ML19343C770
| ML19343C770 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/20/1981 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| NUDOCS 8103250208 | |
| Download: ML19343C770 (95) | |
Text
'
1505i 1
UNITED SIATES OF AZERICA 2
NUCLEAR REGULATCHY COMMISS!CN 3
x 4 In the satter oft s
5 NET 30POLITAN EDISON COMPANY Docket No. 50-299 (Bestart) 6 (Three Mile Island Unit 1) 4 7
g 8
25 North Court St set, 9
Harrisburg, Penns:ylvania 10 Friday, March 20, 1931 11 Evidentiary hearing in the above-entitled 12 matter was resumed, pursuant to adjournment, at 8:35 a.m.
13 3EFCBE:
4 14 ITAN W. SMITH, Esq., Chairman, Atomic Safety and Licensing Scard 15 DR. WALTER H. JCBDAN, Hesher 16 DH. LINDA W.
LITTLE, Hesher 17 Also present on behalf of the Board:
18 HS. CORIS EORAN, 19 Clerk to the Board 20 LAWRENCE BEENNE3, Esq.
Legal Advisor to the Beard 21 22 23 24 ALDERSCN REPCRTING COMP ANY,INC.
400 VIAGINfA AVE., S.W. W ASHINGTON. DA 20024 CO2) 556-2345
1595T) 1 APPEARANCES:
2 On behalf of the licensee, Metropolitan Edison Company 3
GEORGE F. TECWBRIDGE, Esq.
4 THOMAS A. BAXTER, Esq.
NANCY KNOWLES S
Shaw, Pittman, Potts and Trewbridge, 1800 5 Street, N.W.,
6 Washington, D. C.
7 On behalf of the Regulatory Staffs 8
J AMES TOURTELLOTTE, Esq.
JAMES 3. CUTCHIN, IV, Esq.
9 Office of Executive Legal Director, United States Nuclear Hegulatory Commission, 10 Washington, D. C.
11 On behalf of the Commonwealth of Ps.insylvanias 12 WILLIAM DORNSIFE 505 Executive House 13 Harrisburg, Pennsylvania 14 15 16 17 18 l
19 20 21 22 23 24 25 ALDERSoN REPcRTING CCMPANY,INC, 400 VIRGINIA AVE, S.W. WASHINGTCN. D.C. 20024 (202) 554 2345
A I!
CONTENTS i
CROSS 2i WITNESS DIRECT CROSS REDIRECT RECROSS BOARD O'i BOARD 3,i I
Denwood F.
Ross, Jr.
i By Mr. Baxter-resumed 15956 4l By Mr. Dornsife 15987 By Mr. Jordan 16000 g
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EXHIBITS
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i Licensee Ex. 34 15968 16040 l
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Licensee Ex. 35 15970 16040 4
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Licensee Ex. 36 15972 16040 g
16 i Licensee Ex. 37 15973 16040 l
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l Licensee Ex. 38 15973 16040 5
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i Licensee Ex. 39 15976 16040
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Licensee Ex. 40 15980 16040 20 l l
l Licensee Ex. 41 15982 16040 21 <
l Licensee: Ex. '42 15984 16040 22 :
Licensee Ex. 43 & 44 15985 16040 23 24 i
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ALDERSON REPORTING COMPANY, INC.
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15956
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(8:35 a.:.)
3 CHAIRMAN SMITH Are you ready te restine, Mr.
4 Bax te r?
5 MR. BAITER:
Yes.
6 Whereupon, 7
DENWOOD F. ROSS, JR.,
8 with witness on the stand at the tiae of recess, resumed the 9 stand and, having been previously duly sworn, was examined 10 and testified further as follows:
11 CROSS-EIAMINATION -- RESUMED 12 BI MR. BAITER:
13 Q
Dr. Hoss, is there reasonable assurance now that 14 the pressurized water reactors now operating in the United 15 States without reactor level instrumentation do not endanger 16 the health and safety of the public?
17 A
Yes.
DR. JORDAN:
I as sorry, I did not hear the 18 l
19 question.
I could not quite get it.
l 20 BY MR. BAITER:
(R e suming )
l 21 C
Is there reasonable assurance now that th e l
I 22 pressurized water reactors now operating in the United 23 Sta tes without instrumentation do not endanger the health 24 and safety of the public?
25 Dr. Ross, I would like to describe just in the l*as
ALOERSCN REPCRT;NG CCWP ANY,iNC, 400 vtRGMA AW,5.w WASMiNGTON. D.C. 20024 (202) 554 2345 l
1595 1
abstract and ask you to correct me or infors =e if you 2 disagree with what would be the normal sequence of the 3 engin eering methods 4
One would be probles identification; 5
Two would be the selection of a f unctional 6 criteria for the solution of the problem; 7
The third would be the identification of practical 8 alternative solutions which fulfil the functional criteria; 9
The fourth would be the selection of the op timal 10 alternative.
11 A
I'm sorry.
The what?
12 O
Selection of the optimal alternative.
13 Fif th would be the de tailed engineering to apply 14 that alternative; 15 Sixth would be the procurement of material, part l
l 16 of which might proceed in parallel with the detailed i
17 engine ering ;
l 18 And last, installation, including constructio'n and 19 verification testing.
20 Would you have any disagreement with that as a 21 normal sequence?
22 A
It seems reasonable.
Step five, I assume tha t the 23 detailed engineering includes suitable testing.
Suitable l
24 testing could have taken place in steps three or four or 25 five, but it was not mentioned except at th e en d.
And I do ALOERSoM REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTCN, D.C.20024 (202) 564-2345
15958 1 not think -- my interpretation of the testing that you 2 sentioned in step seven was not proof of principle testing.
3 So that has to come somewhere.
And as long as it took place 4 in three, f our or five, I do not think it matters.
5 As you have listed it, it seems like a reasonable 8 structure.
7 C
The ites I described as the identification of 8 practical alternative solutions which fulfil the functional 9 criteria, what would be the kinds of things you would expect 10 to evaluate?
11 A
What would be the that?
12 Q
What would be the kinds of things you would expect 13 to consider in that evaluation as a general matter?
Would 14 you look at things like the urgency of the solution, 15 component availability, functional interf ace with o ther 18 systeas?
17 A
What I would like to do, because there is an 18 excellent listing, is to refer to a document.
It is a 19 listing of 11 items.
And if I could, I would like to refer 20 to a document that has then listed, so it could be 21 complete.
22 I will refer to document NU3EG/CP-0016, which is a 23 seeting summary of a meeting held on October 30, 1980, at 24 the National Bureau of Standards.
The topic -- the title of 25 the report is " Meeting on Reactor Vessel liquid level d
ALDER $oN REPORTING CCMPANY. INC.
400 VIRGINIA AVE., S.W, WASHINGTON. D.C. 20024 (202) 554 2345
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Measurement."
I refer to Appendix A of that report, which 2 was written by Mr. H.1. Anderson of Cak Ridge.
3 On page A-3, Table 3 of that report, are listed 4 the follcwing 11 items.
By the way, these represent 5 criteria and each of these
' ems has a weighted number.
6 Reliability is one; 7
Two, ease of retrofit; 8
Three, in situ verification of the callibration; 9
Four, probability of accident survival; 10 Five, lifetime or long-term survival; 11 Six, accuracy; 12 Seven, additional penetrations; 13 Eight, simplicitys 14 Mine, versatility; 15 Ten, performance history; 16 And eleven, cost.
17 Those seem like a reasonable list of a ttributes of
(
18 not-necessarily a liquid level system -- some of these, like l
19 iten seven was slanted towards additional penetrations, 20 which would apply to liquid level.
But that is not a bad 21 list for other items, also.
22 Q
Could you repeat for us the last two items?
l 23 A
The last two -- the last one was cost.
Ten was l
24 performance history, and eleven was cost.
l 25 The document, by the way, has about a one-cage, a l
ALDERSoN REPCRTING COMPANY. INC.
400 VIAGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) $54-2345
15960 1
50-vord elaboration on each of these items.
2 Q
Thank you.
let's turn back to page 4 of your 3 vritten testimony, please, Dr. Ross.
4 (Pause.)
5 A
Okay.
6 C
Ton are describing on that page, as reinforcement 7 for the staff belief that level measurement capability would 8 contribute to safe operation, an event at S equoyah 1 on 9 February 11, 1981, while the plant was in cold shutdcwn 10 condition.
11 Who is the nuclear steam supply system vendor for 12 tha t plant?
13 A
W es tingh o use.
14 C
You describe that a valve that connected the 15 containment spray system to the operating RHR system 16 erroneously opened.
Is RHR operable when the plant is at 17 power?
18 A
On what?
l l
19 0
When a plant is a t power.
I 20 A
No.
21 Q
Can you confirm my understanding that while in
(
22 this ice condenser plant RHR can be diverted to containment 23 sprays as a backup to normal sprays, at TMI there are two 24 loops of containment spray that are dedicated, so that the 25 primary system could not be drawn down by inadvertent spray l
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O ALCERSoN REPORTING COMPANY,lNC, 400' VIRGINIA AVE., $1#, WASHINGTCN. 0.C. 20024 (202) 554-2345 I
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15961 1
actuation?
2 A
A little bit of your premise was incorrect, as it 3 described the containment spray at Sequoyah, becat se th e re 4 are two containment sprays, normal, then two additional 5 spray rings from BHB.
6 However, in the BHB mode, if I understand your 7 question, if T5I-1 were operating in the BHS mode, could one 8 or more valves be opened to divert water into the 9 containment spray.
If that is the sense of your question, I 10 guess I do not know the answer.
11 I as familiar with -- there are interconnections 12 in the system, because in the BHB system is also the lov 13 pressure injection system.
And in the loss of coolant mode 14 both the low pressure injection system and the containment 15 spray systems take suction f rom a common source.
16 There may or may not be crossovers from the pump 17 discharge.
If there are, I am not aware of them.
Nor is i
18 the point particularly relevant to the testimony on page 4.
19 Q
Well, we -- I as sure the Board will be a ble.to 20 decide that.-
21 You do not know, then, whether this particular 1
L 22 event could occur at THI-1 the way it did at Sequoyah 17 l
23 A
This?
Well, if -- it depends on what you mean by l
24 "particular."
There a re interconnecting valves :-ce 1e --
l 25 from any BHB system that -- whether it be what are reterred l
l l
r ALDEA$oN REPcRTING COMPANY,INC.
l 400 VIRGINIA AVE. S.W WASHINGTON, D.C. 20024 (202) 554 2345
15962 1
to as t's, you know, in a hydraulic -- in a piece of piping 2 with valves.
3 I as confident in any system one could open a 4 valve that should be closed and divert wa te r.
It may not co 5 to the containment spray.
It may go somewhere else.
I 6 would have to review the piping diagram.
I do not know 7 whether the board -- pardon me; I am not referring to the 8 three-person Board, but the diagram behind me -- has such.
9 But it may not be complete.
10 0
You state on page 4 of your testimony that it took 11 ten minutes to reestablish pressurizer level.
It is my 12 understanding that the operators lost pressurirer level in 13 this event at two minutes.
Is that your understanding?
14
'A They lost it in roughly two minutes, is that your yes, that is approximately correct, that is my 15
-16 understanding.
17 Q
In order to have reestablished pressurirer level 18 in ten minutes, the operators must have taken appropriate 19 action to restore inventory at some earlier time than that,
20 is that true?
21 A
Some of the actions they took were appropriate and 22 some were not.
They did restore level.
23 C
And to get level back in ten minutes, they had 24 taken ac:tions to restore level at an earlier times ; is that 25 correct?
It did not happen instantaneously, did it?
ALDERSoN REPcRTING CCMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
159u 1
A I an not sure wha t "i t " is that you refer to.
2 They took action.
Some of the actions they took on 3 reflection were not appropriate.
The net sum of their 4 actions restored pressurizer level.
5 C
And they took those actions within ten minutes, 6 didn't they, in order to get pressurizer level back in ten 7 minutes?
8 A
I have, of course, a sequence of events with me.
9 And some of the actions they took occurred in two or three 10 minutes.
They took a large number of actions in the first 11 ten minutes.
They did not wait for ten minutes to do 12 anything.
13 They opened valves, they closed valves, and so 14 on.
The pressurizer was back on scale ten minutes after the 15 initial -- after the initiation of the transient.
It was 16 back on scale as a result of some of the actions that took 17 place two or three minutes after the event.
18 Q
Look, for example, at the relationship between the i
19 pressurizer and the reactor vessel as it is shown on this j
20 simplified schematic of THI Unit 1.
Don't we have, from the 21 core cooling standpoint, the systes essentialfy refilled as l
22 soon as there is pressurizer level?
23 A
I am not sure I got the last -- don't we have --
I 24 Q
Isn't the system essentially refilled as soon as 25 we get pressurizer level reestablished?
l I
l ALDERSoN REPORTING COMPANY. INC, 400 VIRGIMA AVE S.W., WASHINGTCN O.C. 20024 (202) 554 2345
15661 1
A It de pend s.
For Sequoyah the system was at 175 2 degrees Fahrenheit, which would preclude -- and 300 psi, 3 which would preclude boiling in the reactor vessel head.
4 And under those circumstances, when the system depressurired 5 the reactor did "not flash or create steam.
And apparently 6 there was no way to ge t air into the system.
l There probably was a small amount of hydrogen 8 introduced deliberately for chemistry control.
And under 9 those circumstances, restoration of level I think would be a 10 highly reliab.1.e indication that the reactor system inventory 11 had been replenished, which is a long way to say res.
12 C
What do you mean, then, by the la tter part cf the 13 last sentence in the first paragraph on page 4, tha t it took 14 35 minutes to diagnose the event and take appropriate action 15 to refill the system?
16 A
When I said the pressurirer level was back on l
17 scale, I did not mean it was back to the normal operating 18 mode.
It was on scale.
It was of f scale f or ten minutes.
l 19 Getting back on scale does not mean you have refilled back l
20 up to the normal half-full level.
1 21 f)
So the 35 minutes is -- applies to the time it 22 took to get to normal pressurirer level?
f ga A
Yes, and to restore and to terminate the leak and 24-get back on the RHR, normal RHR mode.
In other words, to 25 restore cooling there were large sequences of events that ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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took place, and that was -- I consider tne transient 2 terminated then.
3 (Counsel for Licensee conferring.)
4 Q
On page 3 you are discussing the St. Lucie event, 5 which Mr. Phillips when he appeared in January also brought 6 up in his testimony.
You make reference, however, in about 7 the middle of the second paragraph on page 3 to what you 8 describe as an extended period of operator conf usion 9 concerning the status of the system.
