ML19327A595

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Response to Licensee Interrogatory 8-1.B&W Small Break LOCA Analysis Reinforces Ucs Contention That Analysis Performed to Show Adequate Protection for Entire Spectrum,Is Insufficient.W/Trowbridge 800122 Ltr & Transcript Excerpts
ML19327A595
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 04/28/1980
From: Weiss E
SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:
METROPOLITAN EDISON CO.
Shared Package
ML19327A583 List:
References
ISSUANCES-SP, NUDOCS 8008060442
Download: ML19327A595 (36)
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Text

. -. .- -_ . - _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _

a.  ;*** .

.e e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'. -)

In the Matter of- )

)

METROPOLITAN EDISON COMPANY, )

et al., ) Docket No. 50-289

) (Restart) .

(Three Mile Island Nuclear )

Station, Unit No. 1) )

) .

/

UNION OF CONCERNED SCIENTISTS ANSWER TO LICENSEE'S INTERROGATORY NO. 8-1 Question Copies of Babcock & Wilcox ("B&W") documents concerning small break analyses will be supplied to UCS counsel under 1

( separate cover. Does UCS contend in the light of the informa-tion contained in such documents that sufficient analyses have not now been done to show that there is adequate protection for the entire spectrum of small break locations? If so, l explain the inadequacies which UCS contends exist in the analy- ,

l ses performed to date and describe in detail the further analy-ses which UCS contends should be performed.

Answer E

, UCS has reviewed the documents provided us by the licensee on B&W small break LOCA analysis. A copy of the letter forward- _.

ing the document is attached. We will refer to each by one l l

number assigned to it in that letter. This material reinforces l our contention that insufficient analysis has been done to show i l

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that there is adequate protection for the entire spectrum of

( small break locations. It should first be noted that several l

of the documents contain no information relevant to this question. Instead they can be characterized as conclusory, j promises to do analyses and, in one case, nbtificati'on of the existence of a proprietary report which UCS was not

. forwarded and thus, could not review. Those with no useful .

information are #4 (for.which the attachments are missing and which states conclusions and promises), ,#5 (which references i

but does not include a proprietary report), #6, #7 (which states conclusion based on an " attached document" which is neither r

i attached nor identified), #12, #15, #18. To the extent that l

these documents were intended to be included within the scope of the interrogatory, we have found them to contain no useful

(_'. information and, therefore, they have not formed any portion of the bases for this answer.

UCS has noted the following general deficiencies in the analyses :

1. The analyses are inconsistent with the require-ments of NRC regulations because the assumptions with regard to the availability of equipment do not distinguish between safety and non-safety equip-ment. For example, many of the analyses rely on t

the operation of systems and components not l

classified as safety grade to mitigate the acci-(

i dents.and transients considered. These include

o -

{ reactor coolant pumps, pressurizer heaters, auxiliary feedwater, pressurizer power- ,

operated-relief valve, PORV block valve, pressurizer level ihstrumentation.

Because this equipment is not classified as safety-related .

and thus not subject to the strict requirements for safety-grade ss N

equipment [see Stan'dard Review Plan, Table 7-1, column labelled -

" Applicability (S AR Section ) 7.3"] In evaluating the adequacy of protection against LOCA's, the applicant is not permitted to rely on the availability of non-safety equipment. The Standard Review Plan specifically requires that each of the non-qualified and non-safety-grade components and systems is assumed to fail to function if failure adversely affects core cooling

('

N. capability and is assumed to function if functioning adversely affects core cooling capability (SRP, Appendix A, S7.3) 2 .- The analyses are also defective in that they rely upon operator action to initiate or control a protective function despite the clear requirements'of IEEE Standard 279 and GDC 20 that protection system functions shall be initiated automatically, e For example, in various accident sequences, operator action is required to " bump" the reactor coolant pymps, to align the suction of the low-pressure inje.ction pumps to either the borated water storage tank or the containment sump, to balance high

. pressure injection flow between injection lines, to isolate a leaking steam generator, to close the PORV or associated block

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valve, to maintain adequate suction head for the low-pressure injection pumps. Such extensive reliance on the operator is-  :

unwise, particularly because there has been no analysis of the competing demands on his time and attention during an

~

accident.

3. Even where the analyses rely on safety-grade systems and components, they do not take account -

of the actual experience at TMI-2. Safety systems such as~ decay heat removal have an acceptable leak rate and provisions for radia- __

tion shielding that are based upon the assump-tion that no significant fuel failures will occur.. If significant fuel failures do occur, as they did at TMI-2, the safety systems can be rendered unusable because the high radio-active contamination will exceed the design bases. That is, the contamination from leaks in the decay heat removal system to the auxi-liary building may be so high as to preclude the use of that system.

The interrogatory goes on to ask UCS to describe the further analyses which we contend should be performed. As a general matter, there is nothing in the analyses which could not have been done before the accident occurred. As noted above, our basic criti- -.

cisms are with various assumptions used in the analyses. We believe that loss-of-coolant accidents should be analyzed over

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a spectrum of aizes and locations under the following conditions:

(-

1. Equipment which dr.es not meet NRC regulations for structures, systems, and components important to safety should be assumed to fail or to function depending upon which assumption yields the most adverse results on core cooling capability. .
2. No operation action is credited. Or, in the alternative (which we do not believe is acceptable), at least the analyses should consider the effects of operator errors of commission and omission, such as failure to initiate transfer of LPI suction from the borated water storage tank to the contain-ment sump or too early a' transfer, when adequate positive suction head is unavaila-ble.
3. Demonstrate that the leak rate from all systems outside containment and the radia-tion shielding for those systems is acceptable assuming fuel failing in excess of 10 CFR 50.46.

