ML20054H532
| ML20054H532 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/22/1982 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8206240174 | |
| Download: ML20054H532 (175) | |
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NCPM REGULATORY COM!CSSICN ORIGIMAL iO l
O BEFORE THE ATOMIC SAFETY,AND LICENSING BOARD In the Mattar cf: :
LONG ISLAND LIGHTING COMPANY :
- DOCKET NO. 50-322-OL (Shoreham Nuclear Power Station) :
O CATE: June 22, 1982 PAGES: 4992 - 5166 AT: Riverhead, New York 3, pvg-i gol
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Q 400 vi_yd -+a Ave., S.W. W==H'_"g =n, C. C. 20024 Talachc=a: (202) 554-2345 8206240174 920622 PDR ADOCK 05000322 i T PDR
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4992 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION
() 3 BEFORE THE ATOMIC S AFETY AND LICENSING BO ARD 4 - - - - - - - - - - - - - - - - -x 5, In the Matter of :
6 LONG ISLAND LIGHTING COMPANY 4 Docket No. 50-322-OL 7 (Shoreham Nuclear Power Station) 8 -----------------x 9
10 Riverhead Town Hall 11 200 Howell Avenue 12 Riverhead, New York 11901 l
l 13 Tuesday, June 22, 1982 14 The hearing in the above-entitled matter 15 reconvened, pursuant to recess, at 10:40 a.m.
16 BEFORE:
17 LAWRENCE BRENNER, Chairman 18 Administrative Judge l
19 JAMES CARPENTER, Member l
20 Administrative Judge 21 PETER A. HORRIS, Member 22 Administrative Judge 23 WALTER H. JORDAN, Assistant to the Board O 24 Administrative Judge 25 l
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
4993 1 APPEARANCES:
2 On behalf of Applicanta 3 ANTHONY F. EARLEY, Esq.
4 W. TAYLOR REVELEY III, Esq.
5 T. S. ELLIS III, Esq.
6 DONALD P. IRWIN, Esq.
7 Hunton C Williams l
8 707 East Main Street 9 Richmond, Va. 23212 10 On behalf of the Regulatory Staffs 11 BERNARD BORDENICK, Esq.
12 RICHARD RAWSON, Esq.
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13 Washington, D.C.
14 On behalf of Suffolk Countys 15 LAWRENCE COE LANPHER, Esq.
16 K ARL A J. LETSCHE, Esq.
17 Kirkpatrick, Lockhart, Hill, 18 Christopher C Phillips 19 1900 N Street, N.W.
20 Washington, D.C. 20036 21 22 23 O 24 i
25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
4994 h 1 E 9. E T.,E E T_ E 2 WITNESSES : DIRECT CROSS REDIRECT RECROSS 3 George F. Dawe, George Garabedian, Pio W. Ianni 5
Robert M. Kascsak, Paul J. McGuire, 6 Paul W. Riegelhaupt and David J. Robare (Resumed) 7 By Ms. Letsche 5000 8
(Afternoon Session. . page 5055) 9 George F. Dawe, 10 George Garabedian, Pio W. Ianni, 11 Robert M. Kascsak, Paul J. McGuire, 12 Paul W. Riegelhaupt and David J. Robare (Resumed)
By Ms. Letsche 5056 14 15 l
16 E X H I B,I T S_
17 NUMBER IDENTIFIED RECEIVED Suffolk Coienty No. 19 5025 19 20 1 RECESSES:
! 21 Noon - 5054 23 Afternoon - 5111 0 2.
25 O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
4995 O i 2aasssa11ss 2 (10440 a.m.)
() 3 JUDGE BRENNER: Good morning. I am sorry we 4 are starting about ten minutes late, but considering the 5 logistical problems we had, I am surprised that it is 6 only ten minutes. I have a few preliminary matters on 7 my list this morning.
8 One was the status of LILCO's motions for 9 summary disposition and to strike with respect to SOC to 9. And Mr. Irwin this morning told me he had something 11 on that. -
12 BR. IRWINs Thank you, Judge Brenner. We 13 considered the Board 's suggestions relative to the 14 timeliness of those mo tions over the weekend, and have 15 concluded that on a balance, considerations of 16 maintaining the progress of a complex proceeding like 17 this -- it was suggested on balance that the withdrawal 18 of these motions was in the common interest of all the 19 participations of the proceeding. And I, therefore, 20 withdraw them.
21 And we appreciate the Board's concern with 22 this factor and will pay due heed to it in all future 23 filings. And we a pprecia te the guidance given on b'l 24 summary disposition motions henceforth.
25 JUDGE BRENNER: Okay. The next time maybe we
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ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
4996 O 1 should do that, and we can resoundingly deny thinos for 2 untimeliness, but obviously, we would prefer to do
() 3 things this way. As I au sure you reslize, we did 4 distinguish between the two motions.
5 We mesnt to snd apt arently did give the strong 6 implication that the moi. ion to strike stood a good 7 chance of being denied !!or timeliness since that motion 8 for summary disposition would have involved different 9 considerations; considerations which apparently were 10 recognized by LILCO, anil undoubtedly, SOC would have 11 recognized the same. That is, given the time it was 12 filed, how complica ted is it and could it have been 13 filed somewhat earlier or even auch earliet'.
14 MR. IRWIN4 Yes. I think you summarized the 15 considerations that we went into our decision. And' 16 also, Mr. Latham was apprised of this decision.
17 JUDGE BRENNER: Thank you.
18 Last week, we deferred any judgment on the 19 action to strike on Suffolk 28A-4, the display system.
20 The parties are going to see if, in fact, an agreement 21 is reached, and I assume we will hear sbout that as soon 22 as agreement is finalized. ,
Judge Brenner, we iave a draft >
23 MR. LANPHER:
() 24 agreement which we just have to run by one of the J 25 technical people and Mr. Irwin and I havd talked about ALCERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, o.C. 20024 (202) 554-2345
4997
() 1 it. I have not had a chance to discuss the exact words 2 with Mr. Shea, but he is here today and I think we can 3 probably have a resolution along the lines that were
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4 outlined isst Friday. We would expect to be able to 5 report to you tomorrow morning.
6 JUDGE BRENNER: Fine. I just wanted the 7 parties to realize we still had it on our deferred 8 list. On Thursday, I would appreciate it if the parties 9 would remind the Board that we should discuss how many 10 contentions cross examination plans should be filed on, 11 and when they should be filed. That is, those beyond l
12 the ones va have already scheduled.
l 13 On Friday af ter we recessed the on-the-record
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14 business and while meeting with counsel on another l 15 subject, I was informed thirdhand that counsel for l
16 intervenors in another case -- I believe it is the Byron 17 proceeding, I am not even sure of that -- had filed a 18 telegraphic request with this Board to cancel the 19 hea rings this week so that Mr. Hubbard and Mr. Hinor 20 could, as I understand it, prepare interrogatories in 21 the other case.
22 I did not receive the talegram, and it was 23 sent by Myron Cherry, counsel in the other case. He l
24 apparently did not send it to my secretary who I was in 25 contact with many times between Friday and today, and
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() 1 she had nevir received it. However, at 10:00 o' clock 2 last evening, Western Union did call me and read the
{) 3 telegram. It was -- even hearing th e telegram, it was 4 difficult for me to understand the circumstances.
5 The way I first learned about it on Friday was 6 through a call from the Appeal Board to inform me that 7 it had been filed, and I inferred, although did not ask, 8 that Mr. Cherry was covering his bets and also filed 9 some sort of request in Byron with the Appeal Board, 10 although I as not even sure of that fact.
11 In any event, obviously, we are not going to 12 postpone an evidentiary hearing so that interroga tories 13 can be filad in another case, without regard to whether (1) or not the excuse of this case is a legitimate 14 15 justification for what was argued in the other case or 16 not. I certainly have no idea because I do not know 17 what the timeframe involved was in the other case.
18 I did inform Judge Halperin of the Appeal 19 Board as to what our schedule had been in this 20 proceeding and what it was expected to be over the next 21 few weeks, including the break next week. He also asked 22 se if M r. Hubbard had been here every day, and I said 23 although it was a rare day when none of these three 24 principals were here, there were certainly days when 25 both of them were not here, and what else they were O
l ALDERSON REPORTING COMPANY,INC, l 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
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() 1 doing when they were not here I, of course, could not 4 2 state.
3 So, for formal purposes, as is obvious by our
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4 presence here, assuming standing to file within this 5 case, which is a big assumption, the motion is denied 6 and we are in session this week.
7 I do not plan any further transmission of that 8 ruling, and if HHB is concerned.. perhaps they can inform 9 Mr. Cherry, since they are apparently the only link 10 between that case and this case.
11 We have nothing else, and unless one of the 12 parties has something else, we vill proceed with the i 13 cross examination by Ms. LetsChe on systems interaction O 14 of LILCO's witnesses.
15 Whereupon, 16 GEORGE F. DAWE, 17 GEORGE GARABEDIAN, 18 PIO W. IANNI, 19 ROBERT H. KASCSAK, 20 PAUL J. McGUIRE, 1
21 PAUL W. RIEGELHAUPT and 22 DAVID J. ROBARE, 1
l 23 the witnesses on the stand at the time of recess, and 24 having been previously duly sworn, were examined and 25 testified further as fo11 ova
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( 1 JUDGE BRENNER: Excuse me, Ms. Letsche, I 2 guess I did have one other question. I received the 3 consolidated filing of emergency planning contentions a
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4 few moments ago. I have not read them, of course. We 5 were expecting to also receive the positions of the 6 staff and LILCO today, although we were somewhat 7 concerned as to the lack of advance notice to LILCO and 8 the staf f, as we discussed last week.
9 MR. REVELEYs You will receive something from 10 us later today, and it will suffer from the lack of fast 11 notice but it will summarize our position.
12 JUDGE BRENNER: The way things should proceed 13 hereaf ter with respect to emergency planning is that l () 14 there is a report due to the Board on July 6th, and we 15 are in session that day, and hopefully, that will have 16 the benefit of further discussions among the parties.
17 And the Board, therefore, would not issue a ruling on 18 the admissibility of the contentions prior to that 19 further report. We will, however, use the time to 20 become cognizant with the contentions and the 21 preliminary arguments.
22 Ms. Letsche?
l i 23 CROSS EXAMINATION -- Resumed
() 24 BY MS. LETSCHE ,
25 0 Good morning, gentlemen. I would like to O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554-2345
5001 1 direct your attention to Section 5 of your testimony on 2 7B which begins on page 56. I am going to be addressing 3 to you some questions regarding that section of your
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4 testimony.
5 I believe that portion was sponsored by Mr.
6 Dave, Mr. Robare and Mr. Kascsak, is that correct?
7 A (WITNESS ROBARE) Yes.
8 0 Er. Kascsak, have you personally been involved 9 in the conduct of any kind of systems interaction study 10 or analysis?
11 A (WITNESS KASCSAK) Well, I think that the 12 testimony enumerates the types of studies that we have g 13 characterized for the purpose of this testimony as l V 14 representing not necessarily a complete, but a l
15 comprehensive list of the systems interaction studies 16 that have been performed for this particula r plant.
l 17 My participation and the participation of 18 LILCO has been, in many cases, one of the review and 19 developing the criteria that went into the studies, in 20 concert with Stone & Webster and General Electric. In 21 most cases, we reviewed the results and were party to -
22 reach the conclusions of acceptability, as noted in the 23 final reports.
O 24 0 Have you personally ever constructed an event 25 tree or a fault tree to be used in the systems O
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() 1 interaction analysis?
2 A (WITNESS KASCSAK) I do not know specifically 3 what event trees or fault trees you are talking about.
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4 0 Any.j 5 A (WITNESS KASCSAK) Personally, I have not l 6 performed -- I have not actually put them together, but 7 -- also, again, as f ar as talking Shoreham, PRA, fault 8 trees and event trees were produced by a contractor, and 9 those event trees and fault trees were reviewed by LILCO to and LILCO's engineers for accuracy and completeness.
11 And we have gotten them, in a sense, validated by 12 engineers.
13 0 You said LILCO engineers have done that. Have 14 you don any of that?
15 A (WITNESS KASCSAK) Yes, I have.
16 0 You have reviewed some event trees and fault 17 trees in the SAR snd PR A?
18 A (WITNESS KASCSAK) Yes, I have.
19 Q Have you ever conducted a failure modes and 20 effects analysis yourself?
21 A (WITNESS KASCSAK) Well, I think you might be, 22 -- again, f ailure modes and eff ects analyses have been 23 performed for Shoreham. The actual studies were O 24 performed by GE or Stone & Webster, an,d LILCO has 25 reviewed those SLJdies and was party to the studies O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
9 5003 1 while they were being performed.
2 0 But you never performed one yourself, 3 personally?
4 A (WITNESS KASCSAK) As far as being the prime 5 organizstion developing the study, no. But we have 6 participated in those studies.
7 0 I am asking you personally. Your answer was 8 in terms of an organization. You personally have not 9 performed a study?
10 A (WITNESS KASCSAK) I personally was involved in 11 reviewing those analyses when they were performed.
12 0 And these are the FMEA analyses referred to in 13 your testimony in Section 5?
14 A (WITNESO KASCSAK) Yes.
15 0 Have you ever performed a walkdown that was 16 undertaken for the purposes of identify systems 17 interactions?
18 A (WITNESS KASCSAK) I personally have not, 19 although, again, walkdowns were a part of the Shoreham 20 PRA, as identified in our testimony.
21 0 But you did not participate in those walkdowns 22 personally?
23 A (WITNESS KASCSAK) I personally did not, O 24 although engineers that work for me and were under my ,
25 direction did participate in those walkdowns.
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( 1 0 M r. Kascsak, have you ever had any current 2 training with respect to the identification of systems 3 interaction?
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4 A (WITNESS KASCSAK) I think the training and 5 experience that people would accumulate in part as being 6 knowledgeable and curre14t in their knowledge about how 7 components operate and how systems function, those are 8 basic prerequisites for evaluating how a system might 9 interact. And they use that knowledge, that is brought to to bear to consider what type of systems interactions 11 may take place.
12 0 But you have not had any specific training in 13 event tree / fault tree analysis or FMEA analysis,'have 14 you?
15 A (WITNESS KASCSAK) I have had some training in 16 event trees and fault trees during some course of 17 participation I had as part of the preparation for 18 performing the Shoreham PRA. Myself, along with a 19 number of our engineers had a number of training 20 sessions with the SAI organization and they briefed us 21 on the methodology and, in a sense, went through a 22 training program to understand how fault trees and event 23 trees are prepared, so tha t we were knowledgeable in O 24 evaluating those when they were produced by them.
25 0 When was that training?
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() 1 A (WITNESS KASCSAK) I could not give you an 2 exact date at this point. It was prior to the report 3 being prepared.
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4 0 So it wa s some time in 1981 or 1982?
5 A (WITNESS KASCSAK) I would have to check.
6 0 It was after SAI had been been awarded the PRA 7 contract?
l 8 A (WITNESS KASCSAK) I was either right after or 9 right before.
10 0 And thst is the only specific training you had 11 in that area?
12 A (WITNESS KASCSAK) Other than, again, general 13 familiarity with the plant.
O 14 MR. ELLIS Would you permit the witness to 15 answer?
16 JUDGE BRENNERa Yes. You are. talking over 17 each other, both of you, to some extent.
18 MS. LETSCHEa I am sorry.
19 BY MS. LETSCHE (Resuming):
20 0 Other than the answer you had given previously 21 about the plant experience, --
22 A (WITNESS KASCSAK) Yes. As I said, the plant 23 experience is, in fset, a prerequisite for an 24 understanding of how different system interactions may 25 take place, and it is a necessary ingredient for O
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5006 1 evaluating them.
2 0 Mr. Robcre, have you personally been involved 3 in the performance of any failure modes and effects
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4 analyses?
5 A (WITNESS B0 BARE) Yes, I have. In my role as 6 licensing engineer in the Shoreham project, I have been 7 involved in various studies involving FHEAs.
8 0 Are those studies referenced in your testimony?
9 A (WITNESS ROBARE) Yes, they are.
10 0 Can you identify for me which of the 11 particular studies identified in Section 5 of your 12 testimony you personally were involved in?
13 A (WITNESS ROBARE) Study B on page 58. Study M l
14 on page 63. Those two.
15 0 With respect to Study E of the FMEA mentioned 16 there on page 58 of your testimony, was GE actually 17 involved in the performance of those FHEAs, or were they 18 involved more in the review?
19 A (WITNESS ROBARE) Those were performed 20 primarily by Stone & Webster, and GE was involved in 21 reviewing those FMEAs.
22 0 And you personally were involved in that 23 review?
} (WITNESS ROBARE) Yes, I was.
l 24 ,
A 25 0 Have you ever personally constructed f ault O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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O 1 trees or event trees for the purposes of systems l
i 2 interactions analysis?
3 (WITNESS ROBARE) I have not personally
{
r]) A 4 constructed event trees or fault trees for FMEAs. In my 5 role in licensing I am more involved in a review of the 6 engineering work and in the presentations to the 7 regulatory authorities. ;
8 0 Have you had any training in the performance !
9 of fault tree or event tree analysis, or the analysis of 10 the results of such methodologies?
11 A (WITNESS ROBARE) Just on-the-job training.
12 0 And by that you are referring to what you have 13 done, your review that you mentioned in your prior 14 answer?
15 A (WITNESS ROBARE) I am sorry, I have not had 16 formal courses in the subject, but I have worked with it 17 in the context of my licensing work.
18 0 Have you personally ever performed or been 19 involved in the performance of a walkdown conducted for 20 purposes of identifying systems interaction?
21 A (WITNESS ROBARE) I have been involved in some 22 walkdowns at the plant. They were not specifically 23 identified as systems interaction walkdowns, but they l
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24 were evalustions and plant reviews that could show a 25 systems interaction concern.
O ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
5008 1 Q Are any of them referenced in your testimony 2 on systems interaction in Section 5?
3 A (WITNESS ROBARE) Study H on page 59. I was 4 involved in the determination that a walkdown would be 5 advisable to assure the high energy line break study, 6 considered the actual plant configuration.
7 0 Were you involved in the actual performance?
8 Well, was a walkdown actually performed?
9 A ( WITNESS ROB ARE) Yes, it was.
10 0 Did you participate in the walkdown personally?
11 A (WITNESS ROBARE) It was last Tuesday, so I was 12 unable to.
13 0 Mr. Dave, have you ever personally perfccmed 14 an FMEA?
15 A (WITNESS DAWE) I have not been responsible for 16 performing FMEAs. I have worked with the engineers 17 producing the FUEAs in discussing with them the system 18 functions and operations and system logic as they were 19 developed in the fault trees for the FMEAs.
20 I also was involved in reviewing the FMEAs 21 from a conclusion point of view when they were prepared 22 and submitted for the Shoreham plant. I have also been 23 involved in additional FMEA work on the Shoreham plant 24 which continues to be ongoing, up until'this very time.
25 0 The FMEAs that you have reviewed or discussed, O
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() 1 are they referenced in your testimony in Section 57 2 A (WITNESS DAWE) Yes, they are.
3 0 Can you identify them for me, please?
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4 A (WITNESS DAWE) They are item E on page 58.
5 0 Have you ever personally constructed fault 6 trees or event trees?
7 A ( WITNESS DAWE) As I just mentioned in my 8 previous response, I have not been responsible for the 9 construction of fault trees, although I have worked with to the engineers who.were constructing fault trees, with 11 respect to system functions.
12 0 Have you had any training in how one performs 13 or how one reviews the fault tree / event tree methodology 14 or results from the application of the methodology?
15 A (WITNESS DAWE) I have had no formal training 16 in that area other than that which I have gained f rom 17 perf ormance of my duties at Stone E Webster.
18 0 Have you ever personally participated in a 19 valkdown performed for the purpose of identifying i
20 systems interaction?
l 21 A (WITNESS DAWE) Not with respect to any of the 22 particular studies that we have stated here. I have 23 spent a grea t deal of time in tha plant at Shoreham with 24 other engineers discussing certain aspects of the plant 25 f rom tim e to time. However, I am f amiliar with the O
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() 1 efforts Stone & Webster.has done over the years on 2 Shoreham, and I am familiar with walkdowns that have 3 been conducted by other engineers. And specifically,
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4 with the systems interaction in these studies in mind.
5 0 But you have not personally gone on any of 6 those walkdowns, is that right?
7 A (WITNESS DAWE) I did not personally conduct 8 the walkdowns that were done as f ar as any of these 9 studies which are in our testimony.
10 0 Can you tell me which of the studies mentioned 11 in your testimony involve the walkdowns that you 12 mentioned in your prior answer?
13 A (WITNESS DAWE) Yes. I personally an aware O 14 that the study A, piping failures and internal flooding, 15 called for walkdowns. Also, the cable separation 16 analysis report, item D, involved walkdowns. As Mr.
17 Robare has mentioned, I an also aware that iten H is 18 involved in walkdowns.
19 Q Those are the ones that began last Tuesday, or 20 the one that took place last Tuesday ?
21 A (WITNESS D AWE) That is right.
22 JUDGE BRENNEB: Mr. Dave, the one you gave 23 before was iten D as in Dan?
() 24 WITNESS DAWEa Yes, Judge Brenner.
25 For the remaining studies that Stone & Webster O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5011 1 has performed which are Shoreham-specific studies, I 2 have no personal knowledge of specific walkdowns that
() 3 were performed. However, I am familiar with the 4 individuals and organizations who performed those 5 studies, and I would assume that they used their 6 in-plant knowledge in the performance of those studies.
7 BY MS. LETSCHE (Resuming):
8 0 Mr. Kasesak, you mentioned a few minutes ago 9 that you have participated in some of the LILCO review l
10 of certain studies that have been done, and I believe 11 you specifically mentioned FMEAs. Are the things that i 12 you have reviewed referenced in your testimony in 13 Section 5 of the testimony?
14 A (MITNESS KASCSAK) Part of what has been 15 reviewed is included in this testimony.
16 0 To make my -- my question probably was not 17 very clear. What I want you to do, if you can, is 18 identify for me which of the items listed in Section 5 19 of your testimony you personally were involved in. And 20 I understand that your involvement with respect to the 1
21 systems interaction methodologies, or H to your report, 22 is limited to a review by LILCO results of these studies.
23 HR. ELLISa I am not sure whether that was a O 24 question or testimony by counsel.
25 MS. LETSCHE4 Let me start again, I am sorry.
O v
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() 1 JUDGE BRENNER: Let's try this. I am not sure 2 your characterization was accurate, because he testified
() 3 that his personal involvement was a review, but he did 4 not, I do not think, squarely state that LILCO's only 5 involvement was a review because he reviewed the work 6 with LILCO employees. Why don't you ask him the l
7 question Which ones were you involved with, and 8 describe your involvement as to each one he lists.
9 ME. LETSCHE That is a good suggestion, Judge 10 Brenner.
11 BY MS. LETSCHE (Resuming):
12 0 Mr. Kascsak , which of the items listed in this 13 portion of your testimony were you personally-involved 14 in reviewing, or were you personally involved in at all?
15 JUDGE BRENNER: A nd , M r. K a sc sa k , do not get 16 too hung up on the meaning of personally involved, 17 because I do not know what it means in the abstract, 18 either. As you go down each one, just describe the 19 involvement in your own words.
20 WITNESS KASCSAK I think it is important to 21 preface this response in a sense by saying that LILCO 22 was involved in the review of all of these studies. And 23 although I personally might not have been involved,
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24 there was someone from LILCO involved. In tha t respect, 25 LILCO's involvement was covered.
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( 1 Now, if your question is my own personal 2 experience as relative to each one of these studies, it 3 may be difficult for me to reflect back on every one in
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4 detail.