10 Are you f amiliar with the report on the St. Lucie 11 1 natural circulation cooldown on June 11, 1960, by the 12 Office for Analysis and Evaluation of operational data, l
13 prepared by E.V.
Imbro, I-m-b-r-o?
14 A
I read the report a number. of months ago.
I do 15 not think I have a copy with me.
So I world say generally 16 res.
17 Q
Let me read from the first finding by Mr. Irbro l
l 18 and then I will hand this to you.
I am sorry, I do not have 19 extra copies of it.
Quotes 20 "Although the actual safety significance of 21 drawing a steam bubble in the reactor vessel head during the 22 natural circulation cooldown appears to be small, the plant 23 response did initially puzzle the plant operators.
This 2.
could have resultad in the plant operators taking actions 25 that were incorrect, although this was not the case in this ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
15966 1
instance.
It does indicate that operater guidance needs to 2 he developed in this area."
3 (Counsel handing document to witness.)
4 C
Do you have any information different than Mr.
5 Imbro 's tha t would lead you to describe what he terms 6
- initial pu==lement" and "an extended period if operator 7 confusion"?
8 (Witness reviewing document.)
9 A
We share the same information.
So I have nothing 10 sore than what he had.
11 C
Do you agree with Mr. Isbro's findings that the 12 operators in the St. lucie event took the correct actions?
13 (Pause.)
14 A
I as trying to see where you are ref e rring tc.
15 Q
Re said the initial pu lement could have led to 16 incorrect operator actions.
And then he proceeded to say, 17 although th at was not the case in this instance, or words to 18 that effect, which I put tocether co mean they took the i
19 correct actions.
\\
l 20 A
Ch, ch.
I understand what you mean, because my sy initial puzzlement was it was l
21 initial puzzlement 22 operator actions that caused the event in the first place.
23 Eventually they diagnosed what was going on.
Ihey did take
?
24 the correct action thereafter.
25 If -- if there is a confusion, it is between my a
s ALCERSCN REPCRTING CoWPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTCN. D.C. 20024 (2C2) 554 2346 b
15967 1
word " extended" and Mr. Imbro's word " initially."
I would 2 be glad to explain.
3 Q
Fine.
4 A
I was referring to the fact that there were v1 5 svings in pressurirer level tha t extended over a period of 8 about an hour and a half.
There were about ten cycles, 7 roughly 15-minute ci dles, where the pressurizer vent fron 8 nearly empty to nearly full.
And it is this time period 9 that I was using when I used the adjective " extended."
10 (Counsel f or Licensse conferring. )
11 Q
Dr. Ross, I overlooked one question on the 12 Sequoyah event.
Were the operators in that transient -- did 13 they get into their inadequate core cooling precedure?
Were i
14 they utilizing it?
15 A
Not to my knowledge.
I do know what precedure 16 they did go to.
They vent to the loss of coolant 17 procedure.
18 Q
Let's turn to page 7 of your written testimony.
19 In the last sentence of your answer to question number 4 yCu 20 stated tha::
"Those plant owners who have devoted their 21 resources to sa tisf ying the 2.F.2 requirement rather than to meet the schedule -a;;ircrents of 22 resisting 1*g expect 23 N U S EG -0 7 37. "
24 I would like to refer you -- I handed cut some s
25 documents to the parties this morning.
I would like to ALCERSCN REPCRTING CCMP ANY, NC.
400 VIAGINIA AV.,1.W., WASHlhGToN. D.C. 20024 @t $54 234$
15968 1
refer you to the second document.
It is entitled "Cperating 2 Reactors, 0737, 1-1-81 Responses, Status as o f 1-9-81."
Do 3 you recognize this paper as having been produced by a member 4 of members of the NRC staff?
5 A
Tes.
8 HR. BAITER:
Mr. Chairman, I ask this document be 7 marked for identification as Licensee's Exhibit 34.
8 (The docurant referred to was 9
marked Licensee Exhibit No. 34 to for identifica tion. )
11 BY 3R. BAXTER:
(Resuming) 12 C
Do I read the first page correctly, Dr. Ross, that 13 the data contained in here represents 65 plant submissions?
14 A
Yes.
15 0
And if we turn to the fourth page of the document, 18 looking down to iten II.F.2, are we told here that fer 17 inadequate core cooling instrumeatation in the submissions i
i 18 on this item, that 20 p1onts took technical exception in 19 their submission and 23 took schedule excaptions?
20 A
That is what it said, yes, sir.
21 Q
And-it is -- if we look at page 2 of the document, 22 at this point you did not have the TMI-1 responses is that 23 correct?
24 A
I did not get the question.
25 0
On page 2 of this summary, this paper, down at the s
AISERSON REPORTING COMPANY. INC,
- 1,' A 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202) 55' 2345
15969 1
botton, does it indicate that TMI-1 had not yet been filed 2 and therefore was not part of the 657 3
A Ies, that is what it said, yes, sir.
4 0
And weald you categorize TMI-1 as a technical 5 exception, now that you have the filing?
6 A
Both, I believe, technical and schedule.
Well, I 7 quess technical would be the best, although I think tha t 8 even if the technical vent away, then the schedule would 9 appear.
But I would call it technical, yes.
10 Q
One of the other plants whose submittals are nec 11 part of the 65 data base is indicated on the same page as 12 San Onofre; is that correct?
13 A
Tes, that is correct.
14 0
Is that a Westinghouse plant ?
15 A
San Onofre, I should point out, that is San-Cnofre 16 1,
and the-answer is res.
17 Q
I have also distributed -- and it should be the 18 first piece of paper on your pile -- a letter which we 19 obtained from the staff dated December 23, 1980, from the l
l 20 Southern California Edison Company t-the NHC, with an i
21 attachment page 3, which includes their response to the 22 MUREG-0737 item on Ites II.F.2.
23 ER. BAITER:
I would ask that this document be f
24 marked f or identification as Licensee's Exhibit 35, l
25 (The document referred to was l
i l
f ALDERSON REPCRTING CoWPANY. INC.
l
(
400 VIRGINIA AVE., S.W. WASHINGTON. 0.C. 20024 (202) 554-2345 L
1597v 1
marked licensee Exhibit No. 35 2
for identificatien.)
3 BY 13. 3 AITE3 (Resuming) 4 C
The San Onofre Licensee states their view, !
5 believe, that existing instrunentation is sufficient and 6 that additional instrumentation to detect inadequate core 7 cooling is not warranted.
Would you categorire that as a S technical exception?
9 A
Yes.
to O
Turning over to page 11 of your written testi=ony 11 in response to question 8, you are describing the status of 12 other operating PWR's and BCW reactors with respect to this 13 NUREG -0737 ites, II.F.2.
Did ycu personally prepare this 14 summary of the submissions made by these licencees, or was 15 it performed for you by a sesber or members of your staff ?
16 A
Are you referring to -- I forget the exhibit 17 number, but I presume it is 34, entitled " Operating tc He a ct ors. "
19 Q
No, I as referring to your answer to questien 8 cn 20 pages 11 an d 12, the summary.
21 A
No, I did not personally prepare that.
It was 22 prepared at 27 instruction.
23 C
let's concentrate for a sinute at your description 24 in the first paragraph of your answer to the ECW operating 25 licensees.
Based on the description you have given there of tot-owcN REPORTING COMPANY ;NC, 400 VtAG6NIA AVE., S.W. WASHtNGTCN, D.C. 20024 (202) 364-234$
15971 1
the positions taken by these licensees, if any of these 2 other plants were in this hearing today, in the position 3 tha t THI-1 is, and we are being judged on a standard of 4 reasonable progress toward the completion of this NU3EG-0578 5 requirement for additional instrumentation to detect 6 inadequate core coolin g, would you conclude that any of 7 these licensees, ignoring for the moment ANO-1 and THI-1, 8 have made reasonable progress?
9 A
Just to make sure, I think you are now limiting 10 the question to Oconee, Crystal R. ver, Davis-Besse and 11 3ancho Seco.
12 Q
That is correct.
13 A
It is arguable -- it is not obvious they have_made 14 reasonable progress.
I think sarbe they have made some 15 progress.
I think in order to ansder that I would probably 16 have to moet with them and see just how earnestly they were 17 proceeding.
18 It is -- I just cannot tell.
I cannot give a yes 19 or no.
i l
20 Q
Do you think there is a possibility that l
l 21 Davis-Besse and Rancho Seco, the status of which you l
22 describe as still reviewing currently available systems and 23 have made no decision, do you think there is a chance that 24 you might conclude they have made reasonable prCeress f TCu 25 had the opportunity to sit down and talk with them?
a ALDERSCN REPCRTING CCMPANY,INC, 400 VlRGINIA AVE. S.W. WASHINGTCN, D.C. 20024 (2C2) 554 2345
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A Well, th ere is a ch an ce.
I would have to find out 2 how hard they were working, how much they were supporting 3.the ingredients, for example, in your seven-step procedure, 4 were they looking at solutions ard doing earnest and sincere 5 efforts to do such things as explore alterns tre, do tests 8 and so on.
7 I cannot exclude it.
I would have to characterire i
8 sy reading of those responses -- and I have read the m a ll --
9 as sort of lukewarm.
So I do not know any better way to say l
10 it than t? at.
It C
Iou will find in the papers I distributed today a 12 letter dated January 2, 1981, from Duke Power CCapany to Yr.
13 Denton of the NRC staff.
This was provided to Licensee by 14 your counsel at our request and it contains, I believe, the 15 response to II.F.2 for the Oconee station, is that correct?
l 16 A
Ies.
17
- 63. BAXTEHs I ask that this letter be marked for 18 identification as Licensee 's Exhibit 36.
19 (The document referred to was marked Licensee Exhibit No. 36 20 for identification. )
21 l
l 22 BY 52. BAXTES:
(Resuming) 23 C
There is also contained in this material a le tte r 24 dated recember 15, 1980, from the Sacramento Municipal 25 U tility District to the NRC staff, with an excerpt including ALDERSCN REPORTING CCMPANY,INC.
400 VIRGIN!A AVE, S.W., WASHINGTCN D.C. 20024 (202) 554 2345
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that Licensee's response to NUREG-0737 Item II.F.2.3.
Is 2 this the submission ?
3 A
res.
4 MR. BAXTER:
I ask that be marked for 5 identification as Licensee 's Exhibit 37.
6 (The document referred to was 7
marked Licensee Exhibit No. 37 8
for iden tification. )
9 CHAIRMAN SMITHS Which one was that?
10 MB. BAXTER4 SMUD.
11 BT MB. BAITEHs (Resuming) 12 0
You have also been provided with a letter from 13 Toledo Edison Company dated December 30, 1980, with respect 14 to the Davis-Besse plant.
This was provided to us also by 15 your counsel and includes that Licensee's response to 16 II.F.2.3 of NUBEG-0737; is that correct?
17 A
Tes.
18 MR. BAITEH4 I ask that be marked for 19 identification as Licensee's Exhibit 38.
20 (The document referred to was 21 marked Licensee Exhibit No. 38 22 for identification.)
23 BY MB. BAXTEH4 (Hesuming) 24 0
In the next paragraph you go on to discuss the 25 Combustion Engineering operating licensees, the four ALDERSoN REPCRTING CCMP ANY. (NC.
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licensees who you sar are still reviewing the available 2 options.
Are those licensees, would they pass a reasonable 3 progress standard if they were being judged in their 4 compliance with this 0578 item?
5 A
Well, I guess I am still f ollowing the hypothesis 6 that those four, placed in the context of this proceeding 7
8 C
Te=?
9 A
Okay.
Again, it would be arguable.
The -- the 10 perception, our perception, may not be complete on hcv 11 energetically they are pursuing or reviewing optiens withcut 12 a detailed discussion or detailed reading of exactly what 13 they are doing.
I cannot make that judgment on reasonable 14 progress.
15 0
I am getting the sense, though,, am I correct, that 16 vhat it would take to show reasonable progress is not a 17 commitment to install a system, but some activity cr 18 expression of interest and effort.
Is that your --
yes, I think it would -- if utility X l
19 A
It would l
20 sent in a one-sentence letter that says:
"We hereby censit l
21 to install a liquid level systes on or before 1-1-92," I 22 would not regard that as reasonable progress.
l-l 23 C
You would not?
l 24 A
I would not.
I would like to have some evidence l
25 tha t he kne w what the system was and that he was pursuing l
l ALDERSCN REPCRTING COMPANY tNC.
8
- 1 400 VIRGINIA AVE 3.W. WASHihGTCN, D.C. 20024 (r4 554-2345
15975 1
the required -- for example, seven steps that you earlier 2 p ro po un ded.
So ! vould expect some details to go with 3 that.
4 In many instances, in connection with the 1-1-01 5 submittals, we got the amount of detail to which I refer.
6 And I think a good erample is the naterial received from 7 Fort Calhoun, which is also another Combustion plant.
That 8 is an example of what I would cr.11 reasonable procress.
9 Q
Tou indicate that three of the eight CE plants are 10 committed to a system.
Who are the three plants th a t you 11 summarize there?
12 A
I would like to refer to a table that I have.
I 13 just mentioned Fort Calhoun.
I also included St. Lucie-1 14 and Maine Tankee.
The Maine Yankee is what I would call a 15 little vague.
They do not come out and say exactly heated 16 junction thermocouple, but it was close enough.
And ther 17 have not requested a schedule exception.
18 Now those were the three plants.
I -- could I 19 continue, because I -- based on information subsequent to l
20 filing of the material on page 11, the number four should l
21 really be three, because I note in my more up-to-date 22 summary that Hillstone-2 has taken some action.
So the y a re l
1 I would not -- they still have a schedule problem, b ut 23 24 they have gone beyond reviewing available options.
And this 25 was later than the filing of the testimony.
ALDERSON REPORTING COMPANY,iNC.
400 VIRGINIA AVE. S.W, WASHINGTCN, D.C. 20C24 (202) 554 2345 L
15976 1
Q Let me refer you to -- you identified St. Lucie 2 Unit 1 as one of the plants you considered to have committed 3 to a system.
In the papers we distributed today is a letter 4 from Florida Power and Light Company dated December 23, 5
1980, to the NRC staff.
This was provided to us, again, by 8 your counsel.
And it includes their response to item 7 II.F.2; is that correct?
8 A
Yes.
9 HR. BAITEHs I would like to have tha t marked for 10 identification, please, as Licensee's Exhibit 39.
11 (The document referred to was 12 marked Licensee Exhibit No. 39 13 for identificaticn.)
i 14 BY MR. BAITEB (Besuming) 15 C
The second paragraph of the St. Lucie filing 18 says "In addition, v6 are participating in the CE owners 17 group effort in evaluating reactor water level indication as 18 a part of our evaluation of inadequa te core cooling.