, Respectfully. submitted:

t^ES h : 7.~ ( . l(.b:e.. ,,4 Q 3 Ellyn R. Neiss -!

SHELDON, HARMON & WEISS 1725 I Street, N.W., Suite 506 Washington, D.C. 20006 (202) 833-9070 I l

-( DATED: April 28, 1980 l

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M anuary 22, 1980 HAND DELIVERED Ellyn R. Weiss, Esquire Sheldon, Harmon & Weiss suite 506 1725 Eye Street, N.W.

Washington, D.C. 20006

Dear Ellyn:

In Interrogatory 8-1 of Licensee's Interrogatories to UCS, dated January 18, 1980, I indicated that copies of certain B&W documents concerning small break analyses would be supplied to UCS counsel under separate cover. I enclose with this letter the following items:

1. Volumes I and II of B&W'" Evaluation of Transient Behavior and Small Reactor Coolant System Breaks in the 177 Fuel Assembly' Plant," dated May 7, 1979.
2. Letter Taylor to Mattson, dated April 17, 1979 (with attachments).
3. Letter Taylor to Mattson, dated April 25, 1979 -

(with attachment) .

4. Memorandum Roy.to Mattson, dated April 26, 1979.
5. Letter Taylor to Hanauer, dated May 3, 197,9. _.

l i

! 6. Letter Taylor to Ross', dated May 4, 1979.

i

! 7. Letter Taylor to Mattson, dated May 7, 1979.

A

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SHAW, PITTMAN, POTTS & TROWBRIDGE Ellyn R. Weiss, Esquire January 22, 1980 Page Two

8. Letter Taylor to Novak, dated May 10, 1979.
9. Letter Taylor 'to Rosztoczy, dated May 16, 1979 (with attachment).

~10. Letter Taylor to Mattson, dated May 18, 1979 (with attachment) .

11. Letter Taylor to Mattson, dated May 24, 1979

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(with attachment).- .

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12. Letter Taylor to Mattson, dated June 8, 1979.
13. Letter Taylor to Mattson, dated June 13, 1979 (with attachmant).
14. Letter Taylor to Novak, dated June 14, 1979.
15. Letter Taylor to Tedesco, dated June 15, 1979.
16. Letter Geissler to Case, dated July 20, 1979.

/

\ 17. Letter Taylor to Ross, dated August 30, 1979 (with attachments).

18. Letter Taylor to Denise, dated October 9, 1979.

. , 19. Letter Taylor to Eisenhut, dated November 2, 1979 (with attachments) .

20. Letter Taylor to Eisenhut, dated November.9, 1979. ,

(with attachments). '.

21. Letter Taylor to Eisenhut, dated November 20, 1979.
22. Letter Taylor to Denise, dated. December 10, 1979 (with attachment). ~

f Sincerelv,

~

Georg F. Trowbridge Enclosures

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MR. TROWBRIDGE: I reali'ze the Board has per- ,

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mitted discovery on this general issue in advance of de- )l! .,

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ciding whether or not it's going to consider the issue. ..:

I don't mind answering the l*

4 WITNESS KEATEN:

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7 WITNESS KEATEN: Again, you're asking for my f-l l ,e

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! .' I a personal opinion, and my personal opinion is that in fact q!! '

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9 the hydrogen situation that existed, resulting from the  ! .

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. to TMI-2 accident, was successfully controlled. y '

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Does B&W have any opinion on that? j ,l 12 Q . U 13 A (Witness Karrasch) No. i j

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, 14 A (Witness Jones) l

.' 4 It's outside o'ur scope.

15 hydrogen control aspects. '

16 O Interrogatory 114, beginning at 114 on environ- .-

4 ,

17 mental qualification. - 1; .

. t 18 Well, let's go to 116. I don't think we have any 19 questions before then. 1-20 You state that the length of time for which each t

21 component is qualified is unchanged from that described in .

I Does that mean that the length of time for which i 4 22 the FSAR.

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1 each piece of equipment is required to be operable is the ',

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2 same as before the accident?

!A It means that we have not jyi 3 A (Witness Keaten) . '

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N 6 Q Do you intend to change the qualification require- .

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y A 9 Q In an earlier answer you state that you're in n g i N l' $

k' 10 the process of ccmpiling the list of structures, systems 1

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t)t 11 and components within the containment and auxiliary buildings '

$3 which are important to safety and you'll furnish us that g 12

.i 2 13 list when it's completed. Is the list completed yet? .i 14 A No, it's not.  ;

h. 15 Is.it true then that you don't know at the moment .

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17 A That is true in the sense that we do not have 'i.i j.

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21 But, for example, in the Unit 2 FSAR this infor- ]!I1

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i I same was not true in the 1 FSARj which is the reason we f x

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. 3 Q So you are still in the process of assembling

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-.1 1 5 A Right. I' 6 Q. And you don't know the extent to which the  !

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7 qualification parameters were exceeded for any of that y

8 equipment yet? 1 9 A That is correct. And I guess I have to take some 3 10 issue with the word "yet" in that we do not have a 100 -

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$+ 11 percent characterization of exactly what were the parameters i

j 12 following the accident. And at the. present time we don't ,j i 3: < {'

13 know how accurately we will ever be able to make that com' J l ~

14 parison.

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15 Q- Is there any particular analysis that you're [i e i g 16 undertaking in order to enable you to answer that question 5_ t 17 better? il li Il 18 A No. No, it's more of a data compilation task, !n y

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but it's a good-sized data compilation task and so it is not '

!i' 20 something that we can do overnight. j!. ,

I l' l 21 Q If the environmental conditions during the  ![ , j I

22 accident did exceed the maximum conditions for which any of [

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1 the equipment was qualified, do you intend to requalify that r:_

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equipment?

