ML19322C226
| ML19322C226 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/15/1979 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001160651 | |
| Download: ML19322C226 (67) | |
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THREE MILE ISLAND m_
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y SPECIAL INQUIRY
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' INTERVIEW O'F STEVEN VARGA i
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Place - Bethesda, Maryland Date. Wednesday,15 August 1979 Pages 1 - 67
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(202)347-3700 ACE -FEDERAL REPORTERS,INC.
OfficialReporters 80 01160 6 N/.,
444 North Cecitol Street Washington. D.C. 20001 NATIONWIDE COVERAGE DAILY
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NUCLEAR REGULATORY COMMISSION s
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4 In the Matter of:
SPECIAL INQUIRY 5
.THREE MILE ISLAND f
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INTERVIEW OF STEVEN VARGA j
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9 Room 426 i
Arlington Road Building l
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6935 Arlington Road Bethesda, Maryland e
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Wednesday, 15 August 1979 12 10:45 a.m.
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13 BEFORE-i 14 SPECIAL INQUIRY GROUP:
15 FRED G. FOLSOM FRED J. HEBDON 16 R. LAWRENCE VANDENBERG WAYNE LANNING 17 AND:
18 MARJORIE NORDLINGER 19 Office of General Counsel, Nuclear Regulatory Commission 20 1
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(10:45 a.m.)
3 MR. HEBDON:
Would you raise your right hand, please.
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4 Do you swear and affirm the testimony you are about f
5 to give will be the truth, the whole truth and nothing but the i
'6 truth, so help you God?
7 MR. VARGA:
I do.
.i 8
EXAMINATION
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9 BY MR. HEBDON:
10 g
Have you read and do you understand the witness Il notification I have just given to you?
I, 12 A
gYes.
j 13 G
Do you have any questions or comments?
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14 A
No.
15 l Would you please state your name?
16 l A
Steven Varga.
7 4
What is your current occupation?
A I am employed by the Nuclear Regulatory Commission J]
4 19 1 in the Division of Project Management.
G What is your current position?
N 21 (I A
I am Acting Assistant Director for Light Water r
22 Reactors.
23 g
I would like to turn the questioning over to 4
24 '
Mr. Vandenberg, who has so.e questions he wants to ask you.
usi nemnm. ine.
25 A
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1 BY MR. VANDENBERG:
2 g
The questions I have deal with the preoperational
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3
'and startup test program for TMI 2 and NRR procedures about 4
that in general.
]
5 First, what documents contain the preop and startup I
6 tests that NRC required for TMI. 2?
j 7
A Well, there is a regulatory guide that is fairly 8
extensive, and the Standard Review Plan also addresses it.
l l
9 And I don't know if there is other formalized documents.
I l
l 10 think there are also ANSI standards, the industry standards l
II :
that are referenced in some way or another in some of the i
l 12 regulatory documents as well.
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s 13 g
Now, are all of those items specifically required 14 [ of TMI 2 or is it just things that are in the license itself?
l 1
15 i A
well, the preoperational testing aren't specifically ;
I 16 l in the license.
There are requirements that they have to
$7 ] meet, and the I&E monitors their performance of preoperational.
I testing, and prior to the issuance of the license they give I
-o it i
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~ 10 4 us a clearance that all of those have been satisfactorily i
G,, completed.
l l
J 21 L g
.There is'no single document that contains a full i
i I
22 l list of the preoperational tests?
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23 j
A There may be.
There probably is.
I just don v 1
24 know the specific document.
I&E certainly must use something
. T Reporters. Inc.
l 25 to measure it against, and I'm sure our regulatory guides l
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I and the Standard Review Plan must have it.
I'm not specifically 2
aware of all the details.
3 G
How about for the startup teste?
Is there a single 4
document that lists all of the startup tests that TMI 2 was I
5 required to perform?
l 6
A I think that is when we discuss the modes, the 7
various ". odes of operation.
There are requirements, and I l
8 think in these similar document that I mentioned, Standard 9
Review Plans and regulatory guides, and in the technical 10 specifications they outline and delineate the various modes, II what has to be completed prior to, from mode one to mode two, 12 and to mode three, and that sort, or vice versa, mode six to 13 mode one.
14 g
Did the licensee ever state a schedule for completing 15 l the preop and startup test program?
l 16 l A
Well, his schedule is controlled more or less by I
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the issuance of the operating license.
He has a schedule and q I have seen various schedules that have been discussed, and I
,, I have forgotten the exact format or the exact document that I L
K p saw.
But he cannot get his operating license unless all of li 21 I those tests have been completed.
22 So occasionally, and I'm sure often, probably, his i
23 ;
schedule that he has predicted probably has been changed, n.
depending upon what problems he arrived at or experienced, but
,"a' RfDOrters,Inc.
25 that his preoperational testing must be completed prior to his I,
F mta 4 5
1.
receiving an operating license.
There may be occasions, and i
l 2
i there may have been in this one -- I can't recall -- where 3
certain preop tests may not have been completed, but they were i
1 4
called out as conditions in the license, that this preop 5
test would have to be done or this particular test would have
-6 to be done before a certain time period or before another 7
certain reactor was received into a certain mode.
8 BY MR. LANNING:
9 Would you distinguish the difference between 10 preoperational tests and startup tests?
II A.
Well, preoperational testing is required of all of 12 : the systegs for indicating compliance, that the as-built 13 performance of the system meets the design performance, and 14 are required to be performed prior to any license and prior to 15 { any fuel in the reactor.
- 6 Startup tests are those tests required after he has i
Jj received the license and the reactor is fueled.
3ii BY MR. VANDENBERG:
I!
19 'l g
Do you know of any schedule the license had for
-- a completing the startup tests?
That is, after fuel was loaded.
d II A.
The tech specs would delineate those startup tests.
22 I don't know what the specific numbers were or what the specific 2$; schedule was.
But he has certain startup tests that he has j:
24 ~ to perform prior to initial criticality and that sort of thing.
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25 G
Do the tech specs contain any time schedule for j,
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I completing the startup tests?
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A I don't think the tech specs equire a particular 3
time schedule, but rather, a particular event, I think.
But 4
in some of the conditions for the license, if a test -- I I
5 don't know specifically on TMI, but I recall that there would l
I 6:
be some instances where a specific test had to be performed 7
by a certain time.
I think it varies depending upon what the i
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8-nature of the test is and its impact upon the plant operation. l l
9 G
So there were some items?
10 A
I think, but I can't recall on TMI, but there may i
Il l have been.
i 12 !
G A The monthly operating reports show a forecast date 13 for commercial operation.
How does that forecast date relate 14 !
to completion of the required test program?
l 15 l A
I don't recall the commercial operation having a 16 l specific regulatory connecticn except in one or two instances.
7f I think in-service testing is the only thing that comes to l
a i
mind which has in it commercial operation.
Commercial opera-e I*htionisnormally, in my view, a contractual operation between ',
'i i
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the vendor and the utility that requires so many hours of i
ii 21 warranty testing and that sort of thing.
- ! I 22 It is also, I think, associated with his financial l.j 23 arrangements or when he can start gaining some sort of tax 24 l benefits.
But as far as a regulatory requirement, I don't n: v nworms. Inc.
25 think that commercial operation plays a very great role at all.
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I G
Do you think it plays any role at all?
2 A
The only one that I can recall is the one on 3
in-service testing, where I think the words in the regulatory 4
guide, or at least the draft -- it may have been taken out; I 5
can' t recall.
But the draft had some discussion about commer-i 6
cial operations, certain things being performed prior to 7
commercial operation, which has given some dif ficulty because 8
commercial operation is a highly, in my view, uncertain date 9
And depending upon circumstances that are not safety-related l
10 at all.
11 i i
4 That was a draft of which reg guide; do you recall?
i I2 l A
, I can't recall.
It was in-service testing, as I 13 recall.
14 3
g From your vantage point, Steve, who were the persons with authority to establish the TMI 2 test schedule, parti-6 cularly startup operations or startup testing?
I A
Authority to establish it?
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G Yes.
W0 A
Well, I guess the utility establishes his schedule.
2 I'm not sure that regulatory -- except that certain tests
-71 prior to certain events taking place, I'm not sure the regu-22 latory staff has much input there or does much review.
I 23 4
All right.
How about among the different contractors 24 '
and licensee groups.
Do you know which groups were responsible 0
a! Reporters, Inc.
25 primarily for establishing the startup test schedule?
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1 A
I'm afraid I don't know much about startup test i
2 schedules, except that the utility must somehow work that out. i i
3t g
Did you ever learn of any indications that the 4
preoperational or the startup test programs for TMI 2 were 5
subject to schedule pressures?
6 A
I can't speak for the utility's pressures on his 7
own people.
I don't recall of any schedule pressures on the 8
regulatory staf f for startup or operational tests, expediting 9
those tests.
I don't know of any instances.
i i
10 G
Did the licensee express any rush to get the safety Il relief valves replaced once the problem was identified?
i 12 }
A I'm not sure I understand your question.
Did he 13 express to us?
Would you phrase your question again?
I don't 14 understand it.
15 G
Did you ever hear of any indication or expression 16 {
by the licensee or B&W or Burns & Rowe and others involved 27 that there was a rush to get those valves replaced so they u
-} could maintain their startup test schedule or for any other I*'!
reason?
-+y A
There may have been.
I'm not aware of that.
It 21 '
wouldn'tsurprisemethattheywouldrushtogetthemreplaced.l l
22 The plant is an operational plant and the longer it's not j
23 h operating, I guess the worse it is for the ' utility.
But I F
l 24 don't recall.
And again, I don't know if the utility did.
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25 But from a regulatory standpoint, I don't recall any rush.
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1 If I can interpret your question in this way, that, was there 2
pressure exerted on the staff by the utility to review and 3
approve it quickly, if that is your question, I don't recall 4
of any.
There well may have been.
i i
5l The utility generally is anxious.
When he is at a I
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6 certain point, he is anxious to move ahead.
But if the thrust I'
7 of your question is, did I discern any pressure to expedite i
8 the review, with the feeling that perhaps we may have been i
9 pressured into some expedited review, I don't recall any such l
10 pressure.
11 l G
How would you characterize the quality or the margin 12 !
by which_TMI 2 passed its startup tests?
l N
e 13 A
I can't answer that, just because I don't know.