A 19 detailed description of our plans for inadequate ccre 20 cooling vill be forthcoming upon completion of that effert.
21 Is that what you construed as a commitmant to a 22 system?
23 A
That paragraph alone would not -- could not be l
\\
24 regarded as commitment to a system, no.
25 0
What is the basis, then, for that part cf your ALDERSON AEPoRTING CcMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
15977 4
1 testimony?
2 A
Well, as I had stated earlier, the Fort Calhoun 3 submittal had a good description of the work of the CE 4 owners group.
My staff has b=en meeting with the CE owners 5 group relatively fre;'antly.
And their information is that 6 the St. Lucie-1 -- St. Lucie-1 plant, which is also l
7 Combustion, was going in the direction of the heated 8 junction thermocouple, for which I believe there has been 9 reasonable progress.
10 You cannot get that, however, out of a reading of 11 the document.
12 0
You said your staff has the information that St.
13 Lucie will go with heated junction thermocouples.
Have they 14 committed to such a system?
15 A
I think in the sense you mean committed, no.
That 16 is, in a piece of paper tha t I can show you.
We believe 17 that is what they are going to do.
But I do not have a 18 piece of paper to show you.
19 Q
Well, I did not set the requirement for a piece of 20 paper.
You said your staff has information beycad this 21 filing that they are heading in that direction.
Does your 22 staff have information on paper or otherwise that they are 23 committed to install that system?
24 A
I would not use the word " committed" until it is 25 on paper and it is not on paper.
We believe that is what ALDERSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE S.W WASHINGTON, D.C. 20024 (202) 554 2345
1597a 1
t.tey are going to do, and when they write it down they are 7 committed.
They have not written it down yet, though.
3 C
You identified Maine Yankee as one of the CE 4 plants included in the cossitsent?
5 A
Yes.
6 0
Earlier you described, when we were discucsing 7 what reasonable progress vould be in the abstract, that 8 someone who just wrote a sentence that said, I an qCing to 9 put something in by January 1,
1982, would not nake it.
I 10 did not reproduce the Maine Yankee letter.
I will read it 11 to you and then provide it to you, that verifies I have --
12 A
I have a copy, if you want to wait a minute.
13 C
Certainly 14 (Witness reviewing documents.)
15 A
I have a large stack.
It might be just mere 16 useful to go ahead and read yours.
17 0
It is one sentence with a semi-colon in the 18 siddles
" Maine Iankee anticipates completion of 19 modificatians to provide unambiguous indication of 20 inadequate core cooling by January 1,
1982; however, should 21 unforeceen problems arise which preclude completien of this 22 modification schedule, the NHC will be notified promptly."
23 A
And the question is?
24 0
First, have I correctly read into the record th e 25 Maine Yankee response to this NUREG-0737 iten?
Did I read ALDERSCN AEPCRT1NG CCMPANY. ANC.
400 VIRGINIA AVE, S.W. WASHINGTON, D.C. 20024 (202) 554-2345
15979 1
the sentence correctly?
2 A
Ch, yes.
Yes, I as sorry.
Yes, that is a ccrrect 3 reading.
4 C
And would you consider that to be reascuable 5 p rogress ?
6 A
In and of itself, no.
It has to be coupled with 7 our knowledge of what the Combustion owners group is doing.
8 0
The last sentence on page 11 rou amended to say, I 9 believe, that three of the CE licensees are still reviewing 10 available options.
Would that be the two Calvert Cliffs 11 units and Palisades?
12 A
I hope we did not count Calver t Cliffs twice.
13 ANO-2, Calvert Cliffs, and Palisades.
14 Maybe it would be better to correct.
Instead of 15 " plants," read'the word " licensees."
16 Q
I as sorry.
Yo u se pa ra te out ANO-2 in the last 17 part of the sentence, so I thought t
18 A
Eaybe I did.
I am sorry.
(
19 Q
I thought it was not included in the earlier t
20 number.
21 A
You're right.
let me check.
22 (Witness reviews document.)
23 A
I am sorry, your original presise was corr *ct.
l 24 Calvert Cliffs, both units, and Palisades.
I forect I was 25 counting ANO-2 separate.
i l
l ALDERSoN REPcRTING CCWP ANY. INC.
.oo== we s.w. wAs=oreN. o.c. :ecu nem su.2xs L
15989 1
C I provided you with a copy of a letter which we 2 received from your counsel fron Baltinore Gas and Electric 3 Company dated Pecember 15, 1980, providing the NUBEG-0737 4 response for the two Calvert Cliffs units, with the attached 5 excerpt response to II.F.2; is that right?
6 A
Yes.
7
- 53. BAXTES:
I request this be marked for 8 identificatica as Licensee 's Exhibit No. 30.
9
( The document referred to was 10 sarked Licensee Exhibit No. 40 11 for identification.)
12 BY HR. BAITER:
(Hesuming) 13 Q
An I correct that in this response the Calvert 14 Cliffs Licensee has said, " Combustion Engineering is 15 developing a heated junction thersoccuple device for direct 16 indication of reactor vessel level.
We do not think this 17 system is necessary, but we vill reevaluate our position 18 when the Combustion Enginee ring owners group stud y ha s been -
i i
19 completed"?
And$1s that the basis for your categoriring 20 them as still reviewing available options and not putting 21 them with ANO-2 in the position that they have responded 22 that nothing is needed?
u A
Well, you vere reading fron 40, right?
And I 24 thought you said ANO-2 and I got confused there at the end.
- '5 Q
Okay.
ALOERSoM REPCRTING COMPANY. INC.
400 VIRG3NtA AVL 3.W, WASH 6HGioN. O.C. 20024 (202) $$4-2345
f 15981 1
A By the way, that was only a partial reading, 2 although I do not know that the rest is important.
But that 3 was only a partial reading of what the Licensee said.
4 C
Fine.
Well, we will hopefully have the entire 5 submission in the record.
So I will not -- if I abbreviated 6
it, it was only to save time.
7 A
What was the question again, then?
8 0
Well, I read this -- and correct me where I have 9 misunderstood -- that Calvert Cliffs is essentially saying, 10 we do not think a system is necessary, we will reevalua te it 11 after the CE owners group effort is completed.
And if that 12 is correct, why do you characterire them in your testjmony 13 as still reviewing available options, rather than placing 14 them with ANO-2 as a description of a Licensee whc has taken l
15 the position that nothing is needed?
16 (Pause.)
17 A
I probably have to refresh my recollection on 18 ANO-2.
It zar be that the basis is that ANO-2 is'a bit more 19 dogmatic than Baltimore Gas and Electric.
However, the l
l 20 distinction between reviewing available options and the 21 position that nothing is needed may overlap'n little hit.
I 22 And it might be that I could ha ve put it in one category or i
23 the other.
24 If necessary, I could go back and reread ANC-2, l
25 which I have somewhere in this stack, and see if I c.ould l
ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON O.C. 20024 (202) 554-2345
15982 1
give you a better answer.
2 0
It is not necessary for my purposes.
If you feel 3 that you -- I have also provided you with a letter da ted 4 December 19, 1980, from Consumers Power Company on the 5 Palisades Plant, to the NHC staff.
This was provided by 6 - your counsel and includes the response to NUEEG-0737 Item 7 II.F.24 is that correct?
8 A
Yes.
9 ER. BAXTER4 I request this be marked for 10 identification as Licensee's Exhibit 41.
11 (The document referred to was 12 marked Licensee Exhibit No. 41 13 f or identifica tion. )
(
14 BY MR. BAXTEBs (Resuming) 15 0
An I correct this is a licensee you also 16 categorized as still reviewing available options?
17 A
That is correct.
18 Q
Let's turn now to page 12 of your testimony, where 19 you are addressing the Westinchoose.
First, Dr. Poss, I 20 have ma thematical probleis with this paragraph.
It says 15 21 of 27 have committed, and then you describe five other 22 plants committed with a delay in the schedule, and nine 23 others still have the selection under review.
And that adds I
\\
24 up to 29.
25 1
The number should be 29.
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON. O.C. 20024 (202) 554 2345
15983 1
Q You have not categorired any of the Westinghouse 2 licensees as taking the position that no additional 3 instrumentation is required,; is that correct?
And is that 4 accurate, that none of them have taken that position?
We 5 have already discussed the San Onofre licensee.
6 A
Tes, that is a fair reading of the first six lines 7 on page 12, that is correct.
8 Q
I have provided you with a copy of a letter from 9 the Wisconsin Public Service Corporation dated January 5, 10 1981, to the NRC staff for the Ke waunee -- K-e-w-a-u-n-e-e 11
-- plant.
This was provided by your counsel and includes 12 that Licensee's attached response to II.F.2.
13 Is Kevaunee a Westinghouse plant?
14 A'
I aa sorry.
The last question 15 Q
Is Kevaunee a Westinghouse plant?
16 A
Yes.
7 0
Is it f air to characterize their position as
~
18 stating a belief that existing instrumentation is adequate 19 to detect inadequate core cooling?
20 A
Let me take a reading.
I think that is right, but 21 just a minute.
22
-(Witness reviewing document.)
23 A
Tes, that is right.
They use the word 24 " installed."
I wanted to make sure they were not referring
\\
25 to something they had not yet installed.
But they used the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
i ddl 1
word " installed" and that is their position.
2 MR. BAITER:
I request this letter be marked for 3 identification as Licensee's Exhibit 32.
4 (The document referred to was 5
marked Licensee Exhibit No. 42 6
for identificaticn.)
7 BY NB. BAXTER:
(Hesuming) 8 0
I have provided two letters from the Ecchester Gas 9 and Electric Corporation with respect to the Ginna Nuclear to Power Plant, one dated July 2, 1980, which is provided to us 11 by your counsel, and one dated December 15, 1980, which we 12 have obtained on our own.
13 The second letter is referenced in the letter 14 provided to us by your counsel.
15 Do these two letters both respond to NUEEG-0737, 16 Item II.F.2,, either in the fors of a precise ldesntifica tion 17 of the NUREG-0737 item and the December 15 letter and in 18 response to the companion 0578 item in the July 2 letter?
19 A
Yes.
20 CHAIRMAN SMITH:
Mr. Baxter, with respect to 21 Ginna, I have a single letter dated December 15.
The cther 22 two Board members seem to have --
23 MR. BAITER:
I would request i
' ~
24 CHAIRMAN SMITHa I have bo th letters no w.
25 MR. BAITEEs I would request that the July 2 s
ALDERSoN.% CRTING CCMPANY, INC.
$b 400 VIRGIM A AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
15985 1
letter be marked for identification as Licensee's Exhibit 43 2 and the December 15 letter Licensee's Exhibit 44.
3 (The documents referred to were 4
marked Licensee Exhibits Ncs.
S 43 and 44 for identification.)
6 BY ER. BAXTER4 (Hesuming) 7 0
Dr. Ross, is Ginna a Westinchouse plant?
8 A
Yes.
9 Q
In response to question number 9 on page 12, you 10 state that:
"The staff intends to take action to expedite 11 progress on the installation of a level measurement or 12 equivalent system."
13 And I take it from the quustion you are referrino 14 to plants that seem to be late and prepared a deviation to 15 the requirements.
Has the staff taken any enforcement 16 action with respect to any PWB in response to their 17 NUBEG-0737 submissions?
18 A
Are you restricting it just to the II.F.2 items?
19 C
Yes.
20 A
No.
21 (Pause.)
22 0
Have you had the opportunity, Dr. Ross, to review 23 the testimony which Licensee 's witnesses Jones and Kea ten i
l 24 presented in this hearing on the same issue en which you are l
25 testifying today, reactor vessel water level?
And in l
ALDERSON REPORTING CCMPANY,INC.
400 VIRGINtA AVE, S.W WASHINGTON. O.C. 20024 (202) 554-2345
15986 1
particular, I mean their oral testinony here at the hearing 2 in response to examination, rather than just their prefiled 3 testimony.
t 4
A I read their testimony as the transcript crossed 5 ay desk and I no longer remember the date.
6 Q
I would like to read to you just briefly, and we 7 will provide you with a copy of the testimony.
On page 8
10,919, Chairman Smith --
9 A
I see what you are referring ts, yes, sir.
l 10 5H. BAITERS I aa waiting for the Board to get 11 theirs.
12 THE WITNESS:
I's sorry.
13 (Pause.)
14 NB. BAITER:
It is January 22.
i 15 CHAIBHAN SEITHs It is missing.
l 16 (Pause.)
i 17 BI MR. BAITER:
(Hesuming) 1 18 Q
Chairman Smith asked if the panel would be able to 19 tell us whether the licensee continues to evaluate the 20 problem, the problem being inadequate core cooling and any 21 additional instrumentation.
Had you reviewed this answer by 22 Er. Keaten before you prepared your written testimeny?
23 A
Did I do whac with Mr. Keate7?
l 24 Q
Had you read this testimony by Mr. Keaten prior tc l
25 the preparation of your written testimony ?
l l
ALCERSoN REPCRTING COMPANY. :NC, 400 VIRGINIA AVE, S.W, WASNINGTCN, D.C. 20024 (202) 554 2345 i
\\
~
t 1598L7 1
A Yes, I had.
2 C
So that you do not consider the interest and/or 3 effort expressed in this testinony to be reasonable 4 progress?
5 A
I really do not know what the BC'4 Owners Group is 6 doing, if anything.
7
- 53. BAITEHs I have no further questions.
8 CHAIREAN SMITH Mr. Cornsif e ?
9 BY MR. DORNSIFE to C
Tour oral testinony resterdar, tr. Ross, you 11 talked about programs which are -- the possibility of being 12 developed which would use core exit thermocouple data to 13 show trending information and therefore predict or infer 14 reactor vessel levels is that correct?
Did I characteri=e 15 that correctly?
16 A
Sort of.
I said th a t when the water level had 17 dropped to the -- below the top of the active fuel, by l
18 making some inferences of a thermal hydraulic nature and l
19 with respect to the radial variation in dryout, you could 20 infer water level below the top of active fuel.
21 Q
This type of device or progras _ vould only be j
22 useful once the core begins to uncover; is that correct?
It 23 could not infer a level above the core to the top of th e 24 vessel?
25 A
It could not.
s ALDEA$oN REPORTING COMPANY,INC, 400 VIRGINIA AVL S.W., WASHINGTON, OA 20024 (202) 554 2345
15988 1
0 On page 8 of your testimony at the top, the first 2 full sentence, you talk about CE claimin.g that their system 3 is adaptable to every operating FW3 without requiring 4 additional penetrations.