5 JUDGE BRENNER: M r. Kascak , I changed the 6 question in order to make it easier. I am sorry if you 7 got confused in that exchange. As to each item in 8 Section 5 of the testimony, describe either your 9 involvement or LILCO's involvement, if you have 10 knowledge of what LILCO's involvement was, even if it i 11 was not your involvement.
12 And I just want to make sure we get an 13 accurate description for the record, regardless of whose 14 involvement it is. If you know what LILCO's involvement 15 was, even if it was not you, you can at least 16 preliminarily tell us what that is, and I think that 17 would make it simpler.
18 WITNESS KASCSAKa The confusing part about l 19 this is that none of the studies are time-dependent l
20 studies. They were performed initially and they have, l
21 in many cases, been reperformed dependent upon the 22 plant. And as the plant is modified, certain studies 23 need to be modified.
l
() 24 The A, which is the pipe failure and internal l 25 flooding, which appears in the FSAR in Section 3.6,
()
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( 1 Appendix 3C, I personally wac involved in the 2 preparation of the initial Appendix 3C and its 3 evaluation of pipe failure and internal flooding when it
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4 was originally submitted in the FSAR. The report has 5 been updated a number of times.
8 In all cases, LILCO has participate in that 7 update. I personally have not been involved in every 8 single phase of the update, but I am generally familiar 9 with its results.
10 Item E, the missile study which includes 11 internal and external missiles, again, I was involved 12 personally in review of the FSAR Section 3 when 13 initially generated, and as project engineer, was 14 involved in discussions of various studies that were 15 prepared by Stone & Webster and GE to address this type 16 of phenomena.
17 Item C, the fire hazards analysis, I again was 18 involved in the initial review of the report. That was 19 prepared at the time I was LILCO project engineer, and 20 in that respect was required to sign off on that 21 document prior to its submittal to the NRC.
22 Item D, the cable separation study, the 23 significant part of LILCO's review was performed by 24 personnel who worked for me. I reviewed the thesis of 25 that document but did not review it in the depth that I O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D C. 20024 (202) 554 2345
5015 O i reviewed the previous items identified.
2 Iten E, failure modes and effects analysis, as
! 3 I have stated before, I was involved in the review of 4 those when they were initially generated. It is my 5 understanding the fact is that these FMEAs are being 6 updated at this juncture to reflect the plant as it has 7 been constructed, as it has been designed and 8 constructed. I am not personally involved in that 9 update, although again, engineers working in my 10 o rganiza tion a re, in f act, involved in that review.
11 Item F, which was a response recently prepared l 12 in conjunction with an SER open ites, I personally 13 reviewed that response prior to its being submitted to 14 the NBC, as did other engineers. working within my i
15 organ ization .
16 Items G and H, which I will combine since they 17 are both ongoing studies, and again, are in response to 18 SER open items. I have not been personally-involved in 19 the ongoing dialogue with Stone C Webster and GE on 20 these studies, but again, individuals who work within my 21 organization have been involved and keep me apprised of 22 those discussions as they develop. And many times, we 23 discuss the criteria and the methodology that is being O
d 24 used in the studies.
25 Item I which relates to probabilistic risk O
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() 1 assessments that have been performed on other BWR-4s or 2 6s to represent an evaluation of the design
{} 3 acceptability of the plant -- the only one of those 4 referenced that I have some familiarity with is the 5 Limrick PRA, and I have seen the Limrick report and have 6 reviewed it in some detail and, in fact, we have had a l
7 number of meetings with the Philadelphia Electric 8 Organization to discuss the results of their PRA, and to 9 do -- Well, I guess tha t is suf ficient.
10 Item J, the heavy loads, ahich again was a 11 response to an SER open item, I.was personally not l
12 involved in re vie w of th a t , but again, individuals who 13 work within my organization did review that response.
O 14 Item K, which is a discussion of how industry 15 experience will be evaluated by LILCO and how that 16 experience will be reflected in decisions on plant 17 operation and design, is an ongoing program. It is a 18 program that I am knowledgeable of, and in fact have 19 reviewed and participated in the generation of the 20 corporate procedures identifying this program. And I 21 personally have reviewed the specific procedures 22 associated with the working day-to-day activities of 23 that group.
24 Item L deals with the pre-operational startup 25 testing, and identifies how that testing evaluates the O
V l
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( 1 plans for potential system interactions. I have worked 2 closely with the LILCO startup organization, 3 particularly within my role as LILCO project engineer.
(])
4 Many of the individuals that currently work for me hnve 5 worked within the startup organization, and in fact, we 6 have performed certain tasks for the startup 7 organization relative to preparation of certain 8 specialized test procedures.
9 Iten M -- well, the next series of studies, M, 10 N -- well, let me say M, N and 0 -- I guess I could 11 characterize these as generic studies that were 12 performed by GE. I was personally not involved in those 13 studies, although I have seen copies of the studies as 14 they have been produced.
15 Iten P, which deals with the water level 16 instrumenta tion, evaluating the response of 17 Shoreham-specific water level instrumentation. I have 18 reviewed that report, and am familiar with its results, 19 and in fact, LILCO engineers were involved in evaluating 20 that particular interaction with the GE engineers.
21 BY MS. LETSCHE (Resuming):
22 0 You were not one of the engineers involved in 23 evaluating the interaction?
24 A (WITNESS KASCSAK) Yes, I was.
25 Q You were.
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l 5018 1 A (WITNESS KASCSAK) Item G is also a generic 2 study that was performed by General Electric to evaluate
() 3 the response of the BWR facilities, as an outgrowth of 4 the TMI event.
5 JUDGE BRENNER: Do you have item 0?
6 WITNESS KASCSAK Ites Q, yes. I was not 7 personally involved in that evaluation, although I have 8 seen some of the reports that identified the results of 9 that study.
10 And the last item, item 4, the Shoreham PRA, I 11 have been very actively involved in that program. My r 12 particular division has had the responsibility for the 13 management of that programs in fact, we prepared the 14 initial procurement documents, selected the contractors 15 that are performing the analysis and have, on s daily 16 basis, participated in the review of those results.
17 BY MS. LETSCHE (Resuming):
18 Q Mr. Kascsak, can you tell me what your 19 definition of systems interaction is, as you dse it in 20 Part 5 of your testimony?
21 A (WITNESS KASCSAK) I would state a simple 22 definition of systems interactions would be a set of 23 dependen t f ailures. In the context we have used it O 24 here, it is an interaction whereby a system or component 25 interacts with another system or component in such a way O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5019 O 1 ths t it may challenge its function.
2 0 When you say challenge its function, do you 3 sean either make it inopera tive or degrade its f unction?
(])
4 A (WITNESS KASCSAK) As part of the evaluation, 5 you would evaluate the extent of the interaction and 6 evaluate whether the interaction was acceptable or 7 unacceptable.
8 0 But your definition which says it is an i
9 interaction whereby a function would be challenged --
10 what I an asking for is what you mean by challenged. Do 11 you mean by that -- well, what do you mean by the words 12 " challenge its function."
13 A (WITNESS KASCSAK) Simply that there is an 14 interaction there whereby the one system or component 15 interacts in such a way as to possibly affect, as I say, 16 possibly af f ect the function that the other system was 17 intended to perform.
18 0 So any effect of the function on the other 19 system caused by s separate system or component would 20 constitute a systems interaction? Is that a correct 21 statement of your explanation?
22 A (WITNESS KASCSAK) Yes. I think it could be 23 broader than that in terms of what potential O 24 interactions may be. Interaction is, as I say, a 25 dependent activity, so you would have to evaluate what O
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() I that activity may be. It may be a spatial interaction, 2 it may be a functional interaction, it may be a human 3 interaction. So you would have to evaluate the type of
[]}
4 interaction that you are considering and evaluate the
! 5 effect of that interaction on the function of what it is 6 interacting wi th .
7 0 In your opinion, is an analysis of systems l
8 interaction. helpful in determining the importance or the 9 significance of a component or a system to the safe 10 operation of a plant?
11 (Panel of witnesses conferring.)
12 A (WITNESS KASCSAK) I think I would like to hear 13 the. question again.
O 14 0 I will repeat it for you. In your opinion, is 15 the analysis of systems interaction helpful in 16 determining the importance or the significance of a 17 component or a system in the safe operation of a plant?
18 A (WITNESS KASCSAK) The consideration of 19 interactions is part of the design process, and in that 20 respect, those considerations are made during the design 21 and the maintenance of the classification of a 22 particular system.
23 A ,
(WITNESS DAWE) If I could add to that answer 24 just briefly, I think that that may be a somewhat 25 reversed description of the process or the significance O
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5021 O i of systems interactions to c1assification. tar 1y 2 classification of systems and knowledge of 3 classification systems are particularly usef ul f or the 4 designers for the interactions between systems that 5 would be acceptable. And in fact, I think that it is 6 true that functional interactions are particularly 7 well-identified and avoidable by knowledge of the 8 initial classifications of your systems.
9 Perhaps what is more difficult is spatial 10 interactions. When the plant is being constructed there 11 will always be limited volume in a plant to put in the 12 various components and systems that perform various 13 functions within the plant. I think that interaction 14 studies as done for Shoreham are a very valuable thing.
15 But the existence of the studies or the fact 16 of systems interactions would not necessarily lead to a 17 need to change classification. Certainly, it would tell 18 you the importance of things in the plant and would i
l 19 identify the difficu1 ties that you might have with the l
20 design, particularly spatially. As I say, the 21 functional interaction in the design process is much 22 easier to view and to avoid.
23 I think in that regard, yes, systems 24 interaction studies are useful, but I do no t think that 25 they are a leading factor. I think that they are a O
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() 1 verification factor.
2 (Counsel f or Suff olk County conf erring. )
3 0 Nr. Kascsak and Mr. Dawes, you also answered
(])
! 4 that last question -- setting a side classifica tion , I 5 assume from your answer that you would also agree that 6 systems interaction analysis, or looking at the systems 7 interactions questions, would also be helpful in 8 determining the reliability of components or systems in I
9 the plant. Is that correct?
l 10 (Panel of witnesses conferring.)
11 A (WITNESS DAWE) I think tha t if you look at a 12 specific component's reliability, the inherent 13 reliability of the component, I do not see the
() 14 connection that you are suggesting there in terms of t
15 reliability of the plant.
16 It would be my opinion that, again, the 17 reliability would be the driving factor, and not the 18 systems interaction. If there were an interaction to 19 exist, for example, the types of things we have studied 20 here, just as an example, pipe break which is 21 reliability of the piping, it is the reliability that is 22 going to determine whether you have the event, and then 23 a subsequent interaction. It is not the interaction 24 tha t is going to d etermine the reliability of the pipe.
25 Certainly, the overall conservatism of the l
(
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() 1 design is demonstrated and enhanced by the performance
! 2 of these studies.
l 3 Q Mr. Kascsak, in one of your earlier answers
{;
4 you mentioned dif fe rent types of systems in teractions.
l 5 Wha t different types of systems interaction are there?
i 6 A (WITNESS KASCSAK) Well, I think I stated 7 previously that in the broad sense of types, there are 8 spatial interactions, functional interactions and human 9 interactions. And in your evaluation of an interaction, 10 you would look for these and evaluate their role in the 11 performance of a particular system or component.
12 A (WITNESS DAWE) If I could add, there are
- 13 further refined definitions of types of dependencies in 14 Attachment 5 to our pre-filed testimony that are used by 15 the PRA methodologists in defining it. But I would 16 agree with M r. Kascak that it is easily understood that 17 there are such things as spatial, functional or human l
18 interactions, and I think that the more detailed 19 definitions in the attachment to our pre-filed testimony 20 are forms of those three.
21 Q Mr. Dave, are you familiar with the systems l 22 interaction study, State-c,f-the-art review and methods i
I 23 evaluation performed, by the Lawrence Livermore O 24 Laboratory for the NRC7 It is -- I can give you a copy 25 of it to look at. It is NUEEG/CR-1859, published in O -
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, g 5024 4
h 1 January of 1981.
2 /
9 4 5
6 7
8 9
10 11 12 13 '
@ 14 ,
15 16 17 18 19 20 -
21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRG'NIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554-2345 l
5025
() 1 MR. ELLIS: May we also have a copy?
MS. LETSCHE 2 Yes.
1 3 (Counsel handing document to witnesses and
(])
4 counsel for Applican t and Judge s. )
5 MS. LETSCHE Judge Brenner, I would like to 6 have this marked for identification as Suffolk County 7 Exhibit 19.
8 JUDGE BRENNER All right.
9 (The document referred to 10 was marked as Suffolk 11 County Txhibit No. 19 for 12 identification.)
13 WITNESS DAWEs Ms., Letsche, do you have a full O 14 copy of the document from which this study is dravn?
15 MS. LETSCHEa Yes, I do.
16 JUDGE BRENNER: And Mr. Dave has reminded me, 17 you should identify what it is you are marking since you 18 have not yet.
19 MS. LETSCHEa I was going to do that.
20 HR. ELLIS Also, if the witnesses are going 21 to be asked questions I would reques t that they be given 22 the whole copy.
23 MS. LETSCHE: I am going to give to Mr. Dave a
( 24 copy of the entire report, and I will state for the 25 record that what I have had marked for identification as O
ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W, WASHINGTON, D.C. 20024 (202! 554 2345
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5026
() 1 Suffolk County Exhibit 19 is just certain pages of the 2 entire report. They are pages xvi through xix -- that i
() 3 is, little Roman 16 through 19 -- and page 53 of th a t 4 report.
! 5 And I will also note for the record that this 6 entire report was cited in the LILCO testimony in three 7 separa te portions of the testimony of Mr. Joksimovich 8 and Mr. Burns.
9 MR. ELLIS: Those are the PBA witnesses, 10 Judge, and not these witnesses; and if there are going 11 to be questions on it, it seems to me appropriate to 12 reserve it for those witnesses rather than for these.
13 JUDGE BRENNER: Mr. Ellis, she can ask 14 ' questions on it if she wants, and we will see where it 15 goes. You are premature.
16 MS. LETSCHE Thank you, Judge Brenner.
17 WITNESS DAWEs Ms. Letsche, in response to l 18 wha t I believe is your outstanding question, I have not l
19 personally seen the study nor had time to review it.
20 BY MS. LETSCHEt (Resuming) 21 0 okay. I would like to direct your attention 22 to page 16, what is marked as page 16 of Suffolk County 23 Exhibit 19 for identification.
24 A (WITNESS DAWE) It is Roman numeral 167 25 0 Yes. And beginning on that page and l
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() 1 continuing over onto the next page there is a list under +
2 the hearing "Important Classes of Systems Interactions,"
3 and it lists the five groups of systems interactions. I 4 would like you to review those five groups and tell me 5 if you would not ag' ee with me that those five do fall 6 into the three categories you gave me of functional, 7 human and spatial interactions, perhaps in more detail 8 than those three general categories you have given me.
9 A (WITNESS DAWE) That is going to take us a 10 moment, Ms. Letsche.
11 (Panel of witnesses conferring.)
12 JUDGE BRENNERt Ms. Letsche, while they do 13 tha t -- and we will certainly give them a moment -- it O 14 would be helpful if you listed at least the five 15 headings for the record at this point. It also would 16 have been helpful if you would have told them in advance 17 that you were going to ask this question and handed this 18 out in advance. But let us proceed with reading the 19 titles.
20 MS. LETSCHE: The five titles that are listed 21 in this exhibit are, one, common mode failures 22 propagated through reactor support systems; two, common 23 mode failures due to shared environmental conditioss
() 24 three, latant human errors and inherent problems; four, 25 dynamic human errors; and five, failures that result O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 ,
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5028
() 1 from reactor degradation.
2 BY MS. LETSCHEa (Resuming) 3 0 Mr. Dawe, I know you are reviewing this, and I
(]}
4 do not want to cut off your review, but let me see if I 5 can ask a specific question that might help you. I 6 think my other one was very broad and general.
7 Would you agree with me that --
8 A (WITNESS DAWE) I would like time to review 9 the document you have handed me, Ms. Letsche, plea se .
10 0 All right. Fine.
11 (Panel of witnesses conferring.)
12 JUDGE BRENNER: Are any of the other six 13 witnesses of the seven witnesses on the stand familiar
()
l 14 with this document?
( 15 WITNESS IANNIs Briefly. I am somewhat
( I have seen it before, but I have not 16 familiar with it.
17 studied it in detail.
l 18 (Panel of witnesses conferring.)
1 19 JUDGE BRENNERs Ms. Letsche, I hope this is a 20 more important question than I can perceive.
21 MS. LETSCHE: Judge Brenner, I was trying to l 22 shorten things by indicating to the panel what I wa n ted 23 to ask, and they indicated they did not want to hear I O 24 that until they reviewed the document.
25 JUDGE BRENNERs Well, I will not repeat my O
I ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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5029 i
() 1 earlier comment -- well, I will repeat it -- that they 2 should have been given the document earlier.
{) 3 WITNESS DAWE4 We have had a chance to review I am not sure if we have an outstanding question 4 this.
5 at this point.
6 BY MS. LETSCHEs ( R esumi ng) 7 0 What I was going to ask you is would.you agree 8 that the category " Common mode failures propagated 9 through the active support systems," as that is defined to in this document, is included within your category of 11 functional systems interaction?
12 A (WITNESS DAWE) With an initial readits of 13 this I would state that the first category appears to be O 14 a description of functional. There may be in all of 15 these categories some overlap that we have not had a 16 cha nce to really identify or think about. But the first i
t 17 would appear to be functional interactions.
18 0 And would you noree that the second category, 1
19 that is, " Common mode failures due to shared 20 environmental conditions," corresponds pr.tarily to your 21 category of spatial interactions?
22 A (WITNESS DAWE) Yes. The second category 23 appears to be addressing spatial interactions.
24 0 And the third category, identified as " Latent 25 human errors and inherent problems," would you agree O
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( 1 that that is a subset of what you would have classified 2 as human interactions, that would be included within 3 your human interactions category?
(]}
4 A (WITNESS DAWE) That one is a little difficult 5 to categorize. It certainly would include potential 6 human interactions. There may be other types of 7 interactions that could result from some of the 8 descriptive phrases here, but basically it appears to be 9 human interactions as we understand them.
10 0 Would the other types of interactions that 11 might be encompassed in the tabulation here be included l 12 in one of your other areas of interaction like either 13 functional or spatial, or is there a separate category 14 that you think is being identified here?
15 A (WITNESS DAWE) No. I think it would be 16 overlapping to the other categories.
17 0 The next category , that is, " Dynamic human 18 errors," I assume that is within your human interactions 19 category, is that right?
20 A (WITNESS DAWE) Yes. I would say that tha t 21 would be in our human category.
22 0 And the last category, that is, " Failures that 23 result from reactor degrada tion ," would tha t ,f all into l C) 24 your functional category?
25 A (WITNESS DAWE) Not necessarily. In fact, I I
()
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() 1 think looking at conditions 3 and 4 it might likely be 2 more spatial than f unctional.
{} 3 0 Would you agree with me, though, Mr. Dave, 4 that in fact there are five types of interactions, 5 systems interactions identified here in this document 6 even though they are -- some of them are subsets of some 7 of the three broader categories you have given us?
8 A (WITNESS DAWE) It is as plain as I can see 9 that the authors of this document have listed five 10 dif f erent ty pes. That is their opinion of the way they 11 wanted.to break them down for the purposes of their 12 study. I have not reviewed the study, and I do not know g, 13 wha t use to make of these definitions in the rest of the U
14 study.
15 0 I really am not asking for that. All I was 16 asking you was whether or not you would agree that these 17 a re dif f erent types of interactions that the authors of 18 this study have identified, and that they in fact are 19 types of interactions that exist.
20 A (WITNESS DAVE) I am not sure that there was a 21 question in all of that. I understand from looking at 22 two pages placed in front of me that the authors of this 23 study have identified five classifications or 24 categorizations of potential interactions, yes.
25 0 Well, do you disagree that any of these O
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINTA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5032 1 categories constitute types of interactions? I mean do 2 you believe that some of these do not?
3 A (WITNESS DAWE) No, I do not believe that 4 these do not constitute interactions.
5 0 So you agree that they do?
~
6 A (WITNESS DAWE) This is one way of sorting 7 them.
8 0 That is all I want.
9 A (WITNESS DAWE) I might also state that in 10 reviewing these I do not see any in here that I am not 11 svare of having addressed on the Shoreham design.
12 0 I assumed that was right. That is why I was 13 tr.'ing to relate these to the categories that you had O 14 identified.
15 Can you -- and I will address this to the 16 panel -- identify for me or tell me what techniques 17 there are in your opinion that are available to evaluate 18 systems interactions? I know you have listed a number 19 of different systems interactions, what you identify as 20 system interaction studies, tha t have been done at 21 Shoreham.
22 I would like for you to tell me what types of 23 techniques there are to evaluate or to identify systems 24 interactions.
25 (Panel of witnesses conferring.)
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() 1 A (WITNESS DAWE) The types of studies that are 2 shown in our testimony that we have performed all
{} 3 involve what we consider to be valid methods of 4 reviewing 1 design for system interactions, and I think 5 thoce methods are pointed out in our prepared 6 testimony. And if any of the panel members want to add 7 to that --
8 A (WITNESS IANNI) I think that a method we 9 never talk about is one of experience with the same kind
. 10 of design over and over. Systems interactions are not 11 new, and I think you would find some hesitancy on our 12 parts because as engineers it is sort of built into us 13 to look out for systems interactions.
14 Way back in the mid '60s I used to go to the 15 reactor we were building and find things I did not 16 like. Things were hanging over some system or some 17 control cable was lying across the floor, things of this 18 sort. You just naturally look out for things like that.
19 I think what is happening now is these people 20 have come up with a way of identifying different means 21 that can be used, but I do not think right now from wha t 22 I have seen of the literature that there is a generally 23 accepted good way of saying I have done a systems 24 interaction study and have found all of the systems 25 interactions. I think we are still struggling with that
()
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() 1 ss an industry. We are trying to find a good way of 2 doing it.
(} 3 I think the methods that these people suggest 4 are okay, but I do not think they are the only ones.
5 And I think PR A, in my book, comes out as one of the top 6 ways of doing it.
7 I want to emphasize, though, that when you 8 have a system that you build over and over that nature 9 tells you when you have got a bad system interaction 10 unless they are extremely improbable. And the other 11 part of it that smokes out systems interactions is the 12 interdisciplinary design reviews. For example, last 13 week I was on a design review in which we discovered a O 14 potential for a reactivity excursion which the people 15 working on the systems had not paid that much attention 16 to. They had to go back and take care of that. ,
17 Another example where we find things by 18 interdisciplinary design reviews was in air being sucked 19 into the ECCS lines potentially by the discharge of the 20 SRVs. And people had to go back as a result of that and 21 do studies to make sure air would not be injected into 22 the ECCS lines. We find things, for example, like we 23 found out that loss of offsite power impacted on the
( 24 display in the AVRMs, and so we put those on ancillary 25 power.
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() 1 And so as a result of all of this accumulated 2 experience, there is not any single way of determining
{} 3 systems interactions. I think we are marching to wa rds 4 eventually finding a method, but I do not think we are 5 yet. And any of these techniques are probably pretty 6 good. I am sure there are going to be others. I do not 7 think there is any single way that we will ever assure 8 you you have got all of the systems interactions that 9 could conceivably occur.
10 And you have to depend a great deal on the 11 engineer and his common sense and his savvy and his 12 experience and the design procedures that we used. And 13 we emphasize separation and we emphasize redundancy, and O 14 we have independence, especially on the BWB. I want to 15 emphasize the independence where we have gone out of our 16 way not to mix up nonsafety systems and safety systems.
17 We have kept then separated from day one, and where you 18 cannot avoid having some interconnection like between 19 control systems, we.have isolators between them. In the 20 nonsafety systems and the safety systems we try to keep 21 things separated. And if you follow that common sense 22 approach to it, then when people do come in and do a 23 perfect stady, if you want to call it that, then you 24 will find you have dodged all of the significant ones.