I i
14 didn't focus on the startup testing or the degree of compliance!
15 or the problems that they ran into.
16 BY MR. HEBDON:
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G In the course of your review, do you look at the i
b 0,; actual results from the startup tests?
Do you see the actual 12 9 results that they develop?
i
_C A
I think they do.
I think they transmit the test 21 results, but I'm not certain.
22 G-To whom?
23 A
I&E.
24 G
To I&E7
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25 A
Yes.
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1'l G
But are they reviewed by NRR?
2' A
I don't know.
3 MR. HEBDON:
Thank you.
4 BY MR. VANDENBERG:
5 G
Did you ever determine why the licensee completed 6
or nearly completed its startup test program on December 30th, 7
as opposed to, say, completing it the following January?
l 8
A You mean December 30th as opposed to January l?
9 G
Yes.
10 A
No.
State your question again?
'l i G
The licensee completed, or at least nearly completed,!
12!
their startup test program by the end of December, and I'm s
13 wondering if you knew of any reason why they completed it on l
14 that date, as opposed to letting it go until January.
15 l A
No, I don't know.
16 l G
How and what was the extent of coordination between
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you and other people in NRR and in the I&E inspectors regarding i
Jg the quality of the completed test and the startup test program?
I9 !!
A There is none that I know of specifically.
Whether l
there is informal contacts, there may be; but I am not aware 21 l of any fornalized procedure other than I&E reviewing the 22 startup test programs, and if they have problems, then alerting; 23 jl l
us to those, which has happened. If thqr have a specific 24fproblemwithatestthatrequiressomeevaluation on the
, # Repo,ters, Inc, 25 part of NRR, they then, by either a transfer of lead l
l l
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1 responsibility or discussion, resolve those problems and get 2
input.
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But if I&E reviews the startup test program and it l
-4 is satisfactory, unless there is some informal mechanism --
I 5
I don't think there is a formal mechanism to that, to the i
I I
6, best of my knowledge.
I i
7 Do you know of any instances where a licensee i
I 8
attempted to speed up or delay completion of their test 9
program?
10 A
There have been instances where test programs have j
ll i been delayed.
To the best of my knowledge, they had to do with l
12 delays in the completion of the construction or delays in 13 equipment.
To my knowledge, other than those practical 14 reasons, I know of no reasons why delayed or deferred speedup --
15 I know of no specific reasons.
I would assume that the 16 applicant was anxious, wherever he tried to expedite, was
. anxious to complete his p/lant.
17 n
G You can't think of any specific instances where a
.a 1
i 19 fi licensee was trying to speed up their test program?
l S
l E
A I think in general he is trying to speed up his i
1 21 test program.
I think he is trying to do that in general.
i 22 Now,.whether he was trying to speed it up because he had a l
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23; particular deadline.-- as a hypothetical example, we in the i
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24 '
construction permit, in the permit for the construction of
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- l 25 the plant, there is a date for the completion of the i
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construction, whereas if the applicant is not to meet that, l
2 even though we may be under the licensing review, he is bound 3
to, 30 days before that date expires, he is bound to come in 4
here for reasons for delay.
5 So I would suggest that of tentimes a utility, for 6
whatever reason, would like to speed up his test program and 7
complete his plant so he doesn't have to go through that 8
problem of informing us and requesting delay in the completion 9
of his construction, which requires an amendment to his 10 construction permit.
l 11 !
So I am aware that that could happen, but specifically, 12 I other than those kinds of reasons, I don't know.
13 I don't know if I have answered the thrust of your 14 question or not.
15 l G
You have.
16 '
Do you believe it is possible for a licensee to rush i'
' 7 ',
their test program to the point of compromising safety without d it the knowledge of NRC?
il I? ]
A Oh, I would think so.
My personal opinion is, from 3
20 considerable experience in the field, is that if there was a 21 deliberate attempt to mask or to deceive or to dissemble in 22 any way, I would think it is possible.
The tests are numerous, 23 detailed, require significant manpower, and'in my view it is 24 very difficult for a one-to-one correlation from NRC onto those
% e neponen, Inc.
25 tests.
So it would be possible.
I can't conceive of why he
mta 12 13 I
would want to do that.
I 1
2 BY MR. FOLSOM:
I 3 !
O May I ask a couple of questions?
4 We speak of Met Ed as "he. "
Who would the Commissioni 5
be dealing with by name with respect to the issuance of the 6
operator's license and the startup time?
7 A
Well, the operator license is issued and it is 8
issued -- I think Mr. Herbein was the officer at the utility.
9 He is the vice president with whom most of the management 10 discussions took place.
There were several other contacts 11 l and we have those in our list of utilities.
If you have our 12 roster of utilities, it outlines the responsible management s
13 official and then the technical contact, the licensing contact, 14 and then the lawyers are also involved.
And we had a service 15 list that delineates those, and we provide those so that the 16 license is issued by Mr. Denton to the company, and I think i
17l it is addressed to the company, but with the attention to oJ whoever the responsible official is.
I think it was h
I Mr. Herbein, but it may'have been the president.
But that is c
i the "he,"
that is the utility.
l 2I Now, we have other contacts that we deal with on a 22 day by day basis, and I have forgotten the gentleman's name 23 l for Three Mile Island 2 --I should know it; I've forgotten it --
24 that we dealt with in the licensing arena, who sets up meetingsI j
..ai n n or m i. ire.
25 and interfaces with us.
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But oftentimes Mr. Herbein would attend the meetings 2
we had here.
3 BY MR. VANDENBERG:
4 G
Steve, do operating licenses in general or TMI 2's 5
OL in particular stipulate that certain test items must be 6
completed within an allotted time frame?
7 A
Test items?
I can' t recall.
There were several 8
conditions on the TMI 2 license, numerous conditions which 9
had associated with it various completion dates.
I think that 10 on some of those items there were instances where not only was i
11 l the design to be implemented and modified as approved and the i
12 I test resnits had to also be completed in that sense, where s
13 there were specific things culled out.
And I can't recall 14 specifically, but I think at Three Mile Island 2 there were 15 some instances where in the license it addressed as part of 16 the overall, the testing to be completed as well.
17]a But in general, the startup tests, the license eg discusses modes, but I don't think discusses the specific l9y date-when these tests are to be completed.
A BY MR. HEBDON:
i l
21 ]
When time is included as a factor for when a test 22 may be done, what you're saying, then, as I understand it, is 23 l that that time is tied to some mode of operation?
In other
'l 24 words, this test must be completed within six months following M 21 Reporters inc.
25 mode one operation or mode four or whatever, rather than L
mta 14 15 I
saying, this test must be finished by June 1st.
2 A.
Yes, it is tied to an event or tied to prior to l
3 reaching such a plateau.
In that sense, yes.
But there may 4
be, within a particular mode, there may be a date tied into it i
5 as no later than for certain instances.
And I'm trying to l
6l think of a specific condition in the TMI 2 license.
There 7
were some hardware changes that had to be made, and the hard-8 ware changes had to be made and the test results run and the 9
tests completed p-ior to a mode, I guess, rather than a specific 10 date.
I think it was prior to a mode, as I recall.
MR. HEBDON:
Thank you.
l l
BY MR. VANDENBERG:
-s 13 Q.
Steve, do you know of any meeting that was held, Id whether or not you attended, where the license test schedule 15 l
was discussed for the purpose of trying to speed it up or put
'6 l pressure on completion?
A.
I think there were some meetings with the project
" ll manager that I am aware of that had to do with the overall j e :i
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progress of where we were in the license review, and when it d
appeared that we would be ready with a recommendation for an i
i operating license, that there were so many open items that had i 22 i
to be completed and when, applicant, are you going to get the i
3 responses in to these questions.
i
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Associated with that discussion was a turn to, all
- = 1 at Reporters, Inc, right, now let's see where you are on your preoperational i
ll i
mto 15 16 I
testing and let's see how your schedule is coming on there, 2 ll to be sure that that schedule is consistent.
If you want to 3
reach this end point, be sure you pay the proper attention 4
to your preoperational test program as well.
So in that 5
s e ns e, I'm sure there were meetings.
6 g
Is there one in particular you can remember?
7 A
No.
I normally did not attend the detailed level i
8 meetings.
But there are meeting summaries available on all 91 of these meetings that were held, and I'm sure that discussions' 10,
like that took place, because that is part of the scheduling II activity that we do in terms of allocating our resources.
l l
12 g BY MR. LANNING:
i 13 g
Who within NRC composes the operating license per se i
14 for a plant, writes it?
I i
i 15 l A
That is done in the project management in the 16 ',
various branches.
{
i i
i 17 i G
Where does project management get its input for outstanding license issues, for example, the requirement that l'
c-4 l'
is required:to complete the various modes, the test procedures?
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23 i f
i 24 4:
- 3. Reporters, Inc.
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458105 01 17 3pHEE I
A As I say, I'm not sure the test procedures are 2
specifically called out in the license, but they are called 3
out in the Tech Specs, which are part of the license.
- Now, 4
those all come f rom the standard technical specification 5
group, which is one of the people that put together the 6
specific Tech Specs.
7 0
This is the license for TMI-2.
License number 6
I want you to take a look at Attachment 2 to the v
Operating License and you will see a list of requirements 10 there.
11 MR. FOLSOM:
Do you want to identify that as an 12 exhibit or for identification. purposes?
13 pR. LANNING:
I thought I had.
It is the license 14 numbered DPR-73, Docket Number 50-320, Three Mile Island 15 Nuclear Station Unit 2 Facility Operating License.
And it 16 is dated February the 8th, 1978.
17 MR. FOLSOM:
Fine, tha t ge ts us there.
18 BY MR. LANNING:
19 0
Maybe you should look at this.
The first part is 20 the license, as I understand it.
21 A
Right.
22 0
And then there is an attachment to the license.
23 A
Right.
24 0
And then Attachment 1 is Technical Specifications.
25 A
Right.
L
i458 05 02 18 wa pHEE I
O tJow, wi th regard to A ttac hmen t 2, there is a list.
2 It is titled Preoperational Test, Startup Test, other items 3
which must be completed.
There is a number of test 4
procedures identified in those f ew pages in the attachment.
5 A
Right.
6 0
Where does the project management get their input 7
to..those items?