Is this only true for those as far 5 as detecting water level above -- from the top of the ccre 8 to the top of the vessel?
Is this only true for those types.
7 of thermocouple installations that are from th'e top and not 8 from the bottom?
9 A
Yes, that is right.
10 0
So on the BCW type of core thermocouple device, 11 which is bottom entry, even if you installed one of these 12 devices you could still not determine the water level from 13 the top of the core to the vessel?
7 14 A
Well, there is a little bit of confusion.
All of 15 the PWR core exit thermocorples come in f rom the bottom of 16 the vessel.
These are not heated junction thermocouples.
17 The Combustion system is an additional heated junction 18 thermocouple that would be installed by penetrating the top 19 head.
It would be a new device.
20 The thrust of the sentence is tha t Combustion says f
21 they can install this heated junction thermocouplo from the l
22 top, but this seasures the liquid or vapor state well above 23 the core exit thermocouples.
So there is no connection
.+
24 betweenn the two.,
25 Q
I had understood from Mr. Phillips' testimony tha t ALDERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
15989 1
that was not the case, that the CE theraccouples were top 2 entry.
Are you sure of your information?
3 A
I as reasonably sure, and the reason ! sake that 4 statement is I do not know how physically one cculd sake n
5 such a device.
It is subject to check, of course.
ut 6 anything from the top has te come off when you defuel, and I 7 just do not know how you would work all that hardware and so 8 on.
9 G
But if in fact the CE penetrations are from the 10 top, it would make a big difference as far as installation, 11 easy installation of this device is concerned; isn't that 12 correct?
13 A
No, I do not see the difference.
Well, you need 14 -- if you are sci ic to put in a heated junction 15 thermocouple, you need a hole in the primary coolant 16 pressure boundary.
All o f th e he a te u junction thersecouple 17 concepts are to seasure the fluid above the core, and I dc 18 not know any way that you can accomplish this from below the 19 ccre.
20 So if you are going to use heated junction 21 theraccouples, you have to have an upper head intrusion of 22 some sort, no matter who made the reactor.
23 Q
But o the BEW reactors have these types of 24 existing pent.trations?
25 A
I do not know.
Some of them were designed with ALDERSoN REPORTING CCMPANY,;NC, 400 VIRGMA AVE. S/N, WASHINGTON. O.C. 20C24 (203 554-2345
15 9,n) 1 extra control rod thimbles.
There may be some extra 2 penetratic s.
I do no t know.
I kno w the testimony says 3 that Co; ustion has looked and claims that there is.
4 Whether that is a fact or not, I have not personally 5 lc ea.
6 Q
Are you aware of any -- any owners grCup Cr 7 experimental program which involves detection of fast 8 neutrons as a way of inferring level?
9 A
There is in place at the Farley plant, and here is 10 a companion work, experimental work, at the LOFT reactor on 11 what is called a non-intrusive neutron device.
That 12 operates on the principle that the neutron leakage would 13 increase even for a shut down rea -tor as the water level 14 d ro pped.
And this is being tested.
15 It is by the NNC Corporation, and I forget what 16 "NNC" stands for.
And whether or not it works remains to be 17 seen.
It is being tested.
18 C
If in fact this system tested out as being an 19 acceptable system, wouldn't it be the preferable one in that 20 it is a non-intrusion system?
21 A
Well, I mentioned the level criteria.
Intrusion 22 is less desirable than non-intrusion.
The data I have seen 23 on that system indicate it say take -- the time response may 24 he very sisd.
It may take many minutes to get enough counts 25 to be statistically significant, and that is a drawback.
g.-
ALOERSCN REPCRTING CCMP ANY. !NC.
400 VIRGINIA AVE. S.W. WASH 6NGTCN, D.C. 20024 (202) 554-2345
15991 1
So partly yes and partly no.
2 Incidental.i.y, I do not know whether they are 3 counting fast or thermal neutrons.
4 Q
Isn 't it true that -- or is it po ssible to have 5 inadequate core cooling and not reach saturation?
6 A
Yes.
Not in the sense tha t we are talking about 7
it.
But the so-called inlet flow blockage could produce 8
~:
9 0
I as sorry.
What?
10 A
Inlet flow blockace could produce local inadequate 11 core cooling.
But no device that has been discussed in the 12 last day would be useful to detect that.
13 Q
Including vessel water level?
14 A
Including vessel water level.
15 C
But wouldn't -- as far as systems -- as f ar a s the 18 usef ulness of the water level detector, wouldn't a 17 saturation meter always be the first indication of approach 18 to inadequate core cooling?
19 (Pause.)
20 A
Yes.
21 Q
And 1 n't it also true that the core thermocouple 22 temperatures are a way of -- the only way of confirming 23 inadequate core cooling, of actually knowin g you do have 24 inadequate core cooling?
25 (Pause.)
At.CERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
l 1594?
1 A
There are -- there are -- it is generally true.
2 There are some instances where for a period of time the flew 3 would be downward through the core, for a break on the cold 4 leg side.
And of course, the thernoccupies are abcve the 5 top of the core and they would not see i t.
6 But for conditions that are reasonably expected tc 7 occur from breaks, this condition would not persist very 8 long.
And the way you characterire it, I would say 9 saturation seter would be the first indication and liquid 10 level indication would be the second.
And then I think the 11 final confirmation would come from the thermocouples.
12 Q
So wouldn't it be somewhat correct to characterize 13 the usefulness of the vessel water level meter as something
'14 to get you f rom the saturation meter to the core 15 thermocouple, something to cover the area in between?
16 A
Yes.
The licensee has pointed out, I believe in 17 some places correctly, that the outlet temperature as 18 seasured by the RTD's, being in the superheat rance, tend to 19 confirm saturation zeter and thus play a role.
But your 20 sequence I think is correct.
21 Q
In the two cases you sentioned in your testimony, 22 the St. lucie and the Sequoyah event, wouldn't a reactor 23 head vent in both cases have been more useful to ecnfirm the 24 vessel was indeed full than a water level zeter, if you were 25 concerned about the level in the vessel?
ALDERSCN REPORTING CCMPANY,INC, 400 VIRGlNIA AVE, S.W WASHINGTON, D.C. 20024 (202) 554 2345
15993 1
A I really do not think there is a connection v th 2 the head vent.
The head vent would be used to purge 3 presumed noncondensibles.
And of course, in neither o9 4 those instances was there any.
5 No, I really do not think there is a connection.
6 Q
Isn 't the concern, even if you can detect reduced 7 vater level in the vessel, is to get that either 8 noncondensible or steam bubble out by some methed, and 9 wouldn 't in fact, without the vessel head vent, there would 10 be no way of getting that out other than a laborious process 11 that was used during THI-27 12 A
That is correct.
But the trouble I an havice in 13 getting a connection is, if you had a reacter vessel level 14 meter and if it indicated losL of level, then it is not 15 necessarily the appropriate thing to do to operate the head 16 ven t.
That 'should come later.
l 17 Q
So you are saying the head vent would not be a l
18 necessarily safe way to determine whether in fact the level l
l 19 of the vessel was full?
20 A
That is correct, I do not think that that would be 21 a pp ro pria te.
22 0
would it be correct to characterire the 23 Commission's -- the staff 's concern about vessel water level 24 in that, although not absolutely necessary to ensure public i
25 health and safety, it increases the nargin or decreases the l
t ALCERSoN REPCRTING COMP ANY. INC.
400 VIRGlh IA AVE. S.W. W ASNtNGTON, D.C. 20C24 (2C2) 554-2345
15994 1
risk f rom accidents, and therefore it is usef ul?-
2 (Pause.)
3 A
I have not used those words, " absolutely 4 necessary."
5 Q
I know.
That is why I used them.
6 A
And --
7 0
How would you characterize it?
8 A
Well, the way I would characterize it has to do 9 with the perception following THI-2 that rather th3n having 10 what we have called tunnel vision and looking merrily at one 11 instrument, that there needed to be more diverse instruments 12 that would let operators cope with anomalous transients.
13 THI-2 was an anomalous transient, one for which training and 14 procedures did not exist.
15 In a much milder version, the Sequoyah and St.
16 Lucie were anomalous transients.
Procedures and training 17 did not exist.
The Davis-Besse event of September '77 was 18 an anomalous transient.
And there have been others.
19 The desire to get reactor vessel level is te get 20 the diversity of information such that the operator would l
21 have more than just his now range.
The though t was no t all 22 transients could be postulated in advance and that the 23 diversity would allow operators to cope.
\\
24 For this very reason, inadequate core coolino 25 procedures are intended to recover from something i
ALDERSON REPCADNG CCWPANY. INC, 400 VIRGINIA AVE., S.W., WASHINSToN, D.C. 20024 (202) 554 2345
15995 1
1 undesirable, without any postulation as to how one get there 2 in the first place.
3 I think it is necessary that additional 4 instrumentation other than the ones presantly exicting in 5 ope ra ting reactors is needed.
Reactor essel level seems to 6 se to be an appropriate instrument to add to the armenents 7 that the operating staff has.
8 If that turns out in a year to be technically 9 infeasible -- and I do not rega rd that as likely at all --
l to then I would - my position would be that the regulators and 11 the regulated are going to have to do some more searching 12 and find some other way to provide the diversity and the 13 confirmation and the diagnostic capability for the' operating 14 staff, if not level something else.
15-Q So therefore --
16 A
So I would say to absolutely -- I would say level 17 or its equivalent.
And I cannot define what its equivalent 18 is.
And the clever industry will have to come up with l
19 something.
20 0
So therefore you say it is -- it is strictly a l
l 21 diverse way -- an additional and diverse method of l
22 determining inadequate core cooling and provides defense in 23 depth for that particular happenstance?
24 A
I would agree with that statement, yes.
25 0
Has the NRC done any numerical risk analysis to ALOER$oN REPCRTING COMPANY. INC.
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determine whether this indeed significantly reduces that 2 risk, compared to doing something else, for example?
3 A
There have been -- there has been some work, yes.
4 The work that I refer to is work that is beir.g done in 5 connection with the Degraded Cooling Steering Group, which l
6 is a group of about eignt managers in the NRC, one of whom 7 is myself.
We are working on the Item II.3.8 of the Acticn 8 Plan, which is the rulemaking.
9 We have done numerical estimates of the likelihood 10 that one can successfulli-terminate a degraded cere.
In 11 looking at the precedures we have represented to the 12 Commission and others that in general additional 1: strumen ts 13 and equipment and procedures can provide a risk reduction, 14 and we had a range.
And I think the nusher was about a 15 factor of five.
But it varies depending upon the asse=ptien 16 Tou make.
17 We have looked at it both ways, a verting core nelt 18 or reducing the core melt, frequency per reactor year, and 19 also looking at risk, which is a consequences argument.
We 20 tend to loot more at trying to quantify the likelihood of 21 reducing core melt per reac_ tor year, because if ycu throv in 22 consequences then the low probability, high-risk sequences 23 tend to cover up everything and you do not see the reduction 24 in core zelt per reactor year.
25 I do not have the numbers with me.
However, we ALOERSCN REPCRTING CCMPANY,INC, 8
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have recently placed the minutes of all our meetings in the 2 public document room and the nunbers should be there.
3 This is a continuing study.
~4e have engaged a 4 consultant to aid us in quantifying this and more 5 inf orma tion should be available, oh, I do not know, sid, 6 late sunser, something like that.
7 Q
Did you say your numerical analysis included the 8 effects of both instrumentation and equipment?
9 A
I did not.
They are the same thing.
I said both, 10 but equipent including various instrumentation.
'4 ha t we 11 were looking at overall is the livelihood of successful 12 operator intervention given a degraded core.
13 Now, as yet we have not allotted any marginal 14 effect due to the presence or absence of a reactor vessel 15 level instrument.
I do not know if we vill ever cut it that 16 fine.
17 C
In your opinion, would increasing or making l
18 safety-grade a system to recover from inadequate ccre 1
l 19 cooling provide more risk reduction than just merely having l
20 another instrument to detect it?
l 21 A
let me think.
I as prepared to answer.
22 I do not think that one could really measure it.
23 I do not think it would be a measurable increase.
Let me 24 explain why.
I believe that -- and this is true for I?.I-1 l
25 and I believe that when all facilities have in place i
ALOERSCM REPoRTWG CCWPANY,INC, 400 VIRGINIA AVE, S.W WASH 6MGToN. 0.C. 20024 (2C2) 554-2345
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inadequate core cooling procedures they will have a step, 2 something like, if all else fails, turn on some react:r 3 coolant pumps.
4 I expect -- and I an using " expect" in the 5 sta tistical sense -- that power would be available to those 6 pumps and the pumps would start, one or more would start, 7 and except for rara situ &tions the penps would be 8 effective.
9 The pumps are not saf e ty-g rade.
If yC1 made them 10 safety-grade, I do not think you could quantify the sarginal 11 increase in safety.
12 O
Isn 't ano ther way to recover from inadequa.e core 13 cooling by use of atmospheric dump valve to lower pressure, 14 so low pressure injection can be effective?
15 A
Yes.
16 C
Wouldn't making that system sore reliable 17 significantly lower risk, possibly?
18 A
I would not use the word "significant."
The 19 atmospheric dump valve can be operated manually, and in the 20 probability space we are talking about if it is an 21 air-operated dump valve -- I do not know for T!!-1, but 22 usually it is -- and the air is not safety-grade, then you 23 might postulate it would not work.
24 But more likely than not, the power will be there, 25 the air will be there.
If it were not, the operator could
)
l l
AwEasoN REPCRT'NG COMPANY,INC, f.,
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do it by hand.
And I think all these together, I would not 2 see any difference.
3 0
But if in fact there was, you could by numerical 4 analysis -
you could determine tha t some significant =cre 5 reliability could be made of those valves, would you then 6 compare that with the additional lowering in risk from the 7 instrumenta tion, the core level instrumen ta tion, compared to 8 this other change?
9 A
I understand your question.
I think the way -- I l
10 think the answer is no.
I think the way to reduce the core 11 melt, given an ICC, is to permit proper diagnosis and action 12 by the operator to do something different from what he is 13 doing.
The benefit of other devices in reducing risk you 14 would have to quantify by some work not yet done.
15 Q
On Licensee 's Exhibit No. 34, licensee's counsel 16 asked you about the information on page 4 concerning the 17 number of exceptions taken to ICC or ites II.F.2 being 20.
18 Do you recall that discussion?
19 A
Yes.
I did not mark that 44, but I recall the 20 discussion.
21 Q
If you look at the subsequent pages, aren't nany 22 of those licensees that have taken exemptions boiling water 23 reactors and therefore water level instruments are not 24 really applicable to them ?