25 And if you have not dodged the significant ones, then O
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5036 O 1 nature is going to tell you if you have operated that 2 kind of plant for any length of time unless it is the Q 3 statistically extremely low probability.
4 5
6 7
8 9
10 11 12 O 14 15 16 17 18 19 20 21 22 23 O 24 25 O
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() 1 A (WITNESS KASCSAK) I would like to make a 2 statement relative to the processes that are involved 3 here, and I think th ere is, in a sense, two distinct
{])
4 processes. We have a design process whereby through the 5 initial design of the plant and the involvement of the 6 engineers and engineering procedures, inherent in that 7 program is an evaluation of interactions, and an effort 8 to insure that no unacceptable interactions take place.
9 In addition to that, there is the assessment 10 process whereby we evaluate through other methods, the 11 PRA being one of them, that in fact, the plant as 12 designed and built possesses no unacceptable 13 interactions. And this is somewhat of a verification or O 14 assessment of the design process. It complements the 15 design process and some of these studies fit into both 16 of those categories.
17 Q Hr. Kascsak, with respect to the second 18 category you were talking about, the assessment process 19 of evaluation, that would included wouldn't it, reviews 20 of operating experience? That is one of the things you 21 have listed in your testimony as a technique, is that 22 right?
23 A (WITNESS KASCSAK) That is right.
24 Q And it would also include techniques such a i
25 failure modes and effects analysis, isn't that right, as O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5038 O i pert of the assessment 2 2 A (WITNESS DAWE) Failure modes and ef fectc 3 analysis is certainly an as sessmen t process, but they 4 are also part of the desiga process.
5 Q That is fine. Then it also includes, as you 6 mentioned, the PRA, which would be fault trees and event 7 trees and the analysis of that. Is that right?
8 A (WITNESS KASCSAK) Our startup and 9 pre-operational test program is a program where we 10 assess the response of the plant, and we evaluate its 11 response against pre-determined events. And if the 12 plant responds in a way different than predicted, we 13 will evaluate that response.
O 14 JUDGE BRENNER: Excuse me, maybe I missed 15 something, but I did not Lear an answer to your question 16 with respect to the PRA.
17 MS. LETSCHE I thought he said yes.
18 WITNESS KASCSAKs Haybe I did not hear the 19 question.
20 BY MS. LETSCHE (Resuming):
21 Q I said a PRA would be another assessment 22 method that you had mentioned.
23 A (WITNESS KASCSAK) Yes, that is true.
24 Q Mr. Kascsak, I would like to direct your 25 attention to pages 17 through 19, these are Roman O
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() 1 Numerals XVII through XIX that have already been marked 2 as Suffolk County Exhibit 19 for identification, and ask
(} 3 4
you if you would agree that this does identify -- that there are identified here different techniques for 5 e valua ting or for assessing -- I think is your word --
6 systems interactions.
7 JUDGE BRENNER: Hs. Letsche, if you want them 8 to read two and a half more pages, let us come back to 9 that, and tney can read it over lunch.
10 MS. LETSCHEa All right, that is fine, Judge 11 Brenner.
12 JUDGE BRENNER: And during the break, if you 13 are going to want them to read anything else from this O 14 document or any other document for which you do not feel 15 you need the element of surprise, -- you are certainly 16 entitled to reserve that -- but other than that, let's 17 see if we can work out the logistics.
18 HS. LETSCHE: I would like the panel to review 19 this entire document which has been marked as Suffolk 20 County Exhibit 19. There is not much more to it. And 21 we will come back to that after lunch.
22 JUDGE BRENNER: We will break around 12:15, if 23 that will assist your planning, Ms. Letsche.
24 BY HS. LETSCHE (Resuming):
25 0 I would like to discuss a little bit your O
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() 1 first study that is described in your testimony, 2 gen tlem en; that is, pipe failure and internal flooding.
3 Am I correct that these were, in fact, two separate
(])
4 studies done, one on pipe failure and one on internal l 5 flooding?
6 (Panel of witnesses conf erring. )
7 A (WITNESS DAWE) I am sorry, Ms. Letsche, could l
8 you repeat your question, please.
9 0 Whether there are two separate studies 10 referred to in this portion of your testimony.
11 A (WITNESS DAWE) There were a number of studies 12 referred to in this portion of the testimony.
13 0 Okay. Can you tell me what they were, or what 14 they are?
15 A (WITNESS DAWE) Pipe failure studies on this 16 plant began in the early 1973 timeframe. I nitial 17 studies were directed toward high energy line break 18 studies outside of containment. High energy line break 19 studies inside of containment as part of the design 20 basis accidents had been looked at earlier. In 21 addition, high energy line breaks were done in more 22 detail in the early 1970's inside the containment.
23 At the time that was being done, internal 24 flooding was being studied as a separate study for 25 potential flooding sources within safety-related areas O
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( 1 of th e pla n t . These studies have all essentially been 2 drawn together because it turns out that the primary
() 3 internal flooding source is a line failure, either high 4 energy or moderate energy crack.
5 Those studies have been done and redone and ;
1 6 revised. They have been checked as plant design changes 7 have occurred. I would characterize them now as 8 e ss e r. '.ia lly the same study, looking at different aspects 9 of the consequences of piping f ailure and line cracks.
10 0 These were done in response to a regulatory 11 requirement? Is that right?
12 A (WITNESS DAWE) Well, they certainly are 13 regulatory requirements. Some aspects of the studies C:)
14 are done to our good engineering judgment as opposed to 15 a specific d efinition of a study that may have been 16 proposed in a regulatory guidance document, such as a i
17 branch technical position, which do exist relative to 18 these types of hazards in the plant.
19 Other portions of the studies, for example, 1
20 flooding, is always a concern in the design process, at 21 least in terms of the way things are arranged in the j 27 plant. But yes, the studies, pipe failure psrticularly, 23 are responsive to regulatory requirements. That makes 24 it no less part of the design process, however.
25 Q Did the NRC requirements also identify what O
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5042 O i etees of the p1 ant the pipe fa u ure study had tocove?
2 A (WITNESS DAWE) Area-wise I am not aware that 3 any of the NRC documents specify what area of the plant 4 to be studied. In fact, Shoreham has been studied in 5 all area of the plant for these effects and these causes.
6 0 Does the NRC identif y particular systems that 7 have to be studied? I guess my question iss was the 8 scope of the study primarily defined by the regulatory 9 requirement?
10 A (WITNESS DAWE) The regulatory guidance 11 documents do define certain categories of lines for 12 considerations for example, high energy and moderate 13 energy lines. The regulatory guidance documents do not, O 14 to my knowledge, discuss the scope of the study that you 15 do beyond that type of a definition in terms of which 16 area of the plant you look at.
17 As I mentioned before, we have considered all 18 areas of the plants in these studies, but obviously, 19 some areas of the plant are much simpler to do than 20 other areas of the plant, because of wha t is contained 21 in that area of the plant and what might be potentially 22 impacted by a line failure in that area of the plant.
23 Q Did these studies include conrideration of the 24 pipes in the turbine bui1 ding?
25 A (WITNESS DAWE) Yes, they did. However, the O
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() 1 turbine building area is not as difficult an area, for 2 example, as the remetor building or the control building.
3 Q Am I correct that Stone E Webster did these 4 studies?
5 A (WITNESS DAWE) Yes, Stone E Webster did these 6 studies.
7 Q Somebody men tioned earlier -- and I don 't 8 remember whether it was you or Mr. Robare -- that there 9 was a walkdown or walkdowns conducted in connection with 10 these studies. Can you describe for me the walkdowns 11 that were conducted in connection with these studies?
12 A (WITNESS DAWE) I as personally aware of 13 walkdowns conducted with the pipe break study in some O 14 specific areas. What I had in mind when we talked about 16 that earlier for the pipe break studies, we developed 16 shutdown models which are described in the FSAR.
17 As part of those shutdown models, we looked a t 18 the automatic protection and anticipated operator 19 actions following pipe breaks. We were particularly 20 concerned in the study with the impacts on instrument 21 lines in the plant. Instrument lines are kind of a 22 network throughout the plant that you must be careful 23 of. And we, in the study, identified for each type of 24 break and location of break and for each of our shutdown 25 models, instrument lines that would be necessary for the O
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() 1 shutdown model that we were relying upon for mitication 2 of that break action.
3 And those instrument lines were walked in the plant 4 by the instrument engineers with knowledge of the break 5 location and the dynamic effects of the zones of 6 influence for the breaks, to assure that the instrument 7 lines we were relying on would be available to us. So 8 that, for example, is a walkdown that was conducted 9 relative to these studies.
10 JUDGE BRENNER: Mr. Dave, I have been 11 wondering about something, and if Ms. Letsche will 12 permit me, maybe this is a good time to find out. Can 13 you describe for me what is done on a valkdown?
O 14 Obviously, people are there to look at things, but can 15 you give me a little bit more detail? Some of the 16 considerations I have in mind are actual measurements 17 per formed or isometric drawings genersted by 18 representatives who participated in the walkdown and 19 then made available to the entire crew. Are the 20 necessary inter-disciplinary people represented, and do 21 they actually go on the walkdown or do they depend on 22 other people, or are there different walkdowns for 23 different purposes, in terms of depth? And this is the 24 type of thing I want to ge t at, more of the nitty-gritty 25 for what is done on a valkdown, if you are performing a O
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() I walkdown for the purpose of systems interactions.
2 WITNESS DAWE: Some of the characterizations 3 tha t you were describing in your question I am aware of 4 were done. Whether they are all tied together in the 5 same walkdown or not, I would have some trouble 6 answering that question discretely.
7 Instrument lines, for example, the one I 8 discussed, those would have involved the people who 9 actually performed the instrument design, discussing 10 with the systems engineers the shutdown model in 11 determining ahead of time the instrument lines that 12 would be used. Then they would actually go into the 13 plant and walk those instrument lines to locate their O 14 location in the plant relative to the break locations 15 for which the shutdown model would be used.
16 In some cases, yes, measurements were taken 17 for dynamic effects. But in most cases, that type of 18 thing would not be necessary because the break location 19 would not, in fact, be close to the line that was being 20 required.
21 We do generate isometrics for the plant.
22 Isometrics are used for the studies. Isometrics are 23 verified in the plant under an as-built type of
(} 24 arrangement, but whether these people actually carried 25 the isometrics during the walkdowns, I cannot answer O
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() 1 tha t question.
2 JUDGE BRENNER: But the conclusions would be 3 based on the walkdowns rather than the as-built 4 drawings, whether they be isometric or otherwise, unless 5 the drawings were verified by the walkdowns. That is 6 the inference I get from your answer.
7 WITNESS DAWE No. I think it could go either l 8 var. We deal in drawings. There is nothing magic about 9 the drawings. A lot of information can be gained from 10 the drawings. A lot of the analysis is done from the 11 d ra wings. If there is any doubt in anybody's mind as to l 12 the validity of the analysis done from the drawings, 13 then a new plant visit would be conducted or could be O 14 conducted by the individuals responsible for that i
l 15 portion of the analysis.
16 Conversely, if there was some doubt as to the 17 actual facility layout in an area, it could be do.ne in 18 the reverse direction. In other words, go in and sketch i
19 the area and then come back and do the analysis. After 20 you have the information from the plant, it could be 21 confirmatory or it could be driving. The analyses are, 22 in large part, done from engineering drawings available 23 to us, however.
( 24 JUDGE BRENNER: When you work with the 25 drawings, how can you be confident that the drawings O
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() I represent the as-built condition of the plant?
2 ( Panel of witnesses conferring.)
3 WITNESS DAWE Again, Judge Brenner, it
(])
4 depends upon the type of drawings which you are working 5 with. The drawing should dictate the as-built condition 6 of the plant, if they are installation drawings, for 7 example, as opposed to a flow diagram which is l
8 sch ema tic. If someone has to deviate from that drawing 9 field, that deviation requires an engineering l 10 disposition before it occurs. And that should be l 11 reflected either on the d ra wing before you change 12 documents to the drawings which are collected until the 13 next revision of the drawing.
14 Some types of dra wings and some types of 15 installation of the plant are on drawings which we would 16 call diagrammatic as opposed to a construction drawing.
17 Which means that they are not physically laid out, and 18 that type of thing is field drawn in the plant. Rather 19 than engineered areas like that, you would have to look 20 at the plant. And instrument lines are, in some cases, 21 an example of that, where it is diagrammatic as opposed 22 to installation drawings. That is why that type of a .
23 look is important for that. l C:) 24 We can rely on our drawings because of our '
i 25 change control on our drawings. Likewise, some of the l
l
(:)
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5048 W
t
_O ' ar 1a== re mutte. aa or tae =tuaie re 2 being made on as-built to insure that the studies that 3 were done from the drawings are still valid at the 4 Completion point.
)
5 i 6 7
! 8 i 9
a 10 11 12 t
13 O 14 I
15 j 16 17 l 18 19 20 i
j 21
. 22 I 23 lO 24 25 O
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() 1 JUDGE BRENNERa It does not surprise me that 2 you have procedures for documenting changes to drawings 3 which represent installation drawings as opposed to
[])
4 diagram-type drawings when you are dealing wi th safety 5 systems. Do you have the same types of procedures for 6 documenting devistions from installation-type drawings 7 for nonsafety systems?
8 WITNESS KASCSAKa Maybe what I could do is 9 explain an example of an interaction evalua tion that was 10 performed that I was presently involved in.
11 JUDGE BRENNER: Could I get an answer to my 12 last question?
13 WITNESS DAWEs Speaking for Stone and Webster 14 in direct response to your question, yes, they are the 15 same procedures that are used for drawing control.
16 JUDGE BRENNER4 Now, Mr. Kascsak, I did not 17 want to stop you, and you can proceed now.
18 WITNESS KASCSAKs What I was going to allude 19 to is we were talking about pipe break considerations, 20 and as part of our walkdowns and the design process for 21 evaluating pipe breaks inside containment, initially 22 walkdowns were prepared to evaluate where pipe breaks 23 could occur, and Stone and Webster developed zones, 24 exclusion zones, that would be used as criteria for 25 routing field run piping, conduit and instrument lines.
O i
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5050 1 And that criteria was given to the contractors who then 2 planned those lines within the containment.
l
(} 3 We then evaluated the as-built conditions.
4 And let me say this. As the installation was 5 proceeding, any deviation to that criteria was l 6 identified, and it was evaluated on a case-by-case bacis l
7 by the engineers. After the installation was complete, 8 the as-built condition of the lines was checked relative 9 to the criteria.
10 And again, that is an example of an 11 interaction tha t we considered in the design process and 12 verified through the as-built design of the plant.
13 JUDGE BP.ENNERs Thank you. That helps.
14 BY MF. LETSCHEa (Resuming) 15 0 Mr. Dawe, in your discussion of the instrument 16 line walkdowns when did that walkdown tak e place?
17 A (WITNESS DAWE) My recollection is over a 18 period of time that it would have been about in the '78 19 time frame, '77 time frame.
20 0 So there would not have been as-built drawings 21 available at that point to the engineers, is that right, 22 or would there?
23 (Panel of witnesses conferring.)
24 A ( W IT N ES S DAWE) I have a little trouble 25 cha racte rizing it. I do say that anything is as-built O
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() 1 until the plant is completed. Any of the drawings at 2 that time were completed, and much of the work was done 3 to those dra wings; for example, large bore piping was 4 well established in the field.
F Yes, we work from our latest drawings. Our 6 latest drawings through change control are maintained to 7 correct. As changes come into the plant, these things 8 are verified. For example, in the specific case of high 9 energy line break studies, those line break studies are 10 very much dependent upon the stress analysis. And you 11 start your studies using preliminary stress analysis, 12 your as-built verification program, and your final 13 stress reconcilation programs going on at Shoreham now O
- ~ ~
14 are defining the final stress analysis, and we are 15 verifying break locations against final stress analysis 16 and final placement of protective features in the plant i
17 such as restraints and supports.
18 It is an ongoing process. You cannot take a 19 picture of it once and walk away from it. Likewise, you 20 cannot wait until the very end to do that type of a ;
)
21 study. You do it preliminarily, you modify it as you go l l
22 along, and you verif y it and confirm it at the end.
23 That is a necessary part of the design process. j
( 24 0 What percentage of the instrument lines were 1
25 in place in the 1978 time frame when this walkdown took O
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() 1 place?
2 A (WITNESS DAWE) I cannot put a percentage 3 figure on it from my personal knowledge. I do know from
(])
4 personal knowledge that the instrument lines that we 5 were interested in in the shutdown model were verified 6 at that time. My time frame may be wrong, but my l
7 recollection it is either a '77 or '78, perhaps early 8 '79 time frame.
9 0 You mention in your testimony that under to Section A, Dynamic and Environmental Effects, Including 11 Flooding, which result from high energy line breaks and 12 modera te ene rgy cracks, are determined. What effects 13 other than flooding were analyzed in that study?
l l
() 14 A (WITNESS DAWE) Dynamic effects of whip and 15 jet impingement. Environmental effects other than 16 flooding would be temperature, pressure, humidity in the 17 spaces as a result of piping failures.
18 0 The study you identify as one of spatial, a 19 study in spatial interactions here in your testimony, 20 that study did not try to identify human interactions 21 that could be relevant, is that right?
22 A (WITNESS DAWE) No , I would not say th a t that 23 was entirely true. Pipe break studies is primarily a 24 spatial interaction study in that you are looking at a l
25 physical event which has spatial results, the results l CE) l l
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( i being the d ynamic or environmental results. i 2 If you read our final safety analysis report 3 which describes the models done, there are certain
(])
4 assumptions that are made in doing the analysis. One of 5 the assumptions is single failure, and one of the forms l 6 of single failure is a single operator errors so those 7 types of things were considered in the conduct of that l
8 study.
t 9 I would also say that operators -- that human 10 factors were involved in those studies to the extent .
11 that we did design evaluations and we had shutdown i
12 models, but they are not exotic shutdown models. They 13 are things that we as engineers are convinced that the O 14 operators can and will do in the J1 ant for recognizable 15 events. So, yes, I would say that, human factors were I
16 involved in those studies.
17 Q But this study was not designed to identify 18 human interactions, was it? You say that it was a stud'y 19 of spatial interactions.
20 A (WITNESS DAWE) It is predominantly a study of ,
21 spa tial interactions. To t':le extent that human 22 involvement is involved in the recovery from the event, 23 yes, we did consider that, as I have already described.
l l 24 0 We re there any walkdowns done in connection t
l 25 with this study other than the ones relating to l C2) i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D C. 20024 (202) 554 2345 t i
5054
() 1 instrument lines that you mentioned?
2 A (WITNESS DAWE) I have discussed with other 3 engineers who worked on this study their involvement and
(]}
4 their use of the plant in doing the study. The one tha t 5 I was personally familiar with is the instrument line 6 case. As I said before, the people who did these 7 studies, psrticularly this pipe break study, were 8 project engineers from Stone and Webster who spent a 9 great deal of time in the plant. They may be there as 10 auch as two or three days a week in some phases of the 11 design. As they are doing this kind of work they make 12 use of the plant. It is probably the best design model 13 we have because it is there. And so to that extent, 14 yes, there was a great deal of involvement with the use 15 of in-plant knowledge.
16 MS. LETSCHEa Judge Brenner, I think this 17 sight be an appropriate place to break. You had 18 mentioned 12:15.
19 JUDGE BRENNER: All right. Let us break for 20 an hour and fifteen minutes, so we will come back at 21 1:35.
22 (Whereupon, at 12:20 p.m., the hearing was 23 recessed for lunch, to be reconvened at 1:35 p.m., the 24 same day.)
25 O
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() 1 AFTERNOON SESSION 2 JUDGE BRENNERs Before we proceed, I had an 3 interchanga with LILCO's counsel this morning about
{])
4 LILCO's response to the emergency planning contentions, 5 and I neglected to include the Staff in that response.
6 I assume I will receive the Staff's today as well.
7 MR. BORDENICKa Judge Brenner, the response 8 you will get will be a joint response.
9 JUDGE BRENNER: Thank you.
10 Ms. Letsche, as you may recall from the 11 discussion at the end of last week, we are very hopeful 12 that you can finish your cross examination on systems l
13 interactions today. I hope the percentage of the cross
()
l 14 plan is not indica tive , and you were interrupted by us, 15 I know.
16 MS. LETSCHEa Your Honor, I an hopeful of 17 that, too, and I will move as rapidly as I can.
18 JUDGE BRENNER: I did not intend any criticism 19 of the day so far. I was just remembering for myself 20 and for you what our goal was.
21 Whereupon, 22 GEORGE F. DAWE 23 GEORGE GARABEDIAN
( 24 PIO W. IANNI 25 ROBERT 5. KASCSAK
()
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() 1 PAUL J. MC GUIRE 2 PAUL W. RIEGELHAUPT 3 DAVID J. ROBARE
[}
4 the witnesses on the stand at the time of recess, 5 r es um ed the stand and were further examined and 6 testified as follows:
7 CROSS EX AMINATION -- Continued 8 BY MS. LETSCHE:
9 0 Going back just one minute to what we were to discussing before lunch, Mr. Dave, the walkdowns that 11 you described 5 -r-us -on -ins trument lines, are they 12 documented in the FSAR?
13 A (WITNESS DAWE) N o, they are not. They are O 14 part of the methodology that was used in the pipe break 15 studies. Much of that methodology is in the documented 16 records in Boston, but the FSAR reports and results are 17 the high points of the analysis.
18 0 Mr. Robare, did GE participate at all in the 19 pipe f ailure studies that are referenced in the 20 testimony?
21 A (WITNESS ROBARE) No, we did not, except to ,
22 the extent that we have design responsibility for the 23 main steam and recirculation portions of that piping.
24 (Panel of witnesses conferring.)
l 25 0 Does that mean that the answer is yes?
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- () 1 A (WITNESS ROBARE) Well, the answer is no, we 2 did not participate in these particular studies.
i
() 3 (Panel of witnesses conferring.)
4 A (WITNESS ROBARE) The answer is since we had 5 design responsibility for main steam and recirculation 6 piping within the dry well, we did provide information 7 for that portion.
l l
8 0 When you say provide information, I am not l
, 9 sure what you mean. Did GE actually conduct any l
10 portions of this study, or did you just provide 11 information and then Stone and Webster put it into the 12 study they were doing? I just do not understand your 13 answer.
l O 14 (Panel of witnesses conferring.)
15 A (WITNESS ROBARE) Since we have design 16 responsibility for those portions, we did the full 17 evaluations and provided the information that is in the 18 FSAR for our scope of supply.
19 0 In doing those evaluations were there any 20 valkdowns conducted of the plant by GE?
21 A (WITNESS ROBARE) Yes, there were.
22 0 I take it -- were you involved in the study 23 yourself?
24 A (WITNESS ROBARE) I was not involved, but I 25 have talked and worked with the people in our O
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() 1 engineering department that have made these walkdowns as 2 recently as six months ago.
3 Q Are those walkdowns documented in the FSAR?
(])
4 A (WITNESS B0 BARE) No. Walkdowns are not 5 documented in the FSAR. They are part of the study 6 process.
7 0 Nr. Dawe, did Stone and Webster also do the 8 internal flooding portion of the studies that are 9 referenced in your testimony?
10 A (WITNESS DAWE) Yes. Stone and Webster did 11 those portions.
12 0 Also, this portion of the study was also done 13 in response to a regulatory requirement, is that right?
O 14 (Panel of witnesses conferring.)