8 A
I&E.
You see, ti.is is normally, as I said, as a 9
condition in the license.
Ideally, one would hope that all 10 of the preoperational testing would be done, that would be
.11 the preferable way to run it, but we recognize that there 12 are certain problems in procuring material, procuring 13 equipment and part of our evaluation seeks to see the ways 14 to satisfy the safety requirement reasonably, and yet at the 15 same time to proceed with the activities underway.
16 So rather than say that no license will issue, it makes 17 reasonable sense upon the review that these items could be 18 completed prior
> operational mode four, which is hot 19 shutdown, wherein the rea.ctor is still sub-critical with all
.20 of the rods in and these are required to be completed prior 21 to moving from those.
22 But, normally -- and you can see licenses which don't 23 have operational, many preoperational testings required 24 because there was sufficient time beforehand to complete 25 them all, wherefore, whatever reasons.
But, that is not an
458 05 03 19
..a pH EE I
unusual practice.
But we get thi s f rom IaE.
2 0
In your capacity as branch chief, how many licenses 3
have you issued?
4 A
Operator license s?
5 0
Yes.
O A
Just thi s one.
7 0
This is the only one ?
8 A
Yes.
9 0
Would you describe the process that NRC implements 10 f or a c hange to the license.
11 A
Amendment to the license?
12 0
Well, let's start with amendments, yes.
13 A
'Well, if there is some particular request, or if we 14 see something tha t needs to be done, there is a safety 15 evaluation prepared about that particular i ssue.
That 16 saf ety evaluation discusses the issue, what the conclusions 17 were, what the changes should be to the license, including 18 whatever Tech Spec changes have to be performed, have to be 19 a ccom pl ished, and includes the Tech Specs.
20 Tha t package then is put into the formalized amendment 21 format, which is a standard format that is used, that 22 indicates what the license is, what particular sections are 23 being c hanged, it indicates the saf ety evalua tion, it makes 24 a significant hazards consideration which is whether or not 25 the hearing should be -- there should be an opportunity for
)458 05 04 20 JapiEE I
nearing if it is a significan t ha za rd.
If it is, certain 2
events take place.
If it is not, we proceed then to prepare 3
the package f or OELD's concurrence, and then the amendment 4
is issued.
5 MR. HEBDON:
Could I interru pt for just a second?
o Could we go off the record for a moment?
7 (Discussion off the record.)
8 MR. HEBDON:
Let's go back on the record.
9 BY MR. LANNING 10 0
Besides the license amendment, are there other ways
.11 to change the requirements of a license?
Or to grant relief 12 from a license?
g ell, there are exemptions that are granted from 13 A
W 14 certain regulatory requirements, which are then included in 15 the safety evaluation.
And I assume are included in the 16 license itself.
But once a license is issued, I am not 17 aware of other mechanisms other than amendment.
Even Tech 18 Spec changes require an amendment to the license, so I am IV not aware of other ways to change the license.
I'm a little 20 bit fuzzy on exemptions because there are certain 21 regulations that have certain provisions for exemptions that 22 can be provided or can be granted by the Director, so I 23 could see a particular regulation, for instance, applying to 24 some reactors that are already licenses, and that it might 25 take a letter perhaps, granting the exemption and it might 1
658 05 05 21 a pHEE 1
not'specifically appear in the license, although that would 2
a ppear untidy to me.
But that might ha ppen.
3 0
You have been reviewing a document the title of 4
which is Safety Evaluation by the Office of Nuclear Reactor 5
Regulation Support Amendment Number i to this already 6
opera ting license number DPR-73.
It is dated March 3, 7
1978.
At the bottom of the first page there, there is a 8
sentence addressing something to do with the f act of the 9
interest of minimizing the delays in licensing process.
10 A
Yes.
11 0
Do you recall under what circumstances those delays 12 ref erred to?
13 A
Well, f rom the language in the paper, that says in 14 the interest of minimizing delays, the licensee proposes 15 that a waiver of the requirements of the Technical 16 Specifications be granted to permit perf ormance of 17 hydro sta tic te sts.
I am assuming that that means -- and I 18 would read it to mean -- tha t the applicant is anxious to 19 keep his work on schedule and that he is asking for certain
.20 deletions or waivers to be granted in order for him to keep 21 his schedule.
22 0
So the NRC approved that amendment primarily for 23 the purpose of minimizing delay?
24 A
I didn't say tha t.
25 C
Let me ask the question diff erently.
The A
458 05 06 22 od pd EE I
amendment -- what in your opinion is the basis f or that 2
amendment?
3 A
It is indicated in the safe evaluation.
4 0
In the Metro poli tan le tter of February 24th,
'78, 5
directed to Director of Nuclear Reactor Regulation, 6
a ttention R.W. Reed, Chief -- that is from J.G. Herbein, 7
which, in effect, is the letter requesting Licensing 8
Amendment Request Number 1.
Y In that letter, there are reasoning for amendment 10 request.
And I'm quoting, This amendment is nece ssary to 11 avoid celays af ter heatup of primary system that could 12
. resul t f rom coolant leaking through new pressure boundaries 13 that have not yet been hydrostatically tested.
14 A
You see, he is anticipating f uture delays, not 15 delay for that moment.
He is saying that if you do it now 16 it is going to save me time because if I do it later and I 17 find I have a leak, I'm going to be in worse problem because 18 it's going to take me longer to fix it.
He doesn't want to 19 do the test now because it is going to delay him.
He says 20 t ha t it would be more expeditious for him to do it now and 21 correct his problems, rather than wait til later, which 22 would be a little more difficult because of the status of 23 the system.
24 0
But as I understand it, these requirements for this 25 certain testing of the equipment were to be.done when they
S58 05 07 23 pdEE 1
were in operational mode 4.
2 A
Ri gh t.
3 0
And March 3rd, I don't think they had comple ted 4
mode 6 or 5 by that time?
5 A
Right.
And the impact being that no later than 6
mode 4 do you want that done, and as the saf e evaluation I 7
think indica tes, I just glanced at the document in the few 6
minutes that we had, indica te s that the acceptableness of Y
the test that the applicant proposed met our requirements.
10 And we saw no reason why the applicant's request couldn't be
.11 granted f rom a saf ety standpoint.
12 BY MR. HEBDON:
13 0
.As I understand it, what you're saying is that your 14 perception of what the applicant has requested is that he be 15 alloweo to do the test earlier, not later?
16 A
That's right.
17 0
And the reason he wanted to do it earlier was in 18 order to avoid potential delays that might exist or might 19 develop if he were to do it at a later date.
20 A
Yes.
21 MR. HEBDON:
Thank you.
22 BY MR. LANNING:
23 0
I want to return back to the question of 24 e xem ption s.
You cad mentioned earlier about in-service 25 inspections.
L
23 05 06 24
%JpHEE I
A Rignt.
2 0
And how it relates to commercial operation.
3 A
hell, I mentioned that I know there is some 4
discussion about commercial operation, but I've forgotten 5
the nexus, but there is some discussion.
I don't recall o
wha t it is, specifically.
7 0
What does commercial operation really mean to you?
8 A
As I understand, commercial operation is when the 9
utility has arrived at a point where he is now going to 10 financially benefit, reap the benefits of the plant.
Il 0
Which means what?
12 A
He is now going to get the tax breaks and his 13 depreciatjon will start, his whatever other financial 14 benefits accrue to him as a result of having an opera ting 15 facility, and that is in the financial understanding of lo it.
It also means to me that he now has a responsibility 17 f or the plant and the vendor has essentially discharged his 16 warrantee obliganions with whatever his contractual 19 obligations were.
20 It is an inttrpretation that I have.
There must be, 4
21 perhaps a be tter. definition, but that is my understanding of 22 it as.best-I know.
23 0
To grat,t an exemption f rom a license does not 24 rcquire an amendment; is that true?
Or is an exemption to 25 the license require an amendment to the license?
A
- 458 05 d9 25 spHEE I
A I don't know.
Tha t is what I mentioned earlier, is 2
I tnink there may be instances where an exemption is granted 3
and that amendment may not be forthcoming, and I am hazy on 4
that point.
I don't know what the specific requirements 5
are.
6 BY MR. HEBDON:
7 0
Is it your understanding that the normal practice 8
is that an exemption is an amendment?
9 A
That is my understanding, is tha t if an exemption 10 is given, it is reflected somehow in an amendment.
If it 11 isn't, we ought to do tha t.
12 0
In a letter of April 21 st, '78, to Metropolitan 13 Edison Company, signed by Roger Boyd, Director of the 14 Division of Project Management -- would you read that?
15 MR. HEBDON:
We apologize f or the quality of that 16 c o py.
17 BY MR. LANNING:
i8 0
The first few pages in f ront of that is what you've 19 been looking at, which relates to tha t.
Can you determine 20 the purpose of that letter?
21 A
Yes.
This was f rom the in-service valve testing, I 22 think.
In-service testing, I think for pumps and valves.
I 23 think, I can' t read that first paragraph at all.
24 Yes, this is the one that -- I think, that af ter the 25 license had been issued there was some requirement placed
~
l
-)458 05 10 26 dpHEE I
because of the requirements delinea ted in one of the Regs 2
and that an exemption is given if requested, and if findings 3
are made that an exemption can be granted.
And this, I 4
think, addre sses that.
5 0
What specific requirements?
The ASME code?
o A
Yes, I think ASME code Section II, paragra ph 5, 7
6(g) or wha tever it is.
I've forgotten what the paragraphs 8
were.
Here it is.
50, 55(a)(g)(b)(1), which refers, I 9
think, to the various ASME code Section 11 for in-service 10 testing of pumps and valves, il 0
Is it your understanding that that is also covered 12 by Technical Specification requirements?
13 A
Yes.
g 14 0
Is it also your understanding that that letter 15 grants relief f rom certain in-service inspection 16 requirements?
17 A
Yes.
It grants relief for a certain period of 18 time,.right.
19 0
Was that relief granted to an exemption or an 20 amendment?
21 A
I can't recall.
I recall the letter.
It is 22 apparently that this letter was the basis upon which the 23 granting of the relief was made and it didn't result in an 24 amendment.
I think the practice was to take care of it by a 25 letter f rom the division of project management or the
458 05 li 27 apHEE I
appropriate operating division, like operating reactors.