25 A
That may be true.
I would have to check and see.
ALDERSoN REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON. 0.C. 20024 (2C2) 554 2345 e.
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Q Would you make a quick check, please?
2 (Witness reviewing d7cument) 3 A
W ithout counting the ntabers, I think that is 4 generally true.
5 DE. JORDANS Wha t is tr'4e?
6 THE WITNESS It, the fact that the boiling water 7 reactor industry had indicated exception to Item II.F.2.
8 Now, part of II.F.2 is for thermoccuples and some 9 of the BWB industry has taken exception to that, also.
So 10 without a closer look I do not think you can tell what 11 subpart is the letter "s" or the letter "t" in reference 12 to.
13 BY HR. DORNSIFE (Resuming) 14 Q
Byt that 20 is a very misleading number to use, 15 total number taking exception, until you look at more 16 information.
17 A
It is only misleading if one is misled, and I was 18 not misled by it.
19 3R. E0HNSIFEs I have no further questions.
20 BOARD EIAMINATION -- RESUMED 21 BT DB. JORDAN 22 0
I have several questions, but first I would like 23 to clear up my misunderstanding of one of your answers to
(
24 Er. Co rn sif e.
You described the committee that is working 25 on the rulemaking hearing as having done some numerical ALOCRSON REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTCN, D.C. 20024 (202) 554-2345
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analyses, trying to put numbers on the probabilities of ccre 2 melt.
And you said, I believe -- I thought you said at 3
first that it looked to you that a core level meter would 4 improve by a factor -- the situation by a factor of five.
5 But then later it was obvious that you did not 6 sean exactly -- that I misunderstood somehow.
Could Icu 7 straighten me out?
8 A
What I said was we have looked at the approximate 9 estimate of what the role of an operator could be in 10 terminating the core -- degraded core before it went to core 11 melt.
We did not attribute this to any particular action.
- 2 Q
So it is the role of the operator?
13 A
That's right, and whatever -- as he manipulates 14 plant controls and instrumentation and equipment.
15 0
Yes, all right.
16 Now, what actions can the operator take to 17 terminate inadequate core cooling other than the high 18 pressure injection systen?
19 A
Well, he has, I think, generally three actions he l
20 can take.
Two of them involve the high pressure injection, 21 and these are not necessarily in preference order.
But he 22 can restore inventory with the high pressure injection and 23 restore auxiliary feedvater to the steam generator and 24 return the plant to heat removal through the steam 25 generator.
ALDERSoN REPORTING COMPANY. lHC.
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Secondly, if that fails no can restore high f pressure injection and operate the pilot operated relief 3 valve, if there is one, and renove heat by the f eed and 4 bleed systes.
5 Thirdly, he can turn on one or more reactor i
6 coolant pumps and remove heat at the steam generatcr if 7 there is auxiliary f eedwater. Nov --
8 Q
If there is adequate inventory.
9 A
EventuallT that would f ail under the following to situation:
if you have a leak in the system snd eventually 11 all the water would be gone.
So operating the pumps would 12 work only as long as there is at least some water in the 13 system.
It does not need to be auch, but you would need 14 some injection.
15 Now, if the postulation was that you were only 16 getting a limited asount of high pressure injection, not 17 enough for feed and bleed, that night be enough water, 18 however, to continue to run the prisary system as long as 19 you did not have a leak.
Now --
20 C
Are you saying 21 A
In connection with these modes, if there is heat 22 transfer at the steam generator then you can do what r.
23 Dornsife was mentioning as an adjunct.
You can blow down 24 the secondary side, reducing its pressure, which in turn 25 will pull the primary pressure down to the point, hopefully, ALOERSoN REPCRTING CCMP4(. INC, 400 VIRGiNtA AW S.W WASHINoTCN. D.C. 20C24 (2C2) 564-2345
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where you can use the low pressure system.
2 Now, that would be useful for option cce and 3 option three.
It would not do much good for option two.
4 Q
Option two is which?
5 A
That was f eed and bleed.
6 0
Tes.
7 A
Until -- until you can somehow -- if you do not 8 have auxiliary feedwater, then feed sad bleed would have tc 9 go sn for a number of hours before you can get the pressure 10 down, use the low pressure injection.
11 0
You did mention the possibility of using dump 12 valves, but that were the secondary dump valves you were 13 talking about, not trying to reduce the pressure of the 14 primary to the place where decay heat removal system would 15 come on?
16 A
Tes, sir.
If there is heat transfer from the core 17 to the steam generator.
18 Q
That is the only way you can get the pressure down 19 to the place --
20 A
Right.
21 Q
All righ t.
22 A
As I recall, all of these methods are mentiened in 23 the THI-1 inadequate core cooling procedure as of last 24 June.
25 0
All righ t.
Nov just how dces a ccre -- a water ALDERSCN REPORTING CCMPANY,INC, 400 VIRGINIA AVE., S.W, WASHINGTCN, D.C. 20C24 (202) $$4-2345
l l
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level meter help the operator to decide to take any one of 2 those actions?
It seems to ne that essentially he takes the 3 action of adding water, high pressure injection, and he 4 certainly tries to preserve cooling' in the secondary system i
5 any time.that there is evidence of inadequate core cooling 6 by a sa turation meter or whatever.
7 A
A2 I sai.d, I think it is the diversity cf 8 information, and I think we have seen what happens if you l
l 9 rely on one instrument.
It could be confusing.
1 10 Certainly, in principle level is diverse from 11 temperature.
It uses -- displays a different type of l
12 information, uses a different type of sensor.
And I regard 13 these as somewhat complimentary.
And it th e total, I think, 14 that makes it more likely that the operator will take the l
15 correct action in time of need.
l 16 Now, it follows, of course, that for some 17 postulated accidents all three of these will indicate.
18 Through some breaks the saturation meter will gc to zero or 19,to superheat, the reactor vessel level will go empty, and 20 the core exit thermocouples will heat up.
This would he 21 expected for most -- for the loss of coolant event.
l 22 Anything bigger than two or three inches, one would expect n this.
l 24 Further, what I call a stylized scenario --
25 0
What?
ALDERSON REPORTING COMPANY. INC, y,
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i t
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A For a scenario that is well predicted in ad va nce,
2 one needs nothing.
You do not need any of these instruments 3 if you are able to predict what happens.
4 But for the anomalous transients that ycu have nct 5 been able to predict in advance, a more complete arsenal, I l
6 think -- arsenal is needed fcr the reactor operator.
7 C
You described the ATOG program as one which would i
8 aid the operator in diagnosing the problem.
Now, does the 9 ATOG program add sufficient to the operator's ability to to diagnose that a water level meter would be less valuable or 11 superfluous?
12 A
I as sorry, I just do not have the de tails to 13 answer that.
I doubt that it does, because it is a BCW 14 program and I think they probably left it out of their work 15 because they thought it was not needed.
They left out 16 level, that is.
But I really do not know.
17 (Pause.)
18 Q
You said you had read Mr. Keaten 's testimony.
I 19 believe Mr. Keaten said that he felt that a water level 20 meter haald perhaps confuse the operator and possibly result l
21 in incorrect actions.
22 Have you -- did you?
23 A
I recall pecple have made that statement.
I do l
24 not recall -- I do not disagree that Mr. Keaten made it.
I 25 just don't remember.
I ALDERSoN REPCRTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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0 Supposing he had or other people had.
Oo you have 2 -- do you disagree, and if so why?
3 A
Well, an inaccurate water level signal, like any 4 other inaccurate signal, could confuse the operate and 5 cause his to take incerrect action.
I do not believe 6 inherently that an operator can intt pret temperature, flov 7 and pressure, but not level.
Those are the fetir classic 8 parameters.
I do not know inherently why he would be 9 confused by one and guided by the other three.
10 And of corrse, the whole thing goes as to the 11 validity of the signal.
And the staff indeed had the sane 12 concern, oh, say two years ago, about being confused by an 13 invalid signal, which is why we want to be assured that tie 14 signals are indeed valid before they are added to the 15 arsenal tha t the opera tor has.
i 16 (Board conferring.)
17 0
Can you tell se how the GE level meter WCrks?
18 A
I as sorry.
What ?
l 19 C
The GE vater level seter works.
How does it L
20 operate?
How does it seasure level?
21 A
I.believe they are all delta p type.
There are a 22 number of instruments, including a number of delta p 23 instruments, I would just have to say to the best of my 24 belief.
l 25 C
Then that instrument also would change in reading ALOERSCN REPORTING COMPANY,INC, 400 VIRGIN (A AVE, S.W W ASHINGTON. D.C. 20024 (2C2) 554-2345
16007 1 as the recirculation pumps are started?
2
! believe the inst:cnent -- well, they have what 1 3 think is known as an instrument stalk.
4 C
Instrument what?
5 A
Inst:caent stalk, an arrangenent.
And th e 6 location of these instrumen ts varies.
I think nost of the 7 designs are in what is called the downconer, and there is S little flow in the downconer.
So it would not change nuch 9 with th; -- the flow rate in the downconer is relatively to small.
The pressure drop due to friction losses is 11 relatively small.
12 Q
I guess I am forgetting the situation.
I thought 13 that the recirculation pumps, the jets themselves vent,into f
i 14 the downconer and made a large flow in the devncozer and 15 then bsck
',p to the core.
An I wrong?
16 A
That is correct.
But the flov :ste -- the 17 pressure drop due to f riction in the downcomer is not all 18 that large.
In fact, the whole core pressure drop is not 19 that auch.
And most of the liquid levels, of course, of 20 significance are well above the core.
21 I do not think there is such of a head loss from 22 location to location that can be attributed to f rictional 23 losses.
I think it is sostly elevation.
24 C
I see.
25 A
So I would not,-except for collapsing voids, I at 'Y. Jt$CN RE?oAnNG c0MP ANY. iNo.
400 V8GIh A avl S.W. WASMtNGTCN. oA 20C24 (202 554-2345
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would not expe'et much change in the delta p signal as a 2 result of tripping.the pump.
3 0
Well, does it measure the level of water in the 4 downcomer and is that in itself sufficient inf orma tion?
5 Don you really want to know what the level in the core 6 is?
7 And I am going to go on, by the way, with this 8 because I want to get into something else that Mr. Keaten 9 said, namely that when the core -- when you have power being 10
- enerated, then you may have a froth, and the frcth, there 11 1s no real water level.
It is hard to say that there is a 12 vater level.
There is an inventory, but not necessarily a 13 vater level.
14 And doesn't the GE system have a problem that 6
l 15 there is no real water level in the core?
16 A
Well, ce rtainly the average exit void fractica is 17 40 percent.
So to a certain degree you can say the core
~
18 runs uncovered.
You know, it is not full of liquid.
But i
19 there is many feet of water above the core.
20 0
'ihere is what?
l l
21 A
There is many f eet of water above the ccre in the 22 downcoser.
Of course, the inference is the level in the 23 downconer and the level in the core are the same, and to a 24 certain degree that is not true, because of the acceleration 25 losses and the friction losses.
I f
ALDERSoN REPCRTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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But I think compared to the mass above the core 2 this is small.
And as long as the downcomer and the core 3 are connected, as they are in a jet pump plant, then it is a 4 f air inference to say the downcomer level and the core level 5 are the same.
i 6
G Now we have a similar situation, then, in a PWE.
7 Is it therefore enough to measure the level in the i
8 downconer?
l l
9 A
There was an event in May '79 where the downcomer i
10 and the core were not connected because of some -- it was 11 not a jet pump plant, where the valves were closed going out 12 to the recire pump and then for a period of time the water 13. level in the downconer was high and the water level above 14 the core was low.
15 C
This was a BWR7 18 A
BWB.
17 0
In the case of a PUR, would a measurement in the i
18 level -- of the level in the downconer also be an adequate l
l 19 indication of the level in the core?
l l
20 A
We had not thought about that, but I think it is l
21 hard to say.
It would depend on the transient.
I think fCr l
22 a good number of transients the answer is res.
There are 23 some -- there are some transients where the water level in l
24 the downconer is higher than the water level in the core for l
25 certain cold leg breaks, because of the frictional losses of l
I I
I
~
ALDERSoN REPORTING COMPANY. INC.
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the core exit steam going around through the stean 2 generator.
3 But that does not last but for a few =inutes.
Sc 4 I think by and large the downcomer level and the core level 5 could be used more or less interchangeably.
The top of the 6 downcome is, oh, several feet above the top of the core.
I 7 do not think anyone has proposed a downconer level 8 seasurement, but we will be glad to look at it if anybcdy 9 did.
10 C
Er. Keaten pointed out that one of the problems 11 with the core, measuring the water level, is that under 12 situations where there is boiling going on in the core --
13 during the approac'h to inadequate core cooling, there is no 14 defined level.
There is a froth which is providing adequate 15 cooling at the power levels we are talking about, which is 16 usually shutdown, and the ref ore there is no level to 17 measure.
18 A
Well, bo th the methods of the heated junction 19 t:1ermocouple and the delta p systes, which would provid'e 20 some inf erence. -- the delta p systen, obvio usly the only 21 thing you would get out of it is what one sometimes calls a 22 collapsed or quiet level.
And it cannot tell whether there 23 is a froth in the core extending well above the core or 24 whether it is collapsed.
25 Q
Would you saI it is inadequate, therefore, in a At.CER3oN REPoMNG COMPANY. INC, g,
400 VIRGiMA AVE., S?V, WASHtNGToN, D.C. 20024 (202) 554 2345
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s an se ?
2 A
I think it is quite easy and in f act has been done 3 j n experiments that were commissioned on another ECW reactor 4 to draw an inference between froth level and inadequate core 5 =coling.
The data exists on this.
There are other 6 experiments, also.
But since we are looking at BCW 7 reactors, I just refer back to these tests to make that 8 co rrela tion.
9 Incide n ta lly, the BEW vent valve design would 10 probably make a downconer level even -- make it better, nore 11 representative, because there is less tendency on that 12 design to have what is called steam binding.
So with the 13 close coupling of the upper part of the internals above th e
(
14 core on the inside to the downconer on the outside, then the 15 pressure gradient between the two should be very small, so 16 the downcomer level and the core level should be very close l
17 on a BEW reactor.
i I
18 It is one of the -- wha t I call a distinct design 19 advantage of the B&W system.
20 Q
You mentioned some cases, such as St. lucie, where 21 there seemed to be operator confusion.
Now, does the staff I
22 have in mind a nur.ber of scenarios -- let me first ask, at 23 St. lucie did they have a saturation meter in operation?
24 A
I do not know.