15 A (WITNESS DAWE) At this juncture I am not 16 aware of any particular regulatory requirement or 17 guidance document that speaks to internal flooding 18 studies. As I mentioned this morning, we had initiated 19 flooding studies in the plant prior to the initia tion of 20 pipe break event studies, and ultimately the studies 21 became one because of the cause and effect 22 relationships. Obviously, internal flooding is a 23 natural result of the failure of a fluid system, so it 24 is a very logical thing to do with the pipe break .
25 studies. But I am not aware of any particular O
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() 1 regulatory guidance document that goes right to calling 2 itself internal flooding studies or methodologies for 3 internal flooding studies.
(]}
4 0 Were there any changes that resulted from the 5 studies that you have identified in Section A of your 6 testimony?
7 A (WITNESS DAWE) Yes, there were a number of 8 enhancements in the plant that resulted from those 9 studies. They are documented in the final safety 10 analysis report in the results and conclusions of the 11 study.
12 JUDGE BRENNERs Do you mean in Section 3.6 or 13 in Appendix 3(c)?
O 14 WITNESS DAWEs I was specifically referring to 15 Appendix 3(c), typical examples. For the steam line 16 break in the steam tunnel which runs parallel to the 17 control building there is a large -- by "large" I mean 18 thick reinforced concrete wall which basically is 19 capable of handling the impact from the steam line. But 20 as a result of the study we concluded that it would 21 additionally be beneficial to add a steel plate on the 22 back of that wall to prevent any possibility of spalling 23 effects from the f ar side of the wall due to an impact O 24 of large steam line on the wall. In certain areas of 25 the plant we made specific modifications: the use of O
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5060 1 excess flow check valves from moderate energy lines so 2 that discharge from a crack would be self-limiting if 3 there were no automatic isolation involved with the line.
4 I recall that in the main steam tunnel we 5 changed the motor operator on the RCIC injection valve 6 to an operator that was qualified for a 340 degree steam 7 environment. Although that was significantly higher 8 than our projected environment, we wanted to be sure 9 that that valve would be operable due to failures of 10 main steam line drains in the area.
11 We added some additional temperature detection 12 in the steam tunnel to isolate main steam line drains on 13 high tempera tures- being a probable cause of temperature O 14 effects in the steam tunnel. There were a number of 15 modifications like that that are described in the FSAR.
16 JUDGE BRENNERa Thank you.
17 WITNESS IANNIs Also, those studies are 18 iterative in nature and like in our scope of supply 19 where we first determine where the pipe, potential pipe 20 rupture locations are, then we use that information and 21 determine where we put the pipe snubbers and pipe whip 22 restraints and things of that sort. So tha t is how you 23 feed it into the design.
24 (Counsel for Suffolk County conferring.)
25 BY MS. LETSCHEa (Resuming)
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() 1 0 There have not been any changes made as a 2 result of these studies, though, subsequent to, what, 3 1978, the last change in the FSAR, is that right?
[]}
4 (Panel of witnesses conferring.)
5 A (WITNESS DAWE) As we have said earlier, these 6 are ongoing studies and will continue until final 7 stresses are available and final break locations are 8 identified. The examples that I gave earlier were 9 predominantly made back in that time frame. I think 10 there have been some additional enhancements in the 11 plant recently, within the past year or so. I am not 12 able to be specific on everything because I just have 13 not been working on that stuff in the past year.
O 14 I do know, for example, within the last six to 15 eight months there was another excess load check valve 18 added in the control room building in a heating and 17 ventilation area where a potential crack in a hot water 18 heating line, one of my examples which is fairly recent.
19 0 The Appendix 3(c) that you referenced of the 20 FSAR has not been updated since 1978, is that not right?
21 A (VITNESS DAWE) I would have to review the 22 appendix at this point to verify that.
23 0 Let's move on.
24 The pipe failure studies that you gentlemen 25 reference here were deterministic studies, is that right?
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() 1 (Panel of witnesses conferring.)
2 A (WITNESS DAWE) I would characterize the Stone 3 and Webster studies as deterministic studies.
[]}
4 A (WITNESS IANNI) We had first done a 5 probabilistic study on the generic plant which was 6 similar to Shoreham, not identical to Shoreham, and then 7 when the criteria were developed as to how you loca te 8 the pipe break locations and so forth, then we did a 9 deterministic study.
10 0 The GE study with respect to Shoreham was a 11 deterministic study?
12 A (WITNESS IANNI) Yes, ma'am, but the other 13 study also helped us.
14 0 The other study is not one that is referenced 15 in the section of the testimony, is it, as a systems 16 interaction study?
17 A (WITNESS IANNI) No, it is not, because it was 18 not done for Shoreham. It was a general study that we 19 had done in developing the criteria.
20 0 Gentlemen, you state in the introductory 21 paragraph to this section of your testimony that the 22 last -- the next to the last sentence, "The changes that 23 did result from these studies further assure that 24 adverse systems interactions will not occur."
l 25 Now, in light of the changes that you he.ve ,
I l
l 1
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( 1 indicated to us, Mr. Dave, that were made as a result of 2 this study, can you tell me how you have -- how those
(} 3 changes have assured that no adverse systems 4 interactions will occur?
5 (Panel of witnesses conferring.)
6 A (WITNESS DAWE) Well, as the statement says, 7 in performing these interaction analyses we did find 8 vars to enhance the design, and specifically those 9 things that were advanced we have minimized the 10 possibility of adverse interactions from those events on 11 those components or systems that were modified.
12 Additionally, the scope, the broad scope of those 13 studies confirms that there are not lurking interactions 14 as a result of those events that were studied.
15 A (WITNESS KASCSAK) I might add that each of 16 these studies contains an acceptance criteria by which 17 you judge the results of this study, and that acceptance 18 criteria evaluates the interaction and assures that the 19 plant can be safely shut down or that safety functions 20 can be maintained.
21 0 Hr. Kascsak, did you review the results of 22 these pipe failure and internal flooding studies against 23 the acceptance criteria?
O 24 A, (WITNESS KASCSAK) Yes. And that is contained 25 in the analysis itself.
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( 1 0 You said you were only involved in the l
2 preparation of the initial FSAR items on this study, I 3 believe earlier?
{]}
4 A (WITNESS KASCSAK) The initial FSAR report 5 contained an evaluation of acceptance crite ria and 6 conclusions against that criteria.
7 Q But you did not review the things that were 8 done subsequently; that is, those that are in the 1978 9 revision, is that right?
10 A (WITNESS KASCSAK) That is true. I was not 11 personally involved in all of the updates.
12 0 So that your statement with respect to the 13 changes that resulted which are documented in the 1978 O 14 appendix to the FSAR were not reviewed by you, is that 15 richt?
16 A (WITNESS KASCSAK) They were not reviewed by 17 me, but they were reviewed on the same basis by someone 18 else.
19 0 Who establishes the acceptance criteria for 20 these studies, or who did establish them?
21 (Panel of witnesses conferring.)
22 A (WITNESS DAWE) Stone and Webster and LILCO 23 jointly discussed the methodology and the acceptance
! 24 criteria. The acceptance criteria are really quite l
25 simply stateds that we can assure following any of the O
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() 1 postulated pipe break or crack events that we can safely 2 shut the plant down. From that point forwa rd additional 3 acceptance criteria become the measurement of the
)
4 capabilities of the components in shutdown systems or 5 methodologies that will be used for any particular event 6 against the consequences of that event, be they dynamic 7 effects or environmental effects.
8 0 Were there any changes in the plant that 9 resulted from the internal flooding aspect of these 10 studies?
11 A (WITNESS DAWE) Yes, the re were.
12 0 Can you tell me what they we re , please?
13 A (WITNESS DAWE) Specifically, we added O 14 saf ety-related level detection on the eight-foot 15 elevation of the reactor building and in at'least one of 16 the sumps in the reactor building so that the operators 17 would have rapid indica tion of collection of water in 18 the building.
19 0 And can you tell me again, going back to the -
20 sentence you have in your testimony, how that change 21 assures that adverse systems interactions will not occur?
22 A (WITNESS DAWE) Ms. Letsche, that statement 23 says "further assures." We feel that the basic design 24 process by which we are careful in our designs to 25 preclude adverse system interactions in this plant gives O
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i i O i os .1 oceat dea 1 of aesurance that a1on .ith the aaroins 2 we designed at the pisnt -- the defense in depth concept 3 of this plant, the aultiple systeas' cable to shut this 4 plant down -- these f urther give us assurance because we 5 have perforaed these studies and we have found ways to 6 enhance the design as a result of those studies.
7 8
9 10 11 12 13 O 14 15 16 17 18 19 20 21 22 23 O 24 25 O
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1 (Counsel for Suf folk County conferring. )
2 0 Mr. Dave, are both the HPCI and RCIC systems 3 on the Level 87 4 A (WITNESS DAWE) Do you mean are they on 5 elevation 8 of the reactor building?
6 0 Yes.
7 A (WITNESS DAWE) Yes, they are.
8 Q And if there was a flood at that elevation, is 9 it possible that both those systems.would have been lost?
10 A (WITNESS DAWE) Part of our analysis 11 demonstrates that for internal flooding, the rate of 12 flooding, the detectability of the flooding and the 13 available operator actions to secure the flooding source O 14 and the ability to remove the water from the building 15 will protect all essential equipment operating on 16 elevation 8.
1 17 That is the intent and the result of our l l
18 internal flooding study. They are not bounded on the l
19 floor; they are up on pedestals. We have minimum 20 elevations of essential instrumentation for automatic.
21 We have checked elevation for instrumentation of the 22 control room. We have checked elevation of the pumps 23 and valves of the electrical components and assured 24 ourselves that from internal flooding sources we will 25 not flood the required equipment to safely shut the O 1 ALDERSON REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 plant down following these events.
2 (Pause.)
3 0 Gentlemen, I would like to go back for a 4 minute to what we were discussing prior to lunch; that 5 is, Suffolk County Exhibit 19 for identification. Have 6 you all now had an opportunity to review that exhibit?
7 A (VITNESS DAWE) We have had roughly an hour and 8 15 minutes to review that exhibit.
9 JUDGE BRENNER: Not counting time to eat.
10 WITNESS DAWEs Or to drive, Judge Brenner.
i 11 BY 55. LETSCHE (Resuming):
12 0 Directing your attention to the section of 13 tha t exhibit which falls under the category B, classes O 14 of techniques to evaluate systems interactions, would 15 rou agree with me that there are listed here five 16 classes of evaluation techniques for systems 1
17 interactions? And I will state for the record what 18 those five are that are identified on pages 17 through 19 19. These are Roman numeral XVII through XIX of this i
20 exhibit. First is " Review of Operating Experience."
1 21 Second is " Analysis by Parts." Third is " Graph-based 22 Analyses." Fourth is "On-site Inspection", and fifth, 23 "On-line Decision Aides."
() 24 A (WITNESS DAWE) I am not sure if I have a 25 question directed to me.
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() 1 0 The question was to the panel, and it vass 2 Would you agree with me that there are five classes of 3 techniques for evaluating systems interactions
(]}
4 identified in this exhibit.
5 A (WITNESS DAWE) That is what your exhibit says 6 it has in it, yes.
7 0 Well, do you agree? Are you saying that it 8 does not?
9 A (WITNESS DAWE) We have read the exhibit. The 10 authors of this exhibit classify those five groupings 11 which you read as techniques for evaluation of system 12 interactions. We have reviewed.this document, and 13 believe that each of these things points to ways of 14 evaluating sytems interactions, many of which we believe 15 ve have used.
16 0 Would you also agree, Mr. Dave, that -- and 17 the entire panel, I an addressing this to -- that these 18 different techniques have varying strengths and 19 weaknesses with respect to identifying different types 20 of systems interactions?
21 (Panel of witnesses conferring.)
22 A (WITNESS DAWE) The authors feel that they hare 23 various strengths and weaknesses. With the lir_ted time 24 we had to review them and to understand the authors' 25 terminology, it is a little hard for us to say what O
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() 1 those strengths and weaknesses are without speaking with 2 the individuals.
3 0 I was not asking you about the authors' of 4 this document opinions. I was asking you for your 5 professional opinion. In your opinion, do the different 6 techniques of identifying systems interactions have 7 various strengths and weaknesses with respect to their 8 ability to identif y different types of inte ractions?
9 JUDGE BRENNERs Well, Ms. Letsche, although 10 you did not ask the question in the terms he answered 11 it, I think you got a fair answer. That is, I think the 12 witnesses are entitled to the caveat that to some 13 extent, it depends on what the authors mean by those O 14 categories. And I think it was in that sense that Mr.
15 Dave referred to what the authors think.
16 HS. LETSCHEs Judge Brenner, I think that Mr.
17 Dave also stated that he feels that they h' ave used a 18 number of these techniques. I assume he is referring to 19 his testimony. I think it is not an unreasonable 20 question for me to ask his opinion, since he sponsored 21 this testimony on systems interaction as to whether or 22 not these different techniques -- and if you like I will 23 refer to the techniques you have used, and when we go
} 24 through these, you can tell me what sort of techniques 25 you have used in each one of these things.
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() 1 JUDGE BRENNER: Well, stay with me for a 2 minute.
3 HS. LETSCHE Whether or not those techniques 4 have varying strengths and weaknesses with respect to 5 identifying different types of interactions.
6 JUDGE BRENNERs I did not cut off your line of 7 inquiry. I jumped in because I felt you were asking the 8 same question a second time and had received what I 9 considered to be a fair answer. Now, I could be wrong, 10 but you have not addressed tha t directly, so you are 11 entitled to pursue the line. But I think a next 12 question would be in order.
13 BY MS. LETSCHE (Fesuming):
O 14 0 Mr. Dawe, let's take your study A, referred to 15 in your testimony that we have been discussing, that of 16 pipe failure and internal flooding. Looking at the 17 classes of evaluation techniques tha t are ider.tified in 18 Suffolk County Exhibit 19, can you tell me which class 19 the techniques used in the pipe f ailure study fall into ?
20 (Panel of witnesses conferring.)
21 A (WITNESS DAWE) I think several parts of 22 several of these, as I understand the terminology, 23 without having had time to review the entira document 24 from which they were taken which I assume would give me 25 more detailed information, could really be considered O
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( 1 part of a pipe break study, for example.
2 Analysis by parts -- if I understand th e te rm
(} 3 " gross hazards analysis", from what I can see then 4 described in here, -- things such as the results from 5 the pipe break and what those hazards are in terms of 6 high temperatures, for example, would be part of that 7 study.
8 With respect to graph-based analyses, there 9 are certainly portions of that description that are in 10 there. We are talking about -- in graph-based analyses, 11 they are talking about looking at systems interactions 12 involving common mode failures, and to the extent that a 13 pipe break creates an environment which can then be a 14 common dependency among systems, certainly, we are 15 looking at it in that vein.
16 As I read this terminology and look at 17 something such as " influence diagrams", I could 18 interpret that in two ways. The things that are going 19 to influence components or the inter-relationship of 20 components themselves, to the extent that we use 21 diagrams to tell us auxiliary support systems or primary 22 systems and the commonality of those auxiliary support 23 systems, to look at things that are potentially disabled 24 as a result of a pipe break, and I would say we have 25 portions of that involved in a pipe break study.
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Certainly, as we discussed this morning,
(]) 1 2 on-sito inspection techniques are a part of the pipe 3 break study, and at least in terms of operator reaction 4 to pipe break events, I would think that on-line 5 decision aides minimizing the chances of operator errors 6 are a part of a pipe break study because one of the i
7 thing we look at is how the operator will respond to 8 that particular event, cettainly. And the level of 9 instrumentation we have added is an on-line decision.
10 Various leak detection instrumentation 11 throughout the plant, which identifies the source of 12 leakage, is part of the operator's decision aides as to 13 how to respond to a particular indication from his 14 plant. So I think there are many aspects of this thing 15 that are involved in a pipe break study.
16 0 So you actually used a combination of these 17 different techniques in doing your pipe break study? Is 18 that correct? _
19 A (WITNESS DAWE) That is my belief.
20 Q Gentlemen, I would like to move on to your 21 Section B on missiles on page 57 of your testimony. I 22 guess the first question iss who did the studies that 23 a re referenced here?
() 24 A (WITNESS DAWE) Those studies were done by both 25 General Electric and Stone E Webster.
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() 1 0 When were they done? When were they performed?
2 A (WITNESS ROBARE) The GE portion was performed 3 approximately in 1978.
4 A (WITNESS DAWE) The Stone & Webster portions 5 have been performed over a period of time from, I would 6 say, 1972 or 1973 up until the present, actually, with 7 final reviews of the turbine missile analysis.
8 0 You mentioned in your testimony two FSAR 9 s ec tion s. Can you tell me what particular study it is 10 that you are referring to in this testimony?
11 A (WITNESS DAWE) FSAR Section 3.5 refers to 12 missiles in genersl and has sections on both internal 13 and external missiles. It is referring to internal O 14 missile generators other than the turbine missile 15 analysis, and it refers to external missiles from 16 natural events, primarily, a tornado, which are the 17 limiting missiles for the plant.
18 External natural missiles, Section 10.23 of 19 the FSAR, is where you will find the results and a 20 description of the methodology for the turbine missile 21 analysis.
22 A (WITNESS ROBARE) The General Electric portion 23 deals with the recirculation pump over-speed potential
( 24 in Section 3.5.
25 JUDGE JORDAN: Is aircraft included?
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() 1 WITNESS DAWEa Aircraf t is included in the 2 FSAR. It is discussed in Chapter 2 of the FSAR.
3 JUDGE JORDANS In the missile study?
4 WITNESS DAWEs No, it is not, Judge Jordan, 5 because of the probability of the event.
6 JUDGE JORDANS Do you feel that missiles from, 7 say, tornadoes are more probable? You say you included 8 such missiles as natural missiles, and I presume that 9 would include tornado-driven missiles. You feel that 10 those are more probable than aircraft?
11 (Panel of witnesses conferring.)
12 WITNESS DAWEs Judge Jordan, I am not sure 13 that I can speak at this point to the probability of a 0 14 tornado at the Shoreham site. I just do not have that 15 information in my head right now.
16 JUDGE JORDANa I was just a little surprised 17 at the reasons for leaving it out of missile studies.
18 It does not seem to be s completely logical reason, but 19 as long as it is included I do not particularly want to 20 go into it.
21 WITNESS DAWEs Well, I would just like to say 22 tha t aircraf t is a specific site-related study which is 23 done based on the site. We do have certain requirements
() 24 to meet of a regulatory nature as the site measures up i
25 against the regulatory requirements. It is not the l
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() 1 design basis event for the plant for an aircraft impact 2 on the structures.
3 Similarly, tornado missiles are a regulatory 4 requirement, independent of the probability of the 5 tornado.
6 JUDGE JORDANS That really answers my question 7 very well, thanks.
8 BY NS. LETSCHE (Resuming):
9 0 Mr. Dave, you mentioned tha t the tornado 10 missile analysis was a regulatory requirement. That is 11 true also of the internal and external missile studies 12 -- I am sorry, the internal missile study and the 13 turbine missile study you mentioned, is that right?
()
l 14 A (WITNESS DAWE) Yes, those are regulatory 15 req uirem ents , and I am certainly aware that the 16 Regulatory Commission is interested in reviewing our 17 conclusion relative to that part of the design.
18 0 Was your turbine missile study a probabilistic 19 study?
l 20 A (WITNESS DAWE) Yes, it was. And also, a 21 deterministic study. It is both.
22 0 How about the tornado study? The tornado i
l 23 missile study?
) 24 A (WITNESS DAWE) The tornado missile study I 25 would characterize as a deterministic study. We did not ALDERSON REPORTING COMPANY. INC.
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() 1 concern ourselves with the probability of missiles; we 2 concerned ourselves with a spectrum of missiles and the 3 ability of the plant to withstand impact of those 4 missiles.
5 0 You indicate in your testimony that these were 6 spstial interaction studies. Does that mean you were 7 basically looking for the mechanical effects of the 8 missiles on the plant?
9 A (WITNESS DAWE) Yes, we were basically looking 10 for mechanical effects. However, if you review the 11 design, you will find that in essence, missile damage is 12 precluded by the design through the use of structural 13 vall thickness, for example, and so forth. So in the O 14 design process, as much as a pragmatic decision as 15 anything else, the exclusion of the missile from the 16 components of interest is a large part of the design.
17 0 Did you make any changes in the plant as a 18 result of the studies that are referenced in Section B 19 of your testimony?
20 (Panel of witnesses conferring.)
l 21 A (WITNESS DAWE) I am not aware of any changes 22 that result from those analyses. And I think the reason 23 that that does not occur is that those types of analyses 24 are really confirmatory to the extent that the design 25 f rom the ground up considers those potential hazards to O
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5078 1
() 1 the plant. And the analysis is a review of the design 2 adequacy, but since you know at the start of the design 3 what hazards you have involved, the chances of such a 4 study showing a particular problem are really very slim.
5 In fact, many of the design features are 6 directly related to those protection requirements for 7 the plant. By the time you get done designing a 8 structure to be able to withstand the same shutdown 9 earthquake and the tornado missiles, it becomes somewhat 10 argumentative in some of the designs as to which is the 11 more limiting feature. So that is really a'part of the 12 design process right f rom the start of the design.
13 0 In an earlier answer, you were talking about O 14 how the design precludes the mechanical eff ects of a 15 missile. Is that true also with respect to turbine 16 missiles, or was your answer limited to the discussion 17 of exterior missiles?
18 A (WITNESS DAWE) Well, to the extent that design 19 changes do not become required as a result of the review I
20 of the turbine missile event, I would say that yes, that 21 is part of the design.
22 (Counsel for Suffolk County conferring.)
23 Q With respect to the turbine missile study ,
( 24 there were not any changes as a result of that, either, 1
25 right?
l
(
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() 1 A (WITNESS DAWE) There were no changes made that 2 I am aware of.
3 0 And was one of the reasons for the lack of 4 changes the probability of that event occurring that was 5 determined as a result of your study?
6 (Panel of witnesses conferring.)
7 A (WITNESS DAWE) Could you repeat your question, 8 just to be sure I as answering the question you asked.
9 0 Let me see if I can restate it. Was the fact to that you did not make any changes in the plant as a 11 result of the turbine missile study, at least also 12 partially based on the probability of that event 13 occurring?
O 14 A (WITNESS DAWE) Well, there is more to it than 15 the probability of an event occurring. You really have 16 to separate turbine missiles into two categories to 17 answer that question meaningfully. A, low trajectory 18 turbine missiles are looked at and damage from them is 19 precluded. It is actually by the massive amounts of 20 concrete in the plant -- it is really a barrier design.
! 21 High trajectory turbine missiles, analysis of
{
22 them depends more on probability, but it is not just 23 probability of events occuring; it is also probability l () 24 of a given occurrence. The probability of having the 25 missile and then the probability of having the missile t
i t
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() 1 strike a safety-related component, and then the 2 probability of having the damage occur when you get the 3 probability of the strike. So it is really three 4 probabilities involved in a high trajectory missile.
5 0 In these missile studies that you referenced 6 here, those particular studies did not attempt to 7 address possibilities of human interactions, did they?
8 I believe you state in your testimony that these are 9 spatial interaction studies.
10 (Panel of witnesses conferring.)
11 A (WITNESS DAWE) With respect to the missile 12 studies in particular, it is a little difficult for me 13 to see much involvement of human error with respect to 14 the event occurring, while it is occurring. If you 15 start looking at human error and trying to track it back 16 into latent effects, that we have left something out of 17 the design or have put something in improperly relative 18 to the way we wanted to put it in there.
19 Those things are designed, the process covers 20 with quality assurance, with design reviews and things 21 of that nature. And the studies look to see what is 22 there and confirm it, so I think human error would have 23 very little involvement here. And tha t basically , as we
() 24 have characterized it, missile studies would be spa tial.