2 But I am looking f or the Tech Specs.
If the Tech Specs 3
were changed, why weren't the Tech Spec changes -- oh, 4
because it was granted in the le tter itself.
I assume there 5
was no amendment.
I think that was in procedure.
6 O
Af ter a license is i ssued, how are changes to the 7
FSAR handled or reviewed?
8 A
That i s a good question.
That has arisen from time 9
to time, that if the applicant does change, or some thing 10 happens that he wants to have changed anc it aff ects the 11 principal engineering and architectural criteria, I assume 12 that he submits to us -- I think he submits to us whatever 13 the appropriate paperwork and documentation outlining the 14 particular issue and the concern.
We evaluate it and if it 15 requires changes to his Technical Specifications those are 16 made by amendment.
17 0
How would these changes to the FSAR be communica ted 18 to the NRC?
19 A
Well, most of the changes -- I don't recall changes 20 specifically to the FSAR, except where there are license 21 cond i tion s, there are a certain set of licensed conditions 22 which require design work.
And then they submit us an 23 amendment to their FSAR and we review it.
And then it 24 appears as a removal of the condition f rom the license.
25 Most of the paperwork tha t is associated with changes af ter O
458 05 12 28
..a pH EE I
a license have to do with changes to the Technical 2
S pecif i ca tions.
They then propose or request a change to 3
the Technical Specifications.
That change is evaluated and 4
a saf e evaluation is written, conclusions are made, and if 5
appropriate to be granted, then a license amendment is then 6.
issued, which inaicates the changes in the Technical 7
Specification, because the Tech Specs are part of the 8
license.
9 I'm not aware -- and don't know -- what ha ppens if there 10 is a change or if it has happened, if there is a change in 11 the design that didn't af fect the Technical Specifications.
12 I don't know what would ha ppen.
I would a ssume that he has 13 responsibilities similar to the construction permit stage, 1
14 where if it affects the principal engineering and 15 architectural criteria and if it is an unreviewed saf ety 16 question, then he has an obligation to inf orm us and then a 17 finding is made.
And if there is a Tech Spec change then 18 the amendment is issued.
19 BY MR. HEBDON:
20 0
Is there any effort maintained to keep the FSAR and 21 tne Tech Specs consistent?
22 A
There have been ef forts in that direction.
There 23 have been significant discussions f rom time to time about 24 keeping FSARs current.
And the responsibilities that the 25 applicant should have in keeping FSARS current.
There was a
i458 05 l'3 29 apHEE I
f airly extensive discussion on a draf t paper, draf t Reg 2
Guide, or some regulatory draf t paper that was before the 3
Ratchet Commi ttee, that discussed the requirement of having 4
all of the FSARs for all of the operating plants brought up 5
-- to assure that they brought up to current as-built o
conditions.
7 0
Wha t is the current status of that?
8 A
I think that i t went back, as I recall, there vere 9
comments given to that paper by the individual committee 10 members and I think it is still under review.
I've 11 f orgotten wto the contact was on it.
But I know, for 12 instance, that Roger Boyd made extensive comments on the 13 proposal and it is still under review.
I don't know where 14 it is right now.
15 0
So then it would be safe to say that at the present 16 time, at least, there is no systematic effort to ensure that 17 FSARs are kept current?
18 A
I don't know tha t.
There may be in DOR.
They have 19 activities underway that I'm not aware of.
I've related to 20 you as much as I know.
21 MR. HEBDON:
Thank you.
22 BY MR. LANNING:
23 0
The list of license conditions that uppear in the 24 Operating License, do you have a -f eeling for whe ther the 25 number listed there is normal, exce ssive, less than usual
458 05 14 30
..d pd EE I
Compareo to other license s?
2 A
My guess -- it is somewha t greater than what I 3
understand would be the average.
As I say, I have no t a 4
great aeal of experience, myself, in Operator Licenses.
But 5
f rom the number of conditions and the items, I would say it 6
is not -- I don't think unusual, but I think it is somewhat 7
more than the average, is my perception.
8 0
Is.there any reason why only one Operating License 9
has been issued by project managers in your branch?
10 A
Well, we are mostly associated with cps.
And OLs ll are just now beginning to come in, and I have been Branch 12 Chief there for about two years and this is the only one 13 we've i ssued.
We have several under reviews we have many 14 under review.
15 0
Is it correct that your branch still has 16 responsibility f or Three Mile Island 27 17 A
We transf erred responsibility today.
18 0
What has been the time f rame from the time it 19 received its OL until it was transferred?
20 A
I've forgotten what the date of the OL is, which 21 was '77.
I've f orgotten what the date is.
22 C
17 months, or thereabouts?
If they received an 23 Operating License in February '787 24 A
Well, from then til now.
25 0
Is that a normal period of time, which a plant
358 05 l5 31 apdEE I
woulc remain in the division of projects management af ter 2
receiving their license?
3 A
We ll, I'm not sure that I know that there is a 4
normal period of time.
I believe it is too long.
5 0
What is the normal procedure?
o A
The normal procedure is to delineate, in a 7
memorandum, to delineate the outstanding issues in license, 8
ioentif y the responsible organization to resolve, to review, 9
and to technically resolve those issues, outline a schedule i
10 a ssociated with each of those issues.
This is an internal b
ll memorandum, now.
It discusses in a synoptic way the status I
12 of the plant, the summary of the review, a ppends to it the 13 safe evaluations, the various license amendments and the 14 license itself and a rather elaborate concurrence chain then 15 takes place with the project manager on the giving end and 10 the project manager on the receiving end and the branch 17 chief and the ads and everyone involved.
It is a rather 18 elaborate and rather extensive document.
19 0
Have you attempted earlier to transfer this license 20 to the division of operating reactors?
21 A
Yes, we have several times.
It is a matter of 22 resource allocation.
23 0
Would you expruo upon that, what you mean?
24 25 i-
sbrv&Arve; HEER/pv 32 i l
1 A
The effort that it takes to set up and to receive an 2
operating plant requires personnel in the new branch that it is 3
going to requires the licensing assistants assignments, and it i
i 4
requires certain resources that the receiving branch han to have.
5 And my perception is that there were some difficulties in having
.6 the appropriate personnel available.
7 0
Did it have anything to do with the number of out-8 standing items in the license?
i 9
A It could have had some difficulty with that, but it j
l 10 was decided early, as I recall, that as long as the delineationi 11 of the responsibility, the specific item evaluation, and the 12 schedule was called out, that that would not be a stumbling s
13 block or an obstacle.
14 MR. HEBDON:
Let' go off the record for a moment.
15 (Discussion off t.a record.)
16 MR. HEBDON:
Back on the record.
XXX 17 BY MR. LANNING:
18 G
We want to turn now to th e question of technical quali:-
19 fications during a review of a plant.
What part does the pro-20 ject manager contribute to determining the technical qualifica-21 '
tions of the applicant?
22 A
He plays a role that is not explicitly defined any-i 23 where, but he does play a role.
He probably interfaces the
!l 24 greatest number of times and interfaces the most with the
[
Am.FWwel Reimrters, lre.
{
25 applicant and his architect engineer, his vendor, and the staff l
n.
pvs 33 I
that the applicant himself has, and over a period of several 2
years, forms a perception and a feeling for the technical quali-3 fications of the applicant.
4 There is also -- since you have asked me only about 5
the project manager, I will stick to that -- but there is also, 6
of course, input that he receives from others who have made 7
evaluations from I&E who make their evaluations.
If, for 8
instance, the utility has had other operating plants, if it is 9
an OL, the I&E also gives a perception of how they perform l
10 during the construction of the plant.
11 But the project manager's role is mainly in an over-12 all perce,ption which leads him to concur in a statement that 13 says that,'
with all of these other inputs that we find, that 14 the applicant technically qualified, he has no numerical 15 guidance, he has no checklist as such.
Most of the project 16 managers are knowledgeable about the design and operation of the 17 plants, and with discussions internally with the staff, with the-18 technical reviewers themselves, forms a rather detailed opinion 19 of the technical qualities and qualifications of the applicant 20 and his supporting contractors.
21 4
Where is this normally addressed?
In the SER?
22 A
It is addressed under technical qualifications.
I 23 have forgotten what the section is.
And it is also addressed 24 in the conclusions of the SER.
There is a section, I think, Ace Federal Reporte,s, tric.
25 on technical qualifications; that is Chapter 13 or 15, I have L
p 34!
I forgotten.
2 G
What part does I&E contribute to determining the 3
technical qualifications?
l 4
A They give -- I am not sure what the formalized role l
5 is -- but they give either informally or maybe by form, formal i
6 memorandum -- but that may not be correct.
Thef give a per-7 ception or an opinion about the technical qualifications or the
- 8 performance of the applicant if he has a plant in the field or 9
if there have been other reasons why I&E had opportunity to 10 interact.
Il For a new plant, even in the CP stage, I&E very early 12 interacts,with the applicant with a meeting at the applicant's s
13 home office with the senior members of the utility to establish 14 that early a QA program is under way, even before we have under--
15 gone much of a review, to be sure that whatever components he 16 is purchasing has an approved and an acceptable QA program.
17 And we get from the QA branch in NRC, get from I&E a report of 18 that visit and the perceptions of the applicant's QA program 19 and his implementation very early in the CP review.
l
(
20 And similar interfacing goes on by reports of inspec 21 tions which the project's manager gets, every report of inspec-4 l
22 tion that is performed by the I&E, Whether there is a specific i
l 23 document that says -- that addresses specifically their recom-
[
l 24 mendation or perception of the technical cualifications of the Am FWwQ Rgeners. Inc.
l 25 applicant, I don't know.
pv4 l
35 l
6 1
G Are you familiar with an NRC internal appeal process l
l 2
which is used to resolve technical differences between the 3
licensing staff and the applicant?
4 A
Yes.
5 g
Would you explain how that process works?
'6 A
In the acceptance review of the application, CP or OL, 7
there is a standard paragraph that is inserted that explains to 8
the utility that "we have accepted your application fo'r a 9
review and that we will be communicating within the terme of 10 schedules and that sort of thing."
And as the review progresses:
11 this paragraph goes on to say that "if you should run into some 12 problem o,r disagreement with the staff, contact,"
I think it s
13 says, " division of project management and succeeding levels 14 whenever you wish."