They probably should have, but in 25 readino -- we know what the saturation was at all times for l
I ALDERSoN REPORTING COMPANY,INC, i
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tha t event, and I do not know whether it came from the 2 saturation meter or not.
They never approached saturation.
3 They never came within 50 degrees of saturation on th e 4 saturation meter, although they clear.1.y had saturated l
5 conditions.
6 They formed about 800 cubic feet of steam.
So in l
l 7 the reactor vessel upper head they were clearly saturated, 8 but the meter did not detect it.
9 0
That is because the meter was not located in the 10 upper head?
11 A
That is right.
12 Q
I see.
(
,~
13 A
So the saturation meter itself can under certain l
14 circumstances give inadequa te inf ormation?
l l
15 A
Yes, sir.
And I think we pointed this out in one 16 of the testimonies filed by the staff on this subject.
I 17, f orget which one.
provide in 18 Q
All right.
Does this, then, provir _
l 19 large measure the reason why the staf f feels that supplement 20 is needed in that the saturation meter does not always give 21 you adequate information?
22 A
Not really.
I think we started on this for 23 diversity.
I think this may just illustrate it.
But we are t
1 1
8 l
24 not relying on'the St. Lucie event in pa rticular.
It is 25 just that a multiple set of inf ormation is much better than ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
16013 1
trying to rely on one instrument.
2 0
But 3
A Yes, sir.
Go ahead.
4 0
But diversity can be obtained in a number of 5 ways.
Sometimes we call it functional diversity.
6 A
Right.
7 Q
And if it is just diversity yi.u need, a diverse 8 method of measuring saturation, for example, would do that.
9 A
It could be.
We have had some proposals where l
10 people could put thermocouples somevhat widely distributed 11 in the upper head.
There have been other discussions on l
12 putting them in the area above the core.
There is about 12 l
r-13 feet above the core, give or take a little, with the control 14 rod drive extension thimbles and so on.
15 But something like that could indeed be diverse.
16 It just has not been pursued.
17 Q.
I see.
I guess I would have thought that was in a 18 sense if you have -- you said thermocouples, not heated 19 junction thermocouples?
I 20 A
Not necessarily, although if you are' going to put 21 in a thermocouple it is just as easy to put in a hea ted 22 junction thermocouple.
l 23 Q
Which would give you more ir forma tion?
24 A
Yes.
We have ceen instcnces where, if a 25 t
s ALDERSON REPORTING COMPANY. INC.
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thermocouple is near a radiating body like a large slab of 2 metal at 550 degrees, it could be influenced by that.
And l
3 by heating it you measure the rate at which heat has been 4 transported away, which varies as the quality varies.
So a 5 heated junction gives a bit more information.
There is a 8 substantial amount of test data on that subject.
7 0
In the proposals for heated junction, do they have 8 a continuous line?
Is it necessary to have a continuous 9 line of heated junction therzoccuples from the top of the 10 upper head. lown to the core or below, or in some cases are 11 they considering only, say, five or six different hea ted 12 junction thermocouples?
I 13 A
I think that would be about the right number.
14 0
You do not need a continuous line?
15 A
No, no.
18 C
Now, do you need a thermocouple below the level of I
17 the core or can you rely on the core outlet thermoccuples I
18 for that?
19 A
There is not unanimity amongst the staf f on this 20 subject.
I think the view.will prevail that proper software 21 and computer treatment ef th: heated junction thermocoupl'es 22 can be made to be acceptable, and you would not need to 23 extend the heated junction into or below the core.
That 24 remains to be seen.
I 25 Q
Ey intuitive feeling is that what you want to knew s
ALDERSoN REPORTING COMPANY,INC,
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is that there is water above the core.
New of course in 2 some instances, I ga ther f rom Mr. Kea ten or pcssihly the 3 staff testimony, that the loss of coolant accident would 4 very quickly -- the level gets devn to the tcp of the core.
5 And so therefore only knowing the level of what is above the 6 core is of little vslue.
7 A
Is what, sir 8
C Is of little value, because you know in many of 9 these scenarios the level does drop to the top of the core.
10 And so therefore, the level -- the level zeter is of little 11 addition al val'.le.
12 A
Yes, sir.
I would say the sase for the other two C =etars that we heve been discussing, the saturation meter 14 and the core exit therzoccuple.
In fact, for most less of 15 coolant accidents, there is adequate core cooling.
And ss 16 long as it is following the postulated accident, the best 17 thing the operator can do is watch.
18 The equipment should come en, it should recover 19 the core.
Ihat is what it is designed to do.
l 20 C
Tou would say that the core level neter would be i
21 of value because he would see the le vel f alling and then l
l 22 could observe that the actions that he takes vould improve i
23 the water level?
Is this hev it helps the operater?
f 24 A
It helps, yes.
It also helps for the 25 nonpostulated sequences.
'Je had a request of the Adviscry ALOEA$oN RE?cATLNG CcWPANY. INc.
400 VmG;htA AVL S.W. WASHINGTON, D.C 1T24 (202) $M-234$
16016 1
Committee.
We analyzed nultiple instrument tube failures at 2 the bottom of the vessal.
Eulti;.le instrument tube failures 3 are not a design basis event.
4 We calculated that if five or six of these failed 5 concurrently there would be a small break loss of coolant 6 accident, for which the liquid effluent would be higher than 7 the high pressure injection.
So in this instance what the 8 operator would see, the saturation meter would go to 9 super' heat, or it certainly would go to saturation, the high l
10 pressure injection would come on, there would be other 11 symptoms of loss of coolant-like activity in pressure and so 12 on.
13 If he had a level, the level would show a drop.
14 He would look at the flow. rates on his high pressure 15 injection system.
He would see they are both performing l
16 normally.
But accordingly to our calculations the level l
l 17 would continue to drop.
He would never recover the core.
1 18 That is an anomalous transient.
It is not 19 postulated for design.
Its likelihood is very low.
20 C
Ies.
21 A
Given that situation, the operator may well decide of course, by the way, when the level gets below 22 23 presume he has tripped the pumps pursuant to procedure and 24 when the level dropped below the core, then the core exit 25 thermocouples should start doing something.
Now, whether ALDERSoN REPCRTING COMP ANY. !NC, l-l l
400 VIRGINIA AVE., S.W., WASHtNGToN. D.C. 20024 (202) 554-2345
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indeed they will function in this situation I do not know, 2 because the flow is downward.
The break is at the bottom.
3 I think the level ins trument in this instance 4 could'be useful.
It might be determining.
I do not know.
5 It would take a more detailed analysis than I have done to S indicate.
We really focus more on inadequate core coolino 7 on the anomalous transients not heretofore considered.
So I 8 would hate to rely on'the sequence I just mentioned as a 9. justification.
It is just an illustration.
10 0
I see.
Is it then sort of a gut feeling on the 11 part of the staff that there are anomalous transients that 12 have not been considered?
If they had been considered you 13 would not need the level meter?
Or are there transients --
14 A
If all of the anomalous transients were converted 15 into design basis transients, then onc e again the opera tor 16 could just sit and watch.
17 0
You mentioned one possible anomalous transien t.
- 18. Are there others?
l 19 A
If I had a list I would convert them into an 20 analy7ed transient and.make sure there was enough I
21 e etApnent.
Now, just looking at the symptoms and making 22 sure that the operator can -- has enough symptomatic 23 information that he can use the equipment, whatever he N
- he best he can, 24 happens to have available at the time to de.
25 and so, no, I do not have a list of anomalous transients.
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345 l
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Q I see.
2 A
I gave some for illustration, but I certainly de 3 not regard then a s con ple te.
The probles with -- you kncv, 4 I sentioned Sequoyah in the testi=cny.
In that instance tha 5 water was 175 degrees. If it had been 275 destees, which is l
[
6 clearly possible for use of the RHR, then the course of that 1
1 7 transient would have been markedly different.
8 So I do not want to see Sequoyah 1 as it was in 9 Feb rua ry 1981.
How about ancther reactor at ancther time at 10 a higher teuperature?
That was a single operater error.
We 11 have operators and they are still gela; to make errers, and 12 I would like to get more weapons available for the 13 operator.
14 Q
Are you saying, then, that there are -- just has 15 to be anomalous transients beyond those for which cre ra tinc 16 procedures have been written?
17 A
That will always be true.
18 DR. JORDAN:
Are you going to have some redirect?
19 HR. CUTCHIN:
At this point no more than a couple 20 of questions, Dr. Jordan.
21 Mr. Chairman,are you planning to take a break er 22 go straight through, or wha t is the plan ?
23 (Board conferring.)
24 CHAIREAN SHITH:
How about additional cross?
25 ER. SAITER:
Not such.
ALOEAScN AEPCRTWG COMPANY !NC, i
400 v1AGNA AW. S W WA$NWGTCN, O.C. 20C 4 (202) $54 2345
16019 1
CHAIRMAN SMITH:
I think we should be able to 2 finish up, then.
3 BY DR. JORDANi (Resuming) 4 Q
Would you say a little bit more about what ycu 5 consider to be reasonable progress.
Mr. Baxter read to you 6 the position of THI Licensee, and you said that ycu did not 7 in your opinion believe that that was an adequa te commitment 8 to show reasonable progress; am I correct?
9 A
Yes, sir, that is what I said.
I think first I 10 would like to sake a commitment which I can live up to.
I 11 would be glad to elaborate in greater detail in supplement 12 two on this subject.
I think it would be useful to do 13 that.
14 Q
Wh: n supplement two comes out, you sa y there vill 15 be a bettr.r es 'lanation of the staff's position?
18 A
- Ies,
,ir.
17 Q
Than in supplement one.
Well, supplement one is 18 pretty clear.
I mean, not supplement one; the original SIR, l
19 this position was very clear, yes.
20 A
Well, I can fix that.
But when I was reading the 21 submittals that were filed by the Omaha Public Power 22 District, February 27, 1981, with respect to Fort Calhcun, 23 they had a summary status report that they enclosed.
The
?
24 pages are numbered separately, so it is about 20 or 25 pages 25 and the title is inadequate core cooling de tec tion system l
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554-2346
16')10 1
summary status report.
2 57 inspection of that led me to classify that as 3 rea sonable progress, as an example.
I think I can clearly 4 see the need for us to speak less ambiguously in the 5 forthcoming supplement.
I will say that we vill do it.
6 CHAIRMAN SMITH:
That might net be good enough.
7 It just may be too late.
It say not give us an opportunity 8 to address it timely.
This is the second crack the staff 9 has made on making this case on this issue.
ou try your to own lawsuit.
11 DR. JORDAN:
That is all the questions I have.
12 CHAIHr.3N SEITH4 My problem is, you cannot come tc 13 the Board, make a case, go back and look at it, decide it is 14 insufficient, come again and tell us you are going to make 15 the case the thi'rd tim e.
Now is the time to make the case 16 on it.
17 MR. CUTCHIN:
I did not make the commitment, Mr.
l 18 Chairman.
l 19 CHAIHEAE SMITH:
All right.
You see, you are 20 a n ticipa tin g, I guess, that the supplement two will be l
l 21 produced into evidence and subject to cross-examination, and 22 I do not know if you are planning on that, Dr. Eers.
Eut if 23 you are going to make the case about reasonable progress in 24 a contested issue, such as this is, it is going to have to 25 he subject to adjudica tion and cross-examination and ALDERSoN REPORT.NG CoWPANY,INC, 400 VIAGNA AVE S.W. WASHINGTCN D.C. 20o24 (202) $54-2345
_6021 1
testing.
2 IHE WITNESS:
Mr. Chairman, perhaps I did not 3 understand Dr. Jordan.
He was asking about ressonable 4 progress and I was representing I would be glad to discuss 5 examples in supplement two of what I considered reasonable l
l 6 progress.
I i
7 CHAIBHAN SMITH:
Oh, now I understand.
8 THE WITNESS:
I could refer to the example that I 9 had of the Caaha, because I had it with me, and I thought it 10 would be preferable to the Board just to put it in the 11 supplement.
But.ve can go into it now if you would like.
12 CHAIRHAN SMITH:
I guess I misunderstood your 13 testimony.
I thought that you were suggesting that you 14 recognize now that the staff has to address more thoroughly 15 the subject of reasonable progress and that it vould be 16 addressed in supplement two.
(
17 But I did not understand that you were 18 volunteering now to tell us what supplement two is going to l
19 contain on the subject, if tha t is --
l 20 THE WITNESSs I can do that in this instance.
21 This comment also applies for some submittals I 22 received from Westinghouse as well.
I an speaking in 23 g eneralitie s.
If I -- both of these submittals, the one 24 f rom the Westinghouse Owners Group and the one from the CE 25 Owners Group that was supplied by Omaha Public Power ALDERSCN REPCRT!NG COMPANY ANC, 1
400 VIRGINIA AVE, S.W. WASF NGToN, D.C. 20024 (202) 554 2345 l
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1 District describes some screening that was done on systems 2 about a year ago, the selection of candidate systems for 3 further tests, tests at the reactor vendor's facilities, 4 either at Windsor Locks or Combustion or at Forest Hills, i
5 Pennsylvania, for Westinghouse, sending prototypic sysress i
6 to the Commission *s r _; arch facilities at Oak Ridge and in
~
l 7 Idaho Falls, operation of these prototypic devices in 8 realistic LOCA environments, and f urther
.s on --
9 analyses that related certain postulat'.a sequences that to created loss of coolant environments, and in particular what 11 would the predicted reacter vessel level be and how would 12 this be fed in to the operator.
13 We have seen creation of inadequate core cooling 14 guidelines that used the level as a signal to the cpera tor 15 for when he should take actions, and we have seen the 16 coupling of reactor vessel level to the guidelines f or use 17 of the reactor head vent.
That is what I mean by reasonable 18 progress.
l 19 Now, the confusion is I was representing that we 20 would document all that in supplement two if it would be 21 helpful, because we had not heretofore offered on this 22 subject a working definition of reasonable progress, excep 23 as I have explained it here.
24 SY DR. JORDANS (Resuming) 25 Q
I guess that is what I was inviting you to do:all s
ALCERSCN REPCRTING COMPANY,INC, 400 VIRGINIA AVE S.W. WASHINGTON. D.C. 20024 (202) 554-2345
46023 1
right, was to try to get some criteria of what you seant by 2 reasonable progress and therefore justify why you say the 3 licensee has not made reasonable progress under that kind cf 4 a criteria or definition.
5 A
That would follow, yes, sir.
6 0
Ho w is th a t?
7 A
That would follow, I would agree.
If I produced a 8 list of one through N items taken together that was 9 reasonable progress, it would follow I had to show where 10 Licensee did not fulfil
.,n one or more of the list.