25 0 Mr. Kascsak, I believe you indicated that this O
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(]) 1 was one of the studies that you had some reviewing role 2 in. Can you tell me -- I believe you said before that 3 you reviewed the FSAR, and you also reviewed the Stone &
4 Webster and GE studies, is that right?
5 A (WITNESS KASCSAK) That is correct.
6 0 Can you tell me what you were reviewing those 7 things for? What was the purpose of your review?
8 A (WITNESS KASCSAK) Well again, the review is 9 based upon an understanding of what the objective of the 10 analysis was, what the acceptance criteria were for 11 evaluating the results of the analysis. And basically, 12 concurring in those aspects of the report.
13 0 Basically, were you reviewing these reports to 14 determine whether or not they met the regulatory 15 requirements that they were designed to address?
i l 16 A (WITNESS KASCSAK) In part, that would be part
- 17 of an aspect of the objective of the report.
i 18 0 Well, did you check the calculations in the 19 reports?
20 A (WITNESS KASCSAK) In some cases, we reviewed 21 calculations.
22 0 You say we. I am asking, did you.
23 A (WITNESS KASCSAK) Yes, in some cases.
() 24 0 Did you review the assumptions that were used 25 in the reports?
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( 1 A (WITNESS KASCSAK) Yes.
2 0 Did you review the methodology that was used 3 in the reports or in the analyses?
[])
4 A (WITNESS KASCSAK) Well, as part of reviewing 5 the report, you review the methodology.
6 (Counsel for Suffolk County conferring.)
7 0 Mr. Kascsak, you have reviewed these studies.
8 Can you tell ne which of the classes of techniques that 9 are identified in Suffolk County Exhibit 19 for 10 identification were used in these missile studies?
11 (Panel of witnesses conferring.)
12 A (WITNESS KASCSAK ) I would say this type.of
- 13 study would be very similar to the pipe break study in 14 the sense that it evaluates a pre-determined hazard or a 15 pre-identified hazard. And in that light, it would fall 16 under the category of analysis by parts, and also, would 17 in some way fall under the definitions of influence 18 diagrams in terms of looking at the spheres of influence 19 of these missiles as they are generated.
l 20 0 There were not any walkdowns conducted in 21 connection with these studies, right?
22 A (WITNESS KASCSAK) I am not aware of any.
l I
23 (Counsel for Suffolk County conferring.)
l s' 24 0 Mr. Kase,sak, I would like to direct your l
j 25 attention to the introductory paragraph of Section 5 of l
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
i 5083 1 your testimony where you say in the next to the last 2 complete sentence, "The results of these studies 3 demonstrate the potential interactions were adequately
[]}
4 considered in Shorehan's design, particularly with 5 respect to the missile studies." In your review of 6 those studies, can you tell me the basis for your 7 conclusion that those results demonstrate that potential 8 interactions were adequately considered?
9 ( Panel of witnesses conferring.)
10 A (WITNESS KASCSAK) That conclusion is based 11 upon the fact being that we actually performed these 12 analyses, that these analyses were, in fact, part of the 13 design and assessment process that was performed for the 14 Shoreham plant. And in many cases, we concluded that l 15 the design was adequate without changes after the l
16 studies were performed. So in that light, the studies 17 are the confirmation that the studies demonstrate that 18 potential in teractions were adequately considered.
19 'Q So it is because you did not have to make any 1
20 changes, you determined that the original design was all 21 right? Is that sort of a restatement?
l 22 A (WITNESS KASCSAK) Well, the fact that these 23 interactions were considered in the design process, and l () 24 that we assessed the fact that they were properly 25 considered in that process through these confirmatory O
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() 1 studies leaves us with the conclusion that, in fact, we 2 did address and demonstrate that potential interactions
{} 3 do not exist.
4 Q And with respect to this study, the 5 interactions we are talking about are the mechanical 6 effects of one of the missiles that was studied on the 7 plant, right?
8 A (WITNESS KASCSAK) For this particular study we 9 are addressing, the interaction of aissiles and whatever 10 those consequences aay be.
11 A (WITNESS DAWE) Ms. Letsche , I think I would 12 like to add slightly to tha t response, and that is to 13 take the introduction to a total section such as this O 14 and try to apply it in the direct context of'each 15 individual study or subpart of that study is a somewhat l
16 narrow interpretation of the introduction.
17 I think that, at least in ay view, the results 18 of these studies do deaonstrate potential interactions 19 vere adequately considered because in each case of doing ,
l 20 these studies we did not find significant or what I l
21 would, for lack of a better word, call fatal flaws in l 22 the designs. We were able to enhance the designs in 23 some cases.
() 24 ,
We did make changes, and the changes that we 25 made we feel further assured the safety of the plant.
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() 1 And that those ststements should be taken in that 2 context.
3 JUDGE JORDAN: When you said -- you answered
(])
4 that the studies demonstrated that the potential 5 interactions were adequately considered, you are 6 speaking now of the interactions listed A, B, C and so 7 on. That does not mean tha t these consider all 8 interactions, does it? You are not claiming that these 9 are the only interactions that could exist.
10 WITNESS KASCSAK4 I think what we are stating, 11 or what I was stating, Judge Jordan, is that as we 12 men tioned earlier, systems interactions are considered 13 in the design process by the engineers.
( 14 JUDGE JORDAN Some systems interactions; not 15 all systems interactions? That is what I want to get 16 clear.
- - --~_ _ _ . . _ -
17 WITNESS DAWE. I think we have certainly tried l 18 to consider all systems interactions in the design l
19 process as we designed the plant.from start to finish.
20 I would sa y that the analyses that review and 21 specifically address types of systems interactions may 22 not address every potential type, but we feel that we 23 have addressed the significant causes of systems
%- 24 interactions in the plant.
25 And as I said before, the functional types of l
c:)
l l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 systems interactions are inherently studied in the 2 design process. We do not support safety-related 3 equipment with non-safety cooling sources or non-safety 4 ventilation systems or non-safety power supplies and so 5 forth. We are aware of the functions of the components 6 of systems going into the plant and what their 7 inter-relationship is.
8 I think the further assurance comes from the 9 fact that we can do these detailed studies, and they are 10 truly very detailed and they are very comprehensive 11 studies that were done. And the plant design is proved 12 by those studies.
13 To think that making a change as a result of O 14 one of these studies belies the validity of the design 15 process would not be a proper interpretation at all in 16 my mind because, in fact, these studies are a part of 17 the design process. We think that the studies that we 18 have done are representative studies and truly have 19 demonstrated the adequacy of the design.
20 JUDGE JORDAN: And you include in that, of 21 course, then, the probability risk assessments that will 22 be talked about by Mr. Burns and others?
23 WITNESS DAWE: Yes, we would include that in
( 24 that category. That is another verification of the 25 capabilities of the design.
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() 1 JUDGE JORDANS All right.
2 BY MS. LETSCHE (Resuming):
3 0 I would like to move on to Section C, fire
[
4 hazard analysis. This was done by Stone & Webster, I 5 believe, is that right?
6 A (WITNESS DAWE) That is correct.
7 Q This was done in response to an NRC request 8 for this study? Is that right?
9 A (WITNESS DAWE) The specific packaging of a 10 fire hazards analysis study was in response to an NRC 11 request for such a document. What the stud 1 does is 12 document the plant capability to be adec.uately protected 13 against fire. The designs allowed uG to conduct tha t O 14 study in a relatively short period of time, and the 15 report on the adequacy of the design for fire was not 16 done as a result of some specific request f rom the 17 Commission. But the format of the study and the 18 submittal of the study, yes, those were requested by the 19 staff.
20 0 Was this a predictive study?
21 A (WITNESS DAWE) Could you possibly rephrase 22 that question for me?
23 0 How about, was it a probabilistic study?
(} 24 A (WITNESS DAWE) No, this was not a 25 probabilistic study. This was a study of the fire O
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[ () 1 hazards in the plant, the fire detection ca pability 2 within the plant, and the fire suppression capability 3 within the plant, to demonstrate the adequacy of l (])
4 detection and suppression for the potential fire hazards t
5 that would exist in the plant.
6 0 You mention in this description of this study 7 on page 57 of your testimony that the study considered 8 plant fire areas. Can you tell me what you mean by 9 that, plan t fire areas?
10 (Panel of witnesses cor. ferring.)
11 A (WITNESS DAWE) The terminology " fire area" or 12 " fire zone" is referring to the existence of a barriered
]
13 a rea within which the fire would expect -- we would O 14 expect to be contained. Review of that study would show 15 that in almost all cases of the areas or zones described l
l 16 in the study, each by and of itself, is a fully-enclosed 17 three-hour fire area.
18 The one exception to that would be the reactor 19 building where the fire anlaysis or the fire hazards l
20 analysis report was done elevation by elevation.
21 0 Did the analysis --
I am trying to understand 22 your prior answer. Did the analysis look at each sort ,
l 23 of self-contained area and determine the effects of a 24 fire within that area and then go on to the next area 25 and look at that one, rather than considering --
l l
ALDERSON REPORTING COMPANY,INC, )
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5089 O 1 A (WITNESS DAWE) Considering what?
2 0 Considering effects from one area to another?
() 3 A (WITNESS DAWE) That particular study would 4 take an area of the plant, it would review -- well, in 5 actuality the study is really in two parts. The first 6 part of the study discusses or responds to specific 7 concepts of fire protection such as the use of low 8 combustible materials, the use of various types of 9 fire-fighting equipment or suppression systems, the use 10 of various types of detection systems, what our design 11 philosophy was for the use of available fire protection 12 in various areas. That is part of the study.
13 The other part of the study is to look at 14 specif3c fire areas in the plant, look at the 15 combustible loadings within that area of the plant, 16 assess the potential for fires in that area and wha t 17 types of fires they would be; what types of indication 18 you would have from the fire, whethe r it would be a 19 smokey fire or a hot fire, or whether you should be 20 using detectors or heat detectors or both.
21 We then looked at the available fire detection 22 capability in each area to assure that it was 23 commensurate wi th the combustible loadings and types of O 24 fires that could occur. And having done that, we looked 25 at the philosophy of placement of the suppression O
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5090 i I
l 1 systems, whether we were looking at total emersion gas 2 systems entering the compartment, whether we were
() 3 looking at water extinguishment and so on for the type 4 of fire we had, and again, showing that for a given fire 5 hazard; namely, what the hazard was in the area of the I
6 plant, that we had a commensurate detection capability )
l l 7 and suppression capability.
8 And we further looked at what was contained in l
9 that area, and what the effect would be from a fire in 10 that area with and without the active fire suppression. l 1
11 So, for example, when we looked at the diesel generator j 12 rooms, we have three diesel generator rooms, each is a l l
13 three-hour fire room onto itself. The effect with and l
{~
l 14 without active fire suppression is really an effect of l
15 commercial damage because we can withstand the total 16 loss of one diesel generator room and all components 17 con tained within it. That type of analysis is what we 18 did. 4 l
19 l 20 l 1
l t
21
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l 22 '
)
23
) 24 )
)
25 l
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5091 1 0 You mentioned in your reactor building that l 2 you did it by elevation rather than by area.
() 3 A (WITNESS DAWE) My recollection of that study 4 is that within the reactor building we looked at l 5 elevation, by elevation for the fire hazards analysis
(
6 report.
7 0 Did you look at the entire elevation all in 8 one analysis, or was that a segmented analysis?
9 A (WITNESS DAWE) For the fire haza rds analysis 10 report my recollection is that we looked at each 11 elevation as an entire elevation for the cable 12 separation analysis, which is one of the other studies 13 referenced in our testimony. It was a detailed l
. 14 segmented analysis.
15 (Counsel for Suffolk County conferring.)
l l
16 0 You indicate here that this was a spatial 17 interaction study. I take it from that that it was not l 18 designed to address the possibility of human i
19 interactions, is that right?
I 20 (Panel o f witnesses conferring.)
21 A (WITNESS DAWE) Well, I would not say that it 22 did not consider a human involvement. The fire 23 suppression systems in many cases are certainly human 24 involvements. It is the humans using the fire 25 suppression systems which is the active fire suppression ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 capability. In some areas of the plant the fire 2 protection is totslly automatic and others require 3 operator action based upon what the expected hazard is
}
4 and the type of fire suppression system it is.
5 JUDGE BRENNER. Ms. Letsche, from time to time 6 you have used the term " human interactions." Should I 7 interpret that any dif feren tly tha n the term " human 8 actions" in the context of your question?
9 MS. LETSCHE: Yes. Human interactions is one 10 of the categeories of interactions which Mr. Dawe or Mr.
11 Kascsak, I cannot remember who, somebody initially 12 identified as one of the three categories of 13 interactions -- spatial, human and physical. When I say O 14 " human interactions," that is what I am referring to.
15 JUDGE BRENNER: I understand that is one of 16 the three categories; yet, when you asked the question 17 it is have you considered human interactions, and at the 18 level you are asking it, that is, it seems to me it is 19 no different than human actions; that is, have you 20 considered the effect of humans. And if there is a 21 difference in the context in which you asked the 22 question, I am not sure I am appreciating it, and I am 23 not sure the witnesses are.
( 24 You are not asking them to jump to the point 25 where they have actually identified an interaction so l l
(~ l V)
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5093 1 much as have they considered the human element, am I 2 correct?
() 3 MS. LETSCHEa Yes. I understand the point you 4 are making...
5 JUDGE BRENNER: The only reason I asked the 6 question is I do not have interactions in mind when you 7 asked the question. I just have the insertion of the 8 human element.
9 (Counsel for Suffolk County conferring.)
10 BY MS. LETSCHE ( R esur.in g )
11 Q Mr. Dawe, following up on what Judge Brenner 12 said, I think I can be a little more specific in my 13 question. You did answer, I think, a question about the 14 human involvement in the fire protection question. I 15 guess my question is did this particular study in 16 considering systems interactions -- you have identified 17 it as having considered spatial interactions -- did it 18 attempt to identify any human-caused systems l
19 interactions? And what I am referring to are possibly 20 human errors that would result or that could take place 21 after one of the failures that you would be considering 22 in a study.
23 Was that sort of interaction considered in the O 24 study?
25 A (WITNESS DAWE) Well, I am not sure that this O
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5094
() 1 is a study of failures, as you characterize it.
It is a 2 study of fires and the correctness and capability of the 3 fire protection provided to the plant. Certainly within
(]}
4 the fire protection provided to the plant we make 5 allowance for potential human failure. An example I 6 that would give for that is fire doors between fire 7 areas. Those are monitored doors. We have alarms in 8 the control room. If those doors are not closed, the 9 operator in the control room is alerted to the status of 10 his fire barriers, to the extent that his fire barriers 11 can be defeated by people going through doors and then 12 leaving them open. So the design, if not the study, 13 certainly considers that type of a concern.
l
() 14 0 But I was asking about the study. Did the 15 study, the study that we are talking about here, take 16 into account or analyze the possibility of human l
17 interactions as I.just explained them?
18 A (WITNESS DAWE) It is addressed in the study 19 to the extent that the fire brigade and the training of 20 the fire brigade are addressed in the study as to how we 21 or how LILCO will ensure that the people who perform the 22 firefighting services on the plant are trained. But 23 this particular study is one of facts and figures, what 24 are the capabilities of the plant and why were those l
25 capabilities put there versus the hazards that were O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5095 O 1 there. And I am not sure I can see how human actions 2 would factor into this particular study.
() 3 0 Okay. Let me ask a question, Mr. Dave. How 4 does this study as you have described it, this analysis, 5 how does that identify systems interactions?
6 A (WITNESS DAWE) In the latter parts of the 7 study which I discussed earlier relative to the fire 8 areas of the plant, what is contained in each fire area 9 and what the effects are on the plant with and without 10 the active fire protection is certainly a spatial 11 interaction, because what we are looking at is a fire in 12 an area and what can be affected by that fire in the
, 13 area. And that is the relationship of components in 14 space within an area of the plant subjected to a hazard 15 in that area which is a fire.
16 Q But basically you have an area and you say we 17 are going to have a fire, and you say well, let me look 18 and see wha t is going. to be destroyed if I have this 19 fire? That is basically what the study does.
20 A (WITNESS DAWE) W e look at the area, what is 21 in the area and what could be lost as a result of a fire 22 in that area with and without the suppression system, 23 and what the impact would be to the plant and its safe 24 shutdown capabilities.
25 0 What is the systems interaction that you are O
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} 1 looking at in this study?
2 A (WITNESS DAWE) You are apparently defining
(} 3 " systems interaction" as one system interacting on 4 another. That would be, I think, a somewha t limited 5 definition.
6 A systems interaction can occur not just f rom 7 one system interacting on another, but any type of a 8 common cause or common event situation of which this is 9 one, just as pipe break is. Pipe break may be a little 10 easier to see in terms of system interaction because the 11 thing that breaks is a system, and it potentially 12 interacts on another system.
13 A spatial interaction between systems due to a 14 fire if the fire is caused by some component of the 15 plant, again then it is the spatial effect of the fire 16 being in tha t area that could interact with another 17 component of the plant or another system in the plant.
18 It all comes down to a spatial-environmental concern.
19 Here, the hszardous environment is the fire.
20 JUDGE BRENNER: Mr. Dave, does the study 21 consider whether or not the fire can be maintained 22 within a typical three-hour fire barrier in a given area 23 given the loadings and the ability to fight the fire in n/
s 24 that area?
25 WITNESS DAWEs Yes, sir, it does. That was in O
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i 5097 O
ss 1 large part the purposes of those studies.
2 JUDGE BRENNER: So it is a system interaction
() 3 study in that sense, is it nots that is, whether er not 4 there would be an interaction beyond the fire barriers 5 placed in the design?
I 6 WITNESS DAWE4 Yes, I would agree with that.
7 JUDGE BRENNER: Does the study also consider 8 the human element in the sense of temporary increase in 9 fire loadings in the event of a fire and consider 10 procedures with respect to them ?
11 (Panel of witnesses conferring.)
12 WITNESS DAWE: Judge Brenner, the study does 13 discuss that. It does discuss procedural controls to be 14 put in place in terms of temporary combustibles, control 15 of combustible sources, velding procedures and so on 16 throughout the plant. That is part of the first part of 17 the study which is discussing the philosophy of fire 18 protection in the plant.
l 19 JUDGE BRENNER: Does the procedure require 20 civing cognizant officials permission to temporarily l
21 increase the fire loadings in an area of the plant?
22 WITNESS KASCSAK: Yes. As Mr. Dawe stated, 23 the initial part of the report deals with the operating l
CE) 24 plan, if you will, for fire protection at the site, and l
i 25 it deals with the procedural aspects of how you control
(
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5098 A
\~/ 1 combustibles in a certain ares, how, if combustible 2 loadings, as you stated, are increased, what kind of
() 3 procedural controls are used to prevent that situation 4 from being in an unacceptable situation. One of those 5 means would be through institution of fire watches where 6 during welding a fire watch is established to ensure 7 tha t if anything happens, it is responded to on an 8 immedia te basis.
9 (Panel of witnesses conferring.)
to WITNESS KASCSAKs Another aspect of the 11 program is the control of combustibles within the plant 12 itself, the limitations put on in terms of the types of 13 solvents tha t are used, the fireproofing of wood as it 14 is used for scaffolding material or whatever. So in all 15 cases you are trying to reduce to the most practical 16 extent possible the amount of combustible materials in a 17 particular area.
18 JUDGE BRENNER: Ms. Letsche, a t some point are 19 you going to ask them the same question as the study, 20 whether they have made any changes?
21 MS. LETSCHE: Yes.
22 JUDGE BRENNER All right. I will let you get 23 to it when you want to.
G 24 BY MS. LETSCHEt (Resuming) 25 0 I just want to follow up on one thing you just O
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(_- 1 mentioned, Mr. Kascsak. Does the fire ~ hazard analysis 2 which you reference in your testimony go to the 3 consequences of fire during maintenance procedures,
[]}
4 maintenance operations, as well as during normal plant l 5 o pe ra tio n ?
6 (Panel of witnesses conferring.)
7 A (WITNESS KASCSAK) I would say typically the 8 analysis assumes the normal loadings within the plant, 9 the material that is part of the design of the plant.
10 And as additional loadings are added to the area, 11 additional procedural controls are established beyond 12 the original design of the protection and suppression
( 13 systems that are built into the plant. 1
(
14 0 I understand that, and I thought I understood 15 some of your answers to Judge Brenner's question. My 16 question is does the analysis that you are referring to 17 in your testimony address all of those sorts of '
I )
18 procedures tha t you were discussing with Judge Brenner j
19 and the procedures that would be necessary if there were l
l 20 welding going on in a maintenance operation?
l 21 (Panel of witnesses conferring.)
22 A (WITNESS KASCSAK) I take it you are asking is 23 it part of the study. It is part of the study in terms l O
\> 24 of how these matters are addressed. And maybe I could l
l i 25 interpret your question in two ways. If in the second O
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5100 l
0 1 way of whether you mean that in the combustible, the 2 analysis of the combustibles within a particular area,
() 3 the amount of BTUs that exist in a particular area, 4 whether or not we consider transient materials in that 5 analy sis, my recollection is that we do not.
6 A (WITNESS DAWE) But as we have stated earlier, 7 the control of transient combustibles is discussed in 8 that analysis from a procedural aspect.
9 0 Were there any changes made in the plant as a 10 result of this fire hazard analysis you have referenced 11 in your testimony?
12 A (WITNESS DAWE) Yes,khereweresomeminor 13 changes made. The number of hose reels, for example, 14 were extended in length to ensure that we would have 15 double 100 perdent coverage within an a rea. So from two 16 hose reels certain changes such as curbing was added in 17 certain areas of the plants. In the chiller rooms we 18 added some curbing around the chiller units to control 19 combustibles such as oil that might come out of the 20 chiller units. The same is true in the HPCI and RCIC 21 turbine areas. We had drainage and depressed floors, 22 and we additionally added curbing.
23 I think those are typical of the kinds of O
\' 24 changes we made. I think there were several others, but 25 they do not come to my memory right now.
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( 1 0 The curbing that you mentioned, was that not a 2 regulatory requirement f rom a Branch Technical Position
)
(} 3 9.57 l 4 A (WITNESS DAWE) I would have to review that l
5 Branch Technical Requirement to see if it is l
6 specifically a requirement in there. There are a number 7 of ways to ac'hieve the same end.
l 8 (Counsel for Suffolk County conferring.)
9 JUDGE BRENNER: M r. Dawe, I infer from your 10 answers as to changes that you did not have to reroute l
11 any cable as a result of the study, is that correct?
12 WITNESS DAWEa That is correct, Judge 13 Brenner. I am not aware of any cable that was rerouted 14 as a result of either this study or the cable separation 15 analysis study.
l 16 JUDGE BRENNER: How about having to add any 17 barriers to assure cable separation -- and I am usina 18 "ba rriers" in a very loose sense -- fire suppression 19 material over cable or actual barriers?
20 WITNESS DAWEa Judge Brenner, we did in terms 21 of barriers add some barriers to the plant, a partial 22 barrier in elevation 8 between HPCI and RCIC turbines, 23 and vertical cable risers comes to mind as a result of 24 our cable separation analysis we did, and ramping to l
25 certain cables in the plant. Our analysis did not show l CE) l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5102 1 it was necessary to achieve safe shutdown, but we felt 2 it was a valuable enhancement to the plant because it
(} 3 gave us more options in the conservative sense of what 4 might be damaged or what might be protected. So there 5 were some additional barriers added as a result of these 6 studies.
7 (Panel of witnesses conferring.)
8 A (WITNESS DAWE) One other that comes to my 9 mind, we did add an additional fire wall, a two-hour 10 fire wall in the control building between some HB AC 11 equipment and some chiller equipment. As a matter of 12 fact, I think it is two walls, one each on eleva tions 43 13 and 63 up in the control room building.
14 JUDGE BRENNER: In the cable spreading room 15 did you have to aid any firefighting equipment such as 16 water sprinkler systems or car docks or other systems, 17 or did you already have them there?