And this can be an informal contact; it 15 doesn' t have to be very formalized.
16 I think the paragraph gives some indication of " pick 17 up the phone and if you have a problem with the staff's require-18 ments, that can be appealed to upper management."
19 O
Is this process documented?
l 20 A
Yes.
21 O
Where?
22 A
I believe -- I think a sample letter is included in 23 the project manager's handbook that has that paragraph in it.
24 And I think one of the later revisions to one of the PMOPs --
~
, Ace Fewet Rgomm, lnc.
l 25 the project manager's operating procedures, which I think go I,
y 36i I
I into the project manager's handbook -- addresses that letter, I
2 and specifically, the paragraph I just spoke about.
l 3
0 What level of management does the appeal process start i
4 at?
l 5
A It usually starts at the branch level and goes usu-
-6 ally something like this:
that the applicant after responding 7
to some questions, outlines his case; he has a meeting with the 8
staff, and the staff tries to persuade the applicant about the 9
rightness of its views, and the applicant tries to persuade the 10 staff on its views.
II This continues perhaps for an iteration or two, where 12 some attempt at compromise is usually attempted in these pro-13 ceedings.
But fairly early, after about the second iteration, Id after another meeting with the staff where there has been per-i 15 haps one iteration, they then meet in the branch chief's office.1 16 And the branch chief then attempts to assess the staff and the 17 applicant's positions and further suggests an acceptable com-l 18 promise.
l If that is not successful, they then meet in the I9 20 assistant director'.s office, but by that time they meet with 21 the assistant director and'the division director together.
If 22 the division director then cannot resolve the issue and calling i
23 in appropriate other division directors -- for instance, the 1
24 division of project management and the division of site safety Am-Feerst Roorwes, lu.
j 25 will meet -- and that is the level they will meet in.
It has
[
t I
pv6 37 I
happened many times.
I have been involved in many of these 2
appeal meetings.
3 If that is not resolved there, it then goes to the 4
director of NRR -- in this case, Mr. Denton.
XXX 5
BY MR. HEBDON:
i i
6 G
In your opinion, what percentage of the issues that i
7 are referred to this appeal process end up being resolved in 8
favor of the applicant's position, as opposed to in favor of 9
the staff's position?
i 10 A
I don't know of any.
i 11 O
If the applicant -- if I understand you, then,you'rel 12 saying the applicant rarely wins?
13 A
The applicant rarely wins.
l i
14 4
Then why do they even bother to go through the appeal '
15 process?
I 16 A
I have often wonderad.
'17 MR. HEB DON :
Thank you.
l l
i XXX 18 BY MR. LANNING-19 G
Do you recall of any appeal made by Met Ed during l
20
'their license for Three Mile Island 27 l
i i
21 A
Yes.
They appealed the safe shutdown position, l
22 safety-grade cold shutdown.
Cold shutdown position, as I recall.
l l
23 O
Any others, or just the one?
l 24 A
There may have been others, but I can't recall any
! Aa Fede,d Reporters, Inc.
25 of the others.
I
PM 38' o
1 G
Do you recall one concerning the steam outbreak?
I 2
A That is the cold shutdown, the safety-grade equipment.i i
3 G
I see.
j i
XXX 4
BY MR. HEBDON :
I i
5 g
Excuse me.
Met Ed was required in the application 6
for TMI-2 to meet a cold shutdown requirement?
7 A
No. 'They mitigate the steamline break accident with 8
safety-grade equipment.
9 G
So it was not a cold shutdown?
10 A
Well, but you had to achieve -- no, you are correct:
11 That proceeded the cold shutdown branch position.
They had to 12 achieve a hot standby condition; that is correct.
13 MR. HEBDON:
Thank you.
XXX 14 BY MR. LANNING:
15 g
would you comment on the effectiveness of the present.
16 organization of segregating division of project management from 17 technical reviewers and as to the control which the project 18 manager has over the project, the resolution of issues and such; 19 things?
20 A
Ideally, the present systam should work without any 21 particular problems.
The project manager, through the techni-s 22 cal review branches and the two technical reviewers, has the i
23 issues that the applicant has presented, have those issues l
l 24 evaluated.
He calls meetings with the applicants and with the
' Am Federal Reporters, Inc.
25 reviewers and has those issues resolved.
His control, in that i
m
pv8 39 1
sense, is, I believe, adequate.
i 2
The control that I feel he does not have and is lack-3 ing:
He has no control over the technical content of the evalua-4 tion, particularly.
He certainly can interject wherever his 5
interest and persuasion leads him, and he can attempt to influ ;
I I
6 ence wherever he can; but the responsibility for the technical 7
evaluation rests with the technical branches.
So, consequently, l
8 his control in the sense of the technical review is rather l
9 minimal.
10 G
How are unresolved safety issues addressed at an SER?
II A
They are addressed either as a specific issues high-12 lighted in the SER, or not addressed at all under the assumption 13 that they have been resolved during the review.
The SER doesn't Id outline every facet of the review; it doesn't outline everything 15 that was reviewed and found acceptable.
It summarizes, high-16 lights, the significant issues that arose that were more than 17 the normal or more than the routine problems.
I 18 As you know, SERs refe'rence frequently previous l
19 reactors that have been reviewed of a similar design and simi-20 lar configuration, and the SERs rely fairly heavily on that 21 background, and that there is a.rather broad range of what 22 specific issues are highlighted in the SERs.
I 23 g
So, they would not necessarily list any unresolved safety --
24 A re-w neomn,1=.
l I l i
25 A
They would resolve unresolved safety issues if they
pv9 40 I
have not been resolved.
They would do that.
2 G
Is there any reason why this list of unresolved 3
safety issues should not be addressed in the operating license?
l l
4 For example, once the safety issue is resolved, there should 5
be some requirement for the applicant to meet a resolution?
6 A
They are.
If it is not resolved by the time of the 7
issuance of an' operating license, all unresolved issues, if we 8
proceed with the license, should be outlined as a condition to 9
the license.
10 G
How about generic safety issues, generic unresolved 11 safety issues?
12 A
Well, generic unresolved safety issues are addressed 13 in the SER or in the supplement or in, usually, in the SER.
In 14 the TMI case, was addressed, I believe, as a part of the ACRS 15 concerns.
16 Now, if you recall,the time frame of the generic 17 issues, so-called " unresolved safety issues," have a rather 18 long history.
They predominantly started out as ACRS concerns ;
19 and in the ACRS letter for TMI-2, they outlined that these 20 specific issues are applicable to TMI-2.
And those issues were 21 then resolved or discussed in the SER of what the resolution
?
22 was.
23 Subsequent to that, there were these.
The continued 24 staff efforts and interaction with Congress and the various Ace. Federal Repersets, Inc.
25 categorizations that took place of safety issues took place
pv10 41 1
after the license of TMI was issued.
And I can't recall whether 2
during some of the license proceedings after TMI, like the air-3 craft crash hearings that went on, I can't recall whether 4
generic issues were discussed, but I seem to have a feeling that 5
we addressed the categorization, the generic items that have i
6 been categorized or addressed in some manner, and I can't recall 7
when.
8 But for TMI, at the stage of the license, the l
9 unresolved safety issues, or so-called " generic concerns," were 10 those addressed in the ACRS letter.
11 G
Only the ACRS letter?
12 A
At that time.
But, as I say, subsequent to that, I 13 seem to recall that there was some additional work.
I may have!
14 it mixed up with another project.
There was some additional 15 work done with unresolved safety issues on TMI, but it may have' 16 been that TMI, as were the other operating reactors, would be 1
17 taken care of in the procedures that the other operating 18 reactors were going to follow.
19 G
What are the functions and what contributions do the 20 Atomic Safety Licensing and Appeal Boards make from a stand-l 21 point of increased safety?
22 A
Well, that is a broad question.
23 G
Well, let's start with what the functions are of the 24 appeal boards.
Ace Federal Reporters, Inc.
25 A
Well, as I understand the appeal boards -- and 1
N-
pvil 1
42
- 1 probably counsel knows more about those than I do -- but the 2
appeal board takes the initial decision that the-licensing l
3 board has arrived at and reviews it, not necessarily because 4
someone has specifically appealed to it, but I think just :-
5 reviews it as a matter of course, I think.
And then it either concurs or makes whatever findings; 6
i 7
it feels are appropriate.
~
8 In the meantime, however,'it has to Iaact rather i
I 9
quickly because of an ASLB decision and has a certain specific !
i 10 schedule that has to be followed so that there is a certain l
11 period of time where the appeal board acts before the license 12 is issued.
13 G
So, they review or hoLdhearings prior to issue of a 14 license?
15 A
Yes.
The function of them, of the ASLB, holds hear-16 ings.
Now, the appeal board may hold hearings, if they don't 17 remand it to the licensing board.
Rarely, they have done that..
18 Mostly, they remand the issue to the licensing board and s.ay to; 19 them, "we find such and such and we are remanding this to you,"'
20 which I understand means you would get new hearings started and 21 call witnesses and do your thing.
l 22 And then the appeal board then reviews that again.
i 23 G
How do the decisions of the licensing board find theiq 24 way back to the staff?
Ace Federst Reporters, Inc.
25 A
Oh, the licensing boards provide an initial decision I
pv12 43 I
that goes to all the parties, including the staff, and it goes i
2 to our counsel and to the project managers and, depending upon 3
what that initial condition may say, either a license is issued 4
with appropriate conditions as called out by the board or what-i 5
ever the' initial decision says.
6 G
Do you knew the scope of their review?
7 A
Of the ASLB7 l
t l
8 G
Yes.
9 A
Well, as I understand it, they don't do a sui sponte 10 review; they don't do another review of the plant.
They review, II I guess, what the staff has done.
But that doesn't mean that f
12 they can't explore whatever area that they feel are necessary, 13 and they do, as I can point out -- Dr. Jordan, in several Id instances.
15 So, they review the staff's work, the applicant's 16 work, and whatever else they think is appropriate.
17 4
Do you see their role as a contributor to increased l
18 safety?
19 A
Insofar as it imposes on the staff another -- not that 20 it doesn't have enough -- but another pressure to do a gooc job 21 and to search itself to areas that could be open to question and I
22 to be sure that it has resolved the issues satisfactorily.