11 Q
Where I as heading now -- I do not want to trap 12 you -- it is this.
There are -- we have the problem of 13 deciding whether reasonable progress has been made before we 14 can recommend restart.
On the other hand now, there is the 15 situation with operating licensees, and we do not want to 16 apply necessarily a different criteria to T5I than the 17 operating licensees.
18 There are lo ts of ope rating licensees that have 19 not made reasonable progress, and therefore would you say 20 that.this Board would now accept the staff's position that 21 they had not made reasonable progress and therefere restart 22 should be denied?
23 NE. CUTCHIN Mr. Chairman?
24 BY DR. JORDAN 2 (Resuming) 25 Q
In view of the fact that apparently the same ALCERSoN REPCRTING COMPANY INC.
400 VIRGINIA AVE. S.W. WASHINGTCN. O.C. 20024 (202) 554 2345
16024 1
criteria.is not being applied to the operating reactors.
2 5R. CUTCHIN:
Mr. Chairman, may I interject 3 something here that I think may be necessary for the record, 4 as to how I see the case gcing?
I think before the 3 card 5 has to decide whether reasonable progress has been made, the j
8 Board has to first decide whether in this instance 7 Intervenors and staff prevail on the necessity argument or 8 whether Licensee does.
i 9
If we and the Intervenors do not make a 10 satisfactory case that this instrument for core water level 11 seasurement is necessary, then the Board does not have to 12 even address the reasonable progress question.
7 -
13 CHAIRMAN SMITHS Of course we are quite aware of 14 that.
But the difficulty is the record has to be made en
(
15 both issues, becanss the Board has not yet decided.
16 MR. CUTCHIN4 I understand that, sir.
And I just I
17 vanted to be sure that there was a clear indication of that, 18 because I did not necessarily get that f eeling f rom Dr.
l 19 Jordan's questions.
20 HB. BAITEH4 I do not agree with that.
21 DR. JORDAN:
I think you and the Chairman 22 understand each other better than I do, and I think Mr.
23 Baxter is also --
24 HE. BAXTER:
I do not agree that if the Board i
25 decides that level instrumentation is necessary that the l
l ALDERSON REPORTING COMPANY,INC, y,
.e.ro 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20Clel202) 554 2345 m
1&O25 1
rea'Anable progress issue goes out.
Is tha t what staff 2
.ounsel --
3 DR. JORDAN:
That is what staff counsel said.
4 MR. CUTCHIN :
I an saying only if the Scard 5 decides it is necessary, need they address the reasonable 6 progress question.
If the Board decides it is unnecessary l
7 and you prevail, the licensee prevails, then the reasonable 8 progress question would in my view go away.
9 DR. JORDAN:
Oh, yes, I understand that.
And I 10 think Mr. Baxter is shaking his head.
We all understand 11 that.
12 CHAIRMAN SHITH:
I suggest that after the record 13 is closed on this issue, we might arrive at this situation.
14 We may decide one way or the other as to whether the water 15 level indicator is necessary in the sense of the Commission 16 order.
I think we are going to have to decide that there is 17 some reliable and probative evidence on bot'.t sides of the 18 issue.
19 I think that to perform our full responsibilities 20 ve vill have to decide in the alternative in any event i
l 21 whether reasonable progress has been made.
I think for the i
22 Commission to have a complete record it may be nec'essary for 23 us to address both, no matter which way.
And rea sonable 24 progress, that I think is going to I-the Board is going to 25 have to apply some standards that perhaps the staff har not ALDERSoN REPORTING COMPANY. INC, 400 VIRGINtA AVE.,3.W, WASHINGTON, D C. 20C24 (202) 554-2345
1602S
~
1 con sid'e red.
2 And it might be -- le t me back up a lit tl e bi t.
3 In the first place, I am not entirely" comfortable either way 4 about the Board continuously indicating to the staff or to 5 any party that in this instance the staff, you have not made 6 Tour case, you have not made your case, you have not made 7 your case, keeping in mind some magic goal that has to be 8 reached, and then allowing it to be added onto and added 9 onto until you have satisfied the Board that you have made 10 your case as to necessity.
11 That just is not fair, because it is a contested 12 issue.
On the other hand, to adjust things, if that is 13 happening anyway, we certainly should allow the Licensee te 14 make parallel progress, if they wish, on reasonable 15 progress.
16 That was a digression, but I thought it was a 17 point that should be made.
Now, I do not -- the question 18 1s, has the staff considered.
And I am not suggesting it is 1
19 appropriate the staff consider.
But has the staff l
20 considered that reasonable progress might very well be that 21 the Licensee has given a reasonable look at the problem and 22 bas given an explanation which reasonable minds can accept l
\\
l 23 as being arguable as to why they do not think it is l
l 24 necessary and, having elected to litigate it, go the 25 litigation route rather than the staff route?
l l
ALDERSoN REPoRUNG COMPANY,INC,
~:**-
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
16027 1
That in itself sight be reasonable progress.
I 2 think I read into your testinony a little bit of annoyance 3 on the part of the Licensee -- I am referring to page 7, the 4 last paragraph of your answer 4,
the last sentence, which 5 says, quotes l
6 "Further, these plant owners who have devoted i
7 their resources to satisfying the II.F.2 requirement, rather 8 than resisting it, expect to meet the scheduled requirements 9 of NUREG-0737."
10 Now, I think that is a non sequitur.
It succests 11 that the same resources used to resist are those which would 12 have been applied to satisf-it, and it suggests tungible 13 resources and that one prevel;'s the other.
So I de not 7
14 think you are quite -- I think you meant it you.are i
15 piqued, you are annoyed, I think, with then.
16 IHE WITNESSa I did not mean to imply the sc=e 17 amount of resources.
It was more calendar tine.
By 18 saiting, let's say, many months to start, with a fixed end 19 date makes it difficult.
So it is not necessarily scope so 20 auch as schedule.
21 CHAIBMAN SMITH:
It is resisting, though.
Ihe 22 language, "ra ther than resi sting," which seens to suggest 23 that they have wasted their resources in resisting you 24 rather than complying with what you want.
25 THE WITNESS:
It-could, of course, by ny l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
16023 1
perspective.
The work was done.
The B&W report was 2 produced for the Owners Group in August 1980 that documented 3 why, in the osinion of the writers and the references of 4 that report, reactor vessel l'evel is net needed.
Sc we did 5 get documentation.
I think that was mentioned in your first 6 step.
7 CHAIRMAN SMITH:
The point I am making is that I 8 think we have to give it a diff erent perspective than you 9 do.
And reasonable progress, I think, will have to perhaps 10 take into account that the licensee has been given an 11 opportunity to litigate it in this instance, rather than i
12 just accept what the staff is trying to impose.
l l
13 I also want to make another point, and that is, no
[
14 matter what we find -- no, I cannot be that strong.
It may 15 very well be that we could find hypothetically that within 16 the standards the Commission has required us to accept for 17 this hearing, that the staff has not prevailed.
But we 18 would also be careful to state that we are not finding 19 making any findings which intrude upon the staff's duties 20 and responsibility to impose reasonable improvements tc the 21 margin of safety, which is a different co nsid e ra tio n.
22 And this is a distinction I would like for you to i
l 23 keep in mind and address and perhaps summarire and conment, 24 the difference between the standard that the Board must 25 impose, and that is necessary in the long run to assure ALDER $oN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
16029 1
to provide reasonable assurance for public health and safety 2 -- as compared with reasonable improvement in the margin of 3 safety which should be imposed, which we do not wish to get i
4 involved in, that second level.
5 We do not wish to support or impede the staff at 6 that level of enforcement.
We just wish to linit our l
7 adjudication to the level that the Commission has given us.
8 THE EITNESSs Yes, sir, I think I understand th e I
9 difference.
Except for the reasonable progress finding, !
at least it is our intent to 10 believe that we are treating 11 treat THI-1 in this respect r.s any other operating 12 pressurized water reactor.
13 CHAIRMAN SHITHE Perhaps I think we have been
, 14 unfairly trying to impose upon you the responsibility to l
15 make decisions which the Board has to make.
16 Mr. Eaxter?
17 HB. BAITER:
I was merely going to suggest that we i
l 18 go back to Dr. Jordan's question, which the witness was not 19 able to answer because of the interjecting arguments, or l
20 discussions.
Excuse me.
21 BY DH. JORDAN:
(Resuming) 22 C
I asked for the criteria of reasonable prcgress 23 and I gather that Er. Eaxter at least feels you ha ve not hsd 24 a chance to reply in full, that you had gotten interrupted.
l 25 Is this right?
(.
ALOERSCN REPCRTING CCWPANY,INC, 400 VIRGINIA AVE S.W WASHINGTCN, n.C. 20C24 (202) 554 2345 b
16030 1
MR. BAITER:
Dr. Jordan, you had just completed 2 the question that said, a pparen tly o ther opera ting licensees 3 have not made reasonable progress, and the Board has to 4 decide whether or not TMI-1 has and whether or not it should 5 restart, and how is the staff applying the standard here 6 versus operating licensees.
7 That is when Mr. Cutchin said, I would like to 8 give you my views on the case.
The question was not 9 answered.
10 BY DR. JORDAN:
(Resuming) 11 Q
Iou heard the summary of Mr. Baxter.
Would ym' o 12 ahead and address that now?
13 A
Some other operating PWB's have not made 14 reasonable progress.
If that was the question, the answer l
15 is some have and some have not.
i 16 0
But you have always said you are not going to shut 17 those reactors down.
You are going to let them operate.
l 18 You are going to try to continue to exert pressure until 19 they do either conform or convince you that it is not 20 necessary.
21 A
The reason I cannot be more --
22 0
Therefore THI-1 is in a different category, you 23 see, because we have to apply a different standard than you 24 are.
You can have flexibility; we do not.
We have the f
25 Commission order which says they must demonstrate reasonable ALDERSON REPORTING COMPANY. INC, t ' s' ' '
400 VIRGINIA AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
16031 1
progress before restart.
2 A
That is correct.
And the reason I cannot be more 3 specific is there have been two suggestions on how to bring 4 the -- I hate to call them laggards, but the people we put 5 into the category of not making progress.
We have 6 considered issuing crders and there has been some 7 consideration go promulgating an immediately effective 8 rule.
And I do not know what legal strategy we are going to 9 follow.
10 That is why my testimony said, you kncv, we are 11 going to do something and re do not know what.
12 C
Well, I notice, f or example, in the case of ATWS 13 that that has drug on for four years.
The staff has issued t
14 rules, but the resistance still continues.
There is no 15 reason to think it might not continue for some time in this 18 case too, isn't that correct?
17 A
It could continue.
This is a matter of legal I have not followed it.
I do not 18 strategy and I am not 19 know what we are going to do.
l 20 (Board conferring.)
21 BT DR. LITTLE:
(Resuming) 22 C
Because of the resistance by at least some segment
~
23 of the industry to putting in measurements of water 1evel, i
24 does the staff consider there az9 any other approaches which 25 will compensate?
For example, better training of operators, ALDERSCN REPCRTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTCN, D.C. 20024 (202) 554-2345 m
16032 1
more sensitive training?
2 Is there anythin7 that will compensate, in the 3 staff's view for not putting a water level indicator in?
4 A
I think the objections are sincere.
I think the 5 people that are concerned are concerned tha t --
a lot about 6 time.
I do not detect any undue concern about the cost.
It 7 is not a cheap system.
8 I think the concern is the fact they perceive a 9-short schedule, perhaps unduly prescriptive, and I guess a 10 sincere concern that the rush to judgment to put in a systen 11 that has not been f ully qualified and therefore would have 12 the potential to be aisleading.
That is how I view the 13 concern of those who have not yet committed.
I 14 Now, their concern may not be well-founded. It may 15 be if they would join the fold, so too speak,and talk with 16 the people who have experimented with these, then their 17 concerns would be allayed.
I do not know.
That is my 18 explanation f or the people who have not yet committed.
19 (Board conferring.)
20 Q
Where there is a serious disagreement between a 21 particular utility and the staff on this, is there any 22 seasure that that utility could take which would satisf y the 23 ' staff and allow that utility to continue operation for, say, 24 on a longer-tern basis?
Any kind of concensating action 25 that could be taken which would allow the industry or allow ALDERSCN REPCRTING CCMPANY. iNC.
400 VIRGINIA AVE. S.W. WASHINGTON D.C. 20024 (202) 554-2345
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the utility to be satisfied that before it devoted a lot of 2 resources to water level instrunentation, they voc3d be 3 warranted?
4 A
I think due to the acoustics I did no t get quite 5 all of the questien there.
I don 't know, should we get the l
G reporter to read it, o r can you --
7 Q
Is there any measure that a particular utility 8 could take to Duy time until it felt that it had adequately 9 explored the probles and conld make a reasonable judgment as 10 to whether the water level instrumentation could be 11 installed and would be usef ul in that particular plant?
12 CHAIRMAN SHITH:
This is in the longer-term, Dr.
13 Ross, as compared to the shorter term, which you have 14 already addressed.
15 THE WITNESS 4 Yes, I understand.
16 When we were addressing this problem in an 17 advisory paper that was prepared, we speculated on what to 18 do past January '82 if things were not goin g well.
And I 19 think, with added attention to detail of training and 20 procedures, using existing equipment and in consideration ef 21 a demonstrated good faith effort to try to, let's say, 22 continue down the seven-point program that Mr. Eaxter laid 23 out, that we would reccamend extending the deadline.
i 24 Tes, I do think there are additional short-term 25 actions along training and procedures that could continue to AL:ERSON REPCRT1hG COMPANY. INC.
400 VIRGINIA AVE., S.W WASHINGTON. D.C. 20024 (202) 554-2345
16034 1
be utilized.
I would not think it advisable to centinue fcr 2 the full 40-year license of the plar.t that way.
3 I think this is a thing we would have to nego tia te 4 on a case by case basis -- owner gro up by owner group basis, 5 just to see what the problem is and see if indeed they were 6 searching out the problems and trying to resolve it, as 7 contrasted with waiting for somebody else to come up with 8 the answer.
9 CHAIR 3AN SMITHS Anything further?
10 MR. CUTCHII:
I have a couple of questions on 11 redirect.
12 BEDIRECT EIAMINATION 13 BT MB. CUTCHINa 14 Q
Dr. Ross, during Mr. Baxter's questioning of you 15 regarding your reference to the Sequoyah incident of recen t 16 weeks or months, you indicated in response to a question 17 that, under the pressure and temperature conditions tha*.
18 prevailed at the time of that incident, that pressurizer 19 level indication alone was an adequate indicator of the core 20 being covered.