18 WITNESS DAWE. We already had gas systems. We 19 had total CO flooding automatic in the relay room.
2 20 We have added nothing else to the relay room. That 21 system is demonstrated to be a good system for the fire 22 hazards there. In addition, we have manual CO hose 2
23 reel backup and backup for that room. One of those hose 24 reels may have been extended to ensure 100 percent 25 coverage.
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() 1 JUDGE BRENNER: Is the relay room the same as 2 the cable spreading room?
3 WITNESS DAWEt It is the same volume. The 4 relay room is the lower level, and the cable spreading 5 area is above the relay panels prior to entering into l
6 the control room which is above the relay room.
7 JUDGE BRENNER: Thank you.
8 BY MS. LETSCHE (Resuming) 9 0 There was not a walkdown performed in
~0 1 connection with this analysis, was there?
l 11 A (WITNESS DAWE) I am not personally aware of 12 any specific valkdown done as part of this analysis.
13 However, as I mentioned before, the individuals who O
G 14 performed this study were members of the project team 15 from Boston, and I know they spent a great deal of time 16 at the site, and I am sure that during portions of that 17 time at the site while they were doing these studies 18 that is just what they were doing is reviewing the 19 results and looking at the physical installations in the 20 plant against the analysis they have been doing.
21 0 But you do not know that from your personal 22 knowledge, do you?
23 A (WITNESS DAWE) From my personal knowledge I 24 do not know that.
25 Q I would like to move on to the Category D on 1
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554-2345
5104 O 1 cable separation analysis. Oh, let me ask one other 2 question, I am sorry, on the fire hazard analysis. When
(]) 3 was that performed, in '77?
4 A (WITNESS DAWE) Yes. That fire hazard 5 analysis was performed in and submitted in May of 1977.
6 It was performed in '76 and '77. It is in fact being 7 updated now, and it is being looked at again under later 8 design conditions. It is being verified.
9 0 Who performed the cable separation analysis to tha t is ref erenced in your testimony?
11 A (WITNESS DAWE) That was performed by Stone 12 and Webster.
13 0 This analysis was done to justify the failure
)
14 to meet separation requirements of Reg Guide 1.75, is i
15 tha t right?
16 A (WITNESS DAWE) N o, that is not true.
17 0 Why was the study performed, this analysis 18 performed?
19 A (WITNESS DAWE) The analysis was originally 20 s ta rted to be performed as a general review and check of 21 the plant design. It is a methodology that Stone and 22 Webster had developed and used on other plants for i re 23 protection. We decided to apply it to Shoreham and made O 24 the recommendation to the Lighting Company that we apply
(
25 it to Shoreham as a general way of reviewing the layouts I
i
()
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5105
( 1 of the buildings and the networking of the building 2 through the cable. It ultimately came to be used 3 primarily in response to the fire protection question of
(])
4 the plant to show that not only were components in the 5 reactor building physically separated on the component 6 level, but that their networking through power 7 instrument and control cables was equally well separated.
8 It is a fairly advanced methodology and a very 9 comprehensive methodology for reviewing the 10 interrelationships in the plant that exist as a result 11 of the cable routings. As I say, it considers all types 12 of cable, power control and instrument cable. It also l
l 13 is a valuable study in terms of cable separation in
() 14 terms of Regulatory Guide 1.75, but I think you are to 15 some extent confusing two issues and looking at two 16 different things. .
17 The conclusions of the study certainly show 18 that you can consider a large area of the building to be 19 totally lost to you and maintain your safe shutdown l
20 capability.
21 Q This study that you reference, the results of 22 the study that you reference in your testimony were 23 submitted to the NRC in order to attempt to justify the O
k/ 24 failure to meet separation criteria, thouch, were ther 25 not?
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( 1 A (WITNESS DAWE) No, that is not true. The 2 study was submitted to the NRC in response to a question 3 which resulted from the fire hazards analysis review
(]}
4 that was specifically interested in the routing of the 5 cable through the plant and the ef fect of routing of 6 cable on the fire analysis of the plant. That is the 7 purpose for which it was submitted.
8 0 Has the NRC ever reviewed this report?
9 A (WITNESS DAWE) Oh, yes, I am sure they have, 10 and we have had many discussions with them, many of 11 which I participated in, both in terms of the 12 methodology and the results of the study.
t 13 Q Ihe NRC did not a gree, did they, that the O 14 results of this study justified the failure to meet the 15 requirements of Rag Guide 1.75, did it?
l 16 A (WITNESS DAWE) I believe that is another l 17 contention, and I am not sure I understand th e l
1 18 relationship of that to this. I can explain to you what 19 the study does. It is a study which looks at cable 20 routings in the reactor building. We have a methodology 21 using our raiseway pulling schedules and our elementary 22 diagrams and the relationship of cable to component in l 23 segments of the building. We took each elevation. We 24 separated the eleva tions in to 45 degree segments. For 25 each 45 degree segment of each elevation we identified
)
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5107 l
A
\/ 1 all safety-related cable which passes through that l
2 elevation or starts or terminates in that elevation. We
[
then used our design documents, elementary diagrams, for
(]) 3 4 example, to identify what components were affected by 5 that cable. As a result of this, we were able to 6 identify every component that was at all affected by I
i 7 that area of the pisnt and tha cable in tha t area.
I 8 We developed a shutdown model, or a flov 9 network, if you will, that showed us how to go from hot to operating conditions to cold shutdown. We looked at c
l 11 every f unction we needed to do that and the various ways l
12 we had in the plant using only safety-related equipment 13 to perform that shutdown. We identified every auxiliary O 14 system and support system needed to support those 15 shutdown components and systems, and then we identified 16 every component and instrument within that shutdown l 17 method that we needed. As we did each segment of the 18 building we totally eliminated the use of every 19 component that was affected by that segment by just 20 assuming that everything was lost as a result of a fire 21 in that segment, and we then balanced that against our 22 shutdown component list to confirm that we could make 23 our way from normal operating to cold shutdown using l
I
() 24 installed capabilities of the plant and no heroic 25 efforts or unusual shutdown methods.
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5108 O
k/ 1 When we got done with each elevation with our 2 eight 45 degree sagements, we rotated the segments 22 ,
(} 3 1/2 degrees to pu'; the original boundaries in the center 4 line of a new segment to make sure there were no 5 critical boundcries in our original analysis and
(
0 repeated the whole analysis. And we did that for the 7 secondary containmen t, and we did that for the primary 8 containment, except in the primary containment rather 9 than doing it by elevation we did the whole containment 10 st one shot, and we used 60 degree segments instead of 11 45 degree segments.
12 We are convinced that is a very powerful study 13 and shows a great capability of this plant not just for 14 fire but for any spatial hazard tha t can exist in that 15 plant. And it was, in fact, the total concept of' 16 spatial hazards that started us doing the study in the l
! 17 first placa. By the time we got to fire analysis review 18 in the 1977 time frame -- or I forget when that study 19 was, let me just check's yes, February 1981 we submitted 20 the thing -- we had already done the study, and it was 21 just something that we had been doing for our own 22 purposes that was used to answer questions relative to 23 fire pro tec tion.
p k- 24 It is a very powe rf ul study. In fact, th ere 25 is more to the study than has ever been really used in bl Ns' ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
5109
() t f 1 this set. We looked at other areas of the plant with 2 the same methodology, and we did not just look at 3 cable. We looked at instrument lines using the same
(]}
4 type of stud y, and we looked at small bore piping using 5 the same kind of study, and in the reactor building we 6 overlaid all three of them using the same kind of 7 study. It is a very, very powerful study.
8 (Counsel for Suffolk County conferring.)
9 JUDGE MORRISs Mr. Dawe, the obvious question 10 is did you make any changes as a result of that study?
11 WITNESS DAWEs As a result of this study we 12 made no changes. There was more than enough redundancy 13 and separation in the plant to allow us to do the O 14 shutdowns. We did recommend that LILCO in fact 15 implement, whether it has been or not, certain wrapping 16 of cables.
17 Within our shutdown methodology if you review 18 the study you will see a logic network to come down 19 through various functions and different ways of doing 1
20 it. Some of those ways are preferred over other ways 21 because they are more normal ways. The operator 1
22 operates the plant, but they are all within his 23 procedures, and he is trained to use all of those 24 methods.
25 We felt we could have some additional O
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( 1 protection and capability of the plant to maintain a 2 more preferred method, or a more normal method rather 3 than preferred I think is a better word. So there are
(])
4 some areas of the plant where we have recommended and it 5 is being done, but no changes were needed.
6 JUDGE JORDAN: Speaking of wrapping of cables, 7 was it recently that I was reading Shoreham did have a 8 problem in procurement of cables in which there was a 9 thread around the cable which bound the cable unduly?
10 Am I right?
11 (Panel of witnesses conferring.)
12 JUDGE JORDANS Was this not a specific 13 Shoreham problem that has been cited recently?
O 14 WITNESS DAWEa It is not one in my body of 15 knowledge. I do not know.
16 JUDCE JORDAN I think I read it only this 17 past weekend, by my memory fades. I did not think it 18 was very significant.
19 BY MS. LETSCHEa (Resuming) 20 0 I take it from your testimony that the study 21 was not done using as-built d rawings, is that right? I 22 am referring specifically to the top of page 58, the 23 last sentence of Section D.
( 24 A (WITNESS DAWE) The study was performed in the 25 '78 time frame in my recollection. We do have a O
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() 1 commitment to the NRC that we vill perform th a t, 2 reverif y that cable separation analysis study for fire 3 using as-built drawings, and we also have a commitment
}
4 to slightly expand the zones to make sure there is no 5 zonal dimension less than 20 feet. But yet it will be 6 verified. As I mentioned earlier, you cannot choose one 7 of the studies at a point in time without going back and 8 looking at it, nor can you wait until the very end when 9 the plant is all done and sitting there to start 10 performing these studies.
11 We do these studies at a logical point in time 12 as we become knowledgeable of changes in the plant or as 13 the plant is completed. Then when necessary the studies O 14 are verified to the as-built condition.
15 MS. LETSCHEa Judge Brenner, I do not knov 16 when you were planning on taking a break this 17 afternoon. This is a logical breaking point f or me, 18 although I can keep going into another area if you would 19 like.
20 JUDGE BRENNER: If we do not break now I would 21 vant to break by 3 30; so if it would be more convenient 22 for you now --
23 MS. LETSCHE: It would be more convenient now.
24 JUDGE BRENNER: Okay. Let us break until 3:30.
25 (Recess.)
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() 1 JUDGE BRENNER: Anytime you are ready, Ms.
2 Letsche.
3 BY MS. LETSCHE ( Resuming):
4 0 Gentlemen, I would like to move on to Section 5 E, failure modes and effects analysis, page 58 of your 6 testimony. Who performed the analyses that are 7 ref erenced in this section of your testimony?
8 A (WITNESS D AWE) Those referred to in part E 9 were done by Stone C Webster. ,
10 0 Mr. Robare, I believe you mentioned earlier 11 that you had some involvement in reviewing the items or 12 the FMEAs mentioned here. Can you tell us what your 13 cole was?
14 A (WITNESS ROBARE) General Electric performed a 15 review of the Stone & Webster FMEAs. Our participation 16 was rather minimal, since these were Stone & Webster's 17 scope of supply.
18 0 Well, can you be a little more explicit as to 19 wha t your participation was?
20 A (WITNESS ROBARE) Yes. We reviewed them for 21 accuracy as far as our interf ace was concerned with the 22 Stone C Webster systems.
23 0 When you say interface, do you mean interface
() 24 between the equipment supplied by GE and that supplied 25 by Stone & Webster?
O I
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W, WASHINGTON, D.C. 20024 (202) 554 2345
5113 1 A (WITNESS ROBARE) Yes.
2 0 And you only reviewed the portions of the
(} 3 FME As that deal with that interf ace?
4 A (WITNESS ROBARE) That is correct.
5 0 Mr. Dawe, when were these FMEAs performed?
l 6 A (WITNESS DA'WE) The FMEAs that are referenced l
l 7 in part E vere performed -- they were started in 1974 8 and completed in 1976 for submittal to the NRC.
i 9 Additionally, they were maintained and updated over the l
10 period of time since then, and now they are being 11 totally redone to meet the latest issue of the drawings.
12 0 Did the FMEAs cover only the systems in the 1
l 13 Stone C Webster scope of supply ?
l (2) (WITNESS DAWE) They were done for all the 14 A 15 safety-related systems in the plant which are shown on 16 the Stone C Webster elementaries. So to the extent tha t 17 some of the systems are GE-designed systems but the l 18 design is implemented by Stone & Webster, certain of 19 what would be classically considered as NSSS systems 20 were also included in these from the Stone C Webster 21 elementaries.
22 Q The FMEAs did not include any non-safety 23 related systems? Is that right?
24 A (WITNESS DAWE) That is correct. These FMEAs 25 were done for safety-related systems.
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() 1 0 Wa s the --
2 A (WITNESS DAWE) I would like to modify my
{) 3 answer. To the extent that any of these systems --
4 there a re safety-related and non-saf ety related barriers 5 or interfaces. The barrier which -- pardon me -- the 6 interface which is safety-related would also be 7 included, for example, in the closed loop cooling water 8 system during normal operation of the plant .
l 9 The closed loop cooling water system supplies 10 both safety-related and non-safety related loads. Under 11 certain conditions and accident conditions, those loads
! 12 are shed from the system and the interface between the i
13 portions of the systems that are going to continue to
() 14 serve the safety-related loads and those that are going 15 to be shed are involved in the FMEA.
16 0 I gather from your testimony, or your 17 description of the study here, that the purpose of these l 18 FMEAs was to assure that the single failure criteria was l 19 met. is tha t righ t?
j 20 A (WITNESS D AWE) That is correct. That is the
- 21 basic purpose of the FMEA. -
l l 22 Q Can you tell me what kind of systems 23 interactions you were attempting to identify in
) 24 performing these FMEAs?
25 A (WITNESS DAWE) Well, these FMEAs, as they were O
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() 1 done, would show inter-train interaction within a 2 system. For example, service water system which is a 3 two-trai system, would all be modeled in the same
{]}
4 f ailure modes and effects analysis, using the same fault 5 tree. And in terms of interaction between trains of the 6 systems it would show that there was no way that one 7 train could disable the other train from a single 8 failure within the system design.
9 So as I have said in the testimony, to identifying unacceptable interactions between redundant 11 trains of a safety-related system, it would do that.
12 0 That is a type of functional interaction, 13 isn't it?
14 A (WITNESS DAWE) Yes, I would consider that a 15 functional interaction. What we would be looking for in 18 tha t case is, for example, in the service water system, 17 there are cross-connect valves that are isolated on 18 accident signals. He would assure that the isolation 19 was properly performed, and tha t there was no single 20 failure in that isolation that would cause a failure in 21 one part of the system to degrade the other part of the 22 system.
23 Where you have multiple-train systems that 24 have what I would call permissives or directions back 25 and forth as to which portion of the system is going to O
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() I carry the load at which instant in time, we would assure 2 that that type of controls within the system would not 3 result in a degradation of both trains, so that the 4 system would meet the single failure analysis.
5 In addition by using this methodology, we can 6 really look in detail at the difficult portion which is 7 the control circuitry and make sure that there are no 8 unidentifiable or undetectable single f ailures in 9 there. It is a powerf ul tool for the design and for the to verification of the system design.
11 (Counsel for Suffolk County conferring.)
12 O Mr. Dave, were any changes made in the plant 13 as a result of these FMEAs?
O 14 A (WITNESS DAWE) I an aware of two changes that 15 were made as a result of these FMEAs and were reported 16 in the FMEA. One was a valve in the reactor building 17 closed loop cooling water system which isolated the two 18 trains to the closed loop cooling water system following 19 accident signals. We improved the logic to ensure that 20 the isolation would occur.
21 And there was one other instance where we had 22 a single damper in the ventilation system within the 23 relay room. Although we had redundant two-train .
( 24 ventilation, we did have one damper -- I am not sure 25 whether it was an inlet side or an exhaust side. But to O
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( 1 ensure that we would not lose ventilation within the 2 relay room with failure of one train, we added a l
(} 3 redundant damper and some additional ductwork to contain
- 4 that damper.
l 5 Other than those two changes, I am not aware l
6 of any that came out of the FMEAs.
7 0 Mr. Kas:sak, I believe you stated tha t you 8 reviewed these -- I think what you said was the FMEAs i
l 9 tha t were initially generated. Those were the ones back 10 in 1974, the early ones Mr. Dawe referenced. Is that 11 right?
12 A (WITNESS K ASCSAK) That is correct, the initial 13 submittal.
O 14 0 What did your review consist of? What were 15 you reviewing for?
, 16 A (WITNESS KASCSAK) We were reviewing them to l
17 ensure that the objectives of the analysis were 18 fulfilled, that the fault trees that were generated and l 19 the conclusions that were reached and the evaluation of l
l 20 the failure modes that were projected in the fault trees 21 were, in fact, complete and correct, in our assessment.
22 0 How did you determine that in reviewing it, 23 whether they were correct?
24 A (WITNESS KASCSAK) Based upon a review of the 25 documents that we used, mostly the elementary diagrams O
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() 1 that we used in the preparation of the FMEAs and the 2 actual report itself which identified the logic that was 3 used in evaluating these' failure modes, and the 4 conclusions that are also contained in the analysis 5 itself.
6 One of the aspects of this analysis is to try l 7 to identify common mode type interactions where a 8 particular item such as a switch or a relay, if failed, 9 could impact or prevent the successf ul operation of 10 redundant trains. So, as Mr. Dave stated, we were 11 concerned about assuring that single failure criterion
! 12 was, in fact, complied with in the initial design.
13 0 Were, as a result of your review, were there
() 14 any changes or additions made to the FMEA analysis, or l
l 15 to the FMEA, I sa sorry.
l 16 A (WITNESS KASCSAK) I am not aware of 17 particularly how the changes that Mr. Dawe alluded to, 1 18 how they were idenitified and whether or not we were a I
19 party to that identification. But in general, no other l
20 changes besides the ones he has identified came out of 21 that review.
22 JUDGE BRENNERs Mr. Kascsak, unless I 23 misunderstood the question myself, I think you are
() 24 confusing chances in the plant with changes in the 25 analysis, and I think Ms. Letsche asked you about any O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5119 O 1 changes in the analysis. Is that righ t, Ms. Letsche?
2 MS. LETSCHE: Yes, that is right, Judge 3 Brenner.
4 WITNESS KASCSAK: I apologize. I was not 5 aware of that distinction. No, I do not believe there l 6 were any changes in the analysis.
I 7 BY HS. LETSCHE (Resuming):
8 0 Mr. Robare, as a result of the GE review of 9 the interfaces that you mentioned, were there any to changes or additions made to the FMEAs?
11 A (WITNESS ROBARE) I do not recall any changes.
12 That was six years ago, however.
13 0 I take it from that that GE is not involved in 14 the continuing or the updating of these FMEAs that Mr.
15 Dawe mentioned?
16 A (WITNESS ROBARE) The current review that -- or 17 tipdate -- that Stone & Webster is doing has not yet 18 progrssed to the point where we have been asked to l
19 review it.
20 0 Mr. Dawe, can you tell me when this updating
(
l 21 is anticipacted to be completed?
22 A (WITNESS DAWE) I believe it is anticipated to 23 be completad by fuel load.
24 JUDGE JORDAN: Could I ask one question, l
25 please. As a consequence of the TMI-2 accident, one of 6
()
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() 1 the lessons learned, and a requirement, in fact, was 2 that there be a f ailure modes and effects analysis of
{} 3 the integrated control system for the BEW plants. Now, 4- this was designed specifically to look for interactions 5 between non-safety equipment and safety equipment. And 6 it did identify, in fact, some interactions that were 7 necessary to change and to fix.
8 You have not tried to make any similar FMEA 9 analysis, I presume, to search for interactions between 10 the non-safety and the safety?
11 WITNESS DAVEs Judge Jordan, we have not done 12 that with the FMEA methodology. There are additional 13 studies going on which are referenced later in our
()
I 14 testimony, which do go to that type of an issue.
15 JUDGE JORDANS Thank you.
16 JUDGE BRENNER: Mr. Dawe, could you tell us 17 which ones particularly, to make sure:we are on the same 18 wavelength? Which additional ones referenced in your 19 testimony?
20 WITNESS DAWEa Sp ecifically, item F addresses ,
i l 21 that type of a question. Itess G and H also address l ;
22 that question. !
l 23 BY MS. LETSCHE (Resuming)s ;
() 24 Q Let me move on to item F, electrical bus l
25 failures. ,
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() 1 JUDGE BRENNER: Excuse me, could I ask another 2 one about E? I am not familiar enough with the wording 3 of Regulatory Guide 1.70, which you reference in item
[}
4 E. If I picked thst up and read it, would it say 5 something close to " perform an FMEA"?
6 WITNESS DAWEs I would have to look at the 7 regulatory guide to see exactly what it says. I believe 8 it sa ys " utilizing methods such as FMEAs to confirm 9 single failure."
10 JUDGE BRENNER: Thank you.
11 JUDGE JORDANS Regulatory Guide 1.70 is the 12 great big thick book, is it not?
13 WITNESS DAWE No, it is about th ree-quarters O 14 of an inch thick. It is the standard format.
15 JUDGE JORDAN : Oh, the standard format.
16 WITNESS DAWEa The thick book is the standard 17 review plan which further expands on the standard format.
18 BY MS. LETSCHE (Resuming):
19 Q Who performed the analysis that is referenced 20 in Section F of your testimony?
21 A (WITNESS DAWE) Stone C Webster performed that 22 analysis.
23 0 And when was that performed?
( 24 A (WITNESS DAWE) I believe it was performed, in 25 terms of a submittal document, in 1981.
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE,5 W., WASHINGTON. D.C. 20024 (202) 554-2345
5122 1 Q I am not quite sure I understand what you 2 sean. Do you mean that is when it was submitted, or 3 that is when it was performed?
4 A (WITNESS DAWE) My statement, performed in 5 terms of a submittal document, it means that in 1981 we 6 formatted engineering information to respond to a 7 specfic type of question. The engineering process that 8 led up to doing that, of course, had all been 9 performed. This was just a re-sorting of information to 10 respond to a particular type of question.
11 0 Oh, I see. This was not a particular analysis 12 that was undertaken; this was just a regrouping of data 13 that you had in order to respond to an NRC question.
14 A (WITNESS DAWE) No, no, it certainly is an 15 analysis. The purpose of that study was to demonstrate 16 that given any single bus failure, we would maintain 17 sufficient equipment, particularly instrumentation and 18 controls, to be able to perform a safe shutdown of the 19 plant.
20 The particular study that is documented in the 21 FSAR demonstrated that capability, utilizing only 22 safety-related components. And by that I mean that we 23 looked again at our shutdown model that we had developed 24 earlier, and there is a great deal of similarity in 25 those shutdown models. For example, when we look at a O
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5123 1 pipe break event, we look at a fire event or we look at 2 an accident scenario and so forth, there are 3 redundancies and diversities in the design of the plant 4 in the safe shutdown equipment, and there are a number 5 of pathways to success to get to the cold shutdown 6 condition.
7 We developed the framework of that type of 8 analysis as an engineering tool. My recollection would 9 be back in about the 74-75 timef rame , that the question to would arise over and over again, maybe in a different 11 con te xt , but -- how do you get from point A to point B.
12 Generally speaking, all of these analyses go to the same 13 point, and that is, achieving safe shutdown of the plant.
O 14 In this particula r study, we again looked at 15 the entire design, we looked at the methods available 16 for safe shutdown and instrumentation and control 17 necessary f or ssf e shutdown. We looked at the power 18 sources of all of that equipment, and we were able to 19 show that the f ailure of any non-safety bus just would 20 not take away something that we needed, and the failure 21 of any single safety-related bus we would have 22 sufficient instrumentation and controls and system 23 a vailability to achieve the cold shutdown condition.