23 Insofar as that aspect of it goes, I think it serves a very 24 useful function, particularly when issues are discussed and Ace Fede,-f Reporters, Inc.
25 testimony is prepared and highlighted.
t e
pvl3 44 l j
j 1
So, I think it is a very useful checkpoint for the j
2 staff.
I myself am not aware, except in one or two instances, 3
where issues not raised or discussed by the staff were raised l
4 wy the board that resulted in some added assurance fo r safety.
5 But that doesn' t mean they don' t.
I just myself don't know.
XXX 6
BY MR. HEBDON:
7 g
I would like to go on and ask you some questions con-8 cerning precursor events.
9 A
Precursor events?
10 g
Events that occurred prior to the accident at TMI Il that might have provided some indication or some warning that 12 that particular accident was going to occur.
I 13 What was your position in the organization in January 14 of 1978?
15 A
I was branch chief.
16 g
How many people reported to you?
17 A
11, 18 G
To whom did you report?
19 A
To Domenic Vassallo.
20 g
Did Carl Stahle work for you in that particular time 21 period?
22 A
Carl Stahle did work for me.
I 23 MR. HEBDON:
Can we go off the record for just a i
I 24 second?
" Am.FWwel Reu.srs, Inc, l
25 (Discussion off the record.)
l
%'9 I
l f
CR 6458 45 HEER 7
- mto 1 1
- i., HEBDON:
Let's go back on the record.
I 2
For the purposes of the record, the questions and 3
the discussion that we have just had on the licensing process, 4
the intent of the questions w*s to get your perception of how 5
the system worked, what various terms meant, what constituted 9
6, amendment, what was an exemption, that type of thing, rather 7
than trying to get a legal opinion, which obviously you are 8
not qualified to give.
9 THE WITNESS:
I understand that.
10 MR. HEBDON:
Thank you.
i II I BY MR. HEBDON:
1 12 G
First of all, I would like to ask you some questions 13 concerning some questions that were asked by the ACRS during 14 their review of the Pebble Springs docket. Particularly, prior i
15 to March 28, 1979, vhat knowledge did you have concerning the 16 l questions raised bysMr...Ebersolel of the ACRS concerning the 17 l B&W small break LOCA analysis?
h la l A
Rather extensive knowledge.
I 19 ;' '
O Would you describe the knowledge that you did have?
l Ej A
Well, there was a series of questions, and I have l
21l forgotten, 25 or so questions 2aised by Mr. Ebersole, who 22 provided those in written form to us af ter a Subcommittee 23 l meeting, I thinP He bas part of the Subcnmmittee for 24 Pebble Springs.
, ' El E Cporters, Inc.
25 Those questions were rather extensive in nature and l
46 mt3 2 I
l some of them related to small break LOCA, some of them related 1
2 to auxiliary feedwater, complete loss of feedwater, loss of I
3!
off-site power, loss of all AC power, and several broad-ranging l 4
questions.
We reviewed those, and it was very detailed.
I 5
My knowledge is in terms of a peripheral way, knowing
'6l what the subject way.
I did not take each issue and in t
t 7
exhaustive detail examine the cogency of the question and the i
8 applicability, necessarily.
But we took a look at that in some 9
detail.
10 And then, as I recall,6we hadiseveral: meetings'with 11 l (thelstaffi (We sent?aTletter'to the applicadt sayihg, Ewe have_
12 itheselquestionsiandiwouldlyou please1 respond.
We also sent
~
13 a letter to the staff, not only sending the Ebersole questions, 14 but also the applicant's response to all of the appropriate i
15 l review branches.
16 '
And we had a subsequent meeting with all of the I~] review branches and the people that were involved in the 3
review of each one of those particular questions.
At the i
I9 subsequent ACRS meeting, the applicant made a presentation l
i 1
10 j item by item.
Mr. Ebersole and the rest of the ACRS -- this
{
d y
l was in front of the full Committee, during the Pebble Springs j
21 I i
l 22 full Committee hearing, c meeting, rather -- Mr'. Ebersole f
l i
fextensively[discussedthosewithAhe~,applidant,fand:lturnihg 23 24 ;[ lto f the7stiaff [from stime.td? timed or LthA : staf f !siperceptiod'..
f
- e. e repenm. inc. ;
25
- (3y Meelinglis that Mr.iEbersoleLwa's'--and I think
~
i o
mta 3 47
~
I said so -- kasTvery. pleased.Lwith..the response and complimented 2
the applicant for the job that it did.
I he llet ter i forwarding ithel q'ues'tio ns _ from/ theT ACRS T
3 0
~
~
4
- basica11ylasked' the questions. ~of 3 the i staf f ?;
5 A.
E Right.
6 4
Why were the questions then forwarded to the utility 7
to respond to?
i 8
A Well, we discussed this, I think,7with the ACRS.
j
~
9 3' staff, as I recall, andfit-wasian, agreement or^an, understanding to or we came to some understanding that these questions, although i
11 the letter said, I want the staff's responsa, we also inter-12 !
preted that as a broader -- in a broader context, that not I
13 only the staff but the applicantisNould'respdnd) Land 5thenswe't 14 l 5
'Gouldievaliaie f he applicant's response.a Because that is t
I 15 normally the way we do business.
The applicant proposes and 16 we review.
And we don't necessarily have all of the details i
17 '
of all of the designs.
l
\\
3 '!;
As you know, the review proceeds in accordance with
!? ' the Standard Review Plan and it appeared most expeditious to 2; y get the applicant's response, and we reviewed that.
'l 21 O
Was it a common practice for the ACRS to send ques-22 tions to the staff directly?
23 i A
We would get questions from the ACRS frequently.
i-24
G In a formal manner such as this, in the form of a
' o rd Rewrters, inc.
25 memo and formal written questions?
48 l
mto 4 i
I A
Yes.
We got some the other day on FNP, about three 2l pages' worth.
I i
3 G
Was this a common practice at the time that it was 4
done in this particular case, in late 1977, for the ACRS to 5,
provide?
I 6l A
Common practice?
No,(IJwo'uld-ndtisaym itiwas< common:
I 7
{ practice.. It was..a practice.
It was a specific requirement
~
8 from Mr. Ebersole, one of the members.
And we have had l
9 questions, formalized questions, from the ACRS.
I've forgotteni 10 the mechanism that the letter -- do you happen to have a copy II of the letter we got from the ACRS?
I2 G
Yes, I do.
It was a memo that was just addressed to 13 the staff.
I can get a copy of it if you like.
Id A
Do you recall who it was addressed to.
15 l G
By name I don't recall.
i 16 !
A My perception was at the time that there was no
-,i
' ' j' great -- there was no focused attention by Mr. Ebersole that k
he only wanted the staff.
He wanted answers to the questions, {
t
"!!,andIthinkwemadesome--therewassomediscussionabout 3 ii that, and the agreement -- and I think the appropriate proce-ll 21 h dure was agreed upon, was to gd6 the applicant to answer 22 those.
23 MS. NORDLINGER:
Would that letter be useful to you?
e4 c THE WITNESS:
Yes. I would like to see exactly who
.. w nemners. ine.
25 it was addressed to.
I f
mta 5 I
49
)
MR. HEBDON:
Certainly.
Let's go off the record for 2
a moment.
3 (Discussion off the record.)
4 MR. HEBDON:
Let's go back on the record.
5 For the record, this is a memo from Mr. Muller, 6
senior staff engineer of the Advisory Committee on Reactor 7
Safeguards to Carl Stahle, dated November 7th, 1977.
8 BY MR. HEBDON:
9 G
Now, as I understand it, that's the memo that to forwarded the questions to the staff?
l 11 A
Right, from a member of the staff. And we oftentimes 12 get questions in this form, often.
It is not very often we 13 l get them more formalized from either Max Carbon or Mr. Fraley, 14 but we do do that too.
But the11nteractionJbetween_my.istAff; 15 l imemberland the staff. member from'.the'!ACRS.tak'es: place rather,
~
e l
16 Loften.
I 17 1 G
Was this a common practice in the period when this
..;; particular memo was written, in late 1977?
I!
I?
A My perception is that it was, I would not say
- 0, common, but it has occurred frequently.
i.
21 g
What was your responsibility or function with respect 22 to this information in these questions?
I 23 N A
To assure that it was reviewed.
I 24 O
What signicance did you attribute to the concerns
- n. w Amorms. Inc.
25 raised by Mr. Ebersole and the responses provided by PG&E?
50 l
mto 6 I
i 1 l A
The significance I placed on it were, depending upon i
2l what the question was -- in some Einstances.Ilfel't the'qu' stionsi e
i 3, tjhile ; plausible, peihaps: exceeded what were then NRC. require-4 imentsTasTrelated f to. single..'f ailurel or~ loss of all. AC. power.
i 5
My perception was that these questions were penetrating and i
6 thoughtful questions, and that the answers likewise were j
7 thoughtful and responsive.
8 G
Do you recall a particular question, Question No.
6, 9;
that refers to the small break LOCA analysis?
I 10 l A
- yes, 11 i G
Part of that question discusses the issue of the 12 ;
operator's interpretation of pressurizer level.
Do you recall,
13 reviewing the respons provided by the utility to that parti-14 f cular part of the question?
15 A
I recall reviewing the responses.
I don't know that l
16 l!
I focused or recall focusing specifically at that time on that l
i
'7!
response.
i M!
O Have you reviewed those responses subsequently?
i!
I? ]
A Yes.
Mi G
Do you feel that the applicant adequately respended
[
21 to that particular question?
l 22 A
Well, I'm not sure that I understand all the ramifi-l i
i l
23l cations in detail, the similarities that ar'e being placed upon ;
24 that response or that scenario and the TMI 2.
There are signi-
- n w nwnters. snc.
25 ficant similarities.
There are.also differences.
-t
mto 7 51 i
1 There have been discussions between the various I
l 2
technical specialists on that specific issue and there are t
f 3
similarities, but there are also differences.
Whether or not 4
one could have extrapolated the subsequent events at TMI 2 5,
from that specific question and the response depends a great 6'
deal upon your own understanding in intimate detail with the 7'
system, as well as some of the specific other events that 8
could have happened in addition to what was outlined in the 9
question.
10 BY MR. FOLSOM:
11 O
I think you jumped beyond the question to answer 12 l something that might come up in the future.