2 Is that part of your program?

3 A Not necessarily.

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Q Under what conditions will you requalify?

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5 A We have not defined that.

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p 6 Q When will you. define that? .

,$t 7 A I would assume that we would some time following y 8 the point in time at which we have the data to make the comparison, but we are not taking the position that just

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2 4.1 10 because environmental qualifications may have been exceeded

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11 in some degree during the TMI-2 accident that that necessi-g.-

l 12 tates a change in the qualification of the TMI-l components.

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'", 13 0 Will the decision depend on the extent to which

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14 the parameters were exceeded, essentially?

c 15 A I don't know. '-

16 Q What other variables might be involved?

17 A The relative importance of the particular com-18 ponent, the conse.quences of having it exposed to environ-19 mental conditions which exceeded its qualifications are 20 two possible examples.

21 BY MR. POLLARD:

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22 Q Might it also be a factor that you think that you  ;

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, therefore, you might argue that those conditions would not

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A That would be a possibility. _

I have to answer 1

p%:J f. 5 all of these with "maybe" because we have not defined the M

?? 6 criteria, and I would expect that any decisions would be se

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7 made on a case-by-case basis.

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}l,yf 8 BY MS. WEISS:

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Q Do you expect this analysis to be completed before

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vW 10 the plant goes into operation? '1 mw  :,

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11 A We have not made that a requirement for restart. -

12 as BY MR. POLLARD: .

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Q Perhaps we already asked this: i

- 1 j(a 14 Did the pressurized heaters themselves, were 9s j jf '

15 they qualified to operate in an accident environment?

.i It 16 3] A To the best of my knowledge, no. h w!a' $

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.w Q Did the nuclear instrumentation source range .; l ns  !'

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'h detectors, did they have to be qualified to operate in an i 31 4' 19 i

.;l accident environment? 1 H

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  • 20 A I'll let B&W answer that.

g 21 A (Witness Karrasch) To the best of my knowledge. -

l N; 22 i the answer to that is also No, J. i l

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Tg. 1 Q Are you now relying upon-- Excuse me. Let me 2 rephrase the question.

3 Any time after the accident began, have you found 4

need for information from '.the source range detectors?

5 A - (Witness Keaten)

- 6.

I am not aware of any time in 6

which it was mandatory that we have the information from

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7 those detectors. ,

8 t i Q Are you now relying upon the source range de-

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tectors to detect the' return to criticality in Unit 2?

3 10 A We are certainly monitoring the source range 11  :

detectors but as backed up by the intermediate range de-i

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13 Q  !

How many intiermediate range detectors are now

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15 A Oh, I don' t know. l-i-

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.c .} 17 A I don't know that either. fI i 18  !)! ,

, O Is one of the reasons to argue for venting of the  !

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19 4 Unit 2 containment or access to the Unit 2 containment for Y{

20 t i l the purpose of repairing source range detectors?

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1 t 21 A I can only answer that I have not heard that

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I 22  !' I advanced as an argument, but I have not been intimately  ; [

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F 1 involved in the discussions of the reasons for venting.  ;

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2 A (Witness Wallace) If I may add, there have been ,

I 35 EQu 3 discussions of doing maintenance on equipment inside the ,.

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r]"ugg 4 containment building that has failed as part of the basis  !.

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,:.p .V 6 Q Could you identify what equipment you want to i

.;g hh 7 maintain?

A I 8

A I cannot identify specific equipment. ,

9 'A' (Witness Keaten) No.

WE F m> r 10 Q The power operated relief valve and the block '

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11 valve of the power operated relief valve; did those have

.t J 12 to be environmentally qualified? i

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jg 13 A (Witness Karrasch) To the best of my knowledge 14 they were not environmentally qualified.

h5 w I~ff 15 Q We don't know what equipment has to be maintained 3..,.

lf.gf 16 in TMI-2 but you are assuming that that's part of the dis-t-

ij 17 cussion as to the reason you want to get into the contain-  ;

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1 A (Witness Keaten) I think there is a desire to {

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'y d 20 do maintenance on some equipment. I am not sure that that I

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21 is cast in the terms that it is absolutely necessary to do  !

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J[ 22 that maintencnce. I just don't know.  !

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_ p i 0 If there were some equipment where it was abso-

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2 lutely necessary to do maintenance to assure the continued  : .

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.W' Q 3 safety of Unit 2, do you have any plans to requalify such Q a.,

. 4 equipment so that it could remain operable in accident

.w L's N 5 environments for periods of a year? g

...,I A We do not have any present plans to do that, no.

6 N 7 BY MS. WEISS:

f 8 Q Interrogatory 120 asks for the criteria which you 9 used to judge environmental qualification of safety-related ,

to equipment, and I'm not sure whether you understood that t e

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J' 11 because you didn't provide us with an answer. h[

g s . y 12 We're looking for what IEEE standards or Reg. t frf 13 Guides or regulations you used as the criteria"for environ-o '

h Ms, 14 mental qualification. h j

'f2 15 (Pause.)

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l M 16 A Does Gilbert understand that question and know . ,

17 the answer to it?

$ja i 18 Q Is there any problem in understanding the ques-

{e i h 19 tion?

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$ 20 MR. POLLARD: Let me try it. ,-

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'j 21 BY MR. POLLARD: l-

) 22 We asked you what criteria, and in your answer f.

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115 says the parameters to p i 1 you referred us back to 115. l-I 2 which we qualified are listed in the FSAR.

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w, 3 The question is directed to what criteria did ,

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4 you use to select those parameters, not only the particular .

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.; 5 parameters but the value of the parameters.

, 6 A ,(Witness Willems) In the FSAR we have done an ,

'4 J t3 accident analysis which provid'es the temperature inside the 7

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  • 8 reactor building. That's where the value is. . t
l 9 Q Well, do you have some criterion, for example, .