24 This was a study that was specifically 25 requested of operating plants in ICE Bulletin 97. It O
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() 1 was not applicable for response to construction permit 2 applicants, although later in the review process we were 3 asked to respond to the same question in the context of 4 1 review question as opposed to the context of an ICE 5 h !211e tin .
6 But again , the engineering though t processes 7 had all been done. It gets to the point where it just 8 does not take too long to answer the questions anymore 9 because you have been looking at it all along, and these
)
to are things you need to know. So when I say that it was 11 put into a format and it was a study to respond to a 12 specific question, that is the context in which I say
)
(
13 that. ;
( 14 You say in your testimony that this is a study 0
15 of f unctional interactions of power supplies and 16 equipment. I take it you were, when you did this study, 4 I
17 you were attempting to identify interactions arising 18 from common mode -- let me rephrase that -- interactions 19 arising from common mode failures propagated through a 20 support system, is that right? 1 l
21 A (WITNESS DAWE) Well, the electrical power 1
22 sources are a support system to the components of the 23 pla nt, and yes, it is a functional interaction study
/'T 1
\~/ 24 because as you fail a power supply, you then look at all 25 of the things you lose as a result of that. You look at O
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345 1 .
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() I what you have remsining and your capability to perform 2 your desired functions with the remaining equipment.
3 0 And what techniques were used in conducting 4 this study?
5 A (WITNESS DAWE) I guess the easiest way to 6 answer that is to tell you my understanding of how we 7 did that study, having been involved with those studies 8 and ha ving reviewed that study.
9 Q Let me see if we can shorten the answer a 10 little bit. Referring to Suffolk County Exhibit 19 for 11 identifica tion where there are classes of techniques 12 identified, can you tell se what of those techniques 13 were used in the conduct of this study?
O 14 A (WITNESS DAWE) Well, you are asking me to i 15 apply somebody else's terminology to what we did. It i
l 16 very simply stated from our engineering documentation.
17 We can take a bus, we can look at all sub-distribution 18 levels supplied by that bus and we can trace it down to 19 exactly those components that are powered by that bus.
20 We can then assume the failure of that bus so 21 that all of those components are, in fact, not available 22 to us because they failed, or we can look at the 23 remaining components that we have that we are going to l
24 rely on for achieving and maintaining safe shutdown.
l l 25 And we can demonstrate that they are not affected by the l
O l
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() 1 bus that we have lost, and therefore, we can draw the 2 conclusion in a quite straightforward manner that we 3 have suf ficient capability remaining for the safe 4 shutdown of the plant.
5 0 So basically what you did is make a list of 6 what equipment was dependent upon which of the buses, 7 and you just made a list and looked at it?
8 A (WITNESS DAWE) Well, you really make two 9 lists. You make lists of what equipment is desirable to 10 use or available to use; then you make a list of what is 11 available from or powered from any particular bus, and 12 as you fail each one you cancel from one list to the l
13 other, and what remains you look at and whst O 14 capabilities you have in the plant to do that with the l
15 remaining equipment.
l 16 Remember this is primarily an instrumentation 17 and control study, though. And it is documented in the l 18 FSAR, again, in response to 223-90, as stated in our 19 pre-filed testimony.
20 0 Were there any changes in the plant that 21 resulted from the study?
22 A (WITNESS DAWE) No, there were not.
23 JUDGE JORDAN Could I ask one or two 24 questions in regard to that study? In the case, again, 25 of the failure modes and effects analysis for the O
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() 1 integrated control system, it turned out that sometimes l 2 in some places it wo uld be not an absolute failure which I 3 would be easily identifiable and the effects would be 4 easily identifiable, but it is just a mid-scale 5 failure. 3r in this case, perhaps we have an intance in l 6 which -- was it Hillstone in which the voltage just the 7 voltage just wen t down and the f requency went off and ,
l 8 that messed things up a lot worse than just an out and l 9 out failure.
10 I can conceive of other possible failures in, 11 say, a power supply. What would happen, for example, if ,
i 12 you had a phase reversal in the three-ptrase systems?
13 What would that do? Did you look at things like that?
O 14 WITNESS DAWEa To my knowledge, phase reversal 15 I do not believe has been looked at, to my knowledge.
16 The electrical engineers may have considered such a 17 thing.
18 With respect to the other parts of what you 19 are referring to, again, later studies are referenced 20 that we are doing to look at the kinds of things that 21 you have talked about in specific response to things 22 like the Millstone low voltage event. We looked at that 23 one specifically for this plant very early on, and l () 24 assured ourselves that we would not have that problem of 25 relays not picking up as a result of low voltage; that l
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() 1 our tripping and bus logics were such that the transfers 2 would be made before such a voltage condition was 3 reached, either voltage or frequency.
4 JUDGE JORDAN Again, I will beat the Chairman 5 to it this time. Would you identify which study does 6 that?
7 WITNESS DAWE I think specifically, the next 8 studies in the list, the control system failures and the 9 high energy line break studies which go into the 10 non-safety side of the control systems. Particularly 11 item G, the control system failures if very much 12 supplementary to item H because it does the same kind of 13 study on the non-saf ety side, all the way up to the full 14 non-safety bus failure for the resultant effects on the 15 non-safety control systems, and what that results in in 16 terms of plant conditions that are achieved.
17 JUDGE BRENNER: Do you mean supplementary to 18 item F7 19 WITNESS DAWE4 Yes, Judge Brenner, 20 supplementary to ites F. It is the other half of the 21 same study, if you will.
22 JUDGE MORRIS: This particular study is really 23 an interaction between the power supply and equipment
() 24 that is supplied, is that right? You are not looking 25 for interactions among the different systems that are O
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() 1 supplied power from that same bus?
2 WITNESS DAWEs No. This is primarily an
{} 3 interaction study between the su pport system, the power 4 supplies and the supplied systems.
5 JUDGE MORRIS: All right.
6 BY MS. LETSCHE (Resuming)s 7 0 Okay, I would like to move on to the control 8 system failures that you address in Section G of your 9 testimony on page 59. Is this analysis which I see in 10 your testimony as ongoing, iss this also being conducted 11 by Stone & Webster?
l 12 A (WITNESS DAWE) This study is being conducted 13 by both Stone & Webster and General Electric.
)
14 Q Can you tell me what systems interaction this 15 study -- or types of system interaction -- this study is 16 intended to identify?
17 A (WITNESS DAWE) Well, it will identify the 18 interactions, again, from power sources to supplied 19 components. It will also look at the interaction of i
20 those supplied components to the state of the plant.
21 This study looks at those control systems, non-safety 22 related control systems that control components which 23 then have an effect on significant parameters of the l 24 reactor system, such as reactor pressure, reactor level, 25 reactivity control.
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() 1 This system goes to the lowest level of power 2 supply or sensor. For example, a power distribution 3 panel. And for each system which can have an effort on 4 a primary reactor parameter, we identify all of the 5 power sources for those systems. The systems that are 6 not included in the study are looked at for what their 7 function is in the plant and demonstrated that they 8 cannot have an effect such as that; namely, on a 9 principal reactor parameter.
10 We look at each power supply feeding more than 11 one control system at a time, catalog them and then 12 proceed to f ail them one at a time in a cascading effect 13 until we get back to the main bus. By that I mean if O 14 you go down to the lowest level of distribution panel, 15 each time we identify one that has two systems on it -- --
16 that is, systems which we have judged from the function 17 of the system can have these kinds of effects on the 18 level of pressure in the primary system --
19 JUDGE JORDAN: That is water level?
20 WITNESS DAWE Water level or system pressure 21 or reactivity control. We fall it, and look at the 22 resultant effects of the state into which the plant 23 goes. And then we take the one next to it, and we move 24 back to the next higher level of distribution which may 25 pick up two or three or four or six of these O
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() 1 distribution panels with all of their attendant control 2 functions that are on them, until we have worked our way
(} 3 all the way back to the non-safety buses, which is the 4 comparable side of the study to the safety buses we were 5 discussing earlier.
6 And this is a study that is being done to show 7 that the impacts of the non-safety systems from these 8 types of f ailures of sensors or power supplies will not
,2,..9 -eesult in exceeding the events that we have already 10 analyzed in Chapter 15. And tha t is currently an 11 ongoing study.
12 BY MS. LETSCHE (Resuming):
13 Q In your analysis, did you use only the total O 14 failure of that, the total failures that is, of total 15 lack of power? Did you take into account an 16 intermediate type failure of the sort Judge Jordan 17 mentioned earlier?
18 (Panel of witnesses conferring.)
19 A (WITNESS DAWE) This would be a mechanistic 20 loss of bus. If the component fails as is, then we look 21 at what the result of the failed as-is is. If the 22 component fails closed or if it f ails open, then we look 23 at that effect. So it is not just saying that it is not 24 there anymore; what we are doing is looking at what the 25 resultant plant state is as a result of loss of power to O
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() 1 the component, to the control system.
i 2 A (WITNESS IANNI) On GE's side of the fence on 3 this control system failure, there is the ongoing 4 program which was just discussed, but that is not the 5 only thing that has been done. Over the years, we have 6 completed what might be called a control system failure 7 FMEA, in which we took esch of the three control 8 systems, the pressure control system, the feedwater 9 control system and the recirculation control systea, and 10 asked ourselves what would happen if it failed on the 11 high scale, what would happen if it failed where it was, 12 and what would happen if it failed down scale.
13 And then we looked at two parts of the O 14 problem. One, is the transient that that genera tes a 15 severe transient that we have not looked at, or is it 16 less severe than the ones we have already looked at.
17 And if it was a significant transient, we put it in 18 Chapter 15. And you will find one or two there that I 19 quess are Chapter 15.
20 Then we asked the second questions How would 21 this failure affect the bounding accidents in Chapter 22 15. In other words, would a loss of cooling accident be 23 worse if a control system failed upscale, stayed put or
( 24 went downscale? And this was a pretty thorough study, 25 although it was done with those three basic failure O
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() 1 modes without asking how we got there.
2 And what we found was this: that as far as
( 3 the transients, the effect -- that is to say, the 4 transient itself, the effect on the core was minimal.
5 The minimum critical power ratio changed by only a small 6 amount, and only a few rods went into transition 7 boiling. And that is significant because that says any 8 failure of the control system in that manner, the core 9 is not damaged really.
10 Then -- and we put these in Chapter 15. Then 11 what happened was on the accident analysis conclusions, 12 it turns out that the accidents, people who do the 13 accidents, take such a conservative approach that ther O 14 do not take credit for the good side. For example, on 15 the LOCA sccident, they do not take credit for feedvater 16 anyway, so the fact that it failed on the downscale 17 would not help him. If it stayed put it would help 18 them, and if it went up it would help them. So in that 19 case, they bounded the situation.
20 Then the other thing we concluded is that for 21 transients, we always had a safety system backino it 22 up. In other word s, in no way did we jeopardize the 23 safety system such that it was not there ss a backup.
24 Now, the new study will probably show 25 something similar, but we feel that since this was ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 conducted by very senior people over a long period of 2 time, and it is not the first time we have looked at the
(} 3 effect of control systems on safety systems, and 4 hopefully with the new method it will be more thorough 5 and we will get a better answer. But right now, we feel 8 pretty good about it. It was a pretty good study.
7 JUDGE MORRISa Mr. Ianni, what does the new 8 study have in it that was not incorporated in the 9 previous study?
10 WITNESS IANNI: I would hope that it is more 11 Shoreham-unique, because the studies we did were based 12 upon a standard plant, whereas this new study will be 13 Shoreham-specific and, I imagine plant-specific in other O 14 plants, too, as needed. But the point that is important 15 here is that our control systems have not changed.
16 For instance, BWR-2 or BWR-3, they have not 17 really changed. The basic control system is the same.
l 18 The f unctions are the same. And the basic protection I 19 system is pretty much the same, so that we feel pretty 20 good about the study. 'And I think the thing that will 21 be important about this one is that it will be 22 Shoreham-unique.
23 And by the way, I think we have discussed on 24 and off here the specifics of Shoreham and so forth. I 25 think it is important to recognize from the vendor point O
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() 1 of view it is like buying a refrigerator, more or less.
2 You put it into a kitchen, all the refrigerators are the 3 same for all of the kitchens but the architect engineers 4 who design the kitchens will make each of them 5 different. Every AE has his own design, so to speak.
6 But those refricerators all fit in.
~
7 So that the idea here from a vendor point of 8 viev, when we look at design of a refrigerator and study 9 very carefully whether it goes into A's kitchen or B's 10 kitchen, it is pretty much the sam? ref rige ra tor . And I 11 think from the vendor point of view, the reactor point 12 of view, this idea of standardization is very, very 13 strong. And I think that is something to remember here
() 14 as we go on into this.
15 JUDGE BRENNER: However, if you are selling a 16 ref rigerator, you do not care how strong the ceiling is 17 because you do not care if it f alls down on it. There 18 are some differances, are there not?
19 WITNESS IANNI: Yes, that is true. Except 20 that the basic refrigerator, how it functions, how it 21 behaves:when the motor stops, what happens when the l
22 electricity goes off, that refrigerator behaves in the 23 same way, is what I am trying to say -- tha t the ba sic 24 system behaves in the same way. Certainly, external l
25 events, you are certainly correct, they-have to be O
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() 1 looked at, also.
2 JUDGE BRENNERa In my own inarticulate way, 3 what I am trying to say is you are not as concerned with 4 the interfaces when you put a refrigerator in your 5 kitchen as you might be with respect to the NSSS system 6 and the balance of plant systems in a reactor.
7 WITNESS IANNI: That is right. And that is 8 why we have the interface documentation between us and 9 the AEs to make sure that they hooked it up the right 10 way. You bet.
11 JUDGE CARPENTER: If I right ask one 12 question. Mr. Dave, did you tell me something about --
13 give me some feel for the dimensions of this new study O 14 in terms of man years or dollars or what have you, so I 15 know whether it is bigger than a bread box or smaller 16 than a bread box.
17 JUDGE HORRIS: Or a refrigerator.
18 (Laughter.)
19 WITNESS DAWEa From the Stone E Webster end, 20 it is probably approaching a man year over several j 21 months with mutliple people working on it.
22 WITNESS ROBARE: The GE portion is 23 a ppro xim a tely two man months.
() 24 WINESS DAWE: We do have in Stone & Webster 25 the larger portion of this study because the (2) l l
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5137 identification of all of the power sources and whatnot
(]) 1 2 which are within our scope of supply is a lot of sorting 3 of data for final evaluation, and it has to go to our 4 systems engineers for their evaluation of the results of 5 the failure modes and the various components, and the 6 same with 3E.
7 I say a man year. It may be two man years or 8 three, but it is in tha t range.
9 JUDGE CARPENTER: Thank you.
10 BY MS. LETSCHE (Resuming):
11 0 Do you have -- I am not real good at these man 12 years and months and things like that. Do you have an l
13 idea when the study is going to be completed?
14 A (WITNESS DAWE) I believe it is currently 15 scheduled to be completed by the end of August of this i
16 year.
17 0 The studies, or at least -- let me rephrase 18 that.
19 You state in your testimony the study is done 20 in response'to an NRC open item, is that right?
21 A (WITNESS DAWE) The specific study we are doing l
l 22 and the types of results we are looking for were agreed 23 to with the NRC in the SER process in the review of the
() 24 FSAR. However, as I said before, it is another look at 25 things we have already looked at and just another O
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() 1 approach to coming back and drawing what we think are 2 going to be the same conclusions that we ha ve been 3 drawing all alona.
4 We certainly expect that there will be no 5 major surprises in the study because we have already 6 looked at transients and transient initiators and the 7 functional relationships between the non-safety and the 8 safety components.
9 0 What do you mean in your testimony when you 10 say that you are analyzing to determine that the 11 failures referenced here will not result in consequences 12 outside the bounds of Chapter 15 analysis? What do you 13 mean by outside the bounds of that analysis?
14 A (WITNESS ROBARE) The NRC stated need for this i
15 study was to provide them with assurance that failures 16 of buses with multiple control systems or sensors or 17 components would not result in a transient event that 18 was more severe than one that had already been analyzed 19 in Chapter 15.
( 20 So we are methodically looking at each failure 21 and the consequential multiple control system effects, 22 and we are concluding for each of those failures what 23 equivalent event, if any, that relates to Chapter 15.
24 For instance, certain bus failures may give you a 25 turbine trip, and if it has certain sensors also O
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() 1 associated it may give you a turbine trip without bypass.
2 So as we evaluate each bus, we come up with a 3 list of the equivalent event, or it is no event. In 4 most cases, there is no impact upon the pla nt.
5 JUDGE JORDAN: By buses, do you mean the major 6 high voltage buses, or are you talking about DC buses, 7 DC power supplies, AC instrument supplies, the works?
8 WITNESS ROBARE: I am talking about all buses 9 that have control systems, components or sensors that 10 may have an impact upon the reactor performance.
11 JUDGE JORDAN: Okay. Again, this is single 12 failure?
13 WITNESS DAWE: Judge Jordan, I think that you O 14 are most aptly correctly characterized it as the works.
15 It is AC and DC power supplies. As I said before, it 16 will go from the smallest distribution panels all the 17 way back to the 4160 volt buses. By the time you take a 18 4160 volt bus, you are are taking a lot of MCCs and a 19 lot of distribution panels. It is just a cascading 20 study. We are looking at it from the lowest level to 21 the highest level.
22 JUDGE JORDANS It is single failure?
23 WITNESS DAVE: It is single f ailu re , but it is
( 24 also -- of course, within the definition of single 25 failure, it is multiple failure if that is occurring O
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() 1 fron a single failure. And when we failed the 4160, 2 everything supplied by it is gone.
3 JUDGE JORDAN Right.
4 JUDGE BRENNER: Can you tell me what an MCC is?
5 WITNESS DAWE: An MCC is a motor control 6 center which is an electrical component within the 7 plant. Typically, it has control components in it such 8 as breakers, and it also ha s portions of it which act as 9 power supplies to instrumentation or control, so we did to the breakers themselves.
, 11 JUDGE BRENNER: So if you are performing the i
12 type of analyses you indicated on the buses, you would 13 have to include the motor control centers, given their O 14 functions?
15 WITNESS DAVE: To the extent that motor 16 control centers are in fact power supplies to other 17 sub-tiered components within the plant, yes, they are 18 considered just like power distribution panels or 19 junction boxes if they have fusing in them and so on.
20 JUDGE BRENNER: Thank you.
21 (Counsel for Suffolk County conferring.)
22 BY MS. LETSCHE (Resumino):
23 0 Mr. Dawe, has Stone & Webster done any
( 24 analysis of the non-safety related control systems prior 25 to the study that is referenced in item G7 O
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5141 (G_) 1 A (WITNESS DAWE) Yes, we have. As we have 2 stated before, the engineering analysis that goes on 3 with the design of the non-safety control systems is 4 done all the way along. There are other types of 5 control systems that have been studied. Fo r exam ple, 6 the instrumentation air system throughout the plant is a 7 control system. It is the pneumatic equivalent of an 8 electrical control system.
9 That was studied by Stone & Webster all the to way through the engineering process, and in fact, the 11 various design parameters of Stone C Webster that go l 12 into that type of design were studied for the plant.
13 The failure mode of air-operated components, the design O
14 of the determination and the design as to the fail safe 15 mode of each component, and it is being powered by or 16 controlled by the air system and so forth.
17 Yes, I think that many, many studies of the 18 plant have occurred, far more than we really put in our 19 testimony here. These were major significant integrated 20 studies that were done. We certainly did not want to 21 imply that these are the only studies that are done on 22 the plant. There are many that are done throughout all 23 stages of the engineerino. Just the engineering itself 24 is an analysis in the study of the functioning of the 25 plant.
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5142 1 Q I am sorry, Er. Dave, I should have explicitly 2 sta ted in my question to you that I was ref erring to any 3 other systems interaction studies which would relate to 4 the non-safety related equipment, which is studied in 5 item G.
6 A (WITNESS DAWE) I think that is what I was 7 answering. When you design the systems into the plant 8 and you look at the function of the system and what it 9 is expected to do, that in itself includes systems 10 interactions.
11 12 13 O 14 15 16 17 18 19 20 21 22 23 24 25 0 .
ALDERSON REPORTING COMPANY,INC, 400 VIRGINTA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
5143 O 1 o sut zou e1dn t 11st those in your oref11ed 2 t es timon y , i s th a t right?
3 A (WITNESS ROBARE) Yes, we did list those. It 4 is the turbine bypass specifically and the level 8 trip 5 in the rod block monitor as its failure increases the 6 effect of the transients.
7 Q Mr. Dawe, what techniques were used in 8 conducting this -- or are being used I guess would be 9 more accurate -- in conducting this study that is 10 referenced in item G 7.
11 A (WITNESS DAWE) I think I have just described 12 the study and how it is being done. I'm not sure what 13 more I could say about the techniques.
O 14 Q Maybe I missed that portion of your answer.
15 Has Stone and Webster constructed FMEAs in connection 16 with this analysis?
17 (Panel of witnesses conferring.)
18 A (WITNESS DAWE) FMEAs per se are not being 19 conducted for this analysis. A lot of the thought 20 process that goes into developing the FMEA -- the 21 undesired result versus the things that can cause it --
22 the study does not really lend itself to an FEMA 23 methodology. It is a very deterninistic study to the 24 extent that we know specifically what we are looking for 25 once we identify the power source failure and the O
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() 1 components in their failure mode, and it is a case of 2 going and looking at the plant and what that f ailure 3 mode causes in the state of the plant.
4 MS. LETSCHE: If the Board has any other 5 questions on this, they may ask them now. If now, I 6 vill move on to the next item.
7 JUDGE BRENNER: Please do.
8 BY MS. LETSCHE: (Resuming) 9 0 With respect to iten H, high energy line 10 break, this is another ongoing analysis. Is this also 11 being conducted by GE and Stone and Webster?
12 (Panel of witnesses conferring.)
13 A (WITNESS DAWE) Yes. It is being done both by O 14 GE and Stone and Webster.
15 0 And this is in response to an NRC request, is 16 that right? At least that is what it says in your 17 testimony here.
18 A (WITNESS DAWE) The specific study is being 19 done to respond to an NRC item in the SER, yes.
20 0 When do you anticipate that this study is 21 going to be completed?
22 A (WITNESS DAWE) I believe the current schedule 23 is in the same time frame as the previous study, at the 24 end of August or into September.
25 0 Is the GE portion of the study a O
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() 1 Shoreham-specific study, Mr. Robare?
2 A (WITNESS ROBARE) Yes, it is. It is a very
{} 3 similar study in concept to the previous control system 4 failure study, the only difference being the initiator 5 of the multiple f ailures. Once those are established by 6 Stone and Webster we will evaluate the consequences of 7 the multiple f ailures and compare them with the Chapter 8 15 events.
9 Q What failures do you assume in this analysis, 10 Hr. Dave? What is the initiating event?
11 A (WITNESS DAWE) The initiating event for these 12 studies are the high energy line breaks that we have 13 previously studied in the plant. It is really O' 14 supplementary to the high energy line break because we 15 are evaluating the effects of those high energy line 16 breaks on the nonsafety control systems in the plant, 17 looking at again the nonsafety control systems which can 18 have effects on the reactor parameters, as would a .
19 transient effect. It is the same set of nonsafety 20 control systems that we are doing for the control system 21 failures analysis, only now we are looking at the pipe 22 break initiator instead of the loss of power source or 23 loss of sensor.
24 0 In the study I take it you are attempting to 25 identify spatial interactions, is that right?