But the question 13 really was, do you think that the answer to Question 6 was 14 adequate from PG&E7 15 l A
From my understanding at the time, I felt that the i
16 6 answer -- they answered the que,stion.
17 I G
Now, you've looked at it since.
Do you still think
\\
d.
it is adequately answered?
19 !
A Well, I haven't looked at it in the last three months.
L; And as I recall, when I looked at it there were some simi-21 larities, but I could also see'some dissimilarities --whether 22 or not, if they had extrapolated to some other contributing 23 f event, whether or not the response would have been adequate.
1 24 BY MR. HEBDON.
j ce r a ponm. w.
g 25 0
What responsibility did the staf f have to review I
m
mta 8 52 I
the technical content of the responses?
2 A
The same responsibility they have to review any 3
applicant response in connection with a licensing case.
I 4
G Do you know if the staff in fact reviewed the i
5, responses for their technical content?
l I
i
-6 l A
As I recall the meeting we had, that they had reviewed l
7 it.
8 g
Were there any questions or concerns raised by the j
?
staff as a result of their review of the responses?
i 10 A
Not to my knowledge.
l i
ll i G
In the normal course of a review, if the staff sent i
l 12 L out that number of questions, 25 or 26 questions, and received !
l i
4 13 1 responses, would it be normal for them to be able to review I
14 those responses and not have any additional questions, based i
15 i on your experience?
Does it strike you at all odd that, with i
16 that many questions, the staff had no additional concerns or I
l 17 j) no additional questions that they wanted to ask back of the 4l applicant?
d i:
A It doesn't strike me as odd, because most of the 20 ; questions went to scenarios that went somewhat beyond the 21 d assumptions and requirements li1d on by the standard practice 22 of Standard Review Plans and Regulatory Guides.
So there was 23 h a degree of interpretation that one wants to make on those il 24 " questions, tha$ perhaps the' reviewer'recogni'zedithe question'
- cua! Reporters, Inc.
25 Cand';said, well, lit.wsul'd be; in'terestingito see Yhatithe manswer.
~
~
U mto 9 53 j
I 1
Cis[lbutiltididn'.t raise'.into;hisidind,any doubts about his w
B 2
previous review in accordance with the guidance that he had.
j i
3 MR. HEBDON:
Let's go off the record a second.
l 4
(Discussion off the record.)
5 MR. HEBDON:
Let's go back on the record.
6 BY MR. HEBDON:
I i
7l G
Did you make any attempt to get more detailed 8
positions from the staff concerning the questions or their 9
responses?
10 A
Of these 26 questions?
11 G
Of these 26 questions and responses.
I 12 '
A No. [I as'sumed that the appro'priate attention _ ~and:
13 ithe appropriate ' evaluations Ihad/beNSbmade.
14 G
As you mentioned earlier, Mr. Ebersole also discussed i
15 these issues during the January 1978 ACRS full Committee i
16 l meeting.
Do you recall that particular meeting?
i 17 A
Yes.
.; d G
Do you recall his discussion of these questions?
19 :!
A As I indicated earlier, I recall his discussion as l
l Z/
the applicant went through.
I'm not sure he went through
!?
l 21!! item by item, but I think he re5ponded to questions that 22 Mr. Ebersole had based upon the applicant's response.
I think I
23 j that was the format.
And the applicant then answered specific il 24 h questions for Mr. Ebersole and from time to time he would turn
. - 31 Reporters, Inc.
I 25 to the staff for some comments.
j i
54 mts 10 l
~
l G
Do you recall the discussion of Question No. 6?
2l A
I don't recall the discussion of Question No. 6.
3 G
Do you recall a discussion of the f act that the i
i 4l operators would not normally be trained to see this particular 5!
transient described in Question No. 6 during their sinulator l
i
.61 training?
i j
I 7
A I don't recall any discussion.
8 G
Do you know if anyone on the staff discussed any i
I 9
of the questions or responses with anyone on the ACRS or the 10 !
ACRS staff?
i i
11 l A
Carl Stahle night have, is the only one I could l
t lo '
think of.
I don't know whether the other technical reviewers i
13 that attended these meetings that I discussed in terms of 14 l evaluating the questions, whether they had any discussion with '
15 !
the ACRS staff.
I don't know.
'61 i
l G
Approximately how many of these meetings were held?
,, l
"{
A Which meetings, now?
d
=
0 The meetings you are referring to within the staff.
'o n A
I think there was one that we had when.the questions,
".1 responses came in outlining responsibilities or outlining the i
/
I need that we had and the people who would attend.
Then we had 22 another meeting with management to go over the more -- high-21 li; light the ones that mayba required a little more i".-depth
'l e# e
' li evaluation than some of the others.
(
2a j : rat Rewrters, Inc.
25 There were two, I think.
Carl Stahle himself may i
l
_~
mta 11 55 l
l l
1 have had other informal meetings, but I don' t know.
2lg G
In hindsight, what significance do you assign to 1
3 the concerns raised by Mr. Ebersole?
l 4
A Well, I think you could take almost any of the i
1 5
questions that Mr. Ebersole raised and, by some extrapolation j
i 6;
or some peripheral modifications, probably devise scenarios i
7 that may be lurking out there yet, and that probably that, had l l
8 we been -- had some foresight about the specific events that l
l 9'
happened and perhaps more knowledgeable about or more appre-10,
hensive about operator action, perhaps one might have said ll i that that could have given at least some indication of some 12 '
- problems, i
13 But I'm not so sure you could separate that one 14 particularly from any of the others.
15 j 0
I would like to go on and ask you some questions that i
16 !
are in a more general sense concerning the functioning of the
- 7 ] NRC.
.?
Is there anyone in NRR who considers the operator i.l 19 ', as a subsystem and assesses his interaction with the overall a,
system, to your knowledge?
I 4
4,r..
Well, werassess the operator;.--In-the-technical:
i 21 A
I i
22 Ireview! branches, I assume you're speaking of.
l 1
23{'
O In any of the areas that you know' of, to your know-o anonm. ire.
[l 24 ledge within the NRC.
25 A
Well, certainly; operator trainingcand the' Operator?
I i
i
mta 12 56 org ev y s
,vp "r, e,9 JTraining. Branch; reviews the operator as a subset in the system 2
of operating the plant, and as part of -- just as a piece of 3
hardware, they are part of operating the plant.
G But that is from the context of training the 5
operators?
'0:
A Right.
I 7
g Is there anyone that looks at the operator and says, i
8 Here is what the operator is likely to see 'nd here is what he t
9 might do, or here's what he might not do?
A You are discussing it in terms of the design and
[
10 II l the technical disciplines as such, in the design of the plant, l
12 ;
for instance, or a specific system?
Our concern is given to s
13 the operator reaction.
I#
G Well, for example, we have a Reactor Systems Branch 15 j and they make an evaluation of reactor systems.
Is there a 16 l comparable Operator Systems Branch that makes the same types
,\\
i of analyses of the operators?
A Other than what would take place, to my knowledge, 19 li in the Instrumentation and Control Branch, who view instruments 3
,Y
" ii to monitor the course of an accident, for instance, or any of
/
.I those instrument areas where they do have some operator 22 interaction and cognizance there.
They may in terms of, for
^3
~
r l instance, assembling instruments on a control board, certainly
-i i
L have the operator somewhat in mind. Except for that area, I an! Recorters, inc, i
25 don't know of any areas where that might take place.
mta113 57 f
i i
I-0 What is your perception of the relationship between j
2 I&E and NRR?
l i
3 A
The technical relationship?
Well, for construction, d
for plants under construction, they are responsible to monitor I
5 that the plant is being built in accordance with the construc-i 6
tion permit, which includes the PSAR and all of the other 7
commitments by the applicant.
They review the construction 8
QA and make periodic inspections, announced end unannounced.
9 JIf thereiareipart' Acular fprob1' ems thdt. occur,3 Da ?tsansfer"of.
10 if ilead responsibility.we gat involvedlif it is appropriate, 11 it requires a technical decision upon a certain requirement 2
that the applicant has not met or seems to be a problem to I&E.
13 So we get involved in that interrace.
Id So there is considerable interface in that area i
15 l under construction.
And when plants are nearing the licensing M
stage, they conduct all of the pre-CP QA reviews.
If, for I
17 ': ins tance, they provide bulletins, if a bulletin goes out, there; i
I er l
is an interaction in terms of bulletins that they provide with to :i DOR, and we get copies in DPM as well of all the bulletins.
i
",,, p Occasionally, in a plant under construction or even i
I 21 i s
an operating plant, a bulletin oes out and they get a 22 response in as a result of that bulletin that requires some j
i l
23 technical evaluation..'R7 a mechanism of the ' transfer of lead e.a responsibility, they. outline that issue and essentially
- a! Aeporters, Inc.
25 turn that particular problem over to NRR.
And there are monthly
mts 14 58 I
meetings between NRR and I&E at the assistant director level 2
to discuss mutual problems.
3 G
In your opinion, how effectively does the current 4
I&E-NRR relationship facilitate the feedback of operational 5
experience into the licensing process?
6, A
well, I can't speak except from general knowledge of 7
what happens b'etween DOR, who have most all of the operating 8
plants, how that feedback mechanism -- I know that there is 9
significant interaction on LERs and significant events of the 10 i day and that sort of thing.
But in terms of the review -- and II I am assuming that you mean how, in the review process, do 6
12 things that I&E unearth, how do they get translated into the 13 review process.
14 -
G Yes.
15 A
There are -- the LERs are distributed to all the 16 !
- branches, inc1' ding the technical review branches.
The u
I 17 l bulletins are,'likewise.
There I don't believe is a formal o
oj mechanism that reviews and highlights for technical review n
M<
the disciplines' particular LERs to be given specific attention, 2 0,, unless they came through the transfer of lead responsibility, d
i 2I '
which is a specific problem that I&E sees that NRR needs to 22 get involved in.
23 ll l
But in terms of a formalized mechanism for assuring i
n 24 h that experience is translated into reviews of ongoing applica-a ae snone,s. inc. -
i 25 tions, except for this informal process, which is rather i
I
-mta 15 I
59 l
l I
1 extensive, I don't know of a formalized way.
There may be one, 2
but I don't know of one.
i 3
O When a significant incident occurs at a plant, at 8
i.