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En that said if you calculated some peak enviionmental condi-b - 10 {a{

q M .11 tions t. hat you would add to that some margin? (

12 A No margin was provided as far as the qualifica-3 s

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tion itself. .However, I understand that their margin was f^

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14 in the calculations.

P k So what you're saying is you believe the calcu-p r 15 Q a p '

$ 16 lations of the accident environment themselves are in the q.7 tj p 17 FSAR?

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y 18 A They're in the FSAR also.

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% 19 BY MS. WEISS:

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sj 20 Q Well, I take that answer to mean that you did'not

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.-7 21 use IEEE 323, 1971, as the criterion. l

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y" 1 22 A The concept of the margin in existence in 1971.

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BY MR. POLLARD:

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.w Did you use IEEE 323 1971 as the design criteria - '

)p 3 5 when you were developing environmental qualification para-4 4

meters?

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% A Some equipment was bought prior to 1971 and a'A. - 6

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specified before 1971.

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{. BY MS. WEISS:

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r.g 8 Q So you didn't comply with the 1971 version?

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8 A Not completely, m

to h:y. Q All right.

W 11 Q Who answered 122 -- Gilbert.

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g. j 12 r You say that the significant criteria in the '74 3 13 6 version of IEEE 323 -- 1974, which is not included in the 14

, h s '71 version of that same standard involves-- ,No, strike 15 that. You don't say that.

16 You say that the;significant requirement of IEEE 17 323, 1974, not addressed by the. TMI-1 qualification ..

18 program, involves aging. Is that correct?

18 A

(Witness Karrasch) It's my understanding that that -

20  !

is the primary difference between the two standards..  !

21 l A (Witness Keaten) This is in respect to the -

22 i reactor production system. i

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!4 s MS. WEISS: It's getting a little confusing with j .

all the people jumping in. .  ;'il 2 -

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81 3 3 BY MS. WEISS: jj s

4 Q By the two standards you mean the 1974 standard l

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-Il 5 as contrasted with the 1971 standard?

F 6 A (Witness Karrasch) I think so, yes. {

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'd But the TMI-l qualification program did not, s.n 7 Q 1 ,

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' s all respects, conform with the 1971 standard, did it? I j

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9 think that's what Mr. Willem just said.

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3 I think the important to A I think that's correct.

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-t 5 11 point is rhat the qualification standard used for TMI-l is  :

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{ 12 basically that outlined in IEEE 279, 1968. Section 4.4 i i

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f 13 describes the requirements for equipment qualification for  ; ;. ,

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14 protection systems. IEEE 279, 1968-- The FSAR describes ."

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t 15 how the safety systems comply with that requirement for li h 3 l i!

16 environmental qualification. a

.e' il 1 17 Q Okay. q N

> 18 And what you're saying now is that the significant 19 requirement of the '74 version of IEEE 323, which is not 20 addressed by IEEE 279, 1968, is aging?

21 A (Witness Wallace) Excuse me. If I ua.derstood .

I 22 what you did you mixed standards between 279 and 323. [. .

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{, 3 Q That's right, because that's what Mr. Karrasch i

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, 2 just told me was the qualification. {  :

.I A Well, I think the original answer -- and maybe I h' Q t-2 n

li a

y 4 shouldn't say what your original answer was, but I thought lh Q you were addressing the differences in 323 between the '71 3 5 -

li 4, p 4 6 and '74 version when you made your comment about aging, --  ;

Yd b* 7 A (Witness Karrasch) That's correct.

A (Witness Wallace) -- not the difference between 4l 8

.j 9 323 and 279. '

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2

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to Q Well, then, is there any way in which you would . [.

i 5 h

@- 11 want to change the following sentence in your answer? i t..

.s 1 f? I-3 12 Your answer is:

a- ' i, "3 '

13 "The significant requirement of IEEE i 2.t.

E

$ 14 323, 1974, not addressed by the TMI-l qualifica-y tion program involves aging of the equipment being g 15 I-

-.g J 16 qualified."

3 li.

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17 That is not the same as saying the significant i) kc 18 requirement of IEEE 323, '74, not addressed by IEEE 323, ,

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% '71.

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  • You just told me the TMI qualifica- l!

p 20 All right. i:

.s 21 tion program did not conform with the IEEE 323, 1971. You

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J 22 told me it conformed with IEEE 279, 1968.

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1 Isn't that what you just told me?  ;

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d'L. ' ' 2 A (Witness Karrasch) Yes.

7Mei )

M?S i .

i E-Ty 3 3 Q And is it your view that the only significant l

'.YW;F I yfSi 4 requirement of the '74 version of IEEE 323 not. addressed by ,

M ci 5 IEEE.279, 1968, is aging?

4&O 7:ff{2 3; j p

6 I'm waiting for Mr. Karrasch to answer.

[ T 7 A I'm reading the response.

E" 51i "

8 Q Okay.

9 (Pausc.)

3 e

ffh.qz to A Okay. Would you please repeat your question, or

h ,

\

jyp 11 would you read it back, one or the other? i d.n jhldl 12 O You told me that the TMI qualification program l 3E5d .

Jt58 13 was that described in IEEE 279, 1968.

  • -- Are you saying that  ;

,'! I

'kSV igf;j 14 the only significant difference between IEEE 279, 1968, and I f 15 IEEE 323, 1974, is aging?

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jf[j 16 A I'm telling you that the significant requirement Mj

$[aj 17 of IEEE 323, '74, not addressed by the TMI-1 quali'fication e sii

. 18 program involves aging on one point.

at

^

19 On the other point I'm telling you the TMI-1

%j 20 qualification program met the requirements of IEEE 279, 21 ki? 1968.