O l ALDER' SON REPOPTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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() 1 A (WITNESS DAWE) Yes In this study we are 2 identifying the spatial interactions as a result of the 3 dynamic ef fects primarily of the pipe break event. We
)
4 will also be looking at the environmental effects, but 5 we will be looking at them in terms of how they affect 6 the nonsafety components and what effect that has on the 7 plant. There are acceptance criteria, of course, for 8 the nonsafety components that will be different from 9 what our acceptance criteria was for the safety 10 components.
11 We are not requiring the nonsafety components 12 to work, but we will be looking at their failure 13 mechanisms and the timing of the f ailure mechanisms -and
()
14 what effect that has on the recovery from the pipe break 15 event.
18 (Counsel for Suffolk County conferring.)
17 0 Could you be a little more specific in 18 describing what the acceptance criteria are with respect 19 to the nonsafety-related items?
20 A (WITNESS DAWE) As we have described, the 1
l 21 acceptance criteria for this study will be to achieve 22 safe shutdown and to have no effects more significant l 23 than the transients in Chapter 15 that have been
() 24 previously analyzed. So we are really looking at two 25 things. We have already done the safe shutdown part for
}
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() I the safety-related systems, and now we're looking at the 2 eff ect on the nonsafety-related systems and balancing 3 them against the Chapter 15 transients.
4 (Counsel for Suffolk County conferring.)
5 0 I would like to move on to section I, 6 probabilistic risk assessment, on page 60 of your 7 testimony.
8 Mr. Robsre, have you reviewed the Limmerick 9 PRA? -
10 A (WITNESS ROBARE) Yes, I have. I have read 11 portions of it. I have not formally reviewed it as a
, 12 reviewer, but I have read it.
I i 13 0 Can you tell me what this reference is in your
() 14 testimony to a BWR? Is this a BWR-4 of a M ark-II plant 15 just a modifier of Limmerick?
16 A (WITNESS ROBARE) Yes.
17 JUDGE BRENNER: Excuse me. It was my fault, 18 but I missed your prior answer, Mr. Robare. Is it 19 possible for you to restate it?
l l 20 WITNESS ROBAREs Sure. She asked me if I 21 reviewed the Limmerick PRA, and my response was that I 22 had read most of the Limmerick PRA, but I had not been a 23 formal reviewer in the sense of approving it or
) 24 rontributing to its accuracy technically. .
25 JUDGE BRENNER: Thank you.
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() 1 BY MS. LETSCHE: (Resuming) 2 0 Is there a separate PRA that you have reviewed 3 that relates to a BWR-6 standard plant?
)
4 A (WITNESS ROBARE) My participation in the 5 BWR-6 PR A was similar to the Limmerick.
6 JUDGE MORRISs Was that a specific BWR-6, or I
7 is that a generic BWR-67 8 WITNESS ROBARE: It is a generic BWR-6.
9 However, it is very close to the TVA units.
10 JUDGE BRENNERs Do you mean the Hartsville 11 units?
12 WITNESS ROB? des Yes.
13 JUDGE MORRIS: This was performed by whom?
14 WITNESS ROBARE: General Electric. Both of 15 those were performed by General Electric, Limmerick and 16 Gessar.
17 JUDGE MORRIS: Mr. Robare, I assume you are l
l 18 saying General Electric did the analysis for its scope 19 of supply and not the total plant, is that correct?
20 WITNESS ROBAREs No. We did avoid the total
( 21 plant.
l 22 JUDGE MORRIS: You did containment on 23 Limmerick?
( 24 WITNESS ROBAREs No. I am sorry. ,
25 (Panel of witnesses conferring.)
I
()
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() 1 WITNESS ROBARE: We were the project manager 2 for the total PRA for both those plants. We did 3 subcontract some of the work to SAI.
4 JUDGE MORRIS: And Bechtel?
5 WITNESS B0 BARE: Yes.
l 6 BY MS. LETSCHE: (Resuming) l l 7 0 Mr. Robare, I would like for you to tell me 8 with reference to the last sentence in that section l 9 there, " Positive results indicate the effectiveness of 10 the generic BWR design, including the consideration of 11 systems interaction."
12 Can you tell me on what you base that 13 conclusion, particularly the conclusion with respect to O 14 the consideration of systems interaction?
l 15 A (WITNESS ROBARE) Well, I believe the 16 methodologies used in PRA assessments are one of the 17 better tools for assessing the potential for a systems 18 interaction, the event trees and fault trees. And since 19 the results of both of these PRAs did not indicate any 20 need for a design change, I felt that it further assured 21 the generic ef f ectiveness of the BWR design.
22 0 Did you review the particulars of the 23 methodology that was used in the Limmerick PRA?
} 24 A (WITNESS ROBARE) I reviewed the PRA, and that 25 would show the methodology, yes.
()
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() 1 A (WITNESS IANNI) I also reviewed the me thods 2 that were used, especially in the areas tha t my group 3 con trib uted to. We did a lot of the heat transfer and 4 degraded core cooling calculations for both designs, and 5 so I reviewed those rather carefully and looked over the 6 report as a whole.
7 MS. LETSCHE: Judge Brenner, I would like to 8 add ress these questions to the panelists who sponsored 9 this testimony to find the basis for their statements 10 here, which is why I was directing it to Mr. Robare.
11 WITNESS IANNIs I am sorry.
12 MR. ELLISs That does not mean, Judge, though 13 that Mr. Ianni cannot add to it since he was also O 14 present when this testimony was prepared.
15 JUDGE BRENNER: I nodded along as you were 16 telling me that because I thought you were going to tell 17 me you wanted to come back to it with the PRA witnesses, j 18 and therefore your bottom line surprised me. You can 19 exclude Mr. Ianni preliminarily if you want, but he is 20 entitled to come back later and add material. Frankly, 21 in this area I do not see the problem with his adding l
22 contemporaneous 1y with the answer as distinguished from l
23 probing a particular witness' qualifications.
( 24 MS. LETSCHE Judge Brenner, I was only saying 25 that because I was hopeful that whatever additional
)
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5151 0 ' aue tion r *ed- 1r 1 directed the to "r aohere 1 2 could get his answer. And if Mr. Ianni wishes to 3 comment, I do not have any objection to that; but I do 4 vant to get the answers of the people who have written 5 this portion of the testimony. That was the point of my 6 comment.
7 JUDGE BRENNER: Okay. Maybe I missed it. I 8 thought you did get Nr. Robare's answer first.
9 NS. LETSCHE: I did. I was talking about it 10 with respect to questions I am going to ask now.
11 JUDGE BRENNERa All right. I am with you 12 now. Let's let Mr. Robare answer first, and then if 13 anybody else wants to add anything, including Mr. Ianni, O 14 they should feel free to do so.
15 BY HS. LETSCHE4 (Resuming) 16 0 Mr. Robare, did your review of the Limmerick 17 PRA include a review of how the probabilities on the 18 fault trees were arrived at?
19 A (WITNESS ROBARE) No, it did not.
20 0 Did your review include a review of the data 21 base that was used in deriving probabilities?
22 A (WITNESS ROBARE) My review included a reading 23 of the report and discussions with the people who O 24 prepered the report end did the ectue1 werx, inc1eding 25 the probabilities and the data base. I did not O
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() 1 specifically work on the PB A for Limmerick.
2 O How about wi th the respect to the generic 3 BWR-6 PRA? You did not work on that one personally?
4 A (WITNESS ROBARE) No. My participation was 5 the same.
6 (Counsel for Suffolk County conferring.)
7 0 With respect to the Liamerick PRA these 8 component failure rates were used in that study?
9 A (WITNESS ROBARE) As I previously stated, I am 10 simply not aware of that kind of detail in the Limmerick 11 PBA or the Gessar PRA. We have people on the panel at 12 the appropriate time who can address that.
13 (Panel of witnesses conferring.)
O 14 (Counsel for Suffolk County conferring.)
15 A (VITNESS ROBARE) I would like to say that my 16 main purpose for including these in the testimony was 17 that the results I feel are appropriate to Shoreham in 18 that they showed the generic BWR quality even though 19 these are no t specific Shoreham PR As. The Shoreham PRA 20 is mentioned later on. But as a design tool and as a 21 way to provide experience for our designers, those 22 particular PRAs I thought were of value in confirming 23 the adequacy of Shoreham and BWRs in general.
) 24 0 How did Shoreham I guess I am a little 25 confused as to why the Limmerick PRA and the Gessar PBA O
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() 1 are listed here as systems interaction studies. The 2 implication is that they are relevant to Shoreham. What 3 exactly did your review of these studies or the 4 existence of these studies, what impact did that have on 5 the Shoreham plant?
6 A (WITNESS ROBARE) I thought I just answered
{
l 7 that in my previous answer. It provided our designers 8 witn assurance of the adequacy of the Shoreham design.
9 The f act that no generic changes were discovered to be to needed from the Limmerick and the Gessar PR A provides 11 f urther assurance of the Shoreham design adequacy. That 12 is the reason I listed them as appropriate for systems 13 interaction studies in our testimony.
14 0 But your conclusions would be limited to the 15 generic aspect of those studies, is that correct?
16 A (WITNESS ROBARE) That is correct. And often 17 that is a very appropriate thing at General Electric.
18 Our engineers work on multiple plants, and if a problem 19 is found on one, they evaluate each plant. And it 20 turned out there were no problems developed from these 21 particular studies.
22 Q So there were not any -- the results of those 23 studies did not lead you to make any changes or decide
() 24 to think about making any changes at Shoreham, is that 25 right?
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5154 l
() 1 A (WITNESS ROBARE) That is correct.
2 A (WITNESS IANNI) May I add to tha t?
3 0 Yes, you may.
4 A (WITNESS IANNI) The reason that the generic 5 design is applicable to Shoreham like he stated is 6 generic in that the basic systems are pretty much the 7 same for the standard plant at Shoreham except for the 8 high pressure core spray, and the key difference is in 9 the containment area since that has got a Mark-III 10 whereas Shoreham has a Mark-II. And so the results at 11 the far end turned out to be somewhat different. But 12 the important thing is that the PR A serves as a check on 13 the designers, and we draw confort from that because O 14 since the systems are so much alike, why, if the answers 15 come out greatly different, you are suspicious.
l l 16 And over and over we find as we do these I 17 calculations that the answers had better be in the 18 ballpark so that there is more similarities than there 19 are diff erences, especially at the reactor level, so 20 they are very effective from a checkpoint view. And 21 there was nothing that stuck out like a sore thumb, in 22 other words, across the spectrum. That is the reason 23 you draw comfort from it.
I
() ,
24 0 Mr. Kascsak, I believe you stated earlier that 25 you had some f amiliarity with the Limmerick PRA. Do you O
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() 1 have any familiarity with the Gessar PRA that Mr. Robare 2 referenced?
3 A (WITNESS KASCSAK) No, I do not.
4 0 Did you personally review the entire Limmerick 5 PRA report?
6 A (WITNESS KASCSAK) We have copies of the 7 entire Limmerick report, and I have reviewed it, not in 8 great detail but in some detail.
9 Q A re you -- did you review the data base upon 10 which, or are you familiar with the data base upon which 11 the probabilities used in that PRA are based?
12 A (WITNESS KASCSAK) Yes, I am familiar with 13 those data bases.
! 14 0 Do you know whose component f ailure data were l
15 used in that study?
16 A (WITNESS KASCSAK) Well, I understand the 17 spectrum of data that was used in that study, and I 18 understand that -- I understand the process by which one 19 specific analysis performed, how the available data 20 bases are considered to evaluate the best data base to 21 be used in a particular plant analysis, considering 22 7eneric data bases, considering utilities' specific data 23 bases, if they are appropriate to a particular system or
( 24 component within a plant, if that data exists. And the 25 type of approach that was used on Limmerick is similar l
O ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
5156 O ' to the eo co ca en t o e4 oa snorene nea e at 2 through the same thought processes to develop the 3 appropriate data bases to be used in the Shoreham 4 analysis.
5 Q Do you know what the component failure data 6 was that was used in the Limmerick PRA?
7 (Panel of witnesses conferring.)
8 A (WITNESS KASCSAK) Well, I think, as I have 9 stated, there is a spectrum of data bases, a composite 10 of different data bases that exists and are selected on 11 a case-by-case basis by the contractors involved in the 12 analysis and agreed upon with the utility.
13 0 That is what I as asking you. Do you know O 14 wha t was selected for Limmerick ?
15 A (WITNESS KASCSAK ) I know in general what was 16 selected. On a case-by-case basis I would have to look 17 at the analysis to find it out.
18 0 So the answer is you do not know?
19 (Panel of witnesses conferring.)
20 MS. LETSCHEs I am just trying to get an 21 answer to my question, Judge Brenner.
22 JUDGE BRENNER: I understand.
23 (Panel of witnesses conferring.)
24 JUDGE BRENNER: I do not consider a grunt of 25 displeasura objections either.
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() 1 WITNESS KASCSAKs Maybe you could restate your 2 question one more time.
3 HS. LETSCHE Maybe the Reporter could read it 4 back.
5 (The Reporter read the record as requested. )
6 (Discussion off the record.)
7 JUDGE BRENNER: This is a fine area, but I 8 have a sense tha t preliminarily the questioner is going 9 to Mr. Kascsak's knowledge here and through him LILCO's 10 knowledge.
11 You have given a series of answers, Mr.
12 Kascsak, as to generally what component failure -- how 13 component failure methodology is arrived at in the O 14 Limmerick PR A and in the Shoreham PRA, for and from 15 which data bases. And you have stated, as a good lawyer 16 might, that appropriate data bases are looked at in 17 appropriate circumstances.
18 What she is trying to find out is if you can 19 tell her how the component failures were arrived at in 20 the Limmerick PRA through the use of data bases, and you 21 responded that you would have to look at each one, but G
22 you could tell her in general. And I guess the followup 23 question to that would be what would you state in
() 24 general if you cannot tell her in any other fashion?
25 WITNESS KASCSAKs In general there are three O
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() 1 or four possibly broad data bases. There is the EPRI 2 data base, there is an NRC data base, and there is a GE j 3 data base, and in certain cases there is a 4 utility-specific data base. The Philadelphia Electric, 5 in particular with the Peachbottom units, had data bases 6 established through the operating of their plants that 7 were applicable to the Limmerick design. Many of the 8 situations like failure of loss of offsite power which 9 would be specific to the electrical grid system, the 10 LILCO electrical grid system, was appropriate to use 11 data that was associated with the failure of our offsite 12 power supply. So all of those data bases are used in 13 discussions with the contractor and the utility to
()
l 14 decide which data is best to use for a particular fault l 15 tree or event tree.
i 16 BY MS. LETSCHE. (Resuming) 17 Q With respect to the Limmerick PRA I think some 18 of your answer was talking about what LILCO has done in 19 LILCO 's PR A . Do you know, Mr. Kascsak, how those 20 different data bases, what hierarchy was used, which 21 portions of which were used in the Limmerick PRA? That 22 is my question.
23 A (WITNESS KASCSAK) I do not know the specifics
() 24 of how that selection was made, no.
25 MR. ELLIS Judge, there was a comment tha t O
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() 1 you made in the course of talking about the testimony 2 about testing Mr. Kascsak's knowledge and therefore j 3 LILCO 's knowledge. I do not think that we were l
t 4 necessarily advised that we had to have the person who 5 reviewed or the person who had the most precise 6 knowledge about the Limmerick PR A on the board -- on the 7 panel. And to the extent that that --
8 JUDGE BRENNER: You can come back later with 9 anything you want, and if Mr. Kasesak in his answer had i
10 said Joe Smith at LILCO is the one who really knows 11 this, that would have helped me, too, but he did not say 12 that. You see, I am not very smart. All I know is what
! 13 I read in the testimony for starters, and on page 60 14 under probabilistic risk assessment there is the 15 sentence which references the Gessar standard PBA and 16 the Limmerick PRA, and the sentence that follows states, 17 "The positive results of these studies indicate the 18 effectiveness of the generic BWR design, including the i
19 consideration of systems interactions."
l 20 I think with that sentence the questioner is 21 e n titled to pursue how that was plugged in for 22 Shoreham. She did pursue it with Stone and Webster and 23 GE witnesses. Then she pursued it with Mr. Kascsak,
() 24 partially, I will submit, because at the beginning of 25 the questioning today Mr. Kascsak made a point of
(
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
5160 0 1 distinouishino, accordino to m1 notes, the suboart on 2 study from the others in which he said he only performed 3 a general review. He said he is familiar with what is 4 in the Limserick PRA snd in fact has repeated it in some 5 detail.
6 So that is all I know. That does not mean 7 that there is not somebody else at LILCO who does not 8 know more, but I am not clairvoyant.
9 MR. ELLISs Fine. Well, I will just ask him 10 on redirect. Thank you, Judge.
11 JUDGE BRENNER: And that was ,the basis for my 12 comment, and if I did mischaracterize the situation, you 13 are free to come back.
O 14 BY MS. LETSCHE: (Resuming) 15 0 Mr. Kas:sak, does the Lianerick PRA report 16 tha t you have reviewed or th'at you have some familiarity 17 with have a separate discussion on systems interactions?
18 A (WITNESS KASCSAK) My recollection is that it 19 has a similar discussion to - what is contained in the 20 Shoreham PRA relative to the types of interactions that 21 are addressed in terms of the methodology that is used.
22 I would have to look at the report to refresh my memory 23 on the exact details of how that is presented in the 24 analysis.
25 0 Mr. Dswa, sre you f amiliar with the Gessar PR A O
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() 1 that is referenced in this section of the testimony?
2 A (WITNESS DAWE) Ms. Letsche, I have no
! 3 firsthand knowledge of either of these PRAs that are i 4 referenced in this portion of the te stim ony . However, 5 as a co-author of this portion of the testimony I l
6 certainly can support the philosophy with which these 7 were presented, namely that there are great similarities 8 between these plants, particularly in the NSSS area, l 9 although they have different AEs and have slightly 10 different balance of plant designs.
11 As engineers we look for data and information 12 throughout the industry, and in.the vein in which these 13 were presented from my perspective I can see the
) 14 similarities of the planta, and to the extent that a l
l 15 plant can be subjected to a detailed study such as l
16 that. And you earlier said you made no changes because 17 of it.
18 I take personal satisfaction and comfort in 19 tha t fact, that there were no particular problems in 20 that type of a design that came from that kind of a 21 study. But that is the extent of my knowledge and 22 participation in that portion of the testimony.
23 JUDGE BRENNER: Who wrote this subpart of the
( 24 testimony, subpart I on page 60?
25 WITNESS ROBARE: I think it was my idea.
i t
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() 1 JUDGE BRENNER4 So if somebody wanted to probe 2 with the panel the bases for the conclusion in subpart l 3 I, you would be the most appropriate person to probe it 4 with?
5 WITNESS ROBARE: Yes. -
6 WITNESS IANNI: M ay I add something to that?
7 MS. LETSCHE4 Certainly.
8 WITNESS IANNIa I guess when we split this 9 right up, Mr. Robare took this and included it in his 10 writeup. I happened to be a little more familiar with 11 it, to be closer to it. But at GE we tend to do things
( 12 fairly standardized, and we used three failure rate i 13 data. We used the so-called NRC data. We have some of
() 14 our own data. We have got quite an extensive data bank 15 of our own, of BURS. And then there is the other one, 16 the third d a ta , which is discussed in the report right 17 here.
18 Let us see here. And these three, basically 19 there is the WASH-1400 data, the GE data, and the NRC 20 data. Those three data bases we take and we compared 21 the data bases, and then the probability people went -
22' through a fairly sophisticated combination analysis of 23 some sort which I am not sophisticated enough to explain
/"%
(_) 24 to you in detail, but it is in the report. And that was 25 the data that was used in the standard plant.
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() 1 Now, I suspect -- an'd I can check this -- I 2 suspect that we used the same technique in the limmerick 3 report because we generally do things the same way. But 4 it is not just a simple case of going to a data bank and 5 pulling out a number and applying it. It is much more 6 sophisticated than that, and I think some of the expert 7 PRA people can shed better light on it than I can.
8 JUDGE CARPENTERS May I interject something?
9 I do not believe the quality of either the Limmerick PR A to or the BWR-6 standard plant are subject for litigation 11 before this Board. We just spent 15 minutes because one 12 witness would not say "I do not know." I just cannot 13 believe this exchan. i am sorry. I do not think that 14 is the question here at all. The question was do you 15 know the data base and that is, I thought, all that you 16 have asked four times.
17 I am sorry we have gotten so far afield from 18 the question. And specifically, in the Board order of 19 March 15 th with respect to Shoreham, the suggestion was 20 the quality of the PRA was not to be a subject for 21 litigation. Now we are off discussing the quality of 22 other PR As. I am sorry. I just see us taking a long 23 time to get to wherever you are trying to get to.
() 24 JUDGE BRENNER: Let me make sure I interpret 25 your comment correctly. You are not criticizing the ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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() 1 question; you are criticizing the answers?
2 JUDGE CARPENTERS I think the panel is trying 3 to be helpful, without question, but I think they are 4 going off in directions that the examiner did not 5 suggest you go at all.
6 MR. ELLIS: But if the data base -- if the 7 correctness of the PRAs is not an issue, then the 8 correctness of the data base is not an issue either. It 9 is just the conclusion of the PRA in this instance.
10 JUDGE BRENNER: 'J ell, I do not think we have 11 to rule on your comment at this point. I, for one, do 12 not f ully ag ree with it, Mr. Ellis, for what that is 13 worth, and I do not think that is consistent with the O 14 distinction we drew in our ruling last week .
15 JUDGE JORDANS At the risk of prolonging this 16 discussion --
17 (Laughter.)
l 18 -- I wanted to make sure, are you saying that 19 the Llanerick and BWR-6 PRAs -- are you saying tha t
( 20 systems interactions were specifically included in the 21 assignments of the probabilities of failure, and are you 22 saying that as a consequence of these inclusions that 23 the f ailure rate was not increased in any mode? In
() 24 other words, that the failure probabilities to core melt 25 was not influenced by any systems in ter actions? Or O
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() 1 would you clarify then when you say that they fall to 2 identify sny systems interactions, do you mean that they 3 did include systems interactions and that those 4 contributed only a negligible amount to the overall 5 failure?
8 WITNESS IANNI I mean the latter, that 7 systems interactions were, included, and in the report 8 you will find extensive discussions by operator acting 9 under stress and data probabilities from various sources 10 of our breeder reactor reacting with equipment and so 11 forth. It is laced with that kind of informa tion.
12 What I as saying is that whatever systems 13 interactions were included, that were included, that did O 14 not affect the casults to such an extent that something 15 stuck out as being highly probable.
16 JUDGE JORDANS Okay. I think that is what I 17 had understood you to say. Fine.
18 JUDGE BRENNER Ms. Letsch e, are you going to 19 finish with this subpart I soon?
20 MS. LETSCHEa Judge Brenner, I think I am 21 finished with it now.
22 JUDGE BRENNER: Then I think we had better 23 break for the day. We have some logistical problems in
() 24 moving things to the other hearing room for tomorrow.
25 All right. We will resume at 9:00 tomorrow O
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5166 1 morning at the County Legislature's hearing room.
2 (Whereupon, at 5:00 p.m., the hearing was 3 recessed, to be reconvened at 9:00 a.m., the following 4 day, Wednesday, June 23, 1982.)
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NUC::. EAR REGUI.ATORT COMMISSICN This is to certify that the attached proceedings before the BEFORE THE ATOMIC SAFETY & LICENSING BOARD in the 2atter of; Long Island Lighting Company (Shoreham Nuclear Power station)
Date of Proceeding: June 22, 1982 Docket
!!u:::bar: 50-322 OL
, Place of Proceeding: Riverhead, New York were held as herein appears, and that this is the original transcript thereof for the file of the Coc::sission., ,
Ray Heer Official ?leporter (Typed)
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'Officia aporter (Signature) l
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