believe, Region II at that time, who V 5 had responsibility for the plant. And Mr. Rogers documents 6 his review of a turbine reacter trip test. He states 7 High pressure injec tion was randomly initiated due 8 to decreasing pressurizer level when the actual level 9 reached approximately 31 inches. He further states: The 10 corrective action listed in the test document f or these deficiencies indicate that none is possible, and that these 12 deficiencies are characteristic of the primary system. 13 (Pause.) h 14 VOICE: Were you involved --- I may have already O is esked vo" tats. '"t oteese rerres" =v =e orv- "ere vo" lo involved in the review of the startup test results, in 17 particular, deficiencies regarding acceptance criteria for 18 the tests? bM VOICE: No, I wasn't. 19 20 VOICE: Is that your position, that no corrective 21 action was -- that no corrective actions are possible to 22 address the pressurizer level indication problem? 23 VOI CE: That may have been the thought at that 24 time, when that thing was prepared. But as.I stated i 25 earlier, we have taken corrective action and the
\\ j 8633 03 05 40 NRCmte-I pressurizer level indication has remained in subsequent 2. transients at the pl an t, as a result of the tuning in the 3 integrated control system and the changes in the secondary .,c3 4 system in the plant. O 5 VOICE: To you knowledge, do the operators 6 presently at ANO-1, upon a reactor trip, have to immediately 7 isolate letdown and initiate high pre ssure injection? hoddla VOICE: On a reactor trip? I don't believe they 8 9 . do, unless there are other symptoms that indicate that 10 that's an emergency si tua tion. In a normal reactor trip, 11 no. You know, that's my knowledge right ncw. () VOICE: Was that in response to what you 12 13 previously commented on, that B&W said that you shouldn't 14 initiate high pressure injection? ] / 15 VOICE: Well, they said that we didn't need to 16 initiate high pre ssure injection, that the plant was 17 designed to accommodate those transients, and when high 18 pressure injection was needed it would be automatically 19 a c tua ted. 20 And the operators know that when they get to a 21 certain set point, if it doesn't actuate, they will actuate 22 it. Or if they know that they've got a concition and they 23 haven't gotten there yet, tha t they may actuate it earlier. 24 You know, that's an operator judgment. He can tell by all 25 the various indications he's got where he's headed. ) / t l r.
8633 03 06 41 ' h VOICE: NRCm te I Knowing that before one loses indication 2 on the pressurizer level the heaters trip off, was the 3 subject of loss.of pressure control via the pressurizer 4 heaters ever discussed as a problem in this whole sequence p 'J 5 of analysis? 6 M VOICE: I don't recall that it was. I know we're 7 looking at it.now as part of the lessons learned in Three 8 Mile Island. But I don't recollect anything. I t may have 9 been, but I don't recall. 10 VOICE: Are you personally aware of any comments 11 tha t the operators might have had, when this problem first 12 appeared, about what they were concerned about? 13 VOICE: No, I didn't have any personal 14 communications with the operators about this. (] 15 VOICE: At this point I'm going to turn it back 16 over to Fred and let him ask any additional questions he 17 might have. 18 MaNi VOICE: I have no specific questions. As a final 19 question, if you have any statements or comments you care to 20 make, f. eel free to make them a t this time. 21-VOICE: I guess the only comment I've got is that 22 a lo t of wha t I've said is from my recollection, and without 23 having had a lot of preparation time to go through all of 24 the various files that would be available on this to get the n 25. specifics of any of my direct involvement in the situation. U
..- w i i ii -. 42 t633:03 07 .~NROnte i Mostly it's f rom my recollection of what happened five years 2 ago.
- VOICE:
Tha t's understood. 2 VOICE: Okay. With that, it's 12:11 and we'll ' 4 -5 terminate the hearing at this point. '1e thank you very much ~ i' 6 for your time. 7 (End of recording. ) B f i 10 f Ii 12 1 13 14 O is 16 17 4 19 20 - 21 I' 22 t 2'3 l l i 24 i i ' 25 I. ~ mh eD mas b 4w + m 2 y -we' ywyi,s4-- m w,W p< .w' w ---wr-'gr-q,-n g yr + p-m gwyw y gyy w myg p w y ycw w-re,_j gw syg-apeg S r' e g g-=yye -y- =15p*-}}