-' ! 1 22

.! Those are the only two f acts that I've put on the

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1 record, or the only two facts that I want to put on the

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'j[ 3 Q Do you mean that all other ways in which your y

e- '74, are in-it 4 qualification program doesn't meet IEEE 323,

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5 significant?

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a.

i 6 A I have to,go to the words in the interrogatory l

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and answer with respect to the interest of the public safety.

gc j 7 qh.I I think that's what the response to the interrogatory b,. . 8 Yes, g .n x=:

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9 Says. ,

I@: : , 10 Q Well, I'm not asking what the response to the

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11 interrogatory says.

12 IEEE 323, '74, has a detailed section dealing

[]

7 13 with the margin between the most severe specified service e

f 14 conditions in the plant and the conditions to be used in

't -

n E x. 15 type testing.

16 Are you familiar with that?

Y.

17 A I'm familiar only to the extent that the words 3.

[ 18 apply. I am not familiar with the detailed design require-19 ments as they apply to the equipment being qualified.

20 Q It's Section 6315, ar.d I hand it to you so you 21 can read through it.

22 (Document handed to Witness Karrasch.)

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J While you're reading through that, h

j D- .,, 1 MS. WEISS:

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$j I notice that Mr. Karrasch is answering these questions 1-2

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while it is indicated that Gilbert provided the answers to h [ ,'

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the interrogatories. h,.

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5 BY MS. WEISS: .

L 6 Q Gilbert did provide the answers to these interro-  ;

7 gatories? hq i

! i A (Witness Keaten) Let me qualify that.  : i 8 ' i j GPU received answers both from B&W and from jf[

9 I l! !

Gilbert, and pulled together a total answer. And the parti- pj 10 ,4

[ ;N lf 11 cular portion that you are asking questions on came from >

3l ki 12 B&W.

I 13 Q Okay.

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14 If you will just tell me when yoh are finished

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.; 15 reading thrcugh that? V i; Okay. l ,i (Witness Karrasch) 16 A '

l i J 4- I Did your original environmental cualification

'l 17 Q ii.

, 18 program meet'those detailed requirements? f' 1"'

i.

j i 19 A Not to my knowledge.  ;

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s 20 0 Do you consider them to be insignificant? g, ,

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a, They provide specific requirements for increasing 4

21 A ,  !

22 the margin of environmental testing. When the environmental ,

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-t;h testing was done for the TMI-l equipment per the. require-

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  1. 3 2 ments of the 1968 version of IEEE 27,1 -- '

.. i A (Witness Keaten) 279, 1968.

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4 A (Witness Karrasch)--279, 196 8, the margin was l Sh

$D 5 also included. The calculations of temperature following a  ;

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loss of coolant accident or following a steam line break f-f:j

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E%E 7 accident were conservative. .

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reactor to trip following a stern line break had margin W.*

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'%$ 9 added to it, or a conservative value.

w W So we applied margin in a different way in quali-jf to w-

? 11 fying the equipment and in a different way which was not

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specified or called out in the regulations.

EA <'l 12 su r.

x.- .The only difference I see between the way it was j.. 13 c

P 14 done at TMI and what the IEEE 323 states is that it speci-

& It prescribes a way to do it. When we designed 15 fies margin.

j .

c-16 the TMI-1 equipment that prescription was not available.

"h

17 O Mr. Willems, did you tell me that the concept 18 of margin in the sense that it's used in the .1974 version 19 of the IEEE 323 standard was unknown in 1971?

20 A (Witness Willems) It was unknown in the area 21 of qualification purpose. However, it was known within the 22 analysis and calculations.

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1 r i E g2 1 BY MR. POIJ ARD: '

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} Q The way that you did your margin requirements on

,. .3 . ,

8, 3 the original qualification of TMI-l equipment comp'arad to i

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s ;! 4 the way that IEEE 323, 1974, specifies how to calculate 7.. ** -

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l' i Q .n 5 this margin, do you consider those differences insignificant?

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  • ra 6 A (Witness Karrasch) I really can't answer that ,

$s; p 7 question. I don't know enough about the details of the A  ;.

[jj' 8 levels of temperature, pressure, radiatiion voltage fre- [i

!M l  !! I W 9 quency and time that were included in uhat original analysis.  : I h

4 to l

.gg Q So there might be a significant difference then? .,

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].V, A I just don't know.  !

12 d Q Okay.. !I m  !

7; 13 Where can we find the details of the original "j N 14 '}t 1[l.; qualification so that we could determine how you established

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g 15 margin originally? Are those in the FSAR or referenced in . ll

$ Il 16 d the FSAR? l[

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17 i.

i 1 A The FSAR and StrW Topical Report 10,003, Rev. 2 L D ' I!!

4 18 outline the qualification testing of protection system l 9

instrumentation. To answer your question we would have to i 0 f

.{ put that document or those two documenos next to this re- ,) .

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t 21

'd quirement and do a comparison. {.

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' Well, I don't want to put it next to this document.

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(l What I want to know is if I go back and read the FSAR an i jj 1 determine how h P: I f il f this B&W Topical Report, would I be able to

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you in fact did establish margin in your original qua . r.

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cation program?

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  • I think you would, yes.

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Okay. h i 6 Q  !

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BY MS. WEISS: )

7

{ g M 8 Q But you didn't make that analysis before you p y .

l l r 9 answered the interrogatory? *

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10 A That is correct. '

l h@ Would you take a look at Section 6.3.2 on test l kht 11 Q

'74 version of IEEE 323, and please read b 12 sequence of the ,

J i

7$j 13 it through and tell me wien you're finished. .\

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s. n (Witness Karrasch reviewing document.)
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14

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Okay. sj A

Yli ga 15 Did your original qualification program for TMI tf j

Mj 16 O meet those detailed requirements?