21 For the clarify of the record, would you indicate 22 whether pressurizer level alone is always an adequate 23 indicator of the core being covered, and under what 24 circumstances it does and does not?
25 A
Yes.
As I sentioned, for this plant as icnq as ALDERSoN REPCRTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
16035 1
the water was subcooled with respect to atscsphere, I vculd 2 not expect flashing.
The draining of the vessel in this 3 instance was from what is'known as the drop line, which is 4 connected to the hot leg or the cutlet leg of the reactor 5 coolant system.
It is thus imp ossible to pump varer out 6 below the hot leg, and if the water does not flash it is act 7 possible to blow it out.
8 Therefore, it is not possible, except by boiloff 9 due to decay heat, to bring the water level below the level 10 of the hot leg.
And since decay heat was restored in a very 11 few miputes, I would not expect any problem with uncovering 12 the core.
13 C
Hy question was more aimed -- let me ask it =cre 14 directly.
In a situation where the re was a break, a small 15 break occurred in the pressurizer at the top of the 16 pressurizer, such as occurred at THI-2 and there was 17 flashing in the vessel, would pressurizer level alone under 1
18 those circumstances he an adequate indicator of the cere 19 being adequately covered?
20 A
30.
21 C
One further question, a follow-up to Dr. Jo rdan 's ZZ questioning about the mode for core cooling following a l
23 small break LOCA.
If the only mode of ccre cooling 24 available was by feed and bleed using the safety valves and 25 the PCRY as the relieving device, is it possible te reduce AL::EASCN REPORT!NG COMPANY,INC, 4fC VIRGIN 1A AVE, S.W. WASHINGTCN. D.C. 20C241202) 554-2345
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pressure and temperature in the primary system to a range at 2 which the RHH system could be-brought into play?
3 A
No.
4 MR. BAXTEHs Th a n k yo u.
I have no further 5 questions.
6 MB. DORNSIFEa I have two short follow-ons.
7 CHAIREAN SEITH:
We have to allow some Eoard 8 time.
We need a substantial amount of Board time before 9 noontine today for other problems.
10 MB. DORNSIFE :
They will be very short.
11 RECROSS EIABINATION 12 BY MR. DOHNSIFE:
13 Q
In a small break LOCA scenario, where the top of 14 the core is approached, wouldn't the scenario show, first of 15 all, the vater -- either the hea ted thersoccuple or the 16 differential pressure seter, wouldn't this particular l
17 scenario show a gradual reduction in the level, and in fact 18 eventually it could show the level being below the top of i
19 the core, even though adequate core cooling was being 20 maintained?
21 In order for the operator to take action for 22 inadequate core cooling, he would still rely primarily on l
23 the core thermocouples for that point in making a decision, 24 is that not still true, even if those meters were 25 available?
I ALDERSCN REPORTING CCMP ANY. INC, 400 VIRGtNIA AVE., S.W., WASHINGTON, D.C. 20C24 (202) 554-2345
l l
46v37
/
1 A
I did not understand all of your question, but if 2 -- there are small breaks, say, in the line the sire of 3 three inches or so, where the water level dropped below th e 4 top of the active f uel for a while and then recovers, then,
[
5 depending on the time, sosq of the reactor vessel level l
l 6 would show a dropping ana some of the thermocouples might l
7 show a heatup and some might not.
8 It is hard to say until you are specific.
If all 0 equipment is working, then you would not want the operator to to diagnose inadequate core cooling.
You would want to let it' the sequence go to completion, no matter what instruments 12 rou were using for inadequate core cooling.
13 Q
But couldn't the core water level instruments, if 14 installed, show that the water level was below the top of 15 the core, when in fact it really was not?
16 A
In fact, it would do what?
l 17 Q
It really was not.
16 A
With the understanding that Dr. Jordan used on 19 froth level, which a lot of people call it good heat 20 transfer level, with that qualification, yes.
21 C
And if the operator on seeing the water level 22 meter below, indicating below the top of the core, if he 23 took action for inadequate core cooling, such as starting a 24 reactor coolant pump, couldn't that make the accident more 25 severe?
u ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON. D.C. 20024 (202) 554 2345
16038 1
A If eventually you postulated anouher failure, 2 yes.
3 Q
Just starting the reactor coolant pump rf itself 4 could not make it more severe?
5 A
No.
That would make it much more benign.
If you i
6 later -- if you can it, say, for another hour or some time, 7 and it' pumped more liquid out of the break, then had a 8 failure when the pump stopped, then 4.t would make it more 1
l 9 severe.
You are really compounding the sequence here.
10 0
Couldn 't sta rting th e reactor coolant pump i
11 distribute the ' rater differently in the systes?
The pump 12 would be turned off, it could collapse, and lead to a true I
13 uncover 7 of the core?
[
14 A
That is what I just said, yes.
15 C
Well --
16 A
I think I just so testified.
17 Q
Okay.
The example you used of a reactor vessel 18 multiple instrument tube rupture, you said that that is 19 different than a small break.
I guess I do not understand l
20 that.
21 Wouldn't injection water still be coming into the 22 bottom of the vessal and most of the water that was lost 23 would be injection water?
24 A
The water comes into the cold leg pipe, goes down 25 into the downconer, and by then it has lost its identity.
ALDERSoN REPCRTING CCMPANY,INC.
400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345
16039 1
All I am saying is, the rate -- when I said nultiple tubes 2 fciled, the water leaves at a certain rate which is in 3 excess of the high pressure injection rate.
4 Q
But you said the core thermocouples would not 5 necessarily work in that case, because flow would be down i
6 through the core.
And I am not sure how that would be 7 different f rom a small break LOCA on the cold leg.
8 A
Well, it may not be.
The flow would be down 9 within the core, and I indicated tha t it was not really 10 possible to characterize, without looking into details, how 11 the flow would be down.threich't the core and whether it
[
12 could be -- we have seen cases of thermal siphons where l
l 13 there would be internal core circulation, but a net i
14 downflow.
So the pattern of the thermocouples is pretty 15 complex.
16 C
Is it the staff's position that this level meter 17 needs to be safety grade?
18 A
No, it is not our position.
19
- 58. DORNSIFE4 I have no more questions.
20 CHAIHHAN SHITHs Anything further?
21 HR. BAITEHs Ye s, sir.
22 CHAIENAN SHITH:
Your exhibits?
23 MB. BAITER:
I was intending to offer them, but I 24 will offer those. exhibits now.
Licensee's Exhibits 34 1
1 25 through 43 I move into evidence.
ALDERSON REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W. WASHINGTCN, D.C. 20024 (202) 554-234S L
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CHAIHEAN SMITH:
If there are no objections, the 2 exhibits are received.
l 3
(The documents referred to, 4
previously marked for identi-5 fication as Licensee Exhibits t
Nos. 34 through 43, were 7
received in evidence.)
8 BY MR. BAITER:
(Besuming) 9 Q
Dr. Ross, during the examination by the Board I to believe you made the statement that in most LOCA's there is 11 inadequate core cooling, if I heard you correctly.
Wha t did 12 you mean by inadequate core cooling?
13 A
The core heat is up.
14 0
The core heat is up?
15 A
Yes.
I should have differentiated.
I dCn't mean 18 in the sense of triggering the inadequate core cooling 17 procedure.
That might have been misleading.
I meant the 18 core hea ts up.
19 Q
I forgot to ask you about one of the submittals 20 described on page 11 of your testimony.
One of the BEW 21 liceasees has selected a concept, you reported, hot leg 22 instrumentation.
Does such an instrument meet the 23 functional criteria set out in NUREG-0737 for this item?
24 A
We have not decided yet.
It is marginal, and the 25 last time I talked to the people on th a t th e y were not sure ALDERSCN REPCRTING COMPANY. INC.
400 VIRGINIA AVE, S.W, WASH 14GTON, D.C. 20024 (202) 554 2345
16041 1
what portion of the hot leg they were going to measure.
I 2 would not exclude it at this tine.
! vould like to discuss 3 it further with whoever proposes it.
4*
Q In the Board's examination, you said the Onaha 5 Public Power District's submittal ha s at least cne exangle 6 of what you consider to be reasonable progress; is that 7 correct?
8 a
Did you say Caaha ?
9 0
Yes.
10 A
Yes, I did.
11 Q
Now, when I asked you earlier in ny 12 cross-examination as to whether you could testify tha t the 13 other BCW licensees had made reasonable progress if ther 14 were in our situation today, you said you did not know or 15 rou could not reach that conclusion based on what you know.
l 16 And ycu said the same about the Combustion Engineering 17 plants that are still reviewing available options.
18 Is that still your testimony, having given this 19 example?
Do you --
20 A
I said some are reviewing and some -- ! do no t 21 recall what I said about Fort Calhoun.
I az sure I did not 22 say they were reviewing options.
l l
23 0
No, sir.
I sean,.of the CE plants you said -- ycu l
24 classified in your testimony are still reviewing
- tions, 25 which I think we classified were the two Calvert Cliffs l
ALOERSCN RUM')RTING COMP ANY,INC, 400 V'RGiNIA AVE, S.W. WASHtNGTCN, D.C. 20C24 (2023 554-2345
16042 1
units and the Palisades units.
2 A
Correct.
3 0
And the two BEW units, Davis-Besse and Fancho 4 SeCC.
5 Is it still your testimony that you cannot reach a 6 decision here as to whether or not those licensees have 7 shown reasonable progress, based on the Omaha Public Power 8 District example?
9 A
I have not -- 1 do no t believe the staff has the 10 level of detail that was described or contained in the Omaha 11 example that I gave.
We have not, in the ordinary course of 12 our business, tried to reach a reasonable progress decision 13 on the operating reactors, because that burden did not rest 14 on us.
15 We were looking sostly at an end date.
So ! do 16 not have formal positions there, as contrasted with here.
17 If I had the Oconee report in f ront of me, I could look at 18 it and say, this is an example of reasonable progress.
But 19 I do not, so I cannot.
20 0
Are you talking about some Oconee report other 21 than the letter we discussed today?
22 A
Yes.
23 0
Rave you given any more attention or tine or 24 effort in reviewing the THI-1 submittals than ycu have these 25 other licensees?
Do you know more about our position than s
ALOERScN REPORTING CCMPANY,INC, 400 VIRGINIA AVE, Sf#, WASHINGTON, DC 20C24 (202) 554 2Mi
16043 1
you do about the others?
2 A
I do not think so, no.
3 MR. BAITER:
I have no further questions.
4 CHAIREAN SMITHS Is that all?
Anything f ur th e r ?
5 ER. SAITER:
Not for the witness.
I do --
6 CHAIHEAN SEITH:
Anybody?
7 (No response.).
8 MR. BAITER:
I have some closing matters that do 9 not involve the witness.
10 CHAI35AN SMITH:
Ckar.
11 MR. BAITER:
I wanted to just remind the 3 card 12 that Mr. Keaten is going to answer the Board's outstanding 13 question to him about water level when he appears to sponser 14 his testimony on energency feedvater.
15 One other closing matter.
I as going te provide 16 the Board and would like the record to reflect that we are 17 providing the other parties here Licensee's response to 18 Intervenor Aamodt's filing of March 10 related to opera tor 19 fatigue.
20 CHAIRMAN SNITH:
Iou are exct' sed.
Thank you very l
l 21 auch, Dr. Boss.
I i
22
('ditness excused.)
i 23 5R. CUTCHIN:
Er. Chairman, could we have an 24 indica tion of what the Board's outstanding questien to Mr.
25 Keaten is, in the Licensee's view?
l ALOERSCN REPCRT;NG COMPANY ;NC, 400 VIRGINtA AVE. S.W, wASHINGTCN, O C. 20C24 (2C2) 554-2345 L
16044 1'
CHAIRMAN SMITH:
Yes.
Throughout Mr. Keaten's 2 testimony and Mr. Jones' testimony, both their testimonies, 3 they made the general point that unnecessary instrumentation t
4 is an undesirable, even if it has no -- it is just better
)
5 not to have it.
6 But they emphasized that it is specifically 7 undesirable in that it could lead operators into incorrect i
8 actions.
And it was my view that that -- he should lock at 9 that testimony and see if they presented a balanced to position.
I think you joined in the concern that the idea 11 that unambiguous information to lead a TMI-1 operator into 12 vrong actions was a disturbing thought and you would like to 13 have some elaboration on it, and so would we.
14 MR. CUTCHIN:
Quite so.
It is a question of, ar'e 15 they going so f ar as to say it is not only not desirable but 16 perhaps unsafe.
That refreshes my memory.
17 CHAIRMAN SMITH:e I just wanted him to see if they 18 really meant it to the extent I heard it, that we heard it.
I 19 MR. BAITEHa Mr. Chairman, I agree with your I
20 description of the outstanding question.
I would like to 21 put the Board and the staff on notice, however, that I would 22 also propose to ask Mr. Keaten to elaborate on his earlier l
23 testimony, which I asked Dr. Ross about today, as to the 24 efforts that the licensee has and is making to continue to 25 follow and evaluate water level instrumentation.
ALOERSCN REPCRTING COMPANY,INC, 400 VIRGINIA AVE S.W, WASHINGTON, D.C. 20024 (202) 554-2345
16045 t
CHAIRMAN SMITH:
I certainly think that is ycur 2 right.
3 H3. CUTCHIN:
The staff =ay wish to review that 4 additional testimony and then sake another statement as to 5 whether this indeed does go far enough to have the staf f S state that it does in its view show reasonable progress, if 7 that is the case.
If not, we would leave the record as it 8 is.
9 CHAIRMAN SMITH Sure.
Okay.
10 All right.
We will adjourn, then, until 10:00 11 a.a. March 24 12 (Whereupon, at 11:16 a.m.,
th e he a rin g was 13 recessed, to reconvene at 10:00 a.m.
on Tuesday, March 24, 14 1981.)
e e
e j$
16 17 18 19 20 21 22 23 24 25 ALCE95CN REPoATING COMPANY, fNC.
400 VIRG NIA AVE., S.W WASHINGTON. D.C. 20024 (202) 564-2.4 5
l l
,1a l
NUCLZAR REGULATORY C::.P. SSICN This is := certif/ that Ohe attached ;rectedings bef:re One
.]
in the satter o f:. METROPOLITAN EDISON COMPANY (TMI Unit 1)
Cata of Pr ceeding:
- March 20, 1981 Occket lit.
- ::ther:
50-289 (Restart)
Place of ?: Oceeding: Harrisburo, Pa.
were held as herein appears, and. cha: this is the crigt:2L trrisc:-i;;
- herecf fc.- the fil.a of the Cc==issice.,
David S. Parker Official Keperter (T/;ed.)
1 M.L L
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