ML20024C430
| ML20024C430 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/11/1983 |
| From: | GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-01, TASK-02, TASK-06, TASK-1, TASK-2, TASK-6, TASK-GB GPU-2349, NUDOCS 8307120619 | |
| Download: ML20024C430 (6) | |
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80 Civ.1683 (RO)
OFFER OF PROOF We would like to make an offer of proof for the record on the various points Mr. Marzec was prepared to testify on, but which were excluded by the Courts 1)
Mr. Marzec was prepared to testify that it a
l was customary in the nuclear industry before the accident for training responsibilities to be divided among the NSSS vendor and the utility; for' the vendor to provide advanced training, usually in the form of simulator training, on transient and abnormal situations; and for the utility to rely on the vendor to provide training, warnings and instructions on unusual or dangerous plant responses associ-ated with equipment within the vendor's scope of supply.
2)
Marzec was prepared to testify that the action of the TMI operators in throttling of HEI, and leav-ing it throttled, in response to the increase in pressurizer level was a reasonable and expected response based on and-reinforced by their B&W simulator training, procedures, limits and precautions and technical specifications.
3)
Marzec'was prepared to testify that the 4
operators' conclusion that low pressure was attributable ~
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to the condensation of the pressurizer steam space as a result of an insurge of relatively cold HPI water into the system was reasonable under the circumstances in light of their training, the circumstances in the control room at the time, and the complex calculations necessary to determine the effect of the particular thermohydraulic phenomena involved;.Marzec was also prepared to testify.
that under prevailing standards within the industry, operators were not expected to perform the types of calcu-lations which would have been necessary to make such a determination, particularly in the midst of transient situations.
- 4) ' The operators were reasonable, in light of.
the reinforcement provided by their misleading B&W simulator training, procedures, tech specs, and limits and precautions, in attributing the high pressurizer level they were i
experiencing to a large insurge of water from HPI, and, later, to a possible failure of the letdown valve, but not to a break at the top of the pressurizer on which they had received no training that would lead them to expect high pressurizer level in such a situation.
5)
The operators could not be expected to diagnose a stuck-open PORV on the morning of the accident based on the pressurizer system failure procedure because the symptoms listed in that procedure were masked by the e
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high pressure reactor trip; because the symptoms themselves are inadequate to distinguish between a leaking PORV, a stuck-open PORV, a PORV which opens and closes as designed, j
and a leaking, stuck or opened and closed code safety; and because the psf procedure fails to list increased pressurizer level as a symptom.
6)
The operators were reasonable in light of their training and the general state of knowledge prior to the ace,ident within the industry, including B&W, in expecting to temperatures of 400-600* in the PORV tailpipe with an open PORV and in attributing a tailpipe temperature of 285* to an opened and closed PORV.
7)
In light of the misleading reinforcement provided by their B&W simulator training, the operators could not be expected to diagnose a LOCA based on the LOCA 650 procedure provided by B&W because of the sharp ese in pressurizer level which the procedure and their training taught them was antithetical to the existence of a LOCA; furthermore, even if the operators were in the LOCA procedure, they would be expected, based on their'" training and the procedure, to throttle HPI based on pressurizbr level.
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Marzec was prepared to testify that the reference to " continued operation" in Section 3.2.5 in Part A of LOCA procedure referred to continued operation of the plant without tripping the reactor, cons,istent'with Section 2.2.5 of the procedure; Marzec was also prepared to testify that-the Section 3.2,5 was defective because it did not cover a,LOCA with pressurizer level up. and pressure down. -
9)
Marzec was prepared to testify that operators could not reasonably be expected, _i_n. light of their training and industry practice,.to perform.calcul'ati.ons.necessary to determine whether the RCDT rupture disc could blow based on a possible $[e'ning and closing of the PORV and code safety valves.
10)
Marzee was prepared to testify that event-oriented procedures, such as B&W's without the Dunn instruction, were inadequate to deal with multiple failures and were otherwise deficient compared to condition-oriented instructions, such as Dunn's, because of the difficulties in identifying events and the masking effect of certain symptoms in event-oriented procedures.
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Marzec was prepared to testify that before the accident, heatup-cooldown curves were generally used in nuclear plant operations for controlled heatups and cooldowns in o'rder to protect the integrity of the equip-ment and not as a means of detecting saturation in a transient situation or as a basis for HPI management.
12)
Marzec was prepared to testify that the operators acted reasonably, in light of their training, procedures and limits and precautions in shutting down the reactor coolant pumps based on excessive vibration.
13)
Marzec was prepared to testify that the operators acted reasonably based on their B&W training, procedures and specifications in raising the steam generator water level to 50% on the operating range and not higher after securing the reactor coolant pumps.
14)
Marzee was prepared to testify that the operators acted reasonably, in light of their training, procedures and the circumstances in the plant in securing the reactor building sump pumps.
15-)
Marzec was prepared to testify that the' operators'were reason'ble in believing that the code safety a
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16)
The operators reasonably relied on the PORV indicator light on the morning of the accident based on their training and procedures, including the general industry practice of training operators to believe their control room indicators, particularly in, transient situations.
In addition to the points enumerated above, Mr. Marzec was precluded from providing testimony in a number of additional areas, as to which the record already contains an adequate description of the testimony he was prepared to give and which should be considered a part of this Offer of Proof.
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