17 k,ii 18 A Not to my knowledge.

19 Q Do you consider this to be an insignificant re-26 quirement?

21 A I really don't have any basis to answer that 22 question, one way or the other, except to say that it s my

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..,derstanding that this portion of the IEEE. standard is ,  ! . gj

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, ..,, der discussion right now with respect to its validity or ,

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, ncustry with respect to meeting this requirement.

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, o So far as you know, the test sequence requirements  ; , j .

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  1. - culd be significant? ,

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, A I don't know. j [1

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s Q Would you turn to Section 8.8 on documentation.  !

l l 1

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8.8, or Sectio'n 8? l l (l

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l1 BY MR. POLLARD:  !

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m Section 8 she means.  ! l -ll, l

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i  : E Section 8. Okay, ;b i

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1 BY MS. WEISS:  ;

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'l Q And you've read tha

l v Il' A No, I haven't.

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Q Would you read through tha'? ,u i t. i }'

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' (Witness Karrasch reviewing document.)  : ,

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') Okay, I've read i-.

A

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Q Did your program comply with those requirements O! :t' f

>. 't f0: documentation? (!~ .I n '; l I. s Y

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A To the best of my knowledge, the intent 6f Section -

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1 8.2 and 8.3 have been met on the TMI-1 qualification program.  ; )

i, y 1 2 I don't know about Section 8.4 on operating experience data. il f:

3 Q When you say the " intent" has been met, I take

}! -

j 4 it that you've made some effort at documenting environmental ' -

5 qualification but you don't know whether those precise .

i 6 requirements were met?

!. ^

7 A I know that the equipment performance specifica-  !

8 tion and equipment specificat. ions were documented and are

~

9 available. I know that there are test plans, reports of to test results, test procedures, test data and accuracy, t

19 supporting data. I know that that is available on the TMI-l  !

v.-

12 equipment, just from my own personal knowledge. So that was p f y g 13 the basis for my answe.c.  ?

14 Q Are you familiar with a series of I&E circulars j J f5 and then lastly a bulletin that's gone out to all plants,  ! o Ip e v

16 beginning I guess in the early part of '78, in an effort 4l w _

17 to compile the documentation for the environmental qualifi- h

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18 cation of various kir.ds of electrical equipment? Are you  !

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19 familiar with that? ,  ; };d 20 A (Witness Wallace) Yes. -

j%

as Q Did you ?. ave any difficulty responding to those f " '35 22 ' .

y 9 3-circulars? ""

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54 G A l & +,.eL.

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  • 158

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1 A Yes.

% .-:s j

j]x 2 Q Have you yet?

  • + A Not completely.

.. r.

3 9

.h;. 4 BY MR. POLLARD:

Was the difficulty in locating the documentation, hT 5 Q

[f 6 or was the difficulty that the documentation did not have -

a Or perhaps l 7 the information which the bulletins asked for?

'm{:.

p gg 8 you can explain.

Mr The context of my answer was primarily phrased j[ 9 A

~

10 around my own information with regard to the level of effort

.9 11 required for each specific instrument. Whether or not there

'1 war specific instances of lack of information or inability

.C 2 12 i

2- 13 to locate specific information, I do not know.'  !

.a

~-

14 BY MS. WEISS:

Sut in any case, as of yet you have not completed

.2 , .

15 Q

~'

16 compiling all of that information.

17 A That's correct.

18 Q Let's go back to aging.

19 You say that your existing program for surveillance.

20 and periodic testing, maintenance and replacenent will detect Is that correct? I 21 the degradation of those components.

22 mean is that an accurate paraphrase of your answer?

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f k .;7 1 A (Witness Keaten) The answer was that the exist-

'f; 2 ing programs at TMI for surveillance, periodic testing, s,

3 maintenance and replacement detect those components that 4[x

( T 4 may degrade during their installed life due to the environ .

  • i 5 mental conditions.

g.

4 6 Q Would you agree that the environment in the if, 7 containment and auxiliary buildings can be significantly

.t

. p. .

,g 8 more severe during an accident than during normal operation?

?:

2 9 A Yes. .

O L* 10 Q Would you explain then how surveillance can be c ~

11 used to detect components that might not fail during normal i

{C

?

12 operations but might fall in the accident environment?

, 13 A The programs that are in use as mentioned in this j- 14 answer are directed toward identifying the degradation of a 75 component that occurs with time due to its aging in its 16 abnormal environment, and then are directed toward doing 17 preventative maintenance or, as the case may be, breakdown

-g 18 maintenance on the component.

19 To my knowledge, those programs are not directed 20 toward qualifying the components for an accident environ-21 ment. ,.

l 22 BY MR. POLLARD:  !

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.k ,. 1 Q I didn't quite hear your words. ,

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2 A I'm sorry.  !

ti 3 Q Did you say that the surveillance and detection ,

I programs were for the purpose of detecting degradation in 4 ,

4 J.;,

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p 5 the normal environment or the abnormal environment?

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9,. 6 A To my knowledge, they are directed toward the 1

b  !

.{ 7 normal environment. .

?

Do you think then that your surveillance and a Q  :

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9 periodic testing and Idaintenance are an adequate substituta I

.L  !

I 10 for not conforming with the aging requirements of IEEE 323, i E

J 11 1974? .

My 12 A You're again asking for my personal opinion. i

.g .

13 personal opinion is that the plant can be operated safely

.d 14 without the components being qualified to all of the require-j 15 ments of the standard that you quoted. I 1  :

i

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16 BY MS. WEISS:

.h, i But you would agree, I understood you to have s4

  • i1 17 Q 1

- 18 said, that this equipment, it's presumed, does have to

'l operate during the accident environment and that your sur-19 1

20 veillance, periodic testing and maintenance programs are ,

j 21 directed only toward normal operation. Is that correct?