4 an operating plant, what are the lines of authority.tand I
i 5
responsibility for the subsequent investigation and analyses?
I I
I
'6; A
I'm afraid I really don't know all of the established I,
7 lines of authority.
I do know that is an Operating Reactors 1
8 responsibility.
I 9
G Well, it would still be a DPM responsibility for the i
l 10
~* ir to 18 months that an operating plant remains under control I
II I or DPM.
l I2 -
A Ostensibly, but in actual fact, as in TMI 2, although 13 the transfer has not taken place, the operating problems there,j 14 I the problems that occurred at TMI 2 were directly translated 15 l into actions by the Director of NRR to DOR, who then took i
16 f actions.
I 17 G
TMI, I think, may have been a little bit more l
l severe than what I really had in mind.
What I was concerned o
i
.n..
"1 about would be some of the more significant incidents that l
L [! occurred prior to TMI, more in the context of the staff being i
i l
21 P involved in an analysis and investigation, rather than an I
22 actual effort to combat the particular incident.
h 23 il Do you have any feel for the lines of authority and 24 dae procedures that would be followed in conducting an investi-
%-r nuoners, inc.
25 gation of such an incident?
i i
O
mts 16 60 i
I A
Well, if an incident happens at a plant, I&E, of 2
course, is the first line.
They either have a resident 3
inspector or they have a regional.
So under our present 4
procedures, they have this open line of communication to the 5
incident center, which is now established at all the operating !
l Sothatimmediatecontactwouldbemadeattheincidenk 6,
plants.
i i
7 center, as well as to the resident inspector.
8 The incident center is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day now with; I
9 DOR personnel and I&E personnel.
That incident center then 10 has established, as I understand it, specific procedures of II who to contact and who would be available and what actions 12 would take place from then on, depending upon what the parti-l 13 cular problem was.
14 c-7 G
What is a safety-related system?
s 6
15 I
I, 16 !.
i i
A 17 !
I I
4 4
1?.
1 20 4
i i
,....r 21 l
,e I
22 h
23 it br 24
.le
--f Peporters, Inc.
-25 s
CR 6458 #8 HEER/pv 61 a
1 A
A system that is required to mitigate or -- I have 2
forgotten what the specific words are -- to mitigate or prevent t
l 3
safety problems -- protection to the health and safety of the i
i 4
public.
5 g
Do'iyou knowiwhereEthatiparticularftermfisidefined?;
I 6
i IIIdhn't thinki,itfis definedianplspecific place.
And 7
by practice, it is included, the list of systems that are 8
included in the Appendix B list of systems that require a cer-9 tain QA, Appendix B QA procedure.
10 g
Appendix B to what?
II A
= Appendix. B itoL10lCFR 50'.
12 O
What does it take to be classified as at safety-related 13 system?
14 A
I don' t know if there is a formalized procedure.
It I
i 15 depends upon the perception of what that system does.
If it i[
16 has certain attributes in terms of mitigating or preventing l
17 accidents or preventing doses in excess of whatever the particu-l 18 lar limits are, which I have forgotten, then the NRC establishes I9 requirements for that in terms of seismic categories and redun-i l
20 dancy and '2EE.
21 O
Who decides if a system is safety-related?
22 A
The appropriate technical review branch, if there are ;
23 changes.
There are certain sets of safety-related systems now i
24 ( existing.
If a change is made, as it was made recently to a l Ace Fuere: Reporters, Inc
- 25 certain part of the effluent treatment system, it was decided l
l
pv2 i
62 I
that that system would be safety-related and certain safety-2 related requirements were imposed upon it by the' appropriate 3
branch that was responsible for the review of that particular l
4 part of the design.
5 g
Was that decision to include that particular part of 6
the system as safety-related reviewed by the RQC?
7 A
I think it was, yes.
I 8
G So, then, it sounds like there is some standard list 9
of safety-related systems.
Is that a true statement?
10 A
I don't know if it is standard.
I think that each Il particular plant has those structures and systems important to I I
12 safety, safety-related, which require established QA procedures i
13 in accordance with Appendix B of 10 CRF 50.
That list is then 14 the list that is provided in the PSAR and FSAR, which comprises, i
15 a list of the safety-related systems and components.
Whether 16 there is a standard one that appears in a regulatory document, i
17 I am not clear that there is.
18 G
Do you know if there is -- if a list of what systems 19 are defined as " safety-related" is included in the standard 20 review plan?
/
21 A
I don't know that.
1 22 G
What desigli review is required for a safety-related i
23 system?
24 A
The design review is outlined in the standard review Ace Federal Reporters, Inc.
25 plans, and I can't be any more specific than that.
o
pv3 I
63 1
G What design review is required for nonsafety-related 2
systems?
3 A
Again, whatever is required in the standard review 4
plan, which, as you know, is a rather extensive document.
l l
5 G
Based upon your understanding of the standard review 6
plan, in your experience, could you compare or contrast the 4
1 7
design review of safety-related equipment as compared to the 8
review of nonsafety-related equipment?
I ibelieve Ynonsafety-rela'tedI equipment.[ receives 1a f 9
A.
I i
10 freviewLcommensurate %ith.its. role in.'the; system".
Forinstance,!
l Il there are nonsafety-related systems that become important if, 12 as a consequence of its failure, it could impact or somehow r_
i 13 influence a safety-related system.
So, in that respect, 14
- nonsafety-related systems Lhave aigradation as: well', that they 15 get somewhat of a more detailed review.
Nonsafety-related
\\
16 systems, such as the parking lot lighting, for instance, or 17 others, would receive practically no review, if any at all.
18 G
What about something like the power-operated relief l9 ' valve; is that normally considered to be a safety-related system' t
or nonsafety?
h 20 i
As far as the relief valve itself, as far as its role !
21 A
22 that it plays in the small-break LOCA, I believe,as far as its 23 mounting and its-role in the primary system, is a safety-24 related system.
I do not know about its control instrumentation Ace-Federal Reporters, Inc.
25 or control mechanism.
I think it might be, but I am not sure.
pv4 64 1
But certainly, the part it plays in the primary system, it is 2
a safety-related system, in terms of its mechanical components.
3 G
Do you feel that the characterization of systems as 4
" safety-related" is applied in a consistent manner?
i 5
A I have no reason to believe it is inconsistent.
It I
6 wouldn't surprise me if there were instances of inconsistency.
7 G
One example that has been s ited that may clarify the i
8 point that I am trying to make is tha the diesel is classified,
9 as a " safety-related system," but the air-start system for the i
10 diesel is not.
11 A
That seems to be inconsistent.
12 G
Are you aware of other similar inconsistencies in the 13 application of that definition?
I 14 A
I am not right at the moment aware.
I 15 G
Is it your perception that such inconsistencies are 16 common?
l 17 A
Not being aware -- and myself, as I said -- I don't i
18 believe I would be surprised if there were inconsistencies.
I 19 would be surprised if they were common.
1 20 G
Do you know o'f any otherfprecursor events.that are l
l l
l 21 relevant to the accident at TMI?
i 22 A
Yes. LThe Davis-Besselincident, I think, is probably 1
23 the most analogous to the TMI event, the Davis-Besse that was 24 the subject of a board notification, I think, in April, or maybe Ace Federal Reporters, Inc.
25 it was earlier.
pv5 t
I 65*
1 G
Is that the incident that occurred in September of 2
1977?
3 A
I think it was.
It was where the operator recognized 4
the PSOV was open and closed it rather expeditiously.
There 5
were some similar problems that occurred.
As one looks at it 6
now, with the knowledge of TMI-2, there are significant simi-i 7
larities to that action..
8 4
Did you have any knowledge of that particular event 9
prior to the accident at TMI?
I 10 A
I saw the board notification, and I saw I&E's evalua-11 tion, which I read in passing.
These are distributed for 12 information purposes.
I think I routed it to Carl Stahle, t
13 because of some gross similarities at that time that I thought f
i 14 had some impact with Pebble Springs, just for his information.
I i
15 0 But I didn't do anything more with it.
16 G
Was this1before or after;thelaccidentiatiTMI?
17 A
Before.
i 18 G
Thd boardinotifications.that you're referring to?
19 A
Was before the accident.
20 0
This is a board notification of the accident?
?
21 A
To all the boards, to sitting boards, all of the 22 boards.
23 4
k of(the" accidentTtha t' occurred EatJDavi's-Besse?
24 A
Yes.
- Am FWeral Reportus, x.
25 G
Do you have a[copyl.of that board notification in your
s--
p 66:
1 1
-files?
i 2
A No.
But it is readily available.
I don't have it in '
3 my file. IMr.iVassallo ;has11t;iniiiis.7f' le', the board notifica-i 4
tion file.
l l
S I G
Could you possibly get us a copy of that and provide
{
6 it to us?
l 7
A Sure.
8 0
Thank you.
Do you have any additional information i
9 that might be relevant to our inquiry into the events surround-l 10 ing the accident at TMI?
1 11 A
No.
I have none.
Nothing further to add.
If you j
l 12 have any other questions, I will be glad to answer them.
l l
13 MR. HEBDON:
Let's go off the record for a moment.
14 (Discussion off the record.)
l 15 MR. HEBDON:
Let's go back on the record.
I 1
16 That is all the questions we have for right now.
l 17 We would like to reconvene this interview tomorrow, i
18 August 16, at 10:45, at this same location.
Is that agreeable 19 to you?
l 20 THE WITNESS:
Yes.
Do you have any idea how long it s'
l 21 might~be?
l 22 MR. HEBDON:
I would guess a half an hour to 45 l
23 minutes.
It should be by n'oon.
l 24 MR. FOLSOM:
Now, the witness understands that he i Am Federet Reporters, Inc.
l 25 remains under oath and that all the warnings and preconditions i
4
. pv'y 67
,e 1
to this meeting are still applicab.1e to tomorrow's meeting.
2 THE WITNESS:
I understand that.
3 MR. HEBDON:
Thank you.
4 (Whereupon, at 12:45 p.m.,
the interview was 5
adjourned, to.-reconvene at 10:45'a.m., on Thursday, August 16, cnd#8 6
1979.)
7 8
9 10 i
11 12 t
13 14 15 16 17 18 19 20
/*
21 22
?lt 24 Aes Federal Reporters, Inc.
2' i
I
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