22 A I believe what I said was that the' programs that i

d i

$ceSclcral$ porters, bNc.

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j 161 .

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! ii are being carried out address the performance of the compo- ,i li 1 i f!

2 nents in the normal environment and to my knowledge do not ,: :

j-3 address their operation in the accident environment. '

g i

4 BY MR. POLLARD: d I i

g l

What is your basis for saying that you believe--

i ',  :

5 Q l  !

l 6 Do you believe that your equipment w'ould operate in the , ...;

, I'm assuming J

7 accident environment, regardless of its age? q I'

?

8 now the age is less than its installed life. '

i (Witness Karrasch)

The process we go through to 9 A 3 ,g 10 qualify this equipment is one of doing a qualification test .

11 in the accident envircament to show that if a transmitter a . _

35 12 is built and designed per the normal specifications that it

!f 13 will then perform its intended function in the accident. I' r 42 Regardless of the component's age? 'f 14 Q *

~

15 A Regardless of the component's age. ,

a.

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Gg 16 BY MS. WEISS:  !

l to C

17 Q Does that mean your program does not address age? r llLM 18 A What IEEE 323 does is age the equipment to make {if ,f

'! .U0 19 sure it performs its normal function over the life of the ..,

20 equipment, and if it continues to stay within the envelope h{i

.p,jj 21 of its normal design parameters, I believe it's a fair assumption to make that it will then perform its intended ifd I@

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  • 162-163 - El .
i' 1 function in the accident environment also. it -

i i

The aging does not continually reconfirm that l

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ident environ- -

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3 will perform its intended function in the acc '

]

You really only confirm that when you do the type '

4 ment. -

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5 test itself. .,

j ,,

So whether you age the equipment per IEEE 323, t' ,,

f L 6 illance, '

1974, or whether you do the periodic testing and surve 7 r, , ,

k s no t.

i 8

which is what is being done at TMI-1, really ma e ill, 1,

9 difference with respect to a confidence level, if you w dition. O to that it will perform under the accident con '

m$

This answer that you've just niven, is that your .

t 11 Q i p't 323, 1974, says? -

interpretation of what IEEE 12

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) .

A Yes.

13 323, 1974, requires aging ,

[ Lh' You don't believe that I I !O 14 Q [

of the equipment and then subjecting it to the type test

li l14g .

15 t l l9 l.

' , +1 16 under the simulated accident environment?  !

[?

Not to my knowledge.

Again, I haven't read i* { \ .-

17 A .-

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18 carefully.

f g

Well, this is important enough that perhaps I ,

,J i 19 0 t, should find the paragraph for you.  !

20

-[  ;

21 (Document handed to Witness Karrasch.)  ! i-:

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22 The particular paragraph showing the test sequence L :.

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3

.1 1 you already read, which is Section 6.3. 2 (4) , says: "The p i

, [' h, 2 equipment shall be aged." I i .: 3 3 And then Paragraphs 5 and 6 say: (( .

p' .

4

! "After aging, they shall be subjected j!'

a it .

5 to mechanical vibration and then exposure to the

]

, 6 simulated design basis event." :l g

75 7 A But I have to clarify my response. As I mentioned ,

i. g a

8 before, aging is one area and type testing also per this y. .

9 is one area which is under a great deal of discussion in ,!

l 4 10 the industry right now. The response that I gave you was in ill9 b$4r f ll t

11 line with what my understanding of the B&W cosition is on

I
Q 12 aging and type testing.

{.

g 13 I did not mean to respond as a literal interpre- 2. ,@.

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't *sI 14 tation of.the standard. M

.u 15 Q Okay. '

{

D 16 BY MS. WEISS: "

^ '

F= .

17 Q Having read the standard, would you answer the Jfj '

18 i k.

question with respect to the standard?  : '

52' i.

19 i . Es:.

r.

A Yes. With respect to the standard, what '

M

\

20 Mr. Pollard said was correct. It's ve.m.f clear in the sec-  ; j@

21 l Ni tion on test sequence.  :;j

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22 BY MR. POLLARD: l l

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R 165-166 y

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.. b ,92 1 Q For the time being, let's forget about a future 2 revision to 323 that'doesn't exist and let's focus on thu 3 requirement as it now exists, as we asked it in the interro-4 gatory.

What portion of the original qualification 5

or what portion of your sur-6 program for the TMI equipment, 7

veillance, periodic testing and maintenance do you believe 8 compensates for failure to meet the aging requirements of IEEE 323, 1974?

9 I

to A Correct me if I'm wrong here, but my understanding 11 is that the TMI qualification program does not meet the N 12 intent of Section 6.3.2 under " Test Sequence."

13 Q Thank you.

14 A (Witness Keaten) I might add also that-- Well, I do not disagree with what 15 that is my understanding also.

16 Mr. Karrasch said.

17 I think our position is that the type of sur-the 18 veillance and maintenance that is done to make sure that components operate normally in the normal environment also 19 20 gives adequate assurance that they would respond as they 21 are required to respond in an accident situation.

22 BY MS. WEISS:

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1 Q Do you have any studies or tests thht would ,

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p 2 verify that?

l 3 A Not to my knowledge.

j i

4 j 0 What's it based on? !L !

l

5 A It's based upon my opinion, which is what you b

L 6 earlier had asked for.

I e F y 7 Q What is your opinion based on? ll

.1 9

8 A I thought Mr. Karrasch answered that question -

'f:

9 fairly clearly, that if a component is type tested to show l e5

' 10 that initially it will respond in an accident. environment [ A

t h 11 and if it is surveilled and maintained to make sure that its j , h 12 characteristics maintain within its design characteristics, l

ff g

13 '

that there is reasonable assurance that it will continue to 14 be capable of responding to an accident envi'onment.

r ,

W 15 BY MR. POLLARDr 16 Q Can we then go back to the answer to the inter- ,

17 is rogatory? Then you're saying this was a significant require- 3 18 I

' $:r w.

ment of IEEE 323, 1974, that was not addressed by the TMI-1 ,

Il ':-

h 3 19 20 qualification program. Are you now saying that you don't r,

a he think the aging requirements are a significant requirement 1 f,(

21 in assuring the operability of equipment during an accident?  :

j: , b-i l

.li ..

22 A Let me quote from the answer we gave you. E if n O.

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168 j[ 3 i ,

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" Applying the aging considerations of ' ,

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1974, in addition to the qualification test- fd

,!i 2 IEEE, i

f 3 ing that has already been performed would yield '

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4 insignificant increases in the level of confidence i l ql that the subject equipment is qualified.."

5 'd 4

6 Q Thank you. @l9

$ i

s BY MS. WEISS:

7 r  : .

  1. :I e S Q And you have no studies or analyses to indicate --  ; l iA N t s .-

9 to back that uo? ,: 4 i -

10 A Your question was, did we have studies or analy- ,k{i.

'ti , isr .

11 ses underway, and I'm not aware of any. i

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{ h 12 Q .But you had none at the time the answer was p

.i f  ; M 13 supplied?

  • i

]2 ;l 14 A I did not personally have any; that's true.  ;

q.,

f [- j

'i 15 Q And neither did B&W? +. d .x

.I i

p That's correct. +-

i 9 16 A (Witness Karrasch)

Can we take a short break? Ten minutes or so? j 17 d.i I

fc li lj I8 MR. POLLARD: Class 9 is next so we'd better. 'lly M s.

i 19 (Recess.)

O,>'- ? -

20 MS. WEISS: We'll go back on the record now. ii

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g, 21 BY MS. WEISS: -

y!!!

22 Q Would you please refer to Interrogatory 131? i1 t-' .

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1

. 1 UNITED STATES OF AMERICA HUCLEAR REGULATORY COMMISSION COMMISSIONERS: &

s . z. : ...

John F. Ahearne, Chairman ,

_ [ 6 "u. + m ,.M..,

Victor Gilinsky - ,

/ pT* . K,.: - I

~'["' O Q Richard T. Kennedy s,-' Iy

  • Joseph M. Hendrie S/ _. l%  :.

yM[2[g g [. -l Peter A. Bradford Q C f , Q'-

i .

ETE Yl2.;!.?If:=n'.

'  ; s :.

a.:.,z.. : af T,i'

) '"..~. .

, i' In the Matter of ) s' ..-

3 .

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t ij jg,i,i ? "

1

) N PETITION FOR EMERGENCY ) c 's .. 'd,e 7y# '

AND REMEDIAL ACTION )

}

'v' l

1 l

MEMORANDUM AND ORDER l l

{.CLT-80-21 }

The Union of Concerned Scienti'sts (UCS) initiated this matter j on November 4, 1977 by filing with the Commission a " Petition for i Emergency and Remedial Relief." The petition sought action in two areas: fire protection for electrical cables, and environmental l qualification of electrical components. After an extended period of review by the NRC staf f, and havin'g received numerous submissions f rom the staf f and UCS in addition to public comments, the Commissiort i 1

issued a Memorandum and Order on April 13, 1978.1/ - Although the 1

1

,:Lergency relief sought by UCo. 2/ was not granted, the Commission l

1 osiered its staff to take several actions rela ted to petitione r'::, recues t 1

l UCS filed a petition for reconsideration on May 2, 1978. By order i

g g m yg g 7-7wyy K5'iMPQn de t e rmined as a ma t t e r of dis m e t ion )

gm. .t

~

No. of pages: ion to immediately shut down all leonstruction of new plants. ,

, .:. . n .. ~ e sa K

hk%$*s ;h kes% NM bb Y $w+ $

views on all issues raised by the UCS independent of the Cocmission's April 13 decision. In addition to its overall evaluation of the petition, the staff was asked to respond to specific questions l

which reflected the Commission's view of the discrete issues

. 1 raised by the petition. Cartain items of immediate safety .

interest were reported to the Commission on July 6, the remainder i

of the staff analysis was provided to the Commission on August 31  ;

with additional clarification provided on September 19, 1978.1/

I Additional Commission questions directed to the staff on October 6, i

Dacember 5 and December 12, 1978 wera responded to in a staff  ;

msmorandum dated October 26, 1978 and in staf f papers SECY-79-112 (Februa ry 12, 1979) and SECY-79-ll2A (March 15, 1979). On March 3f ,

1979, UCS filed a Motion for Expedited Decision Making, and requested a meeting with the Commission. This motion restated the UCS arguments previously presented. On{. arch 21,UCS submitted a

~

letter concerning fire protection at nuclear plants, repeating previous UCS contentions, and making ref erence to the November 1977 UCS Petition. In response to Commission questions,.the staff submitted further information on August 24, 1979. On November 5, 1979 UCS submitted a letter again requesting Commission action.

3/ Nineteen public comments on the petition for reconsideration were received in response to the June 27 order. .The comments represented views f rom priva te citizens, public interest groups, and the nuclear industry, and ranged from strong support for the April.13 decision --

to strong support for the UCS position. The staff reviewed these comments, and reached the conclusion that no new safety information was_provided which might call into doubt the conclusions reached in our April 13 decision. As a result of the actions taken in today's order, the Commission concurs with the staf f conclusions.

_ _ . , _ _ _ _ - _ . _ _ .

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